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Date: January 13. 2004
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FROM: Marco de Sa e Silva
TELEPHONE: (206) 628-7766
FAX: (206) 628-7699
SEND TO:
NAME
David Alvarez
Greg McCarry
Mark Dorsey
AI Scalf, Director
Jeffrey B. Taraday
FIRM/COMPANY/CONFIRMATION NO.
FAX NUMBER
Jefferson County Prosecuting
Attorney's Office
360 385-9219
Port Ludlow Associates
360 437-2101
Jefferson County Community
Development
360 379-4450
Foster Pepper & Shefelman
206447-2690
360385-9186
360437-2522
360 379-4451
206749-2193
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2600 CENTURY SQUARE
1501 FOURTH ",VENUE
SEA l'Tl.E, WA 981(H-1688
Tin. (206) 62:2.;'>150
FAX pOti) (.28-7699
www.d.Wt.com
January 13, 2004
Via Facsimile No_ 360385-9186
and First Class Mail
David Alvarez
Prosecuting Atiomey's Office
Jefferson County
P.O. Box 1220
Port Townsend, W A 98268
Re: Ludlow Bay Village Plat Alteration
Dear Mr. Alvarez:
I represent Port Ludlow Associates LLc. T am writing in response to the letter dated January 6,
2004, from Jeffrey B. Taraday to Al Scalf and you regarding my client's proposed alteration of
the plat of Ludlow Bay Village. Mr. Taraday claims that the proposed plat alteration violates
RCW 58.17.215 because it allegedly would result in the violation of restrictive covenants filed at
the time of the original approval of the plat Mr. Taraday claims, in particular, that the proposed
plat alteration conflicts with an alleged resjdential density limit and with alleged single family
and town home use restrictions in the original plat and master declaration.
For the reasons set forth below, I believe that Mr. Taraday is mistaken. If you agree with my
analysis of the issues, then I respectfully request that you direct Mr. Scalfto notify Mr. Taraday
that Jefferson County has detennined that he has not shown that the proposed plat alteration
would result in the violation of a restrictive covenant
1. Background. The original plat of Ludlow Bay Village was recorded on June 6, 1994, in
Volume 6 of Plats, pages 228 to 233 (the "Plat"). The Plat has not yet been altered or amended.
At the time the Plat was approved, restrictive covenants were filed in the form of a "Master
Declaration of Covenants, Conditions, Restrictions, Assessments, Charges, Liens, Reservations
and Easements for Ludlow Bay Village" dated May 25, 1994, and recorded under Jefferson
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County Auditor's File Nos. 372516 and 372695, together with an Amendment dated Apri125,
1995, and recorded under Auditor's File No. 381139 (collectively, the "Master Declaration").
No other declaration of restrictive covenants affects Ludlow Bay Village.
2. Relevant Legal Authority. Mr. Taraday correctly notes the applicable legal authority,
RCW 58.17.215, which provides in relevant part as follows:
RCW 58.17.215. Alteration of subdivision~-Procedure
When any person is interested in the a1terati011 of any subdivision or the
altering of any portion thereof, except as provided in RCW 58.17.040(6),
that person shall submit an application to request the alteration to the
legislative authority ofthe city, town, or county where the subdivision is
located. The application shall contain the signatures of the majority of
those persons having an ownership interest of lots, tracts, parcels, sites, or
divisions in the subject subdivision or portion to be altered. If the
subdivision is subiect to restrictive covenants which were filed at the time
of the approval of the subdivision. and the application for alteration would
result in the violation of a covenant the application shall contain an
agreement signed by all oarties subject to the covenants providing that the
parties agree to terminate or alter the relevant covenants to accomplish the
purpose of the alteration of the subdivision or portion thereof.
(Emphasis supplied.) There are no reported decisions under this statute.
3. Identification of Covenants. The first step is to identify the "restrictive covenants
which were filed at the time of the approval of the subdivision." See id. I acknowledge that the
Master Declaration contains restrictive covenants filed at the time of approval of the Plat.
However, I do not agree that the Plat contains any restrictive covenants.
The statute does not define "covenants" or "restrictive covenants." See RCW 58.17.020
(definitions). However, thc Washington Court of Appeals has relied upon the following
definition of "covenant" in another context:
A covenant is defined as an agreement or promise of two or more par6es
that something is done, will be done, or will not be done. In modem
usage, the term covenant generally describes promises relating to real
property that are created in conveyances OT other instruments.
Shafer v. Board of Trustees, 76 Wn. App. 267, 883 P.2d 1387 (1994)-
Under this definition, the Plat contains no restrictive covenants- It contains easements, a great
deal of descriptive information about the Plat (including tot addresses and lot numbers), and
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required certificates and signatures~ but no restrictive covenants- The only mention of covenants
within the Plat is on Sheet 1 of 6, under the headings ,''Declarations, Covenants, and Restrictions"
and "Declaration of Covenants," where a one-sentence reference is made to the Master
Declaration. The Master Declaration contains covenantS. But there are DO restrictive covenants
contained within the Plat.
Mr. Taraday contends that the lot addresses and lot numbers contained within the Plat are
restrictive covenants. This contention ignores the distinction between a covenant - a contract, a
pro:mise, a commitment -- and mere descriptive information. By Mr. Taraday's standard,
anything appearing within the Plat is a restrictive covenant, including the surveyor's office phone
number. This certainly is not what the legislature had in mind in adopting RCW 58.17.215.
The list of addresses and the "SF" and "TH" descriptive terms do not constitute covenants. A
covenant is a promise to do or not do something. There is no promise expressed or i:mplied on
the face of the Plat that the addresses will not be changed or increased in number or that the use
of the tenns "SF" and "TH" means that those lots will be used in perpetuity for single family and
town ho:me uses.
4. Interpretation of Master Declaration. Mr. Taraday and his clients do not have the
authority to interpret the Master Declaration because, when Mr. Taraday's clients purchased their
lots in Ludlow Bay Village and agreed to be bound by the Master Declaration, they agreed that
the Ludlow Bay Village Association Board of Directors would have the "exclusive right" to
interpret the Master Declaration and to determine "[a]l1 disputes, complaints or other matters
relating to the Master Declaration or other Governing Documents." Master Declaration ~4.25 at
14-15 and ~19.1 at 42. The Master Declaration also requires that an such disputes, complaints,
and other :matters "shall be submitted to the Master Association Board for determination, unless
otherwise provided herein to be within the authority of the Architectural Review Co:mmittee."
Master Declaration ~4.25 at 15. "In the absence of any adjudication to the contrary, the Master
Association's construction or interpretation of the provisions herein shall be [mal, conclusive and
binding as to all persons and property benefited or bound by this Master Dec1aration-" Master
Declaration g19.1 at 42. Tn other words, unless and until a court rules on the question whether
the proposed plat alteration would violate a restrictive covenant within the Master Declaration,
only the Board of Directors of Ludlow Bay Village Association has legal authority 10 determine
whether or not there is a violation.
Because the question whether the proposed plat alteration conflicts with any restrictive covenant
found within the Master Declaration requires the interpretation of the Master Declaration, and
because the question is a "matter relating to the Master Declaration," Mr. Taraday and his clients
are obliged to submit the matter to the Board of Directors of Ludlow Bay Village Association,
which then can make a detemlination whether or not there is a violation. The mere fact that Port
Ludlow Associates controls all five votes on the Board of Directors does Dot exCuse compliance
with this requirement. Until Mr. Taraday and his clients have submitted this :matter to the Board
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David Alvarez
January 13, 2004
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of Directors, they themselves have acted in violatiol1 of the Master Declaration by failing to
follow the adnrinistrative remedies and processes available to them.
5. Master Declaration Contains No Residential Density or Use Restrictions. Even if
Mr_ Taraday and bis clients had the authority to interpret the Master Dcclaration, the Master
Declaration simply contains no covenants regarding the density of residential development
within the Plat. It also does not contain covenants that forbid stacked residential units or that
would prevent anything but a single family residential use on "SF" lots or a town home
residential use on .'TH" lots_ The reason that Mr. Taraday did not identify a single section or
page within the Master Declaration in which such covenants may be found is because none exist.
While the Plat does contain lot addresses and lot numbers, neither the Plat nor the Master
Declaration contains any covenants that the addresses will not be changed or increased in
number, and neither contains any covenants that lot numbers beginning with the letters "SF" are
restricted to single family residential uses or that lot numbers beginning with the letters "TH" are
restricted to town home uses.
The Master Declaration does indeed contain a recital that the Declarant intends to '"incorporate a
mix of uses within Ludlow Bay Village" including "53 residential town homes and 5 single
family residences." Master Declaration at 1. That is not a restrictive covenant, for three reasons:
first, it is contained within a mere recital; second, it is a mere statement ofthe Declarant's intent
in 1994, not a promise to perform any act in the future; and third, it contains no promissory
language like "shall" or "agrees to" or "covenants to." See King County v. Rasmussen, 143 F.
Supp.2d 1225, 1229 (W.D. Wash. 2001) ("an acknowledgement of the probable use cannot limit
the conveyance unless accompanied by a specific restriction on use"). If I tell you that I intend
to become a millionaire someday, I have not promised you or covenanted to you that I wilt
become a millionaire, and I am not liable to you in do not become a millionaire.
Definitions typically do not contain covenants. But even if the proposed improvements and the
new owners are not "dwelling units," .'lots," and "residents" as these words are described in the
Master Declaration in its current form, the idea that a definition can be violated makes no sense -
the sole consequence of a mismatch is that the proposed improvements and new owners simply
would not be "dwelling units," "lots," or "residents." Just because a definition does not apply
does not mean that the definition is a restrictive covenant or that the definition is "violated."
Mr. Taraday cannot find an express residential density or use covenant with which the proposed
plat alteration would conflict, because no there are no express covenants with which the
alteration would conflict. Mr. Taraday instead finds implied. covenants (e.g., that a list of 58
street addresses implies a covenant that there will be only 58 residential units, that "SF" implies
a single family use covenant, that "TH" implies a town home use covenant). But Washington
courts are Dot fond of implied restrictive covenants. "Restrictive covenants upon the use of real
property will not be extended beyond the clear meaning ofthe language used." Weld v. Bjork, 75
Wn.2d 410,411, 451 P.2d 675 (1969), citing Jones v. Williams, 56 Wash. 588, 106 p, 166
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(1910); Hunter Tract Improvement Co. v. Corporation of Catholic Bishop ofNisqually, 98
Wash. 112, 167P.100,L.R.A.1918A,297(1917); Millerv.American Unitarian Ass'n, 100
Wash. 555, 171 P. 520 (1918). "Restrictions, being in derogation ofthe common-law right to
use land for all lawful purposes, will not be extended by implication to jnclude any use not
clearly expressed. Doubts must be resolved in favor of the free use ofland." Burton v. Douglas
COUl1.ty, 65 Wn.2d619, 622, 399 P.2d 68 (1965), citing Grangerv. Boulls, 21 Wash.2d 597,152
P.2d 325, 155 AL.R. 523 (1944); 14 AmJur- g211 at 620.
Based on these authorities, I am confident that nO Washington appellate court would conclude as
a matter oflaw either that the listing oflot addresses creates a restrictive covenant that the
density ofthe lots will not change in petpetuity, nor that the use of "SF" or "'TH" as a prefix jn a
subdivision lot number creates a restrictive covenant that the lot wHl be used in perpetuity only
for single family or town home residential uses, nor that any other residential density or use
covenants can be implied from the Master Declaration.
6. Declarant's Exemption. Even ifthe Master Declaration did contain residential density
or use restrictions with which the proposed plat alteration would conflict, Port Ludlow
Associates (as successor Declarant to Pope Resources) is exempt from any such restrictions:
Section 4.24. Declarant's Exemption. Nothing contaUled in this
Master Declaration shall be construed to prevent the erection or
maintenance by Declarant, or its duly authorized agents, of any buildings,
utilities, structures, improvements or signs necessary or convenient to the
development [ or] sale of property within Ludlow Bay Village.
Under this exemption, Port Ludlow Associates has complete authority to construct improvements
(including stacked residential flats) within any lot in Ludlow Bay Village. Therefore, increases
in density and changes in uses - when undertaken by Port Ludlow Associates ~ cannot possibly
conflict with any residential density and use restrictions in the Master Declaration.
7. Lack of Specificity and Completeness. Mr. Taraday's claims lack both specificity and
comp1eteness- They lack specificity becallSe Mr. Taraday's letter fails to identify by reference to
any specific section or page numbers any restrictive covenant within the Master Declaration with
which the proposed plat alteration would conflict. The claims lack completeness because Mr.
Taraday closes with the contention, "There are numerouS other examples to which one could
point to illustrate the manner in which the site plan violates the restrictive covenants imposed by
the plat and the CCRs." Both the County and Port Ludlow Associates are entitled to know what
those other examples might be. ML Taraday's January 6 letter would have been the proper time
to identify them short of submitting the matter to the Board of DirectoTs of Ludlow Bay Village
Association, as required by the Master Declaration and as discussed above.
8. Amendment of Master Declaration. [fPort Ludlow Associates were aware ofa
specific restrictive covenant that would be violated by the proposed plat alteration, then it either
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would amend the proposed plat alteration or the Master Declaration. Port Ludlow Associates has
the power to do either or both. (In fact, Port Ludlow Associates does intend to amend the Master
Declaration this year with respect to other matters.) Notwithstanding Mr. Taraday's letter, Port
Ludlow Associates sees no violation of any residential density or use covenants. It therefore has
not amended the Master Declaration regarding those matters.
9. Conclusion. As noted above. if you agree with my analysis of the issues, then I
respectfully request that you direct Mr. Scalf to notify Mr. Taraday that Jefferson County has
detennined that he has not shown that the proposed plat alteration would result in the violation of
a restrictive covenant.
Thanks very much for your consideration.
Sincerely yours,
1iW~~:~
Marco de Sa e Silva
MD:vh
cc: Greg McCarry, Port Ludlow Associates LLC (Via Facsimile)
Mark Dorsey, Port Ludlow Associates LLC (Via Facsimile)
Al Scalf, Director of Community Development, Jefferson County (Via Facsimile)
Jeffrey B. Taraday, Foster Pepper & Shefehnan PLLC (Via Facsimile)
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