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JUN -9 20M
PLOD
JEFFERSON COUNTY OeD
Port Ludlow Drainae:e District. Post Office Box 65261. Port Ludlow. 98365 WA
SUBJECT: REVIEW OF PORT LUDLOW RESORT PLAN REVISION DRAFT
SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT,
JEFFERSON COUNTY, WASHINGTON
Jefferson County Department of Community Development
621 Sheridan Street
Port Townsend, WA 98368
Dear: Mr. Al Scalf
3 June 2004
The Port Ludlow Drainage District has reviewed the Port Ludlow Resort Plan Revision
Draft Supplemental Environmental Impact Statement (DSEIS) dated April 2004. The
Resort Plan Revision area described in the DSEIS lies entirely within the boundaries of
the PLDD. The District submit the following comments: .
1. The Port Ludlow Drainage District is a public agency with SEP A authority
and environmental expertise for surface water and drainage issues within the
District. The PLDD should be included in all distribution of any SEP A
documents developed for this and any prpject within or impacting the PLDD
per WAC 197-11-455.
2. The SEPA Handbook (Publication #98-114) states on page 53 that "...the
adoption form (of the original EIS] must be included within the draft
supplemental EIS." The development regulation in Appendix A reference that
adoption but does not include the adoption form (published October 1992 and
April 1993.
3. Jefferson County and the PLDD have adopted the 2001 Washington State
Department of Ecology Storm water Management Manual for Western
Washington. Since the DSEIS is essentially a new application, the proposal
must meet all applicable requirements at the time of application. Therefore,
the currently adopted Stormwater Management Manual should be used for
stormwater management.
4. The PLDD encompasses all ofthe proposed development. The District has
prepared and adopted a Comprehensive Stormwater Management Plan
(October 2003) which should be included in the environmental documents
referenced and commented on by the DSEIS.
5. Short-term impacts from construction must be addressed for Temporary
Erosion and Sediment Control (TESC). A TESC certified professional should
be part of all construction inspection.
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6. The Ahernative 1: Preferred Project does include stormwater facilities for new
development. To the maximum extent practical, the new facilities should
address existing developed areas that may not have adequate water quality or
quantity treatment. Examples of this may be use of treatment facilities such as
oil/water separators for parking areas.
7. To the greatest extent practical, low-impact development methods should be
incorporated into the development plans. Areas such as occasional or
overflow parking should have specially designed pervious surfaces to allow
for direct inftltration of storm water, separation of directly connected
impervious areas, and bio-retention to the maximum extent practical.
8. Under Section 3.2. 1. I-Affected Environment, reference is made to stormwater
discharge to an "artificial lagoon." Using the lagoon for storm water
management, active maintenance would be anticipated. No such provisions
are stated in the DSEIS. Additional detail for responsibility and operations
and maintenance should be provided. Within the lagoon, settlement of
suspended solids is included in one-water quality treatment mechanisms.
However, no discussion is provided pertaining to the maintenance and
operation of the lagoon. Is dredging anticipated ifso how often? Where
would the dredge spoils be disposed? How will the lagoon be accessed?
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Presently pumps circulate the lagoon water, these pumps consume
considerable electrical power and require maintenance and eventual
replacement. The DSEIS must discuss the future operation, maintenance and
expenses incurred by the pump facilities.
Liability issues pertaining to the lagoon must be discussed in this DSEIS and
prior to start of construction, these liability issues must be fully resolved.
Items such as the floating walkway over the lagoon, the unfenced lagoon, the
integrity of the embankment separating the lagoon from the bay, algae
blooms, etc.
11. The DSEIS does not provide any information on the water quality of the
existing lagoon. Before proposing to use the lagoon for water quality
treatment for stormwater flow, testing should be completed for the existing
water quality ofthe lagoon. This will help determine if the addition of
stormwater would result in an improvement or degradation of water quality
for the runoffas well as of the lagoon. We recommend testing for fecal
coliform, metals, salinity, hardness and pH in both wet and dry season.
12. The DSEIS does not specifically state the responsibility for drainage systems
after construction is complete. The operation and maintenance of all installed
drainage facilities must be clearly stated. With the additional private '
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residences rather than a larger single complex, stormwater facilities and
maintenance often are ignored until the point of failure.
13. The location of the proposed Admiralty III complex will require addressing
both surface water runoff and groundwater. During the wet season, the
groundwater is very close to the surface and it will impact any development or
stormwater detention systems. We recommend that a geotechnical engineer
or hydrogeologist licensed in the State of Washington be used to design the
storm water and groundwater system in compliance with the 2001 Department
of Ecology Storm water Management Manual for Western Washington.
The Port Ludlow Drainage District was formed in year 2000 to address drainage issues
within the greater North Bay. Since the formation, the District has developed a
comprehensive plan that includes modeled flows, flow control, treatment, and
maintenance for drainage facilities within the District. The District looks forward to
working with Jefferson County and Port Ludlow Associates in addressing stormwater
issues within the project area.
Very truly yours,
/7!f
/ PLDD Commissioner
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JUN -9 20M
JEFFERSON COUNTY DCn
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