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HomeMy WebLinkAboutNotification of Incomplete Applications - OT General - 6/6/2006 r MASON COUNTY DEPARTMENT OF COMMUNITY DEVELOPMENT Planning Mason County Bldg.1 411 N.5th P.O.Box 279 Shelton,WA 98584 (360) 427-9670 Belfair (360) 275-4467 Elma (360) 482-5269 Seattle (206) 464-6968 Date: February 6, 2002 To: Barbara Anderson, Collins Woerman From: Pam Bennett-Cumming, Senior Planner RE: Letter of incompleteness for Alderbrook hm/SR106 project NOTIFICATION OF INCOMPLETE APPLICATIONS - ALDERBROOK INN/SR 106 RELOCATION You have submitted permit applications for proposed construction or development in the county. Upon review of your applications we have determined that the contents of the applications are incomplete or do not provide enough detail for review. Therefore, review of your applications will not proceed until the necessary information is provided (see this letter for details). Once the information is submitted we will continue review of your applications accordingly. Submitted documents Thus far we have received several documents related to your planning applications submittal. The documents and their status are shown in the table below: Permit application Permit no. Status Shoreline Substantial Development SHR 2003-00005 Incomplete Conditional Use Variance application Mason Environmental Permit MEP 2003-00004 Incomplete Special Use Permit DDR 2003-00005 Incomplete Other submitted documents Owner authorizations n/a Incomplete SEPA checklist and supporting SEP2003-00012 Incomplete documents OWNER AUTHORIZATIONS The owner authorizations for the permit application process appear incomplete based on your supplied ownership map. Missing: • Kevin Supple • Elizabeth Armintrout • Rebekah Dalby 1 In addition, many-of the exhibits referred to in the authorizations are missing(e.g. property descriptions, or road alignments). Gates has given Carletti power or attorney, but it appears to be for the short road alignment, not the longer one submitted. ENVIRONMENTAL CHECKLIST & SUPPORTING DOCUMENTS Other county department review: Your SEPA checklist submittal documents are currently under internal review by other applicable Mason County departments as well as planning. In the interest of providing you with as timely as possible review related to planning documents, the following information is provided to you in the interim based on planning staff s review. We will forward comments from other county departments as soon as humanly possible. Department of Transportation Olympic Region senior reviewer Larry Anderson has requested and received a copy for DOT internal review. They will forward their comments to the County. As staff discussed with Dan Foltz who concurred, they have requested that their comments are turned in to us by February 28, 2003. Planning review to date: You have submitted a substantial package with extensive supporting documents. The comments below are intended to be constructive and aid you in achieving a complete package at the soonest time possible. We understand from you that timing for this project is tight given the scope and the construction season. In general: FYI there appear to be some inconsistencies between the various documents or subsections within the SEPA packet—relative to the project descriptions, whether things will be rebuilt after demolition, which critical areas (e.g. streams) will or will not be affected, types and locations of stream crossings and other modifications, other streams affected and how. Road realignment activity: This is a large project involving the movement of a large quantity of material, and regrading of the area. There is lots of information on final treatment of the site, revegetation, stormwater, stream restoration etc. How will environmental impact of the road project during construction be avoided? From the information provided, it is not yet clear whether the environmental impact from the extensive activity involved in road realignment will be mitigated both during and post- project. At the beginning of each subsection of the SEPA document, add a list of maps, figures etc. and clarify their location within the corresponding text. The msp/plan numbering varies based on their original source, this might avoid some confusion. Within the document when a figure is referenced, say where to find it. There are some really excellent maps, plans etc. Highway 106 relocation—earlier we had discussed the importance of providing an alternatives evaluation for the road relocation, showing why the chosen alignment had the least impact environmentally. This does not appear to be explicit within the SEPA. It 2 r should go here and within the Mason Environmental Permit application(consistency with 17.01.110.G.I.i). Streams: clearly the project outcome will have an extremely positive impact on both Dalby Creek and Alderbrook Creek because of improved fish passage, restoration and enhancement of the riparian area of Alderbrook Creek. It's unclear however how other streams in the road alignment will or will not be affected, and how impact to all streams will be mitigated during construction. This should be included in the HMP as well. Wetlands in road realignment footprint: As currently represented in the SEPA documents, no mitigation for wetland impact is proposed, however the wetlands are of jurisdictional size under Wetlands chapter 17.01.070 of the Resource Ordinance because they are each Category III wetlands which are greater than 2,500sq ft. Based on staff s conversation with CW project manager Barbara Anderson, we understand you are currently working on developing a wetland mitigation plan, and that part of the mitigation may include some wetland areas related to the proposed stream restoration. The SEPA document indicates no change to septic/sewer systems, yet it appears from discussion with N 40 representatives this week that two septic systems will be decommissioned (contact Environmental Health for info), and the residences hooked to the sewer system. Noted within the SEPA document: A.10 did not list Boundary Line Adjustments A.11 This description of the existing and proposed project in the actual checklist is good —gives the reader an overview of the proposal. It would be helpful to add a little more detail such as before and after total sq ft, and before and after footprint sq ft information here. Alderbrook Inn parcels and Gates parcel(s) are referenced as being included in the project. The project actually covers substantially more parcels because the road realignment is part of the project. All project parcels should be listed (old and new alignment of SR106). B.Lg Would a table here aid the reader in understanding the imperviousness "before"and "after"? B.Lh references King County Stormwater manual—also ref d in other parts of the document. Is this intentional? B.3.a.1) Stream typing has not been included. All streams affected by the project need to be addressed (Big Bend Creek, other type 5 streams). Address wetland mitigation. B.3.a.2 This table is a great help in understanding the before/after configuration. It needs a heading, and if this is footprint sq ft, then indicate so. If not already included (where?) 3 l the portion of covered walkways in the buffer could also be listed. Eastwood&pool on- site box needs completing. B.8.a indicates the building sq ft and room count will increase slightly. Elsewhere in the document it is stated that the footprint will reduce and room count will decrease. (e.g. B.10.c 96 to 90 room count; B.3.c- stormwater section: "hotel design based on a reduced footprint"). See also table for parking below which says 98 keys. B.8.h. Hood Canal, all streams, wetlands and slopes over 15% are considered environmentally sensitive. B.14.c Parking As proposed the parking appears inconsistent with the parking ordinance. Based on 98 rooms (is this the accurate count?) 98 spaces would be needed. For the balance of the uses it looks as though you have (correctly) drawn from Section 9.06 of the parking ordinance which addresses clustered uses. Therefore the Meeting, Rest/Bar& Spa at a total of 12,478 sq ft would need 69 spaces (rounded). Parkin Use Parking spaces 98 rooms 98 12,478 sq ft Meeting, Rest/Bar, Spa at 5.5 69 (rounded) spaces per 1,000 sq ft Total 167 Handicap spaces at 1 per 50 4* *we are getting clarification as to whether the HC spaces are inclusive or in addition Based on the above formula, additional staff parking is not required, because it is figured into the formula. PERMIT APPLICATIONS For to each permit application submitted: Each permit application needs to stand on its own for review purposes. Right now most of the descriptive detail of the project is only contained in the SEPA checklist. The individual permit application must stand alone in terms of representing the project through both written narratives and plans, maps and other supporting documentation— both for County review, and for any outside readers who are reviewing with no advance knowledge of your project. The above information is listed once here but applies and needs to be supplied for each of the individual permits listed below. Since your permit applications does not contain enough detail to understand your project, staff drew from a secondary document(your SEPA checklist and attached supporting materials)to develop a greater understanding of your project detail. Therefore please be aware that Mason County may need to revise the incompleteness information below as your SEPA documents, applications and proposal are revised, and we learn more about the project specifics accordingly. 4 r MASON ENVIRONMENTAL PERMIT The submitted Mason Environmental Permit(MEP) development description gives a one- paragraph general overview of the Alderbrook project, but does not give any further information about activities in critical areas that require permit review. Because an environmental permit is granted for specific activities, the application materials themselves need to be in enough detail for both Mason County and any outside readers to understand both what a given permit request is for, and subsequently what activities are allowed under a permit when it is issued. Detailed narratives.and supporting maps/plans need to be provided for all the MEP required activities that will occur within streams &buffers, wetlands &buffers, the shoreline buffer, on steep slopes, and any other critical areas as provided by the Mason County Resource Ordinance. Thus far it appears that permit required activities which need to be addressed in your MEP application include the items listed below. In each case the project narrative and supporting plans, cross-sections and other documents need to be in enough detail that the project to be permitted is understandable, and consistent with the applicable chapter provisions. Note that the activities in a Fish and Wildlife Conservation Area or buffer require a Habitat Management Plan. • Forest practice conversion, grading, land clearing(including road construction) are MEP required uses. (Mason County Landslide Hazard Area Chapter 17.01.100.C.2., Fish and Wildlife Habitat Conservation Area Chapter 17.01.110). • A project-specific geotechnical report is also required for these activities on slopes or their buffers, which evaluates the site, and addresses site treatment both during and post-construction including drainage, stormwater control and revegetation. A geotech report was included in the SEPA submittal. The report will be reviewed for consistency with the provisions of Chapter 17.01.100.E.5 and applicability to the project. • Stream relocation(s): in each case show consistency Mason County Resource Ordinance Fish and Wildlife (F&W) Chapter 17.01.110.G.1.d. • Stream restoration(see above citation) • Highway 106 relocation in stream buffer—show consistency with 17.01.110.G.Li. • Proposed access road in buffer serving Dalby parcels (same consistency) • Utilities—are any utilities proposed or to be modified in F&W buffers? If so please include. • Stream crossings—application materials and project information must show consistency with 17.01.110.G.2.a. Will any stream crossings be removed? if so include in permit appl. • Wetlands—impact of road,proposed wetland mitigation per Wetland Chapter 17.01.070. Structure footprint replacement in F&W buffer—questions and information: Fish and Wildlife Chapter 17.01.110.F.1. provides that remodel, repair, change of use or reconstruction of an existing building within its existing footprint plus or minus ten percent does not require an MEP. These activities are reviewed by the planning to 5 determine consistency with the applicable provision. For such activities(e.g. applicable replacement or expansion of Alderbrook buildings), show how the project is consistent -- provide a narrative and supporting information as to why these are not permit required activities. (Narrative, table of footprint comparisons, site plan overlays etc.) • Same footprint reconstruction (plus or minus 10%)—in each case provide footprint before and after sq.ft. for comparison. • If greater than 10% increase then please discuss with planning staff -- in that case you will need to look at the provisions of F&W chapter 17.01.110.D.3 Provision for Decreasing Buffer which requires a public hearing and concurrence of the same tribal and government agencies who will review the HMP. In this case your HMP would need to explicitly support the request. • A deck is shown projecting from the northeast corner of the main building. In a very early meeting this was discussed with North 40 in general terms relative to the Shoreline Master Program. In later discussion with you, staff understood the deck would be taken out of the project because of potential inconsistency with the later revisions to the F&W chapter. Is this deck within the 10%? Is it at least 75ft from the shoreline? If so a concrete deck at grade is possible because it is not considered a"structure"under the Resource Ordinance. Parking area & old road modified within the stream buffer: Parking moved further away from stream—show how this configuration has less impact, i.e. because its moving away from the stream, and how sq ft of parking in the buffer will decrease—show old vs. new footprint in stream buffer and provide sq ft differences. That information is needed so we can determine whether there is additional parking footprint within the buffer, the same, or less footprint (the last being preferred, and most consistent with F&W chapter). Also indicate where some parking area in buffer replaced by stream and riparian area restoration, and some road footprint near stream removed. SHORELINE SUBSTANTIAL DEVELOPMENT CONDITIONAL USE VARIANCE The submitted Shoreline Permit development description gives a one-paragraph general overview of the Alderbrook project, but does not give any further information about activities in critical areas that require permit review. Because a shoreline permit is granted for specific activities, the application materials themselves need to be in enough detail for both Mason County and any outside readers to understand both what a given permit request is for, and subsequently what activities are allowed under a permit when it is issued. Your shoreline permit application materials need to be in enough detail that the reader can completely understand the project from the submitted materials. There should be a detailed project narrative with supporting plans, maps etc for the work in shoreline jurisdiction. This includes Inn demolition &construction, portions of road within shoreline jurisdiction, site preparation, grading, landscaping, stream restoration and any other work within shoreline jurisdiction. 6 Note: in the area where the fire lane will replace an existing access road, and within the 50ft Shoreline Master Program buffer, show that grasscrete surface is proposed(per earlier meeting with North 40,planning staff and Dept of Ecology shorelines)to mitigate for road in buffer. Since this is existing it doesn't need a variance, but should be shown. Your project requires a Substantial Development permit because your value is greater than $5,000.00. We received a completed shoreline permit application, but its project description is not concrete enough for a reviewer to understand what they would be reviewing on the application. Review as a Conditional Use is required because this is a commercial development within 200ft of the shoreline. You have submitted a conditional use narrative. Review as a Variance is required for portions of the Alderbrook Inn project which are inconsistent with the Shoreline Master Program, i.e. greater than 35ft in height within 200 ft of the shoreline. You have not submitted a variance narrative. We received a blank variance form faxed to us together with your submittal of the Conditional Use narrative (!). The variance request narrative should clearly indicate why each part of the variance request meets the criteria of the variance chapter(see your copy of variance form). We understand that your additional roof profile on the main building increases the height of an already pre-existing non-conforming structure which predates the Shoreline Management Act, and that in your revised application you propose arguments explaining the importance of replacing your flat roof with a sloped roof for maintenance. Will other areas be greater than 35ft in height? If so they should be included in any variance request. From the plans which show the extent of shoreline jurisdiction in relation to the "replacement" lanai guest rooms area, it is not clear whether the 200ft jurisdiction ends before that building reaches 35ft or not. Also, the dotted line which denotes the 200ft mark does not appear to exactly reflect the shoreline. In your shoreline permit applications,please clarify if any of this new section of construction will exceed the 35ft height mark in shoreline jurisdiction. As you are aware from our earlier discussions, a variance for new construction over 35ft will be the more difficult of the two (vs. existing nonconforming structure which predates the Shoreline Management Act). While some of the overlap between what is reviewed under the MEP and the Shoreline permit may seem duplicative (e.g. stream crossings &restoration in shoreline jurisdiction), this is because there is overlapping jurisdiction between the two sets of regulations each with their own permit process. SPECIAL USE PERMIT We have received your faxed SUP application. Please mail the original with the original signature. You had some questions relating to the narrative questions for the permit—the following is to clarify the intent of the questions, and your replies (use the same numbers as the questions). 7 I First, address why you are applying for the SUP—because the proposed structure size is greater than 5,000 sq ft, and because the proposed building height is greater than 35ft. Then in the case of each question address why these two requests are consistent with the issue raised in the question. Provide supporting maps/plans. HABITAT MANAGEMENT PLAN You are developing a single Habitat Management Plan for your entire project. As well as addressing how the site will be treated after the development is completed, your HMP needs to address how environmental impact of the actual road and other development activities will be mitigated and/or avoided during construction. Impact to other streams affected by the road footprint, and mitigation, should be included. We understand you are currently working on developing some wetland mitigation, this should be included. Ensure that the described stream crossings and restoration are consistent with those proposed. We understand from Pat McCullough that there may be some proposed changes (open bottom culvert to bridge). Project description addresses demolition of Lanai buildings, not what will replace them. Where is the analysis of the effects of the project on existing fish and wildlife species and their habitat during project construction? Figures 84A and 8-113 are not there. Include the stream restoration design/plan as part of the HMP. Will land be held in open space? That was referenced elsewhere... The version of the wetland inventory in the HMP appears to be an earlier draft. It should be the final. WETLAND REPORT Puget Sound is referenced several times instead of Hood Canal. ENGINEERED STORMWATER PLAN Required for project. Must address site treatment during development activities as well as post-development. GEOTECHNICAL REPORT Submitted. To be reviewed by our engineer. 8