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HomeMy WebLinkAbout2961-625 ((i-J\ Lf, , lvl1"t 1t1 Jeanie Orr From: Sent: To: Cc: Subject: Jeanie Orr Wednesday, June 17, 20098:50 AM Michelle McConnell AI Scalf; Stacie Hoskins; Jeanie Orr FW: PC RDSMP Attachments: SMP Comments.PDF SMP ments.PDF (122 -----Original Message----- From: Robert.Meier@rayonier.com [mailto:Robert.Meier@rayonier.com] Sent: Wednesday, June 17, 2009 7:54 AM To: #Long-Range Planning; jeffbocc Subject: PC RDSMP County Commissioners and Planning Department Please accept the attached comments in PDF form on the DCD - SMP. I have also copied the letter below for your convenience. Sincerely Robert Meier Manager, Forest and Land Policy Rayonier 360-538-4560 Commissioner Phil Johnson Commissioner David Sullivan Commissioner John Austin DCD - SMP Comments 621 Sheridan St., Port Townsend, WA 98368 Dear County Commissioners and Reviewer Rayonier owns and manages 58,000 acres of forest land in Jefferson County mostly on the west side of the county where working forests are the dominant land use. We manage our lands under the strict Forest Practices Rules of Washington and are certified by the Sustainable Forestry Initiative. Rayonier is asking that you retain language within the proposed Shoreline Master Program that is consistent with RCW 90.58.150 and the prior code relative to the selective commercial timber cutting within shorelines of statewide significance. The current language and RCW state "_thirty percent of the merchantable trees_" may be removed, rather than the newly proposed "_thirty percent (30%) of merchantable timber volume..." to replace "trees". The full language is attached on the next page. The proposed change has negative impacts on landowners, jobs and tax revenue. First it will reduce potential timber harvest in terms of volume and value reducing jobs and tax revenue as well as the income needed to keep working forests working. Secondly, it will increase landowner costs by requiring that the cut trees and all of the leave trees be cruised for merchantable timber volume. A cruiser will have to 1 ZCi (if """---. \ / / tb y\. -,,,.,/' ,.",",.,-,,",~ ~ be sent out to the unit when a forester could simply do a tree count. A tree count system is much more economical and verifiable from a regulatory standpoint. The regulation does not state the method or standard for measurement of volume. In the event of a dispute after the harvest more speculative stump scaling (estimating the volume by measuring the stump and estimating the rest) would have to be used. I would urge the commissioners to adopt language that is consistent with the referenced RCW and forest management practices throughout the state. Sincerely Robert Meier Manager, Forest & Land Policy (See attached file: SMP Comments.PDF) 2 ~ I western Forest Resources Commissioner Phil Johnson Commissioner David Sullivan Commissioner John Austin DCD - SMP Comments 621 Sheridan St., Port Townsend, W A 98368 Dear County Commissioners and Reviewer Rayonier owns and manages 58,000 acres of forest land in Jefferson County mostly on . the west side of the county where working forests are the dominant land use. We manage our lands under the strict Forest Practices Rules of Washington and are certified by the Sustainable Forestry Initiative. Rayonier is asking that you retain language within the proposed Shoreline Master Program that is consistent with RCW 90.58.150 and the prior code relative to the selective commercial timber cutting within shorelines of statewide significance. The current language and RCW state".. . thirty percent ofthe merchantable trees..." may be removed, rather than the newly proposed" ... thirty percent (30%) of merchantable timber volume..." to replace "trees". The full language is attached on the next page. The proposed change has negative impacts on landowners, jobs and tax revenue. First it will reduce potential timber harvest in terms of volume and value reducing jobs and tax revenue as well as the income needed to keep working forests working. Secondly, it will increase landowner costs by requiring that the cut trees and all of the leave trees be cruised for merchantable timber volume. A cruiser will have to be sent out to the unit when a forester could simply do a tree count. A tree count system is much more economical and verifiable from a regulatory standpoint. The regulation does not state the method or standard for measurement of volume. In the event of a dispute after the harvest more speculative stump scaling (estimating the volume by measuring the stump and estimating the rest) wO\1ldhave to be used. I would urge the commissioners to adopt language that is consistent with the referenced RCW and forest management practices throughout the state.i Robert Meier Manager, Forest & Land Policy 3033 Ingram Street. Hoquiam, WA 98550 Telephone (360) 533~7000 · Fax (360) 532-5426 Current Code Lanf!ua2e: Jefferson County Code Title 18 UNIFIED DEVELOPMENT CODE Chaoter 18.25 SHORELINE MASTER PROGRAM 18.25.330 Forest rnanaoernent. (i) Timber situated within 200 feet abutting landward ofthe ordinary high water mark within shorelines of state-wide significance shall only be harvested by selective commercial timber cutting so that no more than 30 percent of the merchantable trees may be harvested in any 10- year period of time provided other timber harvesting methods may be permitted in those limited instances where topography, soil conditions, or silvicultural practices necessary for regeneration render selective logging ecologically detrimental; provided further, that clear-cutting of timber that is solely incidental to the preparation of land for other uses authorized by the Shoreline Management Act and this master program may be permitted. Proposed lanf!uaf!e in Shoreline Master Proeram relative to selective timber harvest within shorelines of statewide sif!nificance: Selective commercial timber cutting on shorelines of statewide significance shall 28 not exceed thirty percent (30%) of the merchantable timber volume in any ten 29 (10) year period as required by RCW 90.58.150. The County may allow 30 exceptions to the thirty percent (30%) limit with a conditional use permit in 31 accordance with WAC 173-26-241(3)(e). RCW 90.58.150 Selective commercial timber cutting,. when. With respect to timber situated within two hundred feet abutting landward of the ordinary high water mark within shorelines of statewide significance. the department or local government shall allow only selective commercial timber cutting, so that no more than thlrtv oercent of the merchantable trees may be harvested in any ten year period of time: PROVIDED, That other timber harvesting methods may be permitted In those limited Instances where the topography, soil conditions or silviculture practices necessary for regeneration render selective logging ecologically detrimental: PROVIDED FURTHER, That clear cutting of timber which is solely incidental to the preparation of land for other uses authorized by this chapter may be permitted.