Testimony to BOCC Concerning Shoreline Planning

by Bob Benze, Environmental Engineer

As you know, Kitsap County is beginning the process to update their portion of the state’s Shoreline Master Plan in accordance with Chapter 173.26 of the Washington Administrative Code.  Among other things, this requires an inventory of shoreline features and the conduct of studies to assess the impact of man-caused features on the nearshore ecosystem.  The goal is to ensure that future development will not cause a net loss of ecological function of the shoreline. 

The county plans to use an Oregon State University “Alternative Futures” model as a “decision support tool for the SMP update”.  I will comment on the wisdom of this approach at some future time.  But the important thing to note this evening is that a nearshore assessment remains the key element of the proposed shoreline planning process, as mandated by the WAC.  Kitsap County has had a contractor prepare such an assessment for the eastern part of the county titled East Kitsap County Nearshore Habitat Assessment and Restoration Prioritization Framework.  Regrettably, I need to tell you that this assessment is fatally flawed.

You have received a copy of a report written by Dr. Donald Flora titled Evidence of Near-Zero Habitat Harm from Nearshore Development.  Dr. Flora, in a very straightforward manner, has shown that the data in the East Kitsap nearshore assessment does not show any meaningful relationship between man-caused alterations of the shoreline and the ecosystem functions of the nearshore environment –- despite the report’s authors’ contention that it does so.

This is not a dispute of opinions between one scientist and other scientists.  It is simply a straightforward statistical analysis of the report’s own data that shows virtually no correlation between the supposed shoreline stressors and the observed condition of the nearshore habitat.  This result can be easily replicated by anyone with basic competence in statistical analysis –- something that should have been done as part of the contractor’s own due diligence -– but wasn’t.  They were apparently so sure of the outcome that they wrote their findings without rigorously analyzing their own data. 

This would be of only minor concern if it were one of the hundreds of studies of environmental phenomena accomplished by academia each year.  But it isn’t.  It will be used to determine the destiny of about two billion dollars worth of private shoreline property owned by citizens of this county.  The stakes are high. 

The government, under pressure from environmental organizations, is seeking to put large buffer zones in-place along shorelines –- 150 ft. or more -– with the long term goal of the Department of Ecology of eventually eliminating non-conforming structures and uses in these buffer zones (see Dept. of Ecology presentation).  They assumed they had the science to support these actions.  Now we see that a reputable scientific organization has collected data that says quite the opposite. 

I would suggest that our county officials take Dr. Flora’s report seriously  Have it independently reviewed.  Then take appropriate actions to base the county’s shoreline planning on the real scientific evidence. There is too much hanging in the balance to do otherwise.

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