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State of Washington
DEPARTMENT OF FISH AND WILDLIFE
Region 6 Office: 48 Devonshire .Road - Montesano, Washington 98563-9618 - (360) 249-4628
September 12,2000
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Olympic Property Group
ATTENTION:
19245 Tenth Ave. NW/P.O.Box 1789
Poulsbo, Wa. 98370-0239
JEFFERSON COUNTY
DEPl OF COMMUNITY DEVELOPMENT
Dear Applicant:
SUBJECT: Hydraulic Project Application; Port Ludlow Marina Expansion, Port
Ludlow Bay, Tributary to Admiralty Inlet, Section 16, Township 28 North,
Range 1 East, Jefferson County, WRlA 17.MARI, WDFW Log No.
00E7804.01
The Washington Department ofFish and Wildlife (WDFW) received the above-referenced
Hydraulic Project Application on 28 August 2000, but we are unable to complete processing your
application at this time for the following reason(s):
Written notice of compliance with the State Environmental Policy Act (SEP A),
including exemption or type of determination, date of exemption or final
determination date, and lead agency is required.
Please contact your local planning department for information regarding SEP A
requirements and procedures
The project includes the addition of 100 new slips to the Port Ludlow Marina.
The WDFW is now responsible for managing habitat for federally listed salmonid species,
including Hood Canal summer chum and Puget Sound chinook. The proposed marina expansion
offers significant risk to critical habitat used by both of these species, as well as other salmonids.
Specifically: 1 )Both Hood Canal summer chum and Puget Sound chinook use shorelines of the
subject property as a migratory corridor; 2) Port Ludlow Creek, just west ofthe proposed
expansion, is an important salmonid resource that has showed declines in use over the last 15
years; 3) Sand lance and surf smelt, collectively known as baitfish, and cited by state law as
critical salmonid food resource, are documented to spawn adjacent to the subject property., and
4) Nearshore areas within the existing marina are indicating severe water quality problems,
including anoxia and ulvoid blooms. These impacts will only increase with expansion.
Project impacts to these critical resources and habitats include: 1) Significant increase in
overwater structure from both marina and boats in nearshore areas; 2) Decreased water quality
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Applicant
September 12,2000
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and increased pollution due to both increased boat volumes and decreased flushing from
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additional overwater structure, and; 3) Increased scour in nearshore from increased boat volume
(partictilrti'ly infthe')ft.f~l dock area). These are top priorities for concern, and should be addressed.
WOFW feels potential adverse impacts to finfish resources from this marina expansion should be
thoroughly addressed in the project design before the project is approved.
To summarize: there are two ESA species, and a number of other critical species, that use
tidelands of or immediately adjacent to the subject property. The project, as currently designed,
will negatively affect critical habitat of these species, which the WDFW is mandated to prevent
through both state WAC and federal Endangered Species Act (Section 10 and Section 7).
Specifically, overwater structure from both marina and boats in nearshore areas, disruption of
migratory corridor for fish using Port Ludlow creek and nearshore Port Ludlow Bay, further
degraded water quality and increased pollution from increased boat use and limiting of flushing,
and increased scour in nearshore from increased boat volume (particularly in the fuel dock area)
are top priorities for concern, and should be addressed to eliminate, or otherwise mitigate,
impacts as defined by WAC 220-110-020(41). Specifically, reducing overall overwater structure,
(including decreasing number of slips and dock widths), assessing impact of marina to fish
migration along the nearshore as well as to and from Port Ludlow creek, and decreasing
nearshore fueling activities are suggested areas to start with.
Because your application for HP A is incomplete and has not been accepted for evaluation, it has
been neither approved nor denied. Once a complete application and written notice of compliance
with SEP A have been received by this office, the formal 45-day review period for evaluating
applications for HP A per RCW 75.20.100 or 75.20.103 will commence and your application will
be evaluated for approval. If you have any questions, please contact me at (360) 457-2634.
Sincerely,
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1. Anne Shaffer
Area Marine Habitat Biologist
JAS:jas:00E7804.01
cc: WRIA File, Olympia
CoE (Gossett)
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Applicant
September 12, 2000
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DNR Olympic (Shreck)
NMFS (Longenbach)
Jefferson County (Peters)
DoE shorelines (Stewart)
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