Testimony of Alan R Beam at the Public Hearing 23 May 2011 Kitsap County Shoreline Inventory and Characterization Report.
The stated purpose of the Shoreline Inventory and Characterization Report is to compile existing data in the Shoreline jurisdiction, describe ecosystem wide processes and functions, and identify current shoreline conditions. This then becomes the baseline for determining “no net loss” of ecological conditions. The INC fails to achieve these goals in many ways.
The INC does not define or enumerate the ecological functions that are to be managed for “No net loss”. In particular, biological processes are not addressed; stating that: “On this basis, the nearshore assessment evaluates stressors to the controlling factors and physical processes as a proxy for ecosystem degradation”
The INC does not address the real stressors to the shoreline ecosystem, and place them in priority. The Washington State Department of Ecology identified surface runoff as the most significant contributor of toxic chemicals to Puget Sound. (Toxics in Surface Runoff to Puget Sound: Phase 3 Data and Load Estimates, May 2011, http://www.ecy.wa.gov/pubs/1103010.pdf) Shoreline property owners of the first 200 feet of land have only minor impact on storm water runoff and its effects .
For many of the shoreline species the inventory only provides sketchy generalizations such as patchy eel grass. There has been no attempt to quantify or discuss such high interest items as clams, mussels, oysters, geoducks and crab. This is insufficient as a baseline measurement to establish a monitoring system to determine no net loss.
The Drift Cells and NAUs are characterized and managed by amount of disturbance. In general the amount of disturbance is quantified by percent armoring of the shoreline. The Puget Sound Partnership Science panel states that bulkhead armoring “May be a good indicator, although there is not a lot of science concerning how this affects biota (i.e. difficult to determine whether it responds predictably to ecosystem attributes). Also difficult to determine thresholds – how much armoring in an area is bad? Easily measured, and cumulative effects important especially in the context of other shoreline stressors.” PSP Puget Sound Science update May 2011 188.8.131.52 Interface habitat indicator evaluation ( Page 22). The exclusive use of bulkhead armoring as an numeric indicator places a great percentage of the Kitsap shoreline as highly disturbed, making prioritization of restoration efforts impossible.
The Buffers and Setbacks paragraph was dropped into the INC without discussion or scientific justification. This issue is of great concern to shoreline property owners and merits consideration in the SMP process, rather than the blanket application of the flawed Critical Areas Ordinance buffers. “Critical area buffers option: Local governments may extend the shoreline jurisdiction to include “land necessary for buffers for critical areas that occur within shorelines of the state. (RCW 36.70A and RCW 90.58.030(2) (f) (ii)”. This option applies to critical areas that lie partly in and partly out of the shoreline jurisdiction. Kitsap County staff recommends that the SMP jurisdiction remain at the required minimum and that the CAO buffer requirements for the outlying areas be maintained in order to consistently continue to protect the critical areas pursuant to Kitsap County Title 19.” Section 2 Background page 26.
The final draft Inventory and Characterization Report is insufficient and does not support the establishment of a credible baseline to determine “no net loss of ecological function”.