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<br />Michelle McConnell <br />From:Jim Hagen [jchagen@donobi.net] <br />Sent:Wednesday, May 05, 2010 7:56 AM <br />To:Stewart, Jeff R. (ECY) <br />Subject:Fw: DOE SMP Public Comment I <br />Categories:LASMP Public Comment <br />Public comment on the Jefferson County Shoreline Master Program. <br /> <br /> <br /> <br />----- Original Message ----- <br />From: <br /> Jim Hagen <br />To: <br /> jkramer.consulting@gmail.com ; cmacilroy@gmail.com ; mclancy@esassoc.com <br />Sent: <br /> Friday, March 19, 2010 8:12 AM <br />Subject: <br /> Draft SMP White Paper Comments <br /> <br />Jim Kramer <br /> <br />Carol MacIlroy <br /> <br />Margaret Clancy <br /> <br /> <br />This draft white paper appears to strongly hint that the ambitious scope of the post 2003 SMP <br />update is exceeding the resources local jurisdictions and the Department of Ecology are able to <br />provide. The conclusion reached in the final section - Capturing the Opportunities - suggests that <br />acquiring the necessary resources to successfully implement SMPs involves expanding local <br />oversight to bring in "business and environmental interests and then working with State staff, <br />legislators and the governor to increase strategic investments for the protection of Puget Sound's <br />shorelines." This indicates that the DOE has first of all underestimated the complexity and expense of <br />updated SMP requirements and second, that the model SMP update remains in the prototype <br />phase and despite being in a continual state of fluidity, jurisdictions such as Jefferson County are very <br />shortly going to have to live with the very certain consequences of this costly experiment. <br /> <br /> <br />If private property is going to be regulated for the general benefit of the environment, it is the <br />responsibility of the public interest to first have developed an accountable system it is prepared to <br />administer, implement, and monitor. What this white paper is admitting is the state is approaching the <br />half-way of state-wide updates and there are still many unanswered questions. That is an <br />unacceptable when landowners are being asked to make very certain sacrifices. <br /> <br /> <br />An important element of land-use planning in Washington state is a locally-driven, bottom up <br />approach. The GMA grants deference to local decision making as long it it is in compliance with the <br />intended purpose and goals. Continuous and ongoing public participation is also a critical element in <br />ensuring that those directly effected by regulations have a key voice. RCW 90.58.050 describes a <br />collaborative effort between the DOE and local jurisdictions. It mentions nothing about outside <br />agencies and non-governmental environment interests assuming prominent roles in overseeing <br />adminstration of local regualtions. <br /> <br /> <br />Several statements in the white paper appear to hint that to increase funding and resources, local <br />SMP update processes need to be brought under a wider umbrella. On page four the white paper <br />states that accounting for no net loss needs to occur on three levels, including a "Sound-wide level." <br />That is currently beyond the legal requirement of meeting no net loss on a jurisdictional level, not to <br />1 <br /> <br />