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Shoreline Master Programs

Task 4.3: Demonstrate how no net loss is achieved

Demonstrating that your SMP achieves no net loss (NNL) of ecological functions requires that you prepare a narrative summary. The summary should demonstrate how you have applied the results of your locally prepared SMP analyses and plans to the development of SMP policies, use regulations and environment designations.

Prepare a narrative summary

In order to demonstrate NNL, you must prepare a narrative summary that demonstrates how the recommended shoreline management recommendations in the inventory and characterization report (Task 2.3), together with the conclusions of both the cumulative impacts analysis (Task 3.6) and the restoration plan (Task 4.1), are reflected in your proposed SMP and achieve no net loss (NNL) of ecological functions of shorelines. You may submit this summary as an independent deliverable or integrate it into your cumulative impacts analysis.

Think of the summary as describing the standard for NNL of ecological functions. In it you should give an overall picture of how your town, city or county will meet the NNL requirement. You should explain how policies and regulations within your SMP were developed from a science-based understanding of existing ecological functions, land segregation patterns, shoreline uses and modifications, and restoration opportunities.

Relate the summary to other documents

Each of the documents (deliverables) listed below should contribute key components to demonstrating how your SMP achieves NNL. The narrative summary should describe how each of these documents were applied, and that the resulting SMP will achieve NNL when implemented over time.

  • Inventory and characterization report

  • Shoreline use analysis

  • Cumulative impacts analysis

  • Restoration plan

  • SMP environment designations, policies, regulations and maps

  • SMP checklist

The summary can briefly compare the conclusions of the documents (all but the SMP itself and the checklist) with the environment designations and use regulations to demonstrate how these provisions avoid, reduce, and mitigate reasonably foreseeable impacts in order to achieve NNL.

You should refer to specific sections of these documents but do not need to repeat detailed information from them (e.g. no need to list specific SMP regulations or ecological functions in the summary). Detailed references to SMP regulations should be provided in the final SMP checklist in a chronological manner that captures any suggested or required changes to the SMP.

This summary should provide a general chronology of the SMP amendment (or comprehensive update) while providing reference to the specific chronology captured in the SMP checklist. By providing a chronology, your town, city or county can describe its planning process, SMP documents, major findings, SMP provisions, and changes that were made along the way to address NNL, in addition to other relevant issues.

How the summary may be used

The purpose of the NNL narrative summary and other supporting documents is to ensure that the SMP environment designations, policies, regulations and shoreline restoration plan are based on the findings of the inventory and characterization report and the cumulative impacts analysis, and will achieve NNL.

Documentation of this information will also provide a record of the jurisdiction’s decisions on SMP policies and regulations in relation to NNL. This concise information will be helpful when explaining the draft SMP to your Planning Commission, elected officials and the public. Ecology will use information from the summary in its findings and conclusions to document that NNL will be achieved and to justify approval of the SMP. Lastly, this information will be part of the record and will also be useful if your SMP is appealed.

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