OCA Statement on draft Shoreline Master Program

On 7/5/17 OCA sent the following statement to the Clallam County Planning Commission concerning the Shoreline Master Program, updating our earlier comments on the previous draft of the SMP:

My name is Robert Vreeland.  I am a member of the executive committee with the Olympic Climate Action group which has more than 600 members in Clallam County.  We believe that one of the goals of the Shoreline Master Program (SMP) should be to inform Clallam County residents of potential climate change impacts.  This goal, pg. 1-18, was in an earlier draft but has been removed from the current draft.  The earlier draft Goal #13 stated “To protect people and property from adverse impacts related to climate change and to promote resiliency in responding to climate change impacts.”

At its recent meeting Olympic Climate Action agreed that in order to manage risk and liability, the County’s SMP should fully acknowledge the imminent potential for sea level rise.  Acknowledgement of climate change impact projections is particularly important to residents owning properties along low lying shorelines, Shoreline Residential – Intensive and Marine Waterfront Designations.  Some of these properties (e.g. 3 Crabs and Diamond Point) may be exposed to sea level rise and storm surge inundation by as early as 2030, based on projections in the Climate Change Preparedness Plan for the North Olympic Peninsula, Sept. 2015 (see http://www.noprcd.org/about2).  Given the existing technical studies and maps showing severe threats to dozens if not hundreds of low-elevation shoreline properties, often within 10-15 years, OCA believes County citizens could be financially liable for property losses to homeowners as well as home buyers if these risks aren’t clearly indicated in the most relevant County-wide planning document used to guide development and land use decisions.

The 2017 Draft SMP presently contains policies and a regulation regarding climate change and/or sea level rise and storm surge for: Restoration (pg. 3-32), Transportation (pg. 3-36), Buffers (pg. 6-1) and Regulations – General, 14 Shoreline stabilization (pg. 4-23).  We believe it is imperative that similar policies or regulations be incorporated for residential shoreline properties < 200 feet deep measured from the Ordinary High Water Mark (OHWM) landward, given these properties have the smallest buffers for Minor New Development, 50 feet.  It may be appropriate to have similar policies/regulations for Shoreline Residential – Intensive and Marine Waterfront, Minor New Development on lots > 200 feet deep (75-foot buffers), as well as Major New Development and Shoreline Residential – Conservancy Minor New Development < 200 feet deep (100-foot buffer), if these properties are low-lying and could be potentially subject to sea level rise and storm surge in the near future.

Furthermore, “hard” shoreline armoring such as rip rap and sea walls, even if mitigated, will impact the neighboring properties, coastal sedimentation system, and nearshore ecology, and these risks need to be acknowledged in the SMP.  At the Clallam County Planning Commission meeting of 6/21/17, the consultant for Clallam County on the SMP mentioned that there are approximately 83 parcels in the 3 Crabs and Diamond Point areas that could be permitted to install hard armoring to protect their properties.