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..JUL-21-2006 FRI 12:58 PM DO" REGIONAL OFFICE FAX NO, 3_07 6305 p, 01
. FAXNUMBER . ~u>O-37~ -<-J~5 j
DATE:
FAX COVER SHEET
I TIME:
I # OF PAGES
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TO:
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FROM:
REMARKS:
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Washington Department Of Ecology
Southwest Regional Office
300 Desmond Drive SE
P.O. Box 47775
Olympia, W A 98504';7775
Phone: (360) 407-6300
FAX: (360) 407-6305
RECEIVED
JUL 2 1 2nDS
JEFffRSOI COUNlYDCO
#'!t'ITEM
Page I of...s
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Thank you for the opportunity to comment on the amended mitigated detennination of nOnSignificance
for the Ludlow Cove Division 2 project (MLA06-00221), located on Paradise Bay Road in Port Ludlow
as proposed by Port Ludlow Associates, LLC. The Department of Ecology (Ecology) reviewed the
enviromnental checklist and has the following comment(s):
/
JUL-21-2006 FRI 12:58 PM D~SW REGIONAL OFFICE
FAX NO, 36~7 6305
p, 02
RECElVED
JUl 2 1 2006
J[~,. iftm'!~ilIV nJ\~
nfUWUl1 bij:~.( n k; l; lJ
STATE OF WASHINCTON
DEPARTMENT OF ECOLOGY
PO Box 47775 . Olympia, Washington 98504-7775 . (360) 407-6300
July 21, 2006
Ms. Barbara Nightingale
Jefferson County
Department of Community Development
621 Sheridan Street
Port Townsend, W A 98368
Your add ress
is in the
Quilcene-
,Snow
'" watershed
Dear Ms. Nightingale:
TOXIC CLEANUP: Chuck Cline (360)407-6267
Original SEP A comments still apply concerning detection of contamination and reporting of such (see
enclosure).
Ecology's comments are based upon the information provided with the SEPA checklist. As such, they do
not constitute an exhaustive list of the various authorizations that must be obtained or legal requirements
that must be fulfilled in order to carry out the proposed action.
If you have any questions or would like to respond to these comments please contact the appropriate
reviewing staff listed above.
Department of Ecology
Southwest Regional Office
ODN:06_0S-S608)
Enclosure
cc: Chuck Cline, TCP
Mark Dorsey, Port Ludlow Associates (Applicant)
Lyn Keenan, Reid Middleton, Inc. (Agent)
.......
o
.__J~L=21-20_~~!RI _13:59 PM DO.W REGIONAL OFFICE
FAX NO. 360~7 6305
P. 03
,.
. .
"
~
STATE Of WASHINGTON .
DEPARTMENT OF ECOLOGY
PO Box 47115 . Olympia, W.tlhinJfon 985lJ4.1115. (360) 407.-6300
;RECI~IVK~ lD
. JUL 2 1 2006
JEffERSDN COUNTY .DiuID
Mach 2.2005
. Ms. Michelle Farfan
Jefferson County, .
Department of Community Development
~lopmcnt Review Division
621 Sheridan Street
Port Townsend, W A 98368
Dear Ms~ Farfan: '
Tboak you Ibr tile ~Iy to __ on 1ho ~ COllIlIIIoIiaB Ibrtba LudloW CoW DiviPoll
n project(Caso Nos. SUSOS.ooo04; 80P05..oooo1: ZONOS..ooooS) locatec:l OD.Panu:lise BaylloaCl in Port
Ludlow as proposed by Port Ludlow Assooia~s, u.c. We revieWed thc'Cnvifomnental checklist and
have the fol101'lini comments: " .' ',' . , ' , "
Your address,
Is in the',
" Qullcene-
SnoW
, watershed
The proposal baa bMn classified as ''re"idcmrial". which apPears ~,b~ _lctC,in.~.tlK,; .'
projcot. Tbc proposal is for time-share condominiumi. a fonn oftranSieni ~~'which ~.
from tb1l time residential use. Tho projeot also appears to include oommercillactivitiea although t}iCse
are miirimaily described. so more exact definition of assOCiated ameniU4ils for pests should ,be described
and will need to be revieWed for applicable policies and regulations in the shordine IIlIst<< Program. -
Non-watcr-dependent commercial deVelopment in shoreline jurisdiction nqui1'esshot'e1inc. ~ '
use approval., " ,.' " .' .
Whether or not comm~ciall8 well is residential aetivities are in faCt ~sect we beli~tbo public
acce8S mandate of~ Shoreline ManaJement Act olevly applies to this liCVeloPinerii., '1'heptoposal'as
tc:o.cJeml would priJvideinsufficient opportunity for public enjoyment of these Shorelines of Stattwide .
SignifICance.
We note in the materials pt'Ovided. applicants writtM intention to limit the use ofpathways aloog tbC '.
shoreline to residentS of the proposed development. The appiication states. that li~1 access to.~ lite
to a sinsle. private acc:eaIlTOBd .....win not be injurioUS totheneilbbolhood or public welfare." 'IbiS' '
assertion, focusec! on the access J08d. also has Jelevancc to shorel_ issues becatlSC the: prn'io~y
plumed waterfront trail intended for public use is now,proposed bein& limited 10 resideDtsonly. The
statement appeen in that conteXt unsupported and jncon'eCt. " ,"
. . ,
.' .'
We belieVe approval oCthil proposal as tendered would be inconsist. with. the poli_ Of the Jefferson
County Shoreline Master Procram. and t\Ot in keepins with the lsgislati:ve intent in the. Shoreline
Manapment At;t (90.58.020). Policies in the Jeft'crson County Shoreline Mastex: Prowam state, for
Urban Designated shoreline areas. "Public access to and along the water's edIe should be 0()0fdinat&ld in
a walkway system and linked tq acljaecnt existing or futuTC waJkways:t Urbm development shOuld
provicJe for public views to the water. _.:I:;' ".. ' 0
JUL-21-2006 FRI 12:59 PM ~SW REGIONAL OFFICE
FAX NO. 3'11t07 6305
P. 04
t
(
March 2, 2005
Page 2
RECEIVED
. .
,
JUL 2 1 2006
JHitiSH tOUllY DLD
The master program states, "Provisions to enhance the public's use and enjoyment of the shorelines and
waters of the state shall be included with new substantialdevelopments or any change in the principle
property use to a new conditional use occurring along the shoreline" and "Developments shalt be
designed so as not to block, adversely interfere with. orreduce the public's visual and physical access to
the water and shorelines of the State."
The proposed waterfront trail needs to open to the public and must be linked with trail systems on
adjoining lands, enabling residents of other Port Ludlow subdivisions and the public ~ continuing
opportunity to enjoy pedestrian use of the shoreline areas on waters of the State.
Provision for adequate public parking and proper signage need to be added to the proposal, The shoreline
trail should be designed with appropriate vegetative buffers planted with well-chosen native speCies shTub
and tree plantings. These should be designed to allow a sense ofprivacy/separation from adjoining , )
residential structures, and to enhance the natural character and habitat Value of the shoreline over the long
term. .
TOXICS CLEANuP: Chack Oble (360)407;"()Z67
I{contamination is currently known or observed during constrUction, sampling of the potentially
. contamin~ted media must. be conducted. If contamination of soil or groundwater is readily visible, or is
revealed by sampling. the Department of Ecology ~ust be notified. 'Contact the Environtnel1:tal Report
1'rac:kinsSystem Coordinator at the Southwest Regi~l Office at (361)) 407-6300. For. assistance and.
inforination about subsequent cleanUp and to identify the type or testing thitt will be required contact~. )
ChuckClincat.(360) 407-6267. ' "
W ATEll QUALITY: Betsy Dickes (360) 407-6294
Any discharge of sediment-laden,runoff Or other pollutants to waters of the state is in violation of ChaPteJ:
90.48, Water Pollution Control, and WAC 173-201A. Water Quality Standards for Surface Waters oCthe
State of Washington, and is subject to enforcement action. Waters of the state include, bid are Dot
limited to, waters In roadside dltehes, storm dra1us, wetlands, Ludlow Creek, the Type 5 stream; .
and Port'LudlowBay. . '
Erosion control measures must be in place prior to' any clearing, grading, or constniction. These cOritrol :'
measures must be effective to' prevent stonnwater nmoff from carrying soil and other pollutants into
surface water or stann drains that lead to waters of the state. Sand, silt, clay particles, and soil will
clamageaquatic habitat and are considered t~ be pollutants.
If this project moves rorward~ a National PoUatioa Discharge RUmination System (NPDES) permit
would be required~ The ~wner of a construction site which disturbs five acres or more' of total land area,
and which has or will have a discharge of stormwater to a surface water or t!l a stonn sewer, must apply.
for coverage under the NPDES and State Waste Discharge General Permit for Stonnwater Disi:harges
AssQciated with ConstrUCtion Activities. .
Owners of sites where less than five acres of tota1land area will be disturbed must also apply if the
cO'nstruction activity is part of a larglef contiguous plan of development or sale in which more than five
acres will eventually be disturbed. Discharge of stormwater from such sites without a permit is a
..
JUL-21-2006 FRI 01:00 PM DOtljW REGIONAL OFFICE
FAX NO, 360~7 6305
p, 05
March 2, 2005
, Page 3
RECEIVED
Jlijt ~ 1 2006
JffffRSltN.lUI1
} i i..,,~U
violation of federal and state law and the owner will be subject to enforcement action by the Department
of Ecology or through third party lawsuits.
.
.
.
For construction of subdivisiOns, the five acre threshold, which triggers the NPDES permit requirement
applic!I to land that is, disturbed by the land owner, land. owner's agent. or by an entity which has obtained
a use agreement (e.g., tease, easement) from the land oWner. Include acreage which is disturbec;l (e.g.,
graded) priOf to its sale to independent con1ractor(s).
. .
A stOrmwater ,permit application form, referred to as a Notice of Intent, can be obtained by calling
Ecology's Stonnwater Request Line (360) 407.71 S6 or Linda Matlock at (360) 407-6437. The NOI
application fonn is also accessible inetectronic fonn on Department of Ecology' s website at:
http://www.ecv.WB.,ovlnroifamslwqlstonnwater/constructionl#A,wtication
Applicants are encouraged to submit completed forms and publish public notices more than 38 days prior
to the planned start of construction to avoid delays to the Project.
, If you have. any questions or would like to respond to these comments please contact the appropriate
reviewing staff listed above.
Department of Ecology
Southwest Regional Office
(A W: 05-0805)
00: Chuck Cline, TCP
Betsy Dickes, WQ
Linda Matlock, WQfHQ
Jeftree Stewart, SEA
Mark Dorsey, Port Ludlow Associates (Applicant)
Lyn Keenan, Reid Middleton, Inc. (Agent)
-
......."
o
e
e
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
PO Box 47775 · Olympia, Washington 98504-7775 · (360) 407-6300
July 21,2006
Ms. Barbara Nightingale
Jefferson County
Department of Community Development
621 Sheridan Street
Port Townsend, W A 98368
Your address
is in the
watershed
Dear Ms. Nightingale:
Thank you for the opportunity to comment on the amended mitigated determination of non significance
for the Ludlow Cove Division 2 project (MLA06-00221), located on Paradise Bay Road in Port Ludlow
as proposed by Port Ludlow Associates, LLC. The Department of Ecology (Ecology) reviewed the
environmental checklist and has the following comment(s):
TOXIC CLEANUP: Chuck Cline (360) 407-6267
Original SEPA comments still apply concerning detection of contamination and reporting of such (see
enclosure ).
Ecology's comments are based upon the information provided with the SEPA checklist. As such, they do
not constitute an exhaustive list of the various authorizations that must be obtained or legal requirements
that must be fulfilled in order to carry out the proposed action.
If you have any questions or would like to respond to these comments please contact the appropriate
reviewing staff listed above.
Department of Ecology
Southwest Regional Office
R JE fI" E,1J~ TE'4D.
Ld ~ ",..di "~ J d jL-'
(DN: 06_05-5608)
Enclosure
JUl 2420GB
cc: Chuck Cline, TCP
Mark Dorsey, Port Ludlow Associates (Applicant)
Lyn Keenan, Reid Middleton, Inc. (Agent)
JEffERSON COUNTY DeD
~'
e
e
."
STATE OF WASHINGTON
DEPAR~MENT OF ECOLOGY iR> lE(" Er~lE D
PO Box 47775 · Olympia, Washington 98504.7775. (360) 407~6~).
March 2, 2005
JUL 2 4 2006
JHffRSUN COUNTY DeD
Ms. Michelle Farfan
Jefferson County
Department of Community Development
Development Review Division
621 Sheridan Street
Port Townsend, W A 98368
Your address
is in the
Quilcene..
Snow
, watershed
Dear Ms. Farfan:
Thank you for the opportunity to comment on the prethreshold consultation for the Ludlow Cove Division
II project (Case Nos. SUBOS-00004; SDP05-00002: ZON05-00005) located on Paradise Bay Road in Port
Ludlow as proposed by Port Ludlow Associates, LLC. We reviewed the environmental checklist and
have the following comments:
SHORELANDS: Jeffree Stewart (360) 407-6521
The proposal has been classified as ''residential'', which appears accurate but incornplete in defining the
project. The proposal is for time-share condominiums, a form of transient accommodation, which differs
from full time residential use. The project also appears to include commercial activities although these
are minimally described, so more exact definition of associated amenities for guests should be described
and will need to be reviewed for applicable policies and regulations in the shoreline master program.
Non-water-dependent commercial development in shoreline jurisdiction requires shoreline conditional
use approval.
Whether or not commercial as well as residential activities are in fact proposed, we believe the public
access mandate of the Shoreline Management Act clearly applies to this development. The proposal as
tendered would proVide insufficient opportunity for public enjoyment of these Shorelines of Statewide
Significance.
We note in the materials provided, applicants written intention to limit the use of pathways along the
shoreline to residents of the proposed deve]opment. The application states that limiting access to the site
to a single, private access road". . . will not be injurious to the neighborhood or public welfare." This
assertion, focused on the access road, also has relevance to shoreline issues because the previously
planned waterfront trail intended for public use is now proposed being limited to residents only. The
statement appears in that context unsupported and incorrect.
We believe approval of this proposal as tendered would be inconsistent with the policies of the Jefferson
County Shoreline Master Program, and not in keeping with the legislative intent in the Shoreline
Management Act (90.58.020). Policies in the Jefferson County Shoreline Master Program state, for
Urban Designated shoreline areas, "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.
o
e
e
March 2, 2005
Page 2
The master program states, ''Provisions to enhance the public's use and enjoyment of the shorelines and
waters ofthe state shan be included with new substantial developments or any change in the principle
property use to a new conditional use occmring along the shoreline" and "Developments shall be
designed so as not to block, adversely interfere with, or reduce the public's visual and physical access to
the water and shorelines oCthe State."
The proposed waterfront trail needs to open to the public and must be linked with trail systems on
adjoining lands, enabling residents of other Port Ludlow subdivisions and the public a continuing
opportunity to enjoy pedestrian use of the shoreline areas on waters of the State.
Provision for adequate public parking and proper signage need to be added to the proposal. . The shoreline
trail should be designed with appropriate vegetative buffers planted with well-chosen native species shrub
and tree plantings. These should be designed to allow a sense ofprivacy/separation from adjoining ,
residential structures, and to enhance the natural character and habitat value of the shoreline over the long
tenn.
TOXICS CLEANUP: Chuck CliDe (360) 407-6267
If contamination is currently known or observed during construction, sampling of the potentially
contaminated media must be conducted. If contamination of soil or groundwater is readily visible, or is
revealed by sampling, the Department of Ecology must be notified. Contact the Environmental Report
Tracking System Coordinator at the Southwest Regional Office at (360) 407-6300. For assis'tance and
information about subsequent cleanup and to identify the type of testing that will be required contact Mr.
Chuck Cline at (360) 407-6267.
WATER QUALITY: Betsy Dickes (360) 407-6294
Any discharge of sediment-laden runoff or other pollutants to waters of the state is in violation of Chapter
90.48, Water Pollution Control, and WAC 173-20 lA, Water Quality Standards for Surface Waters of the
State of Washington, and is subject to enforcement action. Waters of the state include, but are Dot
limited to, waters in roadside ditches, storm drains, wetlands, Ludlow Creek, the Type S stream, .
and Port Ludlow Bay.
Erosion control measures must be in place prior to any clearing, grading, or constrUction. These control
measures must be effective to prevent stormwater ronofffrom carrying soil and other pollutants into
surface water or stonn drains that lead to waters of the state. Sand, silt, clay particles, and soil will
damage aquatic habitat and are considered t~ be pollutants.
If this project moves forward, a National Pollution Discharge Elimination System (NPDES) permit
would be required. The owner of a construction site which disturbs five acres or more of to tal 1 and area,
and which has or will have a discharge of stormwater to a surface water or to a stonn sewer, must apply
for coverage under the NPDES and State Waste Discharge General Permit for Stonnwater Discharges
Associated with Construction Activities.
Owners of sites where less than five acres of total land area will be disturbed must also apply if the
construction activity is part of a larger contiguous plan of development or sale in which more than five
acres will eventually be disturbed. Discharge of stormwater from such sites without a permit is a
~
.
~
March 2, 2005
Page 3
violation of federal and state law and the owner will be subject to enforcement action by the Deparbnent
of Ecology or through third party lawsuits.
For construction of subdivisions, the five acre threshold, which triggers the NPDES permit requirement
applies to land that is, disturbed by the land owner, land owner's agent, or by an entity which has obtained
a use agreement (e.g., lease, easement) from the land owner. Include acreage which is disturbed (e.g.,
graded) prior to its sale to independent contractor(s).
A stormwaterpermit application form, referred to as a Notice ofJntent, can be obtained by calling
Ecology's Stonnwater Request Line (360) 407-7156 or Linda Matlock at (360) 407-6437. The NO!
application form is also accessible in electronic form on Department of Ecology's website at:
htto://www.ecv.wa.goV/Drograms/wqlstormwater/construction/#Application
Applicants are encouraged to submit completed forms and publish public notices more than 38 days prior
to the planned start of construction to avoid delays to the project.
If you have any questions or would like to respond to these comments please contact the appropriate
reviewing staff listed above.
Department of Ecology
Southwest Regional Office
In
![~'
11 ~,
TYr~'~ ',(-'\,
C. 'U'
) _J.J "
(AW: 05-0805)
JUL24 2006
JEffERSON COUNTY OeD
cc: Chuck Cline, TCP
Betsy Dickes, WQ
Linda Matlock, WQIHQ
Jeffree Stewart, SEA
Mark Dorsey, Port Ludlow Associates (Applicant)
Lyn Keenan, Reid Middleton, Inc. (Agent)