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<br />Michelle McConnell <br />From:Jim Hagen [jchagen@donobi.net] <br />Sent:Thursday, May 06, 2010 9:35 PM <br />To:Stewart, Jeff R. (ECY) <br />Subject:Fw: DOE SMP Public Comment XI <br />Categories:LASMP Public Comment <br />Public Comment on the Jefferson County Shoreline Master Program. <br /> <br /> <br /> <br />ARTICLE 7.8, cont., <br /> <br /> <br />7.8.C Regulations - Existing Structural Shoreline Armoring. <br /> <br /> <br />7.8.C.1.ii. <br />Restrictions on increase in size fails to meet requirements in RCW 90.58.100(6) and in <br />essence establish bulkheads and armoring as a nonconforming use. Erosion by its very nature will <br />increase in size, requiring additional protection. <br /> <br /> <br />7.8.E.1. <br />Contains the language "strongly encouraged to remove it." This is a regulation, not a <br />philosophical treatise. It should be exact in its meaning. My past experience with the term "strongly <br />encourage" is that the alterantive is rarely pleasant. <br /> <br /> <br />7.8.E.2.i. <br />New structural armoring is allowed for ecological restoration but is heavily conditioned on <br />undeveloped lots. <br /> <br /> <br />7.8.E.4. <br />This evaluation of the need for new or expanded structural armoring includes "No action <br />(allow the shoreline to retreat naturally). Huh? Second is increased building setbacks and/or <br />relocated structures. Lastly, it appears proponents are restricted in what materials they can use for <br />new or expanded armoring. <br /> <br /> <br />7.8.E.5. <br />Again, the County is demanding "credible" proof armoring is necessary, as if homeowners <br />have nothing better to do than needlessly spend tens of thousands of dollars when they would rather <br />be fishing. And what if the "evidence" is insufficient? Is the permit denied? What about RCW <br />90.58.100(6)? Is this DCD or CSI? <br /> <br /> <br />The qualifier significant is again absent throughout this section when addressing adverse impacts. <br /> <br /> <br /> <br /> <br /> <br />ARTICLE 8 - USE-SPECIFIC POLICES AND REGULATIONS. <br /> <br /> <br /> <br /> <br />8.8. Residential. <br />WAC 173-26-241(2)(j) mandates polices and regulations that assure no net loss of <br />ecological functions will result from residential development. Provisions including setbacks and buffer <br />areas...and should be sufficiently set back from steep slopes...including bluff walls." WAC 173-26- <br />Critical Saltwater Habitats, <br />221(2)(c)(iii) lists management planning including "Establishing <br />adequate buffer zones around these areas to separate incompatible uses from the habitat areas." <br />Nowhere does it remotely reference the need for buffers the width of which consume nearly 3/4 of the <br />1 <br /> <br />