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Jefferson County Department of Community Development
621 Sheridan Street
Port Townsend, WA 98368
June 6, 2004
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Dear Department of Community Development:
, JEFFERSON COI INTY OCD
Thank you for the opportunity to respond to the Port Ludlow Resort Plan Revision DrafT
Supplemental Environmental Impact Statement of April 2004, As a resident of Port
Ludlow, I appreciate the effort in developing this statement. However, I would like to
express concern with portions of the document.
· The document indicates that the "lagoon is a man-made facility constructed in
1967 by excavating upland soils and not a shoreline regulated under the Shoreline
Management Act." The study then notes that the American wigeon, buffiehead
and killdeer use the lagoon as does the mallard, pintail, scamp and merganser. I
checked the 2003 edition of "Birds of the Puget Sound Region (by Bob Morse,
Tom Aversa and Hal Opperman) and the aforementioned birds and fowl live in
"costal bays, mudflats, marshes, ponds and estuaries and frequent beaches:1I
would like to inform you that the Shoreline Management Act applies to upland
areas that the Act terms "shorelands" and located up to 200 feet landward from
the edges of the shoreline, All wetlands within the 1 00 year flood plain are
protected by the legislation. I would ask that you re-evaluate whether the lagoon
is covered by the Shoreline Management Act,
· Section 3.3 (Plants and Animals) of the study relies ona 1992 survey of plants
and animals within the Port Ludlow Development Program Area, The data were
collected arid analyzed 12 years ago and may no longer be valid given the passage
of time. Additionally, the developer's new proposal calls for the elimination ofa
significantly greater amount of open space. The document mentions that you
performed a biological site survey on November 4,2003, but I contend that a one
day survey is not sufficient to validate the 1992 findings.
· Section 3.5.2 (Environmental Impacts) states that the "project will not impact
efforts to preserve and protect area greenbelts, open spaces or wildlife corridors"
referencing Policy LNG 25.6 of the Jefferson County Comprehensive Plan. That
statement cannot be supported as new residential construction will eliminate much
of the open space within the project area (see Figure 3A of your EIS).
· The document does an excellent job of analyzing the traffic flow along
Washington State Route 104 concentrating on the intersections with Paradise Bay
Road and Beaver Valley Road. You then state that" 1400 linear feet of existing
private roads provide internal circulation", however you have neglected to
perform a traffic flow analysis for those roads. How can one evaluate whether
emergency vehicles (including fire trucks and ambulances) can successfully
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maneuver through the site in case of emergency?The average age of our town is
older than that in the state of Washington as a whole (empirical evidence backed
up by data in a recent edition of the "Port Townsend Leader"), so it is essential
that we can receive assistance in the case of an emergency.
. Section 3.6.1 states that on-site parking for the residential town homes is provided
at a rate of one to two stalls per unit. However, Section 2.2 states that "all new
residential units will include off-street parking for two cars." I examined Figure
12A (Building Layouts) which exclusively shows one car garages. Please state
your definition of "parking". For example, my husband and I have a two car
garage, We have a driveway in which we can park two additional automobiles,
Do we have two parking spaces or four according to your definition?
. Section 1.3 states the purpose of this EIS. You contend that "shifting market
trends and reduced demand for large conference facilities in the Pacific
Northwest" requires the proposed changes to the plan, I could not find an
economic analysis substantiating this statement, In addition, econoinic viability is
influenced by a number of factors, Failure to update a conference facility to
appeal to the market is a factor. An insufficient sales and marketing plan is
another factor.
. In closing, Open Space Goal Four ofthe Jefferson County Comprehensive Plan is
to "develop and maintain park and recreational facilities responsive to the needs
and interests of Jefferson County residents and visitors." I attended a town hall
meeting to discuss the proposed development, and there was widespread
dissatisfaction, Most disturbing was the elimination of a significant amount of
open space along with the effects caused by the reduction. Another distressing
aspect is the developer's proposal to develop a new 7500 square foot private
recreational facility, Port Ludlow already has two such facilities, and I would be
surprised if the number of residents in this community could support a third
facility,
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Sincerely,
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Barbara Tipton
23 Clear View Place
Port Ludlow, W A 98365
360-437-0558
JEFFERSON COUNTY DCO
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