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HomeMy WebLinkAbout257Point No Point Treaty Council Port Gamble S'Klallam o Jamestown S'Klallam December 8,2011 Jefferson County Department of Community Development ATTN: Michelle Farfan 621 Sheridan Port Townsend WA 98368 D) lnllJu tr Gtr[Vtr DEC I 8 2017 JIFIIiISON COUNTY .(]PMT(]F COI,4MUNI] Subject: Revised Wildlife Management Plan for Pleasant Harbor Master Planned Resort Dear Ms. Farfan The Point No Point Treaty Council (PNPTC) is writing in response to your request for comments specific to the November 2,2017 Revised Wildlife Management Plan prepared by GeoEngineers Inc. for the Pleasant Harbor Master Planned Resort (MPR) in Brinnon. As you are aware, on August 3l,20ll we submitted comments on GeoEngineers' original Wildlife Management Plan dated July 31, 2Ol7 . Following our review of the Revised Wildlife Management Plan, it is our conclusion that the plan still has only partially met the requirements of Jefferson County Ordinance 0 1 -0 I 28-08 condition 63(l). The major shortcoming in the revised plan is that it still does not describe management actions in sufficient detail to allow the assessment of risk or the likelihood of success. Evaluating the potential efficacy of management actions, or their impacts on wildlife is not possible because the descriptions of these actions are vague and incomplete. Please refer to Section 4 (bottom of page 7) of our August 31,2017 comment letter for further discussion of this topic. It is unclear to us how Jefferson County will be able to monitor or enforce compliance with the WMP, given its lack of specificity. The new provision relating to the installation of a fence illustrates this point. The Revised WMP sums up this vital wildlife management action in a single sentence, stating only that "the Applicant has agreed to satisfy the concerns of PGST to install a west oriented fence in any open areas where elk could find access to the t holes of golf course grasses" (page 8, first full paragraph). The Point No Point Treaty Council and the Port Gamble S'Klallam Tribe sincerely appreciate the applicant's willingness to revise their plan to accommodate a fence. It is not possible however, for the reader to evaluate whether such a fence will be effective without at least a cursory description of the fence in the WMP. Please be aware we are not asking for detailed engineering specifications. There is a need, however, for the WMP to describe the fence in sufficient detail to allow the Jefferson County staff to evaluate whether the applicant has met the County's expectations for mitigating the impacts of the MPR on wildlife. To add to the confusion, farther down on page 8 (second bullet point) the Revised WMP continues to state that installation of a fence will be done "as a last resort." Several concerns we raised in our August 31 comments on the original WMP were not addressed in the revision. First, the Revised RMP still contains outdated information about the life history 19472 Powder Hill Place NE, Suite 210 Pou lsbo, Wash ington 983 70 a Office (360) 297-3422 a FAX (360) 297-3413a and ecology of the Duckabush elk herd, including the erroneous statement that it is a migratory herd. Please refer to Section 2 (bottom of page 2) of our August 31,2017 comment letter for further discussion of this topic. If the WMP is to be used as a blueprint for mitigating the impacts of the MPR on wildlife, it must be based on the best available scientific information. Erroneous information detracts from the credibility of the WMP. Second, the Revised WMP still does not contain an expressed, definitive, enforceable commitment that wild animals will not be killed when conflicts arise. This is also a concern of the Washington Department of Fish & Wildlife. Please refer to Section 6 (page 9) of our August 3l,20ll comment letter for further discussion of this topic. Third, the Revised WMP is still short on details of how the managers will evaluate the effectiveness of their wildlife management actions, and how they will respond if such actions prove ineffective. Please refer to Section 5 (page 9) of our August 3l,2Ol7 comment letter for further discussion of this topic. The Revised WMP doesn't reflect some of the discussions we had in the field on the October 19th site visit to Black Point. One revision to the WMP regarding the strategic use of unpalatable plants to deter elk states only that the applicant "will investigate" whether such technology exists. No further detail about the landscaping of the golf course (such as the use of junipers and low shrubs between tee boxes and fairways) is provided, despite our concurrence during the site visit that such action is a key component of preventing elk from occupying the site. The revised plan needs to more thoroughly address the conclusions we reached on the October lgth site visit. Thus far our comments have focused on the absence of sufficient detail in the WMP and on the resulting inability of reviewers to assess risk and effectiveness of the actions proposed. Now that the Pleasant Harbor project has reached the stage of formulating an official Development Agreement, we must also question how Jefferson County will be able to measure compliance with the WMP. In our experience, any statement of proposed actions that is intended to be legally binding must contain performance standards that are objective, quantifiable, and measureable. The WMP fails to identify such standards. Without quantifiable standards against which to measure performance, Jefferson County will not be able to monitor or compel compliance with the WMP. For example, the WMP uses terms such as "reduce," "minimize," and "prevent diminishment of." In most cases, however, no baseline level is identified. We question how Jefferson County will be able to determine whether reduction of an impact or diminishment of a resource has occurred without knowing a baseline level. Even if the baseline level were known, in most cases the WMP doesn't specify the magnitude of the reduction or diminishment expected of a given action. How will the County determine if an action is sufficient to establish compliance, considering that no quantifiable objectives are stated? These shortcomings can be rectified by revising the WMP to make use of clear, unambiguous action verbs linked to quantifiable objectives. The plan must state how progress toward the objectives will be measured and what remedial actions will be taken if the initial action fails to meet the objective. We consider it a given that any credible natural resource management plan must have these basic evaluate compliance. PNPTC comments on Pleasant Harbor them, there isruldiable way for Jefferson County to\J DEC Page 2 of 3 Dn Wildlife Management'Plair t In summary, it is our conclusion that the Revised Wildlife Management Plan still does not describe management actions in sufficient detail to allow an independent and unbiased assessment of the probability of success or of the risks to wildlife. Nor does it contain a description of measureable performance standards that will to allow Jefferson County to determine whether the applicant is in compliance with their commitments to mitigate the MPR's impacts on wildlife. At some point Jefferson County is going to need a legally binding document that specifies the responsibilities of the applicant in sufficient detail that it will allow the County to objectively determine whether those responsibilities have been met, and to compel compliance if they aren't met. There are two ways to do this: I ) ensure that the WMP specifies quantifiable objectives, a description of how progress will be measured, and a description of actions to be taken if the objectives are not met, or 2) ensure that these standards are specified in detail in the Development Agreement. The Point No Point Treaty Council and the Port Gamble S'Klallam Tribe respectfully urge Jefferson County to continue to consult with us regarding the Pleasant Harbor MPR's proposed actions to manage wildlife. Respectfully, Timothy P. Cullinan Wildlife Program Manager cc: Randy Harder, PNPTC Paul McCollum, Port Gamble S'Klallam Tribe Hansi Hals, Jamestown S'Klallam Tribe Roma Call, Port Gamble S'Klallam Tribe Charin Godbolt, Port Gamble S'Klallam Tribe Bryan Murphie, Washington Department of Fish & Wildlife Matt Blankenship, Washington Department of Fish & Wildlife ffi trGtr[Vtr DEC 1 8 2017 JEFTERS()N COUNIY N[PT. OT COMM /TLOPMENT D lft lf tSOt't COUr, ti PNPTC comments on Pleasant Harbor Revised Wildlife Management Plan Page 3 of 3 L+ (L 'nl t L0P[a