What Does “No Net Loss” Mean?

Testimony of Chuck Shank for the Public Hearing 23 May 2011 Kitsap County Shoreline Inventory and Characterization Report

May 27, 2011

Dear County Commissioners,

What precisely does the catch phrase “no net loss” mean?

It’s very important that we the public get clear definitions of the words and phrases being used during the public participation phase of the SMP update.

I am very concerned that the “no net loss” phrase is being used to mean something, but have no clear definition of what that is, and decisions are being made based upon the SMP panel’s collective understanding of this phrase.

I am concerned because the phrase is leaving out what it is referring to – the rest of the phrase – “of ecological function”.  

The correct phrase is “no net loss of ecological function”.

Possibly the “ecological function” part is left off because it’s redundant or irrelevant to everyone’s understanding, but I believe it’s being dropped because of the “eyes glazing over” syndrome.

Please take a few moments to look up on line or in University level texts, what “ecological function” really means.  I think it will help you understand the very complex process you’ve undertaken to inventory and characterize the shoreline of Kitsap County.

Ecological function of the shoreline is everything physically, chemically and biologically occurring in every selected inventory area all the time day and night.

This means everything  – such as seasons, sunshine, rainfall, tidal cycles, air pressure, air temperature, water temperature, water column salinity, pelagic species, benthic species, algal growth, trace elements, the carbonic acid cycle balance, and on and on.

In other words, an inventory of ecological function has never been baselined for every unique stretch of shoreline from the quiet coves and mudflats to the exposed rocky, wave-beaten shores.

It would take an army of PhD’s with assistants to do such a task.

To assert that “no net loss” of ecological function is the criterion without establishing measurable and monitorable baseline parameters of biological, physical, and chemical characteristics of each and every reach area is wishful thinking at best, and unimplementable at worst.

There by establishing the real credibility of this endeavor.

In other words, “no net loss” is a measured mathematical result of ecological function before and after an event – per your interest which appears to be only man-made habitat’s ecological function.

Let me suggest one more time, that you would be far better served in your quest to preserve our shoreline environment if you would instead choose to define shoreline inventory and characterization reaches according to “indicator species”.

Each particular ecological niche will have an organism that is characteristic of a healthy environmental situation, and of times of an unhealthy situation.  And it’s not ‘salmon” an   anadromous species.

It would be far easier to use indicator species in reach areas to define their baseline characteristics in order to track harmful change due to habitat alteration over time.

It would also be possible to define what habitat alteration caused the problem, if one is found – such as feeder bluff slumps which completely cover up and destroy thriving benthic communities, and consequently their predatory pelagic counterparts.

However, if you are intent on determining “no net loss to ecological function” then you must develop a set of measurable parameters within each of the biological, chemical and physical regimes so that you can determine if there in fact is a net loss, gain, or no change over time in every reach shown in the inventory.

Or, you could just go on doing what this process suggests and change the phrase from “no net loss of ecological function” to one more palatable in order to just continue what DOE requires of you, such as “no net loss”.

I am very disappointed in this SMP update process up to now, and will continue to be disappointed unless you take control of the effort and make it credible.

sincerely,

Chuck Shank

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