HomeMy WebLinkAbout016PORT GAMBLE S'KLALLAM TRIBE
NATURAL RESOURCES DEPARTMENT
31912 Little Boston Rd. NE - Kingston, WA 98346
kettle ponds. The proposed project would result in the loss of approximately 20,700 square feet
of wetland area and a portion of the wetland buffers associated with Wetlands C and D. The
proposal to create wetland area as a mitigation measure does not guarantee the successful
replacement and maintenance of this important habitat. Annual monitoring of wetland creation
areas is not sufficient for detecting any adaptive management that may be required.
Fish and Wildlife Habitot
The forested uplands to the northwest of Black Point represent an important elk migration
corridor between the Dosewallips and Duckabush river valleys. The proposed development
would result in the loss of existing upland wildlife habitat and although the areas of on-site
habitat would be retained, we are concerned about the impacts to the elk migration corridor,
The SDEIS did not address this issue.
The plan includes the monitoring of water quality from the state water quality sampling station
at Pleasant Harbor to identify any impacts on fish species. However, additional monitoring
stations both on and off site and more preventative measures are needed to adequately protect
water quality and existing fish species. We are concerned that once degradation occurs from the
project, impacts to spawning and refugia habitat will be irreversible. The plan does not provide
any assurance that water quality issues would be adequately resolved.
Shellfish Species
Tribal members harvest between 13,000 and 2L,000 pounds of manila clam and between L3,000
and 48,000 pounds of Pacific oyster from the Duckabush alone. So we are highly concerned
about the potential impacts to this important resource. The DSEIS states that with
implementation of identified mitigation measures, no significant unavoidable adverse impacts to
shellfish would be anticipated. However, the analysis does not consider the increased risk of
spills and accidents that would occur with the increase in vessel traffic both on land and in the
water. Although the SDEIS describes plans for stormwater to be managed appropriately, the
increased risk of discharges from contaminants, turbid waters or sediment as a result of
construction and operations must be considered.
Given the short timeframe for review of the DSEIS and appendices, this letter represents only a
summary of our most critical concerns about the proposed project. We request the opportunity
to consult more directly with the project applicant and Jefferson County staff to discuss our
concerns in more detail. Please contact me at ro" m"ag*@pg$!Is.n.ll"s to schedule a meeting,
Thank you,
Sincerely,.,
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Roma Call
Environmental Coordinator
Phone: (360)297-4792 Fax: (360) 297-4797 Z
PORT GAMBLE S'KLALLAM TRIBE
NATURAL RESOURCES DEPARTMENT
3i912 Little Boston Rd. NE - Kingston, WA 98346
fanuary 5, 2015
Pleasant Harbor DSEIS c/o fefferson County DCD
621 Sheridan Street
Port Townsend WA 98368
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JAN 0 5 2011
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Dear Mr. Johnson,
Thank you for the opportunity to comment on the Draft Supplemental Environmental Impact
Statement for the proposed Pleasant Harbor Master Planned Resort. The Port Gamble S'Klallam
Tribe's (PGST) Natural Resources Department provides the following comments. Due to the
potential for significant adverse effects to shellfish, fish, and wildlife we continue to oppose this
project and request a meeting to discuss the issues in more detail.
The proposed project is located within the Usual and Accustomed area of the Port Gamble
S'Klallam Tribe. Tribal members depend on the fish, shellfish and wildlife resources within the
project area for their cultural and economic well being. We are concerned that habitat loss and
degradation from the proposed project would impact salmon, shellfish and other important
species in the area. The Dosewallips and Duckabush rivers and their deltas serve as critical
habitat for threatened salmon and other fish, shellfish and wildlife populations valued by the
Tribe. Therefore, we are concerned that the proposed project would jeopardize the Tribe's
treaty rights to fish and hunt in the proiect area.
As we have stated previously in our 2001,2006 and 2007 comments on this project, we are
concerned with the size and scope of the proposed development. The increase in traffic and
intensity of land use will have significant impacts on resources and the DSEIS fails to adequately
address these concerns.
Water Resources
The project site includes a susceptible aquifer recharge area and the potential impacts to local
groundwater, stream flows and wetland geology are very significant. Ongoing monitoring of
water runoff and its affects on sensitive resources is needed during the construction and
operation phases, in addition to an adaptive management plan for making any necessary
operational changes. The proposed management plan should require weekly rather than
monthly monitoring and should include monitoring for saltwater intrusion. Under the current
plan, steps are identified in the event that saltwater intrusion is detected in neighboring wells,
but no preventative measures are provided. A more comprehensive monitoring plan is needed
to protect water resources.
E nv iro nme ntally S e n si tiv e Area s
In a December 2'L,200L joint SEPA comment letter from Point No Point Treaty Council,
famestown S'Klallam, Port Gamble S'Klallam and Skokomish tribes, we highlighted the presence
of numerous sensitive environmental features that would be degraded by resort development
including unique kettle ponds and streams. In addition, the Washington Dept. of Natural
Resources landslide hazard zone maps depict steep, unstable slopes fringing the Black Point