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November 2010
Re: Black Point Development
To whom it may concern:
People For Puget Sound is one of the largest and longest operating non profits working
solely to protect and restore Puget Sound, Hood Canal and the Strait of Juan de Fuca. With
thousands of members, and twenty years of experience, we wish to offer our position on
the Black Point development. As a member of the Board of Directors from the
Olympic Peninsula to People For Puget Sound, I want to state our opposition at this time to
this development.
We believe that the development of Black Point, sitting right above a major estuary, will be
disastrous for the environment there, in the estuary and in the Hood Canal below it.
Hood Canal is already suffering from the affects of population growth, septic leaching, and
pollution coming from existing developed properties. There are also grave concerns,
scientifically based, about it's affects on local water supplies.
Additionally, there has been little done to evaluate and address the indirect and cumulative
impacts of the development on the Duckabush and Dosewallips River watersheds, including
indirect and cumulative impacts to habitat for listed species and to the health of Hood Canal.
The apparent precarious financial state of the developer is also a concern. The concern we
have is that the development may be allowed, based on assumptions of sales and intended
environmental protections, and then, after clear -cutting the near shore environment,
creating environmental damage, that the development would end up going bankrupt due to
low sales. That would leave the county vastly worse off than if the project was never started.
While we are opposed to this development going forward at all, if the development is given
a green light, what I would ask the County to consider is putting stiff requirements on sales
levels that would guarantee that the environmental protections of the project would have
to be funded before destruction of the environment begins. This could be in a form of an
escrow account that forces the developer to sell so many lots before work can begin.
911 Western Avenue, Suite 580
Seattle, WA 98104
(206) 382-7007
fax (206) 382-7006
people@pugetsound.org
407 Main Street, Suite 201
Mount Vernon, WA 98273
(360)336-1931
fax (360) 336-5422
northsound@pugetsound.org
1063 Capitol Way South, Suite 206
Olympia, WA 98501
(360) 754-9177
fax (360) 534-9371
southsound@pugetsound.org
It should be required to be tiered in, like the Treehouse project in Port Townsend was, in
phases. The developer should have to develop the least environmentally sensitive area first-
-like the upland interior --before any shoreline is denuded or views cut. We would also like
to see an environmental easement, perhaps managed by the local Land Trust, to protect the
shorelines. We're sure there are other methods we are unaware of to protect this beautiful
point, the estuary and Hood Canal below it.
We also would have the county require full completion and bonding of the environmental
protection, Low Impact Development (LID) and buffers for 10 years due to the maintenance,
grading and soil amendments that tend to be improperly managed in many projects like this
during the initial stages. An additional approach is in the permit to state than no occupancy
permit will be allowed until all environmental controls are in place.
It is documented scientifically in the last ten years', that streams become unstable when
watersheds are about 1/3 cleared (Booth and Jackson, 2002). Thus the 65/10/0 LID
standard is the lowest possible standard before stream destabilization. We would
recommend that the county require this approach.
Again, we strongly oppose this planned development on the shores of Hood Canal, and
believe it is the wrong project for this location. We would prefer to see it never happen. We
believe that it will lead to degradation of Hood Canal and the estuaries around the project.
However, if is not possible to stop it, having the county demand an approach to guarantee
the development actually happens according to plan, seems to be a small price to ask.
Sincerely:
Os -
Al Bergstein
Board of Directors
People For Puget Sound
Port Townsend
www.pugetsound.org
cc:Brinnon Group;Jefferson Marine Resource Committee;Jefferson County Commissioners; Jefferson County Planning
Commission;Jefferson County Democrats;Port Townsend Leader; Peninsula Daily News
1 Booth, D.B. and C.R. Jackson. 1997. "Urbanization of Aquatic Systems - Degradation Thresholds, Stormwater Detention, and the
Limits of Mitigation. Journal of the American Water Resources Association
22(5) 1-20.
http:l[www thefreelibrary comJStream+reach+evaluation+tool+for+assessing±notential+urban ation-a01777 4921