Testimony to the Bremerton Planning Commission on the Bremerton Shoreline Master Program.

I am a shoreline homeowner that honestly believes that I am a good steward of my land. The stream that runs through my property is completely natural and untouched. I have a soft bulkhead erected to mitigate the effects of my hard bulkhead. I rarely use fertilizer on my lawn, have declared dandelions a flower and have a 20-foot strip of native vegetation along the water.

I am willing to tolerate some restrictions on my land if there is a demonstrated need; but I am not convinced that the proposed restrictions are backed up by good science. The first problem is the city has not defined the problem that we are trying to solve.

The most succinct discussion of Bremerton’s SMP underlying philosophy can be found in the Cumulative Effects Analysis dated May 15 2012, Sec. 1, Page 2: 

“It is not known, at this time, whether general trends in ecological degradation from human disturbance are continuing to result in incremental degradation of ecological functions or whether localized ecosystems have reached a stable condition. There is no scientific consensus on appropriate indicators of ecological productivity and no comprehensive means of monitoring. Based on the continuing trends of declines in key aquatic species in Puget Sound over several decades, the most justifiable conclusion is that existing land use and practices within watersheds and along shorelines are continuing to degrade habitat and trends will continue unless substantial changes in practices are implemented in many areas.”

“Specific ongoing contributions to nearshore degradation that will likely continue, unless substantial changes are made to physical facilities, include:

Existing practices in managing ornamental vegetation, such as use of fertilizers, herbicides, and pesticides, adversely affect not only the nearshore food chain, but also have adverse impacts on the central nervous system functions of fish, including salmonids.

Shoreline bulkheads have negative impacts on substrate through interfering with natural recruitment sources, especially on feeder bluffs; in some cases, they produce a high energy environment because of reflective wave action and also contribute to the absence of shoreline vegetation.

The lack of native vegetation on the shoreline likely contributes to the absence of a nearshore food chain, and also results in higher nearshore temperatures due to the lack of shade.

Current docks and other moorage facilities contribute to predation and also may cause avoidance behavior in salmonids by forcing them out of nearshore environments and into environments where food and shelter are less available and where predation is increased.

Shoreline Cumulative Effects Analysis (DRAFT) May 15 2012

If the quality of the Puget Sound is in question then there should be a baseline quantitative measurement of the waters, flora and fauna; problems identified and programs established to solve them. The term “No Net loss” is not adequately defined, and there is no plan to sample water quality, shoreline vegetation or wildlife to measure progress toward a goal.

I believe our waters are in fact getting better. The City of Bremerton, Puget Sound Naval Shipyard and the Kitsap County’s Stream Pollution Identification & Correction Program have spent millions of dollars and made significant progress in cleaning up Sinclair and Dyes Inlet, and restoring salmon habitat along Chico Creek for which you take no credit towards no net loss.

The emphasis of placing land use restrictions on shoreline homeowners diverts attention and resources from the real source of pollution, stormwater runoff.  In the last 6 months the city of has discharged over 750,000 gallons of untreated sewage and combine sewage overflows into Bremerton’s  waters and you are telling me that you are worried about the lack of shade trees, native vegetation and fertilizer used on my front yard.

Counterproductive efforts

Additionally you are proposing even more restrictions on some of the cities most desirable property. There is a significant portion of Bremerton’s shoreline residential properties that were built over fifty years ago; most are small by today’s standards and limited by urban lot size. The issue is remodeling and rebuilding.

Instead of encouraging homeowners to improve their land; the SMP places significant restrictions and hurdles to the process. Requiring in some cases hiring a Biologist, Geologist, Vegetation Management plans, Hydrology reports, performance bonds, permanent notices to title, etc.

While the ability to rebuild a house destroyed by natural disaster within a year is minimally impacted, the city places burdens on the owner who wants to perform a significant remodel. If the projected remodel will cost more than 75% of the assessed value of the structure, the owner will be required to bring the house up to current codes including new buffers and setbacks. Rebuilding in the same footprint may no longer be an option, and the foundation will have to be moved to conform.

Instead of allowing continuous improvement to a property, the code penalizes a phased approach. Factored into the calculation of the 75 % assessment value  “all repair and maintenance work conducted within a five (5) year period on the structure shall be included in the calculation.”

In many cases for a severely run down house, rebuilding will not even be a feasible option. It is counter to the best economic interests of the community to severely restrict some of the city’s most attractive property. Property buyers will go to areas that are more accommodating, Shoreline property values and associated tax base will be depressed and the taxes on the upland properties will necessarily rise to make up the difference.

Please look at this program carefully as it will several negative impacts to current and future homeowners and it does not encourage economic development.

I recommend you consider taking positive action to improve the environment. Establish a shoreline homeowner education program and website that discusses best practices and products, provide tax incentives for shoreline conservation and native vegetation plantings. Develop a meaningful monitoring to measure progress towards improvement in Puget Sound rather than burden individual property owners and developers to prove “No Net Loss” on a property-by-property basis.


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