DRAFT WRIA 9 Shoreline Armoring Recommendations

RCW 90.58.030 defines Substantial Development as: “any development of which the total cost or fair market value exceeds five thousand dollars, or any development which materially interferes with the normal public use of the water or shorelines of the state…” The definition also allows an “exemption” from the definition of substantial development for single family bulkheads as follows:
“Construction of the normal protective bulkhead common to single family residences.”

This exemption from the definition of substantial development has caused some confusion by local jurisdictions regulating shoreline development under the Shoreline Management Act and their individual Shoreline Master Programs (SMP). Although the exemption (if the proposal qualifies) does not require the approval of a Shoreline Substantial Development permit, the proposal must still comply with the requirements of the SMA and the local SMP, which may include provisions for technical studies to evaluate the need for the proposal, soft armoring alternatives to the proposal, and mitigation of environmental impacts under the State Environmental Policy Act (SEPA).

Confusion also arises over the applicability of the exemption. Not all bulkheads (or other forms of hard armoring) serve a protective function; therefore the evaluation of the need for the bulkhead is essential. Smaller jurisdictions that do not have their own in-house technical staff (e.g. geotechnical experts) have the option of having an applicant’s technical study evaluated by an objective third party working on the local jurisdictions behalf and charging the cost of that evaluation to the applicant.

The bluffs, beaches, and nearshore[1] areas of Puget Sound are completely connected as integral parts of a coastal system. Past and current management of parts of bluffs and beaches (primarily bulkheading) treated in isolation from the coastal system has resulted in substantial negative impacts to coastal erosion, fish, and wildlife. Protecting and restoring sediment pathways is fundamental to conserving beaches, fish spawning and salmon rearing habitat, wildlife foraging, and coastal wetlands.

There is a substantial amount of scientific information and the understanding of marine coastal systems is improved to begin making informed decisions on managing the nearshore. Most notably, the marine nearshore environment plays a critical role in the life history and ecology of threatened Chinook salmon and many other species in Puget Sound.Subsequent to the adoption of the WRIA 9 Salmon Habitat Plan, two key technical studies were completed that provide additional data on the importance of marine nearshore processes with particular emphasis on the importance of feeder bluffs. The Inventory and Assessment of Current and Historic Beach Feeding Sources/Erosion and Accretion Areas for the Marine Shorelines of Water Resource Inventory Areas 8 and 9 report (2005) documents historic and current marine nearshore conditions. The report includes detailed mapping of feeder bluff and accretions shoreforms along all 90 miles of Puget Sound shoreline within WRIA 9. The report also characterizes feeder bluffs by their significance (e.g. “exceptional,” “modified”). Building on the 2005 Inventory and Assessment report, the Prioritization of Marine Shorelines of WRIA 9 for Juvenile Salmonid Habitat Protection and Restoration report (2006) identifies Puget Sound shoreline salmon habitats in southern KingCounty that should be preserved or restored. The 2006 report made specific recommendations for twelve subareas on Vashon-Maury islands and from Magnolia bluffs to Federal Way that can be used by WRIA 9 marine nearshore jurisdictions in evaluating armoring requests and in updating their SMP’s.

RECOMMENDATION:

1. Adopt the 2005 and 2006 marine nearshore reports cited above as part of the WRIA 9 Strategic Assessment.

2. Develop policy that specifically addresses marine nearshore armoring that will serve to provide support and guide WRIA 9 marine nearshore jurisdictions during updates to their SMP’s and in exercising their authority under the SMA, their SMP, and SEPA to regulate, and when appropriate to deny exemption requests for single family bulkheads. Policy Guidance for Armoring in the Nearshorewould include the following elements:

  • Shoreline exemption requests for single-family house hard armoring proposals shall document the need for hard armoring and evaluate “soft” armoring alternatives.
  • State Environmental Policy Act (SEPA) and the Shoreline Management Act (SMA) should be used to require mitigation of adverse environmental impacts.
  • Washington State Department of Fish and Wildlife (WDFW) should be consulted regarding Hydraulic Project Approval (HPA) prior to making a decision on the exemption request.
  • Current WRIA 9 marine nearshore technical documents should be used in evaluating shoreline armoring proposals.
  • Protect existing undeveloped shoreline areas in WRIA 9 from development practices that would be detrimental to the nearshore ecosystem. Develop protection, acquisition, and incentive strategies for lands that would contribute to maintaining or restoring ecosystem processes and functions to the benefit of nearshore ecosystem health.
  • Protect and enhance marine riparian vegetation.
  • Protect forage fish spawning areas and other upper intertidal habitats and species. Concentrate restoration and enhancement efforts on areas with shoreline armoring and other development practices that reduce ecological processes and functions that support habitat quality.
  • Develop a restoration strategy for the WRIA 9 nearshore that takes an ecosystem perspective within the landscape and helps to build our knowledge of the nearshore environments.
  • Identify critical areas for protection, restoration, and enhancement in WRIA 9. Then protect, restore, and enhance them.
  • Reduce the amount of existing shoreline armoring in WRIA 9, and prevent new installations of shoreline armoring.
  • Restore natural physical and biological processes lost as a result of shoreline armoring and other bank stabilization practices.
  • Determine and restore natural drift cell processes, specifically sediment budges (i.e., rates, volumes, distribution). Feeder areas are particularly important. Where sediment supply is unimpeded, protect it. Where it is impeded, restore or enhance it. Prevent the loss of sediment supply from armoring and other structures within the drift cell.
  • Develop and implement technical guidance for alternatives to traditional shoreline armoring that maintain natural shoreline processes and functions.

10/12/2018

[1]The nearshore zone is defined as that area between the lower limit of the photic zone (approximately minus 30 meters mean lower low water) and the upland aquatic interface. The nearshore zone extends landward to include coastal landforms such as coastal bluffs, the backshore, sand spits, and coastal wetlands, as well as marine riparian zones on or adjacent to any of these landforms and aquatic features. The nearshore zone includes sub-estuaries such as the tidally influenced portions of river and stream mouths.