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MEMO
APR 2 1 2004
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April 17, 2004
JEFFERSON COUNTY OCD
Michelle Farfan, Associate Planner, Jefferson County
Al Scalf, David Goldsmith, David Alverez, BOCC, Randi Thurston
WDFW, Jeff Davis WDFW, Jeffree Stewart DOE, Paula Mckrow NOSC,
Richard Brocksmith HCCC, Doug Soehl TU, Carol Saber PL VC,
Dwayne Wilcox PL VC, Jeff Schreck DNR, LBV Homeowners
Bert Loomis
a)
b)
Port Ludlow Resort Plan Revision - Draft SEIS, 3/15/04
Shoreline Primary Use Substantial Development Permit No,
SDP 91-017, issued 5/11/93
Dear Michelle:
After reading the Shoreline Management Master Program [SMMP] for Jefferson County,
along with the two documents referred to above, it appears that the SEIS contains fatal
flaws that are violations of the SMMP,
The SEIS proposes to increase density by approximately 66%, with the majority of these
units being constructed on pilings over the lagoon, See SEIS Figures 7 A, 7C & 12A,
Please review the SMMP Pages 69 & 70, Section 5.160, Residential Development:
Prohibited Uses and Activities
1, Residential structures located on or over marshes, bogs, swamps, lagoons,
tidelands, ecologically sensitive areas or water areas subject to this Master
Program.
Policies
4. Over-water residential development, including floating homes, should not
be permitted,
Performance Standards
5. Developments containing marshes, swamps, lagoons, portions of a flood
plain, or similar wetlands shall use those areas only for the purpose of
parks, open space, or recreational facilities.
,
.
Also, the following permit conditions clearly indicate any construction over the lagoon
will be inconsistent with, and contrary to, the intent of at least ten mitigation conditions
of the existing Permit SDP91-017, dated May 11, 1993, as previously agreed to by the
County and Developer.
Development pursuant to this permit shall be undertaken subject to the applicable policies
and performance standards of the Jefferson Shoreline Management Master Program and
the following conditions:
13. Eelgrass (zostra marina) shall be planted in the eastern sector of the pond
to prevent the growth of sea lettuce (ulva).
14. During construction, water levels in the on-site pond shall be lowered and
sediment removed therefrom prior to the discharge of water into the Bay.
15, Two pumps shall be installed in the pond for redundancy in case of failure
and to improve flexibility for periodic maintenance. A standby mobile
power generator shall be provided in the event of power outages.
16, The maintenance schedule for the pond shall avoid pump shutdown during
warmer weather, thereby lessening stagnation of water and related water
quality problems.
21. Landscape design and planting materials for the perimeter of the pond
shall minimize the need for herbicide application, Native plant materials
shall be utilized to the maximum extent throughout the entire project site
to reduce the use of fertilizers, pesticides, and herbicides, When the
application of such chemicals is necessary, they shall only be applied by
state - licensed personnel.
22. Buffers of grasses, low growing plants, shrubs, and trees shall be planted
along the shoreline and around the pond, providing habitat, water quality
enhancement, and protection from human disturbance,
24, Enlargement of the existing pond shall make provisions for improved
aeration and circulation to discourage algae growth, maintain consistent
water quality, and improve its value as fish habitat.
27, The weir outlet to the pond shall be designed to prevent fish entrapment in
the pond,
28. The pond shall be designed to provide some shallow area along the south
shoreline, suitable for wading birds, isolated from public access.
2
29. Pond shoreline length equivalent to at least 50% of the existing shoreline
length shall be provided for bird loafing area, This shoreline area must be
buffered by landscape vegetation to discourage public disturbance.
This permit was issued subject to significant mitigation requirements. The applicant now
wants to increase density by 66%, while concurrently violating previously agreed to
permit conditions, I call your attention to the Notice Section of the Permit:
1, This permit may be rescinded by the Jefferson County Board of
Commissioners or the Washington State Shorelines Hearings Board upon
finding the Developer has not complied with the conditions herein,
pursuant to RCW 90,58,140 (8),
2. .. ,Construction or substantial progress toward construction of the
permitted development shall begin within two (2) years from the date of
this permit and completion of the permitted development shall be
accomplished within five (5) years from the date of this permit...
This Permit was issued on May 11, 1993 and completion was to have been accomplished
by May 11, 1998, To date, 11 years later, less than 44% of the development has been
completed.
As you know, serious questions have been raised concerning the Developer's failure to
comply with many of the current permit conditions, I call your attention the SEIS,
Appendix C, Landscape Plan Port Ludlow Resort by GeoEngineers [2/04]. The
consultant acknowledges a failure to comply with conditions of the Permit to date:
Appendix C
1.0 Introduction, , ,This conceptual landscape plan has been prepared to assist
PLA in satisfying the mitigation requirements,. ,to lessen project impacts
and enhance environmental conditions at the Port Ludlow Resort,
4,1 South Lagoon Shoreline - Wildlife Area" ,This will address one of the
requirements in the 1993 shoreline conditions."
4.3.4 Eelgrass (zostera marina) .. .One of the conditions of the 1993 shoreline
permit for the Port Ludlow Resort states that "Eelgrass shall be planted in
the eastern sector of the pond"." to date that has not been accomplished.
4.4 Esplanade and Walking Paths ,., a plan for connecting these trails with
parking facilities and other public access routes is under development. . .
3
Why are they still planning for the required mitigation conditions eleven
years after the permit has been issued?
Also, see SEIS Page 3-21, Section 3.3,1, Affected Environment:
Artificial Lagoon
The lagoon was initially constructed in 1967 by excavating upland soils,
It was 1.4 acres in size. In 1994 the lagoon was expanded to 2,2 acres as
mitigation for planned Resort expansion,
Based on the Applicant's clear failure to comply with Section 5,160 of the
Shoreline Management Master Program for Jefferson County, I request that you reject
their Draft SEIS. Also, I expect the County to fully enforce all conditions of Permit SDP
91-017 and the SMMP as required by law,
Contact:
Bert Loomis
9500 Oak Bay Road
Port Ludlow, W A 98365
360-437-2400
bertl@cablespeed,com
End:
Permit SDP91-017 with conditions
Figure 7 A SEIS
Figure 7C SEIS
Figure 12A SEIS
4
JEFFERSON COUNTY
SHORELINE SUBSTANTIAL DEVELOPMENT PERMIT
WASHINGTON STATE SHORELINE MANAGEMENT ACT (ReW 90.58)
/4647
. .
PERMITTEE:
Pope Resources
DATE ISSUED:
May 11, 1993
TYPE OF ACTION:
General
TYPE OF USE:
Primary, Secondary, Conditional
CASE NUMBER:
SDP91-017
APPLICATION DATE:
August 7, 1991
,
PROPOSAL:
A residential, commercial, and recreational development consisting
of the following: .
* A 36-room hotel;
* 5 detached single family residences and 53 attached single family
residences in 14 multi-unit structures;
* Roadways and 367 parking spaces;
* utilities, including water, electrical power, and sanitary sewer ;
* 500 cubic yards of rip rap shore defense works;
* Marina modifications including a new manager's .building, new
restrooms and laundry, new fuel and propane tanks located between
the marina and the pond, and removal of an existing boat launch;
* Landscaping and recreational amenities inclUding construction of
vegetated artificial dunes on the'southerly portion of the.spi~,
trails and a pedestrian bridge, outdoor sport courts, and expansion
of the existing pond;
* Approximately 45,000 cubic yards of
filling including 25,000 cubic yards for
* Temporary and permanent soil erosion
management system;
* Directional and informational signs;
* Outdoor lighting; and
* 10.5 acres of undeveloped open space.
excavation, grading and
pond expansion;
control and storm 'water
The Inn would be a,three-story, wood frame structure, that would
include a manager's.:residence. Its maximum height would be 52 feet.
It would have a foot print of 11,345 square feet and total square
footage of 34; 171 square .feet. Its design would include the
following fire and life safety features: quick-response sprinkler
heads; automatic alarm notice to Fire District #3; tamper
protection for the automatic sprinkler system; hose cabinets at
each floor; diesel generator back-Up power source; an indicator
panel for all building safety systems; ,smoke detection on HVAC
systems; a stairwell to the roof; and a wet-sprinkler in the
covered drive-through. The proponent also proposes planning and
staff training in order to enable rapid respond to emergencies.
Shoreline Substantial Development Permit
SDP91-017
Pope Resources
The existing man-made pond covering 1.4 acres would b~ enlarged to
2.2 acres. A pump would supply with water from Ludlow Bay in order
to maintain a'constant salinity.
A new 800 square foot marina manager's office would be constructed
midway between the existing office and the Inn site. The existing
office would be demolished and replaced with newrestrooms and
laundry facilities on the same site.
The e~isting underground fuel and propane tanks-would be removed
and new tanks would be located adjacent to the manager's office in
a containment bunker.
Exterior lighting fixtures would employ hoods, shades, or dther
techniques to direct illumination onto the immediate area where it
is needed. Light standards in parking areas would not exceed 10
feet in height. Light fixtures along pedestrian walkways would not
exceed 4 feet in height. No colored lights would be used except for
holiday occasions.
utilities would be installed underground.
LEGAL DESCRIPTION:
The proposal site comprises 17.5 acres adjacent to the existing
marina and resort at Port Ludlow and is described as ,portions of
Government Lots 1 and 2 in section 16, Township 28 North, Range 1
East ,.'W.M.- . ,
WATERBODY AND/OR ASSOCIATED WETLANDS: Port Ludlow Bay
SHORELINE OF STATE-WIDE SIGNIFICANCE: No
SHORELINE DESIGNATION: Urban
CONDITIONS: Oevelopment pursuant to this permit ~hall be
undertaken subject to the applicable' policies and performance
standards of the Jefferson-Port Townsend Shoreline Management
Master Program and the following conditions: .
J 1. A detailed erosion and sedimentation .control plan using the
best management practices set forth in the Washington
Department of Ecology's storm Water Manual for the puaet Sound
Basin shall be prepared in conjunction with final site design
and a construction phasing schedule. Grading on the project
site shall not begin until the er~sion control plan has been
approved by the Director of the Jefferson County Department
of Public Works or his design~e. The objectives of said plan
are to (a) control dust and mud and stabilize the construction
area including entrances and roadways; (b) prevent surface
. 2
Shoreline Substantial Development Permit
SDP91-017
Pope Resources
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water runoff from eroding areas to be cleared and graded; (c)
prevent sedimentation from entering the waters of Port Ludlow
Bay. Erosion control techniques may include, but are not
limited to, piped slope drains, subsurface drains,
hydroseeding, surface roughening, interceptor dikes and berms,
check dams, swales, gradient terraces, rip-rap, gravel filter
berms, storm drain inlet and outlet protection, and filter
(silt) fences. A maintenance program shall be implemented
during the course of construction to insure the proper and
effective functioning of erosion and sedimentation control
features. Inspection of erosion control features shall be
conducted daily. '
Soil disturbance associated with, major grading activities
shall conform to t~e guidelines and timing restrictions set
forth in the Washington State Department of Ecology Storm-
Water Manaqement Manual (current edition). Prior to final plat
approval and prior to any clearing and grading on the site,
the proponent shall submit a construction phasing plan to the
Jefferson County Public Works Department for review and
approval. The plan shall specify how the proponent proposes.
to achieve the goals of this mitigation measure.
Dur ing construction, to the extent practicable, existing
vegetation shall be maintained on those portions of the site
planned as permanent open space. only during the course of
utility installation or revegetation/landscaping shall
disturbance occur.
Grading stockp~les shall be located on the uphill side of
excavation areas to act as runoff diversions. Any large
stockpiles shall be shaped and covered or seeded.
Soil, sediment, water, or debris generated during pond
enlargement shall be confined to specific areas on the site
as identified. on. the erosion control plan. Dredged pond
material and other site material unsuitable for project fill-
shall be disposed of at a location approved by the Director
of the Jefferson county Department of Public Works.
Following construction, all cleared and graded areas shall be
permanently revegetated according to .an overall landscape
plan. Revegetation shall be completed as soon as practicable
after grading and construction is,complete.
Dunes proposed for the Inn area shall be stabilized ,through
the use of vegetation and underlying foundations so as to
minimize sand and soil redistribution during storm events.
3
Shoreline Substantial Development Permit
SDP91-017
Pope Resources
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The proponent shall designate a qualified, trained, and
experienced individual or firm who shall ensure that (a)
erosion control .devices are correctly installed; (b)
inspection and maintenance schedules are regularly k~pt; (c)
corrective actions are employed in the event erosion control
measures fail to perform effectively and (d) reports and
inspections are coordinated with the Jefferson County
Department of Public Works.
A complete geotechnical investigation. shall be undertaken on
slopes steeper than 15% where buildings or infrastructure are
proposed. Particular attention will be paid to possibilities
of earthquake-induced subsidence or liquefaction. Structures'
shall be designed, engineered, and constructed in conformance
with the Uniform Building Code, other adopted standards
pertaining to landslide 'and seismic hazard protection, and
specific construction practices recommended by the
geotechnical consultant. The consultant shall be a qualified
professional selected and paid by the project proponent. No
construction of buildings, or installation of infrastructure
on slopes steeper than 15% shall take place. prior to
completion of the geotechnical investigation. .
A permanent stormwater drail)age system shall be installed, the
design and construction of which shall be to the satisfaction .'
of the Department of Public .Works. system.components~sha~l
include grass-lined swales, oil/water separators, and a
detention pond to manage both water quantity and quality.
..../' 11. The project's stormwater management system shall be
incorporated into the ongoing Port Ludlow Bay "water"Quality
Monitoring Program -: Nonpoint Sources".
v' 12. A maintenance program shall be developed for pil/water
separators and biofilters and approved by the Jefferson County
Department of Public Works. .
10.
V' 13. Eelgrass (zostra marina) shall be planted in the eastern
sector of the pond to prevent the growth of sea lettuce
(Ulva) .
/ 14. During construction, water levels in the on-site pond shall
be lowered and sediment removed therefrom prior to the
discharge of water into the Bay.
" 15. Two pumps shall be installed in the pond for redundancy in
case of failure and to improve flexibility for periodic
4
...
Shoreline Substantial Development Permit
SDP91-017
Pope Resources
J 19. Groundwater seepage encountered during construction in 'upland
areas shall be directed by sloping excavations to shallow sump
pits. Any collected water shall be discharged to the
construction-phase stormwater control system.
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Portions of structures subject to periodic tidal inundation
shall be sited and constructed in'compliance with Jefferson
County's "Flood Plain Management Ordinance No. 1-89."
J 21. Landscape design and planting materials for the perimeter of
the pond shall minimize the need for herbicide applicatiol).
Native plant materials shall be utilized to the maximum extent'
throughout the entire project site to reduce the use of
fertilizers, pesticides, and herbicides. When the application
\~.of such chemicals is necessary, they shall only be applied by
~i state-~icensed personnel.
20.
..j 22. Buffers of grasses, low growing plants, shrubs, and trees
shall be planted along the shoreline and around ~pe pond,
providing habitat, water quality 'enhancement, and protection
from human disturbance. .
j 23.' Primary landscape materials planted on, the site shall be those
native trees, shrubs, grasses, and herbaceous cover which
provide food and cover for wildl.ife, for example, Douglas
firs, We~tern red cedars, vine maples, wax myrtles, and wild
strawberries.
.J 24. Enlargement of the existing pond' shall make provisions for
improved aeration and circulation to discourage algae growth,
maintain consistent water quality, and improve its value as
fish habitat.
5
Shoreline Substantial Development Pe~it
SDP91-017
Pope Resources
.
J 25. Interpretive signs shall be installed at pertinent points
throughout the site to describe important habitat features and
wildlife. Pamphlets and brochures shall be distributed to
residents and guests to increase awareness and respect for
wildlife which inhabit the project site. -
J 26. Filtration shall be provided at the pump water-intake pipes
to reduce the incidental capture of fish.
v 27. The weir outlet to the pond shall be designed to prevent fish
entrapment in the pond.
v 28. The pond shall be designed to provide some shallow area along
the south shoreline, suitable for wading birds, isolated from
public access. '
../ 29. Pond shoreline length equivalent to at least 50% of the
existing shoreline length shall be provided for bird loafing
area. This shoreline area must be buffered by landscape
vegetation to discourage public disturbance.
" 30.
Excavation shall be minimized to reduce
encountering contaminated soil materials
development of the site.
J 31. Lead concentrations from previous testing in the vicinity pf
Test pit 10 (TP-10) shall be reported to the Washington
Department of Ecology if encountered in quantities in excess
of 10 cubic yards. .
potential for
from previous
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.
../ 32. Excavated soils at locations other than TP-10 shall be,
monitored for presence of potentially hazardous materials.
v 33. In accordance with DOE Policy #101 (Site piscovery aud Release
Reporting), a qualified hazardous waste specialist shall be
contacted if more than 10 cubic yards of charcoal-like
material is encountered in order' to prop~rly assess
implications for disposal.
34. Prior to initiating excavation, a qualified haza+dous waste
specialist shall orient the construction contractors and crew
regarding field identification of, potentially contaminated
soil and materials.
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35. The proponent shall establish legally enforceable-
architectural design guidelines which address such matters as
roof materials, siding, exterior colors, appurtenances, and
6
Shoreline Substantial Development Permit
SDP91-01.7
Pope Resources
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other factors that affect the overall aesthetic Gharacter of
the project site.
The proponent shall comply with all regulations of the State
Shoreline Management Act (RCW 90.58), RCW 217.44.0.40, RCW
27.53.060 and WAC 25-489 regarding archaeological sites.
These regulations prohibit intentional disturbance of
archaeological or burial sites without prior approval and
provide protocols for actions following discovery of such
sites.
Prior to excavation, a qualified archaeologist shall orient
the construction contractors and crews in identification of
potential archaeological resources that might be uncovered,
and how to proceed in the event of an unexpected'discovery.
If cultural resources are discovered during construction, a
qualified archaeologist shall be immediately dispatched to
systematically analyze the findings. All construction or
excavation on that portion of the project site shall
immediately cease and measures shall be taken to prevent
further disturbance prior to analysis by a qualified
archaeologist.
The following above-code fire and life safety features shall
be provided in the Inn structure: quick-response sprinkler
heads; . automatic alarm notice to Fire District' #3; tampe,r
protection for the automatic sprinkler system; hose cabinets
at each floor; diesel generator back-up power source; an
indicator pane~ for 'all building safety systems; smoke
detection on HVAC systems; interior stairway to the roof; and
a wet-sprinkler in the covered drive-through. .
The proponent shall develop a plan for the Inn which
identifies applicable emergency, actions to be tak~n during
such unlikely events as fires or earthquakes. The staff shall
be trained in fire behavior, built-in fire and life safety
systems in the Inn structure~ and proper re~ponses to
emergencies and safety needs of all ~ests.
A maintenance schedule for fire and life safety equipment
shall be developed. All such equipment. and related systems
shall be tested at least annually in cooperation with
Jefferson County Fire District, No.3. Records of all
maintenance and system tests shall be retained at the Inn and
copies transmitted to Jefferson County Fire District No.3.
Exit maps and instructions on emergency procedures shall be
7
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Shoreline Substantial Development Permit
, SDP91-017
Pope Resources
installed on the inside of all guest room doors..
J 43.
A public relations videotape which
emphasizing building safety' features,
guest responsibilities for safety in
shall be available in all guest rooms.
includes. a prologue
exit locations, and
emergency sit.':lations
V 44. The Inn's resident manager and all other on-site staff, as a
condition of employment, should be trained in basic first aid
and CPR.
J 45. Fundamental emergency aid equipment shall be provided at the
Inn for staff use.
46. In order to assess cumulative impacts from this project, the
proponent shall:
(a) continue the existing Water Oualitv Monitorinq Proqram
which documents nonpoint source effects on the Class A
"Extraordinary" designation of Port Ludlow Bay and it's
tributaries. Sampling shall include the water column,
sediments, and shellfish as appropriate. If monitoring
indicates that activities of the, proponent- are causing
reduction in the water quality of Port Ludlow Bay below the
Class AA "Extraordinary" designation, the proponent. shall
inundiately so advise Jefferson County. The "scope of work"
for each year's program shall.be conducted where necessary to
obtain the most meaningful scientific data. The ensuing year's
scope of work shall be approved by Jefferson county each
autumn. Each year's monitoring results shall be reported to
Jefferson county by March 15 of the following yepr. The
proponent shall be responsible' for employing a qualified water
quality research firm at proponent's sole expense.
(b) Conduct a Water Resource Monitorinq Proqram which
documents the condition of several aquifers utilized as a
domestic source by the proponent. Attention should be focused
on static groundwater levels and saltwater intrusion. Should
groundwater monitoring indicate an inadequate yield to support
development of the proponent's proj ects in the context of
water rights and projected water use, the pr9pqnent shall
immediately inform the County and take' necessary action to
insure an adequate supply of potable water. This action could
include, but is not limited to, development of additional
sources, supplementation of existing sources, and/or
implementation of additional conservation measures.
If mutually agreeable, the proponent shall include Olympus
8
Shoreline Substantial Development Permit
SDP91.-017
Pope Resources
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Beach Tracts' wells in ongoing groundwater monitoring efforts.
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The proponent shall be responsible for employing a qualified
geohydrologist to.design, direct, and conduct said monitoring
program. The expense of said geohydrologist shall be the
proponent's. Results of the monitoring program shall be
reported to Jefferson County and the Washington Department or
Ecology by March 15 of each year.
(c) Conduct a Sewaqe Treatment Plant Monitorinq Proqram which
documents effects of the proponent's ,projects on capacity of
the secondary wastewater treatment plant. Attention shall be
focused on the number of connections; effluent flow volume;
and effluent quality. It is acknowledged that the ,sole
authority to monitor and regulate operation of the sewage,
treatment plant rests with the Washington Department of
Ecology. Nothing in this condition is intended to supersede
or conflict with requirements of the proponent's National
Pollution Discharge Elimination system (NPDES) Permit No. WA-
002120-2 issued pursuant to the Federal Clean Water Act and
companion statutes. If any function or value monitored by the
NPDES permit is exceeded, notice shall be prov.ided to
Jefferson County concurrently with notice to the Washington
Department of Ecology. Results of the monitoring contained in
this condition shall be transmitted, to Jefferson County and
the Washington Department of Ecology by March 15 of, each year.-
The riprap shore defense work shall be constructed 'in
~ubstantial alignment'with the ordinary high water mark.
. .
Design of the fuel and propane tanks shall be approved by the
Chief of Fire District No.3.
The deed to the homeowners association from Pope Resources of
Tracts A, C, and M-1 shall be subject to' an easement in favor
of the general public for access, use, and enjoymeht for th~
life of the project. The association will retain the right ~o
reasonably regulate those common areas by establishing rules
and regulations., such as those to protect lanscaping, regulate
noise, prevent nuisances. '
Informational and directional signs shall clearly indicate the
location of public access areas.
The proponent shall provide near 'the marina loading area an
access area and stairway to facilitate launching of small
watercraft such as di~ghies, canoes, and kayaks.
9
. .
Shoreline Substantial Development Permit
SDP91-017
Pope Resources
.
NOTICE: .
1. This permit may be rescinded by the Jefferson 'county Board of
Commissioners or the Washington State Shorelines 'Hearings
Board upon the finding the permittee has not complied with the
conditions herein, pursuant to RCW 90.58.140(8).
2. The permittee is liable for all damages to public and private
property arising from violation of any provisions of the
permit hereby granted, including the cost 'of restoring the
affected area to its condition prior to violation and possible
court costs that may ensure from violation, pursuant to RCW
90.58.230. '
3. Construction pursuant to this permit will not begin nor is to
authorized until thirty (30) days from the date of filing as
defined in RCW 90.58. 140(6) and WAC 173-14-090, or until all
review proceedings initiated within thirty days from the date
of such filing have terminated, except as provided in RCW
90.58.140(5.a-c). Construction or substantial progress toward
construction of the permitted development shall begin within
two (2) years from the date of this permit and completion of
the permitted development shall be accomplished within five
(5) years from the date of this p~rmit.
4. Nothing in this permit shall excuse the permittee from
compl ing with any other federal, state, or local statutes,
~nan s, or regulations applicable to this projec~, but
consisten ith R W 9 .5
,
10
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Shoreline Substantial Development Permit
SDP91-017
pope Resources
THIS SECTION IS
CONDITIONAL USE
USE ONLY IN REGARD TO A
.
FOR DEPARTMENT OF ECOLOGY
PERMIT OR A VARIANCE. .
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Date received by the Department:
Approved:
"f
Denied
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This conditional use permit/v1u. .i.~IP p is approved/dwll.i.oQd by the
Department pursuant to Chapter 90.58 RCW. Development shall be
undertaken pursuant to the following. additional terms and
conditions: ~~ ~l"IA-e Hbl)LellE:.R- ,
C:\SDP\SDP91017.Per
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Igure 7
Alternative 1
Port Ludlow Resort PIa
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Figure 12A - Building Layouts
Port Ludlow Resort Plan DSEIS
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DRIVE
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-\-17,00 -\-17.80
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R-8 (600) Ludlow Bay Village
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