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Home My WebLink AboutLog016 ~ .' t ,.~ ">.~Si \.-. A Pope Resources Company' ~D..'...... ...'...rE..................~. '.' re..........~..... ...WI.,. IE. ".....~'.~. ........... ..... I..... .~--~..... '. I....... '.'...JU.l. 26 2000..1 ~. . ' .... . '. . .' .1 --......,.......---.-.".......J JEFF(HSON COUNTY DEPl OF:~OMMIJNITYOEVELOPMENT July 25, 2000 Al Scalf, Director ofComm1,lnityDevelopment Jefferson County Permit Center 621 Sheridan Street Port Townsend, W A 98368 Jerry Smith, Project Plan.ner Jefferson County Permit Center 621 Sheridan Street Port Townsend, WA 98368 Subject: Shoreline Substantial Development Permit Application Port Ludlow Marina Expansion Project Dear Al and Jerry, On behalf of Olympic Property Group, I ampleased to submit an application for expansidn of the Port Ludlow Marina. Project Description Port Ludlow Marina has 280 existing slips plus areas for approximatel)f40 additional boat sideties.. The application prQPosesexpansion of the Marina qyadding 100 new slips. '.An, existing dock for kayak rentals and storage will be upgraded. 111 addition, the project will include upgrades to the existing infrastructure including the electrical system and lighting. The work will be conducted in such a manner as to minimize impatts On "the marine habitat. Olympic Property Group (OPG)has been planning andevaluatingamarinaexpam;ion for the Port Ludlow Marina for over ten years. The TOO-slip expansion was evaluated and discussed in a 1993 EIS and numerous public and regulatory meetings. The. final proposed layout for the expanded Marina encompasses the many public and regulatory comments anderivironmental reviews that have occurred over the past ten years. LOG "'TEM #(~ pageJ-vl~ -I "--:-"~" ' . . \ '..' 19245 Tclith Avenue Northeast, P,O, fro.x1780, Poubbo~WashingtOll 98370,0239 (360) 697-6626, Seattle: (206) 292-0517, Fqx: (360)697-1156 o .. \.... 'AI Scalf, Director ofComt1'rtrhity Development Jerry Smith, Project Planner Jefferson County Permit Center July 25, 2000 Page 2 \J Submission Materials We have prepared the following documents relating to our applicatjon for a shoreline sub,stantial development permit for the expansion of the Port Ludlow Marina: 1. Signed JARP Aapplication 2. Drawing Sheets 1 to 4 3. SEP A Environmental Checklist 4. Biological Evaluation prepared byPentec Enviromnental 5. Letter regarding results of the Sonar Surveydemons~rating no vegetation in the project ~ci~ty " , 6. Memorandum regarding Public Comments/Public Involvement 7. Memorandum regarding Parking ManagellientPlaIl 8. Memorandum regarding Public Access SEPA Issues In February 1999, the Port Ludlow Marina had vacantslips.Today,it has a waiting list06nore than 180 boat owners. Last year there was no need to move the Marina expansion project , forward. Today, the Port Ludlow community needs this project. We ,expect it will take many months to obtain the discretionary land use approvals required to expand the Marina from Jefferson County, the Washington State Department of Fish and Wildlife, and the U.S. Army Corps of Engineers. J am writing this letter mainly to desGribe my understanding, based oR' our recent discussions, of Jefferson County's requirements forehvironmentaLl'eview of this project under the State Environmental Policy Act. First, with respect to your threshold determination under SEPA, I linderstalld that you are likely to issue a determination of significance and require thecOlnpletionofaSupplemental Environmental Impact Statement prior to making any substantive decision regarding this project. The SEIS would supplement the final environmental impact statement for the Port Ludlow Development Program dated April 12, 1993, and otherenvirolllrientaL documentsrelatingto the impacts of the Marina expansion project. The SEIS maybe comprised of existing environmental d()cuments,but may also include additiomilreportsor studies. ' , Second, with respect to the scope of environmentalreviewunder ~EPA, Iunderstand that the , scope of the SEIS will be limited to the environmental impactsoftheMarina expansion project. I understand that under Section 3.902.1 ofOrdinanceNo.08-1004-99,aproj~ct level SEIS. "analyzing the resort plan is required prior to issuance of building permits for any new resort development." Section 3.902.6 similarly proyides, "Actual resort development maybe undertaken in phases, but only following completion of review and approval of a full resort ,LOG ITEM, # l~ Page 'Z-.'Of~ .~~' ";'" Al Scalf, Director of Com~nity Development Jerry Smith, Project Planner Jefferson County Permit Center July 25, 2000 Page 3 '::-!,. buildout plan through the SEISprocess." ,I understand,' based onthese subsections of the ordinance, that you will not issue a building permit for (and we may not begin construction 'of). the Marina expansion project unless and until we comply with these requirements as written or. amended. In other words, althoug, h we may obtain land use approva, Is relating to the Marina expansion project based on environmental revi~w()ftheimpactsofthatproject, we may not obtain a building permit to begin constructionofthatproject untilwe comply with these subsections of the ordinance. We do not propose to obtain buildingpermitsorbegin~ctual resort development of any portion of the resort plan, including the Marina exp(insion project, until we have complied with these subsections. I acknowledge that Section 3.902 oftheordinance also provides, "Environmental review of the Resort Plan shall not be piecemealedor'broken into small segments'?' I recognize that piecemealing is not allowed under SEP A, but phased review is allowed when certain criteria at:e met. Phased review ofland use approvals relating to,the Marjnaexpansionprojectis appropriate' under SEPA, even though phasedreview of building permit approvals reTatingto any resort development may not be appropriate under Sections 3'.90201 and 3.902.6 ofthe ordinance, for the following reasons: . . Land use review and approval of the Marina expansi6nproject canproceedregardless whether the remainder of the resort is implemented simultaneously (seeJIN AC 197-11- 060(3)(b )(i)). . , . Although the Marina expansion projeCt is part of the resort plan, iFisnot an interdependent part of the resort plan and does not depenclon the resort plan as its justification or for its implementation (see WAC 197-:11-060(3)(b)(ii)). . , . Either the sequence of environmentalreviewisfroma nonprojectdocument{the 1993 FEIS for the Port Ludlow Development Plan) to a document of narrower scope "-. a site specific analysis regarding the environmental impacts of the Marina expansion project (see WAC 197 -11-060( 5)( c )(i));or the sequence is from an environmental document 011 a specific proposal at an early stage to a subsequent environmental do~umentat' a' later stage (see WAC . 197-11-060(5)(c)(ii)).' . , ' , The sequence is not from a narrow projectdocumentto abroadpdlicydocument(see WAC 197-11-060(5)(d)(i)). . Phased review would not merely divide a larger systeminto exempted fragments 6t avoid discussion of cumulative impacts (see WAC 197-11~060(5)(d)(ii)). . . Phased review would not segment and aVQidpresentcollsiderationofproposals apdtheir impacts that are requiredbySEPA to be evaluated iuasingle environmental document (see WAC 197..11-060(5)(d)(iii)). LOG ITEM # C(p Page..2 , of ~.'.......... ~: :,...... . Al Scalf, Director of ~om~nity Development Jerry Smith, Project Planner ' Jefferson County Permit Center July 25,2000 Page 4 \..-I . I acknowledge that the ordinance provides that no building permit forthe Marilla expansion project may be issued until completion of a SEISanalyzingthe resort plan. We do not expect to begin construction of the Marina expansion until we have resolved that obstacle to the satis'faction of Jefferson County and the PortLlldlow community. We look forward to working with you on this important project. Thank you for your consideration. Sincerely, nRose, P.E. Vice'President, Property Development . Enclosures ' LOGrrE~ . (1' .,'{/' Paga --!-of-f- . #-I(P,..,~