Concerns expressed about Port Angeles Shoreline Master Program

from Kaj Ahlburg,
Port Angeles, WA

March 15, 2011

Port Angeles, WA - From attending a number of public meetings regarding the County and City Shoreline Master Program (SMP) updates, it seems quite clear to me that, while there may be isolated problems with enforcing existing rules, no major problems exist with regard to the current SMP requiring sweeping new rules. Please do not attempt to fix what is not broken.

Having reviewed several of the Department of Ecology (DoE) publications on Shoreline Master Plans and the City Master Shoreline Program draft, I am most concerned with regard to the following issues.

First, there is a new concept called “no net loss of ecological function”. We need a rigorous definition of this concept that would allow an objective determination whether a proposed action by a landowner complies with this requirement or not. It is of paramount importance that implementation of this new requirement does not lead to “net loss of economic function” for the City and its citizens. It also is important to ensure that DoE can not use a vaguely defined term as a hammer to get landowners to do in each case whatever unelected government officials subjectively deem “best for the environment”, without clear standards known in advance. Uncertainty can be fatal to economic development. There is enough uncertainty relating to archeological resources overhanging any development on the City waterfront. We do not need to further add to it.

Second, all DoE publications on the subject are suffused with a strong hostility toward hard shoreline armoring. The nature of our shoreline is such that without hard armoring we would lose use of the Olympic Discovery trail in the first winter, and certain homes on top of bluffs would go not very long afterwards. Loss of the ability to properly maintain such armoring inside the harbor area could also prove very detrimental to the economic activities of the Port of Port Angeles. We must preserve the ability to maintain, and where necessary upgrade, hard armoring to protect existing public and private improvements and property rights.

Third, I see that the current City Master Shoreline Program draft still has a blank on p.19 for the section that will govern the site of the former Rayonier property. Given the importance of this site, once cleaned up, for the economy, jobs and tax base of the City, it is of great importance that the SMP not establish today’s undeveloped, “wild” condition of the property, but rather the pre-1997 condition of the property, as a baseline against which “no net loss of ecological function” will be measured. Otherwise, even if the site should get cleaned up in the future, there is a risk that the SMP could make it harder or impossible for economic activity to occur on it, be it light industrial activity, the Jamestown S’Klallam Salish Village concept, or any other productive use. Given the crucial nature of the Rayonier site and this provision of the SMP there has to be adequate time for the public to review and comment on this section after it is made publicly available. The public comment period should be extended, at least with respect to this section.

Fourth, you also need to make sure that any requirements imposed by Section 3.B.2 with regard to archeological resources do not impose further obstacles, beyond those existing by virtue of existing laws and regulations, on waterfront development. We saw in connection with the Graving Yard and Harbor-Works the burdens and obstacles existing laws and regulations relating to archeological resources impose on economic activity and development on the Port Angeles waterfront, arguably the City’s most significant natural resource. We must ensure that we do not add to these burdens.

I ask that you carefully balance ecological concerns with economic considerations. I also respectfully request that, as the SMP process moves forward, you continue to provide ample and timely opportunity for the public’s views to be expressed and heard at a time when such views can influence the outcome, and ensure that the public be given frequent real time information as to the input DoE is providing into the process.

Thank you for your consideration.

Kaj Ahlburg

Port Angeles


The draft program of the Port Angeles Shoreline Master Program (SMP) can be found at . The DoE website is at . The City currently states that it will accept comments only until April 1, 2011.)