Frequently asked Questions
SMP Development Shoreline Classifications/Parameters
What is a Shoreline Management Plan?
A shoreline management plan (SMP) is a comprehensive plan intended to manage the multiple resources and uses of a lake’s shoreline so that they are consistent with a utility’s license requirements and project purposes, and address the needs of the public. The SMP balances the many competing interests associated with the construction of structures along the shoreline.
Why did Appalachian Power Company (Appalachian) develop a Shoreline
Appalachian is licensed to operate the Smith Mountain Project by the Federal Energy Regulatory Commission (FERC.) The Smith Mountain Project includes both Smith Mountain and Leesville lakes. Appalachian has an obligation under its license from the FERC to manage the different occupancy and uses of project lands. This includes the construction of boat docks, piers and erosion control structures. The FERC license for the project includes the requirement that Appalachian manage the lands within the project boundary in such a way as to protect the resources of the project. These resources include the environmental, public recreation, cultural, scenic, and power production resources.
Appalachian developed the SMP to assist with the management of the area within the project boundary. The goal of the SMP is to provide public and private access, protect and enhance the non-power resources (scenic, recreational, and environmental) and the project’s primary function, the production of electricity.
Prior to the approval of the August 29, 2003 SMP, docks serving multi-family type dwellings and docks with more than 10 slips required resource agency review and prior FERC approval. One goal of the SMP is to provide detailed requirements for these types of projects that take into account the protection and enhancement of the scenic, recreational and environmental values so that a project meeting the plan can be approved without additional agency and FERC review. An updated SMP, as approved by FERC Order Modifying and Approving Updated Shoreline Management Plan issued January 30, 2014 is now in effect.
Why does the Federal Energy Regulatory Commission’s interest
extend beyond the power production aspect of the project to the shoreline?
FERC has oversight and regulatory authority over all of the activities and lands within the project boundary at the Smith Mountain Project. Under Section 10(a)(1) of the Federal Power Act, FERC is required to ensure that any project for which a license is issued will be best adapted to a comprehensive plan for improving or developing a waterway for the use or benefit of interstate or foreign commerce, for the improvement and utilization or waterpower development, for the adequate protection, mitigation, and enhancement of fish and wildlife, and for other beneficial public uses such as recreation. In 1986, the Electric Consumers Protection Act amended the Federal Power Act to require FERC to give “equal consideration” to non-developmental interests when issuing a license for a hydropower project. To carry out its responsibilities, FERC has not only the authority, but also the obligation, to ensure that any uses of the project boundary will be in the public interest. To that end, FERC requires the licensee to have sufficient control of the reservoir and shoreline to protect the project’s recreational, scenic, environmental and other public uses.
What is the "project boundary?"
In general, the project boundary for Smith Mountain Lake is the area within the 800-foot contour National Geodetic Vertical Datum (NGVD.) Likewise, in general, the project boundary for Leesville Lake is the area within the 620-foot contour NGVD.
Under what authority can Appalachian Power Company manage
what is being built on the shoreline?
As the licensee, Appalachian has the responsibility and obligation under its license from FERC to manage the different occupancy and uses of project lands. Appalachian is to manage the project lands in such a way as to protect the environmental, public recreation, cultural, scenic, and power production resources of the project. In order to carry out Appalchian’s obligations under its license, property interests within the project boundary in the form of a Flowage Right and Easement Deed were acquired in the late 1950’s and early 1960’s before the project was constructed. These interests are recorded in the respective counties surrounding the lake and are often referred to simply as flowage rights. These Flowage Right and Easement Deeds conveyed interest to Appalachian that run with the land and as such are part of a federally licensed project. Unfortunately, with the rapid pace of development at the lake in recent years, the interests held by Appalachian may have been overlooked and uses of project property have occurred as if “by right” rather than as a privilege. The deeds specify that use of project property by an adjoining landowner is under a revocable license.
Who has been involved in the development of the Shoreline
The SMP was developed with the help of interested individuals, local governments, businesses and state agencies. In its review of the 2003 SMP, Appalachian organized a Steering Committee to provide as open a forum as possible for the development of the SMP. The Steering Committee represented in the development of the 2010 SMP was expanded to include the following groups:
In addition, in order to better understand the issues involved in the review of the August 29, 2003 SMP, as modified, Appalachian and Steering Committee representatives held numerous public and stakeholder meetings to solicit input. In addition to holding meetings open to the public, meetings were held with the following groups:
What is a "Shoreline Classification?"
The SMP includes a shoreline classification system to identify categories of use along the shoreline within the project boundary. The classifications are as follows:
The exact definition of each of the classifications can be found in the Shoreline Management Plan. To define each shoreline classification, parameters were developed by the steering committee. These parameters can also be found in the Shoreline Management Plan.
What is a "Parameter?"
Parameters were developed for defining each type of shoreline classification. The parameters were then applied to the actual shoreline to determine how each section of shoreline would be classified. For example, the parameters for defining shoreline for future Low Density Use structures include:
A complete list of parameters for each shoreline classification can be found in the Shoreline Management Plan.
Why was boating density used as a parameter?
Boat density was considered as a parameter in determining the type of shoreline that is suitable for future high-density boat dock projects. The intent is to not place a high-density use in an area of the lake that currently has an existing high-density boat use. This may be the opposite of how it is done on the land, but on land, additional lanes and traffic lights can be added as traffic increases. The lake is a fixed area that cannot be widened to accommodate increased boat traffic in a narrow cove.
Aerial photos of the lake on 10 randomly chosen holiday and weekend days between Memorial Day and Labor Day 2002 were collected and analyzed. To analyze the number of boats on Smith Mountain Lake, the lake was divided into 209 sections. Smith Mountain was divided based upon natural restrictions and coves on the lake. The boat counts were utilized to develop average boat densities for each of the sections on the lake. Boating patterns are not uniform around the lake, therefore it is inappropriate to apply these standards to the entire lake to determine an average carrying capacity for the entire lake as a whole. By utilizing smaller sections of the lake, boating capacity could be more accurately depicted.
Appendix C of the Shoreline Management Plan contains the results of the boat density mapping.
Where can I get a copy of the regulations to build a dock?
Regulations can be found within the Shoreline Management Plan which is available at www.smithmtn.com or you may request a copy of specific regulations by calling 540-985-2579 or emailing Lisa Hammock at firstname.lastname@example.org.
How are extended side lot lines determined?
According to the SMP, extended side lot lines may be determined in two ways. A developer may show the lot lines as they extend into the water as part of the subdivision plat. These lines may be the extension of the actual side property lines into the water or they may be shown at an angle in order to better accommodate each lot’s dock. If shown on a subdivision plat these extended lot lines are called dock delineation lines. If dock delineation lines are not shown on a plat, then the extended property lines will be the extension of the actual side property line as it goes into the water.
There is another option for showing dock locations. A developer may show actual dock locations on an approved subdivision plan as long as docks are thirty feet apart. This meets the intent of the plan by showing potential property owners where their neighbor’s docks will be located and provides a 15’ setback for each structure.
As a developer, I want to give the owners of off-water lots
in my subdivision a boat dock on the lake. What are my options?
There are several options available to serve off-water lots. A community dock in a low-density use classification allows two slips per 100’ of shoreline. More than two slips / 100’ of shoreline would require location in a High Density Multi-Use classification or a High Density Commercial classification. In a High Density Multi-Use classification, community docks on a subdivision access lot or a courtesy pier with a boat ramp can serve off-water lots provided the structures meet the High Density Multi-Use regulations.
How do you count personal watercraft (pwc) slips?
Lift areas used for storing personal watercraft (e.g. jet skis, wave runners, etc.) are not counted in the total number of slips for the dock as long as the lift area dimensions are not such that it could be used or modified to dock a boat. These lift areas will be included in the overall square footage of the structure.
Why does my permit require the installation of reflectors on my dock?
All dock permits issued after the implementation of the SMP in 2003 include the requirement to install white reflectors on each outermost waterward portion of the structure and every twenty feet on both sides. This is a Virginia Department of Game and Inland Fisheries recommendation to enhance navigational safety by helping to alert mariners of structures on the lake. Vessel operating lights reflected by the white reflectors help operators of vessels underway on the lake to distinguish both floating and permanent structures. Final inspections of docks and assignment of permit applications will not be issued until white reflectors have been installed.
I have a sink on my dock. Do I have to remove it?
Sanitation facilities, including sinks, that existed prior to the implementation of the SMP (August 31, 2003) shall not be expanded or rebuilt. Any future permits will not be issued until such sanitation facilities are removed from within the project boundary.
Can I have a water spigot within the project boundary?
Low density single family properties have the right to withdraw water for domestic purposes (such as landscaping) and the use of a yard hydrant that utilizes lake water would be consistent with this. However, discharge into the lake below the 800 foot contour elevation (from showers, sinks, hydrants etc.) utilizing water from other sources is not permissible.
Does my dock qualify for the Legacy Program?
The Legacy Program applies to any dock or pier in existence as of August 31, 2003 for which Appalachian has not yet issued a permit. The Legacy Program will also apply to any dock or pier for which the appropriate county issued a permit by August 31, 2003 and it was constructed no later than September 22, 2005. Further, a Permit for Non-Commercial Boat Dock/Pier/Landing issued by Appalachian prior to August 31, 2003 and built no later than September 22, 2005 would also qualify. Any modifications/additions after the appropriate date would require compliance with the SMP. See Section 2.6 Documentation Program of the SMP for full details.
Is there a deadline for submission of an application for the Legacy Program?
No. Applications may be submitted at any time. However, the application must contain the specified information to be processed.
I submitted Existing Non-Conforming Structure documentation for my dock in 2005. Do I still need to apply for a permit through the Legacy Program?
Under the Legacy Program, dock or pier owners must voluntarily apply to Appalachian for a permit. However, the Legacy Program was established as a procedure for documenting and administering permits for existing docks by FERC Order Modifying and Approving Updated Shoreline Management Plan issued on January 30, 2014 and replaces the Existing Non-Conforming Structure (ENCS) documentation program. The Legacy Program expands the ENCS to include those people that did not meet the ENCS deadline. The Legacy Program involves the issuance of an Occupancy and Use Permit and as such, is more thorough and more accurate than the ENCS.
Can my dock be rebuilt if it is destroyed if I submitted Existing Non-Conforming Structure documentation for my dock in 2005?
(i) The footprint of existing non-conforming structures may be replaced provided sufficient documentation was submitted and Appalachian has issued an approved Non-Conforming Structure Documentation Letter in response to information provided to Appalachian prior to August 31, 2005 (existing non-conforming documentation) detailing the structure. The following conditions set forth in the SMP also apply,
(ii) The structure was properly maintained and has not been deemed to be a "Dangerous Structure" under Section 2.8 of the SMP (Monitoring and Enforcement);
(iii) Two (2) years has not lapsed since the dock or pier was destroyed;
(iv) The replacement structure does not include habitation or sanitation facilities;
(v) Enclosures exceeding the size or location requirements set forth in the SMP shall not be rebuilt;
(vi) Walkways located between the base elevation and the Project Boundary that exceed the width requirements of the SMP shall not be replaced;
(vii) If the structure is located adjacent to shoreline classified as a Resource Protection Area, then the replacement structure shall to the greatest extent possible maintain a setback of at least 30 feet from the Resource Protection Area;
(viii) The proposed replacement structure conforms to the documentation Appalachian has on file under Section 2.7(a)(i)(1), (2), and (3) above;
(ix) A building permit for the replacement structure is obtained from the appropriate County;
(x) A permit for the replacement structure is obtained from Appalachian that includes verification that the above conditions are met;
(xi) The replacement dock or pier will be placed within the buildable area to the greatest extent possible.
My dock is an existing non-conforming structure but I did not submit Existing Non-Conforming Structure documentation for my dock in 2005. If I obtain a permit under the Legacy Program can the dock be replaced if destroyed?
The structure may be replaced provided the conditions detailed in Section 2.7 Nonconforming Structure Provisions, Replacement of Destroyed or Damaged Structures are met.
I have a Permit for Non-Commercial Boat Dock/Pier/Landing issued by Appalachian Power. When I sell my property should the Permit be issued to the new owners or should they submit an application for the Legacy Program?
Upon the sale of the property, an Application for Assignment of Permit for Non-Commercial Boat Dock/Pier/Landing should be submitted to Appalachian.
My enclosure is larger than allowed under the SMP. If I obtain a permit under the Legacy Program can I rebuild my enclosure to the same dimensions?
No. The enclosure and the walkway, if larger than allowed under the SMP, will be required to be rebuilt according to the SMP in effect at that time.
I have a Permit for Non-Commercial Boat Dock/Pier/Landing issued by Appalachian prior to the SMP. My dock is built according to the Permit but my walkway and enclosure are larger than allowed today. If my dock is destroyed can I rebuild my enclosure and walkway to the same dimensions?
Do I need a permit from Appalachian to install an automatic boat cover on my dock?
An Occupancy and Use Permit is required to install an automatic boat cover only if the boat cover extends beyond the structure, thereby occupying and using additional Project lands and waters. Boat covers that expand the non-conforming nature of a dock are not allowed.
If I installed an automatic boat cover on my dock prior to January 30, 2014, do I need to apply to Appalachian for a retroactive permit?
A permit will not be required if an automatic boat cover was installed prior to January 30, 2014. However, if the automatic boat cover extends beyond the structure, when the property is sold, an application for a new Occupancy and Use Permit will be required rather than an application for an assignment of permit unless the automatic boat cover is removed and is considered to be no longer part of the structure. If the automatic boat cover does not extend beyond the structure, an assignment of permit application is required.
My neighbor has a dilapidated dangerous structure. Is there anything I can do about it?
Appalachian will provide notice to the appropriate County and request that a County Building Inspector be assigned to review and evaluate the structure. The property owner will be notified and will be required to either perform maintenance work or remove the structure. See Section 2.8 of the SMP for full details.
Will I be able to stabilize my shoreline?
Having natural shoreline is beneficial to the lake but it also needs to be balanced with the need to maintain the shoreline where wave action causes bank erosion. There are situations where erosion is not a problem such as natural beach areas or in wetland areas. In these cases, erosion control structures are not necessary.
If there is active erosion, property owners may make application for shoreline stabilization. Property owners are encouraged to consider first the installation of vegetation to control erosion (possible in the backs of coves), then bioengineering techniques (involves both plants and structure) and lastly hard-armoring e.g. riprap. Applications are available under forms.
Will I be able to riprap my shoreline and how do you define
According to the Shoreline Management Plan, riprap will be allowed along the shoreline in areas experiencing active erosion. A definition of active erosion has been added to the plan. Active erosion is defined as areas that are 1) bare and void of vegetation or other stabilizing material, 2) areas that are experiencing undercuts and/or sloughing off of the parent material, or 3) areas directly adjacent to the shoreline that have the potential to deposit sediment or soil material into the lake.
Do I have to replace the vegetation that is removed for the
installation of riprap?
Vegetation does not have to be replaced. However, an AEP representative will work with the property owner to determine the appropriate amount of vegetation necessary to remove in order to install riprap. Existing vegetation to be preserved shall be indicated on a landscape plan to be submitted as part of the Shoreline Stabilization application. Any vegetation removed in excess of the specified amount will be required to be replaced. Trees and woody material removed during the installation of riprap must be collected, bundled and sunk along the adjacent shoreline in water no greater than 20 feet deep so as to replace fish habitat. Applications for Shoreline Stabilization Permit and for a Vegetation Permit are available under forms. The vegetative replacement rate is available in Table 2-5.2 of the Shoreline Management Plan.
Shoreline vegetation is important to the aesthetic qualities, environmental health and water quality of Smith Mountain Lake and Leesville Lake. Vegetation enhances the natural beauty of the lakes, helps prevent water pollution and provides habitat for birds, mammals and fish.
Can I stabilize my shoreline with a bulkhead?
Bulkheads are not the preferred choice for shoreline stabilization due to their associated negative impacts to fish habitat and natural areas. However, there are times when bulkheads are necessary and desirable such as where the bank is very steep. A variance from the FERC would be required before Appalachian could issue a permit for a bulkhead
Will I be able to dredge around my dock?
According to the SMP, maintenance dredging is allowed within existing slip and fairway areas.
Retaining shallow water habitat and not disturbing spawning areas are important to the ecology of the lake. The SMP allows dredging according to certain guidelines. Dredging must be done outside the spawning period of February 15 – June 15. Only accumulated sediment can be removed and original lake bottom may not be altered. Dredging must not occur within 10 feet of any wetland area and dredging cannot occur between 795’ elevation and 793’ elevation in order to retain shallow water habitat. All U.S. Corps of Engineers (ACOE) and Virginia Department of Environmental Quality requirements also apply. Notification to AEP and the ACOE is required for all dredging activities. See Section 2.5.10 of the SMP for full dredging requirements.
Why is Appalachian requiring that vegetative cover be retained
along the shoreline?
Shoreline vegetation is important to the aesthetic qualities, environmental health, and water quality of Smith Mountain and Leesville lakes. Vegetation enhances the natural beauty of the lake, helps prevent water pollution and provides wildlife habitat.
May I maintain my existing lawn?
According to the SMP, if the area within the project boundary was cleared prior to the implementation of the SMP (August 29, 2003) and no vegetation other than grass is present, the property owner may continue to maintain the lawn. However, it is encouraged that a vegetative buffer be reestablished in order to protect the water quality of the lake.
What are the advantages of using native plants along the shoreline?
Native plants are environmentally friendly, require less maintenance and are cost effective, both in the nursery and in the landscape. In other words, they require less pesticides and fertilizer treatments and they conserve water.
Are beaches allowed?
The SMP allows owners of beaches that existed prior to August 29, 2003 to maintain their beaches by adding additional sand above the 795' contour at Smith Mountain and the 613' contour at Leesville. However, these beach owners will have the responsibility to make sure the sand that is added to their beaches doesn’t erode away and decrease the water depth in the adjacent shoreline area. If this occurs, the beach owner may be required to dredge the accumulated sand. Existing beaches may not be expanded and new beaches will not be allowed unless in public use areas or with a variance in the High Density Commercial and High Density Multi-Use classifications.
May I remove woody debris from my shoreline property?
Woody debris is defined as trees and woody material that extend from the shoreline into the lake. The most common type of woody debris is fallen trees where the roots of the trees are still attached or are resting upon the shoreline. Woody debris provides important habitat for fish and wildlife and should be protected. The removal of existing submerged woody debris from the lake that has a diameter of 10 inches or greater at the base of the trunk is discouraged, unless such debris constitutes a navigational or public safety hazard. In the placement and construction of new docks, the removal of woody debris should be minimized. Applicants for shoreline development may be required to mitigate for the removal of woody debris from the lake. Mitigation may involve bundling and sinking the woody debris along the shoreline or underneath the dock in water depths not to exceed 20 feet.
I would like to construct a path to access my dock. How wide can it be and what materials should I use?
Structures located between the project boundary (800 foot contour elevation at Smith Mountain and 620 foot contour elevation at Leesville Lake) and the base elevation (795 foot contour elevation at Smith Mountain and 600 foot contour at Leesville Lake) shall be limited to a structure that provides access to the dock and pilings or cables installed for purposes of enhancing stability of a floating structure. The maximum width of the access structure shall be not more than six (6) feet between the project boundary and the base elevation and must be perpendicular to the shoreline. Access paths should be sited to fit into the character of the land; the path should avoid existing vegetation and wind around existing large trees and shrubs. To minimize the impairment to the overall function of the vegetative buffer and to minimize erosion on the access path, vegetation or additional mulch should be used to cover the exposed soil. If paving material is needed, gravel, stepping stones, or other permeable material may be used especially where there is frequent use, slopes or other factors that would prevent erosion from otherwise occurring. Paths designed for those with disabilities can be made from semi-permeable granular stone compacted to accessible surface. Three or four inches of mulch is the preferred method. It can readily be replaced and holds water. It also adds to the ability for the buffer to remove nitrogen. Impermeable materials, such as asphalt or concrete should not be utilized for access paths.
I own the land in fee below the water level. Do I still have to
comply with the Shoreline Management Plan?
Even though you may own the land underneath the water in fee, the property is still subject to Appalachian’s Flowage Right and Easement Deed that was obtained when the project was built and you will be required to comply with the Shoreline Management Plan.
Are applications available in an electronic format?
The following applications may be downloaded from smithmtn.com.
Applications for others uses may be obtained by contacting by calling 540-985-2579 or by emailing Lisa Hammock at email@example.com.
Does Appalachian charge a fee for a permit?
Appalachian’s license from the Federal Energy Regulatory Commission allows it to charge a reasonable fee to cover the costs of administering the permit program. A study is being conducted to assess what fees are appropriate.
What is the time line for dock approval?
For new docks serving single family uses, there is a 2 week average turnaround time for complete applications. Site inspections are conducted on all properties. If violations are detected, additional time may be required to resolve any unforeseen issues.
Do I need a permit to add a personal watercraft (pwc) lift?
Yes. Any modification to an existing structure or the creation of a new structure requires permission from Appalachian to occupy and use project lands and waters.
Is the Occupancy and Use Permit a building permit?
No, the Occupancy and Use Permit is not a building permit. The Occupancy and Use Permit issued to the property owner is permission from Appalachian Power Company, the licensee of the Smith Mountain Project, to occupy and use Project lands and waters. It is a personal right issued to that property owner and upon sale of property, a new permit must be issued to the buyer so that he/she also has permission to occupy and use project lands and waters. The appropriate county should be contacted following the issuance of an Occupancy and Use Permit to obtain a building permit.
If I expanded my dock without the benefit of a permit, will
I have to mitigate?
According to its license, Appalachian has the authority to grant permission for certain types of use and occupancy of Project lands and waters. Permission is granted only if the proposed use and occupancy is consistent with the purposes of protecting important natural, environmental, recreational and scenic resources. Appalachian has the continuing responsibility to supervise and control the uses of, and ensure compliance with, the permits issued. All new structures and any addition require permission from Appalachian.
Effective November 1, 2010, property owners who have expanded their docks without the benefit of a permit have 30 days upon notice to obtain a permit for the expansion. If the expansion does not meet the SMP, then property owners will have 30 days to remove the unauthorized addition if the structure is a floating structure and 60 days to modify a stationary expansion. If the modifications are not made within this time period, property owners may be given the opportunity to mitigate in lieu of having their permit revoked.
Mitigation has historically involved the planting of native vegetation within the project boundary. Should the project boundary be sufficiently vegetated, the installation of fish habitat may be considered.
When selling lakefront property, how does a seller convey
his Occupancy and Use Permit to the buyer?
All Occupancy and Use Permits issued after the implementation of the Shoreline Management Plan for the Smith Mountain Pumped Storage Project (August 29, 2003), all Occupancy and Use Permits that required prior approval from the Federal Energy Regulatory Commission, and all Permits for Non-Commercial Boat Docks/Piers/Landings must be assigned to new property owners if the property is sold, in essence resulting in a new permit for the new property owners.
The seller contacts Appalachian (firstname.lastname@example.org) to request a status report of the project boundary and any permits issued for the property in question. Appalachian staff researches its records, conducts a site visit if necessary and conveys its findings in writing to the seller. Upon compliance with any permits issued and a satisfactory inspection Appalachian will state in writing that, as of that day and barring no modifications, Appalachian can execute the Assignment of Permit. If the structure is not in compliance with the permit issued or other violations are detected, additional information will be conveyed to the property owner on the actions necessary to obtain compliance.
Is the buyer or the seller responsible for compliance issues?
The seller is responsible for compliance issues. However, if the property sold without the proper assignment requests submitted, then the buyer is responsible and may be required to remove the structure or bring the structure into compliance with the regulations set forth in the Shoreline Management Plan. In either instance Appalachian would ask that a new application for Occupancy and Use be submitted. Appalachian will only issue an Occupancy and Use Permit for structures that meet the Shoreline Management Plan. Modifications to the structure and mitigation may be required.
What types of shoreline or dock maintenance can be done without
What is the appeal process?
If a property owner wishes to appeal a decision made by a Shoreline Management staff member the appeal must be made in writing to Bradley R. Jones, Hydro Manager, P.O. Box 2021, Roanoke, VA 24022-2121.
In addition, any decision may be appealed to the Federal Energy Regulatory Commission.
Federal Energy Regulatory Commission
888 First Street, NE
Washington, DC 20426
How do county zoning laws and Shoreline Management compare?
County zoning is based on land use and goals identified in their respective comprehensive plans. Each has specific language regarding development along the shoreline. Appalachian used this information in the development of shoreline classifications and regulations.
The proposed use will dictate which regulations will apply to the proposed development. When the proposed development is a “lesser” use than the SMP shoreline classification, the regulations for the proposed development will prevail (e.g. a proposed residential dock in an area where the shoreline designation is high-density multi-use is required to meet the low-density use regulations). In addition, if county zoning and the shoreline classification do not match, then the more restrictive regulations will apply (e.g. a dock in a county’s residentially zoned district would have to meet the Low Density regulations, even if the shoreline classification is commercial, unless the County changed their zoning for the upland use).
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