2021.02.11_RZ20-00002_Letter_of_Incompleteness.doc
February 11, 2021
Meredith Cambre
Senior Executive Director
YMCA of Greater Seattle
909 Fourth Avenue
Seattle, WA 98104
RE: RZ20-00002
Dear Ms. Cambre:
Thank you for submitting your application on January 19, 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 initial review of your application,
including the information provided in the SEPA checklist. Before the county can deem your
application complete, several outstanding issues detailed below must be submitted.1
For example, the SEPA checklist maintains that the project will answer all of these outstanding
issues during a subsequent binding site plan application. I understand you believe these items
could be relegated to a subsequent process, however a complete application for the Master
Planned Resort must be consistent with RCW 36.70A.360.
If the application cannot show that it is consistent with RCW 36.70A.360(2) and (4), then the
county would be unable to include a finding that as a part of the approval process, “…the land is
better suited, and has more long-term importance, for the master planned resort than for the
commercial harvesting of timber…, if located on land that otherwise would be designated as
forestland or agricultural land under RCW 36.70A.170.”2
Therefore, please specifically address the following issues to complete your application:
1 See LCC 17.05.070(1)(b) and (2)
2 RCW 36.70A.360(4)(c)
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.3
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.
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.
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.
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.
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.
If the requested information is not submitted within 90 days of the date of this letter, your
application will automatically lapse per Chapter 17.05.070(B)(1) Lewis County Code and will not
be processed. You may request in writing up to two three-month extensions if the County
3 RCW 36.70A.360(4)(e)
determines that the required studies or information warrants additional time. The county
cannot consider financial hardship for any extensions of deadlines.
Given that there is an intrinsic link between this application and a future binding site plan
application, an alternative approach you may wish to consider is to take advantage of the
provisions under Section 17.05.100 LCC for the consolidation of project permit applications. If
you wish to discuss the advantages and disadvantages of this approach, please feel free to
contact me.
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