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HomeMy WebLinkAbout031Michelle Farfan From: David W. Johnson <dwjohnson@cojefferson.wa.us> Sent: Monday, May 10, 2010 5:13 PM To: Al Scalf, Stacie Hoskins Subject: FW: Port Gamble S'Klallam Tribe Concerns Attachments: PGST_Concerns_Outline-May5-10.pdf FYI From: VMorrisCS@aol.com [mailto:VMorrisCS@aol.com] Sent: Thursday, May 06, 2010 1:49 PM To: David W. Johnson Cc: Garth@statesmancorporation.com; peckassoc@comcast.net Subject: Port Gamble S'Klallam Tribe Concerns David In response to your request during our Pleasant Harbor MPR SEIS status report conversation this morning, I have attached the Port Gamble S'Klallam Tribe "Statement of Concerns" document prepared by Jessica Coyle, Tribal Response Program Manager, sent to Garth yesterday. It is my understanding (from a message I received from Garth) that he plans to schedule a meeting with Jessica and others in June or July. The Tribe's Statement of Concerns identifies technical reports they would like to review to confirm compliance with the 30 BoCC conditions imposed on the Master Planned Resort. As you know, all of these reports are still in -preparation. More thorough information will be completed to fully support preparation of the draft SEIS. Vicki Vicki Morris Consulting Services 7732 18th Avenue NE Seattle, WA 98115-4426 206.522.8057 Cellular: 206.501.8227 FAX: 206.523.4648 May 5, 2010 STATEMENT OF CONCERNS The purpose of this document is to provide a general outline of some of the concerns of the Port Gamble S'Klallam Tribe. The hope is that this document will provide some guidance for our meeting on May 10, 2010. Many of the topics we would like to discuss are in relation to 30 conditions contained in ordinance 01-0128-08 , (e.g. 63. a-dd) (January 28, 2008)(See Attached).that the Jefferson Board of County Commissioners adopted in 2008, which our tribe was involved in creating. This document will reference the specific conditions and comment on the Tribe's related concerns. It is important to note that this list does not completely cover all our potential concerns, as more may arise in the future, which is why we hope to establish some form of communication with Statesman. It is important for Statesman to involve the S'Klallam Tribes in the planning of this Master Planned Resort (MPR). Our tribes have protected treaty rights to this project area as well as critical natural resources in the surrounding environment. We understand that all the requirements outlined in the 30 conditions may not be complete, but we are asking to be involved in the development of these requirements. Condition a): This requires an environmental impacts analysis, which includes producing rainfall projections, runoff projections and potential impacts to the Hood Canal. We would like documentation that this has been completed and a copy of this documentation. In particular, we would like to see an impact analysis on the resources of the Hood Canal, such as shellfish, finfish and habitat. Condition h): Ecological impacts analysis. Statesman has identified two kettles within the project footprint, but there appears to be four kettles, or at least two other forms of wetlands. This raises some questions: Kettle "A" is planned to be used as a Class A water holding system; is it possible to preserve this kettle and use a storage tank? If development plans go forward with this, an archaeologist needs to be onsite, as these kettle features have proven to be archaeological hot spots. Kettle "B" has been chosen for preservation, what about the two other wetland features on the project site? Condition i): Report of Environmental Scientist. Reports on the impacts of hydrology and hydrogeology from using Kettle "A" for water storage are to be created. We would like documentation that this has been completed and a copy of this documentation. Condition j): Cultural Resource Protection. This provision requires Tribes be consulted on cultural resources. This consultation must include the S'Klallam Tribes and is not a one time consultation. This still needs to occur here. Condition k): Memorandum of Understanding with Local Tribes. The S'Klallam are a Local Tribe and there is no such Memorandum at this time. Some form of memorandum of understanding from local tribes is necessary before the County issues permits. We are one of those tribes as we have legally proven treaty rights in the project area. Condition 1): A wildlife management plan is required with consultation by the Local Tribes. The S'Klallam are a local Tribe and have not yet been consulted. We would like documentation that this has been completed and a copy of this documentation. In addition, the Tribes request the opportunity for consultation on the final plan as required in the ordinance. Condition m): Adequacy of Water Rights. We would like documentation whether water rights have been obtained and whether a supply has been identified. Condition q): Stormwater Discharge. This requires that stormwater discharge from the golf course shall meet requirements of zero discharge. We would like documentation on Statesman's Plan for achieving zero discharge and information whether a soil study has been completed. Condition r): Comprehensive Water Quality Monitoring Plan. We would like documentation that this has been completed and a copy of this documentation and an opportunity to review it. The S'Klallam would like to see at least monthly sampling results and could offer assistance in the collecting of these samples. We also request a water quality monitoring plan for the surrounding beaches, including the Duckabush estuary. Condition t): Adaptive Management. Our tribe would like to be potentially involved or at least informed of the adaptive management plan to control invasive species in relation to the marina. Condition y): Golf Course maintenance. We request that the log of fertilizers, pesticides and herbicides used on the MPR site is made easily accessible to the public, perhaps through a website. It is important for tribes and shellfish growers to monitor potential sources of contamination to the near by beaches. In addition to the concerns/comments listed above, there are additional issues we would like to address. First, it would be helpful for you to explain what the Skokomish Tribal Conservation Management Agreement consists of and provide a copy of that agreement. Explaining the Conservation Group and the South Shore Conservancy would also help us understand the efforts occurring with this MPR. More details on mitigation measures would also aid our meeting on Monday. So far, we have not been able to find clear mitigation plans for the impact that this large MPR will have on the relatively small area of Black Point. Please contact me if you have any questions or concerns. Sincerely, Jessica Coyle, Tribal Response Program Manager, Port Gamble S'Klallam Tribe