By David C. Kyler,
Executive Director, Center for a Sustainable Coast
February 3, 2004
Maintain site hydrology - While limits on impervious surface is desirable, to the maximum extent possible,
CRD should require that those using hammocks for developed purposes retain the site's pre-development hydrology,
as well as water quality both onsite and in surrounding areas.
Reliable and responsive monitoring and assessment - Conditions imposed on permits related to hammock use must
be properly monitored and evaluated to ensure (a) that permit conditions are being met, and (b) that conditions
imposed are achieving their intended benefits. This will require an unprecedented level and extent of staff capacity,
without which standards will not be effective.
Permits across marshes for use of hammocks are a privilege and not a right. Such privileges are justifiably
subject to standards that are beyond those for development of conventional sites. Those who choose to exercise
those privileges much comply with higher development standards and be willing to compensate the state for the cost
of enforcing them.
Analysis of feasible alternatives - Before being granted a marsh permit, applicants should be required to
demonstrate that there is no reasonable, feasible alternative for developing an alternate site for the
intended purpose that would not require the marsh permit, or which would significantly reduce the potential
for harm to the public interest.
The capacity for determining environmental risks and adverse impacts on surrounding property owners
introduced by proposed hammock projects must be significantly advanced. For instance, the effects of marsh
vistas on property value are generally understood, and are acknowledged in the concept of 'viewshed' addressed
in the work of DNR's facilitation process, but more documentation of these effects in this region is needed.
Such work would help substantiate the need to improve regulations in order to reduce undesired outcomes.