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Home My WebLink AboutLog150 I I I I I I I I I I I I I I I I I I I Port Ludlow Marina Expansion DRA1=-T Final Supplemental Environmental Impact Statement Jefferson County Department of Community Development October 23, 2002 '-1 ,~_." 1 ' I'" i, I t ......... ~ ~ ..."...J~ Q.,,~.",_,_~_. I I I I I I I I I I I I I I I I I I I Copies Distributed: Applicant Port Ludlow Associates LLC Mark R. Dorsey, P.K 70 Breaker Lane Port Ludlow, W A 98365 Jefferson County Departments Jefferson County Public Works 621 Sheridan Street Port Townsend, W A 98368 Jefferson County Natural Resources 615 Sheridan Street Port Townsend, WA 98368 Federal Government Agencies US Army Corps of Engineers Seattle Regulatory Branch Attn: Susan Glenn 4735 East Marginal Way South Seattle, W A 98124 National Marine Fisheries Service Attn: Shandra O'Haleck . 510 Desmond Drive SE Suite 102 Lacey, W A 98503 U.S. Fish and Wildlife Service Attn: Lou Ellyn Jones 510 Desmond Drive SE Suite 102 Lacey, W A 98503 State of Washington Agencies Department of Ecology SEP A Review PO Box 47703 Olympia, W A 98504-7703 Department of Ecology Shore lands SW Region Jeffree Stewart 300 Desmond Drive Lacey, W A 98503 DISTRIBUTION LIST Department of Natural Resources SEP A Review Dave Deitzman 1111 Washington Street SE Olympia, W A 98504-3135 Department of Natural Resources Jeff Schreck 411 Tillicum Lane Forks, W A 98331 Department ofFish & Wildlife SEP A Review 1111 Washington Street SE Olympia, W A 98504-3135 Department of Fish & Wildlife Anne Shaffer 332 East 5th Street Port Angeles, W A 98362 Tribal Government Port Gamble S'Klallam Tribe 31974 Little Boston Road Kingston, W A 98346 Jamestown S'Klallam Tribe 1033 Old Blyn Highway Sequim, W A 98382 Port Ludlow Roster LMC Governmental Affairs Com Richard Smith PO Box 65060 Port Ludlow, W A 98365 Port Ludlow Village Council PO Box 65012 Port Ludlow, W A 98365 (2 Copies) Local Organizations Port of Port Townsend 333 Benedict Street Port Townsend, WA 98368 Port Ludlow Marina Expansion final SEIS DRAFT DL-l October 2002 --- Port Ludlow Marina Expansion Draft SEIS DL-2 July 2002 --- I I I I I I I I I I I I I I I I I I I Local Organizations (Continued) Olympic Environmental Council PO Box 1906 Port Townsend, W A 98368 Rae Belkin Mats Mats Area Coalition 900 Olympus Blvd Port Ludlow, W A 98365 The Bay Club at Port Ludlow 120 Spinaker Place Port Ludlow, W A 98365 Bert Loomis Loomis Properties 9500 Oak Bay Road Port Ludlow, W A 98365 Port Ludlow Beach Club 121 Marine Drive Port Ludlow, W A 98365 Paul Taylor Smith Nancy Taylor Smith 63 Scott Court Port Ludlow, W A 98365 Port Hadlock Branch, Jefferson County Public Library Port Hadlock, W A 98339 Notice of Availability: Sally Smith PO Box 65435 Port Ludlow, W A 98365 Grant Colby Lori Colby PMB 526, 2442 NW Market Street Seattle, W A 98107-4137 D. A. & Sandy Routt 87 Scott Court Port Ludlow, W A 98365 William G. Funke Diggie Funke 75 Scott Court Port Ludlow, W A 98365 Peter A. Joseph Jeanne M. Joseph 6 Heron Road Port Ludlow, W A 98365-9300 Wendi Wrinkle 172 Hubbard Creek Port Ludlow, W A 98365 Fred P. Delmissier Darlene J. Delmissier 9514 NE 13th Street Bellevue, W A 98004-3445 Ruth Altis 2408 State Avenue NE Olympia, W A 98506 Donald S. Clark Anita J. Clark 8915 SE 56th Street Mercer Island, W A 98040 Roger Larson 142 Resolute Lane Port Ludlow, W A 98365 Larry Lawson 10140 Oak Bay Road Port Ludlow, WA 98365 Janet L. Kennedy 26 Heron Road Port Ludlow, W A 98365-9300 Jack Morris Alice Morris PO Box 650 Maple Valley, WA 98038 McCarry Family Trust 2 Heron Road Port Ludlow, W A 98365 Alton K. Lanterman 221 First Avenue W, Suite 108 Seattle, W A 98194 I I Timothy J. Howard Utilities and Services Kazuko M. Howard Jefferson County Fire District 3 I 13129 Muir Drive NW 7650 Oak Bay Road Gig Harbor, W A 98332-8897 Port Ludlow, W A 98365 I George C. Hill, Trustee Olympic Water and Sewer Company Barbara F. Hill, Trustee 70 Breaker Lane G&B Hill Trust 8-18-75 Port Ludlow, W A 98365 22 Heron Road I Port Ludlow, W A 98365-9300 News Media Port Townsend Leader Bernie J. Brown Copy Editor - Hearing I 20730 Bond Road NE PO Box 552 Poulsbo, W A 98370 Port Townsend, W A 98368 I William O. Master, Jr. Peninsula Daily News Judith L. Master 922 Washington Street 10 Heron Road Port Townsend, W A 98368 I Port Ludlow, W A 98365-9300 Colleen J. Ferris I 1619 Windermere Drive E Seattle, WA 98112-3737 Burke F. Gibson I Dolores Gibson 89 Cascade Ky Bellevue, W A 98006-1023 I Bill Clark 10 Trader Lane I Port Ludlow, W A 98365 Vince Pace I 211 Greenview Lane Port Ludlow, W A 98365 I Herman Voss 60A Fairway Lane Port Ludlow, W A 98365 I Clark Ruggles 125 Seaway Place Port Ludlow, W A 98365 I Dennis Madson 93 Driftwood Court I Port Ludlow, W A 98365 I I Port Ludlow Marina Expansion July 2002 Draft SEIS DL-3 --- I I I I I I I I I I I I I I I I I I I FACT SHEET Proposed Action: The proposed action is the addition of 100 slips (plus additional side ties) and associated electrical and utility improvements to the existing 280-slip Port Ludlow Marina. The existing kayak and dinghy floats will also be replaced. The Port Ludlow Marina, built in the late 1960s and early 1970s as part of the Port Ludlow development, provides moorage for residents of Port Ludlow and transient moorage service to guests. This Port Ludlow Marina Expansion Final Supplemental Environmental Impact Statement supplements the 1993 Programmatic Environmental Impact Statement for the Port Ludlow Development Program. Location: Port Ludlow Marina is located in Port Ludlow Bay, Jefferson County, Washington. Port Ludlow Bay is located on the west shore of Admiralty Inlet at the mouth of Hood Canal (Section 16, Township 28 North, Range 01 East, W.M.). The location of the project is shown in Figures 1 and 2. Lead Agency: Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 Project Proponent: Port Ludlow Associates 70 Breaker Lane Port Ludlow, W A 98365 Responsible Official: Al Scalf, Director, Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 Contact Person: Josh Peters, Associate Planner, Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 Jefferson County File No.: SDPOO-00014, Shoreline Primary Use Substantial Development Permit Port Ludlow Marina Expansion final SEIS Odober 2002 --- DRAFT fS-l Authors and Principal Contributors: This Final Supplemental Environmental Impact Statement (Final SEIS) has been prepared under the direction of the Jefferson County Department of Community Development. Research and analysis was provided by: Reid Middleton, Inc. Document Preparation and Engineering 728 134th Street SW, Suite 200 Everett, W A 98204 (425) 741-3800 Pentec Environmental, Inc. Analysis of the Marine Environment 120 Third Avenue South, Suite 110 Edmonds, W A 98020 (425) 775-4682 Required Permits and Approvals: Jefferson County · Shoreline Primary Use Substantial Development Permit - Department of Community Development - Development Review Division · Building Permit - Department of Community Development - Building Permits/Inspections. State of Washington · 401 Water Quality Certification - Department of Ecology · Coastal Zone Management Consistency Determination · Hydraulic Project Approval- Department ofFish and Wildlife FederalC;overnrnent · U.S. Army Corps of Engineers Section 10 Permit - Docks and Pilings Date of Issue of Final SEIS: October 2002 Location of Final SEIS for Review: Copies of this Final SEIS are available at the following locations for review: Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 The Bay Club At Port Ludlow 120 Spinaker Place Port Ludlow, W A 98365 Port Ludlow Beach Club 121 Marine Drive Port Ludlow, W A 98365 Port Ludlow Marina Expansion final sEls DRAFT fs-2 October 2002 --- I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Port Hadlock Branch, Jefferson County Public Library Port Hadlock, W A 98339 Technical reports, background data, and other relevant information are available at the Jefferson County Department of Community Development. Electronic copies of this FSEIS are available to download and print at the Jefferson County website. The URL for this site is http://wvvw.co.iefferson.wa.us/commdevelopment Copies of this FSEIS are also available for sale for Community Development. Port Ludlow Marina Expansion final sEls DRAFT fs-3 at the Jefferson County Department of October 2002 --- I I I I I I I I I I I I I I I I I I I Chapter 1 - Summary 1.1 Proposed Action The proposed action is the addition of 100 slips (plus additional side ties) and associated electrical and utility improvements to the existing 280-slip Port Ludlow Marina. The existing kayak float will also be replaced and enlarged, and the existing dinghy float will be replaced with three smaller floats. The Port Ludlow Marina was built in the late 1960s and early 1970s as part of the 1,200-acre Port Ludlow development and provides moorage for residents of Port Ludlow, residents of other area boating groups, and transient moorage service to guests. The 100-slip expansion was included as a projected aspect of the Port Ludlow development in the 1993 programmatic EIS, Port Ludlow Development Program EIS. 1.2 Location of the Proposal Port Ludlow Marina is located in Port Ludlow Bay, Jefferson County, Washington. Port Ludlow Bay is located on the west shore of Admiralty Inlet at the mouth of Hood Canal. The Bay is a 2.2 square mile, J-shaped tidal basin, which extends from the mouth of Ludlow Creek 3.5 miles to Admiralty Inlet (Section 16, Township 28 North, Range 01 East, W.M.). The location of the project is shown in Figures 1 and 2. 1.3 PurposejObiectives of the Proposal The objectives of the Port Ludlow Marina expansion are: · To accommodate the increasing market demand for boat slips. · To respond to market trends for an increased diversity of berth sizes. · To sustain the growth of the Port Ludlow community. · To improve customer satisfaction with the condition of the facility. · To upgrade and enhance services and amenities provided on moorage docks. · To minimize potential environmental impacts. · To comply with Jefferson County development regulations. 1.4 Proiect History The Port Ludlow Marina was developed by Pope and Talbot in the late 1960s and early 1970s as part of the Resort at Ludlow Bay development. It was expanded in the late 1970s and has undergone subsequent minor modifications. The Marina serves guests, boating groups, and Port Ludlow area residents. Visitors to the Resort at Ludlow Bay and Heron Beach Inn also utilize the facilities. Port Ludlow Marina Expansion final sEls October 2002 --- DRAFT 1-1 TI Reid iddleton VICINITY MAP Figure 1 Port Ludlow Marina Expansion FSEIS i:\ \24 \99\014 \permit\eis\DEISreport\.;icinity.dwg I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I ~ NORTH N.T.S. I I I I ) -_J- I I I I I .J L.EcSoe~ - - - - I"ORT L.UClL.OIl'l MASTER I"LAN GOMMUNI'T'l" 6OlJNI:)AR"l" Reid iddleton LOCA TION MAP Figure 2 PORT LUDLOW MARINA EXPANSION FSEIS i:\ \24\99\014\permit\eis\4914Iocation The Marina was transferred to Pope Resources (along with other real properties in Port Ludlow) in 1985 and was managed by a Pope Resources subsidiary company, Olympic Real Estate Management, Inc. until August 2001. The Marina is currently owned and managed by Port Ludlow Associates. Property below Ordinary High Water (OHW) is leased from the Washington Department of Natural Resources (DNR). Peratrovich, Nottingham, and Drage conducted a marina expansion study in 1992. In 1993, the resort area and surrounding residential development underwent a permitting process for redevelopment. The redevelopment included the addition ofthe 36-room Heron Beach Inn, 53 residential townhomes, 5 single- family lots, an 800 square foot marina building, and a 100-slip expansion of the Port Ludlow Marina. Two EIS documents were prepared. The programmatic EIS for the Port Ludlow Development Program included the 100-slip expansion for the Marina together with the proposed buildout of the residential and commercial components of a Port Ludlow master plan. The project EIS for the Inn at Port Ludlow included impacts from the expansion for the upland Marina facilities (office, etc.) as described above. In August of 1998, Jefferson County adopted a new comprehensive land use plan that designated the Port Ludlow community as a Master Planned Resort (MPR). Subsequent to the adoption of the Comprehensive Plan, Jefferson County adopted Development Regulations for Port Ludlow Master Planned Resort under Ordinance Number 08-1004-99. The adoption date for the Code was October 1999. Under Section 3.902.1 of Ordinance No. 08-1004-99, a project level SEIS "analyzing the resort plan is required prior to issuance of building permits for any new resort development." Section 3.902.6 similarly provides, "Actual resort development may be undertaken in phases, but only following completion of review and approval of a full resort buildout plan through the SEIS process." A key element of the SEIS is to compare the change in cumulative development impact between the permitted plan of Ludlow Bay Village to proposed changes for any new resort components. Jefferson County will issue a land use or building permit for the Marina expansion only after a project level SEIS for the Resort at Ludlow Bay is complete. That SEIS must address the cumulative impacts of both the Resort and Marina Expansion. For a variety of reasons, the applicant (PLA) has formally requested that Jefferson County allow the preparation of an SEIS for the Marina separate from an SEIS for the Resort.' The elements of the two reports would then be combined into one overall project SEIS to meet the conditions of Section 3.902 as described above. The reasons for the request follow: · The Marina expansion EIS requires multi-agency review with the DNR, Washington Department ofFish and Wildlife (WDFW), U.S. Army Corps of Engineers (COE), National Marine Fisheries Service (NMFS), and U.S. Fish and Wildlife Service (USFWS)all having some level of jurisdiction over the expansion proposal. These agencies have little if no review authority over the upland Resort development plans. Port Ludlow Marina Expansion final sEls DRAFT 1.4 October 2002 --- I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I . Although the Marina expansion project is part of the Resort plan, it is not an interdependent part of the Resort plan and does not depend on the Resort plan as its justification or for its implementation (see WAC 197-11-060(3)(b)(ii)). There are two separate issued related to a "phased" review of this project. On the one hand, Section 3.902 of the MPR ordinance provides, "Environmental review of the Resort Plan shall not be piecemealed or broken into small segments." Based upon this language, the County is authorized to require only a single review of the project, however, the State Environmental Policy Act clearly authorizes the phased review of land use approvals. This process is described in Section 1.5 below. Jefferson County has agreed to allow the applicant to proceed with separate review of the Marina and the Resort with the clear understanding that no land use permits or building permits will be issued for the Marina Project until a Resort SEIS process (including cumulative impacts) is complete. 1.5 Phased Review Jefferson County is using phased review, as authorized by SEPA (WACI97-11-060(5)(b)) in its review of development projects in Port Ludlow. As noted above, a programmatic, non-project environmental impact statement was issued in 1993 for the Port Ludlow Development Program. The 100-slip expansion of the Marina was one element of the proposed development program identified in that document. This Draft Supplemental Environmental Impact Statement (Draft SEIS) assesses site-specific impacts and specific mitigation related to the Marina expansion. Using "Phased Review" under SEP A, the sequence of environmental review can take two forms. The review can be from a non-project document (the 1993 FEIS for the Port Ludlow Development Plan) to a document of narrower scope (a site specific analysis regarding the environmental impacts ofthe Marina expansion project (see WAC 197-11-060(5)(c)(i)). Alternatively, the environmental review can take an environmental document on a specific proposal at an early stage to a subsequent environmental document at a later stage (see WAC 197-11-060(5)(c)(ii)). Phased review does not divide a larger system into exempted fragments or avoid discussion of cumulative impacts (see WAC 197-11-060(5)(d)(ii)). Phased review does 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 (see WAC 197-11-060(5)(d)(iii)). The applicant is pursuing phased review as authorized by SEP A but modified by the Port Ludlow MPR Ordinance that will restrict the issuance of any permits until the cumulative Resort SEIS process is complete. 1.6 Summary of Alternatives The proposed project and three alternatives were evaluated in the Draft Supplemental EIS. This Final SEIS includes an additional alternative, Alternative 5 - Response to DSEIS Comments, which was developed in response to view/aesthetic impact concerns. The five alternatives include: Port Ludlow Marina Expansion final sEls Odober 2002 --- DRAFT 1-5 Alternative 1: Proposed Project The Proposed Project adds 100 slips to the Marina in a westward and waterward direction. The existing D-Dock and E-Dock will be extended (12 and 48 new slips respectively), and a new F-Dock (40 slips) will be constructed. A major trend in the marina industry is towards larger boats (Statewide Recreational Boating Study - Recreational Moorage Analysis and Boating Sewage Disposal Facility Analysis, BST Associates, October 2001); thus, all the new slips will be 36 feet and larger, up to 60 feet in length. The existing kayak float and a dinghy float will also be replaced and/or upgraded. The proposed project is shown in Figure 3. Port Ludlow Marina Expansion final sEls Odober 2002 --- DRAFT 1-6 I I I I I I I I I I I I I I I I I I I ------------------- ./ N .j>. ./ co co ./ o .j>. ./ o fTl (j) G) Z ./ -0 fTl ;:u ;;;: =i ./ fTl (j) ./ 2J z )> ,- ./ .j>. CO .j>. I o -0 ;:0 o -0 o :2' G) :ta. r- rM ~ ::b ::j ~ ~ ..... -l r- ;g ~ r- a 0 ~ "1:J ~ 0 :::0 en ~ ~ ;:t;: ~ ~ ;g ~ ~ 0 ;:r; ~ OJ C) en ..... 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A new float will also be constructed to connect B-Dock and C-Dock, and the existing kayak float will be repositioned to the new waterward extension of A-Dock. Alternative 2 is shown in Figure 4. Alternative 3: 1993 Design Alternative 3 will include a 100 slip expansion and improvements as conceptually proposed in the 1993 Port Ludlow Development Program Final Environmental Impact Statement. The 100 new slips will be accommodated by: a new dock with 14 slips along the eastern shore of the Marina (i.e., east of the fuel float); an extension of A-Dock approximately 150 feet waterward to accommodate a new T -shaped dock; a new L-shaped dock approximately 150 feet waterward of E-Dock; and extension ofC-, D-, and E-Docks to the west. Dredging will occur in a slightly less than one acre area near the eastern shore of the Marina (along Burner Point) in order to increase water depths and improve access to the new inner dock. Alternative 3 is shown in Figure 5. Alternative 4: No Action This alternative will result in maintenance of the existing Marina facilities, but no expansion of slips or upgrade of amenities such as the dinghy float or kayak float, at this time. Alternative 4 is shown in Figure 6. Alternative 5: Response to DSEIS Comments This alternative was developed as a response to comments received on the DSEIS concerning view/aesthetics impacts to properties on Scott Court and Burner Point. Scott Court residents were concerned with view impacts arising from Alternative 1 and Burner Point residents were concerned with view impacts arising from Alternative 2. Alternative 5 proposes a 100-slip expansion that concentrates the expansion and balances view impacts. With this alternative, the existing D-Dock and E-Dock will be extended (12 and 48 new slips respectively), and a new F-Dock (33 slips) will be constructed. The A-dock will be extended waterward (15 slips) and include a "L-shaped" floating breakwater. The B-dock will lose eight slips. The existing kayak float will be replaced at a new location. Alternative 5 is shown in Figure 7. 1.7 Scoping Notice and Request for Comments The scoping period for the Draft SEIS was from October 3 to November 2,2001. Notice of the scoping period was published in The Port Townsend and Jefferson County Leader on October 3, 2001. A public scoping meeting was held at the Port Ludlow Bay Club on October 12,2001. Both written and oral comments were received. A full copy of the scoping comments is on file with the Jefferson County Department of Community Development. 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Townhomes are located on Burner Point, east of the Marina. The proposed Marina expansion (Alternative 1) will extend to the west, potentially affecting the views currently enjoyed by these residents and potentially limiting ingress and egress to their dock. · Impacts of the proposed project on shoreline resources, wildlife habitat, and ESA listed speCIes: Listed ESA salmonid species, (i.e., chinook salmon and Hood Canal summer- run chum salmon) are known to use this area. The proposed expansion could have adverse impacts to food sources, habitat, and water quality. · Impacts of the expansion on water quality: Expansion of the Marina and the increase in Marina usage could potentially result in an increase in gray and black water discharge and the potential for hazardous material spills. The proposed action could potentially result in adverse impacts to water quality. · Consistency with new State of Washington Department of Natural Resources Rules for Residential Use of State-Owned Aquatic Land: During preparation of the Draft SEIS for this project, the Department of Natural Resources (DNR) was in the process of clarifying the rules governing residential use on state-owned aquatic lands. The Port Ludlow Marina leases State-owned aquatic lands and, therefore, would be subject to the new Rules. The new Rules were approved by the Board of Natural Resources on October 1, 2002. The new Rules clarify language related to floating homes and vessels and require marinas to use Best Management Practices (BMPs) to prevent environmental damage. In addition, there is a ten percent limit on residential use of vessels moored on state-owned aquatic land, unless otherwise determined by a local jurisdiction. 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So $:I o ~.til [ ~~,g~ October 2002 --- I I I I I I I I I I I I I I I I I I I Chapter 2 - Proposed Proiect and Alternatives 2.1 Description of Proposal 2.1.1 Name of Proposal "Port Ludlow Marina Expansion" 2.1.2 Project Sponsor Port Ludlow Associates, LLC 70 Breaker Lane Port Ludlow, W A 98365 2.1.3 Project Location The Port Ludlow Marina is located in Port Ludlow Bay, Jefferson County, Washington. The Marina is located on the north shore of the Bay, inside Burner Point. Port Ludlow Bay is located on the west shore of Admiralty Inlet at the mouth of Hood Canal. (Section 16, Township 28 North, Range 01 East, W.M.) The location of the project is shown in Figures 1 and 2. 2.1.4 Existing Project Features The Port Ludlow Marina currently provides 280 slips, additional side tie areas for 20 to 40 boats, as well as a boat sewage pumpout, dinghy float, fuel float, kayak float, and public access to the. water. Water, fire protection, and electrical service are available at the docks. Upland facilities include a store, rest rooms and showers, parking areas, and waterfront trails. In December 2001, the moorage distribution was 225 permanent residents, seven permanent non-residents, and 48 slips available for guests. Water depths at the Marina vary from shallow intertidal (approximately -10 feet Mean Lower Low Water - MLLW) around the perimeter of the Marina to depths of -38 feet MLLW. The Marina is configured with five dock systems and one fuel float. The fuel float, as well as the A- and B-Docks, are located at the east end ofthe Marina, just inside Burner Point, and extend from shore in a north-south direction. A floating breakwater is located at the end of A-Dock. Two five-foot gangways provide access to A- and B-Docks, the fuel float, and the kayak float from the upland facilities. The C-, D-, and E-Docks are connected by one central walkway and are located to the west, in a general east-west configuration. These docks are accessed from the upland facilities by a third gangway. The existing 1,600 square foot wood and foam kayak float accommodates 40 kayaks in racks and is located on the west side ofB-Dock. The existing 680 square foot wood dinghy float is located at C-Dock, at the junction of the main walkway and the lateral. This dinghy float completely covers the area between the walkway and the first finger to the south. Port Ludlow Marina Expansion final sEls October 2002 --- DRAFT 2-1 The boat sewage pump-out station is located on the fuel float. The fuel float also accommodates a small structure for fueling accessories and the cash register. The fuel float is also used occasionally by seaplanes for docking. The current mix of slips at the Port Ludlow Marina ranges from 24-foot slips up to side tie areas for boats in the 80-foot range. The recent trend in boat design is toward boats that are longer, have wider beams, and include amenities such as "swim steps." 2.2 Proposed Proiect and Alternatives The proposed project is an addition of dock systems at the Port Ludlow Marina to provide an additional 100 slips. For all expansion alternatives, the existing kayak and dinghy floats will be replaced. The new Marina floats will be constructed of concrete sections with structural wood wales and an encapsulated foam floatation core. The new floats will generally be 5 feet to 8 feet in width and will be held in place by new steel piling. Floats for the outer dock will be 12 feet in width. These outer floats serve as a floating breakwater to protect the Marina from waves and wakes. The wider width is necessary to provide this protection. It is very likely that mitigation as requested by the Jefferson County Fire District 3 to provide additional access to the floats will be provided. The mitigation measure will include installation of a float to provide a connection between B-Dock and C-Dock to increase access to the floats to and from land. Currently, only one gangway provides land access to C, D, E, and F-docks. This mitigation will require an additional three piling to be located in water less than 20 feet in depth. The only upland actions associated with this project are new utility tie-ins that will be required in an area of approximately 50 feet upland of OHW. Alternative ,': Proposed Project The proposed project (i.e., the Marina expansion as proposed by the project sponsor) is shown as Alternative 1. The proposed project adds 100 slips to the Marina by expanding the existing float system both westward and waterward. The proposed configuration of the new floats/slips is as follows: . D-Dock will be extended 120 feet to the west to accommodate an additional twelve 36.foot slips. . E-Dock will be extended 400 feet to the west to accommodate an additional 42 slips (seven 50-foot, nine 60-foot, and twenty-six 45-foot slips). . The east side ofE-Dock will be reconfigured to accommodate sixteen slips (eight 36-foot slips and eight 40-foot slips, to replace 10 existing slips). . A new F-Dock will be constructed waterward ofE-Dock. The new F-Dock will extend 700 feet westerly and 250 feet easterly of the central walkway. The new F-Dock will Port Ludlow Marina Expansion final sEls October 2002 --- DRAfT 2-2 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I accommodate 40 new slips (thirty 45-foot slips and ten 50-foot slips). F-Dock will serve as a floating breakwater to protect the Marina. The existing 1,600-sq. ft. timber kayak float will be replaced in the same location with a 2,850-sq. ft. float with light transmission capabilities. The new kayak float will be constructed using plastic pontoons for floatation and timber for the connection system. The float cross section will consist of three pontoons. A space will be left open between each of the pontoons in the cross section. The new float design will incorporate light-transmission panels. The two gaps between the three pontoons will be spanned by grating or sandblasted plexiglass (versus timber decking), which will allow light to penetrate beneath the float. The existing 680-sq. ft. dinghy float on C-Dock will also be replaced with three new floats totaling 1,086 sq. ft. The floats will be 6 feet wide and attached to the sides of the main walkway and the C-Dock lateral, the E-Dock lateral, and the F-Dock lateral. The new dinghy floats at E-and F-Docks will be located at water depths of greater than 20 feet (MLLW=O Datum). The new dinghy float at the junction ofthe main walkway and the C-Dock lateral will open up a now covered side space between the dinghy dock and the first finger. The proposed project is shown in Figure 3. Alternative 1 will result in an additional 33,745 sq. ft. of overwater structure. Ofthis total, 966 sq. ft. of new overwater structure will be located in water depths of less than 20 feet (MLL W=O). The remaining 32,779 sq. ft. will be located at water depths of20 feet or greater. Approximately 100-130 new steel piles will be required. The proposed project includes placement of one of the piles in water less than 20 feet in depth. Pile-driving equipment will be barge-mounted and will be either a diesel-powered hammer or vibratory driver. Pile-driving equipment will be sized according to the geotechnical characteristics of the substrate. The barge will be sized to accommodate the equipment used during the pile driving. The one piling to be installed in shallow water (18 to 20 feet deep) will be shorter than those to be installed in deeper water, requiring less energy to install than the pilings in deeper water. Installing the one piling in shallow water will take less than 1 day, minimizing the time of potential disturbance of any salmonids that may be present in the nearshore area. The remaining piles will be installed at water depths of greater than 34 feet. The barge will be maintained at sufficient depth to ensure that it will not ground. All pile driving will be done outside the closed work window for listed species. Alternative 2: Deep Water Expansion Alternative 2 provides for a 100-slip expansion primarily waterward, rather than laterally to the west. The existing dinghy dock will remain in place. The proposed configuration ofthe new floats/slips is as follows: . Thirteen 45-slips will be added to the waterward side ofE-Dock, west ofthe central walkway. Port Ludlow Marina Expansion final sEls October 2002 --- DRAFT 2-3 Port Ludlow Marina Expansion final sEls DRAFT 2.4 Odober 2002 --- I I I I I I I I I I I I I I I I I I I · The east side ofE-Dock will be reconfigured to accommodate sixteen slips (eight 45-foot slips and eight 50-foot slips, replacing 10 existing slips). · New F- and G-Docks will be constructed waterward ofE-Dock. The new F-Dock will extend 250 westerly and 180 feet easterly of the central walkway, and will accommodate 35 slips (twenty-one 45-slips, eight 50-foot slips, and six 60-foot slips. The new G-Dock will extend 170 feet westerly and 180 feet easterly of the central walkway, and will accommodate 14 slips (eight 45- foot slips and six 60- foot slips). This will serve as a floating breakwater. · A-Dock will be extended 270 feet waterward and will accommodate an additional thirty-two 45-foot slips. This will serve as a floating breakwater. · A new float will provide a connection between B-Dock and C-Dock, and the existing kayak float will be repositioned to the new extension on the A-Dock. Alternative 2 will result in an additional 37,865 sq. ft. of overwater structure. All of the 37,865 sq. ft. of additional overwater coverage will be located at water depths of 20 feet or greater. Approximately 100-130 new steel or concrete piles will be required. None of the piles will be located in water less than 20 feet in depth (MLLW=O Datum). Alternative 2 is shown in Figure 4. Alternative 3: 1993 Design Alternative 3 will include a 100-slip expansion and improvements with the configuration proposed in the 1993 "Port Ludlow Development Program Final Environmental Impact Statement." The proposed configuration ofthe new floats/slips is as follows: · C-Dock will be expanded 60 feet to the west to accommodate 120 feet of side ties. · D-Dock will be extended 240 feet to the west to accommodate an additional fourteen 40-foot slips and twelve 48-foot slips. · E-Dock will be extended 200 feet to the west to accommodate an additional ten 48-foot slips, and seven new 50-foot slips will be added to the east side ofE-Dock. · A new L-shaped dock will be constructed approximately150 feet waterward ofE-Dock to provide additional side-ties. · A-Dock will be extended 150 feet waterward and will accommodate an additional thirty-four 40-foot slips. · A new dock will be constructed between the fuel float and Burner Point. This new dock will accommodate fourteen 40-foot slips and will be located in water less than 20 feet in depth. I I I I I I I I I I I I I I I I I I I · Approximately 500 cubic yards of dredging will be required at slightly less than a I-acre area along Burner Point in order to increase water depths and improve access to this new inner dock. Alternative 3 will result in an additional 31,164 sq. ft. of overwater structure. Of this total, 7,956 sq. ft. of new overwater structure will be located in water depths of less than 20 feet. The remaining 23,208 sq. ft. will be located in water depths of20 feet or greater. Approximately 100-130 new steel piles will be required. Approximately two-third of these piles will be located in water greater than 20 feet in depth. Alternative 3 is shown in Figure 5. Alternative 4: No Action This alternative will result in maintenance of the existing Marina facilities, but no expansion of docks or slips, and no upgrade of amenities such as the dinghy float or kayak float, at this time. Alternative 4 is shown in Figure 6. Alternative 5: Response to DSEIS Comments Alternative 5 provides for a 100-slip expansion designed to minimize view impacts from Scott Court and Burner Point. The proposed configuration ofthe new floats/slips is as follows: · D-dock will be extended 120 feet to the west to accommodate additional twelve 36-foot slips. · E-dock will be extended 270 feet to the west to accommodate additional 35 slips (five 60- foot, seven 50-foot, and twenty three 45-foot slips). · The east side ofE-dock will be reconfigured to accommodate 23 slips (thirteen 36-foot slips and ten 60-foot slips to replace 10 existing slips). · A-Dock will be extended 220 feet waterward and will accommodate additional fifteen slips (eight 50-foot and seven 60-foot slips). An L-shaped floating breakwater will be constructed. · The existing float between the fuel float and A-Dock will be relocated to provide a connection between B-Dock and C-Dock. This will increase access from C, D, E, and F-Docks to land, thus improving fire safety at the Marina. · The existing kayak float will be removed and replaced with a new grated kayak float (2,850 sq. ft.). Alternative 5 will result in an additional 37,400 sq. ft. ofoverwater structure. Approximately 1,330 sq.ft. of new overwater structure will be located in water depths ofless than 20 feet. Approximately 120 new steel piles will be required. A total of four piles will be located in water less than 20 feet in depth (MLL W=O Datum). The existing dinghy float on C-dock will be replaced with three new dinghy floats totaling 960 sq.ft. The dinghy floats will be six feet wide and attached to the sides of the main walkway and the C-dock lateral, E-dock lateral, and the F -dock lateral. Alternative 5 is shown in Figure 7. Port Ludlow Marina Expansion final sEls DRAFT 2-5 October 2002 --- I I I I I I I I I I I I I I I I I I I 2.3 Benefits /Disadvantages of Delaying Implementation The SEP A Guidelines encourage permitting agencies to view each generation as a trustee for succeeding generations. With this perspective, environmental review is encouraged to consider whether approving/implementing a proposal at this time will preclude future options {WAC 197- 11-440(5)( c)( vii) } . The benefits of delaying expansion ofthe Marina relate to delaying the associated impacts to the natural and built environments. No expansion of the Marina at this time will result in no immediate construction or additional operational impacts to the marine environment or impacts to views from adjacent residential properties and the traveling public. The Port Ludlow Marina is now at full capacity, and there is an increased demand for both more boating facilities and larger slips to accommodate larger boats. The Marina now turns away approximately 30 vessels each month between Memorial Day and Labor Day. It is unknown whether delaying implementation will result in potential Marina customers constructing their own docks in Port Ludlow Bay, additional boats anchoring in the Bay, and/or increased use of alternate marina locations. The disadvantage of delaying the expansion relates to delaying provision of planned facilities and services for local and traveling boaters. As stated above, if the expansion is not permitted at this time, the demand for boating facilities in and around Port Ludlow Bay will continue to increase. Also, merely delaying implementation to a later point in time will not minimize identified impacts. Port Ludlow Marina Expansion final sEls October 2002 --- DRAFT 2-7 CHAPTER 2 - PROPOSED PROJECT AND ALTERNATIVES .........................................................................1 2.1 Description of Proposal................................................................................................................................. I 2.1.1 Name of Proposal....... '" ......... ............... ..... .......... ................................................. ....... .......... ....... ......... ..... 1 2.1.2 Project Sponsor....................... ............ ... ................................... .................... ............. ................................. 1 2.1.3 Project Location.... ......... ............... ........ ....... ........ ........ ...... ....... ... ............ ...... .......... '" ......... .....,...... ...........1 2.1.4 Existing Project Features ............................................................................................................................1 2.2 Proposed Project and Alternatives ................................................ ................................................................. 2 2.3 Benefits/Disadvantages of Delaying Implementation.............................................................................. ...1f7 Port Ludlow Marina Expansion final sEls DRAFT 2-8 October 2002 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 3.6 AESTHETICS /VISUAL QUALITY A visual quality study was prepared by Reid Middleton, dated February 2002, to evaluate potential changes to visual qualities of the environment from the proposed project and alternatives. The study describes the existing landscape character, viewer groups, viewpoints, and identified visual impacts. Reid Middleton revisited the site in August 2002 and prepared arevised visual analysis in response to comments received on the Draft Supplemental Environmental Impact Statement (Draft SEIS). The revised aesthetic/visual analysis includes an additional viewpoint from the townhouses on Burner Point and an additional alternative developed in response to comments on the Draft SEIS. Study and Methodology To evaluate potential visual impacts of a proposed project, both the visual quality of the existing site and viewer sensitivity to the proposed changes must be analyzed. Analyzing aesthetic and visual impacts includes concern for the nature of the visual experience and its quality. Because this type of analysis can be subjective, sets of proven evaluative measures have been developed. The methodology described below was developed from such evaluative measures as they apply to expansion of the Port Ludlow Marina. The methodology employs both quantitative and qualitative analysis of the described landscape components. The project site was first analyzed with respect to three key factors identified below. Ratings from 1 to 5 express the degree to which the landscape contains a high degree of each factor, with 5 being the highest rating. Table 4 summarizes the results of the Existing Scenic Quality Inventory. . General landscape (landform, vegetation, water, color, adjacent scenery, scarcity, and cultural modifications) relative to the basic design elements of form, line, color, and texture. . Degree of visual interest (vitality, vividness, and variety). How memorable, striking, or distinctive are the elements of the landscape and the visual patterns inherent in it? . Sense (congruence, clarity, and coherence) and unity (fit, intactness, and harmony) are related and explore whether the landscape is compositionally harmonious. Are there visual encroachments to the essential quality of the site that detract from the overall experience? Do manmade elements add and fit within the natural elements of the landscape? Do the visual patterns in the landscape represent a confusing and chaotic quality rather than a coherent and congruent experience? Viewer sensitivity was then analyzed relative to the type of viewers, amount of use (i.e., frequency and duration), the level of public interest, adjacent land uses, and uniqueness ofthe scenery. Viewer sensitivity levels were identified for four viewer categories relative to six factors in Table 4. Other related analyses involve identifying key view or observation points, viewsheds in the area, distance zones and view impact cones related to views of the site. Port Ludlow Marina Expansion final sEls DRAFT 3-1 October 2002 ~ Lastly, impacts were assessed by contrasting the visual quality of the existing area and viewpoints with the visual quality ofthe proposed changes, via the use of computer simulation photographs. Contrast ratings are developed for each alternative, and an analysis of impacts is developed. The level of viewer sensitivity and view analysis issues are factored into the impact assessment. Several ofthe inventory and analytical worksheets used for this analysis were adapted from the Bureau of Land Management's Visual Resource Management Manual (September 2001). Consequently, some of the charts may reflect their system of classification. 3.6.1 Affected Environment Existing Visual Environment The Port Ludlow Marina is located on the north side of Port Ludlow Bay, on the western shore of Puget Sound, just north of where Hood Canal enters Puget Sound. The intimately-sized Bay is partially enclosed by medium steep and rounded slopes that surround it on most of three sides. Although views east of the site may include some expanses of the larger Puget Sound, the more immediate views of the Marina area are of the protected Bay and surrounding hillsides. The relative steepness of the slopes gradually lessens to gentle banks to the north of the Marina and the flat promontory area (known as Burner Point), east of the Marina. Existing views of the site are shown below. Adjacent hillsides are mostly covered with a variety of deciduous and evergreen trees that provide a variety of interesting forms, textures, color, and patterns. The Bay is a dominant factor in the landscape. The J-shaped Bay lends a quality of protection that gradually spirals out to larger, more expansive vistas of the Sound as one leaves the immediate vicinity ofthe Marina. The Marina is located along the north shore of the Bay. The Marina itself provides visual interest to the scene. It provides texture, pattern, color, and movement, while generally fitting well in its natural setting and within the scale of the surrounding Bay. The upland area of the Marina is developed with parking, and small marina buildings. Beyond this to the north are Port Ludlow Marina Expansion final sEls DRAFT 3-2 October 2002 --- I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I undeveloped parking areas. The upland area to the east is flatter topographically and is developed with larger-scaled buildings including a restaurant, inn and condominium development. There is less natural and landscape vegetation here partially due to the amount of development, but also due to the nature of a less protected and windy promontory location. To the west of the Marina is an undeveloped wooded slope. An area of single-family residences is located west of this slope; generally characterized by homes on individual lots surrounded by a combination of natural and landscaped vegetation. The visual analysis of the existing landscape is summarized in Table 4 below. The general landscape rating was based upon a site inspection, using a form adapted from the Scenic Quality Inventory and Evaluation Chart developed by the Bureau of Land Management (BLM) for Scenic Quality Assessment of federal lands use, as published in the Visual Resource Management Manual 8400 BLM Standards. Visual Interest and Sense & Unity are described earlier in the Methodology section. In the table below, the General Landscape, Visual Interest and Sense and Unity Ratings are broken down relative to the elements of Landform, Vegetation, Water, Color, Influence of Adjacent Scenery, Uniqueness/Scarcity, and Cultural Modifications/Manmade Form. Table 4 Port Ludlow Marina Existing Scenic Quality Inventory and Evaluation Chart: Key Factors General Landscape Rating* 3 5 5 5 5 4 4 Visual Interest Rating Sense & Unity Rating 5 5 5 5 5 5 4 5 5 5 5 4 3 4 Landform Vegetation Water Color Influence of Adjacent Scenery Uniqueness/Scarcity Cultural Modifications/ Manmade Form Subtotal 34 31 Total 96 *Visual Resource Management Manual 8400 BLM Standards, Scenic Quality Inventory and Evaluation Chart. Totals of 80 and above = High Visual Quality Totals of 79 to 42 = Medium Visual Quality Totals of 41 or below are of Low Visual Quality 31 Based on the scoring techniques used in this analysis, a total score of 80 or more is considered a high rating. The analysis resulted in a high rating of 96 points. It was rated slightly lower relative Port Ludlow Marina Expansion Final sEls DRAFT 3-3 October 2002 --- to only two issues, intactness and uniqueness/scarcity. Intactness relates to whether development has had a negative impact on the natural scenic quality of the setting. In the case of previously developed areas with high visual quality, intactness may also refer to whether new development is congruent with the existing pattern of built form that has been key to the visual quality ofthe setting. Intactness is reflected in the factors of Influence of Adjacent Scenery, Cultural Modifications/Manmade Form, and would affect ratings under the General Landscape and Sense and Unity Ratings. In this case, much ofthe development has been well integrated into the natural setting (e.g., homes on well-vegetated lots). A few examples of more recent development are less successful in this regard and consequently the rating for Adjacent Scenery indicates a slight impact to the intactness of the scenery. Regarding Uniqueness/Scarcity, the Marina site cannot be characterized as being completely one of a kind in northwest Washington, but it is still a highly- valued example of this type of landscape setting in this area. Viewer Sensitivity Viewer sensitivity issues of the Port Ludlow Marina have been divided into four locations based on different views. These locations are: · Views from Oak Bay Road, above the Marina. · Views from Other Roads and public areas with views of the Marina. . Views from Adjacent or near-by Residential Properties. · Views from Other Residential Properties further inside, or across, the Bay. Views from the Scott Court properties and Townhouses on Burner Point fit into the third category above. Viewer sensitivity levels were evaluated on the basis ofthe following factors: . Viewer type · Amount of use (i.e., duration and frequency) . Public Interest . Adjacent Land Use · Uniqueness/Cultural Value of the Areas . Other Factors such as Level of Impact The four viewer sensitivity locations listed above were identified and analyzed. Sensitivity levels for each of the four locations were then rated as High, Medium, or Low relative to the six factors listed above. Viewer sensitivity ratings are shown in Table 5 below. Pori Ludlow Marina Expansion Final SEIS DRAFT 3-4 October 2002 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Table 5 Port Ludlow Marina Viewer Sensitivity Rating KEY FAOORS Oak Bay Other Roads Adjacent Residential Other Residential Road Properties Property Type of Users Passengers Passengers and Single-family, and Single- family, and drivers in condominium full- and drivers vehicles and time and vacation! condominium full- in vehicles, pedestrians part-time residents time and vacation! bicyclists part-time residents Amount of Use Public Interest Adjacent Land Use Uniqueness/Cu ltural Value of Area Other Factors* M L H L TOTAL-H H L M+ L *This considers the level of impact likely to the group of viewer, such as the impact that is inherent from views that impact home environment. H H M-H H M-H L-M H-M M-H L H L L M+ L L+ L The analysis of viewer sensitivity issues for each location above, demonstrates that two ofthe locations have significant levels of sensitivity to proposed expansion of the Marina: 1. Those related to viewing the site from Oak Bay Road, 2. Those related to viewing the site from Adjacent Residential Properties. Oak Bay Road provides important views for those traveling past the site. These views are public views, close to the site, on a well-traveled public road, and hence, important to a large number of viewers. This is the best, ifnot the only good view of this portion of Port Ludlow Bay from a public road. It is recognized, however, that most viewers are travelling at a speed that lowers sensitivity. Trees and vegetation obscure the Marina in many places. The over-all sensitivity level for views from Oak Bay Road is "High. " The viewer sensitivity for views from adjacent residential properties is a "Medium to High" sensitivity level. The group of viewers associated with this view is relatively small and characterized by a private, as opposed to public interest. However, there is greater public interest from Burner Point where there are public walking trails adjacent to the shoreline and in front ofthe Townhouses. There is a higher potential for impact associated with private views from adjacent residential properties because the views ofthe Marina extend over a greater period oftime, at different view angles, at various times of day, with a range of light conditions. and the views are unobstructed from the Scott Court properties and from the second story-west facing windows and decks ofthe Burner Point Townhouses. First floor views from Burner Point, however, are partially obscured by topography. The viewers in this group view the Marina from their home environment. Pori Ludlow Marina Expansion final SEIS I I I j DRAFT 3-5 October 2002 ~ The viewer sensitivity is lower when considering that only part of the total views available to these viewers would be affected (see Figures 27 and 28). The rating would lower slightly relative to the location ofthe Burner Point Townhouses within the developed resort area. Views from other properties across the Bay or further away from the Marina and from public roads in the study area have lower sensitivity levels since the proposal site is obscured or too distant to have a significant impact. View Analysis A View Analysis was conducted. Several viewpoints and their related viewsheds in three distance zones were identified (Figures 11 through 13). Five viewpoints, noted below, were reviewed originally for potential impacts. Three ofthese viewpoints (Viewpoints #1, 2a, and 3) were identified as key viewpoints subject to a more detailed analysis. An additional viewpoint, #2b, lies in Distance Zone #1 and was reviewed for the purposes of preparing the Final SEIS. Figures 11 through 13 have been revised to include this Key Viewpoint. Viewpoint # 1 represents views from Viewshed 1, that segment of Oak Bay Road located directly above the Marina. Views from this area are characterized by being high in frequency and high in public interest, but sometimes obscured by vegetation and the speed at which the viewer is moving. Figure 26 shows the portion of the total view from Oak Bay Road that would be affected by Marina expansion. Viewpoint #2a represents views from Viewshed 2, adjacent private residential waterfront property (known as the "Scott Court" property). These views are characterized by a limited number of viewers with a prolonged viewing time. Views of the Marina and Bay are unobscured. Figure 27 shows the portion of the total view from Scott Court properties that would be affected by Marina expanSIon. Pori Ludlow Marina Expansion Final SEIS DRAFT 3-6 October 2002 ~ I I I I I ' I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Viewpoint #2b (Burner Point Townhouses) also represents views from Viewshed 2, adjacent, private, residential waterfront property. These views are characterized by a limited number of viewers with a prolonged viewing time. Ground floor views are partially obscured by topography. Rolling mounds vegetated with wild grasses lie between the Townhouses and the marina. These mounds obstruct much of the first floor view of the Bay and the Marina. The photograph ofthis view shown above is taken from the top of one the dune-like mounds in front of the townhouse located closest to the Marina. Views from the first floors of the townhouses would be even more obscured because the townhouses are lower than the dunes and further away from the Marina. Second floor views of the Marina and Bay, however, are generally unobstructed especially for windows facing to the west. A few decks are oriented to the south and would have southwestern views towards the Marina as well. Views ofthe Marina are only a portion of the total view from these townhomes (see Figure 28). Many second floor windows are oriented to the south, not southwest toward the Marina. The eastern most townhouses have views eastward; the Marina is not within a significant portion of their views. Viewpoint #3 represents views from Viewshed 3, private residential waterfront properties across the Bay. These views are unobscured by topography or vegetation, but are obscured by distance. Viewpoint #4 represents views from public roadways across the Bay. There are few views of the Marina from this viewshed; vegetation, buildings, and distance often obscure what views there are. Pori Ludlow Marina Expansion Final SEIS DRAFT 3-7 October 2002 ~ Viewpoint #5 represents views from homes or residential streets that are distant. These views may or may not be obscured by topography, vegetation, or buildings. The number of viewers is small and the public interest is low. Pori Ludlow Marina Expansion Final SEIS DRAFT 3-8 Oclober 2002 --- I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I ~ NORTI-l * vleJIII simulation IOGatlon ( (l) l~lZllZl' 2~lZllZl' I\-J I I SCALE: I" = l~lZllZl' Reid iddleton KEY VIEWPOINTS PORT LUDLOW MARINA EXPANSION FSEIS FIGURE 11 i:\ \24\99\0 14\permit\eis\ view ~ x @)north @ Fort L.lJdlo~ 6C1~ NORT~ * vie JIll simulation IOGatlon (l) l,lZllZllZl' 2,(l)lZllZl' ~ I I SCALE: I" = l~lZllZl' Reid iddleton VIEWSHEDS PORT LUDLOW MARINA EXPANSION FSEIS FIGURE 12 1:\ \24\99\0 14\permit\eis\FINAL \ views2 ( I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I [251 ~ E2Z1 c::Ilstanc:.e zon II * vleJIII simulation IOGa ( (l) l~lZllZl 2 ~lZllZl I\...l I I SCALE: I" = l~lZllZl' Reid iddleton DISTANCE ZONES FIGURE 13 PORT LUDLOW MARINA EXPANSION FSEIS 1:\ \24\99\014\permit\eis\FINAL \views 3.6.2 Environmental Impacts Key Viewpoints In the Draft SEIS, one key viewpoint was identified in each of View sheds #1, 2, and 3 for a more detailed analysis through view simulation. In response to comments on the Draft Supplemental EnvironmentalImpact Statement, an additional key viewpoint was added for Viewshed #2. These key viewpoints are: . View #1 looking south from Oak Bay Road. For purpose of analysis, a panorama was created for this view using a composite of the "Left," "Middle," and "Right" views. This view depicts the expansive view of the Marina from this location. . View #2a from Scott Court. View #2a represents the view to the southeast from adjacent residential properties located immediately west of the Marina. . View #2b represents the view to the southwest from townhouses on Burner Point located immediately east of the Marina. For the purposes of analysis, a second floor deck view was used. The view used for the analysis represents the best view ofthe Marina from this viewpoint, not the typical view. . View #3 looking north from across Port Ludlow Bay. View #3 provides for further analysis of the visual impact to waterfront properties located further away. Pori Ludlow Marina Expansion Final SEIS October 2002 ~ DRAFT 3-12 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Contrast Ratings Photographs of each of the above views were taken in November and December 2001 and August 2002. Computer simulations of the proposed project and alternatives were then produced and compared to the existing views. The existing views were evaluated and contrasted to the simulation view of the proposed changes using the "Viewer Contrast Rating Sheet" shown below. The contrasts are evaluated and rated as "Strong," "Moderate," or "Weak." The existing and simulated views of Views 1, 2a, and 3 for Alternatives 1 through 3 are shown in the Draft SEIS (Figures 14-22) and are not reprinted here. Existing and simulated views for View 1 and 2a for the Response to Comments Alternative are included in the FSEIS as Figures 23 and 24. Existing and simulated views from Burner Point for all alternatives are shown as Figure 25 ofthe FSEIS. Existin Form Line Color Texture Pro osed: Form Line Color Texture Sam Ie Viewer Contrast Ratin : 1. LandIW ater 2. Vegetation 3. Structures 1. LandIW ater 2. Vegetation 3. Structures Existin - Visual Quality Existin - Visual Sensitivity 1m acts- Construction 1m acts- Operational Comments The results of the Viewer Contrast Rating Sheets based on the photographic simulations prepared for the key viewpoints are summarized in Table 6 below. A weak contrast rating means that the difference in the existing view and the view with simulated changes is very slight. Moderate contrast rating means that the change in the simulated view is more than discernible. A strong contrast rating means there is a good amount of difference between the computer simulated photograph and the photograph ofthe existing view. Alternatives # 1 - Proposed Project # 2 - Dee Water # 3 - 1993 Design #4 - ExistingINo Action #5 - Response Pori Ludlow Marina Expansion Final SEIS DRAFT 3-13 View #3 Across The Ba Weak-None Weak-None Weak-none None N/A October 2002 ~.. - - - - - - - - - - - - - - - - - - - )> ::; (I) .., ~ < A) (j)" r+ =E -. m < '!:t: >< (I) -" (ij. - c.n "TI -. en ...., ::s m ace ;:;0 3 3 ~. OQo(l) c::: tn QlC/Jt/) Q) - '" -.""C OJ 3 0 - ~ CD CO ~=-~ Q. ::oat/) :S :SI a CD C'D CD ~Q. CD :E - <r+ :E "'tI -.0 Ql CD :J ~ n a Ql tn 0 3 3 ~ 3 (I) ~ r+ t/) I I, "T1 CO c::: .., CD ~ UJ I I I I I I I I I I I I I I I I I I I Existing View Simulated View ~ Alternative 5: Response to Comments Existing & Simulated Views View #2a - From Scott Court Figure 24 - - < CD" =Emj\) ~~. w , en ,., ~ .e:. ..., :::I .. ~CCQ) oQo::::J ~ ~ c. OJ 3 c.n ~ So ;;0 SU :;Q ~ S' CD c..Q.en ~:S1:J III CD 0 is ::e ::::J Dl en en ~ CD r+ o o o 3 3 CD ::::J r+ en "T1 -" cc s::: ~ CD ~ CJ1 )> - r+ CD .., ::::J Q) r+ <" CD en ~ - - - - )> ;:; CD ~ ~ OJ - <" CD w ~ co co ' w )> ;:; CD ~ ::s OJ - <" CD en 3 s::: - D) - CD Q. S CD ~ - - - - - )> - CD ~ ~ D) - <" CD I\) c CD CD "'C ~ - CD ~ en -" 3 s::: D) - , CD" Q. S CD ~ )> ;:; CD ~ ~ OJ - <" CD c.n :;0 CD U) "'C o ~ tn CD - o (') o 3 3 CD ~ - U) en 3 s::: OJ - CD Q. S CD ~ - - - - - - - - )> ;:; CD ~ ~ OJ - <" CD ~ "tJ ~ o "'C o tn CD Q. )> ;:; CD .., Ii: ~ ~ ~;' OJ "0 ,\ - <" CD en 3 .~ s::: ~. D) ~ - CD Q. S CD ~ )> ;:; CD ~ ~ OJ - <" CD ~ m >< tn ~ ~ cc - Z o )> n ~ o ~ S CD ~ I I I I I I I I I I I I I I I I I I I Impact Assessment To determine the level of impact, the contrast rating shown in Table 6 was then combined with viewer sensitivity shown in Table 5. One aspect ofthe viewer sensitivity analysis for each alternative relates to the amount of each view impacted by each ofthe alternatives. Figures 26 through 28 depict the View Impact Cones for Views 1, 2a, and 2b. These cones show the portion ofthe view that would not have any impact from each alternative, "Unobstructed View." The "Modified View" represents the area in which the view is partially obstructed or changed by the alternative. The "Obstructed View" is the area that is totally and permanently blocked by an alternative. None ofthe alternatives have this level of impact. In the case of the Oak Bay Road and Burner Point views, existing views ofthe Bay are partially obstructed by trees or topography. Therefore, modification in these portions of the views have less visual impact. After the contrast rating and viewer sensitivity were considered, determination was made as to how the view was different in order to evaluate the degree of visual impact (see Table 7 below). It is generally assumed that within areas exhibiting a high value of existing scenic quality (such as Port Ludlow Bay), any significant change results in a "Strong" contrast rating and potentially a high visual impact. On the other hand, a moderate contrast rating does not necessarily mean only a moderate visual impact; the degree of viewer sensitivity and other view analysis issues also may lead to a high impact. Alternatives Table 7 Port Ludlow Marina Visual/Aesthetic 1m act Oak Bay Road Scott Court - - Viewshed #1 Viewshed #2a Scott Court Across the Bay - Viewshed #3 Burner Pt. - Viewshed #2b Burner Point L M M N M+ M+ L-M H = High M = Medium L = Low N = None L L L N L Port Ludlow Marina Expansion Final SEIS October 2002 ~ DRAFT 3-17 ------ ------------- ;/ G . *~~EJ l> N X .,. rt'" /' "11< \\\ lD o- lD /' ::JG < , S O':l i' C) 3 c :l .,. 0- :l \l" C) ::J 0 /' ::J 3 C) 0 0"11 0' n. \l" rt'" fTl 0' ..... <" (j) _0 3 , =b 0' i;) c i' ..... z .....(\ (\ , \\\ /' G..... c ..... n. c -u ,0' 0 G (\ '" ::J 0 ..... n. < ..... - ~, ~O' 0 i" G .. :;:- <0 ::J < :l n. ...... fTl i' . < U) G , C) :l i" :y ~ G (\ . :l \\\ J 0' 0 0 c ..... -0 / ..... 0 ~ ::J , '::. 0 0 '-l -- \) < 3 iii' 0 '" 0 () , U\ 0 J :i \\\ '" 0 0. D.. '" lO -0 , ~" \\\ ~~ ~ S <D. ~ ~, ""tJ :1'1 -. ~..., \\\ r- 0 ~ &3 <:) - ~ 0 3 ~s:\)\) ~. ;:Il:- 1) Q) (\ ~OJn- Q) s:\) ~. 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() :I m o u::: )> u r c n. () :I m o u::: ------------------- /' \\) . *~~El )> N .p. X 'C'I'" /' \1< to (b to 0- /' :J\\) < "'1 S CI'~ i' \) 3 c ::J .p. 0'- :J 0 /' :J 3 ~ \'f \) \) 0 CI' Q. 'C'I'" fTl 0\1 CI' "' \'f U1 , =b CI' <' Cl _0 3 "'(\ c i' "' z ""' C (\ , (b /' "' n. c OJ , CI' 0 " (\ ro :Jo 3 "' n. < "' - 9-CI' ij' i' " .. ;; <0 :J < ~ n. -I '::l i' . < U1 \\), \) ~ i' :::::r --:::: " (\ . (b OJ CI' 0 ~ 0 ;::- c "' -0 "' 0' ~ "'1 '::, \) :J 0 --.J ..... s; 3 \} ro 0 :;; 0 (") 0 , (Jl OJ 5' ro 0 (b 0. 0.. :;; to -0 "'1 ~, (b g.~ ~ )> --- ~-- --- ~ --- ...-r --- [--- --- --- - .~ \) --- --- ~ -- --- --- --- --- -- --- --- --- --- 'C'I'" (b "'1 ::J o 'C'I'" <' (b Ut ~ (b U\ \) o ::J U\ (b --- --- 'C'I'" o ~~ 3 !~ ......- --- ~ --- ~ --- ...-r c ___ Q. --- - --- \) ~--- --- --- --- --- --- --- --- --- --- --- --- --- --- --- s Q)O ~ :tJ ~ $ ~ 0, l.b &~l C5"o - ~3~ s' tb n ~ ~ (\ ~ :::J n- CU Q) ~ ..., (\ g' -0 \) ~o ::l ~ 50 l.b Cn_(J\ )> 'C'I'" (b "'1 ::J 0 'C'I'" <' (b ~ .. 0 (b (b ~~ 0 ...- 'C'I'" ~~ (b (Jl ll) ::J --- --- :!! co c::: .., CD N 0) I I I I I I I I I I I I I I I I I I I The analysis of the contrast rating and visual impact for each key view for each alternative is summarized below: Alternative 1: Proposed Project Alternative 1 will expand the Marina primarily westward and waterward, and will be visible to some degree from all three key views. View #1. The simulation View #1 "Left" has no discernable change from the existing view. The View #1 "Middle" will have a very slight change and received a weak contrast rating. The change to View #1 "Right" was greater than the other portions ofthis view, but considering the speed at which the Marina is viewed and the location of trees that obscure the view of proposed modifications, the contrast rating is still relatively weak. View #1 is considered the most significant view because ofthe number of viewers, the greater. public interest, and visual access to Port Ludlow Bay. In conclusion, the proposed project has a low visual impact on this key viewpoint (see Figures 14A, 14B, and 14C in DSEIS). View #2a. The contrast rating for View #2a is rated strong. Some expansion of docks here could have a positive visual impact by providing a transition from the foreground structure (Scott Dock) to the background structures (houses and housing developments across the Bay). The degree of expansion is more than necessary for this transition and the positive aspects are outweighed by the negative impacts on this view. Although the contrast rating is strong for the photographic simulation, it should be stated that the photographic simulation does not encompass the total view available to the viewers in the viewshed. Views to the south and west would be unaffected by any marina expansion in this viewshed. However, the proposed project has a high visual impact to this viewshed, especially when the length oftime viewers are exposed to the view is weighed. The view is part of their daily, home environment and has a great impact to those private residents that are subject to the changes proposed (see Figure 15 in DSEIS). This key viewpoint is not as significant as View # 1 because although its view is unobscured, it has a smaller number of VIewers. View #2b. The contrast rating for View #2b is relatively weak for this alternative (see Figure 25). The photographic simulation view represents a second floor view facing southwest. Topography partially obstructs the first floor views ofthe Marina. Visual impact for this part of View shed #2 is low. View #3. The visual impact to View #3 is visible, but has only a weak contrast rating, so the impact is low (See Figure 16 in DSEIS). Alternative 2: Deep Water Design Alternative 2 results in expansion of the Marina primarily waterward. The expansion will be primarily visible from View #1. View #1. This alternative has a moderate to strong contrast rating for View #1. This is important because this view received a high viewer sensitivity rating, although the visual impact is lessened by the speed at which viewers tend to see the Bay. While trees obscure portions ofthe existing Pori Ludlow Marina Expansion Final SEIS DRAFT 3-21 October 2002 ~ Marina view, the area of the waterward expansion will be very visible from Oak Bay Road. The simulated photographs only partially capture this view due to constraints regarding the location of the photograph (see Figures 17 A, 17B, and 17C in the DSEIS). This is a case where a medium to strong contrast rating based on a photo simulation does not result in merely a medium visual impact on this viewshed. A very important part ofthe view, the Bay itself, is being obscured. When considering that the view ofthe Bay is now obscured from the public on most ofthe public roads in the Port Ludlow area by trees, especially within Distance Zone 1, it is evident that the alteration of the existing view from Oak Bay Road would have more than a medium impact. The traveling viewer in this view shed does not have much of an opportunity to visually search for an unobscured view of the Bay. Views #2a and #3. The Deep-Water expansion has a weak contrast rating and low visual impacts on Views #2a and #3 (see Figures 18 and 19 in the DSEIS). View #2b. This alternative has a moderate contrast rating for View #2b (see Figure 25). The simulated view is a second floor view. Existing topography partially obstructs portions of the existing Marina from first floor views. The visual impact is medium. Therefore, including this viewpoint in the analysis results in a higher impact rating for the whole viewshed. The rating moves from low to medium. Alternative 3: 1993 Design Alternative 3 will result in a generally lateral expansion of the Marina, to both the east and west. The expansion will be visible, at least to some degree, from all three key views. Views #1 and #3. Since the expansion is spread throughout the Marina, the contrast ratings are weaker (see Figures 20A, 20B, 20C and 22 in the DSEIS). The visual impact is low. View #2a. View #2a will have a strong - moderate contrast rating and a high visual impact (see Figure 21 in the DSEIS). View #2b. Alternative 3 has a moderate contrast rating for View #2b (see Figure 25). The simulated view is a second floor view. Topography partially obstructs portions ofthe existing Marina from first floor views. The visual impact is medium. Therefore including this viewpoint in the analysis results in a higher impact rating for the whole viewshed. The rating moves from low to medium. Ahernative 4: No Action No expansion of the Marina will result in no changes to existing views. Alternative 5: Response to Comments The Response to Comments Alternative is similar to the Proposed Project Alternative in that it will expand the Marina primarily westward and waterward and will be visible to some degree from all three key views. However, it does not expand westward as far as the Proposed Project Alternative. It is similar to the Deep Water Alternative in that it will expand waterward from the existing east docks, but to a lesser degree. Pori Ludlow Marina Expansion final SEIS October 2002 ~ DRAFT 3-22 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Views #1. Since the expansion is spread throughout the Marina, the contrast ratings are weaker (see Figure 23). The visual impact is moderate. View #2a. View #2a will have a strong - moderate contrast rating and a moderate visual impact (see Figure 24). View #2b. This alternative has a weak to moderate contrast rating for View #2b (see Figure 25) especially as compared to the Deep Water and 1993 Alternatives. The simulated view is a second floor view. Topography partially obstructs portions ofthe existing Marina from first floor views. The visual impact is low to medium as compared with the lower impact ofthe Proposed Project Alternative for this portion of the viewshed. In summary, analysis of views, viewsheds, viewer sensitivity issues, and contrast ratings for photographic simulation of key viewpoints have been evaluated to identify the visual impacts to each viewshed for each alternative. Alternative 1 - Proposed Project has high visual impact on View #2a in Viewshed #2. Alternative 2 - Deep Water has high visual impact on Viewshed #1 and View #2b in Viewshed #2. Alternative 3 - 1993 Design has spread out visual impacts so that its visual impacts range from low to high on all of the views, but has a high impact on Viewshed #2a and 2b. Alternative #5 -Response to Comments also has spread out visual impacts where all views have relatively medium impact. This alternative has a lower impact on Viewshed #2a - Scott Court than Alternative #1 - Proposed Project. It has a lower impact on Viewshed #2b - Burner Point than the Deep Water and 1993 Alternatives. It may have the most impact on the Oak Bay Road alternative in that all the proposed changes are visible from this view, however, the areas of impact of the Response Alternative may be more obscured by distance, speed, and screening by trees from this view. It has a lower impact than Alternative #2 - Deep Water Design for this viewshed. It should be pointed out that in each of the view simulations, the view shown is only a portion of the view available to the viewer at that viewpoint (see Figures 26-28). It is that portion of the view that is directed towards the proposed expansion. No view is completely blocked or totally impacted, even for this portion ofthe view. The determination of a "high" rating is relative to that portion of the views only. Therefore, evaluation ofthe impact to each of the views studied should be lowered in this regard. In general, all ofthe expansion alternatives will result in visual impacts. The differences between the alternatives are related to which view the particular alternative would most impact and the number of viewers impacted. All alternatives including the existing/no action also share a visual impact that stems from the trend towards a preference for larger sized vessels. Because the proposals represent expansion of existing development, the impacts are relatively less than if new, different, and larger-scaled development was proposed. Pori Ludlow Marina Expansion Final SEIS DRAFT 3-23 October 2002 ~ Construction Impacts Short-term, construction-related impacts were also considered. During the first phase of construction, one or two barges will be used, one with a barge-mounted crane. One or two small workboats (around 20 feet) will also be present. It is anticipated that the new piles will be brought in by barge. The new floats will be assembled on-shore and dropped in place by the crane after the piles are driven. Typically, the construction will take place first in the vicinity of the more landward docks and then proceed waterward. After the piles and floats are installed, construction activity will include installation of water and fire lines on the newly constructed docks. A fenced, contractor lay-down area will be located upland. Semi-trucks and trailers will visit the site to drop off materials and workers will be arriving daily. Although temporary, the visual impact of the construction stage is not only larger but also more intense than that of the long-term impacts of the proposed project. There will be temporary, visual, and aesthetic impacts on all views, especially on Views #2a and 2b. 3.6.3 Mitigation Measures Proposed Boats in excess of 60' in length will not be side-tied to the west end ofD-Dock or E-Dock. 3.6.4 Unavoidable Adverse Impacts Views from the four Scott Court properties will be impacted by the proposed Marina expansion. References Bureau of Land Management, U.S. Department ofthe Interior, 2001. Visual Resource Management Manual. www.blm.gov/nstcNRM/8410.htrnl (The Department of the Interior's website may not be available at this time.) Pori Ludlow Marina Expansion Final SEIS DRAFT 3-24 October 2002 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Chapter 3 - Affected Environment, Environmental Impacts, Mitigating Measures and Unavoidable Adverse Impacts TABLE OF CONTENTS .. 3.6 AestheticsNisual Quality...................................... .....................................................................................3 -46 3.6.1 Affected Environment.. ........... ............... ........ ......... ............ ................. ............. ................. ....... ........3-47 3.6.2 Environmental Impacts... ...... ... ... ......... .... ..... ... ...................... ......... ..... ................. ......... ....... ....... ... ..3-51 3.6.3 Mitigation Measures..... ................. ..... .............. ............. .......... .................................... .......... ......... ..3-73 List of Figures Figure 11 - Key Viewpoints ......................................................................................................3-52 Figure 12 - Viewsheds........................................... .................................................................... 3-53 Figure 13 - Distance Zones .......................................................................................................3-54 Pori Ludlow Marina Expansion Final SEIS DRAFT 3-25 October 2002 ~ I I I I I I I I I I I I I I I I I I I Chapter 4 - DSEIS Comments 4.1 Introduction The Notice of Availability for the DSEIS was published on July 5,2002 and the comment period ended on August 5, 2002. This section of the Final SEIS contains letters of comment on the Draft SEIS from public agencies and private citizens, together with responses to those comments. Each comment letter is followed by responses, with each response numbered to correspond to the numbered comments. Jefferson County wishes to express its appreciation of all commenting agencies and individuals for taking the time and effort spent in reviewing the Draft SEIS. 4.2 Comment Letters & Response to Comments Letters Received: Public Agency Letter: Washington Department ofFish and Wildlife Private Citizens Letter: William Funke Letter: Bill Master Letter: Scott Gibson Letter: Peter Joseph Letter: Grant Colby Letter: Burke Gibson Pori Ludlow Marina Expansion Final SEIS DRAFT 4-1 October 2002 ~ I I I I I I I I I I I I I I I I I I I State of Washington DEPARTMENT OF FISH AND WILDLIFE Region 6 Office: 48 Devonshire Road. Montesano, Washington 98563-9618. (360) 249-4628 August 4, 2002 f5)1 lE C le B ~ rE. ~ lr\1 AUG - 6 2002 lW Jefferson County Department of Community Development A TTENTlON: Josh Peters, Associate Planner 621 Sheridan Street Port Townsend, WA 98368 Dear Mr. Peters: JEFFERSON COUNTY OEPT. OF COMMUNITY OEVELOPMENT SUBJECf: Port Ludlow Marina Expansion Draft Supplemental Environmental Impact Statement; Port Ludlow A"sociates Proponent, Port Ludlow Marina Expansion, Port Ludlow Bay, Tributary to Puget Sound, Jefferson County, WRlA 17.9090 The Washington Department of Fish and Wildlife (WDFW) has reviewed the above-referenced State Environmental Policy Act (SEP A) document received on July S, 2002, and offers the following comments at this time. Other comments may be offered as the project progresses. Critical Resources The Port LudlowMarina Expansion Biological Evaluation (Draft) and the Draft Supplemental Environmental Impact Statement identified several species of fishes and wildlife that are likely present in Port Ludlow Bay. Puget Sound chinook and Hood Canal summer chum salmon are listed as "Threatened" under the federal Endangered Species Act and juveniles are present throughout Puget Sound during the spring and summer, including Port Ludlow Bay. A Port Ludlow Bay stream, Ludlow Creek, supports spawning populations of chum ::.nd ccho s2!mon, and cutthroat trOllt. Juveniles of each of these species utilize the nearshore environment. During their first spring, juvenile chinook, churn and pink salmon arc heavily dependent on nearshore areas as a migration corridor, a refuge from predators, and a foraging area. Cutthroat trout, yearling chinook and coho salmon, and yearling steelhead arc also present to some extent along the nearshore areas throughout the year. Bull trout are listed as "Threatened" under the federal Endangered Species Act. Little is known regarding their presence in nearshore areas of Port Ludlow Bay, but they may be present occasionally at a low density. . Contrary to the infonnation stated in the Port Ludlow Marina Expansion Draft Supplemental Environmental Impact Statement and Biological Evaluation, WDFW has docwncntcd spawning by Pacific sand lance and surf smelt on the beaches at or near the proponent's location. The spawning habitat of both of these forage fish species is upper intertidal sandy-gravel beach 1 08/07/2002 09:42 3503794473 JEFF CO OCD PAGE 02 Mr. Peters August 4, 2002 Page 2 material. Spawning occurs at high tide, at which time the adhesive eggs commonly acquire a camouflaging coat of sand grains. Sand lance and surf smelt are schooling planktonic feeders. However, sand lance are unique in that they tend to feed in open water dwing the day and burrow in bottom substrates at night to avoid predation. aoth species are an important component of diet of chinook and coho salmon, as well as other marine fishes, mammals, and birds. WDFW publishes a Priority Habitats and Species (PHS) list. Priority species require protective measUres for their perpetuation due to their population status, sensitivity to habitat alteration, and/or recreational, commercial and tribal importance. Priority species include those species designated as Endangered, Threatened, or Sensitive by the State and federal governments. Priority habitats are those habitat types or elements with unique or significant value to a diverse assemblage of species. It appears from the PHS map, the proponent's location is very close to an existing osprey and purple martin nesting areas. In addition, the PHS map shows estuarine habitat exists within Port .Ludlow Bay. While the Port Ludlow Marina Expansion Draft Supplemental Environmental Impact Statement does address potential adverse impacts to several priority habitats and species, it doesn't address impacts to osprey, purple martin, or the estuarine habitat. Envirorunental review of the Marina Expansion as well as the Resort Plan should address potential impacts to all priority habitats and species in Port Ludlow Bay and adjacent uplands. Concerns It was evident that a great deal offocused effort went into preparing the Port Ludlow Marina Expansion Draft Supplemental Envirorunental Impact Statement. WDFW supports either Alternative 4: No Action or Alternative 2: Deep Water Expansion with additional mitigation. It appears from the description of both alternatives, that a Hydraulic Project Approval (HPA), to be issued by WDFW, will be required. The Hydraulic Code (RCW 75.20.100) states, "In the event that any person or government agency desires to construct any form of hydraulic project or perform Qthet work that will use, divert. obstruct. or change the natural flow or bed of any of the salt or fresh waters of the state, such pe~on or government shall, before commencing construction or work thereon and to ensure the proper pJ:otection of fish life, secure the written approval of the department of fisheries or the department of game as to the adequacy of the means proposed for the protection of fish life." "Bed" is further defined as the land below the ordinary high waterlines of state waters (WAC 220-110-020(3)). Any individual conducting any activity subject to the above-referenced RCW 75.20.100 without first obtaining an HPA from Washington Department of Fisheries and Wildlife (WDFW) is guilty ofa gross misdemeanor (WAC 220-110-030(16)) and may be subject to legal action. I I I I I I I 2 I I I 3 I I I I I I I I I I I I I I I I I I I I I I I I I I I I 08/67/2002 09:42 3e.El3794473 JEFF CO DeD PAGE 63 Mr. Peters August 4, 2002 Page 3 According to correspondence from Alan Rounds) an additional 900 units of polyurethane coated floatation, for a total of3900 units, was installed at the marina this past winter. WDFW does not issue after-the-fact HP As. It appears the installation of the floatation was done without an HPA. To comply with the Hydraulic code and avoid future legal action, the proponents should obtain a HPA prior to conducting maintenance activities in WDFW'sjurisdiction. 4 WDFW recognizes the several mitigation measures proposed in Alternative 2 will minimize adv~rse impacts on fish resources including: . Minimizing dock width to decrease under-dock shadow area . Ple.cing docks in deepc~water to avoid grounding impacts to the intertidal . Inserting dock grating to allow under-dock light transmission across the sub-tidal . Using steel or concrete pilings to reduce the adverse impacts on fish resources associated wit:p. creosote or arsenic treated wood. . Placing new structures in deeper water to preclude dredging However, Alternative 2 still has the potential to adversely impact fish resources. Thus) additional I measures are needed to meet mitigation requirements to achieve no-net-Ioss of productive capacity of fish and shellfish habitat. . 5 Pile driving will result in a direct loss of benthic habitat and shellfish. ,The loss of bivalves and benthic habitat requires a mitigation plan. In addition, there will be impacts from construction such as increased turbidity from pile driving which may reduce primary productivity, interfere with fish respiration, reduce bottom habitat diversity, and smother benthic organisms. Furthermore, a biological opinion issued by National Marine Fisheries Service for the San Francisco-Oakland Bay Bridge East Span Seismic Safety Project states that underwater sOWld pressure waves, created ~hen the hamm(..'t' contacts the top. of a steel pile, have the potential to adversely affect fishes including listed salmonid species. Potential adverse effects of underwater ' shock waves cited include instantaneous or delayed mortality from barotrawnas associated with drastic changes in pressure, acoustic stwming,structural damage to the ilU1er car, and agitation resulting in disroption of behavior. A mitigation ratio of greater than 1: 1 for direct loss of benthic habitat will be required to mitigate for both the direct and indirect loss habitEltand fish life from pile driving. I 6 WDFW does not agree with the conclusions in the submitted documents regarding the negligible impact of the proposed structure for shading effects on epibenthic organisms and macroalgae. For past projects involving ovcrwater structures (once minimized in size), WDFW has accepted a mitigation ratio of 50% of the new overwater structure tO,offset losses for epibenthos and macro algae. Until new research with conclusive results yields information to the contrary, 7 08/07/2002 09:42 31:>03794473 JEFF CO OCD PAGE 04 Mr. Peters August 4, 2002 Page 4 WDFW prefers a conservative approach that gives the benefit of doubt to fish resources and thus will continue to require mitigation for impacts from overwater structures. Although, floats and upper portions of pilings may provide additional substrate that supports . production of some epibenthic zooplankton preferred as prey by juvenile salmonids, these strUctures also provide sUlface area for encrusting communities of mussels and other sessile organisms such as sea stars that prey upon shellfish attacbed to the structures. This predation lesuIts in large depositions of shell hash on the bed near the structures and changes the biotic communities associated with the bed. WDFW has evaluated the application for the proposed marina expansion under RCW 77 .55.1 00 which outlines a clear mitigation sequence of: 1. avoidance of impacts i:~ the highest mitigat\on priority then, 2. minimization of impacts by limiting the degree or magnitude of the action and lastly, 3. compensation of unavoidable impacts through restoration, creation and enhancement or a combination. The goal ofRCW 77.55.100 is no net loss of habitat functions and values and net gain through restoration, creation and enhancement. Since adverse impacts from pile driving and increased overwater structule to subtidal habitat cannot be avoided or minimized sufficiently to achieve no net loss of habitat functions or values, a mitigation plan should be submitted for review by WDFW. Mitigation plan should include the following: . Baseline data . Estimate of impacts . Mitigation measures for the life of the structures . Goals and objectives . Detailed iroplementation plan . Adequate replaCement ratio . . Performance standB1ds to measure whether goals are being reached . Maps and drawings of Pl'Oposal . Operation and maintenance plans (including who will perform) . . Monitoring and evaluation plans (including schedules) . Contingency plans, including corrective actions that will be taken if mitigation does not meet goals and objectives. . Performance bonds, mitigation agreement or other guarantees that the proponent will fulfill mitigation, operation and maintenance, monitoring, and contingency plan. Mitigation measures are an integral part of a construction project and should be completed before or during project construction. WDFW recommends the removal of piling in the vicinity andlor restoration of the lagoon or beach arca by bulkhead/fill removal. I I I \ 8 I I I I I I I I 9. I I I I I I I I I I I I I I I I I I I I I I I I I I I 08/07/2002 09:42 3603794473 JEFF CO DeD PAGE 05 Mr. Peters August 4, 2002 Page 5 Recommendations 1. To protect juvenile salmon residing in nearshore areas, work waterward of the ordinary high water line should not be permitted from February 15 through July 14. 2. Due to the lengthy spawning' period of surf smelt in this portion of Puget Sound, work waterward ofthe ordinary high water line from October 15 through January 31 should not be permitted unless a WDFW representative confirms a lack of spawn during a site inspection. 3. To protect spawning Pacific sand lance, work waterward of the ordinary high water line should not be permitted from October 15 th.rough March 1. 4. Pile driving and new overwater structure will result in a both direct and indirect loss subtidal benthic habitat for epibenthic organisms, bivalves and macroflora. WDFW recommends removal of piling in the vicinity and/or restoration or creation of subtidal. intertidal, or upper intertidal beach or salt marsh habitat as compensatory mitigation. A mitigation plan: should be submitted to WDFW for review. 5. To attenuate the effects of sound pressure waves on fishes from pile driving, n bubble curtain should be required for driving of all in-water piles. To maintain the integrity of the bubble cmtain, no barges, boat traffic, or other structure or equipment should be allowed to penetrate the curtain during pile driving activities. 6. To avoid attracting fishes with lights during nighttime pile driving operations, pile driving should be limited to daylight hours. 7. WDFW is concerned about potential impacts to bed from prop scour and impacts to nearby beaches supporting forage fish spawning from boat wakes. To reduce impacts, WDFW recommends the fuel dock and boat sewage pump be moved to deeper water. 8. Upland storage for kayaks and dinghies should be considered to minimize the need for overwater structures. 9. Environmental review ofthe Marina Expansion as well as the Resort Plan should address potential impacts to all priority habitats and species including but not limited to osprey , and purple martin. ", 08/87/2882 89:42 3G03794473 JEFF CO DCD PAGE 0G cc: SEP A Coordinator, WDFW SEPA Coordinator, Ecology Project Reviewer, USACE Project Reviewer, NMFS Project Reviewer, USFWS DNR Olympic Peninsula Mark Dorsey. Port Ludlow Associates I I I I I I I I I I I I I I I I I I I Mr. Peters August 4, 2002 Page 6 Thank you for the opportunity to provide these comments. If you have any questions, please contact me at (360) 895-6123. Sincerely, J ~ fil,,~ ,/ Pi Randi Thurston Area Habitat Biologist RL T:r1tSP-E7804-03 I I I I I I I I I I I I I I I I I I I State of Washington Department ofFish and Wildlife Letter Dated August 4, 2002 Comment 1: Contrary to information contained in the DSEIS, WDFW has documented spawning by Pacific sand lance and surf smelt on the beaches at or near the project location. Both species. are important components of the diet of chinook and coho salmon, as well as other marine fishes, mammals and birds. Response 1: Pacific sand lance and surfsmelt are recognized in the DSEIS (page 3-25) as spawning within Port Ludlow. However, Mr. Greg Bargmann ofWDFW (personal communications 2000) stated that there were no data indicating that forage fish spawn within the project area, i.e., within the area occupied by the Marina and its proposed expansion. The nearest probable habitat for forage fish spawning is found on the south and east shores of the spit that forms the north entrance to the Bay. Recent forage fish surveys have been conducted that further identify spawning areas in or near Port Ludlow. Those data appear to confirm the information provided in the DSEIS but add new identified spawning areas south of Burner Point and west of the Marina. These newly-identified spawning areas are not within the footprint of any of the alternatives. It is not anticipated that impacts to these spawning areas resulting from Alternative 1 and Alternative 2 will be greater than the impacts identified in the SDEIS. However, impacts to the spawning areas south of Burner Point resulting from Alternative 3, may be greater than identified in the SDEIS (from dredging activities). Comment 2: It appears from the Priority Habitats and Species (PHS) List that the project location is very close to existing osprey and purple martin nesting areas. In addition, the PHS map shows estuarine habitat within Port Ludlow Bay. Although several priority habitats and species were addressed in the SDEIS, these were not. The environmental review should address potential impacts to all priority habitats and species in Port Ludlow Bay and adjacent uplands. Response 2: Avian species known to inhabit the Port Ludlow Bay and the marina area are addressed in the DSEIS Section 3.3.4.1. This information is based on detailed surveys in March and May of 1992 and subsequent incidental observations in 2000 and 2001. No osprey or purple martin were reported in any of those observation periods although the occasional presence of osprey was reported (DSEIS pg 3-28). Purple martin were reported in the PHS data base (DSEIS Appendix D: BE Appendix A) as occupying two boxes in the marina area in 1995. There are no subsequent records of martin use of those boxes and the status of the boxes is unknown. As a conservation measure, the applicant will investigate the location and status of the referenced boxes. If indeed they are (or were) on Marina property, the boxes will either be maintained or replaced. Potential impacts of the four alternatives on all avian species (except bald eagle and marbled murrelets) are described on DSEIS pg 3-29 and would apply equally to osprey and purple martin. In contrast to the nature of the benthic infaunal assemblage that would be lost due to piling placement over a very small area, provision of new piling and floats would greatly increase the substrate available for attachment of epibiota. As noted in the DSEIS, eelgrass occurs within the project area only attached to floats at the waterline (BE Appendix B, Photos 1 and 2). Although not detailed in the DSEIS, these floats also support a rich assemblage of epibenthos including dense aggregations of oysters, mussels, anemones, hydro ids, tunicates, and barnacles. Biomass (biota weight per unit area) of this assemblage greatly exceeds that within the bottom sediments where piles would be driven. Thousands of mussels and oysters occupy each float section in the Marina, and new mussels and oysters that colonize the new floats and pilings will exceed the bivalve biomass lost due to pile placement. Many of the species found on these floats I I I I I I I I I I I I I I I I I I I Comment 3: WDFW supports either Alternative 4 - No Action or Alternative 2 - Deep Water Expansion with additional mitigation. A Hydraulic Project Approval, issued by DFW, will be required. Response 3: Your comment is acknowledged. Comment 4: Additional floatation was installed at the marina this past winter as part of maintenance activities without issuance of the required HP A. Response 4. Your comment is acknowledged. Comment 5: Although Alternative 2 includes mitigating measures, this alternative still has the potential to adversely impact fish resources. Thus additional mitigation measures are needed to achieve no-net-loss of productive capacity of fish and shellfish habitat. Response 5: The Applicant will work with WDFW to develop a mitigation plan that assures no net loss of the productive capacity of fish and shellfish habitat. Comment 6: Pile driving will result in the loss of benthic habitat and shellfish. Impacts from construction include increased turbidity, and an increase in underwater sound pressure waves. A mitigation ratio of greater than 1: 1 for direct loss of benthic habitat will be required to mitigate for the direct and indirect effects of lost habitat and fish life. A mitigation plan is required. Response 6: As noted in the BE (Appendix D to the DSEIS; page 33) installation of95 piling would eliminate less than 30 m2 of soft bottom habitat that likely supports an infaunal assemblage typical of organically enriched low energy bottoms. Over most of the site, and especially in the very soft silt found in all areas deeper than -25 ft MLLW, the dominant bivalves are likely pollution tolerant species such as the very small Axinopsida serricata and the bent-nose clam, Macoma nasuta Only in the shallower water (less than -25ft MLL>>? along the western edge of the diver survey transects (Appendix C to the BE; page 2 - 3) was a somewhat sandier substrate observed that supported a few horse clams (fresus sp.). Thus, the number of potentially commercially or recreationally important bivalves that would be lost to Alternatives 1 - 3 would be very small, less than a few dozen. I I I I I I I I I I I I I I I I I I I support or produce small planktonic organisms (e.g., harpacticoid copepods, barnacle cyprids) that are prey to juvenile salmonids and to forage fish. Very large schools of herring have been present within the Marina during each of two site visits by WDFW representatives and appeared to be feeding on waterborne plankton. In short, it is difficult to identify the loss in habitat and fish life that this comment implies. Comment 7: WDFW does not agree with the conclusions regarding the negligible impact of the proposed structure for shading effects on epibenthic organisms and macroalgae. For past projects, WDFW has accepted a mitigation ratio of 50% ofthe new overwater structure to offset losses for epibenthos and macroalgae. WDFW prefers a conservative approach that gives the benefit of doubt to fish resources. Response 7: As noted in the eelgrass survey (Appendix C to the BE), there is very little macroalgae on the bottom under areas that would be occupied by new marina floats. Low abundance of macroalgae is due to a combination of lack of substantial hard substrates for attachment and to poor light transmissivity in the Bay. No algae were seen at depths greater than -32ft MLL W (it was not reported whether algae at that depth were attached or simply had drifted to the site). Although not measured, it can be assumed that microalgae were more widely present than macroalgae, although their per unit area productivity is likely lower. Because of the narrow width of most project structures, t;lnd because of high suspended particulate lot;lds in the Bay, which scatter and diffuse light under structures, it is uncertain the degree to which algal productivity would actually be reduced by the proposed additional floats. The Applicant is aware that WDFW has recently been requiring 50 percent mitigation where shading impacts depths less than -10ft MLL Wand will work with WDFW to prepare a mitigation plan outlining mitigation for those impacts. Comment 8: Although floats and upper portions of pilings may provide additional substrate for epibenthic zooplankton, these structures also provide surface area for communities that prey upon shellfish attached to the structures. The predation results in large depositions of shell hash on the bed near the structure and changes the biotic communities associated with the bed. Response 8: Accumulation of shell hash over many years can indeed alter the nature of the substrate and the associated benthos around structures. This 'rain' of shell debris is particularly noticeable around piling where tidal action scrapes shells from the piling and where the piling offer a pathway for predators (mostly sea stars) to access epifauna (mostly barnacles and bivalves). Shell material can be expected to build up under floats at much lower rates because often (as at Port Ludlow) the floats are a predator-free zone, inaccessible to sea stars or drills. In organically-enriched areas such as the bed under the Port Ludlow Marina, addition of shell material will add to the habitat diversity and increase the diversity of the associated infauna. Where shell hash builds up above the sediment surface, as it does around very old pilings, it becomes an island of coarse firm substrate surrounded by much softer organically enriched sediments. Such areas support very different biotic assemblages, Comment 9: A mitigation plan should be submitted for review by WDFW. Mitigation measures are an integral part of a construction project and should be completed before or during project construction. WDFW recommends the removal of piling in the vicinity and/or restoration of the lagoon or beach area by bulkhead/fill removal. I I I I I I I I I I I I I I I I I I I for example, small Dungeness crab are known to favor areas of shell covered bottom because the shells offer refuge from predators. In shallow waters relatively free from sea star predation, shell enriched areas can support high densities of little neck clams (protothaca staminea). The applicant agrees that shell accumulations can change the biotic assemblages in localized areas, however, we have found no scientific evidence to show that those changes are adverse to the health of the benthos or fish and shellfish life in general, especially in the context of Port Ludlow. Response 9: The Applicant is committed to working with WDFW to develop a mitigation plan that will fully compensate for adverse impacts to fish or shellfish habitat. I I E-mail Message DATE: July 25, 2002 I TO: Department of Community Development, Att'n: Mr. Josh Peters I cc: Ms Susan Glenn, US Army Corps of Engineers, Messrs. Grant Colby, D.A.Routt and Dr. Paul I RE: Port Ludlow Marina Expansion, Draft SEIS Seattle Trrmi!'~ (E 0 WI ~ ~ trul M 26.. I!lJ FR: William G. Funke 75 Scott Court Port Ludlow JEFFERSON COUNTY DEPT. OF COMMUNITY DEVELOPMENT I I In response to the referenced Marina Expansion, Draft SEIS, I question the validity of the marina expansion map shown in the Draft as Alternative 3. I This Alternative 3 map purports to be the original marina expansion plan considered as part of the 1993 FEIS 100 slip marina expansion approval which. as drawn. shows a shoreline expansion to the West of the existing docks. reaching to and overlapping the current "Scott" docks. I Although the Reid Middleton document of September 17, 2001 lists a 1993 proposal amongst three alternatives, and the County Scoping document of November 30, 2001 lists a 1993 proposal amongst four alternatives, in response to my interest is seeing documentation of the 1993 Marina Expansion FEIS, Mr. Josh Peters advised me there was no record at the County that such a map existed. 1 I Subsequently, I made a thorough search of the complete 1993 FEIS file in storage at the Beach Club without finding any marina expansion map nor a reference to one. I I call attention to this matter because at last fall's marina expansion scoping meeting, Mr. Greg McCarry made the comment that Scott Court residents knew prior to buying our properties that the marina expansion would be built off shore of our Scott Court property. As all Scott residents will attest there is no record of such disclosure. Mr. McCarry's statement was false 2 I I The appearance and inclusion of an Alternative 3 map as part of the Draft SEIS appears to be the Developer's attempt to lay basis and support any claims, as first made by Mr. McCarry, that the unrestricted water view Scott Court properties we purchased from Mr. McCarry were in fact encumbered at the time of sale by prior 1993 County approval for a Marina expansion. I Accordingly, I would appreciate your soonest validation and supporting documentation that the Draft SEIS Alternative 3 map is that plan originally proposed by the Developer and the map specifically considered by the County in the 1993 PElS. I Another issue with respect to the Draft SEIS is that while the Draft SEIS records the Scott Court residents objections to any Marina -Expansion and Marina activity off shore of our Scott Court property, the specific objections I raised in my letter to Mr. Peters relating Pope Resources marketing our lots as water front property and the May 1999 shoreline bank collapse and loss of my shoreline property were not included in the Draft. Accordingly I have included herewith copy of my September 20, 2000 letter on these subjects. 3 I I It is further noted Scott Court residents will be directly impacted by construction noise. 4 I Finally, I will repeat the opinion set forth in my letter to Mr. Josh Peters dated November 1,2001 that the County has violated the intent and requirements of the Port Ludlow Master Planned Resort Ordinance #0- 10-1004-99. specifically: I I Section 3.902, Paragraph 1. "Environmental review of the Resort Plan shall not be piecemealed or broken into small segments" and I Section 3.902. Paragraph 3. "Architectural drawings including a detailed site plan. and architectural sketches or drawings showing approximate elevations. sections. and floor plans are required. however. to ensure that the SEISconsiders proiect-Ievel details.". I Along with Mr. Greg McCarry, then representing Olympic Resources Management division of Pope Resources, I served as one of the County appointed "stakeholders" on the Mediation Group charged with developing these Zoning Ordinances for Port Ludlow. I I I can attest the Resort Development process, as set forth in Section 3.902, was agreed to by all Mediation Group parties and specifically addressed and resolved the previously deadlocked position differences between ORM and Jefferson County. i.e. the Planning Staff and the Planning Commission. with respect to RCW requirements for a "Resort Plan" prior to creating and adopting Ordinances for a Master Planned Resort. I Mr. Josh Peters indicated the County Attorney approved the "piece meal" SEIS study for the Marina Expansion based on existing RCWs relating to shoreline studies. I would again remind the County the County Attorney approved the Resort Ordinances as worded, to specifically codify development requirements in compliance with and beyond those RCWs now used to justify this SEIS variance. I 51 The above-cited Ordinance requirements were formulated and must be followed to evaluate the on -shore impacts of Marina Expansion to the ORM Resort Development conceptual proposals or whatever Port Ludlow Associates now plans, not to the existing Resort area structures and uses. I The ORM Resort Development proposals were presented to the Port Ludlow community and Mediation Group with artist conceptual paintings which illustrated maior planned changes in the areas immediately adiacent to the existing marina. These included an outdoor amphitheater replacing the existing lake. the current marina parking lot area replaced by four single family houses. a new restaurant on the current overflow parking space and an under ground parking facility to be developed upland of the current marina parking area. I I It is noted the ORM artist concept showed the Marina Expansion water ward only out from ORM property only. I It should also be noted that these ORM concepts were used during the Mediation to calculate the Resort Plan development limits as set forth in Ordinance Section 3.901 I For the County to ignore the required Port Ludlow Resort Development EIS process citing convenience of accommodating and scheduling the many involved government agencies party, makes mockery of the Ordinance creation efforts and, in my belief, is an illegal action. I Respectfully submitted, I William G. Funke Attachment: 1 I I I I I I I I I I I I I I I I I I I I I I I COpy William G. & Katherine S. Funke 75 Scott Court September 20, 2000 f5) lE (c lE 0 \Yl ~ ffiI lfU JUl 2 6 2002 lW Port Ludlow, WA 9836 Mr. Josh Peters JEFFERSON COUNTY DEPT. OF COMMUNITY DEVELOPMENT Department of Community Development Jefferson County 621 Sheridan Street Port Townsend, W A 98368 Expansion Re: Port Ludlow Marina Case # SDPOO-00014 Dear Mr. Peters: Further to our discussions concerning the Marina Expansion proposal, my wife and I would like to submit our objections herewith to building any new docks and slips to the west of the existing docks, as proposed by Olympic Property Group (formerly known as Pope Resources). Our Scott Court property was marketed and sold to us by Pope Resources as a premium water front lot with unrestricted water view, not as Marina front property. The planned dock extension will be built off shore to a point immediately adjacentto our extended property line. This dock extension and the resulting re-routing of Marina traffic will completely block our water front view and further subject us to Marina noise and shore incursions detrimental to all Scott Court water front property. " Please note that in May of 1999 an arc shaped section approximately 40 feet by 20 feet of our shoreline bank broke off and slid to the tidal flat. As you can appreciate high tides and wave action combined with rain water drainage create an on going bank erosion process in the Scott Court area. William G. and Katherine S. Funke I I I I I I I I I I I I I I I I I I I We most certainly do not want our property subjected to the additional boat wake action, oil and fuel spills and other intrusions, which will result from moving the current Marina access boat traffic lane to pass immediately off shore of Scott Court properties. You have received objections from our neighbors, Grant and Lori Colby dated September 18,2000. My wife and I fully concur with their concerns and statements and join them in asking that the County deny the proposed Marina Expansion design. A copy of this letter will be sent E-mail to the other government agencies participating in this project evaluation: The DNR, OEP, WDFW and the Corps of Engineers. Again, with all thanks for your information, we are, Very truly yours, I I I I I II I I I I I I I I I I I I I Page I of 1 Josh Peters From: William G. Funke [wgfunke@olypen.com] Sent: Friday, July 26,200212:11 PM To: Josh Peters Cc: Paul Taylor-Smith; DA Routt; Grant Colby; sussan.s.glenn@usace.army.mil Subject: Port Ludlow Marina Expansion Mr. Josh Peters Jefferson County Office of Community Development Josh: In response to your offer to accept comments concerning the Marina Expansion Draft SEIS through today, I have attached herewith to this cover Email my response to this Draft. There is also attached a copy of my memorandum of September 20, 2001, referred to in today's submittal. I have copied Ms. Glenn of the Army Corps of Engineers who also will also accept comment through today. Sincerely, William G. Funke 7/26/02 William Funke E-mail dated July 25, 2002 I I I I I I I I I I I I I I I I I I I Comment 1. Although Alternative 3 - 1993 Design includes a site plan, no site plan for the marina expansion was included as a part of the 1993 EIS or can be found in Jefferson County or Port Ludlow Beach Club files. Response 1. Page 2-7 of the 1993 "Port Ludlow Development Program Final Environmental Impact Statement" describes the proposed marina expansion as follows: "This expansion would provide 1 00 additional slips by extending new docks from existing docks. The new dock configurations would likely be as follows: a T-shaped dock extending 150 feet southward from the easternmost existing dock; an angled L-shaped dock extending 150 feet southward from the western existing dock; and, southwesterly extensions of the three westernmost docks. The total length of the dock extension would be about 1,400 feet, with additional 40 to 50-foot "prongs" defining the slips. Dredging would occur in a slightly less than one acre area near the eastern shore of the Marina in order to increase depths and improve access to the inner docks. The expansion would not involve any breakwaters or other underwater structures. " The drawing shown in this DSEIS as "Alternative 3 - 1993 Design" was prepared from a Peratrovich, Nottingham & Drage, Inc. drawing dated March, 1992, developed as part of a marina expansion study and found in the project files. This drawing is the best representation found of the 1993 text description. It is unknown to what extent this drawing was or was not circulated in 1993. Comment 2. Scott Court residents were not aware of the marina expansion being built off shore ofthe Scott Court properties at the time of their purchase. Response 2. Your comment is acknowledged. Comment 3. Previous objections related to Pope Resources marketing the Scott Court lots as waterfront property and the May 1999 shoreline bank collapse on my property with loss of shoreline property were not addressed in the DSEIS. Increased boat activity may further increase erosion. Response 3. Marketing of the Scott Courts lots is not within the scope of this SEIS. I I I I I I I I I I I I I I I I I I I Regarding the bank collapse, page 3-8 of the DSEIS, states that it is unknown to what extent the previous bank collapse was a result of upland drainage, boat wakes, and/or storm waves. With Marina expansion, additional boat wakes will occur, but are not anticipated to be significant as the Marina is a "no wake zone, " with speeds limited to a maximum of five knots. The new outer docks will reduce wave action, including storm waves, comingfrom Port Ludlow Bay. The reduced wave action may result in a decrease in shoreline erosion shoreward of the new docks. Comment 4. Noise from construction activity will impact the Scott Court residents. Response 4. Construction activity will be limited to non-holiday weekdays and Saturdays from 8:00 a.m. to 8:00 p.m. and restricted by conditions set forth by regulating agencies. Comment 5. The project is violating the Port Ludlow MPR Code which states "Environmental Review of the Resort Plan shall not be piecemealed or broken into small segments" and that architectural drawings or site plans are required for review. Response 5. The discussion of this issue in the SDEIS (pages 1-4 and 1-5) is reprinted below: "In August of 1998, Jefferson County adopted a new comprehensive land use plan that designated the Port Ludlow community as a Master Planned Resort (MPR). Subsequent to the adoption of the Comprehensive Plan, Jefferson County adopted Development Regulations for Port Ludlow Master Planned Resort under Ordinance Number 08-1004-99. The adoption date for the Code was October 1999. Under Section 3.902.1 of Ordinance No. 08-1004-99, a project level SEIS "analyzing the resort plan is required prior to issuance of building permits for any new resort development." Section 3.902.6 similarly provides, "Actual resort development may be undertaken in phases, but only following completion of review and approval of a full resort buildout plan through the SEIS process." A key element of the SEIS is to compare the change in cumulative development impact between the permitted plan of Ludlow Bay Village to proposed changes for any new resort components. Jefferson County will issue a land use or building permit for the Marina expansion only after a project level SEIS for the Resort at Ludlow Bay is complete. That SEIS must address the cumulative impacts of both the Resort and Marina Expansion. For a variety of reasons, the applicant (PLA) has formally requested that Jefferson County allow the preparation of an SEIS for the Marina separate There are two separate issues related to a "phased" review of this project. On the one hand, Section 3.902 of the MPR ordinance provides, "Environmental review of the Resort Plan shall not be piecemealed or broken into small segments." Based upon this language, the County is authorized to require only a single review of the project, however, the State Environmental Policy Act clearly authorizes the phased review of land use approvals. This process is described in Section 1.5 below. Jefferson County has agreed to allow the applicant to proceed with separate review of the Marina and the Resort with the clear understanding that no land use permits or building permits will be issued for the Marina Project until a Resort SEIS process (including cumulative impacts) is complete. " I I I I I I I I I I I I I I I I I I I from an SEIS for the Resort. The elements of the two reports would then be combined into one overall project SEIS to meet the conditions of Section 3.902 as described above. The reasons for the request follow: . The Marina expansion EIS requires multi-agency review with the DNR, Washington Department ofFish and Wildlife (WDFW), u.s. Army Corps of Engineers (CaE), National Marine Fisheries Service (NMFS), and U.S. Fish and Wildlife Service (USFWS), all having some level of jurisdiction over the expansion proposal. These agencies have little if no review authority over the upland Resort development plans. . Although the Marina expansion project is part of the Resort plan, it is not an interdependent part of the Resort plan and does not depend on the Resort plan as its justification or for its implementation (~ee WAC 197-11- 060(3) (b)(ii)). I I I I I I I I I I I I I I I I I I I Josh Peters From: Mo-chi Zoe Lindblad Sent: Monday, July 29, 20027:30 AM To: Josh Peters Subject: FW: SDPOO-00014 Page 1 of I JUl 2. 9 2002 JEfFERSON~~0~~UOPMEN1 DEPT. OF COMMU -----Original Message----- From: Bill Master [mailto:master@olympus.net] Sent: Saturday, July 27,20029:03 PM To: Mo-chi Zoe Lindblad Subject: SDPOO-00014 My wife and I live at 10 Heron Road, immediately to the east of the Heron Beach Inn. We currently rent space at the marina. We have reviewed the various alternatives for the expansion of the Port Ludlow Marina (SDPOO-00014). As the alternatives in the EIS now stand, we are definitly in favor of alternative 4; "no change". We don't believe that 100 additional slips are needed. In alternative 2, 100 additional slips force the docks out beyond Burner Point and creates a huge mass of boats, way out of proportion to the size of the bay, and destroying the tranquility of the area. This is a residential area, not some sort of industrialized waterfront. Alternative 3 obviously conflicts with the dock belonging to the residents of Scott Court. We don't believe that dredging for slips immediately adjacent to the Inn makes any sense at all. Alternative 1 makes some sense, but only for a smaller number of slips; certainly no more than 50 additional slips, preferably 30, or less. We would support alternative 1, but only if it called for 50 slips, or less. As the EIS now reads, we strongly favor alternative number 4. Alternative 4 retains the rural character of the area, as it currently exists. 100 additional slips is way over the top, and drastically alters the nature of the bay. Thank you for your consideration. Bill & Judy Master 10 Heron Road Port Ludlow 7/29/02 I 1 12 J 3 14 15 Bill Master E-mail dated July 27, 2002 I I I I I I I I I I I I I I I I I I I Comment 1. Weare in favor of Alternative 4 - "No Change"; we do not believe that a 100 slip expansion of the marina is needed. Response 1. The 100-slip expansion was identified as part of the redevelopment program in the 1993 "Port Ludlow Development Program EIS." Section 3.901-Resort Uses of the Port Ludlow MPR Ordinance No. 08-1-1004-99, identifies the 100-slip expansion as the maximum allowed unless a major revision to the Resort Plan is approved. Comment 2. The Deep Water Alternative forces the docks out beyond Burner Point and creates a mass of boats out of proportion to the size of the Bay and destroys the tranquility of the area. Response 2. A view analysis from Burner Point has been completed and is included in Section 3.6 of this FSEIS. Comment 3. Alternative 3 conflicts with the Scott Court dock and nearshore dredging adj acent to the Inn does not make sense. Response 3. Your comment is acknowledged. Comment 4. Alternative 1 makes sense with a smaller number of slips - 50 slips or less (preferably 30). Response 4. Your comment is acknowledged. Comment 5. As the EIS now reads, we strongly favor Alternative 4 which retains the rural character of the area. Response 5. Your comment is acknowledged. I I I I I I I I I I I I I I I I I I I ./ -Original Message----- From: Scott Gibson (moilto:SGibson@BurkeGibsonlnc.cnrnl Sent: Monday, July 29,20023:21 PM To: Josh Peters SUbject: case SDPOO-00014 1\!1\f ["-I'-I-In I'~ S"O."I (::',ifb","r-l (I' ,,- I I hr" ',e; (I .,inl-'c. ,-.e 1" i .-, 1.-'" C'.-,., 111._. -...., __ 1,-"" ....J-J 1,__. 11,_t~_"_lt......I,-I'__'~ll 1__1 _' ._,1,_ _I" _,_.1 Ludlow. I would like to let you know that I feel the some os the Joseph's in regards to the expansion of the marino. I would like it done, so that it does not interfere with my view. There ore other ways to do it. I read their memo and it covers the points that I hod problems with the expansion, This needs to be brought to some one's attention that us homeowner's are sensitive to this expansion plan of the marina and how it is accomplished. 1 If you have any questions, please feel free to call me at: 253-735-4444 Scott Gibson E-mail dated July 29, 2002 I I I I I I I I I I I I I I I I I I I Comment 1. I concur with all the comments that were made by Peter Joseph. I would like the expansion done so it does not interfere with my view. Response 1. Please see responses to Peter Joseph's comments. II II II I II II I Josh Peters From: Sent: To: Subject: Mo-chi Zoe Lindblad Monday, July 29, 2002 11 :50 AM Josh Peters; 'Ikeenan@reidmidd.com' FW: SDPOO-00014 -----Original Message----- From: Jeanne & Peter Joseph [mailto:jjadv@olympus.net] Sent: Monday, July 29, 2002 11:07 AM To: Mo-chi Zoe Lindblad Subject: SDPOO-00014 To: Josh Peters From: Peter Joseph Date: July 27, 2002 II Re: Case # SDPOO-00014 Having just gone through the Draft SEIS for the Port Ludlow Marina Expansion, I would like to make the following comments. II II II I I I II I I II II I attended the scoping meeting held at the Bay club last Fall, and had no objection to what was being proposed at that time, even though I have never felt that they needed an additional 100 slips.There has never been any justification to support that number, and no one has been able to tell me how the 100 slip number was determined. 1 At the scoping meeting, which centered around Scott Court, the deep water option, option two, was not one of the alternatives.I knew that the 1993 plan, option three was D.O.A. due to the need to dredge contaminated soils. Now I read that option 2 would extend "A. dock 270' to the south. This extension would completely block the view of the harbor looking WSW from the 7 townhouses located on Burner point. Under Para. 3.6 "Anesthetics/ Visual Quality., the preparer of the SEIS failed to select the townhouses as a key view or observation point, even though more homes were affected than were located on Scott Court Had he done so and created the simulated photograph like he did for the other three viewpoints, it would be obvious that the extension would block our view. The view is a million dollar view, and is perhaps one of the most spectacular views in all of Jefferson County as you look down the harbor and see the Olympic Mountains in the background. A more aesthetic view than that of Scott Court. I consider the extension of A dock in option 2 to interfere with my rights as an adjacent property owner. It will definitely affect the value of my home. 2 As a person who has spent most of can also point out some practical mention the expense his adult life along the waterfront, I problems to this option, not to associated with construction in such deep water. As the 1 preparer notes on page 3-47, para 3.6.1, 3rd para.,when talking about Burner Point "....but also due to the nature of less protected and windy promontory conditions...". The prevailing winter winds in this harbor are from the SSE. While Burner Point provides some lee to A dock when the wind is out of this direction, the extension will be fully exposed which will create significant problems for both the docks and boats moored on the extension. There are usually several instances each winter when the winds exceed 40 knots with gust exceeding 50 knots. I have witnessed the present outer wave wall on A dock move up and down as much 3-4 feet due to wave action. The proposed extension would 'be more exposed because it extends southward of Burner Point and will feel the full force of both the wind and seas, and I believe the probability of severe damage to both the docks and boats will increase significantly. My boat has been moored on the outer part of A dock for the last 6 years, and I have spent many hours down there ensuring that the boat is properly secured as well as assisting other boats whose owners are absent from the area. From an environmental point of view, I think this extension would have an adverse impact on the ability of the harbor to flush itself. Even the existing marina entraps a good deal of flotsam which not only creates an unsightly appearance, but also causes anoxia and ulvoid blooms. Also the extension would put large close to the Burner area of beach critical part As the proposed slips for the "AN dock expansion are designed for larger boats, a commensurate increase in gray water can be expected which will ultimately flow along the beach tidal line. There are also oysters and clams located within the inter-tidal zone. Also the occasional, but potentially devastating oil/fuel spills must be considered. A recent study concluded that recreational boats petroleum products as was spilled spills were pretty much contained As the eastern shoreline of the boat basin is already polluted from years of previous spills, the relative effect harmful as small spills further out beach at Burner Point as well as the Admiralty Inlet. boats with their gray water discharge very Point Beach where the 1993 EIS highlighted this specific as a sand lance spawning area which, as you know, is a of the food chain for the salmon; still an ESA species. annually spill three times as much by the Exxon Valdez. Previously, fuel in the boat basin near the fuel dock. of spills in this area is not as A dock that might contaminate the pristine shoreline leading out to In closing, I feel the best solution is a compromise by building out a lesser number of slips that would allow the marina to expand to accommodate the additional Port Ludlow residents which is capped at 2250 homes, but not to such an extent that it overwhelms and destroys an absolutely beautiful harbor and its associated views regardless of the viewpoint. With the exception of the long summer weekends, the present A dock almost always has a high vacancy rate throughout the year. The thirty or so underutilized slips, as well as the side ties on the outer wave wall, along with 50-60 additional slips should provide this area with sufficient moorage for 2 I I I 3 I I I I I 4 I I 5 I I I 6 I I I ""7 I I I I I I the foreseeable future. Currently there is one slip for every 8 homes in Port Ludlow. If 400 homes are to be built out before PLA hits the 2250 cap and then leaves the area, there should only be a need for 50 more slips. The Marina would still have an additional 50-60 guest moorage slips and side ties; far more than most marinas. Given that the present marina tenants are being used to fund the expansion through increased moorage rates and converting the marina into private memberships, they will be grateful for not having to fund deep water pile driving. I I I I My qualifications for making these comments are based upon my maritime background including 25 years service in the Coast Guard, a Masters' Degree in Coastal Zone Management, a licensed master mariner , Past Commodore of the Port Ludlow Yacht Club, a long time boat owner, as well as a full time resident on Burner Point for the last six years. I If you would like to discuss this matter further, I am at your disposal. I I I I I I I I I I I I 3 Peter Joseph E-mail dated July 29, 2002 I I I I I I I I I I I I I I I I I I I Comment 1. Expansion of the marina by 100 slips is not necessary and there is no justification to support the need for this number of slips. Response 1. Please see Response 1 to Bill Master's comments. Comment 2. The Deep Water Alternative was not presented at the Scoping Meeting and views from Burner Point were not addressed in the DSEIS. The Deep Water Alternative would significantly impacts views from the seven townhouses located on Burner Point and affect the value of my home. Response 2. Please see Response 2 to Bill Master's comments. Comment 3. The southward dock extension a~ proposed in Alternative 3 - Deep Water Alternative will be fully exposed and result in increased exposure to wind and wave action which may cause damage to the boats and docks. A-Dock already moves as much as 3 - 4 feet up and down due to wave action. Response 3. All outer southern docks will be designed as floating breakwaters similar to the existing floating breakwaters. The Deep Water Alternative has greater exposure to wind and wave action from the southeast and east, around Burner Point. However, the design of the outer floats will be such as to withstand wave action. Comment 4. The Deep Water Alternative would decrease the rate of flushing within Port Ludlow Bay. Even the existing marina entraps flotsam. Response 4. Flushing of Port Ludlow Bay is a result of tidal actions and will not be affectedby the southward extension of the docks as proposed in Alternative 3. The extension will however, trap floating debris which will be periodically removed by marina staff. Comment 5. Gray water discharge from boats docked on the southward extension as shown in Alternative 3 will impact beaches on Burner Point, including a sand lance spawning area. Response 5. Your comment is acknowledged. As noted in Section 1.8 of the FSEIS, the State of Washington Department of Natural Resources has recently issued I I I I I I I I I I I I I I I I I I I new Rules that include the issue of gray water discharge. The Port Ludlow Marina BMPsIMarina Standards are consistent with the new DNR Rules. Current information from the Washington State Department of Fish and Wildlife (WDFW) indicates that the nearest probable habitat for forage fish (including sand lance) is found on the south and east shores of Burner Point. See also, Response 1 to the Washington State Department ofFish and Wildlife. Comment 6. Oil spills from the boats will contaminate the beaches at Burner Point. Previously, fuel spills were contained in the boat basin near the fuel dock. Response 6. The location of the fuel float will remain unchanged in all alternatives. Fuel spills, if any, would be limited to the area of the fueling float, where a hazardous material spill kit and response plans are in place. Discharge of bilge water, which could occur at the docks, is prohibited by the Marina BMPs. Comment 7. The expansion should not overwhelm and destroy an absolutely beautiful harbor. An additional 50-60 slips should provide sufficient moorage to meet foreseeable future demands, based on the total cap of 2250 homes for the Port Ludlow community. Response 7. Please see Response 1 to Bill Master's comments. I I I I October 12,2001 I Mr. Josh Peters Department of Community Development Development Review Division Jefferson County 621 Sheridan Street Port Townsend, W A 98368 I I RE: Application SDPoo-OOO14 I Dear Mr. Peters: We are writing to convey our concerns regarding the Draft Supplemental EIS. I We submit the following list (in no preference or order) for review and consideration with regards to the Draft Supplemental SEIS: I 1) Currently the PL Marina has no official requirement of merit for "liveaboards" to use the pump-out facilities instead of simply pumping wastewater overboard. It is abundantly apparent that current residents of the marina who live aboard their' boats do not follow any guidelines - one only has to "walk the docks" in the early evening or morning to witness black water discharge. Their proposed plan to require once a month pump out is too infrequent to have any merit. As a long term Iiveaboard at Shilshole I can attest that our once a week service by a professional pump out service is required. 2) The Draft SEIS does provide documentation to the negative impact Alternate 1 has to the view of land owners on Scott Court. Our rights should take precedence over the views of anyone driving on Oak Bay Road. 3) There is NO comment or analysis to the riparian rights we posses with regards to access to our dock, nor does the document provide any information about our ability to bring a float plane up to our dock. With Alternate 1, we lose this ability - permanently. . 4) Alternate 1 takes away any future opportunity to expand our dock out to accommodate a larger vessel. The document does not address our rights with regard to future plans. 5) The Draft SEIS does not address any apparent need for expansion - currently (through July 2002), there has only been one weekend when it appears the marina was full for transient moorage and PL Marina personnel attest to a short (40 boats) waiting list. I I I I We remain steadfast that any expansion of the Port Ludlow Marina should be south of the current location, not west. I Thank you. I Respectfully, SENT VIA EMAIL I Grant and Lori Colby 47 Scott Court Port Ludlow, W A I Mailing address: PMB 526 I .. I '" L '" V A q 5 2442 NW Market Seattle. W A 98004 I I I I I I I I I I I I I I I I I I I Cc: Mr. and Mrs. Funke Mr. Paul Taylor-Smith Mr. and Mrs. Routt I I Josh Peters From: Sent: To: Subject: Colby, Grant [gcolby@sodexhoUSA.comj Tuesday, July 30, 2002 9:48 AM Josh Peters Draft SEIS '~ ~ A~G ~ ::2~ '~ I I . draft_-l.doc JEFFERSON COUNTY 1 DEPT. OF COMMUNITY DEVELOPMENT I I in Josh - attached are my comments on the Draft SEIS and the project general. Grant I Reply Separator I Subject: RE: Scoping Document for the PL Marina Expansion Author: "Josh Peters" <SMTP:jpeters@co.jefferson.wa.us> at BUFFALO Date: 12/03/2001 6:44 PM Done. I -----Original Message----_ From: Colby, Grant (mailto:gcolby@sodexhoUSA.com) Sent: Monday, December 03, 2001 11:14 AM To: "Josh Peters" Subject: RE: Scoping Document for the PL Marina Expansion I I a Thanks Josh, I was not in attendance that day, if you could mail me I copy of the 1993 design I would appreciate it. Grant I Reply Separator I Subject: RE: Scoping Document for the PL Marina Expansion Author: "Josh Peters" <SMTP:jpeters@co.jefferson.wa.us> at BUFFALO Date: 12/03/2001 4:18 PM Hello Grant: I I The only item we have on file that pertains to the 1993 design is a one-page, II" x 17" design that, I believe, was shown at the public scoping meeting at the Bay Club. It's not a problem to send you that design. Let me know if you already have it (i.e., you got a copy that day directly from the applicant) . I I I When the DSEIS is issued, there will be more information, description, and analysis available pertaining to that option, as part of the DSEIS. 1 Regards, Josh I -----Original Message----- From: Colby, Grant [mailto:gcolby@sodexhoUSA.com] Sent: Monday, December 03, 2001 10:02 AM To: "Josh Peters" Subject: Scoping Document for the PL Marina Expansion I I I Josh - I received the document over the weekend and have read through it. On the second page in the discussion about alternatives it lists the four. ...how do I get a copy of the alternate design #3 from 1993? I Is this something I can request of the County? I Grant Colby PMB 526 2442 NW Market Seattle, WA 97108 I Thanks. I 46 Scott Court Port Ludlow, WA 98107 I I I I I I I I I I 2 I I I I I I I I I I I I I I I I I I I I Grant Colby Letter attached to e-mail dated July 30, 2002 Comment 1. Currently, the Port Ludlow Marina has no official requirement of merit for liveaboards to use the pump-out facilities instead of simply pumping wastewater overboard. It is abundantly apparent that current residents of the Marina who live aboard their boats do not follow any guidelines - one only has to "walk the docks" in the early evening or morning to witness black water discharge. The proposed plan to require once a month pump-out is too infrequent to have any merit. As a long-term liveaboard at Shilshole, I can attest that once a week service by a professional pump out service was required. Response 1. As noted on page 3-9 of the DSEIS, discharge of black water is illegal and prohibited within the Port Ludlow Marina. Enforcement of this regulation is an on-going concern of Marina staff, Port Ludlow Associates, and members of the Marina. Any live-aboard found to be in violation of this regulation will be evicted. To facilitate sewage pump-out, one new portable pump-out facility has been purchased and an additional portable pump-out facility will be purchased as part of the expansion. The sewage pump-out at the fuel dock will remain. The need for pump-outs is dependent upon the size of the individual boat's holding tank and the extent to which the occupants use land-side facilities. The Shilshole Marina, referenced above, requires pump-outs on a quarterly basis. Comment 2. Negative impacts to views from Scott Court should take precedence over views from Oak Bay Road. Response 2. Your comment is acknowledged. Comment 3. Boat and float plane access to the private dock for Scott Court will be permanently lost by the Alternative 1 design. Response 3. As noted on page 3-27 of the SDEIS, the U.s. Army Corps of Engineers publishes a manual "Environmental Engineeringfor Small Boat Basins" to guide the design of small marinas. The required minimum fairway width for a 60-foot boat would be 90 - 105 feet. The shortest distance between The most desirable taxi channel per the FAA Circular is one that provides direct access to onshore facilities and into the prevailing wind. The prevailing wind in this area is generally from north to south. The taxi channel to the Scott dock is generally in a north-south orientation. Float plane access to the Scott dock is not likely to be impacted by the expansion of the Marina. I I I I I I I I I I I I I I I I I I I the Scott Court dock and the proposed dock extension (D-Dock) for Alternative 1 is approximately 125 feet, assuming side ties present at both docks. The recommended minimum taxi channel width for float planes is 125 feet per FAA Advisory Circular for Seaplane Bases, AC No: 150/5395-1. The shortest distance between the Scott Court dock and the proposed Alternative 1 dock extension is approximately 125 feet. This assumes a side-tie at both the Port Ludlow dock and the Scott dock. Comment 4. Alternative 1 wi11limit future possibilities for the Scott Court dock to accommodate a larger vessel. Response 4. At present, the Scott Court dock is designed for boats approximately 50 feet in length or smaller; however, the design can accommodate boats up to 60 feet in length. To expand the dock to accommodate boats 60 feet in length or greater, the fingers require extension and the slip width must be increased. The Port Ludlow Marina dock extensions proposed in Alternative 1, provide sufficient room to expand the Scott Court dock to accommodate boats 60 feet in length or greater in accordance with standard marina design principles. Comment 5. The DSEIS does not address the need for a 100 slip expansion. Response 5. Please refer to Response 1 to Peter Joseph. 08/05/02 17:02 FA! 2062449886 FATIGUE TECH @ 0011001 I I I I Approved by FACSIMILE lRANS!vfISSION Phone: Fax: (206) 246-2010 (206) 244-9886 401 Andover Park East Seattl~ W A USA I TO; Jefferson County Department of Community Development DATE: ATTN: Josh D. Peters, Associate Planner FAX #; I FROM: Burke F. Gibson PHONE #: SUBJ: Port Ludlow Marina Expansion PAGE 1 OF: 98188-7605 August 5, 2002 (360) 379-4473 (360) 379-4466 1 I I believe you recently received a letter from P_ Joseph of Port Ludlow coucOming the expansion of the marina. I concur with his letter a hundred percent and support his ideas. , I My townhouse is at 24 Heron Road, Port Ludlow. I can be reached at (425) 641-4455 or at the address below: 1 I Burke F. Gibson 89 Ca'icade Key 1~;2Z:- IBurke F. Gibson I I I I I I 'E MESSAGE IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENlTIY TO WHOM IT IS ADDRESSED AND MAY CONTAIN . ORMA TJON THAT IS PRlVII..EGED, CONFIDENTIAL AND EXEMPT FROM DISCLOSURE UNDER APPUCABLE LAW. lfthe reader of this message is ! t tfJc intended recipiClIt, you ate hueby notified tl1at lI.lly dissemination, distribution Or copying of this COltlmuDication is strictly prohibited. If you have m::cived this informatioo in error, please noti1y tIS immediately by ldcphonc, Tbank you. I Burke Gibson Fax transmission dated August 5, 2002 I I I I I I I I I I I I I I I I I I I Comment 1. I concur with the comments made by Peter Joseph. Response 1. Please see responses to Peter Joseph's comments.