HomeMy WebLinkAbout48 2017-12-191
Nicole Allen
From:David Greetham
Sent:Tuesday, December 19, 2017 2:23 PM
To:Nicole Allen
Subject:FW: In Re: Appeal of BDN Shine Road Geoduck Aquaculture Farm Code Interpretation
Attachments:2017 12 15 Appellant Supplemental Brief.pdf
FYI
From: Philip Hunsucker
Sent: Tuesday, December 19, 2017 2:18 PM
To: Jenny Pelesky (j.pelesky@mchlawoffices.com) <j.pelesky@mchlawoffices.com>
Cc: Terri Tyni <terri@plauchecarr.com>; Robert Smith <robert@plauchecarr.com>; Ken Sheppard
<KSheppard@sksp.com>; David Greetham <DGreetham@co.jefferson.wa.us>
Subject: RE: In Re: Appeal of BDN Shine Road Geoduck Aquaculture Farm Code Interpretation
Dear Hearing Examiner Causseaux:
Jefferson County (“County”) has received the Appellant’s Supplemental Brief (attached for
convenience). Appellant’s Supplemental Brief does not and cannot dispute that the 2016 JARPA was the operative
application on which the Army Corps issued its approval under the Nationwide Shellfish Permit or that the 2016
JARPA was never submitted to the County. Nor does it address the County’s argument that an SMP permit required
by the state is not the type of permit the common law vested rights doctrine was designed to address. Accordingly,
the County will not be submitting a responsive brief.
Thank you for your attention to this matter. The County will await your final decision.
Philip
Philip C. Hunsucker
Chief Civil Deputy Prosecuting Attorney
Jefferson County Prosecuting Attorney’s Office
P.O. Box 1220, Port Townsend, WA 98368
Ph: 360‐385‐9180 Fax: 360‐385‐0073
All e-mail sent to this address has been received by the Jefferson County e-mail system and is therefore subject to the Public Records Act, a state law found at RCW 42.56. Under the Public Records law the County must release this e-mail and its contents to any person who asks to obtain a copy (or for
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