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March 6, 2009
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RECEiVED
Jefferson County Board of Commissioners
P.O. Box 1220
Port Townsend, WA 98368
JEffERSDN COUNTY Den
Jefferson County Planning Commission
Jefferson County DCD, Long Range Planning
621 Sheridan Street
Port Townsend, WA 98368
RE: Proposed Shoreline Master Program Update, Sections 6 and 7.
Honorable Commissioners, Commission Members, Staff,
I have been reviewing the proposed Shoreline Management Master Program update. In
Section 6 of the update there is a proposed change to the shoreline setback for residential
structures. The proposal would be for new residences to be set back from OHWM by
160 feet, 150 to accommodate a marine buffer and 10 feet building set back. Under
Section 7, Common Line Setback, the policy recognizes that where there is existing
development the buffer is less functional; and that similar properties should be treated
. similar and view and other amenities not unduly impaired. .
Under current regulation, if there are developed properties on either side and within 300
feet of a proposed residence, the setback is a common line drawn between the developed
structures. If only one property is developed, it is a common line between the developed
structure and the required setback. The same concept as depicted in the diagram on page
6-20.
The problem lies in the distance between developed structures and the non-developed lot
in the proposed regulations. Section 7 (i) proposed states "Where there are existing
legally established non-conforming residences that encroach on the established
setback/buffer within fifty (50) feet (emphasis added) of either side of the proposed
residence... ..." Similar language is found in 7 (ii). The proposed rule moves the
common developed separation line from 300 feet to 50 feet.
If this rule goes into effect, few if any properties would benefit, even in the most
developed areas of the shoreline. In areas where the shoreline is intensely developed
most lots have between 100 and 300 feet of frontage. Depending on the placement of the
residence on the lot, there is often more than 50 foot separation between structures.
Examples in northeastern county include: Port Hadlock, Oak Bay, Matts Matts, Port
Ludlow, Shine, Bridgehaven, Seaview Estates (City), Adelma Beach, Cape George,
Middle Point, all of whom have undeveloped individual properties which would not meet
the 50 foot structure separation even though the area is densely developed. The
application of a 50 foot structure separation would create the inequity that the exception
is designed to avoid.
While 300 feet may be excessive, 50 feet is not practical. How can a buffer be effective
if there are only handful of properties which meet the buffer setback and the majority do
not? Perhaps 100 or 150 feet is a better measuring stick and would address most if not all
of the 'holes in the donut' of undeveloped waterfront property in areas of the shoreline
which historically have been intensely developed.
As an example, I am assisting a lot owner at 301 Shine Road. There are developed
properties all along Shine Road. At this address there is an existing house which is in the
process of being removed. There are residences located between 75 and 95 feet on either
side of the existing house, the lots run from 100 to 250 feet in frontage. This pattern is
repeated all long the road. Under the proposed rule, and after the house is removed, any
new development would have to be set back 160 feet OHWM or a variance applied for.
In practical reality, the shoreline would not benefit as the pattern of more intense
development has already been established and this property would not benefit as it would
be an inequitable treatment, impairing both view and functionality of the property.
Clearly this issue of fitting new development within areas of the shoreline which have
historically been more densely developed needs to be addressed in a fair and equitable
fashion. The fifty (50) foot established residence requirement does not accomplish this
goal.
I thank you for giving this testimony due consideration and ask you to come up with
practical and workable solution to those areas where development patterns have long
been established.
David Goldsmith
DRG Sound Solution
536 Foster Street
Port Townsend, W A 98368
CC. AI Scalf, Director DCD
Michelle McConnell, Associate Planner DCD