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PLOD
Port Ludlow Drainae:e District. Post Office Box 65261. Port Ludlow. 98365 W A
SUBJECT: PUBLIC COMMENT ON PORT LUDLOW RESORT PLAN
REVISION DRAFT SUPPLEMENTAL ENVIRONMENTAL
IMPACT STATEMENT,
JEFFERSON COUNTY, WASHINGTON
Jefferson County Department of Community Development
621 Sheridan Street
Port Townsend, WA 98368
Dear: Mr. AI Scalf
4 November 2005
The Port Ludlow Drainage District has reviewed the Port Ludlow Resort Plan Revision
Draft Supplemental Environmental Impact Statement (DSEIS) dated April 2004 and
second amended Major Resort Plan Revision. The District submits the following
comments:
1. The Port Ludlow Drainage District (PLDD) is a public agency duly formed
under RCW 85.38 with SEPA authority and environmental expertise for
surface water and drainage issues within the District.
2.
The Resort Plan Revision area described in the DSEIS lies entirely within the
boundaries of the PLOD.
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3. Jefferson County and the PLDD have both adopted the 2001 Washington
State Department of Ecology Storm water Management Manual for Western
Washington (2001 DOE Manual). Since the DSEIS is essentially a new
applicatio~ the proposal must meet all applicable requirements at the time of
application. Therefore. the currently adopted Stormwater Management
Manual should be used for storm water management. The PLDD will not
accept any responsibility for facilities not in strict compliance with the 2001
DOE Manual.
4. To the greatest extent practical. low-impact development methods should be
incorporated into the development plans. Areas such as occasional or
overflow parking should have specially designed pervious surfaces to allow
for direct inftltration of storm water. Separation of directly connected
impervious areas. and bio-retention should be utilized to the maximum extent
practical.
5. Under Section 3.2.1. I-Affected Environment. reference is made to stormwater
discharge to an "artiftciallagoon." This lagoon system includes mechanical
pumping systems that are not intended for storm water management. The Port
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Ludlow Drainage District strongly discourages mechanical systems fur any
storm water management systems (public or private) due to highest risk of
failure (power loss) at the time of greatest need (storm events). The District
will not accept any responsibility for management of any new storm water
facilities requiring mechanical systems or for new facilities not in strict
compliance with the 2001 DOE Manual. The District will not accept
responsibility for operation and maintenance of the lagoon due to the
mechanical systems involved.
6. The DSEIS does not specifically state the responsibility for drainage systems
after construction is complete. The operation and maintenance of all installed
drainage facilities must be clearly stated. With the additional private
residences rather than a larger single complex, stormwater facilities and
maintenance often are ignored until the point of failure.
7. The location of the proposed Admiralty III complex will require addressing
both surface water runoff and groundwater. During the wet season, the
groundwater is very close to the surface and it will impact any development or
storm water detention systems. We recommend that a geotechnical engineer
or hydro geologist licensed in the State of Washington be used to design the
storm water and groundwater system in compliance with the 2001 DOE
Manual.
8. Water quality treatment will be required for the proposed development in
accordance with Minimum Requirement #5 of the 2001 DOE Manual. These
requirements must be met regardless of whether detention or direct discharge
is used.
9. The applicant states that stormwater detention facilities will be required for
the Admiralty III complex. Minimum requirement #7 of the 2001 DOE
Manual requires detention only for discharges to fresh water, not marine
waters. Due to the location of the Admiralty III complex, stormwater should
not be detained but be discharged directly to the marine waters of Port Ludlow
Bay.
The Port Ludlow Drainage District was formed in year 2000 to address drainage issues
within the greater North Bay. The District looks forward to working with Jefferson
County and Port Ludlow Associates in addressing storm water issues within the project
area.
Very truly yours,
~?-
Richard P. Regan P.E
PLDD Commissioner Chairman
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