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Planning Commission
Jefferson County
State of Washington
June 15, 2009
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Subject: Planning Commission Revised Draft SMP, Dated June 3, 2009
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To Whom It May Concem:
I am Robert S. Pardo, a retired businessman, graduate of Cornell University in Ithaca, New York, possessing
a Master's Degree in Business and Engineering from the University of Washington, and a homeowner
living on the Bridgehaven Peninsula located approximately two (2) miles south of the Hood Canal Bridge.
The peninsula is approximately 330 feet wide with the access road, North Beach Drive, centered on the land
mass To each side ofthe road 60' wide by 120' deep lots stretch to the water's edge. This development is
over thirty (30) years old and for all intents and purposes it is fully developed (only a few buildable lots remain).
The average home built on the peninsula's lots has its waterward front well within 25 feet of the OHWM.
In our case, over 25' of our house lies within 50 feet of the OHWM.
I consider myself well educated and my beliefs non-radical. However, in reviewing the Draft SMP, I am
quite concerned that its far-reaching intentions are misguided when it attempts to apply itself to existing
high density residential shoreline developments such as Bridgehaven. As a case in point, Section 6-5.5
calls for a standard buffer of a "minimum of 50 feet ...in Shoreline Residential and High Intensity shoreline
environments" PLUS a 5 foot building setback in addition to the "standard buffer". This equates to a 55'
building setback from the OHWM! A buffer is defined on 2-7.22 as an "area adjacent to the shoreline
that separates and protects the area from adverse impacts associated with the adjacent land uses".
This article purports to apply to "new uses and developments", but I can find no definition for "new uses".
Applying this "buffer" concept to an established high intensity residential development such as Bridgehaven
would be nonsensical. Given the intensity and type of residential development in existence at Bridgehaven,
no buffer zone is applicable by definition.
In article 9-2.3. EXEMPTIONS LISTED, part A.2 Maintenance and Repair, it states that normal maintenance
and repair of existing structures or developments, including damage by accident, fire, or elements...shall
be considered exempt from the requirement to obtain a shoreline substantial development permit. This
should be expanded to include "acts of god" meaning earthquakes, tsunamis, and the like. This paragraph
goes on to discuss the meaning of the allowance of "normal repair", but it qualifies the right to repair by
stating "except where repair causes a substantial adverse effect to the shoreline resource or environment".
This qualifying language should be struck in both locations that it appears in this paragraph. An existing
structure should be allowed to be rebuilt or repaired without an arbitrary and potentially misguided use of
someone's interpretation of what "substanital adverse effect" means.
Article 10-6.6 NON-CONFORMING DEVELOPMENT appears to be intented to apply to Bridgehaven (although
this is not readily apparent to the reader). Assuming this is the intent, article 4.a states that damaged structures
may be rebuilt provided" ...they will not cause adverse effects to adjacent properties or to the shoreline
environmenf'. In the case of a high intensity residential environment such as Bridgehaven this qualifying
comment should be struck. If a residential home on this peninsula bums down it should be granted the right
to rebuilt as it existed prior to its destruction as long as it meets or exceeds current building codes and
it should not be subject to some arbitrary "adverse effects" standard.
This article (10-6.4 B) also has a stricken paragraph that stated that a non-conforming development that
suffered a greater than 75% total loss as a result of fire, explosion, etc. could not be rebuilt without complying
with the Program. This paragraph and any like it need to remain stricken since it would in essence be an open
invitation to Eco- Terrorist to fire bomb shoreline developments to achieve their radical agendas.
Article 10-6.F 1 & 2 have been stricken. They referred to unreasonable limitations to the expansion of
existing single family homes BUT 10-8.G states that the "Administrator shall require a conditional use permit
for any of the following: 1. Enlargement or expansion of a single family residence...in excess of those
allowed in 10.6.F" which appears to be referring to the stricken unreasonable limitation paragraph.
This reference itself should be stricken and the meaning of the Administator's authority on this issue
clarified. The existing building codes should be the rule in such a case.
Robert S. Pardo
360 N Beach Drive
Port Ludlow, Wa
360-821-9177