Clallam shoreline plan needs to consider climate change more seriously

At today’s hearing on Clallam County’s Draft Shoreline Master Program (September 2017, Ed Chadd submitted the following comments on behalf of OCA, urging greater consideration of climate change in shoreline planning in order to protect both the public and County government (news article here):

I am here representing Olympic Climate Action, a group of local citizens dedicated to researching, educating, and acting on the issue of climate change, with a distinctly local focus. We have a mailing list of more than 700, and our monthly meetings consistently draw 15-20 Clallam County residents concerned about climate change education, adaptation, and mitigation.  These comments on the County’s draft Shoreline Master Program reflect the consensus of our group, developed at these monthly meetings over the course of more than two years.

We believe one goal of the SMP should be to inform Clallam County residents of potential climate change impacts.  In a prior draft, Goal #13 was “To protect people and property from adverse impacts related to climate change and to promote resiliency in responding to climate change impacts.” We note with concern that this goal has been removed from the current draft, and we would like a clearly-stated reason as to why.

We note that FEMA recently acknowledged that the current floodplain insurance rate mapping project is not utilizing recent research findings related to storm surge.  While the mapping is supposed to be correcting out-of-date floodplain maps, FEMA admits these updates will still not be current. 

Any coherent long-range plan for management of our shorelines would necessarily want to acknowledge increasingly-likely impacts from sea level rise and storm surge, and to forewarn current and future residents of the potential for property damage.  The potential for impacts TO the environment FROM property damage is also a concern for many of us. 

In Clallam County, sea level is expected to rise by over half a foot within 30 years and could rise more than 4 feet by 2100, with slight differences depending on which end of the County you’re talking about.  Specific details about these projections are available in the Climate Preparedness Plan for the North Olympic Peninsula, originally published in 2015 by a consortium of local governments, NGOs, businesses, and citizens, including Clallam County, and more recently updated for the sea-level rise maps.

Given the existence of good studies focused on local shoreline sensitivities and impacts from global warming, the County’s SMP could be considered negligent if current projections aren’t integrated, or at the very least, acknowledged as a concern.

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.

Olympic Climate Action has submitted comments on two prior drafts of the SMP, and we are concerned not to see evidence in many cases that our comments were incorporated or even considered.  We would appreciate an acknowledgment of and response to our current and prior comments.

Thank you for your consideration.