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<br />Michelle McConnell <br />From:Jim Hagen [] <br />Sent:Wednesday, May 05, 2010 10:18 PM <br />To:Stewart, Jeff R. (ECY) <br />Subject:Fw: DOE SMP Public Comment VIII <br />Categories:LASMP Public Comment <br />Public Comment on the Jefferson County Shoreline Master Program <br /> <br /> <br /> <br />ARTICLE 6, cont. <br /> <br /> <br />6.1.C. Regulations - Cumulative Impacts. <br /> <br /> <br />6.1.C.1. <br />There is enough vagueness in this regulation that it really reads more like a policy. This also <br />invites wide interpretation by the administrator. This regulation should specifiy it is intended for <br />rare instances when extreme circumstances converge so that all mitigating factors <br />cannot successfully achieve NNL. The County intends on assessing cumulative impacts even where <br />exempt, preferred uses are concerned, and if upon their determination they conclude net loss might <br />occur they could deny the permit based on 6.1.B.2. So single-family residences are not in fact <br />exempt? <br /> <br /> <br />Addressing <br />Measuring cumulative impacts is as inexact as no net loss. WAC 173-26-201(3)(d)(iii) <br />cumulative impacts in developing master programs. <br />This section acknowledges "There are <br />practical limits when evaluating impacts that are prospective and sometimes indirect." It goes on to <br />describe how "master program policies and regulations should be developed to assure that the <br />commonly occurring and foreseeable cumulative impacts do not cause a net loss of ecological <br />functions..." Doesn't the SMP when taken as a whole effectively consider cumualtive impacts for <br />commonly occurring and preferred impacts such as single-family residentail? Inclusion of this <br />regulation is another redundancy that adds up to an unnecessary 200 pages. <br /> <br /> <br />6.1.C.2. <br />This regulation requires the applicant to perform the duties the County either cannot or will <br />not conduct themselves (inadequate FSICR and CIA). How can the applicant possibly determine <br />whether their proposed development will create negative cumulative adverse impacts? And from what <br />baseline and projected impacts contained in the FSICR and Cumulative Impact Analysis does the <br />applicant measure their proposal? The County received a $670,000 grant from DOE, a good chunk of <br />which went into the FSICR and CIA, and even then haven't established defensible baselines. This <br />really puts an onerous and subjective burden on the applicant who hasn't been given <br />$670,000. Assess impacts on fish and wildlife habitat, public access/use, aesthetics, and other <br />shoreline attributes?! What other attributes? Who decides what is aesthetically valuable? <br /> <br /> <br />Cumulative Impact Analysis: <br /> This document, written by ESA Adolfson and Associates, provides <br />only a general synopsis of potential future development and impacts. It states in 2.1 that Jefferson <br />County is sparsely populated...and that East Jefferson County has between 1 and 149 residents per <br />square mile." It states "Jefferson County's shorelines are in relatively good shape compared to more <br />developed areas of the Puget Sound basin." (DOE shoreline mangers have gone further in <br />characterizing Jefferson's shorelines as excellent, making it an ideal "pilot project" for the model SMP <br />update.). In section 5.4 the CIA concedes that "in and of itself, residential development probably does <br />not have major adverse effects on shoreline resources." Major impacts are associated construction of <br />1 <br /> <br />