HomeMy WebLinkAbout63_Resubmittal Cover Letter 2025-0623June 23, 2025
Jefferson County,
RE:Permit No: SUB2023-00025 (Preliminary Plat Application for Pleasant Harbor
Master Planned Resort).
Explanation of Preliminary Plat Changes and Response to REVISED Technical Review
Comments
This letter outlines changes made to Pleasant Harbor Master Planned Resort (“MPR”),
Preliminary Plat Application SUB2023-00025 (“P-Plat”) and the rational for the changes. This letter
also provides responses to the County’s Revised Technical Comments dated August 16, 2024.
A. CHANGES
Pleasant Harbor made a number of changes to original preliminary plan of subdivision to
further achieve goals Development Agreement (herein “DA”) and further minimize it’s environmental
impact.
Listed below is the changes and the reason for the change.
1.Waste Water Treatment Plant
A.Action Taken: Because of the reasons above the MPR has moved the Waste Water
Treatment Plant from TRACT I to a new TRACT X-8 on the North East side of the
property. Pleasant Harbor moved the Waste Water Treatment Plant (herein “WWTP”) for the
following reasons:
(1)Appendix K, Ordinance 01-0128-08, Paragraph (63 w) requires us to save, where
possible, trees that have a diameter greater the 10 inches at breast height (herein
“DBH”). The location previously proposed area would have required the removal of
around .50 of an acre of relatively undisturbed native vegetation including a number of
trees larger then 10” DBH. The new location for the WWTP does not require removal
of more trees in excess of 10” DBH.
(2)Title 17 of the MPR encourages designs that minimize greenhouse gas (herein “GHG”)
emissions. Moving the WWTP to the new location will greatly reduce the amount of
electricity required for pumping. The new location allows for more gravity flow and
decreases pumping distances. The new location eliminates the the need for a sewer lift
station that was required for the prior location. In addition to reducing electrical
demand, by increasing the amount of gravity feed and limiting the amount of pumping
overall system reliability is improved.
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2.Green House
A. Action Taken: The green house has been relocated from TRACT X-7 to TRACT I for the
following reasons:
B.The green house had to be moved to accommodate the relocation of the WWTP as noted
above.
C.The new location of the green house requires very little modification to the existing
topography and vegetation. This location was previously cleared when it was the
campground, thus making it a suitable location for placement of the green house to be in the
best alignment with the tree preservation requirements of paragraph 63(w) of Ord. No 10-
0128-02.
3.Moving Service Road H Entrance
A.Action Taken: The MPR will use the existing road entrance off Black Point Road into
TRACT X-7.
B.On the East side of the property there is the MPR’s service road entrance. That entrance
was planned to go all the way to the North property line. There is an existing road entrance
off Black Point Road.
C.The relocation of the road will save a number of large trees grater than 10” DBH by
following the existing road entrance in accordance to 63(w) of Ord. No 10-0128-02. It will
also save around .30 of an acre of natural area.
4.Moving Road B West of TRACT X-7
A.Action Taken: Road B is relocated south about 45 feet, and reshaped to follow the existing
contours of the land. This change was made for the following reasons:
B.To save a 1.08 acre pocket of trees with a DBH greater than 10” in accordance with
paragraph 63(w) of Ord. No 10-0128-02 located on the north central portion of the property.
C.As required by Title 17 of the DA this movement will lower the GHG Emissions. The new
location eliminates the need to move around, 47,000 yd³of dirt that the prior road location
would have required. It keeps sequestered carbon in the existing grove of 10” DBH trees
intact. The relocation also eliminates the need for a large retaining wall and the carbon foot
print of 2,445 yd³ of concrete and over 50,000 lb of steel. Finally, it will also allow
revegetation of a larger portion of land on the West side of TRACK X-7.
D.Preserves a higher quality habit area that is more beneficial to wildlife.
5.Moving Convention Center and Hotel/Recreation Center
A.Action Taken: The Hotel/Recreation Center moved to the South about 45 feet and the
Convention Center/Parking Structure rotated 90° and move to the south in between two
ridges for the following reasons:
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B.These revisions were necessitated to allow for the relocation of Road B as noted above.
C.The two buildings are located to fit the contour of the land better. This will also advance the
goals of paragraphs 63 (u)&(v) of Ord. No 10-0128-02
D.The new building sites will also lower GHG Emissions by reducing the amount of grading
by around 13,000 yd³ of dirt for the Convention Center and 18,000 yd³ of dirt for the
Hotel/Recreation Center.
6. Boundary Line Adjustment
A.Action Taken: This BLA is on the north east side of the MPR property. The MPR is
exchanging the property to the South, for a strip of property to the North for the following
reasons:
B.The owner of an adjacent parcel filed a suit to quiet title alleging adverse possession in
Jefferson Superior Court No. 24-2-000214-16 The adjoining owner and Pleasant Harbor
have agreed to resolve the dispute by exchanging land through a boundary line adjustment.
C.This case is not final, however, the parties are in agreement and it is just a matter of the
paperwork being finalized. This is why it is being added at this time.
7. Storm Pond Movement
A.Action Taken: The storm pond in TRACT F, moved to the east and the TRACT was
adjusted to reflect that change for the following reasons:
B.Do to the above BLA and removal of the Sewer Lift Station the MPR is moving to existing
storm pond to the East.
C.This should eliminate the need for an additional access onto Black Point Road. With the
road access eliminated it will keep the existing vegetation along Black Point Road.
8. Housing Density
A.We adjusted the single family house lot density down to better work with the land
topography. The following changes where made:
(1) Road E
(a)The MPR removed all the house lots along Road E on the West side of the property.
(b)With hearing the need from Commission Dudley-Nolette that Jefferson Co needs
Senior Living, the MPR replaced the lots with a full time Senior Living Center
location, that fits the topography of the land better with about 5,000 yd³ less dirt
moved.
(2) Road F
(a)To excavate less and work with the topography of the land better, the lots where
rearranged and a multi-family TRACT X-13 was added. This will reduce the overall
foot print on the land.
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(3) Road A, C and G Lots
(a) The lot density was lowered on Roads A, C and G to allow for less excavation and
work more with the lands natural topography.
(b)On Road G lots where added the to North side of the road.
(c)On the North End of Road C the road was moved closer to the property line to
decrease the required excavation.
(4) Road B Lots
(a)Along Road B the lots were decreased from 52 to 43. The lots were adjusted to work
with the topography of the land and save more of the natural existing vegetation.
(b)We dropped a few of the lots to allows us to keep open two natural infiltration
locations as well as open up some wildlife corridor crossings.
(c)With the movement of Road H to the South we Lost 2 lots as well.
(d)Since the reduction in house lots we added a Multi-Family location on North end of
Road B, TRACT X-11
(5) TRACT X-12
(a)At the East end of Road C, TRACT X-12 was adjusted to work with the topography
of the land to require less excavation and land retention to allow for more
vegetation.
(b)The building is planned to be smaller and that density to be spread out across
multiple Multi-Family buildings, thus decreasing the building footprint.
B.The County commented that the ERU numbers of the Plat where wrong. The Plat shows
that the housing density is 822 ERU. The 822 ERU is because the Plat does not encompass
the entire MPR. When you add the numbers not included in this Plat, of 66 ERU for the
Maritime Village and the 2 BnB’s by the marina, you reach the 890 ERU for the entire
MPR. Also to clear up any confusion on the Plat Cover Sheet reference to parts of the
project not included in this Plat have been removed. Please note that the Civil Plans
references the entire MPR because its calculation are to the entire MPR.
C.The total Single Family house density decreased and the MPR is placing it into Multi-
Family. We went from 216 Single Family Lots down to 150 Single Family Lots.
(1)This will also help lower the water usage for the MPR, as historically Multi-Family
homes use less water.
9. Southern Sewer Lift Station
A.Action Taken: The Sewer Lift Station was moved from the far West side of Road C, to the
Southern Storm Retention Pump Station location for the following reasons:
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B.This change will work with the with the topography of the land, so less earth moving is
required, thus lowering the GHG emissions.
C.This move will work to prevent the need of two standby generators by combining the Storm
Water Lift Station and the Sewer Lift Station standby power into one system. This will help
to lower the GHG emissions by an entire generator and overall carbon footprint of the MPR.
10. Wildlife Corridors
A.Jefferson Co in its May 27, 2025 BOCC letter, mentioned that we where “4. Moving the
wildlife corridor,”. The wildlife corridors were opened up more then moved.
B.With the lowered density of home lots on Road C & E and the removed lots, this will
preserve more of the trees as well as keep more of the wildlife corridors naturally forested
and open to the wildlife.
C.The movement of Road B South is also opening up the North side of the property to more
wildlife habitat in a larger well established forest area.
D.The larger lot size of the lots to the South will allow for easier movement of wildlife
through that area.
11. Wetland C Buffer
A.Ms. Hayworth noted that the Wetland C buffer did not match the updated boundary by Geo
Engineers. After further review Ms. Hayworth was correct, the buffer was the right size, but
the wrong shape.
B.Action Taken: The buffer was updated and the lines where adjusted. The two other buffers
where checked and they are correct.
12. Injection Well Locations
A.There are three wells shown on the Northwest side of the property. Ms. Hayworth noted
that the recharge wells were located in the golf course. She also noted that a golf course was
not allowed to be within the 100’ radius.
B.The wells are not planned to be installed at this time. The wells would only be installed in
the event of saltwater intrusion into the aquifer. The exact well location would be chosen by
the hydrologist at that time.
C.While looking at the code, the 100’ radius pertains to Potable Wells. A golf course is not
called out by the code, however, chemical usage would need to be restricted within the area.
D. Action Take: We have moved the proposed location outside the golf course. The exact
location may be adjusted by the Hydrologist and time of permitting.
13. Golf Course
A.There was some updates to the Golf Course to work with the topography of the land better
and allow different levels of player to play, do to the elevation changes. This will allow
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junior players to be able to learn to play.
14. Main Entrance Road Access
A.Action Taken: The MPR has listed the road entrance as an easement so that it can be
adjusted to fit the actual design once approved.
B.The MPR is proposing to keep the main entrance to the resort in its current location, Old
Black Point Road.
C.Keeping the old entrance will create a better line of sight down Black Point Road. This will
make it a much safer exit onto Black Point for the people turning left, which is the majority
of the traffic. The entrance is at a angle now so the intersection would need to be
straightened slightly to achieve optimal the line of sight.
D.In 63(s) it wants us to keep the green belt along 101. By keeping the road to Old Black
Point it will keep the green belt intact, by allowing the MPR to weave the utility easement
through the woods vs cutting all the trees down and excavating the road out and re-
vegetating. There will be over 1.1 acres of trees larger then 10” DBH saved.
E.This will also lower the GHG emissions by a reduction of 9,000 yd³ less dirt moved.
F.The following steeps need to happen for this change. Jefferson Co Public Works would
need to release Old Black Point Road to the MPR or MPR would connect to the Co road and
work with Public Works to make the intersection improvement.
B. Response to August 16th County Comments
Pleasant Harbor provides the following responses to the County’s comments in its August 16th
letter.
Comment 1—Plan Corrections:
The markups have been addressed in the revised plan set.
Comment 2—Plan Set Inconsistent:
The inconsistencies have been corrected.
Comment 3—Conservation Easement:
The location of the conversation easement is noted on Plat Sheet 19, 23, 25 & 26, Comment 11.
Comment 4—Setbacks:
The building setback is depicted. We disagree that pedestrian paths are prohibited in the
setback. The pedestrian paths are not “structures” as within the meaning of JCC 17.65.040. The
purpose of the setbacks was to minimize visibility of buildings from public areas (US 101,
Black Pt Road, Hood Canal etc.). The setbacks were not intended to preclude non-buildings.
Indeed, one of the mitigation measures requires installation of a fence on or close to the west
property boundary to prevent elk from entering the Property. This fence would be installed
within the setback area and confirms that intent of prohibiting “structures” in JCC 17.65.040
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was not intended to prohibit passive recreation improvements (like paths) or mitigation
measures (like the elk fence).
There are no minimum lot size requirements imposed in the MPR. Therefore, there is no need
to calculate buildable area. We are comfortable with the lots and tracts as they have been
outlined at this preliminary level. Lot and tract adjustments may be made at final plat approval
as site infrastructure is fully designed, as is customary, consistent with state law and applicable
County regulations.
Note, Please see Comment 6 below, Plat Comments, for Tracts and Lots with building on them.
Setbacks have been noted pursuant to JCC 17.65.040.
Comment 5—Vegetation Management:
a. Blending of Buildings.
The preliminary plat application outlines the general layout where lots and roads will be
located. It does not authorize construction of buildings. Per the plain terms of the ordinance
condition “buildings must be constructed and placed in a such a way that they blend into the
terrain and landscape with park like greenbelts between buildings”. The County says “not
enough information has been provided to determine compliance with this requirement” without
specifying what else is required.
Clearly, actual building design is premature at this early stage. Addressing how buildings will
be constructed to blend in like building height, materials, architectural features and landscaping
are more appropriately addressed during building permit review when building plans (including
grade, elevation, and design) are actually prepared. The lot layout leaves room for building
design that can satisfy this requirement. Additionally, a landscaping plan will be provided for
each lot when the permit is applied for to demonstrate compliance with 63 (u) & (v).
Nevertheless, as noted in the changes above, Pleasant Harbor has made a number of changes to
the original plat design to follow existing land contours where possible to minimize the amount
of grading required.
b. Tree Preservation.
As noted above, the tree preservation requirement is not applicable to preliminary plat.
Nevertheless, the preliminary plat layout strives to avoid trees in excess of 10 inches dbh. The
Vegetation Management Plan (Appendix L) (“VMP”) rated forested areas based on the age of
trees (which roughly correlates to the size of trees). The forest areas with the oldest growth and
thus, the highest densities of trees exceeding 10” dbh are rated BP-1 and shown Figure 13 of the
VMP. The preliminary plat avoids those areas where possible. For example, and without
limitation, Tract H, I, E-1, E-2 and X-4 are working to preserve most of the BP-1 trees.
Second, when laying out roads for the preliminary plat effort was made to track the location of
the existing roadwork through the property to further minimize impacts to forested areas. This
is partly due to necessity because, as the County is aware, terrain on the property is uneven and
following the existing road network minimizes the amount of grading required. It is also worth
pointing out that when the Ordinance was adopted the master planned resort contemplated an
18-hole golf course. Since then, the golf course has been reduced to 9 holes which has allowed
for even greater retention of trees than what was possible when the Ordinance was initially
adopted and this condition contemplated. The golf course has been updated to work with the
already cleared areas of land as best possible.
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PHMPR has a staff arborist on site. Although not required by the ordinance, prior to conducting
work on roads and related infrastructure to achieve final plat approval the arborist will mark any
qualifying trees that must be removed for road and related infrastructure improvements needed
to achieve final plat. This will allow for potential plan deviations to preserve trees where
possible.
Finally, the applicant is not required to preserve all trees exceeding 10” dbh. Condition 63(w)
states that construction of buildings will be completed in a manner that “strives to preserve
trees” that have a 10”dbh. It does not, as the comment suggests, require preservation to the
“maximum extent possible”.
Nevertheless, Pleasant Harbor took a hard look at where additional design changes could be
made to reduce potential impacts to stands of trees with a dbh greater than 10 inches. As noted
in the changes section, Pleasant Harbor made a number of changes to accommodate this
comment including, but not limited to, moving the WWTP and relocating roads.
Comment 6—Building Envelopes:
The building envelope requirement in JCC 18.35.400(4)(g) does not apply. The purpose of this
requirement is to map code-required setbacks on each lot. The MPR ordinance does not require
internal lot setbacks except for any lots located within 20 feet of an exterior MPR boundary
(which have been marked). The MPR only requires 10 feet of separation between buildings.
The building envelope is, therefore, the lot boundary. That does not mean, however, that an
applicant can cover the four corners of the lot with a building. As noted above, buildings must
be seperated a minimum ten feet and designed to blend into the terrain and provide green areas
between buildings as well as preserve trees 10” dbh, among other things. Setting a building
pad/envelope at this stage will arbitrarily limit development of actual buildings to a specific pad
and may impede designs that better achieve other design goals on a lot-by-lot basis as actual
construction plans are developed and submitted to the County including tree preservation and
aesthetic considerations.
The following notation has been added to Plat Sheet 10, to address the 10’ foot separation
requirement:
[Plat Note:] All buildings in the plat shall maintain a minimum 10’ foot separation from
adjacent buildings.
(a)Lots 1-150, shall have a building envelope setback of 10’ from a neighboring
building and shall be restricted from building in any easement within the lot, per
JCC 17.65.040(2).
(b)Lots 108-117, shall have an additional setback restriction to the above restrictions.
No building shall be placed within the 100’ Steep Slope Building Setback that is
indicated on the Plat maps.
(c)Tract I, X-12 & X-14, shall have a 20’ from MPR Boundary Line building
restriction, per JCC 17.65.040(1).
(d)Tract D, shall have a building setback of 35’ from US HWY 101 right-of-way, and a
20’ setback from the Black Point Road right-of-way, per JCC 17.65.040(1).
(e)Tract X-7 and F, shall have a building setback of 20’ from the Black Point Road
right-of-way, per JCC 17.65.040(1).
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(f)All lots and tracts associated shall be follow JCC 17.65.040(1)(2) setbacks.
(g)Final Plat, may have further restrictions placed on a lot at time of Final Plat
application and shall be bound to the MPR Development Agreement.
(h)There are no front, side or rear yard restrictions and shall follow MPR Development
Agreement.
Comment 7—Geologically Hazardous Areas:
a.Geotechnical Study .
PHMPR disagrees that a new geotechnical report is required. The prior report delineated
the areas deemed geologically hazardous on the property. That has not changed.
Nevertheless, Pleasant Harbor commissioned a report review from Krazan & Associates,
Inc. dated October 15, 2024 (“Krazan Review Report”). The Krazan Review Report
concludes that geologically hazardous areas from the prior report remain unchanged. The
cut and fill on page 46 of the 2008 report shows, the cut and fills in the same locations, as
will be done in this current Plat.
The only Seismic, Erosion and Land Slide hazard areas listed in the report, on Page 47, for
the project, are outside of the areas proposed for development.
b.Recommendations .
The top of bluff along the southern property edge was resurveyed by Krazan and now is
depicted on both the preliminary plat and the preliminary civil engineering plans. While we
do not believe the cart path is prohibited in this area we have relocated it.
c.Phasing .
The Krazan Review Report concludes that Pleasant Harbor’s current construction
sequencing phases will not undermine existing potentially geologically hazardous areas.
Please note that while the Krazan Review Report references “phases” that is not intended to
deviate or establish phases that differ from those set out in the Development Agreement.
Rather, the reference was intended to identify areas that will have ground disturbance at or
around the same time for purposes of assessing impacts to geologically hazardous areas.
Any phasing of final plats will follow the phasing requirements in the Development
Agreement.
Comment 8-_Wetlands:
a. Delineation.
Please see the enclosed Wetland Verification Report prepared by Geo-Engineers and dated
October 18, 2024.
b.Establishing Buffers .
Please see the enclosed Wetland Verification Report prepared by Geo-Engineers and dated
October 18, 2024 addressing applicable buffers. The buffers have been placed on the
revised preliminary plat. Pleasant Harbor is requesting that the buffers for Wetland C be
averaged as permitted by County Code. The averaged buffers are located on Plat Sheet 16
and explanation for the averaging is on page 8 of the October 18, 2024, Geo-Engineers
Wetland Verification Report.
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c.Buffers in Conservation Easements .
The updated wetland buffers are reflected on both the preliminary plat and preliminary civil
plans. A draft conservation easement is provided with this letter. Applicant will record this
with final plat approval. A notation requiring recording at final plat approval is included on
Plat Sheet 10 (#31).
d.Buffer Encroachments .
Although lot boundary may extend into wetland buffers, the proposed residential lots
impacted by the wetland buffer have been modified on the revised preliminary plat and civil
plans. Other encroachments have also been removed. Buffer Averaged now needs Jeff Co
approval to complete the process.
Comment 9—Recharge Wells:
The wells on Sheet 15 and 20 are not a recharge well they are Proposed Potable Wells. Sheet 21
well is the ACG well. Fairway 3 of the golf course is relocated outside the 100’ radius. See
comments in A.12. of this letter for more reference to recharge wells.
Comment 10—Healthcare MOU:
Float Planes:
The US Navy will not allow float plans in the vicinity of Pleasant Harbor.
Helicopter Landing Pad:
The comment that we need to have a Helicopter Landing Pad (“Heli Pad”) because Appendix J,
Memorandum of Understanding (“MOU”) with Jefferson Healthcare (“JH”). The MPR added
that to its P-Plat updated submittal that was turned in on January 31, 2025. However, with a
closer review of that MOU, Appendix J, Fire/EMS (“Fire”) MOU, and JCC 17.75.030
Prohibited Uses, the MPR is precluded from adding a Heli Pad to the site.
The text of paragraph (7) of the JH MOU reads “Should the Resort expand and require
emergency Air-Lift capabilities, a suitable landing zone will be provided to accommodate
helicopter or float plane transport.”
The text of paragraph (5. d.) of the Fire MOU reads “Helicopter Landing Zones will be utilized
by the established landing zones already in place and approved by Airlift Northwest and
Brinnon Fire Department.”
Because of the above, the MPR has removed the Heli Pad from the P-Plat, however, the MPR
will reserve space in TRACT H if the need arises per the JH MOU.
Comment 11—Appendix P, Wildlife Management Plan.
a.Report Figures .
We presume you are referencing the legend on the right hand side. These figures were
based off the site plan for stormwater. The legends outline stormwater improvements which
have no bearing on the depicted wildlife corridors. A new map has been provided and
attached to the “Pleasant Harbor Wildlife Management Plan Rev 5.pdf”. The new map
depicts the current layout.
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b.Site Features .
Amendment 1 dictates that an exclusion fence must be constructed along the western
boundary of the MPR south of Black Point Road. The fence will be constructed as required.
This is not an issue for preliminary plat approval, but is a condition that must be met for
final plat approval. PHMPR is consulting with Dylan Bergman, wildlife biologist for the
Point No Point Treaty Council about fence location. Dictating the exact fence location on
the plat is premature and not necessary. Site specific design may require some deviation to
achieve overall goals of the MPR including, but not limited to, tree preservation. We have
added a note to Plat Sheet 10, to insure its inclusion into the plan for Final Plat.
Comment 12—Appendix S Dark Sky Standards.
1.Illumination Standards . The applicant will comply with the lighting standards in
Appendix S. A narrative of how we will comply is not required for preliminary plat
approval. The County and Hearing Examiner can condition preliminary plat approval that
all road and path lighting meet the Appendix S standards.
2.Lighting Extent . At time of construction permitting, an updated illumination sheet will be
provided showing the lighting and illumination footprint. The intent of the lighting map
was to demonstrate the calculation of the avg foot candle at road level. The light pole hight
in the plan is wrong and is noted for correction at time of construction permitting.
The road layout on the provided plans is very close to the design of the submitted Plat. The
paths have changes, however, foot level illumination will be accurate. The exact lighted
pathways will be denoted in the construction permit application
Comment 13—Existing Wetlands.
Please see response to Comment 8 above.
Comment 14—Roadway Maximum Slopes.
Maximum longitudinal roadway slope are not planned to exceed 10%. Actual road grades are
shown on the sheets. For example, see Civil Sheet 12, Tract X-12, Road C.
Comment 15—Sanitary Sewer.
Appropriate easements and/or tracts for development and operation of a public sewer system
and water system will be created with the final plat based on the final configuration of as-
constructed systems serving the master planned resort. Pleasant Harbor has identified
easements it knows will be required. See for example, Plat Sheet 20, Lots 17 & 30, show the
easements across multiple lots.
Comment 16—Setback Distance for Well.
The County misinterprets the SWMM. Suitability of stormwater infiltration ponds must take
into account any drinking water wells within 500-feet. That requirement of the SWMM does
NOT require a 500-ft setback as the County asserts.
Please see Steve Hatton’s response below:
"In Section V-5.5 of the 2019 DOE SWMM, the 500-ft reference is NOT a setback. Rather, this
section pertains to Site Characterization for Infiltration. “Documentation” must be considered
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for topography within 500-ft of a proposed infiltration as well as well as the presence of water
wells within 500-ft, among many other elements included in this section. The SETBACK from a
potable water supply well to a stormwater infiltration pond is 100-ft which the proposed pond
and new well will meet."
Comment 17—Stormwater Drainage Easements.
The storm system has not been fully designed. As a result, we cannot provide every easement
in the exact location on the preliminary plat and providing arbitrary easement locations would
be fruitless as those locations would likely change. It is appropriate to condition final plat
approval on construction of code-compliant stormwater facilities and identification and creation
of all appropriate easements to operate the same through the MPR. Most have been already
listed and may require adjustments for final system plans and will be denoted for final plat as
they will have been constructed.
Comment 18—Geotechnical Recommendations.
Please see response to Comment 7.
Comments 19-23—Roadway Widths.
Please see the attached Memorandum dated October 2, 2024 from Michale Read, PE with
TENW for a response to Comments 19-24.
In addition to the TENW Memorandum, increasing the paved width will compromise other
goals of the MPR with no material corresponding benefit. For example, increasing the paved
width will impede the goal to preserve trees exceeding 10” dbh and will further reduce the open
space corridors and vegetated areas with the resort, among other negative impacts. It will also
increase the impervious surface and require more water to be treated, increasing the overall
carbon footprint of the resort vs larger natural greenbelts.
Finally, upon more detailed review it appears the reviewer compared the project against the
Jefferson County Colorado Transportation Design and Construction Manual. We were unable to
find any such manual in the Jefferson County Washington Code or website. Moreover, the
Jefferson County Colorado Transportation Design and Construction Manual contains the
sections and standards cited to in the comment letter.
Comments 24-26—NFPA 1141:
The NFPA 1141 comments appear to result from the use of the Jefferson County Colorado code
requirements noted above. TENW and our team find no reference to this in any of the Jefferson
County Washington code or the Brinnon Fire Department. Finally, the MPR will not be
designing to NFPA 1141 code it will adhere to the Jefferson County Washington code listed in
the attached TENW Memo.
We look forward to your review. We would appreciate the courtesy of being able to review the
County’s proposed conditions of approval before the application is conveyed to the Hearing Examiner.
The conditions should be limited to those needed for final plat approval.
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520 Kirkland Way, Suite 100, Kirkland, WA 98033
(425) 889-6747 www.tenw.com
MEMORANDUM
DATE: October 2, 2024
TO: Cristina Haworth, AICP
Jefferson County
FROM: Michael Read, PE
TENW
SUBJECT: Minimum Roadway Width – Response to SUB2023-00025 Technical Review Comments
Pleasant Harbor Master Planned Resort
TENW Project No. 2901
This memorandum summarizes the roadway width requirements for the Pleasant Harbor Master Planned
Resort project in response to the August 16, 2024 comments from Jefferson County that TENW received
on September 12, 2024. The project proposes several roadway sections that meet the minimum
requirements as outlined in the 2018 International Fire Code (IFC) and the Jefferson County Code (JCC).
Overview of Design Context
The Jefferson County Code (JCC) Title 18 Unified Code Development, Chapter 18.30 Development
Standards, Section 18.30.080 Roads adopts the American Association of State Highway and
Transportation Officials (AASHTO), A Policy on Geometric Design of Highways and Streets. P er the AASHTO
A Policy on Geometric Design of Highways and Streets, Section 5.2.2 Cross-Sectional Elements, Table 5-5,
Minimum Width of Traveled Way and Shoulders for Two-Lane Local Roads in Rural Areas, the minimum
width of traveled way for a volume of 400 to 2,000 vehicles per day (vpd) and a design speed of 15 to 25
MPH is 20 feet. Table 5-5 is included in Attachment A. Jefferson County code does not adopt any other
roadway references to alternative geometric standards that require wider dimensions.
Per the 2018 International Fire Code, Chapter 5 Fire Service Features, Section 503 Fire Apparatus Access
Roads, subsection 503.2.1 Dimensions:
Fire apparatus access roads shall have an unobstructed width of not less than 20 feet (6096 mm),
exclusive of shoulders, except for approved security gates in accordance with Section 503.6, and
unobstructed vertical clearance of not less than 13 feet 6 inches.
For internal circulation and to provide access to community amenities and residences, the project
proposes to construct several internal roadways with varying sections. The proposed roadway sections
for the internal roadways are shown in Attachment B. The roadway sections vary depending on
anticipated use, with traveled way ranging from 20 feet to 24 feet. The posted speed of the interior
private roadways at the project are all proposed to be 20 MPH.
The design of the proposed roadways was based on multiple factors in addition to the minimum
roadway width standards described above. These private local roads are intended to be low speed,
neighborhood resort roadways. Therefore, the roadway widths provide additional traffic calming
measures to achieve this intent. In addition, the roadway design minimizes stormwater generating
surfaces to assist with achieving the mitigation requirement stormwater treatment on-site. Lastly, the
Exhibit 63
Minimum Roadway Width Memo
Pleasant Harbor Master Planned Resort (Jefferson County)
October 2, 2024
Page 2
proposed design helps to achieve the mitigation requirements to blend with the natural setting and
improves the ability to preserve trees and other existing natural landscape features.
Conclusion
As demonstrated in our review, the 2018 International Fire Code and A Policy on Geometric Design of
Highways and Streets were considered in determining the minimum roadway width required for the
Pleasant Harbor Master Planned Resort project. As demonstrated, these criteria would be met or
exceeded with the proposed roadway sections provided in Attachment B. The proposed roadway widths
provide additional benefits to the Pleasant Harbor development including traffic calming/speed control,
stormwater management, and native vegetation preservation.
Please contact me at (206) 361-7333 x 101 or mikeread@tenw.com with any questions.
Attachments
Attachment A – AASHTO – A Policy on Geometric Design of Highways and Streets, Table 5-5
Attachment B – Proposed Site Plan and Roadway Sections
Exhibit 63
Minimum Roadway Width Memo
Pleasant Harbor Master Planned Resort (Jefferson County)
ATTACHMENT A
AASHTO A Policy on Geometric Design of Highways and
Streets, Table 5-5
Exhibit 63
Exhibit 63
Minimum Roadway Width Memo
Pleasant Harbor Master Planned Resort (Jefferson County)
ATTACHMENT B
Proposed Site Plan and Roadway Sections
Exhibit 63
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