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June 16,2009
DCD - SMP Comments
621 Sheridan St.
Port Townsend, W A 98368
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Gentlemen:
I have reviewed the draft SMP, albeit very quickly, as time is short. Rather than
comment on specifics of the SMP, I would like to limit my comments to a more general
nature.
This is not an update to the previously approved SMP. This is an entirely new SMP.
Differences between the existing SMP and the newly written SMP are not stated. The
requirement ofRCW 90.58 is that the SMP shall be updated every 7 years to show
continued compliance with the RCW. An entirely new SMP runs contrary to this
requirement.
This is a very long document filled with ambiguous definitions and term usage, such as
"aesthetics" and "ecological function". Interpretation of these terms can vary over the
entire spectrum.
Two weeks to review such an extensive and complicated document is much too short. It
gives the appearance of quickly trying to push a new and extensive set of regulations
without the public knowledge.
Incorporation of the Critical Areas Regulations should not be done. The document
should stand by itself. Indeed it may be in conflict with the requirements ofRCW 90.58
and RCW36.70A, the Growth Management Act.
There is an amazingly lack of balance between the interests of the affected property
owners and the proposed regulations. The bias against affected property owners is all too
evident. In this regard, there is no evidence that affected property owners, i.e., owners of
property abutting water were consulted or that there was any representation on the
Planning Commission.
There is no analysis or consideration given to the economic impact of these regulations.
This may also be in conflict with RCW 90.58. The better part of$IM was spent on
developing this draft regulation and nothing was spent on economic considerations.
The regulations in this draft SMP goes far beyond the intent of the legislation that
mandates it.
It is my belief that if this SMP becomes incorporated into the county code, there will be
extensive litigation initiated by affected and concerned people.
Sincerely,
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Tom Seavoy /
634 Schwartz Rd
Nordland, W A 98358