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<br />Michelle McConnell <br />From:Tom Brotherton [] <br />Sent:Monday, May 03, 2010 9:38 PM <br />To:Stewart, Jeff R. (ECY) <br />Subject:Comments on Jefferson County SMP <br />Categories:LASMP Public Comment <br />In most areas a well researched document. Several comments: <br /> <br /> <br />1. It is too verbose and needs to have a lot of redundancy removed. <br /> <br />2. The goals, policies, and regulations are disjoint, I.e., there are policies that do not support any goals and <br />regulations independent of all policies. <br /> <br />3. The science supporting 150 foot marine buffers is too thin to be usable. I found only 4 cited research <br />papers addressing effects of marine buffers, and their recommendations differed widely. <br /> <br />4. The science supporting lake, stream, and river buffers was well supported, with over 200 cited papers in <br />general agreement. <br /> <br />5. The vast expansion in natural areas broadly conflicts with the current general zoning of coastal regions as <br />RR 1-5, which, presumably, reflects the will of the community. <br /> <br />6. The Administrative Procedures Act requires a cost/Benefit study for each substantive rule. Since each <br />county's SMP is different and it is a joint state/local rule, it appears a unique study will be required. <br /> <br />7. It differs in several areas from the Port Townsend SMP. While consistency is not required, the differences <br />should be reconciled so that the two SMPs are as compatible as reasonably possible in order to avoid <br />differential treatment of neighbors. <br /> <br /> <br />Thank you for your time. <br /> <br /> <br />Tom Brotherton <br /> <br />255 Cascara Dr. <br /> <br />Quilcene, WA 98376 <br /> <br />360-765-0901 <br /> <br /> <br />1 <br />