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<br />Michelle McConnell <br />From:Jim Hagen [jchagen@donobi.net] <br />Sent:Tuesday, May 11, 2010 8:49 AM <br />To:Stewart, Jeff R. (ECY) <br />Subject:DOE SMP Public Comment XVII <br />Categories:LASMP Public Comment <br />Public Comment for the Jefferson County Shoreline Master Program. <br /> <br /> <br />CONCLUSION. <br /> <br /> <br />The Locally Approved Shoreline Master Program exceeds the requirements of RCW 90.58 and WAC <br />173-26. It lacks a direct cause-and-effect connection between conditions as they presently exist and <br />as they are likely expected to occur in the future and the corresponding five-fold increase in protection <br />standards. For the purpose of achieving the objectives contained in RCW 90.58.020,please consider <br />the following revisions to the LA SMP: <br /> <br />Ensure that the procedure followed by the Jefferson BoCC in adopting the LA SMP was <br />? <br /> <br />consistent with County and State requirements. <br /> <br />Ensure that the integration of the CAO into the SMP meets current legal standards. <br /> <br />? <br /> <br />Acknowledge that the existing protection standards have been successful in maintaining the <br />? <br /> <br />excellent condition of Jefferson's shorelines. There is no more current, accurate scientific <br />information available than what has proven to work on-the-ground. <br /> <br />Establish the 50 foot buffer recommendation of the Planning Commission as the standard <br />? <br /> <br />prescriptive buffer for all shoreline designations except Natural. Reverse the procedures in the <br />LA SMP and instead of starting large and reducing buffer widths, start with the a twenty foot <br />expansion of what has proven successful and increase buffer widths as needed on a case-by- <br />case basis. Our current code has similar requirements where, for instance, bluffs are present. <br /> <br />Identify a No Net Loss baseline that is based actual conditions as they exist in Jefferson <br />? <br /> <br />County. Before an accurate NNL baseline can be established there must be a real inventory of <br />shoreline development as mandated by WAC 173-26-201(3)(c). <br /> <br />The burden for increasing buffer widths ought to be on the regulating authority. The County <br />? <br /> <br />and DOE have argued in the past they cannot afford to conduct expensive site-specific <br />evaluations, so that cost is passed on to citizens. Citizens are already contributing to the public <br />good through taxation. What makes the County and DOE think citizens can afford the <br />increased cost of modern permitting requirements? It would be interesting to see the result of <br />this LA SMP if more of the financial burden fell on the County and DOE. <br /> <br />Reconsider the wide expansion of the Natural designation. This expansion was notable even <br />? <br /> <br />among the consultants and DOE staff working on the preliminary draft. Review the criteria for <br />WAC 173-26-211(5)(a). The Natural designation is clearly reserved for the most sensitive <br />areas of the shoreline that are intolerant of human use. Designation of 41% of Jefferson <br />shorelines is excessive, requires DOE oversight, and unnecessarily prohibits common <br />shoreline accessory uses that aren't even provided an opportunity to mitigate impacts. <br /> <br />Eliminate the repetitive references to "development that causes the current ecological <br />? <br /> <br />condition to become worse shall be prohibited." Even by DOE's own standard, this is not what <br />the SMA mandates. At least distinguish that these provisions refer to development not <br />identified as a preferred use under SMA, and only only extreme circumstances. <br /> <br />1 <br /> <br />