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HomeMy WebLinkAbout130Pleasant Harbor Final Supplemental EIS December 2015 Prepared by Jefferson County Department of Community Development VOLUME 2 – EXHIBITS 1 and 2 Exhibit 1 Comment Letters and Responses Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 1 Exhibit 1 EXHIBIT 1 COMMENT LETTERS AND RESPONSES This exhibit of the Final Supplemental EIS (Final SEIS) contains comments that were received on the Draft Supplemental EIS (Draft SEIS) and provides responses to the comments. The Draft SEIS for the Pleasant Harbor was published November 19, 2014 and Notice of Availability was distributed to agencies, organizations and individuals (see Draft SEIS Appendix A – Distribution List). The public comment period for the Draft SEIS ended on January 5, 2015. During the Draft SEIS public comment period, a total of 70 letters with comments regarding the Draft SEIS and the analysis of environmental impacts were received including seven from agencies and tribes, six from organizations and 57 from individuals. Each letter is included in this section of the Final SEIS. Comment letters/numbers appear in the margins of the letters commentary and are cross-referenced to the corresponding responses. Responses are provided directly after each letter. Responses to comments made at the Planning Commission meeting that was held on December 3, 2014, are contained in Exhibit 2. Expressions of opinions, clearly subjective statements and positions for or against the project or the alternatives are not responded to in this section of the Final SEIS, however these comments are included in this Final SEIS, are acknowledged, and will be considered by the County as part of the decision making process. The following comment letters were received concerning the Pleasant Harbor Draft SEIS: Agencies and Tribes Letter 1 – Jefferson County Department of Community Development (Donna Frostholm) Letter 2 – Jefferson County Department of Public Works Letter 3 – Port Gamble S’Klallam Tribe Letter 4 – Washington State Department of Archaeology & Historic Preservation Letter 5 – Washington State Department of Ecology Letter 6 – Washington State Department of Health Letter 7 – Washington State Department of Transportation Organizations Letter 8 – Brinnon Group Letter 9 – Friends of Miller State Park Letter 10 – Hood Canal Environmental Council Letter 11 – Northwest Watershed Institute Letter 12 – Olympic Environmental Council Letter 13 – Sierra Club Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 2 Exhibit 1 Individuals Letter 14 – Joe Baisch Letter 15 – Joy Baisch Letter 16 – J Hal Beattie and Rebekah R Ross Letter 17 – Bonnie Beaudoin Letter 18 – Bonnie Beaudoin #2 Letter 19 – Barbara Buchman Letter 20 – Joseph Buchman Letter 21 – Scott Burns and Margaret We___?? Letter 22 – Sarah Clawson-Schuch Letter 23 – Ruth Di Domenico Letter 24 – Dalila Dowd Letter 25 – John Dowd Letter 26 – David Galle Letter 27 – Terry Germaine Letter 28 – Belinda Graham Letter 29 – Eric Hendricks Letter 30 – Joan Hendricks Letter 31 – Jennings Heins & Associates Letter 32 – K. Kennell Letter 33 – Genene Kluck Letter 34 – Laurie Mattson Letter 35 – Joy McFadden Letter 36 – John McKay Letter 37 – Brenda McMillan Letter 38 – Rob Mitchell Letter 39 – Richard and Sheila Moore Letter 40 – William and Roxianne Morris Letter 41 – Miriam Murdoch Letter 42 – Gary and Pam Myhr Letter 43 – Joe and Miriam Newsom Letter 44 – Jerry and Susan Olson Letter 45 – Joseph and Krystyna Orrico Letter 46 – Morgan Oslake Letter 47 – Kirie Pedersen Letter 48 – Lynne Robinson and Dan Watson Letter 49 – Mark Rose Letter 50 – David P. Sadler Letter 51 – David P. Sadler #2 Letter 52 – Eleanor Sather Letter 53 – Eleanor Sather #2 Letter 54 – Eleanor Sather #3 Letter 55 – Bud and Valerie Schindler Letter 56 – George Selfridge Letter 57 – Peter Siefert Letter 58 – Mike and Joan Stelte Letter 59 – Fred Stern Letter 60 – William and Victoria Stewart Letter 61 – Phil Thenstedt Letter 62 – Judd Tuberg Letter 63 – Greg and Tina Tyler Letter 64 – Lori Uddenberg Letter 65 – Steve Walker Letter 66 – Patty Wells Letter 67 – Del and Terri Weron Letter 68 – Katie Whitman Letter 69 – Lynda Wilson Letter 70 – Ralph Woodall David W. Johnson From: Donna Frostholm Sent: Monday, January 05, 2015 4:36 PM To: David W. Johnson Subject:Pleasant Harbor DSEIS Comments David: As a follow up to your March 10, 2014 email, I have the following comments on the Pleasant Harbor DSEIS: 1. During my previous review of the submittals, it appeared that the applicant was intending to use the created wetland as part of the water treatment system. Based on a quick review of the documents, I did not find a drawing that shows the connections for the on-site water system. Wetlands created as mitigation for critical areas cannot be used to meet other code sections(such as the stormwater storage and treatment). The applicant should clarify that the mitigation area is separate from other water infrastructure to operate the resort. 2. The 1CC allows for mitigation performance bonding and, given the number of mitigation plants proposed, I would suggest that the applicants be required to post a bond to ensure funding for mitigation, including contingency measures, and to ensure that annual monitoring reports are submitted. 3. The wetland mitigation plan states that reclaimed water will be directed to the existing wetlands, which presumably means Wetlands C and D(and is sometimes referred to in the document as "enhanced" hydrologic patterns). In the JCC, alteration of wetland hydrology is a regulated activity. The EIS prepared for the re-zone was clear that these two wetlands would not be impacted,one of which extend offsite and is in close proximity to a steep slope. The existing vegetation and wetland functions at these two wetlands are based on the current hydrologic regime. Any modification to the hydrologic conditions will affect the vegetation and should be considered a wetland impact. 4. The area of impact for each Impact Class ID in Figure 3. 3- 1 should be quantified to support the statement in Section 3.3-4. Removing approximately 89 percent of the vegetation is inconsistent with the conclusion that there will be no significant unavoidable impacts to plants. The applicant should provide more information to support that statement. Let me know if you have any questions. Donna Frostho(m Associate PCanner/WetCandSpecialist Jefferson County Department of Community DeveCopment 621 Sheridan Street Port 7otivnsencC Washington 98368 360-379-4466 tfrostfiotmcwco jefferson.waus DCD is open from 9:00am—12:00pm and 1:00pm—4:30pm Monday through Thursday;DCD is closed on Friday. All emails sent to and from this address will automatically be archived by Jefferson County and emails may be subject to Public Disclosure under Chapter 42.56 RCW. 1 1 2 3 4 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 4 Exhibit 1 RESPONSE TO COMMENTS FROM DONNA FROSTHOLM (Letter # 1) Comment 1 Wetland B would be used as part of the water treatment system. Impacts to Wetland B would be mitigated for by creating wetland habitat at a 2:1 ratio within Kettle C. This wetland mitigation site would not be used as part of the water treatment system. Comment 2 Your comment is acknowledged. The applicant will follow Jefferson County Code regulations and post a bond to ensure funding for the proposed mitigation plan. Comment 3 According to the project engineer, plans will be revised; reclaimed water will not be directed into existing wetlands. There are two water feature ponds to the east of Kettle B. The revised plan for reclaimed water, according to the project engineer, will involve water being pumped from Kettle B to the top of the ridge so it can flow as a series of water falls and stream across the fairways and through the two ponds to the east of the kettle. Water from the most easterly pond would be pumped back to the top of the ridge to recirculate through the water features continuously. Water would not be discharged from Kettle B to Wetlands C or D. Overflows from the Kettle B pond would infiltrate at the perimeter of Kettle B or in the extreme case, flow by pipe into the mitigation created wetland. Reclaimed water would not be discharged to wetlands. The existing hydrologic conditions associated with wetlands C and D would be maintained and no impacts to the functions of these wetlands would be anticipated. Comment 4 The statement that no significant unavoidable impacts would result has been revised in Section 3.3 (Plants) the Final SEIS as follows: With proposed development under either Alternative 1, 2 or 3, areas of existing vegetation would be removed: 201 acres under Alternative 1, 152 acres under Alternative 2, and 132 acres under Alternative 3. Areas of retained natural vegetation and new vegetation in the form of the golf course and new landscaping would be provided. Jefferson County Department of Public Works 623 Sheridan St. Port Townsend, WA 98368 360) 385-9160 Monte Reinders, P.E. Public Works Director/County Engineer December 30, 2014 F Ir David Wayne Johnson JAN 0 5 2014ProjectPlanner Jefferson County DCD Port Townsend, WA 98368 JEfF "'"?° L IT6:i i GPuD Re: Draft Supplemental Environmental Impact Statement (DSEIS) Pleasant Harbor Master Planned Resort Comments submitted by Richard Talbot, Solid Waste Manager representing Public Works Solid Waste Division Reference: 3.16 UTILITIES 3.16-1 Affected Environment SEIS Solid Waste p. 3.16-2 Comments: 1. The SEIS states that "In 2012, over 19,000 tons of muniaa/solid waste were collected through these two facilities': Our records show a total of 17,543 tons of municipal solid waste of which only 160 tons came from the Quilcene drop box site. The County also processed 3,785 tons of recyclables of which 84 tons and 98 tons respectively came from the Quilcene and Brinnon collection sites. 2. The Level of Service (LOS) standards defined in the JC Comprehensive Plan refer to the capacity of the County's overall solid waste handling facilities, and may be lower for a small rural drop box site such as at Quilcene. 3. The Quilcene drop box site has no weigh-scale and by nature of its design is unable to accept waste from Commercial hauling companies. Waste is charged by the "unit piece" and the waste compactors are designed for hand loading not end dumping. 4. In addition to the free recycling site in Brinnon at the Dosewallips State Park, Skookum also services a County recycle site co-located at the Quilcene drop box waste disposal site. 5. Curbside collection of municipal solid waste and recyclables is also currently provided throughout the unincorporated county by Murrey's Disposal, the WUTC G-certificate holder. This service is by subscription (not obligatory). This waste is primarily taken to the County's main waste transfer facility in Port Townsend. 1 l Reference 3. 16 UTILITIES 3. 16.2 Impacts SEIS Solid Waste p.3.16-6 The SEIS estimates an annual waste generation rate of 1,364 tons/year residential and 45 to 51 tons/year commercial/ retail. And "It is assumed that a private service would pick up solid waste and that a composting and recycling program would be utilized to help reduce the solid waste stream." Reference Draft SEIS, Nov 2014 2.5 Description of Proposal Table 2-1, p.2-20 Final EIS, Nov 2007 1.3 Summary of the Proposal and Permitting Limitations p. 1-17 The non-commercial units are stated to total 890 units (Table 2-1) of which not more than 10% will be permanent residences, 30% to 40% will be seasonal tourist stays (<6 months), and 50% to 60% will be short term tourist pool (FEIS p.1-17). Comments: 1. Ideally an MPR such as Pleasant Harbor would require residents and/or a unit management organization to subscribe to a solid waste collection service as a condition of its development. 2. In the absence of such a requirement individual residents may choose that option or to self-haul to the County's Quilcene site or elsewhere. It is estimated that the Quilcene site could increase waste intake from 160 tons/year to 550 tons/year with no substantial changes to the operation other than additional road-hauls to remove the waste. 3. Private curbside waste collection service is typically suitable for permanent residents 10% of units) and is available weekly, every other week or monthly. This only requires that commercial trucks can access all units and turn-around at road ends. 4. Units designed for seasonal and short term tourist stays (90%) are typically better served by 1 to 2-yard dumpsters that serve a number of units and are not sensitive to a mobile or visiting population. This service is typically provided and managed by a development management organization. Weekly collection is available. 5. Recycling service can be subscribed to as for solid waste. 6. There is no regular yard debris collection service in the county, and it is not accepted at the Quilcene drop box site. There is no food waste composting service in Jefferson County. An ideal solution for an MPR such as Pleasant Harbor would be to establish a central yard debris chipping station, and use the product on-site as landscape mulch. Yard debris can also be hauled by individuals or landscape contractors to the biosolids- composting facility in Port Townsend. 7. There will be increased traffic impacts for all of the above options. Richard Talbot Solid Waste Manager, ph. 385-9213, email rtalbot@ico.jefferson.wa.us 1 cont. 2 3 4 5 6 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 6 Exhibit 1 RESPONSE TO COMMENTS FROM JEFFERSON COUNTY DEPARTMENT of PUBLIC WORKS (Letter # 2) Comment 1 Thank you for your comments. Section 3.16 of the Final SEIS has been updated to reflect the collection numbers and details cited in this letter. The proposed mix of permanent and short-term residential units has changed from the 2008 Final EIS to this Supplemental EIS. As outlined in Table 2-3 of the Draft and Final SEIS, 37 percent of residential units (278 units) to be provided within the development would be for permanent residents (defined in Table 2-3, page 2-31 as ‘long-term tourist residents”), 67 percent (560 units) would be for short-term stays, and 52 units would be for staff housing. Comment 2 As stated on page 3.16-6 of the Draft SEIS, “It is assumed that a private service would pick up solid waste and that an onsite composting and recycling program would be utilized to help reduce the solid waste stream.” Solid waste generated at the existing marina complex and Pleasant Harbor House is presently collected by Murrey’s Disposal, and Section 3.16 of the Final SEIS has been updated with this information. Communications would be initiated with Murrey’s Disposal at a later stage of the development approval process to initiate garbage pickup services. Comment 3 Please refer to the response to Comment 2 of this letter, above. It is not anticipated that operations under SEIS Alternatives 1, 2 or 3 would involve residents, visitors or staff self-hauling waste or recyclables. Comment 4 With regard to the intent to provide curbside waste collection service, please refer to the above response to Comment 2 of this letter, above. The internal road system under Alternatives 1, 2 and 3 is designed to provide commercial truck access to all units and turn-arounds at road ends. Comment 5 Please see the response to Comment 1 of this letter, above, regarding the mix of short-term and long-term residential units under SEIS Alternatives 1, 2 and 3. It is acknowledged that dumpsters would be appropriate for solid waste collection service to the short-term residential units. Comment 6 As indicated in the above response to Comment 2 of this letter, Section 3.16 of the Draft and Final SEIS state that a composting and recycling program would be utilized to help reduce the solid waste stream. Resort staff would maintain the golf course and all landscaped areas, and would manage trimmings from these areas in an onsite composting area. Permanent residents Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 7 Exhibit 1 may occupy the same buildings as short-term residents. No private landscape maintenance would occur within the resort. Food waste composting is not proposed on the site, as food waste has the potential to attract insects and animals. v PORT GAMBLE S'KLALLAM TRIBEr4©k, NATURAL RESOURCES DEPARTMENT O2r` 31912 Little Boston Rd.NE—Kingston,WA 98346 RT In January 5, 2015 Pleasant Harbor DSEIS c/o Jefferson County DCD JAN 0 5 2014 621 Sheridan Street Port Townsend WA 98368 Email: dw'ohnson( co,'efferson.wa.us JEfFEETI P Dear Mr.Johnson, Thank you for the opportunity to comment on the Draft Supplemental Environmental Impact Statement for the proposed Pleasant Harbor Master Planned Resort.The Port Gamble S'Klallam Tribe's(PGST) Natural Resources Department provides the following comments.Due to the potential for significant adverse effects to shellfish,fish,and wildlife we continue to oppose this project and request a meeting to discuss the issues in more detail. The proposed project is located within the Usual and Accustomed area of the Port Gamble S'Klallam Tribe. Tribal members depend on the fish,shellfish and wildlife resources within the project area for their cultural and economic well being. We are concerned that habitat loss and degradation from the proposed project would impact salmon,shellfish and other important species in the area. The Dosewallips and Duckabush rivers and their deltas serve as critical habitat for threatened salmon and other fish,shellfish and wildlife populations valued by the Tribe.Therefore,we are concerned that the proposed project would jeopardize the Tribe's treaty rights to fish and hunt in the project area. As we have stated previously in our 2001, 2006 and 2007 comments on this project,we are concerned with the size and scope of the proposed development. The increase in traffic and intensity of land use will have significant impacts on resources and the DSEIS fails to adequately address these concerns. Water Resources The project site includes a susceptible aquifer recharge area and the potential impacts to local groundwater,stream flows and wetland geology are very significant. Ongoing monitoring of water runoff and its affects on sensitive resources is needed during the construction and operation phases,in addition to an adaptive management plan for making any necessary operational changes. The proposed management plan should require weekly rather than monthly monitoring and should include monitoring for saltwater intrusion.Under the current plan,steps are identified in the event that saltwater intrusion is detected in neighboring wells, but no preventative measures are provided.A more comprehensive monitoring plan is needed to protect water resources. Environmentally Sensitive Areas In a December 21,2001 joint SEPA comment letter from Point No Point Treaty Council, Jamestown S'Klallam,Port Gamble S'Klallam and Skokomish tribes,we highlighted the presence of numerous sensitive environmental features that would be degraded by resort development including unique kettle ponds and streams.In addition,the Washington Dept.of Natural Resources landslide hazard zone maps depict steep,unstable slopes fringing the Black Point 1 2 3 4 5 PORT GAMBLE S'KLALLAM TRIBE NATURAL RESOURCES DEPARTMENT 31912 Little Boston Rd.NE—Kingston, WA 98346 kettle ponds.The proposed project would result in the loss of approximately 20,700 square feet of wetland area and a portion of the wetland buffers associated with Wetlands C and D.The proposal to create wetland area as a mitigation measure does not guarantee the successful replacement and maintenance of this important habitat. Annual monitoring of wetland creation areas is not sufficient for detecting any adaptive management that may be required. Fish and Wildlife Habitat The forested uplands to the northwest of Black Point represent an important elk migration corridor between the Dosewallips and Duckabush river valleys. The proposed development would result in the loss of existing upland wildlife habitat and although the areas of on-site habitat would be retained,we are concerned about the impacts to the elk migration corridor. The SDEIS did not address this issue. The plan includes the monitoring of water quality from the state water quality sampling station at Pleasant Harbor to identify any impacts on fish species. However,additional monitoring stations both on and off site and more preventative measures are needed to adequately protect water quality and existing fish species. We are concerned that once degradation occurs from the project,impacts to spawning and refugia habitat will be irreversible. The plan does not provide any assurance that water quality issues would be adequately resolved. Shellfish Species Tribal members harvest between 13,000 and 21,000 pounds of manila clam and between 13,000 and 48,000 pounds of Pacific oyster from the Duckabush alone.So we are highly concerned about the potential impacts to this important resource. The DSEIS states that with implementation of identified mitigation measures,no significant unavoidable adverse impacts to shellfish would be anticipated. However, the analysis does not consider the increased risk of spills and accidents that would occur with the increase in vessel traffic both on land and in the water. Although the SDEIS describes plans for stormwater to be managed appropriately,the increased risk of discharges from contaminants,turbid waters or sediment as a result of construction and operations must be considered. Given the short timeframe for review of the DSEIS and appendices,this letter represents only a summary of our most critical concerns about the proposed project. We request the opportunity to consult more directly with the project applicant and Jefferson County staff to discuss our concerns in more detail. Please contact me at romacCu?pgst.nsn.us to schedule a meeting. Thank you. Sincerely, L, ) Roma Call Environmental Coordinator Phone: (360) 297-4792 Fax: (360) 297-4791 2 5 cont. 6 7 8 9 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 9 Exhibit 1 RESPONSE TO COMMENTS FROM PORT GAMBLE S’KLALLAM TRIBE NATURAL RESOURCES DEPARTMENT (Letter # 3) Comment 1 Thank you for your comments, your comments are noted. As per this request, a meeting with the Port Gamble S’Klallam Tribe and Jefferson County Department of Community Development was held on February 18th, 2015. Comment 2 The project is proposing several minimization measures to limit potential impacts to fish and wildlife in the Point Black area. Although only a 150-foot buffer from the Ordinary High Water (OHW) is required according to the Jefferson County Code, the project is proposing a 200-foot buffer within the golf course area and is replanting existing degraded riparian areas within the shoreline buffer and will limit access to the shoreline in the area of the golf course. In addition, the project is leaving wildlife corridors (areas of undisturbed vegetation) throughout the golf course area. These corridors will lead to more than 200 acres of relatively undisturbed vegetation on and off site in addition to the existing and created wetland features. For more information on fish and wildlife minimization measures, see the Habitat Management Plan Report (SEIS Appendix H). The site is also being designed so there will be no discharges of runoff into Hood Canal; all water will be collected, treated and reused. Comment 3 Comment acknowledged. Traffic issues, including Traffic Volumes and Level of Service were evaluated in Section 3.9 (Transportation) and Appendix L of the Draft SEIS. This analysis resulted in the conclusion that no significant impacts would result from the Alternatives, with the implementation of appropriate mitigation measures. See this section of the Final SEIS for further details. Changes in intensity of land use were evaluated in Section 3.12 (Rural Character and Population) of the Draft SEIS. As stated in Section 3.12, the Pleasant Harbor resort under the development alternatives would increase the density of development, and establish residential units, vacation units, and commercial and resort related recreational amenities on the site. Activity levels (i.e. noise, traffic, etc. associated with new activity) on the site would increase as a result of development under to the increase in density and associated on-site population (residents and employees) and short-term visitors. This analysis resulted in the conclusion that no significant impacts would result from the Alternatives, with the implementation of appropriate mitigation measures. See this section of the Final SEIS for further details. In addition, based on comments received on the Draft SEIS and other factors, an additional development alternative (Alternative 3) has been added for analysis in this Final SEIS. Alternative 3 proposes a smaller 9-hole golf course with associated putting green practice area, as compared to the full 18-hole golf course assumed under Alternatives 1 and 2. With the smaller golf course, less clearing of vegetation would occur on the site, and more natural area would be preserved. For example, approximately 103 acres (45 percent of the site) would be in natural area under Alternative 3, compared to approximately 31 acres (13 percent of the site) under Alternative 1, and 80 acres (35 percent of the site) under Alternative 2. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 10 Exhibit 1 Comment 4 Please see Key Topic 4-2, Saltwater Intrusion, in Chapter 4 of this Final SEIS for a discussion on aquifer recharge and potential for aquifer impact. Water runoff during construction would be managed onsite in accordance with all applicable Federal, State and County regulations, as described in Draft SEIS Section 3.2 (pages 3.2-16 and 3.2-17), and in the Grading and Drainage Engineering Report (Peck & Associates, May 16, 2012) included in Appendix E of the Draft SEIS. Either the owner or the contractor would employ a Certified Erosion/Sediment Control Lead (CESCL) who would be onsite during construction to monitor compliance with applicable regulations and permit conditions, and to direct the implementation of contingencies if needed during storm events. The majority of stormwater runoff would be detained and infiltrated onsite. Comment 5 As part of the permit requirements of the project, twice as much wetland will be created as would be impacted; approximately 41,400 sq. ft. of wetland would be created to mitigate for impacts to approximately 20,693 sq. ft. of wetland. The created wetland would be monitored for five or more years to ensure that wetland conditions have been established. If the site is not successful, corrective measures would be taken to ensure that approximately 41,400 sq. ft. of wetland is established. The project will not result in the loss of buffers associated with Wetlands C or D; buffer averaging would be utilized as allowed for in the Jefferson County Code. Wetland C and D buffers would be reduced in some areas and Wetland C and D buffers would be increased in some areas so there is no net loss of wetland buffer habitat. See the Wetland and Wetland Buffer Mitigation Plan Report for more information (SEIS Appendix J). Annual monitoring is typical of mitigation sites; however, if the site is not deemed successful after five years of monitoring, the Washington State Department of Ecology would likely not release the site from monitoring requirements until the site is successful. Alternatives 1 and 2 analyzed in the Draft SEIS were developed to address the Jefferson County Board of County Commissioners (BoCC) Ordinance No. 01-0128-08 conditions, including Conditions 63 (h) and 63 (i) that relate to evaluating potential impacts to the kettle features on the site, as reported in Draft SEIS Section 3.2 (Water Resources, page 3.2-18). Also see the Response to Letter 4, Comment 1, below. Alterations to wetlands on the site would require permits and approvals from Ecology and Jefferson County, which would include conditions for wetland creation and adaptive management during the period of establishment. In regards to slope stability of the kettle pond on the site, the project geotechnical consultant inspected the side slopes of the large central kettle feature on the site (Kettle B), and reported "No clear evidence of landslides or smaller debris flows were observed along the margins of the kettle margins or on the steeper slopes in the upland portions of the project site" (Subsurface Group, LLC, December 17, 2008; Section 7.1.4). With construction to convert this kettle to a retention pond for stormwater and for Class A effluent from the wastewater treatment process, the existing 1.5H:1V side slopes would be flattened to create finished retention pond slopes of 3H:1V to 4H:1V, depending on the liner system selected for the project (Subsurface Group, LLC, December 17, 2008; Section 11.5.1). The Final Geotechnical Investigation report is included in Draft SEIS Appendix E. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 11 Exhibit 1 Comment 6 The project is proposing several minimization measures to limit potential impacts to fish and wildlife in the Point Black area. The project is leaving wildlife corridors (areas of undisturbed vegetation) throughout the golf course area. These corridors will lead to more than 200 acres of relatively undisturbed vegetation on and off site in addition to the existing and created wetland features. In addition, a fence will go up along the project boundary to limit elk access to the site. Also, according to the project engineer, cattle guards or similar device would be installed at the entries to further limit the potential of elk coming onto the property. For more information on fish and wildlife minimization measures, see the Habitat Management Plan Report (SEIS Appendix H). Comment 7 The Draft SEIS Section 3.2 (Water Resources, page 3.2-8) reports that the project applicant has complied with BoCC Ordinance No. 01-0128-08 Condition 63 (r), having prepared a draft Water Quality Monitoring Plan (included in Appendix F of the Draft SEIS) that requires monthly water collection and testing at three sites for offsite pollution, discharge, and/or contaminant loading in Pleasant Harbor. Pleasant Harbor Marina and Golf Resort proposes to participate in a program to monitor the potential impact of developments, both private and public, to the water quality of Pleasant Harbor. Performance standards would meet Washington Department of Ecology requirements per WAC 173-201A. The project proposes to coordinate with the Jefferson County Water Quality Department, the Washington State Department of Health, the Hood Canal Salmon Enhancement Group, and the University of Washington to verify acceptable standards for Pleasant Harbor. The proposed monitoring schedule provides for quarterly pre-construction monitoring, monthly monitoring during first and second year construction, quarterly monitoring thereafter in years 3 and 4, with monitoring frequency in year 5 to be determined. Results would be submitted in reports to the Jefferson County Water Quality Department. The Plan commits to notifying the Department immediately of any unacceptable results. In the event that unacceptable test results are found, the Plan states that all property owners surrounding Pleasant Harbor shall be considered partners and act to identify as closely as possible the source and cause. Adaptive management principles in the draft Water Quality Monitoring Plan provide for modifying the plan to add or remove sampling sites, modify the monitoring schedule, update or improve sampling techniques based on new technology, and/or revise parameters to reflect changes in environmental concerns. The draft Water Quality Monitoring Plan is included in Draft SEIS in Appendix F. The methodology and quality assurance guidelines would be established and submitted to the Jefferson County Water Quality Department for approval after the requirements and criteria for this program were approved. Stormwater management systems associated with Highway 101 and Black Point Road would be upgraded during widening and improvements proposed at the entrance to the Resort (see Draft SEIS Figure 2-9). Water quality treatment measures would be installed upstream of discharges from these roadways and from the proposed Marina Village to the unnamed stream that flows through this area of the site. Pervious pavement materials may also be used in the bus turn- around area and Maritime Village parking lot to treat and infiltrate stormwater that falls on these surfaces. These measures are intended to comply with applicable requirements and improve water quality discharges to Pleasant Harbor over existing conditions. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 12 Exhibit 1 Comment 8 A Stormwater Pollution Prevention Plan (SWPPP) would be developed and implemented as required under the National Pollution Discharge Elimination System (NPDES) stormwater regulations for construction sites. Construction techniques will utilize Best Management Practices (BMPs) to minimize potential impacts to species. In addition, the contractor will prepare a construction Spill Prevention, Control and Countermeasures (SPCC) Plan for the project according to Washington State Department of Transportation guidance. Any potential spills would be handled and disposed of in a manner that does not contaminate the surrounding area. Adequate materials and procedures to respond to unanticipated weather conditions or accidental releases of materials will be available on site. This will include materials necessary to isolate pollutants from the environment and contain and absorb spills. The SPCC Plan will also ensure the proper management of oil, gasoline and solvents used in the operation and maintenance of construction equipment, and that equipment remain free of external petroleum- based products prior to entering the work area and during the work, as well as for making any necessary repairs prior to returning the equipment to operation in the work area. The SPCC Plan will be consistent with 40 CFR 112.3 as well as the State of Washington Oil Spill Contingency Plan (WAC 173-182). Work would be in compliance with other local, state and federal regulations and restrictions, local critical areas ordinance and land use regulations, Shoreline Master Plan, State Environmental Policy Act, and 401 Water Quality Certification. The alternatives evaluated in this SEIS would not directly increase vessel traffic in Pleasant Harbor; however, all operations associated with the existing marina would be required to adhere to all applicable regulations related to water quality and vessel safety. As indicated in section 3.9 of this Final SEIS, no significant traffic safety issues are anticipated under the SEIS alternatives. Traffic volumes under the EIS alternatives would result in Levels of Service within acceptable limits, and would not be anticipated to result in an increase in vehicle accident rates. Comment 9 WAC 197-11-455(6) (SEPA Rules) indicates that the comment period for a Draft EIS shall be 30 days unless extended by the lead agency. WAC 197-11-455(7) indicates that the lead agency may grant an extension of up to 15 days. Consistent with SEPA rules, Jefferson County provided a 45-day comment period on the Draft SEIS (30-day requirement plus 15-day extension), the maximum length of comment period allowed in the SEPA Rules. In addition, as noted in the above response to Comment 1 of this letter, the opportunity to consult more directly with Jefferson County was given, and a meeting was held on February 18th, 2015. komp ARTMENT OF M-.°' HAEOLOGY&Allyson Brooks Ph.D..Director HiTORIC PRESERVATION State Historic Preservation Officer January 5, 2015 Mr. David Johnson AN 0 5 2Q 4 Associate Planner Jefferson County n^4 .,p ` t u 621 Sheridan Street Ake '`W 1'° Port Townsend,WA 98368 i' In future correspondence please refer to: Log: 081106-13-JE Property: Request for Comments on DSEIS for Pleasant Harbor Marina and Golf Mater Planner Resort, Case nos. MLA08-00188,ZOON08-00056 Re: Archaeology-DSEIS Comments Dear Mr. Johnson: Thank you for contacting the Washington State Department of Archaeology and Historic Preservation DAHP). Please make sure that the attached Cultural Resources Management Plan(monitoring and inadvertent discovery plan)is included and followed during any development activities. A professional archaeological monitor must be present for any ground disturbing activities in the areas designated for archaeological monitoring per the attached document which was agreed upon by DAHP and the Tribes. Thank you for the opportunity to review and comment. Sincerely, 1/L,,.-_.. Gretchen Kaehler Local Governments Archaeologist 360)586-3088 gretchen.kaehler(&dahp.wa.gov cc. Gideon Kauffman,Archaeologist,Jamestown S'Klallam Bill White, Archaeologist, Lower Elwha Klallam Tribe Josh Wisniewski, THPO,Port Gamble S'Klallam Tribe Kris Miller,THPO, Skokomish Tribe Rhonda Foster,THPO, Squaxin Island Tribe Dennis Lewarch,THPO, Suquamish Tribe 0 stArk op State of Washington • Department of Archaeology&Historic Preservation 8, uP.O. Box 48343 • Olympia,Washington 98504-8343 • (360) 586-3065 x www.dahp.wa.gov '•t yor k1 1889 49 1 Cultural Resource Consultants, Inc. PROPOSED PLAN FOR ARCHAEOLOGICAL MONITORING AND INADVERTENT DISCOVERY PROTOCOL, ARCHAEOLOGICAL MONITORING AT PLEASANT HARBOR MARINA JEFFERSON COUNTY,WASHINGTON AUTHOR:Glenn D. Hartmann DATE: January 12, 2012, revised February 7, 2012, March 27, 2012 LOCATION: Jefferson County, Washington T,R,S: Township 25 North, Range 2 West, Section 15 and 22, Willamette Meridian. PREPARED FOR:Don Coleman Pleasant Harbor Marina 308913 Hwy 101 Brinnon, WA 98320 Pleasant Harbor Marina is requesting periodic archaeological monitoring of construction excavations and other below-fill ground-disturbing activities in Brinnon, Jefferson County, Washington. The Pleasant Harbor Master Planned Resort is proposed on approximately 257 acres of the 710-acre Black Point Peninsula along the western side of the Hood Canal. The peninsula is surrounded on the north, south, and east by the waters of Hood Canal. Pleasant Harbor is formed by the west shore of Black Point and the east shore of the mainland. Background Prior archaeological field investigations of the project area did not result in the identification of any prehistoric or historic archaeological resources(Mather et al. 2006; Berger 2008). Subsurface investigations focused on archaeologically sensitive landforms; that is, those environments most likely to contain naturally buried archaeology identified in collaboration with cultural resources staff of the Skokomish Tribe (e.g., kettles, vantage points, the bluff edge). High probability areas in Black Point where buried archaeological deposits might occur (i.e., kettle margins and bases) were sampled using hand-excavated shovel probes. Locations of all probes, shovel scrapes, and wall profiles were mapped on a small-scale project area topographic map (see Mather et al. 2006: Figure 16). In all, 93 shovel probes/scrapes were excavated during the 2006 field investigations with 27 probes along the southern bluff, 12 probes on high points, 22 probes in kettle basins and 32 probes along the kettle margins and rims. In addition wall profiles were faced in order to assess the local stratigraphy. Subsequent to the initial cultural resource assessment for the project, Berger(2008)conducted archaeological monitoring during geotechnical assessment. Archaeological monitoring of geotechnical explorations did not result in the identification of any evidence of archaeological sites, historic structures, or other features. Conditions and sediments observed during this 710 ERICBSEN AVENUE NE,SUITE 100 PO Box 10668,BAINBRIDGE ISLAND,WA 98110 PHONE 2O6 855-9020 - info@crewa.com episode of archaeological monitoring suggested a low probability for as-yet unidentified archaeological sites. Archaeological Monitoring Archaeological monitoring will include an orientation for the construction crew and machine operators prior to initiating construction. Project personnel would be made aware of the potentials of archaeology within the project area. They will be apprised of their responsibilities during archaeological monitoring, their obligations in the case of an inadvertent discovery and they will be made aware of the inadvertent discovery plan and protocol. Periodic archaeological monitoring is planned during construction excavations and other below- fill ground-disturbing project actions to minimize potential effects to any as-yet unknown human remains and/or intact archaeological deposits. Monitoring would occur at those locations within the project area that have previously been identified as high probability—kettles, vantage points, the bluff edge—if sediments in these landforms will be affected by ground-disturbing construction. Presently available plans indicate that construction would not occur along the bluff edge. Project maps were reviewed and high probability locations were identified using the earlier analyses of the project area(Mather et al. 2006; Berger 2008), which had tested and monitored geotechnical explorations in these locations (Figure 1). Those areas with greater archaeological potentials were mapped on topographic maps of the project area(Figures 2 and 3). Monitoring is planned for the high probability areas until it can be determined with greater assurance that continual monitoring is not necessary. Monitoring results would be reviewed with DAHP staff and tribal representatives prior to adjusting the monitoring schedule. Archaeological monitoring would entail having an archaeologist present during construction excavation below-fill to observe subsurface conditions and identify any buried archaeological materials that may be encountered. Monitoring will be performed either by a"professional archaeologist" (RCW 27.53.030 (8))or under the supervision of a professional archaeologist. The monitoring archaeologist would stand in close proximity to construction equipment in order to view subsurface deposits as they are exposed, and would be in close communication with equipment operators to ensure adequate opportunity for observation and documentation. Archaeological monitoring will seek to identify potential buried surfaces, anthropogenic sediments, and archaeological features such as shell middens, hearths, or artifact-bearing strata. The monitoring archaeologist will inspect project excavations and the recovered sediments for indications of such archaeological resources.The archaeologist will be provided the opportunity to screen excavated sediments and matrix samples when this is judged useful to the identification process. It is not expected that modem fill (e.g., imported culturally-sterile construction fill) or glacial till sediments would be included in screening procedures. Excavated spoils may be examined in the course of monitoring. If cultural materials are observed in spoils piles, it is expected that these would be removed for examination and that the opportunity to screen spoil sediments would be available. CRC Proposed Plan for Archaeological Monitoring and Inadvertent Discovery Protocol 1111L, Pleasant Harbor Marina, Jefferson County,WA Page 2 Archaeological monitoring of construction excavation will proceed until it can be determined with a greater level of confidence that human remains or other cultural resources are not likely to be impacted by construction excavation of the project. The archaeologist will conduct monitoring until native and fill deposits can be confidently isolated and identified based on observed sedimentary exposures. Upon completion of the monitoring, the archaeologist will prepare a report on the methods and results of the work, and recommendations for any necessary additional archaeological investigations, illustrated with maps, drawings, and photographs as appropriate. Contingency Plan In accordance with RCW 27.44 Indian Graves and Records Act, RCW 27.53 Archaeological Sites and Resources, RCW 68.50 Human Remains, and RCW 68.60, Abandoned and historic cemeteries and historic graves, the following protocols will be followed in the event that archaeological materials and/or human remains are discovered: Procedures Upon Discovery of Potential or Actual Cultural Resources 1. Upon discovery of a potential or actual archaeological site, or cultural resources as defined by RCW 27.44 Indian Graves and Records Act, and RCW 27.53 Archaeological Sites and Resources, Pleasant Harbor Marina, its employees,its contractors and sub-contractors shall: a) Immediately cease or halt ground disturbing, construction, or other activities around the area of the discovery and secure the area with a perimeter of not less than thirty(30) feet until all procedures are completed and the parties agree that activities can resume. If such a perimeter would materially impact agency functions mandated by law, related to health, safety or environmental concerns, then the secured area shall be of a size and extent practicable to provide maximum protection to the resource under the circumstances. Project activities that are not ground disturbing may continue outside the secured perimeter around the findings. No one shall excavate any findings and all findings will be left in place, undisturbed and without analysis, until consultation with DAHP and the Tribe regarding a final disposition of the findings has been completed. In accordance with RCW 27.53.060, no one shall knowingly remove or collect any archaeological objects without obtaining a permit. b)Notify the Local Government Archaeologist at DAHP and the Tribes of the discovery as soon as possible, but in any event, no later than (24) hours of the discovery. If human remains are found, Pleasant Harbor Marina shall follow notification procedures specified below(see "Human Remains and Associated Funerary Objects"). c) Arrange for the parties to conduct a joint viewing of the discovery within (48) forty- eight hours of the notification, or at the earliest possible time thereafter, Pleasant Harbor Marina or their authorized representative shall arrange for the archaeologist to attend the joint viewing. After the joint viewing, taking into account any recommendations of the Tribe(s), DAHP, and the archaeologist, the parties shall discuss the potential significance, if any, of the discovery. CRC Proposed Plan for Archaeological Monitoring and Inadvertent Discovery Protocol 1111L, Pleasant Harbor Marina, Jefferson County,WA Page 3 d)Consult with the Tribes and DAHP on the transfer and final disposition of artifacts. Until the Tribe has a repository that meets the standards of curation established 36 CFR Part 79, artifacts shall be curated using an institution or organization that meets curation standards, selected through consultation with the Tribe. Inadvertent Discovery of Human Skeletal Remains on Non-Federal and Non-Tribal Land in the State of Washington (RCWs 68.50.645,27.44.055,and 68.60.055) 2. If ground-disturbing activities encounter human skeletal remains during the course of construction,then all activity must cease that may cause further disturbance to those remains and the area of the find must be secured and protected from further disturbance. In addition, the finding of human skeletal remains must be reported to the Jefferson County Coroner's Office and Jefferson County Sheriffs Office in the most expeditious manner possible. The remains should not be touched, moved, or further disturbed. 3. The Jefferson County Coroner's Office will assume jurisdiction over the human skeletal remains and make a determination of whether those remains are forensic or non-forensic. If the county coroner determines the remains are non-forensic,then they will report that finding to the Department of Archaeology and-Historic Preservation (DAHP)who will then take jurisdiction over the remains and report them to the appropriate cemeteries and affected tribes.The State Physical Anthropologist will make a determination of whether the remains are Indian or Non- Indian and report that finding to any appropriate cemeteries and the affected tribes. The DAHP will then handle all consultation with the affected parties as to the future preservation, excavation, and disposition of the remains. 4. DAHP will handle all consultation with the affected parties as to the future preservation, excavation, and disposition of the remains if there is no federal agency involved. Confidentiality of Information 5. Pleasant Harbor Marina or their authorized representative recognizes that archaeological properties are of a sensitive nature and sites where cultural resources are discovered can become targets of vandalism and illegal removal activities. Pleasant Harbor Marina or their authorized representative shall keep and maintain as confidential all information regarding any discovered cultural resources, particularly the location of known or suspected archaeological property, and exempt all such information from public disclosure consistent with RCW 42.17.300. 6. Pleasant Harbor Marina or their authorized representative shall make its best efforts to ensure that all records indicating the location of known or suspected archaeological properties are permanently secured and confidential. 7. Pleasant Harbor Marina or their authorized representative shall ensure that its personnel, contractors, and permittees keep the discovery of any found or suspected human remains, other cultural items, and potential historic properties confidential, including but not limited to, refraining such persons from contacting the media or any third party or otherwise sharing information regarding the discovery with any member of the public. Pleasant Harbor Marina or CRC Proposed Plan for Archaeological Monitoring and Inadvertent Discovery Protocol 1111.L, Pleasant Harbor Marina,Jefferson County,WA Page 4 their authorized representative shall require its personnel, contractors and permittees to immediately notify the Lead Representative of Pleasant Harbor Marina or their authorized representative of any inquiry from the media or public. Pleasant Harbor Marina or their authorized representative shall immediately notify DAHP of any inquiries it receives. Prior to any public information release, Pleasant Harbor Marina or their authorized representative, DAHP, and the Tribe(s) shall concur on the amount of information, if any, to be released to the public, any third party, and the media and the procedures for such a release, to the extent permitted by law. Lead Representative and Primary Contact 8. The lead representatives and primary contacts of each party under this plan are as identified below. The parties may identify other specific personnel before the commencement of any particular project element as the contacts. Pleasant Harbor Marina 308913 Hwy 101 Brinnon, WA 98320 Primary Contact: Don Coleman, Maintenance and Security Supervisor, 206-714-1482 Pleasant Harbor Marina 7370 Sierra Morena Blvd. S.W. Calgary, Alberta Primary Contact: M. Garth Mann, President&C.E.O, 403-256-4151 Jamestown S'Klallam Tribe 1033 Old Blyn Highway Sequim, WA 98382 Primary Contact: Gideon Kauffman Lower Elwha Klallam Tribe 2851 Lower Elwha Rd Port Angeles, WA 98363 Primary Contact: Bill White, Cultural Resources Port Gamble S'Klallam Tribe 31912 Little Boston Rd NE Kingston, WA 98346 Primary Contact: Josh Wisniewski Ph.D. Skokomish Tribe North 80 Tribal Center Rd Skokomish, WA 98584 Primary Contact: Kris Miller, Cultural Resources Squaxin Island Tribe CRC Proposed Plan for Archaeological Monitoring and Inadvertent Discovery Protocol 1111L, Pleasant Harbor Marina, Jefferson County,WA Page 5 SE 10 Squaxin Lane Shelton, WA 98584 Primary Contact: Rhonda Foster Suquamish Tribe 15838 Sandy Hook Rd PO Box 498 Suquamish, WA 98392-0498 Primary Contact: Stephanie Trudel Washington Department of Archaeology and Historic Preservation PO Box 48343 Olympia, WA 98504-8343 Lead Representative: Allyson Brooks, State Historic Preservation Officer, 360-586-3066 Primary Contact: Gretchen Kaehler, Local Government Archaeologist, 360-586-3088 Primary Contact for Human Remains: Guy Tasa, State Physical Anthropologist, 360-586-3534 Jefferson County Coroner's Office PO Box 1220 Port Townsend, WA 98368 Lead Representative: Scott W. Rosekrans, Prosecuting Attorney/Coroner, 360-385-9180 Jefferson County Sheriffs office 79 Elkins Road Port Hadlock, WA 98339 Lead Representative: Tony Hernandez, Sheriff, 360-385-3831 Department of Community Development 621 Sheridan Street Port Townsend, WA 98368 Lead Representative: David W. Johnson, 360-379-4465 Cultural Resource Consultants,Inc. 710 Ericksen Avenue NE, Suite 100 PO Box 10668 Bainbridge Island, WA 98110 Lead Representative: Glenn Hartmann, Senior Archaeologist/Principal, 206-855-9020 References Cited Berger, Margaret 2008 Archaeological Monitoring of Geotechnical Explorations for the Pleasant Harbor Golf Resort, Jefferson County, Washington. Technical Memo 0804A-1, Cultural Resource Consultants, Bainbridge Island. Mather, Camille, Jennifer Chambers, James Schumacher, and Matthew Gill CRC Proposed Plan for Archaeological Monitoring and Inadvertent Discovery Protocol 1111L, Pleasant Harbor Marina,Jefferson County,WA Page 6 2006 Cultural Resources Assessment for the Proposed Pleasant Harbor Marina and Golf Resort, Jefferson County, Washington. WSHS Technical Report#274. Prepared for Statesman Corporation. On file at Cultural Resource Consultants, Inc., Bainbridge Island. CRC Proposed Plan for Archaeological Monitoring and Inadvertent Discovery Protocol 1111L, Pleasant Harbor Marina,Jefferson County,WA Page 7 an u-.,` care i li coa 1 00,a 4. tWf rYplri11'14" iR F° 91u:{=• i r OW P.Att ip••• '" r0...,4, r e 4'i.nr9 fi rM e - 11wFhNr njY ff i M MYC.+Wi !1 wows YLPh "W`s.yy} MACYY Mea/**. wt NifV'.Yi.YMIw 1OVr y1 RO wVYM4A110, MW t y 4tlwt ......5[ Rf { y+ at M.M.R r[ 11 , .,aw. .. h sV f 1. Ye. SaL?SiwZ. •r.- a. t w4Y t 'r Figure 1.Previous testing(Mather et al 2006)identified high probability areas. CRC Proposed Plan for Archaeological Monitoring and Inadvertent Discovery Protocol 7111L, Pleasan Jefferson County,WA Page t3 eY I y'' 'I 'Y I ` I I YN err t I '1-1' rb%., df g 9 s ti r iia PLEASANT HARBOR MARINA&GOLF COURSE SECTIONS 15&22.TOWNSHIP 25N.,RANGE.2W,W.M. i J Figure 2.High probability areas identified for monitoring(outlined in red)based on previous analyses of the project area(Mather et al.2006). CRC Proposed Plan for Archaeological Monitoring and Inadvertent Discovery Protocol 1111L,Pleasant Harbor Manna,Jefferson County,WA Page 9 PLEASANT HARBOR MARINA&GOLF COURSE F yy y SECTIONS 15&R2,TOWNSHIP 25N.,RANGE 2W.W M. v i r tit* 1, a aurxc,. r{ r e c R 1r C E yAj't iI 1 T, Cd, _ s e Ripka c r',i r a x 11 9 c YYY i' 1 f' r .rl M f 7 q r f d fly M M1 N t} yyam . . 7,7 i f ` i'" , n t ti FAIRWA._.N ---- r 1'-' 1 4 i xr y ` Figure 3.Areas to be monitored(outlined in red)include wetlands,kettles,and vantage points(after Mather et al.2006). CRC Proposed Plan for Archaeological Monitoring and Inadvertent Discovery Protocol 11111,Pleasant Harbor Manna,Jefferson County,WA Page 10 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 14 Exhibit 1 RESPONSE TO COMMENTS FROM WASHINGTON STATE DEPARTMENT OF ARCHAEOLOGY AND HISTORIC PRESERVATION (Letter # 4) Comment 1 Thank you for your comments. The archaeological monitoring plan attached to the letter was included in the Draft SEIS as Appendix O. Adherence to this plan is identified as an applicable condition of the project [63(k)] by the Jefferson County Board of County Commissioners in Section 3.13 of the Draft and Final SEIS. STATE OF WASHINGTON DEPARTMENT OF ECOLOGY PO Box 47775 •Olympia, Washington 98504-7775 •(360} 407-6300 711 for Washington Relay Service •Persons with a speech disability can call 877-833-6341 January 5, 2015 Tr-1 JAN052t11k Mr. David Wayne Johnson Jefferson County tai iii i i1CommunityDevelopmentDepartmentEfLv %• 621 Sheridan Street Port Townsend, WA 98368 Dear Mr. Johnson: Thank you for the opportunity to comment on the draft supplemental environmental impact statement for the Pleasant Harbor Marina and Golf Resort LLC Master Planned 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. The Department of Ecology Ecology)reviewed the information provided and has the following comment(s): SHORELANDS & ENVIRONMENTAL ASSISTANCE: Rick Mraz (360)407-6221 Prior comments were provided regarding wetlands on October 24, 2007(see enclosure). They included the following information: Placement of fill in wetlands may require an individual or general (nationwide)permit from the U.S. Army of Corps of Engineers (Corps). We advise the applicant to contact the Corps to determine if a permit is needed. Should an individual Corps permit be required, a water quality certification will also be required from Ecology. If the wetland is determined to be isolated and not subject to the Corps jurisdiction, it remains a jurisdictional wetland for Ecology, and will require permitting by this agency. For more information, please contact Rick Mraz, Wetland and Shoreline Specialist at the phone number given above. WATER QUALITY: Deborah Cornett (360) 407-7269 Erosion control measures must be in place prior to any clearing, grading, or construction. These control measures must be effective to prevent stormwater runoff from carrying soil and other pollutants into surface water or stormdrains that lead to waters of the state. Sand, silt, clay particles, and soil will damage aquatic habitat and are considered to be pollutants. Any discharge of sediment-laden runoff or other pollutants to waters of the state is in violation of Chapter 90.48 RCW, Water Pollution Control, and WAC 173-20IA, Water Quality Standards for Surface Waters of the State of Washington, and is subject to enforcement action. 1 2 January 5, 2015 Page 2 The following construction activities require coverage under the Construction Stomiwater General Permit: 1. Clearing, grading and/or excavation that results in the disturbance of one or more acres and discharges stormwater to surface waters of the State; and 2. Clearing, grading and/or excavation on sites smaller than one acre that are part of a larger common plan of development or sale, if the common plan of development or sale will ultimately disturb one acre or more and discharge stormwater to surface waters of the State. a) This includes forest practices(including, but not limited to, class IV conversions) that are part of a construction activity that will result in the disturbance of one or more acres, and discharge to surface waters of the State; and 3. Any size construction activity discharging stormwater to waters of the State that Ecology: a) Determines to be a significant contributor of pollutants to waters of the State of Washington. b) Reasonably expects to cause a violation of any water quality standard. If there are known soil/ground water contaminants present on-site, additional information including, but not limited to: temporary erosion and sediment control plans; stormwater pollution prevention plan; list of known contaminants with concentrations and depths found; a site map depicting the sample location(s); and additional studies/reports regarding contaminant(s))will be required to be submitted. You may apply online or obtain an application from Ecology's website at: http://www.ecy.wa.gov/programs/wq/stormwater/construction/ - Application. Construction site operators must apply for a permit at least 60 days prior to discharging stormwater from construction activities and must submit it on or before the date of the first public notice. Ecology's comments are based upon information provided by the lead agency. As such, they may not constitute an exhaustive list of the various authorizations that must be obtained or legal requirements that must be fulfilled in order to carry 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 of Ecology Southwest Regional Office SM:14-5991) Enclosure cc: Deborah Cornett, WQ Rick Mraz, SEA Joyce Smith, HQ/WQ Pleasant Harbor Marina and Golf Resort, LLC (Proponent) 3 4 5 Tart F- i a .: 2 STATE OF WASHINGTON DEPARTMENT OF ECOLOGY PO Box 47775•Olympia,Washington 98504-7775• (360) 407-6300 i October 24,2007 4 1 Ms. Stack Hoskins,Planning Manager 1 Your address 4 Jefferson County U1r is in the i Community Development Department j Skokomish- 621 Sheridan Street ja rl Dosewallips Port Townsend,WA 98368 watershed Dear Ms. Hoskins: 4' Thank you for the opportunity to comment on the Draft Environmental Impact Statement(DEIS)for the Pleasant Harbor Marina and Golf Course,Master Planned Resort project(File No.MLA06-87) located south of Brinnon at Us Highway 101 and Black Point Road as proposed by Statesman Group of Companies,US Head Office. The Department of Ecology(Ecology)reviewed the environmental checklist and has the following comment(s): FLOODPLAINS: Kevin Farrell(360) 407-7253 Ecology's Floodplain Management Program would like to remind Jefferson County of their obligation under the National Flood Insurance Program(NFIP)to regulate development within the FEMA identified 100-year floodplain. While this DEIS is based on a"non-project",further review should be conducted in the event the proposal moves into an implementation phase to ensure any development within the 100-year floodplain meets Federal,State,and local codes. SOLID WASTE& FINANCIAL ASSISTANCE: Al Salvi(360)407-6287 The applicant should consider designing and constructing the facility so opportunities to recycle are at least as convenient as waste disposal. Space should be provided inside and outside the facility to accommodate equipment and containers for processing and storage of recyclables. Materials such as paper,glass, aluminum and other metals,corrugated containers,and plastics should be recycled. Please consider the use of low-toxic building products and finishes,and incorporating building materials that have been salvaged or are made from recycled materials to the greatest extent possible in the project. Please call Rachael Jamison at(360)407-6352 for more information. The applicant should consider designing the waste water treatment facility and golf course to use the treated water for irrigation on the golf course. TOXICS CLEANUP: Chuck Cline(360)407-6267 1 If contamination is currently known or observed during construction or soil removal(placement), sampling of the potentially contaminated media must be conducted. If contamination of soil or ' s 411110-• 0 October 24,2007 Page 2 groundwater is readily visible, or is revealed by sampling,Ecology must be notified. Contact the Environmental Report Tracking System Coordinator at the Southwest Regional Office at(360) 407-6300. For assistance and information about subsequent cleanup and to identify the type of testing that will be required contact Chuck Cline. If contamination is identified,this issue may be referred to your jurisdictional health department as a solid waste concern. This site is presently undergoing review as a Voluntary Cleanup Program site. Scott Rose is the site manager and will provide an opinion letter addressing Toxics Cleanup issues. Scott can be contacted at(360)407-6347. WATER QUALITY:Deborah Cornett(360)407-7269 The project mentions on pages iv and 3-10 that an NPDES permit for construction is needed and will be obtained. As noted, a permit is required if the project is one acre or greater, and there is a discharge of stormwater. Discharges to surface waters include,but are not limited to, roadside ditches,possibly the kettles on site,wetlands,and the intermittent streams identified on the site as well as Hood Canal. Sources of discharge can include tracking dirt off site,which is often overlooked as a potential discharge. To apply for the Construction Stormwater NPDES General Permit(Permit),the application,or Notice of Intent(NOD shall be submitted on or before the date of the first public notice(a different notice than SEPA)and at least at least 60 days prior to the discharge of stormwater from construction activities. The Stormwater Pollution Prevention Plan(SWPPP)developed for this site must be in compliance with Section S. 9 of the Permit as well as Jefferson County regulations. WATER RESOURCES: Phil Crane(360)407-0238 The proponent states they have existing water rights of up to 28 acre-feet that will provide water for the project up to Phase 2. There is no discussion of the extent and validity of the rights so Ecology cannot determine whether these rights are adequate for the initial phase. The proponents have filed new applications for both ground water and surface water that, if approved,would be adequate for the project. WETLANDS: Rick Mraz(360)407-6221 After preliminary review of the.DETS for the Brinnon Master Planned Resort(MPR)I note that the proposal includes fill and possible hydrologic alteration of wetlands determined to be isolated by the U.S.Army Corps of Engineers(Corps). However,the DEIS document does not reference the state wetlands permit processor acknowledge that state authorization is required for these wetland impacts. Any project that calls for filling or altering a wetland determined by the Corps to be isolated will still be subject to regulation by the state. The state's process for reviewing projects that involve isolated wetlands will be different from the 401 Water Quality Certification process that is triggered by the Corps 404 permit. Rather,Ecology will use administrative orders to regulate projects that will have impacts to isolated wetlands. The standards of review will remain the same as under 401 water-quality certifications-that is,the state water-quality standards for surface waters(WAC 173-201A). October 24,2007 Page 3 To seek an administrative order for this project,which proposes to fill or impact isolated wetlands,the proponent should contact the Office of Regulatory Assistance (ORA),where their staff will guide you through the regulatory process. ORA staff can be reached at(360)407-7037, 1-800-917-0043 or via e-mail at assistanceaora.wa.gov. s Ecology's comments are based upon information provided by the lead agency. As such,they do not constitute an exhaustive list of the various authorizations that must be obtained or legal requirements k that must be fulfilled in order to carry 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 of Ecology Southwest Regional Office A W:07-7250) cc: Chuck Cline,TCP Deborah Cornett,WQ Phil Crane, WR Kevin Farrell,SEA Rick Mraz, SEA Scott Rose,TCP Al Salvi, SWFAP Karen Barrows,Jefferson County Statesman Group of Companies,US Head Office (Proponent) Statesman Group of Companies,Corporate Head Office 1 1 4 f; 4 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 16 Exhibit 1 RESPONSE TO COMMENTS FROM WASHINGTON STATE DEPARTMENT OF ECOLOGY (Letter #5) Comment 1 Thank you for your comments, your comments are acknowledged. The Corps has been contacted and they have issued a jurisdictional determination that the three identified wetlands on the site (Wetlands B, C and D) are isolated. Comment 2 Draft SEIS Section 3.2 (Water Resources) and the Grading and Drainage Engineering Report (Peck & Associates, May 16, 2012) included in Appendix E of the Draft SEIS acknowledge and commit to complying with applicable Federal, State and County regulations for erosion control and the control of stormwater runoff during construction, including Department of Ecology requirements. See Appendix E of the Final SEIS for further details. Comment 3 Draft SEIS Section 3.2 (Water Resources) and the Grading and Drainage Engineering Report (Peck & Associates, May 16, 2012) included in Appendix E of the Draft SEIS acknowledge and commit to obtaining and complying with a National Pollutant Discharge Elimination System (NPDES) permit from the Washington Department of Ecology for each phase of site development. Comment 4 There are no known soil/groundwater contaminants present onsite. Existing septic tanks would be decommissioned as required by County and State regulations. Comment 5 Thank you for your comments. It is acknowledged that this letter does not constitute a complete list of all necessary authorizations and legal requirements. BTATe 0 o Wm n= Hy 1889 lk STATE OF WASHINGTON DEPARTMENT OF HEALTH SOUTHWEST DRINKING WATER REGIONAL OPERATIONS PO Box 47823, Olympia, Washington 98504-7823 TDD Relay 1-800-833-6388 tf- December 29, 2014 j--)1 DEC 3 1 2014 David Wayne Johnson Jefferson County DCD Pleasant Harbor DSEIS c'NT 621 Sheridan Street Port Townsend,Washington 98368 Subject: Pleasant Harbor Draft Supplemental Environmental Impact Statement,November 2014 Dear David Wayne Johnson: Thank you for the opportunity to comment on the Pleasant Harbor Draft Supplemental Environmental Impact Statement(DSEIS). The State Department of Health, Office of Drinking Water(ODW)regulates Group A public water systems under state law and will,therefore,be responsible for approving the public water system proposed to serve the Pleasant Harbor Master Planned Resort. Consistent with this responsibility, ODW offers the following comments: 1. Page 3.16-4, Water System Ownership. It states,"...it is anticipated that a multi-purpose utility district would own, operate, and maintain the new water system." ODW Comment: ODW strongly supports the idea of having the water system owned and operated by a public utility district or satellite management agency. 2. Table 3. 18-1,Fulfilment of Jefferson County Board of County Commissioner's Conditions. This table contains the following information: BoCC# Description Notes Status N Approval of a Class A Water Water rights permit G2-30436 Fulfilled System by the Washington granted for(3)wells on the Pleasant Department of Health, and Harbor site—(1)year round approval of Water Rights domestic& commercial,(2)summer Certificate by the Department irrigation—total of 300 gallons per of Ecology shall be required minute. See Section 3.16,Utilities, prior to applying for any of this SEIS for additional detail. Jefferson County permits for plats or any new development. ODW Comment: While the water right permit has been issued for the proposed project,approval of the water system by ODW has not yet occurred. Please discuss how and when this requirement will be met. i,? 1 2 David Wayne Johnson December 29, 2014 Page 2 3. Water Use Assumptions. The DSEIS includes a water use assumption of 175 gallons per day per equivalent residential unit(gpd/ERU)for the proposed Master Planned Development. ODW Comment: Water system demands for new systems must meet requirements of Section 5.2 of the Water System Design Manual(WDSM). Average and maximum day water demands will be approved based on design criteria presented at the time of the water system project approval submittals. 4. Setbacks for Drinking Water Wells. ODW Comment: Any new public drinking water well must maintain a 100-foot sanitary control area(SCA)free of potential contaminants such as roads, buildings, and chemical applications. 5. Page 1-35, Existing Black Point Camp Water System. It states, "Because there is a limited rental housing market, it is proposed that the out-of-town construction crews may use the existing on-site 60-unit RV facility." ODW Comment: The water system serving the existing, inactive, on-site 60- unit RV facility is not suitable for potable use. As described on Page 3.16,operation and maintenance of the aged water system has abated. The system is highly deteriorated and not fully functional. In order to reactivate the water system,ODW would have to review and approve a project report and construction documents describing how the water system would be upgraded to meet current requirements. 6. Table 3.11-5,Number of Employees to Serve the Proposed Master Planned Resort(MPR). This table contains a projection of required"Waste Water"employees to serve the proposed development. ODW Comment: The number of employees to serve the Pleasant Harbor Master Planned Resort should include an estimate of staff required to operate and maintain the drinking water system. Sincerely, r, Susan Clark Office of Drinking Water,Regional Planner cc: Jefferson County Department of Community Development Jefferson County Health Department 3 4 5 6 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 18 Exhibit 1 RESPONSE TO COMMENTS FROM THE WASHINGTON STATE DEPARTMENT OF HEALTH (Letter # 6) Comment 1 Comment acknowledged. A new water system on the site would be required to comply with the Jefferson County Coordinated Water System Plan Section 5.6 Utility Service Review Procedure. Section 3.16 (Utilities) of the Final SEIS has been updated to clarify this requirement (page 3.16-4). Comment 2 Water system plans have been submitted to the Washington Department of Health. Water system permitting is ongoing at the time of this writing. A new water system on the site would acquire all necessary approvals from the Washington State Department of Health, Office of Drinking Water. Comment 3 BoCC Ordinance No. 01-0128-08 Condition 63 (o) requires analysis of the potable water supply requirements of the Resort to be based on 175 gallons per day (gpd) per equivalent residential unit (ERU). It is acknowledged that during phased design and development of the project, actual water use would be monitored. If it can be shown that water system demands can meet the requirements of Section 5.2 of the State's Water System Design Manual at a rate less than 175 gpd/ERU, the Department of Health may allow modification of design criteria; for example, it may be possible to reduce the size of phased development of water storage facilities. This issue would be addressed in the Comprehensive Water System Plan to be submitted to the Washington State Department of Health. Comment 4 Mitigation measures listed in the Section 3.16 of the Draft SEIS included complying with all applicable Jefferson County and Washington State Department of Health regulations for water system construction and operation (page 3.16-8). This includes maintaining a minimum 100-foot sanitary control area around any new drinking water wells. Refer to Section 3.16 of the Final SEIS for further details. Comment 5 Comment acknowledged. The Comprehensive Water System Plan to be reviewed and approved by the Washington State Department of Health will identify the need to upgrade the existing Black Point Camp water system in advance of using the camp to house out-of-town construction crews. An engineering design report and construction documents would be provided to the Department of Health for review and approval prior to making these improvements. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 19 Exhibit 1 Comment 6 The Comprehensive Water Plan and General Sewer Plan (subject to review and approval by the Washington State Department of Health and Department of Ecology) propose that the staff required to operate and maintain the Resort drinking water system would be the same staff as those who would operate and maintain the wastewater collection and treatment system. These staff members would obtain the required certifications for both positions. From:David W. Johnson To:Garth Mann ; peckassoc@comcast.net Cc:Schipanski, Rich; Hollinger, Kristy ; David W. Johnson Subject:FW: Pleasant Harbor Draft Supplemental Environmental Impact Statement (DSEIS) Date:Wednesday, January 07, 2015 4:42:48 PM Attachments:image003.png Final DESIS Notice of Availability.pdf Comments from the Department of Transportation. From: Severson, Dale [mailto:SeversD@wsdot.wa.gov] Sent: Wednesday, January 07, 2015 4:39 PM To: David W. Johnson Cc: Carl Smith; Michael Read, PE Subject: RE: Pleasant Harbor Draft Supplemental Environmental Impact Statement (DSEIS) Hi David, WSDOT is fine with the proposed DSEIS. As noted below from the DESIS the WSDOT requested intersection improvements at Black Point Road intersection are listed as a Phase 1 condition. So the WSDOT concerns have been addressed. Please be aware to build those intersection improvements a three party (WSDOT, County, and Developer) WSDOT Developer Agreement will be needed from my office since some of the intersection work will be on County right-of-way. The Developer Agreement is the construction document needed after the design has been reviewed and approved by WSDOT that then allows the developer Pleasant Harbor to build the US 101 highway improvements. If utilities need to be installed and/or relocated a separate Utility Permit or Utility Franchise may be needed. Also, any private access / driveway changes to/from US 101 would need an Access Connection Permit from WSDOT. Thanks for letting us review this project. Dale C. Severson, P.E. Development Services Engineer - WSDOT Olympic Region (360) 357-2736 | dale.severson@wsdot.wa.gov 1 2 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 21 Exhibit 1 RESPONSE TO COMMENTS FROM THE WASHINGTON STATE DEPARTMENT OF TRANSPORTATION, OLYMPIC REGION (Letter # 7) Comment 1 Thank you for your comments. Comment 2 Because proposed intersection work would occur on Jefferson County right-of-way, it is acknowledged that a three party agreement between WSDOT, Jefferson County and the applicant will be required. David W. Johnson From: Barbara Moore-Lewis <brinnongroup© gmail.com> Sent: Friday, January 02, 2015 11: 11 AM To: David W. Johnson Subject:Fwd: Brinnon Group Comments on DSEIS Attachments: DSEIS summaryBG(6)1227.pdf; Destination_Resort_Impact_Study (1).pdf; waterworksConsultantsWaterReview(1).pdf; Silver Tip Solutions.pdf; walmart.pdf David, Attached are Brinnon Group comments on the DSEIS. Comments are organized into 1) issues in the DSEIS,JAN 0 2 2014 2) mitigation proposed in the DSEIS that is inadequate, and 3) recommendations for adequate mitigation. JEFFi4.14%:,d.. Fr 53a Also attached are supporting documents to our analysis of the DSEIS. All of the attachments are part of the public record and must appear there entirely. Attached are the Brinnon Group summary The Destination Resort Impact Study The UC Berkeley Institute for Research on Labor and Employment study on the impact of Walmart stores Water Review by Waterworks Consultants Water Review by Silvertip Solutions We'd like to state for the record that DCD refused to extend the public comment period despite requests from a number of citizens, giving the developer 5 1/2 years to prepare the DSEIS and the public 45 days (with 3 major holidays)to analyze and respond.. The county has a goal of improving tourism revenue in south county. This proposed resort does not meet that goal. It will pay mainly poverty level wages and will drive down the level of wages in the surrounding area. It will cost the few taxpayers (many on fixed incomes) in this small county more in taxes for infrastructure, life safety services, and social services than it returns in revenue. It may raise utility rates for south county. It degrades the unique environment that is economically important to the whole peninsula. It damages or depletes the entire Black Point aquifer. If the preferred "no action" alternative is not selected, any approval of this project 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. 1)deposit the amount of all ascertainable direct and indirect costs regarding services and infrastructure into a fund available to local government to cover the costs as they are incurred, and 2) furnish a performance bond issued by a highly rated insurer to cover all potential costs that cannot be ascertained beforehand, including repairing any environmental damage incurred over a 50 year period because of the development and the costs of cleanup and restoration if the project is started but abandoned. In this way, local government will try to assure no net economic loss to the community. Thank you, Barbara Moore-Lewis Secretary/Treasurer, Brinnon Group 2 JAN 0 2 2014 JEFF r,. BRIN NON GROUP ISSUE SUMMARY J Pleasant Harbor Marina and Golf Resort DSEIS TJ The DSEIS proposes a Master Planned Resort(MPR)on a 231 acre site. There are 3 options: 1. 18-hole golf course,890 residential units,49,772 square feet of commercial space and resort amenities,33 acres of natural area,and 2. 2 million cubic yards of earth moved. 2. 9-hole-golf course 890 residential units,52,650 square feet of commercial space and amenities, 80 ac res of natural area,and 1 million cubic yards of earth moved. 3. 3. No action. We would recommend no action at this time until the following proposed mitigation is accomplished. When appropriate,this summary will break out the plan into issues when construction is in progress and issues after construction is complete. Issues presented apply to both of the action choices. Construction for this particular project is projected as being at least a 10 year process!There is no guarantee that the construction won't last longer,as the approval process for it has stretched out. Problems during construction include out of town construction workers and contractors, unstable ground,county and taxpayer debt and increased taxes,traffic bottlenecks, more trucks on the road,and chemicals and drugs sent into all Black Point wells. DSEIS ISSUE INSUFFICIENT DSEIS PROPOSED MITIGATION MITIGATION ORDINANCE 01-0128-08 lists a It is unclear the way the DSEIS is The developer to prepare a number of conditions about written whether the conditions separate document listing the actions the developer needs to of the ordinance are being met. conditions from the ordinance propose in the DSEIS In several instances, such as and the ways they are being allowing other residents access addressed in the DSEIS. This will to resort wells when there is salt allow both the public and local water intrusion in the private government to track compliance well,the DSEIS appears not to with the conditions. meet the conditions. 2 cont. DSEIS ISSUE INSUFFICIENT DSEIS PROPOSED MITIGATION MITIGATION Although the marina is included Developing marina under Developer to revise DESIS to in the MPR area and ordinance, existing site plan without local include all relevant plans for construction,traffic,water government or citizen review marina included in the MPR. usage,and waste water and input. Both local governments and the treatment for that site are not public have the right to know the described in this document. The actual impacts of the additional DSEIS covers 231 acres of the development. development and the Development Agreement covers 256 acres of development,. Local governments and citizens cannot understand the entire impact of the development with only part of the information about it. There is a "no action"option in There are insufficient details Developer to prepare DSEIS the DSEIS. This option is not about the no action option in the document to include full details developed in the document in DSEIS to be able to make a of no action option. the way the two options for reasonable comparison of building the resort are options. developed. It appears that it is not actually being considered. ECONOMIC ISSUES State taxes are 9%of sales. 6.5% The developer and a few Developer to identify true costs goes to Olympia and 2.5%comes business owners are the only of infrastructure and public to Jefferson County. Taxes ones who will experience services during and after received can be spent anywhere economic benefit. Local construction and arrange to pay in county,while the brunt of government and all county those costs,above what is paid traffic and fire district costs are taxpayers will experience higher in taxes,to local and county born by south county. We will taxes/fewer services. government. A study in Oregon pay levies attached to property of similar destination resorts taxes for school,fire Developer does not pay found that the standard model department,and sheriff costs. sufficient taxes to cover costs of for a golf-course subdivision- Full tax revenue will not be infrastructure and public services oriented destination resort available until Phase 4 and Full needed by the resort itself, presents local governments and Build Out,while the costs will be resort members,and resort taxpayers with a substantial net present during the whole employees. burden (in the millions of dollars) construction period. that will result in either higher Development agreement overall taxes or a decrease in the specifically says that the county quality of basic services. will not ask for more economic mitigation than is in the MOUs. DSEIS ISSUE INSUFFICIENT DSEIS PROPOSED MITIGATION MITIGATION During construction Construction jobs like this are Conditions set for the DSEIS Set a 20%threshold for contracts done by large companies who require as much employment of given to county residents and have out of town sub county residents as possible, as employment of county residents. contractors,and out of county much use of county contractors Developer to calculate actual suppliers. The only jobs typically as possible,and sourcing number of construction jobs available to local people are construction materials from over the 4 phases. minimum wage day laborers.within the county. Profits from the companies and wages from most of the workers The DSEIS states that 1750 jobs will leave the county. will be created, but this is the number for all four phases and many of the jobs will be the same for all four phases The average median income Creation of substantial number Developer to prepare a report of AMI) in Brinnon is$42,679. The of poverty level jobs in south the services uses by employees number of direct jobs created at county and an increased need with wages below the Brinnon or below 80%of AMI are 223. for taxpayer funded health and AMI and an estimate of the cost Construction and indirect jobs social services. of those services. Developer to with an income of$34,143 equal pay for costs of services to these 342. 83%are considered employees provided by tax poverty level by U.S. Department funded entities. A report of Health and Human Services prepared of minimum wage jobs standards. at Walmart estimated that Walmart costs surrounding 48 jobs are above AMI, communities$13 million in ranging from$36,000 to economic activity and$14.5 52,914 million in lost wages over 20 108 jobs are$10,593 to years. 14,381 121 jobs are from$19,241 to 28,000 2014 Poverty Guideslines of USDHHS: Family of 5: $27,910 Family of 4: $23,850 Family of 3: $19,790 Family of 2: %15,730 DSEIS ISSUE INSUFFICIENT DSEIS PROPOSED MITIGATION MITIGATION Taxpayers will subsidize life In 2013 there were 249 EMS calls Developer to prepare analysis of safety services for about 800 Brinnon residents. true costs of life safety services Add the estimated 2000 resort and to make provisions to pay residents and there will be about for those services to local 620 calls a year. The MOU with government entities. the fire department is for 3,333/month. This is not Developer to present plan for enough to hire another EMT.trained EMT staff. The inadequate funding can go for 10 years or more. Also, local Developer needs to describe role fire department is responsible and training of private security for all training costs and upkeep that will replace county sheriff of used ladder truck Statesman staff. What will be their will provide...all meaning higher authority? Will they be able to local taxes for fire department. handle traffic accidents/fatalities and other emergences involving The developer says if the resort resort residents and/or Brinnon has trained EMT staff,they will residents? be available to surrounding community. For police,the developer will provide a 500 square foot room smaller than a 2 car garage) but no budget to supply and staff it...meaning higher taxes for all county residents. The Sheriffs Department says no additional county resources will be needed if resort has private security. Taxpayers will subsidize road None Developer to prepare analysis of improvement and repair for true costs of road improvement heavy equipment and repair and make provisions to pay for those services to state and local government entities Internet service to local area is None Developer to pay to upgrade inadequate because of volume internet infrastructure to the of use of existing equipment; same speed consumers receive resort use will compound in the metropolitan areas. Internet access problems. DSEIS ISSUE INSUFFICIENT DSEIS PROPOSED MITIGATION MITIGATION After`construction 280 jobs are projected,with the Developer must build low Developer to state how many majority low income or income housing or provide land jobs are part time. Developer minimum wage. It's not stated or money for it.subsidize rents for low income how many of these jobs are part workers in the housing time.constructed or present evidence that wages will allow these workers to rent this housing. . Developer to pay for costs of services to these employees provided by tax funded entities. Developer will provide a 500 Developer to use local medical Developer to prepare analysis of square foot clinic for use by and hospital resources but to true costs of life and safety medical personnel; use by resort provide mitigation only for services and to make provisions members only. resort members. to pay for those services to local government entities, including local hospitals and medical services subsidized by local taxpayers. MOU with Brinnon schools No estimate of real revenue Developer to prepare report on specifies$2 per tee time to go to from tee times. No dedicated income to Brinnon school and on schools and scholarships to be fund for scholarships; no details scholarships to Jefferson County given to Jefferson County school of who will be eligible.children. For example,are home children. schooled children eligible? Money needs to be placed in dedicated account before construction begins that will cover scholarships TRAFFIC Data used for the traffic study is The Loss of Service data is from The developer to do an up to totally inadequate. Highway 101 2000. The actual car trip count is date traffic report with data on the east side of the Olympic from 2006. The data does not from 2014 or later.This will Peninsula is the only non toll count accidents that do not include all accident reports direct connection to the 1-5 occur at intersections(leaving between Olympia and 104. (The corridor and is used for all major out collisions with animals, Peninsula Daily News reports shipments of goods, as well as McDonald Cove, and the tanker that tourist trips increased 25% for residential and tourist traffic. truck that exploded on the during 2014 and the Olympic When serious accidents occur, Duckabush hill. Consultants paid National Park has similar data). 101 is shut down for long by the developer have Developer to present adequate periods of time,affecting both consistently minimized both the mitigation for current traffic. commerce and quality of life.effects of unsafe driving and Developer to pay for mitigation There are serious economic, unsafe driving conditions on 101 for projected additional traffic. health,and safety costs for the in their reports and in response entire Peninsula. to comments on their reports. DSEIS ISSUE INSUFFICIENT DSEIS PROPOSED MITIGATION MITIGATION During constructi Heavy equipment on highway, Developer says earth will be Developer to present evidence increasing congestion and moved within resort area that the earth moved from the accidents because it will be used for site qualifies for construction use construction materials;no and provides data on the evidence gravel fits amount that will be moved on specifications the site vs what will be moved on the highway. Developer proposes mitigation for increased truck traffic and pays for mitigation. Machinery used will be scrapers, None Developer to present report on excavators, bulldozers,wheeled noise impact on other Black front loaders, a portable Point residences and to propose screening plant,feed-hopper, mitigation. Developer to pay for portable gravel crusher,finishing mitigation. crusher, water trucks,conveyor belts systems,and vibratory/sheep-foot compactor rollers. This will be 1200 feet away from the closest existing residence. AfterACM-4.-d000n Ikmconstruction There will be up to 4100 added Buses will run to Seatac and Developer to do traffic analysis daily trips from resort traffic on visitors will take a route to resort with recent data on traffic state and local roads;there was that includes lengthy ferry volumes and with all accident a 25% increase in tourist traffic waiting and heavy Seattle traffic data. Developer will calculate in 2013 alone on the Peninsula; instead of the easier;traffic road improvements needed there will be bottlenecks in volumes calculated with out of from accurate traffic data and Hoodsport date and incomplete data make provision to pay for those improvements. Developer to hold local meetings discussing traffic improvements with local residents before proceeding. Developer to provide proof of estimates of bus usage. The increased traffic along Hood Buses will run to Seatac and Developer to do an analysis of Canal will increase the nitrogen visitors will take a route to resort the environmental impact of the problems and dead zones in the that includes lengthy ferry increased traffic on the health of Canal. waiting and heavy Seattle traffic Hood Canal, using current instead of the easier;traffic science,and propose mitigation. volumes calculated with out of date and incomplete data. DSEIS ISSUE INSUFFICIENT DSEIS PROPOSED MITIGATION MITIGATION WATER The water rights were awarded, For each phase during the 10+ Developer must test the existing but additional wells were never years of construction,adequate well and provide adequate data drilled. A pump test was water must be proven. on drawn down rate and attempted on an existing well, available volume. Developer but was aborted after must show adequate water equipment failure,so draw down supply not only for resort but for rate and available volume was all Black Point wells,existing and never proven. Usage amounts future. Computer models which have not and will not be have been used are not determined until full build out, acceptable. with the caveat that for each phase during the 10+years of Developer must define what construction adequate water mitigation will be provided if must be proven. volume is not sufficient and the aquifer is depleted for all wells. The water supply well is Yearly monitoring Require the developer to test developed below sea level and the water supply well monthly will always be susceptible to salt for salt water intrusion and to water intrusion or cause submit the reports to the county intrusion to the wells along the health department. south and east coasts of Black Point. This is not a well used for testing salt water intrusion The salt water intrusion samples Yearly monitoring Require the developer to test all are taken from 3 Statesman water supply wells monthly for wells that are not located where salt water intrusion and to salt water intrusion is likely to submit the reports to the county happen health department. The developer is required by the Restrictive Neighborhood Water County health department to ordinance conditions to provide Policy that requires 3 years decide if well has salt water access to the resort water monitoring of private wells intrusion. If so,developer gives system by any neighboring before a claim can be made and access to resort system at parcels if saltwater intrusion the developer to decide if claim standard county hook up and comes an issue for them. is valid. monthly usage rates. DSEIS ISSUE INSUFFICIENT DSEIS PROPOSED MITIGATION MITIGATION During co on Statesman's tests for salt water Yearly monitoring Require the developer to test intrusion are to be collected the water supply monthly for salt quarterly, but to be submitted to water intrusion and to submit the Department of Ecology once the reports to the county health a year. This means residents department with neighboring wells may have to wait up to a year to start the process of proving salt water intrusion is due to the water use of the resort. The pumping plan for the supply None Require the developer to submit well will influence salt water a pumping plan that will intrusion minimize salt water intrusion in resort and neighboring wells. After constriction There is one aquifer on Black Water studies are done by Developer to do actual water Point, recharged by rainwater. computer modeling. studies on the property to be The resort wells could deplete developed and to prove the the aquifer.availability of water for all residents. Include wells that already have salt water intrusion not in DSEIS). Require a bond to compensate other residents if aquifer is depleted. Developer to prepare report about how resort will be mothballed or environment restored in case of aquifer depletion. Developer to provide a bond to cover costs of mothballing and/or restoration. There already is salt water Put up a bond that would cover a intrusion in Black Point wells; desalinization plant. resort wells could cause more salt water intrusion not only in adjacent wells but in resort wells as well. It is unclear how much water is Forcing waste water down wells Developer to do water plan with projected to be used. Figures to recharge the aquifer. consistent numbers that fits with from 70 to 175 (standard usage) historical supply and not are in the document. recharging the aquifer in this way. DSEIS ISSUE INSUFFICIENT DSEIS PROPOSED MITIGATION MITIGATION The aquifer is recharged by None Developer to present a plan for rainwater. There are extensive drought years,taking into changes to the land that will account the changes in the affect the amount of permeable landscape to be made by moving land. There is no information on at least 1 million cubic feet of how low rainfall years would dirt and rock. Developer to affect the assumptions of the demonstrate that recharge rates water model. Because will be as projected in DSEIS. everything is based on a computer model,there is no real proof that recharge will take place as described with the development of the land. Recharge may be significantly less. Statesman has put several This is in conflict with the DOE Developer to rewrite restrictive conditions on what an conditions on the water rights, Neighborhood Water Policy in individual well owner has to do including Statesman conditions concert with owners of local to prove their potable well water that they can demand additional wells so that local owers' was lost due to Statesman's evidence that they are at fault. If concerns are answered. County actions. the developer does accept fault, health department to facilitate the owner may hook up, at this rewrite. 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. The utility district created for the Sometime in the future the The developer to clarify fee operation of the Water System entire Sewage Treatment Plant structure of utility district, and Sewage Treatment Plant has will have to be replaced. Owners including hook up fees and to make enough profit to cover of private wells that are monthly fees for owners of maintenance and future compromised by the water use private wells who use the utility replacement of deteriorating of the resort and want to hook district system. equipment. up to the resort water system will have to pay unspecified fees. DSEIS ISSUE INSUFFICIENT DSEIS PROPOSED MITIGATION MITIGATION WASTE WATER No Class A water treatment None Prohibit the developer from system removes soluble contaminating the aquifer with chemicals. This means that the chemicals left from the water medications people use daily will treatment or require water not be removed from the water. treatment that removes all Statesman plans to use the chemicals. water in irrigation,fire suppression,and to recharge the aquifer. The water will be forced down wells into the aquifer, where it will contaminate any water drawn from the single aquifer. OTHER All stormwater runoff from new This does not indicate how they Mitigation can help with pollution generating impervious are going to treat the water. stormwater runoff, but not surfaces must be treated before eliminate it. Developer to discharge to on or off site locations to comply with prepare report on ways to stormwater Management mitigate the stormwater runnon. Manual for Western These can include Washington. stormwater filters(which go onto the stormwater entrances and filter out oils and other pollutants;they should not be used by themselves for they don't always work), tarps(which will trap water while all the earth is being moved;this will help keep the water from running off and giving the construction workers time to filtrate the water into storage containers to be cleaned). and controlling the erosion controlling how workers are move the soil around the work site may save water from running off into the Hood Canal). DSEIS ISSUE INSUFFICIENT DSEIS PROPOSED MITIGATION MITIGATION Moving soil releases the stability Storing stormwater in holding Developer to provide evidence of the ground. Moving at least 1 pond or allowing it to go into the that plans in the DSEIS treat million tons of earth at the site Canal. Various methods of stormwater to remove will affect the stability of the treating pollutants in water. pollutants are realistic. ground. It will also affect the The BMPs( Best Management stormwater,all surface waters Lack of information on chemicals Plans)for golf course from rain and snow. This is herbicides, pesticides,or maintenance needs to be runoff that does not collect in fertilizers)that will be used for explained in detail. the ground. The plan to move golf course grass maintenance or stormwater to a retention pond. any discussion of how the That pond will let the water sink developer plans to protect into the aquifer,transferring the groundwater or stormwater pollutants of construction to the runoff from the use of these aquifer. Less stability of the site chemicals. will cause more stormwater to run off, be absorbed into the aquifer,or go in Hood Canal. Pollutants include oils, antifreeze,and other liquids from construction equipment, pesticides,and fertilizers. Natural wetlands in the resort Destroying wetlands will destroy Developer to revise plan to leave area will be cleared and used as the natural systems now intact wetlands as wetlands.The kettle retention ponds. These and the wetland will no longer with the wetland needs to be left wetlands are pollutant removal be able to help in natural as it is because this will help the systems and clean the ground filtration of stormwater. project to clean some of the water. stormwater runoff that will be Wetlands mitigation plan has not caused by this project. been done. Developer to do wetlands mitigation plan before approval of DSEIS. Biosolids will be sent to Shelton No proof of agreement about Developer to prepare a report on for processing disposal of biosolids. Inadequate biosolids,including proof of a information on amount of plan to dispose of them and an biosolids. Increased truck traffic estimate of truck traffic that will for the biosolids. Unclear if this be generated. is included in the traffic analysis. Mason County PUD#1 has Lacking in details about PUD Developer to present agreement agreed to supply power for the services to be supplied and how with PUD for public review, first phase. they will be funded; no mention including possibility of rate of possible rate increase for all increases for all rate payers. rate payers in PUD#1 from increased energy usage. 34 35 36 37 Fiscal and Economic Impacts of Destination Resorts in Oregon pryrypy$ } 4 g dx 1 r etttra4 c E d F a 3 v"" P c x a' a'EF March 2009 Fiscal and Economic Impacts of Destination Resorts in Oregon March 2009 For: Central Oregon LandWatch By: Eben Fodor FODOR & ASSOCIATES LLC Community anning Conaukir Eugene, Oregon www.FodorandAssociates.com With research and analysis by David Hinkley Cover photo credit:Sandy Lonsdale Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page I Table of Contents Introduction 3 1. Destination Resorts in Oregon 4 2. The Thornburgh Resort Case Study 12 3. Thornburgh Fiscal Impact Analysis 13 4. Revenues from the Thornburgh Resort 17 Property Taxes 17 Room Taxes 22 5. Thornburgh Resort Costs 24 Transportation System Costs 27 School Facilities Costs 40 Fire & EMS System Costs 48 Public Safety System Costs 53 Parks & Rec. System Costs 59 General Government Facilities 64 6. Fiscal Impact Summary 67 Revenue Summary 67 Costs of Facilities 67 Services Impacts 68 Fiscal Impact Conclusions 69 7. Thornburgh Resort's Economic Impacts 70 Job Creation and Employment Impacts 71 Who Will Fill New Resort Jobs: Locals or Newcomers? 76 Housing Impacts of Thornburgh Resort 78 Spending by Destination Resorts 81 Economic Risks 83 Economic Impact Conclusions 85 8. Implications for Impacts of Destination Resorts in Oregon 86 Appendices 89 A-1. Property Tax Explanation 90 A-2. Transient Room Tax Explanation 94 A-3. Population Projection Used in Study 98 A-4. Tax Bases for Jurisdictions Used in Study 99 A-5. About the Authors 100 Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 2 Introduction The recent proliferation of destination resorts,and the number of new resorts currently being proposed in Oregon,raises concerns about the potential impacts of these resort on local communities, cities and counties. Based on a literature review performed as part of the research for this study,there are no independent, third- party studies evaluating destination resort impacts. The only readily-available sources of information are the resort developers'own studies prepared as part of the land-use application materials. This report represents the best effort to date to assess the impact of destination resorts in Oregon. It is a complex task and there are an almost unlimited number of potential impact areas that could be studied. To establish a manageable scope of work within the project budget, the focus of this study is on the fiscal impacts of resorts. Fiscal impacts are those that affect local governments and local taxpayers. They include both the tax revenues that will be generated and the costs to provide the services and infrastructure required to support the development. In addition to fiscal impacts, the economic impact of destination resorts was evaluated in terms of job creation and housing impacts. This study does not address any of the environmental or social impacts associated with residential and recreational development of resorts in the State. Instead this study focuses on the monetary(fiscal and economic) impacts these destination resorts have on the local communities where they are being built. In order to study resort impacts in detail,the proposed Thornburgh Resort in Deschutes County was used as a case study.The Thornburgh Resort is to be located near Redmond and just west of the existing Eagle Crest Resort. The Thornburgh Resort would be a medium-sized resort and was considered to be fairly typical of past and future resorts in the State. This report is intended to be transparent. All sources of information are documented and all the calculations and methodologies are explicit. Where data were not available, reasonable assumptions were made. These assumptions are also clearly stated. In some cases, where good data were not available,alternative scenarios were used to examine a range of possible conditions. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 3 I . Destination Resorts in Oregon Destination resorts typically involve 500 to 3000 single-family homes and various recreational amenities, such as golf courses and clubhouses, in an attractive natural setting located away from existing cities and growth centers. The term"destination resort" has a unique legal meaning in Oregon. Special status was given to "Destination Resorts" allowing them outside urban growth boundaries under Goal 8 (Recreational Needs) of the Land Use Planning Program.' This action appears to be based on the assumption that the tourism benefits would outweigh the costs associated with this form of rural development. In 1987,provisions for destination resorts were enacted into state law and codified in Oregon Revised Statutes(ORS) 197.435 through 197.467. According to ORS 197.440: The Legislative Assembly finds that: 1) It is the policy of this state to promote Oregon as a vacation destination and to encourage tourism as a valuable segment of our state's economy; 2) There is a growing need to provide year-round destination resort accommodations to attract visitors and encourage them to stay longer. The establishment of destination resorts will provide jobs for Oregonians and contribute to the state's economic development; 3) It is a difficult and costly process to site and establish destination resorts in rural areas of this state;and 4) The siting of destination resort facilities is an issue of statewide concern. The State Legislature attempted to enforce the tourism aspects of these developments by requiring a certain minimum amount of overnight accommodations and certain visitor-oriented facilities! The intent was apparently that without such requirements, destination resorts would likely be little more than the classic, sprawling rural subdivisions that the Land Use Program was intended to prevent. However it is unclear that resorts are actually meeting their overnight accommodations requirements due to a lack of reporting and enforcement mechanisms. In spite of State requirements, residential lots and private homes outnumber overnight accommodations by more than two to one. Residential lot sales represent the primary feature of existing and proposed destination resorts. Questions remain as to whether the destination resorts are essentially rural subdivisions that are increasingly having adverse impacts on cities, counties and the state that are not Goal 8: Recreational Needs(OAR 660-015-0000(8)). 2 State Law requires that destination resorts permanently allocate one overnight housing unit for every two residential units in Western Oregon and two overnight units for every five residential units in Eastern Oregon(see ORS 197.445(4)). Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 4 adequately offset by tourism benefits. Our literature review found no studies examining these impacts in detail,other than those prepared by the individual resort developers themselves. So we are left with an inadequate understanding of the full impacts these development are having across the State. The Growth of Destination Resorts Destination resorts have proliferated rapidly in the State and will have increasingly significant impacts,both positive and negative. At this point, Oregon has eight existing resorts, most of which are historic or pre-Goal 8 resorts. Another seven are approved and under construction,and thirteen more have been proposed. Figure 1-1 shows these existing,approved and proposed resorts on a map of the State. Central Oregon shows the highest concentration of resorts in all stages of development. Southern Oregon and the Coast are also seeing resort development. Deschutes County has seen far more resort development than any other county,but Crook, Jefferson and Jackson counties are also seeing a high level of resort development. Figure 1-1: Destination Resorts in Oregon by Status Columbia Clagop Hood River Amur Multnomah Sherman Washington Tillamook Wallowa Morrow Tenth!!! - Clackamas Gilliam Union Polk Marlon Wasco Lincoln Whaabr Baker enne. Jefferson Benton l - Grant MX Try* ,.w bma.n Unn n'. nb<r-n IWwnO E—ntl•r n lrne: adl.Inm nwme.c •by .1 resrn M=n Existing MO.:_. WrF 4 w••cno. M rev Pk Construction Lane ',,, Crook Construction Deschutes - Q Proposed O RbaWaned Comm Os tuodocot coos Douglas e.uan wne Lake Harney Malheur Josephine'. Jackson Klamath a.. !01 Curry • * ywMnvA,a.m Source:Toby B.yerd Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 5 Table 1-1 provides a more-detailed summary of destination resorts that are completed,under construction,and proposed in the State. The land use and housing unit data from this table is illustrated graphically in Figures 1-2 and 1-3. It is evident that destination resorts are expanding rapidly. If the recently-approved and proposed resorts are built,Oregon's destination resort capacity will approximately triple. The rapid growth in destination resorts raises a number of questions. Is there going to be a market demand for so much resort capacity?Will new resorts compete with established resorts and undermine their viability?And will the economies of Central Oregon and other popular resort locations become vulnerable in the event of a possible downturn or collapse of the resort market? Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 6 Table 1-1 Destination Resorts in Oregon, January 2009(11 Overnight Existing Resorts Goal 8? County Acres Homesites Unitsta) Total Units Bandon Dunes Goal 2 exception Coos 2,000 600 150 750 Eagle Crest Yes Deschutes 1,772 891 585 1,476 Sunriver/Crosswater No Deschutes 3,310 3,220 936 4,156 Black Butte Pre-Goal Deschutes 1,300 1,251 425 1,676 Inn of the Seventh Mt. Pre-Goal Deschutes 310 20 210 230 Running Y Ranch Yes Klamath 6,000 896 305 1,201 Otter Crest Pre-Goal Lincoln 35 144 130 274 Salishan Pre-Goal Lincoln 750 369 0 369 Subtotal:15,477 7,391 2,741 10,132 Under Construction Brasada Ranch Yes Crook 1,800 600 300 900 Hidden Canyon Yes Crook 3,250 2,450 1,225 3,675 Remington Ranch Yes Crook 2,079 800 400 1,200 Caldera Springs Yes Deschutes 390 320 160 480 Pronghorn Yes Deschutes 640 430 215 645 Tetherow Yes Deschutes 698 379 298 677 Paradise Ranch Yes Josephine 320 200 67 267 Subtotal: 9,177 5,179 2,665 7,844 Proposed Resorts Crossing Trails Yes Crook 580 490 240 730 Pacific Rogue Ranch No Curry 592 500 150 650 Aspen Lakes Yes Deschutes 550 300 100 400 Skyline Forest No Deschutes 1,500 950 0 950 Thomburg Yes Deschutes 1,970 950 425 1,375 Heaven's Gate Yes Douglas 500 200 200 400 Hidden Valley Ranch(2) Yes Jackson 883 TBD TBD TBD Table Rock Yes Jackson 2,100 1,200 600 1,800 Ponderosa Land&Cattle Yes Jefferson 3,500 2,500 1,000 3,500 The Metolianl 21 Yes Jefferson 640 450 180 630 Crescent Creek Ranch Yes Klamath 5,000 1,965 785 2,750 Naples Golf&Beach Yes Lincoln 576 1,155 0 1,155 Elkhom Estates Yes Marion 464 150 40 190 Subtotal:18,855 10,810 3,720 14,530 Totals: 43,509 23,380 9,126 32,506 1)Data Compiled by Toby Bayard and COLW on 2/25/09 2)Data on number of units not final at this time(TBD is to be determined). 3)Dwelling units only.Hotel rooms were not included in the overnight units when information was available to separate them from dwelling units.Where data for the number of overnight units was not available,required State minimums were applied to Goal 8 resorts. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 7 Figure 1-2 Destination Resort Acres Total=43,509 acres Under Construction, 9,177 Existing Resorts, 15,477 1010 Proposed, 18,855 Figure 1-3 Destination Resort Housing Units Homes & Overnight Units) Under Construction, Existing Resorts,7,844 10,132 Proposed, 14,530 Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 8 The Destination Resort Controversy The booming growth in destination resorts has led to increasing concern about their impacts and more questions than answers. Do we need more destination resorts,or do we have too many already?Are these resorts beneficial to the local economy, or are they just generating profits for a few and low-wage jobs for the rest?Are local governments reaping giant tax windfalls,or are they incurring more costs than they can recover? Are resorts allowing more Oregonians to vacation in beautiful rural areas,or are they destroying the beauty of the landscape and rural character Oregonians currently enjoy?Are resorts well-planned developments that are carefully integrated with the natural environment,or are they just low-density rural sprawl and ecological disasters that threaten ground water and destroy habitat? Regardless of the answers to these questions,opposition to new resorts has grown. For example, last year residents of conservative,rural Crook County voted 2 to 1 to halt the spread of resorts in that county. According to an editorial in The Oregonian newspaper,; Crook County opponents have some justification in warning that these projects are essentially large subdivisions under the guise of destination resorts. They will, as critics complain, have a significant impact on the county's vehicle traffic, water supply and wildlife habitat. Prineville boosters of the new resorts correctly point out that they contribute heavily through property taxes and create hundreds ofjobs.But opponents are equally correct in noting that the influx of homes will inflate land values,putting unwelcome pressure on farmland and making housing unaffordable for workers who will fill all those low paying new jobs. lobs for Whom? In spite of high unemployment in Central Oregon,alarming information was reported in the Bend Bulletin last year that many of the local resorts were hiring from outside the U.S. to fill their jobs."According to the article,instead hiring locally,the Sunriver Resort actively recruited foreign workers at overseas job fairs, hiring 85 workers from countries such as Lithuania,Brazil and Mexico. Inn of the Seventh Mountain hired 11 workers from Jamaica and Indonesia. Other resorts may be doing the same. Even if some resorts are not hiring foreigners, studies show that many of the new jobs they create will go to newcomers rather than locals.5 3"Putting the Brakes on Destination Resorts,"editorial,The Oregonian,May 27,2008. Unemployment might be high,but resorts still struggle to fill some jobs,"The Bulletin,May 11, 2008. 5 See: Who Benefits from Local Job Growth,Migrants or the Original Residents,by Timothy J.Bartik, Regional Studies,vol.27,No.4, 1993. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 9 Resort or Rural Subdivision? It is increasingly clear that the primary incentive for building destination resorts is the traditional profit resulting from the real estate sales of residential lots. Developers rarely build more tourism accommodations than they are required to provide by law. The resort-oriented features appear to be little more than the vehicle by which the subdivision is allowed. Certainly the golf courses and resort amenities enhance the value of the residential lots,but developers recognize that the resort components are marginal,risky and often unprofitable investments. Meeting the tourism-oriented overnight accommodation requirements of Goal 8 has been challenging for resort developers. Newer resorts are focused more on residential lot sales and less on tourism accommodations. There has been an increased use of smaller, lower-cost units,such as hotels and timeshares, to meet overnight lodging requirements.' Resorts that are close to urban areas may end up functioning more like suburbs. The Eagle Crest Resort, for example, is less than six miles from downtown Redmond, making urban amenities and jobs just a 10-minute drive away. Some resorts may evolve into rural communities or towns of their own.The Hidden Canyon Resort for example,which will be located in Powell Butte(Crook County),will have a population roughly equal to that of the City of Madras, if it is fully developed. The proposed Ponderosa Resort could have a population three times that of the City of Sisters. Effects of the National Recession The dramatic expansion of the destination resort industry in Oregon has been fueled in part by a booming real estate market that seemed to have no end. Ten years of unprecedented growth peaked in 2007 and has declined rapidly since. The economic models for destinations resorts were based on assumptions of continued high land values, high real estate demand,and rapidly expanding tourism. However, the ongoing collapse of the inflated national real estate bubble and the ensuing economic downturn requires that these assumptions be revised. In the past, the residential lots in a destination resort have been largely purchased by individuals as second homes and investment properties. The current economic recession will contract the market for second homes and will reduce the appeal of real estate investing. Unless the national economy has an unexpected, dramatic recovery, more and more potential homebuyers will be economically constrained. Potential tourists are likely to reduce travel and shun expensive vacations to save 6 See:Destination Resort Siting,a presentation by Bob Cortright,DLCD in Prineville,October 15, 2008,http://www.oregon.gov/LCD/docs/rulemaking/101508/item4 att D.pdf. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 10 money.'A Central Oregon economic forecast shows tourism to be "extremely weak" and contracting through at least the end of 2010.8 Owners of second homes may find the cost of owning two homes to be too expensive. Under this scenario,it is likely that more of the lots created in destination resorts will be purchased for primary residences. We may see a similar shift in existing resorts,with more second homes and rental properties changing to primary residences. Resort developers may respond to the weak economy by downscaling homes to make them more affordable as primary residences. Infrastructure Needs The residential component of the destination resort functions much like any subdivision in a rural area. It is removed from the retail services and amenities people require. It is lacking adequate infrastructure and services required by an urban population. Greater travel distances are required for commuting and meeting daily needs. This generates demand for more roads with more capacity. When traffic growth is projected in Central Oregon, including destination resorts, the funding gap to bring the state highways to standards for traffic congestion is approximately $750 million over the next 20 years.' Resorts located close to cities and towns run the risk of becoming more residential, as residents have access to the nearby urban amenities homeowners desire. The proposed Thornburgh Resort is to be located approximately seven miles from Redmond. Such resorts may have the effect of attracting higher-end housing away from the cities,which undermines the cities' property tax base while increasing their effective populations and adding to demands for more roads and schools. County and municipal governments will be severely squeezed for financial resources over the next few years as a result of: Decreasing property values that reduce property tax revenues; A weak economic outlook that may reduce other sources of income; Government costs increasing at rates exceeding Measure 47 and 50 limits on property tax increases of 3%; and, Decreasing Federal payments to counties in lieu of timber revenues. Will the new destination resorts be a golden goose, or the straw that breaks the camel's back? Fiscal impact analysis can provide the answer. Early reports indicate that major tourism destinations such as Las Vegas are seeing significantly lower tourism resulting from the recession.Gaming revenues there are down 25.8%,room rates have declined 14.3%,and many construction projects have been canceled or scaled back,according to the Los Angeles Times(published in The Register-Guard Newspaper, 12/26/08). 8 Presentation: United States and Central Oregon Economic Review and Forecast,by Dr.Bill Watkins, Executive Director,UCSB Economic Forecast Project,January 2009,http://www.ucsb- db.com/PPT/2009/OR_Watkins.m. 9 Source: Gary Farnsworth(ODOT),Meeting Minutes for Central Oregon Area Commission on Transportation,COACT,September 13,2007,page 3. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page I I 2. The Thornburgh Resort Case Study In order to examine the impacts of destination resorts in detail,a typical resort was selected for in-depth analysis. The proposed Thornburgh Resort has a similar profile to most of the resorts in Oregon. It is typical in terms of its size and mix of development. It is to be located in Deschutes County,home to more destination resorts than any other county in the State. Due to its pending application,extensive current materials are available on the planned resort. As shown in Table 2-1,the proposed Thornburgh Resort is to have 950 residential ownership units and 425 overnight units,for a total of 1,375 residential units. The application proposes a 50-room hotel with restaurant, three golf courses,recreational facilities,and retail space. Table 2-1: Thornburgh Resort Profile for Impact Analysis Peterson Land Use Economic Report Application Used in Impact Metric 1/2005) 2/2005) Study Total acres 1,980 1,970 1,970 Acres open space (incl. Golf) No info 1,293 1,2810) Residential ownership units 1,400 950 950 Residential overnight units Unclear 425 425 Hotel rooms 100 50 50 Golf courses (regulation 18-hole) 3 3 3 Golf courses—par 3 1 0 0 Other facilities: Retail space 20,000 ft2 20,000 ft2 Real Estate Sales office 15,000 ft2 15,000 ft2 Hotel and restaurant 75,000 ft2 75,000 ft2 Recreational 60,000 ft2 60,000 ft2 Convention facility, Unspecified size Assumed part business center of hotel/rest. Water system 6 new wells, 2 6 new wells, 2 reservoirs reservoirs Sewer system 2 drain fields 2 drain fields 1)From Final Master Plan. Since the Thornburgh Resort is unbuilt, certain types of data were not available. For example, the ultimate occupancy rates and vehicle trip generation rates were unavailable. To reflect the most likely scenario for the Thornburgh Resort at full buildout, data was used from the nearby Eagle Crest Resort. Eagle Crest appears to have a similar profile in terms of the mix of uses and relative price ranges for lots and homes. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 12 3. Thornburgh Fiscal Impact Analysis Fiscal impact analysis generally refers to the evaluation of the financial and budgetary effects of alternative land uses or public policies on local governmental jurisdictions or other local service providers. These may include cities,counties, school districts, special-purpose districts,water and wastewater service districts,and regional authorities. Sometimes state governments are also impacted. While the focus of fiscal impact analysis is on government revenues and costs, the broader public policy question is: How will this action or decision affect local taxpayers and the general public? Answers to this broader question allow elected officials to determine how the proposed action will affect local tax rates or the quality of local services. This question tends to be one of most interesting to local voters and the public in general. As shown in Figure 3-1, the fiscal impact analysis compares the changes in revenues with the changes in costs of a local government entity that result from an action or decision. Revenues include taxes,fees and other income. Costs include operation services)and maintenance(O&M) and new or expanded capital facilities and equipment. Figure 3-1: Diagram of fiscal impacts of land development on local government Fodor &Associates). Revenues Costs Local Property Taxes Government Operation(services) Other Taxes Maintenance Other Revenue Capital Facilities& fees, permits,etc.) City, County or Equipment School District) Usually local governments must balance their budgets so that costs don't exceed revenues. While this is true for government services, it is not the case for major capital expenditures. Local governments may issue general obligation bonds for new capital facilities that enable them to carry debt. General obligation debt is a reasonable way to finance facilities that have a broad public benefit. However,when the new facilities are constructed primarily to serve new development, an inherent Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 13 inequity results,and all taxpayers pay to fund facilities that benefit a small segment of the population. One solution to this problem is the LID,or local improvement district, that limits funding of improvements to the beneficiaries. Another is the impact fee,or system development charge (SDC) in Oregon, that directly recovers some or all of the costs associate with providing certain facilities to new development. Deschutes County also uses "Community Service Districts" to assess the costs of some public safety, fire protection and library services directly to the geographic districts they serve. Public Infrastructure Required by Thornburgh Resort Development Table 3-1 below summarizes the categories of infrastructure required by new development. The costs associated with all onsite facilities and services(such as local roads and utility lines)are assumed to be borne by the developer. Only the offsite impacts are examined here. Of these, transportation and schools typically represent the greatest costs,so much of the analysis work focused on these two categories. Table 3-1: Basic Public Infrastructure Required by New Development All Categories Evaluated Transportation System Yes School Facilities Yes Fire & EMS Facilities Yes Police Facilities Yes Parks & Rec. Facilities Yes Sanitary Sewer System NA Storm Drainage System NA Water Service Facilities NA Library Facilities No General Gov. Facilities Yes Solid Waste Facilities No Public Open Space No The Deschutes County Code10 requires that the resort developer pay for onsite water and sewer systems, so it was assumed that the costs associated with these facilities and services are borne by the resort and its future residents and visitors. The long- term viability of these onsite water and sewer systems is unclear. For example, the current plans indicate that the resort's sewer system will rely on drain field disposal for an indefinite period of time. This method of disposal can contaminate groundwater and has a limited lifespan. The high water demand from the resort may 10 Deschutes County Code,Chapter 18,113.Destination Resorts Zone—DR. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 14 deplete local groundwater supplies and the resort may be obliged to indemnify nearby landowners. The County has no requirements for offsite stormwater management facilities or services, so it was assumed that onsite stormwater management will not have offsite fiscal impacts. These resort developments are contingent on provision of open space within the development." Therefore,additional open space needs may not be generated by the development.12 However,any new residential development is likely to increase demands for certain County parks and recreational facilities, so these impacts were included in the study. Electric power,natural gas, telecommunications, and solid waste disposal services to the resort are operated by private businesses. These services also require offsite infrastructure investments. Such costs tend to be added to the utility rates that are paid by all customers,not just resort residents. The costs associated with increased rates for these services were not included in the study because they are not public- sector costs and because it is difficult to obtain the necessary revenue and cost data from private companies. Impact Analysis Methodology In order to evaluate the potential impacts of the Thornburgh Resort, two scenarios are compared: unbuilt and full buildout. The unbuilt scenario assumes no change in current land use. The full buildout scenario assumes the resort is entirely built out all proposed facilities are built and all lots are developed with homes). In all likelihood the resort will take many years to build out and may have undeveloped lots remaining long after most construction is completed. To simplify the impact analysis,both the unbuilt and full buildout scenarios were compared for the year 2008. This simplification enables a direct comparison of before and after costs and revenues and eliminates the time-values of various cash flows in different years. By comparing built and unbuilt scenarios, the vagaries of uncertain approval dates and construction schedules are eliminated. It is intuitively more useful to consider the alternatives of a resort that is either built or unbuilt under current economic and fiscal conditions than to consider one option today and the other 12 years in the future. A destination resort creates both direct and induced impacts. As described in the Economic Impacts section of this report,a resort induces additional growth and According to Deschutes County Code,DDC 18.113.060(D)(1),"The resort shall have a minimum of 50 percent of the total acreage of the development dedicated to permanent open space,excluding yards,streets and parking areas."Golf courses are considered open space. Z Increased use of public lands surrounding resorts by resort residents is common.For example,the Pronghorn Resort recommended that their property owners use adjoining BLM land for exercising dogs in a recent newsletter. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 15 development beyond its physical boundaries. This is primarily the result of new jobs created at the resort. Many of these jobs will be filled by newcomers who will require additional housing and have fiscal impacts of their own. In this study the induced impacts were evaluated only for schools. All other impact areas reflect only the direct fiscal impacts of onsite development within the resort. The induced impact on schools was addressed because student generation will be significantly increased by influx of new workers at the resort and this information may be useful to school districts for facilities planning purposes. All revenue and cost figures are given in 2008 dollars and values. Costs from other years were adjusted to 2008 values based on the appropriate inflation index or construction cost index. Tax rates were based on the 2008-09 rates. The most recent available data was used throughout the analysis. It is important to note that from an accounting perspective, there are two basic types of costs and revenues: annual streams that occur every year,and one-time costs or payments. Tax revenues and service costs represent the former. Infrastructure costs and any associated System Development Charges are treated as the later. As soon as a new resort development is completed, the residents and visitors will need adequate road capacity, classroom space for their children,fire protection, and public safety services, so these facilities must be in place. There are a number of standard methods for estimating the demand for new facilities and infrastructure a new development will generate. Each method has advantages and drawbacks. The methods used here were selected to yield the best estimates of demand given the limitations of available data. In most cases the capacity of services and infrastructure must be adequate to serve peak demands. For example,police and fire protection capacity must be adequate to meet peak demand periods,not just average demand. In such cases, the demand for public facilities was based on peak season resort occupancy,rather than average occupancy. The terms "gross" and "net"are used to describe costs and revenues in this report. In the case of costs,a gross cost would be the total cost to provide a particular facility or service,while the net cost would be the gross cost,minus any payment or revenue from the resort towards that facility or service. In other words, it is the balance of costs after any revenues are deducted. Tax revenues are treated as gross revenues because they are used to pay for government costs. The net revenue for a particular service, if any, is the surplus left over after the costs of providing the service are deducted. The fiscal impact reporting begins by evaluating the revenues the resort is likely to generate from property taxes and room taxes.Then the costs are addressed. And finally, the costs are compared with the revenues to determine net impacts. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 16 4. Revenues from the Thornburgh Resort A significant selling point for new destination resorts has been the tax revenues they will generate for county governments. As described later, increased tax revenues are offset by increased costs for public facilities and services required by the resort. In this analysis, both property tax revenues and transient room tax revenues are estimated for the proposed Thornburgh Resort. Property Taxes The Thornburgh Resort Company LLC submitted a report by Peterson Economics, of El Cerrito,California,which provided their estimate of property tax revenues,but made no estimate of room taxes. The property tax revenue estimate provided by the developer was approximately three times greater than the revenue calculated here. This was partly due to use of overinflated real estate values that may have seemed realistic during the 2004-2005 boom period,but are out of line with current real estate prices and the assessed values at the nearby Eagle Crest Resort."The annual property tax figures by Peterson were also inflated at an annual 3% rate over the 12- year construction phase so that the final annual tax revenues at completion were given for the year 2016 and are much higher than they would be today. The taxes calculated here are based on the revenues that would be generated if the resort were fully completed in 2008 under the 2008-09 tax rates. Tables 4-1 and 4-2 summarize the estimated property tax revenues from the residential and commercial properties planned for the Thornburgh Resort. The combined total property tax revenues are$5.1 million per year based on a total assessed value of approximately$375 million,as shown in Table 4-3.14 The$5.1 million tax revenue estimate is about one-third of the amount estimated by the applicant in the Peterson Report.15 However the figure calculated here is in line with data reported by other sources for actual tax revenues from other resorts.16 In order to determine where tax revenues will go in Deschutes County, the individual tax rates for each taxing district applicable to the resort were used and the Eagle Crest Resort is considered to be comparable to the proposed Thornburgh Resort in terms of its real estate values. 14 Assessed values are for tax purposes and not the same as real market values. For comparison purposes,the tax revenues estimated by the applicant in the Peterson Report were adjusted from the 2016 buildout year back to 2008,resulting in an estimate by Peterson of 17,500,000 per year. 16 Tax revenues were reported for 2005-06 tax year by Linda Swearingen(a lobbyist and consultant for destination resorts)for various resorts in a presentation to the League of Women Voters, November 2005. She reported annual tax revenues for Eagle Crest at$4,096,058 and for Black Butte at$6,315,414. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 17 results provided in Table 4-4. Technical details on the methodology used for property tax calculations are provided in the Appendix to this report. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 18 Table 4-1 Estimated Property Tax Revenues from Residential Properties at Thornburgh Resort no Assumes lull buildout and 2008-09 tax rates and property values) Estimated Real Markel Value per Unit 151 Property Type Number Lot 01 Improvements Total Assumed AV Property Tax Property Taxes Property Taxes of Units 01 per Unit on Rate III Single Unit 191 for Type 1"1 ResidentialOvemight0" 425 $190,000 $320,000 $510,000 $250,410 14.0041 3,507 1,445,665 Resit 0wner-0ccup.t"I 950 $190,000 $320,000 $510,000 $250,410 14.0041 3,507 3,231,485 Total 4,577,150 Notes: 1)Housing Data Is from the table on page 22 of the Revised application dated April 21,2008.RMV values derived from data on Deschutes County's D.I.A.L system. 2)This table Includes at single family residential property regardless of ownership or deed restriction. 3)Real Market Value(RMV)is the full appraised value of the land and/or Improvements.Willie tracked It is not used to calculate taxes. 4)Assumed Lot value derived by taking 80%of the average value of the RMV far Land as taken from Deschutes County's D.I.A.L system for a 38-lot sample of lots located at Eagle Crest.Reduction in value is intended to reflect declining prices In real estate markets.See Property Tax Methodology in Appendix for details. 5)Assumed Improvement value derived by taking 80%of the average value of the RMV for Improvements as taken from Deschutes County's DIAL system for a 35-house sample of houses located at Eagle Crest.Reduction In value is intended to reflect declining prices in real estate markets.See Property Tax Methodology in Appendix for details. 6)A voter passed Initiative In 1996 rolled the assessments of real properly back to their 1995 level minus 10%and limited annual increases to 3%,Assessed Value(AV)is the result.a Is the value used to calculate the properly taxes due on a parcel. 7)Oregon State Law(ORS 308.153)requires that the real market value of new property be adjusted by the application of a Exception Value Ratio to establish the amount that is to be added to the Maximum Assessed Value of a properly.The Exception Value Ratio lur Resort Properties Is 49,1. 8)In dollars per thousands dollars of Assessed Value.The property fax rate is that of Tax Code Area 2-004.While some of the proposed development Is en parcels that currently are In Tax Code Area 2-003 it has been assumed that when Deschutes County Rural Fire Protection District#1 takes over Ike and rescue responsibilities for those properties that they will changed to Area 2-004. 9)Assumed Assessed Value(AV)times Property Tax Rate. 10)Calculated from'Propery Taxes Single Unit'limes'Number of Units'times 0.97(to reflect 3%reduction for on-time payment). 11)Units subject to a deed restriction requiring that N be available for short term rental at least 38 weeks a year,As the Residential Overnight housing units are needed to meet the Visitor-Oriented Units to Individually-owned Residential Unit Ratio in Deschutes County Code 18.113,060 D 2,It has been assumed that they will at be built. 12)The amount of Residential Single Family Housing not subject to a deed restriction requiring it he avatable for short term rental at least 38 weeks a year.This table was also run assuming a 90%build out of these units,which showed an annual property tax payment of$4,453,593.68. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 19 Table 4-2 Estimated Property Tax Revenues from Commonly held and Commercial Property at Thornburgh Resort") Assumes full buildout and 2008-09 tax rates and property values) Estimated Real Markel Value per Unit ni Property Number Assessed Property Tax Property Taxes Taxes for Property Type of Units Lot tai Improvements 01 Total Value011'1 Rate m Single Unit Typel'ar Hotel and Conference center 0) 1 $2,169,000 $15,000,000 $17,169,000 $8,429,979 $14.0041 118,054 $114,513 Golf Club House lot 2 $578,400 $4,000,000 $4,578,400 $2,247,994 $14.0041 31,481 $61,073 Golf Course 1101 3 $1,949,850 $3,000,000 $4,949,850 $2,430,376 $14.0041 34,035 $99,043 Spa Facility 1'l 1 $433,800 $5,000,000 $5,433,800 $2,667,996 $14.0041 37,363 $36,242 Recreation Center 02) 2 $723,000 $3,000,000 $3,723,000 $1,827,993 $14.0041 25,599 $49,663 Commerical Development I") 1 $578,400 $4,000,000 $4,578,400 $2,247,994 $14.0041 31,481 $30,537 Real Estate Office X191 1 $433,800 $3,000,000 $3,433,800 $1,685,996 $14.0041 23,611 $22,903 Total: 413,973 Notes 1) Data for this table was obtained horn the Thornburgh Application dated 4-21-08,the Deschutes County D.I.A.L system and cited sources. 2) Real Market Value(RMV)is the full appraised value of the land and/or improvements.While tracked,it is not used to calculate taxes. 3) Lot Area assumed to be twice budding area.Land value of$629,744 per acre for all land other than the Golf Course.This value is 80%of the 2008 RMV tar the developed commercial parcel at Eagle Crest.The reduction In value Is to reflect declining real estate values.See Properly Tax Methodology in Appendix for details. 4) Building value assumes a$200 sq It construction cost for buildings and$3 melon per golf course.The$3 million dollar figure is the midpoint at the$1.6 to 4.5 million construction cost range quoted or the USGA and American Society of Golf Course Architects web sites. 5) A voter passed initiative in 1996 rolled the assessments of real property back to their 1995 level minus 10%and limited annual increases to 3%,Assessed Value(AV)is the result.h Is the value used to calculate the properly taxes due on a parcel. 6) Oregon State Law(ORS 308.153)requires that the real madder value of new properly be adjusted by the application of an Exception Value Ratio to establish the amount that is to be added to the Maximum Assessed Value of a property.The Exception Value Ratio for Resort Properties Is 49.1, 7) In dollars per thousands dollars of Assessed Value.The property tax rale is that of Tax Code Area 2-004.While some of the proposed development is ass parcels that currently are In Tax Code Area 2-003 h has been assumed that when Deschutes County Rural Fire Protection District#1 takes over fire and rescue responsibilities for those properties that they will changed to Area 2-004. 8) 75,000 sq It budding on a 150,000 sq ft lot.Includes Hotel,Restaurant,Bar and Convention Facilities. 9) 20,000 sq lf Wilding on 40,000 sq Slot Includes Locker Rooms,Pro Shop and Food Service Area. 10)Assumes 150 acres per course.The land value used of$12,999 an acre was obtained by taking the average RMV of five large parcels at Eagle Crest Identified as containing golf holes. 11)25,000 sq ft of buildings on a 50,000 sq ft lot.Includes Fitness Center,Sauna and Steam rooms,Massage area. 12) 15,000 sq ft of buildings on a 30,000 foot lot. 13)20,000 sq ft of buildings on a 40,000 sq ft lot.Includes Bank,Florist Shop,Drug Store.Grocery,Dry Cleaner and Art Gallery. 14) 15,000 sq S of buildings on a 33,000 sq 11 lot.Includes Sales Leasing and Property Management Offices. 15)Taxes reduced by 3%for ontime payment. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 20 Table 4-3 Estimated Total Property Tax Revenues from Thornburgh Resort Assumes full buildout and 2008-09 tax rates and property values) Property Type Total Assessed Value Annual Property Taxes Residential Property 344,313,750 4,677,150 Commercial Property 30,475,067 413,973 Totals: 374,788,817 5,091,123 Table 4-4 Distribution of Property Tax Revenues by Taxing Districts for Thornburgh(') Assumes full buildout and 2008-09 tax rates.Thornburgh estimated total assessed value of$374,788,817) ID Tax District Tax Rate Property Taxes(2) 001 Deschutes County 1.2783 464,720 007 Jail Bond 0.1335 48,533 010 Fairgrounds Bond 0.141 51,260 011 County Library 0.55 199,950 020 Countywide Law Enforcement 0.95 345,368 021 Rural Law Enforcement 1.4 508,963 070 Redmond Library 0.0567 20,613 090 County Extension/4H 0.0224 8,143 093 911 0.1618 58,822 095 911 Local Option 2008 0.23 83,615 202 Rural Fire District #1 1.7542 637,731 351 Redmond Area Park& Rec District 0.3717 135,130 620 School District #2J 5.0251 1,826,851 626 School #2J Bond 92 &93 0.8307 301,997 628 School #2J Bond 2004 0.293 106,519 651 High Desert ESD(3) 0.0964 35,046 670 COCC(4) 0.6204 225,543 671 COCC Bond 0.0889 32,319 Total 14.0041 5,091,123 1)Tax rates from Deschutes County 2008-09 Summary of Assessment and Tax Roll page 80. 2)Tax revenues= (AV/1000)x Tax Rate x 0.97,Amount to taxing districts assuming the properly owner takes advantage of the 3%discount for paying in full prior to 15 November. 3)High Desert Educational Service District. 4)Central Oregon Community College. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 21 Room Taxes Transient Room Tax revenues are generated from hotels and other overnight lodging facilities in Deschutes County. The tax rate is 7%of the total room charge payable to the County. As shown in Table 4-5,the estimated room tax revenue from the Thornburgh Resort is$430,296 per year. A complete technical explanation of room tax calculation is provided in the Appendix to the report. Currently room tax revenues are allocated to rural law enforcement and tourism,as shown in Table 4-6. Table 4-5 Estimated Transient Room Tax Revenues from Proposed Thornburgh Resort Assumes full buildout and 2008-09 tax rates and rental rates) Number Daily Estimated Estimated of Room Occupancy Tax Daily Tax Annual Tax Type of Unit Units111 Rateeee Rate Ratet4l Revenueist Revenuefbf Hotel Rooms 50 $121 29% 7% 123 44,827 Residential Overnight Unitsm 425 $162 29% 7% 1,398 $408,115 Subtotal: $452,943 Less Collection Reimbursementtat: ($22,647) Revenue to County: $430,296 1.Number of Units available as Visitor-Oriented Units is taken from page 4 of the Revised Application dated April 21,2008. 2.Estimated Average Room Rate subject to the Room Tax.The rate for the Hotel is based on a weighted average of the rates for Hotels,Motels and Inns located in the Greater Redmond Area.The Inn at Eagle Crest showed standard room rates of$95 to$126 per night,depending on season.The rate for Residential Overnight Units is the average of the daily rate for 39 units in the Greater Redmond Oregon Area currently listed on the Vacation Rentals by Owner website for the area.Twenty-eight of these were located in Eagle Crest Resort. 3.While the total monthly Transient Room tax receipts are available,actual occupancy data Is extremely difficult to come by.So an occupancy rate of 90% was assumed for the month of August and then adjusted for the other months based on Total Transient Room Taxes paid to the County for that month.From this an average annual occupancy rate of 29%for all rental types was derived. This table was also run assuming an annual occupancy rate of 100%,and 50%for both types of units.The resulting estimated revenue for Deschutes County was$1,818,010 for 100%and $909,005.13 for 50%annual occupancy rates. 4.The current Tax rate as set by Deschutes County Ordinance. 5.The number of units limes the occupancy rate,times the daily room rate,times 7%. 6.The estimated Daily Tax Revenue times 365 days.For residential units,an 80%reporting rate for room taxes was assumed.100%reporting was assumed for hotel rooms. 7.425 is the number of units that would be subject to a deed restriction requiring that they be available for Short Term Rental at least 38 weeks a year.It is possible that some of the owners at the other 950 housing units in the resort might also want to rent their units at least some of the time,so the actual number of available rental units could be higher. 8.Deschutes County Code 4.08.120 requires the operator to bill the transient for the Room Tax as a separate line item on the invoice or receipt and allows the operator to retain a Collection Reimbursement Charge of up to 5%of all revenues collected.While it is possible for an operator to retain less then the full 5% permitted,for the purposes of this estimate a full 5%has been assumed. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 22 Table 4-6 Distribution of Room Tax Revenues to County Assumes full buildout and 2008-09 room tax rates and rental values) Share 1 Amount For Rural Law Enforcement 73% 314,116 For Tourism-Related Activities 27% 116,180 Total Room Tax Revenue 100% 430,296 1)This distribution assumes the same 73-27%split as was used in the FY 2008-09 Budget for the County. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 23 5. Thornburgh Resort Costs This section examines the fiscal impacts of the proposed Thornburgh resort on the following six major service categories: Transportation System Schools Fire & EMS Public Safety System Parks & Recreation System General Government As described previously,costs occur in two basic categories: 1. Capital Costs: Initial,one-time costs for the increment of new or expanded capital(facilities,infrastructure and equipment) necessary to provide adequate levels of service to the resort; and, 2. O&M Costs: Annual costs for operation and maintenance(O&M) of the services provided to the resort. The capital costs for expanding facilities,infrastructure and equipment were calculated for all six of the above service categories. These capital costs tend to be the greatest costs associated with serving new development. The O&M costs for providing services were calculated for fire/EMS,public safety, and parks and recreation. The tax revenues for each of these service areas were also determined, so that service costs could be compared with revenues. For transportation and schools, revenues come from multiple sources(County, State and Federal)and are allocated based on formulas described in the following sections. Since revenues for these two categories could not be tied directly to the resort,it was not possible to compare the annual O&M costs with the revenues resulting from resort development. O&M costs were not calculated for general government services due to the complexity of assigning service costs to the resort. The cost impacts the resort will have on these systems may be offset by tax revenues and impact fees or mitigation fees the resort will pay. The only impact or mitigation fees identified in this study are related to the transportation system. Deschutes County enacted transportation SDC(system development charge) in 2008. The Oregon Department of Transportation (ODOT) is seeking mitigation funding from the resort for impacts to intersections with state highways. Both of these potential revenues are computed and deducted from the transportation system costs. The County collects no other impact fees and the Redmond School District collects no impact fee from new development. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 24 The Thornburgh Resort is also credited with future tax payments that could potentially go towards repaying bonds for the infrastructure needs the resort creates. A new destination resort will increase the local tax base,which will distribute the bond repayment cost more widely. For example,if a new resort increases the local tax base by 5%, it will pay for 5%of the bond costs. The remaining 95%will be paid by the existing community. However, it is the new development that is creating the demand for new facilities that are calculated in this study,not the existing community. Therefore, new development will pay for only a fraction of the facility costs it creates (1/20th in this example). The actual 2008/09 tax bases for each category of service and the potential contribution of the resort towards future bond repayments is provided in the Appendix. To aid in calculating some costs, an estimate of the number of houses used as primary residences at the Thornburgh Resort and an occupancy rate of these residences was developed. Average occupancy per household in Deschutes County was 2.5 persons per the 2000 Census. The Census data is for all existing housing, and therefore does not accurately reflect the occupancy of new housing. New housing is typically larger than the average of exiting housing and typically has more occupants per unit. The American Housing Survey provides data on new homes for major cities in the US. The nearest city survey is for Portland where new housing units were found to have 8.2% higher occupancy levels than for all existing units."This same adjustment was applied to Deschutes County to produce an estimated household occupancy rate of 2.7 persons per new house. The percentage of housing in destination resorts used as primary residences has been the subject of some debate. Resort housing could be used for a primary residence,a second home(or vacation home), or a rental home (overnight unit). Undoubtedly, the mix of home uses will vary from resort to resort. The nearby Eagle Crest Resort appears to have a very similar profile to the proposed Thornburgh Resort and was used to establish a likely percentage of owner-occupied homes serving as primary residences. A complete tabulation of residential properties at Eagle Crest was generated by Deschutes County from County tax assessment data." There were 1,538 residential properties that were developed with homes on the tax rolls. Of these, 559 property owners received tax statements at their Eagle Crest address. Tax statements are usually sent to the property owner's primary residence, so this is highly indicative of a primary residence address. American Housing Survey for the Portland Metropolitan Area:2002,Issued July 2003,U.S.Department of Housing and Urban Development. Result from this tabulation were provided in Excel format to COLW by Tim Berg,Deschutes County Community Development Department on February 26,2009. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 25 According to a survey provided to the County by Eagle Crest Resort, an estimated 252 of the single family homes in the resort were being used as overnight units rental units)in March of 2008."Deducting the 252 overnight units from the 1,538 total residential units leaves 1,286 owner-occupied units(both primary residences and second homes). Based on the addresses of the tax statements, the 559 primary residences represent 43%of the 1,286 owner-occupied units. The actual percentage of primary residences will be higher if some resort residents have tax bills sent to a post office box or to an accountant's address. 19 Letter from Alan VanVliet of Jeld-Wen Development to Catherine Morrow providing results of an annual housing survey,dated March 25,2008. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 26 Transportation System Costs A key issue in destination resort development is the demand they place on the transportation infrastructure.The new travel demand generated by resorts creates costs for the required transportation infrastructure. The full cost of the transportation infrastructure to serve new growth is reflected both in the new infrastructure that must be built and in the existing capacity that is consumed. Travel demand is a function of both the number of new vehicle trips generated and the average trip distance. The combination of the number of daily trips and the average distance of trips results in the daily"vehicle miles traveled" or VMT. VMT reflects actual roadway usage,and therefore provides a good measure for allocating transportation system costs. Another measure of travel demand is"peak-hour trips,"which is intended to reflect demand on the system during the peak period. Peak-hour trips are widely used in transportation studies because they provide an indication of transportation system conditions at the busiest time of day. However, as roads become more congested, travelers shift their travel times to avoid congestion. Instead, they contribute to congestion at other times. As transportation systems become more and more overburdened,peak congestion periods extend to multiple hours and can occur throughout the day. One deficiency of peak-hour trips is that they only capture those trips generated at the peak hour(usually 5-6pm weekdays) and miss traffic generation at other times. Schools,for example generate considerable traffic at other hours. Resorts will also generate most trips at other hours for golf and other recreational activities. With this measure, traffic sources that do not generate peak-hour trips are not counted as impacting the transportation system, despite increased travel demand. Peak-hour trips are based on the peak traffic hour of the adjacent roadway,and not the peak for the source of the trips being studied. Destination resorts are typically sited in relatively remote locations outside of Urban Growth Boundaries(UGBs)and away from existing cities and towns. Due to their remote locations, residents and guests will travel farther to reach common destinations, such as employment,grocery stores, department stores,etcetera. As a result,VMT generation will tend to be higher per unit of development than it would be in an urban location. Studies show that even in urban areas, the per capita VMT increases by a factor of two to three,or more on the urban fringe compared with the urban core. Daily per- capita VMT was found to be two to four times greater in the Atlanta suburbs than in Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 27 the city's core area 20 Similar findings were obtained for Eugene-Springfield in a 1994 travel study by Lane Council of Governments.' According to a study in Rhode Island (1999), rural towns had on average 16.5 miles of local roads per 1,000 housing units,or almost three times as many as urban core communities (6.1 miles per 1,000 housing units).22 Figure 5-1: Time of day for trips in rural Oregon (Oregon Travel Behavior Survey, ODOT, 2000) s0 s r., re It, Zs' R N ,F 4, e H'i . 1 W y Wom' 'u . Based on the Oregon Travel Behavior Survey,23 Deschutes County's rural households reported an average of 7.31 daily vehicle trips. This is lower than the 9.57 trips that would be estimated using the ITE Trip Generation manual.24 Average rural trip time was 16.52 minutes. While this trip time is comparable to that in urban areas, rural trips will tend to cover more distance and be at a higher average speed, requiring 20 Source: Atlanta Journal-Constitution, 12/9/02,based on data from Georgia Regional Transportation Authority. 21 1994 Estimated VMT per Capita by Production Zone,by Lane Council of Governments. 22 The Costs of Suburban Sprawl and Urban Decay in Rhode Island,Executive Summary,by Grow Smart Rhode Island, 1999,Providence,RI,The Rhode Island Foundation. 23 Oregon Travel Behavior Survey,ODOT,2000,Table 4.2.According to ODOT,survey data involves some underreporting,so actual daily trip will be higher than reported(see footnote,page 9 of Oregon Travel Behavior Survey). 24 Institute of Transportation Engineers'reference manual for trip generation,8th Edition. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 28 more road infrastructure. If an average rural speed of 40 mph is assumed, the average trip distance would be 11 miles and household VMT would be 80.5 miles per day.' The Cost of Transportation Facilities The "projection-based" method for estimating transportation system costs uses a planning estimate or projection of the future system improvements that are needed as a basis for allocating costs to the new development that will occur over the planning period. The County has prepared a 20-year list of transportation projects as part of its adoption of a new transportation System Development Charge(SDC) in 2008. This list covers all projects in the unincorporated areas of the County that are anticipated from 2008 to 2028. The total cost of all projects is $280 million. Project costs are funding by a mix of County, State and Federal sources. Most of these projects are capacity-increasing and will serve the needs of new growth in the County. However, a portion of the projects are maintenance-related and will not expand the system capacity. Only a very brief description is available to characterize each project on the 20-year list and no further information was available from the County. A simplified system was used to allocate individual project costs between capacity expansion and maintenance functions. New roads were allocated 100%to meet the needs of new growth. New bridges were allocated 75% to new growth. Road "widening and overlays"and "road reconstruction and widening," were allocated 50%to new growth. None of the costs for pedestrian and bike lane improvements were allocated to growth as they were considered system-wide upgrades. Based on this cost allocation,$240 million or 86%of these costs are growth-related capacity increasing),while$39 million,or 14%are for maintenance. Table 5-1 provides a summary of the project cost allocation. As shown in column 5 of Table 5- 1, Deschutes County will fund less than one-third of growth-related transportation facilities,while the State will fund two-thirds. (The Federal funding is shown as being fairly small,but Federal transportation funds that are distributed by the State are listed under the State funding,so the actual Federal contribution is larger than shown.) 25 The average speed of 40 mph was used to reflect overall average trip speed,including stops,starts and turns on roadways with typical 55 mph speed limits.This was intended to be conservative,as higher trip speeds would result in longer travel distances and greater road costs. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 29 Table 5-1 20-year Transportation System Project List for Unincorporated Area of Deschutes County(2008-2028)" 1 2 3 4 5 6 7 Percent Percent of Growth Cost per Total Project of Total Growth-Related Growth Cost per Typical New Funding Entity Costs Costs Project Costs Costs Capital')Houset41 Deschutes County $96,614,339 35% 70,165,715 29% 2,273 6,137 State of 0regont 1 $157,500,000 56% 157,500,000 66% 5,102 13,775 Federal Gov.t2i 25,431,250 9% 12,715,625 5% 412 1,112 Totals: 279,545,589 100%240,381,340 100% 7,787 21,024 1)Source:Deschutes County SDC Project List,2008. 2)State funding includes funds from the Federal Government to the State so this distribution only shows final source of funds. 3)Growth-related costs are divided by the projected population increase over the same 20-year period. 4)Costs associated with new house are based on an occupancy rate of 2.7 persons,as described earlier in this section of the report. The per-capita cost for population growth can be estimated by allocating the growth- related (capacity increasing) components of the County's total future transportation system costs for the next 20 years($240,381,340) to the estimated population increase for the same period. During this time period the population of the unincorporated County is projected to grow from 56,609 in 2008 to 87,480 in 2028, an increase of 30,871 people.26 This results in a cost of$7,787 per new person column 6 of Table 5-1). The County's share of this cost is$2,273 per person. The cost per new house can be estimated based on the typical occupancy rate of 2.7 persons per new house(calculated earlier). At this occupancy rate,the total cost per new house is$21,024. The County's share of this cost is$6,137 per new house. A new transportation System Development Charge(SDC) was approved by Deschutes County in July of 2008 to help recover a portion of the County's share of capacity-increasing transportation costs. While the State SDC Statute27 allows for a reimbursement component, the County's fee does not include a reimbursement component to recover the cost of existing roadway capacity that will be consumed by future growth. The SDC fee will be phased in gradually up to $3,504 per new peak- hour vehicle trip by 2011. Fora new single-family dwelling, 1.01 peak-hour trips are generated and the SDC is$3,539 per SFD (not including the$45 administrative charge allowed by State Statute). Deducting the SDC(full 2011 rate)from the County's gross cost per new house($6,137) results in a net transportation system cost to the County of$2,598 per new house for the capacity-increasing components. 26 Based on Deschutes County 2000-2025 Coordinated Population Forecast.The forecast was extended to 2028 using the growth rate for the 2020-2025 period of 2.2%/year. ORS 223.297-314. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 30 Reimbursement Value of Existing Transportation Infrastructure As noted, the Deschutes County SDC project list does not address the value of transportation infrastructure capacity that has already been built that will be consumed by new development(also referred to as "excess capacity"). If average roadway congestion levels on existing roads did not increase over the 20-year project timetable,then there would be no loss in mobility(or increase in congestion), and therefore no "consumption"of existing excess capacity. However,it is unlikely that the County will be able to build enough new facilities to prevent such congestion increases. Nationwide the roads have become increasing congested as cities, counties and states across the country have been unable to keep up with demand.23 To investigate changes in traffic levels on existing roadways, historic traffic count data must be analyzed. The County's traffic count data reports Average Daily Traffic ADT)for 281 roadway segments.29 Data was obtained from the County for the 11- year period, 1998 to 2008. Data was not available for every year for every segment,so the average of the traffic counts in the first four years(1998-2001) was compared with average of the last four years(2005-2008). Only the 212 road segments that had traffic counts in both time periods were analyzed. The results show that traffic increased from an average ADT per road segment of 1,473 to 1,780,an increased volume of 20.8%on County roads in a roughly seven-year span.30 It is therefore reasonable to conclude that new development in the County is generating transportation system demand faster than the County is building new capacity and that new development is consuming existing excess road capacity. There is no data on the existing excess capacity of County roads. The County's Level-of-Service(LOS) standard for rural roads is "D" or better. A LOS of D represents average daily traffic(ADT)of up to 9,600 vehicles for a two-lane road. Therefore,9,600 vehicles is the effective capacity of the roadway under the LOS standard. The County's 1996 Transportation System.Plan shows ADT and LOS for the 36 busiest roadway segments in the County at that time. None of the segments exceeded a LOS of D and most were rated B or C with 3,000 to 5,000 ADT. Based on this somewhat dated data, it appears that the County had more than 50%excess capacity on its main road network in 1996.31 zs The 2007 Urban Mobility Report,by the Texas Transportation Institute reports that over last 24 years we have built only 41%of the transportation infrastructure necessary to keep up with growing demand. 29 A sample of this data can be found on the Deschutes County Road Department web site at http://www.co.deschutes.or.usklownload.cfm?DownloadFile=0D81 3 SCF-BDBD-57C 1- 98378109FA737581.The full data set was used for this study. 30 This increase in traffic occurred over a period of approximately seven years,based on using the midpoint of each of the two periods compared.The period is approximate because traffic count data was not available for all years. 31 The more-recent County traffic count data referred to earlier shows an average ADT at 212 road locations of 1,780 for the 2005-2008 period.If all of these roadways have a capacity of 9,600 ADT, Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 31 The value of the County's excess roadway capacity is significant,however, due to data limitation there is no direct way to accurately determine either the value of this capacity or the amount that will be consumed by new development. However,rather than leave this cost area completely unaddressed,a very rough, but conservative estimate was developed. To make this estimate,the following rough assumptions were used: 1. Excess capacity in 2008 is at least 40%of existing roadways. 2. New development over the next 20 years will consume half of the remaining excess capacity. 3. The value of the excess capacity can be indexed based on its replacement costs today and the population increase served by the total value of the capacity- increasing projects on the SDC project list. To roughly estimate the replacement value of the existing transportation system it was assumed that the value could be based on the estimated costs necessary to serve future population growth. The value of the growth-related (capacity increasing) projects in the 20-year SDC project list is$240,381,340. This results in a cost of 7,787 for each new person projected in the County over the 20-year period. Applying the per-capita cost to the 56,609 persons currently living in the unincorporated County in 2008 results in an existing system value of$441 million. This figure is the approximate replacement value for the system required to serve today's population. The figure is low,since it does not account for building the excess capacity that exists today. None-the-less,as a very rough estimate, the value of excess capacity consumed over the next 20 years is 20%of$441 million,or $88 million. Dividing$88 million by the projected population growth over the next 20 years of 30,871 people, results in a reimbursement cost of$2,856 per new person. Based on an occupancy rate for new homes of 2.7, the reimbursement cost per new home is$7,711. Table 5-2 combines the value of new facilities and the value of excess capacity used to serve new growth in the unincorporated area of the County. As shown,total transportation system costs(from all funding sources)for new growth are $10,637 per person, $28,720 per new house,and $3,929 per daily vehicle trip. Note that the estimates in Table 5-2 are based on planning projections and are therefore only as accurate as the projections they are based upon. then there is approximately 80%excess capacity in the road network.However,the data is not adequate to assess the actual capacity of each roadway segment. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 32 Table 5-2 Estimated Transportation System Costs to Serve New Growth for Unincorporated Area of Deschutes County(2008-2028) County Costs State Costs151 Federal Costs Total Costs Value of New Capacity for Future Growth(1) 70,165,715 $157,500,000 $12,715,625 $240,381,340 Value of Existing Capacity Consumed12) share unknown share unknown share unknown $88,000,000 Total Growth-Related Costs share unknown share unknown share unknown $328,381,340 Cost per Capita for New Population13) 10,637 Cost per New Housej4) 28,720 Cost per Daily Vehicle Trip(5) 3,929 1)Derived from Deschutes County SDC Project List,2008, 2)Rough estimate based on estimated excess system capacity consumed by new growth. 3)Growth-related costs are divided by the projected population increase over the same 20-year period. 4)Cost associated with new house are based on an occupancy rate of 2.7 persons,as described at the beginning of this section. 5)Based on the Oregon Travel Behavior Survey,Deschutes County's rural households reported an average of 7.31 daily vehicle trips. 6)State funding includes funds from Federal Govemmentto the State so this distribution only shows final source of funds. Transportation System Impacts of Thornburgh Resort Estimating the transportation system impacts associated with a destination resort is more complex because standardized data on destination resort travel demand is unavailable and the use has unique characteristics. These resorts contain a variety of commercial and residential uses. The commercial uses cannot be readily estimated from the same per-capita basis used for residential land uses. Also,resorts will accommodate a certain percentage of vehicle trips internally. Internal trips are those that do not leave the resort,and would include residents visiting the golf course or resort restaurant. Since the road structure within the resort is funded entirely by the resort developer,these internal trips do not create an impact on the external public road system. There are various estimates for the number of external vehicle trips generated by resorts. The Thornburgh Resort submitted their own traffic study showing that a vast majority of vehicle trips would be accommodated internally and that the resort would generate a total of 517 peak PM hour trips(5-6pm weekdays).32 However, the peak PM trips" metric failed to capture the peak trip generation by the resort, which occurred earlier than for the adjacent roadways. Peak resort traffic occurred between 1pm and 4pm. 32 Transportation Impact Analysis,Revision II,by Group McKenzie,September 28,2005,Table 9B. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 33 A study by Kittelson and Associates33 measured the traffic generation from the nearby Eagle Crest Resort by counting trips in and out of the resort for several weekday periods. The study concluded that 4.4 offsite trips are generated per residential unit and suggested that this is an appropriate value to use for destination resorts. These trip counts include all the commercial and recreational activities at the resort,as well as the residences. Therefore,they are an indication of the total trip generation by the resort, indexed to the number of residential units. The Thornburgh Resort has 1,375 residential units. Based on the Kittelson Study, the resort would generate at total of 6,050 daily vehicle trips. These would all be external,or offsite trips. For comparison purposes, the trips were estimated using standard trip generation rates for conventional development(see Table 5-3). As a conventional development, the uses at Thornburgh would generate approximately 17,054 daily vehicle trips. However,since destination resorts are likely to accommodate more vehicle trips internally than conventional developments, the empirical data from Kittelson was used instead. Using the estimate based on the Kittelson Study of 6,050 daily trips and the cost per vehicle trip of$3,929 from Table 5-2, the total gross transportation system cost associated with the resort is $23.8 million. To obtain a net cost for the Thornburgh Resort, SDC payments and developer contributions to the transportation system must be deducted. That step is done at the conclusion to this section. Table 5-3 Conventional Trip Generation Estimate for Thornburgh Destination Resort') Expected Expected Daily Description (ITE Code)Unite) Units Trips Single Family Homes (210) DU 1,375 13,159 Hotel (310) Rooms 50 446 Health/Fitness Club (493) TSF Gross 60 1,976 General Office (710) TSF Gross 15 165 Shopping Center (820) TSF Gross 20 859 Quality Restaurant (931) TSF Gross 5 450 Total Trips: 17,054 1)Based on ITE Trip Generation manual,7"Edition. 2)DU=dwelling units;TSF=thousand square feet of gross floor area. 33 Central Oregon Resort Trip Generation Study,by Kittelson and Associates,September 12,2006. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 34 Standards-Based Costing Method The transportation system costs calculated above in Table 5-2 are based on the projected population growth of the County and the projected transportation infrastructure needs for the next 20 years. Both projections are estimates for a long period of time and could involve substantial errors. It is notoriously difficult to estimate future population growth,but it is even more difficult to anticipate and accurately estimate all the transportation infrastructure needs for a county 20 years into the future. To examine the transportation system costs from another perspective, a standards- based impact analysis was performed. This method is based on meeting County level-of-service(LOS) standards. Travel demand was used to determine the number of new lane-miles of roads that are needed to serve new homes. A roadway cost per- lane mile was developed and the number of lane-miles required by new development was used to estimate road costs. Estimates of new road costs were not available from Deschutes County,so road costs per lane-mile were compiled from three sources, including the County SDC project list and ODOT in order to develop a reasonable estimate. Values for two-lane,rural roads on flat terrain were selected. As shown in Table 5-4, the average cost per new lane-mile for all sources is $3.4 million. The seven new roads on the Deschutes County Transportation SDC Project List were used to develop one road cost estimate. The average cost of these roads per lane-mile was $3 million. The cost for one road segment included an overpass, so that some other roadway costs are included as well. Representative road costs should include the costs of intersections, signalization,bridges, and other associated system costs. For comparison, Table 5-4 shows the road costs for a rural road on flat terrain from ODOT's Highway Economic Requirement System ($2.7 million/lane-mile) and an estimate for rural roads from the Victoria Transportation Policy Institute ($4.5 million/lane-mile). These figures bracketed the Deschutes County road costs, so the 3 million per lane-mile figure was used for road costs. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 35 Table 5-4 Road Cost Estimates from Various Sources All costs adjusted to 2008 dollars) Cost per Lane-Mile Construction Land Source Cost Acquisition Cost Total Cost New Roads in Deschutes Co. SDC Project List(t) $2,807,982 240,000 $3,047,982 0D0T New HERS Improvement Costs(2) 2,461,980 240,000 $2,701,980 Victoria Transportation Policy Institute(3) 4,199,040 263,340 $4,462,380 Average of Sources:3,404,114 1)Average cost for new roads on list.Land values based on total road ROW width of 80 feet and land acquisition costs of$50,000 per acre. 2)MOT New Highway Economic Requirement System(HERS)Improvement Costs,lane-mile costs for constructing new rural major collector on flat terrain. 3)Source:VTPI Transportation Cost and Benefit Analysis II—Roadway Costs,Table 5.6.3-4,January 2009.Value for undivided highways in outlying areas.Year 2000 dollars were adjusted to 2008 using Oregon Highway Construction Cost Trends. As described earlier, the Oregon Travel Behavior Survey provides the best available travel demand data for rural households in the unincorporated area of Deschutes County. From this survey data it was estimated that the average daily rural household VMT is 80.5 miles. To translate this into a lane-mile demand for new roadways,a level-of-service standard must be assumed. The County's minimum LOS standard of"D" represents the maximum congestion limits acceptable on County roads. The ADT at LOS D is 9,600 vehicles. A two-lane roadway operating at LOS D could accommodate 4,800 vehicles per day per lane in each direction. At this congestion level, the lane-mile distance required to accommodate the 80.5 miles of daily VMT generated by the typical rural household is 0.017 lane-miles. The cost of building 0.017 lane miles at$3 million per lane-mile, is $51,000 per new household. To maintain a higher LOS standard of"C"(ADT of 5,700,closer to what County residents now enjoy), requires 0.028 lane miles per new household,or$84,000 in new road system costs per new household. The costs on a per-trip basis are shown for both LOS standards in Table 5-5. While costs of$51,000 to $84,000 per household may seem incredibly high, they should be adjusted even higher to reflect the higher occupancy rate that can be expected in a new home compared with the average of existing homes from which the travel survey data was derived. Using the 8%higher occupancy rate of a new house relative to an existing house,the costs would be$55,000 to $90,700 for LOS of D and C respectively. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 36 Table 5-5 Standards-Based Transportation System Costs per New Vehicle Trip Cost Per Household Cost Per New Vehicle TripP Cost to maintain LOS "D" 51,000 6,977 Cost to maintain LOS "C" 84,000 11,491 1)Based on 7.31 trips per household reported for Deschutes County in the Oregon Travel Behavior Survey. These standards-based costs are much higher than the$28,720 per new house cost estimated by using the County's 20-year projections for new road infrastructure and population growth. One possible reason for the higher standards-based cost is that the County is not planning enough future road capacity to maintain current LOS standards and will see roads become increasingly congested in the future. As mentioned previously,road congestion is increasing nationwide and planned road construction is inadequate to maintain current standards. The high cost of maintaining even the County's minimum LOS standard under continuing growth may be too high for the public to bear. Instead of paying for construction of new roads, county residents will likely pay indirectly through the travel delays and increased fuel use associated with growing congestion. Standards-Based Transportation System Impacts of Thornburgh Resort As noted previously, a destination resort generates a complex mix of uses and accommodates many of its vehicle trip onsite. The trip generation estimate from Kittelson and Associates is a total trip generation rate of 4.4 trips per dwelling unit that includes all uses in the resort(residential and commercial). For Thornburgh this would be 6,050 daily vehicle trips. Using the cost per vehicle trip to maintain a LOS of D of$6,977 from Table 5-5, the cost for building the offsite road capacity for 6,050 new trips is $42.2 million. Depending on the fiscal impact analysis method employed, the gross transportation facilities costs for the Thornburgh Resort would range from $23.3 million to $42.2 million (see Table 5-6). While both figures are reasonable estimates, the higher, standards-based figure probably does a better job of representing the full cost of transportation system impacts. This is because the standards-based method assures that the current minimum LOS standard of D is maintained,while the projection- based method does not. It is also worth reiterating that the LOS standard used here still allows for a considerable increase in average road congestion that is not included in the$42.2 million cost,and therefore is a conservative(low)estimate. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 37 Table 5-6 Estimated Transportation System Costs for Thornburgh Resort Impact Analysis Method Cost Planning projection-based estimate 23.3 million Standards-based estimate (LOS=D) 42.2 million Net Transportation Cost from Thornburgh Resort To obtain a net cost, SDC payments and developer contributions to the transportation system must be deducted. The Thornburgh Resort will pay a Transportation SDC for each development. The SDC may be based on the standard rate indicated in the SDC adoption resolution,or an alternative rate based on the applicant's data showing that a reduced number of vehicle trips will be generated.`The approximate total SDC payments under both methods range from $1.8 million to $6.5 million, as shown in Table 5-7. Table 5-7 Estimated SDC Payments for Thornburgh Resort—Conventional Method Assumes full rate charged with no trip reductions) ITE Expected PM Trip Cost per Full SDC Code SDC Category Units Units Rate PM Trips Tripltf Rate 210 SF Detached DU 1375 1.01 1388.8 $3,504 $4,866,180 310 Hotel Rooms 50 0.59 29.5 $3,504 $103,368 493 Athletic Club TSF Gross 60 5.76 345.6 $3,504 $1,210,982 710 General Office TSF Gross 15 1.49 22.4 $3,504 78,314 814 Specialty Retail TSF Gross 20 2.71 54.2 $3,504 $189,917 931 Quality Restaurant TSF Gross 5 2.15 10.8 $3,504 37,668 Totals: 1851.2 6,486,430 Alternative Method with Trip Reductions Resort's Estimated PM Peak Trips(2)517.0 $3,504 $1,811,568 1)Excludes administrative fees. 2)Transportation Impact Analysis,Revision II,by Group McKenzie,September 28,2005,Table 9B,prepared for Thomburgh Resort. According to an unsigned "Cooperative Improvement Agreement"between the Thornburgh Resort and ODOT,the resort will mitigate its immediate,direct Deschutes County Resolution#2008-059 establishes the SDC charge,standard rates,and the allowance for exceptions to the standard rates. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 38 impacts on a nearby intersection with the State highway. This mitigation includes payment of up to $1,125,000 towards improvements at the Cline Falls Hwy/US 20 intersection in Tumalo. The improvement to the Cline Falls Hwy/US 20 intersection is included on the SDC project list,so this contribution should be deducted from the resort's gross transportation system costs. The maximum potential payment of$1,250,000 is applied. The increase in State gas tax revenues resulting from the resort should also be considered. Gas taxes are collected from gasoline sales,but the State distributes them to counties based on the number of registered vehicles in the county. The extent to which the resort increases the number of county-wide registered vehicles will determine the increase in gas tax revenues attributed to the resort. Only permanent,year-around residents of the resort are likely to register their vehicles locally. There was no clear method for estimating the increase in the number of register vehicles resulting from the resort,so this impact could not be computed. However,the impact would be quite small. For example, if there were 400 additional registered vehicles,County Road Fund revenue would increase less than $16,000, which would be insignificant relative to the costs.35 The final cost estimate for the transportation system impacts of the Thornburgh Resort assumes that the resort will apply for trip reductions to lower their SDC payment to a total of$1.8 million. As shown in Table 5-8,the final cost range is 20.7 million to $39.1 million, depending on the impact method used.The higher standards-based figure is used in the final impact analysis because it does a better job of reflecting the full impacts of this development, as discussed previously. Table 5-8 Estimated Net Transportation System Costs for Thornburgh Resort Maximum SDC Developer Impact Analysis Method Gross Cost Paymentsitl Contribution&2 Net Cost Planning projection-based estimate $23,770,450 ($1,811,568) ($1,250,000) $20,708,882 Standards-based estimate (LOS=D) $42,210,850 ($1,811,568) ($1,250,000) $39,149,282 1)Assumes alternate SDC calculation method with trip reductions. 2)Maximum possible contribution towards ODOT expenses at the Cline Falls Hwy/US 20 intersection. 35 For the 2007-08 fiscal year Deschutes County received$7,963,277 in State Road Funds and had 205,402 registered vehicles,equivalent to$38.77 per registered vehicle(based on Oregon Department of Transportation,Financial Services,Highway Revenues Apportionment data). Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 39 School Facilities Costs Destination resorts will generate new K-12 school students and additional demand for school facilities. This section looks at the likely impacts of the proposed Thornburgh Resort on the revenues and costs of the Redmond School District. The resort will generate school students both from the new resort housing and from the newcomers attracted to fill jobs created by the resort. According the current Working Draft of the Deschutes County Comprehensive Plan:36 Schools One of the basic problems with larger amounts of residential development is that it rarely pays in property taxes for the services that must be provided. This is particularly true for the most expensive public facility--schools.Additional permanent residences require more facilities and teachers. When this plan was written, much of the new development had been provided for seasonal recreation and was therefore not likely to require schools. However, the County was realizing that much of the seasonal development was becoming full-time residences. This forced the school districts to seek additional funds for new buildings and more teachers. In addition, costs rose because many of the new residences were in rural areas and required ever more expensive busing. Student Generation by Resort Housing The new,private resort homes that are occupied as primary residences will generate new school students, but the specific level of student generation is unknown. There is no data that clearly differentiate the student generation rate of a private home in a destination resort from a typical new home in the same county. If resort homes are occupied full-time by their owners, they may have a similar demographic profile to other new houses in the area. If they are used as part-time second homes(or vacation homes), they will generate few,if any new students. It is assumed that homes built exclusively for overnight lodging purposes will generate no new students. Therefore, homes designated for overnight lodging are not included in the following analysis. As described at the beginning of this section, homes used as primary residences were found to constitute 43%of owner-occupied (non overnight)units in the nearby Eagle Crest Resort. This percentage may vary considerably from resort to resort. In order to examine the potential impacts of the proposed Thornburgh Resort, two scenarios are used to model the range of potential student generation by the private, owner occupied homes in the resort: 36 Working Draft Deschutes County Comprehensive Plan,draft of 5-14-08,Page 3-18. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 40 Scenario #1: High student generation. Private,owner-occupied homes in the resort are assumed to generate the same demand as new private homes elsewhere in the County. (Overnight units are assumed to generate no demand.) This scenario may become increasing likely if resort homes are purchased and used as primary residences. The Thornburgh resort has no age limits or household limitations regarding children, so the market will decide who owns these units and how they are used. A continued weak national economy may encourage consolidation of home ownerships, reducing the number of second homes. A weaker economy may also reduce the sizes and prices of future resort homes, making them more attractive to families. Scenario#2: Low student generation. This is the"vacation resort" scenario. Private,owner-occupied homes in the resort are assumed to be used largely as retirement homes and as second(vacation) homes and to generate only 25%of the new students generated by new homes elsewhere in the County. This scenario would be more applicable if expensive,higher-end housing is constructed, which would favor more-affluent owners and may reduce the number of families with school-age children and increase the percentage of retirees without school-age children. If a resort were age-restricted(such as 55 and above),it might generate no students from the new homes. However, we are not aware of any destination resorts in Oregon with age restrictions. In Deschutes County, 16.1%of the population is of K-12 school age, 5 through 17 years of age.37 This is slightly lower than the statewide school-age figure of 16.9%of the population. Applying the percent of school-age children to the occupancy rate of 2.7 for new homes, yields a school-age generation rate of 0.43 students per new house. State Law requires that destination resorts provide a certain amount of overnight accommodations to assure that they meet their tourism function. In Deschutes County there must be at least one housing unit available for overnight accommodations for every two private,owner-occupied housing unit created at a destination resort. Most resorts build only the minimum number of overnight units, and therefore adhere closely to this ratio. It is not clear that resorts continue to adhere to the minimum number of overnight units once construction is completed, and some overnight units may convert to owner-occupied status. For the Thornburgh Resort,950 of the 1,375 housing units will be owner-occupied. A 50-room hotel will be used to meet the balance of the overnight housing requirement. There are no age or demographic restrictions on ownership,so the use 37 The most recent US Census estimates for households in Deschutes County are for 2006.This data includes the incorporated areas of the county. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 4 I of these homes will be market-driven. These homes may be used either as primary residences or as second homes(vacation homes). Table 5-9: Estimated K-12 student generation by residential housing at Thornburgh Resort. Scenario#1 Scenario #2 Total owner-occupied housing units 950 950 Students generated per housing unit 0.43 0.11 Students generated by resort housing 409 102 Student Generation from Resort Employment In addition to student generation from the housing in a destination resort, there is a secondary demand resulting from the new jobs created at the resort. These new jobs will attract new households to the area and generate new students. Since the construction jobs are temporary, the number of new students generated by resort employment will fluctuate as households move in and out of the area to meet employment needs. Employment impacts are addressed in more detail in the Economic Impacts section of this report. The direct and induced employment resulting from the Thornburgh Resort is estimated to peak in year six at 2,01.5 jobs and then decline by 1,471 jobs to a steady level of 544 jobs from year twelve onward. There is no straightforward method for estimating school system impacts resulting from short-term employment. Undoubtedly the students generated by the 1,471 temporary jobs will significantly impact the school system. This study evaluates the school impacts resulting from only the permanent jobs generated by the resort. These employment-related school impacts are included in order to better account for the full impact resort development has on the local school district. Based on estimates developed in the Economic Impacts section, 347 new households will be created by the 408 jobs filled by newcomers. Table 5-10: Estimated K-12 student generation by newcomers filling permanent jobs at Thornburgh Resort. Total new housing units for resort-related employment 347 Students generated per housing unit 0.43 Students generated by resort employment 149 Impact or Destination Resorts in Oregon Fodor&Associates March 2009 page 42 Table 5-11 shows total student generation for new resort housing and resort employment. Under Scenario #1, resort housing will generate a similar number of new students as other new housing in Deschutes County, resulting in a total of 558 new students. Under Scenario #2, resort housing will generate only 25% of the students of a typical new house in the County,resulting in a total of 253 new students. These two scenarios provide a reasonable range of 251 to 558 new students generated by the Thornburgh Resort. Table 5-11: Total K-12 student generation by Thornburgh Resort housing and employment. Scenario #1 Scenario #2 Students generated by resort housing 409 102 Students generated by resort employment 149 149 Total students generated 558 251 School Funding in Oregon Schools in Oregon are funded primarily by a combination of state and local sources. The primary local source is property taxes. The State School Fund formula determines how much state funding a school district gets. The formula bases the state funding on the number of students served and deducts the local property taxes going to schools. The state funding is directed to school operations, maintenance, repairs and transportation needs. If the local property tax revenues increase due to a new destination resort,the state contribution to local school funding will be reduced by an equal amount. For new students generated by the resort,the district will receive the same funding per student as they do for the rest of their students. Therefore,new developments provide no extra funding to local school districts for general operations. New school facilities needed to serve growth are funded primarily through issuance of voter-approved local general obligation bonds that are repaid through local property taxes. Local property tax revenues for bond repayment are not deducted from the State's operation funding. The tax base for the Redmond School District comes from the total assessed values of the District in both Deschutes County and Jefferson County. Table 5-12 shows the total tax base is $4,937,455,942 for 2008-09. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 43 Table 5-12: Assessed value for the Redmond School District 2J tax base. Assessed Value Total County 2008-090) Deschutes County 3,594,082,824 Jefferson County 1,343,373,118 Total School District Tax Base: 4,937,455,942 1)Source:Redmond School District. Assuming that the Thornburgh Resort is fully built out as planned, the estimated increase in the assessed value of the school district's tax base would be$374,788,817. At full buildout,Thornburgh would represent 7.1%of the tax base available to the school district. Based on the estimated increase in the total tax base available to the Redmond School District that would be created by the Thornburgh Resort,the resort will pay for approximately 7.1%of facility bonds issued for new construction by the District. This percentage will be deducted from the school facility costs generated by the resort. School Facility Costs To estimate the cost of expanding school facilities to increase student capacity,the total costs for new facilities at all grade levels must be determined. The Redmond School District passed a bond in May of 2008 for a new high school and new elementary school. A new middle school was built by the District in 2006. The costs for these new facilities are added to the land values to obtain a total school facility cost for each grade level,as shown in Table 5-13 below. Table 5-13: School facility costs,Redmond School District,2008. Total School Grade Level Building Cost Land Cost Facility Cost High school(1) 80,000,000 $13,600,000 93,600,000 Middle schooll2) 22,764,955 $3,000,000 25,764,955 Elementary school(1) 20,000,000 $2,600,000 22,600,000 Notes: 1)Building costs based on a bond issue by the Redmond SD approved by voters May 20,2008 as Measure 9-56. 2)Building cost based on Elton Gregory Middle School completed in 2006 for$20 million.Costs adjusted to 2008 using ENR Construction Cost Index for closest location(Seattle). 3)Based on actual acreage and a current land value estimate of$200,000 per acre. The total school facility cost is divided by the capacity of students for each facility to calculate at cost per unit of student capacity(see Table 5-14). Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 44 Table 5-14: School facility costs per unit student capacity,Redmond School District,2008. Cost per Unit Total School Student Student Grade Level Facility Cost Capacity0) Capacity High school 93,600,000 1400 66,857 Middle school 25,764,955 804 32,046 Elementary school 22,600,000 600 37,667 1)Capacity for each school from Redmond School District. The"cost per unit of student capacity"is then distributed across the student generation rate at each grade level for a typical new house in Deschutes County,as shown in Table 5-15. Based on facility costs in the Redmond School District, the total school facilities cost associated with typical new house is $21,542. Table 5-15: School facility costs per new house,Redmond School District,2008. Cost per Percent of Student School Unit Total Students Generation by Facility Student at Grade Grade Level for Costs per Grade Level Capacity Levelly New House New House High school 66,857 47% 0.202 13,507 Middle school 32,046 23% 0.098 3,147 Elementary school $37,667 30% 0.130 4,888 Totals: 100%0.430 21,542 1)Based on 2007 enrollment data. Estimated School Facilities Costs for Thornburgh Resort The Redmond School District does not charge a school excise fee (a development impact fee authorized by the State Legislature)for new and expanded school facilities,so development makes no direct contribution to school facility costs outside of ordinary property tax payments. If the district were to adopt the fee, it could collect up to $1 per square foot. A new 3,000 square foot house would pay a fee of up to $3,000. Based on the high and low student generation rate scenarios (Scenarios #1 and #2), it is possible to estimate the range of total students generated by the destination resort and the resulting total facility costs. The Thornburgh Resort will generate costs for new and expanded school facilities ranging from a low estimate of$12.6 million to a high of$27.9 million,as shown in Table 5-16. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 45 Table 5-16: Total facility costs for K-12 student generation by Thornburgh Resort housing and employment. Scenario #1 Scenario#2 Number of primary residences in resortl'I 950 238 Number of new households for permanent employees 347 347 Total new households generating school-age students 1297 585 Total students generated (at 0.43 per house) 558 251 School facility costs per new house 21,542 21,542 Total school facilities costs (#houses x$/hse):27,939,974 $12,591,299 Note(1)Scenario#1 assumes that 950 owner-occupied resort houses will have similar occupancy to typical new houses in Deschutes County,while Scenario#2 assumes that only 25%of resort houses will be similar and the rest will be second homes That generate no school children. For the final fiscal impact on school facilities,only the student generation from Thornburgh Resort housing was included. Impacts from resort employment were not included in order to be consistent with the rest of the impact study,which did not include secondary or induced impacts. The costs associated with only the resort housing range from $5 million to $20 million,as shown in Table 5-17. Table 5-17: Total facility costs for K-12 student generation by Thornburgh Resort housing. Scenario#1 Scenario#2 Number of primary residences in resortf'1 950 238 Total students generated (at 0.43 per house) 409 102 School facility costs per new house 21,542 21,542 Total school facilities costs (#houses x$/hse):20,464,900 $5,116,225 Note(1)Scenario#1 assumes that 950 owner-occupied resort houses will have similar occupancy to typical new houses in Deschutes County,while Scenario#2 assumes that only 25%of resort houses will be similar and the rest will be second homes that generate no school children. In order to credit the resort for future property tax payments that would potentially contribute to school construction bonds,the estimated 7.1% contribution to the tax base should be deducted from the school facility costs attributed to the resort (see previous discussion on this). Therefore the net costs for school facilities attributed to the resort range from $4.8 million to $19 million,as shown in Table 5-18. To be conservative, the$4.8 million cost associated with the low-student-generation-rate scenario (Scenario #2)was used in the final cost estimates. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 46 Table 5-18: Net K-12 school facilities costs for Thornburgh Resort after deducting future property tax contributions. Net School Facilities Costs Scenario#1 Scenario #2 Total school facilities costs: 20,464,900 5,116,225 Future property tax contribution (at 7.1%) 1,453,008) 363,252) Net school facilities costs: 19,011,892 4,752,973 Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 47 Fire & EMS System Costs The Thornburgh resort would receive fire and emergency medical service(EMS) services from the Deschutes County Rural Fire Protection District#1 (DC RFPD#1). Four of the ten existing land parcels that make up the proposed Thornburgh Resort are located within the boundaries of the Fire District and the remaining 6 parcels have been recently annexed within the District at the request of the resort developer. Deschutes County Rural Fire Protection District #1 does not independently provide fire and EMS services,but rather has entered into a cooperative agreement with the City of Redmond to jointly provide Fire Protection and EMS services to both City and District residents through Redmond Fire and Rescue(RF&R). With an annual budget of$6,483,074 and utilizing the services of 40 career and 23 volunteer fire fighters, Redmond Fire and Rescue provides fire and EMS services to the 42,000 residents of its 145 square mile service area(450 square miles for ambulance service).38 To do this it operates four fire stations: The Headquarters Station located within Redmond proper; the Airport Station at Roberts Field; and the Cline Falls and Terrebonne Fire Stations within DC RFPD#1. Operational Capacity Assessing the capacity of a fire department is a difficult task. First,it is impossible, for both fiscal and operational reasons,to have a fire department of sufficient size to meet all possible operational situations. Second, the random nature of emergency calls makes establishing a reasonable base level of service difficult. In 2007 RF&R experienced 4,253 dispatched 9-1-1 service calls, 2,864 in the city of Redmond and 1,388 rural calls.39 This included 2,894 EMS calls, 830 fire calls and 511 medical transfers. While this averages out to roughly 12 calls per day, or 3 calls per station per day,these call levels are not consistent. They can come in bunches as well as one at a time. Several years ago, a single arsonist, starting fires along Highway 97 managed to overtax the fire departments in three Central Oregon counties.40 The impression from Chief Knorr's report on RF&R operations in the agency's 2007 Annual Report is that of an organization operating within its capabilities. Yet one of the unfunded budget requests in the FY 2008-09 RF&R Budget was for three additional firefighter/paramedics to staff a second ambulance to handle non- emergency medical transfers. Because this went unfunded, the Terrebonne position 2007 Annual Report,Redmond Fire&Rescue,page 11 and data provided by RF&R staff. 39 2007 Annual Report,Redmond Fire&Rescue,page 3. 40 From phone conversation with Redmond Fire and Rescue staff. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 48 is vacant and they are unable to respond to calls for these transfers.' It appears that the Redmond Fire & Rescue has sufficient capacity to provide a reasonable level of Fire Protection for the 42,000 residents living and working within its 145-square mile area of responsibly. Whether the RF&R has sufficient un-utilized operational capacity to provide additional fire protection for the residents of the Thornburgh Resort is not clear. Capital Costs The combined operation provides one fully-equipped fire station for every 10,500 residents 42 In order to apply this current population-based service standard to the resort,an "effective population"was used that reflects the number of structures at the resort requiring fire protection. This population figure is the number of people typically associated with these structures in the County and is not intended to represent the actual population of the resort at any given time.43 As shown in Table 5-19 the Thornburgh Resort would have an effective population for Fire/EMS demand of 3,813. To meet the standard of one station for every 10,500 people,an additional 36.3%of a fire station would need to be provided to meet the demand Thornburgh places on the capacity of Redmond Fire& Rescue. Table 5-19 Thornburgh Effective Population Estimate for Fire/EMS System Demand Number of Persons per Persons per Type of Housing Unit units undo) Typal 1 Hotel 50 2 100 Residential Overnight Unitsf3i 425 2.7 1,148 Houses 950 2.7 2,565 Estimated Population: 3,813 Notes: 1)Hotel room occupancy figure is an estimate.The 2.7 figure used is the residential occupancy rate for new homes in Deschutes County. 2)Number of Units x Persons per Unit. 3)These are the housing units that would be subject to a deed restriction requiring that they be available for short term rental at least 38 weeks a year. 41 Section 2,Fire Fund,City of Redmond FY 2008-09 Budget,page 5 42 It would be preferable to use number of addresses or type or number of structures located within the district as the main metric in an evaluation of this type,but as Redmond Fire&Rescue does not have that data we were limited to what is available,which is population data. 43 In the case of fire protection,all buildings(empty as well as occupied)have the potential of placing demand on the capacity of the system."Effective population"was used here to reflect the number of structures in the resort,relative to those serving the general population.This population figure is different than the figure used in estimating the demand Thornburgh would place on public safety or public parks. In the case of public safety or the park system,it is people who place demand on the capacity of the system. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 49 The Terrebonne Fire Station opened in August of 2007 and is the newest station in the Redmond Fire and Rescue system. It cost$1.3 million dollars to construct. The cost of constructing a similar station in 2008 is about$1,362,920.44 This station is staffed 24/7 by 6 firefighters and has the equipment listed in Table 5-20. Table 5-20 Fire Apparatus at Terrebonne Fire Station Equipment Type11) Cost Light Rescue Truck) 70,000 Light Brush Truck (Type 6 Fire Engine?) 80,000 Heavy Brush Truck(4) 150,000 Fire Engine) 250,000 Ambulance) 150,000 Total 700,000 Notes 1)Equipment list provided by staff at the Terrebonne Station.In addition to the apparatus listed that station also has a boat to facilitate access to parts of Smith Rock Park. 2)The cost figure was estimated using prices for used equipment currently listed on the Internet 3)The$80,000 is the amount budgeted to purchase the truck. 4)The cost figure was estimated using prices for used equipment currently listed on the Internet 5)The cost value used was provided by RF&R staff. The combined cost of constructing a new station and providing it with the same type and number of apparatus is about$2,062,920.45 Based on the estimated need to provide 36.3%of a new fire station to serve the Thornburgh Resort, the total capital cost for providing Fire Protection services to the resort is about$748,840. Oregon Law does not permit the imposition of System Development Charges or impact fees to recover the Fire/EMS system capital costs associated with new development. Therefore, these capital costs for expanding the system will fall on all of the property owners within the DCRPD#1,not just those in the Thornburgh Resort. One of the projects RF&R has been undertaking is researching the feasibility of a fire station in DCRFPD#1's southern area. Due to prudent fiscal planning the DCRFPD#1 has $840,800 in its building reserve fund and$77,250 in its equipment a4 Adjusted using the ENR Construction Cost Index for the nearest city(Seattle). 45 In addition to the fire house structure and the fire apparatus there are a large number of other items that are needed for a fully functioning Fire Station.Items such as beds,stove,washer-dryer,hoses, breathing apparatus,tools,lights,hose nozzles,etcetera,were not included in this cost estimate. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 50 reserve.46 However,that is much less then the$2,062,920 needed to build and equip an additional fire station in the District's southern operating area,particularly as those funds would also be needed to cover the eventual replacement of existing buildings and equipment. To obtain the final net fire/EMS system costs,estimated future contributions to the District tax base from the resorts are deducted from the cost above. If fully developed, the Thornburgh Resort would represent 22% of the DCRFPD#1 tax base. Deducting the contribution through future tax payments, leaves a net cost for fire/EMS facilities of$580,813,as shown in Table 5-21. Table 5-21: Net fire/EMS facility cost for Thornburgh Resort after deducting future property tax contributions. Net Fire/EMS Facilities Costs Total fire/EMS facilities cost: 748,840 Future property tax contribution (at 22%)168,027) Net fire/EMS facilities cost: 580,813 Operational Costs Redmond Fire & Rescue has an annual budget of$6,487,876 of which$5,830,680 is allocated for department operations.47°48 That amount includes the replacement of the division commander's vehicle and $27,000 to replace four ambulance gurneys and similar operational expenses. For the service district population, this operations cost amounts to$138.83 per resident per year. For the estimated 3,813 Thornburgh residents, it should take about$529,359 to maintain this level of service. It is important to note that 18 of the firefighter positions in the RF&R are to be filled by volunteers. As such, the value of their labor is not included in that operational cost.49 At this time, finding individuals with the interest, ability and commitment necessary to become volunteer firefighters is not easy. As reported in the Revenues section of this report,Thornburgh Resort property owners will pay an estimated$637,731 in property taxes to the DCRFPD#1. This exceeds the estimated cost of$529,359 needed to provide the current level of service DCRFPD#1 FY 2008-09 Annual Budget 47 Section 2,Fire Fund,City of Redmond FY 2008-09 Budget,page 4 4'Ibid av Section 2,Fire Fund,City of Redmond FY 2008-09 Budget,page 2 Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 5 I for those residents. The revenue surplus of$108,372 would not be adequate to meet the capital costs to build and equip the additional fire station infrastructure necessary to serve the resort. There is another non-monetary operational cost that the rest of the District residents will bear,at least in the short term,because of the development of the Resort within their District: A reduction in the level of service caused by increased driving time. The Thornburgh resort is located at the extreme edge of the district's southwest boundary and,as a result, fire and EMS vehicles going to and coming from Thornburgh will have longer response times to call in other parts of the district. The construction of an additional fire station in the southern part of the DCRFPD#1's operating area should mitigate some of this negative impact. Additionally,as the proposed Thornburgh Resort is not intended for permanent full time residents, it is not a likely source of additional volunteer firemen and this burden will fall on the other full-time residents of the District. So while the property taxes should adequately cover the day-to-day costs of providing fire protection for the Thornburgh resort,the need to provide volunteer firefighters and to bear the major portion of the capital cost of constructing and equipping an additional station as well as a reduction in service due to extended travel times until it is built means that in the final analysis the current residents of the Deschutes County Rural Fire Protection District #1 would incur net costs if the Resort is constructed. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 52 Public Safety System Costs Public safety involves many different functions,including patrols,prosecution, incarceration,parole, 911 services,courts,and others. Some resorts provide their own onsite security and patrol services. Sunriver, Black Butte and Pronghorn are examples. Some, such as Eagle Crest provide limited onsite security. These services lack the police powers of the Sheriff's officers and are therefore a limited substitute for County public safety services.50 Thornburgh Resort has not indicated that it will provide any onsite security, so security and patrols are assumed to be provided by the Sheriffs Department. To estimate the impacts of the Thornburgh Resort on public safety facilities and services, data is needed on public safety facility costs and the Sheriffs Department operating budget. This analysis was complicated by the many different public safety functions and the lack of usable facility cost data. There are three Sheriff's substations that serve unincorporated Deschutes County: Terrebonne, Sisters and La Pine substations. There is no facility cost data for any of these since two are being leased(Sisters and Terrebonne)and one is part of the South County Building that contains multiple uses. The service area for the substation also cannot be determined,since they have no particular boundaries and overlap coverage. The Thornburgh Resort could be served by either the Sisters or Terrebonne substation. In addition,the main Sheriffs office in Bend provides services for the unincorporated area near Bend. Public safety functions include: 911 County Service District Adult Parole and Probation Community Justice-Juvenile District Attorney's Office Justice Court Sheriffs Office Deschutes County Adult Jail Public safety facilities must be adequate to handle peak demands at the height of tourist season. There is very little opportunity to adjust or downsize the system for off-peak periods. For this reason,public safety facilities must have capacity to serve the resort during peak occupancy. 5°Private security services are limited in their ability to arrest,detain and use force and do not replace the need for true law enforcement services. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 53 The Deschutes County Adult Jail was built in 1994 and has a capacity of 228 beds. According to the Corrections Needs Assessment:Deschutes County, Volume One,Master Plan (January 26, 2006),51 the capacity of the jail is currently being exceeded. The 2005 average daily population(ADP)was estimated to be 270 inmates. Modeling of future jail demand results in a projected ADP of 578 in the year 2015, increasing to 818 in 2025. A two-phased plan is proposed for meeting current and future jail expansion needs. Allowing for fluctuations in jail bed demand,the first phase of development would address projected corrections needs through year 2015 at 690 beds,with occupancy of expanded facilities assumed to occur,in the year 2010. A second phase of development would then address projected corrections needs through the year 2025 at 975 beds,with facility occupancy assumed to occur in the year 2020.The cost for phase one is$70,989,839. Phase two, to be constructed starting in 2020,will cost approximately $54 million. Table 5-22 Deschutes Jail Expansion Master Plano) Population Existing Jail Jail Beds Year Estimate 1 Beds ADP01 Needed(4) 2005 143,053 228 284 349 2010 166,572 690 427 520 2015 189,443 690 578 690 2020 214,145 975 689 820 2025 240,811 975 818 975 1)Corrections Needs Assessment:Deschutes County,Volume One,Master Plan and Volume Two, Technical Appendices,January 26,2006. 2)Based on Deschutes County 2000-2025 Coordinated Population Forecast. 3)ADP is average daily population from page 0.3.3 of Corrections Needs Assessment.Current values for ADP are higher than actual to include early releases. 4)Includes capacity to handle daily fluctuations(peaking factor). Based on the estimated population increase of 3,688 people resulting from the peak occupancy of the Thornburgh Resort(Table 5-23) and the cost for the associated increase in jail capacity,at$1,129 per person (Table 5-24), the associated cost for jail capacity is $4,163,752. Note that jail facility costs are assigned on a population- weighted basis and do not assume that resort residents will be more or less likely to be incarcerated than average residents. In principle,all residents benefit equally from the increased safety that adequate jail facilities provide. 51 Corrections Needs Assessment:Deschutes County,Volume One,Master Plan and Volume Two, Technical Appendices,January 26,2006. See htto://www.co.deschutes.or.us/go/objectid/29B167F2- BDBD-57C1-9A456F288808D927/index.cfm. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 54 Table 5-23 Thornburgh Peak Population Estimate for Public Safety System Demand Type of Housing Unit Peak Number Persons Occupancy Persons per of units per unit") Rate(2)Type lal Hotel 50 2 90% 90 Residential Overnight Units (4)425 2.7 90% 1,033 Houses 950 2.7 100% 2,565 Estimated Population: 3,688 Notes: 1)Hotel room occupancy figure is an estimate.The 2.7 figure is the residential occupancy rate for a new house in Deschutes County.This occupancy rate is applied to overnight housing as well,even though many resort rentals show capacity for 8 to 12 persons. 2)The peak occupancy rates used for the hotel and overnight units are those used to generate the transient room tax data. 3)Number of Units x Persons per Unit x Occupancy Rate. 4)These are the housing units that would be subject to a deed restriction requiring that they be available for short term rental at least 38 weeks a year. Table 5-24 Jail Expansion Costs Associated with Population Growth Phase One Cost')70,989,839 Increase in Beds 462 Cost per New Bed: 153,658 Increase in Needed Beds, 2005-2015 341 Cost for increase in needed beds, 2005-2015 52,397,262 Cost per capita for population growth, 2005-2015(2) 1,129 1)Cost to meet projected needs in 2015 per Corrections Needs Assessment:Deschutes County,Volume One,Master Plan and Volume Two,Technical Appendices,January 26,2006. 2)Population growth for this period was based on the official population forecast for Deschutes County provided in the Appendix. To estimate the costs for other public safety facilities(other than jail facilities), the 2008-09 Deschutes County Capital Asset Query File was used to compile capital costs. It was impossible to determine values for all facilities because some are shared facilities that provide multiple functions and there was no way to separate out the public safety components. These facilities are indicated as zero-values in Table 5-25. Table 5-25 provides the most complete listing possible from the Capital Asset database. Each facility cost was adjusted to 2008 building costs using the ENR Construction Cost Index for the year in which the asset was built or purchased to obtain an estimated current replacement value. The total estimated replacement Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 55 value of public safety facilities is$22.5 million. This total does not include some shared facilities nor any rented facilities. Land values,patrol cars and Sheriff's equipment costs were adjusted for inflation to 2008 values. Table 5-25 Value of Existing Public Safety Facilities (Excluding Jail)ft) Source: Deschutes County 2008-09 Capital Asset Query File All buildings and improvements adjusted to 2008 values using ENR Construction Cost Index) Dept Code Buildings and Land Total Facility Location Code) Facility/Dept Name Improvements Improvements Value) 21 CiviVSpecial Units 0 0 0 29 Automotive/Communiciations 0 45,536 45,536 33 Investigations/Evidence 7,653 0 7,653 34 Patrol 18,214 0 18,214 35 Records 0 0 0 38 Court Security 0 0 0 39 Emergency Services 0 0 0 41 Special Services 7,819 0 7,819 43 Training 0 132,266 $132,266 75 911 General Operations 200,727 0 $200,727 82 Adult Parole/Probation 152,855 70,222 $223,077 45 Non-Departmental" 45(170002) Sheriff's Office Building 3,863,921 0 $3,863,921 45(170202) Juvenile Community Justice Bldg $10,929,783 0 $10,929,783 45(170302) Regional Correctional Building 3,567,591 0 $3,567,591 Facilities Subtotals: 18,748,562 248,024 $18,996,586 170*** Patrol Cars (VO4)0) 1,688,946 170*** Sheriff Equipment (SE)(^) 488,409 170100 Land for Public Safety Bldg (LAY') 1,359,059 Total Capital Value: 22,532,999 Notes: 1)Three Sheriffs Substations were not included because they are rented or shared facilities.Other shared facilities also were not included. 2)Total costs do not include the values of any shared facilities or facilities used for public safety purposes that are rented,such as the Terrebonne and Sisters Substations. 3)Only public safety facilities were included from this department code. 4)Cars,equipment and land costs adjusted for inflation to 2008 values using the Consumer Price Index. To arrive at a per-capita cost for public safety facilities (not including jail cost),the total of facilities values of$22.5 million (from Table 5-25)were distributed across the entire County population. The full County 2008 population of 156,733 persons Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 56 was used because most of the facilities serve the entire County 51 The per-capita cost for these public safety facilities is$144. Based on the demand resulting from the assumed peak population of the Thornburgh Resort of 3,688 persons(Table 5-23), the incremental cost for expanding these facilities to serve the resort is $531,072. As shown in Table 5-26, the total public safety facility costs associated with the Thornburgh Resort is$4,694,824. It is important to note that the cost value is understated due to the lack of data mentioned previously. Table 5-26 Total Public Safety Facility Costs for Thornburgh Resort Per New Person For Resort Jail Expansion 1,129 4,163,752 Other Public Safety Facilities 144 531,072 Total Cost: 4,694,824 To obtain net public safety facility costs,estimated future tax contribution by the Thornburgh Resort are deducted from the cost in Table 5-26. At full buildout, the resort would represent 2.2%of the County's tax base and would fund the same percentage of County facility costs. As shown in Table 5-27, the net cost for public safety facilities is $4,591,181. Table 5-27: Net public safety facility cost for Thornburgh Resort after deducting future property tax contributions. Net Public Safety Facilities Costs Total public safety facilities cost: 4,694,824 Future property tax contribution (at 2.2%) 103,643) Net public safety facilities cost: 4,591,181 Exceptions are the patrol cars and patrol facility cost,which serve primarily the unincorporated area.These costs are relatively small,so the error is negligible,but the effect is to slightly lower public safety costs attributed to the resort. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 57 Cost of Public Safety Services The actual amount spent for the Sheriff's office for the budget year ending June 30, 2008 was $26,844,500.53 This expenditure was allocated to countywide and rural service districts as shown in Table 5-28. The cost for each district was divided by the 2008 population for the district to arrive at per-capita costs. Rural unincorporated residents received service from both districts, so the total per-capita cost is$295 per year. For the estimated 3,688 peak residents of Thornburgh Resort, the cost to provide public safety services is approximately$1,087,960 per year. Table 5-28 Sheriff's Department 2008 Operations Castsl') Population Per-Capita District Expenditure Served Cost Countywide District $15,908,322 156,733 102 Rural District 10,936,178 56,609 193 Total 26,844,500 295 1)Comprehensive Annual Financial Report,Deschutes County,Oregon,For the Fiscal Year Ended June 30,2008,pages 63 and 64. As shown in Table 5-29, the total estimated annual public safety revenues from the proposed Thornburgh Resort are$1,310,884. This is about$223,000 more than the estimated costs to serve the resort. The surplus is due to the allocation of 73%of all room taxes to law enforcement,as described in the Revenues section. Table 5-29 Estimated Public Safety Revenues from Thornburgh Resort Revenue Source Revenue[') Countywide Law Enforcement 345,368 Rural Law Enforcement 508,963 911 Service 142,437 Share of resort room taxes to law enforcement 314,116 Total:1,310,884 1)From Table 4-4 in Revenues section. 53 Comprehensive Annual Financial Report,Deschutes County,Oregon,For the Fiscal Year Ended June 30,2008,pages 63 and 64. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 58 Parks & Rec. System Costs The Thornburgh Resort is within the Boundaries of the Redmond Area Park and Recreation District(RAPRD). The District is supported through a combination of user fees and property taxes. The District operates the Cascade Swim Center,with a 25 meter indoor pool, the RAPRD Activity Center with indoor basketball,volley ball courts and batting cage; and multipurpose activity room; the High Desert Sports Center with 4 softball fields a BMX track and a Remote Control Airplane Landing field; Borden Beck Wildlife Preserve a 26-acre park and nature preserve located along the Deschutes River,and Historical Tetherow Crossing,an 11-acre Deschutes River-front park. The recreational opportunities offered by RAPRD at its swim and activity centers directly duplicate those that would be available to Thornburgh residents and guests at Resort-owned and operated facilities. As those facilities are closer and should be available at little to no out-of-pocket expense, it is likely that Thornburgh residents and guests would use the resorts facilities rather then driving long distances to a similar RAPRD facility. Thus it is reasonable to conclude that the Thornburgh Resort would have no measurable impact on the operation of the RAPRD Aquatics and Activity Centers. The facilities provided by the High Desert Sports Center are not duplicated at the Thornburgh Resort. But as the resort is intended to provide short term rentals,and vacation or second homes, it is not likely that many of the residents would be participating in local softball leagues or otherwise using these facilities. The one possible exception would be out of area teams renting a house or houses to stay in while participating at a tournament hosted by the High Desert Sports Center or Cascade swim Center. However, if that should occur,it would be more accurate to say that the sports complexes were utilizing the short term housing capacity of the Resort rather than Resort residents utilizing the capacity of the sports complexes. Thus it is reasonable to conclude that the Thornburgh Resort would have no significant impact on the operation of the High Desert Sports Center. While the resort does intend to provide open space for the use of residents and guests these facilities do not duplicate those provided by Borden Beck Wildlife Preserve and Historical Tetherow Crossing Park. The Deschutes River is one of the significant tourist attractions in Central Oregon. The Thornburgh Resort does not have any river frontage and both of these parks include extensive Deschutes River frontage. For this reason it is reasonable to assume that residents and guests of the Thornburgh Resort would utilize these two parks. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 59 Canital Costs The flexible nature of park facilities such as the Borden Beck Wildlife Preserve and Historical Tetherow Crossing Park makes it difficult to determine the maximum number of users that could utilize them at a time. Thus making a determination of whether they are at,over,or below capacity difficult to impossible. It is however, relatively easy to determine what the current level of service that is being provided by these two parks to the 32,000 residents of the Redmond Area Park and Recreation District, and from that determine the amount of similar river front park acreage that would be needed to maintain that level of service.' Currently RAPRD provides 1.156 acres of open space per 1,000 residents." Table 5-30 Parks and Open Space Operated by RAPRD Facility Acreage Borden Beck Wildlife Preserve 26 Historical Tetherow Crossing Park 11 Total Acreage 37 Park and recreation facilities receive peak demand in the summer months,the same time that resort occupancy will peak. The limited data available for the proposed Thornburgh Resort does not contain any demographic or population figures,but it is possible to arrive at a peak population estimate for the resort by working from the number of planned housing units,as shown in Table 5-31. If the advertisements for vacation rentals in the greater Redmond area are any indicator of the occupancy rates, the estimate for the occupancy of residential overnight units of 2.7 persons may be low. Many of these ads indicate that rental homes sleep from 8 to 12 persons. sa Population figure was provided by RAPRD staff. 55(37 acres/(32000/1000) = 1.156 acres per thousand residents Impact of Destination Resorts in Oregon Fodor 8/Associates March 2009 page 60 Table 5-31 Thornburgh Peak Population Estimate for Park System Demand Peak Number Persons Occupancy Persons per Type of Housing Unit of units per unit(1) Rate (zl Type la) Hotel 50 2 90% 90 Residential Overnight Units I4) 425 2.7 90% 1,033 Houses 950 2.7 100% 2,565 Estimated Population: 3,688 1)Hotel room occupancy figure is an estimate.The 2,7 figure used is for the residential occupancy rate for a new house in Deschutes County. 2)The peak occupancy rates used for the hotel and overnight units are the same as those used to generate the transient room tax data. 3)Number of Units x Persons per Unit x Occupancy Rate. 4)These are the housing units that would be subject to a deed restriction requiring that they be available for short term rental at least 38 weeks a year. To meet the current standard of 1.156 acres per 1000 residents, the RAPRD would need to acquire an additional 4.26 Acres of parkland with river frontage for the estimated 3,688 new Thornburgh residents. At an acquisition cost of$250,000 an acre,t6 that 4.26 acres would cost the district$1,065,000. As RAPRD does not impose a Systems Development Charge for Parks the money for this land acquisition would need to come from District Reserve Funds,operating revenues,a Parks Bond or some combination thereof. Given the current political climate and the funds available to the district it is unlikely that this land acquisition would happen. So rather than paying to meet this new demand for service, the existing residents would likely experience a reduction in the level of service. The new level of service would be lowered to 1.03,6 acres per 1000 residents. Crediting the Thornburgh Resort for future property tax contributions(assuming full buildout), results in a net cost for parks and recreation facilities of$463,562,as shown in Table 5-32. 56 Replacement Land cost was provided by RAPRD staff. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 61 Table 5-32: Net parks and recreation facility cost for Thornburgh Resort after deducting future property tax contributions. Net Parks and Recreation Facilities Costs Total parks and recreation facilities cost:1,065,000 Future property tax contribution (at 56%)601,438) Net parks and recreation facilities cost: 463,562 Operating Costs As it is unlikely(for the reasons provided above) that Thornburgh residents would be utilizing the Cascade Swim Center, the RAPRD Activity Center,or High Desert Sports Center, there should not be any additional operational costs caused by the resort's demand on the capacity. As for the Borden Beck Wildlife Preserve and Historical Tetherow Crossing Park, which are more likely to be utilized by Thornburgh residents, they do not currently generate General Fund operating expenses. Historic Tetherow Crossing Park is in the public planning phase of development and the limited operations of the Wildlife Preserve are supported by gifts, donations and inter-fund transfers to a special fund. This year the fund's $400-dollar beginning balance was supplemented by a transfer of$500 from the District's General Fund. On the expenditure side,a total of$500 dollars' has been budgeted for Materials and Services out of the fund's$900-dollar balance. The salary and benefits for the minimal Groundskeeper labor are absorbed into that of the rest of the District's operations.This breaks down to$15.63 per thousand residents. Assuming that the per-capita cost generated by new users is equal to the current per- capita cost,and no new acreage is provided,then the increased operating cost resulting from the 3688 peak Thornburgh residents is $57.63. If the additional 4.26 acres is added to the park so as to maintain current levels of service,then an additional $81.91 would be needed to provide the same level of operations and maintenance expenditures that the Wildlife Preserve currently receives. Conclusion Thornburgh property owners will be paying taxes toward the Redmond Area Parks and Recreation District amounting to an estimated$135,130 per year. This greatly The actual expenditure for FY 2006-07 was$551 (RAPRD 08-09 Annual Budget). Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 62 exceeds the$57.63 operating cost associated with meeting their demand on parks capacity. In terms of level of service, District residents would likely see a small drop from 1.156 acres to 1.036 acres per 1000 residents. There is a limit to how many development projects similar to the Thornburgh Resort could be constructed within the District's boundaries before the cumulative negative impacts caused by reductions in the level of service are felt by the current population. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 63 General Government Facilities The costs for expanding Deschutes County's general government facilities to accommodate the Thornburgh resort are calculated in this section. None of the infrastructure or facility costs addressed on other sections of this report are included here,so there is no duplication of costs. Deschutes County's Capital Asset Data File was used to identify the costs of all County facilities purchased or built since 1978 (Table 5-33). This database does not include the road system or facilities operated by independent districts, such as schools,fire, and parks. Note that the County rents some facilities, so these costs will not be included here. The costs for each of these facilities were adjusted to reflect 2008 replacement values using the ENR Construction Cost Index and the BLS Consumer Price Index. Facilities for the Sheriff's Office and the County Jail were removed from this list,as they were already included in the Public Safety Impacts section of this report. Table 5-33 Deschutes County General Government Facilities Costsll) All costs adjusted to 2008 values) Buildings and Land Vehicles, Improvements Improvements Equipment Facility BU, BI) LI)Land and Other Total Value All County Facilities 120,614,699 $34,384,960 $18,388,936 $115,653,683 $289,042,278 Deduct Sheriff&Jail ($31,681,617) ($325,792) ($1,359,059) ($2,177,355) ($35,543,823) County-(Sheriff &Jail) $88,933,082 $34,059,169 $17,029,877 $113,476,328 $253,498,455 1)Includes all facilities and equipment purchased since 1978.Buildings and Land Improvement values adjusted with CCI.Land and Equipment values inflated with CPI.Sheriff and Jail facilities were addressed under Public Safety Impacts. The new population added by the Thornburgh Resort that would require general county services was assumed to be limited to the occupants of primary residences. As previously describe in this report,primary residences were found to comprise 43%of the owner-occupied housing at the nearby Eagle Crest Resort, so this figure was applied to Thornburgh. Other property owners at Thornburgh who have second homes may also used County services and facilities, but this impact was considered to be relatively minor. As shown in Table 5-34, the estimated population in primary residences at Thornburgh is 1,103 persons. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 64 Table 5-34 Thornburgh Population Estimate for General Government Facilities Demand Percent Number Persons Primary Type of Housing Unit of units per unit") Residences(21 Population(') Owner-Occupied Houses 950 2.7 43% 1,103 Notes: 1)The 2.7 occupancy rate is for a new houses in Deschutes County. 2)Percent primary residences is based on an analysis of tax records for the Eagle Crest Resort. 3)Number of Units x Persons per Unit x%Primary Residences. Based on the per-capita value of existing County facilities of$1,617 shown in Table 5-35,the cost of expanding general government facilities in Deschutes County to accommodate the Thornburgh Resort is estimated to be$1,783,984. Table 5-35 General Government Facilities Costs Associated with Thornburgh Resort Countywide General Government Facilities Cost (TbI 5-33) 253,498,455 2008 County Population(1) 156,733 Per-Capita Facilities Cost 1,617 Thornburgh Population Estimate (Tbl 5-34) 1,103 General Gov. Facil. Cost: 1,783,984 1)From Coordinated Population Forecast Since the resort will make future tax payments to the County, those payments should be deducted from the facilities cost in Table 5-35. When fully built out, Thornburgh Resort will represent approximately 2.2%of the County's tax base and will therefore fund 2.2%of these facility costs.The net cost for general government facilities after deducting future tax revenues is $1,744,601, as shown in Table 5-36. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 65 Table 5-36: Net general government facility cost for Thornburgh Resort after deducting future property tax contributions. Net General Government Facilities Costs Total general gov. facilities cost: 1,783,984 Future property tax contribution (at 2.2%) 39,383) Net general gov.facilities cost: 1,744,601 The costs and revenues associated with general government services were not estimated in this study,as there are many types of services and it would have been very difficult to determine how much demand for each of these services would be created by the Thornburgh Resort. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 66 6. Fiscal Impact Summary The section compares the costs and the revenues calculated in the previous sections to determine the net fiscal impacts for the proposed Thornburgh Resort. Revenue Summary Table 6-1 summarizes the total gross annual tax revenues that are estimated for the Thornburgh Resort. Combined property and room tax revenues total $5,521,419 per year. These gross revenues go to pay for all of the services and facilities provided by local government to the resort and therefore do not represent a net windfall. As shown below, these revenues are more than offset by the infrastructure costs created by the resort. Table 6-1: Annual revenue summary for Thornburgh Resort. Revenue Summary Revenue Category Revenue Property Tax Revenue 5,091,123 Total Room Tax Revenue 430,296 Total Annual Revenues 5,521,419 Costs of Facilities As shown in Table 6-2,the total net cost for the five categories of infrastructure required by the Thornburgh Resort is estimated to be$51,284,705.These are effectively one-time costs to local governments that are "due"upon completion of the resort. As noted previously in the text, some of the transportation system costs will be incurred by the State,so not all of these costs will accrue to Deschutes County and its various districts. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 67 Table 6-2: Net cost summary for infrastructure required by Thornburgh Resort. Net Facility Cost Summary Category of Facility Net Cost Estimate(') Transportation System 39,149,282 School Facilities(2) 4,752,973 Fire & EMS Facilities 580,813 Public Safety Facilities 4,591,181 Parks & Rec. Facilities 463,562 Gen Gov. Facilities 1,744,601 Total Net Cost: 51,284,705 1)Net costs are total gross costs,minus any payments or revenues from the resort that fund infrastrycture,including future tax payments and SDCs. 2)The school cost figure is for the lower estimate of student generation In Scenario#2. Services Impacts The costs to provide ongoing services were calculated for three of the six impact categories and compared with the tax revenues generated for that same category. It was not practical to calculate comparative values for schools, transportation and general government,as described previously. Table 6-3 summarizes the revenues and costs and gives a net impact for each category of service. The net impacts are positive for each category. The total net impact is a surplus of$466,344 per year. This accrues to the County and its service districts,since each of these services is funded exclusively by either the County or the service district. Table 6-3: Net annual services impact for Thornburgh Resort. Net Annual Services Impacts for Thornburgh Resort Category of Service Revenue Estimate Cost Estimate Net Impact Transportation System(t)NA NA NA School Facilitiestt)NA NA NA Fire & EMS Facilities 637,731 529,359) $108,372 Public Safety Facilities 1,310,884 ($1,087,960) $222,924 Parks & Rec. Facilities 135,130 82) $135,048 Totals: 2,083,745 ($1,617,401) $466,344 1)Direct revenue and service costs were not be calculated for these categories because they are funded from a combination of sources(Federal,State and County)and revenues from the resort could not be determined. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 68 Fiscal Impact Conclusions The net$51.28 million in infrastructure costs associated with the Thornburgh Resort greatly overshadow the $466,344 annual surplus for County services. In order to consider the overall net fiscal impacts of the resort, the annual surplus for County services was converted to an equivalent amount of capital that could be financed with this cash flow. The$466,344 surplus could service interest and principal payments on a 20-year loan at 6% interest for$5.35 million. Assuming this surplus was used for this purpose,the$51.28 million in infrastructure costs could be reduced to $45.94 million,as shown in Table 6-4. Table 6-4 Net Fiscal Impact of Thornburgh Resort Net Infrastructure Cost 51,284,705 Less Capital Equivalent of Revenue Surplustft 5,348,967) Net Fiscal Impact: 45,935,738 1)This is the value of capital facilities that could be financed with a$466,344 annual revenue stream at 6%interest over 20 years. In conclusion,local governments and local taxpayers will be left with a net cost burden of$45.94 million if the Thornburgh Resort is fully completed as proposed. This is a net cost after the resort has been credited for all known payments and tax revenues it will generate. The$45.94 million cost will be externalized and will ultimately be borne by other taxpayers(not the resort) through some combination of higher taxes, reduced public services,and lower facility service standards. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 69 7. Thornburgh Resort's Economic Impacts This section provides a review and analysis of the jobs and housing issues resulting from destination resorts by examining the proposed Thornburgh Resort as a representative case study. The resort developer,Thornburgh Resort Company LLC, maintains that the resort will create many new construction and operations jobs and will have little impact on housing in the area. To support their position, they have submitted the following two reports as part of the required application materials: An Economic and Benefit Study for the Thornburgh Destination Resort in Deschutes County, Oregon,for Thornburgh Resort Company LLC,by Jon Peterson of Peterson Economics,January 21, 2005. An Employee Housing Analysis for the Thornburgh Destination Resort in Deschutes County, Oregon,for Thornburgh Resort Company LLC,by Jon Peterson of Peterson Economics,August 22, 2005. These reports are referred to here respectively as the Peterson Economic Report and the Peterson Housing Report and collectively as the Peterson Report. The Peterson Economic Report was prepared as part of the required application materials for the Thornburgh Resort. Deschutes County Code Chapter 18.113(B)(19) requires the destination resort applicant to provide: An economic impact and feasibility analysis of the proposed development prepared by a qualified professional economist(s) or financial analyst(s)shall be provided which includes: a.An analysis which addresses the economic viability of the proposed development; b. Fiscal impacts of the project including changes in employment, increased tax revenue, demands for new or increased levels ofpublic services, housing for employees and the effects of loss of resource lands during the life of the project. [Emphasis added.] In spite of the Code requirement,the Peterson report lacks a complete analysis of the fiscal impacts of the project and instead focuses on the property tax revenues that may be generated if the resort is completed. Absent from the report is any analysis of the demands for new or increase levels of public services, The report also neglects to report transient room tax revenues from overnight lodging. The Peterson study, like many economic impact studies provided by developers, portrays an unrealistically optimistic and beneficial picture of the development Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 70 project. Tax revenues,for example, are projected by Peterson to be three times greater than for comparable resorts located nearby. According to a separate study comparing projected tax revenues for commercial developments with actual tax revenues after the developments were completed,projected revenues were found to be overstated by an average of 39%.58 The portrayal of resort development as beneficial is also achieved by ignoring the costs and negative impacts of the project.The Peterson Report ignores all external costs associate with the Thornburgh Resort development. While new jobs, employment compensation and property tax revenues are presented in explicit detail,there is little to no effort made to address the many costs associated with providing public services,public infrastructure,or any of the potential adverse impacts on the community and the environment. In this case, most of the costs are likely to be borne by the current and future residents of Deschutes County via increased taxes or declining services,or both. Costs that are externalized by the developer and shifted onto the local community improve the developer's profitability at the expense of local residents. Job Creation and Employment Impacts The employment and compensation data in the Peterson Economic Report(as Table II-1)was revised downward seven months later in the Peterson Housing Report(as Table 1), so the more-recent Housing Report data is used here. The Housing Report bases projected wages for the Thornburgh Resort on a past projection for an analysis the company did for the Suncadia Resort in Roslyn,WA in 2002 and inflated to 2005 values. By their own figures, almost half of employees(49%)will make less than $21,000 per year and 67%will make less than $26,000 per year. As shown in Table 7-1, Federal guidelines indicate that household incomes below$21,200 represent the poverty level for a family of four. Such households may qualify for Federal aid from the Food Stamp Program, the National School Lunch Program, the Low-Income Home Energy Assistance Program,and the Children's Health Insurance Program. 58 Commercial Development:Impact Analysis Before and After Construction,by C.Fred DeKay,Ph.D. and Barbara M.Yates,Ph.D.,Economic Development Journal,fall 2005,p 7. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 71 Table 7-1: 2008 US Poverty Guidelines. Persons 48 Contiguous in Family or Household 1 2 3 4 States and D.C. 10,400 14,000 17,600 21,200 5 6 24,800 28,400 7 32,000 8 35,600 For each additional person, add: 3,600 Source: Federal Register,Vol.73,No.15,January 23,2008,pp.3971-3972 Resorts are notoriously low-paying businesses. The "leisure and hospitality"sector, that includes destination resorts,pays the lowest of any employment sector in Deschutes County. This sector paid average annual wages of only$16,096,about half as much as the average annual wage in Deschutes County of$31,492 in 2006, according to the Oregon Employment Department.s9 The Peterson Report appears to be considerably overestimating wages for the proposed Thornburgh Resort. Peterson claims that only 7% of jobs will pay less than 16,000 per year. This contrasts sharply with the $16,096 average wage in this sector. Many more than 7%of the jobs created at the resort will likely pay minimum wage. Such jobs include maids,waitresses, dishwashers, groundskeepers,landscape maintenance workers,janitors, and laborers. Minimum wage in Oregon was $7.25 per hour,or about$14,500 in 2005 when the Peterson report was written. In 2008 the State's minimum wage was $7.95 per hour,or approximately$15,900 before taxes. According to Oregon's Report on Poverty 200660 for Deschutes County: The 2005 average[monthly]wage of$2,624, however,proved inadequate for single parents.Deschutes County's 2005 average wage could not fund the basic family budget for a single adult and one child or more. The second largest industry in Deschutes County, leisure and hospitality,paid an average wage nearly half of the county average—$1,342 a month. ... Families earning poverty level wages could afford no more than 40.2 percent of basic family expenses in Deschutes County. 99 Oregon Employment Department,2006,as quoted in 2007 Central Oregon Area Profile,by Economic Development for Central Oregon. eo Oregon Housing and Community Services. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 72 Based on the Peterson Housing Report,61 the median wage offered at Thornburgh would be about$21,000. Median household income in Deschutes County was 45,894 in 200462, more than twice as much as the resort will pay. Even if two members of a household worked full time at the Thornburgh Resort, they would still make less than the median County household income in 2004 and the effect of the resort will be to depress median wages in the County. Peterson uses"induced jobs" to enhance the total employment-related compensation associated with the resort. However,this induced employment works both ways: increasing jobs when hiring,but decreasing jobs in a similar proportion when firing. Using Peterson's assumption of 03 induced jobs per construction job and 0.2 induced jobs per operations job, total employment associated with the resort will peak at 2,015 jobs in the sixth year of development. However,when construction is completed, 1,471 of these jobs will be lost. The loss of 1,471 jobs is roughly equivalent to the closing of Central Oregon's second largest employer, Les Schwab Tire Centers(1500 employees). It will have an even greater impact due to the relatively higher salaries paid to construction workers. The loss of these jobs will have a profound impact on the region as these households struggle to pay bills and seek to relocate to other areas in search of employment. The lost jobs are likely to increase local demand for social services and public assistance and may result in evictions, foreclosures and bankruptcies. The magnitude of these job losses could negatively impact the local economy for years after the resort is completed. 61 Peterson Housing Report,Table 2. 6z According to the US Census Bureau. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 73 Figure 7-1: Direct employment at the proposed Thornburgh Resort estimated by Peterson (based on Peterson Housing Report,Table 1). Projected Direct Jobs,Thornburgh Resort 1200 1000 800 600 400 — 11 YII200 4 5 6 7 8 9 10 11 12 Project Year 0 Construction Jobs Operations Jobs Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 74 Figure 7-2: Total direct and induced employment at the proposed Thornburgh Resort estimated by Peterson(based on Peterson Housing Report,Table 1). Projected Jobs, Thornburgh Resort 2500 - 2000 1500 1000 — 3 _ a. N500 a N c101 wki O I I III I I 1 2 3 4 5 6 7 8 9 10 11 12 Project Year Direct Jobs hduced Jobs Total Jobs Figure 7-3: Employment changes resulting from the Thornburgh Resort development(based on Peterson Housing Report). Annual Changes in Projected Employment, Thornburgh Resort 1000 - 899 800 566 600 411 400 185 200 0 u,,.a I T 200 69 51 -52 179 -188 400 1 2 3 4 5 6 112' 8 9 10 11 600 - 490 512 Project Year Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 75 Theoretically, the only way to prevent such employment shocks from impacting the local economy(other than not building the resort in the first place) is to continually and indefinitely build more resorts at a steady and even pace in Deschutes County. However,this approach is completely impractical as the County could not sustain such development over the long term,and it would be impossible to transition seamlessly from one development to the next for employment purposes. Who Will Fill New Resort Jobs: Locals or Newcomers? The Peterson Report claims that"in excess of 90%"of employees will live in Deschutes County. To support this, they cite anecdotal evidence from conversations with the management of Black Butte and Eagle Crest Resorts that a"vast majority" of employees live within the County. Without additional evidence, Peterson claims that these employees were also local County residents before their employment at these resorts.63 This apparently forms the bases for Peterson's conclusion that only 8%to 10%of jobs created at Thornburgh Resort will be filled by newcomers. However, empirical data and studies indicated that the percentage of newcomers moving into Deschutes County to fill resort jobs will be much higher. Recently it came to light in a Bend Bulletin article that not only are resorts filling some of their jobs from out of the area,they are actively recruiting foreigners.`The Sunriver Resort filled 85 jobs last year with people from as far away as Lithuania, Brazil and Mexico. People may move to a new county for a variety of reasons. Deschutes County has outstanding recreational opportunities and natural amenities that attract people from all over the country. A limiting factor to County in-migration is employment. While there may be a large number of people who would like to live there, most will need employment to make such a move successful. Thus, the more jobs created in the County,the more people will be able to move there. To a large extent this same phenomenon applies statewide in Oregon. The State is viewed as offering attractive natural amenities and a desirable quality of life that act to stimulate in-migration. But the limiting factor to in-migration is the lack of employment opportunities. As a result of this "pent up" demand, new jobs created in the State are rapidly absorbed by newcomers and unemployment levels tend to remain consistently above the national average. This was the case even during the 1990s,a decade of the most rapid economic expansion and job creation in the State's history. 63 Job seekers who move to a new location seeking work often obtain a local address to use for job applications,so employers may not know if they are hiring new arrivals. 64"Unemployment might be high,but resorts still struggle to fill some jobs,"The Bulletin,May 11, 2008. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 76 As shown in Figure 7-4, the US Census found that"work-related" reasons accounted for 31.1%of all intercounty moves 65 More specifically, 24%of all moves were either for new jobs/transfers or to look for work. "New jobs and job transfers" accounted for the most moves of any category in the Census survey. Clearly,employment is a major motivational factor in migration. This factor is amplified when a region offers additional amenities and quality-of-life benefits as found in Central Oregon. Figure 7-4: Reasons for moving to another county(US Census). intercounty movers Other reasons 10.1 Family-related reasons 26.9 u Work related reasons 31.I Housing-related reasons 31.9 Source:US.Census Bureau,Current Population Survey,March 2000. When new jobs are created in a community by a development project, its proponents often claim that the jobs will go to local workers. However,studies show that in the near term,40%to 60%of new jobs go to newcomers and in the longer term,60% to 90% of these jobs are filled by newcomers. 66 Applying the midpoint estimates to the Thornburgh Resort,we can assume that construction jobs are shorter-term jobs that are filled by 50%newcomers and operations jobs are longer-term and are filled by 75% newcomers. As shown in Table 7-2,at peak employment,the resort will generate an estimated net in-migration of 1,150 workers to fill the jobs. This is considerably more than the 133 newcomers identified in the Peterson report. 65 Why People Move:Exploring the March 2000 Current Population Survey,Special Studies,US Census Bureau,March 2001. 66 See: Who Benefits from Local job Growth,Migrants or the Original Residents,by Timothy J.Bartik, Regional Studies,vol.27,No.4, 1993. Impact of Destination Resorts in Qregon Fodor&Associates March 2009 page 77 Table 7-2: Peak In-Migration to Deschutes County Due to Direct and Induced Jobs at Proposed Thornburgh Resort. Peak Percent Jobs to Jobs to Job Source Employment"" Newcomersm Newcomers Construction 964 50% 482 Const. Induced 482 50% 241 Operations 474 75% 356 Oper. Induced 95 75% 71 Total: 2,015 1,150 1)Based on Peterson Housing Report;(2)From Bartik,1993. Housing Impacts of Thornburgh Resort Increased demand for housing will tend to increase prices, especially when there is a relatively fixed supply of housing and a marked increase in demand. Unless housing is expanded to meet the new demand,prices will increase and housing will become less affordable in the County. The loss of housing affordability becomes a regional cost associated with the resort. The Peterson Housing Report states that,due to the vacancy rate in Deschutes County,all housing needs generated by construction and ongoing operations at the resort will not"pose a problem."This conclusion seems to imply that the resort will have no significant impacts on the local housing demand or supply in Deschutes County. To the contrary, we find that the resort will have substantial impacts on the needs and demands for local housing. Peterson indicates that additional offsite job creation will be induced by the onsite jobs at the resort. However,no consideration is given to the housing demand created by the induced employment. Peterson reports that induced jobs peak in year six of the development at 577 jobs. Total jobs are estimated to peak at 2,015 at that time, including construction,operations and induced employment. The addition of more than 2000 new jobs to Deschutes County,many of which are temporary and low- paying,will have a very significant impact on the local housing market. This effect on the housing market is aggravated by the fact that most of these jobs 985 by Peterson's estimate)will be temporary. Temporary demands for a significant quantity of local housing can create multiple problems. As the demand grows rapidly, housing prices go up,housing availability and affordability decline,and additional home construction may be stimulated. As the temporary demand comes to an end,there is a glut of housing with a sharp increase in vacancies and unsold homes that may leave the housing market in worse shape than before the resort started. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 78 Most ongoing jobs will be low-paying groundskeepers, maids, and maintenance positions. Such jobs may attract workers who will require low income housing assistance and will increase demand for affordable housing in the County. Furthermore,many of the lower-paying jobs will be seasonal,or have significant seasonal variations in employment. Seasonal jobs will further stress households that are struggling to afford market-rate housing as their employment varies from season to season. Lower-paid workers will have more difficulty finding affordable housing near the resort and they will need to travel farther to meet their housing needs. The additional commuting requirements will further exacerbate their financial stress. Renters in Deschutes County are currently struggling to meet housing costs. According to the US Census,41%of the County's renters are paying more than 30% of their income for rent 67 New destination resorts will increase local housing demand and push up rental prices forcing more local residents to spend a greater share of their incomes on housing. Peterson estimates that during the 11-year period of resort construction,between 37 and 133 housing units will be required to supply the new workers (both construction and resort operations)and that all of these units can be met from the current inventory of vacant housing. However,this conclusion is based partly on the unrealistic assumption that more than 90%of jobs will be filled by local residents and that only 8-10%will be filled by people moving into the county. As shown previously, the Thornburgh Resort is likely to attract newcomers to fill 1,150 of the peak jobs generated by the resort. Most of these newcomers will create new households in the County. However,some may live with others or have a spouse that is also employed by the resort. To estimate new households it was assumed that 30% of the newcomers will either live with others who work at the resort or have a spouse also working at the resort. These cohabitating workers would reduce demand for new housing by 15%(half of 30%). The newcomers will therefore generate a peak demand for 978 housing units in Deschutes County(Table 7-3). 67 Source: U.S.Census Bureau,2005 American Community Survey,Deschutes County. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 79 Table 7-3: Estimated new households created by peak employment at Thornburgh Resort. Jobs & Households Generated Number Peak jobs at Thornburgh 2,015 Peak jobs to newcomers (from Table 7-2)1,150 Newcomers cohabitating (30% assumed) 345 Households by new cohabitating workers 173 Households by other new workers 805 Total new households by newcomers: 978 The Peterson Housing Report states that there was "an existing vacancy inventory of more than 320 rental units in Deschutes County" in order to show that the County can absorb the modest demand they predict from resort employees without generating any need for additional housing. However,the Peterson data does not appear to be accurate and there is no source cited. The Central Oregon Rental Survey Results for 2004 showed 411 vacant units for all of Central Oregon. The most recent Central Oregon Rental Survey Results for 2007 (1"Quarter) showed 270 vacancies for all of Central Oregon with a 6.86%vacancy rate. However, this survey provides only a partial account of vacancies, since the US Census 2005 American Community Survey shows there were 18,552 rental units in Deschutes County in 2005 with a vacancy rate of 6.4%,or about 1,187 vacant units. Vacancies always exist in the rental housing market and don't necessarily represent housing availability. Vacancies are a natural part of the rental housing business. Turnover of rental units typically requires a period of vacancy between tenants so that the unit can be cleaned,marketed and leased. Rental units also require repairs and improvements during unoccupied periods. Less-desirable, substandard,or overpriced units may take longer to rent. Rental vacancy rates in 2005 were 9.8% nationally and 8.3%in Oregon,much higher than the 6.4%rate in Deschutes County. The likely demand for housing resulting from resort employment will be much greater than Peterson has estimated. Peterson estimated a peak demand of 133 housing units,compared with the estimate here of 978 housing units. It is unrealistic for the Thornburgh Resort to rely on local rental vacancy rates to meet the housing needs for the estimated 1,150 peak jobs filled by newcomers. As shown in Table 7-4,the Thornburgh Resort is projected to create direct and induced long-term employment of 544 persons from year 12 of the project onwards. An estimated 75%of these jobs will be filled by newcomers. Of the 408 permanent jobs filled by newcomers, an estimated 347 new households will be created by these Impact of Destination Resorts in Oregon Fodor&Ass«fates March 2009 page 80 employees 68 This will result in a permanent demand for 347 new housing units in the County. Table 7-4: Newcomers to Deschutes County Filling Permanent Direct and Induced Jobs at Proposed Thornburgh Resort(year 12 of project and onwards). Permanent Percent Jobs to Jobs to Job Source Employment"" Newcomersiz'Newcomers Operations 453 75% 340 Oper. Induced 91 75% 68 Total: 544 408 1)Based on Peterson Housing Report. 2)From Battik,1993. Spending by Destination Resorts The typical economic analysis presented by a developer estimates the total gross spending in connection with the development as a net benefit to the local community. The spending estimate is often magnified by use of multiplier-effects to show even greater benefit to the local community as direct spending ripples through the local economy. Thus, spending figures typically include both direct and induced secondary)spending for wages, construction materials and services. Such spending figures tend to greatly overstate local benefits. For example, assumptions are made that 100%of spending for construction,including materials and supplies,will stay in the local county. However,construction materials such as lumber, cement,appliances, cabinets,flooring,plumbing fixtures, lighting,doors, windows,plaster and paint are obtained through a national and international supply network. It is highly unlikely that a significant portion of these construction materials will be produced within the county. Therefore, most of this spending quickly leaves the county. Many economic studies also assume that other construction-related spending, such as design, engineering,and construction labor,will stay in the local county. However, many of the design firms and construction companies are likely to be based out of the area,or even out of state. Most of the expenditures to firms and employees based out of the area will leave the local county. 6R Estimate assumes that 30%of employees will share housing with another employee,reducing household generation by 15 percent. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 81 Use of"multiplier effects" is a common practice in economic analysis. Multipliers are used to show how money can be recycled in a community or region and can significantly inflate the apparent economic benefits. In contrast,empirical studies show that local growth does not result in real benefits to the community in terms of increased per-capita income.69 Therefore,it must be assumed that much of the direct and indirect economic activity flows out of the community and does not significantly benefit local residents. In this case, "multiplier effects"are likely to be offset by national builders, national building materials suppliers,and non-local workers who will take much of the money out of the community. If multipliers are to be used in impact analysis,they should be applied to cost as well as revenues (see sidebar on this topic). Use of multipliers An increasingly common method among the building industry and some governments for projecting fiscal impacts involves the use of multipliers derived from economic models. Using data from the models,an analyst might take the estimated direct economic activity in dollars associated with a project and "multiply"it by a given amount to account also for indirect, secondary impacts.The total measure of economic activity is then used to estimate revenues for the purpose of determining fiscal impacts. Such multiplier approaches to fiscal impact analysis suffer from several shortcomings. First,the multipliers are usually obtained from economic models of large regions or states.But they are applied at the level of an individual local jurisdiction that is usually only a fraction of a region's or state's economy.The smaller the jurisdiction relative to the economic region for which the multipliers have been derived,the less reliable the multipliers will be for that jurisdiction. Furthermore,while the multipliers are applied to the revenue side of the budget,few such analyses ever apply a multiplier to the cost side of the local budget.The implicit(but often wrong)assumption is that local governments can generate revenue from secondary, induced,or indirect development without incurring increased costs in providing services to that development.Another shortcoming of the multiplier approach is its tendency to"double-count" revenues.A multiplier-based fiscal analysis of a project might credit it with the additional revenue impacts as derived from 1,000 new jobs elsewhere in the jurisdiction. But,when the separate fiscal impact analysis of the development where these jobs are located is (or was) prepared by its developer,the revenues would also be claimed on behalf of that development. Source:Developments and Dollars:An Introduction to Fiscal Impact Analysis in Land Use Planning, by Michael L. Siegel, May 2000, Natural Resources Defense Council. In the case of the Peterson Economic Report for the proposed Thornburgh Resort, compensation is estimated for both direct and induced jobs. While totaling all the wages paid for direct and induced employees is straightforward,it is far less clear how this spending should be counted in terms of net benefits to Deschutes County. 69 Gottlieb,Paul D.,Growth Without Growth:An Alternative Economic Development Goal For Metropolitan Areas,Center for Regional Economic Issues,Weatherhead School of Management,Case Western Reserve University,A Discussion Paper Prepared for The Brookings Institution Center on Urban and Metropolitan Policy,February 2002. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 82 Wages benefit the individual employee, but he or she must exchange their time and labor for the wage. Employment is therefore an economic transaction exchanging labor for money. From the local perspective, existing residents of Deschutes County will benefit from resort employment if: 1. They are currently unemployed and obtain employment at the resort,or 2. They are working part-time and obtain full-time employment at the resort, or 3. They are currently employed,but are able to obtain higher wages at the resort. On the other hand, existing residents of Deschutes County will not benefit from resort employment if newcomers move into the County to fill the jobs. Only the incremental increase in the incomes of existing local residents resulting from resort employment can be counted as a clear economic benefit. This incremental increase in income is a fraction of the total compensation figure estimated for the resort and does not include the 40%to 90%of new jobs likely to go to newcomers. Economic Risks In addition to considering the likely economic impacts of a successful and completed resort, there are emerging risks associated with resort development that could dramatically affect local homebuyers, local government investments, and the local economy. The national economic downturn has revealed structural weaknesses in the real estate markets. Property values became over-inflated and banking institutions lent too much money to unqualified buyers. The supply of homes grew at record levels until supply greatly exceeded demand. It may take several years before the real estate market stabilizes. In the mean time,foreclosures and bankruptcies are at levels not seen since the Great Depression. In the past,California provided many of the second home and investment home buyers in Oregon. Many were able to transfer equity from their California homes to make these purchases. But California's real estate market has suffered greatly. The median price of a home in that state dropped 38%in December from a year earlier.70 Under any circumstances,a destination resort is a risky business venture. If it goes well, it is a potential bonanza to investors. But a great deal of investment is required up front. Typically a hundred million dollars or more must be borrowed and spent to build these resorts. The Thornburgh Resort estimates the total project cost at 160 million.' What happens if revenue streams don't match projections? What if 70 December median home prices in California dropped to$249,000 from$402,000 a year earlier the Associated Press reported January 22,2009. Peterson Economic Report,Table IV-1. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 83 lots don't sell,or prices drop?If one resort fails,how will other resorts in the area be impacted? In Deschutes County the Tetherow Resort's golf course was heralded as the"Best New Course of 2008" by Golf Magazine. However, lot sales have stalled,investors are unable to make loan payments,and the bank is foreclosing on properties.'Z The large,upscale Tamarack Resort in Idaho made the Wall Street Journal last year when investor money dried up and the resort went into default on loans.73 Construction of resort facilities stopped and the bank filed for foreclosure. Homebuyers had already committed more than $500 million for fancy homes, condos and building sites. The resort village remains unfinished, home sales have withered and the local economy is suffering. The resort closed on March 4, 2009 and 250 employees were fired. Of 2,100 planned chalets,condos and town homes,only 250 are completed.74 The Vineyards Resort in Yakima,WA declared bankruptcy last year.75 It was to be a destination resort in wine country designed as a Tuscan-themed village with 500 acres,600 homes, an 18-hole golf course,clubhouse,hotel,and recreation center. They were unable to obtain financing for the $100 million investment needed. The posh Yellowstone Club resort in Montana is also declaring bankruptcy.76 According to the Wall Street Journal article on the Tamarack Resort, A resort's success was often staked to real-estate sales:As a Tamarack lender recounted in recent court filings, the resort had a business model in which "operating expenses would exceed revenues and the primary source ofprofit would be generated by the sale of real estate." Destination resorts are following the same business model as the rural subdivision: buy large tracts of cheap rural land to make hundreds,or thousands,of buildable residential lots for a large profit. The resort elements are often unprofitable,but make the residential subdivision possible. The Tetherow and Pronghorn Resorts in Deschutes County have been unable to build the required amount of overnight housing,which is intended to support tourism. According articles in the Bend Bulletin, Pronghorn was to have completed a hotel by 2006.77 It has received four time extension from the County and cut its planned hotel expenditure in half. 72"Tetherow housing lots are entering foreclosure,"The Bend Bulletin,January 15,2009. 73 Wall Street Journal,"In Idaho,Ski Resort's Promise Fades,"7/7/2008. 74"Tamarack Resort closes;employees cut loose,"Seattle Post-Intelligencer,March 4,2009. 75 Reported by the Associated Press,November 23,2008 in the Seattle Post-Intelligencer. 76 See http://www.bloomberg.com/apps/news?pid=20601103&sid=ai WwtVGzHrY&refer=news. 77"Without financing,Tetherow on hold indefinitely: Hotel won't open in spring 2009 as planned," The Bend Bulletin,October 15,2008. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 84 If Thornburgh Resort is successful,its developer could make$300 million on lot sales, almost doubling its investment. The lucrative profit potential for 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 Impact 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 services,public infrastructure, and the potential adverse impacts on the community and the environment. The"leisure and hospitality" sector(that includes destination resorts)paid average annual wages 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 Thornburgh 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 four. Most jobs created by the resort will be temporary and when construction is completed, 1,471 jobs will be lost, causing ripple effects 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 lost. 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. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 85 8. Implications for Impacts of Destination Resorts in Oregon This section considers the potential statewide and regional impacts that may result from the resorts that are currently under construction and those that are proposed. In order to examine the potential statewide impacts of destination resorts in Oregon, total figures for the number of residential units were calculated for all resorts that are currently planned or under construction. The total number of residential units was then used as an index for gauging statewide impacts. The impact per residential unit is based on the impact analysis for the Thornburgh Resort. As described previously, the Thornburgh Resort is fairly typical of destination resorts in Oregon in terms of its overall profile(land area, mix of homes and overnight units, and recreational facilities). Some factors affecting impact will vary from place to place. For example, sewage treatment,water supply,and stormwater management may involve offsite public expenses for some resorts,but did not in the case of Thornburgh. Such cost factors may be governed by county policies and individual siting issues. The transportation system impacts of the Thornburgh Resort were partially mitigated by the transportation SDC implemented recently by Deschutes County. Total estimated transportation SDC payments for the resort were deducted from the transportation system costs. Most counties in Oregon have no transportation SDC,so the costs will be higher in those counties. It should also be noted that no impacts were calculated for Thornburgh Resort for libraries. As a result of these factors,Thornburgh's fiscal cost impacts may be somewhat less than for the typical new resort. None-the-less, it serves as the best available gauge at this time. The net fiscal impact per residential unit for the Thornburgh Resort is a cost of$33,408.78 Based on the 22,374 residential units in destination resorts that are either under construction or proposed in Oregon, the total fiscal impact is estimated to be a net cost of$747 million. As shown graphically in Figure 8-1, almost two-thirds of this cost will come from the resorts that are proposed. Note that these net infrastructure costs are the externalized costs from the resorts after all payments and contributions are deducted. 7e This net cost incorporates the projected revenue surplus from services in the form of the capital cost that could be financed with the same annual revenue stream,as described in the Fiscal Impact Conclusions section. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 86 Figure 8-1 Future Statewide Resort Costs Total Net Cost=$747,455,211) Esc, n Resorts Under Construction, 262,039,728 s'4 5 f Resorts Planned, 485,415,483 Destination resorts have regional impacts that often receive little or no consideration in the resort planning and siting process. Resorts located near cities tend to create a fundamental fiscal inequity. The counties receive all the tax revenues, and the nearby cities receive much of the impacts, especially from increased traffic. Resort residents and visitors will avail themselves of the urban services and amenities of the city. They may travel to the cities to purchase necessities, for entertainment,or to commute to work in these cities. They may also travel through these cities going to and from the resort and to visit other attractions in the area. Resort employees are likely to find housing in the nearby cities and will create additional traffic. The City of Redmond will be especially impacted by new resort development,as four new destination resorts are planned nearby: Remington Ranch,Hidden Canyon, Brasada Ranch,and Thornburg Resort. The Remington Ranch Resort is just 5 miles from Redmond and it is estimated that 75%of the trips generated by the resort will use the city's road network. An estimate 35%of the trips from the proposed Hidden Canyon Resort will be to,or through, Redmond. According to City of Redmond Public Works Director, Chris Doty, the city's growth is currently constrained by road capacity and by requirements of the State's Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 87 Transportation Planning Rule.79 Yet resort development can continue to burden these transportation facilities without having to mitigate their impacts. Housing needs for resort employees put added pressure on nearby cities to provide additional affordable housing, as resort workers are among the lowest-paid in the State. Impacts of resorts on nearby cities are beyond the cities' control and occur outside of the cities'planning processes. Redmond,for example,collects a Transportation System Development Charge on new development within the city,but is unable to collect such charges from resort development. Resorts have the potential to function like suburban subdivisions or bedroom communities, taking advantage of a nearby city's urban amenities,but paying no taxes to the city. Revenue sharing by the county, or mitigation requirements from the resort developers, could offset some of these impacts. Letter from Chris Doty regarding Remington Ranch Resort to Bill Zelenka,Crook County Planning Department,September 7,2006. Impact of Destination Resorts in Oregon Fodor 8c Associates March 2009 page 88 Appendices Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 89 A-I. Property Tax Explanation The single largest revenue source for local governments,school districts and agencies in Oregon is the property tax. Property subject to taxation includes all privately owned real property(land,buildings,and improvements). This tax is collected by the county tax collector for all agencies within the county. As the boundaries of the various taxing districts do not align the county is divided into Code Areas. Each Code Area represents a unique combination of taxing districts. For the 2008/09 tax year, the proposed Thornburgh Resort was located in two different Code Areas: 2-003,with a total tax rate of$12.2499 per thousand dollars of Assessed Value; and,2-004 with a total tax rate of$14.0041 thousand dollars of Assessed Value. The difference being that property in 2-004 is subject to a tax from Deschutes County Rural Fire Protection District #1. Table A-1 Tax Code Area 2-00380 Id District Total Rate Education Government Non-Limited 001 Deschutes County 1.2783 1.2783 007 Jail Bond 0.1335 0.1335 010 Fairgrounds Bond, 0.1410 0.1410 011 County Library 0.5500 0.5500 020 Countywide Law Enforcement 0.9500 0.9500 021 Rural Law Enforcement 1.4000 1.4000 070 Redmond Library 0.0567 0.0567 090 County Extension/4h 0.0224 0.0224 093 911 0.1618 0.1618 095 911 Local Option 2008 0.2300 0.2300 351 Redmond Area Park&Rec District 0.3717 0.3717 620 School District#2j 5.0251 5.0251 626 School#2j Bond 92&93 0.8307 0.8307 628 School#2j Bond 2004 0.2930 0.2930 651 High Desert Esd 0.0964 0.0964 670 C 0 C C, 0.6204 0.6204 671 C 0 C C Bond 0.0889 0.0889 Total 12.2499 5.7419 4.9642 1.5438 80 Data from Deschutes County 2008-09 Summary of Assessment and Tax Roll page 80. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 90 Table A-2 Tax Code Area 2-00481 Id District Total Rate Education Government Non Limited 001 Deschutes County 1.2783 1.2783 007 Jail Bond 0.1335 0.1335 010 Fairgrounds Bond, 0.1410 0.1410 011 County Library 0.5500 0.5500 020 Countywide Law Enforcement 0.9500 0.9500 021 Rural Law Enforcement 1.4000 1.4000 070 Redmond Library 0.0567 0.0567 090 County Extension/4h 0.0224 0.0224 093 911 0.1618 0.1618 095 911 Local Option 2008 0.2300 0.2300 202 Rural Fire District#1 1.7542 1.7542 351 Redmond Area Park&Rec District 0.3717 0.3717 620 School District#2j 5.0251 5.0251 626 School#2j Bond 92&93 0.8307 0.8307 628 School#2j Bond 2004 0.2930 0.2930 651 High Desert Esd 0.0964 0.0964 670 C 0 C C, 0.6204 0.6204 671 C 0 C C Bond 0.0889 0.0889 Total 14.0041 5.7419 6.7184 1.5438 Since 199782 the assessed value(AV) of a property,and not its real market value RMV), is used to calculate the amount of property tax due. This assessed value was initially established in 1997 by rolling back the RMV of a property to 90%of its 1995 level. As long as the resulting AV is less then the current RMV this value is allowed to increase by 3%annually. For new properties,like the proposed Thornburgh Resort,the County Tax Assessor's Office appraises the property and sets a RMV for the land and its improvements. Then,an Exception Value Ratio is applied for the property class"of the parcel to arrive at the properties initial RMV. For example, the AV of a parcel in a property class with a ratio of 0.46 and a RMV of$100,000 would be$46,000. The Exception Value Ratio is calculated annually and is the ratio between AV and RMV for properties of the same property class. The Current Exception Value Ratio for resort properties is 0.49183 Property tax is levied on July 1 and due on November 15 each year. It can be paid either in a single payment on or before November 15, in which case a 3% discount can be taken,or in three payments due on the 15th of November, February and May. If taxes are not paid within three years the property is subject to foreclosure. 81 Data from Deschutes County 2008-09 Summary of Assessment and Tax Roll page 80. 82 A relatively detailed history of the Oregon Property Tax system can be found as Appendix B of Oregon Property Tax Statistics an annual publication of the Oregon Department of Revenue. 83 Deschutes County 2008-09 Summary of Assessment and Tax Roll,page 9. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 91 Property Tax Revenue Methodology The basic formula for calculating the initial property tax84 on a new development such as Thornburgh is simple and straight forward. It is: Property Tax = ((RMV x Exception Value Ratio)/1000)x Tax Rate The(RMV x Exception Ratio)establishes the initial AV for a new property. All that is necessary is to supply values for the RMV, Exception Ratio and Tax Rate. The Property Class"for the Thornburgh Resort is "#8 Resort," and the Exception Value for all properties in the Resort for 2008-09 is 0.491 which was the value used. As pointed out earlier,the Thornburgh Resort was located in two different Code Areas (2-003 and 2-004)with different tax rates. But, as those parcels not in Code Area 2-004 are to be annexed into the Deschutes County Rural Fire Prevention District #1,85 it was assumed that the$14.0041 tax rate of Code Area 2-004 would apply to all properties in the resort. Establishing a RMV for each type of property was difficult as only the briefest of descriptions was provided in the Thornburgh Resort Application. These descriptions lacked information as to parcel or lot size,building size, construction materials to be used,amenities or expected or proposed costs. Three different methodologies were used to establish a RMV for the various types of properties. For the 1,375 residential properties86 proposed for the Thornburgh Resort a single methodology was used. The land-use application for the resort contained very little information on the characteristics of the residential development, so for calculation purposes, it was assumed that all the residential units and lot sizes would be similar. To arrive at a value for these properties, a sample of 49 residential properties located in the nearby Eagle Crest Resort8'was obtained by selecting a number of parcels from each of the tax maps containing part of Eagle Crest. The current RMV for the land and improvements for each of these parcels was obtained from Deschutes County's D.I.A.L system.88 Townhouses were excluded from the sample. Average values were calculated for a sample of 38 lots and 35 houses. 84 In subsequent years the formula is the same as all other property,(AV/1000)*Tax Rate. 85 Letter from Fire Chief Tim Moor of DCRFPD#1 to Deschutes County Commissioners dated 25 March 2008. 86 The total includes 425 with deed restrictions that they be available for short term rental and 950 without the deed restrictions. 87 Eagle Crest Resort is an existing Destination Resort similar in concept to and located in close proximity to the proposed Thornburgh Resort for which property tax records were available. 88 This is an online tax record system. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 92 The County RMV data from 2008 reflects the peak prices of the real estate bubble should be adjusted downward to reflect current market conditions. The Standard and Poor's/Case-Shiller 20-city housing price index fell 18%in October of 2008 from a year earlier.89 It appears that this downward trend in real estate values is likely to continue through 2009 and possibly longer. To reflect the decline in values,average values from the Eagle Crest sample were reduced by 20%to obtain the RMV of the residential land and improvements in our calculations. For Commercial and resort-owned properties,90 total building square footage was provided in the application. A$200 per square foot construction cost was used to establish an RMV for the commercial improvements. To determine the RMV of the land it was assumed that the lot associated with a building would be twice the square footage of the building (i.e. 50%lot coverage). To reflect declining real estate values, the value of comparable developed commercial parcels at Eagle Crest were reduce by 20 percent in the same manner as residential property. For the Golf Courses it was assumed that they would be 150 acres each and would cost$3 million dollars each to construct.91 The land value was obtained by averaging the cost per acre of 5 Eagle Crest parcels identified as containing significant parts of a golf course. 89 Year-over-year declines in property values were reported in the Standard and Poor's/Case-Shiller 20-city housing price index. See Home Prices post 18 percent annual drop in October,by J.W Elphinstone,AP,December 30,2008. 90 Hotel,Recreation Centers,Golf Club Houses, SPA and Retail Center 91 The web sites for the United States Golf Association and American Society of Golf Course Architects both contain a$1.6 to 4.5 million range for the construction cost of a Golf Course,$3 milllion is roughly the midpoint in that range. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 93 A-2. Transient Room Tax Explanation Deschutes County imposes a Transient Room Tax on the guest of any Hotel or short term rental housing92 located in an unincorporated part of the county. This tax is in the amount of 7%of the full rent charged by the rental manager for the occupancy of a room. The room tax is not imposed on items separate and independent from the use of the room93 nor is it imposed on recreational fees". If the room is rented as part of a package deal that includes food and or recreational activities the Hotel operator is permitted to exclude from the rent the cost of providing the food or activities. The hotel operator collects this tax on behalf of Deschutes County at the time the room rate is paid. Monthly,the hotel or rental operator remits the amount of taxes collected minus a 5%"Collection Reimbursement Charge." Revenues from the Transient Room Tax are currently being used to fund services provided by the Sheriff's Office and for tourism through the Central Oregon Visitors Association." By state law the minimum proportion spent on tourism promotion and tourism-related facilities can not be less then that allocated on 1 July 2003. The current division is about 73%/27%with the majority going to the Sheriff's Office.96 In the FY 2008-09 Annual Budget$2,435,020 or about 19.6%of the operating funds devoted to Rural Law Enforcement came from Transient Room Taxes.97 Room Tax Methodology In its most basic form estimating the amount of revenue raised by the Deschutes County Room Tax from a hotel is a very straight forward process. The revenue equals the room rate, times the occupancy rate,times .07, times 365 days,minus 5% of the total. Making an estimate of a proposed hotel where the only information is 92 The Deschutes County Code(DCC)defines"Hotel"as"...any structure or space,or any portion of any structure or space which is or intended or designed for Transient Occupancy for 30 days or less, for dwelling,lodging or sleeping purposes,and includes,but is not limited to any Hotel,inn,tourist home,tourist accommodation,condominium,motel,studio Hotel,hostel,bachelor Hotel,lodging house,bed and breakfast,vacation home,vacation rental home,rooming house, apartment house, public or private dormitory, fraternity, sorority, public or private club,mobile home,R.V.or trailer park,campgrounds private home, or similar structure or portions thereof so occupied. [DCC 4.08.045] 93 Items such as Food service,Room Service,Pay for view movies long distance telephone. 94"Recreation Fee"means a fee charged,assessed,or allocated by a Hotel to a Hotel occupant or occupants for use of Destination Resort recreation facilities, whether the Hotel charging the Recreation Fee is a Destination Resort or has a contract or agreement with a Destination Resort for use by the Hotel's guests of the recreation facilities of the Destination Resort.[DCC4.08.065] 95 Deschutes County Annual Budget for Fiscal Year 2008-09 page iii. 96 Deschutes County Annual Budget for Fiscal Year 2008-09 pages 332 and 370 97 Deschutes County Annual Budget for Fiscal Year 2008-09 page 370 Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 94 the number of rooms, as is the case here, requires a number of assumptions to be made. In order to estimate the average room rate,it was assumed that the Hotel and other rental units would meet the American Automobile Association's Three-Diamond Rating98 criteria. This rating is the middle of a 5 level scale and is typical of the ratings held by other resorts in Oregon99. There are 14 Three-Diamond Hotels operating in Deschutes County of which rate information is available for 12 of them. The rates range from a low of$89 to a high of$439 per night. Based on the number of distribution of room types in the AAA Guide, it was assumed that there are four times as many inexpensive rooms as there are expensive rooms. The weighted average room rate is $121 per night. Just as there is little information on the configuration of the hotel there is little information on the configuration of the 450 houses that will be available for short- term rental. In order to estimate vacation home rental rates, the assumption was made that they would resemble those currently on the short term rental market for the Greater Redmond area. The Vacation Rentals by Owner web site listed 39 vacation homes available for vacation rental in Redmond, Oregon.10°Twenty-eight of these listings were for rentals in Eagle Crest Resort. The rates for these houses run from $100 to $300 a night,with an average rate of$162. The last variable is the occupancy rates for each type of unit. While the total monthly Transient Room tax receipts paid by all operations subject to Transient Room Taxes are available,actual occupancy data is extremely difficult to come by. To develop an annual occupancy rate estimate,a peak occupancy rate of 90%was assumed for the month of August and then an adjusted occupancy rates for each of the other months was calculated based on the actual monthly Transient Room Taxes paid to the County for that month. From this an average annual occupancy rate for all rental types was derived,as described below. Occutancy Rates for Room Tax Revenues Room tax revenues are difficult to estimate for a planned,but unbuilt resort such as Thornburgh. Occupancy rates and reporting rates(the percent of private rentals for which room taxes are paid) must be estimated.To estimate occupancy rates, County- wide room tax revenues101 were examined and adjusted to reflect the likely seasonal 98 According to AAA,"Three diamond lodgings offer a distinguished style.Properties are multi- faceted with marked upgrades in physical attributes,amenities and guest comforts."(AAA Oregon and Washington Tour Book,AAA Publishing,Heathrow,Florida,2008,page 21) 99 The 2008 AAA Oregon and Washington Tour book lists 7 Oregon Resorts,one Two-Diamond,five Three-Diamond and one Four-Diamond. 00 Data collected on 21 December 2008 from http:www.vrhbo.com/vacation- rentals/region/usa/Oregon/central-oregon. 101 Data from Deschutes County Treasurer Marty Wynn. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 95 nature of this resort. The County-wide vacancy rate was estimated based on the assumption that a peak occupancy rate of 90%is achieved during the peak month of August. This may be overly optimistic, as many private rentals will be occupied by owners during this month. However,this peak occupancy rate was used as a reference to estimate occupancy rates for the rest of the year(see Figure A-1). Average annual occupancy for the County was estimated to be 33%based on this method. Hotels and lodging in Bend, and resorts such as Sunriver and Inn of the Seventh Mountain,are close to Mt. Bachelor and can maintain modest winter occupancy rates. However, resorts such as Thornburgh are located too far away to benefit from skiing. Since Thornburgh would lack off-season appeal,it was assumed that rental occupancy would drop to an average of 10%from November through April. For the remainder of the season,County-wide vacancy rates are applied(see Figure A-2). This results in an average annual occupancy rate at Thornburgh of 29%. Figure A-1: Deschutes County occupancy rates based on monthly room tax revenues. Estimated Rental Occupancy Rates, Deschutes County, 2007 100% 90% d 80% ti 70% - 60% R 50% c 40% v 30% 0 20% 10% b 7 n L• 4 Q fn Z O Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 96 Figure A-2: Occupancy rates used for Thornburgh Resort. Estimated Rental Occupancy Rates for Thornburgh Resort 100% 90% 80%cu ro 70% cc 60% o m 50% 3 40% O 30% 20% 10% • • 0% c .o zi m c rn Wa 5y? > u I.A. 9 c/) V 2 Resort vacation homes that are managed by a property management firm will tend to fully report room taxes, as the room tax revenues provides compensation to these firms to offset administrative and collection costs. However,privately-owned vacation homes that are owner-managed may not fully report room taxes to the County. This situation may occur at Eagle Crest Resort,where a recent property owner survey conducted by Jen-Weld specifically mentioned that survey respondents would not be reported to the County if they were renting their house. For Thornburgh, it was assumed that 80%of privately-owned rental homes are fully reporting room taxes,and that 100%of hotel room rentals are reported. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 97 A-3. Population Projection Used in Study The population figures used throughout this study are from the Deschutes County 2000-2025 Coordinated Population Forecast. The forecast data for each of the 5-year increments was interpolated using exponential growth rates to create data for each year in between, making it possible to examine population changes over any period of time. In order to create a 20-year forecast through 2028, the projection data was expanded beyond 2025 to 2028 using the same growth rate as in the final 5-year period (2020-2025). Table A-3 Interpolated Population Data for Every Year to 2028 Based on Deschutes County 2000-2025 Coordinated Population Forecast Bend Redmond Sisters Unincorp. Total Year UGB UGB UGB County County 2005 69,004 19,249 1,768 53,032 143,053 2006 71,294 20,100 1,864 54,199 147,475 2007 73,661 20,989 1,966 55,391 152,033 2008 76,106 21,916 2,074 56,609 156,733 2009 78,632 22,885 2,187 57,854 161,578 2010 81,242 23,897 2,306 59,127 166,572 2011 83,135 24,953 2,379 60,428 170,914 2012 85,072 26,056 2,454 61,757 175,369 2013 87,054 27,208 2,532 63,116 179,940 2014 89,082 28,411 2,611 64,505 184,630 2015 91,158 29,667 2,694 65,924 189,443 2016 92,981 30,979 2,782 67,374 194,144 2017 94,841 32,348 2,874 68,857 198,962 2018 96,738 33,778 2,968 70,372 203,900 2019 98,673 35,272 3,065 71,920 208,959 2020 100,646 36,831 3,166 73,502 214,145 2021 102,337 38,459 3,275 75,119 219,231 2022 104,056 40,159 3,387 76,772 224,437 2023 105,804 41,935 3,503 78,461 229,768 2024 107,582 43,788 3,623 80,187 235,225 2025 109,389 45,724 3,747 81,951 240,811 2026 111,227 47,745 3,875 83,754 246,530 2027 113,095 49,856 4,008 85,597 252,385 2028 114,995 52,060 4,146 87,480 258,379 Data from County(population for intermediate years are added). Added projections based on previous 5-year growth rates. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 98 A-4. Tax Bases for Jurisdictions Used in Study The total assessed values of the tax base for each of the local jurisdictions used in this study are provide in Table A-4. The final column of the table shows the percentage of each tax base that would be represented by the Thornburgh Resort if fully developed. This percentage was treated as the potential future contribution by the resort towards repayment of bonds associated with the infrastructures costs generated. Table A-4 Potential Contribution to Infrastructure Costs Through Future Tax Payments Percent of Future Taxes Assessed Value Paid by Category of Infrastructure Jurisdiction of Tax Baseltf Thornburgh12> Transportation Systemt3i Deschutes County NA NA School Facilities Redmond School Dist. $4,937,455,942 7.1% Fire & EMS Facilities DCRFPD#1 1,295,518,889 22.4% Public Safety Facilities Deschutes County 16,602,476,500 2.2% Parks and Rec. Facilities RAPRD 288,870,875 56.5% Gen Gov. Facilities Deschutes County 16,602,476,500 2.2% 1)Data from the 2008-09 District Summary Table on page 16 of the 2008-09 Summary of Assessment and Tax Roll published by the Deschutes County Assessors Office.Assessed value of school district from Redmond School District. 2)The percent of the total future tax base represented by the resort based on a fully-developed resort with a total assessed tax value of 374,788,817. 3)Transportation system is not funded by property taxes. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 99 A-5. About the Authors Eben Fodor,Principal Author Mr. Fodor is Founder and Principal of Fodor& Associates,a consulting firm based in Eugene, Oregon since 1993. The firm specializes in community planning and land use consulting,including fiscal impact analysis, growth management,land-use planning,economic forecasting,and research and analysis. He is an expert in development impact analysis. He created a development impact model for the City of San Diego that quickly estimates infrastructure and service costs for new developments of any size and mix of uses. He has examined the fiscal impacts of development proposals in Washington, Oregon, Maryland and Wyoming for various clients. He conducted statewide assessments of infrastructure impacts of residential development in Oregon and Washington. Mr. Fodor holds a Masters in Urban and Regional Planning and a M.S. degree in Environmental Studies,both from the University of Oregon. He holds a B.S. degree in Mechanical Engineering from the University of Wisconsin - Madison. David Hinkley,Research and Analysis Mr. Hinkley has worked since 1996 providing public policy research, analysis and advocacy services to lobbyists, candidates,businesses and individuals. Areas of expertise include land use codes,government budgeting, tax increment financing, development impacts,state land use programs, systems development charges, transportation issues,disability issues,bottle bills, campaign contributions,and liquor laws. He served 8 years on the City of Eugene's Public Works Rates Advisory Committee helping to revise the City's System Development Charge methodologies for transportation,waste water and parks systems. Mr. Hinkley holds a Bachelors of Arts degree in History from the University of San Francisco and a B.S. degree with Honors in Criminal Justice Administration from San Jose State University. Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 100 Waterworks Consultants 4017 Willowbrook Lane Bellingham, WA 98229 360-296-8084 Memo To: Gerald Steel From: Llyn Doremus Date: July 17, 2009 Re: Technical review of: Water Supply and Groundwater Impact Analysis Pleasant Harbor Marina and Golf Resort— November 20, 2008 (SDEIS) Recommendations for Additional Hydrogeologic Testing at Black Point Background The Pleasant Harbor Marina and Golf Resort is planned for construction on the Black Point Peninsula in Hood Canal. The peninsula is surrounded by salt water for more than 75% of it's shoreline. At least 15 wells are located along the Black Point eastern and northern shorelines that are at risk of seawater intrusion. Hood Canal is known to have a serious problem with depleted dissolved oxygen content, which has resulted in what has been termed a "dead zone". The dead zone creates conditions where a wide range of sea life that requires dissolved oxygen in the waters of their environment cannot survive. The depleted oxygen condition is known to result from enhanced activity of bacteria and algae that is promoted by discharge of nutrients (nitrogen and phosphorus) dissolved in surface and groundwater to Hood Canal. The two conditions: seawater surrounding the Black Point Peninsula and the potential for seawater intrusion to degrade water quality in shoreline wells, and extreme sensitivity of Hood Canal biologic health to the release of nutrients generate a very delicately balanced hydrogeologic environment in which the Resort is proposed for construction. The Resort water supply for residential, commercial and irrigation purposes has been proposed through a combination of rainwater capture, reuse, reclamation, infiltration, and groundwater withdrawal processes. While the general scheme of the supply system has been outlined in previous documents, the specifics of how each of the components will operate has not yet been accurately defined. The potential for negative impacts of the various supply system components on the delicately balanced hydrogeologic environment is high. A sophisticated understanding of the Black Point hydrogeologic system is mandated to assess potential for degradation from the proposed water supply scheme to dissolved oxygen levels in Hood Canal, to seawater intrusion into the Black Point aquifer, and for the design, maintenance and operation of that system to function without degrading the Black Point aquifer and Hood Canal. These comments address the hydrogeologic characterization presented in the report: Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort by Subsurface Group, LLC. November 20, 2008 (Report) with respect to the information necessary for characterization, design and operation of a water supply system that does not degrade the Black Point aquifer. The accuracy and completeness of the Report assumptions, information and conclusions are assessed, and recommendations for additional testing to fill in the information gaps in the Report are listed. Hydrogeologic System Groundwater moves through the sediments and rock, which, along with the other water moving through the system, defines the hydrolgeologic system of a specific site. Sediment tends to form in layers, which can be visualized as a "layer cake" type configuration. Sediments and rock layers with a large percentage of void spaces typically transmit water more quickly, which is termed a high permeability hydrogeologic unit. Sediment layers that are more dense, with tiny void spaces are termed "low permeability" or"impermeable". Low permeability sediment layers impede downward migration (infiltration) of groundwater, and tend to accumulate water on their upper surface. This is normally how unconfined aquifers form. The permeability of an aquifer is usually determined by conducting a pump test. With the exception of the single pump test of the American Campground well, and the marginal data generated from that test, there is no data presented on the aquifer properties of the various hydrogeologic units on the Black Point Peninsula. RECOMMENDATION FOR ADDITIONAL TESTING The Report describes results from a pump test conducted in the American Campground well for 48 hours to assess the permeability and other aquifer properties in the well vicinity. The data generated by the test was found to be insufficient to assess the aquifer properties, because the drawdown in Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort Technical Review and Recommendations 2 the monitoring wells was almost undetectable. Pump testing should be conducted in all of the wells that are proposed for water supply purposes. The pumping rate used should be equivalent to the rate at which water is proposed for withdrawal for the water supply needs of the resort(at a minimum 75 gallons per minute to provide the 121 acre feet annual use projection), because of the likelihood that individual wells may be relied upon for the full volume for the resort water demand when problems with water level drawdown and seawater intrusion occur. The tests should be run for sufficient duration (minimum 72 hours) to derive measurable drawdown curve in at least one of the monitoring wells, so that reliable aquifer properties can be calculated. The direction of groundwater movement is defined by the groundwater gradient. Groundwater moves from locations of high water elevation level to low elevation discharging eventually to lower-elevation surface water bodies. The groundwater elevation pattern often mimics the ground surface topographic elevation pattern. Downgradient (lower groundwater elevation) locations manifest the affects of groundwater movement and withdrawal in higher elevation locations. It is important to understand the directions of groundwater movement in order to assess the magnitude and distribution of ground water level decreases associated with groundwater withdrawal (pumping from wells). In particular, reduction in the groundwater levels in shoreline areas increases the risk of seawater intrusion into water supply wells. The Report presents an interpretation of groundwater flow direction towards the center of the peninsula and then to the east (discharging into Hood Canal). The groundwater surface elevation contours are illustrated in Figure 4 of the Report, and suggest that a groundwater high point (at MW-2) dominates groundwater flow direction on the entire peninsula. That single data point (MW-2 water level elevation) is disproportionally valued in interpreting the groundwater flow directions. RECOMMENDATION FOR ADDITIONAL TESTING Groundwater levels should be measured in every accessible Black Point Peninsula well on the same date, so that a groundwater elevation contour level map can be constructed that is reliable for use in interpreting the direction(s) of groundwater movement. A better understanding of the direction of groundwater movement will support a better interpretation of the groundwater withdrawal impacts to private wells on the Black Point Peninsula and seawater intrusion risk. Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort Technical Review and Recommendations 3 Diagrams of the Black Point Peninsula hydrogeologic system are presented in the Report Figures 11, 12 and 13. Much of the site is covered with dense, low permeability till. About one third of the site has additional sediments deposited on top of the till that are higher in permeability and allow water to migrate more quickly through them. Water that migrates downward through these higher permeability sediments might slow down and accumulate in a "perched" aquifer upon encountering the underlying low-permeability till. There is no evidence of perched conditions at this site presented in the Report. Basalt bedrock is shown in Figures 13 in wells located on the northern part of the site. The contribution of groundwater flow transmitted through bedrock to the Black Point aquifer is not well characterized in the Report, nor is the bedrock permeability, or the hydraulic connection between bedrock and the overlying unconsolidated sediments. With the exception of the single pump test of the American Campground well, and the marginal data generated from that test, there is no data presented on the aquifer properties of the bedrock or unconsolidated sediment hydrogeologic units on the Black Point Peninsula, or on the hydraulic continuity between unconsolidated sediment units and the bedrock underlying them. Further pump testing (as previously described) is necessary to better define aquifer properties of the hydrogeologic units and the hydraulic continuity with bedrock on the site. Water Budget A water budget uses estimates or measurements of each component of the hydrologic cycle to assess the entire movement of water through a specific hydrologic system annually. For the purposes of characterizing the impact of the proposed water management scheme on the the Black Point Peninsula aquifer and hydrogeology, the water budget should encompass the entire Peninsula. To prevent or at least minimize detrimental impacts it is essential that the components of the water budget are defined as accurately as possible. A typical equation for a water balance is as follows. Ppt= E + Q + dSg + dSs Where: Ppt= annual precipitation E = annual evaporation plus transpiration (evapotranspiration) Q = stream flow or surface water runoff dSs = the change in quantity that is stored as surface water for the year negative for a decrease in the water quantity in surface storage) Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort Technical Review and Recommendations 4 dS9 = the change in the water quantity that is stored as groundwater for the year (negative for a decrease in the groundwater storage, indicating a drop in groundwater levels) Surface Water Flow Although surface water is not flowing onto the proposed Pleasant Harbor Resort site, the quantity of water discharged from Black Point Peninsula as stream flow impacts the water budget for the Peninsula. Accurate stream flow measurements help reduce uncertainty in other portions of the hydrologic budget that are more difficult to estimate. Stream flow emitting from the lake in the eastern-central portion of Black Point Peninsula, as well as any other stream flow on the Peninsula needs accurate assessment in order to calculate its contribution to the water budget, and its influence on the other components of the budget. RECOMMENDATION FOR ADDITIONAL TESTING(Q) Stream flow emitting from the lake on the eastern-central margin of the Peninsula, and flowing to the east shoreline should be monitored to assess the rate of surface water runoff from the Peninsula. Surface Water Storage Surface water is typically stored in lakes and wetlands. To better understand the changes in surface water storage that are ongoing under current conditions dSs), and that may be expected from the proposed use of kettles as water storage facilities, the water stored in Lake (on the eastern margin of the Peninsula) should be monitored for changes in lake elevation. It is likely that the lake is in hydraulic continuity with groundwater, and receives groundwater discharge. A better delineation of lake level variations, and their relationship to precipitation quantities and timing, and groundwater levels will improve the understanding of how groundwater moves through the Peninsula hydrogeologic system. RECOMMENDATION FOR ADDITIONAL TESTING(dSs) Monitor lake level elevation over the period of a year (concurrent with other monitoring data collected). Precipitation Precipitation provides water that supports the various water uses and hydrologic components. Annual precipitation at this site is poorly understood because of the variability in precipitation along the north south extent of Hood Canal, and the lack of monitored data collected in the Black Point Peninsula or Brinnon vicinity. Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort Technical Review and Recommendations 5 RECOMMENDATION FOR ADDITIONAL TESTING(Ppt) Precipitation should be monitored on the Black Point Peninsula for an entire year. In addition, the data available from the NOAA approved weather station at location AS461 on the west side of Hwy. 101 across from Pleasant Harbor should be analyzed. See Attachment 1 hereto. Groundwater Storage Groundwater that is stored in an aquifer is the amount of water that is added to the aquifer over the course of the year(termed recharge) minus the amount withdrawn or discharged from the aquifer. Recharge to an aquifer derives from precipitation that infiltrates into the ground. Discharge from an aquifer typically goes to stream flow (Q), or it may be pumped for water supply or irrigation purposes, or, in this case, includes flow into Hood Canal to diminish salt water intrusion into the fresh water supply. The difference between the amount recharged and the amount discharged is the change in storage (dSg). Quantification of recharge is an important factor in assessing the storage changes in groundwater, as is quantification of the discharge. Recharge of an aquifer results from vertical infiltration of precipitation that falls on the ground surface overlying the aquifer. Aquifers are more rapidly recharged when the sediment overlying the aquifer is of"high permeability" and when there is high annual precipitation. Consider if the precipitation that infiltrates to recharge the aquifer is half(50%), the standard assumption when data is not available to calculate actual recharge rates. For this site the annual precipitation rate is not well known, which makes the annual recharge rate even more difficult to assess. Table 3 lists 55 inches for annual precipitation in Quilcene (the closest site monitored). Half of this is 27 inches, or 2.3 feet. For this 220 acre site, this provides an annual recharge of 504 acre feet (significantly less than the 783 acre feet claimed in the Report on page 17). The presence of low permeability till will slow down groundwater infiltration, and likely reduce the rate of groundwater recharge to the aquifer even further than estimated using these assumptions. There will be substantial additional evapotranspiration caused by the watering of the golf course and other vegetation in the hot months of the year. This has not been adequately considered. RECOMMENDATION FOR ADDITIONAL TESTING (dSg) Groundwater levels in the three monitoring wells (MW-1, MW-2 and MW-3) should be monitored for at least one year, to determine the variation in groundwater elevation. Precipitation should be monitored on the site for at Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort Technical Review and Recommendations 6 least one year to determine the actual precipitation received annually concurrently with other monitoring data collected). Analyses of recharge quantities and rates should be done using monitored data, and presented in the calculation of the water budget for the site. A separate set of calculations should be done assuming serious drought conditions— perhaps an estimated 500-year drought. Quantification of groundwater discharge is calculated using measurements of changes in groundwater elevation, stream flow measurements, pumped quantities from the aquifer, and precipitation measurements. It is important to delineate the groundwater flow direction and to delineate locations of groundwater discharge, to more accurately assess the annual amount of groundwater discharging from the aquifer. The change in groundwater storage calculated amount (dSg) relies upon an accurate estimation of annual groundwater discharge and its relative value with respect to the annual recharge amount. Additionally, discharge of groundwater from beneath the proposed resort to Hood Canal, that contains contaminated landscaping chemicals especially nitrate and phosphorus) poses a significant risk to the environmental health of Hood Canal. Evapotranspiration The information presented in the Report on estimations of evapotranspiration 24.1 or 24.2 inches per year), need to be presented with data, formulas, tables, and assumptions used in those calculations, as part of the comprehensive water budget estimation. Summary of Recommendations for Additional Testing To better understand the hydrogeologic response to the proposed water supply management scheme in this relatively sensitive groundwater environment, each of the components of the hydrologic cycle should be more accurately quantified. In addition, the aquifer properties must be better defined to design a supply system that does not overstress the aquifer. The following tests are recommended in order to gather that information. Aquifer properties Aquifer testing — pump tests should be conducted for a minimum of 72 hours in any wells that might be proposed for water supply purposes (American Campground Well, Pleasant Tides Coop Well (Sam Boling Water System/Black Point Water Company) and MW-2). Pump tests should be conducted for long Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort Technical Review and Recommendations 7 enough to generate a measurable drawdown in at least two monitoring wells in the vicinity. Pumping rate at the Pleasant Tides Coop Well should include the 300 gpm for existing water rights plus the proposed new withdrawal. Pump testing at MW-2 should include installation of a monitoring well, at a location that is as close as existing wells are to the eastern shoreline, in line with the MW-2 well. Chloride testing of water pumped from the aquifer should be done when the MW-2 is pump tested. Pump testing at the Pleasant Times Coop Well should include monitoring for water level drawdown and for chloride at the other Black Point Water Company wells, the Babare well, the Tudor well and the other Pleasant Harbor Beach Tract Owners wells. Seawater intrusion Chloride content in groundwater should be determined in samples collected from wells pumped adjacent to the marine shoreline over the duration of the pump tests. At a minimum one sample should be collected prior to initiation of pumping, another after at least 12 hours of pumping and a third shortly before pumping is stopped. More samples provide more confidence in the data collected, and the interpretations derived from that data. Chloride concentrations between 100 and 200 mg/I indicate wells at moderate risk for seawater intrusion, with 200 mg/I being the trigger for high risk, according to Island County's Seawater Intrusion Policy (a copy is included with these comments as Attachment 2). Groundwater movement Groundwater levels should be measured in every accessible well on the same date, so that a groundwater elevation contour level map can be constructed that is reliable for interpreting the direction(s) of groundwater movement. A better understanding of the direction of groundwater movement will support a better interpretation of the groundwater withdrawal impacts to private wells on the Black Point Peninsula and seawater intrusion risk. Water Budget The presentation of the water budget in the Report makes it impossible to assess the individual components of the water budget, their relationship to each other, and what data was used to derive them. A comprehensive explanation of the water balance calculations must be provided. This should include: water budget equation used Values for each component the equation Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort Technical Review and Recommendations 8 data, calculations and assumptions used to derive each value In particular the following components need better delineation. Precipitation Precipitation should be monitored on the Black Point Peninsula site for the duration of a year (concurrent with other monitoring data collection). Recharge Groundwater levels should be monitored with continuous electronic logs in the three monitoring wells, and reported for the duration of a year to assess the range of groundwater level variation, and the recharge resulting from precipitation events. Precipitation monitoring should coincide with groundwater level monitoring periods. Precipitation should be used to evaluate the changes in groundwater levels associated with precipitation events (i.e. recharge) Evapotranspiration Evapotranspiration calculations, and the data and assumptions used in those calculations needs to be presented in report form. Streamflow Stream flow emitting from the lake on the eastern margin of the Peninsula, and flowing to the east shoreline should be monitored to assess the rate of surface water runoff from the Peninsula. Lake Level Monitor lake (located in the central-eastern portion of Black Point Peninsula) level elevation over the period of a year concurrent with other monitoring data collected. Water Supply and Groundwater Impact Analysis, Pleasant Harbor Marina and Golf Resort Technical Review and Recommendations 9 Water budget analysis for Black Point Peninsula and the proposed Pleasant Harbor Marina and Golf Course June 3,2010 SILVER TIP SOLUTIONS Dr.Christina J.Bandaragoda 1-425-501-4191 christina@silvertipsol.com Llyn Doremus Waterworks Consultants 360-296-8084 llynadele @gmail.com I Executive Summary The Pleasant Harbor Resort and Marina is proposed for construction on Black Point Peninsula;the 220 acre facility would dramatically change the land surface of the 710 acre peninsula located in Hood Canal. A data-based water budget was calculated for the Black Point for current forested conditions and for the changed land cover and water usage conditions proposed for the Resort. With the construction and operation of the Resort,60 acres will be converted to irrigated golf course, 37 acres to buildings and paved impervious surfaces, 17 acres to lined irrigation pond water storage,60 acres will remain in native forest cover,and we assume the remainder of the 46 acres will be used for bioretention or rain gardens.. The changed land cover will modify the existing water balance that distributes annual precipitation to the processes of evapotranspiration and groundwater infiltration. Evapotranspiration(ET)was calculated for daily timesteps using climate conditions(monitored at Quilcene)and limited by the available water precipitation and ponded surface water). Water ponded in wetlands,bogs and fens at the ground surface infiltrates to recharge groundwater at a rate limited by the soil infiltration capacity of the Black Point till sediments after the daily ET demand is met. With Resort development,impervious surface and landscaped areas will generate surface water runoff. The water budget we calculate,based on the Environmental Impact Statement(EIS)and Resort project plans,includes surface water runoff,changes to the evapotranspiration rates and the affects of groundwater pumping. The removal of trees from 160 acres of the site will modify evapotranspiration rates,causing ET increases in summer months and decreases in winter months. To supply the commercial and domestic water needs and the landscaped areas water demand,groundwater will be pumped from the aquifer. We estimate that groundwater recharge will be reduced by as much as 50% as a consequence of:the groundwater pumping(for irrigation and human consumption), changes to the evapotranspiration rates and generation of surface water runoff from impervious surfaces landscaped areas. With the decrease in recharge to the groundwater, we expect the aquifer to be steadily depleted,given the proposed development plans. Any decrease in aquifer recharge increases the potential for seawater intrusion along the shorelines of the Black Point Peninsula. The EIS and development plans do not use a realistic value for infiltration,which results in an underestimate of surface runoff and overestimate of aquifer recharge. We estimate that the annual amount of surface water could be over 400 acre-ft with the proposed land cover changes;twice as much as what could be contained in a 60,000,000 gallon lined pond. Any untreated surface water runoff from landscaped surfaces can be expected to transport nutrients to Hood Canal, degrading the already depleted dissolved oxygen conditions. 2 1.0 Introduction Black Point Peninsula borders Hood Canal within Water Resource Inventory Area 16(WRIA16; Sections 15 and 22 of T25N,R2W). Pleasant Harbor Marina and Golf Resort is proposed for development on 220 acres of the peninsula. This constitutes approximately one-third of Black Point,which is currently moderately or undeveloped mature forest. Black Point is within the coastal Seawater Intrusion Protection Zone of Jefferson County,WA and is designated as a Critical Aquifer Recharge Area. This water budget analysis explores the two following questions about the proposed development: How much surface runoff quantity can be expected from land uses that may require water quality treatment? How does the aquifer recharge and drawdown change with the proposed development compared to current recharge? Using plans and estimates from previous studies(Subsurface Group,2006; 2020 Engineering,2007)as well as daily climate data,we analyze the potential water supply and demand for the proposed resort development as a function of seasonal weather conditions,in order to estimate changes to Black Point peninsula hydrology given the proposed development. This work addresses the insufficient scope of recent studies Subsurface Group,LLC,2006;2020 Engineering,2007)to 1)accurately calculate Evapotranspiration,a major component of the overall water balance which controls current and potential future water supply 2)the seasonal effects of groundwater pumping for irrigation requirements,and to 3)present a refined water budget estimate for current and proposed resort development land cover conditions.An important difference between our estimates and other studies(Subsurface Group,LLC,2006;2020 Engineering,2007) are related to the limitation of the annual recharge to 23 in/year plus four inches of soil moisture holding capacity(Morgan and Jones, 1999). This value has also been used by the USGS1 for regional aquifer system analysis of Puget Sound(Vaccaro,et a1., 1998). By comparing the current forested conditions water budget with the modifications to the water budget from the proposed development,calculated on a daily timestep using climate data collected in the Black Point vicinity,we show that the water budget estimated by Subsurface Group LLC(2006),developed using annual averages,does not account for the decrease in recharge and increase in surface runoff expected with the proposed land cover change. The current or undeveloped water budget can be expected United States Geological Survey 3 to change dramatically under the proposed developed conditions.The mature forest land cover water use is subject to seasonal limits of water supply,and produces minimal surface water runoff. In contrast,the planned irrigated landscaping artificially alters the water budget by providing unlimited water supply to the landscaped vegetation demands via groundwater pumping,and the developed impervious and landscaped surfaces produces surface runoff in excess of what can be controlled by engineered ponds and bioretention gardens. 2.0 The Water Budget The water budget, or water balance, is important for understanding how changes to one component of the hydrologic cycle will affect other components in the system. In all systems,when more resources are available than are used,there is a surplus;when more resources are needed than is available,there is a deficit. In natural systems, vegetation develops over long time scales in balance with the available resources. Engineered hydrologic systems are generally developed to overcome a deficit of water during dry summer—high demand summer months. The long-term effects of the changes are subject to a range of uncertainties. But by definition,land development and the associated land cover change, alters the water balance by changing the seasonality of supply and demand. 2.1 The Current Water Budget The current water budget(coWB)can be assumed to be in balance(changes in WB on an annual average equal 0),since the demands on the system have developed dependent on the available water resources and infiltration capacity. We use an infinity sign to signify the long-term balance that has developed for the natural system,in contrast to an altered or developed land surface. There is no excess surface water runoff, because there is no stream or creek which conveys surface water runoff or channelization that has evolved on the land surface. The annual average water budget for the current system is therefore defined as: oWB=Rainfall—Evapotranspiration—Groundwater recharge 1) In Equation 1,the amount of rainfall either cycles back into the atmosphere through evaporative and vegetation use,collectively referred to as Evapotranspiration,or the rainfall infiltrates through the soil to recharge groundwater. On a monthly timescale, there is a potential for high rainfall winter months to create surplus water that is ponded on the ground surface in wetlands,bogs,and fens and then slowly infiltrates(or evaporates). Equation 2 describes the adjustment to the water balance in the winter caused by an increase in rainfall.There is a decrease in evapotranspiration due to cooler temperatures,and increase to groundwater recharge at the maximum rate defined by the 4 soils infiltration capacity(Groundwater recharge.). Increases and decreases in each of the components of the water budget are shown with up and down arrows(respectively), with a positive(+)water balance(or surplus)shown for the winter. Equation 3 depicts the summer water balance as defined by a decrease in rainfall.There is an increase in evapotranspiration due to wanner daily temperatures,a groundwater recharge rate limited by the soil infiltration capacity and the available water(Groundwater recharge.avauai,tw). A negative(-)water balance or deficit is shown for the summer. Summer water deficits result in unmet water demand by the vegetation,since both evapotranspiration and recharge are limited by the available water. 0eWB winter Rainfall j' -Evapotranspiration 4,-Groundwater rechargemax (2) O°WB summer= Rainfall 4, -Evapotranspiration 'I` -Groundwater rechargemaxawwabie (3) Taken together,winter and summer water budget(Equations 2&3)are in an annual balance(Equation 1),where the annual precipitation,the capacity of the land surface to hold excess water in wetlands,the water use by vegetation,and the groundwater recharge function together to balance the system. 2.2 Water Budget for the Proposed Resort Development The water budget(AWB)estimated for the developed resort will depend on change to the land cover and water use. Here we use the delta symbol to signify a change to the annual water budget compared to Equation 1. The demands on the current water budget depend on alteration of the land surface due to resort development,which will modify water ponding,or saturated surface water holding,infiltration to groundwater, and surface runoff quantity. The natural undisturbed soil surfaces,with high ponding capacity, are proposed to be reduced from 220 acres of mature forest to 60 acres of mature forest. Additional bioretention gardens with high infiltration capacity are also proposed,but we are not aware of the exact plan and number of acres of bioretention gardens and their planned capacity. Impervious surfaces(planned for 37 acres of the resort)will generate surface runoff. The addition of this Surface Runoff variable to the water budget(Equation 1)is shown in Equation 4. 6WB=Rainfall—Evapotranspiration—Groundwater recharge—Surface Runoff 4) Evapotranspiration from the developed resort is expected to be reduced in the winter with less forest transpiration,and increased in the summer with more grass evapotranspiration than current forested conditions. This is explored further as shown conceptually in Equations 5 and 6. The decrease in winter evapotranspiration will result in an increase in surface runoff. Simultaneously,the groundwater recharge will be 5 reduced because of the change in land cover and the associated reduction in surface water holding capacity compared to undisturbed soils of the mature forest. In the winter,we can expect a water surplus due to reduced evapotranspiration and reduced soil moisture capacity(Equation 5)compared to the current conditions(Equation 2). An increase in summer evapotranspiration supported by irrigation pumping will be used to supply the full potential evapotranspiration water demand of the landscaped grass. Because of the increased evapotranspiration demand,less water will be available for groundwater recharge in the summer, and impervious surfaces will continue to generate surface runoff during rain events. In the summer,we can expect a water deficit due to the increase in evapotranspiration,runoff and associated groundwater pumping(Equation 6)compared to the current conditions (Equation 3). The annual average water budget for the proposed system in the winter and summer is defined as: AWB winter=Rainfall T -Evapotranspiration .1,4,-Groundwater rechargemax4, Surface Runoff (5) 4WB summer= Rainfall 4, -Evapotranspiration "T'1 -Groundwater rechargemaxa,auable4, Surface Runoff T (6) Equations 1 through 6 provide the conceptual framework for how land use changes affect multiple variables simultaneously. The best way to understand how these variables operate in concert,is to use observed climate data to estimate average values for each component of the current and developed water budget.In the following sections,we estimate on a daily timestep,and then average by month,how the land cover changes due to the proposed resort development will increase the winter surplus,and increase the summer deficit. This level of detail is required to understand whether the proposed changes to the peninsula water budget will be adequately addressed by the proposed engineering solutions to protect the Black Point aquifer from drawdown and the risks of saltwater intrusion,as well as protect Hood Canal from increased surface water runoff and the associated water quality degradation from of the surface runoff. 3.0 Evapotranspiration Evapotranspiration is a key element of the water balance whereby water is converted from liquid to vapor phase. Evapotranspiration(ET)is the combination of soil and vegetation processes where water is removed from the ground surface and transmitted to the atmosphere. Depending on the land cover and stage of vegetation growth,water is removed from soil and water surfaces by evaporation as well as transpired by trees or crops. Potential ET is the amount of water that can be evaporated and transpired given an unlimited supply of water.Normally ET is limited in summer months by the water availability,which is termed Actual ET. Actual ET is affected by 6 climate conditions of rain(or irrigation water),temperature,wind speed,humidity,air pressure, and solar radiation. Evapotranspiration estimates presented in this report were calculated using the ASCE2 standardized Penman-Monteith ET equation(Jensen et al, 1990). The available weather data used for calculation of evapotranspiration includes 1)daily total solar radiation, 2)average wind speed,3)minimum daily temperature, 4)maximum daily temperature,5)minimum daily relative humidity,6)maximum daily relative humidity, and 7)precipitation recorded in Quilcene starting in 2006 and continuing to present day for this report,analysis ended March 31,2010). Solar radiation is a required input parameter for the ASCE standardized Penman-Monteith ET equation. This method for calculated ET was recommended by the 1999/2000 ASCE Task Committee on Standardization of ET(Walter et al.,2000). The FAO Penman Monteith methods(Allen et al, 1998)used in the Environmental Impact Statement(Subsurface Group,LLC,2006) to calculate ET predate the ten year old ASCE recommendation. Although climate data has been collected at the Quilcene station since 2001,solar radiation data was only available for 2005-2010. This five-year dataset provides the parameters necessary to more accurately estimate the water balance variable of ET,used in Equations 1 through 6. The evapotranspiration rate of approximately 24 inches per year reported in the EIS(Subsurface Group,LLC, 2006)and Water Supply Bulletin No. 54(Grimstad and Carson, 1981),represents the ET of a grass land covered surface. It does not account for the seasonal differences in water demand(transpiration)of forested land cover that are currently unmet in the summer. In this study,the transpiration of mature forest was estimated using the observed transpiration of a mature Douglas-fir forest in a maritime climate(Bosveld and Bouten,2001),where they reported a minimum transpiration rate for nighttime and dry conditions and a maximum peak daytime and wet transpiration rate that equates to an annual transpiration range of 20-50 in/yr3.The soils used in developing this reference transpiration estimate were well-drained on ice-pushed sandy loam and loamy sand textured river sediments(Typic Distocrepts),similar to those present on Black Point Peninsula. About 90%of the fine root length can be expected to be found in the topsoil to a depth of 16 inches(Olsthoom, 1991). Figure 1 illustrates how the annual average rainfall and ET varies under current forested conditions and developed grass-covered conditions throughout the year. The x- 2 American Society of Civil Engineers 3 These values for water use by Douglas-Fir forest was confirmed by author of the referenced article,Fred Bosveld,personal correspondence,05/10/2010. 7 axis begins in July so that the winter months are centered in the plot. Using the Quilcene dataset(2005-2010),the average monthly rainfall(Figure 1,blue line)ranges between 11 inches/month in the winter and 1 inch/month in the summer. The potential forest transpiration(Figure 1,solid dark green line)demand is consistently between 2-3 inches/month.In the summer,water demand is partially met by available surface water stored in wetlands near the surface. But once the ground surface dries out,there would not be enough water available to meet the forest transpiration demand;instead,the Actual forest ET is the estimated water demand(Figure 1,dashed dark green line). In the winter,2 inches/month is consistently used by the forested vegetation,whereas the landscaped grass demand(Figure 1,solid light green line)is close to 0. This difference in the seasonal water demand between the forest ET and the landscaped grass ET has implications for generation of surface water runoff. The reduced grass ET demand in the winter contributes to a change in land cover from forest to grass increases the surface water runoff(or water budget surplus)in the winter. The summer water demand for the irrigated landscaped grass(Figure 1,solid light green line) peaks at a monthly average of 4 inches/month. Unlike the deficit water availability that causes the difference between potential and actual ET for forested conditions,we can assume that the landscaped grass potential ET,the maximum demand,will be met by irrigation. The difference between the peak demand in July of grass(4 inches/month), compared to the minimum water availability from rainfall (at less than 1 inch/month),we assume will be met by the surface water stored in the planned 17-acre lined pond and supplemented by groundwater pumping. Using the Quilcene dataset(2005-2010),the average annual rainfall estimate for the Black Point Peninsula is 47.5 inches/yr. Of this annual average,24 inches/yr is consumed by forest ET(actual). The annual water demand for grass ET would be 19 inches/yr. Whether the surplus rainfall,or rainfall in excess of ET demand,will recharge the groundwater or become surface water runoff, depends on the developed land cover conditions of the proposed Pleasant Harbor Resort and Golf Course and the infiltration rate of the underlying soils. 8 12 Rain 10 Grass ET 8 Potential Forest ET Actual Forest ET 6 8 7 8 9 10 11 12 1 2 3 4 5 6 Month Figure 1. The average monthly change in available rainfall, mature forest transpiration and grass evapotranspiration demand. 4.0 Groundwater Recharge and Surface Water Ponding In order to estimate the effects of removal of mature forest from the proposed development site and replacement with cultivated grass,irrigated landscaping,and impervious surface,the EIS(Subsurface Group,LLC, 2006)presents an estimate of aquifer recharge derived by subtracting annual ET and change in groundwater storage from annual precipitation. If it is assumed that the water budget balances between annual precipitation and the water quantities consumed via ET,surface water runoff and groundwater recharge Equation 4 can be expressed as: A Groundwater recharge=Rainfall—ET—Surface Runoff 7) A positive change in groundwater storage,implies that excess rain is recharging the groundwater aquifer. A negative change in groundwater storage would be expected to lower the water table. Missing from the EIS water budget analysis is the surface water storage effects of ponding on groundwater recharge,which occurs when the precipitation accumulated at the ground surface exceeds the maximum soil infiltration capacity. Equations 8 (current water balance)and 9(developed site water balance)depict adjustments to Equation 7 to account for the surface water storage ponding affects. Rainfall and ponded surface water 9 accumulate at the ground surface under current soil conditions of the undeveloped site U)(expressed in Equation 8 as Surface Storageu)when the quantity of ponded surface water exceeds the amount that infiltrates at the maximum annual groundwater infiltration rate of 23 in/yr,or 0.063 in/day(Morgan and Jones, 1999;Vaccaro et al. 1998). This rate is also used as the annual rate for surface water infiltration through bioretention gardens designed for high infiltration capacity. Because there is no surface water runoff occurring from the site under current forested conditions,we have assumed that the ponded surface water storage capacity of the undeveloped site is sufficient to store all accumulated surface water until it is either evapotranspired or infiltrated. For the developed resort site(D)conditions,the soil ponding capacity is assumed to be less than that of the current forested conditions due to grading and filling;this is represented in Equation 9 as Surface Storage!). With the decreased soil infiltration capacity from the resort development,a greater amount of water accumulates at the ground surface, exceeding the surface water storage capacity. As a consequence,surface water runoff is generated, and is included in in Equation 9. 00 Groundwater recharge=Rainfall +Surface Storageu —ET 8) A Groundwater recharge=Rainfall+Surface StorageD—ET—Surface Runoff 9) To incorporate the affects of surface water storage(ponding)into our water budget,each of the components of the water balance was calculated on a daily timestep for the entire year using groundwater recharge estimated as the amount of water that infiltrated daily from the available surface water storage(rainfall and ponding)after the ET water demand was subtracted. The maximum infiltration rate was set at 23 in/year for mature forest(Morgan and Jones, 1999;Vaccaro et al., 1998). Water that ponded at the ground surface in excess of the soil infiltration capacity for the daily timesetep was carried over to the next day's timestep calculation. If the amount of surface water storage present exceeded the next day's daily ET uptake,water infiltrated to recharge groundwater for that day. For the current forested conditions,the surface water storage from ponding estimated to be held in bogs,wetlands, or kettles ranged from 0-5 inches in the summer, and from 10 to 35 inches in the winter(illustrated by the blue line; Figure 2). For landscaped grass,the ponding ranges from 0 to 2 inches year round. A significant component of the ET demand for the landscaped grass is assumed to be met by irrigation, which is intensively managed to minimize surface water ponding. Our groundwater recharge estimates are greater than those presented in the EIS for the current forested conditions because we account for the high infiltration capacity of the forest soils(Morgan and Jones, 1999;Vaccaro et al., 1998),as well as the capacity of 10 ponds and wetlands to store and infiltrate surface water.Correspondingly,the impacts to groundwater from the conversion of forest to landscaped grass cover generate a greater groundwater deficit than presented in the EIS,due to the reduction in groundwater recharge associated with the groundwater pumping required to irrigate grass in summer months and the reduction in ponding capacity. an i 35 3p 25 I— 1( c Forest Ponding 15 ,..._. .._ Grass Ponding 10 . i i 5I y o Figure 2. Forest and landscaped grass ponding depths. Figure 3 shows the monthly annual average recharge in units of acre-ft per month comparing recharge under the current conditions of 220 acres of mature forest(Figure 3; blue line),and recharge for the proposed resort development conditions with land use modifications as listed in Table 1 (Figure 3;teal line). With 60 acres of forest remaining untouched, 60 acres of developed golf course,and 37 acres of impervious surface,there is only 46 acres remaining that we assumed would be developed into the bioretention gardens required for the planned management of the stormwater generated from the impervious surfaces. 11 Table 1. Resort land cover areas Acres 60 60 37 17 Land Use Golf Course Mature Forest Impervious surface Lined Pond 46 Bioretention(assumed) 220 Total Proposed Development The maximum available land surface is 46 acres that could be engineered for managing the 146 acre-ft of average annual water that will precipitate on 37 acres of impervious surfaces,based on the planned areas for the resort golf course,forest, impervious surface and lined pond areas(as listed in Table 1). With a 23 inches/year rate infiltration rate,46 acres of bioretention gardens would have the capacity to infiltrate 72 acre feet of water annually(or a maximum of 7.5 acre feet of water per month given 12 inches of pending,and minimum values of 2.5 acre-ft in August and September. 2020 Engineering estimated that rainwater harvesting from the 37 acres of impervious area would generate 132 acre feet of surface water annually(given the 55 inches average annual precipitation recorded at Quilcene). We have estimated 146 acre feet average using 2005-2010 rainfall data. If the entire impervious area runoff of 146 acre-ft was to be directed to bioretention gardens, in addition to 182 acre-ft of rain falling directly on bioretention gardens,there would a total surface water input of 328 acre-ft of water. Of this total surface water input,only 74 acre-ft are used by ET,and 72 acre-ft can recharge given an drained filtration capacity limited by the underlying soils(23 in/yr)and a 12 inch pending capacity. For the 83 acres of impervious surface and bioretention gardens,this leaves a remainder of 182 acre-ft of annual surface runoff occurring primarily between October and March,that is not addressed by the current plans. Figure 3 shows the average monthly rainfall on 37 acres of impervious surfaces(blue line),the bioretention garden recharge capacity assuming 46 acres of bioretention gardens with a maximum capacity of 7.5 acre-ft(green line),and the resulting surface runoff of rainfall in excess of the bioretention recharge capacity(brown line). The annual average surface runoff from impervious surfaces totals 146 acre-ft which will need to be captured and treated to avoid contaminated surface water runoff to Hood Canal. Bioretention capacity,if used in the development,will be limited by the rain falling directly on the gardens. Without 12 filtration and drainage systems,there will be no excess capacity to capture and store runoff from impervious surfaces.. 80 70 : .. 60 50 40 Water Input 30 1 Bioretention recharge 20 9 surface Runoff 10 0 7 8 9 10 11 12 1 2 3 4 5 6 Month Figure 3. The average monthly estimated groundwater recharge of bioretention estimated for managing the rainfall on 37 acres of impervious surfaces for the proposed development land cover. Figure 4 compares the monthly average groundwater recharge for the existing conditions of 220 acres of mature forest with recharge for the developed site mixed land use(as listed in Table 1). For the existing forested site,groundwater recharge ranges between 22 and 35 acre-ft per month,for a total of 351 acre feet per year recharge. For the developed conditions,monthly average recharge rate ranges between 10-25 acre-ft given the mix of land uses, for a total of 230 acre-ft per year. Subtracting 69 acre-ft of commercial and domestic groundwater demand,results in an annual recharge balance of 160 acre-ft. Table 2 lists sources of recharge from the proposed developed mixed land use where 99 acre-ft recharges from the forested land,69 acre-ft from the landscaped area,and 72 acre-feet recharges through the bioretention areas. Comparing the current recharge rate of between 300-350 acre feet/year,with the data-based estimates for developed conditions, 150-200 acre feet/year,shows that the recharge for the developed resort will be 45%of the current recharge. Irrigation water demand is assumed to be taken primarily from lined pond storage. The actual demand is explored in the next section. 13 40 39 Current 30 = Groundwater recharge 1 25 i. E 20 Proposed Recharge 15 i Forest+Golf le Course+ 10 Biwetention) 5 0 1 2 3 4 5 6 7 8 9 10 11 12 month 1 Figure 4. The average monthly estimated groundwater recharge under current forested conditions exceeds the estimated recharge for the proposed development land cover for every month of the year. Table 2.Annual groundwater use estimates and groundwater recharge for the developed resort land cover Groundwater Source or Use Water+ Water -acre-ft) acre-ft) acre-ft) Recharge from forested land 96 cover Recharge from landscaped 64 areas Max recharge from 69 bioretention gardens Commercial &Dom. Pumping 69 Total Recharge 160 Subsurface Group,LLC (2006)interprets the connection between ground water level and precipitation to generate a significant rise in groundwater elevation with precipitation events5. Groundwater elevation increases occurring one to two days after precipitation events leads the authors to the conclusion that off-site water(such as the 5 Page 7 of 19 in EIS. 14 Duckabush River or drainage from the mainland)are the source for the groundwater level increases,as rainwater cannot be expected to infiltrate 100 vertical feet in a 24-48 hour time period. This explanation assumes an unsaturated or dry soil profile, and that all precipitation events could be expected to have the same response. Alternate explanations that merit further evaluation include the presence of perched water tables or saturated soil profiles,with groundwater response based on wet versus dry antecedent conditions. If the water level response is linked to water held at intermediate levels in the soil profile, the effect of land cover change and seasonal changes in water level re sponse would be more extreme than is currently observed. 5.0 Water Use Estimation The difference between surface water availability and water demand can be expected to vary on a year to year basis depending on the annual rainfall. Figure 1 shows the average monthly water demand for forest and grass evapotranspiration which in reality varies from year to year,and throughout the year,as shown in Figure 4. Most rainfall occurs in the winter months(Figure 4;blue line)and the peak ET water demand Figure 4;red line)occurs in the summer months. The timing and the magnitude of the variations in rainfall and evapotranspiration also change from year to year.Figure 4 shows the rainfall and ET variations for the sixty acres of landscaping planned for the developed resort.Using the 2005-2010 Quilcene weather data,the 60 acres of irrigated landscaping would require an amount of water represented by the difference between the rainfall(blue)and the ET(red),when the ET rate exceeds the amount of precipitation received per month(the red line has a higher value than the blue line). If there is insufficient water available to meet the landscaped grass ET demand(the periods when the red line has a higher value than the blue line)the difference is supplied by the irrigation requirement(Figure 4; green line),which is at a peak every year around July. 15 25 20 t 15 10 I Alt 4 4 9 4 4 h h h h c 14111T1 `4411 Rain ---Potential Grass reference ET Irrigation requirement Figure 4.Monthly time series of observed rainfall, calculated ET, and the resulting pumping requirement given four year of observed weather data(2006-2009) To calculate the daily irrigation requirement shown in Figure 4,the precipitation amount and evapotranspiration demand were estimated on a daily timestep. An 85% sprinkler irrigation efficiency was assumed for the 60 irrigated landscaped acres,which resulted in an annual average estimate for irrigated water use of 62 acre-ft(ranging between 44 and 74 acre-ft per year),depending on the weather(rain,temperature,and solar radiation). If 59 acre-ft of reclaimed water(from the 65 acre-ft of commercial and domestic water available from groundwater pumping)is stored in a lined pond,an additional 10-20 acre-ft per year may need to be pumped from groundwater to supply irrigation demand during low precipitation(non-average)years. This is less than the 108 acre-ft annual irrigation estimate by 2020 Engineering for the Golf Course and the FireSmart program6. To estimate the amount of domestic pumping for each month we used the 2020 Engineering(2007)assumptions of 890 units with 32 gal/day water usage per person, with 85%occupancy in the peak season,50%occupancy in the mid season, and 30% occupancy in the low season. The 28 acre-ft annual estimated commercial usage was divided evenly throughout the year. e h is unclear which acres will be treated with the FireSmart program;so this additional demand was not included. They may be irrigating the 60 acres of mature forest,or irrigating the 47 acres of what we are assuming to be the bioretention garden footprint required to capture impervious surface runoff. 16 Figure 5 shows the monthly averages for groundwater recharge and pumping for current and developed land cover(also shown in Figure 3),along with the pumping allocated to supply the irrigation demand,and the cumulative impacts to the groundwater aquifer from the resort development and operation. Monthly pumped amounts(to supply irrigation demand,commercial and domestic consumption)are shown to illustrate the relationship between monthly average estimates of the groundwater pumping requirement Figure 5;red line)and groundwater recharge. The combined impact to the groundwater aquifer from pumping and reduced groundwater recharge due to the changes in the land cover and associated resort landscaping is illustrated by the thicker navy blue line recharge-pumping) . Note that the summer aquifer balance is in deficit given the higher commercial and irrigation demands during those months.Comparing the existing groundwater recharge under current conditions(royal blue line)with the groundwater recharge predicted under the developed site conditions(light blue line)reveals that the combined resort development land cover and water use will generate a significant reduction in groundwater recharge to the aquifer for every month of the year. 40 .Current 35 .* -Groundwater 30 i 4 recharge si25r-- 20 # Proposed Recharge E is i r r p1Ito -- 5 Pumpinftrr& st -1 --2 - 4 9_ TO 1111 12" Comm&Dom. 10 Demand 15 I Reclaimed) 1 month e—Recharge•Pump7ng I I4 Figure 5. The monthly average water budget variables affecting groundwater recharge in the proposed development, compared to the estimated current groundwater recharge. Table 3 lists the average monthly rainfall and corresponding rainfall harvesting from 37 acres of impervious surface, and 17 acres of direct rainfall to the lined pond. 2020 Engineering(2007)estimated 60 acre-ft of water supply from direct rainfall on the pond and our total is slightly higher at 67 acre-ft. The pond storage from direct rainfall 67 acre-ft)plus the 59 acre-ft of reclaimed water makes a total of 126 acre feet or approximately 41 million gallons on average needed for annual storage or treatment 17 capacity. This 41 million gallon storage capacity is based on an annual average rainfall of 47 inches/yr;but a pond designed to capture surface runoff should be sized large enough to retain more than the average rainfall amount each year. For example,in 2006, the annual rainfall was 61 inches. A pond sized at 60 million gallons would be inadequate for capture and storage of the rainfall and reclaimed water for that year,and for other years of higher than average rainfall. Table 3. Monthly average rainfall and the resulting total volumes of impervious surface runoff and direct rainfall inputs to pond. Impervious Surface Pond Rain 37 acres 17 acres Month in/month acre-ft acre-ft 1 7.0 21.5 9.9 2 3.3 10.3 4.7 3 4.1 12.6 5.8 4 3.1 9.6 4.4 5 2.8 8.5 3.9 6 1.7 5.3 2.4 7 0.7 2.3 1.1 8 1.0 3.2 1.5 9 1.1 3.5 1.6 10 3.2 9.8 4.5 11 10.3 31.8 14.6 12 9.1 28.0 12.9 Total/yr 47.5 146.5 67.3 6.0 Comparison of Current and Developed Resort Water Budget To evaluate the changes to the Black Point Peninsula hydrology that may result from the development of the Pleasant Harbor Resort and Marina,we compared the water balance for the existing Black Point Peninsula(mature forest conditions)with the developed and irrigated land cover(proposed for the resort development)using climate data collected at Quilcene,starting from when the solar radiation data was available March 2005-March 2010). The difference between rainfall and ET demand was calculated for current site conditions using a seven day running average where the ET 18 was limited to the available rainfall. The developed site golf course grass water balance estimates include ET calculated for grass and adds groundwater pumping for irrigation required to meet grass water demand; grass potential ET ranges between 0.1 to 4 inches/month. The mature forest water demand(for the remaining 60 forested acres) ranges between a minimum of 1.5 to 2.5 inches/month. Available water remaining after meeting evapotranspiration demands was treated as recharge up to a maximum infiltration rate equivalent to 23 inches/yr(0.063 inches/day). If additional water was remaining after recharge,this water was added to surface storage ponding in the forested condition. The storage that accumulated was the sum of excess surface water accumulation plus the storage available from the previous day. The surface storage ponding was limited to two inches on the 60 acres of golf course grass. Figure 6 shows bow the monthly average rainfall is currently divided between forest transpiration,and groundwater recharge for the 220 acres in the current forested condition. About half of the available water evaporates,while the other half infiltrates and recharges the aquifer. There is a seasonal shift where there is more ET and less recharge in the summer, and more recharge and less ET in the winter. With the current land cover,there is an annual average of 3516 acre-ft of average annual recharge. Figure 7 shows the resulting increase in surface runoff and decrease in recharge with the development land cover condition of 60 acres of mature forest, 103 acres of landscaped grass(golf course plus bioretention), 17 acres of pond,and 37 acres of impervious surface(Table 1). With this land cover,we estimate a total annual average recharge of 1609 acre-ft after commercial and domestic pumping,and supplementary irrigation pumping. r Excess surface accumulation is the sum of water available after meeting ET demands and after infiltrating to the maximum daily infiltration capacity. 8 351 acre-ft is the annual average using data from water years 2006-2009(10/1/2005-9/30/2009). 362 acre-ft is the annual sum of the monthly average using data from 3/23/2005-3/31/2010. 9 160 acre-ft is the annual average using data from water years 2006-2009(10/1/2005-9/30/2009). 172 acre-ft is the annual sum of the monthly average using data from 3/23/2005-3/31/2010. 19 100% 90% 80% 70% Current Forest Demand 60% 50% 40% 30% Current 20% Groundwater recharge 10% 0% 1 2 3 4 5 6 7 8 9 10 11 12 9 month Figure 6., The distribution by month of rainfall used to meet ET demand and recharge groundwater in mature forest conditions. 100% 90% 80% Surface Runoff 70% 60% ' GrassET 50% 40% Forest ET 30% 20% 10% is Estimated Recharge 0% 1 2 3 4 5 6 7 8 9 10 11 12 month Figure 7. The monthly water distribution between the water balance components is shown for the resort development land cover scheme of 60 acres of mature forest, 103 acres of landscaped grass. 17 acres ofpond, and 37 acres of impervious surface. 20 With the developed site land cover,considering impervious surfaces and landscaped grass,there is less surface ponding capacity and increased surface water runoff during the high rainfall winter months. This surface water runoff reduces the annual average recharge as it drains overland from the site instead of infiltrating to recharge the aquifer. We estimate that the surface runoff from landscaped grass is190 acre-ft annually,which will require water treatment for removal of herbicides and fertilizers. The surface runoff from impervious surfaces generated is 146 acre-ft. Surface runoff from impervious surfaces(in excess of bioretention capacity assuming 47 acres of built gardens)and surface runoff from landscaped grass,totals 330 acre-ft per year on average. This surface runoff occurs primarily in the winter months. Depending on storm patterns,the monthly surface runoff may range between 1 acre-ft/month in the summer to 64 acre-ft/month in the winter. The total amount of water requiring management in the development is shown in Table 4. Table 4. Volumes of water requiring surface water management or treatment in the proposed development. acre-ft gallons Landscaped grass surface runoff 155 50,553,247 Surface Runoff from impervious surfaces and direct rain on gardens in 139 45,146,516 excess of capacity Lined pond size requirement to contain direct rain and reclaimed 127 41,289,398 water Total quantity requiring water requiring management 442 136,989,261 21 Table 5 summarizes the water budget for the current conditions of 220 acres of mature forest. The annual average rainfall volume from 2005-1010 was 743 acre-ft; 435 acre-ft was used to meet ET demand,and the remaining water volume recharged the groundwater. Depending on the timing of rainfall throughout the year, the result of using a daily data-based approach show the current aquifer recharge may range between 300- 350 acre-ft per year. Table 5. Water Budget results for current conditions 2006-2010. Acres Land Use Rain ET Recharge 220 Mature Forest 743 435 308 In their resort plans,2020 Engineering(2007)presents a water balance summary in Figure 2-3 Water Cycle concept flow diagram)that calculates an average annual rainfall of 1031 acre feet per year;491 acre feet of which is allocated to groundwater infiltration. An additional 136 of the accumulated surface water runoff,precipitation onto storage ponds and reclaimed water is stored at the ground surface(257 acre feet)in storage ponds. The pond storage capacity described in the 2020 Engineering report is 125 acre feet,leaving approximately 132 acre feet of surface water generated annually beyond the planned storage capacity. Given the water uses listed for the 257 acre feet of surface water storage(golf course irrigation,90 acre feet,fire smart irrigation 18 acre feet;evaporation from the storage reservoir, 13 acre feet;and aquifer recharge, 136 acre feet of excess surface water proposed to recharge groundwater. These values are listed by land use and water source in Table 6a as the EIS water budget. The very low infiltration rates of the till sediments below the proposed Resort site make the actual mechanism for transport of this quantity of surface water into the ground unrealistic. Figure 2-3 of the 2020 Engineering report shows this 136 acre feet as recharging groundwater through a"box"extending from the ground surface to the ground water that is supplied by overflow from the storage reservoir. In addition, the estimate of 491 acre feet of groundwater infiltration for the site,is also unrealistic and beyond the till sediment infiltration capacity. Surface water cannot actually be infiltrated into the ground through a box;the low infiltration capacity of the till sediments(23 inches/yr)mandates that an area of approximately 65 acre feet of ground surface is required for infiltrating this quantity. The current resort configuration does not include land designated for surface infiltration only. Without a realistic means of groundwater infiltration,excess surface water will runoff,with the potential to transmit contaminants to the surrounding surface waters of Hood Canal. The estimate of high quantities of surface runoff are supported by the data-based water budget shown in Table 6b using annual averages of the daily data and calculations described earlier in this report. The annual average recharge by infiltration with the proposed land use(Table 1)would be approximately 229 acre-ft. To give a comparable 22 annual rainfall amount to the EIS,we also show results in Table 6c using the same data- based methods,but for 2006,a year with rainfall similar to the long-term annual rainfall estimate. Using 2006 rainfall,the annual recharge would be approximately 259 acre-ft. In Table 6a,the EIS estimate and development plans,the total surface water input is the sum of 1131 acre-ft of rainfall,90 acre-ft of irrigation for golf course grass, and 18 acre-ft for the Firesmart program;the total is 1249 acre-ft. In Table 6b,the data-based surface water input is the sum of 743 acre-ft of rainfall,59 acre-ft of irrigation water phis 18 acre-ft for the Firesmart program;the total is 820 acre-ft. In Table 6c,the surface water input using 2006 data totals 1068 acre-ft. Although there was higher rainfall in 2006 compared to the average,it fell primarily in the winter. An additional 4 acre-ft would have been required for golf-course irrigation based on summer rainfall amounts and temperatures. Table 6a, 6b, 6c. Water Budget Comparison between estimates presented in this report and in the EIS(Subsurface Science LLC, 2006). The unaccountedfor surplus in both the current and developed site EIS water budgets indicates that unaccountedfor water storage is occurring in the water management scheme. Table 6a. EIS Water budget Ground water Pond Pond Acres Land Use Rain ET Recharge Pumping Pumping Containment Total Source 1131 508 491 65 60 Golf Course(irrigation) 90 90 60 Mature Forest(Firesmart) 18 18 37 impervious surface 132 17 Lined Pond 13 46 8ioretention Total Proposed 220 Development 1239 S21 491 65 108 132 23 Table 6b. Data-based Water budget (this re rt) Ground ET water Pond Pond Acres Land Use Rain (total) Recharge Pumping Pumping Containment Total Source 743 65 60 Golf Course 59 101 64 59 60 Mature Forest 18 119 96 18 37 impervious surface 0 0 146 17 Lined Pond 29 0 46 Bioretention 77 69 Total Proposed 220 Development 820 326 229 65 77 146 Table 6c. Data-based Water budget(this report)for 2006, a water year with comparable rain as the EIS annual rainfall estimate Ground ET water Pond Pond Acres Land Use Rain (total) Recharge Pumping Pumping Containment Total Source 987 65 60 Golf Course 63 104 69 63 60 Mature Forest 18 141 115 18 37 impervious surface 0 0 146 17 Lined Pond 30 0 46 Bioretention 80 74 Total Proposed 220 Development 1068 355 259 65 81 146 The summary results of the water budget using data from Table 6 are shown in Table 7 for annual surface runoff,annual increase to pond storage,total excess water requiring management,and estimated addition to aquifer. Using the EIS and development plan water source and use values,there is 192 acre-ft of annual surface runoff that is not addressed in their plans.This is derived using an unrealistic infiltration rate and unexplained excess recharge into a box discussed earlier in this report. Using data-based values(2005-2010),the annual average surface runoff for the proposed development may be 330 acre-ft or up to 520 acre-ft on a high rainfall year(i.e.2006). 24 All methods and assumptions show that there will be annual increases to pond storage,not a long-term balance. Management of pond overflow is not discussed in development plans. The total excess water requiring management will be 203 acre-ft per year using development plan values,but will likely be in the range of 370-555 acre-ft per year. Irrigation requirements can be met,for the most part,using the volume of water expected to be reclaimed by domestic and commercial use. The rainfall excess expected to generate surface water runoff on the proposed Resort has not been given adequate study or planning. Table 5 and the related discussion show that the current recharge is likely ranges between 300-350 acre-ft per year. The EIS and development plan water source and use values,when looked at with the water budget approach,show that they expect to recharge the aquifer more than current conditions,426 acre-ft after pumping requirements. This demonstrates that the infiltration rates they assume are unreasonable, as they have not proposed any engineering solutions that are expected to increase the overall infiltration and recharge capacity of the 220 acres compared to current conditions. It is more likely,given the 23 in/yr infiltration and recharge capacity Morgan and Jones, 1999;Vaccaro, et al., 1998)and a data-based water budget approach,that the proposed development will reduce the annual recharge to between 160-200 acre-ft per year. This represents more than a 50%decrease in annual recharge. Table 7. Water Budget Comparison between estimates presented in this report and in the EIS(Subsurface Science LLC, 2006). The unaccounted for surplus in both the current and developed site EIS water budgets indicates that unaccounted for water storage is occurring in the water management scheme. Data- based Data- Inputs based EIS 2005- Inputs Water Budget Output Inputs 10 2006 Components from Table 5 Rain-ET-Recharge+ Annual surface runoff 192 330 520 Pumping Annual increase to pond storage 11 41 36 Containment-Pumping-ET Total excess water to manage 203 371 555 Runoff+Pond Overflow Estimated addition to aquifer 426 164 194 Recharge-Pumping 25 7.0 Conclusions The Pleasant Harbor Resort and Golf Course consultant reports(Subsurface Group,LLC,2006; 2020 Engineering, 2007)describe that storm water and sewage effluent from the development will by contained in closed systems. Water demand scenarios divide the 220 acre development into 123 acres of landscaped grass(and assumed bioretention),37 acres of impervious surface,and 60 acres of mature forest Table 1). From the 37 acres of impervious surfaces,water is proposed to be collected and reintroduced to the aquifer,primarily through the use of bioretention or rain gardens. Irrigation demand is proposed to be met primarily by a lined 17 acre pond which will hold direct rainfall and reclaimed water. Evapotranspiration losses from the pond surface are estimated at less than 1 percent of the annual pre-development water budget(3 percent by 2020 Engineering,2007), and recharge is assumed to be maintained over the year. Using daily calculations of water budget variables based on local climate observations(2005-2010),we used a data-based approach to calculate a water budget that accounts for the seasonal distribution of rainfall and associated supply and demands of the current forested land cover and proposed mixed use land cover. By directly calculating the evapotranspiration demands,and limiting the infiltration based on a appropriate soil infiltration capacity rate,we were able to more directly estimate not only the recharge,but the surface runoff. Surface water quality degradation in the waters surrounding Black Point will result from water running off of landscaped surfaces,containing fertilizers and landscaping chemicals,if it is not captured and treated. Of the annual average of surface runoff, 155 acre-ft from landscaped grass that may require treatment for fertilizers and pesticides and 139 acre-ft from impervious surfaces which will also require treatment.This represents water in excess of bioretention garden capacity(assuming highly permeable landscaping is built). A 17 acre lined pond is proposed to be used to contain on-pond rainfall and treated domestic waste water. This lined pond is planned for a storage capacity of 40,000,000 gallons in an average year and upwards of 60,000,000 gallons for higher than average precipitation years to prevent overflow of reclaimed water given maximum annual rainfall conditions. The average annual surface runoff has not been addressed by the proposed development plans. We estimate that a total of 140,000,000 gallons(420 acre-ft)will need to be managed annually. The annual average groundwater recharge is,for the current forested land use, approximately 300-350 acre-ft. The recharge estimated for the proposed development site plan for the Pleasant Harbor Resort and Golf Course is approximately 160-200 acre- ft. This represents 45-50%of the current groundwater recharge compared to current 26 conditions. The development plan estimate of 426 acre-ft is based on unrealistic infiltration and recharge rates. Because the proposed development plans do not adequately account for the seasonal variation of annual rainfall,the resulting seasonal changes in surface runoff and recharge and not adequately addressed. If the drawdown of the local aquifer or discharge of untreated stormwater or wastewater into Hood Canal is unacceptable,then the proposed design fails to meet environmental protection and restoration goals'°.With the continued long-term reduction in aquifer recharge, the groundwater levels can be expected to drop and salt water intrusion to occur in wells located along the Black Point Peninsula shorelines. 10 2020 Engineering,January 31,2007,"Water Resource Management:A Sustainable Water Resource Management Plan",Prepared for Statesman Corporation.Page 5. 27 Use of this report Silver Tip Solutions,LLC.has prepared this memo for Gerald Steele and his agents for use in the understanding of the hydrologic conditions of Black Point Peninsula. The scope of our work does not include services related to construction or design of water engineering systems.The results presented in this report relate to the probability of hydrologic conditions only on the Black Point Peninsula and not any other watershed or system. There are possible variations in hydrologic conditions that may not be represented in this work. Our report,conclusions,and interpretations should not be construed as a warranty of hydrologic conditions. We recommend that Gerald Steel and his agents continue to support the collection of data and consultation services to evaluate whether future conditions differ from those anticipated. Incorporation of updated climate,streamflow, groundwater,and water use data into the water budget and hydrologic modeling system used in this work may result in different results,conclusions and interpretations than are presented in this report. 28 References 2020 Engineering. 2007. "Water Resource Management:A Sustainable Water Resource Management Plan",Prepared for Statesman Corporation.January 31,2007 Allen,R.G.,L.S.Pereira,D.Raes,and M.Smith.1998. "Crop Evapotranspiration: Guidelines for computing crop water requirements."Irrig.and Drain.Paper 56,Food and Agr. Org of the United Nations. Rome.300 pp. Bosveld F.C.,and W.Bouten,(2001),Evaluation of transpiration models with observations over a Douglas-fir forest,Agricultural and Forest Meteorology,108,247-264. Grimstad,P.and R.J.Carson.1981.Geology and Groundwater Resources of Eastern Jefferson County,Water Supply Bulletin No.54,Washington Department of Ecology. 125 pp. Jensen,M.E.,R.D.Burman and R.G.Allen,Editors,1990.Computer Program Supplement to ASCE Manual 70:Evapotranspiration and irrigation water requirements. Morgan,D.S.and J.L.Jones,1999. Numerical Model Analysis of the Effects of Ground-water Withdrawals on Discharge to Streams and Springs in Small Basins typical of the Puget Sound Lowland,Washington. U.S.Geological Survey Water-Supply Paper 2492,73 pp. Olsthoom,A.F.M.,1991.Fine root density and root biomass of two Douglas-fir stands on sandy soils in The Netherlands I.Root biomass in early summer.Neth.J.Agric.Sci.39,49-60. Subsurface Group,U.C.2006.EIS Groundwater(Ver 1.6).doc,Project No.SG0601-02,"Pleasant Harbor Marina and Golf Resort- Water Supply and Groundwater Impact Analysis".June 26,2006 Vaccaro,J.J.,Hansen,A.J.and M.A.Jones,1998. Hydrogeologic Framework of the Puget Sound Aquifer System,Washington and British Columbia,Regional Aquifer-System Analysis— Puget Willamette Lowland. U.S.Geological Survey Professional Paper 1424-D. Walter,I.A.,R.G.Allen,R.Elliot,M.E.Jensen,D.Itenfisu,B.Mecham,T.A.Howell,R.Snyder,P. Brown,S.Echings,T.Spofford,M.Hattendorf,R.H.Cuenca,J.L.Wright,D.Martin.2000. ASCE's Standardized Reference Evapotranspiration Equation.Proceedings of Watershed Management&Operations Management. 29 ya3 o- FY UC BERKELEY CENTER FOR LABOR RESEARCHI ,AND EDUCATION. .:..,, _LABOR CENTER December 2007 RESEARCH , BRIEF A DOWNWARD PUSH : THE IMPACT OF WAL-MART STORES ON RETAIL WAGES AND BENEFITS Arindrajit Dube UC Berkeley Institute for Research on Labor and Employment T. William Lester UC Berkeley Department of City and Regional Planning Barry Eidlin UC Berkeley Department of Sociology EXECUTIVE SUMMARY Empirical evidence suggests that employees at Wal-Mart earn lower average wages and receive less generous benefits than workers employed by many other large retailers.But controversy has persist- ed on the question of Wal-Mart's effect on local pay scales. Our research finds that Wal-Mart store openings lead to the replacement of better paying jobs with jobs that pay less.Wal-Mart's entry also drives wages down for workers in competing industry segments such as grocery stores. Looking at the period between 1992 and 2000,we find that the opening of a single Wal-Mart store in a county lowered average retail wages in that county by between 0.5 and 0.9 percent. In the general merchandise sector,wages fell by 1 percent for each new Wal-Mart.And for grocery store employees, the effect of a single new Wal-Mart was a 1.5 percent reduction in earnings. When Wal-Mart entered a county,the total wage bill declined along with the average wage.Factoring in both the impact on wages and jobs, the total amount of retail earnings in a county fell by 1.5 percent for every new Wal-Mart store.Similar effects appeared at the state level. With an average of 50 Wal-Mart stores per state,the average wages for retail workers were 10 percent lower, and their job-based health coverage rate was 5 percentage points less than they would have been without Wal-Mart's presence. Nationally, the retail wage bill in 2000 was estimated to be $4.5 billion less in nominal terms due to Wal-Mart's presence. The study addressed a number of methodological issues that have plagued previous attempts to assess the effect of Wal-Mart on local labor markets.A less sophisticated statistical model risks con- founding the effects of Wal-Mart openings with unobserved economic factors(positive or negative) that might have drawn the retailer to specific locations. We use the spatial pattern of Wal-Mart's growth(radiating out of Arkansas over time)to identify Wal-Mart store openings that are not driven by local economic conditions.This helps ensure we are measuring the results of store openings,not preexisting conditions. Further,we investi gate(and reject) the possibility that wage declines were an artifact of changes in demographics of the retail workforce.If Wal-Mart jobs bring more minorities,women,young people or workers with lower educational attainment into the retail work force, the wage decline could be accounted for by the lower earning potential of these groups. But controlling for age, gender, ethnicity and education did not change the results.Overall,the results strongly support the hypoth- esis that Wal-Mart entry lowers wages and benefits of retail workers. WAL-MART WAGES Wal-Mart's size and growth over the past two decades, and its contribution to reshaping retailing in America, means that it may be an important force in shaping wages for low-end workers. Existing evidence suggests that Wal-Mart pays lower wages and benefits than other large retailers.In 2005,the company reported an average hourly wage of $9.68 per hour.' An earlier study of pay scales in California found that Wal-Mart employees earned 26 percent less than workers in comparable jobs, defined as retail firms with 1,000 or more workers.2 A national study found a 25 percent earnings gap with retailers overall, and 28 percent with large retailers, though wages did not look significantly different from those paid by other discount stores.3 There are two general problems with comparing Wal-Mart workers' wages with those of other retailers.Wal-Mart started and has its greatest presence in lower-wage and more rural areas,which will account for some part of the wage differential. Second, Wal-Mart makes up a large share of general merchandise workers,giving it a significant impact on the average wage of these workers.Its employees account for 55 percent of all general merchandise workers, and 71 percent of employees who work for large general merchandise companies in the country.To get a valid comparison with other general merchandisers, we adjusted retail wages in the Current Population Survey to match Wal-Mart's location and adjusted for Wal-Mart's contribution to the average general merchandise wage. Wal-Mart Stores,Inc.2005.http://www.walmartfacts,com/associates/default.aspx#a41. 2 Dube,Arindrajit and Ken Jacobs,2004.Hidden Cost of Wal-Mart Jobs:Use of Safety Net Programs by Wal-Mart Workers in California.University of California-Berkeley,Center for Labor Research and Education. 3 Bernhardt, Annette, Anmol Chaddha and Siobhan McGrath, 2005. What Do We Know About Wal-Mart? New York University Brennan Center for Justice. 2 RESEARCH BRIEF A Downward Push: The Impact of Wal-Mart Stores on Retail Wages and Benefits The results still found a sizeable wage gap between Wal-Mart and other general merchandising employers: 17.4 percent.The gap is smaller when compared to all grocery workers(7.5 percent)but larger when compared to large grocers (17.5 percent). In the area of large general merchandise companies,meaning businesses with more than 1,000 employees,Wal-Mart employees earned more than 25 percent less than workers in competing stores.4 RESEARCH METHODS Anecdotal evidence suggests that competitors perceive the need to lower wages and reduce benefits to compete with Wal-Mart. In 2003, as Southern California unions negotiated their contracts with grocery chains,competition with Wal-Mart came up repeatedly as a rationale for lowering wages and cutting benefits.'Although such anecdotal accounts are common and reported often in the media, there is not much in the way of rigorous academic research on this question.We sought to test the hypothesis that Wal-Mart store openings depress local wages and benefits. Our research investigat- ed the effect that a new Wal-Mart store had on the economy of the surrounding county and state by comparing how wages for retail workers, especially grocery and general merchandise employees, changed over time in response to a store opening. Any effort to estimate the impact of individual store openings in a credible way encounters a fundamental methodological obstacle: Wal-Mart does not randomly choose where to expand. In deciding where to open a new store, management may take into account several factors, including the cost of labor. If the company selects areas where wages are already falling in order to minimize competition for employees,the results might artificially indicate that Wal-Mart's arrival in a county caused wages to fall. Alternatively, and more important in reality, Wal-Mart may choose sites with strong economic prospects to take advantage of a healthy consumer market. Such local booms usually lead to an uptick in workers'wages.When Wal-Mart store openings are correlated with local economic booms,the results would mistakenly indicate that Wal-Mart raised wages or had no effect on local wages—even when its entry caused wages to be lower than they would have been. In either case,there is the danger of confusing the factors enticing Wal-Mart to open a particular store with the effects of the store's arrival in the local economy.This problem is what economists call selection bias. In order to resolve this problem, our research began with the fact that Wal-Mart has spread out over time from its initial headquarters. The first Wal-Mart store in 1962 was in Rogers, Arkansas. Since then, new stores have sprung up at increasing distances from the center, like a circular ripple spreading away from a drop of water.The farther a county is from Benton County,Arkansas(ground zero for Wal-Mart),the later it experienced the Wal-Mart growth spurt(see Figure 1 on page 4).This pattern of expansion allowed the company to take full advantage of distribution networks and lower the overall costs of expansion.' 4 Dube, Arindrajit and Steve Wertheim, 2005. Wal-Mart and Job Quality: What Do We Know, and Should We Care? University of California-Berkeley,Center for Labor Research and Education. 5 Goldman,Abigail and Nancy Cleeland, 2003. "An Empire Built on Bargains Remakes the Working World,"Los Angeles Times(November 23,2003).Pearlstein,Steven,2003."Wal-Mart's Hidden Costs,"Washington Post(October 29,2003). 6 Graff, Thomas 0., 1998. "The Locations of Wal-Mart and Kmart Supercenters: Contrasting Corporate Strategies;' The Professional Geographer 50 (1): 46-57. Holmes, Thomas J. 2005. The Diffusion of Wal-Mart and Economics of Density. Unpublished manuscript. Dube, Lester and Eidlin I DECEMBER 2007 3 Figure 1. Wal-Mart store locations 1992, 1996 and 2000 Map 1: Store L©cati s 1992 Number of Wal-Mart stores F 3-6 y. z r j 7-12 40 13-19 Interstates i Map 2: Store Loca6 a ns 1996 C t • , ; 141 r•44: yz 44.. Ra K' • lh .0' Map 3: Store Lacati,ns 2000 f.; f 7 r y, r y' ,y:a` 4 RESEARCH BRIEF A Downward Push: The Impact of Wal-Mart Stores on Retail Wages and Benefits By following the ripple of store openings across the country and over time,we are able to test whether retail wages fell in its wake. Looking at store openings based on both how far the county is from Wal-Mart's"ground zero"and the year in question,our estimates avoid the selection bias that can be a problem for similar studies.We also subject our results to a number of different tests of internal and external validity,which all indicate that our methodology is robust. Our study uses two sources for data on wages: the Quarterly Census of Employment and Wages, employed by the US Bureau of Labor Statistics, which provides county-level information; and the March Supplement to the Current Population Survey,which provides greater detail about wages and benefits,but only at the state level. WAL-MART'S NATIONAL EXPANSION The study focuses on the period 1992-2000, the time period when Wal-Mart expanded outside the South and exploded into major metropolitan areas. During this time,Wal-Mart grew from 1,800 US stores to 2,500, an increase of almost 40 percent. During the 1990s, the corporation expanded from the South to the Midwest, and then to the West and Northeast. By the end of the 1990s, more than half the counties in America had a Wal-Mart in them, and some had many more. In 1992, half the Wal-Mart stores were in rural counties. But during the next eight years, three- quarters of new stores were in metropolitan counties, as Wal-Mart expanded from its rural starting point. WAL-MART OPENINGS PUT DOWNWARD PRESSURE ON COUNTY WAGES When Wal-Mart's timing of expansion is taken into account, we find strong evidence that each new Wal-Mart lowered retail wages (see Table 1). Opening a single Wal-Mart store lowers the average retail wage in the surrounding county between 0.5 and 0.9 percent. In the category of general merchandise,wages fell about 1 percent for each new store,while workers in grocery stores saw aver- age wages decline about 1.5 percent.As we would expect,there was no noticeable effect on wages in other low-paying economic sectors that did not compete with Wal-Mart. Restaurant workers, for example,saw no change in their take-home pay as a result of big box entry into their county. Table 1. County-level effects from the entry of a single Wal-Mart store Average Wage Aggregate Wage BM Retail workers: 0.5-0.9%lower Retail sector: 1.5% lower General merchandise workers 1%lower Grocery employees:1.5%lower Dube, Lester and Eidlin I DECEMBER 2007 5 y°`a a ai ;Several independent factors explain the fall in wages associated with Wal-Mart openings. First is the substitution effect: a new Wal-Mart store replaces better paying jobs with lower-paying ones. Since Wal-Mart workers account for more than half of general merchan- 1 iJ ;; dising employees, mixing lower-paid Wal-Mart jobs in with higher- eefywrvrl rf.w; paid jobs reduces average wages noticeably. A second factor is T11 ra', aI Ott competition: Wal-Mart pushes down wages in compering Mlowersisl'grocery wages by i(businesses.This is most evident for grocery stores,where the effect on wages is purely a result of competitors cutting costs in response1h/it Wal-Mart(see sidebar.) sup rkets per higher higher r Ds of uni jn Some research suggests that Wal-Mart may be responsible for a erage wages ram bus aseLs!small net increase in jobs.8 Our study demonstrates that the opening ecline not just intoresproduces markets was 21 perch co but in a total wage bill o a county, Every new Wal-Mart m a county reduced the combined or aggregate earnings of retail workers by around 1.5 percent.Given that the fall in total wages was 6 in r overall.Wages greater than the decline si average wages, it is highly unlikely that of union rl wp atis workers ate,:there is compensating positive employment growth associated with percent,4ter,#att 1 t a Wal-mart store opening. This is con sistent with research by l axe Newmark et a1.,9 who find that once the timing of store openings is R a .union We f#treFmt tel::taken into account,there is no evidence of job gains. At the national level,our study concludes that in 2000,total earnings for °r erarke sr of'of retail workers nationwide were reduced by $4.5 billion due to 1114144,xr d + advan- Wal-Mart's presence, and these losses were concentrated in metro nationwide union nsmbership, cairrpeti politanareas.1t t3art y e bwwage, non-union employer a Wal-Mart par arty r. WAL-MART OPENINGS REDUCED STATE—LEVEL EARNINGS AND BENEFITS POTENTIAL IMPACT ON sells cgnt FIRMS' COSTS butA r 's a ri as=genar • We also perform astute-level analysis of Wal-Marts impact. By the year 2000,there were 2,500 Wal-Mart stores in the US, an average of tornokiaaa -nu ry 50 per state. Our study finds that each new Wal-Mart lowered the ages f 'fir average hourly wage of retail workers in the surrounding state by include fN two-tenths of a percent (see Table 2). Fifty new Wal-Mart stores Hence, 1 e t line in would mean a 10 percent average wage reduction. 9h t1 wages found to the r t t a e Busker, Emek, 2005. "Job Creation or Destruction: labor Market Effects of A, mong yl t-] Wal-Mart Expansion;'Review ofEconarnics aced Statistics 87(1):174-183. mciu 9 Neumark, David, Junfu Zhan and Stephen Ciccarella, 2005. The Effects ofC9n4mofthe:gr zY Wal-Mart on Local Labor Markets;'NBER Working Paper No. 11782. 1e On average, a single store reduced the retail wage bill by 1 percent in a metro county.In 2000,metro counties had an average of 1.5 Wal-Mart stores,and had a total retail wage bill of$300 billion. This produced an annual reduction in the f went PopulationSurvey,200 nominal wage bill by$4.5 billion. 6 RESEARCH BRIEF ( A Downward Push: The Impact of Wal-Mart Stores on Retail Wages and Benefits Table 2. State-level effects of Wal-Mart openings on retail workers Average Retail Employer-Sponsored Wages Health Insurance Effects of a single store 0.2 percent lower 0.1 percentage point lower opening Effects of 10 store 2 percent lower 1 percentage point lower openings Effects of 50 Wal-Marts the average number 10 percent lower 5 percentage points lower per state) The study was also able to measure the effect of Wal-Mart stores on healthcare benefits using the Current Population Survey.While employees in the retail sector typically do not enjoy good health- care benefits, anecdotal evidence suggests that Wal-Mart employees receive employer-sponsored health insurance at a lower level than workers in competing businesses. Our data indicates Wal-Mart's job-based coverage rate was higher than retailers in general, but lower than large retailers, including large general merchandisers and large grocery stores." Just as Wal-Mart's low wages depressed wages in competing businesses,we found similar effects on the rate of health insurance. The research demonstrates that 10 new Wal-Mart store openings in a state translated to a 1 percentage point reduction in the proportion of retail workers who received health insurance from their employer. EFFECT ON METROPOLITAN COUNTIES Wal-Mart's effect on county wages appeared only in metropolitan statistical areas.The strong decline in earnings that was evident in metropolitan counties did not show up in rural counties.This result is consistent with other research that shows that rural areas are more likely to have low-wage firms.12 Where wages are low to begin with,the arrival of the retail chain is less significant.This is especially true because the minimum wage becomes binding at low wage levels,which is more likely in rural areas.In metro areas with better-paying jobs and a higher rate of unionization,Wal-Mart's entry was more likely to have an impact on the labor market. This is particularly important since the large majority of new Wal-Mart stores are located in metro areas.This also explains the greater resistance to Wal-Mart store locations in metropolitan compared to rural areas,since workers and unions have more to lose in urban settings. Dube and Wertheim,2005. 12 Anderrson,Fredrik,Harry Holzer and Julia Lane,2002."The Interaction of Workers and Firms in the Low-Wage Labor Market,"LEND Working Paper. Dube, Lester and Eidlin I DECEMBER 2007 7 CONTROLLING FOR DEMOGRAPHICS One possible explanation for the apparent reduction in wages is a change in the mix of the workforce. If Wal-Mart hires more minorities, women and young-people than its competitors, then the wage difference could be explained by the lower earnings of these groups,regardless of where they work. A related possibility could be a change in hours of work, skills of workers and fringe benefits. If Wal-Mart hires disproportionately more part-time workers or less skilled workers,for example,then the apparent decline in average wages might not result from a reduction in wages for comparable employees. In order to investigate this possibility,we use the Current Population Survey data(from the Annual Demographic Supplement),which provides details on individual worker characteristics.We look at the impact of Wal-Mart expansion in a state on the average hourly wages for retail workers (as opposed to earnings per worker in our other dataset, the QCEW), and control for the demographics of the workforce,i.e.,gender,age,education and race,as well as the average wage of workers without a college education.13 Controlling for these factors does not change the overall conclusion. Wal-Mart's effects on wages in surrounding areas created lower wages for a set of retail workers,not a change in who was working retail. CONCLUSIONS Until now there have been few studies documenting the effects on compensation from Wal-Mart's entry into a new labor market.The few studies that do address the question focus on a small set of counties in primarily rural states.Because of methodological limitations,none are able to distinguish the effects of Wal-Mart's arrival from the particular conditions that attracted the retailer to open in a given area in the first place. The new research strongly suggests that Wal-Mart entry lowers wages for employees in competing businesses, and the effect can be seen at both the county and state levels. Controlling for demographic or skill mix of the workforce cannot explain the results. Wal-Mart openings depress average and aggregate wages and reduce the proportion of the workforce that is covered by employer-sponsored health insurance. Of course,Wal-Mart's presence is also likely to bring lower prices. Existing research shows big-box stores like Wal-Mart can use their distribution systems and leverage with suppliers to produce substantial savings to consumers."However,to the extent that competing on cost produces negative effects on low-wage workers, this is an important consideration when deciding the "rules of the game"that big-box retailers need to abide by.And since wage and benefit savings are not the main part of the cost advantage for a company like Wal-Mart, it could continue to pass on most of these savings while paying higher wages and benefits. These factors should be taken into account by policy makers in their decision-making on economic development. 13 To be sure,whether or not lower wages bring in more disadvantaged groups does not change the fact that wages are reduced for retail jobs. Our analysis further shows that this cannot"explain"the fall in wages. 14 Hausman, Jerry and Ephraim Leibtag, 2005. "Consumer Benefits from Increased Competition in Shopping Outlets: Measuring the Effect of Wal-Mart,"NB$R Working Paper No.11809. 8 RESEARCH BRIEF I A Downward Push: The Impact of Wal-Mart Stores on Retail Wages and Benefits Dube, Lester and Eidlin I DECEMBER 2007 9 UC Berkeley Center for Labor Research and Education Institute for Research on Labor and Employment The Center for Labor Research and Education (Labor University of California-Berkeley Center) is a public service project of the UC Berkeley 2521 Charming Way Institute for Research on Labor and Employment that links Berkeley,CA 94720-5555 510)642-6432 academic resources with working people. Since 1964, the http://laborcenter.berkeley.edu Labor Center has produced research, trainings and An affiliate of the University of California curricula that deepen understanding of employment Miguel Contreras Labor Program conditions and develop diverse new generations of leaders. Acknowledgments We would like to thank Judith Barrish for support in writing and editing this brief.We also appreciate the helpful comments and reviews we received from Emek Basker, Jared Bernstein, Oeindrila Dube,David Fairris,Michael Hicks,Ken Jacobs,Ethan Kaplan,Alexandre Mas,Suresh Naidu,and seminar participants at LIES (University of Stockholm), University of Uppsala, University of California-Berkeley, University of California- Riverside, Center for American Progress, Economic Policy Institute, American Enterprise Institute, and the Annual Conference of the American Sociological Association. We also wish to thank General Service Foundation, which provided partial funding of this research. The views expressed in this policy briefare those of the authors and do not necessarily represent the Regents of the University of California, UC Berkeley Institute for Research on Labor and Employment, General Service Foundation,or collaborating organizations orfunders. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 23 Exhibit 1 RESPONSE TO COMMENTS FROM BRINNON GROUP (Letter # 8) Comment 1 Thank you for your comments, your comments are acknowledged. The Draft SEIS was issued on November 19, 2014, and public comments were due by January 5, 2015; the comment period was 48 days in total. The public comment period provided for the Draft SEIS was in excess of the 30 day requirements identified in the Jefferson County Code (JCC 18.40.780). Please also refer to the Response to Letter 3 (Port Gamble S’Klallam Tribe), Comment 9 for more discussion on the public comment period. Regarding the wages of employees operating the project – the proposal includes staff housing for up to 208 employees (52 housing units, with up to four employees accommodated per each 2-bedroom housing unit). This on-site housing could accommodate up to 90 percent of employees earning at or below 80 percent of the Brinnon AMI (223 employees). The on-site employee housing would be provided for 30 percent or less of the employee’s income. With these conditions, wages in the surrounding area would not be expected to be substantially affected by the project. Please also refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS for a discussion on tax and other fiscal considerations. The project would be required to pay for any utility upgrades required to serve the site and therefore would not be anticipated to directly cause a raise in utility rates for South Jefferson County. There are two aquifers on the Black Point peninsula: a sand aquifer proposed for use by the Resort water supply wells, and a bedrock aquifer. The water right conditions will not permit pumping from the wells at rates that compromise aquifer quality. As well, as stated in Section 3.2 (Water Quality) of the Draft SEIS, aquifer recharge would be approximately 840 acre-feet per year under Alterative 1 and 804 acre-feet per year under Alternative 2, compared to 759 acre-feet per year under existing conditions; thus resulting in increased recharge to the aquifer compared to existing conditions. Please see Section 3.2 of the Final SEIS for further details. Under Alternative 3, aquifer recharge would be approximately 844 acre-feet per year. Comment 2 Comments regarding deposits and bonding are acknowledged. Jefferson County requires payment of performance bonds for certain right-of-way and infrastructure improvement projects. As well, a site restoration bond would be required of the applicant at certain critical phases of development (such as Golf Course grading). Payment of these bonds would protect the County in the event that the applicant is unable to finish development. The phasing process for construction of the Proposed Actions is proposed by the applicant, and assumed in this SEIS, to be a 10 year process at maximum. The project would be required to obtain additional approvals if construction extended beyond this time limit. Construction impacts and mitigation measures relating to construction worker housing, transportation, earth work and water quality are addressed in Section 3.1, (Earth), Section 3.2 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 24 Exhibit 1 (Water Resources), Section 3.9 (Transportation), and Section 3.11 (Employment and Housing) of the Draft and Final SEIS. It is assumed that Jefferson County’s building permit fees and land use fees would be sufficient to cover the costs incurred by the County to manage the Proposed Actions through the construction phases of development. The MOU’s negotiated and signed between the applicant and public service providers are intended to address potential costs associated with the project and remove or reduce potential costs to the community. Please also refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Comment 3 Section 3.18 (BoCC Conditions) of the Draft SEIS contains a complete list of all BoCC conditions contained in Ordinance 01-0128-08; each condition is outlined and accompanied by a note detailing how the condition has been met, and the overall status of the condition’s implementation. Section 3.18 has been updated in this Final SEIS to reflect any changes that have occurred since publication of the Draft SEIS, please refer to Section 3.18 of the Final SEIS for further details on all the BoCC conditions. Comment 4 As noted in Chapter 2 of the Draft and Final SEIS, redevelopment for maintenance, repair and renovation of the Marina is limited to occur within existing building footprints, under a separate Binding Site Plan permit, which does not require additional environmental review as determined by Jefferson County as SEPA lead agency. Improvement of the Marina is considered a separate project that would proceed independent of the MPR proposal evaluated in this SEIS. Marina area renovations and reconstruction work is ongoing. The marina is not included in the MPR area evaluated in the SEIS. Comment 5 The No Action Alternative in the SEIS is assumed to be the same as that evaluated in the 2007 EIS. However, details on the No Action Alternative have been updated in this Final SEIS. Refer to Chapter 2 and Chapter 3 of this Final SEIS for further information on the No Action Alternative, as well as the summary matrix in Chapter 1. Comment 6 Comments regarding tax revenue are acknowledged. Please refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Comment 7 Appendix N in the Draft SEIS details the number of construction jobs anticipated for each of the four phases of construction as follows:  Phase I – 398 employees  Phase 2 – 289 employees  Phase 3 – 342 employees  Phase 4 – 720 employees Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 25 Exhibit 1 As stated in the Draft and Final SEIS, it is estimated that approximately 342 of the 1,750 total construction jobs (19.5 percent) would earn an average wage of 80 percent or less of the Brinnon area average median income, and 1,408 of the total construction jobs (80.5 percent) would earn an average wage above 80 percent of the average median income. As well, as noted in Section 3.11 (Employment and Housing) of the Draft and Final SEIS, the following mitigation measure identified by the Jefferson County Board of County Commissioners (BoCC) is applicable to the development Alternatives: 63 (e) Statesman shall advertise and give written notice at libraries and post offices in East Jefferson County and recruit locally to fill opportunities for contracting and employment, and will prefer local applicants provided they are qualified, available, and competitive in terms of pricing. Comment 8 Please see the response to Comment 1 of this letter, above. It is not anticipated that employees of the site would generate a demand for services beyond that of a typical resident in the area. Additionally, affordable employee housing would be provided for up to 90 percent of full time employees, and a fee would be paid to assist the acquisition of local housing to the remaining 10 percent of employees of the project. Please refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Comment 9 Comments regarding potential for taxpayer subsidy for public services are acknowledged. As stated in Section 3.18 (Employment and Housing) of the Draft and Final SEIS, a development agreement is required for master planned resorts (MPR) as prescribed under JCC 18.15.126(2), and a preliminary development agreement between the applicant and Jefferson County has been drafted and is included in Appendix S of the Draft and Final SEIS. The development agreement addresses public services including sheriff, fire and emergency medical service, schools, transit and healthcare. As a condition to designating the site as a MPR, the County required the applicant to negotiate Memorandums of Understanding (MOU) to provide needed support for the Brinnon schools, fire district and emergency medical services, sheriff’s office and healthcare services to mitigate for the potential impacts associated with the Pleasant Harbor MPR. It is assumed that during the MOU negotiation process, public service providers were provided with sufficient information to understand the proposal and EIS alternatives, and have included terms in the MOU’s to address any potential concerns as related to additional service demands that would result from the proposed MPR. See Appendix S of the Draft and Final SEIS for the draft MOUs which would be finalized and signed by both parties prior to approval of the development agreement. Please also refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Regarding the role of private security on the site, as detailed in the draft MOU in Appendix R of the Draft SEIS, “The Resort security staff will not act as law enforcement but will be trained and equipped to respond to any likely security or emergency situation on site with the intent to minimize nuisance calls to JCSO and to protect life and property as needed until law enforcement can arrive. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 26 Exhibit 1 It is expected that security staff would be first on scene in the event of a medical emergency, all security staff will be trained to a level of first responder or better.” Comment 10 As indicated in Chapter 4, Key Topics, of this Final SEIS, the costs associated with incremental increased demand on public service providers (including road maintenance) would be balanced by tax revenues and development fees. As noted in Appendix L of the Draft SEIS, transportation of materials and equipment would involve short periods throughout the course of a day to accommodate specific equipment transfer or would occur over several days to handle specific material transport needs. During these limited periods, larger trucks would be utilized but would typically be limited to less than 50 trips on any given day. In total, typical daily vehicle traffic generation related to construction activities are estimated to be up to 300 daily vehicle trips, which is less than 10 percent of the total site buildout under the development alternatives. Best management practices for heavy equipment or material transport would be implemented during construction, including necessary on-site truck wash facilities or oversized load transport routing and operations alternatives. Comment 11 Internet access can be obtained via satellite without any impact to existing internet access systems. Comment 12 Please see the response to Comments 1 and 8 of this letter, above. Please refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. It is anticipated that the majority of jobs to operate the project under Alternatives 1-3 would be seasonal. However, the applicant proposes to develop programs to attract year-round visitors to the site, which could contribute towards retaining staff during off-seasons. Comment 13 Please see the response to Comment 9 of this letter above and refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4. Comment 14 Comment acknowledged. As a condition to designating the site as a MPR, Jefferson County required the applicant to negotiate Memorandums of Understanding with area service providers to provide necessary support, including support for Brinnon schools. Please see the response to Comment 9 of this letter above for additional discussion. The MOU is strictly between the applicant and the School District. Jefferson County only requires a signed MOU prior to approval of the Development Agreement. At this time, there is no estimate on much their arrangement will generate for the School. Please also see Chapter 4, Key Topic Areas, for an overall discussion on revenue and public service costs. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 27 Exhibit 1 Comment 15 The original traffic counts and underlying analytical assumptions were performed and conducted using conservative methods, including conducting traffic counts for use in the analysis during a peak Labor Day weekend in 2006. As recent traffic counts conducted by WSDOT (Annual Traffic Report, 2014, WSDOT) remain between approximately 22 percent and 35 percent below those documented and used along SR 101 in the immediate project vicinity, the traffic level of service analysis and impact evaluation applied in the SEIS analysis remains conservative and appropriate. As the recent traffic counts performed by WSDOT include all regional tolling, tourism, goods, movement travel, and other unique characteristics of the SR 101 corridor, and these remain below SEIS analytical assumptions, no evidence is found to warrant further level of service analysis. Comment 16 An evaluation of construction traffic impacts associated with building the Pleasant Harbor Resort is provided within the Pleasant Harbor SEIS Transportation Impact Study, Second Addendum Supplement to 11/27/07 FEIS, January 30, 2012, TENW, pages 10-12, included in Draft SEIS Appendix L. Regarding the suitability of using on-site soils for structural fill as part of site re-grading, a Geotechnical Investigation (Perrone Consulting, Inc., 2013) and a Soils and Earth Impacts and Mitigation Report (Perrone Consulting, Inc., P.S, 2012) were completed and included in Appendix E to the Draft SEIS. The Soils and Earth Impacts and Mitigation Report states that “nearly all of the excavated material at the site will be suitable for use as compacted structural fill or could be processed on site to produce gravel or sand aggregate needed for concrete, pavement and under-slab base course, and for golf fairways and greens” (page 2). Comment 17 Appendix H of the Draft SEIS (Habitat Management Plan, GeoEngineers, 2012) addresses potential impacts related to construction noise and specific Best Management Practices (BMP) that would be implemented onsite to reduce noise impacts to wildlife and neighbors. As stated in Appendix H, “The use of heavy machinery will be minimized and consolidated as much as possible. An attempt will also be made to organize work requiring heavy machinery into single events. Construction activities will also be limited to normal (8am to 5pm) working hours.” As well, all construction noise would occur in compliance with the Jefferson County Code. Comment 18 The original Transportation Impact Study prepared for the 2007 EIS and the updated Transportation Memorandum (2012) prepared for the Draft SEIS evaluated traffic impacts of full project buildout. See also the response to Comment 15 of this letter, above. Following issuance of the Draft SEIS, an Open House in conjunction with a Planning Commission meeting was held on December 3, 2014 to allow opportunities for public comment and answer questions about the SEIS. Transportation subconsultant (Mike Reed of TENW) was present at the meeting to answer questions regarding transportation. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 28 Exhibit 1 Comment 19 SR 104 and specifically the portion of that section that includes the Hood Canal Bridge is part of the regional highway system and is beyond the scope of study for the SEIS. As this corridor is part of the Highways of Statewide Significance (HSS), which include interstate highways and other principal arterials that are needed to connect major communities in the state, it is exempt under State law from local or State level of service standards. The percentage of traffic from the Pleasant Harbor Project utilizing the area-wide transportation system in proximity to Hood Canal is low and is not anticipated to result in a measurable impact to the health of Hood Canal. Comment 20 Comment acknowledged. Additional wells would be drilled during project development. Though the aquifer test was terminated early, testing was performed for a 24-hour period which is typically considered sufficient, and was sufficient in this case to determine aquifer properties. The test was intensively reviewed by Ecology during the water right application process. Based on the test results and hydrogeology, there is sufficient water for the Resort and Bl ack Point community. All supply wells would be tested prior to system operation. The water right conditions would not permit pumping from the wells at rates that compromise aquifer quality. Comment 21 Comment acknowledged. Implementation of an groundwater monitoring program and mitigation plan, as approved by Department of Ecology, is a condition of the water right. Please see the Response to Letter 3 (Port Gamble S’Klallam Tribe), Comment 4, and Section 3.2 (Water Resources) of the Draft and Final SEIS, for a detailed discussion on groundwater monitoring. Comment 22 The water quality samples were collected from the area of proposed groundwater withdrawal, and indicate that the aquifer contains fresh water. The supply wells are to be located distant from the source of salt water, which is appropriate. Also, please see the Response to Letter 3 (Port Gamble S’Klallam Tribe), Comment 4, for details on groundwater monitoring. Comment 23 The Pleasant Harbor Neighborhood Water Supply Program (February 24, 2010; included in Draft SEIS Appendix F) requires, among other conditions, that a neighboring resident well owner provide conclusive evidence over a "statistically relevant period of time" that chloride levels have increased over chloride levels in the private well prior to the use of groundwater by the Resort. The NWSP does not state a requirement for three years of monitoring neighboring resident private wells. The Jefferson County Health Department does not have jurisdiction over water rights; only the Washington Department of Ecology (Ecology) has this authority. Therefore, the terms and conditions of the Neighborhood Water Supply Program (NWSP) approved by Ecology are in effect. There is no County water system in the Brinnon area to establish standard hook-up and monthly usage rates. The NWSP reviewed and approved by Ecology identifies responsibilities of the Resort and of neighboring private well owners. Neighboring well owners are responsible for Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 29 Exhibit 1 proving whether saltwater intrusion (e.g., an increase in the chloride level) has occurred in their well, subject to criteria defined in the NWSP. The NWSP defines options for how the Resort may mitigate an impact to a neighboring well: 1) set aside recharge areas to mitigate an impact scenario; 2) provide access to the Resort water system for neighboring parcels in the event of a problem with increased chlorides in private wells; or 3) drill a new well for the impact ed neighboring property owner. If access to the Resort water system is provided, it would be the neighboring homeowner's expense to extend a distribution line between the Resort water system and their private residence. As indicated in page 3.2-9 of the Draft SEIS, after completion of the proposed resort, recharge to the aquifer would increase compared to existing condition. This increased aquifer recharge would be anticipated to reduce the potential for saltwater intrusion. Please also refer to Chapter 4, Key Topic Areas, of this Final SEIS for additional discussion on salwater intrusion. Comment 24 Please see the Response Letter 3 (Port Gamble S’Klallam Tribe), Comment 4. Groundwater monitoring is a condition of the water right. The dataloggers will be downloaded and data will be reviewed at least every two to three months. Comment 25 The Neighborhood Water Supply Program (NWSP) approved by Ecology includes aquifer recharge methods and a provision that, if the monitoring program and evidence of increased chlorides in neighboring wells show a probable saltwater intrusion impact on these wells from the Resort's withdrawal of groundwater, the Resort will implement a plan to mitigate or minimize such impact by considering lower pumping rates and/or adding points of withdrawal. As indicated on page 3.2-9 of the Draft SEIS, after completion of the proposed resort, recharge to the aquifer would increase compared to existing conditions. Existing data, testing, and calculations indicate that there is a low potential for the Resort water supply wells to introduce saltwater intrusion. The wells would be operated in a manner so that pumping would not draw down water levels below sea level, consistent with established procedures for reducing the potential for sea water intrusion. Please see Key Topic 4-2, Saltwater Intrusion, in Chapter 4 of this Final SEIS. Comment 26 There are a minimum of two aquifers on the Black Point peninsula: a sand aquifer proposed for use by the Resort water supply wells, and a bedrock aquifer. As presented in the Water Right Report of Examination, these aquifers are essentially isolated from each other. Ecology has performed an evaluation of many of the existing wells in the vicinity; this report is part of the Public Record. The water right conditions will not permit pumping from the wells at rates that compromise aquifer quality. As indicated in page 3.2-9 of the Draft SEIS, after completion of the proposed resort, recharge to the aquifer would increase compared to existing condition. This increased aquifer recharge would be anticipated to reduce the potential for saltwater intrusion. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 30 Exhibit 1 Comment 27 Please see the response to Comment 26 of this letter, above. As noted previously, Jefferson County requires payment of performance bonds for certain right-of-way and infrastructure improvement projects. As well, a site restoration bond would be required of the applicant at certain critical phases of development (such as Golf Course grading). Payment of the se bonds would protect the County in the event that the applicant is unable to finish development. Comment 28 The water right permit was based on the calculations and analyses performed assuming standard usage rates for water consumption. While the Jefferson County Board of County Commissioners required the environmental review process for the Resort to analyze the conservative assumption of a potable consumption rate of 175 gallons per day (gpd) per equivalent residential unit (ERU), it is the intent of the project to demonstrate a lower rate of water consumption (70 gpd/ERU) by means such as using low-flow fixtures (Jefferson County Ordinance 01-0128-08, Condition 63[o]). Please note that wastewater is not proposed to be forced down wells to recharge aquifers. Comment 29 Comment acknowledged. Variable weather patterns were incorporated into the water supply analyses prepared for the Draft SEIS. The Resort site would be graded, as a condition by the Board of Commissioners, to not allow surface water runoff from the golf course to drain directly into Hood Canal. Drought conditions have been anticipated; water storage on the site in the large central lined pond (Kettle B) would reduce demands on the aquifer for irrigation. Irrigation quantities are more than one-half of the permitted water right. Comment 30 Comment acknowledged. The Neighborhood Water Supply Program (NWSP) is a requirement of the Jefferson County Board of County Commissioners, and is a condition of the Water Right Permit by Ecology. It is intended that the NWSP be equally fair to neighboring residents and the applicant, and has been accepted by Ecology as an equitable plan. Comment 31 The fee structure of the private utility district that would operate the Resort water and sewer systems would be established in the Comprehensive Water Plan and General Sewer Plan to be submitted to Ecology and the Washington State Department of Health for review and approval. It would be unusual, and not anticipated, for the entire wastewater treatment plant to have to be replaced at some future time. Rather, the facility would be maintained as needed, and component parts may be replaced or upgraded with new technology over time, as is typical for wastewater treatment plants. Comment 32 Injection wells to "recharge" the local aquifer with reclaimed water from the Resort wastewater treatment facility was included as an element of the 2007 Resort proposal, but has been eliminated from the 2012 proposal (current proposal). Class A effluent that would be generated Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 31 Exhibit 1 by the proposed nutrient removal activated sludge process with clarifiers, granular filtration, and chlorine disinfection, would be reused on the site for golf course and landscape irrigation, and for fire suppression. This Class A effluent would only reach the aquifer after percolating through underlying soils and subsoils in irrigated areas, and/or if effluent were to overtop (during a storm event) the lined area of the large central kettle on the site (Kettle B) where reclaimed water and stormwater storage is proposed. Irrigation with reclaimed water is a common practice in the United States because soil does an effective job of removing many contaminants, especially pathogenic organisms (both bacterial and virus) from highly treated and disinfected effluent. It is acknowledged that limitations have been identified with regard to the capability of existing wastewater treatment technologies to remove household and industrial chemicals such as flame retardants, plasticizers, detergent compounds, pharmaceuticals, personal care products, fragrances, and anti-microbial cleaning agents1 recently identified as Contaminants of Emerging Concern (CEC). There is a common misconception that CECs are chemicals that have only recently been released into the environment. However, most CECs have been present in the environment for as long as they have been in use, but were previously undetected. Advances in analytical chemistry, instrumentation, and hydrology have greatly improved the ability to identify and study CECs in the environment.2 The majority of wastewater treatment processes are designed to remove organic and inorg anic materials, and pathogens, but are not designed to specifically destroy chemicals. CECs leave wastewater treatment plants dissolved or suspended in the effluent or absorbed to biosolids. CECs in effluent typically reach offsite receiving water bodies. However, the proposed Pleasant Harbor Resort Wastewater Reclamation Plant would not discharge to an offsite receiving water, but rather to a large onsite storage pond where the treated effluent would be diluted with stormwater runoff, to be piped to golf course and landscape areas for irrigation, and to the onsite fire suppression water system. Effluent that would percolate to groundwater in irrigated areas would receive additional CEC removal through the soil matrix. Studies have shown that a range of CECs are removed by traveling significant distances through unsaturated, aerobic, and moderately fine-grained soil profile.3 CECs are currently not included in routine monitoring programs for the United States, and may be candidates for future regulation, depending on research on their occurrence in various environmental matrices, toxicity, and public perception. There is currently no EPA-approved detection method for many of the listed CECs. EPA has compiled a searchable database and summarized in a literature review t he results of more than 400 studies of the treatment of CECs.5 The EPA report discusses 16 of more than 200 CECs present in the database, and the average percent removals achieved by full-scale treatment systems that employ six of more than 20 reported tr eatment technologies. This document shows that the activated sludge, granular filtration, and chlorine disinfection processes to be utilized at the Pleasant Harbor Resort Wastewater Reclamation Plant 1 Esposito, K., R. Tsuchiihashi, and B. Stinson. 2007. Contaminants of Emerging Concern: Considerations for Planned Indirect Potable Reuse: Water World. In WESTCAS (undated). 2 Western Coalition of Arid States (WESTCAS). Undated. Contaminants of Emerging Concern. WESTCAS Issue Paper, Research and Technology (draft). 3 Ibid. 5 U.S. Environmental Protection Agency (EPA). August 2010. Treating Contaminants of Emerging Concern ̶ A Literature Review Database. EPA-820-R-10-002. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 32 Exhibit 1 (WRP/WWTP) would each remove between 22% and 100% of the identified CECs. (An overall removal rate for a WWTP utilizing these unit processes has not been estimated.) Comment 33 The Grading and Drainage Engineering Report (Peck & Associates, May 16, 2012) included in Appendix E of the Draft SEIS, and Section 3.2 (Water Resources) of the Draft SEIS, describes proposed stormwater management measures to be implemented during construction and in the operational condition of the Resort for compliance with applicable Federal, State, and County regulations. The applicant would also be required to prepare a design report (called a Stormwater Site Plan) for each phase of Resort development to describe facilities designed and constructed within the project, their location and function. Requirements for the content of these reports are listed in the Stormwater Management Manual for Western Washington (SWMMWW), periodically updated by the Washington Department of Ecology. The Resort would be required to comply with the most current version of the SWMMWW when each Stormwater Site Plan is prepared, ensuring that the methodology for stormwater management would evolve with new technology over time. Comment 34 Stormwater from the Black Point area of the Resort would be discharged to a detention pond (the large kettle feature near the center of the property, Kettle B) where it would mix with the Class A wastewater effluent from the onsite Wastewater Reclamation Plant. The pond would be lined to prevent this water from seeping into the underlying aquifer, unless the pond were to fill to a point where the water would overtop the lining along the sidewalls. The combined Class A effluent and stormwater would be used primarily for irrigation in golf course and landscape areas where infiltration to groundwater would be more diffuse and occur over a less concentrated area. Also see the response to Comment 33 of this letter, above. Best Management Practices (BMPs) to be implemented during development and operation of the Resort golf course are described in the Golf Course Development and Operation Best Management Practices Plan (GeoEngineers, January 6, 2012) included in Appendix F of the Draft SEIS. Comment 35 Construction of the proposal (under either Alternative 1, 2 or 3) would fill the wetland in the bottom of the large kettle feature in the center of the site (Kettle B), and create a wetland in the smaller kettle (Kettle C) to the south (see Figure 2-5 in Chapter 2 of this Final SEIS). Stormwater quality treatment would occur using methods and facilities required by applicable Federal, State and County regulations, as described in the Grading and Drainage Engineering Report (Peck & Associates, May 16, 2012) and included in Appendix E of the Draft SEIS. The Wetland Mitigation Plan (GeoEngineers, Inc., January 26, 2012) prepared for the Resort proposal was provided in Appendix J of the Draft SEIS. Comment 36 The proposal to transport biosolids from the Resort wastewater reclamation plant to a processing facility is described in Draft SEIS Section 3.16 (page 3.16-6). Biosolids processing has been discussed with the City of Shelton. This service would be further defined in the General Sewer Plan to be reviewed and approved by the Washington State Department of Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 33 Exhibit 1 Ecology, and an agreement for the service would be executed following the development approval process. Draft SEIS Section 3.16 also acknowledges the truck trips that would be generated by hauling biosolids offsite for processing (page 3.16-6). As the frequency of the transportation of biosolids is no more than typical waste disposal for residential/resort communities, no separate analysis of truck trips associated with this specific trip type was warranted. Comment 37 All infrastructure improvements to provide power to the project, including engineering studies and designs commissioned by the PUD would be paid for by the applicant, per the Development Agreement. See Appendix S for the Draft Development Agreement. David W. Johnson From: Darlene Schanfald <darlenes @olympus.net> Sent: Monday, January 05, 2015 4:10 PM To: David W. Johnson Cc: Darlene Schanfald Subject:Pleasant Harbor DSEIS/clo Jefferson County DCD PLEASE CONFIRM RECEIPT OF THIS EMAIL. Friends of Miller Peninsula State Park PO Box 2664 Sequim WA 98382 January 5, 2015 Pleasant Harbor DSEIS/c/o Jefferson County DCD 621 Sheridan Street Port Townsend WA 98368 dwiohnson@co.iefferson.wa.us Below are comments regarding the Pleasant Harbor DSEIS prepared by Friends of Miller Peninsula State Park, a 20 year, federally recognized non profit on the North Olympic Peninsula. We know that these are like and similar to other comments being sent, but want to underscore that these are issues of concern to many that need to be addressed. We are disappointed that this DSEIS was released over holidays and the response time could not be extended, especially since years of extensions were given to the developer. POPULATION The population of Brinnon is about 818 and maybe half this number of homes. Expanding the number of living quarters by 890 residential units (Options 1 a 2) will have an enormous impact in the area in many respects, including potable water, storm water, sewage solids and effluents, release of CO2 into the atmosphere and toss of CO2 soil and tree sequestration. ECONOMICS Few of the built units are intended for year round occupancy. ((The majority of this housing (67%) would be for short- term visitors and 33% would be for permanent residents.)) 67%or about 548 units are hoped to be filled, but most likely the largest percentage of PT occupancy will be in the warmer time of the year. The impacts to the area call for showing an economic analysis that this resort is financially viable. We request this be done. Has the resort company factored in the new WA State minimum wage for employees? Where will construction workers (80.5%out of the area) be housed? Feasibility of housing them close to the site? Will all construction works be from WA State? How will their traveling during high tourist season affect normal traffic? Options 1E2 details are described but the No Action, which is to build a few hundred homesites, is not detailed. It seems, then, that this No Action is not being seriously considered. Yet, it is an Option and it should have comparative details so the costs can be seen. You ask for the public to weigh in and the public should have this information to consider. This is an omission and should be corrected. 1 1 2 3 The information should be combined with that of the marina so one grasps an overall picture of the costs and potential impacts of the entire operation. What costs will be put to the area and state citizens? For instance, road repair from additional traffic the resort will bring. Utility costs. Medical facilities. Taxation. This estimation should be made public up front. GLOBAL WARMING Stripping this large area of trees and its natural grasses, soils and wetlands will release immense amount of greenhouse gases into the ambient air. Earth removal will have a large affect on the microbial soil community. A study needs to be done on how this GHG release and resulting changes affect both the harbor life and the surrounding Brinnon community. Appendix M doesn't quantify the GHG releases and effects of the releases, and the mitigations are hardly that! For sequestration to work, even for the replanted trees, the amount will not balance out. It takes years to regain that sequestration, whether replanted trees or new grass. EFFLUENT Class A effluent discharge from the proposed sewerage treatment plant is planned to be stored and recycled. Do not use this to recharge the aquifers. Do not use this for fire protection and irrigation. It will make firefighters ill. There are many studies that determine recycling of wastewater treatment plant (WWTP)effluents are unsafe. There are thousands of chemicals and many pathogens that cannot be tested for, nor their cumulative impacts. It is known that: microbeads from personal products pass through WWTPs into effluent MRSA and other pathogens remain in the sludge and the effluent antibiotic bacteria can be created in the WWTPs triclosan minimizes WWTP treatment effluent contains fire retardants effluent and well as the solids contain thousands of chemicals including chemicals of emerging concern and POPS More reason to not recycle the effluent: http://www.epa.gov/oig/reports/2014/20140929.14-P-0363.pdf More Action Is Needed to Protect Water Resources From Unmonitored Hazardous Chemicals EPA does not have mechanisms to address discharge of hazardous chemicals into water resources. http://www jsonline.com/news/health/common-diabetes-medication-among-drugs-found-in-lake-michigan- bevai7ii2zi-2872R86si.html Common diabetes medication among drugs found in Lake Michigan There is more than one way to measure prescription drug use in modern society. The most direct method is just to count up prescriptions filled by America's pharmacies. That would show, for instance, that more than 180 million prescriptions for diabetes drugs were dispensed in 2013. Or you could test the treated water coming out of sewage facilities such as the South Shore plant in Oak Creek. That approach reveals that in the Lake Michigan waters outside the plant, the diabetes drug metformin was the most common personal care product found by researchers with the School of Freshwater Sciences at the University of Wisconsin-Milwaukee. More importantly, according to their latest research, the levels of metformin were so high that the drug could be disrupting the endocrine systems of fish. Last month, a Journal Sentinel/MedPage Todav investigation found booming sales of diabetes drugs, which in 2013 had grown to more than $23 billion. Metformin is a first-line treatment for type 2 diabetes and is the most commonly prescribed medicine for the condition. In 2013, about 70 million prescriptions were dispensed, according to IMS Health, a drug market research firm. It is so ubiquitous it can easily be found in water samples taken two miles off the shore of Lake Michigan. I was kind of a surprise,"said Rebecca Klaper, a professor of freshwater science at UWM. "It was not even on our radar screen. I said, 'What is this drug?'" 2 4 5 6 7 The drugs get into the sewage and eventually the lake because they are not broken down completely after they are consumed and then excreted. The metformin concentrations are low, compared with the amount taken by people. For instance, coming right out of the treatment plant the levels are about 40 parts per billion. About two miles away, they drop to 120 parts per trillion. Other commonly found substances include caffeine, sulfamethoxazole, an antibiotic, and triclosan, an antibacterial and antifungal found in soap and other consumer products. Klaper co-authored a 2013 science journal paper on the finding as well as another one this year. The more recent research suggests that metformin in lake water is not just a curious artifact of everyday life. The study looked at the effect of metformin on fathead minnows in the tab that were exposed to the drug at levels found in the take for four weeks. It found gene expression suggesting disruption of the endocrine system of male fish, but not females. In essence, the males were producing biochemicals that are associated with female minnows. The biochemicals are precursors to the production of eggs. Klaper said that because the minnows are a stand-in for other fish, the changes also could be affecting other species such as perch, walleye and northern pike. The UWM research confirms what others have found regarding prescription drugs showing up in America's lakes, rivers and streams, said Melissa Lenczewski, an associate professor of geology and environmental geosciences at Northern Illinois University. For years, it was assumed that the volume of water in the Great Lakes was so enormous that any drugs that got through treatment facilities would be diluted to the point that they would not pose a problem, said Lenczewski, who was not a part of the UWM study. That theory itself now is being diluted. Even more concerning are the much higher levels of antibiotics that are being put into rivers and streams near pig farms where the drugs are used to produce larger animals, she said. In addition, strains of antibiotic-resistant bacteria also have been found in water near those farms, she said. It is very alarming how much we are putting drugs out there in the environment,"she said. In that this resort plans to establish a medical clinic for resort members (&workers?)there will be medical wastes in the WWTP, let alone from what goes down the drains from the residential units. TRAFFIC One of the most worrisome issues with this project is traffic. Hwy 101 is a thoroughfare used by those traveling between Clallam County and more southern points to Olympia. Additionally, the traffic 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. Traffic accidents happen. One can imagine that this resort traffic needs will be expensed to the State, hence the citizens. This resort area is an inhospitable site for a large resort. WATER Very worrisome is the availability of water over a long term and the affects on community water needs. If this becomes problematic, what responsibilities will the resort owner be held to? Once it is used, it won't be regained. Water is going to be the "gold" as weather warms and snow levels are minimized and rainwater runoff increases. SUMMARY This comment covers only some of the problems with the planned resort and the DSEIS. Clearly, it is not appropriate to approve this project. Darlene Schanfald, Ph.D. President 3 7 8 9 10 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 35 Exhibit 1 RESPONSE TO COMMENTS FROM FRIENDS OF MILLER PENINSULA STATE PARK (Letter # 9) Comment 1 Thank you for your comments, your comments are acknowledged. Please see the Response to Letter 3 (Port Gamble S’Klallam Tribe), Comment 9. Comment 2 Comment acknowledged. The Draft and Final SEIS identify impacts and mitigation measures for water, stormwater, wastewater, and greenhouse gases in Section 3.2 (Water Resources) Section 3.10 (Air Quality) and Section 3.16 (Utilities). The SEIS does indicate under Significant Unavoidable Adverse Impacts, that development under Alternatives 1, 2 and 3 would change the character of the site from its existing primarily vegetated/forested condition to a new resort development, would result in the filling of wetland area, and would result in the loss of upland habitat. Comment 3 Comment acknowledged. The Washington State Environmental Policy Act (SEPA) regulations do not require evaluation of a proposal’s financial viability. At minimum, the resort would be required to pay the most current Washington State minimum wage to employees. As noted in Section 3.11 (Employment and Housing) of the Draft and Final SEIS, the Applicant proposes to upgrade the existing RV facilities on the site on a temporary basis (presently approved for 60 units) to provide some temporary housing for construction workers. It is assumed that a portion of construction workers would be from Washington State, although the specific mix of in-state versus out-of-state employees cannot be predicted and is somewhat beyond the control of the applicant. However, as noted in the Section 3.11 (Employment and Housing) of the Draft SEIS, one of the BoCC conditions relates to local recruitment and is identified as a mitigation measure for the project:  63 (e) Statesman shall advertise and give written notice at libraries and post offices in East Jefferson County and recruit locally to fill opportunities for contracting and employment, and will prefer local applicants provided they are qualified, available, and competitive in terms of pricing. Section 3.9 (Transportation) of the Draft and Final SEIS outlines construction-related transportation impacts. As stated on page 3.9-9, “typical daily vehicle traffic generation related to construction activities are estimated to be up to 300 daily vehicle trips. This level is less than 10 percent of the total site buildout daily trip generation under the SEIS Alternatives, and therefore, would not represent a significant adverse traffic impact.” Each element of the environment in this Final SEIS has been updated with additional details on the No Action Alternative. Refer to Chapters 2 and 3 of this Final SEIS for further information. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 36 Exhibit 1 Comment 4 Please see the Response to Letter 8 (Brinnon Group), Comment 4. Comment 5 Please refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4, and the Response to Letter 8 (Brinnon Group), Comment 9. Comment 6 Section 3.10 (Air Quality) and Appendix M of the Draft SEIS include a quantitative and qualitative evaluation of GHG emissions that could result from the project. Construction sources of GHG emissions identified and inventoried include mobile power generator combustion, and land use changes from deforestation, below grade carbon loss and soil organic carbon loss. Biosequestration is one of many mitigation strategies identified for reducing GHG emissions, and Appendix M acknowledges that “marginal carbon stores will continue to sequester until equilibrium is reached after 20 years”. As noted in the Final SEIS, “Certain characteristics of the project as proposed under either Alternative 1, 2 or 3 would help to reduce GHG emissions including: the use of grid electricity; preservation of riparian and buffer areas; transplanting usable trees; selective reforestation; offsite trip reduction from a mixed-use contained resort with staff housing, onsite amenities, buses, and onsite electric transportation; energy star appliances; low flow plumbing fixtures; provision of an onsite camp for construction workers; onsite catering and rideshares; recycling; composting and organic waste diversion; best construction practices; LEED construction standards; dark sky exterior lighting; and implementation of the Golf Course Best Management Practices Plan. See Section 3.10 of the Final SEIS for further details. In addition, Alternative 3, which has been added for analysis in the Final SEIS in response to comments on the Draft SEIS and other factors, increases the amount of natural area preserved on the site as compared to Alternatives 1 and 2. Comment 7 The project as designed under Alternatives 1, 2 and 3 would not recharge aquifers, which is a term that indicates the effluent is discharged directly to the aquifer. Effluent would be stored and irrigated on the golf course for growth of grass and as a fire suppressant for native plants. Wastewater reuse is common throughout the U.S. for golf course irrigation and for fire fighting. For example, a new golf course in the State of California cannot be built unless all irrigation is provided entirely from reclaimed wastewater. No effluent would reach the aquifer unless it percolates through the underlying soils and subsoil. Soil does a very effective job of removing all remaining "contaminants", and is especially effective removing pathogenic organisms (both bacterial and virus) from highly treated and disinfected effluent. Regarding the statement that fire fighters could become ill, the reuse or reclaimed wastewater would be treated to meet the same requirements as drinking water, including zero total coliform bacteria [note: coliform bacteria are not pathogenic (i.e. will cause illness in humans) but are an indicator organism (i.e. an indication that a possibility of other bacteria could be present)]. Coliform bacteria are abundant in soils and the environment. If one coliform bacteria is present, Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 37 Exhibit 1 the effluent would not meet Class A Reclaimed Water requirements and would be diverted from the Storage Lagoon to a drainfield designed for this purpose as backup system until the cause is repaired. With reference to the chemicals, etc. cited in this comment, it is important to note that the wastewater (i.e. sewage) from the project would only be associated with employees, residents, restaurants and visitors of the resort and with what is flushed down the sewers. Cleaning products would be carefully controlled by the resort. Comment 8 Natural occurrences or weather events that impact traffic are not considered typical, frequent, or predictable events, and therefore, do not require consideration under SEPA review for traffic impacts. Comment 9 Please see the Response to Letter 3 (Port Gamble S’Klallam Tribe) Comment 4, and Response to Letter 8 (Brinnon Group), Comment 26. As identified in the Draft SEIS, a substantial amount of aquifer monitoring would be required as an element of the project. Drought conditions have been incorporated into the water supply plan as discussed in the Response to Letter 8 (Brinnon Group), Comment 29. Comment 10 Thank you, your comment is acknowledged. a . HOOD CANAL ENVI '-`- MENTAL COUNCIL Amer, a'a jwglle Heritage P. O. BOX 87 1 S' BECK, WASHINGTON 98380 ilECEINEODecember30, 2014 JAN - 5 2015 David Johnson,Associate Planner fill I` Jefferson County Department of Community Development JE FCSOAd COUNTY621SheridanStreetI1%F7 OF CO"fivtr!TYGEVEIppmm Port Townsend, Washington 98368 Re: Pleasant Harbor Master Planned Resort Draft Supplemental Environmental Impact Statement Attention: Mr.Johnson: The Hood Canal Environmental Council (HCEC) has been involved in the decision-making process regarding the proposed Pleasant Harbor Master Planned Resort(MPR) project since early 2006- submitting written and oral testimony to the Jefferson County Department of Community Development DCD) at every opportunity. As the process has dragged on for the last eight years we have remained consistent in our opposition to the proposed MPR and our support for the local citizen organization,the Brinnon Group, whose members would be the most directly affected by the construction and operation of the proposed project. Our position has not changed. The following comments are based on a review of the Draft Supplement Environmental Impact Statement(DSEIS)for the proposed MPR. We respectfully request that they be entered into the public record. GENERAL COMMENTS Environmental Impacts 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 public's perception of the unique and environmentally sensitive character of this watershed is evident in the State's designation of Shorelines of Statewide Significance for all of the shorelines of Hood Canal and numerous projects and programs aimed at protecting water quality and related natural resources. Unfortunately, over the 45 years since the creation of the HCEC,we have seen a gradual "piecemeal"chipping 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 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. Page 1 1 2 3 l (C 7 Lam--. iiw 77 Al JAN L] L. ' DSEIS Alternatives T The DSEIS describes in detail the so-called environmental and other beneficial impacts of alternative1 ' "__ and 2. However,there is very little discussion of impacts under alternative 3 other than to repeat over and over that"the site will continue to develop as a single family residential area based on the existing rural zoning and as described in the 2007 Final EIS". With very few exceptions,the document fails to demonstrate benefits to the environment of the No-Action Alternative with an estimated 30 new residents(pg. 1-11,Volume 1, DSEIS)when compared to the others. Our letter dated 10-14-07 to the Jefferson County DCD commenting on the 2007 Draft EIS for the County's Comprehensive Plan Amendment/Pleasant Harbor Golf Resort details the many benefits of that document's No-Action Alternative. These include significantly lower density,fewer intensive uses, minimal topographic alteration, least demand on groundwater and protection of the aquifer from saltwater intrusion, least traffic impacts,least potential for contamination of marine resources, least impervious surfaces, significantly lower demand for services,increased probability for maintaining the rural character of the Brinnon community, retention of more open spaces, least disturbance of wetlands,and better protection of wildlife habitat. Benefits of Alternative 3 Much is made throughout the DSEIS of so-called"improvements"to water and other resources from upgrades, e.g.sewer,stormwater plan,etc. if the proposed MPR project is constructed (pg.3.2-7 Volume 1, DSEIS). However,there is no mention of the fact that most of these purported improvements could result in the same or higher levels of resource protection when the various regulatory and other tools currently available are utilized and enforced. Existing buffer,setback and lot design regulations, county health department sewage 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 intensive development resulting from another mega resort in the Hood Canal watershed is ludicrous. Adding language describing the benefits to the environment of Alternative 3 throughout the document would go a long way toward demonstrating non-biased comparisons of the three alternatives. SPECIFIC COMMENTS The DSEIS presents a clearer picture of the preferred alternative and offers some improvements from the original plan,e.g.moving the Maritime Village away from the Pleasant Harbor shoreline and consolidating some housing units to allow for more pervious surfaces. However, it still presents unacceptable impacts to the Pleasant Harbor/Black Point area. Environmental Review 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 difficult to get a clear picture of the impacts of the project as a whole. We support the Brinnon Group's position that this area should be subject to a full environmental review under the State's EIS process. Proiect Construction Phases The proposed project is planned to be constructed in three phases over a 10 year period. Page 2 4 5 6 7 8 1 -1_ 1 t r"--'113..._ 1 - n I; t AN _ T I I However,there is no guarantee that this plan will be followed. According to the DSEIS(pg.2.3- 5,Volume 1)the schedule may change depending on market conditions. There are other circumstances that could result in delaying construction,e.g.the developer's financial situation, contract and/or labor problems or any number of unexpected issues. Unfortunately,the construction phase poses the biggest threat to natural resources,including groundwater,which will undergo the greatest demand at that time(Subsurface Group Memo dated 2-22-10). The issue of noise pollution may apply here,since activities like rock crushing,are extremely loud. Impact Cost Deposit and Performance Bond Requirement If the preferred"no build" alternative is not selected,any approval of such a potentially harmful project in this fragile environment should be conditioned upon a complete analysis of the ascertainable and potential economic impact of the proposed MPR during and after construction. Before construction begins,the developer should be required to(1)deposit the amount of all ascertainable direct and indirect costs regarding services and infrastructure into a fund available to local government to cover the costs as they are incurred, and(2)furnish a performance bond issued by a highly rated insurer to cover all potential costs that cannot be ascertained beforehand, including repairing any environmental damage incurred over a 50 year period because of the development and the costs of cleanup and restoration if the project is started but abandoned. In this way,the responsible government is attempting to assure no net economic loss to the community,although the HCEC asserts that the"no build"alternative is superior because this proposed MPR lacks assurance of no net environmental loss. Threats to Groundwater and Aquifer There is only one aquifer which would serve the entire project area, including local residents. The developer plans to use an elaborate system of water management in an effort to protect the water supply. According to State Department of Ecology(DOE)documents,aquifer recharge primarily comes from direct infiltration of precipitation (pg. 3. 2- 2,Volume 1). However,there is no plan for preventing drawdowns in the event of prolonged dry periods which, if scientific predictions of extreme weather events due to climate change(changes in the timing and intensity of rainfall) prove accurate,groundwater and the aquifer could be at risk. The developer's plan to inject treated wastewater into wells poses the possibility of the introduction of pharmaceuticals and other pollutants into the aquifer. The greatest danger to the Black Point aquifer is the threat of saltwater intrusion. Due to its sensitivity to saltwater intrusion,this area is designated as a Critical Aquifer Recharge Area and also an SIPZ(Seawater Intrusion 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 resort's water demands are responsible for the intrusion lies squarely on their shoulders. The Application reads, in part, "The well owner provides conclusive evidence that, over a statistically relevant period of time, chloride levels have increased 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 from the construction of the well owner's well .. ." (emphasis added). The developer also can request additional evidence from the resident showing that the resort groundwater withdrawal is the cause of the increase in chlorides. . . ". Placing the burden of proof on well owners Page 3 8 cont. 9 10 11 pIII t, 11 IJ saddles them with a long and expensive process. We believe that the developer not only is ti „ f ',,T responsible for supplying water to the resident in the event of saltwater intrusion, but-shoe dbe-- -- responsible for the costs involved in the determination of culpability. A DOE Hydrologic(Revised) Memo from John 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 Wells,the statement is made that". . . nearby domestic wells are at risk of seawater intrusion due to their proximity 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. If any wells have been decommissioned due to saltwater intrusion,that information must be contained in the DSEIS. The DSEIS needs to clearly establish the developer's responsibility for proving that there is enough water supply for both the resort and neighboring residents. This includes using updated well data and a monthly monitoring program at the developer's expense. Field sampling is preferable to relying on computer models. The Neighborhood Water Policy should be revised to assign the burden of proof to the developer. Wetland Mitigation 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 III due to its habitat value and moderate to high value for water quality functions(pg.3. 7-2,Volume 1)to a control pond for holding treated wastewater from the wastewater treatment system to provide recycled water for reuse and for golf course irrigation and fire protection. To offset the conversion,the DSEIS states that Kettle C may be"enhanced". Since the wetland mitigation plan has not been done, it is impossible to know how the loss of the Kettle B wetland will be compensated. We feel strongly that in order to meet the state's no-net-loss of wetlands policy, Kettle B and associated wetlands should be kept in their natural state. The DSEIS should also state that the proposed MPR project should not be allowed to encroach on wetland buffers. Golf Course We failed to find a listing of chemicals(herbicides, pesticides,or fertilizers)that will be used for golf course grass maintenance or any discussion of how the developer plans to protect groundwater or stormwater runoff from the use of these chemicals. The BMPs(Best Management Plans)for golf course maintenance needs to be explained in detail. Also,the recommendations relating to golf courses contained in the WRIA 16 Watershed Management Plan should be noted and a plan for 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 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 11 cont. 12 13 14 15 16 IL1, r ICJOTHERISSUESOFCONCERNH While the HCEC's primary area of interest is potential environmental impacts,there are_Whet'ItSUes'r ti T—.! concern to the HCEC relating to the proposed MPR project. Economic Impacts on Local Community 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 operational jobs that could be created, (pg. 1-11 and 1-12,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. It is difficult to say who will benefit economically other than the Brinnon business community,the Canadian based developer,and possibly real estate developers. A study of 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 required to make (Fiscal and Economic Impacts of Destination Resorts in Oregon by Central Oregon Land Watch—March, 2009). Traffic Impacts to Highway 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. Increased 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. In addition, during the construction phase,the increase in trucks and other heavy equipment on Highway 101 would likely lead to costly damages. Further,the question of who will pay for the additional highway repairs and the extension of Jefferson County's transit service needs to be addressed. Jefferson County Resources The HCEC remains concerned about whether Jefferson County has sufficient staff and other resources that would be required to handle the additional workload of monitoring the proposed project for compliance and/or dealing with unexpected problems. Additional Costs to Mason County P.U.D. 1 It is not clear whether the Mason County P.U.D.#1 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. It would be helpful to know how much of a future P.U.D. rate increase can be attributed to the increased energy demand from the proposed MPR. Page 5 17 18 19 20 21 22 Naval Base Security 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 security issue. Miscellanous Pages 1-6 and 3.4-1 in Volume 1 refer to"Rainier"elk populations. The proper name is Roosevelt elk. The HCEC appreciates the opportunity to express our concerns and provide comments on the DSEIS for the proposed Pleasant Harbor Master Planned Resort. We look forward to continuing our involvement and receiving further information as part of Jefferson County's public review process. Respectfully submitted, n .:_ Donna M.Simmons, President JAN - F 2')1Fit Hood Canal Environmental Council J Page 6 23 24 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 39 Exhibit 1 RESPONSE TO COMMENTS FROM HOOD CANAL ENVIRONMENTAL COUNCIL (Letter # 10) Comment 1 Thank you for your comments. Your comments are acknowledged. Comment 2 Impacts to the Hood Canal watershed are evaluated in Section 3.2, (Water Resources) of the Draft and Final SEIS. As noted in the Draft SEIS, on page 3.2-13: “For the Pleasant Harbor project, Jefferson County has required a more stringent restriction than the state by mandating in BoCC Condition 63(q) that no runoff from the golf course is to enter Hood Canal regardless of the size or frequency of the runoff event. This requirement would restrict direct runoff to Hood Canal specifically from the golf course fairways within the Master Planned Resort. Runoff from areas other than the fairways that discharge to adjoining properties would be permitted to leave the site following flow control and treatment that complies with State requirements.” Refer to Section 3.2, (Water Resources) of the Final SEIS for further details. The Draft SEIS does indicate under Significant Unavoidable Adverse Impacts that development under Alternatives 1 and 2 would change the character of the site from a forested/vegetated condition to a new resort development, would result in the filling of wetland area, and would result in the loss of upland habitat. In addition, Alternative 3, which has been added for analysis in the Final SEIS in response to comments on the Draft SEIS and other factors, increases the amount of natural area preserved on the site compared to Alternatives 1 and 2. Also, please see the Response to Letter 3 (Port Gamble S’Klallam Tribe), Comment 3, for information about Alternative 3, which has been added for analysis in this Final SEIS. Comment 3 Preference for the No Action Alternative is acknowledged. Comment 4 Each element of the environment in this Final SEIS has been updated with additional details on the No Action Alternative. Refer to Chapters 2 and 3 for further information. Comment 5 Comment acknowledged. As indicated in Section 3.4 (Fish and Wildlife) under the No Action Scenario B, the potential for impacts to fish and wildlife under the No Action Alternative could be less than under Alternatives 1, 2 and 3. Improvements over existing conditions that would result from Resort development would largely be attributable to compliance with applicable Federal, State and County regulations as included in the mitigation measures sections for elements of the environment evaluated in Draft SEIS Chapter 3. It is acknowledged that compliance with applicable regulations would be required for any new development on the site. Also see the Response to Letter 3 (Port Gamble S’Klallam Tribe), Comment 7, above. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 40 Exhibit 1 Comment 6 Comment is acknowledged. Comment 7 Comment acknowledged. Please refer to the Response to Letter 8 (Brinnon Group), Comment 4 for a discussion on the Marina Binding Site Plan. Comment 8 As stated in Chapter 2 of the Draft and Final SEIS, the applicant proposes to complete the project in four phases over the course of approximately 10 years, or in response to market demand (not three phases as stated in this letter). Jefferson County requires payment of performance bonds for certain right-of-way and infrastructure improvement projects. As well, a site restoration bond would be required of the applicant at certain critical phases of development (such as Golf Course grading). Payment of these bonds would protect the County in the event that the applicant is unable to finish development. Regarding potential construction noise impacts, please refer to the Response to Letter 8 (Brinnon Group), Comment 17. Comment 9 Please refer to the Response to Letter 8 (Brinnon Group), Comment 2 and response to Comment 8 of this letter, above, for discussion on Jefferson County performance bond requirements. Comment 10 SEIS Alternatives 1, 2 and 3 do not propose injecting wastewater into groundwater wells to recharge the aquifer. See the Response to Letter 8 (Brinnon Group), Comment 32 above, regarding contaminants of emerging concern (CECs) in wastewater treatment plant effluent. Please also see the Responses to Letter 8 (Brinnon Group), Comments 22 through 29 for additional discussion on aquifer drawdown and contamination issues. Comment 11 See the Response to Letter 8 (Brinnon Group), Comment 23, regarding provisions in the Neighborhood Water Supply Program in the event of saltwater intrusion into neighboring resident wells adjacent to the Resort. Please also see Key Topic 4-2, Saltwater Intrusion, in Chapter 4. An intent of the applicants proposed stormwater and irrigation system design to minimize the potential for undue burden on neighboring homeowners; the Resort cannot replace a domestic well where the evidence points to a lack of impact to the well caused by the Resort without some other indication that the Resort is responsible for the impact. The Neighborhood Water Supply Program, reviewed and Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 41 Exhibit 1 approved by the Department of Ecology, identifies responsibilities to monitor and mitigate for saltwater intrusion at area wells. Comment 12 The two domestic wells that were found to have sea water intrusion were evaluated by the Washington Department of Ecology in their Report of Examination for the Pleasant Harbor Water Right (G2-30436). [see page 14 of the Groundwater Right Application in Appendix F]. The sea water intrusion was characterized as ‘local upconing’, which occurs when a well is over-pumped and draws deep underlying sea water into the well. Ecology further stated that “it is assumed that both of these wells were originally drilled at a depth within or close proximity of the saltwater wedge and high chlorides have forced these wells to be unusable”. The wells were essentially too proximate to the sea water, too deep, and/or over pumped. These are examples of improper installation and well use proximate to a salt water boundary. Ecology understood this in review of Pleasant Harbor’s water right application, understood that Pleasant Harbor’s wells are and will not be completed with poor construction, and mandated water quality sampling during operation of the wells. It was under this understanding and these requirements that the groundwater right was permitted. Furthermore, any well that is completed proximate to a salt water body has the potential for sea water intrusion if not completed and operated properly; however, the aquifer analyses and Ecology’s analyses have demonstrated that the proposed well locations and water use restrictions mandated by the water right pose little risk to the Resort and community’s wells to sea water intrusion. No further information is available to date regarding recent wells that have been decommissioned due to salt water intrusion. Comment 13 The Department of Ecology is responsible for managing the State’s water resources. Ecology intensively reviewed the applicant’s proposal and hired an independent consultant to perform an independent analyses. The independent analysis, and the analysis prepared for this SEIS, document that the existing aquifer is sufficient to serve the proposal and significant impacts to the aquifer are not anticipated with implementation of prosed and identified mitigation measures. Also see the Response to Letter 3 (Port Gamble S'Klallam Tribe), Comment 4, above. The monitoring program is a condition of the water right and includes field sampling for water quality and regular measurements of groundwater levels that will be performed at the Resort’s expense. It is not possible to place the burden of proof of sea water contamination of a residential well. This would require constant monitoring of every residential well’s water levels, water quality, and discharge rates, and constant access to all of the community’s properties, which is not considered reasonable. Comment 14 A wetland and buffer mitigation plan has been prepared for the proposed project, and was included in Appendix J of the Draft SEIS. A wetland will be created within Kettle C to compensate for impacts to Wetland B. Please see the mitigation plan for more information. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 42 Exhibit 1 Comment 15 The chemicals used on the site will be determined by the maintenance group and will be chosen based on performance of the chemicals and health and safety. The plan adheres to the recommendations within the watershed management plan as water conservation strategies (i.e., water collection over the entire golf course property and using the kettle and Wetland B to contain water runoff that will be used for such things as irrigation for the golf course). The BMPs for the proposed golf course are explained within the draft Golf Course Development and Operation Best Management Practices Plan (SEIS Appendix F). Comment 16 Comment acknowledged. In regards to land use, a golf course is typically considered open space as compared to other types of uses such as residential, hotel, parking and roadways. Open Space as defined under the Jefferson County Code is, ““Open space” means lands committed to farming and forestry uses and any parcel, lot, or area of land or water essentially unimproved and set aside, dedicated, designated, or reserved for public or private use or enjoyment.” However, as indicated in Chapter 2 and Section 3.3 (Plants) of the Final SEIS, the proposed development would disturb existing plant communities, with approximately 73 percent of the site disturbed under Alternative 1 and 53 percent of the site disturbed under Alternative 2. As well, based on comments received on the Draft SEIS and other factors, an additional alternative has been included in the Final SEIS (Alternative 3), which further reduces the size of the golf course and retains more natural area. Under Alternative 3, the revised golf course would reduce the amount of the site disturbed to approximately 43 percent. Section 3.4 (Fish and Wildlife) indicates that development of the site would result in the loss of some existing . Comment 17 As indicated in the Draft and Final SEIS, Section 3.11 (Employment and Housing), the majority of the operational jobs would be below 80 percent of the Area Median Income (AMI), and that construction could employ up to approximately 1,750 workers in total, although the actual number of construction jobs at any given time would vary depending on the nature and construction phase of the project. Please also refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4. With regard to the question of who will benefit economically, this is not a consideration required for analysis under the SEPA regulations. As stated in WAC 197-11-448 (3) Examples of information that are not required to be discussed in an EIS are: Methods of financing proposals, economic competition, profits and personal income and wages, and social policy analysis (such as fiscal and welfare policies and nonconstruction aspects of education and communications). Comment 18 The comment regarding the study on the economic impact associated with destination resorts in Oregon is acknowledged. Please refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 43 Exhibit 1 Comment 19 Comment acknowledged. The transportation impact analysis prepared for the Draft SEIS analyzes vehicle trips under both shuttle and non-shuttle scenarios, and therefore, the impact of vehicle trips between the site and the airport are considered. Refer to Section 3.9 (Transportation) of the Final SEIS for details. Comment 20 Because the highways beyond the study limits of this project are part of the Highways of Statewide Significance (HSS) system, they are exempt under State law from local or State level of service standards and therefore, require no evaluation. The project proposes to provide a common transfer location between Jefferson County and Mason Transit systems. As both service providers currently serve the Brinnon community, no additional transit impacts would be anticipated to result to service providers. See also the Response to Letter 8 (Brinnon Group), Comments 15 and 19, for additional discussion on traffic and Hood Canal. Comment 21 Comment acknowledged. Similar to other development projects in Jefferson County, it is assumed that Jefferson County’s fee and permit schedule is sufficient to accommodate the workload of monitoring the proposed project for compliance and handling issues as they emerge. Please also refer to Key Topic Areas, Fiscal Considerations, in Chapter 4 of this Final SEIS. Comment 22 Comment acknowledged. Draft SEIS Section 3.8 (Energy and Natural Resources, pages 3.8-1 and 3.8-2), and Draft SEIS Appendix K, indicate that the Mason County PUD has capability to serve Phase 1 of proposed Resort development. The Draft SEIS also indicates that "Additional improvements will be necessary to serve the full buildout of the project." Section 3.8, mitigation measures for Energy and Natural Resources (page 3.8-4) reports the Board of County Commissioners condition with which the Resort must comply: 63 (bb) Verification of the ability to provide adequate electrical power shall be obtained from the Mason County Public Utility District. As indicated in Section 3.18 (BoCC Condtions) of the Draft SEIS, the applicant in conjunction with Mason County PUD will complete the report on the capacity of infrastructure to serve the energy demands of the project prior to approval of the Development Agreement. Please also refer to Key Topic, Fiscal Considerations, in Chapter 4 of this Final SEIS. Comment 23 The Bangor US Naval Submarine Base and the US Naval Base Indian Island were provided with notification of availability of the Draft SEIS (see Draft SEIS Appendix A, Distribution List); no comments from the Navy regarding security issues were provided during the Draft EIS comment period. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 44 Exhibit 1 Comment 24 Comment acknowledged. The proper name is Roosevelt Elk, named after Theodore Roosevelt, not Franklin. Jv vw 3407 Eddy Street I Port Townsend,Washington 983 8 -- i ,'T r , Northwest voice 360.385.6786 fax 360.385.2839 1' Watershed Institute email peter @nwwatershed.org i www.nwwatershed.org January 5, 2015 as 0 5 N. David Johnson, Planner ea4 Jefferson County 4„:` lit by email to dwohnson @co.jefferson.wa.us] JEFFER ' RE NWI comments on DSEIS for proposed Pleasant Harbor Marina and Golf Resort development Dear Mr. Johnson, Please add the attached letter from Dr. Richard Horner, dated December 6, 2007. Dr. Horner is a stormwater expert that raised many significant issues and concerns regarding this project during the FEIS review for the comp plan amendment. In reviewing the DSEIS, I see that the issues have not been addressed or mitigated. For that reason,the DSEIS is not adequate. Sincerely, Pa- e4°'g - Peter Bahls Director 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 46 Exhibit 1 RESPONSE TO COMMENTS FROM NORTHWEST WATERSHED INSTITUTE (Letter # 11) Comment 1 Thank you for your comments. The 2007/2008 EIS was found to be adequate and therefore it is assumed that the issues raised in the attached letter have been addressed to a sufficient degree. However, the Draft SEIS contains additional and updated analyses and discussion regarding water quantity and quality. Please refer to Section 3.2 (Water Resources), Section 3.4 (Fish and Wildlife), Section 3.5 (Shellfish), and Section 3.7 (Cultural Resources) of the Draft SEIS. Additional discussion is provided below for completeness. As noted in Chapter 2 of the Draft and Final SEIS, redevelopment for maintenance, repair and renovation of the Marina is limited to occur within existing building footprints, under a separate Binding Site Plan permit, which does not require additional environmental review as determined by Jefferson County as SEPA lead agency. Improvement of the Marina is considered a separate project that would proceed independent of the MPR proposal evaluated in this SEIS. Marina area renovations and reconstruction work is ongoing. The marina is not included in the MPR area evaluated in the SEIS. Jefferson County has conditioned the proposed project to require that no runoff from the golf course enter Hood Canal regardless of the size or frequency of the runoff event. Zero discharge would be achieved by grading the golf course to drain to a detention pond, and by soil infiltration, which is the preferred method of runoff disposal. Since the publication of the 2007 EIS, an additional soil study has been completed (Subsurface Group, LLC. November 21, 2008) and contains on-site infiltration testing results and engineering analysis. The infiltration rates to be used for final design of stormwater facilities are presented in the 2012 Grading and Drainage Report (Appendix E) and are based on the 2008 infiltration testing. Regarding contamination that could result from infiltration, please note that soils would be amended to provide treatment during infiltration, as described in the 2012 (and as updated) Stormwater Management Manual for Western Washington by the Washington State Department of Ecology. Regarding golf course management, please note that a Golf Course Best Management Plan was developed and included in Appendix F of the Draft SEIS. This plan includes measures such as reducing the input of nutrients such as nitrogen and phosphorous through a nutrient management plan, reducing the use of pesticides by choosing pest-resistant grasses and plants, and designing fairways to direct surface runoff to locations where it can be properly treated. See Appendix F of the Final SEIS for further details. David W. Johnson From: joe breskin <joe.breskin©gmail.com> Sent: Monday, January 05, 2015 4:08 PM To: David W. Johnson Subject:OEC Black Point Pleasant Harbor MPR DSEIS Comments David, In addition to the concerns raised by The Brinnon Group in the Jan 2 submittal by Barbara Moore- Lewis, Olympic Environmental Council (OEC) would add the following concerns: POPULATION The population of Brinnon is about 818 and maybe half this number of homes. Expanding the number of living quarters to 890 residential units (Options 1 & 2)will have an enormous impact in the area in many respects, including potable water, stormwater, sewage solids and effluents, release of CO2 into the atmosphere and loss of CO2 soil and tree sequestration. ECONOMICS Few of the built units are intended for year round occupancy. (The majority of this housing (67%) would be for short- term visitors and 33%would be for permanent residents.) 67%or about 548 units are hoped to be filled, but most likely the largest percentage of PT occupancy will be in the warmer time of the year. The impacts to the area call for showing an economic analysis that this resort is financially viable. We request this be done. Has the resort company factored in the new minimum wage for employees? Where will construction workers (80.5% out of the area)be housed? Feasibility of housing them close to the site? Will all construction works be from WA State? Options 1&2 details are described but the No Action, which is to build a few hundred homesites, is not detailed. So it is not being seriously considered. Yet, it is an Option and it should have comparative details so the costs can be seen. You ask for the public to weigh in and the public should have this information to consider. This is an omission and should be corrected. The information should be combined with that of the marina so one grasps an overall picture of the costs and potential impacts of the entire operation. What costs will be put to the area and state citizens? For instance, road repair from additional traffic the resort will bring. Utility costs. Medical facilities. Taxation. This estimation should be made public up front. GLOBAL WARMING Stripping this large area of trees and its natural grasses, soils and wetlands will release immense amount of greenhouse gases into the ambient air. Earth removal will have a large affect on the microbial soil community. A study needs to be done on how this will affect both the harbor life and the surrounding Brinnon community. i 1 2 5 3 4 Appendix M doesn't quantify the GHG releases and effects of the releases, and the mitigations are hardly that! And for sequestration to work, even for the replanted trees, the amount will not balance out. It takes years to regain that sequestration, whether replanted trees or new grass. Too, please factor in how this would affect the marine life. EFFLUENT Class A effluent discharge from the proposed sewerage treatment plant is planned to be stored and recycled. Do not use this to recharge the aquifers! Do not use this for fire protection and irrigation. It will make firefighters ill! There are many studies that determine recycling of wastewater treatment plant(WWTP) effluents are unsafe. There are thousands of chemicals and many pathogens that cannot be tested, nor the cumulative impacts. It is known that: microbeads from personal products pass through W WTPs into effluent MRSA and other pathogens remain in the sludge and the effluent antibiotic bacteria can be created in the WWTPs triclosan minimizes WWTP treatment effluent contains fire retardants effluent and well as the solids contain thousands of chemicals including chemicals of emerging concern and POPs More reason to not recycle the effluent: http://www.epa.gov/oig/reports/2014/20140929-14-P-0363.pdf NOISE: There is an inadequate discussion of construction noise resulting from stated need to crush vast amounts of gravel as site is developed. Presumption is that crushing would occur in batches,based on the combination of site development,related land disturbing activities and projected needs for each development stage.Noise abatement means should be provided in a noise abatement plan that includes hours of operation and noise abatement means and County should require development of computer models to predict noise impacts at receiving properties and ongoing monitoring to insure that projections are accurate and that noise abatement provided is in fact effective,and should includes clauses calling for immediate remedies if abatement fails to deliver promised SPL.Continuous monitoring at receiving property that records both peak and average SPL to be recorded during periods when crushing equipment is in operation and available for public review. SUMMARY This comment covers only some of the problems with the planned resort and the DSEIS. Clearly, it is not appropriate to approve this project at this time. Joe Breskin(Treasurer) for Olympic Environmental Council Jan 5, 2015 2 5 cont. 6 7 8 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 48 Exhibit 1 RESPONSE TO COMMENTS FROM OLYMPIC ENVIRONMENTAL COUNCIL (Letter # 12) Comment 1 Thank you for your comments, your comments are acknowledged. Please see the Response to Letter 8 (Brinnon Group), Comments 1 and 2. Comment 2 Please see the Response to Letter 8 (Brinnon Group), Comments 1, 2, 4, 5, 7, and 8. Comment 3 Please see the Response to Letter 9 (Friends of Miller Peninsula State Park), Comment 6. Comment 4 Please see the Response to Letter 8 (Brinnon Group), Comment 32. Please also refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4. Comment 5 Please see the Response to Letter 9 (Friends of Miller State Park), Comment 6. Comment 6 Comments acknowledged. Comment 7 Please see the Response to Letter 8 (Brinnon Group), Comment 17. Comment 8 Thank you for your comments, your comments are acknowledged. SIERRA Air IF i ftc, - ,.,e( i)1 4{$ 11.` t U4r ; Y _' ss'S a3 +s aru+ aii, 4& Iyb{I aiti, a€${ x e JAN 0 5 2"x 14 5 January 2015 JEffE nI CU':,'' Jefferson County Department of Community Development Attn: David Wayne Johnson RE: Pleasant Harbor Master Planned Resort DSEIS 621 Sheridan Street Port Townsend WA 98368 dwjohnson(a co.jefferson.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. 1 2 EFFLUENT: Class A effluent 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 impacts, 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 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. Traffic 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 community water resources. Water will become a key resource as weather warms and snow levels are minimized and rainwater runoff increases. 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 3 4 5 6 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 50 Exhibit 1 RESPONSE TO COMMENTS FROM SIERRA CLUB (Letter #13) Comment 1 Thank you for your comments, your comments are acknowledged. Comment 2 Please see the Response to Letter 9 (Friends of Miller State Park), Comment 6 for a discussion on greenhouse gas emissions. Comment 3 Please see the Response to Letter 8 (Brinnon Group), Comment 32 for a discussion on aquifer water quality. As well, please note that wastewater reuse is used widely throughout the U.S. for irrigation of golf courses and for firefighting. For example, a new golf course in the State of California cannot be built unless all irrigation is provided entirely from reclaimed wastewater. No effluent would reach the aquifer unless it percolates through the underlying soils and subsoil. Soil does a very effective job of removing all remaining "contaminants", and is especially effective removing pathogenic organisms (both bacterial and virus) from the highly treated and disinfected effluent. With reference to the chemicals, etc. mentioned in the letter, below please note that wastewater generated by the resort (i.e. sewage) would be from workers, restaurants and guests at the resort and what is flushed down the sewers and cleaning products will be carefully controlled by the resort. Comment 4 Please see the Responses to Letter 8 (Brinnon Group), Comment 19 and Letter 9 (Friends of Miller State Park), Comment 8 for discussion on traffic conditions on Hwy 101. Comment 5 Drought conditions have been incorporated into the water supply plan as discussed in the Response to Letter 8 (Brinnon Group), Comment 29. Please note that though there is a component of lateral migration of groundwater from the mainland to the Black Point peninsula, the water supply analyses essentially did not take into account this component of flow and relied only on precipitation as a source of water to the aquifer. As such, the water supply analysis prepared for this SEIS is conservative. Comment 6 Thank you for your comments, your comments are acknowledged. TO: Jefferson County Department of Community Development JEFFERSON.COUNTY DCD L FROM: Joe Baisch, 3485 Dosewallips Road, Brinnon, WA 98320 DEC 0 8 SUBJECT: Pleasant Harbor Marina &Golf Resort SEIS JE In response to your request for community input on the subject referenced above, I submit the following comments: I have lived in Brinnon,Washington since 1992. I am small business owner operating Elk Meadows Lodging and Farm and Mt Jupiter Water System Management. I have been an active citizen in Jefferson County for 23 years. I was on the team who established the North Hood Canal Chamber of Commerce and Emerald Towns Alliance, (Sponsor of ShrimpFest). I was a member of Team Jefferson, County Economic Development Council and established Big Quil Enterprises, a WSU 4H youth run shellfish business. In addition to these activities, I worked for WSU Extension from 2003 to 2010 on two projects: 1.The Bill and Melinda Gates Foundation's Connecting Schools and Community Grant as Coordinator 2. Northwest Area Foundation,St Paul Minnesota's Horizons Community Develop Program as a Community Coach THE STATESMAN CORPORATION'S PROPOSED MPR ON THEIR BLACK POINT PROPERTY IS THE COUNTY'S MOST IMPORTANT ECONOMIC DEVELOPMENT PROJECT SINCE THE PORT LUDLOW MPR. Government Policy has dramatically curtailed County timber revenue and short sited zoning and building codes have not only discouraged commercial development but forced a large percentage of Jefferson County citizens to both shop and work in adjacent Counties. Present County Leadership has offered no plan to turn the trend around. The lack of attention to Economic Development(Private Sector) has lead to an exodus of Families with school age children. All four County school Districts have experienced falling enrolment numbers. Brinnon School had 131 Students in 1993. It started 2013 with 25 students. Of the remaining school age students in the County, over 50%qualify for free/reduced meals. (Poverty!) Jefferson County has also maintained its lead in keeping its unemployment rate above 8%in Western Washington. The 30 conditions put on the developer have been answered. I urge the County to move the process forward and deal with issues sounding questions on these responses. The developer has already invested a few million dollars in bringing the marina complex up to current codes. Jefferson County desperately needs to diversify and increase its revenue streams. One of the main community concerns is how the resort's water requirements will affect neighboring wells. The Neighborhood Water Policy that requires Statesman to provide access to their water system will be a requirement. It is an asset to a land owner to have a public water system supplying water to their property. Joe Baisch, Brinnon,Washington 1 2 3 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 52 Exhibit 1 RESPONSE TO COMMENTS FROM JOE BAISCH (Letter # 14) Comment 1 Thank you for your comments, your comments are acknowledged. Comment 2 Comment regarding project review schedule is acknowledged. Comment 3 Comment regarding the Neighborhood Water Policy is acknowledged. 12345 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 54 Exhibit 1 RESPONSE TO COMMENTS FROM JOY BAISCH (Letter # 15) Comment 1 Thank you for your comments, your comments are acknowledged. The cited Deschutes County Destination Resorts report attached to your letter is included in this Final SEIS. Comment 2 Pumping water out of the Duckabush River was not investigated as an alternative for the Resort water supply. Because there is adequate water supply at the site aquifer, the Resort chose a groundwater supply in lieu of withdrawing water from in-stream flow uses. Any proposal to withdraw water directly from the Duckabush River would necessitate additional environmental review and permitting. Comment 3 Comment acknowledged. Comment 4 Comment acknowledged. Comment 5 Comment acknowledged. As a conservative approach to the SEIS traffic analysis, no reductions were made for resort access via waterborne or airborne modes of transportation. If resort access is accomplished by these modes, they would be accommodated in the typical boat trip generation and occasional float plane charter that is associated with a waterfront project of this type and size. David W. Johnson From: J Hal Beattie <jhalbt@gmail.com> Sent: Monday, January 05, 2015 2:44 PM To: David W. Johnson Cc: Subject: Bekah Ross Brinnon MPR DSEIS comment Attachments: Comment DSEIS Brinnon MPR 05Jan15.docx Mr Johnson Attached 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 concerns with its development. Our main concerns are as follows: 1. 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 turns 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 1 1 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 all available boat trailer parking is taken. Will the 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. In 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. If 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 10% 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 clients 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 will take place. 2 1 cont. 2 3 4 5 6 Many jobs at the resort will be seasonal. Will those workers become part of the permanent population of Brinnon? What happens to those seasonal workers during the off season: unemployment or welfare? What happens if Statesman cannot make a go of it? Will the 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 7 8 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 56 Exhibit 1 RESPONSE TO COMMENTS FROM J HAL BEATTIE and REBEKAH R ROSS (Letter # 16) Comment 1 Please refer to the Neighborhood Water Supply Program (Appendix F of the Draft SEIS) and the Response to Letter 10 (Hood Canal Environmental Council), Comment 11. Please also see Key Topic 4-2, Saltwater Intrusion, in Chapter 4 of this Final SEIS. As indicated on page 3.2-9 of the Draft SEIS, after completion of the proposed resort, recharge to the aquifer would increase compared to existing conditions which would reduce the potential for seawater intrusion. Comment 2 As noted in Appendix L of the Draft SEIS, net trip generation under Alternatives 1 and 2 is anticipated at approximately 3,840 daily trips (including vehicles entering and exiting the site) with approximately 298 trips during the PM peak hour. As noted in the SEIS, with implementation of identified mitigation measures, no significant unavoidable adverse transportation impacts would be anticipated. Comment 3 Comment acknowledged. Because the WDFW boat launch access is an existing State facility and this project would not be anticipated to increase demand for boat launching at this site, no mitigation specific to any peak parking demands is required. However, the applicant has been in conversations with WDFW regarding joint development of an overflow parking area, however, only information discussions have taken place and no formal agreement or project mitigation has been identified in the SEIS as a requirement to address an impact. Comment 4 Comment acknowledged. Please refer to Response to Letter 8 (Brinnon Group), Comment 17 regarding noise impacts. As stated in Chapter 2 (page 2-38) of the Draft SEIS, the applicant is investigating improving float plane access to a dock at the Pleasant Harbor Marina. The float plane dock would allow air access to the area for the general population, marina users, and resort visitors. It is assumed that the float planes would land outside the mouth of Pleasant Harbor and taxi into the harbor itself. However, this is a separate project that would occur independent of the Proposed Actions/EIS Alternatives, and may be subject to additional environmental review at the time that permit applications are submitted. Agency decisions regarding environmental review under SEPA would be required prior to issuance of any applicable permits and approvals. Comment 5 Comment acknowledged. Both direct and indirect potential impacts to rural character and population are outlined in Section 3.12 of the Draft and Final SEIS. As sated on page 3.12-5, “Development under either Alternative 1, 2 or 3 would allow for the transformation of the Pleasant Harbor site from a primarily vacant, former campground that is a largely vegetated and forested area to a new MPR development that would provide opportunities for a range of Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 57 Exhibit 1 residential and recreational land uses and activities.” The SEIS acknowledges that density, population, activity levels would increase over existing conditions, and the type, character, and pattern of land uses on the site would change substantially. However, the rural character of surrounding land uses are intended to be preserved by limiting the visibility of the resort from offsite viewers, preserving natural area and open space, limiting building heights, and clustering the more intense development internal to the site. Refer to Section 3.12 of the Final SEIS for further details on impacts and mitigation. Comment 6 Your comments are acknowledged. Chapters 1-3 of this Final SEIS are shaded to show edits that have occurred since publication of the Draft SEIS. Comment 7 It is anticipated that the majority of jobs to operate the project under Alternatives 1-3 would be seasonal. However, the applicant proposes to develop programs to attract year-round visitors to the site, which could contribute towards retaining staff during off-seasons. Comment 8 Please see the Response to Letter 8 (Brinnon Group), Comment 2. David W. Johnson From: Bonnie BeaudoinPLU <beaudobj @plu.edu> Sent: Sunday, January 04, 2015 8:09 PM To: David W. Johnson Subject:Master Planned Resort(MPR) Dear David Johnson, I would like to weigh in on the master plan for the proposed resort/golf course proposal for Hood Canal area South of Brinnon. Option 3 seems the best option in light traffic impact, fresh water (wells) concerns, and other environmental factors. Option 3 provides recreational access for a variety of people as opposed to a golf course which seems rather elitist. Let's look at the big picture, not just the 18th hole. Bonnie Beaudoin Using stories, artifacts, and experiences to teach, connect, and inspire. beaudobiCa.plu.edu EDUC. 412: Social Studies Methods Outreach Education Coordinator 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 59 Exhibit 1 RESPONSE TO COMMENTS FROM BONNIE BEAUDOIN (Letter # 17) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: Bonnie Beaudoinjj <beaudoinjjQyahoo.com> Sent: Sunday, January 04, 2015 5:47 PM To: David W. Johnson Subject:Proposed Resort/golf course master plan Dear David Johnson, I would like to weigh in on the proposal for the resort/golf course plan on Hood Canal just South of Brinnon. Option 3 seems the least disruptive considering traffic, well water, and other community/ environmental concerns. Option 3 offers resort/wilderness access for a variety of people while the golf option seems rather elitist. Let those golfers trade in their clubs for a nature vacation. Please add me to the email list regarding this concern. Bonnie Beaudoin Beaudobj @plu.edi Sent from my iPhone 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 61 Exhibit 1 RESPONSE TO COMMENTS FROM BONNIE BEAUDOIN (Letter # 18) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: Carl Smith Sent: Monday, December 01, 2014 10: 14 AM To: David W. Johnson Subject:FW: Pleasant Harbor Marina and Golf Resort FYI From:jeffbocc Sent: Monday, December 01, 2014 9:23 AM To:John Austin; Phil Johnson; David Sullivan Cc: Philip Morley; Carl Smith Subject: FW: Pleasant Harbor Marina and Golf Resort From: Barbara Buchman [mailto:barbarabbuchman @gmail.com] Sent: Monday, December 01, 2014 6:20 AM To:John Austin Cc:jeffbocc Subject: Pleasant Harbor Marina and Golf Resort As a Brinnon resident for 25 years, I have great interest and concern for the well being of our town. I am a former Brinnon School Board member and my husband is a retired physician. We have worked to help make Brinnon a beautiful place to live. Our town is in dire need of more job opportunities. Our school is losing enrollment every year. We very much need Pleasant Harbor Marina and Golf Resort to be developed in the way Statesman have proposed. Their design, quality of construction and overall plan is of the highest standard. They have a track record for quality projects with great attention to environmental impact for the community. We have been great supporters of this project since its inception 2008! It is very disappointing that it has taken it this long to get to this point. We have had boats in Pleasant Harbor for many years and the improvements that have already been made are substantial. With this development, new residents will be attracted to our beautiful South County town of Brinnon with employment and recreation opportunities. Additionally, this will be clearly of great benefit to the coffers of Jefferson County. This project will provide a positive impact in every way for our community. This is development and growth at its very best. Please support Pleasant Harbor Marina and Golf Resort. EVERYONE will benefit from this great addition for Jefferson County. Respectfully, Barbara Buchman 256 Wildwood Shores Brinnon, WA 98320 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 63 Exhibit 1 RESPONSE TO COMMENTS FROM BARBARA BUCHMAN (Letter # 19) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: Carl Smith Sent: Tuesday, December 02, 2014 12:05 PM To: David W. Johnson Subject:FW: Pleasant Harbor Marina and Golf Resort Project FYI From:jeffbocc Sent:Tuesday, December 02, 2014 10:57 AM To:John Austin; David Sullivan; Phil Johnson Cc:Carl Smith; Philip Morley Subject: FW: Pleasant Harbor Marina and Golf Resort Project From: Barbara Buchman imailto:barbarabbuchman@gmail.com] Sent: Monday, December 01, 2014 5:13 PM To:John Austin Cc:jeffbocc Subject: Pleasant Harbor Marina and Golf Resort Project As a retired cardiologist (Swedish/Providence Honorary), I am very interested in supporting the Statesman Project for Pleasant Harbor Marina and Golf Resort. This project will be a positive influence on the overall well being of the entire community and Jefferson County. It will provide much needed jobs and raise the standard of living for the area. I have been a 14 year Brinnon resident, have given financial support to meet all stated needs of the Brinnon Food Bank and many other project for the area to improve the quality of life for this beautiful area. We very much need the type of quality development that this project will provide. Sincerely, Joseph G. Buchman, M.D. 256 Wildwood Shores Brinnon, WA 98320 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 65 Exhibit 1 RESPONSE TO COMMENTS FROM JOSEPH G. BUCHMAN (Letter # 20) Comment 1 Thank you for your comments, your comments are acknowledged. REE D5 5 o c3V-,ow‘ t\ mr ecyJc,e4--6.) W e 4N t o r r h U©c ( cv_ ' }2 ?ft9..)ec-71- 5'5e1- 'fib Co,ry1 wkw l ) a 2 g Aril u,rq J l 0-.o rK AA 71m inkra41\kilk RECEIVED EC o s 2014 4+1V0A4 10-a6-54-1a-tL 21111R A €3 z9 m mac 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 67 Exhibit 1 RESPONSE TO COMMENTS FROM SCOTT BURNS and MARGARET W__ (Letter # 21) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: Sarah Clawson-Schuch <saclawso© gmail.com> Sent: Sunday, January 04, 2015 3:57 PM To: David W. Johnson Subject:DSEIS proposal for a Master Planned Resort(MPR) Dear Mr.Johnson: I am writing to voice my opinion regarding the DSEIS proposal for a Master Planned Resort(MPR)just south of Brinnon on the Hood Canal/Black Point peninsula. I am endorsing "no action" because of issues about traffic, lack of available well water to the proposed development, public safety, lack of a bond if the project should begin and fail, infrastructure, and the massive size given the locale. I also feel this decision is being rushed considering the brief window from Thanksgiving to New Year's. I live in Port Ludlow but have hiked extensively in the Brinnon area and south of there. It would be a shame to spoil the natural beauty of this area with large-scale development. Sincerely, Sarah Clawson-Schuch saclawso(&gmail.corn 360) 215-4065 home 765) 776-6839 cell 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 69 Exhibit 1 RESPONSE TO COMMENTS FROM SARAH CLAWSON-SCHUCH (Letter # 22) Comment 1 Thank you for your comments, your comments are acknowledged. Transportation, water, public services, and rural character issues were evaluated in Section 3.2 (Water Resources), Section 3.9 (Transportation), Section 3.12 (Rural Character) and Section 3.17 (Public Services) of the Draft SEIS. See these sections of the Final SEIS for further details. Please see the Response to Letter 8 (Brinnon Group), Comment 2 regarding bonding the project, and Response to Letter 3 (Port Gamble S’klallam Tribe), Comment 9 for a discussion on SEPA EIS public comment. David W. Johnson From: Ruth DiDomenico <intheharbor@msn.com> Sent: Friday, November 21, 2014 5:20 PM To: David W. Johnson Subject:Pleasant Harbor Project Jefferson County Committ ee: The coming meeting re: the Pleasant Harbor Project is so very important to our "sleepy" community. I am surprised that Statesman Group is still interested in investing millions of dollars in our area that would put so many of our idle people to work and give our young people some hope of being able to stay here in Brinnon when they graduate from high school. I understand why the long standing local corner grocery store that has one or two cans of most things on their shelf or the local actors guild would not want to see a sizeable competitors move in, but do not believe that this vocal few should make the difference in making this community come alive and contribute so much to a prosperous (taxable based) and mature improved quality of life that a resort with all their amenities would allow for the rest of living here. Ruth DiDomenico 17 Quiet Place Brinnon, Wa. 98320 360 796 0156 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 71 Exhibit 1 RESPONSE TO COMMENTS FROM RUTH DiDOMENICO (Letter # 23) Comment 1 Thank you for your comments, your comments are acknowledged. Nsgv r Pleasant Harbor Master Planned Resort Draft Supplemental EIS DRAFT SEIS OPEN HOUSE, 12.03.14 PUBLIC COMMENTS ON DRAFT SETS Name Address Telephone/email DALILA DOWD P. O. Box 142, Brinnon, 98320 360-796-4001 Comments: Please make comments as specific as possible and reference the Draft SEIS page number, table number, etc. I retired from Brinnon School District in 2013. The enrollment has dropped by about 75% since Its peak of over 135 students in the late 80's - early 90's. More than 70% of the students are on the National School Lunch Program that qualifies students for free/reduced meals based on household income. This is clearly an indicator of the economic health of the Brinnon community. The Statesman Group is the only significant hope for an economic boost to come to the Brinnon community in the last half century. The Master Planned Resort (MPR) proposal has been studied and scrutinized for years and it is clear that it would be positive for the economic health of the Brinnon community while keeping with the rural character of this tourist/retirement area. t1ed Comments on the Draft SEIS may be given in writing at any time during the comment period, which ends at 4:30 PM on January 5,2015. Written comments can be sent to: David W.Johnson,Associate Planner Department of Community Development,Jefferson County 1 o821SheridanStreet Port Townsend,WA 98368 Comments may also be submitted by email to: djohnson@cojefferson.wa.us I pDEC 1 1 2014 JEFFERSON COONEY L. DEPT OE COMMUNITY DEVELOPMENT 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 73 Exhibit 1 RESPONSE TO COMMENTS FROM DALILA DOWD (Letter # 24) Comment 1 Thank you for your comments, your comments are acknowledged. 4`... J6i 1 sf11 s c,..O Pleasant Harbor Master Planned Resort Draft Supplemental EIS DRAFT SEIS OPEN NOUSE, 12.03.14 PUBLIC COMMENTS ON DRAFT SEIS Name Address Telephone/email JOHN DOWD P.O.Box 142, Brinnon, 98320 360.796.4001 Comments: Please make comments as specific as possible and reference the Draft SEIS page number, table number, etc. Jefferson County and the Brinnon area in particular need the economic boost that the Pleasant Harbor Master Planned Resort will provide. The resort is well thought out with years of studies and public hearings. It will provide jobs and additional tax base in a region that is otherwise quite stagnant. It is planned in a way that is keeping with the rural character with which the people of South County are comfortable. The Brinnon community was once supported by a thriving timber industry, but is now largely a popular retirement area with tourism being the bulk of the economy. The master planned resort would be a good fit for a tourist oriented retirement community. Due to the exhaustive process that Jefferson County DCD, the Brinnon community, and the Statesman Group have been involved with over the past several years, I am confident that either Supplemental Environmental Impact Statement Alternatives 1 or 2 would be appropriate and that it would be best if the Proponent/Applicant were to decide which alternative would be best suited for the site from a business perspective. If the business is successful, then Jefferson County and Brinnon will benefit. Comments on the Draft SEIS may be given in writing at any time during the comment period, which ends at 4:30 PM on January 5, 2015. Written comments can be sent to: David W.Johnson,Associate Planner Department of Community Development,Jefferson County 621 Sheridan Street Port Townsend,WA 98368 Comments may also be submitted by email to: d'ohnson , co.'efferson.wa I c L 11 \ , I I r i I1 i DEC 1 1 2614__ j Li, JL r CUU dTYi it,PT rrt'rip¢ryDHlpon Err _, 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 75 Exhibit 1 RESPONSE TO COMMENTS FROM JOHN DOWD (Letter # 25) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: David Galle <viniferaman @yahoo.com> Sent: Monday, January 05, 2015 12: 10 PM To: David W. Johnson Subject:comments on Statesman/Black Point DSEIS January 5, 2015 To: Mr David Wayne Johnson, Project Planner, Jefferson County, WA sent via email) Dear Mr Johnson, This message contains my comments regarding the Pleasant Harbor Master Planned Resort Draft Supplemental Environmental Impact Statement(DSEIS)that was published on November 19,2014. Would you please verify that I've sent these comments to the correct address(ie,you), or else tell me where they should be sent instead? I live near Hoodsport in Mason County. Even though I'm not a resident of Jefferson County,this proposed resort will have enormous impacts on anyone who lives in the Hood Canal region. The 'improvements' contained in the DSEIS over the project plans presented in previous documents range from miniscule to insignificant, and it's readily apparent that no serious attempt has been made to mitigate the numerous serious impacts this project will foist upon the area where I live. Further damage to the Hood Canal ecosystem, removal of wetlands, increased traffic and progressive saltwater infiltration incurred by this project are among the most glaring issues that have been essentially ignored by the developer in this and previous documents, among a host of others. Furthermore,the developer should not be allowed to withhold from public view project plans for the Pleasant Harbor marina area or any other parts of the project that don't contain proprietary or otherwise confidential information. I urge you in the strongest possible terms to not permit this project to go forward until the developer offers a complete mitigation plan for ALL of the potential project impacts, and is fully transparent regarding plans for existing facilities such as the marina. Thank you for your consideration. s/David Galle PO Box 428 Hoodsport, WA 98548 1 1 2 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 77 Exhibit 1 RESPONSE TO COMMENTS FROM DAVID GALLE (Letter # 26) Comment 1 Thank you for your comments, your comments are acknowledged. Water resources, shorelines, critical areas, and transportation issues were evaluated in Section 3.2 (Water Resources), Section 3.6 (Shorelines), Section 3.7 (Critical Areas) and Section 3.9 (Transportation), of the Draft SEIS. See these sections of the Final SEIS for further details. Mitigation measures are identified for all identified impacts for each element of the environment evaluated in Chapter 3 of the Draft and Final SEIS. Mitigation measures are also summarized in Chapter 1. With regard to the issue of saltwater intrusion, please refer to Key Topic 4-2, Saltwater Intrusion, in Chapter 4 of this Final SEIS. Comment 2 Please refer to the response to Comment 1 of this letter, above. Saturday,January 3, 2015 About two years ago 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 even 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 condition and quality. 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. It is set to maintain and store a record every 30 minutes and has been doing so since 10-11-07 @ 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 which 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 its recordings. 5. Do you have an unbroken data set since 2006 as you say? 6. In 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 the collection and testing of samples? 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 1 2 3 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 79 Exhibit 1 RESPONSE TO COMMENTS FROM TERRY GERMAINE (Letter # 27) Comment 1 Thank you for your comments, your comments are acknowledged. Comment 2 Comment acknowledged. The Quilcene weather monitoring station, data from which was utilized for water resources analyses, has been present since 1948 and is currently operated by the U.S. Forest Service. The Quilcene station is an accredited station and data from this station is appropriate for analysis purposes. Data since 2001 (and earlier) can be found at http://www.raws.dri.edu/cgi-bin/rawMAIN.pl?waWQUC Comment 3 Thank you for your comments, your comments are acknowledged. David W. Johnson From: Belinda Graham <sgraham002t yahoo.com> Sent: Friday, November 21, 2014 6:10 PM To: David W. Johnson; David W. Johnson Subject:Pleasant Harbor Marina & Golf Resort To: Jefferson County Department of Community Development My wife and I are very fortunate to have a vacation home in Brinnon that will be our full-time home in early 2015. We love the area's scenic beauty and splendor. With that being said, we notice that Brinnon and its surrounding area is in need of economic growth to sustain the community for future generations. As our nation's economy starts to dig out of its most recent economic downturn, the proposed Pleasant Harbor Marina&Golf Resort project would be a excellent economic stimulus for this region of Jefferson County and would generate positive impacts for years to come. In addition, my wife and I have always striven to do be good citizens when it comes to environmental impacts in our Brinnon area. After reading the current Draft SEIS we continue to support the proposed Pleasant Harbor Marina&Golf Resort project and ask for the support of Jefferson County. Thank you for your time. Sincerely, Steve&Belinda Graham 764 Point Whitney Road Brinnon, Wa. 98320 Mailing Address: 2173 Fielding Road Riverside, Ca.92506 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 81 Exhibit 1 RESPONSE TO COMMENTS FROM STEVE and BELINDA GRAHAM (Letter # 28) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: Eric and Joan Hendricks<overbrookfarm© embarqmail.com> Sent: Saturday, January 03, 2015 9:39 AM To: David W. Johnson Subject:Pleasant Harbor comments on EIS Eric Hendricks January 2, 2015 1592 Duckabush road Brinnon, Wa 9832 To: Jefferson County Planning Commission Subject: Opposition to Black Point Resort Please consider a concern that I have to offer in opposition to the development of Black Point Resort. In the past, I have worked adjacent to a golf course and am familiar with the fertilizing and pesticide use that is used to maintain the greens. Red thread is a fungus that is common and is controlled by regular nitrate and fungicide applications. The greens also need seasonal nitrate fertilizer and other pesticide treatments. The plan that was presented by the Statesman group was that they would be using organics to treat the golf course. The maintenance of the golf course would be nearly impossible with just organics (manure spreaders on a golf course? not likely). It is also possible that the nitrates and pesticides could run off onto the clam beds or run down into the aquifer. An informal measurement of the rainfall in this area was over 10" or rain in 3 days. Nitrates contribute to low dissolved oxygen and the "dead zones" that are now in Hood Canal. In the aquifer, nitrates are very harmful to human health if found in drinking water. The Hood Canal area has been used and enjoyed by tourists for over 100 years. Surely a different location that is not above some of the Pacific North Wests best clamming beaches could be found. Hood Canal is also notorious for the slow water flushing and replacement back to Puget Sound. This is just the wrong place for a resort. Thank you, Eric Hendricks 1 1 2 3 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 83 Exhibit 1 RESPONSE TO COMMENTS FROM ERIC HENDRICKS (Letter # 29) Comment 1 Thank you for your comments, your comments are acknowledged. However, the applicant believes it is feasible to use organics to maintain the greens. Comment 2 The site will be regraded and designed so that all water on the site will be collected, treated and reused and will not be discharged to Hood Canal. In addition there will be several areas monitored for water quality around the site to ensure that if an accidental release occurs, corrective measures can be implemented quickly. Comment 3 Your comment is acknowledged. David W. Johnson From: Eric and Joan Hendricks <overbrookfarm@embarqmail.com> Sent: Saturday, January 03, 2015 10:06 AM To: David W. Johnson Cc: overbrookfarm Subject:Pleasant Harbor DSEIS comments Joan Hendricks 1592 Duckabush Road Brinnon, WA 98320 January 3, 2015 Dear Mr. Johnson, Jefferson County Planning Commission and Jefferson County Board of County Commissioners, I am writing with concerns about the proposed resort at Pleasant Harbor. I do not believe that all of the issues that would impact our natural environment and our community have been sufficiently addressed. I would support choice number three on this issue, no action, and urge you to follow the thoughtful mitigation proposed by the Brinnon Group before proceeding. I am 55 years old, educated in the biological sciences, and have reasonable common sense. I have read most of the EIS and these are the problems I see with it: No matter how "environmentally safe" a golf course is, there is bound to be run off into Hood Canal that would impact recreational and commercial shell fishing, and water quality. Moving from 1 to 2.2 million cubic yard of earth from the hillsides around Pleasant Harbor would make the area highly susceptible to erosion; we often get 3- 5 inches of rain in 24 hours. Also, there is no way they would be able to yank the undergrowth from the ground on the building site, put it in a holding area, and get good survival so they could later replant it. The 890 condominium units and commercial area will create too great an impact on our highways, community services, and existing residents' wells. The promised jobs for new and old residents would likely pay poorly, and not enable workers to be financially independent. We would end up supporting them through our community services. Thank you for your consideration of my opinions, 1 1 2 3 4 5 Joan Hendricks Joan and Eric Hendricks Brinnon, WA 2 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 85 Exhibit 1 RESPONSE TO COMMENTS FROM JOAN and ERIC HENDRICKS (Letter # 30) Comment 1 Thank you for your comments, your comments are acknowledged. Comment 2 The Jefferson County Board of County Commissioners conditions imposed on the Resort through Jefferson County Ordinance 02-0128-08 prohibits golf course runoff from being discharged to Hood Canal: 63 (q) Stormwater discharge from the golf course shall meet requirements of zero discharge into Hood Canal. To the extent necessary to achieve the goal of designing and installing stormwater management infrastructures and techniques that allow no stormwater run-off to Hood Canal, Statesman shall prepare a soil study of the soils present at the MPR location. Soils must be proven to be conducive to the intended infiltration either in their natural condition or after amendment. Marina discharge shall be treated by a system that reduces contamination to the greatest possible extent. Analysis of the infiltration capabilities of site soils is provided in the Geotechnical Investigation (Subsurface Group, LLC, December 17, 2008) included in Appendix E of the Draft SEIS. The infiltration rates identified in the Geotechnical Investigation will be utilized in the final stormwater system design to implement the goal of no stormwater runoff to Hood Canal. All aspects of site development (i.e., during construction and in the operational condition) would be required to comply with the most current applicable standards for stormwater management under Federal, State, and County regulations. See Draft SEIS Section 3.2 (Water Resources) and the Grading and Drainage Engineering Report (Peck & Associates, May 16, 2012) also included in Appendix E of the Draft SEIS. Please also refer to the Response to Letter 8 (Brinnon Group), Comment 33. Comment 3 The grading proposal for the site would be implemented in phases, as described in the Grading and Drainage Engineering Report (Peck & Associates, May 16, 2012; included in Draft SEIS Appendix E). The construction contractor would be required to comply with the extensive stormwater management requirements of all applicable Federal, State and County regulations, including seasonal restrictions to earthwork between October and April of any construction season. See also the Responses to Letter 3 (Port Gamble S’Klallam Tribe), Comment 4, and Letter 5 (Washington State Department of Ecology), Comments 2 and 3. The comment regarding the survival rate of undergrowth plants to be removed from building sites and transplanted to a holding area is noted. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 86 Exhibit 1 Comment 4 Transportation, public services and water supply issues were evaluated in Section 3.2 (Water Resources), Section 3.9 (Transportation), Section 3.17 (Public Services) of the Draft SEIS. See these sections of the Final SEIS for further details. Comment 5 Please see Key Topic 4-2, Fiscal Considerations, in Chapter 4 of this Final SEIS. Jennings Heins & Associates, Inc General Contractors Jennings Heins&Associates, Inc PO Box 2198 1 ECE]I\IE}Poulsbo,WA 98370 1-'!_ NOV 29 4PleasantHarborDSEISc/o Jefferson County DCD 621 Sheridan Street Port Townsend, WA 98368. NFL, November 25, 2014 To Whom it May Concern; Jennings Heins&Associates, Inc, as the General Contractor for the Pleasant Harbor Bistro,would like to express our support and hopes for future success of the Pleasant Harbor Marina and Golf Resort. We believe the whole of Jefferson County will benefit from the cultural and economic growth brought to this area by this development. The economic inflow from the Stateman Group is already bringing work to this area. Even now,at this early construction stage,there are benefits being felt by the local communities. Our project itself employs 10-15 persons each day. While at work on the Bistro our employees become aware of the general area and the businesses where they go for their lunches and gas,stop for coffees,and chat with staff or owners. These workers will consider this area for their families and homes now that they are working there. This will provide stable real estate values and broaden the tax base for the county. The Pleasant Harbor Marina and Golf Resort will continue on and grow with more workers and more long time jobs being available to the residents of this county. As the construction moves to future phases more workers will see and feel the beauty of this area. This is a just one of the early benefits of this project. The long lasting benefit for those of us living and working in Jefferson County will be the full time jobs and skilled workers who will work, manage and live in Brinnon and the surrounding area because of the resort,golf course and surrounding homes. From entry level to highly skilled workers this project will bring jobs to this area and pay taxes to our county. Sincerely,and with high hopes for the future of Jefferson County, Jennings Heins&Associates, Inc General Contractors Serving the West Sound Community Phone: 360-297-2895 www.jenningsheins.com Fax:360-297-2891 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 88 Exhibit 1 RESPONSE TO COMMENTS FROM JENNINGS HEINS & ASSOCIATES, INC. (Letter # 31) Comment 1 Thank you for your comments, your comments are acknowledged. I Awl. w rrhng iv say 1icz+ psea5an 1 rbar o evclapmcit plans arc -lop big fol. a DEC 0 5 2014 sta4c/ covnii) wlnc I o tvyPAS 30 C nny 11 Eii tiara qp re serve The ctvkalt of VII iS S t ya'. 4tt J{ WO +Canal IPNge' SovI1c It jvst seems a P- n5 f sires(fy5h ,h01V54 4nt sirt ° 01 r The tia5 been slievisiing 4. p,oYrato fimoy wage _pi)s Thank.you , k,K.ch ncS S p.o. sax g9$ swkozle. V* 5 8386 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 90 Exhibit 1 RESPONSE TO COMMENTS FROM K KENNELL (Letter # 32) Comment 1 Thank you for your comments, your comments are acknowledged. Water quality and shellfish issues were evaluated in Section 3.2 (Water Resources), and Section 3.5 (Shellfish) of the Draft SEIS. See these sections of the Final SEIS for further details. To: Diane Coleman[diane @pleasantharbormarina.com] From: Genene G. Kluck D rJSent: Tue 12/2/2014 3:02:06 PM Importance: Normal Subject: Request MAIL RECEIVED: Tue 12/2/2014 3:02:11 PM Diane: I have been concerned about Brigadoon & the cold weather. Doug (my husband) was going to come up this weekend to check on the boat & start it . . . .would that be a good time & is it relatively easy to get to the F Dock? How can we best support the improvements of the marina. . . . Doug would not be able to do the attendance at the night meeting & I am here in California . . . . I am hoping that Kris or Scott Uren will be present at one of the meetings . . .Although I am a new member, I am most supportive & that is one of the reasons I chose Pleasant Harbor to moor the boat there is absolutely nothing on Hood Canal which is an adequate marina for our type of boat or recreational needs . . . . all that is being done for marina & its mooring members/guests is an investment in the Puget Sound Boating Community. . . . this is a win-win project ! Best regards, Genene Kluck 916-955-8757 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 92 Exhibit 1 RESPONSE TO COMMENTS FROM GENENE KLUCK (Letter # 33) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: Laurie Mattson <Imattson72@yahoo.com> Sent: Wednesday, December 03, 2014 10:20 AM To: David W. Johnson Subject:Opposition Comments: Pleasant Harbor Marina and Resort- Draft Environmental Statement 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 of the surrounding wilderness and Hood Canal area and am opposed to the expansion of Pleasant Harbor Marina and Resort. I am very worried about further contamination of Hood Canal,which is already negatively 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. If 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 term. 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 Highway 101 that is already inadequate and often dangerous with curves and long stretches where passing slower vehicles is not a safe option. Too many accidents and lives have been lost already. It 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 in the area. I believe 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 360 796-4416 Imattson72 @yahoo.com Sent from my iPad 1 1 2 3 4 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 94 Exhibit 1 RESPONSE TO COMMENTS FROM LAURIE MATTSON (Letter # 34) Comment 1 Thank you for your comments, your comments are noted. Comment 2 Comment acknowledged. Please see the Response to Letter 30 (Joan Hendricks), Comment 2, regarding runoff to Hood Canal. Also see the Response to Letter 8 (Brinnon Group), Comment 32, regarding contaminants of emerging concern (CECs) in wastewater treatment plant effluent. Comment 3 Comment acknowledged. Please see the Response to Letter 8 (Brinnon Group), Comment 15. Comment 4 Comment acknowledged. Projected employment and wages were evaluated in Section 3.11 (Employment and Housing) of the Draft SEIS. As stated on page 3.11-8, “An Economic Analysis of Earnings Pursuant to Jefferson County Board of County Commissioners’ Condition 63g for the Pleasant Harbor Master Planned Resort (Appendix N). It is estimated that approximately 19.5 percent of construction jobs and 99 percent of operational jobs that would be created by the Pleasant Harbor project could be at 80% or less of the Brinnon area AMI.” Regarding construction employment, BoCC condition 63 (e) requires that: Statesman shall advertise and give written notice at libraries and post offices in East Jefferson County and recruit locally to fill opportunities for contracting and employment, and will prefer local applicants provided they are qualified, available, and competitive in terms of pricing. See FEIS Section 3.11 and Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS for further details. oN co 74 t l t C. wig. 1 r..„...CU i 8 leik qi('N o-c- iri t 1' 50 Pleasant Harbor Master Planned Resort Draft p emental EIS DRAFT SEIS OPEN HOUSE, 12.03.14 PUBLIC COMMENTS ON DRAFT SEIS Name Address Telephone/email NJ(' J y / ” lG F Cif PO.-507c ,ly so/— 60-2008 Qv/ lee ne„./609 9,F37/ I eland/et touseeno, 61c1e.rt Comments: Please make comments as specific as possible and reference the Draft SEIS page number, table number. etc. y 1rbeieve, the- P/esan7/ r{)or Air', Play/nel eyo,- e!&1- -( G ge: 71 TD ,Jef'rer5on (,oct-r r. It breed e xa P/e- orre--c.o 4.--/en JC<::ess 8, / Jai ii-C1 blips k r` Nir(7C'/r-, Z1 C 1:-.;a . C•1 L',17 A-r. Greg D T i ohs r <Sorz77a Je{ a . X 66 iZv/ ye 26ie c+aov.- LsiaC- is sscLs,rai I. 6 wJi t.,,,,' lrrt)rtnvi 15 /201 `b i:1 avid Woad 110/- be- Cite-4-G1vielrnir / B. l ;-- -ri an /S/O/ Ga otc lc LAI-C.4 e- sciIbu2 Nal-A tL cieVlts/a.T'rny leoe/ l il-Q.4-q Lc) D loweveY L1 Goc DCoccr l rfk c i GVt /led Mss wow pIaM4a cc4;16e 17 0 Y1"AO ati-r” COms'i 4 i / i7 rer .,`'ve &Orec S fhe. reer( Lout, u4 rnyop,nton, aa- o way{ t- e.- ne ya-{z bee, • Comments on the Draft SEIS may be given in writing at any time during the comment period, which ends at 4:30 PM on January 5, 2015. Written comments can be sent to: David W. Johnson, Associate Planner Department of Community Development, Jefferson County 621 Sheridan Street Port Townsend, WA 98368 Comments may also be submitted by email to: djohnson(t co.iefferson.wa.us 1 2 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 96 Exhibit 1 RESPONSE TO COMMENTS FROM JOY MCFADDEN (Letter # 35) Comment 1 Thank you for your comments, your comments are acknowledged. Comment 2 Thank you for your comments, your comments are acknowledged. David W. Johnson From: fff<mckayshrimp @hotmail.com> Sent: Sunday, November 30, 2014 10:02 PM To: David W. Johnson Subject:Pleasant Harbor DSEIS Mr. Johnson, We have been waiting a long time now for the Black Point resort to come into being. Too much 'red tape' dampens productivity general community well being. I am looking forward to seeing reasonable community development and the Pleasant Harbor resort project will benefit Brinnon. I also believe in a free market and development has been strangled by minority NIMBY's using environmental concerns as an excuse to keep people from expanding our community in reasonable ways. A greater tax base might afford us cheaper waste management leading to cleaner backwoods roads. John McKay Brinnon resident of forty years PO Box 168 71 Brinnon Ln Brinnon WA 98320 360 3014067 1 1 2 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 98 Exhibit 1 RESPONSE TO COMMENTS FROM JOHN MCKAY (Letter # 36) Comment 1 Thank you for your comments, your comments are acknowledged. Comment 2 Comment acknowledged. Please see Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. fr 9u.r-enns-z f 11— n1F: CEItai D0- Oil CO i,L" is i j1'(CO %L2 Pi I; ': U E G 3 0 2014 w'ti_L GE COP M M[?Y DEVELOPMENT N. v1i6C h pity,. t 199 4 Lct k Po rleco . c vi z . is /Lo n Cc wi is . l. . If_is _a , lost i ossi Jo_ k 4 ctif V-0_, c . ietuact _ r rd o-dopr 2 P ___-/ ... c6 l s iim-i ct Gtrh t& , Q s U1 1 P zto • as 0 t .,r: .,it-- 91/L. 11A.K1 ow cuict,11-d4_ 4 wcetoi-z. 1 s .-ctiVted Fivi.742.1 .it r S ,i_, . effa s to cAc.. e xt S1w.e Ply 3. v ,c 4- Ce.... c Az. iftc141 WIr(.>7 'G1r'Vat c al 19-6-1,1 Ct a,i, crnc C o__riof 67;1 c ry - i 's a,1-- ali 0,66 uA l C o1 l 1 c ce 20 tee- /1 Ec dLt ilovu,, 1:3 B.n6LGoa- tilt-_Ilitilabtf_ -614 /,‘.9e tG 'UGd. ii-e_.- 1 EA 2 3 4 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 100 Exhibit 1 RESPONSE TO COMMENTS FROM BRENDA MCMILLAN (Letter # 37) Comment 1 Comment acknowledged. The 10-year phasing process utilized for the analysis in the SEIS is based upon anticipated buildout of the project as identified by the applicant, is also intended to anticipate and identify evolving conditions that could occur over time. Comment 2 Please see the Response to Letter 10 (Hood Canal Environmental Council), Comment 13. Comment 3 The rationale behind this comment is acknowledged; however, water resource analyses must be based on the nearest accredited weather station with a long period of record. Quilcene was the closest station. A considerable amount of effort was spent evaluating the applicability of that gage to Pleasant Harbor site conditions. These data were also compared to local gages with shorter periods of record, and the Quilcene data was found to be applicable. Comment 4 Please see the Response to Letter 8 (Brinnon Group), Comment 15. RECEIVED Jefferson County Planning Commission Public Commentary on DSEIS Nov. 19 2014 214JAN05 Rob Mitchell C rn ^ r e,1 ;: 9 ^'. 4246 Duckabush Rd. JLH t`s`°' i' A i{ emu' Brinnon, Wa. 98320 I protest the fact that the developer was allowed 5 V2 years with no deadline to produce this massive document and delivered during the holidays when many county residents are away and unaware of it's existence. Furthermore, the Public Commentary Period is inadequate. I ordered and purchased a hard copy at my own cost of$71.67 which was not available until 11/25/14 Many of the Brinnon Residents do not have adequate internet service to view this document or can afford to buy one. The DSEIS for the proposed Black Point MPR is inadequate therefore Alternative 3 or No Action must be preferred. A) The Traffic Study is highly inadequate. Highway 101 on the East side of the Olympic peninsula is the only non toll direct connection to the I-5 corridor and is used for all major shipments of goods, services as well as residents and tourism both on and off the peninsula. When serious accidents occur along 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. In the 2007 EIS P.34 Transportation it states. "The County identified 5 specific issues to be addressed as part of the Transportation Review." The very first requirement is the most important. 1.) US HWY 101 The Loss of Service (LOS) data was from the year 2000. The actual car trip count data dates back to 2006. Neither of these are currant in 2014. Transportation Engineering North West LLC states in Responses to Transportation- Related Public Comments received on SEIS Nov.2009 to an HCEC comment, pg. 18 paragraphs 6-7 There is no evidence of unsafe driving or roadway conditions through review of historical collision records or review of general geometric conditions in the general vicinity." While collisions do occur along roadway segments there was no evidence noted to suggest specific review along roadways. If WSDOT or Jefferson County had identified specific "high accident corridor" in the vicinity then a review of roadway segment collision statistics would have been conducted. Absent this determination, this analysis was not warranted." Transportation Engineering of North West LLC did not count accidents in non intersection highway segments. 1 2 3 Three of the most notoriously dangerous sections of roadways are in the immediate vicinity of the MPR . 1.) 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 from Black Pt. Rd. is Mt.Walker Pass. These 3 locations are sources for hundreds of very 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/.../Jtme2012_Impact_Freight_Congestion.pdf) The traffic analysis shows that out of 4100 car trips a day 30%or 1230 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% or 123 cars a day or over a 10 hour period 12.3 cars/hour. 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 passenger van) no adverse impact is expected." This is inadequate mitigation. B.) In a 2013 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 turn 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 equipment 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 ball 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 monitoring must be done and for as long as 10 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 conflict 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 1) C.) During part of the 10 year construction period there will be a full scale gravel and rock mining operation. "This will include excavation, screening of gravel and rock 4 5 6 7 8 crushing." (The) " machinery used will be scrapers, excavators, bulldozers, wheeled front loaders; a portable screening plant, feed-hopper, portable gravel crusher, finishing crusher, water trucks, highway/of-road trucks... conveyor belt systems and vibratory/sheep-foot compactor rollers." This will 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 off site that will increase heavy truck traffic. 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 1415 tons of refuse per year to be trucked 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 enormous negative impacts on the local roads and community due to the massive scale of the project. Garth Mann and Statesman 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. 1.) EMS: In 2013 there were 249 EMS calls per the 797 people of Brinnon (2010 Census) which is 31%. 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 construction 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 long 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'X20' or smaller than a 2 car garage) 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 8 cont. 9 10 11 12 13 14 15 16 dollars per tee time and spa use will be paid to the school district as well as 1 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 same 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 of jobs created. The Average Median Income AMI) in Brinnon is $42,679. The number of jobs created which are At (80% of$42,679. 34,143.) or Below the AMI are 223 people. The conclusion found in Appendix N page 28 based on tables 3-1 through 3-4 (pages 8- 11) 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://pugetsoundsage.org/downloads/Walmart-Fowler-Report-2012-04-06 1- 1.pdf) In Tables 1-20 for all phases of construction these are the total jobs created and annual incomes. 48 jobs are above the AMI ranging in income from $36,000. to $52,914. 108 jobs are from $10,593. to $14,381. 121 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. 16 cont. 17 18 19 20 21 22 In conclusion out of 280 jobs created an incredible 83% are considered Poverty level. See http://aspe.hhs.gov/POVERTY/14poverty.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 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 9% and sent to Olympia of which 6.5% stays there and the leftover 2.5% 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. If the developer stays on as the Property Management Co. or contracts to another multinational 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 replacement 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.fodorandassociates.com/Reports/Destination Resort Impact Studv.pdf Impact of Destination Resorts in Oregon Fodor&Associates March 2009 page 85 If Thornburgh Resort is successful, its developer could make $300 million on lot sales, almost doubling its investment. The lucrative profit potential for 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 Impact 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 22 cont. 23 24 25 providing public services, public infrastructure, and the potential adverse impacts on the community and the environment. The "leisure and hospitality" sector (that includes destination resorts) paid average annual wages 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 Thornburgh 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 four. Most jobs created by the resort will be temporary and when construction is completed, 1,471 jobs will be lost, causing ripple effects 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 lost. 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 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 102 Exhibit 1 RESPONSE TO COMMENTS FROM ROB MITCHELL (Letter # 38) Comment 1 Thank you for your comments, your comments are acknowledged. The Draft SEIS was issued on November 19, 2014, and public comments were due by January 5, 2015; the comment period was 48 days in total. The public comment period provided for the Draft SEIS was in excess of the 30 day requirements identified in the Jefferson County Code (JCC 18.40.780). Please also refer to Response to Letter 3 (Port Gamble S’Kallam Tribe) comment 9. A hard copy of the Draft SEIS was made available for review at the Brinnon Fire Hall. Comment 2 Please see the Response to Letter 8 (Brinnon Group), Comment 15. Comment 3 It is acknowledged that collisions may occasionally occur which close down area roadways. Comment 4 Comment acknowledged. Collision histories for 2012-2014 were obtained for this Final SEIS, for all reported incidents for mileposts 299-301 (Segment 1), mileposts 309.77 (Brinnon Shop Road) to 309.46 (Mt Jupiter Rd) for Segment 2, and from mileposts 312-313 (McDonald Creek vicinity) as Segment 3. Excessive speeding or impaired driving was the reported cause for collisions within these segments of SR 101 for 70 to 100 percent of all reported collisions. Average annual collisions ranged from 1.67 per year in Segment 2 to 3.33 per year in Segment 1. No geometric conditions or other “unsafe” conditions were identified in review of collision history that would warrant further review or impact evaluation. Comment 5 Comment acknowledged. Please see the Response to Letter 8 (Brinnon Group), Comment 32. Comment 6 Please see the Responses to Letter 8 (Brinnon Group), Comment 20, and Letter 10 (Hood Canal Environmental Council), Comment 11. Comment 7 Please see the Response to Letter 8 (Brinnon Group), Comment 20 and 23 and Key Topic 4-2, Saltwater Intrusion in Chapter 4 of this Final SEIS. Comment 8 Please see the Response to Letter 8 (Brinnon Group), Comment 17. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 103 Exhibit 1 Comment 9 Please see the Response to Letter 8 (Brinnon Group), Comment 36. Comment 10 Please see the Response to Letter 2 (Jefferson County Department of Public Works), Comments 2 and 6. Comment 11 Comment acknowledged. As indicated on page 3.15-2 and 3.15-3 of the Draft SEIS, development of the proposal would extensively change the aesthetic character of the site, and the Maritime Village Building would be visible from SR101 to the west. Comment 12 Please see the Response to Letter 8 (Brinnon Group), Comment 2 and Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Comment 13 Comment acknowledged. Please see the Response to Letter 8 (Brinnon Group), Comment 2 and Comment 9. Please also see Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Comment 14 Please see the Response to Letter 8 (Brinnon Group), Comment 9. Comment 15 Comment acknowledged. As detailed in the Section 3.11 (Employment and Housing) of the Draft and Final SEIS, the rent collected by the applicant for employee housing onsite would be affordable (e.g., no more than 30% of household income) as per BoCC condition 63(g). Please also see Key Topic 4-1, Fiscal Considerations, in Chapter 4. Comment 16 The MOU is strictly between the applicant and the School District. Jefferson County only requires a signed MOU prior to approval of the Development Agreement. At this time, there is no estimate on much their arrangement will generate for the School. Comment 17 Please see the Response to Letter 8 (Brinnon Group), Comment 2 and Comment 9. As stated in Section 3.17 (Public Services) of the Draft and Final SEIS, “In order to provide health care services in proximity to site residents and visitors, as well as to reduce the increased demand on Jefferson Healthcare, approximately 500 sq. ft. of clinic space would be provided on site for a Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 104 Exhibit 1 certified nurse and/or general practitioner that would be staffed and equipped by Pleasant Harbor resort.” Comment 18 As noted in the Section 3.11 (Employment and Housing) of the Draft SEIS, one of the BoCC conditions relates to local recruitment and is identified as a mitigation measure for the project:  63 (e) Statesman shall advertise and give written notice at libraries and post offices in East Jefferson County and recruit locally to fill opportunities for contracting and employment, and will prefer local applicants provided they are qualified, available, and competitive in terms of pricing. Comment 19 The Draft SEIS noted in Section 3.11 (Employment and Housing), that “the construction project could directly and indirectly employ up to approximately 1,750 workers in total. The actual number of construction jobs at any given time would vary depending on the nature and construction phase of the project. Construction jobs would be temporary and would be discontinued once construction of the Pleasant Harbor Golf Resort was complete.” The number of jobs per phase was detailed in Appendix N of the Draft SEIS. Section 3.11 of this Final SEIS has been updated to include the number of construction jobs per phase in order to clarify the breakdown of projected constructed employment. Please also refer to response to comment 18 of this letter. Comment 20 The information cited from Appendix N regarding the number of construction and operational jobs at or below the AMI was also presented in Section 3.11 of the Draft SEIS, on pages 3.11-5 and 3.11-8. Comment 21 Please see Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. It is assumed that the majority of operational jobs associated with the project under Alternatives 1-3 would be seasonal. However, the applicant proposes to develop programs to attract year-round visitors to the site, which could contribute towards retaining staff during off-seasons. Comment 22 Comment acknowledged. The number of construction and operational jobs at or below the AMI is detailed in Section 3.11 of the Draft and Final SEIS. Please also see the response to Comment 20 of this letter. Comment 23 Appendix S of the Draft SEIS outlines proposed public amenities for the project. Resort amenities available to the public include: golf course, putting green, driving range, pro shop, conference center and meeting rooms, restaurant and lounge, spa, medical center, beauty salon, wedding chapel, amphitheater, swimming pool, pedestrian trails, bicycle trails and electric Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 105 Exhibit 1 shuttle service. The applicant has indicated that some of these services will require reservations, bookings or give priority to residents and guests. Amenities that are only available to the residents and guests include: tennis courts, hot tub, bocce ball, billiard and game rooms and fire pit. See Appendix S of the Draft SEIS for additional information on proposed public amenities. Comment 24 The comment regarding state and local government discretion over the allocation of tax revenue is acknowledged. Please see Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Construction of the Pleasant Harbor Resort is proposed in four phases (see Chapter 2 of this Final SEIS), with each phase representing a construction cycle estimated at approximately 30 months. Real property in Jefferson County is revalued every two years. The effective date of the assessment is January 1st of the current year. The assessor determines a full or partial value of new construction, or improvements depending upon the state of completion as of January 1st. It is therefore assumed that as each phase of construction occurs, property valuations, and consequently property taxes, for the project site and its improvements would correspondingly increase to reflect the level of investments and improvements that have occurred. Comment 25 Please see the Response to Letter 8 (Brinnon Group), Comment 31 regarding costs associated with long-term maintenance and repair of the wastewater treatment plant. The same response is applicable regarding maintenance and repair of the private water system that would serve the Resort. 1(' t j' 1f` December 3,2014 ti%+- Jia l j GEC 0 211% Board of County Commissioners Jefferson County,Wa.AMU Commissioners: We are writing to voice our opinion on the "Pleasant Harbor Master Planned Resort". We whole heartedly support this project and have for the MANY years it has been going through the process. It is clear to us and should be to anyone that looks at the proposal and the mitigation for the minimal impacts that the developer has gone the extra mile to make this a very positive action for the County. The Brinnon/South county area is slowly dying because of a lack of good jobs and meaningful opportunities. This project will go a long way to bring about positive changes for this area as well as spill over to adjacent communities. We have a very active community that does wonders with what is available but it just can't do it all. This project not only will provide good paying permanent jobs in the long run,the construction phases will generate a tremendous input of income to the county and the completed Resort will provide a much needed increase to the tax base. This process has been ongoing for a very long time. It is now time for the Commission and those in the decision line to GET ON WITH IT and approve the developement. Thank you, z-(/. /'" (--C—' QiiajoL) j(}1A-114---1—• Richard and Sheila Moore 313094 U.S. Hiway 101 Brinnon 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 107 Exhibit 1 RESPONSE TO COMMENTS FROM RICHARD and SHEILA MOORE (Letter # 39) Comment 1 Thank you for your comments, your comments are acknowledged. To the Jefferson County Planning Commission Jan.2,2015 My husband and I have lived in Brinnon for almost 40 years.We have seen many coming and goings in this area with resorts and few have thrived;consider Port Ludlow, Discovery Bay, Lake Cushman, and Alderbrook.They have all gone through owners and changes in plans to try to succeed.We have concerns about the proposed resort and its enormous size of almost 900 units.Our concerns are around the traffic it will produce on Hwy 101 and surrounding roads,the actual jobs and pay, water,chemicals being used and habitat. Brinnon is a very rural community.The 900 units and the people living even it part time will have a huge impact and change the character to being more Port Ludlow than Brinnon. Even when Garth Mann starts out with 250 units the intent and possibility is the almost 900 even if he sells the resort;the potential is almost 900.That is a lot of people and employees during peak use. Is there a contingency fund for if the resort does not bring in money and fails-what happens to the land and vacant buildings- left to decay as with past owners?Can the size of expansion be reduced if the property is sold down the line? The other concern is who is going to come to Brinnon more than once?You visit it on the sunny day and think it is lovely( which it is but it has more rainy days) but I do not really see than coming back during the rainy weather which is more often than what Port Ludlow or Port Townsend experience. Rain is not conducive to golf. Brinnon is several hours away from the airport and is only accessible by Highway 101 unless they go by boat.There are resorts that are much closer with nice amenities;especially,when you consider the time it takes to get to Brinnon. People might come for shrimp and crab and that will deplete that resource even more. The traffic concerns were seriously, not adequately addressed in the DSEIS.The statistics are out of date. They only looked at intersections and not where the accidents usually occur which are corners and Mt.Walker. Hwy 101 is blocked for several hours or more depending upon severity of accidents. It can be totally closed. It is a two lane windy,twisty, narrow road with few turnouts or passing lanes if traveling south.Traveling north is Mt Walker with several twisty turns and then going south to Brinnon is a bad stretch for accidents. Having the road blocked for several hours has a severe impact on local people who travel for groceries, medical reasons and for work. Putting traffic lights will not address these areas.Who will pay for the road maintenance and traffic congestion relief? I suspect that the local taxpayer will bear the burden for unforeseen changes caused by the resort.As for busses from the airport,wealthy people do not wait for a bus. I don't think they travel by bus.The traffic study is still using old data for it statistics of how many people will increase travel on the highway. My other concern is the increase of traffic on the Duckabush Road where there are several hiking trails. It is now the only access point to the Olympic Mountains since the Dosewallips road slide.The county has never fixed the problem correctly and it appears to be a costly project to do so.We have experienced heavy traffic on weekends and nice weather months. It is an even narrower road in spots and speed limit signs do not seem to be noticed.r= 11 JAN - ..j I I t„i C,, rY O v a ,r1v1 Pj 1 2 3 4 5 As for jobs,the study is very clear that the applicant must be qualified. I am sure that there are local people interested in working but may not be qualified so many local people will not be hired. Training did not seem to be offered. Most of the jobs listed will be below family wage jobs so that there will still be a high rate of poverty. I also think most of the jobs are seasonal, minimum wage,and part time. It could leave more people added to the community in poverty,on Medicaid,and straining the limited local resources. Most construction jobs will go with the large company that is hired to build the resort. They might not hire locally. Who is going to fix and repair the highway after all the trucks-remember it is a million cubic yards of dirt being moved; have traveled it multiple times?Who pays for that? Water is a huge concern as it is one of our most precious resources that developers have little concern. We have seen enough floods and dry months to know how fickle weather is in our almost 40 years living here.With the almost 900 units,think of how many toilets will flush,showers,laundry,and the golf course usage-how many gallons of water will it take before the aquifer is depleted and salt water intrusion occurs? The salt water intrusion burden Is upon the well owner and costs will probably be on the well owner to use the resort water.Will it also give the resort access to their property if the water lines are theirs? I can't imagine wealthy people wanting to ration their water usage but the property owners will due to having to pay for water and limited water due to depletion. Water quality for the Hood Canal is also important. It was said that there were going to be holding areas for affluent but what happens when that overflows during a heavy rain?What happens to the contaminated water?Golf courses and surrounding grounds are able to use nastier chemicals than non business people can get.Craig Peek stated that they would be natural but that is extremely VAGUE.The potential to have these run off into the Hood Canal are possible.And the Hood Canal also offers many family wage jobs in seafood industries. It is a livelihood for many and recreation for others.Who will oversee this? The MPR has a lot of amenities but limited use or none at all for locals.Trails are accessible but where can a local person park?They would want you to use their store and restaurant but the prices are likely not affordable to locals and that is what they need to succeed during the wet weather months. I think there is the potential that local businesses might lose business to the resort.The health clinic is behind the locked gate so it is not accessible.Where will the trucks with trailers 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 that the resort is starting small with 250 units but the potential to grow to the full capacity is always there unless you can change that. Perhaps maybe the almost 900 units ends with this MPR and isn't part of a future sale. It is just out of character for such a rural area. Other issues should still be addressed before this goes forward. Also there is in the plan to have a road to the marina through the Harbor House which has a trail use only due to their septic system being there. What will happen there? With still many concerns. Sincerely;J 1 1 4 \\ l I II William and Roxianne Morris r I,;'I . hJANPUL . 6 7 8 9 10 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 109 Exhibit 1 RESPONSE TO COMMENTS FROM WILLIAM and ROXANNE MORRIS (Letter # 40) Comment 1 Thank you for your comments, your comments are acknowledged. Rural character, transportation, employment and wages, water and habitat issues were evaluated in the Draft SEIS in Section 3.2 (Water Resources), Section 3.3 (Plants), Section 3.9 (Transportation), Section 3.11 (Employment and Housing), and Section 3.12 (Rural Character). See these sections of the Final SEIS for further details. Comment 2 Under SEPA rules (197-11-450), it is not required, nor is it necessarily appropriate for environmental review documentation to analyze the financial or market feasibility of a proposal. Comment 3 Thank you for your comments, the opinions expressed in this comment are noted. Comment 4 Please see the Responses to Letter 8 (Brinnon Group), Comment 15; Letter 9 (Friends of Miller State Park), Comment 8; Letter 10 (Hood Canal Environmental Council), Comments 19/20 and, Letter 38 (Rob Mitchell), Comment 4. Please also see Key Topic 4-1, Fiscal Considerations, in Chapter 4. Comment 5 The original Transportation Impact Study – Revised, Pleasant Harbor EIS, Jefferson County, WA, TENW, August 28, 2007, evaluated traffic impacts onto Duckabush Road and at the intersection of SR 101 and Duckabush Road and found no substantial or significant traffic impacts would occur due to the project. As such, the Pleasant Harbor Resort would not be required to address any real or perceived existing roadway deficiencies noted in the comment letter. WSDOT historical counts on SR 101 at Duckabush Road, indicate approximately 2,800 average daily trips (ADT) in 2006, with most 2014 data indicating a drop in overall use to 2,200 ADT. As such, overall ADT remains approximately 20 percent "below" those levels evaluated in the SEIS. As such, traffic or use of Duckabush Road also remains at or below previous levels evaluated. In 2006, ADT on Duckabush Road was estimated at approximately 350 daily vehicles at SR 101. Recent traffic counts completed by Jefferson County indicate ADT of approximately 415 daily trips. With a traffic capacity of up to 4,000 vehicles per day, the current traffic volumes on Duckabush Road are being generated at approximately 10 percent of its total traffic carrying capacity. As a worst-case scenario, the SEIS assumes that 2 percent of all project trips travel on Duckabush Road, representing approximately 3 percent of its total traffic carrying capacity. As such, no significant adverse traffic impacts are expected to occur. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 110 Exhibit 1 From a recreational standpoint, the Duckabush Road provides access to many trails that serve the Brothers Wilderness area and Olympic National Park. Trails that access The Brothers Wilderness (Source: USFS Website) include:  Lena Lake Trail #810 - This trail is 3.6 miles to the junction with The Brothers Trail and is considered moderate.  The Brothers Trail #821- Accessed from Lena Lake Trail #810, this 3 miles trail provides access to popular climbing routes to The Brothers. It is considered easy to difficult.  Duckabush Trail #803 - This trail follows the Duckabush River and enters Olympic National Park at 6.2 miles. It is considered easy to difficult.  Mt. Jupiter Trail #809 -This difficult 7.9 mile trail provides access along Jupiter Ridge to Jupiter Lakes. This trail is hot and dry during the summer months. In total however, there are nearly 50 different trail heads that serve the greater Olympic National Forest. The Duckabush Trail follows the Duckabush River into The Brothers Wilderness and enters Olympic National Park at 6.7 miles. There are several camps along the trail Access to the trails requires a Recreational Pass and for overnight camping requires a Wilderness Access Permit. There is parking for approximately 36 vehicles at the trailhead. Expected use by Pleasant Harbor guests would be limited to day use. The Pleasant Harbor resort shuttle is expected to have scheduled times for drop-off/pick-up for access to the trailhead on a request basis only. During peak summer months, this could generate up to several shuttle round trips per week or weekend, reducing overall project traffic impacts to trip generation and parking demand at the trailhead. Comment 6 Please refer to the Response to Letter 38 (Rob Mitchell), Comment 18. As noted in the Draft SEIS, the majority of earthwork (grading) would occur within the site. Section 3.9 (page 3.9-9) of the Draft SEIS states that trucks “would typically be limited to less than 50 trips on any given day. Best management practices would be implemented by contractors during construction, including necessary on-site truck wash facilities or oversized load transport routing and operations.” See Section 3.9 of the Final SEIS for more information on construction traffic impacts. Comment 7 Comment acknowledged. Water availability and proposed usage have been evaluated and accepted by Ecology. Please see the Response to Letter 10 (Hood Canal Environmental Council), Comment 13. The analyses have shown that the Resort would use a small percentage of available water and that the risk to existing domestic well users on the Black Point peninsula is low. In the event that the Resort were to supply water to a neighboring homeowner, that would not give the Resort rights to uninvited access to the homeowner’s property. Please also see Key Topic 4-2, Saltwater Intrusion, in Chapter 4 of this Final SEIS. Comment 8 Comment acknowledged. Measures are proposed to deal with an overflow of Kettle B, including an overflow pipe constructed between Kettle B and the smaller kettle to the south (Kettle C). Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 111 Exhibit 1 Also, the impermeable liner to be installed in Kettle B would not extend to the top of the pond side slopes. Overflow water could enter the liner trench and infiltrate site soils at this location. During the winter months when heavy precipitation events of extended duration would be most likely to occur, it is anticipated that occupancy at the Resort would be down, with the result that a reduced quantity of wastewater process effluent would be entering the retention pond at this time of the year. Comment 9 Comment acknowledged. Parking for local area residents who would like to visit and use the amenities of the Resort would be available in the Maritime Village and bus turn-around area adjacent to Highway 101 (see Draft SEIS Figure 2-8). Pleasant Harbor Marina and Golf Resort representatives have been in communication with the Washington Department of Fish & Wildlife (WDFW) regarding options for improving parking for vehicles with trailers on shrimp days. The concept being discussed (but not yet finalized at the time of this writing) is for Pleasant Harbor Marina and Golf Resort to construct an overflow parking area on WDFW property for boat ramp users. Two clinics are proposed within the Resort, one within the Maritime Village, and the other within the Golf Course Resort complex. Both would be accessible to the public as the "control gate" shown on Draft SEIS Figure 2-8 would not be a locked gate. Please also refer to Response to Letter 38 (Rob Mitchell), Comment 23. Comment 10 Details related to improving the Marina Access Drive shown on Draft SEIS Figure 2-8 (that would coincidentally improve access to the Harbor House) were still being resolved at the time of this writing. Portions of the existing vehicular access trail at this location are already paved (though the pavement is old), as this was the former alignment of Highway 101 past the site. The Harbor House septic system is not located beneath this trail. Section 3.9, Transportation, of the Final SEIS has been updated to clarify that construction of the Marina Access Drive is contingent upon negotiating an easement across private property, and that additional trips would occur on SR 101 if this easement cannot be negotiated. David W. Johnson From: Miriam Murdoch <miriamclaire@embargmail.com> Sent: Monday, January 05, 2015 10:52 PM To: David W. Johnson Subject:Pleasant Harbor Master Planned Resort To Mr. Johnson; I have been a resident of the South County for 11 years, having moved out from the east side of Bellevue to live in a quieter environment. Many people I have met out here have done the same, appreciating the pristine beauty and lack of noise and pollution. I don't have any scientific data to give you, Barbara Moore Lewis has covered much of that, but I can tell you that everyone I talk to about the resort feels it is too big of a plan for this area, taking in traffic and environmental issues, and the fact that it will be of little benefit to our community, serving mainly to put money in the pocket of Statesman Corp. I know you feel economic development is good for the south county, but the size and scope of this resort does not fit. The traffic already gets congested in the summer months on 101, a road that has no room for expansion, and a resort of this size will only complicate matters. I ask you to consider some of the conditions outlined in Ms. Lewis' letter. Thank you, Miriam Murdoch P.O. Box 33 Brinnon, WA i 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 113 Exhibit 1 RESPONSE TO COMMENTS FROM MIRIAM MURDOCH (Letter # 41) Comment 1 Thank you for your comments, your comments are acknowledged. Transportation issues, including potential impacts to SR 101, were evaluated in Section 3.9 of the Draft SEIS. See this Section of the Final SEIS for further information. Please also refer to the Response to Letter 8 (Brinnon Group), Comment 15. TO: David Johnson, Jefferson County Department of Community Development FROM: Gary & Pam Myhr, 40304 NW Brown Dr, Woodland, WA 98674; myhrs@icloud.com; 360 560 7616 cell CC: DATE: December 17, 2014 RE: Pleasant Harbor Master Planned Resort Draft Supplemental EIS – Public Comment Period We are property owners with address – 560 Rhododendron, Brinnon,WA., in the Pleasant Tides subdivision. Recently, I (Pam) spoke with you briefly at the open house held Dec. 3rd at the Brinnon Community Center regarding the proposed development. Our comments/concerns with respect to the development: We are in favor and look forward to completion of this planned resort and believe it will benefit the larger Brinnon area. We have two concerns: 1)Black Lake Rd is a rural road that is used frequently by people walking and bicycling (most from Pleasant Tides subdivision) There will be substantial traffic increase from the development as its main entrance is very near the entrance of Rhododendron Rd and the subdivision. We request: As part of the Black Pt. road upgrade that will occur anyway, the road between the resort main entrance and Hwy 101 include marked and adequate firm/wide to keep car/walkers/ bikers safely separate. No need for a fancy separate trail - - just need for well-defined road vs. shoulder and adequate firm shoulders and width. 1 2 2)There is no access allowed for guests of the resort to access the beach. It is our understanding that the local tribe requested this restriction to protect the Duckabush estuary. We assume their concern is difficulty of keeping people out of their shellfish beds. However, complete “no beach access” is extreme and impractical. There exists a very large development in Mason County? called Hartstene Pt. It too is near tribal shellfish beaches, is a very large development with steep cliffs, and has beach access that has been compatible with the environment. Accessing a true beach and being able to walk along it is a huge draw for a resort and its guests. Having the beach and no access is an attractive nuisance. Because Pleasant Tides subdivision is the only community beach within walking distance of the resort, it could become a nuisance policing issue for the subdivision. Neither the subdivision nor the community park/beach are gated. Other adjoining beach property owners may find themselves affected. “No beach access” creates a safety issue as well. Resort guests will find their way down to the beach by forging makeshift trails. It is completely impractical to expect the resort to barrier the entire upland frontage. We propose the county with the developer address the attractiveness of the beach in a pro-active manner that considers the tribes and other beachfront owner concerns. The most southeastern resort shoreline is largely outside the estuary/shellfish area. Within this area, our suggestion is that a walking path be cut down to the beach with “no further beach access” controls denoting end points of allowed beach frontage use. A return loop path exiting the beach back to the upland could join internal resort walkway or path and be an attractive addition to the resort. This proposal doesn’t have to be elaborate but it could make for a nice, interpretive path regarding the canal and environment. Please allow for an attractive, safe access to some portion of the resort shoreline. The marina can’t provide this. Where there is a beach - - access is a huge tourist draw and expectation. Limit, control, and allow is best for all parties. David, would you please confirm you have received these comments. Thanks - 3 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 115 Exhibit 1 RESPONSE TO COMMENTS FROM GARY and PAM MYHR (Letter # 42) Comment 1 Thank you for your comments, your comments are acknowledged. Comment 2 The comment refers to Black Lake Road, however, no known road exists in the immediate site vicinity. For the purposes of this response, it is assumed the comment is referring to Black Point Road. As part of the project, Jefferson County is requiring a roadway upgrade between SR 101 and the proposed main entrance near the Rhododendron Road vicinity. The roadway section will not, however, include a shoulder wide enough to accommodate a multipurpose trail as County standards do not require such a facility. An extensive separate trail system will be provided throughout the project site which would provide for an independent and parallel non- motorized travel separate from vehicle conflicts along Black Point Road. Comment 3 As noted in Section 3.6 (Shorelines) of the Draft SEIS, public access to the shoreline would be limited to the marina area, where the more intense uses are anticipated and public facilities are available to safely accommodate access. Public access to beach area is proposed to be restricted to maintain the natural condition of the bluff. David W. Johnson From: Newsom, Miriam B <miriam.newsom @providence.org> Sent: Tuesday, December 02, 2014 9:34 AM To: David W. Johnson Cc: diane @pleasantharbormarina.com Subject:Pleasant Harbor DSEIS Dear Jefferson County, My family and I just purchased a boat slip in Pleasant Harbor Marina. A major part of our decision to moor our boat there permanently was the incredible consideration for the environment, management of the marina and the proposed growth in the resort/golf course. We currently reside in Tigard Oregon.We have a vacation rental in Hoodsport that one day would like to retire to. During our quest to purchase a boat we have visited many marinas. We can wholeheartedly say that Pleasant Harbor was the cleanest,friendliest and well managed marina we have come across. It is a beautiful setting and a great place to be.The growth potential for Pleasant Harbor will give it even more appeal and provide enjoyment for all that visit and live there. I truly believe that the proposed growth will not take away from this beautiful setting, but will add some extra perks that will enhance the environment and enjoyment for all who visit. I am usually not a fan of large resorts and enjoy the smaller, quainter settings, but the way this marina is approaching this expansion is incredible to see.The attention to detail, the concern for the environment and the incorporation of the surroundings gives this project our full support. We truly believe that Pleasant Harbor can expand, enhance the local economy all while keeping the feeling of a quaint harbor. It will keep us coming to the marina and we look forward to enjoying a few rounds of golf, do a little shopping and enjoy some great food soon. We would have liked to attend the December 3rd community meeting, but due to residing in Tigard, Oregon, we were unable to take the time off work. Please share our comments with all at the meeting. If you have any questions feel free to contact us Joe and Miriam Newsom 10500 SW 71'ave Tigard, OR 97223 503-575-6255 Miriam Newsom RN, MSN RN Coordinator-Clinical Education Neonatal Intensive Care Unit Providence St.Vincent Medical Center 9205 S.W. Barnes Road Portland, OR 97225 t: 503.216.5430 p: 503.301.0095 f: 503.216.3304 miriam.newsom@providence.org This message is intended for the sole use of the addressee,and may contain information that is privileged,confidential and exempt from disclosure under applicable law,If you are not the addressee you are hereby notified that you may not use,copy, disclose,or distribute to anyone the message or any information contained in the message.If you have received this message in error,please immediately advise the sender by reply email and delete this message. 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 117 Exhibit 1 RESPONSE TO COMMENTS FROM MIRIAM NEWSOM (Letter # 43) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: Gerald C. Olson <jerryo @donobi.net> Sent: Friday, November 21, 2014 10:14 AM To: David W. Johnson Subject:Brinnon Resort Wish that we could be there for your meeting to show our support of the project. We live in the Olympic Canal Tracts and do SUPPORT this project. Jerry and Susan Olson 361 Mountain Trail Ro. 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 119 Exhibit 1 RESPONSE TO COMMENTS FROM JERRY and SUSAN OLSON (Letter # 44) Comment 1 Thank you for your comments, your comments are acknowledged. To: Diane Coleman[diane @pleasantharbormarina.com] From: jporrico @outlook.com P1;" Sent on behalf of: Joseph P. Orrico Sent: Invalid Date Importance: Normal Subject RE: Update for Pleasant Harbor Marina &Golf Resort project MAIL RECEIVED: Invalid Date Diane, We cannot attend the meetings, but wholeheartedly support the PH project. You can put my wife and I down for two (2) votes in favor of the development. We look forward to some pleasant- no pun intended - visits to the marina next boating season. It is probably our favorite marina on Puget Sound/Hood Canal. By the way, we will be out of town for the Seattle Boat Show, so will not see you there this time. Joseph& Krystyna Orrico 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 121 Exhibit 1 RESPONSE TO COMMENTS FROM JOSEPH and KRYSTYNA ORRICO (Letter # 45) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: Morgan Oslake <oslake @yahoo.com> Sent: Monday, January 05, 2015 9:29 PM To: David W. Johnson Cc: Morgan Oslake Subject:Proposed MPR on Black Point David Johnson Department of Community Development Jefferson County,Washington State Dear Mr. Johnson, I am writing regarding the proposed Master Planned Resort(MPR)and golf course south of Brinnon on the Black Point peninsula along Hood Canal. After reviewing the MPR options, I would like to register my preference that the resort proposal is *not* approved and that no action is taken. My primary concern is environmental impact including forest clearing, natural habitat loss, pollutant risks to Hood Canal, well water stress,and increased traffic. I own a home in Brinnon and am very supportive in seeing the Brinnon area thrive and be a vibrant community, but I do not think that the resort and golf course is the right path toward that goal. Sincerely, Morgan Oslake 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 123 Exhibit 1 RESPONSE TO COMMENTS FROM MORGAN OSLAKE (Letter # 46) Comment 1 Thank you for your comments, your comments are acknowledged. Plants and vegetation, water and transportation issues were evaluated in the Draft SEIS in Section 3.2 (Water Resources), Section 3.3 (Plants), and Section 3.9 (Transportation). See these sections of the Final SEIS for further details. Also, based on Draft SEIS comments and additional factors, an additional Alternative (Alternative 3) has been added for analysis in the SEIS. Alternative 3 includes a 9-hole golf course, and increases the amount of natural area retained on the site. Overall, approximately 103 acres are proposed to be maintained in natural areas under Alternative 3, or 45 percent of the site compared to approximately 31 acres (13 percent of the site) under Alternative 1 and approximately 80 acres (35 percent of the site) under Alternative 2. David W. Johnson From: kirie pedersen <kirie.pedersen@gmail.com> Sent: Sunday, January 04, 2015 9:49 AM To: David W. Johnson Subject:Public Comment on Black Point DSEIS Attachments: DSEIS PROPOSAL COMMENTS_2015.docx Attention: dwjohnson @co.jefferson.wa.us From: Kirie Pedersen, M.A. 687 Pulali Point Road Mailing address: PO Box 687 Brinnon, WA 98320 360) 316-9066—cellular To: David Johnson Department of Community Development Port Townsend, WA 98368 Re: Proposed Pleasant Harbor Golf Course and Resort DSEIS Date: January 3, 2015 Greetings, I am a lifelong Brinnon resident. My family has lived on Dabob Bay since 1946. I was born here, raised here, and pay taxes here. I know the environment and community from participating in it and observing it over six decades. Over the past several years, I have attended numerous meetings regarding proposed resort development at Black Point. I have also conducted hundreds of hours of research into this and previous proposals for Black Point, and studied similar proposals and completed projects and their impacts on existing communities in the San Juans, Clallam County, and elsewhere. My particular concerns with the current Black Point 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, fire danger, and the statistically high risk that taxpayers will bear the burden of this development and/or its potential for failure. 1. 1 I am deeply concerned that this proposal was handed out for public comment over the Thanksgiving through New Year's holidays when many area taxpayers are out of the area or involved with family and guests and challenging weather conditions. The timing of this public comment period makes it questionable as to whether we, the public, were even offered adequate time or opportunity for review. Due to my family's, neighbors' and my own dependency on wells, I have in particular conducted research on well water availability and safety throughout the area, including Black Point. Sea water intrusion, 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 produced as to potential negative impacts of extremely high water use as proposed by this proposed intensive development and golf course. The proposal as put forth fails to meet county goals for improving tourism revenue for South County, and in reality could adversely impact tourism revenue for South County. 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 traffic, cars with families or people on our way to work,to be stuck on Mt Walker for seven hours. This is only one accident to completely close access to the area. The only other option for access in an accident or larger disaster is by air. Air transport of the injured or to investigate or fight fires often ends up being at public expense. When we had a forest fire here a few years ago, huge crews were housed in Brinnon around our fire station, and some 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 fire 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 enforcement to Brinnon often involves hours of delay, which means that dangerous situations aren't addressed in a timely way. Private security on the resort itself doesn't address peripheral issues that will arise due to the changing demographic such a massive change to our community will entail. Our attractions in South County are the forests, parks, camping, hiking, shell fishing, and relative serenity of a so-far fairly undisturbed shoreline and adjoining forests. This area is already clogged with tourists in the summers. Ironically, these same features also offer the U.S. Navy, a large area employer, the conditions required to conduct myriad 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: 1) deposit the amount of all ascertainable direct and indirect costs regarding services and infrastructure into a fund available to local government to cover the costs as they are incurred, and 2) furnish a performance bond issued by a highly rated insurer to cover all potential costs that cannot be ascertained beforehand, including repairing any environmental damage incurred over a 50 year period because of the development and the costs of cleanup and restoration if the project is started but abandoned. 2 8 7 6 5 4 3 2 Thank you for your consideration of my comments. Respectfully submitted, Kirie Pedersen 3 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 125 Exhibit 1 RESPONSE TO COMMENTS FROM KIRIE PEDERSEN (Letter # 47) Comment 1 Thank you for your comments, your comments are acknowledged. Transportation , water, shoreline, public services, and housing and employment issues were evaluated in the Draft SEIS in Section 3.2 (Water Resources), Section 3.6 (Shorelines), Section 3.9 (Transportation), Section 3.11 (Employment and Housing), and Section 3.17 (Public Services). See these sections of the Final SEIS for further details. Please see the Response to Letter 8 (Brinnon Group), Comment 2 regarding the bonding the project. Also please see Key Topic 4-1, Fiscal Considerations, in Chapter 4. Comment 2 Comment acknowledged. Please see the Response to Letter 3 (Port Gamble S’Klallam Tribe), Comment 9. Comment 3 Please see the Response to Letter 10 (Hood Canal Environmental Council), Comment 13, and Key Topic 4-2, Saltwater Intrusion, in Chapter 4. Comment 4 Comment acknowledged. Please see the Response to Letter 9 (Friends of Miller State Park), Comment 8 and Response to Letter 38 (Rob Mitchell), Comment 4. Comment 5 The comment regarding law enforcement response is acknowledged. As indicated in Section 3.17 of the Draft SEIS, Jefferson County conditions for project approval require that the project developer negotiate an agreement to provide support to Brinnon area service providers, including police service. Regarding the potential to change demographic character of the area, as indicated in Section 3.12 of the Draft SEIS, new development on the Pleasant Harbor site would contribute to cumulative intensification of land uses in the area. Please note that it is anticipated that many resort employees would live in on-site employee housing, thereby reducing the potential of new employment contributing substantially to demographic changes in the area. Comment 6 Comment acknowledged. Impacts to rural character were evaluated in Section 3.12 of the Draft SEIS. Refer to this section of the Final SEIS for further details. As stated in this section, development on the Pleasant Harbor site would result in new residents living on the site and new residents and employees traveling to and from the site each day. At full buildout, proposed residential uses are anticipated to house approximately 556 permanent residents and resort operations are anticipated to employ approximately 190 people, 208 of whom are expected to live onsite in the 52-units of staff housing; resulting in a total of 660 permanent residents on the site. In addition, the resort would also accommodate visitors for day trips and overnight stays Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 126 Exhibit 1 (in 560 units). The increase in site population, site visitors and employees would result in increased activity levels, including pedestrian activity and vehicular traffic travelling to and from the Pleasant Harbor site and within the site. Comment 7 Thank you for your comments, your comments are acknowledged. Comment 8 Please see the Response to Letter 8 (Brinnon Group), Comment 2 regarding the bonding the project. David W. Johnson From: Lynne Robinson <lynnerpt @live.com> Sent: Saturday, November 22, 2014 4:59 PM To: David W. Johnson As members of the Pleasant Harbor Yacht Club, we are very excited about the expansion plans. Lynne Robinson and Dan Watson 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 128 Exhibit 1 RESPONSE TO COMMENTS FROM LYNNE ROBINSON and DAN WATSON (Letter # 48) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: commtech.us @gmail.com on behalf of Mark Rose <mark @markrose.org> Sent: Monday, January 05, 2015 10:56 AM To: David W. Johnson Subject:Brinnon SEPA Acomment Attachments: Brinnon SEPA comment.docx Pasted below and attached -thank you. From: Mark Rose. 687 Pulali Point Road Brinnon, WA 98320 360-301-2600 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 15 years. 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 and/or its potential for failure. 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 course. I remain deeply concerned that this proposal was handed out for public comment over the Thanksgiving through New Year's holidays when many area taxpayers are out of the area or involved with family and guests. This 1 1 2 3 4 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 over 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. Respectfully submitted, Mark Rose Mark Rose http://rebelmouse.com/markrose/ http://about.me/markrose 2 4 5 7 6 8 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 130 Exhibit 1 RESPONSE TO COMMENTS FROM MARK ROSE (Letter # 49) Comment 1 Thank you for your comments, your comments are acknowledged. Comment 2 Potential transportation impacts (highway use and road safety), water quality and shoreline impacts were evaluated in Section 3.9 (Transportation), Section 3.2 (Water Resources), Section 3.6 (Shorelines) and Section 3.7 (Critical Areas) of the Draft SEIS. Please see these sections of the Final SEIS for further details. Please also refer to Key Topic Area 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Please see the Response to Letter 8 (Brinnon Group), Comment 2 regarding the bonding the project. Comment 3 Please see Key Topic 4-2, Saltwater Intrusion, in Chapter 4 of this Final SEIS. Comment 4 Comment acknowledged. Please see the Response to Letter 38 (Rob Mitchell), Comment 1. Comment 5 The comment regarding tourism is acknowledged. Please see the Response to Letter 38 (Rob Mitchell), Comment 4 for a discussion on traffic safety. Comment 6 Thank you for your comments, your comments and preference for the No Action Alternative are acknowledged. Comment 7 Please see the Response to Letter 8 (Brinnon Group), Comment 2 regarding the bonding the project. Comment 8 Comment regarding previous marketing material is acknowledged. Please refer to Response to Letter 40 (William and Roxanne Morris) for a discussion on financial and/or market feasibility. David W. Johnson From: Dave Sadler<davypQq.com> Sent: Sunday, November 23, 2014 9:59 AM To: David W. Johnson Subject:Pleasant Harbor project Mr. Johnson 1 ant a 1png tme slip o -nee at Pleasant llarbor Marina. I have aI gays Wished that some positive developinorits would be allowed in the.Brinnon area and am happy to finally see this type of development being persued. Brinnon is a ve=ry economically depressed area and is in need of sonic capital investments that will bring jr_ a ;tu*;'.;,+, : ate more tourism to the area, Several years ago my wife and I bought some land near Brinnon-inthe hopes of building a house there. After owning the property for several years and seeing-little in the way of economic development occurring we sold and bought a piece of land in Sequirn. We built a home here and now happily live in Sequim. Our wishes to build and have a home in Bnnnon were never realized because we could not see any changes by the county government to allow much in the way of economic- growth. It seemed as though the ounty planning commission and government officials preferred the status quo. 'This attitude seemed to come from a philosophy which wished to keep things the way they are for some reason I never quite understood. Some of the local people I had spoken to indicated that the county government officials had an agenda that appeared to see the area as a place they wished to leave undisturbed. The Pleasant Harbor management and some other would be developers were apparently denicd=permits to develop they property_eata tereially and from,what: understand most have given up their plans. In today's poor econoniic'environment it would seem that the county officials would Welcome development. I would very much like to see the county become more interested in promoting the highway 101 corridor as a destination attraction rather than a corridor to travel to the Ol rnpic Peninsula or the ferry to Victoria, BC. Please read this note knowing that I have little personal economic interest in the area but-have seen for-years the area as a gem in the rough. I support the plans for development as proposed by the owners of Pleasant Harbor. David P. Sadler 453 Louella Heighfs Drive Sequim, WA 98382- 6686 davvp ci q,00m 360-683-4115 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 132 Exhibit 1 RESPONSE TO COMMENTS FROM DAVID P. SADLER (Letter # 50) Comment 1 Thank you for your comments, your comments are acknowledged. To: Diane Coleman[diane @pleasantharr i- -i,..From: Dave Sadler i I , Sent: Invalid Date 1, Importance: Normal Subject: Re: Support of development DEC 0MAILRECEIVED: Invalid Date fThanksDiane N 'I i ,r? ';Ki I am truly in hopes that the hearings go well. I know that in the past some of the county officials had a problem with developments in the Brinnon area. I'm not sure I ever understood their reasons except that they frowned on much of any kind of economic investments that would promote tourism and yield jobs and a more positive image for those who investigate the idea of settling there. If my memory serves me correctly there have been several folks interested in staring businesses in the area only to be denied permits and or zone changes required for those businesses. Several years ago my wife, Carol and I, bought land near Brinnon in the hopes of building a place there. One of the reasons we did not was due to the fact that there were few services available and shopping was a nightmare. If we would have wanted to do some shopping we would have had to drive many miles to do so. We also felt that given more services and attractions in the area more people would want to have boat slips and make the area more inviting to visitors. The marina has been moving slowly to add attractions for transient boaters but as you know their is very little in the way of attractions for them to want to visit. I see what the marina owners doing as a very positive improvement for the area. I wish I could attend the hearing meetings to give my opinions but that isn't possible right now. I can only hope that all of those in favor of proposed improvements will be sufficient to convince those who make the decisions to support the move for the golf course and any other proposed developments. David P. Sadler Slip A-19 davyp( q.corn 360-683-4115 1 2 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 134 Exhibit 1 RESPONSE TO COMMENTS FROM DAVID P. SADLER #2 (Letter # 51) Comment 1 Thank you for your comments, your comments are acknowledged. Comment 2 Thank you for your comments, your comments are acknowledged. Jan 051509:53a p,1 lefl IWHITNEY GARDENS & NURSERY, LL.0 1 .-- P.O. Box 170, 306264 Highway 101, Btinnon, Washington 98320-0170 Fax Transmittal Form 1 Name: e '4i%a X ! Organization Name/Dept: PzZ.,a/ 7-4 Phone number: Q Fax number: __47/ - GZ- lie.. o f/7/_j n/ 1Name: .- I Phone Number: (800) 952-2404 11 - f I , 5 '015 llFaxNumber: (360) 796.3556 Email: info@whitneygardens.com 11141Y Web: www. hitneygardens.com r(JMf iUP111Y DEVELOPMENT 7 4 7 M 7Comments: %%-:' 1 iXi-F-/V --77- z.--"eewd/i/j/ 4--- 7---s ie2(--2; ' 7/u,, - c5: //e,C=42,c/ g, 7 lam' / Og<5.047,-- . 5(9 ./cC OZ ,e30-,C-1-/V 7- 1' 1 ogZ 270/x'7' yip 7- /4 (57,-.0L, 00(7. 7-79/ /---e 712/,5 4L cn :- / 77/v... Jan 0515 09:53a p.2 Seattle investors buy closed Semiahmoo Resort in Blaine - Puget Sound Business Journal Page 1 of 3 Cities Business Directory Book of Lists Upstart Business Journal Bizwomen Contact Us Sign In Like on Facebook Follow on Twitter Follow on Linkedln Follow on Google+ Puget Sound Business Journal Search Home News People Events Jobs Resources Store 31: Subscribe NOwLimited Time Offer Sign Up to receive Puget Sound Business Journal's Morning Edition and Afternoon Edition newsletters and breaking news alerts. Enter your email i Sign Up Seattle investors buy closed Serniahmoo Resort in Blaine Jun 21, 2013, 3:43pm PDT Share on Google + Share on Facebook Share on LinkedIn Share on Twitter Email this article Save Order Reprints Print Staff Puget Sound Business Journal http:l/www.bizjournals.com/seattle/news/2013/06/21/seattle-investors-buy-closed-semialun._. 1/2/2015 Jan 0515 09:53a p.3 Seattle investors buy closed Semiahmoo Resort in Blaine -Puget Sound Business Journal Page 2 of 3 A Seattle-based ownership group on Friday purchased the shuttered Semiahmoo Resort and its still-open golf courses in Blaine for $19.5 million, the group announced. The resort, located at the end of a spit in Blaine's Drayton Harbor, was acquired by Resort Semiahmoo LLC. The ownership group includes Seattle- based Wright Hotels Inc. and Seattle investor Jerry Anches. The Coastal Hotel Group, also based in Seattle, will manage Semiahmoo and its two golf courses. Hints that a deal was in the works surfaced in late May, when the Coastal Hotel Group advertised two job openings at the resort, The Bellingham Herald reported at the time. The Upper Skagit Indian Tribe held a majority stake in the previous ownership, Semiahmoo Resort Co. LLC, which shut down the resort in December after failing to find a buyer. The two golf courses have remained open. Wright Hotels President Stuart Rolfe, in a statement, said his team hoped to refurbish and reopen the resort"before the end of the summer season." In its press release, the ownership group said it plans to invest"a significant amount of capital" in the property. The ownership group's intentions could be welcome news in Blaine, which was sent reeling when the resort closed late last year, eliminating more than 200 jobs. Semiahmoo's new owners have a history of collaboration. Wright Hotels and Anches in 2009 were part of a group that bouaht the Cedarbrook Conference Center in the city of SeaTac from JPMorgan Chase. Cedarbrook is also managed by the Coastal Hotel Group. Related links: Sports, Hospitality Industries: Travel, Commercial Real Estate We Recommend Promoted by Taboola 34 5 0 t.. . Ir F.. http://www.bizjournals.com/seattlefnews/2013/06/21/seattle-investors-buy-closed-semiahm... 1/2/2015 Jan 05 15 09:54a p,4 HP Officejet Pro 8800 N911 g Series Fax Log for Jan 03 2015 10:13AM Last Transaction Date Time Type Station ID Duration Pages Result Digital Fax Jan 3 10:11AM Fax Sent 13603794451 0:00 0 No answer N/A Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 136 Exhibit 1 RESPONSE TO COMMENTS FROM ELEANOR SATHER #1 (Letter # 52) Comment 1 Thank you for your comments, your comments are acknowledged. Please refer to Response to Letter 40 (William and Roxanne Morris) for a discussion on financial/market feasibility. V U I I VV 1VVJ.TJU N• ' WHITNEY GARDENS & NURSERY, LLC 57/-P.O. Box 170, 306Z64 wa 101Highway Brinnon, Washington 98320-0170BY B Fax Transmittal Form Name: i 642a(79/ CY#,I r/7 Organization Name/Dept: / 4 _ie . /Zg , zs Phone number: Fax number: 7f.- q 57 Name: G E,4 Z Phone Number: (800) 952-2404 11 v r Fax Number: (360) 796-3556 L Email: infoCwhitneygardens.com i JA11 - 5 2015 IwWeb: ww.whitneygardens.com Page: r can uNmo Jry Commen EVELOPMENT ogs AMILK.‹9c=c ems 7 C Wie /DAY PEIe ieLe)""ald/94 bc- 6 ./( .7 meeffzzx 0/cf . p,g4g,,e/c/ c5'r/17 t1: - " fiilt, yee)a/64 ( / / . (: - '°/ ' fil"- 71-7i7 late. p/W. 7--//e_ 8/4Z(7a Lz. y v F-r ter' ; ' 4 &, -f 1/4-0E 1 L ,__.E „1---Ve)/ 0 ,$a5' (1/I 7---- c5- 7 f7e- -- 5- ---.L 77-4/44 - m, 4wirii,„,, 1 vun vv i I v.I.-taa Per capita water use.Water questions and answers;USGS Water Science School Page 1 of 2 usGs scisnce for a changing world The USGS Water Science School Search... 11 Search 4- Back to previous page Water Questions & Answers How much water does the average person use at home per day? Estimates vary, but each person uses about 80-100 allons of water per day. Are you surprised that t e largestuseo household wwr water is to flush the toilet, and after that, to take showers and baths? That is why, in these days of water conservation, we are starting to see 11 toilets and showers that use less water than before. r Many local governments now have laws that specify that water faucets, toilets, and showers only allow a certain amount of water flow per minute. Water agencies in some areas, such as here in Atlanta, Georgia, offer rebates if you install a water-efficient 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 faucets, if you look real close at the head of a faucet, you might see something like "1.0 gpm", which means that the faucet head will allow water to flow at a maximum of 1.0 gallons per minute. NOTE: Our data here is very general in nature...just to give you a quick idea of your water use. There are some other Web sites that will give you a much more detailed and accurate estimate of your per-capita water use: WECaIc CSGNetwork Southwest Florida Water Management District Typical water use at home Bath A full tub is about 36 gallons. Shower 2-2.5 gallons per minute. Old shower heads use as much as 4 gallons per minute. Teeth brushing <1 gallon, especially if water is turned off while brushing. Newer bath faucets use about 1 gallon per minute, whereas older models use over 2 gallons. Hands/face 1 gallon washing Face/leg 1 gallon shaving Dishwasher 20 gallons/load, depending of efficiency of dishwasher http:/Iwater.usgs.gov/edu/ga-home-percapita.html 1/212015 Fey capita water use. Water questions and answers;USGS Water Science School Page 2 of 2 Dishwashing by 4 gallons/minute for old faucets.. Newer kitchen faucets hand: use about 1-2 gallons per minutes. Clothes washer 25 gallons/load for newer washers. Older models use about 40 gallons per load. Toilet flush 3 gallons for older models. Most all new toilets use 1.2-1.6 gallons per flush. Glasses of S oz. per glass water drunk Outdoor 2 gallons per minute watering U.S.Denartment of the Interior I U.S.Geological Survey URL:http://water.usgs.gov/edu/qa-home-percapita.html Page Contact Information: Howard Perlman Page Last Modified:Thursday,23-Oct-2014 12:30:25 EDT http://water.usgs.gov/edu/ga-home-percapita.html 1/2/2015 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 138 Exhibit 1 RESPONSE TO COMMENTS FROM ELEANOR SATHER #2 (Letter # 53) Comment 1 Comment acknowledged. Please see the Response to Letter 8 (Brinnon Group), Comment 28. Water supply calculations were performed according to the maximum occupancy scenarios planned for the Resort. Jan 05 15 09:59a p.1 1 WHITNEY GARDENS & NURSERY, LLC P.O. BoxBox 170, 306264 Highway 101, Brinnon, Washington 95320-0170 Fax Transmittal Form Namerffe`51()/C/ I° s / ft7d__/7/77/7°All V/ 1; -4/.E6S21f.49– Organization Name/Dept: t i(a7"T 47 tit. Phone number: Fax number: gecg7f- cKs-,, 11 1 JAN - 5 .2015 t Name: Z-E/ °c5.1-7-172'61e-- Phone Number: (800) 952-2404 r; 0, 01i ITY 1..!) C 'dvillNIP?DEVFLOPA s Fax Number: (360) 796-3556 e,e ei./50-4. 'r Email: info@whitneygardens.com 7' Web: www.whitneygardens.com Page: / Comments: i 7- . . /1- 777,6z7. --0 COgYEXI ge'Qll-se-D 1 cVM/e4D//1 gcC197-- 1 1/1///eN /.. .C' 7: igacL ylv 1 aLE L- 0/)7 i & c=Chik 1 7-&26,-A,/ rp- (c=5K/66V(-a/. e-,--c-c) /-1 Liml - lee-C-02-77 ti0V -- ,. 1 y g , ----/ilg-S aza. 1 -. ( c5.54-1/7e- fr, G_ L.02.. AL go 1 z597-77/ e7-7-/E-c,,s7,0ipt0 z000LD W E 1 Jan 0515 09:59a p.2 Suncadia Resort- Cie Elum, WA I Yelp Page 1 of 19 Find tacos,cheap dinner.Max's Near San Francisco,CA LOG In Home About Me Write a Review Find Friends Messages Talk Wants Yelp= Suncadia Resort 78 reviews Dacus SSS • Hotels,Day Spas,Golf,Resorts ' Ed't a jj Trailtead corr arnr uns• 1' Yap date+20tsgeogkt 3SODSuncadia Trail Edit i u.-.A,4.F !r Cte Elum,WA 98922 M 11GelC4•eckons rimer 509)649.6400 Message the business 1/.4-4 r-'',.. e-° .so,- 4 * suncadiaresort.cor ISThe Portals restaurant located in the Lodge is pricey but well worth the money,I think."in 6 rev ews Make a Reservation Friday,January 2.2D15 t Awesome indoor/outdoor pool complex for the kids with water slides" 7:0 f pm: -.2 fide in i reviEws VI " There is also a town nearby(Roslyn)which has some cute shops and Reserve a tablet for 4 today restaurants.'in 7 review_ Book a Room Recommended Reviews Search reviews Yelo Sort Jane Rating Ekes English TB View offerings Yrs&trust Is our top concern,so businesses coat pey b alter o•remove(heir reviews.Learn more -' '$$SS Price range Pricey Edit business info h. . Kelly C. 12/26/2014 f. - Seattle.WA 271 friends 1 cheolt•ct Hours 27 rwiews My husband and I stayed here for Christmas 2014 and It Offerings was awesome.We wanted a close getaway for the holidays without spending too much SE.Even though there was no Skillet Breakfast Potatoes................4.00 snow,Suncadia offered SO much to do to keep families of House Made Elk Breakfast Sausage all ages and types entertained during the holiday.Even the 6.00 spa was open co Christmas,and we were able to enjoy a VERY relaxing couples massage right before dinner(they Bison Burger... ...................19.00 even offered us a complimentary glass of proseccol)It was View all ef'srmgs one of the best massages I've ever had. Though not everything was operating"normally"--Portal's More business info wasn't serving breakfast Christmas morning,and the candle lighting ceremony Christmas eve was cancelled,the Accepts Credit Cards Yesore staff went above and beyond to make it a cozy Parking Private Lot environment We enjoyed the hot tub while sipping on hot Bike Parking Yes cocoa and there were several families in the lodge's living room hung out until late at right while one e the girls from Wneelcliair Accessible Yes the front desk payed Christmas songs on the piano.Thee Good for Kids Yes was also an ice skating rink around the corner and each 1M_Fi Free night the Lodge had a smore bullet next to a 6repit for itiffl http:liwww.yelp.comlbizistutcadia-resort-cle-elum 1/2/2015 Jan 0515 09:59a p•3 Suncadia Resort- Cle Elum,WA I Yelp Page 2 of 19 anyone to enjoy.By Appointment Only Yes Since each loom has a kitchenette,you could make a AIt D longer slay out of it here.too--there's a Safeway just 10 First to review minutes away,along with coffee stands,bars(which are open 3n Christmas!)and anything else you might need. Suncadia's definitely one of those rare hidden gem's that People also viewed worth way more than its value--just be sure to ask a lot of Lodge at Suncadia questions before you arrive to make sure you bring everyteirg you need(especially since the weather can it reviews REALLY be a wlldcard.) Fist Gass resort,first class staff great food,views and commemity. Ili Amanda S. r, - Suncadia 1223/2014 Redmond.,Wa 18 review; e friends 1 c-eck-in Love the lodgefrooms and the 9 reviews view is killer. First major downer is that the resat isn't connected.You t r have to take a shuttle from your room to the pool,spa,or Swiftwattr Cellars any activities. 47 rev me Swiftwater Cellars at Suncadie The only thing included here is the wifi. is superfab. Want to slide down a(fake?snow covered hi?$20 A pop. Browse nearby Want to ice state?315 a pop, Restaurarts.Nightlife,Scooping.Show at Ware to ice a gingerbreadnouse?$35 a pop. People Viewed This After Want to have hot tea in the lodge?$25 a seat. Searching For... Want an elf to tuck your kid In?$20 per kid. Cross Country Swing Cie Elum Things To Do Cle Elum Want your bed made?Not sure it it costs extra.but I assume it must as our room was never made up once despite housekeeping being always on the floor. Want to go swimming?Wear a wet suit We were charged, but when the lifeguard on duty is wearing a full on coat to keep warm,you can understand why no one was In the icy water. Want to eat?Rob a bane We reverted the menu first and learned that if we ordered conservatively, wen spend$65 on breakfast.$80 on lunch and$120 on dinner.We tried breakfast and it was lackluster at best and service was an absokte-joke*.Had to ask to be seated and had to ask for our food twice.The closest off property restaurant is 20 minutes each way. The mom was nice,the view was spectacular. But no way we're ever coming back. iw• s Diana J. 124412014 Bellevue Wa 41 friends Oh boy,wish I could be writing a review about my 1 review experierce.but unfortunately I cannot because the resort never responded back! 12-1-14: We called-10pm to book a room as we had seen Suncadla's Cyber Monday deal on the website and were very excited as this was for a special occasion.We were planning to bring my dog(a Slih-Tzu,small dog of 10Ibs) and asked if we could book a room that was pet-friendly. The website claims that this'Ss'a pet-friendly hotel so we had already done our ter).The receptionist told us that she didn't know which rooms were pet-friendly(huh?)and would need to confirm with someone who would get back to us the next day.Before we hung up.we specifically asked that they make a note that we could have booked the room with the Cyber Monday rate had the receptionist known which rooms were pet-friendly)and would want this rate when they find us a pet-friendly room. http://vlfww-yelp.com/biz/stmcadia-resort-cle-elum 1/2/2015 Jan 05 Sfuicadia 1509:59a Resort- Gle El p.4 ton, WA I Yelp Page 3 of 19 Guess what,no one called back,nor the day after... I sent an email the next day(12-2-14)outlining cur phone call and what we had agreed with the rep.We still haven't heard back—No one has yet to give US any updates on what is available,or availability of pet rooms,or anything. Crickets. Not sure who is managing customer service requests,but the fact that ro one is responding to phone call inquiries or emalls says a LOT about the resort.I don't need to go there to know that guest service is NOT a top of the mind priority there... r John a. 0©0©© 12/2412014 Edmonds, 33 fends 2 check-ins 31 rrvlewe I love this place what a great suit with a amazing view kick up my feet and turn on the are rid lime to relax.I love the hobdaysl t a BM P.' g401,-A r OP Blaine H.12r90/2014 k'. Seattle,WA r o rnends V high prices for medo re food.This is par for course at 2 reviews rntn ledges.But deception in menu is a new and insulting twist.Menu says'maple syrup'with$14 French toast.But the syrup is cheap corn-based trudose.When asked about the deception,servers look uncorfodable.Bedsion to bait and switch obviously made by business school sharpies who bet that parents are too exhausted to notice the con. Kenneth A 1012'12014 ifiii r4Col_- Las Angeles,CA 31n xrds This s a great resort_Although ifs out in the middle of 16 revsi•s nowhere and what the h"I,its nice.The views are amazing.The rooms are spacious,clean and very tunctonal.My room has a full kitchen,washeridryer, fireplace,balcony with furniture.etc.I wish I could stay longer and just relax The big shower and tub are nice as well.The staff is pretty friendly and knowledgeable.In a state that can be cold(weather wise and"Seattle Freeze,' this location warms up to everyone.I will be back. http://www.yelp.com/bizlsuncadia-resort-cue-elum 1/2/2015 Jan 051510:OOa p,5 Suncadia Resort- Cle Elum,WA I Yelp Page 4 of 19 n,..r sot See all photos from Kenneth A.for Suncadia Resod 31I 1 Tami H. j 9/1/2014• Kirkland,WA Epfe 14 Suncadia is...Su needle. 19he cs 150 reviews What's great about Suncadia: Huge range cf lodging options from hotel to condo to 5000 square foot homes Beautiful scenery Great golfing Reasonably good dining fSwif valer cellars which is not officially part of the resort is the best) Awesome indoor/outdoor pool complex for the kids with wafer slides Bike trails galore Vihthln 9D minutes of Seattle What's not so great about Suncadia: Service is spotty. It seems like either its a featly busy weekend and There's not enough staff,or ifs a not so busy weekend and there's not enough staff.:) Now,service has improved since a couple years ago and seems friendlier and more accommodating. But They still seem overwhelmed on busy holiday or summer weekends. Maintenance Is sketchy.The architectee,condosfhomes are beautiful,but stuff always seems to be broken/not h:nctoning, Not major things,but the little things you notice- Pricing is crazy overpriced as they have a captive audie ice That said,the resat is certainly maturing and every time we go there is more infrastructure.better service,and more dining and activity options.For example,this summer they had a'chill and grill'by the pod which was great,though not sure how often that is in service. By far the best option is to rent one of the big homes with tots of ramifies.Some of the homes are truly amazing with incredible amenities.decor and space. Definitely a great vacation for those in the Seattle area-- not sure I'd travel further than that as there are probab y better options like Star River in Oregon. http://www.yelp.com/bizisuncadia-resort-cle-elum. 1/2/201 Jan 0515 10:OOa p.6 Suncadia Resort- Cle Elum, WA I Yelp Page 5 of 19 Zagreus A. 5/17/2014 Camas,W 18 friends 1 check-m 85 rsenws This is a regular stop due to an annual medical conference. Always enjoyed a well run luxury hotel but this time something changed! Broken tiles in front of the conference center and dead plants.I observed a poor configuration for the conference with a 2rd groups lunch in front of our conference office, restricting the flow for our group to get back to the main building and the bathrooms.Just plain dumb planning.I suppose I should be happy they make a phone call to make sure everything is right in the room.How much more effort woub it be to make sure it was right in the first place.It is not rocket science to make sure there is soap in every roc m. Get a bad of the center pieces at lunch.I suppose a coal lamp is cute.but it looks like it was designed by the 3rd grade class at the kcal school. Lien I originally called for a reservation,they were sold out fcr the.2nd night,but I rarely worry at these conferences;someone always cancels.Most of the time I just ask to be put on a wait list IN course.1 didn't get a call, and later found out at least six colleagues had cancelled, so I could have altered my arrangements accordingly. The problem here is that this is supposed to be a top rank luxury hotel,but the level of service and attention to detai evident in this trip was at a level of a Motel 6. Vey important the line staff was awesome.My criticism is directed at leadership.Enable your people to do what they are here for and don't pinch around true edges-We the customers notice,especially at this category of hotelt r. f t .. 4'. 1 f Jennifer M. 12/7:2014 tle,Seat WA C rr ends Summary.you should come here if you want to enjoy the 22 revw s beautiful outdoors and eat your own food. Pros:the room was very nice;it was actually a suite which I wasn't expecting.The surrounding area is beautiful.I loved the views of the evergreen forest and mountains. Cons:plenty They really don't seem tc be into answering the phones and returning calls here.This was a Theme throughout the http://www.yelp.corn/biz/suncadia-resort-cie-elum 1/212015 Jan 0515 :OOa P,7 Sunca10dia Resort- Cle Elam,WA( Yelp Page 6 of 19 weekend. Spa:after calling several times and leaving messages days before we arrived we got appointments for massages and facials.I called when we arrived to confirm the times,but no one answered the phone.I left a message and no one returned my call.Allen we got to the spe we found that they didn't have our reservations.Fortunately.we were able to get new ones for different times. Food:it you're vegetarian the food options are dismal. There was almost nothing I could eat.I ordered a vegetable platter for lunch off the kids'menu,and when it arrived I was disappointed to fird it covered in parsley.They also put their"big dirt/'spice,which I didn't like,on everything. incuding mixing it into the hummus.Both of those are a matter of personal taste,of course.but you should be aware that they may surprise you with unnecessary additions.The food's also overpriced.I recommenc bringing your own fooc if you're vegetarian;the kitchen.Is well-stocked with cooking supplies.If you're vegan, definitely bring your own food as there will be nothing to eat. It looks the several landslides have happened recently_ Make sure to visit before the lodge falls off the hill. Joshua B.3/17i2014 t? Seattle.WA Elite'14 3 check-ins 396 Irieres 550 reviews Decided to have a small family getaway last winter and planned the trip to Sircadia after hearing great things about it from a few friends.We generally enjoyed ourselves here,but I cant say I was overwhelmed,and its very expensive for what I feel like you get and the service was hit-or-miss. The room itself was great.We had a two bedroom and it was way more space than we needed.Great to be able to cook and eat in the suite it steed of eating out all the time, especially with little kids. Since this was winter they had a few wintry activities.The ice skating was like 515:person fcr a tiny rink,the pool is fun if your kid can swim(asp the slides)but not huge and I can imagine very crowded during normal season.The restaurant is overpriced and fine.but the service was melt. Even the sledding hill was fun,but they charge you per ride,so I just!e:my kid go most of the lime. I can't really get over the idea that this is a resort that nickles and dimes you with a"resort fee"and per-sledding charge,when there's nothing else to do. Also,no:realy their fault,but it was rainy/cart snowing.so in the winter twat means you're stuckir the lodge,or in the small pool...not much else to do,which considering this is billed as a huge resort is a bummer. Really wanted to like this more,but just couldn't.Maybe well give it another shot in the summer or next winter because it'd be nice to have an option to get away to for a few cays that daear't involve flying. Tanya S. 9/1/2014 r Edmonds,WA 139 fiends 1 aleck-in 195 reviews I nave to say that I don't after write negative reviews,so I dont take them lightly.. This review is based on two experiences:once.for a bachebrette spa weekend getaway for my beslie and most recently,for the lack of Jhttp:/iwtivw_yelp.com/bizJsuncadia-resort-cle-arbor 1/_/201 dijil° Jan 051 510:OOa p.8 Suucadia Resort- Cle Elum,WA I Yelp Page 7 of 19 customer se rvicelresponse 10 my own wedding Inquiry. Last year,I arranged for a small bachelorette weekend getaway for my bestie. Spa was great,wine tasting in the lodge relaxing,beautiful grounds,and a so-so dinner at Portals. All in all,it was a nice getaway and customer service was sufficient. On Jt.h,91h of th.s year,I called and left messages on the customer service line requesting information for possibly planning my owl wedding in Suncadia in August 2015. filled out the online request form on this date. I never heard back,despite a second voicemail. No calls returned,no email response. Today,I received notice that we need to close our request date.as the decision deadline I posted is coming up tomorrow. Leaving two voicemaiis and using their designated information request service online,you would think you would get some sort of response... especially in recant to a high budget,high stress event such as a wedding. Apparently,SurK.cadia does not regard a potential wedding as a worthy event to respond to. I wal not be returning. Kelly W. t 7:_ •.._.. i--iygeab.. : ' 4ai 4/2512014 Longview,WA 1s tnema We stayed here while my husband attended a convention. 10 revievrs The rooms are nice!!recommend getting a suite.Ours had a full kitchen.washer/dryer,tub and shower,balcony.It was perfect!The food al the lodge is fantastic,and at the bar you can bring drinks back to your room.I needed a later checkout(typically 1 tam)and the man at the front desk graciously'et us check out at 1prn. I would have given 5 stars except when I took my son to the park I didn't see the parking lot,and parked just off the side of the road.A parking officer nearly Issued me a ticket for"parking on the vegetation:.I guess vegetation means gravel al suncadia. iie. 1,' Or '..,, .. Leslie R. 1/3/2014 Monroe,WA L11rrnos Schack-ins 82 rSv,e.vs We had high hopes when our family booked Suncadia to celebrate the New Year,but the cost of the enmities and poor customer serv.ce was a huge disappointment Pros: Accommodations: We stayed at 440 Larkspur Loop in a beautiful house, heated floors,hot tub outside w/disco fights,modern kitchen,modem bath,remote control to turn or the gas toe place.comfortaNe furniture,high ceilings,satellite 1'VNJ- e http:/.fwww.yelp.com/bizlsuncadia-resort-cle-elum 1/2/2015 Jan 051510:01a p.9 Suhcadia Resort- Cle Elora, WA I Yelp Page 8 of 19 Fi,etc. Resort Shuttle: Many of us used the resort shuttles which pith you up and drop you off where ever you need to be very convenient. It made getting around the resort much easier than having to navigate the area ourselves Viiew. The surrounding area is beautiful being located in the foothills of the mountains.There are a number of gorgeous hiking veils. Cons: Accommodations: Just a little note to folks staying in the master suite at 440 Larkspur Loop who are staying in this house ve small children-don't be surprised to hear the sound of pitter- patter of feet going up ano down tine halls as sound travels across the whole house. Challenging to Navigate: Many of us had a challenging time folding our way around the resort due to poor signage and at night due to lack of lighting and hard to se&locate house numbers which are not visible when it gets dark. Limited Restaurant Options: If you don't plan on cooking you have very few options to eal out In the area. You have the Lodge or the Winery or by your luck as one of the few places in town. Overall it was our family who made the time we spent here wonderful...red time we'd probably consider other options. rF`-:DES r."- -' 1 tTALS rr s.. EliBetsy W. j,...:, : .. 11/26/2014 mill Creek.WA 30 fri •ds 2 check-Ins 34 reeve's I don't know what the cost was for rooms,food,sic.This review just details my experience with lodging 47 the lodge, Meeting facility and food,the bar,and the fitness facility. The rooms were large w living space that included a http://www.yelp-com/biz/suncadia-resort-cle-elum 1/2/20150 Jan 05s1 5 uheadi10: 02a a Resort- p.10 Cle Elum,WA I Yelp Page 9 of 19 fireplace.I wish the fireplace had been In the bedroom though.Also,there were some scratches on the wall and pulled up wall paper.Basically,some minor details I think they could improve upon.The banquette food was certainty nothing out of the ordinary. I had two breakfasts,a lunch, and two dinners:here and not one thing was memorable. The one thing I will give them is some very friendly frontline staff.From the bellmer to the bar tenders they were all great young people.The fitness center was impressive.it just seemed to take awhile to get shuttled from the lodge to the fitness center which was necessary alter dark with the sidewalks frozen over.The view in the entryway of the lodge is lovely.Overall,a very nice place.If you are looking for a feeling of seclusion and relaxation I could see how this would be a rice place to visit SOC P.6!12/2014• Tacoma.WA 2 f:ierds Not the same caliber of qua ty and class as when it first 15 reviews opened.At least 5 trays of old room service meals in hall leading to our top floor room.The old trays remained in hell overnight creating a hazard...Health and tripping as our 14 yr old did!While"relaxing"by pool at ii am,man w blower zoomed his loud and dust-dispensing machine by our lounge chairs twice!No relaxing nor fun to get`ace ful of dirt.Why cant the blower guy get his work done before pool opens?Mc,after calling ahead to confirr water slide operation,we arrived to find slides are only open weekends because they"can't afford to pay lifeguards weekdays'. After coming to Suncadia w friends and family for the past 4 years,well look For a new,quieter,cleaner meeting spot to vacationl Max!'. r Fi.IIZeiil3:vi br.1/ _. , 9/29;2D14 a Issaquah,WA 39 friend, I was here for a business offsite.It was a great location to 32 reviews be out of the city's distraction_A great oasis from the hustle of the city. Beautiful views of Pacific Northwest.Roams were very comfortable and sizeable,there is nothirg much to do outside of the resort but the resort itself offers a great variety of activities and the restaurants in it are also gooc. Nice people and certainly has a distinctive lodge atmosphere Chris O.Coil' 9/14,'2013DI '.._jiiii Kirkland,wA Elite'14 Pros: 12 rr enrs Large,beautiful rooms with mini-kitchens and views. 250 reviews Peaceful. Great pool area with watersiides. Nice weather compared to Seattle at least when we were there?2 times now). Lots of biking trails. Probably good for kids. Cons Really expensive. Banquet toed is mediocre. 2 nights.maybe 3 tops is the right amount. I hear Village Pizza in Roslyn is very good. Mol li M. 4/26/2014 Renbn,riA y f .! 30 friends 1 check-in 12 reviews Stayed through an amazon local deal and what a deal it was.Eve yone was friendly and helpful.Portals food was good•little pricey but it is a resort.Bison burger,lobster Mac 2 must to order_Lots of activities indoor pod with awesome sides.free campfire s'more night and desert http://www_yelp.com/biz/suncadia-resort-cle-alum 1/2/2015 Jan 051510:02a p,11 Suncadia Resort- Cle Elum, WA I Yelp Page 10 of 19 buffet Lots of hues,biking,golfing and extra things like horseback riding.Definitely would come back again. i Bison •so o.•Y 1v See all photos from Holl M.for Suncadia Resort E Julie F. O©©©© 1-!312013 sosfaa,WA sfriends We love this place! Got married here at the Inn at 4 rev iews Suncadia last year and are here again for our anniversary. Staff are always awesome-happy and helpful. Place is beautiful:rustic and refined at the same time. Portal's Restaurant is delicious whether we are eating dinner or breakfast They are great if you need gluten free options. too! Look forward to coming back every year to celebrate our wedding anirversary! And love seeing all the dogs here too! 4401 Brad R_ r i 711712013• Boada,WA 1s floods What a great place to spend tie weekend with the family 2so reinsws and friends_ This Is the uber fancy of mountain resorts. Beautiful majestic views of the mountains,valet',and river. The interior is representative of the big mountain lodge of Montana,luxury suites,nice swimming pool,and huge fire pits for roasting marshmallows_ I visited during summer but I imagine its just as amazing all year around. Despite being deep in the forest,this aini roughing it by any means. I was rare on a business retreat and was amazed by the conference rooms,great rood,and open areas. Well designed,great layout,and Interior. I loved all the historic photos of the founding families of Cle Elum. The views from the lounges were pretty incredible. Nice comfy couches and big fire places like that of a hunting lodge. Only thing lacking was good beer. This is the Pacific Northwest and with the effort they put into serving great food,they ought not to skimp on good beer and wine. Trey need to include some good Seattle micro brews like Fremont IPA,Schooner Exact,Elysian,Reuoen's,Diamond Knott,Sound Brewing,7 Seas Brewing,Fort George Brewing,HUB,and Rogue just to name a few. For irph ://ww. el ,cotn/biz/suncadia-resort-cle-elum 1/2/2015rtPwYP Jan 05 1510:02a p,12 5uncadia Resort- C1e Elum,WA 1 Yelp Page 11 of 19 travelers,you need to provide that unique local experience and its not there yet w 2G 6 Jessica R. Lacey.WA p mends Sunradia is a beautiful resort,we stayer 2 nights at The 20 relaa.vs Lodge and it's a great hotel with stunning views.Like many of the other reviews we were disappointed with the dining options-the food is good but WAY overpriced and the service was mediocre at best.Roam service for breakfast was a good option since it's essentially the same price as eating at the restaurant. We ventured Into Ce Elum for dinner one night and are glad we did. Steve the concierge was very helptu-and we booked a sleigh ride and snowmobile trip Through him Both were really fun,though When we checked out the snowmobile tour was$160 more than planned.They fixed the charge but had we not been diligent about reviewing the bill we could have been charged quite a bit more. It was a nice experience and I'm glad we stayed but due to the over the top cost we likely won't return.• Adrian S.9120,2013- Updated review Olympia,WA Erse'14 I'm here for a couple of days,and t like it I've been here ie friends several times Pros Gorgeous location,nice facilities, 235 rev'ews beautiful golf courses,wonderful spa,good restaurants. Cons:Can get crowded,families with bud kids(not a con if you're a famiy with road kids),and business mini- conventions.Tip:Specify that you do NOT want a handicapped bathroom(unless you need one).This seems to be a common bait and switdi.All in all...very nice. 10.02010 • Previous review http:ilwww.yelp.com/bialsuncadia-resort-ele-glum 1/2/2015 5/1 Jan 0515 10:03a p.13 Suncadia Resort- Cle Elum, WA [ Yelp Page 12 of 19 We had a great time at Suncadia this weekend.I would warn people upfront that this probably isn't... R,ad more Kristin F. 92/2014 Seattle WA o friends Came here for a corporate event and had a great time. 2•eviews Rooms were nice and well equipped,food was delicious, and al the staff were gracious and incredibly helpful.In fact.the primary mason for my review is that I left my jacket in a golf cart and the pro shop and front desk staff kindly shipped it to my office. Now that's service! Vifll deenitely be going back with my family. 1011 Stacya S.20412014 Seattle,WA 16 friends I spent my birthday here at the Trailhead Condos. We 5.6 reviews slayec three nights on the 3rd Moor,a one bedroom.and our friends were on the second floor. I would do this again! It is the perfect way to get away from the city without roughing it or camping.which I do riot do. Tne surrounding area is beautiful,which is a little sad because you know that the more they develop here,the more trees and natural beauty will be destroyed. That sad,they seem to be doing a pretty good ob of preserving what is left,which is a loL I hope it doesn't turn into an actual planned community, which is the only negativethlrg I will say.Our condo had a very useful kitchen,which was important to me. It is fully stocked,and the oven and stove top are gas not cheesy electric burne is.The bed is comfortable,and It was quiet. I think for people that work for themselves,or have flexible schedules,coming on the week days as we did instead of weekandswo:rlc be more peaceful. Also.our friends took their two dogs_and we took our large dog Chester_ it is a wonderful place for people who want to take a break with their best friend! It costs ST5.00 extra for each night to bring our cog,but it was well worth it and would have had to pay a dog sitter if we left him behind. Plus,the dogs made the trip more Fun. I can imagine it is a popular Family place during school holidays and summer,which 1 probably would never book then. But we had a wonderful,peaceful time. We cooked bring your own food,foodies,because there is only a Safeway in town,an you will want to bring your own groceries)which I love to do on my holiday,sot appreciated the full size apptances. There is also a washer and dryer. The'back yard'of our condo was the golf course,which was covered in beautiful snow so we had fun h king back there,and the Pont yard leads to a gorgeous bail. We also used the sauna and steam room at the spafgym,and the hot tub. It was perfect,on a Wednesday,not crowded at all. We never ate out as we love cocking,so I can't speak to the places there to eat,but heard they are pretty good. t think for people who really want to"rough it-this place would seem very resort-y,but guess what? That is what it is. A resort. Probably best to do your research when you plan your getaway,you know? Thumbs up from my group. Sarah 10/1312C12 Issaquah WA Elite'L'. Some friends and had been talking about this place for 173 friends forever and we finally made it down to visit. 696 reviews First off,the fall time is the best time to come here.The foliage changing is absolutely breathtaking ano the crisp temperatures make the hiking more bearable. My husband booked a one bedroom sui:e on the river front which was just an incredible room.The views themselves 7http:Nwww.yelp.cornlbi7Jstzncadia-resort-cle-eltun 1/2!_015 Jan 0515 10:03a p.14 Suifradia Resort- Cle Elum, \VA I Yelp Page 13 of 19 were worth it atone.We had a oanoremic view of the mountains,river,and skyline.lncrediblel The room came fully stocked with a decent-sized bedroom, a living room,dining room,fully stocked kitchen.,and washer and dryer.Probably not necessary for the one night that we were there but definitely a nice to have The cneckinicheck-out prccess was a breeze,valet was reasonably priced,(58 something?)and the service was above average.We were greeted everywhere we went, doors held,the works. The hotel has some nice hiking trails on site-we opted for the Mort one down to the liver which was about a mile each way.Tile river was beautiful and well worth the walk There is also a shuttle to the various sites within the Suncadla community-there are a toe of amenities including a fitness center,a trout stocked pond for fishing.a winery,restaurants,and a spa There is also a town nearby(Roslyn)which has some cute shops and restaurants. Room was a little pricey but well wonh it-around$350 or so per night?Would be more worth it lf you were staying for multiple days. Such a fun place to come for a relaxing retreat! V Debbie W. 63,so, 7/26+2013 Kent,WA Elite'14 I eneck-in 21 Mends 177 revaus We have always found the staff here to be over the top when it comes to customer service.The concierge Steve is a gem when it comes to recognizing your special events and providing little treats in your room.We love to bike riding in the summer,swimming in the outdoor pool, hanging out in the huge outside iacuwzi or playingon the water slides. Wintertime,you will find us snowshoeing the groomed trails an the golf course or swooshing down the Inner tubing hill(and being pulled back up by the tube tow/) Lots to do and lots of fun to be had beret Desiree H.8i5/201a Bothell,WA friers The golf course is beautiful and the atmosphere of the 12 revivers lodge is pleasing but the service is so poor.Allison in customer service and Brandy in he Portals restaurant were the most helpful people on the whole property.I find it amazing that so rreny people have 4 star ratings for this resort.They need a lot of staffing work.A bar tender actually put Ice in a glass I had been drinking out of and then dumped it back into the big ice bucket wharf I reminded him"no ice"Every meal I have eaten here has taken 2 hours.Not because of me but because of hors slow the service is When you order a drink anywhere but the actual bar the wait staff bring the order to the only bar and 1 have watched repeatedly white the bar tenders leave the orders waiting 20 minutes while they procrastinate making the drink,tidying napkins.drying glasses,etc.I am not being fickle here either,the bar was dead with only me sitting at it while this happened.Its not until the poor server comes back and asks if the drinks we done yet a second or third time that they actual leave the bar.I have waited 30 minutes for a drink.Room service takes twice as long as the expected time.There are no vegetarian options,I had to custom order everything and feel like a total snob doing so because the lack of consideration this place has for anyone who doesn't eat beef.pork,hricken or anything with tees_The valet lost my car keys in front of me Slimes before I even entered the resort•he set them down in odd f h w+rttp://ww .yelp.com/bithuncadia-resort-cle-elum 1/2/2015 I Jan 0515 10:04a p.15 Suncadia Resort Cle Elum,WA i Yelp Page 14 of 19 places and then asked me for them 3 limes.I lent my car worried he would lose my only key.The valet and staff are friendly but useless,anything I have asked them about the area and events has led me to walking on with no ansvrer. Basicaly if you have any sod of schedule or vegetarian lifestyle this place will be an inconvenience.You can't trust their staff to serve you and allow you to make tee time or events on lime.Plan meals 2.5 hours ahead of anything you might have planned.Seriouty. Kathy W. t, 11/2612013 y1 . Seattle,wA i;mll mil liai Fts 4 ( 3!nerds Overall,I had a great experience here.l'm not a big 23 renews outdoorsy person.so the resort is set in a just enough nature"for my taste.There are trails for you to go an and fa Mastic views-It's a good overnight stay for a quick get away from the city.The Portals restaurant located in the Lodge is pricey but well worth the money,I think.The portions are generous with fresh ingredients.The chili I had there was the best I ever had with huge chunks of tender:cin and prime rib cuts.The place is very clean,the customer service is noticeably lacking just a bit given the resort is an expensive one.Receptionist was distracted at check in.and the barista seemed offended when we told her to update the drinks menu since they no longer offer coconut mile_It's also a very kid-friendly place. Jim M. 5131!2013 Moses take,WA 1 freed Service at bar isterribleT' - 42 reviews Grea-food but if you aren't a twenty-something yuppy or an old man chasing a young lady then plan on waiting for service Save your money for something in downtown Roslyn and don't spend your money here t CommentCoent from Karen P.of Suncadia Resort ausinees Owner 6/672013 • Thank you so much for sharing your Thoughts regarding your latest experience in our lounge with the... Read more Amy J. ammo©-.x1/2014 Seattle.WA o mends We had a FANTASTIC three nights four days at this 1 renew magical place. Our third time here and eacn f me,we seem to enjoy it more-great for kids AND adults- So much fun with the pool,the slides,the snow hill,the iceskabng,tie lounge lounging&game room,hot tubs,hiking trails and more! Great hotel room and house-keeping service. We were very impressed with the manager of The Portals Restaurant&bar,John. He took extra caret attention for my father(who was in a wheel chair)and gave us the royal treatment. He was also very family-friendly with our young children. What a nice guy who went above and beyond for our family. THANK YOU It made a great impression on us. We will definitely be back(and.by the way,the breakfast food and Bloody Mary's were fabulous[y e i .. Rachel H. 2x2;2011• Seattle.WA EG[e'14 2 chsc.-ins4 431 friends 12;-renews We came to Suneadia wit,a sate on our face this winter. mainly because we had a Living Social voucher in our pocket. http:/fwww.yelp.com/bizfsuncadia-resort-cle-elum 1/2/201 0 Jan 0510:04a Suncadia 15 Resort- p.16 Cle Elum,WA I Yelp Page 15 of 19 For a set price we received strawberries,a bottle of free mediocre)champagne,$50 in spa vouchers,valet parking and breakfast for two. We are a family of three,and we found the Suroadia lodge room fine for our family. Pretty cissapointed with how the Living Social Voucher is handled. Particul any,how much is not included in the price. Taxes,resort fees,and basically. another S50 or so of extras.which basically added another 27%onto the price of the room. MirP177. Cv. 8/13,2013 Tacoma.WA ofriends We s-ayed in a 2 bedrOom Condo and absolutely LOVED RI 25 reviews It was very luxurious Put very comfortable at the same time. The grounds were very well kept,naturally as it is a 5 star got course,and the trails are fabulous.Unfortunately the water slides and cut door pool wereIt open during our visit and the•ndocr pool oohed a bit"murky'so we stayed away.tam that.We decided to eat at restaurants in Cie Elum and Roslyn,sot cant comment on the food at the Lodge.There is a resident herd of Roosevelt Elk and the area is rich with history tool Suncada is a Very relaxing place to be and enjoy all that nature has to offer. 0,ipf Doug P. V 9i 512012 vaahon,wA 16 mends 1 check-ir 6 reviews A relatively unknown resort,at least among my community of friencs and colleagues. How fortunate that we found Suncada!Wonderful staff,beautiful grounds.The best part was learning that there is something at the resort for everyone.from ankle-biters to octogenarians.The perfect spot for a family gathering,and I think we're going to do Rust that on our next visit. The reason for the three-star revers is that we were told that every room had reliable high-speed Wife,So,of course. we left our LAN cables and AirPort at home.Big mistake. The WI in the room was non-existent.BRING YOUR HARDWARE. laa A V.8(1112014 Kent,WA e kends oohhh Suncadial your customer service has gone way 3 reviews down.Front desk was unhelpful and kind of rude.Had dirty room at check In with about'`our spiders.Short black hair when I pulled back the sheets.When i called about the room she could not put me in another room or offer housekeeping.She just repeated how busy they were. Speed ahead two days later around 8:30am...Coffee maker didnt work,so called and said they"will try to get another coffee maker".Called at 3prrroh we will look for one--one hour later,front desk doesn't answer phone.Carpet stained and worn thin.Watched staff nat replace the coffee cups and glasses but rinse them off with water.No soap.New the spa set had my appt which i cancellec two days before and were going tc charge me a no show fee.They fixed it and then came back from lake and found they charged me 148.80 an my card.Had to go t0 spa and found out they a http://www,yelp.comibiz/suncadia-resort-cle-elum 1/2/2015 Jan 05 1510:04a p.17 Suneadia Resort -Cle Elum, WA I Yelp Page 16 of 19 charged my card for another persons service. WOW...fyi i am still waiting for coffee maker. Alice B. 11/22/2012 Seattle,WA Elite'14 1 check-3n 40 leends 211 reviews The setting and decor are beautiful,and definitely compares to the Four Seasons in Vancouver.Except for the service.Clearly not many of the staff have any real hospitality experience,except for the concierge,We booked a room wilt a private hot tub,ody to find it filled with cold rainwater when we checked in.We called down to the front,and they assured us they would take care of it right away.After 3 calls over the duration of our stay.we eventually realized we would riot be able to take advantage of the hot tub.No apologies,they just said I guess you're ou'd`luck At least on checkout,when I complained about this for the'tit time.they refunded us the difference between the upgrade and standard room. Darcy H. 812 512 01 2 Seattle,WA 23 friends We had a truly relaxing weekend at Suncadia.Somehow, 243 rev4cs despite the various wedding activity and kids and families, our room was perfectly,perfectly quiet. The fad that dogs are welcome is wonderful. There was lots of activity in the common spaces,and lots of quieter spaces to retreat to if one wished.Everything is made available to guests night and day,all things are easy and convenient. We dined outside every real but one,which was a treat, though we were the only ones out there.All of the staff seemingly delighted to be there. One disappo'n:ment was the winety huh?It's just another restaurant and gift shop...not a working winery at au. Strange. Suncadla is expensive,but the chance to truly kick back and betaken care of makes it worth it IMPORTANT TIP:bring a day pack for your swimsuit dry clothes,book,etc.Keep the day pack with you after you check out of your roola (they'll stow the rest of your luggage)Then you can continue to enjoy the facilities until nightfall.Don't chink you have to leave at 11a--stay and enjoy what you paid for. Eric L A. 1 • LL - 9.'2512013 Rape°,HI 2 friar s Beautiful resort.Serious problems. in reviews Firs:an alert,they may put a$110 bill on your credit card without telling you This is for latent changes you lied about when you checked aut.I guess there is an adverse presumption that their guests.I was told by the single telephone point of access that all resorts do this and it would be about ten days it is refunded.BTW I was informed that your hoe:stay is charged to your card seven days before arrival. Upon arrival our party was told that we would be in the Inn instead of the Lodge which we all independently believed we had reserved.Two of the three of us were able to correct this.Our beautiful room was an incredibly long distance down an endless halt.Unfortunately I forgot one of my wife's items and had to repeat the journey,inducting a wet trip to the distant parking lot.We were able to regroup in time for dinner at Portals only to have an unhappy and http://www.yelp.convbiesuncadia-resort-cle-chin 112;201 f 7 Jan 051510;05a p.18 Suncadia Resort Cie Elum,WA Yelp Page 17 of 19 distracted waitress.Food was disappointing,A Caesar salad came soggy and with tough chicken.A medium rare bison burger arrived cold and cooked to a well,well done. InedibleI Our'waitress,though indifferent,all least took the returned burger off the bill.Mark uos on wine appear tc be 300 or400%.not unusjal, This was our second and last visit to this resort Regina W. 2;9!2014 Mount Vernon,WA o mends There were good things,and I'm sure most people have a 1 re,e..v great time here. Its beautiful and we did a wine tasting. which had tasty wine for a great price The staff were all quire friendly. Unfortunately,I think the management needs to communicate much more clearly with said staff aboutwhat visitors may actualry want A group of 5 friends and I planned a 3 night trip to stay near Suncedia,planning to rent cross country skis there and make use of their trail system for several days. We called a few months in advance and were told rentals were available,and my friers called the week before to double check dire to the low snow levels. She was told that the trail system might be closed,but that we could rent skis and take them to a nearby area with more snow. Thus assured, we dic not rent skis before leaving the Seattle area Wnen we arrived,we spend about an hour and a half shuttling from Information to various places within in search of anyone who knew where we could rent skis and then,upon finding them,were informed that there were no rentals available and that we'd need to head to Cle Elum to find some. We were a bit annoyed,but its understandable that skis aren't avatabie right now-conditions are temble. We just wanted to know sooner. That right,we couldn't Ind any locations to rent skis in Cie Elum,either. I called early the next morning to explain the situation and ask if they knew of anywhere else we could rent skis or if,since it was their fault we didn't have any, they could let us rent some for use elsewhere as originally described. I called twice,was assured a manager would call me back,and never heart anything else We still had fun,but it really changed our weekend and we were disappointed. We'd switched our annual trip from Leavenworth just to try it out and I'm realty disappointed in Suncadia's organization and customer service. Julia W. 6125'2411 Seattle,WAT` ` Elite'14 I have lived in WA my whole life and spend most of my time 78 Viands on the Y,lestside of the Mountains or out of state. 50e reviews I had a off-site meeting at Suncada and drove the 90 mins from Seattle to the reso't.The website is lacking it did not show that it had wilt;cry wired).I found out only later through the in-room hotel amenities book that it was wireless as welt. I didn't bother to try as I did not see any information anywhere on open will. I did not pay for my room as it was covered under the conference being held)so I can't speak to the price but imagine it was not cheap. Check-in wasn't until 4prr but I was able to get early check- in which I appreciated. My room was beautiful and likely a timeshare when not being used as a hotel room.It was like a mini-apartment with a fully-stocked cupboard complete with.breakfast bar, dishwasher and washer&dryer. The room opened info a large patio with two entry doors living room&off bedroom). http:/1vrww-yelp.com/biz/suncadia-resort-ale-alum 1/21201 Jan 051510:05a p.19 Suncadia Resort- Cle Elam,WA] Yelp Page 18 of 19 I travel frequently with a 70130 split for pleasure/business. The one area I often rate hotels are in the bathroom.If you Gam to be a 5-star(which Suncadia does)then you need to have a nice bathroom. I walked in and turned on the lights to find a LARGE bathroom(I can't recall one so large in the last year I've been traveling all over the US).The sink&tub were both Kohler's and the tub was sunken and had a special fast FY aswell as a drain which was hidden by a handle.This was unique and what's great is that you can have TWO people sit on either end and no one has to sit a)against the water nozzle or b)with the drain on their bottom.I took a bath of course and it was great!The free-standing showerwas also nice-overszed showerhead and decent water pressure. The downsides- If you've ever been to Eastern WA.Cle Elum is a lidle in the middle of nowhere.There is no for very limited)cell reception.The signage leading into the lodge to check-in was limited.They are currently building condos&adding onto the resort(it is 1200 acres).It is pretty easy to get turned around and there was no sign directing you back to the main road to get to the hotel.I spent a good 30 mess getting lost until I found my way back. The room was beautiful but the patio doors were left open unsure if just that day or overnight)but several different bugs get irro the room(when I closed the doer they became apparent).I em deathly allergic to mosquitoes and so had a challenging time. tJViifi is free ono open but not listed anywhere(in room or in lobby or on website).Having traveled often,I don't assume every hotel or resort has tree will as most either have a pay rate or it is not consistent. Overall,it was a great place to b-ing your family and kids to.There are carry trails and local things to do as long as events they'sponsor'each day(Diking.swimming,etc). Rebecca R. 9+2014 seatae,wa D f-i=_nds Lovely resort,but the music piped in all over the public 5 reviews areas is HORRIBLE! Why does this place have to play music at all? It is impossible to enjoy the beautiful view and hotel if you have to listen to dreck,even outside_ Page of 2 1 2 15 other reviews that are not currently recommended Best of Yelp Cle Elum—Hotels t.Aag~err ` Sec Mae http://www.yelp.com/biz/suncadia-resort-ele-elurn 1/2/2015 Jan 051510:06a p.20 Suncadia Resort-Cle Elum, WA I Yelp Page 19 of 19 About Discover Yelp for Business Owners Languages Abc_t Yelp The Weekly Yelp Claim your Business Page I English Careers Yelp Blog Advertise on Yela Press Support Yelp SeatMe Countries Investor Relations Yelp mobile business Success Stories United States Content Guidelines Developers BusinessSupcort Terms of Service RSS Yetp Blog for Business Owners Privacy Policy Ad Privacy' Info Cle_tum Business Listings a A B C D E F G H I J K L N N O P Q R S T U V N' X Y Z Site Map Atlanta j Austin;Boston I Chicago j Dallas;Denver!Detroit; Ho^oluki Houston? Los Angeles;%anti j Minneapolis j New York{ Philadelphia!Porterd?Sacramento San Diego; San Francisco;San;ose;Sessile Washington.DC{More Cities Copyrgnt s 2004-2C15 Yelp he.Yep. Yelp::.Ji and related marks are registered traderarks of Yelp. http://www.yelp.com/bizisuncadia-resort-cle-elurn 1/2/2015 JC411 T, v ,v.vvu N' ' WHITNEY GARDENS & NURSERY, LLC P.O. Box 170, 306264 Highway 101, Brinnon, Washington 98320-0170 1 Fax Transmittal Form Name: J- /G W 62e /(rl 67//t& 7 "T Organization Name/Dept: Phone number: Fax number: C Q 7,"'-' V t Name: 41/0 . 5/i- Phone Number: (800) 952-2404 Fax Number: (360) 796-3556 Email: info@whitneygardens.com Web: www.whitneygardens.com Page: Comments: 1 S9/1(61/4--P/X1 ULl 4)&2/ r / V4I__ V / D IP- PRI/ ve JA,vITT X015 I 411V. ! VU11 VV IV IV.VVG poe4.,..,.../....... 37.-F.:: - /'-1 61ile AP/4 f` t { W e. r l 34 i ftt 55k x A.`1 1 S sir lP ' mat ativK rA fi j APO 04 ltir r. III c il. I yLi Yom:. yrt. x 7 Irt r ,. Yr N •. r 1 1 w w ` g 1 a,. ylc, 1V. Iii., N•• fi-/11- z r 4 r f i.. s _ riY' S} ' l' > ;;‘,.,:-.--r t E , X t '.„.. "- Y, r-. 3ent' ik d a yy -'. x s a * .; r.f t ' . ' St}x ilk + r F b F r...-; K ;, ./ 1„,:.s 4i, , 1 e 1 eyw+.P ^Y5- . t +,i n y' Y P. s.P w n .•SirC c.4:30-:: 4X' Y A q ! s' T, 0. Q M -1;'i k W C J p, ish y•1 Tie.----..:,"4. 4IkA', 1 ' S d yy`K. S' 3Gt LAM. l Y Z; , J j `W X.. •' TX ,,7;!.:1:..W4-1i Ca S .,..'-'..z.1.-. ° t Ivw•i •y x c , om. I e a Ik ` n + aa i t 44-004. y Wa pp{{t r i'.'.....,-,..,;.,--.4,- t y' f lY Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 140 Exhibit 1 RESPONSE TO COMMENTS FROM ELEANOR SATHER #3 (Letter # 54) Comment 1 Thank you for your comments, your comments are acknowledged. The information on the Suncadia Resort attached to the comment letter is included in the published Final SEIS. FE January 2,2015 i I JAN — 5 ^n':. To: Jefferson County Department of Community Development r , JC/O David Wayne Johnson, Long Range Planner a L:1 621 Sheridan Street iivTY Port Townsend,WA 98368 1',EFT OF COVIVI 1!TY EEVn ONE NT Subject: Comments on DSEIS for Pleasant Harbor Marina and Golf Resort The purpose of this memo is to provide general DSEIS comments in support of the Black Point MPR. Our comments are based on the fact that parity will exist between the development effort and the community outside the development. As such, we look forward to the following improvements: Senior Nutrition Program and Meals on Wheels lost its county funding support due to a lack of county revenue; Brinnon School is in an aged building and is in need of repairs before the growth in attendance occurs; Brinnon Fire and Emergency Rescue lacks funding support such that those in need get rapid response and need not be required to travel long distances when time is important; Living wage jobs for our community will grow as will the population. Our area has been devastated by both the demise of the logging industry and the current economic conditions; Senior Health Care will improve such that traveling at least an hour in either direction will be minimized; Environmental improvements will take place. According to the DSEIS this project will be the most environmentally friendly project in Western Washington and will be something our community can always be proud of; Parks and Recreational activities will improve leading to a variety of activities for both tourists and the community; The Brinnon Village Center infrastructure will improve. The systems for water, sewer and roads will improve and will result in healthier and safer environment for local residents; The tax base for our community (and for the county)will grow leading to improved revenue for the county and hope for lower property taxes for our community. We support all aspects of the DSEIS and encourage its approval. Changes brought about by this development are very important to our community and, as such, we urge the county to support its continued development. Sincerely, 15-LICM/( 4/4 -C1141.61(914-- Bud and Valerie Schindler 270 Rhododendron Lane Brinnon, WA 98320 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 142 Exhibit 1 RESPONSE TO COMMENTS FROM BUD and VALERIE SCHINDLER (Letter # 55) Comment 1 Thank you for your comments, your comments are acknowledged. Diane Coleman Pleasant Harbor Marina 308913 Highway 101 t -, Brinnon, WA 98320 v` 0 1 December, 2014 Diane, I am writing in support of the Pleasant Harbor Marina and Golf Resort development. Not long ago we were moored at the Alderbrook Resort and Spa dock. While there I had a conversation with several of the Alderbrook managers. I mentioned that we had permanent moorage at Pleasant Harbor and they expressed hope that the expansion of the golf resort project would proceed.Their reasoning was that, while the PHM expansion might seem to be competition to their operations, in fact they felt that anything that brought additional people into the Hwy 101 corridor between Olympia and Pt Townsend would only help add to their revenues and the revenues of all business in the region. I am sure everyone is aware of both the short term (1-5 years)and long term (perpetual) impact on job creation the construction and operation of the resort will have in the region. This includes the positive impact the development will have on all regional businesses. Virtually every person in the area will have improved opportunities. Real estate values and turnover will improve as more people,employed by the Resort or because of peripheral jobs created as a result of the development and operation of the resort, can afford to own or upgrade/remodel a home. As the financial health of individuals in the region improves then so will tax revenues at the municipal, county, state and federal levels.This will improve badly needed funding for area schools,fire/ambulance and entitlement programs as well as numerous other programs. One estimate is that every dollar that comes from outside a community or region will be re spent up to seven times before it leaves the area providing tremendous cash flow for all. Infrastructure improvements including those that would be provided by state, county and various utilities in support of the development will be costly but these expenses can be spread over time and offset by increased tax revenue and economic growth. Infrastructure improvements will also create additional jobs and-will aid in the financial recovery and stability of the region as a whole and will, of course, promote"additional development outside the planned resort. Sincerely' rf eorge Selfridge 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 144 Exhibit 1 RESPONSE TO COMMENTS FROM GEORGE SELFRIDGE (Letter # 56) Comment 1 Thank you for your comments, your comments area acknowledged. David W. Johnson From: Rstlss49@aol.com Sent: Sunday, January 04, 2015 9:56 PM To: David W. Johnson Cc: Rstlss49 @aol.com Subject:Comments on MPR at Black Point revised Mr. Johnson, 1 have revised my comments to fix a couple of typo's. This is my final version. Please submit this as my comments on the MPR. Mr Johnson, I write to you today concerning the proposed MPR at Black Point in Brinnon Wa. I strongly oppose this development and urge a "No Action" determination. I was involved with this process early in the Brinnon Sub Area Plan, which was simply a vehicle to push forward this MPR, with no consideration to any adverse effects on the people who live in Brinnon or the environment. Most people who visit the Brinnon area do so for the shell fishing and the beauty of the low lands and mountains. I doubt very much if many could afford a round of golf or a home at the proposed resort. Hood Canal is an extremely sensitive body of water already under stress. Who will be responsible for the restoring the habitat after being contaminated with run off and fertilizer? To think that this could never happen is both irresponsible and naive. Once a habitat is destroyed there is neither the money nor the resources to clean it up. This was a poor idea at the beginning and a dangerous one now. Peter Siefert PO Box 573 Brinnon,WA. 98320 1 1 2 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 146 Exhibit 1 RESPONSE TO COMMENTS FROM PETER SIEFERT (Letter # 57) Comment 1 Thank you for your comments, your comments are acknowledged. Comment 2 Comment acknowledged. As noted in the Draft SEIS, the Pleasant Harbor site would be graded, as conditioned by the Board of Commissioners, to not allow surface water runoff from the golf course directly into Hood Canal. Please also refer the Response to Letter 30 (Joan Hendricks), Comment 2. To: Diane Coleman[diane @pleasantharbormarina.com] p m From: Mike Stelte Sent: Invalid Date Importance: Normal Subject: Re: Pleasant Harbor Marina Construction and Parking Access Update#4 MAIL RECEIVED: Invalid Date I'm very happy that various upgrades are going on, especially plans for the golf facility which is now moving foreword. The course as a destination resort and I suppose also as a single family community will become a true asset for the infrastructure of the area, not to mention employment opportunities. We bought a marina slip several years ago because of what seems to be happening now. It has taken a lot longer to get to this point that we thought at the time of purchase. We are now rethinking if we should sell our slip. Do you have any long range development scheduling that you can share at this time? Mike and Joan Stelte 1 2 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 148 Exhibit 1 RESPONSE TO COMMENTS FROM MIKE STELTE (Letter # 58) Comment 1 Thank you for your comments, your comments are acknowledged. Comment 2 As stated in Chapter 2 of the Draft and Final SEIS, the proposed schedule for buildout is approximately ten years based on market conditions. 1 Hollinger, Kristy To:David W. Johnson Subject:RE: Statesman project ‐‐‐‐‐Original Message‐‐‐‐‐  From: fredrstern [mailto:fredrstern@gmail.com]   Sent: Friday, December 05, 2014 11:04 PM  To: David W. Johnson  Subject: Statesman project  Sir,  I live 3 miles south of the proposed resort and think it's way too much for the highway adjacent, and the Duckabush river  and estuary, which is already suffering salmon degradation issues.  Fred Stern   1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 150 Exhibit 1 RESPONSE TO COMMENTS FROM FRED STERN (Letter # 59) Comment 1 Thank you for your comments, your comments are acknowledged. Transportation issues were evaluated in Section 3.9 of the Draft SEIS. Refer to this section of the Final SEIS for further details. The site would be regraded and designed so that water on the site will be collected and would not be discharged to Hood Canal. In addition several areas around the site would be monitored for water quality to ensure that if an accidental release occurs, corrective measures could be implemented quickly. 1 Hollinger, Kristy From:David W. Johnson <djohnson@co.jefferson.wa.us> Sent:Friday, February 20, 2015 2:15 PM To:Hollinger, Kristy Cc:David W. Johnson Subject:FW: DSEIS Found another one.   From: William Stewart [mailto:memostewart@gmail.com]   Sent: Wednesday, December 17, 2014 5:26 AM  To: David W. Johnson  Subject: DSEIS  Greetings from Mexico! My wife and I were unable to attend the open house so I wanted to personally write you and express our support for the Pleasant Harbor Marina project. Brinnon needs this development to move forward. Everyone will benefit. We will return in April and hope to see more progress. Thanks for all of your work. William & Victoria Stewart 620 Duckabush Rd. Brinnon, WA 98320 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 152 Exhibit 1 RESPONSE TO COMMENTS FROM WILLIAM AND VICTORIA STEWART (Letter # 60) Comment 1 Thank you for your comments, your comments are acknowledged. 0 3 t_v. fi Dec 3, 2015 This week there was an article which appeared in the Peninsula Daily News. In that article there was a quote from David Wayne Johnson, Jefferson County Department of Community Development associate planner in which he states regarding the proposed Pleasant Harbor Master Planned Resort) that "Plans have been streamlined..." He goes on to say the final permitting process "could take years." This development was proposed in 2006. I ask you, how is this STREAMLINED"? How many "years" does Jefferson County need to decide this development will be good for the county? The county is struggling with budget cuts and revenue shortfalls, isn't it time for our county leaders to realize this development will bring badly needed revenue without overtaxing county residents? What better way to pay your bills than with money brought into your county from out of the area? Currently Jefferson County's biggest export is it's dollars, isn't it time to start importing some? I read online this week commentary from someone who was comparing the resort to the damn on the Elwa River. A lot more is known about environmental impact today than was known in 1910. The Environmental Impact Studies have demonstrated this proposed resort is a low impact development. This is something that shouldn't have to be the way of the future, it should be the way of TODAY. David Wayne Johnson and the Department of Community Development need to take a serious look at how they're failing the people. Now is the time to provide some economic relief to local citizens and taxpayers. Our residents and property owners are overtaxed and the community needs jobs. All of our local businesses will benefit from this project. It's time we bring a little prosperity back to Jefferson County. I ask the county now to make this resort happen. Phil Thenstedt, Brinnon, WA resident Rj.ccwj4s5._ 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 154 Exhibit 1 RESPONSE TO COMMENTS FROM PHIL THENSTEDT (Letter # 61) Comment 1 Thank you for your comments, your comments are acknowledged. Due to the size and complexity of the proposal, additional time and effort has been taken to complete the environmental analysis. David W. Johnson From: Ann Tuberg <annmcctu @comcast.net> Sent: Monday, January 05, 2015 12:44 PM To: David W. Johnson Subject:Concerning the proposed DSEIS for Black Point MPR January 3, 2015 As a current property owner in Jefferson County on the Duckabush River Road, Brinnon WA(parcel#502-071-004), I have concluded the subject DSEIS for Black Point MRP is inadequate. I oppose the approval of DSEIS for Black Point MPR by Jefferson County,State of Washington. Judd Tuberg 5401 NE 200th Pl. Lake Forest Park,WA 98155 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 156 Exhibit 1 RESPONSE TO COMMENTS FROM JUDD TUBERG (Letter # 62) Comment 1 Thank you for your comments, your comments are acknowledged. November 26,2014 Daniel W.Johnson Jefferson County DCD 621 Sheridan Street Port Townsend, WA 98368 Dear Mr.Johnson: I am writing in support of the Pleasant Harbor DSEIS. My wife and I have kept our boat at Pleasant Harbor Marina since November 2000. We have seen the changes at the marina and impacts of the changes in the economy at both the marina and in the local community. We were both involved with the development of the Pleasant Harbor Yacht Club and I was a key member of the Advisory Committee( representing slipowners)to the Statesman Group as they developed plans for the marina and golf course developments. As a retired manager in the U.S.Forest Service and Bureau of Land Management(BLM)and co-author of a major EIS for BLM in Western Oregon I am knowledgeable in working with EIS issues. As a result, I feel I am qualified to comment on this DSEIS. I am a strong believer the plans for this development will create jobs and opportunities for the local Brinnon residents. The community does not have a lot of new businesses coming in with even the most basic of wages. Lack of local jobs means residents may be dependent on assistance to meet food and housing needs. Even though the local residents may regard boatowners as'non- local'there are many of us who regard the Brinnon area as our second home and have contributed to it. When I was Commodore of the Yacht Club, I began an annual event to gather food,toys and funds for the local Brinnon Food Bank. That tradition has continued since 2001. In past discussions with the local Food Bank, it was clear that there are many in the community who can't afford to move to where there are jobs so we need to support potential businesses that will provide those options. I believe my involvement with the Advisory Committee has provided me with a strong understanding of the issues and opportunities these plans will bring to the local area.This project also would provide options that are limited or not currently available such as local lodging for visitors and additional groceries and sundries. Improvements to the marina and development of Black Point would benefit the community as a whole by attracting additional boaters,golfers and other recreationists that can afford to spend locally at the stores and restaurants already in Brinnon. If you look at Alderbrook Resort,people will shop at the stores nearby or seek alternative dining offsite, thereby benefitting the local community. It will also add an extra'draw'to travelers on Highway 101. Statesman Group was attracted to the beauty and ambiance of the Brinnon area. I believe that the Corporation and the County will be able to work together to find a balance that will retain that ambiance and bring a hope of moderate opportunity. As can be seen by the work at the marina,not every aspect of any plan gets fully implemented as initially planned. Any improvement in job opportunities, infrastructure,and paying visitors will be a benefit to the local community in ways not yet realized. It may also attract other services or businesses. In short,a new infusion of business in a local area that has very few opportunities to diversify beyond its logging origins should be looked on with favor rather than allowed to be blocked by small group who want no change and won't suffer from perpetuating a lack of growth. The resulting tax dollars to the county,state and local agencies will come when other funding is drying up. I respectfully ask the decision makers in Jefferson County to support the Pleasant Harbor DSEIS. Sincerely, i i I i C Y f ''s i J Greg and Tina Tyler SlipC20, Pleasant Harbor Marina 350 E. Ballycastle Way Shelton,WA 98584 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 158 Exhibit 1 RESPONSE TO COMMENTS FROM GREG and TINA TYLER (Letter # 63) Comment 1 Thank you for your comments, your comments are acknowledged. To: Diane Coleman[diane @pleasantharbormarina.com] From: Lori Uddenberg IImportance: on 11/30/2014 Normal 4:44:13 PM CE-7, Q 3 MAIL RECEIVED: Mon 11/30/2014 4:44:20 PM Hi Diane, I am sorry I can not be present at the meeting. I am on the East Coast for the holidays. I support the project. The work at the marina has been nothing but great. My only concern is keeping my place private. The property lines are clear and I don't think it should be an issue. I would just hope they would make it clear to folks that my land and beach is private land. Other wise, I am 100% behind the development! What a great thing for the area's I' Call me anytime. Lori 253-906-5809 Sent from my iPhone 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 160 Exhibit 1 RESPONSE TO COMMENTS FROM LORI UDDENBERG (Letter # 64) Comment 1 Thank you for your comments, your comments are acknowledged. Access to the beach will be limited. The site may also be fenced in certain areas to keep elk out, and this fence may be extended around the bluff. Fencing and signage are anticipated to be adequate to keep resort visitors from entering private property. Steven John Walker 331 Dosewallips Rd Brinnon,WA 98320 Pleasant Harbor DSEIS c/o Jefferson County DCD 621 Sheridan Street Port Townsend,WA 98368 Via email to dwjohnson @co.jefferson.wa.us JAN 0 5 2 4 5 January,2015 JEFFE11:7" vDP RE: Pleasant Harbor Master Planned Resort DSEIS l The 2000's era adoption of the Jefferson County Comprehensive Plan including zoning for a Master Planned Resort at Black Point was a singular act of folly. The passage of time has done nothing to change the fact that plunking down a luxury resort in the rural county,far from existing infrastructure and services will have a suite of negative cultural and environmental impacts which cannot be mitigated. The proponent's DSEIS document ignores or otherwise glosses over many of the most substantial of these impacts,and therefore must be deemed inadequate and incomplete. I have identified the following adverse cultural and environmental impacts which neither the project proposal,nor the DSEIS are able to adequately address or mitigate Fundamental change to the community Impacts to the natural view shed of the Duckabush River Delta, and other aesthetic issues. Inadequate Traffic and Greenhouse Emission Analyses Emergency Services Inadequate Greenhouse Emissions Analysis Possibility of Failure For these reasons, it is imperative that the DSEIS be rejected in its current form, until these issues are adequately addressed and discussed. Fundamental change to the demographics of southeastern Jefferson County,and creation of a two- tiered society therein. As planned,the project would nearly double the population of the Brinnon area in ten years,a population which has been relatively stable or seen only incremental growth over the last century. Furthermore, this new population (presumably upscale individuals who could afford to,and would choose to, live in a golf-course/resort setting)will have very little in common with Brinnon's current, predominantly working-class population. As a result,we will see the creation of a two-tiered society in the Brinnon area,with the current population largely becoming the servant class of the new resort population. 1 2 This is absolutely clear by the fact that the resort will be a gated community,with public access restricted. The creation of highly-stratified class system in rural, southeastern Jefferson County is one of the fundamental negative impacts of this project proposal,and one of the primary reasons why it should be rejected. Impacts to the natural view shed of the Duckabush River Delta,and other aesthetic issues. This study does not directly discuss the impacts to the Duckabush River delta view shed,except to use weak meaningless language which will not translate to actual planning prescriptions. The topic is mentioned only briefly(3.15-2) but absolutely does not describe how the resort will appear from the south and whether or the primarily natural view shed of the Duckabush will be altered,and to what degree. No figures,diagrams,or artist representations of the altered view are presented. There is no discussion ofto what degree the 200 foot shoreline setback will or will not obscure the resort. Until this topic is addressed,the DSEIS will remain incomplete and adequate with respect to the subject of aesthetic impacts. Traffic Analysis The section 3.9 discussion of collision history is incredibly brief and deficient. It briefly discusses distant interchanges such as WA Hwy. 104/Center Road but completely omits discussion of the real risk,which is accidents along the reaches of US 101.The section of highway between Quilcene and Hoodsport is a winding, poor visibility route with large sections of minimal to no shoulders. As discussed below,the analysis also omits consideration of trips generated by residents commuting to distant employment. Emergency Services Emergency response times for life-saving care to regional hospitals in Port Townsend,Sequim,or Shelton are prohibitively too long from Brinnon. As a result,the typical evacuation for a severe accident victim is via helicopter to Harborview Medical Center in Seattle. We can expect with more residents,and more traffic on the 101,that the number of helicopter evacuations to Harborview will increase.Additionally, life-threatening situations such as heart attacks can also require helicopter evacuations. Brinnon itself has no medical facilities,while Quilcene has a small clinic.Thus, even minor incidents that could be routinely handled in a more populous area with more facilities may quickly escalate into emergencies. 2 cont. 3 4 5 An additional 0.33 EMS units will do very little to mitigate these impacts. An adequate discussion would attempt to fully estimate the number of expected life-threatening and other serious incidents which would require helicopter-based evacuation. A major earthquake or flooding event has a very real possibility of isolating the resort from the outside world.Just recently we've seen US 101 reduced to a single lane south of Brinnon,with the WSDOT reporting that it will be months before traffic returns to two lanes. The potential closure of 101 due to mudslides, rockfalls,or erosion,or the loss of one or both of the Duckabush/Dosewallips bridges could completely isolate the resort. In the case of a major catastrophe such as an earthquake, overwhelmed emergency response units could leave the resort effectively on its own.The injured or ill could expect no medical response for days. This is one of the reasons why it is inappropriate to site a major development in a rural area lacking services. This is also a fundamental flaw in the DSEIS in its present form. For this reason,the proposal should be denied until or unless the proponents are able to provide an adequate discussion of how the isolated resort would respond to a catastrophic natural disaster. Inadequate Traffic and Greenhouse Emission Analyses Together,these topics greatly under-estimate the number of additional vehicle miles which will be generated by the resort,and therefore the volume of greenhouse gasses which will be produced over the period of the resort's life. Presumably,with nearly 300 permanent residential units and an estimated 556 new permament residents, not all of these residents will be retired or members of the idle rich.Some of them may in fact work for a living.Jobs for these presumably upper-middle class individuals are absent in rural Jefferson County.These permanent residents would presumably thus commute to distant areas such as Shelton, Port Townsend,Sequim,or Kitsap for work. Even the roughest calculation shows that a single commuter would generate on the order of 400 weekly round-trip miles to reach these job markets (40 miles one way to Shelton or Port Townsend). Even if only 18%of permanent residents commute to work,this would represent an additional 40,000 weekly miles, and 200,000 yearly miles driven by commuting residents of the resort. Given that neither the traffic nor the greenhouse emission analyses appear to account for these commuter miles, both must be deemed incomplete and inadequate at this time. Conclusion In conclusion,while I understand that the Jefferson County Comprehensive Plan and Zoning allow for a Master Planned Resort at Black Point,they certainly do not require approval of any given proposal. In the case of this proposal,the resort is simply too large for a rural, isolated community to assimilate without fundamentally changing the core aspect of the community. I understand that this is a speculative proposal,and that the proponents need to be sized substantially enough to for it to be economically viable to them. However,this economic-driven scope from the proponent's standpoint should not be allowed to drive the process at the regulatory level. 5 6 7 8 9 Jefferson County must make a realistic estimate of what level of economic development is both viable, sustainable, and realistic in the Brinnon area. The comprehensive plan and MPR designation notwithstanding,this proposal fails tests of viability,sustainability, and reality and therefore should not be approved in its current form. electronically signed 5 January, 2015) Steve Walker 9 cont. Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 162 Exhibit 1 RESPONSE TO COMMENTS FROM STEVEN JOHN WALKER (Letter # 65) Comment 1 Thank you for your comments, your comments are acknowledged. Comment 2 Changes in population as a result of the development alternatives were evaluated in Section 3.12 (Rural Character and Population) of the Draft SEIS. As indicated in Section 3.12, new residents under Alternatives 1, 2 and 3 would result in a population increase of approximately 80 percent. The potential for new population to have little in common with existing, working- class residents in the area may be viewed as a subjective matter and is not considered an environmental impact within the scope of this SEIS. Appendix S of the Draft SEIS outlines proposed public amenities for the project. Resort amenities available to the public include: golf course, putting green, driving range, pro shop, conference center and meeting rooms, restaurant and lounge, spa, medical center, beauty salon, wedding chapel, amphitheater, swimming pool, pedestrian trails, bicycle trails and electric shuttle service. Some of these services require reservations, bookings or give priority to residents and guests. Amenities that are only available to the residents and guests include: tennis courts, hot tub, bocce ball, billiard and game rooms and fire pit. See Appendix S of the Draft SEIS for additional information on proposed public amenities. Comment 3 As indicated in Section 3.15 of the Draft SEIS, development of the Resort would extensively change the visual character of the site, and portions of the subdivisions at the mouth of the Duckabush River have the potential to view site development. Section 3.15-3 includes measures to minimize the potential for visual impacts including maintaining greenbelts and providing new landscaping. It is anticipated that maintaining the 200 ft. wide shoreline buffer would provide some screen of views to the site development. Comment 4 Please see Response to Letter 38 (Rob Mitchell), Comment 4. Comment 5 Comment acknowledged. The County must rely on the authority and expertise of the Fire Chief to determine staffing requirements for the anticipated impacts from EMS calls and negotiate with the applicant accordingly. Please also see the Response to Letter 8 (Brinnon Group), Comment 9. Comment 6 Comment acknowledged. Design and construction of buildings and roadways on the site would be consistent with applicable regulations, including regulations related to seismic safety. The results of a natural disaster that are cited in your letter would apply to everyone within the area Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 163 Exhibit 1 of the disaster and is not dependent on or related to whether or not the proposed resort is sited on the subject property. Comment 7 The cited vehicle miles measure is not an analysis measure typically utilized for EIS vehicle traffic analyses; trip generation, traffic volumes and level-of-service are typical measures. The traffic analyses prepared for the Draft SEIS analyzed trip generation, traffic volumes and level- of-service. For greenhouse gas emissions analyses, the assumed average trip length for “commute” or typical PM peak hour trips was 100 miles, while the more localized trip generated was assumed at 75 miles. Comment 8 Please see the response to Comment 7, above. Comment 9 Thank you for your comments, your comments area acknowledged. As discussed in Section 3.14 (Rural Character and Population) of the Draft SEIS, while “the type, character, and pattern of land uses on the site would change substantially from a primarily vegetated/forested site with minimal existing uses (real estate office and two single family homes) to a denser, resort development. The rural character of surrounding land uses are intended to be preserved in a number of ways, including limiting the visibility of the resort from offsite viewers; preserving natural area and open space; limiting the heights of buildings; and, clustering the more intense development internal to the site.” See Section 3.14 of the Final SEIS for further details. DEC 0 3 4W-141- 73-04-W 7/A2,D OL4LIA 10/ i4.-d Ge9 U. cm} eL. "kit, podeil g701- e at 4it AA-g„ g-A° ha4A-7 a-itzvA20-- piz-tAk0-0-4 aAd afrot-14/14.91-kp_v4--, I"- j Sha-4.43:9 e";,, Ridge 0- 1 2 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 165 Exhibit 1 RESPONSE TO COMMENTS FROM PATTY WELLS (Letter # 66) Comment 1 Comment acknowledged. Injection wells to "recharge" the local aquifer with reclaimed water from the Resort wastewater treatment facility were an element of the 2007 Resort proposal (see 2007 EIS), but have been eliminated from the 2012 proposal evaluated in the SEIS. Regarding well drawdown, please refer to the Groundwater Monitoring Plan discussed in the Response to Letter 3 (Port Gamble S’Klallam Tribe), Comment 4. As discussed in the Response to Letter 8 (Brinnon Group), Comments 23 and 28, it is the goal of the Resort to reduce water demand to 70 gallons per day per unit through measures such as the use of water saving fixtures; however, the Resort water balance was performed using higher standard usage rates (175 gpd/ERU), as required by Jefferson County Ordinance 01-0128-08, Condition 63 (o). Comment 2 Please see the Response to Letter 8 (Brinnon Group), Comment 9. As discussed in Section 3.17 (Public Services) of the Draft SEIS, fire services to the site would be provided by Jefferson County Fire District #4. The MOU negotiated with the Fire District contains mitigation measures relating to aerial apparatus, and as stated in this document, “The-Resort shall Lease/obtain and provide to the Department on aerial type apparatus with a ladder reach of not less than 75 feet.” See Appendix R of the Draft SEIS for further information about mitigation relative to aerial apparatus. To: Diane Coleman[diane @pleasantharbormarina.com] From: Delweron @aol.com rrv; Sent: Invalid Date Importance: Normal Subject: Re: Update for Pleasant Harbor Marina &Golf Resort project MAIL RECEIVED: Invalid Date Dear Diane, We regretfully will not be able to attend the open house and public Planning Commission meeting. Thank you for the update on the progress of the building plans for Pleasant Harbor Marina and Golf Resort. As a family we totally support this project. We have been vacationing at Pleasant Harbor Marina in Hood Canal since 1998. We have had the privilege of introducing our children and grandchildren to this beautiful area. Our grandsons grew up boating with us at Pleasant Harbor as baby's. Our oldest grandson just graduated from high school. We have great memories of this marina. At first we were not sure about our quiet quaint marina becoming a marina and golf resort. It is easier to hang on to the surroundings that we know and love than to dream of what it could be. We believe the changes and improvements will draw many family's to this vacation destination in our very own Washington state. This should make a real impact on the economy as well as employment opportunity in many areas. This should be a win - win opportunity for all. What a great way to bring family's to this very beautiful area. It is time for growth and expansion and moving towards the future of Pleasant Harbor Marina and Golf Resort. We have appreciated the family style atmosphere. Diane, we must say how we have appreciated the way you run a first class marina. Your friendliness and business style keeps people coming back. Congratulations on the progress of the marina. We look forward to the completion of the restaurant and office building. You have our support for this great improvement to the Hood Canal Area. We look forward to receiving an open house invitation to tour the new building and tour the great improvements to the facility. Sincerely, Del and Terri Weron 11006-61st Ave. NW Gig Harbor, WA 98332 253) 318-3587 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 167 Exhibit 1 RESPONSE TO COMMENTS FROM DEL and TERRI WERON (Letter # 67) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: katie whitman <oboyle©olympus.net> Sent: Monday, January 05, 2015 11:06 AM To: David W. Johnson Subject:development near Brinnon I am worried about the proposed development near Brinnon. Please no golf course or resort or commercial development! Sincerely, katie whitman 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 169 Exhibit 1 RESPONSE TO COMMENTS FROM KATIE WHITMAN (Letter # 68) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: LWilson126 @aol.com Sent: Monday, November 24, 2014 11:58 AM To: David W. Johnson Subject:Pleasant Harbor What a wonderful addition to Hood Canal. We are boaters who love nice marinas and this one is going to be on the top of our list. Thank you for supporting the changes. Everyone will benefit, including new employees, tax revenue, and those that go there. So glad to have them expand their marina. Hope everyone will help promote it so they will have a lot of visitors this summer. Lynda Wilson 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 171 Exhibit 1 RESPONSE TO COMMENTS FROM LYNDA WILSON (Letter # 69) Comment 1 Thank you for your comments, your comments are acknowledged. David W. Johnson From: Ralph Woodall <ralphw©americanlegendsracing.com> Sent: Sunday, November 23, 2014 8:31 AM To: David W. Johnson Subject:Pleasant Harbor Mamia I am in support of the remodel project to the Pleasant Harbor Marina and see no reason why anyone would oppose it. Ralph Woodall 6909 61 Place NE Marysville WA 98270 425 239 2330 ralphwCc americanlegendsracinq.com 1 1 Pleasant Harbor Final SEIS Comment Letters and Responses December 2015 173 Exhibit 1 RESPONSE TO COMMENTS FROM RALPH WOODALL (Letter # 70) Comment 1 Thank you for your comments, your comments are acknowledged. Exhibit 2 Planning Commission Meeting Comments and Responses Pleasant Harbor Final Supplemental EIS Planning Commission Mtg. December 2015 1 Exhibit 2 EXHIBIT 2 PLANNING COMMISSION MEETING COMMENTS and RESPONSES This exhibit of the Final Supplemental EIS (Final SEIS) contains a transcript of the Planning Commission meeting that was held on December 3, 2014, to provide orientation, answer questions about the SEIS and the SEIS process, and allow opportunities for public comment. The Planning Commission meeting was held at 6:30 PM in the Brinnon Community Center.1 This transcript is not a verbatim recording of the meeting, however, it captures many of the key issues that were raised by the public. Responses to these comments, which were also in some cases addressed verbally at the meeting, are provided below. 1 The Brinnon Community Center is located at 306144 Hwy 101, Brinnon, WA 98320. Planning Commission Pleasant Harbor Master Planned Resort December 3, 2014 Public Comments – transcribed verbatim Commission and applicant responses summarized in italics Chair Coker opened the comment period George Sickel (?), Brinnon, WA: First of all there’s lots of documents that you’ve talked about here, is there any plan for the documents to be available here in Brinnon for the residents to review? I recognize it’s on the internet, not everybody has internet access. And second – it’s really hard to read these documents on the internet as opposed to a paper copy. …. Brinnon fire hall has a complete copy. …. Mike Weld, Jupiter road, Brinnon, WA: How many acres does this whole thing encompass, and how many private land owners are going to be evacuated off their land to make this thing up? …. 256 acres. No residents displaced. …. Miriam Burdock, Brinnon: Any provisions or plans for saltwater intrusion in the aquifer? Indecipherable. …. Water quality testing is in place. Advanced warning if any saltwater intrusion. If wells are damaged, PH will make provisions to repair, provided proof can be made that PH impacted their well. …. Rob Mitchell, Brinnon: I have here…this is the agreement that Statesman has proposed, and this states that the well has to be…(indecipherable)…DOE has figured that ….(indecipherable)…are, the well owner provides conclusive evidence that over a statistically relevant period of time, chloride levels have increased. (C) Pleasant Harbor has the right to request additional evidence from the residents, showing that Pleasant Harbor…(indecipherable)…is the cause of the increase of the chlorides. The burden of proof is on the homeowner, and if PH replaces the water, it is at Pleasant Harbor’s cost to the homeowner and then the homeowner has to pay for use. This is in direct conflict with what the DOE conditions are for the water rights. In addition, the pump test that was done was aborted after 24 hours for the well that’s existing. A second well was never drilled and second pump test was never completed. So Statesman doesn’t really know, does not have empirical proof that water exists or whether they’re 1 2 3 4 going to affect salt-water intrusion on surrounding wells. Which is going to occur on the edges of the lenticular formulation. That’s in the draft SEIS. …. I ran the pump test, and that’s standard operating procedure, to stop the pump test after 24 hours. …. Rob Mitchell, Brinnon: No. In the SEIS, it states the pump test failed because the generator failed, so which is it? Back and forth conversation between unknown commenters. Staff suggested putting these comments and questions into written form so that they can be captured and responded to. Janice Richards, Harbor House, Brinnon: The gentleman said that there’s no private property that’s impacted by the new plan, and it looked to us like there’s still a road going through our place and some other things going on, so we don’t understand the change, or if we’ll be impacted or not. …. No one is going to be “displaced.” The Richards home will remain and nothing changes. A “shuttle road” will not impact the Richard’s home. …. Janice Richards, Harbor House, Brinnon: So you can change a legal document that says that it’s pedestrian access only, to a shuttle or whatever access? …. Not aware of any legal document stating that it’s a pedestrian only access. …. Janice Richards, Harbor House, Brinnon: Check with the Health Department. It was an exchange for letting us put our septic system up on lot 2, we granted a pedestrian access. Victoria Marshall, Brinnon: We’re waterfront property owners, and we look right at Black Point. Very supportive of this project. I have looked at the SEIS, haven’t made it though I think 269 pages of it, but certainly through the executive summary and through the table, comparing the options. I think what we’re talking about here is one of two options. One is option 2, or do nothing. I guess the comment I would like to make is that sometimes, the greatest degradation to the environment is poverty. And I have witnessed, while certainly people have lots of great concerns, that I’m concerned about the “do nothing” aspect, and leaving this undeveloped and then having piecemeal septics put in, more wells drilled. I mean something’s going to happen to this property. I was very very impressed with the SEIS. I think it’s well done. Well researched. I would like to add that my entire career was in resort marketing on a national basis. I’ve been in many meetings like this with a lot of communities small and large 4 cont. 5 6 7 8 grappling with a lot of issues. I think that the pace that this is going at, the careful work that’s going in to it is impressive, and it’s going to be a wonderful addition to the community. Joe Baisch, Brinnon: I’ve lived here for 23 years. I got here right as the federal forest policy affected the timber county of Jefferson very adversely. South County lost 40 family wage jobs and 4 timber companies went out of business overnight. About that time the county opted in to the GMA process. Now the Growth Management Act process was designed for that I-5 corridor section of real estate and applied dense urban planning standards to dense urban neighborhoods. And when we did this to Jefferson County, we put dense urban planning standards to building standards and code on rural residential prop – most of – rural residential zoned land, most of which applies to Jefferson County. And it’s hurt our building trades and it’s hurt people who want to split their property or develop their property. I know a lot of families that wanted to divide their property up into sections, and now it takes an attorney and ten to twenty thousand dollars to do it. Jefferson County, in the last 20 years that I’ve been here has been a leader in unemployment in Western Washington. It’s been consistently above 8%. When I moved here, we had 133 kids in Brinnon School, we started last year with 24. There’s been an exodus of school aged children and school aged children out of Jefferson County because there’s no work here. 87% of my kids in Brinnon School today qualify for free and reduced lunch. Which means they live in poverty. Over 50% of the school aged children in Jefferson County qualify for free and reduced lunch. They live in poverty. We’ve neglected economic development in this county. We need projects like this. …(indecipherable)…work with WSU and Community Development, was a quote by John Knight of Northwestern University who spent an academic career studying why communities thrive and why they fail: “Communities that thrive focus and build on local assets; Communities that fail focus on…put their energy into their needs.” And that is alive and well here. We need to thrive, and in order to do that we need to build local assets. This project is an asset. It’s taking a piece of real estate and making it an asset with Jefferson County. As many of you know, I ran for County Commissioner last fall and got an hour update on the dire situation the county is in terms of revenue. It’s going to put more and more pressure on property owners. We need this kind of development, that’s well thought out, that’s got global impacts in terms of infrastructure in order to have a future here. So I urge you to seriously consider moving this project forward. Thank you. John Adams, Brinnon: Can you speak for a moment on how the wastewater flow is going to work in the months of April when you’re not necessarily hydrating the golf course, yet you’re still April through June receiving lots of rainfall. …. It’s going to pond. And then infiltrate back into aquifer. Prevented from dispersing into the Hood Canal. …. Don (indecipherable – Scangee?), Brinnon: When this politic completed thing. How much impact would do to the home-owner in the tax consequences? Would it increase? How much would increase my tax? …. 9 10 11 8 cont. That’s a questions for the assessor. …. Don (indecipherable – Scangee?), Brinnon: But by doing this, it would increase the value of my property, correct? ….. Indirectly, but that’s a question for the assessor. …. Jason Willouby (?), Brinnon: Joe Baish’s question about employing people in the community. We just started this wastewater treatment facility here in the community, right? You guys probably know about it. Nobody here’s involved in that. So if everybody’s here worried about employment, why isn’t all these locally people who are employed up there – we never got the Voice and the-or-I think – employed the paper. If anybody knows anything about it, please back me up here, but it was never announced in our paper here in our community but it was in Clallam, Mason, so none of our resources here was able to even hear, because we didn’t know about it. I mean, so if everybody’s worried about these jobs and this, why in the frick aren’t we up there working on this wastewater treatment facility for the county of Brinnon? Why are we worried about this resort?...(indecipherable)…it boils my blood, because I need a job and there aren’t jobs up here. I got injured in a logging accident two years ago and I haven’t been able to work, but man, if everybody’s worrying about jobs and I don’t think anybody up here’s able to. Or nobody’s giving us the opportunity to….why don’t these companies require to hire locally? There’s many guys out there with a shovel and a rake who want to work. A lot of people don’t have internet access and smart phones, they check for notices and information at the post office. …. In the analysis, there may be as many as 253 jobs created during and after construction of the resort. …. Mike Weld: Two years ago, my wife and I went to a meeting and Garth Mann was here, and he filled this little sketchy thing up here that’s on the table for us to look at of what he had planned out, and we asked him where are you going to get the people to work this, and he said “well, I’m going to bring most of them in from China, because Chinese people work better than the American people do, and according quality work. So if he’s going to do bring in a lot of people from out of state, what good’s it going to do us to apply to work for them when he’s going to have other people from other countries do it? …. BOCC condition in the Development Agreement, regarding requiring advertising locally, recruiting locally, give preference to local applicants, providing they are qualified. …. Stew Engle (?), Brinnon: I think the thing to remember is, you don’t get the job if we don’t get the thing built to begin with. Jobs are almost secondary to this thing. We have to develop it, and then get the tax base, and the jobs a lot of them, I agree with you, aren’t living wage jobs. But neither are McDonalds. 11 cont. 12 13 14 They’re stepping stone jobs. If one doesn’t do it, then you work two. A lot of people in this community work more than one job. But I think the most important thing to remember is that the thing has to be built first. Nicole Black, Brinnon: The reference to the jobs, that actually came up in the 2007 meeting. That was one of the big topics and they all came forward in the EIS and were like – Hey we want to make sure we have…cause I was like, I know contractors…and want to make sure they take locals. The next thing I wanted to do was go back to something that Joe said about local assets. And he made a quick little assumption there that the resort is an asset. And it’s actually sitting on our asset. And our people are a local asset, and our infrastructure is a local asset. So before we just assume that this is a local asset, I want to consider what it’s going to take from and as we move forward, which I am pro, but I want to move forward in a very cautious way. I asked a question about the water because if we have to balance out equities between green grass, and water up the river, I hope that the MPR would say communicate, integrate – not just build and pull their selves away from the community, that’s not the way to do it, and I hope the Planning Commission really takes the time to look at all of the questions. These are good people, but they want to feel like they’re being heard and want to know that you guys are listening, and this gets done correctly. Richard Whitcom, Brinnon/County lines: I might go play golf it’s built, I’ll go to the restaurant. I go to the marina once a year, but one thing that’s going to impact all of us, whether you’re pro or con, nobody talks about it, is the highway. And it’s just a highway, but it’s really a lifeline. Go back to before the bridge was built – the bridge sank in ’80, and everybody comes up and down, they repair it, and everybody comes up and down. Think of Hoodsport, think of the light they’re going to have to put down there. It’s just a way of life that’s going to disappear, and that’s sad, because the road really, they can’t handle all this new traffic. There’s no problem there, because it’s a really under-utilized road but wouldn’t it be more likely a life line – so you make this decision to the Council, to the Commissioners, I’d put some weight on it. Because it’s going to be a future thing that might be cursed when the road’s to capacity and there’s only one road. It is – you know what’s going to happen, I was 36 years over in King County and I’ve seen a lot of us come and go, and I’m pretty worried this is going to happen. But how do you – it’s just such a big deal – there’s twice as much build out, so the road’s going to have twice as much traffic. It’s really going to impact everybody. So look at that point, and when the bridge goes out, which it will again, we can use one road. That’s all I can say. …. Yes, WSDOT has been involved all along. They were involved in scoping at intersections, etc., looking at safety, levels of service, shuttle transportation, and trip generation. …. Un-named commenter: Regarding the traffic study. The original level of service evidence was from the year 2000. The actual auto count was from the year 2006. During the entire traffic study, for some reason, none of the other segments of roadway accidents and incidents were included. Only accidents and incidents at intersections were included. Out of the 4100 car trips predicted per day, 65 percent are going to go up and over Mount Walker, that’s over 2600 cars a day over Mount Walker Pass. Mount Walker Pass is one of our more notorious roll-over points, including our own Sheriff’s department. 1200 cars will be traveling south, and the first serious corner is 1/10th of a mile South of Black Point Road. 14 cont. 15 17 18 Many roll-overs, in fact we have a chip truck that disintegrated there last year. We had a head on fatality collision between an SUV and an oil tanker trunk right in front of Canal Tracts. Further South, I believe it’s six miles, is McDaniel Cove. Everybody who lives around here knows how bad that is. None of those places were ever considered in this traffic study. Why? The majority of serious accidents do not occur at intersections. Everyone who’s here, knows that. …. Weren’t required to look at those incidents, due to the low count of those accidents. …. Don Haren (?), Brinnon: My thing was, or understanding, was that this is a destination resort, more so than something that’s going to have people here continuously. So, winter-time, very low traffic. What’s the main mode of transportation for people coming here? …. Both destination, and some stays. Automobile is main mode of transportation. There will be a van from the airport. And a van for tours. …. Un-named commenter: I guess I have a question about build-out, timing of build-out and…indecipherable…I live in Cape George, I have a (indecipherable) in Port Ludlow, and there’s been so many vacancies in both those areas. There’s the big hotel out there that is completely vacant. And I’m wondering where are the people going to come from? And if they don’t come at some anticipated level, you know, is there is this capitalized enough that the County isn’t going to get left with some bag for maintaining roads or other infrastructure? It just seems very very ambitious to me. Un-named commenter: I have another point regarding the traffic. The shuttle bus that’s proposed and the tour van that’s proposed in your traffic study it’s assumed that you’re going to have 100% capacity, which was supposed to take up to 260 car trips a day off of the 4100. Even in your study in the SEIS, you admit that that’s probably not going to happen. And I say, human nature, most likely will not happen. Another point that I have to make is that the Duckabush Rd itself is going to get 2% of the car trips, which is say 120 cars a day. Even if that’s a 10 hour period, that’s 12 cars an hour going up the Duckabush, which, half of the Duckabush, according to you is 11 foot wide lane widths, which it’s not. It’s 8 foot and then it goes into the Duckabush extension, which is forest service road. And then it goes to the Duckabush trail which can park approximately 30 cars for the M--- Falls trail, which has room for about 8. Where are those 120 cars going? …. One of the priorities in terms of traffic, is recreation. The assumption is that those cars will be recreating. …. Un-named commenter, cont: on top of that, the forest service has just done a study, and their usage of trailheads is up 25%. So we are experiencing a huge increase of car traffic, up my road in particular, and 18 19 20 21 22 where are all these people going to go? And what are they going to do? There is no fishing access past where I live, and I don’t know what they’re going to do. It’s going to be gridlock in the woods. Un-named commenter: The gentleman next to me here, you have an amazing capacity for the facts. It’s just awesome. I wish I had that. I guess, what I have to say is more anecdotal. We have – I spent 20 years living in the Sun Valley, Idaho, area. We also have a second home in Sun Peaks area in BC. And our home in the Sun Peaks area is kind of like the Duckabush. We didn’t buy in the resort village, we bought – it’s off a country road, 7 kilometers away. I can tell you that we don’t get anything. The impact – I don’t have numbers – but we don’t have a whole bunch of people driving down our road. Un-named commenter: I live on the Duckabush and there is more traffic on the road, and they speed on the road, and they kill livestock, they kill dogs, hit kids. We’ve had problems on the Duckabush. This needs to be considered. Un-named commenter: I would submit, though, that the type of people that resorts attract are going to be more interested in golf, and more interested in those types of activities. And I hear you, I understand that you have concerns. Un-named commenter: Do you live on the Duckabush? Un-named commenter: No. I ride my bike on the Duckabush all the time. So riding the bike up the Duckabush, there’s no lanes. Yes in the summer time, it’s really busy, and I get that. But, you know, I don’t know that that’s a reason to not let something – or to oppose something like this. We can all think of reasons not to have things changes, but there’s also, there are really a lot of positive things that can come out of this. Un-named commenter: Ma’am, I just want to address something you just said. It’s not about not wanting change or not wanting this to happen, it’s about recognizing the problems before they happen, having a little bit of fore-thought and saying let’s plan this so that we consider these kinds of problems, and build the infrastructure needed. John Dowd, Brinnon: After working 27 years for the Jefferson County road department, I can tell you there’s no forcing Jefferson County to maintain portions of the Duckabush road that’s only 8 feet wide in either lane. Only if there’s a broken piece of blacktop. George Sickel: Let’s turn more to the positive. Why should we be approving this? It will double the tax base in Brinnon. More than. I mean conservatively. Which means more taxes for the schools, for the fire department. They’re proposing a medical facility so we don’t have to travel to Shelton, to Port Townsend, to Silverdale to get medical services. There’ll be a sales tax increase. The County is already hurting. They’re spending more money than they have coming in, so they need to increase the tax base in one form or another. This’ll increase the sales tax base, the motel tax and then also look at the spin- off businesses that will occur. Nicole will be able to have more people riding her horses. There’ll be a shuttle service to be able to go to the casino – north or south. There’ll be hiking opportunities – guided hikes. That’s what those people would be doing, going up the Duckabush. There’ll be people here to go diving, and that’ll hopefully Don Coleman’s going to be able to add additional boats. There’ll be fishing opportunities. There’s so many good things that can come of this, and we have struggled now for 8 years. It’s going to be two more years at a conservative estimate when they’re going to be able to break ground here, so believe it or not it’s going to be 2020 before we even see this tax coming in. So, what 23 24 25 26 27 28 29 22 cont. do we want to do, do we want to put it off for another 5 years? Or do we want to have Garth pull his money out and subdivide that area into one acre, two acre or 5 acre tracts and have all these additional wells and septic systems? So think about those things, and don’t totally look at all the negatives coming out, but look at the positive things that this can do for our community, for all of South County, and for all of Jefferson County. Thank you. Un-named commenter: In return to Mr. Shickel’s comment, I don’t dive, I don’t golf, I don’t ride horses and I don’t do all the things that you described will happen to our taxes, but our taxes will increase and I don’t know about you but I live on a very fixed income, because I’m retired. I can’t really afford a lot of tax increase. Phil Dunster, Brinnon: My wife and I moved here about 7 years ago. We’re fortunate – more fortunate than most – because when we moved here, we brought our jobs with us. We telecommute. We work for a company that’s on the other side of the water. One of the things that makes me sick, is when I kind of needle out of people here that have to commute to places like Port Townsend or Shelton for their jobs, the price of fuel is high, negates and cuts off their income level because they’re traveling and they’ve got all these extra expenses – they’ve got more maintenance to do on their cars. For me to work out of my house is a real benefit for me. What I see here is that yes, there’s jobs being created here, but a lot of them being created may not be at the highest levels, but the ability to have a local job, to be able to put your local kids who are without having to worry about what am I going to do this summer. George mentioned the tax base – the County’s struggling. We’ve got budget cuts, revenue shortfalls. I think it’s time that we all realized that the resorts going to bring all this revenue, doubling the tax base. This is a key thing for us. Our residents are over-taxed. Property owners – my property taxes keep going up. Oddly enough, because of the restrictions on waterfront properties, waterfront properties are going down, so the County’s balancing it by increasing taxes off of waterfront properties. I’m not pleased about it and I’m sure nobody in this room that owns property is pleased about it. And really, what better way to pay your bills than from people bringing in money from out of the area? You know, that makes sense. We’ve going to increase our sales tax revenue from people that are coming here from out of County. Jefferson County’s biggest exports are dollars. When you want to go shop, there’s – a resident said to me the other day: You know, a good example of why people go to shop in Clallam County or Mason County or Kitsap County – you can’t even buy underwear in this County. It’s a basic necessity, and I thought it was funny when it was said to me, but really, it’s a reality. It’s one of the things I read online this week: They compared the resort to the dam on the Elwha River. And I thought that was kind of funny, because really, they were talking about the environmental impact and the dam and how it took a hundred years to correct it. Well, a lot more is known about the environment today and how to correct it, than there was in 1910. The EIS they’ve demonstrated that this is a low-impact development. This isn’t something that should be the way of the future, it should be the way of today. I think it’s time that we bring a little prosperity back to our county. Don Skangee (?): I travel to Port Ludlow over the years. I’ve been living here for 7 years. I have heard a lot of people from Ludlow share the same comments, the same concerns as here today. But look at Port Ludlow today, compared to what we could become like Port Ludlow. They’re more prosperous, they have businesses, bring in a lot more revenue. And so yes, I think that at the beginning it may be a little painful, because of inconvenience and this and that. But that is progress. I would love to live where I am now and don’t have any changes – no traffic so forth – but this place is dying, it truly is. I have a friend who looked for 3 years to find a job. He used to live on Duckabush. Couldn’t find a job anywhere, 29 cont. 30 31 32 had to move away, almost lost his house. I think a lot of time we’re so concerned about our individual comfort – I can understand that – but this place is dying. We don’t have anything to bring in and infuse the community. Have the opportunity to work – to go to school – better teachers. I think we’re fooling ourselves. Nothing will remain the same forever. If progress don’t come today, it will come tomorrow. Un-named commenter: I have two points. Progress is inevitable, it’s a question of how much the surrounding infrastructure can absorb it. The problem with a development of this scale is that this infrastructure’s going to get slammed. It’s going to have a very hard time absorbing all these impacts. Addressing George Sickel’s comment about taxes. This project which was originally supposed to be 4 -7 years, and now it’s 4-10 years, depending on how the economy goes, supposed to be built in phases. We could be seeing a 10 year period of just slowly kind of trying to get to the finished phased. It’s only after full build-out that the collection of taxes will have a positive effect. There will be a certain amount of revenue from the building phase, but a lot other negative effects. After the taxes are collected, 6.5 goes to the State, 2.5 goes back to Port Townsend to be distributed as the County seat sees fit. It doesn’t mean that any of that money is going to be used to take care of the infrastructure in Brinnon or the surrounding areas. The money that goes to the State goes to an open pool. And so, yes, in theory, this revenue is going to be a great boon to the County. But is it going to be a boon to the people who have to withstand the increased traffic, and not being able to get to the doctor if any accidents on 101, and the risk of losing their wells on Black Point. Is that tax money going to help those people? Un-named commenter: You plan on gradually building out to up to 890 units. What if you build 400 units and they’re not selling. Do you stop there? Or will you build out fully? …. The EIS said that build-out will occur at market demand. …. Chair asked for written comments, and closed the public comment period. 32 cont. 33 34 Pleasant Harbor Final Supplemental EIS Planning Commission Mtg. December 2015 2 Exhibit 2 PLANNING COMMISSION MEETING COMMENTS and RESPONSES Comment 1 As noted during the Planning Commission meeting, Brinnon Fire Hall has a complete, printed copy of the Draft SEIS and this Final SEIS. Comment 2 The project site area that is evaluated in this SEIS is 231-acres in size, which is reduced from the 256-acre site that was evaluated in the 2007 EIS. The project site was reduced to eliminate development in the Marina area. Development for maintenance, repair and renovation in the Marina Center (marina upland) area is limited to occur within existing building footprints, under a separate existing Binding Site Plan permit. No private land owners would be displaced by the proposed development evaluated in this SEIS, the project site is owned by the applicant. Comment 3 Please see Key Topic 4-2, Saltwater Intrusion, in Chapter 4 of this Final SEIS for a discussion on aquifer recharge and potential for aquifer impact. Existing data, testing, and calculations indicate that there is a low potential for the Resort water supply wells to introduce salt water intrusion. The wells would be operated in a manner so that pumping would not draw down water levels below sea level, consistent with established procedures for reducing the potential for sea water intrusion. Comment 4 Please see Key Topic 4-2, Saltwater Intrusion, in Chapter 4 of this Final SEIS for a discussion on aquifer recharge and potential for aquifer impact. Please also see the Responses to Letter 10 (Hood Canal Environmental Council) Comment 11, and Letter 8 (Brinnon Group) Comment 20 in Exhibit 1 of this Final SEIS for more information about the potential for salt water intrusion and testing that occurred to determine aquifer properties. Comment 5 Please see the Response to Letter 8 (Brinnon Group), Comment 20 in Exhibit 1 of this Final SEIS for more information about aquifer testing that was conducted to determine aquifer properties. Comment 6 The property referred to in this comment is surrounded by the project site, but would not be displaced by the proposal. An easement has been proposed through this property for an access road and utilities, however, it is at the property owner’s discretion to accept or decline this proposal. As part of the Proposed Action, it was assumed in the SEIS that a paved roadway (Marina Access Drive) would be constructed and available for walking, biking, electric vehicle, and Pleasant Harbor Final Supplemental EIS Planning Commission Mtg. December 2015 3 Exhibit 2 management/maintenance circulation between the Resort/Golf Course and Maritime Village and the existing Marina Building and Pleasant Harbor boat slips. Section 3.9 (Transportation), of the Final SEIS has been updated to clarify what would happen if an easement across private property is not negotiated and the Marina Access Drive is not built. Comment 7 A 40-foot wide easement over Watertouch Lots 1, 2, 3, and 4 (Watertouch Short Plat, originally recorded in 1992) granted joint access/egress for circulation, utilities, and other common uses among all property owners. The question on whether or not these agreements provide for cross-circulation currently proposed as part of the Pleasant Harbor Resort is under consideration. The upper paved road exists within this easement area, and was constructed in the 1990’s for the benefit access of the joint property owners. This asphalt road varies in width from approximately 11 to 13 feet, and under the Pleasant Harbor Resort Master Plan had been designed for pedestrians/bicycles and golf cart access. A separate vehicle access road also serves the property owned by the Richards, and was originally constructed as a gravel road in the 1980’s. This road is single wide and accesses through property owned by the applicant and terminates at the property owned by the Richards. The Pleasant Harbor House is currently accessed through a private road through the Marina property. It is proposed that this roadway would be upgraded extended and be continuous as and its existing connection onto SR 101 be closed. Please also refer to Comment 6 of this letter, above, for more information the easement. Comment 8 Thank you for your comments, your comments are acknowledged. Comment 9 Thank you for your comments, your comments are acknowledged. Comment 10 Wastewater process effluent will flow to the large central detention pond (Kettle B), from which it will be used for irrigation on the golf course and in landscaped areas year-around. Irrigated areas are intended as infiltration areas in the overall water management system for the Resort. Infiltration that occurs in these areas would recharge the aquifer constantly throughout the year. If the golf course is at times too wet to take more water through irrigation, provisions will be made to direct this water into the golf course roughs and forested areas, where it would also infiltrate. Please also see the response to Letter 40 (William and Roxianne Morris), Comment 8, in Chapter 5 of this Final SEIS. Comment 11 Please refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Pleasant Harbor Final Supplemental EIS Planning Commission Mtg. December 2015 4 Exhibit 2 Comment 12 Regarding local employment and advertising available positions at the resort, as detailed in Section 3.11 (Employment and Housing) of the Draft SEIS, the following mitigation measures identified by the Jefferson County Board of County Commissioners (BoCC) are applicable to SEIS Alternatives 1 and 2:  63 (e) Statesman shall advertise and give written notice at libraries and post offices in East Jefferson County and recruit locally to fill opportunities for contracting and employment, and will prefer local applicants provided they are qualified, available, and competitive in terms of pricing.  63 (dd) Statesman Corporation is encouraged to work with community apprentice groups to identify and advertise job opportunities for local students. Comment 13 Please see the above response to Comment 12. Comment 14 Thank you for your comments, your comments are ack nowledged. Regarding wages of employees operating the project, please see the Response to Letter 8 (Brinnon Group), Comment 1 in Exhibit 1 of this Final SEIS. Comment 15 Thank you for your comments, your comments are acknowledged. Comment 17 Please see the Responses to Letter 8 (Brinnon Group), Comment 19 and Letter 9 (Friends of Miller State Park), Comment 8 in Exhibit 1 of this Final SEIS. Comment 18 Please see the Responses to Letter 8 (Brinnon Group), Comment 15; Letter 8 (Friends of Miller State Park), Comment 8, and Letter 38 (Rob Mitchell), Comment 4, in Exhibit 1 of this Final SEIS. Comment 19 Automobiles would be the primary mode of transportation for visitors and residents travelling to the proposed Pleasant Harbor Resort. As noted in Section 3.9 (Transportation), the applicant proposes to purchase two shuttle buses to transport groups to/from the site and SeaTac Airport for conferences and other events. The shuttle buses would also be used for group excursions within Jefferson County and the Puget Sound area. Resort residents would also have the option of daily renting resort-provided electrical carts to travel between the Golf Course/Resort and the Maritime Village and for other internal trips. Pleasant Harbor Final Supplemental EIS Planning Commission Mtg. December 2015 5 Exhibit 2 Comment 20 Jefferson County requires payment of performance bonds for certain right-of-way and infrastructure improvement projects. As well, a site restoration bond would be required of the applicant at certain critical phases of development (such as Golf Course grading). Payment of these bonds would protect the County in the event that the applicant is unable to finish development. Comment 21 Please see the Response to Letter 40 (William and Roxianne Morris), Comment 5 in Exhibit 1 of this Final SEIS. Comment 22 Please see the Response to Letter 40 (William and Roxianne Morris), Comment 5 in Exhibit 1 of this Final SEIS. Comment 23 Thank you for your comments, your comments are acknowledged. Comment 24 Please see the response to Letter 40, (William and Roxianne Morris), Comment 5 in Exhibit 1 of this Final SEIS. Comment 25 Thank you for your comments, your comments are acknowledged. Comment 26 Thank you for your comments, your comments are acknowledged. Comment 27 Thank you for your comments, your comments are acknowledged. Comment 28 Thank you for your comments, your comments are acknowledged. Please see the response to Letter 40, (William and Roxianne Morris), Comment 5 in Exhibit 1 of this Final SEIS. Comment 29 Thank you for your comments, your comments are acknowledged. Please refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Comment 30 Please refer to Key Topic 4-1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Pleasant Harbor Final Supplemental EIS Planning Commission Mtg. December 2015 6 Exhibit 2 Comment 31 Thank you for your comments, your comments are acknowledged. Please refer to Key Topic 4- 1, Fiscal Considerations, in Chapter 4 of this Final SEIS. Comment 32 Thank you for your comments, your comments are acknowledged. Comment 33 Thank you for your comments, your comments are acknowledged. Comment 34 As noted in Chapter 2 of the Draft SEIS, the applicant proposes to complete the Pleasant Harbor Marina and Golf Resort over the course of approximately 10 years, or in response to market demand. Please refer to Chapter 2 of the Final SEIS for further details about project phasing.