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HomeMy WebLinkAbout2961-438 Gl'vVT ~ (LCl~ d1-/~51 04 pC- Yl/V~ @) z.-qbl Comment Bv Peter Brockman at Plannina Commission Meetina 2/25/09: RE: Jefferson County SMP Draft (12/3/08) Article 7-1. Beach Access Structures My name is Peter Brockman, I attended last week's planning commission meeting that discussed beach access structures and had some comments and respectfully request your consideration. My expertise is in designing and building high quality, structurally strong, aesthetically pleasing stairs to the beach that conform to existing topography with no slope modification. I have 16 years of experience in this in Western Washington. In last two years I have built 3 stairs that were inspected for final approval in Jefferson County. . . the building inspector was very pleased with the craftsmanship. Geotechnical reports were completed ()n the projects and each report concluded the projects were feasible and will not increase the rate of bluff retreat or result in a decrease of the stability of the bluff, nor will it have adverse impacts on adjacent properties and will not significantly impact existing shoreline sediment transport processes. Also any portions of a project waterward of the ordinary high water mark were approved by Fisheries. On New Discussion Prohibiting Beach Access Stairs on "Feeder Bluffs". There is no definition of "feeder bluff' in the State Guidelines or in WAC 173-26-020. This is a term of art with various definitions in municipalities as well as in the academic community. What has been found about the definition from any Ecology source is that there is not an adopted regulatory definition of a "feeder bluff'. The description appears no other than a bluff of any height that erodes and that the generic definition does not adequately appraise as to the relative benefits or values of a particular bluff. There is no legal perspective on "feeder bluffs". The bottom line is that our stair products do not negatively effect feeder bluff shoreline functions. We have never run across an assumption that they do in any other jurisdiction. We have a copy of a letter that was sent to you from a Geotechnical Engineer and Engineering Geologist expert in this field that confirms and explains these types of structures do not pose a danger to persons or the aquatic environment when properly sited and constructed. Simply how the planning commission should be handling this-- is that an applicant have a geological reconnaissance (report) that is site specific completed by a qualified Geotechnical Engineer on a slope with geological concern (recommend defining this by when a slope is over a specific degree of slope - reasonably this could be over a 45 degree slope). Regulation #5: Discussed stairs not allowed if "there is other available PUBLIC beach access within 500 feet ofthe proposed access site." There is no rhyme or reason for this, this was picked out of a hat and is not based on anything. This is unreasonable, unjustified and there is no proliferation of building stairs to the beach as in all of Jefferson County there were 4 new stairs permitted last year. For example I have an 80 year old client on Marrowstone Island that would just like a 20 foot run of stairs to his waterfront (what if it was a 10ft. or 5ft. run) why should he be made to walk up to 500 feet and why can't he use his property? What if a waterfront owner can't walk that far-- again this is a taking issue of a property owner not able to reasonably use their property. Why is he paying for waterfront when he can't even access it from his own property---so what is he is supposed to do walk down the street 500 feet to reach a public access point and then trespass pass through his neighbors waterfront to get to his? Also why are you worried about proliferation when these properly built staircases do not have significant adverse effects. Regulation #7: In limiting any portion of the structure "in water or over water" this should be clearly and specifically defined as waterward of the MHHW (Mean Higher High Water which is defined as the trigger point for the US. Army Core of Engineers review). It was discussed limiting this to 25 sq. ft.----yet you need to add the square footage for a let- down stair/ramp to step offthis 25' sq. ft. platform to step to the ground safely. Proposed beach access stairs allowed in all shoreline designations when "ELIGIBLE" for permit. Plainly and clearly they should be permitted. Realize even with a building permit and following the proposed requirements, any part of the project waterward of the ordinary high water mark also requires Hydraulic Project Approval from the Dept. of Fisheries and waterward of the mean higher high watermark needs US. Army Corps. of Engineers review. Waterfront owners have the right to access their own waterfront property . Beach Access Structures should be specifically listed under the definition of appurtenance ---- they are an appurtenance to a single family residence-- meaning structures and developments that are necessarily connected to the use and enjoyment of a single- family residence. Regulation #5: The width of any walkway, staircase or tower shall not exceed five (5) feet". As stated in the definition of "Beach access structures" included is a "stair tower". A staircase can be reasonably built at a width of 5 feet but it is not structural possible to build a stair tower 5' in width. There are some banks/slopes that are more vertical in nature and will require a tower type staircase or portions of one which are wider. The purpose of a stair tower is to build the staircase within a tower to vertical span vertical parts of a bank, this also avoids putting posts on the bank and avoids carving into the bank. The staircase is built to in a sense to structurally spiral down. The smallest width you can build a stair tower is 1 0' . Thank you for your consideration.