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29 January, 2009
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Jefferson County Planning Commission
c/o
Department of Community Development, Long Range Planning
621 Sheridan Street
Port Townsend, Washington 98368
CC: Michelle McConnell
Zoa Ann Lamp
RE: Preliminary Draft Shoreline Master Program (PDSMP): Public Comment
Dear Planning Commission,
Thank you for soliciting comments from stakeholders and citizens regarding the proposed
revisions to the Shoreline Master Program, or PDSMP. As you begin to form your
recommendation to the Board of County Commissioners, I hope that you will find this
input useful and will be willing to recommend certain specific modifications to the
document.
I am currently the president of the Beckett Point Fisherman's Club. which was originally
founded in the 1940's by Port Townsend citizens interested in building fishing cottages at
Beckett Point. The community, which includes Beckett Point itself, along with portions of
adjacent shoreline and hillside, is currently comprised of156 leaseholders. Cabins are built
on most of the lots, with several vacant lots interspersed. With the recent construction of
a community septic system, remodeling and new construction is now possible at the
Point.
Given its unique geography and history, Beckett Point is obviously affected by any changes
in the SMP. I have listed a number of general concerns our community has with the
PDSMP that I hope will be addressed in your recommendations to the Board of County
Commissioners. The Beckett Point board has also reviewed the "Side-by-Side" Review
handout from your 1fi/09 meeting, and has addressed these concerns in more detail in a
companion Public Comment letter.
Buffer Zone/Setbacks
We would like to maintain and continue the current development pattern at Beckett Point
This includes a historical setback line, where the row of existing cabins is set back a
consistent distance from the beach. Since this historical line is within current and
proposed SMP buffer zones, we have some concerns about new limitations proposed by
the PDSMP (for a view of Beckett Point, see slide #23 of ESA Adolfson's presentation to
you from December 3,2008).
In the PDSMP. Beckett Point is classified as "Shoreline Residential" (formerly "Suburban
Shoreline"). The preferred use in this zone is Single Family Residential, with a new 150'
buffer from the Ordinary High Water Mark (OHWM), plus a 10' setback. Most of our
existing lots and cabins will fall within the new buffer zone, thus rendering them" non-
conforming." The PDSMP includes a mechanism for allowing construction on non-
conforming lots if the lot was created before 1976, if construction is a minimum of 30'
from OHWM, and if string-lines between neighboring houses are used to determine
setbacks.
Since it seems odd to designate a thin piece of developed land as "Shoreline Residential",
with single family residential as a preferred use, then overlay a buffer zone that disallows
single family residential construction, then add a mechanism to allow residential
construction, we would prefer to simply have the buffer zone waived at Beckett Point
If the buffer zone cannot be waived, then allowances must be made for new and
remodeled cabins to be built to the consistent, historical setback line that is recorded on
the plat in lieu of the 30' minimum from OHWM and in lieu of the string line between
adjacent houses. It is also critical to establish that these were legal lots in existence well
before 1976, even though they were officially platted in 2008. Please refer to the detailed
Public Comment companion letter for specifics.
Bulkheads
Beckett Point depends on a continuous bulkhead (a type of "structural shore armoring" per
PDSMP definitions) in order to protect individual existing cabins and the point as a whole.
In cases where existing bulkheads need to be replaced, or where there are gaps in the
existing system, we would like to maintain the option to construct new bulkheads.
It appears that the PDSMP Article 7.7.C will allow existing bulkheads to be replaced.
Article 7.7.D suggests that existing bulkheads on lots with no development should be
removed. We assume that this would not be appropriate when removal would endanger
adjacent cabins. Please refer to the detailed Public Comment companion letter for
specifics.
General
In several locations within the PDSMP, there are provisions that if strictly interpreted,
could disallow any future development at Beckett Point. Here is one example:
Article 8, C.2. The following types of residential development shall be prohibited:
i. Developments that can be reasonably expected to require structural shore armoring
during the useful life of the structure or one hundred (100) years, whichever is greater.
RECEIVED
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It is critical to confirm that the intent of the document is not to disallow development
within a well-established existing community of cabins, and that future interpretation by
Jefferson County DCD will follow accordingly.
Conclusion
Thanks again for considering public comment. I realize that this is a major undertaking and
hope that you will be able to take our concerns into account in generating a comprehensive
revised Shoreline Management Plan.
Sincerely,
yd:-
John Kennedy
President, Beckett Point Fisherman's Club
RECEIVED
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