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<br />Michelle McConnell <br />From:seablues Puddicombe [seablues@msn.com] <br />Sent:Tuesday, May 11, 2010 9:39 AM <br />To:Stewart, Jeff R. (ECY) <br />Subject:Jefferson County SMP update. <br />Categories:LASMP Public Comment <br />May 10, 2010 <br /> <br />WS Dept. of Ecology <br />Mr. Jeffree Stewart <br />PO Box 47775 Olympia, WA 98504 <br />300 Desmond Drive, Lacey, WA 98503 <br />jeff.stewart@ecy.wa.gov <br />(360)407-6521 <br /> <br />Re: Jefferson County Shoreline Master Program <br /> <br />Dear Mr. Stewart, <br /> <br />Please accept the following comments on behalf of the citizens of Jefferson County, and The Coalition to <br />Protect Puget Sound Habitat regarding the Jefferson County Shoreline Master Program update. <br /> <br />* Article 2 – Definitions, number 16, page 2-13. Jefferson County should define hydraulic geoduck harvesting <br />as “dredging” and not merely as a de minimus form of dredging. The Washington State Shellfish Growers <br />Environmental Codes of Practice (ECOP) essentially acknowledges that geoduck harvesting involves <br />“dredging” and results in the “removal of sand, gravel or minerals.” According to the ECOP, “the beach level <br />will be lowered 1-2 inches by the harvest “over an area of acreage. One to two inches equals approximately <br />134 to 268 yards of sediment compaction per acre. This is a significant displacement of material and cannot be <br />considered “a trifle” or a de minimus. <br /> <br />* Article 2 – Definitions, number 43, page 2-42. Jefferson County should define geoduck tubes as a structure. <br />The AGO incorrectly concluded that geoduck operations do not involve the construction of structures. First, the <br />AGO incorrectly concluded that the PVC tubes themselves are not structures. The AGO completely <br />disregarded that part of the definition that states that a “structure” is “any piece of work artificially built”. It is <br />that phrase in the definition that makes clear that the PVC tubes are “structures”. Also, the opinion erred when <br />it focused solely on the individual tubes and not on the entire configuration that is constructed on site. Pierce <br />County Hearings Examiner Terrance McCarthy ruled, after several days of expert witness testimony during the <br />“Foss/Taylor Appeal in 2007, that geoduck farms are indeed a “structure”, that they “obstruct public use” of the <br />water, and that they cause “habitat disruption”. <br /> <br />* Article 8 – 2. Aquaculture; A. Policies, page 8-3; numbers 1 and 2. Jefferson County should more fully apply <br />the SMA guidelines in its description of aquaculture as a preferred, water dependent use. Some language <br />should be included to acknowledge that aquaculture is not a preferred use if it results in any loss of ecological <br />functions; if it adversely impacts eelgrass and microalgae; if it conflicts with navigation and other priority water <br />dependent uses such as swimming, fishing, wading, water skiing, etc.; or if it impacts the aesthetic qualities of <br />the shoreline. Under the guidelines, many aquaculture techniques, including geoduck aquaculture, do not <br />1 <br /> <br />