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DEPARTiIENT OF COiIUUNITY DEVELOPMENT
621 Sheridan Sbeet I Port Townsend, WA 98368 | Web: www.co.iefferson.wa.us/communitydevelooment
Tel: 360.379.'1450 | Fax 360.379.4451 | Email: dcd@co.iefferson.wa.us
Building Permits & /nspecfibns lDevelopment ConsisfencyReviewlLong Range Planning I Sguare One Resource @nter
NOTE TO FILE - March 29, 2015
RE: Pleasant Harbor MPR Phase ll - Staff Response to Port Gamble S'Klallam Tribe (PGST) letter dated
March 75,2OL6 (attachment #1)
Staff and the Planning Commission received the attached letter, and for the record, staff is providing this
response as a way to address the issues contained in the letter. This Note to File will be provided to the
Planning Commission prior to its public meeting of April 6,2016.
As part of the Phase I approval for a Comprehensive Plan amendment to designated property for a
future MPR, the Board of County Commissioners imposed 30 conditions of approval (Ordinance No. 01-
0-0128-08). Staff made clear, and the applicant agreed that meeting the conditions prior to signing the
development agreement, was the responsibility of the applicant. Also, the concerns of the PGST stated
in their letter dated March 75,2OL6 related to Cultural and Natural Resources, concerns that were
thoroughly analyzed in the SEIS as required by SEPA.
Consultation with the PGST: The followi ng actions were taken by the Applicant and Staff to meet the
above state and local requirements, including any requirement to consult with tribes
1. The Consultant who drafted the Cultural Resources Management Plan sent letters to all six local
tribes including the PGST requesting consultation on identifying cultural resources on-site
(attachment #2). The Skokomish Tribe was the only one to respond.
2. On May Lt,2Ot2, the applicant sent the PGST the Cultural Resources Management Plan dated
March 27 ,2OL2 (attachment #3). The PGST did not respond to this request to review and/or
comment on the plan.
3. ln order to facilitate coordination and consultation with the Tribes, staff elicited the assistance
of the State Department of Archaeology and Historic Preservation who sent Staff a letter dated
January L4, 2013 (attachment #4) confirming that "three tribes had concurred with the plan and
three others did not comment."
4. On November L9,2OL4, Staff released the draft SEIS for public and agency comment. The PGST
was sent the notice of availability on November 18, 2014.
5. Staff received a comment letter on the Draft SEIS from the PGST on January 5, 2015 (attachment
#5 - date stamp ol 2074 in error). The letter requested "the opportunity to consult more
directly with the project applicant and Jefferson County." As such, staff contacted the Tribal
representative Roma Call and scheduled a meeting on-site.
6. On February 18,2015, Staff and the Project Manager, Craig Peck met with representatives of the
PGST to discuss their concerns. As we recall, the topic of cultural resources and the Kettles was
not discussed, but water quality, shellfish and elk were. At the conclusion of the meeting, Tribal
Representative Roma Call asked if the Tribe could submit a request to the County to include
additional monitoring for water quality. Staff agreed to review any request submitted by the
Tribe, and indicated there would be time for them to submit their request.
7. DCD does not provide notice to interested parties that the Final SEIS is about to be released and
SEPA does not require that such notice of impending Final SEIS publication be provided.
8. On December 9,20L5 the final SEIS was released ten months after the meeting with the PGST,
sufficient time for PGST to submit their request. The release of the final SEIS included a four
page response to the PGST's comments on the Draft SEIS (attachment #6)
9. On December 16, 2015, staff received a letter (attachment #7) regarding a 50 day request to
"complete the Tribe's consultation." The letter also confirms that, "although the document
(FSEIS) covers potential environmental effects to some extent, we are concerned that it does
not go nearly far enough to resolve the potentially significant impacts to E!.bd!g3lllig.h.t5,."
10. On January 22,2076, The Planning Commission and staff agreed to grant the PGST 50 days to
"complete the tribal consultation process," as requested (attachment #8).
11. On March L5,2OL6, the PGST submitted the subject letter (attachment #1) requesting that
"Jefferson County work with the developer and the PGST to implement the following mitigation
actions, and meet the requirements of Ordinance No. 01-0128-08" (the 30 conditions of
approval). From the perspective of DCD, the March L5,2OL6letter formally concluded the
consultation process between the PGST and Jefferson County which began on February 18,
2015.
Conclusions:
Based upon the attached correspondence, DCD concludes the consultation process between PGST and
Jefferson County began on February t8,2OL5 and was completed on March 75,2016 with submission of
the subject letter (attachment #1). The task now is to "continue to work with the developer and PGST
staff' to determine which proposed actions items warrant imolementation.
Although the PGST acknowledges that the FSEIS "covers potential environmental effects to some
extent," it is clear that the PGST believes the SEPA analysis and proposed mitigation, while presumed to
be compliant with State law, does not meet the environmental protection standards the Tribe asserts
are necessary to protect tribal treaty rights.
Ordinance No. 01-0128-08
The following conditions of approval under Ord No. relate to the PGST:
j) Tribes should be consulted regarding cultural resources, and possibly one kettle preserved as a
cultural resource.
Staff Comment: The word "should" indicates that discretion is allowed, while the word "shall" is
mandatory (JCC 17.05.040 Port Ludlow MPR Code).
Aoplicant Compliance: The applicant collaborated with the Skokomish Tribe in preparation of the
Cultural Resource Management Plan (attachment #3) and letters requesting consultation were sent to
the PGST and other local Tribes prior to drafting the plan. Kettle C will be preserved as part of the
proposal.
k) As a condition of development approval, prior to the issuance of anv shoreline permit or approval of
anv preliminarv plat, there shall be executed or recorded with the County Auditor a document reflecting
the developer's written understanding with and among the following: Jefferson County, local tribes, and
the Department of Archaeology and Historical Preservation, that includes a cultural resources
management plan to assure archaeological investigations and systematic monitoring of the subject
property priorto issuing permits; and during construction to maintain site integrity, provide procedures
2lPage
l) A wildlife management plan focused on non-lethal strategies shall be developed in the public interest
in consultation with the Department of Fish and Wildlife and local tribes, to prevent diminishment of
tribal wildlife resources cited in the Brinnon Sub- Area Plan (e.g., deer, elk, cougar, waterfowl, osprey,
eagles, and bear), to reduce the potential for vehicle collisions on U.S. Highway 101, to reduce the
conflicts resulting from wildlife foraging on high-value landscaping and attraction to fresh water sources,
to reduce the dangers to predators attracted to the area by prey or habitat, and to reduce any danger to
humans.
Staff Comment: Staff agrees with the PGST that the wildlife management plan and the Habitat
Management Plan are not the same thing.
Applicant Compliance: The applicant has not complied with this condition and will need to consult with
the local Tribes and the Department of Fish & Wildlife when drafting the plan.
Staff Recommendation: This plan shall be required prior to land disturbing activity for Phase 18
SEPA
ln addition, proposed JCC 17.80.050 Environmental review for Resort Plan development requires
additional environmental review for all project level applications which requires completion of a SEPA
checklist, notice to Tribes, among others, and a SEPA determination. Should the determination require
more environmental study such as a Supplemental ElS, the Tribes will have the opportunity to be
involved in the scoping of that environmental study.
Staff Recommendations:
Beyond the recommendations above, staff recommends the following to satisfy the concerns of the
PGST and others:
The applicant may adopt any or all of the following options and the County may only require
implementation of such options or mitigations as are necessary to comply with one or more of the 30
conditions listed in Ordinance #01-0128-08 at Finding #63. Applicant's options include:
L. Redesigning the stormwater and wastewater management systems to completely avoid the use
of Kettles B & C, or in the alternative;
3lPage
regarding future ground-disturbing activity, assure traditional tribal access to cultural properties and
activities, and to provide for community education opportunities.
Staff Comment: Since the Maritime Village was relocated outside the Marina, and no new development
will take place within Shoreline jurisdiction, no shoreline permits are likely to be required or applied for.
Also, the applicant could process the development zones and residential areas with a Boundary Line
Adjustment instead of a Plat, unless there would be a sale or lease of new parcels. However, the intent
of this condition is to ensure that cultural resources are protected.
Applicant Compliance: The Cultural Resource Management Plan (attachment #3) is intended to comply
with this condition, however, it does not appear to contain provisions for notification of Tribes to assure
traditional tribal access to cultural properties and activities, or to provide for community education
opportunities.
Staff Recommendation: revise the Cultural Resource Management Plan in consultation with the PGST to
include provisions for notification of Tribes of ground disturbing activities, to assure traditional tribal
access to cultural properties and activities, to provide for community education opportunities, and to
ensure that contact information is current. This revised Plan would be recorded with the Auditor and
referenced as a requirement in the Development Agreement.
2. lmplement and complete Actions 2 thru 5 of the subject letter, to include educational
opportunities related to the uniqueness of these geologic features.
3. lmplement and Complete Action steps 8, 9 & 10 of the subject letter.
4. lmplementand Complete a combination of L & 3 above or2 & 3 above.
5. Meet with the representatives of PGST and arrive at a different set of mutually agreeable
mitigations that address the concerns the PGST expressed in the March L5,2076letter.
6. Reduce the number of residential units proposed to 445 - half of the 890 approved units under
Phase 1 and Ordinance #01-0128-08.
7 . Take no action in response to the March L5,2OL6 sent to DCD by the PGST.
Jefferson County recognizes the PGST as a specific party of interest, and as such will be notified of all
project level development applications that require notice, including any SEPA Threshold Determination
as outlined in proposed JCC 17.80.050. Jefferson County cannot grant the PGST any special provisions
under the development regulations that are not granted to other parties, nor can it codify requirements
before determining what those requirements are.
b
Associate Planner
4lPage
Attachment #1
PORT GAMBLE S'KLALLAM TRIBE
31912 Little Boston Rd. NE - Kingston, WA 98346
-- -l -'. ','
,,-, r,r.
March 15,2016
Jefferson County Planning Commission
621 Sheridan Street,
Port Townsend, WA 98368
Email: PlanComm@co j efferson.wa.us
shR 15 2t16
David Wayne Johnson
Pleasant Harbor FSEIS c/o Jefferson County DCD
621 Sheridan Street
Port Townsend WA 98368
Email: dwi ohnson@co. i efferson.wa.us
Subject: Pleasant Harbor Final Supplemental Environmental Impact Statemen!
December 2015, Case No's: MLA08-00188, ZON08-00056
Dear Planning Commission Members and Mr. Johnson,
On behalf of the Port Gamble S'Klallam Tribe (PGST), the following comments are provided
with regard to the Final Supplemental Environmental Impact Statement (FSEIS) and Intent to
Amend the Unified Development Code for the Pleasant Harbor Marina and Golf Resort LLC
Master Planned Resort (MPR). We request that Jefferson County continue to work with PGST
staff to implement the actions described below. These actions are intended to serve as
mitigation for the potentially significant effects of the proposed project on cultural resources
and the Tribe's treaty rights and are also consistent with the conditions required under
Ordinance No. 01-0128-08.
The Port Gamble S'Klallam Tribe is the successor in interest to Indian bands and tribes
signatory to the 1855 Treaty of Point No Point, l2 Stat. 933.1 Today the Tribe retains deep
cultural and economic ties to the surrounding waters and to their fisheries in its usual and
accustomed grounds and stations (U&A). More than a century of federal court decisions have
fleshed out the components of the treaty right, including the right of access to places, the right
to a share of harvest to meet tribal moderate living needs, and the right to protection of fish
habitat. Maintaining access to the entire terrestrial and marine landscape that was used by
tribal ancestors is also of critical cultural importance, and helps to define the Tribe's identity.
The proposed Pleasant Harbor project is located within the Tribe's U&A, in an area where
tribal members depend on fish, shellfish and wildlife.
In 2008, the Jefferson County Board of County Commissioners (BOCC) adopted Ordinance
No. 01-0128-08, listing 30 special conditions to be required for development approval under
the Comprehensive Plan amendment to allow a Master Plan Resort within an area zoned
Rural Residential. "Consultation with the Tribes regarding cultural resources, and possibly
one kettle preserved as a cultural resource," is included as a requirement in the list of
conditions for development approval. The BOCC ordinance also requires a document to be
executed or recorded with the County Auditor, reflecting the developer's written
'Urit"dStot"sv. Washington,459F. Supp. 1020, 1039(W.D.Wash. 1978)(hereinafterEoldtll).
PORT GAMBLE S'KLALLAM TRIBE
31912 Little Boston Rd. NE - Kingston, WA98346
understanding with and among the local tribes, as well as other entities, in order to maintain
site integrity and to assure traditional tribal access to cultural properties and activities. The
BOCC ordinance also requires the applicant to develop a wildlife management plan focused
on non-lethal strategies in the public interest in consultation with the Department of Fish and
Wildlife and local tribes. The other special conditions for development approval focus on
additional measures for environmental protection and other issues also of concern to the
Tribe.
With the release of the FSEIS for this project, it is questionable as to whether Jefferson
County's Community Development Department (DCD) made a good faith effort to consult
with the Port Gamble S'Klallam Tribe. In order to meet the BOCC special conditions in
Ordinance No. 01-0128-08, we understood that Jefferson County would work directly with
PGST during the development of the FSEIS, including the supporting documents in the
appendices. However, the Tribe was not consulted during the development of the FSEIS and
our comments were not incorporated. The FSEIS Volume 2 Appendix O includes a Proposed
Plan for Archeological Monitoring and Inadvertent Discovery Protocol, DAHP Response to
the Cultural Resource Plan and the Skokomish Tribe's Response to the Cultural Resource
Plan. However, this section does not go nearly far enough to resolve PGST's concerns and to
mitigate project effects with regard to cultural resources and tribal treaty right impacts.
The Centennial Accord (1989) and the New Millennium Agreement (1999)2 established a
basic framework and provide the general foundation for relations between the Tribes and
Washington State. The Government-to-Government Implementation Guidelines3 were
developed in order to provide a consistent approach for state agencies and tribes to follow in
implementing the Accord, and are applicable to local governments. In the context of the
government-to-government consultation process, we expected the Jefferson County DCD to
work with us to address the concerns raised at the February 2015 meeting and in our written
comments. Yet PGST was not consulted after the February meeting and was not provided
with any schedule or notification of the FSEIS prior to its release. We find the Jefferson
County DCD consultation process with the Port Gamble S'Klallam Tribe to have been both
inadequate and negligent.
As stated in our previous comments in 2001, 2006,2007 and2015 regarding this project, we
are concerned about the potential for adverse effects on cultural resources and treaty rights
from the loss of wetlands and rare kettle ponds, increased traffic, intensity of land use for
commercial and residential development, significant alteration of hydrology, clearing and
grading, increased impermeable surface, use of persistent pollutants, and other proposed
project effects.
The MPR project would be located in an aquifer recharge area and would signihcantly impact
kettle ponds and wetlands. The project proposes to remove 20,700 sq. ft. of wetland and
associated buffers in and around the largest kettle, Kettle Pond B, for the purpose of creating a
control pond for storing stormwater and treated wastewater. The Kettle Pond B wetland
2 Governor's Office of Indian Affairs: http://www.goia.wa.gov/government-to-govemment/data/agreement.htm
3 Governor's Office of Indian Affairs Implementation Guidelines: http://www.goia.wa.gov/government-to-
govemmenUData/guidelines.htm
2
PORT GAMBLE S'KLALLAM TRIBE
3191.2 Little Boston Rd. NE - Kingston, WA98346
would be cleared of vegetation, filled and lined. The proposal provides inadequate
compensatory mitigation for these effects with the plan to manufacture a wetland in existing
Kettle Pond C that would also serve as a stormwater runoff basin for the project. Impacts to
flora and fauna in the Kettle Ponds and wetlands would likely have significantly adverse
effects on both cultural and natural resources.
Additionally, we are very concerned about the effects of persistent pollutants on water quality
in groundwater, wetlands and streams from the proposed use of pesticides, fungicides and
other chemicals in the project area, and potentially the Hood Canal, Duckabush and
Dosewallips River systems during overflow events. The project would removs 55Yo of
existing trees and native vegetation replacing it with impermeable surfaces and landscaping.
The project also has the potential to impact wildlife, including a migrating elk herd in the
project area. It would increase vehicular traffic along highway, roads and parking lots and
would degrade water quality in Hood Canal through stormwater runoff, impacting the Tribe's
fish and shellfish resources. The developer commissioned a study of the number ofjobs
expected to be created as a direct or indirect result of the MPR. However, an analysis of the
risks to fisheries, an existing economic base in the area for tribal members and others, was not
incorporated into the study. The proposed compensatory mitigation in the FSEIS does not
effectively and sufficiently offset these effects.
Due to the potential for significant impacts to tribal fisheries and cultural resources we request
that Jefferson County work with the developer and PGST staff to implement the following
mitigation actions, and meet the requirements of Ordinance No. 0l-0128-08.
A. Cultural Resources and Stewardship
Action 1: Preserve Kettle Ponds B and C and adjacent wetlands for a traditional
property evaluation and the protection of cultural resources. Conduct a traditional
cultural property evaluation to determine the eligibility of the kettle ponds and
wetlands to the National register. Evaluate the impacts of the proposed project on the
cultural integrity of the area and its eligibility to be listed on the National Register of
Historic Places. Redesign stormwater and wastewater management plans to avoid the
destruction of wetlands and the alteration and use of Kettle Ponds B and C for
stormwater and treated wastewater storage.
Action 2: Schedule a site visit with PGST staff to view the kettle ponds and other
areas of cultural significance.
Action 3: Provide a biological inventory of plants, amphibians, birds and other species
that are currently present in Kettle Ponds B and C and those that were likely present
prior to timber harvesting and other disturbances.
Action 4: Consult with PGST Cultural Resource Dept. staff to schedule site
monitoring, particularly during ground disturbing activities.
Action 5: Develop a Stewardship Plan that provides for the restoration of traditional
plants in the project area and the opportunities for tribal access to cultural resources.
According to oral tradition and knowledge, the Brinnon area, including Pleasant Harbor, holds
cultural resources of great value to the Port Gamble S'Klallam people. Uncommon geological
J
PORT GAMBLE S'KLALLAM TRIBE
31912 Little Boston Rd. NE - Kingston, WA 98346
features, such as kettle ponds, are often linked to spiritual and cultural knowledge that is
passed through the generations. The area was known as an important place for gathering and
processing traditional foods and materials needed to support a productive livelihood. The area
was known for its abundant provisions of reeds and other thrush materials.
The Port Gamble S'Klallam Tribal Historic Preservation Officer (THPO) has provided a
separate letter describing the significance of the site as a traditional cultural property and
challenging the DAHP determination, which did not involve any consultation with the Port
Gamble S'Klallam Tribe's TPHO officer. The proposed action would impact the integrity of
this site, which by oral accounts has cultural and spiritual significance and contributes to
regional Native American history. Based on historic Native American place names, camping
locations, and oral traditions regarding spiritual entities associated with the landscape, the site
has the potential to yield more information about the unique history and use of the area by the
S'Klallam people. The site is representative of unique geology and unique plant communities
and has been actively used within living memory for traditional plant gathering and cultural
practices.
We have great concern with the continued diminution of cultural resources linking the Tribe's
ancestral ties to the land and water. To see its natural resources, such as the rare kettle ponds,
forever changed is deplorable to tribal members. The Tribe seeks to preserve and restore its
natural landscapes in order to reserve the ability to teach its children and future generations
the traditional knowledge and culture that defines it. The County should work with tribal staff
to plan and implement the stewardship of these resources.
B. Shellfish Resources Protection and Management
Action 6: Consult with PGST Natural Resources Dept. staff to develop and implement
a plan for the protection and restoration of tribal shellfish resources. This will include
the following:
a) Protection oftidelands adjacent to the project area,
b) Shellfish seeding and enhancement on Duckabush and Dosewallips River
beaches where tribal members harvest, and
c) Response plans in the event of any water quality incidents or other project-
related activities that would result in a downgrade of shellfish harvesting
areas by the Washington State Deparfment of Health.
The Black Point Resort will be located between two public beaches (the Duckabush and the
Dosewallips) which provide both significant commercial and ceremoniaVsubsistence harvest
opportunities to the Tribes with Usual and Accustomed fishing rights in the area. The two
delta flats are two of the three most important intertidal areas to Tribal harvesters based on
acreage available, habitat available and existing natural manila clam and pacific oyster
production. The Duckabush and Dosewallips tidelands combined supply over 75%o of tribal
resource for pacific oysters from public tidelands.
The increase in visitors, both temporary and permanent residents, is expected to increase the
harvest pressure on the Duckabush and Dosewallips tidelands. Natural recruitment of bivalves
4
t/'
PORT GAMBLE S'KLALLAM TRIBE
319L2 Little Boston Rd. NE - Kingston, WA98346
in Hood Canal is sporadic and increased pressure from additional harvesters without an
annual enhancement will result in a decline in the existing resource over time. In addition,
both tidelands have areas of concern to the Washington Department of Health (DOH). In
2015, DOH reported that one water sampling location on Dosewallips and two locations on
Duckabush were in Threatened status and an additional location on each tideland were falling
into Concemed status. Additional system overflows into the Duckabush or contaminated
stormwater runoff from the increase in impervious areas could result in poor water quality in
the rivers leading to problems with shellfish on the tidelands. A closure of these tidelands by
DOH due to water quality issues would have a cultural and economic impact on the Port
Gamble S'Klallam Tribe.
C. Wrldlde Proteqtiqu and Habitat Maaaeerqeulllaa
Action 7: Consult with PGST/Point No Point Treaty Council wildlife biologist to
develop and implement a plan for the protection of wildlife and the restoration of
wildlife habitat. The purpose of the plan is to provide protective actions for wildlife,
including keeping the elk herd from crossing the highway to enter the project area.
The plan will also provide information regarding vegetation and habitat preservation
in nafural areas.
We are concerned about impacts to the elk herd that forages to the West of this project area in
the lower end of the Duckabush River Valley and the development of an "attractive nuisance"
in the form of highly alluring elk and deer forage opportunities. The construction of lawns and
fairways proposed as part of this MPR will create an "attractive nuisance" that will increase
the frequency at which elk cross highway 101. Coupled with the projected increase of more
than 4,000 vehicle trips per day, the "attractive nuisance" poses a significant risk to human
health and the viability of the elk herd.
The FSEIS Habitat Management Plan was not developed in consultation with the Tribe and
does not fulfill the wildlife safety and damage control objectives of the 2008 BOCC ordinance
(Ordinance No. 0l-0128-08, 63.1). Although the Habitat Management Plan describes the
placement of an exclusion fence to discourage elk from utilizing the site, a more
comprehensive Wildlife Management Plan is required. An adequate Wildlife Management
Plan must describe how the elk will be discouraged or prevented from crossing the highway.
GPS and other elk monitoring records reveal that highway 101 is not a barrier to dispersal to
the Duckabush elk herd. We know that the elk readily cross the highway just north of
McDonald Creek and in the vicinity of Triton Head/Triton Cove. The wildlife management
plan should also describe the location, size, and other specifications of the fence or any other
deterrents constructed to reduce risks to the elk. Additionally, we need a legitimate Wildlife
Management Plan that describes what actions can and will be taken in the event that the fence
doesn't work-i.e. what will be done if the elk still manage to get on the property and start
damaging greens and fairways. Such actions must NOT include lethal control or state-
subsidized monetary compensation.
5
PORT GAMBLE S'KLALLAM TRIBE
31912 Little Boston Rd. NE - Kingston, WA 98345
D. Water Qualitv and Monitorine Plan
Action 8: Contact U.S. Army Corps representatives to request a new determination of
wetlands jurisdiction for the purposes of USCOE permit review. The2007
determination (FSEIS YoL2 Appendix J.A) expiredin2}l? and the document is no
longer a valid determination that the wetlands in question are not Waters of the U.S.
Action 9: Consult with PGST Natural Resources Dept. staff to develop and implement
a plan for the protection of water quality in the project area and in waters adjacent to
the project area or amend the existing Draft Water Quality Monitoring Plan to include
these protections. This will incorporate the following:
a) Water quality monitoring in waters connected to tribal fisheries and
shellfish harvesting areas, including monitoring for pollutants, and
b) An evaluation of alternatives for constructing additional swales and
contours near roadways to redirect stormwater runoff away from Hood
Canal, particularly in the areas of Phase 1 construction.
Action 10: Revise project management plan to eliminate the use of persistent
pollutants and replace them with substances allowed for use under the agricultural
national organic program. Provide the draft revised management plan to PGST Natural
Resources staff for review and comment.
The urbanization of Black Point by the development of the proposed Master Planned Resort
(MPR) will increase the prevalence of toxic heavy metals, persistent organic pollutants and
other contaminants of emerging @ncern in this rural area. The increase in the prevalence of
these pollutants will likely have a negative effect on fish and shellfish resources inhabiting
Black Point and the surrounding areas, including the Dosewallips and Duckabush River
Estuaries.
Developing a stormwater and wastewater remediation system may reduce the effects of these
pollutants. To ensure the functionality of this type of system, extensive and regular, discharge,
ambient water and biota tissue monitoring will be required. Unfortunately, we are unaware of
any working examples of this type of system. Our concern with regard to the construction of
an urban development in this rural area is clearly illustrated by the pollution related loss of
-36,000 acres ofshellfish beds throughout Puget Sound.
The geochemical processes occurring at the seawater/groundwater interface form a critical
transition zone, which provides essential ecological functions driven by sediment-associated
biota. A reduction in the hydraulic conductivity between the wetlands located within the
proposed MPR and the nearshore environment surrounding Black Point will likely affect the
chemical constituents available to biota inhabiting this area. For instance, an increase in
salinity could negatively affect the productivity of Pacific oysters (C. gigas).
E. Unified Development Code and Development Agreement
Action 11: Include the above actions in the Jefferson County Code as an amendment
to the Unified Development Code.
Action 12: Include the above actions as a requirement in the development agreement.
6
PORT GAMBLE S'KLALLAM TRIBE
31912 Little Boston Rd. NE - Kingston, WA 98346
Action 13: Include the final compilation of the plans and measures described in the
above actions as an appendix to the FSEIS.
Although FSEIS covers potential environmental effects to some extent, we are concerned that
it does not go nearly far enough to resolve the potentially significant impacts to tribal treaty
rights and cultural resources. We look forward to working with you to address these concerns.
Please contact me with any questions at (360) 297-6293.
Thank you.
Sincerely,
Roma Call
Environmental Program Manager
Port Gamble S'Klallam Tribe
7
PORT GAITIBLE S'KII\LUI}[ TRIBE
31912 Little Boston Road NE . Kingston, WA 98346
Datc,: March 11,2016
leffersrln Cuunty Plannirrg Contnrissiorr
621 Sheridan Street,
Port Townsc,ntl, WA 98368
Errra iI : PlanCorn rn@co.jr,[t-ersolt.wa.us
(360) 297-2646
Kingston
HAR 15 ?01s
David Wayrre lohnsorr
Pleasant l-larbor FSElS c/o lefferson Courrty DCD
621 Sheridarr Street,
Port Townsc.nd, WA 98368
E ttr a i I : d rv jo h n so lt (D co.i e ffe rsrl n. vvA. u s
Re: Pleasant Harbor Marina and Golf Resort LLC Master Planned Resort
Dear Plattning Corttrrtission Mernllers and [r4r. f olrrtson,
Tlrank you for tlte opporturtity for the Port Canrllle S'Klal]arn Trihal Historic PreservaLion
Office trl revic'w arrd conrrnent on the pltposed Pleasant l{arb<lr Marilur arrd Golf Resort l.l,C
Master Plarr ned Resort.
The proposetl Pleasant llarltrrr Marina and Goll"Re,sort LLC Master l'larrncd Resort is located
within tlre Port Carnblc S'Klallanr Tribe's Adjudicated Usual and Accustoruetl Area and
Traditionaland l'listoric Use Area. This;rroposed undertaking i-s located ilr an area of hig,h
cultural and lristoric signi[icance for the Port Canrble S'Klallarn Tribe. lt is also locatc'd irr arr
area of ltigh prollability frlr e lrcounterirrg cultural rcs()urccs accorcling to the WaslrirrgLon
Depirrtnren t oI Arch eology arrd H istoric Preservati on ( DAl'l P) WISAAIID tlatabasc.
Basc'd on prc,lirrtirrarl'review oilocatiort ol tlte proposerl urrdertakirrg tlte Trihe is cortcernetl
tltat tlre project proposal [o u.s(, Kettle Pontls B and C for strlrirrg.stonuwater artd treatetl
wastewater could rcsult in sig,lrilicarrt danrages to Tratliliorral Culturirl ['rrrperties (1'CPs)
that nrect rnultiple l'ederal critt,ria that rt'nrler thc'nr eligible for inclusiorr olt the Natirlrral
Register oI Historic Places.
Criterion B Associatiolr rrvith the Lives o[Persons Signil'icarrt in our Past: This area
specifically the lreshwater within tlrc proposc,d project area,ltave direct associatiolr wilh
spiritual cntities knowu to the S'Klallanr Triht.
Criterion C. RepreselttaLive oIa Signilicarrt and Distinguislrable Errtity Whose Conrponetrts
May Lack lndividtrrrl [)istinction: Arcas within tlrc 1:ropo-setl grrojtct area ltatc'uniclr,tt
ecolog,ical corrclitions that result in strl:;rurtiug sltecific lliota that sugrprlrted lristoric
S'Klallanr gathering that lras contirrued into the twelrtietl'r eentury within living nrenrory o[
Port Ganrlllc, S'KlaIlarrr Trihal menrbers.
(8011) 831-9921
Tr:ll Free
$60t 297-7t)97
F;u
I
1
Criterion D. History of Yielding or Potential to Yield Information Important in Prehistory or
History: Based on the high density of Native American Place names that include traditional
camp sites and the proxirnity of the proposed project to two traditional S'Klallam historic
and contemporary fisheries and shellfish harvest areas at the Duckabush and Dosewallips
River the area has a high probability to yield valuable information to S'Klallam, and broader
patterns of Native American history and use of the Hood Canal watershed.
The Tribe believes that the uniqueness of the geologic features and oral historical accounts
relating spiritual entities linked to the land, the traditional plants harvested generationally
by S'Klallam people from the past and within living memory, as well as multiple campsites
and Native American place names know in the area, all directly contribute to unique
cultural significance of the area that would be impacted by significant modification of the
physical environment"
The Port Gamble S'Klallam Tribe requests to have a traditional cultural property evaluation
of the kettle ponds and wetland area to determine their eligibility to the National register
and evaluate the impacts the proposed undertakings will have on the cultural integrity of
the area and their eligibility to be listed on the National Register of Historic Places.
Sincerely,
lr*rod,.WC
Laura L. Price
Tribal Historic Preservation Offi cer
Cultural Resources Department
Port Gamble S'Klallam Tribe
350297-6358
lives@pgsrnsn.us
cc:
Roma Call
Environmental Program Manager, Port Gamble S'Klallam Tribe
fosh Wisniewski, Ph.D.
Anthropologist, Port Gamble S'Klallam Tribe
Attachment #2
CONFIDENTIAL. NOT FOR PUBUC DISTRIBWION
June 23,2006
Marie Hebert
Port Gamble S'Klallam Tribe
31912 Little Boston Road NE
Kingston, WA 98346
Re: Cultural Resoure Reconnaissance for the Pleasant Harbor Marina and GoIf Reor9 Jefrerson
County.
Dear Ms. Hebert,
Western Shore Heritage Services, Inc. (WSHS) has been retained by Statesman Corporation to conduct a
cultural resource reconnaissance for the proposed 253 acre Pleasant Harbor Marina and Golf Resort,
Iocated on the Hood Canal near the town of Brinnon, Washington (Figure l). The project entails two
components: the Maritime Village and the Golf Resort. The Maritime Village will encompass the 290
existing slips within Pleasant Harbor with the additional constmction of approximately 150 residential
units and reconstnrction of the current retail into a 10,000 square foot Maritime Center. The Golf Resort
will include the construction of an eighteen-hole golf course with a conference center, spa and
approximately l0O condominium units within the complex. Additionally,800 residential town home
units are planned for consEr.rction throughout the golf course area. WSHS will be responsible for
identifying and determining potential impacts of the proposed development to recorded, unrecorded, and
as-yet unidentified cultural resources.
WSHS is currently in the process of researching available background information. Research consists of
a file search at the Department of Archaeology and Historic Preservation (DAHP) in Olympia, review of
previously recorded cultural resource reports, and review ofpertinent published literature and
ethnographies. Fieldwork will include a visual reconnaissance of the project area to verify background
information. Subsurface testing will not be conducted during this phase of the project. In the event the
reconnaissance determines a high probability for intact buried cultural resources, subsurface testing will
be recommended. Results of the reconnaissance will be presented in a prepared technical report.
information to support our
would very much like to include it in our
or email (camillemather@gmail.com) should you wish to provide any comments. I
appreciate your assistance and look forward to hearing from you.
Sincerely,
Camille A. Mather
Archaeologist
A€
!
iE@
CONFIDENTIAL - NOT FOR PUBLIC DISTRIBUTION
quadrangleFigurePortion
Pleasant Harbor Marina and Golf Resort.
Reference Cited
Elmendorf, W. W. and A. L. Kroeber
A-9
areas
Attachment #3
308913 US Hwy l0l, Brinnon,WA 98320
(3601 79646r r (800) s47-3479
Fox: (866) 8484612
PIEaSRNT HARBoR
___ ryrAalNA Ai..li; ( rOL:r fii \i ,{f I -..-,.._
May 11,2012
Josh Wisniewski Ph.D
Port Gamble S'Klallam Tribe
3L912 Little Boston Rd NE
Kingston, WA 98346
Dear Mr.Wisniewski,
I'm writing to update you on progress of the Pleasant Harbor Marina and Golf Resort
project near Brinnon, Washington (Jefferson County). We are currently submitting the
final reports for the SEIS to Jefferson County DCD.
In order to protect known and unknown archaeological and cultural resources , and to
comply with Jefferson County Ordinance 0l-0128-08 condition 63 (k) as well as state
laws goveming the protection of those resources (RCW 27.53, RCW 21.44). We are
submitting for your review our cultural resources management plan that includes
monitoring and inadvertent discovery processes and procedures
Please review and submit any comments in writing by June 15 2012. Please contact me
by phone (206) 714-1482 or e-mail don@pleasantharbonnarina.com if you have any
questions. I look forward to hearing from you.
Best Regards
Don Coleman
Pleasant Harbor Marina
1of 1
Appendix O
Proposed PIan for Archeological Monitoring and Inadvertent
Discovery Protocol
DAHP Response to Gultural Resources Plan
Skokomish Tribe Response to Gultural Resources Plan
Proposed Plan for Archaeological Monitoring
and lnadvertent Discovery Protocol
AUTIIoR:
DlrE:
Loclrrox:
T,R, S:
Cultural Resource Consultants, lnc.
PRorosrn Plar ron ARcHAEoLocrcat MoxtroRrNc
eNo IxeovrRTENT Dtscovuny PRorocot.,
ARcrrAEoloctcar, MoxrroRrNc AT Plrl.sexr HaRaoR M.+Rrnl
Jnrrnnsox CouNrv, Wlslllxctox
Glcnn D. Hartrnarin
January 12,2012, revised February'7,2012, March 27,2012
Jefferson County, Washington
Township 25 North, Range 2 West, Section 15 and 22, Willamette
Meridian.
PRepenBo roR:Don Coleman
Pleasant Harbor Marina
308913 Hwy l0l
Brinnon, WA 98320
Pleasant Harbor Marina is requesting periodic archaeological monitoring of construction
excavations and other below-fill ground-dish-rbing activities in Brinnon, Jefferson County,
Washington. The Pleasant Harbor Master Planned Resort is proposed on approximately 257
acres of the 7l0-acre Black Point Peninsula along the western side of the Hood Canal. The
peninsula is surrounded on the north, south, and east by the watcrs 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 ofthe project area did not result in thc identification of
any prehistoric or hjstoric archaeological resources (Mather et al. 2006; Berger 2008).
Subsurface investigations focused on archaeologically sensitive landforms; that is, those
cnvironments most likely to contain naturally buried archaeology identified in collaboration with
cultural resources staffof the Skokomish Tribe (e.g., kettles, vantage points, thc bluffedge).
High probability areas in Black Point where buricd archaeological deposits might occur (i.e.,
kenle margins and bases) were sarnpled using hand-excavated shovel probes. Locations ofall
probcs, 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/scrapcs were excavated during
the 2006 field investigations with 27 probes along the southem blufl l2 probcs on high points,
22 probes in kettle basins and 32 probes along the kcttle margins and rims. ln addition wall
profilcs wcre faced in order to assess thc local stratigraphy.
Subsequcnt to the initial cultural resource asscssment for the project, Berger (2008) conducted
archaeological monitoring during geoteclrnical assessment. Archaeological monitoring of
geotechnical explorations did not rcsult iu the identification ofany cvidence ofarchaeological
sites, historic structurcs, or other features. Conditions and sedimsnls observed during this
7 I O ER'CKSEN AVENUE NE" SUTTE I OO
PO Box 10668, B^jNBRrDGE tst-AND, wA 981I0
PHONE206855-9020 - info@crc*r.com
episode of archaeological monitoring suggestcd a low probability for as-yet unidentified
archaeological sites.
Archacological 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
potenrials of archacology within the project area. They will bc apprised of their responsibilities
during archaeological monitoring, their obligations in thc case of an inadvertent discovery and
they;ill be made aware of the inadvcrent discovery plan and protocol.
Periodic archaeological monitoring is planned during construction excavations and other below-
fill ground-disturbing project actions to minimize potential effeets 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-kettlcs, vantage points,
the bluff edge-if sediments in these landforms will be affected by ground-dishrbing
construction. Prcsently 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 ct al. 2006; Berger 2008), which had tested aud monitored
geotecbnical explorations in these locations (Figure l). 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 adjtrsting the monitoring schedule.
Archaeological monitoring would entail having an archaeologist present dwing construction
excavation below-fill to observe subsurface conditions and identify any buried archaeological
matcrials that may be encourtered. Monitoring will be performed either by a 'lrofessional
archaeologist" (RCW 27.53.030 (8)) or under the supervision of a professional archaeologist.
Thc monitoring archacologist would stand in close proximity to construction equipment in order
to view subsurface dcposits as they are exposed, and would be in close communication with
equipment operators to ensure adequate opportunify for observation and documcntation.
Archaeological monitoring will scek to identify potential buricd surfaccs, anthropogenic
sediments, and archaeological features such as shell middens, hearths, or artifact-bearing strata.
The monitoring archaeologist will inspect project excavations and the recovered sedimcnts for
indications of such archaeological resources. The archaeologist will be provided the opportunity
to screen excavated scdiments and matrix samples when this is judged useful to the identification
process. It is not expccted that modern fill (c.g., imported culturally-sterile construction lill) or
glacial till sediments would be includcd in screening procedures. Excavated spoils may be
cxamined in the course of monitoring. If cultural materials are observed in spoils piles, it is
expected that these would be rcmovcd for cxamination and that thc opportunity to screen spoil
sediments would be available.
CRC Proposed Plan for Archaeological Monitoring and lnadvertent Discovery Protocol
11 1 1L, Pleasant Harbor Marina, Jefferson County, WA
Page 2
Archaeological monitoring of construction excavation witl proceed until it can be determined
with a gteater level of confidence that human remains or other cultural resources are not likely to
bc impactcd by construction excavation of the ptoject. The archacologist will conduct
monitoring until native and fill deposits can be confidently isolated and identified based on
observed sedimentary exposures. Upon complction of the monitoring, thc archaeologist will
preparc a report on the methods and rcsults of the work, and recommendations for any necessary
additional archaeological investigations, iltustrated with maps, drawings, and photographs as
appropriate.
Contingency PIm
In accordance with RCW 27.44lndian Graves and Records Act, RCW 27.53 Archaeological
Sites and Resources, RCW 68.50 Humau 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 Uoon Discoverv of Potential or ActuFI Cultural Resources
l. Upon discovery ofa potential or actual archaeological site, or cultural rcsources as defined by
RCW 27.44lndian Craves and Records Act, and RCW 27.53 Archaeological Sites and
Resources, Pleasant Harbor Marina, its employees, its contactors and sub-contractors shall:
(a) Immediately cease or halt ground disturbing, construction, or other activities around
the area of thc discovery and secure the area with a perimeter of not less than thirry (30)
fcet until all procedurcs are complcted and &e parties agree that activities can resume. If
such a perimeter would materially impact agency functions mandated by taw, related to
health, safety or environmental concerns, then thc secured area shall be ofa size and
extent practicable to provide maximum protection to the resource under the
circumstanccs. Project activities that are not ground disrurbing may continue outside the
sccured perimeter around the findings. No one shall excavate any findings and all
findings will be left in placc, undisrurbed and without analysis, until consultation with
DAHP and thc Tribe regarding a final disposition of the {indings 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 Govemrnent Archaeologist at DAIIP and the Tribes of the discovery
as soon as possible, but in any event, no later than (24) hours of the discovery. If human
rcmains are found, Pleasant Harbor Marina shall follow notification procedures specified
bclow (see "Human Remains and Associated Funerary Objects").
(c) Arrange for the parties to conduct a joint vierving of the discovery within (48) forty-
cight 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 thc
joint viewing. After the joint viewing, taking into account any recommendations of the
Tribe(s), DAHP, and thc archaeologist, thc parties shall discuss thc potenlial sigrificance,
if any, of the discovery.
CRC Proposed Plan for Archaeologicaf Monitorlng and lnadvertent Discovery Protocol
1 1 1 1L, Pleasant Harbor Marina, Jefferson County, WA
Page 3
(d) Consult with the Tribes and DAIIP on the transfer and final disposition of artifacts.
Until the Tribe has a repository t&at meets the standards of curation established 36 CFR
Part79, artifacts shall be curated using an institution or organization that meets curation
standards, selected through consultation with thc Tribc.
Inadvertent Discoverv of Httman Skeletal Remains on Non:Federal atd Non-Tribal Land
in the State of Washinston (RCWs 68.50.645.27.44.055. and 68.60.055)
2. If ground-disturbing activities encounter human skeletal rcrnains during thc course of
construction, then all activity must cease that may cause further disturbance to those remains and
the area of the find must be securcd and protected from further disturbance. In addition, the
finding of human skeletal rsmains must be reported to the Jefferson County Coroner's Office and
Jefferson Counfy Sheriff s Oflice in the most expeditious manner possible- The rcmains should
not be touched, moved, or further disturbed.
3. The Jefferson County Coroner's Office will assume jurisdiction over the human skcletal
remains and make a determination of whether those remains are forcnsic or non-forcnsic. If the
counry coroncr dctcrmines the remains are non-forensic, then they will report that finding to the
Department of Archacology 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 lndian or Non-
Indian and report that linding to any appropriate cemeteries and the affected hibes. The DAI{P
will *rcn handle all consultation with the affected parties as to the future preservation,
cxcavation, 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.
Confi dentialitv of Information
5. Pleasant Harbor Marina or their authorized representative recognizes that archaeological
properties are ofa sensitive nature and sites where cultural resources are discovered can become
targets of vandalism and illcgal removal activities. Plcasant Harbor Marina or their authorized
representative shall keep and maintain as confidential all information regarding any discovered
cultural resources, particularly the location ofknown 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 ensurc
that all records indicating the location ofknown or suspected archaeological propcrties are
permanently secured and confi dential.
7. Pleasant flarbor Marina or their authorized representativc shall ensurc that its personneln
contractors, and permittees keep the discovery of any found or suspected human remains, other
cultural itcms, and potential historic properties confidential, including but not limited to,
refraining such persons from contacting the media or any third party or otherwisc sharing
information regarding the discovery with any member of the public. Pleasant Harbor Marina or
CRC Proposed Plan for Archaeological Monitoring and lnadverlent Discovery Protocol
11 11 L, Pleasant Harbor Marina, Jefferson County, WA
Page 4
their authorized represcntative shall rcquire its pcrsonnel, contractors and permittees to
immediately notiff the Lead Representative ofPleasant Harbor Marina or their authorized
represcntative of any inquiry from the media or public. Pleasant Harbor Marina or their
authorized representative shall immcdiately 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 proceduies for such a release, to the extent
permitted by law.
Lcad Representative and Primarv Contact
8. The lead representatives and primary contacts of each parry under this plan are as identified
below. The parties may identi$ other specific personnel before the commencement of any
particular project element as the contacts.
Pleasent Ifarbor Marina
308913 Hwy l0l
Brinnon, WA 98320
Primary Contact: Don Coleman, Maintenance and Security Supervisor, 206-714-1482
Plersant lfarbor Marina
7370 Sierra Morena Blvd. S.W.
Calgary, Alberta
Primary Contact: M. Garth Mann, President & C.E.O, 403-25&15l
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 Wisnicwski Ph.D.
Skokomish Tribe
North 80 Tribal Center Rd
Skokomish, WA 98584
Primary Contact: Kris Miller, Cultural Resources
Squaxin Island Tribe
CRC Proposed Plan forArctaeological Monitoring and lnadvertent Discovery Protocol
111 1L, Pteasant Harbor Marina, Jefferson County, WA
page 5
SE I0 Squaxin Lane
Shclton, WA 98584
Primary Contact: R-honda Foster
Suquamlsh Tribe
15838 Saady 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 Govemment 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 SherifPs office
79 Elkins Road
Port Hadlock, WA 98339
Lrad Representative: Tony Hemandez, Sheriff, 360-3 85-383 I
Department of Community Development
621 Sheridan Srect
Port Townscnd, WA 98368
lrad Rcpresentative: David W. Johnson, 36A479-4465
Cultural Resource Consultants, Inc.
710 Ericksen Avenue NE, Suite 100
PO Box 10668
Bainbridge Island, WA 98110
Lead Representative: Glenn llarhnann, 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, Camillc, Jcnnifcr Chambers, James Schumacher, and Matthew Gill
CRC Proposed Plan for Archaeological Monitoring and lnadvertent Dlsco. very Prolocol
11 11L, Aeasant Harbor Marina, Jeflerson County, WA
page 6
2006 Cultural Resources Assessment for the Proposcd Pleasant Harbor Marina and Golf
Resort, Jeffbrson County, Washington. WSHS Technical Report #274. Prepared for
Statesman Corporation. On file at Cultural Resource Consultants, lnc., Bainbridge Island.
CRC Proposed Plan for Archaeological Monitoring and lnadvertent Discovery Protocol
1111L, Pleasant Harbor Marina, Jefferson County, WA
page l
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Figure l. Previous testing (Mather et al 2006) identified high probability areas.
CRC Proposed Plan for Archaeological Monltoring and lnadve(ent Discovory Protocol
11 1 1L. Pleasant Harbor Marina, Jefferson County, WA
page g
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PLEASANT TIARBOR MARINA & CCILF COTIPSE
sEcTroNs r, & 22. TOWNItmp 25N., RANGE 2W.. W.M.
,
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Figurc 2. High probability areas identified for monitoring (outlined in red) based on prcvious anallres of the project area (Mather et al. 2006).
CRC Proposod Plan for Archaeological Monitoring and lnadvertent Discovery Protocol
1 1 I 1L, Pleasant Harbor Marina, Jefferson County, WA
Page 9
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Figure 3, Areas to be monitored (outlined iu red) include wetlands, kettles, and vantage points (after Mather et al. 2006).
CRC Proposecl Plan for Archaeological Monitoring and lnadvertent Discovery Protocol
11'l 1L, Pleasant Harbor Marina, Jefferson County, WA
Page 10
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Attachment #4
DAHP Response to Gultural Resources Plan
OF
&
PRESERVATION
Allyson Brooks Ph.D., Director
Stote Historic Preservotion Oflicer
January 14,2013
Mr. David Johnson
Associate Planner
Jefferson County
621 Sheridan Street
Port Townsend, WA 98368
ln future correspondence please refer to:Log: 081 106-13-JE
Property: Statesman Group Master Planned Resort in Brinnon's Black Point and Pleasant
Harbor Marina, Jefferson Co.
Re: Concur with Cultural Resource Management Plan for Archaeologica! Monitoring and
lnadvertent Discovery
Dear Mr. Johnson:
Thank you for contacting the Washington State Department of Archaeology and Historic
Preservation (DAHP). We concur with the attached plan for the Statesman Group Master
Planned Resort. Three Tribes have concurred with the plan and three others did not comment.
We have no other comments or concerns as long as the attached monitoring and inadvertent
discovery plan is implemented during ground disturbing activities for the above project.
Thank you for the opportunity to review and comment. Please feel free to contact me if you
have any questions.
Sincerely,
)fJ^[I"*il
Gretchen Kaehler
Assistant State Archaeologist
(360) 586-3088
qretchen. kaehler@dahp.wa.qov
cc. Gideon Kauffman, Archaeologist, Jamestown S'Klallam
BillWhite, Archaeologist, Lower Elwha Klallam Tribe
Josh Wisnieweksi, THPO, Port Gamble S'Klallam Tribe
Kris Miller, THPO, Skokomish Tribe
Rhonda Foster, THPO, Squaxin lsland Tribe
Dennis Lewarch, THPO, Suquamish Tribe
Don Coleman, Pleasant Harbor Marina
Stote of Woshington . Depqrlmenl of Archoeology & Hisloric Preservolion
P.O. Box 48343 . Olympio, Woshinglon 98504-8343 . (350) 586-3065
www.dohp.wo.gov
Skokomish Tribe Response to Gultural
Resources Plan
I
I
I
N. 80 Tribal Center Road
Skokomish Indian Tribe
Tribal Center (360) 426-4232
FAX (360) 877-5943 Skokomish Nation, WA 98584
January 14,2013
Mr. David Johnson
Associate Planner
Jefferson County
621 Sheridan Street
Port Townsend, WA 98368
RE: Proposed Plan For Archaeological Monitoring And Inadvertent Discovery Protocol For
Pleasant Harbor Marina, Jefferson County, Washington.
Dear Mr. Johnson:
Thank you for contacting the Skokomish Tribal Historic Preservation Office. We concur with the
attached plan for the Statesman Group Master Planned Resort.
Skokomish Tribe is requesting a schedule of ground disturbing activities so that they (tribes THPO)
may have the option to be on site during ground disturbance. We have discussed in the past the
importance of this site to the Skokomish people.
We have no other comments or concerns as long as the attached monitoring and inadvertent
discovery plan is implemented during ground disturbing activities for the above project.
Thank you for the opportunity to review and comment. Please feel free to contact me if you
have any questions.
Sincerely,
Kris Miller
Tribal Historic Preservation Offi cer
Skokomish Tribe
(360)426-4232 x 2015
Shlanay I @skokomish.org
.l.l
fi
Attachment #5
PORT GAMBLE S'KLALLAM TRIBE
NATURAL RESOURCES DEPARTMENT
31912 Little Boston Rd. NE - Kingston, WA 98345
Letter 3
1
J
January 5, 2015
Pleasant Harbor DSEIS c/o lefferson County DCD
621 Sheridan Street
Port Townsend WA 98368
Email:.dwtohnson@co'jeft -US
R"ECPI\'rET)
JAN 0 5 A1l
Jffff$Til ffiI}IYBIX
Dear Mr. fohnson,
Thank you for the opportunity to comrnent on the Draft Supplemental Environmental lrnpact
Statement for the proposed Pleasant Harbor Master Planned Resort. The Port Gamble S'Klallam
Tribe's (PGSD 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
proiect 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 frorn the proposed project would impact salmon, shellfish and other irnportant
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 proied 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 signiflcant impacts on resources and the DSEIS fails to adequately
address these concerns'
Woter Resources
The project site includes a susceptible aquifer recharge area and the potential impacts to Iocal
groundwater, stream flows and wetland geology are very significanl Ongoing monitoring of
water runoffand its affects on sensitive resources is needed during the construction and
operation phases, in addition to an adaptive management plan for maklng 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, sreps 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'
Env iro n m e nta lly S e n sitiv e A re a s
In a December 2\,2001joint SEPA comment letter from Point No Point Treaty Council,
tamestown 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 steepr unstable slopes fringing the Black Point
.,
4
5
PORT GAMBLE S'KLALLAM TRIBE
NATURAL RESOURCES DEPARTMENT
31912 Little Boston Rd. NE - Kingston, WA 983416
kettle ponds. The proposed project would result in the loss of approximate'ly 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 tlre successful
replacement and maintenance o[this important habitat. Annual monitoring of wetland creation
areas is not sumcient 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 altlrough 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 identiff any impacts on fish species. However, additional monitoring
stations both on and off site and more preventative measures are needed to adequate)y 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 thatwater quality issues would be adequately resolved.
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 contarninants, 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 projecl We request the opportunity
to consult more directly with the proiect applicant and )efferson Cgunty staff to discuss our
concerns !n mcre detail. Please contact me at rornac(OpgsLnsn.us to schedule a rneeting.
Thank you.
Sincerely,
5 cont.
6
7
9
8
"i'K lrr
Roma Call
Environmental Coordinator
Phone: t360)297-4792 Fax: (360) 297-4797 z
Shellftsh Species
Attachment #6
RESPONSE TO COMMENTS FROM PORT GAMBLE S'KLALLAM TRIBE
NATURAL RESOURCES DEPARTMENT
(Lefter # 3)
Comm ent 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.
Gomment 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. ln 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; allwater will be collected, treated and reused.
Gomment 3
Comment acknowledged. Traffic issues, including Traffic Volumes and Level of Service were
evaluated in Secfion 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 Secfion 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.
ln 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 gotf 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 B0 acres (35 percent of the site) under Alternative 2.
Comment Letters and Responseflr j€:r.i iiiRl;FrcExhibit 1
Pleasant Harbor Fina, SE S
December 2015 9
Comment 4
Please see Key Topic 4-2, Saltwater lntrusion, in Chapter 4 of this Final SEIS for a discussion
on aquifer recharge and potentialfor 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 Secfion 3.2 (pages 3.2-16
and3-2-17), 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. lf 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 untilthe 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 Secfion 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.
ln 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 obserued along the margins of the
kettle margins or on the steeper s/opes in the upland portions of the project srte" (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 lnvestigation report is
included in Draft SEIS Appendix E.
Pleasant Harbor Fina, SE S
December 2015
Comment Leffers and Responsss';':: i:.
Exhibit 110
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. ln 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).
Gom 7
The Draft SEIS Secfion 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. ln 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 Fina, SE S
December 201 5 11
Commen-t Lefters and
Exhibit
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. ln addition, the contractor will
prepare a construction Spill Prevention, Control and Countermeasures (SPCC) Plan for the
project according to Washlngton 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 rnaking 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.
Gomment 9
WAC 197-11455(6) (SEPA Rules) indicates that the comment period for a Draft EIS shall be 30
days unless extended by the lead agency. WAC 197-11455(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. ln 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.
Pleasant Harbor Fina, SE S
December 2015
'' rii;a; iz;-
12
Comment Leffers and Responsos
Exhibit 1
PORT GAMBLE S'KLALLAM TRIBE
31912 Little Boston Rd. NE - Kingston, WA 98346
Attachment #7
n[c 15 2015
December 16,2015
Jefferson County Planning Commission
621 Sheridan Street,
Port Townsend, WA 98368
Email : PlanComm@co jefferson.wa.us
David Wayne Johnson
Pleasant Harbor FSEIS c/o Jefferson County DCD
621 Sheridan Street
Port Townsend WA 98368
Email : dwiohnson@co.iefferson.wa.us
Subject: Pleasant Harbor Final Supplemental Environmental Impact Statement,
December 2015, Case No's: MLA08-00188, ZON08-00056
Dear Planning Commission Members and Mr. Johnson,
With regard to the December 9 Notice of Availability of the Final Supplemental
Environmental Impact Statement (FSEIS) and Notice of Planning Commission Public
Hearing and Notice of Intent to Amend the Unified Development Code for the Pleasant
Harbor Marina and Golf Resort LLC Master Planned Resort, I am submitting this letter on
behalf of the Port Gamble S'Klallam Tribe (PGST). While we appreciate the February 18,
2015 meeting, the tribal consultation process is not yet finished. We understood that Jefferson
County DCD would work with PGST staffto address the concerns raised at the meeting and
in our comments. However, PGST staff were not consulted after the February meeting and
were not given any notification of the FSEIS prior to its release. [n view of the incomplete
consultation process, and as stated in our January 5,2015letter, we continue to oppose this
project. We request a 60-day extension of the process in order to allow time to complete the
Tribe's consultation.
The Port Gamble S'Klallam Tribe is the successor in interest to Indian bands and tribes
signatory to the 1855 Treaty of PointNo Point, l2 Stat. 933.r Today the Tribe retains deep
cultural and economic ties to the surrounding waters and to their fisheries in its usual and
accustomed grounds and stations (U&A). More than a century of federal court decisions have
fleshed out the components of the treaty right, including the right of access to places, the right
to a share of harvest to meet tribal moderate living needs, and the right to protection of fish
habitat in all areas of the Tribe's U&A. The proposed Pleasant Harbor project is located
within the Tribe's U&A, in an area where tribal members depend on fish, shellfish and
wildlife. We are concemed that the proposed project would jeopardize the Tribe's treaty right
to fish and hunt in the project area.
As stated in our previous comments in 2001, 2006,2007 and 2015 regarding this project and
at the February meeting, we are concemed about the potential for adverse impacts from
increased traffic, intensity of land use, and environmental effects. The proposed project would
I lJnited States v. l{ashington, 459 F. Supp. I 020, t 039 (W.D. Wash. I 978) (herein after Botdt tt)-
PORT GAMBLE S'KLALLAM TRIBE
31912 Little Boston Rd. NE - Kingston, WA 98346
be located in an aquifer recharge area and the potential water quality and water quantity
impacts to local groundwater, streams and wetlands are significant. We are concerned about
the potential for significant adverse effects to fish habitat and the Tribe's fisheries as a result
of these impacts. Additionally, numerous environmentally sensitive features are located
within the project area, including unique kettle ponds. We are concemed about the potential
adverse effects to these habitats from the proposed stormwater management system.
An elk herd forages within the forested uplands to the northwest of the project between the
Dosewallips and Duckabush river valleys. We are concemed about the development of highly
attractive elk and deer forage from the proposed project lawns and fairways and the risk that
the elk will cross the highway to get to the food. Couple that with the projected increase of
>4,000 vehicle trips per day on the highway and it poses a significant risk to the viability of
the elk herd. We are also concerned about the possible increase in recreational shellfish
hanesting from project residents, which would have the potential to impact shellfish habitat
and the Tribe's harvest. 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.
These issues were not satisfactorily addressed in the FSEIS. Although the document covers
potential environmental effects to some extent, we are concerned that it does not go nearly far
enough to resolve the potentially significant impacts to tribal treaty rights. In order to
adequately address the Tribe's concerns, we zre requesting a 60-day period to work with
Jefferson County staff as needed to complete the tribal consultation process. We would
appreciate your consideration and timely response.
Thanlc you.
ru
Chair, Port Gamble S'Klallam Tribe
2
Attachment #8
David W. Johnson
From:
Sent:
To:
Cc:
Subject:
Roma Call <romac@pgst.nsn.us>
Friday, January 22,2016 5:45 PM
David W. Johnson
Cynthia Koan; David Goldsmith
Re: PGST Tribe's 60 day request
David,
We very much appreciate the Planning Commission granting more time for the tribal consultation process.
PGST staff will be discussing the project with Tribal Council on Feb. 8. lmmediately after that meeting I will let you know
how the Council would like to proceed.
Thank you
Roma Call
Roma CalI
Port, Gamble S'K1a11am Tribe
Environmental Coordinator
romac@pgsE . nsn. us
cell 350-5L5-3979
office 360-297-6293
On L/22/L610:54 AM, David W. Johnson wrote:
Roma,
The Planning Commission and Staff have agreed to your 60 day request from the January 6,zOtG
Planning Commission Public Hearing to complete consultation started during our February 2015 meeting
at Pleasant Harbor. Please let me know how you would like to proceed.
Thanks!
David Wayne Johnson - LEED AP - Neighborhood Development
Associate Planner - Port Ludlow Lead Planner
Department of Community Development
Jefferson County
360.379.4465
Mission: To preserve and enhonce the quality of life in Jefferson County by promoting a vibront
economy, sound communities ond a heolthy environment.
1.t SaVe PAPER - Please do not print this e-mail unless absolutely necessary
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