2021.04.19_RZ20-00002_Letter_of_IncompletenessApril 19, 2021
Meredith Cambre
Senior Executive Director
YMCA of Greater Seattle
909 Fourth Avenue
Seattle, WA 98104
RE: Notice of Incomplete Application, Case RZ20-00002
Dear Ms. Cambre:
Thank you for submitting supporting documentation for your application
received on April 5, 2021 to amend the Lewis County Comprehensive Plan and
Zoning Code to redesignate approximately 643 acres from Forest Resource Land
to Master Planned Resort.
The county’s Planning Division staff have completed their second review of your
supporting documentation. Unfortunately, there remains several outstanding
issues detailed in the February 11, 2021 Notice of Incomplete Application that
your project representatives did not include. The county will need this
information before deeming your initial application complete.
Given this proposal may potentially have a significant impact on the
environment and neighboring land uses, Lewis County requires a sufficient level
of information to allow adequate review. That information was not provided in
the initial application materials and the current subsequent submittals.
Responses to questions in the SEPA checklist that delay addressing potential
impacts until a subsequent binding site plan process avoids addressing the
larger concerns of how the request fits into the larger planning context of this
area in Lewis County and how it meets the criteria of a Master Planned Resort
overlay zone. The county finds that your second information submittal did not
completely answer our specific questions for our analysis as well.
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In addition, a complete application for the Master Planned Resort must be
consistent with RCW 36.70A.360. It is important to the county that this proposal
can meet all federal, state, and local regulations, including all elements of the
Lewis County Comprehensive Plan and Lewis County Code Chapter 17.20E.
In our first Notice of Incomplete Application dated February 11, 2021, the county
provided a list of items we needed you to address. I have restated them below
to assist you in providing us the level of detail the county needs to review your
application.
1.In order to continue the review, additional detail and analysis relating to how this project
would provide sewage disposal, water service, fire protection, and emergency services given
current levels of service available in this rural section of the county.1
a)The checklist states on Page 7 that the proposed project will rely on an on-site sewage
disposal system to serve a population of approximately 500 people and cites an initial
feasibility study that the application did not include. Please provide the county with that
study, including information relating to its design.
Staff Response: The “Mineral Lake YMCA Camp Wastewater Memorandum” and
the GeoEngineers letter dated March 23, 2021 were helpful in understanding at
a very high level the siting requirements for large on-site septic system (LOSS) on
this site. However, these reports do not provide enough detail to ascertain a
level of certainty that a LOSS for a project of this magnitude will be consistent
with the critical area goals and policies in the Comprehensive Plan. Mineral
Lake is an important environmental asset to the county and the protection of
groundwater for potable water supply for area property owners is a significant
concern. Our analysis of the application will need specific information that
provides greater detail on the following items:
i. The design, specific type, size, and location of each proposed onsite
sewage system for each phase of the project.
ii. Given the extensive presence of glacial drift soils, please provide
information on the impacts and the potential location of on-site sewage
disposal systems in proximity to camp structures, the lake, wetlands,
streams, and off-site wells used for potable water supply.
1 RCW 36.70A.360(4)(e)
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iii. Phase 3 of the project will depend on a subsurface soil absorption system
(SSAS); with the current amount of information available, we are unable to
evaluate the feasibility of this system for this project.
iv.The assumption that at Phase 3 the camp will generate 45 gpd per person
is a broad generalization that needs further explanation. The submittal
document does not provide detail regarding the similarities or differences
of the proposed Mineral Lake Camp with the Camp Orkila or Camp
Colman examples.
v.The county is unclear as to what fully encompasses the proposed phases
for the camp’s development as described in the final paragraph of page
3 in the Wastewater Memorandum. It describes Phase 3 as adding a
Camp B, but it states that the number of campers and staff will remain
the same as in Phase 2. Please provide a more detailed explanation of
these phases. The memorandum also indicates schematic layouts of the
proposed camp completed by Mithun Architects. Include details of how
the project might occur in each phase. We need more than conceptual
drawings at this phase.
b)The checklist on Page 7 states the project will rely on groundwater from existing wells for
its water system, citing sufficient capacity from an initial feasibility study that the
application did not include. Please submit this study for review.
Staff Response: The submitted memorandum “YMCA: Mineral Lake Pumping Test
Methods and Results” by Matthew Lewis dated March 1, 2021 only provides
general information about the existing well on site. This report does not address
whether this single well has adequate flow for fire suppression or meets drinking
water standards for quality and quantity. There is also no discussion regarding
sufficient water rights from this well to meet the camp’s use or how the
increased draw on this well will affect private wells on other residential properties
in the area.
c)The checklist on Page 16 provides no information relating to how this project will achieve
adequate levels of service for emergency services given current local capacities and the
projected population increase. Please provide additional information that will aid us in
assessing how this project will achieve its anticipated service demand considering
current resources available in the vicinity of Mineral Lake.
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Staff Response: Your second document submission provided no information on
how this project will address adequate levels of service for fire protection and
emergency services given current local capacities and the project population
increase. Your response should also address concerns about how the project
will provide physical access to emergency vehicles such as fire trucks and
pumpers given topography and current road conditions on- and off-site.
2. RCW 36.70A.360(4)(e) requires the designation process to ensure the Master Plan Resort will
be consistent the county’s critical area protection provisions under LCC 17.38. Given that the
checklist states the project intends to rely on an on-site sewage system for a population of
500 people, the county will need analysis as to how the design of this system will or will not
affect Mineral Lake as a fish and wildlife habitat conservation area and any wetlands on the
subject parcel. Furthermore, discussion as to how stormwater during the construction and
operation phases of the proposed Master Plan Resort will protect these aquatic resources.
Staff response: Similar to our concerns previously expressed in this letter about
wastewater treatment, the submitted reports provided insufficient detail on
stormwater containment and treatment on site, especially in regard to the
“natural dispersion” treatment approach mentioned on Page 5 of the
GeoEngineers letter. Furthermore, this letter provides no explanation how it
derived the conclusion that the wastewater and stormwater conceptual
designs will not impact fish and wildlife conservation area, wetlands, or aquifers
for potable water supply.
Due to the sensitivity of Mineral Lake and critical areas, the county requests that
you submit further analysis of the potential impacts associated with this proposal
in relation to the goals and policies relating to critical area protection in the
Lewis County Comprehensive Plan.
3.The checklist on Pages 15 and 16 provides no information relating to how the designation
process will impact Mineral Hill Road, Mineral Road, and SR 7. Please include information
on future traffic generation created by the project; the capacity of these roads to handle
increased traffic; and potential mitigation action necessary to address resulting
transportation deficiencies.
Staff response: The memorandum “Mineral Lake YMCA Camp-Trip Generation
Memo” prepared by SCJ Alliance did not include any information requested
that addressed how the project will impact current road conditions, the road’s
capacity to accommodate increased traffic, or potential mitigation actions
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necessary to address transportation deficiencies other than a left turn lane on SR
7 and/or Mineral Hill Road. The statement that the camp will rely primarily on bus
transportation to get campers to the site given current road conditions also
needs further analysis. Please include these analyses in your next application
submittal.
Finally, it would also be useful to receive a copy of the Kidder Creek Orchard
Camp traffic study for the county to evaluate the similarities of that project with
the YMCA camp proposal.
Final Observations on Submitted Documentation
Please keep in mind that the county is not expecting specific project design at
this point. However, it does need a higher level of information beyond a
conceptual site plan about the proposal to evaluate its impacts within the
context of the goals and policies of the Land Use Element, the Shoreline
Element, the Utilities and Capital Facilities Element, and the Transportation
Element of the Lewis County Comprehensive Plan. A project of this scope within
a rural area of the county necessitates a thorough examination of its affect on
neighboring land uses.
In addition, Lewis County needs a higher level of information to show the
proposal is consistent with Lewis County Code 17.20E Master Planned Resorts.
We recognize the binding site plan is being deferred to a later date, however,
the Master Planned Resort overlay zone cannot be approved without showing
consistency with LCC 17.20E.020 - Designation Criteria for Master Planned
Resorts, LCC 17.20E.040 - Minimum Standards, LCC 17.20E.050 - Master Plan
Approval, and LCC 17.20E.060 - Approved Master Planned Resort.
Finally, the crux to this request focuses on its reasoning as to why this property is
better suited as a Master Planned Resort rather than Forest Resource Land. In
order to do that, we need details showing this site can meet the applicable
federal, state and local policies and regulations mentioned in this letter.
In conclusion, the information requested in this letter is necessary to complete
your application so Lewis County may fully evaluate this proposal. If you do not
submit the requested information within 90 days of the date of this letter, your
application automatically will lapse per Chapter 17.05.070(B)(1) of the Lewis
County Code. You may request in writing two three-month extensions if the
County determines that the required studies or information warrants additional
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time. The county cannot consider financial hardship for any extensions of
deadlines.
If you have any questions on the issues raised in this letter, please call me at your
convenience. My telephone number is (360) 740-2602. You may also reach me
email at brianna.uy@lewiscountywa.gov.
Sincerely,
Brianna Uy
Associate Planner
cc: Dan Penrose, SCJ Alliance
Attached: LCC 17.20E.020
LCC 17.20E.040
17.20E.020 Designation criteria for master planned resorts.
Master planned resorts may be developed as a Type III binding site plan application when:
(1) The comprehensive plan specifically identifies policies to guide the development of master planned resorts;
(2) The comprehensive plan and development regulations include restrictions that preclude new urban or suburban land uses in the vicinity of the master planned resort, except in areas otherwise designated for urban growth under RCW 36.70A.110;
(3) The county includes a finding as a part of the approval process that the land is better suited, and has more long-term importance, for the master planned resort than for the commercial harvesting of timber or agricultural production, if located on land that otherwise would be designated as forest land or agricultural land under RCW 36.70A.170;
(4) The county ensures that the resort plan is consistent with the development regulations established for critical areas; and
(5) On-site and off-site infrastructure and service impacts have been fully considered and
appropriate mitigation measures have been established. [Ord. 1269 §13, 2016; Ord. 1219 §1 (Exh. A), 2010]
17.20E.040 Minimum standards.
The following minimum standards apply to all master planned resorts:
(1) A master planned resort, when approved in accordance with this chapter, is established as an overlay zone and, as such, does not alter the existing, underlying zoning designation. Development standards of this chapter shall, as applied to an approved master planned resort, supersede those of the underlying zone.
(2) Master planned resorts are urban-scale developments located in the rural area.
(3) The resort, including buffers and open space under the control of the development, is sited on a
parcel or parcels of land no less than 40 contiguous acres.
(4) Existing state or county roads are adequate, or need minimal improvements, to serve the development.
(5) Capital facilities, utilities, and services, including those related to sewer, water, stormwater, security, fire suppression, and emergency medical, provided on site shall be limited to meeting the needs of the master planned resort. Such facilities, utilities, and services may be provided to a master planned resort by outside service providers, including municipalities and special purpose districts; provided, that all costs associated with service extensions and capacity increases directly attributable to the master planned resort are fully borne by the resort. A master planned resort and service providers may enter into agreements for shared capital facilities and utilities; provided, that such facilities and utilities serve only the master planned resort or urban growth areas.
(6) At least 40 percent of the total of the site area, shall be dedicated to a mixture of permanent open space, natural areas, and/or active recreational areas, excluding streets and parking areas.
(7) Active recreational uses such as golf courses, pools, tennis courts and playing fields shall be
provided to adequately meet the needs of the residents and guests of the master planned resort.
(8) The maximum density for residential dwellings including hotel and motel units shall not exceed two units per gross acre of the overall master planned resort. Residential dwellings for long-term occupancy shall be limited to no more than 10 percent of the total number of residential units.
(9) Parking shall be provided for in accordance with a transportation management plan as submitted with the application and approved for the project.
(10) The minimum lot area, width, frontage and yard requirements, setback standards, street standards, and building heights otherwise applying to development in the underlying zone(s) may be modified consistent with the master planned resort, as approved in conformance with this chapter.
(11) The tract or tracts of land included in a proposed master planned resort must be in one ownership or control or the subject of a joint application by the owners of all the property included.
(12) All uses within the master planned resort shall be harmonious with each other through the use
of special design, placement, or screening.
(13) Unless otherwise approved in accordance with applicable sign regulations, on-premises signs and off-premises signs shall be designed and erected in conformance with design guidelines, as submitted and approved with the project and off-premises signs shall be limited to those necessary for directional purposes.
(14) Commercial services provided as part of the master planned resort shall be contained within the development and shall be oriented to serve the master planned resort. The protection of public views shall be considered in orienting such commercial services. [Ord. 1269 §13, 2016; Ord. 1219 §1 (Exh. A), 2010]