Call for comments on the Thurston County Shoreline Master Program (SMP)

Call for comments on the Thurston County Shoreline Master Program (SMP)

Dear Auduboners willing to help protect our shorelines,

Can you comment on the proposed revisions in the Thurston County Shoreline Master Program (SMP)?  We want to strengthen, not loosen, protections for our shorelines.

Here are examples of a short template letter and a long template letter to the Thurston County Board of County Commissioners that you can modify, especially if you can add personal information. Use any part of these templates to form your own short letter(s) (officials read short letters more often than long).

Send to: smp@nullco.thurston.wa.us:

Audubon Conservation member Anne Van Sweringen, representing Black Hills Audubon and four other local environmental organizations, has submitted extensive comments to the BoCC on this proposal revision.  We need supporting letters from our members and others.

The proposed revisions will be presented at a meeting of the Board of County Commissioners (Sept. 12, 3:30 – 4:00 p.m., Thurston Ct. Courthouse, Bldg. 1, Rm 28.)  See further details.

Can you attend?  We want a show of support for strengthening, not loosening, protections of our shorelines.

Thank you!
Black Hills Audubon Conservation Committee

 

Sample of short letter:

 The Honorable John Hutchings, Gary Edwards, Bud Blake

Commissioner Districts 1, 2, 3 respectively

Thurston County Board of County Commissioners

Dear Commissioner Hutchings, Edwards, and Blake:

My name is [first, last], and I am a Thurston County citizen and member of Black Hills Audubon Society. I am writing to urge you to consider these comments for the Thurston County Draft Shoreline Master Program 7.2018 Update (SMP).

I am concerned about the county’s trend of converting shoreline to other uses.

The SMP guidelines (WAC 173-26-186(8)) provide for development standards and use regulations designed to achieve no net loss of shoreline ecological functions, which is necessary to sustain a shoreline’s environment; management of shoreline aquatic systems is critical for the health and safety of the public. Shoreline buffers provide many benefits for water bodies, including protecting habitat and water quality.

I specifically request you consider and support the following:

  • Buffers – Do not allow standard SMP buffer widths or setbacks to be modified or reduced; not for Shoreline Environmental Designations, vegetation conservation, or other areas.
  • Mitigation – Encourage long-term net gains in both programmatic (planning-level decisions) and project (site-specific design detail) bases, particularly when conducting mitigation sequencing (avoiding, then minimizing, finally compensating for impacts). Require compensatory mitigation to occur in the same, or a related, habitat area for gain in the same ecological functions and ecosystem-wide processes.
  • Aquaculture – Aquaculture’s use of shorelines must be consistent with the regulations of the Shoreline Management Act, the shoreline master program, and Best Available Science. A water-dependent use, aquaculture is polluting western coastlines, sounds, and estuaries with plasThe use of plastic by the aquaculture industry is pervasive, and will increase with industry expansion. Geoduck aquaculture mitigation practices, when based on Best Available Science, are known to reduce risks to birds and other wildlife. Use mitigation practices to reduce these and other risks.

I urge you to take the necessary steps to protect the county’s natural resources and habitats, so the marine and freshwater shorelines and shorelands of our county will flourish into the future.

 

Sincerely,

[Your name]

Sample of long letter:

The Honorable John Hutchings, Gary Edwards, Bud Blake

Commissioner Districts 1, 2, 3 respectively

Thurston County Board of County Commissioners

Dear Commissioner Hutchings, Edwards, and Blake:

My name is [first, last], and I am a Thurston County citizen and member of Black Hills Audubon Society. I am writing to urge you to consider these comments for the Thurston County Draft Shoreline Master Program 7.2018 Update (SMP).

Thurston County’s shoreline master program is conducting an update process pursuant to the requirements of Washington’s Shoreline Management Act of 1971 (SMA). The main tenet of the SMA includes “protecting against adverse effects to the public health, the land and its vegetation and wildlife, and the waters of the state and their aquatic life.” I am concerned about the county’s trend of converting shoreline, including marine, estuarine, freshwater and shoreland ecosystems and functions, to other uses.

As the SMA states, the SMP must not allow expansion, redevelopment, or replacement of existing structures, or development or new land alterations, that result in a net loss of shoreline ecological functions. Both protection and restoration are needed to achieve no net loss. Mitigation is critical to offset ecological impacts from development.

The SMP guidelines (WAC 173-26-186(8)) provide for development standards and use regulations designed to achieve no net loss of shoreline ecological functions. No net loss is necessary to sustain a shoreline’s overall marine, estuarine, and freshwater aquatic environments. Environmental management of shoreline aquatic systems is critical for the health and safety of the public. The intention of the SMP is to protect the functions shoreline vegetation provides. Shoreline buffers provide many benefits for water bodies, including protecting habitat and water quality.

I advocate for sustainable densities and methods in shoreline uses that ensure no net loss of marine or freshwater ecological functions. I specifically request you consider and support the following:

  • Buffers – Do not allow standard SMP buffer widths or setbacks to be modified or reduced; not for Shoreline Environmental Designations, vegetation conservation, or other areas. Adequate buffer widths are the most straight-forward protection method available; buffer widths should be maximized to account for unforeseen effects.
  • Mitigation – Encourage long-term net gains in both programmatic (planning-level decisions) and project (site-specific design detail) bases, particularly when conducting mitigation sequencing (avoiding, then minimizing, finally compensating for impacts).

Mitigation conducted when buffer widths are reduced in size must result in a no net loss of environmental functions. Mitigation for development projects alone will not minimize adverse cumulative impacts to the shoreline environment, so restoration with a net gain in environmental functions is also required. Require compensatory mitigation to occur in the same, or a related, habitat area for gain in the same ecological functions and ecosystem-wide processes.

  • Aquaculture – Aquaculture’s use of shorelines must be consistent with the regulations of the Shoreline Management Act, the shoreline master program, and Best Available Science. A water-dependent use, aquaculture is polluting western coastlines, sounds, and estuaries with plasThe use of plastic by the aquaculture industry is pervasive, and will increase with industry expansion. Geoduck aquaculture mitigation practices, when based on Best Available Science, are known to reduce risks to birds and other wildlife. Use mitigation practices to reduce these and other risks:
  1. Change methods geoduck aquaculture uses during site preparation and harvesting that eliminate, or at least reduce, damage to benthic communities;
  2. Avoid plastics; encourage the use of non-toxic plastics;
  3. Limit changes (little or no scraping, dredging) in the benthic (ocean floor) community during geoduck site preparation and planting;
  4. Limit the use of predator control area netting to reduce the risk of birds being trapped;
  5. Prohibit the use of plastics in aquaculture. At a minimum, Non-toxic plastics; keep birds, fish, and wildlife from ingesting micro-plastics which, when ingested, cause starvation;
  6. Monitoring that includes a habitat assessment or biological baseline surveys to learn about potential and cumulative impacts of seed planting, bed maintenance and tube removal, harvesting and processing;
  7. Encourage the development of upland facilities for all types of aquaculture.
  • Mining – Thurston County should provide adequate access to mineral resources while limiting land use conflicts where mining could lead to environmental degradation, including diminished water quality and quantity.

The county should pass stringent mine reclamation and other rules that lower mining impacts. Protecting our aquifers should be the highest priority.

The county must provide adequate protection to ecological functions, processes, and shorelines against sediment and silt production when mining operations remove rock, sand, gravel, or minerals from shoreline and shoreland areas. Mining must not preclude public recreation of the public shoreline.

You are empowered with the authority and capacity to make a difference. I urge you to take the necessary steps to protect the county’s natural resources and habitats, so the marine and freshwater shorelines and shorelands of our county will flourish into the future.

Sincerely,

[Your name]