On behalf of Surfrider Foundation - Oregon Chapter's nearly five hundred members, please include the following public comments to the official record for Lane County Commissioners Public Hearing regarding File No. Pa 05-5506, City of Florence & Shelter Cove Homeowners Assn. to amend the Lane County Coastal Resources Management Plan. Surfrider Foundation membership is comprised of fishermen, sailors, paddlers, divers, surfers and beachgoers - people who spend a significant amount of time on the coast and in the ocean. The Surfrider Foundation is a non-profit environmental organization dedicated to the protection and enjoyment of the world's oceans, waves and beaches for all people, through conservation, activism, research and education. Represented by over 40,000 members and 60 local chapters in the U.S. Surfrider Foundation believes that healthy coastal communities are sustained by a healthy ocean.

Those of us who spend time on the coast may do so for different reasons, but we all value its importance and cherish our ability to enjoy it - this is our coastal legacy. Our special coastal and ocean places are of critical importance to not only diverse fish and wildlife populations, but also to the people who enjoy and depend upon them. Oregon's special places attract thousands of surfers, divers, beachgoers and recreational fishermen annually. However, growing demands on these sensitive coastal and ocean places threaten the health of our marine ecosystem and the fabric of our coastal legacy.

Surfrider Foundation-Oregon Chapter opposes a change in zoning that would permit rip rap revetment to be installed at Shelter Cove in Florence. We do however, emphasize our commitment to finding a long-term solution that will not compromise the navigational, nor increasingly important recreational benefits of maintaining existing sand configurations in the river and estuary. Surfrider Foundation - Oregon Chapter opposes the rip-rap proposal on the following grounds:

• We believe that the proposal is in violation of Statewide Planning Goal 18 because it was not "developed" as of January 1, 1977 and therefore not eligible for a shoreline structure.
• The applicant has not sufficiently addressed wildlife habitat or channel alterations.
• The applicant has not conducted wave modeling to prove that no recreation resources will be altered with this proposal. The jetty wave draws hundreds if not thousands of recreation tourists per year. Local decision makers have not sufficiently considered the recreation effects and potential loss of tourism should this proposal destroy the wave quality.

Planning Goal Compliance

Statewide Planning Goal 17 Implementation Requirement 5 states that: Land-use management practices and non-structural solutions to problems of erosion and flooding shall be preferred to structural solutions. Where shown to be necessary, water and erosion control structures, such as jetties, bulkheads, seawalls, and similar protective structures; and fill, whether located in the waterways or on shorelands above ordinary high water mark, shall be designed to minimize adverse impacts on water currents, erosion, and accretion patterns.

Statewide Planning Goal 18 Implementation Requirement 5 states that: "Permits for beachfront protective structures shall be issued only where development existed on January 1, 1977. Local comprehensive plans shall identify areas where development existed on January 1, 1977. For the purposes of this requirement and Implementation Requirement 7 "development" means houses, commercial and industrial buildings, and vacant subdivision lots which are physically improved through of streets and provision of utilities to the lot and includes areas where an exception to (2) above has been approved. The criteria for review of all shore and beachfront protective structures shall provide that:

• visual impacts are minimized;
• necessary access to the beach is maintained;
• negative impacts on adjacent property are minimized; and
• long-term or recurring costs to the public are avoided.

Surfrider Foundation - Oregon Chapter believes that the proposal has not satisfied all of the local, state or federal standards to construct the proposed project. If these criteria are required for a beachfront revetment, they should be referenced for additional shoreline hardening, particularly for those within the beach dune. These conditions should be satisfied, and a State Parks and DLCD permit should be completed prior to constructing this proposal.

Wildlife Habitat

The Corps report claims that wildlife will not be affected. Wildlife such as seals, sea lions and sea birds congregate in the relatively calm waters of Shelter Cove directly in front of where the proposed revetment. It is possible that the beach there has been identified as a seal 'haul-out' area. If that designation is correct, the County Coastal Resources Management Plan is intended to protect such sanctuaries for wildlife. Therefore, this proposal should not be permitted until this issue is satisfied.

Wave Quality

This proposed revetment will have a shoreline sediment transport effect. As the shoreline is hardened, the river current will accelerate near the structure, transporting sand out to the ocean and not on our beaches. If we continually remove sand sources from our rivers, we will eventually starve our beaches of sand. If the river current is accelerated, it is also possible that the sandbar on the opposite side of the river will be eroded. This sandbar is used by surfers and kayakers nearly year-round. Daily, it draws recreational tourists from Eugene, Portland, Coos Bay, Newport and beyond. According to industry marketing figures, surfing recreation in the Pacific Northwest is growing at approximately 400% per year. The future revenue generated by surfing-specific visitors to this area is incalculable.

This break is one of approximately eight south wind-protected surfing spots along the entire Oregon coast. Because south winds accompany most storm events - occurring year-round - this protection is invaluable. Decision makers should consider the potential tourist revenue effects to altering or destroying this resource before this permit is approved. Because the applicant has not conducted wave or sand transport modeling, Surfrider Foundation believes that the applicant cannot definitively address the proposed revetment's effects of sand movement along the estuary or sand replenishment to the shoreline.

Because the applicant has not conducted wave modeling to prove that no recreation resources will be altered with this proposal, and local decision makers have not sufficiently considered the recreation effects and potential loss of tourism should this proposal destroy the wave quality, this proposal should not be permitted.

The Corps claims that the source of bank erosion at Shelter Cove comes from local wind-generated waves. This is very inaccurate. As a surfer, intimate with this area, I observe ocean waves come straight down the outlet of the Siuslaw River and break against the bluffs at Shelter Cove. There are ocean waves interacting with this bank. Additionally, this proposal is on the cut-bank side of the river, where the majority of the current's velocity is realized. It is natural that this bank will erode and the river will laterally migrate over the landscape. These ecological factors should be considered before the permit is approved.

Because the applicant has not conducted sand or wave modeling for this project, they cannot prove that the structure will be sufficient. Revetment structures this close to the water's edge typically accelerate erosion in front of them. The applicant has no plan to maintain this sand in front of the structure when it is eroded. There is no plausible way to assure that a beach exist in front of the proposed structure. In years past, there has been a rideable wave directly in front of the proposed structure. This resource should not be destroyed because one developer failed to abide by the conditions of a development permit.

In a similar case in Westport Washington, the CORPS has been required by a settlement agreement to maintain a sandy recreational beach in Half Moon Bay. They have been required to do this for several years, but have not fulfilled these terms. Recent coastal engineering and the introduction of gravel and cobble to the beach has actually accelerated erosion along portions of the beach. This combined with the lack of required sand replenishment in the area has further degraded public access and recreational resources in Half Moon Bay. While we recognize that the proposed revetment Florence Oregon is a different CORPS District, we have concerns that there are numerous familiarities to the Westport, Washington case. It can be assumed that the CORPS is not capable of maintaining a sandy beach, preserving public access and recreational resources in Florence. Additional measures should be developed that protect the jetty and the navigational channel, while maintaining the sandy beach.

Please do not approve the proposed request until all questions about design and cost, the effect on wildlife, legal compliance and ocean recreation are satisfactorily addressed.

For the Ocean,
Bryon McConnell