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January.29, 2009
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Jefferson County Planning Commission
Department of Community Development
621 Sheridan
Port Townsend 98368
Regarding: SMP Update
Greetings,
Jefferson County's present Shorelines Master Program carries the date of
1989, but much of it is unchanged from the County's original SMP which
was adopted shortly after the Shorelines Management Act was passed in
1972. Thus, the Program currently incorporated in the UDC is essentially
the same as the one which guided my review of permit applications and
occasional Program amendments in the approximately ten years I was a
member of the Shorelines Commission during the 1980's and into the
1990's. Even then, some elements of the Program were clearly out of
date.
While I was unable to participate in the lengthy and thorough public
process which has brought the current draft before us, I have followed it
from its inception, thanks to the frequent on-line updates. provided by the
OCD. I doubt that there has ever been in the history of Jefferson County
a more detailed, open, inclusive, and accessible effort in the realm of land
use and resource planning. County staff, the consulting team, and, in
particular, the members of the citizen advisory committees, are to be
commended for their dedication and for the quality of their work.
This draft, if adopted today without changes, would be a significant
improvement over the Program now in place. From the perspective of
those who wish to develop property along the shoreline, its clarity and
specificity would aid in the design of their projects. From the standpoint
of the protection of the public interest, as found in the natural resources
of our County, both those which we utilize and those which we do not,
this document is exemplary. I find. it to be balanced and reasonable.
I will comment upon this draft and comment in greater detail at the public
hearing which you will hold at the conclusion of your review. At this
time, I offer the following specific comments:
1. I applaud the prohibition of net pens. When I was a member of the
Shorelines Commission, the policy of the State of Washington was to
encourage net pens, making it impossible then for Jefferson County to
prohibit them. The many problems caused by net pens in British Columbia
and elsewhere demonstrate the wisdom the the proposed prohibition. At
the same time, however, I support the encouragement given in the draft
to other forms of aquatic and intertidal aquaculture.
2. Within the stated goals in the draft, I read of many uses that are
referred to as "preferred", language which is carried over from the
present SMP. This notion of "preferred" has always been troublesome
because the County reviews permit applications individually, not in
competition with other applications. To the extent that "preferred"
guides the development of policies and regulations, it may be a useful
construct, but I suggest that "encouraged" or "fostered" are more
suitable in this context.
3. I am troubled by the exemption of residential bulkheads and some
residential docks from permit requirements, although I recognize that
their development still must be in accord with the goals, policies, and
regulations of the Program. These uses are simply too intrusive upon the
aesthetics of the shoreline and too threatening of ecological functions to
be allowed without the scrutiny which a permit ,application and review
entails.
4. While the length of docks associated with residences is limited to sixty
feet, the administrator may, at his or her discretion, permit longer
structures in order to "Reach adequate depths to accommodate
watercraft". This is a loophole long enough to moor the Queen Mary.
recommend that a maximum length be specified. There are several
intertidal areas in the county which are so shallow of slope that even a
dock several hundred feet in length would be dry at a zero tide and,
therefore, insufficient for mooring a dinghy.
5. I am particularily troubled by the allowance of mining anywhere within
the 200 foot shoreline jurisdiction, even as a conditional use. In this
county, "mining" means gravel extraction, which cannot be accomplished
without destruction of the vegetation which stablilizes shoreline areas.
There are sufficient gravel resources in Jefferson County outside of
shoreline areas to allow gravel adjacent to shorelines to be left in place.
6. I consider the expanded buffers for the various indicated uses to be
manageable, especially in light of procedures for buffer averaging and the
optional CASP procedure.
7. I am pleased to see the elimination of "Secondary Uses" from the use
matrix and from the list of definitions. Permitted, Conditional, and
Prohibited categories simplify both applying for permits and for their
review.
8. Water-oriented commercial development is listed as a conditional use
in the Conservancy Designation and as a permitted use in the Residential
Designation. I questions whether these c1assfications are in agreement
with the Comprehensive Plan, which limits all commercial development to
very specific areas within the County. The same holds for the
classification of non-water-oriented commercial development as a
conditional use in the Residential Classification.
9. I applaud the following statement and welcome its inclusion in the
SMP: "All shoreline use and development, including preferred uses and
uses that are exempt from permit requirements, shall be located,
designed, constructed, conducted, and maintained in a manner that
maintains shoreline ecological processes and functions." (Article 6, B1)
I believe without reservation that we must allow no further deterioration
of the resources which we appreciate and upon which we and our
children depend.
Best regards,
G=e; ,
Phil Andrus
POB 261
Chimacum 98325