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HomeMy WebLinkAbout029Michelle Farfan From: Sent: To: Cc: Subject: Attachments: peckassoc@comcast. net Wednesday, January 07,207512:39 PM Mike Read; Bender, Scott; Rick Esvelt David W. Johnson Pleasant Harbor SEIS Comments PHMPR DSEIS Comments for Mike-1.7,15.pdf; PHMPR DSEIS Comments for Scott-l-.7.15.pdf; PHMPR DSEIS Comments for Rick-1.7.15.pdf Mike, Scott, and Rick Attached are some of the comments received at the January 5 end of the comment period. I have selected some of the comments for each of you that I believe are representative of concerns expressed. lt is likely that you will be asked to respond to these comments in the near future and I wanted to provide you with a few days to determine the scope of work and budget for preparation responses working with David; with EA Engineers, the SEIS authors; and me for the FSEIS. lf you have questions or comments, please contact me. Thank you. Craig 253-840-5482 1 Davld W. Johnson From: Scnt: To: Subfect: Thank you ior the opportunlty to @mment on the draft environmental statement for the proposed darelopment, Pleasant Harbor Marina and Resort. I have owned a home and resided in Brinnon for over 24 years. ! moved here for the peace of the surrounding wilderness and Hood Canalarea and am opposed to the expansion of Pleasant Harbor Marlna and Resort. I am very worried about firrther contaminatlon of Hood Canal, which is already negatively impacted by pollution caused from insufficient septic and sewer systems, and run-off from pesticides and herblcldes. Low oxygen Ievels in Hood Canal are already a serious impact to this valuable body of water. lf the proposed development comes to pass, it would have a dlsastrous effect on water quality and marlne llfe. Further, it would take water fnom the acqulfer at an amount that may exceed capacity and will do so in the long term. We must thlnk of the long term negative effucts of thls development and not allow greed to harm this pristine area - an area that is already being adversely effected by current operations. Would I let my family fish or swim in Pleasant Harbor at this time? tlefinitety not. And the situation will get much worse Laurie Mattron <lmattson72@yahoo.com> Wednesday, Dscsmber 03, 2014 10:20 AM David W. Johneon Oppooition GornmenB: Pleasanl Harbor Marina and Resort - Draft Enyironmentat Stabment lf the forurard. There are those who believe that a development at Phasant Harbor nrculd provlde Jobs for people who llve ln the area. I belleve thatJobs for local resldents from the proposed development would most likely be those with minlmum wates, not enough to provlde for a famlly, Unless there is a mentorship proEram where local people are hired and trained to motre up a specific carcertrack, a mlnlmum wageJob is unllkely to ralse the standard of llvlng for people who live in this area. Again, thank you br allowing my concerns to be documented on your list of people opposed to development of Pleasant Harbor Marina and Resort. Laurle Mattson 1811 Dosewallips Road Brinnon, WA 98320 360 796-4416 lmattsonTz@yahoo.com Sent from my lPad 1 road system in this area is qulte heavlly traveled, especlally during the summer months during heaw tourlst season. Additional vehicles traveling to and from this proposed resort would put a straln on Hlghway 101that ls already inadequate and often dangerous with curves and long stretches where passlng slower vehkles ls not a safe optlon. Too many accidents and lives have been Iost already. lt would be a serious rnistake to add to this existing problem without a plan for an enhanced and safer hlghway. i i I 0 OEC 2014 Ir- I l-- 30 trG aE+t0/ Sl,ur', IQ or^d. I bappLea&{a cho{tLq:L3 ilt*- tL"Url /) 3w* 6Lt k/,ili{*,fr" Ph^,, du{of ntr^t /*Black PoW ? lartle aMs'dt),fl* lc lloa"y cowLntu,ff, p*ruod - .-..,,,..- ._.... -." -.'.,:.' *Jl"*tJ "la^/l,rt,;tr aal, ofisus t'o Ak/e. tlttlt 3 .Bwc*.a"tz- oj- tl, ,iltuttl/ tWltu?otfl,aufrr *log-k . ".#ota C-mol, s]4-L call ytof, qrttt/,vu?- Tlaf .+- - a a**{a,l{, {t?M e-{t te.'+ unt"tu q-tu4! fuan n+ _a&fur,l Mo ii at g// Wr.uh&,te .,,-..-r-.Y-v.-.-- - .-. r J31tffi,{12 1'5 *fu.td.ted 2-olt?4fM 1-o07A B-ag-tld!.ilt, tLllw,-$':w' ?*t lRllirjilnvjnl.) Jl[ 0 Lfrt. JIIftffiii-:.]i:l December 30,2014 Oavld Johnson, Associate Planner Jefferson County Department of Community Development 621Sherldan Street Port Townsend, Washington 98368 Re: Phasant Harbor Mastcr Planned Resort Dmft Supplemental Environmental lmpact Statement Attention: Mr. Johnson: The Hood Canal Environmental Councll(HCEC) has been lnvolved in the decision-making process regardlng the proposed Pleasant Harbor Master Planned Resort (MPR) profect since early 2006 - submlttint written and oraltestimony to the Jefferson County Department of Community Development (DCD) at every opportunity. As the process has dragged on for the last elght years we have remained consistent in our opposltion to the proposed MPR and our support for the local citlzen organlzation, the Brlnnon Group, whose members would be the most directly affested by the constructlon 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 (DSElSlforthe proposed MPR. We respectfully request that they be entered into the public record. GENERATCOMMENNi EnvironBental lBoaqts to Hood C:nal Watershed Ihe still Iargely undevebped rural character of the Hood Canal watershed ls what sets it apart from the morc densely developed and urbanlzed greater Puget Sound region. The publlCs perception of the unique and environmentally sensltlve character of this waterched ls evldent ln the State's designation of Shorellnes of Statewide Signlffcance for all of the shorelines of Hood Canal and numerous projects and proSrams aimed at protecting water quallty and related natural resources. Unfortunately, over the 45 years since the creatlon of the HCEC, we have seen a gradual "piecemeal" chipping away of the natural landscape from rapld growth and development in rural areas. Consequently, there are fewer open spaces throughout the Hood Cana! reglon. We now join with local resldents and vlsitors allke in placing the hlthest priority on protectlng what ls left of our natural undeveloped areas. The proposed MPR must be evaluated wlth the pot€ntial cumulatlve lmpacts to the broader Hood Canal watershed in mlnd. There can be no question that, under the preferrcd ahernative cited ln the DSEIS, adding another mega r€sort that includes a golf course, 890 residential units (includlng 52 unlts for staff housing), 55,6t0E q. ft. of commerclal area, and rercrt related amenities spread over 231 acres (not lncludlry the Pleasant Harbor Marina area), leaving very llttle natural, preserved arca and allowlng 1 mllllon cublc yards of cut and fill for golf course gradlng, poses significant unavoidable environmenta! impacts to the Pleasant Harbor/Black Point area. The HCEC fully supports the Brinnon Group, other or8anlzatlons, and many local resldents in rejectint the project-level development alternatfues (1 and 2) and choosing the No- Actlon Altemative 3. Page 1 D$ElS Altematlves The DSEIS describes ln detailthe so-called environmental and other beneficial impacts of ahernatives 1 and 2. However, there is very llttle discusslon of lmpacts under alternative 3 other than to repeat over and over that "the site will contlnue to develop as a slngle famlly resldential area based on the existing rura! zoning and as described in the 2007 Final ElS". Wlth very few exceptlon$ the document falls to demonstrate benefits to the envlronment of the No-Action Ahernative with an estimated 30 new residents (pg. l-11, Volume 1, DSETS) when compared to the others. Our letter dated 1G14-07 to the Jefferson County DCD commenting on the 2007 Draft EIS for the County's Comprehensive Plan AmendmenVPleasant Harbor Golf Resort details the many benefits of that documenfs No-Actlon Alternatlve. These lnclude signlflcantly lower density, fewer intensive uses, minimal topographlc alteration, least demand on groundwater and protection of the aquifer from saltwater intrusion, least traffic impacts, least potentlal for contamlnation of marine resources, least lmpervious surfaces, significantly lower demand for servkes, Increased probabillty for malntalning the rural character of the Brinnon community, retentlon of more open spaces, least dlsturbance of wetlands, and better protection of wildllfe habitat. Benefits of Alternatlve 3 Much is made throughout the DSEIS of so-called "improvements' to water and other resources from upgrades, e.t. sewer, stormwater plan, etc. if the proposed MPR project is constructed |W.3,2-7 Volume L DSElSl. However, there is no mentlon of the fact that most of these purported improvements could resuh !n the same or hlgher levels of rercurce protection when the various rcgulatory and other tools currently available ere utillzed and enforced. Existing buffer, setback and lot design regulatlons, county heahh department sewage dlsposalapprovalprocess, the Shellffsh Protection District response plan, upgraded requirements for exlstlng road$ray deflclencles, buildlng permit regulrements, shoreline permlttlng process, stormwater control plans, local state, and hderal prolect review and habitat mltlgatlon requirements and wetlands protect'on regulations are Just some of the numenous tools llsted in our 1G14-07 letter that are still avallable. The notlon that water quality, water quantity, and other natura! resource protectaons can be lmproved by albwlng the klnd of lntensive development resulting from amther meta r€sort in the Hood Canal watershed ls ludicrous. Addlng language descrlblng the benefits to the envircnment of Alternative 3 throughout the document would go a long way toward demonstrating non-biased'comparisons of the three atternathres. SPECIFIC COMMENTS The DSEIS presents a clearer picture of the prefened altematlve and offers rcme improvements fn m the orlglnal plan, e.t. moving the Maritime Village away from the Pleasant Harbor shorellne and consolldating some housing units to allow for more pervious surfaces. Honever, lt still presents unacceptable lmpacts to the Pleasant Harbor/Black Point area. Environmental Revlew of Pleasant Harbor Area The northern portlon (Phasant Harbor) of the proposed project is being evaluated under a BSP (Bindlng Slte Plan), a separate process which does not require involvement by the public and makes it very dlfflcuh to get a clear plcture of the impacts of the project as a whole. We support the Brinnon Grouy's positlon that this area should be subJect to a fullenvlronmental rerriew under the State's EIS process. a a Prolect Constructlon Pllgn$ The proposed proJect is planned to be constructed ln three phases over a 10 year period. Page 2 a However, there is no guarantee that thls plan wlll 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 resuh ln delaylng constructlon, e.g, the develope/s flnancial sltuation, contract andlor labor problems or any number of unexpected lssues. Unfortunately, the construction phase poses the biggest threat to natural res)urces, lncludlng groundwater, whlch will undergo the greatest demand at that time (Subsurface Group Memo dated2-22-L0). Ihe issue of noise pollution may apply here, since activities like rock crushing, are e,firemely loud. lmpact Cost Deoosit and Performance Bond Reouire$ent lf the preferred "no bulld" alternative is not s€lected, any approval of such a potentially harmful proJect ln thls fnglle envirpnment should be conditioned upon a complete analysis of the ascertalnable and potentialeconomic impact of the proposed MPR during and after constructlon. Before construction begins, the developer should be required to (1) deposlt the amount of all ascertainable direct and indirect costs retarding servlces and lnfrastructure lnto a fund available to local government to coverthe costs as they are lncurred, and (2) furnlsh a performance bond lssued by a hlghly rated insurer to cover all potentia! costs that cannot be ascertained beforehand, lncludlng repairlng any erwlronmental damage lncuned over a 50 year perlod 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 bulld" alternative ls superior because this proposed MPR lack assurance of no net envlronmental loss. Threats to Grovndwater and Aqq,lfer There is only one aquifer which would serve the entlre prolect area, includlng local residents. The dweloper plans to use an elaborate system of water menagement in an effort to protect the water supply. According to State Depaftment of Ecology (DOE) documents, aquifer recharge primarily comes from direct infiltration of precipitation (pg. 3.2-2, Volume 1). However, there ls no plan for preventlng drawdowns in the event of prolonged dry periods which, if scientific predlctlons of extreme weather events due to cllmate change (changes in the timing and intensity of rainfall) pnove accurate, groundwater and the aqulhr could be at rlsk. The darelope/s plan to lnject treated wastewater into wells poses the possibility of the lntroductlon of pharmaceutlcals and other pollutants lnto the aquifer. The greatest danger to the Black Point aqulfer ls the threat of sahwater Intrusion. Due to its sensitivity to sattwater intrusion, this area is deslgnated as a CrltlcalAqulfer Recharge Area and also an SIPZ (Seawater lntrusion Protection Zone). Residents llvlng in thls area need to be aware that accordlng to the Pleasant Harbor Neighborhood Water Supply Program Application dated 2-24-tO (W. 2, Appendlx F) lf thelr wells show saltwater contamination, the burden of proof as to whether the resort's water demands are responslble for the intrusion lies squarely on their shoulders. The Appllcatlon reads, in paG'The well orunor provides conclusive evidence that, over a statistlcally relevant perlod of time, chloride levels have lncreased over chlorlde levels in the wel! prior to Pleasant Harbo/s use of groundwater, lncludlng but not llmited to, evidence that the increase in chloride levels is from the Pleasant Harbor groundwater use and not frorn the construction of the well owne/s well . . ." (emphasis added). The developer also can "request addltional evidence from the resident showing that the resort groundwater withdrawa! is the cause of the lncrease in chlorides. . . o. Placing the burden of proof on well owners Page 3 o a saddles them with a bng and expensive process. We believe that the developer not on,y is responslble for supplylnt water to the resident in the event of saltwater intrusion, but should be responsible for the costs lnvolved ln the determlnation of culpability. A DOE Hydrologic (Rarised) Memo ftom John Pearch dated 1-14-10 shows that there is reason to belleve that wells in the Black Point area are already experiencing saltwater intruslon. Two wells have already been found to have salh^,ater intrusion. Under the lrcading of DomQslic Wglls. the statement ls made that ". . . nearby domestic wells are at risk of seawater intruslon due to their proximity to the coast ...' Also, "Addltional pumplng of the ACG well and additional proposed wells by Pleasant Harbor could cause thls saltwater lnterface to move further inland, thereby lncreasing the risk of seawater intrusion in these wells." Further, these wells were in the area where, accordlng to the memo, saltwater Intrusion would likely be found. Seven wells were not tested as requlred by Jefferson County bulldlng permltting. lf any wells have been decommiss'toned due to saltwater intrusion, that lnformatlon must be contalned ln the DSEIS. The DSEIS needs to clearly establish the develope/s responsiblllty for provlng that there ls enough water supply for both the resort and neighboring residents. This includes using updated wel! data and a monthly monitorlng prognm at the develope/s exprn$. 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 Mitication There are three "Kettles' and associated wetlands on Black Point - A, B and C. The developer plans to convert Kettle 4 which has a high rating of category lll due to lts habltat value and moderate to high value for water quality functions (pg. 3. 7-2, Volume 1) to a control pond for holding treated wastewater ftom the wastewater trcatment system to provide recycled water for rcuse and for golf course lnlgatlon and flre protectlon. To offset the conversion, the DSETS states that Kettle C may be "enhanced'. Slnce the wetland mitigation plan has not been done, h is imposslble to know how the los of the Kettle B wetland wil! be compensted. We feel strongly that in order to meet the state's no-net-loss of wetlands pollcy, Kettts B and associated wetlands should be kept in thelr 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 listlng of chemicals {herblcides, pestlcides, or fertilizers) that will be used for golf course grass maintenance or any discussion of how the developer plans to protect troundwater or stormwater runoff from the use of these chemlcals. 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 15 Watershed Management Plan should be noted and a plan for how the developer willadhere 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 counie, natural areas 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. Page 4 OTHER ISSUES OF CONCERil Whlle the HCECs prlmary area of interest is potential environmental impacts, there are other lssues of concern to the HCEC relatlng to the proposed MPR project. a Economk lmoacts on LocalCommunitv The developer has a responsibility to revealthe true impaas on the local economy from the proposed MPR durlng constructlon and operation. Of the estlmated 225 permanent operationaljobs that could be created, (pg. 1-1f and 1-12, Volume 1), the majorfi would be low paying Jobs. According the DSEIS, these lobs would pay t0 percent or less of the AMI (average medlan lncome) forthe Brlnnon area. Construction jobs would fluctuate durlng varlous phases of constructlon. Manyirbs would be seasonal and part time, including food service, maintenancc security, etc. lt is difficult to say who wlll beneflt economically other than the Brinnon buslness community, the Canadian based developer, and posslbV rcalestate developers. A study of fiscal and economic impacts of destination resorts in Oregon concluded that, after subtractlng the costs for services from the gross property and room tax revenue generated by the study resort, only a modest net surplus remalned. When the cost of capital facilitles including rcads, schools, fire and pollce stations, and others ls also accounted for, the net cost to localtaxpayers ls substantialeven after accounting for all known payments the resort would be requlred to make (Flscal and Economic lmpacts of Destination Resorts ln Oregon by Central Oregon landWatch - March,2009). a The HCEC remains concerned about whether Jefferson County has sufflcient staff and other resources that would be required to handle the additional workload of monitoring the proposed project for compllance and/or deallng with unexpected problems. a Additional Costs to Mason Countv P.U.D. I tt is not clear whetherthe Mason County P.U.D. f t has the capacity at the present tlme 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, dlstribution feeders and engineering studies and designs needs to be answered well before approvalof the proposed MPR project is considered. lt would be helpfulto know how much of a future P.U.D. rate lncrease can be attribdted to the lncreased energy demand from the proposed MPR. The impacts to Hlghway 101 from the increase in vehicles traveling to and from the alrport would be substantial. The develope/s, plan to rely on two shuttle buses does not take into account that most visitors wlll travel by car to and from the rercrt along highway 101. lncreased trafflc congestion ln towns like Hoodsport is already a problem ln the summer months. The HCEC is also concerned about vehicle-related ngn-point pollution, stormtrmter runoff enterlng Hood Canal and more greenhouse gas emissions resuhing from increased traffic. The data used to assess trafflc volumes in the DSEIS appears to be outdated. ln addition, during the constructaon phase, the increase ln trucks and other heavy equipment on Highway 101would likely lead to costly damages. Further, the questlon of who wlll pay for the additional highway repalrs and the extension of Jefbrson Countt's translt servlce needs to be addressed. a Page 5 Naval Base Securitv There is no mentlon of the proposed MPR's proxlmity to the U.S. NavalStatlon Bangor Subase and whether this might be consldered by the Navy to present a nationa! securlty lssue. Miscpllanous Pages 1-5 and 3.4-1 in Volume 1 refer to "Rainier" elk populations. The proper name is Roosevelt elk. Ihe ]ICEC appreclates the opportunaty to express our concerns and provide comments on the DSEIS for the proposed Pleasant Harbor Master Planned Resort. We look fonrard to continulnt our lnvohement and recefuing further information as part of Jeftsrcon County's public review process. Respeafully subm itted, Donna M. Simmons, President Hood Canal Environmenta! Council Page 6 o a David W. Johnson Sent: To: Cc: Frcm:Darlene Schanfald <darlenes@olympus.net> Monday, January 05, 2015 4:10 PM Davld W. Johnson Darlene Schanfats Pleasant Hartor DSEISi/c/o Jefbrson County DCD PLEASE CONFIR}T RECEIPT OF THIS ETIAIL Frlends of f,tllter Penlnsuta State Park PO Box 266{ Sequim WA 9E3E2 January 5, 2015 Pleasant Harbor DSEIS/c/o Jeffer:on County DCD 62t Shcridan Street Port Townsend WA 9E368 drd.ohnsor@co. lefferron.wa. rs Betow are comments regardlng the Pleasant Harbor DSEIS prcpared by Frlends of rttltter Penlnsuta Stltc Park, a 20 year, fe<leratty rccognlzed mn pmflt m the )torth Otynpic Pcnlnsula. We know that thele are llke and simitar to othcr comrnents belrB sellt, but want to underscorc that thece are isqm sf concem to ,mny that nccd to be addrusstd. We are disappointcd tbat this DSEIS was released over holidays and the response time sould not be extended, especially since years of extensions wer€ grven to the developer. POPULATION The poputation of Brinnon is about 818 and rnaybe hatf this number of homes. Expanding the number of tiving quarters by E90 residential units (Optlons I & 2) v{itt have an enormous impact in the area in many respects, incl.uding potabte water, storm water, sewage sotlds and effluents, relear of CO2 into the atmosphere and loss of CO2 rcit and tree sequestration. ECONOI tCS Few of the bultt units are intended for year round occupancy. ((The maJorlty of this houslnS (67ts) would be for short' terrn visltorc and 33* woutd be for permarient resldents.)) 67% or about 546 unlts arc hoped to be fitted, but ,nost tikety the targest percentage of PT occupancy witt be in the warmer tlme of the ),Bar. The lmpacts to the area catl for showing an economlc anatysls that this resort is financiatty vlable. We reqwst this be done. Has the resort company factored in the new WA State minimum wage for emptoyees? Where wilt corstruction workers (80.5[ out of the area] be hourd? Feasibitity of houslng them close to the site? Witt alt construction works be from WA Statc? How witt their traveting during high tourlst season affect normat traffic? Optlons 1&,2 detaits are descrlbed but the No Action, wtrich ls to build a few hundred homesltes, ls not detailed. lt seems, then, that this No Actton ls not belng serioustyconsidered. Yet, lt ls an Optlon and lt should have comparative details so the costs can be seen. You ask for the pubtic to wcigh in and the pubtlc shoutd have this information to conslder. Thls is an omlsslon and shoutd be corrected. Sublcct: 1 The lnformatlon shoutd be combined with thlt of the marina so one grasps an overall picture of the costs and potentiat impacts of the entire operatbn. What costs wltt be put to the area and state citizens? For instance, road repair from additional traffic the resort will bring, Utltity costs. ltedicat facitities. Taxation. This estimation shoutd be made pubtic up frcnt. GLOBAL WAR,vIING Stripplng thls tar8s area of trees and lts naturat gras6es, solts and rwttands wltl retease lmmense amunt of greenhor,se gases lnto the ar6lent alr. Earth removat wltl hare a Lrge affect on the mkmblal, soll communlty. A study needs to be done on how this GllG rcleasc and rcsuttlry dranges affrt both the harbor llfe and the runoundiry Brinrnn commmity. ApPendlx I$ docgr't qwffi the GHG rchase! and effectr of the rchases, and the mltlgatlons arc hardty thatl For sesJestration to vrork, ercn for thc rcphntcd treer, tlre amunt wilt rct balarce urt. lt takcs years to regaln that seque$ration, whether reptanted trccs or ncur Sra$. EFFLUENT Ctas A cffluent dtscharge from ttrc proposed sewerage trEatment plant is ptanned to be stor€d and recycled. Do not usc thls to recharge the aqulfen. Do not trt this for flrc protection and irrigation. lt will make flrefigfiter ilt. Thcrc are many studler that deGrmine rec)rcting of wastewater treatment plant (WWTP) efftuents are rnsafe. There are thousandg of chemlcals and many pathogens that cannot be tested for, nor thelr cwnulattva lmpacts. lt ls known that: . mlcrobeads from personat prcducts pas thrwgh WWTPs lnto efftwnt . iIRSA and other pathog€ns rernain in the slu{e and the effluent . antlblotk bacterla can be crcated in the \{WTPS . trklosan mlnlmlzes WWTP trcatmcnt ' cfflucnt contains ffrc retardants . effluent and vrett as the sollds contaln thouands of chemkats lnctudlng chemkats of emerglrg concern and POPs ilore rcason to not rccych th? efflLrnt: htto: / /$rvw.eoa.qov/oidrcoorrs/201 4/20140929- 1,t;P-0363.qdf llorc Actlm lr ]lrrdrd to Protcct W.tor Rffouracl From Unmonttorcd llrzardour Chcmlcelr ffA tlocs mt lraw melpnlsrm to o&tcss dlxtprge of iu,ardas clrrnlcals lfio wqter fia,lrlurcel. httlr://-rfirryJronHne.corny'ncws/hcelth/commondlsbctce-mc4lcrdqr.alrons-drugt-foEnd-in-lalrc-mi.hisllr- booarzr rzzr-z8zzs865lr.html Common dhb€tes medlcadon amongdnrgr fuundln LeleMfchfsm Therc is more than one way to measur€ prescrlptlon drug use ln modem soclety. The most direct method is just to count up prescriptlons fltted by Amerlca's pharmacles. That would show, for lnstance, that rmre than lE0 mittion prescriptions for diabetes drugs vrere dispensed ln 2013. Or you could test the treatd vrater comlng out of sewage faclUtles such as the South Shore ptant ln Oak Creek. That approach rryeals that in the Lake Michlgan waters outside the ptant, the dlabetes drug metformln was the most common personat care product found by researchers wlth the Schoot of FresIwltqr Sclences at the Universlty of Wisconsin-Mitwaukee. ,\ ore importantty, according to their latest research, the tevels of metformln were so high that the drug coutd be dlsruptlng the endocrlne systems of fistr. Last rnonth, a Journal Sentlnet/iledPaqe Todav lnvestlsatlo!. found boomlng sates of dlabetes drugs, whlch ln 201 3 had grown to more than $23 bltllon. ,ttetformh is a flrst-llne treatlncnt for type 2 dlabetes and is the rrxlst cornmonty prerribed medicine for the condition. ln 2013, about 70 mittlon prescriptions were dispensed, accordlng to ltr{S Heatth, a drug martet research firm. It ls so ublquitous lt can easity be found in water ramphs taken two mitm off the shore of Lake Michigan, 'l was klnd of a surprlse, said, 'What is thls drugl ' sald Rebecca Ktaper, a professor of freshwater science at Uwtrt, "lt was not even on our radar screen. I 2 Thc drt4: tst lnto the iew.te rnd eventu.lly the hkc bcceusc thoy rr. not brolcn down completcly aftcr tlny are cmrumcd and thrn cxcrctcd. The netformln concentratlons are low, cornpared wlth the amount taken by peopte. For lnstance, coming right out of the trratrnent ptant the tcvets are about 40 parts per bitllon. About two mites away, thcy drop to 120 parts per trlllion. Other comrmnty found substances include caffelne, sutfarpthoxazote, an antlbiotic, and triclosan, an antibacterial and antifungal found in soap and other consumer products. Ktaper co-autlrcrrd a 2013 rience Joumal paper on the finding as wetl as another one thls year. The more r€cent research ilggests that metformln ln take water is not Just a curlous artlfact of everyday tlfe. The study looked at the effect of metformin on fathead minnows in the tab that were exposed to the drug at leveb found in the take for four vreels. It found gene expresslon suggEstlng dhruptlon of the endocrlne system of male flsh, but not femates. !n essence, the males were produclng blochemkats that are assoclated wlth femate mlnnor:. The btochemlcats are pr€cursonr to the productlon of egg. Ktaper sald that because the minnows are a stand-ln for other flsh, the changes atso could be affectlng other species swh as perch, waltqle and northem plke. The UWM researrh conflrms what others have found regarding prescriptlon drugs showlng up ln Arnerlca's lakes, rlvers and stream, said l/ctlssa Lenczervskl, an assoclate profesrcr of geotogy and environmentat geosciences at Northem llllnois Unlverslty. For yeans, it vras assumed that the volurr of water ln the Grcat Lakes was so enormous that arry drugs that got thrcugh treatment facilities urcutd be dltuted to the point that they woutd not pose a probtem, said Lenczewski, who was not a part of the UWM study. That theory ltsetf now ls being dlluted. Even more concerning are the much hlgher tevels of antlblotlcs that are being put lnto rfirrrs and streams near plg farms where the drugs are used to prodrce [arger animats, she said. h addltton, stralns of antlblotk-reslstant bacterla atso have been found ln water lrear those farms, she sald. 'lt ls very atarmlng how much uE are rutting drugs out there in the environment,'she said. ln that this resort pbns to estabtish a medkat clinic for resort rnernben (& worken?) therc witt be medkal wastes in the WWTP, let alone from what goes dotm the dralns from the resldentlal unlts. WATER Very $orlsorne ls the avaltabltlty of water over a tong te.rm and the affe'cts on commmlty water needs. lf thh becornes prcblematlc, wlrat rcspon$bitftles wllt thc nerrt oyyner be hcld to? Once it is uscd, ft won't be rcaaincd. Water is golng to be t'he "gold" as neather wanns and snow lwets are minimlzed and ralrilvater runoff lrrreaseg. 5Ui,lt{ARY Thls corrnent coven only sorne of the problem wlth the planned resort aBd the oSE|S. Clearty, lt ls not approprlate to approve thls prorcct. Dartene Sdranfatd, Ph. D. Prcrldcnt 3 One of the rnost norrlsome lssurs wlth thls prolect ts tnfflc. Hwy 101 ls n thoror4hfare used by those travetlng htween Ctattam Courty and rprr southern polnB to Otympla. Additlonatty, the trafflc ls grcatly lncraased durlng the summer season. Roads arc narow. trlnch of the rcute is on btuffs whlch falt, as rorne Just nave thls Decernber 2014 cr€ating one way trafflc for rvceks. Landstldes arc comrpn on thls route durlng the nlny Fa$n. Trafflc acsldents happen. One can lmaglne that thh r"lort tr.ffk nccd3 witt be ogenscd to the State, herre the cltlzens. Thls rercrt area ls an lnhocpitabte site for a taryc rcson. TRAFF|C fi}:#ffil iD JAN()5Al[ 5 January 2015 JffrffiI[fiiililY0[0 Jeffercon County Department of Community Development Attn: David Wayne Johnson RE: Pleasant Harbor Master Planned Resort DSEIS 621 Sheridan Street Port Townsend WA 98368 dwj ohnson @ co j efferson. wa.us On behalf of Sierra Club North Olympic Group and our hundreds of members, activists, and supporters, we are writing to submit comments on the Pleasant Harbor Master Planned Resort DSEIS. Please include these comments in the administative record. Sierra Club feels there are serious omissions in this Draft Environmental Impact Statement that must be corrected. Our comments on dilferent aspects are listed below. GLOBALWARMING: An assessment needs to be done and presented on how this project will affect global warming and the microbial soils community due to extensive plant and soil removal. Appendix M doesn't quantifr the GHG releases and eflects of the releases, and the mitigations are clearly inadequate. It takes years to regain sequestration of carbon,and the DEIS also fails to factor in how this would affect marine life. R ll-l* -'-' EFFLUENT: Class A effluent discharge from the proposed sewerage freatment plant is planned to be stored and recycled. This is a dangerous practice that should not be used due to inevitable pathogen transfer to aquifers, There are thousands of chemicals and many pathogens, (microbeads, MRSA, antibiotics, fire retardants and chemicals of emerging concern) that cannot be tested, nor are clearly known for their cumulative impacts, ffid that will be introduced in a recycling system. WAIER: Another very worrisome issue is the availability of water over the long term and the effects on courmunity water resources. Water will become a key resoutce as weather warms and snow levels are minimized and rainwater runoffincreases. The DSEIS does not address this truth. SUMMARY This comrnent can only cover some of the problems with the planned resort and the DSEIS. Clearly, it is not appropriate to approve this project. Respectively submitted, Monica Fletcher Chair North Olympic Group, Sierra Club monicaflet@gmail.com TRAFFIC: One of the most worrisome issues with this project is traffic. Hwy 101 is a thoroughfare used by those traveling between Clallam County and more southern points to Olympia. Additionally, the taffic is greatly increased during the summer season. Roads are narrow. Much of the route is on bluffs which fail, as some just have this December 2014 creating one way traflic for weeks. Landslides are common on this route during the rainy season. Traffic accidents happen. This resort area is an inhospitable site for a large resort. Davld IY. Johnaon Scnt: To: Cc: Sublect: Frpm:J Hal Beattie <Jhalbt@gmail.mm> Monday, January 05, 2015 2:44PM Davkl W. Johnson Bekah Roas Brlnnon MPR DSEIS comment Comment [XlElS Brlnnon MPR O5Janl5.docx Mr Johnson Attached and Included in the text of this email are our commeirts regarding the proposcd resort on Blapk Point. Sincerely J Hal Beattie Rebclrah R Ross Commcnt on the Statesman MasterPlanned Resort located in Brinnon, Washington From J Hal Beattie and Rebekah R Ross, Brinnon, WA 5 January 2015 Otn property shares aboundary with the proposed r€sort. As such we have several concems with its development. Or,r main concerilr arE as follows: l. Well waterquality 2. Traffrc 3. Noisc 4. Rural ctraracter The proposed resort puts our water supply at risk. \Mtat happens if our water supply dries up or is contaminated or tums salty? Our water presently is not salty as confirmed by Departnent of Ecology testing in 2009. Houever our well drarvs water from appx 50' belorv sea level, making it vulnerable to I Attrchments: salt water intrusion if the head produced by the overlying fieshwater aquifer is sufficiently reduced by resort use for the freshwater/saltwater interface to rise. Noise. Black Point is at present very quiet. The addition of 2000 plus more people as resort residents and employees will add s(7nificant noise pollution. ln addition there is a possibility of float plane service to the resort. Thare is cunently one privately owned float plane that occasionally flies out of Pleasant Harbor. Even though we cannot see Pleasant Harbor from our house, we know ftom the noise when that plane is landing or taking off. lf the MPR operates like other time shares, exchange of clients would come on Saturday and Sunday. Even moderate float plane service ulould raise airplane noise to unacceptable levele. For example if even 10o/o of the resort population uere to choose to fty in and out on a Saturday or Sunday, that would mean 30 to 50 nights each day. That is a lot of nobe. Rural Character Brinnon is a pretty sleepy and laid back place. The development of a resort on Black Point will undoubtedly change the charac{er of community. There willbe more people, more transitory people. The resort will not be self contained. I envision a demand from the resort cllents for services that the community does not now have, or at least in volume. I see things like a strip with fast food, souvenir shops, and other cfieap stores that are ubiquitous in coastal towns nearly everywhere. Other Comments and concerns The Draft SEIS is fullof typos and inconsistencies;too manyfor me to list here. Wewould hope a better rcview and editing of the finalwilltake place. 2 Trffic. Assuming only one trip out per unit per day would add nearly 1800 vehlcle trips per day in and out of the reeort and the enffance onto 101 ftom Black Point Road. That will be a significant rise ovor present flow. Use of the boat ramp at pleasant hafuor. Present use includes rscreational boating fishing and tribal fishing boats. On a busy day all available boat trailer parking is taken. Wllthe resort supply overflorv parking or require their boating clients to park their rigs eleewhere? Many jobs at the resort will be seasonal. Wll those workers become part of the permanent population of Brinnon? What happens to those seasonalworkers during the off Beason: unemploynent or welfare? What happens if Statesman cannot make a go of it? Wllthe next owner be able to maintain and operate the resort in the manner proposed by Statesman (ie low use of pesticides and herbicideg, low water use protocols, energy efiicienry)? What if there is no next owner. Can the resort be bonded to cover expenses to deconstruct if the rcsort fails? 3 Steven John Walker 33l Dosewallips Rd Erlnnon, WA 98320 Pleasant Harbor DSEIS c/o Jefferson County DCD 521 Sheridan Street Port Townsend, WA 98358 Vla email to dwjohnson@co.lefferson.wa.us 5 January 2015 - ,t) RE: pteasant Harbor Master ptanned Resort DsErs Jtttt$$Iil [tliliil llil The 20fi)'s era adoption of the Jefferson County Comprehensfve ptan including zoning for a Master Planned Resort at Black Point was a slngular act of folly. The passage of time has done nothing to change the fact that plunklng down a luxury resort in the rural county, far from exlstlng lnfrastructure and services will have a suite of negatlve culturaland environmental impacts which cannot be mitigated. The proponent's DSEIS document lgnores orotherwlse glosses over many of the most substamial of these impacts, and therefiore must be deemed lnadequate and incomphte. I havc identifled the followlng adverce cultural and environmental impacts which nehher the prolect proposal, nor the DSEIS are able to adequately addres or mltlgate #Fundamental change to the communlty #lmpacts to the natural view shed of the Duckabush River Delta, and other aesthetlc issues. #lnadequate Traffic and Greenhouse Emlsslon Analyses flEmergency Servlces f lnadequate Greenhouse Emissions Analysis #Possibility of Failure For these reasons, it is imperatlve that the DSEIS be rejected in ats current form, untilthese issues are adequately addressed and d iscussed. f Fundamentalchange to the demographics of southeastern Jeffurson County, and crcation of a two- tiered socie{therein. As planned, the pmJect would nearly doubb the population of the Brlnnon area ln ten yeaE, a populatlon whlch has been relatively stable or seen only lncrementalgrowth orrer the last century. Furthermore, thts nur population (presumably upscale lndlvlduals who could afford to, and would choose to, llve ln a golf-course/resoft settinglwill have very little in comrnon wlth Brlnnon's cunent, prcdomlnantly working-chss population. As a rcsuh, we will see the creation of a two-tlered soclety ln the Brlnnon area, with the cunent populatlon largely becoming the servant class of the new resort populatlon. R JANOSAT This is absolutely clear by the fact that the resort will be a gated communlty, with public access restrictd. The crcatlon of hlghly-stratlfled class systern In rural, southeastem Jefferson County is one of the fundamental negatlve impacts of thls prorect proposal, and one of the prlmary reasons why it should be reiected. flmpacts to the natural vleur shed of the Duckabush River Deha, and other aesthetlc lssues. Ihis study does not dlrectty discuss the impacts to the Duckabush River deha vlew shed, except to use weak meanlngless language whlch wlllnot translate to actual planning prescrlptlons. The toplc ls mentloned only brlefly (3.15-2) but aholutely does not describe how the resort wlll appear from the south and whether or the prlmarily natural vlew shed of the Duckabush will be ahcred, and to what degree. No figures, dlagrams, or artlst repres€ntations of the ahered view are presentd. There ls no discusslon of to what degree the 200 foot shoreline setback will or will not obscure the resort. Untll thls toplc ls addressed, the DSEIS will remaln lncomplete and adequate with respect to the sublect of aesthetlc impacts. #Emergency Services Emergency rcsponse times for llfe-savlng care to regional hospitals ln Port Townsend, Sequim, or Shehon are prohibltively too long from Brlnnon. As a resuh, the typicalevacuatlon for a severe accldent yictlm is via hellcopter to Harborview Medioal Center ln Seattle. We can expect with more resldents, and more traffic on the 101, that the number of hellcopter evacuations to Harborview wlll increase. Additionally, !ffe-threatenlng sltuatlons such as heart attacks can also requlre hellcopter evacuatlons, Brinnon ltself has no medicalfacilities, while Quilcene has a small clinlc. Thus, even mlnor incldents that could be routinely handled ln a more populous area with more faclllties rnay qulckly escalate into emergencies. frTrafflc Analysls The sectlon 3.9 dlscussbn of colflslon hlstory ls lncredlbly brief and deflclent. lt brlefly dbcusses dastant interchanges such as WA Hwy. 100 / Center Road but completely omits d'scussion of the real rlsk, whlch ls accldents along the reaches of US 101. The sectlon of highway between Qullcene and Hoodsport is a wlnding, poor visibility route wlth hrge sectbns of minlmalto no shoulders. As discussed below, the analysb also ornlts conslderation of trips generated by resldents cominuting to distant employment. An addltbnal 0.33 EMS unlts wlll do very llttle to mitigate these impacts. An adequate dlscusslon would attempt to fully estimate the number of expected lifu-threatening and other serious incidenr which would require helicopter-based evacuation. A maJor earthquake orflooding event has a very rcal possibility of bolating the resort frorn the outside world. Just recently we've seen US 101 reduced to a slngle lane south of Brlnnon, wlth the WSDOT reportlng that lt wlll be months before traffic returns to two lanes. The potential closure of 101 due to mudslldes, rockfalls, or erosion, or the loss of one or both of the Duckabush/Dosewalllps bridges could completely lsolate the resort. In the case of a malor catastrophe such as an earthquake, ovenrhelmed emergency response units could leave the resort effecttuely on its own. The injured or ill could expect no medkal response for days. This ls one of the reasons why it is inapproprlate to slte a maror developrnent ln a rural area lacklng servlces. This b also a fundamental flaw In the DSEIS ln lts present form. For thls reason, the proposal should be denled untll or unless the proponents are able to provide an adequate discussion of how th€ isolated resort would respond to a catasfiophlc naturaldlsaster. fConcluslon ln concluslon, whlle t understand that the Je{ferson County Comprehensive Plan and Zonlng dbw for a Master Phnned Resort at Black Point, they certainly do not reguire approvalof any glven ploposal. ln the case of this proposal, ttre resort h slmply too larye for a rural, lsolated communfi to assimllate wlthout fundamentally changing the core aspect of the oommunlty. I understand that this is a speculative proposal, and that the proponents need to be sized substanttally enough to for it to be economkally vlable to them, However, thls economlcdrhen scope from the proponent's standpoint should not be allowed to drive the process at the regutatory level, Together, these toplcs greatly under-estlmate the number of additlonalvehkle miles which will be generated by the resort, and therefore the vplume of greenhouse gasses whkh wlll be produced over the perlod of the resorfs ltfe, Presumably, with nearly 3fi) permanent resldentlal unlts and an estlmated 556 new permament resldents, not allof these resldents will be rctircd or members of the idle rich. Some of them rnay in fact work for a lMng. Jobs for these presumably upper-middle class lndividuals are absent ln ruralJefferson C,ounty. These permanent resldents wouH presumably thus commute to dlstant areas such as Shelton, Port Townsend, Seguim, or Kitsap for work. Even the roughest cahulation shows that a slngle commuter would generate on the order of 400 weekly round-trlp mlles to reach these Job markets (40 mlles one $ray to Shehon or Port Townsendl. Even if only 18% of permanent resldents commute to work, this would represent an additional4O000 weekly mlles, and 2fi),000 yearly mlbs drlven by commuting resHents of the resort. Glven that nelther the trafflc nor the greenhouse emlsslon analyses appear to account for these commuter mlhs, both must be deemed incomplete and lnadequate at thls tltne. f,lnadequate Trafflc and Greenhouse Em'ssion Analyses Jefferson County must make a realisth estimate of what level of economlc danelopment b both viable, sustalnable, and realistic in the Brinnon area. The comprehenslve plan and MPR designatlon notwithstanding thls proposal hils tests of viability, sustalnabality, and reallty and therefore shouH not be approred ln lts current forrn. (electronlcally slgned 5 January 2015) Steve Walker STATE OF WASHINGTON DEPARTMENT OF ECOLOGY PO Bax 47775 , Olympia, Washington 98504-7775 . (360) 407-4300 711 for Washinglon Relay Servroe , Fensons with a spech disability can cail 877-833-6U1 January 5,2015 Mr. David Wayne Johnson Jefferson County Community Dcvelopment Departnent 621 Sheridan Street Port Townscnd, WA 9E368 Dear Mr. Johnson: IR.ECBNItr'D JNt 0 5 01t lttft$$lt0t''il1\ti$ Thank you for the opportunity to comment on the draft supplcmental environmental impact statcment for the Pleasant Harbor Marina and Golf Resort LLC Master Plannad Resort Project (Case Nos. MLA08-00188, ZON08-00056) located at Pleasant Harbor, south of Brinnon as proposed by Pleasant Harbor Marina and Golf Resort, LLC. Thc Department of Emlogy @mlogy) rcviewed thc information provided and has tlre following comment(s): SEORELANIDS & EI{VIRONMENTAL ASSISTAI{CE: Rlck Mraz (360) 407-622t hior comments werc provided rcgarding wetlands on Octobcr 24,20W (see enclosure). They included the following information: Placement offill in wetlands may require an individual or general (nationwide) pcrrrit from the U.S. Army of Corps of Engineers (Corps). We advisc the applicant to contrct thc Corps to determine if a permit is needed. Should an individual Corps permit bc requircd, a water quality ccrtification will also be required from Ecology. If the wetland is dctcrmined to be isolatcd and not subject to the Corpo jurisdiction, it rcmains a jurisdictional wetland for Ecology, and will require permitting by this agcncy. For more information, please contact Rick Mraz, Wetland and Shoreline Specialist at the phone nurnber given above. WATER QUALITY: Dcborah Cornett Qfi) n7-7269 Etrosion control measurcs must be in place prior to any clearing, grading, or construction. These control measurcs rnust bc cffective to prcvent stormwater runofffrom carrying soil and other pollutants into surface water or stonndrains that lead to waten ofthe stae. San4 silt, clay particles, and soil will damage aquatic habitat and are considered to bc pollutants. Any discharge of sedimcnt-laden runoffor othcr pollutants to waters of the state is in violation of Chapter 90.48 RCW, WaterPollution Control, and WAC 173-201y'.,\ilater Qualtty Standards for Surface Waters of the Starc of \ilashington, and is subject to enforccmcnt action. January 5,2015 Page 2 The following construction activities rcquire covemge under thc Construstion Stonnwaler GeneralPermit: l. Clcaring grading and/or excavation that results in the disturbance of one or motE aqrs end discharges stormwatr to surface water ofthe State; and 2. Clearing, grading and/or excavation on sitcs srnallerthan one acre that aro part of a larger common plan of developmcmt or sale, ifthe common plan of developmcnt or salc will uhirnarcly disurb one asnc or more and dischargc stormwater to surfacc waters ofthc Statc. a) This includes forest practices (including, but not limited to, class [V conversions) that are part of a consEuction activity that will result in the disturbance of one or morc acrcs, rnd discharge to surface waters ofthe St*e; and 3. Any size construction actiyity discharging stormwater to waters of the State that Ecology: a) Determines to be a significurt contibutor of pollutants to watcrs of the State of llVashington. b) Reasonably expects to oause a violation of any watcr quality strndsrd. Ifthcre are known soiUground wder contaminants prElr€,nt on-site, additional information (including but not limitod to: ternporary erosion and sediment mntol plans; storm*,atcr pollution prEycntion plan; list of known sontEminants with concentations and dcpths found; a site map dcpicting the sample location(s); and additional studies/rrports regarding contaminan(s)) will be roquired to be zubmitted. You may apply onlinc or obtain an application ftom Ecology's wcbsite at: http:4www.ecv.wa.gov/proerams/wq/stormwater/constructio!/ - Applicatiop. Construction site operators must apply for a permit at least 60 days prior to discharging stormwater from construction activities and rnust submit it on or beforc the date of the first public notice, Ecology's commens are bascd upon information provided by the lead agency. As such, they may not constitute an exhaustive list ofthe various authorizations that must be obtained or legal rcquiremcnts that must bc fulfillcd in order to sarry out the proposed action. If you have any questions or would like to respond to these comments, please contact the appropriate reviewing staff listed above. Department ofEcology Southwest Regional Office (SM:la-5991) Enclosure cc: Deboratr Cornett, WQ Rick Mraa SEA Joyce Smith, HQ/WQ Pleasant Harbor Marina and GolfResort, LLC (Proponent) David W. Johnson From: Sont To: David Galle <vinibraman@yahoo.com> Monday, January 05, 2015 12:10 PM David W. Johngon commenta on Statesman/Black Point DSEIS9ubicct: January 5, 2015 To: Mr David Wayne Johnson, Project Planner, Jefferrcn County, WA (sent via email) Dear Mr Johnson, Thls mesage contains my comments regarding the Pleasant Harbor Master Planned Resort Draft Supplemental Environmental lmpact Statement (DSEIS) that was published on November 19,20L4. Would you please verlfy that I've sent these comments to the conect addres (ie, you), or else tell me where they should be sent instead? ! llve near Hoodsport ln Mason County. Even though l'm not a resident of lefferson County, this proposed resort will have enormous impacts on anyone who lives in the Hood Canal region. The'lmprovements'contalned in the DSEIS over the project plans presented in previous documents rante from mlnlscule to insignlflcant and lt's readlly apparent that no serious attempt has been made to mltltate the numercus serlous lmpacts this proJect wlllfoist upon the area where I llve. Further damage to the Hood Canal ecosystem, removalof wetlands, Increased traffic and progrcssive saltwater inflltratlon Incurred by this proJect are among the most glaring issues that have been essentially lgnored by the developer ln thls and prwious documents, amont a host of others. Furthermore, the daneloper should not be allowed to wlthhold from public view project plans for the Pleasant Harbor marlna area or any other parts of the project that dont contain proprletary or othenrlse conlldentlal information. I urge you ln the strongest posslble terms to not permit thls project to go fonrard until the developeroffers a complete mltlgatlon plan for ALL of the potential project impacts, and is fully transparent regarding plans for existing facllities such as the marlna. Thank you for your consideration. /s/ Davld 6alle PO Box42t Hoodsport WA98548 I Jefferson County Planning Commission Public Commentary on DSEIS Nov. 19 2014 Rob Mitchell 4246 tluclabush Rd. Brinnon, Wa. 98320 R.ECPIVID]D JAll 0 5 nil ffiHa3illffi5l[iIl[t I protest the fact that the developer was allowed 5 % years with no deadline to produce this maesive documeirt and delivered during the holidays when many oounty residents are away and unaware of it's existence. Furthermore, the Fublic Commentary Pedod is inadequate. I ordered and purchased a hard copy at my own cost of $71,67 which was not available until I lnsll4 Many of the Brinnon Residents do not have adequate intsrnet service to view this document or can afford to buy one. The DSEIS forthe proposed Black Point MPR is inadequate thercfor€ Alternative 3 or No Astion mustbe A) The Traffrc Study is highly inadequate. Highway l0l on the East side of the Olympic peninsula is the only non toll dir€ct connection to the I-5 corridor and is usd for all major shipments ofgoods, services as well as nesidents and tornism both on and offthe peninsula Wheu serious accidents occur dong 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 Inthe 2007 EIS P.34 Trmsportation it states. "The Comty identified 5 specific issues to be addrcssed as part of the Transportation Review.'The very first requirement is the most important. l.) us HwY l0l The Loss of Service (LOS) data was ftom tlre year 2000. The aotual car trip count data dates bacl to 2006. Neither of these are cunant in20l4. Transportation Engincering 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 "Therr is no evidence of unsafe driving or roadway conditions thoryh review of historical collision rscords or review of general geomefiic conditions in the general vicinity." "lVhile collisioos do occru along roadway segments there was no evidence noted to suggcst specific review along roedways. tf WSDOT or Jefferson County had identified specific "high accident corridor" in the vicinity then a review of roadway segment collision statistics would have becn couducted. Absart this deterrrinatioru this analysis was not warranted." Transportation Engineering of North West LLC did not count accidents in non intersection highway segments. Th,ree of the most notoriously dangerous sections of roadways arc in the irnmediate vicinity of the MPR. l.) South bound, l/100'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 Ere sources forhrurdreds ofvery serious accidents, including our oum Sheriffs Dept. which shuts down this vital corunrercial route for as long as 6 horns. (See Traffc's Financial Impact Study www.wsdot.wa. gov/. .. I Jvnez0 12 _lmpact_Freight_Congestion.pdf ) The taffic analysis shows that out of 4100 oar trips aday 3V/o or 1230 carc a day will pass the first hro dangers southbound,650/o or 2665 cars a day will negotiate Mt Walker Pass. On the two side arterials of Duckabush and Dosewallips Roads it will tx 3o/o or 123 cars a day or over a l0 hour period 12,3 carVlroru. The 2 public trail heads up the Duclobush have a combined parking area of @36 vehicles. The response from Transportation EngineeringNorth West LLC is that "this insrease in traffrc is common with developmeots of rhis size and with the mitigations proposed (the shuttle bus and passeng€r van) no adverse impact is expected." This is inadequate mitigation. B.) h a2013 meeting at Departrrentof Ecology while clarifring the awarding of water rights to Stat€smao Corp. John Pearch, LHG informed us that "No class A water treatment system nemoves soluble chemicals" The MPR proposes to re-use this water in inigation, fue suppression and aquifa recharge. This would meatr that hundreds of medications people use daily will tum up in the single aquif€r under Black Point. The water rights were awarded but additional wells rvere never drilled. A prunp test was atternprted on an existing rvell but was aborted after equipment failure so draw down rate and available volume was never proven. Usage arnounts have not and will oot be determined until full build out with the caveat that for each phase during the possible decade long constnrction adequate water must be proven. If the developnent is stopped rvho pays to moth ball it or restore it to natrral conditions? There is physical evidence of saltw'ater intnrsion having occurred on the edges of the Black Point Aquifer. DOE has conditioned that rnonitoring must be done and for as long as l0 additional years after build out completion. Statcsman has put several restrictive conditions on what an individual well owner has to do to prove their potable well water was los due to Statesman's actions. This is in conflict with the DOE conditions on the water rights. Statesmon condition's that they can demand additional evidence that they are at fault. If they do accept fault thc oumer rnay hook up, at Statesman's cost, to their water system and then they will have to pay for,it's tse. This is also in conflist with ttre conditions DOE placed. (See Pearch Hydrolory 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 uscd will be scrapers, excayatom, bulldozers, wheeled front loaders; a portable screcning plant, feed-hopper, portable gRvel crushcr, finistring crusher, water trucls, highway/of-road tnrcks...conveyor belt systems and vibratory/sheepfoot compactor rollers." This will be 1200 feet away from the closest existing residence. This is inadequarc mitigation. D.) There is no estimate of the tonnage of Bio Solids the beatment plant will produce althougb" there's mention of it's transport offsite that will increase heavy tnrok trafhc. It's stated that it will be processed at the propos€d Shelton Plant yet there is no evidenoe of this. E.) This resort will also conffibute 1415 tons of refuse per year to be tucked offsite to land fills. F.) The rcduction of the rcsort structure's foot print results in constnrction savings for Statesnran 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 "Grcenet''also creates construotion savings. The Grcen Washing of this resort does nothing to mitigate the enonDous ncgative impacts on the local roads and community due to the massive scale of the project. Garth Mann and Statcsuran goup 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 Couty were to be mitigated by Memoranduns Of Understanding (MOU's) but achieve little for ou citizens. l.) EMS: In 2013 there were 249 EMS calls per the797 people of Brinnon (2010 Census) which is 31%. Add the estimated population of 2000 Resort peoplc means that there would be 620 calts per year, While Statesman will pay the Fire Dept $10,000. per qusrter or $3,333 per month only duing consfitrction that amount is lcss than it would cost to hire an additional EMT. After fuU build out the collected taxes are estimated to bc enough for increased services and calls but now the estimated construction tine is vaguely as long as ten years depeirding on the economy. Starcsman will supply a wed ladder truck so our volunteqs can fight fircs in buildings as tall as 70'. However the Fire Dept. is responsible for all taining personnel for it's use and upkeep and mechanical maintenance. 2.) Poliee: Due to b'udget shorlages the Sub Station in Quilcene was closed. Starcsman will sttpply a 50O sq. ft. room (25'X20' or smaller than a 2 car garage) but without the budget to supply and staffit. 3.) Employce Housing: Since most of the ernployees will b€ from out of Brinnon and probably Jefferson Corurty Statesmaa will build "Affordabld'housing forthem and collect rcnt. 4.) Schools: Basically get nothing until collection oftores afier fuU buitd out, use of an on site space for lectures on how grcen the MPR is. The only money they will receive is 2 dollars per tec timc md spa use will be paid to the school disfrict as well as I dollar per hour for students hircd 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')<20') for an LNP or GP for use by r€sort members. 6.) Construction Jobs: A prcject of this magtitude is done by Multi National Commercial Company which means that the principte profit will leave town. Sub Contactors would be required to have the commercial level of insurance and usually have worked with the Gencral Constnrction compny before. The only additional workers needed will be Minimum wage day laborers. In the EIS 3.tl-5 ConsfructionEmployurent it states that 1750 jobs will be created but this number is the total for all four phases ufueir in fact many of the jobs will be the mme for all four phases. For example the sit€ prep, excavation, forurdatioru framing and finish crcws will rcmsin the sarne so this nurnber is false. In 3.1l-15 vague promises re made such as the new-e,mployment40UlD-lowq the Jefferson County unemployrnent rate- depending -on whether the individuals reside there. fuid, it's POSSIBLE nearby businesses will experience and increase in business. In Appendix N, pg. 29 is the oonchsion ofjobs created. The Average Median Income (AMD in Brinnon is$42,679. The nuurber ofjobs cr€ated which are At (807o of $42,679. = $34,143.) or Below the AMI arc223 people. The conclusion found in Appeirdix N page 28 bascd on tables 3-l through 3.4 (pages 8- I 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 thosc are part time employment. It's estimated that "Walmart costs surrounding communities $13 million in economic activity and $14.5 rnillion in lost wages over 20 years " (see htto://ougetsoundsage.orE/dolvnloadVWgl-mart-Fowler-Reoort-2012-04-06 l-l.edfl In Tables l-20 for all phascs of constnrction these are ilre total jobs created and annual incomes. 48 jobs are above the AMI rangrng in income from $36,000. to $52,914. 108 jobs are from $10,593. to $14,3E1. l2l jobs are from $19,241. to $28,00. The 2014 Poverty Guides from the US Dept. of Health & Human Scrvices are; Family of 5 annual income of $27,910,4 23,850.3 19,790,2 15,730. In conclusion out of 280 jobs qeatcd an incredible E3% are considered Poverty level. See http//aqpe.hhs. gov/POVERTY/l 4poverty.cfm 8.) Public Use: Is limited to the bike and walking paths.Tee times are restricted and a limited number of the Resort's features can be used and paid for by the local commrurity Many ame,nities zuch as trse of the pool and tennis courts are for Resort residents only. 9.) Tax Revenue; State taxes are collected of 9/o and sentto Olympiaof which 6.5% stays there and the leftovff 2.5o/ois retumed to Port Townsend the County scat. Both of these entities have free reign as to where and how it's spent while the citizens of Brinnon and those commurities along Hood Canal bear the brunt of traffic and safety. Levies attached to our property taxes will go to help our school, fue dept, and County Sheriff. These furds \4rill not be available until Phase 4 and Full Build Out arp achieved. This is a developme,nt of massive scale. If allowed to go ahead lyittr thcsc multiple inadequacies in the DSEIS it will require a large invesfnent but also reaps very large short-term profit for the dweloper and that rcv€rlue leaves. If the develop€r stsys on as the Property Management Co. or contracts to another multinational company ln either case property management is still pmfit driven, Up keep of the MPR's in&astructur€ will be paid for by user fees and Home Owner Association fees, which will rise as deterioration begins and operational costs rise. The PUD created for the opcration of the Water System and Sewage Treafrnent Plant has to make enough profit to cover maintenance and futwe rc,placeurent of deteriorating equipment. Some time in the future the entire Sewage Trtatnent Plant will have to be replaced. Who and how is thatpaid for? See http//www.fbdqrandasqociatcs.com/Reportq/Destination-Resor-t-I$roact Studv.odf lmpact of Destination Resorts in Oregon Fodor & Associates March 2009 page 85 lf Thomburgh Resort is successful, iF developer could make $300 million on lot sel€s, almoet doubling its investment. The lucrative profit potentlalfor developers crgateg a formidable inoentive for them to prlrcue resort projects on Oregon's cfieap rural lande in beautrfulnaturalsettings. They can afiotd to spend liberally to make their resort projests poeeible. Economic lmpad Conclusions Many of the economic impact sfudiee provided by developers portray an overly optimistic picture of the development projec't's beneffts by ignoring the cogts associEted with providing public servioos, public inftashuc{ure, and the potentialadverse impact on thE oommunig and the environment. The'ldsure and hocpitalitf sector (that includee destlnation resorts) paid average annual wag€s of only $16,096, the lowest of any employment sector in Deechutee County and about half as much as the a\rerage annual wage in the County of $31,492 in 3o*' Even if tr,vo members of a household worked full time at the Thomburgh Resorl, they would etill make lesg than the median houeehold inoome in 20M and the effec't of the :*rt will bs to depress median wages in fie County. Household incomes below $21,200 represent the Federal poverty level for a family of :o" Most jobe created by the resort will be temporary and when conetrustion is completed, 1,471 jobe will be logt, causing ripple effsc'ts in the localooonomy. The addition of more than 2000 peak new jobs to Deschutes County will have a very significant impact on the localhousing market, especially when the tcmporary jobs are lost. a Low-wage jobo created by tre resortwill increase demand for affordable housing. *U" the Petereon Housing Report estimefes a ppak of only 133 nEw households generated by Utc resort, it is more realistic that a peak of 97E new households will need to find housing in DeschutEs County. Afterthe resort is completed, there will b€ an estimated permanent demand for 347 new housirB units in the County Davld W. Johncon Frcm: Sent: To: 3u$ect: Attrchmcnts: kirie pedersen <kirie. peders€n@gmail.com> Sunday, January 04, 2015 9:49 AlVl David W. Johneon Public Comment on Black Point DSEIS DSEIS PROPOSAL COMMENTS-2O1 5.dOCX Attention: dqiohnsont@co.iefferso$.wa.us From: Kiric PederseU M.A. 687 Pulali Point Road Mailing address: PO Box 687 Brinnon, WA 98320 (360) 316-9066 - cellular To: David Jobnson DeparEnent of Community Development Port Townsend, WA 98368 Re: Proposed Pleasant Harbor Golf Course aod Resort DSEIS Date: January 3,2015 Greetings, I am a lifelong Brinnon resident My family has lived on Dabob Bay since 1946. I was bom here, raised here, and pay taxcs hcre. I know the envimnrnentand community from participating in it and observing it over six decades. Over the past several )rcffs, I have atteuded num€Klr,rs meetings regarding proposed resort dwelopment at Black Poinl I have also conducted hundreds of hours of rpscarch into this and prwiors proposals for Black Point, and snrdied similar proposals and complaed projects and their impacts on oristing communities in the San Juans, Clallam County, and elsewtrere. My particular concerns with the cument Blapk Point DSEIS include but are not limited to highway use, road safety, water qualrty in Hood Canal, overdevelopment on a fragile shoreline, potential for adverse impacts on ou existing economic base of tourisrq fire danger, and the statistically high risk that taxpayers will bear the bruden of this developrnent and/or its potential for failure. 1 I am deeply conccrned that this proposal was handed out forpublic comment overthe Thanlsgiving thrcugh New Year's holidays when many arca taxpayenl are out of the anea or involved with farnily and guests and challenging weather conditions. The timing of this public comment pcriod makes it questionable as to wtrether we, the public, were even offered adequate time or opportunity for review. Due to my family's, neighbors' and my own dcpendency on wells,I have in particular conducted research on well water availability and safety throughout the area, including Black Point. Sea water intnrsion" well contamination, decreasing water supplies in the world and area in general, and the impacts of new drilled wells on existing water supplies is a huge issue in South County and in particular close to the shoreline. It is clear that insufficient data has been collected or prodnced as to potential negative impacts of pxtemely high water use as The proposal as put forth fails to mcet cormty goals for improving tourism revenue for South County, and in reality could adversely impact tourism rcvenue for South Corutty. This area is reachable only by a two-lane road from north and south. Last year, just one fatality accident on Mount Walker caused a huge quantity of taffrc, cars with families or people on our way to work, to be stuck on Mt Walka for seven hourc. This is only one accident to completely close access to the area. The only other option for access in an accident or larger disaster Whenatlsor to of the firefighting then was also by air, with helicopters scooping water from Hood Canal to dump on the almost inaccessible steep slopes where the fue was located. Safety problems out on the Canal are also difficult to address, as I know personally from having a front row seat to many. Getting law enforwnrcnt to Brinnon often involves hotrs of delay, which means that dangerous situations arEn't addressed in a timely way. Private security on the resort itself docsn't addrcss pcriphcral issues tbat will arise due t,o the changing demographic zuch a massive change to our community wiU entail. Our attnactions in South Courty are the forests, parks, canrping, hikiog, shell fishing, and relative serenity of a so-far fairly undisturbed shoreline and adjoining forests. This area is already clogged with tourists in the sunmem. honically, these same features also offer the U.S. Navy, a large area employer, the conditions required to conduot mynad tests out in Hood Canal. I urge that the no action option be selected in response to this project. If options one or two are allowed, the developer must be required to: l) 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 perfomrance bond issued by a highly rated inzurer to cover all potential costs that cannot be ascertaincd beforehand, including repairing any environmcntal damage incurred over a 50 year period becsuse of the dwelopment and the costs of cleanup and rcstoration if the project is startd but abandoned. 2 Thankyou for your consideration of my comments. Respectfully submitte4 Kirie Pederscn 3 HOOD CANAL ENVI MENTAL COUNCIL Ant tique Heritage P. O. BOX 87 BECK, WASHINGTON 98380 December 30,2Ot4 trG IHL=-t OV tr Davld Johnson, Associate Planner Jefferson County Department of @mmunity Development 521 Sheridan Street Port Townsend, Washington 98368 fiFrtns]:i c0ultII Re: Pleasant Harbor Master Planned R€sort Draft Supplemental Ewlronmental lmprt Stetemmt Attention: Mr. Johnson: The Hood Canal EnvironmentalCouncil(HCECI has been inrolved in the decisionmaking process regarding the proposed Pleasant Harbor Master Planned Resort (MPR) project slnce early 2005 - submitting written and oral testimony to the Jefferson County Department of Community Development (DCD) at every opportunlty. As the proces has draged on for the last elght years tfle have remained conslstent in our opposftion to the propsed MPR and our support for the local citizen organization, the Brinnon 6roup, whose members would be the most directly affected by the constructlon and operatlon of the proposed project. Our position has not changed. The followlng comments are based on a revlew of the Draft Supplement Environmental lmpact Staternent (DSEIS) for the proposed MPR. We respectfully request that they be entered into the public record. GENERALCOMMENTS I JAN - 5 2015 Page 1 Environmenul lmpacts to Hood Canal Watershed The still largely undeveloped rural character of the Hood Canal watershed is what sets it apart from the more densely developed and urbanlzed greater Puget Sound region. The publiCs perception of the unique and envlronmentally sensitive character of this rrvatershed is evident ln the State's designatlon of Shorellnes of Statewide Significance for all of the shorelines of l-lood C-anal and numerous projects and progoms aimed at protecting water quality and related natural resources. Unfortunately, over the 45 years since the creation of the HCEC, we harre seen a gradual "piecemeal" chlpplng away of the natural landscape from rapid growth and development ln rural areas. Consequentln there are fewer open spaces throughout the Hood Canal region. We now irin with local residents and vlsitors allke in placlng the highest prior'rty on protecting what is left of our natural undweloped areas. The proposed MPR must be enaluated whh the potentialcumulatlne lmpacts to the broader Hood Cana! watershed in mind. There can be no question that, under the prefierred ahemative clted ln the DSEIS, adding another mega resort that includes a golf course, 890 resldentlal unfts (lncluding 52 units for staff housing), 56,608 sq. ft. of commercial area, and resort related amenities spread orer 231 acres (not including the Pleasant Harbor Marina area), leaving very little natural, preserved area and allowlng 1 mllllon cubic yards of cut and fill for golf course grading poses significant unavoidable enylronmental impacts to the Pleasant Harbor/Black Point area. The HCEC fully supports the Brlnnon Group, other organlzations, and many local residenB ln relecting the project-level development alternatlves (1 and 2) and choosing the No- Actlon Ahernative 3. ir JAN - 5 20i5 DSEIS AlternatiYes The DSEIS descrlbes ln detall the so<alled envlronmertaland other beneffclal and 2. Howser, there lsvery llttle dlscusslon of lmpacts under altemattve 3 other than to nepeat oycr and orcr that 'the site will continue to deyelop as a single family residenUal arca based on the existing rural zonitg and as described in the 2007 Final EIS'. With very ftm exceptions, the docurrert fails b demonstrate benefits to the erMronmem of the ltleAction Alternative wlth an estimated !10 new resldents (pg. 1-11, Volume 1, DSEIS) when compared to the others. Our letter dated 1G1+07 to the Jefferson County DCD commentlng on the 2fi)7 Draft ElS for the CounVs Comprehensive Plan AmendmenVPleasant Harbor Golf Resort details the many benetrts of that document's NoAction Alternative. These include signiflcantly lower density, fewer lntensive uses, minimal bpographic alteratftcn, least demand on groundwaterand protecdon of the aquifer from saltwater lntruslon, least trafflc impacts, least potentlalfor contamlnatlon of marlne resourcc, least lmpewior,s surfaces, significantly lower demand for services, increased probabllity for malntaining the rural character of the Brinnon communlty, retention of rnore open spaces, least dlsturbance of wEthnds, ard better protectlon of wlld llfe habttat. 8e rcfr ts of Altpf na$ye..l Much ls made throughout the DSEIS sf so-called 'improvementsl to water and other resoures from upgrad6, e.B. sewer, stormwater plan, etc. lf the proposed MPR prolect ls constructed hW,3.2-7 Volume 1, DSElSl. Howe'ver, there ls no mentlon of the fact that most of these purported lmprorements could result ln the same or hlgher levels of resource protecflon when the mrlous regulatory and other tools currently available are utllized and enforced. Existin6 bufhr, setback and lot design regulations, oounty heahh departsnent sewaSe dlsposalapprwal process, the Sfirellfish Protecdon Dlstrlct response plan, upgraded requlrements br exlsdng roadvvay deffclencles, bulldlru permlt requlrements, shorellne permltting pr<rces, stormwater control dam, local state, and federal profect rwlw and habltat mltlgation requlrcments and wetlands protectlon regulatlons arc Jrst some of th€ numerous tmls llsted ln our 10-14-{17 htter that are stlll available. The not'nrn that rwter quality, water quantity, and other natural nesourse prutectlons can be imprwed by allowing the klnd of intensive developnrent resuldng from enothcr mega resort ln the Hood Canal watershed is ludlcrous. Addlng language descrlblng the benefig to the envlronment of Alternatlve 3 thror4trout the docunent would go a long way toward demonstratllq non-biased comparisons of the three alternatiyes. SPCCIHGOOUMEXIS The DSEIS presents a charerplcture of the preferred alternatlve and offers rcme imporcments from the ori$nal plan, e.g. movlng the Maritlrne Village auaay from the Pleasant Harbor shorellne and cottsolidatrg sorne housittg unlts to allow for more pervious surfaces. Howeyer, it still presents unacceptabh impacB to the Pleasant Harbor/Black Point area. a EnvltoJtJtrlElFf RGvleryy of Pleasam Harbor Area The northem portion (Pleasant Fhrborl of th€ propoced proiect is belng analuated under a BSP (Blnding Slte Plan), a sepaftrte proccss whictr does not require inrolvement bV the publk and makes it very difrlcuh to get a clear plcturc sf the lmpacB of the profect as a whole. We support the Brlnnon Grouy's posltlon that thls area should be subiect to a frrll erMronmertal ranlw underthe State's EIS process. Prolect Constructbn Phases Ihe proposed prorect ls planned to be construcEd ln three phasesoyer a 10 year perlod. J ,_,,f r..;-,', irL,ir[Y Page 2 i JA.N - ; ?'^lri lr I i 'i : llouraaer, there ls rr gnr.ntee $at thb plan will be folbtrred. Acordlr6 to ttre DSE1S (pg:2.+, 5, Volume tl the sctredule may charye dependlng on marlat condftlons. There are othef - ' circumstances that could resuh ln dehylrU constructlon, e.g. the develope/s ffnandal situation, contract andlq labor problems or any number of urnxpected lssues. Unfiortunately, the construdlon phase poses the biggest thrcat to natural rEsources, lndudlng groundrvater, whklr wlll undergo the greateet demand at that tlme (Subourface Group Memo dated 2-22-101. Th€ lsue of nolse pollutlon may apply here, slne actlvttles llke rock crushlng, arc er(Uemely loud. lmoact Gost Deooslt and Performance Bond Reoulrement lf the prcftned'm bulld' altematlve ls not selected, anyapproralof such a potentiatly hannful prolect ln thls fta$h envlronment should be condltloned upon a aomphte analysis of the asoertalnable and potentlaleconomlc lmpact of the proposed MPR durlng and after onstructlon. Befure constructlon be$ns, the developer should be requlred to (1) deposlt th€ amourt of all ascertalnable dlrect and lndlreqt costs regprdlng servlces and lnfrasbucture Into a fund available to local goremmem to oover the costs as they are lncured, and (2) fumlsh a performane bond issued by a hlghly rated insurer to corer all potentlal osts that €nmt be asertaln€d befiorehan4 irrcluding repairitg any eruironmental damage imuned oyer a 50 year period becauc of the dadopment and the @sts of deanup and restoration if the project is started but abandoned. ln this way, the rcsponsiHe Bouemment is attempting to assurr no net economlc loss to the communlty, althor.gh the HCEC asserts that thc 'no build' atternative ig superlor because thls proposed MPR lacks assurarte of no net envlronmental loss. . \,, o Page 3 r threzts to gr.oqn{fyetef.a.nd-AeUt&J There ls only one aqulfer whlch would serve the entire project area, lncludlng local residerts. The dadoper plans to use an elaborate system of rJterunanagemefi in an effurt to protect the water supply. Aeordlng to State Department of Ecology (DOE) documents, aquifer recharge primarif comef from direct inffhration of precipitation (pg. 3. 2-2, Volume 1]. However, there ls no phn fur preruntlnt drawdowns in the eu€nt of prolorged dry perMs whhh, lf scbntnc predlcdons of extreme weather events due to climate charge (changes ln the dmlng and lntemlty of ralnfallf proue accurate, groundwater and the aqulfer could be at risk. The dwelope/s plan to inpct treated wasEnvater lnto wells poses the possibility of the introdwtion of pharmaceutkab and other pollutants into the aquifer. The greatest danger to the Black Polnt aqutfer ls the threat of saltwater lntrusbn. DrE to lts sensitMty to saltwater intruslon, thls area ls deslgnated as a Oitlcal Aqulfer Recharge Area and also an SIHZ (Seawater lntrusion Protectlon Zone). Residents living in this area need to be awarc that according to the Pleasant Harbor t{elghborhood Water Supply Prognm Application datad 2-2+lO tW.2, Appendix Fl if their wells shor saltrater contamination, the burden of proof as to whether the resort's water demands are responslbh for the intruslon lles squarely on their sltoulders. The Applhadon reads, ln paG 'The trell own€r provides concluslve arldence that over a statlsdcally relwam perlod of tlme, chlorlde hvels have lncreased over chlorlde leveb in the well prlor to Pleasant tlarbo/s use of grourdvyater, Includlng but not limlted to, evidene that the lncrease ln chftcrlde Ieveb ls from the Phasant Harbor groundwater use and not frrom the onstrrrtion of the yvell owne/s wel! . . .' (emphasls added). The dweloper also can' "reguest additional widence from the resident showing that the resort groundwater whMrawal ls the cause of the lncrease ln drlorldes. . . ". Placlng the burden of proof on wel! ownerc a a saddles them with a long and expensive process. We believe that the 1!j;i,,,'ilY responsible for supplyint water to the resldent in the event of saltwater responsible for the @sts lnt ohred ln the determlnatlon of culpability. A DOE Hydrologk (Revlsed) Mem from John Pearch dated 1-1tl-10 shows that there ls reason to believe that wells in the Black Polnt area are alrcady experlendng saltrvater lntrusion. Two welb have alrea{y been fiound to have sattwater lntruslon. Under the headlng of Domestic Wells. the statement ls made that '. . . nearby &mestlc wells are at rlsk of seawater intrusion due to their proxlmlty to the @ast ...' Also, 'Additional pumplng of the ACG well and addltlona! proposcd wells by Pleasant Harbor could cause this saltwaEr interface to more further lnlan4 thereby increasir6 the risk of seawater intn sion ln these wells.' Further, these wells werc ln the area where, according to t{rc ,nemo, saltwater lntrusion would likely be fould. Seven wells were not tested as requlred by Jefhrson Gounty building permittlng. lf any wells have been decommlssloned due to saltwater Intrusioo that information must be onUined in the DSEIS. The DSEIS needs to clearly estaHish the develope/s responslbill{ for prwlng that there is enorgh water supply for both the resort and nelghboring resHents. This includes using updated well data and a monthly monltorlng program etthc deuclopc/r crpGn*. Fleld sampling is prefurable to relylrg on computer models. The ileigfiborhood Water Pollcy should be rwlsed to asslgn the burden of proof to tlu dweloper. Wetland Mitlcation There are three "Kettles' and associated wetlands on Black Polnt-A, B and C. The daneloper plans to conyert Kettle B, which has a high rating of category lll due to lts habitat yalue and moderate to hlgh value for water quallty fumtions (pS. 3. 7-2, Volume 1) to a control pond for holdlng treated wastewater from the rastmatertreatment system to ptouid€ reqycled water for reuse and for golf course inigatbn and fire protection. To ofEet the @nrerslon, the DSEIS states that Kettle C may be 'enhanaed'. Sinoe the wetland mltitdon plan has not been done, it ls imposslble to krcw lrow the loss of the Ketde B wedand wlll be @mpensated. We feel stnongly that ln order to meet the state's no-net-loss of vvedands pollcy, Kettle B and associated wetlands should be kept in their natural state. The DSEIS should also state that the proposed MPR proiect should not be allowed to encroach on wetland buffers. Golf Course We failed to find a listing of dtemicals (hertlicides, pesticides, or fertilizersl fiat will be used br golf course ttras maintenanoe or any discussion of irow the devtloper plam to protect groundrrater or stormrater runofrfrom the use of these chemkals. The BMPs (Best lUanagement PlanslforgoJf ourse rnalntenanc n€€ds tobeerylained in detall. Also, the recommendatlons relatlng to golf cources contained in the WRIA 16 Waterched Managernent Plan should be mted and a plan for how the developer will adhere to the recommendatlons discused in the WRA Plan. Under the preftrred alternatlve (2) the statemert ls made that 88 percent of the site rrvould be retained in open space ln 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 spaaes as they do not have natural landscape, habtbt or other environmental values. Page 4 - I ?l:'r ril-A,r=flnrrF i-E ((.;, ti-.*, l.i "Y,' ilf, JtN - : ir15 orHER rsslrE oF cotrcEnr{ Whlle the HCECs primary area of interest is potential environmental impacts, concem to the HCEC relatlng to the propoaed MPR proJect. a Ecommk lmoacts on local Corrununltv The developer has a responslblltty to reveal the tru€ lmpecs on the local eoonomy from thc proposed MPR durlng constructlon and operaUon. Of the stlmated 22!i permanent operatlonallobs that ould be create4 (pg. 1-11 and 1-12, Volume 11, th€ majority would be low paylngJobs. Accorditgthe DSEIS,these jobswould paym percentorless of the AMI laverage median lnome) for the Brinnon area. Constrwtlon lobs nould fluctuate durlng varlous phases of consUucdon. Many lobs would be seasona! and part time, lncludlng fuod seMce, malntenance securlty, etc. !t is difficult b say who wlll beneftt economically otherthan the Brinnon buslness ommunity, the Canadlan based derreloper, and possibly realestate dandoperc. A study of flscal and economlc lmpacB of destlnatlon resorts ln Oregon concluded that after subrtracdngthe costs for seMces frorn the gross Eoperty and room tax reaenue generated by the study resort, only a modest rct surdus remained. When the oet of capiul facilities includlrg roads, schools, ftre and pofie stations, and others is also acoounted br, the net cost to local taxpayers is substantial even after acountlng for all known payrnems the resort would be requlred to make (Flscal and Economlc lmpacts of Destinatlon Resorts in Oregon by Central -Mardr,2m9l. Jefferson Counil Resoures The HCEC rcmalm concemed about whether Jefferson County has sufficlent stafi and other resourses that rrould be regulred to handle the addldonal workload of monilorlng the proposed project for complhrrc and/or dealing wi$ unergected probhms. Addltlonal Costs to Mason Countv P.U.D. 1 It ls not clear whether the Mason County P.U.D. # I has the capacity at the present time br providiry poruer durlrq constructlon and operation of the proposd projest (pg. 3. &2, Volume 11. According to the DSEIS, the P.U.D. has only agreed to supply poryer durlng the flrct phase, The guestbn of who would pay for a new substation, dlstrlbution feeders and en$neerlng studles and deslgns needsto be answered well befiore approml of the proposed MPR profrt ls considered. h would be helpful to know how much of a future P.U.D. rate increase can be attributedtothe increased energy dcmand from the proposed MPR. a a The irnpacts b Higlpay 101 from the increase ln vehi,cles trarcling to and from the airpon would be substantial. The develope/s plan to rely on two shuttle buses does not take into aount that most visitors will trave! by carto and from the r€sort alory hlghway 101. lncreased trafnc @ntestlon in towns llle Hoodsport ls already a prcblem ln the summer months. The HCEC ls also conemed aboutvehkle-related non-point pollutloO stormwater runoff enterlng Hood Canal and more greenhouse Eas emissions rerul irg from incnrascd traffic. The data used to assess traffic volumes ln the DSEIS appearc to be outdated. ln addition, during the constrrrction phase, the lncrease ln trucks ard odrer heavy equipment on Hlghway 101would llkely lead to costly damages. Further, the questlon of who wlll pay for the addltlonal hlghway repalrs and the extenslon of Jeffierson County's translt service needs b be addressed. Traffic lmoacts to Hlehwav 101 Page 5 E) iri'i ,' ..r ...5: L:i...',iI Naval Base Securitv There is no mention of the proposed MPR's proxlmltyto$€ U.S. NamlStatbn BangorSubase and whether this might be considered by the Narry to preent a national securlty lssue. Miscellanous Pages 1-6 and 3.tt-1 in Volume 1 refer to 'Rainief elk populations. The proper name is Roosevelt elk. The I|CEC appreciates the opportunlty to erpress our ooncerns and prwlde oomments on the DliElS for the proposed Phasant Harbor Master Planned Resort We look furward to continuing our involvcmem and receMng further lnformatlon as partof Je{ftrrcn Count/s publlc revlry process. Res pectfully submttted, A*g** E rlrBfl '.\.-.j,' li;. ii 1/rE Donna M. Slmmons, Prcsldent Hood Gnal Eruironmental Council a a JAN - 5 ?1I5 il il ti Page 6 The traffic conserns were seriously, not adequately addressed ln the DSEIS. The statlstlcs are out of date. They only looked at intersections and not wtrere the aoddents usually occur whlch are corners and Mt. Walker. l{wy 101 is blocked for sweral houm or more depending upon sererity of accldents. It can be totally closed. lt is a two lane windy, twisty, narow road wlth few turnouts or passing lanes if travellng so.rth. Travellng north ls Mt Walker wlth severa! twlsty turns and then going south to Brinnon ls a bad stretch for accldents. Havlng the road blocked for serrcral hours has a sevefie Impact on local people who travel for groceries, medkal reasons and for vrort. Puttlng trafflc llghts wlll not address these areas. Who wlll pay for the road malntenance and trafflc congestion reliefll I suspect that the local taxpayer wlll bear the burden for unfioreseen changes caused by the resort. fu for busses from the airpor!, realthy people do not wait for a bus. I don't think the,,y travel by bus. The traffic study ls sdll uslng old data for it staUsUcs of how many people wlll lncrease trarrcl on the highway. My other conoern is the inrease of traffic on tlre Duckabush Road w?rere there are s*eral hlklng tsalls. It ls norv the only access polnt to the Otymplc Mountalns slnce tfie Dosmallips rcad slide. The county has never fixed the problem correctly and it appears to be a costy proJect to do so. We have experlenced hearrytrafflc on weekends and nke weaths months. lt is an even nerrower road in spots To the Jeffercon County Plannlng Conrmisslon Jan.2,2015 My husband and I have llved in Brlnnon for almost tO years. We have seen rnarry comlng and goings ln thls area wlth resorts and fmr harrc thrlyed; conslder Port Ludlow, Dlscovery Bay, Lake Otshman, and Alderbroolc They have all gone throgh ourners and changes ln plans to try to succeed. We have concerns about the proposed reson and tts enormous slze of almost 900 unlts. Our concerns are arornd tfie trafflc lt wlll produce on Hwy 101 and sunoundlng roads, the actualJobs and pay, water, chemlcals belng used and habttat. Erlnnon ls a very rural communtty. The 9(X) unlts and the people llvlng even h part tlme wlll have a huge lmpact and change the character to belng more Poft Ludlow than Brlnnon. Even when Garth Mann starts out wtft 250 unlts the intent and posslblllty ls the almost 900 wen ff he sells the resorB the potential is almoet 9fi). That ls a lot of people and employees durlng peak use. !s there a contlngency fund for if the resort does not bring in money and fails-what happens to the land and yacant bulldlngs left to decay as with past ownens? Can the size of ereansion be reduced if the propefiy is sold dourn the llne? The other concern is who is golng to come to Brlnnon more than once? You visit it on the sunny day and trlnk lt ls lovely (wtrhh lt ls but lt has more rainy days) but I do not rcally see than coming back during the ralny weather whlch is more often than what Port Ludlow or Port Tornsend experlence. Raln ls not conduclve to golf. Brlnnon ls sarcral hours array from the alrport and ls only accessible by Hlghway 101 unless they go by boat There are resorts that are much closer wlth nlcd amenttles; espectally, when you consider the time it takes to get to Brlnnon. People might come for shrimp and crab and that will r*-- i ut't L K ;.-i:l i-(J+rs ;lrtii{iJ tt- I !=:, As for lobs, the study ls very clear that the applicant must be qualiffed. I am sure that there are local people lntelested ln rcrking but may not be qualifted so rnany loca! peoplewill not be hired. Training dld not seem b be offered. Most of the iobs listed wll! be below famlly wage jobs so that there will still be a hlgh rate of poyErty. I also think most of the jobs are seasonal, minlmum wage, and parttime. lt could leave more people added to tfie community in poverty, on Medlcald, and strainlng the llmlted local resourccs. Most constructlon jobs wlllgo wlth the large company that ls hlred to bulld the resort Thery mlght not hlre locally. Who ls golng to flx and repalr the hlShway after al! the trucks-remember lt ls a mllllon cublc yards of dlrt belng morcd; have traveled lt muhlple tlmes? Who pays for that? Water is a huge concem as it is one of our most predous resouroes that dwelopers hrye ltttle concern. We hane seen enough f,oods and dry months to know how flckle weather ls ln our almost 40 yean llvlng here. With the almost 900 units, thlnk of how many tollets wlll flush, showprs, laundry and the golf coure usagehow many gallons of waer wlll it take before the aqulfer ls depleted and salt water lntruslon ocrurs? The salt water lntruskcn burden ls upon the well owner and costs wlll probably be on the well owner to use the resort water. Wlll lt also give the resort acc6s to their prcperty if the water lines are theirc? I can't imagine wealthy people wantilu to ration their water usage but the property owners wil! due to havlng to pay for water and limiEd water due to depletion. Water quality for the Hood Canal is also lmportant lt was said that there were going to be holding areas for affluent but what happens when that overfloun during a heavy raln? What happens to the contaminated water? Golf courses and surroundlng grounds are able to use nastier chemicals than non buslness people can get. Cralg Peek stated that they would be natrral but that ls extremely VAGUE. The potenUal to have these run off lnto the Hood Canal are posslble. And the Hood Canal also offers many famlly wage jobs ln seafood lndustries. lt ls a llvellhood for marry and rccreadon for others. Who will overcee thls? The MPR has a lot of amenltles but llmited use or none at allfor locals. Tralls are accesslble but where can a local penron part? TheV would want you to use thelr store and rctaurant but the prlces are llkely not affordable to locals and that is what they need to succeed durlng the tret weather months. I thlnk there is fie potendal $at local businesses might lose business to the resort. The heahh cllnic is behind the locked gate so it is not accessible. Where will the trucks nrtth trallers park on shrimp days since the parking is now a resort? They will probably park along Highway 101 and cause serious congestion. The only saving grace is ftat the r€sort is starting small wtth 250 uniB but the potential to gron, to the full capadty is always there unless you can change thaL Perhaps maybe the almost 9fi1 units ends wlth thls MPR and lsn't part of a fu$re sale. lt ls iust out of character for such a rural area. Odrer lssues should stlll be addressed before thls goes foruard. Also there ls ln the plan to have a noad to the marlna through the Harbor House wfilch has a trall use only due to thelr septlc system belng there. What wlll happen there? With stlll many concerns. Slncerely; William and Roxianne Morris po B ox tttqr B..,Lra.6r^- w h 1q3r* I trc rEllViF:r JAN - 5 Zit::l. t I ,: i ; : :ir.isilr i ;ir;u;.,i iy - - j[]I .qi!L:!r! ijir.'L[i[ !: j!,r rrui Davld W. Johnson From: Sent: To: Laurie Mattson <lmattsonT2@yahoo.com> Wednesday, December 03, 2014 10:20 AM David W. Johnson Opposition Comments: Pleasanl Harbor Marina and Resort - Draft Environmental StatementSubiect: Thank you for the opportunity to comment on the draft environmental statement for the proposed development, Pleasant Harbor Marina and Resort. I have owned a home and resided in Brinnon for over 24 years. I moved here for the peace ofthe surrounding wilderness and Hood Canal area and am opposed to the expansion of Pleasant Harbor Marlna and Resort. I am very worried about further contamination of Hood Canal, which is already netatively impacted by pollution caused from insufficient septic and sewer systems, and run-off from pesticides and herbicides. Low oxygen levels in Hood Canal are already a serious impact to this valuable body of water. lf the proposed development comes to pass, it would have a disastrous effect on water quality and marine life. Further, it would take water from the acquifer at an amount that may exceed capacity and will do so in the long terrn, We must think of the long term negative effects of this development, and not allow greed to harm this pristine area -- an area that is already being adversely effected by current operations. Would I let my family fish or swim in Pleasant Harbor at this time? Definitely not. And the situation will get much worse if the development goes forward. The road system in this area is quite heavily traveled, especially during the summer months during heavy tourist season. Additional vehicles traveling to and from this proposed resort would put a strain on Hlghway 101 that is already inadequate and often dangerous with curves and long stretches where passing slower vehicles is not a safe option. Too rnany accidents and lives have been lost already. lt would be a serious mistake to add to this existing problem without a plan for an enhanced and safer highway. There are those who believe that a development at Pleasant Harbor would provide jobs for people who live ln the area. I belleve that jobs for local residents from the proposed development would most likely be those with minimum wages, not enough to provide for a family. Unless there is a mentorship program where local people are hired and trained to move up a specific career track, a minimum wage job is unlikely to raise the standard of living for people who live in this area. Again, thank you for allowing my concerns to be documented on your list of people opposed to development of Pleasant Harbor Marina and Resort. Laurie Mattson 1811 Dosewallips Road Brinnon, WA 98320 360796-44t6 lmattsonT2@yahoo.com Sent from my lPad 1 :-\ l I t : ; D[c 0 3 Ii;+ i)nh:i:i 35/ hn$ol W* H"Vn ,l J- ,^LA d;,tr t"/t9rq4r' .Jal- 4-, /ar.r' 1l w t/otr, ! I I Ca 2 EG tr0 "q1* o/ Coawr^fq DEC 3 0 ZOrq 6Lt s/\U&de,w W,vl,lu;frh Plur,,, dtudopvr,wul fuBia* Po*T 7la*M co/r s'rc\u,:il, /c lloo, ol corvLara,ff. lt ,, I p*niod 7^_ . '3-. .tsacd..!.(.t2. od Tl, ,llwf futtuto'd-twafic U"Z'k #o"a C*.nuL arw crtrt yipf qttu,vw-{f,a*o aantfu)t f ,g,r*- e{eqe+ wulrx @@4! f,rrr"+ i7+ . al,fual uLA, ii a* q// qeua &.Q- v A LooT r,ralfri et'Q n ntc/ oiy/re"4{e b a 'Lottt ,r+pc*rfr .$w,t, Btroadn il'\, ilillou, 'Lq'Lq slv.r'',c/-tut Aur- ?*t 16u.,wttutt. David W. Johneon From: Sent: To: Cc: Subiect: Attachments: nana@hctc.com Friday, January 02, 2015 1 1:57 AM David W. Johnson PhiUKaren; gampc@wavecable.com; awharris@wavecable.com; bob@wiltermood.com; don @ mahalo2u22,com; mzharle@hotmail,com; Barbara; John HCEC Response to Pleasant Harbor DSEIS 12-29-14 HCEC Comments Brinnon MPR DSE|S.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, 2014. 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 13601877-s747 nana@hctc.com 1 lrtlilCiili'\rrj[T)j JAll 0 ?,fr| fiTHI:i:r"{':' -,t \..-i ] December 30,2074 David Johnson, Associate Planner Jefferson County Department of Community Development 521 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 regardlng 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. GENERAT COMMENTS E nvi ro nr.ne r!!!r I I m pa c_ts. tg H ood Ca na I Wate rs hed The still largely undeveloped rural character of the Hood Canal watershed is what sets it apart from the rnore densely developed and urbanized greater Pr2get Sound region, The public's perception of the unique and environmentally sensitlve character of this watershed is evident ln 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 away of 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 ls left of our natural undeveloped areas. The proposed MPR must be evaluated with the potential cumulative lmpacts 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 231 acres (not including the Pleasant Harbor Marina area), leaving very little natural, preserved area and allowing L 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- Actlon 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 lmpacts under alternative 3 other than to repeat over and over that "the site will continue to develop as a single farnily residential area based on the existing rural zoning and as described in the 2007 Final ElS". With very few exceptlons, 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.t. sewer, stormwater plan, etc. if the proposed MPR project is constructed (pg. 3.2-7 Volume 1, DSEIS). However, there is no mention of the fact that most of these purported improvements could result ln the same or hlgher 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 disposal approval 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 10-14-07 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 lntensive 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. Environmental Re.view of Pleasant Harbor Area The northern portion (Pleasant Harbor) of the proposed project is being evaluated under a BSP (Binding Site Plan), a separate process which does not require involvement by the public and makes it very difflcult 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. a a Proiect Construction PllAses The proposed project is planned to be constructed in three phases over a 10 year period. Page 2 a 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 lssues. 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. lmpact Cost Deoosit and Performance Bond Requilef.ngIt 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 repairlng 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. a Th reats to G roVndwater and_AquJIer 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 ls 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 pharmaceutlcals and other pollutants into the aquifer. The greatest danger to the Black Point aqulfer ls the threat of saltwater lntrusion. 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-lO (pg. 2, Appendix F) if their wells show saltwater contamination, the burden of proof as to whether the resoft's water demands are responsible for the intrusion lies squarely on their shoulders. The Application reads, in part, "The wellowner provides conclusive evidence that, over a statistically relevant period of time, chloride levels have lncreased over chloride levels in the well prior to 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 frorn the construction of the well owne/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 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 lohn Pearch dated 1-14-10 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 Wg!5 the statement is made that ". . . nearby domestic wells are at risk of seawater intrusion due to their proximity to the coast ,.." Also, "Addltional pumping of the ACG well and additional 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 develope/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 develope/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. a a 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 imposslble 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 (herbicideq pestlcides, 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 relatint to golf courses contained in the WRIA 16 Watershed Management Plan should be noted and a plan for how the developer will adhere 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, natural areas and buffers (pg. 3, 2-12, Volume f ). We would artue that golf courses do not count as open spaces as they do not have natural landscape, habitat or other environmental values. Page 4 OTHER ISSUES OF CONCERN Whlle the HCECs primary area of interest is potential environmental impacts, there are other issues of concern to the HCEC relatlng to the proposed MPR project. Economic lmoacts 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 l.-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 wilt benefit economically other than the Brinnon business community, the Canadian based developer, and possibly real estate developers. A study of fiscal and 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 requlred to make (Flscal and Economic lmpacts of Destination Resorts in Oregon by Central Oregon LandWatch - March, 2009). Traffic lmpacts to Hiehwav 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 101would 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. a a o Jefferso{r Cou ntv Resgurce.g 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,$-oqts-Io Mason Countv P.U.D. 1 It is not clear whetherthe 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 approval of the proposed MPR project is considered. lt would be helpful to know how much of a future P.U.D, rate lncrease can be attributed to the increased energy demand from the proposed MPR. Page 5 a Naval Base Securitv There is no mention of the proposed MPR's proximity to the U.S. Naval Station Bangor Subase and whether this might be considered by the Navy to present a national securlty issue. Miscpllanous Pages 1-6 and 3,4-1. in Volume 1 refer to "Rainie/' 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. Respectfully subm itted, Donna M. Simmons, President Hood Canal Environmental Council a a Page 6 David W. Johnson Sent: To: Cc: From: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 CONFIRI RECEIPT OF THIS El,lAlL. Friends of Mltter Peninsula State Park PO Box 2664 Sequim WA 98382 January 5, 2015 Pteasant Harbor DSEIS/c/o Jefferson County DCD 621 Sheridan Street Port Townsend WA 9E368 dwi.oh nsoq@co. lefferson. wa. us Betow are comments regarding the Pleasant Harbor DSEIS prepared by Frlends of Mltter Penlnsula State Park, a 20 year, federalty recognized non proflt on the North Otympic Peninsuta. We know that these are like and similar to other comments belng sent, but want to underscore that these are isues 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 v/ere given to the developer. POPULATION The poputation of Brinnon is about 818 and maybe hatf this number of homes, Expanding the number of tiving guarters by 890 residential units (Optlons 1 & 2) wilt have an enormous impact in the area in many respects, inctuding potabte water, storm water, sewage sotids and effluents, release of CO2 into the atmosphere and loss of CO2 soiI and tree sequestration. ECONOMTCS Few of the built units are intended for year round occupancy. ((The majority of this housing (67%) woutd be for short- terrn visltors and33frwouldbeforpermanentresidents.)) 67%orabout54Sunitsarehopedtobefitted,butmosttiketythetargestpercentage of PT occupancy witt be in the warmer time of the year. The impacts to the area calt for showing an economlc analysis that this resort is financiatly viabte. We request this be done. Has the resort company factored in the new WA State minimum wage for emptoyees? Where witl constru€tion workers (E0. 5% out of the area) be housed? Feasibitity of housing them ctose to the site? Witt atl construction works be from WA State? How witt their traveling during hlgh tourist season affect normal traffic? opttons 1&Z details are descrlbed but the No Action, which is to buitd a few hundred honnsltes, ls not detailed. lt seems, then, that this No Action ls not being seriously considered. Yet, it is an Optlon and it should have comparative detaits so the costs can be seen. You ask for the public to weigh in and the publlc should have this information to consider. Thls is an omission and shoutd be corrected. Subject: 1 The information shoutd 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 witt be put to the area and state citizens? For instance, road repair from additional traffic the resort witl bring, Utitity costs. Medicat facitities. Taxation. This estimation shoutd be made pubtic up front. GLOBAL WARMING Stripping this large area of trees and its natural grasses, solts and wettands wlt[ release immense annunt of greenhouse gases into the ambient air. Earth removat wllt have a large affect on the mkroblat soll communlty. A study needs to be done on how this GHG release and resutting changes affect both the harbor life and the surrounding Brinnon community. Appendlx M doesn't quantlfy the GHG releases and effects of the reteases, and the mitigations are hardty thatl For seguestration to work, even for the reptanted trees, the annunt witt not balance out. lt takes years to regain that sequestration, whether reptanted trees or new grass. EFFLUENT Ctass A effluent dlscharge from the proposed sewerage treatment plant is ptanned to be stored and recycled, Do not use this to recharge the aquifers. Do not use this for fire protection and irrigation. lt witt make firefighten ill. There are many studies that determine recycting of wastewater treatment ptant (WWTP) efftuents are unsafe, There are thousands of chemicals and many pathogens that cannot be tested for, nor thelr cumulatlve impacts. lt is known that: . mlcrobeads from personal products pass throqh WWTPs into efftuent . MRSA and other pathogens rernain in the sludge and the effluent . antlblotlc bacteria can be created in the WWTPs . trictosan minimlzes WWTP treatment ' effluent contains flre retardants ' effluent and wett as the sollds contaln thousands of chemicats lncluding chemlcats of emerging concern and POPs More reason to not recycte the efftuent: httq: / /vyww.eoa.sov/oie/ reoorts/201 4i 20140929' 14;P-0363.o.df More Actlon ls Needed to Protect Water Resourcer From Unmonltored Hazardous Chemlcals EPA does not have mechanlsms to address dlxhorge of hazardous chemicols into water resources. httJEll/werur'lco.n$ne.com/news/healt'h/common-diabetes-me4ication-amonedruse-found-in-lake-michiean- bqqarzr rgzr-z8721 86sr. hEnl Common diabetes medication amont druge found ln Lake Mlchlgan There is more than one way to measure prescrlptlon drug use in modern society. The most direct rnethod is just to count up prescriptions fitted by America's pharmacles. That woutd show, for lnstance, that more than 1E0 mittion prescriptions for diabetes drugs were dispensed in 2013. Or you coutd test the treated water com'lng out of sewage facitltles such as the South Shore ptant ln Oak Creek. That approach reveals that in the Lake Michigan waters outside the ptant, the diabetes drug metformln was the rnost comrnon personal care product found by researchers wlth the School of Freshwatel Sclelces.at the Univers'ity of Wisconsin-Milwaukee. More importantty, according to their latest research, the levels of metformln were so high that the drug coutd be disruptlng the endocrine systems of fish. Last month, a Journal Sentinet/MedPaqe Todav lnvestiqatlon found boomlng sates of dlabetes drugs, which ln 2013 had grown to more than S23 blttion. Metformin is a flrst-line treatrnent for type 2 diabetes and is the npst cornmonty prescribed medicine for the condition. ln 2013, about 70 mittion prescriptions were dispensed, according to IMS Heatth, a drug rnarket research firm. It is so ubiquitous lt can easily be found in water samptes taken two mites off the shore of Lake Michigan, "l was kind of a surpdse," sald Rebecca Klaper, a professor of freshwater science at UWM, "lt was not even on our radar screen. I said, 'What is this drug?'" z The drugs get lnto the sewage and eventually the lake becaus€ they .re not broken down completely after they are consumed and then excreted. The metformin concentratlons are [ow, cornpared v{ith the amount taken by people. For instance, coming right out of the treatrnent plant the tevets are about 40 parts per bitlion. About two mites away, they drop to 120 parts per trlltion. Othercommonly found substances includecaffelne, sutfamethoxazote, an antibiotic, and triclosan, an antibacterial and antifungal found in soap and other consumer products. Ktaper co-authored a 201 3 science journal paper on the finding as we([ as another one thls year. The more recent research suggests that metformin in lake water is not Just a curlous artifact of everyday tife. The study tooked at the effect of metformin on fathead minnows in the tab that were exposed to the drug at levels found in the lake for four weeks. It found gene expresslon suggesting dlsruptlon of the endocrlne system of male fish, but not femates. ln essence, the males were produclng biochemlcats that are assoclated wlth femate mlnnows. The biochemlcats are precursors to the productlon of eggs. Ktaper said that because the minnows are a stand-ln for other flsh, the changes atso could be affecting other species such as perch, walteye and northern plke. The UWM research confirms what others have found regarding prescription drugs showlng up ln Amerlca'r takes, rlvers and streams, said Metissa Lenczewski, an associate professor of geotogy and environmental geosciences at Northem ltllnois Un'lversity. For year:, it was assumed that the volume of water ln the Great Lakes was so enormous that any drugs that got through treatment facilities would be dltuted to the point that they woutd not pose a probtem, said Lenczewski, who was not a part of the UWM study. That theory itsetf now ls being dltuted. Even more concerning are the much hlgher tevels of antlblotlcs that are being put lnto rivers and streams near pig farms where the drugs are used to produce larger animals, she said. In addltion, stralns of antlbtotlc-reslstant bacteria atso have been found ln water near those farms, she said. "lt is very atarming how much we are putting drugs out there in the environrnent," she said. ln that this resort plans to estabtish a medjcat ctinic for resort members (& workers?) there witl be medicat v{astes in the WWTP, tet atone frorn what goes down the dralns from the residentlal unlts, TRAFFIC One of the nrost worrisome issues with this project is traffic. Hwy 101 is a thoroughfare used by those traveling between Ctaltam County and npre southern points to Otympia. Additionatty, the traffic is greatty increased during the summer season. Roads are narrow. Much of the route is on btuffs whlch falt, as some Just have thls December 2014 creating one way traffic for weeks. Landslldes are common on thls route durlng the ralny season. Trafflc accidents happen. One can lmaglne that thls resort traffic needs witt be expensed to the State, hence the cltizens. Thls resort area is an lnhospitabte site for a [arge resort. WATER Very worrlsome ls the avaltablllty of water over a long term and the affects on communlty water needs. lf thls becomes prcblematlc, what responsibitities wiLl the resort owner be hetd to? Once it is used, it won't be regained. Water is going to be the "gold" as weather warms and snow levets are minimized and rainwater runoff increases. SUIilXIARY Thls comment covers onty some of the problems wlth the ptanned resort and the DSEIS, Clearly, lt ls not approprlate to approve this project. Dartene Schanfatd, Ph.D. President 3 R [--]ri. ''1 - i) JAN 0 5 2014 5 January 201 5 Jtrttft3ll fifiililY il[[ Jefferson County Department of Comrnunity Development Attn: David Wayne Johnson RE: Pleasant Harbor Master Planned Resort DSEIS 621 Sheridan Street Port Townsend WA 98368 dwj qhnson 6, co j efferson. wa. us On behalf of Sierra Club North Olympic Group and our hundreds of members, activists, and supporters, we are writing to submit comments on the Pleasant Harbor Master Planned Resort DSEIS. Please include these comments in the administrative record. Sierra Club feels there are serious omissions in this Draft Environmental Impact Statement that must be corrected. Our comments on different aspects are listed below. GLOBAL WARMING: An assessment needs to be done and presented on how this project will affect global warming and the microbial soils community due to extensive plant and soil removal. Appendix M doesn't quantify the GHG releases and effects of the releases, and the mitigations are clearly inadequate. It takes years to regain sequestration of carbon,and the DEIS also fails to factor in how this would affect marine life. EFFLUENT: Class A eflluent discharge from the proposed sewerage treatment plant is planned to be stored and recycled. This is a dangerous practice that should not be used due to inevitable pathogen transfer to aquifers. There are thousands of chemicals and many pathogens, (microbeads, MRSA, antibiotics, fire retardants and chemicals of emerging concern) that cannot be tested, nor are clearly known for their cumulative irnpacts, and that will be introduced in a recycling system. TRAFFIC: One of the most worrisome issues with this project is traffic. Hwy 101 is a thoroughfare used by those traveling between Clallam County and more southern points to Olympia, Additionally, the traffic is greatly increased during the summer season. Roads are naffow. Much of the route is on bluffs 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. Trafiic accidents happen. This resort area is an itable site for a large resort. SUMMARY This comment can only cover some of the problems with the planned resort and the DSEIS. Clearly, it is not appropriate to approve this project. Respectively submitted, Monica Fletcher Chair North Olympic Group, Sierra Club monicaflet@gmail.com WAIER: Another very worrisome issue is the availability of water over the long term and the effects on community water resources. Water will become a key resource as weather warns and snow levels are minimized and rainwater runoffincreases. The DSEIS does not address this truth. David W. Johnson From: Sent: To: Cc: Subiect: Attachments: J Hal Beattie <jhalbt@gmail.com> Monday, January 05, 2015 2'.44PM David W. Johnson Bekah Ross Brinnon MPR DSEIS comment Comment DSEIS Brinnon MPR 05Jan15.docx Mr Johnson Affached and Included in the text of this email are our comments regarding the proposed resort on Black Point. Sincerely J Hal Beattie Rebekah R Ross Comment on the Statesman Master Planned Resort located in Brinnon, Washington From J Hal Beattie and Rebekah R Ross, Brinnon, WA 5 January 2015 Our property shares a boundary with the proposed resort. As such we have several concems with its development. Our main concems are as follows l. Well water quality 2. Traffic 3. Noise 4. Rural character The proposed resort puts our water supply at risk. What happens if our water supply dries up or is contaminated or tums salty? Our water presently is not salty as confirmed by Department of Ecology testing in 2009. However our well draws water from appx 50' below sea level, making it vulnerable to salt water intrusion if the head produced by the overlying freshwater aquifer is sufficiently reduced by resort use for the freshwater/saltwater interface to rise. Traffic. Assuming only one trip out per unit per day would add nearly 1800 vehicle trips per day in and out of the resort and the entrance onto 101 from Black Point Road. That will be a significant rise over present flow. Use of the boat ramp at pleasant harbor. Present use includes recreational boating fishing and tribal fishing boats. On a busy day allavailable boat trailer parking is taken. Willthe resort supply overflow parking or require their boating clients to park their rigs elsewhere? Noise. Black Point is at present very quiet. The addition of 2000 plus more people as resort residents and employees will add significant noise pollution. ln addition there is a possibility of float plane service to the resort. There is currently one privately owned float plane that occasionally flies out of Pleasant Harbor. Even though we cannot see Pleasant Harbor from our house, we know from the noise when that plane is landing or taking off. lf the MPR operates like other time shares, exchange of clients would come on Saturday and Sunday. Even moderate float plane service would raise airplane noise to unacceptable levels. For example if even 1Ao/o of the resort population were to choose to fly in and out on a Saturday or Sunday, that would mean 30 to 50 flights each day. That is a lot of noise. Rural Character Brinnon is a pretty sleepy and laid back place. The development of a resort on Black Point will undoubtedly change the character of community. There will be more people, more transitory people. The resort will not be self contained. I envision a demand from the resort cllents for services that the community does not now have, or at least in volume. I see things like a strip with fast food, souvenir shops, and other cheap stores that are ubiquitous in coastal towns nearly everywhere. Other Comments and concerns The Draft SEIS is full of typos and inconsistencies; too many for me to list here. We would hope a better review and editing of the final willtake place. 2 Many jobs at the resort will be seasonal. Wil! those workers become part of the permanent population of Brinnon? What happens to those seasonalworkers during the off season: unemployment or welfare? What happens if Statesman cannot make a go of it? Willthe next owner be able to maintain and operate the resort in the manner proposed by Statesman (ie low use of pesticides and herbicides, low water use protocols, energy efficiency)? What if there is no next owner. Can the resort be bonded to cover expenses to deconstruct if the resort fails? 3 Three of the most notoriously dangerous sections of roadways are in the immediate vicinity of the MPR , l.) South bound, 1/10th 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 frorn 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 Jvne20l2 _Impact_Freight_Congestion.pdf ) The traffic analysis shows that out of 41 00 car trips a day 30Yo or I 230 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 3% ot 123 cars a day or over a l0 hour period 12,3 carVhour. 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 passengor 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 tum 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 equiprnent 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 balt 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 rnonitoring must be done and for as long as l0 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 conllict with the DOE conditions on the water rights. Statesman condition's that they can 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.) Dwing 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 gtavel crusher, finishing crusher, water trucks, highway/of-road trucks...conveyor belt systerns and vibratory/sheep-foot compactor rollers." This witl 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 ofI site that will increase heavy truck taffic. 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 14 I 5 tons of refuse per year to be tnrcked 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 101 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 Stalesman 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 Briruron (2010 Census) which is 3 I %. 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 consffuction 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 Iong 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'X'20'or smaller than a 2 car guage) 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 I 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 sarne so this number is false. In 3.11-16 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 ofjobs created which are At (80% of $42,679.: $34,143,) or Below the AMI arc223 people. The conclusion found in Appendix N page 28 based on tables 3-l tluough 3-4 (pages 8- I 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:/ipugetsoundsage.olg/dolvnloadVWplmart-Fowler-Report-2012-04-06_l - l.pdO In Tables I -20 for all phases of construction these are the totaljobs created and annual mcomes. 48 jobs are above the AMI ranging in income frorn $36,000. to $52,914. 108 jobs are from $10,593. to $14,381. l2l jobs are from $19,241. to $28,00, The 2014 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 of280jobs created an incredible 83% are considered Poverty level. S ee htto ://aspe.hh s. gov/POV ERT Y/ 1 4poverty. c fm 8.) Public Use: Is limited to the bike and walking paths. Tee times are restricted and a lirnited 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 collected of 9o/o and sent to Olympia of which 6.5% stays there and the leftover 25% 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. Ifthe developer stays on as the Property Management Co. or contracts to another rnultinational 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 replacernent 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.fqdqrandasqocjale_S,com/Reports/Destination_Resort_Impact Studv.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 servioes, public infrastructure, and the potential adverse impacts on the community and the environment. The "leisure and hospitality'sector (that includes destination resorts) paid average annualwages 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. Even if two members of a household worked full time at the Thomburgh 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 :o" Most jobs created by the resort will be temporary and when construction is completed, 1,471 jobs will be lost, causing ripple etfects 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 :o" 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 David W. Johnson From: Sent: to: Sublect: Attachments: commtech.us@gmail.corn on behalf of Mark Rose <mark@markrose.org> Monday, January 05, 2015 10:56 AM David W. Johnson Brinnon SEPAAcomment Brinnon SEPA comment.docx Pasted below and attached - thank you. From: Mark Rose, 687 Pulali Point Road Brinnon, WA 98320 360-30 l -2600 To: David Johnson Department of Community Development Port Townsend, WA 98368 Re: Proposed Pleasant Harbor Golf Course and Resort DSEIS Date: January 5, 2015 Greetings, I have been a Brinnon resident for the past l5 yearc. I have followed the proposed resort development at Black Point closely since it was proposed more than 5 years ago, I have also conducted hundreds of hours of research into this and previous proposals for Black Point devleopment, and studied similar proposals and the history completed MPR-typeresorts in the San Juans, other counties in Washington state, and elsewhere in the United States. I appealed the SEPA ruling for the Brinnon Sub Area plan in 2002 and received favorable rulings from the SEPA Hearings Examiner and Western Washington Growth Management Hearings Board. I have studied to Jefferson County FEIS and the DSEIS for this latest resort proposal. My particular concerns with the current DSEIS include but are not limited to highway use, road safety, water quality in Hood Canal, overdevelopment on a fragile shoreline, potential for adverse impacts on our existing economic base of tourism, and the statistically high risk that taxpayers will bear the burden of this development its for failure. I remain deeply concemed that this proposal was handed out for public comment over the Thanksgiving through New Year's holidays when rnany area taxpayers are out of the area or involved with family and guests. This Sea water intrusion, well contamination, decreasing water supplies, and the impacts of new drilled wells on existing water supplies is a huge issue in South County and in particular close to the shoreline. It is clear that insufficient data has been collected or produced as to potential negative impacts of extremely high water use as proposed by this intensive development and golf corrse. 1 makes the timing of this public comment period questionable as to whether we, the public, were even offered adequate time for review. The proposal as put forth fails to meet county goals of improving tourism revenue for South County, and in fact could adversely impact tourism revenue for South County. This area is reachable only by a two-lane road from north and south. Last year, one fatality accident on Mount Walker caused traffic to be stuck on Mt Walker for seven hours. This is only one serious accident that has completely closed access to the area. I urge that the no action option be selected in response to this project. If options one or two are allowed, the developer must 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 ever a 50 year period because of the development and the costs of cleanup and restoration if the project is started but abandoned. I have read the marketing materials from the developer. Like the previous developer they use misleading language to explain the area, We can go virtually the entire month of August with a couple of days of sunshine and the heavy rains, cold and wind for approximately six months of the year is not conducive to an attractive resort. Thank you for your consideration of my comments. Respectfu lly submitted, Mark Rose Mark Rose http : //reb-_e_l lno u s e. c o m/m arkjo se/ http ://about.me/markrose 2 Knowing the existence of these environmental conditions when we purchased this property we installed a weather monitoring station of the same quality and brand as used by many municipalities in this country. lt is set to maintain and store a record every 30 minutes and has been doing so since tO-Lt-O7 @ 6:12pm, recording heating degree days, cooling degree days, solar radiation, ET, wind, rain, etc. I would like to ask a couple of questions about the Quilcene weather station on whlch ALL of your weather data for Black Point is based upon. 1. What agency owns and maintains this station? 2. What make and model is it? 3, When it was last calibrated? 4, The frequency it records to record its data and how often it has failed to make lts recordings, 5. Do you have an unbroken data set since 2006 as you say? 6. ln all these years why has the county not placed a monitoring station at this project site on Black Point? 7, Does the county plan to rely on the developer for all of its future data or will the county monitor Saturday, January 3, 2015 About two years ato as a property owner on Black Point with a well on my property I was very distressed to have the county tell me I would no longer be able to use ANY water outside the walls of my home. Not eyen for the flower pots on the door step. We have a 5 acre property located at 104 Rhododrendon Lane, we raise fruit trees, berries and grow a large garden each year for our subsistence. We have large lawns which we do not try to water as we know the lack of water availability on Black Point as we watch the decrease in our water table since this well was originally drilled. We have also had extremely detailed and expensive water tests performed at that time to set a base record for our well From past dealings with the DCD I can say without a smile I have little trust or respect for the county but I must also say I have much less for the developer of this project. This lack of trust in the county commissioners, the developer, the unsustainability of this project and the unrepairable environmental damage that will be caused result in my total opposition to this development in any form. Sincerely, Terry Germaine 104 Rhododendron Lane Brinnon, Washington 98320 HOOD CANAL ENVI MENTAL COUNCIL ttiqte Hetitage BECK, WASHINGTON 98380 trG ftsls,I1V tr David Johnson, Associate Planner Jefferson County Department of Community Development 521 Sheridan Street Port Townsend, Washington 98358 Jrfftns0ii tloUilII 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. fu 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 revlew 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 lmoacts to Hood Canal Watershed The still largely undeveloped rural character of the Hood Canal watershed is what sets it apart from the more densely developed and urbanized greater Puget Sound region. The publiCs 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. U nfortunately, over the 45 years since the creation of the HCEC, we have seen a gradual "piecemeal" chipping away of the natural landscape from rapid groMh 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 231 acres (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. Anet P,O,BOX87 ; S JAN - 5 2015 Page 1 December 30,2074 i) , uu -5 2(.}i5 DSEIS Alternatives The DSEIS describes in detail the so-called environmentaland other beneficlal and 2. Howeyer, there ls very llttle discussion of impacts under alternative 3 other than to repeat orer and over that "the site will continue to develop as a single farnily residential area based on the existing rural zoning and as described in the 2007 Final EIS'. With very few exceptions, the document fails to demonstrate benefits to the environrnent of the No-Action Ahernative wlth an estimated 30 new resldents (pg. 1-11, Volume 1, DSEIS)when compared to the others. Our letter dated 1G14-07 to the Jefferson County DCD commentlng on the 2007 Draft EIS for the Count/s Comprehensive Plan AmendmenVPleasant Harbor Golf Resort details the rnany benefits of that document's No-Action Alternative. These include significantly lower density, fewer intensive uses, rninimal topotraphic alteration, least demand on groundwater and protectlon of the aquifer from saltwater lntrusion, least trafflc impacts, least potentialfor mntamination 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 protectlon of wlldlife habltat. qenefits of Alternative 3 Much is made throughout the DSEIS of so-called "improvements' to water and other resources from upgrades, e.g. s€wer, stonnwater plan, etc. if the proposed MPR project is constructed (pg. 3.2-7 Volume 1, DSEIS). How€ver, there is no mention of the fact that most of these purported lmprovements could result in the same or higher levels of resource protectlon when the various regulatory and other tools currently available are utilized and enforced. Existing buffer, setback and lot design regulations, county health department sewage disposal approval process, the Shellfish Protection District response plan, upgraded requirements for existing roadway deficlencies, bulldlng permit requlrementt shoreline permltting process, stormwater control plans, local state, and federal project review and habitat mitlgatlon requirements and wetlands protectlon regulations are Just some of the numerous tools listed in our 1G'14-07 letter that are still available. The notion that water quality, water quantity, and other natural resource protections can be irnproved by allowing the kind of intensive development resulting from anqther mega resort in the Hood Canal watershed is ludicrous. Mding language describing the benefits to the environment of Altematlve 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 improrements frorn the origlnal 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 EnvjloJmentalReylewof_P.lg_?ganlHqrlgr.Are.q The northern portion (Pleasant Harbor) of the proposed project is being evaluated under a BSP (Binding Site Plan), a separate pr(rcess which does not require involvernent by the public and makes it very difficuh to get a clear picture of the impacts of the project as a whole. We support the Brinnon Grouy's posltlon that thls area should be subject to a full environmental revlew under the State's EIS process. Proiect Construction Phases The proposed project is planned to be constructed in three phases over a 10 year perlod. Page2 ,_. a t,:.-..'tr,"l,ri] 1,,- i','i.'!, 1' \rr 1Y iJ- r:-i lDlftltarftativHl'- i : -':f inlpacts,of a JA.T'I - | ?.^'i i:. However, there is no guarantee that this plan will be followed. According to the DSEIS (pg. 2.il 5, Volume 1) the schedule may change depending on market conditions. There are othei - circumstances that could result ln delaylng construction, e.g. the develope/s financial shuation, contract andlor labor problems or any number of unexpected lssues. Unfortunately, the construction phase poses the biggest threat to natural resources, including groundwater, which will undergo the greatest demand at that time (Subsurface 6roup Memo dat€d 2-22-10). The issue of nolse pollution may apply here, slnce activltles like rock crushing, are extremely loud. leoact Cost Depos.lt and Performance Bond Regulremen! lf the prefered "no bulld" alternative is not selected, any approval of such a potentially harmful proJect ln thls fragile environment should be conditioned upon a complete analpis of the ascertainable and potentlal econornic lmpact of the proposed MPR during and after constructlon. Before constructlon begins, the developer should be requlred to (1) deposlt the amount of all ascertainable direct and indirect costs regardlng services and lnfrastructure lnto a fund available to local govemment to cover the costs as they are incurred, and (21 fumlsh a performance bond issued by a hlghly rated insurer to cover all potential costs that cannot be ascertalned 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 govemment is attempting to assure no net economlc loss to the communlty, although the HCEC asserts that the "no build" alternative is superior because thls proposed MPR lack assurance of no net environmental loss. a a There ls only one aqulfer which would serve the entire project area, lncluding local residents. The dareloper 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 drawdorns in the event of prolonged dry perlods whlch, lf sclentlflc predlctlons of ertreme weather events due to climate change (changes in the timlng and lntenslty of ralnfalll prove accurate, groundwater and the aquifer could be at risk. The developer's plan to iniect treated wastewater into wells poses the possibility of the introduction of pharmaceuticals and other pollutants into the aquifer. The greatest danger to the Black Polnt aquifer ls the threat of saltwater intrusion. Due to lts sensitivity to saltwater intrusion, this area ls designated as a Critlcal Aqulfer 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 (pg. 2, Appendix F) if their wells show saltwater contamination, the burden of proof as to whether the resorfs water demands are responslble for the intrusion lles squarely on their shoulders. The Appllcatlon reads, ln part, "The well owner provides conclusive evldence that over a statlstlcally relevant perlod of time, chloride levels have lncreased over chloride levels in the well prior to Pleasant Harbo/s use of groundwater, includlng 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 dweloper also can "request additional evidence from the resident showing that the resort groundwater withdrawal is the cause of the increase in chlorides. . . '. Placlng the burden of proof on well owners Page 3 il '._il !-" Ilj 1^t\l - F, 1f"', IL'l', l{ . ,' ' I a Page 4 o Wetland Mitlsatign There are three "Kettles" and associated wetlands on Black Point - A, B and C. The developer plans to convert Kettle 4 which has a high ratin8 of category lll due to its habitat value and moderate to high value for water quallty functions (pS. 3. 7-2, Volume 1) to a control pond for holdlng treated wastewater from the wastewater treatment system to provide recycled water for reuse and for golf course irrigation and fire protection. To offset the converslon, the DSEIS states that Kettle C may be "enhanced". Since the wetland mltigation plan has not been done, it is imposslble 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. 9olf Course We failed to find a listing of chemicals (herbicides, pesticides, or fertilizers) that will be used for golf course gras maintenance or any discussion of how the developer plans to protect groundwater or stormwater runofffrom 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 Managernent Plan should be noted and a plan for how the developer will adhere to the recommendatlons discussed in the WRIA Plan. Under the preferred alternatlve (2) the statement ls made that 88 percent of the site would be retained in open space In the form of golf course, natural areas and buffers (pg. 3. 2-12, Volume 1). We would argue that golf courses do not count as open spaaes as they do not have natural landscape, habitat or other environmental values. saddles them with a long and expensive process. We believe that the responsible for supplying water to the resident in the event of saltwater intrusldn; responsible for the costs involved ln the determination of culpability. A DOE Hydrologic tRevised) Memo from John Pearch dated 1-14-10 shows that there is reason to beliene that wells in the Black Point area are already experlencing sattwater intrusion. Two wells have already been found to have saltwater intruslon. Under the heading of @!!S Wg[' the statement is made that ". . . nearby domestic wells are at rlsk of seawater intrusion due to their proximlty to the coast ..." Also, "Additional pumping of the ACG well and additional 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 decommlssloned due to sahwater intrusion, that information must be contained in the DSEIS. The DSEIS needs to clearly establish the develope/s responsibility for provlng that there is enough water supply for both the resort and nelghboring residents. This includes using updated well data and a monthly monltoring program at the darelope/s ergense. Field sampling is preferable to relylng on computer models. The Neighborhood Water Policy should be revlsed to i$; ;.;lYnot the burden of proof to the dweloper. f7- /i=t r;=[E (l ,', L.=.', llii ['----' '--" l:j , '-,:li .1f,y .ll.N - i illli OTHER ISSUES OF CONCERN While the HCEC's primary area of interest is potentialenvironmental impacts, concern to the HCEC relating to the proposed MPR project. a o a a Economic lmoacts on Local CorRrqrlr.nitv The developer has a responslbility to reveal the true lrnpacts on the local economy from the proposed MPR during construction and operation. Of the estlrnated 225 permanent operationaljobs that could be created, (pg. 1-11 andL-LZ, 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 varlous phases of construction. Many jobs would be seasonal and part time, including food service, maintenance security, etc. lt is ditficult to say who will benefit economically other than ttre Brinnon business community, the Canadian based developer, and possibly real estate developers. A study of fiscal and economlc lmpacts of destlnation resorts ln 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 frcilities includlng roads, schools, fire and police stations, and others is also accounted fior, the net cost to local taxpayers is substantial even after acoounting for all known payments the resort would be requlred to make (Fiscal and Economlc lmpacts of Destinatlon Resorts in Oregon by Central Oregon LandWatch - March, 2009). Traffic lmoacts to Hlehwav 101 The irnpacts to Highway 101 from the increase in vehicles traveling to and from the airport would be substantial. The develope/s plan to rely on two shuttle buses does not take into account that most visitors willtravel by car to and from the resort along hlghway 101. lncreased traffic congestion in towns like Hoodsport ls already a problem ln the summer rnonths. The HCEC ls also concerned about vehich-related non-point pollutlon, stormwater runoff entering Hood Canal and more greenhouse gas emissions resulting from increased traffic. The data used to assess traffic volumes ln the DSEIS appears to be outdated. ln addition, during the construction phase, the increase in trucks and other heayy equipment on Highway 10l would llkely lead to costly damages. Further, the questlon of who wlll pay for the addltlona! hlghway repalrs and the extenslon of Jefferson County's transit seruice needs to be addressed. Jefferson Countv Re:oqrces The HCEC remains concerned about whether Jefferson County has sufficlent staff and other resources that would be required to handle the additionalworkload of monitoring the proposed project for compliance and/or dealing with unexpected problems. A4dltlonal Costs to Mason CounW 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 durlng construction and operation of the proposed project {pg. 3.&2, Volume 1). According to the DSE|S, the P.U.D. has only agreed to supply pot ,er durlng the flrst phase. The questlon of who would pay for a new substation, distribution feeders and englneerlng studies and designs needs to be answered well before approval of 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 energ'y demand from the proposed MPR. Page 5 NavalEase SecuriW There is no mention of the proposed MPR's proximiry to the U.S. Naval Station Bangor Subase and whether this might be considered by the NaW to present a national security lssue. Miscellanous Pages 1-6 and 3.4-1 in Volume 1 refer to "Rainief elk populations. The proper name is Roosevelt elk. The HCEC appreciates the opportunity to express our concerns and provlde comments on the DSEIS for the proposed Pleasant Harbor Master Planned Resort We look fonrard to continuing our involvement and receiving further lnformation as part of lefferson County's public rwiew process. Res pectfully submitted, a t fE 7-],8[L: \i!..j/ lj;::il!i r .l ,l':=rv.i i_lJ V\MJM t-- I I i I I Donna M. Simmons, President Hood Canal Environmental Council JAN - 5 ?fl5 i! irI' ' : j'::j'ri-!U'rill!'jil Sf: !.ilor/lill Page 6 WmMIPy GRNDENS & NUNSERY, LLC vqtt vv tvvJ.-vo tr I I ; I ! I I A P.O. Box 1?0, 306264 Highn'ay 101, Brinnon, \Tashington 98320-01?0 Fax Transmittal Form /fl;* ryNarne, Organizarion Name/Deptt Phone number, Fax nurnber: Namet Phone Number: (800) 95LZ4O4 Fax Number' (360) 79&3556 Email : info@vhiureygardens. c om 'Webt www.com r\ I L. i-'t, i r* rF rE n \/71-=ir- \r. , 'l ll \Y, lL -: -'.'/ ''-.-1.' 'J E L .JA\! - 5 2015 :i.i,rr CUUNTY 6/4d fcrar frEepr t/# /,t#t/ss //U2/4.+rs /9 lEE p,4r ffi 6Wlods /tr ,Mr CCl,,*frPds €-4 P,UE /EE sa,( sr{r4 /t/o /EaArc't tflualtr4,F 3 or/f,p ffi lfatr sG{r ltre p4 { N'E €IT LY OFF z74E @ u#u, /54 std/lLffi saru<t4&E ,+ 74/,UK s &USGS sc,etce tor a changi ng wotld I w vv,tvq Per capita water use. Water questions and answers; USGS Water Science School Page I of2 SearchThe USGS Water Science School * Backto prcviotrs page Search. Water Questions & Answers How much water does the average person use at home per day? Estimates vary, but each person uses about 80-f00 ga[ons of water per day. Are you Irousenolq water is to flush the toilet, and after that, to take showers and baths? That ls why, in these days of water conservatlon, we are starting to see boilets and showers that use less water than before. Many local governments now havg laws that specify that water faucets, toilets, and showers only allow a certain amount of water flow per mlnute. water agendes i n some areas, such as here in Atlanta, Georgia, offer rebates if you install a water-efficlent toilet. In fact, I Just put in two new toilets and received a rebate of $100 for each. Yes, they really do use a lot less water. For your kitchen and bathroom fauceB, if you look real close at the head of a faucet, you might see something like "l.O gpm", which means that the faucet head will allow water to flow at a maximum of 1.0 gallons per mlnute. NOTE: Our data here is very general in nature,..just to give you a qulck ldea of yourwater use. There are some other Web sites that wlll glve you a much more detailed and accurate estimate of your per-caplta water use: . WECalc. CS.GNetwork. $outhwesL Florida Water Management District w Bath Shower Teeth brushing Hands/face washing. Facer/leg shaving Dishwasher Typical water use at horne A full tub is about 36 gallons. 2-2.5 gallons per minute. Old shower heads use as much as 4 gallons per minute, <1 gallon, especially lf water is turned off while brushing. Newer bath faucets use about 1 gallon per minute, whereas older rnodels use over 7- gallons. 1 gallon 1 gallon 20 gallons/load, depending of efficienry of Cishwasher htp //water.usgs. g ov/e du/qa-home-percapita.htrnl tDnoL5 - fi- i' ' '{o .J t1$' ,. vgrtvv tvvv!-eq Pel: capita watEr use. Water questions and answers; USGS Water Science School Page 2 of2 Dishwashing by hand: Clothes washer Toilet flush Glassee of weter drunk Outdoor watering 4 gallons/minute for old faucets.. Newer kitchen faucets use about 1-2 gallons per minutes. 25 gallons/load for newer waslrers. Older rnodels use about 4o gallons per load. 3 gallons for older models. Most all new toilets use 1.2-I.6 gallons per flush. 8 oz. per glass 2 Eallons per minute U,S. Denartment of the Interior I U.S. Geoloeical Survey URL: http :l/water.usgp.gov/edu/q+.home-percapitantml Page Contact Information: Howard Perlman Page last Modified: Thursday, 23-Oct-2o14 rz:3o:a5 EUf http://wate r. rrsgs. gov/edu/qa-home-percapita.hml tnaus Scnt: To: Cc: Frcm:Darlene Schanfald <darlenes@otympus.nefr Monday, January 05, 2015 4:10 PM David W. Johnson Darlene SchaniaU Pleasanl Hartor DSEIS/o/o Jefbrson County DCD PLEASE CONFIR}T RECEP'T OF THIS ETIAIL Frlends of l*llter Penlnsuta State Park PtO 8ox 266{ Scqulm WA 9E3E2 January 5, 2015 Pleasant Harbor DSEIS/c/o Jeffenon County DCD 621 Sheridan Street Port Townsend WA 9E35E dwlohnsor!@co, lefferson. wa. u Below arc comnEnts re3an lng the Pleasant Harbor DSEIS prupared by Frlends of Mltler Penlngrla Stat Park, a 20 )ear, fe<lenlty rccofnlzed rnn proflt m the llorth Olyrpic Penlnsuta. We know that these arc llke and rlmitar to other comrnents belng sent, but want to under:core that ttr e are isrrs sf colrem to ,mny that nced to be addrcsscd. We are disappointcd that this DSEIS was released over holidays and the response time could not be extended, especially since years of extensions \iler€ grven to the developer. POPUI.ATION The poputation of Brinnon ls about 81E and maybe hatf this number of homes, Expanding the number of living quarten by 890 residential units {Optlons I & 2) witt have an enormous impxt in the area in many respects, incl,uding potabte water, storm water, sewage rctlds aM effluents, retear of COZ into the atmosphere and toss of COZ soil and tree seguestration. ECONOiilCS Few of the bultt units are lntended for year round occupancy. ((The majorl$ of thls houslns (67X) woutd be for short- tenn visltom and 33[ rvou]d be for permanent rcsldents.)) 671 or about 5{E unlts arc hoped to be filled, but most tikety the largest percentage of PT occupancy witt be in the warmer tlme of the ),Ear. The lmpacts to the area call for showing an economlc analysis that this resort is financiatly vlable. We reqtrcst this be done. Has the resort company factored in the new WA State minimum wage for emptoyees? Where wilt construction workers (E0.5% out of the area) be housed? Feasibility of houslng them ctose to the site? Witt atl construction works be from WA State? Ho$, wilt their traveting durlng high tourist season affect normat traffic? Optlons 1&2 detaits are descrlbed but the No Actlon, wfrkh ls to build a few hundred homesltes, ls not detaited. lt rems, then, that this No Actlon ls not belng seriousty considered. Yet, lt ls an Optlon and lt should have comparatiye detaits so the costs can be seen. You ask for the publk to vrcigh in and the pubtlc shantd have this infonnation to conslder. Thls ls an omlsslon and shoutd be corrected. Sublect: 1 David tfl. Johnson The lnformation shoutd be combined with that of the marina so one graspr an overatl picture of the costs and potendat impacts of the entire operation. What costs wttl be put to the area and state citizens? For instance, road repair from additionat traffic the resort witl bring. Utitity costs. medkat facilities. Taxation. This estimation shoutd be made pubtic up front. GLOBAL IVARMNG Strlpplng thls larye area of trees and lts naturat grasses, solts and rwttands wltl retease lmmense amount of greenhouse gases lnto the arDlent alr. Earth removat wllt have a tlrge affect on thc mkmblal, solt communlty. A study nceds to be cbrn on how thts GllG release and rcsuttlry drangee affect both the harbor tlfc and thc runoundlry Brlnmn commnity. Appendlx ,S doccr't quanttfy the GHG rcteases and qffestr of thc rcteucs, and thc mftlgatlons arc hardty thatl For seqJestratlon to work, ercn for thc reptantcd trees, thc arpunt wlll rct balance out. lt tak6 yre.rs to regaln that sequestratlon, whether rcptanted trecs or rEw grass. Ctas A cfftunt dlscharge from the proposcd seh€rage trG.trnent plant is planned to be *ored and recycled. lb mt tsc thh to recturge the aqulfen. Do not use this for flre protectlon and irrlgatlon. h will make flrefighters ill. There are many strJdles that determine recyctiry of wastewater treatment ptant (WIVTP) efftuents are Lnsafe. There arc thoGandl of chemlcals and many pathogens that cannot be tested for, nor thelr cumulatlve impacts. lt is known that: . mlcrobeads frorn personat prcducts pass through WWTPs lnto efftunnt . IIRSA and other pathogens rernain in the stu{e End the effluent . antlblotk bacterla can be crcatcd in the WWTPs . trictosan mlnlmlzes WWTP treatmcnt ' effluent contains flre retardants ' effluent and wetl as the sollds contaln thouands of chemlcats lnctudlng chemlcals of emerglng concern and POPs EFFLUENT }lorc reason to not rccych the cfrllent: httq: / /www.eoa.cov/oir/ ruoors/20.l 4/20140929- 1{:P{363.qdf llorc Actlon lr ]lcdcd to hotact W*or Rotourcr From Unmonltorcd lhzardous Chrmlcrlr ffA does not hwe merfionlsms to a&r*s dlsrlr,rye of ,w?rdoius clum,lcals lnto woter rcrourccr,. Common dtabetcs medlcatlon among drugr found tn Lelre Mtchlgen Therc is rnore than one way to measure prescrlptlon drw use ln modem soclety. The rnost direct method is jr6t to count up prescriptlons fltted by Amerlca's pharmacles. That woutd show, for instance, that rnore than .|80 mittion prescriptions for diabetes drugs uere dispensed ln 2013. Or you coutd tcat the treated vrater comlng out of sewage facltltles such as the South Shore ptant ln Oak Creek. That approach rweats that in the Lake ilichlgan waters outslde the ptant, the dlabetes drug rnetformln was the ,nost common personal care prodrct found by researchers wlth the School of Fresbllater Sclences at ttrc Univenlty of Wisconsin-ilitwaukee. ilbre importantty, according to their tatest rerarch, the tercts of metformln lyere so high that the drug could be dlsruptlng the endocrine systems of fish. Last month, a, Joumal Sentlnet/l,tedPase Todav lnyestlratlgn found boomlng sates of dlabetes drugs, whlch ln 2013 had grown to rnore than t23 blltton. Lletformh is a flrct-tlne treatmeylt for type 2 dlabetes and is the rnost commonly prescribed medicine for the condition. ln 2013, about 70 mittlon preEcriptions were dispensed, accordlng to IMS Heatth, a drug mariet research firm. It ls so ublquttous lt can easity be found in water sampt$ taken two mites off the shore of Lake Michigan, '1 was klnd of a surprlse," sald Rebecca Ktaper, a profesrcr of frethwater science at UWM, "lt was not even on our radar screen. I said, What is thls drugl " 2 The drup tet lnto the sewagg and eventually the lake becausc they are not broken down completely after they are consumed and then excretad. The rEtformln concentratlons are low, compared wlth the amount taken by peopte. For imtance, coming right out of the treatrnent ptant the tevets are about 40 parts per billlon. About two mites away, thcy drop to 120 parts per trlltion. Othercomrmnty found substances include caffelne, sutfamethoxazole, an antlbiotic, and triclosan, an antibacterial and antifungat found in soap and other consumer products. Ktaper co-authored a 2013 science joumat paper on the finding as wett as another one thls year. The more r€cent r"search suggests that rnetformin ln lake water is not Just a curlous artlfact of eveqfray tife. The study tooked at the effect of metformin on fathead minrrcws in the tab that were exposed to the drug at leveb found in the lake for four v€elc. It found gene expresslon sl8gestlng dhruptlon of the endocrlne system of male fish, but not femates. ln e$ence, the males were produclng blochemkats that are assoclated wlth femate mlnnows. The biochemkats are pnrursoB to the productlon of eggs. Ktaper sald that because the mlnnows are a stand-ln for other flsh, the changes aho coutd be affectlng other species such as perch, walteye and northem plke. The UWM research conflrms what others have found regarding prescriptlon drugs showlng up ln Amerlca's takes, rlvers and streams, sald liettssa Lenczewskl, an associate profesrcr of geology and environmental geosclencei at Northern llllnois Unlverslty. For years, it ltas assumed that the volunr of water ln the Great Lakes was so enormous that any drugs that got thrcugh $eatrnent facitities woutd be dltuted to the point that they vrmutd not pose a probtem, said Lenczery:ki, who was not a part of the UWM study. That theory ltsetf now ls being dlluted. Even more concerning are the much hlgher tevels of antlblotlcs that are being put lnto rlvers and streams near plg farms where the drugs are used to prodrce larger animats, she said. h addltlon, stralns of antlblotlc-reslstant bacterla also have been found ln water near those farms, she said. 'lt is yery atarming how much we are pttting drugs out there in the environment," she said. ln that thh resort ptans to establish a medicat clinic for resort mernhn (& workers?) th€rc witt bc medicat vrastes in thc WWTP, tct atone from what goes doiln the dralns from the resldentlal unlts. TMFFIC One of the rno6t norrlsome lssrs wlth thls proJect is trafflc. Hwy 101 ls a thoror4hfare used by thor travellrg betwE"n Ctattam County and nprc rcuthern polnts to Otympla. Addltlonalty, the trafflc is grcatty lncreased durlng the 3umrnr season. Roads are narow. itnch of the route is on btuffs whlch fall, as some Just haw thls Decerter 2014 creatir[ one way trafflc for urceks. Landstldes arc Gomrnon on thls routc durlng the nlny season. Trafflc accldents happen. Onc can lm4lne that thls r"sort traffic nccds witt be ogensed to the State, hence the cltlzem. Thls reron area ls an lnhospitable sltc for a laryc rcsort. WATER Very worrlsome ls the avaltablllty of water over a long tem and the affects on communlty ryater needs. lf thls becomes p,Dblematlc, vrlrat rcspon{billtlel wi[ thc nercrt owner be hctd to? (hce it ls uad, ft uon't be regained. Water is golr6 to be the "gold" ar neathr wanm and snow terets are mlnlmlzed and ralmvater runoff irrreases. SUi,ll,lARY Thls cornment covers onty sorne of thc problems wlth the ptanned resort ard the DSEIS. Ctearly, lt ls not apprcprlate to approve thls prcJcct, Oartene Schanfatd, Ph.D. Presldent 3 Davld llU. Johnson From: Sent: To: joe breskin <Joe.breskin@gmail.com> Monday, January 05, 2015 4:08 PM David W. Johnson OEC Black Point Pleasant HarborMPR DSEIS CommentsSubjcct: David, In addition to the concems raised by The Brinnon Group in the JanZ submittal by Barbara Moore- Lewis, Olympic Environmsntal Council (OEC) would add the following concerns: POPULATION The population of Brinnon is about E I 8 and maybe half this number of hornes. Expanding the number of living quarters to 890 r,eside,utial units (Options I &,2) will have an enonnous impact in the area in many respccts, including potable watetr, stormwater, scwage solids and efrluents, trleas€ of CO2 into tlre afrnosphere and loss of CO2 soil and trec sequestration. ECONOMICS Few of the built rmits are intended for year round occupancy. (The majority of this housing (670/o) would be for short- tsrm visitors anrd33% would be for permancnt residents.) 670/o or about 548 units are hoped to be fillcd, but most likely the largest perccntage of PT occrrpancy will b€ in the warmer time of the year. The impacts to the area call for showing an economic analysis that this resort is finurcially viable. We request this be done. Has the resod company factored in the new minimum wage for ernployees? Whene wi[ construction workers (80.5% out of the area) be honsed? Feasibility of houing them close to the sitc? lVill all constnrction works be from WA State? Options l&2 daails arc described but the No Actioq whic,h 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 cosr can be seen. You ask for the public to weigh in and the public should bave this information to consider. This is an omission and should be corrocted. 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 ingtance, road repair frorn additional traflic the resort will bring. Utility costs. Medical facilities. Ta:ration. This estimation should be made public up tont. GLOBAL WARMING Stipping this large area of tees and its nailral grusses, soils and wetlands will release imrnense amount of greenhouse gases into the ambient air. Earth removal will havc 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 nrrounding Brinnon commuoity I Appendix M doesn't quantiry the GHG releases and effests of the releases, and the mitigations are hardly that! And for sequestration to work, even for the replanted tees, the amount will not balance out. It takes years to regain that sequestration, whethsr replanted Eees or new grass. Too, please factor in how this would affect the marine life. EFFLUENT Class A effluent discharge from the proposed sewerage reatment 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! Thcrc ae many studies that determine recycling of wasterrater teatnent plant (WWTP) cflluents are nnsafe. There ale thorsands of chemicals and many pathogens that cannot be tested, nor the cumulative impaots. It is knovm that: . rnicrobeads from personal products pass through WWTPs into effluent . MRSA and other pathogens remain in the sludge and the effluent . antibiotic basteria can be created in the WWTPs . triclosan rninimizes WWTP treatment . effluent contains firc reurdants . effluent and well as the solids contain thousands of chemicals including chemicals of emerging concern and POPs More reason to not recycle the eftluent: http ://www.epa- gov/oi e/reports/20 1 4120 I 40929- I 4-P-03 63.pdf Thcrc is an inadcquatc discussion ofconstuction noise resulting fiom sEtcd ncod to crush vast arnounts ofgravcl as sitc is developed. Prcsumption is that crushing world ossur in batchcs, bascd on the combination of sitc dwclopmcl4 rclacd larrd disturbing activities and prdoctcd nceds for cach dcvclopncnt stagc. Noisc ab&mcnt mcrns should bc providcd in a noise abatcrncnl plur thu inclrdes hours of operation and noiae abatement mcans and County should requirc dwclopmcnt of computcr modcls to prcdict noisc impacts at rccoiing propcrties and ongoing monitoring to insurc that projedions arc accuratc and tha noise abatament providcd is in fact cffcctive, md should lncludcs clursos oalling for fuumcdiac rcmodies if abatarcnt ftils to deliver promised SPL. Continuous rnonibring at recMng prcpcrty that rccor& bch pcak md merage SPL to bG rccorded dwing pariods whco crushing cqulpment is in opercion ond awilablc for public rcvicw. SUMMARY This comment cov€rs only sorne 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 Cormcil Jan 5,2015 2 ( iN t\ 'tt I -I"v StnRRA CLUE ffi [-i(-'?' i) JAN(}5AT 5 January 201 5 Jtt[EB33I [BtiltlY 0[0 Jefferson County Department of Community Development Ath: David Wayne Johnson RE: Pleasant Harbor Master Planned Resort DSEIS 621 Sheridan Street Port Townsend WA 98368 dwjohnson @co j efferson. wa.us On behalf of Sierra Club North Olympic Gtoup and our hundreds of members, activists, ond zupporters, we are writing to submit comments on the Pleasant Harbor Master Planned Resort DSEIS. Please include these comments in the administrative record. Sierra Club feels there are serious omissions in this Draft Environmental Impact Statement that must be corrected. Our comments on different aspects are listed below. GLOBALWARMING: An assessment needs to be done and presented on how this project will affect global warming and the migrobial soils community due to extensive plant and soil removal. Appendix M doesn't quantifr the GHG releases and effects of the releases, and the mitigations are clearly inadequate. It takes years to regain sequesfiation of carbon,and the DEIS also fails to factor in how this would affect marine life. r ${J },1 $ t [! I 8{,r:l EFFLUENT: Class A effluent discharge from the proposed sewerage ffeatment plant is planned to be stored and recycled. This is a dangerousi practice that should not be used due to inevitable pathogen tansfer to aquifers. There are thouands of chemicals and many pathoge,ns, (microbeads, MRSA, antibiotics, fire retardants and chemicals of emerging concern) that cannot be tested, nor are clearly known for their cumulative impacts, ffid that will be introduced in a recycling system. TRAFFIC: One of the most worrisome issues with this project is traffic. Hwy 101 is a thoroughfare used by those traveling between Clallam County and more southern points to Olympia. Additionally, the taffic is greatly increased during the summer season. Roads are narrow. Much of the route is on bluffs 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. Traftic accidents happen. This resort area is an inhospitable site for a large resort. WATER: Another very worrisome issue is the availability of water over the long term and the effects on courmunity water resources. Water will become a key resource as weather warms and snow levels are minimized and rainwater runoffincreases. The DSEIS does not address this truth. SUMMARY This comment can only cover some of the problems with the planned resort and the DSEIS. Clearly, it is not appropriate to approve this project. Respectively submitted, Monica Fletcher Chair North Olympic Group, Sierra Club monicaflet@gmail.com