HomeMy WebLinkAbout2961-391
co fn 11
~b
lO~~l'
Page 10f3
From: Jerry Gorsline Ugors@q.com]
Sent: Friday, January 30, 2009 2:16 PM
To: #Long-Range Planning
Cc: Michelle McConnell
Subject: RE: Preliminary Draft Shoreline Master Program
?Ale I
cg-
Jeanie Orr
Memorandum
Date: 01/30/09
To: Jefferson County Planning Commission
From: Jerry Gorsline
Subject: Preliminary Draft Shoreline Master Program (pDSMP)
I am writing to express my support for the proposed Shoreline Master Program (SMP) update.
Recognizing how fInite and vulnerable our shoreline and nearshore habitats are, I have long advocated
for an update to Jefferson County's 1980s vintage SMP in order to align it more with contemporary
science. In support of this cause, I nave served on county policy advisory committees that helped shape
both the 2000 draft SMP and this 2009 preliminary draft SMP (PDSMP).
I believe the goals, policies and regulations embodied in the PDSMP are consistent with both the
Shoreline Management Act (Chapter 90.58 RCW) and the Shoreline Master Program Guidelines
(Chapter 173-26 WAC), and that, with proper implementation, the SMP update could accomplish two
important objectives: maintain our current baseline of shoreline ecological functions through regulations
that require avoidance and mitigation of impacts and restore shoreline ecological functions over time.
The PDSMP will accomplish this at both the planning and project levels: employing environment
designations with appropriate use and development standards; regulations that protect critical areas
within the shoreline; and mitigation for impacts associated with uses and development. Restoration will
be used both to mitigate development impacts (while adhering to strict "nexus and proportionality"
standards) and achieve net gain in ecological functions over time through non-regulatory means. In
addition, the PDSMP will help implement the following environmental goals and policies in the
Jefferson County Comprehensive Plan:
GOALS:
ENG 5.0 Allow development along shorelines which is compatible with the protection of natural
processes, natural conditions, and natural functions of the shoreline environment.
ENG 11.0 Protect flood hazard areas from development and uses that compromise the flow storage and
buffiring of flood waters, normal channel functions, and fish and wildlife habitat and to minimize flood
and river processes risk to life and property.
ENG 12.0 Protect and enhance fish and wildlife habitat throughout Jefferson County.
2/2/2009
Page 2 of3
ENG 14.0 Protect and enhance wetlands in all their junctions.
POLICIES:
ENP 12.2 Land use decisions should recognize the priority of the protection and enhancement offish and
wildlife habitat in accordance with proposed listings of threatened and endangered species under the
Federal Endangered Species Act.
ENP 12.3 Buffersfor fish and wildlife habitat areas should be consistent with the best available science
for habitat protection.
ENP 12.6 Cooperate and coordinate with appropriate agencies to avoid adverse impacts to fish and
wildlife habitat in the review and approval of development proposals.
ENP 14.1 Designate and manage wetlands based on the best available science.
I fully support the proposed 150 feet buffers for marine shorelines: Jefferson County's more than 200
miles of marine shoreline riparian zones perform functions similar to freshwater riparian zones that will
protect nearshore habitat. Marine riparian vegetation will filter pollutants to protect water quality;
contributes large and small organic matter important for habitat structure and marine food chains
(including terrestrial insects important to juvenile salmon) and provides shade to intertidal beaches
important for forage fish spawning. In addition, terrestrial insects delivered from riparian areas provide a
significant part of juvenile chinook diets in the nearshore and marine riparian trees provide habitat for
numerous terrestrial species of wildlife (see Brennan, et al, 2004 & 2005).
I recommend the PDSMP be strengthened with regard to legally non-conforming development within
the more than 3,000 undersized shoreline lots extent within Jefferson County shorelines. The PDSMP
exempts legally non-conforming development in these lots from meeting the standard buffer and
setback rules with only minimal review by county staff. Adequate review must be provided to ensure
impacts are avoided or mitigated to the greatest extent possible, and I therefore recommend an
administrative conditional use permit be required for development of these undersized lots order in order
to thoroughly address environmental impacts.
In conclusion, I urge your support for the PDSMP draft. Please keep this SMP update process moving
forward. I believe the PDSMP, as proposed, will help protect the health, safety, and welfare of our
citizens; help sustain our "natural capital" (with its associated "goods and services") that we should
faithfully steward and pass on to future residents of this county, and place Jefferson County in the front
ranks in our state's great efforts to protect and restore Puget Sound.
Jerry Gorsline
5282 Cape George Road
Port Townsend
W A 98368
Email: jgors@q.com
Ph 360.385.6132
Bibliography:
Brennan, J.S., et al. 2004. Juvenile Salmon Composition, Timing, Distribution and Diet in Marine
2/2/2009
Page 3 of3
Nearshore Waters of Central Puget Sound in 2001 and 2002. King County Department of Natural
Resources and Parks.
Brennan, J.S., and H. Culverwell. 2005. 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.
2/2/2009