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HomeMy WebLinkAbout027Michelle Farfan From: Sent: To: Subject: Attachments: Barbara Moore-Lewis < bri nnongrou p@gmai l.com > Wednesday, January 27,2016 6:57 PM PCCo m m iss i o n Des k@ co j efferso n.wa. u s; P I a nCo m m @ co j efferso n.wa. u s Comments on the Pleasant Harbor MPR FSEIS summaryBOPG(5) 1227 (76 2X3).pdf Attached are comments from the Brinnon MPR Opposition Group on the proposed MPR at Pleasant Harbor. We recommend the No Action Scenario A. Please reply to this email to confirm that you have received these comments. 1 1 BRINNON MPR OPPOSTION GROUP ISSUE SUMMARY Pleasant Harbor Marina and Golf Resort FSEIS The FSEIS proposes a Master Planned Resort (MPR)on a 23L acre site. There are 5 options: 1. 18-hole golf course, 890 residential units, 49,772 square feet of commercial space and resort amenities, 31 acres of natural area, and 2.2 million cubic yards of earth moved. 2. 18-hole golf course, 890 residential units, 56608 square feet of commercial space and resort amenities, 80 acres of natural area,2 million cubic yards of earth moved 3. 9-hole-golf course with 3 hold practice course, 890 residential units, 56,608 square feet of commercial space and amenities, 103 acres of natural area, and L million cubic yards of earth moved. 4. No Action Alternative Scenario A: Continuation of exisiting conditions with site's current land use designations 5. No Action Alternative Scenario B: Redevelopment of the site under existing land use designations with single family residential uses and a 9-hole golf course. We would recommend No Action Scenario A at this time untilthe following proposed mitigation is accomplished. When appropriate, this summary will break out the plan into issues when construction is in progress and issues afterconstruction is complete. lssues presented applyto both of the action choices. Construction forthis particular project is projected as being at least a 10year 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. 2 FSEIS ISSUE INSUFFICIENT FSEIS MITIGATION PROPOSED MITIGATION ORDINANCE 01-0128-08 lists a number of conditions about actions the developer needs to propose in the FSEIS It is unclear the way the FSEIS is written whether the conditions of the ordinance are being met. ln several instances, such as allowing other residents access to resort wells when there is salt water intrusion in the private well, the FSEIS appears not to meet the conditions. The developer to prepare a separate document listing the conditions from the ordinance and the ways they are being addressed in the FSEIS. This will allow both the public and local government to track compliance with the conditions. Although the marina is included in the MPR area and ordinance, construction, traffic, water usage, and waste water treatment for that site are not described in this document. The FSEIS covers 231 acres ofthe 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, Developing marina under existing site plan without local government or citizen review and input. Developer to revise FESIS to include all relevant plans for marina included in the MPR. Both local governments and the public have the right to know the actual impacts of the additional development. There are 2 "no action" scenarios in the FSE|S. These scenarios are not developed in the document in the way the three options for building the resort are developed. lt appears that no action scenarios were not actually being considered. There are insufficient details about the no action scenarios in the FSEIS to be able to make a reasonable comparison of options. Developer to prepare FSEIS document to include full details of no action scenarios. 3 FSEIS ISSUE INSUFFICIENT FSEIS MITIGATION PROPOSED MITIGATION ECONOMIC ISSUES State taxes are 9Yo of sales. 6.5% goes to Olympia and2.5% comes to Jefferson County. Taxes received can be spent anywhere in county, while the brunt of traffic and fire district costs are born by south county. We will pay levies attached to property taxes for school, fire department, and sheriff costs. Full tax revenue will not be available until Phase 4 and Full Build Out, while the costs will be present during the whole construction period. The developer and a few business owners are the only ones who will experience economic benefit. Local government and all county taxpayers will experience higher taxes/fewer services. Developer does not pay sufficient taxes to cover costs of infrastructure and public services needed by the resort itself, resort members, and resort employees. Draft development agreement specifically says that the county will not ask for more economic mitigation than is in the MOUs. Developer to identify true costs of infrastructure and public services during and after construction and arrange to pay those costs, above what is paid in taxes, to local and county government. A study in Oregon of similar destination resorts found that the standard model for a golf-course subdivision- oriented destination resort presents local governments and taxpayers with a substantial net burden (in the millions of dollars) that will result in either higher overall taxes or a decrease in the quality of basic services. Construction jobs like this are done by large companies who have out oftown sub contractors, and out of county su ppliers. The only jobs typically available to local people are minimum wage day laborers. Profits from the companies and wages from most of the workers will leave the county. Conditions set for the FSEIS require as much employment of county residents as possible, as much use of county contractors as possible, and sourcing construction materia ls from within the county. The FSEIS states that about L750 jobs 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 Sel a 20% threshold for contracts given to county residents and employment of county residents. Developer to calculate actual number of construction jobs over the 4 phases. Duri *H;Uiinstructiari 4 FSEIS ISSUE INSUFF!CIENT FSEIS M!TIGATION PROPOSED MlTIGAT!ON The average median income (AMl) in Brinnon is 542,679. The number of direct jobs created at or below 80% of AMI are 223, Construction and indirect jobs with an income of $34,L43 equal 342. 83% are considered poverty levet by U.S. Department of Health and Human Services standa rds. o 48 jobs are above AMl, ranging from 536,000 to isz,9t4o 108 jobs are S10,593 to Sr+,sero 127jobs are from $19,241to S28,ooo 2014 Poverty Guideslines of USDHHS: o Family of 5: 527,910o Family of 4: 523,850o Family of 3: 519,790o Family of 2: %L5,730 Creation of substantial number of poverty leveljobs in south county and an increased need for taxpayer funded health and social services. Developer to prepare a report of the services uses by employees with wages below the Brinnon AMI and an estimate of the cost of those services, Developer to pay for costs of services to these employees provided by tax funded entities, A report prepared of minimum wage jobs at Walmart estimated that Walmart costs surrounding communities St3 million in economic activity and S1+.5 million in lost wages over 20 years. 5 FSEIS ISSUE INSUFFICIENT FSE!S MITIGATION PROPOSED MITIGATION Taxpayers will subsidize life safety services ln 2013 there were 249 EMS calls for about 800 Brinnon residents. Add the estimated 2000 resort residents and there will be about 620 calls a year. The MOU with the fire department is for S3,333/month. This is not enough to hire another EMT, The inadequate funding can go for 10 years or more. Also, local fire department is responsible for alltraining costs and upkeep of used ladder truck Statesman will provide...all meaning higher local taxes for fire department. The developer says if the resort has trained EMT staff, they will 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 Sheriff's Department says no additional county resources will be needed if resort has private secu rity. Developer to prepare analysis of true costs of life safety services and to make provisions to pay for those services to local government entities. Developer to present plan for trained EMT staff. Developer needs to describe role and training of private security that will replace county sheriff staff. What will be their authority? Will they be able to ha nd le traffic accidents/fatalities and other emergences involving resort residents and/or Brinnon residents? Taxpayers will subsidize road improvement and repair for heavy equipment None Developer to prepare analysis of true costs of road improvement and repair and make provisions to pay for those services to state and local government entities lnternet service to local area is inadequate because of volume of use of existing equipment; resort use will compound internet access problems. None Developer to pay to upgrade internet infrastructure to the same speed consumers receive in the metropolitan areas. 5 FSEIS ISSUE INSUFFICIENT DSEIS MITIGATION PROPOSED MITIGATION About 280 jobs are projected, with the majority low income or minimum wage. lt's not clear how many of these jobs are part time or seasonal. Developer must build low income housing or provide land or money for it. Developer to state how many jobs are part time or seasonal. Developer subsidize rents for low income workers in the housing constructed or present evidence that wages will allow these workers to rent this housing. lf employees have their own housing, developer will pay for this housing the same as for employees who rent from the developer. Developer to pay for costs of services to these employees provided by tax funded entities. Developer will provide a 500 square foot clinic for use by medical personnel; use by resort members only. Developer to use local medical and hospital resources but to provide mitigation only for resort members. Developer to prepare analysis of true costs of life and safety services and to make provisions to pay for those services to local government entities, including local hospitals and medical services subsidized by local taxpayers. MOU with Brinnon schools specifies 52 per tee time to go to schools and scholarships to be given to Jefferson County school children. No estimate of real revenue from tee times. No dedicated fund for scholarships; no details of who will be eligible. Developer to prepare report on income to Brinnon school and on scholarships to Jefferson County children. For example, are home schooled children eligible? Money needs to be placed in dedicated account before construction begins that will cover scholarships After construction 7 FSE!S ISSUE INSUFFIC!ENT FSEIS M!T!GATION PROPOSED MITIGATION TRAFFIC Data used for the traffic study is totally inadequate. Highway 101 on the east side of the Olympic Peninsula is the only non toll direct connection to the l-5 corridor and is used for all major shipments of goods, as well as for residential and tourist traffic. When serious accidents occur, 101 is shut down for long periods of time, affecting both commerce and quality of life. There are serious economic, health, and safety costs for the entire Peninsula. The Loss of Service data is from 2000. The actual car trip count is from 2006. The data does not count accidents that do not occur at intersections (leaving out collisions with animals, McDonald Cove, and the tanker truck that exploded on the Duckabush hill. Consultants paid by the developer have consistently minimized both the effects of unsafe driving and unsafe driving conditions on 101 in their reports and in response to comments on their reports. The developer to do an up to date traffic report with data from2OL4 or later. This will include all accident reports between Olympia and 104. (The Peninsula Daily News reports that tourist trips increased25% during 20L4 and the Olympic National Park has similar data). Developer to present adequate mitigation for current traffic. Developer to pay for mitigation for projected additional traffic. Heavy equipment on highway, increasing congestion and accidents Developer says earth will be moved within resort area because it will be used for construction materials; no evidence gravel fits specifications Developer to present evidence that the earth moved from the site qualifies for construction use and provides data on the amount that will be moved on 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, excavators, bu lldozers, wheeled front loaders, a portable screening plant, feed-hopper, porta ble gravel crusher, finishing crusher, water trucks, conveyor belts systems, and vibratory/sheep-foot com pactor rollers. This will be 1200 feet away from the closest existing residence. None Developer to present report on noise impact on other Black Point residences and to propose mitigation. Developer to pay for mitigation. During construction 8 FSEIS ISSUE INSUFFICIENT FSEIS M!T!GATION PROPOSED MITIGATION There will be up to 4100 added daily trips from resort traffic on state and local roads; there was a 25o/o increase in tourist traffic in 2013 alone on the Peninsula; there will be bottlenecks in Hoodsport Buses will run to Seatac and visitors will take a route to resort that includes lengthy ferry waiting and heavy Seattle traffic instead of the easier ; traffic volumes calculated with out of date and incomplete data Developer to do traffic analysis with recent data on traffic volumes and with allaccident data. Developer will calculate road improvements needed from accurate traffic data and make provision to pay for those improvements. Developer to hold local meetings discussing traffic improvements with local residents before proceed ing, Developer to provide proof of estimates of bus usage. The increased traffic along Hood Canal will increase the nitrogen problems and dead zones in the Canal. Buses will run to Seatac and visitors will take a route to resort that includes lengthy ferry waiting and heavy Seattle traffic instead of the easier ; traffic volumes calculated with out of date and incomplete data. Developer to do an analysis of the environmental impact of the increased traffic on the health of Hood Canal, using current science, and propose mitigation. WATER 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 1,0+ years of construction adequate water must be proven. For each phase during the L0+ years of construction, adequate water must be proven. Developer must test the existing welland provide adequate data on drawn down rate and available volume. Developer must show adequate water supply not only for resort but for all Black Point wells, existing and future. Computer models which have been used are not acceptable. Developer must define what mitigation will be provided if volume is not sufficient and the aquifer is depleted for all wells. After construction 9 FSEIS ISSUE !NSUFFICIENT FSEIS MITIGATION PROPOSED MITIGATION The water supply well is developed below sea level and will always be susceptible to salt water intrusion or cause intrusion to the wells along the south and east coasts of Black Point. This is not a well used for testing salt water intrusion Yearly monitoring Require the developer to test the water supply well monthly for salt water intrusion and to submit the reports to the county health department. The salt water intrusion samples are taken from 3 Statesman wells that are not located where salt water intrusion is likely to happen Yearly monitoring Require the developer to test all water supply wells monthly for salt water intrusion and to submit the reports to the county health department. The developer is required by the ordinance conditions to provide access to the resort water system by any neighboring parcels if saltwater intrusion becomes an issue for them. Restrictive Neighborhood Water Policy that requires 3 years monitoring of private wells before a claim can be made and the developer to decide if claim is valid. County health department to decide if well has salt water intrusion. lf so, developer gives access to resort system at standard county hook up and monthly usage rates, Statesman's tests for salt water intrusion are to be collected quarterly, but to be submitted to the Department of Ecology once a year. This means residents 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. Yearly monitoring Require the developer to test the water supply monthly for salt water intrusion and to submit the reports to the county health department The pumping plan for the supply well will influence salt water intrusion None Require the developer to submit a pumping plan that will minimize salt water intrusion in resort and neighboring wells, rDUrins,const ucti-fi 10 FSEIS ISSUE INSUFFICIENT FSEIS MITIGATION PROPOSED MITIGATION There is one aquifer on Black Point, recharged by rainwater. The resort wells could deplete the aquifer. Water studies are done by computer modeling. Developer to do actual water studies on the property to be developed and to prove the availability of water for all residents. lnclude 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 intrusion in Black Point wells; resort wells could cause more salt water intrusion not only in adjacent wells but in resort wells as well. Put up a bond that would cover a desalinization plant. It is unclear how much water is projected to be used. Figures from 70 to 175 (standard usage) are in the document, Forcing waste water down wells to recharge the aquifer. Developer to do water plan with consistent numbers that fits with historical supply and not recharging the aquifer in this way. The aquifer is recharged by rainwater. There are extensive changes to the land that will affect the amount of permeable land. There is no information on how low rainfallyears would affect the assumptions of the water model. Because 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. None Developer to present a plan for drought years, taking into account the changes in the landscape to be made by moving at least 1 million cubic feet of dirt and rock. Developer to demonstrate that recharge rates will be as projected in DSEIS. After construction 11 FSEIS ISSUE !NSUFFICIENT FSEIS MITIGAT!ON PROPOSED MITIGATION 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, including Statesman conditions that they can demand additional evidence that they are at fault. lf the developer does accept fault, the owner may hook up, at Statesman's cost, to their water system and then they will have to pay for its use. This is also in conflict with the conditions DOE placed. Developer to rewrite Neighborhood Water Policy in concert with owners of local wells so that local owers' concerns are answered. County health department to facilitate this rewrite. The utility district 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. Sometime in the future the entire Sewage Treatment Plant will have to be replaced. Owners of private wells that are compromised by the water use of the resort and want to hook up to the resort water system will have to pay unspecified fees. The developer to clarify fee structure of utility district, including hook up fees and monthly fees for owners of private wells who use the utility district system. WASTE WATER No Class A water treatment system removes soluble chemicals. This means that the medications people use daily will not be removed from the water. Statesman plans to use the 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 aqu ifer. None Prohibit the developer from contaminating the aquifer with chemicals left from the water treatment or require water treatment that removes all chemicals. L2 FSEIS ISSUE INSUFFICIENT FSE!S MITIGATION PROPOSED MITIGATION OTHER All stormwater runoff from new pollution generating impervious surfaces must be treated before discharge to on or off site locations to comply with Stormwater Management Manual for Western Washington. FSEIS does not indicate how they are going to treat the water. Mitigation can help with stormwater runoff, but not eliminate it. Developer to prepare report on ways to mitigate the stormwater runnon These can include a 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). a a 13 FSEIS ISSUE INSUFFICIENT FSEIS MITIGATION PROPOSED MITIGAT!ON Moving soil releases the stability of the ground. Moving at least 1 million tons of earth at the site will affect the stability of the ground. lt will also affect the stormwater, all surface waters from rain and snow. This is runoff that does not collect in the ground. The plan to move stormwater to a retention pond. That pond will let the water sink into the aquifer, transferring the pollutants of construction to the aquifer. Less stability of the site 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, Storing stormwater in holding pond or allowing it to go into the Canal. Various methods of treating pollutants in water. Lack of information on chemicals (herbicides, pesticides, or fertilizers) that will be used for golf course grass maintenance or any discussion of how the developer plans to protect grou ndwater or stormwater runoff from the use of these chemicals. Developer to provide evidence that plans in the DSEIS treat stormwater to remove pollutants are realistic. The BMPs (Best Management Plans) for golf course maintenance needs to be explained in detail. Natural wetlands in the resort area will be cleared and used as retention ponds, These wetlands are pollutant removal systems and clean the ground water. Destroying wetlands will destroy the natural systems now intact and the wetland will no longer be able to help in natural filtration of stormwater. Wetlands mitigation plan has not been done. Developer to revise plan to leave wetlands as wetlands. The kettle with the wetland needs to be left as it is because this will help the project to clean some of the stormwater runoff that will be caused by this project. Developer to do wetlands mitigation plan before approval of DSEIS. Biosolids will be sent to Shelton for processing No proof of agreement about disposal of biosolids. lnadequate information on amount of biosolids. lncreased truck traffic for the biosolids. Unclear if this is included in the traffic analysis. Developer to prepare a report on biosolids, including proof of a plan to dispose of them and an estimate of truck traffic that will be generated. Mason County PUD #1 has agreed to supply power for the first phase. Lacking in details about PUD services to be supplied and how they will be funded; no mention of possible rate increase for all rate payers in PUD #1from increased energy usage. Developer to present agreement with PUD for public review, including possibility of rate increases for all rate payers. 74 FSEIS ISSUE !NSUFFICIENT FSEIS MITIGAT!ON PROPOSED MITIGATION The Geoengineer's Fish and Wildlife report states that Stream A is considered (Type F) fish bearing until it reaches a hung culvert, which prevents fish passage and makes the stream non-fish bearing (Type N). An impassable culvert alone cannot be used to justify classifying a stream as Type N waters (WAC 222-L6-031, and Section L3 of Forest Practice Board Manual). The Wetland Delineation Report has further details about the stream, including that it has a gradient barrier of over 2O%, bul this still does not preclude the water from upstream being typed as Class F if the habitat is sufficient. The FSEIS does not provide adequate detailto determine if the habitat is sufficient and if the stream is properly Type F or Type N, The FSEIS does not take into account WAC 222-16-031 and Section 13 of the Forest Practice Board Manual in determining the Type of Stream A. The developer to prepare a report on Stream A that gives more detail and supports the Type of stream.