HomeMy WebLinkAbout061Jefferson County Planning Commission
Public Commentary on DSEIS Nov. l9 2014
Rob Mitchell
4246Duckabush Rd
Brinnon, Wa.98320
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I protest the fact that the developer was allowed 5 '/, years with no deadline to produce
this massive document and delivered during the holidays when many county residents are
away and unaware of it's existence. Furthermore, the Public Commentary Period is
inadequate. I ordered and purchased a hard copy at my own cost of $71.67 which was not
available until I ll25l14 Many of the Brinnon Residents do not have adequate internet
service to view this document or can afford to buy one.
The DSEIS for the proposed Black Point MPR is inadequate therefore Alternative 3 or
No Action must be preferred.
A) The Traffic Study is highly inadequate. Highway l0l on the East side of the Olympic
peninsula is the only non toll direct connection to the I-5 corridor and is used for all
major shipments of goods, services as well as residents and tourism both on and off the
peninsula. When serious accidents occur along this highway it closes it down for many
hours affecting both commerce and quality of life for residents. This has large real
monetary costs and in some cases health and safety to not only Brinnon residents but, the
entire Peninsula.
In the 2007 EIS P.34 Transportation it states. "The County identified 5 specific issues
to be addressed as part of the Transportation Review." The very first requirement is the
most important.
l.) us HwY 101
The Loss of Service (LOS) data was from the year 2000. The actual car trip count data
dates back to 2006. Neither of these are currant in2014.
Transportation Engineering North West LLC states in Responses to Transportation-
Related Public Comments received on SEIS Nov.2009 to an HCEC comment, pg. l8
paragraphs 6-7
"There is no evidence of unsafe driving or roadway conditions through review of
historical collision records or review of general geometric conditions in the general
vicinity."
"While collisions do occur along roadway segments there was no evidence noted to
suggest specific review along roadways. If WSDOT or Jefferson County had identified
specific "high accident corridor" in the vicinity then a review of roadway segment
collision statistics would have been conducted. Absent this determination, this analysis
was not warranted."
Transportation Engineering of North West LLC did not count accidents in non
intersection highway segments.
Three of the most notoriously dangerous sections of roadways are in the immediate
vicinity of the MPR.
l.) South bound, l/lOth of a mile from Black Pt. Rd. the sharp down hill rt. Turn
prior to Duckabush Rd.
2.) At 2.8 mi. Southbound is McDaniel Cove.
3.) Northbound 6.4 miles from Black Pt. Rd. is Mt.Walker Pass.
These 3 locations are sources for hundreds ofvery serious accidents, including our
own Sheriff s Dept. which shuts down this vital commercial route for as long as 6
hours. (See Traffic's Financial Impact Study
www.wsdot.wa. gov/.. . I Jwe2}l2_Impact_Frei ght_Congestion.pdf )
The traffic analysis shows that out of 4100 car trips a day 30o/o or 1230 cars a day will
pass the first two dangers southbound.65% or 2665 cars a day will negotiate Mt. Walker
Pass. On the two side arterials of Duckabush and Dosewallips Roads it will be 3Yo or 123
cars a day or over a l0 hour period 12.3 carslhour. The 2 public trail heads up the
Duckabush have a combined parking area of @36 vehicles.
The response from Transportation Engineering North West LLC is that "this increase in
traffic is common with developments of this size and with the mitigations proposed (the
shuttle bus and passenger van) no adverse impact is expected."
This is inadequate mitigation.
B.) In a2013 meeting at Department of Ecology while clarifying the awarding of water
rights to Statesman Corp. John Pearch, LHG informed us that "No class A water
treatment system removes soluble chemicals" The MPR proposes to re-use this water in
irrigation, fire suppression and aquifer recharge. This would mean that hundreds of
medications people use daily will turn up in the single aquifer under Black Point.
The water rights were awarded but additional wells were never drilled. A pump test was
attempted on an existing well but was aborted after equipment failure so draw down rate
and available volume was never proven. Usage amounts have not and will not be
determined until full build out with the caveat that for each phase during the possible
decade long construction adequate water must be proven. If the development is stopped
who pays to moth ball it or restore it to natural conditions?
There is physical evidence of saltwater intrusion having occurred on the edges of the
Black Point Aquifer. DOE has conditioned that monitoring must be done and for as long
as 10 additional years after build out completion. Statesman has put several restrictive
conditions on what an individual well owner has to do to prove their potable well water
was lost due to Statesman's actions. This is in conflict with the DOE conditions on the
water rights. Statesman condition's that they qan demand additional evidence that they
are at fault. If they do accept fault the owner may hook up, at Statesman's cost, to their
water system and then they will have to pay for it's use. This is also in conflict with the
conditions DOE placed. (See Pearch Hydrology Memo Part l)
C.) During part of the l0 year construction period there will be a full scale gravel and
rock mining operation. "This will include excavation, screening of gravel and rock
crushing." (The) " machinery used will be scrapers, excavators, bulldozers, wheeled front
loaders; a portable screening plant, feed-hopper, portable gravel crusher, finishing
crusher, water trucks, highway/of-road trucks,..conveyor belt systems and
vibratory/sheep-foot compactor rollers." This will be 1200 feet away from the closest
existing residence. This is inadequate mitigation.
D.) There is no estimate of the tonnage of Bio Solids the treatment plant will produce
although, there's mention of it's transport off site that will increase heavy truck traffic.
It's stated that it will be processed at the proposed Shelton Plant yet there is no evidence
of this.
E.) This resort will also contribute l4l5 tons of refuse per year to be trucked off site to
land fills.
F.) The reduction of the resort structure's foot print results in construction savings for
Statesman yet raises the elevations of the buildings visible from l0l to as high as 70'.
The reduction of the cut and fill necessary while being "Greener" also creates
construction savings. The Green Washing of this resort does nothing to mitigate the
enorrnous negative impacts on the local roads and community due to the massive scale of
the project. Garth Mann and Statesman group state they can build the resort to this scale
legally but the real reason is to increase the profit margin.
G.) Direct negative impacts on Brinnon and Jefferson County were to be mitigated by
Memorandums Of Understanding (MOU's) but achieve little for our citizens.
l.) EMS: In 2013 there were 249 EMS calls per the797 people of Brinnon (2010 Census)
which is 3loh. Add the estimated population of 2000 Resort people means that there
would be 620 calls per year. While Statesman will pay the Fire Dept $ 10,000. per quarter
or $3,333 per month only during construction that amount is less than it would cost to
hire an additional EMT. After full build out the collected taxes are estimated to be
enough for increased services and calls but now the estimated construction time is
vaguely as long as ten years depending on the economy. Statesman will supply a used
ladder truck so our volunteers can fight fires in buildings as tall as 70'. However the Fire
Dept. is responsible for all training personnel for it's use and upkeep and mechanical
maintenance.
2.) Police: Due to budget shortages the Sub Station in Quilcene was closed. Statesman
will supply a 500 sq. ft. room (25'X20' or smaller than a 2 car garage) but without the
budget to supply and staff it.
3.) Employee Housing: Since most of the employees will be from out of Brinnon and
probably Jefferson County Statesman will build "Affordable" housing for them and
collect rent.
4.) Schools: Basically get nothing until collection of taxes after full build out, use of an
on site space for lectures on how green the MPR is. The only money they will receive is 2
dollars per tee time and spa use will be paid to the school district as well as 1 dollar per
hour for students hired by statesman for part time, minimum wage jobs. How much this
amount will be is not supplied.
5.) Health: Statesman will supply 500 sq. ft. clinic (25'X20') for an LNP or GP for use by
resort members.
6.) Construction Jobs: A project of this magnitude is done by Multi National Commercial
Company which means that the principle profit will leave town. Sub Contractors would
be required to have the commercial level of insurance and usually have worked with the
General Construction company before. The only additional workers needed will be
Minimum wage day laborers.
In the EIS 3.11-5 Construction Employment it states that 1750 jobs will be created but
this number is the total for all four phases when in fact many of the jobs will be the same
for all four phases. For example the site prep, excavation, foundation, framing and finish
crews will remain the same so this number is false. In 3. I 1- l6 vague promises are made
such as the new-employment-CoUlD-lower the Jefferson County unemployment rate-
depending -on whether the individuals reside there. And, it's POSSIBLE nearby
businesses will experience and increase in business.
In Appendix N, pg. 29 is the conclusion ofjobs created. The Average Median Income
(AMI) in Brinnon is $42,679. The number of jobs created which are At (80% of $42,679.: $34, I 43.) or Below the AMI are 223 people.
The conclusion found in Appendix N page 28 based on tables 3-l through 3-4 (pages 8-
l l) is that "Construction total and indirect jobs at or below the Brinnon AMI is only 342
jobs with an income of $34,143.00
7.) Finished Resort Employment: While 280 jobs are predicted the majority will still be
low income or minimum wage and it's not stated how many of those are part time
employment. It's estimated that "Walmart costs surrounding communities $13 million in
economic activity and $14.5 million in lost wages over 20 years " (see
http://pugetsoundsage.org/downloads/Walmart-Fowler-Report-2012-04-06-1- 1 .pdO
In Tables l-20 for all phases of construction these are the total jobs created and annual
lncomes.
48 jobs are above the AMI ranging in income from $36,000. to 552,914.
108 jobs are from $10,593. to $14,381.
l2l jobs are from $19,241. to $28,00.
The2014 Poverty Guides from the US Dept. of Health & Human Services are;
Family of 5 annual income of $27,910.4 23,850.
3 19,790.
2 15,730.
In conclusion out of 280 jobs created an incredible 83% are considered Poverty level.
See http ://aspe. hhs. gov/POVERTY/ I 4pover.ty. cfm
8.) Public Use: Is limited to the bike and walking paths. Tee times are restricted and a
limited number of the Resort's features can be used and paid for by the local community
Many amenities such as use of the pool and tennis courts are for Resort residents only.
9.) Tax Revenue; State taxes are collecte d of 9o/o and sent to Olympia of which 6.5%
stays there and the leftover 2.5Yo is returned to Port Townsend the County seat. Both of
these entities have free reign as to where and how it's spent while the citizens of Brinnon
and those communities along Hood Canal bear the brunt of traffic and safety. Levies
attached to our property taxes will go to help our school, fire dept, and County Sheriff.
These funds will not be available until Phase 4 and Full Build Out are achieved.
This is a development of massive scale. If allowed to go ahead with these multiple
inadequacies in the DSEIS it will require a large investment but also reaps very large
short-term profit for the developer and that revenue leaves. If the developer stays on as
the Property Management Co. or contracts to another multinational company In either
case property management is still profit driven. Up keep of the MPR's infrastructure will
be paid for by user fees and Home Owner Association fees, which will rise as
deterioration begins and operational costs rise.
The PUD created for the operation of the Water System and Sewage Treatment Plant has
to make enough profit to cover maintenance and future replacement of deteriorating
equipment. Some time in the future the entire Sewage Treatment Plant will have to be
replaced. Who and how is that paid for?
See http://www.fodorandassociates.com/Reports/Destination_Resort_Impact_Study.pdf
lmpact of Destination Resorts in Oregon Fodor & Associates
March 2009 page 85
lf Thornburgh Resort is successful, its developer could make $300 million on lot sales,
almost doubling its investment. The lucrative profit potentialfor developers creates a
formidable incentive for them to pursue resort projects on Oregon's cheap rural lands in
beautiful natural settings. They can afford to spend liberally to make their resort projects
possible.
Economic lmpact Conclusions
Many of the economic impact studies provided by developers portray an overly optimistic
picture of the development project's benefits by ignoring the costs associated with
providing public services, public infrastructure, and the potential adverse impacts on the
community and the environment.
The "leisure and hospitality" sector (that includes destination resorts) paid average
annual wages of only $16,096, the lowest of any employment sector in Deschutes
County and about half as much as the average annual wage in the County of $31 ,492 in
2006.
a
Even if two members of a household worked full time at the Thornburgh Resort, they
would still make less than the median household income in 2004 and the effect of the
resort will be to depress median wages in the County.
Household incomes below $21,200 represent the Federal poverty level for a family of
:ou'
Most jobs created by the resort will be temporary and when construction is completed,
1,471jobs will be lost, causing ripple effects in the local economy.
The addition of more than 2000 peak new jobs to Deschutes County will have a very
significant impact on the local housing market, especially when the temporary jobs are
:"
Low-wage jobs created by the resort will increase demand for affordable housing.
While the Peterson Housing Report estimates a peak of only 133 new households
generated by the resort, it is more realistic that a peak of 978 new households will need
to find housing in Deschutes County.
After the resort is completed, there will be an estimated permanent demand for
347 new housing units in the County