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<br />Michelle McConnell <br />From:Jim Hagen [jchagen@donobi.net] <br />Sent:Thursday, May 06, 2010 9:19 PM <br />To:Stewart, Jeff R. (ECY) <br />Subject:Fw: DOE SMP Public Comment X <br />Categories:LASMP Public Comment <br />Public Comment on the Jefferson County Shoreline Master Program. <br /> <br /> <br /> <br />Backing up to ARTICLE 7: This entire chapter is over-reactive to the impact of shoreline modifications <br />as they exist in Jefferson County. Not to mention that water-dependent uses are preferred by the <br />SMA. The Cumulative Impact Analysis identifies that "A relatively small percentage (less than 10%) of <br />of the County;s shorelines are armored." The CIA also cites data form the assessor's office that 70% <br />of the shorelines has already been developed. The likelihood that shoreline armoring will become a <br />How Does <br />significant contributing factor to degradation is not shown to exist. Section 5.4 of the CIA <br />Residential Development Affect Shorelines? <br />includes concern for armoring but only in general <br />terms, not how this will directly threaten Jefferson shorelines. This concern is characterized by the <br />statement, "Over time a heavily armored shore can lose its beach because sediment sustains the <br />beach is no longer reaching it or staying on the beach." But what does that have to do with Jefferson? <br />We are not, nor are we likely to be, "heavily armored." The same general presumptions are made for <br />common water-dependent uses such as docks, piers, and mooring buoys. Assumptions of future <br />harm, development pressures, and "proliferation" of shoreline accessory uses and modification need <br />to be documented with facts from relevant sources to meet the "reasonably foreseeable" standard. It <br />is interesting that a process where private landowners are beholden to a rigorous "science says" <br />standard conversely allows assumptions on future development to be taken on face value. <br /> <br /> <br />ARTICLE 7, cont. <br /> <br /> <br />7.2 Boating Facilities <br /> <br /> <br />7.2.A.4. <br />Again, the emphasis on "protect the natural character of the shoreline and prevent ( missing <br />significant) adverse ecological impacts..." But these are preferred uses given preference by RCW <br />90.58.020 and WAC 173-26-201(2)(d). It is the rest of the sentence that is actually disturbing, <br />"...caused by in-water and over water structures by limiting the number of new docks/piers/floats and <br />by controlling how they are designed and constructed and where they are located." This is a blatant <br />violation of the law and also suggests that DCD is going into the water-dependent design and <br />construction business. What are the qualifications of DCD staff to perform this kind of work? <br /> <br /> <br />7.2.B. Shoreline Environment Regulations. <br /> <br /> <br />7.2.B.3.ii & iv. <br />Public docks are allowed in the Natural SED as a conditional use but all other boating <br />facilities accessory to residential development are prohibited. <br /> <br /> <br />7.2.B.4. <br />Boating facilities are allowed in the conservancy SED as a conditional use. This subjects <br />69% of Jefferson shorelines to either prohibition or conditional use of preferred, water-dependent <br />uses. <br /> <br /> <br />7.2.F. Regulations - Docks, Piers, Floats, and Lifts - Accessory Development. <br /> <br />1 <br /> <br />