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Jeanie Orr
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From: Ryan Hunter [rhunter@ecoisp.com]
Sent: Friday, January 30, 2009 1 :35 PM
To: Jeanie Orr; #Long-Range Planning
Subject: SMP Update Comment
Dear Commissioners:
I am writing to urge you to support the County staffs December 3rd draft of the Shoreline
Master Program (SMP) update. This draft was produced following an extensive public participation
process, including over 44 opportunities for public involvement through open public meetings of two
advisory committees - one technical and one policy - and numerous public events in locations across the
County. The result is a draft SMP that is based on sound science and state law, with the flexibility
necessary to adjust to specific circumstances.
I do, however, have two minor recommendations for strengthening what is an excellent draft SMP. First,
the draft allows for large hydroelectric dam projects so long as the projects' benefits to county residents
outweigh any adverse ecological impacts and the projects comply with certain environmental
regulations. I believe that it is impossible for the benefits of large hydroelectric dam projects to
outweigh adverse ecological impacts and for such projects to comply with the environmental regulations
set out in the draft SMP. It would be simpler to prohibit outright large hydroelectric dam projects, as
such projects would not be appropriate for any of the county's rivers.
I therefore recommend that reference to large hydroelectric dams be deleted from line 37 on page 7-25.
Moreover, I recommend that a period be placed after the word "permitted" in line 33 on page 7-26, and
that the remainder of regulation number "I" (lines 34 through 3 on pages 7-26 and 7-27) be deleted.
Second, the draft SMP allows mining in active water channels so long as the mining meets certain
conditions. I believe it is impossible for mining that uses motorized devises (usually done in a technique
that is called "suction dredge mining") to meet condition "i" (lines 18-20 on page 8-21). The
environmental impacts of suction dredge mining have been documented by non-profit organizations in
southern Oregon and the Washington Department of Fish and Wildlife recently revised their regulations
of such mining in recognition of the adverse environmental impacts of such activity. Since this type of
mining is a recreational rather than commercial activity, there is no economic benefit to the county in
allowing it to occur. I therefore recommend that in-stream mining using motorized equipment be
prohibited outright.
In this regard, I recommend that item "iv" be added to regulation number "5" on page 8-21 which would
read "No motorized equipment shall be used in the extraction of mineral resources, including but not
limited to suction dredging equipment."
The December 3rd draft of the SMP is an excellent document that could prove to be among the best
SMP's in the state of Washington. I urge you to approve the draft SMP largely as it is written. If any
changes are made to the document, I request that the changes strengthen rather than weaken the
regulatory protections provided our shorelines.
Regards,
Ryan Hunter
1423 Grant 81.
Port Townsend, WA 98368