HomeMy WebLinkAboutLog059
.....
..
I'
i '
'Lu . " I ,
" ,
. -
I ~'" ..,,",","~
COpy
Laurence H. Nobles. 81 Harms Lane
Port Ludlow, W A · 98365
(360) " ~37- 16/.5
/no.6/es@ca.J/'f/ee'!'co1'tt
August 1, 2003
LOG \TEM
# Sc\
page _ 1 of...5-"
Mr. Al Scalf, Director
Jefferson County Department of CoImnunity Developnent
621 Sheridan Road
Port Townsend, WA 98368
Dear Al,
The Port Ludlow Village Council has subnitted a statement regarding the
scoping of the Environmental Impact Statement for the MPR-RC/CF Zone in the Port
Ludlow MFR. I wanted to call your attention personally to three questions raised
in the stmllary of our statement that are not strictly related to scoping of the
EIS.
(1) Can the lot designations stipulated in the 1993 approved plan for the
Ludlow Bay Village developnent be changed without further County approval?
(2) Are certain of the platted lots in Ludlow Bay Village that lie
partially within the lagoon actually buildable lots? If buildable, is
permission required from the Department of Ecology, Fish and Wildlife, or
other responsible environmental agencies?
( 3) Can the Port Ludlow conununi ty be assured that Jefferson County will
finally enforce the conditions that were set down in the 1993 Shoreline
Substantial Developnent permit and will the Connty monitor and insist on
compliance with any new conditions imposed upon the current proposal?
We would very much appreciate it if your Department could research these
questions and provide us with timely answers . They are of vi tal concern to us
as we address the proposal for the final build-out of the MPR-RC/CF Zone.
We will look forward to your answers.
~~~~::~~
~
~
JEFFERSON COUNTY
DEPT. OF COMMUNITY DEVELOPMENT
'.
F>OR'T'
LUDI~OW VI LLAGE~
CC)l.JNC: I L
July 31, 2003
,Jefferson Cmmty Department of Cormnuni ty Development
Development Review Division
621 Sheridan Street
Port TO,^,'l1send, WA 98368
RE: Environmental Impact Statement Scoping MLA03-00360
The Port Ludlow Village Council and its Cormnunity Development Cormnittee
have carefully reviewed. the new plans submitted. by Port Ludlow Associates LLC:
for development of the Resort Complex/Corrmunity Facilities Zone (MPR-RCjCF) as
defined by the Port Ludlow Master Planned Resort Code under Ordinance No: 08-
1004-99 which was effective October 4, 1999. The Council is generally supportive
of the development now being done by PhA in Port Ludlow and we also feel stongly
that further development of the Resort Complex is in the best interests of the
entire Port Ludlow Cormnuni ty . Our review, however, has turned. up several very
significant concerns that must be addressed. in the Supplemental Environmental
Impact Statement and resolved between PLA, the Port Ludlow Cormnuni ty, and the
Count;;' before this project should be allowed. to proceed.
The proposal includes two somewhat separate areas within the MPR-RC/CF
Zone: (1) The area of Ludlow Bay Village, platted. in 1993; and (2) the proposed.
condominium complex at the north end of the Zone cormnonly referred to as
"Admiralty III".
LUDLOW BAY VILLAGE AREA
Density
In August, 1991 Pope Resources applied. for a Shoreline Substantial
Development Permit for this area which proposed. building a 36 room Inn, 32 single
family residences, and 58 attached. single family residences--a total of 90
residential units. The Port Ludlow cormnuni ty reacted strongly in protesting the
densi ty of this development. The Port Ludlow Cormnuni ty Council initially was
vigorous in its opposition to the project and nearly 300 let,ters of protest were
wri tten by members of the Cormnuni ty . A draft EIS was published. in October, 1992
proposing a 36 room Inn and 72 residential units (23 single-family and 49
multifamily). An alternative in the draft EIS was Reduced Residential Density,
specifically a 36 room Inn and 56 residential units (16 single family and 40
multifamily). The Shoreline Permit of May 11, 1993 and the final approved. plat
authorized the Inn and 58 residential units (5 detached. single family residences
and 53 attached single family residences in 14 multi-unit structures).
It should be made clear that the pro:rx:>sed Alternative 2 - 1993 Port Ludlow
Resort Plan authorizes only 58 residential units within the Ludlow Bay Village
boundaries. We believe that the current proposed density, which is 32 residental
uni ts larger than this, is excessive (for all of the reasons pointed out by
residents of the Cormnunity in 1993) and should not be allowed.
July 31,2003
Page 2
Zonin!r
The 1999 MPR Code is not clear as to the usage of specific parcels wi thin
the HPR-RC/CF zone. PLA is proposing to build this project entirely within the
confines of lots that were platted and approved in the 1993 Resort Plan. The
plat now containing the Harborm.aster Restaurant, designated in 1993 as
Corrnnercial, is proposed for residential housing. The proposed Recreation Center
is partially on a lot now designated as Single Family. We are told that the
proposed new housing will be built as condominiums on lots now designated for
fee simple town homes. Do these changes require re-zoning or simply replatting?
Buildable Lots
Recent aerial photography indicates that a significant number of the lots
platted in the 1993 plan intrude onto the lagoon and may not be buildable.
Therefore they have been granted reduced assessments by the Jefferson County
Assessor. If they are indeed not buildable, how does this affect the overall
plan? If they are deemed to be buildable does this not require a permit from
the Washington Department of Ecology and other environmental-related
authorities?
Parkil1J;!
By moving the corrnnercial center of the development to the western portion
of the property PLA is concentrating the Marina ( expanded by 100 slips and with
its new office and store), the new restaurant, meeting facilities, possible space
for the Port Ludlow Yacht Club, and its proposed Recreation Center all into the
same area. This could pose an intolerable burden on parking in this area. Can
a plan be devised to accomodate sufficient nearby surface parking for all of
these facilities or will it be necessary to build a parking structure?
Traffic
The 1993 EIS addresses the external and regional aspects of the potential
traffic generated by the development, but it does not consider the traffic
pattern within the development, which has already proven to be a matter of
concern. Traffic exi ting from the Inn tends to use Heron Drive where the garages
of newly-built townhomes are only a few feet from the paved drive. The internal
traffic pattern of the development needs a thorough re-study.
Resort Operation
It is not yet clear whet,her PLA intends to operate the Resort as a 37 room
Inn, Marina, Restaurant and Recreation Center or whether it intends to expand
the total room base by managing a short-term rental pool for the condominium
units similar to the one formerly operated for the Admiralty I and II condos.
These t>wo scenarios pose somewhat different problems for both parking and traffic
and both should be examined in the SEIS. It should be noted that the current
room base for the resort already includes 14 rooms in the Admiralty condos.
"
July 31, 2003
Page 3
Beach Access
The 1993 Shoreline Conditional Use Permit #1993-14647 granted by the
Department of Ecology contained the following conditions: "A public access plan
shall by tendered for review and approved by Jefferson County and Ecology for
the easement on tracts A, C, and M1. Said plan shall detail the width and
location of proposed easement, plus document how public use will be facilitated,
including hours of availability and designated pulic parking, plus visual
screening from adjacent private property. Public access launch site at marina
for kayaks and other small craft shall also be described in this plan." A sketch
map of approved beach access }X)ints and signage required was included in the EIS.
A comparable beach access plan should be required in the supplemental EIS and
should be enforced by the County.
Stormwater Plan
The area of Ludlow Bay Village is now part of the Port Ludlow Drainage
District. All stormwater plans will have to be approved by that body. We are
particularly concerned about runoff into the lagoon and Ludlow Bay. Significant
recent anecdotal information seems to indicate a marked deterioration of the
near-shore environment in the Bay.
LEV 1993 Concerns
Residents of Ludlow Bay Village and others in the Community have ex-pressed
concern that some of the conditions that were set down in the 1993 Shoreline
Development Permit have never been met and that Jefferson County has been lax
in enforcing these conditions. As long ago as Nay, 1993 the Greater Port Ludlow
COIIlll1unitJ'~ Council warned in a letter to the County that "Pope Resources record
of compliance wi th shoreline permits has not been satisfactory." It also noted
that "Past monitoring efforts seem to have been quite inadequate...". The County
Plarming Department's only reply was to note "The limitation of County staffing
which precludes making frequent interim site inspections of permitted projects
"
How can we assure that the County will move expeditiously to enforce not
only the 1993 conditions, but any new conditions that are set down during
approval of the present pro}X)sal?
Lan d sca pinJ;f
One of the four "Sponsor's Stated Objectives" in the 1993 EIS was to
"Restore the shoreline landscaping and adjacent }X)nd to a more natural character
us ing wetland plants and beach and dune grasses. " The landscaping requirements
around the lagoon were spelled out in detail in the 1993 permit but were never
carried out. How can we insure that the area will be landscaped so as to be
invi ting to birds and other wildlife and also be a visual and recreational asset
to the entire Community?
r.
. ~
July 31, 2003
Page 4
ADMIR~TY III AREA
Storm water
Our concerns here as the same as those outlined for the LBVarea. Adequate
retention ponds and other facilities must be designed to limit runoff into Ludlow
Bay.
Traffic
The proposed exit from the Admiralty III condos onto Oak Bay Road should
probably be relocated so as to minimize the impact, on residences to the west.
Maintenance Facilit:v
Section 3.901 of the MPR Code permits Support BuildingslMaintenance,
Warehousing, Housekeeping) wi thin the MPR-RCjCF zone. How can we be assured that
the proposed Maintenance Facilty will be restricted to support of the Resort and
not be used for heavy, and noisy, equipment working for PLA throughout Port
Ludlow?
SlJMr'l<\RY
The Port Ludlow Village Council is supportive of the proposal to build
corrnnercial facilities at the western edge of the Ludlow Bay Village area provided
that the serious parking problems can be solved adequately. We are, however,
strongly opposed to any residential density greater than the 58 units approved
in the 1993 plan.
We also need answers from Jefferson County to three critical questions
raised above:
( 1) Can the lot designations stipulated in the 1993 plan be changed without
further County approval?
(2) Can certain of the platted lots that lie partially within the lagoon
be built on wi thout approval of the Department of Ecology, Fish and
Wildlife, etc?
l 3) Can we be assured that the County will enforce both the 1993 conditions
and any new condi tions set down during approval of the current proposal?
SinCerelY~\ ~ ~_ ~, \
~~~
Port Ludlow Village Council