HomeMy WebLinkAbout061716 Dorgan, Nancy - Post-docket June 16, 2017
Port Townsend Planning Commission
Re: 2016 GMA Update—Capital Facilities
Commissioners:
I would like the Commission to allow me to make a few further comments on the Commission's hearing
record. During the staff presentation June 9th, City Engineer David Peterson specifically discussed
aspects of my June 4th comment letter, and I would like the opportunity to respond. He did not,
however, discuss my criticism re Best Available Science and the related problems of using the obsolete
2005 DOE Stormwater Manual for project review. I will comment further on that to Council.
However, I hope the Planning Commission does not also avoid the issue of BAS compliance of
implementing regulations during the 2016 GMA Update.
Perpetually Pending Stormwater Master(Functional)Plan
Why is this plan taking decades to complete? How can the City even operate this utility without a
current general plan? What are the GMA planning and permit review ramifications of not having such a
plan while also using obsolete editions of Ecology's Stormwater Manual? How can the City be eligible
for state GMA or other planning grants without an adopted current stormwater functional plan? Now
staff does not even want to include Ecology's obsolete 2005 plan with those proposed for incorporation
into the Comprehensive Plan.
The stormwater master plan is still a Plan requirement and rightly so. The City's stormwater utility was
established pre-GMA in 1987 by Ordinance 2053, which also adopted the companion Comprehensive
Drainage Plan. For 20 years under GMA planning, the City has been saying that the stormwater master
plan was a priority, in the CIP, was imminent, would be ready in the Spring, etc. Yet there is still no plan.
For example:
• The March 1995 Comprehensive Plan Appendix 3 - Capital Facility Requirements states that the
stormwater master plan had "proposed funding" in the 1995-2000 CIP would be completed in
"Spring 1995"
• In 1995, 1996, 1997 the City contracted with consultants CH2MHill to prepare the required
stormwater master plan and its implementing regulations. Council resolutions hiring the
consultants referred to the plan as a priority and in the CIP/budget. See related Resolutions 95-
129, 96-145, and 97-17.
PC-28
• In 1999 Ordinance 2708 repealed stormwater reserve capacity charges on an interim basis was
careful to mention that the action was being taken:
"... Pending adoption of the City's Stormwater Management Plan and Implementing
Regulations.
• In 2006 Ordinance 2899 [a personal favorite] Amending PTMC 19.05 "Critical Areas Ordinance"
with Best Available Science states that the City's updated Stormwater Management Plan will be
adopted "by the end of 2005" and the implementing regulations in the EDS by "Spring of 2006:
From Findings:
33.The City Council expressly finds that adoption of the 2005 Stormwater
Management Manual for Western Washington (SWMM)within the Environmentally
Sensitive Areas(ESA) Ordinance is inappropriate at this time because it was just
published in April 2005 and staff has not had adequate time to review it, and further,
doing so would result in two separate and inconsistent city standards(i.e. those
within ESA's based on the 2005 SWMM, and those in all other areas of the city based
on the 1992 SWMM. The Council hconcludes that all documents relating to
stormwater management and control should be consistent to ensure proper
implementation and acceptance by the public.
34. The Council finds further that it is necessary and in the public's interest that the
City adopt an updated Stormwater Management plan as well as updated stormwater
management standards to implement the plan, based upon the Department of
Ecology's updated SWMM. Accordingly, the Department of Public Works has been
directed to complete an update of the City's Stormwater Management Plan as soon as
practicable,with revisions to the implementing provisions of the Engineering Design
Standards(EDS) Manual being undertaken without delay thereafter. It is expected
that the update to the Stormwater Management Plan will be completed by the end of
2005, with implementing revisions within the EDS Manual completed in the spring of
2006.
• June 9, 2016 City staff tells Planning Commission that the draft Stormwater Master Plan is in the
adopted budget/CIP and a priority. Sound familiar? Unfortunately, no specific new information
was given about what is actually being done to get the delinquent plan finished and adopted. It
is now rather far down on the wannabe list of 2016 CIP projects that may or may not even have
funding.
This is an expensive major piece of fundamental utility planning that should have been in use decades
ago. Not having such a plan and also playing games with the DOE Stormwater Manual is very disturbing.
Thank you for your consideration of these comments.
Nancy Dorgan
PC-28