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Home My WebLink About2961-458 .GmA- -ILl /'.L 1',' ~ ....",~ \11 v,,~...., '?J IQ\.V~I . VVeM ~C::___o0 A~ l{- ("") <;,"TD ~. ~ tV r?c "'~ L'1 ~II @ April 2, 2009 P~erDowney,Chamnan Jefferson County Planning Commission 621 Sheridan St. Port Townsend, W A 98368 Re: PDSMP comments, Shoreline buffers and Climate change Dear Mr. Downey. I was unable to attend the April 1 planning commission meeting. Please accept this letter as Jamestown S'KIallam Tribe's continuing input into this process. These comments add to and clarity Jamestown S'KIallam Tribe's comments in a joint tribal letter dated January 30, 2009. What I'm going to discuss below are two items. First is to recommend an expansion for the CASP (Critical Area Stewardship Plan, or alternatively a Shoreline Stewardship Plan), where the landowner has the option to go through a very rigorous process to prove that the natural shoreline width on their property is less than 150 ft. Second item are recommendations to incorporate into the Shoreline Management Plan a 3 ft sea-level rise marine planning target and a 500-year floodplain planning target on freshwater shorelines. Critical Area Stewardship Plan or Shoreline Stewardship Plan The marine and freshwater shorelines are where fish habitat meets wildlife habitat. They can be very sensitive to disturbances, particularly development. Development is a permanent change; any development within the natural shoreline will impact fish and wildlife habitat. Shorelines. as with any ecological feature, vary in width. We often underestimate their width. For example, a steep eroding marine bluff dropping directly onto a beach (at or below Ordinary High Water) may contain an ecological shoreline in width more or less than 150 ft from the Ordinary High Water Mark. These are often called "Feeder bluffs" and are critical to maintaining beaches within that drift cell. The Shoreline in this case would be the expected bluff erosion for some period, at least 100 years, and the fish and wildlife habitat for that shoreline community, whichever distance is greater. Conversely, a gradual sloped marine bluff may contain a shoreline much wider than 150 ft. When a shoreline forest is cleared for a house and yard. that acreage is no longer wildlife habitat. Those trees will no longer provide shade and nutrients to the beach invertebrate community or forage fish spawners. RCW 90.58.020 contains language such as: uses shall be preferred that are consistentwith...prevention of damage to natural environment... Alteration of natural conditions of shorelines of the State. in those limited instances when authorized, shall be given priority for... (see Article 1-l.A.5). Shoreline development, according to the RCW, is the exception not the role. In addition, the draft SMP has a "no net loss of shoreline ecological function" provision (Article 1, 3.G.2). The reality is cumulatively, Shoreline development where 2 functioning shoreline habitat is removed for residences or other infrastructure, is in conflict with the no net loss provision. The proposed 150 ft Shoreline buffer is thus a compromise to minimize the damage while still allowing development. Jamestown S'Klallam Tribe supports the default and compromise 150 ft buffer in the Draft. As an alternative to the fixed buffer, the landowner should have the opportunity to prove that the natural Shoreline width on their property is less than 150 ft. 1. A Geotech study will only partially address the "no net loss of shoreline ecological function" provision of the draft code (Article 2-N.5). The Geotech study must include an estimate for 100 years or more of erosion or channel migration (see climate change discussion below for how that erosion should be modeled) with no bank protection. The biology and width of that shoreline would be described in the Habitat Management Plan. The two together would describe the approximate Shoreline width for that property, besides how the landowner plans to use the site. 2. In some cases, the site is degraded habitat, such as dominated by invasive species. In this case the landowner could write a plan where site restoration is used as mitigation for their damage to the shoreline through development. The amount (aerial extent) of restoration must be many times the development footprint; Ecology would provide guidance on the ratio. 3. Even if a Habitat Management Plan is also written, the County is then responsible to determine the accuracy of these reports. County planners likelv will not have this expertise. And frankly. there are some consultants out there that are known to write landowner-friendly reports. A field review of the reoorts bv a team of experts must occur for this to be acceptable. This would be an ID team approach (analogous to Forest Practices review) composed of at least three of Tribal, State Fish and Wildlife, Ecology, Department of Natural Resources, and other County, State, Federal biologists and geologists; or if a minimum of three are not available. the remaining experts hired by the County at the landowners expense. 4. The bar is high for the non-fixed buffer option, and landowners should understand they may end up anyway with the 150 ft buffer plus the expense of the process. Climate change In our January 30, 2009 comments, we included a paragraph on Climate Change. Here is a more detailed recommendation, preceded by a very brief and selected update of the state of scientific state knowledge. In March 2009, climate experts worldwide gathered in Copenhagen to update climate knowledge since the 2007 IPCC (Intergovernmental Panel on Climate Change) report. The 2007 IPCC report really only contained information up to 2005, much has been learned since. In general, the climate is warmin2 faster than the worst case model in the 2007 IPCC report. A Sea-level rise model presented at the meeting was based upon current ice melt rates (Greenland, West Antarctica, temperate glaciers), models show greater than a 1 meter SLR by 2100 (lo5-305m SLR by 2200, and >5m SLR by 2300). Still not included in these models are other worrisome trends. First the arctic permafrost is melting faster than expected releasing methane, a 25 times more powerful greenhouse gas than carbon dioxide. Second the rate of carbon uptake is slowing in the oceans as their temperature increase and the ocean becomes more acidic. Finally, the Amazon forest is a huge carbon sink, an extended drought (like what occurred in 2005) or continued rapid forest conversion, will convert the Amazon to a carbon source. Jamestown S'Klallam Tribe comments April 2, 2009 3 A greater than 3 ft SLR bv 2100 should be the Jefferson County Plannin2 target (storm sur2e will be higher that 3 ft) identified in the Shoreline Manwrement Plan. Sea level rise will flood low lying marine areas and rapidly increase bluff erosion. Jefferson County must place a moratorium on new buildin2 permits (expansion of footprint and new housing) within low-lying marine Shorelines less than 3 ft above the Ordinary Hilili W mer Mark. These likely include all or portions of Beckett Point, Diamond Point, and South Point marine areas, plus others. Within freshwater Shorelines, developmentlbuilding permits should be restricted on the 500-year floodplain to protect public safety and shoreline ecosystems. This likely includes all of Lazy C on the Dosewallips, portions or all of Olympic Canal tracts on the Duckabush, and other Shoreline floodplains on Jefferson County river systems. As an example. the Nisqually and Chehalis Rivers suffered roughly 500 yr flood in separate flood events the past several years. We must recognize this danger and act now. Already the taxpayer and landowner fmancial exposure to Climate Change is enormous, not to mention the loss of ecosystem function; please keep our climate change exposure from increasing. Thank you, Byron Rot Habitat Program Manager CC: Jefferson County Board of County Commissioners Michelle McConnell, Jefferson County planner Scott Chitwood, Jamestown S'Klallam Tribe Natural Resources Director Jamestown S'Klallam Tribe comments April 2, 2009