The following was submitted by the Friends of the San Juans.

On Dec. 22, the Friends of the San Juans appealed San Juan County’s recently updated Shoreline Master Program to the Washington Growth Management Hearings Board. The SMP is the primary tool for protecting the fragile marine ecosystem that depends on the health of that narrow band of shoreline where the water meets the land. In October, San Juan County and the Washington Department of Ecology rejected requests by many public commenters and adopted an SMP that Friends believes rolls back important protections for natural beach building, fish spawning beaches, and shoreline views.

Of greatest concern to the Friends are the likely indirect impacts that occur on the dwindling population of Southern Resident Killer Whales (“orca”) who frequent San Juan Islands waters every summer in search of their favorite food, Chinook salmon. The population has plummeted to 76 members and could fall still further if nothing is done to counteract their decline. Particularly worrisome are adverse impacts to our forage fish spawning beaches and the threatened juvenile Chinook salmon that rear along our shorelines— and by extension to endangered orca higher up the food chain.

“Our county has said that protecting orca and helping recover Chinook salmon is a priority, yet this SMP failed to designate protections for the vast majority of forage fish spawning beaches and the bluffs that supply sand to many of those beaches,” stated Friends of the San Juans Executive Director, Stephanie Buffum. “And it went a step further and removed clauses that prevented development that disturbed spawning areas and bulkheading that would seriously disrupt the creation of beaches from bluff erosion. The SMP essentially ignored the past 20 years of science that located important areas and identified the types of development that impact them the most. We have to get this right, our orcas depend on the San Juans,” added Buffum.

“Decisionmakers will reassure the public that a ‘no-net-loss’ provision will cure new development impacts,” according to Friends’ staff attorney, Kyle Loring. “But in practice, no-net-loss is an experiment where we cause new harm and try to offset it with unproven rehab efforts. The scientific literature criticizes such ‘biodiversity trading’ schemes in complex ecosystems like our shorelines because they don’t work.”

“There isn’t a single issue in our appeal that will come as a surprise,” said Tina Whitman, Science Director of Friends. “Since 2011, Friends of the San Juans and other concerned groups and citizens have been providing detailed comments about the failure of designations to protect the most important places: the ten miles of forage fish spawning beaches, the 30 miles of bluffs that create and feed our beaches.” The reason we update the SMP is to incorporate new information and make sure our policies reflect community values. “This effort failed on both counts,” Whitman concluded. “This community wants improved protections for salmon and orcas.”

“We have worked tirelessly for over 6 years to avoid having to appeal, but unfortunately, the new SMP just fails our community in too many ways and it sets the stage of the next twenty years of development along our shorelines,” stated Friends’ Board President San Olson. “The whales just don’t have that kind of time left.”