Green Tree Alert

GreenTree Alert #9 (5/12/99)
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State Rules to Protect Shorelines and Streamsides Out for Public Review
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Do you enjoy Washington's lakes, rivers, streams and 
coastlines? Your voice is needed to protect our shorelines.
One of the reasons we still have quality shorelines in Washington is due to 
the state's Shoreline Management Act (SMA). After 27 years, the 
Department of Ecology will be updating the SMA state guidelines which 
determine how more than 250 city and counties manage these sensitive 
areas through local shoreline master programs. This SMA guideline 
update is a key element of the state's response to the listing of wild 
salmon under the Endangered Species Act and will play an important role 
in the state's efforts to comply with the federal Clean Water Act.  
Four public hearings will be held in May on Ecology's draft rule. 
Attendance at the hearing will be crucial to show strong support for 
updating the rules and protecting our shorelines.
Ellensburg (Hal Homes Community Center, 201 N. Ruby)
Wednesday, May 19, 7:00 PM
Spokane (Public Health Center, W. 1101 College, Room 140)
Thursday, May 20, 7:00 PM
Olympia/Lacey (Ecology Headquarters, 300 Desmond Drive, Auditorium)
Tuesday, May 25, 7:30 PM
Seattle (Mountaineers, 300 Third Ave. W., Tahoma Room #2)
Wednesday, May 26, 7:00 PM
BACKGROUND:
A full copy of the proposed rule is available at Ecology's website:
www.wa.ecy.wa.gov/ (then click on Shorelines and Wetlands)
Also, written comments can be received until June 21, 1999. WEC will 
post detailed comments to its website (www.greenwec.org) as soon as 
possible. In the meantime, following are some general observations 
compiled by the environmental community and the League of Women 
Voters.
General Observations of the draft Rule
Ecology doesn't expect everyone to know all the particulars and 
implications of the draft rule. Here are some basic observations that you 
can relate in conjunction with your local knowledge and experience with 
shoreline and streamside management.
1) Thank the Shorelines Commission and Ecology for updating new 
guidelines for protecting shorelines and critical areas. It is encouraging 
and important that the update is happening. Twenty-seven years is too 
long a period to improve shoreline and streamside management.
2) Overall, the draft rule improves the policies which local governments 
must abide by to protect shorelines and other critical areas. Improvements 
of the draft rule include the following: 
Encourages both visual and physical public access to shorelines, 
emphasizing public rights under the Public Trust Doctrine. For example, 
there is a requirement that public entities must include public access 
provisions in their shoreline developments.
Directs that local shoreline and critical areas guidelines be based on best 
available science - a fundamental principal if we are to recover wild 
salmon and restore water quality.
Places new restrictions on bulkheads and other "hard" shoreline armoring 
that, if enforced, can contribute to the salmon recovery. One of the 
greatest challenges of salmon recovery is addressing the cumulative 
impact of hundreds/thousands of actions. Salmon are dying the death of a 
thousand cuts, and restrictions on every-day projects, such as bulkheads, 
will be necessary if we hope to recover them.
3) Despite general improvements, there are some significant concerns 
about the draft rule that could undermine potential benefits. Deficiencies 
of the draft rule include the following:
Lacks clear, minimum standards that would provide certainty for the 
ecological health of shorelines and critical areas. The existing narrative 
standards will be difficult to enforce. Minimum state standards would 
provide more clarity for local governments and business and ensure better 
environmental protection.
Relies on a "net gain" approach to wetland and watershed mitigation. 
While the concept sounds good, this appears to allow for habitat 
degradation in one area provided it is made up or compensated for 
someplace else. The net gain concept should be applied within a project 
context to ensure accountability and effectiveness of mitigation efforts.
Lacks strong monitoring requirements and inventory protocols. The draft 
rule constantly makes reference to preserving ecological functions, 
adaptive management, and best available science to guide decision 
making. In order to achieve these objectives, however, there needs to be a 
good baseline inventory and on-going monitoring - provisions that are 
required but not well defined. Monitoring and inventory protocols should 
be better articulated to ensure that they actually work.
Allows for varying levels of enforcement. All shorelines deserve the same 
level of strong regulation and enforcement.
Allows lower standards for urban areas. Aside from being without 
scientific merit, it is areas within urban growth boundaries that are at 
greatest risk from degradation. We need to save what we have left and do 
no harm to existing habitat if we hope to recover salmon.
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Tom Geiger
Outreach Director, WEC
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