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<br />Michelle McConnell <br />From:Jim Hagen [jchagen@donobi.net] <br />Sent:Monday, May 10, 2010 12:30 PM <br />To:Stewart, Jeff R. (ECY) <br />Subject:DOE SMP Public comment VII, cont. <br />Categories:LASMP Public Comment <br />Public comment on the Jefferson County Shoreline Master Program. <br /> <br /> <br /> <br />6.1.B. 2., cont. <br />The dictate for an outright prohibition on developments that cause a net loss of <br />ecological functions is found here and in several other places in the LA SMP. An undated Ecology <br />"No Net Loss of Ecological Functions" <br />document acquired from a public records request titled <br />addresses the standards, meaning, and implementation of NNL. This document poses the question, <br />Does this mean that an SMP must prohibit all development that will result in a loss of <br />" <br />shoreline ecological functions? No <br />Answer. 1. . Current available science tells us that all types of <br />shoreline development produce at least some degree of impact to ecological functions. Some <br />preferred uses as set forth in the SMA are among those developments which impact shoreline <br />function. The 'no net loss of ecological function' standard means that updated SMPs must contain <br />provisions for mitigating these unavoidable impacts, for instance by restoring degraded shorelines <br />identified in the locally prepared shoreline inventory and analysis." <br /> <br /> <br />Please reconcile that interpretation with the many outright prohibitions contained in the <br />Jefferson LA SMP. <br /> <br /> <br /> <br />6.1.B. Regualtions - No Net loss and Mitigation. <br /> <br /> <br />6.1.B.1., cont. <br />Lacking any inventory of the "extent of existing structures" as required in WAC 173- <br />26-201(3)(c), it isn't possible to establish a meaningful No Net Loss baseline. Protection of ecological <br />functions does not occur in a vacuum. An essential component of the NNL equation is the <br />corresponding impact of development. This must be determined in as rigorous a fashion as the <br />science used to identify ecological processes and protection standards. If the environmental science <br />were applied as casually and with the same undocumented assumptions as the development impacts <br />have been analyzed it would fail all legal tests. <br /> <br /> <br />"No Net Loss of Ecological Functions""How do <br />Again referring to the document, the section titled <br />local jurisdictions demonstrate no net loss in their SMPs?" <br />lists eight steps toward <br />accomplishing NNL. <br /> <br /> <br />2.b. <br />advises "projecting 'reasonably foreseeable future development' over a minimum 20 year <br />planning period, in a shoreline use analysis." This hasn't been done (and there is a link here to a lack <br />of internal consistency with the JC Comprehensive Plan). <br /> <br /> <br />5. <br />states "Cumulative impacts analysis is typically conducted while drafting SMP provisions as part of <br />the comprehensive update process. It is thus an iterative land use planning exercise, based on a <br />scientific understanding of the shoreline ecological functions, and evaluation of future development <br />and use scenarios. When applied to each shoreline planning unit, cumulative impacts analysis should <br />1 <br /> <br />