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HCEC Comments on FSEIS MPR
HCEC email to JCPC on Pleasant Harbor MPR.docx
Enclosed please find the Hood Canal Environmental Council's written comments regarding the FSEIS for the proposed
Pleasant Harbor MPR. We request that these comments be entered into the public record.
Please send confirmation of your receipt of this e-mail and attachment
Thank you.
Donna Simmons, President
Hood Canal Environmental Council
(360) 877-s747
nana@hctc.com
t
Date: January 5,2016
To: Jefferson County Planning Commission
From: Hood Canal Environmental Council
Re: Final Supplemental Environmental lmpact Statement - Pleasant Harbor Master
Planned Resort
Hood Canal Environmental Council (HCEC) respectfully requests that the following written
comments regarding the Final Supplemental Environmental lmpact Statement (FSEIS) for the
proposed Pleasant Harbor Master Planned Resort (MPR) be included in the public record.
1 . lnadequate review time. The FSEIS was released by Jefferson County on December 9,
2015 with the public hearing before the Jefferson County Planning Commission scheduled
for January 6,2016. This coincides with the busiest holiday of the year. The public needs
more time to review and comment on the FSEIS, especially as this document contains
substantial changes compared to the Draft SEIS. We ask that the Planning Commission's
recommendation to the Jefferson County Board of County Commissioners (BOCC) be
delayed until all interested parties have had sufficient time to review the new material.
2. Support No-Action Alternative. HCEC continues to oppose the development alternatives (1,
2 and 3) and to support the No-Action Alternative. The newly added Alternative 3, with its
smaller 9-hole golf course, would involve less land clearing and leave more natural
vegetation intact. However, these benefits are far outweighed by the overall unavoidable
environmental impacts which, according to the FSEIS, would remain nearly the same as
Alternatives 1 and 2. As for the 2 scenarios presented in the No-Action Alternative, there is
insufficient information to make a reasoned choice between the two. Although Scenario A
would be preferable from an environmental standpoint, especially if existing regulatory tools
are enforced, the information on Alternative B appears to be based more on assumptions
rather than specifics. HCEC (or Jefferson County) cannot make a reasoned decision based
on "assumed designs and anticipated impacts."
3. Supoort Brinnon Group opposition. HCEC continues to stand behind the Brinnon Group in
its opposition to the proposed MPR. We concur with the comments presented by that
organization, especially regarding the potential economic and environmental adverse
impacts from construction and operation and the potential for dramatic changes to the rural
character of the Brinnon community and surrounding area.
4 Prevent Hood Canal pollution. All alternative proposals entail a significant increase in traffic
along Highway 101 , which hugs Hood Canal for many miles, and will inevitably increase
toxic non-point pollution from chemicals and metals washed by stormwater into Hood Canal,
poisoning aquatic life. Puget Sound Partnership's"Stormwater Strategic lnitiative 2016"
(see https://pspwa. app. box.com/s/b3ii eraen 1 whiazkitia0136klmtr20s)
should be applied, costs of potential mitigation determined, bonding required from the
developer to pay for all related costs, and funds administered through the Hood Canal
Coordinating Council's ln Lieu Fee (lLF) Mitigation Program
(see http://hccc.wa.qov/ln+Lieu+Fee+Mitiqation+Proqram/default.aspx).
5. National securitv issues exist. The fact that the U.S. Navy did not provide comments on the
Draft SEIS as stated in the FSEIS does not mean that it has no national security concerns
about the proposed MPR. ln its Draft Joint Land Use Study (JLUS), the U.S. Navy's list of
land use developments considered to be potentially incompatible with its operations includes
large master planned communities/resorts. Further, the Draft JLUS states that high intensity
planned units or planned rural residential development have been identified as a threat to
the Hood Canal Military OperationalArea and Dabob Bay Complex. Since Jefferson County
is a participant in the JLUS project it stands to reason that this issue should be part of the
conversation regarding whether allowing another large densely populated resort within the
naval range complex (Dabob BayiHood Canal) is advisable. This issue is likely to become
more important at a time of increased awareness of national security concerns.
6. lncomplete reports and aqreements. important reports and agreements have not yet been
completed. The Neighborhood Water Policy (NWP) agreement (2011) has not been signed,
and needs to better protect neighboring residents from potential financial burden in the
event of saltwater intrusion of existing wells. The report being drafted by the Mason County
P.U.D. to address the demand, capacity and availability of electric power has not been
completed. Other agreements with agencies are still in draft form. The public must review
these reports/agreements before any decision to move fonruard is made.
7. FSEIS inadequate and imoacts unacceptable. lssues and concerns raised by HCEC in its
December 30,2014 comment letter on the proposed MPR Draft SEIS have not been
adequately addressed in the FSEIS. Any perceived economic benefits from creating
another mega resort in this unique watershed are'far outweighed by the potential negative
environmental impacts. Approval of any of the development alternatives would likely result
in significantly higher density, more intensive land uses, major topographic alteration,
increased demand on groundwater and risk to the aquifer from saltwater intrusion,
significant demand on public services, traffic congestion on highway 101, loss of rural
character in the Brinnon area, increased impervious surfaces and stormwater runoff, loss of
open spaces, disturbance of wetlands, loss of wildlife habitat and potential security problems
for the U.S. Navy's Bangor Sub Base operations.
As the Jefferson County Planning Commission deliberates on the FSEIS, Development
Agreement and Development Regulations and prepares its recommendation to the Jefferson
County BOCC, HCEC is hopeful that the commission will place the highest priority on making
sure that the level of development chosen will have the least impact on the rural character and
environmental health of the Hood Canalwatershed.
Thank you for the opportunity to provide comments on the FSEIS for the proposed Pleasant
Harbor Master Planned Resort. HCEC looks fonuard to your response to these and others'
comments.
Donna M. Simmons, President
Hood Canal Environmental Council
P.O. Box 87
Seabeck, Washington 98380
(360) 877-5747
nana@hctc.com