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HomeMy WebLinkAbout2961-280 G i1;\;t\- ~~ Michelle McConnell '-4lt71 From: Sent: To: Subject: Attachments: Jeff McGinley Ueff@pacificforestmanagement.com) Thursday, January 29, 2009 10:25 AM Michelle McConnell Draft SMP Comments Jeffco_draftsmp.doc Michelle, Thanks for the opportunity to comment. I would be glad to discuss it further if clarification is needed. Jeff McGinley Pacific Forest Management Inc. P.O. Box 2342 Forks, Washington 98331 (360) 374-8755 1 c9 Pacific Forest Management Inc. P,o. Box 2342, Forks, Wa. 98331 (360)374-8755 Fax (360)374-0347 Date: January 29,2009 To: Jefferson County Dept of Community Development From: Jeff McGinley Subject: Comments on Draft Shoreline Management Plan My company provides Forestry Consulting services for both small and large landowners in Jefferson County. My family also owns 260 acres of forestland in west Jefferson County. When formulating the final SMP please consider the following comments: There are 4 references in the Draft SMP to the amount of timber harvest that is allowed within Shorelines of Statewide Significance. All 4 include a reference that "30% of the timber volume in any ten year period........" There is one additional reference under the Regulation section. See below highlighted in yellow. 4. Forest Practices 33 3. Natural: Forest practices may be allowed subject to the policies and regulations of this Program. Selective commercial timber on shorelines of statewide involving more than in any ten (10) year period may be allowed with a conditional use permit. Forest practices roads on slopes that exceed thirty-five percent (35%) may be allowed with a conditional use permit when necessary to obtain access to road networks on land outside shoreline jurisdiction. 4. Conservancy: Forest practices may be allowed subject to the policies and regulations of this Program. Selective commercial timber on shorelines of statewide significance involving more than in any ten (10) year period may be allowed with a conditional use permit. Forest practices roads on slopes that exceed thirty-five percent (35%) may be allowed with a conditional use permit when necessary to obtain access to road networks on land outside shoreline jurisdiction. 5. Shoreline Residential: Forest practices may be allowed subject to the policies and regulations of this Program. Selective commercial timber shorelines of statewide significance involving more than thirty percent in any ten (10) year period may be allowed with a conditional use permit. Forest practices roads on slopes that exceed thirty-five percent (35%) may be allowed with a conditional use permit when necessary to obtain access to road networks on land outside shoreline jurisdiction. . Page 2 January 29, 2009 6. High Intensity: Forest practices may be allowed subject to the policies and regulations of this Program. Selecti~.~. commercial timber cutting on shorelines of statewide significance involving more than '1i~~t~nt(30%)ofthe.mercl1antaple..timp~ryglqtl1e in any ten (10) year period may be allowed with a conditional use permit. Forest practices roads on slopes that exceed thirty-five percent (35%) may be allowed with a conditional use permit when necessary to obtain access to road networks on land outside shoreline jurisdiction. D. Regulations 15 3. Selective commercial timber cutting on shorelines of statewide significance shall not exceed '1itty o)oftl1~rn~rchantabletimbe:t'.v~lutne in any ten (10) year period as required by R 50. The County may allow exceptions to the thirty percent (30%) limit with a conditional use permit in accordance with WAC 173-26-241 (3)( e). The problem is that the regulations as proposed are in conflict with the RCW. Specifically the RCW references 30% of the merchantable trees rather than 30% of the volume as proposed in the SMP. SeeRCW reference below. RCW 90.58.150 Selective commercial timber cutting, when. With respect to timber situated within two hundred feet abutting landward of the ordinary high water mark within shorelines of statewide significance, the department or local government shall allow only selective commercial timber cutting, so that nplTlOre th~nthirtypercentof~m!1'rch_l:il!l!t{~ may be harvested in any ten year period of time: PROVIDED, That other timber harvesting methods may be permitted in those limited instances where the topography, soil conditions or silviculture practices necessary for regeneration render selective logging ecologically detrimental: If the draft SMP remains as written, it will be in conflict with the RCW. The draft as written is much more restrictive than the State law, which leads me to believe it may have intentionally been inserted into the language. The Draft reference to "volume" would also be extremely difficult and expensive to enforce as it requires specific technical expertise to calculate volume rather than simply counting trees or stumps to determine if requirements have been met. The consequences of increasing restrictions on forest landowners will be to discourage forest land ownership. Forest landowners are already bound by the Forest and Fish Agreement and the Forest Practice Rules to make major investments in improving roads and stream crossings by 2015. This additional regulation which essentially removes land from forestry production will cause more hardship on forest land owners and that will likely lead to more fragmentation and conversion of Jefferson County forest lands. Please remove the reference to "volume" and restore the reference to "trees" as written in the RCW. Thank you for the opportunity to comment. Feel free to call me if you have any questions.