19990715crcsma.html July 15, 1999logo prints here
July 15, 1999
Amy Johnson, Washington Department of Ecology
Shorelands and Environmental Assistance Program
PO Box 47600
Olympia, WA 98504
Proposed Amendments to "State Master Program Approval/Amendment Procedures and Shoreline Master Program Guidelines" (Chapter 173-26 WAC)
Dear Ms. Johnson:
Thank you for the opportunity to comment on the proposed Shoreline Master Program Guidelines. I am commenting on behalf of the board of trustees of the Chehalis River Council (CRC). The CRC is an all volunteer non-profit 501(c)(3) organization, dedicated to protecting water quality and quantity within the Chehalis watershed. We are completely local and grass-roots. We are not sponsored by any national environmental organization, and virtually all of our members live in Grays Harbor, Lewis, Mason or Thurston counties. Many of our members own property along one of the streams in the Chehalis Basin.
First we want to state our general support for the proposed guidelines. The Shorelines Management Act has provided a useful tool that permits cities and counties to adopt regulations to protect our water-related natural resources. The waters of the State of Washington belong to all of the citizens, and we all have a strong interest in seeing that they and their related shorelines are protected and enhanced. There are many benefits to protecting streams and shorelines - the farmer doesn't lose land to the river every year, the town or city doesn't have to treat the drinking water as much, the harbor will see less silt and buildup, the water storage provided will lessen downstream flooding. It is also very appropriate after 27 years to update the guidelines, given changes in population pressures and development and also in scientific understanding. The goal of integrating the Shorelines Master Program with the Growth Management Act is also valuable. Our current need to save the wild species of salmon also call for a revision of the rules. The proposed guidelines are excellent, given the complexity of the subject.
Shoreline Stabilization . The Chehalis River Council trustees wishes to express strong support for the new section on Shoreline modification activities (WAC 173-26-230). Although these new rules are strong, they will prevent further loss of our irreplaceable shorelines. They should also help prevent losses of property and even life from natural causes such as earthquakes, slides, floods, and wave erosion.
Vegetation Management Corridors and Agriculture . We understand the controversy surrounding the section of Vegetation Management (number 5, WAC 173-26-220). We have looked closely at the proposal, and we do not see the potential for a government land grab identified by other commentors. However, we recommend that Ecology do everything in its power to clarify that this section does not mandate buffers of a specific width or take 200 feet of shoreline away from any property holder.
Proposed section 5 (v), currently reads,
"For shorelands used for agricultural practices, restrict uses and activities that are not existing and ongoing agriculture sufficiently to ensure maintenance of ecological functions. Establish provisions that will contribute to vegetation enhancement where the shoreline has been ecologically degraded. If the land is converted to a more intense use, do not allow significant vegetation removal, clearing or development within the vegetation management corridor, except for low-intensity water-dependent uses and public access that sustains ecological functions."
We support this section, which amounts to an exemption for existing agricultural uses. One only needs to compare the degradation of urban streams with rural streams to see that family farms and rural property owners have in many cases done a fairly good job of protecting our waterways. Unfortunately, if we make it too hard for our farmers to continue farming, their land is likely to fall to development and housing subdivisions. The best way to preserve green belts for the cities and quality of life in the rural areas is to make it possible for farmers to keep farming.
The CRC is in favor of riparian vegetation areas and understands the value of "one site-potential tree height width" as a useful goal for optimum buffers. We believe that the best approach to achieving this as the standard vegetation corridor is a gradual one, where voluntary efforts predominate. A strict regulatory approach, in many cases, can only cause a backlash by property owners and perhaps the legislature against the whole concept.
Inventory of Shorelands Conditions . Section (c) (WAC 173-26-200) requires a comprehensive inventory of ecological conditions. Some local jurisdictions have pointed out that such an inventory is beyond the capabilities and resources available to them. The proposed guidelines state that "the preferred method for local governments to accomplish a detailed comprehensive inventory of ecological conditions is to participate in a inter-jurisdictional state-wide, regional, or watershed based inventory." The guidelines should be clearer that Watershed Assessments being prepared under SB 2514, the Watershed Management Act, can serve as the inventory, so long as the local jurisdiction has provided existing data to the Assessment at the level of detail specified in these guidelines. It would be helpful if the guidelines could state up-front that Watershed Assessments prepared under SB 2514 grants will suffice for the required inventory. Currently, plans are being made for Watershed Assessments, but planners may not recognize how helpful these assessments will be to local governments, and this interdependence should be highlighted in the guidelines.
To summarize our comments and concerns, we strongly support the concept of giving local governments the tools they need to protect our natural resources. This is what the Shorelands Management Act does. We support the increased consistency and stricter protections that will result when these guidelines are adopted and implemented. Strong measures must be taken to protect our shorelines and water quality for humans and for fish. To preserve our rural greenbelts, the guidelines should not put an undue burden on small farmers and landowners in rural areas. It's also important that these guidelines actually empower local governments and not make it more difficult for them to do their job.
Thank you also for scheduling additional hearings and extending the comment period so that more people can become educated about shorelines issues and comment on this proposal.
Sincerely,
Dave Palmer
for the Board of Trustees
Chehalis River Council
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19990715crcsma.html July 15, 1999logo prints here