HomeMy WebLinkAbout060316 Dorgan, Nancy - Post-docket June 4, 2016
Port Townsend Planning Commission
Re: 2016 GMA Comprehensive Plan Update
Commissioners:
The links to the Comprehensive Plan (Plan) on the City's website lead to a digital version maintained
with Code Publishing Co. in Seattle. Seven appendices are listed as part of the Plan along with the 10
chapters being reviewed during this Update. The 1996 ordinance adopting the original Plan included
these appendices as part of the Plan -- showing its GMA"homework". Appendices 2 and 3 deal with
revenue sources for capital facilities and capital facility requirements—documents in which the City
states its capital planning needs, wants, and its ability to fund them. For example, a proposed
Stormwater Master Plan is mentioned several times in these appendices and is shown to be potentially
funded by a future$550,000 Public Works grant.
If the City wishes to rescind all references to a local Stormwater Master Plan in its Plan during this
Update, then the hearing draft should also delete any such references in the adopted appendices--for
internal consistency of the overall Plan. Perhaps more importantly, however, is the problem that the
existing proposed deletions striking a Stormwater Master Plan exceed what could be considered staff
"housekeeping". These deletions grossly exceed the docketed scope of the Update. City ordinances
2929 and 2915 adopted and recognized Ecology's 2005 standards manual (Storm Water Management
Manual for Western Washington -SWMMWW) as the City's Best Available Science standard.That was
correct at that time. However,these ordinances also contain significant references toop lice
relationships between a local Stormwater Master Plan and Ecology's. Please see the following for
examples: http:!lweblink.cityofgt.us/weblinkl0/d /Pa oc/R525el.aspx
http:!/weblink,cityofpt,us/weblinkl0/doc/R253/Pa�el,aspx
Unfortunately, in retaining use of the now obsolete 2005 SWMMWW as the City's BAS standard, staff
quietly overlooked the fact that Ecology has subsequently twice revised its 2005 standards. The
Executive Summary for the current 2014 edition revising the 2012 edition, significantly states:
"Ecology has revised many of the BMP-s from the 2005 SWMMWW to improve their
effectiveness for protecting water quality and to meet the intent of the anti-degradation
provisions of the water quality standards."
See: haps://fortress,wa, ov/acylpublications/parts/1410055part2,pdf
It is obvious that any policy continuing to use Ecology's older 2005 manual as the project permitting
standard is inconsistent with GMA's requirement for Best Available Science.
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Dorgan Comments re 2016 GMA Update
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It is also inconsistent with the City's Engineering Design Standards:
"2.Standard Specifications
b. The conditions and standards set forth in the most current edition of the following
plans and specifications are incorporated into these standards by reference and shall be
applicable when pertinent or required:
xiv. State of Washington Department of Ecology Stormwater Management Manual for
Puget Sound(SWMM)" [emphasis added]
Because Ecology periodically revises its stormwater standards, the approach of the EDS to always use
the most current edition of that manual seems very appropriate. It should certainly assure ongoing City
compliance with GMA-- if it were not for proposed Plan policy to the contrary. I suggest that the Plan
be made consistent in all regards and that all references to Ecology's SWMMWW also refer to the "most
current edition".
Thank you for your consideration of my comments.
Nancy Dorgan
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Dorgan Comments re 2016 GMA Update
PC-25