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Jeanie Orr
I
From:
Jeanie Orr
Sent: Wednesday, June 17, 20093:57 PM
To: Michelle McConnell
Cc: AI Scalf; Stacie Hoskins; Jeanie Orr
Subject: FW: PNP Tribes Comments on the PC Revised Draft SMP
Attachments: PNP Tribes Response to PC 50 ft buffer proposal_6 17 09.doc; Jeff SMP letter_PNPTribes_6
17 09-FinaL pdf
From: Steve Todd [mailto:stodd@pnptc.org]
Sent: Wednesday, June 17, 2009 12:56 PM
To: #Long-Range Planning
Cc: 'Scott Chitwood'; 'Sarah Burlingame'; paulm@pgst.nsn.us; rharder@pnptc.org; 'Chris Weller'; 'Hans
Daubenberger'; 'Mike McHenry'; rbrocksmith@hccc.wa.gov; 'Stewart, Jeff R. (ECY)'; twright@nwifc.org;
stallison2000@yahoo.com; dherrera@skokomish.org; 'Byron Rot'
Subject: PNP Tribes Comments on the PC Revised Draft SMP
Planning Commission and County Planning Staff:
Regarding the Jefferson County Planning Commission Revised Draft SMP, please see the attached comment letter
(in pdt) and separate analysis document from the Point No Point Treaty Council, Jamestown S'Klallam Tribe, and
Port Gamble S'Klallam Tribe.
Thank you,
Steve Todd, Habitat Biologist
Point No Point Treaty Council
360-297 -6526
6/17/2009
Response to 50' Buffer Proposal by the Jefferson County Planning
Commission for Marine Shorelines Designated High Intensity and Shoreline
Residential in the Preliminary Draft Shoreline Master Program
Prepared by:
Steve Todd and Sarah Burlingame, Point No Point Treaty Council (pNPTC)
and Byron Rot, Jamestown S'Klallam Tribe (JSKT)
June 17,2009
Background and Tribal Recommendation
In Spring 2009, the Jefferson County Planning Commission (PC) made a recommendation to reduce the
standard buffer from 150' (as it occurs in the Preliminary Draft Shoreline Master Program [PDSMP]) to
50' for designated High Intensity (HI) and Shoreline Residential (SR) shorelines in the PDSMP. This
document presents a summary of a review and analysis done in response to the 50' buffer proposal
submitted by the PC.
We recommend the following as a response to the Planning Commission buffer reduction proposal:
· Shoreline Residential (SR) shorelines that are designated Priority Aquatic (PA) below OHWM
should have standard 150' buffers. The PA designation was assigned to shorelines that are
particularly supportive to salmonid habitat, highly productive shellfish beds, and other ecological
values, notably documented forage fish spawning.
· SR shorelines that are Aquatic (A) below OHWM but have noted ecological values including
sediment source/feeder bluff, well-forested/vegetated uplands within shoreline jurisdiction, and/or
border estuarine habitats, should have standard 150' buffers.
· All other SR shorelines should have 50' buffers.
· High Intensity (HI) shorelines should have 50' buffers.
Methodology
We performed an in-depth review and analysis of all Shoreline Residential (SR) designated shorelines as
interpreted from pdfmaps available online that accompany the PDSMP. To enable this review, we
consulted air photos, including the most recent available Washington Dept. of Ecology oblique series (~
2006) and a shoreline geomorphology dataset available through the Salmon and Steelhead Habitat
Inventory and Assessment Program (SSHIAP). As a surrogate for assessing the degree of forest cover, we
calculated impervious surface for all marine shorelines within shoreline jurisdiction and summarized
percent imperviousness by Shoreline Reach and Shoreline Designation. We used impervious surface data
derived from the 2006 National Agricultural Imagery Program (NAIP) color ortho-photos and made
available from the Hood Canal Coordinating Council (HCCC). Using geographic information systems
(GIS), the impervious surface polygons were "clipped" within the 200' shoreline jurisdiction of the
marine shorelines.
Results of Impervious Surface Analysis
Table I provides a summary of our analysis of impervious surface for marine shorelines within Shoreline
jurisdiction (from OHWM to 200 ft. landward of OHWM). We used the results of impervious surface
within the different shoreline reaches and designations to evaluate the level of development that has
occurred within these reaches and designations.
Table 1. Summary of Impervious Surface Analysis by Shoreline Environment Designation
(rounded up to whole numbers).
Shoreline Shoreline
Environment Length
Designation (km)
0/0
Shoreline
length
%
%
Impervious
Minimum
%
%
Impervious
Mean
Impervious
Maximum
Impervious
Standard
Deviation
Natural 103 41 3 0 26 5
Conservancy 77 30 6 0 23 6
SR (P A) 19 8 10 2 22 5
SR (A), (but 26 10 8 2 19 4
with noted
ecological
values)
Other SR (no 19 8 17 0 46 11
P A or other
noted
ecological
values)
High Intensity 9 3 31 5 92 22
All Designated 253 100 8 0 92 II
Shorelines
SR = Shoreline Residential
P A = Priority Aquatic
A = Aquatic
Shoreline Residential (SR) shorelines that have a parallel Priority Aquatic (P A) designation, and SR
shorelines that have an Aquatic (A) designation but have notable sediment source/feeder blufffeatures
and/or are well-forested, have levels of impervious surface that are similar to that found in Conservancy
(C) designated shorelines. Shoreline Residential (SR) shorelines that are designated as Aquatic below
OHWM and have sediment source/feeder bluff, estuarine habitat, or well-forested uplands within
shoreline jurisdiction are described below with selected oblique air photos courtesy of the Washington
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Dept. of Ecology. Due to noted ecological values, we recommend that these shorelines have a
standard 150' vegetated buffer. Please consult the on-line PDSMP Maps for more details of the
shoreline reaches and designations.
Reach D (see Figure 1)
This reach is well-forested and adjacent to Priority Aquatic (PA) just south of the Duckabush Estuary.
Figure 1. Reach D. Photo courtesy of Washington Dept. of Ecology.
Reach F (see Figures 2 and 3)
This reach is well-forested, contains sediment source/feeder bluff, and estuarine habitats.
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Figure 2. Reach F showing estuarine habitat and kettle "lake". Photo courtesy of Washington Dept.
of Ecology.
Figure 3. Reach F showing feeder bluff and well-forested uplands. Photo courtesy of Washington
Dept. of Ecology.
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Reach G (see Figure 4)
This reach is well-forested.
Figure 4. Reach G. Photo courtesy of Washington Dept. of Ecology.
Reach H (see Figure 5)
This reach is well-forested and within a unique embayment.
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Figure 5. Reach H, along south shore of Pleasant Harbor. Photo courtesy of Washington Dept. of
Ecology.
Reach I (see Figure 6)
The section of Reach I that extends north of Pleasant Harbor to immediately south of the Dosewallips
River delta is mostly a well-forested sediment source/feeder bluff. The section of Reach I immediately
south of the entrance to Pleasant Harbor is more fragmented and mostly built out parcels.
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Figure 6. Reach I. Photo courtesy of Washington Dept. of Ecology.
Reach W (see Figure 7)
We recommend standard 150' buffers along the eastern section of the reach from where Shine Rd. leaves
the shoreline. This eastern portion of the reach is well-forested, and a sediment source/feeder bluff,
appearing particularly unstable at the eastern end of the reach.
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Figure 7. Eastern section of Reach W. Photo courtesy of Washington Dept. of Ecology.
Reach AA (see Figure 8)
This reach is mostly well-forested or vegetated sediment source/feeder bluff shoreline. We recommend
that for the east section Reach AA, where Shine Road moves out of Shoreline jurisdiction and where
feeder bluffs become prominent, the standard buffer be 150'. For the west portion of the reach, where
Shine Road occurs along the shoreline, the standard buffer be 50'.
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Figure 8. Reach AA. Photo courtesy of Washington Dept. of Ecology.
Reach EE (see Figure 9)
The shoreline includes an estuary and mostly well-forested conditions from along the north shore of Mats
Mats Bay (immediately south of the creek mouth) to the northern extreme of Reach EE. An exception
occurs at the very end ofthe reach, where the forest is highly fragmented. We recommend 150' buffers
for the north portion of Mats Mats Bay and the inlet to the bay. For the south "lobe" of the bay, we
recommend a 50' minimum buffer.
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Figure 9. Reach EE just north of Mats Mats Bay. Photo courtesy of Washington Dept. of Ecology.
Reach HH (see Figures 10 and 11)
With the exception of the most northerly section of this reach (beginning where a small point oflandjuts
out just south of Little Oak Bay Lagoon), most of this reach is well-forested and much of it is sediment
source/feeder bluff.
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Figure 10. Reach HH. Photo courtesy of Washington Dept. of Ecology.
Figure 11. Reach HH. Photo courtesy of Washington Dept. of Ecology.
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Reach PP (see Figure 12)
This reach is mostly well-forested and includes sediment source/feeder bluff.
Figure 12. Reach PP. Photo courtesy of Washington Dept. of Ecology.
Reach ZZ (see Figure 13)
This reach is mostly well-forested sediment source/feeder bluff north of Port Hadlock.
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Figure 13. Reach ZZ between Port Hadlock and Irondale (mouth of Chimacum Creek). Photo
courtesy of Washington Dept. of Ecology.
Reach FFF (see Figure 14)
This reach includes a precipitous sediment source/feeder bluff immediately north of the Cape George
Marina and additional feeder bluffs occur south of the marina (see Figure 15).
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Figure 14. Reach FFF immediately north of the Cape George Marina. Photo courtesy of
Washington Dept. of Ecology.
Figure 15. Reach FFF south of Cape George Marina. Photo courtesy of Washington Dept. of
Ecology .
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Reach JJJ (see Figure 16)
This reach is mostly well-forested.
Figure 16. Reach JJJ that is considered Shoreline Residential and Aquatic in the PDSMP. Photo
courtesy of Washington Dept. of Ecology.
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Port Gamble S'Klallam Tribe Point No Point Treaty Council Jamestown S'Klallam Tribe
June 17,2009
Peter Downey, Chairman
Jefferson County Planning Commission
621 Sheridan Street
Port Townsend, W A 98368
Re: June 3, 2009 Planning Commission Revised Draft Shoreline Master Program
Dear Chairman Downey and Fellow Commissioners:
The Jamestown S'Klallam and Port Gamble S'Klallam Tribes, and the Point No Point Treaty
Council have been active participants and monitored progress in the revision of the County SMP
during the past 2-3 years. We offer the following comments with respect to the June 3, 2009
Planning Commission Revised Draft Shoreline Master Program (PC Revised Draft SMP). The
Tribes depend on the protection and restoration of Jefferson County shorelines and habitats to
support healthy fish, shellfish, and wildlife populations into the future. As you are aware, there
are several salmonid species that use Jefferson County shorelines and are currently on the federal
Endangered Species Act (ESA) list, and a significant regional umbrella group, the Puget Sound
Partnership, is mobilizing a broad spectrum of stakeholders in an effort to protect and recover
Puget Sound to a healthy condition. There are compelling reasons for Jefferson County to
implement a SMA that is in concert with a regional goal to move away from pervasive and
ecologically damaging shoreline development that has been in place for generations, and toward
a plan that better protects (and restores) the shoreline. The Tribes seek a SMP that adequately
meets that larger goal.
The Tribes have serious concerns with key aspects of the 6/3/09 PC Revised Draft SMP. This
letter intends to provide the basis for our concerns and constructive criticism on these specific
Issues.
Our primary concerns are the following (Note: the first 4 bulleted items address non-conforming
lots or structures):
· PC recommendation to reduce the Preliminary Draft Shoreline Master Program (PDSMP)
standard marine shoreline buffer from 150' to 50' for all Shoreline Residential (SR) and
High Intensity (HI) designated shorelines.
· PC recommendation for increased distance provision from 50' to 300' as it applies to the
Common Line Setback rule for non-conforming single family residential development.
· PC recommendation to allow reconstruction of damaged/destroyed non-conforming
homes/structures without clear discretion to the source (i.e., fire, flood, channel
migration, landslide, etc.) of the damage/destruction.
· PC language pertaining to expansion of existing non-conforming homes.
· PC recommendation largely eliminates the distinction between public and private beach
access and overwater structures.
· PC recommendation largely eliminates the Conditional Use Permit (CUP) review
process, particularly where it pertains to beach access and overwater structures associated
with single family residential development.
In addition to these issues, we provide comments on SMP implications of climate change-related
sea level rise, and recommendations as to how the County (and partners) could effectively begin
to monitor for "no net loss" of ecological functions.
Buffer Reduction from 150' to 50' in SR and HI Shorelines
In response to the PC proposal to reduce marine shoreline buffers along SR and HI designated
shorelines from 150' to 50', the Tribes conducted an in-depth review and analysis of the
shorelines in question in order to better understand these shorelines ecological condition and
value (see attached report). One of the main arguments used by the PC was that most SR and
HI shorelines are largely built out and that wildlife habitat that would benefit from buffers wider
than 50' is already compromised. This is an overly simplistic view of these shorelines, as
ecological protections must consider wildlife, water quality, geomorphic processes (e.g., erosion,
sediment inputs, etc.), and contributions of wood and food to the nearshore. The 50' buffer
proposal does not reflect the science to be used in protecting a suite of ecological functions. Our
analysis reveals that many of the SR shorelines are actually well-forested and have relatively low
levels of impervious surface (an indicator of landscape development). In addition, many of the
SR shorelines are sediment source beaches or "feeder bluffs" that naturally erode over time and
therefore provide the necessary sediment and organic inputs to drift cells, maintaining our
beaches, spits, and nearshore ecological functions. Following this logic, implementing a standard
50' buffer along many of these shorelines means the buffer width would decrease over time as
the shoreline recedes, diminishing wildlife habitat, risking water quality, and leading to pressures
to armor the shoreline in order to protect homes and structures. By removing native vegetation as
close as 50' to the shoreline we potentially alter hydrologic conditions and undermine root
strength that holds soil, and in so doing, we potentially welcome accelerated erosion along
shorelines that already erode. Implementing 50' buffers along shorelines where much of future
development is likely to occur is likely to promote future shoreline armoring, which is
inconsistent with the intent of the SMA.
County and State agencies are being advised to begin planning for sea level rise associated with
climate change (see section below on 'Climate Change and Sea Level Rise'). It is expected that
many of our shorelines that already naturally erode and low-lying areas (including spits and tidal
estuaries) will be among the most affected by sea level rise, which would likely accelerate
erosion rates along many shorelines. The 50' buffer recommendation not only degrades
ecological conditions over time when played out across shoreline reaches, but it also puts people
2
at risk when they place homes too close to the shoreline. When we consider potential accelerated
erosion under current climate change and sea level rise projections, these risks grow only bigger.
We understand there are political pressures and benefits to minimizing the number of non-
conforming parcels and to phase out non-conforming developments over time. Reducing the
standard buffer in SR shorelines to 50' certainly helps to reduce non-conformity. However, this
represents a compromise of the standards at the cost of ecological functions. The PDSMP
already contains sufficient flexibility to allow landowners under certain conditions to implement
buffers more narrow than 150'.
Based on our analysis of the SR and HI shorelines in the attached report, we propose applying
the following standard buffers to Shoreline Residential (SR) and High Intensity (HI) shorelines:
· 150' standard buffer along SR shorelines that have a parallel Priority Aquatic (PA)
designation.
. 150' standard buffer along SR shorelines that have the above noted ecological values,
particularly shorelines that are well-forested, have relatively low impervious surface,
and/or provide sediment sources ("feeder bluffs") to our beaches (these reaches are
described in the attached report and in a GIS file available on request).
· We recommend that the SR shorelines that do not fit within either of the above categories
have a 50' buffer.
· 50' standard buffer in the High Intensity (HI) designated shorelines. The HI shorelines
are clearly built out shorelines (e.g., our analysis showed HI shorelines average about
30% impervious surface) where development has long been established.
Non-Conforming Lots (in the Context of the 50' Buffer Proposal)
The approach to address non-conforming lots outlined in both the PDSMP and the PC Revised
Draft SMP contradicts the following (which we support) from Article 6.1.B.1 of the PC Revised
Draft SMP (bold italics added for emphasis):
"1. All shoreline use and development, including preferred uses and uses that are exempt
from permit requirements, shall be located, designed, constructed, conducted, and
maintained in a manner that maintains shoreline ecological processes and functions.
2. Uses and developments that cause a net loss of ecological functions and processes shall be
prohibited. Any use or development that causes the future ecological condition to become worse
than current condition shall be prohibited."There are approximately 450 non-conforming
Shoreline Residential-designated lots in Jefferson County. Bypassing substantive permit review
prior to the development of this many lots, will result in net loss of ecological function over time.
The Planning Commission strategy of reducing the number of non-conforming lots by drastically
reducing the standard buffer width from 150' to 50' does not fix the problem of cumulative
impacts to ecological functions. In fact, it would effectively promote ecological damage and
future non-conformance when we (re)leam in the future that the 50' buffers were a mistake.
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Common Line Setback Distance Provision Increasedfrom 50' to 300' (Article 6.7)
The PCSMP proposes increasing the distance between homes from 50' to 300' in order to
qualify for the 'Common Line Setback' (CLS) rule as it applies to non-conforming development.
We recommend there not be any distance provision since non-conforming lots are by definition,
small. Both the PDSMP and PCSMP allow for the CLS rule if existing homes occur on one or
both sides of the proposed development. We recommend that the provision be revised such that a
proposed development would be eligible for the CLS rule when existing homes occur in the
parcels adiacent on both sides of the non-conforming proposed development. We believe this
would minimize the proliferation of "non-conforming" development over time.
The CLS rule (as does the PC-proposed 50' buffer along SR shorelines) allows minimal buffers
(e.g., as narrow as 30 ft. where CLS applies) and will likely necessitate armoring shorelines in
order to protect homes and other structures in the future. This contradicts Article 8.8.A.5:
"New residential development should be planned and built in a manner that avoids the need
for structural shore armoring and flood hazard reduction."
The stated purpose of employing the CLS is to"... (accommodate) shoreline views to be adequate
and similar to adjacent residences but not necessarily equivalent. . ." The CLS therefore allows for
reduced buffers/setbacks for a new residential development to have a comparable buffer/setback to
their adjacent neighbor(s), which in many instances is extremely minimal. The preservation of views
should not take precedence over the protection of ecological processes and functions. Employing the
CLS in this way cumulatively over the long-term will result in the loss of ecological functions. The
allowance of minimal buffers under the CLS rule when coupled with potentially high numbers of
undeveloped non-conforming lots, will make it very difficult or impossible for the County to meet its
no net loss mandate.
The Final Cumulative Impact Analysis needs to determine the approximate number of potential CLS
lots, their distribution, and their likely impacts to ecological functions. The County will then need to
consider how to compensate for these and other cumulative impacts (e.g., from developing non-
conforming lots) through implementation of stewardship programs, mitigation, restoration actions,
and targeted property acquisitions.
Reconstruction of Non-conforming Single Family Residences Following DamagelDestruction
Article 10.6.A.4 of the PC Revised Draft SMP allows for the reconstruction of a non-conforming
home in the same footprint following "major damage" from fire, flood, or other natural event
even when the lot configuration would allow for relocation in conformance with new standards.
First, the term "major damage" needs to be defined. Second, though no less important, this
provision should apply only to fire-damaged/destroyed homes, not homes damaged/destroyed by
floods, channel migration, landslides, or other geologic events. There is no sense in allowing
reconstruction in a precarious geologic location. Any rebuild of a non-conforming home that is
damaged/destroyed by a flood or other geologic event needs to conform to the new standard
buffers. We propose that even if a non-conforming structure is damaged/destroyed by fire, the
owner should be encouraged to rebuild or move remaining structures to a location that is in
conformance with new standards, or at least to a location that is a greater distance from the
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shoreline or critical areas. We also propose that damaged/destroyed structures that were
originally built waterward ofthe ordinary high water mark (OHWM) be required to be
reconstructed landward of the OHWM.
Finally, the County should consider a investing in a program that provides options to relocate
people to locations that are not at risk of geologic hazards and that are outside of shoreline
jurisdiction and critical areas if possible when their homes or businesses have been
damaged/destroyed by fire or geologic events (i.e., flood, channel migration, landslide).
Expansion of Existing Non-conforming Residences
In Article IO.6.D.2 regarding expansion of non-conforming single family residences, the PC
Revised Draft SMP allows for "the increase/expansion in total footprint area (when the
expansion) does not threaten critical areas". This makes no sense as it seems impossible to avoid
a critical area when a development already does not conform (i.e., "non-conforming") to
standards. Instead, we recommend that the language in the PDSMP from Article IO.6.F be
retained.
Distinction between Public and Private Beach Access and Overwater Structures
In Article 7 of the PC Revised Draft SMP the distinction between public and private overwater
and beach access structures is largely eliminated where this distinction was rightfully made in the
PDSMP. The PC Revised Draft SMP needs to differentiate between public and private beach
access and overwater structures (OWSs) to prevent the cumulative impacts associated with
proliferation of many private structures. The policies and regulations need to instead encourage
and emphasize shared use of beach access and overwater structures, including existing structures,
whenever possible.
In Article 7, 1. Beach Access Structures. A. Policies, the PC Revised Draft SMP refers to
minimizing "significant adverse effects". "Significant" needs to be defined, otherwise this is
unenforceable.
Elimination of Conditional Use Permits (CUPs)
Article 7, IB, (Shoreline Environment Designations), 1 through 6, ofthe PC Revised Draft SMP,
eliminates requirements for conditional use permits (CUPs) that were found in the PDSMP [e.g.,
beach access and overwater structures [see Art. 4, Table 1)]. The intent of a CUP is to trigger
more rigorous review by County staff and importantly, by Ecology, and others (e.g., Tribes)
because there are greater risks to ecological functions associated with these shoreline uses. We
realize that much of the reason for eliminating CUPs is that the County simply has few resources
and lacks expertise to review these proposals and judge whether no net loss of ecological
function will likely occur. Lack of resources is not a valid reason for avoiding regulatory
responsibility. Eliminating the CUPs will only facilitate the proliferation of beach access and
overwater structures that translate into cumulative impacts to marine riparian forests (e.g., forest
fragmentation and simplification), sediment delivery and transport, nearshore habitat structure
(e.g., overwater structures and prop scour effects on eelgrass beds), and heightened risks to water
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quality associated with greater boat traffic in the nearshore. We recommend retaining the CUPs
found in the PDSMP (Article 4. Table I) so that adequate review is afforded through Ecology.
Tribes. and others.
Climate Change-related Sea Level Rise
In general, the PC Revised Draft SMP ignores climate change, which we are currently
experiencing and will continue for the remainder of this century and likely for centuries to come.
The document erroneously assumes our past experiences can be a guide for the future. The
climate change models are consistent in describing a future of increased extreme weather events,
both winds and flooding. The shoreline, whether marine or freshwater, is the most vulnerable
landscape to climate change. Flooding in Puget Sound watersheds over the past few years will
become more common in the future. In addition, as scientists continue to refine their models, the
amount they predict for sea-level rise (SLR) increases. Current estimates are now 3-4 ft SLR by
2100, with some scientists arguing this number is still substantially too low. Sea-level rise,
combined with more frequent winter storms, will rapidly change the erosion rate and flooding
along marine shorelines.
A greater than 3 ft SLR by 2100 should be the Jefferson County planning target (storm surge will
be higher than 3 ft) identified in the Shoreline Management Plan. Sea level rise will flood low
lying marine areas and rapidly increase bluff erosion. Jefferson County must place a moratorium
on new building permits (expansion of footprint and new housing) within low-lying marine
shorelines less than 3 ft above the Ordinary High Water 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 SOO-year
floodplain to protect public safety and shoreline ecosystems. FEMA is already moving in this
direction. 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 floods in separate flood
events during the past several years.
Definitions (Article 2)
The definition for "feeder bluff" should be "any shoreline that contributes sediment to a drift
cell."
Monitoring
To help gauge whether no net loss of habitat function is occurring over time, at a minimum, we
recommend monitoring the following changes within the shoreline jurisdiction (and in
watersheds). Some of this monitoring could be accomplished by systematically tracking permits
for bulkheads, overwater structures, fill, and other actions:
. Changes in forest cover (and across watersheds)
. Changes in impervious surface (and across watersheds)
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. Changes in shoreline armoring (Le., bulkheads, dikes, etc.)
· Changes in overwater structures
. Changes in wetland fill (including intertidal habitats)
As sovereign nations that share the watersheds, shorelines, and waters with Jefferson County
citizens, the Tribes are interested in sustained and further engagement with County staff, the
Planning Commission, and others in developing the most effective strategies for protection,
restoration, and stewardship of our shorelines.
We thank the many individuals who have participated in reviewing the Jefferson County SMP
and the time taken by members of the Planning Commission. We urge the PC to seriously
consider our comments in your final recommendations to the Board of County Commissioners.
Please direct any questions to Steve Todd, Habitat Biologist with the Point No Point Treaty
Council at 360-297-6526, or Byron Rot, Habitat Biologist with the Jamestown S'Klallam Tribe
at 360-681-4615.
Sincerely,
Scott Chitwood, Natural Resources Director
Jamestown S'Klallam Tribe
/2;~
Paul McCollum, Natural Resources Director
Port Gamble S'Klallam Tribe
~~~A
Randy Harder, Executive Director
Point No Point Treaty Council
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