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Christina Maloney, Owner / Operator
Kayak Brinnon
360-796-4116
Kayakbrinnon.com
Christi na Maloney < christina@kayakbrinnon.com >
Wednesday, February 03, 2016 4:17 PM
PlanComm@co jefferson.wa.us
Pleasant Harbor MPR Comments
JeffCoMPR20L6.docx
1
Christina Maloney
2380 Duckabush Rd.
Brinnon, WA 98320
February 3,2016
Jefferson County Planning Commission
621 Sheridan St.
Port Townsend, WA 98368
Pleasant Harbor MPR FEIS (December 2015) Comments
Dear Jefferson County Planning Commission,
With these comments I state my concern for the proposed Pleasant Harbor Master Resort as
described in the December 2015 Final Environmental Impact Statement (FEIS).
Comment #1 - Groundwater and Aquifer Recharqq
The discussion of theoretical groundwater recharge is contradictory and incomplete. The table
states that groundwater recharge would be greater under Alternatives 7,2, and 3 than under
current conditions because of more impervious surfaces and less vegetation. However, under
Alternative 3 it states that because there would be less irrigation occurring for a t hole golf
course than an 18 hole course that groundwater recharge will actually be higher than in
Alternative L There is no discussion of irrigation needs under Alternatives 1 or 2 or any type of
calculation of irrigation needs for Alternative 3. There is also no calculation of evaporation from
holding ponds and irrigation, and there is lack of discussion concerning the quality of water
leaching into the aquifer after it's been treated with fertilizers, running off pavements, and other
contaminants that may run into holding ponds and seep into the aquifer.
Comment #2 - Fish
The table states that a sewage treatment plant will be built to treat grey water to irrigate the golf
course under all three alternatives. There is no analysis of how grey water sewage spread over
the golf course acreage will affect the aquifer. I also find it strange that under No Altemative -
Scenario B that resort developers would choose to build homes on the "beachfront riparian edge"
where they say "greater impacts to the natural habitat could result". If there will be greater
impacts to this cliff above the beach it sounds dangerous for home owners and also sounds like a
bit of a threat.
Comment #3 - Wildlife
There is no such animal as Rainier Elk (Page 1-8, Table 1.1). The correct species is Roosevelt
Elk. This surprising mistake makes me skeptical of the accuracy and thoroughness of the FEIS's
analyses of impacts to wildlife. Furthermore, Black Point is home to a relatively large
population of Black Bears as most people living on Black Point would attest to. Black Tail Deer
are also a well know inhabitant of Black Point. The FEIS states that235 acres of Black Point
will be gated with "exclusionary fencing" to keep elk out. Therefore, no large wildlife will be
able to access the grounds except perhaps Cougar which there is also no discussion of. The FEIS
states that there is no "suitable habitat" for elk. A11 environments in the Brinnon area are suitable
for elk. I've witnessed elk on grasslands, forests, riparian areas, ponds, gardens, highways and
even on the beaches and tidelands. The FEIS states that "wildlife corridors" will be available
within the gated and fenced community. I suppose they mean only for wildlife such as squirrels
and birds. To summarize,the Wildlife analyses of this report is grossly incomplete and
inaccurate.
Comment #4 - Threatened and Endangered Species
As a former author of Threatened and Endangered (T&E) Species analyses portions of EIS's all I
can say, is there isn't one in this document. Each T&E species found in Washington State
should be addressed and if a species does not occur in the area, then the document must simply
state this and provide a source for their information. Furthermore, State listed species and State
species of concern are not addressed at all in the document. A complete analysis of all State and
Federally listed species that could occur in the area must be included in the document.
Commgnt #5 - Transportation
The conclusion that 2 shuttles vans running to and from the airport and adding a bus stop will
result in having an "insignihcant" effect to the rural character, the environment, or to public
safety to the project's increased traffrc is preposterous.
Comment #6 - Construction Impacts
The project's construction traffic approximates 250 vehicle trips per day, 5 days per week for 10
years for Alternatives 1,2, and 3. For those of us who live in Brinnon, especially us living on
Duckabush Road and on Black Point, this will result in major impacts to our neighborhoods,
lives and safety.
Comment #7 - Air Ouality
There are calculations of pollutants that will be emitted due to construction activities but no
analysis on how the environment will be affected by these pollutants.
Comment #8 Employeruent and Housins. Lone Term Housine Conditions
Section 3.12-5 of the FEIS states that for all three alternatives "[o]f the 764 permanent residents,
208 are assumed to be resort employees living in the 52 units of worker housing". "This housing
can also be considered as permanent housing and it is expected that up to four people could
reside in each unit year round, resulting in a permanent staff population of 208; thus, a total of
764 permanent residents would be expected on the site". This is making the assumption that 208
staff members will be single people bunking together in apartment units. Not only is this
improbable but I am curious as to how you can stipulate that the workers do not have families. It
seems more likely that these low wage service workers will be commuting from outside the area
and have children and spouses. Shelton has a relatively large population of seasonal workers. It
would be expected that many of these workers would relocate to the Brinnon area where there is
no rental market creating potentially unsanitary conditions for families living in moldy trailers
potentially with failing septics or without septic systems or running water at all.
Comment #9 - Operational Employment
The FEIS states that they expect a workforce of 225 people to work within the resort and that
these'Jobs would include opportunities in tourism and leisure, hospitality, restaurant and food
service, med-spa/grotto, maintenance and security, and environmental standards management".
There is no mention of the tourism and tourist lodging businesses that the resort has already
displaced, Kayak Brinnon and House Boats for Two. The eviction of House Boats for Two
resulted in a loss of 2 jobs including the owner, and the eviction of Kayak Brinnon, my business,
resulted in a great income loss to my family. The Resort's owner Garth Mann has shown his
great disdain for local business owners, his employees, and residents of Brinnon creating a
profound distrust of his business practices and intentions. He does not behave as someone who
wants to partner with the community but one whom wants to control it. Another concern
regarding the jobs he intends to create is the issue of inviting over 250 low wage workers to this
area. The EIS states that 208 of these positions are expected to be permanent, however I am
highly skeptical of this and would expect that most workers will be laid off every fall letting our
state welfare system, Oly Cap, and our local food bank pick up the slack. The last thing Brinnon
needs is a huge influx of low wage families into the area.
Comment #10 - Indirect Employment Impacts
The FEIS states, with poor grammar "Additional residents in communities surround[ing] the site
could result in increased retail and service spending an*[at] local businesses". I initially
believed this statement to be true until my business was evicted from the marina property and the
marina owner, Garth Mann, bought a fleet of kayaks and paddle boards to absorb my clients and
compete with my business. It seems the resort owner is more interested in reducing employment
in the community at business besides his own. Furthermore, in a discussion I had with a local
vacation rental property owner, I learned that in the last 3 years the number of vacation rentals on
the Hood Canal has tripled due to VBRO and AirB&B. She has lost so much business due to
this increase in available vacation properties that she is considering selling her vacation rental
property in Brinnon if the resort is built as proposed, as adding 560 short term vacation
properties to Brinnon will skyrocket the current glut of available vacation rentals in the area.
She will be a third small business owner run out of Brinnon if this occurs.
Thank you for your time and considering my comments when making your decision.
Christina Malony, Owner / Operator
Kayak Brinnon