For me, a pattern seems to be emerging that divides the waters between two fundamentally different types of environmentalists. That is, either you believe in de minimis or you don't. The cornerstone of the US strategy for environmental protection has been to quantify excess human health and ecological risk, and then to take measures to reduce that risk. An integral aspect of that approach is the notion of de minimis risk, which is risk so low that it is below regulatory concern. Quite literally, it is a pointless waste to insist on measures to reduce de minimis risk even further. However, if you don't believe in de minimis, then you think that all human activity must be regulated.
This would appear to be the approach of most in the planning profession, and accordingly, it appears to be the prevailing view among the planning-dominated mentality of our state and local government as well as the Friends. Without the notion of de minimis, you don't need any proof that human activity causes harm, you just believe it anyway.
That's virtually the mantra of CDPD and cohorts. It's also the view of many on the Planning Commission, who voted to restrict ALL activities in buffers except for a select few activities they vouchsafe us. "They" believe everything is harmful, unless "they" sanctify it.
This blog has addressed risk and de minimis in earlier postings. It is a central tenet of environmental protection, and if you don't believe in de minimis, you aren't really engaging in rational environmental protection.
_________________________________________________________
April 30, 2012
San Juan County Council
San Juan County Planning
Commission
San Juan County Community
Development and Planning Department
COMMENTS ON THE PROPOSED CAO SHORELINE
RESTRICTIONS
My concerns are centered on
the possibility that our home and the existing property features may be
designated non-conforming going forward within the proposed CAO Shoreline
Management Plan. As ordinary law
abiding owners / tax paying citizens of the county we are not equipped nor
should we rationally be expected to have a complete understanding and working
knowledge of the 300+ page Inventory and Characterization Report (plus maps and
appendices), or the potential impact imposed upon our specific property by the
proposals being considered. In our
opinion, the county has done a woeful job of communicating the specifics,
basis, true motivation, and full ramifications of the changes being
considered. The property tax bill
enclosure provided only direction to some documents available for viewing
online, none of which included a draft of changes to development standards, parcel
specific information for each owner to relate to, nor an indication that owners
may be required to take action to protect their rights or inform the county of
the as is condition of their property.
Granted, communication with
property owners is difficult and costly.
An added challenge in San Juan County is the high number of absentee /
part time resident owners. However,
these parties are equally impacted by changes in standards, if not more so in
the case of vacant land owners hoping to build retirement homes in the coming
years. This being the case, it
seems unfair and highly unwise for county officials to proceed with adoption of
any code document calling for sweeping changes in development standards,
requirements, and classification of land and existing structures prior to
making an exhaustive effort to advise each property owner as to the specific
information on file for their parcel and the impact to their property by the
proposed code changes.
In addition, as far as we
have seen, there has been no truly objective local study of best available
science in the San Juan Islands.
In truth, any such study is highly subject to bias by the personal
beliefs and motivations of the scientists and/or the funding source driving
said reports. We also question
purported scientific proof that doubling or tripling future development
setbacks will significantly alter the effects of development on the
environment. These issues combined
with the unavoidable bias of planners drafting the proposals, and counsel
members directing and adopting the development standards, dramatically speaking,
the county and public is presented with a cauldron of venomous snakes poised to
strike.
For ourselves, what we do
know is that we have followed the current development guidelines and standards
completely. We have endeavored to
do no harm to the physical condition of the environment in which we are
privileged to live. Having done
so, we are greatly concerned about and object to the county imposing any
regulation that will classify our property at any point in the future as
non-conforming by subsequent changes in regulations. In spite of what anyone may say to convince you otherwise,
from my professional experience, I can advise with near absolute certainty that
among the future consequences of your actions will be an exponential increase
in the hostility of your constituents, a decrease in future property tax
revenue potential spanning for much more than a decade, and a long term legacy
of increase in cost of litigation for the county over development issues. Clearly, your decisions on this issue
will have direct and indirect long term effects upon all property owners within
the county and services it is able to provide, proponents and detractors
alike. The course of action being pursed
on this matter appears drastic. In
the interest of mitigating the potential negative outcomes from the development
code review in process, I encourage you to endorse the absolute minimum and
necessary revisions of the existing code.
Respectfully submitted,
Harlow Cameron
Eastsound
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