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City of Seattle Shoreline Master Plan: Letter to City of Seattle

Seattle Boater issues with the revised October 2011 Ordinance proposals by the City

December 21, 2011
Dear Tenant


The City of Seattle has been commissioned to update its Shoreline Management Plan.
Within the plan are some ominous issues affecting your boating experience. I am forwarding parts of the plan that I believe pertinent.
The due date for input to the City in regards to the plan is December 23, 2011.
I have attempted to place a table with the City ordinance on the left and comments on the right.
Prior to the table is a section that can be clipped and e-mailed to Margaret Glowacki margaret.glowacki@seattle.gov She is the City of Seattle official responsible for accepting comments.

A link to our whole submittal to the city can be found with a link on our Marina News page at: http://www.salmonbaymarina.com/news.html
Thank you for your consideration.
Merry Christmas
Charles Draper
Salmon Bay Marina

Margaret Glowacki margaret.glowacki@seattle.gov
Dear Ms. Glowacki.
I am a boater in the greater Seattle Area. I have two lists that I believe are detrimental to boaters and need to be eliminated or refined.

I find the following proposed ordinances with the following numbers to be objectionable and need to be eliminated from the Ordinance.
23.60.002 Title and purpose. Section B.3 -Taking Private lands - too many restrictions
23.60.162 Standards for parking and loading zone requirements section 2. Eliminates necessary parking for boaters and businesses
23.60.164 Standards for regulated public access -Sections:C,D,E,F,G,H,I,J,K Takes private property without compensation to owners.
23.60.200 Standards for marinas, commercial and recreational Over regulates marinas and its tenants and restricts small vessel moorage.
23.60.204 Standards for house barges Eliminates future house barges and over regulates house barges made before January 1, 2011.
23.60.214 Standards for live-aboard uses on vessels Over regulates boaters.
23.60.215 Standards for uses on vessels Over regulates boaters.
23.60.216 Standards for vessel moorage Over regulates marinas and moorages.
23.60.514 Regulated public access in the UM Environment Takes private property without compensating the owners.


Further the following ordnances with the following numbers that need the suggested revisions (In red).
23.60.002 Title and purpose "B.1 "Protect the ecological functions of the shoreline areas insofar as practical" Per governing RCW statute
23.60.012 Inconsistent development prohibited.
DELETE "including a use that is located on a vessel" Over regulates boaters.
23.60.027 Ecological Mitigation and Measuring Program: 1. Use best available science combined with realistic economic considerations (which may be arbitrated) to determine values for ecological functions measured in habitat units; This adds economic conditions for future applicability so businesses can survive.
23.60.162 Standards for parking and loading zone requirements
B. New off-street parking and parking structures shall be located at least 50 feet from the OHW mark when reasonable. The Director may modify this requirement to allow parking required pursuant to Section 23.54, for lots that have a lot depth of less than 75 feet of dry-land. In such cases the parking is prohibited within shoreline setbacks and shall be located as far upland from the OHW mark as reasonable.
23.60.162 Standards for parking and loading zone requirements Eliminates necessary boaters parking.
DELETE #2
23.60.164 Standards for regulated public access
Should apply only to Public land, not private land. Delete all if applied to Private land.
23.60.200 Standards for marinas, commercial and recreational Micro Manages marinas and moorages without taking any liability Delete Section E.1 b & c add and the City of Seattle will award the Marina a release from damage for any and all incidence. Or Strike all of statute.
23.60.924 Definitions -- "L" "Live-aboard vessel" means a vessel that is used as a dwelling unit for more than a total of thirty days in any forty-five day period or more than a total of ninety days in any three hundred sixty-five-day period; or where the occupant or occupants identify the vessel or the facility where it is moored as their residence for voting, mail, tax, or similar purposes.


Thank you for considering the above recommendations.


Respectfully


_______________
The following is a table reviewing the areas of affected ordinance sections

City of Seattle Proposed Ordinance
Objections to proposed Ordinance
23.60.002 Title and purpose.
B.1 "Protect the ecological functions of the shoreline areas"
 Added terminology should be included as stipulated within the RCW
RCW 90.58.020:
Permitted uses in the shorelines of the state shall be designed and conducted in a manner to minimize, insofar as practical, any resultant damage to the ecology and environment of the shoreline area. . ."
…"Protect the ecological function of the shoreline areas insofar as practical"
If "insofar as practical" is not included then the cost of having moorage may go out of sight due to the unreasonable restraints that government can wage to businesses.
23.60.002 Title and purpose.
B.3 "provide for maximum public access to and enjoyment of the shorelines of the city"
 The City of Seattle asserts ALL shorelines are part of the city, public and private because they are within the boundaries of the city.
According to the statute "Public Access is to be based on "Publicly owned area"
RCW 90.58.100:

"(2) The master programs shall include, when appropriate, the following:

(b) A public access element making provisions for public access to publicly owned areas;
It references access to publicly owned areas however it does not stipulate that the public access is to be across private lands. It also does not account for adjacent public facilities that already provide access to those same public areas.
The DPD indicates The WAC states that public access includes views of the water. They site WAC 173-26-221(4)(d)(iv) which says: (iv) Adopt provisions, such as maximum height limits, setbacks, and view corridors, to minimize the impacts to existing views from public property or substantial numbers of residences. Where there is an irreconcilable conflict between water-dependent shoreline uses or physical public access and maintenance of views from adjacent properties, the water-dependent uses and physical public access shall have priority, unless there is a compelling reason to the contrary.
Unfortunately that sighting says nothing about views of the water?
If in fact a view of the water from the city street is considered public access then some of the issues of public access can be accommodated, however it does not account for requirements for easements across private lands without compensation.
In our situation, the publicly owned area claimed by the state is across our submerged uplands and beyond State of Washington claimed DNR land in which we have permit to use and control. Although some of the State lands and waters are "public", they have been removed from public usage by virtue of our 30 year permit with the DNR including the water column. Access would not be accomplished within the SMP because even if the public reached the water, the Water would not be available to the public for public usage and therefore the intent of the proposed SMP could not be manifested.
A Reference to private lands being required for public access should be removed from the proposed ordinance. It is not reasonable to make ANY requirements for private lands to be taken for public uses without due process or eminent domain taking.
Delete B.3 "provide for maximum public access to and enjoyment of the shorelines of the city"

23.60.012 Inconsistent development prohibited.
No development shall be undertaken, no shoreline modification shall be made, and no use, including a use that is located on a vessel, shall be established in the Shoreline District …
 Including Vessels within the context of the ordinance is beyond the scope of the Shoreline Management Act. Thousands of boaters repair their boats each year, and even do business from their boats. Those business transactions and repairs including repower, rebuild and making changes to their vessels (boats) should be allowed without special requirements. Requiring all "VESSELS" to be included within the context will result in a significant burden on boat owners as to if they go through the "Hoops" just to make those changes. A vessel or boat is not nor should be considered a shore type structure. It has specific characteristics of which the most important is it can sink, unlike a building. A billion dollar industry in Washington may be jeopardized due to a lack of foresight or over regulation of maintenance for a boat. Further, Vessels are controlled by the Federal Government as to how they operate and function. Additional restrictions from the City of Seattle will result in boats leaving the City causing further loss of marina businesses within the city.
REMOVE any indication that includes VESSEL within 23.60.012
   
23.60.162 Standards for parking and loading zone requirements
B. New off-street parking and parking structures shall be located at least 50 feet from the OHW mark. The Director may modify this requirement to allow parking required pursuant to Section 23.54, for lots that have a lot depth of less than 75 feet of dry-land. In such cases the parking is prohibited within shoreline setbacks and shall be located as far upland from the OHW mark as reasonable.
 The City of Seattle is attempting to significantly curtail the use of vehicles on its city streets. That being said, the maritime industry requires access for navigation and commerce. (navigation on water and commerce on the land) These conditions were required by Congress to build the Lake Washington Ship Canal. Unfortunately to have such commerce on land, access from the land must be furnished via vehicles. Long ago it was wagons. Today it is cars and trucks. Since the City of Seattle is eliminating many of the on street parking spots provisions must be made (to conform to the congressional act) for parking on site. Shoreline restrictions must not inhibit such parking.

Revised should read:
B. New off-street parking and parking structures shall be located at least 50 feet from the OHW mark when reasonable. The Director may modify this requirement to allow parking required pursuant to Section 23.54,

23.60.162 Standards for parking and loading zone requirements
C. 1. New over water parking is prohibited.
2. Existing over water parking areas shall not be expanded or restriped to create additional parking stalls.
 With the advent of smaller more efficient vehicles, motorcycles, and bicycles, it is imperative that effective striping of parking stalls be allowed. This not only efficiently utilizes existing space but encourages economic development of any site.
Delete #2

23.60.164 Standards for regulated public access
C. Minimum Standards
1. Regulated public access shall be provided in the form of any one or a combination of the following physical improvements: Walkway, bikeway, viewpoint, park, deck, observation tower, pier, boat-launching ramp, non-motorized pull-out areas, transient moorage, or other areas serving as a means of view and/or physical approach to public waters for the public. Regulated public access may also include, but not be limited to, interpretive centers and displays explaining maritime history and industry.
2. The minimum regulated public access shall consist of an improved walkway at least 5 feet wide on an easement 10 feet wide, leading from the street or from a public walkway directly to a waterfront use area or to an area on the property from which the water and water activities can be observed. There shall be no significant obstruction of the view from this viewpoint.
3. Maintenance of the regulated public access is the responsibility of the owner or developer.
D. The Director shall review the type, design, and location of regulated public access to insure development of a public place meeting the intent of the Shoreline Master Program. The Director shall apply the following criteria in determining what constitutes adequate public access on a specific site:
1. The location of the access on the lot shall be chosen to:
a. Maximize the public nature of the access by locating it adjacent to other public areas including street-ends, waterways, parks, other public access and connecting trails;
b. Maximize views of the water and sun exposure; and
c. Minimize intrusions ()into privacy for both site users and public access users by avoiding locations adjacent to private windows and/or outdoor private open spaces and by screening or other separation techniques.
2. Public amenities appropriate to the usage of the public access space, such as bike racks, benches, picnic tables, public docks and sufficient public parking to serve the users, shall be selected and placed to promote a usable and comfortable public area. Form Last Revised: July 27, 2011 45 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31
3. Regulated public access shall be located to avoid interference with the use of the site by water-dependent uses located on the site.
4. Public access shall be separated from private uses through landscaping or other appropriate screening unless the private spaces include uses that are open to the public, such as eating and drinking establishments or retail stores.
5. Required public access shall provide connections to trails, parks, and other public amenities wherever feasible.
6. Paths and other public access features shall not disturb trees and shall be sited in locations that result in the least disturbance to native vegetation; and
7. Pedestrian paths shall use pervious material to the greatest extent feasible.
E. Regulated public access may be limited as to types of activities allowed and the Director may approve limited hours of access availability based on location and projected use of the site. However, 24 hour availability is preferable and the access must be available to the public on a regularly scheduled basis.
F. Regulated public access shall be open to the public no later than the time of the Director's final inspection of the proposed development that requires public access.
G. Regulated public access and any related parking shall be indicated by permanent signs provided by the applicant, of standard design and materials prescribed by the Director. The signs shall be located for maximum public visibility and be clearly visible and legible from the right-of-way.
H. All regulated public access points shall be provided through an easement, covenant or similar legal agreement recorded with the King County Department of Records and Elections.
I. For shoreline development requiring more than one Shoreline ((s))Substantial Development Permit or extending for more than 1,000linear feet of shoreline, regulated public access shall be required in the context of the entire project as follows:
1. A shoreline development that requires more than one Shoreline Substantial Development Permit need not provide separate regulated public access for each permit, but regulated public access shall be provided in the context of the entire development.
2. A comprehensive development plan for the entire project shall be submitted with the first shoreline permit application. The plan shall include all project components intended, plans for the regulated public access and a development schedule that indicates when various components of regulated public access will be available for public use. The level of detail of the plans for the regulated public access shall be equal to that of the project proposal.
3. If a regulated public access area for the development has previously been agreed upon during a street vacation process, then the Director shall not require a greater land area for access, but may require development of physical improvements.
4. A minimum of one regulated public access site shall be provided for each 3,500linear feet of shoreline unless public access standards are met elsewhere as part of a public access plan approved by the City Council or public access is not required for the development.
J. General Exceptions.
1. The requirement for one regulated public access site for each terminal or facility may be waived if the terminal or facility is included in a public access plan approved by the Council and the applicant complies with the plan.
2. In lieu of development of public access on the lot, an applicant may choose to meet the requirement for regulated public access through payment-in-lieu or by development of public property equivalent to the regulated public access otherwise required if the applicant's lot is located in an area included in a regulated public access plan approved by the Council and in the City's Capital Facilities Element of the Comprehensive Plan. To be allowed, payment in lieu or development off-site must be allowed by the approved public access plan.
3. Regulated public access is not required or may be modified if the Director has reviewed all reasonable alternatives for public access, including off-site improvements under the control of the applicant, viewing platforms, and separation of uses through site planning and design, and has determined that:
a. The cost of providing public access is unreasonably disproportionate to the total cost of the proposed development, in which case the Director may adjust the required public access so that it is reasonably proportionate; or
b. The site is not located in an area covered by a public access plan approved by the Council, and public access for the site is not part of the City's Capital Improvement Plan that would allow payment-in-lieu or public access development off-site and one of the following conditions exists:
1) Unavoidable hazards to the public in gaining access exist;
2) Inherent security requirements of the use cannot be satisfied;
3) Unavoidable interference with the use would occur;
4) Public access at the particular location cannot be developed to satisfy the public interest in providing a recreational, historical, cultural, scientific or educational opportunity or view; or
5) Adverse impacts to ecological functions that cannot be feasibly mitigated would result.
4. Access to regulated public access may be denied to any person who creates a nuisance or engages in illegal conduct on the property. The Director may authorize regulated public access to be temporarily or permanently closed if it is found that offensive conduct cannot otherwise be reasonably controlled.
K. Public Access Plan. A public access plan shall meet the requirements of WAC 173-26-221(4) and shall be developed through an open public process as provided in WAC 173-26-201(3)(b)(i).
 "C,D,E,F,G,H,I,J K are NOT acceptable for private lands.
Private lands are just that. If the City anticipates taking private lands then they must condemn them and take them according to law.
Requiring public access to any private land is analogous to allowing any public enter your back yard to have a "Pick Nick" when they desire. It is tress pass.
Fifth Amendment - nor shall private property be taken for public use, without just compensation.
Further, it is assumed that the water is considered public for public use. This assumption is in error. DNR leases / permits give the rights of the ground water column and surface to the lessee / permitted. This eliminates the "public sector from using those waters designated under this revision of the SMP. Easements across private property would not give access to publicly owned areas because the DNR has explicitly precluded the public off of the Claimed DNR Public property for a fee. Giving usage rights exclusively to the lessee.
Delete all of C,D,E,F,G,H,I,J,K
23.60.200 Standards for marinas, commercial and recreational
B. 8. In Lake Washington and the Puget Sound overwater projections, boat lifts, and areas used for vessel moorage shall be located a minimum distance of 30 feet waterward from the OHW mark or in a minimum water depth of 8 feet, whichever is less if reasonable. In Lake Union and Portage Bay overwater projections, boat lifts, and areas used for vessel moorage shall be located a minimum distance of 15 feet waterward from the OHW mark or in a minimum water depth of 8 feet, whichever is less, if practicable.
 Marinas will generally moor smaller vessel in shallower spaces and against bulkheads. Eliminating the ability to moor vessels in those shallower areas or have floats near those areas for moorage significantly restricts the use of waters for water oriented activities such as small craft boating. The City of Seattle is making it difficult for trailer boats to navigate throughout the city on city streets. In addition the city is making it difficult to store boats on or near private residential property. The alternative is to moor the small craft. If the draft is deep enough for large vessels to moor then it is in the best economic interest for the marina to accommodate the larger boats. Unfortunately that leaves much of the general public out of the picture because the low draft locations at marinas generally rent for less per foot than the larger vessels and there is over five times more shallow draft vessels than deep draft vessels in Seattle. Restricting shallow draft vessels from mooring in shallow areas will reduce operating capital for moorages and diminish a portion of the billion dollar boating industry from the City of Seattle. An attempt to add clarity by placing "if practicable" to the end of the statute was made. Unfortunately the verbiage relates to either / or and not to elimination of statute if neither is practicable.
Suggest: In Lake Washington, Lake Union and Portage Bay overwater projections, boat lifts, and areas used for vessel moorage shall be located a minimum distance of 15 feet waterward from the OHW mark or in a minimum water depth of 8 feet, if practicable.
23.60.200 Standards for marinas, commercial and recreational
E.c. The minimum public access for a marina providing less than 9,000 linear feet of moorage space is an improved walkway 5 feet wide on an easement 10 feet wide leading to an area located at the water's edge, which shall be 10 feet wide and shall provide 10 feet of water frontage for every 100 feet of the marina's water frontage.
 E 1 b &c is not acceptable.
Private lands are just that. If the City anticipates taking private lands then they must condemn them and take them according to law.
Requiring public access to any private land is analogous to allowing any public enter your back yard to have a "Pick Nick" when they desire. It is tress pass.
Fifth Amendment - nor shall private property be taken for public use, without just compensation.
Delete E 1 b & c
23.60.204 Standards for house barges
A. New house barges are prohibited.
B. House barges that are established by a permit issued by the department prior to the effective date of this ordinance are allowed as non-conforming uses pursuant to Section 23.60.122. A qualifying permit must verify that the house barge existed and was used for residential purposes within The City of Seattle as of June 1990. The Director may invalidate the permit, following notice and a hearing, if the Director determines that the house barge was removed from Seattle waters for more than six months after the permit was issued.
C. House barges that were in existence prior to January 2011 per HB 1783 and after June 1990 shall are allowed and must be registered pursuant to subsection 23.60.204.L. A qualifying house barge must verify that the house barge existed and was used for residential purposes within The City of Seattle as of January 2011.
D. House barges are required to be moored at a recreational marina.
E. House barges must meet state water quality standards and the City's stormwater code, and all overboard discharges are required to be sealed and contain a means for conveying all waste water. F. Owners and operators of house barges shall use best management practices to minimize impacts on the aquatic environment. The best management practices include the following:
1. using non-toxic cleaners and other products used on vessels;
2. eliminating wastewater and sewage discharge by conveying wastewater to an approved disposal facility using a pump out station or a pump out service.
3. disposing of garbage, food scraps, waste material and recyclables into the appropriate on-land receptacles; and
4. securing all outside furniture, barbeque grills, plant containers and other material to ensure that they do not blow away in the wind.
5. using non-toxic building material that are exposed to the elements to eliminate leaching of toxins into the water.
6. using non-toxic cleaning and other household products in outside areas and on exterior structures.
7. not using herbicides, pesticides or fertilizers in outside areas or on the exterior of the structure.
8. using a double containment system when using liquid products on the vessel so that any spills are contained in the second receptacle rather than entering the water.
G. The Director may establish appropriate best management practices to implement the requirements of sub-section 23.60.204.F by Director's Rule.
H. The permit for a house barge is transferable between owners of that house barge, but cannot be transferred to a different house barge.
I. A house barge may relocate to a different recreational marina within the city;
J. If a house barge is removed from Seattle waters for more than six months, the house barge is prohibited from relocating in Seattle waters.
K. House barges cannot expand or extend beyond external dimensions above or below the water.
L. Registration numbers for house barges.
1. The owner of each house barge that is allowedunder subsection 23.60.204.C is required to obtain from the Director a registration number within six months of the effective date of this ordinance and to pay the fee established by the Director to recover the costs of issuing registration numbers. The Director shall determine whether a house barge meets the standard in subsection 23.60.204.C before issuing a registration number. The owner shall display the registration number on the landward side of the house barge in numbers at least 3 inches high in a location legible from the pier.
2. Failure to obtain or correctly display a registration number is a violation of this chapter that is subject to the enforcement process in Chapter 23.90, and does not forfeit the owner's right to maintain a house barge
 If the house barge is a boat by federal standards then prohibitions should not exist.
Liveaboards are allowed according the DNR on public lands under permit of the DNR to various Marinas. The city of Seattle will need to override Washington State who takes precedence over the City of Seattle.
House barges with a means of propulsion and following the US standards for navigation are allowed vessels in the waters of the United States. Additional restrictions attempting to be employed by the City of Seattle beyond those established by the Federal Government should not be applicable including Date of manufacture.
The state of Washington received the waters of Salmon Bay, Lake Union and Lake Washington upon statehood in 1889 under the Equal Footings Doctrine. When the Federal Government accepted the construction of the Federal Ship Canal it was required by Congress to have all of the waters within the ship canal to be deeded back to the Federal Government under the Government control. This happened in 1894 by an act of congress. The ship canal was deeded back to the Federal Government under its jurisdiction. This was necessary due to the vast damage that could exist if the locks ever failed. Included with the requirement of ownership by the Federal Government was a release from damage to the Federal Government (not to the State of Washington or City of Seattle) from every adjacent property owner. The Lake Washington Federal Ship Canal is Federal Waters and not State Waters. (See Bilger V State of Washington)
To restrict "house barges" due to its characteristics which are similar to a "House" are not reasonable.
Houses do not sink, nor are they portable.
The city of Seattle does not meet Water quality standards in that technically the fluoridated water is a contaminant and cannot be released into the receiving waters of the ship canal.
The Federal Government has made significant requirements for boats which also apply to house barges including the type of discharge to the receiving water, disposal of materials including plastics into the receiving waters, the Clean Water Act, etc.
The City restrictions on house barges are a precursor to restrictions on other vessels resulting in the decline in a billion dollar industry in Washington State.
Standards for house barges should be eliminated.
23.60.214 Standards for live-aboard uses on vessels
B. Live-aboard uses are allowed on vessels other than house barges if the vessel is moored at a marina for the particular type of vessel, and if the marina complies with the standards set out in Section 23.60.200.
 This makes no sense?
A vessel is a vessel according to the US Coast Guard. Some vessel are Documented Vessels others are not. If they conform to the Federal Standards then they are allowed on the waters of the United States
Strike totally.

23.60.215 Standards for uses on vessels
Activities and uses on a vessel, except as allowed in subsection 23.60.214.A, that are not customary to that type of vessel are prohibited while the vessel is moored. Customary activities or uses occurring while the vessel is moored are subject to the standards of the applicable shoreline environment unless incidental to the customary use of the vessel or the residential use allowed under subsection 23.60.214.A
 This makes no sense?
The City is attempting to control a federally controlled vessels based upon land law. Vessels fall within Admiralty law which dates back to the venetian times and has many nuances different than Land Law.
In many ways, vessels are similar to trailers, RV's and automobiles however unlike those land vehicles, Vessels have their own Federal guidelines and restrictions as to how they can and cannot be used especially on Federal Waters. An extra layer of vague language from the City will reduce the Boating industry in Seattle and the State, and will result in a disenchantment of a recreation and life style that the Northwest was founded on.
Strike totally.
23.60.216 Standards for vessel moorage
A. Owners and operators of vessels moored in recreational marinas, commercial marinas and other lawful moorages shall use best management practices to minimize impacts on the aquatic environment. The best management practices include the following:
1. using non-toxic cleaners and other products used on vessels;
2. limiting the amount of gray water produced by using less water;
3. disposing of sewage at pump-out stations or through a pump-out service;
4. disposing of garbage, food scraps, waste material and recyclables into the appropriate on-land receptacles; and
5. storing all outside materials in a secure manner so that they do not blow away in the wind.
6. not using herbicides, pesticides or fertilizers in outside.
7. using a double containment system when using products on the vessel so that any spills are contained in the second receptacle rather than entering the water.
B. The Director may establish appropriate best management practices to implement the requirements of this Section 23.60.216 by Director's Rule.
 This is a regulatory issue with licensing the vessel in the State of Washington and not a standard that can be enforced by a Marina.
It should not be included as an ordinance for a particular piece of real estate when the tenant is not permanent.
23.60.924 Definitions -- "L"
"Live-aboard or live-aboard use" means a use that meets the definition of live-aboard vessel".
"Live-aboard vessel" means a vessel that is used as a dwelling unit for more than a total of thirty days in any forty-five day period or more than a total of ninety days in any three hundred sixty-five-day period; or the occupant or occupants identify the vessel or the facility where it is moored as their residence for voting, mail, tax, or similar purposes. Marinas may define "residential use" more narrowly than the above definition, but not more broadly.
 This definition will result in most marinas having 50% or more live-aboards due to the nature of tenants wishing to utilize their vessels and stay aboard during weekends. Additional live-aboard fees will be incurred by boaters who actually do not live aboard.
Live-aboard at our marina is any tenant wishing to stay more than 16 nights/ month which relates to 192 days / year aboard. This is no different than a person who has recreational property and wishes to stay on the weekends at their property.
It is not reasonable to for a person to invest into recreational vehicle and be restricted by the City as to its usage.
Recommend change definition of live-aboard to:
"Live-aboard vessel" means a vessel that is used as a dwelling unit where the occupant or occupants identify the vessel or the facility where it is moored as their residence for voting, mail, tax, or similar purposes. Marinas may define "residential use" more narrowly than the above definition, but not more broadly.

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