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Michelle McConnell
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Jerry & Luanne Mills Ualamills@comcast.net]
Friday, January 30, 2009 2:52 PM
Michelle McConnell
SMP Comments
SMP Comments. doc
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Hi Michelle, I've attached my comments to the draft SMP. Please let me know if you have any trouble opening up the
attached word document. Thank you.
Jerome Mills
1
30 January 2009
Department of Community Development
621 Sheridan Street
Port Townsend, WA 98368
Subject: SMP Comments
Thank you for the opportunity to submit comments. I would like to comment on four
specific areas:
Article 6, Section 1, Subsection D (Regulations), Point 6 addressing standard buffers and
building setbacks from Marine shores. The draft increases the building setback from 30.
feet to 150 feet. This is excessive and unnecessary and will prevent reasonable
development on many lots. While the shoreline needs to be protected and conserved,
increasing the setback by 500% is unnecessarily harsh and extreme.
Article 7, Section 7, SubSection C (Regulations - Existing Shoreline Amioring), Point 1.
The SMP should make clear that existing bulkheads and other forms of shoreline
armoring that were properly approved and in place prior to the fmalization of this Plan
may be repaired or replaced to protect existing residences and other structures or
infrastructure. Point ii is unnecessarily restrictive and represents a ''taking'' or private
property by not allowing additions or increases in size. Increases or additions of existing
armoring should be allowed if it is necessary to protect the existing structure because of a
change in natural conditions (increasing water levels, tidal action, waves, etc). For
example, if additional development is allowed such as a mining operation with barge
traffic that increases the wave action, the SMP should clearly allow an increase in
shoreline armoring to protect existing property and structures from damage. Likewise, if
sea levels rise, expansion of the bulkhead should be allowed to protect the existing
property.
Article 8, Section 6, Subsection A (Mining Policies). Point 1 should be strengthened.
The draft would allow mining activities on shorelines simply if the benefits from mining
outweigh the adverse impacts. While mining is certainly an important activity, the
location of mining operations on shorelines should be discouraged and restricted to
specific industrial areas to minimize the damage and destruction caused by this activity.
There should be a presumption against the location of mining activities including its
transportation on any shoreline of significance. Only when there is no other choice
should mining activity be allowed on the shoreline.
Article 9, Section 3 (Exemptions from Shoreline Substantial Development Permit
Process), Subsection A, point 2. The SMP should make clear that existing homeowners
and owners of other structures that were in place prior to the fmalization of the SMP are
exempt from the shoreline development process provided their activities are limited to the
repair, remodel or rebuild of their property within the existing or similar footprint. The
exemption should not be limited to activities required as a result of damage by fire,
accident or other elements.
Respectfully submitted,
Jerome A. Mills
370 North Beach Drive
Port Ludlow, W A 98365
jalamills@comcast.net