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<br />Michelle McConnell <br />From:Jim Hagen [jchagen@donobi.net] <br />Sent:Wednesday, May 05, 2010 8:02 AM <br />To:Stewart, Jeff R. (ECY) <br />Subject:Fw: DOE SMP Public Comment II <br />Categories:LASMP Public Comment <br />Public Comment on the Jefferson County Shoreline Master Program. <br /> <br /> <br /> <br />----- Original Message ----- <br />From: <br /> Jim Hagen <br />To: <br /> jkramer.consulting@gmail.com ; cmacilroy@gmail.com ; mclancy@esassoc.com <br />Sent: <br /> Sunday, March 21, 2010 2:38 PM <br />Subject: <br /> Draft SMP White Paper Comments II <br /> <br />Jim Kramer <br /> <br />Carol MaciIroy <br /> <br />Margaret Clancy <br /> <br /> <br />I would like to add on to my previous comments, which were limited to the perception that <br />the overarching objective of the white paper was to, due to funding and resource <br />challenges, lobby for increased involvement by outside agencies and non-profit organizations in the <br />implementation and administration of SMPs. There were some not-so-subtle volleys that changes in <br />state law could enable organizations like the Puget Sound Partnership to become designated as a <br />central warehouse for oversight of SMPs, diluting local control. History has shown how often today's <br />"assistance" becomes incrementally greater centralized control. <br /> <br /> <br />The following comments are meant to address some of the specific topics addressed in the white <br />paper. <br /> <br /> <br />The white paper describes "many successes where counties and cities have increased local <br />protection of the ecosystem." It further describes no net loss as " the environmental protection <br />standard for SMPs to achieve." Immediately following, however, are concessions that "even though <br />the SMP update process has been underway for several years, the path for SMPs to meet the no net <br />loss policy objective is still emerging." Later, "While these measures (protection polices) constitute <br />major improvements in shoreline protection, verifying that they achieve no net loss will be difficult <br />because there is no agreed-upon indicators of function for local governments to use and <br />consequently there is no commitment to monitor over time." This is a remarkable acknowledgement <br />by a paper authored with guidance and support from the Department of Ecology. How can there be <br />any successes when the cornerstone of SMP no net loss protection strategies is missing the core <br />building block? It is equally stunning that the DOE is halfway the post 2003 statewide update process <br />absent any fundamental understanding of how this key principle will be applied, not to mention that <br />until it is understood, monitoring is impossible. <br /> <br /> <br />Jurisdictions are being told in no uncertain terms that 150 foot shoreline buffers are based on the <br />most current scientific information and are absolutely necessary, but now this paper is stating there <br />are still no agreed-upon indicators of function. How can you establish protection measures without <br />this information? This explains why uniform 150 foot buffers are applied regardless of whether the <br />1 <br /> <br />