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PLDD
Port Ludlow Drainaf!e District. Post Office Box 65261. Port Ludlow. 98365 W A
October 23,2006
RE(~E I\rJE:
OCT 2 3 zaos
JEffERSON &OUNlY OeD
Ms. Barbara Nightingale
Department of Community Development
Jefferson County
621 Sheridan Street
Port Townsend, W A 98368
SUBJECT: REVIEW OF REVISIONS TO BINDING SITE APPLICATION;EQR,"
MASTER LAND USE APPLICATION (MLA) 05-00029
Dear Ms. Nightingale:
The Port Ludlow Drainage District has reviewed the materials submitted for Ludlow Cove
Division II. The submittal included the Master Land Use Application dated May 6,2005,
Binding Site Plan Application dated May 6, 2005, Subdivision Review Application dated May 6,
2005, SEPA checklist dated May 6,2005, and plan sheets 1-5 of 5 of the Preliminary Binding
Site Plan for Ludlow Cove Division 2 prepared by Reid Middleton dated May 2005. Additional
materials have been submitted since the remand by appellate hearing examiner John Galt. The
items available from Jefferson County's website include: Suggested Amendment to
Develooment Agreement dated May 17, 2006; Shoreline Permit Application dated
June 7, 2006; and DCD Staff Reoort dated September 13, 2006.
This is the first step in the review process and is not intended to have detailed construction plans.
Those will be reviewed for the additional permits that are identified in the SEP A checklist
(Section A.1 0), specifically clearing and grading and construction Plan approval.
The District provided comments in letters dated June, 30, 2005 and February 28, 2005, on the
previously submitted application packet dated January 13, 2005. Previous comments will be
reiterated where necessary and this letter is intended as a stand-alone document. The following
are the District's comments on the submittal:
1. The Port Ludlow Drainage District is a public agency duly formed under
RCW 85.38 with SEP A authority and environmental expertise for surface
water and drainage issues within the District. The District includes Ludlow
Cove Division II. The District should have been included in the notices listed
on page 5 of the Jefferson County Department of Community Development
Staff Report. Notice to SEP A agencies is required by RCW.
2. Ludlow Cove Division 2 area described in the application lies entirely within
the boundaries of the PLDD.
3. Jefferson County and the PLDD have adopted the 2001 Washington State
Department of Ecology (WSDOE) Stormwater Management Manual for
Western Washington (2001 DOE Manual). The proposal must meet all
applicable requirements at the time of application. Therefrb~i_t1y
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adopted Stormwater Management Manual should be used for stormwater
management. The PLDD will not accept any responsibility for facilities not in
strict compliance with the 2001 DOE Manual.
The applicant and Jefferson County continue to reference Ordinance #10-
1104-96 "Stormwater Management Ordinance" as the appropriate regulation
for stormwater management. This Ordinance references the 1992 (as revised)
Stormwater Management Manual for the Puget Sound Basin. While Jefferson
County's interpretation may be true from a legal standpoint, it makes little or
no sense from a practical standpoint.
The applicant and Jefferson County acknowledge the need for compliance
with the Shoreline Management Act and requirements from the Washington
State Department ofFish & Wildlife Hydraulic Project Approval for the
proposal. Both of those agencies will require, as a condition of those permits,
compliance with the current WSDOE manual.
In addition, compliance with the current WSDOE manual places no greater
requirements on this proposal than the 1992 DOE manual. The location of
this proposal exempts it from flow control (detention) requirements as long as
downstream conveyance facilities are adequately sized. In fact, if a strict
reading ofthe manuals is made, the current WSDOE manual allows more
flexibility, particularly in the area of water quality treatment, than the 1992
DOE manual allows.
An example of this is the use of technology based treatment methods to meet
basic water quality requirements (as required in either manual). In the current
manual, several technologies are approved for use as basic treatment, as are
additional "traditional" treatment methods, which are not found in the 1992
Manual. In fact if the applicant were to propose use of say a filter system, or
continuous inflow bioswale, an exception from the 1992 DOE manual would
need to be obtained, a fairly onerous process which involves public
involvement, notice, hearings, findings of fact, special circumstances, etc.
(See Section 1-2.16, 1992 DOE Manual).
With this in mind, the Port Ludlow Drainage District urges the applicant to
comply with the current state adopted standards from the outset (since they
will have to anyway) and make the reviewing consistent between all
permitting agencies.
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 infiltration of stormwater. Separation of directly connected
impervious areas and bio-retention should be utilized to the maximum extent
practical. LOG ITEM
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State Environmental Policy Act (SEP A) Checklist
1. Section A.10 lists a National Pollution Discharge Elimination System (NPDES) permit as
required for the project. The Washington State Department of Ecology (WSDOE)
administers this permit. A fact sheet is available on the WSDOE website
http://www.ecy.wa.gov/programs/wq/stormwater/construction!cnst_fact_fm.pdf.This
fact sheet reads, in part, "The pollutant control, inspections, and compliance with
standards provisions of this permit include specific requirements as well as references to
Ecology's Stormwater Management Manual (SWMM)." The current WSDOE SWMM
is the February 2005 Stormwater Management Manual for Western Washington. The
project must comply with the 2005 WSDOE Manual to meet the NPDES permit
requirements. The SEP A checklist references the 1994 WSDOE Manual.
2. Section B.1.c references a geotechnical report as included in the submittal packet. No
report was included in our submittal packet. On June 28, 2005, Port Ludlow Drainage
District staff reviewed the public information on file with Jefferson County Department
of Community Development. No geotechnical report is listed in the SUB05-0004
Ludlow Cove 2 log and no geotechnical information is available in the file. We request a
copy of the geotechnical report for review.
3. Section B.3.a.2 references a storm drainage outfall to a type 5 stream. Discharge to a
type 5 stream will require a Hydraulic Project Approval from the Washington
Department ofFish and Wildlife (WDFW). This permit is noted in the SEPA checklist
but the JARPA application does not include submittals to WDFW.
4. Section B.3.a.6 and Section B.3.c.2 should provide additional detail. Waste materials
typical of urban residential stormwater runoff are anticipated. Pollutants include
increased levels of metals, oils and grease, nutrients, and sediment.
5. Section B.3.d states compliance with the 1992 Stormwater Management Manual for
Puget Sound Basin as revised 1994 (1992 DOE Manual). Since an HP A is required for
the project compliance with the 2001 Stormwater Management Manual for Western
Washington (2005 DOE Manual) will be required as a condition ofthe WDFW permit.
Jefferson County UDC includes the 2001 DOE Manual. This project should comply with
the 2005 DOE Manual due to NPDES requirements listed above. Prior to fmal plat
approval and construction, the applicant shall obtain a letter from the Port Ludlow
Drainage District accepting responsibility for the storm drainage facilities and
concurrence that the facilities are designed in accordance with the Jefferson County
UDC.
6. Section B.5.b should also include marbled murrlets as threatened or endangered species
known to be on or near the site.
Plansheet Review
1. Sheet 1 - The wetland buffer is not identified on the plans.
Sheet 2 - It is unclear how the storm system will function. The bio- filtration swales do
not appear to be connected to the storm system. The topographic contours show the
easternmost bioswale flowing uphill. We recommend an oiVwater separator be installed
at the two downstream parking lot/road drainage system before entering into the
treatment system.
2. The Port Ludlow Drainage District anticipates that the applicant will obtain a letter from
the District accepting responsibility for operations and maintenance and that the facilities
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have been designed and constructed in compliance with applicable codes and regulations
prior to final plat.
3. No easements are shown for access to the drainage facilities. Easements shall be required
for access to all drainage facilities maintained and operated by the Port Ludlow Drainage
District.
The District appreciates the opportunity to provide comments on the drainage aspects of the
project. If you have questions or need additional information, please contact the undersigned
below.
Sincerely,
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Richard Regan, P .E.
Commissioner, Chairman
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Barbara Nightingale
From: R.P.Regan [rregan@olypen.com]
Sent: Monday, October 23,200610:27 PM
To: Barbara Nightingale
Subject: PLDD Comments on Ludlow Cove II Trendwest
Barbara: Attached are the PLDD revised comments on subject project. If you require a hard copy from
the PLDD please let me know right away and I will deliver it to you.----- Thanks
Dick
R.P. Regan P .E.
Commissioner PLDD
Phone # 360-437-5153
Cell # 360-301-0755
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