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Home My WebLink AboutLog078 e e - November 15, 2001 File No. 24-99-014-001-01 Subject: Port Ludlow Marina Expansion SEIS Engineers Planners Surveyors Josh Peters Shoreline Administrator Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 Dear Josh, Attached is a Draft Scoping document and Schedule for the Port Ludlow Marina Expansion Draft Supplemental Environmental Impact Statement (SEIS). The initial scope prepared by Jefferson County for the purposes of the Scoping Meeting on October 12, 2001, identified six elements of the environment for review. These elements are: Earth, Water, Plants and Animals, Land and Shoreline Use, Transportation, and Public Services. The initial Scoping Document is based upon the Port Ludlow Master Planned Resort (MPR) Development Regulations, Jefferson County Ordinance No, 08-1004-99, Section 3.904 (2). However, the elements of the environment included in the Scoping Document are only those elements pertinent to the marina expansion (i.e., does not include historic preservation, traffic congestion, pedestrian hazards, etc.). As a result of the comments received from the Scoping Meeting, an additional element has been added: Aesthetics (view impacts, light and glare), The issue has been raised about whether Port Ludlow Associates intends to prepare one or two SEIS's for the Port Ludlow Resort. According to Section 3.902, "a project level SEIS analyzing the resort plan is required prior to issuance of building permits for any new resort development." On July 25, 2000, Olympic Property Group (OPG) submitted the initial application for a Shoreline Substantial Development Permit Application with Jefferson County for the expansion of the Port Ludlow Marina. This project does not include any upland development. Washington Oregon Alaska In a cover letter dated July 25, 2000, to Al Scalf and Jerry Smith, Jon Rose, Vice President for Property Development for OPG, clarified the SEP A requirements for the Port Ludlow Resort. (See letter enclosed.) In this letter, Mr. Rose acknowledged the language of Section 3.902. However, he stated that his understanding is that he may obtain land use approvals relating to the Marina expansion project based on environmental review of the impacts of that project. No building permit would be Reid Middleton, Inc. 728 134th Street SW Suite 200 Everett, WA 98204 LOG ITEM : !. -,.y. ,~ / D 'j0_L-of4 Ph: 425741-3800 Fax: 425741-3900 Josh Peters Jefferson County Department of community Development November 15, 2001 File No. 24-99-014-001-01 Page 2 e e issued for the Marina until OPG completed the SEP A review required for the entire resort plan. This understanding of the SEP A process, a 2-step approach, has been the basis for going forward with the proposed Port Ludlow Marina expansion. When Port Ludlow Associates purchased the Port Ludlow property from OPG, it continued on with the Marina expansion work commenced by OPG in 1999. It has been the understanding of Port Ludlow Associates that the issues identified in the July 25, 2000, letter still apply. This process was also discussed and agreed to during a meeting between Al Scalf and Greg McCarry, President of Port Ludlow Associates on November 7,2001. Therefore, we continue to pursue the permitting of the Marina Expansion as a stand alone SEIS, There is no change in the overall program from that initiated by OPG and continuing now with Port Ludlow Associates. The Marina expansion continues and plans are in preliminary stages for redevelopment of the Port Ludlow Resort. Port Ludlow Associates intends to comply with the requirements for preparing a Resort SEIS prior to Jefferson County issuing a building permit for the Marina Expansion. However, at this time, Port Ludlow Associates will continue to proceed with preparation of the SEIS for the Marina based upon the Scope and Schedule enclosed with this letter. Please give me a call to discuss this further if you have any questions, Yours truly, Reid Middleton ~1:~ Nicole Faghin () Director of Planning and Environmental Services sjs\24wf\99\014Pt.Ludlow\PLA W ork\SEP A\DEIS\Scoping\Nov.14cov.1tr.doc Enclosures cc: Mark Dorsey, Port Ludlow Associates Al Scalf, Community Development Director, Jefferson County LOG ITEM . i j<g' i-'age :>- of If ~ . '. OS-Ph200cr" 08:44 .. " __olio FRO~O,R,t.4, INC, e ()h';;r)h., >O>,_,l\ . "'.,. , .1', )lIP' .... I 1'( 360-697-1156 T-6QO ?002/00S F-494 e . A p.,. J",.",..n C..,.., July 25, 2000 AI Scalf, Director of Community Development Jefferson Counry Pennit Center 621 Shmdan Street Pon Townsend. W A 98368 Jerry Smith, Project Plan,nec Jefferson Counry Permit Center 621 Sheridan Street Pon Townsend, W A 98368 SubjeCt: Shoreline Substantial Development Permit Application Pon Ludlow Marina Expansion Project Dear AI and Jerry, On behalf of Olympic Property Group, I am pleased to submit an application for expansion of the Port Ludlow Marina. Project Description Pon Ludlow Marina has 280 existing slips plus areas for approximately 40 additional boat sideties. The application proposes expansion of the Marina by adding 100 new slips. An existing dock for kayak rentals and storage will be upgraded. In additio~ 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 impacts on the marine habitat. Olympic Property Group COPG) has been planning and evaluating a marina expansion for the Pon Ludlow Marina for over ten years. The IOO-slip expansion was evaluated and discussed in a 1993 EIS and numerous public and regulatory meetings. The fmal proposed layout for the expanded Marina encompasses the many public and regulatory comments and environmental reviews that have occurred over the past ten years. 19H~ T<:nrn A;-cn,,\; SOCUlc..sr, P.O. Bo,IC 1780, Po..lsbo, W~y,;ngton 98370-0239 (360)697.6616. S~~ttk (ZOtl) 192-0517, F~'(: (360) 69i.1l56 LOG ITEM ff ~ PtJ{1e 3 OflPJ_- o . 08~a?-2CJO, 08:44 FROM-O,R,M, INC,~ Al Sc.alf, Director of Community Development Jerry Smith,Projtct Planner Jefferson County Permit Center July 25, 2000 . Page 2 380-897-1158 e T-800 P.003/009 F-484 Submission Materials We have prepared the following documents relating to our application for a shoreline substantial development penn it for the expansion of the Port Ludlow Marina: 1. Signed J.~ A application 2, Orawing SheetS 1 to 4 3. SEPA Environmental Checklist 4. Biological Evaluation prepared by Penrec Environmental 5. Letter regarding results of the Sonar Survey demonstrating no vegetation in the project vicioi~ . 6. Memorandwn regarding Public CommentSlPublic Involvement 7. Memorandum regarding Parking Management Plan 8. Memorandum regarding Public Access SEPA Issues In February 1999, the Port Ludlow Marina had vacant slips. Today, it has a waiting list of more than 180 boat o\\ners. Last year there was no need to move the Marina expansion project forward. Today. the Porr 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 ofFish and Wildlife, and the U.S.-Army Corps of Engineers. I am writing this letter mainly to descnoe my understanding, based on our recent discussions, of Jefferson County's requirements for environmental review of this project under the State Environmental Policy Act. Firs~ with respect to your threshold determination under SEPA, 1 understand that you are likely to issue a dctennination of significance and require the completion of a Supplemental Environmental Impact Statement prior to making any substantive decision regarding this project. The SEIS would supplement the fmal environmental impact statement for the Port Ludlow Development Program dated April 12, 1993, and other environmental documents relating to the impacts of me Marina expansion project. The SEIS may be comprised of existing environmental documentS, but may also include additional reports or StUdies. Second, with respect to the scope of environmental review under SEP A. I understand that the scope of me SEIS will be limited to the environmental impacts of me Marina expansion project. [understand that under Section 3.902.1 of Ordinance No. 08-1004-99, a project level SElS "analyzing the reson plan is required prior to issuance of building permits for any new resort development." Section 3.902.6 similarly provides, ..^~U1al resoll development may be undertaken in phases, but only following completion of review and approval of a full resort . LOG ITEM 1~ft ~'7? Jpge 4 of-Dp- 08-Q?-2000 08:45 FROM-O.IU4.IMC, " ., e A! Scalf. Director of Community Development Jerry Smith, Project Planner Jefferson County Permit Center .J.uly 25, 2000 Page 3 360-697-1156 e T-600 P.Q04/009 F-484 buiIdout plan through the SEIS process'" I understand. based on these subsections oftbe ordinance, that you will nor issue a buildini permit for (and we may nor besin congtrncrion of) the Marina expan~ion project unless and tmtit \ye comply with these t"eQ.JJirements as wTitten Qr am~de4. In other words. although we may obtain land use approvals relating to the Marina expansion project based on environmental review of the impactS of that project, we may not obtain a building permit to begin construction of that project until we comply with these subsections of the ordinance. We do not propose to obtain building permits or begin actual resort development of any portion of the resort plan, including the Marina expansion project, until we have complied with these subsections. I acknowledge that Section 3.902 of the ordinance also provides. "Environmental review of the Resort Plan shall not be pieccmealcd or broken into sniaII segments_" I t'ecognize that . piecemealing is not allowed under SEPA. but phased review is allowed when certain criteria are met. Phased review of'land use approvals relating to the Marina expansion project is appropriate under SEPA., even thouih ph~d review of building permit approvals reJaring to any resort development mav not be a~propriate under Sections ~t902,l and 3,902.6 of the ordinance. for the following reasons: · Land use review and approval of the Marina expansion project can proceed regardless whether the remainder of the reson is implemented simultaneously (~ WAC 197-11- 060(3)(b)(i)). ' · Although the Marina expansion project is pan of the reson plan. it is not an interde.pendenr part of the reson plan and does not depend on the resort plan as its justification or for its implementation (~WAC 197-11-060(3)(b)(ii)). · Either the sequence of environmental review is from a nonproject document (the 1993 FEIS for the Pon Ludlow Development Plan) to a document of narrower scope - a site specific analysis regarding the environmental impacts of the Marina expansion project (sa: WAC 197-11-060(5)(c)(i)); or the sequence is from an environmental document on a specific proposal at an early stage to a subsequent environmental document at a later stage (sc WAC 197-11-060(5)(c)(ii)). . The sequence is not from a narrow project document to a broad policy document ~ WAC 197-11-060(5)(d)(i)). · Phased review would not merely divide a larger system into exempted fragments or avoid discussion of cumulative impacts <s= WAC 197-11-060(S)(d)(ii)}. · Phased review would not segment and avoid present consideration of proposals and their impactS that are required by SEP A to be evaluated in a single environmental document (~ \V AC 197-1l-060(S)(d)(iii)). LOG ITEM # --rz Pnpe .> Of1- . , L ,09,-~~-ZOOJ 08:46 FROM-O,R,M, INC. Al Scalf. Director of Community Development Jerry' Smith. Project Planner Jefferson County Permit Center July 25. 2000 Page 4 360-697-1156 e T-600 P.005/009 F-484 I acknowledge that the ordinance provides that no building pennit for the Marina expansion project may be issued until completion of a SElS analyzing the reson plan. We do not ex.pect to begin constrUction of the Marina expansion until we have resolved that obstaCle to the satisfactiou of Jefferson County and the Pon Ludlow community. We look fotward to working with you on this important project. Thank you for your consideration. Sincerely, Olympic 1 n Rose. P.E. Vice" President, Property Development Enclosures " LOG ITEM 1/ ?:l Pnge (p Of-..q._ I . Port Ludlow Marina Expansion Supplemental Draft Environmental Impact Statement (SDEIS) Scoping Summary Application: SDPOO-OOOI4, Shoreline Primary Use Substantial Development Permit Applicant: Port Ludlow Associates LLC. Determination of Significance: Jefferson County issued a Determination of Significance for the above project on September 28,2001. Notice of the Determination of Significance and Scoping was published in the Port Townsend & Jefferson County Leader on October 3,2001. This SEIS will supplement the 1993 "Port Ludlow Development Program EIS", That document examined the potential cumulative environmental impacts of the entire Port Ludlow Development Program, including a proposed 1 OO-slip expansion of the Port Ludlow Marina. Pursuant to Section 3,904(1) of the MPR Code, detailed environmental review for future resort development shall take the form of a project-level SEIS that supplements the 1993 EIS. Scoping Summary: The scoping period for the Port Ludlow Marina Expansion SDEIS extended from October 3,2001 to November 2,2001. Five comment letters were received. In addition, earlier comments received from the State of Washington Department of Fish and Wildlife and the Department of Ecology were considered, A public scoping meeting was held on October 12,2001 at the Bay Club in Port Ludlow. The meeting was directed by Josh Peters, representing the Jefferson Co. Department of Community Development. Representatives of the applicant (Port Ludlow Associates) and the EIS consultant (Reid Middleton) were present. Twelve area residents and a representative of the Washington Department of Natural Resources (DNR) attended the meeting. Summary minutes of the scoping meeting are on file with Jefferson Co. Scope of Port Ludlow Marina Expansion SDEIS: Based on comments received during this scoping process, Jefferson County has identified the following elements of the environment for discussion in the SDEIS: Elements A. Earth - Potential for bank erosion, scour, and dredging B. Surface Water - Water quality impacts to Port Ludlow Bay from the proposed expansion/use and related stormwater runoff, C. Plants and Animals - Identification of marine habitat and species (especially Threatened and Endangered species) and impacts to the habitat and marine species. LOG \TEM it n ~J- -~-> ppge -J Of1.If I . , .. e e D. Land and Shoreline Use - Relationship to existing land use plans and population, consistency with existing MPR Code, impacts to adjacent land uses (noise, odors, access to docks). E. Aesthetics - View impacts, light and glare F. Transportation - Potential new trip generation and parking demands G. Public Services -Increased demand for fire protection/emergency medical services and sanitary sewage disposal, Alternatives The following alternatives will be addressed in the SDEIS: Alternative 1- Proposed Project (100 slip expansion per 2001 application) Alternative 2 - 1993 (Alternate) Design for 100 slip expansion Alternative 3 - No Action (No Expansion of the Marina) Discussion of impacts will include both short-term construction impacts and long-term (operational) impacts. Any known cumulative impacts will also be addressed. Note: No building permit for marina expansion will be issued by Jefferson County until completion of an EIS or SEIS for the entire Port Ludlow Master Planned Resort expansion project. That document must address the cumulative impacts of both the resort and marina expanSIOn. \\RMI\ VOL2\DOC\24Wt\99\0 l4Portludlow\PLA WORK\SEP A \DEIS\Scoping\Scopdoc,doc LOG HEM - "fl: $f P0~e_ 6 of_- e e Port Ludlow Marina Expansion SEIS Draft Schedule Pre-Draft DSEIS Submit Pre-Draft DSEIS to PLA- Submit Pre-Draft DSEIS to Jefferson Co. - County review of Pre-Draft - Revisions to Pre-draft SEIS - Draft SEIS Circulate Draft SEIS - Final SEIS Submit pre-draft FEIS to PLA - Submit pre-draft FEIS to Jefferson Co. - Issue FEIS December 18,2001 January 7, 2002 January 7 - 28, 2002 January 28 - February 8, 2002 February 12 - March 14,2002 April 8, 2002 April 15,2002 May 6, 2002 Shoreline Substantial Development Permit - (Administrative Decision) May 20, 2002 November 14,2001 H:\D0C\24Wt\99\0 l4Portludlow\PLA WORK\SEP A \DEIS\Schedule\Draftsched.doc LOG rrElvl .J -n ;)2ge~of-'P-