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Comments on Pre-Draft Port Ludlow Manna Expansion DSEIS
CONTENT
Somewhere near the beginning of the document (tide page, fact sheet, etc.), mention what
the DSEIS supplements (i.e., the 1993 programmatic EIS).
p.FS-2, Required Permits and Approvals: Add "Development Review Division" after
"Department of Community Development." After "Building Permit," replace "Building
Department" with "Department of Community Development - Building
Permits /Inspections."
Location of Draft SEIS for Review: Are we going to be able to put this document-at least
the text-on the web? If so, we should mention that fact and give the URL here.
Will copies be available free of charge to interested individuals? If so, that should be
mentioned. If not, the price per copy and method for acquiring should be stated.
p.l-l, 1.1: Substitute a descriptive phrase for the word "addressed" in the last sentence of
this section-something like".. .included as a projected aspect of Resort expansion at Port
Ludlow..." The point is that the programmatic EIS discussed or included the 100-slip
expansion, but to say that it "addressed" the 100-slip expansion may be perceived by the
reader that the 1993 document addressed all the environmental impacts associated with the
. .
manna expanSIon.
Figure 1: To where is the arrow associated with the "Port Ludlow" box pointing? It
definitely is not pointing to the Marina. Appears to be pointing to the northern limit of the
Port Ludlow MPR. Needs to be adjusted or forget the arrow and stick with only the box.
p.1-4, third paragraph: Make the first sentence active. Who conducted the expansion study?
Fifth paragraph: "Therefore,] efferson County will issue no building permit. . ." should be
"Therefore,]efferson County will issue no land use or building permit..." Replace ".. .has
been submitted to the County..." with "...is prepared..."
The sixth paragraph, the seven bullet points that follow, and subsection 1.5 on Phased
Review need to be rewritten or deleted. The bullet points appear to be culled from Jon
Rose's letter to DCD included in the original application submitted in the year 2000. There
is no need to repeat those arguments here. The basic reason why DCD is proceeding in the
lead agency role for environmental review under SEP A for the Marina expansion
application, even though the Port Ludlow MPR Ordinance clearly calls for comprehensive
environmental review at one time of all the elements of the Resort expansion projected in
the 1993 programmatic EIS, is to accommodate for the fact that the Marina expansion
element of the overall Resort Plan requires multi-agency review, including Federal nexus
ESA compliance. The other participating agencies in the review of SDPOO-00014 are likely
to be much less involved, if at all, with the other elements of the Resort Plan. Therefore,
Jefferson County is serving in its role as lead agency in order to accommodate the review
timelines of the other agencies for the review of the Marina expansion element of the Resort
Plan, at the explicit request and insistence of the applicant. ] efferson County will not issue
atry permits-shoreline, land use, or building-until the Resort SEIS process is complete.
While phased environmental review is appropriate under particular circumstances as defined
in the RCW and WAC,]efferson County approval ofSDPOO-00014 absent the completion
of the Resort expansion SEIS process is not. If the Port Ludlow MPR Ordinance did not
preclude phased review and approval, it would appear to be appropriate for this case
pursuant to the relevant WAC, as this section of the preliminary DSEIS explains. The
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applicant desired this approach to reviewing the Marina expansion element of the Resort
Plan and convinced the County of its merits. Consequendy, the risks associated with
acquiring approval from State and Federal agencies and later having to acquire approval for a
modified proposal, if] efferson County shoreline approval or an appeal process results in a
modified proposal, reside solely with the applicant. If the applicant desires to present an
argument in the DSEIS for phased review by citing the relevant WAC, the second sentence
of Section 3.902.1 of the Port Ludlow MPR Ordinance should also be citied and explained
in the context of this process: "Environmental review of the Resort Plan shall not be
piecemealed or broken into small segments."
p.l-ll, 1.8: Re-name Significant Areas of Controversy to Significant Issues for
Consideration.
Add "and the potential for hazardous material spills" after the word "discharge" in the third
bullet.
p.l-13, Alt. l/Mit. Meas.: In the text, it is stated that there is a no discharge rule for black
water, but that gray water policy is being left up to DNR. Perhaps the statement in this box
of the table should read, "Enforce the no black water (sewage) discharge rule and provide
better boater education on black and gray water discharge."
p.1-13 & 1-14, Alt. 2/Marine Plants and Animals: "Similar to proposed project." Please edit
this statement, where appropriate, to indicate to the reader that the Deep Water Design will
presumably have less impact on the nearshore environment (i.e., salmonid habitat) than the
other two expansion alternatives.
p.l-17, Alt. l/Pub. Servo and Util./Env. Imp./Sanit. Sewer Serv.: How exacdy is the
anticipated increase in the use of the sewage pump-out facilities "incremental"? Is it because
the 100 additional slips are expected to be filled incrementally (though the applicant
maintains that demand is very high) or because each additional vessel using the Marina only
contributes an insignificant amount of sewage? Is there a better descriptor?
p.2-2, 2.2, second sentence: "For all alternatives..." Later (p.2-S, for example) it is stated
that under the No Action Alternative, the kayak and dinghy floats will not be replaced. If
this is so, the sentence should begin, "For all expansion alternatives. . ."
p.3-8, 3.2.1, Wtr. Qual. and Stormwtr., first paragraph: It seems odd to cite a 1993 source to
buttress the statement that water quality since 1984 remains excellent. What is the reference,
anyway? In the References, there are two Jefferson County documents with the 1993 date:
the programmatic EIS and the Inn at Port Ludlow EIS. Is the reference to one of these?
Why?
Fourth paragraph: Is there a way to include tables and/or charts that summarize the results
of the studies that allow for this conclusion: "No long-term upward or downward trends in
constituent concentrations are evident for any of the monitoring stations"?
p.3-9, first paragraph: Has Port Ludlow Marina considered being proactive in terms of
establishing and enforcing a strong gray water discharge policy (rather than simply wait for
the State)?
p.3-9, third paragraph: ".. . and that live-aboard tenants submit to inspection of their vessels
plumbing and mechanical systems to verify compliance with state and local public health and
safety laws." What is the frequency of these inspections? Who does them( t!(YffEMis
kept at the Marina? ~L.
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Comments on Pre-Draft Port Ludlow Manna Expansion DSEIS
p.3-10, Port Lud. Bay Flush. Char., last sentence of first paragraph: To which of the 1993
] efferson County sources does the reference refer?
p.3-12, Long-Term Effects, Exp. Alt., second paragraph: Absent a policy from the State on
gray water discharge, where is the projection of increases in gray water discharge because of
the additional vessels using the Marina and that analysis of whether those projected increases
will or will not have an impact?
p.3-16, 3.3.2.1, first paragraph: In regard to the last two sentences, it is our understanding
that current WDPW policy is that there is no historical record of a viable population of
Chinook in the Big Quil, but it is likely that Chinook from other Hood Canal rivers would
utilize the project action area for rearing and feeding. Worth checking with them?
p.3-21, Table 1 (hasn't there already been a Table 1? OK, you must mean the first table of
Chapter 3): This table seems incomplete. Are the question marks indicating something other
than the fact that the table is incomplete?
p.3-22, second paragraph: The reader may not know what a "take" is under ESA. Add an
explanatory phrase or sentence, perhaps even a prelude to the paragraph that indicates that
the paragraph contains a summary of the BE findings (which seems to be the case, since it is
filled with ESA terminology). Would be useful to briefly explain what "may affect, but is not
likely to adversely affect" means in terms of findings and Federal review process.
p.3-23, 3.3.2.3: The dock floats will not include any surface with light transmissive
capabilities? Was this not discussed with Anne Shaffer and the Army Corps representative
during the initial pre-application on-site meeting? It may be appropriate to cite observance
of the construction work windows in relation to fish species as a mitigating measure.
p.3-26, 3.3.3.3: See note above regarding light transmissive capabilities of new dock floats.
So the new dock floats will be completely solid? And what length and width? Will the floats
meet WDPW specs?
p.3-29, 3.4.1, last paragraph: Remove "Land Use" from "Comprehensive Plan." Though the
Comp Plan may deal principally (though not exclusively) with land use, there is no document
entided Comprehensive Land Use Plan. Substitute the word "established" for "adopted" in the
last sentence.
p.3-30, Land Use Desig., Zoning, first paragraph: Third sentence should read, "These
development regulations are applied to development proposals within the Port Ludlow
MPR, while the Jefferson County Unified Development Code (UDq contains the
development regulations for the rest of the county.
p.3-34, second paragraph: Is there another source for the industry standard fairway width
besides Tobiasson? Does the Army Corps or DNR have anything to say about navigability
issues related to the fairway width at marinas?
p.3-36, 3.5.1,]eff. Co. Compo Plan: LNG 25.0 was amended by Ordinance No. 08-1224-01.
It now reads: Maintain the viability of Port Ludlow as Jefferson County's only existing
Master Planned Resort (MPR) authorized under RCW 36.70A.362.
Figure 10 Shoreline Environment Designations: The map is missing the Natural designation
for the two inner Bay islands.
p.3-41, first paragraph: "The expansion is consistent with local and state guidelines regarding
marina development." Provide additional information/explanation. What are thct.OG ITEiv1
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guidelines? Can written documents be cited and included in the appendices? Where is the
analysis demonstrating that the guidelines have been met? Who puts out those guidelines,
the Army Corps and WDPW or DNR? "The expanded marina will expand public access to
the water." How? Will all members of the public, including those who are no customers of
the Marina, be able to use the facilities for walking, fishing, etc., or are there restrictions on
members of the public who are not Marina customers? If so, please explain and condition
the preceding statement.
Fourth paragraph: Explain Best Available Science. Cite the applicable WAC or other source.
p.3-42, 3.5.3: The process also requires consistency with the Port Ludlow MPR Ordinance
and other applicable ordinances, such as the Critical Areas Ordinance.
p.3-44, second paragraph: What is the date of the Visual Resource Mgmt. Manual? Is the
citation found in References?
p.3-56, Alt. 2 Deep Wtr. Des., View #1: "This alternative has a strong contrast rating for
View #1." According to Table 5 on p.3-52, Alt. 2 appears to have Moderate, Moderate-
Strong, and Weak-Moderate for the Left, Middle, and Right views, respectively, that
compose View #1. How does a flat "strong" come out of that combination?
p.3-62, summary: Substituting the word "high" for the terms previously explained and
employed (i.e., Weak, Moderate, Strong) may not be the best approach in attempting to
summarize. For example, the results as presented in Table 5 are clearly not identical for
Alternative l/View #2 (Strong) and Alternative 2/View #1 (Weak-Moderate through
Moderate-Strong for the three angles within View #1).
Summary, second paragraph: Substitute "particular" for "proposed" in the second sentence,
so that the reader does not associate the statement with only the Proposed Project.
p.3-72, Parking: Remove reference to the UDC, as it does not apply to PLA projects within
the Port Ludlow MPR. According to Qualified Lead Planner Jerry Smith (see Port Ludlow
MPR Ordinance section 1.50 and Port Ludlow Development Agreement section 4.15), in
certain circumstances when the Port Ludlow MPR Ordinance is silent on a particular zoning
issue, other ordinances that were in effect at the time of adoption of the Port Ludlow MPR
Ordinance that are not silent on the particular issue provide guidance. In this case, the
Jefferson County Zoning Ordinance (as Amended for Implementation of the Jefferson
County Comprehensive Plan by Section 1.60.2 of the Emergency Interim Control
Ordinance) lists in Table 5 on p.55 0.50 spaces per boat slip for marinas, which is equivalent
to the City of Des Moines requirement of 1 space for 2 slips. Use this figure for the
calculations and related text analysis.
p.3-80, 3.8.3.1, third paragraph: Is there a need for additional upland restrooms, showers,
and laundry facilities to serve the 100 additional slips? If not, please state so explicidy and
provide the analysis, according to the Uniform Building Code and other applicable
prOVISIons.
p.3-81, 3.8.4.1, second paragraph: Update this section when the DSEIS is released, as the
release date will likely be in or after May 2002.
p.3-82, paragraph after italicized section: Is it appropriate to add". . . per existing State and
Federal laws" to the end of the sentence ending with". . . Port Ludlow to do so"? Otherwise,
the lay reader may wonder why.
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p.R-3: Replace the X with an 8 for the date of the Comprehensive Plan. Should read,
"Jefferson County, 1998. Comprehensive Plan, as amended."
Appendix A Summary of Scoping Comments: Where is the summary?
Appendix B Draft Geotechnical Report: Why is the report still in draft form? When will it
no longer be a draft-in time for the FSEIS?
Appendix C Port Ludlow Marina policies: Same comment regarding draft status for the
Regulations and Policies
Appendix D BE: Please list the appendices within the BE on the Appendix D tide page to
prevent confusion.
Appendix F Traffic Monitoring Summary Report, p.3: Why the question mark in the right
margin of Table 1?
READABILITY & GRAMMATICAL CONSISTENCY
p.FS-l, Location: Extra period after parentheses ending legal description.
p.l-l, 1.1: Remove comma after "Port Ludlow development" in third sentence.
p.l-l, 1.2, second sentence: When referring to Port Ludlow Bay by only the word "Bay," it
should be capitalized. When referring to the word "bay" in general, it is not. This is not a
major issue, obviously, but capitalization of the word "bay" is inconsistent in the document.
Pick one style and stick with it.
Add a period after the parentheses ending with W.M., or conversely, add the period to the
end ofInlet. In either case, make the phrasing/punctuation identical for the legal
descriptions on p.FS-l and p.l-l.
p.l-l, 1.3. "The objectives for the Port Ludlow. . ." should be "The objectives of the Port
Ludlow. . ."
Add the word "the" between "of" and "Port" in the third bullet.
Remove the capital letters in "Development Regulations" in the last bullet. The
capitalization may confuse the reader, as there is no document with that tide.
p.l-l, 1.4: When referring to the Port Ludlow Marina as just "the marina," the M should be
capitalized (similar to referring to Port Ludlow Bay as the Bay). When referring to marinas
in general, the m is not capitalized (e.g., p.l-5, 1.6, third sentence under Alternative 1:
Proposed Project). Again, this is a minor issue, but use of the word marina as a stand-alone
term to identify the Port Ludlow Marina is inconsistent throughout the document, as it is
sometimes capitalized and sometimes not. Choose a style and stick with it.
p.l-l, 1.8: First sentence: has ESA been spelled out yet? If not, spell it out the first time.
(ESA is spelled out in the second bullet.) It would be very helpful to have in the
appendix or elsewhere a list of acronyms used in the document, as well as a glossary
of technical terms and abbreviations.
Remove the comma between "salmon" and "and" in the parenthetical phrase in the second
bullet.
p.1-12, 1.9 table, Earth/Alt. l/Mit. Meas.: Spell out BMPs the first time it's used.
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Alt. 4 column: End phrases with periods (or don't, but be consistent throughout the table).
See also Alt. 1 and Alt. 4 columns on p.l-13, etc.
p.1-13, Alt. l/Marine Plants and Animals/Env. Impacts/Marine Veg.: "Benthic" is one of
the terms that should be in the glossary of technical terms, abbreviations, and
acronyms.
p.l-l5, Alt. 3/ Aesth'/Vis. Qual./Env. Imp.: The word "Moderate" in the statement
regarding Oak Bay Road should be followed by the closing quotation mark.
Alt. l/Trans./Env. Imp.: LOS should be spelled out the first time it's used (and included in
the glossary).
p.2-1, 2.1.4, second paragraph, first sentence: Spell out MLLW the first time it's used.
p.2-3, second paragraph: Square feet is used, as well as sq. ft. and later in the document fe
(e.g., p.3-11). See also inconsistency in fourth paragraph. Suggestion: use "square feet" the
first time with "(sq. ft.)" direcdy after, then use "sq. ft." from then on.
p.3-1, 3.1.1, Topography, third paragraph: Spell out MSL the first time it's used; include in
glossary of terms.
Fifth paragraph: Should it read "0" instead of "-O"?
p.3-5, Sed. Qual., last sentence: Position period inside closing quotation mark.
3.1.2, Short-Term Imp., third paragraph: Remove comma after parenthetical expression
ending in "moment arm" and after "-40 feet of water" in the next sentence. Eliminate
spaces between "70," "-," and "80," so that "70-80" is expressed in the same format as "100-
130" on the next page.
p.3-8, 3.2.1, Wtr. Qual. and Stormwtr., fourth paragraph: Add a comma after "e.g."
p.3-9, second paragraph: "mL" is used here and "ml" used in later sections (e.g., p.3-11).
Pick one style.
p.3-9, third paragraph: "... and that live-aboard tenants submit to inspection of their vessels
plumbing and mechanical systems..." Make the word "vessels" possessive (i.e., "vessels'
plumbing and mechanical systems").
p.3-10, first paragraph: Remove the additional closing parentheses and comma after
"(PSWAQ and DNR 1992),"
Port Lud. Bay Flush. Char., second sentence on second paragraph: Verb conjugation should
be "averages" and "varies." (Subject noun = "volume.")
p.3-11: Spell out NTU first time and place in glossary.
p.3-14, 3.3, second paragraph: Add "was" between "(2001)" and "prepared" in the first
sentence.
Project Area, first paragraph: Add an "s" to the letter "a" between "mollusks such" and
"geoduck" in the third sentence.
p.3-l5, third paragraph: The acronym "DFW" was used previously (p.3-14) to indicate
WDFW. Pick one and stick with it.
3.3.1.2, first paragraph: The phrase "where eelgrass and other macrophytes would most likely
occur" presumably is intended to describe the character of areas in water stt.f~e1f~lVf)
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Comments on Pre-Draft Port Ludlow Manna Expansion DSEIS
than -20 ft. MLLW. The construction of this sentence, however, leaves the lay reader
confused. Re-phrase such that the intention is clear.
p.3-18, Bull Trout, first paragraph: Remove extra period after "(WDFW 1998b)."
Third paragraph, Critical Habitat: Has USFWS been spelled out yet? Add to glossary.
Bald Eagles: Include the closing parentheses after "(Rodrick and Milner 1991)."
p.3-20, second paragraph: ".. .locally elevated turbidity. . ." instead?
p.3-23, top of page: Has BE been defined and explained? Include in glossary.
3.3.2.3: Add period to end of sentence.
p.3-25, fourth paragraph: Spell out "ft-c" first time and include in glossary.
p.3-30, Project Area, last paragraph: Re-phrase the last sentence. It is unclear what "as well
as rafting and anchoring" is intended to modify. Uses?
Land Use Des., Jeff. Co. Compo Plan: If you're looking for the exact tide, it's the Jefferson
County Comprehensive Plan: Jefferson County, Washington.
Zoning, first paragraph: Add the closing quotation mark to "MPR Development
Regulations."
p.3-31, 3.4.2, second paragraph: Spell out or otherwise explain Leq. Add to glossary.
Third paragraph: Add "is" between "it" and "anticipated" in the third sentence.
p.3-41, third paragraph: DFW or WDFW? USFW or USFWS?
Alt. 4: No Action, SMP: Use either SMMP or SMP as the consistent acronym. Does not
matter which one, though the 1989 document is entided, the Shoreline Management Master
Program = SMMP.
p.3-43, 3.6, first paragraph: Add comma after "Reid Middleton."
p.3-45, second paragraph, last sentence: Does "And" have to be capitalized in "Visual
Interest And Sense and Utility Ratings"?
p.3-56, Alt. 1: Beginning on this page, the figures that demonstrate the actual and simulated
views for the various alternatives are cited in the text using labels such as figure Al, Figure
V#3, and Figure A2V2. Please use a consistent approach for this section that begins with
the actual figure number (i.e., Figure 14A).
p.3-71, Level of Serv., first paragraph: Replace the second sentence with this: "Traditionally,
the LOS ratings for roadways have been based on an A through F quantitative scale
measuring roadway capacity, as defined in the Highway Capacity Manual." (What Highway
Capacity Manual? Has the Manual been cited previously and does it appear in References?)
Second paragraph: PM is used here, while p.m. has been used elsewhere. Pick one style.
p.3-73, fourth paragraph: There is an unnecessary space between "0" and "f" in the word
"of" between "north" and "Areas B and C."
p.3-77, 3.8.1.1, first paragraph: Substitute a colon for the comma after "fire stations" in the
second sentence. Remove the comma between "May" and "2002" later in the paragraph.
p.R-l, References: The References appear in varying fonts. Please adjust. Why do Jefferson
County and Pentec documents appear at the end of the list and not in alphabetical order? EM
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