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HCEC Response to Pleasant Harbor DSEIS
12-29-L4 HCEC Comments Brinnon MPR DSEIS.docx
Attn: David Johnson
Enclosed is the Hood Canal Environmental Council's response to the Draft Supplemental Environmental lmpact
Statement for the proposed Pleasant Harbor Master Planned Resort, A signed hardcopy will be mailed today or hand
delivered on Monday, January 5,20'J.4.
Please reply and let me know that you received this e-mail and enclosed attachment O.K.
Donna M. Simmons, President
Hood Canal Environmental Council
(3601877-s747
nana@hctc.com
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December 30,2074
David Johnson, Associate Planner
Jefferson County Department of Community Development
621 Sheridan Street
Port Townsend, Washington 98368
Re: Pleasant Harbor Master Planned Resort Draft Supplemental Environmental lmpact Statement
Attention: Mr. Johnson:
The Hood Canal Environmental Council (HCEC) has been involved in the decision-making process
regarding the proposed Pleasant Harbor Master Planned Resort (MPR) project since early 2006 -
submitting written and oral testimony to the Jefferson County Department of Community Development
(DCD) at every opportunity. As the process has dragged on for the last eight years we have remained
consistent in our opposition to the proposed MPR and our support for the local citizen organization, the
Brinnon Group, whose members would be the most directly affected by the construction and operation
of the proposed project. Our position has not changed. The following comments are based on a review
of the Draft Supplement Environmental lmpact Statement (DSEIS) for the proposed MPR. We
respectfully request that they be entered into the public record.
GENERAL COMMENTS
Environmental lmpacts Hood Canal Watershed
The still largely undeveloped rural character of the Hood Canalwatershed is what sets it apart from the
more densely developed and urbanized greater Puget Sound region. The public's perception of the
unique and environmentally sensitive character of this watershed is evident in the State's designation of
Shorelines of Statewide Significance for all of the shorelines of Hood Canal and numerous projects and
programs aimed at protecting water quality and related natural resources. Unfortunately, over the 45
years since the creation of the HCEC, we have seen a gradual "piecemeal" chipping awayof the natural
landscape from rapid growth and development in rural areas. Consequently, there are fewer open
spaces throughout the Hood Canal region, We now join with local residents and visitors alike in placing
the highest priority on protecting what is left of our natural undeveloped areas. The proposed MPR
must be evaluated with the potential cumulative impacts to the broader Hood Canal watershed in mind.
There can be no question that, under the preferred alternative cited in the DSEIS, adding another mega
resort that includes a golf course, 890 residential units (including 52 units for staff housing), 56,608 sq.
ft. of commercial area, and resort related amenities spread over 231acres (not including the Pleasant
Harbor Marina area), leaving very little natural, preserved area and allowing 1 million cubic yards of cut
and fill for golf course grading, poses significant unavoidable environmental impacts to the Pleasant
Harbor/Black Point area. The HCEC fully supports the Brinnon Group, other organizations, and many
local residents in rejecting the project-level development alternatives (1 and 2) and choosing the No-
Action Alternative 3.
Page 1
DSEIS Alternatives
The DSEIS describes in detail the so-called environmental and other beneficial impacts of alternatives 1
and 2. However, there is very little discussion of impacts under alternative 3 other than to repeat over
and over that "the site will continue to develop as a single family residential area based on the existing
rural zoning and as described in the 2007 Final ElS". With very few exceptions, the document fails to
demonstrate benefits to the environment of the No-Action Alternative with an estimated 30 new
residents (pg. 1-11, Volume 1, DSEIS) when compared to the others. Our letter dated 10-14-07 to the
Jefferson County DCD commenting on the 2007 Draft EIS for the County's Comprehensive Plan
Amendment/Pleasant Harbor Golf Resort details the many benefits of that document's No-Action
Alternative. These include significantly lower density, fewer intensive uses, minimal topographic
alteration, least demand on groundwater and protection of the aquifer from saltwater intrusion, least
traffic impacts, least potential for contamination of marine resources, least impervious surfaces,
significantly lower demand for services, increased probability for maintaining the rural character of the
Brinnon community, retention of more open spaces, least disturbance of wetlands, and better
protection of wildlife habitat.
Benefits of Alternative 3
Much is made throughout the DSEIS of so-called "improvements" to water and other resources from
upgrades, e.g. sewer, stormwater plan, etc. if the proposed MPR project is constructed (pg.3.2-7
Volumel,DSElS). However,thereisnomentionofthefactthatmostofthesepurportedimprovements
could result in the same or higher levels of resource protection when the various regulatory and other
tools currently available are utilized and enforced. Existing buffer, setback and lot design regulations,
county health department sewage disposalapproval process, the Shellfish Protection District response
plan, upgraded requirements for existing roadway deficiencies, building permit requirements, shoreline
permitting process, stormwater control plans, local state, and federal project review and habitat
mitigation requirements and wetlands protection regulations are just some of the numerous tools listed
in our 10-1,4-07 letter that are still available. The notion that water quality, water quantity, and other
natural resource protections can be improved by allowing the kind of intensive development resulting
from another mega resort in the Hood Canal watershed is ludicrous.
Adding language describing the benefits to the environment of Alternative 3 throughout the document
would go a long way toward demonstrating non-biased comparisons of the three alternatives.
SPECIFIC COMMENTS
The DSEIS presents a clearer picture of the preferred alternative and offers some improvements from
the original plan, e.g. moving the Maritime Village away from the Pleasant Harbor shoreline and
consolidating some housing units to allow for more pervious surfaces. However, it still presents
unacceptable impacts to the Pleasant Harbor/Black Point area.
a Environmental Review of Pleasant Harbor Area
The northern portion (Pleasant Harbor)of the proposed project is being evaluated undera BSP
(Binding Site Plan), a separate process which does not require involvement by the public and
makes it very difficult to get a clear picture of the impacts of the project as a whole. We
support the Brinnon Group's position that this area should be subject to a full environmental
review under the State's EIS process.
Proiect Construction Phases
The proposed project is planned to be constructed in three phases over a 10 year period.
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However, there is no guarantee that this plan will be followed. According to the DSEIS (pg. 2.3-
5, Volume 1) the schedule may change depending on market conditions. There are other
circumstances that could result in delaying construction, e.g. the developer's financial situation,
contract and/or labor problems or any number of unexpected issues. Unfortunately, the
construction phase poses the biggest threat to natural resources, including groundwater, which
will undergo the greatest demand at that time (Subsurface Group Memo dated 2-22-10). The
issue of noise pollution may apply here, since activities like rock crushing, are extremely loud.
a lmpact Cost Deposit and Performance Bond Requirement
lf the preferred "no build" alternative is not selected, any approval of such a potentially harmful
project in this fragile environment should be conditioned upon a complete analysis of the
ascertainable and potential economic impact of the proposed MPR during and after
construction. Before construction begins, the developer should be required to (1) deposit the
amount of all ascertainable direct and indirect costs regarding services and infrastructure into a
fund available to local government to cover the costs as they are incurred, and (2) furnish a
performance bond issued by a highly rated insurer to cover all potential costs that cannot be
ascertained beforehand, including repairing any environmental damage incurred over a 50 year
period because of the development and the costs of cleanup and restoration if the project is
started but abandoned, ln this way, the responsible government is attempting to assure no net
economic loss to the community, although the HCEC asserts that the "no build" alternative is
superior because this proposed MPR lacks assurance of no net environmental loss.
Threats to Groundwater and Aquifer
There is only one aquifer which would serve the entire project area, including local residents.
The developer plans to use an elaborate system of water management in an effort to protect
the water supply. According to State Department of Ecology (DOE) documents, aquifer
recharge primarily comes from direct infiltration of precipitation (pg. 3.2-2, Volume 1).
However, there is no plan for preventing drawdowns in the event of prolonged dry periods
which, if scientific predictions of extreme weather events due to climate change (changes in the
timing and intensity of rainfall) prove accurate, groundwater and the aquifer could be at risk.
The developer's plan to inject treated wastewater into wells poses the possibility of the
introduction of pharmaceuticals and other pollutants into the aquifer.
The greatest danger to the Black Point aquifer is the threat of saltwater intrusion. Due to its
sensitivity to saltwater intrusion, this area is designated as a Critical Aquifer Recharge Area and
also an SIPZ (Seawater lntrusion Protection Zone). Residents living in this area need to be aware
that according to the Pleasant Harbor Neighborhood Water Supply Program Application dated
2-24-10 (p9.2, Appendix F) if their wells show saltwater contamination, the burden of proof as
to whether the resort's water demands are responsible for the intrusion lies squarely on their
shoulders. The Application reads, in part, "The well owner provides conclusive evidence that,
overa statistically relevant period of time, chloride levels have Increased overchloride levels in
the well priorto Pleasant Harbor's use of groundwater, including but not limited to, evidence
that the increase in chloride levels is from the Pleasant Harbor groundwater use and not from
the construction of the well owner's well . . ." (emphasis added). The developer also can
"request additional evidence from the resident showing that the resort groundwater withdrawal
is the cause of the increase in chlorides. . . ". Placing the burden of proof on well owners
Page 3
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saddles them with a long and expensive process. We believe that the developer not only is
responsible for supplying water to the resident in the event of saltwater intrusion, but should be
responsible for the costs involved in the determination of culpability.
A DOE Hydrologic (Revised) Memo from John Pearch dated L-14-10 shows that there is reason
to believe that wells in the Black Point area are already experiencing saltwater intrusion, Two
wells have already been found to have saltwater intrusion. Under the heading of Domestic
Wells, the statement is made that ". . . nearby domestic wells are at risk of seawater intrusion
duetotheirproximitytothecoast..." Also,"Additional pumpingoftheACGwellandadditional
proposed wells by Pleasant Harbor could cause this saltwater interface to move further inland,
thereby increasing the risk of seawater intrusion in these wells." Further, these wells were in
the area where, according to the memo, saltwater intrusion would likely be found. Seven wells
were not tested as required by Jefferson County building permitting. lf any wells have been
decommissioned due to saltwater intrusion, that information must be contained in the DSEIS,
The DSEIS needs to clearly establish the developer's responsibility for proving that there is
enough water supply for both the resort and neighboring residents. This includes using updated
well data and a monthly monitoring program at the developer's expense. Field sampling is
preferable to relying on computer models. The Neighborhood Water Policy should be revised to
assign the burden of proof to the developer.
Wetland Mitieation
There are three "Kettles" and associated wetlands on Black Point - A, B and C. The developer
plans to convert Kettle B, which has a high rating of category lll due to its habitat value and
moderate to high value for water quality functions (pg. 3. 7-2, Volume 1) to a control pond for
holding treated wastewater from the wastewater treatment system to provide recycled water
for reuse and for golf course irrigation and fire protection. To offset the conversion, the DSEIS
states that Kettle C may be "enhanced".
Since the wetland mitigation plan has not been done, it is impossible to know how the loss of
the Kettle B wetland will be compensated. We feel strongly that in order to meet the state's
no-net-loss of wetlands policy, Kettle B and associated wetlands should be kept in their natural
state. The DSEIS should also state that the proposed MPR project should not be allowed to
encroach on wetland buffers.
Golf Course
We failed to find a listing of chemicals (herbicides, pesticides, or fertilizers) that will be used for
golf course grass maintenance or any discussion of how the developer plans to protect
groundwater or stormwater runoff from the use of these chemicals. The BMPs (Best
Management Plans) for golf course maintenance needs to be explained in detail. Also, the
recommendations relating to golf courses contained in the WRIA 16 Watershed Management
Plan should be noted and a plan for howthe developerwilladhere to the recommendations
discussed in the WRIA Plan.
Under the preferred alternative (2)the statement is made that 88 percent of the site would be
retained in open space in the form of golf course, naturalareas and buffers (pg.3.2-12, Volume
1). We would argue that golf courses do not count as open spaces as they do not have natural
landscape, habitat or other environmental values.
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OTHER ISSUES OF CONCERN
While the HCEC's primary area of interest is potential environmental impacts, there are other issues of
concern to the HCEC relating to the proposed MPR project.
o Economic lmpacts on Local Communitv
The developer has a responsibility to reveal the true impacts on the local economy from the
proposed MPR during construction and operation. Of the estimated 225 permanent
operationaljobs that could be created, (pg. 1-11 and!-12, Volume 1), the majority would be low
paying jobs. According the DSEIS, these jobs would pay 80 percent or less of the AMI (average
median income) for the Brinnon area, Construction jobs would fluctuate during various phases
of construction. Many jobs would be seasonal and part time, including food service,
maintenance security, etc. lt is difficult to say who will benefit economically other than the
Brinnon business community, the Canadian based developer, and possibly real estate
developers.
A study of fiscaland economic impacts of destination resorts in Oregon concluded that, after
subtracting the costs for services from the gross property and room tax revenue generated by
the study resort, only a modest net surplus remained. When the cost of capital facilities
including roads, schools, fire and police stations, and others is also accounted for, the net cost to
local taxpayers is substantial even after accounting for all known payments the resort would be
required to make (Fiscal and Economic lmpacts of Destination Resorts in Oregon by Central
Oregon LandWatch - March, 2009).
Traffic lmpacts to Hishway 101
The impacts to Highway 101 from the increase in vehicles traveling to and from the airport
would be substantial. The developer's plan to rely on two shuttle buses does not take into
account that most visitors will travel by car to and from the resort along highway 101. lncreased
traffic congestion in towns like Hoodsport is already a problem in the summer months. The
HCEC is also concerned about vehicle-related non-point pollution, stormwater runoff entering
Hood Canal and more greenhouse gas emissions resulting from increased traffic. The data
used to assess traffic volumes in the DSEIS appears to be outdated. ln addition, during the
construction phase, the increase in trucks and other heavy equipment on Highway 101 would
likely lead to costly damages. Further, the question of who will pay for the additional highway
repairs and the extension of Jefferson County's transit service needs to be addressed.
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Jefferson Countv Resources
The HCEC remains concerned about whether Jefferson County has sufficient staff and other
resources that would be required to handle the additional workload of monitoring the proposed
project for compliance and/or dealing with unexpected problems.
Additional Costs to Mason Countv P.U.D. 1
It is not clear whether the Mason County P.U.D, # t has the capacity at the present time for
providing power during construction and operation of the proposed project (pg. 3. 8-2, Volume
1). According to the DSEIS, the P.U.D. has only agreed to supply power during the first phase.
The question of who would pay for a new substation, distribution feeders and engineering
studies and designs needs to be answered well before approvalof the proposed MPR project is
considered. lt would be helpful to know how much of a future P.U.D. rate increase can be
attributed to the increased energy demand from the proposed MPR.
Page 5
a Naval Base Security
There is no mention of the proposed MPR's proximitytothe U.S. NavalStation BangorSubase
and whether this might be considered by the Navy to present a national security issue.
a M iscellanous
Pages 1-6 and 3.4-1- in Volume L refer to "Rainier" elk populations. The proper name is
Roosevelt elk.
The HCEC appreciates the opportunity to express our concerns and provide comments on the DSEIS for
the proposed Pleasant Harbor Master Planned Resort. We look forward to continuing our involvement
and receiving further information as part of Jefferson County's public review process.
Respectfu lly subm itted,
Donna M. Simmons, President
Hood Canal Environmental Council
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