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HomeMy WebLinkAbout010ocT-18-2001 THU t0:50 All DNR FI SHER I ES FAX N0, 3608775148 P, 01 t Skokomish Natural Resources 2o4b e Telephone: (360) 977-5213 Fax: (360) tr/7-sfd$ .541 Tribal Center Road Shelton, WA 98584 6? FA)( TRA}ISMITTAL SHEET TO: 5O 5 ftH FROM: DATE:to Itu /or Z^"\u \Lo tLo r\^ t-.t-O& O<-rc- Co^^r" r^\S Ow \-{. # OF PAGES INCLUDING CO\IER SHEET: -1 NOTES \\u"- b q.wo{:t^br coo -t"$*e ["frr'f,.r^[. 1 \N-q EG E OVE TTERSO t,tc0uN ryDEPI. OF con,luull rry orve[opn,tErur ocT ts mtm OCT-18-2001 THU 1O:50 ATI DNR FISHERIES FAX NO, 3608775148 P, A2 tw as on O*,lt ?e IG, Skokomish Natural Resources Telephone: (360) 877-5213 Fax: (360) 977-s148 N.54f Tribal Center Road Shelton, WA 98584 October 15,2001 EGEIVE Josh Peters, Associate Planner Jefferson County Department of Community Development 621 Sheridan St. Port Townsend. WA 98368 ocT 1 I 2001 Brinnon Sub-area Planning Group JEFFERSON COUNW DEPT. OI. COMMUN Y DIVELOPMENT A Jefferson County Planning Commission unail a+k REr Commerrts on August 28r200L DRAFT Brinnon Sub-area Plan To: Iosh Petgrs, Brinnon Subrarea Planning Group and the Jefferson County Planning Commission The Skokomish Department of Natural Resources would like the following comments submitted into the record. The tribe belieryes that the Brinnon Planning Group should have made sn etternpt to include the Port Gamble S'Klallam and Skokomish Tribes in the early planning stages of the proposed sub-area plan because of the tribe's authority to co- manage salmon and shellfuh. In addition, land-use actions that affect the local fish, shellfish and wildlife resources are of a grert concern to the Skokomish Tribe. Furthermore, early consultation with affected tribes would have added greatly to the attempt in the plan to describe the local nafive history of Hood Canal and the Brinnon area. Cultural resources staffwith the Skokomislr Tribe would like to have an opporhrnity to review and comment on the contents ofthis plan as well. The Jefferson County Department of Community Developrnont and/or the Jefferson Coupty Planning Cornmission should have made a genuine attempt to inform the affected hibes of the Brinnon -Sub-area Plan and the ability to provide oornments. It was only through other interested parties that the Skokomish Tribe was informed of a planning process undenvay in Brinnon that may impact treaty-reserved resowces. Past development in the floodplains of the Duckabush and Dpsewallips Rivers as well as inappropriate shoreline development have already impacted salnron runs arrd shellfish resources that the tribes rely on- The majority of our comments will focus on environmental attributes of the Brinnon arga and eco-systems that may be threstened by items proposed in the plan rather than the economic conditions, growth and job opportunities available. 1 OCT-18-2001 THU 10I51 AIl DNR FISHERIES FAX N0, 3608775148 Pg. 6 Flooding Annual flood events that occur in the Dosewallips and Duckabush Nvers shoutd not be termed as "flash flooding". Flash floods tend to occur quickly over several hours and are generally unanticipated- The normal hydrological regime of these two rivers is such that when flooding does it occur, it occurs over the course of a few days. It is true that rain on snow eve,rfis compounded by high tides often results in local flooding. The plan states that FEMA: Washington State and Jefferson County have taken measures to "contain possible flooding of the Dosewallips River by riprapping approxirnately one- quarter nrile up from the Dosewallips Bridge over Highway 101". Amroring techniques of shorelines do not contain floodwaters but instead are used to reduoe localized bank erosion, It would be inappropriate to change the EENIA maps and floodplain boundaries besause of these types of activities. Changes should only occur afier careful review of the hydrologio regime and physical attributes of the entire floodplain. Furthermore, installation of riprap banks in floodplains that possess a channel migration zone restricts the ability of the channel to respond to inoreases in water, wood and sediment thereby impacting fish habitat and fish produotivity. Pg. 16 GOALS The goal stated to "protect and enhance the natural environment" is a laudable goal and is included in most plans, However similar goals are often just lip service and never the top priority whem development and economic concsrns conflict with the goal, Sensitive oitical areas such as floodplains, shorelines and riparian habitats should be set aside when planning for development and not be assumed to be potentially developed. POLICIES Policy Pl.0 promotes agrioulhrre and residential dwelopment as primary uses of land adjoining shorelines. These larrd uses have historically been one of the primary detriments to fish habitat and shoreline health throughout the west, These activities should only be allowed after adequate and science-based buffers and setbacks are established between the shoreline and the proposed use. Summer chum salmon Iisted as"threalened'under the Endangered Species Act (ESA) utilize the mainstem Duckabush and Dosewallips Nvets, Activities that harm their habitat are considered a'take" of that speoies. Jefferson County €,ventually will have to amend its Shordine Master PIan (SlvIA) as their Uniform Developmart Code (UDC) to make them ESA compliant. The SMA should be a powerful force in salmon recovery in Hood Canal if used effectively. In addition, the Shoreline lvlanagement Act (SIvIA) was created to protect valuable shoreline habitats and eco-systems and that "the interest of all people shallbe paramount". Ultimately, the SMA has not lived up to it purpose and shorelines and floodplains have continued to be impacted since the establishment ofthe SN4A. Promoting funher dwelopment that may impaot the local shorelines is not only unwise but shows poor land stewardship Policy P3.0 promotes the continued development within the Brinnon Flats area even though the majority of the flats are within the 100-year floodplain. Future growth, P, 03 ,| OCT-18-2001 THU 1O:51 AI1 DNR FISHERIES FAX N0, 3608775148 whether it is commercial or residential should not occur in floodplains because of their unpredictable nature and the resulting impacts on the natural envirotrmelfi from such development. Furthermore it is poor stewardship and does not live up to the goal of protecting and enhancing the natural environmenl. Pg. f8 Rural Character Definitions in the Growth Managernent Act (GIvIA) [at RCW 36,704,030] that refer to rural areas are stated on page 18. Future dwelopment of the Brinnon Flats as well as a proposed MPR for Black Point refemed to later in this plan are not consistent with these definitions, Pg. 25 Rural Residential Land Uce GOALS, POLICTES, AND STATEGIES The first four of the eight policiee stated in this chapter focus on environmental protection and maintaining habitat in the face of development, However the same policies also promote the oontinued development within these areas as long as they don't impact them. As stated previously in these comments, development should be focused outside of the critical areas and not attempt to be cited within thgm. History of past laud uses statewide have shown that it you cflmot have it both ways. Pg.32 Rural Commercinl-Brinnon Rural Village Center (RVC) GOALS, POLICIES AND STATEGIES We agree with Goal 2.0 thilt an update of FEMA's FIRM maps for the Dosewallips should occur. However, if the rationale is to make the floodplain smaller and to remove the Brinnon Flats ftom the map because of the shoreline armoring and bridge work done then we think that is very shortsighted and narve. The update should be based on solid hydrological data and landsoape attributes zuch as mioro-topography. In fact, some work to document local micro-topography for the Dosewallips has already been initiated by the Port Gamble S'Klallam Tribe who is pursing LIDAR mapping technology that will assist in defiuing the Dosewallips Nver floodplain, The Port Gamble S'Klallam and Skokomish Tribes request to be involved in any negotiations with FEMA to update their maps and floodplain boundaries. It appears that the authors have a pre'conceived idea ofthe boundaries ofthe Doscwallips. If a request is made to redesignate the floodplain then better rationale than bank armoring and bridge repairs need to be formulated. Pg. 43 Rural Commercinl-Black Point It is inappropriate to blame mill closures in the early 1980's entirely on environmental regulations and spotted owls restristions. In fact, mill closure as well as job losses irr the woods were occurring long before spotted owls were on most people radar screens. New technologies for harvesting timber and getting the wood to the market, along with unsustainable harvest levels, were primarily to blame for the job losses, Using the peak of timber harvesting in the 1970's as if this was a benchmark to place future hawesting levels at is urrrealistic. It is widely known that harvest levels on National Forest lands wore exceeding high during that time and could not be sustained over the long run. P, 04 OCT_18-2001 THU 10I51 AH DNR FISHERIES N'ew forest practice rules due to ESA listings (Forest and Fish Agreement) will not adversely impact forest land owners to a significart degree beoause new riparian buffers are not significantly larger than previous buffer standards and non fish streams are still left un-protected to I great degree. While it is true that a Itdaster Planned Resort (IvPR) at Blaok Point may help boost the local economy. but at what costs? It may provide jobs for local wage earners but primarily the MPR is designed to take advantage of the growth in tourism and recreatiorr, It will do nothing to make housing availability and oosts low to the average first time home buyer. It does show promise though to make money for the few proponents and benefa,ctors of the MPR which appears to be the primary goal. Pg 57 Shellfrsh Earuesting Rights Future Objectives Objective number 3 tries to advance the dweloprnent of a "put and take" approach for supplementation of natural shellfish production on public tidelands by using the WDFW models oftheir "put and take" trout urd steelhead programs. These prograrns have been to a large extent detrimental to native trout, steelhead and salmon populations and have failed to enhance the overall production of trout and salmon over the long term. Pg.59 Goal G4.0 The tribe would endorse a oountyride Salmon Recovery Program that uses the "best available science" and that protects and attempts to recover critical fish habitat. However, this being said, the politicians and landowners need to accept what the established habitat needs are and be willing to work towards I oornmon goal for the needs of the salmon. A viable and effeotive plan would preclude most development within the floodplain and along marine and freshwater shorelines and would impose ecologically based buffers that would protect and restore river, riparian, floodplain and shoreline habitat. P9.67 Vision Semi-Active Recreation Elements For the plan to proposed construction of a golf course, swimming pool and roller rink potentially in the floodplain shows that the goal orr page 16 of protec'ting and enhancing the natural environment is not ofprime importance to the authors ofthis plan. Water table depths are only one of many attributes that should preclude the development of these elements within the floodplain. Pg. 7f Economic Dcvelopment Element The statement made that "traditional and hisioric roots oflogging, fishing and rcsourced based support activrties haven been grudgingly reduoed largpltr to increased environmental restrictions" is incorrect. The loss of fish, wildlife ad habitat from inappropriate development, harmful forest practices, over exploitation and non- sustainable haruest of fish and forests have resultod in the loss of these resouroes forcing tighter environmental restrictions. FAX N0, 3608775148 P, 05 A OCT-I8-2001 THU 1O:52 AIl DNR FISHERiES FAX N0, 36087i5148 Pg. E0 Natural Environmental Element This chapter should set the stage for the rest of the plan and should have been included closer to the front to portray what the geologic and geographic characteristios are and how to plan around them. Pg. 8I As stated earlier, irrstallation of rip-rap to "contain any possible flooding" is often oounter productive and does not change the bourrdaries of a floodplain. Most times, rip-rap banks are installed to control localized erosion and only contain small floods. In rivers the size of the Dosewallips and the Duckabush IOO-year flood wents generally cannot be oontained within a channel bounded by rip-rap unless major dredging and or dikes are constructed, Hardening banks may satisE/ short*term goals (bank protection at site) but oftem fail to achieve loug-term goals (maintaining ecosystem funotion and quality fish habitat and flood reduction). Pg 82 P1.1 Utilizing land a^od resources for their "highest and best use" has different connotatioru for differemt people depending on their philosophy. Obviously a landowner or real estate developer may view this phrase differently than a photographer or biologist. Pg.82 Shorelines The Shorelines of Hood Canal and the Duckabush and Dosewallips are not only importarrt to the Hood Canal tribes but also the people of the entire state of Washingldn. Shoreline developmerrt and degradation had gone on for a long time which is why the legislature passed the Shoreline Management Act in 1971, The purpose of the act was to preserve and protect these sensitive shorelines and to maintain their ecological integrity for all the citize,ns of Washingon. However even with these adnrirable goals and subsequent policies, the SMA has failed to accomplish its mission. Much of the inappropriate Iand use in the lower Duckabush and Dosewallips Rivers has occurred in the last 3 decades since the inception of the SMA. The SMA and the Jefferson County Shoreline Master Program are in need of major revisions so that they can attempt to achieve the intended goals and vision ofthe SMA. Pg. 8,{ Naturrl Eeritage Vegetation, Wildlife and Landforms The marine habitats mentioned are utilized by 3!! species of sahnon and trout. Chum salmon may tend to use them to a greater eldent as far as juvenile residency times, but the importanoe of these habitats to other salmonids is no less significant. In addition, beach habitat is also important for other species ofbait and forage fish other than hetring, including surf smelt, shiner perch and many others . Not mentioned are the numerous invertebrates which currently have no cornmercial or sport value but are nevertheless important components of the marine eoosystem. P, 06 ( OCT-IB-2001 THU 1O:52 AI{ DNR FISHERIES FA}( N0, 3608775148 Pg. t5Invertebrate and Fish-Marine, Water and Terrestrial It is interesting to note that the only salmonid mentioned in this list is the clrtthroat trout. The authors need to include the other species of salmon and trout that are found in the Brinnon area including chinook, chum, pink and coho salmon as well as steclhead. In closing, there is a lot of good information in this sub-area plan that should be retained and utilized towards a final Brinnon Sub-area plan, however the way the plan deals with the environmental elements and proposed land uses can not be endorsed by the Skokomish Tribe. If you have any questions regarding these comrnents, please feel free to call me at (360) 877-5213, ext 504 or email me at marty@.skokoryiqb.org. Thank you for the opportunity to provide oomments, Sincerely P, 07 $N"\€s\ l"Iarty Ereth Fish Habitat Biologist Co: Ted Labbe, Port Gamble S'Klallam Tribe Celeste Vigi[ Skokomish Cultural Resouroes Better Brinnon Coalition R