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December 19, 2004
DEe 2 a 2004
Mr. Dan Titterness,
Mr. Glen Huntingford
Mr. Pat Rodgers
Jefferson County Commissioners
Port Townsend, Washington
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Re: Agenda for Meeting of December 20, 2004; Community Development Actions
Dear Messrs Titterness, Huntingford, and Rodgers:
As a concerned resident of Jefferson County and Port Ludlow, I am addressing this open letter to
you as Jefferson County Commissioners because of my concern with proposals by Jefferson
County Community Development to retain certain consultants, to permit the draft supplemental
environmental impact statement urged by Port Ludlow Associates ("PLA") to proceed without
regard to the views of the Port Ludlow community, violations of law, failures to perform contract
conditions, and violations of safety and environmental concerns, and to retain certain elected
public officials as employees after the end of their offices. Except for the employment of elected
officials, all of the matters to which the preceding sentence avers relate to the 1994 Townhouse
Plat at Ludlow Bay and PLA's proposal to modify or develop same. The 2004 election results
strongly suggest that all of these matters should be reviewed by the Board of County
Commissioners as constituted by the voters and not by the outgoing Board of County
Commissioners, two of whose members were rejected by the voters.
I draw your attention to the following matters:
1. There is no conceivable justification to spend limited Jefferson County resources to retain
the consultants identified in items eight through ten of the Agenda when their duties are clearly
duties that should be performed by the staff of Community Development itself with the advice of
the Jefferson County Attorney.
2. Community Development, currently under internal audit, by seeking outside consultants
is admitting that its costly personnel are not able to handle issues relating to plats, a matter
directly within its historical aegis. If Community Development lack competent personnel, perhaps
the existing costly personnel should be replaced with personnel that understand land use law and
land use planning as a substitute to adding consultants that have had long term relationships with
Community Development and the various developers at Port Ludlow.
3. Before retaining the auditor of Community Development for another year, Jefferson
County should spend the time to evaluate the results of the initial audit to see if the cost is
justified and to see if the auditor is accomplishing its assigned tasks.
4. Before accepting Community Development's proposal to retain consultants, there should
be an independent investigation of Community Development's continuing pattern of (a) unlawfully
approving construction proposed by the developer at Port Ludlow under lapsed Shoreline
Substantial Development Permits, (b) unlawfully continuing approval of actions on building
permits that violate the 1999 Master Planned Resort Ordinance (the "Ordinance") as to setbacks
from Heron Rd., the 2000 Development Agreement (the "Development Agreement") between
Jefferson County and the developer incorporating same, and the building permits containing such
conditions as special conditions to the building permits, (c) unlawfully accepting the developer's
construction of a roadway of substandard width at Heron Rd. and between the Ludlow Bay
marina and the hotel at Ludlow Bay, and, (d) unlawfully failing to enforce the conditions of the
1993 Shoreline Substantial Development Permit against the developers for failing to perform the
landscape plan and conditions and to maintain the lagoon in accordance therewith.
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5. To the extent there is any justification for contracts between Community Development
and any consultants, such contracts should be fully and publicly reviewed to determine if the
contracting parties have any prior relationship with the developer whose proposals they are asked
to review giving rise to conflicts of interest.
6. Since the consulting contracts identified in items nine and ten in the Agenda involve
exclusively the Port Ludlow community, that community should be consulted before retaining any
such consultants.
7. Before accepting Community Development's decision to permit the developer's draft
supplemental environmental impact statement of April, 2004, as modified, there should be an
independent investigation of the nearly two hundred complaints of the Port Ludlow community
including complaints relating to the safety of the project and of development along Heron Rd., the
preservation of fish and wildlife habitat as required by the 1999 Shoreline Substantial
Development Permit, violations of legal requirements respecting the project, and failure by the
proponent of the project to identify and provide bonding to assure the construction of amenities
promised under the Ordinance and the Development Agreement.
8. Before accepting Jefferson County Community Development's ("Community
Development") decision to permit further building permits to issue to the developer, there should
be an investigation of the liability of Jefferson County for Community Development's unlawful
approval of single family attached residences along Heron Rd. that violate the twenty (20) foot
setback requirement of the Ordinance, a requirement that Community Development admits has
safety implications involving ordinary traffIC and emergency and fire vehicles.
9. Before Community Development enters any commitments or contracts, employment or
consulting, with former elected officials whose services the voters have terminated, it would a
good idea to review the Chapter 42.23, RCW governing the ethical requirements applicable to
municipal officials, including county offICerS.
Jefferson County is not a rich county. It does not have funding to permit its agencies, such as
Community Development to engage consultants that are clearly for the purpose of advancing the
agenda of the developer by finding ways to modify the Ludlow Bay Townhouse Plat to fit the
developer's plans or, through the same consultants, urging the Washington Department of
Ecology to permit that same developer to build over the lagoon in violation of the Jefferson
County Master Shoreline Program. It cannot afford to fail to force the developer to cure violations
of the Ordinance and setback requirements in the building permits even though Jefferson County
is indemnified by the developer and its knowing approval of the deficiencies exposes it to
substantial liability if anyone is injured as a result of the violation of the Ordinance and the
underlying safety concerns that support it. It cannot afford to permit the developer to continue to
construct residential improvements at Port Ludlow without identifying and bonding the completion
of the supporting amenities promised under the Ordinance and the Development Agreement,
amenities, the construction of which would increase employment and the value of which would
increase Jefferson County's tax base.
What we have here is an obvious attempt by Community Development to continue to evade its
legal duties for the benefit of the developer to the detriment of the Port Ludlow community and to
the detriment and substantial risk of Jefferson County. I call on the Board of County
Commissioners to put the health and safety of its people over the short term profits of developers
such as PLA, to hold Community Development accountable to further health, safety and
. environmental interests of its residents, and for its long term failure to do so. Community
Development should not be permitted to hire additional expensive personnel, particularly those
who are former elected public officials, or consultants with cozy historical relations with the very
developers that are the subject matter of their advice. Nor should it be permitted to pass on the
developer's flawed draft supplemental environmental impact statement in its present form until it
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addresses all of the concerns of the affected Port Ludlow community and until the developer has
brought itself into compliance with the legal requirements, conditions and promises, of the 1993
Shoreline Substantial Development Permit, the Ordinance, and the Development Agreement.
The derelictions of which this letter avers are not simply innocent mistakes or lapses in judgment.
The Agenda contains yet more evidence that Community Development intends to conduct
business as usual for the benefit of its friends, the developers. My townhouse is located less than
three feet, not twenty feet from Heron Rd as required by the Ordinance. It is built on a Shoreline
Substantial Development Permit that lapsed in 1998. Building without a valid Shorelil)_e
Substantial Development Permit is civilly and criminally actionable against both the developer and
the personnel of Community Development that knowingly or recklessly permitted the developer to
do so. My neighbors and I have defective title in our units as a result of the developer's decision
to ignore setback, plat and Shoreline Management Act requirements. We cannot sell our units or
even refinance them. Community Development approved the location of the improvements in
violation of the building permits, Ordinance and safety concerns and the building of the
residences without a Shoreline Substantial Development Permit. Twelve units, all of those built
by PLA are affected. Am I to believe that the inspectors were blinded to the difference between
three (3) to six (6) feet and twenty (20) feet ten (10) times and to the absence of a legally required
Shoreline Substantial Development Permit twelve times. Even the developer has openly
represented that Community Development knew of the violations and approved them to my
detriment, that of my neighbors, and that of Jefferson County. The fire in the condominium units
should have been a wake up call. The 911 procedure failed from human error and the fire units
had trouble deploying. How do you think they will deploy around the hotel or the lower
townhouse units in like circumstance? I hope none of you seriously thinks that Jefferson County
will not be presented with a huge bill should there be such an event. There has been enough
winking of eyes for the benefrt of development at the expenses of safety, health, contract rights,
and environment under the oversight of this Board of County Commissioners. ,It is time that they
forsake "development at any cost" and look to the interest of the residents as the voters have so
obviously directed them to do. I call upon this Board of County Commissioners to do the right
thing, for the County residents and not for the developer.
If this Board of County Commissioners is not willing to take stands on these matters, all of the
issues identified herein, including items eight through ten of the Agenda, should be tabled until
the new Board of County Commissioners is able to review them. I am sending this to Mr. Loomis
who will be present at the above referenced meeting. He has my instructions to introduce this
letter into the record of the meeting and to publish it.
Sincerely,
Leslie A. Powers,
Resident,
Port Ludlow, Washington
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