This Thursday, at 7 PM in the City Hall Council Chamber, the City Planning Commission meeting includes a public hearing on a proposal to amend the city Shoreline Master Program (SMP).  http://www.cob.org/government/public/boards-commissions/planning-materials.aspx.  Please note that this is scheduled as the second public hearing of the evening.  (It is a favored tactic to place the most controversial hearing last, discouraging the public from sticking around and speaking.)

This proposal will change the shoreline environment designation at the log pond and Cornwall Landfill and beach from “waterfront recreational use” to “waterfront mixed use” (industrial and commercial development).  This will amend the shoreline development standards to increase building heights, decrease the shoreline buffer, and to allow stand-alone non-water oriented uses.  These changes increase development and boat traffic without protecting aquatic and shoreline wildlife, or our marine industry.

Please show up and object to this proposal.  Talking points are listed below.

• This proposal will increase the type and the intensity of shoreline use, development and boat traffic in an area that contains federal ESA (Endangered Species Act) fish and wildlife, and state priority habitat and species.   
• The Cornwall Landfill and beach, and the log pond are adjacent to areas determined to be of sensitive and vulnerable habitat for seabirds, seals, and other forms of aquatic life as reflected in the SMP shoreline assessment.  
• We must protect biodiversity.  Any amendment to the city shoreline regulations should include requirements to replace the habitat that will be lost from increased intensity of use (“compensatory mitigation”).  We can not keep losing precious shoreline and aquatic habitat.
• Development must comply with local shoreline regulations.  This is a requirement of the Shoreline Management Act (SMA), enacted pursuant to a people’s initiative. The purpose and intent of shoreline regulations are undermined when amended to accommodate land use development plans.  This is contrary to the public’s intent under state and local law.
• These changes are in response to a letter from Department of Ecology (DOE) advising of conflicts between the waterfront district plan and the SMP.  DOE expected the city to revise the waterfront district plans, noting that “it would be appropriate to alter the waterfront district plans for consistency with the SMP.” The city is doing the reverse by making the SMP consistent with waterfront district development.  
• The SMP was only updated in January of this year, after a great deal of work and effort, which included analysis to determine the amount of shoreline use and development that could occur and still protect the ecological functions of the shoreline. This was reflected in the shoreline environment designations, which the staff is now trying to change. This does not comply with best available science.
• Accommodations were made in the Waterfront District provisions of the SMP to provide a great deal of flexibility to the city in its future planning efforts.  The city is now attempting to go beyond the scope of anything contemplated by either the public or the Department of Ecology when the SMP was enacted. 
• Under local law, the staff must establish a legitimate purpose for SMP amendments and has failed to do so.  Wanting more shoreline development than is permitted under shoreline regulations is not a legitimate purpose.
• Non-water oriented uses should not be allowed within the shoreline jurisdiction. Shorelines are a limited resource and uses should reflect state and local priorities for environmental restoration, habitat, public access and marine industrial and commercial use. 
• This proposal is premature.  We should not be modifying SMP shoreline regulations for a waterfront proposal that is still a draft.  There is no rush.