HomeMy WebLinkAbout041Michelle Farfan
From:
Sent:
To:
Subject:
Attachments:
nana@hctc.com
Tuesday, February 28,2017 12:46PM
pcha rnas@co jefferson.wa.us
HCEC Comments - TFA
2-27-L7 TFA Report comments.docx
Enclosed are comments from the Hood Canal Environmental Council regarding Jefferson County's TFA "goals and
policies". Pleasereplysolcanbeassuredthatyoureceivedthise-mail. Letmeknowifyouhavetroubleopeningthe
attachment. I will mail a hard copy today.
Thanks again for accepting HCEC's comments.
Donna Simmons, President
HCEC
1
February 27,201-7
Patty Charnas, Director
Jefferson County Dept. of Community Development
62l Sheridan Street
Port Townsend, Washington 98368
pcha rnas@co. iefferson.wa. us
Attn: Ms. Charnas:
On behalf of the Hood Canal Environmental Council (HCEC), lhave reviewedJefferson County's
Total Fitness Assessment (TFA) Report and offer the following comments on the report's "Goals
and Policies". The HCEC respectfully requests that these comments be entered into the
county's public record as part of its current Comprehensive Plan Update process.
A review of the goals and policies makes it clear that the county places a high priority on
preserving its largely rural character and lifestyle. This inclination toward protection of natural
resources, open spaces and critical areas is evident throughout the Land Use and Rural Element
section of the report, especiallyinthe Rural Charactersection (LNG 18.0through LNP 22.3) .
There are exceptions, however; the most notable exception being the goals and policies
regarding the siting of new Master Planned Resorts (MPRs) outlined in LNG 24.0 through LNP
24.L3 of the Master Planned Resorts section.
Goal LNG 24 states that MPRs must be sited ". . . . . in locations that are appropriate from both
an economic and environmental perspective". We believe that the location of the Pleasant
Harbor MPR proposed to be located in the Black Point/Pleasant Harbor area in Brinnon, is
neither appropriate from an economic nor environmental perspective. As you are aware, the
HCEC has opposed this proposal at every stage ofthe approval process forthe past 11 years.
Even the county's own Planning Commission has expressed serious concerns about the siting of
this MPR as stated in its July 6,2076letter to the Jefferson County Board of County
Commissioners (BOCC) as follows:
"We believe in the cose of this porticularly environmentally sensitive location, the county hos o
legal right, and in fact o legol ond ethical imperative, to go beyond the mitigotion meosures that
ore proposed in the FSEIS in order to be consistent with the Comprehensive Plan, Critical Areas
Ordinonce, the UDC ond stote ond federal requirements for the protection of the environment.
ln fact, there is volid concern thot odequate mitigotion of significant environmentol impacts
moy not even be possible given the scole of the proposed development ond the sensitivity of the
site and surrounding oreo."
As for economic considerations, we continue to have reservations about the costs to Jefferson
County if the Pleasant Harbor MPR is developed. We believe that the goals and policies guiding
new MPRs in the FTA Report should be strengthened with the addition of stronger language
regarding environmental risks and emphasizing the developer's responsibility to shoulder the
burden of additional costs to the public.
The best possible course of action would be to change the zoning in the Black Point/Pleasant
Harbor area to "residential" as it currently is in the rest of the area, and to reduce the density
regulations accordingly. The benefits to the environment and the public would be substantial.
Most importantly, the long, drawn out and contentious process, complicated by frequent
changes and uncertainties, would finally be settled.
The latest source of confusion regarding the status of the proposed MPR is the developer's
latest version, titled "Pleasant Harbor Marina and Recreational Community". The new
proposal, introduced in August of 20L6, differs substantially in scope and design from the
proposal described in the Final Supplemental Environmental lmpact Statement (FSEIS). At this
point, the Tribe, HCEC and other groups and agencies remain focused on the proposal in the
FSEIS and not the newer version. lt should be noted here that the FSEIS is far from final since
not all of the conditions established by the county have been met.
At a recent meeting attended by the developer, Jefferson County DCD staff, Port Gamble
S'Klallam Tribe (PGST) representatives, and other interested parties, tribal representatives
noted this confusion aboutthe status of the new proposal and raised the question about
whether the developer would move toward protecting Kettles B and C and associated wetlands.
For this to happen, the project would have to be redesigned. We strongly recommend that the
county honor the consultation agreement that was worked out between the PGST and
Jefferson County at the government to government meeting.
One final suggestion regarding the TFA Report is to add The Brinnon Group's name to the list of
"Stakeholders". This organization has been actively involved in the decision-making process of
the proposed MPR in Brinnon and its members would be the most directly impacted if the
proposed development is approved.
The HCEC appreciates the opportunity to provide comments on this phase of the
Comprehensive Plan Update process. We look forward to receiving information and updates as
the process moves forward.
Sincerely,
Donna M. Simmons, President
Hood Canal Environmental Council
(360].877-s747
nana@hctc.com