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HomeMy WebLinkAboutLog304 , '" ~~' PORe luOloill vtllAQ€ COUOdl, P.O. BOX 65012 PORe luOlow, W^ 98365 ,~ .- I i~: l=l::::.J :'Cl\\! H...., I /".1','::1.../," November 3,2005 Mr. Al Scalf Department of Community Development Jefferson County 621 Sheridan Street PortTo~end, VVA 98368 Re: Application by Port Ludlow Associates for Major Resort Plan Revision, (MLA05- 00407 including ZON03-00044, Major Resort Plan Revision, SUB05-00030 Boundary Line Adjustment, SDP 00019 Shoreline Substantial Development Permit and ZON05- 00035 Administrative Code Interpretation Dear Mr. Scalf: Port Ludlow Village Council (pL V) has closely followed this proposal by the developer, Port Ludlow Associates throughout the lengthy application process. The Council recently held a town meeting for the purpose of introducing the final application and proposal to the community and hear questions.and concerns from residents. As the developer states in the proposal, "Our project will complete the resort...will provide valuable jobs and housing, and will lessen the potential impacts of the approved Resort Plan." PL VC concurs in part; this project will have major impact on Port Ludlow's Core Resort area and the identity of Port Ludlow. A vital resort core, or a failing one, will directly affect the future values of each of our properties and will certainly affect the continuing quality oflife for everyone in Port Ludlow. The Council has concerns with some parts of the proposal and doubts that some planned buildings are allowable under applicable law. It continues to be the position of the PLVC that development in Port Ludlow must follow all applicable law. Building Over Water The State Department of Ecology has said that no over-water construction should be permitted. The developer has submitted an application that does not intrude into the lagoon. However, they have also submitted a request for Administrative Code Interpretation (ZON05-00035) seeking to have this restriction set aside, and asserting that LOG ITEM # ~Ot.( Page---L-ofS; 1 /4, the lagoon is artificial and is not valuable wildlife habitat. These arguments were specifically addressed and rejected by the DOE (Letter of October 25,2004 to:tvlr.M Scalf). .. - The lagoon is a valuable portion of the open space and natural settings around which the Port Ludlow Resort has been created. Degrading the remaining lagoon area by allowing intrusion of condominiums or townhomes over it will further reduce the quality of both the lagoon waters and wildlife visitation areas and the Master Planned Resort designation from which the developer benefits. We believe this request should be denied, in keeping with the Department of Ecology position. Meeting and Maintaining Prior Development Conditions Landscaping around the lagoon is divided into "human" and "wildlife". The previous permit included Conditions relating to provision of bird rest areas, covering vegetation in and near the lagoon and other provisions that have not been met. Prior Conditions including provision for completing and maintaining these areas should be included in conditions set for any approvals of further development permits. The Council suggests that an appropriate means to ensure that these and other amenities be built in a timely manner is performance bonding of those portions of the project which will be retained by the Resort owner rather than sold to new residents. Such a requirement is within the power of Jefferson County and would provide confidence in the project for Port Ludlow's residents who depend on the County for governance. Traffic Flow and Parking The FSEIS contains traffic volumes for major roads surrounding Port Ludlow but no study has been done of the internal traffic flows likely to result from the proposed increased residential development.. The Master Association CC&R's of Ludlow Bay Village for Heron Road, a private road, do not allow on-street parking. Internal traffic congestion, the likelihood of on-street parking violations resulting from 12' setbacks as allowed for condominiums, lack of sidewalks for safe pedestrian traffic and lack of turning space for emergency vehicles are concerns that will be multiplied by the increase in density to 101 residences. Single car garages and tandem parking in 12' driveways will certainly create conditions likely to cause accidents. This is particularly true of Building R-8, which is placed directly across from existing townhomes with less than 5- foot setbacks. It should not be built. While parking has been increased in the overall area, there is not sufficient parking near the proposed residences and this is primarily a result of greater density than the area can reasonably accommodate. The parking study does not appear to consider the Yacht Club needs. The proposed relocation of marina parking will require a significant walking distance of several blocks. No pathways or sidewalks are provided within resort areas or from parking to marina where considerable vehicular traffic must be expected. Heliport location Typically when emergency vehicles arrive at the current designated helicopter site, traffic is shut off on the neighboring roads for 30 to 90 minutes. In the location designated in LOG ITEM # 3 () L( Page ~ of6 2 the proposal the ~earby roads are Marine View Drive, Ol~pic Lane and O.akr~~~9a~t These are the mam route through Port Ludlow, and the pnmary roads carrymg.Ml ~,~ into and through Ludlow Bay Village, reaching proposed new residences on Heron Rd., the hotel, marina, Beach Club and Admiralty Condominiums, existing and proposed. The heliport should be relocated to a site which will not cause an inordinate amount of traffic disruption. /" Boundary Line Adjustments, Zoning considerations It has been the position of the PLVC that development of the resort should be in keeping with the Master Planned Resort Ordinance and the Development Agreement set out between the developer and the community and the County. The laws governing development in Port Ludlow should be carefully followed. The existing plat providing for 58 residences (53 townhome lots and 5 single family residences) is governed by CC&R's as well as County Ordinances. This is a major revision to the resort under Para. 3.903 of the MPR Code. A plat alteration is required rather than a boundary line adjustment for a subdivision that has been approved and recorded but only partially developed. Further, the existing plat has CC&Rs attached which should not be over- ridden, or circumvented in an attempted boundary line adjustment to accommodate condominiums on town-home lots. Increased Residential Density The PL VC supports the density of 58 units permitted by the Hearing Examiner for the existing plat and presumably recognized by PLA at the time of acquisition of the Resort property by them in 2001. Under the heading of Unavoidable Adverse Impacts the Final Environmental Impact Statement, published in May 2005 states on p. 3-61 (3.4.4) Build-out of the Resort will result in more intense development of the project area. Increased 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. The aesthetic character of the Resort can be expected to change with development but excessive density should not be imposed to the detriment of the existing Resort community. The 1993 Plat submitted by Pope Resources and approved for this property contains among other Conditions, Department Recommended Condition 5: that open space easements be granted in perpetuity. The applicable provision is as follows: 6.204(1) Minimum areafor parks, open space, greenbelt and buffer strips shall be provided as ten (10) percent of the total gross area of the subdivision with at least one- half (1/2) of said area being suitable for active recreation pursuits. That relationship of density to open space and recreation area was established and approved for this plat in 1993. We do not want to see it diminished. LOG ITEM #3()L( ~ Page. 3 _.of ~ 3 Residential construction on the current Harbormaster Restaurant site sho~d be allowed if approved by the Ludlow Bay Village Association. Residential units shoUld remain as town-homes or single-family'residences unless changes to the plat are approved in accordance with the Master Association CC&Rs. In following Jefferson County Code, the rights of the property owners of the LBV Association should be ensured. In the interest of the integrity of the Port Ludlow community the PL VC opposes any requirement of the Development that new or existing residents ofLBV be required to join a new club built in the Marina area for use of marina and hotel guests. Under the existing Master Association CC&Rs LBV owners are members of Ludlow Maintenance Commission, (LMC). Adding yet a third community association to Port Ludlow is divisive to the community and a significant revenue loss to LMC. Admiralty III Insufficient detail is provided in the FSEIS or the applications for review of the development planned for the Admiralty III area. A retention pond is mentioned but not located. The FEIS indicates a known "medium slip risk" for the Admiralty II and III areas yet additional development is planned adjacent to steep slopes above Admiralty II buildings and a retention basin would add to the potential for slippage from seeping storm water runoff. The Council agrees that this area may be suitable for condominium development at some point. However it should not be included in consideration of this Application nor should any of the current Application proceedings be vested for future development of Admiralty III. Part of Admiralty III is planned on the only remaining recreation area in the Ludlow Bay area, where play equipment, volleyball court, basketball court, horseshoe pits and walking paths now exist. No replacements for these facilities have been provided in the resort plans. Increased populations will occur without even the existing levels of recreation facilities. The County Comprehensive Plan states in Parks and Recreation Policies - Open Space Goal 4.2 Develop recreational opportunities such that: a. Existing recreational areas and facilities are not overburdened, b. Recreational facilities are planned to support areas designated for future residential development, c. Adequate infrastructure is available. This area of Admiralty III should be improved for recreation facilities to serve current and future guests and residences of the Ludlow Bay village and Admiralty I and II area of the resort and other near-by homeowners. Maintenance Facility A major maintenance shop is indicated which would indicate the presence of considerable utility vehicle traffic on Olympic Lane. A total of 39 new stacked flats are proposed along this street. Traffic, both vehicular and pedestrian can be expected to increase without provision for it. No sidewalks or widening is indicated for Olympic LOG ITEM :a:t of S 4 ..... re..""',T Lane. ~e ~oca~ion ~f a maintenance facility in close prox~~ to the ~l~!K~ complex IS m vIolation of the Development Agreement gwdelmes. ,;; ,.1 '. ' Approved for Submittal by Port Ludlow Village Council this 3rd day of November 2005. Sincerely, /.--...." ~.D~ Tony D 13t#-. A,'---> Bert Loomis ~},-r-I-t:t.~ ....A ~_~c/~ ijrnce~9hnriu ---\) A.llen Panasuk JL~?"~~ Thomas Stone RW~~$ >' ...., ~ '~Y~Z-e'4 -.. . Q~; leff~f~QP. CqHJ1ly' Ppmml~~iQn LOG ITEM # 3oL( Page S of ~ 5