No Net Loss of Obfuscation

While we're not done with the CAO, the SMP controversies are heating up. There was a technical workshop on Friday, with its accompanying talk of "no net loss".  What does the Shoreline Management Act actually say?

RCW 90.58.020 - Alterations of the natural condition of the shorelines of the state, in those limited instances when authorized, shall be given priority for single-family residences and their appurtenant structures, ports, shoreline recreational uses including but not limited to parks, marinas, piers, and other improvements facilitating public access to shorelines of the state, industrial and commercial developments which are particularly dependent on their location on or use of the shorelines of the state and other development that will provide an opportunity for substantial numbers of the people to enjoy the shorelines of the state.

In other words, in passing the SMA, the legislature found that we were to enjoy the shorelines, not be excluded from them. Also, single family residences were explicitly named as a use that is protected under SMA.

The SMA requirement is "no net loss of shoreline ecological function", not "no change of shorelines". The "no net loss" requirement of the SMP places added emphasis on those areas defined as critical under the CAO (WAC 365-190-030), which is why some in our community want to designate all the shorelines as critical. The CAO standard is "protection" of functions and values, but under the SMA, the standard is "no net loss" of function.

However, one of the major problems with the Shoreline I&C Report, from my perspective, is that the scoring system it uses is utterly inadequate for making determinations of critical areas under the GMA or SMA.