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Jeanie Orr
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From: Jeanie Orr
Sent: Wednesday, June 17, 2009 8:48 AM
To: Michelle McConnell
Cc: AI Scalf; Stacie Hoskins; Jeanie Orr
Subject: FW: Hood Canal Environmental Council Comments on the Draft SMP
From: Andrea Mitchell [mailto:andrea88@embarqmail.com]
Sent: Tuesday, June 16, 2009 9:27 PM
To: #Long-Range Planning
Subject: Hood Canal Environmental Council Comments on the Draft SMP
Members of the Hood Canal Environmental Council (HCEC) are property owners and residents in the Hood Canal
region, including Jefferson County, with a vested interest in protecting the health of our shared ecosystems,
These ecosystems rely on regional, state-wide, national and world-wide commitment to long term, science-based
protection. Economically speaking, it is our belief that the health of these ecosystems is the single most important
element in a healthy economy over the long-term. In terms of public health, maintaining water quality and
ensuring that buffers adequately protect citizens from dangers such as flooding and landslides are critically
important.
Shoreline Master Plans are potentially in effect for decades and as such should consider the exponentially
increasing intensity of use and density of population that our region will face in the future. If the past is a guide,
progressive environmental protection that was once deemed extreme by some, has become commonly accepted
or is considered minimal or inadequate now, as our population grows and pressure on natural systems increases.
The State prioritizes no net loss of ecological processes and functions and (RCW 90.58.020), "To this end, uses
will be preferred that are consistent with control of pollution and prevention of damage to the natural
environment." Many of Jefferson County's shorelines are Shorelines of State-Wide Significance and should be
managed with these priorities in mind.
We understand that the Jefferson County Draft Shoreline Master Plan has been over three years in the writing
and we have witnessed repeated calls for public involvement throughout that time. The resulting draft document
with the exception of one element was generally supported by HCEC in January of this year. While we are
appreciative of the hundreds of volunteer hours that have gone into the edited plan, in general we support the
original draft with the exception of mining and mining activities allowed in conservancy shoreline and shoreline of
statewide significance.
The Planning Commission draft continues to include language allowing mining related activities such as piers and
conveyer belts in shorelines zoned conservancy. Much of this shoreline is also shoreline of state-wide
significance. The state prefers activities that prevent damage to the natural environment and activities that
promote long-term, state-wide benefit over short-term local benefit. The allowed mining and mining related
activities have the potential to cause substantial environmental damage. Products from mining are non-renewable
and are therefore unsustainable. Unsustainable activities provide one-time, short-term benefit and should be
prohibited in shorelines of state-wide significance and conservancy shore. HCEC has long been on record
opposing mining in sensitive shoreline areas.
The draft plan is a complex document and we would like to respond with a some additional specifics. We support
the changes made to clarify but not weaken the intent of the original draft where environmental protection is
concerned. We also support revisions that increase environmental protection, for example the increased
protection given to freshwater shorelines with respect to mining and the changes in Article 7.1.C.5 (iii), where the
distance has been increased to 500 feet.
6/17/2009
Page 2 of3
We are highly supportive of regulations such as in Article 6,1.8.2 that prohibits uses and developments that cause
a net loss of ecological functions and processes. This supports the State's mandate for no net loss. However, the
next regulation is in direct conflict, allowing for uses that will cause a net loss and not specifying that the mitigation
be functionally equivalent to the natural loss. Where mitigation is allowed, the level of performance of the
mitigation should be specified. If mitigation performance falls short of the natural functions it replaces, there will be
a net loss of ecological function.
HCEC supports buffer widths that accomplish full protection of ecological function and water quality. While
specific setback distances are an imperfect method of dealing with a widely variable subject, shoreline buffers of
150 feet are an acceptable compromise that increases environmental protection while still allowing development.
Public safety is increased with allowed development being potentially better protected from flooding, erosion, and
earthquake damage. We feel that the needs of owners of non-conforming shoreline lots were well addressed in
the original draft but support simplification of the process parcel owners must follow in repairing or developing
their lots. Consistently applying the 150 foot buffer to streams and rivers as well as marine shorelines makes
ecological sense and is more equitable (RCW 90.58). It makes no sense to justify and apply a 150 foot buffer on
inland fresh water and to reduce that buffer on marine shorelines protecting that same water.
It is our belief that increased intensity of use and density in housing should come with a proportionally equal or
increased responsibility to protect the environment, not less. These uses benefit a greater number of
people than residential zoning would, however that number is small relative to the population of the State, all of
whom rely on healthy marine ecological function. Since high density housing and intensive use areas are likely to
have a high level of impact and exposure, they should be positive models of environmental protection. We believe
reducing buffers for high intensity use or high density housing to 50 or even 30 feet, as has been proposed, will
cause a net loss of ecological function.
The Shoreline Master Plan is a long-term document that will cover periods of climate change and potential sea-
level changes. While it can be politically unpopular to be proactive, it is a sound economic and long-range
planning and HCEC supports the creation of language to deal with potential environmental issues resulting from
climate change.
It is well known that the marine waters of Hood Canal are slow flowing/flushing which means that water pollution
in anyone area stays in the canal for long periods of time. This can only lead to increased water quality problems
in this sensitive body of water. HCEC supports a ban on all fish farming in the marine environment of the canal.
Some may consider net pen fish farming as preferred, water dependent use, and as such, a use that the state
would support. However, as commonly practiced, it has the potential to cause more environmental harm than
economic benefit. Those economic benefits are short term in relation to the long-term health of our marine water.
Shoreline Master Plans will only become more important as time passes, scientific knowledge increases,
and human population grows. Growth and the effects of growth will increase exponentially. Most shoreline
development has a permanent effect on the shoreline environment that we feel can not meet the no net loss
provision, however, in reality, compromises are made. We feel the minimum acceptable buffer width is 150 feet
and recognize it as a compromise. This is not choosing the well being of the environment over residents of the
region, rather it recognizes that residents are dependent on ecosystem health for their own health. HCEC is
appreciative off the effort and time involved in creating a visionary, long-term plan to guide development and
protect the health of our waters and shorelines. In particular, we would like to thank the members of the Jefferson
County Planning Commission and Long-Range Planning Department in their past and continued efforts.
Respectfully submitted by Andrea Mitchell for the Hood Canal Environmental Council
6/17/2009