HomeMy WebLinkAbout0611\UJefferson County Long Range Planning
Attn: David Wayne Johnson
Transmitted via email
November 27,2009
Re:Brinnon Master Planned Resort
Scoping for the "Programatic" EIS
The Hood Canal EnvironmentalCouncil (HCEC) has been involved in Jefferson
County's approval process for the Statesman Group's proposed Pleasant Harbor Marina
and Golf Resort since the spring of 2006. HCEC submitted written and oraltestimony to
the Department of Community Development (DCD) during the scoping and Draft
Environmental Imoact Statement (DEIS) oublic inout neriods for the nronosed
Comprehensive Plan Amendment and Master Plan. We also attended the public scoping
meeting for the "programmatic" EIS on October 28,2009 and are participating in the
public comment period for that document in writing.
We applaud the developer's interest in solar energy mentioned in the meeting as well as
the reduction in impervious surfaces. We would like to see statements made publicly (in
the papers, during public meetings, in advertisements, on the internet, etc) by the
Statesman Group and/or it's representatives regarding specific details of the resort be
included in the FEIS and development agreements. We incorporate those publicly
distributed documents, presentations, dvd's and ads by reference.
The HCEC has consistently expressed serious concerns about the Statesman Group's
proposal for a Master Planned Resort (MPR). We believe that it will result in
unacceptable environmental impacts to Hood Canal, undermine the complex research and
recovery efforts currently under way to determine probable causes and possible solutions
to the serious water quality problems plaguing the canal, and result in undesirable
changes to the rural character of the area. These and more specific concerns, e.g. water
rights, wastewater treatment method, adequacy of stormwater plans, and wetlands
mitigation, were spelled out in our l0-14-07letter to the DCD, hereby incorporated by
reference.
In addition, we would like to see the following addressed:
The Jefferson County Website includes a link to a document entitled 6'Master
Planned Resorts Washington Style" which we incorporate by reference. This
document includes input from county officials in Washington and Oregon on
issues that they have had with their own master planned resorts. According to the
document, less than l0% of the resorts have been profitable for the original
developer. The document covers resorts built over the last 30 years and covers
better economic times than we are experiencing now. MPR's are designed to be
self-contained and must, according to RCW 36.70,{.350 pay for the services they
require, yet there is a growing body of information that says they don't. Counties
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and the State (taxpayers) are frequently burdened with expenses that should be
attributed to these resorts.
The issues that residents have with the Black Point project are well researched
and valid. Economic issues quickly become environmental issues. In practice,
other resorts have made employment promises to local residents that have not
been fulfilled in part because resorts bring in college students and immigrant
labor. Affordable housing issues abound. Tourist accommodations become
permanent residences in a setting that provides very little in the way ofjobs or
goods and services, causing the residents to travel frequently from their rural
housing to urban centers. Traffic issues in rural areas become a primary concern.
The rural area experiences sprawl and urban-like traffic congestion, crime, need
for services grow...resort residents become voters with little understanding of
rural issues.... . .in short, most resorts are not self-contained over time and they
eventually characterize an area instead of being a more passive participant as they
were originally designed to be.
All Level of Service (LOS) noted must be updated to current levels. Services
that can have significant effects on county and state oversight ofprojects, services
received from the county by Statesman Group, and social services provided to
residents have all been reduces dramatically. Reduction in services can have a
direct environmental impact.
We question whether Jefferson County has the resources necessar7 for the
regulatory oversight required for this project. The additional burden of
administering and/or ensuring compliance with multiple permit applications and
resource management plans described in the FEIS, e.g. stormwater management
plan, golf course aquifer protection guidelines, LID site design (with the state),
habitat management plan, Shellfish Protection District requirements, and pet
management plan, will undoubtedly strain already tight budgets and staff.
All data and research should be updated to current. There has been a
tremendous amount of new research in the past two years. For example, studies of
the Hood Cana| Stormwater management, Traffic studies from DOT, etc.
Statements in the FEIS stating law enforcement LOS required by the
developer are not revenue dependent are misleading and should be
corrected. Levels of service are directly dependent on funding and can have a
direct environmental impact.
The FEIS statement that there is no or limited runoff to the Canal from the
majority of the site should be verified. The water pictured below appears to
travel through the resort property. Additional photographs show water flowing
through the marina area. Water patterns should be verified during and
immediately after a rain event such as the 30" of rain received in the month of
November of this year.
Dr. Hoerner wrote an in-depth letter regarding stormwater and traffic issues
dated 12/6108 which is included in the FEIS, and we incorporate those
comments by reference and as relevant issues for this EIS.
Golf courses and lawns should be receiving a permeability rating that is a
low percentage of natural, undisturbed terrain. Golf trade publications
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provide volumes of information on how permeability is lost due to compaction
from equipment, overhead watering and foot traffic. Permeability is typically low
on both because maintaining permeability is difficult and expensive.
Extremely dry summers and variably wet winters typify the Brinnon area. In
a month such as this, stormwater collection, holding and treatment would
have to handle in the area of 35.45 million gallons of water in 30 days.lf the
"natural but disturbed areas" had a functional permeability rating of 50%, the
stormwater collection, holding and treatment systems would need to handle
another 50 million gallons for a total of 85.45 million gallons of water in 30 days.
Stormwater holding and treatment in the maritime village area would have to be
built to handle 6.63 million gallons in 30 days. Not only did the area receive over
30" of rain in 30 days, over l0" fell in one 24-hour period. Stormwater systems
for this 24-hour event would have to be designed to handle I 1.82 million gallons
(lTYoimpervious), add another 16.68 million gallons or a total of 28.5 million
gallons (if disturbed soils are given a 50% permeability rating), and the system for
the maritime village alone would have to handle 2.2 million gallons in 24 hours.
This does not include the obvious requirement to build for a 50 & 100-year storm
nor safety margins nor the volume of the 5 streams that cross the Maritime
Village area.
Because the Brinnon area typically experiences extremely dry summers,
permeability of all soils for the first rains in the winter is low with high
runoff. When the soil particles become as dry as is typical, they retain an
electrical charge, which repels water molecules. Absorption is slow and low.
After about 15" of rain this November we finally saw soils moist below l" in
depth.
Even with the winter rains, the availability of potable water is a key issue and
we incorporate by reference, The Brinnon Group's letter dated 0lll8l09,
addressed to the Department of Ecology. The letter gives an in-depth
description of saltwater incursion issues and the fact that the developer has likely
underestimated water usage significantly among other issues. It should be noted
that there are a number of wells where saltwater incursion has already occurred as
confirmed by the Department of Ecology. One is a wellowned by Statesman
Group. Another set of wells is located adjacent to that of a Statesman
representative. Another well near Pleasant Harbor has gone functionally dry in l0
years.
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In viewing Statesman's models and conceptual drawings of the proposed
resort, we believe the developer is modeling what it plans to build. If not, the
drawings would potentially mislead investors. The shoreline along Pleasant
Harbor does not appear to retain any natural buffer. It appears that the paved or
cement "promenade" is directly next to the water (first and third drawing). No
buffer is shown on the high bank above Hood Canal where the golf course
appears to be within a few feet of the steep bluff and clearly visible from the
water (2'd drawing). No buffer appears to be shown in the drawing above (4'h
drawing), with wide expanses of lawn stretching to the water. The illustrations
show a clear lack of understanding of key environmental issues in the northwest.
A statement made in the presentation at the last public meeting stated that this
land was "made for a resort". This conflicts with our beliefs on the most
fundamental level; that we all rely on a healthy environment for our own health
but also that the environment has intrinsic value in and of itself. We believe it
should not simply be consider raw material to be used for short-term economic
gain.
Float plane use of Pleasant Harbor is mentioned as not in Statesman Group's
plans but showcased on its website.
Views of the resort built environment should be filtered or hidden. Light
should be shielded from the night sky and from the water. Information on the
resort on the Internet describes expansive views of the mountains and Hood
Canal. This would imply that the views will be intrusive when reversed and that
the resort will have significant visual and light impact from the mountains and
water.
The model of the resort presented at the latest meeting shows standalone
trees surrounded by what looks to be lawn in a rendition that looks much
more like California than the Olympic Peninsula. This type of "landscaping"
should not count towards fully pervious surfaces or be given a classification
as natural. It does not fit in with natural vegetation in the area, nor does it
possess the degree of permeability that a group of trees and natural vegetation like
salal and sword fern would afford
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. Assure that the resort receives the Platinum certification from Built Green
Ca (Canada) that was promised publicly in a Port Townsend Leader ad.
o Statesman should be strongly encouraged to reduce all lawn and intensely
maintained golf course surface area. Today individuals are being coaxed to
shrink or remove their lawns due to environmental concerns ranging from
fertilizer, pesticide and herbicide runoff monoculture issues and the
corresponding loss of species diversity, high carbon usage from equipment used
in the intensive needs of lawn care, etc. Corporations should be encouraged
similarly. The golf course in the developer's plan is located directly above an
aquifer recharge area. It is located on the Hood Canal, a body of water that is
already known to be in serious environmental trouble. It is located in a County
with an existing world class golf course in it's other Master Planned Resort, less
than 30 miles away. That golf course has been reported to be in financial trouble
and has closed a portion to reduce costs. The pictures of the planned resort show
acres of lawn in addition to the golf course.
. The golf course should be organic. In cases where golf courses are located near
sensitive bodies of water there is growing use of organic growing methods to
combat herbicide and pesticide runoff. While it is not apanacea, organic
management will reduce potential for contamination of Hood Canal. It is common
knowledge that conventional golf courses do pollute in this manner.
o All runoff from the golf course should be captured and treated. Nutrients that
are used should be removed from runoff before it leaves the resort.
. Pharmaceuticals and hormones present in recycled wastewater should be
removed. The resort management seeks to inject water back into the aquifer after
treatment. The treatment should include removal of pharmaceuticals and
hormones as well as nutrients, bacteria, viruses, etc. If this does not occur and
contaminants enter the aquifer and are used repeatedly for potable water, the
contaminants may become more concentrated over time.
o Treatment of stormwater should be held to the highest current standard.
r Statesman Group's assurance that revenue from the resort will mitigate
community issues, infrastructure costs, or correction of environmental issues
brought on by the resort is not enough. There are many actual cases where
optimistic economic development statistics have not measured up to revenues,
ultimately costing the environment, taxpayers, counties and the state.o Tight timetables for resolution, specific remedies, methods for attributing
responsibility, and specific details on who will pay for any damage to the
environment to avoid no net loss should be detailed. Simply "working with the
County" does not necessarily solve the problem nor fulfill the State's mandate for
no net loss.o It is not acceptable for mitigation to be simply considering the problem or
issue. Mitigation should always offer a remedy that accomplishes no net loss
of habitat or ecological function. It is well known that mitigation attempts often
fall short of their intended goal- a situation we cannot afford.
r It should be noted that the shoulders on Hwy 101 in the vicinity are well
under 3 feet in many places and 10 foot wide shoulders are hard to find. A
typical mountain bike is about26" wide at the handlebars and it is not uncommon
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to be passed by two large RV's going opposite directions when biking on the
highway. Guardrails encroach on much of the shoulder. In the FEIS it was stated
that Hwy l0l has 3 to l0 foot wide shoulders Biking, which is an envisioned
activity of resort residents and visitors is extremely dangerous from Walker
Mountain south.
Non-motorized activities should be encouraged and a safe walking and
biking trail should be mandated to facilitate non-vehicle traffic between the
town of Brinnon and the resort.
It should be noted that drivers on Hwy 101 south of Brinnon are often
unaware of the treacherous road conditions contrary to a statement in the
FEIS. Drivers are often on vacation and unfamiliar with the area. This is born out
by the many accidents attributed to inattention.
Full DOT accident statistics must be used. Accidents in the area of the
proposed resort are only counted at intersections in the FEIS. Most accidents on
Hwy l0l do not occur at intersections. For example, there has been a recent
fatality within a mile of the resort, numerous accidents on Walker Mountain, a
fueltanker accident just south of Duckabush Rd., two serious accidents on the hill
just south ofthe resort entrance, and none ofthese recent accidents would be
counted as accidents at intersections.
The FEIS traffic projections show that the resort is expected to more than
double traffic in the local area. There are discrepancies with regard to the
extrapolation of new traffic patterns that do not follow current traffic patterns.
The resort can be expected to double highway stormwater issues, local traffic
accidents, wear and tear on the highway and local roads, area fuel usage, highway
related emergency services and so on. Every attempt should be made to reduce the
additional trips for a variety of environmental reasons. This should be mitigated at
the state and county level.
Resort traffic between the maritime village and the golf course crosses the
intersection between Black Point Rd and Hwy l0l. This will create 4-way
traffic at or near the intersection and should be considered.
Property to the north side of Hwy 101 (also north of the marina) is owned by
the developer but not included in the MPR map. This property should be
specifically excluded from serving the resort in any way.
It has been said that we should not assume that mitigation and engineering
efforts will fail, however there are many cases where they do. We are
including photos of the Washington Department of Fish & Wildlife boat ramp in
Pleasant Harbor. These photos cover three years and appear on the next pages.
Water flows into Pleasant Harbor and the marina can be seen in photos l&5.
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Climate change must be considered. Dramatic changes in weather can be
expected with weather events increasing in intensity. Similarly, this area has a
high earthquake danger. The effects of such an event should be considered with
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regard to structural integrity of all waste holding areas, areas of chemical,
fertilizer or fuel containment, and geothermal wells where anti-freeze of other
fluids may be lost directly into the aquifer.
The carbon footprint of the resort must be considered. Most if not all supplies,
guests and residents, and potentially many employees will be received by vehicle
or plane. It will truck out most if not allof its waste. Therefore HCEC takes issue
with the resort being characterized as a "sustainable green space."
Affordable housing is a primary concern. The FEIS estimates 40 full+ime jobs.
The Statesman Group has claimed in local papers that it expects to create 280
jobs. One might assume that240jobs will be part-time and seasonal. Housing 50-
I l0 of those leaves anotherl30-190 to commute over long distances or find
affordable housing in the area on a part-time, likely minimum wage job. It has
been noted that there is very little inventory in the area. We are aware of cases in
which, under similar circumstances, employees or those seasonally unemployed
find their housing in unheated storage units, creating an immediate social and
public health crisis which can quickly become an environmental issue, The carbon
footprint of employee travel needs to be considered.
We would like to see the "programmatic EIS" present a reasonable alternative with less
environmental impact. We support an alternative that would halve the number of housing
units and increase the affordable housing units by 100%.
Since it would be in the best interest of the County to protect and support the viability of
it's first Master Planned Resort and protect Hood Canal, we suggest eliminating the Golf
course at Pleasant Harbor and offering a shuttle service to the world-class golf course
already built in Port Ludlow. This more accurately reflects the focus of the Brinnon area
on enjoyment of the Olympic National Forest and one of the "gateways" to the Olympic
National Park. It offers visitors other options for staying in the area. Jefferson County is
comprised of almost 90Yo state and federal land and should use this unique asset to its
best advantage. At 445 units, and at an estimated 2.2 individuals per unit, the resort still
dwarfs the year-round population of Brinnon, and is a compromise. Increasing the
number of affordable housing units will help stabilize and ensure a happier, healthier
workforce.
The reduction in units and removal of the golf course would lower the environmental
impact of the resort considerably, potentially reducing the extensive cut and fill needed to
build the golf course and additional ERU's, reducing potable water needs, reducing
energy consumption, lowering carbon footprint, and so on.
The argument has been made that a smaller resort will not be cost effective. It should be
noted that the Statesman Group has developed other, smaller resorts and in fact, does not
appear to own a resort incorporating a golf course of it's own. In these times, larger resort
owners are dealing with lack of profitability and the effect can be greater because they
usually are more highly leveraged.
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Respectful ly submitted,
Andrea Mitchell
Board Member
Hood Canal Environmental Council
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