HomeMy WebLinkAbout014XRI
Steven John Walker
331 Dosewallips Rd
Brinnon, WA 98320
r)Pleasant Harbor DSEIS c/o Jefferson County DCD
621 Sheridan Street
Port Townsend, WA 98358
Via email to dwjohnson@co.jefferson,wa.us
5 January, 2015 JAN o s Nt6
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RE: Pleasant Harbor Master Planned Resort DSEIS
The 2000's era adoption of the Jefferson County Comprehensive Plan including zoning for a Master
PlannedResortatBlackPointwasasingularactoffolly. Thepassageoftimehasdonenothingto
change the fact that plunking down a luxury resort in the rural county, far from existing infrastructure
and services will have a suite of negative cultural and environmental impacts which cannot be mitigated
The proponent's DSEIS document ignores or otherwise glosses over many of the most substantial of
these impacts, and therefore must be deemed inadequate and incomplete.
I have identified the following adverse cultural and environmental impacts which neither the project
proposal, nor the DSEIS are able to adequately address or mitigate
#Fundamental change to the community
#lmpacts to the natural view shed of the Duckabush River Delta, and other aesthetic issues.
#lnadequate Traffic and Greenhouse Emission Analyses
#Emergency Services
#lnadequate Greenhouse Emissions Analysis
#Possibility of Failure
For these reasons, it is imperative that the DSEIS be rejected in its current form, until these issues are
adequately addressed and discussed.
# Fundamental change to the demographics of southeastern Jefferson County, and creation of a two-
tiered society therein.
As planned, the project would nearly double the population of the Brinnon area in ten years, a
population which has been relatively stable or seen only incrementalgrowth over the last century
Furthermore, this new population (presumably upscale individuals who could afford to, and would
choose to, live in a golf-course/resort setting) will have very little in common with Brinnon's current,
predominantly working-class population.
As a result, we will see the creation of a two-tiered society in the Brinnon area, with the current
population largely becoming the servant class of the new resort population.
This is absolutely clear by the fact that the resort will be a gated community, with public access
restricted.
The creation of highly-stratified class system in rural, southeastern Jefferson County is one of the
fundamental negative impacts of this project proposal, and one of the primary reasons why it should be
rejected.
#lmpacts to the natural view shed of the Duckabush River Delta, and other aesthetic issues.
This study does not directly discuss the impacts to the Duckabush River delta view shed, except to use
weak meaningless language which will not translate to actual planning prescriptions.
The topic is mentioned only briefly (3.15-2) but absolutely does not describe how the resort will appear
from the south and whether or the primarily natural view shed of the Duckabush will be altered, and to
what degree.
No figures, diagrams, or artist representations of the altered view are presented
There is no discussion of to what degree the 200 foot shoreline setback will or will not obscure the
resort,
Until this topic is addressed, the DSEIS will remain incomplete and adequate with respect to the subject
of aesthetic impacts.
#Traffic Analysis
The section 3.9 discussion of collision history is incredibly brief and deficient. lt briefly discusses distant
interchanges such as WA Hwy. 104 / Center Road but completely omits discussion of the real risk, which
is accidents along the reaches of US 101, The section of highway between Quilcene and Hoodsport is a
winding, poor visibility route with large sections of minimal to no shoulders. As discussed below, the
analysis also omits consideration of trips generated by residents commuting to distant employment.
#Emergency Services
Emergency response times for life-saving care to regional hospitals in Port Townsend, Sequim, or
Shelton are prohibitively too long from Brinnon. As a result, the typical evacuation for a severe accident
victim is via helicopter to Harborview Medical Center in Seattle.
We can expect with more residents, and more traffic on the 1,01, that the number of helicopter
evacuations to Harborview will increase. Additionally, life-threatening situations such as heart attacks
can also require helicopter evacuations.
Brinnon itself has no medicalfacilities, while Quilcene has a small clinic. Thus, even minor incidents that
could be routinely handled in a more populous area with more facilities may quickly escalate into
emergencies,
An additional0,33 EMS units will do very little to mitigate these impacts. An adequate discussion would
attempt to fully estimate the number of expected life-threatening and other serious incidents which
would require helicopter-based evacuation.
A major earthquake or flooding event has a very real possibility of isolating the resort from the outside
world. Just recently we've seen US 101 reduced to a single lane south of Brinnon, with the WSDOT
reporting that it will be months before traffic returns to two lanes. The potential closure of 101 due to
mudslides, rockfalls, or erosion, or the loss of one or both of the Duckabush/Dosewallips bridges could
completely isolate the resort.
ln the case of a major catastrophe such as an earthquake, overwhelmed emergency response units
could leave the resort effectively on its own. The injured or ill could expect no medical response for
days. Thisisoneofthereasonswhyitisinappropriatetositeamajordevelopmentinarural area
lacking services.
This is also a fundamentalflaw in the DSEIS in its present form. For this reason, the proposal should be
denied until or unless the proponents are able to provide an adequate discussion of how the isolated
resort would respond to a catastrophic natural disaster.
#lnadequate Traffic and Greenhouse Emission Analyses
Together, these topics greatly under-estimate the number of additional vehicle miles which will be
generated by the resort, and therefore the volume of greenhouse gasses which will be produced over
the period of the resort's life.
Presumably, with nearly 300 permanent residential units and an estimated 556 new permament
residents, not all of these residents will be retired or members of the idle rich, Some of them may in fact
work for a living. Jobs for these presumably upper-middle class individuals are absent in ruralJefferson
County. These permanent residents would presumably thus commute to distant areas such as Shelton,
Port Townsend, Sequim, or Kitsap for work. Even the roughest calculation shows that a single commuter
would generate on the order of 400 weekly round-trip miles to reach these job markets (40 miles one
way to Shelton or Port Townsend). Even if only t8% of permanent residents commute to work, this
would represent an additional 40,000 weekly miles, and 200,000 yearly miles driven by commuting
residents of the resort.
Given that neither the traffic nor the greenhouse emission analyses appear to account for these
commuter miles, both must be deemed incomplete and inadequate at this time.
#Conclusion
ln conclusion, while I understand that the Jefferson County Comprehensive Plan and Zoning allow for a
Master Planned Resort at Black Point, they certainly do not require approval of any given proposal. ln
the case of this proposal, the resort is simply too large for a rural, isolated community to assimilate
without fundamentally changing the core aspect of the community.
I understand that this is a speculative proposal, and that the proponents need to be sized substantially
enough to for it to be economically viable to them. However, this economic-driven scope from the
proponent's standpoint should not be allowed to drive the process at the regulatory level.
Jefferson County must make a realistic estimate of what level of economic development is both viable,
sustainable, and realistic in the Brinnon area. The comprehensive plan and MPR designation
notwithstanding, this proposal fails tests of viability, sustainability, and reality and therefore should not
be approved in its current form.
(electronically signed 5 January, 2015)
Steve Walker