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Johnson, Reid C., Ph.D. <RCJohnson@mednet.ucla.edu>
Sunday, February 26,2017 5:01 PM
'pcharnas@cojefferson.wa.us'
'Lianna Johnson'
Comments regarding the Black Point Master Planned Resort and Jefferson County
Comprehensive Plan
Black Point_Jeff Co Comp Plan Johnson.pdf
To Patty Charnas:
We are submitting the attached comments to the Jefferson County Planning Commission regarding the Black
Point Master Planned Resort and Jefferson County Comprehensive Plan.
Please acknowledge receipt of this mail and the attached comments that we would like to be part of the record
Thank you,
Reid Johnson
Reid C. Johnson
email: rciohnson@mednet.ucla.edu
mobile: 310 903-6845
Los Angeles address:
10492 Colina Way
Los Angeles, CA90077
Washington address:
221 Canal Lane
Brinnon, WA 98320
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1
Michelle Farfan
February 26,2017
Comments regarding the proposed BIack Point Master Planned Resort in relationship to
the Jefferson County Comprehensive PIan
To the Jefferson County Planning Commission:
We are writing as local homeowners and interested citizens in regards to the proposed Black
Point Master Plan Resort near Brinnon in relation to the "Jefferson County Comprehensive
Plan". We have property, including a house, across the Duckabush estuary from Black Point.
We are opposed to the Master Planned Resort (MPR) desiqnation for the propertv on Black
Point.
The lt/PR designation for the Black Point peninsula on the Hood Canal is inconsistent with
objectives stated in the Jefferson County Comprehensive Plan, and more generally, what is
appropriate for the area. The currently proposed massive development will result in a sparsely
developed area to be deforested for commercial use, high density housing, and a golf course.
Natural wetlands (kettles) will be filled or converted to water storage units and massive
earthworUgrading will be required. The current phase I development plan proposes a huge
septic system next to the Hood Canal. Contamlnation of the Canal from sewage, silt, and golf
course effluent (despite unsupported claims by the developer in the various ElSs) is a huge
concern. Effects of eutrophication (pollution) are already evident around the Pleasant Harbor
Marina with its current high density of human activity and low water exchange.
The letter bythe Jefferson County Planning Commission dated Ju|y6,2016 and signed bythe
chair Cynthia Koan describes some of the reasons why Black Point is such an environmentally
sensitive site (page 2). lt borders on the Duckabush River estuary and is just south of the
Dosewallops River estuary, both of which are teeming with life including shellfish, salmon, seals,
and birds. The geologic properties of the aquifer at the Black Point location is of particular
concern. The Hood Canal is subject to frequent periods of low oxygen and algal and plankton
blooms (e.9., the particularly bad bloom last summer).
Designation of the Black Point peninsula as an MPR and the proposed Black Point development
plans are incompatible with multiple sections of the Jefferson County Comprehensive Plan.
Below we list a few examples taken from Total Fitness Report l/latrix:
1. Urban Growth Element: [Purpose] "The GroMh Management Act says that future growth
should be located in areas that already have public facilities like sewers." This is not the
case, and water quality issues with respect to the Hood Canal are major concerns.
2. Land use + Rural Element LNP14.16: "Develop land use ordinances based on
comprehensive watershed and salmon recovery plans for the conservation, protection, and
management of surface and ground waters, in order to maintain water quality and quantity,
provide potable water, and to restore and protect fish habitat." The proposed development
is incompatible with the Duckabush watershed.
3. LNP 20.4 "Prohibit outside of Urban Growth Areas new rural commercial development that
is incompatible with rural character or inconsistent with rural commercial level of service
standards." See comment to point 5 below.
4. LNG 21.0 "Encourage residential land use and development intensities that protect the
character of rural areas, avoid interference with resource land uses, and minimize impacts
upon environmentally sensitive areas." No further comment needed.
5. LNG 24.0 "... siting of ItIPRs ... in locations that are appropriate from both an economic and
environmental perspective." We seriously question the economic feasibility of the large high
end development (56,608 sq ft of commercial space and near 900 residential units planned)
and believe there is little chance this will improve the admittedly depressed economic state
of the area. lndeed, it was stated in the FSEIS that 99 percent of operational jobs that
would be created by the Pleasant Harbor project could be at 80% or less of the Brinnon area
median income.
6. LNG 25.0 "To manage storm water to improve drainage, control storm water quality and
quantity, protect shellfish beds, fish habitat and other natural resources and to reduce
nonpoint sources of pollution." These are of great concern during both construction and
maintenance phases of the project despite the unjustified statements in the FSEIS.
7. Natural Resource Conservation NRG 1 1.0 "Conserve and protect aquaculture lands and
associated facilities in order to ensure a longterm commercial and recreational resource
base." The project would greatly add to the already heavy recreational and commercial
shellfishing in the Duckabush River estuary area. We are also concerned about effects of
increased boating in the sensitive estuary.
8. MPR designation of the Black Point peninsula is incompatible with most sections of the
Open Space, Parks and Recreation chapter.
We also note that Tribal concerns regarding the Black Point development plan have not been
satisfactorily addressed.
ln summary, we believe a Master Planned Resort designation for the Black Point property is
inappropriate for the area and incongruent with the Jefferson County Comprehensive Plan.
Sincerely,
Reid and Lianna Johnson
221 Canal Lane
Brinnon, WA 98320
rciohnson@mednet. ucla.edu
lianna. iohnson@qmail.com
alternative address:
10492 Colina Way
Los Angeles, CA 90077