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" . lI,em,..., ,,8#8' #9 an~#10 from the 12/20/04 consent agenda.
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From: Robert Azen [raincrow@cablespeed.com]
Sent: Sunday, December 19, 200410:55 AM
To: Lorna Delaney
Subject: "ems #8, #9 and #10 from the 12/20/04 consent agenda.
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DEe 2 02004
Board of County Commissioners
Jefferson County
Port Townsend, Washington
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Re: December 20, 2004 Agenda; Community Development
Decision on Ludlow Bay Draft Supplemental Environmental
Impact Statement
Dear Sirs:
I call upon you to table items eight, nine, and ten on the agenda and to send Mr. Scalf
instruction not to proceed with the approval of PLAls SEIS in its present state. PLA must
not be permitted to go forward on its plans until it has brought the project as a whole into
compliance with law, and with safety, health, and environmental concerns affecting
Jefferson County.
I appreciate your attention to this letter in your consideration of the December 20th, 2004
Agenda.
I have been informed that Community Development has placed three items on the agenda for the
December 20th Meeting of the Board of County Commissioners, numbers eight, nine, and ten. They
provide:
8. Agreement, Amendment No. I re: Professional Consulting Services for
the Review of Permitting and Plat Issues of Ludlow Bay Village in
Port Ludlow; Jefferson County Department of Community Development;
The Latimore Company, LLC
9_ Agreement re: Professional Consulting Services for 2004 for the
Review of Permitting and Plat Issues of Ludlow Bay Village in Port
Ludlow; Jefferson County Department of Community Development;
Lumsden International, Inc.
10. Agreement, re: Professional Consulting Services for Zoo5 for the
Review of Permitting and Plat Issues of Ludlow Bay Village in Port
Ludlow; Jefferson County Department of Community Development;
Lumsden International, Inc.
12/20/2004
LOG ITEM
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Items #8, #9 and #10 from the 12/20/04 consent agenda.
Page 2 of 4
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I want to raise my objec~on to the co~ideration of th~ items. ~omm~ty Development is pres~t1Y.A"1..
under a performance audIt. Although It has an extensIve payroll mcludmg persons that have expertise in ,.
land development and the law applicable thereto and has access to Mr. Alvarez, the Jefferson County
Attorney with responsibility for advising Jefferson County officials on legal matters, it chooses to retain
expensive experts to "advise" it as to its area of expertise and competence. I also note that Community
Development is asking the Board of County Commissioners to approve a contract for Ms. Lumsden
after Community Development retained her services. This must be true as to the 2004 portion of the
contract unless her work will be performed in the last ten days of2004. I have checked with the Port
Ludlow Village Council. It has not been consulted as to the identity of a proper "consultant" with
respect to planned revisions to the Plat urged by the developer. I would think that the Persons most
affected would be consulted before retaining an advisor such as Ms. Lumsden.
I am not aware of the qualifications or need to retain the Latimore Company, LLC or the identity of its
ownership and personnel. Before approving Latimore Company, LLC, I would think it appropriate to
provide information on its expertise, contacts, and need.
As I noted, Community Development is under a performance audit. While I do not understand that audit
addresses such matters, I would think it should address the approval by Community Development's
building inspectors of buildings 400 and 700 in the Plat as compliant with the conditions to the bUilding
permit and the requirements oflaw. The building permits require a twenty foot setback from Heron Rd.
The setback, as Mr. Scalf, head of Community Development knows from personal inspection is in fact
in some instances such as my unit less than three feet from Heron Rd. The building permits, again as
Mr. Sca1fknows because I personally informed him, reflects the requirements of the 1999 Jefferson
County Ordinance approving the Master Planned Resort at Ludlow Bay (the "Ordinance"). The
Ordinance is incorporated by reference as an exhibit and is an integral part of the development
agreement (the "Development Agreement") between the 2000 Jefferson County and Port Ludlow
Associates, the developer ("PLA"). The Ordinance's requirement for a twenty (20) foot setback from
roadways applies to all single-family residences, both attached and detached, that are built in the Master
Planned Resort. Townhouses are expressly defined in the Ordinance as single family attached
residences. The language in the Ordinance is absolutely clear. Community Development identified the
requirement as a special condition to the building permits issued to PLA.
PLA ignored the road setback requirement and violated the Ordinance and conditions to the building
permits when it designed and built the townhouses in buildings 400 and 700. Community
Development's building inspectors then consistently certified that the setback condition to the building
permit and requirement of compliance with land use laws had -been met when visual inspection shows
and would have shown that this was not the case. There is a big difference between three (3) feet and
twenty (20) feet. There was no confusion. The action by the building inspectors, all employees of
Community Development was intentional or reflected a failure by the building inspectors to visit the
sites.
This is not a harmless violation. The setback as Mr. Sca1fhas confirmed to me reflects safety concerns.
The seriousness of those concerns is evident from comments made in response to PLAts "new plan" in
the meeting of December 15th, Mr. Sca1fwas present and heard those comments first hand. Moreover, ~~
in part as a result of the ordinance violations, First American Title has informed my surveyor that it will
no longer issue standard title insurance policies on the units in building 700, rendering title to the units
for sale and finance defective. Because ofPLA's violation of the road setback conditions of the
Ordinance, the Development Agreement, and the building permits, my neighbors and I are left with
dangerous conditions affecting the use of our garages and defective title. Community Development was
either knowing complicit in ~ese violations or negligent in permitting them to go unaddressed when the
buildings were initially permitted and later approved.
12/20/2004
ITEM
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. Items #8, #9 and # 10 from the 12/20104 consent agenda.
Page 3 of 4
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.J:w Community Development in the face of shortfalls in available tax revenues wants to spend more
money to hire more "consultants" to help it or PLA obtain relief from conditions to the Plat, Ordinance
and Development Agreement which bind both. This is unconscionable. Jefferson County has better
things to do with its money than spend it on consultants to give cover to Community Development
personnel that have not been doing their jobs and appear to want to continue not to do so. The chief
concern of Community Development should be the safety and health of Jefferson County's residents and
residential property owners and ~e preservation of the environment, not the profitability of development
projects to developers such as PLA. I call upon the County Commissioners to reject this brazen attempt
by Community Development, probably at the instance ofPLA to retain personnel thafview development
as more important than health, safety, and the environment.
I note that Mr. Scalfhas given the Ludlow Bay Village Council written notice that he will permit PLAts
draft supplemental environmental impact statement ("SEIS") originally submitted in April, 2004, to go
forward even in the face of nearly two hundred (200) adverse comments and a generally hostile
reception as to its revised form in the meeting of December 15th, 2004 called by PLA. The SEIS is
fatally flawed and conflicts with the requirements of the Development Agreement that it consider both
the marina expansion and the buildout of the Plat and associated commercial facilities simultaneously.
The SEIS now appears to proceed on two or three tracks. It is required to propose a single development
plan. The SEIS proposes a modification to the Plat that requires joinder of a majority of the owners of
the Plat.
The SEIS does not demonstrate that it has support from a majority of the persons owning an interest in
lots in the Plat. Please note, PLA has but one vote, not one vote per platted lot. Please have Mr.
Alvarez review RCW 58.17.215 and advise you of its terms. PLA does not propose a lot line adjustment
or its like here. The changes are fundamental to the ownership in the plat. Condominium owners do not
own lots; townhouse owners do.
The SEIS fails to cure all of the deficiencies in the 1991 Substantial Development Permit (the "SDP")
applicable to the lagoon and to the plat as a whole. PLA's agreement not to build over the lagoon after
receipt by Community Development of an opinion of the Washington Department of Ecology (the
"DOE") that Community Development could not approve such construction, does not represent much
progress toward curing patent deficiencies to the lagoon or the Master Planned Resort. Neither the
landscaping plan has been followed nor has the condition of the lagoon been maintained in accordance
with the SDP. These deficiencies, if cured, would surely restore the lagoon to a wetland and not just a
tidal aim of Ludlow Bay as noted by the DOE.
Not only did Community Development spend its own time and treasure pursuing an opinion from the
DOE that the lagoon is not a wetland and that PLA should be permitted to construct residences over it
but Community Development, obviously without approval of the Board of County Commissioners hired
Ms. Lumsden to assist it to obtain the relief it sought for the benefit ofPLA. Community Development
took these actions notwithstanding the consistent response of the community at Ludlow Bay in
opposition thereto. The proper response was obvious. IfPLA wanted to pursue the right to build over
water and there was a question, its application should have been rejected. PLA would then have had the ~~
opportunity to pursue an appeal through the hearings examiner at its cost. The community at Ludlow
Bay could have intervened in opposition to the proposal at its cost. The DOE would have had the right
to intervene at its cost. In other words, Community Development squandered public funds to advance
the interests of a developer rather than have the developer pursue its own remedies at its own costs.
Apparently, it is permitted to spend Jefferson County funds, obviously in short supply, to help favored
developers such as PLA.
12/20/2()04
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Items #8, #9 and #10 from the 12/20/04 consent agenda.
Page 4 of4
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The SEIS does not identify and secure the construction of the amenities promised in the Development .....
Agreement and implicit in the Ordinance. Moving and shrinking the restaurant and providing an
amenity restricted to the hotel is not a substitute for the amenities that should have been buill Neither is
it permissible for PLA to ask the community at Ludlow Bay or Jefferson County to rely upon its
reinvestment of profits from sale of residences to finance the amenities. The amenities are at least a
condition ofPLA's rights to develop residences and commercial improvements under the Development
Agreement. What are the amenities? When will they be constructed? For the benefit of the community
at Ludlow Bay, Community Deyelopment must cease to give a free pass to PLA on the amenities. PLA
has had a nwnber of years to identify and complete them. Further development in the Master Planned
Resort should cease until the amenities are identified, approved by the community at tiid10w Bay and
their completion bonded. The SEIS does not address this very critical issue. IfPLA is permitted to
complete residential and commercial undertakings without providing assurance of amenities that support
them, the community at Ludlow Bay and Jefferson County will financially suffer.
We are at another crossroads in PLAts ill considered proposal to dense pack condominiums along Heron
Rd. There is no reason for Community Development to decide to permit PLAts proposal, whatever it
may be, to go forward. PLA has not cured any of the problems with the SEIS. Its second proposal does
not do so. It has not brought itself into compliance with the Ordinance, the Development Agreement or
the SDP. In fact it is out of compliance with the requirements of the Shoreline Management Act and the
Jefferson County Substantial Development Program because it has built twelve (12) townhouse units in
the Plat after the lapse of its rights to build under the SDP in 1998. Construction of improvements
valued at more than $5,000 is civilly and criminally actionable. What has Mr. Alvarez been doing about
this matter? How does Community Development explain issuing building permits and approving
construction of twelve (12) townhouses on a lapsed SDP? These questions need to be answered before
permitting the SEIS to go forward. The County Commissioner need to investigate these derelictions of
Community Development and the County Attorney before permitting the approval of additional
construction in the Master Planned Resort
There will be two new County Commissioners in January 2005. Their election represents a radical shift
in the position of the voters about the actions of the County Commissioners in approving development at
the expense of safety, health, and environmental concerns. The new County Commissioners should be
. permitted to review the audit of Community Development before approving any more contracts for
"consultants" or permitting Community Development to continue its pro developer stance by giving a
pass to PLAts SEIS.
I appreciate your attention to this letter in your consideration of the December 20th, 2004 Agenda.
Sincerely,
~r
Robert Azen, Chairman
Bayview Village Architectural Committee
70 Mariner Place
Port Ludlow, W A 98365
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Home: (360) 437-9677
raincrow@cablespeed.com
12/20/2004
l.OG ITEM
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