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HomeMy WebLinkAbout023David W. Johnson From: Sent: To: Cc: Subject: Darlene Schanfald <darlenes@olympus. net> Monday, January 05, 2015 4:10 PM David W. Johnson Darlene Schanfald Pleasant Harbor DSEIS/c/o Jefferson County DCD PLEASE CONFIRM RECEIPT OF THIS EMAIL. Friends of Mitter Peninsula State Park PO Box 2664 Sequim WA 98382 January 5, 2015 Pleasant Harbor DSEIS/c/o Jefferson County DCD 621 Sheridan Street Port Townsend WA 98368 dwiohnson-@co. iefferson. wa. us Below are comments regarding the Pleasant Harbor DSEIS prepared by Friends of Mitter Peninsuta State Park, a 20 year, federatty recognized non profit on the North Otympic Peninsula. We know that these are like and simitar to other comments being sent, but want to underscore that these are issues of concern to many that need to be addressed. We are disappointed that this DSEIS was released over holidays and the response time could not be extended, especially since years of extensions were given to the developer. POPULATION The poputation of Brinnon is about 818 and maybe hatf this number of homes. Expanding the number of tiving quarters by 890 residential units (Options 'l & 2) wi[[ have an enormous impact in the area in many respects, inctuding potabte water, storm water, sewage sotids and efftuents, retease of CO2 into the atmosphere and toss of C02 soit and tree sequestration. ECONOMICS Few of the buitt units are intended for year round occupancy. ((The majority of this housing (67%) woutd be for short- term visitors and 33% would be for permanent residents.)) 67%or about 548 units are hopedto be fitted, but most tikety the largest percentage of PT occupancy wit[ be in the warmer time of the year. The impacts to the area ca[[ for showing an economic anatysis that this resort is financiatty viabte. We request this be done. Has the resort company factored in the new WA State minimum wage for emptoyees? Where witl construction workers (80.5% out of the area) be housed? Feasibitity of housing them ctose to the site? Witt att construction works be from WA State? How witt their traveling during high tourist season affect normat traffic? Options't &2 detaits are described but the No Action, which is to buitd a few hundred homesites, is not detaited. lt seems, then, that this No Action is not being seriousty considered. Yet, it is an Option and it shoutd have comparative detaits so the costs can be seen. You ask for the pubtic to weigh in and the pubtic shoutd have this information to consider. This is an omission and shoutd be corrected. 1 The information shoutd be combined with that of the marina so one grasps an overatl picture of the costs and potentiat impacts of the entire operation. What costs wilt be put to the area and state citizens? For instance, road repair from additionat traffic the resort witt bring. Utitity costs. Medicat facitities. Taxation. This estimation shoutd be made pubtic up front. GLOBAL WARMING Stripping this [arge area of trees and its natural grasses, soits and wettands witt retease immense amount of greenhouse gases into the ambient air. Earth removal witl have a large affect on the microbiat soit community. A study needs to be done on how this GHG retease and resulting changes affect both the harbor tife and the surrounding Brinnon community. Appendix M doesn't quantify the GHG reteases and effects of the reteases, and the mitigations are hardty that! For sequestration to work, even for the replanted trees, the amount witl not balance out. lt takes years to regain that sequestration, whether reptanted trees or new grass. EFFLUENT Ctass A effluent discharge from the proposed sewerage treatment plant is ptanned to be stored and recycted. Do not use this to recharge the aquifers. Do not use this for fire protection and irrigation. lt witt make firefighters itt. There are many studies that determine recycting of wastewater treatment ptant (WWTP) efftuents are unsafe. There are thousands of chemicats and many pathogens that cannot be tested for, nor their cumutative impacts. lt is known that: . microbeads from personal products pass through WWTPs into efftuent . MRSA and other pathogens remain in the studge and the efftuent . antibiotic bacteria can be created in the WWTPs . triclosan minimizes WWTP treatment . efftuent contains fire retardants . efftuent and wetl as the sotids contain thousands of chemicats inctuding chemicats of emerging concern and POPs More reason to not recycle the effluent: http: / /www.epa.eov/oiq/ reports/201 4/201 40929- 14-P-0363. pdf More Action ls Needed to Protect Water Resources From Unmonitored Hazardous Chemicals EPA does not have mechanisms to address discharge of hazardous chemicols into water resources. httlr://rvwwjsonline.com/news/health/common-diabetes-medication-among-drugs-found-in-lake-michigan- bgq4rzrrzzr-z87zr86sr.hunl Common diabetes medication among drugs found in Lake Michigan There is more than one way to measure prescription drug use in modern society. The most direct method is just to count up prescriptions fitted by America's pharmacies. That woutd show, for instance, that more than 180 mittion prescriptions for diabetes drugs were dispensed in 2013. Or you coutd test the treated water coming out of sewage facitities such as the South Shore ptant in Oak Creek. That approach reveats that in the Lake Michigan waters outside the ptant, the diabetes drug metformin was the most common personal care product found by researchers with the School of Freshwater Sciences at the University of Wisconsin-Milwaukee. More importantty, according to their latest research, the [evets of metformin were so high that the drug coutd be disrupting the endocrine systems of fish. Last month, a Journal Sentinet/MedPaee Todav investieation found booming sates of diabetes drugs, which in 2013 had grown to more than S23 bittion. Metformin is a first-line treatment for type 2 diabetes and is the most commonty prescribed medicine for the condition. ln 2013, about 70 mitlion prescriptions were dispensed, according to IMS Heatth, a drug market research firm. It is so ubiquitous it can easily be found in water samptes taken two miles off the shore of Lake Michigan. "l was kind of a surprise," said Rebecca Klaper, a professor of freshwater science at UWM. "lt was not even on our radar screen. I said, 'What is this drug?' " 2 The drugs get into the sewage and eventually the lake because they are not broken down completely after they are consumed and then excreted. The metformin concentrations are [ow, compared with the amount taken by peopte. For instance, coming right out of the treatment ptant the tevets are about 40 parts per bitlion. About two mites away, they drop to 120 parts per triltion. Other commonty found substances include caffeine, sutfamethoxazole, an antibiotic, and trictosan, an antibacterial and antifungat found in soap and other consumer products. Ktaper co-authored a 2013 science journaI paper on the finding as wett as another one this year. The more recent research suggests that metformin in take water is not just a curious artifact of everyday [ife. The study looked at the effect of metformin on fathead minnows in the lab that were exposed to the drug at levets found in the lake for four weeks. It found gene expression suggesting disruption of the endocrine system of mate fish, but not femates. ln essence, the males were producing biochemicals that are associated with femate minnows. The biochemicats are precursors to the production of eggs. Ktaper said that because the minnows are a stand-in for other fish, the changes also coutd be affecting other species such as perch, watleye and northern pike. The UWM research confirms what others have found regarding prescription drugs showing up in America's lakes, rivers and streams, said Metissa Lenczewski, an associate professor of geotogy and environmentaI geosciences at Northern ltlinois University. For years, it was assumed that the votume of water in the Great Lakes was so enormous that any drugs that got through treatment facitities woutd be dituted to the point that they woutd not pose a probtem, said Lenczewski, who was not a part of the UWM study. That theory itself now is being dituted. Even more concerning are the much higher levels of antibiotics that are being put into rivers and streams near pig farms where the drugs are used to produce larger animats, she said. ln addition, strains of antibiotic-resistant bacteria atso have been found in water near those farms, she said. "lt is very atarming how much we are putting drugs out there in the environment," she said. ln that this resort ptans to estabtish a medical clinic for resort members (& workers?) there witt be medical wastes in the WWTP, let atone from what goes down the drains from the residential units. TRAFFIC One of the most worrisome issues with this project is traffic. Hwy 101 is a thoroughfare used by those traveting between Ctattam County and more southern points to Otympia. Additionatty, the traffic is greatty increased during the summer season. Roads are narrow. Much of the route is on btuffs which fail, as some just have this December 2014 creating one way traffic for weeks. Landslides are common on this route during the rainy season. Traffic accidents happen. One can imagine that this resort traffic needs witt be expensed to the State, hence the citizens. This resort area is an inhospitabte site for a large resort. WATER Very worrisome is the avaitabitity of water over a long term and the affects on community water needs. lf this becomes problematic, what responsibitities witt the resort owner be held to? Once it is used, it won't be regained. Water is going to be the "gotd" as weather warms and snow levels are minimized and rainwater runoff increases. 5UM/$ARY This comment covers onty some of the probtems with the planned resort and the DSEIS. Ctearly, it is not appropriate to approve this project. Dartene Schanfatd, Ph. D President 3 David W. Johnson From: Sent: To: Subiect: joe breskin <joe.breskin@gmail.com> Monday, January 05, 2015 4:08 PM David W. Johnson OEC Black Point Pleasant Harbor MPR DSEIS Comments David, In addition to the concerns raised by The Brinnon Group in the Jan 2 submittal by Barbara Moore- Lewis, Olympic Environmental Council (OEC) would add the following concerns: POPULATION The population of Brinnon is about 8l 8 and maybe half this number of homes. Expanding the number of living quarters to 890 residential units (Options I & 2) will have an enorrnous impact in the area in many respects, including potable water, stormwater, sewage solids and effluents, release of CO2 into the atmosphere and loss of CO2 soil and tree sequestration. ECONOMICS Few of the built units are intended for year round occupancy. (The majority of this housing (67%) would be for short- term visitors and 33% would be for permanent residents.) 670/o or about 548 units are hoped to be filled, but most likely the largest percentage of PT occupancy will be in the warner time of the year. The impacts to the area call for showing an economic analysis that this resort is financially viable. We request this be done. Has the resort company factored in the new minimum wage for employees? Where will construction workers (80.5% out of the area) be housed? Feasibility of housing them close to the site? Will all construction works be from WA State? Options l&2 details are described but the No Action, which is to build a few hundred homesites, is not detailed. So it is not being seriously considered. Yet, it is an Option and it should have comparative details so the costs can be seen. You ask for the public to weigh in and the public should have this information to consider. This is an omission and should be corrected. The information should be combined with that of the marina so one grasps an overall picture of the costs and potential impacts of the entire operation. What costs will be put to the area and state citizens? For instance, road repair from additional traffic the resort will bring. Utility costs. Medical facilities. Taxation. This estimation should be made public up front. GLOBAL WARMING Stripping this large area of trees and its natural grasses, soils and wetlands will release immense amount of greenhouse gases into the ambient air. Earth removal will have a large affect on the microbial soil community. A study needs to be done on how this will affect both the harbor life and the surrounding Brinnon community. 1 Appendix M doesn't quantify the GHG releases and effects of the releases, and the mitigations are hardly that! And for sequestration to work, even for the replanted trees, the amount will not balance out. It takes years to regain that sequestration, whether replanted trees or new grass. Too, please factor in how this would affect the marine life. EFFLUENT Class A effluent discharge from the proposed sewerage treatment plant is planned to be stored and recycled. Do not use this to recharge the aquifers! Do not use this for fire protection and irrigation. It will make firefighters ill! There are many studies that determine recycling of wastewater treatment plant (WWTP) effluents are unsafe. There are thousands of chemicals and many pathogens that cannot be tested, nor the cumulative impacts. It is known that: . microbeads from personal products pass through WWTPs into effluent . MRSA and other pathogens remain in the sludge and the effluent . antibiotic bacteria can be created in the WWTPs . triclosan minimizes WWTP treatment . effluent contains fire retardants . effluent and well as the solids contain thousands of chemicals including chemicals of emerging concern and POPs More reason to not recycle the effluent: http://www.epa. gov/oi g/reports/20 I 4/20 I 40929- I 4-P-03 63.pdf NOISE: There is an inadequate discussion ofconstruction noise resulting from stated need to crush vast amounts ofgravel as site is developed. Presumption is that crushing would occur in batches, based on the combination of site development, related land disturbing activities and projected needs for each development stage. Noise abatement means should be provided in a noise abatement plan that includes hours of operation and noise abatement means and County should require development of computer models to predict noise impacts at receiving properties and ongoing monitoring to insure that projections are accurate and that noise abatement provided is in fact effective, and should includes clauses calling for immediate remedies if abatement fails to deliver promised SPL. Continuous monitoring at receiving property that records both peak and average SPL to be recorded during periods when crushing equipment is in operation and available for public review. SUMMARY This comment covers only some of the problems with the planned resort and the DSEIS. Clearly, it is not appropriate to approve this project at this time. Joe Breskin (Treasurer) for Olympic Environmental Council Jan 5, 2015 2