HomeMy WebLinkAbout016 2025-05-07_report CAO Engage JC Public Comment Public Comment on SPTH Integration in Jefferson County Critical Area Ordinance
To: Jefferson County Department of Community Development & Jefferson County Planning Commission
From: Engage JC
Date: 5/7/2025
Subject: Adopt SPTH-Based Riparian Buffers in the CAO and Ensure Equitable Compliance
Introduction
We are submitting this public comment to urge Jefferson County to adopt Site Potential Tree Height
(SPTH) as the foundational standard for riparian buffer widths in its Critical Area Ordinance (CAO), and
to implement this policy through equitable, community-supported strategies. This method—supported by
science and consistently recommended by Northwest Treaty Tribes—offers a defensible and effective
approach to riparian protection that aligns with the County’s obligations to environmental health, climate
resilience, and intergovernmental responsibility.
What is SPTH?
Site Potential Tree Height (SPTH) is a measurement of the height that dominant trees would naturally
reach at a given location, if undisturbed. This metric is used to set riparian buffer widths that ensure
adequate shading, bank stability, water filtration, and wood recruitment—functions that are critical for
fish-bearing streams and overall watershed health.
The Northwest Indian Fisheries Commission (NWIFC) defines SPTH-based buffers as: “At least one site
potential tree height in width on each side of the stream. This width reflects the minimum needed to
provide full riparian functions.” (Riparian Management Recommendations, Volume 2 – NWIFC, 2018)
Tribal Recommendations
SPTH-based buffers have been consistently recommended by regional Tribes through formal
government-to-government consultation processes. Our outreach and engagement with the Northwest
Treaty Tribes, Northwest Indian Fisheries Commission, Jamestown S’Klallam Tribe Environmental
Planning, and Quileute Natural Resources confirms that SPTH is the preferred and necessary approach for
protecting riparian health and salmon habitat.
The Quileute Tribe emphasized that, “The Tribe obviously needs to be involved in this process.” A key
concern raised was the County’s use of variances—these have a clear impact on Tribal resources and must
require Tribal consultation. They cannot continue to be granted as they have in the past.
Local Relevance
Jefferson County’s watersheds support salmonid species and flow through areas of deep cultural and
ecological significance to multiple Tribes. Yet, the draft CAO policies fall short of integrating
ecologically functional standards or honoring treaty rights. The County also has a history of limited
engagement with Tribal governments on the West End. Communities like the Quileute and Hoh must be
included meaningfully in any planning process that impacts their lifeways, watersheds, and reserved
rights.
Equitable Implementation Strategies
To implement SPTH fairly, we recommend the following strategies:
- Establish or expand cost-sharing programs for riparian restoration, prioritizing low-income, Tribal, and
rural landowners.
- Use phased rollout based on parcel size, ecological risk, and land use.
- Ensure that all variances undergo Tribal consultation and ecological review.
- Provide outreach using plain-language materials and host workshops in collaboration with Tribes and
local groups.
Recommendation
We respectfully urge Jefferson County to:
- Integrate SPTH-based buffer requirements into the Critical Area Ordinance for all fish-bearing and
seasonal streams;
- Use SPTH to revise buffer widths based on local ecological data and site-specific tree potential;
- Require that all variances trigger Tribal consultation;
- Implement equity-centered compliance tools including technical assistance and funding access.
Closing
SPTH is not only sound science—it is an act of intergovernmental respect and environmental
responsibility. This is Jefferson County’s opportunity to protect future generations, uphold treaty-reserved
rights, and lead with care.
Sincerely,
Engage JC