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City of Tukwila Planning Commission <br />March 28, 2019 <br />Page 3 <br />Importantly, the March 28, 2019 Staff Report to the Planning Commission states that this periodic <br />update is "not" intended to "extensively assess the no net loss criteria other than to ensure that proposed <br />amendments do not result in degradation of the baseline condition." Likewise, the focus of the City's SMP <br />is, appropriately, on "no net loss" of baseline conditions. However, the language that is proposed to be <br />added here expressly calls for "improvement" rather than no net loss, and with no definition as to the level of <br />"improvement." That is sea change in policy approach and inconsistent with a periodic update. We <br />recommend that section 18.44.05011.1 read: <br />H.1. All shoreline development and uses shall occur in a manner that results in no net loss of <br />shoreline ecological function through the careful location and design of all allowed <br />development and uses. In cases where impacts to shoreline ecological functions from <br />allowed development and uses are unavoidable, those impact shall be mitigated according to <br />the provisions of this section; in that event, the "no net loss" standard is met. <br />5. Pronosed 18.44.090 Shoreline Design Gttidelines <br />Here, too, language is added to the regulation that seeks to recognize the use of the Green River to <br />support salmon and trout. That is just one feature of the Green River. The placement of this language also <br />infers that Endangered Species Act requirements would apply to upland projects in the event any portion of <br />the project fell within the City's Shoreline jurisdiction. We certainly understand the City's desire to <br />acknowledge the importance of the river to aquatic species and to do so, we recommend that the Ordinance <br />recitals — not the regulatory text — include a statement such as: "The City of Tukwila recognizes and <br />celebrates that the Green River and its tributaries support salmon and resident trout, and that the river flows <br />to Puget Sound which is home to salmonids and southern resident orca whales, and the City has designed this <br />SMP update to assure no net loss in ecological function of the river system." We also recommend that the <br />introductory language of 18.44.090 not include the sentence about salmon and trout. <br />We appreciate your attention to this matter and would be happy to answer any questions. <br />Very truly yours. e <br />L4,1t44- <br />Nancy Bainbridge Rogers <br />NBR:alw <br />cc: Ann Marie Soto <br />Nora Gierloff <br />Mark Segale <br />Mike Pruett <br />{03700624.1)00U <br />1 1 <br />