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January 26, 2009
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TO:
Planning Commission
621 Sheridan Street
Port Townsend, WA. 98368
FROM:
Beckett Point Fishermens Club
890 Beckett Point Road
Port Townsend, WA. 98368
RE:
DCD-SMP PROPOSAL FOR REVIEW
Beckett Point is a historic non-profit corporation of 156 individual leaseholders managing
86 acres of residential use property in Jefferson County. In 2008, we completed a Large
On-Site Septic system to mitigate potential failing individual systems on Beckett Point
spit in Discovery Bay.
As part of this process and in order to become a legal conforming entity within Jefferson
County, we were required to develop and record an Assessor's Plat. This was adopted
an9- approved by the County on June 26, 2008. Imbedded in the Assessor's plat is the
historic house setback from the water. Also, the line of the flood control bulkhead is
established.
In the process of reviewing the proposed updates to the SMP, we find it does not consider
our conditions and leaves out the sustainability of our residential community by virtue of
at least the following items:
1. (Section 2 SMP, Subsection 5, Shoreline Residential) Our characteristics and density
are not included and we should be included as plated (ref. Assessor's Plat 6/26/08). By
not being included in the shoreline use as a legally included density with in the Shoreline
Residential designation much of the regulations becomes difficult or impossible for us to
interpret.
2. (Section 5.160 Residential Development) If the shoreline setback is moved from 30-ft
to either 100-ft or 150-ft, it should be done ONLY for new land development that occurs
after the date of the implementation of the SMP. The previously agreed upon Assessors
Plat lots for Beckett Point should be honored in perpetuity under the 30-ft setback.
3. (Section 5.160) Historically at Beckett Point, the wetland depicted on our adopted
Assessor's Plat was a natural egress waterway connected at high tide by small channels to
the south/north. These channels were cut offby county road construction. In order to
restore this wetland as desired by Beckett Point, new channels are needed and the 150-ft
..
(2)
setbacks on each side would preclude this being done. Use of fixed numbers on this type
of setback is inappropriate.
4. (Section 5.160/8.8, Residential Development) In like manner, we have an agreement to
build/remodel on the spit that meets FEMA flood control standards. The ability to
build/re-build should be grandfathered in using the adopted Assessor's Plat so that action
needs only to meet FEMA standards. The flood control measures used by Beckett Point
as shown by adopted Assessor's Plat, should be honored independent of SMP rules.
5. (Section 5.180 Shore Defense) Beckett Point objects to the use of "imminent danger"
as a standard for structural armoring where historic cyclical storm patterns exist and
foresight and planning could be used to better advantage.
6. (Section JCCI8.20.260, Non-conforming Use) Beckett Point, due to our recent
experience with SPAADs, Department of Ecology, Department of Archaeology, Fish and
Wildlife, Native Tribes and county regulations we feel that a two year period is
insufficient to meet these requirements. The 5-year standard as used in the application of
SPAAD's is appropriate.
In summary, Beckett Point has completed an exhaustive process of building an
environmentally safe septic system. This process included the time-consuming
requirements to adopt an Assessor's Plat, and become an acceptable entity with in
Jefferson County. We believe that those negotiations should be honored.
In general, Rules should not be applied in a retroactive way to legally approved
Assessor's Plats.
Sincerely,
Patti Sahlinger, Secretary
John Kennedy, President
Ed Edwards, Trustee
Jean Camfield, Trustee
Keith Hansen, Past President
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