Hughes Dock Permit - comment letter to first HEX

October 31, 2005 Lee McEnery San Juan County Community Planning & Development Department 135 Rhone Street Friday Harbor, WA 98250 Re: Hughes Dock Permit, Pearl Island, WA, TPN 461454023; Shoreline Substantial Development Permit No. 05SJ013 Dear Lee: Friends of the San Juans respectively submits the following comments on the proposed single use dock for the Hughes property, Lot 23, Pearl Island Subdivision, TPN 461454023. We recommend denial of the substantial shoreline development permit as the proposed project is inconsistent with state law and multiple provisions of the San Juan County Shoreline Master Program. Adverse Impacts to Eelgrass The near-shore environment of the Hughes property contains thick beds of eelgrass. The application states that “there is eelgrass running along the entire coast of the project area” and “adverse impacts to eelgrass are expected.” (pg. 2, August 24, 2005, letter to Matt Zybas from Francine Shaw). Eelgrass is a saltwater habitat of “special concern,” and “serves essential functions in the developmental life history of fish or shellfish.” WAC 220-110-250. Construction of docks, ramps, floats and piers “shall incorporate mitigation measures as necessary to achieve no-net-loss of productive capacity of fish and shellfish habitat.” WAC 220-110-300. (Emphasis added). “No-net-loss” is defined as (a) avoidance or mitigation of adverse impacts to fish life; or (b) avoidance or mitigation of net ...