by Michael Gustavson
To: Director, Department of Community Development, MS-36 6/02/2011
Attn: Mr. David Greetham
614 Division St
Port Orchard, WA. 98366
Perhaps the following will be helpful in developing the Shoreline Master Plan Update. I recommend these maps be developed and included in the Shoreline Inventory and Characterization study:
“At Risk” Shorelines Relationship Maps
The biological relationships per NAU or parcel between “stressed” and “stressor” are nowhere displayed, thus preventing meaningful regulation of individual building permit applications.
These maps would display the relationship between an alleged “Stressor” and a “Stressed Biological Creature”
For instance, a map displaying bulkheaded parcels and the locations of forage fish spawning beaches would be appropriate.
A map of bulkheads and beaches that are frequently impacted by shipping wake action might be appropriate. A map of parcels with riparian vegetation and forage fish spawning beaches might be appropriate.
A map of piers and fish passage or existence would be appropriate. There is a body of evidence supporting the premise that piers are not an impediment to either fish habitat or passage.
A map of bulkheads and geoduck beds or eel grass beds would likely not be appropriate because there is no logical relationship, since both of eel grass and geoducks are sub-tidal and beyond the reach of bulkhead wave influence.
The benefit of this type of mapping would be to show where regulation might be most appropriate and effective for future development.
It is worth keeping in mind that existing structures, and I believe that includes bulkheads, become “grandfathered” and there continuance would be allowed. Given that being the case, we’re really only in the position
of regulating new construction bulkheads.
Because new construction bulkheads must be constructed at or above the mean higher high tide line, they become useful for abating excessively high waves. These occur at high tide from storms (fairly rare) and ship wakes (frequently several times each day).
It has been shown soft bulkheads are effective in sheltered area, but do not survive on exposed beaches, especially points which receive higher wave impacts. This might drive the application of regulations regarding the typed of
new construction bulkheads allowed as new construction.
You may reach me at email@example.com if you have further questions or if I may be of further assistance.
/s/ Michael A. Gustavson