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Michelle Farfan
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Sent:
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Sue Smith [ssmith@reidmidd.com]
Thursday, April 15, 2004 10:40 AM
AI Scalf; Michelle Farfan; Mdorsey@portludlowassociates.com
Port Ludlow Resort Draft SEIS
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Summary of
Alternatives.doc
Table l.doc
Attached are two items for your review - Table 1, Summary of
Environmental Impacts and Mitigating Measures and a revised first paragraph for Section
1.5, addressing the alternatives. We added a reference to the past No Action as no
development and the fact that this has been previously analyzed. This approach was
suggested as a way to address the concern reo using the 1999 Regs as No Action.
Lyn is out of the office today, but will be in Friday.
Sue Smith
Office Administrator
Reid Middleton, Inc.
728 134th Street SW, Suite 200
Everett, WA 98204
(425) 741-3800; Fax (425) 741-3900
ssmith@reidmidd.com
1
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In 2002, a project-level Supplemental EIS (SEIS) was prepared to address the 100-slip expansion
of the Port Ludlow Marina, an allowed Resort facility. This Supplemental EIS focused primarily
on issues associated with in-water construction in Port Ludlow Bay and was part of the in-water
permitting process which included the U.S Army Corps of Engineers, NOAA Fisheries, the U.S.
Fish and Wildlife Service, and the Washington Department of Fish and Wildlife, as well as
Jefferson County. The impacts identified in the "Port Ludlow Marina Expansion EIS" are
included in this SEIS to identify cumulative impacts as required by Sections 3.902 and 3.904 of
the MPR regulations.
The current SEP A process for the Resort is specifically addressed in Sections 3.902 and 3.904 of
Jefferson County Ordinance Number 08-1004-99. Section 3.902.1 states, "A project-level SEIS
analyzing the resort plan is required prior to issuance of building permits for any new resort
development. Environmental review of the Resort Plan shall not be piecemealed or broken into
small segments...." One intent of this section was to assure that cumulative impacts of all new
development within the Resort area would be addressed.
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 build-out plan through the
SEIS process." Jefferson County will not issue a land use or building permit for any resort
expansion until a project level SEIS for the full Resort Plan has been completed.
Section 3.904 identifies the preliminary scope of the required Resort SEIS or EIS. The scope is
to include, but not be limited to, the following elements: earth, water, plants and animals, land
and shoreline use, transportation, and public services and utilities.
1.5 Summary of Alternatives
The proposed revision to the "2003 Resort Plan" and two additional alternatives are evaluated in
this Draft Supplemental EIS. The two alternatives are based on two previous alternative
development scenarios for the Resort area - the Resort Plan as proposed in 1993, and the
approved 1999 Resort Plan. The 1999 Resort Plan is considered the "No Action" alternative for
this analysis; if no change to the Resort Plan is made at this time, development would continue
under the 1999 Plan, per existing County regulations and the existing practical constraints related
to the plat of Ludlow Bay Village. The "No Action" alternatives contained in the 1993 Port
Ludlow Development Program EIS, and The Inn at Port Ludlow EIS (adopted as part of this
SEIS) addressed no further development - e.g., the site remaining in its partially developed state,
but anticipating future development proposals. That analysis is not repeated here.
All three alternatives result in build-out of the Resort area, including a 100-slip expansion of the
manna.
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, ,
, Table 1 . Summary Of Environmental Impacts And Mitigating Measures
Alternative 1 Alternative 2 Alternative 3
Element Preferred Project 1993 Resort Plan No Action - 1999
Resort Plan
Earth
Environmenwllmpac~
Topography No major alterations to Similar to proposed Alteration to site slopes
site topography. project. along Oak Bay Road.
Soils and Subsurface Earthwork required to Similar to proposed More significant
Materials construct new buildings project. earthwork required to
and infrastructure. construct new buildings
and infrastructure.
Eastern half of lagoon to
be filled.
Large, heavy structures
in areas of fill would
require extensive ground
improvement
techniques.
Installation of 100 - 130, Similar to proposed Similar to proposed
24" diameter steel piling project. project.
will result in temporary
increase in turbidity and
permanent loss of
substrate at location of
piling.
Mitigating Measures
Soils Erosion control measures Similar to proposed Similar to proposed
to be implemented during project. project.
upland construction.
Work in steep slopes will Similar to proposed Grading of slopes along
be minimized. project. Oak Bay Road is
required.
Site-specific geotech. Similar to proposed Similar to proposed
explorations to continue. project. project.
In-water construction
activities to be limited to
times when salmon are
not likely to be present.
Upland and in-water Best Similar to proposed Similar to proposed
Management Practices project. project.
(BMPs) to be employed
during construction.
Element
Of Environmental Impacts And Miti atin
Alternative 1 Alternative 2
Preferred Project 1993 Resort Plan
Measures
Alternative 3
No Action - 1999
Resort Plan
Table 1 . Summa
Water
Environmental Impacts
Surface Water New storm drainage Similar to proposed Similar to proposed
system to be constructed project. project. New storm
in Basins A and B. drainage system also
required to serve area
along Oak Bay Road.
Water Quality New water quality vaults Unknown if new water Unknown if new water
will be added at each inlet quality treatment quality treatment
to the lagoon. proposed. proposed.
In-water construction Similar to proposed Similar to proposed
activities increase project. project.
potential for leakage of
petroleum products;
driving of 100 - 130 piles
will temporarily increase
localized turbidity and
increase suspended
sediment concentrations.
Potential incremental Similar to proposed Similar to proposed
increase in gray/black project. project.
water discharge, and bilge
water discharge.
Potential for increase in Similar to proposed Similar to proposed
hazardous material spills. project. project.
Groundwater Approx. 12% increase in Similar to proposed Greatest increase in
groundwater withdrawal project. withdrawal rate.
rate.
Mitigating Measures
Water Quality Implementation of erosion Similar to proposed Similar to proposed
. & sedimentation control project. project.
plans
cont. of Non-point Water Similar to proposed Similar to proposed
Qual. Monitoring Progr. project. project.
New piling to be steel. Similar to proposed Similar to proposed
project. project.
Silt fences to be installed Similar to proposed Similar to proposed
where necessary. project. project.
One additional portable Similar to proposed Similar to proposed
sewage pump-out facility project. project.
to be provided.
. .
Element
Of Environmental Impacts And Miti atin
Alternative 1 Alternative 2
Preferred Project 1993 Resort Plan
Measures
Alternative 3
No Action -1999
Resort Plan
Table 1 . Summa
Boaters to be educated reo Similar to proposed Similar to proposed
potential impacts of project. project.
hazardous material spill.
Enforce a no black water Similar to proposed Similar to proposed
(sewage) discharge rule project. project.
and provide better boater
education on black and
gray water discharge.
Groundwater Continued groundwater Similar to proposed Similar to proposed
monitoring program project. project.
Plants and Animals
Env&onmenwllmpacft
Upland Vegetation Land clearing and Similar to proposed Similar to proposed
increased human activity project. project.
to result in minor change
in the distribution of
habitat types and values.
Foraging eagles may Similar to proposed Similar to proposed
avoid Resort area. project. project.
Minor impact from new No new boardwalk No new boardwalk
boardwalk along the proposed. proposed.
waterfront.
Eastern two-thirds of
lagoon to be filled.
Marine Vegetation No eelgrass present at Similar to proposed Similar to proposed
project site. Loss of project. project.
benthic habitat at location
of new piling.
Threatened and Endangered
and Priority Species:
Salmonid Species Juvenile salmonids may Similar to proposed Similar to proposed
avoid areas of localized project. project.
high turbidity and areas of
reduced dissolved oxygen
level. Increased
overwater coverage may
increase predation, alter
migratory behavior, and
reduce prey production
and availability.
Table 1 . Summa
Element
Of Environmental Impacts And Miti atin
Alternative 1 Alternative 2
Preferred Project 1993 Resort Plan
Measures
Alternative 3
No Action - 1999
Resort Plan
Bald Eagles Potential temporary Similar to proposed Similar to proposed
disruption of foraging project. project.
behavior.
Marbled Murrelets Potential temporary and Similar to proposed Similar to proposed
localized impact to project. project.
foraging behavior and
prey availability.
Steller Sea Lions No impact anticipated. Similar to proposed Similar to proposed
project. project.
Other Fish and Invertebrates Temporary disruption of Similar to proposed Similar to proposed
foraging behavior and fish project. project.
may avoid project area
during construction.
Increased overwater
coverage and increased
shading may result in
minor decreases in
microalgae and benthic
productivity.
Avian Species Temporary impacts Similar to proposed Similar to proposed
include disruption of project. project.
foraging behavior and
may result in bird species
avoiding project area
during construction.
Mammals Mammalian species may Similar to proposed Similar to proposed
avoid project area during project. project.
construction and foraging
behavior may be
disrupted.
Mitigating Measures
Upland Vegetation Revegetation & Similar to proposed Similar to proposed
landscaping plan, project. project.
including lagoon.
Marine Vegetation No mitigation is Similar to proposed Similar to proposed
proposed. project. project.
Threatened and Endangered New kayak float will Similar to proposed Similar to proposed
and Priority Species: include light transmissive project. project.
capabilities.
Other Fish and Invertebrates New kayak float will Similar to proposed Similar to proposed
include light transmissive project. project.
capabilities.
"
Element
Of Environmental Impacts And Miti atin
Alternative 1 Alternative 2
Preferred Project 1993 Resort Plan
Measures
Alternative 3
No Action - 1999
Resort Plan
Table 1 . Summa
Avian Species & Mammals No mitigation is Similar to proposed Similar to proposed
proposed. project. project.
Land Use
Environmental Impacts Construction activities to Similar to proposed Similar to proposed
result in temporary project. project. Most significant
increase in noise, dust and new construction.
vehicular and barge
traffic.
New residential and Similar to proposed Most significant new
limited commercial project. residential &commercial
development. Resort development. Resort
facilities to serve the facilities to serve large
traveling public conference groups.
Expansion consistent with Similar to proposed Similar to proposed
and MPR land use project. project.
designations.
Mitigating Measures Upland construction to be Similar to proposed Similar to proposed
limited to 7:00am- project. project.
6:00pm, Mon - Sat.
Marina construction to be Similar to proposed Similar to proposed
limited to 8:00 am - 8:00 project. project.
pm, non-holidays
weekdays & Saturdays.
Stationary equipment to Similar to proposed Similar to proposed
be positioned as far as project. project.
possible from residential
properties.
All mufflers to be Similar to proposed Similar to proposed
properly maintained. project. project.
Dust will be suppressed Similar to proposed Similar to proposed
with wetting techniques. project. project.
Energy efficient Similar to proposed Similar to proposed
equipment will reduce project. project.
emISSIOns.
Project provides for an Similar to proposed Project would not
economically sustainable project. provide for a sustainable
Resort. Resort.
Residential & commercial Residential & Least separation of res.
uses to be separated. commercial uses less and comm. uses
separated.
. .
Table 1 . Summary Of Environmental Impacts And Miti atin
Alternative 1 Alternative 2
Element Preferred Project 1993 Resort Plan
Measures
Alternative 3
No Action - 1999
Resort Plan
Existing arch. character to Similar to proposed Similar to proposed
be maintained. project. project.
New marina docks will be
located to provide adequ. Similar to proposed Similar to proposed
fairway & maneuvering project. project.
for Scott dock.
Consistency with Plans
and Policies
Environmental Impacts
County Comprehensive Plan Proposed project is Similar to proposed Similar to proposed
consistent with County project. project.
Comprehensive Plan.
Shoreline Management Proposed project is Similar to proposed Similar to proposed
Master Program consistent with the project. project.
Shoreline Management
Master Program.
AestheticsNisual Quality
(from Port Ludlow Marina
Expansion SEIS)
Environmental Impacts
Marina Expansion Medium impact to Similar to proposed Similar to proposed
existing view from Oak project. project.
Bay Rd.
Medium impact to Similar to proposed Similar to proposed
existing view from Scott project. project.
Court.
Low impact to existing Similar to proposed Similar to proposed
views from across Port project. project.
Ludlow Bay.
Low to medium impact to
existing views from Similar to proposed Similar to proposed
Burner Point. project. project.
Mitigating Measures
Marina Expansion None Proposed Similar to. proposed Similar to proposed
project. project.
.
"
. '
Table 1 . Summary Of Environmental Impacts And Mitigating Measures
Alternative 1 Alternative 2 Alternative 3
Element Preferred Project 1993 Resort Plan No Action - 1999
Resort Plan
Transportation
Environmental Impacts
887 new daily vehicular 968 new daily vehicular 3,791 new daily
trips generated, 97 of trips generated, 105 of vehicular trips
these trips during the these trips during the generated, 337 of these
peak hour. Increased boat peak hour. Increased trips during the peak
traffic at the marina. boat traffic at the hour. Increased boat
manna. traffic at the marina.
Adopted LOS for County Similar to proposed LOS E for westbound
intersections will not be project. traffic at Beaver Valley
exceeded. Rd./Oak Bay Rd., and
Oak Bay Rd./W alker
Way.
Side-street movements @ Similar to proposed Similar to proposed
the SR 104 intersections project. project.
with Paradise Bay Rd.
and Beaver Valley Road
will continue to exceed
standards, but not as a
result of project traffic.
New off-street parking to Similar to proposed Similar to proposed
be provided. project. project.
Signed pedestrian trails to Similar to proposed Similar to proposed
be provided. project. project.
Mitigating Measures
None required Similar to proposed Similar to proposed
project. project.
Public Services and
Utilities
Environmental Impacts
Fire/Emergency Services Incremental increase in Similar to proposed Similar to proposed
demand for fire services. project. project.
Piped fire suppression
system required for new
marina floats.
Two new propane storage Similar to proposed Similar to proposed
areas to be added project. project.
Water Service 12.2% increase in total Similar to proposed Greatest potential
Port Ludlow water usage project. increase in water usage.
anticipated.
.., ."
L _. ,
Table 1 . Summary Of Environmental Impacts And Mitigating Measures
Alternative 1 Alternative 2 Alternative 3
c Element Preferred Project 1993 Resort Plan No Action - 1999
Resort Plan
Sanitary Sewer Service Proportional increase in Similar to proposed Greatest potential
demand for sewage project. increase in use of
treatment and marina sanitary sewer system.
pump-out facilities.
Mitigating Measures
FirelEmergency Services Mitigation/impact fees to Similar to proposed Similar to proposed
be paid. project. project.
Permanent emergency No helipad to be Unknown if helipad to
helipad to be provided. provided within Resort be provided within
area. Resort area.
Fire hydrants and Similar to proposed Similar to proposed
emergency access to be project. project.
provided.
New dry line fire Similar to proposed Similar to proposed
suppression system to be project. project.
installed on C-Dock, the
central walkway and all
new docks.
Training for marina Similar to proposed Similar to proposed
personnel and live-aboard project. project.
residents in emergency
fire fighting procedures.
Fire call boxes to be Similar to proposed Similar to proposed
installed on new docks project. project.
and central walkway.
Construct new connection Similar to proposed Similar to proposed
between B-Dock and C- project. project.
Dock
Water Service Resort build-out and 100- Similar to proposed Similar to proposed
slip marina expansion project. project.
anticipated in plan for
water system.
Sanitary Sewer Service Two portable pump-outs Similar to proposed Similar to proposed
and stationary pump-out project. project.
to be available for use at
the marina.
The Port Ludlow sanitary Similar to proposed Similar to proposed
sewer treatment plant was project. project.
designed to accommodate
build-out of the Resort.