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<br />Michelle McConnell <br />From:linh phuong [] <br />Sent:Wednesday, April 28, 2010 9:11 PM <br />To:Stewart, Jeff R. (ECY) <br /> <br />Subject:Comments to proposed SMP Plan <br />Categories:LASMP Public Comment <br />Dear Mr. Stewart, <br /> <br />I own property located at 911 South Point, in Port Ludlow, and am concerned about the new (SMP ) Shoreline Master <br />Plan and the impact it will have on how I am allowed to use my property. My concerns are as follows: <br /> <br />The SMA policy section (RCW 90.58.20) only requires that a SMP “minimize, insofar as practical, any <br />resultant damage to the ecology and environment of the shoreline area”. Later on, in section 90.58.140, it is <br />stated that projects with “significant irreversible damage to the environment” not be approved. So the Planning <br />Commission recommended uses of the terminology “significant adverse effect” in Articles 7 & 8 are <br />appropriate and the DCD recommended deletion of the word “significant” should have been rejected. <br /> <br />Also, there is absolutely nothing in RCW 90.58 that suggests that a “No Net Loss” policy is appropriate. The <br />“No Net Loss” policy appears out of the blue and permeates the regulations and guidelines (WAC 173-26) <br />spawned by the Department of Ecology and flows into the proposed SMP. That appears to be inappropriate and <br />probably illegal. <br /> <br />RCW 90.58.100 requires that the contents of a SMP must be developed using a “systematic interdisciplinary <br />approach” which includes economics. The costs caused by this SMP must be evaluated verses the potential <br />environmental benefits. Nowhere in this process has anyone been required to quantify the cost of these <br />regulations to the county and to the property owners. <br /> <br /> <br />Going to the “Inventory and Characterization” report generated with DoE funds during the Jefferson County <br />SMP development process, one would hope to find the rational/analysis that led to the recommended Shoreline <br />Designations. We find that the report contains about 200 pages devoted to “characterization” descriptions in <br />general and some application of these characterizations to individual shoreline spans or “reaches”. However, we <br />find no analysis, even though one of the sections is titled “REACH INVENTORY AND ANALYSES”, nor any <br />rational for the designations proscribed in this report. Further, the DCD representative handling the SMP <br />process stated that the “Experts” developing the draft SMP “look at aerial photos to determine the appropriate <br />characterizations”. Therefore, it appears all designations are suspect and in particular the 400% increase in <br />Natural Designations. Finally, the so called science referenced by this report and the DCD is mostly <br />inapplicable to Jefferson County and has not had serious peer review. And finally, there is no indication that the <br />current Jefferson County regulations are not working. <br /> <br />Therefore it seems to me that the DoE must reject this proposed SMP and drop the requirement that No Net <br />Loss be a criteria. Also DoE should demand a cost benefit analysis and an evaluation the effectiveness of the <br />current Jefferson County regulations before any changes are made to the Jefferson County shoreline regulations. <br /> <br />Thank you for your attention on this matter. <br /> <br />Diane Williams <br />1 <br />