Comments on Jefferson County SMP Update

The SMA policy section (RCW 90.58.20) only requires that a SMP “minimize, insofar as practical, any resultant damage to the ecology and environment of the shoreline area”. Later on, in section 90.58.140, it is stated that projects with “significant irreversible damage to the environment” not be approved. So the Planning Commission recommended uses of the terminology “significant adverse effect” in Articles 7 & 8 are appropriate and the DCD recommended deletion of the word “significant” should have been rejected.

Also, there is absolutely nothing in RCW 90.58 that suggests that a “No Net Loss” policy is appropriate. The “No Net Loss” policy appears out of the blue and permeates the regulations and guidelines (WAC 173-26) spawned by the Department of Ecology and flows into the proposed SMP. That appears to be inappropriate and probably illegal.

RCW 90.58.100 requires that the contents of a SMP must be developed using a “systematic interdisciplinary approach” which includes economics. The costs caused by this SMP must be evaluated verses the potential environmental benefits.  Nowhere in this process has anyone been required to quantify the cost of these regulations to the county and to the property owners.

Going to the “Inventory and Characterization” report generated with DoE funds during the Jefferson County SMP development process, one would hope to find the rational/analysis that led to the recommended Shoreline Designations. We find that the report contains about 200 pages devoted to “characterization” descriptions in general and some application of these characterizations to individual shoreline spans or “reaches”. However, we find no analysis, even though one of the sections is titled “REACH INVENTORY AND ANALYSES”, nor any rational for the designations proscribed in this report. Further, the DCD representative handling the SMP process stated that the “Experts” developing the draft SMP “look at aerial photos to determine the appropriate characterizations”. Therefore, it appears all designations are suspect and in particular the 400% increase in Natural Designations. Finally, the so called science referenced by this report and the DCD is mostly inapplicable to Jefferson County and has not had serious peer review. And finally, there is no indication that the current Jefferson County regulations are not working.

Therefore it seems to me that the DoE must reject this proposed SMP and drop the requirement that No Net Loss be a criteria. Also DoE should  demand a cost benefit analysis and an evaluation the effectiveness of the current Jefferson County regulations before any changes are made to the Jefferson County shoreline regulations.