Letter to the EPA

Mr. Richard Parkin, Acting Director
Office of Ecosystems
United States Environmental Protection Agency, Region 10
1200 Sixth Avenue, Suite 900
Seattle, WA 98101-31140

Mr. Parkin,

The application and approval process for Funding Opportunity Number EPA-R10-PS-1001 (Watershed Stewardship Resource Center) has included numerous theoretical project plans, estimates, projections, and assumptions addressing how the Center might function in practical application. Three recent episodes during the past couple weeks might provide some insight into how accurately the WSRC project plan assumptions actually hold up when tested under real life circumstances.

On April 19th a local community association hosted a panel discussion on the Shoreline Master Program. Jill Silver, one of the main proponents behind the WRSC concept since 2006, was the primary speaker and her presentation was instructional on how the WRSC might resonate with the typical permit applicant the Center is designed to serve. I say typical because the audience consisted not of policy activists who have followed the SMP but who are just now, as the message below states, just "tuning in for the first time in this nearly 5-year process."

Ms. Silver's presentation consisted of a nearly one-hour treatise on the value and processes of shoreline ecological functions, described in numbing techno jargon-speak that went way over the audience's head. There is an art to communicating complicated, Greek-to-me concepts into terms the layperson can understand but this was pure "inside baseball." During questioning on the consequences of the new regulations it became apparent Ms. Silver was surprisingly uninformed on the actual content of the SMP, repeatedly saying she didn't have that information right in front of her. This is a common response for activists driven by environmental ideals rather than jurisdiction-specific public policy tailored for particular conditions, but hardly an asset for a public position that has been promoted as assisting applicants through the permit "maze." As the Q & A further progressed it was clear Ms. Silver's single-minded passion for ecological protection wasn't relating to the overwhelming concerns expressed by the group, especially on the impact of buffers on their property. (She called the 150 foot buffers "too small" but "politically feasible."). Ms. Silver several times used the phrase "this is what I think" as opposed to "I can understand your concerns," a distinction not lost on the group. If the raised eyebrows in the room acted as a barometer for how the WSRC might enable acceptance of increasingly comprehensive land-use regulation and improved relations between the citizen and regulator, this trial run was a failure.

On April 20th the Department of Ecology hosted a public hearing on the Locally Approved SMP that is now under their review for final approval. Roughly 200 citizens attended, and by a show of hands nearly 90% were against the LASMP. Of the approximately 90 people who spoke, I counted 11 who were in support of the LASMP and 10 of them were from within the Port Townsend city limits, where their own SMP rules. Again the support was characterized not in relation to specific needs but through invocation of general environmental ideals and anecdotal references to apocalyptic scenarios. Was the voice of the majority acknowledged? No, they were marginalized by the minority as misinformed. How often can so many be so wrong? The populace of rural Jefferson County is at their wits end with their voice being ignored or even subverted by Port Townsend interests. How those interests, exemplified by Jill Silver and Sam Gibboney and the WRSC, can be expected to represent and gain the trust of rural folks who will be the ones actually using the center (PT has their own Planning Department) has yet to be qualified in the grant application submittals.

Finally, I refer you to the message below. For a county employee to use a public information listserve as a bully pulpit to address "a mix of facts and rumors circulating through our community" is totally inappropriate and counter to the spirit if not he law of state public participation statutes. Mind you, the DOE is presently soliciting the public for their input so they may evaluate all available information in support of a final decision. For the lead DCD SMP planner to insinuate that there are "rumors" (translation: objections/dissent) circulating about sends a chilling message and discourages citizens who are already shy about expressing their views from doing so now. What this really amounts to is an attempt to influence and control the flow of information during a public process. Jefferson County is not a state-run information agency, nor is Michelle McConnell the arbiter of what is fact and what is fiction. There is an important distinction between rumors, which have a negative connotation, and a difference in interpretation. The SMP is a complex undertaking that has lasted four years. Both the Courts and the Legislature have had difficulty clarifying fundamental aspects of how protection of our shoreline is to be undertaken. For Ms. McConnell and DCD to characterize interpretations of the SMP they don't agree with as rumors only reveals their advocacy-driven slant and disregard for the public they are intended to serve. Very simply,the formal public comment period is the time for the people to speak and policy and decision-makers to LISTEN.

All through the so-called SMP "public process" citizen dissent has been labeled as rumor, misinformed, or myths. What is clear is that when DCD states it wants citizens to be informed it really means it wants them to conform. Every source listed below for "information" is from a government agency. To this day the County has refused to answer the real Frequently Asked Questions as they have been posed by the citizens. The 200 page SMP comes with fineprint and unforeseen consequenses. The rubber meets the road in the real world. This is a one-dimensional debate that hardly facilitates meaningful public involvement that might result in acceptance of a legitimate final product. But such is the insular culture in DCD. This would normally be of little interest to you at EPA, except you are now in the middle of a hefty funding allocation to promote concepts and ideas that have been sold to you on paper but hardly in practice, as these three incidents readily expose. Actions speak louder than words, and in that context the WRSC project narrative is not education but indoctrination. Lacking authoritarian military rule, indoctrination has an historically poor success rate. The County and the State seem to be gambling that eventually the people will "come around." That too has predictably failed time after time. It is so much easier, and less expensive, to LISTEN before you leap.

Jim Hagen
Jefferson County