Welcome to the South Portland 2040 Comprehensive Plan Comment Period! 

Typo: Remove "the"

Quotes are found throughout this document, but I haven't seen one attribution. Did AI write the 'quotes'? They don't come across as authentic.

Real historical preservation would be to designate the (Liberty) shipyards as Rural/Conserve and create a monument to honor and remember the dozens of families whose homes were taken by eminent domain and to the 30,000 shipyard men and women who built over 250 Liberty Ships.

What happened to protecting open space? You are inviting 3 story buildings into what is now Bug Light Park.

It's delusional to imagine that South Portland's residents wouldn't be horrified at the prospect.

While the City is "discouraging" high volume traffic, Broadway will be in gridlock if this is the totality of your traffic plan. Broadway cannot handle dense development in the shipyard area. The Cushing's Point Transportation Study came to the same conclusion. Nothing written in section C has any teeth. Nothing

How do you propose to maintain Bug Light Park for public use when you're inviting 3 story buildings into its southern half?
The whole area should be a park, but you want to endanger the treasured little park that we do have.

How do you plan to enhance or preserve public views? Three story glass buildings?

What build-out? The community has indicated time and again, year after year, that they do not want a 'build-out' on the eastern waterfront on or near toxic soils, tank fumes, flooding, traffic congestion.

This is confusing. Why aren't these growth zones aligned with zones -- Rural, Transitional, Growth -- that the State recognizes?

Yes, 330 submissions, and 62% of the community chose to avoid development in the shipyards, or D. But the Planning staff insisted on combining B and C (B actually aligns with A-growth, and C aligns with D-avoid) to completely skew the results and resulting analysis.

Why does the Plan have 6 growth designations (the 6th is B-C, even though B is Limited, while C is growth), when the State, as is mentioned a paragraph ago, identifies 3 growth designations: Rural, Growth, Transitional. From the get-go, this plan mis-aligns itself with the State's recognized designations and sets the stage for confusion.

Maybe if the city listened and took action to support what residents wanted like their overwhelming choice to avoid growth in the Eastern Watefront, they would actually feel empowered.

Or the time the CPC sent a full room of residents (about 80) out of city hall because they were too busy doing the wrong work. The reason the residents were there was to tell them their work did not represent their wishes. Yes I am sure that made them feel empowered. Why don't you add that?

The present library was constructed in 1967, not 1907.

Contrary to some comments here, I believe strongly that relying on other entities like EPA or Maine DEP is false hope. They are not prepared for making the current or future owners responsible for the environmental clean-up. South Portland needs to ensure that it protects its citizens with exercising control and standards of clean-up.
Again as stated in Lincoln St comment, the City needs to assess, define and impose financial security (Bonds) for the eventual clean up of these properties.

I personally have not seen any documented shift away from Petroleum Storage as this says. Tere is lots of hoping but it seems like all the tank farms are there and are licensed.

HOWEVER, I have seen bias by top city hired management to get residential development to be within "a stones throw" away from Petroleum Storage facilities.

When a development is next to a Park where parking on weekends is at peak for both residents and park visitors; the assumption that everyone will not buy cars and instead will use public transportation places Park vistors parking access in jeapordy. Please don't block everyone's way to visit Bug Light Park.

PARKING - Planning has a concept they are placing throughout the city, "shared parking". The intent is to use the same space when the work schedule timing/needs allow. Its critical to understand that concept does not work next to Bug Light Park because on weekends the Park and the nearby developments need for parking will be at their peak simultaneously. Nearby developments must require national standards for parking requirements and also must not be allowed to use the special parking reduction that a bus stop ,allows in this plan.

Add map showing 8.8 ft sea level rise flooding under high tide scenarios.

J.11. Replace with:

New subdivision patterns must mirror the residential scale of Ferry Village but must be designed as internally-oriented blocks. These patterns shall not be used to create new vehicular thoroughfares into Ferry Village. All new blocks are engineered to the 8.8 ft sea-level rise standard to prevent floodwater displacement onto existing properties or roads for safety and property damage reasons.

Reason:
This change protects the neighborhood’s character by ensuring new road construction matches the scale of existing streets, new "shortcut" roads that put new car traffic onto quiet side streets. By requiring all new blocks to meet the 8.8 ft sea-level rise standard, the policy ensures that roads have required drainage/water pumps etc. so as to not to displace floodwater or runoff into the yards and basements. Essentially, it keeps Ferry Village from becoming a high-traffic cut-through area for new development.

J.10: Replace with:
No development shall be approved that adds vehicle volume to Broadway, its connected arterial corridors, major and minor collectors, the local residential street network, or the Casco Bay Bridge corridor until these roads can offer a safe Level of Service (LOS) of 'C' or better. All traffic impact studies must be performed by a City-appointed independent consultant, paid for by the developer. Street network upgrades shall be strictly limited to safety and transit infrastructure; increasing vehicle lane capacity through road widening on Broadway or its connected arterials is prohibited. Development that exceeds these infrastructure and safety thresholds shall be denied.

Reason:
Vague terms like "minimized" or "discouraged" are unenforceable The Casco Bay Bridge and Broadway are already at or above safe traffic capacity with a failing Level of Service D. New development will mean more traffic, filling up the roads even further, forcing cut-through traffic onto residential side streets like Ferry Village or Preble Street/Cottage Road. The City must prohibit widening Broadway (which would require eminent domain to take houses) and instead require that the entire connected road network maintain a safe Level of Service C (through 3rd party independent study). If a project exceeds these safety and infrastructure limits, it must be denied.

J.8 Replace with:

8. Limit Vehicular Connectivity to Protect Residential Streets. New street patterns shall prioritize pedestrian and bicycle connectivity to adjoining neighborhoods. New through-traffic vehicular connections into Ferry Village are prohibited to prevent "cut-through" traffic on residential side streets. Any new road infrastructure must meet the 8.8 ft sea-level rise standard and must not be elevated so that it would cause flood channeling into surrounding neighborhoods.

Reason:
We want people to be able to walk and bike between neighborhoods, but we do not want thousands of new traffic trips back and forth from the Shipyard to use quiet side streets as a shortcut to bypass Broadway traffic. This change protects Ferry Village and Willard Square areas from becoming a high-traffic bypass zone while keeping the "walking" connections open.

Furthermore, we must ensure that roads are not elevated to accomodate or fight accelerating and worsening sea level rise flooding. Elevated roads could act like a "dam" that pushes floodwater and rising groundwater into the basements of existing Ferry Village homes for example or flood other roads, preventing emergency vehicle access. We all have to think LONG TERM because climate change and accelerating sea level rise is REAL and will get worse over time.

J.7 Replace with:
Prohibit new heavy freight-generating industry. The City shall prohibit any new land use that increases heavy freight volume on the Broadway corridor or surrounding streets. Existing freight must be strictly managed to ensure total corridor volume provides an acceptable Level of Service (LOS) for emergency response times and provides acceptable driver safety for residents.

Reason:
Safety: "Discouraging" is unenforceable; caps or limits are required to ensure industrial use does not compromise residential safety. On a one-way-in, one-way-out road ie Broadway, a single stalled or slow-moving freight truck can paralyze the entire neighborhood. We must prioritize "Life-Safety-Traffic" (ambulances/evacuations/resident travel) over "Industrial Traffic.". And we do not want heavy freight trucks driving through family neighborhoods like Ferry Village.

Replace with:
Require substantial, interconnected, and publicly-accessible open spaces that link directly to the Greenbelt Walkway and prioritize permanent public ownership to ensure long-term community access. Substantial means at least 10% (?) of the land area.

Reason:
define substantial as this is a vague term and can be interpreted in many ways; open space, rec aras and access to the green belt are valuable to the community.

J. 5 Replace with:

5. All contaminated soils must be remediated to residential health standards and certified by an independent third party. Remediation must be engineered as permanent infrastructure capable of withstanding the 8.8 ft sea-level rise standard under high tide/storm surge conditions to prevent the mobilization of toxins in the ground into the groundwater, other land or surface areas, vapor in buildings or leaching into Casco Bay.

Reason:
Infrastructure Safety: To meet the Standard of Stability and public safety, soil must withstand sea-level rise standards for residents and visitors.

We cannot just "cap" the contaminated land and place 12" of fresh soil and assume all is well. As sea levels rise, the groundwater underneath the Shipyard rises too. This "rising tide from below" can soak into old contaminated soil, salt water may weaken the cap material and float toxins up to the surface, the air or even vapors leaking into buildings. To ensure safety, brownfield cleanup should hold even when the ground is fully saturated by a 8.9 sea level rise (and acceleration of SLR in future).

I’m think the Bug Light area should h designated limited growth because it is enjoyed by families from all over the greater Portland metro area.

J.2: Replace with ("considered" is weak, instead mandate this to avoid harm and damage)

Building heights and accompanying land elevation are compatible with adjacent neighborhoods and height flexibility shall not cause consequential flooding in other downstream areas, as evidence with engineering study.

Reason:
Liability: Prohibits raising sites in a way that displaces floodwaters into adjacent properties or causing roads to be flooded (safety issue for evacuation, Fire/EMT etc.)

J.1. Replace with:
The City shall mandate that all development in the Shipyard District adhere to the most current 'Prepare to Manage' scenario of 8.8 feet of sea level rise under high tide and storm scenarios. Because climate projections and the standards of the forthcoming Coastal Resilience Overlay Zone (CROZ) are *dynamic* and sea level rise is accelerating, all project approvals must be contingent upon compliance with the updated hydrodynamic modeling and science-based projections adopted by the City at the time of construction, ensuring no project is 'grandfathered' into outdated safety standards. ***The CROZ shall be updated as sea level rise projections change and shall be a dynamic standard applying to all development in the area and supercede or take precedence over the related sea level rise standards in the Comp Plan 2040.

Reasons:
"Protecting the City's Legal and Fiscal Future"

The rationale for this specific language is to prevent a 'Policy Gap' between the Comprehensive Plan and the upcoming CROZ.

1. Avoiding Legal Conflict: If the Comprehensive Plan is approved with vague or outdated standards, any future attempts by the CROZ to mandate the 8.8-foot standard could be struck down in court as 'inconsistent with the Comp Plan.' This language ensures the Comp Plan explicitly authorizes the higher standards of the CROZ.

2. Eliminating the 'Race to the Bottom': Without the 'No Grandfathering' clause, developers may rush to file applications the day after the Comp Plan passes to 'lock in' lower, less expensive safety standards before the CROZ is finalized. This would result in buildings that are obsolete and hazardous before they are even finished.

3. Fiscal Protection: By mandating that projects must meet the most current science at the time of construction, the City shifts the liability away from the taxpayers. We are ensuring that new developments are self-sufficient and do not become 'drainage burdens' on the Broadway corridor or require emergency municipal intervention during the 8.8-foot flood events we already know are coming.

4. Preventing Liability: If the City allows a developer to build at an unsafe elevation today (like 14 feet), and that building floods or causes neighboring streets (like Broadway) to flood tomorrow, the City could be held liable for negligence. The rationale here is fiscal protection: the City is requiring a higher standard now to avoid massive taxpayer-funded bailouts or infrastructure repairs later.

I. Replace with (need stronger language)

Mandate Coastal Resiliency Plans. All petroleum operators must submit a certified plan as a condition of their municipal license. Facilities must prove that all tanks, dikes, berms and electrical systems are fortified to the 8.8 ft sea-level rise standard (or updated as sea levels rise). Approval requires an independent audit verifying that storm surges or rising groundwater will not mobilize oil into Casco bay or the neighborhood.

Reason:
"Working with" operators is weak and will not resulted in the level of protection we need. We are making resiliency a legal requirement. This mandate ensures that every tank in our city is engineered to stay sealed and grounded, even in the worst-case flood scenarios, protecting our water and our homes.

H. Replace with:
Set Performance Standards for Clean Energy. While attracting clean energy, the City shall prohibit industrial-scale acoustic pollution, low-frequency vibration, and shadow flicker from oceanfront turbines. All energy infrastructure must prove it will not degrade the health or quality of life of nearby residents or the environment or birds/fish habitat etc.

Reason:
"Clean" energy doesn't automatically mean "quiet" or "compatible." For example, large turbines can create constant low-frequency humming or flickering shadows that make living nearby unbearable. As petroleum tanks become decommissioned (hopefully), we don't want a new type of industrial nuisance in the neighborhood or anything that would harm the environment or birds/fish.

G. Replace with:
Establish a mandatory Annual Operating License for all industrial facilities. Renewal is strictly contingent upon providing independently verified, real-time data proving that all emissions—including burst events and venting—stay below health safety levels. Failure to meet these standards or provide public data results in the immediate suspension of the municipal operating permit.

Reason:
"Investigate the feasibility" is weak language and provides no protection to the residents and visitors to the area. An Annual License gives the City more control to protect citizens. This ensures that the industry's right to operate never matters more than the citizens' right to healthy air.

f. Replace with:
Mandate complete REAL TIME fenceline monitoring for all industrial/petroleum facilities. The City shall require real-time public access to data and mandatory immediate notifications for the neighborhood when any toxic emissions spike above safety levels.

Reason:
Tracking is only useful if it leads to action. By requiring "complete" real time monitoring and "mandatory notifications," the City ensures that neighbors aren't kept in the dark about the air they breathe. This protects families and vulnerable people and children by giving them the real-time information they need to stay safe during a leak or a malfunction.

NEW (add)

Before any new development is approved, Mandate or require an Evacuation Capacity & Cumulative Impact Audit to analyze how any proposed land elevation (fill) or building density will impact regional flood patterns and emergency egress. The audit must account for 8.8 feet of Sea Level Rise during high tide storm surges as required for critical infrastructure and prove (with engineering study) that elevating new development will not divert floodwaters onto existing roadways or adjacent properties, thereby compromising the only available evacuation routes for current residents.

Require bicycle and pedestrian paths that link to adjoining neighborhoods. All paths must be engineered to the 8.8 ft sea-level rise standard to prevent them from acting as flood channels into the community.

Reason:
If a developer build up the land 14ft for example to keep a new building dry, that displaced water (from sea level rise/storm surges) has to go somewhere. This required audit ensures that water doesn't get pushed onto Broadway or into Ferry Village. We must prove that "saving" a new building doesn't mean "sacrificing" other flooded homes or the neighborhood's only evacuation route.

We want a walkable neighborhood, but those paths shouldn't turn into "water highways" during a storm. By requiring them to be built to the City’s flood safety standard, we ensure that paths do not accidentally increase the flood risk for existing homes nearby.

NEW (additional)
The City must mandate a Certified Traffic & Emergency Response Audit as a condition for any development plan approval or Occupancy permit in the Shipyard District. This audit must provide empirical evidence that the single-access Broadway corridor maintains adequate 'Level of Service' (LOS) during peak hours, specifically ensuring that Fire and EMT response times meet NFPA safety standards despite current over-capacity conditions. Approval shall not be granted until it is evidenced that regular citizen traffic and emergency vehicles can navigate the corridor safely and efficiently.

Reason:
Broadway is a "bottleneck" with only one way in and out. The City has a duty to ensure that new residents don't create gridlock that prevents an ambulance from reaching a heart attack victim or a fire truck from reaching a house fire. This audit makes sure the road is safe for the people already living there before we add more traffic. Relying on walking, bikes, buses is not realistic in Maine and is a plan for failure.

E. Replace "possibly"... with
...Impact Fees must pay for necessary Traffic and Emergency improvement and Audit. No building or development plan would be allowed or occupancy permits until it is proven that traffic capacity is at safe levels for all residents and that Fire/EMS can get through Broadway traffic safely with minimum level of service. A plan needs to be in place well before any development plan is approved.

Reason:
New development should ensure and not degrade the safety of existing residents or Fire/EMT. An independent audit ensures that the road network can still support life-saving emergency response times before new people move in and traffic should be at safe levels for all residents

D. Replace with:
Establish continuous, publicly accessible shoreline paths through property acquisition or development requirements. All shoreline access must be engineered as flood-resilient infrastructure to the 8.8 ft sea level rise standard to ensure public safety and prevent paths from acting as channels for storm surge into the neighborhood.

Reason:
Shoreline paths are great, but they must be built correctly. If they are built too low, they become "low points" that allow ocean water to rush into the streets during a storm.

NEW to be added:
1.5 off-street parking spaces per unit within 500 feet of all residences shall be provided and adequate parking for all business development shall be provided.

Reason:
Adequate on-site parking is a *safety necessity*. Without it, cars will overflow onto narrow side streets like in Ferry Village, which can block fire trucks and ambulances from reaching homes in an emergency.

C. This language is vague ("strive to provide") and can lead to unintended consequences. Suggest putting a cap on type of housing mix (for example no more than 25% can be lodging etc.).

Additional:
Also, residential should not be allowed because of the health and safety issues: VOCs emitted from tanks causing health issues, sea level rise is accelerating can mobilize brownfields to surface or other areas or cause chemical vapor to enter buildings. Also SLR damage to infrastructure and buildings will be ongoing as seas rise and storm surges worsen. This also poses a safety issue for Fire/EMT and evacuation of residents as in the main road out (broadway) can become flooded etc.

B. Replace with:
Establish a mandatory 1,000-foot 'Public Health Safety Buffer' around all bulk petroleum storage facilities and a 'Coastal Resilience Buffer' within the 8.8-foot Sea Level Rise inundation zone; new residential development is prohibited within these buffers. For any non-residential use allowed on brownfield sites within these zones, the City shall require full excavation and removal of contaminated soils to residential standards, rather than soil capping, to prevent the mobilization of toxins into Casco Bay and neighboring properties as sea levels and groundwater tables will continue to rise at an accelerated rate.

Reasons:
Establishing mandatory buffers for VOCs, Sea Level Rise and Toxic Brownfields is essential to protect public health AND the city’s fiscal future. These concerns are rooted in the City’s own data and past industrial history.
1) VOCs: Already, petroleum facilities like Global and Sprague were sued for emitting twice the legal VOC emissions limit. Fenceline monitoring continues to show spikes of dangerous levels of cancer-linked chemicals. We need a mandatory 1,000-foot buffer to stop placing new residents in this proven "hazard zone” (especially children, aged people, or those with health issues).
2) Sea Level Rise: South Portland has officially adopted an 8.8-foot "high scenario" sea level rise target for long-term planning. And Sea levels are rising at an *accelerated rate*! Allowing new residential development in these inundation zones is physically dangerous and creates a "never ending COST" for taxpayers to maintain failing infrastructure, not to mention the safety issues like ensuring Fire/EMT can reach people in emerging flood zones. Furthermore, private flood defenses like berms or raising the ground by 14 feet can cause a "fortress effect," displacing floodwater onto neighboring properties and public streets.
3) Brownfields: Much of the ground is contaminated with toxic chemicals like PCBs. Capping them with only 12” of soil (like 149A Front Street on Casco Bay) is insufficient for areas prone to 8.8-foot tides, storms, and flooding which will worsen because sea levels are RISING and an ACCELERATED RATE. When these areas flood, rising groundwater will mobilize buried toxins, flushing them directly into Casco Bay and the surrounding grounds. For any future projects, the City should require full soil excavation to residential standards rather than cheap capping to prevent permanent environmental and financial liability and to protect the health of everyone including the most health-vulnerable people.

Define "evidence based". For example, when mapping including waves, does that mean wave height as determined and as detailed as FEMA has published them? Does it mean we will pick the lower or higher projections? What specifics will we use for Storm Surge and Tidal levels?

The Executive Summary of the Scientific Assessment of Climate Change for 2024 from the Maine Climate Council makes clear that planning must think beyond 2100. It states that by 2100, projected sea level rise reaches:
“8.4 inches per decade under the Intermediate (RCP 4.5) scenario and 1.2 feet per decade under the High (RCP 8.5) scenario.”
At a pace approaching one foot of sea level rise every decade, continuing to plan as if today’s shoreline will remain viable is not realistic. Sea level rise DOES NOT STOP. This isn’t a distant or abstract problem — it is a foreseeable, accelerating condition. Failing to plan for higher ground now doesn’t avoid the cost; it simply guarantees that our children and grandchildren will pay far more, with fewer options and higher risks.

The Executive Summary of the Scientific Assessment of Climate Change for 2024 from the Maine Climate Council makes clear that planning must think beyond 2100. It states that by 2100, projected sea level rise reaches:
“8.4 inches per decade under the Intermediate (RCP 4.5) scenario and 1.2 feet per decade under the High (RCP 8.5) scenario.”
At a pace approaching one foot of sea level rise every decade, continuing to plan as if today’s shoreline will remain viable is not realistic. Sea level rise DOES NOT STOP. This isn’t a distant or abstract problem — it is a foreseeable, accelerating condition. Failing to plan for higher ground now doesn’t avoid the cost; it simply guarantees that our children and grandchildren will pay far more, with fewer options and higher risks.

The Executive Summary of the Scientific Assessment of Climate Change for 2024 from the Maine Climate Council makes clear that planning must think beyond 2100. It states that by 2100, projected sea level rise reaches:
“8.4 inches per decade under the Intermediate (RCP 4.5) scenario and 1.2 feet per decade under the High (RCP 8.5) scenario.”
At a pace approaching one foot of sea level rise every decade, continuing to plan as if today’s shoreline will remain viable is not realistic. Sea level rise DOES NOT STOP. This isn’t a distant or abstract problem — it is a foreseeable, accelerating condition. Failing to plan for higher ground now doesn’t avoid the cost; it simply guarantees that our children and grandchildren will pay far more, with fewer options and higher risks.

The Executive Summary of the Scientific Assessment of Climate Change for 2024 from the Maine Climate Council makes clear that planning must think beyond 2100. It states that by 2100, projected sea level rise reaches:
“8.4 inches per decade under the Intermediate (RCP 4.5) scenario and 1.2 feet per decade under the High (RCP 8.5) scenario.”
At a pace approaching one foot of sea level rise every decade, continuing to plan as if today’s shoreline will remain viable is not realistic. Sea level rise DOES NOT STOP. This isn’t a distant or abstract problem — it is a foreseeable, accelerating condition. Failing to plan for higher ground now doesn’t avoid the cost; it simply guarantees that our children and grandchildren will pay far more, with fewer options and higher risks.

The Executive Summary of the Scientific Assessment of Climate Change for 2024 from the Maine Climate Council makes clear that planning must think beyond 2100. It states that by 2100, projected sea level rise reaches:
“8.4 inches per decade under the Intermediate (RCP 4.5) scenario and 1.2 feet per decade under the High (RCP 8.5) scenario.”
At a pace approaching one foot of sea level rise every decade, continuing to plan as if today’s shoreline will remain viable is not realistic. Sea level rise DOES NOT STOP. This isn’t a distant or abstract problem — it is a foreseeable, accelerating condition. Failing to plan for higher ground now doesn’t avoid the cost; it simply guarantees that our children and grandchildren will pay far more, with fewer options and higher risks.