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HomeMy WebLinkAbout2961-651 ClivI\:- .lne~;fS Page 1 of3 'It.! /, I ,,-.( it/ Jeanie Orr From: Jeanie Orr Sent: Wednesday, June 17, 2009 3:57 PM To: Michelle McConnell Cc: AI Scalf; Stacie Hoskins; Jeanie Orr Subject: FW: PC Revised Draft SMP Comments From: Ryan Hunter [mailto:rhunter@ecoisp.com] Sent: Wednesday, June 17, 2009 12:39 PM To: #Long-Range Planning Subject: PC Revised Draft SMP Comments Dear Commissioners, I am writing to comment on the June 3, 2009 Planning Commission Revised Draft Shoreline Master Program (SMP). I understand and appreciate that the Planning Commission has put a lot of time, thought, and effort into revising the Draft SMP. I'm also aware that many of the revisions involve "word-smithing" or document organization issues, for which I have no significant comment. However, I believe that many of the Planning Commission's most significant revisions weaken rather than strengthen the Draft SMP and I therefore urge the Planning Commission to reverse itself and adopt much of the original language proposed by DCD staff on these significant topics. What follows is a brief summary of my thoughts and recommendations on the significant revisions in the revised Draft SMP. Significant Revisions That I Oppose · Reduce the standard buffer proposed along Shoreline Residential and High Intensity designated marine shorelines to 50' rather than the proposed 150': Marine shoreline buffers serve multiple and critical ecological functions. Marine shoreline buffers provide wildlife habitat, filter pollutants, stabilize banks, control sediment inputs from surface erosion, regulate freshwater delivery, provide shade, and contribute organic matter. The proposal to reduce the shoreline buffer from 150' to 50' is not adequate enough to serve these multiple functions and is not supported by the scientific literature on the subject. To my knowledge, the Planning Commission did not consult a single scientific expert or reference a single scientific study before approving the proposed reduced buffer. I strongly recommend that the Planning Commission reverse itself and support the original proposal of a 150' marine shoreline buffer. · Allow single family residential development on non-conforming lots to use the Common Line Setback provision when neighboring homes are within 300' rather than the proposed 50' separation: It is my understanding that this revision would increase the number of applicable non-conforming lots that could reduce the size of marine shoreline buffers for the purpose of preserving views. Given the ecological importance of marine shoreline buffers as previously stated, and their importance to the 6/1 7/2009 Page 2 of3 effectiveness of any SMP, I oppose any revision that would decrease buffer size for the sake of preserving views. I recommend that the Planning Commission reverse itself and support the original 50' separation proposal. · Eliminate the differentiation between public and private beach access structures and boating facilities rather than the proposed preference for public facilities: This revision would not only increase the number of structures and boating facilities on our shoreline, thus increasing the cumulative ecological impact of such structures, but also reduce the amount of public access to the shoreline, a key feature of the SMP. In addition, public structures provide opportunities to build community, for neighbors to meet each other and for increased social interactions generally. I believe the original preference for public facilities would benefit the county both ecologically and socially and I recommend that the Planning Commission reverse itself and support the original proposal. · Allow geoduck aquaculture along all marine shorelines without local permits, except as a conditional use when adjacent to Shoreline Residential designated shorelines rather than the original proposal to require conditional use permits for all geoduck aquaculture: Due to the fact that the proliferation of geoduck aquaculture is relatively new, there is not an extensive body of knowledge about how best to manage the industry. As a result of this relative lack of knowledge, and the fact that residential development also exists along Conservancy and some Natural designated shorelines, I recommend application of the precautionary principle and requiring a conditional use permit for all geoduck aquaculture. The regulations could be revised in the future when more information is available to guide management of the industry. · Allow some finfish net pen aquaculture rather than prohibiting it outright: Finfish net pen aquaculture has proven incredibly destructive of marine ecosystems where it has been practiced in British Columbia. Outright prohibition is fully justified given the existing knowledge of the industry's impacts. If the Planning Commission believes that some future technology will reduce the impact, then the prohibition can be revisited at that time, but until then, I recommend that the Planning Commission support the original proposal for an outright prohibition. Significant Revision That I Support · Prohibit mining in river channels: I support the prohibition of mining in river channels and believe that the Planning Commission could go further by prohibiting mining activity in floodplains, Channel Migration Zones (CMZ), and Conservancy designated shorelines. Significant Revision That I Recommend I have an additional recommendation that was not addressed by the Planning Commission. The Draft SMP 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 therefore be simpler to prohibit outright large hydroelectric dam projects, as such projects would not be appropriate for any of the county's rivers. 6/17/2009 Page 3 of3 I recommend that reference to large hydroelectric dams be deleted from line 6 on page 7-27. Moreover, I recommend that a period be placed after the word "permitted" in line 4 on page 7-28, and that the remainder of regulation number "I" (lines 5 through 10 on pages 7-28) be deleted. Thank you for the opportunity to comment on this very important issue. I hope the Planning Commission ensures that the Draft SMP is as strong and protective as it can be based on the best available science. Thank you for your work on this issue. Regards, Ryan Hunter 1423 Grant St. Port Townsend, W A 98368 6/1 7/2009