HomeMy WebLinkAboutExhibit256
JEFFERSON COUNTY
DEPARTMENT OF COMMUNITY DEVELOPMENT
621 Sheridan Street
Port Townsend, WA 98368
AI Scalf, Director
CLOSING ARGUMENT
To:
From:
Phil Olbrecths, Jefferson County Appellant Hearing Examiner
Al Scalf, DCD Director
David Wayne Johnson, Port Ludlow Lead Planner
December 14, 2007 .
Closed Record Appeal of Port Ludlow Major Revision to Resort Plan
Date:
Re:
Jefferson County would like to respectfully re-assert its desire to move forward with this
project. As such, we would like to briefly touch on most of the issues raised as part of
this closed record appeal.
Issues:
Single Familv vs. Multi-familv
The final SEIS, County Staff and Hearing Examiner all agreed that the townhomes are
multi-family (based upon UBC standards) and setbacks for those structures are regulated
under the UBC (Uniform Building Code) as specified under the MPR Code and which
allow a zero foot building setback for garages.
Heron Road
Heron Road was approved for 24 feet on the face of the Plat and areas of that road were
granted a variance to 20 feet by the Jefferson County Commissioners. We would also
like to point out that Appellants have absolutely no proof to support their claim that
Heron Road is inherently unsafe because of County actions, lack of enforcement or
combination thereof.
Condominiums
The Hearing Examiner did not approve any "condos" only "residential units."
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Building Permits/Inspections
(360) 379-4450
Development Review Division
ascalf@co.iefferson.wa.us
Long Range Planning
FAX: (360) 379-4451
Boundary Line Adjustment vs. Plat Alteration
County Staff (based upon the Crispin v. Seattle court case and advice from legal Counsel)
and the Hearing Examiner agreed that the proposal met the criteria for a Boundary Line
Adjustment (BLA) under RCW 58.17.040(6). It would be unconscionable to require a
Plat Alteration of an applicant when a BLA is sufficient.
CC&Rs
Upon advice from legal Counsel, County Staff determined no CC&Rs would be violated
as a result of the BLA. Appellants have legal recourse should they disagree with this
determination.
Resort Amenities
There is no guarantee implied or otherwise of additional Resort Amenities in either the
Development Agreement or the MPR Code. Section 3.90 Resort Plan states, "The Resort
Plan for future development of properties in the MPR-RC/CF zone shall be limited and
shall not exceed the scope of development set forth below and shall include no uses
except those set forth below, unless a major revision is approved (see section 3.905).
Changes to this Resort Plan that decrease the sizes noted below are allowed." In fact, the
MPR limits the scope and scale of the buildout unless a major revision is approved. The
Hearing Examiner recognized that to focus on the Resort Complex as the only area of
resort type amenities was a mistake and risked taking out of context the criteria for a
Master Planned Resort. He states in his decision, "Granted, the geographic scope of the
application falls within the RC/CF area. However, Port Ludlow is the whole
development. The residents identify with the whole of Port Ludlow, including the golf
course, trails, open spaces, architectural design controls, and the various other
recreational features." Other recreational features would be sure to include shoreline
beach access and all the activities that are associated with it.
Level of Detail
Just because the Appellants didn't find the plan level of detail adequate to suit their needs
does not mean that the plans submitted by the applicant were insufficient for County Staff
and the Hearing Examiner to review and approve the proposed revision. Apparently the
Appellant's are under the impression that a project should not be granted approval
without their consent after their review and approval of plans they deem sufficient. As
stated at the hearing, those plans are conceptual. The level of detail demanded by the
Appellants isn't warranted until the building permits are submitted and it would be
inappropriate and financially over burdensome to require anv applicant to submit that
level detail for a resort plan revision with the understanding and likelihood that those
plans may change.
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Stormwater Treatment
Details on how Stormwater shall be treated are submitted at time of building permit
application. The Port Ludlow Drainage District (PLDD) has no jurisdictional authority
over Stormwater treatment; however the County does consult with the PLDD on
Stormwater treatment and issues within its boundaries.
Defacto Rezone
It was stated at the hearing that at least one of the Appellants considers the revision a
rezone. This is in no way a rezone since no new uses were approved that were not
already allowed within the RC/CF zone.
View Blockage
As with the supposed violations of other CC&Rs, view blockage in this case would be a
civil matter. The Hearing Examiner states, "While the view issues are outside of the
Examiner's authority, the parties are encouraged to continue negotiations with the focus
on review of actual building plans prepared at the building permit stage."
Summary:
In his Decision to approve a Major Revision to the Resort Plan, Boundary Line
Adjustment and Shoreline Substantial Development Permit for a Conditional Use permit,
the Hearing Examiner clearly addresses these and other issues. The County agrees with
the Hearing Examiner's Decision.
Conclusion:
The fact that the four Appellants disagree with the Hearing Examiner's Decision after
four days of open record hearing in which they were allowed to testify to the same issues
they have raised in their appeals and to then have those issues addressed by a highly
experienced and competent Hearing Examiner is troublesome and frustrating to County
Staff. Of course, they have a right to appeal. The developer also has the right to develop.
What troubles County Staff is the apparent determination by Appellants to continually
dredge up past grievances combined with issues out of context and not under the
authority of the Examiner and use those issues and grievances to prevent the developer
from proceeding with the Resort buildout. Although Appellants have the right to due
process, Staffviews their justification for excising that right as nothing more than a
"grudge" against the County and the developer - and in fact, their testimony bares
witness to that. The Hearing Examiner states on page 27 of his decision, "One may
quibble about details. One may dwell on past arguments lost. However, the goal of the
proposed revision clearly supports a conclusion that Criterion (e) is met." Do Appellants
have the right to use their right to due process as a weapon against PLA? What about the
rest of the residents of Port Ludlow? Are their rights being addressed by these Appeals?
Appellants for the LMC would like us to believe that they represent all the members in
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their organization, but do they? County staff would like to think that we represent the
rights and interests of all the residents within the Port Ludlow MPR not just those within
the LBV plat, RC zone or LMC. Regardless, Appellants have the burden of proof to
demonstrate that the Hearing Examiner's Decision of February 7,2007 is in error.
Jefferson County respectfully submits that it is not in error.
In conclusion we request that the Appellant Hearing Examiner Approve the Hearing
Examiner Decision of February 7,2007 or Modify the Decision with conditions as he
sees fit to advance the project for the benefit of all the residents of Port Ludlow. To
Remand the decision would be to not only move in the wrong direction, but would
reinforce the notion that due process and appeal of a project based upon grudges can be
used to stall, prevent and ultimately kill a project. And that is not good for anyone.
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