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Home My WebLink About2961-332 ~~~ CUM~~ Michelle McConnell 2flle I Importance: Pat Pearson [pearsonp@jefferson.wsu.edu] Friday, January 30, 2009 4:01 PM Michelle McConnell SMP comments SMPCommentPat09.doc; A TT101560.htm High @ From: Sent: To: Subject: Attachments: Attached are my comments on the draft SMP. 1 January 30, 2009 Department of Community Development 621 Sheridan Street Port Townsend W A 98368 Attn: Michelle McConnell, Associate Planner Dear Ms. McConnell: via email: planning@co.iefferson.wa.us mmcconnell@co.iefferson.wa.us Re: Preliminary Draft Shoreline Master Program (pDSMP) Comments I am writing to comment and express my support for the draft PDSMP. As WSU Jefferson County Extension Water Quality/Natural Resources faculty, and a staff member of the Jefferson County Marine Resources Committee (MRC), my primary focus is on protecting the health of our natural ecosystem, natural processes, and resources. My work includes providing outreach and science based education to the public to increase their awareness about the value of healthy, functioning natural systems, and address many of the human activities that impact water and land resources. The policy goals of the Shoreline Management Act (SMA) are to encourage water-dependent uses, protect shoreline resources, and promote public access. I believe that a regulatory land use program such as the PDSMP can be one of many valuable tools to protect shorelines, nearshore areas, and marine resources. Public Outreach and Plan Development Process · I hope the Planning Commission will appreciate the extensive public process that has gone into preparing this draft and act on it in a timely manner. The public outreach for the PDSMP has been extensive and has included open houses, neighborhood information booths, mailings, fliers, and a project webpage. There were also two advisory committees with broad representation. The PDSMP represents a compromise document that balances the broad interests of Jefferson County while meeting the goals of the SMA. Designations and Classifications · I support the changes to the SEDs. This includes that the "Natural" designation is applied more widely; development restrictions are applied to higher percentage of the County shorelines, the "Priority Aquatic" designation is applied to important salmon and shellfish habitats, and more uses require a Conditional Use Permit allowing for site specific conditions to be taken into account. Aquaculture · I support local control and involvement through permitting of aquaculture activities such as geoduck and floating/hanging operations. Certain types of aquaculture may have impacts and involve land use contlics that are best handled at a local level. I support the use of either a Substantial Development Permit or a Conditional Use Permit to regulate NEW geoduck and floating/hanging operations in some areas, and that all aquaculture must be sited to prevent damage to eelgrass beds, kelps, etc., and sturctures tied to bottom must use anchors that minimize impacts. Boating Facilities, Bulkheads and Access Structures . I support the provisions of the proposed SMP with respect to boating facilities, bulkheads and access structures. The construction of docks and bulkheads are alterations of nearshore habitat that can threaten parts of the ecosystem. The value of the our shorelines for salmon production, aquaculture and recreation are immense. I support limiting shoreline structures of any kind and halting armoring in locations in front of and adjacent to feeder bluffs. I support the proposed limitations to armoring. The PDSMP allows new structural armoring for residences only when existing primary structures are in imminent danger caused by winds. currents. or waves. The proposed SMP requires geotechnical study and mitigation for impacts. A permit applicant must also demonstrate that bio-stabilization is infeasible or inadequate to protect the existing structure. The science and on-the-ground experience with natural soft shore armoring techniques for shoreline home protection are now in place. I support the proposed limitations to private beach access structures. The PDSMP allows private beach access structures with a Conditional Use Permit and will usually require geotechnical study prior to approval, dimensions are limited to prevent adverse impacts and are only allowed if there is no other available access within 300 feet. These structures are not allowed where impacts to feeder bluffs, critical areas, landslides or erosion hazards would occur. I support the proposed requirements for docks, piers and lifts as follows: grating/light penetrating materials are required on walkways in nearshore areas, cumulative effects of dock proliferation must be considered, the maximum allowance per residence is one of each: lift, dock., and float, residential docks are prohibited in Priority Aquatic designation and no moored vessel can be used as a residence. I support the proposed requirements for Marinas as follows: marinas must restore part of the shoreline to improve ecological conditions as a condition of approval and must be located to avoid need for dredging, excavating or filling wetlands. Open pile and floating breakwaters are preferred. Armoring must be limited to minimum necessary and bio-stabilization is preferred. Breach nourishment of down-drift areas may be required if adverse effects on sediment transport are likely. I support the proposed requirements for mooring buoys. The PDSMP requires County to coordinate with other agencies regarding placement of buoys, limits the number to 4 buoys/acre in enclosed bays and requires helical or other low impact anchor systems. Marine Shoreline Buffers and Vegetation Management . I support the proposed marine shoreline buffer of 150'. . I support the vegetation conservation provisions which include: maintenance of existing native vegetation (80% of buffer must be 'predominantly natural'; 20% of buffer can be 'active use'), and limited clearing for views and lawns (pruning, limbing is allowed up to 25% per tree/canopy). One hundred and fifty feet is consistent with the buffer width being proposed and/or adopted in many jurisdictions. The City of Port Townsend's recently adopted SMP has 200' buffers along some of its shorelines, while Whatcom County's new SMP has 150' as the standard buffer for marine shorelines. King County currently applies a 165-foot buffer to Type S shorelines outside of urban growth areas via the King County critical areas ordinance. Kitsap County is proposing to adopt a 150 foot marine shore buffer in certain shoreline environment designations. Buffers are necessary to protect water quality and wildlife by providing habitat and travel corridors, microclimate regulation, organic input, and to counter the impacts of human activities. Birds use logs on beaches, tideflats, and estuarine channels as perches for hunting and resting. Gulls use log beaches and estuarine meadows for breeding. Logs function to visually isolate adjacent nests, provide temperature regulation benefits for egg development, and cover for newly hatched chicks. Recent studies have shown that riparian vegetation on open marine shorelines may play an important role in producing terrestrial insect prey for juvenile salmon. Eelgrass beds provide habitat for fish and invertebrates and spawning habitat for herring. Solar radiation is also an important factor determining distribution, abundance, and species composition of upper intertidal organisms (Brennan and Culverwell, 2004). Moisture and direct solar radiation also influence egg viability of intertidal-spawning forage fish such as surf smelt and sand lance (penttila, 2001). Buffer recommendations range from 98 to 262 feet for natural temperature regulation and shading, or providing equivalent shading as a mature forest (May, 2003). References Cited . Brennan, J.S., and H. Culverwell. 2004. Marine Riparian: An Assessment of Riparian Functions in Marine Ecosystems. Published by Washington Sea Grant Program Copyright 2005, UW Board of Regents, Seattle, W A. 27p. . Levings, C. and G. Jamieson. 2001. Marine and estuarine riparian habitats and their role in coastal ecosystems, Pacific region. Canadian Science Advisory Secretariat, Research Document 2001/109.41 p. www.dfo- mpo.gc.ca/csas/. . May, C. andG. Peterson. 2003. East Jefferson County Salmonid Refugia Report. . Penttila, D. 2000. Documented spawning areas of the pacific herring (Clupea), surf smelt (Hypomesus) and Pacific Sand Lance (Ammodytes) in East Jefferson County. Washington State Department ofFish and Wildlife, Marine Resources Division Manuscript Report. Restoration Plan I appreciate the Department's work in preparing the Draft SMP. I look forward to working with DCD and other entities/organizations to promote marine resource protection and restoration through education and outreach. Sincerely, Pat Pearson, WSU Jefferson County Extension