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<br />Michelle McConnell <br />From:Chimacum Grange [chimacumgrange@gmail.com] <br />Sent:Tuesday, May 11, 2010 12:04 PM <br />To:Stewart, Jeff R. (ECY) <br />Subject:Jefferson County Proposed SMP Amendment (Res. No. 77-01) <br />Categories:LASMP Public Comment <br />By E-Mail (jeff.stewart@ecy.wa.gov) <br />Jeffrey Stewart, Shoreline Specialist <br />Washington State Department of Ecology <br />P.O. Box 47775 <br />Olympia, WA 98504-7775 <br /> <br />Re: Jefferson County Proposed SMP Amendment (Res. No. 77-01) <br /> <br />Dear Mr. Stewart: <br /> <br />On behalf of the Chimacum Grange and its members I request that the comments submitted by Attorney Dennis <br />D. Reynolds on behalf of the Olympic Stewardship Foundation, an affiliate organization, be incorporated in full <br />as comments from the Chimacum Grange. <br /> <br />In addition, we wish to emphasize the following: <br /> <br /> • Due to our building’s proximity to Chimacum Creek, a listed stream under the proposed SMP <br />amendment, our building will be subjected to extreme additional costs and time constraints of permitting and <br />construction should we experience a loss. We do not believe this was ever an intent of the legislature. <br /> <br /> • We question the inclusion of Chimacum Creek as a stream of significance on two counts. First, as <br />Chimacum Creek runs through the Chimacum Grange property, it is an artificial drainage ditch constructed by <br />th <br />the Army Corps of Engineers which historically was not a natural stream prior to human alteration in the 19 <br />century; secondly, we have serious doubts that the mean annual stream flow of Chimacum Creek was accurately <br />measured and that it falls below the requisite 20 cubic feet per second. <br /> <br /> • The proposed SMP amendment incorporates liberal construction. We insist that liberal construction <br />must also apply to the laws and rules that have forced the SMP amendment to occur. This has not been done. <br /> <br /> • Restrictions on the land available for new agricultural use are overly broad and not in the public <br />interest, given that agriculture performed under best management practices will provide necessary future food <br />for people and fauna. In this matter the proposed SMP amendment violates the intent of the legislature. <br /> <br /> • The county was not diligent in using science to determine text in the proposed SMP amendment. The <br />county failed to identify and assemble the most current, accurate, and complete scientific and technical <br />information available that is applicable to the issues of concern. <br /> <br /> • Re: Unconstitutional Takings of Private Property. Documents made public by Jefferson County <br />indicate that the county was misled by Ecology, and that both the county and Ecology have been remiss in <br />complying with RCW 36.70A.370. <br /> <br />1 <br /> <br />