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Home My WebLink AboutLog175 - ... " d (/f/WJ a ~ ~ ~?~ vc) ~ ~a ~ , ~ft~~~;;tf~0~~~ <JuneI4,200il~.a-..d ~ ~ ~ . ~ot;ounty~entofCommunityDevelopment s:;; ~M.l-5t,::J ~ o;;j? 621 Sheridan Street ::;7/vrv"""-7 r Port Townsend, WA 98365 ? b'T6.f. .J- f<A ILt.A t' r TIM 1ZR-,(2.-t /)?13-, IJ{L Dear Sirs, ft)(2.--rL-vIJUI'v w4 9~J6r Weare writing as individual members of the Port Ludlow Village Council Community Development Committee to comment on the Port Ludlow Resort Plan Revision's Draft Supplemental Environmental Impact Statement (DSEIS). The report contains serious flaws and omissions and we strongly recommend that it be completely rewritten in order that we may properly evaluate the impact of the planned resort revisions. The flaws and omissions have been detailed in several letters to the County and in particular the letter from the Ludlow Maintenance Commission Board of Trustees representing over 1000 home, lot and condominium owners. The resort sits immediately adjacent to LMC common areas that are seriously impacted by the proposed changes. Our specific comments on the DSEIS are contained below. Compliance with Shoreline Master Manae:ement Proe:ram The DSEIS states that the lagoon contained within the resort area is not a wetland that falls under the provisions of the SMA. We believe that conclusion is in error. Section 5.160 of the SMA specifically prohibits the building of "residential structures on or over marshes, bogs, swamps, lagoons, tidelands, ecologically sensitive areas or water areas subject to the master program." The lagoon was originally created in 1967 and updated in 1994. The lagoon is within 200 feet of the high tide line and was constructed to mitigate the building of the hotel. By all definitions it is a wetland containing many animal species and will remain a wetland in perpetuity. It is clear to us that the lagoon falls under the restrictions of the SMA and that building over the lagoon should be prohibited. Parkine: : Parking is not adequately analyzed in the DSEIS and we believe that the parking space requirements for the resort revisions as stated in the report are in error. In order to properly determine the parking requirements each commercial building, business and the marina must be analyzed against the county code requirements for parking. This has not been done in the report and we believe that such an analysis will show that more parking spaces are necessary to serve all of the functions planned in the revision to the resort plan. The report indicates that each residential unit will have two parking spaces. However, these spaces are in tandem and we do not believe that they will be used in that manner. In o order to have ready access to each vehicle residential owners will most likely park one gvehicle in the street although the CC&R's of Ludlow Bay Village prohibit on-street ~ parking. This will create safety hazards for emergency vehicles trying to enter the area. ~ This deficiency must be corrected. o:J o ~:..::> Traffic Within the Resort Area LOG ITENl #-17S' " Page _.-1..__ ot_~__ -~ ~~ # "'of I The report contains no analysis of traffic flow and traffic load within the resort. Section 3.904 Item E of County Ordinance 08-1004-99 requires that transportation impacts be analyzed including trip generation, traffic congestion, traffic systems, vehicle and pedestrian hazards, parking and spillover parking. None of these items have been adequately addressed within the resort. Pedestrian traffic will increase significantly with the planned revisions to the resort. No analysis has been done on the effect of the planned revisions to the safety of pedestrians in the resort. There are no pathways or sidewalks proposed within the resort for these people to walk on so they will be forced to walk on the resort roadways creating an undue safety hazard. It is our belief that sidewalks or pathways are required within the resort to protect pedestrians. Environmental Impact to Habitat The DSEIS does an analysis of the impact ofthe resort revisions on the animal and plant habitat within the area. This analysis is flawed since it relies on 12-year-old data for determination of the local animal and plant habitat. The habitat within the resort area has changed significantly in the past 12 years. Wildlife now abounds within the lagoon and surrounding area. Eagles fly and nest in areas immediately next to the resort. The environmental analysis must use current data on the habitat within the resort. This data can only be obtained by on-site visits to the resort and in communication with those who live daily in the area. Stormwater Draina2e Stormwater drainage is only superficially treated in the DSEIS. There is no estimate made of the increase in Stormwater created by the planned revisions. Without this estimate the adequacy of facilities planned to handle the increase cannot be assessed. The North Bay Drainage District, which has responsibility for drainage within the North Bay area, was not consulted regarding the effect of the proposed changes on drainage. The report indicates that a retention pond will be added within the Admiralty complex but does not indicate its location. No analysis is done of the impact that this pond may have on the residences of Admiralty I and Admiralty II. Density of Residential Units Within the Resort The planned resort revision increases the residential density by 56% over the currently approved plan (from 122 to 190 residential units overall). The Port Ludlow community is strongly opposed to this increase in density as it will overcrowd the resort and adversely affect the aesthetics of the area. The community and the County have previously in 1994 strongly rejected a planned increase in density for the resort. We strongly encourage the County to reject it again. The floor plans included in the DSEIS do not represent all the types of residences proposed in the DSEIS and it is not possible to determine from the site maps where each LOG ITEIVi # 17S' Page ~ ~ _.of3___, " " 'l .. of the types of units are located. Additionally, there are no floor plans for any of the proposed commercial buildings. Alternatives We believe that the Alternatives examined by the current draft EIS are fallacious. Specifically, Alternative 2 (1993 Resort Plan) is not the plan that was finally approved and that the Ludlow Bay Village homeowners bought into. The final EIS should include the correct final 1993 Plan, which approves the construction of the 37 room Inn, 53 townhomes and 5 single-family dwellings. Moreover Alternative 3 (1999 Resort Plan-No Action) is a sham which has no validity as it was never approved and would require plat changes that would never be authorized by the current residents of Ludlow Village. We suggest that the final EIS should use a proper comparison of Alternatives as follows: Alternative I-20m Resort Plan Alternative 2-Correct 1993-94 Resort Plan of Ludlow Bay Village Alternative 3-A compromise plan combining the best features of the 1993 and 2003 Resort plans that would be acceptable to both PLA and the Community. Conclusions We believe that the current DSEIS is so deficient that it must be completely rewritten. However, we want to reassure the County that our aim is to have PLA succeed in developing the Resort core into a facility that has both long-term economic viability and lasting benefit to the Community. We stand ready to meet with the developer at any time to examine compromise solutions that would maximize both the viability of the Resort and the overall ambiance of Ludlow Bay Village and the entire Port Ludlow community. Sincerely, LOG ITEM # /75"" Page ,~_of ~