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Home My WebLink AboutLog235 I I I I I I I I I I I I I I I I I I I Port Ludlow Resort Plan Revision Final Supplemental Environmental Impact Statement Jefferson County Department of Community Development May, 2005 LOG-1TEM #_~~~ Page _of - :; .-i ~ ~~ t;.: J.r' J.:' ~l ) COUNT"\/ !.)r.'r~ \f""I'\i!I.'i".."r (..) I , C'/)I"'/TI.....t 1 t ,. '~J 1"" l _ ,I' ., I '!!', '~,l!.,} J :, ,l , .~: I".'! ">,' i & J rrv nIJ~VE! ,OPMENT 621 ;;hr;rid;,:;r1 :';!((;(-":I Port TrwmJ~nc!, \/\I!\ qinG8 /1,/ S(;a!f, j)irce;lor Date: May 18, 2005 NOTICE OF AVAILABILITY OF FINAL SUPPLEMENTAL ENVIRONMENTAL IMPACT STATEMENT FOR PORT LUDLOW RESORT PLAN REVISION NOTICE IS HEREBY GIVEN that Jefferson County has issued a Final Supplemental Environmental Impact Statement (FSEIS) under the State Environmental Policy Act Rules (Chapter 197-11 WAC) for the following project: Application: ZON03-00044, Environmental and Resort Plan Review Applicant: Representative: Mark Dorsey, Port Ludlow Associates LLC Lyn Keenan, Reid Middleton, Inc. Proposal: A revision to the current (1999) Port Ludlow Resort Plan is proposed. The Resort Plan identifies the type and size of facilities to be located within the Resort Area. This FSEIS examines the environmental impacts associated with the alternatives identified in the FSEIS. This FSEIS is not a land use decision on any of the proposed alfematives in the FSEIS. The following documents are also adopted as part of this Supplemental EIS: 1. Final Environmental Impact Statement, Port Ludlow Development Program (Jefferson County, 1993), 2. Final Environmental Impact Statement, Inn at Port Ludlow (Jefferson County, 1993), 3. Final Supplemental Environmental Impact Statement Port Ludlow Marina Expansion (Jefferson County, 2002) 4. Final Environmental Impact Statement, Jefferson County Comprehensive Plan (Jeffemon County, 1998). Location: Port Ludlow Resort, Port Ludlow, WA 98365 Legal Description: Sections 9 and 16, Township 28 North, Range 01 East, WM Required Approvals: Permits and approvals are required from Jefferson County, Washington State Departments of Natural Resources and Fish and Wildlife and US Army Corps of Engineers. No building permit for new commercial or recreational facilities will be issued by Jefferson County until the completion of this EIS, as outlined in Section 3.902 of the MPR Code (Ordinance No. 08-1004-99, adopted October 4, 1999). Document Availability: The FSEIS is available for inspection at The Bay Club at Port Ludlow, 120 Spinaker Place; Port Ludlow Beach Club, 121 Marine Drive; Port Hadlock Branch of the County Public Library and at Building Permits/Inspections Developrncnt I\(:vlcw Divisir'I' Long F~ange Planning P60) 379-44~)O ascalf@co.iefferson.wa.us rAX: (360) 379-4451 For Port Ludlow Resort Plan Revision Page 2 - ~ ..:i .1< the Department of Community Development, 621 Sheridan Street, Port Townsend. The FSEIS can be purchased at SOS Printing (360) 385-4194 located at 2319 Washington Street, Port Townsend for a reproduction fe~. The text and maps of the FSEIS are accessible on the Department website: www.co.iefferson.wa.us/commdevelopmentl. Background data and other relevant information are available at the Department of Community Development. Appeal Period: According to Section 8.1 0.12.e of the Unified Development Code (UDC) the adequacy of an EIS may not be appealed under the provisions of the UDC. Parties of record will be publicly noticed of their appeal right under RCW 36.70 C (LUPA) on the adequacy of this FSEIS at the time of any land use decision issuance. Project Planner: Michelle Farfan Responsible Official: AI Scalf Position: Senior Planner Position: Director Phone: (360)379-4457 Phone: (360) 379-4493 /11ft! IB.2COS Date of FSEIS ( Entered into the Public Record I I I I I I I I I I I I I I I I I I I TABLE OF CONTENTS CHAPTER 1 - SUMMARY ...................................................................................................... 1-1 1.1 PROPOSED ACTION ....... .......... ........................................ .............. ............... .................... 1-1 1.2 LOCATION OF TlfE PRoPOSAL .. ...................................... ........ ..... ..................... ....... ......... 1-2 1.3 PURPOSElOBJECTNES OF TlfE PROPOSAL ............. ..................... ................ ......... ............. 1-2 1.4 PROJECT HISTORY... ......... ............................................................ ............... .................... 1-2 History of the Port Ludlow Community and MPR ................................................................ 1-2 MPR Development Regulations......................... ........................................ ........................... 1-5 SEP A Review..................... ............ .................................. ................ ....... ....................... ........ 1-5 1.5 SUMM.ARY OF ALTERNATIVES.... .................................................. ............... ........ ............ 1-6 Alternative 1: Applicant's Proposed Project - 2003 Proposed Resort Plan...................... 1-7 Alternative 2: 1993 Resort Plan...... .......... ................ .......... ...... ............... .............. ............ 1-11 Alternative 3: Existing 1999 Resort Plan........... ....... ......... ................... .............. ....... ........ 1-13 Alternative 4: Response to Comments......................... ............... ................ ........ ................ 1-15 Alternative 5: No Action..... ......................................... ................ .......... ....... ........ .............. 1-19 1.6 SCOPING NOTICE AND REQUEST FOR COMMENTS.......................................................... 1-21 1.7 SIGNIFICANT ISSUES FOR CONSIDERATION ....................................................................1-21 CHAPTER 2 - PROPOSED PROJECT AND ALTERNATIVES ....................................... 2-1 2.1 DESCRIPTION OF PRoPOSAL.... ................................................. ..... ........................... ........2-1 2.1.1 Name of Proposal.. .... .......... ........................................................... .......... ..... .... ...... ....2-1 2.1.2 Project Sponsor.................. ........................................... .......... .................. .................. 2-1 2.1.3 Project Location.......................................................................................................... 2-1 2.1.4 Existing Project Features............................................................................................ 2-1 2.2 ApPLICANT'S PROPOSED PROJECT AND ALTERNATNES ..................................................2-3 2.3 BENEFlTS/DISADV ANTAGESOF DELAYING IMPLEMENTATION ...................................... 2-14 CHAPTER 3 - AFFECTED ENVIRONMENT, ENVIRONMENTAL IMPACTS, MITI G A TIN G MEA SURES ..................................................................................................... 3-1 3.1 EAR11I ...... ...................... ........ ............................................... .................... ....... ............... 3-1 3.1.1 Affected Environment ..................... ................ ....................................... ..... ....... .......... 3-1 3.1.2 Environmental Impacts............. .............................................................. .................... 3-3 3.1.3 Mitigating Measures................................................................ ............... .................... 3-9 3.1.4 Unavoidable Adverse Impacts................................................................................... 3-10 3 .2 WATER ...................................................................................................... ..... ............... 3-11 3.2.1 Surface Water................................. ................................................... ........................ 3 -11 3.2.2 Groundwater............................................................................................................. 3-17 3.3 PLANTS AND ANIMALS.................................................................................. ........... 3-22 3.3.1 Affected Environment................................. ............................................................... 3-22 3.3.2 Environmental Impacts.................................................................................. ........... 3-29 3.3.3 Mitigating Measures................................................................................................. 3-37 3.3.4 Unavoidable Adverse Impacts.................................................................................... 3-41 3.4 LAND AND SHORELINE USE ............................................................................................3-43 3.4.1 Affected Environment............................................................................................. 3-43 3.4.2 Environmental Impacts .................. .... ........... ............... ......... ............... .................. 3-47 Port Ludlow MPR Resort Plan Final SEIS .j. May 2005 ~ 3.4.3 Mitigation Measures...................................................................................... ........ 3-59 3.4.4 Unavoidable Adverse Impacts......................................................................... ...... 3-61 3.5 LAND AND SHORELINE USE - RELATIONSHIP TO PLANS AND POLICIES .......................... 3-62 3.5.1 Affected Environment............................................................................................. 3 -62 3.5.2 Environmental Impacts .......................................................................................... 3 -68 3.5.3 Mitigating Measures.............................................................................................. 3-72 3.5.4 Unavoidable Adverse Impacts ....................... ................ ......................... .......... ..... 3-72 3 .6 TRANSPORTATION.... ................................................................................................ 3-73 3.6.1 Affected Environment................................................................................................ 3-74 3.6.2 Environmental Impacts ............................................................................................. 3-84 3.6.3 Mitigation Measures............................................................................................... 3-105 3.6.4 Unavoidable Adverse Impacts................................................................................. 3 -106 3.7 PUBLIC SERVICE AND UTILITIES...... ........ ...... ..................................................... .......... 3-107 3.7.1 Fire/Emergency Services.................................................................... ................. 3 -107 3.7.2 Water Service .......... ..................... .................................................. ....... ............... 3-110 3.7.3 Sanitary Sewer Service........... ..................... ................... ................ .............. ....... 3-113 CHAPTER 4 - DRAFT SEIS COMMENTS AND RESPONSES ........................................4-1 4.1 INJRODUCTION ................................................................................................................. 4-1 4.2 COMMENT LETTERS....................................................... ...................................................4-1 4.3 COMMENTS AND RESPONSES ............................................................................................ 4-3 4.3.1 Permitting Requirements 4.3.2 Resort Function 4.3.3 Aesthetics 4.3.4 Wildlife Habitat 4.3.5 Admiralty Open Space and Recreation Facilities 4.3.6 Transportation and Parking 4.3.7 Access to the Shoreline 4.3.8 Marina 4.3.9 Utilities 4.3.10 Environmental Review 4.3.11 Additional Port Ludlow MPR Resort Plan Final SEIS -ii. May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I FIGURE LIST Figure 1 - Vicinity Map.......................................................................................... ..................... 1-3 Figure 2 - Location Map..................................... ........... .................................... .......................... 1-4 Figure 3A - Alternative 1, 2003 Resort Plan... ........................................................... ............. .... 1-8 Figure 3B - Alternative 1, Waterlront Site Plan.......................................................................... 1-9 Figure 3C - Marina Expansion Site Plan............ ............................. .................. ................... .....1-1 0 Figure 4 - Alternative 2, 1993 Resort Plan.................... .......... ....... ................. .............. ............ 1-12 Figure 5 - Alternative 3, 1999 Resort Plan................................................................................ 1-14 Figure 6A _ Alternative 4, 1999 Resort Plan............................................................................. 1-16 Figure 6B - Alternative 4, Waterlront Site Plan........................................................................ 1-17 Figure 6C - Alternative 4"Marina Expansion.... .......... ............ ........... ......... ................. ............ 1-18 Figure 7 - Alternative 5, No Action ..........................................................................................1-20 Figure 8 - Site Topography................................... .............................................. ........................ 3-2 Figure 9A - Alternative 1, Section View Plan ............................................................................ 3-5 Figure 9B - Alternative 1, Section A-A ......................................................................................3-6 Figure 9C - Alternative 1, Section B-B .......................................................................................3-7 Figure 10 - Drainage Basins ............................................................................ ......... ....... .......... 3-13 Figure 11 - Aquifers. ........................... ................ ............. ............... .................... ........... ........... 3 -19 Figure 12A - Conceptual Lagoon Landscape Types ................................................................ 3-38 Figure 12B - Conceptual Planting Plan, West and South Sides................................................ 3-39 Figure 12C - Conceptual Planting Plan, South Side ................................................................. 3-40 Figure 13 - Comprehensive Plan Land Use Designations......................................................... 3-45 Figure 14A - Alternative 1 Building Layouts ...........................................................................3-49 Figure 14B - Alternative 1 Typical Elevations ......................................................................... 3-51 Figure 15A- Alternative 4, Building Layouts ...............................,..........................................3-57 Figure 15B - Alternative 4, Building Layouts........................................................................... 3-58 Figure 16 - Trail Plan............... .............. ....... ...................... ............ .......................................... 3-53 Figure 17 - Shoreline Environment Designations ..................................................................... 3-67 Figure 18 - Existing Traffic Volumes.... ...................... ........... .......... ..... ............................ ....... 3-75 Figure 19 - 2003 PM Peak Hour Volumes (Weekdays)............................................................ 3-79 ~~Bigure 20 ~2003Estimated Weekend Peak Hour Volumes...................................................... 3-80 Figure 21 - Alternative 1, Estimated Weekend Trip Distribution............................................. 3-86 Figure 22 - Alternative 1,2010 Estimated Weekend Daily and Peak Hour Traffic V 01 urnes.......................................................................................................................... ........... 3-88 Figure 23 - Alternative 2, Estimated Weekend Trip Distribution............................................. 3-94 Figure 24 - Alternative 2, 2010 Estimated Weekend Daily and Peak Hour Traffic Volumes................... ..... ................... .................. ................................................ .......... .... ... ... .... 3 -95 Figure 25 - Alternative 3, Estimated Weekend Trip Distributions .........................................3-100 Figure 26 - Alternative 3, 2010 Estimated Weekend Daily and Peak Hour Traffic Volumes ...... ......... .... ....... ....... ........ ........................................ ............... ................ .............. ..... 3-101 Figure 27 - Existing Resort Utilities ....................................................................................... 3-111 TABLE LIST Table 1 - Summary of Environmental Impacts and Mitigating Measures ................................1-24 Table 2 - Comparison of Alternatives ........................ .......... ...................... ............................... 2-13 Table 3 - Accident History....... .......................... ................................. ................................ ...... 3-77 Table 4 - Existing Weekday Levels of Service ......................................................................... 3-81 Table 5 - Existing Weekend Levels of Service ......................................................................... 3-81 Table 6 - Estimated Weekend Trip Generation, Alternative 1 (Proposed Action) ................... 3-85 Table 7 - 2010 Weekend Levels of Service, Alternative 1 .......................................................3-87 Table 8 - Estimated Weekend Trip Generation Alternative 2................................................... 3-93 Table 9 - 2010 Weekend Levels of Service .............................................................................. 3-96 Table 10 - Estimated Weekend Trip Generation, Alternative 3................................................3-99 Table 11 - 2010 Weekend Levels of Service .......................................................................... 3-102 Table 12 - Estimated Weekend Trip Generation, Alternative 4.............................................. 3-104 TECHNICAL APPENDICES (All Technical Appendices are contained in a separate document, available at the Jefferson County Department of Community Development) A ppendix List Appendix A - Jefferson Co. Ord. No. 08-1004-99 Port Ludlow Development Regulations Appendix B - Plants and Animals - Port Ludlow Resort Regional Conditions, GeoEngineers, March 2004 Appendix C - Landscaping Plan, Port Ludlow Resort Appendix D - Jefferson County Comprehensive Plan Parks and Recreation and Shoreline Comprehensive Plan Goals and Policies Appendix E - Port Ludlow 2003 Resort Plan MERU Calculation Appendix F - Year 2010 Background Traffic Volumes and LOS Base Conditions, Geral yn Reinart, PE Appendix G - Fire District No.3 Correspondence Appendix H - List of Acronyms Used Appendix I - Plat of Ludlow Bay Village Mill Pond Assessment, GeoEngineers, September 2004 Appendix J - Resort Parking I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I FACT SHEET Proposed Action: The proposed action is the approval of a proposal by Port Ludlow Associates, LLC (PLA) to complete development of the Plat of Ludlow Bay Village and an adjoining area commonly known as Admiralty III, under a revised Resort Plan that will decrease the range and size of uses from those approved by Jefferson County in the 1999 MPR zoning regulations and the Development Agreement of 2000. The proposed action will be processed as a Major Revision to the Port Ludlow Resort Plan, consistent with Section 3.90 of Jefferson County Ordinance No. 08-1004-99/Development Regulations for the Port Ludlow Master Plan Resort (MPR). The Resort Plan identifies the type and size of facilities to be located within the Resort Complex/Community Facilities Zone within the MPR. The proposed revisions to the Resort Plan will decrease the size of the remaining facilities allowed proposed to be located within the Resort area under Section 3.901. The focus of the Resort will be shifted from a destination conference center orier-ned to a destination resort serving the traveling public, rather than serving as destination conference facility for large groups. New facilities within the Resort zone are proposed to include a new Harbor Master restaurant (relocated), a one new recreation building, a new marina office and store (retail), PLA offices within the former conference building, a new maintenance building, 101 new residential units, a 100-slip expansion of the marina, a central receiving dock, a new shoreline boardwalk/esplanade, additional off-street parking, open space and trails, and associated infrastructure improvements. In 2002, a project-level Supplemental EIS (Port Ludlow Marina Expansion SEIS) was prepared to address the 100-slip expansion of the marina. The proposed action will require Jefferson County approval of a major revision to the Resort Plan and a shoreline permit. A plat alteration or boundary line adjustment may also be required for the plat of Luldow Bay Village, depending on the final approved Resort Plan. These actions will be processed by Jefferson County as a single permit action requiring decisions by both Department of Community Development staff and the Hearing Examiner. The permit process will use information from this environmental document, public comments received during formal public comment periods, and a public hearin~ before the Hearing Examiner. The Hearing Examiner may approve, approve with modifications, or deny the applications requests. This Final SEIS includes a new alternative that was developed by the applicant based on comments received on the Draft SEIS. This new alternative is known as the "Response to Comments" alternative: this alternative reduces the total number of new residential units by 14, and reduces the number of new marina slips to 60. Further, no residential units would be built over water, along the edge of the artificial lagoon. In order to maintain consistent references throughout the draft and final SEIS documents, this Final SEIS continues all references to the ori~inal proposal and other alternatives described in the Draft SETS, while adding an analysis of the Response to Comments Alternative. This approach will allow the final decision maker to fully compare probable environmental impacts of each alternative. Port Ludlow MPR Resort Plan Final SEIS FS-1 -- Port Ludlow MPR Resort Plan Final SEIS FS-2 ~ ~~ I I I I I I I I I I I I I I I I I I I Location: The Port Ludlow MPR is located adjacent to and surrounding Port Ludlow Bay, Jefferson County, Washington. Port Ludlow Bay is located on the west shore of Admiralty Inlet at the mouth of Hood Canal (portions of Sections 9 and 16, Township 28, Range IE). Within the MPR, the Resort complex is located north of the marina, between Oak Bay Road and Port Ludlow Bay. The location of the project is shown in Figures 1 and 2. Lead Agency: Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 Project Proponent: Port Ludlow Associates, LLC 70 Breaker Lane Port Ludlow, W A 98365 Responsible Official: Al Scalf, Director Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 Contact Person: Michelle Farran, /\ssociate Senior Planner, Lead Planner for Port Ludlow Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 Jefferson County File No.: EIS File No. ZON 03-0044 Resort Plan - Maior Revision - MLA 03-00360/ ZON 03-00044 SDPOO 00011, Shoreline Primary Use Substantial Development Permit (Application pending, to be processed after completion of EIS with Resort Plan Revision)-SDPOO-00014, MLA 04-00428/SDP 04-00028 Plat Alteration (application to be considered after decision on Resort Plan Revision)- MLA 04-00255/SUB 04-00014 Adoption of Existing Environmental Document: The following documents are adopted as part of this Supplemental EIS: . Final Environmental Impact Statement, Port Ludlow Development Program (Jefferson County, 1993) . Final Environmental Impact Statement, Inn at Port Ludlow (Jefferson County, 1993) I I I I I I I I I I I I I I I I I I I . Final Environmental Impact Statement, Jefferson County Comprehensive Plan (Jefferson County, 1998) . Final Environmental Impact Statement, Port Ludlow Marina Expansion (Jefferson County, 2002) Authors and Principal Contributors: This Iflaft Supplemental Environmental Impact Statement (Iflaft SEIS) has been prepared under the direction of the Jefferson County Department of Community Development and Lumsden, International Inc..,. Research and analysis was provided by: Reid Middleton, Inc. Document Preparation and Marina Engineering 728 134th Street SW, Suite 200 Everett, W A 98204 (425) 741-3800 Pentec Environmental, Inc. Analysis of the Marine Environment 120 Third Avenue South, Suite 110 Edmonds, W A 98020 (425) 775-4682 GeoEngineers, Inc. Analysis of Upland Habitat and Artificial Lagoon 1550 Woodridge Drive SE Port Orchard, W A 98366 Geralyn Reinart, P.E. Transportation Analysis 1319 Dexter Avenue North Suite 103 Seattle, W A 98109 ESM, Inc. Upland Site Civil Engineering 720 South 348th St. Federal Way, WA 98003 Architectonics, Inc. Upland Site Planning and Building Design 1018 Market Street Kirkland, W A 98033 Required Permits and Approvals: The proposed action is the approval of a Major Revision to the Port Ludlow Resort Plan, consistent with Section 3.90 of Jefferson County Ordinance No. 08-1004-99/Development Regulations for the Port Ludlow Master Plan Resort, and other permits and approvals. The required permits and approvals are as follows: Jefferson County . Resort Plan Revision, Department of Community De'lelopment (Hearing Examiner1 . Construction Plan Approval, :Department of Public Works Port Ludlow MPR Resort Plan Final SEIS FS-3 -- . Boundary Line Adjustment or Plat Alteration (Ludlow Bay Village), - Department of Community Development or (Hearing Examiner) . Preliminary and Final Plat Approval (Admiralty Ill) - Hearing Examiner . Shoreline Primary Use Substantial Development Permits - Department of Community Development Hearing Examiner . Building Permit - Building Department State of Washington . 401 Water Quality Certification - Department of Ecology . Coastal Zone Management Consistency Determination . Hydraulic Project Approval - Department of Fish and Wildlife Federal Government . U.S. Army Corps of Engineers Section 10 Permit - Docks and Pilings (Marina expansion and Boardwalk) Date of Issue of Draft SEIS: April 23, 2004_ Date of Issue of Final SEIS: _May 18, 2005 Location of Final SEIS for Review: Copies of this Final SEIS are available at the following locations for review: Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 Port Ludlow Bay Club 120 Spinaker Place Port Ludlow, W A 98365 Port Ludlow Beach Club 121 Marine Drive Port Ludlow, W A 98365 Port Hadlock Branch, Jefferson County Public Library Port Hadlock, W A 98339 Technical reports, background data, and other relevant information are available at the Jefferson County Department of Community Development. Electronic copies of this FSEIS are available to download and print at the Jefferson County website. The URL for this site is http://www.co.iefferson.wa.us/commdevelopment Copies of the DFSEIS are also available for purchase at SOS Printing, 2319 Washiington Street, Port Townsend W A 98368. (360) 385-4194sale for $_ at the Jefferson County Department of Community Development. Port Ludlow MPR Resort Plan Final SEIS mmD FS-4 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Copies Distributed: Applicant Port Ludlow Associates LLC Mark R. Dorsey, P.E. 70 Breaker Lane Port Ludlow, W A 98365 Jefferson County Departments Jefferson County Public Works 621 Sheridan Street Port Townsend, W A 98368 Jefferson County Natural Resources 615 Sheridan Street Port Townsend, W A 98368 State of Washington Agencies Department of Ecology SEP A Review PO Box 47703 Olympia, W A 98504-7703 Department of Ecology Shorelands SW Region J effree Stewart 300 Desmond Drive Lacey, WA 98503 Department of Natural Resources SEP A Review Dave Deitzman 1111 Washington Street SE Olympia, WA 98504-3135 Department of Natural Resources Jeff Schreck 411 Tillicum Lane Forks, W A 98331 Department of Fish & Wildlife SEP A Review 1111 Washington Street SE Olympia, WA 98504-3135 Tribal Government Port Gamble S'Klallam Tribe 31974 Little Boston Road Kingston, W A 98346 DISTRIBUTION LIST Jamestown S'Klallam Tribe 1033 Old Blyn Highway Sequim, W A 98382 Point No Point Treaty Council Environmental Review 7999 NE Salish Lane Kingston, W A 98346 Utilities Jefferson County Fire District 3 7650 Oak Bay Road Port Ludlow, W A 98365 Port Ludlow Drainage District P. O. Box 65261 Port Ludlow W A 98365 Port Ludlow Roster LMC Governmental Affairs Com Richard Smith P.O. Box 65060 Port Ludlow, W A 98365 Port Ludlow Village Council P.O. Box 65012 Port Ludlow, W A 98365 (2 Copies) Local Organizations Port of Port Townsend 333 Benedict Street Port Townsend, W A 98368 Olympic Environmental Council PO Box 1906 Port Townsend, W A 98368 Port Ludlow Bay Club 120 Spinaker Place Port Ludlow, W A 98365 Port Ludlow Beach Club 121 Marine Drive Port Ludlow, W A 98365 Port Hadlock Branch, Jefferson County Public Library Port Hadlock, W A 98339 Port Ludlow MPR Resort Plan Final SEIS DL-1 __ Notice of Availability: us ARMY CORPS OF ENGINEERS SEATTLE REGULATORY BRANCH ATTN: SUSAN GLENN 4735 EAST MARGINAL WAY SOUTH SEATTLE WA 98124 NATIONAL MARINE FISHERIES SERVICE ATTN: SHANDRA O'HALECK 510 DESMOND DRNE SE SUITE 102 LACEY W A 98503 U.S. FISH AND WILDLIFE SERVICE ATTN: LOU ELLYN JONES 510 DESMOND DRNE SE SUITE 102 LACEY W A 98503 SALLY SMITH looA FAIRWAY LN PORT LUDLOW W A 98365-9724 WILLIAM G. FUNKE DIGGIE FUNKE PO BOX 65334 PORT LUDLOW W A 98365 WENDI WRINKLE 172 HUBBARD CREEK PORT LUDLOW W A 98365 RUTH ALTIS 2408 STATE A VENUE NE OLYMPIA W A 98506 ROGER LARSON 142 RESOLUTE LANE PORT LUDLOW W A 98365 LARRY LAWSON 10140 OAK BAY ROAD PORT LUDLOW W A 98365 JACK MORRIS ALICE MORRIS PO BOX 650 MAPLE V ALLEY W A 98038 RAE BELKIN MATS MATS AREA COALITION 900 OL YMPUS BLVD PORT LUDLOW W A 98365 BERT LOOMIS LOOMIS PROPERTIES 9500 OAK BAY ROAD PORT LUDLOW W A 98365 PAUL TAYLOR SMITH NANCY TAYLOR SMITH 63 SCOTT COURT PORT LUDLOW W A 98365 GRANT COLBY LORI COLBY PMB 526, 2442 NW MARKET STREET SEATTLE WA 98107-4137 WILLIAM D. WEIR 87 SCOTT COURT PORT LUDLOW W A 98365 PETER A. JOSEPH JEANNE M. JOSEPH 6 HERON ROAD PORT LUDLOW W A 98365-9300 FRED P. DELMISSIER DARLENE J. DELMISSIER 9514 NE 13TI1 STREET BELLEVUE W A 98004-3445 DONALD S. CLARK ANITA J. CLARK 8915 SE 56TI1 STREET MERCER ISLAND W A 98040 JANET L. KENNEDY 26 HERON ROAD PORT LUDLOW W A 98365-9300 MCCARRY FAMILY TRUST 2 HERON ROAD PORT LUDLOW W A 98365 ALTON K. LANTERMAN 221 FIRST AVENUE W, SUITE 108 SEATTLE WA 98194 Port Ludlow MPR Resort Plan Final SEIS DL-2 ~ ~~ I I I I I I I I I I I I I I I I I I I I I TIMOTHY J. HOWARD CAROL & GERALD SABER KAZUKO M. HOWARD PO BOX 65487 I 13129 MUIR DRNE NW PORT LUDLOW W A 98365 GIG HARBOR W A 98332-8897 RONALDR.GARTON,PHD I GEORGE C. HILL, TRUSTEE 33 MCCURDY LANE BARBARA F. HILL, TRUSTEE PORT LUDLOW W A 98365 G&B HILL TRUST 8-18-75 I 22 HERON ROAD DALE AND DELLA WITT PORT LUDLOW WA 98365-9300 20 GAMBLE LANE PORT LUDLOW W A 98365 BERNIE J. BROWN I 20730 BOND ROAD NE BONNIE & KENNETH MILLER POULSBO W A 98370 30 GAMBLE LANE PORT LUDLOW W A 98365 I WILLIAM O. MASTER, JR. JUDITH L. MASTER N.ROBERTJORGENSEN 10 HERON ROAD III GAMBLE LANE I PORT LUDLOW W A 98365-9300 PORT LUDLOW W A 98365 COLLEEN J. FERRIS WILLIAM JACKSON I 1619 WINDERMERE DRNE E RIGGAN SHILSTONE SEATTLE W A 98112-3737 61 GAMBLE LANE PORT LUDLOW W A 98365 BURKE F. GIBSON I DOLORES GIBSON ARLETHA & ROBERT BERG 89 CASCADE KY 105 GAMBLE LANE BELLEVUE W A 98006-1023 PORT LUDLOW W A 98365 I THEODORA & BILL CLARK DIANE & RONALD CAMPO 10 TRADER LANE 81 GAMBLE LANE I PORT LUDLOW W A 98365 PORT LUDLOW W A 98365 VINCE PACE JANNET & ROGER WILCOX I 211 GREENVIEW LANE 143 GAMBLE LANE PORT LUDLOW W A 98365 PORT LUDLOW W A 98365 I HERMAN VOSS MARLENE & ROBERT BLACK 60A FAIRWAY LANE 192 MONTGOMERY COURT PORT LUDLOW W A 98365 PORT LUDLOW W A 98365 I LOIS & CLARK RUGGLES SHERRILLANN & KARL BARDEN 125 SEAWAY PLACE 290 OL YMPUS BLVD PORT LUDLOW W A 98365 PORT LUDLOW W A 98365 I DENNIS MADSON MARY & JAMES BRANNAMAN 93 DRIFTWOOD COURT 563 PIONEER DRNE I PORT LUDLOW W A 98365 PORT LUDLOW W A 98365 I I Port Ludlow MPR Resort Plan -- Final SEIS DL.3 . I II' I I MAGGIE & KEITH BROWN BARBARA & LAURENCE NOBLES I 343 CAMBER LANE 81 HARMS LANE PORT LUDLOW W A 98365 PORT LUDLOW W A 98365 I MARGE & THOMAS CARTER WANDA & REINHOLD PFLUGFELDER 103 HERITAGE LANE 135 TIMBER HEIGHTS DRIVE I PORT LUDLOW W A 98365 PORT LUDLOW W A 98365 BARBARA & WILLIAM COLLINS HEATHER & RICHARD ULLMAN I 154 SEA VISTA TERRACE 203 PUGET LOOP PORT LUDLOW W A 98365 PORT LUDLOW W A 98365 HELEN & MAURICE COTTA ELIZABETH & JOHN V AN ZONNERALD I PO BOX 65068 PO BOX 65477 PORT LUDLOW W A 98365 PORT LUDLOW W A 98365 I ESTHER M. DARROW KORIWARD 110 SEA VISTA TERRACE PO BOX 65114 PORT LUDLOW W A 98365 PORT LUDLOW W A 98365 I VICTORIA JO & OLIVER GARDNER DIANE & DWAYNE WILCOX PO BOX 65156 271 MONTGOMERY LANE I PORT LUDLOW W A 98365 PORT LUDLOW W A 98365 JUDITH & GARY HAGEN MERILYNN A. WILSON I 96 HERITAGE LANE 1707 WATER STREET PORT LUDLOW W A 98365 APT. 10 PORT TOWNSEND W A 98368 I ELIZABETH & LEWIS HALE 10552 15TII A VENUE NW MARILYN & WARREN WILSON SEATTLE WA 98177 91 DREW LANE PORT LUDLOW W A 98365 I JOY & DOUGLAS HERRING 227 EDGEWOOD DRIVE Jefferson County Departments PORT LUDLOW W A 98365 JEFFERSON COUNTY BOARD OF I COMMISSIONERS LYNNE & EDWARD JONES 615 SHERIDAN STREET 5517 17TII A VENUE NE PORT TOWNSEND, W A 98368 I SEATTLE WA 98105 JEFFERSON COUNTY PROSECUTING PATRICIA & GREGG JORDSHAUGEN ATTORNEY'S OFFICE I 17435 SE 47TII STREET 615 SHERIDAN STREET BELLEVUE W A 98006 PORT TOWNSEND, W A 98368 SHIRLEY & HARTMUT KEMPKEN JEFFERSON COUNTY HEALTH & HUMAN I PO BOX 65187 RESOURCES PORT LUDLOW W A 98365 615 SHERIDAN STREET PORT TOWNSEND, W A 98368 I DORIS & ANTHONY MONTI 30 DEER HOLLOW ROAD PORT LUDLOW W A 98365 I Port Ludlow MPR Resort Plan -- I Final SEIS DL-4 I I I I I I I I I I I I I I I I I I I JEFFERSON COUNTY PLANNlNG COMMISSION 615 SHERIDAN STREET PORT TOWNSEND, W A 98368 Local Organizations JEFFERSON TRANSIT ENVIRONMENTAL REVlEW 1615 SIMS WAY PORT TOWNSEND W A 98368 W ASlllNGTON ENVIRONMENTAL COUNCIL JERRY GORSLINE 5528 CAPE GEORGE ROAD PORT TOWNSEND W A 98368 JEFFERSON COUNTY PUD #1 PO BOX 929 PORT HADLOCK W A 98339 CHIMACUM SCHOOL DISTRICT #49 PO BOX 278 CHIMACUM W A 98325 FOSTER PEPPER & SHELFELMAN PLLC 1111 THIRD A VB, STE 3400 SEATTLE WA 98101 ATTN: JEFFREYB. TARADAY. DAVIS WRIGHT TREMAINE LLP MARCO DE SAE SILVA 2600 CENTURY SQUARE 1501 FOURTH A VB SEATTLE WA 98101 State of Washington Agencies Office of Community Development: GMP DEPARTMENT OF TRANSPORTATION SEP A REVlEW PO BOX 47440 OLYMPIA WA 98504-7440 DEPARTMENT OF FISH & WILDLIFE RANDI THURSTON WDPW REGION 6 502 HIGH AVE, STE 112 PORT ORCHARD W A 98366 PUGET SOUND WATER QUALITY ACTION TEAM TIM RANSOM PO BOX 40900 OLYMPIA W A 98504 PARKS & RECREATION COMMISSION BILL KOSS PO BOX 42653 OLYMPIA W A 98504-2653 Tribal Government SKOKOMISH NATURAL RESOURCES N 541 TRIBAL CENTER SHELTON W A 98584 Utilities and Services OLYMPIC WATER AND SEWER lNC. 70 BREAKER LANE PORT LUDLOW, W A 98365 PORT LUDLOW DRAlNAGE DISTRICT DICK REGAN PO BOX 65041 PORT LUDLOW W A 98365 News Media PORT TOWNSEND LEADER COPY EDITOR - HEARlNG PO BOX 552 PORT TOWNSEND, W A 98368 PENINSULA DAILY NEWS 922 W ASlllNGTON STREET PORT TOWNSEND W A 98368 THE VOICE PO BOX 65077 PORT LUDLOW W A 98365 Port Ludlow MPR Resort Plan Final SEIS DL.5 __ Commentors on DSEIS not listed above: BOB & CONNIE WILKINSON 114 SKIFF LANE PORT LUDLOW, WA TOM AND MARY ANN CALLAHAN 134 TlMBER MEADOW DRIVE PORT LUDLOW, W A HUGH & ANNE JENINGS SERENDIPITY SLIP #E-29 705 RAINIER LANE PORT LUDLOW, W A 98365 POWERS & THERRIEN, P.S. 3502 TIETON DRIVE Y AKlMA. W A 98902 RAY B. BENEDICT 30 ADMIRALTY LANE, # 321 PORT LUDLOW, W A 98365 DELOS DUNN 385 SOUTH BAY LANE PORT LUDLOW, WA 98365 TERESA L. SMITH 42 HERON ROAD PORT LUDLOW, W A GARY & SUSAN KA YSINGER 46 HERON DRIVE PORT LUDLOW, W A 98365-9300 GARY & KATHY HASHBARGER 38 HERON ROAD PORT LUDLOW, W A 98365 RICHARD ROZELL 41 WINDROSE DRIVE PORT LUDLOW, WA BROWN- NO ADDRESS ALLEN B. & DOROTHY A. WRIGHT 40 KELLER LANE PORT LUDLOW NORTH BAY, W A 98365 MARIAN PETERSON P.O. BOX 65183 PORT LUDLOW, WA 98365 DON PLORDE 55 MCKENZIE LANE PORT LUDLOW, WA 98365 DOUGLAS SCHIEBEL 192 SEA WAY PLACE PORT LUDLOW W A 98365 ED & JAN KNODLE 121 SOUTH KEEL WAY PORT LUDLOW, WA 98365 RALPH ARCHUNG P.O. BOX 65164 PORT LUDLOW, W A 98365 PETERS- NO ADDRESS SOUTH BAY COMMUNITY ASSOC. THE BAY CLUB 120 SPINNAKER PLACE PORT LUDLOW, W A 98365 R.E. SOW A TSKY 654 PIONEER DRIVE PORT LUDLOW, W A 98365 FREDERICK H. KING 83 DUNSMUIR ROAD PORT LUDLOW, W A 98365 GERALD AND DIANE PURDY 14 FOREST LANE PORT LUDLOW, W A 98365 DANIEL & ESTHER DARROW 110 SEA VISTA TERRACE PORT LUDLOW, W A 98365 LENETT A & BUD JOHNSON 64 AMES LANE PORT LUDLOW, W A 98365 LOA BOARD OF DIRECTORS MELANIE LEWIS, PRESIDENT MICHAEL DERRIG 100 A FAIRWAY LANE PORT LUDLOW, WA 98365 Port Ludlow MPR Resort Plan Final SEIS DL.6 ~ ~~ I I I I I I I I I I I I I I I I I I I I I JOHN & LYNNE MARCH DOUG BARKER 322 ADMIRALTY LANE 10233 BELGROVE COURT NW I PORT LUDLOW, WA 98365 SEA TILE, W A 98177 ROBERT H. HERBST II MARK PEARSON I P.O. BOX 65399 1201 LUDLOW BAY ROAD PORT LUDLOW, WA 98365 PORT LUDLOW, WA 98365 I STEPHEN J. FAILLA PAULE & MARGARET A. YTURRI 114 TIMBERRIDGE DRIVE 106 EDGEWOOD DRIVE PORT LUDLOW, W A 98365 PORT LUDLOW, WA 98365 I PL VC DEVELOPMENT COMMITTEE P.O. BOX 65012 PORT LUDLOW W A 98365 I HOWARD & CAROL SLACK 100 PATHFINDER LANE I PORT LUDLOW, W A 98365 VAUGHN BRADSHAW I 61 NORTH BAY LANE, #6 PORT LUDLOW, W A 98365 I JOHN GOLDEN 101 EDGEWOOD DRIVE PORT LUDLOW, W A 98365 I JOHN ARMES 114 DUNSMUIR ROAD PORT LUDLOW, W A 98365 I RA Y B. & MARCET H. BENEDICT 30 ADMIRALTY LANE, #321 I PORT LUDLOW, W A 98365 HARVEY WILLIAMSON I 82 TIMBER HEIGHTS DRIVE PORT LUDLOW, W A 98365 R.P. & MJ. BALCK I 192 MONTGOMERY COURT PORT LUDLOW, WA 98365 I LUDLOW MAINTENANCE COMMISSION P.O. BOX 65060 PORT LUDLOW, WA 98365 I I I Port Ludlow MPR Resort Plan -- Final SEIS DL.7 . I "., CHAPTER 1 - SUMMARY 1.1 Proposed Action The applicant's proposed action is the approval of a proposal bv Port Ludlow Associates, LLC (PLA) to complete development of the Plat of Ludlow Bav Village. adjoining aquatic lands, and adjoining uplands commonly known as Admiralty ill, under a revised ResOlt Plan that will decrease the range and size of uses from those approved by Jefferson County in 1999 and 2000. The proposed action will be processed as a Major Revision1 to the existing Port Ludlow Resort Plan and will result in the reduction of the scale of the resort function from that presently allowed under Section 3.901 of Jefferson County Ordinance No. 08-1004-99. POlt Ludlow Associates proposes to construct 101 atttached dwelling units in Ludlow Bay Village and Admiralty III, 100 new marina slips in adjoining aquatic lands. a new and relocated Harbormaster Restaurant (and demolition of the existing restaurant building), a marina office and store, a private recreation facility, a maintenance building, a central receiving dock, emergency helipad, and surface parking for 387 vehicles. The current Resort Plan was approved in 1999 as part of Jefferson County Ordinance No. 08-1004-99/Development Regulations for the Port Ludlow Master Plan Resort (MPR); the approved Resort Plan (1999 ResOlt Plan) is described in Section 3.901 of that Ordinance. Section 3.904 of this Ordinance states that detailed environmental review for future resort development is required, and that a project-level Supplement to the Port Ludlow Development Program EIS (finaled April 1993), or new stand-alone EIS shall be prepared. The proposaled revision to the Resort Plan (~2003 Resort Plan::) will shift the focus of the Resort from a conference facility serving large groups, to a destination resort for the traveling public. The proposed revision will eliminate those features and amenities in the 1999 Port Ludlow Resort Plan and associated development regulations that are designed to accommodate large conference groups. The proposed revision will reduce the overall amount of resort development at build-out and will include fewer commercial and public facilities, but it will include more residential units than the existing 1999 Port Ludlow Resort Plan. This SEIS is designed to meet the requirement set forth in Ordinance No. 08-1004-99, Section 3.902 and addresses project- specific and cumulative impacts anticipated due to completion of development under the 2003 Proposed revision of the Port Ludlow Resort Plan. The following documents are also incorporated by reference adopted as part of this Supplemental EIS: Draft and Final Environmental Impact Statement& Port Ludlow Development Program (Jefferson County, 1993), Draft and Final Environmental Impact Statement~ Inn at Port Ludlow (Jefferson County, 1993), Draft and Final Environmental Impact Statement~ Port Ludlow Marina Expansion (Jefferson County, 2002), and Draft and Final Environmental Impact Statement~ Jefferson County Comprehensive Plan (Jefferson County, 1998). J Under the existing Jefferson County Code regulating the Port Ludlow Master Planned Resort, a "Maior Revision" includes anv increase in the intensity of use, or in the density of development described in the 1999 ResOJ1 Plan. Although the currentlv proposed Resort Plan would significantly decrease the intensitv of commercial uses. it would increase the intensity and density of residential uses. It is therefore classified as a "Maior Revision" which means that the proposal must be approved bv the Hearing Examiner rather than the Department of Community Development. Port Ludlow MPR Resort Plan Final SEIS 1-1 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 1.2 Location of the Proposal The Port Ludlow Master Planned Resort (MPR) is located adjacent to and surrounding Port Ludlow Bay, Jefferson County, Washington. Port Ludlow Bay is located on the west shore of Admiralty Inlet at the mouth of Hood Canal. The changes addressed in this SEIS affect the marina and Resort Complex/Community Facilities zone of the Port Ludlow MPR. This zone is specifically located on uplands adjacent to and north of the marina (portions of Sections 9 and 16, Township 28, Range IE). The location of the project is shown in Figures 1 and 2, located on pages 3 and 4. 1.3 Purpose/Objectives of the Proposal The objectives of the propos&ed re'.'isions to the Resort Plan are: . To respond to shifting market trends and reduced demand for large conference facilities in the Pacific Northwest. . To sustain the growth of the Port Ludlow community. . To improve customer satisfaction with the condition of the facility. . To upgrade and enhance services and amenities provided in the Resort Complex/Community Facilities Zone. . To minimize potential environmental impacts. . To comply with Jefferson County development regulations. 1.4 Project History History of the Port Ludlow Community and MPR The Port Ludlow community was established in the mid-1800s as a logging, shipbuilding, and sawmill town. Pope & Talbot purchased the Port Ludlow sawmill and adjacent property in the 1870s. By the 1880s, Port Ludlow was comprised of a sawmill, log dump, numerous houses, a hotel and other facilities. The sawmill was permanently closed in 1935 and subsequently dismantled. The existing homes were moved to Port Gamble. Development of the current Port Ludlow Resort Master Planned Resort (MPR) was initiated in the late 1960s. The multi-phase Port Ludlow MPR encompasses 1,800 acres surrounding the inner portion of Port Ludlow Bay. The MPR as a whole includes residential, commercial, and recreational/resort development, as well as significant tracts of permanent open space. The original owner, Pope and Talbot, Inc., transferred ownership to Pope Resources in 1985. The MPR was then managed by Olympic Real Estate Management, a subsidiary company of Pope Resources until 2001, when Pope Resources sold its Port Ludlow assets to the present owners, Port Ludlow Associates, LLC. The Resort portion of the MPR is located on the site of the original Port Ludlow community- along the north side of Port Ludlow Bay, between Oak Bay Road and Port Ludlow Bay. Resort development of this area began in the late 1960s, with construction of the 285-slip marina, the Harbormaster Restaurant, and the homeowners' Beach Club. A conference center building and Port Ludlow MPR Resort Plan Final SEIS 1-2 May 2005 ~ Vicinity Map - Figure 1 Port Ludlow Resort Plan FSEIS \ , , "' Project Area north N.T.S. ~ - , , , .~ \ ~ QIi}VJlleRr:t. \Nalkerlz,.: '?t- ---' r~ . g,... -0 ~....... if ~. Q:. CIJ o I I .'/ ~ ) I '-- 1 I I - Port Ludlow Master Plan Resort Boundary ---, I r ~ I , L ,...- - - / Teal L' - ~ ~~ Port Ludlow MPR Resort Plan Final SEIS 1.5 May 2005 --- I I I I I I I I I I I I I I I I I I I residential units were also constructed in the Admiralty I and IT areas within the northeastern portion of the Resort. The Inn at Port Ludlow (formerly known as the Heron Beach Inn) was constructed in 1994, and adjacent townhomes were constructed beginning in 1994. The artificial lagoon was first created in 1967 and expanded to its present size in 1994 in conjunction with construction of the Inn and townhomes and the plat of Ludlow Bay Village. MPR Development Regulations Jefferson County development regulations pertaining to the MPR have evolved over the last fifteen years, most recently after adoption of the 1998 Jefferson County Comprehensive Plan as required by the State of Washington Growth Management Act. Since 2000, development within Port Ludlow has proceeded under the "Port Ludlow Development Agreement" and Jefferson Co. Ordinance No. 08-1004-99 (an attachment to the Development Agreement), which sets forth detailed development regulations for the MPR. Ordinance No. 08-1004-99 is reprinted in Appendix A of this document. Under the MPR regulations, the Port Ludlow MPR is divided into several zoning districts, one of which is the "Resort Complex/Community Facilities Zone." Section 3.90 - "Resort Development" of Ordinance No. 08-1004-99 describes the approved "Resort Plan" and identifies the specific facilities (and their sizes) that are to be developed within the Resort Complex/Community Facilities Zone. Changes to the Resort Plan that decrease the listed sizes are allowed. Under Section 3.90 of the MPR regulations, the Resort at Port Ludlow was envisioned to be a destination resort for large groups, as well as the traveling public. The Resort facilities were anticipated to encompass 498,300 square feet of development, not including residential structures. Facilities were to include a 275-room hotel, two restaurants, resort retail, a conference center, a recreation complex, museum or interpretive center, amphitheater, youth center, an expanded marina, and public open space. Since adoption of the MPR regulations, it has become evident that a destination resort oriented to large conference groups is not feasible for Port Ludlow and that the resort must be oriented more to the traveling public. A change to the Resort Plan as outlined in Section 3.906 of Ordinance No. 08-1004-99 is therefore proposed. In addition to the above market factors, the 1994 plat of Ludlow Bay Village (located within the Resort zone) and subsequent construction of townhomes within this plat, has legally and practically limited the ability of Port Ludlow Associates, LLC to site some of the larger facilities anticipated by the MPR regulations. An attempted Redevelopment Agreement was proposed to reconcile the conflicts between the MPR regulations and the plat, but this agreement failed for lack of ratification. The failure of the Redevelopment Agreement legally and practically makes implementation of the existing MPR Resort Plan infeasible. SEPA Review SEPA review is required for this project pursuant to WAC 197-11, SEPA Rules and Section 3.90 of Ordinance No. 08-10-1004-99. Jefferson County is using phased review, as authorized by SEPA (W AC197-11-060(5)(b)) and Section 3.902.1 of Ordinance No. 08-1004-99 in its review of development projects within Port Ludlow. I I I I I I I I I I I I I I I I I I I Previous SEP A review for projects within the Port Ludlow Resort area has coincided with the permitting process. In 1993, the MPR underwent a County permitting process for continued development. Two EIS documents were prepared at that time - a programmatic document and a project-level document. The 1993 programmatic EISfor the Port Ludlow Development Program addressed the proposed build-out of the residential and commercial components of a Port Ludlow Master Plan, including build-out of the Resort. The 1993 project-level EIS for the Inn at Port Ludlow addressed proposed development within the southern portion of the Resort: specifically, construction of the Inn at Port Ludlow (i.e., Heron Beach Inn), the addition of 72 residential units and 2,500 square feet of commercial space, construction of a Town Hall, landscaping, parking for 400 vehicles, placement of riprap along the marina parking lot, replacement of underground fuel tanks with partially aboveground tanks, expansion of the artificial lagoon, and expansion for the marina and upland marina facilities (office, etc.). 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 SEPA 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 pennits 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 Resort Plan revision (Alternative 1) and twe four alternatives are evaluated in this I}mft: Final Supplemental EIS. The twe four additional alternatives are based on_-include: ~two alternative development plans for the Resort area - the Resort Plan as proposed in 1993, and the Resort Plan approved by Jefferson County in the MPR code in 1999.. . A Response to Comments alternative developed in response to comments received on the Draft SETS, and Port Ludlow MPR Resort Plan Final SEIS 1-6 May 2005 ~ . The "No Action" alternative, or stopping all new development. Under this alternative, the site would remain in its partially developed state. subiect to potential future development proposals.) The No Action alternative was also evaluated in the 1993 Port Ludlow Develovment Prof.?ram EIS, and 1993 The Inn at Port Ludlow EIS (adopted as part of this SEIS). The 1999 Resort Plan is considered the "No i\ction" alternative for this analysis; if no change to the Resort Plan is made at this time, development may continue under the 1999 Plan, per existing Count)' regulations and the existing practical constraints related to the plat of Ludlow Bay Village. Other "No .A.ction" alternatives were evaluated in the 1993 Port Ludle~r DCilclepmcnt PNJgmm E!S, and 1993 Thc Inn at Port Ludlew E!S (adopted as part of this SEIS) in which the "No f.ction" alternatives '.vere no further development e.g., the site remaining in its partially developed state, subject to potential future development proposals. The passage of time since 1993 has not changed the analyses of those "No f.ction" alternatives and those analyses are not repeated here. .A.11 tHree All-alternatives except No Action would result in build-out of the Resort area, including a 100 slip expansion of the marina. Alternative 1: Applicant's Proposed Preferred Project - 2003 Proposed Resort Plan The 2003 Resort Plan proposes that the Resort serve as a destination resort for the traveling public, as opposed to large conference groups. This change will decrease the size of many resort facilities identified in the 1999 regulations and will increase the number of residential dwellings. Conferences will still be accommodated, but on a smaller scale and will be housed in existing facilities such as the Inn at Port Ludlow, the Bay Club, and the relocated Harbormaster Restaurant. Phasing of the new development is addressed in Chapter 3.4 of this FSEIS. At build-out, development within the resort area will include the following existing and new facilities: 191G residential units (the 90 -89 existing units within Admiralty I and II and Ludlow Bay Village (in 2005) + 101 new residential units) Inn at Port Ludlow (37 rooms), including restaurant and lounge (existing) Reconfiguration of the access to the Inn at Port Ludlow to restrict access to/from Heron Road Harbormaster Restaurant - 5,000 square feet (relocated) Private Recreational Facility - 7,500 square feet (new) Private LMC Beach Club Recreational Facility (existing) Marina - 380 slips (280 existing slips + 100-slip expansion) Central Receiving Dock (new) Permanent Emergency Helipad (new) PLA Offices (within existing conference building) Maintenance building - 2,900 square feet (new) Off-street parking (expanded and reconfigured, with new elevator) Lagoon Landscaping (new) Shoreline Boardwalk/Esplanade (new) Open space, trails (existing and new) A conceptual site plan for Alternative 1 is shown in Figures 3A.L -ami-3B, and 3C. Port Ludlow MPR Resort Plan Final SEIS 1.7 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Alternative 1 - Figure 3A Port Ludlow Resort Plan FSEIS MARINA 380 SUPS 2003 Resort Plan - '" o Ul () ~ '" o z " '" '" o o )>- Z 0"'0 ~r:~ -< ~8 ~~I UlO )>-< , g:c ': O~ "'Ul 2c z'" "'['1 r -<~ . , - - - - - - - - - - - - - - - - '" - ~~ \ \ \ \ \ \ ~ .- -' -....j I\..) 1.0 ~~ 0:;':)> d AZ~ ;;! r i5@@ C(XI(XI ::U>eVXV "'''' @C>.C>. ~:E:E ~.................. o.(X).~ ...-'---'- -" ,---- ------- ----~ -.------- ...----.------_. o :c :E --~ \~ \ / /~/ u; ~ r~ ------------..... ''--... @ <D " (XI, ~ ~_. 24' c '1)- '1) m- JJ- '1)- SJ-,~ ^- z- G)- r- 0_ -l 81 I ~ JL=~J l iL - \ c' o 'I. e> I 155m Ii ; ~~51n ~13 ~ >' IOcunoC"'l tOlD .....--.. ::, ~ > c m ~ o .oJ o :;:) .oJ ... a: o IL o z < ...I IL ::l \\ ~ ~~ Port Ludlow MPR Resort Plan Final SEIS 1-11 May 2005 ~ I I I I I I I I I I I I I I I I I I I Alternative 2: 1993 Resort Plan Alternative 2 is the Resort Plan as identified in the 1993 Environmental Impact Statements prepared for Port Ludlow. This plan is similar to the Alternative 1 - 2003 Applicant's Proposed Resort Plan, but has slightly fewer residential units, new retail commercial space, a new town hall and marina manager's efH€eoffice, but no new maintenance or recreation facility-:-. This alternative is included for evaluation because it addresses build-out of the entire "Resort Complex! Community Facilities" zone, in a manner that places more of the new residential development within the Admiralty area, and introduces a small amount of Resort retail use and a community "Town Hall" to the Ludlow Bay Village area. -At build-out, the 1993 Resort Plan would include: 186 residential units (64 existing in Admiralty I and II in 1993 + 122 new units in Admiralty and Ludlow Bay Village) Retail commercial building - 2,500 sq ft (new) Heron Beach Inn (now know as the Inn at Port Ludlow)- 37-room Inn, including restaurant and lounge (existing in 2005) Harbor Master Restaurant - 5,000 sq ft (retained in its current location, and existing in 1993) Town Hall- 1,850 sq ft (new) Marina - 380 slips (280 existing slips + 100-slip expansion) Marina manager's office (new) Off-street parking Open space, trails (existing) The conceptual site plan for Alternative 2 is shown in Figure 4.- It is acknowledged that given the continued townhome development within the plat of Ludlow Bay Village, this Alternative could no longer be fully developed as described above. If townhome development were to stop, however, many features of this Plan could still be constructed within the Resort area. I I I I I Alternative 2 - Figure 4 Port Ludlow Resort Plan FSEIS I I I I 1993 Resort Plan Port Ludlow MPR Resort Plan Final SEIS 1-13 May 2005 IDJmaI I I I I I I I I I I I I I I I I I I I Alternative 3: Existing 1999 Resort Plan Alternative 3 is development of the Resort as described in Section 3.901 of the existing MPR regulations. No revision to the Resort Plan would be approved. At build-out, development of Alternative 3 would originally have provided for 498,300 gross square feet of Resort development, described as follows: Hotel Guest Rooms - 275 rooms (37 existing in 1999,238 new) Restaurants - 59,000 square feet One 200-seat, year-round restaurant (new) One 125-seat, seasonal restaurant, near the marina (new) Also includes hotel lobby & registration area, spa, kitchen offices, and storage rooms (new) Lounge, 1 year-round, 125 seats - 5,000 sq ft (new) Resort Retail- 2,500 sq ft (new) Plus assoc. storage - 1,400 sq ft Conference Center, associated with, and physically part of Hotel Building - 22,000 sq ft (new) Plus support areas and storage - 8,000 sq ft (new) Indoor tennis courts - 26,000 sq ft (new) Indoor sports and pool complex - 13,500 sq ft (new) Structured/underground parking -119,000 sq ft (new) Museum or Interpretive Center -7,500 sq ft (new) Support Buildings - 12,000 sq ft (Maintenance, Warehousing, Housekeeping - new) Youth Center - 4,000 sq ft (new) Marina Expansion - 280 existing slips + 100-slip expansion Amphitheater - One (new) Yacht Club - One (new) Four Single-Family Dwellings, and one-l--te 5-unit townhome structure (square footage not part of Resort square footage) All existing town homes (in 1999 - 1 single-family dwelling, 13 townhomes, M condominiums units - square footage not part of Resort square footage) This alternative also includes partial filling of the artificial lagoon, assuming necessary environmental permits could be obtained. An illustration of this Resort Plan is shown in Figure 5. It is acknowledged that given the continued townhome development within the plat of Ludlow Bay Village, this Alternative could no longer be fully developed as described above. If townhome development were to stop, however, many features of this Plan could still be constructed within the Resort area. 'I I I I I I I I Alternative 3 - Figure 5 Port Ludlow Resort Plan FSEIS I ,I I ! I 1999 Resort Plan Port Ludlow MPR Resort Plan Final SEIS 1.15 May 2005 IDJmaI I I I I I I I I I I I I I I I I I I I Alternative 4: Response to Comments Alternative 4 was developed as a response to comments received on the Draft SEIS concerning impacts on residential density, construction of residential units over the artificial lagoon, the adequacy of parking in the marina area, and the appropriate size of the marina expansion. Alternative 4 is similar to Alternative 1, but would result in slightly less residential density (7 fewer units in Admiralty III, and 7 fewer units in LBV), a smaller marina expansion (60-slips vs. 100 slips for Alternative 1), and no buildings extending over the edge of the artificial lagoon. At build-out, development within the resort area would include: 177 residential units (the 90 existing units within Admiralty I and II and Ludlow Bay Village in 2005 + 87 new units) Inn at Port Ludlow (37 rooms), including restaurant and lounge (existing) Reconfiguration of the access to the Inn to restrict access to/from Heron Road Harbormaster Restaurant - 5,000 square feet (relocated) Private Recreational Facility - 7,500 square feet (new) Private LMC Beach Club Recreational Facility (existing) Marina - 340 slips (280 existing slips + 60-slip expansion) Central Receiving Dock (new) Permanent Emergency Helipad (new) PLA Offices (within existing conference building) Maintenance building - 2,900 square feet (new) Off-street parking (expanded and reconfigured, with new elevator) Lagoon Landscaping (new) Shoreline Boardwalk/Esplanade (new) Open space, trails (existing and new) A conceptual site plan for Alternative 4 is shown in Figures 6A, 6B and 6C. I I I I I I I I I Alternative 4 - Figure 6A Port Ludlow Resort Plan FSEIS I I I I I I Response to Comments - - - - - - - - - - - - - - - - '" \ \ \ \ \ \ '" ~ (f) je =i ~ fTl II' ""U g. s;: z ~~ - . -::-~ ~~ -f o~)> o ~z~ ~ I@@ o e"'''' ::0 X~)(~ "'''' @o,"'- to,'I: 'I: ~" q~~ .- ------_.~ ---- -.....- \ ....-~ ~~ ---- ~- o I 'I: -~ ~,- / / z Z'" ",n -n "Cll Og: :Da -Ie: r- eCll 00 r~ O~ :E~ '------ ~-- -- U; ~ c; @ 24' ,~ DRIVE~ to Oak Bay Rd \ A II II I I I / I / 1 ( ---...... -0 :J: 1 0 co I z a '" ) 0 ::J 0 ::0 ( )> 0 \ ::u III ~ 0- I I I I \ 101 I I 1 \ I fl g .QI~~ I I I \ ~ I I \ I -->'" '-;--:::--.--- 1 I 1 ;0'" I,~ 1 I I I ^~ I I , Z'" II 0- Cl~ 0 "- l/) I I I ~ :ri I \ "- " " '0 " '" l( \. " , " " y " " 8 Q " .. " " ']b ,'" " " '] " '] --< )>- 2 , I>> 0" 0 " '1 I r ~~~ I I I I I -- --I ;- 1 I L___ ()~ ': I I 8~ I L_____ ;ol/) 2e 2;0 Cl'" r -<~ OJ a: -- :5 - - IEZ, I ... Ie m !.. ;i!~ ::J '" lele"'le ~!i ~ iiliil~iil z It;; ~ ~~~~ ~/j ~ o N-O CD OlOl i ('roI1"')__ ...- I o z C ..J II. j > c m ~ o ..J C :;) ..J I- a: o D. - Alternative 5: No Action This alternative will result in no additional development within the Resort zone (either the Admiralty area or Ludlow Bay Village) at this time, no expansion of the existing marina, and no reconfiguration of the parking and access for the Inn at Port Ludlow. Alternative 5 is shown in Figure 7. Port Ludlow MPR Resort Plan Final SEIS 1-19 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Alternative 5 - Figure 7 Port Ludlow Resort Plan FSEIS No Action 1.6 Scoping Notice and Request for Comments The scoping period for the Draft SEIS extended from July 2 to August 31,2003. Notice of the scoping period was published in The Port Townsend and Jefferson County Leader on July 2, 2003. A public scoping meeting was held at the Port Ludlow Beach Club on July 16, 2003. Both written and oral comments were received. A full copy of the scoping comments is on file with the Jefferson County Department of Community Development. 1.7 Significant Issues for Consideration Major issues identified during the scoping process for the 2003 Resort Plan relate to: 1. Increased Residential Density vs. Reduced Commercial and Recreational Facilities . The proposed 2003 Resort Plan increases the number of residential units from that currently allowed and reduces the size and number of commercial and recreational facilities to be constructed within the Resort. The current (1999) Resort Plan permits the then-existing 14 units in Ludlow Bay Village and 64 units in Admiralty I and II, as well as nine new residential 87 residontial units; the proposed 2003 Resort Plan would permit 1919 residential units in Ludlow Bay Village, and Admiralty I, II, and III.. Additionally, the 2003 Resort plan would not include elements such as a large hotel, an additional restaurant, resort retail, a new conference center, indoor tennis courts, and a museum or amphitheater. 2. Alteration to the Plat of Ludlow Bay Village The plat of Ludlow Bay Village, a commercial and residential mixed-use subdivision, is located within the southern portion of the Resort complex. This plat was recorded in 1994, prior to adoption of the current MPR regulations. The plat created lots and tracts for 53 town home units, five single-family units, the artificial lagoon, the Inn at Port Ludlow, the Harbormaster Restaurant (in its current location), open space, and roadway and infrastructure improvements. The plat is not consistent with either the currently approved Resort Plan (1999), or the proposed 2003 Resort Plan revision, but continues to be developed. To date, 25 townhome units within the eastern portion of the plat, and one single-family dwelling, have been built. Section 3.903 of the MPR Regulations state that any vested development rights for undeveloped property within the RC/CF zone (i.e., undeveloped lots within the plat of Ludlow Bav Village) must be "... withdrawn, vacated or permanently released" prior to issuance of any development permit if these development rights are not provided for in the approved Resort Plan. In order to develop any portion of the proposed 'J003 Resort Plan (i.e., ;,\lternati','e 1), PLA wH+ will be required to address this issue. Subsequent to approval of a Resort Plan by the Hearing Examiner, and prior to issuance of any development permits, a determination wil be made as to the consistency of the Resort Plan with vested development ri~hts. A Boundary Line Adiustment application or submit a request for Port Ludlow MPR Resort Plan Final SEIS 1-21 May 2005 IDJmaI I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I a Plat Alteration for that portion of the plat owned or controlled by PLA may then be required. The applicant's proposed 2003 Resort Plan, while similar in over-all character to the 1994 plat, provides for increased residential density (i.e., 88 LBV residential units, vs. 58 residential units in the ori ginal plat of LBV f*i*); this increased residential density within Ludlow Bay Village is of concern to some existing townhome residents and property owners. 3. Parking and Vehicular Traffic . The proposed 2003 Resort Plan, including the expansion of the marina, will create demand for additional parking, especially in the vicinity of the shoreline. Residents have questioned if WiH sufficient parking will be available during the peak summer months..-+ Existing traffic circulation in the vicinity of the Inn at Port Ludlow and the adjacent townhomes is difficult for the town home residents. WiH Ithe proposed development should not be allowed to exacerbate thise problem? 4. Beach Access and Trails . Access to public beach areas is currently not signed. There are no clearly defined pedestrian trails through the Resort area. Residents believe How will t!he new development should address this problem..-+ 5. Stormwater and Water Quality . IWhat is the proposed proiect will add new structures to the Resort area. The impact of additional development on the existing storm drainage system and water quality-+ should be addressed. Major issues related specifically to the marina expansion were identified during the scoping processes for the Port Ludlow Marina Expansion Draft SEIS in the fall of 2001, and are summarized below: . Impacts of the marina expansion on adjacent properties; specifically - views, property values, and impacts to ingress and egress to an adjacent dock; . Impacts of the marina expansion to shoreline resources, wildlife habitat, and ESA listed species; and, . Impacts of the marina expansion on water quality. Please refer to the 2002 Port Ludlow Marina Expansion EIS for a more detailed description of these issues. Port Ludlow MPR Resort Plan Final SEIS May 2005 ~ 1-22 :a: "'C C ct tn - (,) co ~ E co - c Q) E c o - oS; C W - o >- - co E E :::J en . ,.... Q) :0 co I- Lt) CP C > 0 ;;:: ca (,) c<( ti) 0 ;::z tn ~ :::J tn CO Q) :a: en c += CO en E ~ CP > :.;::::: ca c ~ CP - 4 ,gen CP- en C C CP E 8.E en 0 ~O C ca ii: t:: o en CP a: 0) 0) 0) ..... 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I .9 ~ 's V5 I I ~ ,&) .9 en ll) l< o ,&) C<l U e ~ I I c: ... il CI) a: a: iJ 'gw ~, I I I I I I I I I I I I I I I I I I I I Table 1 as originally shown in the April, 2004 Draft SEIS Table 1 Summary of Environmental Impacts and Mitigating Measures Earth Environmental Impacts Topography No major alterations to Similar to proPQsed Alteration to site slopes site topography. project. <{long Oak Bay Road. Soils and Subsurface Earthwork required to Similar to proposed Moti~significant Materials construct new buildillgs project. earthwork required to and infrastructure. construct new buildings and infrastructure. Eastern half of lagoon to befiIled. ... /// Large, heavy structures in areas of fiIl would require extensi ve ground improvement techniques. InstaIlation of IO()-- 130, Similar to proposed Similar to proposed 24" diameter steel piling project. project. will re~u1t 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. I 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, propgsed. In-water construction Similar to proposed Similar to proposed activities increase project. project. potential for leakage of petroleum products; driving of 100 - 1$0 pile~ will temporarily increase localized turbidity and increase suspended sediment concentrations. Potential incremental Similar to proposed Similar to proposed increase ingrlly/black project. project. water discharge, ancl bilge water dischaI;ge, 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. I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 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 Sirrlilar to proposed Similar to proposed monitoring program pr()ject. project. " Plants and Animals , / Environmental Impacts Upland Vegetation Land clearing and Simila:rto proposed Similar to proposed increased human~C:ti -vi~y project. project, to result in minol'~hange inthedistribu!ion'bf h~bit~ttyPes llnd values. F()raging ea,gles may Similar to proposed Similar to proposed avoid Resdrt 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. Bald Eagles Potential temporary Similar to proposed Similar to proposed disruption of foraging project. proiect. I 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. pwject. may avoid pwject area during construction, Increased overwater coverage and increased shading may result in minor decreases in microalgae and benthic .. productivity. Avian Species Tempprary impacts Similar to proposed Similar to proposed includ~ disruptionof project. project. foraging behaVior and may result in bird species avoiding project area during construction, Mammals MaII1Il1alian 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. A vian Species & Mammals No mitigation is Similar to proposed Similar to proposed proposed. project. project. I I I I I I I I I I I I I I I I I I I I Land Use I Environmental Impacts I I I I Mitigating Measures I I I I I I I I I I I I Construction activities to result in temporary increase in noise, dust and vehicular and barge traffic, New residential and limited commercial development. Resort facilities to serve the traveling public Expansion consistent with and MPR land use designations. Upland constructipn tppe limited to 7 :OOam.. 6:00pm, Mpp.- S~t. Marina construction to be limited to 8:00 am - 8:00 Pm, non-holidays weekdays & Saturdays, Stationary equipment to be po~itioned as far as possible from residential properties. All mufflers to be properly maintained. Dust will be suppressed with wetting techniques. Energy efficient equipment will reduce emissions. Project provides for an economically sustainable Resort. Residential & commercial uses to be separated. Existing arch, character to be maintained. New marina docks will be located to provide adequ. fairway & maneuvering Similar to proposed project. Similar to proposed project. Similar to proposed project. Similar to proposed project. Similar proposed project. Similar to proposed project. Similar to proposed project. Similar to proposed project, Similar to proposed project. Similar to proposed project. Residential & commercial uses less separated. Similar to proposed project. Similar to proposed project. Similar to proposed project. Most significant new construction, Most significant new residential &commercial q.evelopment. Resort "lities to serve large c ence groups. Similar to proposed projeCt. Similar to proposed project. Similar to proposed project. Similar to proposed project. Similar to proposed project. Similar to proposed project. Similar to proposed project. Project would not provide for a sustainable Resort. Least separation of res. and comm. uses Similar to proposed project. Similar to proposed project. I 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 Si~lar to proposed Master Program consistent with the project. pr()J~ct. Shoreline Management Master Pro~ram, 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 prpject. project. Bay.:I{d. Medium impact to Similar to proposed Similar to proposed e'Xisting 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. I for Scott dock. I I I I I I I I I I I I I I I I I I I I Transportation Environmental Impacts I I I I I I I I Mitigating Measures I I Public Services and Utilities Environmental Impacts I Fire/Emergency Services I I Water Service I I I I 887 new daily vehicular trips generated, 97 of these trips during the peak hour. Increased boat traffic at the marina. Adopted LOS for County intersections will not be exceeded, Side-street movements @ the SR 104 intersections with Paradise Bay Rd, , and Beaver V alley ~Road will continue to exceed standards, but not as a result of project traffic. New off-street parking to be provided. Signed pedestrian trails to be provided. None required Incremental increase in demand for fire services. Piped fire suppression system required for new marina floats. Two new propane storage areas to be added 12.2% increase in total Port Ludlow water usage anticipated. 968 new daily vehicular trips generated, 105 of these trips during the peak hour. Increased boat traffic at the marina. Similar topr6posed proj~t. Similar to proposed project. Similar to proposed project. Similar to proposed project. Similar to proposed project. Similar to proposed project. Similar to proposed project. Similar to proposed project. 3,791 new daily vehicular trips generated, 337 of these trJpl; during the peak hour. Increased boat traffic at the marina. 'LOS E for westbound ~affic at Beaver Valley R~.tOak Bay Rd., and Oalc]3ay Rd,/Walker Way.. Similar to proposed Pl"gject, Similar to proposed project. Similar to proposed project. Similar to proposed project. Similar to proposed project. Similar to proposed project. Greatest potential increase in water usage. 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. Dump-out facilities. Mitigating Measures Fire/Emergency 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 :p~,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-D()cK, the pentral walkway and aU new dOCKs. Trairiing 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. I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I CHAPTER 2 - PROPOSED PROJECT AND ALTERNATIVES 2.1 Description of Proposal 2.1.1 Name of Proposal "Port Ludlow Master Planned Resort - Proposed 2003 Resort Plan" 2.1.2 Project Sponsor Port Ludlow Associates LLC 70 Breaker Lane Port Ludlow, W A 98365 2.1.3 Project Location The Port Ludlow Master Planned Resort (MPR) is located adjacent to and west of Port Ludlow Bay, Jefferson County, Washington. Port Ludlow Bay is located on the west shore of Admiralty Inlet at the mouth of Hood Canal. The changes addressed in this ~ Final SEIS affect the Resort Complex/Community Facilities Zone and marina portion of the Port Ludlow MPR. This zone is specifically located on uplands adjacent to and north of the marina (portions of Sections 9 and 16, Township 28, Range IE). The location of the project is shown in Figures 1 and 2. 2.1.4 Existing Project Features The Resort Complex/Community Facilities Zone (RC/CF zone) at Port Ludlow is developed with a mix of residential, commercial, retail and recreational uses. For purposes of discussion, the northern portion of the Resort area is referred to as the "Admiralty" area, the central portion is referred to as the "Ludlow Maintenance Commission (LMC)" ownership, and the southern portion is referred to as, "Ludlow Bay Village". The "Admiralty" and "Ludlow Bay Village" designations reflect the name of the underlying subdivisions and condominium proiects. The LMC ownership is the approximate five-acre area administered and maintained by the LMC, whose members are owners of townhomes in Ludlow Bay Village, and homes in several Port Ludlow subdivisions and condominium proiects, including Ludlow Bay Village and Admiralty I and II. This area is occupied by the Beach Club, tennis courts, and off-street parking. A detailed description of the existing project site follows: Admiralty Area Admiralty I and Admiralty II encompass a development of 64 stacked condominiums located in the northeastern portion of the RC/CF zone. The condominiums were constructed in two phases in the 1960s and 1970s and were the first residential structures built in the RC/CF zone. The area proposed to be known as Admiralty III area is an undeveloped approximate II-acre tract lying immediately east of Oak Bay Road, north of Heron Road. The northern portion of this area encompasses the original conference center and associated parking; the southern area is now occupied by lawn. Port Ludlow MPR Resort Plan Final SEIS -- 2-1 Port Ludlow MPR Resort Plan Final SEIS 2-2 -- I I I I I I I I I I I I I I I I I I I Conference Center A 6,500-square-foot conference center is located in the northwest section of the RC/CF zone. This facility has off-street paved parking for 54 vehicles. LMC Beach Club Recreational Facility The LMC operates a private recreational club that is located in the central portion of the RC/CF zone, along the shoreline and just south of the Admiralty I and IT condominiums. The club is open to members only, and provides amenities such as an outdoor and indoor swimming pool, sauna, work-out facilities, outdoor tennis courts and squash courts, and the Bridge Deck - a library/meeting room. The facility also includes off-street parking lots. Port Ludlow Associates has a lease agreement with LMC that allows the marina to use 56 spaces in an LMC lot for overflow parking; this lease expires in 2013. Harbor Master Restaurant This 5,000-square-foot, two-story restaurant is located in the south central area of the RC/CF zone between the artificial lagoon and Harbor Drive. The restaurant seats 120, and includes a lounge known as the Wreck Room. Inn at Port Ludlow This 37-room Inn is located southeast of the lagoon on Burner Point and within Ludlow Bay Village. The Inn includes a restaurant and the Fireside Lounge and was the primary subject of the 1993 project-level EISfor the Inn at Port Ludlow. Vehicular access to the Inn is currently from both Heron Road and Gull Drive. Parking for the Inn is situated between the Inn and adjacent townhomes. Ludlow Bay Village Townhomes The 1994 plat of Ludlow Bay Village (LBV) provides for 53 townhome lots and 5 single-family lots. To date, 25, two- and three-story townhomes and one single-family residence have been constructed. The townhomes are sited east and north of the Inn. Vehicular access to the townhomes is via Heron Road and Gull Drive. The one single-family residence (the Pintail House) is located at the west edge of RC/CF zone, along the shoreline. Marina - 280 existing slips An existing 280-slip marina extends south from the shoreline into Port Ludlow Bay. The marina has side tie areas for an additional 20 to 40 boats, as well as a boat sewage pump-out, dinghy float, fuel float, kayak float, and public access to the water. The current mix of slips ranges from 24-foot slips up to side tie areas for boats in the 80-foot range. Upland facilities include a store, rest rooms and showers, laundry, propane, parking areas, and waterfront trails. Off-street parking Paved off-street parking is located at each of the facilities noted above. Additionally, paved and unpaved parking lots are located through out the RC/CF zone. Several paved and graveled parking areas are centrally located south of Marine View Drive between the LMC Beach Club Recreational Facility and Oak Bay Road. I I I I I I I I I I I I I I I I I I I Open Space & Trails Several areas of open space and trails are located in the RC/CF zone. Much of the area within the Admiralty I and IT area is open space and a playground is located along the central west edge of the zone. A temporary, large open space used for special events such as weddings and community gatherings is located along the shoreline in the Ludlow Bay Village area, between the single-family residence and the artificial lagoon. Approximately half of the south end of Burner Point is designated open space and is developed with beach access. 2.2 Preferred Applicant's Proposed Project and Alternatives The applicant's proposed project is a major revision to the current 1999 Port Ludlow MPR Resort Plan, and associated permits and actions as identified in Chapter 1. Alternatives to this action are identified and desclibed with the intent of examining a range of potential development options and their associated environmental impacts, The final action chosen by the Hearing Examiner need not be identical to any single alternative identified in this SEIS, but the action must be within the range of alternatives discussed. Alternatives 1, 2, ffit6-3, and 4 will each result in additional residential, commercial and recreational development and full build-out of the Resort area at Port Ludlow (including a---l-QQ- slip expansion of the existing marina). The alternatives differ in both the type and intensity of development (hotel versus residential, etc.), and consequently the character of the Port Ludlow Resort. Alternatives 2 and 3 are presented here as originally conceived in 1993 and 1999, respectively, Individual proiect ~lements of each alternative are labeled as either existing or proposed - this is meant to indicate the condition of that element at the time the plan was written, i.e. as conditions existed at the Resort in 1993 or in 1999. It must be noted that development and subdivision activity that has occurred in Ludlow Bay Village since 1993 precludes full build-out of either Alternative 2 or 3 as originally conceived. While it would have been possible in 1993 or 1999, it is no longer possible to construct some of the major facilities proposed in these alternatives because development and lots platted in 1994 have reduced the size of available developable land. Where a project element can no longer be built as proposed, a note has been added indicating that this potential element would need to be revised (smaller, larger, different location, etc.) or is no longer possible. Section 3.4 -"Land Use and Land Use Designations" in the Draft SEIS addresses the potential for build-out under Alternatives 2 and 3 given current conditions. Other sections within Chapter 3 also acknowledge this issue. Alternative 4 has been developed in response to comments received on the Draft SEIS with respect to the proposed residential density, construction of residential units over the aItificial lagoon, adequacy of parking in the marina area, and the size of the marina expansion. Regarding the "No Action" alternative, the "No Action" alternatives contained in the 1993 Port Ludlow Development Program EIS, and 1993 The Inn at Port Ludlow EIS (adopted as part of Port Ludlow MPR Resort Plan Final SEIS ~ ~~ 2-3 this SEIS) addressed no further development - e.g., the site remaining in its partially developed state, but anticipating future development proposals. Because t+he passage of time since 1993 hags not changed the analyses of those "No Action" alternatives fl-fltl-those analyses are were not repeatedfiefe in the Draft SEIS. For purposes of additional clarification, the analyses are repeated in this Final SEIS. Alternative 1: Preferred Applicant's Proposed Project - 2003 Proposed Resort Plan The 2003 Proposed Resort Plan proposes that the resort serve as a destination resort for the traveling public, as opposed to large conference groups. This change will decrease the size of many resort facilities identified in the 1999 Resort Plan and development regulations, and will increase the number of residential units. Conferences will still be accommodated, but on a smaller scale and will be housed in existing facilities such as the Inn at Port Ludlow, the Bay Club, the Beach Club, and the relocated Harbor Master Restaurant. Large, outdoor special events will no longer be accommodated. At build-out, development within the resort area would include: . 191Q residential units The 191Q units would consist of: the 64 existing stacked condominiums within Admiralty I and n, the existing 25 townhomes within LBV, the one single-family dwelling within LBV, and 39 new townhomes in the Admiralty ill area (32 stacked flats and 7, two-story townhomes) and 62 new stacked flat condominiums within LBV. The 62 new units within LBV will consist of 48 stacked flats, and 14, two-story townhomes. Vehicular access to existing townhomes within Ludlow Bay Village will be via Heron Road, and will be separated from access to the adjacent Heron Beach Inn. The new townhomes will maintain the existing architectural theme established in Ludlow Bay Village (i.e., New England/Colonial) and will be 1,200 - 1,500 square feet in size - smaller than existing townhomes in Ludlow Bay Village. The smaller size will allow for an over-all variation in product type and price range. . Inn at Port Ludlow - 37 room inn, including restaurant and lounge (existing) The existing building will remain unchanged, however vehicular access to the Inn will be modified. Vehicular access to the Inn and its associated parking will be restricted to Gull Drive, and separated from access to the adjacent townhomes. The existing 36 stall parking lot will be reconfigured to provide 55 spaces. Regarding interior improvements, the size of the formal restaurant will be reduced to double the size of the Fireside Lounge. . Waterfront Commercial Facility (proposed) This I-story building will be located on the shoreline near the west end of the marina, and will contain the Dock Master's office, the marina maintenance area, a store for marina tenants and guests. This facility will be situated adjacent to the relocated Harbor Master Restaurant. The building will maintain the New England/Colonial architectural theme, . Harbor Master Restaurant - 120 seats existing/90 seats proposed (Restaurant to be relocated) Port Ludlow MPR Resort Plan Final SEIS 2-4 -- I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I The existing restaurant building will be demolished, and the restaurant will be relocated to the waterfront commercial facility near the marina. The seating capacity will be reduced from 120 people to 90 people (inside seating for 60, together with outside seating for 30). . Private Recreational Facility - 7,500 square feet (proposed) This 2-story, indoor recreation facility will be located adjacent to the waterfront commercial facility near the west end of the marina. The facility will include an indoor-outdoor swimming pool, spa and a fitness center, and will be available only to residential property owners within Ludlow Bay Village and their guests, guests at the Inn and guests at the marina. The recreation building will also be designed in the New England/Colonial style. . LMC Beach Club Recreational Facility and Bridge Deck (existing) No changes to this private facility or its parking areas are proposed. . Port Ludlow Associates Offices (existing building) Offices for Port Ludlow Associates will be moved from their current location (off Paradise Bay Road) to the old conference center along Oak Bay Road, in the north end of the RC/CF zone. Approximately 30 employees will be located in this building. . Maintenance building - 2,900 square feet (proposed) This building will be used as a maintenance facility for the Inn and other Resort operations. . Off-street parking (existing and proposed) All new residential units will include off-street parking for two cars. A total of 387~ off-street stalls will be provided in a series of paved parking lots for the marina, commercial, and recreational uses in Ludlow Bay Village. . Central Receiving Dock (proposed) A new approximate 1,000-square-foot central receiving facility will be located within an existing parking lot on the north side of Harbor Drive. . Open space, trails (existing and proposed) A designated, signed trail system will be developed within Ludlow Bay Village to provide for better pedestrian circulation and access to public portions of the shoreline. This system will include an 8-foot wide wooden boardwalk along the shoreline that will extend from the new recreation facility, east to the Inn. Existing open space along the south side of the artificial lagoon will be retained, as will the open space at the end of Burner Point. Parking for access to the public trails will be located at the upper community lot. Vegetated slopes along the east side of Oak Bay Road and Harbor Drive will also be retained. The southern portion of the Admiralty 1II area will remain undisturbed at this time, but ultimately may be used for additional parking. . Designated Helipad for Emergency Evacuations (proposed) A 20' by 20' paved helipad for use by Fire District #3, The pad will be located north of Marina View Drive between Oak Bay Road and Olympic Place. Port Ludlow MPR Resort Plan Final SEIS -- 2-5 . Infrastructure Improvements Storm Drainage - Within Ludlow Bay Village, the existing storm drainage system consists of pipes from catchments to oil/water separators which drain to the artificial lagoon and ultimately, Port Ludlow Bay. New water quality vaults will be added at each of the inlets to the artificial lagoon to supplement water quality treatment. Within the area to be known as Admiralty ill, new storm water detention facilities, as well as water quality facilities will be required. Upgrades to the downstream conveyance system may also be required, Sanitary sewer and water service will be provided by the Olympic Water and Sewer Company. New hook ups will be required but the capacity of the existing systems is adequate to handle the increased use. . Marina - 380 slips (280 existing slips + 1O0 slip proposed expansion) The marina expansion is shown in Figure 3B. The proposed project adds 100 slips to the marina by expanding the existing float system both westward and waterward. The proposed configuration of the new floats/slips is as follows: . D-Dock will be extended 120 feet to the west to accommodate an additional twelve 36-foot slips. . E-Dock will be extended 400 feet to the west to accommodate an additional 42 slips (seven 50-foot, nine 60-foot, and twenty-six 45-foot slips). . The east side of E-Dock will be reconfigured to accommodate sixteen slips (eight 36-foot slips and eight 40-foot slips, to replace 1O existing slips). . A new F-Dock will be constructed waterward of E-Dock. The new F-Dock will extend 700 feet westerly and 250 feet easterly of the central walkway. The new F-Dock will accommodate 40 new slips (thirty 45-foot slips and ten 50-foot slips). F-Dock will serve as a floating breakwater to protect the Marina. The existing 1,600-sq. ft. timber kayak float will be replaced in the same location with a 2,850-sq. ft. float with light transmission capabilities, The existing 680-sq. ft. dinghy float on C-Dock will also be replaced with three new floats totaling 960 sq. ft. Please refer to the 2002 Port Ludlow Marina Expansion SEIS for complete details. Alternative 2: 1993 Resort Plan Alternative 2 is the Resort Plan as identified in both the project-level and programmatic Environmental Impact Statements prepared for Port Ludlow in 1993. The 1993 Plan is similar to Alternative 1 (2003 Resort Plan), but proposes four fewer residential units, new retail commercial space, a new town hall and marina managers office and no new maintenance or Port Ludlow MPR Resort Plan Final SEIS 2-6 -- I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I recreation facilities. New development along the shoreline is proposed as residential, rather than commercial. Note - Alternative 2 is presented here as originally conceived in 1993, Individual project elements are labeled as either existing or proposed. This is meant to indicate the condition of that element at the time the plan was written in 1993. It must be noted that it is not possible today to construct some of the facilities as proposed in Alternative 2. The plat of Ludlow Bay Village and townhome development that has occurred since 1994 has reduced the size of available developable land. Generally, it is possible to implement this alternative and construct the facilities, but the locations and sizes of the facilities would need to be adjusted. In these instances, a note has been added indicating that construction of a potential element would need to be revised (smaller, larger, different location, etc.) or is no longer possible. At build-out, Alternative 2 would include: . 186 residential units :..Jthe 64 existing units existing in Admiralty I and II in 1993, + 122 proposed! units in Admiralty III and Ludlow Bay Villagej (2005 development includes 64 units within Admiralty I and II, and 26 units and 32 undeveloped lots within LBV). Within Ludlow Bay Village, residential development under the 1993 Plan would have consisted of 23 single-family detached platted lots (11 along the shoreline at the west end of the marina and 12 north and east of the artificial lagoon) and 49 multi-family units (20 townhouse units, 17 villa units, 11 units in mixed-use structures, and one "carriage house" unit). The average single-family lot size would be 4,361 square feet; the average size of a multi-family unit would be 1,200 square feet. No architectural theme has been identified, but it is assumed the new units would be consistent with the design of the Inn at Port Ludlow. Further, 50 new townhomes would be constructed in the area to be known as Admiralty III area (in addition to the existing 64 townhomes in Admiralty I and II in 1993), The size and architectural style of these new townhomes has not been specified. . Retail commercial building - 2,500 square feet (proposed!) Retail uses were to be located in the ground-floor space of a 3-story mixed-use complex located in the northeast corner of Ludlow Bay Village. Anticipated retail uses included a bakery/coffee shop and souvenir shop. · Inn at Port Ludlow - 37 room Inn, including restaurant and lounge (proposed in 1993. cun-ently constructed) The Inn was initially proposed as a 3-story, 37 room Inn, in its current location. Access to the Inn and its associated parking area was combined with access to proposed residential development to the north and east. . Harbor Master Restaurant - 5,000 square feet (existing) 4- May require alternate location or size. Port Ludlow MPR Resort Plan Final SEIS 2-7 -- The addition of a deck to the existing Harbor Master Restaurant at its CUlTent location was proposed, The deck was constructed in 1995. . Town Hall - 1,850 square feet (proposedl) A Town Hall, to be used for meetings and community activities, was to be located adjacent to the mixed-use complex in the northeast portion of Ludlow Bay Village. The Town Hall would be a maximum of 50 feet in height, with a footprint of 1,030 square feet and a total of 1,850 square feet. . Off-street parking Parking for 400 vehicles was to be provided within Ludlow Bay Village. Parking lots would be provided in three general portions of the site, and smaller lots would accompany the multi-family structures. Parking for single-family residents was to be on individual lots and adjacent roads. . Open space, trails Within Ludlow Bay Village, approximately 10.5 acres would remain in open space. The major open spaces included the southern end of Burner Point, and the expanded artificial lagoon (the open space and expanded aJiificiallagoon currently exist). . Infrastructure Improvements Storm Drainage - Within Ludlow Bay Village, impervious surfaces would cover approximately 40% of the site. Stormwater runoff would be piped from catch basins to oil/water separators, and ultimately to the artificial lagoon. After mixing with the lagoon, water would be released into Port Ludlow Bay. A small portion of the runoff from shoreline areas would not be routed through the artificial lagoon, but would drain through swales and biofilters prior to release into the Bay. Within the area to be known as Admiralty Ill, new storm water detention facilities, as well as water quality facilities would be required. Upgrades to the downstream conveyance system may also be required. Sanitary sewer and water service would be provided by Olympic Water and Sewer Inc. (then known as the Ludlow Sewer Company and Ludlow Water Company). New hook ups would be required, but the capacity of the existing systems was determined to be adequate to handle the increased use, Within the plat of Ludlow Bay Village. the infrastructure improvements already exist. . Marina - 380 slips (280 existing slips + 1O0 slip proposed expansion) This element is flew-the same asfef eaffi Aalternative-1. See the description under Alternative 1 for more details of the expansion, or see the FSEIS for the Port Ludlow Marina Expansion (2002). Port Ludlow MPR Resort Plan Final SEIS 2.8 ~ ~~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I This element is oow-the same aSfef eaffi AalternativeJ.. See the description under Alternative 1 for more details of the expansion, or see the FSEIS for the Port Ludlow Marina Expansion (2002). In the original 1993 Plan, the marina would have expanded primarily to the east and west, rather than out into the Bay. Dredging would have been required in a slightly less than one acre area along the west side of Burner Point in order to increase depths and improve access to inner docks, . Marina Support Development (proposed) A new 800 square foot marina manager's office and store would be constructed midway between the Heron Beach Inn and existing marina buildings to the west. Marina restrooms and laundry facilities would be housed in a new building at the location of the old marina manager's office. Underground fuel and propane tanks would also be removed and relocated to a partially aboveground containment bunker. A conceptual illustration of Alternative 2 is shown in Figure 4. Alternative 3: NQ ActiQR Existing 1999 Resort Plan Alternative 3 is development of the Resort Plan as described in Section 3.901 of the existing MPR regulations. It differs significantly from Alternatives 1 and 2 by proposing to fill two- thirds of the artificial lagoon and develop a large hotel, conference center, amphitheater, several restaurants, indoor tennis courts, structured parking, museum, youth center and retail stores. The recreation facilities would have served both guests at the conference center and residents of the MPR. Note - Alternative 3 is presented here as originally conceived in 1999. Elements of the plan are labeled as either existing or proposed. This is meant to indicate the condition of that element at the time the plan was written in 1999. It must be noted that it is not possible today to construct some of the facilities as proposed in Alternative 3. The plat of Ludlow Bay Village and subsequent townhome development since 1994 has reduced the size of available developable land. Generally, it is possible to implement this alternative only with significant changes and formal approval of a Redevelopment Agreement (requiring 100 percent approval of the Ludlow Bay Village Homeowner's Association). In the absence of a Redevelopment Agreement, this would likely result in relocating and reducing the size of the hotel and conference center (with a corresponding reduction in the resort amenities), and eliminating the amphitheater. A note has been added to those items that would require relocation or adjustment, or elimination. At build-out, development was to include: . Lagoon Fill (proposed) The eastern two-thirds of the artificial lagoon was proposed to be filled in to create an open grass area. Port Ludlow MPR Resort Plan Final SEIS 2-9 -- A 238-room hotel was proposed to be located near the northeast edge of the filled section of the artificial lagoon, The hotel, conference center and restaurant would be physically connected to each other with enclosed breezeways. . Restaurants - 59,000 square feet (5,000 Harbor Master + Inn Restaurant - Existing)! One, 200-seat year round restaurant connected to the conference center and hotel One, 125-seat year round lounge connected to the conference center and hotel One, 125-seat seasonal restaurant near the marina Also includes hotel lobby and registration area, spa, kitchen offices and storage rooms. . Resort Retail- 2,500 square feet (proposed) with associated storageJ-l,400 square feet} A marine/non-marine related retail store would be constructed near the shoreline at the west end of the marina. This building would also contain the waterfront restaurant. . Conference Center - 22,000 square feet (proposed!) with support areas and storage-8,000 square feet (proposed!) The conference center would be located between the hotel and restaurant on the north side of the filled section of the artificial lagoon. The hotel, conference center and restaurant would be physically connected to each other with enclosed breezeways. . Indoor tennis courts - 26,000 sq. ft. (proposedl) Three buildings housing indoor tennis courts would be constructed in the southwest portion of the resort, below Oak Bay Road. . Indoor sports and pool complex - 13,500 square feet (proposed!) One indoor sports building and an outdoor pool would be located south of the indoor tennis courts, below Oak Bay Road. . Structured/underground parking -119,000 square feet (proposed!) A concrete parking structure with underground and above ground parking would be located south of the indoor sports and pool complex, below Oak Bay Road and west of the remaining artificial lagoon. . Museum or Interpretive Center - 7,500 square feet (proposed) This museum would contain permanent and rotating art and cultural displays. It would be located north of the retail and restaurant building on the shoreline, and west of the remaining artificial lagoon. . Support Buildings - 12,000 square feet Several support buildings for use in maintenance, warehousing and housekeeping. ! May require alternate location or size, Port Ludlow MPR Resort Plan Final SEIS 2-10 ~ ~~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I . Youth Center - 4,000 square feet (proposed) A youth center containing an assembly area, kitchen, game room, media room and other amenities would be located in the northwest corner of the Resort, in the old conference center. . Amphitheater - One (proposed;;) An outdoor, uncovered amphitheater would have been located at the east end of the filled section of the artificial lagoon. The amphitheater would have included parking below, and would have been used for concerts and other events. Whether this amphitheater could still be constructed depends on the ability to obtain permits to fill the artificial lagoon and the ability to provide required parking. . Yacht Club - One (proposed]) A yacht club would have been located within the restaurant building along the shoreline. . 4-Single Family Dwellings, and one-l-5.:-unit townhome . All existing town homes (61 units in Admiralty I and II 13 townhomes in Ludlow Bay Village in 1999 - sq. ft. not part of Resort sq. footage) . Marina Expansion - 280 existing slips + 1O0 slip proposed expansion This element is the same for ~eaffi Aalternative 1 regardless of which upland alternative is choseR. See the description under Alternative 1 for more details of the expansion, or see the FSEIS for the Port Ludlow Marina Expansion (2002). A conceptual illustration of Alternative 3 is shown in Figure 5. Alternative 4: Response to Comments Alternative 4 is similar to Alternative 1 with the following exceptions: The total number of new residential units in the Admiralty area would be reduced by seven (32 proposed new units vs. 39 proposed new units under Alternative 1 ). The total number of new residential units in Ludlow Bay Village would be reduced by seven (55 proposed new units vs. 62 proposed new units in Alternative 1 ). No portion of the residential units would extend over the artificial lagoon. The marina expansion will include 60 slips. Alternative 4 is shown in Figure 6. 2 Cannot be constructed. Port Ludlow MPR Resort Plan Final SEIS 2-11 -- Alternative 5: No Action Alternative 5 would result in no additional development within the Resort area at this time, no expansion of the existing marina, and no reconfiguration of the parking and access for the Inn at Port Ludlow. Alternative 5 is shown in Figure 7, The following Table 2 compares each of the tffi:ee five alternatives with respect to the major facilities proposed. Port Ludlow MPR Resort Plan Final SEIS 2-12 -- I I I I I I I I I I I I I I I I I I I - - ~ I - ~ - * * z *-J ~ c.n:r ~ ":l ,., .., - ~ \0 = VI \0 ~ ::: J;:.. ~ ;;. 3Z VI :r Z-) ~ ;' ~ ~ ;.;:. g,. ,., c Co. I;>:l Co. 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'" '" z lS'~ n ::l CiJ n D> CiJ ell D> CD ell l!. m )C ~ S' cc o o ::l Q. ;:; o' ::l ell :r> if ~ ::l a ~. ...... !\,) o o w ;a CD ell o ::I- ." Dr ::l o o 3" "Co ~.~ en, oc...... :::J c.. D) 2,,0'2: )>:eCD ;::;:c~ CD CD 3 ~ D) .... - - <" CD en :r> if 3 a ~. !':' ...... co co w ;a CD :g ::I- ." Dr ::l :r> if ~ ::l a :c" CD ~ ..... co co co ;a CD ell o ::I- ." Dr ::l Z o :r> !:1 o' .a. Q;I b- CD I\) D) cn o ~ ca" s" D) :::: '00::: en :::r o ~ s" s CD :b "0 ~ I\) Q ~ ~ Qi ::t CI) !!! CI) Port Ludlow MPR Resort Plan Pre.Draft ESEIS DRAFT 2-14 I I I I I I I I I I I I I I I I I I I 2.3 Benefits/Disadvantages of Delaying Implementation The SEP A Guidelines encourage permitting agencies to view each generation as a trustee for succeeding generations. With this perspective, environmental review is encouraged to consider whether approving or implementing a proposal at this time will preclude future options {WAC 197-11-440(5)(c)(vii)}. The benefits of delaying revision to the 1999 Resort Plan relate to preserving tfle future development options, including fef developmentffig of conference facilities and recreational facilities for large groups (i.e., the No Action l\lternative). If the new 2003 Resort Plan is not approved, and Port Ludlow Associates ceases building new townhomes within the Resort zone, some of the commercial/recreational facilities identified in the 1999 MPR Regulations could still be developed if market conditions warrant such development. Expansion of the marina could -still occur whether or not the Resort Plan is revised, under the No .^~ction .Alternative. Delaying implementation of the proposed 2003 Resort Plan would postpone the impacts from new development, and would also postpone the proposed reconfjguration of the Heron Road/Gull Drive access to the Inn at Port Ludlow. Delaying revision to the Resort Plan would not effeet affect the provision of adequate public services or utilities to other uses within the Port Ludlow MPR. It is unclear whether or not delaying implementation of the Resort Plan would delay construction of the proposed emergency helipad. The disadvantages of delaying revision to the Resort Plan relate to maintaining the economic viability of the Resort. If the resort market cannot support the large conference and recreational uses originally proposed, new conference facilities will not be built. In that case, Port Ludlow Associates would likely apply for pennits to continue te--build,:-Out of the plat of Ludlow Bay Village. It is unclear what development would occur within the area to be known as Admiralty III area. It is not anticipated that undeveloped Resort properties would remain undeveloped over the long term, so pressure would continue to amend the 1999 Resort Plan. If delaying revision to the Resort Plan delays new development within the Resort area, opp011unities for employment (both construction-related and operational) will also be delayed, I I I I I I I I I I I I I I I I I I I CHAPTER 3 - AFFECTED ENVIRONMENT, ENVIRONMENTAL IMPACTS, MITIGATING MEASURES 3.1 EARTH A detailed examination of the "Earth" characteristics for the Marina expansion and the Ludlow Bay Village areas can be found in the 2002 Port Ludlow Marina Expansion SEIS, the 1993 EIS for the Port Ludlow Development Program, and the 1993 EISfor the Inn at Port Ludlow. A more general discussion of the "Earth" characteristics for the RC/CF zone follows. 3.1.1 Affected Environment Topography The Resort area consists of terrestrial uplands and submerged lands in, and immediately north of the inner portion of Port Ludlow Bay. Topography in the southern portion of the Resort area was modified by progressive filling from the shipbuilding, logging, and sawmill activities that occupied the site beginning in the late 1800s. Existing site topography is shown in Figure e~. The uplands consist generally of a gently upward, south-east facing slope, ranging from 0 elevation at sea level and the shoreline near the Marina, to an elevation of approximately 90 feet at the northwestern boundary of the Resort. The upland topography can be broken into three distinct areas; the flat lowland adjacent to the Marina shoreline, which includes old fill; the gently sloping upland plateau; and bands of steep slopes lying between the lowlands and uplands. The bands of steep slopes (40+ percent) generally lie along the east side of Oak Bay Road, south of Marina View Drive; one band of slopes also extends easterly and separates existing parking and lagoon areas from property fronting Harbor Drive. The beach slope above the existing Port Ludlow Marina consists of quarry spall and small riprap. Further west, the beach steepens, and the 15- to 40-foot bank is covered with vegetation. Property owners in this area have experienced problems with sloughing and erosion. Within the Marina, subsurface elevations range from -0 feet (MLLW) to -38 feet under the outermost docks. Underwater slopes adjacent to the beach average 9 to 11 percent. Further waterward, the bottom flattens with slopes ranging from 2 to 4 percent. Port Ludlow Bay is a 2.2 square mile, J-shaped tidal basin, which extends from the mouth of Ludlow Creek 3.5 miles to Admiralty Inlet. The eastern approach to the bay is characterized by a submerged sill, which forms a submerged basin open to the north. The average depth at the mouth of the bay is 78 feet (MLLW). From this point, the bottom of the basin slopes upward for a distance of 0.5 mile to a depth of 48 to 54 feet. From here, the depth of the bay remains fairly uniform throughout most of its length to within 0.5 mile of Ludlow Creek. The innermost 0.5 mile of the bay has a maximum depth of 40 to 42 feet. Port Ludlow MPR Resort Plan Final SEIS 3-1 May 2005 ~ - - - - - - - - - - - - - - - - o !i! I , I I , , , , I I I I o .. I I , , I I , I " " I I I :i// I , , PORT LUDLOW / , , I , , \ , , , *, o SCALE ~ 100 0 IN FEET I 100 I 200 - - I I I I I I I I I I I I I I I I I I I Soils Upland Soils The flat, lowland area above the Marina contains fill material from the original lumber processing and shipping uses. On-site soil investigations in this area were completed by Shannon & Wilson in 1988, and by Landau Associates in 1991. These investigations found the lowland area to be characterized by near-surface heterogeneous fill material, ranging from imported native material to construction/demolition debris. Densities range from loose to very dense, and portions of the area are very permeable. One isolated pocket of soil to the north of the pond was found to contain trace levels of semi-volatile organic compounds. This soil was removed in conjunction with expansion of the artificial lagoon in 1994. Soils within the Admiralty area have been mapped as Swantown gravelly sandy loam, 0 to 8 percent slope (SuB) and Indianola loamy sand (InC). Marine Sediments Landau Associates conducted subsurface explorations in the Marina in 2001. Based on the conditions encountered in seven borings, the area of the proposed Marina expansion is generally underlain by an upper unit of very soft, recent marine sediment over a lower unit of medium dense/stiff, older marine sediment. Underlying the marine sediment is an upper unit of medium stiff glacial deposits and a lower unit of denselhard glacial deposits. These subsurface conditions preclude the shallow anchoring of new floats. Sediment sampling was conducted in 1987, 1991, 1993, 1995, 1997, and 1999. Metals tested for include: arsenic, cadmium, chromium, copper, iron, lead, mercury, nickel and zinc. Samples in 1995 were also analyzed for the content of organic carbon, fats/oil/grease (FOG) and pH. Results of the sediment quality monitoring demonstrate that sediments in Port Ludlow Bay contain low concentrations of heavy metals. The 1999 Report concluded "...sediment quality is comparable to other non-urban Puget Sound bays, metal concentrations are generally much lower than in urban bays of Puget Sound, and sediment quality is not declining. " Geologic Hazards The 1998 Jefferson County Comprehensive Plan includes maps depicting designated Critical Areas. The Resort at Ludlow Bay is not shown as encompassing areas of Erosion Hazard. That portion of the Resort along the shoreline adjacent to the Marina is shown as "Landslide Hazard-Low Risk," and the shoreline adjacent to the Admiralty I and II areas is shown as "Landslide Hazard - Medium Risk." The flat, lowland area above the Marina (i.e., area of fill) is shown as an area of potential seismic hazard. 3.1.2 Environmental Impacts Short-Term Construction Impacts Temporary, short-term impacts will result from construction activities. For all alternatives, grading will be required for construction of building pads, reconfiguration of parking areas, and, in the Admiralty ill area, installation of utility improvements. For the Marina expansion, construction work will also occur in and over water. Port Ludlow MPR Resort Plan Final SEIS 3-3 May 2005 ~ The upland erosion potential for this construction site is less than that for a typical construction project because the construction activity will be spread-out in various "pockets" throughout the larger development, thus reducing the potential for large amounts of erosion or erosion runoff. Also, many of the areas being proposed for construction have already been cleared of their existing vegetation through previous grading activities. This previous work will reduce the current clearing and grading time and thus reduce erosion potential. Because of many unforeseen circumstances such as a large unexpected rain event during construction or a longer than expected construction schedule, erosion control measures will nonetheless be implemented. No upland earthwork will extend below Ordinary High Water (OHW). Construction activities associated with installation of new piles in Port Ludlow Bay will result in a temporary increase in localized turbidity. A more detailed discussion of turbidity is included in the 2002 Port Ludlow Marina Expansion SEIS. No dredging will be required for the Marina expansion in any Alternative, Because of the quality of the existing sediments in Port Ludlow Bay, re-suspension and movement of contaminated sediments is not considered a significant impact. Long- Term Impacts Alternative 1: Preferred Applicant's Proposed Project - 2003 Resort Plan Alternative 1 would require earthwork to reconfigure parking areas, construct new buildings, and install new infrastructure in the Admiralty III area. No major alterations to site topography are proposed. Except as nOled below, existing steep slopes would remain undisturbed. Proposed grading in the Ludlow Bay Village area will be relatively minor relative to the development proposed. Parking lots will be placed close to existing grade, with a maximum cross slope of 5 percent. Grading for the parking lots will require construction of one concrete wall, a maximum of 18 feet in height, in the area of steep slopes north of the relocated Harbor Master Restaurant. Grading for the residential buildings will also be fairly minor since many of the buildings will be placed on pile foundations near the lagoon instead of a typical flat pad that would require extensive fill. Residential units located on slopes will be built to accommodate the slope by use of multi-stories with upper and lower entry-level parking. It is anticipated that total grading activities will result in comparable amounts of cut and fill and therefore, import and/or export of material will be minimal. Sectional views of proposed grading within Ludlow Bay Village are shown in Figures +A-9A through +G9C. Grading activities within the new plat of Admiralty III area-will not be significant given the existing topography. Site soils are suitable for the proposed construction. Development within the Ludlow Bay Village area will require ground improvement techniques to limit foundation settlement. To date, the townhome structures built within this area (except those structures on the bluff above the lagoon) have been constructed on piling. Each building site is evaluated on a case-by-case basis by a geotechnical engineer to determine the requirements for foundation stability. From Port Ludlow MPR Resort Plan Final SEIS 3-4 May 2005 ~ I I I I I I I I I I I I I I I I I I I I Alternative 1 - Figure 9A Port Ludlow Resort Plan FSEIS I EZ I I '-.; n 1: ""fi ,~~L ~!; C tC - I:L ~ CU :> c o .- ~ U CU '" w. ~~ 5~ ww wH CI)~ H. a: > w l! w. ~i z h <'l o o _00 QlOl Z ~<( Ci5~ I- ~ ~ E ~~ 0 <'l_ ~ cri ~ "S 0'0 "0 ~af E l/) CD ~ 3: 3: m 0 0 0 0 0 N (() '<t '<t I \ \ 0 \ N + \ L() Cl 0 <C (() 0 c::: + '<t o N o (() o '<t o o ..r I o '<t + '<t o o + '<t o 10 + n <I: I <I: c o -- ~ U Q) V\ III Ill. Z o Z III '" o o _CO C1)Cll C1)<( ~S .c>. -., ~S "'- ." cn~ Ql 0"0 CIlQl .....LI.. m I 0 0 0 0 0 N to -.;t -.;t I C I 0 <D - - + I LO N \ I z \ w a.. 0 0 N + LO N I 0 I CO + -.;t N I 0 -.;t + -.;t I N I 0 CQ 0 I + -.;t CQ N I c 0 .- 0 ....- <D U + I t') OJ N V\ I 0 N + t') N I ft. -. 0 5~ CO I + ft. .N N N. N i w we ~~ I ~ u u _'u J z h 0 Cl Z '" Cl ~Il -.;t w 0 ,,<( + 0 0 N _co QlOl I a::: N Ql<( Z ~s , >I1\fMa~\f08 .r=>. E ______,0__ -., ~s 0 "'- t:! 0 .., 'S; I z en'- 0 Ql '0 + 0'0 C\IQl E N I"-LL. I/) N I Ol ~ I 0 0 0 0 0 ~ N co -.;t -.;t ~ I Figure 9C Alternative 1 Port Ludlow Resort Plan FSEIS the past building activity and soil testing, it is assumed the new restaurant and recreation buildings will be supported by steel or auger-cast concrete piling. Over-excavation of material has not been used to date, and it is not anticipated that it would be used in the future. With the use of piling, grading activity in these areas will be minimized. The Port Ludlow Marina Expansion SEIS (2002) concluded that expansion of the Marina will not affect geologic conditions in that area. Minor maintenance dredging may be required at the northwest corner of the existing C-dock at some point in the future, but the timing is unknown. Expansion of the Marina to the west will increase boat activity in the vicinity of properties that have experienced previous problems with erosion. It is unclear whether past erosion problems were the result of boat wakes, storms, and/or upland runoff. The western docks will reduce wave impact on the shoreline behind the floats. A more detailed discussion of impacts associated with the Marina expansion is contained in the Port Ludlow Marina Expansion SEIS (2002). Alternatjve 2: 1993 Resort Plan Impacts of Alternative 2 on site topography and soils are similar to Alternative 1. Within Ludlow Bay Village, more grading would be required within the steep slopes at the southwest corner of the Resort (below Harbor Drive) to provide for the new residential development in that area. No grading would be required, however, for reconfiguration of the upper parking lot south of Harbor Drive. Alternative 3: No Action Existing 1999 Resort Plan Impacts to site topography and soils resulting from construction of Alternative 3 would be more significant than with Alternatives 1 or 2, as the site would be more intensely developed. Construction of Alternative 3 would require significant grading of existing slopes along the eastern side of Oak Bay Road from the shoreline north to Marina View Drive in order to construct the proposed parking and recreation facilities. In addition, the eastern one-half of the existing artificial lagoon would be filled to provide required open space. It is also assumed that the proposed amphitheater would not be constructed but that a conference center would be constructed. The original 1999 Plan envisioned the southern portion of the Admiralty ill area as open space, in response to the more intense facility development within Ludlow Bay Village. If the area were to remain as open space, no grading would occur, It is unclear, however, what would happen to this area at this point in time given the less intense development in Ludlow Bay Village. Construction of large, heavy structures such as a parking garage (southwest corner of Resort) on areas of existing fill would require extensive ground improvement techniques. Impacts from the Marina expansion would be the same as the impacts identified in Alternative 1. Alternative 4: 1993 Response to Comments Impacts of Alternative 4 on site topographv and soils are similar to Alternative 1, with the exception that the construction of fewer residential units in the Admiralty and Ludlow Bay Port Ludlow MPR Resort Plan Final SEIS 3-8 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Village areas would result in somewhat less grading for building: pads. No units would be constmcted on piling over the artificial lagoon. Alternative 5: No Action No further development within the Resort area at this time would result in no immediate impact to existing soils or site topography. 3.1.3 Mitigating Measures Proposed - All Alternatives: Short- Term, Construction Impacts - The following erosion control measures are proposed: . Silt Fences - Silt fences will be placed around graded areas where vegetation has not yet been established to prevent construction runoff from spreading sediment to adjacent properties or Ludlow Bay. . Mulching and Hydroseed - Mulch and/or Hydroseed will be placed on areas that have been disturbed by grading and construction activity. Once placed and established, grass and mulch help to prevent runoff containing high concentrations of sediment. . Plastic Covering - Plastic covering will be used to cover stockpiles of soil on site, and plastic may be used to temporarily cover slopes to prevent erosion before the establishment of hydroseed or mulch. . Interceptor Ditches w/Check Dams - Interceptor ditches will be used to direct stormwater in the construction areas to temporary sediment traps and/or ponds. Check dams help to reduce flow velocities and thus reduce the suspension of sediment in the stormwater. Interceptor ditches may also be used to prevent stormwater from areas not under construction from entering the construction area. · Dust Control - Dust control management includes providing water trucks on site to spray exposed areas during dry times where wind-blown dust is possible. Gravel construction entrances and mulch also will help to prevent excessive dust. . Sediment control facilities - Sediment ponds and sediment traps will be used to collect, treat, and discharge stormwater runoff during construction. These facilities function as small water quality facilities by allowing residence time for sediment to fall to the bottom of the trap and discharging clean water from the top as water rises. From the Port Ludlow Marina Expansion Final SEIS (2002): . In-water construction activities will be limited to the period between July 16 and February 16 in order to minimize potential impacts to juvenile Puget Sound chinook salmon, Hood Canal summer-run chum salmon, and bull trout. · Best Management Practices will be employed during construction including silt fences, spill control measures, floating booms, etc. Long-Term Impacts . Work in steep slopes will be minimized to the extent possible. Port Ludlow MPR Resort Plan Final SEIS 3-9 May 2005 ~ . New development will be designed to follow the existing topography to the extent feasible. . Site-specific geotechnical explorations will continue to be undertaken for each building pad to determine construction recommendations. 3.1.4 Unavoidable Adverse Impacts No significant unavoidable adverse impacts to site soils or site topography are anticipated. Port Ludlow MPR Resort Plan Final SEIS 3.10 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 3.2 WATER 3.2.1 Surface Water The following information regarding surface water has been taken from the Port Ludlow Development Program Draft EIS (1992), the Draft EIS for the Inn at Port Ludlow (1992), the Port Ludlow Non-Point Monitoring Program 2002 Report (2003), the Draft Report-Landscaping Plan, Port Ludlow Resort Expansion (2004), and information provided by ESM, Inc. 3.2.1.1 Affected Environment Water Bodies No wetlands or streams are located within the Resort. A 2+-acre artificial lagoon is located within Ludlow Bay Village above the Marina. The Resort complex is surrounded by Port Ludlow Bay on the south and east. The existing artificial, man-made lagoon was first created in 1967 and then expanded to its current size in 1994. The lagoon is situated on part of the old mill site. The lagoon approximately 1O feet deep; a floating walkway connects the north and south shore via a small island. Because the soils between the lagoon and Bay are porous, water seeps out from the lagoon and pumps are used continuously to bring in saltwater via three short waterfalls. Salinity of the lagoon water is expected to be similar to the salinity of the Bay (approximately 30 parts per thousand), although the presence of freshwater from rainfall, stormwater runoff, and any groundwater seepage, causes this level to fluctuate. Further information regarding the habitat conditions of the artificial lagoon is found in Section 3.3 of this Final SEIS. The artificial lagoon provides water quality treatment by providing residence time for stormwater runoffprior to discharge into the Bay. The residence time allows time for suspended solids to settle to the bottom of the lagoon, and improves the quality of water being discharged. Other water quality parameters in the pond (i.e., dissolved oxygen, nutrients, and temperature) have been reported to vary widely, which is common in small, shallow ponds. Port Ludlow Bay is a 2.2-square mile, J -shaped tidal basin, which extends from the mouth of Ludlow creek 3.5 miles to Admiralty Inlet. The location, geometry, and orientation of Port Ludlow Bay is such that the strong offshore ebb-and-flood tidal currents in Admiralty Inlet create a large eddy in the outer portion of Port Ludlow Bay that appears to reverse direction with each tidal stage. Waters from Admiralty Inlet are drawn into the Bay under a wide variety of tidal conditions. Current measurements, drogue observations, and salt balance calculations made in 1984 and 1986 indicated that the outer bay eddy is accompanied by a complex pattern of currents that exert influence into the central portion of the Bay. Significantly more water is circulated into and out of the Bay due to eddies and currents than would be the case if only a simple ebb-and-flood pattern existed. As a consequence, the Bay may be better mixed and better flushed than many bays within Puget Sound. Mixing is further enhanced by vertical currents and upwelling at the entrance and head of Port Ludlow Bay (Jefferson County 1993). The Bay is flushed by tidal currents, fresh water from streams and rainfall, wind-mixing of the surface water, and local vertical mixing. Salt balance calculations indicated that the volume of Port Ludlow MPR Resort Plan Final SEIS 3-11 May 2005 IDJmaI water exchanged daily between Port Ludlow and Admiralty Inlet averages 39 percent per day and varies from 20 to 50 percent of the total volume of the Bay, dependent on the time of year and prevailing tidal range. The time to exchange the water volume of the Bay, including the innermost reaches, was estimated to be between 2 to 5 days. Localized portions of the Bay may have longer or shorter flushing rates. The flushing time for the outer bay has been estimated to be 9 hours on average (Jefferson County 1993). Drainage The Port Ludlow Resort complex is divided into five drainage subbasins, as shown in Figure -81O. Storm drainage systems have been constructed in Basins EX-I, EX-2 and EX-3 to accommodate the Resort development to date. No development has occurred in Basins A or B. Jefferson County Ordinance No. 08-1004-99 states that all future development within the Port Ludlow MPR shall be subiect to the standards of Jefferson County Stormwater Management Ordinance No. 1O-1104-96 (1991 Puget Sound Water Ouality Management Plan, Revised 1994). The Port Ludlow Drainage District (PLDD), formed in 2000, reviews storm drainage plans for new development within the MPR for consistency with adopted regulations, in coni unction with the Jefferson County review. The PLDD 2003 Comprehensive Stormwater ManaRement Plan includes Jefferson County ordinances and programs necessary to fulfill the requirements of a comprehensive stormwater program, and identifies specific structural and non-structural solutions to known flooding and water quality problems within the District. No structural improvement proiects or Capital Improvement Proiects are identified within the Resort area. Runoff within Basin EX-l~ the area surrounding the conference center, is collected and conveyed to a ravine that outlets to the Bay in the vicinity of the treatment plant. Runoff within Basin EX-2, the area known as Admiralty I and II and the LMC ownership, is also collected and conveyed (via catch basins and pipes) to outlets to the Bay. Basins A and B are located in the Admiralty III area; no storm drainage systems have been constructed within these basins, Property owners have noted that groundwater is close to the surface within this area, and drainage problems have been observed. Runoff within Basin EX-3, the area known as Ludlow Bay Villaf!e, -is collected and conveyed to inlets on the east and west ends of the artificial lagoon. From the lagoon, water is discharged directly into Port Ludlow Bay. Because of the {Jroximity of the basin to the Bay, no detention of run-off is required. Rooftop drainage within EX-3 is connected (via downspouts) to this drainage system. The drainage system for the entire EX-3 basin was constructed in 1994 as part of the plat of Ludlow Bay Village. All storm draina~e facilities within the Resort area are currently owned and operated by Port Ludlow Associates. At completion of development, these facilities will be turned over to the Port Ludlow Drainage District for maintenance. Because the artificial lagoon is not a designated drainage facility, the artificial lagoon is maintained by the LBV Home Owners Association. Port Ludlow MPR Resort Plan Final SEIS 3-12 May 2005 ~ I I I I I I I I I I I I I I I I I I I - - .. - - - - - - - - - - - - - - - ~ I ~ ~ CD (f> .,,'-1 C) 3 l1)N 0 () 0.0 ~ ~(f) z ",. u> (; -w :E.t>. c: 0 ",2;> r 3 ~;;y -I :E~ z )>(jj ~~ Cl 0 m 0 w Z Cl II .~ ~ m :II <t)u> t~ I I I I I I I I I I I I I I I I I I I Water Quality The Washington State Department of Ecology has classified all waters of Port Ludlow as Class AA. Water Quality monitoring of Port Ludlow Bay from 1984 through 1998 has demonstrated that overall water quality in Port Ludlow Bay is excellent, consistent with its Class AA designation (Jefferson County 1993). A program to monitor non-point sources of pollutants to Port Ludlow Bay was initiated in 1989 to comply with conditions imposed by Jefferson County. Annual monitoring reports have been prepared since 1990; the study design varies from year to year to focus on priority issues. In combination, these reports have identified the chemical composition of stormflow and baseflow from each tributary to Port Ludlow Bay, characterized stormflow quality from various development areas, and established baseline sediment quality. Potential non-point sources of pollution within the general area include septic tanks, roads and parking lots, residential runoff, agricultural chemicals and waste, forestry runoff, golf course drainage, Marinas and boats, internal loading from sediments, atmospheric fallout, and exchange of water with Admiralty Inlet. Inputs of water from Admiralty Inlet average 3,000 mgd and dominate over the influences of all freshwater sources.! No long-term upward or downward trends in constituent concentrations are evident for any of the monitoring stations. Constituent concentrations, for the most part, have not been increasing along with the increased population density of the watershed. Concentrations of most constituents (e.g., fecal coliform) have been higher during storm events than during baseflows, which is consistent with the findings of other watershed studies (Berryman & Henigar 1999). A point-source monitoring program for the Port Ludlow Wastewater Treatment Plant was also conducted from 1989 through 1997 but was discontinued in 1998 due to the excellent performance record of the treatment plant. Although the artificial lagoon receives run-off from the EX-3 drainage system, it is not officially operated or maintained as a water quality facility. In fact, however, the artificial lagoon does provide some water quality treatment through settlement of suspended solids. A detailed discussion of the history and use of the artificial lagoon is presented in Appendix I. Marina - Gray and Black Water Discharge The Port Ludlow Marina Expansion SEIS (2002) addressed gray and black water discharge as follows, The potential for the discharge of gray (galley, bath, and shower water) and black water (sewage containing human body wastes and the waste from toilet and other receptacles intended to receive or retain body waste) exists within all Marinas. Discharge of black water is illegal and prohibited within the Port Ludlow Marina, Discharge of gray water is allowed under specific conditions, consistent with State requirements. Please refer to the Port Ludlow Marina Draft Supplemental Environmental Impact Statement (2002) for a more detailed discussion of the Marina's policies for controlling discharge of sewage and gray water within the Marina. Of particular concern is the discharge of sewage. The Washington State Department of Ecology (Ecology) has established water quality standards for fecal coliform bacteria (Chapter 173-201 1 Port Ludlow Non-Point Monitoring Program, 2002 Report Port Ludlow MPR Resort Plan Final SEIS 3-14 May 2005 ~ WAC). For Class AA marine waters, including Port Ludlow Bay, the fecal coliform standard is a geometric mean of 14 organisms per 100 milliliters (mL) of water. This standard applies to waters where edible shellfish are present. The U.S. EPA has established water quality criteria for fecal coliform and enterococcus bacteria based on health risk to swimmers at both freshwater and saltwater beaches. These criteria are geometric means of 200 and 35 organisms/lOO mL, respectively. Current Port Ludlow Marina regulations require that all live-aboard tenant vessels must be equipped with a Coast Guard-approved holding tank and that live-aboard tenants submit to inspection of their vessels plumbing and mechanical systems to verify compliance with state and local public health and safety laws. The Marina now provides one sewage pump-out station at the fuel dock and will soon be putting into service a portable pump-out facility. Shoreside restroom facilities are also available for Marina patrons. As stated above, water quality monitoring data for Port Ludlow Bay indicates no long-term upward or downward trends in constituent concentrations for any of the monitoring stations. Bilge Water The Port Ludlow Marina Expansion SEIS (2002) addressed the discharge of bilge water as a potential source of pollution in Marinas, as bilge water may contain a variety of chemical constituents, but predominantly petroleum hydrocarbons. Port Ludlow Marina's Best Management Practices (BMPs) expressly forbid the discharge of bilge water within the Marina. 3.2.1.2 Environmentallmpacts Short- Term Construction Impacts Upland Development. The potential for runoff from erosion and sedimentation during construction activities is addressed in Section 3.1.2 - Earth. Marina Expansion, The Port Ludlow Marina Expansion SEIS (2002) addressed water quality impacts. The SEIS determined that during construction, potential discharges to surface water include leakage of petroleum products from construction equipment. These substances can enter marine water directly or in stormwater runoff. Few, if any, juvenile salmonids are expected in the action area during construction activities; also, few adult chinook salmon or bull trout are expected in the project area during construction. Short-term and localized decreases in dissolved oxygen or increases in turbidity due to project construction may result in avoidance of immediate work areas. Should this avoidance occur, it would have only insignificant and unmeasurable effects on salmonids. Temporary and localized impacts to water quality may also occur due to pile driving. However, given the depth of the water where the pilings will be installed, it is highly unlikely that any increased turbidity due to pile driving will affect areas frequented by juvenile salmonids, Long- Term Impacts Alternative 1: Applicant's Proposed Preferred Project - 2003 Proposed Resort Plan Build-out of the Resort will increase stormwater runoff in Basins A and, B (Admiralty III area), and Basin EX-3 (Ludlow Bay Village). Port Ludlow MPR Resort Plan Final SEIS May 2005 ~ 3-15 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I New development in Basins A and B will require construction of a storm drainage system (including detention and water quality treatment) consistent with the requirements of Jefferson County/Port Ludlow Development Agreement and Jefferson County Ordinance No. 10-1104-96. After detention and water quality treatment, runoff from Basins A and B will pass through the existing conveyance system to the artificial lagoon. A preliminary evaluation of the capacity of the existing conveyance system to accommodate the additional runoff has been undertaken, but it was found that a design level of detail will be required before a final determination regarding capacity can be made. If it is determined that existing capacity is not sufficient, then the existing storm drainage line will be replaced with a larger line. The location and design of the storm drainage detention facility for Basins A and B will also be determined during the design phase of development; it is assumed, however, that a detention pond or detention barrel will be located iust north of the new helipad. The new construction is not anticipated to exacerbate any existing problems with groundwater seepage. In addition to requirements contained in the Jefferson County regulations, the new storm drainage system may intercept site run-off from currently undeveloped areas, and direct that run-off to detention facilities and/or the Bay. New development within Basin EX-3 will be located within the Ludlow Bay Village area, where an existing storm drainage system is already in place. New impervious surfaces in this area will consist only of rooftops. The existing drainage system was originally designed has the oapacity to accommodate the volume of increased runoff from build-out of the area. Water quality treatment is not required for rooftop drainage. In order to supplement water quality treatment within the Ludlow Bay Village area, Alternative 1 will include adding a water quality vault at each of the two inlets to the artificial lagoon. The Port Ludlow Marina Expansion SEIS (2002) concluded that no long-term direct or indirect effects to water quality are anticipated as a result of the Marina expansion. Although the Marina expansion will result in increased boat activity, this activity is not expected to significantly degrade water quality or impact any populations of shellfish that may be present in the vicinity of the project area. Alternative 1 does not include any filling or dredging within any body of water, but does include construction of 19 residential units extending over the edge of the lagoon. Alternative 2: 1993 Resort Plan The impacts of Alternative 2 on surface water would be similar to Alternative 1. The 1993 Plan proposed two residential units extending over the edge of the artificial lagoon; in the 1993 Plan, the lagoon was 1.4 acres in size (vs. 2.2 acres today). Alternative 3: Na AetiaD 1999 Resort Plan The impacts of Alternative 3 on surface water would be similar to Alternatives 1 and 2, except that the western half of the existing artificial lagoon would be filled. In addition, the more Port Ludlow MPR Resort Plan Final SEtS 3.16 May 2005 ~ intense use of the site would result in increased impervious surfaces, increased vehicular traffic, and an increased need for water quality treatment for road and parking lot drainage. Alternative 4: Response to Comments The impacts of Alternative 4 on surface water would be similar to Alternatives 1 and 2, except that no residential units would extend over the artificial lagoon. With the reduced Marina expansion, two new portable sewage pump-outs would still be provided Alternative 5: No Action No further development within the Resort area at this time would result in no immediate impact to existing surface waters or the existing storm drainage systems. No measures to improve the water quality in the artificial lagoon would be undertaken. 3.2.1.3 Mitigating Measures Proposed .:,.tAll Alternative~-lj: . Erosion and sedimentation control plans would be implemented as described in Section 3.1.3. . The existing storm drainage conveyance system will be evaluated to determine if sufficient capacity exists to accommodate runoff from Basins A and B (post-development). . New water quality vaults will be installed at the east and west ends of the artificial lagoon. . In conjunction with the Resort's plans for application of fertilizers and pesticides, the stormwater collection and treatment system is expected to protect water quality over the long term. . The Non-Point Water Quality Monitoring Program will be continued. From the Port Ludlow Marina Expansion SEIS (2002): . At the Marina, a hazardous material spill clean-up kit will be available on the fuel float and on one of the expanded docks, and crews will be trained in the use of this kit. . The Port Ludlow Marina will continue to educate users of the Marina regarding BMPs. . Port Ludlow Associates will educate Marina users regarding the effects of discharging gray water and will strongly discourage such discharge. . Port Ludlow Associates is committed to ongoing enforcement of BMPs at the Marina; the BMPs will be enforced via fines and/or revocation of Marina use. . Two portable boat sewage pump-outs will be installed at the Marina, providing further ability to pump out sewage from vessels. 3.2.1.4 Unavoidable Adverse Impacts No significant adverse impacts to surface waters are anticipated. 3.2.2 Groundwater Port Ludlow MPR Resort Plan Final SEIS 3.17 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 3.2.2.1 Affected Environment Four principal aquifers have been identified in the general vicinity of the Resort at Port Ludlow, These aquifers are shown in Figure 9- n and are known as the: . Well 1 Aquifer . North Aquifer . South Aquifer, and . South Valley Aquifer Olympic Water and Sewer Inc., which serves the Port Ludlow MPR, currently draws groundwater from three wells in the North Aquifer (Wells 2, 3, and 4N) and two wells in the South Aquifer (Wells 13 and 14). No groundwater is currently withdrawn from the Well 1 Aquifer or the South Valley Aquifer. Existing information on each aquifer, summarized below, is taken from the Draft EISfor the Port Ludlow Development Program (1992), the Draft EISfor the Inn at Port Ludlow (1992), and the Olympic Water and Sewer Inc.' s annual Monitoring Report dated February 20032. The annual Monitoring Program, required by Jefferson County, concentrates on the North and South Aquifers and encompasses the area presumed to overlie these aquifers, as well as a substantial area around each aquifer. The current groundwater monitoring network is comprised of 17 wells owned and maintained by eight separate participants. The goal of the program is to assess the long-term condition of the aquifers in the Port Ludlow area. To date, the monitoring program has found "no definitive indications of declining water levels related to groundwater production or rising chloride and conductivity levels in any of the three aquifers monitored in the Port Ludlow area". 1 The Well 1 Aquifer lies partially beneath the Resort. The Well 1 Aquifer has one well (Well 1) that is completed at a depth of 361 feet (approximately 250 feet below sea level). Well 1 is currently unused and has a production capacity of approximately 50 gallons per minute (gpm). The North Aquifer is encountered about a half-mile northwest of the Resort and contains three wells (Wells 2, 3, and 4N) currently used by the Olympic Water and Sewer Company to serve the Port Ludlow MPR and other users. The recharge area is estimated to be 1 square mile and total annual recharge to the aquifer has been calculated as 370 gpm (597 acre-feet per year [af/yrD. Historic water level production and precipitation data were examined in the early 1990s to determine production rates that would not result in water level declines of the North Aquifer. Production from the North Aquifer had reached 87.3 gpm (141 af) in 1992. Robinson and Noble estimated that, at a pumping rate of 70 gpm (113 af/yr), water levels would remain steady with average rainfall, Therefore, an average withdrawal from this aquifer of 65 gpm (105 af/yr) was recommended. The average withdrawal rate has been approximately 70 gpm (113 af/yr) between 1993 and 2002 and was 78 gpm (126 af) in 2002. Water levels in the North Aquifer have shown 2 Robinson & Noble, Inc. 2003. 2002 Annual Report on the Port Ludlow Area Groundwater Monitoring Program for Port Ludlow Associates, LLC, February 2003. Port Ludlow MPR Resort Plan Final SEIS 3-18 May 2005 ~ Data Sources: Interstates, stale routes, and roads from TIGER 2000. County boundaries, cities, and waterbodies from Department of Ecology. Aquifer and well locations from Draft EIS for Port Ludlow Development Program (Oct. 26, 1992). All locations are approximate. Lambert Conformal Conic Washington State Plane North North American Datum 1983 Explanation ..-:. Approximate Aquifer Boundary . Well Locations Note: This drawing is for informational purposes. It is intended to assist in showing features discussed in an attached document. It is unlawful to copy or reproduce all or any part thereof, whether for personal use or resale, without permission. Principal Port Ludlow Area Aquifers GEoENGINEERS Q I I I I I I I I I I I I I I I I I I I a general rise since the programmed decrease in withdrawal rates from the aquifer was initiated in 1993. The groundwater monitoring program is continuing. The South Aquifer lies across Port Ludlow Bay, at and south of Tala Point, and includes two wells (Wells 13 and 14) operated by the Olympic Water and Sewer Inc. The recharge area is approximately 4.5 square miles and total recharge is approximately 1,640 gpm (2,640 af/yr). The combined withdrawal rate from Wells 13 and 14 in 2002 was 109.2 gpm (176 af), while a hypothetical yield of 492 gpm (794 af/yr) was determined for the aquifer based on conservative assumptions for precipitation, evaporation, and runoff. The South Aquifer also contains four other major wells - the PUD Bywater wells 1 and 2, the Paradise Bay well, and the Tala Point Partners well. The South Valley Aquifer is located across Port Ludlow Bay, about 2 miles south of the Resort. Numerous test wells have been drilled in this aquifer but none are currently in use. This aquifer has two inactive sources - Wells 4A and 9, which are being considered for treatment and return to service. A hydrological study concluded that this aquifer is unable to support long-term, year- round groundwater production but could augment supplies during peak demand periods by up to 65 gpm. Other wells exist in the vicinity of Port Ludlow. In the upland areas, most are private wells tending to draw from water-bearing zones that are above sea level, such as the North Aquifer. Along the shoreline, private wells are generally completed below sea level in water-bearing zones such as the South Aquifer. A monitoring network that includes 17 wells operated by Olympic Water and Sewer, other purveyors, and private residences was established in 1993 to monitor for indications of salt-water intrusion. To date, the water characteristics have remained stable, with no indications of salt-water intrusion. The depth of shallow groundwater at the Resort site varies with season, rainfall and tidal influence. In areas of fill, groundwater is encountered at approximately 8 feet below ground surface. In portions of the upland areas, water depth may be as shallow as 3 feet. The groundwater quality within the North and South Aquifers is typical of groundwater in the Puget Sound region. The relatively low concentrations of chloride, a parameter used as an indicator of salt-water intrusion, have remained stable in all of the monitoring network wells. 3.2.2.2 Environmental Impacts Alternatives 1, 2, aBEl-3. and 4 Water supplies to meet the additional demands from Resort build-out will be provided by Olympic Water and Sewer Inc. They will continue to rely on the North and South aquifers but may also draw from the South Valley Aquifer to augment supplies during periods of peak demand. The increased demand on the water supply from the planned Resort development and Marina expansion is estimated to be approximately 23 gpm (37 af/y). This represents a demand increase of approximately 12.2 percent over the 2002 production of 187.2 gpm (302.3 af). The water company, with its water rights holdings of 465 af/yr, has concluded from previous studies Port Ludlow MPR Resort Plan Final SEIS 3-20 May 2005 ~ that these aquifer systems have sufficient capacity to support Alternatives 1 or 2. Alternative 3 has not been studied, The withdrawal of groundwater to serve the expanded Resort and Marina is not expected to have any impact on water quality. Approximately 10 years of monitoring data have demonstrated that saltwater intrusion has not occurred under current rates of withdrawal. Based on the current understanding of aquifer dynamics systems, there is currently no basis for believing that the approximately 12 percent increase in withdrawal rate will change this situation. Since annual groundwater monitoring will continue, any saltwater intrusion problems will be identified and corrected (such as through altering pumping rates from the various supply wells available) before they affect water supplies. The proposed project does not involve discharge of surface waters to groundwater. Any accidental releases of sediments, petroleum products, or other contaminants during construction would either run off and be collected in the stormwater distribution and treatment system, or would be retained in surface soils. Neither construction nor operation present any risks to the Well 1 Aquifer beneath the Resort site nor to any other aquifers in the area (none of which are downgradient from the site). Alternative 5: No Action No further development within the Resort area at this time would result in no immediate increased groundwater usage within the Resort area. 3.2.2.3 Mitigating Measures Proposed - All Alternatives: . The continuing groundwater monitoring program provides adequate coverage and information regarding water levels and water quality and allows long-term trend analysis of the Port Ludlow area aquifers. 3.2.2.4 Unavoidable Adverse Impacts The region's aquifers will continue to be managed to sustain long-term supplies of water for the expanded Port Ludlow Resort and Marina and other area users. Withdrawals are not likely to significantly draw down or reduce the production capacity of the aquifers. However, as with any project, use of additional water for this project will preclude that water from being available for other future uses in the area. Port Ludlow MPR Resort Plan Final SEIS 3-21 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 3.3 PLANTS AND ANIMALS 3.3.1 Affected Environment Regional Conditions In 1992, Raedeke Associates conducted a survey of plant and animal communities in the Port Ludlow Development Program area (Raedeke Associates, 1992a). The purpose of that survey was to obtain baseline information on an approximate 1,200-acre area and to assess impacts of future development. Since that study area encompasses and generally surrounds the portion of the Port Ludlow Resort development addressed in this SEIS, it serves as the primary source of recent infonnation on plants and animals in the general vicinity of the resort site. The information regarding regional conditions is contained in Appendix B of this document and is summarized from that report unless indicated otherwise. Resort Site In 1992, Raedeke Associates conducted a plant and animal survey of a 17. 5-acre study area including the artificial lagoon and areas immediately to the east, west, and north of the lagoon (Raedeke Associates, 1992b). That report, an appendix to the 1992 Inn at Port Ludlow DEIS (Jefferson County, 1992b), contains species lists and scientific names ofthe plants and animals named below. This section combines the Raedeke information with more recent data on site-specific conditions (as noted below), including a biological site reconnaissance on November 4,2003. In addition, in response to comments received on the Draft SEIS, Geo Engineers conducted a field investigation of the lagoon on December 13,2004. Information from that investigation is presented in this section: the GEO Engineers Field Report, including photos of outfall and intake structures, is attached as Appendix 1. Upland Areas The upland portions of the Resort site have been disturbed previously and do not appear to support any significant concentrations of native habitats or species. Much of the site is presently covered by roads and driveways, parking lots, residences, recreational facilities, and other structures, all of which are surrounded by lawns or ornamental landscaping. On the west and north sides immediately beyond the Resort boundaries, vegetation is relatively dense and undisturbed (except areas surrounding scattered residences). Even though the Resort occurs in an area of fairly steep terrain, most of the site has been contoured and a stormwater drainage system has been installed. Even the few remaining open, undeveloped portions have been graded flat and planted with lawn grass. The northern portion of the site tends to drain to the east (toward the Bay) while the southern portion drains to the south (toward the lagoon). Noise and human activity levels at the Resort can vary widely depending on the season. During the November 4,2003 site visit, noise and activity levels were fairly low. Some noise from construction within the resort and traffic on the adjacent highway was discernable. Port Ludlow MPR Resort Plan Final SEIS May 2005 ~ 3-22 Animal populations and assemblages most common on the site are birds and small mammals that are tolerant of human activity (such as moles, shrews, mice, rats, squirrels, and rabbits). Artificial Lagoon The lagoon is a man-made facility, initially constructed in 1967 by excavating upland soils in the area of the old mill site. It was 1.4 acres in size. In 1994 the lagoon was expanded to 2.2 acres as mitigation for construction of the Inn at Port Ludlow. The lagoon is not a shoreline regulated under the Shoreline Management Act, but does lie within 200 feet of Port Ludlow Bay, The lagoon is reported to be approximately 1O feet deep with a firm bottom composed of sands and silt. A floating walkway connects the north and south shore. Mowed lawns cover upland areas north, south, and east of the lagoon. Ornamental and native shrubs and trees, including big-leaf maple and Douglas fir, grow between the lagoon and restaurant. California poppy, aster, and clover cover the south and west banks of the lagoon. GeoEngineers conducted a field investigation of the lagoon on December 13, 2004. The purpose of the investigation was to confirm previously reported information on habitat conditions and species usage, which would in turn be used to update the assessment of impacts from resort development activities. Parameters evaluated include plant and animal species inhabiting the lagoon, marine and stormwater inputs and outputs, water quality and water depth. The field report from this investigation, including photos of outfall and intake structures within the lagoon is included as Appendix 1. Although freshwater enters the lagoon as surface runoff, and via shallow groundwater seeps primarily along the northern shoreline, almost all of the water entering the lagoon appears to come from the artificial conveyance system that pumps seawater directly from the bay. At the time of the field investigation, seawater was being pumped to the lagoon via three waterfall weir structures and was estimated to total approximately 700 gallons per minute (gpm), although the flows were variable over time. Multiple outlets along the south side of the lagoon conveyed lagoon water back to the bay, resulting in a stable water level. The salinity of lagoon water at various depths and locations was fairly consistent, ranging from 28.27 to 28.66 parts per thousand, which is close to that of seawater. This is a reflection of the limited freshwater contribution to the system (even though rain was fairly steady immediately prior to and during~ the field investigation), and it also suggests that the water was circulating fairly well within the lagoon. The plants and animals found in the lagoon are representative of a marine environment. The following groups of plants were observed (see report for species list): . brown algae . sedges . red al gae . rushes . green algae . grasses · filamentous algae . sea asparagus . seagrasses, including two small clumps of eelgrass Aquatic invertebrates observed include: . chitons . bivalves . barnacles . limpets . periwinkles . . . . . whelks crabs sea anemones brittle stars amphipods Port Ludlow MPR Resort Plan Final SEIS 3-23 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I . . . . isopods copepods sponges marine worms . nemertreans . marine flatworms . serpulid tube wonns . nudibranchs The only fish observed was the Threespine stickleback. Water clarity was good, allowing for visual surveys of fish from the banks (around the entire lagoon perimeter) and by snorkeling in a variety of locations. It is believed that if any other types of fish - such as salmonids - occurred in any significant numbers in the lagoon, they would have been observed during these surveys. Bird species observed on or near the lagoon include: . Common goldeneye . Hooded merganser . Bufflehead . Killdeer . Glaucous winged gull . Thayer's gull . American crow Sediments at all locations were characterized by a strong organic odor and large amounts of clam shell debris and detritus including detached algae and leaf litter material. Sediment color and texture was primarily darkish brown to black silt while also containing a fair amount of sand and gravels with a few larger sized cobbles. Dissolved oxygen (DO) concentrations were somewhat low (5.07 to 6.30 mg/L), but it is unknown whether this was due to low DO in the pumped seawater or was caused by organic decomposition occurring in the lagoon, Soils bet'.veen the lagoon and the Bay are relati'lely porous, so water seeps out from the lagoon and the '.vater level can drop a foot per day if it is not replenished. Consequently, saltwater is pumped into the lagoon from the Bay on a continuous basis to maintain the water level. The lagoon experiences considerable algae growth at times. Filamentous algae grOVlS '.vhere water depths are less than 3 to 1 feet and covers much of the lagoon during the summer, at times creating floating algae mats and odors. Mechanical means are used periodically to remove algae from the lagoon. The lagoon is not used for boating or swimming. Small clams and mussels occur along the bottom of the lagoon and attached to the algae. The algae probably also served as habitat for other invertebrntes, including insects. Neither amphibians nor reptiles ','lere observed near the lagoon during the 1992 Raedeke survey. Fish are kno','ln to occur in the lagoon but neither species nor population characteristies have been documented. WDFW has noted that, based on the elevation of the culvert connecting the lagoon with the Bay, the lagoon may be accessible to marine fish at tides above MHHW and probably provides some rearing habitat (Burkle, 2002). American wigeon, bufflehead, and killdeer use the lagoon. Wigeon have been observed flying or walking from the adjacent shoreline to the lagoon. The birds engage in social and loafing activities while on the lagoon and feed on the lagoon's algae and invertebrates. Wigeon also feed on lawn areas to the east of the lagoon. Port Ludlow MPR Resort Plan Final SEIS 3-24 May 2005 ~ Bufflehead have been observed diving for food within the lagoon. Bufflehead feed on crustaceans, which are readily available within the lagoon. Killdeer feed along the shoreline of the lagoon, presumably consuming a variety of invertebrates. Mallard, pintail, lesser scaup, and merganser have been reported to use the lagoon. It is also expected that gull, belted kingfisher and American crow use the lagoon, A variety of passerines and other species that favor upland habitats use shrubs and other vegetation near the lagoon and in the vicinity of the restaurant. These include song sparrow, violet-green swallow, robin, American crow, European starling, and purple finch. Both finches and starlings have been observed constructing nests in the shrubs and trees near the restaurant. Mammals expected to use the lagoon include domestic dog and raccoon, Mole, shrew, mouse, rat, vole, red fox, and skunk may use the lagoon and nearby areas during some times of the year. Port Ludlow Bay and Marina The Port Ludlow Marina Expansion Draft SEIS (Reid Middleton, 2002a) addressed marine conditions in the vicinity of the marina. This section focuses on birds and other biological features not included in that document. Much of the rocky substrate, and most of the structure associated with docks of the marina, contain barnacles, clams, mussels, anemones, and other marine invertebrates. No amphibians or reptiles are expected to use the marine environment on a regular basis, Seventy-six bird species are expected to use the open water and shoreline areas of the marina and Bay. Of these, 18 species were observed during the Raedeke field studies. Nineteen species of waterfowl have been reported or are expected to use the area. American wigeon and scoter are abundant in the area. Scoter feed by diving within Port Ludlow Bay while wigeon feed and loaf along the shoreline by the marina. Wigeon also feed on grassy areas next to the shoreline. Common loon feed near the marina. Arctic and red-throated loon are expected to use the area during the winter. Horned grebes feed near the docks. Red-necked, eared, and Western grebe have been reported or are expected to use the Bay and marina. Other common birds seen near the marina included double-crested cormorant and pigeon guillemot. Brandt's cormorant and pelagic cormorant are expected to use the Bay near the manna. Sixteen species of shorebirds are expected to occur in the vicinity of the marina. Killdeer feed along the shoreline, Port Ludlow MPR Resort Plan Final SEIS 3-25 May 2005 IDJmaI I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Glacous-winged and herring gull are commonly seen flying, feeding, and loafing on the docks and waters adjacent to the marina. Signs of use by gulls are common on most areas of the docks, An additional eight species of gulls and terns are expected to use the area. Belted kingfisher and American crow have been reported flying near the marina. American robin and rufous-sided towhee use the area. Domestic dog was the only mammal observed at the marina during the 1992 Raedeke survey. However, raccoon, river otter, gray whale, Dall's porpoise, and harbor seal have been reported to use the marina and Port Ludlow Bay. Endangered, Threatened, Sensitive, and Other Priority Species and Habitats Vegetation and Habitats The Washington Natural Heritage Program has developed a list of plant species considered to be Threatened, Endangered, or Sensitive within the state of Washington. A number of the species on these lists are thought to occur in Jefferson County, although several are known from historical records only. Federally-protected threatened and endangered plants are listed by the U.S. Fish and Wildlife Service. Based on a review of existing information, no plant species listed as endangered, threatened, or sensitive by state or federal agencies are known or likely to occur in the area. The Washington Natural Heritage Program has no records for rare plants or high quality native ecosystems in the vicinity of the project (Washington Department of Natural Resources, 2003). The National Wetland Inventory (NWI) shows the nearest upland wetland to be located more than 0.75 mile west of the Resort site. The nearest coastal wetland in the NWI database is about 0.5 mile from the site, across Port Ludlow Bay. The Washington Department ofFish and Wildlife (WDFW) was contacted for information on Priority Habitats and Species (PHS) as well as other species and habitats of concern in the vicinity of the project site. The U.S. Fish and Wildlife Service responded on October 16, 2003, to a similar request by providing a list of federally protected species and species of concern possibly occurring in Jefferson County; however, they deferred to the WDFW's PHS program for site-specific species information. The PHS report was prepared on October 9,2003. The PHS report included two types of priority habitat in the project vicinity. Priority estuarine zones occur along the north shore of Port Ludlow Bay (about 0.25 mile west of the marina) and on the south shore (about 0.5 mile south of the marina across the Bay). The NWI coastal wetland noted above is also a priority habitat in the PHS database. Fish The PHS report includes three species of priority fish species in Ludlow Creek, which drains into Port Ludlow Bay about a mile southwest of the marina: chum and coho salmon and winter steelhead. All three are anadromous species that use the creek for spawning and rearing and are found in open marine waters during most of their life cycle. The coho is a candidate for listing Port Ludlow MPR Resort Plan Final SEIS 3.26 May 2005 ~ under the Endangered Species Act (ESA), No priority resident species were reported from the area. Species listed as threatened under the ESA that could occur in marine waters in the project vicinity include Puget Sound chinook salmon, Hood Canal summer-run chum salmon, and bull trout. Birds Marbled murrelet and spotted owl are listed as threatened or endangered species by both federal and state jurisdictions, and both are reported by USFWS to occur in Jefferson County. Although marbled murrelet was noted by Raedeke (1992b) to use Port Ludlow Bay, the PHS report included no indication of marbled murrelet or spotted owl occurrence within a mile of the project site. Although critical habitat for both species has been designated in Jefferson County, no such habitat occurs near the project site. Any use of the area by either species is highly unlikely. The PHS report identified breeding sites for the following priority species within a mile of the project site: . Bald eagle . Great blue heron . Purple martin The eagle and heron nests are located across Port Ludlow Bay in the general vicinity of Tala Point, more than a half-mile south and east from the Port Ludlow Resort site. No nests are known within the Port Ludlow development area, nor would any be expected there because of a relative lack of suitable nesting sites (i.e., large snags or old-growth trees) and the level of human activity. The nearshore area along the eastern shoreline of Port Ludlow Bay (along Tala Point across the Bay from the Resort) is shown in the PHS database as bald eagle territory used for feeding and possibly used for breeding. Bald eagles are often seen flying over Port Ludlow Bay and have been reported to occasionally land on trees in the vicinity of the Resort. The bald eagle is classified as threatened by the federal government and the State of Washington. Purple martin nesting has been reported to occur at the Port Ludlow Marina. In late June of 1997, 30 birds were reported to use boxes installed on pilings at the marina. Those boxes are no longer present. The common loon, a species classified as sensitive by WDFW, is frequently observed in the vicinity of the marina. The diet of common loon consists primarily of fish, crustaceans, and some plant material. Five state candidate bird species (species under review by WDFW for possible listing as state endangered, threatened, or sensitive) may occur within the area: . Pileated woodpecker Port Ludlow MPR Resort Plan Final SEIS 3-27 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I . Northern goshawk . Vaux's swift . Western grebe . Merlin Signs of pileated woodpecker have been observed in upland forest habitats. However, this species typically occupies large home ranges (one square mile or more) and may forage a great distance from the nest. No nests have been reported, and potential nest sites (large, tall snags) are limited in the area given its logging history. Thus, while this species appears to forage in the area as part of its home range, it may not breed there because of a general lack of suitable nest sites. Northern goshawk may forage in the area but are more likely to be found in the foothills and higher elevations in the Cascade Range. Vaux's swift may forage in the area but are not likely to find their preferred nesting habitat of large dead-topped trees in mature and old-growth forests. Residents have reported sightings of Western grebe in Port Ludlow Bay. Merlins, a small falcon, may occur in the area in low numbers during certain times of year. They prefer more open habitats for feeding and typically feed on shorebirds in the Puget Sound area. The short-tailed albatross is a state candidate species and a federal endangered species reported by USFWS as possibly occurring in Jefferson County. However, there is no indication in either the PHS data or the Raedeke report that this species occurs in the vicinity of the Port Ludlow Resort. Six state monitor species (those managed by WDFW to prevent them from becoming endangered, threatened, or sensitive) are expected to occur within the area: . Horned grebe . Red-necked grebe . Black-crowned night heron . Green-backed heron . Great blue heron . Osprey Horned grebe have been reported feeding in deeper water areas of the Bay and within the marina. Red-necked grebe and black-crowned night heron are expected to use the Bay during certain times of year. Green-backed herons may occur in the area, although they are most commonly found along woods-edged rivers. Great blue heron feed in shallow waters near the southern end of Port Ludlow Bay and have nested in the vicinity, The osprey, a fish-eating hawk, has been reported to use Port Ludlow Bay and is known to nest in the vicinity. Ospreys typically breed along water bodies where fish are available as prey. Osprey breeding has been reported to occur both across the Bay and in a flat-topped Douglas fir tree about one-third mile west of the Port Ludlow Resort site. Port Ludlow MPR Resort Plan Final SEIS 3.28 May 2005 ~ A number of birds designated as state game species of concern are expected to occur in the area, Bufflehead use the artificial lagoon for feeding, loafing, and social activities. Bufflehead consume mostly animal material, including insects, snails, mollusks, and crustaceans, and are classified as state game species of concern due to their population status and sensitivity to habitat alteration. Other state game species reported to use the area included common merganser, hooded merganser, Barrow's goldeneye, and harlequin duck. Mammals A harbor seal haulout and parturition site is located in the Port Ludlow Bay/Admiralty Inlet area about two miles northeast of the Resort. Adult harbor seals use this site year-round, with pupping occurring in the summer. The PHS report included no other priority mammal species or habitats in the project vicinity. The gray whale, listed as a federal and state endangered species, was observed by a resident at the entrance to Port Ludlow Bay (Raedeke, 1992b). Gray whales spend most of their time in the North Pacific Ocean but sometimes stray into Puget Sound during their migration from breeding grounds in Baja California to waters further north. The Townsend's big-eared bat -- a state candidate species -- may forage over forest and wetland habitats. Breeding and roost sites are not expected to occur in the project vicinity because of a general lack of large snags, caves, or other suitable cavities. As noted previously, two state game species of concern that are expected to occur in the area may frequent the site: Columbian black-tailed deer and beaver. 3.3.2 Environmental Impacts Upland Impacts Common ToAII-Alternatives 1.2.3. and 4 This assessment of project impacts is based on information contained in the original EISs prepared in 1992 for the Inn at Port Ludlow (Jefferson County, 1992b) and the Port Ludlow Development Program (Jefferson County, 1992a), supplemented by current site information (presented above) and an analysis of project activities common to all three alternatives. Although each of the three alternatives would involve different types of new construction and human use, their impacts on plants and animals would be more similar than not. All three alternatives will result in potential impacts to plants and animals from the following project activities and effects: General Construction Effects (short-term) . Land clearing and conversion . Stormwater runoff . Noise . Emissions Indirect Effects (long-term) . Increased human activity . Change in hydrologic patterns Port Ludlow MPR Resort Plan Final SEIS 3-29 May 2005 IDJmaI I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Short- Term Construction Impacts Land clearing activities typically involve the removal of existing vegetation and grading to prepare a site for construction. In some cases, vegetated areas will be replaced with impervious surfaces (such as parking lots or roofs). In other locations, the disturbed area will be replanted with the same or different species after construction has been completed. For all three Port Ludlow Resort alternatives, no wetlands, riparian zones, dunes, or other significant areas of native vegetation will be cleared, converted, or otherwise disturbed during construction. Land-clearing activities will reduce the amount of vegetative productivity and cause a minor change in the distribution of habitat types and values within the Resort site. Smaller, less mobile animals whose home range lies wholly within a disturbed area or that cannot access other available habitat in the vicinity will likely perish. Some animals will be displaced temporarily to less disturbed areas in and adjacent to the Resort. Some mortality may occur as a result of that displacement, depending on habitat conditions and suitability. The overall effect of land clearing and conversion activities on plants and animals is expected to be insignificant because animals currently using the site tend to be those that tolerate moderate to high levels of human activity. Furthermore, the areas to be cleared or converted to other uses have already been disturbed and currently offer little natural habitat. For example, reptiles and amphibians generally rely on forest duff, downed logs, and snags for habitat, but these habitats are generally lacking within the Resort area. Consequently, although full development of the Resort could further reduce populations of these species, the number of individuals potentially affected is low. The change in land cover could increase stormwater runoff and erosion during construction. The potential for erosion and offsite transport of sediments will depend on the construction season, soil types affected, amount of exposed soils, slope conditions, surface drainage patterns, and mitigation measures employed. Construction impacts will largely be controlled through the implementation of best management practices (BMPs) tailored to suit site-specific conditions and the season of construction. Excavations in the upland areas will likely encounter some groundwater seepage, especially if construction occurs during the rainy season, but this seepage is expected to be minor (Jefferson County, 1992b). However, site topography and drainage characteristics are such that any_turbid water escaping from a construction site will be intercepted and prevented from reaching marine waters by considerable expanses of lawn or other vegetated land in the northern portion and by the lagoon in much of the southern portion. Facilities to be constructed adjacent to the beach near the west end of the marina are more subject to uncontrolled runoff, but this area is predominantly flat from previous contouring and special runoff controls will be used there to prevent stormwater or any intercepted groundwater seepage from reaching the Bay. Consequently, no adverse effects on water quality in the Bay are anticipated. Water quality in the artificial lagoon could be adversely affected if a large slug of turbid water or a petroleum spill were to escape a construction site at the southern end of the Resort. Such an event is likely to be very local and temporary. The sediments are expected to settle out quickly in the calm lagoon waters without adversely affecting plants or animals in the lagoon. The fact that lagoon water tends to discharge to the Bay via seepage means that the subsurface soils will Port Ludlow MPR Resort Plan Final SEIS 3-30 May 2005 ~ serve as a filter, generally retaining all but the smallest suspended particles before the lagoon water reaches the Bay. As noted previously, habitat quality in the lagoon is currently poor, and further degradation from accidental releases would not affect any sensitive species using or otherwise dependent on the lagoon. Construction of residential units over the edge of the lagoon will cause direct disturbance of the bed and generate turbidity during pile driving, Impacts will last only a short period and will not occur in the vicinity of the eelgrass clumps, and the turbid water will be flushed from the lagoon relatively quickly due to the active seawater pumping system in place. Considering the artificial nature of the lagoon system and the poor quality of in-water and nearshore habitats, these construction activities are not expected to significantly degrade water quality or affect any populations of sensitive or protected species of plants or animals. Noise typical of construction activities will be generated from the project site during the course of the construction period. In response to this noise and increased level of human activity, an overall reduction in local wildlife populations could occur due to avoidance of the area by sensitive species. However, most of the wildlife currently using the site is tolerant of at least moderate levels of noise and human activity, and the surrounding terrain and dense forest vegetation in the area will tend to dampen the noise and largely prevent it from reaching areas outside the Resort. Consequently, any population reductions associated with additional noise or human activity during construction are expected to be minor. Discernable (above-background) construction noise is presumed to carry a distance of a half-mile or less. For none of the three alternatives is such noise expected to reach and adversely affect known bald eagle or great blue heron nests located more than a half-mile across Port Ludlow Bay. This distance is much greater than the 400-foot protective zone (or 800-foot buffer zone) typically established by WDFW around eagle nests under the State of Washington Bald Eagle Protection Rule (WAC 232-12-292). Both species may be less likely to forage in the immediate Resort vicinity during construction, but the impact is expected to be minor since foraging activity is low and those that do use the site are used to some level of human activity in the immediate vicinity. Of the state sensitive, candidate, and monitor bird species that could occur in the project vicinity, none will be significantly affected by any of the three alternatives, The primary basis for this conclusion is that none of these species breed nor find their high quality or preferred habitat in the upland Resort area, primarily due to the existing level of development and disturbance. Areas offshore of Port Ludlow Bay are sometimes used by such species as grebes, merlins, herons, and osprey, and construction noise or other construction-related activities could drive them further offshore, However, because suitable open-water habitat is fairly abundant here, such effects are expected to be temporary and minor. Osprey breeding has been reported to occur as close as about one-third mile from the Port Ludlow Resort site. Although some construction noise could be carried that distance, it is not expected to have a significant impact on breeding behavior of this state-monitor species. WDFW has not published management recommendations for nesting osprey, but this particular nest is well beyond the 400- and 800-foot management zones established for bald eagle nests, Port Ludlow MPR Resort Plan Final SEIS 3-31 May 2005 IDJmaI I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Neither marine mammals of concern nor their breeding habitats will be affected by any of the three alternatives, as they are located well beyond the potential zone of construction impacts. Surf smelt and sandlance spawning areas along the east-facing beach will not be affected by construction. Gaseous emissions from construction equipment and vehicle transport will increase during construction, and the higher level of use during normal operations will increase vehicle emissions. These emissions will be controlled through standard emission control equipment and are not expected to exceed any air quality criteria nor to adversely affect plant or animal populations in the vicinity. An accidental release of oil or fuel from construction equipment could lead to petroleum contamination of soil or water. The spill prevention BMPs to be employed during construction should serve to prevent a release from occurring. Even if a release did occur, the flat terrain at the construction sites will make it fairly easy to contain and clean up the spill before it reaches the artificial lagoon, Bay, or any other sensitive receptors. Operational Impacts Once the new Resort facilities are in operation, increased human activity will increase the likelihood of human disturbance to wildlife. The magnitude of these impacts at the Resort site is expected to be relatively minor because of the development that has already occurred there. Most of the Resort area has already been converted from its natural condition to a managed community. Much of the area proposed for new structures currently consists of mowed lawns, and few areas of shrubs and trees will be lost, Species most affected will be those least tolerant of such disturbance, such as ground- and shrub- nesting birds (e.g., dark-eyed juncos, rufous-sided towhees and ruffed grouse) and ground- dwelling mammals (e.g., deer mice and small weasels). Domestic pets associated with the increase of residential use at the Resort could contribute to wildlife mortality through predation or habitat disturbance. Some species such as gulls, squirrels, raccoons, mice, and coyotes will likely do well and may experience growth in population size in the more developed environment. Noise and other human activity may cause foraging eagles and other protected birds to avoid the Resort area and immediate surroundings, although the current level of such use is low. Considering that less-developed areas are located across the Bay and north of the Resort, birds diverted from the Resort area are expected to find more suitable foraging habitat elsewhere. Over the life of the project, the maintenance of the Resort's stormwater conveyance and treatment system as a result of the Resort developments will ensure that the new facilities are adequate to manage both the quantity and quality of runoff so that plants and animals are not adversely affected. In conjunction with the Resort's plans for the application of fertilizers and pesticides, the stormwater collection and treatment system is expected to protect water quality over the long term. None of the three alternatives would impact wildlife migration patterns, since no specific migratory corridors exist on the site. No protected plant species or wetlands would be affected Port Ludlow MPR Resort Plan Final SEIS 3.32 May 2005 ~ by any alternative either in the short or long term. With stormwater management BMPs in place, project impacts are not expected to extend as far as the nearest state priority habitat - an estuarine zone about 0.25 mile west of the marina, None of the alternatives are expected to have any impact on Ludlow Creek (about one mile southwest of the marina) or on the three priority salmonid species that spawn and rear in that system. Increased residential and Resort use will result in increased human use of the east-facing beach, primarily as occasional beach combing and related low-intensity use. If this activity were to occur when eggs of surf smelt or sandlance were present in the beach substrate, some eggs could be crushed and the reproductive success rate of these fish populations could be reduced. Due to the limited use of the beach by humans, the effect is expected to be small in terms of the percentage of eggs lost and the impact on local populations of these species. The project is not expected to significantly affect individuals or populations of Columbian black- tailed deer or beaver, two state game species of concern in the area. Although use of the Resort site by these species may decrease, current use is believed to be low because of the lack of suitable habitat. Any significant operational impacts are not expected to extend beyond the resort boundaries. For all three alternatives, neither operations nor construction activities are expected to have any effect on the three ESA-listed threatened fish species that could occur in marine waters in the vicinity: Puget Sound chinook salmon, Hood Canal summer-run chum salmon, and bull trout. Alternative-Specific Upland Impacts In addition to the impacts common to all tffi:ee four development alternatives (described above), additional alternative-specific impacts could occur. These specific impacts are addressed in the following sections. Alternative 1: Applicant's Proposed Preferred Project - 2003 Proposed Resort Plan A total of approximately 4 acres of lawns or ornamental vegetation will be disturbed during construction of Alternative 1, which includes demolition of the Harbor Master Restaurant located just north of the lagoon. Alternative 1 includes 39 new townhomes in Admiralty III to be constructed south and east of the existing Conference Center. Both areas are flat and largely covered by lawn. The southern portion includes a few scattered trees and a circular grove of red alder trees and dense blackberry bushes about 25 feet in diameter. It is expected that most of the trees and the grove will be removed, although the revegetation plan is expected to include replacement of any trees lost. Construction of Ludlow Bay Village residences (62 townhomes/condominiums) will mostly affect areas covered by lawn and, to a lesser extent, landscaped vegetation. Most of this construction will occur north and east of the lagoon. The new units of Ludlow Bay Village as well as the new restaurant and new recreation building near the waterfront on the west side of the Resort will be constructed on flat, mostly lawn-covered areas or existing rip-rap. Special erosion Port Ludlow MPR Resort Plan Final SEIS 3-33 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I and sedimentation control measures will be employed here to minimize the potential for local water quality impacts on the Bay during construction. Construction of the 8-foot-wide boardwalk along the waterfront between the new Restaurant building and the Inn may affect nearshore habitats in the immediate area. However, the impact on plants and animals is expected to be small because the work will occur above the ordinary high water line, BMPs will be installed to control runoff, and any soils or sediments reaching the intertidal zone should be carried away and dispersed by waves and tides. Alternative 1 does not involve any alteration of the artificial lagoon. Demolition of the Harbor Master Restaurant and construction of residential units along the northern edge of the lagoon could cause water quality impacts, although BMPs will be installed and maintained during construction to control runoff. Any releases to the lagoon are expected to be temporary and limited to an increase in suspended sediments, which will largely settle or be filtered out by subsurface soils before the water seeps into the Bay. The poor habitat conditions in the lagoon and the apparent lack of sensitive species would minimize the impact of any accidental releases. Operational impacts associated with residential units extending over the edge of the lagoon are primarily limited to the effects of shading on aquatic life in the lagoon. This shading is not expected to have an impact on plants and animals. First, the total shaded area will be small relative to the total area of shoreline. Secondly, the lagoon offers poor nearshore and in-water habitat for fish and wildlife and is dominated by species that are able to adapt to a wide range of water quality conditions. Finally, the overwater structures will not be located in the vicinity of the two eelgrass clumps, and the lagoon does not support salmonids or other sensitive species that can be affected by shading under certain conditions. In fact, any effects from shading may prove to be beneficial -- i.e., it is possible that shading from these residential units combined with landscaping along the edges of the lagoon will enhance the diversity and complexity of habitat types and help promote a more valuable lagoon ecosystem. Alternative 2: 1993 Resort Plan A total of approximately 4 acres of lawns or ornamental vegetation will be disturbed during constmctionoLAlternative 2. Alternative 2 includes 50 new townhomes in Admiralty ill which, like Alternative 1, would be constructed south and east of the existing Conference Center. Both areas are flat and largely covered by lawn. The southern portion includes a few scattered trees and a circular grove of red alder trees and dense blackberry bushes about 25 feet in diameter. It is expected that most of the trees and the grove would be removed, although the revegetation plan is expected to include replacement of any trees lost. Construction of Ludlow Bay Village residences (72 townhomes/condominiums) would mostly affect areas covered by lawn and, to a lesser extent, landscaped vegetation. Most of this would occur north and east of the lagoon and near the waterfront on the west side of the resort. These are generally flat, lawn-covered areas, Special erosion and sedimentation control measures will Port Ludlow MPR Resort Plan Final SEIS 3.34 May 2005 ~ be employed here to minimize the potential for local water quality impacts on the Bay during construction. Alternative 2 does not involve any alteration of the lagoon. Construction of residential units along the northern edge of the lagoon could cause water quality impacts, although BMPs will be installed and maintained during construction to control runoff, similar to Alternative 1, Alternative 2 would not involve restaurant demolition, a new waterfront commercial building, and recreational facilities in the western portion of the property, nor a boardwalk along the waterfront. Alternative 3: No ActioR (1999 Resort Planj A total of approximately 4 acres of lawns or ornamental vegetation will be disturbed during construction of Alternative 3. One of the differences between this and the other two alternatives is that Alternative 3 might not include development of the Admiralty ill area east and south of the Conference Center. Thus, the existing lawn and scattered trees in that area would remain. The major difference is that Alternative 3 would involve significant alteration of the artificial lagoon. Assuming environmental permits could be obtained, -:-+!he eastern two-thirds of the lagoon would be filled, lawn would be planted over that area as open space, and major facilities would be constructed north and east of the new lawn area. These facilities include, an underground parking garage, a 238-room addition to the Inn, a large conference center and a restaurant. The filling of the lagoon would directly impact the fish, mollusks, plants, and other organisms that occur in the water as well as the waterfowl and other birds that feed and rest on its surface. A cofferdam could be constructed or other BMPs could be implemented so that sediment-laden water was contained and treated, although it is possible that the lagoon filling and adjacent construction could result in the discharge of some quantity of sediment-laden water to the Bay. Although filling two-thirds of the lagoon will be disruptive to a variety of plants and animals that use the lagoon, this loss may not be significant. One aspect of this evaluation of significance is the fact that the lagoon was artificially constructed and water levels are artificially maintained by daily pumping of seawater. The lagoon is not a natural system and is not known to support any species of particular value or concern, Birds use the lagoon for resting and feeding (on algae and invertebrates primarily), but a reduction in lagoon area may have little affect on the magnitude of usage. On the other hand, public and regulatory concerns about filling the lagoon have been significant. Alternative 4: Response to Comments The impacts of Alternative 4 to plants and animals would be similar to Alternatives 1 and 2. Port Ludlow MPR Resort Plan Final SEIS May 2005 ~ 3-35 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Alternative 5: No Action No further development within the Resort area at this time would result in no immediate impact to existing plants and animals. Cumulative Impacts This section combines the impacts associated with development of upland portions of the Resort (described above) with the impacts related to the planned expansion of the Port Ludlow Marina. The upland commercial and marina construction activities will likely overlap in time. The most notable impacts of each of the three Resort development alternatives on upland plants and animals are due primarily to an increased level of human activity and the affect of that activity on noise, traffic, and runoff in the immediate vicinity. The fact that the Resort site has largely been altered previously and that the areas to be impacted contain no natural vegetative features or valuable habitats means that, compared to new construction in a previously undeveloped location, the project impacts will be incremental and minor. This assumes that BMPs needed to control offsite impacts will be installed, monitored, and maintained properly throughout the course of construction. The one exception to this conclusion is the high degree of public and regulatory concerns associated with lagoon filling iri Alternative 3. In addition to these impacts, the effects on marine species and habitats due to marina expansion must be considered. These impacts are largely addressed in the draft and final SEIS prepared for that project (Reid Middleton, 2002a; Reid Middleton, 2002b) and can be summarized as follows: . No adverse impacts to eelgrass or other marine macrophytes . Displacement of small area of benthic habitat due to pile installation (currently projected to be 120 piling but subject to revision during final design), partially offset by increased surface area for future colonization by marine plants and animals . A voidance of significant numbers of juvenile salmonids by constructing only during the work window approved by WDFW . Generation of noise, vibration, and turbidity during pile driving possibly causing salmon, birds, and mammals to temporarily avoid these areas . Increase in overwater coverage may increase predation, alter migratory behavior, and reduce prey production and availability for salmonids. . Increased shading of predominantly deep subtidal habitats beneath the floats resulting in minor decreases in macroalgae and benthic productivity, offset by substantial additional surface area for colonization by aquatic vegetation and invertebrates . Increased productivity of epibiota due to the floats providing additional area for colonization . Temporary and localized disruption of foraging behavior by forage fish and groundfish due to pile driving and elevated turbidity Port Ludlow MPR Resort Plan Final SEIS 3-36 May 2005 IDJmaI . No effects on fish access, fish refugia, substrate, shoreline, riparian conditions, flow and hydrology, current patterns, or saltwater-freshwater mixing patterns . No adverse modification or destruction of designated critical habitat for Chinook or Hood Canal summer-run chum, both species protected under the Endangered Species Act (ESA) . No significant impacts on bald eagles, marbled murrelets, or Stellar sea lions, all protected under the ESA . Possible short-term disruption of bird and marine mammal foraging behavior during construction but no long-term effects on either group. . No effects on populations of shellfish in Port Ludlow Bay In summary, the greatest cumulative impacts on plants and animals caused by any of the three alternatives are likely to be centered on the nearshore marine environment in the immediate vicinity of the marina. This area will be subject to turbidity and shading effects from both marina expansion and to potential runoff of sediments and other contaminants from upland development near the shoreline. The magnitude of these impacts will depend on whether the marina and upland construction activities overlap and the effectiveness of BMPs and other measures intended to limit the disturbance (including the monitoring and maintenance of BMP effectiveness). 3.3.3 Mitigating Measures Proposed - All Alternatives (AlteTRstive 1): Upland Development . All three upland alternatives will include a revegetation and landscaping plan designed to control erosion and runoff during construction and to offset the permanent loss of plant cover. The first element of the plan involves restoring disturbed areas as soon as construction has ceased using species that mimic the vegetation located within the existing area. The impacted areas will be vegetated with native species that are perennials, have good soil-binding qualities, grow relatively quickly and provide habitat cover. The selection of vegetative species will also be based on the hydrologic requirements of the plants and their attributes, such as being able to support wildlife, to improve water quality, and to foster aesthetic appeal. Selecting vegetation found in the vicinity of restoration helps to avoid the spread of non-native and undesirable species, such as reed canarygrass, Scots broom, and Himalayan blackberry, and it also serves to foster survivability of the planted species. . Native plants will also be established along the south and west sides of the lagoon. A conceptual planting plan is shown in Figures +GA-12A -i-QG12C, and described in Appendix C. Low growing grasses and shrubs will dominate, with special emphasis on species that provide food and cover for wildlife (such as dune grass, wild rose, twinberry, Douglas aster, salt grass, low growing willow, shore pine, and Douglas fir), Logs, rocks and other natural features will be included in the landscaping plan. 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The proponent also intends to include new purple martin nesting boxes in this area, This additional landscaping will serve multiple purposes, It will: make up for lost primary productivity associated with land conversion; provide terrestrial habitat for birds and other small animals; serve as a partial buffer to control the quantity and quality of stormwater reaching the lagoon from adjacent lawns, roadways and parking areas; and provide aesthetic benefits, Alternative 3 (1999 Resort Plan) . Alternative 3 would require special mitigation to compensate for the partial filling of the lagoon. A previous evaluation of lagoon filling by WDFW and Jefferson County led to the conclusion that replacement mitigation would have to be created in the vicinity of Ludlow Bay. Three potential mitigation sites were evaluated: the stream associated with the Oak Bay Road bridge, the Ludlow Creek area and a marshy area in the vicinity of Ludlow Point Villages. Further investigation will be necessary before mitigation plans can be developed at any of these or possibly other sites, Marina Expansion Because the final design for the marina expansion has not yet been completed, WDFW has not made a final determination of specific mitigation requirements to be attached as conditions to its Hydraulic Project Approval (lIP A). Nevertheless, once these details have been worked out, the applicant has committed to prepare a mitigation plan that complies with the terms of the marina expansion HP A and WDFW's goal of no net loss of habitat functions and values, as related to both the marina and upland developments. Mitigation specific to the marina expansion includes the following elements: . The kayak float will be relocated to deeper water and designed to include light- penetrating panels (one design under consideration is a grated polymer panel that allows water and sunlight to pass through the walking surface). . Boater education regarding potential impacts of discharged or spilled wastes or hazardous materials will be increased, and a "no black water discharge" rule will be enforced. . It is anticipated that the loss of benthic habitat associated with the installation of 120 new piling will be mitigated by removing a yet-to-be-determined number of old, unused wood piling from the head of the Bay (based on final design considerations, the applicant and WDFW will agree on a mitigation ratio which is expected to be 1: 1 or greater). . All in-water work will be conducted during approved work windows when salmon are not likely to be present. . The U.S. Army Corps of Engineers has issued a permit for the 100-slip expansion; this permit includes concurrence by NOAA Fisheries and U.S. Fish and Wildlife. 3.3.4 Unavoidable Adverse Impacts Under all three alternatives, including the marina expansion component, the following impacts are unavoidable: disturbance and displacement of some fish and wildlife species due to elevated levels of human activity and noise during the construction period; loss of vegetative cover and productivity between the time land is cleared and the time revegetation takes hold; increased Port Ludlow MPR Resort Plan Final SEIS May 2005 IDJmaI 3-41 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I surface runoff due to an increase in impermeable surfaces; loss of small areas of subtidal benthic habitat at the location of the new piling; possible loss of algal and epibenthic productivity at locations beneath the new floats; mortality to beach-spawning forage fish associated with increased human use of the beach; and increased risk of spills or discharge of gray/black water, petroleum products, or hazardous material. Port Ludlow MPR Resort Plan Final SEIS 3-42 May 2005 ~ 3.4 LAND AND SHORELINE USE 3.4.1 Affected Environment Port Ludlow is located in a generally rural portion of eastern Jefferson County, approximately six miles north of SR 104. The MPR is centered on the inner portion of Port Ludlow Bay and extends both north and south of this inner portion of the Bay. The Resort complex is situated on the north shore of the Bay and includes both shoreline and upland properties. Project History Port Ludlow was originally settled in the mid-1800s as a shipbuilding, logging, and sawmill community. By the 1880s, Port Ludlow encompassed a sawmill, log dump, numerous homes, a hotel, and other facilities. These facilities were generally located in the area of the current Resort. The sawmill was permanently closed in 1935 and subsequently dismantled. The existing homes were moved to Port Gamble. Development of the current Port Ludlow Resort and residential community was initiated in the late 1960s, with construction of the Harbormaster Restaurant, Conference Center, and the marina. The Admiralty I and II areas were platted in 1968, and the plat of Ludlow Bay Village was recorded in 1994. As approved by Jefferson County, the Port Ludlow MPR as a whole will include up to 2,250 dwelling units (1,800 of which have been developed to date), the Resort complex, a 27- hole golf course, a small retail center, and extensive parks and open space. Existing Resort Development The Resort complex is located on the north shore of Port Ludlow Bay, in the area of the original shipbuilding/sawmill community. To date, approximately three-quarters of the Resort area has been developed. Existing Resort development includes: . The Harbormaster Restaurant (5,000 square feet/120 seats) . The Inn at Port Ludlow (37 rooms) . Residential units (25 townhomes and one single-family dwelling within Ludlow Bay Village, and 64 condominiums within the Admiralty I and II areas) . The LMC Beach Club (private recreation facility, open to guests at the Resort) . One conference building . Paved and graveled parking areas . Open space including "Mill Pond" (an artificial, man-made lagoon), areas of open lawn, informal trails, and a viewing area at Burner Point; and . A 280-slip marina with support facilities. The marina serves Port Ludlow area residents, guests, and boating groups. The 27-hole Port Ludlow Golf Course, located on the south side of the Bay, is a major attraction for visitors to the Resort. Port Ludlow MPR Resort Plan Final SEIS May 2005 ~ 3-43 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Project Area The Resort complex is surrounded by residential portions of the larger Port Ludlow MPR to the north and west and is bordered by Port Ludlow Bay on the south and east. Immediately west of the Resort complex, properties around the inner portion of Port Ludlow Bay are occupied by single-family homes and condominiums. Properties further upland are situated atop the hill and are occupied by single-family homes. The majority of the Resort complex is separated from surrounding single-family development by Oak Bay Road. Properties immediately west of the Marina lie within a designated "Single-Family" area and are occupied by four single-family dwellings. These properties access Oak Bay Road via Scott Court, and for purposes of this discussion are referred to as the "Scott Court Properties." A four-slip dock serves these residential lots. This dock, known as the "Scott Dock," is located approximately 150 feet from shore, approximately 300 feet west of the Port Ludlow Marina C- and D-Docks. Within the inner portion of the Bay, the number of existing private docks is small; these docks are generally locatedon the southwestern shore of the Bay. The Meydenbauer Bay Yacht Club uses four dock slips at the west end of Port Ludlow Bay, as well as rafting boats together and anchoring boats in the Bay, as a satellite club facility. Land Use Regulations Current land use regulations pertaining to Port Ludlow stem from the 1998 Jefferson County Comprehensive Plan, designating Port Ludlow a Master Planned Resort (MPR), and the 2000 Port Ludlow Development Agreement. Jefferson County Ordinance Number 08-1004-99, adopted in October 1999, establishes the Port Ludlow Development Regulations consistent with the MPR designation established in the Comprehensive Plan. Under Ordinance No. 08-1004-99, the Port Ludlow MPR is divided into several zoning districts, one of which is the "Resort Complex!Community Facilities (RC/CF) Zone.:,,;_" The requirements of the RC/CF zone are contained in Section 3.40 of Ordinance No. 08-1004-99. -The purpose of this zone is to provide amenities and services associated with a Resort and the surrounding community and to support existing residential uses. Uses allowed in this zone "...recognize the recreational nature of the Resort and include the existing and planned Resort complex, as well as limited pennanent residential uses, and non-resort community facilities including a beach club and Kehele Park:-" (Section 3.401 ). Section 3.402 describes the permitted and conditional uses allowed in the RC/CF zone. A variety of conference facilities, lodging, recreational facilities and multi-family and single family residential structures 00 units/acre density) are allowed. Height. bulk and dimensional requirements for Resort Uses are identified in Sections 3.404 and 3.405.' Some comments received on the Draft SEIS were concerned with the application of these bulk standards to uses other than those anticipated in the 1999 Resort Plan. Issues related to application of the MPR Regulations will be addressed in the Department of Community Development staff report prepared for this project. The Port Ludlow land use designations are shown in Figure 13H. Port Ludlow MPR Resort Plan Final SEIS 3-44 May 2005 ~ D D - ~ Comprehensive Plan - Figure 13 Port Ludlow Resort Plan FSEIS Port Ludlow Master Plan Resort Boundary Single Family Residential 4 DU per acre (MPR.SF 4: I) Single Family Tracts I DU per 2.5 acres (MPR-SIT 1:2.5) Single Family Residential I DU per 5 acres (RR 1:5) Multi-Family Residential 10 DU per acre (MPR.MF 10:1) Resort Complex Community Facilities (MPR,RC/CF 10: I) Village Commercial Center (MPR.VC) Recreation Area (MPR,RA) Open Space Reserve (MPR,OSR) Resort I '1 'I f{ 'I , ~::'~:~=k;~;~ FOR INFORMATIONAL PURPOSES ONLY. Jefferson COllllt)' dues f10Cllttest to the aCClIrll(Y of the data contained herein and makes no warranty with respect to its correctness or validit)'. Dara contained ill this map is limited by the method and accuracy of its collection. Product (!f Jefferson County Illtegmted Duta MtI1U1gemellt Systems. In addition to recoxni::.ing legal pre+exisfillg land lIses. Jefferson County recogni::.es pre- existing lots of reconl as legal lots. Current parcel database us olJuh. 1998. /idms5/comp,clips/ludlow.aml by dal'idn on November 04. 1998 Port Ludlow Comprehensive Plan - Land Use Designations I I I I I I I I I I I I I I I I I I I In addition to regulations pertaining to the RC/CF zone, The approved Resort Plan is described ffi-Section 3,90 - "Resort Development" of Ordinance No. 08-1004-99 describes the "Resort Plan" in terms of facilities to be allowed, the process for required environmental review, and the process for reviewing major and minor revisions to the Resort Plan. Section 3.901 identifies the specific facilities (and their sizes) that are--ffi could be developed within the Resort Complex/Community Facilities Zone. Section 3.90 envisions the Resort as a destination resort for large groups, as well as the traveling public. Section 3.901 "Resort Plan" identifies Resort facilities encompassing 498,300 square feet of development, not including residential structures. Facilities include a 275-room hotel, two restaurants, resort retail, a conference center, a recreation complex, museum or interpretive center, amphitheater, youth center, an expanded marina, and public open space. Multi-family and single-family structures are permitted uses within a density not to exceed 10 units per acre. Changes to the Resort Plan that decrease the size of the facilities are allowed. Section 3,903 addresses vested residential development rights, including the requirement to apply for a plat alteration (or boundary line adjustment) as part of the permitting process for new resort development. The Development Agreement and MPR regulations eXlJlicitly acknowledge the existing plat of Ludlow Bay Village and the potential conflicts between the plat and the then- anticipated Resort Plan (Alternative 3 of this FSEIS). Section 3.903 requires a Plat Alteration prior to issuance of permits for any new Resort development if the approved Resort Plan does not include all the development rights vested in the plat. Any development rights not included in the approved Resort Plan must be "withdrawn, vacated or otherwise permanently released" by means of a plat alteration. The need for the plat alteration thus can only be determined after the Resort Plan has been approved. Section 3,904 describes the environmental review process required for resort development. Revisions to th~is Resort Plan are provided for in Sections 3.905 and 3.906. Section 3.906 describes the information to be provided in an application for a Major Revision to the Resort Plan. The MPR as a whole is subject to a development cap (e.g., a maximum limit of development). To implement and monitor this cap, while providing for flexibility regarding future land uses, a measurement and transfer system was developed. This system is based on the actual number of residential lots, residential units, and equivalent residential units for commercial development. The unit of measurement is termed an "MERU" (Measurement Equivalent Residential Unit). Total MERUs are not to exceed 2,575; total residential units are not to exceed 2,250. Jefferson County maintains an official MERU Record. Since adoption of the 1999 MPR regulations, it has become evident to the owners of the Resort that a destination Resort oriented to large conference groups is not feasible for Port Ludlow. Changes in the resort market have resulted in a need for a resort more oriented to the traveling public. A change to the Resort Plan as outlined in Section 3.906 of Ordinance No. 08-1004-99 is therefore proposed, Port Ludlow MPR Resort Plan Final SEIS 3-46 May 2005 ~ In addition to market factors, the 1995 plat of Ludlow Bay Village (located north of the marina within the Resort area) and subsequent construction of townhomes within this plat, has limited the ability of Port Ludlow Associates to construct certain facilities anticipated by the 1999 MPR regulations. 3.4.2 Environmental Impacts Short- Term Construction Impacts Alternatives 1, 2, aBd-3. and 4: For all alternatives, construction activities will result in short-term impacts to the existing Resort uses, Marina and upland construction activities will also result in short-term impacts to adjacent residential properties. Construction activities will temporarily increase noise levels and levels of suspended particulates (dust); fumes from construction equipment may be noticeable; and truck and marine barge traffic will increase. Construction noise will be generated primarily by operation of heavy machinery for grading and earthwork and from pile driving, but will also come from the use of generators, other small engines, and hand tools. Construction hours will be limited to 7:00 a.m. to 6:00 p.m., Mondays through Saturdays. For the Port Ludlow Marina expansion, the Marina Expansion SEIS concluded that construction noise will be generated primarily by pile driving and will be heard from the Resort area and the Scott Court properties to the west. Data from the Shilshole Bay Marina Dock Replacement/Moorage Expansion Project Draft Supplemental Environmental Impact Statement (Port of Seattle, 2000) indicates that, from a noise standpoint, the "worst case" pile driving scenario is a diesel-powered hammer driving steel piles into a very hard subsurface soil layer, with no noise abatement shrouding. In this scenario, the Leq measured 1O0 feet from the diesel hammer was 95.9 dBA. At 180 feet, the Leq will be 90.8 dBA and at 300 feet, 86.4 dBA. The noise level will be determined largely by the number of piling to be driven and the depth to which they are driven. Given the subsurface conditions at the Marina, it is anticipated that both a vibratory hammer and a drop hammer and/or diesel hammer will be used. The pile driving will occur over an approximate 45-day period. Because sound travels well over water, construction noise will likely be heard around the entire Bay, but will not be as significant. WAC 173-60 states that noise emitted by any commercial or industry activity shall not exceed those levels established by the Washington State Department of Ecology, WAC 173-60.030 classifies residential sites and parks and recreational sites as Class A EDNA (Environmental Designation for Noise Abatement zone). The maximum noise exposure levels for noise emitted in Class A EDNA that is received by Class A EDNA is 55 dBA (WAC 173-60-040). WAC 173-60-050 lists activities that are exempt from the maximum noise level requirements of WAC 173-60-040. Section 3-a exempts sounds originating from temporary construction sites as Port Ludlow MPR Resort Plan Final SEIS May 2005 ~ 3-47 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I a result of construction activity with the exception that these sounds are not allowed between the hours of 10:00 p.m, and 7:00 a.m. in Class A EDNA receptors. Impacts from increased construction truck and barge traffic will be concentrated within the shoreline area, although the pile-driving barge will also be located in the vicinity of the Scott Dock, The barge will not block access to that dock. Fumes from the construction activities are not anticipated to be significant. Alternative 5: No Action No further development within the Resort area at this time would result in no immediate construction impacts within the Resort area. Long-Term Impacts Alternative 1: Applicant's Proposed Preferred Project - 2003 Proposed Resort Plan Construction of Alternative 1 would result in build-out of the Resort complex, with Resort facilities designed to serve the traveling public. Conferences will still be accommodated but on a smaller scale and would be housed in existing facilities such as the Heron Beach Inn, the Bay Club, the Beach Club, and the relocated Harbormaster Restaurant. Large, outdoor special events would no longer be accommodated. At build-out, development within the Resort area would include: Residential Units 191Q residential units, described as follows: ~Admiralty area - The existing 64 stacked condominiums within Admiralty I and n, together with 39 new townhomes within the new Admiralty ill (32 stacked flats and 7, two-story townhomes). .gLudlow Bay Village - The existing 25 townhomes and one single-family dwelling, together with 62 new units stacked flat condominiums (48 stacked flats, and 14, 2-story townhomes). This is an increase of 30 units over the existing 58-lot plat of Ludlow Bay Village. Vehicular access to existing townhomes within Ludlow Bay Village will be restricted to Heron Road and will be separated from access to the adjacent Inn. · New townhomes will maintain the existing architectural theme established in Ludlow Bay Village (i.e" New England/Colonial) and will be 1,200 - 1,500 square feet in size - smaller than existing townhomes in Ludlow Bay Village. The smaller size is intended to allow for an overall variation in product type and price range. Typical floor plans for the new residential units are shown in Figure ~14A. Hotel · Inn at Port Ludlow- Existing 37 room inn, including restaurant and lounge. The existing building will remain unchanged, however, vehicular access to the Inn will be modified. Vehicular access to the Inn and its associated parking will be restricted to Port Ludlow MPR Resort Plan Final SEIS 3-48 May 2005 ~ :::I l> , , Z r-J 11 ~! r I~ () , () L -1 III J I i i la I I I J I~ I i c I -0 I -0 m I -{ < III :::I 11 r P- c "C 8 z z -. -,I n 11 IU r QI l> () /U - () ()) l> ." IU J> - 0 0 ~ "'a - QI :s '" c -0 -0 m III 11 r () () IU l> lJl c -0 -0 m IU 11 r () () IU .....-\- 0) w o r~ :3 .!!: :z n ~ f : ~ '=l ~ r; - ~ :z ~ ~ ~ tr:1 ~ C) n ~ 8 ~ z Bi 0 ~ ~ Z ~ ~- i~ :::ll:J I 00 ,...., 0\ o o ~ r- s:: C. - o ~ = QI '< < -. - - QI \C (1) .....-\- --oJ g -\- ..... --oJ 00 o .....-\- ?J CJ'l o .....-\- co o o I I I I I I I I I I I I I I I I I I I .g. Gull Drive and separated from access to the adjacent townhomes. The existing 36-stall parking lot will be reconfigured to provide 55 spaces, Regarding interior improvements, the size of the formal restaurant will be reduced to double the size of the Fireside Lounge, Waterfront Facilities . Waterfront Commercial Facility. A new I-story building will be located on the shoreline near the west end of the marina which will contain the Dock Master's office, the marina maintenance area, and a store for marina tenants and guests. This facility will be situated adjacent to the relocated Harbormaster Restaurant. The building will maintain the New England/Colonial architectural theme; a preliminary architectural elevation of the building is shown in Figure ~ 14B. . Harbormaster Restaurant (relocated) The existing restaurant building will be demolished, and the restaurant will be relocated to the waterfront commercial facility near the marina. The seating capacity will be reduced from 120 people to 90 people (inside seating for 60, together with outside seating for 30). A preliminary architectural elevation of the building is shown in Figure ~14B. . Private Recreational Facility - 7,500 square feet A new 2-story, indoor recreation facility will be located adjacent to the waterfront commercial facility near the west end of the marina. The facility will include an indoor-outdoor swimming pool, spa, and a fitness center and will be available only to residential property owners within Ludlow Bay Village and their guests, guests at the Inn, and guests at the marina. The recreation building will also be designed in the New England/Colonial style; a preliminary architectural elevation of the building is shown in Figure-l-2B14B. . LMC Beach Club Recreational Facility and Bridge Deck No changes to this existing private facility or its parking areas are proposed. · Port Ludlow Associates Offices (existing building) Offices for Port Ludlow Associates will be moved from their current location (off Paradise Bay Road) to the old conference center along Oak Bay Road, in the north end of the RC/CF zone. Approximately 30 employees will be located in this building. . Maintenance building - 2,900 square feet A new maintenance facility serving the Inn and other Resort operations will be located just east of the old conference center facility. . Central Receiving Dock A new, approximately 1,000-square-foot central receiving facility will be located within an existing parking lot on the north side of Harbor Drive. Port Ludlow MPR Resort Plan Final SEIS 3-50 May 2005 ~ :b :0 --~_.~- .. ---G) ~ ~!., c: .:.. ~ en c;j :0 -t . ---.-..---0) ~ ~ -, ::0 -; ::0 111 C1 111 -~--- -, -, . -.... :b rn -- _. -~..:,: ,.lII ::' () =":::~_-- ,J ./ ::0 (") ::0 'T~ ~ ::0 ~ ~ c~ .. en ::j :0 ::! 0 --~ <: . 0 I\.) -- .... <= ::0 ::0 OJ 111 . ~ w r- .... tJ -- ::0 r- G) OJ . .tl... Po c: .... -- ::0 ::0 r- tJ . _.~ rn 0) -- If- ti"- C/) <: Po G) ~ en c: ::0 ~ . c: C;1 ........ ~ I>- -t <= ~ ...... 111 OJ -- -- ----- ,---{~ r- 0 ,.1 II G) I I -~,. 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Off-street parking (existing and proposed) All new residential units will include off-street parking for two cars. In most cases, the parking will be "tandem" - i.e., a one car garage, with parking for one additional car in the driveway. In addition, aA total of 387~ off-street stalls will be provided in a series of paved parking lots serving the marina, commercial, and recreational uses in Ludlow Bay Village. Per Jefferson County Code, 322 parking spaces are required. Fourteen of these spaces must be ADA compliant. The calculation of required parking and parking provided is shown in Appendix J. Although PLA currently has an agreement with the Ludlow Maintenance Commission (LMC) for use of certain spaces for overflow parking; these spaces are not counted as part of the spaces provided. The Alternative 1 Resort Plan locates parking both adlacent to the commercial facilities in a "lower" and "immediate upper" lot, as well as in a series of "upper" lots along the north side of Heron Road. These lots are identified on Appendix J - Parking Layout Plan. Parking at the west end of Ludlow Bay Village will be reconfigured, expanded, and more actively managed. More details regarding the individual parking lots is provided in Appendix J. . Designated Helipad for Emergency Evacuations (proposed) A 20-foot by 20-foot paved helipad for use by Fire District No.3. The pad will be located north of Marina View Drive between Oak Bay Road and Olympic Place. . Open space, trails (existing and proposed) A designated, signed trail system will be developed within Ludlow Bay Village to provide for better pedestrian circulation and access to public portions of the shoreline. The pedestrian access/trail plan is shown in Figure_-l~ This system will include an eight-foot-wide wooden boardwalk/esplanade along the shoreline that will extend from the new restaurant, east to the Inn. Existing open space along the south side of the artificial lagoon will be retained, as will the open space at the end of Burner Point. Parking for access to the public trails will be located at the upper community lot. . Infrastructure Improvements Roads - The internal road system for the Resort has been substantially completed in conlunction with past development activities. All streets within the Resort are privately owned and maintained. Please refer to Section 3.6 of this Final SEIS for a detailed discussion of the existing and proposed internal roads. Storm Drainage - New water quality vaults will be added at each of the inlets to the artificial lagoon to supplement water quality treatment. Also, within Admiralty III, new stormwater detention facilities, as well as water quality facilities, will be Port Ludlow MPR Resort Plan Final SEIS 3.52 May 2005 ... :c () <( w en IE z :c () <( w en " (I) o~ ~ CL>...........c '- 0 :J-oo'- -0 ...2 Ql Ql '" ,-..c:cno .....1-2E o .0 c ~"2..~ c 0::>::>1- .B :;:; .Q'l . Q) O.......c.,;"'O'1J ~.~ ~ ~ 0 ~ :;:;:5.DE~::;;: ~c~~I....:2 :Q.- ~ ~ '0 ~ Ql" ..cQl - _]f)~~E c E (j) E - ._ '" 0::> I"') _o~Eoo .~ '" 1 o.g ~ ",Qll- - o ~ . o.~ Q:; :JQ} 0..0 B g 1V ~::: E "'0 0.002 QlEEoQlo. -geoo:S~ Ql..... 0 C "0 I.... .~ en "'0 a.i'- Q) 0 0 ~ o .~ ~2 ~ ~ .g E_EoO!'-. 'x - 0 ~:.;:: ~ .c o .00 0 ~-E'Q) g:E':= 0: 0.0'- I-~ o ~Q} -~ "'~'- .,,- ~~oo~5Vi o8.o.8~.t ~~o.g~gg o CL"; .~ - CD ..c c Ql..c .0:: u>_Q>tn_Cf) ",gE~.....~ ~ Qlo::>_oQl 0 l.....:';::; L> .~ =0 ::>OOQlCo!::> -0 E -0 2 .2 ~ -' 2o"'Ocoo- .......vEuQ) lo... _c_o'-=oo o '-.2 ::>.D Jl... I....Q)O'J~~. '0 ~ L -+-"' Q....o "'0 OOQl,,~ ~.~ c c: :S ~ C .2 Ql'- 0 Ql.B Ql o~,,"OUCl) U .Q'l ~ en.~ CI) cO! 0....... Ul (I) U).- .- -::>0 ~ l1>.~ ~ ~ .s ~ ~ ~~'6~.g80 ~N in Ql o Z o C C tC - CL. \I') \I') CU u u <C c tC os: .., \I') CU 'C CU CL. Qi o C Ql '- 2 Ql 0:: V) a: w w Z - ~ Z W o w ~ I I I I I I I I I I I I I I I I I I I constructed. The existing storm drainage collection/conveyance system within Ludlow Bay Village will be evaluated to determine if the 100 year capacity is adequate to accommodate the additional runoff from the Admiralty III area. Please refer to Section 3.2.1 of this Final SEIS for a more detailed discussion of the storm drainage system. Sanitary sewer and water service will continue to be provided by the Olympic Water and Sewer Inc. New hook-ups will be required, but the capacities of the existing systems are adequate to handle the increased use. Please refer to Sections 3.7.2 and 3.7.3 of this Final SEIS for a more detailed discussion of the water and sanitary sewer systems. . Marina - 380 slips (280 existing slips + 100-slip proposed expansion) The existing Marina will be expanded by up t0100-slips. The expansion will occur both westward and waterward. Build-out of the Resort as proposed in Alternative 1 will increase the intensity of residential use within the Resort complex. The 101 new residential units will roughly double the number of existing residential units and potentially double the permanent residential population. Assuming a household size of two persons per unit, 202 new residents may be expected. It is unknown to what extent these households will be permanent residents, seasonal occupants, or temporary visitors. It is not anticipated the new residents will include a significant number of school-age children. All new construction within the Resort zone must meet the requirements of Section 3.4 of the MPR Regulations. The question of how the bulk and dimensional requirements contained in Section 3.405 should be applied to development on individual lots within the plat of Ludlow Bay Village will be examined in the staff report prepared for this application. The new townhome units would meet Uniform Building Code setback requirements, consistent with older (pre-1999) townhomes in Ludlow Bay Village. The new buildings and expanded marina will be visible from within the Resort, travelers on Oak Bay Road, and homes along Gamble Lane (above the Resort). The increased building intensity will also be visible from across the Bay, but these views will be distant. The design of the new residential and commercial buildings will be consistent with the New England/Colonial style established in Ludlow Bay Village. No building will exceed 35Jeet in height. The Marina Expansion SEIS concluded that the expanded marina will moderately impact portions of views from the Scott Court properties, Oak Bay Road, and Burner Point. A detailed analysis of impacts to views from the marina expansion is included in the 2002 Port Ludlow Marina Expansion Final Supplemental Impact Statement. The new uses, especially the commercial uses and associated increased use of parking areas, will generate additional light and glare. Noise levels associated with increased vehicular and boat traffic and increased use of the waterfront area will increase over existing levels. No unusual Port Ludlow MPR Resort Plan Final SEIS 3-54 May 2005 ... Port Ludlow MPR Resort Plan Final SEIS 3.55 May 2005 ... I I I I I I I I I I I I I I I I I I I sources of noise are anticipated. The Harbormaster Restaurant, a commercial use, will be relocated from the residential area to the new commercial area along the waterfront. The Marina Expansion SEIS also concluded that odors associated with a marina, such as exhaust from boats, will also likely increase incrementally. Extensive boat repairs are not allowed within the Marina, so odors from repair activities will not be significant. Impacts of Alternative 1 on adjacent land uses (i.e., outside the Resort Complex) relate primarily to potential impacts to the Scott Court residential properties. The Marina Expansion SEIS concluded that the marina expansion will result in Port Ludlow docks lying within approximately 150 to 200 feet of the Scott Dock and within 250 to 350 feet of the closest residential lot (currently undeveloped). Residents of Scott Court have expressed concerns regarding the increased boat activity adjacent to their homes, the ability of boats and seaplanes to access their dock, and the ability to expand their dock if the marina expansion were to be approved. Alternative 2: 1993 Resort Plan Because the overall intensity of Alternative 2 is similar to Alternative 1, the overall land-use . impacts would be similar to those of Alternative 1. Land-use impacts within specific areas of the Resort complex would differ, however. With regard to residential units, 50 new units would be added to the Admiralty area (versus 39 new units with Alternative 1). Within Ludlow Bay Village, the number of new residential units would total 49 (versus 62 with Alternative 1). With Alternative 2, there would be less separation of residential and commercial uses within Ludlow Bay Village. The Harbormaster Restaurant would remain in its current location, the access to the Inn and adjacent townhomes would remain in its current configuration, and the western end of the waterfront area would be residentially developed, rather than occupied by commercial uses. A new Town Hall, rather than a new recreation facility is proposed. Parking for commercial facilities within the LBV area would remain in its current configuration. It is assumed the architectural style of the new buildings would be consistent with the New England/Colonial style, although no architectural elevations are available. The proposed marina expansion would be the same as that proposed in Alternative 1. Alternative 3: 1999 Resort Plan (Na ActiaD) Build-out of Alternative 3 would result in the most intense development of the Resort complex. If construction of new townhomes within Ludlow Bay Village is halted, new development would consist of commercial Resort facilities - outdoor sports facilities, an expanded conference center and hotel, a youth center and museum, and a parking garage. The new resort facilities would be focussed in the Ludlow Bay Village area and would require partial filling of the lagoon and 100 percent approval of the Ludlow Bay Village Homeowner's Association through a Redevelopment Agreement. Assuming: the issuance of the necessary permits, aApproximately half of the existing artificial lagoon would be filled and replaced with open lawn area. Aside from the new hotel, no new residential units would be added. I I I I I I I I I I I I I I I I I I I Given the existing level of residential development that has occurred in Ludlow Bay Village since adoption of the 1999 Resort Plan, full development of the Alternative envisioned in 1999 can no longer be achieved. Certain uses, such as the amphitheater, are no longer feasible. More intense development could, however, still occur along the north side of the lagoon at the western end of the waterfront area and along the slopes adjacent to Oak Bay Road. In this scenario, no new development is proposed within the Admiralty area; the existing conference center building would, however, be converted to a youth center. This issue is also addressed in Chapter 2, Section 2.2 Preferred Applicant's Proposed Project and Alternatives. If, however, a new Resort Plan is not approved, and development of townhomes within Ludlow Bay Village continues, it is unclear what facilities would exist at build-out. The current plat provides for four additional single-family homes along the shoreline, as opposed to additional Resort facilities. The artificial lagoon would remain at its present size, and the Harbormaster Restaurant would remain in its current location. Up to 28 additional townhomes could be constructed. Given the demand for improved Resort facilities, it is unlikely, however, that the owner would fully develop their remaining ownerships only with residential uses; more intense use of the Resort waterfront is anticipated. Alternative 3 would likely result in the greatest increase in noise, light, and glare and overall vehicular and people use of the site and greatest water consumption and waste production. The character of the Ludlow Bay Village area could be that of a commercial resort, with a limited residential environment. Visitors to the Resort would be accommodated in a hotel setting, rather than townhomes or condominiums. The proposed marina expansion associated with Alternative 3 is the same as that proposed in Alternatives 1 and 2. Alternative 4: Response to Comments The land use impacts of Alternative 4 would be similar to Alternative 1, although the proposed density, and associated impacts, would be slightly reduced. At build-out, LBV would encompass a total of 81 residential units (vs. 88 units for Alternative 1), and the new Admiralty III would encompass a total of 96 residential units (vs. 103 units for Alternative 1). No residential units would extend over the artificial lagoon. The marina expansion would be limited to 60 slips (vs. 100 slips for Alternative 1 ). Off-street parking for 299 vehicles would be required; parking for 387 vehicles would be provided. Parking would be provided in the same configuration as proposed for Alternative 1. Typical floor plans and architectural elevations for proposed residential units sited along, but not over the edge of the artificial lagoon, are shown in Figures 15A and 15B. Alternative 5: No Action No further development within the Resort area at this time would result in no additional residential development and/or new recreational amenities, including expansion of the marina. The existing parking in the marina area, and the access to the Inn from Gull Drive and Heron Road, would remain in their current configuration. The Harbormaster Restaurant would remain in the existing building in its current location. Port Ludlow MPR Resort Plan Final SEIS 3-56 May 2005 ... -------- 1) ----- ~----- ----0- -of '< "C _0 n QI - - --"-.-.- .- - -of 0 ~ r0- c: ::J 0 'C :c ~ 'C tD tD 0 .., IU .., ---- ---- 3 c: c: tD :::s l> :::s _0 ;:; ,.... G ." '" '" - 0 0 ., -a - QI ::J V\ I I I I I I I 1_11-+ ___0 --_..~-- / m m >< >< ![ ![ :r :i" co co r OJ 9- c: r ~ :;- ::r CD <D III c.. ~ '" ..:.. 5 ~ ~ ~ Z (J :~R-::c ~ ~ ~ ~ . z-3 2S ~ t:rj ~ ~ n ? 8-3 ~ Bi 0 S ~ z I~ I (j I ~ :::0 :::01:::0 :::0 :::0 :::0 :::0 :::0 :::0 :::0 :::0 :::0 I I I I ... ~ ~ ~ I 00 ~ I I I I r-:., ~ ... ~ N ~ 0 \D (J) U1 .r:>. w to III IT1 - tD < OJ ~ _0 o ::J V\ z c 3 cr to (Xl .r:>. (J) 0'\ (Xl ... o .... C ::s ;:;" UI I e3 m i m\N .r:>. U1 N ~ I I I I ------------------ < 'C -. n QI - n o ::s c. o 3 ::s -. c 3 """ - o o -s "'C - QI ::s V\ r- o ~ to ., c:: ::J ~ VI ~ II: ...:.. Ci ~ ~ i Z n ; !l.i Ill' ~ iil ,!, "tl _ ;:l ~ ~ .-3 ~ ~ t:tj ~ ~ n ~ 8.-3 x Vi 0 ~ ?= Z ~~ ~ -fa- \] \ m x ![ S' lO r 2- r S' CD c:: 'C 'C to ., c:: ::J ~ VI 1"1 - t'D < QI f""to -. o ::s V\ I I I I I I I I I I I I I I I I I I I I I I Since the Resort area is the area within the MPR anticipated to be the most intensively developed, it is assumed that development proposals would be submitted for approval at some future time. Until a future development proposal is approved, there would be no increase in traffic, demand for public services, or additional impacts on the natural environment. 3.4.3 Mitigation Measures Proposed - All Alternatives (Alternative 1): Construction Impacts . Hours of construction will be limited to 7:00 a.m. to 6:00 p.m., Mondays through Saturdays. · Stationary construction equipment will be positioned as far as possible from residential properties. · The construction contract will require that all mufflers are maintained in good working order. . Any dust will be suppressed by utilizing wetting techniques. . Energy-efficient equipment will be used to control emissions. Proposed - All Alternatives: LODf.!:- Term Impacts . The proposed Resort Plan acknowledges the existing residential character and architectural style of the central and eastern portions of the Ludlow Bay Village area. . New street and parking lot lighting will be designed to shield and focus light. Proposed - Alternatives 1 and 4: Long- Term Impacts · The proposed project will provide for an economically sustainable Resort function. · The proposed Resort site plan will separate residential and commercial uses to minimize conflicts associated with traffic, noise, light, and glare. OThe proposed Resort Plan acknmvledges the existing residential character afld architectural style of the central and eastern portions of the Ludlow Bay Village area. ONev.' street and parking lot lighting will be designed to shield afld focus light. From the Port Ludlow Marina Expansion Final SEIS (2002): · The new docks associated with the marina expansion will provide adequate fairway and maneuvering area for access to existing Scott Docks. · The new docks associated with the marina expansion will not block significant portions of existing views. Proposed - Alternatives 1 and 4: Phasine of Amenities Based on comments received on the Draft SEIS, Jefferson County requested that the applicant identify a phasing program for completion of proposed Resort amenities. This phasing program Port Ludlow MPR Resort Plan Final SEIS 3-59 May 2005 ~ I is intended to balance construction of residential units with construction of the remaining I amenities. The following amenities have been constructed within the Port Ludlow MPR to date; Bay Club I Beach Club 27-hole Golf Course and Club House I Retail Center Inn at Port Ludlow and Fireside Lounge I Harbormaster Restaurant and Wreck room Lounge Bus pull-outs/Public Transportation Stops Community Trails and Bridges I Public Marina and Shoreline Access Permanent Open Space and Greenbelts Twin Islands - Permanent Preservation I The applicant has identified the following phasing program for the new amenities recognized as part of Alternative 1. Permitting for each new development phase will be dependent upon I completion of the amenities identified in the prior development phase. Alternative 1 - Applicant's Proposed Project I Proposed Amenitv Phasine Development Phase Residential Units Amenities I I Phase 1 22 units Inn parking lot and fire lane improvements (Buildings R-3,R-7, R-8, R-9) Gull Drive reconstruction to two lanes I Boardwalk (that portion landward of Ordinary High Water) I Lagoon Landscaping and Restoration, south and west sides Phase 2 18 units New Marina Retail/Office I (Buildings R-l, R-2, R-4) Recreation Center (including marina shower, laundry and restrooms) I New Harbormaster Restaurant New Marina and Restaurant Parking I Phase 3 22 units Signage - Community parking (Buildings R-5, R-6) lot/trail/educational I Parking Lot Elevator Phase 4 39 units EMS Helipad I (Buildings R-lO, R-1l, R-12) PlavlITound I Port Ludlow MPR Resort Plan May 2005 I Final SEIS 3-60 ~ I I The applicant has identified the following phasing program for the new amenities recognized as part of Alternative 4. Permitting for each new development phase will be dependent upon I completion of the amenities identified in the prior development phase. Alternative 4 - Response to Comments I Proposed Amenitv Phasine Development Phase Residential Units Amenities I I Phase 1 17 units Inn parking lot and fire lane improvements (Buildings R-3, R-7, R-8, R-9) Gull Drive reconstruction to two lanes I Boardwalk (that portion landward of Ordinary High Water) I Lagoon Landscaping and Restoration, south and west sides I Phase 2 18 units New Marina Retail/Office (Buildings R-l, R-2, R-4) Recreation Center (including marina shower, I laundry and restrooms) New Harbormaster Restaurant I Parking for New Marina and Restaurant Phase 3 20 uni ts Signage - Community parking I (Buildings R-5, R-6) lot/trail/educational Parking Lot Elevator I Phase 4 32 units EMS Helipad (Buildings R-1O' R-12) I Playground I 3.4.4 Unavoidable Adverse Impacts Build-out of the Resort will result in more intense development of the project area. Increased I development and use of the area will result in increased activity levels, vehicular traffic, noise, light, and glare; this increased intensity of use will be noticeable to existing users and residents within the Resort. I I I I Port Ludlow MPR Resort Plan May 2005 Final SEIS 3-61 ... 3.5 LAND AND SHORELINE USE - RELATIONSHIP TO PLANS AND POLICIES 3.5.1 Affected Environment Jefferson County Comprehensive Plan The Jefferson County Comprehensive Plan, adopted in 1998, addresses Master Planned Resorts (MPRs) in Chapter 3 - "Land Use and Rural Element." The Comprehensive Plan describes MPRs, establishes MPR Goals and Policies, and identifies an MPR Strategy and Action Items, as follows: Master Planned Resorts "Master planned resorts (MPRs) are large-scale, self-contained developments that are based on an integrated, conceptual master plan, yet are typically developed in stages depending on market demand or other factors. Recent amendments to the Growth Management Act (GMA) allow jurisdictions to recognize existing master planned resorts which may constitute urban growth outside of Urban Growth Areas as limited by RCW 36. 70A.362. Jefferson County currently contains one existing master planned resort, Port Ludlow. The master planned resort of Port Ludlow is characterized by both single-family and multi-family residential units with attendant recreational facilities including a marina, resort, and convention center, and is one of Jefferson County'sfastest growing communities. Located on Port Ludlow Bay and surrounded by an area of significant natural amenities, Port Ludlow is suited to be designated as a master planned resort. Port Ludlow is managed by Olympic Resources Management (ORM), a corporation which is responsible for the phased development of the community and resort. Although Port Ludlow is a planned development, its overall phased development pattern may change according to changing market conditions. Any change in the development plan will need to be reviewedfor consistency with the Comprehensive Plan andfor compliance with Port Ludlow's FEIS and all applicable federal, state, and local regulations. Currently, a development agreement is being prepared between ORM and the County that, if adopted, will allow for flexibility in the overall development of the Port Ludlow master planned resort within the limits of a residential cap of 2,250 residential units and a total of 65, 000 sq. ft. of retail /commercial development. The Comprehensive Plan contains policies in LNG 25.0 that help guide development at Port Ludlow. Many of Port Ludlow's goals and policies were drafted from issues identified by community residents who, through the establishment of community planning groups, articulated their desired plan for Port Ludlow's future development. The goals and policies identified by the community and included in Jefferson County's Comprehensive Planfocus on maintaining and enhancing Port Ludlow's recreational and community amenities and preserving the community's lifestyle. " Port Ludlow MPR Resort Plan Final SEIS 3-62 May 2005 ... I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I The Goals, Policies, and Strategies related to the Port Ludlow MPR and the Resort area are as follows: Goals: LNG 25.0 Policies: LNP 25.1 LNP 25.2 LNP 25.3 LNP 25.4 LNP 25.5 LNP 25.6 LNP 25.6.1 LNP 25.7 LNP 25.8 Maintain the viability of Port Ludlow as Jefferson County's only existing Master Planned Resort (MPR) authorized under RCW 36.70A.362. Ensure that development in Port Ludlow complies with County development regulations established for critical areas and that on-site and off-site infrastructure impacts are fully considered and mitigated. The provision of urban-style services to support the anticipated growth and development at Port Ludlow shall occur only within the designated MPR boundary. No new urban or suburban land uses will be established in the vicinity of the Port Ludlow Master Planned Resort. The total number of residential lots allowable within the MPR boundary shall not exceed the 1993 Port Ludlow FEIS total of2,250 residential dwelling units. Port Ludlow shall accommodate a variety of housing types, including affordable housing, single family and multi-family housing, and assisted living care facilities. Support efforts to preserve and protect Port Ludlow's greenbelts, open spaces, and wildlife corridors. Support the establishment of a Ludlow Creek Nature Preserve. No preliminary plats will be processed by Jefferson County for the 200-acre area south of the Port Ludlow Golf Course within the MPR boundary (as depicted on the official Jefferson County Land Use Map) until such time as a conceptual site plan has been approved by the County. The Port Ludlow Master Planned Resort commercial area shall be designated as the Port Ludlow Village Commercial Center. Strategies: Jefferson County's strategy is to coordinate efforts with Port Ludlow to support its development as an existing Master Planned Resort while containing "urban" type development within the boundaries of the Resort. Port Ludlow MPR Resort Plan Final SEtS 3-63 May 2005 ... Action Items: 1. Establish procedures for monitoring growth to ensure that Port Ludlow does not exceed its targeted population and housing projections. (Corresponding Goal: 25.0) 2. Encourage the Port Ludlow MPR to provide a mixture of affordable housing types including single-family, multi-family, and assisted care living facilities. (Corresponding Goal: 25.0) 3. Allow for the adoption of a Development Agreement between the Jefferson County and Olympic Resource Management for the Port Ludlow MPR pursuant to RCW 36.70B.170. (Corresponding Goal: 25.0) The glossary contained in the Jefferson Count)! Comvrehensive Plan defines Master Planned Resort (Existing) as follows: A self-contained fully integrated planned unit development, in a setting of significant natural amenities, with a primary focus on destination resort facilities consisting of short-term visitor accommodations associated with a rang.e of developed on-site indoor or outdoor recreational facilities and pursuant to the criteria set forth in RCW 36.70A 362. The Jefferson County Comprehensive Plan also includes goals and policies related to both Parks and Recreation (Chapter 6) and Shorelines (Chapter 7). Regarding Parks and Recreation, the goal is to develop and maintain facilities that are responsive to the needs and interests of Jefferson County residents and visitors. The associated policies state that existing facilities should: not be overburdened; be planned to support designated residential development; and should include adequate infrastructure. The facilities should also be consistent with the needs and desires of the citizens of the area and be compatible with the Shoreline Management Master Program. Policies related to Parks and Recreation are listed in Appendix D. Regarding Shorelines, Comprehensive Plan goals relate to preserving the long-term benefits of shoreline resources and allowing development that is compatible with the natural environment. Associated policies establish a hierarchy of preferred uses, promote public access, and allow development that is compatible with the natural processes, conditions, and functions of the shoreline. Policies related to Shorelines are listed in Appendix D. Jefferson County Shoreline Management Master Program The Shoreline Management Act (SMA) of 1971 (Revised Code of Washington, RCW, Chapter 90.58) was enacted to provide for the management of the shorelines of the state by planning for and fostering all reasonable and appropriate uses. It is the policy of the state to protect against adverse effects to public health, land and its vegetation and wildlife, and the waters of the state and its aquatic life. Permitted uses in the shorelines are to be designed and conducted in a manner to minimize, insofar as practical, any resultant damage to the ecology and environment of the shoreline and any interference with the public's use of the water. Port Ludlow MPR Resort Plan Final SEIS 3-64 May 2005 ... I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I The SMA gives responsibility to the local governments in initiating and administering the regulatory program of the Act. As a result, Jefferson County developed and adopted a Shoreline Management Master Program (SMMP) in March of 1989. The SMMP is a regulatory ordinance with performance standards for development intended to implement adopted goals and policies. The SMMP is adopted as Section 5 of the Jefferson County Unified Development Code. All shorelines subject to the SMA are given a shoreline environment designation designed to locate the most appropriate uses in particular areas and to enhance the character of that shoreline environment. Two shoreline environment designations are located within the Port Ludlow Resort complex. The south shoreline, including Burner Point, is designated "Urban." The east shoreline of the Resort complex (excluding the east side of Burner Point) is designated as "Suburban." Shoreline environment designations are shown in Figure 4417. The Urban shoreline environment is an area of high intensity land use, including residential, commercial, and industrial development. The policies and performance standards of the SMMP, Urban Environment give preference to water-dependent, water-related, and water-enjoyment uses. Shoreline policies for the Urban Environment (SMMP 4.105) follow: Policy 1. Development in urban areas should be managed so it enhances and maintains the shoreline for a variety of urban uses, with preference give to water dependent and water related uses. Water-enjoyment uses that provide access to and enhance enjoyment of the shoreline for a substantial number of persons should also be given priority in urban areas. Efficient utilization of existing urban areas in a manner consistent with this program is encouraged before further expansion into non-urban areas occurs. Policy 2. Policy 3. Pedestrian and visual access should be provided to and along the urban waterfront area. Public access to and along the water's edge should be coordinated in a walkway system and linked to adjacent existing or future walkways. Urban development should provide for public views to the water. Wherever possible, the waterside of shoreline buildings should include windows, doors, and public areas that enhance enjoyment of the shoreline and present and interesting, attractive view of the development from the water. Policy 4. Policy 5. Development in urban areas should preserve and enhance significant architecture and historic buildings. Unique natural features of the urban shoreline, such as bluffs, dunes, and wetland areas, should be preserved and protected. Parking facilities should be located on the upland side of buildings away from the shoreline. Policy 6. Policy 7. Port Ludlow MPR Resort Plan Final SEIS 3-65 May 2005 ... Policy 8. Internal and perimeter landscaping should be incorporated and maintained to screen parking facilities from the shoreline and adjacent properties. Development within the shoreline urban area should be consistent with other adopted plans, programs, or policies. Policy 9. The Suburban shoreline environment is an area where residential activity may approach urban density, but usually where densities permit space for small numbers of livestock, gardens, or wood lots. Shoreline uses are classified as "primary," "secondary," or "conditional," in order of preference or appropriateness on a particular shoreline. Within the "Urban" shoreline, water-related and/or dependent commercial uses, marinas, recreational facilities, residential development, transportation facilities, and utilities are "Primary" uses (SMMP 4.40). Residential development and day-use recreational facilities are deemed as preferable within the Suburban designation and are classified as "primary" (SMMP 4.40). Policies and specific Performance Standards for commercial development, marinas, recreational facilities, residential development, transportation facilities, and utilities are provided in Chapter 5 of the SMMP. Consistency with the specific performance standards is determined through the Shoreline Substantial Development Permit process. A Shoreline Conditional Use Permit was approved by Jefferson County on May 11, 1993 (Permit No. SDP91-017), and by the State Department of Ecology on June 14, 1993 (Permit No. 1993-14647), to allow construction of the plat of Ludlow Bay Village. Specifically, this permit approved residential, commercial, and recreational development consisting of: . A 36-room hotel (HeronBeach Inn, now known as the Inn at Port Ludlow, with 37 rooms) . Five detached single-family residences . 53 attached multi-family residences in 14 multi-unit structures . Roadways and 367 parking spaces . Utilities, including water, electrical power, and sanitary sewer . 500 cubic yards of riprap shore defense works . Marina modifications . Landscaping and recreational amenities . Approximately 45,000 cubic yards of excavation, grading and filling including 25,000 cubic yards for pond expansion . Directional and informational signs . Outdoor lighting . 10.5 acres of undeveloped open space The infrastructure (roads and utilities) for the plat, the Heron Beach Inn (now known as the Inn at Port Ludlow), 13 townhomes, one single-family dwelling, the pond expansion, and the shoreline work were completed by 1998. Twelve additional townhomes were constructed after Port Ludlow MPR Resort Plan Final SEIS May 2005 ~ 3-66 I I I I I I I I I I I I I I I I I I I Port Ludlow Master Plan Resort Boundary ..-- I I I -...- Suburban I I I I I Legend _ Urban ~ Natural _I I --- Conservancy r- I I ---. I r I I I I 1 I / L_ 1, ,...- - - Teal Lake \f 'J Shoreline Environment Designations ~ 1998 (Townhome Buildings 400, 700 and 800). Some commentors on the Draft SEIS expressed concern regarding the status of this 1993 permit, an issue which is beyond the scope of this Final SEIS. The 1993 Shoreline Permit was approved with 51 conditions. Jefferson County approved the final plat of Ludlow Bay Village in 1994 based on a finding of compliance with these conditions. That decision was not appealed. Questions have been raised by commentors on the Draft SEIS about whether all of the 1993 conditions for plat aplJroval were fully met. That question is not related directly to the current application and is beyond the scope Qf this environmental review process. Regardless of the issues associated with the 1993 Shoreline Permit, a new Shoreline Substantial Development Permit is required for any further development within Ludlow Bay Village, unless the development is identified as categorically exempt by the Jefferson County Shoreline Master Prof!ram. The new Shoreline permit is required for any development scenario - development consistent with the 1994 plat, development consistent with the existing MPR regulations, or development proposed under the proposed revision to the Resort Plan. The new Shoreline permit may set forth conditions for the proposed new development. 3.5.2 Environmental Impacts Alternative 1: Applicant's Proposed p.,eferred Project - 2003 Proposed Resort Plan Jefferson County Comprehensive Plan Alternative 1 is consistent with Goal LNG 25.0 of the Jefferson County Comprehensive Plan, relating to maintaining the viability of the Port Ludlow MPR. Changed market conditions have resulted in a need to shift the focus of the resort complex from that of a conference facility serving large groups, to a destination resort for the traveling public. The business model for the Resort envisioned in the 1999 Development Agreement is no longer viable. Build-out of the Resort with a new waterfront restaurant, additional indoor recreational facilities for Resort guests, additional lodging opportunities (permanent and/or seasonal), improved parking and circulation in the waterfront area, and expansion of the marina with upgraded support facilities will maintain the Resort function and will be economically sustainable. With regard to consistency with Policies and Strategies related to Comprehensive Plan Goal 25.0: . Policy LNG 25.1 - Compliance with critical area regulations related to fish and wildlife habitat was addressed in the 2002 Port Ludlow Marina Expansion SEIS; the proposed expansion was found to be consistent with County regulations. The Marina expansion has also been reviewed by applicable federal agencies (U.S. Army Corps of Engineers, NOAA Fisheries, U.S. Fish and Wildlife Service) and the State Department ofFish and Wildlife and found to be consistent with federal and state regulations related to threatened and endangered fish species and marine habitat. The impacts of upland and infrastructure improvements are addressed in Sections 3.1 - 3.3, and 3.7 of this Draft SEIS. Port Ludlow MPR Resort Plan Final SEIS 3-68 May 2005 ... I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I . Policy LNG 25.2 - No urban services will be established outside the MPR as a result of this project. . Policy LNG 25.3 - No new urban or suburban land uses will be established outside the MPR as a result of this project. . Policy LNG 25. 4 - The total number of residential units allowed in the MPR (i.e., 2,250) will not be exceeded. . Policy LNG 25.5 - The new residential units will provide increased variety of residential unit types (1,200 - 1,500-square-foot townhomes and flats) within the Resort complex. . Policy LNG 25.6 - The project will not impact efforts to preserve and protect area greenbelts, opens spaces, or wildlife corridors. . Policy LNG 25.7 - N/A . Policy LNG 25.8 - N/A Alternative 1 would be consistent with the County definition of an MPR. The revised Resort Plan does not change the fact that Port Ludlow is a self contained, fully integrated planned unit development in a setting of significant natural amenities. The revised Resort Plan will, however, change the focus of the Resort development from that of a conference facility serving large groups, to a destination resort for the traveling public. The Resort will include meeting space, a new waterfront restaurant, and the Inn at Port Ludlow. At build-out, recreational facilities will include the 27-hole golf course (with new clubhouse), an expanded marina, kayaking, walking and bicycle trails, and multiple indoor recreational facilities including spa services and a swimming pool. The proposed project is also consistent with the Parks and Recreation Goals and Policies of the Jefferson County Comprehensive Plan, Open Space Element that encourage development and maintenance of park and recreational facilities that are responsive to the needs and interests of Jefferson County residents and visitors. The expansion will relieve existing and potential overburdening of existing recreational areas and facilities. The proposed recreational facilities will support areas designated for future residential development and adequate infrastructure will be available. The location, type, and amount of park and recreational facilities is consistent with the needs and desires of the citizens in the area and will accommodate a diversity of user groups. Consistency of the marina expansion with the Jefferson County Comprehensive Plan was also addressed in the Port Ludlow Marina Expansion SEIS. Shoreline Management Master Program (SMMP) Regarding Shoreline goals and policies, consistency with the policies and performance standards contained in the Shoreline Management Master Program (SMMP) would result in consistency with the Shoreline goals and policies. Port Ludlow MPR Resort Plan Final SEIS 3-69 May 2005 ... Port Ludlow MPR Resort Plan Final SEIS 3.70 May 2005 --- I I I I I I I I I I I I I I I I I I I With Alternative 1, proposed new development will be located within the Urban shoreline environment. It is anticipated one shoreline permit will be requested for all regulated development within shoreline jurisdiction (marina and upland), although the actual construction of projects may occur in phases. Consistency with the Urban Policies follows: . Policy 1 - The proposed project adds new uses to the waterfront and expands the existing marina. The relocated restaurant, recreation building, and promenade are considered water-enjoyment uses; the marina and its support services are a water- dependent use. The proposed boardwalk and marina expansion will increase public access to the water. . Policy 2 - The proposed project provides for utilization of property within the Urban designation and does not propose expansion into non-urban areas. . Policy 3 - The proposed project includes a new pedestrian shoreline boardwalk and improved signage for pedestrian access along the shoreline. Visual access to the shoreline will be maintained. The expanded marina will be visible from adjacent residential uses and Oak Bay Road. . Policy 4 - Public views to the water will be maintained from the waterside of shoreline buildings, from outdoor spaces, and from Oak Bay Road. Conceptual elevations of the waterfront buildings are shown in Figure 12B. . Policy 5 - No significant historic buildings currently exist within the Resort complex. . Policy 6 - The existing shoreline will not be disturbed. . Policy 7 - The existing parking facilities to be reconfigured will be located on the upland side of buildings, away form the shoreline. . Policy 8 - The parking areas will include internal and perimeter landscaping. . Policy 9 - The proposed development must be consistent with other adopted plans, programs, and policies. Consistency of the marina expansion with the SMMP was also addressed in the Port Ludlow Marina Expansion SEIS. Consistency of a proposed proiect with the specific Performance Standards contained in Section 5 of the SMMP is typically addressed as part of the staff report. In this case, Alternative 1 includes construction of residential units extending over the artificial lagoon; there is a question of whether this "over-water construction" is allowed by the Jefferson Countv SMMP. The Washington State Department of Ecology states that they believe such construction is prohibited by Section 5.160 of the County SMMP. The proiect applicant disputes this interpretation. Jefferson County will make its determination at the time the staff report is prepared. Alternative 2: 1993 Resort Plan Alternative 2 is similar to Alternative 1 in its consistency with goals and policies contained in both the Jefferson County Comprehensive Plan and SMMP. With Alternative 2, however, the I I I I I I I I I I I I I I I I I I I upland shoreline would contain primarily residential development, rather than a mix of commercial and residential uses. Public views to the water would be maintained. Alternative 2 would also be consistent with the County definition of an MPR. Similar to Alternative 1, a revised Resort Plan does not chan?:e the fact that Port Ludlow is a self contained, fully integrated planned unit development in a setting of significant natural amenities. The Alternative 2 Resort Plan would also change the focus of the Resort development from that of a conference facility serving large groups, to a destination resort for the traveling public. The Resort would include meeting space, the existing restaurant, and the Inn at Port Ludlow. At build-out, recreational facilities would include the 27-hole golf course (with new clubhouse), an expanded marina, kayaking, walking and bicycle trails, but no new indoor recreational facility. Alternative 2 also includes construction of residential units extending over the edge of the artificial la~oon. Alternative 3: 1999 Resort Plan (No Action) Development of the Resort as described in the 1999 Development Regulations 3 is consistent with the policies contained in the Jefferson County Comprehensive Plan, but does not appear to be consistent with the overall goal of maintaining the viability of the MPR. Since the time Alternative 3 was developed in response to the County Comprehensive Plan, the Resort owner has found that market conditions have changed and there is therefore, a need to change the focus of the Resort. Alternative 3 would also be consistent with the SMMP, and would provide for a more intense use of that portion of the shoreline within the Urban environment. Alternative 3 also proposes development within the band of steep slopes along the east side of Oak Bay Road. Continued development of townhomes within Ludlow Bay Village, but with no revision to the Resort Plan, would result in development which is generally consistent with the Comprehensive Plan and Shoreline ManaRement Master Program Policies. It is unclear how this scenario would e~ffect the economic viability of the Resort. This scenario could also result in single-family residential development along the western portion of the shoreline, a designated "Urban" environment. Alternative 3 would also be consistent with the County definition of an MPR. Alternative 3 does not include construction of residential units extending over the artificial lagoon. This alternative does, however, assume filling of the east half of the lagoon and extension of a new restaurant over the north edge of the remaining lagoon. Alternative 4: Response to Comments Alternative 4 is similar to Alternative 1 in its consistency with goals and policies contained in both the Jefferson Countv Comorehensive Plan and SMMP. and consistency with the definition of an MPR. With Alternative 4, however, no residential units would extend over the edge of the artificial lagoon. Port Ludlow MPR Resort Plan Final SEIS 3-71 May 2005 ... Alternative 5: No Action Alternative 5. the No Action Alternative means no further development within the Resort area would occur. This alternative would be inconsistent with the goals and policies contained in the Jefferson County Comvrehensive Plan which address maintaining the viability of the Port Ludlow MPR. No further development within the Resort area would be inconsistent with Policy 2 of the Shoreline Manaf!ement Master Prof!ram, which encourages efficient utilization of existing urban areas before expansion into non-urban areas occurs. 3.5.3 Mitigating Measures The permitting process for the expansion will require consistency with the Port Ludlow MPR Ordinance and the Comprehensive Plan and Shoreline Management Master Program goals and policies as well as any other applicable ordinances, such as the Critical Areas Ordinance. Specific development conditions may be attached to the Resort Plan Revision, any Plat Alteration, and the Shoreline Permit by the County staff recommendation and/or by the Hearing Examiner. These conditions may provide for necessary monitoring and adaptive management strategies. 3.5.4 Unavoidable Adverse Impacts No significant unavoidable adverse impacts are anticipated. Port Ludlow MPR Resort Plan Final SEIS May 2005 ~ 3.72 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 3.6 TRANSPORTATION The traffic analysis developed for this Draft SEIS (prepared by Geralyn Reinart, PE) includes a review of the existing conditions in the project vicinity and analyzes the potential traffic-related impacts associated with the Preferred Action (Alternative 1), the 1993 Resort Plan (Alternative 2), and the current Resort Plan (Alternative 3 - 1999 Resort Plan/No Action). The type and magnitude of the land use associated with the alternatives is described in more detail under the "Project Description" found in Section 2.2 of this Draft SEIS. It should be noted that it is unlikely that all the facilities proposed under the current Resort Plan (i.e., Alternative 3) could still be built, given the development that has occurred since the 1999 Plan was adopted. For purposes of this traffic study, however, and to provide a comparison between the alternatives, this Alternative is analyzed as described in the current MPR regulations. The major elements included in this traffic analysis are a description of the existing roadway and traffic conditions, traffic accident history, the trip generation/distribution, level of service (LOS) analysis at critical intersections, and a summary of impacts and expected mitigation. Also included in the analyses are the cumulative impacts associated with external traffic growth and current and future housing construction within Port Ludlow. Trip generation utilized for the alternatives is based on values from the ITE Trip Generation Manual (published by the Institute of Transportation Engineers). Values from the Trip Generation Manual are used for all land uses with the exception of the residential development. Past traffic impact analyses in Port Ludlow have used adjusted trip generation values for residential development to account for smaller household sizes. Adjustments to the trip rates were utilized in the preparation of the 1993 Port Ludlow Development Program Final Environmental Impact Statement (FEIS) and were described in detail in that document. The above-mentioned yearly traffic-monitoring program provided for Jefferson County also captures count data for use in calculating the trip generation rates for the residential units within Port Ludlow. This trip generation data has been based on the number of occupied units at the time of the counts by using utility records to determine occupancy. (The use of just occupied units in the calculation of trip rates tends to result in a conservative or higher trip rate value than may actually exist based strictly on a per lot basis.) Data collected from the 2002 program is used in the analyses that follow. Future traffic volumes are estimated for the year 2010, which is the expected year for complete build-out and occupancy of the Resort. The existing traffic volumes are adjusted upwards based on a combination of data provided by Jefferson County from their Comprehensive Plan and the traffic generated by the approximately 350 residential units that remain to be constructed under the Port Ludlow Master Plan. Further discussion and details regarding these estimates can be found in Appendix F. Port Ludlow MPR Resort Plan Final SEIS 3-73 May 2005 ... 3.6.1 Affected Environment Existing Roadway and Traffic Conditions Area roadways that would serve the Port Ludlow Resort include SR 104, SR 19 (Beaver Valley Road), Paradise Bay Road, and Oak Bay Road. Roadways in the project area are shown in Figure ~18. The following briefly describes these roadways. SR 104 is a predominantly east-west highway that provides access to the Edmonds-Kingston ferry to the east and connects to SR 101 to the west. In the project vicinity the roadway is typically two lanes wide with six- to ten-foot paved shoulders and some extruded curb. Turn storage lanes have been provided at the Paradise Bay Road and Beaver Valley Road intersections, and a hill-climbing lane extends west from Paradise Bay Road for several hundred feet. The posted speed is 60 mph. SR 104 is characterized by gentle horizontal and vertical curves and the adjacent land use is typically undeveloped/rural property. Existing intersections from SR 104 that provide access to Port Ludlow include Paradise Bay Road, Teal Lake Road, and Beaver Valley Road. All of these intersections are controlled by stop signs on the side street. SR 19 (Beaver Valley Road) is a state highway that extends north from SR 104 to Port Townsend. Beaver Valley Road is approximately 24 feet wide with 4- to 7-foot paved shoulders and some extruded curb. The roadway is in good condition and is characterized by gentle horizontal and vertical curvature. A Park & Ride lot and visitor information center are located just north of where Beaver Valley Road intersects SR 104. The posted speed is 50 mph. Paradise Bay Road is a minor collector that provides a connection between SR 104 just west of the Hood Canal Bridge and Oak Bay Road within the Port Ludlow community. The roadway is two lanes wide and is characterized by fairly gentle horizontal and vertical curvature. The posted speed varies from 30 mph to 50 mph, with a 40-mph speed posted within the Port Ludlow community. The roadway is 22 feet wide with shoulders varying from about 1 foot up to 10 feet. (The wider shoulder width is typically located at the intersections serving newer developments.) The roadway is fronted by undeveloped parcels, residential lots, and some commercial development near its intersection with Oak Bay Road. Oak Bay Road is a major collector that provides access from Beaver Valley Road to the Oak Bay/Fort Flagler area to the north, traveling through the Port Ludlow community. The roadway is approximately 20-22 feet wide with shoulders up to 3 feet wide in certain areas and open ditches. The posted speed is 40 mph. An all-way stop controls the intersection of Oak Bay Road/Paradise Bay Road. The Resort complex itself, including the marina, is accessed directly from Oak Bay Road. Approximately 1,400 linear feet of existing private roads provide internal circulation within the Resort. On-going Monitoring Program. Port Ludlow Associates is required by Jefferson County to provide a yearly traffic-monitoring program for Port Ludlow. The purpose of the monitoring program is to provide a cumulative summary of traffic volumes in the area and an assessment of Port Ludlow MPR Resort Plan Final SEIS 3-74 May 2005 ... I I I I I I I I I I I I I I I I I I I Existing Volumes - Figure 18 Port Ludlow Resort Plan FSEIS I I XXXX - August 2003 weekend average daily volume I (XXXX) - 2003 Jefferson County average daily volume - 2002 WSDOT average daily volume N.A. - not available I I I I I I I I 1106 (1425) (3734) "'0 a: Q) ~ ;> 7037 [~ Existing Daily Traffic Volumes current operating conditions at critical intersections in the general area. The Washington State Department of Transportation (WSDOT) has also expressed concern regarding traffic impacts in July and August, particularly on weekends. The Port Ludlow monitoring program has thus focused on weekend counts by taking machine counts on a Saturday, Sunday, and Monday in August. The year 2002 is the ninth year that data has been collected for this program. Data from this program has been used in this traffic analysis. Copies of the annual traffic-monitoring program are on file with Jefferson County. Transit Service Transit service in Jefferson County is provided by Jefferson Transit. Port Ludlow is served by the Port Ludlow/Poulsbo/Tri-Area route, which provides service between Port Townsend and Poulsbo via the Tri-Area and Port Ludlow. Service is provided daily, although service is reduced on the weekend. Weekday service begins at approximately 6:00 AM and continues until approximately 7:30 PM, at approximately one and a half to four hour headways. Weekend service is limited to one AM and one PM run in each direction. The Port Ludlow Village Store is listed as a scheduled timepoint along the route. Non-Motorized Facilities Some paved pathways have been constructed within the Port Ludlow MPR development; these pathways meander through the residential areas. Sidewalks have been constructed within the most recent subdivisions. A comprehensive community-wide pedestrian trail plan has been approved by Jefferson County and is being constructed in phases. The trail system is intended to serve recreational uses, as well as a network between activity nodes such as the recreation center, marina, and commercial complex. Trails exist within the Resort complex, but are currently unsigned. Accident Analysis Traffic accident data was provided by Jefferson County for Oak Bay Road and Paradise Bay Road. The following table summarizes the accident frequency along the roadway sections and at the major intersections for the years 2000, 2001, and 2002. Port Ludlow MPR Resort Plan Final SEIS 3-76 May 2005 --- I I I I I I I I I I I I I I I I I I I I I Table 3 Accident Historv I Accident Type Property LocationNear Damaae Injury Fatality Total I Oak Bay Road: at Swansonville Road (MP 8.40) 2000 0 0 0 0 I 2001 0 0 0 0 2002 0 0 0 0 between Swansonville Road and Paradise Bay Road (MP 8.40-9.47) I 2000 0 0 0 0 2001 1 0 0 1 2002 1 0 0 1 I at Paradise Bav Road (MP 9.47) 2000 0 0 0 0 2001 1 0 0 1 I 2002 0 0 0 0 between Paradise Bay Road and Beaver Valley Road (MP 9.47-10.80) 2000 0 1 0 1 I 2001 0 0 0 0 2002 0 0 0 0 Paradise Bay Road: I between Oak Bay Road and Spinnaker Place (MP 0.00-0.45) 2000 0 0 0 0 2001 1 0 0 1 I 2002 0 0 0 0 between Spinnaker Place and Ludlow Bay Road (MP 0.45-1.24) I 2000 0 1 1 2 2001 0 1 0 1 2002 2 0 0 2 I at Ludlow Bay Road (MP 1.24) 2000 0 1 0 1 2001 0 0 0 0 2002 0 0 0 0 I at Teal Lake Road (MP 1.52) 2000 0 0 0 0 2001 0 0 0 0 I 2002 0 0 0 0 I Injuries were involved in 4 of the 11 collisions (36.41 percent) along roadways in the area, and one fatality (9.1 percent) was reported. The fatality involved a driver having a heart attack whose vehicle left the roadway and rolled over. The majority of the accidents (63.6 percent) involved I vehicles either losing control and rolling over or leaving the roadway in a curve section. The remaining collisions included right angle collision, a rear-end collision, and a head-on collision. Overall, the frequency of accidents in the area is low. I Port Ludlow MPR Resort Plan May 2005 I Final SEIS 3-77 ~ Traffic Volumes Traffic count data has been collected in the Port Ludlow area since 1994 as part of the yearly traffic monitoring program that was required as a condition of approval for several prior plat approvals. The rnonitoring program collects both weekday and weekend data during the month of August, along with weekday PM peak hour turning movement counts. Counts are conducted during the month of August in order to capture the higher volume tourist traffic that is typically present during the summer months. This data was again collected in 2003. The Washington State Department of Transportation (WSDOT) also conducts traffic counts along the state highways, and Jefferson County counts the County roadways. Summaries of the various daily traffic volumes are shown on Figure H18. In general, the volumes along the state highways were typically higher on the weekend than the average daily volumes, whereas the reverse was true along the County arterials. The weekday PM peak hour is the highest 60-minute period between the hours of 4:00 and 6:00 PM and typically occurs during the peak afternoon commute. Peak hour counts completed in 2003 available for this study include the intersections of Paradise Bay Road/SR 104, SR 104/Beaver Valley Road, Oak Bay Road/Beaver Valley Road, Paradise Bay Road/Oak Bay Road, Teal Lake Road/Paradise Bay Road, and Oak Bay Road/Walker Way. A summary of these counts can be found on Figure M19. Figure +7-20 shows the estimated weekend peak hour volumes for these same intersections. These I volumes are based on the approach volumes from the mechanical counters. The weekend peak hour for all of the intersections within Port Ludlow (Le., Oak Bay Road/Paradise Bay Road, Oak Bay Road/Walker Way, and Paradise Bay Road/Teal Lake Road) occurred on Saturday during the late morning/early afternoon, whereas the intersections along SR 104 or SR 19 peaked on Sunday afternoon. At all locations, the weekend peak hour total approach volumes were higher than the weekday peak hour volumes. Level of Service Existing levels of service were calculated for intersections that would be affected by future development and per discussions with Jefferson County Staff. LOS analyses were conducted using the traffic count data described above. Calculations for the intersection LOS analyses completed for this assessment were conducted using the McTrans Highway Capacity Software release 4.1c based on the 2000 Highway Capacity Manual. "Level of service" is a common term used in the Traffic Engineering profession that is defined as a qualitative measure describing operational conditions within a traffic stream and its perception by motorists and/or passengers. These conditions are usually described in terms of such factors as speed and travel time, freedom to maneuver, traffic interruptions, comfort and convenience, and safety. Six levels of service are designated, ranging from "A" to "F", with LOS "A" representing the best operating conditions and LOS "F" the worst. Jefferson County considers LOS "c" or better acceptable in areas outside the urban line and LOS "D" or better acceptable in areas within the urban lines and along urban/tourist corridors. Port Ludlow MPR Resort Plan Final SEIS 3-78 May 2005 ... I I I I I I I I I I I I I I I I I I I I I I I I I I 2003 Volumes - Figure 19 Port Ludlow Resort Plan FSEIS 53 9J'-....,..16 ! .. 28 ~ \0 \~ '.<9- \.?Z. '\1b- ". , 2003 PM Peak Hour Volumes (Weekdays) 83 11 +69 4 3 106 1127+1122 C~ 485+606 \ 1 1 15 " ,+. / ~ 144 5 Jl"-.. 8 Y 131 338 34+304 22 0 295 (551~529 C~ 521~816) \, 7 I \ 0 0 0 J + l .~ 2F-12,\ 255 28 \ I" ~ 1181' r )64 . 315 36 " ~36 ~ ~ ~l ~ '/ 2003 Estimated Weekend Peak Hour Traffic Volumes I I I I Six intersections were analyzed for this assessment and include the following: I . SR 104/Paradise Bay Road . SR 104/SR 19 (Beaver Valley Road) . SR 19/0ak Bay Road I . Oak Bay Road/Paradise Bay Road . Paradise Bay Road/Teal Lake Road I . Oak Bay Road/W alker Way All of these intersections operate under minor street stop sign control with the exception of Oak I Bay Road/Paradise Bay, which is controlled by stop signs in all directions. The following tables summarize the current levels of service for the weekday and weekend conditions. I Table 4 Existing Weekday levels Of Service NORTHBOUND SOUTHBOUND EASTBOUND WESTBOUND OVERALL I SR 104/ Lose LOSF LOS A LOS A Paradise Bay Road 18.8 sec. > 100 sec. 10.0 sec. 8.8 sec. N.A. SR 104/ LOSB LOSD LOS A LOS A I Beaver Valley Road 14.0 sec. 27.2 sec. 9.2 sec. 8.0 sec. N.A. Beaver Valley LOS A LOSB Road/Oak Bay Road N.A. 8.1 sec. N.A. 12.6 sec. N.A. Oak Bay RoadlParadise LOS A LOS A LOS A LOS A LOS A I Bay Road 8.6 sec. 8.7 sec. 8.5 sec. 9.7 sec. 9.0 sec. Paradise Bay RoadlTeal LOSB LOS A LOS A LOS A Lake Road 11.7 sec. 9.9 sec. 7.6 sec. 7.6 sec. N.A. I Oak Bay Road/Walker LOS A LOS A LOSB LOSB Way 7.6 sec. 7.6 sec. 11.1 sec. 11.2 sec. N.A. N.A. - not applicable/available (i.e., calculation not provided for specific analysis or movement) I Table 5 I Existing Weekend levels Of Service NORTHBOUND SOUTHBOUND EASTBOUND WESTBOUND OVERALL SR 104/ LOSD LOSF LOS A LOSB Paradise Bay Road 29.8 sec. >100 sec. 8.9 sec. 11.4 sec. N.A. I SR 104/ N.A. LOSF LOS A LOS A Beaver Valley Road >100 sec. 10.0 sec. 8.6 sec. N.A. Beaver Valley LOS A LOSB I Road/Oak Bay Road N.A. 8.2 sec. N.A. 14.3 sec. N.A. Oak Bay RoadlParadise LOS A LOS A LOS A LOSB LOS A Bay Road 8.8 sec. 9.0 sec. 8.9 sec. 10.1 sec. 9.3 sec. I Paradise Bay RoadlTeal LOSB LOSB LOS A LOS A Lake Road 12.0 sec. 10.1 sec. 7.5 sec. 7.6 sec. N.A. Oak Bay Road/Walker LOS A LOS A LOSB LOSB Way 7.5 sec. 7.7 sec. 11.3 sec. 11.5 sec. N.A. I N.A. - not applicable/available (i.e., calculation not provided for specific analysis/movement, or no volume on subject movement) I Port Ludlow MPR Resort Plan May 2005 I Final SEIS 3-81 --- I Where: I LOS Delay A < 10 seconds I B > 10 & < 15 seconds C > 15 & < 25 seconds D > 25 & < 35 seconds I E > 35 & < 50 seconds F > 50 seconds (for unsignalized intersections) I Tables 4 and 5 show that the intersections along SR 104 are operating at a lower LOS than the I intersections located on the County arterial system. The lower LOS for the minor road movements is a result of the high volumes on SR 104 that make it difficult for vehicles to enter from the minor roadway. A comparison of the results of the analyses from the prior monitoring I programs shows minor changes in the amount of delay at the intersections of Teal Lake Road/Paradise Bay Road, Oak Bay Road/Beaver Valley Road, and Paradise Bay Road/Oak Bay Road since 1992. I In general, both of the intersections along SR 104 have shown increased intersection delay over the past decade due to increased demand for the southbound left-turn movements and higher I through volumes on SR 104. The LOS for the southbound movement at the intersection of SR 104/Paradise Bay Road was at LOS "F" in 2003. This movement has ranged from "c" to "F' since 1992. I The comparison of the 2003 weekend data with the weekday data was similar to most of the prior years when both the intersection of Paradise Bay Road/SR 104 and Beaver Valley Road/SR 104 I operated at a worse condition on the weekend than the weekday. Internal Circulation within the Resort I Ludlow Bav Villa2e. Primary vehicular access to LBV from Oak Bay Road is provided via Marina View Drive and Harbor Drive. Within LBV, Heron Road provides access to the I townhomes, Harbor Master Restaurant, and the eastern side of the Inn, while Gull Drive provides access to the shoreline, marina, and western entrance to the Inn. Because Heron Road and Gull Drive connect at the Inn parking lot, the system can (and does) function as a loop. I All streets within LBV are privately owned and maintained, and provide local access to the adlacent parking lots, marina, inn, and townhomes. Heron Road is 24 feet in width (two 1O-foot I paved driving lanes with 2-foot concrete shoulders). The roadway is generally flat and straight along the section between the Inn and the townhomes, with some gentle horizontal and vertical curvature in the vicinity of the existing Harbor Master Restaurant. The garages of the I townhomes along this section of Heron Road are setback 32 to 36 or more inches from the edge of the concrete shoulders. Heron Road currently serves the existing townhome traffic, Harbor Master Restaurant, some of the Inn traffic (the Inn can also be accessed from Gull Drive), and I miscellaneous service vehicles. The cross section of the roadway most closely resembles the Jefferson County tyPical road section for an 18-foot roadway (35 mph - under 400 ADT, 2-foot I Port Ludlow MPR Resort Plan May 2005 Final SEIS 3-82 ... I I I I I I I I I I I I I I I I I I I I paved shoulders) standard for public roads, with the exception that the design speed used for Heron Road was 20 mph.(the lower design speed was deemed appropriate since Heron Road is a local access road and low speeds were desirable through this area). The width of Heron Drive was approved through the Jefferson County variance process. The roadway was designed for a 20-mph speed, and stopping sight distances along the roadway meet this standard along all sections, and exceed the design speed along many sections. Vehicles can currently travel along Heron Road, through the Inn parking lot and back onto Heron Road to "loop" through this area. No speed limit is currently posted along the roadway, nor is parking allowed along the roadway, although some graveled areas are available out of the roadway cross section that can be used for parking, and paved guest parking stalls are provided for townhome guests. Gull Drive is 24 feet in width on the west side of the artificial lagoon, and 22 feet in width along the shoreline (south side of the lagoon). Gull Drive provides access to the Inn, the Marina, and parking areas, and connects to Heron Drive at the Inn. Admiraltv. Olympic Place is a privately owned roadway that serving Admiralty and intersecting Walker Way within the Port Ludlow resort area, and running roughly parallel to Oak Bay Road. Olympic Place is an internal, fully paved roadway approximately 19-feet wide, with no shoulders. The roadway is flat and straight, with no residences fronting it. Pedestrian circulation within LBV is accommodated by the interior roadways and trails, and the footbridge across the artificial lagoon which connects Heron Road and the Harbor Master Restaurant to Gull Drive and the shoreline. A gravel trail is provided along the front (waterside) of the townhomes. Resort Parking Off-street parking is currently provided throughout the Resort area. Within the Admiralty area, the conference center provides parking for 54 vehicles. Parking for the Admiralty I and IT condominium units and the Beach Club is provided. Within Ludlow Bay Village, 36 stalls are currently available at the Heron Beach Inn; additional stalls are located in the upper and lower parking lots north of the marina. On-site parking for the residential townhomes is provided at a rate of one to two stalls per unit, plus guest parking stalls. Much of the available existing parking is located north of Heron Road and tends not to be used except during peak season. Parking along the side of roads adjacent to the marina also occurs during the peak season. Further details regarding Resort parking is provided in Section 3.4 of this Final SEIS. Port Ludlow MPR Resort Plan Final SEIS 3-83 May 2005 ~ 3.6.2 Environmental Impacts Short- Term, Construction Impacts (all development Alternatives) Development under all Alternatives 1, 2, 3, and 4 will generate the customary temporary construction traffic. Typically, the majority of these activities occur during the daylight hours on the weekdays, thus limiting the impact on the adjacent roadways. Large vehicles used in grading or deliveries will travel to and from the site until the facilities are complete. Some of the larger equipment will be brought in once and remain on site until it is no longer needed. For all Alternatives, assuming a total work force of 40 to 50 during the various phases of construction, plus a total of 30 deliveries on any given day, a total of 220 to 260 construction trips per day may occur. This amount is less than the traffic that would be generated by the development upon completion. Long- Term Impacts For all Alternatives, several project elements are included in the Resort Plan. These elements include both existing uses such as the Heron Beach Inn, the Harbor Master Restaurant, the marina, and the existing residential units, as well as new (proposed) uses. Those uses that currently generate traffic are included in the existing traffic volumes. Those uses that will generate new traffic are included in the analysis of future traffic volumes. Alternative 1: Applicant's Proposed Project P-r-eferred Action - 2003 Proposed Resort Plan The following sections summarize the traffic-related impacts associated with build-out of the remainder of the Port Ludlow Resort under the Proposed Action (Alternative 1). One of these uses, the Harbor Master Restaurant, will be relocated from its current site to a site closer to the water and the seating capacity will be decreased by 25 percent, which is likely to result in less traffic. To provide a conservative analysis, however, no deduction of current traffic has been made to coincide with this seating reduction. Those development actions that will generate new traffic and are included in the projection of future traffic volumes include: an additional 101 residential units, the 100 additional slips at the marina, the 2,900-square-foot maintenance building, and the PLA offices that will be relocated to the existing conference center building. All other uses described under the Proposed Action are either existing uses or support facilities that are not traffic generators by themselves. (Note: many of the trips associated with the relocation of the PLA offices to the resort currently exist on the roadways. However, for purposes of the following analyses, these trips will be assumed new to the adjacent intersections of Oak Bay RoadlWalker Way and Oak Bay Road/Paradise. Beyond these intersections, the employee trips would be included in the existing traffic volumes.) In addition, the analyses completed for the Proposed Action reviews peak weekend conditions. The peak intersection volumes in the area occur on the weekend rather than on a weekday as is typical in most urban areas where commuter traffic produces higher volumes. Trip generation rates for a Saturday are used, since this is the day when the higher volumes within Port Ludlow are present. The peak hour for both the various land uses and the adjacent intersections are assumed to occur simultaneously in order to review the worst-case condition. Port Ludlow MPR Resort Plan Final SEIS May 2005 ... 3-84 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Direct Impacts Trip Generation Alternative 1 will generate additional traffic onto the adjacent transportation system. The trip generation for the proposed action was estimated using the most recent values in the ITE Trip Generation Manual (6th Edition, 1997) and trip generation data collected as part of the traffic-monitoring program in Port Ludlow. The average trip rates have been used for the trip generation unless noted otherwise. As noted earlier, only those uses that will generate new traffic are included in the trip generation. Land Use Codes 150 (Warehouse), 420 (Marina), and 710 (General Office Building) from the ITE Trip Generation Manual for the maintenance building, additional slips, and PLA offices respectively were used in the trip generation estimates. The trip rates for the residential units are based on data collected in the 2002 monitoring program. Table 6 summarizes the weekend trip generation associated with the proposed action. Table 6 Estimated Weekend Trip Generation Alternative 1 (Proposed Action) Port Ludlow Resort PROPOSED ACTION Maintenance Townhomes Marina PLA Offices (30 Building (101 units) (100 slips) emp.) (2,900 SF) Daily Trip Rate 5.40 trips/unit 3.22 trips/slip 0.54 trips/ 1.22 trips/ employee 1,000 SF Daily Trips 545 322 16 4 Peak Hour Rate 0.66 trips/unit 0.27 trips/slip 0.09 trips/ 0.12 trips/ employee 1,000 SF Peak Trips Entering 36 12 2 0 Peak Trips Exiting 31 15 1 0 Total Peak Trips 67 27 3 0 Total Trips 887 50 47 97 Table 6 shows that the townhomes will generate the majority ofthe new weekend trips. Trip Distribution The distribution of traffic is based on current travel patterns, a review of the existing roadway system and activity centers, and the proposed land uses. Figure -1-8-lishows the estimated weekend daily and peak hour trip distribution/assignment for the proposed action. Many of the trips associated with the Proposed Action will be destined to and from other activities/areas within Port Ludlow, i.e., the commercial area, the community center, golf course, other housing areas, and could include social trips within the community. Reasons for traveling beyond the Port Ludlow community include major shopping, medicallhealth care, or social/recreational opportunities. Some of the trips would require traveling on SR 104 to reach the ultimate destination, with many trips using Oak Bay Road or Beaver Valley Road to access the Tri-Area or Port Townsend areas. Many of the trips are expected to stay within the Port Ludlow Pori Ludlow MPR Resort Plan Final SEIS 3-85 May 2005 ... Altl Distributions - Figure 21 Port Ludlow Resort Plan FSEIS XXX% - Percent Distribution (XXX) - Peak hour volume [)<)<,~ - Daily volume (10) , /" ( Ii , \ 'i \ , , 15%,\\ (7) Estimated Weekend Trip Distribution/Assignment (Proposed Action - Alternative 1) I I community. The proposed action would have its greatest traffic-related impact on Oak Bay Road, which provides direct access to the Resort. I Future Volumes Figure -l9--22 shows the estimated 2010 weekend daily and peak hour traffic volumes for the I I Proposed Action. The trips associated with development under the proposed action were then added into the 2010 base volumes (see description and base volumes in Appendix F) to produce I the volumes shown on Figure 19. Level of Service I LOS analyses were completed for the 2010 Proposed Action conditions (including anticipated increases in base volumes) and are shown in Table 7. I Table 7 2010 Weekend Levels Of Service I PROPOSED ACTION NORTHBOUND SOUTHBOUND EASTBOUND WESTBOUND OVERALL SR 104/ LOSF LOSF LOSB Lose I Paradise Bay Road >100 sec. >100 sec. 10.2 sec. 16.8 sec. N.A. SR 104/ N.A. LOSF LOSB LOS A Beaver Valley Road >100 sec. 12.8 sec. 9.1 sec. N.A. Beaver Valley LOS A LOSe I Road/Oak Bay Road N.A. 8.6 sec. N.A. 20.0 sec. N.A. Oak Bay Road/Paradise LOSB LOSB LOSB LOSB LOSB Bay Road 11.5 sec. 10.6 sec. 10.9 sec. 13.9 sec. 12.3 sec. I Paradise Bay RoadfTeal LOSe LOSB LOS A LOS A Lake Road 18.6 sec. 11.0 sec. 7.6 sec. 7.9 sec. N.A. Oak Bay RoadlWalker LOS A LOS A LOSB LOSe Way 7.7 sec. 8.0 sec. 14.2 sec. 17.0 sec. N.A. I N.A. - not applicable/available (i.e., calculation not provided for specific analysis/movement, or no volume on subject movement) I Where: LOS Delay I A < 10 seconds B > 10 & < 15 seconds e > 15 & < 25 seconds D > 25 & < 35 seconds I E > 35 & < 50 seconds F > 50 seconds (for unsignalized intersections) I The results of the capacity analyses for the future conditions under the proposed action indicate that all of the intersections will drop from their current levels of service. Much of the increase in I delay, especially at the two intersections along SR 104, is a result of the increase in traffic over the next seven years associated with miscellaneous background growth (see discussion in Appendix F). The local intersections (i.e., Teal Lake Road/Paradise Bay Road, Oak Bay I Port Ludlow MPR Resort Plan May 2005 I Final SEIS 3-87 ... Altl 2010 Volumes - Figure 22 Port Ludlow Resort Plan FSEIS 16090 121 16~101 + 6 4 162 1710+1702 C~ 739-j.924 . , " 2 1 23.1' \ + / ',1 11 ../ ~ 2010 Estimated Weekend Daily & Peak Hour Traffic Volumes (Proposed Action - Alternative 1) I I I I I I I I I I I I I I I I I I I Road/Walker Way, and Paradise Bay Road/Oak Bay Road) will continue to operate at good levels of service as would the Beaver Valley Road/Oak Bay Road intersection. However, the side-street movements at the intersections along SR 104 would experience considerable delay. (The side-street movements at both of these intersections currently experience LOS "F" on the weekend.) The traffic-related impacts associated with the proposed action have a very limited impact on the critical movements at the intersections reviewed. Transit Service Proposed development would create additional housing and recreational opportunities. As discussed in the "Affected Environment" section, transit service is currently provided by Jefferson Transit between Port Townsend and Poulsbo via the Tri-Area and Port Ludlow. Service is provided daily, although service is reduced on the weekend. Development under the Proposed Action is not sufficient to warrant additional transit service. Non-Motorized Facilities The Proposed Action will likely generate additional pedestrian activity along the adjacent roadways that could potentially conflict with vehicular traffic. A designated trail has been shown on the site plan to serve Resort visitors and residents and is a portion of the pathway system in Port Ludlow. Specifically, the portion of the trail system constructed under the Proposed Action includes an eight-foot-wide boardwalk/esplanade along the shoreline extending from the new Harbor Master Restaurant to Burner Point. Signage for the existing pedestrian trail system will be located at the upper community parking lot and along the Burner Point beach trail. A comprehensive community-wide pedestrian trail system has been constructed within Port Ludlow and is maintained as a joint effort between the Port Ludlow Village Council and the developer. The trail system is intended to serve recreational uses, as well as provide a network between the residential areas and activity nodes such as the recreation center, marina, and commercial complex. Site Access The Oak Bay Road/Walker Way/Marina View Drive intersection will continue to serve as the main access to the Resort, with Harbor Drive continuing as a one-way entry to the Marina area. The analyses completed in the prior section indicate that the Oak Bay Road/Walker Way intersection is currently operating at LOS "B", with the future (2010) LOS upon completion of the Resort projected at LOS "C", which is considered acceptable. The accident history showed no reported collisions at this intersection during the three-year period reviewed. No left-turn lanes are currently constructed along Oak Bay Road to serve traffic entering the Resort. The need for left-turn storage on Oak Bay Road at Marina View Drive has been evaluated using Figure 91O-9a of the WSDOT Design Manual. Based on the anticipated volumes at this intersection and Figure 91O-9a, a left-turn storage lane would not be recommended for the future conditions. The entering and stopping sight distances along Oak Bay Road for the Marina View Drive access were reviewed. A horizontal curve is located to the south of Marina View Drive along with a Port Ludlow MPR Resort Plan Final SEIS 3-89 May 2005 ~ slight upgrade. The grade and alignment to the north is relatively flat and straight. The entering sight distance is approximately 850 feet to the north, as is the stopping sight distance from the north. The entering sight distance to the south is restricted by the horizontal curve and measures approximately 525 to 550 feet. The stopping sight distance from the south is approximately 425 to 450 feet. The posted speed along Oak Bay Road is 40 mph. The required entering sight distance for a 40 mph design speed is 445 feet and 500 feet for a 45-mph design speed according to the AASHTO 2001 edition of A Policy on Geometric Design of Highways and Streets. The required stopping sight distance for a 40 mph design speed is 305 feet and 360 feet for a 45 mph design speed. Based on AASHTO guidelines, the intersection meets both entering and stopping sight distance requirements for the posted speed and a design speed of 45 mph. Internal Circulation Alternative 1 would not significantly change the geometries of the existing interior road network, although changes to the existing traffic patterns would occur due to a change in the configuration of the Inn's parking lot, and the relocation of the Harbor Master Restaurant. The proposed prolect includes eliminating the existing access from Heron Road to the Inn parking, although access for emergency vehicles will be maintained via two, 20-foot driveways from Heron Road. Closing the access between the Inn and Heron Road will result in a hammerhead turnaround at the south end of Heron Road. This turnaround, coupled with the emergency access, has been reviewed and approved by Fire District No.3. Closing the existing Inn access will result in restricting vehicular use of the east leg of Heron Road to the abutting townhome residents. Thirteen townhome units are situated at the south end of Heron Road, in the vicinity of the Inn, and an additional 28 units are/would be situated along Heron Road, north of the Inn and the artificial lagoon, up to the first (easterly) overflow parking access near the existing Harbor Master Restaurant. The estimated future number of daily trips on this section of the roadway would be approximately 220 ADT, which falls below the 400 ADT threshold for Jefferson County's 18-foot roadway section. This amount of traffic is also well below any capacity constraint for a two-lane roadway. Moving the Harbor Master Restaurant to the shoreline area west of Gull Drive and accessing the Inn from Gull Drive will remove vehicular traffic from Heron Road, and to the extent that this traffic used "the loop", will remove that traffic from the east leg of Heron Road as well. Parking Additional parking will be constructed as part of the development. Parking requirements for the various commercial uses (the marina and restaurant comprising the larger requirements) will be provided per county Code and will total ~322 stalls (see Appendix J). An additional 9Q5 parking stalls will be provided to serve as overflow for the townhome guests or visitors using the open space. Altogether, 332 spaces will be provided in lots north of the restaurant and marina or on the north side of Heron Drive. Parking for 55 vehicles will be provided on the east side of the Inn; the Inn currently provides 35 parking stalls. Port Ludlow MPR Resort Plan Final SEIS 3-90 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I During peak season, Resort employees will be required to use the upper lots. The parking supply will be monitored during the peak season and valet service will be provided by the restaurant if needed. Golf carts may also be available for marina users to shuttle supplies and equipment between the upper parking lots to and from the marina. Parking for "special events," such as Ludlow Days or large conferences/weddings, which have resulted in capacity conditions in the summer, will no longer be required. Consequently, many of the past problems with parking demand will be eliminated. Furthermore, the parking lot layout and access for the Heron Beach Inn will be modified to eliminate conflicts with townhome residents across from the Inn and along Heron Drive. Nineteen additional stalls will be provided within the Inn parking lot and access to the Inn will be restricted to Gull Drive. Traffic Impacts Resort development under Alternative 1 would generate just under 900 new weekend daily trips, with just under 100 of those trips occurring during the peak hour. The roadways within the Port Ludlow community will be impacted by the largest number of trips. However, the County roads within Port Ludlow are relatively low volume, and the additional traffic generated by the proposed action is well within the capacity of these roadways. The highest anticipated future volume on either Paradise Bay Road or on Oak Bay Road is less than 6,000 vehicles per day including background traffic growth and new trips from the approved, but unbuilt units. Many of the trips associated with the Proposed Action will be internal to Port Ludlow and will not impact roadways on the regional system. The major County intersections that will be impacted by the development (i.e., Paradise Bay Road/Teal Lake Road, Paradise Bay Road/Oak Bay Road, and Oak Bay Road/Walker Way) are expected to continue to operate at good levels of service with or without the development. As noted earlier, the capacity analyses have indicated that the intersections of the local arterials will operate at LOS "c" or better. The most critical transportation conditions in the area occur along SR 104 between Beaver Valley Road and the Hood Canal Bridge. The side-street movements at the intersections of SR 104/Beaver Valley Road and SR 104/Paradise Bay Road are currently at LOS "F" on the weekends during the peak hour and will continue to experience considerable delays. These conditions have been present for several years and were noted in prior traffic monitoring programs conducted for Port Ludlow and identified in prior environmental assessments. The failing conditions are a result of the extremely high volumes of traffic present along SR 104, especially on the weekends in the summer months, and the limited number of gaps in traffic for vehicles entering the highway, which in turn results in a low LOS. The additional trips from the Proposed Action through either of these intersections have minimal impact and comprise less than a fraction of a percentage of traffic through either of these intersections. The Proposed Action will contribute 0.6 percent of trips through the SR 104/Beaver Valley Road intersection and 0.5 percent of the trips to the SR 104/ Paradise Bay Road intersection. Port Ludlow MPR Resort Plan Final SEIS 3.91 May 2005 ~ Cumulative Impacts The traffic volumes and LOS analyses described under Alternative 1 include estimates of future traffic growth for the year 2010. An annual growth rate ranging from 2.68 percent to 6.09 percent plus pipeline development trips were used to project these volumes to account for background traffic growth in the area and the cumulative effects of this growth. Details and summaries of the future volumes and analyses can be found in Appendix F. Alternative 2: 1993 Resort Plan The subsequent sections summarize the traffic-related impacts associated with development of the Resort as described in the 1993 programmatic EIS for Port Ludlow. Many of the land use elements in Alternative 2 are similar to those under the Proposed Action and include the existing uses such as the Heron Beach Inn, the Harbor Master Restaurant, the marina, and the existing residential units. The traffic generated by these existing uses is included in the existing traffic volumes. As noted under Alternative 1, only those development actions that will generate new traffic are included in the analysis for Alternative 2. These uses include the additional 97 residential units (the 186 units proposed in 1993 less the existing condominiums in Admiralty I and nand townhomes in Ludlow Bay Village), the 100 additional slips at the marina, the 2,500-square-foot retail building, and the 1,850-square-foot Town Hall. All other uses described under Alternative 2 are either existing uses or support facilities that are not traffic generators by themselves. The analyses for Alternative 2 will review peak weekend conditions as noted under the Proposed Action. The peak hour for both the various land uses and the adjacent intersections are assumed to occur simultaneously as noted under the Proposed Action. Direct Impacts Trip Generation Alternative 2 will generate additional traffic onto the adjacent transportation system. The trip generation for Alternative 2 has been estimated using the most recent values in the ITE Trip Generation Manual (6th Edition, 1997) and trip generation data collected as part of the traffic monitoring program in Port Ludlow. The average trip rates have been used for the trip generation unless noted otherwise. As noted earlier, only those uses that will generate new traffic are included in the trip generation. Land Use Codes 420 (Marina), 495 (Recreational Center), and 814 (Specialty Retail Center) from the ITE Trip Generation Manual for additional slips, the Town Hall, and retail building respectively were used in the trip generation estimates. The trips rates for the residential units are from the 2002 monitoring program. Table 8 summarizes the weekend trip generation associated with Alternative 2. Port Ludlow MPR Resort Plan Final SEIS 3-92 May 2005 ... I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Table 8 Estimated Weekend Trip Generation Alternative 2 Port Ludlow Resort AL TERNA TIVE 2 Townhomes Marina Town Hall Specialty Retail Total Trips (97 units) (100 slips) (1,850 SF) (2,500 SF) Daily Trip Rate 5.40 trips/ 3.22 trips/ 9.10 trips/ 42.04 trips/ unit slip 1,000 SF 1,000 SF Daily Trips 524 322 17 105 968 Peak Hour Rate 0.66 trips/ 0.27 trips/ 1.25 trips/ 4.93 trips/ unit slip 1,000 SF 1,000 SF* Peak Trips Entering 35 12 1 7 55 Peak Trips Exiting 29 15 1 5 50 Total Peak Trips 64 27 2 12 105 * - Saturday peak hour rate not available in ITE so weekday value was used. Table 8 shows that Alternative 2 would generate slightly more traffic than the Alternative 1 at build-out. Trip Distribution Figure ~23 shows the estimated weekend daily and peak hour trip distribution/assignment for I Alternative 2. The distribution/assignment is based on current traffic patterns, the existing road system, and the proposed land uses as discussed under the Proposed Action. As noted under Alternative 1, many of the trips are expected to stay within the Port Ludlow community, and the greatest traffic-related impacts will be on Oak Bay Road. Future Volumes Figure 21+ shows the estimated 2010 weekend daily and peak hour traffic volumes for Alternative I 2. The annual growth rates and pipeline traffic discussed in the Appendix were used to project the future base volumes shown in Figure U-23 to account for miscellaneous background and pipeline I traffic growth. Additionally, the traffic associated with development under Alternative 2 was added into these volumes. Port Ludlow MPR Resort Plan Final SEIS 3.93 May 2005 ... Alt2 Distributions - Figure 23 I Port Ludlow Resort Plan FSEIS XXX% - Percent Distribution (XXX) - Peak hour volume - Daily volume (10) . 1 l f , 1: , t ~1 'I \ (8~ 15% \ \ (8)\ Estimated Weekend Trip Distribution/Assignment (Alternative 2) Alt2 2010 Volumes - Figure 24 Port Ludlow Resort Plan FSEIS I I I 2010 Estimated Weekend Daily & Peak Hour Traffic Volumes (Alternative 2) 121 16+101 , 6 4 163 710+1702 C~ 739-t-925 2 1 23 1+11 13 I Level of Service I LOS analyses were completed for the 2010 Alternative 2 conditions and are shown in Table 9. I Table 9 2010 Weekend Levels Of Service I ALTERNATIVE 2 NORTHBOUND SOUTHBOUND EASTBOUND WESTBOUND OVERALL I SR 104/ LOSF LOSF LOSB Lose Paradise Bav Road > 100 sec. >100 sec. 10.2 sec. 16.8 sec. N.A. SR 104/ N.A. LOSF LOSB LOS A Beaver Valley Road >100 sec. 12.8 sec. 9.1 sec. N.A. I Beaver Valley LOS A LOSe Road/Oak Bav Road N.A. 8.6 sec. N.A. 20.2 sec. N.A. Oak Bay RoadlParadise LOSB LOSB LOSB LOSB LOSB I Bay Road 11.6 sec. 10.6 sec. 11.0 sec. 14.0 sec. 12.3 sec. Paradise Bay RoadfTeal LOSe LOSB LOS A LOS A Lake Road 18.7 sec. 11.0 sec. 7.6 sec. 7.9 sec. N.A. I Oak Bay Road/Walker LOS A LOS A LOSB LOSe Way 7.7 sec. 8.0 sec. 14.3 sec. 17.2 sec. N.A. N.A. - not applicable/available (i.e., calculation not provided for specific analysis/movement, or no volume on I subject movement) Where: I LOS Delay A < 10 seconds B > 10 & < 15 seconds I e > 15 & < 25 seconds D > 25 & < 35 seconds E > 35 & < 50 seconds I F > 50 seconds (for unsignalized intersections) The LOS analyses show that that Alternative 2 will have a slightly greater impact than the I Proposed Action at some of the intersections. As noted under the Proposed Action, the local I intersections (i.e., Teal Lake Road/Paradise Bay Road, Oak Bay Road/Walker Way, and Paradise Bay Road/Oak Bay Road) will continue to operate at good levels of service as would the Beaver Valley Road/Oak Bay Road intersection. However, the side-street movements at the I intersections along SR 104 would experience considerable delay. Internal Circulation I Alternative 2 would not change the geometries of the existing interior road network, and the existing traffic patterns would essentially stay the same. More traffic would use Heron Road under Alternative 2 since the Inn parking and lot access would not be modified, the Harbor I Master Restaurant would not be relocated, the town hall would be constructed along Heron Road, and more townhomes would be constructed along the Heron Road than under the proposed action. I Port Ludlow MPR Resort Plan May 2005 Final SEIS 3-96 ... I I I I I I I I I I I I I I I I I I I I Conversely, Gull Drive would be impacted with less traffic under Alternative 2 than under the proposed action since the restaurant would not be relocated, and the Inn could still be accessed from Heron Road. Transit Service Development under Alternative 2 will be similar to the Proposed Action. As discussed in the "Affected Environment" section, transit service is currently provided by Jefferson Transit between Port Townsend and Poulsbo via the Tri-Area and Port Ludlow. Service is provided daily, although service is reduced on the weekend. Similar to the proposed action, development under Alternative 2 is not sufficient to warrant additional transit service. Non-Motorized Facilities Alternative 2 would likely generate additional pedestrian activity along the adjacent roadways as noted under the proposed action. No specific trail or non-motorized facility improvements are noted for construction under Alternative 2. The existing Port Ludlow trail system could serve many of the needs of the new residents. Site Access Access to the Resort under Alternative 2 would be the same as under Alternative 1, i.e., either from the intersection of Oak Bay Road/Walker Way/Marina View Drive or via Harbor Drive. The LOS at the intersection of Oak Bay Road/Walker Way/Marina View Drive would be "C," left-turn storage on Oak Bay Road at Marina View Drive would not be needed, and the sight distance conditions would all be the same as those noted under the Alternative 1. Parking Slightly more parking would be provided under Alternative 2 as compared to the Proposed Action. Parking for 400 vehicles was proposed under Alternative 2 in various lots throughout the site. The parking lot layout and access for the Heron Beach Inn and adjacent townhomes would remain in its current configuration, however. As with Alternative 1, it is assumed the past "special events," generating demands for additional parking during the peak season, would no longer occur. Traffic Impacts The development of the Port Ludlow Resort under Alternative 2 would generate just under 970 additional weekend daily trips, with 105 of those trips occurring during the peak hour. The impacts associated with development under Alternative 2 would be almost identical to those under the Alternative 1, i.e., the major County intersections would continue to operate at good levels of service ("C" or better) and the side street movements at the intersections of SR 104/Beaver Valley Road and SR 104/Paradise Bay Road would experience considerable delays. Cumulative Impacts The traffic volumes and LOS analyses described in Alternative 2 include estimates of future traffic growth for the year 2010. An annual growth rate ranging from 2.68 percent to Port Ludlow MPR Resort Plan Final SEIS 3-97 May 2005 ... 6.09 percent plus pipeline development trips were used to project these volumes to account for background traffic growth in the area and the cumulative effects of this growth. Details and summaries of the future volumes and analyses can be found in the Appendix. Alternative 3 - 1999 Resort Plan (No Action) The subsequent sections summarize the traffic-related impacts associated with development under the existing 1999 Resort Plan for Port Ludlow.:. (No .^~ction alternative). Many of the land use elements in Alternative 3 are substantially different to those under the Proposed Action or Alternative 2; however, Alternative 3 does include the existing uses such as the Inn at Port Ludlow, the Harbor Master Restaurant, the marina, and the existing residential units, which currently generate traffic that is included in the existing traffic volumes. As noted for the previous alternatives, only those development actions that will generate new traffic are included in the analysis for Alternative 3. These uses include the hotel/conference center (including the restaurants and lounge), the 100 additional slips at the marina, the 2,500-square-foot retail building, the museum, and the sports/youth facilities. All other uses described under Alternative 3 are either existing uses or support facilities that are not traffic generators by themselves. The analyses for Alternative 3 will review peak weekend conditions as noted in the previous alternatives. The peak hour for both the various land uses and the adjacent intersections are assumed to occur simultaneously as previously noted. Direct Impacts Trip Generation Alternative 3 will generate additional traffic onto the adjacent transportation system. The trip generation for Alternative 3 has again been estimated using the most recent values in the ITE Trip Generation Manual (6th Edition, 1997). The average trip rates have been used for the trip generation unless noted otherwise. As noted earlier, only those uses that will generate new traffic are included in the trip generation. Land Use Codes 310 (Hotel), 420 (Marina), 492 (Racquet Club), and 814 (Specialty Retail Center) from the ITE Trip Generation Manual were used in the trip generation estimates. No trip generation data is available for museums, so other land uses were reviewed to find a reasonable substitute. The most comparable use of the ones available in the Trip Generation Manual is Land Use Code 590 (Library). The library land use was deemed the most appropriate substitute since its patrons have random arrivals and departures, the use is institutional, and extended stays can occur, all of which are similar to a museum. Some of the site traffic is expected to be internal, i.e., patrons of the hotel/conference center may use the museum, marina or sports facilities, or current townhome/condominium residents may use the marina, restaurants, or sports facilities located within the site. This assumption is further supported by data found in the ITE]rip Generation Handbook summary on multi-use developments where data for multi-use sites with hotels had an internal capture rate of approximately 30 percent. To be conservative, a 15 percent internal rate for trips within the site has been used for Alternative 3. Since these trips are internal, they will not impact the adjacent roadways or intersections and therefore have been deducted from the total trips associated with the proposed land uses. Port Ludlow MPR Resort Plan Final SEIS May 2005 ~ 3-98 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Table 10 summarizes the weekend trip generation associated with Alternative 3. Table 10 Estimated Weekend Trip Generation Alternative 3 Port Ludlow Resort ALTERNATIVE 3 HoteUConf. SportJYouth Specialty Center Marina Centers Retail Museum Total (238 rooms) (100 slips) (43,500 SF) (2,500 SF) (7,500 SF) Trips Daily Trip Rate 8.19 trips! 3.22 trips! 24.51 Trips! 42.04 trips! 46.55 trips! room slip 1,000 SF 1,000 SF 1,000 SF Daily Trips 1949 322 1066 105 349 3,791 Less 15% Internal 293 48 160 16 52 569 Net New Trips 1656 274 906 89 297 3,222 Peak Hour Rate 0.72 trips! 0.27 trips! 3.11 trips! 4.93 trips! 6.75 trips! room slip 1,000 SF 1,000 SF* 1,000 SF Peak Trips Entering 96 12 67** 7 27 209 Peak Trips Exiting 75 15 68** 5 24 187 Total Peak Trips 171 27 135 12 51 396 Less 15% Internal 25 4 20 2 8 59 Net New Trips 146 23 115 10 43 337 * - Saturday peak hour rate not available in ITE so weekday value was used. ** - Directional split not provided; 50!50 split assumed. Table 10 shows that Alternative 3 would generate significantly more traffic than the Proposed Action or Alternative 2. Trip Distribution Figure n25 shows the estimated weekend daily and peak hour trip distribution/assignment for Alternative 3. The distribution/assignment is more heavily weighted towards SR 104 (to and from the east) than the Proposed Action and Alternative 2. This is due to the regional attraction associated with the hotel/conference center, which is not proposed to the same extent in either the Proposed Action or Alternative 2. As noted under Alternatives 1 and 2, some of trips are expected to stay within the Port Ludlow community with destinations to and from existing residential, commercial, or recreational activities within the community. The greatest traffic-related impacts would continue to be on Oak Bay Road. Future Volumes Figure fr26 shows the estimated 2010 weekend daily and peak hour traffic volumes for Alternative 3. The annual growth rates and pipeline traffic discussed in the Appendix were used to project the future base volumes shown in Figure fr26 to account for miscellaneous background I and pipeline traffic growth. Additionally, the traffic associated with development under Alternative 3 was added into these volumes. Port Ludlow MPR Resort Plan Final SEIS 3.99 May 2005 ... Alt3 Distributions - Figure 25 t Port Ludlow Resort Plan FSEIS XXX% - Percent Distribution (XXX) - Peak hour volume [Xx~q - Daily volume (24) i / t j %, , , \. " (16~ 10%\\ - i \ (18)\ Estimated Weekend Trip Distribution/Assignment (Alternative 3) I I I I I I Alt3 2010 Volumes - Figure 26 Port Ludlow Resort Plan FSEIS I I 2010 Estimated Weekend Daily & Peak Hour Traffic Volumes (Alternative 3) I Level of Service I LOS analyses were completed for the 2010 Alternative 3 conditions and are shown in Table 11. I Table 11 2010 Weekend Levels Of Service I ALTERNATIVE 3 NORTHBOUND SOUTHBOUND EASTBOUND WESTBOUND OVERALL I SR 104/ LOSF LOSF LOSB Lose Paradise Bay Road >100 sec. > 100 sec. 10.5 sec. 17.3 sec. N.A. SR 104/ N.A. LOSF LOSB LOS A Beaver Valley Road >100 sec. 13.5 sec. 9.1 sec. N.A. I Beaver Valley LOS A LOSE Road/Oak Bay Road N.A. 8.9 sec. N.A. 40.5 sec. N.A. Oak Bay Road/Paradise LOSB LOSB LOSe Lose LOSB I Bay Road 14.0 sec. 11.7 sec. 15.1 sec. 16.2 sec. 14.9 sec. Paradise Bay RoadlTeal LOSe LOSB LOS A LOS A Lake Road 20.5 sec. ILl sec. 7.6 sec. 8.0 sec. N.A. I Oak Bay RoadlWalker LOS A LOS A LOSe LOSE Way 7.7 sec. 8.3 sec. 16.0 sec. 38.1 sec. N.A. N.A. - not applicable/available (i.e., calculation not provided for specific analysis/movement, or no volume on subject movement) I Where: I LOS Delay A < 10 seconds B > 10 & < 15 seconds I e > 15 & < 25 seconds D > 25 & < 35 seconds E > 35 & < 50 seconds F > 50 seconds I (for unsignalized intersections) The LOS analyses show that Alternative 3 will have a much greater impact at some of the I intersections than either the Proposed Action or Alternative 2. Specifically, the intersections of Oak Bay RoadlBeaver Valley Road and Oak Bay Road/Walker Way would drop to LOS "E" I under Alternative 3, although the intersections of Paradise Bay Road/Oak Bay Road and Paradise Bay Road/Teal Lake Road would continue to operate at good levels of service. The side-street movements at the intersections along SR 104 would continue to experience considerable delay as I noted under the existing conditions, the Proposed Action, and Alternative 2. Internal Circulation I The one-way section of Harbor Drive from Oak Bay Road would be eliminated under Alternative 3. Furthermore, the alignment of some of the internal roadways would be altered. Specifically, the Marina View Drive/Olympic Place intersection would be modified, as would I the Heron Road/Harbor Drive intersection. Considerably more traffic would use Walker Way due to the higher traffic volumes associated with development under Alternative 3 plus the closure of the Harbor Drive access from Oak Bay Road. Furthermore, more traffic would use the I Port Ludlow MPR ResortPlan May 2005 Final SEIS 3-102 --- I I I I I I I I I I I I I I I I I I I I section of Heron Road near the existing Harbor Master Restaurant due to the construction of the hotel/conference center under Alternative 3. Transit Service Development under Alternative 3 would be more intense than Alternatives 1 or 2. As discussed in the "Affected Environment" section, transit service is currently provided by Jefferson Transit between Port Townsend and Poulsbo via the Tri-Area and Port Ludlow. Service is provided daily, however, service is reduced on the weekend. Although development under Alternative 3 would generate more traffic than Alternative 1 or 2, it is not sufficient to warrant additional public transit service, since much of the traffic will be regional. There is a potential to reduce some of the site traffic through private van or mini-bus service to shuttle hotel guests between the various activity centers within Port Ludlow or to and from ferry terminals. Non-Motorized Facilities Alternative 3 would likely generate additional pedestrian activity along the adjacent roadways as noted under the Proposed Action and Alternative 2. A boardwalk along the shoreline extending east from the Inn, similar to the one proposed in Alternative 1, has been shown on the site plan. Additionally, the existing Port Ludlow trail system could serve many of the needs of the hotel guests. Site Access Access to the Resort under Alternative 3 would be the same as under the proposed access, i.e., either from the intersection of Oak Bay Road/Walker Way/Marina View Drive or via Harbor Dri ve. The LOS at the intersection of Oak Bay Road/Walker Way/Marina View Drive would be "E," which is lower than projected for either Alternative 1 or 2, indicating the potential need for upgrades to the intersection. Left-turn storage on Oak Bay Road at Marina View Drive would not be needed, and the sight distance conditions would be the same as those noted under the Proposed Action. Parking Amulti-level parking structure would be provided under Alternative 3. Additionally, additional stalls would be provide in surface lots. This amount of parking is greater than the amount proposed for the Proposed Action or Alternative 2. The parking lot layout and access for the Inn and the adjacent townhomes would remain in its current configuration under Alternative 3. Traffic Impacts The development of the Port Ludlow Resort, if constructed as proposed under the 1999 Plan, would generate over 3,200 additional weekend daily trips, with over 300 of those trips occurring during the peak hour. The impacts associated with development under Alternative 3 would be much greater than those under the Proposed Action or Alternative 2. Specifically, the intersections of Oak Bay Road/Beaver Valley Road and Oak Bay Road/Walker Way would drop to LOS "E" under Alternative 3, although the intersections of Paradise Bay Road/Oak Bay Road and Paradise Bay Road/Teal Lake Road would continue to operate at good levels of service. The side-street movements at the intersections along SR 104 would continue to experience considerable delay as noted under the existing conditions, the Proposed Action, and Alternative 2. Port Ludlow MPR Resort Plan Final SEIS 3.103 May 2005 ~ I Cumulative Impacts I The traffic volumes and LOS analyses described in Alternative 3 include estimates of future I traffic growth for the year 2010. An annual growth rate ranging from 2.68 percent to 6.09 percent plus pipeline development trips were used to project these volumes to account for background traffic growth in the area and the cumulative effects of this growth. Details and I summaries of the future volumes and analyses can be found in the Appendix. Alternative 4: Response to Comments I Compared to Alternative 1 , Alternative 4 would reduce the number of new residential units in Admiralty by seven (to 32 units), reduce the number of new units in Ludlow Bay Village by I seven (to 55 units), and reduce the number of new slips in the marina by 40 (to 60 slips). The following table shows the revised trip generation under Alternative 4. Table 12 I ESTIMATED WEEKEND TRIP GENERATION ALTERNATIVE 4 I PORT LUDLOW RESORT Alternative 4 I Maintenance Townhomes Marina PLA Offices Buildinl! Total I (87 units) (60 slips) (30 emp.) (2900 SF) Trips Daily Trip Rate 5.40 trips/unit 3.22 trips/slip 0.54 trips/ 1.22 trips/ employee 1000 SF I Daily Trips 470 193 16 1 683 Peak Hour Rate 0.66 trips/unit 0.27 trips/slip 0.09 trips! 0.12 trips/ employee 1000 SF I Peak Trips Entering Jl 1 ~ Q 40 Peak Trips Exiting 26 2 1 Q 36 Total Peak Trips 57 16 } Q 76 I The elimination of 14 residential units and 40 slips results in a decrease of 204 weekend daily I trips and 21 fewer weekend peak hour trips, a decrease of iust over 20 percent of the traffic that would be generated by Alternative 1, the applicant's proposed action. The distribution of trips would be similar to Alternative 1. I The reduction in the number of trips under Alternative 4 would result in fewer off-site impacts to the adlacent County and State roadways, and also result in fewer internal impacts to the private I roadways within the Resort. Although a reduction in the number of units and slips is proposed under Alternative 4, the number of parking stalls that are proposed will remain the same as the number proposed under Alternative 1. I The impacts to Transit service and non-motorized facilities would be similar to Alternative 1. I Port Ludlow MPR Resort Plan May 2005 Final SEIS 3-104 ~ I I I I I I I I I I I I I I I I I I I I Alternative 5: No Action No further development at this time would result in no changes to the internal circulation system and no additional vehicular traffic generation at this time. 3.6.3 Mitigation Measures Direct impacts associated with the Alternative 1 - Proposedreffered Action, are limited. Specifically, new trips associated with the Proposed Action will have a negligible impact on the LOS at the local intersections within Port Ludlow and therefore no mitigation is needed. The County arterials in the Port Ludlow area are operating at acceptable levels of service and will continue to operate acceptably with the Proposed Action. The side-street movements at the intersections of Beaver Valley Road/SR 104 and Paradise Bay Road/SR 104 are currently operating at LOS "F" and will become increasingly more congested with or without development under any of the alternatives. The congested conditions are typical during the peak summer season and are regional in nature. Considerably less congested conditions occur during the off-peak seasons. Both of these intersections have had turn lanes constructed on SR 104, and any additional channelization improvements would primarily be constructed on the side streets. The capacity analyses at these intersections were conducted again to determine improvements that could be made to provide a LOS better than "F." The installation of a traffic signal and additional side- street lanes would raise the LOS above "F," although the intersection of SR 104/Paradise Bay Road would still have saturated conditions in the eastbound direction in the future (assuming the over 50 percent increase in these volumes occurs). These improvements would result in LOS "E" at SR 104/Paradise Bay Road and LOS "c" at SR 104/Beaver Valley Road. WSDOT currently has no near-term projects proposed for the area. In its 20-year Highway System Plan, WSDOT lists improvements to SR 19 between SR 104 and ChimacumlCenter Roads and to SR 104 between Beaver Valley Road (SR 19) and the Hood Canal Bridge. The SR 19 long-term improvements include widening to four lanes. The long-term SR 104 improvements would include widening to four lanes, intersection improvements, and access management plus widening of the Hood Canal Bridge to four lanes to address the congested conditions. These improvements proposed by WSDOT are large-scale projects to address regional needs along a highway of statewide significance. The number of trips associated with the Proposed Action impacting either of the intersections along SR 104 is a small percentage of the total traffic through these intersections (0.6 percent at Beaver Valley Road and 0.5 percent at Paradise Bay Road) and is not creating the need for these improvements. Based on the previous analyses and the impacts associated with the alternatives, no off-site mitigation is recommended for Alternative 1 or 2. Some channelization improvements may be required at the Oak Bay Road/W alker Way and Beaver Valley Road/Oak Bay Road intersections to raise the LOS above "E" for Alternative 3. Under all alternatives, enhancements to the on-site parking operations are recommended as described in the previous sections in order to regulate peak demand. Port Ludlow MPR Resort Plan Final SEIS 3.105 May 2005 ... Internal Circulation Revisions to the internal site circulation/access associated with Alternative 1 (i.e., eliminating the existing access from Heron Road to the Inn parking and relocation of the Harbor Master Restaurant) will result in restricting vehicular use of the east leg of Heron Road to the abutting townhome residents. This action will mitigate many of the concerns associated with additional traffic, since the Harbor Master Restaurant and the Inn will be served from Gull Drive rather than Heron Drive. Because the volume of traffic on Heron Road and Gull Drive is within the capacity of the roadways, and traffic on the east leg of Heron Road will be reduced, no street improvements are warranted. To further enhance local access operations (i.e. encourage low speeds and provide motorist guidance) within the Resort, it is recommended that directional signage to the existing and proposed destinations be installed/enhanced along the internal roadways, 15-mph speed limit signs be installed, and Heron Drive be signed for local access/residents only. 3.6.4 Unavoidable Adverse Impacts The traffic study prepared for this DSEIS demonstrates that the proposed action will not result in significant unavoidable adverse impacts that cannot be mitigated. Traffic volume increases along SR 104 from external sources will result in continued LOS "F" conditions in the future during peak (summer) season. This will occur with or without development under the Proposed Action. The construction of traffic signals will be needed in order to accommodate the additional traffic as noted in the previous section, and additional lanes on SR 104 will be needed per WSDOT's long-term plan. No other significant unavoidable adverse impacts have been identified with respect to traffic that cannot be mitigated. Although the amount of traffic is within the capacity of the roadways, or improvements can be constructed to mitigate the levels of service, the presence of additional traffic on the roadways may be perceived as undesirable by existing residents. Port Ludlow MPR Resort Plan Final SEIS 3.106 May 2005 ... I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 3.7 PUBLIC SERVICE AND UTILITIES 3.7.1 Fire/Emergency Services 3.7.1.1 Affected Environment The Port Ludlow Resort is served by Jefferson County Fire Protection District No.3. Fire District No.3 provides emergency fire, hazardous materials, and medical services from four fire stations: one in Port Ludlow, one in Paradise Bay, one on South Point Road, and one in Chimacum. The Port Ludlow fire station (Station No.31) was completed in May 2002 and is located at 7650 Oak Bay Road. This station is manned by a minimum of two career firefighters/EMTs 24 hours a day, 365 days per year, and staff is augmented by five volunteers who respond from their homes in the Port Ludlow MPR. In addition, the Fire Chief is at this station during the weekdays. This station houses two Class A pumper trucks, two Advance Life Support ambulance vehicles, one wildfire engine, and two support vehicles. The Jefferson County Fire Protection District No.3 responded to a total of 344 alarms in 2002, with 159 of those alarms coming from the Port Ludlow MPR. Call data is not reported for the Resort complex independently of the larger MPR. Information provided by Fire District 3 indicates that the typical current response time from Station 31 to the MPR is 2 to 3 minutes from the time of alarm. A typical average immediate response includes three personnel with an additional average of one volunteer. Stations No. 32 (Alder Street in Paradise Bay), Station No. 33 (101 South Point Road), Station No. 11, and Station No. 81 (Kingston) are also available to assist with incidents at the Resort. Station No. 32 will provide a volunteer response 30 percent of the time, with a typical response time of 7 to 8 minutes. Station No. 33 will provide a volunteer response 45 percent of the time, with a typical response time of 8 to 10 minutes. Station No. 11 will dispatch immediately for any incident larger than an emergency aid call in the Resort area, with a typical response time of 7 to 9 minutes. Stations No. 81 (Kingston) and No. 77 (Kitsap Fire District No. 18/Poulsbo) are also available for any incident that has the potential of overwhelming initial response teams. Detailed information regarding Fire District No.3 capabilities is presented in Appendix G. Development-specific fire flows are determined by the Jefferson County Fire Marshall. Fire hydrant tests were conducted in 2000 and 2003 and show adequate flows are available to the Resort area. Existing upland structures were constructed in compliance with fire protection codes for the specified use applicable at the time of construction. Existing townhomes are sprinkled. The new townhomes/condominiums are anticipated to be considered "Type 5, 1 Hour" occupancies and also will be sprinkled. Currently, mid-size emergency medical air transport helicopters can land in open areas within the Resort. No area is designated as a formal landing zone, however. Port Ludlow MPR Resport Plan Final SEIS 3-107 May 2005 ... Port Ludlow MPR Resport Plan Final SEIS 3-108 May 2005 ~ I I I I I I I I I I I I I I I I I I I Within the Resort, propane storage for boats at the marina is currently located adjacent to the Dockmaster's office. Propane storage for the eastern half of the Ludlow Bay residential units is located at the east end of the Resort, between Building 700 and Building 400. The existing fire protection system at the Port Ludlow Marina consists of three individual portable saltwater pump units located in small shed storage areas dispersed throughout the float system. Chapter 9 of the Port Ludlow Marina Operations Manual addresses marina emergencies and outlines procedures for responding to emergencies such as person overboard, medical emergencies, fire control, safety, security, fueling, oil spills, sinking boats, hazardous materials, severe weather, earthquakes, and threats. The Marina staff is trained to respond to emergencies per procedures set forth in this manual. 3.7.1.2 Environmentallmpacts Alternative 1. Preferred Applicant's Proposed Project - 2003 Proposed Resort Plan Alternative 1 will result in an additional 101 residential units within the Resort, as well as a new 7,500-square-foot recreation building, the new Harbor Master Restaurant, and the 100-slip expansion of the marina. Use of the waterfront area for large, outdoor special events will be significantly curtailed. All new construction will comply with current fire code standards. All new residential units, as well as the recreation building and restaurant, will be sprinkled and will not exceed 35 feet in height. The new residential units will result in an incremental increase in emergency aid calls. Vehicular access to the Resort from Oak Bay Road will remain unchanged. Within the Resort, internal access to the Inn at Port Ludlow and adjacent residences will be separated. A designated emergency medical helicopter landing site will be located at the south end of the Admiralty III area. Two new underground propane storage areas will be added - one within Ludlow Bay Village and one within Admiralty III. If the new Harbor Master Restaurant or Recreation building require propane storage, the storage will be located outside, adjacent to the buildings. The Port Ludlow Marina Expansion SEIS (2002) addressed fire suppression at the marina as follows: A piped fire suppression system with call boxes will be provided for all new floats. The system will consist of a piped connection to the existing fire line on land near the existing Marina office. A double detector check valve, post indicator valve, and siamese fire department connection will be provided in the vicinity of the Marina office. A dry line pipe will run from the landside, down the existing gangway, and will be run along the docks under the walers. A fire department connection standpipe will be installed on the dock system per code such that no point on the new dock system will be more than 75 feet from a fire connection standpipe. In addition, a fire hose cabinet with a direct connection to the standpipe will be located at each fire standpipe location; a fire extinguisher will also be located at each of the fire hose cabinets. Additional fire standpipes may be added to the existing floats on A-, B-, C-, D-, and E-Docks and along the existing central walkways to improve firefighting capabilities on these existing floats. I I I I I I I I I I I I I I I I I I I The new fire suppression system will improve the ability to control and contain fires at the Marina. With the presence of a fire piping system, additional fire extinguishers, fire hose cabinets, and numerous fire connection ports, the ability to fight fires is greatly improved. This will reduce the pollution of the environment through faster containment of fires resulting in less sunken vessels, oils, and other debris that may occur in the event of a fire. Alternative 2. 1993 Resort Plan The impacts of Alternative 2 to fire and emergency medical services would be similar to the impacts associated with Alternative 1. Current internal road access would remain unchanged and no emergency medical helipad would be designated; emergency helicopter landings would still occur, however. Alternative 3. 1999 Resort Plan No ,'\dioB Alternative 3 could result in the most intense use of the site and thus the greatest impacts to fire and emergency medical services. Increased use of the site would result in an increase in both emergency medical and fire calls. It is unclear whether Fire District #3, working with the District on a response program, could provide an adequate response to calls during the peak season if this Alternative was developed as originally envisioned. Alternative 4: Response to Comments The impacts of Alternative 2 to fire and emergency medical services would be similar to the impacts associated with Alternative 1. Alternative 5: No Action No further development within the Resort area would result in no increased demands on fire or emergency medical services at this time. 3.7.1.3 Mitigating Measures Proposed: . For each new residential unit, the developer will pay Fire District No.3, $193.00 per unit in mitigation/impact fees. . A portion of the property tax for development within Port Ludlow goes to Fire District No.3; in 2002 this amount was $77,097. . Residential units extending over the edge of the artificial lagoon will include 24-foot-wide catwalks connecting the decks and wrapping around the building side in order to provide emergency egress to the land side. . A designated emergency helicopter landing zone will be located at the south end of the Admiralty III area. . All propane storage areas will meet applicable code requirements. . "Resort Mitigation" measures as identified in the May 4,2004 Fire District No.3 Letter From the Port Ludlow Marina Expansion SEIS (2002) . At least two fire hydrants and adequate emergency access will be provided in the area of the proposed Marina expansion. Port Ludlow MPR Resport Plan Final SEIS 3-109 May 2005 ... Port Ludlow MPR Resport Plan Final SEIS 3-110 May 2005 ~ I I I I I I I I I I I I I I I I I I I . A dry line piped fire suppression system will be provided on float C, down the central walkway, and on all new docks. Additional extensions to the existing docks may also be constructed. This new piped system will provide firefighting capabilities such that each area on the new float system is no more than 75 feet from a firefighting apparatus. Improved firefighting capabilities will reduce the potential for debris and pollutant contamination from fire events. . Marina personnel and liveaboard residents will receive training in emergency firefighting procedures. . Fire call boxes will be provided on the new floats and down the main walkway. These alarms and the main fire alarm for the Marina will be linked to a monitoring service or other entity to assure automatic alert of appropriate authorities. . A connection will be provided between B-Dock and C-Dock to provide additional access to the docks for firefighting crews and for egress for boaters from the docks in the event of a fire emergency. This will allow each dock to be accessed by two gangways instead of the current one-gangway access system for Docks C, D, and E. 3.7.1.4 Unavoidable Adverse Impacts No significant unavoidable adverse impacts to fire and emergency medical services are anticipated. Increased use of the Resort by residents and guests will increase the demand on fire and emergency services, however. 3.7.2 Water Service 3.7.2.1 Affected Environment Water service to Port Ludlow is provided by Olympic Water and Sewer, Inc. (OWSn. An eight-inch water main runs through Admiralty I and n and loops around the plat of Ludlow Bay Village. OWSI obtains its domestic and irrigation water from groundwater (see Section 3.2.2 "Groundwater" of this Draft SEIS). The Port Ludlow development has water rights equal to 186 million gallons per year. Storage totaling 895,000 gallons is provided in four reservoirs. Existing water mains serving the Resort complex are shown in Figure ~27. OWSI produces an annual "Well Productions Report" to monitor their water usage. For the year 2002, the OWSI combined annual average production was 187.2 gpm from all aquifers, or 98.4 million gallons of water for the year. The Port Ludlow Marina Expansion Draft SEIS (2002) states that of the total 98.4 million gallons, the Marina accounted for approximately 1.7 million gallons (4,602 gallons per day), or approximately 2 percent of total water use. Annual water use for the Port Ludlow development is expected to stay well below the 186 million gallons of annual water rights. 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The new residential units and Resort recreation facilities were anticipated in the design of the water system. The adequacy of groundwater supplies is addressed in Section 3.2.2.2 of this Draft SEIS. Use of domestic water also will be increased at the new marina slips, as well as at associated upland facilities such as the laundry, restroom, and showers. The following summarizes the anticipated increase in water usage at the expanded marina (Port Ludlow Marina Expansion Draft SEIS, 2002): . Anticipated total Marina Water Usage with expansion = 6,457 GPD/2,356,805 gallons per year. · Total annual increase in water usage = 620,500 gallons per year, or a 0.7 percent increase in year 2001 total Port Ludlow water usage. Thus, with the Marina expansion, the annual water usage for the Port Ludlow development will not exceed their 186 million gallons of annual water rights. The Uniform Building Code does not address the number of restroom facilities required in marinas. Marina design guidelines recommend adding one additional bathroom stall per 100 slips for expansion (Tobiason, 2000). Alternative 5: No Action No further development within the Resort area would result in no increased demands on the water system at this time. 3.7.2.4 Mitigating Measures Proposed (Alternative 1): · Build-out of the Resort, including a 100-slip expansion of the Marina was anticipated in planning for the water system. · Water system improvements will be installed as required at the time of development. 3.7.2.5 Unavoidable Adverse Impacts No unavoidable adverse impacts to the water system are anticipated. Port Ludlow MPR Resport Plan Final SEIS 3-112 May 2005 ... 3.7.3 Sanitary Sewer Service 3.7.3.1 Affected Environment Sanitary sewer service to Port Ludlow is provided by Olympic Water and Sewer, Inc. (OWSI). All development within the MPR is connected to the sanitary sewer system. Within the Resort, sewage is collected in gravity lines and subsequently pumped via a lift station into a force main and conveyed to the treatment plant located north of the Resort. The 2002 Port Ludlow Development Impact Monitoring Report states that the maximum-month average daily treatment plant flow occurred in January and was 195,000 gallons per day. The treatment plant has a permitted design capacity of 640,000 gallons per day. Key parameters measured in effluent discharge (i.e., biochemical oxygen demand, total suspended solids, and fecal coliform) were well below adopted standards. The existing sewer system within the Resort complex is shown in Figure ~27. The Port Ludlow Marina Expansion Draft SEIS (2002) states that at the marina, the existing sanitary sewer system consists of one stationary boat sewage pump-out system installed on the fuel float and a new portable pump-out facility. The stationary boat sewage pump-out is a Keco Model installed in the early 1990s. The existing discharge piping and system is in working condition and has sufficient capacity to support the Marina. The new portable pump-out facility was installed in April 2002. The draft Resort at Ludlow Bay Marina Regulations and Policies address discharge of gray and black water in Section III D., as follows: D. DISCHARGE OF BLACK WATER AND GRA Y WATER 1. All vessels, which moor in the Marina, must be in compliance with all regulations established by the United States Coast Guard or other federal or state regulatory agencies. 2. Discharge of black water from vessels while in Ludlow Bay is prohibited. 3. Sanitary waste disposal facilities are available at designated locations within the Marina at no charge to users. All users shall use these facilities for the disposal of raw sewage. 4. Liveaboards must pump their holding tanks on a monthly basis. 5. A pump-out log is located on the fuel dock shed, all vessels utilizing the pump-out must sign the pump-out log. 6. The discharge of gray water is currently under review by the State but discouraged while in the Marina. Only Biodegradable soaps and cleaners may be used while in the Ludlow Bay Marina. Port Ludlow MPR Resport Plan Final SEIS 3.113 May 2005 ... I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Item 9 of the Resort at Ludlow Bay Liveaboard Agreement addresses sewage disposal as follows: · Vessels must be equipped with a Coast Guard-approved holding tank. Liveaboards are required to use the pump-out station Monthly. Failure to do so will result in temlination of the live aboard agreement. You will move off your boat or move the boat out of the Marina within ten (10) days of non-compliance. A liveaboard pump-out log will be kept and updated daily. Boats at-anchor in the Bay (both transient and permanent at-anchor) can use Port Ludlow pump-out facilities but cannot be required by Port Ludlow to do so (per existing state and federal laws). 3.7.3.2 Environmentallmpacts Alternatives 1, 2, and 3. and 4 The existing sanitary sewer system, including the treatment plant, has adequate capacity to serve all proposed Resort Plan development alternatives. The Port Ludlow Marina Expansion Draft SEIS (2002) concluded that expansion of the Marina will create an increased demand for sewage pump-out and marina enforcement services. A second portable sewage pump-out facility will be provided as part of the Marina expansion construction project. Alternative 5: No Action No further development within the Resort area would result in no increased demands on sanitary sewer services at this time. 3.7.3.3 Mitigating Measures Proposed (from the Marina Expansion SEIS): · Two portable pump-out carts will be available for use in addition to the existing fixed pump-out facility. · Enforcement of rules regarding discharge of black water will be strictly enforced by Marina management. · The Marina Liveaboard Agreement, Regulations and Policies, and Best Management Practices have been reviewed and revised to address current Marina issues, including discharge of sewage. No mitigating measures are required within the upland portion of the Resort. 3.7.3.4 Unavoidable Adverse Impacts No adverse impacts related to sanitary sewer service are anticipated. Port Ludlow MPR Resport Plan Final SEIS 3-114 May 2005 ~ CHAPTER 4 - DRAFT SEIS COMMENTS AND RESPONSES 4.1 Introduction The Notice of Availability of the Draft SEIS was published on April 23, 2004. The comment period ended on June 17,2004. This section of the Final EIS contains letters of comment on the Draft EIS received from public agencies, tribal governments and private citizens, together with responses to those comments. Because of the volume of letters received and the commonality of many of the comments, the comments and responses are grouped according to issues. The following matrix identifies each commentor, the issues raised, and the title and number of the pertinent response. It should be noted that some comments express opposition or support for the project, rather than comment on specific items of information. In addition to the information contained in these responses, additions, corrections, and clarifications to the Draft SEIS are contained in Chapter 3 of this Final SEIS. Jefferson County wishes to express their appreciation of all commenting agencies and individuals for taking the time and effort spent in reviewing the Draft SEIS. 4.2 Comment Letters Letters Received Commenting on Draft SEIS (Note: Log Item # is shown in parentheses): Public A2encies Letter: Jefferson Count Department of Public Works - Planning Engineer (#166) Letter: Jefferson County Fire District No.3 (#95, 99) Letter: Port Ludlow Drainage District (#164) Local Or2anizations Letter: Port Ludlow Village Council (#176) Letter: South Bay Community Association (#160) Letter: Port Ludlow Lot Owners Association (#169) Letter: Port Ludlow Village Council Development Committee (#176) Letter: Ludlow Maintenance Commission (#189) Port Ludlow Resort Plan Revision Final SEIS 4-' --- I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Private Citizens Ralph Archung (#126) John Armes (#182) R.P. and M.J. Balck (#186) Rosalie Barber (#136) Wayne and Rosalie Barber (#157) Doug Barker (#190) Carol Barnes (#143) Ray Benedict (#104) Marcet Benedict (#183) Vaughn Bradshaw (#178) James Brannaman (#121) Mary Brannaman (#179) Robin Brown (#117) Keith and Maggie Brown (#94) Wayne and Stephanie Buehler (#150) Michael and Hilda Cahn (#130) Tom and Mary Ann Callahan (#100) Daniel and Esther Darrow (#167) Fred DelMissier (#115) Michael Derrig (#172,187) Richard Duce (#135) Delos Dunn (#106) Stephen Faillia (#175) Harvey Fleming (#149) William Funke (#96) Burke Gibson (#140) John Golden (#180) Elizabeth Harmon (#131) Gary and Kathy Hashbarger (#111,114) Bruce and Magdalena Henricus (#153) Robert Herbst (#174) Hill Family (#97) Hugh and Anne Jenings (#101) Lenetta and Bud Johnson (#168) Greg and Pat Jordshaugen (#105) Peter and Jeanne Joseph (#156) Gary and Susan Kaysinger (#108) Frederick King (#162) Frederick King (#181) Edward Knodle (#125) Larry Lawson (#134) Larry Lawson (#165) Larry Lawson (#188) Bert Loomis (#137) Bert Loomis (Log Item #90) John and Lynne March (#173) Bill Master (#110) Richard McDonald (#147) Clarence Miller (#155) Kathleen Muir (#151) Larry Nobles (#109) Mark Pearson (#191) Pat Pearson (#192) Eleanor Peters (#128) Poly Peters (#159) Marian Peterson (#122) Robert and Barbara Phinizy (#129) Don Plorde (#123) Rosalinde Plorde (#146) Powers and Therrien (#102) Powers and Therrien (#171) Powers and Therrien (#184) Powers and Therrien (#194) Gerald and Dianne Purdy (#163) Richard Rozell (#116) Kevin and Susan Ryan (#154) Carol Saber (#137) Douglas Schiebel (#124) Carolyn Schiebel (#127) Bonnie Schoenemann (#141) Grant and Wenonah Sharpe (#145) Cameron Sharpe (#148) Susan and Steve Siegel (#153) Howard and Carol Slack (#177) Teresa Smith (#107) R.E. Sowatsky (#161) Mona Stefflre (#133, 144) Barbara Tipton (#158) Richard Ullman (#113) John VanZonneveld (#118) William Weir (#92) Christine Whitehurst (#142) J. Dwayne Wilcox (#170) Bob Wilkenson (#98) Harvey Williamson (#185) Dale Witt (#152) Dorothy and Allen Wright (#119) Paul and Margaret Yturri (#193) Port Ludlow Resort Plan Revision Final SEIS 4.2 May 2005 ... ------------------- o o 000 o o 0 0000 0000000 o o o I !O o 00 o 00 o o o 000 ~ 0 o 0 .. . .. o 0 00 . . 0 0 ~ 1= . . 0 '. . . . ~ 0 . 0 ~ 0 .. 0 ~ . . n :r a "U^ ...', . CD ., , ,.. .~ . 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MEMO APR 2 1 2DO~ JEFFERSON COUNTY OeD ]JJI ,i!r~ "".",;;f\ ; "Ii" ~_I_ '~~,L..".:f.:"l~\:-~i f"~'J April 17, 2004 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 TV, 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. 1/4.3.1 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. 3.3.3 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. 2 I I I I I I I I I I I I I I I I I I I 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. I I I I I .1 I I I I I I I I I I I I I 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 pennitted development shall begin within two (2) years from the date of this pennit and completion of the pennitted development shall be accomplished within five (5) years from the date of this pennit... 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 Encl: Permit SDP91-017 with conditions Figure 7 A SEIS Figure 7C SEIS Figure 12A SEIS 4 I I I I I I I I I I I I I I I I I I I .i {{\~:r\ \ I l,,7 \ '/ J i'~}";~ . '.. \ '\ ,f' C'"William D. Weir 87 Scott Court I Port Ludlow, WA 98365 I I I I I I I I I I I I I I I I LOG \TEM # q~ 'aoe-L-of-2- Telephone 360.437.4154 Cell 818.292.5111 trellis@ix.netcom.com May 2, 2004 Mr. Al Scalf, Director Jefferson County Community Development Department 621 Sheridan Street Port Townsend, WA 93368 ~.~ flAY -'4 20M JEFFERSON, COUNTY OeD Dear Mr. Scalf, I am writing, as a homeowner and full-time resident of Port Ludlow, to protest the plan to extend the existing docks of the Port Ludlow marina in a westerly direction along the shoreline. My objection points not to issues of water quality or preservation of marine wildlife, but rather to common-law issues of view, personal rights to enjoyment of one's residence, and preservation of property values in the Port Ludlow community. In addition, I will raise issues of marine safety and need for the expansion project. I recently purchased the property at 87 Scott Court, the furthest from the marina of the four developed properties in the Great Scott and Oak Bay Short Plat sections. My property, at the west end of this group of four waterfront properties, on Lot 1 of the Oak Bay Short Plat, is approximately twice the distance from the existing docks as the property at the east end of this group of properties, which is owned by Grant and Lori Colby. It is their property which includes the private dock labeled "Scott Dock" on the drawings for the proposed marina extension, and which bears the greatest impact of the proposed project, however I feel that my property interest will also be negatively impacted. The Scott Court properties are attractive as residences, not because they include a tidal zone, but because of their dominant and unobstructed water views. Having just purchased my property in January, I can attest that my choice of it, and my willingness to pay a price for it which substantially exceeds the value that such a home would have in a non-view situation, depended entirely on its unobstructed water-view. Had the view been obstructed as is threatened by the proposed extension to the marina, I would certainly not have purchased this property, except at a much lower price, and I probably would not have purchased it at all. And please note that my property is the least affected of the four properties of Scott Court. 1/4.3.8 I think it should be very clear to everyone that the view obstruction, increased noise, and water- quality degradation which would be produced by the proposed marina buildout will substantially reduce the value of these properties. And it seems unreasonable to me that a developer should be permitted to pursue a project with this effect without compensating property owners for the losses which they will certainly suffer. There simply has been no legal process here, and we must see this plan as an attempt to seize a revenue and profit advantage for the marina at the expense of area homeowners' property values and these homeowners' enjoyment of their property. Furthermore, this proposed buildout, in front of residential property, seems to violate the planning goal of separation of commercial and residential areas of the community, . 2/4.3.8 Second, it should be understood that the proposed extension of the existing docks toward the Scott Dock owned by the Colbys poses significant marine-safety issues. Over the past three months, I have frequently observed vessels moving into and out of the marina to closely approach the Colby's dock. While the l20-foot "fairway" distance to which EIS reports refer is appropriate for access along the lanes of a marina, it is not a sufficient corridor for access to the primary waterway in my opinion. I hope the Commission will reconsider the practicality of westward extension of the docks as provided in this buildout plan, in the interest of marine safety. Finally, there is a question to be raised about the need for 100 additional slips at the marina. While it may be that 100 slips could be filled, over time, it is not clear that the recreational values afforded the larger community by this extension would be significant. As anyone in the boating community of Port Ludlow knows very well, the levels of use of the boats in leased slips in this marina is very low, much lower than in other Puget Sound marinas. This reflects Port Ludlow's demographics, its affluent and aging population which tends to retain boats which are used less and less by their owners as years pass. The Port Ludlow population can afford more slips than Port Ludlow Bay could ever accommodate, and it makes sense to limit marina growth to a level commensurate with active boat usage. Arguably, the marina is at, and may even at present exceed, a reasonable scale, by this standard. It might be that perceived pressures for additional slips could be relieved by an active brokerage to enable sale of resident boats, which are inactive, by their owners. On the other hand, it may be that some marina growth is inevitable as the community's population increases with further development. In my view the alternative to extend the marina outward into Ludlow Bay, rather than along the shoreline as proposed, would not have the negative consequences which I have expressed above. Residential noise pollution, degradation of water quality, and view occlusion would all be far less with this alternative than with the proposed shoreline extension. Even with this preferred alternative, the residents of the Scott Court properties, and many of the residents of the North Bay Condominiums as well, would suffer slight obstruction of our views, but this impact would be much less than with the proposed plan, and these burdens would be shared more equitably among all residents of the north shore of Port Ludlow Bay. _. I hope the Community Development Department will carefully consider these concerns, and that it will schedule public hearings after May 25, when it will be possible for me to attend. Sincerely, ~LJ~ William D. Weir Copy: Mr. Larry Nobles, Chair, Community Development Committee Port Ludlow Village Council 81 Harms Lane Port Ludlow, W A 98365 I1AY - 4l 2004 JEFFERSON COUNTY OeD I I 3/4.3.8. I I 4/4.3., I I I 5/4.31 I I I I I I I I I 0.,.. "/ 1</' e./ Ie c,- I I I I I I I I I I I I I I I I I ~c ~~''- $ " V \X , May 9, 2004 LOG ITEM # CJLt :..:>aoe I of l Al Scalf, Director Jefferson County Community Development 621 Sheridan Port Townsend, W A 98368 As a tenant of the Port Ludlow Marina I have some concerns regarding the construction project in the Port Ludlow Village area adjacent to the marina. Specifically, with the predominant winds coming from the north in the spring and summer season, airborne dust and sawdust from the construction project makes the maintenance of a 1/4.3.8 clean boat nearly impossible. This might be tolerable if the construction was to be accomplished in a reasonably short time. However, the developer has stated publicly (and has demonstrated in the latest units built) that this construction is intended to be accomplished over a several year period which makes the situation intolerable. Some steps must be taken to mitigate the airborne filth blowing over the marina Some possibilities might include limiting earth moving and framing to the seasons when the wind is predominantly from the south. Another possibility might be the requirement to use tarps to control the airborne particles. There must be other alternatives known to those in the construction trades that regularly deal with this problem. I ~ appealing to you to require some means to control the airborne filth over the marina created by the construction before permitting the construction to proceed. Sinc~,~ I . ';7/" ~y- 17'> ..r- ~.~ Keith & Maggie Brown - 343 Camber Lane flAY 11 2IK JEFFERSON COUNTY DCD Port Ludlow, W A. 98365 15J IE <<: IE D \\9 IE ~ \fl1 .. t I 2004 l!}) . JEFFERSON COUNTY DEPT. OF COMMUNITY DEVELOPMENT M~Y-12-2004 04:13 PM :.. ." PORT LUDLOW FIRE 360 437 9184 Jefferson County Fire Protection District #3 COPlmlJsJoncr Euaene Carmody Chaln..n 0' the Board WaYDe E.. Kler, Sr~ Fire Cllle' Arlene F. ObtlDUlo aid fIDa&(la' OmterlDl.t. Stcretary ffERSON COlJN \.~ . ~.~.. ""r~ ~:. ,.' . .... '1;:". ~. : r F:g~. ~ -':'" . X~!"" Commlllloller David Wheeler COl1lmluloner Roben PODd... CommlJalour Wllllalll It. Hansea CO",IIII..lon.r Mike forter ~:.~, ; ".'1.. ~ ~~ ....... - DISTRICT l'J O. ~ 101 South Point Road, Port Ludlow, Washington 98365 (360) 437-2899 Fax (360) 437-0117 PORT LUDLOW FIRE & RESCUE May 4, 2004 Michelle Farfan, PIaDner Jefferson County Department of CommUnity Development 621 Sheridan Street Port Townsen~ W A 98368 Dear Michelle: LOG ITEM # CfS Page. \ RE: ZON03-000444 Marina ExpansioD Mitigation 1 ;", . . . For any proposaJ. a new dry-line fire suppression system installed at developer's expense into any permanent over-water feature ("'dock" "slip" "tic-up" "float" "breakM1ter") where vessels, boat or ships of any type that are temporarily or pennanently moored. 2. Install a connection between B-Dock and C-<lock to increase access to the floats to and from land, for any proposal except no _action. 3. . Fire hydrants located no more than 1 00 f~t from dry-line fire suppression fire department connectioo Sufficient emergency access provided to docks for emergency responses. 4. Fire call boxes installed on any permanent over the water feature("dock" "slip" '~e-up" "float" ubreakwater") and central walkway. I P.01 '-1 I I I I I I I I I 1/4.3.8 I I I I I I I I I of d lY- :,:6-213134 134: 14 PM PORT LUDLOW FIRE 3613 437 9184 P.132 I I .1 I I I I I I I I I I I I I I I 5. Assurances the fire district has access to key/codes that are simple and quick to use on access gates. 6. The fire chiefhas final approval of the fire suppression system, scope and design. 7. What will happen to the existing fire pumps and if retained as fire suppression system, who will maintain and test the fIre pumps? 213.7.1 Port Ludlow Resort MItigation 1. Living units over the water completely limiting aCcess to one side of the waterside units, how will the FD have access? Mitigation suggests. a man way, I would like to review the . system that is proposed 2. AU living units have approved fire sprinkler system. Living units over the water have exposed underside. There is DO way for FD to suppress a fire Wlder the waterside units. Install. additional a cby fire sprinkler system underside of the buildings over the water for any option. Fire District agrees with thesprinkter mitigation measme. 3. . Fire hydrants no more than 300 feet from any new structure with a maximum of 600 feet between frre hydrants. Include 4-inch sexless adapters installed on large steamer ports as specified by the fire District. 4. Access roads designated permanent fire lane (s)and no curbside puking allo~ at any time. The curbS-painted and stenciled "fire lane" using high visibility permanent paint aJong with signag~. 5. Retail, restaurant and club have approved fire sprinkler System for any option selected. iJ:t;i A-- w~. FlRChicf 15) ~ ~ ~ 0 -\'0 ~ rm lfl1 MAY 1 a D)4 lW JEFFERSON COUNTY OEPT. OF COMMUNITY DEVELOPMENT William G. Funke 75 Scott Court Port Ludlow, W A 98365 May 4,2004 Mr. Al Scalf, Director Department of Community Development Jefferson County 621 Sheridan Street Port Townsend, WA 98368 'MAY 1 ~2UM - ... ~ 'RS~COYNTVDCD LOG IT~ # Cf (0 Page-L-. of A.. Dear Al: This letter is submitted under the provision for Public Comment in the Port Ludlow Resort Draft EIS which process requires reconsideration of the December 31,2002 Final Supplemental Port Ludlow Marina Expansion EIS at this time. Accordingly, it is requested my three communications dated July 25 and July 26, 2002 and September 20, 2000 published in the Marina FSEIS be reconsidered along with the following additional comments and all included in your Findings of Fact for the Resort EIS. It must first be noted the comments in opposition to the proposed marina expansion published in the FSEIS document, including my own, were all afforded published rebuttal by the Developer's agent and these were presumable considered by your department at face value, without addressing further response from the opposition. A significant case in point is the lengthy documented objections and conclusions submitted by Ms. Randi Thurston, Area Habitat Biologist for the Department of Fish and Wildlife who argues against any westward shoreline expansion and recommends two alternatives only: No Action or Deep Water Expansion with additional mitigation. I spoke this morning with Ms. Thurston who was unaware you had ignored her findings in favor of permitting expansion westward along the shoreline as set forth in the new Resort Draft EIS nor has she had opportunity to comment on the developer's rebuttal to her letter. -lO With respedthe developer's response to my previous comments in the Marina Expansion FSEIS: In that neither Mr. Josh Peters nor I could locate the "Alternative -1993 Design" and by the developer's admission it is unknown to what extent this drawing was or was not circulated, I think: it in order you require docwnentation this "drawing" was in fact part of the 1993 additional marina slip consideration. Regarding the developer's other rebuttals to my objections, my determination remains the Marina EIS process was in violation of the MPR ordinances. Finally, it is also noted the Marina Expansion FSEIS does not include statements from the other agencies listed under the Required Permits and Approvals, page FS-2 other I I I I I I I I I 1/4.3.1 I 2/4.3.1 I I 3/4.a.8 I 4/4.3.1 5/4.3.t I I I I I I I --I I I I I I I I I I I I I I than the previously mentioned Department ofFish And Wildlife letter. Doesn't the Department of Natural Resources license the area covered by the marina? Aside from the above stated considerations and irrespective of all ecological or ordinance requirements, the fact that the County has approved under the Marina Expansion Final EIS an expansion in favor of a commercial operator and developer westward that directly negatively impacts and degrades the value of my and of my other Scott Port neighbor's properties is unacceptable to my wife and me. I respectfully request to be included as a stake holder in all meetings and discussions in this Resort Supplemental Environmental Impact Study. 6/4.3.8 It is further requested your office advise me of all appeal procedures and date requirements of the County and State and other authority to stop the westward Marina expansion and protect~ur prop' enjoyment and value. Respect , ...---- / ~-~ 7/4.3.8 CC: The Honorable Pat Rodgers, Jefferson County Commissioner, Port Ludlow Dr. Paul Taylor-Smith, Scott Court Dr. William Wier, Scott Court Mr. Grant Colby, Scott Court , , . I ' " ~ i /Yt1vEi---LD4U ' i Iii i i !~_+--! . i !(fLi rMjLJzt~ik~ i il i 1'.:.1"....+: "i.:~-;,",!.;"t,"! ill. I,. I:,. LOG'Ttl\A I i ;f~, 1/t~kJy)~r.:l'~?J]J1 IU&~ 1; A h80l i I # ' i , ! i ! '~~ Ua !~ ! '~ ;' r 1 Cfll-l I I f~;t%: /f r~Lf 1 i i : : i ~ iJE~FEbdNJoJNrtDJ:oI :'-i~i ;' ~ft': y-l-sfk-1:rllt E~jcH?i. , ! I' I I I ! : I i I i i.!:, i ! !""" IT I I I 'I ! I I r- I I I I I I I i I Ii: I ,,! I I . : j ! 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U ! t : : ! , !~i : I : , i ! 1-2~j~/_~~A.'~-rj!~-20~ j i_ -- : j--+- i I I I I I I I I I I I I I I I I I I I Page 1 of 1 Michelle Farfan From: AI Scalf Sent: Monday, May 17, 20043:09 PM To: Michelle Farfan Subject: FW: Port Ludlow Marina Project. LOG ITEM # CJB Page \ of _~ for the EIS file AI -----Original Message----- From: bob wilkinson [mailto:bobwilkinson@cablespeed.com] Sent: Monday, May 17, 2004 10:49 AM To: AI Scalf Cc: btclark@waypt.com Subject: Port Ludlow Marina Project. Recently, Bill Clark wrote you about his concerns regarding this project, and asked you to require some means of 144.3:.1 control over airborne dust, etc. during construction. I agree with his suggestions, and would appreciate your doing what can be done to minimize the problem. Thank you. Bob Wilkinson 5/17/2004 ~.~!\QID "AY 17' 2Ou; :t.. ~.. JEFFERSON COUNlY DeD May 14,2004 Mr. Al Scalf - Director Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 LOG 'TEM # ll50 Page \ ofl-" RE: Reid Middleton - Supplemental Environmental Impact Statement Dear Mr. Scalf: After reviewing the draft Supplemental Environmental Impact Statement dated April 23, 2004, my wife and I are in favor of supporting the project. We live in Port Ludlow and have a vested interest in seeing the success of the proposed new facilities that are outlined in the report. Along with the two properties we own, we also own a boat and are VERY excited about the proposed marina expansion. 1/4.3.1 The new facilities including a new Harbor Master restaurant, conference center, etc. will greatly improve the entire infrastructure of Port Ludlow. It will create an environment that will make Port Ludlow a unique resort. I 2/4.3.2 I I I I I I I I I We are one hundred per cent behind the proposed project and look forward to its successful completion. Sincerely, ~~ Tom Callahan d1~ Mary Ann Callahan I I I I I I I I I I I I I I I I I I I I I I I I I I I 1-!--"- ~ r~ , ,.-....G.. ; \ \-- \\., LV -. t. w-o-~... Hugh & Anne Jenings SERENDIPITY Slip # E 29 705 Rainier Lane Port Ludlow, W A 98365 "~O' 1:i.; \ ' -- ,. \ nf \ p~ge \___.-.."'-~' , 't...A _._ May 17,2004 Al Scalf, Director Jefferson County Community Development 621 Sheridan Port Townsend, W A 98368 .. 18 20lU , JEfHBJN COUNTY DeD l~ As a tenant of the Port Ludlow Marina who is in favor of the Port Ludlow Village I have some concerns regarding the construction project in the Port Ludlow Village area adjacent to the marina. Specifically, with the predominant winds coming from the north in the spring and Sumln:er season, airborne dust and sawdust from the construction project makes the maintenance of a clean boat nearly impossible. This might be tolerable if the construction was to be accomplished in a reasonably short 114.1.1 time. However, the developer has stated publicly (and has demonstrated in the latest units built) that this construction will be accomplished over a several year period that makes the situation intolerable. Some steps must be taken to mitigate the airborne filth blowing over the marina. Some possibilities might include limiting earth moving and framing to the seasons when the wind is predominantly from the south. Another possibility might be the requirement to use tarps to control the airborne particles. Many construction sites have these problems and these traps are use very successfully in a lot of them. There must be other alternatives known to those in the construction trades that regularly deal with this problem. I am ap ealing to you to require some means to control the airborne filth over the marina created by e permitting the construction to proceed. cc. Larry Smith ort Ludlow Associates 70 Breaker Lane Port Ludlow W A 98365 The Draft EIS does not clearly set forth or contain all of the information needed by me or my engineering firm to conduct the review. There is no clearly delineated base line from which to compare the impact of the project. The plans accompanying the Draft EIS do not show the set backs for the units that have been approved or built and those for which approval is. r~~uested. The Draft EI~ als.o does not114.31( set forth any codes or rules that were adopted subsequent to the InItIal proposal of the project In 1993 that affect, for example, set backs relative either to Heron Way or the lagoon. I did not find information showing capacities of utilities and roadway design as a function of the densities initially proposed for the project. Finally, I did not find a plat plan and S, S, and Ns relative to the existing project in sufficient detail to show where improvements could be located, set backs, or the type of improvements that might be located on the project. The foregoing list is not exhaustive. - 2/4.3.11 4.3.1 I Page 1 of3 Michelle Farfan From: Powers & Therrien [powers_therrien@yvn.com] Sent: Wednesday, May 19,20041:48 PM To: Michelle Farfan Subject: Fw: Port Ludlow Resort LOG ITEM #\O~ Page , ----- Original Message ----- From: Powers & Therrien To: mfarfan@iefferson.wa.us Cc: Powers & Therrien Sent: Wednesday, May 19,20041 :42 PM Subject: Port Ludlow Resort of ~"':, Dear Ms. Michelle Farfan: Jefferson County and Port Ludlow Associates (the "Developers") have provided me with a draft supplemental environmental statement ("Draft EIS") issued by Jefferson County Commissioners that provides for a proposed change in the development plan for Port Ludlow. The Draft EIS concedes that the plan is a major revision from Jefferson County Ordinance No. 08-1004-99 (the "Ordinance"), approved in 1999, that replaced a temporary development plan approved under Ordinance 10-1214-98. Such a change may be approved only by a hearing examiner (Type III) with a public hearing prior to the decision. The criteria for such an approval are set forth in Section 3.906(3) ofthe Ordinance. Response to the Draft EIS is due on May 28, 2004. I am a townhouse owner on Heron Way. I am attempting to review the proposed change. I have retained a civil engineering firm specializing in the analysis of road and infrastructure design to assist me in my review. I hope to accompany my comments to the Draft EIS with a letter setting forth the engineering firm's preliminary evaluation of the Draft EIS as well as the proposed changes. Even to produce a preliminary response to the Draft EIS, I need and would appreciate a copy of the following items: 1. The actual front, side, and back setback requirements imposed by the relevant UBC for the Multi-Family Zone pursuant to Section 3.305 of the Ordinance. 2. A copy of Jefferson County Ordinance No. 10-1214-98 that was replaced by the Ordinance. 3. A copy of the actual 1994 plat plan (plat of Ludlow Bay Village) that was recorded respecting 5/24/2004 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Page 2 of3 the project which shows the total acreage and approved density ofMERU or Single Family Housing. 4. A copy of any waiver, consent, or approval applicable to the conversion of the residential townhouse lot located on the east side of the lagoon immediately north of the hotel to temporary parking and any submissions made in connection therewith. 5. A copy of any waiver, consent, or approval applicable to the conversion ofthe easterly portion of the next lot north of the lot described in Section 4 to parking and any submissions made in connection therewith. 6. A copy of any law, ordinance, regulation, or policy relating to the conversion of the use of any of the project from the 58 residential units (53 townhouses and 5 single family dwellings and the restaurant building to the north of the lagoon to parking and/or residential condominiums. 7. A copy of any submissions relative to closing Heron Way from the hotel and its traffic with a hammerhead and any drawings or plans that reference same. 8. A copy of any information relative to the decision of Jefferson County to approve only 58 of more than 90 residential units originally requested by the then developer for the project including any information submitted in connection therewith. 9. A copy of any study that has been commissioned or made showing the actual effect of the proposed project on the nesting bald eagles that live in the vicinity and are referenced in the Draft EIS, the avarian life that use the lagoon, and the river otters that live in the lagoon and migrate between the lagoon and the bay and Admiralty Inlet over property that will be developed under the proposed project and any remediation ofthe effects of the proposed project thereon. 10. A copy of any law, ordinance, or policy relating to the construction of residential improvements over the lagoon. 11. A copy of any submissions or studies showing vehicular and pedestrian traffic on or along Heron Way and the effect of the project, including the hammerhead thereon, the access of emergency vehicles thereto, the effect of loading, unloading and services thereon, and the elimination of the temporary parking now shared by the residents and the hotel. 12. A copy of the current classification of the lots described in Sections 4 and 5 for real estate tax purposes on the roles of Jefferson County. 13. A copy ofthe current Jefferson County Bicycle Accommodation Policy, if any. 14. A copy of the current Jefferson County Pedestrian Accommodation Policy, ifany. I would appreciate your assistance in obtaining copies of the foregoing materials. I am willing to pay " for any copying and transmission costs. I would appreciate a response from you by no later than May 24th so that I have time to respond to the due date of the 28th. I appreciate your assistance with this matter. Sincerely, Les Powers 5/2412004 Page 3 of 3 POWERS & THERRlEN, P.S. 3502 Tieton Drive Yakima, W A 98902 Phone (509) 453-8906 Fax (509) 453-0745 This email is covered by the Electronic Communications Privacy Act, 18 V.S.C. Section 2510-2521 and is legally privileged. This message and any attachments hereto may contain confidential information intended only for the use of the individual or entity named above. If you are not the intended recipient(s), or the employee or agent responsible for delivery of this message to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this email message is strictly prohibited. If you have received this message in error, please inunediate1y notify the sender and delete this email from your computer. 5/2412004 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Page 1 of 1 Michelle Farfan From: Powers & Therrien [powers_therrien@yvn.com] Sent: Wednesday, May 19, 20042:45 PM To: Michelle Farfan; bturpon@co.jefferson.wa.us; Dan Titterness; Glen Huntingford; Pat Rodgers Cc: Powers & Therrien Subject: Request for information In addition to my previouse email, please forward me a copy ofthe Jefferson County Shoreline Master Program Section 5.160 which specifically prohibits building of "Residential structures located on or over marshes, bogs, swamps, lagoons, tidelands, ecologically 1/4.3.1 sensitive areas or water areas subject to the master program." Thank you LOG 'TEM #- '\~ Page_' of_ \ Les Powers POWERS & THERRIEN, P.S. 3502 Tieton Drive Yakima, W A 98902 Phone (509) 453-8906 Fax (509) 453-0745 This email is covered by the Electronic Communications Privacy Act, 18 V.S.C. Section 2510-2521 and is legally privileged. This message and any attachments hereto may contain confidential information intended only for the use of the individual or entity named above. If you are not the intended recipient(s), or the employee or agent responsible for delivery of this message to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this email message is strictly prohibited. If you have received this message in error, please immediately notify the sender and delete this email from your computer. 5/2412004 LOG \TEtJ! # \G~ Page _\ of 8, ~ ~ ~ ~: : ~ ~ JEFFERSON COUNTY DEPT. OF COMMUNITY DEVELOPMENT \1 \.11'. j ,'J: ';.-' i ~ '1,' ;:~, .. ", < \:.'. ;.-i;' ~t~: - ... t.} ... a(i\..'\-'rse f n ,:j ! \ \- Ie;.; i. ':~:- r.~' ,: (:Ol'}~~,t ft;("tlU n. of' Ii-Ie ?J, Hi. (J EniurriS \\:in prf)cl"L~Ct:~. j\S r~resentiy lra~t\. ~ ~ . , ',' l\ ;3U,-- ,.: \\ ';.:'~; 1< .,' e~~n'~ ;:~l. 1" ~_:: a. j 'n the'ir c:t'i ~;..J d\ 1""; \\B\' ii-';';;, a.r(;~a?,- .~; UT ,.<'rrn:, _~.." C-t.JnstructH) n ,,:,;~ d,' .,: j' d. i~.., .; i ,,,. i~ \'e ,:In l!lCrCJS-f(j \.'_:1'l;J~'~_C:.~' J, ','; ;ni.:: \\.:":: ~.,:a~';j..~(}t ~\rc \ t ;-';(1 i (~n ~. ~ t; \!; -~ ('1 '" R'lr'~ .~~w - I I I I I I I I 1/4.3.1 I I 2/3.3., I I I I I I I I I I I I I I I I I I I I I I I I I I Page 1 of 1 Michelle Farfan From: David W. Johnson Sent: Thursday, May 20,20048:13 AM To: Michelle Farfan Cc: Al Scalf Subject: FW: Port Ludlow Resort Plan Revision - DSEIS LOG ITEM # iDS Page \ of From: Gregg & Pat Jordshaugen [mailto:patandgregg@worldnet.att.net] Sent: Wednesday, May 19,20049:10 PM To: David W. Johnson Subject: Port Ludlow Resort Plan Revision - DSEIS Gentlemen: We are writing to express our concern and disagreement with the plan by Port Ludlow Associates to significantly increase the density of the residential development within the Ludlow Bay Village (LBV) area. No amount of ~:~~~~ ~ci~o T~~~~::~ ~nn~h=~~~~~; r~~~:~~~~~~t~~ ~~~a~h~~I~~0~~e~~pt=~~i~u~~eC:~~t~g9~t~I~;i~I~; 901/3.3.4 residential units was not approved by the county then (and was reduced to 53 town homes and 5 single family 3.3.6 dwellings) for good reason, and nothing has changed in the last 10 years that would make it appropriate to have nearly 100 residential units in such a small area today. Traffic is already a problem at times with just 25 town homes and the Inn. It is dangerous trying to get in and out of the garages (with limited sight visibility), 2/4.3.6 walking in the area without side walks can also be dangerous and will only get worse with more residential construction that brings more cars, more people, and eliminates places to walk without being on the road. Approval of 53 townhomes and 5 single family residences was the right thing answer in 1994 and it is the right thing to hold Port Ludlow Associates to in 2004. We also have some concerns about why Port Ludlow Associates would be allowed to build on lots that would require construction over the pond. We have been told building around the pond is not controlled by shoreline management rules, but we have also been told the county has assessed the lots that are partially in the pond as unbuildable lots for real estate tax purposes. It does not make any sense that a lot is "un buildable" for real estate tax assessed value, but then Port Ludlow Associates is going to be allowed to build over the water and sell the town home at a "water front" premium. We often see otters, ducks of various species, geese, seagulls, and herons in the pond. Allowing construction in the pond is not going to do anything good for the animal habitat. 3/4.3.1, 3.3.3 Gregg & Pat Jordshaugen 34 Heron Road Port Ludlow, Washington 5/20/2004 I I I I I I I I am currently a renting resident of Port Ludlow and an owner of two lots in Port Ludlow, I am building our new home on one of the lots at this time. I have recently reviewed the "Port Ludlow Resort Plan Revision" and I am I very pleased with it. I believe that the new construction and improvements will be very good for our community, I expect the "plan" will improve property values and enhance the community. I see no negative impact in the plan and beli~v~ it to be well thought out and in harmony with the current environment .and ?evelopment. Our new 1/4.31' home will view the new development so I have reason to have been concemed with thiS. . . I heard that some are worried with the increase in unit density with the new town home and Condo's near the . .... . existing Inn. I do not share this concern, I feel that the smaller less expensive units near the Inn and Marina will 2/3.~ attract those looking for a second home or as a destination for their boat trips from other Puget Sound locations. . This will be good for the community and the resort. Page 1 of 1 Michelle Farfan From: AI Scalf Sent: Friday, May 21,20044:39 PM To: Michelle Farfan Subject: FW: Port Ludlow Plan ...G ITEM LU 10la 'aae_, of \ For the DSEIS file AI -----Original Message----- From: Delos [mailto:delos@cablespeed.com] Sent: Friday, May 21, 20044:42 PM To: AI Scalf Subject: Port Ludlow Plan ,,+ tr Dear Sir, I recommend approval. Thank You for considering my opinion. Delos Dunn 385 S Bay Ln Port Ludlow W A 98365 360-437-0377 360-437-0379 (fax) ... 5/21/2004 I I I I I I I I I I I I I I I I I I I I I I I I I I I I Page 1 of 1 Michelle Farfan From: David W. Johnson Sent: Friday, May 21,20044:18 PM To: AI Scalf; Michelle Farfan Subject: FW: DSEIS Port Ludlow LOG \lEM # ,0'1 . .- Page._L._of _.1-- From: TSmith9185@aol.com [mailto:TSmith9185@aol.com] Sent: Friday, May 21, 2004 4:20 PM To: David W. Johnson Subject: DSEIS Port Ludlow I am a relatively new resident living in what will be one of the most impacted traffic areas in the expanded development of the resort area that is currently under environmental review. My unit, 42 Heron Road, will be directly across from the development that will be over the pond. Having only lived here since October in the off season, traffic density and parking are an issue without increased building density. Currently, my garage access is directly into the lane of oncoming traffic. Pulling in is difficult 1(4.3._ without swinging into the gravel across the street. If cars are parked there, this is not possible. If backing out of my garage, alii can do is trust that on coming traffic will see me coming out and yield if necessary as there is no visibility from inside the garage. I try to back into the garage if possible, but traffic and parking does not always allow for this. Parking is an issue as well. I have a one stall garage and was told on purchase that I would have access to an additional space. Today, the parking alternative is across the street where the additional build-out of units will 214..6,;6 occur. I do not understand from the drawings and plans where I will have additional access to parking. Beach access is another issue. Guests strolling the beach are not shy and feel welcome to sit on the porch and peer in my windows. As density increases, access will need to be defined to mark private versus public access.3f4.3.1 My reason for purchasing in this community was to escape the density of an urban setting, not to replicate city life. It is disappointing that once the original build-out of the plans neared completion and demand for waterfront 414/ 02.... has soared, the developers are looking at how they can maximize their returns, ignoring the commitment made to....l ..v.. the residents that embraced the original community design. As a recent investor, it feels a bit like "bait and switch." I request .that the County reject the DSEIS and revisit a plan that meets the interests of the community and the developers. Respectfully submitted, Teresa L. Smith 42 Heron Road Port Ludlow, WA Phone - 206-499-3894 5/21/2004 -The pond is one of the most scenic places in Port Ludlow and this will take away from the entire ambience and quaintness of the marina area. This plan - will have a significant impact on the wildlife who consider the pond their home; Le. river otters, -People :al:::::~::~~:u;::::n:::: :::I:o::dl:a;:~s Ludlow 100::: =~:::lifOrnia. style 2/~jJ development with California attitudes about managing the environment. Port Ludlow Real Estate Agencies (John L. Scott to be specific) consistently advertises that Port Ludlow is a protected "Planned Community" with a well thought out and executed plan that was developed years ago and one of their marketing ploys is "Hurry and buy" because when the defined plan is completed there will be no more opportunities to build in Port Ludlow". I have seen similar advertising in the AlaSka..... A.... Airlines Magazine and Coastal Living. PLA seems to be saying one . thing but doing something completely different. 3/4. . I 4/4.'2 Page 1 of2 Michelle Farfan From: David W. Johnson Sent: Friday, May 21,200410:19 AM To: Michelle Farfan; AI Scalf Subject: FW: Subject DSEIS Port Ludlow LOG ITEM # lOB Page , of ~ From: kaysins@wellsfargo.com [mailto:kaysins@wellsfargo.com] Sent: Friday, May 21, 2004 9:03 AM To: David W. Johnson Cc: kaysins@wellsfargo.com Subject: FW: Subject DSEIS Port Ludlow Attention: Michelle Farfan and AI Scalf From: Home Owners: Gary & Susan Kaysinger (Primary) 46 Heron Dr. Port Ludlow, Wa. (Secondary) 10 Olympic Way Port Ludlow, Wa. We are in total disagreement with the current DSEIS proposal that includes a significant increase in the number of town homes/condominiums around the pond in Port Ludlow for the following reasons: -The population density with the hotel and the existing town homes is already at maximum and by adding the additional condominiums this will stress the entire area. There is already an issue with the number of parking spaces available for the hotel guests and our guests. There is a huge problem with the traffic that goes to the hotel and that will increase with the new condominiums. -PLA is not partnering with the community. They have one goal and that is to improve their cash flow and they have a tendency to take the position that it's "Their way or the highway". There is example after example that supports this comment. The most recent one was when PLA demanded all of the Admiralty I homeowners who were participating in the rental program to either re-model their condo's to the PLA specification or they would not be allowed to participate in the program. 5/21/2004 I I I I I I I I I I I 1/4.31 3.3.6 I I I I I I I I I I I I I I I I I I I I I I Page 2 of2 { Most the owners opted out and so PLA had to disband the rental program. PLA has now lost the ability to have enough room availability to attract the conferences and business groups required to make it a profitable business venture so PLA is now proposing to build high density condominiums which will allow them to increase their daily room numbers. This plan will impact the marina adversely and stress the area significantly. . The real issue is the impact from high density housing in such a small area. This is a planned community with the approved plan in place since 1993. Stick to the plan 1993 plan! If you have any questions please call us at (360) 437-8104 5/21/2004 Mr. Al Scalf, Director Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 RE: Request for time extension of the comment period on the Draft SEIS for Port Ludlow Resort Plan Revision Dear AI, The Community Development Committee of the Port Ludlow Village Council has been working to evaluate the Draft Environmental Impact Statement for the Port Ludlow Resort Plan Revision. We have found this task difficult and time-consuming, in part because of inadequate documentation provided in the Report. In particular, there is no large-scale site plan detailing garages, parking and driveways that will permit us to understand the parking and traffic solutions proposed by the Developer. We ask that we be provided with such a detailed large-scale site plan as quickly as possible. In addition we ask that in accordance with WAC 197-11-455 we be granted a 15 day extension of the comment period on the Draft SEIS. We represent a large number of Port Ludlow residents who are relying on us to do our job accurately and effectively. Ifwe are to serve them properly we need this additional time. Thank you for your consideration. ~. ltJM, Laure~bles, Chair co~:~e~elopment Committee Port Ludlow Village Council I; .1 '0 _ . ..._ .... _., - . -0' n ;' J": ,-~"'" 1 ;\ . J: . \ \ ... : i \ MAY 2 1 2004 : ,::.; i i I i i i \.,"" , \1\ " \ \ I U \'1\ \ \ L~H::~~~~f~'~\';S~~;!~:;'.!V~: ._ _' LOG \lEM #-Loq Page_ \ of3~. I I I I I 1/4.3.11 2/4.3.11 1 I I I I I I I I 1 I I I I I I I I I I I I I I I I I I I I I Michelle Farfan From: David W. Johnson Sent: Monday, May 24,20048:04 AM To: AI Scalf; Michelle Farfan Subject: FW: port ludJow draft supplemental eis LOG ITEM #_' \ 0 Page_ \ of \ From: Bill Master [mailto:master@olympus.net] Sent: Saturday, May 22,200410:03 PM To: David W. Johnson Subject: port Iud low draft supplemental eis May 22, 2004 From: Bill Master To: AI Scalf and Michelle Farfan Page 1 of 1 I do not believe that PLA's proposed additional 30 units for Ludlow Bay Village should be approved. Adding additional units to the previously approved total of 58, creates unacceptable congestion problems. I do believe 114.3.1 that the proposed additional parking for the inn should be approved and is an improvement over current conditions. Thank you for your consideration. 5/24/2004 Page 1 of 1 Michelle Farfan LOG lTEM # II \ Page \ of S From: David W. Johnson Sent: Monday, May 24,20048:03 AM To: AI Scalf; Michelle Farfan Subject: FW: Port Ludlow Resort Plan From: KHashbarg@aol.com [mailto:KHashbarg@aol.com] Sent: Saturday, May 22, 2004 8: 15 AM To: David W. Johnson Subject: Port Ludlow Resort Plan Please find the attached letter regarding our concerns of the proposed over crowding of our Port Ludlow facility. The original letter will also be mailed. Thank you in advance for your review on this matter. Sincerely, Gary and Kathy Hashbarger 5/24/2004 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I May 21,2004 Jefferson County Department of Community Development 621 Sheri den Street Port Townsend, WA Attn: Mr. Al Scalf Director of Department of Community Development Dear Mr. Scalf This is in regards to the Port Ludlow Resort Plan Revision. Weare new homeowners in the Port Ludlow Community. We have only owned our home there for 5 months and do not know what all has taken place previously in 1993, 1994 or 1999. We are not attorneys, politicians or activists; we are merely concerned citizens that value the quality of life in the Port Ludlow Community. This was a major reason why we decided to purchase our home in this beautiful area. We reviewed the voluminous Environmental Impact Statement located at the Beach Club and were totally overwhelmed. This was not written to clearly communicate with the people. To us, a statement about the "environment" should include all aspects of the area in which we live. It should talk about the waters, the wildlife, the vegetation, the parking, the traffic, noise levels, pedestrians and the maintenance of the style already established. 1/4.3.10 And, it should do so in a clear, straightforward manner so plans and policy can be understood. We could not discern from the EIS how the proposed changes will maintain or enhance 2/4.3.10 the "livability" ofthis great community. - We read ofthe impact to roads outside the Port Ludlow Resort, but what about the streets within the Resort? This is where there will be tremendous problems with the increase in automobile/pedestrian traffic. The width and configuration of the roadways throughout the Village/Hotel area are barely adequate for two cars to pass. Increasing the current 313.3.6 population density as proposed would burden our roadways way beyond what they appear to be capable of handling. How will anyone be able to back out of a garage onto these roads with back-to-back driveways without hitting another auto or person walking by? It is already an area of concern for us without the addition of the proposed units. Has anyone from the Community Development Department come by to actually view this situation? It is not acceptable. Which brings up another issue, security. Who is going to monitor/police this influx of 414.3.11 new problems? With the huge population increase, there is undoubtedly going to be more fender benders and car/pedestrian accidents, not to mention home security issues, (i.e. property damage, thefts). Are we going to rely on what appears to be an already burdened county system? And from where is this assistance coming from, Port Townsend? This hardly seems adequate protection. Are the increased tax dollars that already spread so thin going to accommodate the additionally needed support? Where are these issues addressed? The subject of parking has been our concern from the first time we came to Port Ludlow. We have been reassured over and over this would not be a problem. We were told the county guidelines provide for so many parking spaces per dwelling on top of what is needed for the commercial areas. If this issue was addressed and we did try to look for the answers in the EIS, we totally missed it. We have not lived through a summer here but have seen what weekend traffic brings. In talking to the hotel on trying to book an event in September, we were told most weekends are sold out through mid September. We cannot imagine where even these people are going to park. Add more residences, add more slips in the marina, add more and more and more, and where will we put them? It is very discouraging coming to Port Ludlow and finding it on the verge of over extending without a good sensible plan. Weare not opposed the continued development ofthis area, but it must be done right. More is not always better; in fact congestion does not create a better lifestyle or increased business income. It actually can be blamed for the demise of cities that were once considered, "most livable." Please do not approve a plan with so many obvious flaws. Please talk to the people of Port Ludlow and develop a plan that will be better for all and will take us peacefully into the next several decades. Sincerely, cS!Jtnp tDld GJ&thp ~hbtrr5er Gary and-Kathy Hashbarger 38 Heron Road Port Ludlow, WA 98365 I I I I 5/4.3.61 I I I I 614.3.2 I I I I I I I I I I I I I I I ,I I I I I I I I I I I I I I Page 1 of2 Michelle Farfan From: David W. Johnson Sent: Monday, May 24,200410:05 AM To: AI Scalf; Michelle Farfan Subject: FW: Port Ludlow EIS G1T,......M.j LO 1,. C. # l\~ Page \ of~ From: Richard Ullmann [mailto:rullmann@olypen.com] Sent: Monday, May 24, 2004 9:28 AM To: David W. Johnson Subject: Port Ludlow EIS Dear Mr. Scalf and Community Development Staff: I am writing on behalf ofthe Natural Resources Committee - a committee ofthe Port Ludlow Village Council. The nature of the work we do for the community is focused on the environment in and around Port Ludlow and we continually look for ways in which we can contribute to the wellbeing and improvement of our natural resources. We do not intend to critique the draft EIS line by line. Others, I'm sure, will take on that task, and your office will undoubtedly investigate and deal with multiple issues related to the input you receive. Our purpose is to raise one environmental issue that is at the heart of our concern. In our view, it needs clarification. This issue is about the health of the bay! The developer's plan will create additional 1/4.:3,4- impervious surfaces and an increase in water runoff that may contain pollutants headed for Ludlow Bay. 3.3.2 The EIS speaks clearly about the development in Ludlow Bay Village and proposes mitigation plans for runoffby mentioning new storm drainage systems in Basins A and B, water quality vaults, and "residence" time in the lagoon before being sent to the Bay. Based on the generalities in the report, however, it is not clear to us how any of this water is being treated before discharge. Treatment, via marsh lands, sewage system, or other means unknown to us, is immensely critical for the health of the Bay. The monitoring of that health becomes even more critical. Will water quality testing be expanded? Will baseline data be established to determine the health, size and distribution of the animals and organisms that irihabit the Bay? Weare raising this issue in the hope that your office will be particularly sensitive and insistent about adequate treatment solutions to the increasing water runoff as a result of the new construction. Seattle METRO has had significant problems resulting from stormwater runoff into Puget Sound. We could have similar problems here. Our source area is much smaller but so is the receiving water body, Ludlow Bay. When we think of the health of the bay we are already aware of the deterioration of the waters in Hood- Canal and we wonder about the water environment in our own area. In Ludlow Bay, shellfish harvesting has been declared unsafe. Coho and Chum Salmon - spawning in Ludlow Creek - are dependent on the Bay for their sustenance, as are many organisms that make their home in the Bay. Summer run-off from 213.3.2 the lagoon -laden with algae bloom - has the potential oflowering the oxygen content of the Bay. The algae problem is exacerbated in the summer because there is so little rain that the retention time is lengthened. Artificially increased circulation in the summer could reduce retention time, temperature and occurrence of low dissolved oxygen. 5/24/2004 I I I I I I I I I I I I I I I Page 2 of2 I Grassy areas were once considered a mitigating factor in controlling runoff because those areas could I soak up rainfall. In this plan, much of the grassy area will be replaced by roofs, paved streets and parking lots. This has already resulted in the displacement of ducks, such as widgeon, that used to come in large numbers to eat the grass. I Our primary question: How will the Bay be protected as this building plan proceeds? Protections are alluded to in the EIS statement, but they are not specific enough - in our reading- to give us comfort. 3/4..3.11 We would ask that your office take a careful look at all the guidelines, specifications and laws, related to < water health and insist on conformance to the latest state and federal guidelines for control and treatment of runoff in shoreline areas. In the final report, make it clear to the developer and the community what is expected from all of us in order to maintain this fragile environment.. Thank you for this opportunity to react and offer our input to your office. Sincerely, Dick Ullmann Natural Resources Committee 5/24/2004 I I I I I I I I I I I I I I I I I I I JEFFERSON COUNTY COMMUNITY DEVELOPMENT DEPT. 621 Sheridan Port Townsend, Wa. 98368 May 20, 2004 Re: Revised Port Ludlow Resort plan Attn: Department Chairperson It is my understanding that the above referenced resort plan adds approximately 50 residental units to the 1999 plan which was in effect at the time we purchased our townhome on Heron Road. The addition of the 50 units would have the following adverse impact on the value and livibility of our townhome. 1. Traffic and parking problems are aheady in evidence. The additional traffic created by adding 50 units may well bring these problems beyond county requirements. 2.Changing from townhomes to condominiums creates a more transient occupancy which typically results in a lower level of maintance. 3. Any additional use of the shoreline area in front of the existing townhomes would , be detrimental to a fragile ecosystem which is aheady being abused. 4. The revised resort plan would obviously maximize the profit margin for the off-shore owners, but at the same time it would greatly reduce the pleasure and tranquility of living fu this area. '- Respect~y; lh, ~e~~r ~~ # 14 Heron Road Port Ludlow, Wa. 98365 ~~ ,MY 2'4 20M LOG iTEM # \\5 ?age \ of L_.. JEffER5{):~ COUNTY DeD 1/4.3.6, 3.'3.6 214.3.2 314.3.7 4/4.3.2 Page 1 of2 Michelle Farfan From: David W. Johnson Sent: Tuesday, May 25, 2004 10:56 AM To: AI Scalf; Michelle Farfan Subject: FW: DSEIS for Port Ludlow ., {'\G l'E' M L"..; , I 1 \ LP :.Jage~Lof 8. :fi ;1 From: RR2DP@aol.com [mailto:RR2DP@aol.com] Sent: Tuesday, May 25, 2004 10:47 AM To: David W. Johnson Cc: bertl@cablespeed.com Subject: DSEIS for Port Ludlow After a intense review of the DSEIS report, I find that it is typcial of the work coming from your office. Very poor in content and most likely failing even to meet the legal requirements for a DSEIS Report. There are so many errors in this report as well as omissons, I do not know where to start. I I I I I I I I 1. With no baseline in the report from which to jude the proposed revisions, it is extremely hard to determine :~~~~~~;~g fl~,:epla~~ ~~:~~~ ~~J;~~~s~fa~::~~~u~:~~~~i~~S e~a~~t';,';~~~ru.~:'D~~~.WingS with elevations~/4.3. 11 2. The use of 12 year old on impact to our enviromentally sensitive or threatened species and habitats within PO: L::O:a:::::a::::~;:'::~~~;:=:yr::::~: :~~:I~:~: :::::::rt ~:yai:::~ upon roads w~hin fue 214.3., Resort itself, involving bike traffic or auto traffic. Especially lacking is the impact it will have in the area of the 3/4.. ~.6, marina, hotel, and restaurant. 3.3.1 4. In regards to Density within the area of the hotel and marina. Attempting to build even the amount of homes , ,'.. '. ... previously approved will simply make this entire area a quagmire of traffic, people, parking, and reduce the value ,4.3~2, of not only the homes located currently in that area but homes all over Port Ludlow. 4t3. S..t 5. In regards to parking. This plan does not address parking sufficiently and will never be able to address this problem given the amount of new construction PLA is seeking. With the increase in size of the marina as well as/- moving the restaurant, a new club, marina office and retail area, there will be no place to park for visitors or 514.3.1' marina patrons who have boats in the marina and wish to carry items aboard. The overcrowding in this area will simply make using-the factilies so difficult that people will eventually become discouraged and stop. This will in turn reduce the value to every building in this immediate area and then to the rest of the village. I 6. This report is limited to only having imput from the Developer (PLA). There is no imput from the Fire . .' " ,',. . '., Department, Fish & Wildlife, from any of the HomeOwner Associations in Port Ludlow, especially the Townhome 714..3.10 :;;S:~~~i~~~C;:~'::: ~~~a:~~to the hotel. or from any of our community leaders. This is just typical inept style oI .:: .: ; ,I: 814.3.lb 7. Also, it is clear that no one from Jefferson County Community Development made anyon-site visits to verifY any of the information in this report. Again typical of work done from this office. I 8. Jefferson County has no responsiblity to PLA regarding the economical viability of their investment. This is914.3.2 not in anyway be a consideration by any govermental agency. 'I 9. The last thing that I wish to address is the increase in stormwater runoff. Again, we have a Water drainage district on the North side Port Ludlow, yet they were not consulted during the making of this report, nor were the 1013 3j'. effects of increased stormwater runoff given anywhere in this report. . 5/25/2004 I I I I I I I I I I I I I I I I I I I I Page 2 of2 The above nine items are just the tip of the iceberg as what is wrong with this report and what the developer is asking for. I would just like to say in closing that I believe this report does not meet the legal requirements of a EIS report and should be considered invalid for the purpose intended. With all the major flaws it shoud never 1114..3.1tl have been even considered as sufficient. Richard L. Rozzell Resident, Port Ludlow, WA 5/25/2004 . ~f"", f1-t::r\rl LV\.:j at;"...\'<" # \ \'l ----- '\ n$ ,,"1 Page __---,..,.,i-1;JL May 21,2004 ~j~ ~.:-::'... ~..~. Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 ""25200; JEFFERSON COUNTY OeD Attention: Mr. AI Scalf Director, Department of Community Development Re: PLA Proposed Develapment - nr.aft.Environment~ 1 T mpact Statement Dear Sir: As an owner oran Admiralty n .condominium I b~came deeply 'disturbed whenI re~d'the DSEIS for the Port Ludlow Resort Plail revisiOD- 'It coniaiils :riuuiy errorS; .omissio~.and there is no consideratioli given to the safety probleinfit' would deatefor'manfoflls. ' Parking . " The DSEIS says that there will be two off street parking places pertini(but in actuality one space will be behind the other. 11 is only logical to assume that soon caFswiUbe parking on the street making it dangerous for ingress and egress not only for us but for emergency vehicles as well. The DSElS also states that PLA has alCase .agreement with LMC for the use of 56 parking spaces, but that is not the case. They only have the use of 28 spaces and that lease expires January I, 2013 and LMC does not intend to renew it. That means that overflow parking will encroach on the Admiralty II parking area as well as onto the street, thus making the street even more cO!lgested and hazardous. Environmental Impact The DSEIS has a glaring error when it says that there are no eagle nests in the West portion of Port Ludlow B~:!y; There isn't a day when I don't see a minimum of two fly by. Last spririg I knew ~xactly where one nest was. If they destroy this nesting area they will not only be destroying a breeding area but our very quality of life here. Open Space The'DSEIS proposes 'to'eliminateoillbpen space where the FLA consfiucted wonderful, recreation facilities but fails to say they will be:replaced:' This:open'space is used by an Port Ludlow residents. The DSEIS also asserts thafthe lawns or. Admiralty iI are open I I I I I I I I I I 1/4.3.6 I I I 214,3.' I I 314.3.5, I I I I I I I I I I I I I I I I I I I I I spaces that can be used by others. That is absolutely not true, they are the private property of the Admiralty II owners. We want to know how they plan to keep them from being encroached upon by others. Landslide Hazard - Medium Risk My greatest concern, however, is the increase in water runoff We already have so much water drainage from the meadow above us that water in constantly coming up through the parking lot asphalt. There is no doubt that adding significantly more hard surface will only compound the problem and put us in danger. The DSEIS does not adequately address this very serious issue. What happens if we have an earthquake or landslide? Those of us living along the shore would be in great peril! How does the DSEIS pr.opese to ensure our safety? Would they compensate us for damage or loss? There are many more examples of errors, omissions and lack of research in the DSEIS draft. I ask you, no I beg you, to reject the DSEIS entirely. Sincerely, Q.-L~ ,J ~ Robin S. Brown Admiralty II owner ~~~ MAY 25 aIM JEFFERSON COUNTY OeD 4/3.3.2 May 12,2004 # \ \el Page_ I of ~__ I I I I I I I o \,'-1\ i" LO\.,? \ r t,:,l\fl To: Jefferson County Dept. of Community Development 621 Sheridan Street Port Townsend, WA 98368 HAY 25 200+ JEFFERSON COUNTY OeD Re: Draft SEIS - Port Ludlow Resort Plan Revision We take exception to certain comments contained in the DSEIS for the Port Ludlow Resort Plan revision. As Vice President of the Ludlow Maintenance Commission and as a full time resident of Admiralty II Condominiums it is my intention to limit my remarks to the proposed Admiralty III. I. Surface Water to be Contained in Basins A & B There is currently year around seepage and drainage from the meadow above Admiralty II into our lower parking areas, with water pushing its way up through seams in the asphalt. What will happen to the additional surface water and how much will be added to existing drainage problems in Admiralty II? No consideration appears to have been given to overflow of a retention basin from earthquake, landslide or other events which could be destructive tour property and dangerous to our residents. 1/3.3.1 4. Beach Club The Beach Club is not a conference facility as stated in the DSEIS. This is a private facility for members and guests of the Ludlow Maintenance Commission. 4/4.3.2 I I I I 21....3.5 I I I I I I I Admiralty I and Admiralty II and the proposed Admiralty III are known to be in an area of "Landslide Hazard - Medium Risk". Adding even more hard surface and run ofIwill create an area of even higher risk and the greatest risk is to residents of AD II living closer to the shore. 2. Open Space Building stacked flats for Admiralty III will eliminate all present open space in the Resort Area. The DSEIS fails to mention that a playground will be eliminated, a volleyball court, horseshoe pits and a basketball court will also be lost, as well as a walking trail from the Conference Center along Olympic Place. The DSEIS mistakenly calls the lawns of Admiralty II_ open space but we are a private condominium complex. At present only 35% of the owners rent any part of their units. The DSEIS states that events like weddings may be celebrated on Ad II lawns. This is made in error. Admiralty II has no business relationship with the PLA Resort. 3. Bird Population Again the DSEIS is in error. A number of eagles roost west of Ludlow Bay. Ad I and Ad II residents see them every day of the year. The elimination of their nesting area will do severe damage to the population. 3/4.3.4 I~ I I I I I I I I I I I I I I I I I I 5. Creation of a Private Recreational Facility If ever a proposal was made to try and cause problems in a community it is this attempt at social discrimination. Already there are numerous different organizations within the community struggling to maintain facilities. We positively resent addition of another method of splitting the Port Ludlow community by establishing yet another private . "- .. membership facility. 6. Outdoor Recreation Areas The PLA proposal and the DSEIS do not provide any replacement of the recreation area being eliminated as noted in Item 2 above. Where do these proposed new resort residents go to enjoy the outdoors in Port Ludlow? There are no green spaces for leisure, walking or relaxation. There are no outdoor sports facilities, no basketball court, tennis court, no benches or even walking paths. None of the facilities that constitute a resort are being provided. 7. Parking The very worst possible impact will occur in the Admiralty III proposal where every flat will have two outdoor parking spaces, one behind the other. Very soon the cars will be lined up along the street and in the property of Admiralty II. Street parking will prohibit ingress and egress for emergency vehicles and local traffic. 8. Master Planned Resort DesiDnation I call your attention to the description in the DSEIS - page 3-53 of Master Planned Resorts. With this project PLA will totally change the Jefferson County Plan for Port Ludlow from a resort to an urban area 9. Protection for Residents Admiralty II needs protection from the impact of 39 new housing units adjacent to our property. Those new Admiralty III residents will have no open space of their own. They will have purchased property in Port Ludlow with the expectation of enjoying the shoreline, walking paths and views they see here. We request PLA be required to install a fence along our joint boundary, ornamentally designed and including an entry gate for vehicle traffic into Admiralty II for the protection of the privacy of our residents. Yours Very Truly John Van Zonneveld PO 6$477 Port l--lldlpw. 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May 20, 2004 MAY 26 2004 Jefferson County Department of Community Development 621 Sheridan Street Port "Townsend, WA 98368 JEFFERSON COUNTY OeD Subject: Draft Supplemental Environmental Impact Statement (DSEIS) For Port Ludlow Resort Plan Revision Attention: Mr. Al Scalf Dear Mr. Scalf After a thorough review of this document I am dismayed to find that our county planning officials would accept a report as flawed and incomplete as this one. There are many discrepancies and important omissions. The State Environmental Protection Act requires that an EIS "must be prepared in a professional manner with appropriate interdisciplinary methodology". Significant errors and omissions which need to be addressed include: 1. Where is a comprehensive, detailed analysis of parking and traffic flow in this high density area complete with a summary oflegally required parking, and a realistic discussion of access and availability? 2. Little information on the specifics of the proposed buildings Including dimensions, floor plans, and elevations are provided. It is almost impossible to understand exactly what is included in the project. 3. Practically no information; on the locations of the various buildings and how they relate to the streets for access. 4. Incomplete and error filled site plans, Marina plans, and other diagrams. 5. A confusing discussion of this proposal as a destination resort when all evidence indicates that it is nothing more than a high density housing development. Specific comments and questions follow: Comments on the ~'preferred project" Page 3-43 through Pages 3-50 1. Building layouts are shown for only one of the proposed buildings R-8. Where are the layouts for R-I through R-12? 2. Figure 12B shows elevations for type I and type II units. Where are the elevations for a type III unit? 3. Why is the restaurant building on figure 12B shown combined with the marina office? This does not agree with the site plan figure 3B. 4. Only the Trail Plan Figure 13 shows the location of the various buildings and then barely readable, by area number. Why are these not shown on the site plan figure 3B? Which is the governing document for the EIS? LOG ITEf\A #~ Page ----1- ot~ I I I I I I I I I 1/i~..~ 2/4.3.11 3/4.3.11 4/4.3.10 5/4.3.21 I 6/4.3.1, I I I I ~ I I I I I I I I I I I I I I I I I I I 5. Which building houses the facilities for the Marina i.e. Laundry, showers, bathrooms. Comments on Parking and Traffic: 1. Where is a summary of legally required parking spaces? A review of Section 6 of the county development standards along with reasonable estimates of what would 714.3.6, be required by the administrator reveal that a minimum of 45 spaces should be provided for the three new buildings on the water. Why does; the site plan only show 18? Does the plan allow for the 190 parking spaces which will be required for marina users? 2. The residents in R-1 on Pintail will not park tandem In their driveways since parking will be available for their 8 additional cars in the marina lot. 3. The site plan shows an elevator for access to the upper parking lot but it is not referred to in the text of the EIS document. Is this r~lly going to be provided? 4. The EIS states that at busy times the public will park on the streets. At present no parking is allowed on Gull Dr. for fire truck access. At least 45 driveways from the new dwellings will intersect the streets. Where is a detail accounting of the street parking claimed by the EIS? S. Considering emergency vehicle requirements, will on street parking be allowed on Heron Rd., Gull Dr. , Widgeon, Pintail and the llnTUtmed street behind R-S and R-6? 6. Why does the EIS not address the subject of what is a reasonable distance for regular users of amenities to travel on foot if the site is properly planned? Comments on the Site Plan Figure 3-B 1. Why is only one street labeled? Why not Show Gull Dr., Widgeon Rd., and 8/4.3.10 Pintail. 2. Are the proposed new buildings to scale? They appear to be artist renderings with no useful information to the reader. Since parking is a critical issue and driveways will be used, why does the site plan not show them for each of the dwellings? Driveways will have a significant impact on available street parking and must be shown since it is probable that the residents will park their extra cars in the street rather than in the driveways. 3. Why are the buildings not labeled with area numbers shown on the Trail Plan Figure 13? Are these locations correct? 4. What is the street access for units in area R-2? S. What is the building shown between area R-4 and R-5? Is this a residence? 6. What are the buildings within R-6? Are they all alike? No driveways are shown. Are these units equipped with two indoor parking places for each dwelling unit? Are there in fact 14 dwellings in this area and room for 28 cars? 7. What are the dimensions of the street leading in to R-6? Is the area in the street in R-6 adequate to accommodate the 28 cars to operate and provide access for fire trucks? LOG ITEf\J1 # l~l Page ~ .-.o~ ~~ -' Comment on the Proposed Recreation Center: This 7500 sq.ft.facility will be available for the exclusive use of the LBV residents (62 dwelling units), the guests of the 37 room hote~ and the people on boats in the 48 guest slips in the marina in the summer months. A conservative estimate ofthe cost of this building is probably $750,000. It is certain that PLA would expect that the cost to maintain, operate, and amortize the investment in this building would be born by the users. The current residents ofLBV (25 owners) are already members ofLMC and enjoy the use ofthe Beach Club for recreational uses at a cost of$4oo per year. We can see no reason why tbese residents would be willing to assume the burden of an additional Club facility. The covenants and regulations applicable to all of the present undeveloped lots (33 Platted) provide that the purchasers of these properties will become members oftbe LMC and users oftbe Beach Club amenities for $ 400 per year as well as the current owners. Ifall the proposed new dwellings are constructed, under the present CC&R's every owner ofthe new units would become a member of the LMC and a user of the Beach Club unless the developer seeks to aher the language in the current Plat documents to remove this privilege. What is the rationale for providing a new recreational club fucility when one is already available and bow could it possibly be supported financially by only 62 owners, a 37 room hotel and 48 visitor slips in the marina which are only used during the summer months. It would seem that this facility is included in this proposal to support the myth that this a destination resort project when it is in fact simply a high density housing project. The economic reality is that this building can not be justified and will never be buih. In the light oftbe obvious shortcomings of the EIS document it should be rejected and retmned to the proponent for a complete reevaluation. This high density project has so many adverse impacts that it will not be accepted by the Port Ludlow community. The community wants a tasteful, thoughtfully crafted development in the Marina area that we can enjoy and be proud of long after PLA has left. ::)~- ~ James M. Brannaman / / 563 Pioneer Dr. / Port Ludlow, WA 989365 ~ LOG !TEM # lJJ. Page 3, of-3 .. ~ I I I 9/4.3.' I I I I I I I I I I I I I I I I' I I I I I I I I I I I I I I I I I I May 24, 2004 Mr. Al Scalf, Director, Department of Community Development THE DRAFT SEIS As a long-time resident of Port Ludlow I am very concerned about the lack of quality and of significant errors in the SEIS report. The increase in residential unit density is definitely not wanted nor is it consistent with the needs of the community. It is obvious there is not adequate parking when it is shown the reports are erroneous as to the parking available. A major concern is stormwater runoff as a result of the proposed plan. All who live in the Admiralty II area are aware of the seepage and drainage from the meadow above. so, too, are we aware of the landslide hazard. Many of the amenities which attract families and guests to this area would no longer be there! We are also acutely aware of the Eagle population as one of the great pleasures is to watch them each day. Again, a serious error in the SEIS report is that the Beach Club is a conference facility. This is a private club belonging to owners of property in this area (North Bay) of Port Ludlow. We who live and play in this area sincerely request that this plan be completely rejected and a plan that will be ~cceptable to all be developed. sincerely Jr[~~J Marian Peterson Resident MAY 26 20M JEFFERSON COUNTY DeD LOG lTEiVi # J.Ol~ pageJ-ofJ--,,- 1/4.3.2 2/4.3.6 3/3.3.2 4/4.3.2 5/4.3.4 6/4.3.2 I think that the plan is tantamount to creation of a high density residential area consuming a great deal of the .i/ . '....J Open Spaces in the area of this Village, the Beach Club and the Marina. This is inconsistent with the heretofore 1/4.3 development of Port Ludlow which has stressed open spaces, recreational areas and, as far as physically 43<3 possible, maintenance of views - be it Ludlow Bay or the Olympic Range. A more logical approach, although . . totally unacceptable, would to be to build a multi-story condo facility with adjoining multi-story parking ramp that I would retain more of the open space than the proposed plan. I truly believe that no-one in Port Ludlow, with the possible exception of PLA, will be happy with the results if this plan is approved and proceeds as currently constituted. The existing home and condo owners will be unhappy and the potential new unit owners will ultimately be unhappy with the result. Other Port Ludlow residents outside this immediate area will be unhappy when property values of all Port Ludlow homes, more immediately the Ludlow Bay Village homes, decrease with the adoption/completion of this plan. The open areas in the Ludlow Bay Village areas will virtually disappear, the Marina and Bay Club will suffer because of lack of adequate parking, and the existing restaurant(s) will disappear or decrease in size. This hurts all of Port Ludlow and will greatly and negatively impact property values, eventually. How this will attract more outside tourists, a rationale touted by PLA as a driving force for the plan, is a mystery to many Port Ludlow residents. PLA may outsmart themselves when they go to sell their Port Ludlow Resort and other Port Ludlow properties when they exit the community (already announced). Potential buyers will realize that the value of what they purchase is far from what it could have been without this ill-conceived development. Apart from the overview I offer as criticism of the plan, there is the DSEIS itself. I am impressed with the blatant 1')/,,'" ,3...',11". "hand waving" approach that PLA, and their consultants, used. There is no detailed assessment of IMPACT. As~ 9'.\.. a scientifically traiAed person who worked in the chemical industry throughout my career, I can positively state that such a poorly thought-out, researched and written plan would be laughed offby the decision makers. Hopefully those involved and responsible in Jefferson County will see the plan for what it is - a disaster. Page 1 of 1 Michelle Farfan From: David W. Johnson Sent: Wednesday, May 26,2004 1 :55 PM To: AI Scalf; Michelle Farfan Subject: FW: Port Ludlow DSEIS From: Don Plorde [mailto:donp@cablespeed.com] Sent: Wednesday, May 26,2004 1:33 PM To: David W. Johnson Subject: Port Ludlow DSEIS I would like to comment on the DSEIS recently submitted by Port Ludlow Associates (PLA) for the expansion of Ludlow Bay Village. Don Plorde 55 McKenzie Lane Port Ludlow LOG ITE/Vi #J~3 . ._ Dage-1__otl__ 5/26/2004 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Michelle Farfan From: David W. Johnson Sent: Wednesday, May 26, 2004 2:52 PM To: AI Scalf; Michelle Farfan Subject: FW: Port Ludlow Resort Plan Revision From: Sheebell@aoJ.com [mailto:Sheebell@aoJ.com] Sent: Wednesday, May 26, 2004 2:47 PM To: David W. Johnson Subject: Port Ludlow Resort Plan Revision ATTN.: AI Scalf, Director of Community Development I would like to register some concerns regarding the adequacy of the DSEIS supporting Port Ludlow Associates' plans to expand its resort and marina facilities, as follows: Page 1 of 1 1. Provisions for the likely volume of parking needs seem quite inadequate, setting the stage for streets too clogged with parked cars to allow emergency vehicles to pass through. Clogged streets and lack of parking spaces will also, of course, reduce the pleasure of visiting the area or to tI4.3.6 make use of its new amenities. 2. Planning for Increased storm water runoff due to the replacement of open lawn areas with asphalt or roofing fnec~;:s~~::~~~t~f ~~~nS1i~~~.stage for a gradual silting up and contamination of LudlowBay. It may also 213.3..2 3. Esthetic impact of high density condominium developments not addressed. Mass of new buildings will inevitably block the general public's view of the bay and the marina from Oak Say Road. The attractiveness of 314.3.3 the community as a whole, and with it its property values, are likely to deteriorate if the new core of Port Ludlow turns into an impenetrable fortress. In view of the above, Alternative 3, i.e. negotiating a vastly scaled down development plan with Port Ludlow Associates, would seem to be the most responsible future course of action to take, if not a strict adherence to the presently approved platting of 1994, or Alternative 2. Respectfully sUb'!litted, Douglas Schiebel 192 Seaway Place Port Ludlow, WA 98365 LOG iTEM # Page~of 5/26/2004 I I I I I I I I I I I I Page 1 of2 .". Michelle Farfan From: David W. Johnson Sent: Thursday, May 27,20047:58 AM To: AI Scalf; Michelle Farfan Subject: FW: Port Ludlow Associates DE IS for Resort Area From: Edward Knodle [mailto:edknodle@earthlink.net] Sent: Wednesday, May 26, 2004 7:45 PM To: David W. Johnson Subject: FW: Port Ludlow Associates DEIS for Resort Area ----- Original Message ---- From: Edward Knodle To: DevelopementReview@Co.Jefferson.WA.US Sent: 5/25/04 8:34:27 PM Subject: Port Ludlow Associates DEIS for Resort Area Dear Mr. Scalf; My wife and own a home in the South Bay portion of Port Ludlow. We moved here in December, 1996 and have enjoyed the magnificent environment that attracted us here to retire. We have been here long enough to have been involved in the involvement of the community in the planning of the build out of this community by Olympic Resource Management - the previous owner - and we have seen the proposed changes being put forward by the new owners Port Ludlow Associates. We have serious concerns with the proposed changes in the resort area as detailed in the DSEIS currently under review by your office. Weare very concerned with density issues and the number of residential units proposed for construction in what is not only a very attractive part of this community but in such a small area. The plan that was approved in 1994 is a much better use of the available land and helps to maintain the most appealing features of the resort area. The Resort at Port Ludlow has become little more than a motel for those who want to get away for the weekend. This has occurred because the developer made a business decision to effectively exit the resort business in favor of residential construction. This is fine. There is plenty of available land within the MPR boundary to build very fine homes that would not detract from the natural beauty of the area. Please do not deviate from the 1994 plan. Weare also concerned that if you were to approve the increased density in housing in the resort area that serious traffic and parking issues will occur on the interior roads of the area being developed. The could be issues of life safety with the limited street LOG ITEM # lZ-~ 5/27/2004 Page t of-L. - .4 1/3.3.1 I I 2'-4.3.2 I I 3/4.3.1 3.3.6 I . I I I I I I I I I I I I I I I I I I f Page 2 of2 access in that area. Finally, we strongly object to the proposal to build residences over the pond. This is 4/4.3.1 simply not acceptable and frankly destructive to the attractiveness of the resort area. Again we urge you to disapprove the PLA proposal and let stand the 1994 plat design. Sincerely, Ed and J an Knodle 121 S. Keel Way Port Ludlow, W A 98365 --- Edward Knodle --- edknodle@earthlink.net --- EarthLink: The #1 provider of the Real Internet. --- Edward Knodle --- edknodle@earthlink.net --- EarthLink: The #1 provider of the Real Internet. LOG ITEM # {Le;- Page k- of 'L-.. ...... ......._ _l.T. d ~.1:>-- 5/27/2004 I t/4.3.0 214.3.11 :~;~i~~;e~~~~~~~::~~~r~~~ ~~~~~~,additional proposed units (and their associated guests) does not affect any 3/4.3.1 Page 1 of 1 Michelle Farfan From: David W. Johnson Sent: Thursday, May 27,20047:57 AM To: AI Scalf; Michelle Farfan Subject: FW: DSEIS by the PLA in Port Ludlow From: Ralph Archung [mailto:archung@gte.net] Sent: Thursday, May 27,20047:29 AM To: David W. Johnson Subject: DSEIS by the PLA in Port Ludlow Re: the subject DSEIS, I am concerned that the PLA has not adequately addressed the issues of: *Safety, e.g. the ingress and egress of fire and other emergency vehicles, *Strict adherance to existing shoreline and wetlands restrictions, I I I I I I *And, as the PLA has stated in past presentations and in their mission statement, that their activities in Port I Ludlow will be of mutual benefit not only to PLA but also to the residents of Port Ludlow, I fail to find the benefits 4/4.3. to the Port Ludlow residents in the subject proposal. Their proposal to add increased density does not adequately address how the use (including cost to Port Ludlow residents) of existing green belts and existing facilities such as the Beach Club and marina will be affected by their proposal. Thanking you in advance and trusting that these comments will be addressed in your review, Ralph Archung P.O. Box 65164 Port Ludlow, Wa 98365 4374174 LOG ITEM # I LCe Page,__-1- ot..,L 5/27/2004 I I I I I I I I I I I I I I I I I I I I I I I I I I I I ." PLA has tried and failed before to raise the level of development in the marina area. I am sincerely hoping that '-3:i-g the Department of Community Development will again turn down their request for increasing the number of . " " units allowed in this area. I am not opposed to development but feel that the currently approved, platting of 1994 which allows 58 new units is in accordance with good planning and beneficial to all in the community. Page 1 of 1 David W. Johnson ~"'-'V__""_'''.'''_'_W.'__._'_'_.___'____'_~__",_,w_"~'_~"__~."_."'~'''m..,,_.''_'''_''___'__''__'^_''_.'__.__._____.______~_.._.,..,~.__~_._._,_..__________...__"._,...___.~_____v.._...,,_...._.__.._.....,. From: Sheebell@aol.com Sent: Thursday, May 27,20049:26 AM To: David W. Johnson Subject: Port Ludlow Associates DSEIS ATTN: AI Scalf, Director of Community Development, I am writing concerning the totally inadequate DSEIS for the Port Ludlow marina area submitted by Port Ludlow Associates. It fails to address many areas of crucial concern that will arise from their proposed increase to 88 new units from the originally approved 58. This increased density will create traffic and parking problems, decreased access by visitors and residents to the resort and beach front, and visually block the view of the water from the road. The questions of groundwater runoff, silt polution to the bay, and the effects on the wetlands have not been properly addressed in the DSEIS. PLA will leave here after 5 years and the rest of us must live with the results of this decision. I sincerely request that you look at this carefully and project the results to our community. Respectfully, Carolyn Schiebel 192 Seaway Place Port Ludlow, WA 98365 LOG 'TEM #_l2r Page_ L of-L 5/27/2004 I I I I'm aa fairly new resident of Porl LudiOW resorl, but longtime Jefferson Co. residen\. The new "owners, I managemenf' of Port LudlOW-P\.O seem to have no sense when making plans. It doesn1 even seem they consult with the land use planning group. p~~eh~r~i~:'~:U~i~v:~~:a~~i~;::,~:,~::,~::~~;~~;~~:n~:~~ ~a:,n:~ ~~d~in~ians 1 (4:,~~ I people, cars, traffic and problems.' . 4.~'!ii I'm pretty sure townhouses can't be built out over the pond in the lagoon as rl is a wer land, right? Isn't there al2.,.,..",i"4",.,',..a".,,i... 200 It limrl? The cars generated on those little roads would be impossible to manoever. Rescue vehicles '3J~'O' · couldn'1 get into the area. We also DON'T NEED ONE MORE C\.UBHOUSE AND POOL .,........ If the new buildings are of a lower slandard or smaller <as I here is planned), rl would surely lower the value of ou~h;r~n;r~::.::;~E~~J~~o~:;:~~~::~~~~re peopie nd housing No planning has gone into thi~i~:1 I really don't want to be part of the thought processes of these money hungry managers and am concidering selling and moving. I Eleanor peters-64 Goldfinch Lane PL I I I I I I I I I I I David W. Johnson From: Eleanor Peters (owmom@earthlink.net1 Sent: Thursday, May 27, 2004 10:38 AM To: David W. Johnson Cc: DOuglasP@CTED.WA.GOV Subject: Port LudloW development Eleanor Peters ~momav.earthlinl<. net WhY Wait? Move to EarthLink. LOG \TEM # ----LJ- 1(3 page~of-L- 5/27/2004 I I I I I I I I I I I I I I I I I I I JEFFERSON COUNTY DEPARTMENT OF COMMUNITY DEVELOPMENT 621 SHERIDAN STREET PORT TOWNSEND, WA 98368 SUBJECT: PORT LUDLOW RESORT PLAN REVISION DRAFT SUPPLEMENTAL ENVIRONMENTAL IMP ACT STATEMENT (DSEIS), JEFFERSON COUNTY, WASHINGTON From: Robert and Barbara Phinizy, Port Ludlow - LOT 10 resident (20 BLUEBIRD LANE) The present owners of the RESORT (Port Ludlow Associates) have proposed major changes to prior approved plans for Resort area development. As part of those changes, PLA filed a Supplemental Environmental Impact Statement to support the request. Robert and Barbara Phinizy urgently request that the County reject in total the requested changes as presented in the DSEIS. The reason and urgency for rejecting the requested changes in PLA plans are very basic, direct and easy to determine: 1. The proposed density would create an immediate and real obstacle to the passage 1/4.3.6 and access by emergency vehicles and personnel. In addition such simple things as "turn-a-round", parking, resident vehicles emergency exits from dangerous areas are for all practical purposes non-existence. 2. Prior rules and regulations covering beach access maintenance and views are 214.3.1 ignored. 3. Water run-off provision, settling basins and coordination with the already in place DRAINAGE DISTRICT is non-existence. Water run-off is a MAJOR impact item of 3/3.3.2 these requested changes. 4. Rules and regulations regarding set-backs, wet-lands, and wild life provisions are 414.3.4 clearly ignored or appear to be violated. 431 5. Other changes impact recreational areas, access to or elimination of, trails and bikeS/43.S paths. . 6. The peaceful and quiet environment now existing for all neighbors both nearby and in the extended Port Ludlow residences would be severely damaged or destroyed by significant increases in traffic and lack of parking provision. If such damages were 6/4.3.6 severe enough to be tort capable, PLA as agent in causation would not be available for recovery of damages, as they would have long departed, leaving the County as the targeted recovery agent. ~~ r, '_....~_,_n . _~__~7_.;~~.,"".....l.t~1'<;. -" ~y Z1 2004 JEFFERSON COUN1'\' OCO v r- .,.........--. MICHAEL CAHN MD HILDA CARN 104 Wells Ridge Ct. Port Ludlow, WA 98365 May 25, 2004 Jefferson County Dept. of Community Development 621 Sheridan St. Port Townsend, W A 98368 Dear Sirs: We are writing regarding Port Ludlow Associates' plans to expand their building of residential units within the Port Ludlow Resort area. We have become aware of information which distresses us to the point of emotion, and which should distress you. We believe that their current plans violate current county codes and laws, as well as state laws. We believe, that their DSEIS is faulty, vague, and incomplete. Review of their plans raises our concerns about fire hazards, water runoff and drainage, parking capacities and traffic patterns, ecology laws, existing property values, and current codes currently included in our CC&R' s and 20 year plan. Their DSEIS does not detail the impact on the fire risks. The proposed roads are narrow dead ends with no turn around space. It is our understanding that our fire district-3 fire chief and commissioners have not been consulted. It is our belief that they would require through-roads. With our aged population, medical and frreapparatuscalls'are frequent, and require ,easy access to buildings: The fire chief,: we are sure; would thus ban parking in those narrow streets, parking spaces which, we believe, are counted byPLA in their DSEIS. Furthermore;2 propane storages are planned~'withno supporting safety or fire analysis or locations detailed. In our wooded area and our dry summers, fires are a-major concern to our entire community as well as to the entire county. PLA has not consulted our Drainage District commissioners regarding water run-off, impervious area, water pressure impact in view of their increased density proposal, etc. We are aware of water run-off problems affecting the current occupants of residential units in the area, even before changes to the impervious area is altered for the worse. Thus, the jmpact of their plans has not been studied, or if it has been studied, has not been reported. Water run-off has been a problem in this area of Port Ludlow for many years. Parking in the area is often a problem even today. The marina lots are often full, and there are plans to enlarge the number of marina slips by 50%. PLA's plans for increased recreation facilities, yacht club buildings, etc., in addition to the proposed new residential units, will overwhelm the parking capacity. Current codes specify minimal parking per employee in these businesses. Weare unaware that these codes have been specifically included in the DSEIS. Furthermore, we suspect that some parking spaces have been figured more than once in calculating parking space for various functions. That is, lIlarina spaces may.have been calculated as overflow residential parking? It should, also be noted that these units will have one car garages for residents owning 2 vehicles, thus assuming that the 2nd vehicle must be parked in the driveway. However, the driveways will be so LOG ITEfV1 # (30 _ Page_,j..,~..of_L I I J !t o (I') ~I tti """i' I I I 1 14.3.11 4.3.6 I I I :J I ,'~ . :'1 t- N ~ 2/3.3.21 I I 3/4_3..6 I I I I I I I I I I I I I I I I I I I I I I I ., short that these vehicles will stick out into the street. Parking in the street will be extremely limited because of the huge number of driveways, if not completely banned by fire code. We feel that these narrow, poorly planned streets will create an undue danger to pedestrians and bicyclers. We are additionally concerned about the impact of the proposals on the ecology, aesthetics, and current codes in the area. We have been advised that the plans call for some residential units to be built so that at least 50% of the structure is over water; water which has been designated wetlands. It is our understanding that this grossly violates state ecology law. We have been advised that PLA and their predecessors have not encouraged eel grass and wildlife in this wetlands area as prescribed by law. We have also been advised that eagles nest in adjacenttrees, and may be impacted by the proposed plans. Prior plans had called for fish to be encouraged in the existing wetland, and the negative impact of the PLA proposals on this edict has been ignored. Current agreements call for easy access to the Ludlow Beach. This access will be impaired by the current PLA plans. Current residents in this area complain that their open spaces, recreational spaces (for walking, hiking, biking, etc.) will be obliterated. Likewise, their views will be altered from the current green hills to dense, low quality housing, a situation negating promises made when they purchased their residences. Furthermore, property values for these residents, as well as for all Port Ludlow residents, will decline as a result of new construction which is incompatible with existing Port Ludlow value. The proposed plans will violate the 20 year plan accepted by the county which calls for the maintenance of our green belts and open spaces, and for the preservation of our image as the resort in the woods by the bay. Thus the aesthetics of our community will be forever changed for the worse. Finally, we interpret as illegal, the PLA plans to build a new and separate recreational facility for these new residences only, bypassing current CC&Rs which require membership in the LMC for all North Port Ludlow residents. This not only violates current code, but instills bad faith between the parties involved. It dilutes the funds of the separate entities, destabilizing each one. While destabilization may not be illegal, it should be frowned upon. The PLA plans add a great deal of ill will by the current Port Ludlow residents who have witnessed broken promises, past and present. We recommend and hope that a TBD plan can be negotiated with the county and the developer which is acceptable and beneficial to all parties. We recommend that the Jefferson County commissioners and departments thorougWy investigate the proposed plans, and that they meticulously demand compliance with all local, county, state, and federal laws and understandings. We recommend that all plans be approved by the appropriate fire, drainage, ecology, etc. entities. We recommend that the plans be submitted in the greatest detail, and that they include exhaustive impact statements on all of the above issues. We recommend that the plans and DSEIS be evaluated based on current facts and not on past studies which may be outdated. Finally, we recommend that the plans be presented to the Port Ludlow Village Council and to the Port Ludlow residents prior to fmal approval. We hope that our thoughts and recommendations will LOG ITEM # {~O Page_1- of 3 4/4.3.1 4.3.4 5/4.3.3 6/4.3.2 7/4.3. 1 4.3.10 814.3.11 "" I I I I I I I I I I I I I I I I I I I receive serious consideration. We impress upon the county our voting power and political involvement. Yours truly, L~~~) gp 1,/l___, ~ ~,Q~ ~'^- Michael Cahn MD Hilda Cahn .' LOG ITEM # (~ 0 Oage 6--.-of3- , I I I I -I I I I I I I I I I I I I I ., May 26, 2004 ~~ tift 21 21m JEFFERSON 00trNTY OeD Jefferson County Department of CommWlity Development 621 Sheridan Street Port Townsend, W A. 98368 Ladies and Gentlemen: It has come to my attention that the Department ofCommWlity Development is considering the draft proposal of the DSEIS Report. After reading the report, I have significant concerns regarding the proposals it contains, for the commWlity of Port Ludlow and Jefferson COWlty! Our area is one of beauty, but of more importance, an area of well-planned environmental impact! I'm am not against good, defined commWlity growth and development, my husband was a developer in Southwest Florida, but am against poorly thought-out growth with little concern for the environment of our beautiful corner of the world! The following are "red flags" in the DSEIS Report: 1 2 1/3.3.4 2/4.3.10 3/4.3.6 4/3.3.2 5/4.3.10 6/3.3.4 7/4.3.4 3 The overall residential density, in resort area, is being increased by 56%. The report tends to rely on the input of the developer, without input:from the commWlity. The parking situation for this increase of population has not been analyzed in detail or depth of the impact on the present/future commWlity. Storm water runoff or drainage modifications have not been addressed with the Port Ludlow Drainage District. No analysis of impact has been stated regarding the Fire District #3 service. Presently zoned residential areas are proposed for commercial development! Worst yet, this report has been developed on primary data ofa 12 year old report, MAJOR CONCERN!! 4 5 6 7 I welcome your reply and thank you for taking the above items Wlder advisement and review. . f)JL O. Hannon, EdD, ~ 32 Lei brook Lane Port Ludlow, W A. 98365 LOG ITEM # t3 ,~- ~Qe L of ( -- MONA L. STEFFLRE 90 ADMIRALTY LANE #337 PORT LUDLOW W A 98365 ,\ if,"-::'\ {; ri i \ \ ); \ '0" 2:'-: . 1.."_ '.' i i '); : _ 1\ i;' MAY 2; L~ ,; L_-.p .,' - MAY 27,20 4 .1": i' ; " ('f:n or ( ,. " . - AL SCALF, DIRECTOR JC COM:MUNITY DEVELOPMENT 621 SHERIDAN STREET PORT TOWNSEND WA 98368 RE: DSEIS FOR PORT LUDLOW RESORT.PLAN REVISION DEAR MR.. SCALF, AS A 72 YEAR OLD RESIDENT, I IMPLORE YOU TO TURN DOWN THE DSEIS UNDER CONSIDERATION. PLEASE 00 NOT DESTROY MY HOME. I LIVE IN ADMIRALTY 11, IN THE LOWER LEVEL OF ONE OF TIIREE LOWWEST BUILDINGS OF THE COMPLEX. · THERE IS ALREADY RUNOFF OF WATER FROM THE TOP MEADOW WHERE THE PROPOSED ADMIRALTY III WOULD BE SITED. THE CURRENT FLOW MIGHT REACfITHE STAIRS LEADING DOWN TO MY UNIT #337. TONIGIIT,.I COULD NOT GET MY MAIL AS TIIE FLOW OF RUNOFF FROM THE RAIN WOUD HA VB GONE OVER MY SHOES. (THE MAIL BOXES ARE ON A SLOPE WIDCH I WOULD HA VB HAD TO GO UP FROM WHERE I PARKED MY CAR). I UNDERSTAND ADMIRALTY 1 & ADMMIRALTY II ARE IN AN AREA OF "LANDSLIDE HAZARD-MEDIUM RISK". TIllS RISK WOULD SURELY INCREASE WlTII THE CONSTRUCTION OF ADMIRALTY Ill, THE PARKING SPACES, AND NEW ROADS. I CAN NOT IMAGINE ANY PARKING ON THE STREETS EVEN NOW AS TIIEY ARE VERY NARROW AND ALREADY OF SOME CONCERN TO ME IN THE EVENT OF NEEDING EMERGENCY VEfllCLES TO REACH ALL OF OUR BUILDINGS. · IT IS NOT CLEAR WHERE THE .. RETENTION POND" WOULD BE BUILT BUT IT WILL CERTAINLY BE ABOVE ME. NOR AM I TIllLLED WlTII .. POPANE STORAGE" BEING UP HllL FROM ME. · TIIE MEADOW IS USED BY PEOPLE WHO ARE NOT RESIDENTS OF ADMIRALTY I & ADMIRALTY II. SOME PEOPLE WALK THEIR CIDLDREN IN STROLLERS AND OTHERS WAALK AND PLAY WIlli THEIR DOGS. (SOME OF TIIE LAITER PEOPLE ARE PROBABLY RESIDENTS BUT NOT ALL!) THERE ARE ALSO OTHER AMENNITIES SUCH AS A CHILDREN'S PLAYGROUND, BASKETBALL COURT.AND TRAILS. MY SUGGESTION IS THE PLA SHOULD DEED TInS LAND TO THE COMMUNITY. · THERE IS JOINTLY OWNED GREEN SPACE BETWEEN ADMIRALTY I & ADMIRALTY II. - WIlliOUT A OOUBT, WIlli NO GREEN SPACE REMAINING ABOVE, OUR GREEN SPACE WOULD BE OVERRUN. TInS IS A STEEP SLOPE JUST ADJACENT TO MY UNIT AND NOT SUITABLE FOR lliS SAME ACTIVITIES AS ON THE MEADOW UP ABOVE. LOG ITEM #~g3 Page ---L- of ~ I 1 ,~_..t~: ! \ \1' "1 : \ , . i\U, L '- T . ,v I I I I 1/3.31 I I 2/3.3.~ 4.3.EI 3/3.3.21 4.3.11 I 4/4.3.1 I 5/4.3.51 I I I I I I I I I I I I I I I I I I I I I ... · ~~C~TWEAD=~~:=~iI~~~~~~~~~~~TS 6/3.3.4 BECOME RESIDENT HOMEOWNERS. TIllS IS A BIG ISSUE TO THOSE OF US WHO LIVE HERE FULL TIME AND WHO MOVED HERE BELIEVING ., WHAT YOU SAW WAS WHAT YOU GOT". MOST OF US HA VB UNDERTAKEN 7/4.3.2 AS MUCH REMODELING AS WE CAN AFFORD (OR CAN NOT AFFORD AS THE CASE MIGll BE). THE BUSINESS MODEL HAS GREATLY CHANGED FOR TIllS AREA. PLEASE PROTECT ME! SINCERELY, fl\.n-.o.. 1. g~~ MONA L. STEFFLRE -.,.- -~:~"--;.'---'--~'~"-'r-C~r-~\'\ 1"--.... \'-, , t'fj, ~...., n ~\ .' \f\ i\ '\ ,-. Hi.' \ ....':. . n \ h .::.:..-:-:-:--~ .,~: "j \ \ \ \ I \k \\ \\\ 11\ \ \\\ J 11 A~ 2 8 2004 \~. \ \J U' mt\ ,\ Lrrc~'WJ,~ ," \ J(r"~r.~";'.,_: r,cr-lOP"l,(i'< \ '. PT Or CO'J~"II",',~ ..,,.'-t --~ DE . "" ..::..- LOG ITEM # 133 Page_ d- of--R- I Michelle Farfan I From: Sent: To: Subject: David W. Johnson Friday, May 28,2004 1 :13 PM AI Scalf; Michelle Farfan FW: comments and requests I I -----Original Message----- From: Larry Lawson [mailto:thelaw@olypen.com] Sent: Friday, May 28, 2004 1:09 PM To: David W. Johnson Subject: comments and requests I I To whom it may concern, I request that you start this entire process over in order to include pertinent information that has been excluded. I Dealing with drinking water there was a reference to the Draft Environmental Impact Statement from the early 90's but the document does not seem to be at hand, and is probably superseded anyway. I Statements of water rights are claimed but not verified nor is there a County provided document showing essential figures of the total volume of drinking water granted to all local users by DOE or allowed by Jefferson County through historical usage. To reply to this current DEIS the public needs to know of the total water allocated currently, via the vehicles of water rights and historical usage. We also need to know what the total available sustainable usage is in each of the referenced aquifers, and the actual recharge rate. It is not ethical and perhaps not even legal to have the company selling the water to customers doing the verifications of aquifer health and recharge. Shouldn't this be a County responsibility? 1/4.3.9 I I I Even in the abbreviated version included within this DEIS one footnote is missing. I question why there is a lack of open information provided in useful format when the document is offered to the public for serious comment? This is our home and these issues concern our future health and well being. I The public finds ourselves in a vulnerable situation when our County does not advocate for our community essentials. Water being one of the most precious. Hearing only the focused concerns of a developer should not be the primary purpose of a Government which is responsible to all of it's citizens. But based on the previous DEIS process my impression is that the County actually advocated for the allocation of public resources into private use, including our water, without concern for long term conservation. My cautions about the previous developer abnegating their stated responsibility to maintain public services is quite substantiated by the need to create a local drainage district. Shoddy development causes the people of this County to pay for these oversights in the future. A PUD is a tax supported venture to unravel the disasters of poor planning. The requests by the proponent may be valid and supportable but it seems the least the County can do is require that all of their claims are proven and documented. In fact the County should be responsible to the public to assure a continued supply of healthy drinking water and even now be using an unbiased third party to assure the level of water available in our aquifers. It only makes logical sense to know what the limits of our public resources actually are, before we approve utilization. Allowing a corporation to have access to water may be taking it from current users, and the information provided in this public DEIS is not adequate to sustain 2/4.3.9 I I I I I 1 LOG ITEM I the#~ Page { ofD I I I I I I I I I I I I I I I I I I I proponents requests. Also, the County is our only agency able to manage oversight of all events likely to effect future quality of environmental health. But even today (May 28, 2004) there is a clear cut logging operation in progress on top of the north aquifer, but no mention is made about the effect on recharge into the future from this event or other types of further development. 3/4.3.9 As stated above, this process needs to be started over with clear and useful information so that all of us in this County are able to understand what resources we are allocating to who, and how future public use will be sustained. Citizens should not feel forced to take legal action to protect our future health. The County should be the public agency protecting our public resources. Thank you for the invitation to respond by email. Sincerely, Larry Larry Lawson 10140 Oak Bay Road Port Ludlow WA 98365 360 437 9143 LOG lTEM #.-L~ l{ w PageJ-._of_L, 2 One concern I have about expanding the number of lots and housing in the Port Ludlow Resort Plan is the utilities, water and sewer. In 1999 there was an agreement in the 1999 plan to assure the availability of water and sewer to the remaining lots in North Say which have not been built on. My concern is the continuing that 1/4.~ agreement at no extra costs to the lot owners. The water and sewer was developed on the income from the sale . 01 the lots in North Bay area and therelore should be available 10 fhe 101 owners in North Bay. The past actions of ... PLA leads one to believe that they will try to use the utilities services to generate the cash needed to expand the utilities into undeveloped areas of Port Ludlow Resort Plan. The PLA's should be required to demonstrate that they have sufficient sewer and water hookups to serve the existing lots in North Say and not stress the Utilities presently in place. They should also demonstrate that they are expanding those utilities without charging extra fee's to the present owners in the development to cover their costs of expansion. When people purchased in the development there was no representation that the purchase would latter require additional funds to build out the Plan. Page 1 of 1 Michelle Farfan From: David W. Johnson Sent: Friday, May 28,20042:30 PM To: AI Scalf; Michelle Farfan Subject: FW: DSEIS revision of the 1999 Port Ludlow Resort Plan From: Richard Duce [mailto:r.duce@worldnet.att.net] Sent: Friday, May 28, 2004 1 :44 PM To: David W. Johnson Cc: bwagnerj@olympus.net Subject: DSEIS revision of the 1999 Port Ludlow Resort Plan To Whom It May Concern: Richard Duce 132 Gamble Lane Port Ludlow, WA 360-437 -0144 LOG ITEM # 13S' Page--Lof_L 5/2812004 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Page 1 of 1 Michelle Farfan From: David W. Johnson Sent: Tuesday, June 01, 2004 8:12 AM To: AI Scalf; Michelle Farfan Subject: FW: Comments re DSEIS/Port Ludlow Resort Plan revision From: Rosalie Sarber [mailto:barbers@cablespeed.com] Sent: Friday, May 28, 2004 4:43 PM To: David W. Johnson Subject: Comments re DSEISjPort Ludlow Resort Plan revision On May 24, 2004 we attended a Port Ludlow town meeting regarding revisions that Port Ludlow Associates (PLA) is requesting to their original resort plan. At that meeting we received a document that we construed to indicate that we, as residents of Port Ludlow, had until June 14 to comment on the proposed revisions. In reading the June issue of the Port Ludlow Voice (which we received this afternoon), it appears that today is the deadline for those comments. Due to the late hour, our comments will be briefer, and not as well organized, as we would have liked. We, like most of the residents of this community purchased our homes with the understanding that the 1/4.3.1 resort plan was already decided. To find that it may now be possible for the developer to increase the population density of the resort area is appalling to us. Since our first visit to Port Ludlow several years ago, we have noticed a dramatic decline in the number and variety of water birds that visit the area. We believe that the development that has taken place during that time is at least partly to blame for this loss. One of the things we were told before we purchased our home was that residents would have access to the beach in the resort area. The fact is that since extended development has taken place, it is very _ difficult for us to have access to the beach unless it is low tide. Ifpeople can't easily access these areas, 2/4.3. J it isn't hard to believe that the native waterfowl may find them, ifnot inaccessible, at least much less appealing a place to visit than they once did. Just one more comment (since we are out oftime for the 5/28 deadline): We live on Rainier Lane. It is our understanding that not one, but two, sewer lines were installed in this area by PLA (or its predecessor). When we purchased our home no one mentioned that it could not be built to easily access either of these sewer lines. . . at least not until later, after we had sold our existing home (our purchase of the Port Ludlow home necessitated the sale of our previous residence). In other words, at a point when it would have been difficult for us to back out, we were told that "by the way" our new home would have to have a "grinder pump" installed in order to pump our waste up to the sewer line. Of course we 3/4.3.S signed the agreement. We've now been in our home less than 2 years and this grinder pump has already failed once. The point of this comment is that PLA was the builder of our home, and it makes us very uneasy that something as important to the environment as sewage (and drainage.. . another story that I don't have time to relay now, but will do so before June 14) has been so poorly dealt with. It seems like we would be courting disaster to allow development at an increased population density when these important issues haven't really been properly addressed for the current residents. Wayne and Rosalie Barber LOG ITEiVi #J~(P Page _l_ otL 6/1/2004 May 29, 2004 Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, Washington , ' , ", : ','. :;-: d 1 r/ . t" 1 ,; J ,~_:._-,:: '\ 11 II ;;: ;; I jJ Llj JUN - 1 2004 JL0J' L~~_~~'_~_~~0J.~~~~~~~~~~rr~M E.~~I. Dear Sirs: I am writing my comments in regard to the Port Ludlow Resort Plan Revision's Draft Supplemental Environmental Impact Statement (DSEIS) dated in April 2004. I understand that by the extension granted on May 24,2004, I have until June 14,2004 at 4:30 PM to place these in the hands of the Department of Community Development. Before beginning the critique to be contained in this letter, I want to make it clear that I am writing simply as a citizen of Port Ludlow, Washington, without regard to any office position that I may hold in the community or any professional position that I may have attained. Let me also state that I have every desire to see the developer, Port Ludlow Associates (PLA) succeed in the build out of the Port Ludlow Resort. My concern arises when I see the prospective plans for the final development of the resort as seriously flawed and, in my reading of the law, proceeding in some areas in an illegal manner. I have detailed my concerns in an Appendix to this letter (Appendix A) which is attached hereto and made a part of this letter for the record. I have chosen to do this because I believe that if the areas that I believe to be illegal applications for a building permit are addressed (denied), the majority of the objections expressed by myself and the community to the DSEIS will disappear. Therefore, the body of this letter focuses on those illegal areas. I am referring specifically to the Shoreline Management Master Program for Jefferson County dated March 7, 1989. Section 5.160 of that document 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." With reference to the DSEIS, this prohibition specifically applies to the PLA plan to build residential units over the shoreline of the lagoon in the resort. Although the DSEIS states (page 3-10) that "no wetlands or streams are located within the Resort,"this is an untrue statement since the over 2+ acre lagoon constitutes a wetland that is utilized by wildlife residing in or passing through the area. PLA contents that it is not subject to the Jefferson County Shoreline Master Program because the 'lagoon was "man-made" . In my reading of the law and from my personal experience in watching others attempt LOG ITEM #--13 7 Page I of-'-f- I I I I I I I I I 1/4.3.1 I I I I 2/4.3.. I I I I I I I I I I I I I I I I I I I I I I I I Ii I' JUN - 1 2004 -.".. ----..-.-. -.-..... .--.--.---... --.. " , ~ ";-\ DEP-i" o~: r~r .' '. \ t" \/ t_~ :. n ~~, (....:: \;" (without success) to get around the "no building ove~H~etiaI1ds" requirement, it does not matter whether the lagoon is made by nature or man-made. This body of water is not like a swimming pool in one's back yard. Once a wetland is created, it remains a wetland in perpetuity or until natural conditions change and it dries up of its own accord. A reading of the description of the lagoon in the DSEIS, Section 3.2.1.1, Affected Environment further substantiates my view. This lagoon was created in 1967 and enlarged in 1994. Thus, it has existed for 37 years. It is approximately 10 feet deep. It is very close to the Bay and there is water exchange between the lagoon and the Bay. I myself have seen otters playing around the lagoon as well as herons and egrets feeding in the waters of the lagoon. Indeed, one of the "conditions" required in the 1993 permit for resort development of the Inn and surrounding townbomes was the planting of eel grass in the lagoon to promote use by wildlife and aquatic creatures. Clearly, then, this body of water is a wetland and must remain subject to the Shoreline Management Act of the State of Washington and the Jefferson County Shoreline Master Program. Currently in the DSEIS, PLA proposes to build a series of "stacked flats" and town homes over the shore of the lagoon and extending into the lagoon. My count from the map labeled ''Figure 8 - Drainage Basins" at page 3-12 of the DSEIS shows at least 12 and perhaps 13 of these buildings are to be built over and extending into the lagoon. If, as I believe, this building over the shoreline of the lagoon is not permitted under the Shoreline Management Act or the Jefferson County Shoreline Management Program, this would eliminate at least 12 buildings from the crowded plan proposed by PLA and automatically decrease the complaints of the Port Ludlow citizens related to traffic, parking and congestion (See, Appendix A herein). Indeed, no less than the Jefferson County Tax Assessor-Collector, Mr. Jack Westerman, had declared those lots located over the lagoon as "unbuildable" and lowered the taxes assessed to PLA on those lots. My second area of concern relating to legal aspects of the proposed DSEIS relates to the changes requested by PLA in location of commercial/residential properties. While I have no personal objection to the switching of these locations, I am concerned when it appears that PLA is attempting to make these switches without going through the proper permitting process. Specifically, the location of the present Harbormaster Restaurant is a commercial area (See, 1993 Resort Plan, Figure 2-Alternative 2). In the DSEIS, townhomeslstacked flats are being planned for this area. Currently, along the shoreline of the Marina, single family residential units are platted (See, 1993 Resort Plan, Figure2- Alternative 2). The DSEIS contemplates making this area a commercial area with a, marina store, restaurant and recreation facility. Section 3.903 of the Jefferson County Ordinance 08-1004-99 requires that any subdivision that has only partially been developed must apply for a plat alteration "as set forth in state law and in applicable county ordinances". The Resort plat was approved and recorded in 1993 thus, any alteration to that plat must be applied for and processed separately from seeking approval through the DSEIS process. RCW 58.17.215 states that an application for such plat alteration "requires the signatures ofa majority of those persons have an ownership interest in the lots, tracts, parcels, sites or divisions in the LOG ITEM #--1 ~1 Page~_of4- 3/4.3.4 3.3.3 4/4.3.1 5/4.3.1 6/4.3.1 subdivision. " I I I I I I I I I I I I I I I I I I I Since the townhouse owners now living in the resort area outnumber the developer when it comes to a vote by head count and the RCW does not give an advantage to the majority lot owner, PLA would be treated as a single lot owner for the purpose of such a vote. Knowing that PLA would likely fail to garner the required votes for such a plat change, it appears that PLA is trying to slide this plat change requirement through in the DSEIS. Although the two issues stated above are but a few of the flaws that I have found in my reading of the DSEIS (See, Appendix A hereto), they are the most serious because they appear to flout the laws of Washington and Jefferson County. In light of these flaws alone, I believe that the Draft Supplemental Environmental Impact Statement submitted to Jefferson County, Washington by Port Ludlow Associates should be rejected in its entirety. SI'ncerelY'~' , ~ ~" '. ; , :l / , ' . ~ Carol Higley Sa P.O. Box 65487 14 Sea Vista Terrace Port Ludlow Washington, 98365 ; ',(l I;::: :' "\J ._'~_..~ -'. ; 11 ',: ill' : i I ~. i :_i.~; JUN - 1 2004 ! :_0, i I I ----'J E F~-F ~:: S 0 N-~~0U r.rryk---i [)FPT ,), "'(';;:':'" '..lir," :,<vel IJP'''Erj'f _. ,.....-. ,-~..'.::..:.:_~,.;,....,.-, . ..'-;.::......~~~\-:~<.:.~_.,~--j LOG ITEM #_1)7 Page 5 of~ I I I I I dl I I I I I I I I I I I I I JUN - i 2004 Appendix A D:;'-: Overall Critique of Port Ludlow Resort Draft Supplemental Environmental Impact Statement __._.0. _,'__ ._, _,_.', _.__._ __. 'i,: ~. V t: L!JPi/[ 1\; -.;" Traffic/Parking: · Focus is on roadway impact (State Route 104, Beaver Valley Road, Paradise Bay Road, Oak Bay Road) rather than parking at the resort which is the primary concern. No analysis pof parking requirements at the resort is given. · Several numbers given for total parking spaces: which are correct? · Incorrect number off spaces stated as leased from LMC for Resort use (See, LMC letter to Jefferson County Department of Community Development re: DSEIS). · No citing of code reqUirements for adequate parking for each type of use (business or residential) is given, such as" one parking space for each three restaurant seats". · What sort of on street parking is anticipated; where? It is impossible to determine where driveways are located from the maps within the DSEIS. · Residences will have tandem parking for two cars (behind each other) and will tend to use street spaces or parking lot spaces for at least one of those cars per household. Drives for residences will effectively eliminate street parking considering the density of development since driveways cannot be blocked. No on street parking will be allowed on the road to the inn as that is to be a two-way road and is not wide enough to allow for parking as well. · All streets are dead-end streets without turn-around areas. With cars in the streets and no turning areas this creates a hazard in emergency situations. Will fire trucks and emergency vehicles be able to maneuver? · No discussion given to the "elevator" at the parking lot or the "18 foot wall" at the parking lot as shown on the plats and diagrams. What do these items consist of? What are the safety measures (if any) connected with these items? · No consideration was given to the present average use of current parking in determining adequate future parking needs at buildout of the resort and expansion of the marina. Even now, during events at either the marina, Beach Club, Inn or Harbormaster (which are often simultaneous, particularly in Spring, Summer and Fall), parking can be difficult to find. Drainage: · There is no description as to how adequate drainage is to be accompliShed. Present drainage is often inadequate. Development (particularly of Admiralty III) will only increase the drainage problems. LOG ITEM #_1!J7 Page~ofJI 7/4.3.6 3.3.6 813.3.2 , , I' JUN - 1 2004 (""\r:>-:- (-,. . The North Bay Drainage District has not been consulted on these issues even though they are the agency which will directly involved in solving drainage problems that arise. . With so much additional land to be covered by asphalt and concrete in the Admiralty III area, why are there no detailed provisions made for drainage which is already a problem for the Admiralty I and II units? . Where is the retension pond for Admiralty III? Is there to be one at all? If not, is this development allowed? Density : · The proposed residences are a significant increase (56%) over the current plan (from 87 to 190 residential units over all ; with an increase from 58 townhomes to 88 residential units within the resort itself) creating a crowded situation not conducive to a resort atmosphere. · The floor plans included in the DEIS do not represent all the types of residences proposed and it is impossible to tell which of these units are to be located where in the blocks of shaded areas representing housing. · Floor plans for the commercial areas are not included in the DEIS nor are the locations adequately designated on the plats. · Designation of some residential units in the proposed plan occupies land zoned commercial (where the present Harbormaster is located) and some of the currently zoned residential area (along the marina waterfront) is proposed to be commercial space. Doesn't this require a re-zoning and a re-plating? No consideration seems to have been given to the legality/illegality of this change. · No discussion was given to the building of residential units on pilings over the lagoon. Only a one sentence mentioned that the lagoon was exempt from the Washington State Shoreline Management Act but no citation was given nor any opinion cited by an official of that agency as to the truth of that statement. · It is not realistic to say that just because the lagoon is man-made that it is not a wetland. It has been in place for 37 years and water is exchanged between the Bay and the lagoon. · The presence of wildlife around the lagoon was minimized, based on 12 year old data yet, I myself, while dining at the Harbormaster have seem eagles, herons, osprey, muskrat, beaver, otter and deer around the lagoon. I cannot believe that the greatly increased density will not have an adverse effect on wildlife within the water and around the water of the lagoon. · Two additional propane tank storage areas are contemplated but are not shown on the site maps and no analysis of the safety of this propane storage was done. LOG iTEM # (37 Page!7 of ({) . 1 I I 1 1 9/4.3.10 4.3.1 1 4.3.4 4.3.111 I 1 I I I I I I I I I I I" I I I I hi I I I I I I I I I I I I I II JUN - 1 2004 Economics: n:.."r"' . A great deal of space is given over to comparison of the current proposal with the two prior proposals. Is this used as a justification for the current proposal changes to the resport plan? Otherwise, why are these comparisons in there in such detail? . It seems strange that Jefferson County appears to be passing on the economic viability of this project and commenting on changing economics. Since economics has been introduced into the DEIS, it woukj be interesting to inquire as to the economics of the proposed club which is open only to guests at the inn, the townhome residents (who already are designated to be members of the LMC Beach Club), and guests at the marina -(but not slip holders). . How can such a meager use base support a facility that will probably cost 1/2 to 3/4 of a million dollars to build (to say nothing of maintainence)? If the town home residents are to be forced to be excluded from the LMC in order to build the new club base, this will require a change to the current CC&Rs which requires a 100% approval (not a likely prospect). Changing economics would seem to dictate that this facility is not viable. · Reference is made to use of the conference center as PLA offices. However, this facility is under lease to Port Ludlow Vacations, a company unaffiliated with PLA. There is also the possibility that this facility will be sold to an outside party as negotiations are on-going. Overall Evaluation: . It appears that Jefferson County Department of Community Development relied totally on PLA for input into this DSEIS. · The lack of citation of federal, state or county codes to support the statements made is shocking. This does not allow adequate evaluation of the DSEIE in relation to Code requirements. · Port Ludlow is designated a Master Planned Resort (MPR) under the Codes of the State of Washington. That designation was originally created by the Washington State Legislature with Port Ludlow in mind. Now, with the increased density and major changes proposed in the DSEIS, it is hard to realistically continue to call Port Ludlow an MPR. If that designation fails due to the actions of the developer, it opens the community up to all sorts of land use designations leading to much uncertainty in the future. · Increasing the density, changing the focus of Port Ludlow from a resort to just another residential area, removing the open spaces so prized by the citizenry, will have an adverse effect on property values reducing the tax base for Jefferson County in the long run. LOG ITEM # 137 Page {, _ofL 10/4.3.2 11/4.3.10 4.3.2 MEMO 1 I Via Certified Mail I I 1 I I DATE: TO: CC: FROM: May 22, 2004 Michelle Farfan, Associate Planner, Jefferson County Al Scalf, David Alverez, BOCC, PL VC, and LMC Bert Loomis RE: a) Port Ludlow Resort Plan Revision - Draft SEIS, 3/15/04 b) Shoreline Primary Use Substantial Development Permit No. SDP 91-017, issued 5/11/93 [expired 5/11198] 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. 1/4.3.11 Policies I 1 I I I I I I I I 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 7A, 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. 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, op~n space, or recreational facilities. Also, the 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 LOG ilElvi #J37 Page-Lof~_ I I I I I I I I I I I I I I I I I I I existing Permit SDP91-017, dated May 11, 1993, expired 5/11/98, as previously agreed to by the County and Developer. This permit was issued subject to significant mitigation requirements. The applicant now wants to increase density by 66%, while concurrently failing to comply with previously agreed to permit conditions. I call your attention to the Notice Section of the Permit: I. 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... Why are they still planning for this required mitigation condition eleven years after the permit was issued and six years after it's expiration date? LOG ITEM #J67 Page ~ of~ 2 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. On May 1, 2004, I filed a request for access to public records with the Jefferson County Recorders Office for: "Records for Shoreline Primary Use Substantial Development Permit No. SDP 91-017, [issued 5/11/93 & expired on 5/11/98]" "Please provide copies of all documentation, public comments and the legal basis that Jefferson County relied upon to approve construction over- water, which is a direct violation of the Shoreline Management Master Program [SMMP] for Jefferson County [March 7, 1989]." On May 21, 2004 Dwayne Wilcox, Vice President PL VC, and I examined those files at the County office. After a thorough review, we found no authorization for over-water construction. In fact. over-water construction was never mentioned in any of the files we reviewed. 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 this Draft SEIS as submitted. ' Additionally, the parking and traffic components of this Draft are woefully inadequate, lacking specificity, accuracy, consistency and failed to site relevant code sections etc. I will forward my detailed comments on the parking and traffic issues in a separate memo. It is unfortunate that the Department of Community Development [DCD] has allowed such an inadequate document to move forward. Please provide me with a copy of DCD's analysis of the Draft SEIS. Contact: Bert Loomis 9500 Oak Bay Road Port Ludlow, W A 98365 360-437-2400 bertl@cablespeed.com LOG ITEM #-137 Page~_of~_ I I I I I I I I I I I I 2/4.3.6 3.3.61 3 I I I I I I I I I I I I I I I I I I I I I I I I I " Burke F. Gibson 89 Cascade Key Bellevue, washington 98006 May 25, 2004 Jefferson County Department of Community Development 621 Sheridan Street Port Townsend W A 98368 Ref.: Port Ludlow Marina Expansion I have a townhouse at 24 Heron Road in Port Ludlow that I acquired in 1997. I purchased this unit with the covenants that protected the qualities of the area. There are some proposals before you that would take away the very things that I bought. The increased density of below-standard 1/3.3.4 units with increased density of people is not what I bought or that which was sold. I am against the proposed changes of Port Ludlow for the above reasons. s~~~~ MY z ~ 20M Burke F. Gibson JEfFERSON COUNTY DCD LOG ITEM #~ Page ---L-- of I ",,/ ,\;i> ~ R,\I ~ ~~~ ~~~ ~~~ $~ ' Another facet that is not properly addressed by the EIS is storm water draining. It is our 4/3 3 2 understanding that even with the current configuration there is seepage. What will . . happen WIth the addition of 68 units over the current allocation? WILLIAM SCHOENEMANN 221 SOUTH KEEL WAY PORT LUDLOW, W A 98365 May 21, 2004 Jefferson County Dept. of Community Development 621 Sheridan St Port Townsend, WA 98368 Dear Mr. Scalf After reviewing the proposed changes to the Resort Residential Units my wife and I have some serious concerns related to the DSEIS submitted by PLA. Our overriding concern is that the proposed housing density changes the overall character and feel of the area from a pleasant, upscale, open area to a transient, crowded, stacked type of environment. The thought of homes overlapping the lagoon has to be completely alien to any consideration for the habitat and environment. We cannot visualize where people are going to park as the space left for parking cannot possibly accommodate marina, two car residents, visitor, inn and restaurant parking requirements. Parking, currently can be a problem when there are multiple events in the area. Unfortunately, the EIS does not try to address this issue. In the plan there seem to be a lot of blocked streets and dead ends. If people with two cars, reasonably, decide to park on the street there does not seem to be adequate access for fire or emergency vehicles. Again, the EIS fails to address traffic flow issues within the resort community. Under this plan open areas will vanish to be replaced by such unnecessary structures as a third social club in the Port Ludlow MPR. Access to the beach, now open to all, will be restricted. The bottom line is that this plan, as written, is unacceptable. We are concerned for the people who purchased theirhomes in good faith under the assumption that the 1993 plan would be carried out Their property values will be seriously affected by the implementation of this new and onerous plan. ~M- Bonnie Schoenemann LOG ITE # IYJ Page ---1- of-1- I I I I I I 1/3.3.4 I I I I I I I I I I I I I 2/4.3.6 3.3.6 3/4.3.7 I.,. ~ '.. . I I I I I I I I I I I I I I I I I I May 25, 2004 Dear Employee of the Dept. of Community Development I was very concerned after hearing about the Draft Supplemental Environmental Study that has been submitted by the Developer (Port Ludlow Associates) that involves the 'resort area'. The following areas do not seem to have been adequately addressed: The loss of open space and the effect on the wildlife who currently make their homes in this area (deer, eagles, otters...) Emergency Vehicle access, small crowded dead-end streets. Parking issues, not enough place for the increased residential parking and enough parking for an enlarged marina, new recreation club and restaurant. Decrease in access to the beach areas for all Port Ludlow residents. Decrease in access to the pond for wildlife and people caused by units being built, on or too close to the pond. I request that there be additional work done in these areas to be certain that the increased density will not be a detriment to our community. Thank you for your time and effort. Christine Whitehurst Robert Smith 57 Leighbrook Lane Port Ludlow t1AY 2 8 2004 JEFFERSON COUNTY OeD LOG iTEM # /L{J.., Page-4-.-ofl 1/4.3.4 2/4.3.6 3.3.6 3/4.3.6 3.3.6 4/4.3.7 5J4.3.4 .3.3.3 ... May 27, 2004 Carol Barnes 103 Cascade Lane , Port Ludlow, W A 98365 360.437.4120 hcbarnes@tscnet.com JeffeTson County Department of Community Development 62' Sheridan Street Port Townsend, WA 98368 , Subject: DSEIS Changes to Resort Residential Units Ladies and Gentlemen: I am seriously concerned about Port Ludlow Associates latest proposal to develop Port Ludlow. Their 2004 DSElS is apparently based on a proposal approved in 1994. They want to change the emphasis of their development from building a conference center to building condos. I I I I I I I I I You will receive many letters objecting to the density of condos being proposed, the 1/4.3.101 incompleteness of the report, the lack of planning, the lack of on-sight visits, and the lack of consultation with residents of Port Ludlow.l believe they assembled this new proposal with bits and pieces of the one approved in 1994. I 2/4.3.41 My main concern about the 2004 DSEIS is the evaluation of the impact of development on wild life in the town-not just the resort area Since the '94 report the mix of endangered, threatened, and sensitive species has changed: Bald eagles and deer have moved into the area that the PLA proposes to develop_ I I believe-the PLA should "start from scratch" on the entire DSEIS and especially evaluate the impact of development on wildlife in Port Ludlow. When we have an accurate and cI current DSEIS and environmental impact repo~ we can begin negotiations to develop a 3/4.3.1 plan with the County" PLA and residents that acceptable and beneficial to all parties- with the least disruption to the wildlife in this area. ' Thank you for your attention to this latest PLA proposal and concerns raised by residents of Port Ludlow. \ l( Sinn' Caro~es _ts2Jl\ . jErffI\SO~ COUI'ITl UC\l. LOG ITEM # -'.!::J3 Page --L- ofl.- I I I I I Further, counting the mill pond as open space, then proposing to ring it tightly with smaller condos goes against the rules and common sense. Parking and fIfe access will be severely eroded, along with the open space we hold so important. 2/4.3.6 I I I I I I I I I I I I I I I I I LOG ITEM I #, L(t;' I Page -t- of---L May 27.2004 JUN - 1 200~ JEFFERSON COUNTY OeD To: The Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, WA 98368 We are lot owners in North Bay and members of the Beach Club. We have several concerns with the DSEIS now resubmitted by Port Ludlow Associates. Here we will address our major concern, which is the severe loss of open space around the Beach Club, Mill Pond, and Marina. The area adjacent to Oak Bay Road with several trees growing on the green is the signature area of Port Ludlow, giving some validity to the boast that this is the Little Village in the Woods By the Sea. If this area is stacked with condos it will lose its great beauty and welcoming aspect. No fmancial gain will make up for the loss of this space to the community, where it has get-togethers and events during the summer time, as well as cherishing the area at all seasons. 1/4.3.5 4.3.3 Sincerely, Grant and Wenonah Sharpe PO Box 65113 Port Ludlow, W A 98365 JUN -1 214 Rosalind K Plorde 55 McKenzie Lane Port Ludlow, WA 98365 JEFFERSON COUNTY OeD Dear Sirs, I was very dismayed the other evening at the Port Ludlow "Town Meeting," to learn of the DSEIS that Port Ludlow Associates is to submit to Jefferson County for their proposed expansion in the lower harbor-resort area. An outside consultant sitting in a remote location and drawing lines on a "plan" To reinforce and validate what the developer wants to do, is a sorry way to conduct business. There seemed to no understanding ofthe original intent or design and concept ofthe "Resort at Port Ludlow, and worse, no real effort to consider the impact ofthis plan. Practical considerations such as the amount of space it takes to park a car, drive down a street or allow emergency vehicles access to residences seem to be glossed over and/or ignored. Packing in more residences and subdividing open spaces into "products" is the only thing evident in this plan. The "impact" is both esthetic and physical. The regulations put forth by the state of Washington to safeguard shorelines and other environmental considerations are not included at all. There is no evidence that either PLA or their consultants made any finite measurements of the space, did any research on drainage, land slides, water supply, proposed usage, transportation or safety. We as residents of Port Ludlow, moved to this community to enjoy the attractions that both nature and the original developers provided. If and when some facilities are made "exclusive" to only a segment ofthe community, and the natural environment is degraded, many will begin to think of going elsewhere. PLA seems to be trying to present another scheme not unlike the last effort to create revenue by imposing ill- conceived and grandiose programs for the golf and marina community. Many of us are retired, but we are not senile or stupid as this DSEIS report would suppose. _We count on Jefferson County to reject this proposal as both inadequate and a travesty for all concerned. If Jefferson County counts on our property taxes to contribute to the county coffers, they must make sure that Port Ludlow remains a viable and attractive community or it may decline to a mere shadow of its former self. Thank you for your attention and interest. Sincerely, ~ !l.P~ Rosalind K. Plorde LOG ITEM #.J:jlp - Oage---L-o( \ I I I I I I 1/4.3.101 3/4.3.2 I 2/4.3. 1 I I I I 4/4.3.11 I I I I I I I I I I I I I I I I I I I I I I I I I Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, WA 98368 Dear Sir: May 26, 2004 I am writing you in regards to the proposed development of the marina area here in Port Ludlow. If developers wish to build and develop the area around the marina they should be responsible, at their expense, for the entire infrastructure, which would include the expansion of the sewer treatment plant. The burden ::::~~~::n~n~~ ~:~=~::~: ;u~~:h=~~~;S:~:::~~=. 1/4.3.9 The sewer system is adequate for the existing lots. Any major development like what is being proposed must be required to meet future needs. Parking is another major concern. Restrictions have been put in placed over the years, which protects the residents. The developer should not be able to negate these without the 2/4.3.6 consent of all property owners. I know that we have to have development but anything as major as what has been proposed needs very careful study with the present and future in mind. Please do not let development take place that will cause major problems. They will be gone and we are stuck with the corrections, if even possible. ~&l#fLtL 333 Montgomery LN Port Ludlow, W A 360-437-5038 LOG ITEM #~7 :)ape ---1- of l JUN -120M JEFFERSON COUNTY DCD_ The Sharpe Family Trust 10 Admiralty Lane # 304 Port Ludlow, WA 98365 Monday, May 24, 2004 ~~~ JUN -1 20M Jefferson County Dept. of Community Development 621 Sheridan St. Port Townsend, WA 98368 JEFFERSON COUNTY Den RE: Draft SEIS - Port Ludlow Resort Plan Revision: Gentlemen: I I I I I I I I I We have reviewed the details on the Draft SEIS for the Port Ludlow Resort Plan Revision, and wish to make a few comments. We fully understand that the owners should be expected to get the best possible return on investment under the master plan. It must, however, be done carefully, with actual facts, and with some level of integrity. We do not wish to be obstructionist, but we will watch that the process be done right. In the spirit of cooperation, we would like to point out a few issues that need to be corrected. . The transportation assessment in section 3.6 is substantially in error, and should be corrected. Actual impact is more than double the stated figure. 1/4..3.. . Detailed architectural drawings and road plans are not induded as required. 2/4.3.1'1 . The Bay Club and the Beach dub are not conference facilities as stated, but are private dubs for the use of members and their guests under very specific guidelines. 3/4.3.1 . We are very concerned that existing basketball, court and playground facilities are to be removed, ' with no replacement plan. Our major concern is the loss of the only safe playground for children. 4/4.3.5 . The parking plan is unwise in the extreme, and contains significant factual errors. The supervisory I board will do well to exercise a great deal of oversight on traffic portion of this project. I have seen a . , number of cases of front and back parking touted as two spaces. Inevitab\y, one car (or more)wind5/4.3.i6 up parked in the street. Not good. The report also daims quite a number of additional spaces that I can be rented for overflow. This agreement is for about half the number daimed, and expires January ,2013. . The report daims the private lawns of Admiralty I and II as public open spaces. This is a significant Over at::;.e~~=u~:': ~~:~e ends, and several misstated facts. We hope that these issues ca~14.. be resolved equitably, to the benefit of all involved. I know yours is often a thankless job, so I want to express my thanks for your efforts to serve on this board. We hope that these comments will be useful, and help you in your deliberations. P#hO~~$'\-1349; Fax: (480) 314-0125 Mobile: (480) 540-3370 V <2 II t:IVi Port Ludlow 360.437.7304 Pape-LofL_ SharoeC@cox.net I I I I I JUN - 1 20M I I I I I .1 I I I I I I I I I I I I LOG ITEM # -LLlS I Page ---L-of L May 29,2004 Mr. AI Schalf, Director Jefferson County Department of Commumity Development 621 Sheridan Street Port Townsend, WA 98368 Dear Sir: JEFFERSON COUNTY OeD Re: Revised Port Ludlow Resort Plan and and Draft EIS therefor A review of the proposed Port Ludlow Resort Plan and Draft Supplemental Environmental Impact Statement, dated April 2004, reveals the following inadequacies and adverse im- pacts if accepted and implemented as now presented: 1. In the marina area of the Resort: The proposed development of a long row of a num- 1/4.3.1 ber of closely built large commercial and large residential structures immediately along . and next to the sensitive shoreline of Port Ludlow Bay. All or part of this phase of the development may be in violation of the county's Shoreline Management Master Program. 2. In the area of the current location of the Resort's Harbormaster Restaurant: The pro- 24 3 1 posed development of residential buildings on the terrain that includes very steep slopes 1 . '.... . '.. above the shoreline and an existing lagoon/marshland frequented by many kinds of water- fowl. All or part of this phase of the development may be in violation of the County Shore- line Management Master Program and Building Codes. 3. Along the shoreline from the start of Ludlow Bay Village to the current marina office 10- 3/43 '1 cation, to the existing single residence west of the marina office: The proposd (and contin- " . ued) drastic reduction of public shoreline access and public water viewing opportunities with no mitigation offered. 4. Inthe upland area of the Resort: The major elimination of open space in proposed high 4/4.3.5 density residential areas with no mitigation offered. 5. Within the entire resort area: Inadeuqate analysis and detail on accommodations for in-. " I) t:; creased commercial and residential parking and street traffic. 514.v.u 3.3.e I hope for your serious detailed study of the problems I have outlined above which appear to warrant major changes to PLA's seriously flawed development roposals for theResort. ( 5/27/04 JUN .. 1 200; JEFFERSON COUNTY oeD Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, WA 98368 RE: Draft of the Environmental Impact Statement for Port Ludlow Development To Whom It May Concern: My husband and I have lived in Port Ludlew for just one year now and love it, as well as the rest of Jefferson County, very much. We are trying to keep ourselves informed as to proposed projects, etc. which will have an impact on our unique ~ity while allowing for healthy growth and prosperity in Jefferson County. As we understand the DSEIS, we have the following strong concerns that we hope will be considered and acted upon prior to movilg forward with this project: · We'd like to see a detailed analysis of parking and traffic patterns planned. From what we see, we're concerned that there is not enough parking which will lead to much street parking. Not only is this a cosmetic problem, but more importantly, a safety problem. We need appropriate fire truck and emer2encv vehicle access. We also see potential for much higher traffic volume and can't tell if that has been dealt with, especially with roads dead-ending at the Inn (where do we turn around)? · Will there be a decrease or elimination of public access to our beach? · Some land that is currently zoned as residential is proposed for commercial development and some residences proposed would occupy land currently zoned commercial. What impact will that have on current condo owners? · What open space will still be there? One of the things we love about P.L. are the green belts and open area, including the pond. We'd hate to see condos (or anything else) built over the pond. In fact, we thought it was originally zoned to be a common area for the recreation and enjoyment of all homeowners. · Our understanding is that there has been little, if any, analysis done regarding drainage. This is a great concern for those currently living in condos as they already have some problems. Is there an estimate of increased silt or storm water runoff? As implied above, we do want to see PLA prosper, but not at the expense of overlooking the good of the folks who currently make up this community. We believe that a plan can be developed that is acceptable and beneficial to all parties. However, in order to do this, more analysis is needed and dialogue with this community. ~~~~ TheBuehlers CWavY)€- ~6tq>haV1 f~ 120 Fleet Drive, Port Ludlow, W A LOG ITEM # Ir;;o Page-l-ofL ~ I I I I I I I I 1/4.3.6 3.. 2/4." 3/4.. 4/4.. 5/3.3~ I I I I I I To increase the residential density by over 50% in the resort area is too much. My husband and I hope that the EIS is modified and redone to reflect what is best for Port Ludlow and Jefferson County's long range plans, which should not be a degradation of the area, but an enhancement. 3/4.3.2 3.3.4 I I I I I I I I I I I I I I I I I I LOG ITi::lVl # ;s-I I Page_ 1 of ,- n1C4~ ~ 1; lOOV if 25 Sea Vista Place Port Ludlow, W A 98365 Jefferson County Dept of Community Development 621 Sheridan Street Port Townsend, WA 98368 To Whom It May Concern: JUN -1 20M JEFFERSON COUNTY OeD As a current resident of Port Ludlow, and as a property owner from Mats Mats Bay for over thirty years, I am writing to comment about the DSEIS for Port Ludlow. Growth for this area is inevitable, but growth should be regulated responsibly for the long-term future of Jefferson County, one of the most beautiful areas in the country. Unfortunately it appears that the owners of the resort, PLA, are suffering from short-termitis, and want to increase their profits at the expense of responsible growth. Fortunately, the county can and should control the resort plan to ensure that the various county regulations are enforced, including Shorelines Management, fire department access issues, parking adequacy, storm water runoff provision, and landslide hazards. 1/4.3.1 It is my understanding that the report used for evaluating threats to the environment is over 12 years old. That seems hardly a good basis to use at this date. 2/4.3.10 Sincerely, \ )( an~ It/ !h- ~leenrn\J10 Jefferson Co. Community Development Dept 621 Sheridan St. Port Townsend, Wa.98368 JUN - 2 200; JEFFERSON COUNTY OeD Comments on the DSEIS for Port Ludlow development I have a great concern for the impact of surface runoff into Ludlow Bay, Puget Sound and the Hood Canal. Given the recent concern for the sound and Hood Canal [see attached PI article] it is not prudent to consider any development that would contribute to additional degradation. Ludlow Bay is also currently polluted to the extent that shell fishing has been closed due to pollution. [See attached listings by the Washington State Department of Health.] Therefore there should be zero runoff into the Bay from any new development. The 1993 EIS permitted using the grass areas to absorb surface runoff with mitigation plantings around the lagoon. Since then there have been no . plantings around the lagoon and some of the grass areas have been built upon. The proposed development is partially located on the grasslands reserved in the 93 EIS. This may be illegal but in any event it further diminishes the runoff protection. Runoff in the immediate area should not be permitted to go into the lagoon and then into the bay without treatment. There is no indication where the runoff solutions for Admiralty 111 are going to be located and how effective they will be in keeping the runoff out of the bay while minimizing the seepage into Admiralty 1 and 11. The next concern is the proposed density and it's negative impacts on parking and traffic. During the process of applying for the establishment of a master planned community designation the developer held several community meetings and planning forums to get the input of the community. The density and location of the developments were discussed at great length. To get the support of the community the developer agreed to move the residential units from the Marina and Admiralty areas to the west side of the project. This did not prohibit the developer from building all of the units permitted in the 93 EIS. What it did was permit building the residential units in an area that was more environmental friendly. Wildlife issues; In the DEIS there is reference to the Raedke Wildlife Survey in th93EIS. This survey does not support the issues referenced. The Raedke suryey was a snapshot survey that only records the species present on the da~ of the survey. When surveying migratory species such as birds and fish mOJ;-e comprehensive methods are reqlJired to determine/the numbers and species p(esent during the year. Ther-efore the comment that the Marbled LOG ITEM ~95~~of~ I I I I I I I I I I I I I 3/4.3. 1 I I 1/3.3.2 2/3.3.3 I 4/4.3.4 I I I I I I I I I I I I I I I I I I I I I I Murrelt [an endangered and threatened specie] was not present within a mile of the project is misleading. Any birder in the area can verify to the fact that they are present within yards of the marina at certain times of the year. The Maintenance building should not be permitted where proposed. It was no in the 93 EIS and is not compatible in a residential area. It will contribute to 5/4.3.11 drainage, traffic and noise problems. This facility should and can be sited in an area where it would have less impact. The development as proposed will be covering up the last remaining grass in the area. This will have a negative impact on esthetics and wildlife as well as 6/4.3.3 a severe impact on the saltwater environment. It appears that the DSEIS contains some biased alternatives for development. There is no alternative that would protect the environment. Therefore I would like to suggest an alternative be considered that would be considerably environmental friendly and yet permit the developer to construct all the units 7/4.3.11 permitted in the 93EIS. The alternative would be to have all the residential units proposed for the marina and Admiralty areas be constructed in areas near the golf course where they were proposed in 1999.This would have a beneficial effect on the density, drainage, traffic and parking. Thank you for your consideration of the above. ~ {}J~ w.;:hf Dale W. Witt Wildlife Biologist Rat JUN -2 20M JEFFERSON COUNTY OeD dO &avnb(e, L0 Pori- LvcU0-w ()J~ qo3~ LOG ITEM # /5'~ Page ~_of Cp_ DATE PROJ, NO. JUN - 2 200+ -I MORRISON .:; MAIERLE,INC. PROJECT, BY, DATE CHK, PAGE, OF JEFFERSON COUNTY D 0 JI;,rFt=:fZ~ ~,17&-+t of C(Jk1MUNl+Y ~~1fU::N+ '0'2 i 5 H E 12.. { -ocuJ sr-. % t2. + 'T!)t..0Id~ '\f) .3 WA q e 3b8 191. SI.9 u=:. 'L&:4- ~ '1M \ttolf;L ,+ MA.'1 Ct:Jj~~ ; -ltJ SUMMA1Z-f-lr0 R'EvlEW'~6 +he ~fb~E.)(futJ$loN ''fU::>N 171 ~ '1:iE\I~e12..S WE. 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Mr. & Mrs. Bruce Henricus 23 Raeburn Court Port Ludlow, W A. 98365 360437-7711 -'~"'~' JUN -~ 1M ~~fF~.HSQN COUNTr.'[tCtl) June 1St, 2004 Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A. 98368 Re: Resort Residential Units Plan Dear Sir or Madam, W~\Vjsh to register our strong objections to the proposed changes to the Resort Residential Units Plan of 1994. W~loCated in Port Ludlow for the quality oflife that the area offers as well as the fact thatthe community, and developers, seemed committed to retaining the pristine environment that makes this village so desirable. The 1994 Plan was acceptable because it seemed to recognize limits on density, sensitivity to the infrastructure and importance of protecting the Bay and surroundings to \, o\:'~~fdevelopment. Remember that the investment in our homes is a long-term, lifetime commitment, -.' 'ill for many of us who chose this area for retirement. The prospect of turning the . place over-crowded with transients with hundreds of vehicles, multiple . If.itPQI,lAAdaccelerationofthe dissipation of the environment , q$v4th~ppreh~nsion. In addition, it is " 'j~:~~$heriff (with increases in :,~tly, how about medical 1/4.3.1 4.3.2 4.3.4 ~'i-Ib~()flive here. Please also think f;vet-'castdays and rain. Disappointed ~U soon become disenchanted and sell, mg,vacancies, bankruptcies - with their ~Ql1-of the quality of life, environment and many retirees who would suffer a great loss. 'ely, ~_;/' ~ ~~~ ~~:~!----z- and Magdalena Henricus / I I I I I I I I Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 9836& JUN - 3; 2004 .IEFFeisoN COUNTY DCD' J\h~ 1, 2004 Re: DSEIS for Admiralty Condominium and Ludlow Bay ViJJage, Port Ludlow Sir: We are concerned about several features of the draft SEIS for the developments named. We reside in the South Bay area of Port Ludlow but keep a boat in the marina. Like most residents of Port Ludlo.w, we frequently attend fur.ctions at the Beach Club. Many criticisms of the plan have been noted including inadequate plans for parking, lack of road access for emergency vehicles, encroachment on the existing pond, and inadequate provision for likely increased water run.-off. Our personal reservations about the plan are: 1. The intent to create maximum density of housing units in the relatively confmed area promises to. destro.y the present "open air" atmosphere. We already suffer loss of the wonderful water views which we had ten years ago from the Ludlow Village area. As an attraction for both residents and visitors, high density development makes the area less desirable. Although this is primarily an aesthetic issue, home values. are apt to-suffer as. well 2. Rental of a slip in the marina assumes adequate parking proximate to the marina for boat owners. If there is a general inadequacy of parking in the area, oo\o-Wusly this will impact parking by boat owners .It is our understanding that proposed cond011'.iniull1, units will have one car, garages.. Assuming that most home owners will have two cars, the second will occupy public spaces or be parked on the street. \Videspread.street parking, and predominance of dead.end.streetswill create havoc especially for delivery trucks and emergency vehicles. 3. Any further encroachment on the pond will significantly,inhibitthe wildlife population. Frequent spotting of animal life in the village is a major plus for Port Lu_dlow residents. Our recommendation is to replace this draft SEIS with a new comprehensive document takir..ginto,consideration the aesthetic and, environmental impact of further dense development. Sincerely, , .D ~.,c. ~__ ~-"/~ Kevin & Susan Ryan 124 Sooth Bay Lane Port Ludlow, W A 98365 LOG ITEM # IS<./ Page-Lof~ 1 ,_ 1/4.3.1 I I 2/4.3.6 3.3., 3/3.3.31 I I I I I I R.L~ P6~~J-O~ f ~.pd2~,~Z?~/U~~~ ~,~~.'~~~~~ ~~~~~~~*rf~ C3~2ir~~~(~) .. ~.~bb_%.~~ ~atL-~r6~J ~ !5,~.Mo~~ r&6.. {.~~ ~ 1t~.~~2 ~ 8CY1V~~~.A4-~-P~~-~ ~ I.AL"'~' <;Ztu~~~ ~44->-~ "'~P~~~d~ ~,'~I.M--~ " ~~~ -~ ~~ t~.4~~,2/4.~i.1D ,f!:v~i N~~ ~ ,~'Ah?~. .:t/~~~~ho..~~/~~ ?f:;t-.u ~~ / ~~ ~~ f>.A.;~ ~~~~~~~~3f~'.i~~ ~/V'd~~( ~~~~ ~ ~~(~~~~)~~~ /J/IAt-(; ~ _~ ~ ~' .e??~ ~~t4.3.1D p~~~~~~~~~~( &~~~.( I ' w-cU.;~~~ '6 dd6(~~1~1 I. LOG ITEM ~ ~ ~~ -~~, l~,',,;; ::1-3""""".,.,.,,3,.,. P~oelSf., ~~'Pr~ ~.':,,)~ I -. I _O'~brJ ~ ~ ~.&11 I 1 I I I I I &a I I I I I I {, \\ ,~, e~ ;?e-t; ~ {,A.)...<':'-"-1 Q _ /J _ ,/ /J.. d t:PKY2,/ T~V<-<-~- L-t,~ I~ gv"'Y'V ~ i ;zo~ ~'vv&~4 ~VJ ~~hb~cl~P~ 6:2/ ~ ~, ~o-tt ~~ ~ tC1S'3i:<:t, LOG ITEM # 155" Page~, ~_of;[ ~ I r' LtL ;.a~-?~~ .4~ tJ~2- ~ b~lJyV I /VIJ~L>AO- ~~~ ~~ ~ ~- 9/4.3.1 AUr~~~! I p~~~~~ f6CCL~:a- ~ I ~~~'~~.~~ ~'#~~L/^A~~~~ I , .. ' .rv~v I ~~ I I I I I I I I' I I I I I I ~~ ,-" , ~~ <030 Oh{~5 (3\\1<1 P.L, q'g3iP J]DlUM!~ .IJN -, 21M ,JEFFERSON COUNTY Den I I I I I I I I I I I I I I I I I I I June 2, 2004 Peter & Jeanne Joseph 6 Heron Road Port Ludlow, Wa. 98365 JUN - 4 2004 JEFFERSON COUNTY OeD Michelle Farfan and AI Scalf Jefferson County DCD 621 Sheridan Street Port Townsend, Wa. 98368 Re: Comments Concerning the DSEIS for Port Ludlow Resort Plan Revision. As both of you are well aware of our position concerning the density issue pertaining to the build out of the resort core, we will refresh your recollection with bullets rather than extensive prose. 1. The county already rejected the same request in 1993. Unless there are over riding reasons why they should be granted a larger number this time, they should be held to the 58 residential units as a maximum, of which they have already built 26. Increasing the density of residential development will overwhelm the traffic capacity, parking, and ability to absorb that many people into such a small area. It will only degrade an otherwise elegant community. 2. The Jefferson County Shoreline Master Program applies. Section 5.160 specifically prohibits them from building: "Residential structures located on or over marshes, bogs, swamps, lagoons, tidelands, ecologically sensitive areas or water areas subject to the master program." The pond is subject to the shoreline program as it within 200' of the high water mark of the saltwater tidal basin. It certainly is an ecologically sensitive area. There are a number of other paragraphs in the same section that apply as well. Paragraphs 1., 4., and 10 under POLICIES, and paragraph 5. and 9. under PERFORMANCE STANDARDS. I have attached applicable excerpts from my previous scoping comments for your review as needed. 3. It is intuitively obvious to us that the sixteen lots that extend out over the pond cannot be built on. Even your tax assessor concurs with this opinion. You cannot tax these lots as "unbuildable", and then turn around and build on them. The assessor made that decision based on the fact that they could not be built out over water for the same reasons as stated above, not because of any degree of difficulty with construction. Keep in mind there was never any challenge from the developer when his taxes were lowered due to this ruling. The remaining lots must be set back at least 30 feet from the edge of the pond. 4. Referring to Section 3.903 of Jefferson County Ordinance 08-1004-99, which I quote in part: " For any subdivision that has been approved and recorded, but only LOG iTEM #/51p Oage -L_ of ,~ 1/4.3.6 3.3.4 2/4.3.1 3/4.3.1 4/4.3.1 partially developed, a plat alteration shall be applied for and processed as set forth in state law and in applicable county ordinances." We feel they cannot obtain a plat alteration without the town home owner's permission. 5. We also wish to point out that the failure to complete the town home project as projected when we purchased our home, will negatively impact us and is contrary to the interests of all the lot owners. We feel that this is a breach of fiduciary duty by the board of the association, as well as a violation of consumer protection laws. It is also a violation of the county requirement to complete the project no later than June 14, 1998. In 1993, PLA's predecessor signed a contract with JeffersonCounty to meet certain conditions. They have breached that contract and should be sanctioned by being held to a lesser number of units than was specified at that time. 6. If the Inn parking is to be expanded per the EIS the four parking spaces across the south end of the existing island and the evergreens that buffer the town homes should remain. The town homes will have no guest parking if the plan is instituted as drawn. As one of the conditions calls for the town homes to be buffered by natural vegetation, any substitution of vegetation as part of the new parking plan should require trees and plants of equivalent height. Sincerely, , ,iYc,f.Cr.;::.:f,":~", ~ . ~,-. it: I j:t>"". I Yo" ~ - l ~~g-~;; ,~, ".. " . . -. . i"'- ' \+=>n- ~ '\J~~ JUN - 4 2lM* JEFFERSON COUNTY DeD LOG ITEfV1 # / ~<p Page.. ~~__of.3. I I I 5/4.3.1 I I 6/4.3.1 3.3.6 I I I I I I I I I I I I I" I I I I I I I I I I I I I I I I I I Attachment to Joseph letter. Referring back to the County Shoreline Master Program, specifically residential development, section 5.160, Prohibited Use 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." Under the subsection POLICIES Para.. 1." Residential development should be designed at a level of density of site coverage and occupancy compatible with the physical capabilities of the shoreline area, and consistent with the density provisions of local plans, codes, and ordinances. Para.. 4 "over water residential development, including floating homes, should not be permitted" Para. 10 "Sub divisions should maintain usable waterfront areas for the common use of all property owners within the development." Under Performance Standards, Para.. 5 states" 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." Para.. 9 states the standard setback shall be 30" as measured from the ordinary high water mark. All setbacks shall be measured from the water ward most edge of the structure excluding decks, eaves, etc.. ]rny~ J.~~~~t JUN - 4 20lU JEFFERSON COVNiY DeD LOG iTErJl # IGlf ;Jaqe ,~ of 'S .. :se~~i~~:c:~0~~~:~~s~~~7~:~.f~S ~~::::::?::a~r~~:~~ ~':s~i~~e:O;: ~:v::;;:t:1::e~:\~~e t/4.31 population density of the resort area is appalling to us. Since our first visit to Port Ludlow several years ~~~~;ee t~:~~h:o~~:~:p::a~~td~~~~:k: ~~a~::~;n~a~~~;i~~~~~:t ~:~;~~tb~:~~:~t~ 1::.2/4., One of the things we were told before we purchased our home was that residents would have access to ~~~fibc:~~~~; ~~~:~:~ ::a~s;~et~~c~~~~~a~~~~: i~~~e~~~i~~~~~~:;~~ ~:~~:&:~~e~si~h:~; areas, 3/4.. it isn't hard to believe that the native waterfowl may find them, ifnot inaccessible, at least much less appealing a place to visit than they once did. LOG ITEM # 15"7 Page---L-of '-s Page 1 of2 David W. Johnson From: Rosalie Sarber [barbers@cablespeed.com] Sent: Tuesday, June 08, 2004 7:59 PM To: David W. Johnson Subject: RE: Comments re DSEIS/Port Ludlow Resort Plan revision Our address is 585 Rainier Lane, Port Ludlow. The issue regarding drainage which we did not have time to address in our earlier e-mail is that we are aware of a number of instances where problems with drainage have occurred as a direct result of development efforts. In general, we are concerned that this area is being developed without the oversight that normally occurs in more urban areas to ensure that storm drainage is adequate and that there are no resultant erosion problems. This issue is broader than the issue regarding revisions that Port Ludlow Associates wishes to make to the original resort plan, but we believe it is relevant because increased population density is likely to result in more land clearing and more drainage and erosion problems. Wayne and Rosalie Barber From: David W. Johnson [mailto:dwjohnson@co.jefferson.wa.us] Sent: Friday, June 04, 2004 11:45 AM To: Rosalie Barber Subject: RE: Comments re DSEISjPort Ludlow Resort Plan revision Could you please include your home address for the record? Thank you. From: Rosalie Barber [mailto:barbers@cablespeed.com] Sent: Friday, May 28, 2004 4:43 PM To: David W. Johnson Subject: Comments re DSEIS/Port Ludlow Resort Plan revision On May 24, 2004 we attended a Port Ludlow town meeting regarding revisions that Port Ludlow Associates (PLA) is requesting to their original resort plan. At that meeting we received a document that we construed to indicate that we, as residents of Port Ludlow, had until June 14 to comment on the proposed revisions. In reading the June issue of the Port Ludlow Voice (which we received this afternoon), it appears that today is the deadline for those comments. Due to the late hour, our comments will be briefer, and not as well organized, as we would have liked. ~ 6/9/2004 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Page 2 of2 Just one more comment (since we are out oftime for the 5/28 deadline): We live on Rainier Lane. It is our understanding that not one, but two, sewer lines were installed in this area by PLA (or its predecessor). When we purchased our home no one mentioned that it could not be built to easily access either of these sewer lines.. .at least not until later, after we had sold our existing home (our purchase of the Port Ludlow home necessitated the sale of our previous residence). In other words, at a point when4t~'::)' it would have been difficult for us to back out, we were told that "by the way" our new home would ~""".,~.,.g have to have a "grinder pump" installed in order to pump our waste up to the sewer line. Of course we signed the agreement. We've now been in our home less than 2 years and this grinder pump has already failed once. The point of this comment is that PLA was the builder of our home, and it makes us very uneasy that something as important to the environment as sewage (and drainage.. . another story that I don't have time to relay now, but will do so before June 14) has been so poorly dealt with. It seems like we would be courting disaster to allow development at an increased population density when these important issues haven't really been properly addressed for the current residents. Wayne and Rosalie Barber LOG ITEM #/~7 ':)age ~__of 3> 6/912004 Page 1 of 1 David W. Johnson From: Rosalie Sarber [barbers@cablespeed.com] Sent: Friday, May 28, 2004 4:43 PM To: David W. Johnson Subject: Comments re DSEIS/Port Ludlow Resort Plan revision On May 24, 2004 we attended a Port Ludlow town meeting regarding revisions that Port Ludlow Associates (PLA) is requesting to their original resort plan. At that meeting we received a document that we construed to indicate that we, as residents of Port Ludlow, had until June 14 to comment on the proposed revisions. In reading the June issue of the Port Ludlow Voice (which we received this afternoon), it appears that today is the deadline for those comments. Due to the late hour, our comments will be briefer, and not as well organized, as we would have liked. We, like most of the residents of this community purchased our homes with the understanding that the resort plan was already decided. To find that it may now be possible for the developer to increase the population density of the resort area is appalling to us. Since our first visit to Port Ludl()w several years ago, we have noticed a dramatic decline in the number and variety of water birds that visit the area. We believe that the development that has taken place during that time is at least partly to blame for this loss. One of the things we were told before we purchased our home was that residents would have access to the beach in the resort area. The fact is that since extended development has taken place, it is very difficult for us to have access to the beach unless it is low tide. If people can't easily access these areas, it isn't hard to believe that the native waterfowl may find them, ifnot inaccessible, at least much less appealing a place to visit than they once did. Just one more comment (since we are out oftime for the 5/28 deadline): We live on Rainier Lane. It is our understanding that not one, but two, sewer lines were installed in this area by PLA (or its predecessor). When we purchased our home no one mentioned that it could not be built to easily access either of these sewer lines. . . at least not until later, after we had sold our existing home (our purchase of the Port Ludlow home necessitated the sale of our previous residence). In other words, at a point when it would have been difficult for us to back out, we were told that "by the way" our new home would have to have a "grinder pump" installed in order to pump our waste up to the sewer line. Of course we signed the agreement. We've now been in our home less than 2 years and this grinder pump has already failed once. The point of this comment is that PLA was the builder of our home, and it makes us very uneasy that something as important to the environment as sewage (and drainage.. . another story that I don't have time to relay now, but will do so before June 14) has been so poorly dealt with. It seems like we would be courting disaster to allow development at an increased population density when these important issues haven't really been properly addressed for the current residents. Wayne and Rosalie Barber lOG ITEM #JS-7 '~aqe s _of 3 6/1/2004 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 1/4.3.1 3.3.3 June 6, 2004 ]JJf1~~ f , . 'U Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 JUN - 8 2JIK Dear Department of Community Development: . JEFFERSON COI INTY OeD Thank you for the opportunity to respond to the Port Ludlow Resort Plan Revision Drat{ , 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, bufflehead 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?lI 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 on a 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 of a 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 LOG ITEM #-1~ :l:;)age -L-- of L.--- 1 " A l' ~ 2/4~3.4 4.3.10 3/3.3.4 4/3.3.6 4.3.6 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 of the 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. ' ~~ Sincerely, ~j~ JUN - 8 2IIIK JEFFERSON COUNTY OeD Barbara Tipton 23 Clear View Place Port Ludlow, W A 98365 360-437-0558 LOG ITEfVl #-'~ Page ?- of ~ 2 I I I I 5/3.3.f1 4.3.6 I I 6/4.3.2 I I I 7.14.3.2 I I I I I I I I I / ~~ I y-' 1/1 Dlr-~ l 10 10.A.-; ev~ f..r ;t'~ uJ;t 9 "3(0-:: ?"-S" I~~b~.. ~~~ II.?-I ~~ f~ ~,WA1f3'.f" JUN -8 20M I rp- ~ ~ ~ JEFFERSON COUNTY DCO 1 ..) h,... ~ "Jj. ..J- 0 ;tJ,~ tL-:\) s ~IS _ ~~~~.~~~ f..x-~~. 1 ~~"-4-~t~~~~ ~~ '~~~M~ 1 ~ . j;i::'~.J~ ~ ~~ ~P\YVC ~tr. b-~ crv lt4.ZB.liO ~ ~ A.-.. fl>'lT ~, ..J ~ b.-- ~ · 1P'~~~,~"-~I'iq4 ~~ 1 D5~:S ~l~.~:tt..o ~ ~ L.~~~ ~ ~ . ~ ,AAJ N{f(AGGt:tTAtsL€. 1 fiv~1 ~~''7.~ " ~.J.....o 1<- ~ J),~ ,^'-< w-L, ~ ~~~ 1 ~.C<-<U.-. ~ v-.. l' tL-~, ~ ~4.:U]l I ~ '. U~~~~~~~ ~~~ ~~~;tL:c I ~ ~ . Uc::C ~ ~ ~~ ~ _4/4.3.1 ~' ~;7S~~~~~_~~ ~ ~~....y ~ ~ -~ At:;ft..-~ _ U! ~ \~ /l-J.-O- ~ ~~~ - ~ ~ '4- "-~~_ ,.~v~1.-L~ _ ~-:c:~t~c~ \.,v"'"'- /1J2_~~ .'t,..f~"-^-J& c.~ .~c.-,.--R, ~,', ~ ~W~ ~ ~ .- ~ ~~'M.,,_r,-l}-, ,~ ~'--~~"'\5;;; ~ )I\~~TJY-+~~ I t ~~ ~~ ~~~ ~~M~.11 ~..' .'~.~ ~ '1 7h- j;;,.~. tJA- PJcL. ~ ~,.1;"",)9,~~~~~~_~, I ~""r" 'Ill" r .,~ - '.' ;/b 0 ~~~~I ." , ' .'; ,iO:" , lit .PfjfH; /f ~ 1 I ( I 'f>~()t~ I f~~~f~~ I , ~e~_'~~&-~ ~J)~~~ I I I I I I I I I I I LOG ITEM #-15"'9 Page... ~o( ;x,- I I I I I I I I I I I I I I I I I I I JUM ..8 29M ~EffERSON COUNTY Del The Bay Club 120 Spinnaker Place Port Ludlow, Washington 98365 (360) 437-2208 Fax (360) 437-0367 Jefferson County, Dept. of Community Development 621 Sheridan Street Pori Townsend, WA 98368 Attn: Mr. A. Scalf, Director 6 June 2004 Reference: Draft Supplemental Environmental Impact Statement (DSEIS) for Port Ludlow Resort. Application ZON 03-00044. Subiect: Chan~es in Resort Area Development Plans raise Concerns. The South Bay Community Association (SBCA) represents almost 500 households in Port Ludlow. This Association and many of our members are concerned that changes in the plans for completion of the Resort area, as proposed in the referenced DSEIS, will make both Resort and the larger Port Ludlow community less attractive to both business/conference planners and potential new residents. Much time, effort and resources have been expended along the path to a Master Planned Resort (MPR) designation for Port Ludlow. Redesignation of the former MPR as a "Destination Resort", with implicit de-emphasis of construction and maintenance of Resort amenities, such as tennis courts, together with increased housing density leading to additional traffic and probable congestion will detract from this community. While the DSEIS raises these and a number of similar concerns, the SBCA believes the most immediate issues are parking and access. The DSEIS proposes to increase the number of residential units within the immediate Resort area from the currently approved level of 122 units to 190 units. That increase of more than 50% promises a corresponding increase in residential traffic and a likely increase in on-street parking by residents in that area. Planned expansion of the Marina by 100 slips and construction of a new restaurant will all bring additional traffic, and further increase parking needs. Particularly on weekends and at night, access for emergency vehicles may be limited and slow with potentially life-threatening consequences. If parking and redundant (alternative) access are fully and adequately addressed, other major concerns become more amenable to solution. While the DSEIS does not include detail parking and access plans, the addition of well structured guidelines, standards, and subsequent review procedures would focus essential attention on these critical areas. Yours Sincerely, LOG iTEM #-11" 0 :Jage~Of.L Cl~O~2r :wi2 Anthony F. Durham President, South Bay Community Association evJ-d 1/4.3.2 214.3.6 3.3.6 JUH -8 20M June 6th, 2004 Dear Mr. Scalf, JEFFERSON COUNTY OeD I have just reviewed the Port Ludlow Village Council's critique of the EIS prepared by PLA for the expansion of the Marina area with the increased density of townhouses and believe it requires serious consideration. I I I I I I I do not oppose PLA's development of the area with the understanding the development would essentially follow the plan previously agreed upon with Pope Resources. tI4.3.1 ~~~~I 3",.",I"~,....,..,.,3,,.,.,..,.,.I;,,' ..,3.~,.." 414..3..4 3.31 Please try and place yourself in the mind-set of most current members of our community I am specifically concerned about the very significant increase in planned density and the impact such density would have on: . The nature of our community [Resort versus Residential] . P~rking and overall traffic in the marina area . Effect on wildlife in the "Lagoon Area" which so many of us enjoy daily. that choose to spend the balance of our years in Port Ludlow with the understanding ithe area would remain a" Master Planned Resort" - Not a city! Respectfully, ~cc R. E Sowatsky 654 Pioneer Drive Port Ludlow, WA 98365 LOG iTEi\A # IlQ f '!:)age _ I of 1 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I #_~~~ITEM I Page. I - of I 83 Dunsmuir Road Port Ludlow, Washington 98365 ]JDltf~~ JUN -8 2IK JEFFERSONCOUNlY OeD Mr AI Scalf Director Jefferson County Community Development 621 Sheridan Port Townsend, WA 98368 June 6, 2004 Dear Mr Scalf, I am taking this opportunity to voice my concern regarding the Port Ludlow Resort D~-r Supplemental Environmental Impact Statement. In my opinion the dwelling density 1/3 3 4 proposed by Port Ludlow Associates is excessive andparkin9 considerations have been <<.>. inadequately addressed. Your attention to these issues is solicited and appreciated. 4.,3.6 3.3.6 ~ 14 Forester Lane Port Ludlow, W A June 8, 2004 ~"~ _.~.-.. . , Mr. AI Scalf, Director Jefferson County community Development 621 Sheridan Port Townsend, W A 98365 JIt -9 .. JEFFERSON aDlIY DeD Dear Director Scalf: We are writing to you regarding the Port Ludlow Resort Draft Supplemental Environmental Impact Statement (DSEIS). We are particularly concerned about the proposed expansion of the marina area. The proposed increase in residences in the marina area is significant and will have a substantial impact on traffic and parking for the marina. The DSEIS does not provide an analysis of or a solution for the parking and ensuing traffic problems. The proposed prolonged construction will drastically increase the air pollution in and around the marina. The increased pollution will not only cause damage to the boats permanently moored there as well as visiting boats, but may well have a negative impact on the wildlife whose habitat is the lagoon, the shore lands surrounding the lagoon, and marina and waters of the bay itself. These issues are not adequately addressed in the DSEIS. Decisions should not be based on the 12-year-old data. , The proposed construction will also significantly add to the drainage problems in Port Ludlow. It is my understanding that the North Bay Drainage District, the competent agency on drainage issues in North Bay, has not been consulted regarding the drainage issues nor is there any provision in the DSEIS addressing the drainage questions. The substantial density increase proposed in the DSEIS will have a negative impact on our property values. Port Ludlow will no longer qualify as a Master Planned Resort if the proposed expansion is carried out The long-term impact resulting from the loss of the designation, due to the action of the developer, will change the focus of Port Ludlow from a "Village in the Woods by the Bay" to just another residential area. These changes in designation and focus will adversely affect our property values and Jefferson County's tax base. Additionally, the proposed marina expansion calls for the extension of one of the existing docks so far out into the bay that it will unfairly impair or significantly block access to an LOG ITEM #--L(P -3 Page --1__ o~a_ evJovpD I I I I I I I I 114.3.} 3.3., 2/4.3.1 I 3/4.3.1 3.3.2 I 4/4.3.' I 5/4.3.1 I .1 JUM -I - smtSQN 00UN1Y oeo .~ I I I I I I I I I I I I I I I I I I established privately owned dock just west of the marina. Again the DSEIS does not even consider the negative impact on this property owner. We respectfully request that you take our comments into consideration when considering the DSEIS proposed by Port Ludlow Associates. We do not oppose their continued development of the area, but we do object to the DSEIS in its current form. Much more thought and consideration needs to be given to the impact of the developer's plans on the existing community, the environment and the long-term effect on Port Ludlow before any DSEIS is approved. Sincerely, d~ Gerald and Diane Purd ~~~ LOG ITEM #JJR3 Page ~ of ~ A _~.. JUN - 9 2004 PLOD I I I I I I I I See I distribution list I JEFFERSON COUNTY OeD Port Ludlow Draina2e District. Post Office Box 65261. Port Ludlow. 98365 W A 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, W A 98368 Dear: Mr. AI Scalf 3 June 2004 The Port Ludlow Drainage District bas 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 project within or impacting the PLDD per WAC 197-11-455. 2. The SEP A 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 Departinent of Ecology Stormwater 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 bas prepared and adopted a Comprehensive Storm water 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 LOG ITEM # Paae of "2 '.M ~ 2. 1 413.3.' I 513.3.1 I I I I I I I I I I I I I I I I I 6. The Alternative 1: Preferred Project does include stormwater facilities for new 6/3.3.2 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 7/4.3.1 incorporated into the development plans. Areas such as occasional or overflow parking should have specially designed pervious surfaces to allow 4.3.9 for direct infIltration of stormwater, 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 stormwater management, active maintenance would be anticipated. No such provisions 0 are stated in the DSEIS. Additional detail for responsibility and operations (.) and maintenance should be provided. Within the lagoon, settlement of C1 8/3.3.2 ~ 'p= suspended solids is included in one-water quality treatment mechanisms. :z:: However, no discussion is provided pertaining to the maintenance and :::> operation of the lagoon. Is dredging anticipated if so how often? Where ~ 0 . -0 would the dredge spoils be disposed? How will the lagoon be accessed? :z:: :z C> :::>> en 9. Presently pumps circulate the lagoon water, these pumps consume 9/3.3.2 .., ffi u.. considerable electrical power and require maintenance and eventual tb replacement. The DSEIS must discuss the future operation, maintenance and --:>> expenses incurred by the pump facilities. 10. 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. 10/3.3.2 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 11/3.3.3 treatment for stormwater flow, testing should be completed for the existing water quality of the 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 12/3.3.2 after construction is complete. The operation and maintenance of all installed drainage facilities must be clearly stated With the additional private LOG ITEM #~ Page d...., of 3> ~_ 2 residences rather than a larger single complex, stonnwater facilities and maintenance often are ignored until the point of failure. I I I 13. The location of the proposed Admiralty III complex will require addressing both surface water runoffand groWldwater. During the wet season, the groundwater is very close to the surface and it will impact any development or stonnwater detention systems. We recommend that a geotechnical engineer or hydrogeologist licensed in the State of Washington be used to design the stormwater and groundwater system in compliance with the 2001 Department of Ecology Stormwater Management Manual for Western Washington. 13/3.3.1 Very truly yours, L t..l Jim Laker PLDD Commissioner I I I I The Port Ludlow Drainage District was formed in year 2000 to address drainage issues within the greater North Bay. Since the fonnation, 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. JUN -9 20M JEFFERSON COUNTY DeQ I I I I I I I I I I ~ LOG ITEM #~ .jage ~, of ~ 3 I"' I I I I I I I I I I I I I I I I I I ~q JUN 1 0 20IU Hi Folks, June 10,2004 JEFFERSON COUNTY DeD I recently submitted comments on the Dratt Supplemental EIS for the Port Ludlow Resort Plan Revision. First let me paste in my previous email because I have not receiv~d notice of receipt, and Al Scalf, director of Community Development has acknowledged he recently "lost" substantiating documents from a separate communication. i Notice of an extension has been received so I want to augment my letter with the following; Paragraph 3 on page 3-17 beginning with "The North Aquifer" makes claims that are not documented, as well as excluding mention of the current clear cut logging operations, which DNR can validate as a type 4 conversion. A big percentage of the watershed is being denuded as well as prepared for development. This oversight alone is sufficient to require a new DEIS. The following paragraph (paragraph 4) is similarly flawed because there is neither proof nor documentation to support these claims. My claims that this information is not accurate should be perceived as equally valid unless there is documented proof of statements presented. How can I respond to claims that appear erroneous unless I have real information to respond to? I take your invitation to offer comments as a sincere desire to improve the development process. Don't insult the public with gobbledygook. 3.2.2.3. Mitigating Measures Same complaint here, lets see the data! 3.2.2.4. Unavoidable Adverse Impacts Come on! Do not accept this statement. It will institutionalize stealing of water. .~.; And my final comment concerns 3.2.2.2 Environmental Impacts ofr 1/4.3.9 2/4.3.9 Sincerely, Larry Lawson I I 3/4.3.9 I I I I I I I I I I I I I I I I I Grandiose claims are made about the water rights of Olympic Water and Sewer inc. but a few questions I directed to DOE about the OWS combined allotment returned the following email: Larry, These three are under Olympic Water & Sewer: (37) G2-29104 Applicant submitted a new application for 50 gpm. (Pending approval) (47) CG2-21542 Applicant submitted a change application on Certificate G2-21542 to add a well. (Pending approval) (48) CG2-21543 Applicant submitted a change application on Certificate G2-21543 to add d well. (Pending approval) In effect there are no current water rights available to pledge to this project. Maybe they are in transition. But there are rumors of bankruptcy within PLA and granting any further build out on hopes and unsubstantiated claims of abundant water rights for this company is totally irresponsible. It appears we are being conned. Until legal documentation is offered to substantiate all claims contained in this document it is merely an attempt to coerce the County into granting developmental rights that mayor may not be deserved. I suggest you start this entire process over. (See bottom of endnote 1 for address etc.) JUN 10 21m ,.i JEFFERSON COUNTY OeD LOG ITEIVl #~~ Page f)... .... of ~_ I. I I I I I I I I I I I I I I I I I I Subject: comments and requests Date: May 28, 2004 1 :09:26 PM PDT To: developmentreview@co.jefferson.wa.us JUN 1 0 2O(M JEFFERSON COUNTY OeD To whom it may concern, I request that you start this entire process over in order to include pertinent information that has been excluded. Dealing with drinking water there was a reference to the Draft Environmental Impact Statement from the early 90's but the document does not seem to be at hand, and is probably superseded anyway. Statements of water rights are claimed but not verified nor is there a County provided document showing essential figures of the total volume of drinking water granted to all local users by DOE or allowed by Jefferson County through historical usage. To reply to this current DEIS the public needs to know of the total water allocated currently, via the vehicles of water rights and historical usage. We also need to know what the total available sustainable usage is in each of the referenced aquifers, and the actual recharge rate. It is not ethical and perhaps not even legal to have the company selling the water to customers doing the verifications of aquifer health and recharge. Shouldn't this be a County responsibility? Even in the abbreviated version included within this DEIS one footnote is missing. I question why there is a lack of open information provided in useful format when the document is offered to the public for serious comment? This is our home and these issues concern our future health and well-being. The public finds ourselves in a vulnerable situation when our County does not advocate for our community essentials. Water being one of the most precious. Hearing only the focused concerns of a developer should not be the primary purpose of a Government which is responsible to all of its citizens. But based on the previous DEIS process my impression is that the County actually advocated for the allocation of public resources into private use, #l~~_lTEM _ Pag~.,~. of~~ Thank you for the invitation to respond by email. Sincerely, La,'!!! /, ~~ Larry Laws~n. . 10140 Oak Bay Road Port Ludlow WA 98365 3604379143 JUH 1 0 20IK JEFFERSON COUNTY DCD I I I I I I I I I I I I I I I I I I I including our water, without concern for long term conservation. My cautions about the previous developer abnegating their stated responsibility to maintain public services is quite substantiated by the need to create a local drainage district. Shoddy development causes the people of this County to pay for these oversights in the future. A PUD is a tax supported venture to unravel the disasters of poor planning. The requests by the proponent 'may be valid and supportable but it seems the least the County can do is require that all of their claims are proven and documented. In fact the County should be responsible to the public to assure a continued supply of healthy drinking water and even now be using an unbiased third party to assure the level of water available in our aquifers. It only makes logical sense to know what the limits of our public resources actually are, before we approve utilization. Allowing a corporation to have access to water may be taking it from current users, and the information provided in this public DEIS is not adequate to sustain the proponent's requests. Also, the County is our only agency able to manage oversight of all events likely to effect future quality of environmental health. But even today (May 28,2004) there is a clear cut logging operation in progress on top of the north aquifer, but no mention is made about the effect on recharge into the future from this event or other types of further development. As stated above, this process needs to be started over with clear and useful information so that all of us in this County are able to understand what resources we are allocating to who, and how future public use will be sustained. Citizens should not feel forced to take legal action to protect our future health. The County should be the public agency protecting our public resource~. LOG ITEM .,' #-1(pS , page__4 .ofL I I I I I I I I I I I I I I I I I I I JEFFERSON COUNTY DEPARTMENT OF PUBLIC WORKS P.O. Box 2070 1322 Washington Street Port Townsend, WA 98368 (360) 385-9160 Frank Gifford, Public Works Director Robert G. Turpin, P.E., County Engineer MEMORANDUM TO: Michelle Farfan, Associate Planner Jronesvv.peroffion,FToject~anage~ June 10, 2004 FROM: DATE: RE: Port Ludlow Resort Plan Revision Comments on Draft Supplemental Environmental Impact Statement The Public Works Department has reviewed the portions of the Draft SEIS that discuss impacts to County Roads, in particular Section 3.6 Transportation. The Department concurs with the conclusions of the DSEIS, Sections 3.6.3 Mitigation Measures and 3.6.4 Unavoidable Adverse Impacts. Alternative 1 - 2003 Resort Plan and Alternative 2 - 1993 1/4.3.6 Resort Plan are not anticipated to result in significant adverse impacts and should not require off-site mitigation. Alternative 3 - 1999 Resort Plan is projected to result in a decline in Level of Service (LOS) at the Oak Bay Road/Walker Way and Beaver Valley Road (SR19)/ Oak Bay Road intersections to LOS E. Off-site mitigations may be required for Alternative 3. fB) lE (C [E 0 \VI IE rrn U11 JUN 1 0 21M lW JEFFERSON COUNTY DEPT. OF COMMUNITY DEVElOPMENT LOG ITEM #J~ Page "of-1_ 1 00% Recycled Paper .' Daniel & Esther Darrow 110 Sea Vista Terrace Port Ludlow, W A 98365 360-437-9208 JUN 10 20M JEFFERSON COUNTY OeD June 7, 2004 Jefferson County Department of Community Development 621 Sheridan St. Port Townsend, W A 98368 Reference: DSEIS for proposed Port LudlowResort Plan Revision Weare writing to express concern regarding the proposed Port Ludlow Resort Plan Revision and Draft Supplemental Environmental Impact Statement dated April, 2004. The proposed increased density of the residential units will seriously affect traffic access, parking availability and emergency vehicle access to community amenities. Of particular concern is the large increase in non-pervious surfaces caused by the additional roof tops, paved roads and parking areas with resulting increase of rain water runoff This runoffwill potentially include harmful oil and other material that may pollute the watershed and bay. We feel that serious consideration should be given to reducing the site density in order to preserve the environmental habitat. In addition, we suggest that the overall site plan include the use ofbioretention sites, rain gardens and pervious surfaces wherever possible. Attached is information on Low Impact Development using pervious concrete to mitigate runoff and protect the marine habitat. Full information on Natural Approaches to Stormwater Management and Low Impact Development can be obtained from the Puget Sound Action Team, web site www.wa.gov/puget sound~;7 Respectfully submitted, ;;ftltud7 ~~tnJ /"', .:---/ .A ~T v1,...'r Daniel and Esther Darrow LOG ITEIV1 # -LLP1 Page l -40- of-La:- I I I I I I I 1/4.3.61 3.3.6 2/3.3.21 I 3/3.3..9 I 4/3.3.t I I I I I I I I I I I I I I I I I I I I I I I I I I Jefferson County Department of Community Development 621 Sheridan Street PortTo~nd, VVA 98368 Re: Draft Supplemental Environmental Impact Statement (DSEIS) for Port Ludlow Resort Revision Plan Attention: Mr. AI Scalf Director of Community Development Dear Mr. Scalf: As a 13 year resident of Port Ludlow, and frequent battler with PLA, we want to strongly object to the above DHEIS and ask that you reject it in its entirerty. The statement they make that this plan will be good for the residents is pure fiction. I. ~,~t of additional units to a total ofl01 will cause heavy and dangerous traffic. 2.,.~:(trage buildings will be placed right in what is left of the views at buildout.a J,o;,,!,~_9nly one entrance to the entire waterfront complex and the Beach Club and the Admiralty '~~.II, Fire equipment, and Emergency vehicles will be difficult if not impossible to manage. 3/4.3,..'1 ;,4.;i~~BSsumeS the use of~he ~each Club parking lots far beyond what has bee~ ~eed to so far'4/431 ' )otwhen the North Bay IS built out, there wont be enough for the member actIVItIeS. . '..,' ;.;.~.' Mnay residents are aheady leaving the community instead of living out their Golden Years as 1/4.3.2 , Y they were told they could when they bought the property. Please DO NOT let PLA spoil what is left of our beautiful area Thank you for reading this. Sincerely Lenetta and Bud Johnson 64 Ames Lane, Port Ludlow, VVa 98365 fi5), IE ~ IE 8 1M' IE ~ lru JUll 11 2IXM I!:lJ JEFFERSON COUNTY DEPT. OF COMMUNITY DEVElOPMENT LOG ITEiVI #--L1e~ Page --J- otL_ May 24, 2004 [5) IE (C IE n 'W IE ~ .\rU JUN t t 2004 li1J Jefferson County Department of Community Development 621 Sheridan Street PortTo~nd, VVA 98368 JEFFERSON COUNTY OEPT. Of COMMUNITY DEVELOPMENT Re: Draft Supplemental Environmental Impact Statement (DSEIS) for Port Ludlow Resort Revision Plan Attention: Mr. AI Scalf Director of Community Development Dear Mr. Scalf, As the property owners most impacted by the DSEIS for the Port Luqlow Resort Plan Revision, we strongly recommend you reject the DSEIS as written. The Lot Owners Association of Port Ludlow (LOA) represents over 532 fulltime residents and a total of approximately 1,000 taxpaying citizens. The following items represent our major concerns for the safety and welfare for the citizens of our community. . Vehicle traffic has been ignored for the most part in the DSEIS, and will be a major factor in how the build-out will cause serious problems related to safety, i.e., emergency, delivery, and construction vehicles. In addition, once the build-out has been completed and the population is increased, the flow of traffic and parking, as shown in the current DSEIS, is not adequate. Another consideration should be the intersection of Walker Way and Oak Bay Rd., an extremely dangerous intersection. Marina View Dr. is the only street that connects the entire Resort complex as well as.,.,",'" Beach Club. The County, to prevent the potentially deadly accidents that are sure to occur, ','uld consider this a number one priority. . l . Developer responsibility to the Master Plan Resort Designation has been an uphill battle for the citizens of Port Ludlow. Although Port Ludlow Associates (PLA) has the right to complete the resort development originally started by Pope Resources, we are concerned that the current DSEIS, does not protect the community from irresponsible development. Ifpast performance is indicative of the future, a viable resort is not likely, and the community could be left with an overcrowded subdivision. I I I I I I I I I 1!4,! 3.y I 2/4.:i I . The Beach Club is a private club, serving the needs of the residents ofthe North Bay community. I PLA should not assume that the Beach Club facilities and/or parking spaces will be available for 3/4.3f conferences, etc. Although PLA does have a current lease with the Ludlow Maintenance Commission (LMC), the Beach Club's operations management, this lease, which provides for use of28 parking spaces for overflow parking only, will expire in 2013. The reference in the DSEIS to 56 available parking spaces is not correct. In addition, offstreet parking for the new residental area is not properly addressed in the DSEIS. VVith the increase in population density LOG iTEM # Page-t- of I I I I I I I I I I I I I I I I I I I I I I Jefferson County Page 2 proposed by PLA, it appears there is not adequate parking for the condo and townhome residents, the marina, the Harbonnaster, and the new recreational facility. · The LNP 25.5 states that ~'Port Ludlow shall accommodate a variety of housing types, including affordable housing, single family and multifamily housing, and assisted living care facilities." 414.3.11 The DSEIS makes no reference to any assisted living care facilities. This type of housing would be a desirable addition to benefit the community. In summary, the DSEIS should be rejected in its entirety because of significant errors and omissions. As it is currently written, it does not adequately address the environmental impact to the resort and the Port Ludlow community. Thank for your attention to this important matter. W^lB~^.:~~~~~~ rJi~~eWlS, P Sl ent LOG ITEM p~~:l of ~ ADDRESS I I I I I I I I I I I I I I I I I I I WE, THE UNDERSIGNED, CONCUR WITH THE ATTACHED LETTER. MAY 26, 2004 NAME LOG ITEN1 ~~J ._ofl ~\:::) ~~~'("\C'\'-~ ~ Ort"'~t] CA/ :20 tit ~~~ //;J~~ ~ ?/3 I I I I I I I I I I I I I I I I I I I WE, THE UNDERSIGNED, CONCUR WITH THE ATTACHED LETTER. MAY 26, 2004 . I - . ,/~ JL(L-rl""'~~ J < eJjj H __ A ,0, tAUU - '-'>< .~~ l()-.J2ee~ , \;\ C\ L LOG ITEM # -11ai Page~of ~ - ~~L5 It\JVf P,L CZ8?kS /:J.. 0 B~'t'OJ LA-1v ~ 3~~ /7:3- f)o6lE& UWe- 1eS- g-::;c;C ~~. /-0 r' - ('I J/ ,..) XJ..s ...J /jA 1/'...f'i>1 / I $I .;{ s- J ~ Q) (j ~r~d ~X J pr L U{tt~ it/.~ ~~: - .. J /g-).. o(~.i 9~3b>/ ./1 ' I<' ('-1021_C 10 D V\cu.4~/ ~ . f (, Ilj.;)~ 7 .' rr:.:r~ WE, THE UNDERSIGNED, CONCUR WITH THE ATTACHED LETTER. MAY 26, 2004 NAME ADDRESS ," ~ ~ . /) ) _' ? /} -J/ Cl~€ 1('--' '?'<~C- IlZ~~. - ,/ v ,'/II' '. ,/1'77,' '7~} / y<', ,;;/ I /. .' . / / j/ ! ~", /)if,1' v'J:J1.a./ u;/ . I { .' )'/ "~'- U , . lJ, J . ",.' , , //~ t.. , ~-,Hl<-' - , i /7 \ !.l~ "I \..J It h l{lYA/f;'t-11/2,.tA--, ~~ E:-,-F-- k rL t/1 OJ (,." /1770 ~. r. VL- 1-..-/ /"-O~,~" "7~o ;.?n (-I?..v'1" ;)/Z J .;') j LLf'/(' l' /1 1.-hI Z- fA, f1..:ztJ ~. .Jtl / . )7. b ~JUT-e 14#/-<. 6' '3 Sto -rr- (WI<. / I '~( C c( (-4-P- L~ ~) KA.Q~vyn (;r. /D I ,Ilth'- 'I't{tl/ LH. dal 5. J/;P iJ~ ~() ~~"" \.6 tL '/J..". ~ L... /0 \. ..1.......\\ .... ,J:.., .:- n r;;;L.vv,) . ~l/ I '. "i --J C/V'-~'l"\.'\. .~_.., / \.) (:.-';~ .~/ ,"', n _, I -' L . , f 1--) I<C I ..... / '\ ;.' ;-... i'l IV t.-- / ."'"\ /1 'I.~ l -.... . ~ /... , ,h-',-:-,v Ii (, l/v.J 1 ' ''1. 7/ . . :) t~Ju A_ / / I (')7./ <ic .P, J/7 /'! 0 ....:--- r V lroLL-"'1 / _j ..-:? " .~, . ,I '. Ii LOG ITEM p~~~} _of <L I I I I I I I I I I I I I I I .c. I I I I I I I I I I I I I I I I I I I I I I V I. L ' -? J' t .- WE, THE UNDERSIGNED, CONCUR WITH THE AlTACHED LETTER. MAY 26, 2004 NAME (J I /lYf..J. f }O it ~(}f ~,fhfJ(e;v . ?Jq/w" !Ja.nYA/J ,~4/L/{ 1 b# ~7 G>/j(<. v (( 1.1 S f.I J c.;;tZ ,~~i3?gr;,('J \j, ADDRESS 3 ~ T,; {.(rA c..c~ I ,;(/ - .u .5 7 1\ ~ ,?CtLtU___ :1' 7 I PA f i11 p r J.. tlA'l.L- q, ji\ .' ~/ffiRMS LAA/E WE, THE UNDERSIGNED, CONCUR WITH THE ATTACHED LETTER. MAY 26, 2004 NAME ADDRESS '~ -- I- )Y/ '/"l C:' <--:} ,J}"'- L,..; /"'L- '-'f ~ ~kM)jrt tC/':>i:')c~Q /:#;&HC'l/ AU?J"I't/a~pp~;"d;J , 1/'P?t:?.f kU!;,,' . ~Dfyt([0 rflvvv~ L\iJ~ k ';'Y-J/lfL,( ~t/ r~~7~~ U t3 l?~ld ~/J ~ L~ ~ (OJ. !JI~ ~ ~ \O~,J-~ LOG iTEfV1 #~ Page 7~ ~otL I I I I I I I I I I I I I I I I I I I NAME ADDRESS ~ Ii VV1e...s L..a tJ I I I I I I I I I I I I I I I I I I LOG !TEM #-11. ~ Page ~ - 0(3- I ~ WE, THE UNDERSIGNED, CONCUR WITH THE ATTACHED LETTER. MAY 26, 2004 ~//:o";~L), .9 ~//b- 76 S~ {lj: /ddd- ~7 .J cuJr~& <:.e/lc ( Ii r---,. [ l lU"--i , I . \ J. DWAYNE WILCOX 271 Montgomery Lane Port Ludlow, Washington 98365 (360) 437-5056 JUN 1 0 200; JEFFERSON COUNTY OeD June 9, 2004 Jefferson County Department of Planning 621 Sheridan Street Port Townsend, Washington Atten: AI Scalf Re: Port Ludlow Associate Associate Assn. DSEIS Dated April, 2004 Dear Mr. Scalf. This entire DSEIS submission should be rejected by the Planning commission as containing fauhy, incorrect, and incomplete analysis, and further is based on outdated investigation. The last DSEIS was done in 1994 and therefore this supplementary DSEIS submitted is based on stale and incorrect data provided by a different developer and company. This community has undergone substantial growth and change during the last ten (10) years and such is not addressed in this document. Having served on the Jefferson County Planning commission, I was led to accept the proposition that mitigation is imposed on a plan to effect a lessening of a negative impact on a given planning change altering the natural and usual visual scene. The 1994Plan required the pond be restructured in mitigation of the natural and usual visual scene. This was done to soften the impact of construction in a natural beauty area. Now PLA is attempting to do away with the required mitigation by construction over the pond. This construction flies in the face ' of the Shoreline Management Act and the previous requirements. The over the pond construction would do extension damage to that pond area, water and natural habitat. The DSEIS as submitted does not address any of the items of damage to the pond, the parking, and the supposed need to build over the bond when there is more than ample area to build in otherwise and without damage to the areas natural beauty. At the time we bought our homes the 1994 plan was accepted as the future of Port Ludlow and was accepted by the public. The plan proposed by PLA changes the entire character of the city and invites challenge to its MPR designation without attempting to justify the change in original philosophy and direction. The total effect of the proposed DSEIS will be to lessen the quality of the Resort development LOG ITEM #j70 p ape --1- of B- I I I I I I I I I . 1/4.3.' I I 2/3.3.' 4.3. I I I 3/4.3.2 I 414.3'1 I I I I I I I I I I I I I I I I I I I I culminating in crowded areas impossible to fire and emergency equipment and an area deprived of its natural beauty and amenities in favor of concentrated density and impaction of an area otherwise mitigated to retain visual beauty and a healthy and natural habitat. This DSEIS fails to address critical items as follows: A. Impact of the drainage problems to existing areas of the city and what must be done to address those problems. B. Excess traffic and parking problems to non-county owned roadways and what must be done to maintain these areas after the developer leaves. c. Substantial elimination of access to beach areas. D. Habitat and mitigation violations. All of these problems were brought up during the scoping hearing, but have not been adequately addressed or even touched on in this report. For the County to accept this submission as adequate would be a gross disservice to the citizens of Port Ludlow and to the people of Jefferson County generally. JUN 1 0 2004 JEFFERSON COUNTY DCD LOG iTEM #_l70 Oage. ~_of ~ 5/3.3.2 614.3.6 3.3.6 7/4.3.1 8/4.3.4 Page 1 of2 I Michelle Farfan I From: AI Scalf Sent: Monday, June 14,20048:16 AM To: Michelle Farfan; David W. Johnson Subject: FW: Construction at Ludlow I I For the DSEIS file AI -----Original Message----- From: Dan Titterness Sent: Monday, June 14, 20047:25 AM To: AI Scalf Subject: FW: Construction at Ludlow I I -----Original Message----- From: Powers & Therrien [mailto:powers_therrien@yvn.com] Sent: Saturday, June 12, 2004 12:45 PM To: Dan Titterness; Glen Huntingford; Pat Rodgers Cc: Jeanne & Peter Joseph; SchmitzSr@aol.com; Kaysins@wellsfargo.com Subject: Construction at Ludlow ' I I Dear Sirs: I There is a pending Draft SEIS applicable to a material modification to the 99 Ordinance and Development Agreement applicable to PLA and Port Ludlow. You have circulated the draft for comment. Comment is due on June 14,2004. I Sometime prior to the closing of the comment period, PLA applied for permits to construct the improvements contemplated ~ by the Draft SEIS. As noted therein and in the Ordinance, these require a hearing before a hearings examiner. To the extent they contemplate the modificaiton of the existing 1994 plat (the "Plat"), as noted in the Ordinance and Development 114:3 . Agreement, they also require consent of a majority of the persons owning interests in the Plat. The hearing has not yet been .. scheduled. I Prior to the hearing and the receipt of comments on the material modification to the 99 Ordinance and Development Plan, I have been told, PLA has commenced preliminary construction work on the modified project by staking building sites. The I buildings that it proposes to construct on the sites vary from those permitted in the Plat. The Plat and the SMA approved plan provide for 53 townhouses and five single family dwellings. The building in the plat across from the building in which my townhouse is situate contains four townhouse units in the Plat. The revised plan substitutes a building containing six condominium units. Such a change is a variance from the Plat. Work thereon should not be approved or undertaken in the ~ expectation of approval without obtaining approval of the Draft SEIS, a hearing before a hearings examiner that modifies the existing 99 Ordinance and Development Plan, and approval by a majority of the persons owning property within the Plat. 214.:3. ... ., Please provide a copy of this email to Mr. Scalf and to the Building Department for further action. Pending the approvals I identified herein, all construction and activities directed toward constructions of inconsistent improvements on the Plat should cease. Please investigate and confirm the situation. I will be calling your office Monday morning to determine what action is being taken to prevent a breach of the rights of the residents of Port Ludlow and of the persons owning interests in I the Plat. I have not made a determination of my view on the material modification proposed by PLA. Be advised that I do not intend to indicate my approval thereof through inactivity. I Your assistance in this matter is appreciated. Les Powers LOG ITEM #171 Page-L_of_L I 6/14/2004 I I I I I I ,I I I I I I I I I I I I I I Page 2 of2 Powers & Therrien, P.S. 3502 Tieton Drive Yakima, WA 98902 Phone: 509-453-8906 Fax: 509-453-0745 This email is covered by the Electronic Communications Privacy Act, 18 U.S.C. Section 2510-2521 and is legally privileged. This message and any attachments hereto may contain confidential information intended only for the use of the individual or entity named above. If you are not the intended recipient(s), or the employee or agent responsible for delivery of this message to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this email message is strictly prohibited. If you have received this message in error, please immediately notify the sender and delete this email from your computer. LOG ITEM #~ Page ~"- of _~. 6/14/2004 . . ,., J! evYJGY , I' f I'~ j (L-f 0 Y- 1..9/, \ \ \ \ June 12, 2004 Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, WA 98368 To whom it may concern, I have been a resident of Port Ludlow for most all of the last 24 years. I currently live at 100 Fairway Lane, Port Ludlow. I write to you to comment on Port Ludlow Associates LLC (PLA) Draft Environmental Impact Statement (DSEIS) submitted in April 2004 relating to the Port Ludlow Resort Plan Revision. I endorse your acceptance ofPLA's DSEIS as submitted. It has addressed the appropriate issues brought forward through the public comment period, as extended and has also properly built upon all previous environmental reports as required by the numerous governmental agencies involved with development regulations for this property. In particular PLA has addressed what is required in the current county zoning regulations relating to a supplemental environmental review and the agreed upon process for revisions to specifically approved land use designations. I understand these zoning regulations, as well as other regulations appropriate to Port Ludlow's future development, are secured at least in part by a Development Agreement executed between the landowner, now PLA and the County. My question, my concern is, when is enough, enough? When can a developer depend upon a process to move forward with an agreed upon plan, one secured after years of deliberations, compromises and after spending over $1,000,000 in planning costs. PLA's predecessor invested this time and money to help create a unanimously supported Comprehensive Plan Designation, Zoning Ordinance and Development Agreement. All involved; including regional and state-wide environmental groups, local owner associations and other community groups within the MPR boundary"helped create and supported these regulations. Please refer to the July 15, 1999 letter to the Board of County Commissioners from the Mediation Stakeholders regarding this topic. When is enough, enough for County Tax payers? Jefferson County has expended significant taxpayer dollars, possibly a hundred thousand dollars or more over recent years, in addition to thousands of staff hours deliberating Port Ludlow's development. LOG ITEfVi # 17~ Pagei_of_~_ I I I I I I I I 1/4.3.11 I 2/4.3.1 I I I I I I I I 101 I I I I I I I I I I I I I I I I I I Jefferson County officials endorsed executing a Development Agreement, in part, to secure some sense of assuredness that the investment of taxpayer's money and staff time would not be wasted. This particular objective was one of the driving forces for developing specific language in the Zoning Ordinance that addressed the supplemental Environmental Review processes (Section 3.904) and the process for Revisions to the Resort Plan (Section 3.906 & 3.907.) It is my hope, as it is of many others, that enough is enough as it relates to honoring years of work by both the public and private stakeholders. The significant investments of funds and time can only be recovered through sensible and timely development and the resulting property taxes. Professional companies and individuals prepared the DSEIS. It is, as was agreed to, a supplement to the other environmental work that has been previously accepted by all the appropriate regulatory agencies and must be viewed on the merits it is addressing. PLA has seemingly followed the contractually agreed upon procedures for the development of their land. Will the County? Sincerely, Michael Derrig 100 A Fairway Lane Port Ludlow, W A. 98365 Cc. Board of County Commissioners David Goldsmith LOG ITEM #--1 7:2., Page ~ of_~ --, ; ~~, r ~+-tJ( eu Cs,jlCf(OT I David W. Johnson I From: Sent: To: Subject: john march [johncmarch@comcast.net] Monday, June 14, 2004 11 :22 AM David W. Johnson DSEIS for Port Ludlow Resort Plan Revision I Attention: I Mr. Al Scalf Director, Department of Community Development Dear Mr. Scalf: I In reviewing the "Draft SEIS-Port Ludlow Resort Plan Revision"", we are concerned about a plan which eliminates most of the open space and rural feeling which first drew people to the area in the late 1960 I s- 1970 's, and today. 11S.al We appear to be facing a high density issue in areas close to the waterfront of Port Ludlow, with little or no attention given to open spaces, drainage, parking, and public access to the beach. I With the additional condominium units in the proposed Admiralty III , the developer implies that he is trading existing open space in and around the Conference center for~l".iSi'....'> the open space lawn area below and adjacent to the Admiralty I & II condominiums. The lawn area in question is private and belongs to the owners of Admiralty I & II. It is not open space as the developer defines it. The proposed "stacked" units of condos in Admiralty III are tightly packed, with lit.t....l....e.....~.. thought to proper drainage. Drainage and seepage from the existing open space has caused. .. '. problems to the integrity of the paved parking lots in Admiralty II, resulting in :3 313.3.' expensive repairs. Even with the proposed 'drainage pond', the Admiralty III units will create extensive water run off and cause us further problems. Because we are considered an area of "Landslide Hazard-Medium Risk", adding more hard surface area above us for water run off without proper drainage will create a greater risk of landslide for the residents of Admiralty II near the shore. I I We are also most concerned with a potential parking problem. The proposed'Admiralty III units will have space for two cars per unit; however, this will be tandem parking, one car ;~ l~r~~~i~f p:~~~~~r ~n L~~~C s~~~~~ . U;h~~~t o~-:;~~;s=~'~i~~t i~t~~ t brn=~~~s a~n~r~:~~::e~~r :;;.........3.............1......... local traffic and emergency vehicles 'rf3. ..... Although PLA does have a right to develop its property, it must be done responsibly I and with regard to the residents of Port Ludlow. A loss of community open space, possible drainage problems, increased parking congestion, and inadequate beach access are not in the best interests of residents Port Ludlow. The vision of PLA is no longer that of a 514.3.2 planned resort community, but instead, a subdivision of high density housing and limited I public access. We suggest that PLA re-examine its current proposal to address these and the many other issues brought forth by the residents of Port Ludlow. I Sincerely, John & Lynne March (Owners since 1999) 322 Admiralty Lane Port Ludlow Admiralty II Condominiums I I LOG ITeM #_t;:t Page ,_ otl__ I 1 I . ".. I I I I I I I I I I I I I I I I I I I P,' i ( ,f ( u(' 't) U \J'l/Jre vc::-jJ Vi, { -,- , ! ROBERT H. HERBST II P.O. Box 65399 Port Ludlow, WA 98365 Jefferson County Department Of Community Development 621 Sheridan st. Port Townsend, W A 98368 JUN 14 2UO~ JEFFERSON COUNTY DeD June 13, 2004 Re: DSEIS for Port Ludlow. Gentlemen: My wife and I moved to Port Ludlow in The fall of 1988 and built our house on property we had purchased ten years earlier. We felt that we had options, and, rather than moving here simply because we owned property, we spent the better half of a year studying those options. We selected Port Ludlow because of the ambiance of the community; the lovely grassy lawns weddings during the sunny months in tents erected from time to time for that specific purpose; people walking their dogs; families having group photographs taken. It was charming and we bo,-!ght into it. One thing that helped us make up our minds was a map, given to us when we originally purchased the land. It was a black and white map of the community with green areas. A foot note told us that the green indicated "green belt". Two portions of the green shading, near the golf course had black dotted lines with the words "future condominium area" inside of the indicated area. I no longer have the map, but all of the area being considered in DSEIS was green. There were no dotted lines; no notation that the area being considered was LOG ITEM #~~ Page--L_9f_~__, 1 /4.~.1 4.3.2 . -"'l!Ii I I I I I I I 2/4.3.2 I I I I I I I I I I I I ROBERT H. HERBST II P.O. Box 65399 Porl Ludlow, WA 98365 to accommodate condominiums. Well that is in the past and I realize that you have gone too far to go back to what was. But is there any justification (except the good old "bottom line") for creating a rather high density housing complex? Most of us recognize that the owners of the land have a right to seek its highest economic potential, but where does the county draw the line between what is fair for the developer and what is in the best interest of the people who live in this community? We have now been designated a Master Planned Resort. It certainly does not look to be one. This latest request will further disguise the resort aspect of our surroundings. More to the point we are on a fast track to becoming a housing development; a rather densely populated one at that. I strongly urge the County refuse to allow an increase of 30 units, from 58 to 88, a 51 % increase. Sincerely yours, G~//~ ROBERT H. HERBST JUN 14 2004 JEFFERSON COUNTY DCD LOG ITElVl #J'Y, Page ~,_of~_ , . ' J! 0/#1 C1' ~~ i ~ ,(7 J- l/L J ,kv% ~,a, r;~ vf ~ 1"1 vc-e ,Dc . J~. JVJ ~ <-vd-t_ y.te. ~ :f ~./~, --"l-:t:i:2L -11< ~ ~ 2 ~ ~ , ,JUne14.200it:-;~ a-,J .J.4" ~ ~ ) ~rso~ounty r!e;:artment of Community Development ~S/~ ~~' ~"""{jt.j/{;~. 621 Shendan Street ~ 1" '!' Port Townsend, WA 98365 bT6..f ..1'- FA lLLA I/. -r TtM ~2-f2-{ j)?13- IJI7- ?c>t2--rf-v1>i-PV IA/A ']~J6r I I I I I I I I I I I I I I I t ~ I: ,"'~ i ' ~ , I :::'11 I ~ ~ Dear Sirs, We are writing as individual members of the Port Ludlow Village Council Conununity Development Committee to conunent 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 Mana2,ement Pro2,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. 1/4.3.1 Parkin~ . 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 c 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 i:= parking. This will create safety hazards for emergency vehicles trying to enter the area. z This deficiency must be corrected. =:::> o (.;) Traffic Witbin the Resort Area ~ LOG ITEM en ffi #l7S"" L.L- .- tb Page _.-L__ot_:?__ --::> 2/4.3.6 3.3.6 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 of the 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 Drainae.e 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 nQt 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 tbe 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 # 17~ Page ~ ~ _.of3__ I I I I I I I I ,3/4.3.4 4.3.. I I 413.31 I I 514.31 I G/4.3.L I I Alternative 1-2003 Resort Plan I I I I I I I I I I I I I I I I I I I 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 114.3.10 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 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 # '7S- Page .~ _of ~ ~,~ JUN 14 20M JEFFERSON COUNTY oeD June 14,2004 Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, WA 98365 Dear Sirs, We are 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 witb Shoreline Master Manae:ement Protmlm 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. TIris 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 order to have ready access to each vehicle residential owners will most likely park one vehicle 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. LOG ITEM #..J~ 1 Page . of J:L_ I I I I I I t/4.3.1'1 I 1 2./4.3.11 I I 1 3/4.3.61 3.3.6 I I I 1 I 'I I I I I I I I I I I I I I I I I I I Traffic Within the Resort Area 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 ImDact to Habitat The DSEIS does an analysis of the impact of the 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. Stonnwater Drainae:e 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 LOG ITEM #17f.R Page 2 ofL 4/4.3.6 3.3.6 4/4.3.4 5/3.3.2 6/3.3.4 4.3.3 ~, ....... proposed in the DSEIS and it is not possible to determine from the site maps where each 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 1-2003 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 #-1] If Page~~. ,_O~, _~ I 7/4.3.1' I I I 8/4.3.10 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I ~. ( 7t~k 0~$~ 563 Pioneer Drive Port Ludlow, W A 98365 hn Golden I I Edgewood Drive rt Ludlow, W A 98365 {/ ~Ug H <ring 227 Edgewood Drive Port Ludlow, W A 9836 ~ Marie Lytal 64 Cascade Lane Port Ludlow, W A 98365 ,"'/;-" , V To cCay , 40 Mariner Place Port Ludlow, W A 98365 N. /~M~4f~""<u~ Cl,~~~,Jc V V Bruce Scliinitz ' Fnink Siler Howard Slack 7] 7 Raiui" Laue r/ 7] Harms Way 100 Pathfiuder Laue . W A 98365 Port Ludlow, W A 98365 Port Ludlow, W A 98365 ickeham 4 Crestview Drive Port Ludlow, W A 98365 LOG ITEM # .-L7Ct ' . Page ~ of.~" I I 'JUN 14 20M I 4EFFERSON :COUNTY DCD, I I I I I ~ -'..,p.. _ ;(l~.r:~r-:::;'~~~--:)~;\ lij '"",';~'" '~~, ni'''i~'\t,''''','j' ~,'-"~;r.:> ,', , rt' I "k'" '~,' ~"', \ "," ..' l \r'l " ;~~' < ""'~ Howard and Carol Slack 100 Pathfinder Lane Port Ludlow, W A 98365 June 12, 2004 Mr. AI Scalf, Director Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, WA 98368 Dear Sir: We would like to add our voices to the many who are very concerned about what will happen in our Community if the Port Ludlow Resort Plan Revision's Draft Supplemental Environmental Impact Statement (DSEIS) is allowed to stand as it is now written.. We are particularly concerned about the revision increase in residential density from 122 to 190 units overall (an increase of 56%). This represents tremendous overcrowding of this area, is aesthetically displeasing and creat~ unmanageable parking and access problems for not only the residents but also for the Marina patrons and guests. We are ones who strongly opposed an increase in density for the resort in 1994. We just as strongly urge the County to reject it again. Sincerely, qvo u-J aft' cl-<1A c-/:6~ ~~ LOG iTENl #--.17] ~ __. PageJ_ of._L_,_,_ 1/4.3.4 4.3.6 3.3.4 3.3.4 I I I I I I I I I I I I I I I I I I I I I I I I I I I I Vaughn Bradshaw 61 North Bay Lane #13 Port ludlow, WA 98365 June 9, 2004 JUH 14 2004 JEFFERSON COUNTY OeD Jefferson County Department of Community Development 621 Sheridan Street Port TONnSend, WA 98368 Comments on Port luc:tIc:Mi Resort Plan DSEIS: I am a resident of Port LudJa.y, and am very concerned about the pIannecI revisions to the resort here. The plan of increasing the residential density does not realistically address how the additional parking for the proposed new residents and there guests will be accommodated. It appears to rely heavily on street side parking, but there is not physically enough space for all of the proposed new cars. The result Y<<JUId be extreme traffic congestion and competition for too few partdng spaces for the new residents and rorrent users of the resort. And how will the fire departn lef1l gain access to fight fires with the road Mfths reduced t7t the a'CModed partdng? It also appears that the obvious increase in storm water runoff from the increase in impervious surfaces has not been addressed. Furthermore, it appears that public access to the common beachfront Y<<JUId be diminished t7t the proposed revisions 10 the resort. Please do not approve the planned revisions until these issues have been adequately resolved. Sincerely, ~t~ Vaughn Bradshaw LO~ ITEM #.l?~ Page-L__ofL 1/4.3.6 3.3.6 2/3.3.2 3/4.3.7 Jefferson County Department of Community Developme~,W~.' June 11,2004 621 Sheridan Street .' · , ~!U Port Townsend ,- Washington, 98368 JII 14 2004 JEFFERSON COUNTY OeD Dear Mr. Scalf: The currently proposed Port Ludlow development is almost identical to the one that was presented to the Jefferson County Pl~nning Department twelve years ago. At that time, our Community had negative reactions and strongly opposed this development, citing overcrowding, high density, parking problems, a detriment to the environment and an unsightly addition to the area around the pond and near by Marina. Now a new EIS has been presented to the County Planning Department, with the hope of getting approval for this previously unacceptable plan. Why is the developer so intent upon overcrowding and overdeveloping? The only answer is money and more money. Of course a developer needs to make money, however, does the developer have to make money at the expense of the community? Land already platted and approved, in that same area, is available to the developer. The sale and wait list for the same townhouses that they originally planned on building is proof of continued profit, if more of the same are buili. The developer could start construction on these at any time. The currently proposed clustered units, on the land below the "Harbor Master" will obviously be used as part time rentals or even as supplementary hotel rooms. The ill thought out Inn has failed to turn a profit. Evidently, the extra accommodations seem necessary to the developer in order to provide more hotel space. The hotel guests had a view, but then the town houses were built obstructing that view. Now the developers want to add insult to injury by covering the land near the pond and over the pond with high density housing for a transient population. When it is done the developer leaves the mess and we are stuck with it and lower property values. What benefits the developer turns into a financial disaster for the permanent resident. Please insist on another complete BIS and an honest evaluation of the impact that this proposed development would have and the consequences to the environment, parking and s3fety, oot to mention the aesthetics of our community. The EIS that the developers presented to the County is not specific, does not address all issues, and is unprofessional and incomplete. We, as residents and tax payers of Jefferson County, ask that you will realize how crucial it is for the Jefferson County Planning Department to step forward and help our Port Ludlow Community by insisting on a professionally done EIS. We are grateful for your support. Sincerely, p( ~ ltJ2-er- lAA ~~3~~ E&3 Pi- LOG !TEM #-1)9 Page. J _0(._.)., ~/~~ I I I I I I 1/4.3.1 , 4.3.21 4.3.6 I 214.3.1 I 3/4.3.1 I 4/4.3. , I I I I I I I I I I I I I I I I I I I I I I I I John Golden 101 Edgewood Drive Port Ludlow, W A. 98365 _14- ~OO CQUN1"l DeD May 28, 2004 Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, WA. 98368 Subject Port Ludlow DEIS Dear Staff, My wife and I have had a chance to review the DSEIS that covers the proposed changes to the current plans for the development to the harbor area of Port Ludlow. Of the many concerns we have, the one that seems the most disruptive to the tenor of the community is the proposed increase in housing density in the area adjacent to the marina. Our concern with this density centers mostly on the lack of parking for the proposed houses. People having guest over for a dinner party will have no adequate parking near there home and this will cause illegal parking in front of drive ways and in the street inhibiting access by emergency vehicles. Providing parking in the Marina area a quarter of a mile away is not going to work. 113.3.4 3.3.6 4.3.6 It seems that the only logical solution is to revisit the density and parking issue in reviewing this proposed plan. There are some issues concerning the loss of a good portion of the pond in front of the Harbor Master restaurant but this also comes back to the housing density proposed. We hope that you will take these concerns into serious consideration when reviewing the proposed DSEIS. Respectfully yours, i /1 r'{\ .1 fA......' \ , : ) l ..//_._~ .. ,..,-, .+'-"" / j i (e/( /.l,---- "-v " ",j LOG !TE~II #.-lW ~ Page L,,_of..L In your review of the Port Ludlow Resort Draft Supplemental Environmental Impact Statement I urge you to closely consider the present and future parking requirements of ell resort facilities. These facilities include the proposed marina expansion which seems to have been omitted from the Draft EIS. In that resort parking is presently inadequate I carl not support the add~ion of any dwellings or other facilities in the resort area. 1/4.3'1' .... 3.3. 83 Dunsmuir Road Port Ludlow, Washington 98365 ~~~,(~ .1.~ JEFFERSON OOUNlY OeD! Mr AI Scalf Director Jefferson County Community Development 621 Sheridan Port Townsend, WA 98368 June 10, 2004 Dear Mr Scalf, ~erick H. King~ LOG iTEM # Iq 1 Page_.J._ofI~, I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 1/4.3.6 3.3.6 John Armes 114 Dunsmuir Rd Port Ludlow, WA 98365 rJ;j~'~." ,~{)" , if,'J', i \ ~. . " ~... ; .lU\4 14 20M JmtPSONtOlJ"TI bea June 9, 2004 Jefferson County, Department of Co1lTl11lmity Development 621 Sheridan St. Port Townsend, WA 98368 Reference: Port Ludlow Resort Plan Revision Proposed by Port Ludlow Associates Draft Environmental Impact Statement This letter is to voice my obj~ions to PLA's revised resort marina area design. The design is, in my opinion, fatally flawed because of a severe lack of parking. The parking in the area of the present marina is now jpst barely adequate during peak marina use times. Indeed, this past Memorial Day weekend all existing parking spaces were full and the gravel overflow parking lots were full as weD. WIth the construction of 100 additional marina slips, the addition of a restaurant, the construction of a recreation center and the addition of several housingUIUt:s adj~cent to the marina, the planned parking would be grossly inadequate. Most marinas have their parking directly adjacent to the moorage so that marina tenants and gqems will have ready access for transporting supplies (coolers, duffels, sails, tools, etc.) to their boats. The procedure is as follows: you park your car in the p;rrkinglot (hopefultyclose to the marina gangway), go to the marina office and pick up a cart, go back to your car, load up the cart and haul your stuff to your boat. Now picture this routine when your vehicle is parked a block away, up a steep hill. Please keep in mind that the majority of the marina tenants are in their 60's, 70's and 80's. Additionally, it is my opinion that the design for the townhomes and flats does not provide enough parking either. It appears that the d~~sign allows for a single garage or carport for each unit with one additional parking space in a driveway. WIth most families having two cars and the likelihood that many of the garages will be used for storage (kayaks, golf clubs, boating,g~, etc., etc.) it is easy to anticipate that many cars will be parked along the streets. I am concerned that this will make it impoSSlDle for fire/ambulance crews to respond to emergencies. Thank you for your consideration of my con,cems. LOG ITE~1l # l '6~ Page-1_otL~ June 9, 2004 ... l~ 20M Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, WA 98368 ~COUN.TY DCO Attn: Mr. AI Scalf Dear Mr. Scalf: This letter is to inform you of our concerns over the present PLA building program for Port Ludlow. Over the past few years, many of the Admiralty I and II condominium units have been withdrawing from the rental program because of the steady decrease in the number of nights of occupancy. More and more owners are moving into their units, leaving too few units in the rental program for it to be successful. Others are selling to owners who will be full time residents. PLA withdrew as managing agent of the rental program at the end of 2003. They were receiving 60% of the gross' rental;- but as occupancy decreased, they found they were not making a profit on the operation. A private rental managing agent has replaced them only to be faced with a steadily decreasing rental demand. Port Ludlow is no longer a "Destination Resort," nor is it a "Resort for the Traveling Public," as PLA would have you believe. The rental program is all but dead. Should PLA pres~ntly have any zoning or development advantages under the guise of a "resort," this should be rectified as soon as possible. ' Sincerely, ~B;e~i~ ~W Marcet H. Benedict 30 Admiralty Lane, #321 Port Ludlow, WA 98365 LOG iTElVl #~<63 " Page l _ ofL I I I I I I I I I I I 1/4.3.2 I I I I I I I I I I I I I I I I I I I I I I I I I I I Page 1 of 1 Michelle Farian From: AI Scalf Sent: Monday, June 14,20044:02 PM To: Michelle Farfan Subject: FW: RESPONSE Port Ludlow DSEIS rD) rE ~ rE 0 WrE. ~.n ln1 "UN 14 me lW fyi AI -----Original Message----- From: Powers & Therrien [mailto:powers_therrien@yvn.oom] Sent: Monday, June 14, 2004 3:40 PM To: AI Scalf Cc: David W. Johnson Subject: RESPONSE Port Ludlow DSEIS Attached please find my response to the Port Ludlow DSEIS matter which is due by 4:30 today. Please let me know if you need any additional information. I appreciate the assistance of your departinent in obtaining documents referenced in this letter. Thank you. JEFFERSON COUNTY OEPT. OF COMMUNITY DEVELOPMENT Les Powers POWERS & THERRIEN, P.S. 3502 Tieton Drive Yakima, W A 98902 Phone (509) 453-8906 Fax (509) 453-0745 This email is covered by the Electronic Communications Privacy Act, 18 U.S.C. Section 2510-2521 and is legally privileged. This message and any attachments hereto may contain confidential information intended only for the use of the individual or entity named above. If you are not the intended redpient(s), or the employee or agent responsible for delivery of this message to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this email message is strictly prohibited. If you have received this message in error, please immediately notify the sender and delete this email from your computer. LOG ITEM # {rgL{ ~age f _of ~ l/ 6/1512004 -' i . ~e4J June 14, 2004 Via Email ascalffii>.co.iefferson.wa.us ALSCALF iefferson County Community Development 621 Sheridan St. Port Townsend, W A 98368 RE: Port Ludlow Draft Supplemental Environmental Impact Statement Dear Sir: I have a residence in the townhouses at 44 Heron Dr. I am writing this letter in response to the Draft Supplemental Environmental Impact Statement ("SEIS") proposed in connection with the Port Ludlow Resort Plan Revision ("PLA Proposal"). The SEIS at S-3, provides that the PLA Proposal is a major revision requiring a public hearing prior to decision before a hearing's examiner. Criteria are set forth in Section 3.906 of the Jefferson County Ordinance 08-1004-99 (the "Ordinance"). I note that PLA has made applications for permits to commence construction that trigger such hearings process and has initiated preliminary construction work in the form of survey staking prior to approval of the SEIS. I find this questionable, particularly in light of the deficiencies therein. As will be shown, the permit provides for the development of property that conflicts with the CC & Rs and the Plat and, as noted in the Development Agreement, such conflicts cannot be resolved without the consent of the persons owning property interests under the Plat and/or subject to the CC & Rs. The purpose of the SEIS is or should be to measure the impact of the PLA Proposal against a baseline describing the project that can now be developed. I have reviewed the SEIS in detail as has the engineer that I have retained to examine certain aspects of the plan. We both have concluded that there is no baseline and that the so called default plan, that is the development plan adopted in connection with the Ordinance has been mooted by development by PLA in conflict therewith and by PLA's failure to obtain modific{l.tions to the plat that are a condition even to the implementation thereof. I realize that the Ordinance and Development Agreement identify the plan developed in connection therewith as the baseline plan. However, for reasons hereinafter set forth, it is clear that this is not the case. ' I think a summary of the current situation is necessary. In 1993, Pope Resources proposed a development project that included the hotel, retail, the restaurant, a town hall, a marina, a manager office, off street parking, open spaces and trails, and 122 new residential units in addition to those already in Admiralty I and II. The diagram of the 1993 Resort Plan indicates that 20 of the buildings would have been on Heron Dr. to the east of the Harbormaster Restaurant. The mix of single family dwellings, townhouses and other residential construction is not clear. The retail and the town hall were among the twenty buildings. LOG ITEM #.--1 cg tf Page ~ of~ II I I 1 1 I I 1 I 1/4.3.1 I I I 214.3.101 I I I I I I I I I I I I I I I I I I I I I I I I I I, AL SCALF Jefferson County Community Development June 14,2004 Page 2 Jefferson County did not approve the plan. In its place, Jefferson County approved the addition of 58 new residential units, 53 townhouses ands 5 single family dwellings, the 37 unit hotel and the Harbormaster Restaur.mt Building. This approval covered the area covered by the 122 residential units, town hall, retail building Harbormaster Restaurant, and 37 unit hotel in the original plan. The Plat was prepared and recorded reflecting these changes. The changes were also incorporated in an application for a Shoreline Substantial Development Permit SDP 91-0][7 under the Washington State Shoreline Management Act (the "SMA Permit''). A permit was issued on May 11, 1993 in response thereto. The permit references a 36 unit hotel, 58 dwelling units, 5 detached 3/4.3.1 single family and 53 attached single family residences in 14 multi unit structures. In the Plat and by admission ofPLA, the attached residential units are all townhouses. They are not condominiums. Each owner owns the lot upon which his or her townhouse is constructed. The SMA Permit contains Sl additional conditions applicable to the developmel}t of the subject area. I will discuss these later in this letter. I refer to the development plan incorporated in the Plat and approved in the SMA Permit as the "93 Development Plan". The project has been developed in a manner substantially consistent with the 93 Development Plan. The SEIS does not contain a schemata of the 93 Development Plan. Rather, it sets forth Pope's original 1993 development proposal that was not approved by Jefferson County or Washington State Shorelines Management Act Authority. To the extent there is a "baseline" for the project, it is the 93 Development Plan. The SMA Permit contains additionalSI conditions to which Pope Resources, PLA's predecessor, agreed to comply. Relevant hl~reto are those that relate to the lagoon. The lagoon was to be enlarged from 1.4 to 2.2 acres. It was to recycle water to and from Port Ludlow Bay to maintain constant salinity. It was the control basin for storm water run off from the development. It was to prevent sedimentation from entering Port Ludlow Bay. In addition, the lagoon was to be constructed and maintained with a view to its integration as a wildlife habitat. The storm runoff system was to contain improvements including the lagoon, referred to therein as a "detention pond" to manage both water quantity and quality. The lagoon was to be planted in its eastern sector in eelgrass to , preventthe growth of sea lettuce. Two pumps and a standby mobile power generator 4/3.3.3 were required to provide redundancy prote(:tion. The lagoon was to be constructed and maintained to prevent stagnation and water quality problems during warmer weather. The final plan was to diminish impervious :structures to lessen runoff into the lagoon. Portions of the lagoon subject to tidal effects were made subject to Jefferson County's 'Flood Plain Management Ordinance No. 1-89. Enlargement of the lagoon was "to make provisions for improved aeration and circulation to discourage algae growth, maintain consistent water quality, and improve its v~Llue as fish habitat." The lagoon was "to be designed to provide some shallow area along the south shoreline, suitable for wading birds, isolated from public access. 'The lagoon "shoreline length equivalent to at least SO% of the existing shoreline" was to be "provided for bird loafing area." This area was "to be buffered by landscape vegetation to discourage public disturbance." See SMA Permit, Conditions Nos. 1, 10, 13, 14, IS, 16, 17, 18,24,26,27,28, and 29. The lagoon LOG ITEM #~ Page 3 of~ -- AL SCALF Jefferson County Community Development June 14,2004 Page 3 ~, f is integral both to stonn water management and to the development of wildlife habitat in the areas of the project to be left as open spaces. It is both mitigation and an integral part ,of shoreline management, being in whole or part within 200 feet of the highwater mark of Port Ludlow Bay. See discussion in "Shoreline Substantial DevelopmentPermit (SDP), SDP Exemption, Shoreline Conditional Use and Shoreline Variance, p. 1 paragraph 1. As such, it remains under the jurisdiction of the State and Jefferson County Shorelines Management Authorities whether or not it is in part artificial. It is an exception to the carve out to "wetlands" for certain inundated lands ''that were unintentionally created as a result of the construction.. ." as part of mitigation. See RCW 90.58.030(h). The approval was incorporated into the existing plat that was approved and recorded in 1994. No condominiums or residential structures other than townhouses and single family dwellings were approved in the plat. With the plat, CC & Rs were approved and recorded. I attach a copy of the 1994 plat (the "Plat") as Exhibit A. Townhouses were built along 'the south and west side of Heron Dr., ultimately including the building that incorporates 44 Heron Dr., that my wife and I own. I note the contention of counsel for PLA that the CC & Rs are not subject to RCW 58.17.215. That statute provides that an application to alter a subdivision must be subject to an application by the proponent containing "the signatures of the majority of those persons having an ownership interest in the lots, tracts, parcels, sites, or divisions in the subject subdivision or portion to be altered." It further provides that "if the subdivision is subject to restrictive covenants which were filed at the time of the approval of the subdivision, and the application for alteration would resulting the violation of a covenant, the application shall contain an agreement signed by all the parties subject to the covenants..." I must respectfully dissent from that conc1usion~ The CC & Rs were adopted at the same time as the Plat. To the extent the preferred alternative or default alternative violate the CC & Rs, approval of all of the property owners is a condition to the submission of an application to amend the Plat. This conclusion was clear to the Jefferson County Commissioners when they adopted the Ordinan~e and entered the Development Agreement. Section 3.15 of the Development Agreement provides "The parties acknowledge that development of the resort complex may require alteration of the Ludlow Bay Village Plat. One option the parties may exercise regarding any required plat alteration is to process and consider the plat alteration in conjunction with (or on a parallel track with) the resort complex proposal. Alternatively, if the plat alteration is not decided until after the resort complex proposal has been decided, the County shall ensure that any approval of the resort complex is conditioned or made contingent upon approval of any plat alteration....A public hearing shall be required for any necessary plat alteration, and the review process shall consider the criteria in RCW 58.17.215 controlling plat alterations:' On October 4, 1999, in the last year of the effectiveness of the SMA Permit, at the instance of Pope, Jefferson County adopted ordinance 08-1004-99 (the "Ordinance"). A LOG ITEM # {~4 D ,age V~of3~ - I I I I I I I I I I 5/4.3.1 I I I I I I I I I I I I I I I I I I I I I I I I I I I I AL SCALF Jefferson County Community Development June 14,2004 Page 4 copy of the "Ordinance" without exhibits, is attached to the SEIS. It took the place of ordinance 10-1214-98. On February 11,2000, Jefferson County entered a development agreement with Pope to execute the Ordinance (the "Development Agreement"). The Development Agreement and some 534 pagc~s of exhibits are attached to the Ordinance as exhibits. They are available under the Jefferson County Web Site but reference was not made thereto in the SEIS increasing the time:: and burden to review same. Herein, I refer to the plan provided by the Development Agreement as the 99 Development Plan. The Development Agreement recognizes that the Plat probably conflicts therewith. To that extent, it requires approval of an alteration to the Plat in accordance with RCW 58.17.215 and approval, after hearing by a hearings examiner based thereon. It permits the planning and conditional approval under the Development Agreement to proceed simultaneous or prior to the fulfillment of the conditions of approval of the alteration of the Plat. As noted above, to the extent Plat is affected, a majority ofthe persons owning interests in the Plat that are affected by the alteration must approve. To the extent the CC & Rs, if recorded with the Plat are affected, approval of all affected persons is required. To date, approval of the affected persons has not been obtained although I understand that it has been solicited for at least one aspe::ct of the 99 Development Plan. The Development Agreement recognizes that it is subject to consents by various authorities to execute the 99 Development Plan. The Development Agreement contains as exhibits, the requirement that it be consistent with MPR Zoning Code chapter of the . Jefferson County Zoning Code, that it be consistent with the policies set forth in the "Comprehensive Plan Policies for Port Ludlow Resort MPR, that it be subject to Jefferson County Stormwater Ordinance # 10-1104-96, that it be consistent with Jefferson County Interim Critical Areas Ordinance No. 05-0509-94, that it be platted consistent with RCW 58.17 and Jefferson County Subdivision Ordinance No. 04-0526- 92, that it be consistent with the Jefferson County Shoreline Master Program, that the utilities and sewer service be installed consistent with the requirements at time of installation as approved by the Washington Department of Ecology, Modifications are contemplated, but only "in order to achieve :a variety of purposes, including: incorporation of new information; responding to changing community and market needs; encouraging reasonably priced housing; and encouraging modifications that provide 'comparable benefit or functional equivalent with no significant reduction of public benefits or increased cost to the development." See Development Agreement at Sections 3.1 to 3.8 and 3.11. The 99 Development Plan contemplated a major restructuring and expansion of the facilities. The 99 Development Plan added 13 townhouses and 64 condominium units to those constructed to that date. The SEIS is not clear whether the 13 townhouses were a build out under the 93 Development Plan. The 64 condominium units were in addition thereto. The hotel was to be expanded from 37 to 275 rooms. The restaurant facilities were expanded to 59,000 square feet. Additional lounge facilities were to be provided. A museum or interpretive center, youth center, amphitheater, and conference center was to be added. The 2500 square feet of retail space was restored from the initial Pope LOG ITEfV1 # I ~ <-( ?age-2_of~ 6/3.3.4 LOG ITEM #--1cg G{ Page--1P_of~ I I I I I I I I I I I I I I I I I I I AL SCALF Jefferson County Community Development June 14,2004 Page 5 proposal. A large underground parking facility was to be provided. Indoor tennis courts, an indoor sports and pool complex and a yacht club were to be added. An examination of the 99 Development Plan, p. 1-13, reveals that the plan had minimal impact upon Heron Dr. The townhouses in the 93 Development Plan located in the three buildings north of the hotel and west of Heron Dr., and the last two buildings on the north end of Heron Dr. were to be abandoned and converted to amphitheater and open space. This had the effect of reducing, not increasing traffic on Heron Dr. east ofthe existing restaurant hotel, the area that is most impacted by the 2003 Development Plan. I make this comment because of the impression left by the SEIS that the 2003 Development Plan would decrease, not increase, density and burden on Heron Dr. to the existing townhouse owners compared with the 99 Development Plan. Apparently, Pope attempted to obtain the consent of the townhouse owners to the 99 Development Plan. Objections were raised, particularly to the amphitheater. Since the proposal would have had the effect of reducing the common area, Pope was persuaded that a modification of the CC & Rs would be required and that it would need unanimous consent'ofthe persons holding property thereunder. It did not have such consent. As I understand it, the issues between Pope and the townhouse owners did not involve the entire plan. However, Pope was apparently not able to develop a suitable alternative plan. What is important to note here is that the 99 Development Plan in the form set forth in the SEIS cannot be considered a default plan for the SEIS because it contains features that were already rejected by the parties prior to the transfer of the project from Pope to PLA. Contentions within the SEIS that the default plan that PLA will pursue is the 99 Development Plan and that its impact can be compared therewith are misleading. At sometime after 2000 and after failing to obtain approval for the overall 99 Development Plan, Pope sold its interest to PLA. Under the Development Agreement, PLA undertook all of the conditions and covenants undertaken by Pope. While the Development Agreement provides that there are no third party beneficiaries to Jefferson County and Pope under the Development Agreement, clearly, all of the townhouses sold ., in the Plat, and other units sold around Port Ludlow Bay after February 11, 2000, were , sold on Jhe basis that the support facilities contemplated in the Ordinance and Development Plan would be built and operated. PLA is subject to that implied representation to the extent of its continued development activities atPort Ludlow Bay. See Development Agreement, Section 4.2. I understand that certain of those facilities could not be constructed. Nothing prevented PLA, however, from developing a plan consistent with both the Plat and the promises for increased amenities promised under the 99 Development Plan. This it clearly has not done. Since the adoption of the 99 Development Plan, neither Pope nor PLA have begun any development. Notwithstanding the provision in the 99 Development Plan for an amphitheater across from the building my unit is in and for open spaces where the building my unit is in and the building to its north, PLA has constructed the building in which my townhouse is located and a smaller townhouse building to its north. Such LOG ITEM ~~ Page 7 _of 3~_ I I I I I I I I I I I I I I I I I I I AL SCALF Jefferson County Community Development June 14,2004 Page 6 buildings are consistent with the 93 Development Plan. Immediately north of the hotel, it has turned part of the amphitheater into a parking lot and operates informally parking for the townhouses there and along the west side:: of Heron Dr. It has no permits for any such change. It is clear that PLA has paid little or no attention to the 99 Development Plan that it promised Jefferson County and represc~nted to the townhouse owners that it would pursue. The statements contained in the SEIS that the 99 Development Plan is the default plan if the preferred plan is not adopted must be seen in the context that PLA has never followed the 99 Development Plan and has constructed and sold townhouses and constructed and maintained other parking facilities in conflict therewith. PLA now fonnally proposes plans substantially to alter its obligations under the Development Agreement and Plat. It recognizes that the alteration is a major revision under Section 3.906 of the Ordinance. This means that in addition to the pennit and other governmental requirements. including the SEIS procedure, it requires a public hearing before a type III hearings examiner before it can be approved. Scoping. dissemination of the SEIS. and acceptance and review of comments are only the preliminary stages to the approval ofPLA's preferred plan. I refer to I>>LA.s development plan herein as the 2004 Development Plan. The 2004 Development Plan proposes to shrink the amenities that were promised by the 99 Development Plan. Specifically, the hotel is returned from 275 units to 37 units. In addition, the restaurant and lounge space is not only reduced to the original 2003 Development Plan level but is further reduced. The reduction is accomplished by making more ofthe restaurant and lounge seasonal and out of doors. Retail. the athletic and indoor tennis facilities, the museum or interpretive center. the youth center. the convention center, and the yacht club are eliminated. PLA orally represented the yacht club would be included but it was not present in the SEIS. Notwithstanding comparative allegations made in the SEIS, the 2004 Development Plan increases the density in the Heron Dr. both over the 1993 Development Plan and the 1999 Development Plan. Currently. there are 25 t01.vnbouse units, all north, east, or south of Heron Dr. The 1993 Development Plan provided for three four unit town house building_s west of Heron Dr. and two two unit townhouse buildings north of Heron Dr., each in the area west ofthe existing restaurant. Of these 16 units, one. the site immediately north of the hotel has already been defacto abandoned by PLA in recognition of the parking problem created by the hotel at any level of operation. Thus. the actual residential density on Heron Dr. east and south of the existing restaurant under the 93 Development Plan was 35 townhouse units. Under the 1999 Development Plan, not followed by PLA, the buildings on the west side of Heron Dr. that are east and south of the restaurant, the building containing my townhouse unit and the next two buildings to the north are abandoned. The resulting density on Heron Dr. is 18 residential townhouse units. In contrast, under the 2004 Development Plan, There will be two new sixplex condominiwn units and one additional to its north are retained but as six unit condominiwn buildings, and two are retained north of Heron Dr. as two unit townhouse buildings. In all, there will be 39 units, 27 townhouses ands 12 condominiums. In AL SCALF Jefferson County Community Development June 14, 2004 Page 7 addition, the restaurant will be removed and fourteen condominium and single family units will be developed on the south side of Heron Dr. in its place. Since restaurant parking was located north of Heron Dr. in parking lots that are retained, the additional residential traffic load on Heron Dr.' from the residences will be based on 51 units rather , than 35 units under the 93 Development Plan or 18 units under the 1999 Development Plan. It is not the case that the traffic and residential density are not increased by the 2004 Development Plan over any prior configuration. Notwithstanding the nomenclature used in the 2003 Resort Plan, p. 1-8 in the SEIS, the units west of Heron Dr. are not townhouses; rather they are smaller condominiums, an entirely different ownership regime. See the original Plat, the 1999 Resort Plan and the 2003 Resort Plan, SEIS, pp. 1-8 and 1-13. I include a map of the Plat, see Exhibit A. It was inadvertently omitted from the SEIS despite its obvious relevance. As justification for the modification to the 99 Development Plan, PLA claims that the business plan under which it was developed, that is to develop a major convention center, is no longer economically feasible. It says that the business plan for the resort must be changed from a convention center to a destination resort. Under its plan, as noted, the new amenities promised under the 99 Development Plan are eliminated. A new club is to be added. How a club house and an expansion of the marina contemplated under all plans will generate more destination resort business is not explained. Neither can the authors refer to any actual baseline testing. The hotel has never been expanded from its 37 units. No convention facilities have been added. How would anyone knowifthe convention center plan is not economically viable when there is no actual data to support that it was ever really tested? Nor is there any explanation how the addition of 100 slips in the marina and a clubhouse will suddenly attract the number of guests necessary to make a successful destination resort. The basic amenities are not improved by the 2004 Development Plan. They have been present at all relevant times. There have been beach paths, outdoor tennis facilities, a pool and clubhouse since the late 1960s. The golf facility has been in place for more than a decade. The hotel has been in operation; as have the restaurants ands lounges. Nothing has prevented destination guests from coming to Port Ludlow. Yet, there has not been an increase in hotel traffic under PLA's watch. Rather, tbe hotel continues to lose money on a regular basis. How then will it suddenly become remunerative when no new rooms, no new restaurants or bars and no new support facilities are added? These questions are not addressed in the SEIS. One possibility not discussed in the SEIS is that PLA expects to find more purchasers of the smaller condominium units willing to rent them in the hotel pool. It currently has trouble obtaining units from Admiralty I and II, in part because several of the owners have moved into the units as primary residences and in part because PLA's plan to obtain additional units from the owners of Admiralty I and IT backfired. As I understand it from an owner of a unit in Admiralty I, PLA made a proposal to the owners that it would rehabilitate the existing Admiralty units for a cost of$25,000 apiece, adjusted to unit size, and that such rehabilitation was a condition to remaining in the botel pool through which the unit holders rented such units to guests. I understand that the Admiralty owners did not support the proposal and that the units bave been taken out of the hotel LOG ITEM # I ttf Page _ i of 3 y ~ I I I I I 7/4.3.2- I I I I I I I I I I I LOG ITEM # 19l{ :.")age q _ of~ 1 I' I I I I I I I I I I I I I I I I .l I AL SCALF Jefferson County Community Development June 14,2004 Page 8 pool. Although the townhouses are in the hotel pool, the owners have not been willing to rent theirs at all to transient traffic. It is possible that PLA believes that reducing the size and cost of the units from about 2,000 square feet to about 1,200 square feet, and the cost from $450,000 to about $340,000 will attract owners willing to let the units to transients through the hotel. I specifically inquired ofPLA's representative ifPLA intended to use the condominiums to increase the number of luxury units for the hotel. The representative denied such intent. Again, the SEIS does not disclose such intent. Yet, without additional luxury suites, it is difficult to see how the hotel can succeed as a destination resort. I make these surmises not because I can say they are the case but because of the absolute lack of a scintilla of support in the SEIS for the proposition that the business plan based on convention traffic is not workable and that a business plan based on destination resort traffic is. IfPLA wants the townhouse owners to agree to a substantial reduction in amenities promised to them and an increase in traffic, it seems to me that PLA should provide specific justification justifying its business plan over that underlying the 99 Development Plan. Even ifPLA is experiencing problems with the operation ofthe hotel and with the business plan embodied in the 99 Development Plan, such problems are not of themselves sufficient to justify the kind of modification to the plan that PLA urges. Reference is made to the Development Agreement under which PLA operates. Market factors are only one of the factors necessary to justify modification. Other factors include providing reasonably priced housing, the ne(:ds ofthecommunity, new information, and providing comparable benefits and functiomlll equivalency to residents without significant reduction of public benefits. Lowering cost is not a criterion. Not increasing cost to the developer would be. See Development Agre:ement Sec. 3.11. PLA has provided little justification under this standard. There is no marketing problem for the existing townhouses. They are presold before the foundation is poured~ There would not be any problem selling townhouses in accordance with the 93 Development Plan. Thus, marketability of units is not a sufficient basis: to prefer the 2004 Development Plan. It might be possible to see umarketing" in terms of the hotel. However, there is no change in the units dedicated to the hotel under the plan. To market the hotel as a destination resort under the 2004 Development Plan requires no additional residential unit ,development. PLA represented to me that it did not contemplate that the projected condominium owners would furnish luxury suites to the hotel. If that is not the case, PLA should have been forthcoming when I inquired. Moreover, the SEIS contains not one bit of data supporting the view that the changes enhance marketability. On the other hand, the changes substantially reduce amenities available to residential unit owners, a factor that is not approved in the Development Agreement as a basis for changing the development plan even if costs are reduced. The SEIS contains no information showing that the unit owners or the public would benefit by the 2004 Development Plan when contrasted to the 1993 Development Plan and the 1999 Development Plan. While the new units may be less expensive, they are not ureasonably priced housing" by Jefferson County standards. Other than the resort developments, how many houses in Jefferson County sell for $350,000, the approximate price ofthe - AL SCALF Jefferson County Community Development June 14,2004 Page 9 condominium units? I saw no data in the SEIS dealing with this issue. My examination of units available around Port Ludlow Bay indicates that there are freestanding units that fall within the "reasonably priced" classification as do the units in Admiralty. Clearly, nothing in the SEIS justifies modification of the 1999 Development Plan based on the provision of reasonably priced housing. It may be the case that PLA would incur substantial costs to perform the 99 Development Plan in substance and it may be losing money on its hotel operation. Neither of these facts support modifying the "default plan", the 99 Development Plan, under the applicable standard of the Development Agreement. Whatever development plan PLA or its successor execute, it must deal with the problem of the design and use of Heron Dr. The SEIS contains data about the burden of the project on the overall road network. It does not address the more important question about the design of Heron Dr. and the burden of the traffic and parking with respect thereto. Such burden must be explored in terms oflocal vehicular and pedestrian use and use by support and emergency vehicles. At a meeting but not clearly in the SEIS, a representative ofPLA promised that Heron Dr. would be closed at the hotel by a hammerhead to prevent hotel traffic from using the roadway. He also said that the median barrier would be moved to the edge of the parking on the west side of Heron Dr. in the vicinity of the hotel. He also said that the lot north of the hotel that was dedicated to townhouses in the 93 Development Plan and part of the lot next to it would be converted to additional hotel parking. In other words, all of the ' parking now informally shared by the hotel and the townhouses including the parking on the lot and a row of parking extending on the west side of Heron Dr. to the end of the building in which my townhouse is located would be eliminated as parking for the townhouse residents. Driving down Heron Dr. currently will show that PLA or its predecessor have devoted all of these areas to parking for both the hotel and the townhouse residents and have improved and maintained it with barriers and gravel. PLA's representative said that the townhouses could use the parking area north of the present restaurant for their guests. The guests could temporarily park on Heron Dr. to load and unload. Apparently that would also be the case for support vehicles such as carpet cleaners, gardeners and the like. When I asked the legal basis for changing the plat . from townhouses to parking for the hotel, the representative from PLA said that PLA could do what it wished with its property and that it was the only party affected by the change. The problem here is that neither the existing townhouse design and location nor Heron Dr. adequately provides for the townhouses without additional parking or width to Heron Dr. If35 foot tall structures are constructed on the west side of Heron Dr. and around the corner from the building my townhouse is located, there will be a blind spot. The traffic is already dangerous. My neighbor and I have had to have gates installed to prevent children of our guests and my grandchildren from running into the street into traffic. Having the corner blind increases that risk. Moreover, Heron Dr. is only 24 feet wide with 18 inch concrete lips. At my building and the building to the south, the building improvements with bushes are built to the concrete lip. If the buildings across are built LOG ITEM #J ~:1 Page-10 _of 3 q- , I I I I I 8111' I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I - AL SCALF Jefferson County Community Development June 14,2004 Page 10 similarly to the edge of the concrete lip there will not even be enough room to turn a large SUV in and pull it out of a garage. When it emerges from the garage, it will emerge into blind traffic that cannot see around the comer. This is a prescription for an accident. The townhouses only average ,1.5 parking spaces per residence. Some, like mine, have only a single car garage. When guests load and unload and support services stop to provide service, per PLA's representative, they will block half of Heron Dr. How does PLA think emergency vehicles such as fire trucks that are about 10 feet wide can pass temporarily parked vehicles that are loading, unloading and providing services? Heron Dr. needs an additional lane to accommodate loading, unloading, service and emergency vehicles. It should be widened by 8 feet to the west to provide same. PLA's response ofundedicated isolated parking through the townhouse complex is totally inadequate to meet this problem. Because it is not dedicated, it will be first come, first serve. This conflicts with the likely needs of guests and service providers. Dedicating each of the spaces might mitigate but would not solve the problem. The design of Heron Dr. is incompatible with pedestrian and bicycle traffic. By increasing the blind comers, PLA will increase the risk of accidentS. Moreover, the existing road design, continued without mitigation by PLA has no sidewalks or bicycle paths to service the residents. Traffic flow on Heron Dr. should not be controlled by making Heron Dr. narrow and restricting visibility thereon as argued by a representative ofPLA at a meeting I attended. Finally, there are no facilities to enhance access for disabled and elderly owners and guests of residence owners. Finally, the hammerhead concept is misguided. There is no room for a turn around for emergency vehicles. Road design requires a minimum turn around for such vehicles. The 2004 Development Plan to the extent it closes Heron Dr. with a hammerhead does not address or resolve these problems. I was sufficiently concerned about the problems of Heron Dr. to commission an engineering study thereof both as it exists and as it would be affected by the 2004 Development Plan. The engineering firm I retained specializes in testifying in road design cases. The comments in the preceding paragraph are consistent with the conclusions of my engineer. Needless to say, the 2004 Development Plan as it affects Heron Dr. presents substantial issues of liability and insurability that affect PLA and Jefferson County if it does not address these concerns. I attach as Exhibit B a copy of the .engineering report for review. The 2004 Development Plan as discussed bya representative of PLA to the residents contemplates construction of the condominium units to the west and south of Heron Dr. over the lagoon by use of pilings. I have serious questions whether this can be accomplished under existing SMA requirements and under Jefferson County's Shoreline 9/4.3.1 Management Master Program ("Master Program''). At Section 5.160, it describes policies and prohibited uses that relate to residential construction. Paragraph 1 of prohibited uses and activities makes residences located near "lagoons" subject to the Master Program. Paragraph 2 of policies provides that residential development should be designed to adequately protect the water and shoreline aesthetic characteristics. Paragraph 4 provides "Over-water residential development, including floating home, should not be permitted." Paragraph 5 provides "Residential developers and individual LOG ITEM # I <if -:>age J f of~ AL SCALF Jefferson County Conununity Development June 14, 2004 Page II builders should be required to indicate how they plan to preserve shore vegetation and control erosion during construction. Paragraph 5 of performance standards requires that "Developments containing marshes, swamps, lagoons, portions of a flood plain, or similar wetlands shall use those areas only for the purposes of parks, open space, or recreational facilities." Finally, paragraph 9 ofperfonnance standards provides "the standard setback for residential structures, including common appurtenant structures such as garages and workshops, shall be thirty (30) feet or one (1) foot for each foot of bank height whichever is greater." There are exceptions for residential developments with approved setbacks. Since there is no residen~ial development along the lagoon. this is not applicable. Since PLA is proposing a material modification, there would seem to be no reason that the present standards described in this paragraph should not apply. It is unclear to me that these standards did not apply in 1999. The use proposed in the 1999 Development Plan which eliminates residential structures on the west side of Heron Dr. along the lagoon is consistent with this analysis. Furthermore, the applicability of these standards i~ consistent with the current designation of the two lots on the east side of the lagoon to the west of Heron Dr. as unbuildable for property tax purposes, a classification of which PLA has taken advantage until now. While one might argue that the lagoon is artificial, for reasons hereinbefore stated, it is pretty clear that its purpose as mitigation and as a wildlife sanctuary under the SMA Permit eliminates the possibility that the lagoon can be treated as a matter outside the aegis of the Jefferson County and Washington SMA. The SEIS does not adequately deal with the effect of the development on wildlife. Contrary to the statements made in the SEIS, the lagoon is not a dead body of water. Consistent with its purpose, it is the home of ducks, geese, gulls, herons, and other marine birds. It is also the home of two families of river otters that forage live in the lagoon and forage in Port Ludlow Bay. It has fish and shell fish notwithstanding the failure ofPLA to perform the conditions of the SMA Permit regarding algae bloom and water quality. In addition, the bald eagles in the area do not just forage in Port Ludlow Bay; they also nest to the north of the sewage treatment facility. Increasing human density will certainly affect the bald eagle population. The improvements, including building over the lagoon will affect the use of the lagoon by river otters and fowl. Bear ,in mind_the SMA Permit requires that the lagoon be developed and maintained for the benefit of such animals and fowl. How PLA expects to cover the banks of the lagoon with housing and concrete and fulfill its commitments under the SMA Permit are not disclosed in the SEIS. The lagoon is also mitigation for the hotel and townhouse units. Its size is designed to handle the runoff from 58 residential units, associated parking, the restaurant and the hotel. The 2004 Development Plan eliminates the restaurant but adds 36 residential units and additional impervious roadways. There is no solid analysis in the SEIS addressing increases in impervious improvements. The SMA Permit requires that these matters be addressed. LOG ITErV1 ,# 1'Ott Page~_of~ I I I I I I I I I I I 1 O/~~~~~ I I I 11/3.3.1 I I I r I I I I I I I I I I I I I I I I I I AL SCALF Jefferson County Conununity Development June 14,2004 Page 12 Both the 99 Development Plan and the 2004 Development Plan require approval by the Plat owners if the owners are affected. I think it is pretty clear that there is increased density along Heron Dr. that will affect of the residence owners. The elimination of shared parking with the hotel will have a similar effect. The sewer and utility delivery system was designed for the 93 Development Plan. It is unclear that it is adequate to handle the increased density without additional improvements on common areas supporting the residential units. Among such common areas is the propane farm that is located on common area contiguous to lot owners, is owned by them, and will be burdened with additional capacity. The risk to the owners is not addressed in the SEIS. It is pretty clear that the increase density will burden those common areas, an effect on the existing property owners. It is pretty clear that the existing owners beyond the property that PLA retains and proposes to modify will be affected by the 2004 Development Plan. Accordingly, I cannot see how PLA can proceed without the consent of the persons owning property in the Plat along Heron Dr. It seems to me if this is at issue, a decl~ratory judgment action in Jefferson County Superior Court could resolve the matter. I think that it takes little review ofthe CC & Rs to reach the conclusion that they will be affected by the 2004 Development Plan. They contain provision for a Master Association and a Town Home Association. The latter represents 53 residential town homes within Ludlow Bay Village. See third recital, CC & Rs. The 53 residential town homes are built on lots owned by owners. What PLA proposes is to change both the number of ' members and potential members and to change the requirements for membership from lot owners to condominium owners. This is obviously a change to the CC & Rs. To make that change each town home owner must consent. See RCW 58.17.215. PLA cannot gloss over the change in the definition for the qualification for membership. Condominium ownership and town home ownership are legally distinct. Nor can PLA add a new association to the CC & Rs. Nor can PLA increase the population of the town home association from 53 to 94 without in each case obtaining consent of all of the town home association members. In summary, the 2004 Development Plan offers increased burdens and less amenities to , the townhouse residents. It exacerbates an already dangerous condition along Heron Dr. It violates SMA requirements as well as the conditions set forth in the SMA Permit. It ignores wildlife and the duty to promote same. It provides no benefits to community members and in fact restricts all benefits to the hotel, the marina and their guests. It contains no real economic justification for the change in business plan other than, implicitly, PLA is losing money on the hotel operation. It ignores all ofPLA's duties under the 99 Development Agreement to provide additional amenities. While the possibility of change was recognized therein, justification was limited to situations in which costs would increase. Here, PLA simply does not want to incur the costs of providing benefits it as successor to Pope promised or to provide equivalent facilities to obtain relief from the duty to provide such benefits. The SEIS contains no meaningful baseline against which to measure environmental impact. PLA cannot seriously urge that the 99 Development Plan is its default plan after it has already violated its terms by LOG ITEM #-1 <64 Page~ot3..L 12/4.3.9 --.-- AL SCALF Jefferson County Conununity Development June 14,2004 Page 13 I I I I I I I I I I I I I I I I I I I constructing the building in which I have a unit and the next building to the north and by failing to develop one amenity promised in the Development Agreement. What we have here is PLA making objection to the performance of duties that may cost it money without a return and a refusal by PLA to seek advice from persons with expertise in hotel management about the operation of a hotel and the support facilities required thereby. Even ifPLA loses money on this venture, that was the risk it undertook by purchasing Pope's interest in the project. There is no good reason why Jefferson County should permit PLA to avoid its duties without proposing alternatives that actually benefit the community rather than PLA. I have no objection to PLA's successful development of Port Ludlow. I acquired my unit with a view that the amenities proposed in the 99 Development Plan or acceptable alternatives thereto would be provided, as promised. I want the hotel and restaurants to be successful so that I can continue to use them. What I do not want is a modification to an existing plan that enhances only PLA's bottom line at the expense of the residents, including me. I think PLA, as Pope in the 99 Development Plan can build residential units to the north of Heron Dr. and the restaurant without creating the problems that the 2004 Development Plan would create and with little loss in density. I think such development with proper attention to road outlets might be acceptable to the residents. I do not think that these developments eliminate PLA's duty to run successful restaurants and a hotel as promised in the 99 Development Plan. I look for another more carefully considered articulation of the 2004 Development Plan to address these concerns. Several of the issues identified in this letter are of a legal nature dealing with rights of the residents in connection with any proposed development and the duties of PLA. Because there may be disputes over these matters, I would propose as a preliminary to any further plan touching these issues that they be judicially resolved. 4~;?~~ 3502 Tieton Drive Yakima, W A 98902 Ph: 509-453-8906 Fx: 509-453-0745 Em: powers _ therrien@yvn.com Enclosure(s) cc: David Johnson LOG ITEI\J1 #~ Page~f 3 '1 ~~' I I I I I I I I I I I I I I I I I #JitG I I Page L~ _ofli cC ~ A . .i )( w ""OC'I~.""'" IN3)1l33\10't' IH3ftd013^30 M01on, .1HOd NIO"'(Im.LJtC/l:l J 3DVIII^ ^ VB MOlan., 'I I .LN3V'GOVN'ffl ~~~ OIdW."lO II I i I: I -~I ~~ I ~-.:; ~ ~-- ---- - ..-.- -- --.......,..,....,. I~I !.!J~.I... :::::.:: ~ w " ,0:: z ~~ j!i >~I ~ .. >~~ 0(" ~ a>>is ~~~ 09:i ..... ~ t e" III ::>~ ..J~ > o " .. o z o ~ II: o Go < ". ~ , il I' I i I I 0:: en to- ;I~~ ~ bJ~ I::l e ~ ~ . .e '- - ~ . o o . o o .. ~ g . o ~ I .. 41.V""""--;':_- - EOVVARO STEVENS & ASSOCIATES ENGINEERS, INC. soe COLUMBIA ST. NIN.. SUITE 214 OLYMPIA. WASHINGTON 98501 (36OJ 357-6651 FAX: (36OJ :352.0108 @ E,)lh\blt 'PJ Job 3637 June 7,2004 Mr. Les Powers 3502 Tieton Drive Yakima, WA 98902 Re: Review of EIS for the 2003 revision to the Port Ludlow Resort Dear Mr. Powers: Introduction: You have retained the services of Edward Stevens and Associates to review the SEPA action being considered relative to the 2003 revision to the Port Ludlow Resort Plan Revision. The scope of this study is to review the Draft EIS for adequacy related to impact on roadways that are to serve the vicinity of Ludlow Bay Village. Specific attention is being placed on Heron Drive and access to the 37 seat restaurant which seems to be called both Heron Beach Inn and Inn at Port Ludlow in the Draft Supplemental Environmental Impact Statement. Qualifications: I am a registered professional engineer and land surveyor in the State of Washington. I have worked for twe!1ty five years with the Washington Department of Transportation in a variety of areas encompassing the broad field of transportation engineering. I have work~d for five years as a land surveyor and engineer completing a wide variety of transportation engineering projects and subdivision design and platting projects. I have been at Edward Stevens and Associates for more than 7 years. Edward Stevens and Associates is a civil consulting firm specializing in engineering studies related to safety of transportation facilities. A current curriculum vitae is attached for more detailed background. Materials reviewed for this study: 1. Jefferson County Road Standards sheets for: LOG ITEM #J~4 Page~ I (, of~ r I I I I I I I I I I I I I I I I I I r-' I EDWARD STEVENS & AsSOCIATES ENGINEERS, INC. I I I I I I I I I I I I I I I I I Mr. Les Powers June 7 I 2004 1. Single Lane Two Way Traffic, AASHTO "Local Service Roadlt, June 18, 1995 2. . Typical Road Section 18' Roadway, November 13, 1996? (Date difficult to read on our copy) 2. "Guide for Development of Bicycle FacilitieS', American Association of State Highway and Transportation Officials, (AASHTO) 1991 and 1999 editions 3. "A Policy on Geometric Design of Highways and StreetS', 2001, American Association of State Highway and Transportation Officials, (AASHTO). 4. "Design Manuaf, Washington State Department of Transportation, current edition. 5. "The Traffic Safety ToolboX' - A Primer on Traffic SafelY, Institute of Transportation Engineers, 1993 ' 6. "Local Agency Guidelines Manuar, City and County Design Standards, Washington State Department of Transportation, current edition. 7. -Roadside Design Guide- American Association of State Highway and Transportation Officials, 2002 This review is limited to analysis of the transportation element of the Draft EIS, with a focus on roadways within the plat of Ludlow Bay Village. Section 1.7 of the Draft Supplemental Environmental Impact Statement contains the following at page 1-13 and 1-14: 1.7 Significant Issues for Consideration: Major issues identified during the scoping process for the 2003 Resort Plan relate to: (3) Parking and Vehicular Traffic The proposed 2003 Resort Plan, including the expansion of the marina, will create demand for additional parking, especiaUy in the vicinity of the shoreline. Will sufficient parking be available during the peak summer months? Existing traffic circulation in the vicinity of the Inn at Port Ludlow and the adjacent townhomes is difficult for townhome residents. Will the proposed development exacerbate the problem? This section recognizes existing difficulty of traffic circulation along Heron Drive. The potential for making matters worse for abutting townhome owners is acknowledged. I agree with this assessment. The question is asked rhetorically, however there is no information that could be found within the Draft EIS to provide an assessment of impacts and mitigation. LOG ITEM # I ~:l Pag~-.l7 of~ . 1/4.3.0 3.3.0 2 EDWARD STEVENS & AsSOCIATES ENGINEERS, INC. I I I I I I I I I I I I I I I I I I I Mr. Les Powers June 7,2004 Transportation impacts are summarized On Page 1-22 of the Draft EIS. Under the heading of "Mitigating Measures. the entry "None Required" is found. (Exhibit 2)1 do not agree with this assessment relative to at least Heron Drive. In the absence of an answer by the developer to his own identified .significant issue for consideration., I will provide my analysis of existing conditions and possible impacts along Heron Drive, and the likely mitigation that would be required to correct the situation. My concerns are summarized below: Altered and increased traffic patterns: The preferred alternative includes shoreline attractions at the south end of Heron Drive in the form of an esplanade for pedestrians to view the marina, shoreline, and park at Burner Point. Parking is being created at the north end of Heron Drive to serve visitors to the shoreline attractions and overflow from the townhouse area. This new construction will make a pedestrian and bicycle route out of Heron Drive to a far greater extent than exists today. Sight distance. inter-visibility between users and modes Sight distance along Heron Drive is limited in all directions by the narrow roadway and inadequate setbacks for buildings. Garages were measured to have a 4.4 foot setback from the edge of asphalt lane on Heron Drive. Vehicles backing out of the garages cannot see pedestrians, bicyclists or other motor vehicles approaching them until they occupy nearly the full lane. Pedestrians, bicyclists, and other vehicles are in very real danger of conflict during the back- out maneuver. The degree of setback is analogous to head-in parking that used to be seen along city streets. Most cities have eliminated 90 degree head-in parking along streets because of the known hazards of this arrangement. The hazards are ,related to two main factors: 1. Inadequate visibility when backing out onto the street. The visibility in the head-in 90 degree parking that is less severe than what exists when Heron Drive townhouse owners back out of their garages. A driver cannot see out of the garages on Heron Drive at all, but there is usually some visibility for 90 degree head-in parking through the windows of adjacent vehicles. 2. A dart-out problem is created by sight blockages along the street. This problem is especially dangerous for young children, who may not stop and look both ways before they enter the street. It is virtually impossible for a LOG ITEM #~ PageJ~ 3 .1 I I I I I I I I I I I I I I I I I I EDWARD STEVENS &. ASSOCIATES ENGINEERS. INC. Mr. Les Powers June 7 J 2004 motorist or bicyclist to stop for them when they are visible for only the last few feet of their travel path before being struck. Use of Heron Drive by multiple modes of travel: , Heron Drive will become a pedestrian and bicycle route to an even greater extent than it is under present development. There are recognized safe standards for width related to multiple use facilities for motor vehicles, pedestrians and bicycles. Heron Drive does not meet standards for safe multiple use even if sight distances were clear and unobstructed. Heron Drive is inadequate for the uses that will be placed upon it by the new development. Miscellaneous considerations: I have been told that there will be a hammerhead design cul-de-sac at the south end of Heron Drive for vehicles to turn around. Access to the Inn from Heron Drive will be closed off by bollards, thus eliminating Inn traffic from Heron Drive. The preferred alternative includes a fire lane connecting Heron Drive to the Inn at Port Ludlow parking lot for emergency vehicle access. Unless it is effectively blocked to all but emergency vehicles, this access will reconnect Heron Drive with the Inn parking lot, further exacerbating traffic problems on Heron Drive. The Draft EIS indicates that the Inn will not be accessed through Heron Drive for the preferred alternative. Emergency vehicle access is an important part of safe street design. More investigation needs to be done concerning this critical safety aspect. How will safe access be assured with the narrow, blocked off roadways characteristic of the Heron and Gull Road connection? Fire and police officials should approve of plans in this area. County_ Road Standards: A Jefferson County Road Standard that appears to be applicable to Heron Drive has been reviewed. This standard sheet is titled TYPICAL ROAD SECTION 18 FOOT ROADWAY (35 MPH - UNDER 400 ADT. (Exhibit 1) This sheet represents a rural roadway section and shows a 22 foot total roadway width. There is a note on this roadway section stating that: Roads in designated urban areas may require pedestrian improvements, including wider shoulders or sidewalks. The Ludlow Bay Village is an urban-in-character plat located within a rural area. Resort planning calls for walking paths, a shore-front esplanade for pedestrian LOG ITEM #~ g'1 Page -L1- of21- 4 --' I I I I I I I I I I I I I I I I I I I EDWARD STEVENS &. AsSOCIATES ENGINEERS, INC. Mr. Les Powers June 7, 2004 traffic, and emphasizes the outdoor amenities and natural beauty of the area. By design and intent, Heron Drive will operate as a multiple use roadway, serving motor vehicle, bicycle, and pedestrian traffic. In my opinion, widerroadways and sidewalks are required to handle the mixed uses that will be evident on Heron Drive. Requirements for multiple use: The American Association of State Highway and Transportation Officials (AASHTO) is an association of all 50 member states. Literature and design guidance emanating from AASHTO concerning geometric design truly represents the consensus of civil engineering science regarding streets and highways. This guidance is used by all states in setting the basic standards for geometric design. The Local Agency Guidelines for City and County use references Washington Department of Transportation and AASHTO publications for guidance in geometric design of county roads. Bicycle safety and use: U A Policy on Geometric Design of Highways and Streets., 2001, by the American Association of State Highway and Transportation Officials, (AASHTO),contains the following guidance relative to bicyde facilities. (Page 100) BICYCLE FACILITIES The bicycle has become an important element for consideration in the highway design process. Fortunately, the existing street and highway system provides most of the mileage needed for bicycle travel. ..... ...Improvements such as the following, which are generally of low capital intensity, can enhance considerably a route's safety and capacity for bicycle traffic: . paved shoulders. . wide outside traffic lane (4.2 ItA, [14-ft) minimum) if no shoulders exist. . bicycle-safe drainage grates. . adjusting manhole rovers to the grade. . maintaining a smooth, clean riding surface. (Emphasis supplied) LOG ITEM . #--1 cg '-/ Page aD of3l\ s .1 I I I I I I I I I I I I I I I I I I EDWARD STEVENS & AsSOCIATES ENGINEERS, INC. Mr. Les Powers June 7, 2004 The "Guide for the Development of Bicycle Facilities" (AASHTO) 1991, defines the bicycle status of the roads in the Ludlow Bay Village as "Shared Roadways". SHARED ROADWA Y - Any roadway upon which a bicycle lane is not designated and which may be legally used by bicycles regardless of whether such facility is specifically designated as a bikeway. In Chapter 2, on design, the Guide discusses roadway improvements: Roadway Improvements To varying extents, bicycles will be ridden on all highways where they are permitted. All new highways. except those where bicyclists will be legally prohibited. should be designed and constructed under the assumption that they will be used by bicyclists. Bicycle-safe design practices, as described in this guide, should be followed to avoid the necessity for costly subsequent improvements. Because most highways have not been designed with bicycle travel in mind, there are often many ways in which roadways should be improved to more safely accommodate bicycle traffic. Roadway conditions should be examined and, where necessary. safe drainage grates and railroad crossings, smooth pavements, and signals responswe to bicycles should be provided. The RCW's on bicycle accommodation: RCW 47.26.300 Bicycle routes-Legislative declaration. The state of Washington is confronted with emergency shortages of energy sources utilized for the transportation of its citizens and must seek qltemative methods of providing public mobility. Bicycles are suitable for maT1J' transportation purposes, and are pollution-free in addition to using a minimal amount of resources and energy. However, the increased use of bicycles for both transportation and recreation has led to an increase in both fatal and nonfatal injuries to bicyclists. The legislature therefore finds that the establishment, improvement, and upgrading of bicycle routes is necessary to promote public mobility, conserve energy, and provide for the safety of the bicycling and motoring public. [1974 ex.s. c 141 9 1.] LOG ITEM #~ Page -&L of 3 \.f 6 - I I I I I I I I I I I I I I I I I I I EDWARD STEVENS & AsSOCIATES ENGINEERS. INC. Mr. Les Powers June 7,2004 The Port Ludlow development complex is a destination resort and conference center featuring extraordinary beauty and outdoor amenities. Hiking, recreational walking, and bicycling are ordinary activities in this setting, and must be provided for in a safe and responsible manner. Recognized Standards for safety and multiple use: Clear zone standards: A minimum clear zone of 7 to 10 feet is recommended by AASHTO in the publication "Roadside Design GuideD, 2002 edition. This is for urban construction where there is no barrier curb in place. Barrier curb is defined as a curb at least 6 inches high with a vertical or nearly vertical face. There is no curbing on Heron Drive. The term "clear zone" refers to a width outside of the traveled lane edge that is kept free of fixed obstacles. During a field trip to the area, I measured 4.4 feet from the edge of traveled lane to the face of garage buildings. This is in violation of clear zone standards. Clear zone standards are promulgated by the AASHTO, and Washington State Department of Transportation. The purpose is to build safety into the roadside environment. In the case of Heron Drive, safety would be enhanced by not only removing fixed objects, but by increasing sight distance. In my opinion, a minimum of 10 feet should be employed to create some degree of inter-visibility between vehicles backing out of garages, pedestrians entering the street, and traffic on Heron Drive itself. It is my opinion that the lack of adequate clear zone along Heron Drive creates unsafe operating characteristics. The more traffic increases, the greater the probability of serious accidents will become. This deficient aspect of construction along Heron Drive needs to be considered for mitigation before increased mixed , - use is invited to the street. Sidewalks: Sidewalks are the standard application for accommodating pedestrian travel on a street in the urban setting. Sidewalks separate pedestrians from vehicles for very obvious safety reasons. The absolute minimum width for a two way sidewalk is 4 feet where travel is very light, and 5 feet to accommodate appreciable two way foot traffic. Where narrow sidewalks are used, they should be separated from the curb by a planting strip. This generally results in an urban section with a raised curb. LOG ITEM # '<34 Page ~(}-_of 3Y 7 I I I I I I I I I I I I I I I I I I I EDWARD STEVENS & ASSOCIATES ENGINEERS, INC. Mr. Les Powers June 7, 2004 There is a two foot wide concrete strip along one side of Heron Drive. This is not a sidewalk, and will not accommodate pedestrian travel. Pedestrian travel is therefore forced into the traveled lanes of Heron Drive. Pedestrian travel is a recognized necessity to appreciate the amenities of the Ludlow Bay Village area. The danger of forcing mixed travel modes in the narrow and deficient geometric width of Heron Drive, as well as the liability that may accrue to the designers and owners of these facilities if an accident should happen, should be carefully assessed and mitigated in the environmental documentation for the Port Ludlow Resort Plan Revision. I could not find where this issue was mentioned, except possibly in Section 1.7 "Significant Issues for Consideration." In that section, possible impacts were posed only as a rhetorical question. Bicycle accommodation: The standard for one way bicycle travel is a five foot width lane, separate and apart from the travel lane for motor vehides. As noted above, MSHTO recommends a minimum of a 14 foot paved lane on low volume roads. This results in 9 or 10 feet for vehicular passage, and 4 to 5 feet for bicycle passage. This is considered acceptable for light bicyde use in rural areas. The minimum standard for two way bicycle travel is anS foot wide path. Ten feet in width is desirable for moderate to heavy use. Nothing like the above minimums exist along Heron Drive. Instead, all modes of travel are forced into two paved lanes that measured 21.6 feet across both lanes when I made my field trip to the site. Handicap accommodation: Handicap accommodation is a very important consideration where pedestrian routes are created in public places. The final design for Heron Drive should be reviewed for conformance to the Americans With Disabilities Act and its implementing regulations. It is a very poor idea to do nothing, and therefore expect the handicapped to mix with all other traffic modes on this narrow, substandard street. The liability implications of this for the owners and designers should be obvious. A few thoughts on Highway Standards: Standards and codes are developed to provide public safety, convenience of use, and to enable enjoyment of life. Most of the codes and standards are based upon experience from human loss and suffering. For instance, fire escapes are LOG ITEM # It'! Page ;D _of 3tf 8 - I I I I I I I I I I I I I I I I I I I EDWARD STEVENS cS. AsSOCIATES ENGINEERS, INC. Mr. Les Powers June 7 I 2004 required in multi-story buildings for safety. Many lives had been lost in multi- story building fires before uniform escape route codes were enacted. Then it was realized that a fire can spread so fast that fire escapes can be rendered useless, due to heat and smoke. Sprinkler systems are therefore required in multi-story buildings, to suppress fire until occupants can escape. This is all based upon unfortunate human experience. The same is true of highway and street standards. Experience has taught that certain widths, radius criteria, clear zones, and other geometric features contribute to and promote safe, efficient transportation. These criteria are generally codified as standards for design. Such standards must not be Iightlv dismissed. They are adopted as law and/or recognized 9perating procedures by the various government agencies in charge of highway and street construction and permitting. Variances should be granted only when it can be shown that there is a compelling reason, and safety will not be compromised. The geometric design of Heron Drive falls short of both state- wide and nationally recognized criteria. There does not appear to be any compelling reason for lack of adherence to standard. The argument may be proposed that Heron Drive is not a publicly owned road, ' therefore not subject to the aforementioned standards. There are, however, no separate standards of good practice available except AASHTO, Washington Department of Transportation, Americans With Disabilities Act, and Jefferson County adopted standards, and other industry-recognized standards. There is a duty on the part of the developer to create a safe environment, and a duty on the part of Jefferson County to see that a safe environment is designed and constructed. The safety of the final plan can only be judged by adopted industry standards and applicable laws. Analysis that I have not done: 1. Daily traffic volumes for interior roads that will be impacted have not been calculated. These volumes should be shown in the traffic impact analysis, both for the base, or do nothing condition, and for each proposed alternate. Traffic impacts due to implementing revisions cannot be assessed or estimated without this information. It is the responsibility of the proponent to provide this as part of the impact assessment. 2. I have not attempted to estimate pedestrian use or bicycle use for Heron Drive, or any other interior road. This too is the responsibility of the developer, and necessary to identify impacts to the built environment. 3. The Draft EIS does not appear to clearly identify the location of new planned versus existing housing units. I have not attempted to make that LOG ITEM #--L t{Cf Page~of3.:L 9 .1 I I I I I I I I I I I I I I I I I I -' - EOWARO STEVENS & AsSOCIATES ENGINEERS. INC. Mr. Les Powers June 7,2004 detennination, believing that it is the proponent's responsibility to make the distinction clear. 4. I have not studied why setbacks were allowed to be only 4 feet from the edge of travel way to the face of garages. The documentation offered cites only "USC" as the setback distance. USC setbacks may change from time to time, I have not researched them, and do not know what revision may be referred to. I believe that the proponent needs to specify what the setback distance is in feet, so that disclosure is complete and easily understood. If the setback to building face is less than the clear zone distances mentioned above, it should be justified in the face of obvious safety problems created by backing maneuvers and dart-out problems discussed above. 5. I have not evaluated the adequacy of a cul-de-sac that is proposed to be placed at the new end of Heron Drive. I could not find geometric details of this feature, so it is not possible to evaluate it. Possible solutions: In my opinion, Heron Drive most likely needs to be re-engineered to accommodate changes in travel mode and volume associated with the 2003 revision. Studies need to be conducted to accurately identify and mitigate impacts. Steps in this process may include: 1. Identify traffic volumes by each travel mode for the interior roads. This needs to be done for the base condition and for each proposed alternative. 2. Review standards for construction to accommodate each mode and traffic volume. 3. Identify impacts. Impacts will be an assessment of change brought about by the difference between the base condition and the alternative condition being considered. . 4. Produce a listing of improvements to mitigate the impacts identified above. 5. Provide a review opportunity for affected parties, per SEPA requirements. A possible outcome of this study might be 1 o foot minimum setbacks to garage faces from the edge of lane, 5 foot sidewalks on both sides of the road with handicap access features, and a 28 foot wide minimum paved width to accommodate light mixed bicycle use along the roadway. On-street parking would need to be prohibited under this scenario. Conclusion: In conclusion, I find that Heron Drive is constructed to an inadequate standard to safely accommodate mixed use travel. In my opinion, there is considerable LOG ITEM #~4 Page ~~of3i~~_ 10 - I I I I I I I I I I I I I I I I I I I EDWARD STEVENS & AsSOCIATES ENGINEERS, INC Mr. Les Powers June 7, 2004 impact to the neighboring built environment as a result of increased residential density and imposed travel patterns created by parking arrangements. As a reviewer, it is not my responsibility to complete the Draft EIS. My review indicates, however, that the adequacy of disdosure for impacts and mitigating measures concerning roads interior to the Ludlow Bay Village Plat is lacking in the Draft. This subject needs to be considered by the proponent and made available for review as part of the SEPA process prior to adoption by Jefferson County. The existing owners abutting Heron Drive and future owners and visitors to the area deserve the protection of infrastructure that meets adopted standards in accordance with existina laws and reQulations. SEPA approval should be withheld until impacts can be fully assessed and mitigation can be agreed to by the interested parties. Sincerely: EDWARD STEVENS AND ASSOCIATES, ENGINEERS, INC. LOG ITEM #l~tf Page o<lf_ of, 3 ~ 11 .r';'.. I I I I I I I I I I I I I I I I I I Name: Address: Education: His? School Junior College College Professional: Technical Experience: CURRICULUM VITAE Henry 1. Borden, P.E., P.L.S. Henry l(Hank) Borden 2207 Allen Road S.E. Olympia, Washington 98501 606 Columbia Street N.W., Suite 214 Olympia, Washington 98501 Wishkah Valley High School 1958 - 1961 Grays Harbor College, 1962 - 1964 Graduated in Pre-Engineering Washington State University, Bachelor of Science Degree in Civil Engineering, May 1967 eMember, Land SlllVeyors Association of Washington, Southwest Chapter eProfessional Engineer in Washington, Certificate #13676 .Professional Land Surveyor in Washington, Certificate #13676 , February 6, 1997 to Edward Stevens & Associates, Engineers, IDe. present Transportation Engineering Specialist Home Office Work at Edward Stevens and Associates involved preparation of traffic impact studies, topographic surveying of streets and highways, preparation of topographic drawings, analysis of roadways for safety related issues, engineering report writing, writing declarations, client interface, supervision of drafting and technical staff I have provided expert testimony and given depositions in court cases involving safety issues related to streets and highways. LOG ITEM #--1- <gtf Page ~7 of2L lof8 ~" I I I I I I I I I I I I I I I I I I I 8/92 - 2/97 Skillings-Connolly, Inc., Project Manager and Surveyor of Record for a consulting engineering and land surveying firm of approximately 34 personnel. During my 54 months at Skillings-Connolly, I was in charge of all surveying for the firm. This responsibility included organizing, directing, reviewing, and stamping of all land surveying projects, including legal boundary surveys, plats, subdivisions, boundary line adjustments, construction surveys, topographic surveys, writing legal descriptions, section subdivisions, General Land Office retracements, and other work. Typical projects included: Surveyor and Engineer of record for the Plat ofLoma Vista, a S9 lot rural subdivision in south Tburston County, the D.B. Story Subdivision, a 53 lot subdivision in the City ofLongview and the Plat of Noble Firs, a 28 lot subdivision in the City of Lacey, Washington. Surveyor of record for the Plats of Redwood Estates and King's Court in the City of Olympia, and the Plat of Haussler Heights in the City of Kelso, Washington. Complete survey of Section 21, Township 30N, Range 3 West of the W.M. and establishment of a wetland mitigation site for the Washington State Department of Transportation. This project involved section subdivision and General Land Office comer retracement for tbe WSDOT Sequim Bypass Project. Many topographic surveys for the purpose of street design, plat design, site development, and miscellaneous design purposes. Many boundary and lot surveys were completed during this time period. Boundary line adjustments, short plats, large lot subdivisions and planned unit developments were typical small survey projects routinely completed. LOG ITEM #.J~tf Page_ ~~_ ot3 y, 20f8 LOG ITEM #--1 C61 Page~of-.3 q 30f8 .1 I I I I' I I I I I I I I I I I I I I Construction surveys were calculated by myself or survey technicians, field surveyed by field crews under my supervision, and reviewed in the field by me. Typical construction surveys included water and sewer line staking, road and street staking, building foundation staking, lot boundary staking, as-built plan surveys, surveys for easement preparation, and more. There were no claims for inaccurate staking work in my 54 months with this firm. I also completed design of civil projects and performed project management for a variety of private and public clients, including: Washington Department of Transportation, Port of Tacoma, City of Lynn wood, Washington Department of General Administration, developers of private subdivisions, Lower Columbia Community Action Council, miscellaneous site development projects. Typical civil design projects that I personally completed as a "hands on" project manager are: Design of Work Zone Traffic Control (WZTC) plans for the Washington State Department of Transportation's Olympic Interchange project. I was certified by WSDOT as a Work Zone Traffic Control Supervisor prior to completing plans for this project. The certification was given by Sverdrup Civil, Inc., after attending WSDOT's WZTC supervisor training seminar in the spring of 1994. Sverdrup Civil prepared and taught the course for the WSDOT. Design 'and civil plans for a walking path at the Washington Department of Labor and Industries Headquarters Building in Tumwater, Washington. Design and civil plans for three pavement rehabilitation projects, including railroad track reconstruction at the Port of Tacoma's North Intennodal Yard. Included field surveys, cost estimating, and plan preparation. I was involved in promotional work for the firm, including preparation of proposals for civil projects, project scoping and estimating, attendance at job interviews. I also completed grant applications for public funding of transportation projects for client agencies. - " I I I I I I I I I I I I I I I I I I I 6/67 - 8/92 Twenty-five years and three months with the Washington Department of Transportation with general duties as outlined below: 7/84 - 8/92 System Evaluation Supervisor I supervised a headquarters section involved with the following work program: -Highway Perfonnance Monitoring System. Modeling the state's highway system in tenns of performance and cost. .Conducting legislative and other types of special studies. .Monitoring and updating the system of statewide highway functional classification. I worked on the State Legislature's Route Jurisdiction Study, a study to refine the definition of State Highway, and to recommend route changes between State and Local Agency jurisdiction to be consistent with the refined definition of State Highway. This study resulted in the transfer of hundreds of miles of roads between state and local jurisdictions. I worked 'on the Federal Highway Administration's Highways of National Significance Study. This study was conducted for the Federal Highway Administration by the States for the purpose of confonning to the revised Highway Program mandated by the Surface Transportation Act of 1991. I learned state-of-the-art computer techniques for modeling highway systems for performance characteristics while working with the Highway Performance Monitoring System This is a modeling effort done by all 50 states for the purpose of producing the Federal Highway Administration's annual report to the Congress entitled "The Nation's Highways--Conditions and Perfonnance". I wrote and distributed two publications for local agency use during this time period, entitled: "Short Count Factoring Guide", a guide book of recommended practice for local agency traffic counting programs, "The Highway Performance Monitoring System-Facts and Figures", an informational publication of highway statistics and cost analysis for the State of WaShington. Training taken through WSDOT included management and personnel relations courses, and the following WSDOT technical courses: LOG ITEM #--13c.J Page 3 D _ ot5.~.._ 40f8 I I I I I I I I I I I I I I I I I I I 10/78 - 6/84 8/77-9/78 LQ,G,ITEM # --.l1S" ~ PageM-of3'1 eLegal Aspects of Highway Engineering, a WSDOT contract course led by Michael Duggan of the King County Prosecutor's Office. eBeginning and advanced Highway Capacity Manual courses. eQuick Response Travel EstimatingTechniques, utilizing QRS software for producing traffic estimates for spot developments. Assistant District Materials and Project Engineer I was responsible for the day-ta-day operations of a District Section doing soils drilling, foundation analysis, materials quality control, minor plan production, design surveying, and construction inspection. The duties consisted of production of strip maps for minor design projects, including curve realignments, intersection upgrade projects, and paving projects. These projects were field surveyed, mapped, and designed under my direct supervision. I designed a system of estimating project costs for the District Three pavement rehabilitation program. This involved seoping all paving projects for the district's biennial program, including evaluation of deficiencies, identification of safety hazards, and costs to cure. The end product was a scope of work for contract plan production purposes, and an associated cost estimate to complete the work. I did this work for three years while I was in the District (now Olympic Region) Office. I evaluated pavement defects and produced resurfacing reports for pavement rehabilitation contract production for the district design program. Conducted soils slope stability investigations, and recommended solutions to our Headquarters Soils Engineering Group. Assistant District State Aid Engineer Duties as Assistant District Three (now Olympic Region) State Aid Engineer included administration of Federal Aid pass-through programs to the Cities and Counties of the seven northwest counties and cities within those counties. 50f8 -;- I I I I I I I I I I I I I I I I I I I Federal Aid programs I worked with were Bridge Replacement, Federal Aid Secondary, and the various sections of the Federal Aid Safety Program, including Railroad Crossing Upgrade Program, Safer Off System Program, Hazardous Intersection Program and the Pavement Marking Demonstration Program. I issued calls for prospectuses, evaluated and graded prospectuses according to criteria fonnulated by headquarters offices, set up reimbursable accounts for the projects> administered payments oflocal agencies, and assisted the Federal Highway Administration with inspections and documentation requirements. 6/76-7/77 I worked as Assistant to the Project Engineer in a major location and design office. This office specialized in large projects requiring Environmental Impact Statements: .Port Townsend Ferry Terminal Site Study - I scheduled, directed> and managed day-to-:day operations for this multi- disciplinary study leading to the recommended location for the present Feny Terminal in Port Townsend.. This study developed alternative designs and <:ost estimates for ferry tenninal sites, and also conducted an intensive public attitude surVey in the area to assess public desires and community visions for the project. Public hearings were held, and questionnaires were written, circulated> and evaluated. -Trident Base Access Study> Kitsap County - I scheduled> coordinated and managed day-to-day operations for a multi- disciplinary study of design alternatives and environmental. impact studies leading to a recommended design and EIS for the new State Route 3 access to the Naval Submarine Base> Bangor. I organized and managed this study from its inception to a point where the design and limited access bearings were ready to be held. This study included a citizen attitude survey conducted by questionnaire. -Tacoma Spur Study - I finalized the citizen participation aspect of this environmental impact statement, including evaluation of altemative designs. The study resulted in what is now Interstate 705 in Tacoma. -SR 167 Environmental and Location Study - I supervised the final environmental impact statement and contract plans for the section of SR 167 from Puyallup to the King County line. LOG ITEM # l~4 Page 3 ~ of X 60f8 .1 I I I I I I I I I I I I I I I I I I ",,,, 6/67 - 5/76 LOG ITEM #--1 ~q Pag~ 33 of 3lf I worked in the Aberdeen field office of Washington Department of Highways under John Hart, Project Engineer. I was promoted from Highway Engineer 1 to Highway Engineer 4 in this office. I gained a solid background in Highway Engineering in this nine year period, including surveying for right-of-way mapping, surveying for construction projects, including bridge and roadway layout and staking, slope staking, river channel realignment staking, surveying in tidal zones and topographic surveys for highway development projects. I estimate that I spent three years solid in the field in personal charge offield survey work. The remainder of this period always included scheduling and designing a wide variety of surveys, doing office computations for survey work, and turning out finished survey projects. Field surveys and office computations for contractor pay quantities were a routine part of work in this office, for the entire period that I was there. I qualified to sit for the Land Surveyor's Examination based upon work done in this office in right-of-way mapping, boundary surveys for highway construction projects, construction pay quantities, and became a Licensed Land Surveyor in 1979. Significant projects included: · Project inspector for the Shelton Bypass. I was the Department's lead inspector and surveyor in the field for this new five-mile section ofSR 101 bypassing the Town of Shelton in Mason County. This project included four bridges, three channel changes, three interchanges, and several miles of frontage road construction. I was responsible for all field staking, right-of-way staking, inspection, contractor relations, and pay quantity calculation for this project. .Project inspector for the Aberdeen-Hoquiam one-way couplet, a major realignment and construction of a one-way street system in the Cities of Aberdeen and Hoquiam. I was responsible for all field staking, inspection, contractor relations, and pay quantity calculation for this project. I was the survey party chief and surveyor for construction staking on the twin SR 107 overcrossing bridges on SR 12 near Montesano, and the lift span structure across the Hoquiam River at 6th Street in the City ofHoquiam 70f8 ~ .' I I I I I I I I I I I I I I I I I I I I served as Office Engineer for this office for a period of approximately three years. Duties included organization of office, supervision of design projects, calculation of pay quantities for contract work and production of contract plans for general highway work, As a staff Engineer for the Aberdeen Hoquiam Expressway Study, I evaluated alternative designs, prepared presentations for the citizens' advisory committee, and the interdisciplinary team assigned to the study. I supervised field operations for a citizens' attitude survey by questionnaire, and organized day-ta-day office operations for the study. This was a preliminary study for the anticipated construction of a new expressway through the Cities of Aberdeen and Hoquiam. This study is still underway, in one form or another. There were many minor to medium projects worked on during this time period. They are too numerous to mention, but project types included bridge site mapping for replacement, surveys for pavement rehabilitation, safety item installation, contract plans for the Elwha River Bridge and approaches, river erosion control projects, paving projects, safety design and construction projects, slide correction projects, and more. These projects typically involved work in both design and construction phases. LOG lTEiVl #--1~4 _ Pape _3 Y >-cof-3 t{ 80f8 I I I I I I I I I I I I I I I I I Q~. loll\ I ()~ \, Page 1 of 1 David W. Johnson From: Harvey Williamson [harveyw@cablespeed.com] Sent: Friday, June 11, 2004 12:39 PM To: David W. Johnson Subject: Port Ludlow Development Plan It is my understanding that you are reviewing the Development Plan for Port Ludlow. Their are several items I feel are very important to us in the community. 1. Development be limited to the currently approved residential units within the resort area (Master Plan Approved in 1993), in a fashion that does not negatively impact traffic flow and visual esthetics of the community. 2. Adequate parking be provided for all private and public facilities, taking in consideration the maximum use of each facility. 3. Continuation of the emphasis on open space. Harvey Williamson 82 Timber Heights Drive Port Ludlow, Wa. 98365 360-437 -0341 harveyw@cablespeed.com LOG iTEM #.-1 <35' _ I Page-l-- ofL_~r~'~ I 6/11/2004 l-n ~QJI .,1.. m,.j.J.. Qr--._.'._.;!' i,,_ IUUii ::J c- " ! ! c: I~'~ ; Z '\C:,~! ! ~_! ! '''.,== <- ~ IJlJ--!! I I .,,_.1 ~ -~ r'. --.1 l'~j! ~ ~l ~ : C'::)- -:;;:::-__ j .....-.,... -, '-~I I' f..,. '. '~.- ---'::.,'.' 1 ". -,= I I I, ,-;.i.: ...---1.. U-Uil/ \"'."- ... ..' . L.:. J~ L__,.,. --.J I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I # 1<61p IPage l 1 Ii ev~feJ! f 04 \ 1 (tIt ( \. R. P. & M. J. BALCK 192 M.ONTGOMERY COURT PORT LUDLOW, WA 98365 June 10, 2004 Jefferson County Department Of Community Development 621 Sheridan Street Port Townsend, WA 98368 JUN 11 20IK JEFFERSON COUNTY OeD Subject: DJafl Supplemental Environmentallmpact Statement (DSEIS) for Port Ludlow Resort Plan Revision Attn: Mr. AI Scalf, Director of Community Development Dear Mr. Scalf: We have major concerns regarding the above DSEIS as follows: 1. Traffic and Parking 2. Drainage 3. Density 4. Marina impact due to construction 1. Traffic and Parking We believe the roads to and through the Marina, Harbormaster Restaurant, Inn, Ludlow Bay Village, Admiralty III and other commercial properties will be a danger to the community. All traffic will pass through one intersection on Oak Bay Road. Even a stop signal (which we don't want) would not keep the vehicle, truck, bicycle and foot traffic flow smooth and safe. PLA has not indicated where the access points to the new condo units would be and how they would flow through other roads and parking lots. Delivery vehicles, fuel trucks, marina tenants loading and unloading their boats, Inn guests, condo residents and guests, restaurant patrons, marina store and office patrons, recreation center users, Yacht Club visitors, hikers, bicyclists and people and their families wanting to visit the waterfront will all co-mingle in one very congested area. It is a fantasy to assume that condo units will park one care in the one car garage and one in the driveway. (Most people downsizing to the small units PLA proposes will have their garage filled with stuff.) What about their parties and guests-where are they going to park? The "one car in garage and one car in driveway" concept PLA plans is unrealistic. The 332 parking spaces for all the activities and the condo units JUST DOESN'T MAKE SENSE! LOG ITEM of_~ 1/4.3.6 3.3.6 ~ The Marina currently has 100 parking spaces with some overflow up the hill. The Marina 100 spaces are often full with 20-40 cars parked in the overflow. On May 30,2004, the Marina had a Barbecue for marina tenants, and I personally counted 210 cars at 2 p.m. When 100 slips are added, count on a demand for another 30- 50 parking spaces. When you consider the restaurant, recreation facility, marina store and office, overflow from the Inn and condo residents and guests, there is no way to get them all in 332 parking spaces. How are the Marina tenants going to load and unload their boats! They will not get anywhere near the marina ramp. No special events will ever be able to be held at the marina because there will be NO parking. PLA should have to provide adjacent parking plus a parking structure that would accommodate more than the 332 spaces. There is also the danger of fuel trucks going down the dead end road to the Inn to :fill the marina's fuel tanks, which are alongside the boardwalk. 2. Drainage There is no mention as to how drainage will be handled. There will be a great deal of run-off and where will it go? 3. Density PLA states the density will be less than the previously proposed resort hotel. The added condo units will be different. It seems that PLA wants to build on every inch of premium land and take their profits and leave us with the urban mess. Some "Village in the Woods by the Bay"! 4. Marina As a Marina tenant we are concerned that our boat will be covered with construction dust on a continual basis. This could be a problem for 8-10 years. PLA must be forced to control wind blown particles on the marina boats. At a previous marina, every boat had to be washed and detailed on a regular basis at a cost to the company, which bad dirtied the vessels. PLA should have to pay to wash boats monthly and have them detailed quarterly. At the May Village Council meeting, you said your job was to protect the people of Port Ludlow. We expect you to meet this commitment. -----rn ~ ~ f:Bdth- Marlene J. Balck o {~C 360-437-2041 balck@cablespeed.com LOG iTEM #J 'G1P -- Page _~__ of _~- JUN 11 20tH JEFFERSON COUNTY OeD I I I I I I I 2/3.31 I 3/4.3j I 4/4.3.8 I I I I I I I I I I I ~ I I I I I I I I I I I I I I I . ~ORn lliP1!>W LUDLOW MAINTENANCE COMMISSION IBJll'~~ June 14,2004 JUH 1~ 214 Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 JEFFERSON COUNTY DCD Subject: Draft Supplemental Environmental Impact Statement (DSEIS)'FOr POrt Ludlow Resort Plan Revision Attention: Mr. AI Scalf Director, Department of Community Development Dear Mr. Scalf This letter is the response of the Ludlow Maintenance Commission (LMC) to the subject report. The LMC is the homeowners association for the North Bay residents of Port Ludlow representing over 1000 home, lot, and condominium owners. The review and comments contained herein represent the collective opinions of the LMC Board of Trustees acting on behalf of the Port Ludlow North Bay Community. We are very concerned about the lack of quality in the draft SEIS. The report contains significant errors, does not contain a baseline against which to judge the impact of the proposed revisions, and in most cases does not contain references to county, state and federal code requirements that allows us to evaluate the adequacy of the plan against requirements. The report appears to rely heavily on statements by the developer without any input from the community or the community homeowner associations. Further, it appears that little or no on-site visits to the Port Ludlow facilities were made by the engineering firms responsible for the preparation of the report. Our specific comments are listed below and ' - we strongly recommend that the report be rejected and completely redone. Resort Economics Paragraph 3.5.2 on page 3-58 states that the business model for the resort envisioned in the 1999 development agreement is no longer viable and that the alternate 1 plan is necessary to maintain the long term viability of the resort. Normally one would leave decisions regarding the resort business models to the developer. However, economics are discussed in the report and in this instance PLA is indicating that a changing business model is forcing them to modify the plan for the resort. It would thus appear that PLA is under a burden to both the County and to the community to demonstrate that the proposed revisions are in fact necessary and provide assurance for the long-term viability of the resort. There is no basis in the report to conclude that alternate 1 will assure the LOG ITEfV1 #-1t69 Page ---L--_ at 7 __. POST OFFICE BOX 65060 PORT LUDLOW, WASHINGTON 98365 1/4.3.1C 2/4.3.2 '') community the economic viability of the resort In fact, it is our opinion that the opposite is true. Alternate 1 does not add any rooms to the inn to better serve the traveling public, The restaurant is decreased'in size signitIcantly so it is less able to serve the public and" the Port Ludlow residents. Admiralty I and II, which has previously been used as rental units for the traveling public, are now rapidly being converted'to permanent residences by the owners. Thus, it would appear that there will be no additional units to serve the traveITing public and in fact the number may be decreasing. In less than 5 years the business model for the resort has changed. Who is to say that PLA's current business model will be valid in a few more years? There is no requirement that PLA construct all of the facilities shown in the alternative 1. We suspect that PLA could decide to only build the condominium and townhouse units to the maximum density permitted in the resort area and leave without constructing the additional amenities. What is the communities' protection against this? AcceptabiJity of Resort Revisions bv the Community Paragraph 3.5.1 on page 3-55 states "the facilities should also be consistent with the needs and desires of the citizens of the area and be compatible with the Shoreline Management Master Program." We can assure you in the strongest terms that alternate 1, with its significant increase in residential unit density, is not consistent with the needs and desires of the Port Ludlow community. The community has previously, in 1994, very strongly rejected a similar plan for high residential density. The higher density of building proposed by the alternative 1 plan change the esthetics and character of the resort area and will forever impact it negatively. If the County is serious about considering the needs and desires ofthe community you will reject the increase in residential units in the resort area. Resort ParkinS! The adequacy of parking was one of the big issues brought to the attention of the County in letters and during the scoping meeting held last July. In spite of that concern by the Port Ludlow community, parking is only superficially covered in the report and is in error. There are three different numbers in the report for parking spaces planned for the resort (see pages 2-5, 3-47,and 3-78). Which number is right? The report makes no reference to Jefferson County code for determining the number of parking spaces that are required (or the planned new facilities and the expansion of the marina. Page 3-78 of the DSEIS states that parking for the various commercial uses will be provided per county code and total 237 spaces. What is the basis for that number? We believe that number to be significantly in error. The parking analysis must specify the County code requirements for parking spaces for each area/facility within the resort area and demonstrate that the number of parking spaces is consistent with the code requirements and that the parking is within a reasonable distanceto the facility being served. It must include the planned use of the second floor oftJie restaurant building by the Port Ludlow Yacht Club and the use of the third floor as a conference facility. The report indicates that PLA has a lease agreement with LMC for the use of 56 parking spaces in the West Parking Lot That is not true. The lease agreement provides that PLA may have priority rights to 53 parking spaces if they upgraded the West Pm . LOG iTEfV1 #~? Page ~__of~=. I I I I I I I I 3/4.3.2 I I I 4/4.3.. 3.3'l I I I I JUN 14 2UU~ I Irr-r.t:'MN''\U f'f\IIMTV n~r I I I ~ I I I I I I I I- I I I I I I I contain a total of 106 parking spaces. This upgrade has not been done so PLA has only a non-exclusive right to the parking places in the West Lot and LMC has retained access and the right to use all spaces in the West Lot by LMC members, its officers, its guests and other invitees. Further, the lease expires January 1, 2013 and LMC does not currently plan to renew it. We therefore believe that for purposes of assessing long-term impact, none of the 56 parking spaces should be considered usable by resort facilities. The DSEIS states that each condominium and townhouse will have two off street parking spaces. Examination of the only plans made available to us would indicate that one parking space is behind the other. The reality is that it will be very cumbersome for residences to move one car to gain access to the other. People wi11likely park one car in the street in order to have ready access to their cars. This could block the streets and prevent emergency vehicles from access to all of the residences. Parking spaces for each townhouse or condominium should be parallel to each other so that there is ready access for each car. Stormwater Runoff No quantitative estimate has been made of the increase in stormwater runoff resulting from the proposed plan. How can you be confident that the additional steps proposed to be taken to handle the additional stormwater runoff will be sufficient if you do not know what the additional volume of water will be? Page 3-47, under Infrastructure 5/3.3.2 Improvements, states that "the existing storm drainage collection/conveyance system within Ludlow Bay Village will be evaluated to determine if the 100 year capacity is adequate to accommodate the additional runoff from the Admiralty III area." What happens if it is not adequate and why was this analysis not required to be a part of this SEIS? There is currently year round seepage and drainage of water from the meadow above Admiralty II into the lower parking areas, with water pushing its way up through the seams in the asphalt. The DSEIS makes no mention of this problem that will be greatly increased by additional surface water from the construction of Admiralty ID. This problem must be analyzed as a part ofthe DSEIS. We understand that the Port Ludlow Drainage District was not consulted about the impact of Alternative 1 on the drainage within Port Ludlow. How can the agency responsible for drainage within Port Ludlow not have input into this process? We assume that the additional stormwater runoff will carry with it significant additional silt into the lagoon and also petroleum products from parked vehicles. Has any estimate been made of the buildup of silt within the lagoon and the resulting environmental impact to habitat within the lagoon? The location of the retention pond for collection of stormwater runoff from the Admiralty III complex has not been shown. Where is this location, how large will the retention pond be, and what is the possible safety and environmental impact to all residences with the Admiralty complex of buildings? No consideration appears to have been given to overflow from a retention basin from earthquake, landslide or other events that could be destructive to the Admiralty property and to the residents of these units. LOG ITEM #~ Page,3 _ of--Z- J]DlV~~ JUN 14 20M JEFFERSON COUNTY DGD ') FIre District No.3 Impacts Page 3-95 presents a summary of mitigation/impact fees and property taxes to be paid to Fire District No.3 for each residential unit. There is no analysis that demonstrates that this additional money is sufticient to provide additional fire district personnel and equipment for emergency services such that the overall level of service within Port Ludlow is not degraded. A letter in the DSEIS from the Fire District No.3 Fire Chief discusses stations available to support the area but does not address the impact of the resort expansion on the level of service available. The DSEIS should be reviewed by Fire District No, 3 and their concurrence must be obtained that the overall service in Port Ludlow will not be negatively impacted. Loss of Community Recreational Facilities There is significant open space around the Admiralty I and II buildings wherein Pope Resources, in the initial development of the Admiralty complex, constructed amenity facilities including a children's playground, volleyball court, basketball court, horseshoe pits, trails etc. The construction of Admiralty ill will remove these amenities and there is nothing in the report to indicate that they will be replaced. Where is the mitigation necessary by taking these recreation facilities away from the community? Hazard Impact to Admiralty ComDlex Admiralty I and II and the proposed Admiralty ill area is known to be in an area of "Landslide Hazard-Medium Risk". Adding Admiralty III will worsen this potential hazard and create an area of even higher risk to the residents of Admiralty IT living close to the shoreline. A vaiIa bility of Facilities for Conferences The report indicates that small resort conferences can be held at the Bay Club, the Beach Club, the Heron Beach Inn or at the new restaurant. The County must be advised that the Bay Club and the Beach Club are not conference facilities as stated in the DSEIS. These are both private facilities for our members and guests. While we may occasionally rent out our facilities to outside organizations, it is on a very limited and as available basis. We do expect that as the population of North Bay increases pressure will increase to eliminate totally the renting of our facility to outside organizations. PLA should not assume the Beach Club facilities are available for their use. Compliance With County Ordinance 08-1004-99. Section 3.902 Section 3.902 of Jefferson County Ordinance 08-1004-99 Port Ludlow Development Regulations, states that architectural drawings including a detailed site plan, and architectural sketches or drawings showing approximate elevations, sections, and floor plans are required for the SEIS to assure that the SEIS considers project-level details. 6&'.:. None of the site plans contained in the DSEIS show the level of detail required by Ordinance 08-1004-99, Location of roads within the resort and described in the text of the report are not shown. Further, none of the proposed residential units are shown in sufficient detail that one can understand how access is obtained to the residences and LOG ITEIVl p~-J{' \.Lof 1" I I I I 6/4.3.9 I I 714.3.1 I I 814.3.11 I 9/4.3.1, ~ I I i i ~ '~ ~ ::z: ~ .., 10/4.3.1' I I I I I I I I I I I I I I I I I I I I I Comment 4.3.11.6: At a 1996 Planning Forum, owners requested to protect the natural environment and protect the area from over-development. Response 4.3.11.6: Your comment is noted. The overall Port Ludlow Development Plan and MPR regulations are not being revised. The zoning designations, including the Recreation Areas and Open Space Reserves shown on the Port Ludlow Comprehensive Plan (Figure 11 of the Draft SEIS), will remain unchanged. The approved development cap of 2,250 residential dwelling units will also remain unchanged. Comment 4.3.11.7: Two propane storage areas are planned, with no supporting safety or fire analysis. In our wooded area, fires are a major concern. Response 4.3.11.7: Your comment is noted. Any new propane storage area must meet fire code requirements. Comment 4.3.11.8: There is no discussion of the elevator at the parking lot or the 18-foot wall. What do these items consist of? What are the safety measures connected with these items? Response 4.3.11.8: The elevator will be a standard commercial exterior elevator integrated into the engineered concrete wall. All elevators in Jefferson County must meet specific construction and maintenance standards. The 18-foot wall will be an engineered retaining wall. All retaining walls over 4 feet in Jefferson County must be designed by a professional engineer licensed in the state of Washington. Comment 4.3.11.9: Pedestrian traffic will increase significantly with the planned revisions to the Resort. No analysis has been done regarding the planned revisions with respect to pedestrian safety. No pathways or sidewalks are proposed, so people will be forced to walk on roadways. Response 4.3.11.9: Your comment is noted. The proposed pedestrian trail plan is shown on Figure 13 of the Draft SEIS. This trail plan connects the upper community parking lots to the shoreline boardwalk and beach trail. Also, please refer to Response 4.3.6.3 in this Final SEIS. Comment 4.3.11.10: Assisted living care facilities should be provided. Response 4.3.11.10: Assisted living facilities are not considered an appropriate use within the RC/CF zone. Comment 4.3.11.11: Construction of Building 600 (within LBV) as a 6-unit condominium should not be allowed until all required approvals are in place. Response 4.3.11.11: Your comment is noted. No work on Building 600 is now underway. Port Ludlow Resort Plan Revision Final SEIS 4.38 May 2005 ~ Development of the MPR Regulations. The proposed Resort Plan will result in an incremental increase in the demand for services from the County Sheriff, but less demand that would have resulted from the 1999 Resort Plan. Over-all, the Port Ludlow MPR is limited to 2,250 units, wherever they are within the MPR. The proposed revision to the Resort Plan cannot alter the total number of units within the MPR. Although the County Sheriff has not commented on this particular project, the Sheriff's Office has recently commented on other projects stating that the steady incremental increase in population and residences within unincorporated Jefferson County has not been addressed through additional resources being provided to the Sheriff's Office and mitigation should be required to add those resources to the Sheriff's Office. The issue of appropriate resources for the County Sheriff's Office is a county-wide issue. The County must decide, on a county-wide basis, if they believe it is appropriate to assess SEP A mitigation or impact fees. If fees are assessed, they must be based on a study of costs and demand for services. No such studies have yet been prepared. The 1998 Jefferson County Comprehensive Plan does not address a level of service for uniformed officers. Comment 4.3.11.2: Jefferson County has no responsibility to PLA regarding the economic viability of their investment. Response 4.3.11.2:. Your comment is noted. Comment 4.3.11.3: Admiralty II needs protection from the impact of 39 new housing units; these new units will have no open space of their own. They will purchase property with expectations of enjoying the shoreline, walking paths and views. We request that PLA be required to install a fence along our joint boundary, ornamentally designed and including an entry gate for vehicular traffic. Response 4.3.11.3: Your comment is noted. All alternatives evaluated in this Final SEIS assume the entire Admiralty area is part of the Resort complex. Development of the Admiralty III area will be undertaken at a later date and will be subject to a public review process. Comment 4.3.11.4: The Twin Islands should be placed in a Conservancy. Response 4.3.11.4: Your comment is noted. The Twin Islands are not part of the area for which the revised Resort Plan, shoreline permit, or plat alteration is proposed. The applicant has committed, however, to permanent preservation of the Twin Islands. Comment 4.3.11.5: We do not understand why a copy of our comments are sent to the PL VC. The PL VC does not represent us. Response 4.3.11.5: All comments received on the Draft SEIS are part of the public record for this proposal. The PL VC has requested copies of all comments. 4-37 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Monitoring Reports. In addition to the required SEPA review, Jefferson County requires preparation of a series of annual monitoring reports that contain data on specific aspects of both the built and natural environments. Information from these monitoring reports is incorporated into the current SEIS. Further information on the content of the monitoring reports is presented in Response 4.3.1.1. Comment 4.3.10.2: No detailed site plans, architectural drawings, elevations, cross sections or floor plans are available for review. Response 4.3.10.2: Figure 3B of the Draft SEIS is a site plan (to scale) for the applicant's proposed Ludlow Bay Village development. Architectural drawings, elevations, cross sections and typical floor plans are shown in the DSEIS in Figures 12A and 12B and Figures 7 A, 7B, and 7C. Typical floor plans for the condominium units are included in this Final SEIS. A new site plan and typical floor plans are also been included in this FSEIS to illustrate the new Alternative 4 - Response to Comments (see Figures 6A, B, C and 15A, B). This level of detail is consistent with the requirements of Section 3.904 of the MPR Regulations. Comment 4.3.10.3: The Draft SEIS is limited to input from the developer. There is no input from the Fire Department, Fish and Wildlife, or any of the Port Ludlow Home Owners' Associations. Response 4.3.10.3: The intent of a Draft SEIS is to prepare and circulate a draft document to governmental agencies, tribal governments, community organizations, and private citizens for their review and comment. The Final SEIS is prepared after comments are received. This is the process being followed by Jefferson County. All comment letters are reprinted in this Final SEIS. A letter from Fire District No.3 was also included as Appendix G in the Draft SEIS. Comment 4.3.10.4: No one from Jefferson County Community Development made anyon-site visits to verify information. Response 4.3.10.4:. On-site visits to verify technical information were made by the consultants retained to prepare the technical studies. Also, please see Chapter 3, Section 3.3 and Response 4.3.4.1 for more information regarding preparation of the Draft SEIS. DCD staff has conducted frequent on-site visits and examinations of Ludlow Bay Village records. 4.3.11 Additional Comments Comment 4.3.11.1: With the population increase, who will be responsible for security? Will assistance come from Port Townsend? Response 4.3.11.1: Fire and emergency medical responses are addressed in Section 3.8 of the Draft SEIS. Police protection was not identified as an issue for EIS analysis by either the public scoping process for this SEIS, or by Section 3.904 Environmental Review for Resort Plan Port Ludlow Resort Plan Revision Final SEIS 4.36 May 2005 --- These two EIS' s provide the basis from which the current Supplemental EIS has been prepared. Currency of Information. For the current analysis, the 1993 and 2002 information was collected and reviewed then supplemented with site evaluations and compilation and review of current data. This is the accepted method of assessing existing conditions in the SEP A process and was applied to each area of technical expertise (i.e., transportation, wildlife habitat, etc.). More details regarding sources of technical information are provided in Response 4.3.4.1. The scope of the Supplemental EIS was developed pursuant to Section 3.904-Environmental Review for Resort Plan Development and a public scoping process, including a public scoping meeting held on July 16,2003. Level of Detail. The level of detail contained in an EIS should be commensurate with the level of detail in the application being reviewed and the alternatives being evaluated. In this case, the application is for a revision to the Resort Plan, shoreline permits, and plat alteration. Within the Supplemental EIS, different land uses mixes and densities for the Resort are evaluated and compared to one another in order to compare potential significant impacts. What is deemed "significant" for SEP A purposes and what an individual resident sees as "significant" may vary. For example, within a SEP A traffic analysis, the focus is on identification of the number of new vehicular trips generated by the proposal, on the impacts to the measured level of service on adjacent roadways, the operational safety of intersections, adequacy of parking facilities, impacts to transit, etc. These typical traffic impacts were described in Section 3.6 of the Draft SEIS. The same level of analysis was not applied to the interior, private roadways within the Resort, but is now included. SEPA does not typically involve analysis at the individual parcel level, especially when the proposed project is one element of a larger development approval. Issues related to public health, safety, and welfare at the parcel level are addressed by locally adopted ordinances and standards. It is assumed that the adopted development regulations adequately address impacts for those projects that fall under the regulations (RCW43.21C.240). If, however, a project proposal results in an incremental increase in anticipated impacts, the jurisdiction can then analyze whether the additional impacts still fall within accepted standards. For example, within the plat of Ludlow Bay Village, Heron Road was constructed to standards approved by Jefferson County as part of the platting process. Building setbacks along this road have also been established by the County. These standards are not proposed for change. The County will then review the proposed Resort Plan Revision to determine if additional vehicular traffic is proposed on Heron Road; and if so, if the additional traffic can be safely accommodated. In order to provide more detailed information regarding potential project impacts as part of this Final SEIS, further information and analysis has been provided in certain technical areas in order to respond to issues raised. The additional information and technical analyses are presented within Chapters 3 and 4. Port Ludlow Resort Plan Revision Final SEIS 4-35 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Response 4.3.9.6: As stated in Section 3.7.3.2 of the Draft SEIS, the sewage treatment plant has adequate capacity available to accommodate the proposed development. Comment 4.3.9.7: Low Impact Development techniques should be utilized in order to mitigate stormwater runoff from the additional impervious surfaces and to protect the marine habitat. Response 4.3.9.7: Your comment is noted. All new development must be consistent with applicable County drainage regulations. 4.3.10 Environmental Review Comment 4.3.10.1: Environmental Review Requirements Several comments address issues related to the apparent lack of current information used to undertake the current EIS analysis, reliance on previous EIS analyses, and the adequacy of the level of detail provided in the current Draft SEIS document. Following is a clarification of the environmental review process associated with the proposed revision to the Resort Plan. Response 4.3.10.1: As stated on pages 1-5 and 1-6 of the Draft SEIS, Jefferson County is using phased review, as authorized by SEPA (W AC197-11-060(5)(b)) and Section 3.902 of Ordinance No. 08-1004-99 in its review of development projects within Port Ludlow. Specifically, the current EIS supplements, and incorporates by reference, two EIS' s prepared in 1993-one at a programmatic level to analyze the impacts of the overall Port Ludlow MPR Development Plan (EIS for the Port Ludlow Development Program - Jefferson County, 1993) and one at a project- level to more specifically address development within Ludlow Bay Village (EIS for the Inn at Port Ludlow - Jefferson County, 1993). The current EIS also supplements, and incorporates by reference, the more recent project-level SEIS prepared to address the 100-slip expansion of the Marina - the 2002 Port Ludlow Marina Expansion EIS. In the 1993 programmatic EIS, the overall Port Ludlow Development Plan identified the Resort area as "Development Areas" 48 and 50. Development Area 48, the I8-acre area which later became LBV, was proposed to include 72 new residential units, along with new retail space, a 36-room Inn, expansion of the Marina by 100 slips, development of recreational trails, permanent open space, and supporting infrastructure including roads and utilities. Development Area 50, the area to be known as Admiralty III, was proposed to contain 50 new residential units. These units were in addition to the 64 units already constructed in Admiralty I and n. The second project-level EIS prepared in 1993 addressed the specific development proposal within what was to become LBV. Specifically, the proposed development included construction of a 36-room Inn, 72 residential units (23 single-family, 49 multi-family), 2,500 square feet of commercial space, renovated Marina support facilities, expansion of the existing manmade pond, parking, landscaping, shoreline public access, installation of riprap, and replacement of underground fuel tanks with above-ground tanks. Port Ludlow Resort Plan Revision Final SEIS 4-34 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS 4-33 May 2005 ~ I I I I I I I I I I I I I I I I I I I Comment 4.3.9.2: OWSI has no current water rights based on an inquiry directed to the Department of Ecology. The water rights are "claimed but not validated." Response 4.3.9.2: While no current rights are under the name of Olympic Water and Sewer (OWSI), the water rights that OWSI controls are under the name of the previous water purveyors: Pope Resources and/or Port Ludlow Water. Water rights are fully transferable. It is not necessary to transfer the water right ownership name for each transfer or change of water system name. Water rights remain with the point of withdrawal and the place of use. According to these valid certified groundwater rights, OWSI allocation is 465 acre-feet of groundwater rights. The total water allocated and total sustainable usage in the region is addressed in the basin assessment of Water Resource Inventory Area (WRIA) 17 conducted for the Department of Ecology. The Jefferson County Department of Health was the lead agency for the Quilcene-Snow watershed study that contains an evaluation of water rights, water usage, and aquifer sustain ability in the areas. Comment 4.3.9.3: The County should be responsible to the public to assure a continued supply of healthy drinking water. Response 4.3.9.3: The state of Washington Department of Ecology is responsible for the allocation and quality of the water resources. The state and county Departments of Health are responsible for drinking water issues. Also, it is in the best interest of OWSI to maintain and monitor a sustainable and safe drinking water source. Comment 4.3.9.4: The long term impact to the sewer, water and drainage systems should be addressed. Response 4.3.9.4: Your comment is noted. Sections 3.7.2, 3.7.3, and 3.2 of the Draft SEIS address the impacts to the sewer, water, and drainage systems. Comment 4.3.9.5: PLA should be required to demonstrate that they have sufficient water and sewer hook ups to serve the existing lots in North Bay and not stress the utilities presently in place. They should also demonstrate they are expanding those utilities without charging extra fees to present owners to cover costs of expansion. Response 4.3.9.5: Hookups to the water and sewer systems are monitored by the Olympic Water and Sewer Inc. As stated in the Draft SEIS, the water and sewer systems were designed to accommodate build out of the MPR. There is no plan to charge current property owners for installation of systems to serve new development; infrastructure associated with new development is provided by the developer. Comment 4.3.9.6: If developers wish to build and develop the area around the Marina they should be responsible, at their expanse, for the entire infrastructure, which would include expansion of the sewage treatment plant. 5 Parametrix, Pacific Groundwater Group, Montgomery Water Group, and Caldwell and Associates. 2000. Stage 1 Technical Assessment as of February 2000, Water Resource Inventory Area 17. I I I I I I I I I I I I I I I I I I I Response 4.3.9.1: Groundwater resources were evaluated in 198i, 19892 and again in 19923 by Robinson & Noble based on available information. In addition to these studies, Robinson & Noble's 1992 report, entitled South Aquifer Study Port Ludlow/Shine Area, contains detailed analyses of the aquifer hydrogeology, water balance, and recharge in the area. This study was based on available published reports and unpublished information, including Washington Department of Ecology (Ecology) water well reports and water right information and Olympic Water and Sewer, Inc. (OWSI) groundwater levels and usage data. Also, annual reports are produced for OWSI analyzing the water level and water usage trends for an extensive groundwater monitoring program that includes 17 wells.4 The information presented in the Draft SEIS has supporting documentation. Information regarding ongoing or future clearcutting could be relevant to impacts. The purpose of this section of the SEIS is not to assess water-related impacts associated with other developments in the resort's water-supply watershed. However, to the extent another major planned development could affect the ability of the North Aquifer to meet the resort's water supply needs, such developments are relevant to this impact assessment. Clearcutting and site development of land overlying the North Aquifer could have two types of impacts on the subsurface water supply; land conversion that significantly and adversely alters the aquifer characteristics or direct consumption of water after build-out leading to future aquifer drawdown. The evidence relative to the former is inconclusive in general. That is, clearcuts can affect groundwater recharge negatively (by reducing the holding capacity of the soils and by increasing runoff) or positively (by decreasing evapotranspiration, eliminating interception of rainfall by the forest canopy and allowing for direct infiltration into the ground). There is no site specific information to suggest that the clearcutting and site development activities noted in the comment will have a significant effect in either direction relative to the overall recharge amount or consumption. Regarding the second type of potential impact, OWSI is in the best position to determine whether its aquifers have the capacity to serve future users. OWSI maintains an extensive groundwater monitoring network in the Port Ludlow area that allows for the evaluation of trends in groundwater levels, precipitation, water quality, and seawater intrusion. There has been no evidence so far of a loss of sustainabilityof the groundwater supply. Regarding 3.2.2.3 Mitigation Measures, Mr. Lawson makes the same comment implying a lack of support documentation. Please see our response in the preceding paragraph. Regarding 3.2.2.4 Unavoidable Adverse Impacts, OWSI has certified water rights allocated by Ecology. This allows for the beneficial use of groundwater by OWSI. I Robinson & Noble, Inc. 1987. Evaluation of ground water resources potential, Port Ludlow. 2 Robinson & Noble, Inc. 1989. Water resource evaluation for Ludlow Utilities and construction of Well 14. 3 Robinson & Noble, Inc. 1992a. Evaluation of the impact of planned future development on Port Ludlow ground water resources. 4 Robinson & Noble, Inc. 2003. 2002 Annual Report on the Port Ludlow Area Ground Water Monitoring Program for Port Ludlow Associates, LLC, February 2003. Port Ludlow Resort Plan Revision Final SEIS 4.32 May 2005 ~ Comment 4.3.8.5: The Marina EIS process was in violation of the MPR Ordinances. Also, it does not include statements from the other agencies listed under Required Permits and Approvals - DNR is an example. Response 4.3.8.5: Your comment regarding process is noted. Please refer to your July 25,2002 letter, Response 5, in the 2002 Port Ludlow Marina Expansion Final Supplemental Environmental Impact Statement. In summary, Jefferson County determined that a separate review of the Marina Expansion was allowed but with the clear understanding that no land use permits or building permits were to be issued for the Marina project until a Resort SEIS was completed that identified cumulative impacts from both the upland and Marina projects. This SEIS addresses those cumulative impacts. Regarding comments from other agencies, the Draft SEIS was sent to all agencies with jurisdiction over the proposal; they are, however, not required to comment. Comment 4.3.8.6: I respectfully request to be included as a stake holder in all meetings and discussions in this Resort SEIS study. I request to be advised of all appeal procedures and date requirements of the County and State and other authority to stop the westward Marina expansion. Response 4.3.8.6: Your request is noted. Comment 4.3.8.7: Fire District No.3 has identified six proposed mitigation measures to be included as part of the proposed project. Also, the future of the existing fire pumps should be explained, and if to be retained, who will be responsible for maintenance and testing? Response 4.3.8.7: The applicant has agreed to the six mitigating measures. Regarding the fire pumps, the existing pumps are maintained by Port Ludlow Associates. Testing is the responsibility of the Fire District. Expansion of the Marina as proposed would result in removal of the existing fire pumps. Comment 4.3.8.8: We are excited about the proposed Marina expansion. Response 4.3.8.8: Your comment is noted. 4.3.9 Utilities Comment 4.3.9.1: Regarding water rights, the information stated in the Draft SEIS regarding the North Aquifer has no supporting documentation. Clearcutting of land overlying the aquifer is a serious concern. Port Ludlow Resort Plan Revision Final SEIS 4-31 May 2005 --- I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 4.3.8 Marina Expansion Comment 4.3.8.1: Westward expansion of the Marina will result in view obstruction, increased noise, and water quality degradation. The 120-foot fairway distance is not a sufficient corridor for access to the primary waterway. The need for the expansion and what recreational values the expansion would afford the community are questionable. Marina growth should be limited to a level commensurate with active boat usage. Response 4.3.8.1: The view, noise, and water quality degradation issues associated with the Marina expansion are addressed in detail in the 2002 Port Ludlow Marina Expansion Supplemental Environmental Impact Statement (see Chapters 3.6 AestheticsNisual Quality, 3.4 Land Use, and 3.2 Water, respectively). As noted in this EIS, the 120-foot fairway distance is an industry standard and is applicable to the conditions and number of boats using this waterway. The closest distance between the Scott Court dock and any proposed dock at the Marina would be 171 feet (see "Response to Comments AlternativelFigure 7, Port Ludlow Marina Expansion Final SEIS). Limiting the Marina to active boat usage would likely not be consistent with desires of the community. An area for dry boat storage would likely be required. Currently, there is no provision for upland storage or for a lift system to move boats in and out of the water. Locating a storage area and lift system adjacent to the shoreline would not be consistent with the proposed Resort Plan. Comment 4.3.8.2: Windblown dust and sawdust from the construction work will spread over the Marina, damaging the boats. The construction period will extend over a several year period. Control of the dust should be required. Response 4.3.8.2: Windblown dust can be substantially controlled by watering the site as needed. With winds from the north, some construction dust may, however, pass over the Marina. With the exception of construction of the new restaurant and recreation building, the majority of construction activities will occur above the Marina, away from the shoreline. Comment 4.3.8.3: Earlier comments on the Marina expansion, as well as comments from the State Department of Fish and Wildlife (WDFW) recommending only two alternatives - No Action or Deep Water Expansion, have been ignored. Response 4.3.8.3: All previous comments and the WDFW comments regarding the Marina expansion are contained in the 2002 Port Ludlow Marina Expansion Final Supplemental Environmental Impact Statement. Jefferson County has not yet made a decision on the design of the Marina expansion. That decision will come through the upcoming Shoreline Permit process. Comment 4.3.8.4: There is no record that the drawing for the "Alternative - 1993 Marina Design" was ever circulated. Response 4.3.8.4: Your comment is noted. Port Ludlow Resort Plan Revision Final SEIS 4-30 May 2005 ~ Inn, there will be no change to existing shoreline access - the existing trails and open space at the end of Burner Point will remain as will the existing beach trail. With all development alternatives, existing visual access to the shoreline from portions of Heron Road will be limited due to the construction of the new townhomes, restaurant, and recreational buildings. Shoreline access at Burner Point and along the beach would remain the same for all alternatives, available to the general public and signed accordingly. Comment 4.3.7.2: As density increases, public access will need to be defined to mark private vs. public areas. Response 4.3.7.2: A designated, signed trail system will be developed within LBV to provide for better pedestrian circulation and shoreline access. The proposed Trail system is shown in Figure 13 of the Draft EIS. Per State law, the beach is open to public access below Ordinary High Water (OHW). Comment 4.3.7.3: Any additional use of the shoreline in front of the townhomes would be detrimental to a fragile ecosystem. Response 4.3.7.3: As stated in Section 3.3.2 of the Draft SEIS (Plants and Animals, Operational Impacts), increased residential and Resort use will result in increased human use of the east- facing beach, primarily as beach combing and related low-intensity use. If this activity were to occur when surf smelt or sand lance eggs are present in the beach substrate, some eggs could be crushed; and the reproductive success rate of these fish populations could be reduced. The effect is expected to be small, however, in terms of the percentage of eggs lost and the impact on local populations of these species. Port Ludlow Resort Plan Revision Final SEIS 4.29 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I (i.e., eliminating the existing access from Heron Road to the Inn parking and relocation of the Harbormaster Restaurant) will result in restricting vehicular use of the east leg of Heron Road to the abutting town home residents. This action will mitigate many of the concerns associated with additional traffic, since the Harbormaster Restaurant and the Inn will be served from Gull Drive rather than Heron Drive. Because the volume of traffic on Heron Road and Gull Drive is within the capacity of the roadways and traffic on the east leg of Heron Road will be reduced, no street improvements are warranted. The low volume and speeds of vehicular traffic on the roadways, combined with the existing available trails and future boardwalk facility in the Resort area, are sufficient to handle the non-motorized needs. To further enhance local access operations (i.e., encourage low speeds and provide motorist guidance) within the Resort, it is recommended that directional signage to the existing and proposed destinations be installed/enhanced along the internal roadways, 15 mph speed limit signs be installed, and Heron Drive be signed for local access/residents only. Comment 4.3.6.4: The Transportation assessment in Section 3.6 is substantially in error and should be corrected. Actual impact is more than double the stated figure. Response 4.3.6.4: As stated in Section 3.6 of the Draft SEIS, trip generation rates used in the traffic analysis are estimated using the most recent values in the ITE Trip Generation Manual (6th Edition, 1997). This is the standard reference used for traffic studies throughout the state of Washington and in Jefferson County. 4.3.7 Public Access to the Shoreline Comment 4.3.7.1: The proposed Resort Plan will restrict existing access to the shoreline; the shoreline is now open to all. Response 4.3.7.1: The shoreline areas that are privately owned building lots (within the areas subject to development underall alternatives) are not now open to all. All development alternatives will change the shoreline in an approximate 400-foot area west of Gull Drive and the existing Marina store. This area now provides open, unimproved access to the shoreline above the Marina. With Alternatives 1 and 4, this area would be occupied by two townhome buildings, the relocated restaurant, and the new recreation facility. With Alternative 2, the area would be occupied by seven single-family dwellings. With Alternative 3, the area would be occupied by a retail/restaurant building and open space. Alternatives 1,3, and 4 include construction of a new 8-foot wide wooden boardwalk along the shoreline above the Marina; the boardwalk will extend from the new Harbormaster Restaurant easterly to the existing Inn. The boardwalk is intended to improve pedestrian access along this portion of the shoreline; this area now serves as a grass shoulder for Gull Drive. Easterly of the Port Ludlow Resort Plan Revision Final SEIS May 2005 --- 4-28 Port Ludlow Resort Plan Revision Final SEIS 4-27 May 2005 --- I I I I I I I I I I I I I I I I I I I to apply, to local access, private roadways such as those in Ludlow Bay Village, and are more applicable to the highway/arterial system. Providing bicycle-safe drainage grates, adjusting manhole covers to grade, and maintaining a smooth, clean riding surface are all reasonable measures along local access roadways, however, further widening and/or separate bicycle facilities are not reasonable for a local access roadway. Clear zone standards. The clear zone distance cited is not a requirement per AASHTO, but rather a distance that should be provided. The building setbacks along Heron Road were established per the Uniform Building Code (now the International Building Code), as adopted by Jefferson County. The design speed for Heron Road was 20 mph with an intended posted speed of 15 mph. These lower than typical speeds further limit the need for the 7- to lO-foot clearance noted. Sidewalks. The sidewalk standards noted are typical urban improvements. Heron Road is 24-feet in width consisting of two lO-foot paved driving lanes with 2-foot concrete shoulders. The concrete "strip" noted by the technical reviewer has never been designated as a sidewalk by the County, the designers, or the owners. The technical reviewer has concluded that since the concrete strip is not a sidewalk (per the criteria noted), it cannot accommodate pedestrians; and, therefore, pedestrians are forced into the travel lanes. No physical constraint was identified by the reviewer, however, that would "force" a pedestrian into the travel lane rather than walking within the concrete shoulder area. While the density of Ludlow Bay Village has the appearance of an urban area, AASHTO states that for traffic engineering purposes "urban areas are those places within boundaries set by the responsible State and local officials having a populations of 5,000 or more." Urban areas are further divided per AASHTO into areas with population of 50,000 or more and small urban areas with populations between 5,000 and 50,000. Rural areas are the areas outside the urban area boundaries. As such, urban and rural functional systems are classified separately. Ludlow Bay Village is not within an AASHTO urban boundary, and Heron Road is not designated as an AASHTO urban street. Thus, applying the AASHTO urban standard and the requirements for sidewalks is not applicable. Bicycle accommodation. Heron Road is 24 feet in width consisting of two lO-foot paved driving lanes with 2-foot concrete shoulders. (Note: the 2-foot concrete shoulder has yet to be constructed along some sections of roadway but will be constructed in the future. Until such time, this 2-foot section is paved.) The bicycle lane and bicycle path criteria noted may be appropriate if Heron Road is part of a designated County plan, but it isn't. Again, AASHTO specifically notes that the "local roadway may be sufficient to accommodate bicycle traffic." Handicap accommodation. No known impediments to the disabled currently exist along Heron Road. All new paths and the proposed boardwalk associated with the proposed project will be accessible. All new residential units will also be consistent with ADA requirements. Possible solutions. The additional impacts associated with the proposed action do not necessitate any further widening of Heron Road or additional non-motorized facilities other than those proposed. Revisions to the internal site circulation/access associated with Alternative 1 I I I I I I I I I I I I I I I I I I I roadway may be sufficient to accommodate bicycle traffic." Typically, bicycle facilities are not provided along local access roadways. The boardwalk is just a portion of the comprehensive community-wide trail system within Port Ludlow that has been constructed and maintained as a joint effort between the Port Ludlow Village Council and the developer. The trail system is intended to serve recreational uses, and provide a network between the residential areas and activity nodes, such as the recreation center, Marina, and commercial complex. Walking and cycling amenities within the Resort (and Port Ludlow in general) have typically been provided through the trail system or along the adjacent roadways. Port Ludlow is not considered or designated as an urban area. As such, facilities such as sidewalk construction or bike lanes are not required as part of the roadway construction, or are they required as part of the roadway standard for non-urban facilities. The low volume and speeds of vehicular traffic on the roadways, combined with the existing available trails and future boardwalk facility in the Resort area, are sufficient to handle the non-motorized needs. Miscellaneous considerations. The proposed project includes eliminating the existing access from Heron Road to the Inn parking, although access for emergency vehicles will be maintained via two 20-foot driveways from Heron Road. Closing the access between the Inn and Heron Road will result in a hammerhead turn around at the south end of Heron Road. This turnaround, coupled with the emergency access, has been reviewed and approved by Fire District No.3. Furthermore, the existing width of both Heron Road and Gull Drive are sufficiently wide to accommodate both fire and sheriff access. County road standards. As noted, the County Road Standards clearly state that roads in designated urban areas may require pedestrian improvements, including wider shoulders and sidewalks. This is not a mandatory requirement and would likely be at the discretion of the County Engineer, based on potential public need and the availability of other facilities, such as a trail system. As noted previously, Heron Road is not designated as a bicycle "route," and AASHTO specifically notes that the "local roadwaymaybe_sufficient to accommodate bicycle traffic. " Requirements for multiple use. As previously noted, Heron Road is not designated as a bicycle "route," and AASHTO specifically notes that the "local roadway may be sufficient to accommodate bicycle traffic." AASHTO merely notes that "where special facilities for bicycles are desired, they should be designed with the AASHTO Guide for the Development of Bicycle Facilities." There is no AASHTO requirement that non-motorized facilities be provided on local access roadways, and bicycle facilities are typically not provided along local access roadways. Heron Road is not an arterial or highway, public right-of-way, or part of the County's non-motorized plan. Bicycle safety use. None of the AASTHO or RCW citations (with the exception of noting that the roads in Ludlow Bay Village would be shared roadways) necessarily apply, or were intended Port Ludlow Resort Plan Revision Final SEIS 4-26 May 2005 ~ roadway (35 mph - under 400 ADT, 2-foot paved shoulders) standard for public roads, with the exception that the design speed used for Heron Road was 20 mph. The lower design speed was used and deemed appropriate, because Heron Road is a local access road and low speeds are desirable through this area. The garages of the townhomes along this section of Heron Road are set back 32 to 36 inches from the edge of the pavement, with an additional 2 feet of pavement to the edge of the travel lane. Heron Road was designed for a 20-mph speed, and stopping sight distances along the roadway meet this standard along all sections and exceed the design speed standard along many sections, especially the flat, straight sections along the Inn. The required stopping sight distance for a 20 mph design speed is 115 feet. Stopping sight distance is the more critical of the sight distance requirements along local accesses (rather than entering sight distance), since it allows an approaching motorist to react to an object in the roadway and stop the vehicle prior to reaching the object (in this case an emerging vehicle from a garage). Although the traffic volumes along Heron Road are extremely low, there is always the potential for a conflict between a backing vehicle and an on-coming vehicle. The available stopping sight distance does, however, allow an on-coming driver to react and stop for an emerging vehicle on those occasions when these events occur. Furthermore, agencies such as King County do not have entering sight distance requirements for local access roadways (Section 2.03 of the King County Road Standards), and the City of Bellevue would not consider the intersection of a residential driveway with a private roadway to fall under its provisions for intersection sight obstructions (section 14.60.240 of the Bellevue City and Land Use Code, Title 14-Transportation Code). Heron Road, in many ways, functions similarly to the alleys found in the older neighborhoods of Seattle or in the newly developed neo-traditional residential areas in cities such as DuPont in Pierce County. These residential areas have alley access to the garages and have little if any setback from the edge of pavement. Residents using the alleys travel at low speeds, are aware of the closeness of the garages and potential for conflicts, and adjust their driving behavior accordingly. With respect to the "dart-out" problem noted, this condition can occur along any roadway, and the construction of a wider roadway would not eliminate this condition or provide a safer condition. A wider roadway, especially one where parking is allowed, tends to encourage higher speeds and the presence of parked vehicles result in an visual obstacle where children cannot be observed until they step out into the traveled way. Use of Heron Drive by multiple modes of travel. The proposed action will likely generate additional non-motorized activity along the adjacent roadways that could potentially conflict with vehicular traffic. A designated trail has been shown on the site plan to serve residents of the resort and is a portion of the pathway system in Port Ludlow. Specifically, the portion of the trail system constructed under the proposed action includes the addition of an 8-foot wide boardwalk along the shoreline extending from the new recreational facility to the Inn. Heron Road is not designated as a bicycle "route," and AASHTO specifically notes that the "local 4-25 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Potential townhome purchasers will need to evaluate parking availability as part of their decision to purchase a unit within the Resort, versus within a single-family residential portion of the MPR. Additional infonnation with respect to parking supply for the commercial areas can be found in Section 3.4 and Appendix J of this Pinal SEIS. Pedestrian/bicycIe facilities. The proposed action will likely generate additional non-motorized activity along the adjacent roadways that could potentially conflict with vehicular traffic. A designated trail has been shown on the site plan to serve residents of the resort and is a portion of the pathway system in Port Ludlow. Specifically, the portion of the trail system constructed under the proposed action includes an 8-foot wide boardwalk along the shoreline extending from the new recreational facility to the Inn. The boardwalk is just a portion of the comprehensive community-wide trail system within Port Ludlow that has been constructed and maintained as a joint effort between the Port Ludlow Village Council and the developer. The trail system is intended to serve recreational uses, and provide a network between the residential areas and activity nodes, such as the recreation center, Marina, and commercial complex. Walking and cycling amenities within the Resort (and Port Ludlow in general) have typically been provided through the trail system or along the adjacent roadways. The low volume and speeds of vehicular traffic on the roadways, combined with the existing available trails and future boardwalk facility in the Resort area, are sufficient to handle the non-motorized needs. Comment 4.3.6.3: Extensive commentary was submitted with respect to Heron Drive, its adequacy, and its ability to serve the proposed action. Response 4.3.6.3: Altered and increased traffic patterns. Visitor parking currently exists at the north end of Heron Road as well as along Harbor Drive and Gull Drive. Any of these areas can currently be used by visitors to the Marina or shorelineltrails. The projected future volume of traffic along Heron Road at the easterly parking lot is projected to be approximately 220 vehicles per day, including the new townhomes that would be constructed between the Inn and the noted parking lot. Any increase in pedestrian or bicycle activity over the current conditions can be accommodated easily by the combination of multiple routes to access the Marina or shoreline/trails from the various parking areas, the availability of the existing footbridge across the lagoon, the construction of the future boardwalk, and the limited volume of traffic (especially along Heron Road). Sight distance, inter-visibility between users and modes. Heron Road is 24 feet in width (two lO-foot paved driving lanes with 2-foot concrete shoulders). The roadway is generally flat and straight along the section between the Inn and the townhomes, with some gentle horizontal and vertical curvature in the vicinity of the existing Harbonnaster Restaurant. The cross section of the roadway most closely resembles the Jefferson County typical road section for an I8-foot Port Ludlow Resort Plan Revision Final SEIS 4.24 May 2005 --- the roadway design, since it allows an approaching motorist to react to an object in the roadway and stop the vehicle prior to reaching the object (in this case an emerging vehicle from a garage). Although the traffic volumes along Heron Road are extremely low, there is always the potential for a conflict between a backing vehicle and an on-coming vehicle. The available stopping sight distance does, however, allow an on-coming driver to react and stop for an emerging vehicle on those occasions when these events occur. Heron Road, in many ways, functions similarly to the alleys found in the older neighborhoods of Seattle or in the newly developed neo-traditional residential areas in cities such as DuPont in Pierce County. These residential areas have alley access to the garages and have little, if any, setback from the edge of pavement. Residents using the alleys travel at low speeds, are aware of the closeness of the garages and potential for conflicts, and adjust their driving behavior accordingly. New development standards in cities that promote neo-traditional design encourage alley access to garages. Typical setbacks for garages accessing directly from alleys range from ,3 to 5 feet or require the garage to be set back a particular distance (12 feet is common) from the alley centerline. Other development codes have a zero setback but require a minimum alley width of between 24 and 26 feet. Revisions to the internal site circulation/access associated with the proposed action (i.e., eliminating the existing access from Heron Road to the Inn parking and relocation of the Harbormaster Restaurant) will result in restricting vehicular use of the east leg of Heron Road to the abutting townhome residents. To further enhance local access operations (i.e., encourage low speeds and provide motorist guidance) within the Resort, it is recommended that directional signage to the existing and proposed destinations be installed/enhanced along the internal roadways, 15-mph speed limit signs be installed, and Heron Drive be signed for local access/residents only. Those residents who find backing out the townhomes' garages to be difficult may want to consider backing into the garages so that their exiting maneuver will be less cumbersome and provide visibility of the roadway sooner as they exit the garage. Parking. The existing townhomes include a one-stall garage accessed from Heron Road. Parking is not allowed along the roadway, although some graveled areas are available out of the roadway cross section that can be used for parking. The new townhome units will include two off-street spaces per unit, which may be in tandem. Within the Resort, parking of multiple vehicles by visitors or residents is not encouraged and is restricted to the overflow lots. Overflow parking for all townhome units will be provided only in the community lots along the north side of Heron Road. No parking will be allowed on Heron Road or Gull Drive to eliminate blockages for the residents, visitors, and emergency vehicles. This restriction will be enforced by the Fire District. The Fire District has recently provided applicable signs for posting along Heron Road. Closing the access between the Inn and Heron Road will also eliminate the use of Inn parking by townhome residents. Furthermore, the graveled areas currently available for townhome guest parking will be eliminated with the new construction. 4-23 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Closing the existing Inn access will result in restricting vehicular use of the east leg of Heron Road to the abutting townhome residents. Thirteen town home units are situated at the south end of Heron Road, in the vicinity of the Inn, and an additional 28 units are/would be situated along Heron Road, north of the Inn and the artificial lagoon, up to the first (easterly) overflow parking access near the existing Harborrnaster Restaurant. The estimated future number of daily trips on this section of the roadway would be approximately 220 daily trips. This amount of traffic is also well below any capacity constraint for a two-lane roadway. Moving the Harborrnaster Restaurant to the shoreline area west of Gull Drive and accessing the Inn from Gull Drive will remove additional vehicular traffic from Heron Road. The volume of traffic on Heron Road and Gull Drive is clearly within the capacity of the roadways and the roadways can easily handle the increases associated with the proposed action. Visibility/sight distance. Residents along Heron Road have expressed concerns about the closeness of the townhome garages to the edge of roadway pavement and difficulty in backing from the garages. The closeness of the garages to the roadway has resulted in reduced visibility and "blind spots" when backing out of their garages onto Heron Road. Heron Road is 24 feet in width (two to-foot paved driving lanes with 2-foot concrete shoulders). The roadway is generally flat and straight along the section between the Inn and the townhomes, with some gentle horizontal and vertical curvature in the vicinity of the existing Harborrnaster Restaurant. Heron Road currently serves the existing townhome traffic, Harborrnaster Restaurant, some of the Inn traffic and miscellaneous service vehicles. The cross section of the roadway most closely resembles the Jefferson County typical road section for an 18-foot roadway (35 mph - under 400 ADT, 2-foot paved shoulders) standard for public roads, with the exception that the design speed used for Heron Road was 20 mph. The lower design speed was used, and deemed appropriate, since Heron Road is a local access road, and low speeds were desirable through this area. Vehicles can currently travel along Heron Road, through the Inn parking lot, and back onto Heron Road to "loop" through this area. No speed limit is currently posted along the roadway, or is parking allowed along the roadway, although some graveled areas are available out of the roadway cross section that can be used for parking. The garages of the townhomes along this section of Heron Road are setback 32 to 36 inches or more from the edge of the concrete shoulders, with an additional 2 feet of pavement to the edge of the travel lane. The closeness of the garage structure to the roadway, combined with the location of the driver's eye and line of sight when backing from garages, does have inherent limitations. Heron Road was designed for a 20-mph speed, and stopping sight distances along the roadway meet this standard along all sections and exceed the design speed standard along many sections, especially the flat, straight sections along the Inn. The required stopping sight distance for a 20 mph design speed is 115 feet. Stopping sight distance is considered an important element in Port Ludlow Resort Plan Revision Final SEIS 4-22 May 2005 --- of volume is generally considered light and can easily be served by a two-lane roadway. Marina View Drive serves as the main access for the resort traffic, and collects and distributes traffic to/from Olympic Place (to Admiralty), and to/from Heron Drive (to the parking areas, the Inn, the Marina, restaurant, and townhomes). As this distribution occurs, traffic volumes become smaller in magnitude. Capacity analyses completed for the traffic volumes currently traveling through the intersection of Oak Bay RoadlMarina View Drive showed that the intersection is currently operating at level of service (LOS) "B," and is projected to operate at LOS "C," with completion of the Resort (under the proposed action). This LOS projection includes traffic from both the Admiralty and LBV areas and the new/expanded commercial facilities, and is considered acceptable by Jefferson County. No further level of service analyses were performed for the interior intersections within the Resort, since a qualitative review of the volumes present clearly indicates that there are no capacity constraints at the present time, or would there be any constraints in the future. Intersections of interior LBV roads, which carry only a portion of the traffic traveling through the Oak Bay RoadlMarina View Drive intersection, will operate better than LOS "C," based on this comparative analysis. As stated in the Draft SEIS, current development within LBV includes the 120-seat Harbormaster Restaurant, the 37 room Inn at Port Ludlow, 25 townhomes, one single-family dwelling, and the 280-slip Marina. The primary area of concern expressed in the comments, is the east leg of Heron Road, i.e. that portion serving the existing townhomes and the Inn. Because the existing road system can function as a loop, vehicular traffic in this area is not necessarily restricted to townhome residents - it may also include guests at the Inn. It does not appear that this section of road is used significantly by patrons of either the Restaurant or Marina, however. The volume of traffic using Heron Road, together with the 24-foot pavement width and existing townhome setbacks, is perceived as a problem by some commentors. The proposed action includes eliminating the existing access from Heron Road to the Inn parking, although access for emergency vehicles will be maintained via two, 20-foot driveways from Heron Road. Closing the access between the Inn and Heron Road will result in a hammerhead turn-around at the south end of Heron Road. This turn-around, coupled with the emergency access, has been reviewed and approved by Fire District No.3. It is also recommended that directional signage to the existing and proposed destinations be installed/enhanced along the internal roadways, 15 mph speed-limit signs be installed, and Heron Drive be signed for local access/residents only. Port Ludlow Resort Plan Revision Final SEIS May 2005 ... 4.21 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I future homebuilding within North Bay. Based on utility records for the past five years for in-fill housing in the North Bay Area, a conservative estimate of up to 20 new homes per year might be constructed in a busy year. (The mid to late 1990s had much less construction activity.) Thus, the annual growth rates easily account for the portion of North Bay housing construction that could occur through 2010. In addition to these growth factors, traffic associated with pipeline development trips was also added into the existing volumes. The "pipeline trips" consisted of the traffic associated with the remaining housing units designated for construction under the Port Ludlow Master Plan which totals approximately 350 units. This value is not the same as MERU's. The MERU's include both commercial development converted into residential equivalents and residential development. While the use of equivalent residential units may be appropriate for utility projections, it is not necessarily the appropriate multiplying factor for the traffic forecasts. A portion of the trips associated with the 350 residential units remaining to be constructed under the Port Ludlow Master Plan will remain internal to Port Ludlow and consist of trips to and from future new commercial development and therefore simply be the part of the home-to-commercial-to-home trip. Thus, the combination of the use of the annual growth rate, the limited number of in-fill housing units in North Bay per year, the inclusion of the 350 residential units as pipeline traffic, and the percentage of internal trips more than adequately account for increased traffic volumes on the local county roadways and State highways. Off-site mitigation. Jefferson County Department of Public Works Staff has indicated the potential need for mitigation at two off-site intersections in order to mitigate traffic-related impacts associated with development under Alternative 3 (the 1999 Resort Plan). The level of service analyses completed for the Draft SEIS indicate that at least one of the critical movements at the intersections of Oak Bay RoadlWalker Way and Beaver Valley Road (SR-19)/Oak Bay Road could drop to level of service "E." If development occurs as proposed under Alternative 3, the project proponent would work with the County to mitigate its development impacts at these intersections. Comment 4.3.6.2: Internal Circulation. Several comments were received with respect to the internal traffic circulation within LBV. Specifically, comments reflected concerns with congestion, increased traffic, blocked streets (especially with respect to emergency vehicles), visibility, parking, and pedestrianlbicycle facilities. Response 4.3.6.2: The net increase in traffic associated with the proposed action was summarized in Table 6 (Section 3.6 - Transportation) of the Draft SEIS. The table showed an estimated weekend trip generation for the proposed action of 887 daily trips and 97 peak hour trips. Approximately 60 percent to 70 percent of this traffic is associated with the new townhomes, with the remaining trips associated with the Marina, PLA offices and the maintenance building. Current two-way weekend peak hour volumes on Marina View Drive total just under 100 vehicles, and the weekend daily volume is just over 1,200 vehicles per day. This magnitude Port Ludlow Resort Plan Revision Final SEIS 4-20 May 2005 ~ Jefferson County completed a traffic safety study of both Oak Bay Road and Paradise Bay Road in the mid-1990s at the request of the Council of Ludlow Owners Association. The report included speed studies, accident analysis, a review of the pavement markings and signs, intersection sight distances, and curve studies for both roadways. Based on the analyses completed for the County's report, some minor maintenance work and minor revisions to signs were recommended, along with increased enforcement of the speed zones. Otherwise, no changes in the speed limits or pavement markings were recommended. The more recent collision history further supports prior Jefferson County Staff findings. Based on the more recent accident data, prior review conducted by Jefferson County, current traffic volumes and operating conditions and available capacity, there is no technical basis to indicate that either Oak Bay Road or Paradise Bay Road cannot handle the additional traffic associated with the proposed action. Oak Bay RoadIWalker Way Intersection. The analyses completed in the Draft SEIS indicate that the Oak Bay RoadlWalker Way intersection is currently operating at level of service "E." The future (2010) level of service at the intersection upon completion of the Resort (Alternative 1) is projected at level of service "C," which is considered acceptable. (Note: the level of service "C" condition is for the stop controlled approaches; the uncontrolled movements operate at a better level of service.) The future conditions included an increase in traffic volumes through the intersection of approximately 60 percent. Even with this increase in traffic volumes, the intersection would operate at an acceptable level of service. Level of service "C" is generally not considered a congested condition. This level of service is also consistent with Jefferson County long-term forecasts for arterials in the vicinity. The accident history showed no reported collisions at this intersection during the 3-year period reviewed. The lack of any collision history typically indicates that no imminent hazards or unsafe conditions are present. Furthermore, the entering and stopping sight distances for the intersection meet AASHTO guidelines for the posted speed (40 mph) and a design speed of 45 mph. Thus, there is no technical or historical basis to indicate that the intersection of Oak Bay Road! Walker Way will not continue to operate in a reasonably safe condition in the future, with or without the proposed action. Future volume projections. Volume projections for the year 2010 (base condition-without project) were included in the Draft SEIS to account for increases resulting from traffic traveling through the area or traffic associated with miscellaneous new housing. Jefferson County completed extensive analysis to predict traffic growth rates on the arterials within the County as part of their Transportation Plan. These rates were based on historical housing and traffic growth rates and forecast housing growth to produce the estimated traffic growth rates. The County's data showed that the growth rates on those roadways near Port Ludlow that were reviewed in the Draft SEIS ranged from 2.8 percent to 6.09 percent annually. The appropriate annual growth rates were applied to the existing daily and peak hour traffic volumes to estimate the future (2010) volumes in the Draft SEIS. These annual growth rates account for the miscellaneous internal and external traffic growth from new housing, including Port Ludlow Resort Plan Revision Final SEIS May 2005 ~ 4.19 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Table 3 ACCIDENT HISTORY Accident TVDe Property LocationIY ear Damaee Injury Fatality Total Oak Bay Road: at Swansonville Road (MP 8.40) 2000 0 0 0 0 2001 0 0 0 0 2002 0 0 0 0 Between Swansonville Road and Paradise Bav Road (MP 8.40-9.47) 2000 0 0 0 0 2001 1 0 0 1 2002 1 0 0 1 at Paradise Bay Road (MP 9.47) 2000 0 0 0 0 2001 1 0 0 1 2002 0 0 0 0 Between Paradise Bay Road and Beaver Valley Road (MP 9.47-10.80) 2000 0 1 0 1 2001 0 0 0 0 2002 0 0 0 0 Paradise Bay Road: Between Oak Bay Road and SDinnaker Place (MP 0.00-0.45) 2000 0 0 0 0 2001 1 0 0 1 2002 0 0 0 0 Between Spinnaker Place and Ludlow Bay Road (MP 0.45-1.24) 2000 0 1 1 2 2001 0 1 0 1 2002 2 0 0 2 at Ludlow Bay Road (MP 1.24) 2000 0 1 0 1 2001 0 0 0 0 2002 0 0 0 0 at Teal Lake Road (MP 1.52) 2000 0 0 0 0 2001 0 0 0 0 2002 0 0 0 0 As noted in the Draft SEIS, the frequency of accidents in the area is low. The reported fatality involved a driver having a heart attack whose vehicle left the roadway and rolled over. Typically, the County reports accident data only for public roads; no accident data is available for private roads within the Resort. Port Ludlow Resort Plan Revision Final SEIS 4-18 May 2005 ~ of this Final SEIS). This playfield will include facilities similar to what is being removed from the existing playfield and will be constructed prior to removal of the existing playfield. Outdoor Sports Facilities. The proposed Resort Plan includes a new recreation building with an indoor/outdoor pool along the shoreline; no additional new outdoor sport facilities (except the new playfield described above) are proposed. The proposed Resort Plan includes a shoreline-related trail system as shown in Figure 13 of the Draft SEIS. No trail plan is proposed for the Admiralty area. 4.3.6 Transportation Comment 4.3.6.1: Off-Site Concerns. Comments were received regarding impacts to off-site intersections and roadways. Specifically, the comments reflected concerns about the safety of Oak Bay Road and Paradise Bay Road, the intersection of Oak Bay RoadlWalker Way, future traffic volume projections, and the need for off-site mitigation. Response 4.3.6.1: Oak Bay Road and Paradise Bay Road. Paradise Bay Road is a minor collector providing a connection between SR-104 just west of the Hood Canal Bridge and Oak Bay Road within the Port Ludlow community. The roadway is two lanes wide and is characterized by fairly gentle horizontal and vertical curvature. The posted speed varies from 30 mph to 50 mph, with a 40 mph speed posted within the Port Ludlow community. The roadway is 22-feet wide with shoulders varying from about 1 foot up to 10 feet. Oak Bay Road is a major collector providing access from Beaver Valley Road to the Oak Bay/Fort Flagler area to the north, traveling through the Port Ludlow community. The roadway is approximately 20 to 22 feet wide with shoulders up to 3-feet wide in certain areas, and open ditches. The posted speed is 40 mph. An all-way stop controls the intersection of Oak Bay RoadlParadise Bay Road. Traffic accident data was provided by Jefferson County for Oak Bay Road and Paradise Bay Road. The following table was shown in the Draft SEIS that summarizes the accident frequency along the roadway sections and at the major intersections for the years 2000, 2001, 2002. Port Ludlow Resort Plan Revision Final SEIS 4.17 May 2005 ~ I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Washington's bald eagles are protected under a variety of federal and state laws. The main protection for eagle habitat in the state was authorized by the Washington State Legislature in 1984 (RCW 77.12.655: Habitat buffer zones for bald eagles - Rules) and was implemented in 1986 by the adoption of the Bald Eagle Habitat Protection Rule (WAC 232-12-292). Bald eagle management recommendations were developed by WDFW in 2001 and have recently been updated. 4.3.5. Admiralty Undeveloped Areas, Open Space, and Recreational Facilities Comment 4.3.5.1: The proposed Resort Plan Revision will result in the construction of residential buildings in areas that are currently undeveloped. Commentors are concerned about the loss of open space within the Admiralty portion of the Resort, the loss of green spaces, the loss of the existing outdoor playfield located at the north end of Olympic Place, and the lack of outdoor sport facilities. Response 4.3.5.1: The 9.77 acre parcel to be platted as "Admiralty lII" is an undeveloped parcel lying within the designated Resort area. As stated in Section 3.3.2 of the Draft SEIS, the parcel is covered by lawn, a few scattered trees, and a circular grove of red alder trees and dense blackberry bushes about 25 feet in diameter. Local residents use the undeveloped area for recreati anal acti vi ti es. If Alternative 3 (1999 Resort Plan) were implemented, this area would remain as permanent open space, in order to compen~ate for the more intense development within the Ludlow Bay Village portion of the Resort (i.e., the amphitheater, large conference center, sports facilities, etc.). With Alternative 1 - the applicant's proposed project, the intensity of development within Ludlow Bay Village has been significantly reduced from that proposed in 1999, and residential development has been proposed for the Admiralty ill parcel. An area at the south end of Admiralty ill, along the north side of Marina View Drive, would be retained as permanent open space. This area would encompass open lawn, a childrens' playground, and an emergency helipad. Within the developed portion of the proposed plat of Admiralty ill, the new residential structures will be surrounded by open landscaped areas similar in character to Admiralty I and II. Visually, the parcel would become part of the developed landscape. Because the natural vegetation has already been removed from this site, the loss of open space will not result in a loss of valuable natural habitat. As stated in Section 3.3.2 of the Draft SEIS, the new development and associated human activity will, however, reduce or eliminate the population of the remaining wildlife. The closest documented eagle nest to the site is located beyond the 400-foot protective zone (or 800-foot buffer zone). Noise and other human activity may cause foraging eagles to avoid the Resort area and immediate surroundings, although the current level of such use is low. Playfield. The existing outdoor playfield located at the north end of Olympic Place is located within the Admiralty ill parcel, and will be removed to allow construction of new residential buildings. A new playfield will be constructed just north of Marina View Drive (see Figure 3A Port Ludlow Resort Plan Revision Final SEIS 4.16 May 2005 ~ Comment 4.3.4.3: Information in the Draft SEIS does not adequately address the proximity of certain threatened, endangered or sensitive (TES) species, and the project impacts on these species. In particular, it was noted that bald eagle have regularly been observed within or near the Resort site (e.g., roosting on the totem pole at Burner Point) and it was suggested by some that a bald eagle nest occurs near the sewage treatment plant immediately north of the resort. Also noted were observations of marbled murrelets within a few yards of the Marina at certain times of year. Some commentors stated or implied that the TES species information presented in the Draft SEIS was 12 years old. Response 4.3.4.3: As stated on page 3-23 of the Draft SEIS, the information on TES species and habitats was obtained primarily from the Washington Department of Fish and Wildlife (WDFW) in October 2003 by accessing their database on Priority Habitats and Species (PHS). Under a "Sensitive Fish and Wildlife Information Release Agreement" executed between WDFW and GeoEngineers, Inc., site-specific information on sensitive habitats and species known to occur within one mile from the Port Ludlow Resort site was provided to GeoEngineers with the understanding that certain types of highly sensitive site locations (e.g., bald eagle nests) cannot be presented in any public document. WDFW provided GeoEngineers with PHS maps showing locations of documented eagle nests and foraging territories, osprey nests, great blue heron colonies, harbor seal haulout and parturition locations, wetlands, listed fish species and other types of species and habitat information. Under the terms of the referenced agreement, the locations of only some of these features can be released whereas others (bald eagle nests) can only be described in general terms, such as general distance and direction from the Resort site. This was the information that was used to present information on TES species in the Draft SEIS (pages 3-23 to 3-26) and to conclude that there were no known eagle nests near the resort or on the west side Port Ludlow Bay nor were there any reported marbled murrelet colonies in the area. As further documentation, GeoEngineers contacted Michelle Tirhi, WDFW's bald eagle biologist, in August 2004. She confirmed that the information presented in the October 2003 PHS report was still current and that the state was not aware of any eagle nests near the Port Ludlow Resort or anywhere along the west side of Port Ludlow Bay. She encouraged anyone with information on eagle nests to report this information to WDFW; once it is investigated and assuming that location is verified, that information will be entered into the state's PHS database. The PHS database is a catalog of habitats and species considered to be state priorities for conservation and management. Priority species include those listed by the state as endangered (WAC 232-12-014), threatened (WAC 232-12-011) or sensitive (WAC 232-12-011). Also included are animal aggregations considered vulnerable and species of recreational, commercial or tribal importance that are vulnerable. For many of the listed habitats and species, WDFW develops management recommendations that assist landowners, users and managers in conducting land use activities in a manner that incorporates the needs of fish and wildlife. Port Ludlow Resort Plan Revision Final SEIS May 2005 ID:JDIaI 4.15 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 2003 update of habitat features on the site, and a current report on the most important habitats and species in the area affected by future project developments. This approach - collecting and reviewing information collected previously, then supplementing that with a site evaluation and compilation and review of current data - is the accepted method for assessing existing conditions in the SEPA process. More specifically, the SEPA Handbook states the purpose of a supplemental EIS is to add information and analysis to supplement the information in a previous EIS (namely, the 1992 Raedeke data). Jefferson County staff use the most updated mapping information available to review habitat reports submitted by applicants. Comment 4.3.4.2: The planned developments will adversely impact the artificial lagoon and the habitat it provides for birds, fish and other aquatic species. One commentor implied that the Draft SEIS stated the lagoon was a "dead body of water," a position the commentor disagreed with. Response 4.3.4.2: Considerable information was presented on the artificial lagoon, including the history of its initial construction in 1967 and its current conditions. Contrary to the "dead body of water" comment noted above, the Draft SEIS reported the lagoon was quite productive, exhibiting considerable algae growth at certain times of year. Information from WDFW was presented to show the artificial lagoon may provide some rearing habitat for marine fish, and a variety of birds and mammals were noted to use the lagoon. On the other hand, the artificial lagoon is not a natural feature and provides marginal habitat. Not only does it serve as a retention basin for stormwater from a portion of the Resort site, its exchange with the marine waters of the bay has been altered significantly by a culvert and tide gate, marine water is pumped into the lagoon to maintain its water level, and its shoreline is dominated by riprap and vertical walls with very little riparian vegetation. The extensive algae growth - which is removed periodically by mechanical means - also suggests that the artificial lagoon is receiving a large input of nutrients, possibly from fertilizers used in the drainage basin. So although the artificial lagoon is not dead by any means, it is far from a well functioning ecosystem. The planned project activities in and near the artificial lagoon are likely to cause some temporary increase in turbidity during construction, and during the life of the project there will be an increase in human noise and activity and an increase in shading where townhomes extend over the water. However, such changes are expected to have an insignificant effect on the fish and wildlife populations, which currently use the artificial lagoon. Once the landscaping plan is implemented, habitat values will increase and the impacts to life in and around the artificial lagoon will be beneficial relative to current conditions. An additional report on the history of the artificial lagoon, as well as its water quality, and existing habitat has been prepared by GeoEngineers (2004); this report is included as Appendix I of this Final SEIS. Port Ludlow Resort Plan Revision Final SEIS 4.14 May 2005 --- "No building or structure shall be erected, enlarged or structurally modified to exceed 35 feet in height, excluding roof projections, as measured by UBC standards, except that Hotels and associated Conference Center facilities may be allowed to a height not exceeding 50 feet as measured by UBC standards when the Jefferson County Fire District (No.3) finds that fire-fighting and life safety issues are adequately addressed." Comment 4.3.3.2: Existing open, green areas will be lost and converted to residential development. Response 4.3.3.2: Your comment is noted. Certain existing undeveloped areas will be converted to residential and Resort development; no area designated as permanent open space will be converted, however. 4.3.4 Wildlife Habitat Comment 4.3.4.1: Regarding the study methodology for plant and animal habitat, the Draft SEIS relied on old, and out-of-date, information - namely the 1992 surveys conducted by Raedeke Associates that were included in the 1992 Inn at Port Ludlow EIS. Several of the comments stated or suggested that no additional data gathering had been accomplished since 1992. Response 4.3.4.1: The work conducted by Raedeke in 1992 was referenced and summarized in the Draft SEIS because it provided comprehensive and relevant information on both the general region (an approximately 1,200-acre area surrounding the Port Ludlow Resort) and the resort site itself. This information was supplemented by a search for other sources of relevant information on plants and animals within or near the site (such as the current National Wetland Inventory), a site reconnaissance conducted on November 4, 2003, and the acquisition of the most current data on threatened, endangered and sensitive species and habitats from the Washington Department of Fish and Wildlife (WDFW) and the Washington Department of Natural Resources (WDNR). The WDFW is the primary source of information on Priority Habitats and Species (PHS) in the state, and the PHS report provided by WDFW on October 9,2003, represents the most current source of information on bald eagles, great blue heron and other sensitive fish and wildlife within a mile of the site. A current list of threatened, endangered and sensitive plant species maintained under the Washington Natural Heritage Program was obtained in 2003 from WDNR. Other current information (2002-2003) was obtained from personal communications with representatives of WDFW and Wild Olympic Salmon and review of such documents as the Salmon and Steelhead Habitat Limiting Factors report for the Qui1cene-Snow Basin (see references in the Draft SEIS). The outcome of this approach was a confirmation that the Raedeke data provided a reliable assessment of the general presence of plants and animals within the Resort site and vicinity, a Port Ludlow Resort Plan Revision Final SEIS May 2005 --- 4.13 I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I Comment 4.3.2.6: PLA's predecessor invested considerable time and money to help create a unanimously supported Comprehensive Plan Designation, Zoning Ordinance and Development Agreement (1999). All involved supported these regulations. Jefferson County has expended significant taxpayer dollars deliberating Port Ludlow's development. Years of work by both the public and private stakeholders should be honored. PLA has seemingly followed the contractually agreed upon procedures for development of their land. The County should as well. Response 4.3.2.6: Your comment is noted. Comment 4.3.2.7: Reference is made to use of the old conference center as PLA offices. This facility is under lease to Port Ludlow Vacations. There is also the possibility that this facility might be sold. Response 4.3.2.7: Your comment is noted. 4.3.3 Aesthetics Comment 4.3.3.1: Aesthetic impacts, including blockage of views from Oak Bay Road, by a mass of new, high density condominium buildings was not addressed. Response 4.3.3.1: Build-out of Alternative 1 (2003 Resort Plan) will result in new residential buildings within both Ludlow Bay Village (LBV) and the Admiralty area. Within LBV, one new townhome building, a new recreation building and the relocated Harbormaster Restaurant will be constructed along the western shoreline, and new two-story residential buildings will be constructed around the lagoon. Six new residential buildings and one maintenance building will be constructed within Admiralty III. A new 1,000 square foot central receiving facility will be located in the central portion of the Resort. Build-out of the 2003 Resort Plan will result in the conversion of some existing vacant lots to areas of residential and commercial development. Parcels designated as permanent open space will not be developed with structures. The areas to be converted to residential development include the slope along the east side of Oak Bay Road (between the conference center and Marina View Drive), the slope above the artificial lagoon, and the southwest corner of the shoreline, above the Marina. The elevation along Oak Bay Road varies from 60 to 80 feet. The new commercial buildings along the southwest shoreline will not exceed 35 feet in height; given the approximate base elevation of the buildings will be 10 feet, the elevation difference from Oak Bay Road will be approximately 15 to 35 feet. Views from Oak Bay Road will be altered, but not blocked. Alternatives 2 (1993 Resort Plan), 3 (1999 Resort Plan) and 4 (Response to Comments) also propose further development above the shoreline. Regarding Alternative 3, the existing MPR Regulations state that; Port Ludlow Resort Plan Revision Final SEIS 4.12 May 2005 ~ 4.3.2 Resort Function Comment 4.3.2.1: PLA is not partnering with the community - they are trying to improve their cash flow. Also, the advertising regarding Port Ludlow being a "Planned Community" is misleading. Response 4.3.2.1: Port Ludlow is a Master Planned Resort (MPR) being built out over a period of approximately 50 years. The current MPR Regulations were prepared and adopted after a lengthy community and County planning process. These regulations allow the owner to request a revision of the Resort Plan. A public hearing will be required. The decision to grant or deny the application rests with Jefferson County. The County has authority to enforce the regulations but cannot control management of the applicant's business. Comment 4.3.2.2: Changing from individually owned townhomes to condominiums creates a more transient occupancy. Response 4.3.2.2: This portion of the MPR is designated as the Resort. Transient occupancy of some units, whether the units are individually owned townhomes or condominiums, is expected based on the transient occupancy at this resort over the last 40 years. It should be noted that the true distinction here relates to the type of structure, not ownership. Townhome units may be "condominiumized" in the same way as stacked units, or could be rented out under long-term leases or on a short-term, even daily basis. Comment 4.3.2.3: The Beach Club is not a conference facility as stated in the DSEIS. A new private recreation facility would further split the community and make it more difficult to maintain existing facilities. Response 4.3.2.3: It is acknowledged that the Beach Club is not a conference facility. As stated in the Draft SEIS, the Beach Club can, however, be rented for conference use. Your comment regarding a new recreation facility is noted. Comment 4.3.2.4: With this project, the Jefferson County Plan for Port Ludlow wilJ change from a resort to an urban area. Response 4.3.2.4: Your comment is noted. The entirety of the Port Ludlow MPR is currently a designated Master Planned Resort (MPR) by the Jefferson County Comprehensive Plan. Within the MPR, the Resort zone is intended to be that area which is the most intensely developed. Urban residential densities up to 10 units per acre are allowed. Resort facilities such as the Inn at Port Ludlow, the Harbormaster Restaurant, the Marina, shoreline trails, and rental units are concentrated in the Resort zone. The shoreline along the Marina is also designated "Urban" by the Jefferson County Shoreline Master Program. Comment 4.3.2.5: The economic viability of the existing Resort, and/or the proposed Resort as described in the 2003 Resort Plan, is questionable. Response 4.3.2.5: This comment is noted. Port Ludlow Resort Plan Revision Final SEIS 4-11 May 2005 --- I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I development rights vested in the plat. Any development rights not included in the approved Resort Plan must be "... withdrawn, vacated or otherwise permanently released" by means of a plat alteration. The need for the plat alteration thus can only be determined after the Resort Plan has been approved. In 1999 - 2000, there was an attempt to resolve the conflicts through adoption of a "Redevelopment Agreement," which required approval of every owner within the plat. Signatures of all owners could not be obtained; however, this led to the decision to apply for a "plat alteration" applicable to properties still owned by PLA (the successor to Pope Resources). The plat alteration is required, however, only if the approved Resort Plan Building over the Artificial Lagoon. The proposed 2003 Resort Plan includes construction of three buildings containing residential units that extend out and over the north and east edge of the artificial lagoon. The question raised as to whether this proposal is consistent with the regulations of the Jefferson County Shoreline Master Program (SMP) pertaining to "over-water construction." This issue has not yet been fully resolved. The DOE states that the residential over-water construction is prohibited by the County SMP. Jefferson County will not challenge this interpretation; however, the applicant disputes this interpretation so the question will be resolved in a formal code interpretation as part of the upcoming permitting process. This Supplemental EIS analyzes impacts of the "worst-case" proposal, so further environmental review would not be required if construction over the water of the artificial lagoon is allowed. Required Permits. PLA is required to obtain several permits from Jefferson County to move forward with the 2003 Resort Plan. The approval process for these permits is specified in County Code and the MPR regulations. Action on these permits will proceed once the Pinal SEIS is completed. As stated in the Draft SEIS, the required permits include: · Approval of a change to the Resort Plan (agreed to be a "major revision," public hearing is required) · A Shoreline Substantial Development Permit for new development within Ludlow Bay Village · A shoreline substantial development permit for the Marina expansion The above applications are currently pending before Jefferson County and will be processed together. Subsequent applications include: · A boundary line adjustment or alteration to the plat of Ludlow Bay Village · A preliminary and final plat of Admiralty ill (public hearing required, but application not yet filed) · Building permits (administrative approval, following resolution of Resort Plan Revision, Shoreline Permit, and Plat Alteration) · Utility permits (administrative approval, following resolution of Resort Plan Revision, Shoreline Permit, and Plat Alteration) Port Ludlow Resort Plan Revision Final SEIS 4-10 May 2005 --- consistent with the existing plat of LBV, and this fact was recognized and addressed in applicable documents. Vesting. The Development Agreement specifies new development within Port Ludlow shall be subject to the following standards: . MPR Development Regulations . Jefferson County Stormwater Management Ordinance No. 10-1104-96 . Jefferson County Interim Critical Areas Ordinance No. 05-0509-94, as amended by Ordinance No. 14-0626-95 . Jefferson County Subdivision Ordinance No. 04-0526-92, RCW 58.17, and . Jefferson County Shoreline Master Program (1989, as revised through 1998) . Ludlow Water Company (now known as Olympic Water and Sewer, Inc.) System Plan, Jefferson County Coordinated Water System Plan, and W A Department of Health and all other applicable laws, ordinances, rules and regulations . Jefferson County Land Use Procedures Ordinance No. 04-0828-98 . Pope Resources General Sewer Plan, as approved by the Department of Ecology, and all other applicable laws, ordinances, rules and regulations Section 3.401 of the MPR regulations states the purpose of the RC/CP zone, recognizing the recreational nature of the resort as well as supporting existing residential uses. Sections 3.402 and 3.901 of the MPR regulations identify allowed uses within this zone. Multi-family uses within RC/CP zone are one of the allowed uses. The maximum density is 10 units per acre. To date, because all existing structures except the Pintail House contain three or more dwelling units, in this most intense area of development within the MPR, Jefferson County has identified the structures for all residential development within the Resort Complex zone (excluding the Pintail House) as "multi-family," whether the units were to be sold as "town homes" or "stacked flats." The residential building setbacks required are those required by the Shoreline Master Program and the Uniform Building Code; no other front, side or rear yard zoning setbacks are identified (see Section 3.30 of the MPR Regulations). The Resort was envisioned to become a destination resort for large conferences. Prom the MPR regulations and 1999 project graphics,-it can be seen that the LBVarea was proposed to contain a new amphitheater with parking below, a second, larger hotel and large conference center, museum, parking structure, indoor sports facility, and limited residential development. Section 3.901 of the MPR regulations sets forth the maximum development allowed within the resort area, without approval of a "major revision" to the resort plan. New residential uses were allowed, but undeveloped land was designated for future large resort facilities. Section 3.905 of the MPR regulations states that a change to this Plan shall be processed as either a major or minor revision. Changes that decrease the sizes of facilities are allowed (Section 3.901). Requirement for Plat Alteration The Development Agreement and MPR regulations explicitly acknowledge the existing plat of LBV and the potential conflicts between the plat and the then - anticipated Resort Plan (Alternative 3 of this PSEIS). Section 3.903 requires a Plat Alteration prior to issuance of permits for any new Resort development if the approved Resort Plan does not include all the 4-9 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I The Shoreline Permit was approved by Jefferson County on May 11, 1993 (Permit No. SDP91-017), and by the State Department of Ecology on June 14,1993 (Permit No. 1993-14647), subject to 51 conditions. The Shoreline Permit was similar to the proposal described in the 1993 project-level EIS. 1994/Plat of Ludlow Bay VilJage. The plat of LBV, a commercial and residential subdivision, was recorded in 1994. The associated Master Declaration of Covenants and Amendment are dated May 25, 1994, and April 25, 1995, respectively. The final plat of LBV recorded in 1994 was consistent with the 1993 Shoreline Permit and provided for 53-townhome units, five single-family units, the expanded pond, Inn, existing Harbormaster Restaurant, and roadway and infrastructure improvements (excluding Town Hall or retail space described in the 1993 EIS). The infrastructure approved and constructed, in association with the plat included, the street system, drainage system, sanitary sewer system, and water system. When the County accepted the plat, it found that the conditions attached to the Shoreline Permit and the plat approval had been met. Individual building permits were subsequently required for each new structure. 1990 - 1999ffhe GMA and Approval of MPR Development Agreement Achieving consistency between the 1990 GMA and the Jefferson County Comprehensive Plan and Development Regulations especially with regard to Port Ludlow, required several years of effort. The revised Jefferson County Comprehensive Plan was adopted in August 1998. To achieve consistency with the GMA, Jefferson County designated Port Ludlow as a "Master Planned Resort" as defined in RCW 36.70A.362. The Port Ludlow issue, however, was not fully resolved until completion of the Port Ludlow Planning Forum and resulting May 8, 2000, Development Agreement. This Planning Forum involved Jefferson County, Pope Resources, and Port Ludlow community groups and was conducted from August 1996 through 1999. The result of this Planning Forum was the Port Ludlow Development Agreement, which established the Development Standards for future development within Port Ludlow for the next 20 years. This agreement fundamentally changed the Port Ludlow planning and permitting process. The Development Agreement was adopted by Jefferson County as Resolution No. 42-00; the development standards are known as the MPR Regulations. The Development Agreement is between Jefferson County and Pope Resources (or its successors) entities, and any amendment requires written approval of both parties, and a public hearing process. MPR Resort Zone. The MPR regulations established seven "zones" within the MPR, one of which is the "Resort Complex/Community Facilities - MPR-RC/CF" zone. The RC/CF zone encompasses properties along the east side of Oak Bay Road, extending from the existing conference center on the north, to the marina on the south. The RC/CF zone combines the plats of LBV, Admiralty I and II, and undeveloped land, which will be known as the plat of Admiralty III, into "the Resort." The RC/CF designation reconfirmed the intent that this portion of the Port Ludlow development was to encompass the most intense land uses and development activities. The proposed Port Ludlow "Resort" development approved through this process was not Port Ludlow Resort Plan Revision Final SEIS 4-8 May 2005 --- Monitoring Reports. Monitoring reports have also been required over time by different public agencies. Currently, Jefferson County requires that Port Ludlow undertake monitoring and provide the County with a series of annual reports that track and report on: . The number of new lots approved and developed, and number of new residential units constructed . Impacts to Schools - The number of students generated, payment of SEP A mitigation fees, and property tax contributions . Impacts to Fire/Emergency Medical Services - Property tax contributions, payment of SEP A mitigation fees, and number of calls from Port Ludlow as compared to number of District-wide calls . Ground Water Level and Water Quality (chloride) Monitoring in area Aquifers-monitoring network of 17 wells . Receiving Water Quality (monitoring of non-point sources to Port Ludlow Bay). . Wastewater Treatment - Number of connections, effluent quality parameters . Traffic - Traffic counts, trip generation rates, turning movements at key intersections, and levels of service (LOS) for area highways and roads As of 2003, ten years of Monitoring Reports have been prepared and submitted to the County. The conclusions of these monitoring reports were incorporated into the 2003 Resort Expansion Draft SEIS. 1993 Shoreline Permit. Jefferson County and the W A State Department of Ecology approved a Shoreline Primary, Secondary and Conditional Use Permit for the 17.5 acre area to be known as Ludlow Bay Village, to allow construction of a residential, commercial, and recreational development consisting of the following: . A 36-room hotel (then known as the Heron Beach Inn) . Five detached single-family residences . 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 riprap shore defense works . Marina modifications - manager's building, restrooms, laundry, fuel and propane tanks, and removal of existing boat launch . Landscaping and recreational amenities - Vegetated artificial dunes on the southerly portion of the spit, trails and a pedestrian bridge, outdoor sport courts, and expansion of the existing pond . Approximately 45,000 cubic yards of excavation, grading and filling including 25,000 cubic yards for pond expansion . Temporary and permanent soil erosion control and storm water management system . Directional and informational signs . Outdoor Lighting . 10.5 acres of undeveloped open space 4-7 May 2005 --- Port Ludlow Resort Plan Revision Final SEIS I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I I 4.3 Comments and Responses Comment 4.3.1: Permitting for Resort Development Several comments address issues related to permitting within the Resort, and what land uses and densities are, or are not, currently allowed. There are also comments regarding status of the Ludlow Bay VilJage plat, the consistency between the plat and current development regulations, and the extent to which Port Ludlow Associates is required to build recreational amenities identified in the current development regulations. Response 4.3.1: This response clarifies status of existing permits and what new permits will be required to complete the proposed build-out of the Resort. The area identified as the "Port Ludlow Resort" lies within the larger Port Ludlow community, now known as the Port Ludlow Master Planned Resort (MPR). Development within the MPR began almost 35 years ago; the history of planning, and permitting is thus lengthy and complex. For purposes of this discussion, the term "Resort" refers to the area designated as "Resort" on the Jefferson County "Port Ludlow Comprehensive Plan - Land Use Designations" map (Figure 11 of the Draft SEIS, Figure 13 of the Final SEIS). This is the same area encompassed by the proposed Resort Plan Revision. That portion of the history relevant to the current development regulations for the Resort is summarized below. Permitting Development regulations pertaining to the Port Ludlow development as a whole, and to the Resort in particular, have evolved significantly over time - most recently, to respond to the 1990 Growth Management Act and evolving County standards. Current land development regulations are contained in Jefferson County Ordinance No. 08-1004-99, also known as the "MPR Development Regulations." Several other County regulations also apply to the Resort-Subdivision regulations, the Shoreline Management Act, Critical Area regulations, Jefferson County Storm Drainage standards, as well as building and street and utility permits. The Washington State Departments of Ecology (DOE) and Fish and Wildlife (WDFW), and the U.S. Army Corps of Engineers are also involved in permitting any projects below Ordinary High Water (OHW) or Mean High Water (MHW). The Port Ludlow water and sanitary sewers systems are regulated through the State Department of Health. A brief history of permitting within the Resort follows: Initial Resort Construction. Development of the Resort began in the mid-1960s, with construction of the 285-slip Marina, Harbormaster Restaurant, Beach Club, a conference center, and residential units within Admiralty I and II. The Resort was situated on the old sawmill site, homes and a hotel associated with the original Port Ludlow logging, shipbuilding and sawmill community established in the mid-1880s. The Resort area was eventually platted as Admiralty I and II, the plat of Ludlow Bay Village (LBV), and the existing commercial and residential buildings were constructed under then-current building code requirements. Port Ludlow Resort Plan Revision Final SEIS 4-6 May 2005 --- '\ ... Page 2 of2 disposition. However, I note that the description of the project as six townhouses is misleading. PLA represented in the SEIS and in meetings with the townhouse owners that the subject building would be six units organized as stacked condominiums and that such configuration would replace the 4 townhouse units that are provided in the 1994 plat. I understand from, I believe, Ms. Farfan, that you rejected the permit application on the basis of change in density and in nature of ownership and because of questions arising from the application of the Jefferson County Shorelines Management Program to proposed construction over the lagoon. That program forbids construction over water and provides additionally for a 30 foot setback from highwater edge. I would understand the rejection further to be supported by PLAts lack of compliance with RCW 58.l7.215's requirements for consent by a majority of persons with ownership interests in the plat ansd by unanimous consent of persons with property subject to the CC & Rs. These provide for an associastion of 53 platted townhouse owners and not a mix of townhouse owners and condominium owners or a number thereof in excess of 53 that would result under the proposed SEIS ifbuilt out. I also draw your attention to safety issues relating to Heron Dr. that are described in the engineering report attached to my comments to the draft SEIS. The proposed construction, whether as a six plex or as a four plex would increase the risks and potential liability to Jefferson County for approving an unsafe design of Heron Dr.. These matters should all be considered with applicable uniform codes in connection with any review of any permit application for building 600. I intend to provide by subsequent correspondence my analysis of the roadway problems and liability that flows therefrom. I understand from Ms. Farfan that the revised permit application will be submitted to a permit examiner and that interested parties will be given notice before any permit is approved with the opportunity to be heard on the matter. Your assistance on this matter is appreciated. Les Powers Powers & Therrien, P.S. 3502 Tieton Drive Yakima, WA 98902 Phone: 509-453-8906 Fax: 509-453-0745 This email is covered by the Electronic Communications Privacy Act, 18 U.S.C. Section 2510-2521 and is legally privileged. This message and any attachments hereto may contain confidential information intended only for the use of the individual or entity named above. If you are not the intended recipient(s), or the employee or agent responsible for delivery of this message to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this email message is strictly prohibited. If you have received this message in error, please immediately notify the sender and delete this email from your computer. LOG ITEIVI #~ Pace 2- of ~ W' . __ 6/17/2004 I I I I I I I I I I I I I I I I I I I ..I I I ). I I I I I I I I I I I I I I I Page 1 of2 Michelle Farfan From: AI Scalf Sent: Thursday, June 17,20048:51 AM To: Michelle Farfan Subject: FW: Permit for our files AI -----Original Message----- From: Powers & Therrien [mailto:powers_therrien@yvn.com] Sent: Wednesday, June 16, 2004 10:56 AM To: AI Scalf Cc: Schmitz5r@aol.com; carolsaber@olympus.net Subject: Re: Permit AI: I appreciate the response. I assume that the issuance of a shoreline permit after notice and a hearing and subject to modifications, if any, requisred thereby, is a condition among others, of the issuance of a building permit. I also assume that the revised building permit application will have to be posted in the same fashion as the initial April 9, 2004 application for comment. I finally assume that PLA will not conduct or be permitted to conduct construction activities on the four lots on which building 600 would be placed before obtaining both the SMA permit and the building permit against the revised application. If this is not the case, please advise me. I would also like to address with the permit examiner the safety issues 1/4 3 11 that I addressed briefly with you by prior email. My neighbor has already had a problem with young children of guests and. .. the dangerous roadway. I have three grandchildren four years old and under that I want protected. Hence. we, at our cost put in gates to our front porch. This does not resolve the roadway issue. It is simply not safe for pedestrians and will be rendered less safe if the property on its west side to the roadway is developed particularly in the narrow isthmus where our unit is located and the building immediately to the south. This is the case if any improvements are built at or near the roadway on the west side. I hope you understand my safety concern. Les ----- Original Message ----- From: AI Scalf To: Powers & Therrien Cc: Michelle Farfan; SchmitzSr@aol.com ; carolsaber@olympus.net Sent: Wednesday, June 16,200410:48 AM Subject: RE: Pe.rmit Les PLA has verbally indicated they will revise the building application from six to four units. The shoreline permit will have public notice and you can comment on the application at that time. AI -----Original Message----- From: Powers & Therrien [mailto:powers_therrien@yvn.com] Sent: Wednesday, June 16, 2004 10:17 AM To: AI Scalf Cc: Powers & Therrien; Michelle Farfan; SchmitzSr@aol.com; carolsaber@lolympus.net Subject: Permit Dear Mr. Scalf: I have a copy of LOG aFTEMn for building 600 at Port Ludlow dated April 9, 2004. #-.Jqy 6/17/2004 Page 1 _of;{ I am unclear about its :JJ ~ rn - o s: - o o I ~ o z [nn: I I I I I I I I I I I I I I I I I I I C- ~ ~ '" ffl --' = 52 ~ ~~ ~ ...p:. ffl ~ I I I ~ I I I I I I I I I I I I I I LOG ITEM #-1q~ _ I Page ---L- of-L 106 Edgewood Drive Port Ludlow, W A 98365 June 9,2004 Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 JUN 15 20M JEffERSON COUNTY OeD RE: Port Ludlow DEIS After having reviewed the material presented during the Town Meeting of the Port Ludlow Village Council on May 24,2004, Mrs. Yturri and I, as homeowners/residents of the community for over 3-years, feel it is important to provide our input into the proposed changes presented at that session. While we are, admittedly, novices in the world ofEIS and DEIS, the increase in dwelling density being proposed raises concern in two areas, about which we are submitting these comments. · The traffic patterns and congestion within the development complex will be impacted significantly with the addition of resident vehicles, even at one-or- two per homeowner. Additionally, the availability of parking for residents, guests of the hotel, and visitors to homeowners and the marina, was not presented in such a way as to feel that these issue(s) have yet been properly thought-out. 1/4.3.6 3.3.6 · More significantly the proposed modifications, particularly for those of us who live in Port Ludlow, but do not reside in the specific area under discussion, raise concerns regarding traffic on both Paradise Bay Road and Oak Bay Road. Posted speed limits on those roads are currently at 40 MPH. - Safety issues will undoubtedly increase, particularly in those areas of ingress/egress to and from the proposed development areas. 2/4.3.6 3.3.6 We trust that you will take these and all other related issues into serious consideration ;e:You~s~)~~u. ~^ ul E. Ytu . and Margaret A. Ytum \) Pat Pearson 1201 Ludlow Bay Road, Pt Ludlow. Page 2 of2 -I I I I I I 1 I I I I I I I I I I I -I LOG ITEM #.J3~ Page ~ of ~ , :JJ ~ C!! ffi\ ~ ~- \~\ 6 N \\JUU\ CJ \=. ~\ ~ \~S\ 3~_~liUI!\ z \ C=-..:=J J! '------------- . 6/1512004 I I I ~ I I I I I I I I I I I I I I I -Page lof 2 David W. Johnson From: Pat Pearson [pearsonp@wsu.edu] Sent: Monday, June 14, 2004 10:46 PM To: David W. Johnson Subject: pt. Ludlow DSEIS Dear Department of Community Development, This letter is to express my strong feelings about the proposed changes to the Port Ludlow Resort. According to the DSEIS, the proposed changes would increase the residential units from 122 units to 190 units, and change the units allowed in Ludlow Bay Village from 58 to 88 -- increasing the residential density by 56%. Although all of us Ludlow residents (we live across the bay from the resort) want the resort to be economically successful, I don't feel that these proposed changes are either an economic necessity nor beneficial to the Pt. Ludlow Resort community as a whole. A Master Planned Resort is just that ---- it 1/43.2 includes a Master Plan for development that was carefully thought out, created a long range plan for the ... benefit of the developers AND for the benefit of members purchasing homes and condos within the development. Both knew what they were investing in. My concerns are five fold: 1) that these changes will actually change the character, feel, and day by day 'liveability' for the hundreds of residents who have already committed to living in this community as originally reviewed and planned. 2/4.3.2 2) that building residential units next to and over the present lagoon takes away the 'commons' and creates issues such as 'is this buildable land, has it been taxed as such, what are the ramifications of building on/over this water body?" 3/4.3. 1 4.3.3 3) As we know more about surface water and stormwater issues, can we in good faith cover more of the natural drainage without impacting the natural drainage and filtration systems? This did not appear to be4/3.3.2 addressed in the DSEIS. How are the stormwater impacts going to be mitigated and at what costs? 4) The proposed changes w()uldinCrease the traffic, parking, and density within the resort boundaries in ways that appear to be incompatible with safety and residential living. 5/4.3.6 3.3.6 5) This is a matter of trust for the community. The residents have invested long term in their homes and committed to living their lives in this resort area. The resort changes hands, and is concerned with short term investment and profit. The residents expect that the Jefferson County planners and commissioners 614.3.Z will honor the original agreements. Why should these proposed changes be allowed at this point? Simply for increased economic 'viability'? It is the current residents who will bear the brunt of these changes, and continue to bear them for the remainder of their life in this community. Respectively, LOG ITEM #-1q~ Page-l~_of ~ 6/15/2004 .::0 ~ m lnni o C.- :5: ~ U 01 ~ irlJu o ~ = r m 0 ~ -i += o UlftJ Z~ I I I I I I I I I I I I I I I I I I I I LOG ITEf\1 #-1g { Page -L._ofL 1 I David W. Johnson I From: Sent: To: I Subject: Mark Pearson [pearsonm@cablespeed.com] Monday, June 14,200410:46 PM David W. Johnson changes in development at Port Ludlow ;" I To: Department of Community Development: Please let me add my voice to those who are concerned about the possible changes to the parameters for development in and around the Port Ludlow Resort. I feel the changes are strictly economic in nature and short term in scope--that the quality of life for those who live there and those who might choose to locate there will be diminished by increasing the development density, especially around the lagoon. It also appears that most 1/432 important considerations like parking, traffic congestion, and fire response are being 4 .3. ..0........ lover looked or short changed. . .1 My hope is that you will retain the status quo that has been arrived at over many years and much consideration. I Respectfully, Mark Pearson _(20t Gu1low ~~ ~ I ~ L- (y p. 9 ~ :s Co~ ( I I I I I I I I I '\ Page 1 of 1 David W. Johnson From: Doug Barker [doug-barker@comcast.net] Sent: Monday, June 14,20048:02 PM To: David W. Johnson Subject: Re: Complaint Regarding the Development Over the Wetlands at Port Ludlow Washington My mailing address is: 10233 Belgrove Court NW Seattle, WA. 98177 Thank You, Elizabeth ---- Original Message ----- From: David W. Johnson To: DOUQ Barker Sent: Monday, June 14,20048:27 AM Subject: RE: Complaint Regarding the Development Over the Wetlands at Port Ludlow Washington My I have your mailing address for the record, please? Thank you. From: Doug Barker [mailto:doug-barker@comcast.net) Sent: Sunday, June 13, 2004 9:37 PM To: David W. Johnson Subject: Complaint Regarding the Development Over the Wetlands at Port Ludlow Washington I am a homeowner in Port Ludlow Washington and I am very concerned that Port Ludlow Associates is building over wetlands.The wetland is used daily by bald ealges, blue heron, salmon, otters, geese and other wild life. This is unacceptable and needs to be address be a new and complete environement study immediatley. Please let me know how you will stop this development from moving forward without proper permits. Thank You, Elizabeth Sicktich LOG ITEM # _L9, 0 Page-L_ OfL 6/15/2004 I I I I I I I I I I I 1/4.31.. 4.3. 3.Y I I I I I I :0 ~ m o s;: o o r m --i o Z. I I I I I I I I I I I I I I I I I I I = LnnJ C- ~ 0 ~ ffi r--....:;. 52 l~ !lJlfU L~~ \ place since 1994. The addition of these two alternatives only adds volume to the report and further complicates the ability to read and understand the environmental impact analysis of the resort revision being requested by Port Ludlow Associates (PLA). They appear to only be strawmen against which to judge alternative 1. The LMC wants the developer to succeed in the final development of the resort into one that has long-term economic viability. It must, however, be a plan that works for both the developer and for the community. Alternate 1, as presented in the DSEIS, is not a plan acceptable to the Port Ludlow North Bay community. Our preference is that additional residential units be constructed as currently platted. We would be willing to consider removal of the current Harbor Master restaurant, construction of a new restaurant on the waterfront, and expansion of the marina only if it can be firmly demonstrated that adequate parking will exist for the facilities and that the traffic patterns within the resort do not cause a burden to the community. We strongly urge the County to refuse to accept the DSEIS in its present form. There are significant errors in it and environmental impacts to the resort and the Port Ludlow community have not been adequately analyzed. It is clearly a plan we cannot accept. We ask that you include LMC representatives to sit down with the County and the developer to work towards a plan that will be acceptable and beneficial to all. !' [/ ruce Schmitz Prr;dent, ~C r __ ' ~4h,1~ elson ard Member, LMC 'Sally sborn Board Member, LMC .(/~ LOG ITEM #J ~9 .._~ Page 2-- of--1-, JUN 14 20M JEffERSON COUNT\' OeD I I I I I I I I I I I I I I I I I I I I I I I ) I I I I I I I I I I I I I I I which existed at 2002. Finally, and perhaps more importantly, the report goes into great detail on the analysis of traffic impact to roads and road junction's external to Port Ludlow but does almost 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 spill-over parking. None of these items have been adequately addressed within the resort. The increase in residential units, the marina expansion and the remoteness of parking from resort facilities will significantly increase pedestrian traffic within the resort area. 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. There is no analysis to determine the amount of pedestrian traffic within the resort and the safety risk imposed by walking on the roadway. It is our belief that sidewalks are required within the resort to protect pedestrian traffic. ImDact of Recreational Facility on LMC The report indicates that the new condominium and townhouse residents, Inn guests and marina guests are the only ones that will be allowed the use of a new recreational facility to be built in the resort area. Further, PLA has publicly indicated that the new residential units may have their own homeowners association. The Port Ludlow community currently has a master homeowners association in North Bay and another in South Bay. We do not need to further separate various parts of the community and have another association that divides the community. In addition, it deprives LMC of potential member income threatening our economic viability. No changes should be made to the current CC&R's for Ludlow Bay Village that would eliminate the requirement that they become members ofLMC. Public Access to Beach Area Page 3-59 states that the proposed boardwalk and marina expansion will increase public access to the water. That statement is not true. The pedestrian access plan depicted in Figure 13 shows only one basic access trail to the beach as being in front of Heron Beach Inn. That access now exists so no change is being made to beach access. ComDliance With Shoreline Mana2ement Master Pr02ram Page 3-21 states that the lagoon is not a shoreline regulated under the Shoreline Management Act. We do not understand the basis for that statement as our reading of the Shoreline Management Act clearly indicates that the lagoon should fall under the provisions of the act. The County must provide the details for that statement so that we may appeal to the proper authorities if such a ruling has been made. If indeed the lagoon does fall under the regulations of the Shoreline Management Act then the proposed revision is in violation of several provisions of the act. Resort Plan Alternatives We do not understand why Alternates 2 and 3 are contained in the report. The report states neither of these alternatives may be implemented due to changes that have taken LOG ITEM 1114.8.10 #~9 Page V _of 7 14/4.3.2 15/4.3.1 16/4.3.1 , ( ( ~ .. f =: ~ C .-4 <. z ~ ::::> c '-) u 0 I.J. Ll Ll lJ.. ') where the parking is relative to the residence and the roadway. No detailed drawings are presented showing elevations of the various residential units and of the commercial buildings as they would be platted and laid out within the resort landscape. The floor plans included in the DSEIS do not represent all the types of residences proposed and it is not possible to determine where these units are located within the resort. There is no floor plan for any of the commercial buildings planned for the resort area. This significantly hampers our ability to review the document and evaluate the alternative 1 impacts. Propane StoraS!:e Areas and Analvsis of Hazards Page 3-94 states that two new propane storage areas will be added with one within Ludlow Bay Village and one within Admiralty ill. The size and location of these storage areas are not specified or shown on any of the site maps and no analysis is presented to demonstrate that the storage areas do not pose a danger to the residences. Environmental Impact to Resort Habitat Page 3-20 of the report indicates that a 1992 report forms the basis for evaluating the impact of the resort revision on the plant and animal communities within the resort area. How can a 12-year-old report be used as the primary source of data to evaluate current environmental impacts to endangered, threatened, sensitive, and other priority species and habitats in the resort area? The text of the report indicates that a number of species of concern are expected to occur within the area. Mitigation of the concerns and impacts are non-existent. Page 3-35 indicates that the following impacts are unavoidable: disturbance and displacement of some fish and wildlife species due to elevated levels of human activity and noise during the construction period; loss of vegetative cover and productivity between the time land is cleared and the time revegetation takes hold; increased surface runoff due to an increase in impermeable surfaces; loss of small areas of subtidal benthic habitat at the location of the new piling; possible loss of algal and epibenthic productivity at locations beneath the new floats; mortality to beach-spawning forage fish associated with increased human use of the beach; and increased risk of spills or discharge of gray/black water, petroleum products or hazardous material. Those words would indicate to us that there are significant negative environmental impacts that are not mitigated by this plan. The DSEIS states that there are no Eagle nests in the West portion of Port Ludlow Bay. This is in error. Several Eagles now reside in the west portion of the bay and in the Admiralty complex area both near the area proposed for resort revision. We see them flying every day and they roost on the totem pole on Burner Point. Transportation Analvsis The transportation analysis contained in Section 3.6 is in error. The test of the report indicates that the analysis used base data from a 2002 program and estimated traffic volume increases to 2010 at which time the resort is projected to be built out. The analysis used 350 residential units as the number of units remaining to be completed under the Port Ludlow Master Plan. That number is in error. As of2002 PLA had over 450 MERU's remaining for construction of residential units. Additionally, there are currently approximately 350 lots within North Bay that have not yet been built on. Thus, . at resort completion, there will be approximately 800 additional residences over that LOG ITEM #-1-<69 Page 5 _of "7 .~. I I I I I 11/4.3.1 1 I 12/4.3.1 I I 1 1 13/4.31 3.3.1 cf:; Ii ~ .~ I: ~ z: I ::::J I -, 11 I 1 1 .'1 I I ~.~ I I I I I I I I I I I I I I I " which existed at 2002. Finally, and perhaps more importantly, the report goes into great detail on the analysis of traffic impact to roads and road junction's external to Port Ludlow but does almost 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 spill-over parking. None of these items have been adequately addressed within the resort. The increase in residential units, the marina expansion and the remoteness of parking from resort facilities will significantly increase pedestrian traffic within the resort area. 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. There is no analysis to determine the amount of pedestrian traffic within the resort and the safety risk imposed by walking on the roadway. It is our belief that sidewalks are required within the resort to protect pedestrian traffic. Imnact of Recreational Facilitv on LMC The report indicates that the new condominium and townhouse residents, Inn guests and marina guests are the only ones that will be allowed the use of ~ new recreational facility to be built in the resort area. Further, PLA has publicly indicated that the new residential units may have their own homeowners association. The Port Ludlow community currently has a master homeowners association in North Bay and another in South Bay. We do not need to further separate various parts of the community and have another association that divides the community. In addition, it deprives LMC of potential member income threatening our economic viability. No changes should be made to the current CC&R' s for Ludlow Bay Village that would eliminate the requirement that they become members ofLMC. Public Access to Beach Area Page 3-59 states that the proposed boardwalk and marina expansion will increase public access to the water. That statement is not true. The pedestrian access plan depicted in Figure 13 shows only one basic access trail to the beach as being in front of Heron Beach Inn. That access now exists so no change is' being made to beach access. ComnJiance With Shoreline Mana2ement Master Pr02ram Page 3-21 states that the lagoon is not a shoreline regulated under the Shoreline Management Act. We do not understand the basis for that statement as our reading of the Shoreline Management Act clearly indicates that the lagoon should fall under the provisions of the act. The County must provide the details for that statement so that we may appeal to the proper authorities if such a ruling has been made. If indeed the lagoon does fall under the regulations of the Shoreline Management Act then the proposed revision is in violation of several provisions of the act. Resort Plan Alternatives We do not understand why Alternates 2 and 3 are contained in the report. The report states neither of these alternatives may be implemented due to changes that have taken LOG ITEM 11~4.3.1' #-1f69 Page lJ _of 7 - 1414.3.2 15/4.3.1 16/4.3.1 I C << ~ ... f ... ~ C 'P""4 C. z: ::2 = C ..., (j 0 LL LI. U ~ ~. .. . place since 1994. The addition ofthese two alternatives only adds volume to the report and further complicates the ability to read and understand the environmental impact analysis of the resort revision being requested by Port Ludlow Associates (PLA). They appear to only be strawmen against which to judge alternative 1. The LMC wants the developer to succeed in the final development of the resort into one that has long-term economic viability. It must, however, be a plan that works for both the developer and for the community. Alternate I, as presented in the DSEIS, is not a plan acceptable to the Port Ludlow North Bay community. Our preference is that additional residential units be constructed as currently platted. We would be willing to consider removal of the current Harbor Master restaurant, construction of a new restaurant on the waterfront, and expansion of the marina only if it can be firmly demonstrated that adequate parking will exist for the facilities and that the traffic patterns within the resort do not cause a burden to the community. We strongly urge the County to refuse to accept the DSEIS in its present form. There are significant errors in it and environmental impacts to the resort and the Port Ludlow community have npt been adequately analyzed. It is clearly a plan we cannot accept. We ask that you include LMC representatives to sit down with the County and the developer to work towards a plan that will be acceptable and beneficial to all. " {/ ruce Schmitz Prndent, ~C;_._ Ja-4/;y1~ elson ard Member, LMC Sally sborn Board Member, LMC ../', LOG ITEM #--L~9 _ ~_~ Page -2-_ of-2-. Jut( 14 20M JEFfERSON COUNl'l DCa I I I I I I I I I I I I I I I I I I I I I I. '~ I I I' I I I I I I I I I I I I p-age 1 of 1 David W. Johnson From: Doug Barker [doug-barker@comcast.net] Sent: Monday, June 14, 2004 8:02 PM To: David W. Johnson Subject: Re: Complaint Regarding the Development Over the Wetlands at Port Ludlow Washington My mailing address is: 10233 Belgrove Court NW Seattle, WA. 98177 Thank You, Elizabeth ---- Original Message ----- From:.David W. Johnson To: DOUQ Barker Sent: Monday, June 14, 2004 8:27 AM Subject: RE: Complaint Regarding the Development Over the Wetlands at Port Ludlow Washington My I have your mailing adqress for the record, please? Thank you. From: Doug Barker [mailto:doug-barker@comcast.net] Sent: Sunday, June 13, 20049:37 PM To: David W. Johnson Subject: Complaint Regarding the Development Over the Wetlands at Port Ludlow Washington lam a homeowner in Port Ludlow Washington and I am very concerned that Port Ludlow Associates is building over wetlands.The wetland is used daily by bald ealges, blue heron, salmon, otters, geese and other wild life. This is unacceptable and needs to be address be a new and complete environement study immediatley. Please let me know how you will stop this development from moving forward without proper permits. Thank You, Elizabeth Sicktich LOG ITEM #-Lqo Page-L_ o(L 6/1512004 1/4.3.1 4.3'.4 3.3.3 I David W. Johnson From: Sent: To: Subject: Mark Pearson [pearsonm@cablespeed.com] Monday, June 14,200410:46 PM David W. Johnson changes in development at Port Ludlow I I To: Department of Community Development: I Please let me add my voice to those who are concerned about the possible changes to the parameters for development in and around the Port Ludlow Resort. I feel the changes are strictly economic in nature and short term in scope--that the quality of life for those I who live there and those who might choose to locate there will be diminished by increasing ~~o~~::~O~::~~d~~~~i~~~ ~~i:c~:~~rn:~O~~~fi~~ ~~~~~~tio~: :~~of~~~e:~:p~~:~ ~:tbeing t~~~~I;~ over looked or short changed. &if.Q. I My hope is that you will retain the status quo that has been arrived at over many years . and much consideration. Respectfully, Mark Pearson I ( 20 t ~LJw f?~ {fJ t ~ L-- (y p. 9 ~ s Co "S ( I I I I I I I I I I LOG ITEM #~ Page -l._ofL I 1 I I I I I I I I' I I I I I I I I I I I I pg ~ o C- lrU-lI ~ ~ 0 o ~ InriJ o I 1"'.:1 c=:::::J m ~ ~ -I o [fiT[] z ~~ -l'age fof 2 David W. Johnson From: Pat Pearson [pearsonp@wsu.edu] Sent: Monday, June 14, 200410:46 PM To: David W. Johnson Subject: pt. Ludlow DSEIS Dear Department of Community Development, This letter is to express my strong feelings about the proposed changes to the Port Ludlow Resort. According to the DSEIS, the proposed changes would increase the residential units from 122 units to 190 units, and change the units allowed in Ludlow Bay Village from 58 to 88 -- increasing the residential density by 56%. I I I I I I I Although all of us Ludlow residents (we live across the bay from the resort) want the resort to be economically successfu. 1, I don't feel that these prop.osed changes are either an economic necessity nor................ . beneficial to the Pt. Ludlow Resort community as a whole. A Master Planned Resort is just that ---- it 1/43 ..~ includes a Master Plan for development that was carefully thought out, created a long range plan for the .. 3) As we know more about surface water and stormwater issues, can we in good faith cover more ofthe..- natural drainage without impacting the natural drainage and filtration systems? This did not appear to be4/3.3.. addressed in the DSEIS.How are the stormwater impacts going to be mitigated and at what costs? 4) The proposed changes woiildincrease the traffic, parking, and density within the resort boundaries in; ../..1 ways that appear to be incompatible with safety and residential living. i/~.3.1 3.3., 814.3., I I I benefit of the developers AND for the benefit of members purchasing homes and condos within the development. Both knew what they were investing in. My concerns are five fold: 1) that these changes will actually change the character, feel, and day by day 'liveability' for the hundreds of residents who have already committed to living in this community as originally reviewed and planned. 2) that building residential units next to and over the present lagoon takes away the 'commons' and creates issues such as 'is this buildable land, has it been taxed as such, what are the ramifications of building on/over this water body?" 5) This is a matter of trust for the community. The residents have invested long term in their homes and committed to living their lives in this resort area. The resort changes hands, and is concerned with short term investment and profit. The residents expect that the Jefferson County planners and commissioners will honor the original agreements. Why should these proposed changes be allowed at this point? Simply for increased economic 'viability'? It is the current residents who will bear the brunt of these changes, and continue to bear them for the remainder of their life in this community. Respectively, LOG ITEM #-1q~ p I 1 : age-L__of. ~ 6/15/2004 'I 2f4.:t.) 314.3.J 4.3., I I I - I I I I I I I I I I I I I I I :D ~ m - o s a o I ~ o z Pat Pearson 1201 Ludlow Bay Road, Pt Ludlow. LOG ITEM #JS~ Page d-... of ~ . 6/1512004 ffl 2 P :z: N [fiTu = ~ ~ [fTFil CC;=-2] Page 2 of2- 106 Edgewood Drive Port Ludlow, W A 98365 I I I I I I I I I I 1/4.3.1 3.3.iSI '\ June 9, 2004 Jefferson County Department of Community Development 621 Sheridan Street Port Townsend, W A 98368 JUN 15 20M JEfFERSON COUNTY OCD RE: Port Ludlow DEIS After having reviewed the material presented during the Town Meeting of the Port Ludlow Village Council on May 24, 2004, Mrs. Yturri and I, as homeowners/residents of the community for over 3-years, feel it is important to provide our input into the proposed changes presented at that session. While we are, admittedly, novices in the world ofEIS and DEIS, the increase in dwelling density being proposed raises concern in two areas, about which we are submitting these comments. · The traffic patterns and congestion within the development complex will be impacted significantly with the addition of resident vehicles, even at one-or- two per homeowner. Additionally, the availability of parking for residents, guests of the hotel, and visitors to homeowners and the marina, was not presented in such a way as to feel that these issue(s) have yet been properly thought-out. · More significantly the proposed modifications, particularly for those of us who live in Port Ludlow, but do not reside in the specific area under discussion, raise concerns regarding traffic on both Paradise Bay Road and Oak Bay Road. Posted speed limits on those roads are currently at 40 MPH. - Safety issues will undoubtedly increase, particularly in those areas of ingress/egress to and from the proposed development areas. We trust that you will take these and all other related issues into serious consideration ;'h~YOU~);::~OO. ~ ul E. Ytu . and Margaret A. Ytum LOG ITEM #--1 q~ _ Page -Lof-L_ I 214.3.1 .3..3.t I I I I I I I I I I I I I' I I I I I I I I I I I I ::D ~ !!! CJ C- [nnl s: ~ ~ - CJ ~ INTI CJ -- I rv = m 22 ~ -l ...- o ffi Z~ I appreciate the response. I assume that the issuance of a shoreline permit after notice and a hearing and subject to modifications, if any, requisred thereby, is a condition among others, of the issuance of a building permit. I also assume that the revised building permit application will have to be posted in the same fashion as the initial April 9, 2004 application for comment. I finally assume that PLA will not conduct or be permitted to conduct construction activities on the four lots on which building 600 would be placed before obtaining both the SMA permit and the building permit against the revised . application. If this is not the case, please advise me. I would also like to address with the permit exarninerthe safety issues.1143 1 "'" that I addressed briefly with you by prior ernail. My neighbor has already had a problem with young children of guests and. ... 1 the dangerous roadway. I have three grandchildren four years old and under that I want protected. Hence. we, at our cost put in gates to our front porch. This does not resolve the roadway issue. It is simply not safe for pedestrians and will be rendered less safe if the property on its west side to the roadway is developed particularly in the narrow isthmus where our unit is located and the building immediately to the south. This is the case if any improvements are built at or near the roadway on the west side. I hope you understand my safety concern. Page 1 of2 Michelle Farfan From: AI Scalf Sent: Thursday, June 17,20048:51 AM To: Michelle Farfan Subject: FW: Permit for our files AI -----Original Message----- From: Powers & Therrien [mailto:powers_therrien@yvn.com] Sent: Wednesday, June 16, 2004 10:56 AM To:. Al Scalf Cc: SchmitzSr@aol.com; carolsaber@olympus.net Subject: Re: Penn it AI: Les ----- Original Message ----- From: AI Scalf To: Powers & Therrien Cc: Michelle Farfan; SchmitzSr@aol.com ; carolsaber@olympus.net Sent: Wednesday, June 16, 2004 10:48 AM Subject: RE: Permit Les PLA has verbally indicated they will revise the building application from six to four units. The shoreline permit will have public notice and you can comment on the application at that time. AI -----Original Message----- From: Powers & Therrien [mailto:powers_therrien@yvn.com] Sent: Wednesday, June 16, 2004 10:17 AM To: AI Scalf Cc: Powers & Therrien; Michelle Farfan; SchmitzSr(1ilaol.com; carolsaber(1ilolympus.net Subject: Permit Dear Mr. Scalf: I have a copy of LOG arfE~~r for building 600 at Port Ludlow dated April 9, 2004. 6/17/2004 p~~:) _o( 2,- I am unclear about its I I I I I I I I I I I I I I I I I I I I I '~ I I I I I I I I I I I ,I I I I --- Page 2 of2 disposition. However, I note that the description of the project as six townhouses is misleading. PLA represented in the SEIS and in meetings with the townhouse owners that the subject building would be six units organized as stacked condominiums and that such configuration would replace the 4 townhouse units that are provided in the 1994 plat. I understand from, I believe, Ms. Farfan, that you rejected the permit application on the basis of change in density and in nature of ownership and because of questions arising from the application of the Jefferson County Shorelines ManagementProgram to proposed construction over the lagoon. That program forbids construction over water and provides additionally for a 30 foot setback from highwater edge. I would understand the rejection further to be supported byPLA's lack of compliance with RCW 58.17.215's requirements for consent by a majority of persons with ownership interests in the plat ansd by unanimous consent of persons with property subject to the CC & Rs. These provide for anassociastion of 53 platted townhouse owners and not a mix of townhouse owners and condominium owners or a number thereof in excess of 53 that would result under the proposed SEIS ifbuilt out. I also draw your attention to safety issues relating to Heron Dr. that are described in the engineering report attached to my comments to the draft SEIS. The proposed construction, whether as a six plex or as a four plex would increase the risks and potential liability to Jefferson County for approving an unsafe design of Heron Dr.. These matters should all be considered with applicable uniform codes in connection with any review of any permit application for building 600. I intend to provide by subsequent correspondence my analysis of the roadway problems and liability that flows therefrom. I understand from Ms. Farfan that the revised permit application will be submitted to a permit examiner and that interested parties will be given notice before any permit is approved with the opportunity to be heard on the matter. Your assistance on this matter is appreciated. Les Powers Powers & Therrien, P .S. 3502 Tieton Drive Yakima, WA 98902 Phone: 509-453-8906 Fax: 509-453-0745 This email is covered by the Electronic Communications Privacy Act, 18 U.S.C. Section 2510-2521 and is legally privileged. This message and any attachments hereto may contain confidential information intended only for the use of the individual or entity named above. If you are not theintendecl recipient(s), or the employee or agent responsible for delivery of this message to the intended recipient(s), you are hereby notified that any dissemination, distribution or copying of this email message is strictly prohibited. If you have received this message in error, please immediately notify the sender and delete this email from your computer. LOG ITEI\J1 #~ Page 2- of. ~ 6/17/2004 Port Ludlow Resort Plan Revision Final SEIS 4-6 May 2005 --- I I I I I I I I I I I I I I I I I I I 4.3 Comments and Responses Comment 4.3.1: Permitting for Resort Development Several comments address issues related to permitting within the Resort, and what land uses and densiti~s are, or are not, currently allowed. There are also comments regarding status of the Ludlow Bay Village plat, the consistency between the plat and current development regulations, and the extent to which Port Ludlow Associates is required to build recreational amenities identified in the current development regulations. Response 4.3.1: This response clarifies status of existing permits and what new permits will be required to complete the proposed build-out of the Resort. The area identified as the "Port Ludlow Resort" lies within the larger Port Ludlow community, now known as the Port Ludlow Master Planned Resort (MPR). Development within the MPR began almost 35 years ago; the history of planning, and permitting is thus lengthy and complex. For purposes of this discussion, the term "Resort" refers to the area designated as "Resort" on the Jefferson County "Port Ludlow Comprehensive Plan - Land Use Designations" map (Figure 11 of the Draft SEIS, Figure 13 of the Final SEIS). This is the same area encompassed by the proposed Resort Plan Revision. That portion of the history relevant to the current development regulations for the Resort is summarized below. Permitting Development regulations pertaining to the Port Ludlow development as a whole, and to the Resort in particular, have evolved significantly over time - most recently, to respond to the 1990 Growth Management Act and evolving County standards. Current land development regulations are contained in Jefferson County Ordinance No. 08-1004-99, also known as the "MPR Development Regulations." Several other County regulations also apply to the Resort-Subdivision regulations, the Shoreline Management Act, Critical Area regulations, Jefferson County Storm Drainage standards, as well as building and street and utility permits. The Washington State Departments of Ecology (DOE) and Fish and Wildlife (WDFW), and the U.S. Army Corps of Engineers are also involved in permitting any projects below Ordinary High Water (OHW) or Mean High Water (MHW). The Port Ludlow water and sanitary sewers systems are regulated through the State Department of Health. A brief history of permitting within the Resort follows: Initial Resort Construction. Development of the Resort began in the mid-1960s, with construction of the 285-slip Marina, Harbormaster Restaurant, Beach Club, a conference center, and residential units within Admiralty I and II. The Resort was situated on the old sawmill site, homes and a hotel associated with the original Port Ludlow logging, shipbuilding and sawmill community established in the mid-1880s. The Resort area was eventually platted as Admiralty I and II, the plat of Ludlow Bay Village (LBV), and the existing commercial and residential buildings were constructed under then-current building code requirements. I I I I I I I I I I I I I I I I I I I Monitoring Reports. Monitoring reports have also been required over time by different public agencies. Currently, Jefferson County requires that Port Ludlow undertake monitoring and provide the County with a series of annual reports that track and report on: . The number of new lots approved and developed, and number of new residential units constructed . Impacts to Schools - The number of students generated, payment of SEPA mitigation fees, and property tax contributions . Impacts to Fire/Emergency Medical Services - Property tax contributions, payment of SEP A mitigation fees, and number of calls from Port Ludlow as compared to number of District-wide calls . Ground Water Level and Water Quality (chloride) Monitoring in area Aquifers-monitoring network of 17 wells . Receiving Water Quality (monitoring of non-point sources to Port Ludlow Bay). . Wastewater Treatment - Number of connections, effluent quality parameters . Traffic - Traffic counts, trip generation rates, turning movements at key intersections, and levels of service (LOS) for area highways and roads As of 2003, ten years of Monitoring Reports have been prepared and submitted to the County. The conclusions of these monitoring reports were incorporated into the 2003 Resort Expansion Draft SEIS. 1993 Shoreline Permit. Jefferson County and the WA State Department of Ecology approved a Shoreline Primary, Secondary and Conditional Use Permit for the 17.5 acre area to be known as Ludlow Bay Village, to allow construction of a residential, commercial, and recreational development consisting of the following: . A 36-room hotel (then known as the Heron Beach Inn) . Five detached single-family residences . 53attached 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 riprap shore defense works . Marina modifications - manager's building, restrooms, laundry, fuel and propane tanks, and removal of existing boatlaunch . Landscaping and recreational amenities - Vegetated artificial dunes on the southerly portion of the spit, trails and a pedestrian bridge, outdoor sport courts, and expansion of the existing pond . Approximately 45,000 cubic yards of excavation, grading and filling including 25,000 cubic yards for pond expansion . Temporary and permanent soil erosion control and storm water management system . Directional and informational signs . Outdoor Lighting . 10.5 acres of undeveloped open space Port Ludlow Resort Plan Revision Final SEIS 4-7 May 2005 --- Port Ludlow Resort Plan Revision Final SEIS 4-8 May 2005 ~ I I I I I I I I I I I I I I I I I I I The Shoreline Permit was approved by Jefferson County on May 11, 1993 (Permit No. SDP91-017), and by the State Department of Ecology on June 14, 1993 (Permit No. 1993-14647), subject to 51 conditions. The Shoreline Permit was similar to the proposal described in the 1993 project-level EIS. 1994/Plat of Ludlow Bay Village. The plat of LBV, a commercial and residential subdivision, was recorded in 1994. The associated Master Declaration of Covenants and Amendment are dated May 25, 1994, and April 25, 1995, respectively. The final plat ofLBV recorded in 1994 was consistent with the 1993 Shoreline Permit and provided for 53-townhome units, five single-family units, the expanded pond, Inn, existing Harbormaster Restaurant, and roadway and infrastructure improvements (excluding Town Hall or retail space described in the 1993 EIS). The infrastructure approved and constructed, in association with the plat included, the street system, drainage system, sanitary sewer system, and water system. When the County accepted the plat, it found that the conditions attached to the Shoreline Permit and the plat approval had been met. Individual building permits were subsequently required for each new structure. 1990 - 1999ffhe GMA and Approval of MPR Development Agreement Achieving consistency between the 1990 GMA and the Jefferson County Comprehensive Plan and Development Regulations especially with regard to Port Ludlow, required several years of effort. The revised Jefferson County Comprehensive Plan was adopted in August 1998. To achieve consistency with the GMA, Jefferson County designated Port Ludlow as a "Master Planned Resort" as defined in RCW 36.70A.362. The Port Ludlow issue, however, was not fully resolved until completion of the Port Ludlow Planning Forum and resulting May 8, 2000, Development Agreement. This Planning Forum involved Jefferson County, Pope Resources, and Port Ludlow community groups and was conducted from August 1996 through 1999. The result of this Planning Forum was the Port Ludlow Development Agreement, which established the Development Standards for future development within Port Ludlow for the next 20 years. This agreement fundamentally changed the Port Ludlow planning and permitting process. The Development Agreement was adopted by Jefferson County as Resolution No. 42-00; the development standards are known as the MPR Regulations. The Development Agreement is between Jefferson County and Pope Resources (or its successors) entities, and any amendment requires written approval of both parties, and a public hearing process. MPR Resort Zone. The MPR regulations established seven "zones" within the MPR, one of which is the "Resort Complex/Community Facilities - MPR-RC/CF" zone. The RC/CF zone encompasses properties along the east side of Oak Bay Road, extending from the existing conference center on the north, to the marina on the south. The RC/CPzone combines the plats of LBV, Admiralty I and II, and undeveloped land, which will be known as the plat of Admiralty ill, into "the Resort." The RC/CF designation reconfirmed the intent that this portion of the Port Ludlow development was to encompass the most intense land uses and development activities. The proposed Port Ludlow "Resort" development approved through this process was not I I I I I I, I' I I I I I I I I I I I I consistent with the existing plat of LBV, and this fact was recognized and addressed in applicable documents. Vesting. The Development Agreement specifies new development within Port Ludlow shall be subject to the following standards: . MPR Development Regulations . Jefferson County Stormwater Management Ordinance No. 10-1104-96 . Jefferson County Interim Critical Areas Ordinance No. 05-0509-94, as amended by Ordinance No. 14-0626-95 . Jefferson County Subdivision Ordinance No. 04-0526-92, RCW 58.17, and . Jefferson County Shoreline Master Program (1989, as revised through 1998) . Ludlow Water Company (now known as Olympic Water and Sewer, Inc.) System Plan, Jefferson County Coordinated Water System Plan, and W A Department of Health and all other applicable laws, ordinances, rules and regulations . Jefferson County Land Use Procedures Ordinance No. 04-0828-98 . Pope Resources General Sewer Plan, as approved by the Department of Ecology, and all other applicable la,,;,s, ordinances, rules and regulations Section 3.401 of the MPR regulations states the purpose of the RC/CF zone, recognizing the recreational nature of the resort as well as supporting existing residential uses. Sections 3.402 and 3.901 of the MPR regulations identify allowed uses within this zone. Multi-family uses within RC/CF zone are one of the allowed uses. The maximum density is 10 units per acre. To date, because all existing structures except the Pintail House contain three or more dwelling units, in this most intense area of development within the MPR, Jefferson County has identified the structures for all residential development within the Resort Complex zone (excluding the Pintail House) as "multi-family," whether the units were to be soldas "townhomes" or "stacked flats." The residential building setbacks required are those required by the Shoreline Master Program and the Uniform Building Code; no other front, side or rear yard zoning setbacks are identified (see Section 3.30 of the MPR Regulations). The Resort was envisioned to become a destination resort for large conferences. From the MPR regulations and 1999 project graphics, it can be seen that the LBV area was proposed to contain a new amphitheater with parking below, a second, larger hotel and large conference center, museum, parking structure, indoor sports facility, and limited residential development. Section 3.901 of the MPR regulations sets forth the maximum development allowed within the resort area, without approval of a "major revision" to the resort plan. New residential uses were allowed, but undeveloped land was designated for future large resort facilities. Section 3.905 of the MPR regulations states that a change to this Plan shall be processed as either a major or minor revision. Changes that decrease the sizes of facilities are allowed (Section 3.901). Requirement for Plat Alteration The Development Agreement and MPR regulations explicitly acknowledge the existing plat of LBV and the potential conflicts between the plat and the then - anticipated Resort Plan (Alternative 3 of this FSEIS). Section 3.903 requires a Plat Alteration prior to issuance of permits for any new Resort development if the approved Resort Plan does not include all the Port Ludlow Resort Plan Revision Final SEIS 4-9 May 2005 --- Port Ludlow Resort Plan Revision Final SEIS 4-10 May 2005 --- I I I I I I I I I I I I I I I I I I I development rights vested in the plat. Any development rights not included in the approved Resort Plan must be "... withdrawn, vacated or otherwise permanently released" by means of a plat alteration. The need for the plat alteration thus can only be determined after the Resort Plan has been approved. In 1999 - 2000, there was an attempt to resolve the conflicts through adoption of a "Redevelopment Agreement," which required approval of every owner within the plat. Signatures of all owners could not be obtained; however, this led to the decision to apply for a "plat alteration" applicable to properties still owned by PLA (the successor to Pope Resources). The plat alteration is required, however, only if the approved Resort Plan Building over the Artificial Lagoon. The proposed 2003 Resort Plan includes construction of three buildings containing residential units that extend out and over the north and east edge of the artificial lagoon. The question raised as to whether this proposal is consistent with the regulations of the Jefferson County Shoreline Master Program (SMP) pertaining to "over-water construction." This issue has not yet been fully resolved. The DOE states that the residential over-water construction is prohibited by the County SMP. Jefferson County will not challenge this interpretation; however, the applicant disputes this interpretation so the question will be resolved in a formal code interpretation as part of the upcoming permitting process. This Supplemental EIS analyzes impacts of the "worst-case" proposal, so further environmental review would not be required if construction over the water of the artificial lagoon is allowed. Required Permits. PLA is required to obtain several permits from Jefferson County to move forward with the 2003 Resort Plan. The approval process for these permits is specified in County Code and the MPR regulations. Action on these permits will proceed once the Final SEIS is completed. As stated in the Draft SEIS, the required permits include: · Approval of a change to the Resort Plan (agreed to be a "major revision," public hearingis required) · A Shoreline Substantial Development Permit for new development within Ludlow Bay Village . A shoreline substantial development permit for the Marina expansion The above applications are currently pending before Jefferson County and will be processed together. Subsequent applications include: · A boundary line adjustment or alteration to the plat of Ludlow Bay Village · A preliminary and final plat of Admiralty ill (public hearing required, but application not yet filed) · Building permits (administrative approval, following resolution of Resort Plan Revision, Shoreline Permit, and Plat Alteration) · Utility permits (administrative approval, following resolution of Resort Plan Revision, Shoreline Permit, and Plat Alteration) I I I I I I I I I I I I I I I I I I I 4.3.2 Resort Function Comment 4.3.2.1: PLA is not partnering with the community - they are trying to improve their cash flow. Also, the advertising regarding Port Ludlow being a "Planned Communit~" is misleading. Response 4.3.2.1: Port Ludlow is a Master Planned Resort (MPR) being built out over a period of approximately 50 years. The current MPR Regulations were prepared and adopted after a lengthy community and County planning process. These regulations allow the owner to request a revision of the Resort Plan. A public hearing will be required. The decision to grant or deny the application rests with Jefferson County. The County has authority to enforce the regulations but cannot control management of the applicant's business. Comment 4.3.2.2: Changing from individually owned townhomes to condominiums creates a more transient occupancy. Response 4.3.2.2: This portion of the MPR is designated as the Resort. Transient occupancy of some units, whether the units are individually owned townhomes or condominiums, is expected based on the transient occupancy at this resort over the last 40 years. It should be noted that the true distinction here relates to the type of structure, not ownership. Townhome units may be "condominiumized" in the same way as stacked units, or could be rented out under long-term leases or on a short-term, even daily basis. Comment 4.3.2.3: The Beach Club is not a conference facility as stated in the DSEIS. A new private recreation facility would further split the community and make it more difficult to maintain existing facilities. Response 4.3.2.3: It is acknowledged that the Beach Club is not a conference facility. As stated in the Draft SEIS, the Beach Club can, however, be rented for conference use. Your comment regarding a new recreation facility is noted. Comment 4.3.2.4: With this project, the Jefferson County Plan for Port Ludlow will change from a resort to an urban area. Response 4.3.2.4: Your comment is noted. The entirety of the Port Ludlow MPR is currently a designated Master Planned Resort (MPR) by the Jefferson County Comprehensive Plan. Within the MPR, the Resort zone is intended to be that area which is the most intensely developed. Urban residential densities up to 10 units per acre are allowed. Resort facilities such as the Inn at Port Ludlow, the Harbormaster Restaurant, the Marina, shoreline trails, and rental units are concentrated in the Resort zone. The shoreline along the Marina is also designated "Urban" by the Jefferson County Shoreline Master Program. Comment 4.3.2.5: The economic viability of the existing Resort, and/or the proposed Resort as described in the 2003 Resort Plan, is questionable. Response 4.3.2.5: This comment is noted. Port Ludlow Resort Plan Revision Final SEIS 4.11 May 2005 --- Port Ludlow Resort Plan Revision Final SEIS 4.12 May 2005 ~ I I I I I I I I I I I I I I I I I I I Comment 4.3.2.6: PLA's predecessor invested considerable time and money to help create a unanimously supported Comprehensive Plan Designation, Zoning Ordinance and Development Agreement (1999). All involved supported these regulations. Jefferson County has. expended significant taxpayer dollars deliberating Port Ludlow's development. Years of work by both the public and private stakeholders should be honored. PLA has seemingly followed the contractually agreed upon procedures for development of their land. The County should as well. Response 4.3.2.6: Your comment is noted. Comment 4.3.2.7: Reference is made to use of the old conference center as PLA offices. This facility is under lease to Port Ludlow Vacations. There is also the possibility that this facil~ty might be sold. Response 4.3.2.7: Your comment is noted. 4.3.3 Aesthetics Comment 4.3.3.1: Aesthetic impacts, including blockage of views from Oak Bay Road, by a mass of new, high density condominium buildings was not addressed. Response 4.3.3.1: Build-out of Alternative 1 (2003 Resort Plan) will result in new residential buildings within both Ludlow Bay Village (LBV) and the Admiralty area. Within LBV, one new townhome building, a new recreation building and the relocated Harbormaster Restaurant will be constructed along the western shoreline, and new two-story residential buildings will be constructed around the lagoon. Six new residential buildings and one maintenance building will be constructed within Admiralty ill. A new 1,000 square foot central receiving facility will be located in the central portion of the Resort. Build-out of the 2003 Resort Plan will result in the conversion of some existing vacant lots to areas of residential and commercial development. Parcels designated as permanent open space will not be developed with structures. The areas to be converted to residential development include the slope along the east side of Oak Bay Road (between the conference center and Marina View Drive), the slope above the artificial lagoon, and the southwest corner of the shoreline, above the Marina. The elevation along Oak Bay Road varies from 60 to 80 feet. The new commercial buildings along the southwest shoreline will not exceed 35 feet in height; given the approximate base elevation of the buildings will be 10 feet, the elevation difference from Oak Bay Road will be approximately 15 to 35 feet. Views from Oak Bay Road will be altered, but not blocked. Alternatives 2 (1993 Resort Plan), 3 (1999 Resort Plan) and 4 (Response to Comments) also propose further development above the shoreline. Regarding Alternative 3, the existing MPR Regulations state that; I I I I I I. I' I I I I I I I I I I I I "No building or structure shall be erected, enlarged or structurally modified to exceed 35 feet in height, excluding roof projections, as measured by UBC standards, except that Hotels and associated Conference Center facilities may be allowed to a height not exceeding 50 feet as measured by,UBC standards when the Jefferson County Fire District (No.3) finds that fire-fighting and life safety issues are adequately addressed." Comment 4.3.3.2: Existing open, green. areas will be lost and converted to residential development. 'Response 4.3.3.2: Your comment is noted. Certain existing undeveloped areas will be converted to residential and Resort development; no area designated as permanent open space will be converted, however. 4.3.4 Wildlife Habitat Comment 4.3.4.1: Regarding the study methodology for plant and animal habitat, the Draft SEIS relied on old, and out-of-date, information - namely the 1992 surveys conducted by Raedeke Associates that were included in the 1992 Inn at Port Ludlow EIS. Several of the comments stated or suggested that no additional data gathering had been accomplished since 1992. Response 4.3.4.1: The work conducted by Raedeke in 1992 was referenced and summarized in the Draft SEIS because it provided comprehensive and relevant information on both the general region (an approximately 1,200-acre area surrounding the Port Ludlow Resort) and the resort site itself. This information was supplemented by a search for other sources of relevant information on plants and animals within or near the site (such as the current National Wetland Inventory), a site reconnaissance conducted on November 4, 2003, and the acquisition of the most current data on threatened, endangered and sensitive species and habitats from the Washington Department of Fish and Wildlife (WDFW) and the Washington Department of Natural Resources (WDNR). The WDFW is the primary source of information on Priority Habitats and Species (PHS) in the state, and the PHS report provided by WDFW on October 9,2003, represents the most current source of information on bald eagles, great blue heron and other sensitive fish and wildlife within a mile of the site. A current list of threatened, endangered and sensitive plant species maintained under the Washington Natural Heritage Program was obtained in 2003 from WDNR. Other current information (2002-2003) was obtained from personal communications with representatives of WDFW and Wild Olympic Salmon and review of such documents as the Salmon and Steelhead Habitat Limiting Factors report for the Quilcene-Snow Basin (see references in the Draft SEIS). The outcome of this approach was a confirmation that the Raedeke data provided a reliable assessment of the general presence of plants and animals within the Resort site and vicinity, a Port Ludlow Resort Plan Revision Final SEIS 4.13 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS 4-14 May 2005 --- I I I I I I I I I I I I I I I I I I I 2003 update of habitat features on the site, and a current report on the most important habitats and species in the area affected by future project developments. This approach - collecting and reviewing information collected previously, then supplementing that with a site evaluation and compilation and review of current data - is the accepted method for assessing existing conditions in the SEP A process. More specifically, the SEP A Handbook states the purpose of a supplemental EIS is to add information and analysis to supplement the information in a previous EIS (namely, the 1992 Raedeke data). Jefferson County staff use the most updated mapping information available to review habitat reports submitted by applicants. Comment 4.3.4.2: The planned developments will adversely impact the artificial lagoon and the habitat it provides for birds, fish and other aquatic species. One commentor implied that the Draft SEIS stated the lagoon was a "dead body of water," a position the commentor disagreed with. Response 4.3.4.2: Considerable information was presented on the artificial lagoon, including the history of its initial construction in 1967 and its current conditiQns. Contrary to the "dead body of water" comment noted above, the Draft SEIS reported the lagoon was quite productive, exhibiting considerable algae growth at certain times of year. Information from WDFW was presented to show the artificial lagoon may provide some rearing habitat for marine fish, and a variety of birds and mammals were noted to use the lagoon. On the other hand, the artificial lagoon is not a natural feature and provides marginal habitat. Not only does it serve as a retention basin for stormwater from a portion of the Resort site, its exchange with the marine waters of the bay has been altered significantly by a culvert and tide gate, marine water is pumped into the lagoon to maintain its water level, and its shoreline is dominated by riprap and vertical walls with very little riparian vegetation. The extensive algae growth - which is removed periodically by mechanical means - also suggests that the artificial lagoon is receiving a large input of nutrients, possibly from fertilizers used in the drainage basin. So although the artificial lagoon is not dead by any means, it is far from a well functioning ecosystem. The planned project activities in and near the artificial lagoon are likely to cause some temporary increase in turbidity during construction, and during the life of the project there will be an increase in human noise and activity and an increase in shading where townhomes extend over the water. However, such changes are expected to have an insignificant effect on the fish and wildlife populations, which currently use the artificial lagoon. Once the landscaping plan is implemented, habitat values will increase and the impacts to life in and around the artificial lagoon will be beneficial relative to current conditions. An additional report on the history of the artificial lagoon, as well as its water quality, and existing habitat has been prepared by GeoEngineers (2004); this report is included as Appendix I of this Final SEIS. I I I I I I I' I I I I I I I I I I I I Comment 4.3.4.3: Information in the Draft SEIS does not adequately address the proximity of certain threatened, endangered or sensitive (TES) species, and the project impacts on thes~ species. In particular, it was noted that bald eagle have regularly been observed within or near the Resort site (e.g., roosting on the totem pole at Burner Point) and it was suggested by some that a bald eagle nest occurs near the sewage treatment plant immediately north of the resort. Also noted were observations of marbled murrelets within a few yards of the Marina at certain times of year. Some commentors stated or implied that the TES species information presented in the Draft SEIS was 12 years old. Response 4.3.4.3: As stated on page 3-23 of the Draft SEIS, the information on TES species and habitats was obtained primarily from the Washington Department of Fish and Wildlife (WDFW) in October 2003 by accessing their database on Priority Habitats and Species (PHS). Under a "Sensitive Fish and Wildlife Information Release Agreement" executed between WDFW and GeoEngineers, Inc., site-specific information on sensitive habitats and species known to occur within one mile from the Port Ludlow Resort site was provided to GeoEngineers with the understanding that certain types of highly sensitive site locations (e.g., bald eagle nests) cannot be presented in any public document. WDFW provided GeoEngineers with PHS maps showing locations of documented eagle nests and foraging territories, osprey nests, great blue heron colonies, harbor seal haulout and parturition locations, wetlands, listed fish species and other types of species and habitat information. Under the terms of the referenced agreement, the locations of only some of these features can be released whereas others (bald eagle nests) can only be described in general terms, such as general distance and direction from the Resort site. This was the information that was used to present information on TES species in the Draft SEIS (pages 3-23 to 3-26) and to conclude that there were no known eagle nests near the resort or on the west side Port Ludlow Bay nor were there any reported marbled murrelet colonies in the area. As further documentation, GeoEngineerscontacted Michelle Tirhi, WDFW's bald eagle biologist, in August 2004. She confirmed that the information presented in the October 2003 PHS report was still current and that the state was not aware of any eagle nests near the Port Ludlow Resort or anywhere along the west side of Port Ludlow Bay. She encouraged anyone with information on eagle nests to report this information to WDFW; once it is investigated and assuming that location is verified, that information will be entered into the state's PHS database. The PHS database is a catalog of habitats and species considered to be state priorities for conservation and management. Priority species include those listed by the state as endangered (WAC 232-12-014), threatened (WAC 232-12-011) or sensitive (WAC 232-12-011). Also included are animal aggregations considered vulnerable and species of recreational, commercial or tribal importance that are vulnerable. For many of the listed habitats and species, WDFW develops management recommendations that assist landowners, users and managers in conducting land use activities in a manner that incorporates the needs of fish and wildlife. Port Ludlow Resort Plan Revision Final SEIS 4-15 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS 4.16 May 2005 ~ I I I I I I I I I I I I I I I I I I I Washington's bald eagles are protected under a variety of federal and state laws. The main protection for eagle habitat in the state was authorized by the Washington State Legislature in 1984 (RCW 77.12.655: Habitat buffer zones for bald eagles - Rules) and was implemented in 1986 by the adoption of the Bald Eagle Habitat Protection Rule (WAC 232-12-292), Bald eagle management recommendations were developed by WDFW in 2001 and have recently been updated. 4.3.5. Admiralty Undeveloped Areas, Open Space, and Recreational Facilities Comment 4.3.5.1: The proposed Resort Plan Revision will result in the construction of residential buildings in areas that are currently undeveloped. Commentors are concerned about the loss of open space within the Admiralty portion of the Resort, the loss of green spaces, the loss of the existing outdoor playfleld located at the north end of Olympic Place, and the lack of outdoor sport facilities. Response 4.3.5.1: The 9.77 acre parcel to be platted as "AdmiraltyIII" is an undeveloped parcel lying within the designated Resort area. As stated in Section 3.3.2 of the Draft SEIS, the parcel is covered by lawn, a few scattered trees, and a circular grove of red alder trees and dense blackberry bushes about 25 feet in diameter. Local residents use the undeveloped area for recreational activities. If Alternative 3 (1999 Resort Plan) were implemented, this area would remain as permanent open space, in order to compen~ate for the more intense development within the Ludlow Bay Village portion of the Resort (i.e., the amphitheater, large conference center, sports facilities, etc.). With Alternative 1 - the applicant's proposed project, the intensity of development within Ludlow Bay Village has been significantly reduced from that proposed in 1999, and residential development has been proposed for the Admiralty ill parcel. An area at the south end of Admiralty ill, along the north side of Marina View Drive, would be retained as permanent open space. This area would encompass open lawn, a childrens' playground, and an emergency helipad. Within the developed portion of the proposed plat of Admiralty ill, the new residential structures will be surrounded by open landscaped areas similar in character to Admiralty I and II. Visually, the parcel would become part of the developed landscape. Because the natural vegetation has already been removed from this site, the loss of open space will not result in a loss of valuable natural habitat. As stated in Section 3.3.2 of the Draft SEIS, the new development and associated human activity will, however, reduce or eliminate the population of the remaining wildlife. The closest documented eagle nest to the site is located beyond the 400-foot protective zone (or 800-foot buffer zone). Noise and other human activity may cause foraging eagles to avoid the Resort area and immediate surroundings, although the current level of such use is low. Playfield. The existing outdoor playfield located at the north end of Olympic Place is located within the Admiralty ill parcel, and will be removed to allow construction of new residential buildings. A new playfield will be constructed just north of Marina View Drive (see Figure 3A I I I I I I I I I I I I I I I I I I I of this Final SEIS). This playfield will include facilities similar to what is being removed from the existing playfield and will be constructed prior to removal of the existing playfield. Outdoor Sports Facilities. The proposed Resort Plan includes a new recreation building with an indoor/outdoor pool along the shoreline; no additional new outdoor sport facilities (except the new playfieid described above) are proposed. The proposed Resort Plan includes a shoreline-related trail system as shown in Figure 13 of the Draft SEIS. No trail plan is proposed for the Admiralty area. 4.3.6 Transportation Comment 4.3.6.1: Off-Site Concerns. Comments were received regarding impacts to off-site intersections and roadways. Specifically, the comments reflected concerns about the safety of Oak Bay Road and Paradise Bay Road, the intersection of Oak Bay Road/Walker Way, future traffic volume projections, and the need for off-site mitigation. Response 4.3.6.1: Oak Bay Road and Paradise Bay Road. Paradise Bay Road is a minor collector providing a connection between SR-104 just west of the Hood Canal Bridge and Oak Bay Road within the Port Ludlow community. The roadway is two lanes wide and is characterized by fairly gentle horizontal and vertical curvature. The posted speed varies from 30 mph to 50 mph,with a 40 mph speed posted within the Port Ludlow community. The roadway is 22-feet wide with shoulders varying from about 1 foot up to 10 feet. Oak Bay Road is a major collector providing access from Beaver Valley Road to the Oak Bay/Fort Flagler area to the north, traveling through the Port Ludlow community. The roadway is approximately 20 to 22 feet wide with shoulders up to 3-feet wide in certain areas, and open ditches. The posted speed is 40 mph. An all-way stop controls the intersection of Oak Bay Road/Paradise Bay Road. Traffic accident data was provided by Jefferson County for Oak Bay Road and Paradise Bay Road. The following table was shown in the Draft SEIS that summarizes the accident frequency along the roadway sections and at the major intersections for the years 2000, 2001, 2002. Port Ludlow Resort Plan Revision Final SEIS 4.17 May 2005 --- Port Ludlow Resort Plan Revision Final SEIS 4-18 May 2005 --- I I I I I I I I I I I I I I I I I I I Table 3 ACCIDENT HISTORY Accident Type Property LocationIY ear Damaee Iniurv Fatalitv Total Oak Bay Road: at Swansonville Road (MP 8.40) 2000 0 0 0 0 2001 0 0 0 0 2002 0 0 0 0 Between Swansonville Road and Paradise Bay Road (MP 8.40-9.47) 2000 ' 0 0 0 0 2001 1 0 0 1 2002 1 0 0 1 at Paradise Bay Road (MP 9.47) 2000 0 0 0 0 2001 1 0 0 1 2002 0 0 0 0 Between Paradise Bay Road and Beaver Valley Road (MP 9.47-10.80) 2000 0 1 0 1 2001 0 0 0 0 2002 0 0 0 0 Paradise Bay Road: Between Oak Bay Road and Spinnaker Place (MP 0.00-0.45) 2000 0 0 0 0 2001 1 0 0 1 2002 0 0 0 0 Between Spinnaker Place and Ludlow Bay Road (MP 0.45-1.24) 2000 0 1 1 2 2001 0 1 0 1 2002 2 0 0 2 at Ludlow Bay Road (MP 1.24) 2000 0 1 0 1 2001 0 0 0 0 2002 0 0 0 0 at Teal Lake Road (MP 1.52) 2000 0 0 0 0 2001 0 0 0 0 2002 0 0 0 0 As noted in the Draft SEIS, the frequency of accidents in the area is low. The reported fatality involved a driver having a heart attack whose vehicle left the roadway and rolled over. Typically, the County reports accident data only for public roads; no accident data is available for private roads within the Resort. I I I I I I I' I I I I I I I I I I I I Jefferson County completed a traffic safety study of both Oak Bay Road and Paradise Bay Road in the mid-1990s at the request of the Council of Ludlow Owners Association. The report included speed studies, accident analysis, a review of the pavement markings and signs, intersection sight distances, and cQrve studies for both roadways. Based on the analyses completed for the County's report, some minor maintenance work and minor revisions to signs were recommended, along with increased enforcement of the speed zones. Otherwise, no changes in the speed limits or pavement markings were recommended. The more recent collision history further supports prior Jefferson County Staff findings. Based on the more recent accident data, prior review conducted by Jefferson County, current traffic volumes and operating conditions and available capacity, there is no technical basis to indicate that either Oak Bay Road or Paradise Bay Road cannot handle the additional traffic associated with the proposed action. Oak Bay Road/Walker Way Intersection. The analyses completed in the Draft SEIS indicate that the Oak Bay RoadlWalker Way intersection is currently operating at level of service "B." The future (2010) level of service at the intersection upon completion of the Resort (Alternative 1) is projected at level of service "C," which is considered acceptable. (Note: the level of service "C" condition is for the stop controlled approaches; the uncontrolled movements operate at a better level of service.) The future conditions included an increase in traffic volumes through the intersection of approximately 60 percent. Even with this increase in traffic volumes, the intersection would operate at an acceptable level of service. Level of service "C" is generally not considered a congested condition. This level of service is also consistent with Jefferson County long-term forecasts for arterials in the vicinity. The accident history showed no reported collisions at this intersection during the 3-year period reviewed. The lack of any collision history typically indicates that no imminent hazards or unsafe conditions are present. Furthermore, the entering and stopping sight distances for the intersection meet AASHTO guidelines for the posted speed (40 mph) and a design speed of 45 mph. Thus, there is no technical or historical basis to indicate that the intersection of Oak Bay Road! Walker Way will not continue to operate in a reasonably safe condition in the future, with or without the proposed action. Future volume projections. Volume projections for the year 2010 (base condition-without project) were included in the Draft SEIS to account for increases resulting from traffic traveling through the area or traffic associated with miscellaneous new housing. Jefferson County completed extensive analysis to predict traffic growth rates on the arterials within the County as part of their Transportation Plan. These rates were based on historical housing and traffic growth rates and forecast housing growth to produce the estimated traffic growth rates. The County's data showed that the growth rates on those roadways near Port Ludlow that were reviewed in the Draft SEIS ranged from 2.8 percent to 6.09 percent annually. The appropriate annual growth rates were applied to the existing daily and peak hour traffic volumes to estimate the future (2010) volumes in the Draft SEIS. These annual growth rates account for the miscellaneous internal and external traffic growth from new housing, including Port Ludlow Resort Plan Revision Final SEIS 4.19 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS 4.20 May 2005 --- I I I I I I I I I I I I I I I I I I I future homebuilding within North Bay. Based on utility records for the past five years for in-fill housing in the North Bay Area, a conservative estimate of up to 20 new homes per year might be constructed in a busy year. (The mid to late 1990s had much less construction activity.) Thus, the annual growth rates easily account for the portion of North Bay housing construction that could occur through 2010. In addition to these growth factors, traffic associated with pipeline development trips was also added into the existing volumes. The "pipeline trips" consisted of the traffic associated with the remaining housing units designated for construction under the Port Ludlow Master Plan which totals approximately 350 units. This value is not the same as MERU's. The MERU's include both commercial development converted into residential equivalents and residential development. While the use of equivalent residential units may be appropriate for utility projections, it is not necessarily the appropriate multiplying factor for the traffic forecasts. A portion of the trips associated with the 350 residential units remaining to be constructed under the Port Ludlow Master Plan will remain internal to Port Ludlow and consist of trips to and from future new commercial development and therefore simply be the part of the home-to-commercial-to-home trip. Thus, the combination of the use of the annual growth rate, the limi.ted number of in-fill housing units in North Bay per year, the inclusion of the 350 residential units as pipeline traffic, and the percentage of internal trips more than adequately account for increased traffic volumes on the local county roadways and State highways. Off-site mitigation. Jefferson County Department of Public Works Staff has indicated the potential need for mitigation at two off-site intersections in order to mitigate traffic-related impacts associated with development under Alternative 3 (the 1999 Resort Plan). The level of service analyses completed for the Draft SEIS indicate that at least one of the critical movements at the intersections of Oak Bay Road/Walker Way and Beaver Valley Road (SR-19)/Oak Bay Road could drop to level of service "E," If development occurs as proposed under Alternative 3, the project proponent would work with the County to mitigate its development impacts at these intersections. Comment 4.3.6.2: Internal Circulation. Several comments were received with respect to the internal traffic circulation within LBV. Specifically, comments reflected concerns with congestion, increased traffic, blocked streets (especially with respect to emergency vehicles), visibility, parking, and pedestrianlbicycle facilities. Response 4.3.6.2: The net increase in traffic associated with the proposed action was summarized in Table 6 (Section 3.6 - Transportation) of the Draft SEIS. The table showed an estimated weekend trip generation for the proposed action of 887 daily trips and 97 peak hour trips. Approximately 60 percent to 70 percent of this traffic is associated with the new townhomes, with the remaining trips associated with the Marina, PLA offices and the maintenance building. Current two-way weekend peak hour volumes on Marina View Drive total just under 100 vehicles, and the weekend daily volume is just over 1,200 vehicles per day. This magnitude I I I I I I I I I I I I I I I I I I I of volume is generally considered light and can easily be served by a two-lane roadway. Marina View Drive serves as the main access for the resort traffic, and collects and distributes traffic to/from Olympic Place (to Admiralty), and to/from Heron Drive (to the parking areas, the Inn, the Marina, restaurant, and townhomes). As this distribution occurs, traffic volumes become smaller in ~agnitude. Capacity analyses completed for the traffic volumes currently traveling through the intersection of Oak Bay Road/Marina View Drive showed that the intersection is currently operating at level of service (LOS) "B," and is projected to operate at LOS "C," with completion of the Resort (under the proposed action). This LOS projection includes traffic from both the Admiralty and LBV areas and the new/expanded commercial facilities, and is considered acceptable by Jefferson County. No further level of service analyses were performed for the interior intersections within the Resort, since a qualitative review of the volumes present clearly indicates that there are no capacity constraints at the present time, or would there be any constraints in the future. Intersections of interior LBV roads, which carry only a portion of the traffic traveling through the Oak Bay Road/Marina View Drive intersection, will operate better than LOS "C," based on this comparative analysis. As stated in the Draft SEIS, current development within LBV includes the 120-seat Harbormaster Restaurant, the 37 room Inn at Port Ludlow, 25 townhomes, one single-family dwelling, and the 280-slip Marina. The primary area of concern expressed in the comments, is the east leg of Heron Road, i.e. that portion serving the existing townhomes and the Inn. Because the existing road system can function as a loop, vehicular traffic in this area is not necessarily restricted to townhome residents - it may also include guests at the Inn. It does not appear that this section of road is used significantly by patrons of either the Restaurant or Marina, however. The volume of traffic using Heron Road, together with the 24-foot pavement width and existing townhome setbacks, is perceived as a problem by some commentors. The proposed action includes eliminating the existing access from Heron Road to the Inn parking, although access for emergency vehicles will be maintained via two, 20-foot driveways from Heron Road. Closing the access between the Inn and Heron Road will result in a hammerhead turn-around at the south end of Heron Road. This turn-around, coupled with the emergency access, has been reviewed and approved by Fire District No.3. It is also recommended that directional signage to the existing and proposed destinations be installed/enhanced along the internal roadways, 15 mph speed-limit signs be installed, and Heron Drive be signed for local accesslresidents only. Port Ludlow Resort Plan Revision Final SEIS 4-21 May 2005 ... Port Ludlow Resort Plan Revision Final SEIS 4-22 May 2005 ~ I I I I I I I I I I I I I I I I I I I Closing the existing Inn access will result in restricting vehicular use of the east leg of Heron Road to the abutting townhome residents. Thirteen townhome units are situated at the south end of Heron Road, in the vicinity of the Inn, and an additional 28 units are/would be situated along Heron Road, north of the Inn and the artificial lagoon, up to the first (easterly) overflow parking access near the existing Harbormaster Restaurant. The estimated future number of daily trips on this section of the roadway would be approximately 220 daily trips. This amount of traffic is also well below any capacity constraint for a two-lane roadway. Moving the Harbormaster Restaurant to the shoreline area west of Gull Drive and accessing the Inn from Gull Drive will remove additional vehicular traffic from Heron Road. The volume of traffic on Heron Road and Gull Drive is clearly within the capacity of the roadways and the roadways can easily handle the increases associated with the proposed action. Visibility/sight distance. Residents along Heron Road have expressed concerns about the closeness of the townhome garages to the edge of roadway pavement and difficulty in backing from the garages. The closeness of the garages to the roadway has resulted in reduced visibility and "blind spots" when,backing out of their garages onto Heron Road. Heron Road is 24 feet in width (two lO-foot paved driving lanes with 2-foot concrete shoulders). The roadway is generally flat and straight along the section between the Inn and the townhomes, with some gentle horizontal and vertical curvature in the vicinity of the existing Harbormaster Restaurant. Heron Road currently serves the existing townhome traffic, Harbormaster Restaurant, some of the Inn traffic and miscellaneous service vehicles. The cross section of the roadway most closely resembles the Jefferson County typical road section for an 18-foot roadway (35 mph - under 400 ADT, 2-foot paved shoulders) standard for public roads, with the exception that the design speed used for Heron Road was 20 mph. The lower design speed was used, and deemed appropriate, since Heron Road is a local access road, and low speeds were desirable through this area. Vehicles can currently travel along Heron Road, through the Inn parking lot, and back onto Heron Road to "loop" through this area. No speed limit is currently posted along the roadway, or is parking allowed along the roadway, although some graveled areas are available out of the roadway cross section that can be used for parking. The garages of the townhomes along this section of Heron Road are setback 32 to 36 inches or more from the edge of the concrete shoulders, with an additional 2 feet of pavement to the edge of the travel lane. The closeness of the garage structure to the roadway, combined with the location of the driver's eye and line of sight when backing from garages, does have inherent limi tati ons. Heron Road was designed for a 20-mph speed, and stopping sight distances along the roadway meet this standard along all sections and exceed the design speed standard along many sections, especially the flat, straight sections along the Inn. The required stopping sight distance for a 20 mph design speed is 115 feet. Stopping sight distance is considered an important element in I I I I I I I I I I I I I I I I I I I the roadway design, since it allows an approaching motorist to react to an object in the roadway and stop the vehicle prior to reaching the object (in this case an emerging vehicle from a garage). Although the traffic volumes along Heron Road are extremely low, thereis always the potential for a conflict between a backing vehicle and an on-coming vehicle. The available stopping sight distance does, however, allow an on-coming driver to react and stop for an emerging vehicle on those occasions when these events occur. Heron Road, in many ways, functions similarly to the alleys found in the older neighborhoods of Seattle or in the newly developed neo-traditional residential areas in cities such as DuPont in Pierce County. These residential areas have alley access to the garages and have little, if any, setback from the edge of pavement. Residents using the alleys travel at low speeds, are aware of the closeness of the garages and potential for conflicts, and adjust their driving behavior accordingly. New development standards in cities that promote neo-traditional design encourage alley access to garages. Typical setbacks for garages accessing directly from alleys range from .3 to 5 feet or require the garage to be set back a particular distance (12 feet is common) from the alley centerline. Other development codes have a zero setback but require a minimum alley width of between 24 and 26 feet. Revisions to the internal site circulation/access associated with the proposed action (i.e., eliminating the existing access from Heron Road to the Inn parking and relocation of the Harbormaster Restaurant) will result in restricting vehicular use of the east leg of Heron Road to the abutting townhome residents. To further enhance local access operations (i.e., encourage low speeds and provide motorist guidance) within the Resort, it is recommended that directional signage to the existing and proposed destinations be installed/enhanced along the internal roadways, 15-mph speed limit signs be installed, and Heron Drive be signed for local access/residents only. Those residents who find backing out the townhomes' garages to be difficult may want to consider backing into the garages so that their exiting maneuver will be less cumbersome and provide visibility of the roadway sooner as they exit the garage. Parking. The existing townhomes include a one-stall garage accessed from Heron Road. Parking is not allowed along the roadway, although some graveled areas are available out of the roadway cross section that can be used for parking. The new townhome units will include two off-street spaces per unit, which may be in tandem. Within the Resort, parking of multiple vehicles by visitors or residents is not encouraged and is restricted to the overflow lots. Overflow parking for all townhome units will be provided only in the community lots along the north side of Heron Road. No parking will be allowed on Heron Road or Gull Drive to eliminate blockages for the residents, visitors, and emergency vehicles. This restriction will be enforced by the Fire District. The Fire District has recently provided applicable signs for posting along Heron Road. Closing the access between the Inn and Heron Road will also eliminate the use of Inn parking by townhome residents. Furthermore, the graveled areas currently available for townhome guest parking will be eliminated with the new construction. Port Ludlow Resort Plan Revision Final SEIS 4-23 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS 4.24 May 2005 ~ I I I I I I I I I I I I I I I I I I I Potential townhome purchasers will need to evaluate parking availability as part of their decision to purchase a unit within the Resort, versus within a single-family residential portion of the MPR. Additional information with respect to parking supply for the commercial areas can be found in Section 3.4 and Appendix J of this Final SEIS. Pedestrian/bicycle facilities. The proposed action will likely generate additional non-motorized activity along the adjacent roadways that could potentially conflict with vehicular traffic. A designated trail has been shown on the site plan to serve residents of the resort and is a portion of .the pathway system in Port Ludlow. Specifically, the portion of the trail system constructed under the proposed action includes an 8-foot wide boardwalk along the shoreline extending from the new recreational facility to the Inn. The boardwalk is just a portion of the comprehensive community-wide trail system within Port Ludlow that has been constructed and maintained as a joint effort between the Port Ludlow Village Council and the developer. The trail system is intended to serve recreational uses, and provide a network between the residential areas and activity nodes, such as the recreation center, Marina, and commercil;ll complex. Walking and cycling amenities within the Resort (and Port Ludlow in general) have typically been provided through the trail system or along the adjacent roadways. The low volume and speeds of vehicular traffic on the roadways, combined with the existing available trails and future boardwalk facility in the Resort area, are sufficient to handle the non-motorized needs. Comment 4.3.6.3: Extensive commentary was submitted with respect to Heron Drive, its adequacy, and its ability to serve the proposed action. Response 4.3.6.3: Altered and increased traffic patterns. Visitor parking currently exists at the north end of Heron Road as well as along Harbor Drive and Gull Drive. Any of these areas can currently be used by visitors to the Marina or shoreline/trails. The projected future volume of traffic along Heron Road at the easterly parking lot is projected to be approximately 220 vehicles per day, including the new townhomes that would be constructed between the Inn and the noted parking lot. Any increase in pedestrian or bicycle activity over the current conditions can be accommodated easily by the combination of multiple routes to access the Marina or shoreline/trails from the various parking areas, the availability of the existing footbridge across the lagoon, the construction of the future boardwalk, and the limited volume of traffic (especially along Heron Road). Sight distance, inter-visibility between users and modes. Heron Road is 24 feet in width (two lO-foot paved driving lanes with 2-foot concrete shoulders). The roadway is generally flat and straight along the section between the Inn and the townhomes, with some gentle horizontal and vertical curvature in the vicinity of the existing Harbormaster Restaurant. The cross section of the roadway most closely resembles the Jefferson County typical road section for an 18-foot I I I I I I. I' I I I I I I I I I I I I roadway (35 mph - under 400 ADT, 2-foot paved shoulders) standard for public roads, with the exception that the design speed used for Heron Road was 20 mph. The lower design speed was used and deemed appropriate, because Heron Road is a local access road and low speeds are desirable through this area. The garages of the townhomes along this section of Heron Road are set back 32 to 36 inches from the edge of the pavement, with an additional 2 feet of pavement to the edge of the travel lane. Heron Road was designed for a 20-mph speed, and stopping sight distances along the roadway meet this standard along all sections and exceed the design speed standard along many sections, especially the flat, straight sections along the Inn. The required stopping sight distance for a 20 mph design speed is 115 feet. Stopping sight distance is the more critical of the sight distance requirements along local accesses (rather than entering sight distance), since it allows an approaching motorist to react to an object in the roadway and stop the vehicle prior to reaching the object (in this case an emerging vehicle from a garage). Although the traffic volumes along Heron Road are extremely low, there is always the potential for a conflict between a backing vehicle and an on-coming vehicle. The available stopping sight distance does, however, allow an on-coming driver to react and stop for an emerging vehicle on those occasions when these events occur. Furthermore, agencies such as King County do not have entering sight distance requirements for local access roadways (Section 2.03 of the King County Road Standards), and the City of Bellevue would not consider the intersection of a residential driveway with a private roadway to fall under its provisions for intersection sight obstructions (section 14.60.240 of the Bellevue City and Land Use Code, Title 14-Transportation Code). Heron Road, in many ways, functions similarly to the alleys found in the older neighborhoods of Seattle or in the newly developed neo-traditional residential areas in cities such as DuPont in Pierce County. These residential areas have alley access to the garages and have little if any setback from the edge of pavement. Residents using the alleys travel at low speeds, are aware of the closeness of the garages and potential for conflicts, and adjust their driving behavior accordingly. With respect to the "dart-out" problem noted, this condition can occur along any roadway, and the construction of a wider roadway would not eliminate this condition or provide a safer condition. A wider roadway, especially one where parking is allowed, tends to encourage higher speeds and the presence of parked vehicles result in an visual obstacle where children cannot be observed until they step out into the traveled way. Use of Heron Drive by multiple modes of travel. The proposed action will likely generate additional non-motorized activity along the adjacent roadways that could potentially conflict with vehicular traffic. A designated trail has been shown on the site plan to serve residents of the resort and is a portion of the pathway system in Port Ludlow. Specifically, the portion of the trail system constructed under the proposed action includes the addition of an 8-foot wide boardwalk along the shoreline extending from the new recreational facility to the Inn. Heron Road is not designated as a bicycle "route," and AASHTO specifically notes that the "local Port Ludlow Resort Plan Revision Final SEIS 4.25 May 2005 --- Port Ludlow Resort Plan Revision Final SEIS 4.26 May 2005 --- I I I I I I I I I I I I I I I I I I I roadway may be sufficient to accommodate bicycle traffic." Typically, bicycle facilities are not provided along local access roadways. The boardwalk is just a portion of the comprehensive community-wide trail system within Port Ludlow that has been constructed and maintained as a joint effort between the Port Ludlow Village Council and the developer. The trail system is intended to serve recreational uses, and provide a network between the residential areas and activity nodes, such as the recreation center, Marina, and commercial complex. Walking and cycling amenities within the Resort (and Port Ludlow in general) have typically been provided through the trail system or along the adjacent roadways. Port Ludlow is not considered or designated as an urban area. As such, facilities such as sidewalk construction or bike lanes are not required as part of the roadway construction, or are they required as part of the roadway standard for non-urban facilities. The low volume and speeds of vehicular traffic on the roadways, combined with the existing available trails and future boardwalk facility in the Resort area, are sufficient to handle the non-motorized needs. Miscellaneous considerations. The proposed project includes eliminating the existing access from Heron Road to the Inn parking, although access for emergency vehicles will be maintained via two 20-foot driveways from Heron Road. Closing the access between the Inn and Heron Road will result in a hammerhead turn around at the south end of Heron Road. This turnaround, coupled with the emergency access, has been reviewed and approved by Fire District No.3. Furthermore, the existing width of both Heron Road and Gull Drive are sufficiently wide to accommodate both fire and sheriff access. County road standards. As noted, the County Road Standards clearly state that roads in designated urban areas may require pedestrian improvements, including wider shoulders and sidewalks. This is not a mandatory requirement and would likely be at the discretion of the County Engineer, based on potential public need and the availability of other facilities, such as a trail system. As noted previously, Heron Road is not designated as a bicycle "route," and AASHTO specifically notes that the "local roadway may be sufficient to accommodate bicycle traffi c. " Requirements for multiple use. As previously noted, Heron Road is not designated as a bicycle "route," and AASHTO specifically notes that the "local roadway may be sufficient to accommodate bicycle traffic." AASHTO merely notes that "where special facilities for bicycles are desired, they should be designed with the AASHTO Guide for the Development of Bicycle Facilities." There is no AASHTO requirement that non-motorized facilities be provided on local access roadways, and bicycle facilities are typically not provided along local access roadways. Heron Road is not an arterial or highway, public right-of-way, or part of the County's non-motorized plan. Bicycle safety use. None of the AASTHO or RCW citations (with the exception of noting that the roads in Ludlow Bay Village would be shared roadways) necessarily apply, or were intended I I I I I I I I I I I I I I I I I I I to apply, to local access, private roadways such as those in Ludlow Bay Village, and are more applicable to the highway/arterial system. Providing bicycle-safe drainage grates, adjusting manhole covers to grade, and maintaining a smooth, clean riding surface are all reasonable measures along local access roadways, however, further widening and/or separate bicycle facilities are not reasonable for a local access roadway. Clear zone standards. The clear zone distance cited is not a requirement per AASHTO, but rather a distance that should be provided. The building setbacks along Heron Road were established per the Uniform Building Code (now the International Building Code), as adopted by Jefferson County. The design speed for Heron Road was 20 mph with an intended posted speed of 15 mph. These lower than typical speeds further limit the need for the 7- to lO-foot clearance noted. Sidewalks. The sidewalk standards noted are typical urban improvements. Heron Road is 24-feet in width consisting of two lO-foot paved driving lanes with 2-foot concrete shoulders. The concrete "strip" noted by the technical reviewer has never been designated as a sidewalk by the County, the designers, or the owners. The technical reviewer has concluded that since the concrete strip is not a sidewalk (per the criteria noted), it cannot accommodate pedestrians; and, therefore, pedestrians are forced into the travel lanes. No physical constraint was identified by the reviewer, however, that would "force" a pedestrian into the travel lane rather than walking within the concrete shoulder area. While the density of Ludlow Bay Village has the appearance of an urban area, AASHTO states that for traffic engineering purposes "urban areas are those places within boundaries set by the responsible State and local officials having a populations of 5,000 or more." Urban areas are further divided per AASHTO into areas with population of 50,000 or more andsmall urban areas with populations between 5,000 and 50,000. Rural areas are the areas outside the urban area boundaries. As such, urban and rural functional systems are classified separately. Ludlow Bay Village is not within an AASHTO urban boundary, and Heron Road is not designated as an AASHTO urban street. Thus, applying the AASHTO urban standard and the requirements for sidewalks is not applicable. Bicycle accommodation. Heron Road is 24 feet in width consisting of two lO-foot paved driving lanes with 2-foot concrete shoulders. (Note: the 2-foot concrete shoulder has yet to be constructed along some sections of roadway but will be constructed in the future. Until such time, this 2-foot section is paved.) The bicycle lane and bicycle path criteria noted may be appropriate if Heron Road is part of a designated County plan, but it isn't. Again, AASHTO specifically notes that the "local roadway may be sufficient to accommodate bicycle traffic." Handicap accommodation. No known impediments to the disabled currently exist along Heron Road. All new paths and the proposed boardwalk associated with the proposed project will be accessible. All new residential units will also be consistent with ADA requirements. Possible solutions. The additional impacts associated with the proposed action do not necessitate any further widening of Heron Road or additional non-motorized facilities other than those proposed. Revisions to the internal site circulation/access associated with Alternative 1 Port Ludlow Resort Plan Revision Final SEIS 4-27 May 2005 --- Port Ludlow Resort Plan Revision Final SEIS 4.28 May 2005 ~ I I I I I I I I I I I I I I I I I I I (i.e., eliminating the existing access from Heron Road to the Inn parking and relocation of the Harbormaster Restaurant) will result in restricting vehicular use of the east leg of Heron Road to the abutting townhome residents. This action will mitigate many of the concerns associated with additional traffic, since the Harbormaster Restaurant and the Inn will be served from Gull Drive rather than Heron Drive. Because the volume of traffic on Heron Road and Gull Drive is within the capacity of the roadways and traffic on the east leg of Heron Road will be reduced, no street improvements are warranted. The low volume and speeds of vehicular traffic on the roadways, combined with the existing available trails and future boardwalk facility in the Resort area, are sufficient to handle the non-motorized needs. To further enhance local access operations (i.e., encourage low speeds and provide motorist guidance) within the Resort, it is recommended that directional signage to the existing and proposed destinations be installed/enhanced along the internal roadways, 15 mph speed limit signs be installed, and Heron Drive be signed for local access/residents only. Comment 4.3.6.4: The Transportation assessment in Section 3.6 is substantially in error and should be corrected. Actual impact is more than double the stated figure. Response 4.3.6.4: As stated in Section 3.6 of the Draft SEIS, trip generation rates used in the traffic analysis are estimated using the most recent values in the ITE Trip Generation Manual (6th Edition, 1997). This is the standard reference used for traffic studies throughout the state of Washington and in Jefferson County. 4.3.7 Public Access to the Shoreline Comment 4.3.7.1: The proposed Resort Plan wiJI restrict existing access to the shoreline; the shoreline is now open to all. Response 4.3.7.1: The shoreline areas that are privately owned building lots (within the areas subject to development under all alternatives) are not now open to all. All development alternatives will change the shoreline in an approximate 400-foot area west of Gull Drive and the existing Marina store. This area now provides open, unimproved access to the shoreline above the Marina. With Alternatives 1 and 4, this area would be occupied by two townhome buildings, the relocated restaurant, and the new recreation facility. With Alternative 2, the area would be occupied by seven single-family dwellings. With Alternative 3, the area would be occupied by a retail/restaurant building and open space. Alternatives 1,3, and 4 include construction of a new 8-foot wide wooden boardwalk along the shoreline above the Marina; the boardwalk will extend from the new Harbormaster Restaurant easterly to the existing Inn. The boardwalk is intended to improve pedestrian access along this portion of the shoreline; this area now serves as a grass shoulder for Gull Drive. Easterly of the I I I I I I I' I I I I I I I I I I I I Inn, there will be no change to existing shoreline access - the existing trails and open space at the end of Burner Point will remain as will the existing beach trail. With all development alternatives, existing visual access to the shoreline from portions of Heron Road will be limited due to the construction of the new townhomes, restaurant, and recreational buildings. Shoreline access at Burner Point and along the beach would remain the same for all alternatives, available to the general public and signed accordingly. Comment 4.3.7.2: As density increases, public access wiJI need to be defined to mark private vs. public areas. Response 4.3.7.2: A designated, signed trail system will be developed within LBV to provide for better pedestrian circulation and shoreline access. The proposed Trail system is shown in Figure 13 of the Draft EIS. Per State law, the beach is open to public access below Ordinary High Water (OHW). Comment 4.3.7.3: Any additional use of the shoreline in front of the townhomes would be detrimental to a fragile ecosystem. Response 4.3.7.3: As stated in Section 3.3.2 of the Draft SEIS (Plants and Animals, Operational Impacts), increased residential and Resort use will result in increased human use of the east- facing beach, primarily as beach combing and related low-intensity use. If this activity were to occur when surf smelt or sand lance eggs are present in the beach substrate, some eggs could be crushed; and the reproductive success rate of these fish populations could be reduced. The effect is expected to be small, however, in terms of the percentage of eggs lost and the impact on local populations of these species. Port Ludlow Resort Plan Revision Final SEIS 4-29 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS 4-30 May 2005 ~ I I I I I I I I I I I I I I I I I I I 4.3.8 Marina Expansion Comment 4.3.8.1: Westward expansion of the Marina will result in view obstruction, increased noise, and water quality degradation. The 120-foot fairway distance is not a sufficient corridor for access to the primary waterway. The need for the expansion and what recreational values the expansion would afford the community are questionable. Marina growth should be limited to a level commensurate with active boat usage. Response 4.3.8.1: The view, noise, and water quality degradation issues associated with the Marina expansion are addressed in detail in the 2002 Port Ludlow Marina Expansion Supplemental Environmental Impact Statement (see Chapters 3.6 AestheticsNisual Quality, 3.4 Land Use, and 3.2 Water, respectively). As noted in this EIS, the 120-foot fairway distance is an industry standard and is applicable to the conditions and number of boats using this waterway. The closest distance between the Scott Court dock and any proposed dock at the Marina would be 171 feet (see "Response to Comments Alternative/Figure 7, Port Ludlow Marina Expansion Final SEIS). . Limiting the Marina to active boat usage would likely not be consistent with desires of the community. An area for dry boat storage would likely be required. Currently, there is no provision for upland storage or for a lift system to move boats in and out of the water. Locating a storage area and lift system adjacent to the shoreline would not be consistent with the proposed Resort Plan. Comment 4.3.8.2: Windblown dust and sawdust from the construction work will spread over the Marina, damaging the boats. The construction period will extend over a several year period. Control of the dust should be required. Response 4.3.8.2: Windblown dust can be substantially controlled by watering the site as needed. With winds from the north, some construction dust may, however, pass over the Marina. With the exception of construction of the new restaurant and recreation building, the majority of construction activities will occur above the Marina, away from the shoreline. Comment 4.3.8.3: Earlier comments on the Marina expansion, as well as comments from the State Department of Fish and Wildlife (WDFW) recommending only two alternatives - No Action or Deep Water Expansion, have been ignored. Response 4.3.8.3: All previous comments and the WDFW comments regarding the Marina expansion are contained in the 2002 Port Ludlow Marina Expansion Final Supplemental Environmental Impact Statement. Jefferson County has not yet made a decision on the design of the Marina expansion. That decision will come through the upcoming Shoreline Permit process. Comment 4.3.8.4: There is no record that the drawing for the "Alternative - 1993 Marina Design" was ever circulated. Response 4.3.8.4: Your comment is noted. I I I I I I I' I I I I I I I I I I I I Comment 4.3.8.5: The Marina EIS process was in violation of the MPR Ordinances. Also, it does not include statements from the other agencies listed under Required Permits and Approvals - DNR is an example. Response 4.3.8.S: Your comment regarding process is noted. Please refer to your July 25,2002 letter, Response 5, in the 2002 Port Ludlow Marina Expansion Final Supplemental Environmental Impact Statement. In summary, Jefferson County determined that a separate review of the Marina Expansion was allowed but with the clear understanding that no land use permits or building permits were to be issued for the Marina project until a Resort SEIS was completed that identified cumulative impacts from both the upland and Marina projects. This SEIS addresses those cumulative impacts. Regarding comments from other agencies, the Draft SEIS was sent to all agencies with jurisdiction over the proposal; they are, however, not required to comment. Comment 4.3.8.6: I respectfully request to be included as a stake holder in all meetings and discussions in this Resort SEIS study. I request to be advised of all appeal procedures and date requirements of the County and State and other authority to stop the westward Marina expansion. Response 4.3.8.6: Your request is noted. Comment 4.3.8.7: Fire District No.3 has identified six proposed mitigation measures to be included as part of the proposed project. Also, the future of the existing fire pumps should be explained, and if to be retained, who will be responsible for maintenance and testing? Response 4.3.8.7: The applicant has agreed to the six mitigating measures. Regarding the fire pumps, the existing pumps are maintained by Port Ludlow Associates. Testing is the responsibility of the Fire District. Expansion of the Marina as proposed would result in removal of the existing fire pumps. Comment 4.3.8.8: We are excited about the proposed Marina expansion. Response 4.3.8.8: Your comment is noted. 4.3.9 Utilities Comment 4.3.9.1: Regarding water rights, the information stated in the Draft SEIS regarding the North Aquifer has no supporting documentation. Clearcutting of land overlying the aquifer is a serious concern. Port Ludlow Resort Plan Revision Final SEIS 4.31 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS 4.32 May 2005 --- I I I I I I I I I I I I I I I I I I I Response 4.3.9.1: Groundwater resources were evaluated in 19871, 19892 and again in 19923 by Robinson & Noble based on available information. In addition to these studies, Robinson & Noble's 1992 report, entitled South Aquifer Study Port Ludlow/Shine Area, contains detailed analyses of the aquifer hydrogeology, water balance, and recharge in the area. This study was based on available published reports and unpublished information, including Washington Department of Ecology (Ecology) water well reports and water right information and Olympic Water and Sewer, Inc. (OWSI) groundwater levels and usage data. Also, annual reports are produced for OWSI analyzing the water level and water usage trends for an extensive groundwater monitoring program that includes 17 wells.4 The information presented in the Draft SEIS has supporting documentation. Information regarding ongoing or future clearcutting could be relevant to impacts. The purpose of this section of the SEIS is not to assess water-related impacts associated with other developments in the resort's water-supply watershed. However, to the extent another major planned development could affect the ability of the North Aquifer to meet the resort's water supply needs, such developments are relevant to this impact assessment. Clearcutting and site development of land overlying the North Aquifer could have two types of impacts on the subsurface water supply; land conversion that signifjcantly and adversely alters the aquifer characteristics or direct consumption of water after build-out leading to future aquifer drawdown. The evidence relative to the former is inconclusive in general. That is, clearcuts can affect groundwater recharge negatively (by reducing the holding capacity of the soils and by increasing runoff) or positively (by decreasing evapotranspiration, eliminating interception of rainfall by the forest canopy and allowing for direct infiltration into the ground). There is no site specific information to suggest that the clearcutting and site development activities noted in the comment will have a significant effect in either direction relative to the overall recharge amount or consumption. Regarding the second type of potential impact, OWSI is in the best position to determine whether its aquifers have the capacity to serve future users. OWSI maintains an extensive groundwater monitoring network in the Port Ludlow area that allows for the evaluation of trends in groundwater levels, precipitation, water quality, and seawater intrusion. There has been no evidence so far of a loss of sustainability of the groundwater supply. Regarding 3.2.2.3 Mitigation Measures, Mr. Lawson makes the same comment implying a lack of support documentation. Please see our response in the preceding paragraph. Regarding 3.2.2.4 Unavoidable Adverse Impacts, OWSI has certified water rights allocated by Ecology. This allows for the beneficial use of groundwater by OWSI. I Robinson & Noble, Inc. 1987. Evaluation of ground water resources potential, Port Ludlow. 2 Robinson & Noble, Inc. 1989. Water resource evaluation for Ludlow Utilities and construction of Well 14. 3 Robinson & Noble, Inc. 1992a. Evaluation of the impact of planned future development on Port Ludlow ground water resources. 4 Robinson & Noble, Inc. 2003. 2002 Annual Report on the Port Ludlow Area Ground Water Monitoring Program for Port Ludlow Associates, LLC, February 2003. I I I I I I I I I I I I I I I I I I I Comment 4.3.9.2: OWSI has no current water rights based on an inquiry directed to the Department of Ecology. The water rights are "claimed but not validated." Response 4.3.9.2: While no current rights are under the name of Olympic Water and Sewer (OWSI), the water rights that OWSI controls are under the name of the previous water purveyors: Pope Resources and/or Port Ludlow Water. Water rights are fully transferable. It is not necessary to transfer the water right ownership name for each transfer or change of water system name. Water rights remain with the point of withdrawal and the place of use. According to these valid certified groundwater rights, OWSI allocation is 465 acre-feet of groundwater rights. The total water allocated and total sustainable usage in the region is addressed in the basin assessment of Water Resource Inventory Area (WRIA) 17 conducted for the Department of Ecology. The Jefferson County Department of Health was the lead agency for the Quilcene-Snow watershed study that contains an evaluation of water rights, water usage, and aquifer sustainability in the area5. Comment 4.3.9.3: The County should be responsible to the public to assure a continued supply of healthy drinking water. Response 4.3.9.3: The state of Washington Department of Ecology is responsible for the allocation and quality of the water resources. The state and county Departments of Health are responsible for drinking water issues. Also, it is in the best interest of OWSI to maintain and monitor a sustainable and safe drinking water source. Comment 4.3.9.4: The long term impact to the sewer, water and drainage systems should be addressed. Response 4.3.9.4: Your comment is noted. Sections 3.7.2, 3.7.3, and 3.2 of the Draft SEIS address the impacts to the sewer, water, and drainage systems. Comment 4.3.9.5: PLA should be required to demonstrate that they have sufficient water and sewer hook ups to serve the existing lots in North Bay and not stress the utilities presently in place. They should also demonstrate they are expanding those utilities without charging extra fees to present owners to cover costs of expansion. Response 4.3.9.5: Hookups to the water and sewer systems are monitored by the Olympic Water and Sewer Inc. As stated in the Draft SEIS, the water and sewer systems were designed to accommodate build out of the MPR. There is no plan to charge current property owners for installation of systems to serve new development; infrastructure associated with new development is provided by the developer. Comment 4.3.9.6: If developers wish to build and develop the area around the Marina they should be responsible, at their expanse, for the entire infrastructure, which would include expansion of the sewage treatment plant. 5 Parametrix, Pacific Groundwater Group, Montgomery Water Group, and Caldwell and Associates. 2000. Stage 1 Technical Assessment as of February 2000, Water Resource Inventory Area 17. Port Ludlow Resort Plan Revision Final SEIS 4-33 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS 4-34 May 2005 --- I I I I I I I I I I I I I I I I I I I Response 4.3.9.6: As stated in Section 3.7.3.2 of the Draft SEIS, the sewage treatment plant has adequate capacity available to accommodate the proposed development. Comment 4.3.9.7: Low Impact Development techniques should be utilized in order to mitigate stormwater runoff from the additional impervious surfaces and to protect the marine habitat. Response 4.3.9.7: Your comment is noted. All new development must be consistent with applicable County drainage regulations. 4.3.10 Environmental Review Comment 4.3.10.1: Environmental Review Requirements Several comments address issues related to the apparent lack of current information used to undertake the current EIS analysis, reliance on previous EIS analyses, and the adequacy of the level of detail provided in the current Draft SEIS document. Following is a clarification of the environmental review process associated with the proposed revision to the Resort Plan. Response 4.3.10.1: As stated on pages 1-5 and 1-6 of the Draft SEIS, Jefferson County is using phased review, as authorized by SEPA (W AC197-11-060(5)(b)) and Section 3.902 of Ordinance No. 08-1004-99 in its review of development projects within PortLudlow. Specifically, the current EIS supplements, and incorporates by reference, two EIS's prepared in 1993-one at a programmatic level to analyze the impacts of the overall Port Ludlow MPR Development Plan (EIS for the Port Ludlow Development Program - Jefferson County, 1993) and one at a project- level to more specifically address development within Ludlow Bay Village (EIS for the Inn at Port Ludlow - Jefferson County, 1993). The current EIS also supplements, and incorporates by reference, the more recent project-level SEIS prepared to address the 100-slip expansion of the Marina - the 2002 Port Ludlow Marina Expansion EIS. In the 1993 programmatic EIS, the overall Port Ludlow Development Plan identified the Resort area as "Development Areas" 48 and 50. Development Area 48, the 18-acre area which later became LBV, was proposed to include 72 new residential units, along with new retail space, a 36-room Inn, expansion of the Marina by 100 slips, development of recreational trails, permanent open space, and supporting infrastructure including roads and utilities. Development Area 50, the area to be known as Admiralty ill, was proposed to contain 50 new residential units. These units were in addition to the 64 units already constructed in Admiralty I and II. The second project-level EIS prepared in 1993 addressed the specific development proposal within what was to become LBV. Specifically, the proposed development included construction of a 36-room Inn, 72 residential units (23 single-family, 49 multi-family), 2,500 square feet of commercial space, renovated Marina support facilities, expansion of the existing manmade pond, parking, landscaping, shoreline public access, installation of riprap, and replacement of underground fuel tanks with above-ground tanks. I I I I I I I' I I I I I I I I I I I I These two EIS' s provide the basis from which the current Supplemental EIS has been prepared. Currency of Information. For the current analysis, the 1993 and 2002 information was collected and reviewed then supplemented with site evaluations and compilation andreview of current data. Th1S is the accepted method of assessing existing conditions in the SEP A process and was applied to each area of technical expertise (i.e., transportation, wildlife habitat, etc.). More details regarding sources of technical information are provided in Response 4.3.4.1. The scope of the Supplemental EIS was developed pursuant to Section 3.904-Environmental Review for Resort Plan Development and a public scoping process, including a public scoping meeting held on July 16, 2003. Level of Detail. The level of detail contained in an EIS should be commensurate with the level of detail in the application being reviewed and the alternatives being evaluated. In this case, the application is for a revision to the Resort Plan, shoreline permits, and plat alteration. Within the Supplemental EIS, different land uses mixes and densities for the Resort are evaluated and compared to one another in order to compare potential significant impacts. What is deemed "significant" for SEP A purposes and what an individual resident sees as "significant" may vary. For example, within a SEP A traffic analysis, the focus is on identification of the number of new. vehicular trips generated by the proposal, on the impacts to the measured level of service on adjacent roadways, the operational safety of intersections, adequacy of parking facilities, impacts to transit, etc. These typical traffic impacts were described in Section 3.6 of the Draft SEIS. The same level of analysis was not applied to the interior, private roadways within the Resort, but is now included. SEP A does not typically involve analysis at the individual parcel level, especially when the proposed project is one element of a larger development approval. Issues related to public health, safety, and welfare at the parcel level are addressed by locally adopted ordinances and standards. It is assumed that the adopted development regulations adequately address impacts for those projects thatfall under the regulations (RCW43.21C.240). If, however, a project proposal results in an incremental increase in anticipated impacts, the jurisdiction can then analyze whether the additional impacts still fall within accepted standards. For example, within the plat of Ludlow Bay Village, Heron Road was constructed to standards approved by Jefferson County as part of the platting process. Building setbacks along this road have also been established by the County. These standards are not proposed for change. The County will then review the proposed Resort Plan Revision to determine if additional vehicular traffic is proposed on Heron Road; and if so, if the additional traffic can be safely accommodated. In order to provide more detailed information regarding potential project impacts as part of this Final SEIS, further information and analysis has been provided in certain technical areas in order to respond to issues raised. The additional information and technical analyses are presented within Chapters 3 and 4. Port Ludlow Resort Plan Revision Final SEIS 4.35 May 2005 IDJmeI Port Ludlow Resort Plan Revision Final SEIS 4-36 May 2005 --- I I I I I I I I I I I I I I I I I I I Monitoring Reports. In addition to the required SEPA review, Jefferson County requires preparation of a series of annual monitoring reports that contain data on specific aspects of both the built and natural environments. Information from these monitoring reports is incorporated into the current SEIS. Further information on the content of the monitoring reports is presented in Response 4.3.1.1. Comment 4.3.10.2: No detailed site plans, architectural drawings, elevations, cross sections or floor plans are available for review. Response 4.3.10.2: Figure 3B of the Draft SEIS is a site plan (to scale) for the applicant's proposed Ludlow Bay Village development. Architectural drawings, elevations, cross sections and typical floor plans are shown in the DSEIS in Figures 12A and 12B and Figures 7 A, 7B, and 7C. Typical floor plans for the condominium units are included in this Final SEIS. A new site plan and typical floor plans are also been included in this FSEIS to illustrate the new Alternative 4 - Response to Comments (see Figures 6A, B, C and 15A, B). This level of detail is consistent with the requirements of Section 3.904 of the MPR Regulations. Comment 4.3.10.3: The Draft SEIS is limited to input from the developer. There is no input from the Fire Department, Fish and Wildlife, or any of the Port Luqlow Home Owners' Associations. Response 4.3.10.3: The intent of a Draft SEIS is to prepare and circulate a draft document to governmental agencies, tribal governments, community organizations, and private citizens for their review and comment. The Final SEIS is prepared after comments are received. This is the process being followed by Jefferson County. All comment letters are reprinted in this Final SEIS. A letter from Fire District No.3 was also included as Appendix G in the Draft SEIS. Comment 4.3.10.4: No one from Jefferson County Community Development made anyon-site visits to verify information. Response 4.3.10.4:. On-site visits to verify technical information were made by the consultants retained to prepare the technical studies. Also, please see Chapter 3, Section 3.3 and Response 4.3.4.1 for more information regarding preparation of the Draft SEIS. DCD staff has conducted frequent on-site visits and examinations of Ludlow Bay Village records. 4.3.11 Additional Comments Comment 4.3.11.1: With the population increase, who will be responsible for security? Will assistance come from Port Townsend? Response 4.3.11.1: Fire and emergency medical responses are addressed in Section 3.8of the Draft SEIS. Police protection was not identified as an issue for EIS analysis by either the public scoping process for this SEIS, or by Section 3.904 Environmental Review for Resort Plan I I I I I I I I I I I I I I I I I I I Development of the MPR Regulations. The proposed Resort Plan will result in an incremental increase in the demand for services from the County Sheriff, but less demand that would have resulted from the 1999 Resort Plan. Over-all, the Port Ludlow MPR is limited to 2,250 units, wherever they are within the MPR. The proposed revision to the Resort Plan cannot alter the total number of units within the MPR. Although the County Sheriff has not commented on this particular project, the Sheriff's Office has recently commented on other projects stating that the steady incremental increase in population and residences within unincorporated Jefferson County has not been addressed through additional resources being provided to the Sheriff's Office and mitigation should be required to add those resources to the Sheriff's Office. The issue of appropriate resources for the County Sheriff's Office is a county-wide issue. The County must decide, on a county-wide basis, if they believe it is appropriate to assess SEP A mitigation or impact fees. Iffees are assessed, they must be based on a study of costs and demand for services. No such studies have yet been prepared. The 1998 Jefferson County Comprehensive Plan does not address a level of service for uniformed officers. Comment 4.3.11.2: Jefferson County has no responsibility to PLA regarding the economic viability of their investment. Response 4.3.11.2:. Your comment is noted. Comment 4.3.11.3: Admiralty II needs protection from the impact of 39 new housing units; these new units will have no open space of their own. They will purchase property with expectations of enjoying the shoreline, walking paths and views. We request that PLA be required to install a fence along our joint boundary, ornamentally designed and including an entry gate for vehicular traffic. Response 4.3.11.3: Your comment is noted. All alternatives evaluated in this Final SEIS assume the entire Admiralty area is part of the Resort complex. Development of the Admiralty ill area will be undertaken at a later date and will be subject to a public review process. Comment 4.3.11.4: The Twin Islands should be placed in a Conservancy. Response 4.3.11.4: Your comment is noted. The Twin Islands are not part of the area for which the revised Resort Plan, shoreline permit, or plat alteration is proposed. The applicant has committed, however, to permanent preservation of the Twin Islands. Comment 4.3.11.5:' We do not understand why a copy of our comments are sent to the PL VC. The PLVC does not represent us. Response 4.3.11.5: All comments received on the Draft SEIS are part of the public record for this proposal. The PLVChas requested copies of all comments. Port Ludlow Resort Plan Revision Final SEIS 4.37 May 2005 ~ Port Ludlow Resort Plan Revision Final SEIS 4.38 May 2005 ~ I I I I I I I I I I I I I I I I I I I Comment 4.3.11.6: At a 1996 Planning Forum, owners requested to protect the natural environment and protect the area from over-development. Response 4.3.11.6: Your comment is noted. The overall Port Ludlow Development Plan and MPR regulations, are not being revised. The zoning designations, including the Recreation Areas and Open Space Reserves shown on the Port Ludlow Comprehensive Plan (Figure 11 of the Draft SEIS), will remain unchanged. The approved development cap of 2,250 residential dwelling units will also remain unchanged. Comment 4.3.11.7: Two propane storage areas are planned, with no supporting safety or fire analysis. In our wooded area, fires are a major concern. Response 4.3.11.7: Your comment is noted. Any new propane storage area must meet fire code requirements. Comment 4.3.11.8: There is no discussion of the elevator at the parking lot or the 18-foot wall. What do these items consist of? What are the safety measures connected with these items? Response 4.3.11.8: The elevator will be a standard commercial exterior elevator integrated into the engineered concrete wall. All elevators in Jefferson County must meet specific construction and maintenance standards. The 18-foot wall will be an engineered retaining wall. All retaining walls over 4 feet in Jefferson County must be designed by a professional engineer licensed in the state of Washington. Comment 4.3.11.9: Pedestrian traffic will increase significantly with the planned revisions to the Resort. No analysis has been done regarding the planned revisions with respect to pedestrian safety. No pathways or sidewalks are proposed, so people will be forced to walk on roadways. Response 4.3.11.9: Your comment is noted. The proposed pedestrian trail plan is shown on Figure 13 of the Draft SEIS. This trail plan connects the upper community parking lots to the shoreline boardwalk and beach trail. Also, please refer to Response 4.3.6.3 in this Final SEIS. Comment 4.3.11.10: Assisted living care facilities should be provided. Response 4.3.11.10: Assisted living facilities are not considered an appropriate use within the RC/CF zone. Comment 4.3.11.11: Construction of Building 600 (within LBV) as a 6--unit condominium should not be allowed until all required approvals are in place. Response 4.3.11.11: Your comment is noted. No work on Building 600 is now underway.