HomeMy WebLinkAbout27.Brotherton, T. 5-3_Comments on Jefferson County SMP
Michelle McConnell
From:Tom Brotherton [tbrot@msn.com]
Sent:Monday, May 03, 2010 9:38 PM
To:Stewart, Jeff R. (ECY)
Subject:Comments on Jefferson County SMP
Categories:LASMP Public Comment
In most areas a well researched document. Several comments:
1. It is too verbose and needs to have a lot of redundancy removed.
2. The goals, policies, and regulations are disjoint, I.e., there are policies that do not support any goals and
regulations independent of all policies.
3. The science supporting 150 foot marine buffers is too thin to be usable. I found only 4 cited research
papers addressing effects of marine buffers, and their recommendations differed widely.
4. The science supporting lake, stream, and river buffers was well supported, with over 200 cited papers in
general agreement.
5. The vast expansion in natural areas broadly conflicts with the current general zoning of coastal regions as
RR 1-5, which, presumably, reflects the will of the community.
6. The Administrative Procedures Act requires a cost/Benefit study for each substantive rule. Since each
county's SMP is different and it is a joint state/local rule, it appears a unique study will be required.
7. It differs in several areas from the Port Townsend SMP. While consistency is not required, the differences
should be reconciled so that the two SMPs are as compatible as reasonably possible in order to avoid
differential treatment of neighbors.
Thank you for your time.
Tom Brotherton
255 Cascara Dr.
Quilcene, WA 98376
360-765-0901
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