HomeMy WebLinkAbout91.Hagen, J. 5-6_Fw DOE SMP Public Comment XI
Michelle McConnell
From:Jim Hagen [jchagen@donobi.net]
Sent:Thursday, May 06, 2010 9:35 PM
To:Stewart, Jeff R. (ECY)
Subject:Fw: DOE SMP Public Comment XI
Categories:LASMP Public Comment
Public Comment on the Jefferson County Shoreline Master Program.
ARTICLE 7.8, cont.,
7.8.C Regulations - Existing Structural Shoreline Armoring.
7.8.C.1.ii.
Restrictions on increase in size fails to meet requirements in RCW 90.58.100(6) and in
essence establish bulkheads and armoring as a nonconforming use. Erosion by its very nature will
increase in size, requiring additional protection.
7.8.E.1.
Contains the language "strongly encouraged to remove it." This is a regulation, not a
philosophical treatise. It should be exact in its meaning. My past experience with the term "strongly
encourage" is that the alterantive is rarely pleasant.
7.8.E.2.i.
New structural armoring is allowed for ecological restoration but is heavily conditioned on
undeveloped lots.
7.8.E.4.
This evaluation of the need for new or expanded structural armoring includes "No action
(allow the shoreline to retreat naturally). Huh? Second is increased building setbacks and/or
relocated structures. Lastly, it appears proponents are restricted in what materials they can use for
new or expanded armoring.
7.8.E.5.
Again, the County is demanding "credible" proof armoring is necessary, as if homeowners
have nothing better to do than needlessly spend tens of thousands of dollars when they would rather
be fishing. And what if the "evidence" is insufficient? Is the permit denied? What about RCW
90.58.100(6)? Is this DCD or CSI?
The qualifier significant is again absent throughout this section when addressing adverse impacts.
ARTICLE 8 - USE-SPECIFIC POLICES AND REGULATIONS.
8.8. Residential.
WAC 173-26-241(2)(j) mandates polices and regulations that assure no net loss of
ecological functions will result from residential development. Provisions including setbacks and buffer
areas...and should be sufficiently set back from steep slopes...including bluff walls." WAC 173-26-
Critical Saltwater Habitats,
221(2)(c)(iii) lists management planning including "Establishing
adequate buffer zones around these areas to separate incompatible uses from the habitat areas."
Nowhere does it remotely reference the need for buffers the width of which consume nearly 3/4 of the
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shoreline jurisdiction. Our previous SMP included provisions that increased buffers one foot for every
vertical foot of bluff.
Jim Hagen
Director, Citizen's Alliance for Property Rights
Director, Olympic Stewardship Foundation
Jefferson County
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