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STATE OF WASHINGTON
DEPARTiV\ENT OF FISHERIES
Post Office Box 43135, Olympia, Washington 98504-3135 . (206) 902-2200 SCAN 902-2200 TDD 902-2207'
May 18, 1993
craig Ward
Jefferson County
Planning and Building Department
Post Office Box 1220
Port Townsend, Washington 98368
SUBJECT: Final Environmental Impact statement - Pope Resources
Proponent - Port Ludlow Inn Development - Port Ludlow, Hood
Canal, Tributary to puget Sound~ section 16, Township 28
North, Range 01 East, Jefferson County, SEPA Log No. 22494,
WRIA 17. MARI
Dear Mr. Ward:
The Washington Department of Fisheries (WDF) has reviewed the above-
referenced Final Environmental Impact statement for the Port Ludlow
Inn Development and offers the following comments at this time.
other comments may be offered as the project progresses.
WDF habitat policy (POL-410), adopted September 1990, states ".
it is the goal of WDF to achieve no net loss of the productive
capacity of the habitat of food fish and shellfish resources of the
state." This policy requires applicants of projects potentially
impacting fish resources and habitat to mitigate all adverse effects.
Applicants must first take all reasonable steps to avoid habitat
damage, and second, take all reasonable steps to minimize any
unavoidable habitat damage. Any habitat which is unavoidably damaged
or lost must be replaced to its full productive capacity using proven
methods.
First, WDF would like to commend Pope Resources on their proposed
usage of sewage pump stations, both portable and stationary, dye
tablets to detect illegal sewage discharge, and education programs
providing help to boaters in need of pumpout services. This type of
program serves as a model for the entire state.
The plans for the pond however, remain a concern to WDF. The opera-
tion and maintenance of this facility requires the use of Hood Canal
marine waters to manage the temperature, thereby controlling the
growth of algae and associated nuisances. There is also some specu-
lation that aeration of the water that spills from the reflecting
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May 18, 1993
pond into the main pond and transplanting eelgrass that would compete
with the ulva will improve water quality in the pond.
The water being returned to Port Ludlow over the weir structure would
have to be the quality of the water being removed from the marine
system through the proposed filtered hydraulic pumps. Improving
water quality through aerating the water in the manner described and
transplanting eelgrass is speculative and would require proven
success before approval could be granted. Of concern also is where
the donor stock for eelgrass would come from. Under no circumstances
will WDF allow salt water pond construction if any of the current
measures of algae control have to be continued.
It remains unclear as to the permeability of the dike to saltwater
once the proposed project is built. Is it not possible to reduce the
seepage of saltwater into the system so that it could be a closed
stable system for freshwater only? WDF would like to reiterate that
a closed system would improve the water quality of Port Ludlow Bay,
could be more efficiently integrated into the stormwater design, and
eliminate any potential problems with unwanted algal formations. The
only salt water option that would be acceptable to WDF at this time
would be a system that is completely open such as the pocket beach
cove as suggested in a prior response.
One final concern WDF continues to have is the proposal for dredging
for the marina expansion. Mitigation for such projects is extremely
difficult to accomplish. Every effort to expand the marina should be
made without the condition for dredging. For instance, the proponent
may want to consider designating certain areas of the boat basin for
"SHALLOW DRAFT VESSELS ONLY".
We appreciate your cooperation in our efforts to protect, perpetuate
and manage the fish resources of the state of Washington.
Thank you for the opportunity to provide these comments. If you have
any questions please call me at (206) 895-4757.
Sincerely,
~.~~'3Q ~"-
John Boettner
Regional Habitat Manager
Habitat Management Division
JB: j b: 20: May: lh
cc: R. Timothy Flint - WDF
Barbara Ritchie - DOE
Tom Luster - DOE
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