The Sierra Club and Futurewise weigh in on Kitsap County SMP

The Sierra Club and Futurewise have submitted a comment letter to the county planning commission on the SMP. To these groups… ‘No Net Loss’ is actually code for ‘No Development’, new or old.

Singles out undeveloped properties and designates them as Natural with the most extensive restrictions.

“Since most jurisdictions have extensive areas of developed shorelines, it is critical to design the shoreline environments to protect the remaining ecological functions in the jurisdiction. This is accomplished by identifying the well-functioning areas and designating them with the Natural and Conservancy environments (or an equivalent), and equally importantly, by limiting uses in the Management Policies and use limits so these areas are not converted to higher intensity uses.” (page 6)

Declares Single family residences as non-water-dependent use

“non-water-dependent uses (including residences) that cause damage to the environment are non-preferred, and are supposed to be prohibited or discouraged.”(page 29)

General approach to use limits for Natural and Rural Conservancy

“For non-resource uses: all commercial, all industrial, all residential except single family, all boating facilities (multi-user facilities as defined in the SMP guidelines), and all recreation needing more than primitive facilities should be prohibited. Table entries for recreation should have more distinctions based on use intensity.”

“For resource uses: agriculture and aquaculture should be prohibited since they require extensive modification, forestry uses should be allowed, forest- based commercial/industrial should be prohibited, and mining uses should be prohibited.”

“For all modifications: structural modifications and significant alterations should be prohibited. Thus docks should not be allowed, but buoys should be; de minimus excavation and fill for foundations would be acceptable, but larger amounts should not be allowed ; non-structural stabilization could be allowed; minor trails are OK; etc.”

“Use limits for Rural Conservancy should be limited to low- intensity uses. Most commercial and industrial uses, regardless of water-dependency should be prohibited. If not, size and intensity limits must be included, as we have seen done elsewhere. Residential should be limited to single family, not multi -family.”

“When developing an undeveloped lot, the full width of the buffer needs to be functioning to avoid and minimize the new impacts.”

“Some structures (like marine railways and boating storage sheds) may be acceptable in Natural if the bulk of the modification is placed outside the buffer. Some structures (such as covered moorage and single user launch ramps) are dearly convenience facilities that have other alternatives that eliminate or minimize impacts. Covered moorage is prohibited in the text, and should say so in the table. Single user launch ramps should be prohibited too.” (page 12)

Buffers and Vegetation Management

“One of the main ways impacts can be avoided and minimized is by having intact science based buffers. The problem is the apparent assumption that meeting a buffer width regardless of the buffer condition means that there are no impacts from the development.”

“Almost all development has impacts, even development outside the buffer. And a buffer that is degraded cannot actually perform buffering functions, so the impacts will be greater.” (page 26)

“First, option B is written to allow protection of existing out-of-buffer vegetation as mitigation for degrading in-buffer vegetation. Keeping intact vegetation should be a default standard, not an excuse to degrade near-water vegetation. We recommend this provision be eliminated.”(page 27)

Compensatory Mitigation for Shore Armoring lmpacts

“… recommend that sediment enhancement should be a requirement for all stabilization to address changes in sediment transport, and recommend that structure removal be accompanied by slope, soil, and vegetation enhancement.” (page 27)

Compensatory Mitigation for lmpervious Surface Impacts

“installation of a deck and rain garden should not be used to reduce compensation for removal of vegetation.” (page 27)

“When developing an undeveloped lot, the full width of the buffer needs to be functioning to avoid and minimize the new impacts.” (page 28)

“Storage at the waterline is a convenience that has alternatives that cause less damage. Walking a few extra steps or running the marine railway or boat ramp a little further to place these storage sheds outside the buffer is not a hardship.” (page 28)

“Buffer modifications for views should only be allowed when maintaining existing views. We recommend this section be limited to only existing views, and for creating view that does not remove vegetation from the buffer.” (page 29)

“Sediment impacts of stabilization continue over time. Sediment supplementation should be required for all stabilization, including establishing a formal easement and agreement with resource agencies to continue the practice over time.” (page 29)

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