by Ross Barnes Monday, July 1, 2013 5:05 AM

June 28, 2013


From:  Ross O. Barnes

13695 Harbor Lane

Anacortes, WA 98221

(360) 293-7023


To:  John Cooper

Skagit County P&DS

1800 Continental Place

Mount Vernon, WA 98273




My comments are on behalf of myself and Evergreen Islands. 


On April 12, 2013, I submitted comments to you on PL13-0102.  These comments identified a designated Wildlife Habitat Conservation Area (HCA) of local importance--the Anacortes Community Forest Lands (ACFL)-as immediately north of the subject Harkness property and subject to the applicable regulations of the Skagit County Critical Areas Ordinance under SCC 14.24.520 (Exhibit A).  My April 12 letter specifically identified what would be required to meet the requirements of SCC 14.24.520. 


Both your draft MDNS and the May 24, 2013, Stratum Group/Edison Engineering report on which the MDNS is based, fail to recognize the ACFL as a protected HCA and fail to provide the applicable evaluations, recommendations and mitigation required by Skagit County code. 


In the absence of the required evaluations and mitigation plan, SCC 14.24.520 requires that any site disturbances remain at least 200’ away from the HCA-ACFL boundary on the north property line of the Harkness property.  We request that you add an additional condition to the MDNS that specifies this minimum 200’ setback from the ACFL as a protected critical area.  Without this additional condition, your proposed MDNS violates Skagit County code. 




The ACFL is the centerpiece of Anacortes’ non-marine HCA’s and an essential element of  wildlife habitat protection in Anacortes.  All of the complex habitat of the ACFL is a protected critical area in its entirety and for all wildlife species, not just listed species.  The Stratum Group/Edison Engineering report evaluated only listed species and ignored the whole ACFL as an HCA.  My April 12 letter listed just some of the potential impacts of the Harkness projects on the ACFL habitats. 


Evaluation of submitted site plans show that the 200’ setback from the ACFL HCA, that is required in the absence of  HCA specific evaluations and habitat management/mitigation plans, falls within the designated falcon nest buffer or is above the base of the rock cliff where logging is not proposed (Exhibit B).  Thus, this 200’ setback that is required under Skagit County code will impose no additional restrictions on the logging and development activities proposed for the Harkness property, but will bring the MDNS into compliance with Skagit County code. 


Please notify me immediately of your final MDNS decision so we have adequate time for appeal if that is necessary.  My email address is georbarnes@hotmail.com. 


Ross O. Barnes, Ph.D.

Earth Science



Attachments:  Exhibits A and B


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