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HomeMy WebLinkAbout2961-702 (;-,''1',\/'4 ",~.'" 'g.ec'cl fQ M.~ ~}'(I\Jl ~ ~'" A ;,,,'v' Zf?& I June 17, 2009 To: DCD-SMP Comments Department of Community Development 621 Sheridan St. Port Townsend, WA 98368 Attn: Michelle McConnell, SMP Update Project Manager From: Margo DeVries Subject: Public Comment: Revised Draft SMP These comments are submitted with sincere appreciation to all who worked for years to produce this Shoreline Master Program document. During this review of the SMP, among other interests, is one for an understanding of selected, specific word or phrase choices contained within the document; the interpretation of the intention of these choices, and their use through-out the document; which, seems to be translated by application to "shoreline environment designation" as Provisions of the Program. Some comparisons of terms are: "net loss" and "aggregate net loss"; "adverse impacts" and "significant adverse effects", which seems to establish a path to decisions of "non-significance" where specifically used. Since the word "significant" is not in Article 2 - Definitions, how will it -or- will it be used and interpreted equally among locations as a deciding factor, since it seems to be found only in Article 7 - Shoreline Modifications Policies and Regulations, Beach Access Structures, Policies? Is there a calculation for determining a percentage-rate decision of or for significance or non-significance? Are "no net loss" and "mitigation" parts of the aggregate, total shoreline designation, decision? "Conservancy" seems to be the catch-basin term for areas that may be literally and descriptively between "Natural" and "Shoreline Residential" or "High Intensity", Under the term "Conservancy", i. Purpose and ii. Designation Criteria seem to portray a definition of something closer to "Natural", while actually including more, firm references to supporting residential development, recreational activities, commercial and industrial uses. Through out this Revised Draft SMP references to "Conservancy" become more clearly defined toward "providing recreational opportunities" than to Conservancy for "ecological restoration", The potential for this designation-[conversion] of shoreline-use seems to become evident toward aligning with "Residential" and "High Intensity" in these areas, except, when even, more specific: Aariculture Policies; Aauaculture Policies; Commercial Use Policies, which includes Conservancy-specific reference: "small-scale, low-intensity recreational/tourist development/use may be allowed with a conditional use permit provided that a portion of the use/development is water-dependent or water-related."; Industrial and Port Development "Low Intensity" development Recreation. Shoreline Environmental Regulations, which includes Conservancy-stipulated Structure specifications and building coverage related to recreational use; Residential, single- family and duplex...... All other residential development may be allowed....; Transportation; Utilities. Shoreline Environmental Regulations, which includes Conservancy-unique reference to: "Utility development...of local distribution facilities, sewage outtalls and treatment plants, overwater communication or power lines, fuel pipelines, hazardous material facilities, regional facilities, desalination facilities and power generating facilities. "Liberal Interpretation"? Boatina Facilities, Regulations-Docks, Piers and Floats; Total of new reaulations seem conflicting. \ In complying with mandates, presumably, a process of negotiating or compromising shorelines for "no net loss" or "no aggregate net loss", there may be indication or implication that expansion of select-shoreline for "enlargement of recreational opportunities" could mitigate the "significant effects" or "impacts" to "Priority Aquatic" and "Aquatic" and "Natural" designated areas as "no net loss" in exchange for more "development", "commercial ano recreational potential" in "Conservancy" areas seems strongly suggested. Conservancy seems to be designated first for Economic Development and Recreation; and, as it is listed, last for Conservation and Restoration and Enhancement consideration. Hopefully, areas designated Conservancy, whose "shoreline is a good candidate for ecological restoration" will not get lost to other pursuits or purposes. Perhaps, distinctly different, Conservancy categories to stipulate between "development opportunities" and "ecological restoration" would ensure future restoration of these not- quite "Natural" shorelines before they are lost to expanding development. Or "Low Intensity" (LI) added to Shoreline Environment Designations Recreation: Regulations, Conservancy: iv. "Recreational use and development will not result in visitor patterns that degrade shoreline ecological functions." "Visitor patterns" will probably be the most un-regulated process possible in some instances. Over the last several years, the spit located along Hood Canal at the mouth of Fisherman Harbor has become a kayaking destination. The numbers of "visitors" has incrementally increased until last year it included two separate groups, each of which, ranged from 25 to 30 different individuals, who stayed from 2 to 3 days and nights. The natural environment was their facility. No one was noticed with obvious bagging removal of waste. However, no garbage was seen left behind as litter; perhaps, due to the constant, (probably illegal) "campfire" burning in the vicinity of the by now, very narrow, high tide, sliver-spit location. All of the shoreline identified is designated "Natural" with "Priority Aquatic Marine". The owner of this property has recently built a home on the upland property; things might get more interesting this season. "Visitors" arriving on the beach, any beach, seem to have a "find something and start a fire with it" mentally toward primitive beaches anyway; display few or no obvious skills for building or containing a safe fire, if a legal one. These real, safety issues are first in the minds of the upland owners in reaction to the seemingly, oblivious visitor. Among these actions are those convincing some, including those who have found scorched-tree evidence, of the real need for required, "visitor" education prior to implementing policy for the public's physical enjoyment of the these shorelines. Then, there are the boaters observed pumping bilge and holding tank material ahead of the mouth of the Harbor, only to retreat to the other side of the Canal and neighboring County waters. Observations of the west-side Toandos Tidelands State Park location are out of this viewer's range. Thank you so much for this opportunity to comment. -~ _ . Respe9~ ....~ . /"" c "-. ~ffiw~'.--J-~0t)u.Q~-.- Margo DeVries ~( ~..