DESIGNATION:

PROGRAM DRAFT ENVIRONMENTAL IMPACT STATEMENT

TITLE

ABSTRACT

APPLICANT:

LOCATION:
LEAD AGENCY:

COOPERATING AGENCIES

Washington State Coastal Zone Management Program
Amendment No. 3: Approval and Adoption of the
Grays Harbor Estuary Management Plan

The Grays Harbor Estuary Management Plan (plan) is a long-
range, coordinated, comprehensive plan designed to guide
future land and water use activities in Grays Harbor. It
will be implemented through individual local Shoreline Master
Programs under the Washington State Shoreline Management
Act, other ordinances, and through various State and Federal
regulations and permit actions. Grays Harbor estuary has
been previously designated in the State Coastal Zone Manage-
ment Program as an "area of particular concern" requiring
special management attention. The focus of the plan is to
define areas in which future activities and growth would be
deemed acceptable while minimizing adverse impacts. Devel-
oped by an intergovernmental agency task force, the plan
seeks to provide a balance between future development activi-
ties and the productive capacity of the estuarine system;
minimize confl icts between resource users and regulators by
enhancing the predictability of government permit decisions
associated with the location of the future developments by
taking agency requirements into account ahead of time; allow
resource agencies to address cumulative effects of incremen-
tal permit proposals; and to provide appropriate mitigation
or reduction of adverse development impacts.

This PDEIS describes the impacts associated with approval of
the plan's recommendations and its implementation. Adverse
impacts include potentially allowing the filling of up to an
estimated 700 acres of aquatic habitat (or 1.2% of the estua-
rine environment) and the committing of specified areas to
urban uses with related modification to shoreline features.
Beneficial impacts include greater protection and enhancement
of large areas of the shoreline and estuarine environment,
protection of the regional economic base and the potential
for future economic development, improved transportation sys-
tems and others associated with orderly land development.

Washington State Department of Ecology
Olympia, Washington

Grays Harbor County, Washington (see map opposite page)

U.S. Department of Commerce

National Oceanic and Atmospheric Administration

Office of Ocean and Coastal Resource Management

U.S. Army Corps of Engineers

U.S. Environmental Protection Agency

U.S. Fish and Wildlife Service

National Marine Fisheries Service

Grays Harbor Regional Planning Commission*

U.9.0W"""00"

Title Page Continued.

CONTACT: Mr. William Bran, Pacific Regional Manager

Office of Ocean and Coastal Resource Management
3300 Whitehaven Street, N.W.
Washington, D.C. 20235
(tele. 202/254-7100)

*The Grays Harbor Regional Planning Commission has lead agency responsibility
under the Washington State Environmental Policy Act (SEPA). This Federal EIS
is intended to satisfy the requirements of SEPA. Contributions in the prepara-
tion of the EIS from the Regional Planning Commission are gratefully acknowl-
edged.

NOTE TO REVIEWERS

1. Attachment I - Data Maps Supplement, will be distributed on a one-time basis
only.

2. The Program Final Environmental Impact Statement (PFEIS) will be distributed
only to parties who comment on this Program Draft Environmental Impact
Statement (PDEIS) or who specifically request a copy during the public
review period.

3. During 1980, the Coastal Zone Management Act (CZMA) was amended to include
the recognition and encouragement of a relatively new type of planning and
management tool known as "special area management planning" (SAMP). Real-
izing that there are intense conflicts surrounding the utilization and
preservation of some coastal resources more than others, Congress declared
a national policy to: "encourage the preparation of special area management
plans which provide for increased specificity in protecting significant
natural resources, reasonable coastal-dependent economic growth, improved
protection of life and property in hazardous areas, and improved predicta-
bility in governmental decisionmaking;" (§303(3)).

GHEMP is one form of a SAMP and ever since the planning process started in
1976, 0CRM has received a number of expressions of interest in the planning
and management process because of intense conflicts needing resolution.

For those individuals who care to take the time, 0CRM is interested in their
comments and opinions on SAMP's in general and/or on the GHEMP process.
For instance, commenters might consider:

o Does the GHEMP process which involved Federal, State and local government
representatives planning in advance and making general decisions on the
future use of the resources prior to applications for specific projects
represent a useful approach to SAMP consistent with the CZMA directive?

o What other innovative planning and management techniques to solve complex
resource development/preservation conflicts should 0CRM and the States
be developing as types of special area management planning?

Your comments will be appreciated, carefully evaluated and will assist us
in the future conduct of our activities and assistance to the States. You
may submit your comments separately or in conjunction with your comments
on this environmental impact statement.

TABLE OF CONTENTS

SUMMARY

A. Background i

B. Proposed GHEMP ii

C. Areas of Controversy ix

D. Issues to be Resolved xiii

E. Major Conclusions xiv

F. Future Actions xviii

Part I. PURPOSE AND NEED FOR ACTION

A . General 1-1

B. Program EIS 1-1

C. Nature of the Action 1-2

D. Need for the GHEMP 1-6

Part II. ALTERNATIVES INCLUDING THE PROPOSED ACTION

A. General

B. The Proposed Action ,

C. No Action ,

D. Alternative Plan Concepts ,

1. Greater development opportunity/less resource protection

2. Less development opportunity/greater resource protection

3. Disperse development ,

4. Concentrate development ,

5. Locate industrial areas away from estuary ,

a. Non-estuarine areas ,

b. Other sites in estuary ,

c. Other ports ,

E. Urban Management Unit Designations ,

F. Means of Implementation ,

G. Mitigation ,

Part III. AFFECTED ENVIRONMENT

A. General Setting ,

B. Use of Inventory Data in Planning Process

C. Physical Environment ,

D. Biological Environment ,

E. Socioeconomic Environment ,

1-1

1-2

1-14

1-20

1-20

1-22

1-31

1-32

1-34

1-34

1-35

1-37

1-44

1-73

1-77

II-l
II-2
II-4
II-9
11-26

Part IV. ENVIRONMENTAL CONSEQUENCES

A. Introducti on IV-1

B. Elements of the Physical Environment IV-1

C. Elements of the Biological Environment IV-7

D. Elements of the Human Environment IV-20

E. Impact Evaluation of Planning Alternatives IV-25

F. Cumulative Impacts IV-36

G. Relationship Between Short-Term Uses and

Long-Term Productivity IV-42

H. Unavoidable Adverse Impacts IV-44

I. Irreversible and Irretrievable Commitment of Resources IV-44

J. Relationship to Existing Land Use Plans, Zoning and

Regu 1 at i on s IV -46

Part V. MISCELLANEOUS

A. List of Preparers V-l

B. List of Agencies, Organizations and Individuals Receiving

a Copy of the PDEIS V-2

C. Appendix

A. GRAYS HARBOR ESTUARY MANAGEMENT PLAN

B. Federal Agency Letters of Intent

C. Management Unit 12 - Bowerman Basin Impacts

D. Various Articles on the GHEMP process

E. Excerpts from the Federal Coastal Program Review

F. The Citizen's Grays Harbor Estuary Management Plan

G. Use and Development of the Urban Waterfront from
"Revitalization Potentials on the Grays Harbor
Urban Waterfront," GHRPC, Nov. 1981

H. List of Technical Team Members and Individuals

Interviewed
I. Species List

D. Attachment 1 - Data Maps Supplement
Map 1. Existing Land Use

" 2. Land Ownership

" 3. Jurisdiction and Boundaries/Historical

" 4. Land and Water Transportation

" 5. Major Util ities

" 6. Hydrology and Floodplain

" 7. Soils and Sediments

8. Vegetation/Wildlife

" 9. Fisheries

" 10. Natural Resource Use

LIST OF TABLES

1. Breakdown of Management Unit Designations 1 1-3

2. Estimated Waterfront in Generalized Conservation &

Development Categories 1 1-4

3. Characteristic Species of Major Vegetation Types of

Grays Harbor Estuary 1 11-10

4. Organic Carbon Contributions of Various Sources

Wi thi n the Estua ry 1 1 1-1 2

5. Estimated Extent of Intertidal Habitats in Grays Harbor 111-14

6. Populations of Incorporated Communities Around Grays Harbor 1 1 1-26

7. Population Projections: 1990 1 1 1-27

8. Timberland Ownership - Public/Private 1 1 1 -27

9. Average Annual Unemployment Grays Harbor/Washington/Nation 1 1 1-28

10. Potential Loss of Aquatic Areas Which Would Be Impacted

By Future Projects IV-8

11. Habitat Types Depicted in Figure 25 IV-12

12. Bird Habitats Protected by GHEMP IV-16

13. List of Birds Associated With Freshwater Shrub Swamp or

Marsh Habi tats I V-l 7

14. Mammals Found in Six Grays Harbor Habitats I V-l 9

LIST OF PHOTOGRAPHS

1. Aerial View of Management Unit 12 xi

2 . Renni e Isl and 11-33

3. Port of Grays Harbor Shipping Terminal 11-42

4. Bayside View of Ocean Shores 11-45

5. Ocean Shores Existing Air Terminal and Proposed New

Terminal Site 11-47

6. Management Unit 12 11-49

7. Management Unit 12 11-50

8. Management Units 14, 15 and 43 11-56

9. Management Units 18, 19 and 20 11-60

10. Management Unit 21 11-61

11. Management Unit 25 11-63

12. Management Unit 26 11-66

13. Management Units 33, 34 and 35 11-68

14. Management Unit 38 - Westport Airport 11-70

LIST OF FIGURES

1. Planning Areas-Character, Major Uses, Conflicts, Assets iv, v

2. Standard Uses Matrix vi

3. Permitted Activities Matrix vi

4. Shorefronts in Generalized Conservation or

Devel opment Categori es . 1 1-5

5. Consolidated Permitted Activities Matrix 1 1 -7

6. Comparison of Existing Local Shoreline Master Program's

and GHEMP 11-18

7. Port Study Regions 11-38

8. April 1978 Draft GHEMP Proposed Alternative for MU 12 11-53

9. Aberdeen Riverfront Marina Park 11-58

10. Schematic of MU 26 Proposed South Shore Fill Site 11-64

1 1 . West port Man' na 1 1 -72

12. Potential Mitigation Sites 11-78

13. Chehalis Drainage Basin 1 1 1-5

14. Salinity Averages Ill -5

15. Nomenclature of Navigation Channel Ill -6

16. Wetland Vegetation of Grays Harbor 111-13

17. Significant Bird Habitats 111-17

18. Life History Stages and Range and Peaks of

Chinook, Chum and Coho Salmon in Grays Harbor 1 1 1-18

19. Life History Stages and Range and Peaks of

Steelhead, Cutthroat and Sturgeon in Grays Harbor 111-18

20. Life History Stages and Range and Peaks of

Shad, Flounder and Shellfish in Grays Harbor 111-19

21. Outmigration Periods for Selected Salmon and Trout 111-19

22. Predators of Corophium salmonis II 1-22

23. Map Depicting Non-Consumptive Resource Use 1 1 1-29

24. Schematic of Grays Harbor Food Web IV-10

25. Land Use Cover Map of MU's 18 & 25 IV-11

26. Identified Sites of Archeological Significance IV-24

27. Summary of Natural, Social and Economic Impacts of

PI anni ng Al ternat i ves IV -26

28. No Action Alternative Map IV-27

29. GHEMP Alternative Map IV-28

30. Less Development Alternative Map IV-29

31. Greater Development Alternative Map IV-30

32. Dispersed Development Alternative Map IV-31

33. Concetrate Development Alternative Map IV-32

34. Extent of Intense Urban & Residential Development Map IV-37

35. Planning Areas and MU's Showing Extent of Potential

Land and Water Use Activities IV-38

36. Consolidated Permitted Activities Matrix IV-39

37. Major Wetlands Which Will Be Impacted IV-40

SUMMARY

A. BACKGROUND

On June 1, 1976, the Office of Ocean and Coastal Resource Management
(OCRM) approved the Washington State Coastal Zone Management (WSCZM) Program
as complying with the requirements of the Coastal Zone Management Act (CZMA).
The State of Washington Department of Ecology (DOE) as part of its WCZMP iden-
tified the Grays Harbor Estuary as being an "area of particular concern" and
in need of further planning and management. 1 In September 1976 the Grays
Harbor Regional Planning Commission (GHRPC) received funds from the DOE for
the development of the Grays Harbor Estuary Management Plan (GHEMP or plan).

The governmental responsibility for making decisions about the use of the
land and water resources of the Grays Harbor area falls to a wide variety of
local, State, and Federal agencies. This array of authority lacking a common
information and policy base had led to confusion, uncertainty, and frustration
for individuals and organizations seeking to carry out their responsibilities
or commenting on an activity in the estuary. 2

In recognition of these conflicts and variety of authorities, the GHRPC
formed a special advisory Task Force consisting of representatives from those
local, State, and Federal government agencies with authority to decide on land
and water uses, including Grays Harbor County; the cities of Aberdeen,
Hoquiam, Ocean Shores, Westport and Cosmopolis; the Port of Grays Harbor;
Washington State Departments of Ecology, Game, Fisheries and Natural Resources;
Environmental Protection Agency; Fish and Wildlife Service; and the National
Marine Fisheries Service. The Army Corps of Engineers was not an official
member of of the Task Force but did provide technical assistance throughout
the planning process. A consultant team was retained to assist in developing
the plan.

A five-step planning process was initiated including the assembly of a
comprehensive resource data base, development of the plan through alternatives
analysis and consensus decisionmaking, two separate steps involving the review
and revision of draft plans, and finally adoption of the plan by the Estuary
Task Force. The Task Force will approve the plan after all comments from the
public have been received, evaluated, responded to and final changes made.
This action in and of itself has no legal standing since the Task Force is an
advisory body. The GHRPC will then submit the GHEMP to participating local
governments for consideration of revising their existing local Shoreline
Master Programs (SMP's) and implementing ordinances as appropriate. Once
approved, the local governments will submit their amendments to the DOE for
State approval. Additional public hearings will be held by both the local
governments and the DOE in accordance with established rules and regulations.
After DOE approval, OCRM will review the GHEMP for incorporation as an amend-
ment to the existing WCZMP and make Findings of Approvability if appropriate,
at which time Federal consistency under Section 307 of the CZMA will apply to
future Federal actions in Grays Harbor.

1. Office of Coastal Zone Management, NOAA, Final Environmental Impact State-
ment - State of Washington Coastal Zone Management Program, April 9, 1976.

2. For further background information see Part I, Section D-Need, Appendix D;
and GHEMP, p.l, "Why the Plan?"

B. GRAYS HARBOR ESTUARY MANAGEMENT PLAN

The GHEMP is a management framework to guide future decisions related to
the use of the estuary, striking a balance between the human use of the estuary
to meet the region's social and economic needs, and the need to conserve and
protect the long-term productive capacity of the estuarine ecosystem and its
related recreational and natural values. But it does more than attempt to
accommodate environmental, biological, commercial, industrial, sport and other
demands without sacrificing the viability of any of them. One of its major
purposes is its attempt to minimize potential conflicts between development
interests and resource protection agencies and provide a measure of predicta-
bility to development interests, environmental interests and State and Federal
resource agencies. By protecting the natural resource base, minimizing con-
flicts between users, and providing some degree of predictability, it is hoped
that the plan will serve the total spectrum of the public interest in utilizing
and maintaining a valuable ecosystem.

The proposed GHEMP is included in appendix A in its entirety. A summary
of the proposed plan follows, as a description of the proposed action.

1 . Summary of the GHEMP

a. Planning and Management Framework

(1). The GHEMP is based on the assumption that adequate guidance
to property owners and government decisionmakers can only be provided by agreed
upon detailed policies. The plan establishes, therefore, three levels of
policies to guide land use and development activity with increasing degrees of
specificity.

(2). The first policy level is the overall goal to "manage the
estuary for the multiple uses which it can provide." Types of uses include
port facilities, manufacturing, transportation, food industry, commercial,
recreation, residential, agricultural and natural areas. The plan attempts
to accommodate each of these diverse uses in a practical and environmentally
sound way.

(3). The second level broadly categorizes uses of land and water
into eight Planning Areas based on a common set of natural and man-related
features including land ownership, political jurisdictions, existing uses,
areas of existing or possible conflict, and physical boundaries or features.
The Planning Areas provide a basis for describing how different areas of the
estuary function and how they might function in the future. Each Planning
Area is described in terms of its existing character, its major committed uses,
its conflicts and assets, and includes planning guidelines for the future use
of the area. A summary of the Planning Areas is contained in figure 1.

(4). The third level of policy in the plan, the Management Unit
(MU), is the most specific level and is designed to give guidance to property
owners and government agencies in evaluating project proposals. The plan
establishes forty-three MU's classified into the following categories:

n

° Natural (N): to preserve and/or restore natural areas,

° Conservancy Natural (CN): to preserve and restore or enhance
areas to their natural condition,

° Conservancy Managed (CM): to protect an area for uses that
depend on natural systems,

0 Rural Agricultural (RA): to protect existing and potential
agricultural lands from urban expansion,

0 Rural Low Intensity (RL): to restrict intensive development
along undeveloped banklines and maintain open spaces,

° Urban Residential (UR): to protect areas in which the pre-
dominant use is or should be residential,

° Urban Mixed (UM): areas in which there is or should be a mix
of compatible urban uses,

0 Urban Development (UD): areas in which predominant uses are or
will be industrial and commercial development, and

° Special (SP): areas where non-standard conditions exist either
in the unit's boundary definition or where other special cir-
cumstances are present.

(5). In general, most of the estuary is designated in categories
which constitute little change from existing conditions. Most of the water,
intertidal and marsh area in the estuary is designated in Natural or Conser-
vancy environments and most of the uplands are designated in Rural environments.
The Urban environments, allowing more intensive uses, are generally associated
with or are in proximity to areas currently containing intensive uses. While
focusing the more intensive uses toward existing urban areas, the plan allows
for some expansion into adjacent areas.

(6). In some cases, MU's have been split to afford additional
protection to critical wetland values. A standard use matrix for each category
of MU in the plan (see figure 2) identifies the permitted uses (a use or activ-
ity that conforms with the plan and may be undertaken subject to applicable
permit requirements and policies and standards of the plan), conditional uses
(for definition see GHEMP p. 17), and uses subject to special conditions for
each classification category.

(7). For each MU the plan also identifies activities (dredging,
filling, erosion control, water structures, etc.) which may be allowed by
permit or otherwise regulated through a permitted activities matrix for each
MU. Generally, the term "activities" addresses those actions which modify
the physical character of the shoreline, in contrast to the term "uses" which
refers to land use practices. Consequently, a given use (heavy industry,
shipping, residential, etc.) as regulated by the MU category (e.g. UD), may
or may not be permitted to engage in various activities (dredging, filling,
erosion control, placing structures in water, etc.) because of the limitations
placed on the uses in the activities matrix for that MU (see figure 3 and
GHEMP pp. 6-9, HOW TO USE THIS PLAN).

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b. Neither the plan nor agency commitment is intended to circumvent
any permit authority, existing regulations, or public interest review; nor
does it eliminate any of the criteria that an agency must use in evaluating a
specific permit request (see GHEMP, pp 4-5, "Relationship to Local, State and
Federal Permit Processes"). Rather, the plan integrates as much as possible
the various requirements and responsibilities into the future uses and activi-
ties envisioned by the plan. Therefore, it is believed that the plan can
answer some of the most difficult questions often asked during permit decisions
affecting development projects within shoreline areas. For instance, under the
404(b)(1) Guidelines which must be met before a 404 permit can be issued, the
very important issues regarding the practicable alternatives to the discharge
of dredged or fill materials on the aquatic ecosystem, water dependency and
producing the least adverse impacts can perhaps best be answered through col-
laborative (intergovernmental) comprehensive planning of which GHEMP is a
product. The fact that these questions can be answered in part or in whole
ahead of time for major future projects should alleviate many of the problems
encountered in planning for development and in permit processing. The Task
Force attempted to do this for several projects which were considered during
the planning process. In some cases a great deal of time may be saved in
permit processing which may benefit all concerned.

3. Impacts

a. It was the purpose of the Task Force to provide a comprehensive
plan which would provide long-term environmental benefits as well as economic
and social benefits over and above what the existing local SMP's provided.
Large areas of the estuarine system are designated to conserve and protect
their natural productive capacity, including the majority of the estuary's
intertidal and submerged areas not utilized for navigation, a large marsh area
upstream of Junction City and Cosmopolis, all of the Elk River Estuary, exist-
ing game management areas (Humptulips Delta, Johns River, and Oyehut), and
specially designated areas intended to limit designated development areas in
the vicinity of south Aberdeen, Ocean Shores Airport, and the Bowerman indus-
trial area. Of particular importance is the "fish base" located in ML) 1 4 and
the "fish passage" which is important for migratory fish to pass through the
urban areas of Aberdeen and Hoquiam.

b. A major trade-off provides the potential of up to 500 acres of fill
(through phased development) for future port expansion and economic development
while providing permanent protection to 1700 acres of aquatic habitat in ML) 12.
Ml) 12 has been identified as a significant habitat for migratory shorebirds and
peregrine falcons. Filling of the wetlands over the years will have a signifi-
cant adverse environmental impact on that habitat but, in the collective judg-
ment of the Task Force including the Federal agencies, not an unacceptable one
within the context of the entire ecosystem. For a definition of "unacceptable"
see GHEMP p. 20. The U.S. Fish and Wildlife Service has made a finding that
the proposed fill configuration would not jeopardize the continued existence of
the peregrine falcons, and various mitigation and monitoring requirements are
intended to increase the certainty that the peregrine falcons' continued exist-
ence will not be jeopardized.

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PERMITTED USE

SEE SPECIFIC MANAGEMENT UNIT
GUIDELINES

USE CATEGORY

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VI

(8). In addition to the use matrix and the activities matrix,
some MU's have special circumstances identified which would require the appli-
cation of special conditions. Most major projects and activities (i.e., MU 6 -
Ocean Shore Airport, MU 12 - Bowerman industrial development) are identified in
the plan through these special conditions.

b. Other Provisions of the Plan

(1). In addition to the overall policy organization, the plan
contains features which provide the ability to anticipate, guide, or meet
future conditions.

(2). An annual and every fifth year review process is included
in the plan. The Task Force evaluates the plan's ability to address circum-
stances that have occurred during the previous period using this review process.
In establishing this procedure, the Task Force recognized that it could not
foresee nor test all possible situations. While the plan represents the best
judgment of the Task Force in achieving a balance for the estuary, only time
and experience can provide the true test of that judgment.

(3). By this review process, amendments to the plan, initiated
either as a result of the Task Force review process or through the request of
an individual, group, or agencies, are possible. In addition to procedural
requirements, the plan establishes three criteria that, if satisfied, could
warrant such an amendment. These criteria specify that (a) any amendment must
be consistent with the overall goal of the plan and with other applicable
general guidelines and policies, (b) the amendment will not cause adverse
effects that cannot be mitigated, and (c) that there are adequate facilities
or services to support the activity or activities specified in the amendment.

(4). At one time, the planning and management framework of the
plan was for a 50-year period which corresponded to the commitment to set
aside 1700 acres of Port of Grays Harbor owned land in MU 12 for this period
of time. Now, however, the commitment is for permanent transfer and therefore,
the timeframe is basically for an indefinite period of time.

2. Plan Implementation

a. In order for the plan to be a useful management tool, each State
and Federal agency will utilize the applicable portions of the plan in imple-
menting its policy, permit review criteria, and procedures; and local govern-
ments through adoption in local Shoreline Master Programs, comprehensive plans,
and zoning designations. Participation by regional or district offices of the
U.S. Army Corps of Engineers, U.S. Environmental Protection Agency, U.S. Fish
and Wildlife Service and the National Marine Fisheries Service will be acknowl-
edged through signed Letters of Intent (L0 I ) in which they will set forth the
role the GHEMP will play in their future decisionmaking on activities consistent
or inconsistent with the plan as well as the nature and degree of their commit-
ment to the plan (see appendix B).

vn

c. Development is directed toward existing developed areas. Heavy
industry focuses around the filled or upland areas of Aberdeen, Hoquiam, and
Cosmopolis with exceptions in the Bowerman industrial area, in the southeast
corner of Aberdeen, and on the shore of the inner harbor. A limited amount of
new fill would be permitted adjacent to the existing industrial areas in
Junction City and Cosmopolis. There would be some expansion to the existing
boat basins for marine commercial uses. Waterfront commercial uses could
locate on the Aberdeen waterfront; intensive residential uses would be permitted
only in limited upland areas along the shoreline in Ocean Shores, Westport,
Old Aberdeen Waterfront and Central Park, with the rest of the shoreline limit-
ed to low intensity agricultural, forest, resource production and residential
uses consistent with existing character and use.

d. The plan permits uses which are already allowable under the
existing local Shoreline Master Programs (e.g., bankline straightening, fill,
erosion control, residential development, etc.), but does so in a manner which
is generally acceptable to all parties on the Task Force by redesignating MU's
and tailoring permissible/conditional uses allowed within those MU's (e.g.
activities such as jetties or groins, which are permitted in urban environments
under the existing SMA's, are not permitted in all urban MU's under GHEMP).

e. The plan will help address the difficult issue of determining cumu-
lative impacts of future projects. By knowing the amount and probable location
of future development, a better evaluation of the full impact of future devel-
opment on the estuary can be made.

4. Alternatives

a. This EIS discusses practical alternatives to the proposed action
including no action (or status quo), various plan provisions which would
provide greater or lesser development, concentrating or dispersing development,
alternate port and industrial site locations, alternatives to specific MU
designations and alternative methods of implementation. In addition, during
the scoping process OCRM received a Citizen's Grays Harbor Estuary Management
Plan as an alternative to the proposed plan for consideration; it is included
under the "Less Development and Greater Resource Protection" section.

b. The alternatives analysis does not extend to considering different
permitted activities and standard uses in individual MU's. The matrixes
identifying these uses were extensively considered by the Task Force members,
and alternatives fully considered but limited or eliminated in part because
of the consensus decisionmaking process. The analysis of overall alternative
provisions of the plan, such as greater or lesser development, is reflected in
general consideration of various use schemes. For purposes of this public
review, uses and activities identified by the plan within specific MU's are
still open for consideration. Those comments will be evaluated; if a signifi-
cant impact not otherwise analyzed is identified, the final PEIS will be ex-
panded to consider that alternative. Additionally, the plan cannot address
all possible alternatives to individual actions so specific alternatives
analyses may be required for specific proposals during permit processing.

C. AREAS OF CONTROVERSY

The GHEMP was developed to solve problems surrounding land and water uses
of the estuary, especially tension between accommodating economic growth which
might require fill of wetlands and assuring the long-term preservation of a

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viable estuarine system. Given the topography of the area surrounding the
estuary, any growth of large-scale activities tends to encroach from the shore-
line into the water since flat, developable upland is limited. Therefore,
almost all proposals for new activities tend to be controversial.

1 . Management Unit 12 - Bowerman Basin

a. The major controversy identified by the Task Force and the scoping
process focuses on the 2200 acres of intertidal and submerged lands owned by
the Port of Grays Harbor (see photo 1). The area is well suited for future
large-scale port expansion given its location next to the navigation channel
and supporting infrastructure and is considered to be the major site for future
industrial development. The area has also been identified as a significant
habitat for wintering and migratory shorebirds and the peregrine falcons which
prey upon the shorebirds. The area is significant because it provides the
birds a certain amount of shelter from approaching storms and is a prodigious
feeding area (during seasonal migration in particular). While much of the
environment has been modified by previous fills and dredged material disposal,
the majority of the environment remains highly productive. The intertidal
areas and fringing marshes are important for benthic invertebrates, some fish
species and other wildlife as well.

b. In initial Task Force discussions, the Port of Grays Harbor pro-
posed that all 2200 acres owned by the Port be designated as an Urban environment
and be available for fill and development. Based on an early appraisal of the
impact of that proposal, such designation was found unacceptable within the
context of long-term protection of the estuary. A subsequent proposal would
have divided the 2200-acre area into two different environments: a 500-acre
Urban Development Special environment (MU 13) and a 1700-acre Conservancy
Managed Special environment (MU 12). The 500 acres were located north of the
airfield and would be available for fill and development under certain condi-
tions regarding future uses. The 1700 acres were located to the west of the
airfield and were to be turned over for co-management by a State/Federal or a
private conservation organization for a period of 50 years. Further contro-
versy ensued over whether the uses which were allowed by the plan in MU 13
were consistent with the 404(b)(1) Guidelines (September 5, 1975 version) and
over new discoveries concerning the importance of the Bowerman Basin to
migratory shorebirds and peregrine falcons.

c. Because the 404(b)(1) Guidelines were in the process of being
revised during the 1978-79 period, further changes to the plan were not made
until everyone knew what the standards of the Guidelines would be. Shortly
thereafter, Section 7 consultation under the Endangered Species Act was initi-
ated by the 0CRM with the U.S. Fish and Wildlife Service concerning the impact
of the fill in the Bowerman Basin as proposed in 1978. The F&WS made a deter-
mination that the configuration of the 500 acre fill may jeopardize the contin-
ued existence of the American peregrine falcon (spp. anatum) with the potential
of a non-jeopardy opinion if protective measures would be implemented. With
the suggestions of nonmember conservation groups, the Task Force developed a
substitute proposal with conditions and configurations for development and
preservation which are included in the April 1982 draft of the plan. Those
conditions include permanent transfer of submerged and submersible lands owned
by the Port of Grays Harbor to the Washington State Department of Game, reestab-
lishment of vegetated salt marshes and woody vegetation, reestablishment of

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perching sites for birds, containment structures and others (see GHEMP, MU 12,
pp 60-67 for further details). It should be pointed out that the commitment
for fill and the evaluations extend only to Areas 2 and 3 in MU 12 and that
Area 4 (243 acres) fill will be assessed independently at the time' of a fill
proposal; however, filling of an additional 243 acres is considered to be
within the original balance of the plan.

d. It is believed that MU 12 can now comply with the 404(b)(1) Guide-
lines at a planning level (full evaluation can not be completed until the time
a specific permit application is received), and that further controversy be-
tween representatives of the Task Force has been minimized. MU 12 (MU 13
was deleted and combined with MU 12) clearly represents compromises between
preservation and development and attempts to achieve a balance between the
two. The compromises, however, will not satisfy certain groups which believe
the area is extremely critical to the bird population and that no further fill
should be permitted in the area.

2. Estuary Protection

a. Several groups have commented that while future port expansion
may take place, protection for the natural estuarine resources is not commen-
surate. Although permanent protection is afforded the 1700 acres in MU 12 (if
the 500 acres are filled), these groups observe that the amendment process
could allow changes to be made to the estuary's other Natural and Conservancy
environments. Some more permanent form of protection of the estuary is the
preferred goal of these groups to limit any further expansion into North and
South Bays.

b. Other resource protection conflicts which have arisen during the
course of the planning process include:

(1). Bankline straightening - proposed mainly for urban develop-
ment areas, some see it as a positive, strategic move to be more efficient
with development in the urban areas whereas others see it as a source for
more aquatic habitat losses.

(2). Chehalis River - problems associated with aggregate resources
extraction during the salmon runs.

(3). Chehalis Floodplain (MU's 18-25) - a transition area between
estuary and upstream area which stores a great deal of water and is ecologically
significant. MU's 18, 19, 24 and 25 have special conditions placed on future
uses to protect the important resource areas.

(4). Westport Marina and Airport expansion into adjacent wetlands.

(5). Ocean Shores Airport and the issue of water dependency and
adequate mitigation.

(6). MU 26 - Freshwater wetlands owned by the Port of Grays
Harbor on the south side have been designated as an appropriate site for future
industrial development, and so anticipates filling of the wetlands at some
future date. The Port has applied for a Section 404 permit from the Corps and
an analysis of impacts and an EIS are being prepared for the specific action.

xn

During the planning process, controversy had arisen over the marsh adjacent to
the shoreline, buffer zones needed to protect two creeks which flow through
the property, and the interim use of this area for dredged material disposal.

(7). Protection of the "fish base" and the "fish passage" in a
complex urban boundary setting.

(8). Log rafting and avoidance of log grounding.

(9). Wood waste and other solid waste disposal in the estuarine
environment.

(10). Bowerman Airport relocation - upland vs. estuarine site.

3. Adequacy of the Planning Process

Several individuals have criticized the planning process as inhibiting
citizen input at the early stages of the process and suggested that a DEIS
should have been prepared at a much earlier time. It is their feeling that
the Task Force should have contained members from the non-governmental environ-
mental community, and that their comments throughout the process have not been
adequately taken into consideration.

D. ISSUES TO BE RESOLVED

1. Throughout the development of the draft GHEMP, numerous issues were
brought up and resolved through the consensus and mediation process, particu-
larly issues dealing with individual projects and activities such as airport
and marina locations, the protection of the "fish base," bird habitat, etc.
The mediation process was necessary at times to help settle the disputes be-
tween development and preservation interests through compromise. While basic
differences in goals are not necessarily resolved, they have been accommodated
in the overall- goal of balanced estuary-wide management. Consequently, the
objectives of preservation vs. development have been reconciled in a multiple-
use plan which specifies uses on a MU by MU basis and places special conditions
on future actions to protect the significant natural resource val ues. No major,
outstanding issues to be resolved by the Task Force members are identified at
this time.

2. However, a coalition of public interest groups has submitted an alter-
native which is called the Citizen's Grays Harbor Estuary Management Plan as a
distinct alternative to some of the provisions of GHEMP which they would like
to have evaluated and adopted by the Task Force. This proposal is discussed
under the "Lesser Development-Greater Protection" alternative (p. 11-21). The
Citizen's Estuary Plan rejects any fill in MU 12 and the 20 acre site in MU 14,
requires the relocation of the three airports (Bowerman, Westport and Ocean
Shores), and rejects the expansion of the Westport Marina and filling of the
95-acre site in the South Industrial area (MU 26). Further, this plan would
recommend using Section 404 (c) authority under the Clean Water Act to prohibit
the discharge of dredged or fill materials in 25 of the 43 MU's in an effort to
provide more permanent protection. It would allow water dependent development
in areas currently deemed unutilized (293 acres), the Bowerman Peninsula
(approx. 200 acres) and 250 acres of fill elsewhere in the estuary. It
calls for the establishment of a Citizen's Advisory Committee which would have
oversight responsibilities to ensure that available areas were developed to
their satisfaction prior to allowing any further fill.

xm

3. While many of these issues have been discussed during Task Force
deliberations, they should now be formally accepted or rejected (in whole or
in part) by the Task Force as a viable alternative since this is part of the
official review process.

E. MAJOR CONCLUSIONS

1 . Need for the GHEMP

There is a distinct need to update and revise the current local Shore-
line Master Programs in order to assure areas for critical development and
preserve habitat from long-term cumulative degradation by small projects.
Likewise, for the sake of those proposing to use the estuary, the intergovern-
mental decisionmaking process must be improved to provide predictable reactions
by all regulating and commenting agencies. Future project consistency with
the GHEMP will provide greater assurance of conforming with applicable State
and Federal management requirements and expeditious action on proposals.

2. Benefits

a. Adoption of the GHEMP will provide both short and long-term social,
economic and environmental benefits. The plan allows for the following: future
large-scale port and industrial development next to the navigation channel
which will provide greater regional economic benefits; expansion of the Westport
Marina; expansion and improvement of the Westport Airport; construction of an
airport at Ocean Shores; the modification of port slips; and improvements
made to portions of the older urban waterfronts. The plan calls for providing
greater recreation opportunities in certain areas around and within the estuary.
It provides better protection for the Hoquiam-Aberdeen Fish Passage, most of
the saltwater marshes and eel grass beds, and it will provide permanent protec-
tion to a minimum of 1700 acres of important intertidal wetlands currently
owned by the Port of Grays Harbor. In addition, the plan includes mitigation
requirements and will provide further codification of the local SMP's.

b. Administratively, the plan if adopted should make permit process-
ing considerably easier and with fewer incidents requiring conflict resolution.
Some of this may be due to the relationships established by the Task Force
members as they cooperatively worked to understand the complex issues of devel-
opment vs. preservation and work out their differences. However, the plan is
not designed to solve all future problems since there are many issues which
surround the siting of facilities besides wetlands fill; thus the reason for the
necessary case-by-case review of any particular project. The Task Force has
nevertheless taken many other factors into account prior to considering the
amount of fill which might be required in the future, including available energy
and water supply, wastewater treatment capability, commitment to maintaining
and possibly widening and deepening the navigation channel to accommodate
large deep-draft vessels, space requirements, etc.

c. From a planning and management perspective, the GHEMP would effec-
tively place limits on future growth in the estuary requiring further fill. The
plan would accommodate future projected demand and expectations for several gen-
erations to come, but once the area west of the Bowerman Peninsula is utilized
and the 1700 acres in MU 12, Area 1, have been turned over to the Washington
Department of Game, no further expansion along the navigation channel will be

xiv

feasible. This therefore provides an end point to westward industrial expan-
sion along the navigation channel and a framework upon which future decisions
can be made. This is a significant concession from the Port of Grays Harbor.
While the Port gains a (planning) commitment to utilize certain wetlands for
future port/ industrial expansion (which they might or might not achieve in
the absence of the GHEMP), the Port also gives up a potential future develop-
ment option of considerable significance.

d. Additional benefits of the planning process and plan include the
resolution of many planning decisions on potential development proposals
which occurred during the planning period prior to the receipt of an actual
permit application. The Task Force, along with the considerable assistance of
the public and noted experts in the field of ornithology, were able to identify
the importance and significance of the Bowerman Basin as (particularly) shore-
bird and raptorial habitat. This may be one of the first instances where consul-
tation under the Endangered Species Act has provided a plan which would give
permanent protection to a majority of a particular habitat utilized by the
American peregrine falcon and its prey species of dunlin, sandpipers, and other
shorebirds; require monitoring of impacts during phased filling and enhancement
of habitat; and allow future development in a portion of the habitat. All
this was done years prior to the request or issuance of a permit. Special area
management planning has in this case provided increased attention to habitat
preservation for an endangered species in a manner which to date has not delayed
individual permit projects or development plans.

3. Impacts

a. When and if development occurs in the Mil's which allow or may
allow development (through conditional use or special conditions), a number of
shoreline and estuarine alterations will take place having both short- and long-
term impacts. Depending on the type of development, those impacts would include
effects associated with the filling of aquatic areas, including the loss of
primary productivity, invertebrate production, and fish and wildlife habitat;
reduction of the water surface; and other effects associated with physical,
chemical and biological changes to the environment.

b. MU 12.

(1). The most significant adverse impacts would occur in MU 12,
which allows for the phased development of 164 acres of intertidal mudflats
and wetlands; 73 acres of mudflats and marshes; and under a more long-term
scenario, the addition of 243 acres of submerged and intertidal areas. These
intertidal mudflats and marshes contain significant habitat for wintering
populations of shorebirds and for the spring and fall migration populations
which use the habitat for short but intensive periods of time. This area also
produces invertebrates which are food for anadroumous fish and shellfish.

(2). During filling operations the bird populations that frequent
the off-shore and near-shore areas around the Bowerman Peninsula will be dis-
placed or confined more closely to the adjacent habitat, with the potential for
some mortality of birds because of the reduction of habitat (especially during
long winter storms or migration flights). Monitoring, mitigation and enhance-
ment projects could help minimize the probability of bird mortality. While
total bird mortality cannot be predicted with any degree of accuracy, it can be

xv

presumed to occur because of the loss of feeding habitat in particular, and
roosting habitat to a lesser degree.

(3). The plan gives clear recognition of the importance of the
habitat to shorebirds and peregrines, but allows some development with mitiga-
tion in this area. However, some bird experts who have studied the area feel
that any filling done in the area of the Bowerman Basin (and even industrial
development on the Bowerman Airfield) will produce unacceptable levels of impact
on the shorebird population, that the area has international significance and
should be designated as a bird sanctuary. For more on this discussion, see
appendix 3.

(4). It is the conclusion of this PDEIS, based on the findings
and conclusions of the U.S. Fish and Wildlife Service which were rendered
during Section 7 consultation, that the impacts associated with MU 12 implemen-
tation would not have an unacceptable adverse impact on either the shorebird
(prey) species or the endangered American peregrine falcon (predator). This
assessment holds only if the current provisions of the plan are implemented and
the conditions issued by the F&WS are implemented in the future.

(5). This is not to minimize the importance of the shorebird habi-
tat (particularly Areas 2 and 3) which would be altered by development. As
stated in the plan and consistent with existing regulatory practices, any new
information which may be advanced either prior to or during the permit process
stage or during development will be taken into consideration at that time. The
purpose of the plan is to provide guidance based upon the best available infor-
mation while balancing the factors of economic development and environmental
protection. It is not an actual permit request. All interested and concerned
parties who now know that the identified areas may be developed in the future
should continue to work jointly in further defining and evaluating the conse-
quences of the action, and in conducting monitoring, mitigation and enhancement
to the extent feasible before and after any filling operations. To the extent
that OCRM has financial resources available in the future, we will encourage
and assist these efforts through the WDOE. It is also the conclusion of this
environmental analysis that any remaining reasonable and prudent alternatives
and conservation measures which have been identified by the U.S. F&WS during
Section 7 consultation be incorporated into the plan if appropriate or in any
future permit requests to modify MU 12. This can best be accomplished by the
Port of Grays Harbor, the U.S. F&WS, the U.S. Army Corps of Engineers and the
Washington State Department of Game.

c. GHEMP's multiple use goal and the associated designated uses will
perpetuate the use of the estuary as a major port and industrial area which
will require continuous maintenance dredging, potential channel realignments,
widening and deepening, etc. The impacts associated with these activities have
been extensively researched and addressed by the Army Corps of Engineers.!
Long-term implications are that the estuary will continue to be subject to
modifications for navigation purposes (i.e., as opposed to the decision not to
maintain the Willapa Bay Navigation Channel).

TI U.S. Army Corps 67 Engineers, Maintenance Dredging and the Environment
of Grays Harbor, Washington, Seattle, 1977 (15 Volumes).
U.S. Army Corps of Engineers, Grays Harbor, Chehalis and Hoquiam Rivers,
Washington Channel Improvements for Navigation, Interim Feasibility Report
and FEIS, Seattle, 1982.

xv i

4. NEPA Requirements

The OCRM, as well as the cooperating agencies, is well aware of both
the desirability and requirement of distributing a DEIS as early in the decision-
making process as practicable - when sufficient information is available to
analyze the options and when the decision to act is yet to be made. This PDEIS
satisfies those conditions. The April 1982 draft version of the GHEMP is the
first draft to which the Task Force has given conceptual but not full approval.
The document remains subject to modification based upon further public review
as clearly identified in the planning process. No action has been taken to
approve the plan officially by either the Task Force members or in this case
the actual decisionmakers (i.e., local governments, the WDOE or any Federal
agency representatives). While the Task Force had to make decisions and come
to consensus on other controversial management issues, it should be remembered
that these decisions were not made in a void. The Task Force had considerable
resource data available while deliberating on the policies and management
issues, and any permits which were issued during 1977 to the present time have
been done in accordance with regular procedures for permit processing. OCRM
believes that strategically, this is the best time to issue the EIS, as it will
serve well the goal of being a full-disclosure document in which the public and
the decisionmakers can understand the impacts associated with plan implementa-
tion and the options which are available.

5. Citizen Participation

a. OCRM has studied the complaint that there has been insufficient
citizen participation in the development of the GHEMP and that the provisions
of the CZMA and the WSMA have not been met. OCRM concludes that the actions
taken by the Task Force in developing the GHEMP have included adequate public
participation efforts and that the public interest has both been substantially
expressed and served as summarized below.

(1). The Task Force consists of fourteen individuals representing
affected local governments, the Port of Grays Harbor which is a special purpose
unit of local government, and State and Federal agencies. The local government
officials represent the public in development and environmental matters. The
State and Federal agency officials represent the public interest in environ-
mental matters including resource management and protection. While specific
industry and environmental interest groups did not hold voting memebership on
the Task Force, public input from such interests was substantial. The consul-
tants to the Task Force held meetings with a number of environmental interest
groups as did various individual members of the Task Force.

(2). Sixty-eight extensive interviews were conducted with a
diverse group of individuals representing all facets of interests in the es-
tuary during the data collection phase. Various media were used to describe
the GHEMP and solicit input. A public hearing as well as public meetings
were held and numerous modifications to the various versions of the GHEMP have
been made in response to that input. The Task Force clearly intended that at
least two drafts of the plan be subjected to full-scale public review prior to
agency adoption.

XVI 1

b. There are many different methods which can satisfy the requirement
to include meaningful participation. Some of these are being used in other
parts of the country in developing special area management plans and other forms
of comprehensive coastal management plans. Any one form designed to allow full
participation may be subject to criticism from an individual (s) or organiza-
tion^). While no one form of public participation is dictated by law, the
minimum requirements under the CZMA include the following: making general
information available regarding the program's design, its content and its
status throughout program development; providing a list of affected individuals
or organizations and indicating the nature of major comments received and the
nature of response to the comments; holding public meetings, etc., at accessible
locations with reasonable notice and availability of materials; and holding pub-
lic hearings with 30 days notice (15 CFR Part 923.55-58, FEDERAL REGISTER, Vol.
44, No. 61, Wednesday, March 28, 1979, pp. 18610-18612).

c. Neither OCRM nor the WDOE are in a position of endorsing one form
of citizen participation over another when it is the option of local governments
or State agencies and as long as minimum requirements outlined in regulations
are met. While the citizens' participation process designed and utilized in
the GHEMP has legitimacy, that is not to say that it could not have been done
in a different way. Perhaps most importantly, if citizens and interest groups
are not satisfied with the outcome of a collaborative planning process, opposi-
tion to permit applications or proposed projects in the planning area is likely
to impair the usefulness of the plan.

F. FUTURE ACTIONS

1. A public hearing will be held on this PDEIS in Grays Harbor County to
solicit public comments on the draft plan and impact statement. The Task Force
will review and consider these comments prior to adopting a final plan for
submission to the local governments and Federal agency officials. The PFEIS
will be based on this final version of the GHEMP.

2. Once this PFEIS has been distributed, local governments will hold
additional hearings on the plan in accordance with local regulations. Based
upon the results of the hearings, local governments may or may not adopt the
provisions of the plan or make revisions to the plan accordingly.

3. If adopted, local governments will in turn submit their SMP's to the
WDOE for State adoption. The WDOE will also hold a formal hearing on the adop-
tion of the GHEMP as State regulations and as an amendment to the approved
WCZMP. If significant substantive changes are made to the GHEMP by the local
governments, OCRM would issue a supplemental EIS prior to making final "Find-
ings of Approvability" and will publish notice in the FEDERAL REGISTER that
the provisions of the GHEMP have been amended into the WCZMP. Following such
notice, any specific provisions identified in the Federal agency LOI will
become effective as do the Federal consistency provisions of the CZMA.

xvm

PART I: PURPOSE AND NEED

PART I: PURPOSE AND NEED

A. GENERAL

1. The GHEMP is designed as a tool to assist Federal, State and local
government management agencies to guide the future development and conservation
of the Grays Harbor Estuary, including specific project regulatory decisions
that are made on a case-by-case basis. The full realization and use of this
management tool will require normal regulatory and management decisions of
Federal, State and local agencies and elected officials to be consistent with
the plan. Not only will Federal and State agencies and local governments be
expected to deny project proposals inconsistent with the approved GHEMP, as
required by Section 307 of the Coastal Zone Management Act and by the Shoreline
Management Act, but they will be expected to approve expeditiously those project
proposals that are consistent with the approved plan, so long as Federal and
State regulatory criteria not addressed fully by the plan are met. GHEMP, pp.
4-6, explains more fully how the plan relates to the regulatory processes.

2. GHEMP is a form of special area management planning which is becoming
more and more popular in coastal states as a mechanism to harmonize economic
development with crucial environmental regulations. The majority of these con-
flicts are taking place along the shorelines where encroachment into the aquat-
ic environment is the major issue of concern. Most of the newer environmental
laws and regulations encourage or require Federal agencies to coordinate and
cooperate with other entities including State and local governments to plan
comprehensively for the resources of given areas in order to minimize or avoid
these conflicts over resource use and protection. GHEMP does satisfy these
existing statutes to coordinate and consistency with these laws and regula-
tions is discussed in Part V of this environmental impact statement (EIS).

B. PROGRAM EIS

1. The proposed action described in this environmental document is the
incorporation of a final plan as an amendment to the WCZMP and approval of the
GHEMP by a variety of Federal, State and local government agencies. This EIS
is also intended to satisfy the requirements of the Washington State Environmen-
tal Policy Act of 1971 (SEPA) for local government and State agency adoption
of the GHEMP, in accordance with SEPA Guidelines (WAC 197-10-650) which allow
for an adequate Federal EIS prepared pursuant to NEPA to be utilized in lieu
of a State EIS prepared under SEPA. This jointly prepared EIS is also consis-
tent with the Council on Environmental Quality regulations (§1506.2, 40 CFR
Parts 1500-1508) encouraging cooperation between Federal, State and local
agencies in planning and environmental assessments to avoid duplication between
NEPA and comparable State and local authorities.

2. Since GHEMP is a comprehensive land and water use plan intended to
guide future actions in the estuary and adjacent shorelines, this EIS will
serve as a program EIS (PEIS) because of the broad actions which it envisions
for a specific geographic area. Federal and State agencies (and local govern-
ments under SEPA) are encouraged to tier future EIS's and environmental assess-
ments (EA's) to this PEIS for future actions which are consistent with the
plan in order to eliminate repetitive discussions. This is consistent with

1-1

the NEPA Guidelines (§1502.4, 1502.20) and SEPA Guidelines (WAC 197-10-660 (1 ) (a)
and (3)). Information on proposed actions, alternatives and impacts that are
discussed adequately in the PEIS and the GHEMP will, in some cases, satisfy
the NEPA and SEPA requirements for future project proposals, and, in other
cases, those proposals will need to be supplemented in GHEMP and the PEIS with
more detailed information and analyses. However, where the information on
specific proposals is considered to be adequate by the permitting agencies and
where information and conditions have not substantially changed, the policies
and decisions of agencies are expected to be consistent with the GHEMP.

C. NATURE OF THE ACTION

1. This PEIS serves to describe and evaluate several proposed actions,
including:

a. Substantial changes to approved local Shoreline Master Programs
(SMP's),

b. Substantial change to the Washington Coastal Zone Management
Program (WCZMP) resulting from the local SMP changes, and State
agency commitments to the GHEMP,

c. Federal approval of these changes as an amendment to the WCZMP,
by the Assistant Administrator for Ocean Services and Coastal Zone
Management, N0AA,

d. Federal commitments to the provisions of the GHEMP and local
SMP changes, through the following actions:

(1). Letters of Intent signed by regional representatives of the
Corps of Engineers, Environmental Protection Agency, Fish &
Wildlife Service and National Marine Fisheries Service.

(2). Advanced identification of areas suitable and unsuitable
for dredge spoil disposal pursuant to Part 230.80 of the
404(b)(1) Guidelines (see alternatives discus-
sion), and

(3). Use of the PEIS as a guide to or part of subsequent project
specific environmental analysis for significant Federal,
State or local actions under NEPA and SEPA.

2. The following text discusses each of these proposed actions in more
detail :

1-2

a. Changes to approved local SMP's for Hoquiam, Aberdeen, Westport,
Ocean Shores, ~Cosmopol is and Grays Harbor County"

(1). The GHEMP represents in some instances a substantial change
in the local SMP's previously approved by the Washington DOE, and incorporated
as a part of the WCZMP prior to its approval in June 1976.

(2). Under normal circumstances, modifications to local SMP's
under the SMA would not be considered as amendments to the WCZMP and require
an EIS. However, because there are some substantial changes to the SMP's and
the GHEMP has been the subject of nationwide interest as an example of special
area management planning for an area of particular concern involving active
participation and commitment of numerous Federal , State and local agencies and
the public, the plan is being reviewed as an amendment and an EIS is being
prepared. The DOE has asked OCRM to prepare an EIS on the amendment to the
WCZMP in anticipation of future approval and because this advance action would
allow the combination of NEPA and SEPA documents. An official State request
to approve the amendment will be presented to OCZM after the adoption of the
plan by local governments but prior to or concurrent with approval by DOE of
the revised local SMP's.

(3). This PDEIS, therefore, prepares the groundwork for future
decisions regarding approval of the State amendment by the Assistant Adminis-
trator and appropriate officals of the cooperating agencies. The review of the
submitted amendment will include a final review of any changes which may be
made by local governments during their review and approval process, and any
changes the State may make.

b. Amendment to the Washington Coastal Zone Management Program

(1). This action is related to the previous one. The WCZMP
identifies Grays Harbor as an "area of particular concern." In addition, the
area is also identified as a "shoreline of statewide significance" under the
SMA. The WCZMP states: "To assure continued productivity, a balance between
filling of intertidal areas and the preservation of wetlands must be main-
tained. Since the filling of lowlands has provided the only flatland available
for industry and commerce in the area, pressures to fill are not uncommon."
(WCZMP, June 1979, p. 19). GHEMP represents what the Task Force considers
that balance to be. Four State agencies participated in the planning process
and provided their expertise to the land and water use designations which were
made. GHEMP will guide State agency actions and decisions in the future so a
commitment to the plan and its implementation represents a substantial change
to the WCZMP. The plan itself will be amended into the program as a policy
and management program for an area of particular concern which will be imple-
mented through the changes made to local SMP's.

c. Approval by the Assistant Administrator as an amendment to the
WCZMP

(1). The OCRM has funded major portions of the development of
the GHEMP through Section 306 funds of the CZMA which were provided to the
Washington DOE, which in turn funded the GHRPC to assist the local governments

1-3

in revising their local SMP's. The purpose was to address the problems associ-
ated with an identified "area of particular concern."

(2). It is proposed that the Assistant Administrator approve
GHEMP as an amendment to the WCZMP under § 306(g) of the CZMA. § 923.80(c) of
OCRM regulations states in part:

amendments are defined as substantial changes to enforceable
policies or authorities related to... (2) uses subject to the
management program; and (3) criteria or procedures for designating
or managing areas of particular concern or areas for preserva-
tion or restoration. (Part 923 - Coastal Zone Management Program
Development and Approval Regulations, FED. REG., Vol. 44, No. 61,
Wed., March 28, 1979).

(3). The GHEMP is a unique management tool (See Part III: Pro-
posed Action) which requires not only actions to be taken by the State and
local governments pursuant to the SMA, but also Federal agency commitments to
the plan. One action without the other would not make GHEMP the useful tool
envisioned. Because the proposed action will both amend the WCZMP and be used
by Federal agencies to review permits, OCRM is serving as the lead agency in
the preparation of the PEIS and other Federal agencies are serving as coopera-
ting agencies. All decisions will therefore be made from a common assessment
of the proposed action.

d. Federal Agency Commitments

(1). The action taken by the Environmental Protection Agency
(EPA), the U.S. Army Corps of Engineers (Corps), the U.S. Fish and Wildlife
Service (F&WS) and the National Marine Fisheries Service (NMFS) has consisted
of providing substantive technical assistance in the development of the plan.
Recognition of this assistance is expressed through Letters of Intent (LOI -
see appendix B). Representatives from these agencies have been involved in
the planning process for more than seven years. They have participated in
data collection and review, development of proposals for various MU's, and
provided comments on their agency guidelines or standards. In some cases,
representatives from both the regional and headquarters offices have been
involved in preliminary plan negotiations. (The Corps was not involved in
plan negotiations and provided technical assistance only). Because of the
positive effort made by the agencies in the planning process which involved
consensus decisionmaking, the plan will be legitimately entitled to a sub-
stantial measure of favorable recognition during plan implementation. This is
provided for in EPA's 404(b)(1) Guidelines (§230. 10(a) (5)) and by the Fish and
Wildlife Coordination Act.

(2). The LOI, expresses each agency's recognition of the plan,
its participation in the planning process, and its commitment to utilize the
plan in future permit decisionmaking when appropriate. Some LOI are more
detailed than others at this stage.

(3). Federal agency involvement in the planning process, whether
it is through Task Force membership or serving solely in a technical assistance
capacity (Corps), is expected to bring benefits to all parties concerned. The

1-4

agencies are in a position to use the plan in their decisionmaking process on
the resources and permits which they regulate or comment on. Because of direct
participation in the development of the plan, the agencies are generally confi-
dent that it meets the standards and criteria which they are obligated to
enforce. Adoption of the plan will therefore expedite permit reviews and
approval, especially for some of the larger and more controversial proposals.
However, as stated in the plan (GHEMP, p. 5), the plan does not bypass the
Corps permitting process, nor any of the §404 (b) (1 ) criteria used in consider-
ing a permit. The plan has advanced consideration of these issues and has
reviewed some in great detail in the plan itself.

(4). The most common form of a Federal agency response to the
plan will take place when applicants request a permit under Section 404 of the
Clean Water Act (which is often combined with a Section 10 permit request
under the 1899 Rivers and Harbors Act). The final plan along with the FPEIS
on the plan are intended to respond to some of the more general requirements of
the Section 404 permit. The extent to which the plan addresses these require-
ments varies. These requirements include:

o need - which relates to water dependency and need for a project,
o alternative site availability in non-wetland areas, and
o the acceptability of impacts on the aquatic ecosystem.

(5). The plan and the data supporting it will provide an estuary-
wide look at these issues. In the case of certain management units, detailed
data and analysis have occurred on one or more of the issues which the 404
Guidelines address such as the Ocean Shores Airport, Westport Airport and
Marina, and Mil's 12, 18, and 26. For those units, the plan will provide essen-
tial information for agency review. Unless new and significant data are avail-
able, the plan's conclusions on the issues of need, alternatives and impacts
will be presumed correct. The strength of the presumption will vary depending
on the degree of analysis which has been completed for a given MU. All §10/404
permit applications must provide the project-specific and site-specific details
for a final decision regarding these tests.

(6). Generally, "permitted" activities and uses authorized under
the plan are those which are most likely to meet Federal permit criteria.
"Conditional" permitted activities are those which will likely meet Federal
permit criteria only if special care is taken to avoid negative environmental
impacts through specific project/site conditions. "Special condition" activi-
ties are allowed by the plan only if they incorporate the special conditions
listed in the plan which were designed to reflect the unique characteristics
and needs of each MU. The special conditions were developed with reference to
Federal permit criteria whenever practicable and reflect an evaluation of
acceptable (or unacceptable) impact on the aquatic ecosystem. Those activities
which are not authorized by the plan and are depicted by blanks, will generally
result in a negative recommendation (see appendix B, NMFS L0I).

(7). Finally, and in general, the plan will be considered by the
Corps in the public interest review it undertakes for each Section 10 and 404
permit as well as other permits. The plan's concepts, policies, and procedures
can form a primary basis for the Corps review of such issues as conservation,
economics, wetlands, navigation, fish and wildlife values, etc. (33 CFR 325.3
(b)), which are evaluated in the public interest review. In the absence of
substantial new and countervailing evidence, permits will conform with the plan.

1-5

(8). There are two additional (potential) ways an agency may
respond in addition to issuing or commenting on individual permit requests.

(a). The first method, which is identified in the plan, is
for the advanced identification of areas for disposal or non-disposal of dredge
or fill material under 40 CFR, Part 230.80, Guidelines for Specification of
Disposal Sites for Dredged or Fill Material. While advanced identification has
never been implemented by the EPA and the Corps, the plan envisions the
permanent protection of Area 1 in MU 12 (1700 acres) through transfer of fee
title of Port of Grays Harbor lands to the Washington State Department of Game
and by requesting predesignation of this area as one where disposal of dredged
or fill material is prohibited with the possible exception of small habitat
enhancement projects. Likewise, the plan calls for the advanced identification
of Area 2 in MU 12 (164 acres) as an area for the discharge of dredged or
fill material for water-dependent industrial development subject to permit
approval .

(b). The second method which may simplify permit processing
by utilizing the plan, is for the Corps of Engineers to issue a §10/404 General
Permit (aka Regional Permit) under 40 CFR, Part 230.7 for certain activities
which are identified in the plan and meet the criteria for General Permits. A
General Permit is not an essential element to implement the GHEMP but could
help achieve the objectives of simplifying the permit process. The criteria
for General Permits require that they be activities which are substantially
similar in nature, cause only minimal adverse environmental impact when per-
formed separately, and will have only a minor adverse cumulative effect on
the quality of the human environment.

D. NEED FOR THE GRAYS HARBOR ESTUARY MANAGEMENT PLAN

1. General. As we have increased the protection of valuable coastal
resources during the past two decades, our regulatory system has become more
complex. Although most coastal development proposals are approved without
undue problems, in coastal areas where complex natural resource and economic
development issues must be balanced within limited geographic boundaries, the
system of case-by-case review by multiple agencies at times leads to delays,
protracted disputes, loss of valuable habitats and considerable uncertainty for
applicants, agencies, and interested citizens. Problems arise as a result of
applying inconsistent or single-purpose, competing policies among government
agencies, lack of guidance to applicants and others about agency policies that
will be applicable to specific permitting decisions, inability to address
issues of cumulative impact, excessive costs to applicants and the public, and
real and perceived misuses of case-by-case permit review procedures. Problems
also arise when development interests fail to consider natural values early in
project planning, especially in areas where local plans and zoning ordinances

do not require such consideration J

N0AA, The Federal Coastal Programs Review - A Report to the President,
January 1981 , p. 238.

1-6

2. Grays Harbor Estuary

a. The Grays Harbor Estuary includes 62,000 acres of water, tidal
marsh and partially developed shoreline, and is Washington State's largest
port outside of Puget Sound. It is one of the few large coastal bays and
estuaries on the west coast; it supports more than 50 species of fish, large
populations of clams, oysters and crabs, and 325 species of birds. The econo-
mies of six cities and towns depend upon shorefront industries such as ports,
timber processing, fishing and recreational boating. A 23-mile navigation
channel requires periodic maintenance dredging by the Corps which historically
has supplied much of the shoreline fill upon which large parts of the communi-
ties and industries have been built.

b. Since the beginning of the century, the towns of Aberdeen, Hoquiam,
Cosmopolis, and Montesano have been exporting wood products from facilities
located on land created by dredged material deposited in marshes and intertidal
mudflats. Between 1940 and 1976, maintenance dredging disposal involved alter-
ation of about 3,850 acres of aquatic habitat or an average of more than 100
acres per year. This represents 11.5 percent of the total intertidal lands in
the estuary and the loss of an estimated 1,540 acres of vegetated wetlands.
Since 1975, an additional 69 acres of wetlands have been converted to uplandsJ

c. The 1 9 70 ' s have thus been a transition period in which the rate of
altering wetlands has decreased by an order of magnitude from approximately 100
acres per year to 10 acres per year due mainly to the new environmental and
institutional constraints placed on development during the last 15 years and
the Corps shifting of maintenance dredge disposal from shorelines to open water
sites. The other major factor in the decrease is the depressed market economy
since the 1973-74 OPEC oil embargo which has affected the demand for additional
port/industrial space. From an environmental protection point of view, the
substantial decrease in altered wetlands may be considered a success story,
but the transition period has not been without cost in other areas.

3. History of Conflicts. Several articles have been written describing
the events which led up to the need to develop the GHEMP. Some of the articles
are included in appendix D for the benefit of those who are interested in its
history. The following section will only briefly outline the events which
showed the necessity for the various agencies and organizations involved to
sit down together and attempt to resolve the conflicts which were or would be
generated between the requests to fill wetlands and the various constraints
which are placed on such fills.

a. In 1974, the GHRPC, together with the local communities around the
estuary, prepared local SMP's that were adopted by the WD0E in 1975 under the
SMA. However, even though the local programs involved broad citizen and agency
participation, they were unable to resolve major interagency conflicts. Federal
resource agencies claimed that the SMP's were prepared without adequate re-
source information, provided inadequate guidance for aquatic activities, and
was too general. The Port of Grays Harbor and some local units of government
felt that the SMP's unduly restricted development because among other things,
it designated 2,100 acres of Port-owned tidelands and wetlands as conservancy

V. Corps of Engineers, Long-Range Maintenance Dredging Program - Grays Harbor
Chehalis River Navigation Project, 0&M FFT5S Ml T, Oct: W, Seattle,
and personal communication.

1-7

areas.' In addition, the local SMP's were not consistent with approved Economic
Development Plans and local zoning ordinances and regulations. For example,
certain wetlands are zoned for heavy industry, while in the SMP's they may be
included in a Conservancy environment designation.

b. Conflicts over development proposals by the Port to fill 39 acres
of wetlands (of a 45 acre site) at the mouth of the Hoquiam River for first the
construction of a lumber mill site and later for the Kaiser Steel Company to
assemble offshore drilling platforms; a proposed waterfront motel and restaurant
in the City of Aberdeen; and a proposed Boise-Cascade Corporation sawmill re-
quiring fill, involved local, State and Federal agencies in controversies and
permit delays lasting up to two years. The permits were nevertheless issued
and the wetlands filled. The Kaiser and Thunderbird Motel sites have not yet
been developed (see appendix D, pp. D-17 thru D-22 for further details).

c. The confrontation over these projects frustrated the interests of
all parties in the decision process. The Port's development plans were stymied
by State and Federal agency opposition to the Corps permits. Local government
decisions were overturned by State agencies, blocking development plans in
areas designated "Urban" in the State-approved local SMP's. State and Federal
resource agencies were subject to intense political pressures from elected
officials at all levels over specific permits and from environmental interest
groups trying to stop further filling of the estuary. Congressional office
support was taxed by repeated pleas from constituents on each project. In
general , the local and private interests were frustrated by their inability to
predict the outcome of public decisions, or understand the criteria or standards
by which these decisions were being made.

d. With the encouragement of Senator Henry Jackson, the F&WS and the
NMFS urged that a more specific plan be prepared that could address the cumula-
tive effects of future development proposals. The agencies indicated that
they would recommend rejection of all subsequent development proposals in the
estuary until all parties had developed an overall plan for the estuary. The
Port of Grays Harbor also urged the development of such a plan, because 2,200
acres of port-owned tidal lands were directly affected. The situation was
ripe for more effective collaborative planning involving all parties to these
disputes. GHEMP was a concept advanced to provide a consistent bridge between
economic development and environmental concerns.

e. As part of its Coastal Zone Managment Program approved in 1976,
the WDOE designated the estuary as an area of particular concern and funded
the GHRPC to establish a collaborative intergovernmental planning process.
Each unit of local government, State agency and Federal agency with legal
jurisdiction over the use of the estuary was brought together to form the
Estuary Planning Task Force in the Fall of 1976. The purpose of the Task
Force is to serve as an advisory body to the local governments. Even though
7 1/2 years have passed, many of the members serving on the Task Force today are
original members.

1. NOAA, Federal Coastal Programs Review, p. 270

1-8

4. The Grays Harbor Estuary Management Plan

a. What is it?

o A comprehensive land and water use management plan for the
estuary and surrounding shoreline.

o A revision of the Grays Harbor County Local Master Program and
individual local SMP's.

o Its planning period is long-term (indefinite) and gives official
recognition that there are limits to the amount of fill which
the estuary can sustain without unacceptable adverse impacts to
the estuary as a whole.

b. What are the desired and potential benefits?

o Develop a coherent and consistent set of planning goals and
objectives relating to the use, protection, enhancement and
development of a particlar coastal resource - the estuary.

o Reduce interagency conflicts over permit decisions by devel-
oping consensus among all public agencies with legal jurisdic-
tion over the estuary's use and encouraging collaborative plan-
ning and continuous dialogue through the recommended amendment
process.

o Provide greater predictability to permit decisionmaking and
expedite the review of permit applications based on prior
agency participation in developing the plan.

o Provide a balance between competing needs for economic develop-
ment and protection of the natural functions of the estuary.

o Provide long-term protection for valuable coastal resources
and minimize adverse impacts.

o Manage a system which spans local jurisdictions.

o Provide a management tool to determine the cumulative impacts
from incremental dredge and fill decisions.

o Avoid duplicative or identical determinations at the planning
and permit levels of review.

c. What doesn't it do?

o Take away agency responsibilities or authorities.

o Take away the public's right to comment on individual proposals.

o Resolve all conflicts.

o Answer all the questions or information required for individual
permits.

1-9

5. Successful implementation of the plan will depend upon the extent
to which local, State, and Federal agencies will use it as a guide for permit
and project review decisions, and the extent to which the general public accepts
the results of the planning process.

1-10

PART II: ALTERNATIVES

PART II: ALTERNATIVES

A. GENERAL

1. This part describes the proposed action and a number of alternative ac-
tions, including both procedural and substantive alternatives, which are divided
into five separate categories. The first alternative to be considered is the
action which is proposed (i.e., approval and adoption of the GHEMP). The
second alternative includes no action (i.e., rejection of the plan) by one or a
number of participants. The third alternative includes different policy
approaches which were considered by the Task Force plus a Citizen's Management
Plan alternative which has not yet received full consideration. The fourth
alternative includes a set of alternatives considered in the designation of
urban areas and cites specific conditions with respect to future development
activities. The discussion of alternatives in the third and fourth categories
considers both estuary-wide and regional issues. The fifth category of alter-
natives includes different methods of implementing the plan.

2. This part is also intended to serve as partial fulfillment of the Sec
404(b)(1) Guidelines (40 CFR Part 230) which have been issued pursuant to the
Clean Water Act (33 U.S.C. 1344). Part 230.10(a)(5) states that:

To the extent that practical alternatives have
been identified and evaluated under a Coastal Zone
Management program,... such evaluation shall be
considered by the permitting authority as part of
the consideration of alternatives under the Guide-
lines. Where such evaluation is less complete than
that contemplated under this subsection, it must be
supplemented accordingly.

In an effort to avoid management conflicts, the Task Force has attempted to
integrate as many of each agency's requirements into the planning process as
possible, including an evaluation of alternatives to the actions contemplated
in the plan. In addition there is a requirement under §307(f) of the Coastal
Zone Management Act which requires that the Federal Water Pollution Control
Act, as amended, and the Clean Air Act, as amended, shall be incorporated
into any coastal management program. Therefore, any action which allows
or recommends the destruction of wetland habitat through dredge disposal
or fill must review the practicable alternatives to that action.

3. While the GHEMP is not a permit application, its purpose is to satisfy
many of the broader alternative requirements of the §404(b)(l) Guidelines
in advance of specific permit applications by identifying the most appropriate
sites for development and those areas which require protection. As individual
permits consistent with the plan are applied for, various permitting agen-
cies (Corps of Engineers, local government agencies and State agencies) may
find it appropriate to refer to this PEIS under the concept of tiering as fully
or partially satisfying requirements for analyzing alternatives. Naturally,
final analyses of §404 criteria will be based upon project specifics.

II-l

B. PROPOSED ACTION - A GRAYS HARBOR ESTUARY MANAGEMENT PLAN

1. The proposed action is the approval and adoption of the GHEMP (after
any modifications made as a result of this public review) as described in
Part I of this document. A copy of the draft plan is included as Appendix 1
and a summary of the plan is described starting on page ii. Reviewers are
urged to take the time to read the plan and study its various provisions in
order to gain a complete understanding of the proposed action. The procedure
used to structure the plan is both geographically and biologically based and
summarized below.

2. Goals and Guidelines

a. The overall goal of the GHEMP is a broad goal which embodies the
concept of balance in the development and preservation of the estuary as a
whole: "The Grays Harbor estuary will be managed for multiple uses." This
goal is consistent with the use of most major estuaries in the United States
and sets the stage for the continued use of the estuary as a deep draft naviga-
ble harbor to be used for port related uses. The other types of multiple uses
allowed are identified in the Standard Use Matrix (GHEMP, p. 109). These uses
are generally the same as those presently allowed in and around the estuary
and therefore do not represent significant changes. Therefore, while the
impacts associated with the multiple use goal may be significant, they are not
considered as being unreasonable since it is the clear intent of the plan's
goal to provide a balance between the various human uses of the estuary while
protecting the overall integrity of the estuary's natural systems.

b. Given a specific set of criteria, the estuary was divided into
eight Planning Areas (I-VIII), each having a set of Planning Guidelines for
the management of that Area's natural resources and development (GHEMP,
pp. 29-47). As an example, Planning Area VII (pp. 43-44) states that the
South Bay area is predominantly natural and relatively undisturbed. The bank-
line will be maintained in its present natural configuration except for those
areas needed to maintain the existing highway, bridge, control features and
tidegates. Recreational hunting and fishing and the commercial fisheries
industry (fish and oyster rearing) are encouraged to continue to use the
area. The guidelines state that dredging to maintain the navigation channel
from Point Chehalis to the Elk River Bridge to its authorized depth is not
compatible with the area. If implemented, the Guidelines will encourage or
constrain future proposed activities within the Planning Areas.

3. Management Units (MU's)

a. The Grays Harbor estuary and surrounding shoreline are further
subdivided into forty-three different MU's within the Planning Areas. The
boundaries of the MU's and the designation given each MU are a further refine-
ment of the existing "environment types" used by the local governments in
developing their local SMP's. This approach provides management recommenda-
tions specific to and consistent with the characteristics of the various
environments in and around the estuary. These MU designations (illustrated
in GHEMP p. Ill) are shown in table 1.

II-2

TABLE 1

Breakdown of

Ma

nagement

Jnit

De

signations

Single

Unit

Spl

it Unit

Total

Natural

2

5

7

Conservancy Natural

1

2

3

Conservancy Managed

8

8

16

Rural Agricultural

3

0

3

Rural Low Intensity

4

3

7

Urban Residential

2

0

2

Urban Mixed

4

5

9

Urban Development

4

3

7

Special (Unit 12)

1

1

2

b. A summary is set out below of the location of the various cate-
gories of MU's.

Natural (N)

Natural categories are concentrated in the North and South Bays (MU's

2, 6, 9, 18, 29, 34, and 41). Most of them are identified as split units

(e.g., Natural below the line of aquatic vegetation, and a Conservancy or Rural
designation on the upland side).

Conservancy Natural (CN)

CN categories are located in the Westport-Whitcomb flats (MU's 30, 38, and
42).

Conservancy Managed (CM)

There are seventeen CM areas distributed throughout the estuary in
addition to the major water and intertidal areas of the harbor (MU's 1, 3, 7,
19, 20, 24, 26, 28, 29, 33, 34, 35, 36, 37, 40, 43, and 44).

Rural Agricultural (RA)

There are three areas containing RA classifications in North Bay (MU 8),
near Montesano (MU 22), and in South Bay (MU 31).

Rural Low Intensity (RL)

The areas containing RL classifications can be found along the east side
of North Bay (MU's 9 and 10), along the South Channel across from the Hoquiam-
Aberdeen area (MU's 27, 30, 32, and 36), and near Melbourne (MU 23).

Urban Residential (UR)

There are two areas designated in the estuary as UR, the Ocean Shores
area (MU 5) and the Central Park Area (MU 21).

II-3

Urban Mixed (UM)

UM designations are predominantly applied in the Westport area (Mil's 33,
35, 37, 38, and 39), in Ocean Shores (MU's 4 and 6) and in Aberdeen (MU's 16
and 17).

Urban Development (UP)

UD designations are located in or adjacent to present industrial /commer-
cial centers. The most extensive area so designated is the Hoquiam-Aberdeen
waterfront (MU's 11, 14, 15, 18, 26 and upstream to Cosmopolis MU 25); MU 28
is located near Markham.

Special (SP)

MU 12 (MU's 12 and 13 in earlier drafts) has received a Special MU desig-
nation because it is a unique area combining both valuable habitat to be pro-
tected and future sites for the principal industrial expansion in the harbor.
MU 19 is designated Special Conservancy Managed because the long-term use of
the area has not been established.

c. Approximately sixty-eight percent of the estuary waterfront will
be designated within MU's designed to conserve Grays Harbor's natural resources.
Table 2 compares the estimated water frontage in conservation and development
categories.

TABLE 2
Estimated Waterfront in Generalized Conservation and Development Categories

Grays Harbor Estuary Management Plan
Conservation Management Units Development Management Units

Est. Waterfront Est. Percent
82.5 miles 67.5

Est. Waterfront Est. Percent
39.8 miles 32.5

Notes: Because ot split MU's, the estimated miles of waterfront
above exceeds the Estuary's approximately 96 miles of
waterfront. An estimated 24 miles of waterfront is in
split conservation and development management units.

Source: Grays Harbor Regional Planning Commission staff analysis, 1983

(1). Figure 4 displays the Grays Harbor Estuary waterfront
classified into generalized development and conservation categories based on
the MU in which the area is designated.

(2). The estimates in table 2 and the classification in figure 4
are based on the same methodology. The MU's were classified into the conser-
vation and development category based on the level of natural resource protec-
tion afforded by the unit and the MU's permitted uses. The following MU's or
portions of split MU's were classified as conservation: Natural, Conservancy
Natural, Conservancy Managed, Rural Agricultural, Rural Low Intensity, and the
Natural portion of MU 12 (Special). These units are characterized by a high

II-4

J

JM V 3 3

CD

II- 5

level of natural resource protection with development generally limited to low
intensity uses. The Urban Residential, Urban Mixed, and Urban Development
MU's, including the Urban Development portions of MU 12 (Special), were classi-
fied in the development category. The two categories of MU's were then mapped
and measurements made. Certain MU's in the generalized categories also regulate
development through special conditions and conditional activities. Thus, it is
necessary to examine each MU to gain a full understanding of the level of devel-
opment which is permitted.

(3). In general, most of the harbor is designated in categories
which constitute little change from natural or existing conditions. Most of
the water, intertidal, and marsh area in the estuary is designated in Conser-
vancy environments and most of the uplands are designated in Rural environments.
The categories involving more intensive uses are generally associated with or
in proximity to areas currently involving more intensive uses. Taken together,
these categories tend to focus intensive uses toward existing urban areas with
some opportunity for expansion into immediately adjacent areas. The plan overall
tends to limit the potential for major future urban expansion. Existing
rural and undeveloped shoreline areas will generally remain in that condition
if the provisions of the plan are implemented.

(4). The most notable changes from existing local SMP designa-
tions and zoning regulations include:

o MU 11. From R to UD.

o MU 12. Area 1, 1700 acres from C to N.

o MU 12. Areas 2, 3, and 4, 500 acres from C to U (actually, approx.

100 feet of Area 3 north of the airfield is designated as U). Area

6 from U to CM.
o Fish Passage (intertidal lands north of the navigation channel and

south of the Hoqui am/Aberdeen shoreline) from U to CM (acreage

unknown),
o MU 21 . From C to UR to reflect existing housing,
o MU 22. From C to RA.
o MU 23. From C to RL.
o MU 26. From U/C to CM (salt water marsh area currently zoned

Industrial ).
o MU 27. From R/C to RL.
o MU 28. From R to UD.

o MU 29. From C to N (Portions of the Johns River area),
o MU 33. From R to UM.
o MU 35. From R to UM.
o MU 43. From U to CM.

(5). Concerning permitted activities, the plan is yery restric-
tive. In four MU's, no activities listed on the Activities Matrix are permis-
sible either as permitted, conditional or under special conditions. Seventeen
MU's plus six split MU's have activities permissible as conditional or under
special conditions but none which are permitted, and an additional six MU's
have only one activity which is permitted. No activities are permitted in any
Natural or Conservancy Natural MU's. Overall, permitted activities are allowed
in less than 10 percent of the 990 MU activity boxes with Bankline Erosion
Control projects being the most numerous (see figure 5).

II-6

36

37

38

39

40

41

42

43

w

:m

RL

CM

UM

CM

UM

CN

UM

CM

N

CN

CM

CM

■

0

■

■

*

■

■

■

0

0

■

*

■

0

■

*

*

0

*

•

0

*

0

*

■

■

■

*

■

■

*

0

0

•

0

0

*

*

*

*

*

•

■

■

■

•

0

0

■

0

*

0

0

0

*

1

level of natural resource protection with development generally limited to low
intensity uses. The Urban Residential, Urban Mixed, and Urban Development
MU's, including the Urban Development portions of MU 12 (Special), were classi-
fied in the development category. The two categories of MU's were then mapped
and measurements made. Certain MU's in the generalized categories also regulate
development through special conditions and conditional activities. Thus, it is
necessary to examine each MU to gain a full understanding of the level of devel-
opment which is permitted.

(3). In general, most of the harbor is designated in categories
which constitute little change from natural or existing conditions. Most of
the water, intertidal, and marsh area in the estuary is designated in Conser-
vancy environments and most of the uplands are designated in Rural environments.
The categories involving more intensive uses are generally associated with or
in proximity to areas currently involving more intensive uses. Taken together,
these categories tend to focus intensive uses toward existing urban areas with
some opportunity for expansion into immediately adjacent areas. The plan overall
tends to limit the potential for major future urban expansion. Existing
rural and undeveloped shoreline areas will generally remain in that condition
if the provisions of the plan are implemented.

(4). The most notable changes from existing local SMP designa-
tions and zoning regulations include:

o MU 11. From R to UD.

o MU 12. Area 1, 1700 acres from C to N.

o MU 12. Areas 2, 3, and 4, 500 acres from C to U (actually, approx.

100 feet of Area 3 north of the airfield is designated as U). Area

6 from U to CM.
o Fish Passage (intertidal lands north of the navigation channel and

south of the Hoqui am/Aberdeen shoreline) from U to CM (acreage

unknown),
o MU 21 . From C to UR to reflect existing housing,
o MU 22. From C to RA.
o MU 23. From C to RL.
o MU 26. From U/C to CM (salt water marsh area currently zoned

Industrial ).
o MU 27. From R/C to RL.
o MU 28. From R to UD.

o MU 29. From C to N (Portions of the Johns River area),
o MU 33. From R to UM.
o MU 35. From R to UM.
o MU 43. From U to CM.

(5). Concerning permitted activities, the plan is \/ery restric-
tive. In four MU's, no activities listed on the Activities Matrix are permis-
sible either as permitted, conditional or under special conditions. Seventeen
MU's plus six split MU's have activities permissible as conditional or under
special conditions but none which are permitted, and an additional six MU's
have only one activity which is permitted. No activities are permitted in any
Natural or Conservancy Natural MU's. Overall, permitted activities are allowed
in less than 10 percent of the 990 MU activity boxes with Bankline Erosion
Control projects being the most numerous (see figure 5).

II-6

PERMITTED ACTIVITIES

MANAGEMENT UNIT

1

2

3

4

5

6

7

8

9

10

11

12

14

15

16

17

18

19

20

21

22

23

24

25

26

27

28

29

30

31

32

33

34

35

36

37

38

39

40

41

4?

43

\\

MANAGEMENT CATEGORY

CM

N

CM

UM

UR

UM

N

CM

RA

RL

N

RL

UD

SP

UD

UD

UM

UM

UD

N

CM

CM

UR

RA

RL

CM

UD

UD

CM

RL

UD

CM

CM

N

RL

CN

RA

RL

UM

CM

CM

N

UM

CM

RL

CM

UM

CM

UM

CN

UM

CM

N

CN

CM

CM

Ui

S

1

3

Piers, Docks, Wharves

■

0

*

*

*

i

0

0

0

0

■

■

■

0

0

*

0

*

0

*

*

0

*

■

■

■

0

■

■

*

Piling & Mooring Dolphins

0

*

*

*

^

*

0

0

0

0

0

0

*

*

■

0

*

■

*

0

+

■

0

■

■

■

0

0

■

Bridges

0

0

0

0

0

0

0

0

*

0

0

0

■

*

*

*

0

*

0

*

■

0

*

Causeways

■

*

*

0

■

Outfalls

0

*

■

■

■

■

■

*

■

■

0

0

■

*

*

■

■

*

0

0

■

■

■

■

■

■

■

■

■

■

■

■

■

■

■

0

■

*

Cable/Pipeline Crossing

■

■

■

0

0

0

0

*

0

0

■

*

0

*

0

*

0

*

0

*

Boathouses

0

*

0

*

0

0

■

■

■

■

*

■

*

■

*

0

*

Breakwater

■

0

I

■

■

0

*

z
<
a

-i

HI

z
z
<
z
o

Di king

■

*

*

+

*

m

■

■

*

■

■

■

■

■

*

■

■

0

■

■

*

*

■

■

■

■

■

■

*

■

■

Bui kheadinq

■

*

*

*

■

*

*

■

■

■

■

•

Groins

0

■

■

■

0

0

*

Jetty

0

■

0

0

*

Special Project Fills

*

*

*

*

*

*

*

*

*

*

*

+

*

*

Bankline Straightening

*

0

0

0

*

*

Bankline Erosion Control

0

*

0

*

*

*

0

0

0

*

0

0

0

0

0

0

0

0

*

*

■

■

0

■

+

■

*

■

■

*

*

*

*

■

■

■

*

0

0

■

New Access Channel

0

*

■

■

■

0

*

Channel /Berth Maint.

0

*

■

*

■

■

■

■

*

*

*

■

*

■

■

0

0

Channel Realignment

■

*

■

■

■

■

■

■

■

■

0

*

PERMITTEO ACTIVITY

CONDITIONAL ACnVTTY

SPECIAL CONDITIONS

O

■
*

STANDARD USES f~|tandartU,e

II-7

FIGURE 5.
Consolidated Permitted Activities Matrix

4. Policies

a. The plan provides general policies under which future modi fications
of the estuary will be managed, regulated or permitted and was designed to pro-
vide more specific guidance to the land and water users of Grays Harbor.

b. Definitions and Terms. The plan has many definitions but perhaps
the two most important are terms associated with what is a "permitted use" and
a "conditional use."

(1). Permitted uses conform with the plan but are not permitted
outright since they must meet certain requirements and conditions (GHEMP, p. 19).
Nevertheless, it is presumed that they will be able to meet those requirements
and conditions within the specific MU's in which they are permitted.

(2). Conditional uses generally conform with the objectives
of particular Management Categories or MU's, but because they have potential
problems inherent with a specific use or activity, special care must be taken
to avoid negative impacts through the application of project/site specific
conditions. Five specific criteria must be satisfied before a conditional
use becomes an allowable use (GHEMP, p. 17). Despite general consistency
with the plan, a conditional use or activity may be inappropriate because of
specific circumstances surrounding a proposal or because of unique character-
istics of the proposal, and may not be found permissible after case-by-case
review.

c. Structures. The plan regulates and designates areas where various
types of structures may be placed in the water or wetlands of the estuary. There
are eight classes of stuctures (piers, docks, wharves; piling & mooring dol-
phins; bridges; causeways; outfalls; cable/pipeline crossings; boathouses; and
breakwater) identified in the plan. The Task Force members believe they have
given careful consideration to ensure that essential environmental qualities
are conserved in each MU where the structures are permitted, conditional or
require special conditions. Generally along municipal urban areas, a larger
number of structures are permitted. In less intensely developed areas, struc-
tures are more often designated as conditional uses and are generally intended
to support private, recreational and other forms of limited development.

d. Banklines. The plan identifies where and occasionally under what
conditions modifications may be made to the bankline. The policy is designed
to protect both natural conditions as well as urban needs. There are seven
types of aids (diking, bulkheading, groins, jetty, special project fills,
bankline straightening, and bankline erosion control) with only a few of them
considered as permitted activities. They are generally located at the mouth
of the estuary and are needed to protect existing or planned uses and activites.

(1). The purpose of bankline erosion control is to protect prop-
erty along banklines from erosion. Activities permitted include riprapping and
minor straightening and sloping of the bankline to stabilize uplands and
prevent accelerated erosion. The policy contains ten stipulations or condi-
tions which must be applied and does not allow bankline erosion control for the
purpose of gaining developable uplands from existing water areas. Erosion
control is generally allowed in more urban and intensely used areas or where
potential erosion of the shoreline may affect adjacent uses such as industrial
and commercial waterfront activities and transportation facilities. Where the

II-8

policy is allowed as a conditional use or under special conditions, the areas
are generally more environmentally sensitive and a more critical review is
required prior to allowing any modification. Under the existing local SMP's
shoreline protection measures are allowed in all but the Natural environment
and are a permitted/conditional use in the Conservancy environments. The pro-
posed policy is more stringent and constraining than the existing provisions of
law under the Washington SMA (WAC 173-16-060(17)-Shoreline Protection); it is
not unilaterally permitted in all Urban and Rural MU's, nor is it a permitted/
conditional use in all Conservancy MU's. Bankline erosion control measures are
not permitted in the Natural MU designations. The Task Force has taken measures
during the planning process to carefully delineate where bankline erosion
control activities may be appropriate and require greater environmental safe-
guards which are clearly spelled out in the policy (GHEMP, p. 24). Overall,
this policy is more beneficial to the Grays Harbor environment than the existing
policy and provides greater predictability for those who would choose to carry
on such an activity.

(2). In specific MU's, small fills may be permitted for the
purpose of straightening the bankline to consolidate uplands into usable par-
cels. The policy (GHEMP, p. 25) contains eleven criteria which will apply to
activites involving bankline straightening (in addition to the normal Federal
Section 404 permit requirements). The policy limits any single fill to two acres
or less measured from the Line of Non-Aquatic Vegetation to the toe of the fill.
Bankline straightening is permitted only in three MU's in the Hoqui am/Aberdeen
waterfront (MU's 15, 16 and 17) and under special conditions in MU's 12, 18 (UD),
and 25. Once again, the policy and its application in specific MU's are more
restrictive to users than that which currently exists under existing local
SMP's under which landfills are permitted in the Urban environments and
permitted/conditional in all Rural and Conservancy environments.

e. Channels. The primary function of channel policies is to ensure
safe passage of ships, allow channel maintenance, and shorten the total channel
length. There are three designations of activities (new access channel channel
berth maintenance, and channel realignment) to include the creation and mainten-
ance of a side channel connnecting the main navigation channel, dredging of shoal
materials from an existing channel and dredging to relocate an existing channel.
Due to the environmental impact of dredging and other channel policy activities,
care has been taken to permit such activities only where necessary, particularly
the Westport and Ocean Shore Marinas. Channel/berth maintenance is the only
activity which is permitted in MU 44 as it is essential to the economic sta-
bility and vitality of the region.

f. Log Rafting. The policy allows log rafting to continue under
specific conditions and in specific areas. The policy is designed primarily
to avoid the adverse impacts associated with log grounding and any adverse
environmental impacts associated with expansion into new areas. Log rafting
areas are shown on the map in the plan (GHEMP, p. 110).

g. Mitigation. The Mitigation Policy is discussed in Part II,
Section G.

II-9

5. Plan Concepts

a. The overall impetus to develop a comprehensive land and water use
plan was the need to minimize recurring conflicts over the location and cumula-
tive impacts associated with development. These conflicts centered on the
permit applications for development projects in the aquatic environment.
Therefore, the plans boundary or jurisdiction was limited to the aquatic and
adjacent shoreline area where local, State and Federal agencies all have juris-
diction. Specifically omitted were the rest of the watershed (2,550 sq. mi.)
of the estuary or the "total ecosystem," the ocean and beach waterfront, and
the fasti ands of Ocean Shores and Westport whose management are the responsi-
bility of the local governments. Modifying the local SMP's was determined to
be the best management tool which would help resolve the development/preserva-
tion conflicts.

b. The Urban Waterfront and the Fish Passage

(1). The GHEMP has attempted to focus development away from the
"fish passage" or the shallow intertidal and subtidal areas which are found in
the mixing zone between fresh and salt water. During periods of out-migration
of juvenile salmonids (specifically chum and Chinook), this area is located in
the urban areas of Aberdeen and Hoquiam, the areas most likely to be developed
in the future under the existing SMP's. It is here where major transportation
routes come together, where the most infrastructure is located, and where zoning
and water dependency would allow further encroachment into the wetlands and
shallow areas to reach the navigation channel. Specific resources particularly
in danger were a few shallow areas for downstream migrating fish adjacent to
the shore which were considered by some resource managers to be vital resting
and feeding areas and provide safety from predation while they adjust to the
greater concentrations of salt water and gain in size. Also key to the passage's
•ability to support anadromous fish runs during smoltification are several large
remaining marsh areas on the south shore needed for their nutrient supply.
The importance of these areas has more recently been confirmed by Simenstad
and Eggers in studies conducted for the Corps. 1

(2). As vital as this area is, there is nonetheless some oppor-
tunity for new development if particularly important aspects of the aquatic
habitat are protected and if incremental effects could be limited in a predict-
able way. Such development opportunity was especially important to the Task
Force in order to allow for the badly deteriorated urban waterfront to be
rehabilitated. For such rehabilitation some flexibility was needed so that new
development could be encouraged in an appropriate manner. To implement these
objectives, the plan uses the following techniques:

(a). The ultimate extent of development's encroachment into
the passage would be limited to protect the passage. Changing environment
designations from Urban to Conservancy Managed waterward of the line of ordin-
ary high water and placing limits on "bankline straightening" would be used to
implement this limit.

Simenstad, C.A. and D.M. Eggers, 1981. Juvenile Salmonid and Baitfish
Distribution, Abundance and Prey Resources in Selected Areas of Grays
Harbor, Washington, U. of Washington Fisheries Research Institute,
prepared for Seattle District, Corps of Engineers.

11-10

(b). Within the ultimate limits, greater flexibility would
be allowed the cities with dilapidated waterfronts to encourage redevelop-
ment. In particularly key areas, it was agreed to allow water-oriented commer-
cial uses in the Urban Mixed MU's.

(c). Especially important areas, known as the fish base and
the South Aberdeen marshes, would be specifically protected in specified ways.

(3). While these compromises answer some of the needs in the urban
area, they do leave one very important need unanswered: where should new heavy
industrial uses be sited? As long as this need was not met within the plan, the
fish passage could be jeopardized by such developments in the future. The plan
is not acceptable to the local area unless it addresses the area's need for
such space. While some areas are considered within existing developed areas,
none adequately meet modern industrial siting needs. For example, the south
shore industrial disposal area was examined at length but its lack of direct
economical water access (and the threat that poses to the South Aberdeen marshes)
make this a less than effective answer since the types of industry most need by
the region are linked to the navigation channel.

c. The Bowerman Industrial Area

(1). MU 12 is designated in the plan as the solution to the need
(addressed in (3) above) to provide adequate area for new water-dependent
industrial uses while protecting the fish passage upon receipt of appropriate
permits. A total of 500 acres of new industrial land which may be developed
in this area plus the additional use of the Bowerman Peninsula is considered
enough area to meet the water-dependent industrial needs of the region indef-
initely if used wisely. It has always been the intent of the Port of Grays
Harbor to eventually develop the entire 2200 acre area for industrial expansion.
The major reasons the area was selected include:

o location adjacent to the navigation channel and downstream from
Cow Point which will reduce required dredging,

o previous impact on the area by long-term dredged material disposal,

o ability of the existing infrastructure, including transportation,
to serve the area readily, and

o ownership of property by the Port of Grays Harbor.

(2). The major drawbacks to this use are the presence of the
airport and the importance to avian fauna.

(a). The planning process considered relocating the airfield
away from the estuary, but study proved this not to be feasible. 1

(b). In the earlier stages of planning, the area committed
to development was that part most affected by dredged material disposal (i.e.,
the 500 acres north of the airfield and west of the Hoquiam city limits. While
this was less desirable from an economic point of view (since it was away from
the navigation channel), the environmental impact was at the time condsidered
to be less significant.

1. CH2M Hill, Bowerman Field Relocation Planning Study, GHRPC, 1979.

11-11

(c). Subsequent to this decision in 1978 it was noted that
this area was an exceptional environment for shorebirds which included shelter
from storms, raised elevation to permit a longer feeding period, and an abun-
dant food source. The shorebirds are in turn a favorite source of prey for
some of the predators including merlins and peregrine falcons. While it was
known at the time of the original decision that the area was extensively used
by shorebirds, public participation in the planning process coupled with a
concern regarding how the modification of this area might affect the endangered
peregrine falcon (the first confirmed sighting of the endangered species variety
of the peregrine falcon - Falco peregrinus anatum was made by Dr. Steve Herman
on October 31, 1979) which feeds on the shorebirds, led to a reformulation of
this aspect of the plan.

(i). Future development in the area is now designated
to the west of the airport (Area 2), thereby lengthening the peninsula. While
the plan contains a preliminary planning commitment to allow even further fill
(Area 4) in a westerly direction, there are a number of conditions which may
direct expansion beyond (Area 2), elsewhere.

(ii). The airport is conditionally allowed to move
the runway north (Area 3). Its relocation would be dependent on the impacts
associated with the filling of Area 2 and a commitment to use the airfield for
water-dependent industry. The airport is generally a low-intensity use and
may serve as a buffer from industry. The airport fields are sometimes used by
the shorebirds as roosting sites.

(iii). Most of the prime shorebird habitat will be
permanently preserved (the easterly portion of Area 1), with the potential
for future enhancement projects in the westerly portion of Area 1 providing
additional improved shorebird habitat.

(d). MU 12 represents a most difficult tradeoff which
mediates the needs of economic development, fisheries, and birds. As currently
designed, it attempts to take all three into consideration in the decisionmaking
process.

d. Airports

(1). One of the most troublesome policy concerns in the planning
process was the conflict between aeronautical needs and resource agencies
concern for wetlands protection. Since airports consume large areas and are
not water dependent uses, resource agencies resist their siting and development
in estuarine areas. The agencies feel that such areas can be better used in
resource protection or in absorbing development pressure. However, since
estuarine land is relatively inexpensive, relatively easy to buffer from devel-
opment (residential encroachment, etc.), and relatively easy to develop for
runways, it is often desired for airports sites. Three estuarine sites for
airports in Grays Harbor (at Bowerman, Ocean Shores and Westport) compounded
this policy dispute. The airports in the plan were each considered with respect
to costs to the natural resources, ability to meet aeronautic and community
needs, and whether there were viable alternatives. It was determined that
there was a lack of viable alternatives. This led to extensive negotiations
between the resource agencies and the local communities in order to reach some
accommodation regarding each of the airports.

11-12

(2). Ocean Shores. At Ocean Shores, before the initiation of the
GHEMP planning process, plans were well in progress to relocate an airport from
a hazardous and constrained site in the middle of a commercial /residential
area of the city to a wetlands area just east of the peninsula. These plans
were already controversial and were therefore deliberately added to the Task
Force deliberations for resolution in comprehensive context. The Task Force
determined that the proposed site was the best alternative but that the extent
of development would be severely limited to the minimum amount needed (as
defined by FAA standards). Ownership of the remainder of the marsh area would
be transferred to a resource agency or an independent nature conservancy organi-
zation. The compromise not only meets the needs for an airport but also estab-
lishes a limit for the extent of development into the estuary.

(3). Westport. The airport at Westport is currently located
on drained marshlands. The area is often too wet to permit safe landings.
The plan allows some realignment and improvements to be made in exchange for
the city's commitment to conserve large areas of marsh land, once again
establishing a limit for development in the marshes.

(4). Bowerman Airfield. Addressed above.

e. Public Access and Waterfront Rehabilitation

(1). Some of the plan's most significant policy implications are
not clearly specified in the text of the plan itself. Two such concerns are
public access and waterfront rehabilitiation. These concerns were a priority
for the affected cities. Similar to other development activities, the plan
sets down limits within which these activities may occur; allowing the agencies
and parties responsible for implementing such activities some freedom to develop
within those limits.

(2). In the case of urban waterfront rehabilitation, the policy
clarifies what types of development could be permitted. The plan provides
more flexibility, because of the safegards developed in the plan for the fish
passage area to permit the affected cities more options to pursue in their
efforts to redevelop the waterfront. This is especially true for the water-
front near the confluence of the Wishkah and Chehalis Rivers. Prior to the
plan, resource agency policy generally sought to limit development to strictly
water-dependent uses and not water-related commercial activities. The plan
now clearly allows such commercial development and is consistent with attempts
to revitalize urban waterfronts throughout the country.

(3). Public access opportunity in the plan ranges from highly
developed facilities such as a waterfront park in Aberdeen, marinas, boat
ramps, etc., to ^ery low intensity areas where such access is provided by the
absence of development. Generally, water access is provided in a manner
consistent with the intensity of existing development, developed facilities
in urban environments (marinas, water-related commercial development, water-
front parks) and undeveloped opportunity in undeveloped areas. This pattern
tends to be consistent with the need to avoid intense access in areas with
fragile biological resources.

11-13

C. NO ACTION

1. A no action alternative essentially maintains the status quo within
Grays Harbor and could be achieved through the following means: first, local
governments, individually or collectively, could decide not to amend their
local SMP's and comprehensive plans to conform to the applicable provisions of
the plan; second, the DOE could deny local SMP amendment requests. While not
negating local government adoption, plan implementation would be weakened if
Federal regulatory agencies decided not to utilize the plan. Finally, NOAA
could disapprove the amendment request if it decided the plan does not meet
Federal requirements or that it would have an unacceptable adverse environ-
mental impact.

2. This alternative course of action would continue the current situation
of divergent actions of the various agencies which exercise regulatory or
management authority in the estuary without the benefit of a comprehensive
framework on which to base decisions. This alternative leaves open the current
situation for public agencies (including local governments) to pursue single
issue goals and objectives which may or may not be related to one another and
which may have a high potential for conflict between them. This course of
action also continues both the uncertainty regarding the outcome of any project
proposal in the estuary area and the sometimes lengthy permit processes, adding
to the cost of development as well as government administration. A lack of
coordinated public policy among the Federal, State and local agencies creates
confusion and frustrates individuals seeking permission for various actions
as well as agencies attempting to manage the bay's resources and regulate
such requests for the public good. Such confusion and conflict will lead to
continued political intervention, a situation the Task Force sought to avoid
in future decisionmaking.

3. Whether this alternative would in actuality produce greater or lesser
impacts on the environmental quality of the estuary is difficult to assess
since such impacts would depend upon future actions under the existing system.
Generally, it can be expected that the adverse environmental impacts would most
likely be greater for the following reasons.

a. The current system is oriented toward a case-by-case review of
individual projects as they occur without the benefit of a comprehensive land
and water use management plan which enjoys any degree of confidence from State
or Federal agency representatives in which an attempt has been made to integrate
their agency standards and concerns into what is normally a local land use
planning process. The exisiting local SMP's are more permissive than the
GHEMP (as discussed under item 5 below) and would therefore theoretically allow
more development if proposed. While substantial development permits may be
more difficult to obtain, few have actually been denied. In such situations,
the ultimate impact will depend on which projects are proposed and how effec-
tively each is advanced through the regulatory review process. Laws and regu-
lations are almost constantly being amended so there is no real long term
stability or permanent criteria on which to judge actions; ergo, there are no
guarantees that what may be allowed or prohibited one day will be allowed or
prohibited the next. This uncertainty generally tends to favor development.

11-14

b. The difficulty of predicting the ultimate effect of individual
permit decisions under current regulatory systems poses a potential longrange
adverse environmental problem. The estuary is a complex, fragile ecosystem.
Any one project by itself, if carefully designed and sited, may be acceptable,
but the cumulative effects of such projects may pose a serious threat to the
overall ecosystem. Also, a presently acceptable project may not be acceptable
in the future due to its combination with other projects. Because the case-
by-case approach cannot anticipate these future problems or conditions, it
more difficult to evaluate cumulative effects of incremental permit decisions
as required by NEPA and the 404(b)(1) Guidelines.

c. The existing system also poses an additional potential environ-
mental problem in being unable adequately to balance competing concerns for the
use of the estuary. The present permit system cannot address concerns regarding
the "best" or most suitable alternative for a particular use or activity. The
current system responds to specific proposals, it cannot direct development. It
enters the picture only after a proposal is developed, a site selected, owner-
ship questions resolved, and some investments made. This limits the ability
for meaningful alternatives analysis. Furthermore, due to the conflicts in
the existing agency programs (because of imperfect intergovernmental coordi-
nation) a prospective developer has no guidance in how best to direct prepara-
tions. Since this ability to evaluate and influence alternatives is limited,
greater environmental damage might occur due to the "best or least damaging"
site for a particular project not being selected while an "acceptable" but
less appropriate site is approved. This problem can become \/ery serious
when it is combined with the cumulative effects of many projects.

(1). For example, the fish passage might be seriously jeopardized
through incremental filling out to the navigation channel or the Bowerman Basin
might be filled through a series of fills (over a long-term period) as has been
the trend to fill westward. Generally speaking, it is easier to justify single,
disparate projects which are consistent with local government land use plans
than to address estuary wide cumulative effects. While this may be acceptable
in minimizing local impacts, it is not possible to understand the cumulative
effects of those individual fills until the next permit application is proposed
and the sum of the projects may have an unacceptable impact on the resources.
This leads to great uncertainty for both the agencies which issue permits or
comment on them and developers in understanding how their development fits
into the whole picture.

4. While the present regulatory system poses these problems for ensuring
adequate protection of the natural resources, it also creates potential prob-
lems for those attempting to meet the socioeconomic needs of the community.

a. Just as case-by-case decisionmaking limits evaluation of cumu-
lative environmental impacts, case-by-case decisions also limit evaluation
of the cumulative effects of permit decisions on economic conditions. While
denial of one project may not be critical to the economy, the cumulative
effect of several permit denials may be very damaging. The present system
also provides no means by which projects of potentially greater future need
can be evaluated in the permitting process given the amount of developable
space which is available. In other words, the present permit system provides
noway of knowing whether it is allocating efficiently whatever development
the system may be able to accept.

11-15

b. The present permit system is also unlikely to be able to achieve
the optimum balance between environmental and economic needs. Since the case-
by-case review system cannot effectively direct development proposals to the
area of least environmental impact, the cumulative effect of individual permit
decisions could result in a lower level of economic opportunity for a given
level of environmental impact than if it were possible to direct development
proposals, in advance, to the site most capable of accommodating those uses. By
not optimizing economic opportunity in relation to environmental costs, the
resulting balance would be lower than that which could otherwise be achieved.
Also, without the GHEMP there are likely to be greater conflicts between economic
uses, thereby usurping available spots with potentially inappropriate develop-
ment J

5. While the existing permit system has a distinct case-by-case review
character, there are existing policy frameworks which seek to plan future use.
The two major frameworks are local planning and zoning, and local SMP's.
Neither of these programs has been able to establish predictability in regard
to how the system should be managed. While each program can, and does, prevent
or permit actions, other permit authorities can also prevent them because of the
requirement to take additional considerations into account. Consequently, as
discussed above, those programs do not provide a basis upon which future
actions can be predicted. However, these policy frameworks do make up a part
of the existing system which would continue under the no plan alternative.
Therefore, it is necessary to address the environmental impacts which would
occur under those plans rather than the proposed action.

a. Local Planning and Zoning

(1). The proposed GHEMP reduces the area in which urban uses
would be permitted by the local plans and zoning ordinances. As such, the
effect of the proposed plan would be to reduce the potential adverse environ-
mental impacts of development patterns which current zoning would allow. The
most significant reduction would occur in the Aberdeen/Hoquiam/ Cosmopolis
area where a considerable amount of water and intertidal area is presently
zoned industrial. The County's Comprehensive Plan also has more area designated
industrial adjacent to these cities than the proposed GHEMP would permit. The
present plan of Westport would extend urban uses into marshlands which would
be protected under the GHEMP. Plans of the City of Ocean Shores would not
be significantly modified by GHEMP, except for the reduction in area permitted
for ai rport use.

b. Shoreline Management

(1). The potential adverse impact which might occur under the
various existing SMP's is less clear due to diverse interpretations of pro-
visions of those programs. For example, if it were assumed that the future
uses under the Washington SMA would be limited to uses the SMA specifies as
"permitted," the proposed GHEMP represents only a small reduction in the range
of potential uses which could occur. However, if it were assumed that uses
specified as "conditional" in the SMP's Conservancy Environments would be
likely, the plan represents a dramatic reduction in the potential range and

T~. For more information on some of the problems encountered with the existing
regulatory system, see appendix E, which consists of an excerpt from The
Federal Coastal Program Review.

11-16

degree of uses which could occur. Chapter 22, from the existing Grays Harbor
County Shorelines Management Master Program, illustrates this point.

Conditional Uses: The following uses are generally inappropriate
or unnecessary shoreline uses in the Conservancy Environment.
These and other unlisted uses may be allowed as conditional uses
subject to the provisions of Chapter 33:

Duplex; dwelling group; apartment; townhouse, condominium; hotel;
motel; professional office; personal service; financial service;
retail and secondhand sale; outdoor sales; vehicle and merchandise
repair; campground; mobile home park; animal hospital; kennel;
non-appurtenant signs; outdoor amusement; commercial parking lot;
restaurant; tavern; water related industrial; water related commer-
cial; marina; boat basin; boat sales and service; landfill; non-
water related commercial use; non-water related industry; solid
waste disposal; wood waste fill; public building; convenience
goods sale; club, fraternal organization; service station; truck
terminal; wrecking or junk yard; cemetary, school; church; mortu-
ary; hospital; rest home; bulkheads and other protective devices;
dredging and mineral extraction; pollution control facility;
shake shingle mill; utility substation; power generating facility;
airport; gravel crushing; asphalt or concrete batch plant; free-
way, expressway; railroad; highway; log storage and rafting and
golf course.

(2). With few exceptions, almost all such activities are neither
permitted nor conditional uses under the GHEMP in Conservancy Environments.
This should go a long way toward providing predictability in decisionmaking.
GHEMP activities in Conservancy MU's are limited to water dependent/related
uses, agriculture, farm houses and rural low intensity (scattered) house,
navigational aids and linear facilities (roads, utility corridors) which
require access to or through the waters. If past experience is an indicator
of a possible future scenario, it appears highly likely that over the next
20-50 years the Conservancy environments as managed and designated under
existing plans would be subject to more requests for conditional uses than
would be allowed under the GHEMP.

(3). The proposed plan also alters the ML) designations in the
existing programs. The most significant change is a refinement in the Urban
designation that currently applies to nearly all of the incorporated areas of
Aberdeen, Hoquiam, and much of Cosmopolis. While the plan removes the Urban
designation from most of the water area within the incorporated cities, it
extends urban activities into parts of MU 12 and into the Junction City area
somewhat further than the present County program. The benefit of the GHEMP is
that it takes these important wetlands and uplands into account and affords
them greater protection even though they are adjacent to an urban environment.
A comparison between the existing SMP's and the proposed GHEMP is depicted in
figure 6.

11-17

FIGURE 6
COMPARISON OF EXISTING LOCAL SHORELINE MASTER PROGRAM'S AND GHEMP

STANDARD USES

If uses are treated same by both SMP's and GHEMP. then only GHEMP Symbol
"2 shown. If th£ differ, then ,-P". "C" or "X" Is used. It Is noted other uses
ire aUo permitted by SMP's which are not Included In this figure.

ESTUARY ^ -
MANAGEMENT •
PLAN - □

PERMITTED USE

SEE SPECIFIC MANAGEMENT UNIT
GUIDELINES

USE CATEGORY

PORT
FACILITIES

MANUFACTURING
AND OTHER

Z

g

<

H

a.
O
a.
v>

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Jb.

Dock and Warehouse Facilities

<
cc

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Z

>-

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>

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Z

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u

RURAL

URBAN

N

Port Terminal Facilities

Ship Berthing

Barge Berthing

Ship Construction and Repair

Navigational Aids

Heavy Industry

Light Industry

Water Dependent Industry

' Forest Products Processing

Mine ral Extraction and Storage

Ferry Terminal

Shipping

Roads and Railroads

□

CN

Dp

Airports

Overhead Utility Corridor

FOOD
INDUSTRY

COMMERCIAL

z
o

<

UJ

cc
o

UJ

cc

Submerged Utility Corridor

Commercial Fishing (Incl. Shellfish)

Oyster Culture

Aquaculture

Fish and Food Processing

Motel

Boat Sales, Construction and Repair

Restaurant

Marina

Other Commercial

Public Fishing Areas

Water Dependent Hunting

Pleasure Boating

Camping

Public Boat Ramp

RESIDENTIAL

AGRICULTURE

NATURAL
AREAS

Park/Parkway, Other Public Access

Floating Homes

Dp

□x

□x

CM

□

Dp

Dp

□

RL

Dp

□

Dp

Dp

□

Urban/Suburban

Rural Low Intensity (Scattered)

Rural Agricultural (Farm House)

Major Cultivated Crops

Passive Agriculture

Subsistence/Local Market Farming

Tree Farm

Estuarine and Marine Sanctuaries

Wildlife Refuges

Living Resource Production and Habitat

P&C

□

DP

p&c

RA

UR

DP

UD

□

DP

Dp

DP

DP

D

□ P

D

DP

□E

P&C

Dp

Dp

p#c

D

PfiC

UM

Dp

DP

DP

DP

CM

D

v&ttmii

»DC

P#C

Dp

Dp

D

Dp

DP

Dp

Dp

Dp

DP.

D£

Dp

DP

Dr

Dr

Dp

D

D

DP

p#c

D

ft

a

jp__p_

_&

Dp

Dp

D

a

D

_

D

Or

D

a

G

EXISTING SMP's P = Permitted Use C = Conditional Use X = Not Permitted

11-18

(4). It is the collective judgment of local government repre-
sentatives that current SMP's are more permissive to development (notwith-
standing Federal permit requirements) over a long-term period than is the
GHEMP. Local government representatives also believe that while they have
given up some future development options to achieve comprehensive long-range
planning which incorporates additional Federal standards and criteria, they
will gain predictability on remaining more important development. While
previous permit conflicts have been costly to developers because of delays,
the record also indicates that most permits have been approved. The long-
range picture would not likely change in the absence of the GHEMP. Therefore,
the environmental consequences of no action are likely to be both more costly
for particular development projects and more environmentally damaging than
the proposed action.

c. Absent the GHEMP, local governments would make selective modifi-
cations to their local SMP's without the benefit of substantial Federal and
State agency input provided by the Task Force. This could lead to a lack of
balance if those changes are in response to future development pressure. This
is to say, no action does not equate with no fill in the long-term future of
the estuary.

6. Overall, the no action alternative would put greater pressures on
local governments to allow urban expansion into the fish passage areas along
the shoreline. Almost all projects which are contemplated by the plan including
the projects at Ocean Shores, Westport, and the South Aberdeen industrial area
are consistent with the existing local SMP's and local zoning and would be
permitted by the local programs irrespective of the GHEMP. The major exception
would be the development activities in MU 12. Development in Bowerman Basin
would not be consistent as a permitted activity, but nonetheless might be
allowed as a conditional use. In the GHEMP, the Standard Use Matrix does con-
sider port, manufacturing and transportation facilities as a "permitted" use
in the UD MU environment, but all activities in the MU are "special condition"
activities and not designated as "permitted."

a. Under the no action alternative, 1700 acres wetlands - now Port
property - would not be transferred to the Washington State Department of Game
for preservation. Development could well take place within and beyond the 500
acres currently proposed in the plan over the next 50 or even 100 years. No
mitigation would be guaranteed. The Port could opt to restore diked wetlands
as in-kind replacement, but that would not necessarily benefit the shorebird
population that uses the basin. While the actual demand in year one may not be
great for additional land along the navigational channel, the demand will be
great in future years due to a number of variable circumstances including the
widening and deepening of the navigation channel and economic recovery.

b. Conversely, because of the importance of the Bowerman Basin to the
shorebirds and falcons, it is possible Federal laws and regulations would
effectively prohibit future fill despite political and development pressure.
This assumes that environmental laws and regulations would not be weakened and
that the considerable pressures associated with economic development do not
prevail .

c. This evaluation cannot accurately predict the outcome of the
future for the Bowerman Basin under the no action alternative. It would be
speculative at best. One thing is clear: there is a substantial likelihood
of some portion of MU 12 being filled for development during the next 50 years.

11-19

D. ALTERNATIVE PLAN CONCEPTS

1. Any plan is a composite of actions for each of which there are a
number of alternatives. It is not possible, within the scope of this document,
to identify and describe at length each of the alternatives for specific pro-
posals which were considered during the process. However, it is possible to
discuss the general concepts of such alternatives. In the development of the
plan, alternatives were discussed at each level of policy development. Alter-
native goals were discussed before the proposed GHEMP was selected. Potential,
alternative scenarios for each set of planning area guidelines were formulated.
Alternative designations then were discussed as each unit was assigned a manage-
ment category. Each of these discussions tended to involve the following
policy directions in comparison to the policy balance now contained in the
plan:

o Policy or use commitments which provide greater development oppor-
tunity but would result in greater resource loss.

o Policy or use commitments which would provide greater protection for
the resource by greater restriction of development opportunity.

o Policy or use commitments which would address the distribution of
activities, such as: a) concentrating development with its potential
impacts into fewer but more intensely used areas and b) dispersing
development over wider areas but with less intensity.

o Policies which would direct the pending urban uses to other areas:
a) away from the estuary; b) to other areas in the estuary; c) to other
ports.

In all, the consensus decisionmaking process served to narrow down the viability
of many of the alternatives.

2. The following discussion will consider alternative plan concepts and
describe the potential environmental effects that would occur if more propos-
als in the plan were made under each of these alternative policy directions.

a. Greater Development Opportunity with Greater Environmental Costs

(1). The planning process could enable more decisions which
would increase the (apparent or desired) opportunity for local governments
to enlarge their economic base. While this alternative could provide greater
potential economic benefit to the area (by allowing more fill for industrial/
commercial development), it also would significantly increase the potential
for substantive modification of the estuarine system and human environment of
the shoreline. Each such modification would entail further loss of productive
estuarine area. The balance between development opportunity and environmental
costs was extensively discussed, debated, and resolved throughout each stage
of the planning process. The goal formulation stage considered the following
concept:

Manage Grays Harbor for intensive industrial use and protect

Will apa Bay for resource management purposes.

(Note: In 1977, the Corps made a final determination that there

would be no more maintenance dredging in Will apa Bay, and that

log exporting would ostensibly go to Grays Harbor. See appendix E,

p. 2, article on Willapa Bay: An End to Dredging.)

11-20

(2). This concept, if it were selected, would have conditioned
later planning decisions to be conducive to permitting more development oppor-
tunity than the proposed plan. It also would have resulted in a greater number
of provisions in the plan to permit modification of the estuarine system. The
present overall goal tries to avoid this extreme position and encourage a
balance between economic need and environmental costs.

(3). In the consideration of Planning Area Guidelines, the poten-
tial of each Planning Area to support greater use for various socioeconomic
purposes was considered. In all Planning Areas, the guidelines which were
selected tend to constrain the potential development which might otherwise
result, in order to conserve and protect important environmental resources.

(4). As each planning unit was considered in the process, various
specific proposals were also considered which would have resulted in greater
adverse impacts on the natural system. While many such proposals were re-
jected, some of the more significant ones included:

o Retention of Urban designation on all shorelines in Westport,

o Larger airport and support facility area at Westport,

o Larger airport at Ocean Shores,

o Greater residential opportunity along North and South Bays,

o Allowance of some industrial development of North Bay,

o Use of Unit 12 (1700 acres west of Bowerman Basin owned by the Port
of Grays Harbor),

o Leaving Bowerman Field where it is and permitting expansion into the
adjacent tideland,

o Allowing the filling of Units 12 and 14 to the navigation channel
line, especially development of the old "fish base,"

o Having the ability to fill larger areas along the Aberdeen water-
front,

o Immediate extension of Urban Development further up the Chehalis
River,

o Allowing intensive development on the channel along the south water-
front of Aberdeen,

o Permitting greater industrial and commercial use of the area up-
stream from Cosmopolis,

o Providing a larger Urban Development area near Markham and allowing
bankline straightening, and

o Providing areas (such as that near Rennie Island) for in-bay dis-
posal of dredge material.

11-21

(5). These alternatives for providing greater development oppor-
tunity generally are not provided for in the plan because their impact, when
combined with the modifications permitted, is expected to produce unacceptable
cumulative adverse environmental impacts. As more and more modification is
permitted the potential to impair the productive capacity of the system becomes
greater. Other, more specific concerns for rejecting these proposals included,
but were not limited to:

o Discouragement of urban sprawl and haphazard development,

o The especially significant concern of protecting the fish passage,

o The need to ensure protection of critical or particularly important
natural features, and

o The need to conserve productive marsh area for marine production.

b. Less Development and Greater Resource Protection

(1). The process could result in a plan which would permit less
development opportunity than the proposed plan. By so reducing the amount of
modification to the shoreline and estuarine system, there would be greater
assurance that the essential biological function of the system would not be
impaired. Particularly significant, less conversion of wetland to upland
would thus occur. Such environmental protection, however, would be at the
cost of prohibiting future regional economic development which the local gov-
ernment representatives on the Task Force believe to be below the "bottom
line" of what they think is reasonable or desirable from a long-term per-
spective. As in the case of the greater development alternative, decisions of
this nature occurred often during the planning process. When the proposed
goal for estuarine management was selected, the Task Force also considered the
following concept:

Manage Grays Harbor for maximum resource protection, by severely
limiting filling, and limiting development to existing industrial
land. (Note: A distinction must be made between what is zoned in-
dustrial but not developed and what is currently industrial land
as a matter of fact.)

(2). This concept would direct further decisions in the planning
process toward greater conservation of the estuary; it also would prevent the
planning process from adequately addressing the importance of the system in
providing opportunities to meet the perceived long-term economic needs and
desires of the area.

(3). The planning process also considered instituting Guidelines
in each Planning Area which would place greater constraints on the opportunity
for more intense use of the estuary. Such Guidelines would produce more cau-
tious management decisions in the future and thereby serve to conserve more
environmental resources than the present Guidelines. Likewise, such guide-
lines might also frustrate the achievement of perceived socioeconomic needs
and growth.

11-22

(4). This alternative would allow no wetlands filling in MU's 6
(Ocean Shores), 12 (Bowerman Basin with exception of peninsula), 26 (98 acres
of the south shore industrial site, 38 and 39 (Westport Airport and Marina);
but would allow the use of vacant or underutilized lands in order to meet the
region's socioeconomic needs: This alternative would have fewer natural resource
impacts and potentially meet some of the region's economic needs. As discussed
below, some of the spatial or other support requirements provided by the exist-
ing developed or developable lands may not meet the future demands for maritime
industrial needs.

(5). As part of the scoping process, OCRM and the Task Force
have received an alternative to the GHEMP entitled the (draft) Citizen's Grays
Harbor Estuary Management Plan submitted on January 15, 1983 by a number of
national, regional and local environmental and conservation organizations.
These organizations include:

o Natural Resources Defense Council

o Friends of the Earth

o Washington Environmental Council

o Seattle Audubon Chapter

o Tahoma Audubon Chapter

o Black Hills Audubon Chapter

o N.W. Steelheaders - Grays Harbor Chapter

o N. Beach and Pacific Co. Environmental Council

The draft alternative was submitted because the organizations "do
not find that the proposed Estuary Management Plan developed by the Task Force
has arrived at an acceptable 'balance' between environmental and developmental
objectives." While the entire text is included in appendix F, the major
provisions are set forth below.

Citizen's Grays Harbor Estuary Management Plan 1
2. Key criteria of the Citizen's Estuary Plan include the following:

* Acceptance of the Estuary Management Goal for the Estuary which
says that "the Grays Harbor estuary will be managed for multiple uses."

* Equally important, however, is the retention of the tests of
water dependency and feasible alternatives analysis as the basis for estuary
development decisions, and

* Increased protection for natural parts of the estuary.

1. Di rect Quotation

11-23

3. Based on these criteria, certain elements in the Task Force plan are
rejected:

a. Filling 73 acres of tideflats, wetlands and intertidal area north of
the Bowerman Airfield in the Unique Wildlife Bowerman Basin ecosystem by the
Port of Grays Harbor in M.U. 12.

This fill is rejected because its purpose is not water dependent
(i.e., airport relocation), it would have an unacceptable adverse impact to
the estuary and no inkind replacement habitat mitigation is proposed.

b. Filling 164 acres of tideflats, wetlands and intertidal area west
of the Bowerman Airfield in the Unique Wildlife Bowerman Basin ecosystem by
the Port of Grays Harbor in M.U. 12.

This fill is rejected because it would have an unacceptable adverse
impact to the estuary and no inkind replacement habitat mitigation is proposed.

c. Filling 20 acres or wetlands north-east of the Bowerman Basin ecosystem
by the City of Hoquiam in M.U. 14.

This fill is rejected because its purpose is not water dependent, it
would have an unacceptable adverse impact to the estuary and no inkind replace-
ment habitat mitigation is proposed.

d. Filling 95 acres of freshwater wetlands as a dredge spoil disposal
area by the Port of Grays Harbor in M.U. 26.

This fill is rejected because feasible alternatives exist (i.e. open
water disposal) and no inkind replacement habitat mitigation is proposed.

e. Filling approximately 40 acres of tideflats, wetlands and intertidal
area east of Ocean Shores by the City of Ocean Shores for an airport in M.U. 6.

This fill is rejected because its purpose is not water dependent;
despite the fact that inkind replacement habitat mitigation is proposed.

f. Filling of an unspecified amount of acres of wetlands to expand an
existing airport by the City of Westport in M.U. 38.

This fill is rejected because its purpose is not water dependent and no
inkind replacement habitat mitigation is proposed.

g. Filling of an unspecified amount of acres of wetlands to expand an
existing marina by the City of Westport in M.U. 39.

This fill is rejected because of lack of need and no inkind replacement
habitat mitigation is proposed.

4. Since one of the key concepts in the Citizen's Estuary Plan is increased
protection for natural parts of the estuary the following additional protec-
tive features must be included:

* Sec. 404 (c) designation under the Clean Water Act for areas unsuit-
able for dredge or fill disposal.

11-24

* Recognition of the U.S. F&WS's endangered species determination
under Sec. 7 of the Endangered Species Act that filling in 500 acres of the
Bowerman Basin would likely jeopardize the endangered Peregrine Falcon and
management of the area as an International Shorebird Sanctuary.

* The establishment of a mitigation plan in place prior to adoption
of an estuary plan.

* Commitment to a sediment control study as part of any Dredged
Materials Disposal Plan prepared by the Task Force.

* Ocean side management units established and adopted as part of any
estuary plan for Westport and Ocean Shores.

5. The Citizen's Estuary Plan accepts and utilizes the basic political manage-
ment unit divisions and categories which the Task Force has established. How-
ever, it reorders the priorities and assumptions under which development,
especially by the Port of Grays Harbor, can take place.

In particular, a finding is made that the Port of Grays Harbor has current-
ly at its disposal :

a. a 176-acre dredge spoil disposal site which is undeveloped and for
which no inkind replacement habitat mitigation was carried out by the Port in
M.U. 26.

b. a 45-acre (Kaiser Steel) site, speculatively filled by the Port in 1977,
which is still undeveloped and for which no inkind replacement habitat mitigation
was carried out in M.U. 15.

c. a 72-acre site at the Port's Terminal 2 in M.U. 15. Thus, a total of 293
acres of shoreline area accessible to the navigation channel is available to the
Port of Grays Harbor. If the 600 additional acres of potential filling allowed
the Port by the Task Force were carried out, nearly a thousand acres of develop-
able land would be placed at the disposal of the Port. We reject this approach
to Port development. We do not find in the Task Force's plan any requirements
that the Port's existing land development listed in 5. a.-c, above, must be
utilized first before additional filling is permitted.

6. Therefore, the Citzen's Estuary Plan recommends a three phase plan as
follows:

a. Phase I - The Port has 293 acres of development potential. These
areas must be developed to the satisfaction of the Task Force and a citizen
advisory committee to their fullest potential for water dependent purposes.

b. Phase II - The next development opportunity with the least environ-
mental cost is utilization of the Bowerman Peninsula (approximately 200 acres)
with a small amount of filling permitted in the south-west corner to align area
with navigation channel. This however, will require the Port to relocate their
Airport outside the estuary at one of three sites:

11-25

1 . Central Park

2. Markham

3. Elma

as set out in the Bowerman Field Relocation Planning Study, June 1979, Grays
Harbor Regional Planning Commission.

Thus, the Port must make a tradeoff as to whether the economic benefits of
utilizing the Bowerman Peninsula for water dependent uses exceed the costs of
relocating the airport.

c. Phase III - After the completion of Phase I and II to the satis-
faction of the Task Force and a citizen advisory committee a further in depth
examination would be made to amend the Grays Harbor Estuary Management Plan to
accommodate an additional 250 acres of fill someplace in the estuary.
(This is the same process as set out for Area 4 in M.U. 12 in the Task Force's
draft plan.)

Thus, further decisions and additional filling for specific water dependent
projects would be dealt with through the plan amendment process. Under the
Citizen's Estuary Plan, the Port of Grays Harbor would have 500 acres available
to the Port for water dependent development in Phase I and II and the potential
for an additional 250 acres in Phase III with minimum impacts to the Grays
Harbor estuary.

7. Because the Task Force's plan provides little in the way of additional pro-
tections for important natural areas in the estuary the Citizen's Estuary Plan
proposes the following:

a. The following 11 Management Units are recommended for designation under
Sec. 404 (c) of the Clean Water Act as areas prohibited by the Administrator of
EPA for use as a disposal area for the discharge of dredged or fill material:

M.U.'s 2, 7, 9s*, 19, 20, 29s*, 34s*, 36s*, 27s*, 41 and 42. These M.U.'s
are all designated Natural or Conservancy Natural ("*" s means the shoreline
part of a split mangement unit).

b. The following 4 Management Units are recommended in part for designa-
tion under Sec. 404 (c) of the Clean Water Act as areas prohibited by the
Administrator of EPA for use as a disposal area for the discharge of dredged
or fill material :

M.U. 's 12, 14, 18, 26.

c. The following Management Unit is also recommended for designation under
Sec. 404 (c) of the Clean Water Act as areas prohibited by the Adminstrator of
EPA for use as a disposal area for the discharge of dredged or fill material:

M.U. '5. This M.U. is designated Urban Residential.

d. In addition, 9 Management Units are recommended for the Sec. 404 (c)
process of notice and comment without a specific determination made at this time.

11-26

The suitability of the following Management Units would be assessed
during this process:

M.U. 's 1, 3, 22, 23, 27, 30, 40, and 43. These M.U. 's permit only bankline
erosion control fills in the Task Force plan.

Thus, a total of 25 M.U.'s or parts of M.U.'s could be protected by such a finding
by EPA under Section 404 (c).

Sec. 404 (c) designation would of benefit for two reasons:

* It would clearly identify areas in which future filling may be con-
templated but has not been brought to the attention of the Task Force. Since
the 9 M.U.S. listed in 7. d. above, conflict only with the bankline erosion
control feature, we would like EPA to examine the tradoffs of foregoing erosion
control for protection from filling in these areas.

* It would clearly identify areas in which future filling would not
be allowed by the Corps of Engineers.

Appendix B contains a description of each of the M.U. 's listed above.

8. Recognition of the U.S. F&WS's endangered species determination under Sec.
7 of the Endangered Species Act that filling in 500 acres of the Bowerman
Basin would likely jeopardize the endangered Peregrine Falcon. This determina-
tion should be incorporated into the final plan. In addition, the Bowerman
Basin would be designated and managed as an International Shorebird Sanctuary.
See Appendix C.

9. The Task Force with the help of a citizen advisory committee would estab-
lish a mitigation plan to require inkind replacement of habitat for any wet-
land, intertidal , or tideflat area filled under an adopted plan. This mitiga-
tion plan should be in place prior to adoption and incorporated into the final
plan.

10. The Task Force would commit to undertaking a sediment control study as
part of any Dredged Materials Disposal Plan prepared by the Task Force. A
request for such a study was specifically made by then-Governor Dan Evans in
1973. Since that time, the Corps has prepared a literature review, but no in
depth study has been carried out to comply with Gov. Evan's request. Control and
reduction of sediments in the Chehalis River Basin could significantly reduce
the amount of sediment which needs to be dredged, thereby reducing the pressure
on wetland, intertidal and tidal flat filling, especially for maintenance dredg-
ing.

1 1 . The Citizen's Estuary Plan al so cal 1 s for the Task Force with the hel p of a
citizen advisory committee to develop Management Units for ocean side coastal
zone in and around the cities of Westport and Ocean Shores. These coastal
areas are important and should be addressed within the context of this plan.

12. A Citizen's Advisory Committee would be established by the State Dept. of
Ecology to ensure that the public is permitted to participate in the development
of any revised plan or plan amendments.

(end of quotation)

11-27

(a). Evaluation. The Task Force has been provided copies,
but has not convened for full review of Citizen's Estuary Plan. A complete
evaluation will be made on the merits of the alternative after all comments
have been received during the public review process and incorporated in the
PFEIS.

(i). The overall impact of the alternative is to
provide less development potential while providing greater protection to the
wetlands, fish and wildlife resources than the proposed GHEMP.

(ii). While accepting the basic tenents of the plan,
it rejects all of the major provisions in which compromise solutions to the
issues of future growth and protection were formulated on the basis that:

o the intended use would not be water dependent (airports),

o there is no current or demonstrated need (marina expansion),

o there is no in-kind habitat replacement proposed, or

o that the impacts are considered to be unacceptable.

(iii). The Citizen's Plan:

o requires the location or relocation of three airports outside
of the estuary area,

o would allow no future expansion of the Westport Marina,

o would not allow fill for industrial expansion in the Port owned
lands in MU 12 (note: It is not clear expansion would be permitted at some
future time or not. The Citizeh's Plan states that filling is rejected because
of unacceptable adverse impact to the estuary but then may permit fill during
Phase III - i.e., after all existing space is utilized to the satisfaction of
the Task Force and a citizen's advisory committee.), in the City of Hoquiam's
land in MU 14, and in the 98-acre site in MU 26,

o invokes §404(c) of the Clean Water Act on all or parts of 25 MU's
in order to provide additional protection to natural areas,

o requires the incorporation of a previous F&WS determination (13
March 1981) that filling the entire Bowerman Basin (500 acres north of the
airfield) is likely to jeopardize the continued existence of the peregrine
falcon, and that filling westward may do the same,

o requires the re-evaluation of permitting bankline erosion control
activities in specific MU's,

o requires a sediment control study in efforts to minimize the need
for maintenance dredging (and pressure for filling aquatic habitat),

o calls for maximizing the utilization of existing developable
land (Phase I) prior to allowing any further filling (Phase III),

11-28

o establishes in-kind habitat replacement as the only form of accept-
able mitigation, and

o requires establishment of a citizen advisory committee for the pur-
pose of setting up a mitigation plan, planning for ocean side coastal environ-
ments of Westport and Ocean Shores, and involvement in the plan amendment
process.

(b). The Citizen's Estuary Plan alternative is accepted as
a viable alternative with three exceptions which will not be considered as viable
or necessary to the GHEMP proposal. Those items specifically rejected include:

(i). Item 9. The establishment of a Mitigation Plan
which must be in place prior to adoption of the GHEMP. It is premature to
develop a Mitigation Plan prior to the adoption of the GHEMP. The draft GHEMP
is subject to modification and will provide the framework for the Mitigation
Plan. Any mitigation required prior to development and adoption of a Mitigation
Plan will be considered through the existing permit process. A Mitigation Plan
would be incorporated into the GHEMP through the amendment process. The Task
Force would develop such a plan within the first or second year after adoption.
Additionally, "in kind" replacement of habitat may or may not be a part of the
future Mitigation Plan requirements for e\/ery development. As discussed at
GHEMP pp. 26-27, a Mitigation Plan would address the three mitigation concepts
identified in the plan or whatever exists after the public review process.

(ii). Item 10. Undertake a sediment control study as
part of any Dredged Material Disposal Plan prepared by the Task Force. Such a
study was undertaken in 1974 and is entitled: Grays Harbor Erosion Management
Study (by Norman Associates for the GHRPC). The Study is available for review
through the GHRPC. Further duplication of effort is considered unnecessary.

(iii). Item 11. Develop Mil's for the ocean side coastal
zone environments in and around the cities of Westport and Ocean Shores. Without
disputing that these areas are important, the emphasis of the GHEMP is the
immediate area surrounding the estuary in which the major land and water use
conflicts arise and have a direct impact on the estuary. While many different
boundary configurations ^re possible, the Citizen's Estuary Plan fails to make
a case why the ocean side environments must be a part of the estuary plan.

(c). The Citizen's Estuary Plan includes a number of assump-
tions and statements whose premises are subject to dispute:

(i). Wetlands filling should be permitted only if a
project is water dependent and in-kind habitat replacement mitigation is re-
quired. While perhaps desirable from a wetlands protection perspective, these
standards are more restrictive than existing Federal agency Guidelines and
Regulations for filling wetlands. The Corps considers many other factors
through the permit process and public interest review in addition to water
dependency.

11-29

(ii). That there is a need to incorporate into the final
GHEMP the March 13, 1981 U.S. Fish and Wildlife Service Section 7 consultation
letter which states that filling 500 acres directly north of the Bowerman
Peninsula as proposed in the earlier draft plan is likely to jeopardize the
continued existence of the peregrine falcon. The earlier concern was primarily
directed at the location of the fill more than the amount of fill. The area
north and northeast of the Airfield was considered to be the most significant
as shorebird habitat and consequently, the integrity of the falcon's existence.
The plan thoroughly considers that determination. On that basis, the plan
proposes a new configuration of fill, phasing development to permit monitoring
of impacts, mitigation requirements, and the permanent land exchange protecting
427 acres of the 500 acres. The U.S. Fish and Wildlife has since issued a new
determination that the current plan is not likely to jeopardize the continued
existence of the endangered peregrin falcon (see appendix C). If Area 2 is
filled, the Bowerman Basin will be turned over (through fee title transfer of
lands) to the Washington State Department of Game thereby permanently prevent-
ing fill of the shorebird habitat which is most critical to the prey species
of the peregrine falcon.

(iii). That the GHEMP does not have any requirement that the
Port's existing filled lands on south shore (176 acres), the Kaiser site (45
acres) and at Terminal 2 (72 acres) must be utilized before additional filling
is permitted. With respect specifically to the Port of Grays Harbor lands,
the plan does make such specification for filling Area 3 (GHEMP, p. 65, item
2) and Area 4 (GHEMP, p. 67, item 3). Since we are dealing with long term
activities, most of the subject lands are likely to be utilized or committed
prior to the complete development of Area 2.

(iv). That the Airport Relocation Study concluded alternative
sites for a regional airport are available in Central Park, Markham and Elma.
The "Findings, Conclusions and Recommendations" of the Study (p. 97) state the
following:

Realistically there is no opportunity to locate a new Basic Transport
Airport in the 1,200 square mile study area that would readily serve
the population base and be environmentally and economically prudent
to develop. There are however, opportunities in the area to locate a
General Utility category airport to help relieve the developing opera-
tional pressure at Bowerman Field and to better meet the region's
aviation demand. (Those sites include Central Park, Markham and Elma,
emphasis added).

From a systems planning and cost-effective viewpoint, all efforts
should be made to make the existing Bowerman Field site as compatible
with the Estuary Plan as possible to avoid the relatively high capital
outlay for a new airport site.

11-30

c. Distribution of Impact Alternatives

(1). In addition to the alternatives dealing with the overall
level of activity to be permitted, there are alternatives which would distri-
bute this activity in different patterns. The planning process considered
these issues mainly in its development of planning area guidelines where gener-
ally appropriate levels of development were determined for each area. The
result of these guidelines is a relatively concentrated pattern of urban and
natural use areas based largely on the existing character of various planning
areas.

(2). The issue of whether the adverse environmental impact can
effectively be reduced by dispersing or concentrating development is frequently
discussed in estuarine management situations and is seldom completely resolved.
In the Grays Harbor planning process, these allocation decisions were made
more on the basis of the existing character of an area and the most practicable
way of both protecting important environmental features and meeting socioecon-
omic needs, than on the achievement of a philosophical goal to disperse or
concentrate development of natural uses. Nevertheless, the planning process
addressed such alternatives and considered their implications.

(3). Dispersed Development

(a). It can be argued that better environmental protection
can be achieved by dispersing development over a broad area, thereby avoiding
a synergistic effect of development activities. This argument suggests that
greater levels of development can be supported with fewer environmental costs
by spreading the impacts. This is perhaps more true for water and air quality
issues than for wildlife resources.

(b). Theoretically, it could be possible to take the level
of impact addressed in the plan and distribute it over a wider area. For
example, rather than concentrate new water dependent industry in Aberdeen/
Hoquiam, it could be spread more uniformly and less intensively throughout the
estuary. While theoretically possible, this alternative poses significant
practical problems. Each development project is tied to a particular need or
a particular potential opportunity, and in most cases this need would be less
adequately addressed in another location. In some situations, dispersion
would greatly increase public utility and service costs to serve such areas.
This policy could stimulate the spread of urban development along with resultant
infill.

(c). More significant than these concerns is the relation-
ship of this policy to environmental conditions in the Grays Harbor area.
Historically, the urban growth of the area has been relatively concentrated in
the Aberdeen/Hoquiam and Cosmopolis area, and to a lesser extent in Westport and
Ocean Shores. The remaining areas of the estuary are largely undisturbed by
development activity. This alternative would change the development pattern
and introduce new impacts into natural or nearly natural environments. But the
largest limitation to dispersing shoreline development is providing access to
the navigation channel for marine commerce development.

(d). Areas which might, however, serve as future urban
development areas for industrial siting of water dependent/related activities
would be MU 3-CM (Damon Point) which is located near the North Channel,
MU 27-RL (Steam's Bluff) and MU 10-RL (Point New).

11-31

(i). The Damon Point area would require additional
fill and protective structures and destroy significant bird habitat. It
would have substantial transportation problems associated with getting wood
products or other commodities to a shipping site and be located very near MU 2
which is a Natural area.

(ii). With respect to MU 27 near Steam's Bluff on
the south shore, it would be conceivable that industrial development could
expand, given the fact it has highway and rail access and relatively flat land.
This would require opening a portion of the South Channel which has been left
unmaintained for many years. Industrial expansion would substantially alter
the land use pattern of the area and require sewer and water hookup and possi-
bly introduce water quality problems where they now do not exist, which could
adversely affect existing oyster culture areas.

(iii). The Point New area has a substantial amount of
flat land with both highway and rail access. Development would require either
a new navigation channel or transportation of goods and services to other
existing docks for loading. The site could serve as an industrial park for
nonwater dependent uses if filling is not required. This would introduce
industrial activities into the North Bay area which is one of the actions
the GHEMP has attempted to avoid.

(e). In conclusion, dispersing urban development into the
more pristine areas of the estuary would have substantial negative ecological
and economic consequences. In addition, the concept of dispersion is not
consistent with the provisions of the Washington SMA.

(4). Concentrated Development

(a). In contrast to a policy of dispersion, this policy
would concentrate development into few areas and reserve most of the estuary
for more natural, less intensive uses. Current local SMP's tend to support
this policy even more than the proposed plan. As an example, the SMP's for
Aberdeen and Hoquiam would allow greater modification of the waterfront areas.
Fishery experts have stated that this level of development could significantly
impair the passage of anadromous salmonid fish through this area and as such
poses an unacceptable level of impact J Thus, the plan tends to protect this
passage by establishing greater limits on the potential intrusion of develop-
ment into waterfront areas.

(b). As an alternative to filling in MU 12 and the western
part of MU 26 (in order to stop the westward expansion of development and
concentrate development in the Aberdeen/Hoquiam area), MU 43-CM (Rennie Island)
and part of MU 26 (salt water marsh) would allow good access to the navigation
channel (see photo 2). However, because there is no access to the island
from either the north or south shore, a bridge would have to be built to allow
industry to locate there; other modifications would be required as well. The
island has been heavily modified by previous dredge material disposal but is a
good habitat for a variety of fish and wildlife. The area is perhaps unique in
that it will continue to serve as a limited dredge material disposal area but
provide a long-term use for wildlife and waterfowl habitat enhancement.

1. See fishery impacts section, page IV-14.

11-32

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(c). The alternative of greater concentration also embodies
the concept of more efficient utilization of existing space. Waterfront space
which has been altered or has access to the navigation channel can be reserved
exclusively for water-dependent uses, including run down areas or areas not used
to their maximum capacity. While land ownership by marine or private indus-
tries would be a problem, port expansion demands may be met for a longer period
of time, thereby delaying the need for future fill if the spatial requirements
of new industry can be met. In many cases, this would only be feasible if
expansion towards the navigation channel is permitted. There are, of course,
potential hazards to the fish base and passage as pointed out above.

d. Relation of Impact Alternatives to Industrial Development

(1). Finally, there is a set of alternatives related to indus-
trial development in general, and to the Bowerman Basin area in particular.
Local government representatives and the Port of Grays Harbor believe that
the Bowerman Basin area can best represent the industrial expansion and diver-
sification needs of the region's future and, therefore, embodies the need to
provide adequate space for industrial development. Consequently, alternative
space for this purpose should be considered. There are two possibilities for
such space: areas located away from Grays Harbor and other areas in the
estuary.

(2). Non-Estuarine Areas. Suitable industria1 land is a scarce
commodity and has several requirements:

(a). Spatial Requirements. Modern industrial plants require
large areas not only for present use but for future expansion. Planning design
criteria generally recommend that areas for industrial parks siting (the
preferred method of handling industrial uses) have at least 320 acres. 1

(b). Flat Land. Slopes generally cannot exceed 6 percent.

(c). Services. The site must be served or be capable of
being served by adequate rail and highway systems, have access to large quanti-
ties of water, and be served by waste disposal systems as well as by other
util ities.

(d). General Location. Within major commuting distance
but far enough apart to minimize adverse impacts to residential and commercial
areas.

(e). Considering these requirements, there are few locations
within the region which can supply these needs. Other than sites in and along
the estuary, the only other potential sites are areas near the small cities in
the Chehalis Valley, although water and sewer services in those cities general-
ly would need substantial development to meet industrial needs. Such locations
would have several serious disadvantages, including:

1. Industrial Development Handbook, Executive Group of the Industrial Council
of the Urban Land Institute, 1975, Wash. D.C., pp. 29-31.

11-34

o They could threaten fish and wildlife habitat found in the valley.

o Their location in flood hazard areas,

o The conversion of agricultural land,

o Their presence would constitute a major alteration of land use
patterns in the region,

o They would require greater employee commuting,

o They could stimulate greater urban sprawl.

(f). However, the greatest difficulty with these sites is
that they do not relate to the most significant comparative advantage of indus-
trial siting in Grays Harbor - its access to a deep water channel. The sites
in the valley are removed from this potential. Finally, due to its established
infrastructure, the Aberdeen/Hoquiam/Cosmopolis area is generally more able
to accommodate new industrial development than would be the smaller cities in
the valley which lack most of the services and facilities required by industry.

(3). Other Sites in the Estuary

(a). If industry is to locate on the estuary, where is the
most suitable location? In order to answer this question, several criteria
(in addition to those above) should be established:

o The industry should have access to deep water;

o Industrial access should be economical and minimize upstream
movement of vessels;

o The sites should be readily serviceable by rail, street,
water, sewer, and other utilities;

o The sites should be near other public and private services
needed for business operation;

o The industrial use should minimize conflict with adjacent uses
and the land should be generally appropriate for industrial use;
and,

o Industrial siting should minimize potential adverse environmental
impacts.

(b). On the basis of the above criteria there are only
three viable alternatives for new industrial siting - Bowerman Field, South
Shore (MU 26), and the area upstream from Junction City and Cosmopolis. South
Shore is a significant distance from the channel. In order to use the channel,
the industry must construct conveyance facilities to the channel (as in the
case of bulk commodities such as coal or feed grain) or move cargo (such as
logs or lumber) to other transshipment sites. The first alternative is con-
sidered to be the most practicable. In order to make the South Shore area

11-35

viable as an all-purpose related site, substantial modification of the adjacent
salt marsh on the bay side of the railroad would be necessary, and this action
could seriously threaten the quality of the fish passage. Use of the City
area further up the Chehalis River would require significant modification of
the natural area of mixed freshwater marsh, salt marsh, and low forest types.
The site also has poor highway access. The GHEMP would permit only a limited
amount of industrial development to occur in this area (MU 18).

(c). The Bowerman Basin area has the best combination of
these criteria including immediate adjacency to the navigation channel and
its appropriateness for large-scale industrial siting. To quote from the plan:

In establishing its direction for overall management of the estu-
ary, the Task Force recognized that economic growth involving
conversion of natural habitat to industrial uses would continue
at some level in the harbor during the life of this plan. In
reviewing the opportunities for that growth to occur around the
harbor, the Task Force reviewed the several potential areas in
terms of the availability, size and usability of land, transporta-
tion access for both rail and highway, proximity to the main
navigation channel, availability of utilities, relationship to the
existing industrial areas, relationship to other support industries
and uses and other factors. While there are several areas around
the harbor that could accommodate some industrial growth, the
Task Force saw that most provided only limited opportunities. In
pursuing a philosophy of concentrating major future development
rather than dispersing it throughout the harbor, focusing that
growth into the area of Management Unit 12 met more of the criter-
ia than any other area. (GHEMP, p. 63)

(i). While having adverse impacts to the shorebird
habitat, siting (with respect to future filling) is considered not to have an
unacceptable impact on the aquatic ecosystem including wetlands. Once again,
quoting from the plan:

In addition to criteria directly related to the needs of future
industrial development, the Task Force considered the amounts of
various types of intertidal habitat and their values to fish and
wildlife resources. Fish migration habitat was considered a
major limiting factor in Grays Harbor because of past development
patterns. During the next 50 years, the plan, as drafted, will
protect most of the estuarine wetlands from filling except those
in this management unit. This is approximately 1.5% of the inter-
tidal area of Grays Harbor and 6% of the estuary's low silty
marsh. Although there is an adverse impact associated with fill-
ing these wetlands, the balance achieved through protection of
most of the rest of the estuarine ecosystem from filling reduces
the significance of the loss, and is consistent with the overall
goal for management of the estuary for multiple uses. (GHEMP, p. 62)

The plan then lists the reasons why filling of parts of MU 12 is considered
acceptable within the context of the plan and the total estuary.

11-36

(4). Other Ports

(a). The alternatives analysis must also consider the capac-
ity of other ports in the vicinity of Grays Harbor to handle the needs created
by future port demands, with less filling of wetlands or other environmental
impacts. Both alternatives to filling and needs for filling for major water-
dependent industrial sites can only be realistically evaluated on a long-term
comprehensive basis. On that basis, as the projections below indicate, there
will be an expanding need for industrial sites, particularly for forest products
related facilities. Previous evaluations, cited below, also indicate other
ports do not provide viable alternatives for shipping Grays Harbor forest
products.

(b). Long-term analysis, data and evaluations identified
in (c) below, support the conclusion that there will most likely be a valid
and legally recognizable "need" for considering future fill for major water-
dependent industrial sites in Grays Harbor, even in the absence of currently
identifiable site-developers, certainly as to forest products facilities and
quite probably as to other development (coal, grain, etc.). Other ports on
the Washington coast may or may not be able to provide better alternatives to
satisfy those needs. Naturally, complete evaluation of needs must be addressed
and confirmed through the regulatory process at the time of permit application.

(c). Projected future port/industrial demand.

(i). Forecasts on port facility demands for the area
are provided by the Washington Public Ports Association. In their "1980 Port
Systems Study for the Public Ports of Washington State," Vol. II, Part 3, they
state the following with respect to the overall projected needs for the Washing-
ton coast region (Grays Harbor specifically) in relation to other port sites
(see figure 7 for Port Study Regions).

In the Washington coast region, all the shoreline currently
owned by the ports will be developed by 1995, and by the year
2000 a deficit of approximately 3,250 linear feet of shoreline
and 115 acres is forecast. On the basis of these findings,
there appears to be sufficient need for additional shoreline
property in the Washington coast region to support an acquisi-
sition program. Such an acquisition program would need to be
more extensive if facilities for coal or grains are to be devel-
oped, (p. 1-2)

A potential for Washington ports to handle over 25,000,000 ST
[short tons of coal] by the year 2000 has been identified. Hand-
ling this quantity of coal would require either three or four
berths, depending on locations. The optimum arrangement would
appear to be one two-berth terminal in either the lower Columbia
or Washington coast region and another in the Puget Sound region

The assumed typical coal terminal would consist of two

berths, each 1,000 linear feet in length. It would need 100
acres of backup storage and handling area and would have a loop
track access, (p. 1-7)

11-37

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11-38

The Port of Grays Harbor, the only major port in the Washington
coast region, is forecast to need eight new berths for logs and
lumber by the year 2000. These facilities would require 160
acres of backup yard and 6,000 linear feet of berthing. The
Port of Grays Harbor does not appear to have sufficient acreage
or shoreline to accommodate this forecast, (p. 1-9)

The major change along the Washington coast has been the de-
cision by the Federal government to discontinue the dredging
of Willapa Bay. This has meant a loss of waterborne commerce
for the Port of Willapa Harbor, and the logs and forest pro-
ducts that originally were shipped are now being transported
by train or truck to Grays Harbor and Longview. (p. 3-12)

This scenario requires a total of eight new berths, costing
$98 million, in the Washington coast region by the year 2000.
The facilities require 5,950 linear feet of moorage and 160
acres of land. However, this amount of readily developable
waterfront property and linear feet of shoreline is not now
available, (p. 8-6)

(ii). This report indicates that forecast demand for
port space over the next 10-20 years will be greater than the current available
space. Since the plan contemplates a much longer time frame than 20 years, it
is not unreasonable to assume for planning purposes the need for additional
space which the GHEMP envisions prior to there being a "demonstrated need" at
the time of plan adoption.

(d). Another recent analysis and evaluation was conducted
by the Corps on the need and desirability of widening and deepening the present
Federal navigation channel in order to accommodate the export demand of existing
wood products in the "Interim Feasibility Report and Final Environmental Impact
Statement, Grays Harbor, Chehalis and Hoquiam Rivers, Washington Channel
Improvements for Navigation," (Appendix C) September 1982. That evaluation is
incorporated into this PEIS by reference because of its relevance to the
alternatives analysis for existing and future port/industrial expansion needs.
While the Corps projected demands for future exports are more conservative for
some products (e.g., logs & wood chips) than the "1980 Ports Systems Study,"
the evaluation pointed out the following with respect to future growth.

Forestry

Many of the area mills need replacing with modern, more efficient
processing facilities, a shift that is expected to accelerate in
the future provding adequate sites are available. (p. C-9)

Forest Products Exports

With respect to the substantial increases in log exports to Japan,
Korea and China over the last decade, the report concludes:
This favorable trend indicates a significant economic development
potential that may have long-term implications on the structure
of the forest products industry in the region. (p. C-10)
Markets in China and other Pacific Rim Countries have enormous
growth potential and are just beginning to develop, (p. C-19)

11-39

Shipping Activities

This significant growth in harbor tonnage primarily reflects a
strong general uptrend in exports loadings of logs and lumber
over the last decade. Future growth of waterborne commerce
moving through the port will depend on a variety of factors
including world demand, improvements to the navigation channel,
adequate industrial land, and diversification of the export
base. (p. C-12)

Principal Commodities

Although new commodities look to be a definite part of the future
in Grays Harbor, the commodity types and volumes, as well as
vessels used to transport them, are unknown at this time. Accord-
ingly, no benefits were claimed for induced commodity movements.

The Corps eliminated other existing west coast ports (including Willapa,
Olympia, Tacoma, and Longview) and one planned port (Weyerhaeuser 's DuPont
facility) from further alternatives consideration after determining the exces-
sive overland transportation costs associated with transferring Grays Harbor
forest products to these areas (Interim Feasibility Report, p. 17). While al-
ternative port sites are eliminated from further consideration for the purpose
of port/industrial expansion related to forest products, the siting of non-
forest products industries is another matter. The siting of future energy or
industrial facilities may still have to consider alternative port locations
during the permit or EIS review period in order to avoid the utilization of
wetlands on a case-by-case basis. But what the GHEMP has attempted to do is
to recognize not only of the needs for the forest, fishery and tourism interests,
but also to allow for diversification, something that is seen as vital to the
economic survival of the region.

(e). Industrial Land Requi rements J

The economy of Grays Harbor is heavily dependent on the forest products indus-
try. Forest products are followed in importance by tourism and fishing as
the basic components of the region's economy.

In terms of land area, forest products handling and processing continue to be
the biggest users of industrial land. Waterfront sites are needed in order to
have access to the deep water navigation channel through which markets are
reached.

During the past several decades a significant change in the typical wood pro-
ducts site has come about. Fifty years ago the Grays Harbor waterfront was
dotted with dozens of sawmills and shipping docks. Logs were rafted (floated)
from the forests to these sites, to be brought ashore, processed, and loaded
aboard relatively small vessels. Land requirements were modest by today's
standards, involving only a mill site and a relatively small area to accumulate
the next shipment.

1. Stan Lattin, Director of Planning, Port of Grays Harbor (personal communica-
tion, 1/24/83).

11-40

Today, forest product industries generally receive logs by trucks. The logs
are handled and sorted on upland sites, and diverted into one of several pro-
duct streams, i.e., export milling, peeling, or chipping. These operations
have simply outgrown the industrial sites of the 1930's and 40's. Further,
because many of these older sites have been surrounded by other land use
types, site expansion is all but impossible.

A somewhat similar thing has happened to marine terminals. Economics have
forced shippers into larger vessels. The cost of these ships requires quick
loading for fast turn-around and maximum utilization. Cargoes 8-10 times the
volume of smaller ships must be accumulated near the terminal to facilitate
such quick loading. Further, with ship turn-around time measured in days
instead of weeks, cargoes must be amassed for a steady succession of vessels.

By way of example, for almost 40 years the Port of Grays Harbor operated four
marine terminal berths from an upland base of less than eight acres. Today,
the Port operates three marine terminal berths with an upland base of 145 acres
(see photo 3 for example of new terminal).

Studies^ have shown that future production from forests tributary to Grays
Harbor will be significantly higher. Greater forest yield coupled with in-
creasing reliance on foreign markets will result in additional demand for large
waterfront sites.

While it has long been held that diversification of the economic base of Grays
Harbor is necessary ("Overall Economic Development Program for Grays Harbor,"
1961), the recession of the past several years has all but made diversification
essential. Unlike previous economic downturns, the current recession is result-
ing in profound changes in the forest product industries. Economic recovery
may bring a return to historic production levels, but because of technological
and mechanical advances, fewer people are going to be employed.

Diversified industry likely to be attracted to Grays Harbor will most probably
be linked to one of the region's assets - its deep draft navigation channel,
its location on the Pacific Ocean, its proximity to the United States' Pacific
Rim trading partners, or its location relative to Alaska. A common denomina-
tor for industries able to capitalize on these assets is the need for a water-
front location.

Various factors combine to shape the relative suitability of an individual site
for a particular activity. On Grays Harbor it can be said that sites along the
north side of the channel in Aberdeen and Hoquiam have the greatest suitability
for water dependent industry. This results from their close proximity to the
navigation channel, and in the case of sites downstream from the highway and
railroad bridges, unimpeded vessel access and necessary support infrastructure.
By way of contrast, sites on the southside of the channel, downstream from
the bridges, have severe limitations on cargoes that can be efficiently and
economically handled because of the distance to the channel. In general, it
appears feasible to handle certain bulk commodities, i.e., coal or grain,
on conveyor systems, whereas heavy, large commodities, ie., logs and lumber,
would not be practicable.

"Forest tributary to the Port of Grays Harbor," Greenacres Consulting Corps.,
1977.

11-41

Photograph 3.
Port of Grays Harbor Shipping Terminal

11-42

One of Grays Harbor's major industrial waterfront sites (at the mouth of the
Hoquiam River), has recently been optioned for sale to the U.S. Borax Corp.
for a molybdenum processing site. Ore mined in southeast Alaska will be
shipped to the site, and supplies needed at the mine will be accumulated at
the site and shipped to Alaska. The project will satisfy a long-standing goal
of the present site owner, the Port of Grays Harbor, to attract industry
which will diversify the economic base.

The only other available publicly owned industrial site is the recently filled
176-acre parcel on the south shore of Grays Harbor. Feasibility studies have
been completed to evaluate use of the site for transshipping coal. Because of
distance to the channel, (+2000 feet), some type of bulk commodity appears to
be the only cargo which can be effectively handled. Also, completion of the
Grays Harbor Deeper Draft Project is critical to the economics of utilizing
this site.

Consideration has been given to converting public terminal number 2 (72 acres)
to a diversified bulk commodity transshipment facility. Because of the high
cost (estimated $25 million) and lack of a confirmed need, no action has been
taken to date. The terminal continues to be used for shipment of wood products,
and supplemental -diversified cargoes are being sought.

Concerning development of additional publically owned industrial sites, mention
must be made of the excessively long lead time needed to prepare a site for
occupancy. With the use of dredged material for fill, site preparation time
is typically measured in years. Seldom are industrial prospects able to make
such a long range commitment to "future" sites. Indeed, it seems apparent
that preparation of industrial sites in advance of demonstrated need can have
a positive effect on economic development and creation of employment.

11-43

E. URBAN MANAGEMENT UNIT DESIGNATION ALTERNATIVES

Urban environment designations have the greatest potential for permitting
alterations of the estuarine and adjacent upland environment. A review of the
Standard Uses Matrix and the forty-three Permitted Activities Matrices show
that port and industrial facilities siting, transportation and commercial uses
are found primarily in the UD/UM and UR environments. Therefore, alternatives
to Urban environment designations are reviewed in this section.

1. UNIT 4: URBAN MIXED

Purpose of Designation: This designation provides an area on North
Bay for small boat moorage.

Existing Attributes: This unit is the site of an existing boat basin
and, therefore, a modified aquatic environment.

Planned Use Composition: Water- dependent uses are planned in this
unit. The use matrix does permit uses generally related to marina complexes,
though such uses themselves may not be water dependent. Since no filling of
the marina is permitted, these uses would be restricted generally to upland
sites. Management objectives of the unit would rule out those conditional uses
which would not reinforce the marina or the recreational opportunities afforded
by this area. Planning area guidelines further direct conditional use concerns.
Consequently, the plan provides for a water-dependent use (marina) in the
water areas and for a mixed, but mutually reinforcing, water-related use
composition in the upland. This is the only management unit of this charac-
ter on North Bay.

Alternatives: The combination of uses described above must either be
in the water or be of a distinctly different quality. Use of any other aquatic
area on North Bay would involve greater disruption of the aquatic environment
than this site. Since there is an existing marina located at this site, no
further alternatives need be considered. Once the marina has been developed
to its maximum and there is additional demand, the Westport boat basin could
serve as a potential alternative site to meet future demand for the residents
of Ocean Shores as well as the potential waterfront park and marina in MU 17.

2. UNIT 5: URBAN RESIDENTIAL

Purpose: This unit provides a waterfront area for residential use
at urban densities.

Existing Attributes: This area is already platted, has developed
residential lots, and may be considered committed to residential use (see
photo 4).

Planned Use Composition: The plan recognizes the existing commit-
ment "to residential use," but severely limits further waterward intrusion.
The plan permits bankline modifications only to the extent necessary to protect
existing lots.

11-44

Photograph 4.
Bayside view of Ocean Shores looking west.

11-45

Alternatives: This site does not have any access from deeper water to
support water-dependent uses. Water-related commercial uses would not be desir-
able in terms of the upland planning concerns of the city. Since future resi-
dential use would be limited to developed lots, this area is not suitable for
a Conservancy designation. It should be noted that the Urban Residential
management category is used only twice in the plan (here and in a very limited
area in MU 21-Central Park); thus, the opportunity for waterfront residential
uses is very limited.

3. UNIT 6: URBAN MIXED/NATURAL

Purpose: The primary objective of this management unit is to provide
a site for a new airport serving the north beach area of the county while
protecting the remaining salt marsh.

Existing Attributes: This site is composed of a large transitional
salt marsh bounded on the landward side by a line of platted residential lots
(see photo 5).

Planned Use: An airport is specifically provided for on the watermost
portion of the marsh area and the easternmost residential lots. The remainder
of marsh, approximately 190 acres, would then be designated "natural" and
development rights to it would be transferred to an appropriate state agency.
The remaining lots may be developed for residential purposes.

Alternatives: Alternative issues and considerations are addressed in
the Federal Final Environmental Impact Statement^ on the airport. Additional
considerations are addressed in the management unit itself.

Additional Considerations: The entire marsh site has a unique owner-
ship status. When the Ocean Shores project was originally developed, one of
the many commitments made by the developer was that an airport adequate to
serve the needs of the community would be built on this site. When the city
of Ocean Shores was formed in 1970, no airport was constructed by the developer
and a class action suit was brought to have such a facility built. A court
ordered (Docket #754-489, King County) that the land be made available to the
city for the purpose of building an airport. However, the court also ruled
that if such an airport were not constructed, the property would revert to the
development company (see page 60 of Ocean Shores Airport FEIS). Mitigation was
required as a condition of any filling in the wetlands.

4. UNIT 11: URBAN DEVELOPMENT

Purpose: The purpose of this unit designation is to recognize the
existing transportation corridor that uses most of the land in the unit.
Because of the intensity of use in the area, urban development was considered
the appropriate designation.

1 Federal Aviation Administration, Ocean Shores Aiport FEIS, December 1981

11-46

Photograph 5.
Ocean Shores Existing Air Terminal and Proposed New Terminal Site.

3 77

.*■<*•> ""I>i»

Existing Terminal

d Terminal (approx. location)

11-47

Existing Attributes: The unit is almost completely composed of a
railroad and highway corridor.

Planned Use: Continuation of the area's role as a transportation
corridor.

Alternatives: Relocation of both the highway and railroad would be
practically difficult and highly expensive. Any alternative relocation would
be through rugged terrain characterized by sharp, highly unstable slopes. Funds
to support highway relocation are not available, and relocation of the rail line
would probably not be cost effective. Impacts and alternatives resulting from
highway improvements associated with a dangerous curve were evaluated through a
Corps of Engineers permit No. 071 -0YB-2-005073.

The Standard Use Matrix allows roads and railroad use in Rural Low Intensity
and Rural Agriculture MU's as well, so a transportation corridor would not be an
inappropriate use. Since the earlier assumption of designating MU 12 (Area 1)
for UD use is no longer a valid consideration, this designation could be cat-
egorized as RL, thereby being more compatible with the adjacent uses both
south and north of the highway/railway. Because of the constraints to any
other types of development south of the railroad right-of-way, the impacts
associated with the designation of UD or RL are not expected to be significant
or different.

5. UNIT 12: (Areas 1, 2, 3, 4, 5 and 6) SPECIAL

Purpose: Unit 12 is intended to provide an area of sufficient size
through the phased fill of estuarine habitat to allow greater water dependent
industrial expansion over a long-term period along the North Navigation
Channel, while providing permanent protection to some of the significant fish
and wildlife habitats.

Existing Attributes: The site (excluding the existing Bowerman Air
port - Area 5), is approximately 2200 acres in size. The particular character-
istics of this general area have been described in Maintenance Dredging and the
Environment of Grays Harbor and in appendix C of this document. Because of
its characteristics, the area represents a classic conflict between resource
use and protection.

Planned Uses: Area 1 - Natural, 1700 acres of intertidal mudflats
and fringe marshes will be preserved for the protection of significant shore-
bird habitat. The transfer of land through fee title represents in part the
commitment of the Port of Grays Harbor to the plan. The proposed transfer of
land is an attempt to provide a better balance by avoiding unacceptable adverse
impacts to the aquatic ecosystem that would result from future fills in MU 12.
If the plan is adopted, the Port would request predesignation of the site as
unacceptable for disposal or fill even before title has changed hands to the
State Department of Game. Future land and water use would be the equiva-
lent of a Natural environment designation and the intertidal area would serve
as a fish and wildlife santuary. Habitat enhancement projects may be deemed
appropriate in the area (see photographs 6 & 7).

II- 48

11-49

Js"7

Photograph 7. Management Unit 12 absent Area 4 designation,

11-50

Area 2 - Urban Development, 164 acres, would be filled for the purpose
of allowing a major multi -commodity, bulk loading and off-loading facility.

Area 3 - Urban Development, 73 acres, would be filled for the relocation
of the Bowerman Airport when all or a majority of the existing airfield area
is proposed for water dependent industrial use. The fill will be the minimum
amount necessary to accommodate an FAA approved Instrument Landing System (ILS)
Commuter Airport. The maximum line of fill is limited to 750 feet to the
north.

Area 4 - Special, approximately 243 acres, has a designation which
denotes that neither the location nor the commitment to fill this area
are implied. However, when the need arises, the area depicted on the map
(or another area) could be filled for water dependent uses (note: see restric-
tions in GHEMP, p. 66).

Area 5 - Urban Development, includes the existing Bowerman Airfield.
This site is perhaps the most suitable remaining water dependent site for
future large scale industrial and port use in the harbor, provided that the
necessary piers can be economically and environmentally constructed. However,
the site will continue to be utilized as the major airport in the region until
such time more demand for the land exists and legal and financial consider-
ations can be resolved.

Area 6 - Conservancy Managed, consists of the intertidal mudflats south
of the Airfield (and Area 2) to the navigation channel. In all cases, access
to the channel for water dependent uses is provided by means of "T" docks,
with only limited filling permitted. Taking Areas 2, 4 and 5 into considera-
tion, MU 12 provides a long-term program for future port/industrial development.
The ability to reuse and redevelop the Bowerman Field for port and industrial
purposes by permitting the airport landing strip to be located north of the
existing one and combined with the provisions of the other industrial areas in
the plan, should readily meet the potential economic needs of the region
for the forseeable future.

Alternative Considerations: This area is owned by the Port of Grays
Harbor. Alternatives which have been considered by the Task Force include:

o designate the entire area as Urban and allow water-dependent, water-
related, and other uses which would benefit the local economy.

o fill all 500 acres north of the Bowerman Airfield; and

o relocate Bowerman Airport and use the peninsula as an industrial site.

o fill tidelands south to the navigation channel.

All four major alternatives have been rejected by the Task Force mem-
bers as either being environmentally, legally or economically unacceptable.
The following factors were considered.

a. Designate entire area as Urban. Filling 2200 acres of aquatic
area during a short-term or long-term period was rejected based on unacceptable
adverse environmental impacts and failure to comply with current Federal and
State statutes.

11-51

b. Fill 500 acres north of the Airfield. The November 1978 prelimi-
nary draft version of the GHEMP which was circulated to the public proposed a
phased fill of the area north of the Airfield (see figure 8)« Again, based
upon comments received from the public and review of the proposal for consis-
tency with the 404(b)(1) Guidelines and Section 7 (Endangered Species) consul-
tation, this alternative was found environmentally unacceptable.

c. Relocate Bowerman Airport and use the peninsula for port and in-
dustrial expansion. Alternative sites for relocating the Bowerman Airport were
considered in Bowerman Field Relocation Planning Study, 1979 by prepared by the
firm of CH2M Hi 1 1 . The conclusion of that study was that "there is no oppor-
tunity to locate a new Basic Transport airport in the 1,200-square-mile study
area that would readily serve the population base and be environmentally and
economically prudent to develop." (p. 97). Three sites outside of the estuary
were identified which might serve as a General Utility category airport. However
the existing use of the site as an airport and legal commitments made by the Port
prevent for 20 years its use for purposes other than as an airport. Since
Bowerman Field is the regional airport facility, its relocation would also
require significant capital investment. By placing a new runway north of the
existing runway, costs would be kept to minimum since a new tower and other
fixed structures would not have to be built and the airport remains in a
position which best serves the region and has the greatest aviational safety
features. Relocation of the Airfield was rejected for legal and economic
reasons at the time. However, the filling of Area 3 is contingent upon sever-
al integral actions:

(1). That it be done only to accommodate the relocation of the
Bowerman Airfield.

(2). That it can only take place if all or a majority of the
existing Airfield is proposed for water-dependent industrial use.

(3). If Area 2 is filled prior to a permit application in Area 3,
an evaluation of filling Area 2 will be conducted as part of the permit review
process in order to determine whether environmental conditions have changed
sufficiently as a result of Area 2 fill to demonstrate that other alternative
airport sites would be less damaging. This condition resulted over the concern
for the shorebird/raptor population. As a consequence the possibility of not
filling the area for airport relocation is not precluded.

d. Filling the tidelands south of the peninsula was considered but
rejected as having unacceptable adverse impacts on fishery resources.

Alternative Sites: As was previously stated in the alternatives dis-
cussion, alternative sites for port and related industrial expansion were
considered. Part of the criteria which were used include the availability of
infrastructure including rail, road and air service, industrial water supply
and sanitary services, and power supply. Additional site specific services
including fire and police protection, business services and industrial sup-
pliers were also important. Given these factors and the importance of pro-
tecting the fish passage, Task Force members feel that port expansion for
water dependent uses (including use for some wetlands fill for the airport
runway) in this area is justifiable and, with the inclusion of mitigation and
enhancement projects and monitoring of impacts, that the current designation
of MU 12 as identified in the plan would not be considered an unacceptable
adverse environmental impact. For a discussion of impacts, see appendix C.

11-52

FIGURE 8

Previous management alternative to Management Unit 12
(then MU's 12 & 13). April 1978 Draft GHEMP.

11-53

6. UNIT 14: URBAN DEVELOPMENT

Purpose: The purpose of this management designation in MU 14 is to
recognize the strategic location of this unit between the navigation channel
and the prime regional industrial area. However, the uses and activity which
would modify the aquatic area in and adjacent to this unit are limited in
order to conserve the area's significant biological resources.

Existing Attributes: The upland portion of this management unit is
a developing industrial area of regional significance and it would serve as a
link to the planned industrial area in MU 12. The bankline within this unit
is also considered important for fish migration and feeding.

Planned Uses: The upland portion of this unit would be designated
Urban Development with encouragement for location of water oriented industry
(as provided in the special conditions in MU 12). While a diverse range of
uses is allowed in the unit's use matrix, the area's value as an industrial
location and its existing use commitments will direct the unit toward regional
industrial development. Any use of the aquatic area is limited by the Activi-
ties Matrix and the special conditions for water dependent structures (with
very limited fill for approach) which would provide access to the navigation
channel. Also, the special conditions severely limit such activities from
destroying migration routes or critical feeding areas.

Alternative Considerations: The existing developed character of the
upland area of this unit makes its designation as another management category
unrealistic. Also, for reasons similar to those discussed in MU 12, this
general area is one of the most appropriate areas for industrial uses (MU 14,
however, cannot fulfill the role envisioned for Unit 12 as a future indus-
trial park due to MU 14 's existing uses). The proximity of MU 14 to the
navigation channel and to other developed and planned industrial areas makes
it an optimum location for the proposed piers. No other site can serve the
general industrial area of Hoquiam as well.

An alternative designation to UD would be to make this a split MU with
a Conservancy Managed designation to protect the important fishery habitat
area. Because the boundary was changed to include the fish base within MU 44,
this alternative is no longer necessary.

7. UNIT 15: URBAN DEVELOPMENT

Purpose: The purpose of this designation is to recognize the exist-
ing development commitment in this area.

Existing Attributes: This unit presently has the major concentration
of heavy industrial related activities in the region. Activities include the
major marine terminals, a pulp and paper mill, a modern computerized saw mill,
and gravel load and unloading facilities.

11-54

Planned Uses : The site will be used for heavy industrial purposes
with emphasis on water-dependent and related uses. As noted, it is unlikely
that non-water related uses would be established in the area due to its
present use character and other legal commitments. The other likely possi-
bility would be the development of a water-related processing plant by the
private terminal owner of the upland portion of this property. The Port
owned Kaiser site is currently not being utilized but is considered by the
U.S. Borax Corp. for possible option to purchase the site. Filling and/or
development of the existing Port slips would be allowed.

Alternative Considerations: The existing character of this unit makes
an alternative designation impractical. Alteration of the aquatic area would
be restricted to either a water-dependent use or a purpose which is directly
related to the present water-dependent uses (see photo 8).

8. UNIT 16: URBAN MIXED

Purpose: The purpose of this unit designation is to recognize its
proximity to the Aberdeen Central Business District and the Chehalis River,
two major sources of commercial and industrial activity. Within this unit
a unique mix of commercial and industrial uses is encouraged to continue and
develop in the future. Public access to the waterfront is to be designed
into new and rehabilitated projects when practicable.

Existing Attributes: This unit and adjacent areas are in the process
of reorientation from a predominantly industrial area to a finer intermix of
commercial and industrial uses, an intermix which was originally established
in early Aberdeen. Some sites within the unit are badly deteriorated and are
in need of rehabilitation or redevelopment.

Planned Uses: This unit is designated UM to permit continuation of
existing development and encourage future reinvestment in commercial and
industrial ventures. Water area modifications are permitted for two reasons--
to allow water dependent uses or to encourage the rehabilitation and the
development of uses which would promote the revital ization of this area; uses
that would, where appropriate, help provide increased public access to the
waterfront.

Alternative Considerations: The existing and developing character
of this MU makes an alternative designation impractical. The sites within
this area are too small for most water-dependent uses. The rail facilities
bordering the area limit the potential to expand the sites. These rail
facilities also severely constrain the portion of this area between the rail-
yard and the Chehalis River.

In all cases, the waterward extent of any modification is limited in
order to protect the fish migration route (the fish passage).

II- 55

Photograph 8. Management Units 14, 15 and 43.

11-56

9. UNIT 17: URBAN MIXED

Purpose: This unit designation recognizes the unique potential of
this area to provide greater public access to the water area and to permit the
continued redevelopment of a previously heavily used industrial area of the
shoreline.

Existing Attributes: This unit is in the process of transition.
Historically, it was a heavy industrial area. As site requirements became
greater for industry, the small mills located here were abandoned, creating an
unused and visually unattractive area which has persisted for many years.
Due to many factors, including site limitations, the redevelopment of this
area for industry has become impracticable. However, the area's strategic
location in relation to the regional traffic flows has already made it a prime
site for commercial development. As a commercial area, the unit also offers
greatly improved public access to the waterfront.

Planned Uses: The continued development and rehabilitation of the
unit from an obsolete and debilitated industrial area into a commercial and
public access area is envisioned by the plan. Water area modifications which
may be conducted here are directed toward several purposes:

o Protecting shore uses,

o Providing opportunity to rehabilitate the waterfront,

o Increasing public access and opportunity to enjoy the water-
front (see figure 9, a proposed site plan for the Aberdeen
Riverfront Marina Park),

o Allowing limited development of any water dependent use which
might be permitted.

Alternative Considerations: This unit's strategic location in rela-
tion to regional traffic flows makes it the optimum commercial area in the
region. As such, it has an opportunity to meet growing regional commercial
needs. This potential > coupled with both the site's poor suitability for
major new industrial or large water-dependent activity and its former blighted
condition, has made its commercially oriented designation appropriate. Given
the industrial use and designation of most of the urban waterfront, this unit
offers one of the yery few opportunities for the development of public access
to the urban waterfront environment. This capability also gives the unit a
potential for development in tourism related activities, an important sector
of the local economy. Possible alternatives include Urban Development desig-
nation and encourage more intensive use of the area for industrial purposes.

11-57

UJ

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CD

11-58

10. UNIT 18: URBAN DEVELOPMENT/NATURAL

Purpose: The purpose of this unit's designation is to provide the
opportunity for heavy industrial use, while protecting significant biological
resources of the area.

Existing Attributes: The unit is an old, blighted industrial /resi-
dential area infused into an area of mixed freshwater and upland environments.
The unit also encompasses portions of Elliot Slough. Riparian vegetation along
the slough is important for habitat and flood retention. The unit is adjacent
to the main body of the Chehalis River and therefore offers access to the
navigation channel. Ownership in the unit is predominantly private.

Planned Uses: Uses planned for the area are intended to balance the
provision of opportunity for industrial development with preservation of Elliot
Slough, particularly important freshwater marsh areas, and aquatic vegetation.
Consequently, this proposal for use involves the complex division of the unit
into "Urban Development" and "Natural" subdesignations (see photo 9). These
designations were made upon the basis of detailed biological analysis and
specific negotiations with the property owners.

Alternative Considerations: Modification of the saltwater aquatic
area consists primarily of water-dependent activities (boat houses or access
to navigation channel); facilities to protect upland uses; and a very limited
amount of bankline straightening (where essential to maintain the function of
the proposed upland use), or facilities intrinsically related to the area
(outfalls or cable and pipeline crossing). Consequently, these attributes
cannot practically be located away from the shoreline and still serve a
viable function. Designation of the upland portion of the unit as an urban
development area is based in part on its existing character and ownership.

Unit 18' s access to the navigation channel offers the potential for ex-
pansion of water dependent/related industrial development. Much of the area
is considered as potential upland sites for the disposal of dredged material.
While no alternative appears to be practical, designating some of the yet
undeveloped parcels of land as Conservancy or Natural is possible.

11. UNIT 21: URBAN RESIDENTIAL

Purpose: This designation recognizes the existing use and quality
of the unit.

Existing Attributes: The unit is a small area of residential develop-
ment on the upland edge of the expanse of fresh water swamp found in this
planning area. The unit was separated from the adjacent "Conservancy" and
"Rural" units because of its distinctly different character (see photo 10).

Planned Uses: Residential with opportunity for development of compat-
ible uses. Aggregate extraction is a permitted use.

Alternative Considerations: Since it is impractical to relocate exist-
ing uses, and because such relocation would result in little enhancement of the
resource, no alternative site option seems realistic.

11-59

Photograph 9. Management Units 18, 19 & 20,

11-60

■■MB*-* : .«a?»«ffiRM-,#,!

Photograph 10. Management Unit 21.

11-61

12. UNIT 25: URBAN DEVELOPMENT

Purpose: The purpose of this designation is to recognize the estab-
lished role of this unit and its need for redevelopment of blighted areas. As
such, its existence also establishes a transition between its urban uses and
the Conservancy units upstream.

Existing Character: Similar to Unit 16, this unit has a diverse make-
up of urban uses, ranging from a large pulp mill to boat ramps and a small
park. It has been the site of several lumber mills which have passed or are
approaching the end of their usable lives. Consequently, there are several
areas of existing or potential blight in this unit. The unit also encompases
the proposed industrial expansion location needed by one of the region's major
employers.

Planned Uses: This designation envisions a continued and gradual re-
de velopmenF~oT~tnT~unTt's Urban Development character. It also provides some
room for growth for the existing pulp mill.

Alternative Considerations: Since the management decisions for this
unit are related to existing uses or the presence of blighted areas, the pur-
poses served by the unit cannot be provided elsewhere. The pulp mill operation
cannot be feasibly expanded except into the area provided for by the plan (see
photo 11 ).

13. UNIT 26: URBAN DEVELOPMENT/CONSERVANCY MANAGED

Purpose: The purposes of this split unit are to protect the critical
role that its aquatic vegetation serves for fish migration and feeding, and to
recognize its role for potential industrial uses.

Existing Attributes: The existing area has a complex mix of uses and
roles. On the water side of the railroad line is an expanse of marshland
(designated as CM) of significant biological importance, particularly for
supporting fish migration. Within this area is an old saw mill originally
established at its site for access to log rafting. The waste treatment lagoons
for the Weyerhauser Pulp Mill are also found here. On the land side of this
unit (designated as UD) are established residential uses in the north por-
tion, and diked old farming areas (including a junk yard) with a fringe
of marsh along the creeks. Some freshwater marsh areas are also associated
with the diked areas, which were once used for farming, but now have become
marshland due to lack of active use. The Port has also been using one of
these former pastures for contained maintenance dredge material disposal and
has requested a permit from the Corps of Engineers to allow additional disposal
in 98 acres for purposes of maintenance dredge disposal. The Corps is currently
reviewing that request through the standard permit process procedures (see
figure lQ) and is in the process of preparing an environmental impact statement.

Planned Uses: All new development north of the railroad (except for
reasonable maintenance of the existing mill) must be water dependent, and
would be limited in order to protect the resource role of the aquatic vegeta-
tion. Development would be permitted landward of the rail line. It is envi-
sioned that after the site is filled, these areas will become industrial sites.

11-62

Photograph 11. Management Unit 25.

11-63

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11-64

This unit is one of the few that poses relatively minor development problems:
it can be protected from floods, is within range of urban services, has good
highway and rail access, has relatively minor land use conflicts, and is more
suitable than any other area which lacks good water access. This is the only
other area in Grays Harbor which allows for major, long-term industrial expan-
sion where the land is not already committed to industrial uses. The major
loss would be to approximately 98 acres of fresh water marshes south of the
railroad line (see photo 12). The plan ensures that the riparian vegetation
along Charley and Newskah Creeks will be protected in a 50 foot -wide, no-
development buffer strip.

Alternative Considerations: This unit has significant resource values
due to its aquatic vegetation and anadromous fish creeks (Newskah and Charley).
The shoreline is currently classified as Urban under the existing SMP so the
proposed classification would reduce existing allowable uses. The Task Force
did not ignore the potential access to the channel, which would be provided
by means of a trestle. Consequently, the plan leaves the potential for
water dependent use possible under appropriate control to guard the salt water
marshes and creek habitats.

Alternatives would be to classify the area as RA/RL or CM throughout,
thereby precluding any future industrial development. Alternatively, the
salt water marsh area north of the railroad is currently zoned industrial
and could serve for future industrial expansion if designated UD.

14. UNIT 28: URBAN DEVELOPMENT/CONSERVANCY MANAGED

Purpose: The purpose of this designation is to recognize past and
present use of this unit for food processing activities and other urban uses
which might be related to these activities, while conserving adjacent aquatic
resources.

Existing Attributes: This area has a large cranberry processing
plant and assorted oyster harvesting activities. Located at the mouth of the
Johns River, the unit constitutes the only significant cluster of urban uses
and one of the few opportunities for small craft navigation facilities on the
entire south shore of the estuary between Aberdeen and Westport.

Planned Uses: The planned uses of this unit consist of continuation
of the existing cranberry and oyster activities along with construction of
limited docks and other navigation facilities to support water dependent activ-
ity. Most of the wetland character of the area's aquatic vegetation would be
protected.

Alternative Considerations: Since the planned development activi-
ties are related to the existing character of this site, any alternative
area could not serve the same purpose and have fewer impacts. All aquatic
activities are limited to water dependency. The opportunity for industrial
activities would be limited to this one site for the entire South Bay.

II- 65

Photograph 12. Management Unit 26

11-66

15. UNIT 33: URBAN MIXED/CONSERVANCY MANAGED

Purpose: The designation recognizes the existence of a transporta-
tion corridor crossing the Elk River Estuary at the eastern end of the bridge
crossing the Elk River (see photo 13).

Existing Character: The unit is a small area consisting of the end
of a highway bridge anci an assortment of residential and other urban uses
concentrated in Bay City.

Planned Uses: Planning for the unit envisions continuation and
limited expansion of existing uses and activities. Aquatic modifications are
limited to small docks associated with upland residences and those activities
associated with the bridge and utility crossing.

Alternative Considerations: Since the character of the existing
area and any potential growth T~s related to the bridge crossing, and since
this bridge is the only feasible crossing point, no other management designa-
tion alternative for this unit is possible.

16. UNIT 35: URBAN MIXED/CONSERVANCY MANAGED

Purpose: The purpose of this unit is to recognize the area including
the western end of the bridge crossing the Elk River Estuary.

Existing Attributes: The character of this unit is similar to but
less developed than Unit 33.

Planned Uses: Same as Unit 33.

Alternative Considerations: Same as Unit 33.

17. UNIT 37: URBAN MIXED/CONSERVANCY MANAGED

Purpose: This management unit establishes an eastern line of limi-
tation for tTie encroachment of urban uses into the shoreline environment.

Existing Character: The unit is composed of mixed urban use (primar-
ily residential) on its uplands and includes an expanse or transitional marsh.
The marsh is used for grazing.

Planned Uses: Continued development of the uplands for urban uses
as may be appropriate for the needs of the City of Westport, and conservation
of the area below the 404 line for its natural resource values. There is
considerable marsh in the eastern portion which will be preserved in its
natural state.

Alternative Considerations: The proximity of this unit to the high-
way provides suitable access for residential development. While such urban
uses might be relocated to alternative sites, the incorporated nature of
this area and the presence of urban services make it suitable for such use
without significantly injuring resource values.

11-67

Photograph 13. Management Units 33, 34 & 35.

11-68

18. UNIT 38: URBAN MIXED/CONSERVANCY NATURAL

Purpose: This designation recognizes the existing dual role of this
unit both in providing Westport's airport and in serving as a marsh area.

Existing Attributes: The unit has two uses, as an airport and as a
marsh area.

Planned Use: The plan permits, but strictly limits, some develop-
ment and improvements to the existing airport (runway). It protects the
remaining marsh area (except for allowing some possibility for expansion of
the Westport Marina). The retention and eventual upgrading of the airport
is important to both Westport's role as the major sport fishing port in the
region and to efforts to diversify the local and regional economies by expand-
ing the use of other recreational opportunities in the Westport area.

Alternative Considerations: The present site has been used as an
airport for many years and these activities have modified the character of
the site (see photo 14). Therefore, the no action alternative would not
prevent the present use of the high marsh wetlands for the grassy airport
runway.

Because of the topography and existing land use patterns of the Westport
area, few sites if any are well suited for airport development. Because of
the longterm use of this site and location of uses which would conflict with
an airport at other sites, continuation of the airport in this location is the
most viable alternative. The airport improvements which would be possible
under the plan would only be the minimum necessary for a standard small air-
craft landing facility. The plan contains specific provisions limiting the
extent of the fill that may be permitted to minimize the potential adverse
impacts which might result (GHEMP, p. 99).

19. UNIT 39: URBAN MIXED

Purpose: This unit provides for the future expansion of the region's
major marina. Ks such, it significantly benefits the economic base of the
region and provides access to water recreation for thousands of people annually.
It is one of the most important water recreation facilities of the entire
State.

Existing Attributes: Most of the unit consists of the Westport
Marina and related activities. It does include a significant marsh area to
the south and large undeveloped areas west and upland from the marina.

Planned Uses: The area is expected to allow future expansion of the
marina with related upland uses and services. A major role of the facility
would be to continue to provide and develop public access to the shore and the
recreational opportunities of sport fishing as well as providing additional
development opportunity in the commercial seafood industry. The Port would
contemplate expansion only when sufficient demand for additional port slips
justifies the economic costs related to the expansion.

11-69

Photograph 14. Management Unit 38 - Westport Airport

11-70

Alternative Considerations: A marina is a water dependent use.
Consequently, no alternative site would be feasible unless such site also was
an aquatic area with suitable navigation access. Other limits under present
Corps programs restrict alternatives to the present basin or along the main
navigation channel (the access to the Ocean Shore Marina is not Federally
maintained). Winter storms and heavy seas make this area unsuitable for large
vessels. Use of another area would require channel development with related
adverse environmental impacts. Combining future marina development with the
existing facility allows greater economies of scale and reduces the potential
of increasing adverse environmental problems. Such a combination also permits
provision of the necessary public services (especially those needed for water
quality) in an efficient and effective manner.

One expansion of the existing marina has already been completed within
the existing basin (see figure H). The plan would contemplate a second marina
expansion into the wetlands (approx. 48 acres of submerged, intertidal and
marsh wetlands to be dredged and/or filled) south of the existing marina for
additional commercial and recreational boating sometime in the future.

11-71

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11-72

F. MEANS OF IMPLEMENTATION

1. The GHEMP contains several mechanisms to implement both protection
and development of the estuary. They include:

a. A commitment by the various participating parties to utilize the
plan in their decisionmaking and abide by the precepts of the plan insofar as
provisions of law allow.

b. Permanent protection of a vulnerable area in MU 12 (Area 1) as
a natural area.

c. Predesignation of MU 12 for non-disposal /f il 1 in Area 1 and Areas
2 and 3 for the discharge of dredged or fill materials for water dependent
industrial uses.

d. Establishment of an intergovernmental ly recognized balance of
estuarine use and protection which will only be changed through the amendment
process after Task Force review.

2. Various additional means of implementing the GHEMP to either facilitate
development or provide more permanent protection of the aquatic resources are
considered below.

a. Regional Permit.

(1). Although not a requirement of plan implementation, the
U.S. Army Corps of Engineers, Seattle District, is considering the development
of a Regional Permit for certain work in tidal waters of the estuary from
Montesano to the Pacific Ocean. The proposed Regional Permit would implement
Section 10 of the Rivers and Harbors Act of March 3, 1899 (33 U.S.C. 403), and
Section 404 of the Clean Water Act. The work which would be authorized by the
proposed Regional Permit could proceed on the basis of the Regional Permit
without the requirement for an individual project specific permit. The project
authorized by such a Regional Permit might be limited to some of those identi-
fied by the GHEMP as a "Permitted Activity." The Regional Permit would only
satisfy Federal law and not State and local requirements including leasing of
submerged lands, zoning, building, hydraulic, encroachment, or other required
permits. The projects could proceed only after final approval was obtained
from State and local authorities.

(2). The Regional Permit would authorize projects of restricted
scope, size, and waterward encroachment. By regulation Regional Permits can not
apply to projects or activities whose impacts are significant either individu-
ally or cumulatively.

(3). The Seattle District would not issue the proposed Regional
Permit until GHEMP is found to be acceptable and incorporated as State regula-
tion through local SMP's.

(4). The purpose of a Regional Permit is to minimize "red tape"
for projects deemed nonsignificant and administratively allow a greater empha-
sis to be placed on those applications which may have a significant impact on
the human environment.

11-73

b. Section 404 of the Clean Water Act. The CWA has two provisions
which may provide additional (but not necessarily permanent) protection for
aquatic areas.

(1). §404(b)(l) - Advanced Identification of Disposal Areas

(a). The 404(b)(1) Guidelines state:

The identification of any area as a possible future disposal site
should not be deemed to constitute a permit for the discharge of
dredged or fill material within such area or a specification of a
disposal site. The identification of areas that generally will not
be available for disposal sites specification should not be deemed
as prohibiting applications for permits to discharge dredged or fill
materials in such areas. Either type of identification constitutes
information to facilitate individual or General permit application
and processing. (§230. 80(b))

(b). The Guidelines further state:

To provide the basis for advanced identification of disposal areas,
and areas unsuitable for disposal, EPA and the permitting authority
shall consider the likelihood that use of the area in question for
dredged or fill material disposal will comply with these Guidelines.
To facilitate this analysis, EPA and the permitting authority should
review available water resources management data including data
available from the public, other Federal and State agencies, and
information from approved Coastal Zone Mangement Programs and River
Basin Plans. (Emphasis added, §230. 80(d))

(c). As previously stated, the plan calls for the use
of advanced identification for MU 12, Area 1 (non-disposal) and Areas 2 and
3 (disposal). EPA would evaluate the applications by the Port of Grays
Harbor when they are submitted. EPA is currently considering the option of
deleting the advanced identification process from the §404(b)(l) Guidelines
since §230.80 contains no truly regulatory (mandatory) language, but it may
be provided in a Guidance document where other non-regulatory information
will be presented.

(d). Additional areas of the estuary could be designated
as non-disposal sites under these provisions. The major impact of this action
would be to limit or prohibit dredge material disposal in MU 43 since in-water
disposal in the other parts of the estuary (MU 44) is unlikely, with the excep-
tion of the "scour" area at the entrance of the estuary. The Corps has made a
finding that ocean disposal and uplands disposal have lesser environmental
impacts than disposal in the estuary's aquatic area and that any future estua-
rine fill would be acceptable only if consistent with the GHEMP.

(e). Advanced identification for nondisposal areas would
not necessarily preclude applications for future habitat enhancement projects.
Any such proposals would need to be reviewed by all affected resource agencies
to ensure that the habitat trade-offs are acceptable.

11-74

(2). §404(c) of the CWA. The 404(c) regulations authorize the
Administrator of EPA to exercise a veto over the specification by the Corps
or a state (if they administer the 404 program) of a site for the discharge
of dredged or fill material either before or after a permit application has
been submitted.

(a). The regulations apply whenever the Administrator is
considering whether the specification of any defined areas as a disposal site
should be prohibited, denied, restricted, or withdrawn; and, to all existing,
proposed or potential disposal sites for discharges of dredged or fill mater-
ials into navigable waters. (§923.1 (c))

(b). The purpose is to prohibit or restrict a site when-
ever the Administrator determines that the discharge of dredged or fill
material is having or will have an "unacceptable adverse effect" on municipal
water supplies, shellfish beds and fishery areas (including spawning and
breeding areas), wildlife, or recreational areas. (§ 923.1(2)) It is doubt-
ful that municipal water supplies would be impacted by dredged or fill material
in the Grays Harbor setting, but 404(c) might apply to the other resources
mentioned.

(c). This seldom used provision of law could be useful if
there are significant threats to the specific resources mentioned. It is one
method which can provide additional protection to various parts of the estuary.
The key to its use would be that the Administrator of the EPA would have to
make a determination that the discharge of dredged or fill material will have
an unacceptable adverse effect (defined in §231. 2(e)) on the resources within
existing, proposed or potential disposal sites. EPA's definition of "unaccept-
able adverse effect" is similar for all intents and purposes as that in the
GHEMP.

(d). It is not the intent of 404(c) to designate vast
bodies of waters and aquatic habitats ahead of time and "lock" them up.
Rather, there should be an actual or implied threat to the resources which
is serious enough to warrant the administrative actions required under §231.
This management tool could best be used in the context of any future actions
which are not consistent with the plan and which have not been properly amended
into the plan. The Corps current policy on the disposal of dredged or fill
materials is declared in recent EIS's on Operation and Maintenance, and Widen-
ing and Deepening. Dredged or fill materials disposal would be permissible if
consistent with the plan, for possible enhancement projects, ocean and upland
disposal, and in the scour area near the entrance to the navigation channel.

(e). One area that does deserve serious consideration
for §404(c) designation is that area known as the "fish base" in MU 15 which
has been clearly identified as being significant habitat for juvenile chum and
chinook slamon and which is facing significant pressure for future filling.

c. Acquisition Alternatives

(1). Wetland and floodplain preservation through acquisition is
an alternative to regulation. It is generally more acceptable, more permanent,
and more easily enforced than regulatory programs, and eliminates the issue
of the "taking" of property without just compensation. It can be initiated

11-75

by local governments, State and Federal agencies, and private or public groups
through acquisition in fee; fee with retention of a life estate or lesser
estate, purchase of easements; and purchase of development rights. Acquisition
in fee has been the most widely used method in the acquisition of both wetlands
and floodplains, since in most cases it is simpler, less controversial and
more cost-effective than other forms of acquisition.!

(2). With the exceptions of MU 6 and MU 12, Area 1, the plan is
silent but does not prohibit such actions if a group, organization or agency
felt a particular resource needed such protection. Areas which might be con-
sidered under these alternatives might include Natural, Conservancy or Rural
Low Intensity designated environments and MU's, especially those waterward of
the 404 line, surrounding uplands or diked wetlands. Acquisition, particularly
of diked wetlands will definitely be considered in the future Mitigation Plan
and has been applied to the Ocean Shore Airport project and the ITT-Rayonier
fill site east of the Bowerman Basin.

(3). Currently there are no known public or private organiza-
tions or entities which have shown an intent to acquire lands to provide a
more permanent protection to any specific resource. In 1977, the U.S. Fish
and Wildlife Service (Region I, Portland, Oregon) prepared a "Concept Plan
for Waterfowl Wintering Habitat Preservation - Priority Categories 14 and 15,"
in which sites were evaluated for the purpose of determining piority acqui-
sition through the use of Migratory Bird funds. Washington State winter
habitat was ranked eighth nationally, with Grays Harbor being identified as
the third most important habitat in the final ranking after Willapa Bay and
Port Susan. To date no affirmative action has been taken to acquire Grays
Harbor wetlands for inclusion in the National Wildlife Refuge System.

(4). Plan implementation does not preclude any future proposals
for consideration and designation of Federal, State or local parks and wild-
life refuges.

d. No Commitment

(1). It is possible to implement the GHEMP without any type of
commitment from Federal agencies to consider the plan in their permit decision-
making process; however, it would not achieve the goals set out by the various
agency representative as discussed in Part II: Purpose and Need. Most agencies
are encouraged under their existing statutes and regualtions to collaborate
in comprehensive planning to minimize resource conflicts with State and local
governments. With no agency commitment, the GHEMP would simply be another
local SMP; conflict and delay would likely continue.

(2). Without Federal agency commitment to the plan, local commit-
ment to the plan and its implementation is also unlikley. Absence of federal
commitment will lead to the no action alternative discussed earlier.

(3). Local governments have invited substantive Federal agency
participation in the design of local land use decisions in the estuary in
order to minimize future conflicts. Local governments could adopt the plan
or portions of it and at least ensure that shoreline management permits are
consistent with the plan, even without federal agency action.

1. Environmental Law Institute, National Wetlands Newsletter, Vol. 1, No. 4
March 1979. ~~

11-76

6. MITIGATION

1. Mitigation is an important tool in providing for the overall "balance"
which the Task Force has attempted to achieve and aims to maintain. The 6HEMP
is concerned mainly with the impacts associated with future fill sites related
to economic growth (especially port/industrial expansion) and projects of
convenience and necessity such as airports and marinas. Mitigation is discussed
generally in the plan (GHEMP, pp 26-27) and specifically for various special
projects which are expected to take place within the long-range timeframe of
the plan (e.g., see implementing conditions associated with MU 12 including
transfer of title of lands, limitations on piers, airport expansion, etc.).

2. By establishing a balance (or more precisely an acceptable baseline
between economic development and environmental protection), the plan notes
that future amendments to the plan which may upset the balance might not be
allowed because of its adverse effect on the balance of the plan or that it
may be possible to preserve the balance through mitigation of adverse effects
(GHEMP, p. 26).

3. The plan calls for the development of a Mitigation Plan for the
estuary as a future course of action. The Task Force has not yet developed
or approved such a plan but would do so if the GHEMP is approved. The GHRPC
has taken a first step in the development of a Mitigation Plan by preparing a
preliminary/background report which inventoried those potential mitigation
sites in the estuary which may offer some of the best opportunities for miti-
gation as defined in the GHEMP. Figure 12 shows where these sites have been
preliminarily identified.

4. The plan requires specific mitigation of the adverse impacts associated
with any future large scale port development in MU 12. These steps are general-
ly consistent with the Council on Environmental Quality's definition of miti-
gation (40 CFR Part 1508.20(a-e)) as shown below.

a. Avoiding the impact altogether by not taking a certain action or
'parts of an action;

(1). A compromise would not allow total avoidance of the impacts.

b. Minimizing impacts by limiting the degree of magnitude of the
action and its implementation;

(1). Minimizing fill area from 2200 acres to 264 acres - with
possible addition of 246 acres in Unit 12 or elsewhere.

(2). Minimizing Area 2 fill to that area required to provide a
rail loop transportation system for multi -commodity, bulk loading and off-
loading facility.

(3). Minimizing Area 3 fill to that required for an ILS Commuter
Airport but not more than 750 feet to the north.

11-77

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(4). Phase filling to allow for impact evaluation. Implementation
Condition #3, Area 3 reads as follows:

If Area 2 is filled prior to a permit application to fill in Area
3, an evaluation of the effects of filling in Area 2 will be con-
ducted as a part of the permit review process. The primary purpose
of that evaluation will be to determine whether environmental
conditions have changed sufficiently as a result of Area 2 fill to
demonstrate that other alternative airport sites would be less
environmentally damaging. (GHEMP, p. 64)

c. Rectifying the impact by repairing, rehabilitating, or restoring
the affected environment;

(1). With concurrence of state and Federal resource agencies,
recreate lost habitat on the north sides of Areas 2 and 3 for vegetated salt
marshes and woody vegetation and perching sites for birds.

(2). Department of Game will prepare management plans with the
advise from a Bowerman Basin Advisory Council which will include environmental
interest groups and citizens.

d. Reducing or eliminating the impact over time by preservation and
maintenance operations during the life of the action;

(1). 1700 acres of habitat will be preserved, especially critical
eastern section of the Bowerman Basin used for both feeding and roosting habitat.

(2). Preserving other significant shorebird and waterfowl habitat
throughout the estuary.

(3). Maintaining water quality in Area 1 through containment
structures surrounding each fill.

e. Compensating for the impact by replacing or providing substitute
resource or environments.

(1). Area 1 land will be acquired through fee title.

(2). In-kind habitat replacement is associated with some activi-
ties but not all .

5. The plan also discusses the potential for enhancement or the manipula-
tion or modification of the system to increase productivity. The plan does
not generally endorse specifics but treats this activity as other activities
and sets a context and establishes limits within which potential enhancement
projects can be evaluated and permitted. Some enhancement concepts are includ-
ed in the mitigation measures discussed in the plan amendment procedures.
Enhancement activities are specified in the development of the Ocean Shores
Airport (marsh restoration) and the Bowerman industrial area (shorebird habitat
improvement) .

II- 79

6. The plan is generally consistent with the §404(b)(l) Guidelines which
state: "...no discharge of dredged or fill material shall be permitted unless
appropriate and practicable steps have been taken which will minimize potential
adverse impacts of the discharge on the aquatic ecosystem." §230. 10(d).
Some of the possible ways to minimize adverse impacts include: (§230.70, 75)

a. confining the discharge; (GHEMP, p. 64, Condition 5)

b. use previous dredged material disposal sites; (MU 12, Areas 2 & 3)

c. avoid changes in water current and circulation patterns; (pre-
serving MU 12, Area 1, avoids significant circulation pattern changes)

d. avoid sites having unique habitat or other value, including habitat
of threatened or endangered species; (partially met in MU 12, but plan as a
whole avoids and protects other significant sites utilized by shorebirds and
falcons and unique fisheries habitat)

e. use planning and construction practices to institute habitat de-
velopment and restoration to produce a new or modified environmental state;
(if desirable and feasible, such projects are permitted and encouraged by
the plan)

f. timing discharge to avoid spawning or migration seasons and other
biologically critical time periods; (plan states that discharge activities
will be consistent with permit requirements) and,

g. avoid the destruction of remnant natural sites within areas already
affected by development (plan does this for fisheries habitat in urban environ-
ment, Area 1 in MU 17 which is the most natural area remaining in the Bowerman
Basin) .

7. Overall, the GHEMP has a number of elements which will help minimize
future adverse impacts including:

a. greater specificity controlling future development;

b. specific requirements which prohibit certain actions which would
have an unacceptable impact and requirements to minimize impacts associated
with other actions to include mitigation, monitoring and enhancement projects;

c. potential phaseout of log rafting;

d. better utilization of existing urban environments to provide a more
attractive environment;

e. phase development which will allow monitoring of impacts; and

f. limiting airport development to the minimum amount of space
required.

II- 80

PART III: AFFECTED ENVIRONMENT

PART III: AFFECTED ENVIRONMENT

A. General Setting

1. Grays Harbor is one of the Pacific Coast's six major estuary systems.
Located on the southern Washington coast, this area lies 110 miles south of
the Straits of Juan de Fuca and about 45 miles north of the mouth of the
Columbia River (see backside front cover for location map). The 91 square
mile estuary is approximately 13 miles at its widest point and narrowing to
less than 100 yards in its upper reach nearly 32 miles from the estuary mouth.
The three corners of the estuary are defined by the mouth of the Chehalis River
flowing into the eastern portion of the harbor; the North Bay, which receives
the waters of the Humptulips River; and the South Bay, into which the Elk
River and Johns River flow. The Wishkah River is tributary to the Chehalis
near the latter' s mouth at the harbor, and a little further west from the
Wishkah, the Hoquiam River flows into the estuary. Four major islands of the
estuary are Goose and Sand Islands (North Bay); Whitcomb Island (South Bay);
and Rennie Island to the east, near the mouth of the Chehalis River. Rennie
Island, measuring about 1.5 miles across, is the largest of the four, while
the other three are each approximately one-half to three-quarters of a mile in
length.

2. Geologically, the estuary is a drowned portion of the Chehalis River
Valley, and is continually being filled in with riverborne sediments and ocean-
ic materials. The surrounding uplands are composed of unconsolidated Pleisto-
cene silt, sand and gravel, which are sedimentary and volcanic rocks of the
Tertiary Age that form low relief hills. The predominant physical feature of
the estuary is the vast amount of intertidal mud and sandflats.

3. The climate of the area is dominated by the influence of the Pacific
Ocean, typically mild, dry summers and mild, wet, cloudy winters. The yearly
mean temperature is 50°F, the warmest month being August, with an average
temperature of 70°F, while the coldest month, January, averages 34°F. Winter
winds, with gusts ranging from 35 to 50 mph, are from the south to southwest.
Spring and summer winds are from the west to northwest and are steadier with
fewer gusts, with velocities ranging from 15 to 20 mph.

4. Grays Harbor is an area of diverse uses. The harbor lies wholly
within Grays Harbor County. The cities of Aberdeen, Hoquiam and Cosmopolis
are situated in the estuary's upper reaches, and their economies depend in
large part upon Grays Harbor as a medium for fishing, shipping and trading
and are heavily industrialized. The cities of Westport and Ocean Shores lie on
the south and north entrance to the harbor with their economies being more
fishing and recreation oriented. The region is served by rail from the east;
highway linkages from the east, south and north; by a 5,000-foot runway airport;
and by a -30 feet mean lower low water (MLLW) navigation channel. Population
ranges from 18,550 for Aberdeen to 1,570 for Cosmopolis.

III-l

6. Use of Inventory Data in the Planning Process

1. The physical, biological, and socioeconomic characteristics of Grays
Harbor were summarized by a technical team familiar with the area prior to the
development of the first draft of the GHEMP. This information was summarized
and displayed using graphics, technical reports and interview-response summar-
ies. That information base was used by the Planning Task Force in its initial
work to develop the first draft of the plan.

2. The major purposes of the data inventory were to:

a. Provide the Task Force with information on which to base decisions

b. Provide the general public with a reference base to test the
recommendations of the task force.

c. Provide a continuing reference source for future planning,
development and management decisions.

The initial step in the planning process was to conduct a detailed inventory
of the physical, biological and socioeconomic resources of Grays Harbor. A
special team of experts, each member representing specific technical disci-
plines (i.e. economics, forestry, fisheries, etc.) was formed (see appendix H-
1). The function of this team was to assist in the collection and review of
the known technical information on Grays Harbor. The team further served to
arbitrate apparent information conflicts and to provide the Task Force with a
reservoir of diverse technical expertise.

3. The various local and special interest groups, individuals and agen-
cies concerned with the planning area were identified. These groups, individ-
uals and agencies (see appendix H-2) were then contacted and given a summary
paper which outlined the background, process and intent of the planning program.
Each group or individual was then interviewed using a standard interview format.
The results of these interviews were then summarized to provide a general pro-
file of what a cross section of the public felt should be protected, developed
or of management concern. The interviews were also used to obtain unwritten
historical and other information on the area. Opinions on facts listed on the
data maps and reports were also solicited. A total of 68 interview sessions
were conducted and the results summarized.^

4. The purpose of the detailed data collection, verification and inter-
view process was to develop an accurate profile of the Grays Harbor estuary.
Obtaining this information was necessary before any deliberations or decisions
could be made by the Planning Task Force or general public on what the plan
should do for Grays Harbor. The data collected were translated graphically
into fourteen large scale (1" = 1000') data maps describing the area. A
series of technical memoranda, summaries of the interviews, and an annotated
bibliography of all known publications on Grays Harbor were prepared for the
Grays Harbor Estuary Management Program. The publication described the plan-
ning process and how it was to provide and solicit general public ideas and
concerns.

V. Montagne-Bierly Associates Inc., Grays Harbor Estuary Management Program -
Phase I, Summary of Interviews, pp. 136-153.

II 1-2

5. The technical team's efforts resulted in the presentation of data
maps, public opinion and technical memoranda to the Planning Task Force at its
initial workshop. The fourteen data maps were displayed at each workshop and
were a continuous reference tool for the Task Force during the development of
the first draft of the Estuary Plan.

6. The following sections on the description of the environment are
supplemented by the Data Maps (Attachment 1) to this PDEISJ They summarize in
graphic form a great deal of data gathered by the technical teams and used by
the Task Force in making preliminary decisions. In addition, an expanded
discussion of the three major environments (physical, biological and socio-
economic) can be found in Grays Harbor Estuary Management Program: Technical
Memoranda , pp. 1-110 (available upon request from OCZM). Additional references
in which the Grays Harbor Estuary environment is discussed at length include:

a. U.S. Army Corps of Engineers, Seattle District, Maintenance Dredg-
ing and the Environment of Grays Harbor, Washington, Appendices A-N, 1976.

b. U.S. Army Corps of Engineers, Seattle District, Long-Range Main-
tenance Dredging Program - Grays Harbor and Chehalis River Navigation Project
Operation and Maintenance, "Final Environmental Impact Statement Supplement
No. 2," 1980.

c. U.S. Army Corps of Engineers, Seattle District, Grays Harbor,
Chehalis and Hoquiam Rivers, Washington - Channel Improvements for Navigation.
"Interim Feasibility Report and Final Environmental Impact Statement," 1982.

d. Sharpe, Grant W., An Interpretive Survey of the Grays Harbor Area,
prepared for the Army Corps of Engineers, 1977.

1. The orignial fourteen data maps have been combined into ten maps. Attach,
I will not be redistributed with the PFEIS; please save it for future refer-
ence.

III-3

C. Physical Environment

1. Hydrology (see attach. I, map 6 - Hydrology & Flood Plain)

a. Grays Harbor Estuary is fed by a 2,550 square mile drainage basin.
Tributary rivers include the Chehalis, Hoquiam, Wishkah, Humptulips, Johns and
Elk River basins. Seven sub-river basins, comprising the Chehalis and the
Johns Rivers, feed fresh water into the estuary. The Chehalis is the largest
basin and constitutes the major fresh water source for Grays Harbor. Providing
roughly 80 percent of the fresh water to the estuary, the Chehalis' inflow is
a primary reason why Grays Harbor is classified as a positive estuary, in
which precipitation and runoff exceed evaporation, and the net surface flow is
seaward (see figure 13). Precipitation is high, increasing from about 80 inches
(200 cm.) near the estuary to over 220 inches (550 cm.) in the higher reaches
of the watershed.

b. Because of the winter storms, streams feeding Grays Harbor are
characterized by higher winter flows and low summer flows. Mixing of fresh
water and salt water in the mid-portion of the estuary (Aberdeen-Hoquiam area)
creates environments ranging from low salinity (five parts per thousand) during
the winter to higher salinities (20 parts per thousand) during the summer
months. The winter salt water wedge or upstream limit of intrusion stops at
the Aberdeen-Hoquiam area and the summer upstream limit some 10 to 12 miles
further up the Chehalis River (see figure 14).

c. The estuary itself is a shallow basin with depths averaging less
than 20 feet. In the harbor entrance depths reach a maximum of 80 feet,
while the navigational channel is maintained at the -30 feet mean lower low
water (MLLW) level by annual dredging of bottom materials and is being con-
sidered for widening and deepening to -38 feet MLLW. The surface area varies
from about 91 square miles at mean higher high water (MHHW) to about 38 square
miles at MLLW, providing 53 square miles (nearly 34,000 acres) of intertidal
lands (Corps, Widening & Deepening, 1982). Much of the tidal flat area is
about 1 to 2 feet above MLLW and is important in the movement, mixing, and
reaeration of harbor waters during tidal ebb and flood J

d. Grays Harbor is subject to the North Pacific's diurnal tide system
(two high tides and two low tides daily). The upper limit of the tidal influ-
ence is Montesano, approximately 32 miles from the harbor entrance. On an
annual basis the mean daily tidal range is 10 feet in the Aberdeen-Hoquiam
area,

e. Tides move slowly up the estuary; high tide occurs 29 minutes
later at Aberdeen than at the harbor mouth. Maximum mean velocities in
the upper harbor vary from about 3 feet per second (fps) during floodtide
to about 4.5 fps during ebbtideJ

f. The estuary is often divided into the outer harbor extending east
from the Pacific Ocean to about Point New, and the inner harbor extending east
from about Point New to Cosmopolis. Also, five physical units of the Grays
Harbor estuary are often referred to:

III-4

OLYMPIC MOUNTAINS

Z
<

O

O

<

0.

«\^

CHEHALIS DRAINAGE
BASIN

COLUMBIA

R.

WASHINGTON

OREGON

SCALE

20

L i i

0
I 1

20 Ml
1

FIGURE 13
Source: COE
M.K. Vincent, 78

Humptulips
River

Grays Harbor Estuary
Management Program

0 ppt Winter
jipt Summer

Chelialis
Hi ver
Cosmopolis

Average Summer and
ns uivcr Winter Salinities

FIGURE 14

Source: Herrmann ( 1 9 7 L' )

1 1 1-5

I

I

Entrance/

North
Bay

\

South
Bay /

/Central Bay/Chehalis River Wetlands

When considering Grays Harbor as an aggregate of socioeconomic and physical
features, these five physical units may be further expanded to eight major
planning units (as designated in the GHEMP). North Bay comprises the largest
planning unit with about one-fourth of the total surface area, followed by
Central Bay, South Bay, and the Chehalis Wetlands. For purposes of mainten-
ance dredging, the Corps further subdivides the navigation channel into eight
units as identified in figure 15. 2

FIGURE 15

15

55

45'

12J-40'W

«6*
58

N

COSMOP-t '
OLIS KV

CHEHALIS,.

' *->V MONTESANO

58'
N

45'

ijyao'w

50'1

50'

15'

124* W

g. Ground water is not heavily used in the Grays Harbor area. Sand
and gravel deposits related to the recent alluvium along the lower Chehalis
River could be a source of domestic and industrial water. These sources are
high quality and available in relatively large quantities (several thousand
gallons/minute).3

III-6

2. Geology

a. On the north, east and south, the harbor is bounded by low hills,
composed of Pleistocene silt, sand and gravel, as well as harder sedimentary
deposits and volcanic rocks of Tertiary age. The outer harbor is composed of
marine sediments, the inner Harbor of eroded sediments from the drainage basin,
with a transition zone between these two regions. It is estimated that sedi-
ment transport into the estuary by the Chehalis River system is about two
million cubic yards per year. The majority of these fluvial sediments enter
the estuary in the winter during high flows; the Satsop and Wynoochee subbasins
discharge the major portion. Likewise, it is estimated that a similar amount
of marine sediments enters the mouth of the estuary on a yearly basis. 3 The
majority of the sediment in the central and lower third of the estuary is of
marine origin (containing less silt and higher sand content). The North Bay,
South Bay and the upper two-thirds of the estuary contain a mixture of marine
and river sediments (see attach. 1, map 7, Soils and Sediments).

b. Several types of soils predominate in various sections of the
estuary. While sandy soils are dominant in the Ocean Shores and Westport
areas, peat lined with clayey soils occurs in the section between Cosmopolis
and Montesano, and most drainage areas are composed of clayey soils. The area
of Aberdeen and Hoquiam is primarily built on fill material. The peat domi-
nated soils provide a serious limitation to development.

c. Topographically, the Chehalis River Valley formation was influ-
enced by debris left by the advance of the Vashon Glacier southward from Puget
Sound some 15,000 years ago. Glacial debris can be found east of Grays Harbor
and along the banks of the present channel of the Chehalis River, which drained
a major portion of the Puget Sound during that glacial period. Thus, Grays
Harbor has been formed into a series of small drainage valleys which cut
through low but rugged hills with a maximum elevation of 2,400 feet. Level
land is scarce and is generally created by the processes of marsh building,
estuarine deposition, stream process, or manmade fill. Erosion in the estuary
area can be a serious problem, especially during storms and high tides. Jetty
structures at the harbor entrance and navigation structures along the main
channels must be protected during these periods. The erosion problems of the
area are more completely addressed in the Grays Harbor Erosion Management
Study.4

d. The estuary contains numerous shallow channels created by ebbtide
flows and river discharges. Historically, there were three main channels run-
ning east to west. These were the North, Middle and South Channels. In the
past, all three maintained depths of about -17 to -20 MLLW with areas of
shoaling. The three still exist, but the North Channel is dredged for
navigation purposes and is the major ship channel to Aberdeen and Cosmopolis.
The other two have shoaled to shallow depths. 3

III-7

3. Water Quality

a. The estuary is a partially mixed system in which tidal flows domi-
nate river flows and nearly complete mixing of fresh and salt water occurs.
The low fresh water inflow in summer and the large estuary volume create a
"giant bathtub" effect in the central portion of the estuary. Pollutants
entering this area are not flushed rapidly and contribute to reduced water
quality in that reach. The mid-reach of the estuary from Cosmopolis to a line
between Point New and Markham has had a history of poor water quality since
the earliest recorded water quality measurements were taken.

b. The areas in Grays Harbor with substandard water quality are the
result of both point and nonpoint sources. The major point sources consist of
municipal and industrial discharges which affect dissolved oxygen levels
(D.O.), turbidity, color, and bacterial contamination. The wood products
industry is considered to be the largest volume contributor of oxygen demanding
wastes (historically considered the primary water quality problem in the
estuary), particularly from sulfite liquors. Nonpoint source contamination
includes surface runoff from both urban development and the general watershed,
garbage and wood waste land fills, septic tank leachates, dredging and log
storage wastes.

c. The overall water quality of Grays Harbor is seriously affected by
the estuary's declining capacity to assimilate wastes. Thus, the level of
past and present industrial discharges has had a major impact on the quality
of the water. Wastes often accumulate as a result of low river inflows and
limited flushing which, in concert with heavy sedimentation from the Chehalis
River, contribute to low oxygen levels in the water. Though water quality has
improved in the last 10 years, additional organic waste discharge above present
levels could reverse this trend. 5

d. During 1980 and 1981, the Corps performed comprehensive sediment
sampling and elutriate testing for contaminants in Grays Harbor. The results
indicated that contaminant concentrations in the sediments increase toward the
inner harbor as the sediments become finer. Copper, zinc, PCB's and BHC exceeded
existing EPA criteria in some sections of the estuary. Some of the sediments
in the Hoquiam and Cow Point reaches could result in contaminant bioaccumulation
in tissues of marine organisms if sediments are discharged in open water. Con-
sequently, there is need for some confined disposal associated with the pro-
posed widening and deeping project. 2

4. Air Quality

a. Both localized and general air pollution occur in Grays Harbor.
Nonstationary pollution sources include vehicular and marine traffic which
emits carbon monoxide, oxides of nitrogen, and unburned hydrocarbons. There is
low-level but measurable air pollution from industrial sources in the Aberdeen-
Hoquiam-Cosmopoli s complex to the east. Localized air pollution problems can
occur as a result of high winds that hold emission plumes close to the ground
near the source. Suspended particulates in the outer harbor average 35 micro-
grams per cubic meter (ug/m3) while those in the Aberdeen area show an annual
mean of 40 ug/m3. Both are well below the National Ambient Air Quality
Standard (75 ug/m3) and the Washington State Ambient Air Quality Standard
(60ug/m3) for high volume suspended particulates. 6

III-8

D. Biological Environment

1 . Habitats

a. A diversity of habitats in and around the Grays Harbor Estuary have
been described including upland forests, lowland forests, adjacent floodplains
(urban and agricultural lands, ponds, lagoons, sloughs and freshwater swamps),
coastal dunes, marshlands (fresh and saltwater), intertidal flats (mud and
sand), eelgrass flats, subtidal or channel, and the man-made jetty habitat
that supports a distinct though small rocky coast marine community. 1»3 Habitat
types are made distinctive by virtue of one or more characteristics: substrate
type; elevation with respect to tidal influence; and predominant vegetation. 6
Salinity is another important factor in determining the type of habitat which
develops at a given site (NMFS, personal communication).

b. The abundant wildlife which have been identified in the estuary
are in response to this wide diversity of habitats, a moderate climate and
relatively low intensity urban and industrial disturbances. There are at
least 52 known species of fish, 326 species of birds and over 50 species of
mammals that utilize the estuary. See appendix I for species lists with
common and scientific nomenclature.

c. Several food chain pathways found in Grays Harbor ecosystems have
demonstrated the extent and persistence of interdependent relationships through-
out the flora and fauna of the estuary. 2 One example might include the eelgrass
habitat which is of particular importance in the estuary, as it provides food,
shelter, and substrate for an abundance of marine organisms and increases the
biological productivity and diversity of the estuary. °

(1). Eelgrass habitat is significant as an ecological link between
other estuarine and offshore habitat types. Eelgrass produces an abundant
yearly crop of vegetable matter which is exported from the immediate habitat as
detritus. This material can be found almost anywhere within the estuary, as
well as offshore along the continental shelf and on ocean beaches. It provides
organisms in these habitats with a rich source of food during the less productive
winter period. 6

(2). A myriad of organisms inhabit eelgrass beds. Benthic fauna
include nereid worms, clams, nematodes, and burrowing anemones. The leaves
support isopods, amphipods, hydroids, bryzoa, harpacticoids, herring spawn,
snails, limpets, protozoa, ciliates, and nudibranchs. Juvenile salmonids,
striped sea perch, pipefish, and blennies find food and cover in the beds. The
epibenthic area is home to flatfish (sole and flounder), crabs, and moon snails
and is an important food item for waterfowl, especially black brant and wid-
geon. 6

2. Vegetation (see attach. 1, map 8 - Vegetation)

a. Substantial areas of native vegetation remain in and around the
Grays Harbor Estuary. Vegetation is important as it provides habitat (nesting
and shelter) and food (seeds, detritus or decaying organic matter), stabilizes
soils thereby minimizing erosion and siltation, helps to filter toxic sub-
stances from surrounding waters and absorb organic and mineral nutrients. 2

b. Table 3 lists the characteristic species of the major vegetation
types of the Grays Harbor Estuary.

III-9

TABLE 3

Characteristic Species of the Major Vegetation Types of Grays Harbor Estuary

Vegetation Type
Eelgrass Salt Freshwater Lowland Upland Dune

Bed Marsh Marsh Forest Forest Vegetation

Common Eelgrass
( Zostera marina)

European Eelgrass
( Zostera noltii )

Pickleweed

(Salicornia virqinica)

Arrow Grass

(Triqlochin maritimum)

Sedge

(Carex lynqbyei)

Tufted Hairgrass

(Deschampsia caespitosa)

Salt Grass

(Distichlis spicata)

Slough Sedge

(Carex obnupta)

Red Canarv Grass

(Phalaris arundinaceae)

X

Cattail

(Typha latifolia)

X

Sitka Spruce

(Picea sitchensis )

X

X

Red Alder

(Alnus rubra)

X

Willow

(Salix sp)

X

Western Hemlock

(Tsuqa heterophylli)

X

Coast Pine

(Pinus contorta)

)

Beach Grass

(Amophila arenaria)

)

c. The upland forests are dominated by Sitka spruce and western hem-
lock with some western red cedar and Douglas fir. The lowland forests generally
occur in riparian environments associated with the floodway of streams or in
the tidally-influenced portions of the Chehalis River upstream from Cosmopolis
and are dominated by spruce, red alder, willow and crabapple. Ground cover is
extremely dense due to an abudance of small tree and tall shrub species. The
lowland forests are distinguished from the adjacent upland forests primarily by
the abundance of deciduous species in the canopy. These environments are more
fully described and delineated in Grays Harbor and Chehalis River Improvements
to Navigation Environmental Studies, "Chehalis River Floodplain Land Cover
Mapping Between Aberdeen and Montesano, Washington," Corps of Engineers, 1980.

111-10

d. The dune vegetation complex comprises a variety of plant communi-
ties such as that found at Whitcomb Island to include American sea rocket, lime
grass, dune grass and yellow abronia. These are pioneer species that are able
to tolerate the harsh conditions of high salinity and abrasive soil action.
Other areas of stabilized dunes are characterized by European beach grass,
purple beach pea, beach morning glory and sea rocket. Behind the dunes are
deflation plains characterized by moist soils which include sedges, rushes, and
in some areas, shrubs or small trees of wax myrtle and willow. Stabilized up-
land dunes are invaded by Sitka spruce and shore pine. 3

e. Wetland vegetation types in the estuary area are freshwater
marsh, saltwater marsh and eel grass communities.

(1). Freshwater marsh habitats are dominant in the Chehalis
River and North Bay portions of the estuary. This habitat type is character-
ized by slough sedge, cow parsnip, cattails, spike rush, bull rush and reed
canary grass. The locations that have been observed are those areas closely
adjacent to the estuary at the upper end of tidally influenced creeks and are
characterized by standing water for a substantial period of the year and by
their accumulation of organic soils.

(2). Extensive saltwater marsh areas are located from the cen-
tral portion of the estuary below Aberdeen throughout North and South Bays.
There are basically two major types of salt marshes in Grays Harbor: high
marshes and low marshes due to their intertidal or above mean tide elevation.

(a). Low marshes are dominated by succulent salt tolerant
species. Pickle weed is characteristic of low marshes. Two major types of low
marshes are developed depending upon the type of substrate available. Sandy
substrates support marshes dominated by pickle weed and jaumea. Low marshes
with silty subtrates are dominated by arrow grass, tufted hairgrass, pickle
weed and Lyngby's sedge. These marshes are quite similiar in vegetation
composition to the unconfined dredge material disposal sites that are newly
colonized in the intertidal area except for greater plant density.

(b). High marshes are dominated by grass-like species,
particularly tufted hairgrass, rushes, salt grass, bentgrass and sedge.

(c). Diking the saltwater marshes by tide-gating eliminates
tidal saltwater influence and generally changes the plant species composition.

(d). Both fresh and saltwater marsh habitats have been
significantly reduced in the Grays Harbor area through diking, filling, dredged
material disposal and ditching. Because they are in a transitional zone between
nearshore lowlands and the water, they are susceptible to alteration for use
as pastureland or urban/industrial development. Today, emergent vegetation
habitat comprises only 16 percent of the Grays Harbor intertidal area, repre-
senting a loss of approximately one-half of the previously existing wetlands. 6

1 1 1-1 1

(3). Eel grass occurs throughout the estuary below Aberdeen and
at tidal elevations between -3 ft MLLW and +6 to +7 feet MLLW. Two species
of eel grass occur in Grays Harbor including common eel grass (Zostera marina)
and European eel grass (Z. noltii) which occurs in the higher intertidal levels
than the former and is most abundant between +5 and +6 MLLW. 3

f. Seaweeds, algae and phytoplankton. Thorn (1981 ),8 noted 23 taxa
of macroalgae in Grays Harbor. Among the most abundant and conspicuous are
3 species of green algae (Enteromorpha clathrata var. crinita, E. linza,
E. intestinalis); a species of brown algae (Fucus distichus ssp. edentatus);
2 species of red algae (Polysiphonia hendryi var. deliquenscens and Porphyra
sanjuanensis); and a complex of tube dwelling and fillamentous diatoms.
Macroalgae's distribution is limited by availability of hard, stable substrata
(e.g., logs, roots, boulders) for attachment. 2 No emergent vegetation exists
in mudflat substrate and the predominant flora are restricted to epibenthic
green and blue-green algae, with diatoms dominating the phytoplankton. On the
sandflat substrate, no attached vegetation exists and there is yery low epi-
benthic algal production. However, Thorn does report dense mats of Vaucheria
longicaulis and Rhizoclonium riparium growing in sand. Phytoplankton is the
primary producer and organic detritus is generally less available than on the
mudflats. While phytoplankton are the least productive plant group in the
estuary, they are considered important primary producers which are the supply
of food for zooplankton.

flora.2

Table 4 compares primary production of several types of aquatic

TABLE 4. ORGANIC CARBON CONTRIBUTIONS (x 106kgC/yr)
OF VARIOUS SOURCES WITHIN THE ESTUARY

Source

Marsh Phanerograms
Zostera spp. (eelgrass)
Benthic Algae
Phytoplankton

Total

Inner Harbor

Outer Harbor

Entire Estuary

3.36

12.6

16.0

49.02

76.78

125.8

24.68

46.6

71.3

2.34

6.6

8.9

73.40

142.6

222.0

Source: Thorn, 1981

j. Figure 16 shows the location of the various types of wetlands
vegetation.

111-12

s

i i

* I I

"8 "8

o> o> M H
I X 6 5

E 5

m ra

1 s

s
&

1

■I

:s

MW 3 0 0 0 I J I 0 f d

111-13

1Y

k. Table 5 lists the extent of the acreage of intertidal habitats in
Grays Harbor.

TABLE 5

ESTIMATED EXTENT OF INTERTIDAL HABITATS

IN GRAYS

HARBOR

Hectares

Acres

Entire Harbor to Extreme High Water (EHW)
Intertidal from MLLW to EHW

22,140
13,600

54,708
33,606

Salt Marshes

Low Marshes
High Marshes

919
514

2,271
1,270

Sedge Marsh
Diked Salt Marsh
Total Salt Marsh

81

441

1,955

200
1,090
4,831

Eel grass Beds

4,740

11,712*

Tidal Flats Not Vegetated With
Vascular Plants

6,905

17,062

Source: Corps of Engineers, Long-Range Maintenance Dredging Project, FEISS,
No. 2, 1980

* The extent of eelgrass beds is extremely variable. In 1977, G. H. Miller
estimated the eelgrass habitat at 20,810 acres. The differences may be due
to seasonal variability and/or sampler subjectivity. ^

3. Wildlife (see attach. 1, map 8 - Wildlife)

a. Birds. A variety of birds characterize Grays Harbor Estuary. The
major groups found in the estuary are waterfowl, shorebirds, fish-eating water-
birds, gulls and terns, terrestrial birds and raptors.

(1). Waterfowl. Dominated by ducks, waterfowl counts in Grays
Harbor peak during September, October, and November at approximately 45,000.9
American widgeon, pintail, and mallard are the most abundant duck species.
Scaup, canvasback, bufflehead, black brant, scoter, ruddy duck and green-winged
teal are also common. Grays Harbor provides an important wintering area for
canvasback and black brant.

111-14

(a). Waterfowl concentrate in abundance in the North Bay
with large numbers also found in the undeveloped area of South Bay. South
Channel is utilized more than the North Channel where there is some concentra-
tion around Rennie Island. Another attractive area for waterfowl in the inner
harbor is the Bowerman Basin. Several hundred canvasback are frequently seen
feeding in this area. Two or three thousand American widgeon, pintail, mallard
and green-winged teal ducks are commonly seen feeding or resting in the salt
marshes surrounding the basin.

(b). Dabbling ducks utilize the Chehalis River and are
found in the sloughs and backwater areas that enter the Chehalis River. The
tide! and swamp area of the upper Chehalis River may provide important year-
round habitat for wood ducks.

(2). Shorebirds. The Grays Harbor Estuary provides habitat for
a large variety of both migratory and resident or wintering shorebirds. Approx-
imately 24 species of shorebirds utilize the estuary as a stopover site, with
western sandpiper being by far the most abundant during spring and fall migra-
tions and dunlin being the dominant species during the winter months.^ As a
result of a recent survey conducted by Dr. Steven G. Herman and John B. Bulger
on the distribution and abundance of shorebirds at Grays Harbor during the
spring of 1981, they concluded that the estuary is host to more shorebirds than
any other estuary along the Pacific Coast south of Alaska and that Grays Harbor
is of extraordinary and critical importance to spring-migrating shorebirds on
the Pacific Coast. '0 Other shorebirds using Grays Harbor are the least sand-
piper, red knot, short-billed dowitcher, sanderling, semipalmated plover,
ruddy turnstone, whimbrel , longbilled curlew, marbled godwit, black-bellied
plover and the great blue heron. The primary food producing area for these
species is intertidal flats with fine grained sand or silt/clay sized particles.
The Bowerman Basin has -been identified as a particularly significant site
among the many important sites within the estuary and is perhaps of interna-
tional significance. A more thorough discussion on the shorebird population
can be found in appendix C.

(3). Fish-eating Waterbirds, Gulls and Terns. The deeper water
areas of the estuary are utilized as feeding sites for sea birds including
rhinoceros auklets, common murres, marbled murlets, pigeon guillemots and
parasitic jaegars. Other waterbirds seen in the outer estuary and the deeper
waters of both the North and South Channels include loons, grebes, shearwaters,
petrels and cormorants. These species aggregate according to feeding prefer-
ence. Some of the species (redneck grebe) feed in high salinity waters of the
outer harbor while others (pied billed grebe and western grebe) feed in fresher
water areas of the main channel of the Chehalis River and into the North Chan-
nel. Gulls and terns are abundant, and the estuary provides nesting space for
unique colonies of mixed associations of gulls and Caspian Tern. The nesting
colonies on Whitcomb Island, Sand Island, and Goose Island are very important
especially to the Caspian Tern populations. The Whitcomb Island colony is the
largest identified Caspian Tern colony on the West Coast.

111-15

(4). Terrestrial Birds. A large variety of terrestrial birds are
found within the confines of Grays Harbor Estuary. These species have a direct
relationship to the surrounding vegetation and are particularly abundant during
the late spring and summer months. Crows, marsh wrens, robins, kingfishers,
flickers, sparrows, red-winged blackbirds, American gold finch and band tailed
pigeon are a few of the more abundant.

(5). Raptors. The estuary is important for raptorial birds
which feed over the wetlands and waterways of the estuary. The marsh hawk
and short-eared owl are common raptors in salt marsh areas. These birds
feed on small mammals and birds that live and feed in the vegetation of the
salt marshes. The great-horned owl, red tailed hawk, peregrine falcon, merlin,
American kestrel, Cooper's hawk, sharp-shinned hawk and bald eagle are also
seen. All of the species except the bald eagle are known to prey upon shore-
birds and are most often seen during migration and wintering periods.

(6). Figure 17 identifies some of the significant avian habitats
within the GHEMP area.

b. Mammals. The mammals of Grays Harbor Estuary are primarily associ-
ated with the intertidal waters and related wetlands. The most abundant mammal
forms are marine mammals that live in the estuary and feed on the fish and
shellfish in the bay. The harbor seal occurs in large numbers in the outer
estuary and haul-out areas have been identified and mapped. The seal population
has been estimated at 500 seals during winter with as many as 1,400 observed
during summer. Marine mammals other than harbor seals make only occasional
appearances in Grays Harbor. Stellar sea lions, harbor porpoises, and gray
whales have been observed inside the estuary. A variety of small mammals
(voles and shrews) are found in the salt marshes and furbearers (muskrat, red
fox, raccoon, mink, weasels, river otter and beaver) are abundant in the ripar-
ian habitat associated with the estuary. Black-tailed deer, Roosevelt elk,
and black bear are generally peripheral to the estuary but use the shoreline,
higher salt marshes and tidelands for occasional feeding. 3

4. Fish (see attach. 1, map 9 - Fisheries)

a. Anadromous fishes. Anadromous fishes in Grays Harbor include
spring and fall Chinook salmon (predominantly fall Chinook), coho salmon,
chum salmon, steel head trout, searun cutthroat trout, Dolly Varden, shad
and sturgeon.

(1). Distribution of the species is strongly influenced by
bottom type, estuary depth, salinity, season, and food organism availability .2
Map 9 identifies the major tributaries of importance within the study area.
All anadromous species use the estuary as a migration route. Since the estuary
is a trnsition zone between freshwater and saltwater, this is a zone of physio-
logical adjustment important to survival. Some species such as fall Chinook
and chum salmon may spend a considerable amount of rearing time in the estuary;
food availability is particularly important for these species. Figures 18
through 20 list the various migration times of the species. Figure 21 shows
both the outmigration times and relative abundance of four of the species.

111-16

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111-17

SPECIES AHD LIFE HISTORY STAGES

RANGE AHD PEAKS OF OCCURRENCE

ACTrVTTT

chinook salmon:
sprdo-ruh adults and jacks

1

UPSTREAM PISH PASSAGE

CHINOOK 1ALM0H:
8FRIB3-RUH JUVENILES (TKAKLLHOS)

DOWNSTREAM FISH PASSAGE

■■..,. ■■.■: \

canaooK salmon:

FALL-RUN ADULTS AID JACKS

UPSTREAM n3H PASSAGE

;

CHDIOOK SALMON:
FALL-RUI JUVENILES (FDCKHLIHOS)

DOWNSTREAM PISH PASSAGE
AHD ESTUARY REARING

^y^'y^^

CHUM SALMON:
ADULTS

UPSTREAM PI3H PASSAGE

CHIM SALMON:

juveniles (nor)

D0WHSTK8AM PISH PASSAGE
AHD ESTUARY REARED

COHO SAIMOH:
ADULTS AHD JACKS

UPSTREAM PI8H PASSAGE

:•:•:

COHO SAIXOH:

JUVENILES (TEAHLDOS)

DOWNSTREAM Plflfl PAS3ACH

MOUTH

JAI.

7ZB

MAR

APR.

MAI

Jim

JULT

AUG.

3Kpr,

OCT.

■or.

DK.

M 0 H T H

Figure 18. life history stages and range and peaks of occurrence of chlnook. chum and coho salmon
In Grays Harbor, (Deschamps, 1970).

3P&CKS AHD LITE HISTORY STAGS

RANOE AHD PEAK OF OCCURRENCE

ACTIVITY

STEELHEAD:
ADULTS AHD JACKS

1

UPSTREAM FISH PASSAGE

STEELHEAD:
KELTS

DOWNSTREAM FISH PASSAGE
(SPAWROUTS)

STEELHEAD:
JUVENILES

DOWNSTREAM FISH PASSAGE

CUTTHROAT:
ADULTS (SEE TEXT)

UPSTREAM FISH PASSAGE

DOWNSTREAM FISH PASSAGE
AKD ESTUARY REARING

CUTTHROAT:

KELTS

CUTTHROAT:
JUVENILES

D0WH3TREAM FISH PASSAGE
AHD ESTUARY REARING

WHITE STURGEON:
ADULTS AHD JUVENILES

FISH PASSAGE AHD
ESTUARY REARING

'.■.".V.V.

|

OREEH STURGEON:
ADULTS AHD JUVSHTLBS

BSTUAHY REARDC

!

M 0 R T H

JAR.

FEB.

MAR.

APR

KAY

JUNE

JULY] AUG

SEPT

OCT.

HOV

DEC.

MONTH

Figure! 9. Life history stages and range and peaks of occurrence of steelhead, cutthroat and sturgeon
1n Grays Harbor.

111-18

SPECIES AND LITE HISTORY STAGE

RANOE AND PEAK OK OCCURRENCE

ACTIVTTT

AMERICA*! SHAD:
ADULTS

1

UPSTREAM FISH PASSAGE

vX-Xj-lv:-'

AMERICAN SHAD:

YEAHLING JUVENILES

AND SUB ADULTS

ESTUARY REARTNG

VARIABLE

AMERICAN SHAD:
PRY JUVENILES

DOWNSTREAM MIGRATION
AND ESTUARY REARING

1

ENGLISH SOLE:
JUVENILES

ESTUARY REARING

;i

1

STARRY FLOUNDER:
ADULTS AND JUVENILES

ESTUARY REARING

SAND SOLE:
ADULTS AND JUVENILES

ESTUAKY REARING

DUNOENZSS CRAB:
JUVENILES

ESTUAKY RKARINO

;.;.;.;.;.;.;.;.

i:5:;S;:i:i:

i

1

80PT8HILL (MUD) CLAM:
ADULTS AND JUVENILES

ENTIRE LITE CYCLE

PRESENT ALL YEAR

MONTH

JAN.

FEB.

MAR

APR.

MAT

OCT.

DEC

MONTH

JUNE

JULI

AUG.

JKPT,

NOV,

F1gure20 Llfe history staties and range and peak of occurrence of shad, flounder and shellfish
In Grays Harbor.

o
2
<

Q

Z

CO

<

Chum Salmon

MA*

MAY JUNE

DATE

Figure 2 1 . Outmigration periods of chum, chinook and coho salmon,
and steelhead trout in Grays Harbor, Washington,
March October 1980((from Siminstad 1981).

Type II ■ migrates out of Grays Harbor

Type III portion of the population that remains within the estuary through October

111-19

(2). The salmon runs require areas sheltered from predators for
rearing, resting and feeding during passage, and food produced by the natural
aquatic environment. The essential aspects of the aquatic environment consist
of three types of areas.

(a). Areas below tidal influences; the fish passage and
the most essential part of the fish habitat.

(b). Intertidal areas; areas between low and high tide.
These areas are highly productive of marine organisms, especially the benthic
fauna which are the base of the food web. These areas also afford juvenile
fish food and shelter at higher tides.

(c). Marsh area; these areas are populated by aquatic
grasses and related plants and are a source of insect larvae which are food
for fishes.

While all aquatic/wetland areas are important, some of these areas have been
considered particularly significant by resource personnel who participated in
the planning process. Areas which are considered particularly important
include:

(d). The shallow areas on the Hoquiam waterfront where
juvenile salmon and other fish have the opportunity to rest and feed during
their passage up the Chehalis estuary to spawn.

(e). The Hoquiam Fish Base. Of the shallow areas for fish
feeding and passage, the old "Hoquiam Fish Base" is considered particularly
important.

(f). The South Side Marsh. A remaining stretch of marsh on
the south side of the Chehalis River provides essential nutrients for this
stretch of the estuary and is considered to be needed to maintain the productive
base of this part of the ecological system. Shallows near this marsh also
give opportunities for fish resting and feeding.

(g). The riparian marsh vegetation and related shallow
areas on the Chehalis River. Riparian vegetation is defined as plants found
adjacent to and dependent on river water for growth and development. As the
river narrows through Junction City and Cosmopolis, the shallow areas and the
riparian marsh fringe on the east bank become particularly important to
support the fish passage.

(3). Shad is an introduced species brought from the Atlantic
Coast in the late 1800' s. Two species of sturgeon are found in Grays Harbor:
the green sturgeon (Acipenser medirostris) and the white sturgeon (A. trans-
moutanus). The white sturgeon is more abundant in the upper estuary and
lower Chehalis River and the green sturgeon dominates-in the lower estuary
and more marine waters.

111-20

b. Marine and Estuarine Fishes.

(1). Flat Fishes. The most abundant flat fishes in Grays Harbor
are the starry flounder, juvenile sand sole and English sole and a variety of
small flat fishes such as sand dabs. The broad mudflat areas in the lower and
mid-portions provide extensive feeding and rearing grounds for the juveniles of
commercially important flat fishes, such as the English sole. Flat fishes also
feed upon insect larvae produced in marshes adjacent to tideflats. However.
English sole and starry flounder are present in all areas of the estuary. 2
Some portion of the population of these two species rear in the estuary.

(2). Marine sport fish. "Surf Perches," ling cod, rockfish and
green! ing are resident in the lower estuary throughout the year and are associ-
ated with marine structures such as rock jetties and pilings.

(3). Smelt and Herring. Smelt and herring-like fishes occur in
lower Grays Harbor throughout the year. "Anchovies" feed in the lower bay and
are an important part of the tuna bait-seine fishery. "Herring" are known to
spawn in the lower harbor during the winter and early spring months in areas
of rocks, pilings, and aquatic vegetation.

5. Invertebrates

a. Shellfish.

(1). Oysters. Pacific oysters (Crassostrea gigas) are cultivated
in outer Grays Harbor, principally near Whitcomb Flats, and in North and South
Bays .^ They require a very high level of water quality, feeding primarily on
plankton in the water.

(2). Clams. Both hard-shell and soft-shell clams occur in Grays
Harbor, although gravelly habitat for hard-shelled clams is limited. Hard-shell
clams are comprised of cockles, Washington butter clams and little-neck clams.
Soft-shelled clams (Mya arenaris) are commonly called mud clams. Other small
clams found in the bay contribute significantly as food for waterfowl.

(3). Crabs. Dungeness crab (Cancer magister) forms an important
part of the commercial shellfish landings in Grays Harbor. The crabs utilize
the estuary mainly as a rearing area and are generally found in the channels
and sink holes but move on to the tidal flats to feed at high tide. Juvenile
crabs feed and rear throughout the bay at all seasons of the year.

(4). Shrimp. Ghost shrimp (Callianassa californiensis) is a
tube-dwelling shrimp that burrows in the sand, is used for bait and causes
losses to the oyster industry because they destroy the firmer substrate needed
by the oysters. Other shrimp include mud shrimp, Gray shrimp and various
species of free-swimming shrimp.

b. Benthic Invertebrates. The broad tidal flats produce a great
abundance of small bottom dwelling organisms which are not commercially impor-
tant but are very significant to estuarine ecology as a basic food source to
higher organisms in the food web and are also of scientific and educational
value. It is these organisms that provide a basic link between the plant and
organic matter transmitted to the bay from the marshes and rivers.

111-21

(1). The three most frequently encountered amphipods in Grays
Harbor are Corophium salmonis, Anisogammarus confervicolous, and an Eohaustor-
ious species. C. salmonis appears to be the most numerous benthic macro-
organism found in the inner harbor and midharbor flats and intertidal areas
and is a major prey species for numerous organisms (see figure 22). The role
of C. salmonis vis-a-vis shorebirds is more thoroughly described in appendix C.

(2). A. confervicolous is important in the high intertidal areas
of the inner harbor, and Eohaustorious is the most numerous in the outer harbor.
A cumacean, Leptochelia savignyei, appears to be the numerically dominant
organism in parts of the outer harbor. Another cumacean, a Diastylis species,
is found at Whitcomb Flats and is the most numerous organism in both the North
and South Channels. Capitellid polychaete worms (Heteromastus filiformis) are
also present through the harbor as is the annelid worm (Manayunkia aestuarina)
(from studies conducted by Albright and Bouthillette, 1982).s"ll

(3). Regarding intertidal invertebrates, some generalities as
stated by Albright and Bouthillette (1982) include: species diversity increased
with decreasing elevation, from the inner to the outer harbor; general abundance
of invertebrates was highest in summer and lowest in spring; when epifauna are
excluded, invertebrate biomass was highest in spring and lowest in summer;
annelid worms were the most important group, by number, at e\tery site studied.
Generalities including subtidal invertebrates include: diversity increases
from east to west; diversity is lowest in spring and highest in autumn; and,
total biomass is highest in winter and lowest in summer.

FIGURE 2?

WMUrn
Sandpiper

Eogammarua

Juv. Salmon

Long -billed
Dowitcher

Starry
Flounder

Dunlin

Shiner Fsrch

English Sole

Snake Prlcklebeck

Three- spine
Stickleback

Dungeness Crab

Crangon

Longfin Smelt

Nemetean Worms

Source: Albright and Armstrong (1982)

111-22

6. Threatened and Endangered Species

a. Flora. No threatened or endangered species of plants are known
to occur in the Grays Harbor study area.

b. Marine Animals.

(1). Of the eight marine animals which are found in the eastern
North Pacific Ocean at some time in the year, and are listed as endangered,
only the gray whale (Eschrichtius robustus) has been known to stray into the
inner areas of Grays Harbor during northbound or southbound migration periods. 2

(2). All marine mammals are protected under the Marine Mammal
Protection Act of 1972 (P.L. 92-522). Harbor seals (Phoca vitulina richardi)
are the most common and utilize the outer harbor islands and flats. Other
marine mammals known to make at least occasional excursions into the estuary
are the Steller sea lion (Eumetopias jubatus), porpoises and dolphins. 2

c. Avian Fauna.

(1). American Peregrine Falcon. The recorded sitings of the
American peregrine falcon (Falco peregrinus anatum) are sufficiently complete
to confirm the presence of the endangered species in the Grays Harbor area
(see appendix C). Previous sitings were generally thought to be the Peale's
variety (F. p. pealei ) which generally inhabits coastal areas. Areas in which
falcons (without respect to subspecies) have been sited include:

o Oyehut Wildlife Recreation area,

o Point Damon,

o North Bay and the Humptulips River Delta,

o Point New,

o Bowerman Basin (most abundant sitings),

o Rennie Island

o South Bay and Elk River.

In addition, Dr. Steven G. Herman, a noted bird expert who has studied shore-
birds and falcons in the Grays Harbor area for an extended period of time,
has stated that his observations strongly suggest that arctic peregrines
(F. p. tundrius) may also migrate in small numbers through Grays Harbor during
spring migration of the shorebirds.10 No specific identification has been
made to date however. Because anatum has been specifically identified hunting
upon the large shorebird populations in the Bowerman Basin which was designated
for development, OCRM has conducted Section 7 (Endangered Species Act) consul-
tation with the U.S. Fish and Wildlife Service (see appendix C).

(2). Bald Eagle. The norther race of the bald eagle (Haliaeetus
leucocephalus alascanus) is regularly sited in Grays Harbor. They have been
sited preying upon waterfowl and shorebirds but normally feed upon salmon and
fish species.

111-23

(3). Brown Pelican. Palecanus occidental is has been sited at the
mouth of Grays Harbor. Grays Harbor is near the northern range limit of the
brown pelican.

(4). Snowy Plover (Charadrius alexandrius nivosus). The snowy
plover is a candidate species to be added to the Endangered Species List. There
are only a few nesting pairs which have been observed on Damon Point.

d. Other Species of Concern.

(1). Caspian Tern. Whitcomb Island contains the largest identi-
fied colony of Caspian Terns on the west coast.

(2). Great Blue Heron.

(3). Brant.

(4). Olumpic Mudminnow.

(5). Black Stickleback.

(6). Short-tailed Weasel.

SOURCES: Sections C & D

1. Vincent, Mary K., Habitat Development Field Investigations, Rennie Island
Marsh Development Site Grays Harbor, WA, Corps of Engineers, 1978.

2. Corps of Engineers, Seattle District, Grays Harbor, Chehalis and Hoquiam
Rivers, Washington - Channel Improvements for Navigation, "Interim Feasi-
bility Report and Final Environmental Impact Statement," 1982.

3. Montaigne-Bierly Associates, Grays Harbor Estuary Management Program,
"Phase I Technical Memoranda," 1977.

4. Norman Associates, Grays Harbor Erosion Management Study, prepared for
the Grays Harbor Regional Planning Commission, 1974.

5. Corps of Engineers, Seattle District, Long-Range Maintenance Dredging
Program, FEISS No. 2, 1980.

6. Opdyke, Jeffrey D. , Final Fish and Wildlife Coordination Act Report, "Grays
Harbor, Chehalis and Hoquiam River, Washington," U.S. Fish and Wildlife
Service, Sept. 1982.

7. Miller, G.H., Eel grass Distribution, Density, Leaf Length and Standing
Stock in Grays Harbor, Seattle District Corps of Engineers, DACW 67-77-M-
1240, 1977.

111-24

8. Thorn, Ronald M., Primary Productivity and Carbon Input to Grays Harbor
Estuary, Washington. Prepared tor Seattle n-Utr-irt r^ nf Fnginccrc, bCl .

9. Smith, J.D. and D.R. Mudd, Grays Harbor Maintenance Dreoqmu and the tnvi-
ronment Appendix H. Impacts ot Dredging on the Aviana Fauna in Grays
Harbor. Seattle District Corps of Engineers, 1976.

10. Herman, S.G. and J.B. Bulger, The Distribution and Abundance of Shorebirds
During the 1981 Spring Migration at Grays Harbor, Washington. Prepared for
Seattle District Corps ot Engineers, 1981. " L

11. Albright, R , and P.K. Bouthilette, Benthic Invertebrate Studies in Grays
Harbor, Washington, Prepared for Seattle District Corps ot Engineers, 1982.

111-25

E. Socioeconomic Environment

1. Grays Harbor has a natural resource economy based on harvest, manu-
facture and/or export of products derived from natural production. Forestry,
commercial fishing, tourism, and agriculture comprise the economic base of
the region. Because of seasonal employment characteristics in these economic
sectors, the area has chronically high levels of unemployment, significantly
higher than State and national averages.

2. The Hoquiam, Aberdeen, and Cosmopolis areas in the upper bay com-
prise the major urban and industrial locations in the study area. Timber
and timber products processing and shipping facilities are located in this
region of the bay. Grays Harbor is a major shipping port for timber products
to national and international markets. In 1980, 498.2 million board feet
(Scribner Scale) of logs were exported. 1 Grays Harbor is Washington's only
Pacific Coast deep water port. In 1982 approximately 2.4 million tons of
imports and exports of water borne foreign and domestic commerce occurred in
the harbor. 2 The estuary has had an authorized and maintained navigation
channel since 1906, and has historically been a major shipping port for forest
products. The currently proposed deepening of the 30 foot channel to Cosmopo-
lis to a depth of 38 feet will require an initial disposal of approximately 19
million cubic yards of material and an annual maintenance dredging of 2.8
million cubic yards. The proposed new channel will accommodate the larger and
deeper draft vessels being used in the international market place. The GHEMP
calls for the preparation of a Dredged Material Disposal Plan to be compatible
with the approved plan.

3. Westport is the commercial and sport fishing center of the Grays Harbor
area, and because of its proximity to the deep draft navigation channel it has
potential to expand into deep draft activities. Ocean Shores is a tourism,
retirement, and suburban area.

4. Grays Harbor County had a 1980 population of 66,314 (U.S. Bureau of
the Census). This is estimated to have declined to 66,100 in April 1982 (Office
of Financial Management, State of Washington). The population of Grays Harbor
County declined from 1930 to 1940, then rose slowly to the 1980 level with
1980 being the first year to exceed the 1930 population. The county population
increased by 11.4% in the 1970's. While the forest industry has fluctuated
with national and international markets, the tourism industry has generally
expanded. The population of Westport and Ocean Shores went from about 300 in
1930 to 3,908 in 1982. While growth in the urban areas of Aberdeen, Hoquiam,
and Cosmopolis increased after World War II, this area has declined in popula-
tion by almost 18% from 1930 to 1982.

5. Although less densely populated areas such as Grays Harbor have become
increasingly attractive to urbanites seeking homes with more open space, the
area's lack of job opportunities has been a major contributor to its lack of
population growth.

6. Five incorporated communities are located around Grays Harbor, (see
table 6).

111-26

TABLE 6
POPULATIONS BORDERING GRAYS HARBOR: 1982

Grays Harbor
County

Aberdeen

Hoquiam

Cosmopolis

Westport

Ocean Shores

66,100*

18,550

9,490

1,570

1,990

1,918

Source: Washi

ngton State Office o1

F Financial Mc

magement.

*This figure is a total Grays Harbor County population figure and not the

unincorporated population which abuts the estuary. The population of the

unincorporated areas which borders the estuary is about 4,000, the largest
portion being in the Central Park area.

Each of the incorporated communities is expected to have a modest growth rate
during the next decade (see table 7).

TABLE 7

POPULATION PROJECTIONS: 1990

Grays Harbor
County

Aberdeen

Hoquiam

Cosmopolis

Westport

Ocean Shores

72,865

19,520

11,039

2,052

2,485

2,969

Source: Grays Harbor Regional Planning Commission.

7. The dominant land use in Grays Harbor is forestry (see attach. 1 , map 1 ,
Existing Land Use). Over 90 percent of the county is timberland. 3 Agriculture
and pasture lands make up approximately three percent of the county's land. 4
The remainder is utilized for industrial, commercial, residential, and recrea-
tional uses.

8. Approximately 1,070,000 acres (87.5%) of Grays Harbor County was
classified as forest land capable of producing 20 cubic feet per acre per year
of industrial wood and available for timber production in 1980. 3 The National
Forest comprises 34% of the public timberland (12% of the total timberland)
and 78% of the private ownership is controlled by the forest industry (about
50% of the total timberland) (see table 8). Nearly all this land is under
some form of management program. In the
to the shoreline as on the south shore,
percent of the front footage along the
Cosmopolis area, using this footage for mill
(see Attach. I, Map 2, Land Ownership).

TABLE 8
' 01"

estuary area, timber use may extend
Timber interests also own about 62
water within the Aberdeen-Hoquiam-
sites and for shipping facilities

TIMBERLAND OWNERSHIP

PUBLIC

PRIVATE

Ownership Class

Thousand Acres

Ownership Class

Thousand Acres

National Forest

131

Forestry Industry*

533
14

Indian

127

Fanner

Other Federal

1

Miscellaneous

139

State

76

County and Municipal

50

TOTAL

385

686

Source: Timber Resource Statistics for the Olympic Peninsula. 3

*Major corporate owners include ITT-Rayonier, Weyerhaeuser, Boise-Cascade,

Simpson Lumber Company, and Mayr Brothers.

1 11-27

9. Forest products constitute one of the major industries in the State
of Washington. This industry produces lumber and wood products, and paper and
allied products. The forest products industry has historically been the major
source of employment in Grays Harbor County. In 1975, 83% of all manufacturin
jobs and over 28% of the total employment were in these employment sectors.
In 1981, 83% of all manufacturing jobs and approximately 23% of the total
employment were in these sectors.5 This later figure reflects an increase
in total employment caused by the Satsop Nuclear Power Project and its large
temporary construction work force in Eastern Grays Harbor County and a general
recession in the timber industry.

10. The historical dependence upon the forest industry has also produced
fluctuating employment levels with unemployment rates generally exceeding
State and national rates. During the first six months of 1982, the unemploy-
ment rate in Grays Harbor was 16.4% compared to the State rate of 12.4% (see
table 9). 6 Approximately 41% of the total persons receiving unemployment
benefits in Grays Harbor County were in the logging, lumber, pulp, and paper
sectors. 7 To combat this heavy dependence on these employment sectors, the
need for diversification of the economic base of Grays Harbor was identified
as early as 1961 and has been a priority goal in every Overall Annual Economic
Development Program since that time.8

TABLE

9

AVERAGE ANNUAL

UNEMPLOYMENT

GRAYS HARI

1972-1982

Percent of

Grays Harbor County

Percent of State

National Labor

Number of

Percent

Labor Force

Force

YEAR

Unemployed

Unemployed

Unemployed

Unemployed

1972

2,370

9.4

9.5

5.6

1973

2,320

8.9

7.9

4.9

1974

2,413

9.3

7.1

5.6

1975

3,156

12.4

9.6

8.5

1976

2,107

8.0

8.6

7.7

1977

2,656

9.6

8.8

7.0

1978

2,310

8.0

6.8

6.0

1979

2,770

8.7

6.8

5.8

1980

3,326

10.3

7.5

7.1

1981

4,709

13.9

9.2

7.6

9/1982

4,520

13.2

11.1

9.7

Source: Washington State Department of Employment Security and U.S.
Department of Labor.

11. Commercial fishing is also a major contributor to the area's economy.
Grays Harbor supports large populations of fish and wildlife which are the
basis for the commercial fishery and a significant proportion of the tourism
economic sector. Westport ranked among the top 40 ports in the country in

111-28

poundage and values of commercial fisheries products landed in the United
States in 1981. 9 Approximately 16% of the gross tonnage of all commercial
boats in Washington were Grays Harbor boats, and about 3.2% of the total State
net fishery for 5 species of salmon were landed near Grays Harbor in 1981.9
In 1982, preliminary figures indicate that approximately 52% of Washington's
commercial troll salmon fish was caught in the ocean area near Grays Harbor. 10
Other than anadromous fish, landings in Grays Harbor include salmon eggs,
shad, and sturgeon totaling about 36,000 lbs. in 1981 .9 Other major marine
fish landings include sole, halibut, and cod. The major processing and landing
facilities are at Westport. The major oyster processing plants are in South
Bay, though oyster rearing occurs in both the South and North Bays. Approxi-
mately 73,000 gallons or 11% of the total oysters produced in Washington State
were from the Grays Harbor area in 1981 .9 Other shell fish harvested include
crab, shrimp, and clams (see Attach. I, Map 10, Natural Resource Use).

12. Tourism, Parks and Recreation.

a. Tourism is directly related to the esthetic characteristics of
the ocean and to other regional attractions. Ocean marine angler trips (charter
boats, salmon fishing) from Grays Harbor accounted for over 50% of the yearly
Washington State total in 1982*0 and represent an influx of about $9 million
to the local economy in direct revenues. H Waterfowl hunting is concentrated
in the North Bay, South Bay and Chehalis River areas, and fishing for salmon
and other species in the streams tributary to the estuary represents a signi-
ficant portion of the total tourist dollar flow. The estuary is also exten-
sively used for non-consumptive wildlife viewing, especially bird watching,
due to the excellent opportunity available to observe a wide variety of birds.
This viewing has been estimated, by fish and game biologists, to equal the
hunting activity (in total man-days) in the bay (see figure 23 for sites).

Humptulips
River

Grays Harbor Estuary
Management Program

0 1 2 3

Montagne-Bierly Associates, Inc. scale

(nautical miles)

Chehalis

River
Cosmopolis

Non-consumptive
Resource Use

f§§j|> Areas Used For

Wildlife Observations

FIGURE 2 3

111-29

b. The major public recreation facilities in the study area itself
include the Westport and Ocean Shores Marinas, several public boat ramps, and
over 3,000 acres of managed wildlife areas. Significant State parks are found
along the ocean beaches where demand for such facilities is considerably higher
than in the estuary itself. There are two water oriented lake parks which
provide a full range of water recreation near the estuary at Lake Aberdeen
(a city park) and Lake Sylvia (a State park). The GHEMP contemplates the
development of a waterfront park in Aberdeen.

c. The estuary and surroundings have significant aesthetic values
which are detailed in An Interpretive Survey of the Grays Harbor Area.

13. Agriculture also contributes to the regional economic base. The two
most significant agricultural producers are the cranberry bogs near Grayland
and North Bay and dairy farming. The Pacific Northwest's only cranberry process-
ing plant is located at Ocosta in the southwest part of the Central Bay area.
County land utilized for agriculture totaled approximately 50,000 acres in
19783 Agricultural uses within the estuary study area are limited to about
92 acres of cranberry bogs on the North Bay, approximately 900 acres of farm-
land west of Montesano, and about 100 acres of pasture in the Ocosta area.
Due to favorable soil conditions, most of the county's farmland extends east
and south from Montesano.

14. The future of Grays Harbor will depend upon maintenance of employ-
ment levels in these four major industries. Expansion in any one area will be
bounded somewhat by serious environmental considerations, but a balance must
be sought between economic growth in these four sectors and environmental
management and protection of the estuary as an essentially fragile resource.
Future land use decisions in the area will inevitably be tied to this need for
balance. Both economic improvement and environmental protection can and must
be pursued simultaneously as twin land use goals of paramount importance to
Grays Harbor.

15. The impacts, use, and development in and adjacent to the estuary are
controlled by a complex set of laws and regulations (see Attach. I, Map 3,
Jurisdiction and Boundaries). Local jurisdictions regulate land uses through
planning and zoning ordinances. The State of Washington Shoreline Management
Act, State Environmental Protection Act, and other State laws regulate land
use, natural resource management, harvest, and environmental quality. Federal
resource protection, management and environmental laws regulate shore! and and
waterway alteration. The coordination of these three levels of government
control (State, local, and Federal) toward commonly agreed-upon goals is the
major objective of the GHEMP.

16. Transportation and Utilities. (See attach. 1, maps 4 & 5)

a. Air. The estuary is currently served by three public airports,
two of which are located in the study area. Two of the public airports, West-
port and Ocean Shores, are inadequate to serve the communities, especially for
their tourism role. The Bowerman Airfield serves as the regional airport.

111-30

b. Rail. The area is served by two rail lines which generally abut
the shoreline of the estuary for extensive distances, and for large distances in
the lesser developed area the lines form artificial barriers between the aquatic
and upland environments. Therefore, the rail lines are generally used as the
study boundary lines for the plan.

c. Road. Traffic circulation through Aberdeen-Hoquiam is currently
a problem with minimal separation of industrial, local and through traffic on
the congested urban arterial s. Both Ocean Shores and Westport generate high
volumes of weekend and summer tourist traffic with a high portion of the
traffic consisting of slow moving recreational vehicles and trailers. Port
industrial areas generate large volumes of log truck traffic as do the commer-
cial centers.

d. Utilities. There is sufficient water, sewer and energy capacity
to service anticipated future growth in the Aberdeen-Hoquiam-Cosmopolis area.

SOURCES: Section E

1. U.S.D.A., Ruderman, Florence K. "Production, Prices, Employment, and Trade
in Northwest Forest Industries, Fourth Quarter, 1981." May 1982.

2. Port of Grays Harbor, "Annual Report-1981 ."

3. U.S.D.A., Bassett, P.M. and Oswald, D.D. "Timber Resource Statistics for
the Olympia Peninsula, Washington, "Resource Bulletin PNW-43," November
1981.

4. U.S. Department of Commerce, Bureau of the Census, "1978 Census of Agricul-
ture, Vol . 1 State and County Data, Port 47 Washington," AC78-A-47.

5. Washington State Employment Security Dept., Nonagriculture Wage & Salary
Workers, by place of work.

6. Washington State Employment Security Department, Resident Civilian Labor
Force and Employment, by Place of Residence.

7. Washington State Employment Security Department, Insured Unemployed by
Standard Industrial Sector by Job Service Center.

8. Grays Harbor Regional Planning Commission, "Overall Economic Development
Program for Grays Harbor County, Washington," Aberdeen, WA, June 1979.

9. Washington Department of Fisheries, "1981 Fisheries Statistical Report,"
Olympia, WA.

10. Washington State Department of Fisheries, "Washington Ocean Salmon Catch
Summaries," 12/19/82, Preliminary.

11. Washington State Research Council, "The Washington State Visitor Industry:
Economic Impacts and Data Base Development," May 1982, and Grays Harbor
Regional Planning Commission, "Grays Harbor Tourism Plan," March 1983

111-31

PART IV: ENVIRONMENTAL CONSEQUENCES

PART IV: ENVIRONMENTAL CONSEQUENCES

A. INTRODUCTION

1. This part discusses and analyzes impacts expected to occur to the
Grays Harbor environment due to plan implementation and impacts associated with
alternatives. Even though this is a program EIS which addresses impacts on a
generic scale, it also attempts to be specific in some areas where those impacts
can reasonably be expected to occur. Further specific impacts (i.e., air and
water quality) associated with a specific use or activity can only be analyzed
on a case-by-case basis and will have to await review at the point of permit
application. Because of the commitment to utilize the plan by the various
regulatory and resource agencies, it is important to have an overall understand-
ing of the potential impacts which will be associated with the fulfillment of
the MU designations, whether or not they occur in reality.

2. There are two assumptions made in this analysis of impacts. First,
the impacts are considered within the framework of a comprehensive plan for the
estuary in which the concept of a balance was considered to include tradeoff
between resource use and protection. Second, GHEMP does more than just modify
existing local SMP's as described earlier in this statement (Part I); neverthe-
less, land and water use activities are currently taking place which may be
similar in nature to those envisioned by the plan because they are consistent
and permitted by existing local SMP's. Thus some impacts would be expected to
occur to estuarine resources irrespective of plan implementation. Therefore,
the major focus of concern deals with MU 12 - the Bowerman Basin - and the
impacts associated with future port expansion in an estuarine area which has
been identified as significant to migratory shorebirds and peregrine falcons.

3. Perhaps the major caveat which should be remembered is that the "plan
is designed to provide guidance to the decisionmaking process, it does not make
decisions itself" (GHEMP, p. 6). In short, what one reads or envisions may not
be what actually takes place since that will be a function of future requests
for development. To the extent that activities are consistent with the plan,
this EIS should be useful in the assessment of those activities.

B. ELEMENTS OF THE PHYSICAL ENVIRONMENT

-• Earth

a. Geology, Soils and Topography. If implemented, the plan would allow
some alterations of the shoreline and wetlands through fill while limiting fill
in other sections especially in existing urban areas. Some areas, notably a
section of the Bowerman Basin, would be raised and leveled from existing con-
tours. Topography would change at Westport Marina and Airport, Ocean Shores
Marina and Airport, and proposed industrial sites at MU's 12, 14, 15, 16, 17,
18, 25, and 26. Marine structures and works permitted in the plan may also
alter the geomorphic processes of erosion and sedimentation by altering the
local hydraulics of the system. From a geologic perspective, these influences
are expected to be minor. The plan protects soils which are conducive to
agricultural practices in North Bay (MU 8) and the Chehalis River (MU 22).
Dredge spoil displaces bottom sediments as new soil for purposes of fill or
marsh habitat creation.

IV-1

b. Unique Physical Features. The Bowerman Peninsula is a unique
man-made physical feature. The western toe of the peninsula would be extended
westward under the first phase of development (Area 2) and northward under
the second phase of development (Area 3). Minor alterations to Rennie Island
(MU 43) will continue through the additions of dredged materials disposal for a

short term.
34, 41 , and

Few, if any, alterations are permitted to occur in MU's 2, 3, 29,
42.

c. Erosion. Erosion and siltation from upland sources are not ad-
dressed in the plan. Shoreline erosion mitigation to both man-made and natural
features through both physical and natural means can be expected to be
minimized through the policy on Bankline Erosion Control. The plan specifically
limits areas in which erosion control measures can be taken and only under
specific criteria and standards applied in the policy (GHEMP, p. 24). Some
form of bankline erosion control would be permitted in the following MU's:

5ermitted Conditional I

special

UD -

11, 14, 15, 18,

26, 28

25

UM -

4, 16, 17, 39

37, 38

6, 33, 35

UR -

21

5

RL -

9, 10, 23, 27

30, 32, 36

RA -

22

31

8

CM -

1, 40

26, 43

3, 24, 28,

33, 35

CN -

30, 38

SP -

12, 19

Each MU was reviewed for it assets, purpose for erosion control and potential
adverse impacts. Given the conditions put into the policy, it is believed the
environmental consequences of the implementation of the policy for permitted
activities will be minima] both individually and cumulatively to the natural
environment and is designed mainly to protect public works (e.g., roads and
bridges), private property and natural resources. Implementation of the policy
in other areas may be deemed potentially significant and activities are there-
fore considered as conditional or special uses requiring extra review for
impacts (e.g., see MU's 5 and 6 which allow erosion control measures only out
to the waterward limit of residential lots). The effect of the plan's imple-
mentation will be to reduce shoreline erosion, including the reduction of sus-
pended particles and toxic materials from runoff; remove debris and solid waste
build-up; and in some cases lead to revegetation of the bankline. Adverse
impacts could include the modification of fish and shorebird habitat, although
implementation of the policy would ensure minimal adverse effects. Major
erosion impacts, however, occur outside the plan area in the upper reaches of

estuary is mainly an accreting area, it is not ex-
many erosion stabilization projects proposed outside
or the entrance of the harbor based upon past exper-
(COE, personal communication, 1982).

the watershed. Since the
pected that there will be
of the urban environments
ience for permit requests.

d. Accretion/Avulsion. Marine structures and works can be expected
to create minor modifications to the hyraulic regime through accretion (build-
up) or avulsion (wearing away). The major areas which might have such impacts
are located in the upper estuary (MU's 15, 16, 17, 18, 25, and 26) and near
the mouth of the estuary (MU's 1 and 40).

IV-2

2. Ai_r

a. Air Quality. Although the plan does not specifically address air
quality concerns, effects of two types might be projected if the plan were
implemented.

(1). Since the plan provides increased areas for industrial uses
near Bowerman Field, on South Shore and other areas, such uses could result in
increased pollutants both by direct emissions (industrial sites) and by in-
creased traffic generation (including boats). The population is expected to
grow as a result of economic development envisioned by the plan. Since direct
emissions are rigidly controlled by the Olympic Air Pollution Authority,
these impacts are not expected to be major or exceed safe levels. The Grays
Harbor airshed does not currently have major air quality problems. The nature
of any direct or indirect emissions would vary substantially by the specific
type of use which would be developed in these areas. Air quality impacts
from specific uses (such as those which might locate in MU 12, the Bowerman
Basin) will be reviewed on a case-by-case basis. Since all other areas desig-
nated as Urban are committed to such uses already, the plan represents almost
no other impact on air quality in these areas. Improved airport facilities
can be expected to induce greater utilization at Ocean Shores and Westport,
thereby increasing the levels of airplane emissions entering the surrounding
estuary.

(2). Since the Rural, Conservancy and Natural designations would
prohibit intensive use and tend to conserve vegetation, conservation of such
areas as envisioned in the plan would tend to be beneficial to air quality
and its shorelines.

b. Odor. The impact of the plan on odor is largely similar to that
of air quality, with actual impacts dependent upon the types of uses which
would be developed.

3. Water

a. Surface Water Movement. Since the plan permits some modification
of aquatic areas, the plan would affect localized water movement. The most
apparent way is by the displacement of water or intertidal area with upland
wherever filling may be permitted, or by inhibiting tidal flushing. Such
areas would be limited to:

(1) Moon Island Tideflats and Bowerman Basin (MU 12). This area
is flushed daily. Filling would not alter the predominant east-west tidal
flow. Filling will provide a more sheltered area from wave attack with potenti-
ally less sediment stirring (Dave Schuldt, Seattle Corps of Engineers, personal
communication 3/83).

(2) Port Slip (MU 15).

(3) Westport Basin (MU's 38 & 39).

(4) Aberdeen Park (MU 17).

(5) Wherever bankline straightening is applied.

(6) Wherever bankline erosion control is developed.

IV-3

(7) Wherever activities may require some filling or diking.

(8) Harbor entrance and navigation channel.

These actions when taken either individually or cumulatively should not signifi-
cantly alter estuarine circulation nor flushing. Channel improvements which
have the greatest potential for altering surface water movements are neither
permitted or prohibited by the plan (in MU 44) and are considered through
existing procedures. The hydraulic alterations associated with the potential
widening and deepening of the navigation channel are discussed in the Channel
Improvements FEIS (Corps, 1982).

b. Runoff /Absorption. Since the use designations of the plan are
largely similar to existing patterns, the effect of the plan on runoff and
absorption would be relatively minor. The most significant effects would
occur in the utilization of Areas 2, 3 and 5 of MU 12 by various uses, and the
infilling of vacant areas within designated Urban areas. Other significant
areas would include the South Shore (MU 26) and Cosmopolis (MU 25). Naturally,
the plan itself will not create growth but would allow it occur. The specific
effect of future uses will depend on the particular design of such developments
and would be evaluated during project submissions.

c. Floods. While filling would reduce the natural capacity of the
estuary to absorb flood waters, the amount of fill which would be permitted by
this plan, coupled with the locations and configurations, would produce an
imperceptible effect. No development is planned in any area designated as a
floodway but some development in the Rural and Urban MU's would be located in
the 100-year floodplain. The plan states that the South Aberdeen flood control
project, which has been previously evaluated by the Corps of Engineers, is
consistent with the plan (GHEMP, p. 80). This would reduce flood hazards in
South Aberdeen and Cosmopolis.

d. Surface Water Quantity. Implementation of the plan would reduce
the tidal prism of the estuary wherever filling would be permitted. Such
reduction, however, is limited by the plan to approximately 600 acres of the
remaining 54,720-acre water surface at high tide (approximately 1.1 percent).

e. Surface Water Quality. While implementation of the plan would
tend to conserve water quality by protecting undeveloped areas of the bay from
significant encroachment, the specific relationship of the plan to the water
quality warrants specific analysis.

(1). Impact of actions.

(a). Bowerman Industrial Complex. The filling of Area 2
and 3 should have a short term adverse effect during construction on the
water quality of the surrounding area of the estuary due to the regulation of
disposal methods and the fact that the dredged material disposal would be
confined behind dikes. The most adverse impacts would be associated with any
dike failure (should that occur) during filling operations. Potential effects
are temporary increases in turbidities, nutrient levels, toxic substance levels
and decreases in dissolved oxygen and acidity (pH). State and Federal agencies
monitor such filling to ensure compliance with water quality standards. Factors
that influence the impact of filling are river flow, time of year, type of
fill, method of fill, amount of fill and location of fill. Before the project

IV-4

is started, all primary and secondary factors will be addressed to reduce the
overall impact. Industrial development of these sites would lead to increased
sewerage loads, both directly and indirectly. Since no new point discharge is
expected, these loads would need to be accommodated in the municipal systems.
The Hoquiam System has been reconstructed, and it is anticipated that capacity
would be sufficient to accommodate future demands. Of potential concern
will be the non-point discharges including storm water runoff which may dis-
charge into the Bowerman Basin or into the navigation channel which may event-
ually mix with tidal flows into the Basin. The degree of impact will depend
on the type of uses to occupy the land and specific measures taken to minimize
non-point discharges.

(b). Modification of Port Slip. The modification of Port
Slip No. 1 includes filling (20 acres) and redevelopment of the area. A tem-
porary increase of suspended particles and a decrease in dissolved oxygen in
the fish passage could result from the project. The Corps of Engineers has
evaluated this proposed use of the site for dredged material disposal in rela-
to the proposed channel improvements and determined that impacts of disposing
of dredged material (some polluted) behind containments structures would not
have significant adverse impacts and mitigation would not be required. (COE,
Channel Improvements FEIS, 1982).

(c). Marinas. The plan contemplates the future expansion
of the Westport and Ocean Shores Marinas and the construction of the Aberdeen
Park Marina. Marinas generally degrade water quality because they inhibit
complete tidal flushing creating a decrease in dissolved oxygen levels, in-
creases in toxic substances (oil based products) and flotsam. MU 4 permits
only continued operation of maintenance of the existing outfall and no new
outfall. MU 38 would permit marina expansion from MU 39 if better flushing
would occur (GHEMP, p. 99). The GHEMP clearly demonstrates a sensitivity to
water quality and marina maintenance and expansion.

(d). Airports. Airport runways and particulates from air-
craft exhaust may increase non-point sources of pollution through runoff into
the surrounding aquatic areas.

(e). Bankline Straightening. During construction, tempor-
ary water quality problems may occur similar to other fill situations (i.e.,
increase in turbidity levels, reduced light penetration, addition of pollutants,
increase in oxygen demand). Bankline straightening is permitted only in MU's
15, 16, and 17 and under special conditions in MU's 12, 18 and 25. This is
in the already highly modified environment and in State Class B waters. The
actions are limited to 2 acres in size which individually or cumulatively
should not significantly impact water quality. Water quality to protect the
fish migrations is important in this area.

(f). Bankline Erosion. The Bankline Erosion policy is de-
signed to reduce erosion and stabilize banklines. Some of the effects of reduced
erosion are reduced suspended particles and toxic materials from runoff, and the
removal of debris and solid waste build up. The long-term effect is expected
to be a minor improvement in water quality (since this is a function of
how many individuals or applicants utilize this provision of the plan).

(h). Structures. Temporary reduction in water quality will
result during construction of structures. Minor fills, use of heavy equipment,
and realignment of the shoreline will increase suspended particles, and reduce
dissolved oxygen levels. After the construction is complete, water quality
will return to near normal conditions.

IV-5

(i). Mineral Extraction. No significant water quality
problems are expected to take place as a result of aggregate mineral extraction.
Exiting operations in MU 22 are monitored by State agencies to ensure suitable
water conditions. New mineral extractions will be required to submit plans to
State agencies. MU 44 policy states that aggregate extraction is conditionally
permitted if water quality standards can be met, there are no adverse impacts
on fish habitat or seasonal fish runs, and there are no alternative sources
in the general urbanized inner harbor.

(2). Management Categories

(a). Urban. Urban Management categories (i.e., UD, UM and
UR) contribute most of the pollutants entering the estuary. Heavy industry,
municipal uses, non-point out-flows and ground seepage are major ways pollution
enters the estuary (in addition to siltation). Plans have been implemented by
local municipalities to meet water quality standards set by the Federal and
State governments to improve the water conditions. Municipalities and private
corporattions have made significant improvements to reduce point source efflu-
ents entering the estuary. The Cities of Hoquiam, Aberdeen and Cosmopolis
have completed development of separated sewage and storm drainage systems.
Westport has developed a new sewer plant with an adequate capacity to handle
future growth and additional fish processing plants. Ocean Shores is planning
to expand its sewer system to reduce sewage outflows. At the present time it
is impossible to determine the total effect or when some proposals are going to
be implemented, but a general improvement in water quality is expected to
occur. The major impact that the estuary plan has on these conditions is to
specify limits to urbanization around the harbor.

(b). Rural. The designation of rural categories (i.e.,
RL and RA) is not expected to affect water quality in the estuary. The type of
pollutants entering the estuary will be leachates, fertilizers, surface runoff
and erosion. The plan does not significantly alter existing conditions or
problems but does reduce potential problems by restricting urban encroachments
into these areas.

(c). Conservancy. Conservancy categories (i.e., CM, CN
and N) aid the natural biological water quality cleaning process. The conser-
vancy categories are designed to preserve much of the natural habitat, micro-
organisms and aquatic vegetation that aid in improving water quality. Further
water quality concerns in the estuary and the tributary basin are specifically
addressed in the Regional Water Quality Management Plan - Basin 22, and the
actions envisioned in this estuary plan are largely consistent with that plan.
This Water Quality Management Plan is the basis of the State's 208 planning
in this basin.

f. Ground Water Movement and Quality. The affect of the actions
and policies envisioned in the plan on ground water movement and quality would
be relatively minor.

h. Public Water Supplies. The impact of this plan on public water
supplies would be to increase their use. The levels of development contem-
plated in the plan can be supported by either existing or planned facilities.
In the case of industrial and port development aspects of the plan such devel-
opment is needed to utilize the existing industrial water system which is
underutilized at this time.

IV-6

C. ELEMENTS OF THE BIOLOGICAL ENVIRONMENT

1 . General

a. Future impacts associated with activities which may be consistent
with the plan can be separated into two categories: first, impacts associated
with dredged material disposal, filling and placement of structures; and second,
land use activities which utilize the fill sites or structures. The major
impacts of concern in the GHEMP will be due to the discharge of dredged and
fill material in selected sites, behind confined dikes, to be used, when filled,
for some form of land use activity (i.e., port, industry, transportation,
etc.).

b. The potential and actual impacts associated with dredged material
disposal on aquatic habitats in Grays Harbor have been studied and discussed at
length by previous investigators J The most significant adverse impact includes
the direct loss of habitat through covering (or removal) which destroys vegeta-
tion, smothers immobile organisms and forces mobile forms to migrate, alters
substrate or destroys access to important feeding, nursery and resting areas
temporarily (if subsurface disposal) or permanently (if uplands are created)
leading to mortality or community disruption. With respect to the fringe
areas of confined fill sites, the bulk and composition of the fill material
and the location, method and timing of discharge may all influence the degree
of impacts on the substrate. Other factors such as changes in normal water
conditions (clarity, chemical content, nutrient balance, D.O., pH, temperature,
salinity, current patterns, circulation and fluctuation) near the impacted site
may also have direct or secondary effects on habitats increasing stress placed
on the ecosystem or sub-element of the ecosystem.

c. While Grays Harbor has a choice diversity of habitats, some appear
to be more critical than others based upon biological productivity and utiliza-
tion. It is important to protect the water and vegetative habitats in order
to ensure there is no decline in the total diversity of the faunal and vege-
tative species which inhabit the estuary or utilize it during migration periods
even though there may be a decline in abundance of organisms utilizing parts
of the estuary due to partial loss of habitat.

d. GHEMP would allow, subject to further permit review when required,
a number of projects which will produce local significant adverse environmental
impacts. The plan also guarantees positive environmental impacts, which are
discussed generally. Vast areas of relatively undeveloped shoreline, estuarine
waters and habitat are protected from development either through MU designa-
tions, conditions placed upon activities (including mitigation and enhancement
requirements) within those MU's, and transfer of potentially developable and
environmentally sensitive land and water areas to the public domain. All users
of the estuary will benefit from an approved plan which provides substantially
better guidance for development by incorporating many requirements of Federal,
State and local governments.

1. A complete listing of pertinent references is available through the Seattle
District of the U.S. Army Corps of Engineers.

IV-7

2. Vegetation and Habitats

The impact of the plan on flora resources of the estuary is similar
several other relationships: a significant impact will occur in

a.
in nature to

areas designated for urban uses and on shorelines where modifications are planned
or permitted; this is balanced by a conservation and protection of resources in
areas designated for lower intensity uses.

b. Table 10 summarizes the potential loss of aquatic areas which
would be impacted by future projects. These are also the areas in which fish
and wildlife resources will be impacted, with some impacts extending beyond the
impacted vegetation zone (i.e., the fringe or edge zone).

TABLE 10

Project

Habitat Affected Approx. Acres Filled*

Bowerman Complex (MU 12)

Tidal Mudflats up to
Eel grass beds up to
Low silty marsh**

350

100

30

Hoquiam Fill (MU 14-Area

7)

Low silty marsh

20

Ocean Shores Airport (MU 4)

Freshwater marsh
High immature marsh

10
30

Westport Marina (MU 39)

Low sandy marsh

48

Westport Airport (MU 38)

High mature marsh

15-18

Aberdeen Marina (MU 17)

Intertidal
Sedge marsh

1.3

1

Port Slip #1 (MU 15)

Intertidal /Subtidal

20

South Shore Site (MU 26)

Freshwater marsh

98

* These are estimates. Final determinations must be made at the time of

permit submission by the applicants.
** The low silty marsh north of the Bowerman Peninsula would be reestablished,

and additional marsh would be established along the north side of Area 2.

This would be at the expense of some intertidal mudflat habitat. So there

may be a net increase in low silty marsh in MU 12.

IV-8

c. Site specific impact analyses related to the Ocean Shores Airport
and Port Slip #1 have been previously reviewed through the NEPA process.! The
impacts associated with the Aberdeen Marina (Morrison Riverfront Park) have
recently been reviewed under the SEPA process. 2 The Seattle District of the
COE is in the process of preparing a site specific DEIS on the South Shore
Site to be used as a maintenance dredging material disposal site by the Port
of Grays Harbor. The types of vegetation located at the various sites in table
10 have been previously described (see Smith, Mudd & Messmer, 1976, Maintenance
Dredging and Environment of Grays Harbor, Appendix F: Vegetation).

d. Adverse impacts associated with the loss of this vegetation and
habitat include the reduction of primary productivity, food supply, rearing
and resting areas; decrease in the capacity to reduce erosion, sedimentation
and absorption of pollutants; and impact nutrient cycles (e.g., the sulfur
or carbon cycles).

(1). Loss of eel grass beds and salt marsh represents the greatest
loss in organic production. The loss of salt marsh vegetation may be offset
somewhat by the establishment or reestablishment of salt marsh habitat in the
estuary (through enhancement or in-kind mitigation). Some of the more pro-
ductive marsh areas in Grays Harbor are former dredge disposal sites. These
areas revegetate naturally and point to the probability of successful marsh
establishment. (COE, 1980, Long-Range Maintenance Dredging Program FEISS No. 2)
The wetlands surrounding the estuary, however, do not provide the greatest
amount of carbon which is used by the neritic and epibenthic zooplankton.
Grays Harbor receives high inputs (ca 900 x 10^ kg C/yr) of both particulate
and dissolved organic carbon through the six major rivers and small tributaries
which enter it (R. Thorn, U.S. Army Corps of Engineers, Unpublished). The most
important sources of the Grays Harbor epibenthic and neritic zooplankton
production are allochthonous (from outside the estuary) detrital material (or
carbon sources) eelgrass and epiphytic algae (Simenstad and Eggers, 1981).

(2). Vegetation associated with tidal mudflats include primarily
algal mats, diatoms and organic detritus (decaying vegetation) which are im-
portant to benthic invertebrates and subsequently the rest of the food web.

(3). The relationship between vegetation and estuarine productivi-
ty can perhaps best be illustrated by the schematic diagram shown below in
figure 24.

e. In addition to the acreage shown in table 10, the GHEMP allows
modification of several hundred acres of privately owned lowland forest and
freshwater marshes in MU's 18 and 25 under appropriate permits. This same de-
velopment is allowed currently under the no action alternative. Figure 25 and
table 11 show the vegetation types in MU's 18 and 25 which would be affected
by urban use. Attachment 1, map 8, shows the extent of lowland (freshwater
swamps) forests and freshwater marshes in the Chehalis River study area which
includes MU's 18 and 25. The GHEMP would protect the majority (acreage unknown)

T~. Ocean Shores Airport T"s discussed in FAA, Ocean Shores Airport, FEIS:
Port Slip #1 is discussed in COE, Channel Improvements FEIS, 1982.

2. City of Aberdeen, Morrison Riverfront Park, FEIS, 1983.

3. Nelson, W.H., S. Kalinowski & L. Lynam, 1980, Chehalis River Floodplain
Land Cover Mapping Between Aberdeen and Montesano, Washington, prepared
for U.S. Army Corps of Engineers.

IV-9

IV-10

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ta

o

CO

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IV-11

TABLE 11
Habitat Types in Figure

1. Urban

11 Residential

111 Nonwooded Residential

112 High Density Residential

12 Commercial/Service/Industrial

14 Transportation/Utilities

143 Highway

144 Railroad
146 Bridge

15 Harbor/Port

1531 Log Storage Yard

18 Open Lands

183 Refuse Station

19 Recreational

193 Urban Wooded

3. Nonforested, Vegetated Uplands

332 Riparian Grass

4. Forested Uplands

43 Mixed Forest

431 Regeneration Mixed
434 Second Growth Mixed
46 Forested Riparian

4622 Immature Broadleaf
4632 Immature Mixed

5. Water

51 Rivers/Streams

511 Estuarine
57 Blind Channels

571 Freshwater Blind Channel

6. Aquatic Lands

61 Aquatic Land - Forested
612 Freshwater Swamp

6121 Shrub Swamp

6121/147 Shrub Swamp/Powerline

61223 Second Growth Conifer Swamp

61231 Regeneration Broadleaf Swamp

61232 Immature Broadleaf Swamp

61233 Mature Broadleaf Swamp

61241 Regeneration Mixed Swamp

61242 Pole Stage Mixed Swamp

61243 Second Growth Mixed Swamp

61244 Mature Mixed Swamp

62 Aquatic Lands - Vegetated Nonforested
626 Freshwater Marsh

IV-12

of these types of habitat from major development in MU's 19, 20 and 24. The
potential impact areas (freshwater swamps and freshwater marshes) which are
outlined in figure 22 are adjacent to existing industrial land uses near
Junction City and Cosmopolis.

(1). Excluding urban and agricultural habitats, the Chehalis River
management area is predominantly forested swamp (4822 acres ).3 These lands
are either covered by water or strongly influenced by adjacent waters. Urban
development in MU's 18 and 19 would constitute the loss of approximately 300
acres.

(2). The Chehalis River Basin also contains approximately 244
acres of freshwater marshes.1 MU's 18 and 25 contain approximately half of the
freshwater marshes in the basin. Herbacious vegetation is dominant. Common
types include sedges, grasses, rushes, cattails, reed canary grass, and bull-
rushes. One of the most valuable functions of the marshes is their ability to
moderate extreme highs and lows in streamflows. Overall, there are approximate-
ly 500 acres of freshwater marsh habitat remaining within the boundaries of the
6HEMP. With full implementation of the plan (as well as under the no action
alternative), approximately 2/5ths of that particular habitat could be altered
or destroyed having potentially significant adverse impacts to flora and fauna
species utilizing that habitat.

f. Estuarine Policies and Activities.

(1). Bankline Straightening will alter or destroy natural vegeta-
tion and animal communities in areas where permitted. The major areas where
the policy applies are along the Hoquiam-Aberdeen waterfront (i.e., MU's 15,
16, 17 and under special conditions in MU's 12, 18 and 25). This type of
vegetation varies from low silty marsh types to fresh water marsh types.
Total impact t)f each application of this policy cannot exceed 2 acres. In
most areas where this policy might be applied, existing vegetation has already
been significantly affected by man's activities. Natural processes may re-
establish vegetation on the face of the fill after construction activities,
depending on the materials used for the fill. The policy states (GHEMP, p. 25)
that two or more fills permitted under the policy. may not occur at the same or
a portion of the same site and that use of vegetation for bankline stabilization
is required where technically applicable. These and other limitations apply
in addition to normal requirements for a Section 404 permit. Impacts associated
with implementation of this policy for may be significant locally but were
considered acceptable on an estuary-wide basis given the resource protection
provisions of the plan.

(2). Bankline Erosion policy is more stringent than existing
policy and will therefore produce less adverse impacts. The intent of the
policy is not to destroy existing vegetation which normally acts to buffer
wave attack and erosion processes. In addition, the policy encourages the use
of vegetation for providing bankline stability. The individual and cumulative
impacts associated with implementation are not expected to be significant. The
Task Force considered the Grays Harbor environment in determining where the
activity is permitted vs. conditionally permitted.

"H Nelson, W. H. et. al., 1980, op. cit.

2. C0E, Long-Range Maintenance Dredging Program, FEIS, 1980.

IV-13

(3). Structures. As new or redeveloped structures are completed,
some modification of flora will take place. Structures such as piers, docks and
wharfs will reduce light that supports vegetation. In delineating the structur-
al activities which might have adverse effects on the environment, the Task
Force was careful in their choice of which activities should be considered
permitted in the various MU's vs. those which need to be conditioned and sub-
ject to further review for impact assessment.

(4). Channel. New channel access and channel realignment have
the most significant potential of impacting vegetation, particularly eel grass
beds. Dredging activities to maintain channels generally have little impact
on the algae, eel grass, and marsh communities in Grays Harbor. 2 The greatest
potential impacts would occur in MU's 4 and 39.

g. Agricultural Crops. The plan would have no adverse impacts on
agricultural crops including subsistence and local market farming activities,
tree farming and cultivated crops which are allowed in the Rural and some
Conservancy MU's.

h. The overall assessment on the plan's impacts to the vegetation of
Grays Harbor is that the changes and refinements made in the MU designations,
designation of permitted activities and conditions placed upon different types
of activities within specific areas will provide greater environmental pro-
tection over the long term to the vegetation and habitat types identified than
the no action alternative.

3. Fauna! Resources

a. The impact of the plan on faunal resources of the estuary is
closely correlated with the impact of the plan on flora resources and habitat
types. Out of necessity, the plan is intended to address those activities
which are destructive (e.g., discharges of dredged or fill materials within
containment structures) of existing habitats. Some activities will be less
destructive than others. In areas where development is permitted or where
shoreline and aquatic areas may be modified, the local impact on fauna may be
significant. There may continue to be some loss of habitat and decreases in
the quantity of individual organisms utilizing the estuary. The net loss to
certain species in particular (e.g., those which favor marsh vs. intertidal
habitat) may be minimized by mitigation measures but some loss to other species
is often associated with implementation of such mitigation.

b. Benthic Invertebrate Communities. Recent studies in Grays Harbor
have focused on the impact of dredging operations on infauna (Albright and
Bouthillette, 1982), epibenthos (Albright and Bouthil lette, 1982 & Cordell
and Simenstad, 1981, Simenstad and Eggers, 1981, Armstrong et al . , 1981) and
Dungeness crab (Armstrong et al . , 1981). Food habitat studies have shown the
importance of benthic invertebrates such as Corophium sp. and Anisogammarus sp.,
polychaete worms and others to fish and shorebirds. Any projects or activities
which impact littoral or sublittoral habitat will smother diverse communities
of benthic invertebrates with recolonization likely at the fringes depending on
tidal elevation and substrate. The major project contemplated in this estuary
is the development of MU 12 (Area 2 and Area 4). Since land would be raised

IV-14

above the high water line and utilized for industrial purposes, a permanent
loss of substrate and habitat would result. The major species of concern in
this section of the estuary is the amphipod Corophium sal mom's which serves as
a major prey for shorebirds and fish. A more lengthy discussion on this topic
is presented in appendix C. Implementation of the plan in the rest of the
estuary should not produce significant adverse impacts to the various forms of
benthic and epibenthic invertebrates in the estuary.

c. Fish. Plan adoption would have several impacts on fishery re-
sources. The plan will provide greater protection of the fish passage and
fish base as has been previously discussed. While some impacts would continue
to occur in the urban fish passage area as a result of permitted/conditional
activities, the plan restricts the extent of encroachment into the passage
area. On a long-term basis, this would prove beneficial to the migratory
fishes which make passage up or down the Chehalis River, especially if water
quality continues to improve as it has during the last decade.

(1). Recent studies assessing the impacts of dredging and disposal
operations were conducted by Charles A. Simenstad and Douglas M. Eggers for the
Corps of Engineers.^ The impacts associated with the proposed channel widening
and deepening have been discussed in the recent FEIS on that subject. 2 Habitat
degradation is divided into the major categories of decreased water quality and
loss of feeding and rearing habitat. The Corps concluded that filling Slip No.
1 would not constitute significant impact to fisheries habitat and is not
considered sufficient to warrant habitat mitigation. Bankline straightening
and bankline erosion would produce minor impacts to small segments of littoral
and sublittoral habitat. Direct removal of shallow sublittoral habitat might
have a long term effect on epibenthic feeding juvenile salmonids. According
to Simenstad and Eggers, it would appear that maximum concentration of organisms
such as harpacticoid copepods occur with +/- 1.0 meter of the MLLW tide level,
although important prey taxa may occur in abundance at higher tidal heights.
Thus, removal of shallow sand and mudflat habitat higher than -1.0 meter tide
level, would effectively remove that area from production of salmonid prey
organisms. Simenstad and Eggers believe this could have the greatest impact
on juvenile chum and small chinook salmon in Grays Harbor which tend to
utilize epibenthic organisms to a greater extent than other salmonids and
English sole may be more adversely impacted than the salmon. 3 Further, the
plan provides riparian habitat protection along streams and sloughs used by
the migratory fish where future projects and activities are anticipated.

(2). Other potential impacts include fishery habitat removal and
degradation in MU 12 (Area 2). This area has been previously impacted. However,
implementation of the Area 1 provisions in MU 12 should provide long-term
protection to Moon Island Tideflats, west of the Bowerman Basin, a known major
nursery habitat for English sole.^

d. Avian Fauna. There are many areas in and around the estuary which
are important to shorebirds, waterfowl and terrestrial birds. The plan protects
the majority of bird habitats as shown in table 12. However, there are two
potentially sigificant impacts which can be anticipated. The potential impact
on birds in MU 12 is discussed in appendix C. The other habitat most likely to
be impacted is the freshwater marshes scattered around the estuary and in the
Chehalis River Basin. Table 13 lists the birds which are commonly associated
with freshwater swamps and marsh habitats. Like marine plant communities,

IV-15

TABLE 12

Area

Birds Present

Management Unit Designation
Water Portion Landside

(1) Bowerman Basin

(2) Point New

(3) North Bay and Humptulips
River

(4) Point Damon

(5) Oyehut Wildlife
Recreation Area

dunlin (largest concentration)

western sandpiper

other shorebirds

marsh hawk

peregrine falcon (feeding ova)

short -eared owl

black brant

ruddy turnstone

peregrine falcon (feeding ova)

marsh hawk (feeding ova)

raptors

shorebirds

Bald Eagle

peregrine falcon (feeding ova)

marsh hawk (feeding ova)

waterfowl (largest concentration)

snowy plover (nesting area)
shorebird nesting area
raptor habitat

peregrine falcon (feeding area)
snowy owl (feeding area)

shorebird resting area
raptor habitat

peregrine falcon (feeding area)
marsh hawk (feeding area)
snowy owl (feeding range)

12-N
(Area 1)

44-CM

44-CM

44-CM

44-CM

11-UD
12-UD
(Areas 2-7]

10-RL

7-CM

8-RA

9-RL/N

3-CM
bordered
closely by
2-N
4-UM

2-N

(6) Grass Island and West-
port

7) South Bay and Elk
Ri ver

(8) Redmans Slough at Ocosta

(9) Goose Island

(10) Sand Island

(11) Whitcomb Island

(12) Outer-Harbor Seabird
Feeding Area

shorebird resting area
raptor habitat

shorebird resting area
waterfowl feeding area
short-eared owl (feeding area)
marsh hawk (feeding area)

spring migratory shorebirds
(heavy concentration)
shorebird (resting area)
marsh hawk (feeding area)

western gull (largest colony

on outer coast of Oregon and

Washington)

shorebird (resting area)

waterfowl (resting area)

western gull colony (800 pair)
Caspian tern colony (700 pair)
shorebird (resting area)
waterfowl (resting area)

Caspian tern colony (1200 pair]
shorebird and waterfowl rest-
ing area

common murres
rhinocerous auklets

44-CM

44-CM

44-CM

14-CM
special

41-N

42-CN

44-CM

37-UM/CN

38-UM/CN

39-UM

34-CM/N
35-UM

30-

• RL

31-

-RA

32-

■RL

14-

•CM

spec

:ial

41-N

42-CN

IV-16

freshwater marshes are naturally fertile systems. A large number of birds and
wildlife species utilize the marshes. Some live almost exclusively in marshes,
while other are dependent on marshes to varying degrees.1 While substantial
impacts would occur to freshwater marshes, the plan protects the remaining
habitat. Any future amendments to the plan should carefully weigh the impor-
tance of the remaining freshwater marshes to the total ecosystem diversity of
Grays Harbor.

table 13

Birds Commonly Associated With Freshwater Shrub Swamp

or Marsh Habitats

pied-billed grebe (Podilymbus podi ceps)

great blue heron (Ardea herodias)

green heron ( Butorides vires cens )

green-winged teal (Anas carolinensi s)

wood duck (Aix sportsa)

ring-necked duck (Aythya collaris)

hooded merganser (Lophodytes cucull at us )

sharp-shinned hawk (Accipiter striatus)

Cooper's hawk (Acci piter cooperii )

Virginia rail (Rail us limicola)

sora ( P or z an a Carolina)

rufous hummingbird (Selas phorus rufus)

downy woodpecker (Dendrocopos pubes cens )

willow flycatcher (Empidonax~traillii)

tree swallow (iri doprocne bicolor)

rough-winged swallow (Stelgi dopter yx ruficollis)

barn swallow (Hirundo rustica)

Steller's jay (Cyanocitta stelleri)

common crow (Corvus brachyrhynchos )

black-capped chickadee (Par us at ri capil lus)

common bushtit (Ps al tripar us minimus)

Bewick' s wren (Thr yomanes bewickii)

long-billed marsh wren (Telmatodytes pal ustris )

robin (Turdus migr at ori us)

Swainson's thrush (Hylocichl a ustulatus)

ruby-crowned kinglet (Regulus calendula)

cedar waxwing (Bombyc ilia cedrorun)

Hutton's vireo (Vireo huttoni)

warbling vireo (Vireo gilvus)

yellow warbler (Dendroi ca petechia)

yell ow-r unped warbler (Dendroica coronata )

MacGil 1 ivray ' s warbler (Oporornis tolmiei)

yellowthroat (Geothyl pis trichas)

red-winged blackbird (Agelaius phoeniceus)

brown-headed cowbird (Molothrus ater )

black-headed grosbeak (Pheucti cus melanocephalus)

Lincoln's sparrow (Melospiza lincolnii)

song sparrow (Melos pi za melodia)

Source: Nelson, W.H., Kalinowski, S., & L. Lynam, Chehalis River Floodplain
Land Cover Happing Between Aberdeen and "ontesan Washington, prepared
for U.S. Army Corps of Engineers, January 1980

IV-17

In addition, construction and use of the Ocean Shores Airport will not destmv
thfM^ant,fh0:eblr^habitat d1rect1*> but mW Provide PadditTonal stress ?o
land^Sf anWdhloCverfl^t2s. ^ ",t'Pn S6Ct1°n °f N°rth Ba* due to "SJfS

e. Mammals. Table 14 identifies the mammals which may be imDacted hv
various future activities permitted by the plan. The table shows that rioari an
areas-wooded swamp habitat have the greatest diversity of species. Host of this
habitat is protected in the plan from extensive use and alterations Host
mamma s are highly mobile and utilize a diversity of habitats The smaUer
mammals (moles, voles and shrews) may be most adversely Impacted due to oss of
habitat which in turn can affect the abundance of other predators.

(ltr ^td^^v^a SiPo«ne?- BT°hth th? National Har1ne "Series Service
Utr. dtd. July 14, 1980 from Thomas E. Kruse, Acting Regional (Northwestl

ntt °/J\Dr- K°be^ R' Kifer' 0CRM> and the u-s- Fish « Wildlife Servici

N Fhlprd-nrpMCfmhber "' ?8l'JBr" Joseph R' Blum' Area Onager to Char es
N. Ehler, OCRH) have provided OCRH with assessments which conclude that imo e-

TrlT°\°f the GHE^P ,is not 11ke1* t0 Jeopardize any known endangered or
threatened species. Earlier drafts of GHEHP led to formal Section 7 consulta-
tion based on concern over the potential impacts to the American peregrine
I «M»(anJ °^er Dpere9r1ne subspecies). The GHEHP was modified to project chl
majority of the Bowerman Basin considered as significant shorebird habitat
which provides the migratory falcons with an abundant prey base. Should a

f rmon1toHnaaf ill beHmad\b* Jhe FSWS based upon new' information derived
from monitoring fill and construction activities in HU 12, the F&WS may recom-
mend reinitiation of formal Section 7 consultation. Rein ti ati on of Section 7
consultation is the responsibility of the action agency. For more information
on Section 7 consultation see appendix C. inrormation

IV-18

TABLE 14. Mamma1s Found in Six Grays Harbor Habitats. 1975

Species

Habitats

^_

f— in

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IX.

Opossum (Didelephis marsupialis)

X

X

Masked shrew (Sorex Cinereus)

X

Dusky shrew (Sorex obscurus)

X

Vagrant shrew (Sorex vagrans)

X

X

X

X

Trowbridge shrew (Sorex Trowbridgii)

X

X

Water shrew (Sorex palustris)

X
X

X

Marsh shrew (Sorex bendirii

x

Shrew-mole (Neurotrichus gibbsii)

i

X

Townsend mole (Scapanus Townsendii)

1

X

X
X

X

Coast mole (Sea

panus orarius)

Snowshoe hare (

Lepus americanus)

Mountain Beaver

(Aplodontia rufa)

Townsend chipmunk (Eutamias townsendii)

X

Douglas squirrel (Chickaree)

(Tamiasciurus douglasii)
Northern flying squirrel

X

(Glaucomys sabrinus)

X

Mazama pocket gopher

(Thomomys mazama)

X

X

Beaver (Castor canadensis)

X

X

Deer Mouse. (Peromscus

maniculatus)

X

X

X

Bushy-tailed woodrat

(Neotoma cinerea)

X

Capper red-backed mouse

(Clethrionomys gapperi)

:!

X

Townsend vole (Microtus

townsendii )

X

X

X

X

Oregon vole (Microtus oregoni )

X

X

X

Longtail vole (Microtus

longlcaudus)

X

X

X

Muskrat (Ondatra zibethica)

X

X

X

X

Pacific jumping mouse (Zapus

X

X

trinotatus)

X

X

Porcupine (Erethizon dorsatum)

X

Nutria (Myocastor coypus)

X

X

Harbor porpoise (Phocaena

vomerina)

X

Killer whale (Orcinus orea

X

Gray whale (Eschrichtius

glaucus)

X

Red fox (Vulpes fulva)
Coyote (Canis latrans)

X

X

X

X

X

X

X

X

Black bear (Ursus

americanus)

X

X

X

X

Raccoon (Procyon lotor)

X

X

X

X

X

Mink (Mustela vison)

X

X

X

X

Longtail weasel (Mustela

frenata)

X

X

X

X

Shor'tail weasel (Mustela

erminea)

Striped skunk (Mephitis

mephitis)

X

X

X

Spotted skunk (Spilogale

putorius)

X

X

X

River oiler (Lutra

canadensis)

X

X

X

Mountain lion (Felix

concolor)

X

X

X

Bobcat (Lynx rufus

X

X

X

Steller sea lion (Eumeto-

piasjubata)

X

Harbor seal (Phoca

vitulina richardi)

X

X

Roosevelt elk (Cervus

canadensis roosevelti)

X

X

X

X

Blacktail deer (Odocoileus

hemionus col umbi anus)

— — — — » '

X

X

X

X

X

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CO

IV-19

D. ELEMENTS OF THE HUMAN ENVIRONMENT

1. Population and Economy. Since the plan only addresses a portion of
the entire settlement region, it does not and cannot determine in itself popu-
lation levels to be obtained. However, the estuary is the focus of economic
activity of the region. Since population at a regional level tends to follow
employment, the provisions of the plan should influence ultimate population
levels. The plan appears to have one main potential influence on population
growth. The provision of the plan which permits further industrial expansion
(in MU 12) would increase the basic economic opportunity in the region. In
terms of accepted planning design standard, 500 acres of industrial land can be
expected to provide up to 3,000 jobs.* The potential pressure that this number
of jobs would place on the region is not expected to be great because of high
unemployment. Development in MU 12 is specifically designed to permit adequate
space for economic diversification (i.e., something other than activities
associated with forest products) to minimize the adverse impacts to the region
when the forest products industry is in a slump. As was pointed out in Part III,
Grays Harbor County's unemployment rate is substantially higher than the State
average. In addition, having improved airports at Westport and Ocean Shores
may provide a stimulus to the tourist and fishing industries, resulting in
increased employment and possible population growth.

2. Housing. The proposed plan will reduce the potential area which could
be utilized for high density housing developments by effectively discouraging
and/or limiting the use of shoreline areas for housing. The plan would tend to
divert pressure for new housing from shorelines to upland areas. The plan does
recognize existing residential development areas in MU's 5, 21, 33, 35 and 37.

3. Transportati on/Ci rcul ati on . With the exception of water transporta-
tion and airport siting, the plan does not adversely affect transportation,
although indirect effects might be noted along with the plan's impact on
water and air transportation.

a. Vehicular Traffic Generation. If the plan were implemented there
would be several nodes of increased traffic generation. In most of these
situations the actual impact will depend on the particular uses involved. The
specific areas include: the Westport Marina (MU 39), Ocean Shores Airport
(MU 6), Bowerman Field (MU 12), Morrison Park (MU 17), Junction City (MU 18),
Cosmopolis industrial growth area (MU 25) and the south shore area west of
South Aberdeen (MU 26).

b. Parking Facilities. Parking is not addressed in the plan itself
since parking needs for any development permitted in this plan are addressed in
the affected zoning ordinances.

c. Transportation Systems. The plan would tend to strengthen the
balanced transportation system of the region by providing for the needed devel-
opment and maintenance of the port facilities, and by providing for the devel-
opment (or improvements) of two existing airports. However, the plan could
affect the relocation of Bowerman Field and consequently the regional trans-
portation system.

DeChiara, J. and Koppleman, L., Planning Design Criteria, Van Nostrand,
Reinhold Co., NY 1969, p. 247

IV-20

d. Movement of People and Goods. The development of the port and
airports would facilitate the movement of people and goods, although a require-
ment to relocate Bowerman Airfield could impair that movement.

e. Waterborne, Rail and Air Traffic. The plan will facilitate
waterborne commerce and increase the opportunity for water-dependent industrial
use to locate along the Federal Navigation Channel. This includes all the
navigation appurtenances including T-docks, piers, etc. A new rail -loop spur
would be required for industrial needs in MU 12, Area 2. The plan is rather
restrictive with respect to the conditions which allow airports in the aquatic
areas. In the absence of the plan, both the capacities and alignments of the
airports might be modified to allow greater development.

f. Traffic Hazards. The plan is not expected to add new traffic
hazards, but will make improvements to the Westport and Ocean Shores airport
landing facilities. Relocating Bowerman Airport north may increase landing
hazards because of its nearness to large shorebird populations and new
industrial sites but would have to meet FAA safety regulation standards prior
to relocation. The plan considered the improvement to a hazardous highway
section in MU 11 and permits bankline erosion control measures to protect
highway and railway structures and facilities.

4. Public Services. No unusual or significant impacts are anticipated.
Some increase in fire protection for the Bowerman Field area, Junction City
South Shore and Cosmopolis would be required if industrial development occurs.
By promoting an orderly development pattern, the plan makes it possible to
deliver public services to new development more efficiently. This holds true
for police protection, parks and recreational facilities and other services.

5. Energy. The plan will not have a direct impact on energy supplies
and services, although increased development may lead to an increase in the
amount of energy needed. However, such increases would be consistent with the
requirements of the general population base. The source of any such energy
would be from the existing service pattern.

6. Utilities.

a. Energy. The energy utilities of the region are either adequate
now or can be readily developed to serve all envisioned development.

b. Communication. Communication services are either adequate now
or can be readily developed to serve the facilities envisioned.

c. Water. Adequate water capacity is generally available to serve
the envisioned demand and lines can be readily developed to serve most of the
potential sites. Surplus industrial water is available.

d. Sewer. With the completion of sewer system projects under way
or planned, sewer service should be adequate to serve most of the development
envisioned in the plan. However, additional facilities may be needed depend-
ing on the types of industry which might be developed within the plan. Some
industries often provide their own water treatment facilities. Such require-
ments can only be determined when specific uses are proposed. Sewer hook-ups
would be required to the newly developed lands.

IV-21

e. Storm Water. The plan would increase storm water runoff in tho\se
areas where wetlands are filled and utilized for industrial purposes or urban
waterfront redevelopment (e.g., from paved parking lots, airport runways, docKs
or buildings). Storm water, if not collected, will flow into the estuary with
potential long-term implications to the degradation of estuarine waters, wet-
lands and wildlife. The severity of the impact will be a function of the type
of land use, volume of discharge and management practices which cannot be
determined at this time.

f. Solid Waste. The plan does not generally permit the disposal of
wood waste or other solid waste material in shoreline areas (as defined by the
SMA). Wood waste may however, be utilized as fill material (in combination
with other fill material) to create upland development consistent with the
plan, if appropriate permits are obtained.

7. Human Health

The plan has no direct impact itself on human health concerns with
the exception of concerns over protecting water quality and water storage
areas of the Chehalis River floodplain.

8. Noise

The plan generally maintains the present situation related to noise
concerns. Urban development and related noises would generally be directed to
existing urban areas. The major change in the pattern would be:

o industrial uses in the Bowerman Field area (impacts would depend
on particular uses),

o the relocation of Bowerman Airport would reorient related noises,

o relocation of Ocean Shores Airport would reorient and increase
noises towards shoreline residential units and into North Bay, and

o development of Westport Airport would lead to increased air noises.

9. Light and Glare

The potential impact of the plan itself on light and glare concern
would be minimal. The major potential concerns would be an increase in traffic
and activity with industrial development at MU 12 and the features of that
concern would depend on the characteristics of the particular uses. The impact
of other development opportunities provided in the plan would be largely simi-
lar to existing conditions.

10. Land Use

The proposed plan tends to largely reinforce existing land use pat-
terns while providing for a limited expansion of various urban uses in an
orderly fashion by directing new development to areas adjacent to development
areas. Although the most significant land use change would be the potential
to develop MU 12, the most significant overall impact of the plan on land use
patterns is substantially to reduce the opportunity to develop various areas
intensely. This will conserve undeveloped areas.

IV-22

11. Risk of Explosion or Hazardous Emission. While the plan itself does
not affect this concern, it is possible that some use permitted under the plan
could lead to an increase risk of explosion or hazardous emission. Such a
situation cannot be now foreseen and therefore is outside the scope of this
assessment.

12. Natural Resources

a. Rate of use. The plan will substantially reduce the historical
rate of converting aquatic habitats to non-aquatic areas and would limit the
conversion of such areas. The plan generally in itself does not affect the
rate of use of other resources (fishing, hunting, aquaculture).

b. Continued use of resources. GHEMP attempts to allow the current
and future uses of natural resources through its multi-purpose use goal, while
at the same time attempting to minimize the conflicts between resource users.
No habitat is eliminated or resource use denied on an estuary-wide basis (see
Planning Area Guidelines - Management of the Natural Resources, GHEMP pp. 29-47).
Use of the water surface for log rafting may eventually be eliminated if need
and use by the lumber industry no longer warrants it. The intent of the log
rafting policy is to restrict rafting to areas where grounding does not occur.
Dredged material may continue to be used as a resource for fill material. The
plan also permits continued extraction of gravel resources from the system.

13. Aesthetics and Recreation. In general, the plan will protect and
conserve the overall aesthetic quality of the estuary through the implementa-
tion of management unit designations which provide for low intensity uses. The
plan is expected to assist in reducing urban blight by facilitating the redevel-
opment of the urban waterfront. By clarifying the appropriateness of commercial
uses of the Aberdeen waterfront, increased public access is expected to be
provided by the private sector. The plan also specifically encourages the
expansion of public access and proposes some public facilities to implement
that objective such as the Aberdeen Park in MU 17. It would permit future
proposals for boat launching ramps and is permissive with respect to recreational
fishing, hunting and resource utilization. The aesthetic quality of the Bower-
man Basin will be decreased through fill and development. At present, the site
offers one of the most accessible estuarine view points available in the urban
area. The proposed development of the area would reduce that opportunity.

14. Historical and Archeological . The proposals embodied in the plan
propose no known significant adverse impact on recognized historical and archeo-
logical resources. Two historic sites listed in the National Register of
Historic Places (Hoquiam's Castle, and the Light Station west of Westport)
are all outside the plan's boundary. The SIERRA, a wrecked ship is located
near the south shore of the City of Aberdeen in MU 44. The plan will affect
the ship nor its historic significance. There are ten known archeological
sites located within the boundary area. The sites are shell middens and are
close to the water. The majority of these sites are located along the South
Bay shoreline where major development is not permitted. Two potential conflict
areas are located along MU's 38 and 39 in Westport and along MU's 4 and 5 near
the Ocean Shore Marina. Expansion of the Westport marina could have impacts
on a shell midden area. Since the Ocean Shores MU's recognize only existing
uses, there is no practicable alternative to their designation. Future con-
struction activities would be required to comply with archeological preserva-
tion requirements prior to permit approval. Figure 26 shows the sites which
have been identified by the Washington State Historic Preservation Officer
(J.M. Welch, personal communication, 3/79).

IV-23

J

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CD

IV-24

E. IMPACT EVALUATION OF PLANNING ALTERNATIVES

1. The planning options of choice identified in Part II include:

o No Action (or No GHEMP)

o GHEMP

o Less Development (including the Citizen's Estuary Plan)

o Greater Development

o Dispersing Development

o Concentrating Development

2. The impact matrix shown below (see figure 27) was developed to broadly
summarize the natural, social and economic impacts which may be associated
with the various management alternatives. Because of its simple design to
convey general development/preservation concepts related to comprehensive plan-
ning, it cannot be used for site specific decisionmaking. Rather, it compares
the general magnitude of various impacts associated with the different plan
alternatives. The GHEMP alternative was used as a baseline on which to judge
the other alternatives because of its specificity from which other actions
can be evaluated. Impacts are related mainly to the amount and location of
potential wetlands fill and shoreline alterations. Figures 28 through 32
generally show where major new industrial /commercial development (both water-
dependent and water-related since not all can be located next to the navigation
channel) might be located (based upon flat land requirements, allowed or con-
ditionally allowed by existing zoning, etc.) within and around the estuary.

3. Naturally, there is a degree of uncertainty associated with each
scenario, but this assessment assumes that development could occur during a
long-term period (20 - 50+ years). It does not consider the potential itera-
tions of shoreline development associated with residential development which
might be allowed in relatively undeveloped areas such as North and South Bays
and along the South Shore. Also, it does not count those shoreline/wetland
areas which have previously been filled under the existing local SMP process
(i.e., Kaiser fill site (45 acres), Port Slip #2 (70 acres), South Shore dredged
material disposal site (179 acres)). These areas will eventually be developed
for industrial purposes. While they are important in determining need and
alternatives to fill, they will not be considered in the impact analysis of
potential future actions. Therefore, the following estimates of acreage (see
below) which might be altered over a long-term basis if a demand for space
existed are used in the figure 27 assessment.

Estimated
Acres of Altered Shore! ine/Wetands

o NO ACTION 1 ,000 +

o GHEMP 700

o LESS DEVELOPMENT 250

o GREATER DEVELOPMENT 2,000 +

o DISPERSED DEVELOPMENT 1,000 +

o CONCENTRATED DEVELOPMENT 700 +

IV-2 5

FIGURE 2 7
SUMMARY OF NATURAL, SOCIAL AND ECONOMIC IMPACTS OF PLANNING ALTERNATIVES

N. RESOURCE

i/
a

CO

\ IMPACTS

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ALTERNATIVES \

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1 No Action

4

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4

4

3

3

3

3

4

4

44

GHEMP
1 Less Devel opment *

I2

2

3

3

3

3

2

2

2

2

3

3

30

[l

1

2

2

2

2

5

6

6

4

2

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35

1 Greater Development

I6

6

6

6

6

6

1

1

1

1

6

6

52

1 Disperse Development

I5

3

1

5

5

5

4 1 5

4

5

1

1

44

1 Concentrate Develop.

|3

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5

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6 J 4

5

6

5

5

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42

Potenti

al Ai

Iver

se Impacts

1 = Least 2 = SI ig

ht 3 = Mode

rate

4

= Substantial 5

= Heavy

6 ■

= Most:

* Includes the Citizen's Estuary Management Plan

NOTE

The numbers assigned represent a measure of the degree of potential adverse
impacts to the resources identified. The resource categories indicate some of
the more significant factors which have been considered by the Task Force
members and take into account both the natural environment and the social and
economic environment. All actions which include fill and shoreline development
will have some degree of impact so zero (0) was not used. Adverse impacts are
considered in both a positive and negative
amount of shoreline alterations permitted
least adverse natural resource impacts, but
adverse impacts to the long-term economy of
are necessarily subjective to a degree and in addition to considering the
amount of shoreline and wetlands altered along with their subsequent impacts,
reflect a philosophy of the planning alternatives. While it may be argued
that one factor is more important than another and therefore should be weighted
to reflect that importance, all factors are given equal consideration for
purposes of this assessment.

sense. That is to say, the least
by an alternative will have the
can potentially have the greatest
the region. The numbers assigned

IV-2 6

IV-2 7

ill

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Figure 2 9

GHEMP Alternative

i 811

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IV-28

IV-2 9

IV- 30

IV-31

IV-3 2

4. Evaluation

a. Shoreline Alterations. The largest amount of shoreline alterations
is associated with greater development and dispersed development. If an effort
is made to utilize flat land for industrial /commercial purposes, requiring few
wetlands alterations, development would have to move away from the central
urbanized areas but still have access to transportation (rail, highway and
air cargo). Because the development would be removed from the navigation
channel, it would likely have to be water related uses (rather than water-
dependent) unless new navigation channels were developed and maintained such as
the South Channel. Less development has the fewest potential alterations. The
no action alternative is considered to be more permissive than GHEMP and there
would be greater fill towards the navigation channel, which is also likely
under the concentration alternative.

b. Wetlands. Wetlands alterations are similar to the above impacts
associated with shoreline alterations with the exception of dispersed develop-
ment and concentrated development. Dispersed development would require con-
siderable shoreline alterations, but many development sites would be located on
uplands beyond the line of aquatic vegetation. Concentrating development
would be more costly to intertidal wetlands.

c. Fisheries. Three alternatives (no action, greater and concen-
trating development) would most adversely impact the fish passage. The least
impacts would be associated with dispersing development away from the inner
harbor and major fishery habitats. GHEMP protects the fish passage but could
have adverse impacts on some English sole nursery habitat in MU 12. Less
development would protect more acreage of wetlands but under Phase III (250-acre
fill) might permit development in MU 12 along the navigation channel which
could also affect fishery habitat.

d. Avian Fauna. Greater development would clearly have the most
significant adverse impacts with concentrating development in the inner harbor
having the least. GHEMP would have moderate impacts with less development
having slight to moderate impacts during Phase III development. No action
and dispersed development would have moderate to heavy impacts.

e. Other Fauna. Oniy two alternatives (greater and dispersed devel-
opment) have the potential for significantly affecting other wildlife resources
because of their encroachment into relatively undisturbed areas.

f. Open Space and Aesthetics. Concentrating development would theo-
retically retain the most open space and have the greatest aesthetic appeal
to larger parts of the estuary. Less development includes development of 250
acres along the navigation channel which would have some adverse impacts to
the aesthetic appeal of the Bowerman Basin. Similar adverse impacts would
occur under GHEMP, with greater impacts in Bowerman, Westport and Ocean Shores.
The most significant impacts would be associated with shifting development into
the rural areas of the harbor and include all 2200 acres of the MU 12 under
greater development.

IV-33

g. Recreation and Cultural Opportunities. Greater development pro-
vides the most opportunity to increase recreational and cultural activities in
and along the estuary. Larger waterfront parks, marinas, recreational support
facilities (motels, restaurants, mobile home parks), viewing shipping and
milling activities, etc., could be provided in greater abundance even though
aesthetic appeal and faunal distribution would be diminished. Both less devel-
opment and concentrating development would have more adverse (social /economic)
impacts, as they would basically not allow any further expansion of marinas
into existing wetlands and limit developments in the Westport and Ocean Shores
areas, which have the largest concentrations of visitor use.

h. Economic Growth and Employment. The greater development alterna-
tive can clearly provide the most opportunity for growth in and around the
estuary. This alternative puts fewer constraints on development if the need
can be demonstrated. Conversely, the less development alternative permitting
only 250 acres of new development in the aquatic area and any further attempts
to expand existing facilities would have the most adverse impacts on economic
development opportunity.

i. Transportation Systems. The less development alternative would
have the most adverse (socio/economic) impacts on proposed or future transpor-
tation systems including marinas, airports and on improvements to highways,
bridges and railroads. GHEMP has slightly fewer adverse impacts than the no
action alternative because it accommodates the Bowerman Airfield relocation at
least cost, which the no action alternative might not be able to do.

j. Urban Waterfront Revital ization. Less development would have the
most adverse impacts, as it rejects the use of the shoreline for non-water
dependent activities. Likewise, concentrating development requires the reser-
vation of the shoreline space for water-dependent industrial purposes related
to the navigation channel and the region's economy, thereby making waterfront
revitalization more difficult. GHEMP policies and plan provisions specifically
take urban waterfront revitalization into account by allowing new industrial
development along the navigation channel and revitalization in the older urban
areas.

k. Air and Water Quality. Impacts to air and water resources are
similiar for the development alternatives. Dispersing development would most
likely have fewer air and water quality impacts because of dilution and
dispersal factors, although infrastructure costs would be higher. This assumes
that any activity or use will meet State air and water quality standards.
Greater development and concentrating development more would place the most
stress on the estuary air and water resources.

5. Conclusions.

a. The total scores have no particular meaning in and of themselves
other than to provide a ranking; however, they can perhaps collectively repre-
sent a meaningful evaluation for purposes of a broader level of decisionmaking.
There are twelve resource areas. When the total scores are added up and divided
by twelve, the overall effects of the various plan alternatives range from
slight to substantial. The mean scores include:

IV-34

ALTERNATIVE

MEAN SCORE

OVERALL IMPACT

o GHEMP

2.5

Slight

o Less Development

2.9

Slight

o Concentrate Development

3.5

Moderate

o No Action

3.6

Moderate

o Disperse Development

3.6

Moderate

o Greater Development

4.3

Substantial

Taken from an estuary-wide, long-term/multiple use planning and management
framework, this assessment might very well demonstrate the overall impact
between the options of choice. This does not imply that any one individual
action will not have a major and significant impact on the human environment.

b. In a simplified way, the conclusions of the matrix demonstrate:

(>). GHEMP, based on joint collaborative planning and including
compromises between economic development and environmental protection, has the
least overall adverse impact. It is neither the best solution to protect the
estuarine environment, nor is it the best for economic development potential.
It does, however, strike a balance which gives it the lowest overall adverse
impact score.

(2). Less development clearly provides the least adverse impacts
to the natural resources of the estuary but has the greatest adverse impacts
to the future economy of the region by limiting growth potential. It neverthe-
less ranks a close second. If the Task Force makes a determination that the
less development alternative (specifically the Citizens Management Plan alter-
native) can satisfy the future social and economic needs of the region after
comments are received from the public (and therefore confirms the viability of
the alternative), then the less development alternative would be the preferred
alternative.

(3). The third best alternative is to concentrate development,
(a similar concept is embodied in the GHEMP), but this would require greater
industrial utilization of the urban waterfront along the navigation channel.
This would impact the migratory fishery resources and still may not provide
enough space for the requirements of new industrial users.

(4). The fourth best alternative would be to take no action. The
existing local SMP's are rather broad and more permissive than GHEMP. Over
time, it is possible and likely that development interests will obtain permits
on a case-by-case basis under existing and amended local SMP's.

(5). Dispersing development would require substantial shoreline
alterations into rural areas but not necessarily require wetlands alterations
unless a navigation channel were to be developed and maintained. Industry
(light/heavy) or commercial developments locating along the shoreline would
be less dependent on water access but would have flat land and relatively good
transportation services available.

(6). The greater development alternative is almost the opposite
image of the less development alternative, having the most adverse impacts on
natural resources yet providing the greatest opportunity to all types of devel-
opment proposals.

IV-35

F. CUMULATIVE IMPACTS

One of the major purposes behind the development of the GHEMP is to prepare
a comprehensive plan which can be used as a baseline by all jurisdictions in
determining the cumulative effects of incremental fill and development proposals
in the estuary. This section provides a general overview of the combined effect
the various uses will have on the environment.

1. Figure 3 4 shows the total extent of shoreline development (including
uplands within the study area) and wetlands alterations under GHEMP. This
includes both existing uses and proposed allowable future uses. Approximately
one-third of the shoreline (32.5 percent) is currently devoted or will be to
"development" type environments and two-thirds (67.5 percent) will be preserved

type environments. Ninety-nine percent of the bay waters

in

"conservancy"

will be designated in Conservancy or Natural environments,

2. Figure 3 5 shows a comprehensive picture of the Management Unit desig-
nations. This, together with the Standard Use Matrix and the Permitted Activites
Matrix, present the best picture of what the potential developments in the estu-
ary will be.

3. The Permitted Activities Matrix (figure 36) shows the types of activi-
ties which will be permitted, conditionally permitted, or which will require
special conditions to meet special environmental concerns if they are to be
allowed. Special project fills, which will have the greatest potential for
adverse cumulative impacts, may occur as a special condition activity in MU's
6 (Westport Airport); 12 (Bowerman Industrial Complex and Airport relocation);
14 (Hoquiam industrial expansion - 20 acres - and "T" dock filling); 15 (fills
for navigation structures); 18 (fills for navigation structures); 24 (fills
associated with road construction); 25 (road, flood control project and other
urban activities); 26 (industrial structures and urban development); 38 (West-
port Airport); 39 (Westport Marina) and 44 (water-dependent uses).

4. Figure 37 shows the types of the wetlands which would be impacted by
the major development projects if all sites are developed under the plan.
Impacted wetlands would include:

Estuary's

Wetland Type

Approx.

Acres Filled

Total Acres

Percent of Total

Freshwater marsh

110

250*

44.0

Low silty marsh

50

1,620

3.0

Low sandy marsh

48

650

7.4

High immature man

;h

30

240

12.5

High mature marsh

15-18

1,030

1.7

Sedge marsh

Unknown

152

Diked salt marsh

Unknown

1,090

Eel grass beds

100

11,000+

1.0

Tideflats

350

28,160

1.2

Wooded swamp

Unknown

940

Does not include freshwater marshes along the Chehalis River.

IV-36

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IV-40

5. Approximately 3850 acres of aquatic habitat have been used for dredged
material disposal or fill activities in Grays Harbor from 1940-1975 (Smith,
Mudd and Messmer, 1975). Since then, an additional 69 acres have been filled
(source: COE). This brings the total estimated acreage filled or impacted by
deposits or filled material to 3920 acres. Implementation of the GHEMP over a
long-term period will allow an additional 700 acres of fill. From what can be
anticipated at this time, this would bring the total acres used for dredged
material disposal and/or fill to approximately 4620 acres. Subtidal habitat
will continue to be modified due to maintenance of the navigation channel.

6. The most significant changes to intertidal aquatic areas would occur in
MU 12 which would allow confined dredged material disposal for fill to permit
water dependent industrial development along the North Channel. The plan is
designed to accommodate from 164 acres up to 500 acres over a long term period
if adverse impacts to peregrine falcons and the shorebird community can be
minimized. Filling Area 2 and possibly Area 4 represents the termination of
further westward expansion towards the outer harbor once the 1700 acres in Area
1 are turned over to the Department of Game.

7. Further westward industrial expansion along the south shore in
MU 26 stops at Chapin Creek, with minor structures permitted over the marshes
adjacent to the MU to allow access to the navigation channel. Filling 98 acres
of freshwater marsh will eliminate a significant amount of the freshwater habitat
along the south shoreline of MU 26.

8. In North Bay the very extensive intertidal mudflats will not be dis-
turbed. The western marsh near Ocean Shores will be impacted once a small
airport is developed. The majority of the marsh will be permanently preserved
and protected from residential development. The introduction of the airport
represents a potentially significant conflict with shorebird use of the
adjacent tideflats in North Bay. This will be the major development along
with the existing Ocean Shores Marina (with potential channel maintenance)
along the west side of North Bay. Much of the residential housing along the
shoreline has already been developed.

9. South Bay will remain relatively undisturbed, with eventual expan-
sion of the Westport Marina into the adjacent wetlands being the major develop-
ment. It is probable that some of the diked saltmarsh habitat will be restored
as undiked saltmarsh through mitigation efforts.

10. The shoreline adjacent to South Aberdeen, Cosmopolis and Junction City
will continue to be modified having potential adverse effects on the migratory
fish passage.

11. On a long-term, comprehensive basis, there is nothing to indicate that
overall species diversity will be diminished by the proposed action. There will
be adverse impacts to wintering and migratory shorebirds through the loss of
feeding and roosting sites in the harbor and possibly other factors (land and
water use activities) causing stress. However, those impacts cannot be quanti-
tatively assessed at this time without further monitoring (pre/during/post
activities). At this point, it is not believed that impacts are "unacceptable"
even though any adverse impact is deemed "undesirable." Should future informa-
tion concerning the shorebirds (main prey of the peregrine falcon) show unac-
ceptable impacts, formal Section 7 consultation would be reinitiated and revis-
ions to the plan may be required. The mitigation measures are intended to
ensure to the maximum extent practicable the long-term usability of the Bowerman
Basin to the avian fauna.

IV-41

G. RELATIONSHIP BETWEEN SHORT-TERM USES OF MAN'S ENVIRONMENT AND THE
MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY

1. The proposed GHEMP represents an effort to coordinate policy and manage-
ment regulations pertaining to the estuary. Implementation of the proposed
plan through amendments to existing SMP's will result in the modification of
policies and regulations presently existing, rather than in the initiation of
new regulation in an area previously unmanaged. As indicated elsewhere in this
document, the State SMA recognizes (in areas designated as shorelines of state-
wide significance) the importance of giving proper consideration to uses which
emphasize long-term over short-term benefits. The proposed plan is consistent
with this policy. It will allow some short-term uses of the environment, while
at the same time protect the long-term productivity of the natural system's
resources for the benefit of future generations.

2. In some instances designation of lands and water for high-intensity
uses under the plan may result in both short and long-term economic gain,
while designation for conservation or preservation may result in foregone
economic opportunities. Since the estuary is presently under the management
control of local SMP's and other environmental regulations, these assumed land
value changes may actually represent a shift of values within the estuary (i.e.,
industrial development in MU 12 vs. the fish passage) rather than an economic
loss or gain for the total estuary area. Without the plan, there may be a
loss of both economic and environmental values.

3. Another short-term use effect of the proposed plan is the designation
of specific areas for particular agreed-upon projects. While these projects
will result in diminished environmental quality at the specific sites, special
conditions have been included within the plan to assure that degradation is
minimized. Also, marsh creation and marsh restoration projects are included
within the proposed plan under some areas (i.e., MU 12, MU 43) and will act to
restore areas previously degraded, potentially resulting in the long-term
enhancement of the estuary. The major projects with their gains and losses
include:

a. Management Unit 12 - Bowerman Basin

(1). Gains. The creation of long-term industrial site in the
most appropriate area for urban services. Increased employment opportunity,
governmental revenue and enhanced economic viability. Also, potential increased
capacity for dredge material disposal (estimated at a savings of $12,000,000
over alternative disposal methods). Decreased costs associated with airport
relocation. Permanent protection of 1700 acres of valuable fisheries and
shorebird/raptor habitat.

(2). Losses. Up to 500 acres of aquatic habitat impacting the
food webs of both avian fauna and fishery resources.

IV-42

b. Modification of Port Slip No. 1

(1). Gains. Improved capacity for cargo exports with related
gains in regional employment and income. No future maintenance dredging needed
to keep slip operational.

(2). Losses. A 20-acre reduction in sub- and intertidal area
which has already been highly modified, some reduction in food production for
fish, and a minor modification of the migratory fish route.

c. Westport Boat Basin

(1). Gains. A substantial increase in the opportunity for boat
moorage with related increased opportunity for recreation and commercial fish-
ing.

(2). Losses. Eliminate 48 acres of marsh and subtidal area, with
related losses in primary productivity and food production for fish, and
possibly slight reduction in water quality in the immediate vicinity of the
basin.

d. Westport Ai rport

(1). Gains. Substantial improved air safety for existing uses.
Potential for attraction of greater tourism with resulting gains in income and
employment.

(2). Losses. Reduction of high marsh land (already impacted by
existing airport use) with related losses in biological productivity.

e. Ocean Shores Airport

(1). Gains. Improved and safer airport for the Ocean Shores
community. Permanent protection of 200 acres of wetlands.

(2). Losses. Thirty acres of wetlands, diminution of buffer
strip between North Bay and Ocean Shores residences. Additional stress on
avian fauna.

f. Aberdeen Park

(1). Gains. Improved public access, increased recreational oppor-
tunity and reduced urban blight in MU 17.

(2). Losses. Limited loss of intertidal area (about 1.3 acres)
with some alteration to the migratory fish route.

IV-43

H. UNAVOIDABLE ADVERSE IMPACTS

The following list summarizes the adverse impacts which would occur if the
GHEMP is implemented:

o The topographical features of the estuary will be changed by dredged
material disposal and filling in areas where such activities are permitted,
conditionally permitted or specially conditioned.

o Existing soils and land areas will be modified wherever development is
permitted, reducing natural absorption of storm waters.

o There will be a slight reduction in the tidal prism of the estuary by
approximately one percent below existing conditions.

o Urban development in some areas will increase air emissions, make minor
changes in hydraulic patterns resultina in minor changes in erosion and depo-
sition of sediment.

o Temporary reduction in water quality during dredging and construction
of various projects would occur.

o The removal of up to 5 percent of the remaining salt marsh of the
estuary, a slight removal of eel grass beds, and the removal of other forms of
vegetation in areas designated for urban uses would be permitted.

o The removal of an estimated one percent of the aquatic area of
the estuary, with a resulting reduction in the number of fauna utilizing the
bay, would be permitted. The most significant of these is the covering of
benthic communities in filled intertidal areas and the destruction of some
shorebird and fishery habitat.

o Some changes in the patterns of noise, light and odor would occur, most
notably relating to industrial use of the Bowerman area and relocation of
airports.

o Some land use patterns would be modified, reducing the shoreline area
potentially available for housing, increasing traffic generation wherever
development is permitted, and increasing the consumption of energy in the
region.

o The plan limits future options along the shoreline.

I. IRREVERSIBLE AND IRRETRIEVABLE COMMITMENT OF RESOURCES

When the GHEMP is implemented through local government adoption and permit
issuance (i.e., Section 10/44, shoreline development permits, etc.), a number
of actions if implemented would be considered as irreversible and irretrievable
commitments of the estuary's resources.

o A commitment to fill approximately 500 acres in MU 12. The plan allows
this commitment to be modified only if impacts are later shown to be unaccept-
able to the significant avian community based upon the results of monitoring
activites or new information.

IV-4 4

o A commitment to modify Port Slip No. 1 (permit has been issued).

o A commitment to expand the Westport Marina.

o A commitment to develop the Westport Airport.

o A commitment to construct a waterfront park in Aberdeen.

o A commitment to construct an airport at Ocean Shores.

o A commitment to allow up to two acres of fill to straighten banklines
in limited areas.

o A commitment to allow the protection of banklines from erosive forces.

Each of these commitments involves a modification of the aquatic area of the
estuary which cannot in practical terms be reversed.

o A commitment to preserve 1700 acres of prime shorebird habitat in
Mil 12 and 190 acres of marsh at Ocean Shores in MU 6 through the transfer of
lands from private to public ownership.

o A commitment to abide by the management categories, especially in the
cases of natural or conservancy environments, to protect these areas from
significant adverse modification. While plan modifications may be made through
the amendment process, approved amendments must provide balanced protection of
the estuary.

IV-45

J. RELATIONSHIP TO EXISTING LAND USE PLANS, ZONING AND REGULATIONS
1 . Local

a. County Planning and Zoning. The proposed plan would significantly
reduce the area available for higher intensity levels of development from that
currently permitted in the county comprehensive plan and zoning ordinances.
The most notable of these are a reduction of industrial zoning in the Junction
City area, a reduction in industrial zoning plans and further limitations on
the use of industrial areas on the south shore of the estuary, and a prohibition
on industrial use in Area 1 of MU 1 2 of the proposed plan. In aquatic areas
where the county comprehensive plan and zoning ordinances provide for low
intensity uses, the proposed designations and policies of the estuary plan
generally represent a refinement of existing regulations which could increase
restrictiveness. However, the plan produces little change in upland areas
which are planned and zoned for low intensity uses.

b. City of Aberdeen Comprehensive Plan and Zoning Ordinance. The
provisions of the plan do not directly conflict with any specific provision
of the plans and zoning of the city, but the policies of the plan would increase
restrictiveness in the degree to which water areas may be modified by filling.
While the present zoning ordinance zones this water area as "industrial," the
proposed plan would not allow most of this area to be filled.

c. City of Hoquiam Comprehensive Plan and Zoning Ordinance. The
proposed plan has much the same relationship to the Hoquiam land use regulation
as in Aberdeen', except that in addition to further restriction of potential
shoreline modification, use of waterfront areas are further limited by means
of a preference for water dependent and related uses.

d. City of Cosmopolis Comprehensive Plan and Zoning Ordinance. The
relationship and impact of the plan on Cosmopolis is similar to the impact
on Aberdeen's.

e. Ocean Shores Planning and Zoning. The proposed plan is highly
compatible with the City of Ocean Shores planning, zoning and other forms of
land use controls. The only exception is that the salt marsh area planned
for the airport is now zoned in its entirety (240 acres) for residential uses.
Residential development would be a non-permitted use of the marshes.

f. Westport Planning and Zoning. The proposed plan would reduce the
area planned for intense development by limiting use of several large marsh
areas in the city limits.

g. Shoreline Regulations. The plan generally constitutes an amendment
and clarification to the local Shoreline Master Programs which are now in effect
within the entire area. The relationship might be most effectively summarized
as a more detailed plan providing clarification of ambiguous provisions in the
SMP's. The clarifications include more specific environment designations,
particularly waterward of the high water mark or §404 jurisdiction, policy
guidance and identification of types of permitted activities within specific
environments. The types of changes to environment designations have been
previously addressed on page 1 1-6.

IV-4 6

2. Regional

a. The proposed GHEMP, when adopted, would be one element of an entire
Regional Plan which is described in a "Summary Statement for Land Use and
Housing Element Certification" which was developed with assistance from the
Department of Housing and Urban Development. This document is on file at the
offices of the GHRPC. Elements of this Regional Plan which are particularly
related to and affect the estuary, include:

o The Water Quality Element

o The Erosion Control Element

o The Open Space and Recreation Element

o The Overall Economic Development Element

o The Regional Land Use Element

o The Flood Control Element

o The Regional Circulation Element.

Other GHRPC planning documents were used in the development of the GHEMP and
are also on file at the Commission's offices.

3. State

a. The Washington Shoreline Management Act (SMA). The SMA was adopted
by the State of Washington Legislature in 1971. It provides the foundation
for the management program of the State's shorelines. The act's jurisdiction
includes all marine water areas of the State, streams with an average annual
flow of 20 cubic feet per second or more, and lakes larger than 20 acres. Also
included are lands adjacent to these waters extending 200 feet landward from
the ordinary high watermark and all marshes, bogs, swamps, floodways, river
deltas, and floodplains associated with the main water bodies. The GHEMP
includes the Grays Harbor estuary area from the harbor entrance jetties, up the
Chehalis River to its confluence with the Wynoochee River just south of the
town of Montesano. The area generally conforms to the jurisdictional bounda-
ries established under SMA described above, but also includes a small number
of additional areas outside this jurisdiction.

(1). The SMA requires and defines a planning program and regula-
tory permit system, both of which are initiated at the local level under State
guidance. In accordance with these requirements, those local jurisdictions
within the boundaries of the proposed Grays Harbor Estuary Plan have adopted
their respective shoreline master programs (SMP's). Inherent in the policy of
the SMA is the necessity for coordinated planning for the State's shoreline
resources. While local SMP's for the estuary have been adopted and have become
part of the State's Coastal Zone Management Program, the responsibility for
decisionmaking on various land/water resource actions continues to fall on a
variety of local, State and Federal agencies, each having its own policies or
regulations. Under RCW 90.58.020, the Washington State Legislature found a
"clear and urgent demand for a planned, rational and concerted effort, jointly
performed by federal, state and local governments, to prevent the inherent harm
which would result from uncoordinated and piecemeal development of the state's
shorelines."

IV-4 7

[c). [his identified desire to promote coordinated planning of the
shoreline resource is further addressed under RCW 90.58.340:

All state agencies, counties, and public and municipal corpora-
tions shall review administrative and management policies, reg-
ulations, plans, and ordinances relative to lands under their
respective jurisdictions adjacent to the shorelines of the state
so as to achieve a use policy on said land consistent with the
policy of this chapter, the guidelines, and the master programs
for the shorelines of the state. The department may develop
recommendations for land use control for such lands. Local
governments shall, in developing use regulations for such areas,
take into consideration any other state agencies or units of
local government.

The combined efforts of the Task Force members have resulted in a proposed
plan which resolves inconsistencies between the various adopted policies and
regulations presently found at the local, State, and Federal levels. The
proposed plan is a progressive effort representing a comprehensive set of
guidelines, management objectives, and use regulations for the entire estuary.
It is the type of coordinated planning program envisioned under the SMA.

(3). With regard to specific uses, the act places a strong empha-
sis upon a balance between conservation of the resource and use of the shore-
line. Under RCW 90.58.020 the legislature declares that "unrestricted construc-
tion on the privately owned or publicly owned shorelines of the state is not in
the best public interest," an interest which should be protected through coordi-
nated planning as discussed earlier, while "at the same time, recognizing and
protecting private property rights consistent with the public's interest."
Under RCW 90.58.020 the legislature further declares that it is the policy of
the state to provide for the management of the state's shorelines "by planning
for and fostering all reasonable and appropriate uses" and that this policy is
designed to:

insure the development of these shorelines in a manner which,
while allowing for limited reduction of rights of the public in
the navigable waters, will promote and enhance the public inter-
est. This policy contemplates protecting against adverse effects
to the public health, the land and its vegetation and wildlife,
and the waters of the state; while protecting generally public
rights of navigation and corollary rights incidental thereto.

(4). More specific priorities regarding shoreline use preference
are given for shorelines of statewide significance. This is particularly
significant to the proposed Grays Harbor Estuary Plan since the GHEMP has been
designated as a shoreline of statewide significance by the Legislature under
the SMA. Specifically, SMPs for such designated areas must provide use prefer-
ences that:

o recognize and protect statewide interest over local interest,

o preserve the natural character of the shoreline,

o result in long-term rather than short-term benefits,

IV-48

o protect the resources and ecology of the shoreline,

o increase public access to publicly owned shoreline areas, and

o increase shoreline recreational opportunities for the public.

(5). Another policy statement of the SMA particularly relevant to
the subject of use preference is again found under RCW 90.58.020. "...the
public's opportunity to enjoy the physical and aesthetic qualities of natural
shorelines of the state shall be preserved to the greatest extent feasible
consistent with the overall best interest of the state and the people general-
ly. To this end, uses shall be preferred which are consistent with control of
pollution and prevention of damage to the natural environment, or are unique to
or dependent upon use of the state's shoreline." While the act does not pro-
hibit all nonwater dependent uses, there is clear intent to establish a prefer-
ence for water dependent uses.

Throughout the GHEMP process, considerable weight has been given to the policy
regarding water-dependency. In viewing the proposed plan in total, priority
for uses has closely followed the policy and intent of the act, including the
criteria for shorelines of statewide significance. The proposed plan recognizes
the estuary as a valuable natural resource: important for food chain production;
anadromous fish feeding, rearing and migration; and wildlife habitat. It also
recognizes the estuary as an important navigational transportation corridor
between local, national and international markets, serving as a focal point for
the regional economy. The basic thrust of the proposed plan is to require
water dependent development as a requisite to major shoreline alterations.
There are a few specific areas which may, within the context of the total plan,
be allocated to non-water dependent uses such as airports (MU's 6, 12, 38),
industrial development (MU 14-Area 7) and urban revital ization of existing
shoreline (MU's 16 & 17). The planning effort has given substantial considera-
tion to MU 12 and has determined that the balance derived from allowing continued
industrial expansion in that part of the estuary abutted by existing industrial
development and urban services, while assuring future resource protection for
nearly ninety-nine percent of the estuary, is a reasonable and appropriate use
of the shorelines and is in the public's interest.

(6). The SMA contains language dealing with adoption procedures
of local SMP's and amendments to these programs. In the process of adopting
the proposed plan as an amendment to the previously approved local program,
the SMA will be observed.

(7). Basically, RCW 90.58.100 provides that in preparation of
amendments to SMP's, the DOE and the local government shall provide a sound
data base as a first step. The proposed GHEMP is based on data pertinent to
the estuary system, including vegetation and wildlife, existing uses, soils and
sediments, hydrology and others. The consultants have provided studies, inven-
tories, and surveys of the estuary for the consideration of the Task Force
members.

The second step in preparing a SMP or an amendment to an existing program is
the formulation of goals and policies. In regard to the proposed plan, the
overall goal of managing the estuary for multiple use is supported by general
policies at the planning area level and more specific management objectives

IV-49

for each separate MU. Also, as required by the SMA, the proposed plan contains
an introductory section, charts, definitions, and plan map to assist readers in
ease of understanding.

While the SMA does not prescribe specific guidelines for public involvement in
the master program amendment process, it has been used for guidance. RCW
90.58.130 requires that, in the original development of local shoreline master
programs, reasonable efforts must be made to inform people about the proposed
shoreline master program by inviting and encouraging public participation of
private groups and entities who show an interest. All Federal, State, and local
governments with an interest are also encouraged to participate.

While the proposed GHEMP was developed by the Estuary Task Force Committee,
(a group of local, State, and Federal agency representatives), public involve-
ment was also invited. The drafting of the proposed plan was initiated through
a process of extensive interviews with people and representatives of groups
with an interest in the estuary planning program. In addition, all meetings
of the Task Force were open to the public and notification of those meetings
was publicized in local newspapers. A public hearing on a draft proposed plan
was held February 21, 1978, and comments resulting from the hearing were con-
sidered by the Task Force.

In addition to the public input already provided, this NEPA/SEPA document will
allow for thorough review and comment on the proposal.

The final phase of the GHEMP development will be its adoption at the local
level and amendment to the existing shoreline master programs. Each affected
entity (six) will hold a public hearing, preceded by proper legal notice, at
the local level. Modifications to the local master programs will be processed
and evaluated by the Department of Ecology through State administrative pro-
cedures established under the SMA. Basically, the Department will review the
proposed amendments to determine consistency with the SMA and the Final Guide-
lines.

b. Other. The purpose of the State membership on the Task Force is
to ensure to the maximum extent practicable the consistency of the plan with
other significant State laws and regulations. For Grays Harbor this includes:

(1). State Forest Practices Act (RCW 76.09) - passed to protect
water quality of the streams and to ensure continuing productivity of the
timber lands of the State. The shorelines in the GHEMP are restricted to non-
damaging forest practices.

(2). Hydraulics Project Approval Law (RCW 75.20) - attempts to
control stream diversions or other actions that change natural streamways.
GHEMP affords this protection to the tributary streams and sloughs by requiring
minimum 50-foot buffer zones.

(3). Tideland Ownership and Leasing. The State has ownership
responsibility of the beds (unless previously sold) and shore of all navigable
waters of the State up to the line of ordinary high water. The Department of
Natural Resources holds the aquatic lands in trust for all the people of the
State and employs multiple use concepts to best satisfy the variety of needs
of the people. * Some tidelands in Grays Harbor have been granted, sold and

IV-50

leased (see attach. 1, map 2). Management of aquatic lands includes guide-
lines for navigation and commerce, public use, food, mineral and chemical
productions, protection of the natural aquatic environment, uses by abutting
upland owners, and revenue production. GHEMP is consistent with this multiple
use policy and ownership patterns.

(4). State Environmental Policy Act (RCW 43.21 C). GHEMP satisfies
the requirements of SEPA to foster and promote the general welfare, create and
maintain conditions under which man and nature can exist in productive harmony,
and fulfill the social, economic, and other requirements of present and future
generations of Washington citizens. This PEIS satisfies the administrative
requirements of the law.

(5). Miscellaneous Water Quality Controls. GHEMP is consistent
with other State requirements governing shellfish harvesting, the pollution
block line established by the DOE governing maintenance dredging during the
summer months, and other DOE regulations governing polluting materials and
effluents deposited into the estuary.

4. Federal

a. Coastal Zone Management Act (16 U.S.C. 1451, et. seq., as amended).
The GHEMP, the planning process and the proposed amendment to the State CZMP
are consistent with the CZMA Findings (§302) and Policies (§303). The findings
state the importance of resolving conflicts between competing demands placed on
fragile coastal ecosystems and of developing a forum and management system which
will allow such resolution. Both the findings and policies encourage Federal,
State and local governments to work together with other vitally affected inter-
ests in developing comprehensive land and water programs for the coastal zone.
The CZMA encourages "the preparation of special area management plans which
provide for increased specificity in protecting significant natural resources,
reasonable coastal -dependent economic growth, improved protection of life and
property in hazardous areas, and improved predictability in governmental
decisionmaking." (§303(3)). The GHEMP is one form of special area management
planning designed to meet those objectives and was partially funded through the
CZMA. The plan attempts to "preserve, protect, develop, and where possible, to
restore or enhance" the estuary's resources for this and future generations by
"giving full consideration to ecological, cultural, historic, and esthetic
values as well as to needs for economic development." (§303(2)). Once a final
version of the GHEMP is approved by local governments and the State, the plan
will be reviewed as an amendment to the Washington State CZMP and, if approved,
federal consistency will apply.

b. Clean Water Act (CWA, §404, 33 U.S.C. 1344 et. seq.). The purpose
of §404 of the CWA is to restore and maintain the chemical, physical and bio-
logical integrity of the water of the U.S. through the control of discharges of
dredged and fill materials. Dredged and fill material should not be discharged
into the aquatic ecosystem, including wetlands, unless it can be demonstrated
that such discharge is necessary, there are no practicable alternatives, and the
discharge wil 1 not have an unacceptable adverse impact either individually or
in combination with known and/or probable impacts of other activities affecting
the ecosystems of concern. The GHEMP has been revised from previous drafts in
order to be consistent as much as possible with the implementing regulations of
Corps of Engineers and EPA's §404(b)(l) Guidelines. The law and regulations

IV-5 1

encourage comprehensive resources planning and firmly state that approved
coastal resource management programs which have evaluated alternatives and
have a reasonable degree of specificity can be used to satisfy several of the
documentation requirements for permit applicants (40 CFR Part 230.10(a)(5)).
However, since it may be many years before any particular activity is proposed,
specific information and evaluations must be made at the time of a permit
application, and additional information will be required as a supplement to the
plan and this PEIS.

c. Rivers and Harbors Act of 1899 (§10, 33 U.S.C. 403) prohibits
the unauthorized construction or alteration of any navigable water, the exca-
vation from or deposition of material in such waters, or the accomplishment
of any other work affecting the course, location, condition or capacity of
such waters unless the work has been recommended by the Chief of Engineers
and authorized by the Secretary of the Army. Technical assistance provided
by the Seattle District of the Corps of Engineers has been useful in laying
the foundation in the plan for potential location of structures in the estuary.
While the public interest review required for each permit precludes the Corps
from foreclosing options for permit applications, the GHEMP has gone to great
length to take into consideration those items considered in a public interest
review. Therefore, the plan can be expected to provide greater predictability
to permit applicants. Projects which are inconsistent with the GHEMP (not
including conditional activities or special projects) would be precluded from
approval through the federal consistency provisions of the CZMA.

d. Fish and Wildlife Coordination Act (FWCA) (16 U.S.C. 661-666c).
The purpose is to recognize the vital contribution of wildlife resources to the
Nation, the increasing public interest and significance thereof, and to provide
equal consideration to those resources with other features of water resource
development programs through the effectual and harmonious planning, development,
maintenance and coordination of wildlife conservation and rehabilitation. Both
the U.S. Fish and Wildlife Service and the National Marine Fisheries Service
have been actively involved in the planning process to ensure equal considera-
tion of the fish and wildlife resources and to develop and evaluate alternative
plans. The FWCA requires such agencies to first consult with State and Federal
wildlife agencies with a view to ascertaining what project facilities, opera-
tions, or measures may be considered necessary by those agencies to mitigate
and compensate for project occasioned losses to wildlife resources, as well as
to enhance those resources. This input has substantially affected the design
and development of the GHEMP.

e. Endangered Species Act of 1973 (ESA) (16 U.S.C. 1531). The purpose
of the ESA is to provide a means whereby the ecosystems upon which endangered
and threatened species depend may be conserved, to provide a program for the
conservation of such endangered species and threatened species, and to take
such steps as may be appropriate to achieve the purposes of the treaties and
conventions set forth in the act. All Federal departments and agencies must
seek to conserve listed species and utilize their authorities in furtherance
of the purposes of the act. As lead agency for purposes of this PEIS, the 0CRM
has consulted with both the NMFS and the F&WS in order to ensure compliance
with the ESA. It was determined that no marine animals listed on the endan-
gered or threatened species list would be adversely impacted. Formal Section 7
consultation, however, was required with the F&WS for the endangered American

IV-52

peregrine falcon (F.p. anatum), the sitings of which have only recently estab-
lished Grays Harbor as a significant habitat for the migrants which frequent
the area. The Task Force modified the plan to comply with ESA requirements and
obtained a non-jeopardy opinion from the F&WS (see appendix C).

f. The above mentioned laws have been critical in developing and
shaping the GHEMP. Other applicable laws include:

(1). Archeological and Historic Preservation Act, as amended

(2). Clean Air Act, as amended

(3). Executive Order 11988, Floodplain Management

(4). Executive Order 11990, Protection of Wetlands

(5). National Environmental Policy Act, as amended

5. Upon successful completion of the NEPA process and plan adoption, the
GHEMP and the actions taken to adopt and implement it should be in compliance
to the maximum extent practicable with all Federal, State and local plans,
policies and regulations. Local governments will have revised local plans,
zoning ordinances, etc. in order to be consistent with the GHEMP. While the
GHEMP will provide the major framework for the future management of the Grays
Harbor Estuary, other laws and regulations will still be utilized in the
decisionmaking process.

IV-53

PART V: MISCELLANEOUS

NAME

Richard B. Mieremet
(EIS Coordinator)

JoAnn Chandler

Dr. Robert K. Kifer

A: LIST OF PREPARERS
EXPERTISE DISCIPLINE

Office of Ocean & Coastal Resource Management

Environmental assessment
& EIS preparation, CZM
issues & program approval

Envi ronmental law &
Administration

Physical Sciences,
Biological Sciences

B.S. Conservation & Resource

Development

M.S. Water Resources Mngt.

B.A. History

J.D. Land Use, Environment,

Public Interest

B.S. Dairy Science,

EXPERIENCE (Yrs)

Natural Resources & Coastal Zone
Management (10)
Environmental assessment (8)

Coastal Zone Management (8)

Coastal Zone Management (8)

M.S. Biochemistry, Physiology Environmental assessment (13)

H. Grant Dehart

Roy N. Arnold
Gina DeFerrari

Pat Dugan

Janet Richardson

Tim Trohimovich

Rol lie Montagne
Gordon Davis

Land Use Planning,
Historic Preservation

Water resources planning
Wetlands management

Environmental assessment

B.A. Architecture
M.A. City Planning &
Architecture

A.B., M.B.A., Masters of
Regional Planning

B.S. Geology

M.S. Marine Affairs

Grays Harbor Regional Planning Commission

Economic Development,
Urban/Regional Planning

CI ly /Urban I' I, inning

Land Use & Environmental
PI anning

B.A. Political Science
M.A.T. Geography

II. A. Urban/Roy luna I Manning

Coastal Zone & Land Use Mange-

ment (7)

Environmental assessment (2)

Coastal Zone Management Plan-
ning Specialist (2)

Coastal Zone Management Plan-
ning Specialist (3)

Urban/Regional Planning (10)
Public Administration (2)

Urban Lion uw It A Soilal
Planning (15)

B.A. Urban/Regional Planning Urban/Regional Planning (5)

Consultants

INTERAGENCY PROJECT REVIEW TEAM

The following individuals have provided assistance during EIS preparation by reviewing draft copies and providing
additional information.

Dr. Fred Weinmann
John Malek

Charles K. Walters
Jackie Wyland

Ralph Boomer
Jeffrey Opdyke

Ron Lee

Virginia Fox-Norse

Seattle District of the U.S. Army Corps of Engineers

National Marine Fisheries Service

U.S. Fish & Wildlife Service

U.S. Environmental Protection Agency

Washington Department of Ecology

Don Peterson
Joe Williams

Other members of the Grays Harbor Estuary Task Force.

David Ortman, Friends of the EarWi, provided the Citizen's Estuary Management Plan Alternative

Typing and Editorial Assistance

Richard Kelly
Denise Brown
Sheila Faulkner
Donald Hardy
Marian Mieremet

V-l

C: LIST OF AGENCIES, ORGANIZATIONS AND PERSONS
TO WHOM COPIES OF THE STATEMENT ARE SENT

FEDERAL AGENCIES

Advisory Council on Historic Preservation
Council on Environmental Quality
Department of Agriculture

Forest Service

Soil Conservation Service
Department of Commerce
Department of Defense

Office of Assistant Secretary

U.S. Air Force

U.S. Army Corps of Engineers
Department of Energy
Department of Health & Human Services
Department of Housing & Urban Development
Department of the Interior (45 copies)
Department of Justice
Department of Labor
Department of Transportation

Environmental Division

U.S. Coast Guard
Environmental Protection Agency

Office of Federal Activities

Region X
Federal Emergency Management Agency
Federal Energy Regulatory Commission
General Services Administration
Marine Mammals Commission
Nuclear Regulatory Commission

CONGRESSIONAL REPRESENTATIVES

Honorable Henry Jackson
Honorable Slade Gorton
Honorable Don Bonker
Honorable Norman D. Dicks
Honorable Mike Lowry
Honorable Joel Pritchard
Honorable Al Swift

NATIONAL INTEREST GROUPS AND ORGANIZATIONS

AFL-CIO (Maritime Trades Department)
American Association of Port Authorities
American Bureau of Shipping
American Farm Bureau Federation
American Fisheries Society
American Gas Association

V-2

American Littoral Society

American Shore and Beach Preservation Association

American Society of Landscape Architects, Inc.

American Society of Planning Officials

American Waterways Operators

AMOCO Production Company

Atlantic Richfield Company

Boating Industry Association

Bureau of Marine Resources

Center for Law & Social Policy

Center for Urban Affairs

Center for Urban & Regional Planning

Chamber of Commerce of the United States

Chevron, USA

Cities Service Company

Conservation Foundation

Continental Oil Company

Council of State Planning Agencies

El Paso Company

Environmental Policy Center

Environmental Defense Fund, Inc.

Environmental Law Institute

EXXON Company, U.S.A.

Friends of the Earth

Gulf Oil Exploration & Production Company

Gulf Refining Company

Institute for the Human Environment

International Council for Bird Preservation

Interstate Natural Gas Association of America

Manomet Bird Observatory

Marathon Oil Company

Marine Technology Society

Mobile Oil Corporation

Murphy Oil Company

National Association of Conservation Districts

National Association of Home Builders

National Audubon Society

National Marine Manufacturers Association

National Coalition for Marine Conservation, Inc.

National Farmers Union

National Fisheries Institute

National Forest Products Association

National Ocean Industries Association

National Recreation and Park Association

National Research Council

National Society of Professional Engineers

National Wildlife Federation

National Waterways Conference

Natural Resources Defense Council

Nature Conservancy

New York Zoological Society

Outboard Marine Corporation

Sierra Club

Soil Conservation Society of America

V-3

Standard Oil Company of Ohio

Sun Company, Inc.

Ecology & Environment, Inc.

Tenneco Oil Company

Texaco, Inc.

Union Oil Company of California

United Mobile Sport Fisherman

Urban Research & Development Association, Inc.

Western Oil & Gas Association

Wildlife Management Institute

World Wildlife Fund

STATE AGENCIES

Office of the Governor

Department of Commerce & Economic Development

Department of Ecology

Department of Fisheries

Department of Game

Department of Natural Resources

Department of Parks and Recreation Commission

Department of Transportation

State Conservationist

State Planning and Community Affairs Agency

Interagency Committee for Outdoor Recreation

Office of Archeology & Historic Preservation

LOCAL GOVERNMENTS

Mayors and Officials of the Cities of:
Aberdeen
Cosmopolis
Hoquiam
Montesano
Ocean Shores
Westport

MEMBERS OF THE GRAYS HARBOR ESTUARY TASK FORCE

LIBRARY INFORMATION CENTERS

Aberdeen Public Library

Cosmopolis Public Library

Evergreen State College Library

Grays Harbor Community College Library

Hoquiam Public Library

Montesano Public Library

Ocean Shores Public Library

Seattle Public Library

University of Washington Library

Westport Public Library

V-4

NEWS MEDIA

Daily World

Twin Harbors Press

Grays Harbor Suburbanite & Farmer- Logger

North Beach Beacon

Seattle Times

Tacoma News Tribune

Seattle Post-Intelligencer

Montesano Vidette

OTHER INTERESTED PARTIES

In addition to the above, OCRM will distribute some additional 600 copies to
individuals and organizations who have either requested a copy of the DEIS,
who commented during the scoping process, or who are generally interested in
activities occuring in Grays Harbor and have been identified from Seattle
District Army Corps of Engineers mailing list or the Grays Harbor Regional
Planning Commission's mailing list.

A limited number of additional copies of the PDEIS will be available through
the Grays Harbor Regional Planning Commission or OCRM. Contacts follow:

Grays Harbor Regional
2109 Sumner Ave.
Suite 202

Aberdeen, WA 98520
(206) 532-8812

Planning Commission

NEPA Compliance Coordinator

N/0RM4

3300 Whitehaven St., N.W.

Washington, D.C. 20235

(202) 634-4120

V-5

Grays Harbor
Estuary

Management
Plan

Grays Harbor, Washington
February 1983

Grays Harbor Regional Planning Commission
WHsey&Ham

The preparation of this report was financially aided through a grant from the Washington
State Department of Ecology with funds obtained from the National Oceanic and
Atmospheric Administration, and appropriated for Section 306 of the Coastal Zone
Management Act of 1980.

PARTICIPATING AGENCIES

ON THE

GRAYS HARBOR ESTUARY MANAGEMENT

PLANNING TASK FORCE

Grays Harbor County

City of Aberdeen

City of Cosmopolis

City of Hoquiam
City of Ocean Shores

City of Westport

Port of Grays Harbor

Grays Harbor Regional Planning Commission

Washington State Department of Ecology

Washington State Department of Fisheries

Washington State Department of Game

Washington State Department of Natural Resources

U.S. Army Corps of Engineers

U.S. Environmental Protection Agency

U.S. Fish and Wildlif e Service

National Marine Fisheries Service

TABLE OF CONTENTS PAGE

INTRODUCTION

Why the Plan? 1

The Plan Area 2

The Planning Process 2

Plan Concepts 3

Relationship to Other Plans 3
Relationship to State and Federal

Permitting Processes 4

How to Use this Plan 6

Plan Review and Amendment 9

Future Actions 12

PLAN CONCEPTS AND DEFINITIONS

The Planning/Management Framework 13

Estuary Management Goal 13

Planning Areas 13

Management Units 14

Definitions 14

Management Units 14

Fills 16

Terms 16

GENERAL POLICIES

Management Categories 22

Bankline Erosion Control 22

Bankline Straightening 24

Standard Uses 25

Log Rafting 26

Mitigation 26

Disposal of Wood Waste 28

PLANNING AREAS - DESCRIPTIONS AND

GUIDELINES

Planning Area I 29

Planning Area II 31

Planning Area III 34

Planning Area IV 36

Planning Area V 38

Planning Area VI 40

Planning Area VII 43

Planning Area VTII 45

MANAGEMENT UNITS

Management Units 1-44 48

STANDARD USES 109

INTRODUCTION

WHY THE PLAN?

Grays Harbor is one of two major estuaries on the Washington coast and is the only
coastal estuary in the state with an authorized deep water navigation channel and major
port. The Grays Harbor estuary provides an important transportation linkage between
local, national and international markets and serves as a focal point for the regional
economy. In addition, the estuary is a nursery ground and passage way for a vast array of
living resources and an important link in the migratory patterns of many fish and wildlife
species.

Each year an increasing number of demands are placed on the estuary by an expanding
economic base and growing population. The ability of the estuary to accommodate these
demands, remains constant or diminishes. The result is often conflict between the various
groups that want to use the resources of the estuary and the agencies responsible for
managing those resources.

The responsibility for making decisions about the use of the land and water resources of
the Grays Harbor area falls to a wide variety of local, state and federal agencies. Each
agency that has some authority uses a plan or written guidelines to make decisions on
what may or may not be done. The cities and the county have comprehensive plans and
Shoreline Master Programs; the Corps of Engineers, Environmental Protection Agency,
State Departments of Game and Fisheries and other state and federal agencies each have
their own regulations. In general, these agencies have prepared their plans and guidelines
independently. The result is that the process for making decisions and getting things done
is confusing, uncertain and often frustrating for the individuals involved.

In response to the increasing conflicts, the Grays Harbor Regional Planning Commission
formed an Estuary Planning Task Force in late 1975. In September, 1976 the Task Force,
through the Regional Commission and the Department of Ecology, received federal funds
for the development of a Grays Harbor Estuary Management Plan. A consultant team was
retained to assist the Task Force in the development of the plan.

The Grays Harbor Estuary Management Plan does not eliminate or modify any of the laws,
regulations, or policies which govern the actions and decisions of local, state or federal
agencies, but rather, improves their interpretation, interaction and implementation. In
identifying the major legal authorities and concerns which may be called into play
throughout the estuary, the plan attempts to meld these authorities and concerns into
unified estuary-wide guidelines for both protection and development of the area's
economic and natural resources. Since these guidelines have been developed by
participating local, state and federal agencies and, in full recognition of legal and policy
constraints on each, the plan will avoid piece-meal decisionmaking through the estuary.
By the same token, activities which are not allowed by the Plan can expect non-
concurrence by participating agencies.

THE PLAN AREA

The area covered within the management plan includes the Grays Harbor estuary area
from the end of the harbor entrance jettys, up Chehalis River to its junction with
Wynoochee River, south of Montesano. The specific study boundary is defined in the
description of each management unit.

THE PLANNING PROCESS

A five-step planning process was used in the development of the management plan.

Step 1

This initial stage of the planning process included the preparation of a comprehensive
estuary information base. A technical team, composed of resource specialists, planners,
economists and other technical personnel, was drawn from industry and local, state and
federal agencies to assist the consultant team in the development of this information
base. The completed data are in the form of thirteen large scale maps and a technical
document entitled, Grays Harbor Estuary Management Program, Technical Memoranda,
Summary of Interviews, and Annotated Bibliography. These documents are maintained at
the offices of the Grays Harbor Regional Planning Commission. The information
contained on the maps and in the technical document are:

hydrology and f loodplain

jurisdictions and boundaries

land and water transportation

land ownership

existing uses

historical features

soils and sediments

fisheries

natural resource use

major utilities

comprehensive plan designations

shoreline types

vegetation and wildlife

areas of conflict and concern

Beginning with the Step 1 work effort, a major public information and communication
program was undertaken. The program focused on three primary groups including: 1) the
general public within the Grays Harbor region, 2) organized groups and individuals with an
interest in the harbor, and 3) specific affected individuals. To reach these groups, a
program of media contact and solicitation was undertaken; a sequence of general mailings
established at various phases of the work; several thousand copies of a special
"Community Information Bulletin" were prepared and distributed; and in-depth, hour long
interviews were conducted with 68 individuals representing environmental groups, naviga-
tion interests, recreation interests, university and research groups, the fishing industry,
local business organizations, specific local industries, labor, and the general citizenry.
The thirteen maps are contained in the Federal Environmental Impact Statement that has
been prepared on this plan.

Step 2

Through a series of six, one and two day workshops, the Estuary Planning Task Force
evolved the management plan. The Task Force operated on a concensus basis under the
guidance of the consultant team to discuss key issues, evaluate alternative courses of
action and arrive at critical decisions. At the completion of the last workshop, the
consultant team prepared a first draft of the management plan.

Step 3

This stage of the planning process involved a lengthy review of the Preliminary Draft Plan
by the general public and the various agencies and jurisdictions represented on the Task
Force. On the basis of that review, which included a public hearing conducted by the
Grays Harbor Regional Planning Commission, a revised draft plan was prepared and
published in November, 1978. As with the initial draft plan, extensive public and agency
review has been conducted on this second draft. While some delay occurred in this review
because of changing federal guidelines that had direct bearing on the plan, the completion
of this step resulted in a revised public draft in early 1981.

Step i*

Based on public and agency comments received formally and informally by the consultant
team, a proposed set of changes to the November draft was presented to the Estuary Task
Force in a two day workshop. Based on the directions of the Task Force, a final revised
public review plan was prepared and forwarded to the Grays Harbor Regional Planning
Commission for their review and transmittal to the member jurisdictions and the affected
state and federal agencies.

Step 5

This step is the formal process that each agency and local government must go through
including public hearings, to officially adopt or endorse the plan. For local government,
this involves adoption of the applicable provisions of the plan as a revised or amended
local Shoreline Master Program. State and federal agencies will participate in the
development of a state (SEPA) and federal (NEPA) environmental impact statement for
this plan and will develop memoranda of agreement or other documents to describe their
use of the Plan.

PLAN CONCEPTS

There are two important concepts that are the basis for the plan. First, the plan contains
management goals, guidelines and policies as well as agreements on specific issues or
projects within the Plan Area. The distinction is important since the normal process for
developing this type of plan begins and ends with the establishment of goals and policies.
However, because of the lack of agreement that has arisen in recent years on specific
issues within the Grays Harbor region, it is not possible to develop goals and policies
without understanding the effect of the policies on those issues. In many cases, the
resolution of specific issues paralleled the development of policies for the area within
which the issue existed.

The second concept of the plan is "balance". The Estuary Management Goal states that
the estuary as a whole will be managed for multiple uses. Inherent in this goal is the idea
of balance - the plan specifies goals, policies and guidelines which strike the tenuous
balance between necessary and appropriate development of the harbor and protection and
preservation of the estuary's natural resources. The plan looks at this balance on an
estuary-wide rather than a piecemeal basis. Thus, some areas of the estuary are primarily
devoted to the preservation of fish, wildlife and plant resources, free from the pressures
of development. Still other areas are approved for certain types of development only,
allowing both development and natural resources to co-exist.

Although the plan has been carefully balanced in this manner, this does not mean that it
cannot be amended or revised. In fact, in a later section entitled Plan Review and
Amendment specific procedures are outlined for amendment processes. Perhaps the most
important consideration for plan amendment or revision is its effect on the balance of the
plan. Future changes, whether in policy or specific issues, will be evaluated to ensure
that the balance of the plan is maintained. Such changes must either be accommodated
within the existing balance of the plan, or must be combined with actions which will re-
establish that balance.

RELATIONSHIP TO OTHER PLANS

The Estuary Management Plan is being prepared by the Grays Harbor Regional Planning
Commission. The Commission itself, however, does not have the authority to adopt or
enforce any plan since it is strictly a planning and coordinating agency. The Estuary
Management Plan represents a recommendation from the Estuary Planning Task Force,
which was formed under the auspices of the Regional Commission, to the Commission
members (local cities and county) as well as to the affected state and federal agencies.

To use the plan, each state and federal agency and local government will incorporate the
applicable portions of the plan into their policies and review criteria and processes as well
as into local Shoreline Master Programs and comprehensive plans. After adoption into
local plans, the State Department of Ecology will incorporate the plan into the state's
Coastal Zone Management program. In areas where management unit boundaries fall
outside the jurisdiction of local Shoreline Master Programs, local comprehensive plans and
zoning designations will be used to implement the plan.

RELATIONSHIP TO LOCAL, STATE AND FEDERAL PERMITTING PROCESSES

Most local, state and federal agencies with management authority in the estuary exercise
their authority through either the issuance of permits or through review and comment on
permit requests. As previously noted, the plan does not eliminate or modify these
authorities, but does improve the predictability of these permitting processes through
advance consideration and evaluation on an estuary-wide basis.

Perhaps the most significant permitting processes affecting the estuary and its wetland
areas are those under the responsibility of the Corps of Engineers. Under the Rivers and
Harbors Act of 1899, the Corps must determine whether work in navigable waters of the
United States may be allowed (Section 10 permits). Additionally, under the Clean Water
Act, the Corps must determine whether filling of waters of the United States, including
wetlands, may be allowed (Section 404 permits). While administered by the Corps, Section
404 permit requests are evaluated with guidelines developed by the Environmental
Protection Agency (404 Guidelines) and are subject to review and concurrence by the EPA
and other federal agencies. In addition, in issuing both Section 10 and 404 permits, the
Corps must solicit comments from state and federal fish and wildlife agencies and must
assure that equal consideration is given to the protection of fish and wildlife resources
along with other project purposes. These latter requirements are based on 404 Guidelines,
the Fish and Wildlife Coordination Act, the National Environmental Policy Act, and
various state statutes.

Just as the plan does not bypass the Corps permitting process, or any other local, state or
federal permitting process, neither does the plan circumvent any of the criteria which an
agency must use in issuing or commenting on a permit. The advantage of the plan,
however, is that it brings increased predictability into these permitting processes because
of the direct involvement of the permitting and reviewing agencies in the planning
process. Whenever possible and appropriate, the planning process, including these
agencies, has attempted to look ahead to permit criteria to the extent of the available
data, in establishing the goals, policies and standards for this plan. For purposes of
clarity, Management Unit descriptions specify where and to what extent these advance
evaluations have been conducted. Where a proposed use or activity has not been
permitted (or is considered conditional by the Plan and is denied through a local and/or
State review process), a local Shoreline Permit will be denied and therefore if a Corps of
Engineers permit is required, it will also be denied. A proposed use or activity is not
permitted by the Plan if 1) it is not designated "permitted" in either the Permitted
Activities table for each Management Unit or the Standard Use table and/or, 2) it is
designated as "conditional" but denied through the review process conducted by local
government or the State Department of Ecology.

As a more specific example, Section 404 Guidelines, which control requests to fill in
waters and wetlands, require that a permit applicant make four demonstrations. These
are: 1) that the activity associated with the fill is either water dependent, or there is no
practicable site or construction alternative for the activity; 2) that there is a need for the
proposed activity; 3) that there are no less environmentally damaging alternatives; and 4)
that there are not unacceptable adverse impacts to the aquatic ecosystem from the fill
and the activity associated with it.

In the broadest sense, the alternatives and needs demonstrations required of a permit
applicant under Section 404 Guidelines have been evaluated under the plan, on an estuary-
wide basis. In many cases, more specific aspects of these criteria were reviewed as a part
of the decision making for this plan. However, many aspects of the first three criteria
(including the needs and alternatives evaluations) are most directly associated with the
specific project and its characteristics. To fully satisfy these three criteria under the
Section 404 permit process will require evaluations related primarily to a specific project
and its area of impact.

It is in the fourth area - unacceptable impact evaluation - that the plan has its greatest
value, and the permitting process has its greatest stumbling block. The plan indicates

where proposed activities would generally be "acceptable", provided that avoidable
adverse impacts are controlled (e.g., in the scope and design of the proposed activity).
Simply, the acceptability of some site-specific adverse impacts is contained in the
estuary-wide resource protection of the plan.

HOW TO USE THIS PLAN

This plan does not answer all questions on what can or cannot be done with a specific
piece of land. As some of the previous sections have described, this plan does not take
away the authority of existing regulations or policies, nor does it remove any decision
making responsibility. The plan is designed to provide guidance to the decision making
process, it does not make decisions itself.

The issues surrounding any proposed use or activity in an estuary are complex. The
decision on such a proposal is therefore rarely based on a simple "right or wrong", or "good
or bad" evaluation. Because of this, it is not possible to simply go, as an example, to page
38 to find out "the right answer" to the question of a specific permitted use. This plan
contains several different forms of guidance which all must be considered to determine
what is "right". Both the individual property owner who is considering a specific proposal
and the decision maker who is evaluating the proposal, must use all of the guidance of this
plan to make their final judgement.

There is no single way to properly use this plan since the most effective way would be to
understand the entire plan. However, the following steps represent a general sequence to
be used to determine whether or not a specific use or activity is considered by the plan as
appropriate.

STEP 1

Locate the property in question on the Estuary Management Plan map. Two things
should be noted from the map; first, the Management Unit number; second the
Planning Area number.

STEP 2

The proposed use or activity must be accurately described. To do so, several
questions should be asked:

1. Which of the uses identified on the "Standard Uses" table on page 109 most
accurately describe the proposal?

2. Will any of the following activities be be required to accomplish the proposal?
If so, which ones?

Permitted Activities

Structures

o Piers, docks, wharves

o Piling and mooring dolphins

o Bridges

•

•

Causeways
Outfalls

•
•

Cable/pipeline crossing
Boathouses

•

Breakwater

Bankline Activities

•
•
•

Diking

Bulkheading

Groins

•
•
•
•

Jetty

Special project fills (see page 16)
Bankling straightening (see page 2k)
Bankline erosion control (see page 2k)

Channel (Navigation) Activities

• New access channel

• Maintenance of existing channels or berths

• Realignment of existing channel

3. Will any part of the proposed use or activity extend waterward of the line of
Ordinary High Water?

If the answer to this question is yes, in addition to the Management Unit
number identified in STEP 1, note that Management Unit kk (dealing exclu-
sively with the water area) will also apply to the proposal.

k. Will any part of the proposed use or activity extend waterward of the line of
non-aquatic vegetation (into the wetlands)?

NOTE: This line will not be easy to identify without technical assistance.
While the line generally describes marsh areas, the seasonal nature of
these areas and the broad definition of non-aquatic vegetation types
make it difficult to accurately identify the extent of these areas. The
Regional Planning Commission, city or county staff can provide some
preliminary guidance on this question.

If the answer to this question is yes, the proposal will be subject to the Corps
of Engineers Section kOk permit requirements. Other permits may also be
required depending on the specific type of proposal. This plan does not try to
identify those additional requirements, but again, the Regional Planning
Commission, city or county staff should be consulted for any of those possible
other permits or procedures.

STEP 3

Turn to the page that covers the identified Management Unit (pages 48-108). On
that page, you will find the following information about that management unit:

1. Planning Area Number

This number (roman numeral) occurs directly under the Management Unit
number. This refers to the Planning Area within which this management unit
occurs (occasionally a management unit occurs in two Planning Areas).
General Guidelines for the Planning Area can be found on pages 29-47.

2. Management Category

Pages 22 and 23 will provide a general definition of these categories.

3. Boundary Description

This is a series of statements that attempt to fix the boundaries of the
management unit as accurately as possible.

NOTE: The water ward boundary of a shoreline management unit is generally
the line of Ordinary High Water. In some cases, the waterward
boundary has been modified and is thereby described in this section.

4. Management Objective

This is a statement about the general objectives for the management of this
specific area. This should be considered a refinement of the Management
Category definition for this management unit.

5. Permitted Activities Table

A table that describes the permitted activities for this specific management
unit (definitions of permitted and conditional are found on pages 17 and 19).

6. Standard Uses

This is only a reference to the Standard Uses table on page 109.

7. Special Conditions

Not all management units contain this section. For those that do, this section
provides further guidance than can be found in the Permitted Activities or
Standard Uses tables or within other guidelines.

If it is determined that the proposal involves Management Unit 44 (STEP 2, question 3),
turn also to the page corresponding to that management unit.

STEP 4

Conduct an initial evaluation of the proposal in the following sequence:

1. Turn to the Standard Uses table (page 109);

2. Find the use (barge, berthing, aquaculture, etc.) that best fits the proposal;

3. Find the column with the applicable Management Category (UR, CM, etc.) for
your Management Unit;

4. Identify whether the use is ( • ) PERMITTED, ( D ) subject to SPECIFIC
MANAGEMENT UNIT GUIDELINES, or (no symbol) NOT PERMITTED.

USE is Permitted, or subject to Specific Management Unit Guidelines;

Turn to the Management Unit page and determine whether or not the
activities (piers, diking, etc.) that will be required are permitted.

USE is not Permitted:

When a proposal does not conform to the plan, the requested permit will be
denied by the permitting agency. If the proposal is still desired, however, it
must first be presented as a proposed amendment to the plan (see Plan Review
and Amendment section, pages 9-12).

ACTIVITIES are not Permitted, Conditional, or subject to Special Conditions:

The proposal does not conform to the plan (even though the use might be
permitted) and will require an amendment to the plan (see Plan Review and
Amendment section, pages 9-12).

USE and ACTIVITIES are Permitted or subject to Special Conditions:

Check the Special Conditions section of the Management Unit for any
applicable provisions.

USE or ACTIVITIES are Conditional:

The proposal will be reviewed on the basis of its specific merits rather than on
its general use or activity characteristics. Review the definition of Condi-
tional Use (page 17) and develop a presentation to support the proposal based
on its specific, unique characteristics and on its conformance to the Estuary
Management Goal (see page 13), the applicable Planning Area Guidelines
(pages 29-47), the Management Unit Objective and other relevant factors.

PLAN REVIEW AND AMENDMENT

The Estuary Planning Task Force, through its consensus decisionmaking process, will
continue to play an important role in both on-going planning and plan review and
amendment. This continuing role is necessary in order to maintain the balance of the plan
through the consensus process. Both consensus and balance must be maintained if the plan
is to serve as an effective guide to local, state and federal decisionmaking. A change in
the balance of the plan (even through a change in a single Management Unit) could
jeopardize the responsiveness of the plan to agency and citizen concerns, imparing the

advance permit evaluations that are contained in the plan and undermine the commitment
of Task Force members to use the plan. The review and amendment process includes the
following elements:

• Annual Review

In February of each year, the Estuary Planning Task Force will meet in a day-long session
to conduct an Annual Review of the Estuary Management Plan. The primary purpose of
this session is to review development and permit activities of the previous year and to
assess the usability of the Management Plan. The Task Force may wish to suggest
amendments to various portions of the Management Plan although the nature of those
amendments will be more administrative or for the purpose of clarification than
substantive policy changes. As with all of its reviews, the Task Force will ensure that
comments from the general public are solicited and reviewed.

• Five Year Review

In February of the fifth year after the adoption or endorsement of the initial Management
Plan, the Estuary Planning Task Force will meet in a series of workshops to systematically
review all of the elements of the plan. On the basis of that review, both administrative
and substantive changes will be recommended through the Regional Planning Commission
to the respective Task Force jurisdictions, agencies, and the general public.

• Plan Amendment

The plan amendment process is guided by the adoption, implementation and amendment
process of the State's Shoreline Management Program. Initially, this plan will be adopted
by each local jurisdiction as an amendment to their Shoreline Master Program. Once
done, the State Shoreline Management Program will be amended to incorporate the
amended local Shoreline Master Programs.

Although the Estuary Planning Task Force is not legally a part of this adoption/amend-
ment process because of its planning advisory role, it has, nonetheless, been the means to
create the plan through the consensus of its members. Since state and federal agencies
have worked with local officials on the Task Force to develop the plan, their early
involvement in amendments to the plan will facilitate subsequent permits that might be
required because of the amendment.

Through the annual and five year review process, the Task Force will be forwarding
recommendations to local government for possible amendments to various components of
the Estuary Management Plan and their Shoreline Master Programs. Such amendments
will follow the same process as the adoption/amendment process of the initial Estuary
Management Plan.

It is probable that individuals, corporations or special interest groups may wish to propose
amendments to local Shoreline Master Programs and thereby the Estuary Management
Plan.

Again, such amendments are only within the jurisdiction of local government although the
Estuary Planning Task Force will have an interest in such amendments since they will
effect other areas of the estuary. The role of the Task Force in such proposed
amendments will be that of "review and comment" to the local government involved. To
ensure that the Task Force or its individual members are able to provide meaningful

10

comment on such amendments, local government should consider limiting the considera-
tion of plan amendments to once every six months. The following general procedure will
be followed.

1. When a local government receives a request for an amendment to their Shoreline
Master Program, that request will be forwarded along with explanatory materials to
the Grays Harbor Regional Planning Commission.

2. Commission staff will forward the request to the members of the Estuary Planning
Task Force.

3. The Task Force members will be polled to determine if the proposed amendment
should require a special Task Force meeting outside the established annual review.

4. If no meeting is believed necessary, individual Task Force member comments will be
forwarded directly to the local government.

5. If a meeting is believed necessary, the Task Force recommendation from that
meeting will be forwarded to the local jurisdiction. Normally, such recommenda-
tions will be forwarded within 60 days from the time the Regional Planning
Commission received the request.

In conducting a review of the proposed plan amendment, the Task Force, through its
consensus decisionmaking process, will develop its recommendation to the local jurisdic-
tion based on a consideration of the following criteria. Applications, therefore, should
address themselves to these factors:

1. The conformity of the amendment with the Estuary Management Goal, the appli-
cable Planning Area Guidelines, and other Plan objectives and policies;

2. A demonstration that the amendment is not already permitted elsewhere in the
estuary or that other permitted locations are not suitable (land ownership is
insufficient as a sole factor in determining suitability);

3. A demonstration that the amendment:

a. will not cause adverse effects on the local and estuarine natural systems or that
these effects can be mitigated, and

b. will be within the ability of local and regional support systems (rail, utilities,
highways, etc.) to serve the proposed amendment,

4. Specific factors to be considered in a proposed plan amendment include an
evaluation of short and long term, primary and secondary:

a. changes in land use patterns,

b. changes in energy supply and demands,

c. increased pressures for development in floodplains, streams and natural drainage
ways, wetlands or other aquatic areas,

d. significant changes in air, noise or water quality levels, or potential violations of
established standards,

e. significant changes in surface or groundwater hydrology,

f . pressures for encroachment on fish or wildlife habitat;

11

5. Additional factors include the degree to which an amendment would:

a. set a precedent for other comparable amendments,

b. result in or promote a significant cumulative adverse impact, and

c. affect significant historic, archaeological, pre-historic or scientific areas or
facilities.

In addition, any amendment to local Shoreline Master Programs must include satisfaction
of environmental requirements that result from an evaluation of the State Environmental
Policy Act and the National Environmental Policy Act as appropriate. Once approved by
a local jurisdiction, the amended Shoreline Master Program must be forwarded to the
State Department of Ecology for approval.

FUTURE ACTIONS

Even though this plan has developed a comprehensive management framework for the
entire estuary, it has not been possible to develop all of the planning tools that are needed
to deal with all issues. For that reason, the following additional actions are necessary.

1. Preparation of a Mitigation Plan for the estuary identified in the Mitigation Section
(Pages 26 and 27).

2. Preparation of a Dredged Materials Disposal Plan for the estuary to designate
acceptable disposal sites and options to accommodate dredging needs for at least a
20-year period.

12

PLAN CONCEPTS AND DEFINITIONS

THE PLANNING/MANAGEMENT FRAMEWORK

The planning and decisionmaking framework of the Estuary Management Plan is contained
within a concept of descending levels of policies. The concept recognizes that one set of
policies applied to the entire estuary cannot provide the type of guidance to individual
property owners nor government in making decisions on permitting uses or activities on
specific sites. Yet to develop policies only at the site-specific level fails to recognize the
implications of those policies to the total estuary. Policies, therefore, must begin with
the total estuary and end with site-specific guidelines. Each level of policy and the size
of the area to which those policies are applied, is more specific than the preceding level.

Estuary Management Goal

In the Grays Harbor Estuary Management Plan, three levels of policies are established.
The first level is a single, broad policy called the Estuary Management Goal. The core of
this goal is the concept of balance in the development and preservation of the estuary as a
whole (see also section entitled Plan Concepts). The Goal, which says that "the Grays
Harbor estuary will be managed for multiple uses" is, of course, very general, and is not a
yardstick which can be used to assess a specific project proposal. Instead, specific project
proposals must be evaluated by looking at the more detailed policies at the second and
third levels of the planning/management framework.

Planning Areas

The second policy level contained in the Grays Harbor Estuary Management Plan is the
Planning Area. The estuary has been divided into eight Planning Areas (see Estuary
Management Plan Map), each representing a common set of natural and man-related
features. The criteria that were used to establish the boundaries for the Planning Areas
include:

land ownership

political jurisdictions

existing uses

areas of existing or possible conflict

physical boundaries or features

13

Planning Areas provide a basis for describing how different areas of the estuary presently
function and how they might function in the future. Each Planning Area is described in
terms of its existing character, its major committed uses, its conflicts and assets.
General guidelines are established for each Planning Area on the management of the
Planning Area's natural resources and on development within the Planning Area.

Management Units

The third policy level in the management plan is the Management Unit. This is the most
specific policy level and is designed to provide guidance to property owners and
government in evaluating project proposals. Forty-three Management Units are contained
in the Estuary Management Plan (see Plan Map). Each unit is given a Management
Category (defined on pages 22 to 23) which carries with it a set of Standard Uses (page
109). The boundaries of each unit are described along with the Permitted Activities and a
general Management Objective. Some Management Units also contain a set of Special
Conditions that relate to that unit only.

DEFINITIONS
Management Units

o Management Unit Boundaries

Most management units run generally parallel to the shoreline. They are defined on the
upland side by the Study Boundary; on the water side by the line of Ordinary High Water;
and on the third and fourth sides by boundaries established whenever possible, by specific
ground or other property features. The diagram below is a further illustration of the basic
management unit boundaries.

Management Unit Boundary

Ordinary High Water

□0 Study Boundary

14

• Split Management Units

The plan has a number of management units that have critical wetland values shoreward
of the line of Ordinary High Water. In these units, additional protection is afforded the
wetlands through the split managment unit concept. The management units have been
split with a third line parallel to the shoreline. Most often, the Corps of Engineers line of
nonaquatic vegetation (Section 404 line) is used to split a management unit although
occasionally other features are used. Splitting these management units has been done to
add special emphasis to their management philosophy and objectives. The split line
separates areas with distinctly different characteristics. In such cases, each split portion
of the management unit has its own management designation.

Ordinary High Water

•"

SpTTTOHit Boundary /{jj^

^ — * '' IMfad(d

^||||HlIll4^u^^Mlm^^^^lMnllMlHrPl m^iV

Study Boundary

S

• In-Water Management Units

While most management units are defined by the line of Ordinary High Water, some units
are tidelands and submerged lands generally within the water area of the estuary. In
these cases, the boundaries of the management units are not exact but are described by
the features that are receiving special management treatment. As an example, the
Whitcomb Flats area is designated as Management Unit 42. There is no attempt to
precisely define the boundaries of that management unit except as it is generally outlined
on the Management Unit Map.

• Management Unit 44

Management Unit 44 is a special unit that includes all the water area not included within
any other designated management unit.

• Special Management Units

Several management units have been given a "Special" classification. This indication is
designed to be used where non-standard conditions exist either in the unit's boundary
definition or where other special circumstances are present. In all cases, the unique
circumstances are covered in a Special Conditions section of the management unit
description.

15

Fills

Erosion Control

This type of fill is designed to preserve the existing bankline or to protect the bankline
from erosion. This fill type is contained in the Bankline Erosion Control Policy. This
policy may only be used where specifically authorized within the Permitted Activities
Table of each management unit.

Special Project Fills

This type of fill is included within the special conditions of specific management units to
deal with specific projects or sites. The fills in Management Unit 12 are an example of
this type of fill. The exact conditions of these fills are spelled out within specific
management units and have been determined through the estuary planning process.

Bankline Straightening

This is a small fill primarily done for the purpose of straightening the bankline to create
more usable uplands for development. Within the estuary planning process it is not
possible to identify all such possible circumstances where this type of fill might be desired
so a Bankline Straightening policy has been developed. Like Bankline Erosion Control, this
policy may only be used where specifically authorized within the Permitted Activities
Table of each management unit.

All other fills that do not fit the preceeding definitions will be disallowed through the
permit process. The term fill, as used in this plan, does not include fills which are needed
to prepare upland sites above the jurisdiction of the Section 404 line of non-aquatic
vegetation. See also, section on Disposal of Wood Waste.

Terms

Many of the definitions in the following material contain terms or phrases that are
somewhat technical in nature, but which conform to specific language contained in
various statutes or regulations. Specific questions relating to some of these terms should
be addressed to the Grays Harbor Regional Planning Commission staff or the state
Department of Ecology or Corps of Engineers.

Access Channel: Creation of a side channel connecting the main navigation with

shoreside facilities including ship berthing.

Activities: Any action taken either in conjunction with a use or to make a use

possible. Activities do not, in and of themselves result in a specific
use. Several activities (for example; dredging, piling, fill) may be
required for a single use.

Bankline: That area of the shoreline that lies above ordinary high water and

may be below the 404 boundary. The bankline can include wetland
areas.

Bankline Erosion

Control: See Page 24

16

Bankline
Straightening:

Boathouse:

Breakwater:

Bridge:
Bulkhead:

Cable and Pipeline
Crossings:

Causeway:

Channel
Maintenance:

Channel
Realignment:

Conditional Use:

See Page 24

A structure built over the water to house boats.

An offshore barrier, sometimes connected to the shore at one or both
ends, to break the force of waves. A structure of rock, piling or
concrete to protect a shore area, harbor or basin.

An overwater structural crossing for the purpose of vehicular,
pedestrian and rail access.

A structure that separates land from water by a vertical retaining
wall. The bulkhead retains earth and prevents sliding as well as
protects the upland against wave damage.

Lines and cables placed in the substrate of a waterway to traverse
the waterway beneath the water.

A filled passageway for vehicle access, often with culverts to allow
drainage or tidal flow through the causeway.

Dredging of shoal materials from an existing navigation channel to
maintain access.

Dredging to relocate an existing navigation channel in the same
waterway. Primarily done to increase safety of navigation, decrease
maintenance or to shorten the total channel length.

An activity or use which generally conforms to the management
objectives of a particular Management Category or management unit,
but because of potential problems inherent with the specific use or
activity, may not be appropriate in every situation. Being "conditio-
nally allowable" assumes that the use or activity is allowable only if
sufficient care is taken to avoid predictable negative impacts through
the application of project/site specific conditions.

Uses and activities classified as conditional may be authorized
provided that all of the following criteria can be satisfied:

1. The proposed use or activity is consistent with the appropriate
Planning Area Guidelines and the Management Objectives of the
specific management unit. Consistency includes both the scope
and scale of the proposed use or activity,

2. The proposed use of the site and design of the project will be
compatible with other permitted uses and activities adjacent to
and within the area,

3. The proposed use or activity will cause no unreasonably adverse
effects to aquatic and shoreland areas,

17

Dike:
Dock:

Dolphin:

Dredging:

Fill:

404 Boundary:

Groin:

Interim Uses:

4. The proposed use or activity will not have substantial adverse
cumulative effects, and

5. There will be no substantial detrimental effects to the public's
interest in the area, including normal public use of the shoreline.

Uses and activities which are authorized as conditional will be
subject to conditions necessary to prevent any undesirable effects
(including limitations to the scope and scale of the proposed use or
activity).

A use or activity may be considered conditional, and thereby
generally consistent with the plan goals, but may not be found
permissible after a specific case review. Despite general consistency
with the plan, a conditional use or activity may be inappropriate
because of the specific circumstances surrounding the proposal or
because of the unique characteristics of the proposal.

In the exceptional case where a proposed use or activity has not in
any way been identified, classified or set forth in the plan, it may be
proposed a conditional use or activity, but may only be authorized if
the above criteria are met, and other applicable state and federal
regulations (including permit requirements) are satisfied.

An earthen embankment or ridge constructed to restrain high waters.

A fixed or floating decked structure against which a boat may be
berthed temporarily or indefinitely.

A group of piles driven close together in water and tied together so
that the group is capable of withstanding lateral forces from vessels
and other floating objects.

Removal and relocation of materials from a waterway or its banks.

See page 16

This is the upward limits of jurisdiction of Section 404 permit as
required by the Corps of Engineers. This boundary is the line
between uplands and wetlands. Detailed guidance for identifying the
boundary is not presently available. Field surveys and vegetation
sampling can establish the boundary (see also section on Relationship
to Local, State and Federal Permitting, page 4).

A shore protection structure (usually perpendicular to the shoreline)
to trap littoral drift or retard erosion of the shore.

Interim use of a site would not result in the alteration of the site in a
manner that would preclude future permanent use and would not
involve significant capital investment in fixed facilities. In general,
significant investments would involve costs that exceeded the cost of
the land or would force the development of major facilities, not
directly associated with the use but whose investment would be
jeopardized if the use were discontinued (e.g. wastewater treatment
plants, major roads, utilities, rail lines, etc.).

18

Jetty:

Mean Low Water
(MLW):

Mean Lower Low
Water (MLLW):

Ordinary High
Water (OHW):

An artificial barrier used to change the natural littoral drift to
protect inlet entrances from clogging by excess sediment and to
direct and confine the stream of tidal flow. Jetties are built at the
mouth of a river or estuary to help deepen and stabilize a channel.

The average of all observed low tides over a 19-year period. The
average is of both the lower low and of the higher low tides recorded
each day over a specific time period.

The average height of the lower low tides observed over a 19-year
interval. The datum plane is used on Pacific Coast nautical charts to
reference soundings. This line appears as a dotted line on NOS
(formerly C&GS) charts between tidelands and submerged lands.

The same as mean high water. 1) the average height of the high
waters (tides) over a 19-year period. All high waters are included in
this area of diurnal tides, 2) this line is the boundary between uplands
and tidelands and is shown as a solid dark line on NOS (formerly
C&GS) charts. In the area near Aberdeen, OHW is 9A feet, at
Westport 8.3 feet, at Montesano approximately 7.5 feet above mean
lower low water.

Outfall:

Permitted Use:

Pier:

Piling:

Riprap:

Discharge or point of discharge of a culvert or other closed conduit
and may also include an open outfall structure for return water from
dredge material disposal sites, cranberry bogs, etc.

A use or activity that conforms to the Grays Harbor Estuary
Management Plan and may be undertaken subject to:

• The general requirement that the use or activity be designed and
constructed in a manner that will minimize, so far as practical,
any resultant damage to both the natural resources of the
affected aquatic and shoreland area, and maintain consistency
with the intent of the goals, policies and standards of the plan,

• Specific policies, standards or special conditions contained in
this plan, and

• Applicable local, state and federal permits and regulations.

A structure extending into the water from solid land for use as a
landing place or promenade for persons and goods to and from vessels
alongside the pier. Sometimes synonymous with wharf.

A long, slender stake or structural element of timber, concrete or
steel which is driven, jetted, or otherwise embedded on and into the
ground for the purpose of supporting a load.

A facing layer of material placed on an embankment to prevent
erosion, scour, or sloughing.

19

Unacceptable
Adverse Impact/
Not Unacceptable
Adverse Impact:

An unacceptable adverse impact is one which will significantly
affect the biological functions of the particular site or of the estuary
as a whole. Whether impacts of a particular use or activity are
unacceptable depends on a comprehensive analysis including the
nature of the proposed use or activity and proposed protective and
mitigative measures.

Where the Plan indicates that certain uses and activities will not
have unacceptable adverse impacts, this determination is made based
on current data and in the context of all of the impacts and
protective measures contained in the Plan. The determination
presupposes that measures will be adopted to control avoidable
adverse impacts, that all special conditions will be satisfied, and that
appropriate permit criteria will be met.

Uplands:

Use:

Vegetation:

Water Area:
Water Dependent:

Water Related:

Areas of shoreland characterized by plants that cannot withstand
periodic or prolonged flooding or saturated soils. These areas do not
support wetland vegetation and are outside Section 404 jurisdiction
(see 404 Boundary definition).

The "end" to which a land or water area is ultimately employed. A
use often involves the placement of structures or facilities for
industry, commerce, habitation or recreation. An accessory use is a
use incidental and subordinate to the main use of the property and
located on the same lot or parcel as the main use.

The general plant cover of an area as differentiated from individual
types (species) of plants. Vegetation includes the numerical
relationships of different species.

That portion of the study area that lies below Ordinary High Water.

A water dependent use or activity cannot exist in any other location
and is dependent on a water location by reason of the intrinsic nature
of its operations. The water location or access must be needed for:

• Water-borne Transportation - navigation, moorage, fueling and
servicing of ships or boats, terminal and transfer facilities,
resource and material receiving and shipping; or

• Public access; or

• A Source of Water - for facilities necessary for water
withdrawal.

A water related use or activity is not intrinsically dependent on a
waterfront location. A use or activity is water related if:

• It provides goods or services that are directly associated with
water dependent uses, such as supplying materials or services to
or using products of water dependent uses; or

20

Wetlands:

• It gains substantial cost savings or revenue-differentiating
advantages (not associated with land cost or rents) from being
located on the waterfront that it could not obtain from an inland
location, or

• A location other than adjacent to the water would result in a
public loss of quality in the goods and services offered, consi-
dering the economic, social and environmental consequences of
the use.

Water related uses and activities are not differentiated from non-
water dependent uses by federal regulations or guidelines. The
application of federal regulations or guidelines to such uses will
therefore be done as though they were non-water dependent.

The term "wetlands" means those areas that are inundated or
saturated by surface or ground water at a frequency and duration
sufficient to support, and that under normal circumstances do sup-
port, a prevelance of vegetation typically adapted for life in satu-
rated soil conditions. Wetlands generally include swamps, marshes,
bogs and similar areas (40CFR230, 24 December 1980).

By definition, wetlands are considered to be "waters of the United
States", and are thereby within the jurisdiction of the Corps of
Engineers to regulate the discharge of dredged or fill materials into
those waters.

Wharf:

A structure built alongside a waterway for the purposes of receipt,
discharge and storage of goods and merchandise from boats.

21

GENERAL POLICIES

MANAGEMENT CATEGORIES

The final Department of Ecology Guidelines for the implementation of the State Shoreline
Management Act, identify four "environment types" that would be used by local
government in developing their local Shoreline Master Programs. Those four environ-
ments - natural, conservancy, rural and urban - have been expanded into eight manage-
ment categories within the Grays Harbor Estuary Management Plan. The following
paragraphs identify the management categories along with a general statement of their
purpose.

N Natural

Purpose: The Natural management category is intended to preserve and/or restore
designated natural areas to their natural or original condition. Such areas are designed to
remain relatively free of human influence and have severe restrictions on the intensity
and type of use that is allowed.

The primary determinant for designating an area as Natural is the actual presence of an
important natural feature which is intolerant of intensive human use.

CN Conservancy Natural

Purpose: The Conservancy Natural management category is designed to be used to
preserve and restore areas to their natural condition. Direct human influence in such
areas will be minimal. The primary emphasis of Conservancy Natural is to ensure that
future uses and changes that occur within the area are designed to enhance rather than
degrade the natural characteristics of the area.

CM Conservancy Managed

Purpose: The Conservancy Managed management category classification is designed to
protect areas for purposes that directly use or depend on natural systems. While it is not
intended that such areas will be preserved in their natural state, the activities which
occur in these areas should be compatible with the natural systems.

Managed is the key word in this classification. It is the intent of this classification to
allow uses which depend on the natural ecological system for production of food for
recreation, for recognized scientific research, or for public access for recreational uses.
Recreation uses will be water dependent and designed to maintain the quality of the
natural elements of the area.

22

RA Rural Agricultural

Purpose: The Rural Agricultural management category is intended to protect existing and
potential agricultural land from the pressures of urban expansion and Rural-Low Intensity
development. Agricultural uses include intensive cultivated practices that are dependent
on regional, national and international markets and includes agricultural food crops as
well as tree farming.

Residential development will be limited to one dwelling per 10 acres.

RL Rural Low Intensity

Purpose; The Rural Low Intensity management category is intended to be used to restrict
intensive development along undeveloped banklines and maintain open spaces and opportu-
nities for recreational uses that are compatible with a general rural character.

Agricultural uses are possible within the Rural Low Intensity category although it will
relate more to local markets or individual subsistence farming.

Residential development within Rural Low Intensity areas will be limited to densities that
do not exceed one dwelling per five acres.

UR Urban Residential

Purpose: The Urban Residential management category is intended to protect areas in
which the predominant use is or should be residential. The Urban Residential category is
designed to maintain or ensure the maintenance of a residential character in the
development of a designated area in terms of density, scale and the general types of
activities permitted.

Public water access and limited local service commercial uses are appropriate within
Urban Residential areas.

UM Urban Mixed

Purpose: The Urban Mixed management category is to designate areas in which there is
or should be a mix of compatible urban uses. In general, residential densities will be
higher than those of rural areas; industrial and commercial uses will be service or
community oriented; public access to the water area will be encouraged for recreation
purposes.

UD Urban Development

Purpose: The Urban Development management category is intended to designate areas in
which the predominant uses are or will be industrial, and commercial development. The
intent of the designation is to provide for efficient utilization of such areas primarily for
water-dependent/water-related commerce and industry that are directly related to the
region's basic economic sectors.

23

BANKLINE EROSION CONTROL

Within each management unit description, the Permitted Activities Table identifies where
the following policies will be applied.

Activities permitted within these policies include riprapping and minor straightening and
sloping of the bankline as required to stabilize upland areas and prevent accelerated
erosion processes.

1. Materials to be used shall be of nonerodable quality that will allow long term
stability and minimize maintenance.

2. Riprap/bank stabilization procedures shall be confined to those areas where active
erosion is occurring or new development or redevelopment requires protection for
maintaining the integrity of upland structures or facilities.

3. Only clean materials may be used. Materials which could create water quality
problems or which will rapidly deteriorate are not permitted.

4. Minor modifications of the bankline may be permitted on a case-by-case basis.
These alterations shall be for the purpose of stabilizing the bankline, not for the
purpose of developing new upland areas.

5. Under no circumstances shall bankline erosion control be initiated for the purpose of
gaining developable uplands from existing water areas.

6. All projects shall be constructed in a manner to minimize turbidity.

7. In all cases, restoration of the bankline through removal and prevention of debris
and solid waste build-up will be encouraged.

8. The use of concrete slabs will not be permitted for bankline erosion control unless
the concrete is broken into pieces no larger than 10 square feet in surface area and
placed in a manner so as to preclude slumping and displacement. It is not the intent
of this section to preclude the use of old concrete but rather to ensure that when
used it will accomplish the same purpose and have the same qualities as natural
material.

9. The outer slope of the bankline after completion of the erosion control will not
exceed a slope of 2:1.

10. Use of vegetation for bankline stability is required where technically applicable and
is encouraged in conjunction with structural forms of erosion control.

BANKLINE STRAIGHTENING

In specifically designated "urban" management units (identified in the Permitted Activi-
ties Table of the management unit), small fills may be allowed for the purpose of
straightening the bankline to consolidate uplands for development.

2k

In general, management units so designated have been found to represent the best
alternative areas within the estuary for maximum and efficient utilization of the uplands
and bankline for water dependent and water related uses. In these cases, consolidation of
the upland areas through minor filling to straighten the bankline is seen as the means to
promote efficient and effective use of the bankline areas. Where applied, the environ-
mental impacts of such fills have not been found to be unacceptable, particularly in view
of the broader objectives of the specific management units. In addition to the normal
requirements for a federal Section 404 permit (see Relationship to Local, State and
Federal Permitting), the following criteria will apply to instances where Bankline
Straightening is permitted:

1. This policy will be applicable only in specified management units and as required in
adjacent Management Unit 44.

2. Bankline straightening can only occur between two exisiting points of land as
defined by the limit of Corps jurisdiction, and when complete, the new line of Corps
jurisdiction will be a straight line connecting these two points of land.

3. The maximum permitted fill within this policy is two acres measured from the Line
of Non-Aquatic Vegetation (Section 404) and includes the areas defined as wetlands
and is measured to the toe of the fill.

4. Two or more fills permitted under this policy may not be accumulated at the same
or a portion of the same site.

5. Any projection beyond the permitted fill must be by a structure.

6. The outer slope of the fill will not exceed a slope of 2:1. However, a greater slope
may be permitted if conditions warrant and the design is approved by state and
federal resource agencies.

7. Broken concrete of sizes not to exceed 10 square feet and placed in a manner so as
to preclude slumping and displacement is permitted along the fill slope.

8. Materials to be used on the fill slope shall be of non-erodable quality that will allow
long-term stability and minimize maintenance.

9. Only clean materials may be used for the fill and fill slope. Materials which could
create water quality problems or which will rapidly deteriorate are not permitted.

10. All projects shall be constructed in a manner to minimize turbidity.

11. Use of vegetation for bankline stabilization is required where technically applicable
and is encouraged in conjunction with structural forms of erosion control.

STANDARD USES

Each Management Category contains a set of Standard Uses that are either permitted,
allowable by special conditions or are not permitted under the plan. Each management
unit is assigned a management category which automatically brings with it a set of
standard uses. The Standard Uses Table matches management categories with uses.

25

LOG RAFTING

Log rafting may be permitted in areas where it occurs on the map (see Map in the
Appendix) provided that log grounding does not occur within those areas. If log grounding
occurs, the log rafting may continue as a non-conforming use subject to the following
conditions:

1. Any modification or replacement of existing structures or practices can only be
approved if such modifications will result in a net reduction of the incidence of log
grounding, and

2. If such log rafting is discontinued for a period of time exceeding one year, it will not

be allowed to resume.

j

Expansion of log rafting into new areas can only be permitted if it is demonstrated that no
grounding will occur, there will be no significant modification of the aquatic environment,
excessive debris will not accumulate, and other environmental impacts are minimized.
Special consideration will be given to such expansion if it will reduce the incidence of
grounding at an existing area.

MITIGATION

As previously noted, balance is one of the important concepts of the plan. In developing
the goals, policies and standards of the plan, the planning process established a balance
between protecting the integrity of the natural systems and its resources, and allowing for
the long term maintenance and development of the region's economic base. To a degree,
that balance was achieved by allowing both objectives to be met within the total estuary,
with the acceptance of some site-specific economic and resource impacts in return for
opportunities for resource protection and economic development on an estuary-wide basis.

In striking the balance, the planning process also recognized that it could not foresee all
possible circumstances and so allowed for changes through the plan amendment process
(see also Plan Review and Amendment). Any amendment to the Plan must maintain its
balance. In some instances, it is possible that a plan amendment might not be allowed
because of its adverse effect on the balance of the Plan. In other instances, it may be
possible to preserve the balance of the Plan through mitigation of adverse effects.

There are three mitigation concepts used in this plan. The first involves the creation,
restoration or enhancement of an estuarine area to maintain the functional characteris-
tics and processes of the estuary. The second is somewhat of a variation on the first
where a creation, restoration or enhancement project involves multiple actions over time.
The third involves the "banking of estuarine lands" for the permanent protection of their
resources.

In mitigation actions to create, restore or enhance the estuary, the emphasis includes (but
is not limited to) maintaining the natural biological productivity of the estuary;
maintaining the diversity of species and habitats; maintaining the tidal prism; maintaining
the quality of estuarine waters; and, maintaining the integrity of unique features within
the estuary.

26

Mitigation projects involving multiple actions are generally large in size and/or dollar
scope and may also involve actions that should be done over a relatively long period of
time. In such cases, the project is initiated through one mitigation action and is continued
with subsequent additional actions (e.g., the addition of more land, regrading a restoration
area, cash payments to support continued mitigation actions, etc.) that result from other
situations where mitigation is deemed necessary. While this is not truly a different form
of mitigation, it is a different way to implement a creation, restoration or enhancement
mitigation project. It has the advantage of allowing a very large resource project to be
undertaken without a corresponding large development action. Additionally, very small
mitigation requirements can be met without the necessity for a complete mitigation
project.

Mitigation projects involving the banking of estuarine lands represent a different
philosophic approach to mitigation. Whereas the first two forms of mitigation emphasize
the replacement or enhancement of the estuary's biologic characteristics, this latter form
of mitigation works to achieve permanent protection of the resource. In such actions, the
emphasis is on lands immediately adjacent to development areas which may be subject to
pressure for conversion to development uses; lands with high resource values; lands with
unique resource characteristics; and, lands in resource scarce areas.

In choosing areas, sites or actions as possible mitigation projects for plan amendments or
other changes that would upset the balance of this plan, the following priorities will be
used:

Priority Areas, Sites, Actions

BIOLOGICAL MITIGATION

1 areas in general proximity to the proposed alteration,

2 other areas according to their similarity in characteristics to the proposed
amendment area - characteristics include salinity regime, tidal exposure,
substrate type, hydrology, solar orientation,

3 areas or resources which are presently in greatest scarcity compared to
their past abundance and distribution,

NON-BIOLOGICAL MITIGATION

k areas directly related but indirectly connected to estuarine systems, and

5 estuarine land banking.

A local/state/federal mitigation team will prepare a Mitigation Plan for the Grays Harbor
Estuary that will include a definition of potential mitigation projects that meet all three
mitigation concepts. Prior to the completion of that plan, the mitigation team will define
needed mitigation actions on a case-by-case basis.

Mitigation actions developed to address the balance of the Plan are not the only habitat
restoration or improvement proposals which may be considered or implemented in the
estuary. Additional actions to restore or improve fish and wildlife habitat (e.g.,
restoration of diked habitat, marsh creation) are possible, but should be reviewed and
coordinated with mitigation actions under the Plan to assure that they are complemen-
tary.

27

DISPOSAL OF WOOD WASTE

Disposal of wood waste, and other solid waste material, in areas under the jurisdiction of
the Shoreline Management Act is not permitted unless the primary purpose for creating
the fill is for a use other than waste disposal. Proposals to use wood waste in combination
with other fill material to create an upland development site may be permitted and will
be evaluated on a case-by-case basis.

28

PLANNING AREAS
DESCRIPTIONS AND GUIDELINES

PLANNING AREA I
Area Description

• Predominant Character

The predominant character of Planning Area I is natural, with a major influence from the
fresh water system of Chehalis River. It is an area of limited access and sparse
development.

• Major Committed Uses

The predominant use of the planning area is for hunting and fishing as well as
nonconsumptive resource use (wildlife observation). Secondary committed uses include
the gravel extraction operations and agricultural areas in the upriver portions of the
planning area.

• Major Existing or Potential Conflicts

No major conflicts exist within the planning area. Potential conflicts exist with industrial
development pressures in the western portion behind the Junction City area and with
possible development proposals for the many small parcels that exist in the area. Such
proposals would conflict with the predominant character and use of the area. It is not
believed that continued operation of the gravel extraction facility at its present location
poses a major conflict.

• Planning Area Assets

The majority of the planning area is important as a water containment area. It operates
as a storage area for flood waters from up-river areas as well as tidal surging. In
accommodating this hydrologic function, it serves as a valuable area for water fowl
nesting and for recreation hunting and observation. The river corridor is a necessary area
for fish passage and rearing.

Planning Area Guidelines

Management of the Natural Resource

• Bankline

The bankline within Planning Area I will be maintained in its natural configuration except
as specifically provided through other guidelines and policies.

29

• Water Area

The water surface area will remain in its present configuration or as allowed by other
guidelines and policies.

• Water Quality and Hydraulics

Any alterations to this planning area should not detract from its ability to function as a
water storage area. Existing high levels of water quality will be maintained.

• Fish and Wildlife

Fish and wildlife resources will be managed to maintain or enhance their present
condition.

• Vegetation

Selective harvesting of timber resources will be allowed within the planning area. Such
activities will not detract from other planning area guidelines and will adhere to accepted
forest harvesting practices. All other vegetation including marsh areas will be maintained
in their present condition.

• Aggregate Minerals

Aggregate resources have a long-term importance to the economy of the area. Aggregate
extraction within the planning area will be allowed to continue within the guidelines of a
reclamation plan and in accordance with practices that are consistent with other planning
area guidelines.

Development Within the Planning Area

• Economic Base

The planning area provides indirect support to the local and regional economy through
recreational hunting and fishing. Additionally, it provides secondary support to the
commercial fisheries industry as a fish rearing area. These two roles are important to the
Grays Harbor community and should be maintained. Both the eastern and western
portions of the planning area provide limited opportunities for industrial or agricultural
development. These should be considered transitional only to uses in adjacent planning
areas and should not detract from the ability to achieve other planning area guidelines.

• Use Character

The general, natural unaltered character of the planning area should be maintained. Any
deviation from that character should occur only at the eastern or western boundaries.

• Recreation

The current level of recreation use should be maintained with no general increases in use
intensity. Limited additional pedestrian access may be possible but without supporting
facilities (parking areas, roads, etc.).

30

• Resource Harvesting

Existing aggregate extraction along with selective timber harvesting will be allowed
within the constraints of other planning area guidelines.

• Navigation

The river surface and supporting navigation channel are important to the regional
economy. Continued maintenance of the channel at its present depth is consistent with
the character of the planning area. Any dredging done in conjunction with the authorized
channel shall be consistent with other planning area guidelines.

• Structures and Fills

In general, filling within the planning area is inconsistent with the character of the area
and with other guidelines except for limited bankline maintenance. In-water structures
are also inconsistent with the character and guidelines of the area except for limited
personal boat docks. Upland filling and structures including regional public facilities, may
be acceptable on a case-by-case basis provided they do not detract from other planning
area guidelines.

PLANNING AREA H
Area Description

• Predominant Character

Planning Area II is a high intensity, urban area with a mix of industrial, commercial and
marine uses. The mix of uses is more oriented to urban commercial than to heavy
industry although some heavy industry is present. Much of the character of the planning
area is formed from the convergence of highway, rail and water transportation systems.

• Major Committed Uses

In addition to existing industrial, urban commercial and marine uses, the planning area is
also an important fish passage, rearing and feeding area; it provides a commercial fishery
on migrating fish; some waterfowl nesting areas exist in the southwestern portions; log
storage areas and industrial waste discharge occur within this area; and major regional,
north/south transportation linkages exist in this planning area. Some upland dredged
material disposal sites exist in this area.

• Major Existing or Potential Conflicts

The primary conflicts occur as a result of the demands of urban development and the
needs of the water system to support fish passage, resting and feeding. As the focal point
for development and transportation, high demands are placed on the water system and
thereby the quality of the water. As the focal point for fish migration, water quality is a
critical factor for fish movement and in-transit feeding.

31

• Planning Area Assets

The area has good connections to all major regional transportation systems; although
somewhat limited, back-up land for industrial and commercial development is available in
portions of the south shore; relatively low channel maintenance requirements exist
through most of the planning area because of good currents; some relatively productive
feeding and rearing areas do exist for crab and fish, particularly in the western portion of
the planning area.

Planning Area Guidelines

Management of the Natural Resource

• Bankline

Generally, the bankline should be intensively developed with the most intensive uses in the
central and northwestern portions of the planning area. Redevelopment is an important
management and development strategy in this planning area as little undeveloped land
presently exists.

• Water Area

The primary function of the water area is transportation for both marine vessels and fish.
Alteration of the water surface area is possible provided that it does not detract from the
navigation capacity of the corridor or fish movement. A more natural bankline along the
western portions of the south shore will be maintained to ensure adequate areas for fish
feeding.

• Water Quality and Hydraulics

Any new or redeveloped uses within the planning area will be required to meet water
quality standards. Waste discharge should not cause a degradation in the existing water
quality and should be balanced against the assimilative capacity of the area. New
discharges should also be evaluated against any detrimental effects they might have to
the waste treatment efforts of existing industry.

• Fish and Wildlife

Except for the southwestern portion, this planning area is not considered a prime fish or
wildlife area. An active wildlife and fishery management program in all but the
southwestern area is not consistent with the overall character of the area although the
fish and wildlife resource is important, particularly as it supports other areas of the
estuary and river system.

t Vegetation

The salt marsh areas on the south shore are important for food production for fish moving
through the planning area. The riparian vegetation adjacent to Charley and Newskah
Creeks is important and should be protected but will not be actively managed.

32

• Aggregate and Minerals

While no known aggregate or mineral deposits exist within the planning area, utilization of
upland areas for aggregate reclamation of dredge materials is considered generally
consistent with the overall character of the planning area.

Development Within the Planning Area

• Economic Base

This planning area is the focal point for a large regional area particularly as related to
regional transportation systems. Commercial and industrial uses that depend upon and
directly support the needs of the regional market are seen as appropriate to this planning
area. Additionally, the passage of fish through this area to and from up-river feeding,
spawning and rearing areas, is an important link to the commercial and sport fisheries
industry.

• Use Character

The overriding character of the planning area is that of high intensity urban development
that is consistent with other planning area guidelines.

• Recreation

Recreation use within the planning area is an important but not dominant use. Existing
recreational water access should be maintained and improved with additional access
developed. Opportunities to use the visual qualities of both the water and industrial
activities will be encouraged.

• Resource Harvesting

Resource harvesting is not a primary activity within this planning area, but is acceptable
provided it is consistent with other planning area guidelines.

• Navigation

Continued use of the water surface and corridor for navigation has high priority within the
planning area.

• Structures and Fills

In-water and shoreline structures are permissible in this planning area although their use
in the western portions of the south shore will be restricted. In all cases, in-water
structures are preferred to fills.

33

PLANNING AREA III
Area Description

• Predominant Character

Planning Area III is a mixture of urban-industrial development and natural resource areas.
The predominant developed character is heavy industrial and port facilities. Within the
natural resource areas, the character is tide flats and salt marsh.

• Major Committed Uses

Committed developed uses include: major industrial and port development, regional air
and rail transportation, upland log storage, and dredged material disposal. Committed
resource uses include: water fowl and shore bird resting, feeding and rearing areas, fish
rearing and passage, crab rearing and commercial fishing.

• Major Exising or Potential Conflicts

The primary conflicts exist between demands for the development of new industrial areas
and the loss of fish and wildlife habitat that would result from filling and dredging. There
is also a potential for a similar conflict if the area is used for dredged materials disposal
associated with both channel deepening and maintenance.

• Planning Area Assets

The planning area represents the prime area remaining for large industrial expansion in
immediate proximity to the navigation channel, land-based transportation facilities, other
urban facilities and a local labor force. At the same time, it represents an area of high
food production for water fowl, shore birds, crab and fish.

Planning Area Guidelines

Management of the Natural Resource

• Bankline

In the eastern portion of the planning area, the bankline will continue to be used in a
highly altered condition. While the bankline in the central portion will be altered
somewhat through upland development, much of its present configuration will remain
unaltered. Along the north shore, the riprap along the road and rail line will remain. The
bankline in the Rennie Island area will be managed in accordance with it short and long-
term management unit policies.

• Water Area

The water area serves as a primary transportation corridor in the south and as a natural
resource area north of the airfield. The primary alteration of the water surface will
occur west of the airfield and in specific, locations along the north bankline and adjacent
to the navigation channel.

34

• Water Quality

Any new or redeveloped uses within the planning area will be required to meet water
quality standards. Waste discharge should not cause a degradation in the existing water
quality and should be balanced against the assimilative capacity of the area. New
discharges should also be evaluated against any detrimental effects they might have to
the waste treatment efforts of existing industry.

• Fish and Wildlife

This area is considered to have some of the prime fish habitat in the estuary. Of
particular importance will be the protection of fish and shellfish migration and feeding
areas along the shoreline, north of the navigation channel. Additionally, the Rennie Island
area will serve as a potential location for future wildlife habitat development and
enhancement.

• Vegetation

The vegetation in the Rennie Island area and most of vegetation north of the airfield will
be preserved consistent with Special Conditions sited in the Management Unit.

• Aggregate and Minerals

While no known aggregate or mineral deposits exist within the planning area, utilization of
upland areas for aggregate reclamation of dredge materials is considered generally
consistent with the overall character of the planning area.

Development Within the Area

• Economic Base

This planning area is the central area for major economic expansion within the Grays
Harbor region. As such, use of the land and water areas will be primarily for heavy
industry directly related to the region's basic economic sectors.

• Use Character

The overriding character of the planning area is that of high intensity urban development
that is consistent with other planning area guidelines.

• Recreation

Recreational use is generally not associated with the overall character of the area.
However, compatible recreation activities should not be precluded.

• Resource Harvesting

Resource harvesting is not a primary activity within this planning area, but is acceptable
provided it is consistent with other planning area guidelines.

• Navigation

Continued use of the water surface and corridor for navigation has high priority within the
planning area.

35

• Structures and Fills

In-water and shoreline structures are permissible within this planning area. Fills are
permitted within this planning area but only as allowed under specific management unit
guidelines.

PLANNING AREA IV
Area Description

• Predominant Character

The predominant character of Planning Area IV is aquatic (water as opposed to land), with
heavy tidal influence and low intensity development.

• Major Committed Uses

The use of the area is mixed, with substantial commitments to commercial fishing, oyster
production and crab and fish rearing. Additional important uses include hunting and
recreational fishing, wildlife observation and sparse upland development, including some
agricultural products' processing.

• Major Existing or Potential Conflicts

The planning area is relatively free of conflict except for the potential effects of
navigation channel dredging and spoiling on adjacent oyster rearing areas. This is
particularly true in the Whitcomb Flats area of the realigned channel. The ability of the
area to maintain its natural productivity and continue to assimilate up-river waste
discharge could be a long-term conflict.

• Planning Area Assets

The planning area contributes substantially to commercial and sport fishing and to
shellfish productivity. Its large water area allows it to play an important role in waste
assimilation. Finally, the area is without substantial development pressures.

Planning Area Guidelines

Management of the Natural Resources

• Bankline

The majority of the bankline within this planning area at present is unaltered and should
remain so. Minor alterations for erosion control and maintenance of adjacent facilities
are permitted. No substantial alterations from the natural configuration will be
permitted.

36

• Water Area

Any alteration of the water area is discouraged unless it will contribute directly to the
enhancement of the fisheries resource or the waste assimilative capacity of the area.

• Water Quality and Hydraulics

This planning area serves a particularly important function in assimilating waste discharge
for the upper estuary areas. Any new or redeveloped uses within the planning area will be
required to meet water quality standards. Waste discharge standards should not cause the
degradation of existing water quality and should be balanced against the assimilative
capacity of the area. New discharges should also be evaluated against any detrimental
effects that they have to the waste treatment efforts of existing industry.

• Fish and Wildlife

This planning area is one of the prime fisheries and wildlife feeding and harvesting areas
in the estuary. Active management programs for fisheries and habitat enhancement
should be encouraged in this area. Portions of the planning area suitable for aquaculture
should be protected and reserved for such uses. Whitcomb Flats area should be managed
as a potentially valuable oyster rearing area.

• Vegetation

Existing vegetation should be maintained throughout this planning area. The saltmarsh
and marsh areas in the Johns River area in particular should be preserved in their existing
state without alteration.

• Aggregate and Minerals

Although aggregate or mineral deposits are known to exist within the planning area,
mining is not compatible with the character of the planning area.

Development Within the Planning Area

• Economic Base

The planning area directly contributes to the local and regional economy through
commercial fish harvest and indirectly through production of fish and wildlife. Additi-
onally, the area provides recreational hunting and fishing for both the local and regional
recreationalist. The cranberry processing plant in the Markham area, although a
relatively small employer, is a critical link in the northwest cranberry industry and should
be continued.

• Use Character

The general character of the planning area is rural, large expanses of tidelands, and low
intensity development. Any change in the intensity of the use of the area would be
inconsistent with its predominant character.

37

• Recreation

The present recreational use of the planning area should be encouraged, with no general
increase in the intensity of the use. Opportunities for wildlife viewing should be
encouraged.

• Resource Harvesting

Selected timber harvesting will be allowed within constraints of other planning area
guidelines. Commercial fishing is recognized as important resource harvest activity in
the planning area as is oyster rearing and other aquaculture interests.

• Navigation

The water surface is an important transportation route and fishing use area for
commercial fishing and sport fishermen. Navigation aids should be maintained for these
shallow draft vessels.

• Structures and Fills

In general, filling within the planning area is inconsistent with the character of the area
unless it will enhance the fisheries or wildlife habitat. Bank protections, navigational aids
and in-water navigational mooring facilities are acceptable providing they meet the other
planning guidelines for the area. Upland filling and structures are acceptable providing
they are consistent with other planning area guidelines.

PLANNING AREA V
Area Description

• Predominant Character

The predominant character of the planning area is natural, aquatic with heavy tidal
influence. Along with Planning Area VII, this is the least disturbed planning area in the
estuary.

• Major Committed Uses

Primary uses within the planning area include resource production and harvesting.
Specific uses include: oyster and fish rearing, water fowl and shore bird resting, feeding
and rearing, recreation and commercial harvesting of fish, shellfish, and wildlife, and
uplands agriculture.

• Major Existing or Potential Conflicts

The only foreseeable conflict is with upland residential development pressures in the
northwestern portions of the planning area.

38

• Planning Area Assets

The planning area contains the largest water surface within the estuary. Additionally, it
contains the largest population of water fowl and shore birds, one of the estuary's largest
fisheries and a substantial amount of the oyster rearing and harvesting in the estuary.
Perhaps its greatest asset is that it lacks conflicts.

Planning Area Guidelines

Management of the Natural Resources

• Bankline

The bankline in this planning area will be maintained in its natural configuration. Bank
protection and minor bank modification for erosion control will be permitted.

• Water Area

The water area should be maintained in its present configuration.

• Water Quality and Hydraulics

Existing high levels of water quality will be maintained to ensure continued oyster
production and high fishery and wildlife production values currently enjoyed in the area.
Any major alterations to the estuary bed will be designed to prevent detrimental effects
on estuary hydraulics.

• Fisheries and Wildlife

Fish and wildlife resources are of extremely high value in the area and will be actively
maintained and managed to ensure existing levels. Oyster production will be encouraged
throughout the planning area. The Goose and Sand Island Refuges should be maintained.

• Vegetation

Selective harvesting of timber resources will be allowed in the planning area provided it
does not detract from other planning area guidelines, utilizes accepted forest harvesting
practices, and is consistent with other applicable regulations. All other vegetation,
including marsh areas, will be maintained in their present condition with a particular
emphasis on riparian vegetation.

• Aggregate and Minerals

Although deposits of minerals and aggregates are known to exist in the planning area,
their extraction will be discouraged unless directly associated with navigational mainte-
nance needs.

Development Within the Planning Area

• Economic Base

The planning area provides direct support to the local and regional economy through
recreational hunting and fishing, commercial fishing, oyster production, and agriculture.

39

It provides secondary support to the natural resource, fishery and wildlife resource base
through fish rearing and habitat areas. These roles are important and should be
maintained. Existing agricultural land in the cranberry area and small farming area are
considered compatible to the area and should continue.

• Use Character

The natural aquatic tideflat character of the area should be maintained along with the
generally low intensity of use.

• Recreation

The present recreation use of the planning area should be maintained with no general
increase in the intensity of the use. Passive recreational development related to wildlife
viewing or hunting and fishing is compatible with the area and should be encouraged. High
intensity recreational development should be discouraged.

• Resource Harvesting

Commercial fishing and oyster culture should be encouraged and continued as should sport
fish and wildlife harvest. Selected timber harvesting will be allowed within the
constraints of other planning area guidelines.

• Navigation

The major shipping channel in the southern portion of the planning area is a major
transportation corridor and should be maintained. Navigational aids in the remainder of
the planning area for shallow draft vessels should be maintained where appropriate.

• Structures and Fills

In general, structures and fills within the water area are inconsistent with the character
of the area, except for limited personal boat docks. In-water structures are also
considered inconsistent with the area except as necessary for navigational aids and
limited bankline maintenance. Upland filling and structures may be acceptable if they do
not detract from other planning area guidelines.

PLANNING AREA VI
Area Description

• Predominant Character

The character of this planning area is a mixture of urban, residential/recreational and
estuarine. While there is substantial urban development with homes, homesites, a marina
and other businesses, the area also contains areas of more natural, estuarine influence.

• Major Committed Uses

Primary committed uses within the planning area include the Oyhut Wildlife Recreation

40

Area, the Ocean Shores marina, developed homes and homesites, recreational hunting and
fishing, passive recreational/water use on large areas of publicly owned waterfront lands,
the north jetty and oyster rearing and harvesting.

• Major Existing or Potential Conflicts

Most conflicts relate to the continued development of the residential/recreational uses in
the City of Ocean Shores and the preservation of unique or important natural areas along
the shoreline. The major specific conflicts are with the proposed relocation of the Ocean
Shores airport to a site along the shoreline and with the marina entrance channel
maintenance dredging.

• Planning Area Assets

A principal asset of this planning area is it ability to absorb a substantial amount of the
long-term demand for recreational/residential development and destination tourism. It
also contains areas that contribute to the total productivity of the estuary and unique
areas (such as the Oyhut Refuge) that have permanently preserved natural assets. Its
proximity to the ocean is also considered an asset.

Planning Area Guidelines

Management of the Natural Resources

• Bankline

The existing bankline within the planning area contains major structural modifications
associated with the north jetty, bank protection devices, and the Ocean Shores marina.
Continued maintenance of these facilities is consistent with other guidelines for this
planning area. Other planning area banklines will be managed as a finite resource,
maintaining a natural configuration to as great an extent as possible.

• Water Area

In general, the existing water area will remain in its present configuration. Minor
alterations for jetty and marina maintenance will be permitted.

• Water Quality and Hydraulics

Any alteration of the planning area should not detract from existing high water quality.
Any modifications to the estuary bed will be designed to prevent detrimental effects on
estuary hydraulics.

• Fish and Wildlife

Fish and wildlife resources will be managed at or above the present level. The Oyhut
Wildlife Recreational Area will continue to be an area of high priority for active wildlife
management.

• Vegetation

Significant riparian vegetation and marsh and saltwater marsh exist throughout the
planning area. Alteration of these areas should be minimal and selective. Any alteration
to present vegetation should not detract from the overall character of the vegetation in
the planning area.

41

• Aggregate and Minerals

Mining of materials or aggregates will be discouraged unless directly associated with
navigation maintenance.

Development Within the Planning Area

• Economic Base

The planning area provides a direct support to the local and regional economy through the
recreation industry. The planning area serves as a portion of one of the two destination
recreation centers in the Grays Harbor area. Its recreation role is more passive in
relation to the estuary and other water areas than is in Planning Area VIII, although the
Ocean Shores marina area does contribute to the sport and commercial fishing industries.

• Use Character

The use character of the planning area is a mixture of urban residential, recreational and
estuarine. The character of the southern and western areas is marine, open sea. This
mixed character should be maintained as it represents one of the planning area's primary
assets.

• Recreation

The planning area is a major destination recreation center for western Washington.
Permanent facilities to accommodate this demand should be maintained and selective
additional facilities developed in a manner that is consistent with other guidelines.
Active and passive recreation should be encouraged in all areas.

• Resource Harvesting

Major resource harvesting in the area associated with sport and commercial fishing should
be continued.

• Navigation

The southern portion of the planning area includes the main harbor navigation channel.
This vital transportation link to the upper estuary should continue to be maintained. The
navigation channel into the Ocean Shores Marina is consistent with the character and
guidelines for the planning area and should be maintained.

• Structures and Fills

In general, in-water fills and structures are not consistent with the overall character of
the planning area except as required to maintain existing facilities.

42

PLANNING AREA VII
Area Description

• Predominant Character

The predominant character of the planning area is natural.

• Major Committed Uses

In addition to a substantial fish and shellfish resource and wildlife habitat, the area is
committed, through private clubs, as a major private recreational area for hunting and
wildlife observation. The small residential area of Bay City is also a part of this planning
area.

• Major Existing or Potential Conflicts

The planning area is relatively free of conflicts although maintenance of the authorized
channel could create pressures for uses that would be inconsistent with the predominant
character of the area.

• Planning Area Assets

The principal asset of the planning area is that it is a relatively undisturbed natural area
with no conflicts or pressures.

Planning Area Guidelines

Management of the Natural Resources

• Bankline

The bankline in the planning area will be maintained in its present natural condition
except those areas immediately proximate to the highway, bridge and erosion tidegates.
Necessary maintenance of existing facilities will be permitted.

• Water Area

The water area will remain in its present configuration. Any reduction of the existing
water area, unless directly related to increased production of fish and wildlife, is not
consistent with the area's character or role within the estuary.

• Water Quality and Hydraulics

Existing high levels of water quality will be maintained. Any use which would reduce
existing water quality would not be compatible with the long-term use of the area.

• Fish and Wildlife

Fish and wildlife resources will be actively managed to maintain and enhance their
current levels. Such programs will encourage aquaculture (including oyster production).

43

• Vegetation

Selective harvesting of timber resources will be allowed within the planning area,
provided it does not detract from other planning area guidelines and utilizes accepted
forest harvesting practices. All other vegetation, including all marsh areas, will be
maintained in their present condition.

• Aggregate and Minerals

The mining of aggregate and mineral resources in this area is not compatible with other
planning area guidelines.

Development Within the Planning Area

• Economic Base

The planning area provides direct support to the local and regional economy through
recreational hunting and fishing. Additionally, it provides secondary support to the
commercial fisheries industry as a fish and oyster rearing area. These two roles are most
important to the Grays Harbor region and should be maintained. The planning area also
provides a unique role to the recreation industry through the private hunting clubs. Those
uses should be encouraged and continued.

• Use Character

The general natural, unaltered character of the planning area should be maintained. Any
deviation from the existing character is possible only on the eastern and northern
extremes of the planning area, and then only in the uplands or areas immediately adjacent
to the highway. No substantial developed uses should occur within this planning area.

• Recreation

The current level of recreation use should be maintained with no general increase in use
intensity. Limited additional pedestrian access may be acceptable but without major
supporting facilities. Existing private duck clubs and facilities are compatible uses in the
planning area.

• Resource Harvesting

Timber harvesting will be allowed within the constraints of other planning area guidelines.
Commercial and recreational fishing and hunting are considered beneficial uses of the
area as is oyster production and harvest.

• Navigation

While there is an authorized navigational channel from Point Chehalis to the Elk River
Bridge, dredging to maintain the channel to its authorized depth is not compatible with
the area. In-water navigation aids for shallow draft vessels are acceptable as necessary.

• Structures and Fills

In general, in-water filling within the planning area is inconsistent with the character and
use of the area. In-water structures, other than those required for navigation safety and

M

the existing highway are also inconsistent with the character and use of the area. Upland
filling and structures may be acceptable provided they do not detract from other planning
area guidelines.

PLANNING AREA VHI
Area Description

• Predominant Character

The predominant character of the planning area is urban fishing. The substantial
commercial and sport fishing facilities and supporting activities dominate the physical,
social and economic character of the developed portion of the planning area. Large areas
of salt marsh and tideflats exist in the undeveloped portion of the planning area.

• Major Committed Uses

Committed uses are those that directly relate to the commercial and sport fishing
industries. Those facilities include a marina, airport, state park, fish processing
industries, supporting commercial and tourist facilities and the south jetty, revetment and
groin system. Productive salt marsh areas also exist in the south part of the planning area
as do some in-water, dredged materials disposal sites.

• Major Existing or Potential Conflicts

The principal conflicts occur with proposals to continue to develop fishing and tourism
facilities and the adjacent estuarine resources. Specific conflicts include expansion of the
marina and airport site, continuing increases in the overall intensity of use of the
shoreline and adjacent water areas, in-water, dredged materials disposal and general
shoreline property development.

• Planning Area Assets

The primary assets of the planning area are its proximity to the ocean and its substantial
commitment to support the commercial and sport fishing industry. Additionally, the
Westport Marina serves as the port of refuge for a substantial area of the Washington
coast.

Planning Area Guidelines

Management of the Natural Resources

• Bankline

The highly altered banklines in the north and northeasterly portion of the planning area
should be maintained and are considered acceptable alterations. The natural bankline in
the Half Moon Bay State Park area and in the southern portion of the planning area shall
be managed as a finite resource maintaining a natural configuration to as great an extent
as possible.

f\5

• Water Area

The existing water area will remain substantially in its present configuration. Minor
alterations for maintenance of the existing bankline, protective structures and the marina
access channel will be permitted.

• Water Quality and Hydraulics

The existing high levels of water quality will be maintained to ensure the continued
production of fish and wildlife and oysters adjacent to the planning area. Any new
developments or discharges will be evaluated to determine any detrimental effects they
might have on existing water quality.

• Fish and Wildlife

Fish and wildlife resources will be managed to maintain and enhance their present
condition.

• Vegetation

Marsh is the primary vegetative type within this planning area. Subject to permitted uses
and activities identified for specific management units, that marsh will be maintained.
Some destruction of the marsh areas to the east and north of the airport is possible to
accommodate the raising of the existing airport and a limited expansion of the marina.
Only the minimum amount of marsh areas to accomplish the projects will be allowed to be
destroyed.

• Aggregate and Minerals

There are no known deposits of commercially significant aggregate and minerals within
the area. Development of discovered resources should be only in conjunction with
navigation channel maintenance.

Development Within the Planning Area

• Economic Base

The planning area provides a direct contribution to the local and regional economy
through commercial fisheries and sport fishery recreation. In addition to Ocean Shores,
this planning area represents the other major recreation destination center in the Grays
Harbor region. The economic base of the planning area is dominated by the recreation
and fisheries industries and draws on a large regional and national market for its support.
Continuation of this economic role is considered vital to the Grays Harbor region.

• Use Character

The predominant character of the northern and central portions of the planning area is
highly developed, marine-oriented, recreation and fishing uses. This character should be
continued and enhanced. The southern portion of the planning area represents a transition
from the more developed northern areas to the natural areas in Planning Area VII. This
transition is important to maintain the integrity of both areas. No substantial develop-
ment should occur in this southern area.

46

• Recreation

The area represents the major destination recreation center associated with sport fishing.
Facilities in support of this activity should be encouraged.

• Resource Harvesting

This planning area is the focus for commercial fish harvesting and processing and
aquaculture within the Grays Harbor region. The continuation and enhancement of those
operations is compatible with role and character of the planning area. The greatest
portion of sport fisheries harvest is landed in this area. Support facilities for these
harvest activities should be maintained and encouraged.

• Navigation

Continued maintenance of the navigation channel into the marina area is critical to the
primary economic role of the planning area. Maintenance of the authorized channel into
Planning Area VII is not considered appropriate to the guidelines of that planning area.
Navigation aids are appropriate in the planning area.

• Structures and Fills

In general, major in-water filling is considered inconsistent with other planning area
guidelines, the fisheries resource and navigation. In-water structures may be appropriate
in existing developed areas and in direct support of the recreation or fisheries industry.
Navigational structures and erosion control devices such as jetties and groins are
acceptable uses in the area. Upland filling and structures are acceptable providing they
do not detract from other planning area guidelines.

47

MANAGEMENT UNITS

Management units are designed to provide specific guidance to planning and development
activities as well as management of the natural resources throughout the estuary. Most
management units represent segments of the shoreline and include both upland and aquatic
areas with the latter extending to the line of Ordinary High Water. The remainder of the
aquatic area below this line is also a management unit known as Management Unit 44.
Within this unit are also a few special "in-water" management units (see page 107).

Each management unit contains a designated Management Category, a statement of the
overall Management Objective for the unit, a listing of the Permitted Activities allowable
within the unit and a reference to a set of allowable Standard Uses. In addition, some
management units contain Special Conditions that describe circumstances that are unique to
that particular unit and that may place additional standards on the allowability of uses and
activities.

Management Unit 44 is the largest, most unique and perhaps the most difficult to manage
within the estuary. As essentially the "water" area of the harbor, it serves as the important
linkage for many of the adjacent "upland" uses and at the same time the foundation for the
natural resource systems of the estuary. They key to the management problem in
Management Unit 44 is its relationship to these other needs, uses and areas. While overall,
this unit is to be managed for its relationship to the natural resources, it nonetheless
recognizes its role in providing direct support to adjacent shoreland areas where certain uses
and activities are allowable and require connection to the aquatic or water areas.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

CM

CO

UJ

OC

?

O

D

Piers, Docks, Wharves

□

Piling & Mooring Dolphins

Bridges

Causeways

Outfalls

•

Cable/Pipeline Crossing

Boathouses

Breakwater

□

z
<

CO

Diking

Bulkheading

Groins

•

Jetty

•

Special Project Fills

Bankline Straightening

BankHne Erosion Control

•

-J
UJ

z
z
<

o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
#

STANDARD USES

See Standard Use
Table

MANAGEMENT UNIT 1
PLANNING AREA VI

Management Category

CM - Conservancy Managed

Boundary Description

Western Boundary - western terminus of the north
jetty.

Eastern Boundary - approximate intersection of
section line (T17N, R12W, Section 27) with bank-
line or at intersection of submerged jetty with
bankline.

Management Objectives

The management unit serves principally as a navi-
gation feature and secondarily for public recrea-
tion and enjoyment.

Special Conditions

The City of Ocean Shores wastewater treatment
plant exists within this management unit and is
generally compatible with the purposes of this
management unit. Expansion of that facility will
fall under the following guidelines:

a. Modification to equipment or minor external
changes or additions within the present site
configuration will be subject to local city
permit processes.

b. Modification or expansion that involves
major facilities and/or enlargement of the
present site configuration is considered an
intensification of the present use and is
subject to review and comment by the Estu-
ary Planning Task Force as well as local city
permit processes.

48

MANAGEMENT UNIT 2
PLANNING AREA VI

Management Category

N - Natural

Boundary Description

Western Boundary - Management Unit 1.
Eastern Boundary - approximate eastern site of
water outlet from mud flat area.
Study Area Boundary - State Game and Depart-
ment of Natural Resources property out to the old
North Jetty.

Management Objectives

This area encompasses all of the state game
properties and will remain in an undisturbed,
natural condition.

Special Conditions

1. The existing V.O.R. airplane navigation
facility and site is considered appropriate as
are the maintenance activities necessary to
support it.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

N

(0
111
AC

O

D

I

Piers, Docks, Wharves

Piling & Mooring Dolphins

Bridges

Causeways

Outfalls

Cable/Pipeline Crossing

Boathouses

Breakwater

Z
<
GO

Diking

Bulkheading

Groins

Jetty

□

Special Project FHIs

Bankline Straightening

Bankline Erosion Control

-1
111

z
z
<

o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
D

STANDARD USES

See Standard Use
Table

49

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

CM

CO
w

oc

o

3
OC

(0

z
<

CD

Piers, Docks, Wharves

Piling & Mooring Dolphins

Bridges

Causeways

Outfalls

Cable/Pipeline Crossing

Boathouses

Breakwater

Diking

Bulkheading

Groins

Jetty

Special Project FHIs

Bankline Straightening

Bankline Erosion Control

*

-J
UJ

z
z
<

o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
*

MANAGEMENT UNIT 3
PLANNING AREA VI

Management Category

CM - Conservancy Managed

Boundary Description

Western Boundary - Management Unit 2.

Eastern Boundary - intersection of Damon Point

with main bankline.

Study Area Boundary - the edge of the platted

properties between Mariners Way and Marine

View Drive.

Management Objectives

Damon Point is considered a valuable recreational
resource and will be managed for those purposes.

Special Conditions

Because Damon Point is an unstabilized sandspit,
it is probable that its present configuration will
change. No attempts will be made to artificially
stabilize the spit. If future changes begin to
interfere with the purposes of adjacent manage-
ment units, remedies will be considered through
the plan amendment procedures.

STANDARD USES

See Standard Use
Table

50

MANAGEMENT UNIT k
PLANNING AREA VI

Management Category

UM - Urban Mixed

Boundary Description

Southern Boundary - Management Unit 3.

Northern Boundary - the northern property line of

the Ocean Shores Beach and Yacht Club.

Study Area Boundary - Marine View Drive and

Catala Avenue.

Eastern Boundary - Marina Entrance*

Management Objectives

This is the primary waterfront development area
in Ocean Shores. It presently contains the Ocean
Shores Marina and Country Club. Future develop-
ment will reinforce and expand on the present
uses.

Special Conditions

Continued operation and maintenance of the
existing outfall in this management unit is
allowed. New outfalls that may be required to
support the runoff needs will not be allowed
within the marina.

*This management unit goes beyond the normal
water ward boundary to encompass the total
marina complex.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UM

(0
U
a

g

o

(0

Piers, Docks, Wharves

•

Piling & Mooring Dolphins

•

Bridges

Causeways

Outfalls

*

Cable/Pipeline Crossing

Boathouses

•

Breakwater

•

z
<

CO

Diking

□

Bulkheading

□

Groins

□

Jetty

Special Project Fills

Bankline Straightening

Banklrne Erosion Control

•

-1
111

z
z
<
z
o

New Access Channel

•

Channel/Berth Maint

•

Channel Realignment

□

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
#

STANDARD USES

See Standard Use
Table

51

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UR

UJ

O

E

Piers, Docks, Wharves

Piling & Mooring Dolphins

Bridges

Causeways

Outfalls

□

Cable/Pipeline Crossing

Boathouses

*

Breakwater

z
<

CD

Diking

♦

Bulkheading

*

Groins

Jetty

Special Project FHIs

BankHne Straightening

BankHne Erosion Control

*

_l
UJ

z
z
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z
o

New Access Channel

Channel/Berth Mairtt

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
#

STANDARD USES

See Standard Use
Table

MANAGEMENT UNIT 5
PLANNING AREA VI

Management Category

UR - Urban Residential

Boundary Description

Southern Boundary - Management Unit 4.
Northern Boundary - the northern limits of the
shorefront platted residential properties, approxi-
mately at the intersection of Harbor View Drive
and Duck Lake Drive.
Study Area Boundary - Duck Lake Drive.

Management Objectives

This management unit will be used entirely for
public shoreline access and recreation with shore-
front residential properties immediately behind.
Existing public access points will be maintained as
will all areas of aquatic vegetation.

Special Conditions

1. Sloped, interlocking concrete slab type bulk-
heading is permitted only as a means of
erosion control with existing platted resi-
dential lots and only out to the waterward
limit of those lots.

2. Diking is permitted as an alternative means
of erosion control to bulkheading as speci-
fied in Special Condition #1 above.

3. Boathouses are permitted only within the
existing lagoon area.

52

MANAGEMENT UNIT 6
PLANNING AREA VI

Management Category

UM/N - Urban Mixed/Natural

Boundary Description

Southern Boundary - Management Unit 5.
Northern Boundary - Ocean Shores city boundary
or the southern line of Section 26 (T18N, R12W).
Split Unit Boundary - line of non-aquatic vegeta-
tion (Section 404).

Study Area Boundary - Duck Lake Drive and
North Bay Avenue.

Management Objectives

Within the urban mixed portion, the management
intent is to allow the eventual development of a
new airport for Ocean Shores, as well as the
continued development of residential properties.
Within the remainder of the area, the property
will remain in an undisturbed, natural condition.

Special Conditions

1. Sloped, interlocking concrete slab type bulk-
heading is permitted only as a means of
erosion control with existing platted resi-
dential lots and only out to the waterward
limit of those lots.

2. Diking is permitted as an alternative means
to erosion control to bulkheading as speci-
fied in Special Condition #1 above.

3. The City of Ocean Shores is unique both
from the standpoint of its physical setting
as well as its history. As a major land
development project from the 1960's, the
plan for the now incorporated city was
established to achieve land sales objectives.
These objectives have resulted in the par-
celization and sales in excess of 11,000
homesites and the location of the existing
airfield in the middle of and totally sur-
rounded by developing parcels, posing prob-
lems not only of runway and facility capa-
city, but also safety. As an economy based
on tourism, the city has considered alterna-
tives for upgrading the airfield to allow
greater usability and safety, which have
included a review of the existing and alter-
native sites. The existing site, while an

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UM

N

(0
111
a

o

I

Z
<
CO

Piers, Docks, Wharves

Piling & Mooring Dolphins

Bridges

Causeways

Outfalls

D

□

Cable/Pipeline Crossing

Boathouses

Breakwater

Diking

*

*

Bulkheading

*

Groins

Jetty

Special Project Fills

*

*

Bankline Straightening

Bank line Erosion Control

*

_l
111

z
z
<

o

New Access Channel

Channel/Berth Makit

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
«

STANDARD USES

See Standard Use
Table

ideal location, was discarded because of its
inability to be to either upgrade its capacity or
solve safety problems. A private airfield at
Hogan's Corner, approximately IK2 miles north of
the city, 2Vi miles north of the existing airfield
was discarded because of its location, safety
problems associated with adjacent homes and the
need for intrusion into marsh areas for airfield
expansion. No other property exists within the
city of adequate size to accommodate the airfield
except the proposed site, approximately K2 mile
east of the existing airfield and within
Management Unit 6.

53

The location of the facility at the proposed site in
accordance with the Airport Master Plan and
Environmental Impact Statement (1976) would in-
volve partial intrusion into a salt marsh area.
Filling of these areas must comply with appro-
priate permitting processes, including the Section
404 permit process. However, based on current
information and subject to the following condi-
tions, the location of the airfield within Manage-
ment Unit 6 would not have an unacceptable
adverse impact on the aquatic ecosystem,
including wetlands within the meaning of Section
404 Guidelines.

a. That sufficient property fronting North Bay
Avenue be acquired to allow the shifting of
the airfield to the west.

b. That the entire facility be redesigned to
minimum F.A.A. standards in accordance to
the Proposed Design Revision dated
11/2/78(77). The emphasis of that redesign
is on reducing the dimensions between the
taxi-way and adjacent property; the taxi-
way and runway; the runway and the toe of
the outer slope of the fill; the safety zones
at the end of the runway.

c. That the remainder of the 230 acres
(approximately 190-200 acres) will be pre-
served as a permanent natural area through
the establishment of a conservation ease-
ment (or similar mechanism); that the ease-
ment will be granted to an agreed upon
state or federal resource agency, or an
independent nature conservancy organiza-
tion; that the easement will indicate that
the area will be preserved for the use of fish
and wildlife, and, conversely, will not be
used for development.

d. That a mitigation project (see discussion of
Mitigation, page 26) will be developed and
approved by State and Federal resource
agencies in advance of a permit issuance,
and that an implementation schedule for the
mitigation project will be committed to and
initiated at the time of permit issuance.

54

MANAGEMENT UNIT 7
PLANNING AREA V

Management Category

CM - Conservancy Managed

Boundary Description

Southern Boundary - Management Unit 6
Northern (East) Boundary - Farm Road and ease
side of Kurtz Slough.

Study Area Boundary - a line at approximately 20
feet elevation or the line of non-aquatic vegeta-
tion and the Ocean Shores Road on the west.

Management Objectives

This area will remain in an undisturbed condition
although some opportunities for recreational use
will be possible under the guidelines of Standard
Uses and Permitted Activities.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

CM

(0
u
oc

o

I

Z
<
CO

Piers, Docks, Wharves

Piling & Mooring Dolphins

Bridges

Causeways

Outfalls

Cable/Pipeline Crossing

Boathouses

Breakwater

Diking

Bulkheading

Groins

Jetty

Special Project FHIs

Bankline Straightening

Bankline Erosion Control

_l
111

z
z
<

X

o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

*

STANDARD USES

See Standard Use
Table

55

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

RA

CO

tu
ec

I

E

z
<

CO

Piers, Docks, Wharves

Piling & Mooring Dolphins

Bridges

Causeways

Outfalls

□

Cable/Pipeline Crossing

Boathouses

•

Breakwater

Diking

*

Bulkheading

*

Groins

Jetty

Special Project Fills

Bankline Straightening

Bankline Erosion Control

*

■J
UJ

Z

z
<
z
o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

MANAGEMENT UNIT 8
PLANNING AREA V

Management Category

RA - Rural Agriculture

Boundary Description

Western Boundary - Management Unit 7.
Eastern Boundary - west side of Campbell Slough.
Study Area Boundary - Ocean Shores Highway.

Management Objectives

This area is one of the few agricultural areas
within the study area of the Estuary Management
Plan. Because of the valuable agricultural
resource it represents, future uses and activities
will be permitted consistent with that purpose.

Special Conditions

1. Diking and bulkheading with sloped, inter-
locking concrete slabs, are permitted only in
association with necessary road mainte-
nance and to protect existing structures.

STANDARD USES

See Standard Use
Table

56

MANAGEMENT UNIT 9
PLANNING AREA V

Management Category

RL/N - Rural Low Intensity/Natural

Boundary Description

Western Boundary - Management Unit 8.
Eastern Boundary - east side of Gillis Slough.
Split Unit Boundary - line of non-aquatic vegeta-
tion.
Study Area Boundary - Ocean Shores Highway.

Management Objectives

On the water side of the Section 404 line, the
area will remain in an undisturbed, natural condi-
tion. On the land side of the Section 404 line, the
area may be used as a rural area in accordance
with the guidelines of Standard Uses and Per-
mitted Activities.

Special Conditions

1. Boathouses are acceptable only on Campbell
and Jessie Sloughs and are even then con-
sidered a conditional use subject to site
specific, case-by-case review.

2. The installation of piers, docks, wharves,
piling and mooring dolphins is allowable only
through the application of conditional use
standards and provided that no new naviga-
tion channel is required.

3. Piers, docks, wharves, piling and mooring
dolphins will be allowed associated with
small private residential uses and provided
that it does not interefere with the manage-
ment of Department of Game property at
the mouth of Humptulip River.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

RL

N

(0
HI

oc

o

D
OC

(0

Piers, Docks, Wharves

*

*

Piling & Mooring Dolphins

*

*

Bridges

•

Causeways

Outfalls

Cable/Pipeline Crossing

□

Boathouses

*

Breakwater

z
<

03

Diking

□

Bulkheading

Groins

Jetty

Special Project FHIs

Bankline Straightening

Bankline Erosion Control

•

-J

u

z
z
<

o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
*

STANDARD USES

See Standard Use
Table

57

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

RL

</>
W
CO

O

D
OC

Z
<
GO

Piers, Docks, Wharves

*

Piling & Mooring Dolphins

*

Bridges

•

Causeways

Outfalls

□

Cable/Pipeline Crossing

□

Boathouses

•

Breakwater

Diking

□

Bulkheading

□

Groins

Jetty

Special Project FHIs

Bankline Straightening

Bank line Erosion Control

•

-I
LU

Z

z
<
z
o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

#

STANDARD USES

See Standard Use
Table

MANAGEMENT UNIT 10
PLANNING AREA V

Management Category

RL - Rural Low Intensity

Boundary Description

Western (North) Boundary - Management Unit 9.

Eastern Boundary - the eastern line of Section 12

(T17N, R11W) or the western boundary of port

ownership.

Study Area Boundary - Burlington Northern rail

line and line of non-aquatic vegetation along

Grass Creek.

Management Objective

No significant development activity is envisioned
in any portion of this management unit except as
consistent with guidelines of Standard Uses and
Permitted Activities.

Special Conditions

1. Continued maintenance of existing railroad)
rights-of-way and facilities is permitted.

2. The installation of piers, docks, wharves,
piling and mooring dolphins is allowable pro-
vided that no new navigation channel is
required.

3. Piers, docks, wharves, piling and mooring
dolphins will be allowed associated with
small private residential uses and provided
that it does not interefere with the manage-
ment of Department of Game property at
the mouth of the Humptulip River.

58

MANAGEMENT UNIT 11
PLANNING AREA ID

Management Category

UD - Urban Development

Boundary Description

Western Boundary - Management Unit 10
Eastern Boundary - Hoquiam City boundary.
Study Area Boundary - Railroad tracks.
Waterward Boundary - line of non-aquatic vegeta-
tion (Section 404) or northern line of Port of
Grays Harbor ownership, whichever extends fur-
thest south.

Management Objectives

This management objective is principally a trans-
portation corridor containing both the Ocean
Shores Highway and the Burlington Northern rail
line. Continued use of the management unit for
this purpose is considered appropriate.

Special Conditions

1. This management unit is immediately adja-
cent to Management Unit 12. Continued
maintenance of the railroad line and high-
way is permitted.

2. Highway improvements at the "Grays
Harbor City curve" are permitted subject to
the terms and conditions defined in Corps of
Engineers permit No. 071-OYB-2-005073.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UD

CO

u
s

o

D
K

CO

z
<

CO

Piers, Docks, Wharves

Piling & Mooring Dolphins

Bridges

Causeways

Outfalls

Cable/Pipeline Crossing

Boathouses

Breakwater

Diking

□

Bulkheading

Groins

Jetty

Special Project FHIs

Bankline Straightening

Bank line Erosion Control

•

-1
III

z
z
<
z
o

New Access Channel

Channel/Berth Mamt

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

STANDARD USES

See Standard Use
Table

59

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

SP

</>
U

K

O

3
B

F

CO

z
<

CD

Piers, Docks, Wharves

*

Piling & Mooring Dolphins

*

Bridges

Causeways

Outfalls

#

Cable/Pipeline Crossing

Boathouses

Breakwater

Diking

*

Bulkheading

*

Groins

Jetty

Special Project Fills

*

Bankline Straightening

*

Bankline Erosion Control

*

-1

w

z
z
<

o

New Access Channel

*

Channel/Berth Maint

*

Channel Realignment

*

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
*

STANDARD USES

See Standard Use
Table

MANAGEMENT UNIT 12
PLANNING AREA IH

MANAGEMENT CATEGORY: Special

BOUNDARY DESCRIPTION; See Attached Exhi-
bit

MANAGEMENT OBJECTIVES

This Management Unit represents a unique area,
combining both valuable habitat to be protected
for fish and wildlife and future sites for the
principal industrial expansion in the harbor.

Part of the Management Unit (approximately
1,700 acres) provides valuable habitat for fish and
wildlife which will be managed as a natural area
for the protection and enhancement of fish and
wildlife resources, while other parts of the Man-
agement Unit (approximately 500 acres) will be
managed to provide major new areas for industrial
development within the Grays Harbor region. Fil-
ling of some intertidal areas and wetlands will be
necessary to provide these new areas for indus-
trial development.

The above objectives are mutually dependent in
that the fill and development of some areas is
balanced with the protection of other areas to
assure multiple use of the estuary consistent with
the Estuary Management Goal. The key to the
management philosophy and balance for this Man-
agement Unit is that protective guarantees are
established through incremental and proportional
fee title transfer of tidelands and wetlands in
Area 1 with fill and development in Areas 2 and 3,
thereby avoiding unacceptable adverse impacts to
the ecosystem. While this same management
philosophy generally applies to Area *f, evaluation
of impacts, alternatives and need for fill in this
area have not been made in this plan and must
therefore be performed in connection with speci-
fic development proposals (see additional discus-
sion of Area k in this Management Unit). As
always, fill for development is subject to the
normal permitting process, although the permit-
ting process itself will be improved through the
advance evaluations and decisions made in this
plan.

60

Special Conditions

Six sub-areas are included in this Management Unit (see attached exhibit)

Area I - Natural

Area 2 - Phase I Fill - Urban Development

Area 3 - Airport Fill - Urban Development

Area 4 - Special Designation

Area 5 - Existing Airport - Urban Development

Area 6 - Waterfront Area - Conservancy Managed

AREA I - NATURAL AREA

Description

Area I is an area of extensive tideflats, wetlands and intertidal land and contains
significant shorebird habitat. The area includes all of the land owned in fee by the Port of
Grays Harbor below the Section 404 line of non-aquatic vegetation, except those lands
included within Areas 2, 3, 4 and 6. An additional area commonly known as "the fan" (see
Management Unit 12 exhibit for further description) is also included within Area I. The
final determination of Section 404 jurisdiction will be made by the Corps of Engineers as a
part of the permit process. Area I includes approximately 1,700 acres and is bounded on
the west by the eastern line of Section 12 (TI7N, Rl IW) and on the south by the northern
edge of the authorized federal navigation channel and Areas 2, 3, 4 and 6.

Implementation Conditions

The following conditions have been developed in conjunction with conditions for Areas 2,
3, 4 and 6 and are tied, therefore, to their implementation.

1. Any filling that may be allowed within Management Unit 12 will carry with it the
condition that lands within Area I will be preserved as natural areas through the
transfer of fee title. As Areas 2, 3, 4 and 7 (see Management Unit 14 for Area 7)
are filled for industrial development, fee title will be transferred for a portion of
Area I on the basis of 3.4 acres transferred for each acre filled.* The transfer will
permanently establish a balance that is essential to avoid unacceptable adverse
impacts to the aquatic ecosystem, including wetlands (within the meaning of Section
404 guidelines) might otherwise result from future fills in Area I. Transfer of title
will be done in accordance with Condition 3 to. follow.

2. Upon evaluation of the Final Environmental Impact Statement on this plan by the
E.P.A. and the Corps of Engineers, the Port of Grays Harbor, under the provisions of
40CFR, Part 230.80, Guidelines for Specification of Disposal Sites for Dredged or

*This proportion is derived from the approximate acreage figures noted previously, which
have been determined in the plan to be an acceptable balance between natural and
development areas in the Bowerman Basin, i.e., 1,700 acres: 500 acres = 3.4:1.

61

Fill Material, will formally apply to the Environmental Protection Agency and the
Corps of Engineers to designate Area 1, exclusive of Areas 2, 3, 4, 6 and 7 (in
Management Unit 14) as lands where the placement of dredged or fill materials is
prohibited.

3. Fee title transfer of lands within Area 1 will be accomplished in accordance with
the following terms and conditions:

Recipient: Fee title will be transferred by the Port of Grays Harbor to the
Washington State Department of Game. A Bowerman Basin Advisory Council will be
formed consisting of representatives of state and federal resource agencies, Grays
Harbor County, the Port of Grays Harbor, interested formally organized environ-
mental groups, and at least two citizens at large to be appointed by the Grays
Harbor Regional Planning Commission. As the Department of Game prepares
management plans or is faced with specific management decisions on lands within
Area 1 transferred to its responsibility, it will seek the review, advice and counsel
of the Advisory Council. At a minimum, the Department of Game will call at least
one meeting of the Advisory Council each year to review the status of transferred
lands and other relevant issues.

Purpose: The purpose of the transfer is to preserve Area 1 as a natural area.
However, federal or state resource agencies may undertake research on experi-
mental habitat protection and enhancement programs in the area, provided that
those actions do not interfere with allowable uses and activities of adjacent
Management Units; are consistent with applicable local, state and federal policies
and regulations; and are reviewed by the Bowerman Basin Advisory Council and the
Department of Game.

Conveying Title: As a permit is issued for fill of a portion of the Management Unit
(including Area 7, Management Unit 14), a 3.4:1 proportional amount of Area 1 will
be transferred in fee. No fill may commence until the proportionate transfer of
title has occurred.

The general sequence of title conveyance will be from East to West across the
Bowerman Basin beginning along the northern edge of Area 1 (see Management Unit
12 Exhibit for the actual conveyance sequence). This specification is designed to
act as a guideline for transfer rather than as an absolute requirement. However, as
an additional guideline, parcels transferred should generally be four-sided with one
dimension no greater than three times the other.

Final Parcel Conveyance: At such time as the final fill action allowed in
Management Unit 12 (and Area 7 in Management Unit 14) is permitted, the
remaining parts of Area 1 will be transferred. It is recognized that this final
transfer may not strictly satsify the 3.4:1 proportional rule due to the fact that
acreage figures for Area 1 (1,700) and Areas 2, 3, 4 and 7 (500) are only
approximate.

AREA 2 - PHASE I FILL SITE - URBAN DEVELOPMENT

Description

Area 2 includes approximately 164 acres as measured to the toe of the dike for any fill
within the area. The dimensions of this area are illustrated on the Management Unit 12

62

exhibit and represent an area as measured to the top of the dike of any fill within the
area. These dimensions and the other conditions attached to this area, are established to
provide for the development of a major multi-commodity, bulk loading and off-loading
facility. The facility is envisioned with a rail loop transportation system and sufficient
on-site storage for handling several types of bulk commodities simultaneously.

Implementation Conditions

The following conditions have been developed in conjunction with conditions for Area 1
and are tied, therefore, to their implementation.

1. As a permit is issued for fill in Area 2 for industrial development, fee title will be
transferred of a portion of Area 1 on the basis of 3.4 acres transferred for each acre
filled. The transfer will permanently establish a balance that is essential to avoid
unacceptable adverse impacts to the aquatic ecosystem, including wetlands (within
the meaning of Section 404 guidelines) that might otherwise result from additional
future fills in Area 1. Transfer of title will be done in accordance with Condition 3
of the Implementation Conditions for Area 1.

2. Grays Harbor is one of the major estuaries on the west coast. The Harbor contains a
total of 54,720 acres to the extreme high water line with 33,600 acres of intertidal
land. It contains 5,420 acres of saltmarsh and 28,160 acres of tideflats. Between
1940 and 1975, 3,850 acres of intertidal wetlands have been impacted with the
placement of dredged materials, including portions of the area within Management
Unit 12. In the early portion of that period, the rate of fill was as much as 50 acres
per year. More recently, that rate has slowed to 10-15 acres per year or less.

In establishing its direction for overall management of the estuary, the Task Force
recognized that economic growth involving conversion of natural habitat to indus-
trial uses would continue at some level in the harbor during the life of this plan. In
reviewing the opportunities for that growth to occur around the harbor, the Task
Force reviewed the several potential areas in terms of the availability, size and
usability of land, transportation access for both rail and highway, proximity to the
main navigation channel, availability of utilities, relationship to the existing
industrial areas, relationship to other support industries and uses and other factors.
While there are several areas around the harbor that could accommodate some
industrial growth, the Task Force saw that most provided only limited opportunities.
In pursuing a philosophy of concentrating major future development rather than
dispersing it throughout the harbor, focusing that growth into the area of Manage-
ment Unit 12 met more of the criteria than any other area.

In addition to criteria directly related to the needs of future industrial development,
the Task Force considered the amounts of various types of intertidal habitat and
their values to fish and wildlife resources. Fish migration habitat was considered a
major limiting factor in Grays Harbor because of past developmental patterns.
During the next 50 years, the plan, as drafted, will protect most of the estuarian
wetlands from filling except those in this management unit. This is approximately
1.5% of the intertidal area of Grays Harbor and 6% of the estuary's low silty marsh.
Although there is an adverse impact associated with filling these wetlands, the
balance achieved through protection of most of the rest of the estuarian ecosystem
from filling reduces the significance of the loss, and is consistent with the overall
goal for management of the estuary for multiple uses.

63

3. Filling that occurs in Area 2 will be subject to approval through the Section 404
permit process. However, in the context of the total Management Unit and the
total Estuary Management Plan, such filling is not considered to have an unaccept-
able impact on the aquatic ecosystem, including wetlands. This determination is
made in consideration of:

a. Implementation Condition 2, above

b. The Management Objective for this Management Unit,

c. The implementation of allowable fill through the application of normal local,
state and federal policies and regulations,

d. The implementation of the policies and standards of this plan,

e. The full implementation of the conditions of this Management Unit including
the fee title transfer of approximately 1,700 acres of intertidal and wetland
area,

f . The guarantees and protective measures afforded to the resources of the total
harbor by this plan,

g. The consideration, in the preparation of this plan, of the long term need of the
Grays Harbor community to seek out and accommodate major new industrial
diversification and expansion,

h. The consideration, in the preparation of this plan, of alternative areas and
ways to accommodate new water dependent industry and the general lack of
areas as uniquely suited as this Management Unit and

i. Implementation Condition 5, below.

4. Upon evaluation of the Final Environmental Impact Statement on this plan by the
E.P.A. and the Corps of Engineers, the Port of Grays Harbor, under the provisions of
40CFR, Part 230.80, Guidelines for Specification of Disposal Sites for Dredged or
Fill Material, will formally apply to the E.P.A. and the Corps of Engineers to pre-
designate Area 2 as an area for the discharge of dredged or fill material for water
dependent industrial development subject to permit approval.

5. As filling occurs, it will be done in accordance with disposal practices approved
through the permit process, including the use of containment structures surrounding
each fill to preclude the unnecessary dispersal of fill material to the adjacent
aquatic area. With the full review and concurrence of state and federal resource
agencies, plans for the placement of fill in Area 2 will consider the selective
placement of additional fills and/or non-standard design of fill dikes to recreate lost
habitat on the northern edge of this area. A particular emphasis will be placed on
recreating the vegetated salt marshes and woody vegetation that is similar to the
vegetation on the north side of Moon Island. Additionally, piles that must be
removed to accommodate the fill will be replaced in the area north of the fill site to
re-establish perching sites for birds. Although the plan views this area as a fill site,
rather than a dredged materials disposal site, the use of dredged material for fill
meeting these special conditions is appropriate.

6. The specific size and shape of the northern portion of Area 2 (within the general
dimensions illustrated on the Management Unit 12 exhibit) is determined by the
engineering requirements for a railroad loop track including required maintenance
roads and drainage facilities.

64

AREA 3 - AIRPORT FILL - URBAN DEVELOPMENT

Description

Area 3 is approximately 73 acres as measured to the toe of the dike required for a fill in
this area.

Implementation Conditions

The following special conditions have been developed in conjunction with the conditions of
Area 1 and are tied, therefore, to their implementation.

1. As a permit is issued for fill in Area 3 for the relocation of the Bowerman Airfield,
fee title will be transferred of a portion of Area 1 on the basis of 3.4 acres
transferred for each acre filled. The transfer will permanently establish a balance
that is essential to avoid unacceptable adverse impacts to the aquatic ecosystem,
including wetlands (within the meaning of Section 404 guidelines) that would result
from future fills in Area 1. Transfer of title will be done in accordance with
Condition 3 of the Implementation Conditions for Area 1.

2. Filling of Area 3 will be allowed for the relocation and expansion of the airport in
order to accommodate an FAA-approved ILS Commuter Airport. However, the
maximum line of fill shall be 750 feet to the north, and the fill shall be the minimum
amount necessary to accommodate the ILS airport. Fill of Area 3 can only occur to
accommodate the relocation of Bowerman Airfield and only when all or a majority
of the existing Airfield area (Area 5) is proposed for a water dependent industrial
use.

3. If Area 2 is filled prior to a permit application to fill in Area 3, an evaluation of the
effects of filling in Area 2 will be conducted as a part of the permit review process.
The primary purpose of that evaluation will be to determine whether environmental
conditions have changed sufficiently as a result of the Area 2 fill to demonstrate
that other alternative airport sites would be less environmentally damaging.

4. Filling in this area will be subject to approval through the Section 404 permit
process. However, in the context of the total Management Unit and the total
Estuary Management Plan, such filling is not considered to have an unacceptable
adverse impact on the aquatic ecosystem, including the wetlands. This determi-
nation is made in consideration of:

a. Implementation Condition 2, above

b. The Management Objective for this Management Unit,

c. The implementation of allowable fill through the application of normal local,
State and Federal policies and regulations,

d. The implementation of the policies and standards of this plan,

e. The full implementation of the conditions of this Management Unit including
the fee title transfer of approximately 1,700 acres of intertidal and wetland
area,

f . The guarantees and protective measures afforded to the resources of the total
harbor by this plan,

65

g. The consideration, in the preparation of this plan, of the long term need of the
Grays Harbor community to seek out and accommodate major new industrial
diversification and expansion,

h. The consideration, in the preparation of this plan, of alternative areas and
ways to accommodate new water dependent industry and the general lack of
areas as uniquely suited as Area 3, and

i. Implementation Condition 5, below.

5. As filling occurs, it will be done in accordance with disposal practices approved
through the permit process, including the use of containment structures surrounding
each fill to preclude the unnecessary dispersal of fill material to the adjacent
aquatic area. However, with the full review and concurrence of state and federal
resource agencies, plans for the placement and fill in Area 3 will consider the
selective placement of additional fills and/or non-standard design of fill dikes to
recreate lost habitat on the northern edge of this area. A particular emphasis will
be placed on recreating the vegetated salt marshes and woody vegetation on the
north side of Moon Island. Additionally, piles that must be removed to accommo-
date the fill will be replaced in the area north of the fill site to re-establish
perching sites for birds. Although the plan views this area as a fill site, rather than
a dredged materials disposal site, the use of dredged material for fill meeting these
special conditions is appropriate.

AREA 4 - SPECIAL DESIGNATION

Description

Area 4, as identified on the Management Unit 12 exhibit, is not intended to denote an
exact location nor an absolute commitment to a future fill within that specific area.
Nonetheless, for purposes of describing the conditions under which future filling might
occur, the following sections are included as a part of this Management Unit. Area 4
includes approximately 243 acres. The actual acreage of this area will be defined at the
time of permit considerations. However, in concept, the acreage of this area is the
remainder of the sums of the acreage (to the toe of the dike) of Areas 2, 3 and 7 (in
Management Unit 14) subtracted from 500 acres.

Implementation Conditions

The following conditions have been developed in conjunction with conditions for Area 1
and are tied, therefore, to their implementation.

1. As a permit is issued for fill in Area 4 for the development of water dependent
industrial uses, fee title will be transferred of a portion of Area 1 on the basis of 3.4
acres transferred for each acre filled. The transfer will permanently establish a
balance that is essential to avoid unacceptable adverse impacts to the aquatic
ecosystem, including wetlands (within the meaning of Section 404 guidelines) that
might result from additional future fills in Area 1. Transfer of title will be done in
accordance with Condition 3 of the Implementation Conditions for Area 1.

2. Area 4 is a conceptual designation for future fills (Phase II fill) which are intended
to provide a total of 500 acres of potential fill for industrial development within
Management Unit 12 and Area 7 of Management Unit 14. The designation of Area 4

66

for fill does not represent a commitment that the area will actually be filled. A
decision on the actual location of future fill will be made at the time of future
development. This decision will be made in accordance with these conditions and
will be guided by the principles of:

a. locating necessary fills in areas where there will not be an unacceptable
adverse impact on the aquatic ecosystem, including wetlands, and

b. meeting industrial development needs within the region.

3. Area 4 fills can only occur if Area 2 is fully developed and utilized. In addition, uses
that may be proposed as a part of the Area 4 permit application must demonstrate
that there are no other less environmentally damaging practicable locations for the
use including the existing Bowerman Airfield area (Area 5).

4. Area 4 fills will be subject to approval through the Section 404 permit process.
Unlike Areas 2, 3, 6 and 7 (in Management Unit 14) no prior Section 404 or Section 7
(Endangered Species Act) evaluations have been considered for this area within this
plan on whether filling would have an unacceptable adverse impact. Consequently,
proposals for Area 4 fill must demonstrate acceptable levels of impact on the
ecosystem, the need for the proposed project which would be located on the fill, and
alternative locations. As noted above, the actual location of an Area 4 fill which
meets these requirements will depend on assessments at the time of proposal.

5. It is recognized that an Area 4 fill proposal may be submitted which meets needs
and alternative requirements but cannot be located within this Management Unit
due to unacceptable adverse impacts on the ecosystem. In such a case, it is
expected that the Estuary Management Plan may be amended to accommodate
necessary fill proposals (up to the total 500 acre limit) in other areas of the estuary
and that the general area identified for the Area 4 fill will be redesignated as a
natural area.

AREA 5 - EXISTING AIRFIELD - URBAN DEVELOPMENT

Description

Area 5, as identified in the Management Unit 12 exhibit is intended to describe the
existing Bowerman Airfield area including all that land above the Section 404 Line of
Non-Aquatic Vegetation, extending east to the Hoquiam City Limits line. In the area
generally known as "the fan", the northern boundary of Area 5 is described by an east-
west line, parallel to and 750 feet north of a line formed by the northern edge of the
existing buildings on the Bowerman airfield. It is envisioned that this area will continue
to be used for the existing airfield. At such time as the airfield is relocated, either to
Area 3 or to another location, Area 5 will be used for water dependent industrial uses.

Implementation Conditions

The following special conditions have been developed in part with the conditions of
Area 3.

1. Continuation of the existing use of this area is allowed subject to local land use
regulations and other applicable local, state and federal requirements.

67

2. With the relocation of the airfield, either through its location in Area 3 or through
its location elsewhere, the reuse of this area will be for water dependent industrial
purposes.

3. If the airfield is relocated to an area other than Area 3, the subsequent reuse of
Area 5 will be for uses whose dependency on the aquatic area can be accommodated
through Area 6 only. No aquatic connections will be allowed into Area I from
Area 5.

4. The relocation of the Airfield into Area 3 is intended to include only the runways
with the fixed base facilities remaining in their present location. Reuse of Area 5
for water dependent industries will be in those areas vacated by the runways and
other relocated facilities.

AREA 6 - WATERFRONT AREA - CONSERVANCY MANAGED

Description

This is the southern-most portion of the management unit extending from the Section 404
Line of Non-Aquatic Vegetation along the existing airfield out to the northern edge of the
federal navigation channel. The area extends from the Hoquiam City Limits at the
boundary between Management Units 12 and 14, westerly to the western-most extent of a
potential fill in Area 4. The western boundary of Area 6 is not fixed at this time but is
rather variable depending fill decisions made within Area 2 and 4.

Implementation Conditions

I. The southern shoreline of the existing Bowerman Airfield is an area of significant
natural resources, particularly as it relates to the migration and feeding of fish and
shellfish. At the same time, with the use of Areas 2 and 5, and potentially Area 4,
for water dependent industrial development, access to the water and the navigation
channel is of prime importance. Any development will be done with great care and
under the following guidelines:

a. A very limited number of "T" docks will be allowed within this area. The
principal concern with these structures is the number of tressle connections to
the shore rather than the length of dock structure at the navigation channel.

b. Very limited filling is allowable at the approach to the "T" dock for the
purposes of establishing a safe and efficient connection to the shore and, to
reduce the high costs of such structures. Under no circumstances will such
fills extend to that portion of the structure adjacent to the channel nor will it
substantially interfere with the migration of fish and shellfish, or their rearing
and feeding areas.

68

2. With the relocation of the airfield, either through its location in Area 3 or through
its location elsewhere, the reuse of this area will be for water dependent industrial
purposes.

3. If the airfield is relocated to an area other than Area 3, the subsequent reuse of
Area 5 will be for uses whose dependency on the aquatic area can be accommodated
through Area 6 only. No aquatic connections will be allowed into Area I from
Area 5.

4. The relocation of the Airfield into Area 3 is intended to include only the runways
with the fixed base facilities remaining in their present location. Reuse of Area 5
for water dependent industries will be in those areas vacated by the runways and
other relocated facilities.

AREA 6 - WATERFRONT AREA - CONSERVANCY MANAGED

Description

This is the southern-most portion of the management unit extending from the Section 404
Line of Non-Aquatic Vegetation along the existing airfield out to the northern edge of the
federal navigation channel. The area extends from the Hoquiam City Limits at the
boundary between Management Units 12 and 14, westerly to the western-most extent of a
potential fill in Area 4. The western boundary of Area 6 is not fixed at this time but is
rather variable depending fill decisions made within Area 2 and 4.

Implementation Conditions

I. The southern shoreline of the existing Bowerman Airfield is an area of significant
natural resources, particularly as it relates to the migration and feeding of fish and
shellfish. At the same time, with the use of Areas 2 and 5, and potentially Area 4,
for water dependent industrial development, access to the water and the navigation
channel is of prime importance. Any development will be done with great care and
under the following guidelines:

a. A very limited number of "T" docks will be allowed within this area. The
principal concern with these structures is the number of tressle connections to
the shore rather than the length of dock structure at the navigation channel.

b. Very limited filling is allowable at the approach to the "T" dock for the
purposes of establishing a safe and efficient connection to the shore and, to
reduce the high costs of such structures. Under no circumstances will such
fills extend to that portion of the structure adjacent to the channel nor will it
substantially interfere with the migration of fish and shellfish, or their rearing
and feeding areas.

68

69

MANAGEMENT UNIT 13
NOT USED

MANAGEMENT UNIT 14
PLANNING AREA HI

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UD

CO

LLi

AC

o

D

cc

(0

Piers, Docks, Wharves

♦

Piling & Mooring Dolphins

♦

Bridges

Causeways

Outfalls

□

Cable/Pipeline Crossing

Boathouses

□

Breakwater

z
<

CO

Diking

□

Bulkheading

□

Groins

Jetty

Special Project Fills

*

Bankline Straightening

Bankline Erosion Control

•

-J

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New Access Channel

D

Channel/Berth Maint

□

Channel Realignment

□

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

*

STANDARD USES

See Standard Use
Table

Management Category

UD - Urban Development

Boundary Description

Western Boundary - Management Unit 12, City of

Hoquiam Boundary

Eastern/Study Boundary - Adams St., Burlington

Northern Railroad out to line of Ordinary High

Water.

Management Objectives

The uplands portion of this management unit will
be one of the prime areas for continued heavy
industrial expansion with an emphasis to water
related and dependent uses. The bankline within
this management unit is considered an important
fish and shellfish migrating and feeding area. Any
development within the bankline will be done with
utmost care.

Special Conditions

The following special conditions will apply within
this management unit:

1. A very limited number of "T" docks will be
allowed within this Management Unit. The
principal concern with these structures is
the number of trestle connections to the
shore rather than the length of the dock
structure at the navigation channel.

2. Very limited filling is allowable on the ap-
proach to the "T" dock for the purposes of
establishing a safe and efficient connection
to the shore and, to reduce the high costs of
such structures. Under no circumstances
will such fill extend to the channel portion
of the structure nor will it substantially
interfere with the migration of fish and
shellfish or their rearing and feeding areas.

70

AREA 7 - HOQUIAM FILL

(See Management Unit 12 Exhibit)

Area 7 includes approximately 20 acres of land below the line of non-aquatic vegetation.
This area, and much of the adjacent land is owned by the City of Hoquiam.

Implementation Conditions

The following special conditions have been developed in conjunction with the conditions of
Area 1, Management Unit 12 and are tied, therefore, to their implementation.

1. When a permit is issued for fill in Area 7 for industrial development, fee title will be
transferred for a portion of Area 1, Management Unit 12, on the basis of 3 .4 acres
transferred for each acre filled. The transfer will permanently establish a balance
that is essential to avoid unacceptable adverse impacts to the aquatic ecosystem,
including wetlands (within the meaning of Section 404 guidelines) that might result
from future fills in Area 1, Management Unit 12. Transfer of the title will be done
in accordance with Condition 3 of the Implementation Conditions for Area 1,
Management Unit 12.

2. Filling in this area will be subject to approval through the Section 404 permit
process. However, in the context of the total Management Unit and the total
Estuary Management Plan, such filling is not considered to have an acceptable
adverse impact on the aquatic ecosystem, including wetlands. In addition, the
geographic location of this area, particularly its great distance from the authorized
federal navigation channel, will be taken into account in permit determinations
related to water dependency.

3. As filling occurs, it will be done in accordance with disposal practices approved
through the permit process, including the use of containment structures surrounding
each fill to preclude the unnecessary dispersal of fill material to the adjacent
aquatic area. Although the plan views this area as a fill site, rather than a dredged
materials disposal site, the use of dredged material for fill meeting these special
conditions is appropriate.

71

MANAGEMENT UNIT 15
PLANNING AREA HI

Management Category

UD - Urban Development

Boundary Description

Western Boundary - Management Unit 14
Eastern Boundary - The extension of Michigan
Street to the shoreline

Study Area Boundary - Burlington Northern Rail-
road line out to the line of Ordinary High Water

Management Objectives

This area will serve as one of the principal areas
for heavy industrial expansion for the Grays
Harbor region. The emphasis on use will be for
water related and dependent uses and redevelop-
ment of already developed lands.

Special Conditions

1. Filling and/or development of the existing
Port slips will be allowed subject to
applicable local, state and federal
regulations. Such filling however, is not
considered to be an unacceptable adverse
impact in the context of the total Estuary
Management Plan.

2. Any other filling that may occur in this
management unit also must meet applicable
local, state and federal regulations. By so
doing, it is not the intent of this plan to
preclude the property owners from
submitting proposals that might include the
filling of areas adjacent to this management
unit. However, in such circumstances, any
proposal must demonstrate that the
immediately adjacent uplands are (or will
be) fully developed with water dependent
uses; there are no practicable means of
developing without such fill; and, a
mitigation project (see Mitigation section)
must be developed and approved by state
and federal resource agencies in advance of
permit approval, and an implementation
schedule for the mitigation project
committed to and initiated at the time of
permit issuance.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UD

CO
U

O

1

Z
<
CD

Piers, Docks, Wharves

•

Piling & Mooring Dolphins

•

Bridges

•

Causeways

Outfalls

□

Cable/Pipeline Crossing

•

Boathouses

□

Breakwater

Diking

□

Bulkheading

□

Groins

Jetty

Special Project Fills

*

Bankline Straightening

•

BankHne Erosion Control

•

-J
LU

Z

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New Access Channel

□

Channel/Berth Maint

♦

Channel Realignment

□

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
II

STANDARD USES

See Standard Use
Table

Navigation channel approach structures will
be permitted. Limited filling will be per-
mitted with the structure approach. The
primary purpose of this filling is to cut the
high costs of such a structure. State and
Federal fish and wildlife agencies will
review the proposed fill to ensure that there
is a minimum intrusion on the fish and
shellfish migration route.

A public boat ramp is believed appropriate
within this management unit.

72

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UM

ifi
LU
AC

?

O

D

a,

Piers, Docks, Wharves

•

Piling & Mooring Dolphins

•

Bridges

#

Causeways

Outfalls

•

Cable/Pipeline Crossing

•

Boathouses

□

Breakwater

z
<

CD

Diking

□

Bulkheading

□

Groins

0

Jetty

Special Project FHIs

Bankline Straightening

•

Bankline Erosion Control

•

-J
W

z

z
o

New Access Channel

□

Channel/Berth Maint

p

Channel Realignment

□

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

□

MANAGEMENT UNIT 16
PLANNING AREA II/HI

Management Category

UM - Urban Mixed

Boundary Description

Western Boundary - The extension of Michigan
Street to the shoreline.

Eastern Boundary - Wishkah Railroad Bridge.
Study Area Boundary - Burlington Northern Rail-
road Line out to the line of Ordinary High Water.

Management Objectives

This Management Unit encompasses the area
commonly known as the "Old Aberdeen
Waterfront". Along with other areas in the har-
bor, this portion of the waterfront was the center
of the historic industrial and commercial develop-
ment in the harbor. Changing economic condi-
tions have shifted the center of economic activity
to other areas of the harbor, leaving this area in
need of a major redevelopment effort. The
management objectives for this unit recognize
this need and are designed to support it with a
range of use and activity options that allow
flexibility in the siting and design, and can serve
as a catalyst for the redevelopment effort.

STANDARD USES

See Standard Uee
Table

73

MANAGEMENT UNIT 17
PLANNING AREA H

Management Category

UM - Urban Mixed

Boundary Description

Western Boundary - Wishkah River Railroad
Bridge.

Eastern Boundary - western edge of oil storage
facility.

Study Area Boundary - Burlington Northern Rail-
road line out to the line of Ordinary High Water.

Management Objectives

This area represents one of the few opportunities
to "see the river" from the uplands. At the same
time, it has limited opportunity for major devel-
opment. The management unit will be used
primarily for a mix of private and public uses that
maximize the opportunities for water related
enjoyment.

Special Conditions

In addition to Standard Uses and Permitted
Activities, the following special conditions will
also apply:

1. A public park is proposed by the City of
Aberdeen for passive and active waterfront
recreation. Limited filling is allowable
through the Bankline Straightening Policy.
Some additional filling may be appropriate
for this use, based on the normal 404 permit
process and a review of detailed plans by
state and federal agencies.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UM

CO
LU

£

O
B

Piers, Docks, Wharves

•

Piling & Mooring Dolphins

•

Bridges

•

Causeways

Outfalls

•

Cable/Pipeline Crossing

•

Boathouses

□

Breakwater

□

Z
<

tn

Diking

□

Bulkheading

□

Groins

□

Jetty

Special Project Fills

Bankline Straightening

•

Bankline Erosion Control

•

iij

z
z
<
z
o

New Access Channel

a

Channel/Berth Maint

a

Channel Realignment

a

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•

D

#

STANDARD USES

See Standard Use
Table

74

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UD

N

CO
III

o

I

Piers, Docks, Wharves

•

Piling & Mooring Dolphins

•

Bridges

•

Causeways

Outfalls

□

Cable/Pipeline Crossing

•

Boathouses

D

Breakwater

Z
<
CD

Diking

□

Bulkheading

□

Groins

Jetty

Special Project FHIs

*

*

Bankline Straightening

*

Bankline Erosion Control

•

-I
III

Z

z
<
z
o

New Access Channel

□

Channel/Berth Maint

D

Channel Realignment

□

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
J*

STANDARD USES

See Standard Use
Table

MANAGEMENT UNIT 18
PLANNING AREA U

Management Category

UD - Urban Development/Natural

Boundary Description

Western Boundary - Management Unit 17
Eastern Boundary - See Special Conditions below.
Study Area Boundary - Burlington Northern Rail-
road out to the line of Ordinary High Water.

Management Objectives

It is envisioned that this will be a heavy industrial
area on the north side of the Chehalis River.

Special Conditions

In addition to Standard Uses and Permitted
Activities, the following special conditions will
also apply:

1. No filling will be permitted along Elliott
Slough below the line of non-aquatic vegeta-
tion (Section 404) or to within 100 feet of
the line of Ordinary High Water.

2. Structures will be permitted to approach the
navigation channel. Very limited filling is
allowable at the approach to these struc-
tures for the purposes of establishing a safe
and efficient connection to the shore, and to
reduce the high costs of such structures.
Under no circumstances will such fills
extend to the channel portion of the struc-
ture nor will it substantially interefere with
fish feeding areas or migration routes.

3. Bankline straightening may be appropriate
in very limited circumstances within this
management unit. The primary criteria for
the application of bankline straightening
will be to minimize effects on fish feeding
and migration and to ensure that bankline
straightening is essential to maintaining the
function of the proposed use.

4. The accompanying figure is an enlarged ver-
sion of the boundary between Management
Units 18 and 19 as well as the special split
that occurs within Management Unit 18. In
addition to the designated management
categories, the following conditions will also

75 apply:

a. A 100 foot, no fill/no development buf-
fer will be maintained along Elliott
Slough and along both sides of the
slough (designated Slough A) that inter-
sects with Elliott Slough in the north-
eastern portion of the management
unit.

b. A 50 foot, no fill/no development buf-
fer will be maintained on both sides of
the slough (designated Slough B) in the
southern portion of the management
unit, where that slough is north of the
existing access road.

c. The existing access road in the area
designated as Natural, can be main-
tained and up-graded to permit access
to the Urban Development areas to the
east.

d. The southernmost boundary between
Management Units 18 and 19 is a line
50 feet west and parallel to Slough B,
from its intersection with the existing
access road to its intersection with
Chehalis River.

iPowarHn*

Weyerhaeuser
Mill

5. Other fills above the bankline within the
Urban Development portion of the Manage-
ment Unit may be allowable consistent with
applicable state and federal regulations.

76

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

CM

CO

m

K

o

E

Piers, Docks, Wharves

Piling & Mooring Dolphins

□

Bridges

Causeways

Outfalls

*

Cable/Pipeline Crossing

□

Boathouses

Breakwater

z
<

CD

Diking

Bulkheading

Groins

Jetty

Special Project Fills

Bankline Straightening

Banklme Erosion Control

-J
U

z
z
<
z
o

New Access Channel

□

Channel/Berth Malnt

□

Channel Realignment

□

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
•

STANDARD USES

See Standard Use
Table

MANAGEMENT UNIT 19
PLANNING AREA I

Management Category

CM - Conservancy Managed Special*

Boundary Description

Western Boundary - Management Unit 18 (also see
map on previous page).

Eastern Boundary - a line approximately at the
narrowest point between Chehalis River and the
Burlington Northern Railroad line.
Study Area Boundary - Burlington Northern Rail-
road line out to the line of Ordinary High Water.

Management Objectives

This management unit is between the more
intensely developed areas of Junction City and
the more natural areas upriver. The long-term
utilization of this area has not been determined
by the estuary planning task force. In the short
term, the area will remain in its present, some-
what undisturbed natural condition. Activities
that hinder its natural characteristics, particu-
larly its function as a natural water storage area,
will not be permitted during this interim period.

Special Conditions

In addition to Standard Uses and Permitted
Activities, the following special conditions will
also apply:

1.* This management unit will automatically be
reviewed by the estuary planning task force
in their five year plan review. The purpose
of this review will be to establish a final
management classification for the manage-
ment unit.

2. Any specific project proposals within this
management unit will be reviewed by the
estuary planning task force during their
Annual Review.

3. A potential wastewater treatment plant will
be permitted as a conditional use subject to
local permit approval as well as review and
consensus by the members of the Estuary
Planning Task Force.

77

MANAGEMENT UNIT 20
PLANNING AREA I

Management Category

CM - Conservancy Managed

Boundary Description

Western Boundary - Management Unit 19
Eastern Boundary - the eastern extension of Mox
Chuck Slough to Chehalis River
Study Area Boundary - Burlington Northern Rail-
road line out to the line of Ordinary High Water.

Management Objectives

This area will remain relatively undisturbed from
its present natural condition. Continued use of
the area for wildlife observation and hunting will
be permitted. Activities that hinder its natural
characteristics, particularly its function as a
natural water storage area, will not be permitted.

Special Conditions

In addition to Standard Uses and Permitted
Activities, the following conditions will apply:

1. A potential wastewater treatment plant will
be permitted as a conditional use subject to
local approval as well as to review and
consensus by the members of the estuary
planning task force.

2. Extraction of aggregate resources in areas
outside the river is permitted.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

CM

(0
111
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PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

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STANDARD USES

See Standard Use
Table

78

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UR

to
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PERMITTED ACTIVITY

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M

MANAGEMENT UNIT 21
PLANNING AREA I

Management Category

UR - Urban Residential

Boundary Description

Western Boundary - Management Unit 20
Eastern Boundary - west side of Higgins Slough.
Study Area Boundary - Burlington Northern Rail-
road line out to the line of Ordinary High Water.

Management Objectives

This is one of the few places in the river segment
of Chehalis River where urban/suburban develop-
ment is in close proximity to the river. Limited
urban development will be permitted within this
area. Additionally, this area can provide some
limited opportunities for public access to the
river. However, development of public access
will be done to maintain compatibility with the
natural characteristics of the management unit
and adjacent areas.

Special Conditions

1. Extraction of aggregate resources in areas
outside the river is permitted.

STANDARD USES

See Standard Use
Table

79

MANAGEMENT UNIT 22
PLANNING AREA I

Management Category

RA - Rural Agriculture

Boundary Description

Western Boundary - Management Unit 21
Eastern Boundary - west bankline of Wynoochee
River.

Study Area Boundary - Burlington Northern Rail-
road line out to the line of Ordinary High Water.

Management Objectives

This area will continue to serve as one of the few
agricultural areas within the study limits of the
management plan. Additionally, the area will
serve as one of the region's major extraction
source of aggregate. However, activities associ-
ated with agriculture and aggregate extraction
will be done to maintain compatibility with the
natural characteristics of the area.

Special Conditions

In addition to Standard Uses and Permitted
Activities, the following special conditions will
also apply:

1. Extraction of aggregate resources in areas
outside the river is permitted.

2. Maintenance of existing dikes will be
allowed.

3. New dikes may be appropriate to protect
agricultural land provided they meet appli-
cable State and Federal regulations and do
not encroach into wetlands.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

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111
tt

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i

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Channel/Berth Maint

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PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

STANDARD USES

See Standard Use
Table

80

PERMITTED ACTIVITIES

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

MANAGEMENT CATEGORY

RL

CO

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MANAGEMENT UNIT 23
PLANNING AREA I

Management Category

RL - Rural Low Intensity

Boundary Description

Eastern Boundary - Confluence of Chehalis and

Wynoochee Rivers.

Western Boundary - A point where the highway

and Union Pacific Railroad line leave the parallel

alignment of Chehalis River.

Study Area Boundary - Union Pacific Railroad line

out to the line of Ordinary High Water.

Management Objectives

This management unit presently contains a scat-
tering of single residences on mixed land parcels.
Continuation and some expansion of these uses is
seen as appropriate within the guidelines of Stan-
dard Uses and Permitted Activities. However,
any development activities will be done to main-
tain compatibility with the natural characteristics
of the management unit and adjacent areas.

Special Conditions

1. Extraction of aggregate resources in areas
outside the river is permitted.

STANDARD USES

See Standard Use
Table

81

MANAGEMENT UNIT 2fr
PLANNING AREA I

Management Category

CM - Conservancy Managed

Boundary Description

Eastern Boundary - Management Unit 23

Western Boundary - a line at the eastern edge of

the Weyerhaueser property in Section 24 (T17N,

R9W).

Study Area Boundary - The Union Pacific Railroad

line out to the line of Ordinary High Water.

Management Objectives

This management unit is similar in character and
future use intent to Management Unit 20. Its
relatively undisturbed, natural character will
remain, with continued use for wildlife observa-
tion and hunting encouraged. Activities that
hinder its natural characteristics, particularly its
function as a natural water storage area, will not
be permitted.

Special Conditions

In addition to Standard Uses and Permitted
Activities, the following conditions will apply:

1. Continued maintenance and/or redevelop-
ment of the South Bank Road and railbed
will be permitted.

2. Reconstruction of the South Bank Road or
construction of a new highway in the same
approximate corridor alignment will be per-
mitted. Specific plans for such a facility
will be reviewed by the Estuary Planning
Task Force.

3. Limited filling and erosion control measures
will be permitted only as required for the
reconstruction of the South Bank Road.

4. Extraction of aggregate resources in areas
outside the river is permitted.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

CM

(0
111
a

o

K

£

Piers, Docks, Wharves

Piling & Mooring Dolphins

•

Bridges

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Causeways

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Outfalls

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Breakwater

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Bulkheading

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Channel/Berth Maint

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Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
ft

STANDARD USES

See Standard Use
Table

82

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UD

(0
U

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•

Piling & Mooring Dolphins

•

Bridges

•

Causeways

*

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*

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*

Boathouses

□

Breakwater

Diking

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Bulkheading

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Groins

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Special Project Fills

*

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*

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PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
*

STANDARD USES

See Standard Use
Table

MANAGEMENT UNIT 25
PLANNING AREA I/n

Management Category

UD - Urban Development

Boundary Description

Eastern Boundary - Management Unit 2k.
Western Boundary - east side of Chehalis River
Bridge.

Study Area Boundary - Union Pacific Railroad
line, Burlington Northern Railroad line and the
connection of the two spurs off of the Burlington
Northern Railroad at the northern bend of
Chehalis River out to the line of Ordinary High
Water.

Management Objectives

This is an area of heavy industrial development.
Existing uses will continue with an emphasis on
redevelopment of old facilities and reutilization
of existing sites. Some new expanded develop-
ment is envisioned in the eastern portion of the
management unit although it will be done in a way
that recognizes the need for a transition to the
more natural areas immediately upriver.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following conditions will apply:

1. Maintenance of existing public boat ramps is
permitted.

2. Fills in the eastern undeveloped areas of an
upland character are permitted. Other fills
within this management unit may be allowed
provided they can meet applicable state and
federal regulations. Specifically, bankline
straightening may occur from the extension
of "E" Street, up-river to the existing dis-
charge channel with a priority for such fills
in the area immediately adjacent to the pulp
mill.

3. Construction of the South Aberdeen flood
control project is consistent with the objec-
tives of this management unit.

it. Cable and pipeline crossings, outfalls,

83

bankline straightening, and bankline erosion con-
trol are permitted in that portion of Management
Unit 25 within Planning Area II, and conditional in
that portion of the management unit within Plan-
ning Area I.

5. Reconstruction of the South Bank Road or con-
struction of a new highway in the same approxi-
mate corridor alignment will be permitted.
Specific plans for such a facility will be reviewed
by the Estuary Planning Task Force.

84

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UD

CM

(0

HI

S

g

o

E

Z
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ffi

Piers, Docks, Wharves

•

*

Piling & Mooring Dolphins

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*

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•

•

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•

Outfalls

•

•

Cable/Pipeline Crossing

•

•

Boathouses

Breakwater

Diking

•

Bulkheading

Groins

Jetty

Special Project FHte

*

Bankline Straightening

Bankline Erosion Control

□

□

-1

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PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
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UMDARDUSES %*l£x™

ndard Use

MANAGEMENT UNIT 26
PLANNING AREA II/IV

Management Category

UD/CM - Urban Development/Conservancy Man-
aged

Boundary Description

Eastern Boundary - Management Unit 25
Western Boundary - the east bank of Chapin
Creek.

Split Unit Boundary - the Burlington Northern
Railroad line.

Study Area Boundary - the Burlington Northern
Railroad line westerly to the line between Sec-
tions 16 and 17, T17N, R9W, thence southerly to
the Westport Highway, following the highway
west to the western management unit boundary.

Management Objectives

This is a particularly critical management unit in
that it represents one of the future new industrial
areas and yet contains critical vegetation to
upriver fish migration and feeding. Additionally,
two upland creeks with significant adjacent habi-
tat traverse the area. Preservation of both
features is the key to future use of this area.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following conditions also apply:

1. On the landward side of the railroad line,
heavy industrial development will be per-
mitted consistent with the standard uses for
the Urban Development classification. In
the development of those areas, the riparian
vegetation along Charley and Newskah
Creek will be preserved (see also Conditions
6 and 7 below).

2. On the water side of the railroad line,
limited development of inwater structures
will be permitted in direct support of devel-
opment within the Urban Development area.

3. Also within the Conservancy Managed area,
on the water side of the railroad line, the
existing treatment ponds and the Saginaw
Mill site will be permitted to continue as
will maintenance of the bankline of the
treatment ponds and railroad line.

85

4. While development activity will be per-
mitted throughout this management unit,
the overriding interest is in the preservation
of the existing salt marsh areas. Modifica-
tion of those areas will only be possible as
necessary to build structures or maintain
banklines as specified in the preceding con-
ditions.

5. Construction of the South Aberdeen flood
control project is consistent with the objec-
tives of this management unit.

6. A 50 foot, no fill/no development buffer
(including roads) will be maintained along
both sides of main stems of Charley and
Newskah Creeks.

7. It is recognized that fills will be required in
this management unit to accomplish its
Urban Development objectives. It is also
recognized that there are areas within this
management unit that are, by definition,
wetlands. Therefore fills, occurring in these
latter areas that are done to meet the
development objectives of this management
unit must also meet the tests of applicable
state and federal regulations.

86

MANAGEMENT UNIT 27
PLANNING AREA IV

Management Category

RL - Rural Low Intensity

Boundary Description

Eastern Boundary - Management Unit 26.
Western Boundary - state property boundary on
the southern line of Section 36 (T17N, R11W).
Study Area Boundary - Burlington Northern Rail-
road line.

Management Objectives

Scattered residences exist throughout this general
area although few, if any, exist on the water side
of the railroad line. Continued development of
this general character is considered appropriate in
this management unit.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

RL

CO

in
S

o

E

z
<

CD

Piers, Docks, Wharves

Piling & Mooring Dolphins

□

Bridges

Causeways

Outfalls

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Cable/Pipeline Crossing

Boathouses

Breakwater

Diking

Bulkheading

Groins

Jetty

Special Project Fills

Bankline Straightening

Bankline Erosion Control

•

-1
U

z
z
<
z
o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

«

STANDARD USES

See Standard Use
Table

87

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UD

CM

Uj

O
(0

Piers, Docks, Wharves

•

*

Piling & Mooring Dolphins

•

*

Bridges

□

*

Causeways

Outfalls

□

□

Cable/Pipeline Crossing

D

*

Boathouses

□

Breakwater

z
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□

Groins

Jetty

Special Project FHIs

Bankline Straightening

BankHne Erosion Control

□

*

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New Access Channel

D

Channel/Berth Maint

□

Channel Realignment

□

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
*

STANDARD USES

See Standard Use
Table

MANAGEMENT UNIT 28
PLANNING AREA IV

Management Category

UD/CM - Urban Development/Conservancy Man-
aged

Boundary Description

Eastern (North) Boundary - Management Unit 27
Western (South/East) Boundary - Westport High-
way to a line just east of the west line of Section
1 (T16N, R11W) to the intersection of the small
slough with Johns River, approximately 800 feet
east of the Westport Highway Bridge.
Split Unit Boundary - line of non-aquatic vegeta-
tion.

Study Area Boundary - the Burlington Northern
Railroad line and the northern quarter section line
of Section 1 (T16N, R11W), the northern boundary
line of the Johns River Wildlife Recreation Area.

Management Objectives

This is one of the few industrial areas outside of
the greater Aberdeen/Hoquiam area. The existing
agricultural processing facility is seen as impor-
tant to the continued viability of the region's
cranberry crops. Continuation of that activity
and other necessary supporting facilities is appro-
priate as are the present oyster plants. This is
also an area of significant wetlands and thereby
creates a potential for conflict. While the man-
agement philosophy expressed by the definition of
Conservancy Managed appropriately fits this area,
the permitted conditional uses of CM do not
automatically fit the unique circumstances in this
management unit and the adjacent uplands.

Special Conditions

In addition to the Standard Uses and Permitted
Activities, the following special conditions will
also apply:

1. Maintenance of existing oyster docks and
facilities is considered appropriate.

2. Development of a limited number of new
docks and piers in direct support of adja-
cent, upland water dependent uses is

88

considered appropriate. Under such
circumstances, special design and con-
struction measures may be required to
minimize destruction or modification
of the wetlands.

3. A utility corridor for cable and pipe-
line crossing is permitted adjacent and
parallel to the highway bridge.

4. Maintenance of the highway bridge
and transportation corridor is allowed.

89

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

CM

N

CO

HI

K

O

D

I

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Piers, Docks, Wharves

Piling & Mooring Dolphins

Bridges

*

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Causeways

Outfalls

Cable/Pipeline Crossing

Boathouses

Breakwater

Diking

□

Bulkheading

Groins

Jetty

Special Project Filis

Bankline Straightening

Banklbie Erosion Control

-J
U

z
z
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o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
«

STANDARD USES

See Standard Use
Table

MANAGEMENT UNIT 29
PLANNING AREA IV

Management Category

CM/N - Conservancy Managed/Natural

Boundary Description

Northern Boundary - Management Unit 28
Southern Boundary - the extension of Johns River
Road

Split Unit Boundary - line of non-aquatic vegeta-
tion (Section 404)

Study Area Boundary - a line 200 feet landward
from the line of non-aquatic vegetation or the
boundary line of the Johns River Game Range,
whichever is greater, including all of the water
area to be western boundary of Management Unit
28.

Management Objective

The Johns River area is considered one of the
prime natural areas in the estuary. This manage-
ment unit will continue to support that designa-
tion and ensure that an adequate buffer exists to
minimize any potential negative effects of activi-
ties on adjacent lands.

Some portions of this management unit have been
diked and provide the definition for that area to
be managed under a Conservancy designation.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following special conditions will also
apply:

1. Maintenance of the existing public boat
ramp is permitted.

2. Maintenance of the bridge and transporta-
tion corridor is permitted.

90

MANAGEMENT UNIT 30
PLANNING AREA IV

Management Category

RL/CN - Rural Low Intensity/Conservancy
Natural

Boundary Description

Eastern Boundary - Management Unit 29.
Western Boundary - east side of the intersection
of Redman Slough with the estuary.
Split Unit Boundary - line of non-aquatic vegeta-
tion.
Study Area Boundary - the old railroad grade.

Management Objectives

This management unit will continue to serve as a
low intensity rural area with scattered homes and
generally sparse development. In addition, sig-
nificant wetland areas exist within this manage-
ment unit and will be preserved.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following special conditions will also
apply:

1. A limited number of small private docks will
be permitted in conjunction with upland
residences.

2. Maintenance of existing boathouses is per-
mitted.

3. A utility corridor for cable and pipeline
crossing is permitted adjacent and parallel
to the highway bridge.

k. Maintenance of the highway bridge and
transportation corridor is allowed.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

RL

CN

Hi
Ul

AC
O

1

Piers, Docks, Wharves

•

*

Piling & Mooring Dolphins

Bridges

•

*

Causeways

Outfalls

□

□

Cable/Pipeline Crossing

•

ale

Boathouses

□

*

Breakwater

*
Z
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£Q

Diking

□

Bulkheading

□

Groins

Jetty

Special Project Fills

BankHne Straightening

BankHne Erosion Control

□

*

mi

u

z
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<
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New Access Channel

Channel/Berth Main!

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

*

STANDARD USES

See Standard Use
Table

91

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

RA

U

o

E

Piers, Docks, Wharves

Piling & Mooring Dolphins

□

Bridges

Causeways

Outfalls

Cable/Pipeline Crossing

Boathouses

Breakwater

z
<

CD

Diking

*

Bulkheading

Groins

Jetty

Special Project Fills

Bankline Straightening

Banklirte Erosion Control

□

-1
111

Z

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<

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New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
*

MANAGEMENT UNIT 31
PLANNING AREA IV/VII

Mangement Category

RA - Rural Agriculture

Boundary Description

Eastern Boundary - Management Unit 30
Western (South) Boundary - the straight line
extension of the east-west segment of the
Westport Highway in Section 9 (T17N, R11W).
Study Area Boundary - shoreline management
boundary.

Management Objectives

This management unit will continue to serve as an
agricultural area with scattered farm homes.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following special conditions will also
apply:

1. Maintenance of existing dikes is permitted.

STANDARD USES

See Standard Use
Table

92

MANAGEMENT UNIT 32
PLANNING AREA VII

Management Category

RL - Rural Low Intensity

Boundary Description

Northern Boundary - Management Unit 31
Southern Boundary - southern line of Section 16
(T16N, R11W).
Study Area Boundary - Westport Highway.

Management Objectives

This area will continue to be used for scattered
residences on mixed land parcels with a generally
low intensity use character throughout.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following special conditions will also
apply:

1. Maintenance of existing dikes is permitted.

2. A limited number of small private docks will
be allowed in conjunction with upland resi-
dences.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

RL

(0
m

a

e

I

Z
<
CO

Piers, Docks, Wharves

*

Piling & Mooring Dolphins

*

Bridges

Causeways

Outfalls

Cable/Pipeline Crossing

Boathouses

Breakwater

Diking

*

Bulkheading

Groins

Jetty

Special Project FHIs

Bankline Straightening

Bankline Erosion Control

D

-1
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z
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<

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New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□ '
&

STANDARD USES

See Standard Use
Table

93

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UM

CM

UJ

AC

o

£

Piers, Docks, Wharves

•

*

Piling & Mooring Dolphins

•

*

Bridges

•

*

Causeways

Outfalls

□

□

Cable/Pipeline Crossing

•

*

Boathouses

□

*

Breakwater

z
<

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Diking

□

Bulkheading

□

Groins

Jetty

Special Project FHIs

Bankline Straightening

Bankline Erosion Control

*

♦

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New Access Channel

Channel/Berth Mabit

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
D

STANDARD USES

See Standard Use
Table

MANAGEMENT UNIT 33
PLANNING AREA VTI

Management Category

UM/CM - Urban Mixed/Conservancy Managed

Boundary Description

Northern Boundary - Management Unit 32
Eastern Boundary - a line approximately 500 feet
east of a local service road intersection with the
shoreline at Beardslee Slough.
Split Unit Boundary - line of non-aquatic vegeta-
tion.

Study Area Boundary - Westport Highway and a
line approximately 250 feet north of local service
road on the east side of the highway.

Management Objectives

This small management unit ecompasses the unin-
corporated community of Bay City. By reason of
its relationship to the Elk River Bridge and
Westport Highway, it represents a good location
for local highway service uses. The designation of
this management unit as Urban Mixed will permit
these activities to continue and will allow some
limited expansion. It is not anticipated that the
full range of Standard Uses permitted in Urban
Mixed will be appropriate in this area.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following special conditions will also
apply:

1. Small, private boat docks associated with
upland residences are permitted.

2. A utility corridor for cable and pipeline
crossing is permitted adjacent and parallel
to the highway bridge.

3. Maintenance of the highway bridge and
transportation corridor is allowed.

94

MANAGEMENT UNIT 3fr
PLANNING AREA VII

Management Category

CM/N - Conservancy Managed/Natural

Boundary Description

Eastern Boundary - Management Unit 33
Western Boundary - Westport Highway.
Split Unit Boundary - line of non-aquatic vegeta-
tion and all water area to the Westport Highway
Bridge* (5).

Management Objectives

This is one of the significant natural areas in the
estuary. The Elk River tideflats and water area
contain some of the most significant wildlife
populations and habitat. Classification of this as
a natural area will not preclude its use for wild-
life observation and hunting but will ensure that
the natural characteristics are preserved. The
management concept also establishes a buffer
area around the natural designation to ensure
maximum compatibility with adjacent uses.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following special conditions also apply:

1. While the intent of this management desig-
nation is to keep the area in a natural
condition as it presently exists, continuation
and limited expansion of certain existing
uses and activities such as oyster culture is
considered appropriate.

2. Stake and bottom oyster culture are per-
mitted methods.

3. Limited raft oyster culture is considered
appropriate.

k. Maintenance of existing boat ramps is per-
mitted.

5. The Natural boundary extends to the bridge
except as relates to the permitted uses and
activities associated with Management
Units 33 and 35.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

CM

N

U
K

O

1

Piers, Docks, Wharves

□

Piling & Mooring Dolphins

□

Bridges

□

Causeways

Outfalls

Cable/Pipeline Crossing

Boathouses

Breakwater

*
Z
<

Diking

a

Bulkheading

Groins

Jetty

Special Project FHis

Bankline Straightening

Bankline Erosion Control

-1
UJ

z
z
<
z
o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
a
4

STANDARD USES

See Standard Use
Table

6. Those activities permitted in Management
Units 35 and 33 that require intrusion into
this management unit are permitted pro-
vided they are done in a way that is consis-
tent with the natural character and manage-
ment objectives of this management unit
and through the conditional use process.

95

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UM

CM

0)
111

O

D

Piers, Docks, Wharves

□

□

Piling & Mooring Dolphins

•

D

Bridges

•

*

Causeways

Outfalls

D

□

Cable/Pipeline Crossing

•

*

Boathouses

□

*

Breakwater

□

Z
<

Diking

□

Bulkheading

Groins

Jetty

Special Project Fills

BankHne Straightening

BankHne Erosion Control

*

*

-j
u

z
z
<

X

o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

•

STANDARD USES

See Standard Use
Table

MANAGEMENT UNIT 35
PLANNING AREA VTI

Management Category

UM/CM - Urban Mixed/Conservancy Managed

Boundary Description

Western Boundary - a line located 200 feet west
of the intersection of the local service road and
the Westport Highway, drawn generally north-
south across the point of land at the west end of
the Elk River Bridge.

Split Unit Boundary - line of non-aquatic vegeta-
tion.

Management Objectives

This management unit is similar in character and
future use intent to Management Unit 33. It is
designed as a small area of mixed urban uses
taking advantage of its unique location at the
highway and the bridge. It is not expected that
this area will take on the intensity or full charac-
ter of the Bay City side of the bridge. Several
areas of significant wetlands exist within this
management unit and will be preserved.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following special conditions will also
apply:

1. A utility corridor for cable and pipeline
crossing is permitted adjacent and parallel
to the highway bridge.

2. Maintenance of the bridge and transporta-
tion corridor is permitted.

3. Maintenance of boathouses and skid ways is
permitted.

k. Rip-rap of existing bankline to protect per-
mitted uses is considered appropriate.

96

MANAGEMENT UNIT 36
PLANNING AREA VII

Management Category

RL/CM - Rural Low
Managed

Boundary Description

Intensity/Conservancy

Southern Boundary - Management Units 3^ and 35
Northern Boundary - Westerport city limits, gen-
erally defined by the half section line in Section
18(T16N, R11W).

Split Unit Boundary - line of non-aquatic vegeta-
tion (Section 404).

Study Area Boundary - a line 200 feet landward
from the line of non-aquatic vegetation (Section
404).

Management Objectives

This is somewhat of a transition management unit
between the more natural areas to the south and
the urban areas of Westport. The management
philosophy of this unit preserves the shoreline
area in a relatively undisturbed condition. The
landward portion of the unit is intended to remain
a low intensity use area.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

RL

CM

ill

o

i

z
<

CO

Piers, Docks, Wharves

Piling & Mooring Dolphins

□

Bridges

Causeways

Outfalls

□

□

Cable/Pipeline Crossing

Boathouses

Breakwater

Diking

□

Bulkheading

Groins

Jetty

Special Project Fills

Bankline Straightening

Bankline Erosion Control

D

-J
u

z
z
<
z
o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
•

STANDARD USES

See Standard Use
Table

97

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UM

CM

(ft
IU

O

D

E

Piers, Docks, Wharves

Piling & Mooring Dolphins

Bridges

Causeways

□

Outfalls

□

□

Cable/Pipeline Crossing

Boathouses

Breakwater

z
<

CO

Diking

□

Bulkheading

Groins

Jetty

Special Project FHIs

Bankline Straightening

Bankline Erosion Control

□

_J
111

z
z
<

o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

ft

MANAGEMENT UNIT 37
PLANNING AREA Vffl

Management Category

UM/CM - Urban Mixed/Conservancy Managed

Boundary Description

Southern Boundary - Management Unit 36
Northern Boundary - Pacific Avenue.
Split Unit Boundary - the line of non-aquatic
vegetation (Section 404).

Study Area Boundary - a line approximately 200
feet landward of the line of non-aquatic vegeta-
tion.

Management Objectives

This management unit is intended to establish an
eastern line of limitation for the expanding urban
areas of Westport. There is considerable salt
marsh in the eastern portion of the management
unit and will be preserved in its natural condi-
tions.

STANDARD USES

See Standard Use
Table

98

MANAGEMENT UNIT 38
PLANNING AREA Vffl

Management Category

UM/CN - Urban Mixed/Conservancy Natural

Boundary Description

Southern Boundary - Management Unit 37

Northern Boundary - the line between the City of

Westport Airport property and the lands owned by

the Port of Grays Harbor. This line is further

defined by a drainage ditch between the two

properties.

Split Unit Boundary - the line of non-aquatic

vegetation (Section 404).

Study Area Boundary - a line 200 feet landward of

the line of non-aquatic vegetation.

Management Objectives

This management unit contains considerable salt
marsh areas as well as the existing Westport
Airport. Both uses are important to the local
area and the regional economy and both will be
preserved.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following conditions also apply:

1. Filling to raise the existing Westport air-
field is allowed in this management unit.
The specific area of that fill is described by
the drainage ditch on the east to a line
perpendicular to the ditch that intersects
the northeast corner of Lot 4, Block 6, in
the plat of Chehalis, Section 7, T16N, R11W,
to the south of the present airfield. Any
filling must comply with appropriate per-
mitting processes, including the Section 404
permit process. However, based upon cur-
rent information, the raising of the airfield
would not have an unacceptable adverse
impact on the ecosystem, including wet-
lands.

2. Regarding the marina expansion project pro-
posed in Management Unit 39, one of the
important considerations in evaluating final
design options will be the ability to obtain
adequate flushing within the marina to
maintain water quality conditions necessary
to protect aquatic resources. It is possible
that considering design options which would
achieve better flushing characteristics, very

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UM

CN

(0

UJ

S

i

Piers, Docks, Wharves

Piling & Mooring Dolphins

□

Bridges

Causeways

Outfalls

□

□

Cable/Pipeline Crossing

Boathouses

Breakwater

Z
<

m

Diking

□

*

Bulkheading

Groins

Jetty

Special Project Fills

*

*

Bankline Straightening

Bankline Erosion Control

□

*

-i

UJ

z
z
<
z
o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

m

STANDARD USES

See Standard Use
Table

99

limited encroachment into Management
Unit 38 might be considered. However,
encroachment into Management Unit 38 will
not be permitted if another alternative to
protecting water quality for fisheries
resources, such as artificial aeration or
basin redesign, is feasible. Any suspected
water quality problems must be clearly
demonstrated through physical hydrolic
modelling, mathematical modelling, or other
appropriate methods. This determination
will be made by EPA, Corps of Engineers
and state and federal resources agency per-
sonnel at the time marina design options and
alternative methods for maintaining water
quality are evaluated. Mitigation would be
required for any loss of wetlands within
Management Unit 38.

100

MANAGEMENT UNIT 39
PLANNING AREA VIII

Management Category

UM - Urban Mixed

Boundary Description

Southern Boundary - Management Unit 38
Western Boundary - a point where the old
railroad grade intersects with the shoreline
of the western side of Point Chehalis.
Study Area Boundary - State Highway and
Jetty Haul Road.

Eastern Boundary - the waterward boundary
includes all of the water area of the existing
marina and protective breakwater.

Management Objectives

This is the most intensely developed man-
agement unit in this portion of the estuary.
It is designed to accommodate the major
commercial and sport fishing requirements
of the Westport area. Intensive use of the
shoreline and backup areas is envisioned for
both private and public activities.

Special Conditions

In addition to Standard Uses and Permitted
Activities, the following conditions will also
apply:

1. The new marina is permitted in the
southeastern portion of the manage-
ment unit.

2. The project is envisioned to involve a
plan generally consistent with the size
identified in Alternative 2, the Public
Brochure released by the Corps of
Engineers entitled, Alternatives and
Their Pros and Cons, Small-Boat
Basin, Grays Harbor, Washington, Area
A - Westport, Draft #3, September,
1973. While such a project must meet
applicable local, state and federal
regulations, it is not considered an
unacceptable adverse impact in the
context of the total Estuary Manage-
ment Plan.

Filling as may be required by the
Westport Marina Expansion Plan is

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

UM

CO

Ul
K

o

CO

Piers, Docks, Wharves

•

Piling & Mooring Dolphins

•

Bridges

Causeways

Outfalls

•

Cable/Pipeline Crossing

Boathouses

•

Breakwater

•

z
<
to

Diking

□

Bulkheading

*

Groins

•

Jetty

•

Special Project Fills

*

Bankline Straightening

Bankline Erosion Control

•

-I
u

z
z
<
z
o

New Access Channel

•

Channel/Berth Maint

•

Channel Realignment

•

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
«

STANDARD USES

See Standard Use
Table

101

permitted including necessary

reconstruction of existing docks,
breakwater, or other existing facilities
to permit optimum use of the existing
marina.

4. Design options that are developed and
evaluated as a part of the marina
expansion permit may be constrained
by factors in Management Unit 38.
Prior to any final evaluations, the
conditions and management objective
of that Management Unit should be
reviewed for compliance.

102

MANAGEMENT UNIT ftO
PLANNING AREA Vffl

Management Category

CM - Conservancy Managed

Boundary Description

Eastern Boundary - Management Unit 39

Western Boundary - the western terminus of the

south jetty ruins.

Study Area Boundary - the Jetty Haul Road.

Management Objectives

This management unit is similar to Management
Unit 1 and is intended for exclusive public recrea-
tional uses.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

CM

(0
HI

cc

e

o

i

Piers, Docks, Wharves

□

Piling & Mooring Dolphins

Bridges

Causeways

Outfalls

Cable/Pipeline Crossing

Boathouses

Breakwater

z
<

CO

Diking

Bulkheading

Groins

•

Jetty

•

Special Project Fills

BankHne Straightening

BankHne Erosion Control

•

-4
III

z
z
<

o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

STANDARD USES

See Standard Use
Table

103

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

N

CO

ui

AC

o

z
<

CO

Piers, Docks, Wharves

Piling & Mooring Dolphins

Bridges

Causeways

Outfalls

Cable/Pipeline Crossing

Boathouses

Breakwater

Diking

Bulkheading

Groins

Jetty

Special Project FHIs

Bankline Straightening

Bankline Erosion Control

-1

y

z
z
<
z
o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□

M

MANAGEMENT UNIT frl
PLANNING AREA V

Management Category

N - Natural

Boundary Description

The general zone around Goose and Sand Islands,
specifically the Department of Natural Resources'
Scientific Preserves plus an area equal to an
additional Yi mile around the islands.

Management Objectives

This area is intended as a natural area exclusively
for wildlife habitat enhancement and preserva-
tion.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following special conditions apply:

1. Bed type oyster culture is permitted.

2. Commercial fishing is permitted.

STANDARD USES

See Standard Use
Table

104

MANAGEMENT UNIT »2
PLANNING AREA IV

Management Category

CN - Conservancy Natural

Boundary Description

The general zone known as Whitcomb Flats.

Management Objectives

This area is designed to remain undisturbed. The
area contains some valuable oyster beds, however,
which will continue to be viewed as an important
resource for protection and harvesting.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following special conditions will also
apply:

1. While this management unit is to remain
predominantly undisturbed, continued use of
the area for oyster culture and commercial
fishing is permitted.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

CN

(0

LU
CC

O

1

Z
<
OQ

Piers, Docks, Wharves

Piling & Mooring Dolphins

Bridges

Causeways

Outfalls

Cable/Pipeline Crossing

Boathouses

Breakwater

Diking

Bulk heading

Groins

Jetty

Special Project FHIs

BankHne Straightening

Banklme Erosion Control

-I

yj

z
z
<
z
o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□ '
*

STANDARD USES

See Standard Use
Table

105

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

CM

HI

o

CO

Piers, Docks, Wharves

□

Piling & Mooring Dolphins

•

Bridges

Causeways

Outfalls

□

Cable/Pipeline Crossing

•

Boathouses

Breakwater

*

z
<

CD

Diking

□

Bulkheading

Groins

Jetty

Special Project FHIs

Bankline Straightening

Bankline Erosion Control

□

•J
LU

Z

z
<

o

New Access Channel

Channel/Berth Maint

Channel Realignment

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□
*

STANDARD USES

See Standard Use
Table

MANAGEMENT UNIT »3
PLANNING AREA HI

Management Category

CM - Conservancy Managed

Boundary Description

The Rennie Island area including the dredge spoils
island to the west out to the line of Ordinary High
Water.

Management Objectives

This area has served as a dredge materials dispo-
sal area and as a waste treatment pond for many
years. While dredge spoiling will continue in the
area for some time, the long term use will be for
wildlife and water fowl habitat enhancement and
development.

There may be opportunity to use dredged mater-
ials in this area to develop marsh habitat through
experimental management programs.

Special Conditions

In addition to Standard Uses and Permitted Acti-
vities, the following conditions will also apply:

1. In the area currently used for waste treat-
ment ponds, inlet pipes and outfall struc-
tures may continue to be used in support of
requirements of state and federal waste
discharge permits.

2. The disposal of dredged materials will be
permitted to continue in those areas pre-
sently authorized.

3. Experimental resource utilization and habi-
tat development programs such as those
currently available through the Corps of
Engineers may be pursued subject to design
and review by state and federal resource
agencies.

106

MANAGEMENT UNIT frfr
PLANNING AREA

Management Category

CM - Conservancy Managed

All the water and tideland area waterward of the
Ordinary High Water Line not included in other
designated management units (see Special Condi-
tions below also).

Management Objectives

This special management unit includes all the
remaining area within the study area of the
estuary management plan not covered by other
management units. It is essentially all the water
area and is intended to be managed for multiple
uses within an overriding "conservancy" designa-
tion. The conservancy designation is designed to
protect areas for purposes that directly use or
depend on natural systems. Activities which
occur in the estuary should therefore be compa-
tible with those natural systems in order to main-
tain the carrying capacity and biological producti-
vity of the bay. Because those systems are easily
upset by man-made disturbances, special condi-
tions are imposed to ensure that activities are
carried out in a manner which does not reduce or
degrade these estuarine resources.

Special Conditions

1,

Activities in Unit 44 should be compatible
with the natural system. For example,
areas of significant fish and wildlife habitat
should be managed to ensure continued bio-
logical productivity. Where consistent with
resource capabilities, high-intensity water-
dependent recreation, dredging, and other
water-dependent uses are to be provided
for. Thus, those uses that depend on the
water area (e.g., shipping and fishing) and
the activities that support those uses (main-
tenance dredging, navigation aids, etc.) are
generally considered appropriate to the
Management Unit. While the definition of
Conservancy Managed is appropriate to this
management unit, the set of Standard Uses
normally assigned to this category are not.
Therefore, a special column is added to the
Standard Use Table on Page 109 for
Management Unit 44.

PERMITTED ACTIVITIES

MANAGEMENT CATEGORY

CM

CO

Hi

cc

p

I

Piers, Docks, Wharves

*

Piling & Mooring Dolphins

□

Bridges

Causeways

Outfalls

*

Cable/Pipeline Crossing

*

Boathouses

*

Breakwater

*

z
<

CO

Diking

Bulkheading

Groins

*

Jetty

*

Special Project Fills

♦

Bankline Straightening

BankHne Erosion Control

-1
til

z
z
<
z
o

New Access Channel

♦

Channel/Berth Maint

•

Channel Realignment

*

PERMITTED ACTIVITY

CONDITIONAL ACTIVITY

SPECIAL CONDITIONS

•
□ '
*

STANDARD USES

See Standard Use
Table

107

APPENDIX A
STANDARD USE MATRIX

2. All new allowable or expanded on-site
existing uses occurring within
Management Unit 44, that by their
nature are independent from direct
upland support (except by authorized
federal navigation projects) and that
require a construction permit, are
considered conditional uses by this
plan.

3. Uses permitted in shoreline
management units that are water
dependent/related and/or require some
form of access into Management Unit
44 as a direct support for that
shoreline use are permitted in
Management Unit 44 only to the
extent necessary to provide that
access and/or only to the extent
covered in other Special Conditions.

4. Experimental resource utilization and
habitat development programs such as
those currently available through the
Corps of Engineers may be pursued
provided that such programs would not
interfere with uses and activities
allowed in adjacent management units.
Any such programs will be subject to
review and approval by state and
federal resource agencies.

5. Extraction of aggregate resources in
Chehalis River above Cosmopolis is
permitted under the following
conditions:

a. The extraction of aggregate as a
part of channel and berth
maintenance is allowable.

b. Extraction of aggregate within the
river but not as a part of channel
maintenance may be allowed
providing that:

1) there are no alternative sources
of aggregate within the general
Montesano, Aberdeen, Hoquiam, or
Cosmopolis area; 2) water quality
standards can be met; 3) there will
be no adverse impacts on fish
habitat or seasonal fish runs.

8. Realignment or improvement of the
authorized federal navigation channel
is neither permitted nor prohibited by
this plan. Instead, such activities will
be considered through existing
procedures.

108

STANDARD USES

0 PERMITTED USE

Q SEE SPECIFIC MANAGEMENT UNIT
GUIDELINES

USE CATEGORY

PORT
FACILITIES

MANUFACTURING
AND OTHER

Dock and Warehouse Facilities

Port Terminal Facilities

Ship Berthing

Barge Berthing

Ship Construction and Repair

Navigational Aids

Heavy Industry

Light Industry

Water Dependent Industry

Mineral Extraction and Storage

<

oc
o

a.

z
<
oc

_fc.

FOOD
INDUSTRY

Forest Products Processing

Ferry Terminal

Shipping

Roads and Railroads

Airports

Overhead Utility Corridor

Submerged Utility Corridor

Commercial Fishing (Inch Shellfish)

Oyster Culture

Aquaculture

Fish and Food Processing

COMMERCIAL

Z

o

<
UJ

OC

o

111

oc

Motel

Boat Sales, Construction and Repair

Restaurant

Marina

Other Commercial

Public Fishing Areas

Water Dependent Hunting

RESIDENTIAL

Pleasure Boating

Camping

Public Boat Ramp

Park/Parkway, Other Public Access

Floating Homes

Urban/Suburban

Rural Low Intensity (Scattered)

Rural Agricultural (Farm House)

Major Cultivated Crops

AGRICULTURE

NATURAL
AREAS

Passive Agriculture

Subsistence/Local Market Farming

Tree Farm

Estuarine and Marine Sanctuaries

Wildlife Refuges

Living Resource Production and Habitat

109

APPENDIX B
AREAS USED FOR LOG RAFTING

11

en w

-1 cr
O

DQ
DC
<

I

DC

2

Q
LU

§ CO
CO £

55 o

cr

<

no

APPENDIX C
GRAYS HARBOR ESTUARY MANAGEMENT PLAN
PLANNING AREAS AND MANAGEMENT UNITS

N D

ory

Nl

ncy Natural (CN)
ncy Managed (CM )
ricultural ( RA I
v Density I RL I
»sidential I UR )
xed I UM )
tvelopment I UD I

Conservancy Managed I
ent Unit Number -Category
ent Unit Boundary
»a Boundary

lanagement Unit Boundary
Area

i

5000

Scale in Feet

5 000

15.000

Grays Harbor Estuary Management Program

2

<

O m

6

( y«hul

io-rl\\ >^\

>t*

UM/J.

/ 5"l\R

f OCEAN \"
SHORES

4-UM

2-i

N 0 R T

BAY

V

\!41t:n:;::;:;*

Grays Harbor

fl-OlH.ati.

HlOQUIAM
14-UD

ABERDEEN

1 — i i6-ui\

" ib-uui ■ "A® J

18-UD/N

■flK

-,#

"*»»iinniiM»"",,,*'1E

G R A Y S

,# i

>* HA R BO R

5-UD*
26UD/CM -"coSMOPOLIS

WK

Central Park
,20-CM^ 21-UR

/

. ....iillllllKH^IIIHIllllllllllllllllltll
lllllinM' m V^X .*..*»• am* ■-

«V-

^

40 -CM

IV

#'

24 -CM

/

//

//
//

o

38-UM/<J*&ft |(.ih ^Q^i" CNT

Vi-

S O U T H
J?

Arbor
*28-UD/CM

\HII lliinlffli1*r

^ 1I'c1m\n

LEGEND
Management Category

B

AY #32-RL „,#*

IL*

Ms*

1% *

, 55- N ,

MONTESANO

3 Natural I N I
Conservancy Natural ICNI
Conservancy Managed I CM I
Rural Agricultural I RA I
Rural Low Density I RL I
Urban Residential I UR I
Urban Mixed I UM I
Urban Development I UD I
Unit 44 I Conservancy Managed I
Management Unit Number -Category
Management Unit Boundary

""«""'."' Study Area Boundary

'»------' Aquatic Management Unit Boundary

« SP I Special Area

btftLE in for

SQOO 10 MO 15 000

^^ L^— I

APPENDIX B
FEDERAL AGENCIES LETTERS OF INTENT

U.S. ENVIRONMENTAL PROTECTION AGENCY
.x\ to sr4, REGION X

£>' ^^^ X> UOO SIXTH AVENUE

" ^SS^T £ SEATTLE, WASHINGTON 98101 C7.l'\

ysay

1382 NOV 29 AH ID 1

ATTN OF: M/S 423 ..,.,, p-.-nj

ri.-»iu i\ ^*-<i I

NOV 2 2 1932

Donald Moos, Director
Washington Department of Ecology
Mail stop PV-11
Olympia, Washington 98504

RE: Grays Harbor Estuary Management Plan

Dear Mr. Moos:

This letter of intent is provided to develop an understanding on how EPA
intends to use the Grays Harbor Estuary Management Plan (GHEMP). We
understand the plan will be amended into the local Shoreline Management
Master Program for the county and incorporated cities with jurisdiction
in the estuarine area, and adopted as state regulations by the Department
of Ecology under the Shoreline Management Act.

The GHEMP was developed with the participation and consensus of the
various local, state, and Federal agencies responsible for estuarine
resource development and preservation in the area. By bringing together
these entities, it was hoped that a common set of goals and objectives
could be developed which took into account the respective authorities and
standards of each jurisdiction. The GHEMP provides a mechanism to reach
balanced decisions regarding necessary development and preservation of
natural resources in the estuary. As a result, time delays in obtaining
permits should be significantly reduced.

The Environmental Protection Agency (EPA) participated in the planning
process by virtue of its role in the Section 404 dredge and fill permit
program administered by the U. S. Army Corps of Engineers. Under Section
404 of the Clean Water Act, EPA recommends to the Corps actions necessary
for the protection of water quality and associated beneficial uses,
including municipal water supplies, shellfish beds and fishery areas,
wildlife, and recreation areas. EPA believes that protection of water
quality and related uses has been incorporated into the GHEMP on an
estuary-wide basis, and in some cases on a site-specific basis. As a
result, EPA intends to use the GHEMP in our permit review evaluation in
conjunction with our Section 404(b)(1) regulatory guidelines.

B-l

EPA is unable to commit ourselves to planning recommendations for
specific projects in advance of actual permit application. The nature of
Federal legislation is such that existing laws and environmental criteria
may change, which precludes our prejudging project proposals until they
become actual permit applications. Current examples of this are
reauthorization of the Clean Water Act and revision of the 404(b)(1)
guidelines. Project proposals must, therefore, be evaluated at the time
of permit application under then existing requirements.

We recognize that planning under the State of Washington Shoreline
Management Act is a necessary and worthwhile activity. Development of
the GHEMP has certainly been a commendable effort. We have appreciated
the opportunity to work on the GHEMP and look forward to its successful
implementation.
\

^inoerXV.

RegionaUA&ninistrator

B-2

January 5, 190?

Donald W. Moos, Director
Washington Department of Ecology
CljTipia, Washington 98504

Pear Mr. Moos:

The Fish and Wildlife Service has been actively involved in the Grays Harbor
Estuary Management Plan (GHEMP) for several years. We have supported the
development of GHEMP because 1t provides predictability to development inter-
ests while providing long-term protection for important natural resources.

The key concept upon which the GHEMP is premised is balance. This "balance"
oust be maintained through reasonable interpretation of the plan, as well as,
through any changes which may occur to the plan in the future.

This Service intends to use the GHEMP as an important tool for making deci-
sions and recommendations 1n the Grays Harbor area. The plan provides good
general guidance for the various management units, although it could not, of
course, predict specific projects or activities which night take place.
Therefore, we will continue to evaluate projects through the normal permit
process, as explained on page 5 of the plan. We believe that our permit
review will be facilitated since much of our normal permit evaluation
criteria has been incorporated into the plan.

We believe that the GHEMP 1s a significant step toward maintaining the bio-
logical productivity and enhancing the economic productivity of the Grays
Harbor Estuary, and look forward to participating in its implementation.

Sincerely,

0.:-: -!•■>! signed by
jcscpli R. (tarn

Joseph R. Blum

Assistant Regional Director - Environment

cc: ES Olympia

B-3

f7M

JAh$jm-s wo -2

MAIL r.GGi'1

Mr. Donald Moos, Director
Washington Department of Ecology
Mailstop PV-11
Olympia, Washington 98504 .

UNITED STATES DEPARTMENT OF COMMERCE

National Oeaanlc and Atmospheric Administration

NATIONAL MARINE FISHERIES SERVICE
Office of the Regional Director

7600 Sand Point Way, NE

BIN C15700, Seattle, WA 98115

F/NWR5:JVW

Dear Mr. Moos:

I have enclosed an unsigned draft letter describing how the National
Marine Fisheries Service intends to use the Grays Harbor Estuary Management
Plan (GHEMP). When the GHEMP is final, after the full review process, the
enclosed letter would be signed and reference the appropriate final plan date.

Some plan changes may be made as a result of the forthcoming public (and
agency) plan and Environmental Impact Statement review process. If major
changes are proposed, the Task Force should be reconvened to consider them.

The Washington Department of Ecology has played a key role in facilitating
the completion of'the GHEMP. This planning effort constitutes a remarkable
example of coordination and cooperation between local, State and Federal
agencies. We look forward to working with your agency to ensure successful
plan implementation.

Sincerely yours,

Original Signed by
H. A. Larkins

H.A. Larkins
Regional Director

Attachment

B-4

UNITED STATES DEPARTMENT OF COMMERCE

National Oceanic and Atmoaphorio Administration

NATIONAL MARINE FISHERIES SERVICE

Northwest Region

7600 Sand Point Way N.E.

Seattle, Washington 98115

F/NWR5-.JVW

DRAFT

Mr. Donald Moos, Director
Washington Department of Ecology
Mailstop PV-11
Olympia, Washington 98504

Re: Grays Harbor Estuary Management Plan (date)

Dear Mr. Moos:

The Grays Harbor Estuary Management Plan (GHEMP) is a landmark document
developed with the participation and consensus of the various local, State and
Federal agencies responsible for development, resource conservation, and
preservation. By bringing together all of these entities, their respective
authorities and standards were to a very great extent reconciled with each
other. As a result the plan provides increased predictability for the
community and the agencies regarding development and natural resources
protection. The GHEMP provides a blueprint for economic growth balanced with
provisions for the protection of the natural features of the bay area.

As you are aware, the National Marine Fisheries Service (NMFS) is charged
with the protection, development and enhancement of marine, estuarine, and
anadromous fishes and the habitat on which they depend. The NMFS participated
in the GHEMP Interagency Task Force in a coordination role as provided by
Section 307 of the Coastal Zone Management Act. We expect that the GHEMP will
expedite our review of Corps of Engineers Section 10 and 404 permit
applications (provided for in the Fish and Wildlife Coordination Act) for the
Grays Harbor area. We believe that an acceptable level of fishery habitat
protection has been incorporated into the GHEMP on an estuary-wide basis and in
some cases on a site-specific basis. We therefore intend to use the GHEMP in
preparing permit comments for the Corps of Engineers.

As noted in the GHEMP (page 5), the plan does not bypass the Corps
permitting process, nor any of the Section 404(b)(1) criteria used in
commenting on a permit. Yet through the direct involvement of the permitting
and reviewing agencies in the planning process, development has been designated
for these areas where Federal permits are most likely to be issued.
Conversely, certain kinds of development have been excluded from those areas
where Federal permits are most, likely to be denied. Without specific project
and design details it was of course not always possible to do complete advance
permit evaluations tor development, in given locations (management units). Full
satisfaction of the Section 404 Guidelines must logically be demonstrated
through the permit application at the time a project is proposed. Yet the
permit criteria in the Section 404 guidelines have been evaluated in a broad
sense as one basis for designating a given management unit's "category" (e.g.
natural, conservancy managed, urban development, etc.).

B-5

There are four major classes of activities addressed by the GHEMP, each
with different consequences for Federal permit decisions. The "permitted
activities" tables for each management unit depict all four classes. The
tables list "permitted" activities authorized under the plan which are most
likely to meet Federal permit criteria. The tables also list activities
"conditionally permitted" by the plan which will likely meet Federal permit
criteria only if special care is taken to avoid negative environmental impacts
through specific project/site conditions. These specific conditions will be
developed in pre-permit or permit consultation with the appropriate resource
agencies, including NMFS. Some other activities are identified in the
"permitted activities" tables as "special condition" uses. These activities
are authorized under the plan only if they incorporate the "special conditions"
listed in the plan which were designed to reflect unique characteristics and
needs of each management unit. The special conditions in the plan were
developed with reference to Federal permit criteria whenever practicable; e.g.,
in some management units, the special conditions reflect an evaluation of
acceptable (or unacceptable) impact on the aquatic ecosystem. Finally,
activities not authorized by the plan (depicted by blanks in the "permitted
activities" and "standard uses" tables) will generally result in a negative
permit recommendation. To the extent that Federal permit criteria have been
addressed in the GHEMP, this agency will follow the guidance in the plan,
including the management objectives for each unit, in commenting on Corps of
Engineer's permits.

The consensus decision-making process of the Task Force evolved through
numerous compromises and resulted in a careful balance between development and
resource protection. Our reliance upon the GHEMP in permit review is
predicated on maintaining this balance. As a result, plan amendments which
could alter this balance should be carefully reviewed by the Task Force so that
continued use of the GHEMP is possible.

We genuinely hope and expect that the GHEMP will facilitate growth and
development in appropriate areas of Grays Harbor while ensuring long-term
protection for the productivity, fish, and wildlife of the estuary.

Sincerely,

H.A. Larkins
Regional Director

DRAFT

cc: Office of Ocean and Coastal Resource Management

B-6

DEPARTMENT OF THE ARMY

SEATTLE DISTRICT. CORPS OF ENGINEERS

P.O. BOX C-3755

SEATTLE. WASHINGTON 98124

^*P

SOP-NP

Donald Moos, Director

w .fiing ton State Department of Ecology

Mail stop PV-li

Oiyrapia, WA 98504

Dear Mr. Moos:

This letter responds to Mr. Don Peterson's proposed draft of a Memorandum Oi
Understanding for Implementation of Grays Harbor Estuary Management Plan.
Rather than modify the draft Memorandum to our satisfaction, I submit the
iv/1 lowing as our intentions:

a. The Seattle District supports incorporation of the Plan into the Scar.
Coastal Zone Management Plan.

d. Although the Seattle District cannot agree to use certain port tons oi
t lie; Plan as the sole basis of findings and documentation for our actions, the
Pian will be a part of our evaluation process.

.-■ u

c. As required by law, permits for work in navigable water., ana a
adjacent wetlands will be denied, where within 6 months, the Statf declare^
that a proposal is inconsistent with the Washington Coastal Zone Manage. ..ie.ii
Plan and this determination is not overridden by the Secretary of Conunerct .

a. The Seattle District is willing to participate in the amending of th
Plan if requested by the State.

Incorporation of the Plan into the State Coastal Zone Management Plan will
culminate many years of effort by a number of public agencies and private
individuals. Providing predictability for future uses of this estuary iius
r>een our ultimate goal and the Seattle District has been and continues to be-
strong supporter of this concept. As this Plan represents the spirit or
cooperation that exists amongst us, we look forward to its implementation.

Sincerely,

NORMAN C. KINTZ

Colonel, Corps of Engineers

District Engineer

B-7

APPENDIX C
MANAGEMENT UNIT 12 - IMPACTS ON BOWERMAN BASIN

APPENDIX C

MANAGEMENT UNIT 12 - BOWERMAN BASIN & ENVIRONS
Special Impact Analysis

A. GENERAL

1. Management Unit (MU) 12 consists of the Bowerman Airfield peninsula,
approximately 2200 acres of Port of Grays Harbor owned marsh and tidelands and
some subtidal lands, and tidelands extending from the south of the peninsula to
the navigation channel (see photo C-l). The area is further divided into areas
commonly referred to as Moon Island, Minimoon Island (or formerly dredge
disposal site E), the Bowerman Basin and the Moon Island Tideflats to the west
of the Basin (see photo C-2). For management purposes, the unit has been
divided by area designators (Area's 1 through 6 in MU 12, and Area 7 in MU 14)
in the plan (see figure C-l).

2. It is this MU (particularly that area known as the Bowerman Basin)
more than any other which has become the focus of both controversy and concern
during the development of the GHEMP and the NEPA scoping process. This area
has been identified as being essential to the future economic needs of the
region to provide suitable land for water dependent industrial development and
also clearly identified as an essential site for shorebirds and peregrine
falcons. Therefore, this section of the PDEIS will take a closer look at the
environment, the proposed actions which the plan contemplates and the potential
consequences of those actions to the natural environment should they occur
(i.e., the consequences to the socio/economic environment are discussed in
Part IV). This section has been included as an appendix only because of its
length and focus on a particular subject and is not intended to diminish its
importance from the rest of the EIS.

3. It is not possible to fully or accurately describe all the impacts at
this time for a diversity of reasons including: lack of knowledge of timing of
the proposed actions, new information which may come to light from monitoring
activities and the uncertainty associated with predicting impacts on dynamic
bird populations. Nevertheless, some conclusions can be drawn at this time
prior to any action taking place. This information (as well as any new informa-
tion) will be presented, reviewed and added to through the existing permit
process prior to any approval to discharge dredged or fill materials into
the aquatic lands of MU 12.

B. DESCRIPTION OF THE ENVIRONMENT
1 . Physical

a. Bowerman Basin, a section of the estuary, is located on the north-
ern shore of the inner harbor approximately 8 miles east of the mouth of the
harbor. The basin is bordered on the north by Highway 109, on the south by the
Bowerman Airfield peninsula, and on the east by Paulson Road connecting the
peninsula to Highway 109. Prior to the construction of the road, the Basin
extended farther eastward. The remaining wetlands west of the road are owned by
the City of Hoquiam and designated as Area 7 in MU 14. The west end of the
Basin opens into the inner harbor portion of the estuary. The western boundary

C-l

C-2

Photograph C-2. Management Unit 12

C-3

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NVnd JLN3W39VNVW AUVfUS3 a09dVH SAVUO

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C-4

of the Basin is hard to set for purposes of shorebird use but is normally
defined by a man-made, nonfunctional trestle line extending from the western
portion of the peninsula northward. The boundary therefore, includes approxi-
mately 500 acres of aquatic lands. Bowerman Airfield was developed by the Navy
during World War II by placing dredged material disposal within the confines of
a bulkhead. It was originally connected to the mainland by a trestle and was
known as Moon Island. During the 1940's dredge material disposal was placed in
the area east of the field connecting it to the mainland, to form an east-west
trending peninsula. Uncontained dredged material disposal at the eastern side
of the Basin continued in a westerly direction until 1972. Since 1972, dredged
material disposal placed in the area has been confined behind dikes (Lattin,
pers. comm. 1980). Thus the area has been substantially modified over the
years through diking, dredged material disposal, filling and sundry land uses.
It has been estimated that as much as 1600 acres of aquatic habitat have been
used for dredged material disposal since 1940 in areas west of the Hoquiam
River to Minimoon Island (Herman 1978). The area to the west of the Airfield
has been completely modified through the discharge of dredged material disposal
over a long term. Disposal in this area has been halted since 1976. The
impacts of these former discharge activities have been described in significant
detail in a Corps of Engineers publication entitled "Maintenance Dredging and
the Environment of Grays Harbor - Appendices A-N."

b. Unconfined disposal has covered the basin with a layer of predomi-
nately fine grained material dredged from the inner harbor channel (Corps, App. F
1976). Figures C-2 and C-3 show the different types of sediments and grain
sizes for the estuary and MU 12. These show that MU 12 consists mainly of
intertidal mudflats (as opposed to sandflats). The sediment character of the
Bowerman Basin consists mostly of silty clay fringed by silty sand. Sediment
type and grain size is important to the types of benthic invertebrates which
inhabit the estuary, and consequently important to the shorebirds.

c. The elevation of the Basin has been raised as a result of the
discharge of unconfined dredged material disposal (Corps, App. F, 1976).
Tidal channels created by water draining off the flats at low tide can be seen
draining water from east to west and near Mini -Moon Island from south to north-
west indicating a predominant drainage pattern. Protected from major wave
attack by the peninsula, the tides have carried the materials back and forth
to provide a gradual sloping which appears to be advantageous to the shorebirds
because it provides a longer period of time in which to feed on the mudflats
(Herman 1978). Figure C-4 shows a topographical map of the estuary. Tideflats
between an elevation of +5 feet above mean sea level to +9 feet are shown in
black, thereby providing a comparison of tideflats which may be available for
the lastest and earliest feeding periods for the shorebirds. Bowerman Basin
is not necessarily unique in having extensive mudflats for late feeding but it
does appear to be the latest part of the estuary to be inundated at high tide,
consequently providing the longest feeding period (1-2 hours) (Herman 1978).

2. Vegetation

a. The basin includes 450 acres of intertidal area fringed on the
north, east, and south by 90 acres of salt marsh, grass lands, and scattered
trees. The west end of the peninsula is vegetated by bentgrass (Agrostis alba),
American dunegrass (Elymus mollis), tufted hairgrass (Deschampsia cespitosa),

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sedges (Carex sp.), American searocket (Cakile edentula), beach pea (Lathyrus
japonicus), deervetch (Lotus corniculatus) , and brass buttons (Cotula cornonopi-
folia). East and northeast of the Airport the tideflats are bordered by
scattered stunted red alders (Alnus rubra) and willows (Salix sp.). In the
southeast portion of the basin the elevation is slightly higher and a fairly
diverse assemblage is found, including black willow (Salix lasiandra) , Scouler's
willow (S. scouleriana), red alder, the sedges (C. lyngbyei) and""~[C. obnupta),
and the grasses red top (A. alba), Pacific silverweed (Potentilla pacifica),
water parsley (Oenanthe sarmentosa), cattail (Typha lati folia), brass buttons,
and seashore saltgrass (Distich! is spicata). These species are also found on
the high elevations of the north border of the basin. Pickleweed (Salicornia
yirginica), saltmarsh sandspurry (Spergularia marina), and seaside arrow-grass
(TriglocTvin maritimum) are the most abundant pioneer species. Other species
found in higher elevations there include the grass Agrostis alba, western dock
(Rumex occidental is), orache (Atriplex patula), sedge (C. lyngbyei, meadow bar-
ley (Hordeum bracfiyantherum), and red canary grass (Phalaris arundinacea)
( He rman 1978).

b. The salt marsh along the eastern border of the Basin forms a horse-
shoe shaped projection into the tideflats (sometimes referred to as the "fan" -
see photo C-3). Seaside dock (Rumex maritimus), weeping alkali grass (Puccinella
distans), American bulrush (Scirpus americanus) are species found in areas
influenced by freshwater. An algal community of Vancheria sp. and Oscillatoria
sp. is found on the tidal substrate not covered by vascular halophytes (Corps
App. H, 1976). Shorebirds forage on the saltmarsh plants S. marina and T.
maritimum when high tides prevent them from feeding on the tideflats. Much of
the marsh habitat in the eastern part of the Basin has been established over
the last 8-10 years since dredge disposal operations ceased.

c. The lowest tideflat portion of the Basin is sparsely vegetated
with eel grass (predominately Zostera marina) which is an important part of the
diet of waterfowl. Denser beds of eel grass can be found west of the Basin
in the Moon Island Tideflats.

d. Although the saltmarsh and grass areas are important as wildlife
habitat, they cover only one fifth of the area of the Basin; four fifths being
occupied by intertidal mudflats. The remaining 1700 acres of Ml) 12 is also
predominantly intertidal with some subtidal habitat near the western limits.
These non-vegetated intertidal areas are highly productive areas. The ability
of mudflats to drain slowly is a contributing factor to their high productivity
since it leaves them exposed to environmental extremes for a shorter period of
time than are areas which drain quickly. The direct contact between the sedi-
ments, water, atmosphere and biota in non- vegetated wetlands facilitates
nutrient cycling and storage (the sediments act as both a nutrient source and
sink, regulating the productivity and keeping it at a constant level). The
shallow depths of intertidal areas expose them to relatively large amounts of
light the year round and favor respiration of the algae and phytoplankton, and
the regeneration of nutrients by the formation of algal mats (Theberge, et.al.
1978).

(1). Exposed mudflats support a large macrobenthic population.
The benthic organisms found in these finer grained sediments tend to be small,
thin shelled, and are usually confined to the upper five centimeters of the
sediment (the oxidized layer). The density of invertebrates on mudflats is

C-9

Photograph C-3. Bowerman Peninsula and the "Fan.

C-10

extremely high, and in the high intertidal is greater than at comparable
elevations on any other substrate. This density is of tremendous importance
to vertebrates, especially shorebirds, which feed on these invertebrates.
High intertidal areas are exposed a large percentage of the time by low tides,
greatly increasing the amount of time available for shorebirds to feed in
comparison to mid- and lower intertidal zones. This is especially critical
during winter when mean tidal levels are often increased by storms and high
freshwater runoff. During these periods, the availability of feeding area is a
critical factor for shorebirds. The birds become heavily dependent on these
high elevation mudflats since they offer the greatest food resources. Mudflats
are, therefore, extremely important in supporting shorebirds and shorebird
predators such as falcons, especially during winter (Albright, et.al. 1980)
Figure C-5 shows how various shorebirds may be distributed on mudflats based
on vertical feeding ranges. Other substrates such as sand flats, coble and
rock are also utilized by different types of shorebirds in the estuary (Herman
& Bulger 1981).

(2). The Bowerman Basin contains approximately 450 acres of
intertidal mudflats of the approximately 34,000 acres of intertidal lands
remaining in the estuary.

3. Fauna

a. Benthic Invertebrates. Several studies have been conducted on
the abundance, distribution and importance of the benthic invertebrates in
Grays Harbor. The studies have shown that the crustacean amphipod, Corophium
sp. and Anisogrammarus confervicolus are two of the most abundant and important
species to serve as a prey base for numerous other organisms. There are several
different species of Corophium including C. salmonis and C. spinicorne which
are known to be abundant in Grays Harbor. C. salmonis is a dominant member
of the mudflat community and C. spinicorne is abundant in the Chehalis River
section near Cosmopolis. C. salmonis is extremely important to shorebirds
in portions of Grays Harbor and C. spinicorne appears to be important to the
fishery resources along the fish passage [Albright & Armstrong 1982). The
major focus for MU 12 therefore is turned to C. salmonis.

(1). C. salmonis distribution and abundance appears to be deter-
mined largely by sediment type and beach slope. Silty-sand or silt-clay sub-
strates present on broad, gently sloping tideflats appear to support the highest
densities (see figures C-2 and C-3). Salinity does not appear to be as impor-
tant a factor in controlling C. salmonis distribution and abundance as sediment
type. Elevation is also an important factor in determining distribution and
abundance (Albright & Armstrong 1982). This does not necessarily mean that
the Bowerman Basin has the highest abundance of Corophium sp. in the estuary.
Samples however, may be naturally depressed due to heavy shorebird predation.
There are other sites which have been identified as having higher densities
and which are not utilized to the same extent as the Bowerman Basin. Table
C-l for example, shows that the mid-harbor tideflats have prodigious densities
(32 - 56,000/sq. meter) of Corophium in muddy sand sediments but existing
literature doesn't identify the flats as being important to shorebirds. Table
C-l also shows that the eastern end of Bowerman Basin at the higher elevations
does not appear to support large densities of C. salmonis (3,300 - 5,800/sq.
meter) above the 2.1 meter (approximately +7 feet) elevation above MLLW.

C-l 1

FIGURE C-5

FCePlfJS DISTRIBUTION ON MUPFLATS ANP NEWSHORE
WATERS BY SELECTED SHORE BIRDS.
VERTICAL PEEPING RANGE

ABOVE ANP I AT SURFACE

BETWCEU WATER I OF BEACH

SURFACE AND

SEACH

SUBSTRATE

AT VARYIN6 DEPTHS WlTWlM SUBSTRATE
(SOME MAV ALCO FEED OJ SURFACE)

***rrett su«r*ca

m>ch svrhace

Shorebirds are able to probe below the surface to varying depths according to bill length (the
numbers indicate both length of bill and depth to which they can probe in inches). They also
have varying leg lengths, and are able to wade in shallow water, as illustrated by the Greater
YeTlowlegs which feeds in tidalpools and shallow nearshore waters. Phalaropes generally feed
while resting on the water's surface, while Plovers feed on organisms on the surface of beach
substrates.

Source: Albright, Rick, et. al . , Coastal Zone Atlas of Washington, Land
Cover/Land Use Narratives, Vol. II, Washington Department of
Ecology, June 1980

C-12

TABLE C-l

Table 13: Densities of C. salmonis in Grays Harbor, Washington. Data for all
locations exeept Sites M and MC taken from Albright and Rammer, 1976.

Mean * Max. go.

Location Date Elevation Ho. per ■ per wr Sediment

Mid-harbor flats 3-75 .9-1.2 m 36,700 50,000 Muddy sand

Mid-harbor flats 8-75 .9-1.2 m 32,300 56,000 Muddy sand

W. of Moon Island 10-74, 4-75, 7-75 1.8 m 4,900 6,800 Muddy sand

W. of Moon Island 10-74, 5-75, 7-75 1.8 m 7,700 14,600 Fine sand

W. of Moon Island 10-74, 4-75, 7-75 1.6 m 3,300 7,600 Fine sand

W. of Moon Island 10-74, 4-75, 7-75 2.1 m 3,700 6,200 Fine sand

W. of Moon Island 12-74, 5-75, 7-75 1.6 m 17,000 32,800 Mud

W. of Moon Island 12-74, 5-75, 7-75 2.2 m 3,000 5,900 Fine sand

E. end of Bowerman

Basin 11-74, 7-75 -v2.1 m 3,300 5,800 Mud

Mouth of 0'leary

Creek 9-74 tl.8m 35,900 35,900 Mud

Mouth of Grass

Creek 9-74, 10-74. 11-74 ^2.2 m 200 300 Muddy sand

South Channel
w. of Charlie

Creek 11-74 ^1.8 ■ 57,900 57,900 Nud

Site M 3-80 to 9-80 .6m 6,600 18,300 Mud

1.8m 11,400 49.700 Mud

Site MC 3-80 to 9-80 1.8 m 13,300 42,400 Mud

Source: Albright and Armstrong, 1982

C-13

(2). Both abundance and diversity are important to shorebirds
feeding in different substrates. Most shorebirds eat a variety of food and
are opportunistic feeders. One study of the eating habits of dunlin in Grays
Harbor identified from esophagi analysis the following types of food sources:
28.1% were annelid worms, 0.9% nematode worms, 37.3% arthropods, and 33.6%
salt marsh plants. The amphipods Corophium and Anisogammarus confervicolous
comprised 31.7% of the total (Corps, App. J, 1976). Other studies have shown
higher concentrations of amphidpods or polychaete worms depending on location
and substrate, and insects and seeds after high tide. Dunlin and western
sandpipers are capable of eating different species of invertebrates in different
estuaries as well. For instance, in the Copper-Bering River Deltas system in
Alaska, dunlins feed primarily on bivalve molluscs, particularly Macoma balthica,
while western sandpipers have a very diverse diet including molluscs, amphipods,
and insect larvae (Senner 1977). A distinct Corophi urn-dunlin relationship in
the inner harbor and Bowerman Basin, however has been previously documented.
The highest densities of Corophium ssp. occur during the summer months after
eggs have hatched (Albright, 1982), but as previously mentioned (p. 11-22) inter-
tidal invertebrate biomass is highest in the spring and lowest in summer.

b. Avian Fauna

(1). Species Utilization. During the 1981 spring migration period
(April-May) at Grays Harbor, Dr. Steven G. Herman and John B. Bulger conducted
one of the most complete and intensive studies on the distribution and abundance
of shorebirds in Grays Harbor to date (Herman & Bulger 1981). The study documents
the large number of shorebirds which utilize the estuary and that shorebird
utilization was significantly higher than had been previously reported by other
investigators. Table C-2 identifies the numbers of each species of shorebirds
counted at eleven census sites around the harbor. Western sandpipers are by
far the most numerous species of shorebirds present in the harbor during spring
migration. Dunlin are the second most numerous species followed by dowitchers
spp. Figure C-6 shows the timing and magnitude of the shorebird migration with
peak numbers occuring between April 17 through April 28, 1981. The figure shows
that the total number of shorebirds on April 23, 1981 amounted to nearly 1,000,000
birds. Table C-3 shows the average number of shorebird species recorded and
indicates that Wakina Flat in the North Bay had the largest mean number of species
(diversity) per day followed closely by the Bowerman Basin and Bottle Beach in
South Bay. Wakina Flat was the most important site for black-bellied plovers,
whimbrels and marbled godwits based on the mean numbers of birds during the
migration period; Bowerman Basin for semi-palmated plovers, dunlins and western
sandpipers; Point New for ruddy turnstones; Bottle Beach for red knots; Kurtz
Slough and Bowerman Basin for dowitchers; and, Chenois Creek and Wakina Flat for
greater yell owl egs. On the basis of the data, they conclude that Bowerman Basin
supported 40% of the total shorebird numbers during the peak of migration, North
Bay supported 30%, South Bay 25% and the Inner Harbor 5%. The results of the
survey indicates that:

(a). Grays Harbor Estuary is host to more shorebirds than
any other estuary along the Pacific Coast south of Alaska;

(b). Grays Harbor is of extraordinary and critical impor-
tance to spring-migrating shorebirds on the Pacific Coast;

C-14

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C-16

TABLE C-3

Average number of shorebird species recorded each day at each census
site during the period 25 April - 14 May.

X number of
Site species per day Range Area

Wakina Flat 11.5 8-14 North Bay

Bowerman Basin 9.8 8-13 Bowerman Basin

Bottle Beach 9.8 9-11 South Bay

Bay City 9.0 7-10 South Bay

Point New 8.8 8-12 South Bay

N. Wakina 8.8 8-11 North Bay

Chenois Creek S.2 6-10 North Bay

Westport Fiat 7.9 6-10 South Bay

Kurtz Slough 7.2 5-10 North Bay

O'Leary Creek 5.1 4-7 Inner Harbor

Newskah Creek 3.8 2-7 Inner Harbor

Source: Herman and Bulger, 1981

C-17

(c). All intertidal areas in the estuary, as well as many
of the other wetlands and some upland sites, are important to migrants;

(d). The Bowerman Basin supported the largest numbers of
shorebirds on every census day and is the most important site to migrating
shorebirds in Grays Harbor for the following reasons:

o Bowerman Basin is the last area to cover on the incoming tide and
the first to uncover, thereby providing the longest feeding time with food
being abundant; (see photo C-4)

o It is one of the largest expanses of high mud in the harbor, and
it is somewhat protected from wave action and other effects of weather;

o It offers a mosaic of habitats, including roosting areas of several
kinds and good cover; (see photo C-5)

o The previous filling of areas to the east may have increased the
density of birds using the Basin, (see photo C-6)

(2). Bowerman Basin is most significant as an area utilized
extensively by foraging birds. Although several species forage in this inter-
tidal area, its importance lies in the large number or densities of birds
rather than the diversity of birds that utilize it (Paulson 1980). Shorebirds,
waterfowl and terrestrial birds are all present in the Basin. Table C-5 con-
tains a list of birds sighted in the Bowerman Basin by Dr. Dennis R. Paulson,
Affiliate Curator of Birds at the Burke-Museum in Seattle, Washington. Both
Dr. Paulson and Dr. Herman have identified the Bowerman Basin as the most
significant bird habitat site within MU 12 as well as studies conducted by the
Washington State Department of Game for the Corps of Engineers. This includes
the easterly portion of Area 1 and Area 3. Area 2 is also used for feeding
and roosting and Area 4 (Mini-Moon Island) is used primarily for roosting.
Area 2 is not as significant a site as the Bowerman Basin. Figure C-7 shows
the differences in densities of the areas west of the peninsula (Site E) and
north of the peninsula (Site E-l).

(3). Dunlin (Calidris alpina)

(a). The tideflats in Bowerman Basin are one of the largest
wintering grounds for the shorebird dunlin on the west coast. Dunlin concen-
trations reached 3,500 birds per 100 acres in 1975, and 10,000 to 50,000 indi-
viduals regularly use the area (Corps, App. H, 1976) Dunlin use Grays Harbor
from October to April and then migrate to Alaskan breeding grounds. Dr.
Dennis R. Paulson identified 3 migratory peaks of shorebirds by conducting
weekly censuses of the area during the fall of 1979. The first is late June/
early July with the returning of adult western sandpipers, short-billed dowitch-
ers and whimbrels; the second in mid-August to early September with the peaking
of juveniles of these and other species; and the third at the end of October
as large numbers of dunlin arrive (Paulson, per. comm., 1983). Dunlin utilize
many areas of the harbor. During the spring migration, highest concentrations
of dunlin for a short duration of time were found in South Bay (April 25 & 27
19,000 and 16,000 respectively) and the largest mean population was distributed
in North Bay (North Bay 4,100, South Bay 3,500 and Bowerman Basin 3,400) (Herman
& Bulger 1981). The dunlin is a migrant and quite common and locally abundant
winter resident in many other parts of Washington. "A Baseline Survey of
Significant Marine Birds in Washington State," identifies other major and

C-18

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Photograph C-4. Bowerman Basin: Birds Roosting. Source: S.G. Herman 1980

C-19

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Photograph C-5. Bowerman Basin: Birds Feeding & Roosting. Source: Herman 1980

C-20

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Photograph C-6. Bowerman Basin: Birds in Flight. Source: S.G. Herman 1980

C-21

TABLE C-5

BIROS RECORDED IN BOWERMAN BASIN DURING ONE-YEAR WEEKLY SURVEY, 1979-1980
AND ON OCCASIONAL VISITS OVER PREVIOUS 7 YEARS - WATER BIRDS ONLY

C - common to abundant

U - uncommon to fairly common

0 - occasional visitor

R - resident

Common Loon - UW*
Horned Grebe - UW*
Western Grebe - UW*
Double-crested Cormorant - CR*
Great Blue Heron - CR
Canada Goose - UW
White-fronted Goose - OW
Ma Hard - CR
Gadwal 1 - OW
Pintail - CW
Green-winged Teal - CW
Cinnamon Teal - OM
European Wigeon - OW
American Wigeon - CW
Northern Shoveler - UW
Canvasback - CW
Greater Scaup - CW
Lesser Scaup - UW
Bufflehead - UW*
White-winged Scoter - UW*
Surf Scoter - UW*
Ruddy Duck - UW*
Red-breasted Merganser - CW
Semipalmated Plover - CM
Kil ldeer - UR

W - wi nter vi si tor
S - summer visitor
M - migrant, spring and fall
* - offshore, in deeper water
primari ly

American Golden Plover - OM (fall)

Black-bellied Plover - CM, UW

Ruddy Turnstone - CM (mostly spring)

Whimbrel - OM

Spotted Sandpiper - OM i -

Greater Yellowlegs - UM

Lesser Yel lowlegs - UM

Red Knot - UM (mostly spring)

Bai rd 's Sandpiper - UM

Least Sandpiper - CM

Dunl in - CW

Short-billed Dowitcher - CM

Long-bil led. Dowi tcher - CM

Western Sandpiper - CM, UW

Marbled Godwit - OM

Sanderl i ng - OW

Northern Phalarope - OM

Glaucous-winged Gull - CR

Western Gull - CR

California Gull - CM (mostly fall)

Ring-billed Gull - CR

Mew Gull - CW

Bonaparte 's Gul 1 - CM

Caspian Tern - CS

Belted Kingfisher - UR

Land birds using the basin for feeding include bird-eating hawks (in small
numbers) Sharp-shinned, Cooper's. Marsh Hawk, Peregrine Falcon and Merlin-
mouse-eating hawks (in small numbers), Red-tailed, Rough- legged and Marsh
Hawks, and other species that feed at times on the mudflats, including
Band- tailed Pigeons, Common Crows, Water Pipits, Starlings and Song
Sparrows. Other predatory birds that are present during some winters
include Snowy Owls, Short- eared Owls and Northern Shrikes, all of which
are primarily rodent-eaters.

Source: Paulson D.R. 1980

C-2 2

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SITE E-l

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SPRING

SUMMER

FALL

FIGURE C-7 Total seasonal densities of birds using tideflats
at disposal Site E and contrast Site E-l.

SITE E. West of Bowerman Field. Dredged material disposal site
(census area). Blind used: U.S. Coast Guard aft Range "C."

SITE E-l: West tip of Bowerman Field, blind. Area censused was
tideflats north.

C-2 3

minor sites in which wintering flocks of dunlin have been identified. The
maps are reproduced in the following pages to give the reader an idea of the
extent of dunlin distribution within Washington State. In most cases, equiva-
lent studies as those conducted by Herman and Bulger have not been done for
other areas in Washington. One example might be given of the number of dunlin
present on a different substrate (sand) at Dungeness Spit, Washington. Table
C-6 shows the number of shorebirds observed by Mr. Karl Gruebel on Dungeness
Spit. Dunlin were abundant and numbered in the 1000's during the winter months
(Albright, et.al . 1980)

(b). Dunlin have historically been present in Grays Harbor.
The following excerpt from the Birds of Washington State dates back to 1920.

When crossing Grays Harbor on April 6, 1920, just as the ebbing tide
was beginning to expose the mud flats, Cantwell saw several small
flocks of dunlins passing overhead, some settling on boom logs at
short range, permitting certain identification. A thousand or more
thus flew by, coming from the sand beach on the lee side of the
harbor about Westport. Suddenly an immense flock appeared, looking
like a waving dark ribbon in the sky. The flock was estimated to
be fully a mile long, and about 50 feet wide, and containing 10,000
birds, the largest flock of sandpipers seen in many years' experi-
ence. As Hoquiam and Aberdeen were neared, this immense flock was
found scattered out over the mud flats.

From this, one may interpret that the Bowerman Basin and areas eastward which
are now filled have historically been used by dunlin. Figure C-8 shows the
extent of tidelands in the Bowerman area prior to 1940.

(4). Western Sandpipers (Calidris mauri )

(a). Western sandpipers are among the most abundant shore-
birds in the world. Isleib (1979) estimates that the south-central coast of
Alaska is host to more than 20 million shorebirds each spring, the bulk of
them being western sandpipers (6 1/2 million) and dunlins (3 1/2 million).
Herman and Bulger (1981) report that western sandpipers were the most abundant
migrant shorebird species in Grays Harbor and Bowerman Basin was the site most
utilized each day during the 1981 spring migration with as many as 400,000
birds feeding in the Basin on 23 April 1981. Bowerman Basin contains less
than one square mile of tidal mudflats. A density of 410,000 birds may repre-
sent the largest concentration per square mile ever recorded. Isleib (1979)
has reported densities up to 250,000 shorebirds per square mile in the Copper
River Delta in Alaska during spring migrations. Herman and Bulger's census
figures show the Basin's significance during the peak migration period in
particular. Figure C-7 shows the distribution of western sandpipers in Grays
Harbor from 25 April - 14 May 1981. Herman and Bulger (1981) report that
concentrations of 500,000 to nearly 1,000,000 western sandpipers were present
from 20-27 April 1981, accounting for 85 to 90 percent of all shorebirds present
and that they were widely dispersed throughout Grays Harbor.

(b). The prime breeding range of western sandpipers are the
Yukon-Kuskokwim Delta and the Seward Peninsula in western Alaska (Senner, 1979).
During investigations conducted in Alaska, Senner (1979) has found evidence that
the Copper-Bering River Deltas serve as critical habitat in the annual cycle

C-24

i' .tm '* j .-■ • .*

C-26

'•"' i -:' ■

Table C-6

SHOREBIRDS OBSERVED ON DUNGENESS SPIT,
SEPTEMBER - NOVEMBER 1977 AND 1978

High Daily
Species Count

Kill deer

Black Oystercatcher 5

Semi pal mated Plover 50

23

Black-bellied Plover 100' s

Ruddy Turnstone 15

Black Turnstone 33

Whimbrel 5

Greater Yellowlegs 4

Wandering Tattler 9

Willet 1

Surfbird g

Red Knot 5

Sanderling 10Q.S

Semipalmated Sandpiper 2

Western Sandpiper 100' s

Least Sandpiper 17

Dunlin 1000.s

Short-billed Dowitcher 100's

Marbled Godwit 2

Northern Phalarope 6

Source: Albright, et.al. 1980

C-2 7

FIGURE C-8.
Bowerman Basin circa 1940.

C-28

of western sandpipers and dunlins. The deltas serve as a critical stopover
where the birds replenish fat reserves and rest prior to flying to their breed-
ing grounds in western Alaska, a distance of 1,000 kilometers. Drs. Herman and
Paulson believe that the species which utilize Grays Harbor as a "staging area"
during spring migration may fly directly to the Copper-Bering River Delta
system, a distance of 1,000 miles (1,600 kilometers) or more and therefore need
to replenish fat reserves to propel them for this long-distance flight. If
Grays Harbor is the last "staging area" prior to departing for the long flight,
then this leads credence to the importance of the Grays Harbor estuary as also
providing critical habitat to the shorebirds.

C. POTENTIAL IMPACTS TO AVIAN FAUNA

1. U.S. Fish & Wildlife Service (F&WS) Opinion

a. The Washington Area Office of the F&WS has provided 0CRM with two
separate assessments on the GHEMP. The first assessment (dtd March 31, 1981)
addressed impacts associated with implmentation of an earlier version of GHEMP
which would have allowed filling of the Bowerman Basin while protecting the area
west of the peninsula and Basin beyond the trestle line. Their assessment
concluded that the Bowerman Basin was important to the integral well-being of
the American peregrine falcon (Falco peregrinus anatum) vis-a-vis the shorebird
utilization of the Basin. Consequently, filling aTT 500 acres of the Basin
would likely jeopardize the continued existence of the peregrine falcons which
hunt in the Basin and require large concentrations for their hunting success.

b. In response to their opinion, a mini-Task Force was formed to
consider alternatives to the configuration for development and came up with a
totally new development scenario based upon the importance of resources in the
Bowerman Basin to shorebirds and falcons and is described in GHEMP, pp. 60-69.
The F&WS reviewed the new proposal which would extend the peninsula westward,
thereby avoiding what has been identified as the most critical habitat and
conditionally permit some development (airport relocation) northward subject
to stringent requirements. After 0CRM reinitiated formal Section 7 consulta-
tion, the F&WS rendered a new opinion (dtd December 11, 1981) based upon the
revised GHEMP. Because of their importance, both letters are incorporated in
their entirety into the PDEIS and serve as the major assessment of impacts to
shorebirds, waterowl and endangered peregrine falcons (and in reality, all
birds of prey). While the Section 7 opinion was concerned mainly with impacts
to the falcons, it necessarily had to focus on impacts to the shorebirds (the
falcons prey base). They concluded that the high densities of wintering and
migratory shorebirds needed to sustain the falcons should not be reduced given
certain mitigation measures. The December 11, 1981 opinion is however, a
guarded assessment because of uncertainty associated with shorebird and pere-
grine falcon response to filling Area 2. Referring to Area 3 which may fill as
much as 73 acres of the Bowerman Basin, they state that "a quantifiable impact
to peregrine falcons will not be known until after Area 2 is filled and an
analysis of shorebird and peregrine falcon response is made," and also that
"several data gaps concerning peregrine falcons at Grays Harbor exist."

C-2 9

THE FOLLOWING ARE BIOLOGICAL OPINIONS OF THE
U.S. FISH AND WILDLIFE SERVICE ON THE IMPACTS

ASSOCIATED WITH IMPLEMENTING THE
GRAYS HARBOR ESTUARY MANAGEMENT PLAN TO THE
AMERICAN PEREGRINE FALCON

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Figure 3

Conceptual Alternative Plan of Development
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Figure 1. Grays Harbor, Washinoton

WORTH

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Schematic of fill areas in
M.U. 12. Cross-hatch represents
areas subject to fillino -in
Phase I Development.

c. This uncertainty led to the plan's provisions for phased filling
and the need to conduct a monitoring program prior to making any decision on
Area 3. Phase I filling (Area 2) could take up to 10 years or longer to fill
and airport relocation is a long-term (i.e., possibly 15 years or more away)
proposal. Likewise, the potential impacts associated with Area 4 fill would
have to be evaluated in the future based upon future circumstances and impacts
associated with Area 2 and Area 3 fills. On March 3, 1983, OCRM staff met with
Drs. J. P. Myers, (Academy of Natural Sciences of Philadelphia), S.E. Senner
(Hawk Mountain Sanctuary Association) and M.A. Howe (U.S.F&WS) to discuss the
GHEMP proposal and to solicit information on the possible impacts of GHEMP
implementation to the large populations of shorebirds during migration and the
winter months. Concern was expressed about the effects of any additional
filling in the Bowerman Basin. However, if a decision was made to fill Area 2,
a monitoring program should be in place before any filling was begun. The
following procedures were recommended to be used as baseline and for possible
follow-up studies.

(1). Census. Conduct censuses of shorebirds in Bowerman Basin
and surrounding portions of Grays Harbor at regular intervals throughout the
year, with effort intensified during the period of migration (especially
spring). Census methodology must be consistent and replicable, but actual
methods could be determined at a later time.

(2). Color-Marking. An intensive color-marking study should be
initiated in order to determine both normal patterns of movement of individuals
within the estuary and rates of turnover of birds during migration. These
studies will help answer the question of site fidelity of individuals and permit
more accurate estimates of total numbers of birds using the area during migra-
tion.

(3). Body Condition. Changes in Bowerman Basin may affect shore-
bird food supply or intensify competition between individuals. This may result
in deteriorating body condition or attenuated rates of pre-migratory fat depo-
sition. Birds trapped for marking should be weighed and examined for molt or
other indicators of health.

(4). Invertebrates. The invertebrate prey population should be
systematically sampled throughout the year, not only to determine distribution
and numeric abundance, but also to determine size distributions and caloric
content. This should be done in both natural and reclaimed areas.

(5). Use of Reclaimed Areas. Shorebird use of reclaimed areas
after the development has been initiated should be carefully monitored.

They stressed the importance that the work be started as soon as possible if the
plan is approved, so that baseline patterns and natural levels of variability
can be established. This would allow for a more quantitative assessment of
impact.

2. OCRM Assessment

a. OCRM concurs in the assessment of impacts made by the F&WS for
American peregrine falcon habitat protection in MU 12 based on their December
11, 1981 opinion. That assessment is based on the protection and enhancement

C-46

provisions to the falcon's habitat and prey base, the shorebirds. OCRM offers
these additional thoughts on potential impacts to shorebirds. There is a
likelihood for some adverse impacts to occur which will be associated with the
discharge of dredged or fill material in MU 12 and subsequently with land use
activities permitted under the plan. Those impacts could be significant or
non-significant depending on a number of variables (i.e., there is uncertainty
as to the degree of severity of impact on the populations of shorebirds).
Adverse impacts could result from a direct loss of some of the bird habitat
and possibly due to added stress (i.e., in addition to being hunted by predatory
hawks and falcons, adverse weather conditions, normal competition for food and
space) placed on the shorebirds through noise, light and perhaps water quality.

(1). The worst case scenario would result if all shorebird utili-
zation of the Bowerman Basin were to cease as a result of land use activities
in Areas 2, 3 and 7, even though a majority of the now existing prime feeding
and roosting habitat will be preserved and/or reestablished under mitigation
and enhancement. The most severe impacts should they occur would be to winter-
ing populations of dunlins and migrant populations of western sandpipers which
tend to favor the area in large numbers. Impacts might occur as a result of
some unacceptable level of stress to the birds in which they avoid the area,
not as a result of direct mortality from construction because of the birds
mobility to avoid such impacts. The impacts may be short-term or long-term.
Mortality among shorebirds can be attributed to a number of factors including
inclement weather conditions on the breeding grounds or during the winter
months, lack of food, pesticides, diseases, predation, and not having enough
body fat when the birds arrive at the breeding grounds which may lead to lower
reproductive success (Senner, personal communication). The latter would affect
future population growth rather than result in direct mortality.

(a). Figure C- 9 shows four hypothetical time-related impact
response patterns to organisms disturbed by construction in wetland ecosystems.
Since GHEMP contemplates phased filling and activities occuring over a long-
term period (10-15 years), pattern C (Delayed Response), may best represent
potential impacts under a worst case scenario in which the birds are inhibited
from further utilization of the remaining habitat. Naturally, the response
pattern is highly simplified since it represents a view of a stable population
base which in essence does not exist. If bird response is less severe and the
birds continue to use the Bowerman Basin but to a lesser extent because the
total carrying capacity has been diminished, then pattern D (Substitution), line
(a) is the best representation of potential impacts.

(b). Table C-7 shows generalized biological response pat-
terns to increased levels of environmental stress to individuals, populations,
species or communities. Increased stress will tend to force greater competi-
tion of the best remaining resources and force the more sensitive or less
tolerant individual birds to utilize less desirable habitat thereby creating
certain behavioral and physiological debilitating effects such as reducing
resistence to disease, predation or causing mortality during cold winters.
The chief concern regarding destruction of habitat is whether the habitat is
unique and whether the wildlife using it can be absorbed into alternate habitat.
In light of the fact that Grays Harbor is the northern-most large protected bay
on the Pacific coast south of Alaska, an action undertaken which would reduce
the capacity of Grays Harbor to offer a resting and feeding place for migrating
or overwintering birds would be considered a negative effect. While no absolute

C-47

A.

ORIGINAL
LEVEL

/
/
/

INHIBITION RECOVERY NO EFFECT OR

CHRONIC EFFECT

B.

STIMULATION

CHRONIC EFFECT

C

LAG TIME

INHIBITION

D.

/ •*

o * b

i SUBSTITUTION CHRONIC MODIFICATION

CONSTRUCTION

PERIOD TIME »»-

Figure (S9» Time-related patterns of wetland ecosystem response to
construction disturbance. A. Elimination followed by
complete (a) or partial (b) recovery. B. Stimulation
followed by depression. C. Delayed response. D. Substi-
tution response.

Source: Darnell 1976 (EPA-600/3-76-045)

C-48

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C-4 9

prediction on the numbers of birds which may be adversely impacted can be made
with any degree of assurance, the following findings of Goss-Custard (1979)
which are based upon research conducted in England estuaries on the effect of
habitat loss on the numbers of overwintering shorebirds suggest that filling
of Area's 2 and 3 may lead to a decrease in the numbers of shorebirds, but
only to the extent that there is a food shortage which is already contributing
to winter mortality. Goss-Custard found that:

Shorebirds are not spread out evenly over intertidal flats. Some
are used more than others and may be considered as preferred feeding
grounds for possibly a number of reasons (i.e., close to roosting
site, high densities of prey organisms). If a large part of the
feeding habitat is lost, some birds may go to other sites which may
be non-preferred sites or if they stay will increase the density and
the competition for a smaller prey base. Observations imply that
there is a limit to the number of birds that can exploit any preferred
feeding areas that remain after a development has taken place and
indicate that more feeding would be done, presumably by subdominant
individuals, in the less suitable areas. A reduction in feeding area
might result in birds leaving the estuary altogether. However, an
increase in density levels might occur in preferred areas because a
clear ceiling density is not reached, and an increase in competition
for space might force birds to tolerate higher densities. An increase
in bird densities may not affect survival unless birds already have
difficulty in obtaining food requirements at some time between August
and May. The abundance of available food for some shorebirds may
decline during the winter suggesting that food may be relatively
difficult to collect at that time of the year. The decline may be due
to loss of body weight, less accessible (buried deeper in the mud),
etc. Younger individuals being less experienced and subdominant to
adults may be the ones most likely to be forced into the less profit-
able feeding areas and may be the ones most at risk.

Goss-Custards studies indicate that the most critical time for shorebirds may
be during the winter months during times of prolonged inclement weather if and
when a food shortage exists. (Goss-Custard's work does not address the effects
of habitat loss on migrants, only overwintering birds.)

There is no current evidence to support the prospect that a worst case scenario
will occur in the future based upon the previous actions taken in and around
the Basin. Many hundreds of acres have been filled to the east of the Basin
and while the birds have been denied those acres from further utilization,
they continue to use the Basin in large numbers. Likewise, the fact that large
numbers of birds continue to use the Basin in numbers is no evidence against
the possibility of the worst case scenario occuring. What may be occuring
here is a situation in which incremental losses are tolerated up to a certain
threshold. Without knowing historic use levels, it is hard to say whether
present use represents a healthy situation.

(2). In addition to habitat loss, a second negative impact asso-
ciated with filling and dredged material disposal is potential degradation
of water quality. A confined disposal site for material dredged from the
water, and by overflow of the dredged material over the confining dike.
Overflow of the dredged material may occur as a result of dike failure which

C-50

seldom happens in the Seattle District of the Corps of Engineers. When dike
failures occur, a slurry of dredged material, turbid water, and possible
harmful pollutants enters the surrounding environment. If the slurry enters
a water body, several ecological impacts may occur:

o the material could spread out in a fan covering benthic materials
or interfere with filter-feeding organisms; or

o toxic pollutants could enter the surrounding ecosystem and be taken
up through the food chain.

Likewise, seepage through the dike may release soluble pollutants. The dredged
material to be disposed in Area 2 would most kikely be form the navigation chan-
nel as part of the widening and deepening project or by maintenance dredge dis-
posal until the area is filed. The navigation channel does contain pollutants
and has recently been analyzed by the Corps of Engineers for the proposed
widening and deepening project. The majority of the polluted sediments would
be disposed of in Port Slip #1. However, if polluted material were disposed in
Area 2 (164) acres), it is unlikely that a water quality problem will exist even
if there is a dike failure given the dilutiion factor relating to the area in
which the disposal would be confined (Seattle Corps of Engineers, personal
communication, 1983).

(3). There is also a possibility in which there will be no
significant adverse impacts. Some of the reasons which may account for this
include:

(a). Area 2 would be filled first allowing the birds time
to adjust to the modified' environment. Area 2, while not an insignificant
shorebird feeding and roosting site is apparently of lesser significance than
other sites in MU 12. There is evidence of the ability of shorebirds to adjust
to new environments and utilize new feeding grounds (Fry 1981).

(b). The peninsula would be extended creating additional
protection from wave action and severe storms.

(c). Additional roosting habitat would be created along
the west and north borders of Area 2 providing a greater mosaic of habitat
(including marsh habitat), albeit at the expense of some intertidal feeding
habitat.

(d). The land use activities in Area 2 may not prove to be
severe enough to place stress on the birds. There will be buffer vegetation
provided which will shelter the birds from intense human activities most of
which would occur near the navigation channel and loading docks. Train move-
ment around the perimiter may not be especially adverse as train activities are
or have been common on both sides of the estuary for many years. However,
the intensity of train movement and noise will depend on many factors which
cannot be fully evaluated at this time. Likewise, if after Area 2 has been
filled and a determination of non-significant impact is made with respect to
impacts on shorebirds and falcons and Area 3 is filled, the land use will con-
sist only of relocation of the airport runway north of the existing field.

C-51

The existing Bowerman Airfield has apparently not adversely impacted the shore-
birds for approximately 40 years. The birds are known to use the airfield for
roosting. While birds take to flight now and then upon approaching aircraft,
they have continuously utilized the Basin over these many years.

(4). The severity of adverse impacts cannot be quantitatively
or even qualitatively identified at this time as was pointed out in the F&WS
opinion. This is the reason there is a need to monitor activities and make
further assessments in the future during the various phases of activities.
There are a number of reasons an accurate assessment of the full impacts assoc-
iated with MU 12 implementation cannot be made.

(a). Bird populations are highly variable from day to day,
month to month, season to season and year to year and estimating impacts
related to a single variable (e.g., Area 2 fill) versus population fluctuations
is extremely difficult if not impossible, particularly for migratory birds.
Assessment may require many years of monitoring prior to being able to make an
estimate of impacts, especially since so much of the important habitat is
being protected. Figure C-10 shows the only long-term data which exists re-
garding bird counts made during the annual Audubon Christmas Bird count for
Grays Harbor. These yearly counts were made around the middle of December
over the last 10 years by approximately 40 individuals who covered the whole
estuary and adjacent uplands. Wintering populations of dunlin varied from
7,965 in 1972 to 95,000 in 1976. During two years (1977, 1979) there were
drops in the population of 55,000 birds. As far as is known, no evaluation
has been undertaken of this wide fluction of populations of dunlins in Grays
Harbor. Leadbetter Point, in Willapa Bay is shown by comparison. It shows a
steadier population level. However, Leadbetter Point is only one part of
Willapa Bay. During the winter of 1974 when the Audubon count for Leadbetter
Point was approximately 4,000 birds, the U.S. F&WS made a count of 50,000 dunlins
for the entire estuary. That same year the count for Grays Harbor was 40,000
dunlin. In 1980, the Audubon bird count was 28,000 dunlin and Dr. Steven G.
Herman estimated 40,000 dunlin present in the harbor (Herman and Bulger 1981).
All this points out the extreme variability of bird populations due perhaps
to census taking, timing, environmental conditions, breeding success, and
other factors which may or may not be related to habitat destruction. There-
fore, counts which may differ by several thousands on a monthly or yearly
basis because of many different potential reasons make impact assessment
even more difficult.

(b). Length of feeding time. Herman and Bulger (1981) and
Anderson (1980) point out that one of the reasons the Bowerman Basin is im-
portant is because it provides the shorebirds with a longer feeding time
(1-2 hours) as the tide ebbs and flows. There is a question if the one to
two hours is of major significance to the shorebirds and their survival or
preparation for flight up to Alaska. Future studies would have to be conducted
to determine if the birds which utilize Bowerman Basin have greater increases
in body weight during their winter stay or for the short stopover time they
stay during migration as a result of this extra feeding time. Fifty to sixty
percent of the shorebirds which utilize the estuary apparently do not have or
take advantage of this extra feeding time. To date, there is no indication
that they do not survive the trip to Alaska or are any better or worse off
than the birds using Bowerman Basin; or that there is a greater mortality rate
during "harsh" winters for birds which utilize the other feeding and roosting

C-5 2

FIGURE C-10.
DUNLIN WINTER POPULATION COUNTS
GRAYS HARBOR and LEADBETTER PT., WILLAPA BAY

100,000

I

90,000

Grays 1

terbor

80,000

70,000

60,000

. i

50,000

(U.S.

F&WS,

1975)

40,000

1

(Herman 1981)

30,000

20,000

10,000

j

r l

eadbet

ter Pt. ^N

I

72

73

74

75

76

77

78

79

80

81

82

83

SOURCE: AMERICAN BIRDS, Audubon Chrismas Bird Counts.

C-53

sites. If this extra feeding time does provide some advantage to the birds,
then Area 2 fill is the least environmentally damaging alternative in MU 12
(other than no fill) since it does not provide the birds with the extra feeding
time like the Basin does. Likewise, Area 3 fill would cause greater adverse
impacts.

(c). Related to the length of feeding time is the still
unanswered question of the difficulty of the migratory flight from Grays
Harbor to Alaska. Some bird experts believe that the approximately 1,000
mile (1,600 kilometer) flight from Grays Harbor to Alaska during spring
migration is extremely demanding and requires the birds to replenish fat
reserves in order to make the arduous flight. Hence, the importance of the
Grays Harbor estuary as the last major stopover south of Alaska. This assumes
that the two to five day stopover time is sufficient to replenish fat reserves
and that there would be a gain in weight during this time. This is one of the
items which should receive further study in the coming years. It also assumes
that the birds do not make additional stopovers in other locations to feed and
rest. Senner (1981) reports that the estimated flight range capabilities for
western sandpipers in the Copper-Bearing River Deltas system is about half the
mean estimated range of dunlins 600+77 km (R = 177 - 1081 km) compared to
1260+89 km (R = 744 - 1791 km). These are distances that could not propel
the birds Washington to Alaska on a non-stop flight. These figures are based
upon body weight and fat reserves and the flight ranges are scientifically
estimated. At the same time, Senner and Martinez (1982) have also found that
the potential flight ranges of migrant western sandpipers in spring have been
found in excess of 2,000 km which is enough to allow the birds to make the
non-stop flight. So there is a great deal of variability in the capabilities
of the birds which makes it difficult to come to any definitive conclusions.
Based upon his work in Alaska, Senner hypothesized that dunlins tended to
migrate by extended, non-stop flights, while western sandpipers tended to
stop more frequently (i.e., a series of relatively short "hops") between the
Copper-Bering River Delta systems and the western Alaskan breeding grounds (a
distance of 600-700 miles (1,000 km). Senner, et. al., (1981) points out
that there is no direct basis for evaluating the extent to which either
species makes non-stop flights from Washington and southern British Columbia
to Alaska without conducting extensive survey work along the intervening
coast.

Another point of view is provided by Kaiser (1981). In concluding from obser-
vations and studies on the western sandpiper conducted in the Fraser River
Delta of British Columbia, Kaiser states that "although the migrations cover
long distances and adhere to a specific schedule, neither the northward nor
the southward movements seemed to be particularly rigorous" and "because the
birds forego a large build-up of weight which might be associated with an
arduous overwater flight, they may undertake a more gradual migration using
the many small estuaries and beaches that dot the British Columbia coast. I
have observed western and other Calidris sandpipers on the sandy beaches of
Mclntyre Bay on the Queen Charlotte Islands and on the gravel bars in Big Bay
just west of Prince Rupert during both spring and fall migration. Neither
area contains any typical mudflat communities but they are used by thousands
of shorebirds in the absence of more preferred habitats."

Thus, it may be, for western sandpipers at least, that Grays Harbor is not the
last stopover for at least some portion of the population prior to arriving at
the Copper-Bering River Delta system. Senner (1979) found that the mean body

C-5 4

weights of western sandpiers did not change during the feeding and resting
period in the Delta system prior to flying to other intermediary stops before
arriving at the breeding grounds. Senner concludes that the fact that their
mean body weights do not change across the C-BDR system does not diminish the
value of the system as a habitat in which individual birds can replenish fat
reserves needed for migration and reproduction.

(d). There are several unanswered questions with respect
to the carrying capacity of the Grays Harbor estuary. Given the variability of
the bird populations and also the different densities and utilization rates of
the various sites within the estuary, it is difficult to predict what the
carrying capacity of a feeding area may be. If birds are forced because of
competition (spatial or feeding) to other sites, there is no knowledge that
other sites within the harbor like Wakina Flats, etc., are less desirable or do
not have the capacity during any particular point in time to feed additional
birds. During the 1981 spring migration, Bowerman Basin use varied from a
number of 400,000 on April 23 to 6,700 on May 13 and Bottle Beach from 130,000
on April 25 to 900 on May 13. Populations fluctuated daily and birds moved from
one area to another. Herman and Bulger (1981) reported movement of shorebirds
as a temporal shift in migration from the South Bay to the North Bay area
before and after April 27 and believed the shift was indicative of a migrational
shift as the shorebirds moved in the direction of their northern nesting grounds.
This would be opposed to a belief that the carrying capacity of South Bay had
diminished to such an extent that it could no longer support vast numbers of
birds, although such a possibility can not be ruled out. With respect to
dunlins and western sandpipers use of the estuary, there is no clear cut indica-
tion that other areas in the harbor are less productive or are not capable of
supporting larger populations if some of the birds are displaced, with the
possible exception of the inner harbor area. It may never be known to what
extent the birds are concentrating on less "optimal" tideflats and roosting
sites than previously and whether or not this has resulted in a decrease in
the population of the species. The historical loss of 3,800 acres of tideflats
is likely to have had some negative effects on the shorebird populations over
time, although all tideflats may not have historically been used to the same
degree as the Bowerman Basin. It is not possible to estimate the mortality
factor related to the loss of this habitat over the many years because empirical
data and studies are lacking. Herman and Bulger (1981) state that there is no
way now to estimate the long term impact of the intertidal habitat destruction
that has taken place in the Grays Harbor estuary historically. Also, there
are no records of major winter kills of dunlins in Grays Harbor which can be
related to a lack of adequate food. The weather is relatively mild and the
estuary doesn't ice over and deny the birds important tideflat feeding grounds.

(5). Opinions of shorebird experts.

(a). 0CRM has received directly or has been provided copies
of a number of letters from shorebird experts who have stated their opinion of
the importance of the Bowerman Basin to species of wintering and migratory
shorebirds, especially dunlins and western sandpipers. The list of individuals
include:

C-5 5

o Dennis R. Paulson

o Steven G. Herman

o Stanley E. Senner

o Edward H. Miller*

o Raymond McNeil*

o Gary Page*

o Joseph R. Jehl , Jr.*

o J. P. Myers*

o Frank A. Pitelka*

o Brian A. Harrington*

o Jack Davis

Burke Museum, University of Washington

Professor, Evergreen State College

Hawk Mountain Sanctuary Association

Vertebrate Zoology Division, British
Columbia Museum

University of Montreal, Center for
Ecological Research

Point Reyes Bird Observatory

Hubbs-Sea World Research Institute

The Academy of Natural Sciences of
Philadelphia

Professor, University of California,
Berkely

Manomet Bird Observatory

Black Hills Audubon Society

* These individuals wrote letters of concern to Dr. Dennis R. Paulson and were
provided to OCRM through Mr. David Ortman, Friends of the Earth. Their view-
points are appreciated and their comments on the PDEIS are encouraged. With
Dr. Paulson's permission, copies of their letters are included for the record
as an addendum to attachment C.

(b). Summarizi
to any fill and industrial development
Grays Harbor as a whole, but especiall
stopover location for migratory shorebi
the environmental health of Grays Harbor
importance. They believe that any fil
activities will have immediate as well
both wintering populations and spring a
reduced shorebi rd populations because
uctive success because they believe:

are opposed
believe that
a "critical"

ng their concerns, they

in the Bowerman Basin and

y the Bowerman Basin is

rds along the Pacific Flyway and that

is therefore a matter of international
1 and subsequent industrial land use

as long-term detrimental effects for
nd fall migrants. The result will be
of mortalities or diminished reprod-

o there is a lack of alternative feeding and resting sites;

o many species return to the same sites each year (site fidelity) and
if the habitat is no longer useable, they are incapable of finding new sites
and will therefore be unable to replenish fat resources in order to make the
"exhausting" flight to Alaska stopover grounds on their way to the breeding
grounds;

o the impacts of displacement of the Bowerman Basin will affect the
shorebi rd populations throughout the entire estuarine system (i.e., have a
domino affect).

C-5 6

(c). OCRM concurs in the assessment of significance
of the Bowerman Basin as being an important habitat for many varieties of birds.
It's significance lies mainly in the fact that the Basin apparently provides
conditions conducive to providing the birds with preferred feeding and roosting
habitat and that the birds utilize the area in large, concentrated numbers.
Part of the factors which make the basin a preferred habitat may include
physical features which have in part been created through previous dredged
disposal and fill activities. It has not been shown to date that there are
unique biological features (e.g., the highest density or diversity of prey
species like Corophium or other benthic invertebrates) in relation to other
parts of the estuary which provide the most food for the least feeding effort
per unit of time. This information can most likely be confirmed with subsequent,
focused studies. With the GHEMP, the majority of the Bowerman Basin will be
preserved in perpetuity for the shorebirds. It is not clear that alternative
feeding sites to Area 2 do not exist within the estuary and would not be used
by the shorebirds. Implementation of the provisions of MU 12 does have the
potential of increasing roosting habitat. Further studies need to be conducted
to determine how much the birds increase in body weight (increase fat reserves)
during the short stay in Grays Harbor during migration and if the fat reserves
are a limiting factor in the birds ability to make a 1,000 mile non-stop flight
to Alaska. Future research and observations will provide better answers to
these and other questions.

3. Conclusions

a. Mitigation and enhancement measures built into the GHEMP and the
F&WS opinion include protecting a majority of the existing prime habitat for
the shorebirds which favor the Bowerman Basin. At least 400 acres (out of
500) of the Bowerman Basin will be permanently protected with no future threat
of filling activities. Some negative impacts should be expected whenever
feeding habitat is lost. Area 3 fill would likely produce the most signifi-
cant impacts as that area serves most as a late feeding and prime roosting
site. It is OCRM's opinion that the impacts will not lead to either heavy
mortality factors among the shorebird populations that utilize Area's 2 and 3
or the rest of the estuary based upon the loss of habitat. There is a potential
for Bowerman Basin to be utilized even more intensively in the future and that
peak migrations may show even greater concentrations of birds until a carrying
capacity (during a particularly prolific year) is reached which may differ
from year to year. There are several indications and studies which show that
the shorebirds are able to adjust to new conditions and surroundings. There
have been no reports (historical of recent) which have confirmed major incidences
of mortality of shorebirds in Grays Harbor or in the Copper-Bering River Delta
systems which may be the next stopover point in the birds migratory route to
the western Alaskan breeding grounds. What we are dealing with is uncertainty.
In the face of uncertainty and based solely upon the interests of the bird
population, caution suggests that there be no additional filling in or near
the Bowerman Basin. However, based upon the philosophy which the Task Force
has initiated in which they attempted to balance the economic development
interests with the preservation interests, the current plan shows a clear
attempt by the Task Force at being prudent managers of the resources and seek-
ing a balance and management strategy in MU 12 which attempts to provide some
foresight into a difficult management decision. Additional assessments will
be required in the future to provide further information on which to base
final decisions on particular permit applications.

C-5 7

ADDENDUM TO APPENDIX C:
LETTERS FROM SHOREBIRD EXPERTS IN RESPONSE TO
DECEMBER 22, 1982 LETTER WRITTEN BY DR. DENNIS R. PAULSON

C-58

THOMAS BURKE MEMORIAL WASHINGTON STATE MUSEUM
UNIVERSITY OF WASHINGTON

SEATTLE, WASHINGTON 98195
22 December 1982

We are in danger of losing one of the most important shorebird habitats on
the Pacific coast, and I would like to ask your help in saving it.

Grays Harbor, Washington, furnishes habitat for migrating shorebirds of many
species. Of particular importance is Bowerman Basin, a shallow basin of several
hundred acres adjacent to Hoquiam. Spring migrant shorebirds use this protected
mini-estuary as a staging ground, peaking in the last week of April when hundreds
of thousands of birds are present simultaneously (one estimate of 400,000). The
basin furnishes low-tide feeding and roosting, high-tide roosting and the most ex-
posed flats available for feeding just before and just after high tides. Bowerman
Basin is extremely important at that time, and, in addition, it supports flocks of
tens of thousands of shorebirds through fall migration. Western Sandpipers, Dunlins
and Short-billed Dowitchers are the abundant species, the Dunlin also wintering in
the tens of thousands (almost 100,000 in one peak year).

Developers and planners in the Grays Harbor Estuary Planning Task Force are
trying their utmost to clear the way for the filling of Bowerman Basin or parts
thereof for marine-related industries, because it is shallow and convenient to Hoquiam.
Local environmentalists and biologists, including Steven G. Herman and myself, have
apparently halted the original plan to fill the entire basin, primarily because
Peregrine Falcons use the area. Recent modifications of the plan include the filling
of as much as one-third of the basin, and the proposed fill sites encompass some of
the most valuable feeding and roosting area now used by the birds. No matter how we
have tried, we have not entirely convinced all interested parties of the value of
this site, certainly the biggest concentration of shorebirds on the west coast south
of the Copper River delta. This has been documented -by Herman and John Bulger in a
report to the U. S. Army Corps of Engineers in September 1981.

We think that with a bit more professional input our statements about these
matters will gain more credibility. Could you possibly write a letter to me about
the international importance of Grays Harbor and, ^specially, Bowerman Basin? This
of course would be based on your professional expertise as a shorebird biologist,
and a sentence or two making that expertise clear would be a valuable part of the letter.

I hope you will find time in what I know is a busy schedule to write at least
a brief letter. David Ortman, of Friends of the Earth in Seattle, has been the most
active environmentalist in this process, and he will probably follow up on this by
phoning you after the first of the year, as there is a sense of urgency. The Task
Force is attempting to wind up its deliberations, and an E.I.S. is being written at
this time that could include your comments. My phone number is 206-543-4486 if you
have any questions that I might answer; David's is 206-633-1661. Thank you very
much for anything you can contribute.

Sincerely yours,

Dennis R. Paulson

Arfincr f!iim1-nT- nf 7nn1nou

HUBBS-SGA WORLD RESEARCH SMSTITUTG

wmaammmmtmammaBmammmMmm

1700 South Shores Road Mission Bay, San Diego Calrfomia 92JOB (714) S23-2693

4 January 1983

Dr. Dennis R. Paulson

Burke Memorial Washington State Museum

University of Washington

Seattle, WA 98185

Dear Dennis:

Thank you for alerting me to the status of the Bowerman 'Basin. That is
not good news.

As you know, I have been studying shorebirds and their migrations for over
25 years and have published rather extensively about this group of birds.
Accordingly, I feel qualified to at least make some general comments on your
situation, even though I have no direct knowledge of the area.

We have known for a long time that many species of shorebirds make very
long non-stop migrations; some cover only a few hundred miles at a flight, but
others may. fly as much as 3,000 miles nonstop. Such flights, of course, are
very taxing energetically, and many birds arrive at their destination totally
exhausted, with their fat reserves fully depleted, and are unable to proceed
farther without a rest stop of 10-14 days.

We have also been able to establish that many species return each year
to the same traditional staging areas. If, for some reason, these areas
disappear, or if ecological conditions change such that the area can no longer
support the numbers of birds that rely on them, the consequences could be
serious. Indeed, entire populations of species could be affected, perhaps
even to the extent that they would require (or demand) special protected status
(i.e., endangered, threatened) from governmental agencies.

These staging areas, then, are really "critical habitat" for many species,
and they should not be tampered with unless one is absolutely sure that
alternate sites are available.

All of the information available to me indicates that the Bowerman Basin
is. an extremely important staging area for many species of shorebirds, both
in spring and fall. Furthermore, I know of no alternate sites that can take
its place, should it become degraded or changed.

A non-profit research organization

All of the species that stage at Bowerraan Basin are long-distance migrants,
which move from Alaska to Central or South America. Many breed in the Canadian
arctic. Thus, we are dealing with an area that has international importance.
Harmful actions in Washington can imperil the resources that belong, equally,
to other nations. The Migratory Bird Treaty protects these animals from being
killed directly. Should it not be extended to prevent the indirect death as
a result of destruction of the habitat on which they rely.

I urge you to continue your efforts to sensitize local authorities to the
value of this area, and I would further urge you to bring this matter to the
attention of the National Audubon Society or other environmental groups, so
that all the relevant information can be fully discussed and evaluated prior
to the making of an irreversible decision.

Sincerely yours,

'Joseph R. Je
Assistant Director

JRJ/eg

Province Of Ministry Of British Columbia

British Columbia Provincial Secretary Provincial Museum

. — . o. Parliament Buildings

and Government Services victoria

PROV.NC.AL SECRETARY Brjtjsh Co|umbja

V8V 1X4

5 January 1983

Dr. D. R. Paulson
Burke Museum

University of Washington
Seattle WA 98195
U.S.A.

Dear Dennis :

I remain horrified at the prospect of Bowerman Basin being reduced
in extent by filling, for "development." The basin is truly extraordinary
in its value to shorebirds passing north to breeding grounds in Alaska, the
Yukon, and northern British Columbia, at the very least. It is also enormous-
ly important to certain species during winter and in fall migration. The
simple statistics of use of the area by species and numbers attest to its
significance, but conceal a very complex web of cause and effect. For
example, there is simply nowhere else for the vast majority of the shorebirds
to go; they can not just shift to another location, partly because none
exists, and partly because they are highly conservative animals. Available
evidence from South America, Europe, Africa and both coasts of North America
indicates that shorebirds are strongly site- faithful from year to year, both
to their wintering areas and to their migration stopover points. Further,
the evolutionary "choice" of the Bowerman Basin (and other parts of Grays
Harbor) as *a stopover point in spring (for example) was based on its rich-
ness and its proximity to the nesting grounds: it is crucial for these birds
to "fuel up" before making their flight north to breed, as is well known
from studies on energetics and fat deposition. Finally, evidence being com-
piled over the past decade points to wintering areas and migration stopover
areas as the most important parts "of shorebirds1 life cycle, as far as their
population regulation is concerned. We can get away with far greater distur-
bance on their breeding areas than we can elsewhere, without materially im-
pairing the health of shorebird populations.

As you know, my shorebird research over the past nine years has covered
breeding areas from Nova Scotia to the north coast of Alaska. In the past
few years, I have been working in Alaska, the Yukon, and northern British
Columbia. It is no exaggeration to predict that significantly large areas
there would become impoverished to nearly depleted of certain shorebird species
if an act as major as the filling of Bowerman Basin were committed, and this
is particularly true of species with modest to low nesting densities, like
Short-billed Dowitchers. I strongly oppose such action on both scientific and
environmental grounds.

Edward H. Miller
Curator

Vertebrate Zoology Division
EHM:nk

4 -.-*»sj>W< ^ \ -.,..1 . ■•& *■»

■*_ _7 -

POINTS REYES BIRD ^JOB SERVITOR Y

4#0*-Shoreline Highway, Stinsctfffiea^tJaiiforiSia S4V1&
N.^_ Telephone (415) 868-12*1^-* _ ^

•

January 11, 1983
Dear Dr. Paulson,

Your letter describing the threat to the habitat of hundreds of
thousands of migratory shorebirds in the Bowerman Basin concerns rae. Over
the eleven years I have studied shorebird use of California wetlands I have
discovered few areas that hold the large concentrations you describe. In
fact in a recent conversation I had with Dr. Marshall Howe concerning the
identity of locations with at least 20,000 shorebirds during migration, we
only identified a handful of sites in California. A site that holds
100,000 is truly unusual! One wonders what these birds will do if they
lose their habitat. What other feeding sites have been identified to
absorb the refugees? Will this cause population declines that will show up
as decresed numbers at California wintering sites? If the site is a
staging area for long non-sfcop flights, say to breeding areas in Alaska,
the problem may be even more serious.

Your efforts to oppose this particular development project are
definitely worthwhile. I hope the decision-makers in Washington will agree
to value this resource and you succeed in substantially scaling down the
project.

FOUNDED IN 1812

RESEARCH • MUSEUM • EDUCATlOl

PHILADELPHIA

18 January 1983

Dr. Dennis Paulson

Burke Museum

DB-10

University of Washington

Seattle, Washington 98195

Dear Dr. Paulson:

Without doubt or exaggeration, Grays Harbor plays a crucial and irreplaceable
role in the migration of hundreds of thousands of shorebirds on the Pacific Coast
of the United States. If this area is altered substantially, we risk threatening
a substantial and significant portion of the West Coast populations of many dif-
ferent bird species, species that nov; are common, populations that extend from the
arctic to South America. This is because of the critical geographic location of
Grays Harbor along the Pacific Coast and the habitat it affords migrating birds.
The environmental health of Grays Harbor is thus a matter of international concern.
Any reductions in the extent of intertidal habitat must be avoided, and alteration
in the natural condition of Bowerman Basin would be especially damaging to inter-
national populations.

As a professional biologist who has worked on the population biology of
migrating and wintering shorebirds along the Pacific Coast for the last 10 years,
as a current board member of the International Council for Bird Preservation —
Panamerican section, as Chairman of the Wader Study Group Steering Committee for
North America, and as a member of the Neotropical Migrant Bird Advisory Council
for the World Wildlife Fund-US, I am greatly distressed that Grays Harbor is now
threatened by plans to fill Bowerman Basin. In my professional estimation this
has significant potential for doing irreparable harm to the health of the Pacific
Coast shorebird migration system.

Shorebirds such as Dur.lin Calidris alpina, Western Sandpiper Calidris mauri,
Short-billed Dowitcher Limnodromus griseus, Black-bellied Plover Pluvialis squat-
arola, and Semipalmated Plover Charadrius semipalmatus depend utterly on the
resources they gather at staging areas during migration in order to complete their
annual cycle. They fly into these sites in vast numbers, replenish their energy
stores, then resume migration. Grays Harbor is one such site, and it is one of
the most important along the Pacific Coast of the US. Work by Herman and Bulger
in their report to the U.S. Army Corps of Engineers clearly documents this fact.

Traditionally Grays Harbor has been used by hundreds of thousand of shore-
birds a j they head northward to the breeding ground, and surveys indicate it is
so important because of the extremely limited supply of suitable estuarine areas
in the Pacific northwest. Thus the consequences of reducing a patch of intertidal
habitat in Bowerman Basin extends far beyond the local area. It will materially
affect the ability of hundreds of thousands of shorebirds to reach their breeding
ground in breeding condition. We cannot risk the possible consequences of that
effect.

THE ACADEMY OF NATURAL SCIENCES OF PHILADELPHIA • 1 9TH & THE PARKWAY. LOCAN CIRCLE • PHILADELPHIA PA 1 9 1 03

There will be local consequences also. Based on my research in the central
coast of California, in an estuary system not unlike Grays Harbor — but much smaller
— we know that wintering populations (as opposed to migratory) depend upon a mosaic
of habitats in order to survive through the winter. What happens in one part of
that mosaic, for example, in Bowerman Basin, will affect shorebird populations
throughout the entire estuarine system, in this example the Grays Harbor area.
This is especially the case for key habitats within the estuary systems that are
especially rich. in food resources. As shown by Herman and Bulger's work, this
is clearly the case for Bowerman Basin.

Over the last 100 years, intertidal habitats for shorebird populations along
the Pacific Coast have been devastated by development. Over much of the region
less than 30% of the original area remains suitable for shorebird use. Based on
a large body of research on the ways that shorebirds feed, particularly by John
Goss-Custard and his colleagues in Britain, we know that the habitat removal has
long-lasting detrimental effects on the size of wintering shorebird populations.
We cannot afford to lose another major wintering area, much less one of such
singular importance as Bowerman Basin.

Since w*ly yours,

J. P. My*
Assistant Curator
Ornithology

JPM:krg

UNIVERSITY OF CALIFORNIA, BERKELEY

BERKELEY • DAVIS • IRVINE • LOS ANGELES • RIVERSIDE • SAN DIEGO • SAN FRANCISCO

Reply to:

MUSEUM OF VERTEBRATE ZOOLOGY
2593 LIFE SCIENCES BUILDING
BERKELEY, CALIFORNIA 94720

20 January 1983

Dr. Dennis R. Paulson

Thomas Burke Memorial Washington State Museum

University of Washington

Seattle, WA 98195

Dear Dr. Paulson:

I am dismayed to learn of the possibility that critical intertidal
habitat at Grays Harbor now used by massive numbers of migrating shore-
birds may be filled and developed commercially.

This locality is already known to be a major staging area for
northward-bound shorebirds, and it is also very important for southward
migration and as a wintering area. These statements apply to Grays
Harbor as a whole, but especially to Bowerraan Basin.

The numbers of birds recorded there indicate that Grays Harbor
may well be one of the truly critical stopover locations for shorebirds
along the entire Pacific Coast, from Alaska to South America. This lifts
concerns for the area from the local level to the international level.
At least half of the various shorebirds concerned, I would estimate, are
moving between high latitude breeding grounds (in Alaska and northwestern
Canada, even eastern Siberia) and wintering grounds (at varying distances
south, as far as the Chilean coast and the southern half of Argentina).
Because of this international significance, I trust the problems at Grays
Harbor are getting the active attention of federal agencies such as the
Fish & Wildlife Service and private agencies such as the World Widlife
Fund .

Why is a certain stopover location used massively by migrating
shorebirds termed "critical"? These are places where migrants stop
after long and exhausting flights and where they take 5-10 days to recoup
and regain weight by feeding and depositing fat.

The general facts and concerns for migrating shorebirds along the
Pacific Coast expressed here are backed by papers in "Shorebirds in
Marine Environments" (Studies in Avian Biology No. 2), published in
1979 and edited by me. In addition, since 1975 we have had a program
of intensive research on wintering and migrating populations of shorebirds
at Bodega Bay in central California, sponsored by the National Science
Foundation. We have concentrated on one species, the Sanderling, banding
and color-marking hundreds of them to get solid data on local movements
and in particular on the question of discreteness of local populations
relative to suitable stopover and wintering sites along the coast. These
data strongly indicate that the individuals of a given sub-population use
and re-use year after year a given area, such as the Bodega Bay beach/

lagoon system. The migration of a given sub-population is adapted to
the geographic placement of specific and dependable sites, and has been
so adjusted over eons of time. Any disturbance or elimination of habitat
serving as critical stopover and staging sites thus echoes in the shore-
bird life of the entire Pacific Coast from the Arctic to southern South
America.

It is only with recent, locally intensive banding and color-marking
of shorebird populations that we are beginning to realize some of the
implications of cutting back yet more on remaining maritime habitat
so important to migrating birds, not just shorebirds but many other
kinds as well. I have no doubt at all, personally, that were there
studies based on large numbers of banded birds moving through or otherwise
using Grays Harbor, they would support all I have said about its importance,
Here I refer not to the already available results of intensive census work
documenting the high numbers of shorebirds moving through and/or wintering
at Grays Harbor, but to the evidence expected from banding as to the impor-
tance of Grays Harbor as a link in migrating systems involving many areas
to the south and north.

I most strongly urge you and your colleagues in western Washington *
to continue your campaign in behalf of the protection of critical
intertidal habitat in Bowerman Basin and the rest of Grays Harbor.

Sincerely yq^irs ,

Wank A. Pitelka
Professor of Zoology

P:l

w

cr*m

Universite de Montreal

Centre de recherches ecologiques de Montreal

11 February, 1983

Dr. D. R. Paulson

Thomas Burke Memorial Washington

State Museum

University of Washington

Seattle, 'Washington 98195

U.S.A.

Dear Dr. Paulson:

Sorry to come so late in reply to your letter dated
22 December 1982.

Taking into account the species of shorebirds and the
numbers of individuals observed in the area of Grays Harbor, especially
in the Eowerman Basin, as a staging ground, a feeding, a roosting and
a wintering site, the Bowerman Basin is a strategic area comparable to
the best similar areas of other regions (Atlantic coast of North and
South America). As far as I can see by the literature, it supports the
highest concentrations of shorebirds on the Pacific coast during spring
migrations.

Since a few months, I am documenting and evaluating the
habitat losses for shorebirds along the northern coast of South America.
The good staging areas for spring migrant as well as fall migrant shore-
birds are dangerously decreasing in some regions. Good staging areas are
particularly important in the U.S.A. and southern Canada because, as we
can see by fat deposit studies, such areas provide the shorebirds with
the necessary food requirements for depositing the energy reserves neces-
saty for the flight to the breeding areas in Arctic regions, and facing
inclement conditions on the breeding grounds before or at the beginning
of the nesting activities.

I really have difficulties in understanding why, in 1983
and in the U.S.A., it can't be possible to developpers and planners to
find places for marine-related industries outside good wildlife habitats.

Consequently, I strongly support all efforts to save
the Greys Harbor and Bowerman Basin shorebirds habitats.

Very sincerely,

Raymond McNeil

5858. chemin de la Cote-des-Neiges, bureau 400. CP. 6128. succursale A. Montreal. Quebec. H3C 3J7. teleDhone. 343-6190

APPENDIX D
VARIOUS ARTICLES ON THE GHEMP PROCESS

"The lasting benefits that society derives from [wetlands]
often far exceed the immediate advantage their owners
might get from draining or filling them. Their destruction
shifts economic and environmental costs to other citizens —
often in other states — who have had no voice in the
decision to alter them."
— The President's Message to the Congress, May 23, 1977

COMPROMISE

AT GRAYS HARBOR

DANIEL JACK CHASAN

Brown mud slopes up gradually from the
salt water's edge. Above the brown, the slope
is coated by a growth of mossy green.
Beyond that, an expanse of tall yellowish
grass ripples in the wind. Not far from this
patch of marsh, on the northern shore of
Grays Harbor, stand the pipes and stacks
and rusting metal buildings of a huge pulp
mill. Logs float in booms along the
shoreline, lie in great heaps on the land. Lift

trucks pile them on the aging freighter
Seizan Maru for shipment to Japan. The
foul smell of pulp mill effluent rises from
settling ponds. Nearby, the port-and-
logging cities of Aberdeen and Hoquiam
crowd down to the water's edge. In the
distance, a great cloud of smoke rises from a
slash burn in the eastward hills.

At first glance, it seems inevitable that
sooner or later, the port facilities and

Reprinted with permission from the author,
From PACIFIC SEARCH, February 1978

D-l

industry will spread out over the marsh
Dredges will deposit their spoils along the
shore. Bulldozers will flatten out the fill.
Pavement will be laid, buildings erected, and
an otherwise-worthless patch of land
brought into the local economic system.

Not long ago, that transformation
probably would have been inevitable. It is
not inevitable now, largely because there are
people in government agencies who do not
consider the land worthless and will fight
tooth and nail to prevent the wholesale
filling in of this or any other estuary. In
Grays Harbor, they've been fighting for
some time.

Estuaries — enclosed arms of the sea in
which salt water meets and mixes with
fresh — are valued by biologists for the great
quantity and diversity of life that feeds in the
shallow waters and adjacent marsh. Phrases
like "web of life" are often used to describe
the complex ecosystems that flourish among
the eelgrass and pickleweed and bulrushes
and sedge, and the biological productivity of
such areas is often compared favorably with
the productivity of land given over to human
agriculture. That field of yellow-green grass
rippling in the wind produces more living
matter per acre than anything human beings
grow except a field of sugar cane. It dies
down completely every year, decomposes,
and ultimately nourishes everything in the
food chain, from the brown diatoms and
green algae on the mud to salmon, steelhead,
and occasional whales in the water, and the
ducks, herons, and other waterfowl in the
air.

Grays Harbor, which covers some 55,000
acres on the Washington eeast, is connected'
to the Pacific by a narrow channel that
separates the spits of land on which stand the
resort towns of Westport and Ocean Shores.
Fresh water flows into it from the Chehalis,
Hoquiam, and Humptulips rivers. It
supports more than 50 species of fish,
including salmon and steelhead spawned in
the rivers, large populations of oysters,
clams, and crabs, and 325 species of birds,
one-third of all the species found in
Washington State.

A Western estuary the size of Grays
Harbor "is such a rare thing," Nancy
Thomas, president of the Washington
Environmental Council, has remarked. "If
you look down the Pacific coast from
Washington, after Grays Harbor and
Willapa Bay you have to go down to Coos
Bay and San Francisco before you find
another major estuary of this size. You don't
mess around with it until you know what the
impact will be."

Actually, people have been messing
around with Grays Harbor since the
beginning of this century. Aberdeen,
Hoquiam, and the Chehalis River towns of
Cosmopolis and Montesano have been
exporting wood products ever since then,
and the shipping channel has been dredged
repeatedly. Spoils from the dredging have
been deposited in marshy areas, and
portions of the shoreline have become the

February 1978

habitat not of wildlife but of human
commerce and industry. "Between 1940 and
1975, dredgings were dumped on about
3.850 acres of intertidal areas," game
biologist David Mudd has written in
Washington Wildlife. "We don't know how
much eelgrass and salt marsh was lost, but
1950 aerial photos show eelgrass and salt
marshes where upland areas no"\v ^\h>r.'"

The filling of Grays Harbor according to
the dictates of economics and convenience

Biologists value estuaries/or
the profusion of wildlife
they support. But portions
of the Grays Harbor
shoreline now support
commerce and industry, not
wildlife.

did not stop with the passage in the 1970s of
the federal Water Pollution Control and
Coastal Zone Management Acts, the
resurrection of the federal Rivers and
Harbors Act of 1899, or the passage of the
state Shorelines Management Act, but its
progress became much less swift and sure.
Federal and state agencies that were
committed more to the preservation of the

natural environment than to industrial
progress gained both the power and the
willingness to hold up permit applications
indefinitely, and they began to use that
power. Boise Cascade had an application for
waterfront filling held up for two years
Finally, the company announced that if its
application wasn't approved within two
weeks, it would abandon its expansion
plans. The Port of Grays Harbor and the
nearby municipalities, conscious of the
area's high unemployment and its limited
attractiveness to industries not dependent
on logs, were eager to have Boise Cascade go
ahead. Pressure was applied, and the permit
was granted— with the understanding,
however, that Boise Cascade's would be the
last major permit granted before all
interested parties had developed an overall
plan for the estuary.

Things didn't work out that way. It wasn't
long, in fact, before a much more ambitious
and much more intrusive filling project was
on the drawing boards: the Kaiser Steel
Company wanted to fill 45 acres,, including
39 acres of wetlands, to create a site for the
"assembly of offshore drilling platforms. The
Port was delighted. The Grays Harbor area
depends heavily on the forest products
industry, with its wild swings in
employment. Here was a chance to get an
entirely new kind of industry.

The "resource agencies" (those state and

WILLAPA BAY: An End to Dredging

Willapa Bay, which occupies most of
coastal Washington between Grays Harbor
and the Columbia River, is the last relatively
unspoiled large estuary in the United States.
It is not currently threatened by
development; but only a few years ago, it
was the place where the major
environmental battle over Northwestern
estuaries was happening.

For many years, the U.S. Army Corps of
Engineers had kept a channel for deep-draft
vessels dredged through the mouth and
northern body of the Bay, between the
Pacific and the port of Raymond. As at
Grays Harbor, the channel tended to silt up,
and the only way to keep the port in business
was to dredge. Spoils from the dredging
were deposited on marshland.

The channel was cleared routinely, with
little or no controversy, until the early 1970s,
when the Corps put together a feasibility
study and a draft environmental impact
statement for continued dredging. A
number of environmental groups protested
vehemently, and the Board of Engineers for
Rivers and Harbors, sitting in Washington,
D.C., refused to authorize the additional
studies that would be needed if the dredging
were to go ahead.

The project was stalled but not forgotten,
and it became increasingly controversial.

Environmentalists argued that, as a large
and valuable estuary, Willapa Bay should be
allowed to exist in its natural state.
Advocates of dredging argued that no
dredging meant no more deep-draft vessels
at Raymond, which meant no more jobs
loading logs or lumber on the Raymond
docks.

In 1975, the Corps issued another, more
carefully drafted impact statement, which
included a rigorous cost-benefit analysis.
According to the Corps' calculations, the
economic benefits of dredging promised to
be only 56% of the cost. By that time,
Weyerhaeuser, whose logs were the ones
being shipped through Willapa Bay, had
evidently decided on its own that using the
port of Raymond wasn't especially
profitable. Weyerhaeuser and the Corps
both reasoned that it would be cheaper to
truck the logs to Grays Harbor, a short drive
up Route 101, and load them on ships there.
The Corps decided not to dredge for deep-
draft vessets tffter Ty77. That decision
implied at least three things: Willapa Bay
itself would not be used or developed as a
conduit for ocean shipping; Raymond
would be consigned to eventual oblivion as a
port; and the pressure to maintain and
expand the Port of Grays Harbor would
increase. D.J.C.

D-2

GRAYS HARBOR

federal units responsible for protecting
natural resources) opposed the fill. But local
officials wanted it very badly, and besides,
the manufacture of drilling platforms
seemed to further the national policy of
developing domestic energy resources. A lot
of political pressure was brought to bear.
Finally, Senator Henry Jackson's office got
into the act. The Kaiser project should go
ahead, Jackson's representative said, but the
practice of fighting over every permit
application that came down the pike had to
stop; after the Kaiser permit was approved,
all the contending parties had better work
out a plan for the estuary. (The filling was
done right away; but at this writing,
ironically, a poor market for drilling
platforms has kept Kaiser from building
anything on the fill.)

This time, something happened. At the
enH of 1975, the Grays Harbor Regional
Planning Commission set up an Estuary
Planning Task Force, which included
representatives from the Port of Grays
Harbor, all the nearby municipalities, and
the eight state and federal agencies that had
some form of jurisdiction in the estuary. The
first step was hiring the Salem, Oregon
consulting firm of Montagne-Bierly
Associates to coordinate the planning
process. (In the early 1970s, as an Oregon
state official, Roland Montagne had
presided over the creation of a successful
management plan for the lower Willamette
Valley.) Montagne's first move was to
assemble a technical committee to compile
the necessary information. Then, in
February, 1977. trie Estuary Planning Task
Force began to work out a plan.

The Task Force was a wildly disparate
group, united only, by a common
dissatisfaction with the way things were
going and a common apprehensiveness
about the future. The Port and

Without an overall plan,
every development proposal
meant a new battle.

municipalities did not like the delays and
uncertainty of the permit process; the
resource agencies did not like the piecemeal
nibbling away at the estuary. Without an
overall plan to which all parties agreed, there
was little chance that the situation would
improve from either point of view.

To begin with, the factions were poles
apart. The Port, which wanted to preserve
Grays Harbor's position as the only deep-
water port on the Washington coast and
realized that a lot of space was one of its
chief assets, wanted freedom to develop all
of the 2200 acres it owned along the harbor's
northern shore. The municipalities, which
favored development, were jealous of their
local jurisdiction and resented any meddling
by outside agencies. And the meddlers, the
10

people from the resource agencies, were
determined to stick to their guns and
approve filling only on a case-by-casc basis.

They felt that any loss of wildlife habitat
in the estuary was significant.

"The first thing they say," one biologist
observed, "not just in Grays Harbor but all
over, is 'how much development does it take
to have an impact? It's as if I said to you,
'O.K., I'm going to start chopping off your
fingers one by one. How many do I have to
chop off before you become unfunctional?"

The resource people and outside
observers from the environmental
movement would have been happy to see
dredging and filling in Grays Harbor stop
completely. Liz Greenhagen, a vocal Ocean
Shores resident who has followed the
planning process from the beginning — she
refers to herself as the "token
environmentalist" in the cast of characters —
says that has never been realistic. "You can
come down from someplace else," she says,
"and say, 'wouldn't it be nice to save a whole
estuary,' but you can't really do that. Living
here you can't just beanti-dredging, because

our economy depends on it." You can,
however, try to "show the port and great
planning authority that the estuary is good
for something besides dredging and filling."

When the various interested parties sat
down together, approaches to planning
differed sharply. Local officials were more
interested in specific development
projects — a Thunderbird Motel turned out
to be a big one — less interested in the
generalities of planning, and much less at
home with the maps and charts and
technical data with which the plan was being
forged. Resource people, partly because of
their backgrounds, focused more intensely
on technical details, realizing the need, for
example, to figure out exactly what
marshland is, and to determine where it
begins and ends. Whatever the reasons, it
became clear that the participants weren't all
on the same wave length. Late in the
planning process, after hours of heated
argument over developing the part of the
northern shore (on which the Kaiser fill
already jutted into the water like a huge, rip-
rapped parking lot), one local mayor
consulted a map and concluded that the area
was, and was scheduled to remain, all but
totally natural.

This group, as edgily self-conscious as a
convention of lions and lambs, was
supposed to come lip with a detailed plan for
the whole Grays Harbor estuary. Observers
have compared their proceedings to difficult
labor-management negotiations. Certainly,
the more intense sessions fit that description.
At first the 'consultants (Montagne and

Gordon Davis of the firm of Wilsey and
Ham, who actually ran the meetings) steered
the group away from the touchier subjects
And within the sessions, there was some
pressure to avoid conflict by simply
abandoning certain areas to development
The resource people resisted. Why not just
keep Willapa Bay largely unspoiled and
develop Grays Harbor intensively? Because
Grays Harbor was valuable in and of itself,
and habitat lost there would not be replaced
Why not preserve the south shore of the
Harbor, which now, except for pilings and
log booms, presents a largely unbroken line
of marsh and alders, and develop the north9
Because the north side is more productive,
and again, habitat lost is habitat lost. Why
not forget about the largely developed area
around the eastern end of the Harbor, most
of which was already zoned commercial and
industrial, and preserve portions closer to
the ocean? Because with a higher percentage
of fresh water and with finer sediment, the
eastern end was more productive. And so
on.

The touchiest area of all was the one
behind the airport, Bowerman Field, on the
northern side of the main channel. When
this area came onto the agenda, the meeting
lasted far into the night and resumed the
next morning. One side would caucus, then
come in and present a proposal. The other
side would then caucus, and come back with
a counter-proposal.

The area "is the subject of quite a battle
between the Port of Grays Harbor and
environmentalists," The Aberdeen World
reported. "The Port wants to fill the land —
three square miles of it if possible — with
dredge material and lease it to heavy
industry, while representatives of state and
federal agencies have indicated that they
would like the expanse of grassy marshland
preserved.... When [Hank] Soike [general
manager of the Port] indicated the Port's
wishes by sweeping his hand across an aerial
photograph of the area. ...a couple of the
resource agency representatives gasped
indignantly. ...[Stan] Lattin [planning
director of the Port] then directed the
group's attention to a large map, where the
Port's version of an adequate industrial site
was blocked out in purple....

" 'No way would we allow filling of that
entire purple area,' said Ron Lee of the
Environmental Protection Agency. 'It's just
too expansive.'

" That's more fill than I think we'd look at
nationwide in five years,' [Chuck] Walters
[of the National Marine Fisheries Service]
added. 'This kind of a chunk is like giving
you several gold mines. I just can't see it.'

"Soike then offered to cut the Port's
proposal by two-thirds, but when the
resource representatives received no
assurance that the Bowerman Field site is
the only major filling planned, the task force
stalemated....

"Said Walters: *1 just spent a week
testifying against a sixth-of-an-acre fill, and
now I have a 500-acre fill proposal. I don't

D-3

know how that's going to go over....' "

Eventually, the two sides worked out a
compromise: the Port would limit its
expansion plans to 500 acres over the next 50
years. The resource agencies would resign
themselves to the development of those 500
acres. Both sides had made significant
philosophical concessions. The Port was

The compromise could set
a national precedent for
settling wetland disputes.

renouncing for 50 years the right to do as it
pleased with land it owned. The resource
agencies were renouncing the right to
protect the development of 500 acres of the
most preciously productive habitat on earth.
For people used to haggling over sixths of an
acre, the idea was staggering.

"The Fish and Wildlife Service basically
got the short end of the compromise,"
suggests Dale Jones, Northwest
representative of Friends of the Earth. "The
Fish and Wildlife Service tries— the people
who worked on this should get a pay raise —
but politically, they just don't have the
muscle to cope." Another observer suggests,
though, that "the resource agencies have
been viewed as kind of poor boys, and they
like that image, but don't kid yourself — they
pull a lot of power out of Washington, D.C.
I don't think they got the short end of the
stick in Grays Harbor. I think they got a
pretty good compromise." Certainly, the
municipal officials— who must live with
their constituents, as well as the plan — felt
that they had given up a great deal, too.

In fact, a good many of the people
involved probably felt like those described
by the wise old attorney who noted that in a
"good settlement" both sides always go away
from the table "a little sick to their
stomachs."

By now, the whole estuary has been
divided into planning areas, and detailed
specifications agreed on for the amounts and
kinds of development that can take place in
each of them. All the participants have
approved the plan. Now, if it is to be more
than an abstract declaration of intent, it
must be incorporated into local zoning
codes.

A lot of people far from Grays Harbor are
watching closely to see just exactly what it
does become. Because Washington was the
first state to gain federal approval for its
Coastal Zone Management Act, the
planning done in Grays Harbor with Coastal
Zone Management money is viewed as a
possible precedent. "We think this has
national significance," says Hank Soike,
manager of the Port of Grays Harbor, and
Montagne says the plan marks "the first time
something like this has been done on this
grand a scale."

And because — with President Carter's
^executive order of May 1977 — saving
wetlands has become a national policy, ports
all over the country are more than casually

Pacific Search

■interested in how conflicts between wetlands
and port development are worked out. The
Northwest offers a couple of interesting
examples in addition to Grays Harbor. In
the port of Everett, Washington, a conflict
between preservation and development is
being worked out through mediation. In
Oregon, a state law now says that before any
part of an estuary can be developed, the
development must be formally judged to be
in the public interest. If it is judged in the
Oublic interest, then any loss of estuary
nabitat must somehow be "mitigated." At
Coos Bay, when the airport expanded out
/into the estuary, the loss of habitat was
mitigated by returning an equal portion of
the bay, enclosed behind old dikes^ to its
natural state.

Ultimately, the people who have grown
concerned about the Grays Harbor estuary
believe that the essential job is not planning,
but education: the public must be taught the
value of estuaries in general. An
understanding of the processes that go on
there is crucial, because no one is going to
make an effort to save marshes or eelgrass
beds for themselves. "One of the problems
we have with estuaries," says Dale Jones,
"especially the Washington estuaries, is that
they don't have the beauty of a Mount
Rainier." Bob Bowker, a Fish and Wildlife
Service biologist who served on the Estuary
Planning Task Force, suggests that people
must learn "to tie the habitat to the

critters" — that is, to realize that the
profusion of fish and animals that they value
can't exist without the marsh and grassy
water that they don't value.

In the Grays Harbor area, commercial
fishing, sport fishing, and tourism all depend
on the salmon and steelhead that pass
through and spend varying lengths of time in
the estuary. If you ask a state Game
Department biologist why one should even
try to save areas near the huge Rayonier
pulp mill, for example, he may reply that all
the anadromous fish that spawn up the
Chehalis and its tributaries must pass by that
point. The mouth of the Chehalis is already
heavily developed. Steelhead planted
upriver by the state return at a rate of .5%.
Farther west, in the largely undeveloped
Humptulips, the rate of return is 5%.

So far, there has been no outpouring of
sentiment in favor of saving the estuary for
the fish. But Stan Lattin suggests that the
planning process has educated many of the
participants and various other local civic
leaders, if not the public at large, to the fact
that the issue is not simply one of saving
worthless mudflats. By now, he says, when
those people look at the estuary, "they know
that something's going on there." That
alone, he believes, is enough to justify the
time and effort spent on planning.
Greenhagen almost agrees. "I'm interested
in reaching more people," she says. "It's
bigger than just Grays Harbor."

D-4

Compromise plan
on estuary may
satisfy both sides

By SANDY NELSON
World Staff Writer

The Grays Harbor Estuary
Management ' Task Force modi-
fied Us original plan Tuesday,
offering a new proposal that could
ease the five-year stalemate be-
tween concerned conservationists
and those who say waterfront
development is vital.

The task force learned during
public testimony Monday that its
proposal to fill Bowerman Basin
— the 500-acre mudflat between
Highway 109 and Hoquiam's Bow-
erman Field — may threaten the
existence of the endangered pere-
grine falcon.

On Tuesday, the panel — com-
posed of representatives from 16
state and federal agencies and
local municipalities — threw out
its original agenda, rehashed the
problem and bounced back .with a
compromise plan that could pre-
serve the estuarine habitat for,
migratory birds while giving in-
dustry a place to grow.

If approved, the new design
would extend' Moon Island — also
known as the Bowerman Field
peninsula — westward with fill
material in an effort to preserve
the mudflats to the north.

"WE'VE SEEN some positive
changes in the direction the task
force has taken," said David Ort-
mann, Northwest representative
of the Friends of the Earth and
one of the most outspoken critics
of the original plan. "We're much
more hopeful that our plans will
be addressed in the near future,
and it looks like there's a possibil-
ity of resolving the conservation-
development stalemate that has
developed."

Pat Dugan, director of the
Grays Harbor 'Regional Planning
Commission, which initiated the
task force five years ago, said he
was optimistic despite the fact
that the new twist represents "an-
other significant delay (in the
planning process)."

"I'm still firmly committed to
what we're doing," he said. "The
process takes a long time, but I
think it works. We've got signifi-
cant practical problems in reach-
ing compromises, but I'm still
optimistic."

IN THE original draft plan, the
Port of Grays Harbor offered
conservation easements on its 1,-
700 acres of wetlands, west of
Moon Island if it could fill the
Bowerman Basin for Industrial
development.

That plan has met opposition
since its Inception. Environmen-
talists, and fishermen fear that
any filling of the mudflats would
endanger the ecological balance
for fish, birds, crabs and other
creatures that live there. And
Monday, the task force heard
scientific testimony that Grays
Harbor — and specifically, the
Bowerman Basin — seems to be a
crucial staging area for migrating
shorebirds and may be critical to
the survival of. the peregrine fal-
con.

Planners formed a mini-task
force Tuesday to investigate the
feasibility of (he new design and
to determine what the environ-
mental impacts of a westward
extension would be.

The mini-task force is composed
of representatives from the City
of Hoquiam, the Environmental
Protection Agency, the Port of
Grays Harbor, the Army Corps of
Engineers and fish and bird spe-
cialists.

A representative from the Of-
fice of Coastal Zone Management
said the new plan will be assessed
along with the original plan, and
U.S. Fish and Wildlife Service
biologist Rich Howard said he
could render a biologic opinion on
both plans by Feb. 25.

HOWARD HAD testified Mon-
day that Grays Harbor, while an
important wintering ground for
the endangered falcon, was not a
critical habitat, and he said the
original plan to fill Bowerman
Basin would not jeopardize the
bird.

He conceded, however, that fur-
ther study was needed before he
could conclude that the Bower-
man Basin was not crucial to the
falcon's survival.

D-5

Source: DAILY WORLD
Aberdeen, WA 12/10/80

Joe Blum, area manager for the
U.S. Fish and Wildlife Service,
said Tuesday that Howard's testi-
mony had been a "rough" opin-
ion, and that the final opinion
would be ready by Feb. 25.

"If it's a jeopardy opinion, we'll
work with the task force and the
Office of Coastal Zone Manage-
ment to see if planning can go on
in a way that won't impact the
species," Blum said. He assured
the task force that the federal
agency would not compromise its
biologic knowledge and principles
in its evaluation of the plan.

GORDON DAVIS, consultant to
the task force, guided the group
through the exhaustive discus-
sions Tuesday morning that led to
the new plan.

John Clark, a representative of
the Conservation Foundation in
Washington, D.C., initially sug-
gested that the. basin habitat
could be duplicated west of Moon
Island "since Bowerman Basin is
a man-made creation in the first
place."

"I accept the evidence present-
ed yesterday showing that shore-
birds use the basin and that it's a
most valuable habitat," Clark
said, "but I don't accept that it's
the only important staging area
for birds in this area.

"It would appear feasible to use
fill material to extend the basin to
the west (of Moon Island) and
replicate that habitat."

Research should precede such a
move, Clark said, adding that it
would involve the loss of 500 acres
of open. water in the Harbor —
two percent of the available
space. "If it (the basin) is a
major staging area for shore-
birds, people in the community
have a responsibility to establish
a sanctuary in Bowerman Basin,"
Clark said.

CHUCK WALTERS of the Na-
tional Marine Fisheries Service in
Washington, D.C., warned that a
westward reconstruction of the
basin may bring other unforseen
impacts, but he favored consider-
ing alternatives that could lessen
the environmental impact so de-
velopment can proceed.

The task force decided to pro-
ceed with the proposal to extend
the airfield peninsula, rather than
attempting to reconstruct the bas-
in.

It will meet again March 3 and
4 at an undetermined site to
consider the new plan and to work
out other changes in the draft
document.

Source: The Coastal Society, BULLETIN,
Vol.3, No. 2, March 1979

Planning for Predictability

in Grays Harbor Grant Dehart,

Federal Office of
Coastal Zone Management

Editor's Note: Representatives of the Port of Grays Har-
bor and Friends of the Earth will review this article and
provide their views on events in Grays Harbor, includ-
ing the planning process and the plan in the June issue
of the Bulletin.

Over the past three years, the Grays Harbor estuary
in Washington State has been the focus of an innova-
tive planning process which has recently gained broad-
er national attention from coastal managers, environ-
mentalists, port interests and Federal agencies. This
increased attention is due to the potential for such a
process to become a prototype for resolving conflicts
between economic development and environmental
protection needs in specific geographic areas of the
coastal zone.

The process may offer a solution to some common
criticisms of completed state CZM programs, e.g. the

lack of specificity, the need for more long term protec-
tion of specific resource areas, uncertainty for permit
applications and conflicts among government policies.
With the Grays Harbor example in mind, the Federal
Office of Coastal Zone Management has introduced
the concept of "special area management." Whether
the Grays Harbor process and estuary plan becomes a
prototype for this "special area management" concept
or not will probably depend upon what government
officials and influential interest groups think about:

• directly involving State and Federal agencies in
the development of local and regional plans for wet-
lands and shoreland areas.

• committing Federal and State agencies to plan-
ning decisions in advance, to narrow their discretion
on individual permits, thus increasing the predictabil-
ity of the permit process,

• trading off a specific amount of tidal wetlands to
economic development for the long-term preservation
of the vast majority of remaining wetlands in the
estuary.

• mediating environmental disputes among govern-
ment agencies, while keeping citizens in an observer
or advisory role.

The Grays Harbor estuary is one of the largest on the
Pacific Coast, with an area of about 62,500 acres of
tidal marsh and partially developed shoreline. The es-
tuary supports more than 50 species of fish. It is also
the location of six- towns that depend upon the shore-
line for their economic survival, particularly from
ports, timber processing, fishing and recreational
boating. Grays Harbor is the only port with deep water
access on the coast of Washington (outside of Puget
Sound), and is of major significance to the economy of
the region and the State. The 12 mile navigation chan-
nel through the estuary requires annual maintenance
dredging.

The stage was set for the present planning process
when State and Federal offices refused to support fur-
ther applications for dredge and Jill^ projects until an
overall plan for the estuary was agreed upon. This ac-
tion was prompted by a long and bitter controversy
over a 45 acre fill by Kaiser Steel Company, and was
generally supported by the major parties to the
dispute, since they realized that the impasse that
existed was detrimental to all of their interests. A
Grays Harbor Estuary Planning Task Force was estab-
lished with representatives from the county, the muni-
cipalities around the estuary, the Port of Grays Harbor,
four State and four Federal agencies with legal juris-
diction in the Harbor, and the Regional Planning Coun-
cil. After the Washington Coastal Zone Management
plan was approved, Federal CZM funds provided for a
planning study and consultants were hired to act as
technical advisers, planners, and mediators.

The Grays Harbor process appears to have four
major goals, including:

• consensus on a specific 50 year plan for the estu-
ary, among all public agencies with legal jurisdiction
over its use,

,• "predictability" that activities permitted in the

plan will have the general concurrence of all agencies
involved in finalizing permit decisions,

• "balance" between competing needs for economic
development, and protection of natural functions and
areas of the estuary, and

• management of cumulative impacts from incre-
mental dredge and fill decisions.

For more than two years, since September 1976, the
Task Force and its consultants have worked to develop
a. plan that will be acceptable to all parties with legal
responsibility for its implementation. They have also
attempted to involve interest groups and the public in
the plan' development, but have not been successful in
gaining full support of environmental interest groups
that are concerned both with the extent of their in-
volvement and the substantive policies being pro-
posed.

The major compromises that were reached in the
draft plan include:

• The Port of Grays Harbor agreed to abandon its
plan for the development of 2200 acres of submerged
lands along the harbor's northern shore, for assurances
that it could develop 500 acres between the Bowerman
Air Field and the shoreline in Hoquiam over the next
50 years. This amount was split in half, so that only
250 acres would be allowed until the need for the addi-
tional fill is demonstrated and the detailed plans for
the first segment are subjected to special review by
affected agencies. Mo decision was made on the use of
this area after 50 years.

• The remainder of the Port's 2200 acres is to be
transferred to a designated state resource agency for
50 years, to be managed for resource purposes.

• Further major filling of the submerged lands was
limited to bankline straightening or bankline erosion
control in the least naturally productive portions of the
harbor.

D-6

• Long-term policies for relocation of non-water de-
pendent uses along the harbor, such as an airport, was
approved subject to the location of a suitable alterna-
tive site.

The Task Force is now reviewing a revised draft of
the plan. At the same time, environmental interest
groups seem to be organizing opposition to the plan;
the port is seeking support for the plan from Congres-
sional and headquarters Federal officials; EPA is con-
sidering revisions to Section 404(bXl) of the Clean
Water Act that could affect major proposals in the
plan, and the Office of Coastal Zone Management to-
gether with participating Federal agencies, is prepar-
ing a Joint Draft Environmental Statement in anticipa-
tion of formal amendment to Washington's CZM pro-
gram.

With some of the most controversial issues yet to be
resolved, some agencies have begun to question
whether such a process actually saves time. Others
maintain that the controversial issues would be raised
in the permit process in any case, and they should be
dealt with in advance through the plan and NEPA pro-
cess.

The procedural issues include:

• The adequacy of citizen and interest group in-
volvement in the plan formulation.

• The extent to which agencies are committed to
major decisions (as a result of the consensus process)
in advance of open consideration of alternatives under
NEPA.

• How the formal review, EIS and approval process
can be coordinated with so many layers of government
decisions involved, (e.g. local plan amendments, state
Shoreline Management Act approvals. Federal agency
approvals, and amendment to the Washington CZM
program).

• How much discretion over subsequent permit
applications is being surrendered by Federal and State
agencies that approve the plan ... for the sake of pre-
dictability.

• Whether the 404(bXl) guidelines, requiring con-
sideration of alternative disposal sites can be met
through such a planning process without full review
of alternatives for each permit application.

• Whether an approved long-range plan will prevent
further unplanned losses of wetlands due to political
intervention.

• Whether making the plan legally or formally bind-
ing on participating agencies will inhibit their coopera-
tion in future planning efforts.

Several substantive issues of significance beyond
Grays Harbor are also likely to be raised about the pro-
posed plan, including:

• Whether a proposed 250 acre fill for Port develop-
ment can be authorized in advance of a permit applica-
tion specifying the use; or at all, given the President's
executive order on wetlands,

• whether non-water dependent uses that are ancil-
lary to primary port functions should be sufficient jus-
tification for filling wetlands,

• whether long-term preservation of existing wet-
lands is a sufficient trade-off for filling, without an
acre-for-acre replacement with new wetlands to miti-
gate the loss,

• the adequacy of environmental data available to
the Task Force, upon which consensus decisions were
based, and

• the adequacy of an estuary planning boundary that
does not include the entire watershed. (The Grays Har-
bor planning boundary was limited to the Section 404,
and Shoreline Management areas).

During the remainder of the planning and review
process each of these issues and many others will be
debated at all levels of government, before a final plan
is approved.

Hopefully, this article and those that follow will help
keep the debate on a constructive track.

Throughout the country environmental programs
are under attack for being inflationary, unpredictable
and inequitable. At the same time, national polls of
environmental values, and state referenda on coastal
and land use programs show sustained public support
for the basic goals of these programs. The challenge
for coastal zone management is how to improve the
implementation of management policies before pro-
grams are dismantled, or the permit processes are cir-
cumvented by political intervention on a large scale.

Grays Harbor, prior to this planning process, repre-
sented only one example where ad-hoc, agency-by-
agency review of development proposals can lead to
highly-charged conflict situations in which govern-
ment, interest groups and the environment end up
losers. Similar cases can be found throughout the
coastal zone at any time.

The Grays Harbor planning process represents a
positive attempt to improve this situation, but the con-
troversy is not over. Government agencies will worry
about the potential loss of nearly unlimited discretion
over individual projects; environmental interests may
challenge the resolution of disputes that are less-than-
perfect in terms of protection, and development inter-
ests may balk if some of the concessions to economic
development are reconsidered or if predictability is not
maximized.

There are other prototypes for "special area man-
agement," such as The San Francisco Bay Plan, The
Plans for Yaquina Bay and the Lower Willamette River
in Oregon, and the Joint Processing of Permits in the
Corp's Norfolk, Va. District, and other solutions to the
permitting maze, besides the Grays Harbor process.
But there are a lot of positive aspects about this pro-
cess that should not be discarded prematurely in the
rush to protect parochial interests.

Coastal News

D"7 MARCH 1979

JULY 1979

Source: The Coastal Society BULLETIN
Vol.4, No. 4, July 1979

Coastal News

Planning for Predictability in
Gray 's Harbor: Part II

Editor's Mote: In the March, 1979 Bulletin, we pub-
lished an article by Grant Dehart describing the goals
and process of planning for predictability in Gray's
Harbor. Some of the principals involved have different
views on these planning activities. The articles below
were prepared by representatives of two groups that
have been actively involved in Gray's Harbor.

The Case for Planning Pat Dugan

Executive Director
Grays Harbor Regional Planning Commission

A previous article in this journal (March 1979) dis-
cussed a planning process now taking place relating to
the future management of the Grays Harbor Estuary on
the Pacific Coast of Washington State. That article
addressed many of the specific issues which confront
that process and by so doing illustrates the complexity
that arises in such an effort. It is not the intent of this
responding article to debate those issues in the limited
forum provided here. Such a debate, which involves
many issues unique to the Grays Harbor system, would
have little practical benefit to the readers. Far more
important to the management of coastal areas
throughout the nation is a need to accent and clarify
the very fundamental reason to undertake this type of
planning effort. When the process began, it was as-
sumed that "planning" was a commonly held concept
among all the various regulatory agencies ancfinterest
groups involved in the management of coastal areas.
Our experience has suggested that this may not always
be the case. The purpose of this article, then, is to pre-
sent our case for "planning" an estuary. That purpose
must first be accepted before any resolution to the
many issues confronting estuarine protection and
development can be addressed.

The first concept that must be clarified in such a dis-
cussion is what planning is understood to be. For the
purposes here it is intended to mean, as an end prod-
uct, the allocation of space for various uses and activi-
ties (including preservation) within an area. Since the
desirability of allocating space to a particular use or
activity in a given subarea will inherently depend on
how the use or activity is undertaken, planning also in-
volved developing policies and conditions relating to
particular subareas or particular uses and activities.
This concept of planning involves a policy commit-
ment to allow the uses and activities specified in the
plan if the appropriate conditions are met (and hence
the concept of "predictability" addressed in the earlier
article). "Planning" here is not intended to be, as it
often is in discussions relating to resource manage-
ment, a euphemism for regulating.

The Grays Harbor process grew out of a long history
of frustration among various state, federal, and local
agencies regarding the existing permit system for
managing the estuary and its basic deficiencies. The
current system of managing estuarine environments
usually consists of case by case decision making,
utilizing uncoordinated regulations and other manage-
ment programs by various agencies which exercise
authority in matters affecting the resource. Since these
regulations and programs are frequently developed
independent of each other (especially between various
levels of government), this situation creates a strong
potential for these public agencies to pursue goals and
objectives which may or may not be related to one
another and which have high potential for conflict
between them. It also creates uncertainty regarding
the outcome of any project proposal in the estuary
area and continues the lengthy permit processes now
needed to resolve issues arising out of inconsistent
programs of various agencies. Thus, the lack of a coor-
dinated public policy among the many state, federal,
and local agencies causes confusion, and frustrates
both people seeking permission for various actions
and those who are attempting to regulate those activi-
ties for the public good.

One of the major drawbacks of the current system is
that its ultimate, or cumulative, impact on the environ-
mental quality or ecological productivity cannot be
anticipated. This problem is caused by several factors.

First, the current system is oriented toward a case by
case review of individual projects as they come up.
Consequently, the ultimate impact will depend on
which projects are proposed and when, and how effec-
tively each may be advanced and presented in the
regulatory and political processes. Second, the exist-
ing policy framework under which the individual pro-
jects are judged in each agency tend to be general and
subject to a wide range of interpretations. Third, the
specific standards or criteria for development may
vary from agency to agency depending on their basic
sense of purpose. For example, a fishery agency would
develop standards directed toward the fishery, a game
agency may develop criteria primarily directed toward
avian fauna, a city may base its standards on a priority
need to remove urban blight, and a port may develop
its program on a need to create jobs. These purposes
may conflict on any given permit issue in a way which
makes the outcome uncertain.

The problem of predicting the ultimate effect of
individual permit decisions under current manage-
ment systems poses a serious and potentially long
range adverse environmental problem. An estuary is a
complex and potentially fragile system. Any one pro-
ject by itself, if carefully designed and cited, may be
acceptable but many such projects may pose a serious
threat to the overall system. Also, an acceptable pro-
ject in present conditions may become unacceptable
due to the way the resource may be impacted by future
projects. These problems of how a particular project
may relate to future projects and future environmental
conditions is often referred to as the cumulative effect.
Because the case by case approach cannot anticipate

D-8

JGLY 1979

these future problems or conditions, it cannot evaluate
cumulative effects of permit decisions.

An additional problem in the existing system is its
ability to consider alternatives. While the present sys-
tem attempts to address concerns regarding the "best"
or most suitable alternative for a particular use or
activity, it does this very inefficiently. Since the cur-
rent system responds to specific proposals, it only
comes into effect after a proposal is developed, a site
selected, ownership questions resolved, and some in-
vestments made. These commitments limit the ability
to enforce a meaningful alternative analysis. Further-
more, due to potential differences between the various
management programs of each reviewing agency and
the manner in which the programs are administered, a
prospective developer has little guidance as to where
his efforts might best be directed. Since the ability to
evaluate and influence alternatives is limited, greater
environmental damage might occur due to the "best"
or "least damaging" site for a particular project not
being selected and an "acceptable" but less appro-
priate or desirable site approved. This problem can be-
come very serious when combined with the cumulative
effect of many projects.

While the present system poses these problems for
ensuring adequate protection of the natural resources,
it also creates potential problems for being able to
meet the socioeconomic needs of the affected com-
munity.

Just as case by case decision making makes it im-
possible to evaluate cumulative environmental im-
pacts, case by case decisions also prevent evaluation
of the cumulative effects of permit decisions on econo-
mic conditions and needs. While one project denial
may not be critical to the economy the cumulative
effects of permit denials may be very damaging. The
present system provides no means by which future
needs can be evaluated with the permit under con-
sideration.

The present system is also unlikely to be able to
achieve the most optimum balance between environ-
mental and economic needs. Since the case by case re-
view system cannot effectively direct development
proposals to the area of least environmental impact,
the cumulative effect of individual permit decisions
could result in a lower level of economic opportunity
for a given level of environmental losses than if it were
possible to direct development proposals in advance
to the site most capable of accommodating the use. By
not optimizing the ratio of economic opportunity to
environmental costs, the resulting balance would be
lower than that which could be achieved. In other
words, the present system has no way of knowing
whether it is allocating efficiently whatever level of
development the system may be ecologically capable
of accepting.

In Grays Harbor the present system led to many long
and drawn out permit battles between local develop-
ment interests and state and federal resource agencies.
In these battles both sides were frustrated. Developers
were frustrated by not knowing what was expected
from agencies charged with managing the system.

Agencies were frustrated by a feeling that issues were
being decided on factors which did not adequately
address resource needs. Virtually every permit ques-
tion ended up in the "political trenches," as the local
vernacular puts it.

In the middle of one of these bitter controversies in
1975, Senator Henry M. Jackson (Washington) urged
the various agencies charged with either regulating or
developing the estuary to get together and resolve
their differences in a planning process. A process was
established under the auspices of the Grays Harbor
Regional Planning Commission (an association of
local governments similar to a Council of Govern-
ments in many states). Since the process was to re-
solve differences between established management
programs, the Planning Commission formed a task
force of the various state, federal, and local agencies
involved to conduct this program. The process then set
out to develop an alternative approach to managing an
estuary. This approach would consider, in a long range
and comprehensive manner, what is needed to protect
the natural productive capacity of the system, and
what would be needed for the system to perform its
economic functions, along with many other roles the
estuary plays. This approach, then, would result in a
"plan" which addresses the many competing demands
on the estuary in the form of policies and use designa-
tions. While it was understood that such a plan could
not replace the existing permit authorities, it was ex-
pected that it would guide decision making under
those authorities in much the same way that city com-
prehensive plans guide zoning decisions. By address-
ing long term issues, needs and impacts, this approach
could correct the deficiencies in the present system.

Once it is decided to undertake such planning, it is
then necessary to identify the overall objective of such
planning. The Grays Harbor process addressed this
question as one of its earliest policy issues. It was de-
cided that the goal of the task force was to manage the
system for multiple use. This rather innocuous sound-
ing goal is one of the most significant decisions in the
process, since it recognizes that there is a range of
legitimate uses that should be accommodated and bal-
anced, and that management cannot only be directed
toward special purposes. It was at this juncture that the
process departs from the existing system of each
agency developing and administering a management
program directed at its own special purpose.

This recognition drastically compounds the prob-
lems associated with the planning process. As Richard
Babcock observed in "Babcock's Law," "any benefi-
cient public policy if pursued vigorously will inevitably
conflict with an equally beneficient public policy."1
The decision to recognize multiple use in an estuarine
system inherently recognizes the existence of more
than one legitimate public policy which will be pur-
sued vigorously by various interests, and, hence, by
Babcock's Law, conflict. If the Grays Harbor process
has demonstrated anything; it is that Babcock is right.
Planning for special purposes is relatively easy. One
can protect an ecological system with a high degree of
certainty (but not complete) by drawing a line around

D-9

JULY 1979

the system and prohibiting any further modification
within that area. Similarly, very effective economic
development plans can be readily formulated if one is
not constrained by limits on estuarine modification. It
is when both of these objectives are pursued vigor-
ously that planning becomes difficult.

In the previous article Grant Dehart said, "The chal-
lenge for coastal zone management is how to improve
the implementation of management policies before
programs are dismantled or the permit processes are
circumvented by political intervention on a large
scale." Only through effective, balanced planning can
this challenge be met. Whether such planning will be
successful will depend upon whether each agency
charged with management or development of coastal
areas will be able to overcome a natural ingrained
reluctance to balance the narrow purpose of that
agency with other public purposes and needs. As long
as any agency seeks to retain its unilateral discretion
in such matters, continued conflict is inevitable. The
Grays Harbor process represents a potential prototype
process for such a balance to be achieved. It is time to
move the question of balance from political rhetoric to
actual public policy.

'Richard Babcock "Regulating Land Development: Some
Thought on the Role of Government," Land Use: Tough Choices in
Today's World, Special Publication No. 22, Soil Conservation
Society of America, Ankeny,.lowa, 1977, page 35.

Grays Harbor and Coastal Zone
Management — What Went Wrong?

David E. Ortman

Conservation Representative

Northwest Friends of the Earth

Whether or not the Grays Harbor estuary planning
effort in the State of Washington will become a "proto-
type" for resolving conflicts between economic devel-
opment and environmental protection needs in coastal
zone areas will depend a great deal on the Office of
Coastal Zone Management (OCZM) itself. Much of the
controversy outlined by Grant Dehart in the March
issue of the Bulletin is self-generated and a result of
OCZM's own ineptness. Friends of the Earth has fol-
lowed events in Grays Harbor for almost a decade. We
are pleased to respond to the issue raised by OCZM.

Directly involving state and federal agencies in the
development of local and regional plans for wetlands
and shoreland areas is a commendable goal. Efforts
should be made, however, to insure that all major
interests are involved. For example, the Federal Avia-
tion Administration was not part of the Grays Harbor
Estuary Task Force even though there are three air-
ports in the planning area.

Committing federal and state agencies to planning
decisions in advance is not an acceptable goal without
strong guidelines and application of the Clean Air Act
and Federal Water Pollution Control Act requirements.
The draft Grays Harbor estuary plan was developed
without taking into consideration these already exist-

ing constraints. Much like a builder constructing a
home without referring to the building codes, the exist-
ing plan is clearly in violation of the FWPCA require-
ments and the President's Wetlands Order.

The purpose of the Coastal Zone Management (CZM)
Act is (a) to presewe, protect, develop and where pos-
sible to restore or enhance the resources of the nations
coastal zone. From 1940 to 1975 nearly 4,000 acres of
intertidal land in Grays Harbor, one of the few major
estuaries on the entire West Coast, had been utilized
for disposal of dredged material. Trading off additional
amounts of tidal wetlands to economic development
for the long-term preservation of the remaining wet-
lands in the estuary is acceptable only under the fol-
lowing conditions, neither of which are met by the
draft plan. The first is the level of protection. If nothing
else, CZM planning has illustrated the lack of mechan-
isms, tools and programs available to protect critical
wetland areas. No sanctuaries or wildlife refuges or
non-dumping areas are proposed. The only "protec-
tion" offered other parts of the harbor (besides Man-
agement Unit 13) is zoning which is reviewable every
five years. The second condition is an adequate test of
what constitutes economic development. After a
breach of faith on a major wetland permit in Grays Har-
bor in 1976, when the G.S. Army Corps of Engineers
issued a 404 permit for a 45 acre fill which destroyed
13% of the harbor's existing sedge marsh, the conser-
vation community in Washington felt that CZM plan-
ning would be a positive effort. The permit was issued,
not jointly to Kaiser Steel (who proposed building off-
shore oil-drilling rigs) and the Port as the Corps EIS
stated, but to the Port alone, despite the fact that no
need for such rigs was ever shown. This has resulted in
an abandoned site (Kaiser released their option on the
site this spring) devoid of biological productivity. No
longer should Ports be able to claim "economic devel-
opment" with contracts in hand before a permit is
given.

The Wynoochee Dam on the Wynoochee River near
Grays Harbor above Aberdeen, Washington, provides a
perfect example. This project was built in the sixties to
provide an industrial water supply with the expectation
that industrial customers would arrive to use the water
and more importantly to pay for it. But the industry
never arrived and the citizens of Aberdeen, the local
sponsors, were faced with a million dollars a year re-
payment before the Representative from the district
obtained a 10 year moratorium until 1983. First the
government provides speculative water, then we are
asked to provide speculative land. A Port Systems
Study for Grays Harbor shows that much of its exports
are in wood products and that much of this export
capacity even with expansion lies unutilized. Where is
the need for additional wetland fills?

Mediating environmental disputes among govern-
ment agencies, while keeping citizens in an observer
role is contrary to the policies of the Coastal Zone Man-
agement Act which calls for participation by the public
in developing CZM programs. The Federal Office of
Coastal Zone Management, the State Department of
Ecology and the Estuary Task Force have deliberately

D-10

JULY 1979

worked to exclude public participation. This policy is
also being used in CZM planning in Minnesota, where
citizens have gone on record protesting being locked
out of the decision making.

Commenting on the major compromises listed, the
agreement apparently reached for Management Area
13, the conditions placed on filling 500 acres of the
Bowerman Basin for non-specific, non-water depen-
dent uses are inadequate and clearly in violation of the
404(bXl) guidelines. The Bowerman Basin, as one of
the most biologically productive areas in the inner har-
bor and a critical area for shorebirds and waterfowl,
has been proposed to the U.S. Fish & Wildlife Service
for acquisition under their Unique Wildlife Ecosystem
program. This report was unavailable at the time the
draft estuary plan was released. To destroy an area of
known biological importance for unknown non-water
dependent development, flies in the face of every
major wetland and wildlife protection policy this na-
tion has developed.

The area the Port wishes to fill is an area currently
designated Conservancy under the Grays Harbor
Shoreline Master Program (developed under the State
Shorelines Management Act). Transfer to a state
agency of the remaining Port area is controversial and
can be criticized on a number of grounds. Lance D.
Wood and John R. Hill, both from the U.S. Army Corps
of Engineers, in the Coastal Zone Management Journal,
point out that ". . . any 'trade' of public control of some
lands in return for a permit to dredge or fill in other
wetlands must be conducted very carefully, since
some wetland areas are much more valuable to the
public than others are . . . the real value of a devel-
oper's 'committing wetlands to the public' can be ques-
tioned. If a developer buys legal title to wetlands and
transfers title to a state or local government, or to a
conservation organization like the Nature
Conservancy, the transfer of title in itself would not
necessarily safeguard the wetlands for long . . . state or
local government that receives title to 'mitigation wet-
lands' might later develop those wetlands."1

Bankline straightening or bankline erosion control
should not be permitted outside designated develop-
ment areas. This type of conditional use, which per-
meates the plan, is simply one more instance of wet-
land alteration allowed in the estuary for unspecific
purposes.

We note that at least in the draft plan, the relocation
of Bowerman Airport, which borders the navigation
channel, is a definite feature of the plan. OCZM and the
Task Force appear to be backing out of this commit-
ment. We continue to believe that relocation of Bower-
man Airport, a Port owned and operated operation
which lost the Port nearly $45,000 last year, would pro-
vide them with adequate land for water-dependent
uses. If the airport is not relocated, then that to us is
an indication that the Port feels safer with a losing
proposition than with risking their best location in the
hopes of attracting water dependent users.

The procedural issues are again indicative of the un-
imaginative approach OCZM has taken to the planning
process. There is no question that citizen and interest

group involvement in the plan formulation was and re-
mains inadequate. There has been no attempt made by
the Estuary Task Force to keep in contact with citizen
groups. Citizens who did attend Task Force meet-
ings were specifically told their input was not wel-
come. Citizen involvement is so basic to the success of
CZM planning that unless immediate changes are seen
in OCZM's attitude, legal challenges could tie up such
plans for years. For OCZM to suggest that NEPA can
be circumvented by agreement of federal, state and
local agencies to decision making without the NEPA
process will again subject OCZM to long and costly liti-
gation. OCZM has made a mountain out of a molehill
by their refusal to integrate MEPA, the FWPCA and
CZMA.

An EIS should have accompanied the draft plan for
the "special management area." Designations could
have been made between areas for development and
areas for protection, based on the FWPCA and specifi-
cally the 404(bXl) guidelines. Then when a specific
proposal comes up, a site specific EIS would be written
to examine the environmental impacts and the alterna-
tives available. This process assures some degree of
predictability, while at the same time making clear
that designation of an area as Urban or Urban Develop-
ment does not mean a blank check to fill for any use
that comes along. The latter is a principle clearly
stated in the existing Grays Harbor Shoreline Master
Program.

Therefore, no discretion would be surrendered by
federal or state agencies over subsequent permit appli-
cations, rather a process is set up that allows a clearer
understanding of what the federal and state require-
ments are, which must first be met, and in what areas
the permitted uses might be assigned.

The substitution by OCZM of Estuary Planning for
full review of alternatives for each permit application
under the 404(bXl) guidelines is bad policy and con-
trary to Sec. 307(f) of the CZM Act which expressly
states that the FWPCA requirements "shall be the
water pollution control . . . requirements applicable to
such program." OCZM's continued attempts to under-
mine the FWPCA is the single largest obstacle to resolu-
tion of a Grays Harbor Plan. It is clear that the 404
guidelines are not met by the current Plan. Rather than
pressuring EPA to rewrite the guidelines to suit OCZM,
OCZM should adopt the above model and give EPA
every cooperation to strengthen the 404(bXl) guide-
lines to assure that our nation's wetlands do not suffer
further from unwise dredge and fill activities.

The U.S. Army Corps of Engineers, and in our view
rightly so, has refused to "formally adopt" the plan and
has maintained that they will continue to carry out all
their legal obligations of permit review. This is most
important since the Corps regulations outline in detail
the evaluation process on a site specific basis that
must be carried out before a 404 permit is issued.
These regulations state that the evaluation of every ap-
plication must consider "the probable impact of each
proposal in relation to the cumulative effect created by
other existing and anticipated structure or work in the
general area . . . the particular wetland site for which

D-ll

an application is made will be evaluated with the rec-
ognition that it is part of a complete and interrelated
wetland area." The Corps must also consult with other
federal and state agencies to "assess the cumulative
effect of activities in such areas." Furthermore, the
Corps can condition permits to mitigate damage done,
a feature excluded from the draft plan. If the Port of
Grays Harbor can succeed in obtaining 500 acres of
wetlands for non-water dependent uses, what will coas-
tal zone planning bring us in Louisiana, New Jersey or
Alaska?

It is our belief that a long range plan, with the proper
constraints would tend to prevent further unplanned
losses of wetlands due to political intervention. The
current plan does not meet this test. Non-water depen-
dent uses are not sufficient justification for filling wet-
lands. The city of Aberdeen recently pushed through a
wetland permit for a restaurant, motel and parking lot.
In the face of such ill-conceived planning for wetland
uses, it is impossible to believe that further wetland
losses for true water dependent uses would not take
place. The proposed immediate filling of 250 acres for
Port development cannot be authorized in advance of a
permit application specifying the use and we will
oppose such a policy in this and any subsequent CZM
plan.

The adequacy of environmental data is not an issue.
The question at hand is whether that data was ade-
quately used in the decision making. There is ample
evidence that it was not, especially as it concerns the
Bowerman Basin. A more fundamental issue here is
whether or not resource agencies, without citizen help
and support, can adequately protect the public inter-
est.

Finally, the limitation of the estuary planning boun-
dary is a critical shortcoming. Without inclusion of the
entire watershed, the estuary as an ecosystem cannot
be considered. CZM planning can succeed, but only if
OCZM exhibits an interest in the purposes of the CZM
Act to preserve the land and water resources of the
coastal zone in administrating its program. We cannot
afford to sacrifice existing wetland policy to specula-
tive port development in the name of CZM planning.

■Vol. 4, No. 4, 1978.

D-12

THE SEARCH FOR PREDICTABILITY - Planning and Conflict
Resolution In Gray Harbor, Washington, Chapter 3:
"Impetus For Task Force Formation," Washington Sea Grant
Technical Report WSG 80-5, October 1980.

3

IMPETUS FOR
TASK FORGE
FORMATION

A number of factors provided the impetus for the development of
an estuary-wide management plan in Grays Harbor. First of all, the
geographic, socioeconomic, and governmental characteristics of Grays
Harbor made it a prime candidate for successful regional planning.
Secondly, Grays Harbor already had a tradition of interagency
planning before the Task Force was formed. Thirdly, the navigation
channel maintenance project and the potential channel improvement
project result in dredged materials that could be used as free fill
material to create usable development land in wetland and intertidal
areas. The Port of Grays Harbor, in particular, wanted a plan that
would specify sites to receive dredged material. Finally, the
existing estuary management framework was inadequate and a groat
deal of frustration was engendered by attempts to manage development
and conservation in the estuary using the existing procedures.
Several key disputes erupted as a result of this inadequacy and
served as catalysts to plan development. The following discussion
examines in more detail these four factors which gave impetus to the
planning effort.

Regional Homogeneity Conducive to Planning

The geographic, socioeconomic, and governmental characteristics
of Grays Harbor predispose it to successful regional planning.
Although there are numberous cities and towns with special interests,
there is considerable homogeneity in the region, which distinguishes
it from a number of other areas facing similar management problems.
The entire estuary lies within a single' county; there is only one
port district, and its jurisdiction is countywide; and the regional
economy is predominantly dependent on a single resource- -timber. As
stated in chapter 2, about 90 percent of the land in the county is
committed to timber -related industries. Also, the Port of Grays
Harbor uses its shipping facilities almost exclusively for the export
of timber- related products.

This homogeneity should simplify comprehensive regional planning.
Fewer actors are involved, and there is no competition among
different port authorities or multiple county governments, as is the
case in many other estuarine regions. For example, San Franscisco Bay
and Puget Sound contain numerous cities, counties, and port
authorities, and support a highly diverse set of uses. Estuary
planning in these areas would be significantly more complex than in
Grays Harbor.

Interagency Planning Tradition

Regional interagency planning activities are not new to Grays
Harbor. Regional planning has been conducted under the auspices of
the Grays Harbor Regional Planning Commission (GHRPC) and the Army
Corps of Engineers (COE) . Because of the frequent use of inter-
agency planning in the last two decades, a tradition had developed
which was followed when a new set of problems arose in the estuary
in 1974 and 1975.

The GHRPC was formed in 1960 as a result of the Washington State
Planning Enabling Act (RCW 36.80). The Commission is funded from state
and federal sources and functions as a clearinghouse for social,
economic, and environmental information. The GHRPC uses this infor-
mation to facilitate a regional approach to water supply, solid-
waste management, transportation, comprehensive zoning, and economic
development in general. Although the GHRPC has no official authority

D-13

to make development decisions, it has demonstrated its ability to
influence county and municipal policies and decision making through
data organization and directed studies.

In the early 1960s, Grays Harbor County became the first county
in the state to formulate a countywide comprehensive zoning plan.
The GHRPC played a primary role in establishing this plan and
provided support for municipally generated zoning ordinances. Also
beginning in the 1960s, the GHRPC initiated a series of Overall
Economic Development Program publications as an element of regional
comprehensive planning. The fifth edition was completed in June 1979
(GHRPC, 1979). Supported by federal redevelopment funds, each
edition functions as a review of current regional economic conditions
and focuses on the formulation of particular development goals
intended to further economic diversification, resource development,
and environmental improvement. An economic development committee,
with regional membership, guides the creation of economic development
goals and objectives.

In the early 1970s, the GHRPC took the initiative to develop
the first county-wide Shoreline Master Program (SMP) in the state.
The SMP was developed with the cooperation of local governments in the
region, who subsequently used the county's plan as a model in the
development of city SMP's.

The COE has been a primary influence in the development of Grays
Harbor, and was an early advocate of interagency environmental
planning for the estuary. Beginning in the late 1960s and
increasing in intensity in the early 1970s, uncertainty over the
environmental effects of maintenance dredging and the disposal of
dredged material in Grays Harbor developed among public groups and
resource management agencies.

The first overture for interagency collaboration" in the COEi's
long-range maintenance dredging planning program came in 1968. In
addition to the COE as project sponsor, participating agencies were:
the U. S. Fish and Wildlife Service fUSFWS"); Bureau of Commercial
Fisheries (predecessor of the National Marine Fisheries Service);
Federal Water Pollution Control Administration (predecessor of the
Environmental Protection Agency) ; Washington State Departments of
Fisheries, Game, and Natural Resources; and the Washington Water
Pollution Control Commission (predecessor of the Department of Ecology)
The product of this mutual planning effort was an agreement stipulating
the scheduling of dredging in the upper harbor to avoid seasonal low
river flow conditions when dredging would cause water quality
degradation.

In 1972, with the strong support of the state, the COE gathered
a similar cast of participants to plan the conduct of maintenance
dredging in the estuary. The federal agencies reached an agreement
but, in recognition of recent federal and state legislation increasing
the role of state and local governments in shoreline planning and
developments, they decided to include these entities in the lonu-
range planning program. In June 1975, a conference of federal, state,
and local representatives revealed significant questions and different
points of view about the development requirements of the Grays Harbor
region and the future health of estuarine resources. Pending
resolution of these differences, the federal agency agreement was
accepted as an interim program by state and local entities. A
technical study was instituted to produce an adequate environmental
data base for effective long-range planning.

When the technical study was completed early in 1977, the COE
asked federal and state resource management agencies, the Port of
Crays Harbor, and the GHRPC to participate in formulating an

D-H

estuary-wide, aquatic-area dredging plan. As explicitly stated
at the outset, planning was to be within the framework of existing
federal, state, and local policies, laws, and regulations. Particular
emphasis was placed on integrating guidelines controlling dredge
and fill activities with state and local shoreline-use laws and
programs (Weinmann § Malek, 1978) . Although a long-range plan has
not yet been published or submitted for general public review, the
program proposes a flexible system for mutual decision making
among regulatory, management, and development entities. Thus, the
(PP. played an important role in establishing interagency collaboration
as a workable planning format in Grays Harbor.

Opportunity to Specify Fill Sites

In 1971, the Washington State Shoreline Management Act (SJ^IA)
required local governments to create Shoreline Master Programs (see
appendix). In the Grays Harbor County SMP, 2,100 acres (840 ha) of
Port-owned tidelands and wetlands are specifically designated as
conservancy areas. This designation would prevent these wetlands
from being filled and thus preclude industrial and commercial
development. Why this program, which severely limits development,
was approved by the state without Port objection cannot be fully
answered. The program may have been approved because (1) it was the
first local program in the state scheduled to receive approval by the
Washington Department of Ecology (WDOE) , and thus a certain degree of
inexperience prevailed; and (2) the conservancy designation was,
under certain conditions, allowed to accommodate some kinds of
development.

It may be that Port officials did not strenuously object to the
restrictive plan because they u-crc confident that, with Congressional
approval of the improved navigation channel, conditional approval of
filling and developing the tidelands could be obtained. The Port
is responsible for providing disposal sites to receive volumes of
dredged material resulting from maintenance of the present channel
project. Based on its comprehensive plan (see p. 10), the Port could
present a well -substantiated case for creating industrial and
commercial development sites. Such development would provide the
local economy with a needed boost, and thus the local and state
political pressures would seemingly be directed to grant conditional
approval for filling the tidelands.

The combination of the Port's responsibility for providing
dredged material sites, the annual availability of dredged material,
the scarcity of usable flat land surrounding the estuary, and the
fact that the Port owns a great deal of potentially usable tideland
served as strong stimuli for active Port support for development of
an estuary-wide comprehensive plan. Such a plan could predesignate
sites to receive fill for creation of industrial sites, and the Port
could be assured that filling of. at least some of its tideland
holdings would be allowed.

Inadequacy of Existing Management Framework

As shown above, Grays Harbor has had an extensive planning and
management framework for some years. A detailed discussion of the
existing local and state coastal management programs, state environ-
mental legislation and regulatory agencies, and federal environmental
legislation and implementing agencies is provided in the appendix.
This complex web of decision-making authorities, with overlapping
project review responsibilities and sometimes conflicting review
standards, created an atmosphere of confusion and frustration in

DHL 5

Grays Harbor prior to the initiation of the Grays Harbor Estuary
Management Program and was a primary impetus for the formation of
the Task Force.

Resource management and protection agencies, such as the state
and federal agencies responsible for fish and game, play a primary
role in review of development proposals. These agencies exercise
permit review powers over development proposals to ensure the
long-term environmental health of the estuary. Although these
agencies often articulated contrasting perspectives and cited
differing legislative mandates, they were in general agreement that
(1) ecological and resource values must be preserved and protected
for the future; (2) the amount of development the estuary could
absorb while retaining its environmental viability is unknown,
but limited; and (3) case-by-case permit review results in un-
certainty over the cumulative effect of development and risks piece-
meal disruption of estuarine resource properties. Technically, it
is difficult for resource management personnel to document the
ecological importance of the loss of a particular expanse of salt
marsh at a particular point in time. Yet; their knowledge of
estuarine ecology and their observations of changes over time in
the estuary led them to conclude that incremental shoreline
development activities were leading to significant adverse environ-
mental effects in Grays Harbor.

Economic interests in the estuary want timely and predictable
responses from government agencies to project proposals. Aquatic
and wetland areas owned by development interests are valuable
industrial and commercial property. Without the addition of fill
or elevation of aquatic margins to upland grades, tideland owners
may not obtain the full commerical value of their property. Whenever
resource agencies impose limitations on the use of private land, and
these limitations are unaccompanied by specific, technical criteria
and are supported only as a protection of valuable natural resources,
frustrated opposition ensues. Resource agencies maintain that the
benefits from preservation and conservation are in the long-term
public interest. In contrast, development interests maintain
that the cost is not borne by the public when aquatic areas and tide-
lands cannot be developed. In effect, advocates of economic develop-
ment agree that adhering to agency restrictions leaves them with an
uncertain future, property with decreased commercial value, and
violated personal property rights.

Local governments in Grays Harbor, although not always directly
involved as project sponsors, began to feel that state and federal
decision-making policies were interfering with their efforts to
diversify and stabilize the regional economy. They considered the
legislative concepts and administrative frameworks required by state
and federal law to be time consuming and cumbersome. Private
interests and local governments felt that their efforts as advocates
of regional benefit through the use of estuarine resources were
being subjected to highly generalized, and often arbitrary, decision
criteria for the benefit of state and national interests at the
expense of the residents of Grays Harbor.

Given these conflicting interests, disputes over the regional
benefits to be gained from industrial development versus the
potential environmental disturbance resulting from physical
development activities were inevitable. The disputes were intense and
resulted in a great deal of tension between development and
conservation interests, and among public management agencies with
regulatory responsibilities. The cities and the Port were the prime

D-16

local actors concerned with the development projects. State agencies
involved in the disputes were the Washington Departments of Ecology,
Fisheries, Game, and Natural Resources (WDOE, WDF, WDG, and WDNR), and
the federal agencies involved were the COE, the Environmental
Protection Agency (EPA) , the U. S. Fish and Wildlife Service (USFWS),
and the National Marine Fisheries Service (NMFS) . Several key disputes
are presented here to illustrate the conflict and the frustrating
process of project review.

Key Disputes in Grays Harbor

Three key disputes between development interests and resource
management and protection agencies in Grays Harbor were sufficient
to catalyze demands for comprehensive environmental planning in the
estuary. The first example demonstrates local and state coordination
difficulties, while the latter two instances illustrate the inter-
action of development interests with all levels of government with
decision-making authority in Grays Harbor.

Thtuiderbird Motel proposal The City of Aberdeen submitted a draft
SMP to the Washington Department of Ecology (WDOE) in June 1974.
WDOE had not evaluated or approved Aberdeen's SMP when the city
received and approved a substantial development permit application
for construction of a Thunderbird motel, restaurant, and marina
complex along 1,200 feet (372 m) of shoreline near the confluence
of the Chehalis and Wishkah Rivers in the eastern reaches of Grays
Harbor (see fig. 2). Aberdeen determined that the project proposal,
situated on a vacant site formerly occupied by a wood-products

*** i'i'y.1* ' •'«*V>j *£?;"'■

HUMPTULIPS
RIVER

UPSTREAM CONTINUATION OF CHEHAUS RIVER

Figure 2 Sites of key permit-issue disputes

D-17

facility and owned by the Port of Grays Harbor, was a reasonable
and appropriate use and that project plans would generally enhance
the area and benefit the public. Ihe site was designated as "urban"
in Aberdeen's draft SMP and adjoined an upland area zoned "commercial,"
which permitted commercial and light industrial activities.

In accordance with the SMA, the approved substantial development
permit was forwarded to WDOE for review. WDOE did not concur with
local approval, noting that the proposal was not in consonance with
sections of Aberdeen's draft SMP dealing with restoration, public
access, and development policies relating to water dependency.
Further, WDOE determined that, in compliance with the provisions of
the State Environmental Protection Act (SEPA) , an environmental
impact statement must accompany the proposal. Neither Aberdeen
nor the project sponsor had prepared an EIS or the alternative, a
statement of negative impact.

After WDOE rejected the proposal, development sponsors appealed
to the judgement of the Shoreline Hearings Board (SHB #162, 1978).
The state board concluded that the appellants did not comply with
the SEPA guidelines and that this alone mandated WDOE's remand of the
matter for reevaluation. The board made additional comments, noting
that (1) although the project generally incorporated the provisions
of the SMA regarding substantial development permits, the proposal
did not closely follow the development policies stated in Aberdeen's -
draft SMP; and (2) the draft SMP did not appear to parallel state
policies relating to navigation, commerce, and protection of
estuarine resources, especially regarding landfills.

As a result, the project sponsor abandoned the proposal, while
Aberdeen voiced irritation that a potential commercial venture and
use of privately held land and shoreline had been discouraged by the
state. The City of Aberdeen was particularly frustrated because they
believed the project had conformed with the draft SMP. A shoreline
permit was eventually obtained, although no EIS was prepared. The
COE issued the permit over strenuous objections by the environmental
community that the use was not water dependent, and that the COE and
the permittee refused to mitigate the activity by removing the
structure upland to avoid bulkhead filling.

The Aberdeen SMP was finally approved in June 1975 after
amendments concerning landfills had been incorporated by the city.
WDOE approval was accompanied by comment that the SMP did not
squarely address complex issues relating to landfills and the expected
uses of filled areas. WDOE referred to the proposed long-range
dredging effects study sponsored by the COE as providing future
clarification of this issue.

Boise Cascade Corporation sawmill proposal In October 1973, the Boise
Cascade Corporation submitted a substantial development permit
proposal to the city of Aberdeen. Boise Cascade proposed placing
1,348 feet (414 m) of bulkhead along the northern margin of the
Chehalis River opposite the Aberdeen Reach of the main navigation
channel (see fig. 2) , and filling the bulkhead with wood-waste
materials to provide level terrain for log storage and sorting.

Local authorities approved the project proposal. In November,
however, WDOE appealed the proposal through its substantial -
development review capacity because of potential water-quality impacts
from wood-waste leachate. The appeal was based on guidelines
restricting placement of wood-waste fill in shoreline areas. The
permit was eventually granted by the state in late 1975, after it was

D-18

agreed that dredged material from the COE channel maintenance project
would be used for the bulkhead fill in place of wood waste.

Obtaining a federal permit decision for the Boise Cascade project
proved more difficult, and brought the need for comprehensive planning
in the estuary to the attention of the state's two senators. In
1973, EPA had not codified criteria implementing section 404 of the
Clean Water Act (CWA). Consequently, EPA centered its opposition to
the project on water-quality criteria alone. The EPA was concerned
about the long-term effects of wood leachates entering the estuary.
However, after the proposed fill material was changed to dredged
material, EPA retracted its objections. NMFS conditionally approved
the project based on policies for protection of aquatic resources
and water-quality guidelines. The remaining federal agency, USFWS,
opposed the project due to expected adverse effects on fish and
wildlife. USFWS noted specific impacts on (1) juvenile anadromous
fish migrating through the proposed project area; (2) juvenile
salmonid food supply that would be significantly altered by the
fill; (3) shorebird and waterfowl use of the adjacent affected area
for feeding and resting; (4) other specific impacts related to the use
of wood waste for fill material; and (5) former deposition of wood
waste in wetlands and tidelands in the Aberdeen area. Moreover, the
USFWS response addressed the need for comprehensive estuarine planning,
stating that they:

. . .urged development of a comprehensive land use plan for
this area to identify spoil sites and water oriented industrial
needs. Until such a coordinated plan has been developed to
establish a requirement for additional waterfront log storage
area, we cannot accept the losses that such projects engender
for fish and wildlife resources. K'e thus recommend denial of
this permit (USFWS, 1974).

In a letter to the project sponsor, USFWS indicated similar
concerns. The agency emphasized that "piecemeal and indiscriminate
filling and construction" is chronic in the Grays Harbor region, and
reiterated the desire for a comprehensive plan: ". . .we do, and
will continue to, recommend that all such projects be denied pending
development of a comprehensive plan, or at least until solid progress
on a jointly developed plan is evidenced" (USFWS, 1974). Even after
the nature of the fill material was changed from wood waste to
dredged material, the site was designated for the water-related
requirements of a sawmill, and the other involved agencies approved
the proposal, USFWS continued to oppose the project.

The City of Aberdeen charged the Department of the Interior and
USFWS with placing "a moratorium on development in the City of
Aberdeen without consulting the government of Aberdeen and without
providing the people of Aberdeen a chance to be heard." Aberdeen
considered such action to be "an abuse of governmental power."
The response went on to state, "Your objections, without good reason,
have had a damaging effect on the economy of Aberdeen when we have
12 percent unemployment" (City of Aberdeen, 1975). Copies of the
letter were also sent U. S. Senators H. M. Jackson and W. G.
Magnuson.

The USFWS provided detailed responses to inquiries from both
senators. They informed Senator Jackson that they had previously
communicated their position on tideland filling to the GHRPC, and
that USFWS "was not unalterably opposed to the project, but
recommended denial of permits for fill projects until such time as a
proper comprehensive plan is offered." The agency also took

D 19

exception to Aberdeen's charges regarding a moratorium on development:

This is inaccurate. If our position may be termed a moratorium,
it is a short-term moratorium on certain kinds of develop-
ments, such as tideland fill for all of Grays Harbor. This is
done for the purpose of reaching a jointly determined plan
that will accommodate our shared interests in the future
management of the estuary (USFWS, 1975 a).

The response to Senator Magnuson was similar, but also stated:

There is definite need for some kind of balancing action in
this area. We realize port areas are primarily industrial
zones; but to condone the continued piecemeal filling of
valuable littoral areas for nonwater-dependent facilities
and the resultant loss of fish and wildlife habitat without
guarantee that the more valuable tidal and wetland areas
will be preserved. . .is shortsighted and inconsistent
(USFWS, 1975 b).

On 4 September 1975, the USFWS, Boise Cascade Corporation, the
Port of Grays Harbor, and the GHRPC met in Aberdeen in an attempt
to resolve the permit conflict. Boise Cascade indicated serious
reservations about continuing the proposed project. On 18
September 1975, USFWS released its objection to the issuance of
a COE section 10 permit:

In the belief that good faith has been shown with respect
to prompt action on a memorandum of understanding for
joint development of a mutually acceptable comprehensive
plan and with the full expectation that the City of
Aberdeen and other local governments adjoining Grays
Harbor will cooperate to the end that such a plan is
developed in conjunction with federal navigation projects,
it is our intention to withdraw our objections to
issuance of the Boise Cascade Corporation permit (USFWS, 1975).

The agency stated, however, that it would object to any future
filling activity involving wetland areas where a federal permit
was required unless USFWS and appropriate local governments
signed a memorandum of understanding relating to development of a
comprehensive plan. The permit was finally issued after
significant political intervention and a delay of nearly two years.
Kaiser Steel Corporation industrial facility proposal Perhaps the most pivotal
dispute over estuarine resource use in recent years began with
a permit application published by the COE on 31 March, 1975.
An area at the mouth of the Hoquiam River (see fig. 2) had been
obtained by the Port of Grays Harbor in 1963 as an industrial
development district and was zoned "industrial" in the City of
Hoquiam' s comprehensive land-use plan. Hoquiam's SMP classified
the site as "urban development." Therefore, local interests considered
industrial use of the plot appropriate. The 44.5 acre (18 ha) site
included approximately 25 acres (10 ha) of sedge-marsh habitat and
13.8 acres (5.6 ha) of tidelands (the remaining 5.5 acres [2.2 ha] was
of upland grade) , thus requiring the issuance of a combined federal
permit to satisy section 10 of the Rivers and Harbors Act and
section 404 of the Clean Water Act. An impervious dike,
enclosing 3,355 feet (1,023 m) of shoreline, was included in the
project proposal, with a total of 456,000 cubic yards (351,000 m3) of
fill material required to raise the grade of the entire site above
the 100-year flood plain.

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The Port of Grays Harbor, as project sponsor, stated that the fill
was for log and lumber sorting and storage yards. Federal agencies
responded as required by law. However, there was considerably more
weight to certain review statements than in the past, particularly
those of EPA. That agency had recently published proposed guidelines
for implementation of section 404 (b) of the CWA. The guidelines
emphasized project alternatives, and EPA stated that destruction of
tidelands and associated wetlands warranted a critical evaluation of
all reasonable alternatives to the fill of estuarine margins. EPA
also expressed concerns about potential water-quality impacts of the
proposed project; the fill material was to come from a submerged
borrow site, thus increasing the likelihood of adverse affects on
aquatic systems. EPA therefore recommended that the permit be denied.

The USFWS responded in depth to the Port's proposal, relating a
list of project -linked impacts and the absence of comprehensive
estuary planning necessary to avoid regional cumulative environmental
disruption. The response reiterated the now-familiar position of
USFWS:

Past piecemeal development along the channel has decimated
fish and wildlife habitat and drastically limited public access
and fish and wildlife related uses. This is essentially the
last remaining area that has the potential for becoming
a waterfront park, providing public access to the waterfront,
or being dedicated as open space. We believe the failure
to consider this location for such uses is shortsighted and
does not constitute waterfront planning in a comprehensive and
coordinated manner (USFWS, 1975 c).

USFWS also stated that the. use planned for the fill area was
inappropriate because it was non-water dependent, and that alter-
native log storage sites existed elsewhere. USFWS requested that the
permit be denied, and further stated that:

... we have not abandoned our original objectives that there
be coordinated and comprehensive site specific planning for
the Grays Harbor estuary, its shorelines and wise waterfront
utilization. We remain available. . .(USFWS, 1975 c) .

NMFS objected to the permit, concurring with EPA that adverse water-
quality impacts would significantly affect aquatic resources.

After all federal agencies recorded opposition to the proposed log
storage and sorting project, events took an unexpected turn. On 24
June 1975, the EPA received a letter from Senator Jackson stating, *vj
have learned that the land in question, for which a permit must be
obtained from the Corps of Engineers, is intended to be used by a
firm which constructs equipment designed to increase energy production
in this country" (Jackson, 1975). Apparently the Port had
confidential development plans for the site. Specifically, the Port
had been privately negotiating with Kaiser Steel Corporation for an
energy- related industrial facility.

On 17 July 1975, EPA and USFWS personnel met with Port of Grays
Harbor officials and were informed that on 22 July 1975, a lease option
for the site would be signed with Kaiser Steel Corporation. This firm,
it was revealed, would manufacture and assemble off-shore drilling
platforms for exploration and exploitation of oil and natural gas
deposits on the continental shelf of North America.

On 17 September 1975, the Port made appropriate revisions to the
SMA. permit application reflecting the proposed Kaiser Steel facility
and identifying Kaiser as a project co-sponsor. The use change from
log sorting and storage to the fabrication of off-shore drilling

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equipment also necessitated a revised COE permit application and thus
reevaluation by all agencies.

In September 1975, EPA's proposed interim final section 404 guide-
lines were promulgated, and construction of the Kaiser Steel facility
appeared to meet the agency's criteria. The Port and Kaiser Steel,
however, had not yet finalized a lease agreement. As previously
noted, many of EPA's original water-quality concerns with this project
were due to the source of the proposed fill material. To overcome
this objection to the project, the Port, Kaiser Steel, and the COE
initiated discussions to coordinate the spring 1976 maintenance
dredging schedule with the filling of the Kaiser Steel and Boise
Cascade sites so that dredged material could be used for fill. EPA
recognized the adverse water-quality impacts caused by filling the
wetland area, but noted that impacts would be minimized if dredged
material were used. As the project would aid energy production and
was considered to be in the national interest, and since it appeared
to conform to their criteria for dredging and filling, EPA responded
on 14 October 1975:

If this agency withholds permit approval pending an actual
Port of Grays Harbor and Kaiser Steel Corporation use
agreement, the time needed for filling the site for this
use may expire. The Port and the Aberdeen-Hoquiam area
may lose this needed industry and employment. We will not,
for this reason, hold up the issuance of the permit for
the agreement (EPA, 1975) .

As noted earlier, Kaiser Steel had merely committed to a lease
option on the property. Concurrently, the availability of off-shore
oil leases in the Gulf of Alaska became uncertain due to conflicts
surrounding secondary impacts of oil development on coastal communities
in Southeast Alaska. Furthermore, additional delay of the Kaiser
Steel project seemed unavoidable since the COE had determined that a
federal EIS would be required. EPA foresaw these potential problems
and surmised that Kaiser Steel would probably never use the site.
Therefore, EPA conditioned its response, citing 404 implementation
guidelines, to require future dedication of the site for water-
dependent use regardless of the ultimate occupant.

In an eleventh-hour effort to salvage the fill proposal and to
retain Kaiser Steel as a lessee for its site, the Port of Grays
Harbor formulated Resolution No. 1673 on 9 December 1975, (Port of
G. H., 1975; USACOE, 1976 b § c) . This resolution officially
". . .dedicates and pledges the use of this industrial site by
water-dependent activities only, and be it further resolved, the
Port of Grays Harbor pledges its continued cooperation in developing
a comprehensive plan for the Grays Harbor estuary. . ." With the
signing of this resolution, the remaining federal agencies conceded
to the issuance of the COE permit.

The filled area west of the mouth of the Hoquiam River is vacant
at present, since Kaiser Steel and the Port did not complete the
final lease agreements. Development of off-shore oil resources in
Alaska has not proceeded as rapidly as initially expected. Commercially
developable oil reserves have not been discovered on the leased
tracts. Off-shore oil and gas drilling equipment probably will be
fabricated and assembled elsewhere. The vacant site remains
controversial, however. The area is stabilized fastland and is
available for use. Resource agencies hold that, if there is a
pressing need for industrial development sites, as local interests
and the Port assert, the site would be occupied at this time.

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Decision-Making Problems at the Local Level

The three key disputes discussed above reflect general decision-
making problems. One of these general problems centers on
uncertainties in implementation of the SMA at the local level. Since
the inception of the SMA in 1972, WDOE has reviewed all substantial
shoreline development applications in the estuary (see appendix) . WDOE
records for the years 1972 to 1975 indicate that an overwhelming
majority of project proposals were situated in the inner harbor area,
thus requiring initial review by Grays Harbor County and the cities of
Aberdeen and Hoquiam. Although the county SMP was first approved by
the state in June 1974, WDOE reevaluated the program in September of
that year. The state determined that the county SMP allowed
"indiscriminate use of fill for all types of activities" and, as a
result, was inconsistent with SMA implementation guidelines (WDOE, 1974).
WDOE requested that Grays Harbor County amend and rewrite portions of
the program such that "regulations for landfills and bulkheads. . .
favor shoreline-dependent uses." The county SMP was not officially
approved until July 1978 after specific WDOE suggestions had been
incorporated. The Aberdeen SMP was finalized in June 1975, but, as
noted above, it contained fundamental inconsistencies with state
water -dependency policy guidelines. Hoquiam' s SMP was accepted by
WDOE in April 1976.

Thus, estuarine resource-use disputes, preceding the agreement
to enter into collaborative planning, had generally occurred in the
absence of officially approved SMP's. A formalized coastal zone
decision framework, as mandated by the state SMA and the federal
CZMA, was not in place in Grays Harbor from 1972 to 1975, the period
in which the three disputes discussed above created a common impetus
for collaborative planning. During this three-year period, approximately
fifty- five substantial development permits were administered by
Aberdeen, Hoquiam, and the County. All of these were followed by
state review. Of this total, only six projects were remanded by WDOE
for reevaluation by local government. Five of the permit applications
returned to local administrators for additional analysis were appealed
to the Shorelines Hearing Board, including the three disputes described
above. Although local SMP's were not functioning as formal devices
for implementation of shoreline management in the estuary, only: a small
portion of project proposals were appealed to the Shorelines Hearing
Board.

State criticism of local permits decisions centered on fill
proposals, water-dependency criteria, and state environmental policy.
As the local SMP's were installed, conflict in Grays Harbor was not
being ameliorated. Furthermore, those involved in the use and
permitting conflicts apparently did not expect the situation to improve
with the forthcoming federal approval of the -state Coastal Zone
Management Program (CZMP) in June 1976.

Decision-Making Problems at the State
and Federal Levels

At the state level, four agencies -- WDOE, WDF, WDG, and WDNR -- are
important participants in estuarine resource-use determinations in
Grays Harbor. Each has authority over aspects of shoreline and aquatic
resource regulation and management, but their individual approaches
differ. These four agencies also have differing sources of decision-
making authority (see appendix) . Authority for water-quality control
has been delegated by the federal government to the WDOE under section
402 of the CWA. Both WDF and WDG are responsible for management of
living aquatic resources, but have no specifically mandated authority

D-23

to protect estuarine shoreline or aquatic-area habitat, except in
issuing a Hydraulics Project Plan Approval. However, both WDF and
WDG have expanded their role in affecting the use of wetland and
aquatic resources because they can influence the federal permit
process (to be discussed below) . WDNR, as a manager of state lands in
the public interest, has established policies and guidelines for the
management of state-owned aquatic areas. WDNR use policies address
navigation and commerce; public use; food, mineral, and chemical
production; uses of aquatic areas by abutting land owners; and
revenue production.

Differing sources of decision-making responsibility and diverse
approaches to management of specific estuarine resources make for
potentially fragmented review of project proposals by state agencies.
For example, WDOE may respond to a particular proposal by noting
water quality concerns. WDF, with primary interests in the direct
use of aquatic areas by fish and shellfish, might agree with WDOE,
especially if no irreversible loss to benthic or intertidal habitat
is foreseen. WDG views development on estuarine margins in a different
manner. If the proposed project would affect estuarine wetlands or
marsh areas, WDG might resist project approval owing to its more
broadly based objectives, which include habitat maintenance. WDNR's
position might support approval or denial, depending on the proposed
project's proximity to established harbor lines or state owned
tidelands or the perceived need for upland access. Thus, agencies
responding to different aspects of a proposal, with potentially
contrasting criteria and objectives, may not only confuse the project
sponsor, but generate concern among the agencies themselves over the
state's overall ability to manage estuarine resources for the long-
term public benefit and protection of the estuary's viability.

The federal resource agencies have perspectives similar to those*
of state agencies with authority over the same resources. USFWS >
like WDG, has a primary interest in wildlife and its habitat; NMFS,
like WDF, has a primary interest in fish and shellfish; and EPA, like
WDOE, is primarily concerned with water quality in the estuary.
Also like the state agencies, the federal agencies' fundamental
concern is for the adverse environmental effects of filling estuarine
tidelands and wetlands.

At the federal level, the COE, EPA, USFWS, and NMFS share
responsibility for review of proposed estuarine development projects.
While the COE actually issues section 10 and section 404 permits, in
the latter case they must apply criteria developed by EPA, and
specific COE decisions can be vetoed by EPA. Moreover, the authority
of both these federal entities is subject to review and evaluation
by other federal and state resource agencies, stemming from the
broad requirements for decision making set forth in the Fish and
Wildlife Coordination Act (FWCA) and the National Environmental
Policy Act (NEPA) . Thus, USFWS, NMFS, and concerned state resource
agencies provide comment and can influence section 10/404 determinations
In theory, this multiagency review should result in a comprehensive
analysis and decision, since COE expertise lies chiefly in section 10
matters, USFWS and NMFS have extensive experience in management of
specific aquatic resources and wetland habitats, and EPA concentrates
on water quality. However, fragmented decision making may also result.

Another potential problem area in federal agency decision making
concerns the alternatives analysis required under NEPA, CWA, and
FWCA. In particular, analysis of alternatives to wetland fill is
central to the joint EPA/COE guidelines to implement section 404 of
the CWA. Alternatives must be determined for each proposed shoreline
or aquatic-area project, with analysis and evaluation dependent upon

D-24

the specific nature of the proposed activity as it relates to wetland
resources. The various federal agencies may differ in their evaluation
of the proposed alternatives. Thus, although the proposed joint 404
guidelines establish agency responsibilities for review of the
specific environmental effects expected from development proposals, the
agencies could still differ among themselves on the preferred outcome.

Given all these difficulties in coordinating local, state, and
federal decision making, case-specific disputes similar to those over
the Thunderbird Motel, Boise-Cascade, and Kaiser Steel proposals were
expected to continue and increase in frequency. All interests
and actors were dissatisfied. Dredging and filling activities were
likely to be continuous and the decision -making system offered little
relief to developers or resource agencies. By the mid- 1970' s, all
parties were, therefore, ready to participate in a Grays Harbor
Estuary Management Program.

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APPENDIX E
EXCERPTS FROM THE FEDERAL COASTAL PROGRAM REVIEW*

* Source: Office of Ocean and Coastal Resource Management
National Oceanic and Atmospheric Administration
Department of Commerce

244

III. PROBLEMS OF THE EXISTING REGULATORY SYSTEM

This section of the chapter discusses the evolution of the Federal
and state environmental regulatory process during the last two decades,
the typical types of conflicts generated by multi-agency review of
development proposals, and the kinds of generic problems created by such
revi e.v

A. Recent Evolution of the Regulatory Process

An important result of increased environmental awareness and concern
during the 1960s was a flurry of legislative activity at both state and
national levels, and judicial challenges that changed the way in which
some existing laws were administered. Congress passed a number of laws
that set standards and procedures for meeting national air and water
quality requirements, and gave new authority to Federal agencies to
implement them. Other Federal assistance programs were designed to
encourage states to develop their own regulatory programs; states were
encouraged to pass laws involving state agencies in regulating development
in wetlands, beaches, and other sensitive natural areas that had histori-
cally been managed by local governments. In addition, laws were passed
to assure full consideration of environmental values and fish and wildlife
resources in Federal decisionmaking processes. Most of these new state
and Federal laws and court decisions expanded the rights of citizens and
interest groups to influence and participate in the regulatory process.

While these changes dramatically increased protection for valuable
coastal resources, the systems for managing coastal development also
became pluralistic, complex and costly. Development that once had been
controlled primarily by local government through local planning and
zoning permits, or not controlled at all, is now influenced by numerous
Federal, state and local agencies, each with their own permits or separate
revi ew requirements. Developers and citizens are now faced with, not
only the planning and zoning controls of local government, but also
numerous single purpose performance standard programs, each requiring
several reviews and permits. For example, routine dredging applications
in San Francisco Bay typically require the review of five state agencies
and four Federal agencies, in addition to the agencies of the local
jurisdiction involved. According to local officials, over 700 permits
were needed for construction and operation of the S0HI0 oil port and
transshipment facility in the Port of Long Beach. The company spent
nearly $60 million on the development of this project prior to the with-
drawal of its applications in 1979.

In spite of this complexity, the large majority of coastal develop-
ment projects are approved. Many permits are conditioned to meet the
requirements of state, local and Federal laws, but these conditions are
seldom so onerous that projects cannot be completed. The conditions
can involve added costs that must be balanced against public benefits
of improved project design. For example, during the 4 years that the

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California Coastal Commission approved permits for all coastal development
under Proposition 20, 97 percent of more than 25,000 development proposals
were approved. Ouring the last 2 1/2 years of administering the Massachu-
setts Wetlands Protection Act, the state's Division of Wetlands reports
that less than 10 percent of wetlands orders by local conservation
commissions were appealed. At the national level, the Corps of Engineers
reports that in Fiscal Year 1979 less than 1 percent of all permit
applications were referred to its Washington headquarters for resolution
of conflicts. Of the 16,000 permits or letters of permission processed
by the Corps in that year, 72 percent were approved with no problems,
and most of the remainder were handled at the district level.

Although these statistics do not reflect the costs incurred by those
who withdraw applications prior to completion of the regulatory process
due to delay, unacceptable conditions, or general frustration with the
uncertainty of the outcome; the proportion of permit applications that
raise significant problems of interagency conflict or coordination is
very small, in comparison to those that are approved with no conflicts.
The small percentage of permit actions that involve denials, appeals or
conflict are typically larger projects which have a greater potential
for significant impacts on natural resources or economic development.
Conflicts over these projects can take large amounts of time and money
for environmental analysis, litigation, administrative appeals, dispute
resolution and other results of conflict and delay. However, it is
recognized that in some cases conflicts between agencies with different
mandates serve to identify and protect the overall public interest, and
these expenditures are worthwhile.

B. Conflicts Generated by Multi -Agency Review

The pluralistic system of regulatory review that has developed over
the last two decades has, however, contributed to protracted disputes in
some instances and has led to the need for increased coordination among
Federal, state and local agencies. A typical conflict situation may
involve a developer, port authority, or public works agency that reaches
agreement with one or more local governments on a proposed project, only
to have the project denied after lengthy and costly proceedings by a
state or Federal agency. In some cases both local and state approvals
may be granted, but a Federal permitting agency may deny the project on
the basis of its own requirements, other Federal agency comments or
those from citizens or interest groups.

Such conflicts can occur within a single level of government.
For example, local development projects which are proposed in order to
carry out plans supported or approved by one Federal agency may subse-
quently be denied by another Federal regulatory agency. A state or
local government may have invested considerable time and money in pre-
paring a comprehensive land use plan, airport or highway plan, or economic
development plan with Federal funding agency assistance and concurrence
-- only to have projects needed to implement the plan blocked by a Federal
regulatory agency that did not participate in such plans. State or

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Federal resource agencies may also disagree among themselves on how
projects should be developed. Several classic examples of such conflicts
were cited by an agency official providing comments for this Review:

"A water quality agency, in its review of a permit for a shoreline
development, required that it be constructed on fill that would seal
off leachate from an old woodwaste disposal area. A wildlife agency
refused to approve the permit because the fill would remove some wet-
land and required that the project be constructed on a structure.
Either way was acceptable to the developer, but the two agencies
did not agree. The proposal, caught in this delay, lost financing
and fell through. In other situations, agencies responsible for
waterfowl tend to support marsh creation projects while agencies
managing fish will resist any modification in aquatic areas. This
conflict often frustrates mitigation proposals (since mitigation
proposals often benefit one species at the expense of another) and
enhancement proposals. Controversies over mitigation or enhancement
proposals can be as great as development proposals. This conflict
between 'environmental protection' agencies is often very confusing
to local officials and is perhaps their greatest frustration in
dealing with agencies."

Conflicts such as these can delay or prevent needed economic develop-
ment or energy projects, lead to loss of valuable coastal resources, or
cause excessive costs to both private investors and the public. The
Port of Baltimore, for example, maintains that its dredge disposal costs
have increased 400 percent over the last 4 years because of delays in
obtaining necessary Federal and state permits largely due to intergovern-
mental conflict and environmental litigation over spoil disposal on two
nearby islands. Too often, such conflicts emerge from the process after
specific sites have been selected, land acquired, local permits obtained,
and large amounts of money invested in engineering drawings, site investi-
gations and environmental analyses.

These kinds of conflicts are often resolved in a way that leads to
frustration with government. The uncertainty of the outcome and difficul-
ties of the regulatory process has a chilling effect on some citizens'
willingness to engage in it at all. In other cases, developers and
local proponents may try to overturn negative Federal agency decisions
on a project by political intercession rather than seek a more appropriate
location or produce a design that would meet the agencies' requirements.
In Grays Harbor, Washington, for example, 39 acres of valuable tidelands
were lost when state and Congressional legislators intervened in a con-
flict between the local Port Authority and state and Federal resource
agencies over the filling of land for an oil platform construction facili-
ty. Four years later, the filled area remains vacant and unused. In
Monterey, California, the famous Cannery Row was excised from the State
Coastal Commission's jurisdiction by the state legislature when efforts
to resolve conflicts between development and preservation interests
broke down. Such political intercession may foreclose opportunities for
citizens, interest groups or property owners to influence the outcome of

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regulatory decisions, or, at the least, cause them to perceive that they
have not had an equitable chance to do so. The perception that narrow
special interests are often the beneficiaries of such intercession damages
the credibility of the entire regulatory process.

C. Generic Problems

The existing regulatory system is largely reactive. It fails to an-
ticipate potential conflicts and provide mechanisms for avoiding them,
or to provide for a clear and unified framework of public policy to
guide the balancing of public costs and benefits of individual agency
decisions. As a result, the following generic types of problems continue,
underlying many of the conflict situations described above:

1. Inconsistent government policies

Inconsistent government policies can lead to unnecessary conflicts
when development proposals are reviewed. For example, if local govern-
ment plans designate wetland areas for housing or other nonwater related
uses on zoning maps, property owners and prospective developers may be
falsely encouraged to propose development that is likely to be denied,
since it may be the policy of a state coastal zone management program or
Federal agencies to discourage such uses of wetlands. In Marco Island,
Florida, for example, the Deltona Corporation received local zoning and
state approvals for the proposed development of thousands of dwellings
in wetland areas, only to have its proposals denied by Federal regulatory
agencies. The Corporation incurred substantial losses' in the lengthy
battle over these plans.

Approval of a project proposal at the state or local level without
adequate review of Federal requirements often puts additional pressure
on Federal regulatory agencies to approve projects, especially those
considered to serve the local or state public interest. For example, in
states with approved coastal management programs, developers often misin-
terpret the Federal consistency provisions of the Coastal Zone Management
Act as requiring Federal agencies to accommodate local or state desires
to allow development that is allowed by the approved state program. The
problems created by this lack of understanding of the limits of Federal
consistency were described by one Federal agency representative partici-
pating in this review as follows:

"On several occasions I have been present while developers, with
local planners at their side, argue that since their development is
consistent with the local Shoreline Master Plan, (the National
Marine Fisheries Service) and (the Fish and Wildlife Service) must
consent to (Corps of Engineers) permits. When they discover (the
Coastal Zone Management Act) does not provide an automatic path
through the permitting process, there is a sense of betrayal. They
believe they had followed the proper procedures, and are surprised
to discover that FWS guidelines can prohibit something approved in

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their local program. Thus, it is frequently impossible for a developer
acting in good faith to discuss a project with his local government and
thereby get a complete picture of the regulatory hurdles he faces."

2. Uncertainty in the permit process

As a result of the "performance standard" approach to environmental
regulation, most Federal permitting programs lack sufficiently specific
policies to guide applicants. Federal regulations tend to mandate consid-
eration of broad areas of concern, or require documentation of certain
findings, but provide only very general statements of substantive policy
that could guide specific planning decisions. Agencies rely only upon
case-by-case review of development proposals, based on data collection
and analysis of the specific proposed site and the detailed characteris-
tics of the proposal. Even the broad planning considerations involved
in projects, such as suitability and need at the proposed location, or
consideration of alternative sites, typically are addressed only when an
application for a permit is submitted.

Agency regulations typically set forth processes for making decisions
that require consideration of alternatives, environmental impacts, or docu-
mentation of the need for development proposals. However, they do not pro-
vide specific substantive direction to administrators or the public on what
documentation is sufficient, or even clear definitions of such matters as
water dependency, mitigation requirements, or cumulative impacts. For
example, Corps of Engineers' regulatory criteria, to be considered in the
review of permits for dredging and spoil disposal, include factors such as
"the relative extent of the public and private need for the proposed struc-
ture or work" and "the extent and performance of the beneficial and/or detri-
mental effects which the proposed structure or work may have on the public
and private uses to which the area is suited." Because these criteria provide
little substantive guidance, the Corps and other Federal agencies must devel-
op more specific guidance tailored to specific projects or areas. For
example, an association of property owners, with holdings adjacent to
Belvedere Lagoon in California, attempted for more than two years to secure
permits for dredging the Lagoon, permits that consultants said were necessary
to preserve the Lagoon for fishing, swimming, boating and related recrea-
tional activities and to avoid future fish kills, mudflats, algae blooms
and stagnation. After this delay, the Corps and EPA developed new technical
criteria to determine whether the project would cause significant environ-
mental impacts. Based on new tests using these more specific criteria, the
Corps determined that the project complied with the general criteria.

Even in areas where national policies have been developed, they tend
to be so general that administrators have almost unlimited discretion to
interpret their meaning in the case of each permit application or plan.
For example, Corps regulations provide that in determining whether a proposed
alteration of wetlands is necessary, consideration must be given to whether
or not the proposed activity for which the alteration is to be made is depen-
dent on location in, or in close proximity to the aquatic environment.
Because the concept of water dependency is not fully defined, each District

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Engineer must interpret the criteria on their own, and this judgment may
differ from that of other Corps officials and Federal and state agencies.

In contrast to the general procedural criteria of the Corps' regula-
tions, EPA's revisions to regulations for Section 404(b)(1) of the Clean
Water Act include significantly greater guidance with respect to determina-
tions to be made in regional offices regarding discharge of dredged and
fill materials in U.S. waters. For each area of concern, such as salinity
or mud flats, EPA's proposed guidelines describe environmental character-
istics and values, actions that might result in the loss of those values,
guidelines for minimizing impacts, and other special considerations.
These guidelines recognize that individual judgment must be exercised in
each case, and do not prescribe quantified standards or thresholds by
which every project or plan is to be judged; they do, however, provide an
important measure of substantive guidance to field personnel regarding the
standards by which such judgments are to be made. By law these two sets
of regulations go together to control the discharge of dredged or fill
materials under Section 404 permits issued by the COE.

Although the more general system allows permitting agencies to main-
tain maximum flexibility to consider all relevant factors and interests
before making decisions, the uncertainty inherent in this approach can
work against the interest of both applicants and conservation advocates.
The risk of investments 1n development proposals is greatly affected by
the predictability and timing of government regulatory decisions. Inves-
tors want to know what the policies and requirements are," where these
apply geographically, how the agencies will make their decisions, and
when they will receive answers. Uncertainty leads to greater costs for
applicants in developing their proposals. Conservationists and other
citizens also want to know what the agency's policies and requirements
for development are, how these will affect valuable resources, and what
parts of an area are to be protected from development over the long-term
future. Property' owners want to know how their neighborhoods are likely
to change in the future so that their investments and quality of life
are protected.

In addition, the uncertainties of the regulatory system have broader
costs. As indicated above, they may lead to political intercession in
specific decisions that undermines the public perception of the legitimacy
of the governmental process. They also lead to intense frustrations with
the process. As one commentor noted, "applicants are not mind readers."
This reaction was articulated differently by another reviewer of this
study, who claimed that applicants are forced to respond to repeated
vague requests for project information or for the redesign of their
projects until the personal expectations of the reviewer are met, causing
considerable uncertainty, delay and added expense.

Finally, these uncertainties can also lead to inequities in the
treatment of similar problems. For example, in a December 1977 study
of the Corps of Engineers' regulatory program, the General Accounting
Office reported that the Corps' "guidance for evaluating permit applica-
tions can be improved," and indicated that the Corps' headquarters should
provide better guidelines and criteria to districts for evaluating permits

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involving wetlands. GAO pointed out that of the five Corps districts it
evaluated, each considered wetlands protection an objective of the Clean
Water Act, Section 404 Program, but employed different methods to achieve
that objective, and had quite different records of approvals and denials
for similar actions involving wetlands. The report concluded that,
"Differences in the application of wetlands protection measures caused
unequal treatment of applicants desiring to perform work in wetlands
areas. "

3 . Failure to address cumulative impacts

The cumulative impacts of multiple permit decisions often cannot
be assessed adequately through the review of single applications. The
long-term consequences of development in a given area are difficult to
control through a case-by-case review of each project application.
Protection of the natural functions of an ecosystem requires assessment
of long-term cumulative impacts of many projects, not just those for
which applications have been submitted. Balancing economic development
and environmental concerns often requires that ecosystems be dealt with
in their entirety.

For example, at the time a project is proposed, the natural inter-
action of various parts of an estuary, bay or watershed cannot be ade-
quately considered when permitting agencies deal with only one appli-
cation. In 1979, the Port of Coos Bay, Oregon, applied to local, state
and Federal agencies for two permits — one for a dock in the Bay's North
Spit and another for a trawler basin associated with the dock. Both
projects were part of the Port's long.-range plan for industrializing an
estuarine shoreline. Both also involved alteration of wetlands, a matter
of considerable concern to the agencies involved because Coos Bay had
lost .85 percent of its wetlands to fill since 1892. As a result of public
and agency concerns about the impacts of the proposals, the Port withdrew
its application for the trawler basin. This action left the agencies
reviewing the application for the dock with an expectation of potential
secondary or cumulative impacts of the dock proposal, but with no legal
means to address those impacts, given the limitations of the dock appli-
cation before them. The dock was ultimately approved with no mention of
the broader implications of the project in the Corps' permit.

The 1977 GAO report on the Corps of Engineers' permitting program
noted that, although the Corps' regulations require consideration of
cumulative impacts, neither the regulations nor management directives
specifically provide means for identifying and evaluating cumulative
effects. This report indicated that an in-house Corps study in 1976
identified the evaluation of cumulative impacts of proposed works as a
major district problem, due to the lack of methods or data to perform
cumulative impact assessments. The Corps has recently responded to this
need by requesting proposals from contractors to study the cumulative
impact problem and to develop technical methods for cumulative impact
assessment of permit activity.

E-7

251

4. The costs of case-by-case permit review

Case-by-case review of permit applications can involve excessive
costs to applicants and the public. In many areas where development
involves shoreline alteration, a number of state and Federal agencies
review the same project proposals, and are concerned with the same
or similar effects of these proposals on natural resources. Typically,
the U.S. Fish and Wildlife Service, National Marine Fisheries Service
and Environmental Protection Agency, as well as state fishery, wildlife,
public lands, and water quality agencies, all review the applications
for projects involving the discharge of dredged or fill material or
wetland alteration. Each of these agencies may request or collect its
own data, conduct a separate environmental analysis, and reach its own
decision. In some cases, each of these agencies may collect and analyze
data repeatedly for each permit application in the same area. Applicants
for development in such areas may be required to submit information that
has already been acquired by the agencies from previous applicants. Re-
dundant, uncoordinated, and unpredictable agency data collection, analy-
ses, and review procedures increase public taxes. Those who invest in
property and development also bear added costs in the form of interest
on borrowing, property taxes or option fees, professional fees and admin-
istrative expenses.

For example, before the Baltimore and Norfolk Districts of the
Corps of Engineers revised their procedures for reviewing permit applica-
tions for dredging and fill in wetlands, the site of almost every proposed
project was visited separately by the Fish and Wildlife Service or the
National Marine Fisheries Service in these Districts as part of the appli-
cation review. In the case of a proposed Corps harbor maintenance dredg-
ing project to serve a seafood processing plant on Maryland's Eastern
Shore, the owner of the plant and the adjacent, property where the dredged
materials were to be disposed claimed that nearly 200 various government
officials visited the site during the 6 years before the project was
approved in 1979 (with conditions that minimized its environmental damage).
A June 1980 GAO report on processing Corps permits for dredging projects
indicated that overlapping roles and duplication of efforts were still
contributing to permit delays. In the Corps' Districts it reviewed, both
FWS and NMFS were receiving all public notices regarding dredging applica-
tions and often performing field reviews on the same project. Encouraging
progress has been made by the COE in reducing this problem by development
of interagency agreements and joint Federal -state review procedures, des-
cribed in Section IV-A.

There are often substantial costs to natural resources associated
with case-by-case review of completed project applications. Controversy
or delay resulting from a wildlife agency objection to a project applica-
tion, in which substantial investments may have been committed, often
leads to political intercession on behalf of the applicant and loss of
an environmental resource.

No complete estimate exists of the costs associated with redundancy,
delays and conflicts resulting from a regulatory system that relies

E-8

252

primarily on case-by-case permit review. Howeyer, some of the comments
received during this review suggest that the costs are substantial.
These include the following:

- A port official noted that "A rule of thumb in the [port] industry
is that delay alone [in regulatory proceedings] increases total
project costs by 1 percent per month."

- The same official also noted that "There are also substantial
environmental costs caused by delay. Millions of gallons of sewage
have been dumped [into rivers and bays] during delays in getting
agreement between agencies for waste water treatment system im-
provements."

- A conservation group indicated that "The Corps of Engineers spends
$30 to $40 million per year on environmental impact studies, and
millions more in litigation over their decisions. Tremendous cost
savings could be realized by a new approach to these decisions.

ii

. • .

- A city official noted that "We spent between $130,000 and $150,000
producing a regional plan [to address regulatory conflicts] for the
Baltimore Metropolitan Coastal Area. [By comparison,] the environ-
mental assessment for one permit in this area cost $1.2 million.
[For another example,] Bethlehem Steel Company claims that delays
in obtaining permits cost an additional $500,000 to $1 million on
recent construction projects in the area. I do not think you
would have trouble attracting funds [for improving -the regulatory
system] from industry."

5. Misuse of case-by-case permit procedures

It is often alleged that there is a misuse of case-by-case permit
procedures by those who wish to impede economic development, or by others
who wish to circumvent sound requirements for environmental protection.

Those proposing projects frequently claim that permit review proce-
dures provide too many opportunities for opponents of economic growth or
new development to veto projects. They claim that information is withheld
during the planning of projects, when it could be used to improve the
project design; and then used against the project when the opponents'
voices are most effective in the regulatory process, -- such as before
administrators or commissions that are most responsive to environmental
concerns. Project proponents often claim that since projects typi-
cally require several stages of approval through different agencies,
they can be stopped by opponents by gaining cumulative concessions from
agencies for conditions on projects by finding the "weak link" in 'the
chain of regulatory decisions, by challenging projects in the court when
opponents fail to get what they want in administrative procedures, or by
so slowing the process with minor objections that the project becomes
uneconomic. For example, late in the multi-year battle overTellico Dam
in Tennessee, environmental groups allegedly sought and found an endan-
gered species — the snail darter — after failing to stop the project on

E-9

253

other grounds in the administrative proceedings. This led to Congression-
al intercession in the form of changes to the Endangered Species Act.

On the other side, citizens and environmental groups often claim that
some public agencies view the public welfare too narrowly by reviewing
projects in a manner that reflects only interests in business, economic
development, taxes, or jobs and that environmental concerns are too often
ignored. They claim that when legitimate environmental concerns or
requirements are used to condition or deny development proposals, appli-
cants often label the "bureaucratic permit process" as an arbitrary
abuse of public authority, a taking of private property without compensa-
tion, or otherwise try to avoid complying with the law. They frequently
allege that some development interests purposely avoid addressing environ-
mental concerns through political intercession on projects or legislative
challenges to legal requirements. Many coastal management laws have
been challenged repeatedly in state legislatures on the basis of "horror
stories" of delay or increased costs caused by regulatory procedures.
For example, when Brown and Root withdrew a proposal in 1978 for an
OCS platform fabrication facility near Astoria, Oregon, local officials
and the press blamed state and Federal environmental permit procedures,
particularly state mitigation requirements for wetland alterations. Later
information revealed that while the agencies were working toward approval
of the facility with conditions to safeguard the environment, the firm
withdrew its proposal because the market was not favorable for its products
in Alaska lease sale areas and antitrust actions had been commenced
against its parent company.

Environmental and other public interest groups point out that propo-
nents of projects are typically well-financed and have adequate legal
representation for their private interests, while public groups have
only limited (often volunteer) resources to participate in regulatory
proceedings. This, they claim, accounts for those few situations when
such groups avoid commenting in lower level (sometimes hostile) proceed-
ings, in favor of commenting in later proceedings where they have the
most influence. Citizen groups also claim that some developers purpose-
ly "wear down the opposition" by scheduling, then canceling, public
hearings on proposals or making repeated minor revisions to proposals,
and selecting an opportune time for processing applications when the
initial controversy has subsided. However, small developers or private
landowners often have less resources and expertise to use in this process
than such "public" groups, and complain about the undue regulatory burden
imposed by what they see as unrealistic zealots.

To some extent these generic types of problems of the existing
regulatory systems are found wherever development is managed by govern-
ment agencies with overlapping legal jurisdictions over the same projects
or resources. However, they become intensified in the nation's coastal
zone, which contains many limited geographic areas where unique and
valuable natural functions that serve fish and wildlife resources compete
with economic functions such as port and urban development. Any project
involving work in the coastal waters of the United States will automati-
cally be subject to review by at least four Federal agencies, typically

E-VO

254

under five separate statutes. Many of the most sensitive areas in the
coastal zone are enclosed ecosystems such as bays and estuaries, where
development impacts are likely to spill over the boundaries of several
local jurisdictions. Because the resources at stake are likely to be of
more than usual significance, state agencies are also likely to have
some control over proposed projects. Finally, these regulatory prob-
lems tend to become exaggerated in such areas when repeated conflicts
cause normal avenues of communication and cooperation to become closed.

E-ll

APPENDIX F
THE CITIZEN'S GRAYS HARBOR ESTUARY MANAGEMENT PLAN

Citizens' Grays Harbor Estuary Management Plan

Submitted

to THE

Grays Harbor Estuary Management
Task Force

and. THE

Federal Office of Coastal Resources
Management

15 January 1983

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CRAVS HAR9DR EStUAJtY MANAGEMENT PLAN

L'EEEND

MANAGEMENT UNITS AH

?6 - UNIT NO.

CM • MANAGEMENT CATEGORY
N - NATURAL

CN • CONSERVANCY NATURAL
CM • CONSERVANCY MANAGED
RA • RURAL AGRICULTURAL
RL • RURAL ICW DENSITY
UR • URBAN RESIDENTIAL
UM - URBAN MIICD
UD - URBAN DEVELOPMENT

CM/N - SPLIT UNIT

PLANNING AREAS — . //

Figure 3. Conceptual Alternative-Plan of Development
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F-19

APPENDIX G

REVITALIZATION POTENTIALS ON THE GRAYS HARBOR WATERFRONT,
"Use and Development on the Urban Waterfront," Chapter 2,
Grays Harbor Regional Planning Commission, 1982

CHAPTER TWO

USE AND DEVELOPMENT OF THE URBAN WATERFRONT

2.1 INTRODUCTION

Any urban waterfront rehabilitation program must be based upon the economic
character of its region and the locational requirements of the industries which
use the region's waterfront. This chapter will explore those facets of the use and
development of the Aberdeen/Hoquiam/Cosmopolis waterfront. As such, it will
focus particularly on the lumber and wood products industry which has accounted
for the development of both the region and the urban waterfront. Indeed, it
was the juxtaposition of the immense timber resources along with the access to
low cost transportation afforded by waterfront sites that is responsible for
the development of the region. While this locational advantage accounts for
the waterfront development and hence its major opportunities for redevelopment,
it also is responsible for many of the problems that this study seeks to
address. While optimum sites for the lumber and wood products industry are
still in waterfront areas, the changing site requirements of that industry
has also resulted in dramatic changes in the specific type of sites the
industry required. This has led to the abandonment of older mills and develop-
ment of new mills in previously undeveloped areas. These changes have left
behind the blight which may be found on the waterfront. Since many of these
older sites are no longer suitable for lumber and wood manufacturing (assuming,
that resource management agencies would not allow substantial expansion of
these sites into the adjacent water areas; see sections 1.2 and 3.3), this
chapter will also explore the use requirements of other economic activities
which may be possible alternatives.

2.2. LUMBER AND WOOD PRODUCTS AND THE WATERFRONT

2.2.1 Location of the Forest Products Industry in Grays Harbor County

The forest products industry is and always will be the most significant
user of the urban waterfront. A cursory examination of the location of forest
products firms in Grays Harbor County readily indicates that most of the
industry is concentrated along the shoreline of the estuary. Approximately 70
to 80 percent of the employees engaged in forest products manufacturing are
employed near the waterfront in Aberdeen and Hoquiam. This concentration is
especially apparent in the pulp and paper sector (all three firms, employing
1,814 people in 1972, are located near the estuary). Approximately 80% of the
sawmill employment is located near the Harbor as is over 50% of the plywood
and veneer employment. Shake and shingle processing is scattered throughout
the county, but several of these plants are also found near the waterfront.
This total share of forest products employment represents approximately 20 to
25% of the total non-agricultural private sector employment in the county. Of
course all of the employment engaged in exporting forest products is also
located directly on the waterfront.

A definite relationship has been noted between the size of firm and location.
The firms which are larger, with greater capital investment and public facility
requirements tend (though not completely) to be located near the bay. Smaller
firms on the other hand take a more random distribution.

G-l

2.2.2 Importance of the Estuary Sites f.or Industrial Uses

The estuary plays a vital role as a transportation facility involved in
the exportation of regional products. However, the above data also indicates
that a considerable proportion of the forest products manufacturing capacity
which may not be related (or is only marginally related) to waterborne trans-
portation is also located on the shores of the bay.

There appear to be two basic reasons for this occurrence:

1. Available Flat Land. Standards used for industrial locations
generally specify that quality industrial sites cannot exceed a
slope of more than 6%. Topographical information reveals that most
of this land in the county is either adjacent to the estuary or
within the floodplains of the river valleys. In the immediate
vicinity of Aberdeen and Hoquiam this land is found near the estuary.
Consequently, industry in its search for suitable sites naturally
tended to utilize estuary locations.

2. Historical. While much of today's forest products industrial pro-
duction is not now dependent on water transportation, historically
this was not always the case. During the early development of the
forest products industry overland transportation systems were quite
primitive and not capable of the efficient transport of industrial
materials and products. Consequently the forest products industry
relied heavily on water transportation to bring logs to the mills
and ship the finished products to markets.

These two factors still appear to be the major influence over industrial
location. The availability of flat land suitable for industrial activity has
become, if anything, more restricted with time, as many of the flat areas have
filled with other forms of urban uses which also require flat land. Presently
almost all of the land with slopes of less than 12% and which is not located
on the waterfront in Aberdeen, Hoquiam or Cosmopolis is firmly committed to non-
industrial uses.

The continued development of industrial uses along the waterfront has
generally lead to an almost complete orientation of industrial services to
these sites. Such services include: the rail systems, the roads, the indus-
trial water supply, the sanitary services, and the electrical distribution
system. Only those plants which do not require or depend on a high level of
these services can utilize other locations.

In order to locate where these services are not provided, large capital
investments would be needed to extend the services. Such capital may in
many cases find better investment opportunities elsewhere. Also the efficiency
of providing services of the necessary magnitude would be impaired if two
separate location patterns (one oriented to water dependent uses and another
oriented to non-water dependent areas) had to be served. It would also be
questionable economically in an area the size of Grays Harbor.

Related to the present orientation of services, is the factor of linkages.
Industrial activities frequently depend on, or utilize other industrial activ-
ities as sources of materials. Location, then, in proximity to other industries,
which are either suppliers or users , is another important concern (especially

G-2

when bulk volumes are involved). The forest products industry has many such
linkages since many different types of products can be derived from logs or
various part of logs; examples include:

1. Plywood and sawmills provide chips for pulp and paper manufacturing,

2. Pulp and paper manufacture produce a range of by-products suitable
for other activities.

3. Logs vary in suitability for different processes. Access to a
variety of processes ensures maximum use.

4. A range of industrial services for equipment manufacture and service
are associated with the forest product industry.

In these linkages, considerable diseconomies are produced when plants
cannot locate near one another, and the greater the distance, the greater the
diseconomies.

Similarly, materials flows are a concern. When material has a wide variety
of potential uses, considerable economies may be provided by flexibility of
use. As logs flow into the Grays Harbor area they can be readily diverted to
the use that maximizes the greatest market potential at any given time. The
present locational pattern provides that they can readily go into export,
pulp /paper, lumber, or plywood. This advantage lessens with distance between
the possible processors.

Perhaps the most significant of all locational factors is the site of the
transportation network. Sites where transportation routes come together offer
the opportunity to combine materials from many locations into shipment to a
few locations. In this area, forest products are brought in by a road and highway
network which focuses on Aberdeen /Hoquiam. Aberdeen /Hoquiam serves as a con-
venient central place for the collection of logs from most of the Washington
coastal ares.

Another important aspect of material flows is the need to transfer material
from one mode to another. This "break in bulk" offers the opportunity to
process material without incurring additional handling expenses. Where more
than one mode joins this opportunity exists. In addition, each mode of trans-
port has economic advantages and disadvantages in relation to each other.
Generally truck transport is more competitive for state and regional markets,
rail for national markets, and water for international markets.

The flexibility to use the most competitive mode to serve the market that at
any one time has the greatest potential, serves as a significant locational
advantage.

All of these factors provide a set of potentials for the use of estuary
sites, and hence a concentration of economic activity there. A forced change
from these advantages could significantly reduce these potentials, or at best
require much larger capital investments to achieve. Such increased costs
reduce this region's competitiveness with other regions, and thereby reduce the
potential range of economic activity.

While there are decided economic advantages related to the location of
industry on the waterfront there are also some disadvantages to locating this

G-3

activity elsewhere. These include:

1. The development of necessary public facilities and transportation
would stimulate land uses in new areas, contributing to urban sprawl.

2. Such uses would probably require conversion of agricultural land.

3. Almost all potential sites are located in flood plain areas,
requiring some sort of modification for protection.

4. All such sites are well outside of incorporated places; this reduces
the ability to provide necessary public facilities.

5. Such development will reduce the visual amenities of rural areas
and increase the potential for land use conflicts.

Whether industry locates on the waterfront or not also depends on the
attributes of these sites in comparison to other regions where similar urban
areas have developed the infrastructure necessary to support industry. The
regional comparative advantages for industrial locations consists of avail-
ability of the resource (timber), and access to the waterborne transportation.
Since the raw material can be transportated considerable distance once loaded
on a truck or rail car, the access to water transport along with the other modes
is particularly significant and will probably be the most important siting con-
sideration for a processing firm which would locate in the region. Consequently,
most industries locating here would be water related, if not water dependent.

2.2.3 Locational Concerns Related to Water Dependent Forest Products
Activities

In addition to the influences encouraging the location of industrial
activity in general, there are specific concerns related to the location of
firms engaged in water transportation activities.

Many of these are obvious, such as a log export activity which cannot be
located anywhere else. However, questions may arise regarding the location
of activities which are much less apparent.

While the other activity which completely requires a waterfront location
(i.e. cannot be located in any other location) is the loading of ships, sub-
stantial economies can be realized if the ancilliary activities leading up
to the loading also occur near the site where ships will be loaded. In the
case of log exports, adequate storage and sorting areas facilitate ship loading
by providing flexibility. When storage and sorting facilities are separated
from loading areas logistic problems of communications, transport, and timing
arise increasing costs. In the case of loading finished products, processing
plants near the terminal eliminate the need to load and unload trucks between
the plant and the docks. It also permits easier diversion of logs appropriate
for export from logs entering the plant.

2.2.4 Changes in Historical Requirements

While the economy of the area has and will require extensive use of the
urban waterfront for processing and transshipment of lumber and wood products ,
this industry has changed and will continue to change dramatically in terms of
the types of sites it requires for efficient and competitive operation.

6-4

Aberdeen/Hoquiam's heyday of lumbering actually occurred during the 1920' s;
with 1929* s harvest being the largest in the County's history. As the harvest
boomed so did the development of processing and transshipment facilities to
handle that harvest. The location of these facilities originally was dependent
on the most practical way of moving logs before the advent of the logging truck,
rafting logs down rivers to the area where lumber schooners could access. Mills,
docks, and wharfs then located at places where the logs, rafts, and lumber
schooners came together. As these activities developed, so did houses for the
workers, followed by stores and other commercial services. In Grays Harbor's
case the place where the most schooners and logs came together was at the con-
fluence of the Chehalis, Wishkah and Hoquiam Rivers, accounting for the develop-
ment of the Cities of Aberdeen, Hoquiam, and Cosmopolis. It is interesting to
note that the population peak of the County (prior to 1970) occurred in 1930,
the census year nearest the peak harvest year of the County (1929). The
populations of Aberdeen and Hoquiam still have not surpassed this population
peak.

Aberdeen and Hoquiam also, at this time, developed a significant ship
building industry; building lumber schooners to ship the harvest. While
Aberdeen and Hoquiam were the focus of this activity, some type of log handling
or transshipment facility occurred at the mouth of almost every stream in the
harbor; accounting for the remains of pilings and other structures throughout
the estuary.

Mills and shipping facilities in those days were very small by today's
standards, due to by a variety of factors including small ships and inefficient,
labor intensive saws and milling equipment. The site area needed for these
facilities was quite small consisting of just enough room to accommodate the
mill or dock itself. No land space was required to handle logs since logs were
moved, stored, and sorted in the water.

Since the 20 's this has all changed. The changes came slowly but surely
over the years and were due to a variety of influences.

First, much of the easily accessible old growth was exhausted. This
coupled by the depression of the 1930' s lead to extensive mill closures.

When the industry started coming back after the depression, it was of a
different character. Rail transportation became more competitive with water
transportation for domestic markets. Mills were larger due to improved and more
efficient milling procedures. These mills, however, were still tied to the
water since log rafting was still the most efficient way of transporting,
storing, and sorting logs. The pattern of mill sites consisted then of a
tide water mill receiving logs from the water backed by rail services to move
the lumber. A large dock also was often involved to give the mill the flexibil-
ity of ocean transport of timber as well. The two pulp mills were developed
during this period on a similar pattern. Often the lumber mills were basically
expansions of the older and smaller facilities. Since land landward of the
rail lines was not needed to serve these mills, the rail line served as a
border for industry, with the upland area committed to commercial or residential
uses. Consequently, by today's standards these "larger" mills of the harbor
developed on relatively constrained sites with little back up area.

Perhaps the most significant challenge to this pattern of production
resulted from increases in the efficiency of land transportation and handling

G-5

of logs, coupled with the advent of water quality standards limiting the use of
aquatic areas for log transport, storage, and handling.

As road systems developed further and further into forests, log handling
equipment in the forests became more capable of rapid loading. The log truck
became more competitive with log rafting. Similarly, large log handling
vehicles made land sorting and storing more economical. In spite of these
advances, water transport and handling is still more efficient and probably
would be more heavily used today if it were not for the water quality programs
and regulations which are directed at removing logs from the water. While some
water handling still occurs, where no practicable alternative exists, this
activity is minor compared to the 1950's.

At the same time, changes in milling technology resulted in greater
economies for land intensive mill sites. Mills became less compact and more
spread out.

The combination of these influences made it increasingly difficult and
expensive to operate mills on the constrained sites that characterized the
harbor. The mills needed larger areas for log storage, log sorting, and to
accommodate the movement of larger trucks, etc.

While these pressures were strong, they took hold gradually. Since mills
were built they had a capital investment which would be costly to replace.
Thus, many mills continued with the inefficiencies — continuing to struggle
for permits for water handling, relying on inefficient off -site log yards for
storage and sorting, etc. However, with each cycle of poor market conditions
which characterize the industry, fewer and fewer mills survived. To illustrate
the problem, in the last five years an oldwaterfront mill closed which occupied
approximately 25 acres. During this period, a modern computerized mill employ-
ing a similar number of people opened on approximately 80 acres.

Similar trends were occurring in marine terminals, perhaps more rapidly
since they involved less capital investment. A few large centralized marine
terminals now have takeii the place of a wide variety of smaller facilities.
These trends are likely to continue.

If lumber or wood products facilities are to utilize the waterfront area,
they will require larger areas of land. These generally are not present where
the older mills were located without expansion of those sites into the water by
filling.

2.3 ADDITIONAL POTENTIAL WATERFRONT USES

The types of activities which have used the waterfront, other than lumber
and forest products, were quite limited. Historically they consist primarily
of ship building, commercial fishing and processing, and oil receiving and
storage. Also, several other large marine commerce potentials and heavy
industrial uses have been suggested for the harbor. More recently commercial
activities have been locating in these areas. There should also be increased
opportunities for public access and use of the waterfront in the future. The
present locations of these uses are illustrated in Section 3.5.3 and the
specific potentials for various sites are considered in Chapter Four* This
Section will provide a general overview of these activities and their overall
relationship to urban waterfront.

6-6

2.3.1 Ship Building and Repair

In the past the Grays Harbor area was a major ship building center and
boat building and repair activities continue in Hoquiam. While the channel
depth and available sites limit the potential of the harbor for large ship
building and repair activities, it does continue to have ability to efficiently
accommodate smaller boat builders and repair yards. The realization of this
potential is primarily dependent on the area's ability to attract these
activities. While this use can economically locate here, there are many
competing areas — including the Westport area. This use is particularly appro-
priate for some of the smaller industrially oriented sites that remain.
Because of the extensive use of fiberglass and resins in hull construction
and repair, boat construction and repair yards must be carefully sited to
prevent odors and fumes from impacting nearby uses.

2.3.2 Commercial Fishing and Seafood Processing

Historically, the Aberdeen/Hoquiam/Cosmopolis area has supported a
significant level of activity in this industry. The largest facility was
located at the old fish base in Hoquiam. While most of these activities have
now shifted to Westport and to a much lesser extent Ocean Shores, some nodes
of fish and seafood processing remain,. near the mouth of the Wishkah River and
along the Hoquiam River. The waterfront on one hand is locationally disadvantaged
for this activity in its distance from the harbor's mouth relative to Westport,
but on the other hand it has an advantage in being closer to the market for
seafood products. Generally, as compared to Westport the disadvantages outweigh
the advantages. This is not to say that the current fish processing may not expand
and other factors may alter the balance. For example, the competitive balance
may change slightly with further development of bottom fishing where access
to the market (potentially by air) is particularly, important. As in the case
of boat building and repair, the potential for attracting this activity is
limited. This industry has a further limitation at present in that it has
difficulty in attracting investment due to the problems of the fishing industry.

2.3.3 General Commercial Development

Significant investment has occurred recently in a large general commercial
shopping center on the waterfront. Development of this center eliminated a
major blighted area located on the waterfront, illustrating the potential
of such activities to remove blight. The site, however, was apparently selected
by its developers due to its "ideal" location for commercial traffic flows,
rather than its waterfront location. In fact, potential waterfront amenities
were ignored in the center's siting and design. While this has proven to be
unfortunate from an urban design standpoint, it does illustrate the lack of
appeal the urban waterfront may have for potential investors in commercial
development. They will tend to consider waterfront sites for their general
locational aspects rather than for their waterfront amenities. Consequently,
further commercial development will tend to depend on either changing this
perspective, or will be limited to those sites very well situated for commercial
development. The situation of the Wishkah Mall may also point to a potential
hard choice for waterfront development: "should prospective waterfront
developers be required to design for the waterfront amenities even if such
requirements may by their potential expense reduce the competitiveness of
these sites and thereby potentially maintaining blighted conditions?" In the
case of the Wishkah Mall, Aberdeen apparently opted for blight removal as the
priority in this trade-off.

General commercial development of the waterfront poses another concern.
A new regional shopping center is just being completed in South Aberdeen. This

G-7

mall has already caused concern in the community over the future of competitive-
ness of both the downtown and to a lesser extent the Wishkah Mall, further
general commercial development of other waterfront areas may increase this
concern by adding even more floor space. Exceptions to this, however, are sites
in proximity to downtown which may assist in increasing the downtown's ability
to compete with the new mall. The appropriate development of the waterfront
amenities through design may further enhance the potential of Aberdeen and
Hoquiam's downtowns.

As the competition for commercial sales increases, amenities and images
will be increasingly important. Commercial developments which carefully and
sensitively incorporate waterfront amenities could have a comparative advantage
over other commercial areas . Such a development may be able to capture both
a significant share of the local market and attract some of the tourists
traveling through the urban area. The growth in recreational shopping has
been projected by the Urban Land Institute to be the fastest growing commercial
sector in the 1980* s. Recreational shoppers are most often attracted by unique
and different shopping districts. The Aberdeen/Hoquiam waterfront has the
potential to develop such a shopping district.

2.3.4 Tourist Commercial

Unlike many areas in other regions , the waterfront has never been able to
attract commercial activities associated with the tourism industry. For example,
there is only one restaurant on the waterfront, and no motels with a waterfront
view. This appears to be related to two -factors:

1. Aberdeen/Hoquiam/Cosmopolis, itself are not tourism centers. Grays
Harbor tourism is focused on first the beach areas and second on the
mountains. Aberdeen/Hoquiam/Cosmopolis have not been able to compete
effectively with these areas.

2. The poor waterfront amenities apparently do not prove appealing to
potential investors.

However, since other areas have overcome similar difficulties and have
even used facilities such as waterfront restaurant /motel complexes to alleviate
these problems, the local area has attempted at length to attract this type of
investment. The Port of Grays Harbor has even prepared a site to accommodate
such a development proposal. The site has not developed due to a combination
of factors that include poor money markets and competition with other areas in
the market for this type of investment. This site, however, remains a prime
location for this type of investment with perhaps the best amenities available.
It is expected that development will occur when investment markets improve.
The City of Aberdeen is interested in a similar facility for the site of a
closed mill near downtown.

2.3.5 Public Access and Recreation

Public investment in access or recreation facilities on the waterfront has
not occurred to a significant degree. This is apparently due to the interest
of the state in the development of the beach areas and a nearby lake, and the
local communities' interest in upland areas and another lake. The waterfront
generally has been a low priority concern in relation to other recreational
needs. Again, this may also be related to the lower quality waterfront
amenities. This attitude in the local community is changing, partly due to a

G-8

general change in attitude and due to changes in concepts related to what
waiter amenities are, and an increase in the public awareness of the habitat
these area provide. In the past few would have considered the muddy tide
flats that are exposed in these areas as visually appealing. With heightened
environmental awareness, their popularity is increasing and access to such
areas is now being expected by the public.

Areas with views of shipping activities have always been popular. Local
interest in wetland areas, seems to be focused on four particular activities:
boat launching, fishing, viewing shipping activity, and river access where
there are less extensive tide flats.

This interest is illustrated by the waterfront parks included in the
cities* Comprehensive Parks Plans. The City of Aberdeen's Comprehensive Parks
and Recreation Plan (1980) recommends the development of a waterfront park on
eleven acres of City property along the Chehalis River. The City of Hoquiam's
Comprehensive Park Plan (1980) recommends that the City "acquire 10 to 20 acres
along either the Hoquiam, Little Hoquiam, or East Fork of the Hoquiam Rivers"
for a waterfront park. The City of Cosmopolis' Comprehensive Plan (1979) and
the City Parks Plan now under development recommend that a waterfront park be
established at the site of the present boat launch. These parks are intended
to satisfy the unmet community needs for waterfront parks identified in each
of the plans.

The greatest barrier (indeed the only barrier) to such development is the
lack of public funds generally. However, some level of public investment will
probably be necessary to leverage private interest in commercial development
and to meet the recreation needs identified in the cities' Parks Plans. Indeed
public access and commercial redevelopment are mutually supportive.

2.3.6 Other Maritime Commerce

In addition to forest products related shipping there has been interest in
attracting a more diversified commerce. This has been a long established goal
along with industrial diversification. The Port's efforts to do this have
been against the tide of port economics which generally have been in the
direction of centralizing activity in a few large ports. This centralization
particularly occurs in terms of general cargo where it is difficult for small
ports to compete with the economies of scale, the distribution services, and
the transportation systems available in large ports. The best potential for
such diversification tends to be in bulk cargos where specialization Is both
necessary and can be developed in small ports. Currently, coal appears to be
the leading opportunity followed by grains. However, the site requirements
for such activities are similar to those discussed for forest products. These
activities are not likely to be attracted to the old blighted mill sites because
of their small size.

Oil in shipment is and has been a traditional activity at Aberdeen and
Hoquiam. This has been primarily limited to oil consumed locally and this is
unlikely to change since the port cannot accommodate and could not be econom-
ically developed to accommodate larger tankers. No new sites are needed to
accommodate this activity.

6-9

2.3.7 Other Water Related Industry

As noted, industrial diversification has been a long sought goal of the
area. However, success has been limited due to a variety of complex reasons
described in detail in the region's economic development program. At present
two possibilities are apparent. First is the development of offshore well
rig assembly yard. A site has been rehabilitated and reserved for this purpose.
Its development, however, is held off for two reasons: 1) delays in leasing of
Gulf of Alaska oil fields, and, 2) the current excess supply of oil on the west
coast. It is believed that this site will ultimately be developed for this
activity. Since this site is on an old mill site, it is an example of re-
development. When market conditions improve, there is an additional potential
that a graving dock could be built at the old Port terminals.

Manganese nodule processing is another potential for the region, but the
site requirements for this activity do not match those within the study area
itself.

As a part of extensive interest in pursuing the goal of economic divers-
ification, there is interest in attracting to the area some sort of light,
diversified, "footloose" industry. Sites for such industry with the necessary
infrastructure generally are not plentiful outside of waterfront areas. However,
since such industries are not water dependent or water related, state and federal
resource agencies may object to the use of waterfront sites.

2.3.8 Residential Uses

The most crucial rehabilitation needs are on the Chehalis Riverfront.
Local land use policy has generally reserved these areas for industrial, com-
mercial, and public uses. While it is not anticipated that this policy would
change, suitability of these areas for residential uses is also quite low due
to their blighted and industrial character. A very large residential develop-
ment would be needed to change this character and make the Chehalis Riverfront
suitable for residential development. In addition, state and federal regulatory
agencies would strenuously resist residential development proposals.

The situation in many areas on the Hoquiam River and on most of the Wishkah
River is quite different. In fact, the rehabilitation needs in some of these
areas is related to the deterioration of residential structures. In these
areas , residential development is appropriate (provided there is no alteration
of aquatic areas) and may assist in adding public access.

2.4 CONCLUSION

The industry that historically has used the waterfront (lumber and wood
products) has very limited potential as a source of reinvestment in the blighted
areas of the waterfront. This industry will be better suited to larger areas
adjacent to its required public facilities, areas that are not now developed
(assuming that environmental regulations will prevent enlargement of older sites, and
will allow development of the new sites as envisioned in the estuary plan).

Beyond the difficulties associated with siting forest products activities
there are no readily apparent alternative uses demanding these sites. Indeed,
extensive efforts of property owners and public agencies to attract uses have
not been successful. Consequently, unlike situations which may be present in

G-10

other vwLterfront areas, the problem confronting rehabilitation is not what use
to choose for a site, the problem is how to attract a use for many of these
sites given their current physical and regulatory constraints. There are a
few water dependent uses that do_ have some potential to be attracted to these
blighted sites; notably boat building and repair, seafood handling, and oil
well rig assembly. These potentials, however > are very site specific (such as
oil well rig assembly) or have insufficient potential to meet most of the
rehabilitation needs. Consequently, the remaining potentials are either water
related uses or uses that are not water oriented. The most significant of
these uses are public access and parks, and commercial activities which may be
enhanced by waterfront locations. The most significant barriers to these
developments are:

1 . The blighted condition and low aesthetic quality of many sites
discourage these activities.

2. Limited investment potential; both public and private.

3. Competition with nearby areas with similar and often greater
potential.

Blighted conditions are an especially significant barrier in attracting
investment in commercial activities since the blight on adjacent properties
must also be removed to attract investment. This can only be overcome by
either large scale private commercial development or public investment. Since
attracting large scale investment will be- particularly difficult, some sort of
public action will be necessary to remove this barrier and encourage redevelopment

G-ll

APPENDIX H
LIST OF TECHNICAL TEAM MEMBERS
AND
INDIVIDUALS INTERVIEWED

Appendix H- 1. Composition of the Grays Harbor Estuary Team

Member

Gene Deschamps

Jack Smith

Bill Lucas

Ron Merila

Bob Herman

Ron Pine

Gerald Pelton
or Ken Bowring

Al Springer

Stan Lattin
Rich Hirschberg
Patrick L. Dugan

Bob Goodwin

MANAGEMENT TECHNICAL TEAM
Technical Discipline
Fishery Biologist

Wildlife Biologist

Hydraulic Engineer
Civil Engineer
Water Quality
Water Quality
Recreation

Soils

Planner

Forester

Regional Economics

Marine Economics/
Port Development

Agency/Group

Washington Department
of Fisheries

Washington Department
of Game

Corps of Army Engineers

City of Aberdeen

Weyerhauser Co.

Department of Ecology

Interagency Committee
for Outdoor Recreation

Grays Harbor Conservation
District

Port of Grays Harbor

ITT Rayonier, Inc.

Grays Harbor Regional
Planning Commission

Institute of Marine
Studies

H-l

Appendix H - 2.
Personal Interviews Conducted During the Grays Harbor Estuary Management Inventory

Contact Person Interest Represented

Nancy Thomas Audubon Society (Tacoma)

David Ortman Friends of the Earth (Seattle)

Robert Lentz Poggie Club (Fish and Wildlife Group)

Frank J. Youkoff Poggie Club (Fish and Wildlife Group)

Carol F. Agee Poggie Club (Fish and Wildlife Group)

Bonnie Gilovich Pain Forest Chapter of Audubon Society

President

Florence Bailey Grays Harbor Bird Club

Liz Greenhagen General Environmental Concerns

Bill Detrick Bar Pilot - Westport

Karl wall in Port of Grays Harbor Property Manager

Lois Meyer Ocean Shores Community Club

Wes Peterson City of Aberdeen Parks Director

Dr. Murray Johnson University of Puget Sound Museum of

Natural History

Mr. Steve Jeffries University of Puget Sound Professor

Emeritus

Lew Messmer Grays Harbor Community College Botanist

Jim Phipps Grays Harbor Community College

jim smith Grays Harbor Community College

Eugene Schermer Grays Harbor Community College

H-2

Al Pearson Coast Oyster Company

Mike Lent Coast Oyster Company

Brady Engvel 1 Commercial Oysterman

Wally Hendrickson Gillnetters

H.A. Phillips Gillnetters

L.A. Lytle Gillnetters

Mark Cedergreen Westport Charter Association

Frank Synder Charter Boat Fisherman

Harold Hardy (Westport City Engineer)

Jim Dart Fish Processor

Al Lundgren Bay Fish Company

Leif Anderson Washington Crab Producers Co.

Arnie Sandlen Grays Harbor Chamber of Commerce, President

George Douglas Aberdeen Chamber of Commerce, Manager

W.F. Pierson Twin Harbor Stevedoring Co., Vice-President

& General Manager

Bill Marks Ocean Shores Chamber of Commerce, President

Ed Bowers Interstate Asphalt Co,

Len Nordell Enterprises International (Chief Exec.)

Bob Ingram E.C. Miller Lumber Co.

H-3

Tom Quigg
Rusty Johnson

Bob Bracken
Phil Roderick
Ted Ho land
Don Stedman
Hank Soike
Tom Wagner
Lynn Daneker
Jack McGuire

Phil Bolton
Bill McDeavitt
Doug Hofl in
Bill Wade
Dick Smith
Gary Yando
Rol land Youmans
Ken Clay

Quigg Bros. - McDonald

Weyherhaeuser Co., Vice-President,
Publ ic Relations

Graystone of Grays Harbor

Phil -Rod Company

Union Oil Distributor

(Commercial Fisherman)

Port of Grays Harbor, Manager

Ocean Spray, Inc. Manager

Grays Harbor County Labor Council

Mayor of Hoquiam

Mayor of Ocean Shores

City Manager Ocean Shores

Public Works Director of Oceanshores

Mayor of Westport (and Commercial Fisherman)

Director of Public Works for Westport

Planning Director, Grays Harbor County

County Commissioner

Transportation Authority (Past Ferry
Service Oper.)

H-4

Dick Moulton Grays Harbor County Extension Agent

Al Boileau Mayor of Cosmopolis

Walt Bussard Mayor of Montesano

Shelby Warren Hill Rancher, Point New

Mr. Prickett Montesano

Mr. Clemens Montesano

Doug McGoon Department of Natural Resources.

Bob Coykendall Department of Natural Resources

Bill Stewart Daily World, Assistant Editor

H-5

APPENDIX I
SPECIES LIST

SOURCE: Westhave Cove (Westport Marina) Small Boat Basin Expansion
Draft Environmental Impact Statement, U.S. Army Corps of
Engineers, August 1978

SPECIES LIST

The following lists species found in Grays Harbor. 'Hie general
characteristics of the habitats nre briefly described in conjunction
with the bird and mammal lists for convenience. In addition to
notes on habitat, notes on feeding habits, seasonal migrations and
abundance are provided for those species.

Habitat . Four general categories are used to describe the diverse
array of bird and mammal habitats. These four habitats have been
coded in the list as follows:

RS-Rocky Shore Marine Habitat. These rocky outcrops within the
intertidal area are constantly washed by tides and waves.

SM-Salt Marsh, Mud Flat and Sand Flat Habitats. Habitat "SM"
includes highly productive marsh grasslands, mud flats, and sand
flats, all of which are strongly influenced by marine water.

FM-Freshwater Marsh and Meadow. This habitat category includes
upland meadows and marshlands influenced only by freshwater. Also
included in this category is lowland riparian, shrubs, and thickets
and borad-leaved woodland.

OG-Open Water in Grays Harbor. This category includes open
water and the large water surface within Grays Harbor.

Feeding Habits. A notation of feeding habits is given for each spe-
cies based on the type or types of food the animal customarily depends
on. There are fundamentally three major classes of food items:

1 - Class 1 foods are the vegetative parts of plants such as
leaves, stalks, bark, and twigs. Animals dependent on these food
classes are adapted to consuming large quantities of low-energy val-
ue foods, which are regularly available. Many class 1 consumers
also take class 2 foods when available.

2 - Class 2 foods are the storage parts of plants such as

roots, bulbs, tubers, seeds, and fruits. Animals dependent on class
2 food sources are adapted to seeking a food which is irregularly or
seasonally abundant and therefore depend upon a variety of plants.
Some class 2 consumers also take class 1 and 3 foods.

3 - Class 3 food items include all animal matter such as small
birds, mammals, reptiles, amphibians, fish, insects, and other high
protein food sources. Animals dependent on class 3 food items are
adapted for obtaining high energy value foods which are difficult to
capture.

1-1

Seasonality. Most birds of Grays Harbor are migrants, spending the
spring, fall or winter in the harbor. The seasonal occurrence of
the species, including mammals, is abbreviated as follows:

R - Resident: this species is present throughout the year.

S - Summer visitor with seasonal presence extending into spring
and fall.

W - Winter visitor with seasonal presence extending into spring
and fall.

M - Migrant: present only during spring and fall months.

F - Present only during fall months.

Abundance. The term "abundance" refers to the number of individuals
of a particular species in a particular habitat area. The notations
used to indicate abundance are shown under the habitat type columns
and are abbreviated as follows:

C - Common: Present within appropriate habitat in season and
may be seen by trained observers on most visits to area in question.

U - Uncommon: Present within appropriate habitat in season but
usually not seen by trained observers on every visit to area in
question.

R - Rare: Present only in small numbers in the appropriate
habitat in season and seldom seen by trained observers.

The following list of bird and mammal species has been prepared on
the basis of habitat types and a knowledge of species which frequent
such habitats. An extensive list of species was prepared by Dr.
Gordon Alcorn of the University of Puget Sound, and presented in
"Grays Harbor and Chehalis River Navigation Project, Operation and
Maintenance EIS," June 1975. Dr. Alcorn's list was used in con-
junction with the Washington Environmental Atlas— to develop the
bird list which was reviewed and corrected by members of the State
Department of Game and the Rain Forest Chapter of the Audubon Society
The lists for benthic invertebrates and fishes were derived from
the Dredging Effects Study data.

1/U.S. Army Corps of Engineers District, Seattle, Washington,
Washington Environmental Atlas, January 1975.

1-2

BIRDS

Common Name

Scientific Name

u

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Xi

>>

nJ

u

■x

•r-\

. — 1

00

03

c

c

•<-* o

Habitat Type v <$
RS SM FM OG u. $

GAVIIDAE

Common Loon

Yellow-billed Loon

Arctic Loon

Red-throated Loon
PODICIPEDIDAE

Red-necked Grebe

Horned Grebe

Eared Grebe

Western Grebe

Pied-billed Grebe
PROCELLARIIDAE

Sooty Shearwater
PELECANIDAE

Brown Pelican

PHALACROCORACIDAE

Double-crested Cormorant

Brant's Cormorant

Pelagic Cormorant
ARDEIDAE

Great Blue Heron

Green Heron

Great Egret
American Bittern
ANATIIDAE

Whistling Swan
Trumpeter Swan
Canada Goose
Black Brant
Emperor Goose
White-fronted Goose
Mallard
Gadwall
Pintail

Green-winged Teal
Blue-winged Teal
Cinnamon Teal
European Wigeon
American Wigeon
Northern Shoveler
Wood Duck
Redhead

Gavia immer
Gavia adamsii
Gavia arctica
Gavia stellata

Podiceps grisegena
Podiceps auritus
Podiceps nigricollis
Aechmorphorus

occidentalis
Polilymbus podiceps

Puf f inus griseus -

Pelecanus occidentalis
californicus

Phalacrocorax auritus
Phalacrocorax penicillatus-
Phalacrocorax pelagicus

Ardea herodias C

Butorides virescens

anthonyi
Casmerodius albus
Botaurus lentiginosus

Olor columbianus

Olor buccinator

Branta canadensis

Branta nigricans C

Philacte canagica

Anser albifrons -

Anas platyrhynchos

Anas strepera

Anas acuta

Anas crecca

Anas discors

Anas cyanoptera -

Mareca penelope

Mareca americana -

Anas clypeata

Aix sponsa

Avthya americana

C

c

c

3

R

R

-

R

3

W

C

c

c

3

w

C

c

c

3

w

C

u

c

3

w

C

u

c

3

w

C

c

c

3

w

C

c

c

3

w

C

c

u

3

w

R

- R

c

u

c

3

R

c

-

c

3

R

c

-

c

3

R

c -

R

R

u

-

3

R

U

u

-

3

S

U

c

-

3

S

u

u

—

1

W

u

u

-

1

w

c

c

c

1

M

c

-

c

1

M

R

-

-

1

W

U

u

-

1

M

C

c

u

1&2

R

C

c

u

1&2

W

C

c

u

1&2

R

c

c

u

1&2

W

u

u

-

1&2

M

u

u

-

1&2

M

R

R

-

1

W

C

c

-

1

R

C

c

-

1

R

C

c

-

1&2

W

R

R

-

1&-2

W

1-3

U

ri u

re -h

r— I

n: c

•H O

BIRDS

Common Name

Scientific Name

Habitat Type cu
RS SM

Ring-necked Duck

Canvasback

Greater Scaup

Lesser Scaup

Common Goldeneye

Barrow's Goldeneye

Bufflehead

Oldsquaw

Harlequin Duck

White-winged Scoter

Surf Scoter

Black Scoter

Ruddy Duck

Hooded Merganser

Common Merganser

Red-breasted Merganser
CATHARTIIDAE

Turkey Vulture
ACCIPITRIDAE

Sharp-shinned Hawk

Cooper's Hawk

Red-tailed Hawk

Rough-legged Hawk

Bald Eagle

Marsh Hawk
PANDIONIDAE
Osprey

FALSONIDAE

Prairie Falcon
Peregrine Falcon
Merlin
American Kestrel

TETRAONIDAE

Ruffed Grouse
PHASIANIDAE

California Quail

Ring-necked Pheasant
GRUIDAE

Sandhill Crane

Ay thy a collaris - R R -

Aythya valisineria - U U -

Ay thy a marila - C U -

Aythya af finis - C C -

Bucephala clangula C C

Bucephala islandica - C C -

Bucephala albeola - C C

Clangula hyemalis - R R -

Histrionicus histrionicus U U U

Melanitta deglandi - C C -

Melanitta perspicillata C C U C

Melanitta nigra - U - U

Oxyura jamaicensis - U - U

Lophodytes cucullatus - C C U

Mergus merganser - U C R

Mergus serrator U C C

Cathartes aura

Accipiter striatus
Accipiter cooperii
Buteo jamaicensis
Buteo lagopus

sanctijohannis
Haliaeetus leucocephalus

alascanus
Circus cyaneus hudsonius -

Pandion haliaetus
carolinensis

Falco maxicanus
Falco peregrinus
Falco columbarius
Falso sparverius
sparverius

Bonasa umbellus

Lophortyx californicus
Phasianus colchicus

Grus canadensis

U U U -

U

u
c

u

u -

u -
c -

u -

1&2

1&2

2&3

3

3

3

3

3

3

3

3

2

3

1&2

3

3

W
W
R
R
W

w
w
w

R
R
R
W
W
W
R
W

u

u -

3

R

u

u -

3

R

u

c -

3

R

R
R

R

R

R

R -

3

W

R

R

R -

3

w

-

U

U -

3

R

-

U

U -

3

R

-

R

C -

1&2

R

_

R

C -

1&2

R

-

U

C -

1&2

R

u

u -

2&3 M

1-4

Common Name

BIRDS

Scientific Name

XI ^

IT) U

tC "i-l

00 ra

c c

>H O

Habitat Type "g IS

RS SM FM OG £ £

RALLIDAE

Virginia Rail

Sora

American Coot
HAEMATOPODIDAE

Black Oystercatcher
CHARADRIIDAE

Semipalmated Plover

Snowy Plover

Killdeer

American Golden Plover
Black-bellied Plover
SCOLOPACIDAE

Ruddy Turnstone
Black Turnstone
Common Snipe

Long-billed Curlew

Whimbrel

Spotted Sandpiper
Wandering Tattler
Willet

Greater Yellowlegs

Lesser Yellowlegs

Surfbird

Red Knot

Rock Sandpiper

Sharp-tailed Sandpiper

Pectoral Sandpiper

Baird's Sandpiper

Least Sandpiper

Dunlin

Semiplated Sandpiper

Western Sandpiper

Sanderling

Short-billed Dowitcher

Long-billed Dowitcher

Stilt Sandpiper

Buff-breasted Sandpiper

Marbled Godwit

Rallus limicola
Porzana Carolina
Fulica americana

Haematopus bachmani

Charadrius semipalmatus
Charadrius alexandrinus
nivosus

Charadrius vocif erus
Pluvialis dominica
Pluvialis squatarola

Arenarius interpres
Arenarius melanocephala
•Capella gallinago

delicata
Numenius americanus

parvus

Numenius phaeopus
Actitis macularia
Heteroscelus incanus
Catoptrophorus
semipalmatus
Tringa melanoleuca
Tringa f lavipes
Aphriza virgata
Calidris canutus
Calidris ptilocnemis
Calidris acuminata
Calidris melanotos
Calidris bairdii
Calidris minutilla
Calidris alpina
Calidris pusilla
Calidris mauri
Calidris alba
Limnodromus griseus
Limnodromus scolopaceus
Micropalama himantopus
Tryngites subruf icollis
Liraosa fedoa

U
U

u

R
C

u
u

C

u

C

c
c

u

u -

R -

c c

u -

c -

R U

U -

C -

C -

c -

2&3
1&3
2&3

3

3

3
3
3
3

3

3

R
S
R

R

S

S
R
W

w

M

W

R

-

R

R

-

3

S

-

C

C

-

3

M

-

c

C

-

3

M

c

u

-

-

3

M

_

R

R

_

3

M

-

c

C

-

3

M

-

c

C

-

3

M

-

-

-

C

3

W

c

c

-

-

3

M

u

-

-

u

3

F

R

-

-

-

3

F

-

c

c

-

3

M

-

u

c

-

3

M

-

c

c

-

3

W

-

c

u

-

3

M

-

R

R

-

3

W

-

C

C

-

3

F

-

C

U

-

3

W

-

C

R

-

3

M

-

c

C

-

3

M

-

R

R

-

3

M

-

R

-

-

3

M

-

R

R

-

3

M

1-5

t/1
JJ

X>

x

c c

BIRDS

Habitat

Typ

Common Name

Scientific Name

RS

SM

FM

OG

0) QJ

PHALAROPODIDAE

Red Phalarope

Phalaropus fulicarius

-

R

-

U

3

M

Wilson's Phalarope

Steganopus tricolor

-

U

C

-

3

M

Northern Phalarope

Lobipes lobatus

-

u

C

c

3

M

STERCORARIIDAE

Parasitic Jaeger

Stercorarius parasiticus

-

-

-

c

2&3

M

Poraarine Jaeger

Stercorarius pomarinus

-

-

-

c

2&3

M

Long-tailed Jaeger

Stercorarius longicaudus

-

-

-

R

2&3

M

Skua

Catharacta skua

-

-

-

R

2&3

M

LARIDAE

Glaucous Gull

Larus hyperboreus

-

R

R

R

2&3

W

Glaucous-winged Gull

Larus glaucescens

C

c

U

-

2&3

R

Western Gull

Larus occidentalis

c

c

-

C

2&3

R

Herring Gull

Larus argentatus

-

c

u

c

2&3

W

Thayer's Gull

Larus thayeri

-

c

-

c

2&3

w

California Gull

Larus californicus

-

c

C

c

2&3

R

Ring-billed Gull

•Larus delawarensis

-

u

C

u

2&3

R

Mew Gull

Larus canus

-

c

C

c

2&3

M

Franklin's Gull

Larus pipixcan

-

R

R

R

2&3

F

Bonaparte's Gull

Larus Philadelphia

-

c

C

C

2&3

W

Herrmann's Gull

Larus heermanni

-

c

-

C

2&3

W

Black-legged Kittiwake

Rissa tridactyla

-

-

-

C

2&3

W

Sabine's Gull

Xema sabini

-

-

-

U

2&3

M

Forster's Tern

Sterna forsteri

-

R

u

R

2&3

M

Common Tern

Sterna hirundo

-

c

c

-

2&3

M

Arctic Tern

Sterna paradisaea

-

R

-

u

2&3

M

Caspian Tern

Hydroprogne caspia

-

C

u

-

2&3

S

ALCIDAE

Common Murre

Uria aalge

c

-

-

c

3

R

Pigeon Guillemot

Cepphus columba

c

-

-

c

3

R

Marbled Murrelet

Brachyramphus marmoratus

-

-

c

c

3

R

Xantus' Murrelet

Endomychura hypoleuca

-

-

-

u

3

F

Ancient Murrelet

Synthliboramphus antiquus

-

-

-

c

3

W

Cassin's Auklet

Ptychoramphus aleuticus

-

-

-

c

3

R

Parakeet Auklet

Cyclorrhynchus psittacula

-

-

-

R

3

W

Rhinoceros Auklet

Cerorhinca monocerata

-

-

-

C

3

R

Horned Puffin

Fratercula corniculata

-

-

-

R

3

R

Tufted Puffin

Lunda cirrhata

-

-

-

C

2

S

COLUMBIDAE

Band-tailed Pigeon

Columba fasciata monilis

-

-

c

-

2

S

Rock Dove

Columba livia

-

-

c

-

2

S

Mourning Dove

Zenaida macroura

marginella

-

-

u

1-6

Common Name

BIRDS

Scientific Name

m

u

■H

.0

>>

<rj

u

:n

•H

- — i

DO

01

r.

c

•h

0

•0

(/I

Habitat Type <u <n
RS SM FM OG £ $

TYTONIDAE

Barn Owl
STRIGIDAE

Screech Owl

Great Horned Owl

Snowy Owl

Pygmy Owl

Burrowing Owl

Spotted Owl

Great Gray Owl
Long-eared Owl
Short-eared Owl
Saw- whet Owl

CAPRIMULGIDAE

Common Nighthawk

APODIDAE

Black Swift
Vaux's Swift

TROCHILIDAE

Anna's Hummingbird
Rufeous Hummingbird
Calliope Hummingbird

ALCEDINIDAE

Belted Kingfisher

PICIDAE

Common Flicker
Pileated Woodpecker
Yellow-bellied Sapsucker
Hairy Woodpecker
Downy Woodpecker

TYRANNIDAE

Willow Flycatcher
Hammond's Flycatcher
Western Flycatcbcr
Western Wood Pewec
Olive-sided Flycatcher

ALAUDIDAE
Horned Lark

HIRUNDINIDAE

Violet-green Swallow
Tree Swallow

Tyto alba pratincola

Otus asio
Bubo virginianus
Nyctea scandiaca
Glaucidium gnoma
Speotyto cunicularia

hypugaea
Strix occidentalis

caurina

Strix nebulosa nebulosa
Asio otus
Asio f lammeus
Aegolius acadicus

Chordeiles minor

Cypseloides niger
Chaetura vauxi

Calypte anna
Selasphorus ruf us
Stellula calliope

Megaceryle alcyon

Colaptes auratus
Dryocopus pileatus
Sphyrapicus varius
Dendrocopos villosus
Dendrocopos pubescens

Empidonax traillii
Empidonax hammondii
Empidonax difficilis
Cent opus sordidulus
Nuttallornis borealis

Eremophila alpestris

Tachycineta thalassina
Iridoprocne bicolor

R

U

R
R

U -

R -

C -

R -

R -

U U -

C -

C -

U

c

C
C

c

u

R
C

c

C

c
c

u
u

u

c
c

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R
R
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R

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R

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R

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2&3 W

2&3 S

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2&3 R

2&3 R

2&3 R

2&3 R

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1-7

BIRDS

Common Name

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Habitat Type <u m

Scientific Name

RS SM

FM OG £ £

Barn Swallow

Cliff Swallow

Purple Martin
CO RV I DAE

Gray Jay

Stellar's Jay

Common Raven

Common Crow
PARIDAE

Black-capped Chickadee

Mountain Chickadee

Chestnut-backed Chickadee

Bushtit
SITTIDAE

White-breasted Nuthatch

Red-breasted Nuthatch
CERTHIIDAE

Brown Creeper
CINCLIDAE

Dipper
TROGLODYTIDAE

House Wren

Winter Wren

Bewick's Wren

Long-billed Marsh Wren
TURDIDAE

American Robin

Varied Thrush

Hermit Thrush

Swainson's Thrush

Western Bluebird

Townsend's Solitaire
SYLVIIDAE

Golden-crowned Kinglet

Ruby-crowned Kinglet
MOTACILLIDAE

Water Pipit
BOMBYCILLIDAE

Bohemian Waxwing

Cedar Waxwing
LAN I I DAE

Northern Shrike
STURNIDAE

Hirundo rustica

Petrochelidon pyrrhonota
Progne subis subis

Perisoreus canadensis
Cyanocitta stelleri
Crovus corax
Corvus brachyrhynchos

Parus stricapillus
Parus gambeli
Parus rufescens
Psaltriparus minimum

Sitta carolinensis
Sitta canadensis

Certhia familiaris

Cinclus tnexicanus

Troglodytes aedon
Troglodytes troglodytes
Thryomanes bewickii
Telmatodytes palustris

Turdus migratorius
Ixoreus naevius
Catharus guttatus
Catharus ustulatus
Sialia mexicana

occidentalis
Myadestes townsendi

Regulus satrapa
Regulus calendula

Anthus spinoletta

Bombycilla garrulus
Bombycilla cedrorum

Lanius excubitor

-

u

c

-

3

S

-

-

c

-

3

S

-

u

c

-

3

S

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—

u

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R

-

R

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-

2&3

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u

u

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c

c

c

-

2&3

R

-

-

c

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2&3

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-

-

R

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2&3

R

-

-

u

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-

-

c

-

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u -

c -

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c -

u u -

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R

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S

c -

3

R

c -

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R

c -

3

R

c -

3

R

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3

R

c -

3

R

c -

3

S

u -

3

S

u -

3

R

c -

3

R

c -

3

R

M

W
R

W

1-8

Common Name

BIRDS

Scientific Name

u

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nj

u

X

•,-i

i— i

co

ctl

c

c

•r-l

o

Habitat Type S

in
to

RS SM FM OG u!

CO

Starling
VIREONIDAE

Hutton's Vireo

Solitary Vireo

Red-eyed Vireo

Warbling Vireo
PARULIDAE

Orange-crowned Warbler

Yellow Warbler

Yellow-rumped Warbler

Black-throated Gray
Warbler

Towns end ' s War b ler

MacGillivray 's Warbler

Common Yellowthroat

Wilson's Warbler
PLOCEIDAE

House Sparrow
ICTERIDAE

Western Meadowlark

Red-winged Blackbird

Brewer's Blackcird

Brown-headed Cowbird
THRAUPIDAE

Western Tanager
FRINGILLIDAE

Evening Grosbeak

Purple Finch

House Finch

Pine Siskin

American Goldfinch

Rufous-sided Towhee

Savannah Sparrow

Dark-eyed Junco

Chipping Sparrow

Golden-crowned Sparrow

Lincoln's Sparrow

Fox Sparrow

Song Sparrow

Lapland Longspur

Snow Bunting

Sturnus vulgaris

Vireo button!
Vireo solitarius
Vireo olivaceus
Vireo gilvus

Vermivora celata
Dendroica petechia
Dendroica coronata

Dendroica nigrescens
Dendroica townsendi
Oporornis tolmiei
Geothlypis trichas
Wilsonia pusilla

Passer domesticus

Sturnella neglecta
Agelaius phoeniceus
Euphagus cyanocephalus
Molothrus ater

Piranga ludoviciana

Hesperiphona vespertina
Carpodacus purpureus
Carpodacus mexicanus
Spinus pinus
Spinus tristis
Pipilo erythrophthalmus
Passerculus sandwichensis
Junco hyemalis
Spizella passerina
Zonotrichia atricapilla
Melospiza lincolnii
Passerella iliaca
Melospiza melodia
Calcarius lapponicus
Plectrophenax nivalis

U

C -

R

u

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3

R

u

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3

S

c

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S

c

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S

c

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c -

c -

2&3

R

c -

2&3

R

c -

2&3

R

c -

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S

c
c
c
c
c
c
c
c
c
c
c
c
c
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c

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2

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R

2

R

2&3

R

2

R

2&3

R

2&3

S

2

S

2

W

2&3

M

2&3

R

2&3

M

2&3

R

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1-9

Common Name

MAMMALS

Scientific Name

Habitat Type
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DIDELPHIDAE (ORDER MARSUPIALTA)

Didelphis virginiana

Sorex

cinereus

Sorex

trowbridge

Sorex

vagrans

Sorex

obscurus

Sorex

palustris

Sorex

bendirei

Neurotrichus gibbsi

Scapanus townsendi

Virginia opossum
SORICIDAE (ORDER INSECTIVORA)

Masked shrew

Trowbridges shrew

Vagrant shrew

Dusky shrew

Northern water shrew

Marsh shrew
TALPIDAE

Shrew mole

Townsend's mole

Coast mole
VESPERTILIONIDAE
(Note: Data on bats in Washington are limited, and
exists as to species. Most bats in the state can be
and western Washington. Probably most of the more c
found in the Grays Harbor area.)
LEPORIDAE (ORDER LAGOMORPHA)

Snowshoe Hare Lepus americanus

APLODONTIDAE (ORDER RODENTIA)

Aplondantia
SCIURIDAE

Townsend's chipmunk

Chickaree

C -

2+3 R

Scapanus orarius
(ORDER CHIROPTERA)

u -

2+3

R

R -

2+3

R

C -

2+3

R

U -

2+3

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U -

3

R

C -

3

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R

u -

2+3

R

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considerable controversy

found in both eastern
ommon species would be

Aplodontia ruf a
Eutamias townsendi

Northern flying squirrel
GEOMYIDAE

Western pocket gopher
CASTORIDAE

Beaver
CRICETIDAE

Deer mouse

Bushytail woodrat

Boreal redback vole

Townsend vole

Longtail vole

Oregon vole

Muskrat
ZAPODIDAE

Pacific jumping mouse
ERETHIZONTIDAE

Porcupine
MYOCASTORIDAE

Nutria

Tamiasciurus douglasi
Glauf omys sabrinus

Thomomys mazama

Castor canadenisis

Peromyscus maniculatus
Neotoma cinerea
Clethrionomys gapperi
Microtus townsendi
Microtus longicandus
Microtus oregoni
Ondatra zibethlca

Zapus trinotatus

Erethizon dorsutum

Myocastor caypus

c

c -

1

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c -

1

R

—

c -

2

R

-

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2

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--

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2

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c

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2

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R

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1+2

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1+2

R

c

c -

1

R

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1-10

MAMMALS

Common Name

Scientific Name

Habitat Type <u
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,Q

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(ORDER CETACEA)

DESOGUBUDAE

Striped porpoise

Common dolphin

Killer whale

Harbor porpoise
ESCHRICHTIDAE

Gray Whale
URSIDAE (ORDER CARNIVORA)

Black bear

Stenella caerulevalba

Delphinus

delphas

Orcinus orca

Phocoena

phocoena

Eschricht

ius robustus

Ursus americanus

PROCYONIDAE

Racoon
MUSTELIDAE

Shorttail weasel

Longtail weasel

Mink

River otter

Spotted skunk

Striped skunk
CANIDAE

Coyote

Common red fox
FELIDAE

Mountain lion

Bobcat Lynx rufus

OTARIIDAE (ORDER PINNIPEDIAT

Steller sea lion Eumetopias jubatus

PHOCIDAE

Harbor seal Phoca vitulina richardi

Elephant seal Miroungu angustirostria

CERVIDAE (ORDER ARTIODACTYLA)

Columbia blacktail deer Odocoileus hemionus

columbianus

Procyon lotor

Mustela erminea
Mustela f renata
Mustela vision
Lutra canadensis
Spilogak putorius
Mephitis mephitis

Canis latrans
Vulpes vulpes fulva

Felis concolor

-

u

u

-

u

u

c

u

c

u

R

R

-

-

c

-

-

c

—

u

c

-

-

u

—

—

R

-

-

U

c

R

R

C
R

u

3

R

u

3

R

c

3

R

c

3

R

- u

R -

- U

- c

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C -

3 M

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&3

2+3 R

3

R

3

R

3

R

3

R

2+3

R

2+3

R

2+3

R

2+3

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3

R

3

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M

R

M

1-11

PARTIAL SPECIES LIST OF BENTHIC INVERTEBRATES FOR GRAYS HARBOR

1974-1975

CTENOPHORA
Nuda

Beroe sp. ?
NEMERTEA
Enopia

Heteronemertea

Amphiporus sp. 1 (imparispinosis?)
Amphiporus sp. 2
Paranemertes sp.
ACANTHOCEPHALON

Found in fish stomachs (starry flounder)
Found attached to Corophim stimpsoni
ANNELIDA

Oligochaeta

Tubificidae

Peloscolex gabriellae
Enchy traeidae

Enchytraeus sp. 1
Enchytraeus sp. 2
Naididae

Naididae sp. 1
Polychaeta

Arenicolidae

Abarenicola pacif icia
Arapharetidae

Amphicteis mucronata
Anobothrus gracilis
Capitellidae

Capitella capitata
Capitellid '6'
Heteromastus f ilif ormis
Mediomastus calif orniensis
Notoraastus tenuis

Cirratulidae

Cirratulus sp .
Goniadidae

Glycinde armigera
Nephtyidae

Nephtys caeca

Nephtys ferruginea
Nereidae

Nereis brandti

Nereis sp.

Nereis vexillosa

Nereis virens

1-12

Orbiniidae

Haploscolopolos sp .

Scolopolos armlger
Ophelidae

Armandia bioculata

Ophelia asslmilis
Phyllodocidae

Eteone longa
Polynoidae

Harmothoe imbricata

Hesperonoe complanata
Sabellidae

Fabricia sabella

Manayunkia sp .
Sigalionidae

Pholoe minuta
Spionidae

Polydora ligni

Pseudopolydora kempi japonica

Pygospio elegans

Pygospio sp_.

Rhyncospio arenicola

Spio f ilicornis

Spiophanes sp .

Streblospio benedicti
Syllidae

Brania brevipharyngea

Sphaerosyllis pirifera

Syllis sp.

Trypanosyllis sp .

Unidentified Syllidae
MOLLUSCA

Pelecypoda

Eulamellibranchia
Cardiidae

Clinocardium nuttallli
Mactridae

Tresus capax
Myidae

My a arenaria

Cryptomya californica
Ostreidae

Crassostrea gigas
Solenidae

Siliqua patula
Tellinidae

Ma coma inconspicua

Macoma nasuta

Tellina nuculoides (salraonea)

1-13

Veneridae

Protothaca staminea
Tapes japonica
Saxidomas giganteus
Filibranchia
Mytellidae

Modiolus rectus
Mytilus californianus
Mytilus edulis
Gastropoda

Nacticidae

Polinices draconis
Nassariidae

Nassarius perpingus
ECHINODERMATA
Asteroidea

Pisaster ochraceus
ARTHROPODA

Crustacea

Ostracoda

Unidentified ostracod
Copepoda

Clausidium Vancouver ens is
Diaptemous sp.
Cirripedia

Thoracica

Balanus glandula
Lepas anatifera
Rhizocephala

Unidentified genus: Parasitic on Corophium
Unidentified genus: Parasitic on Callianassa
May be Ellobiopsid
Malacostraca
Pericarida

Mysidaces

Archaeomysis grevnitzskii
Mysis oculata?
Neomysis mercedis
Cumacea

Eudorella sp.
Eurodorella sp .
Diastylis sp.

Lamprops, Hemilamprops , or Mesoprops sp .
Leptocuma sp .
Tanaidaces

Leptochelia savignyi
Pancolus californiensis

1-14

Isopoda

Valvifera

Idotea (Idotea) fewko.si

Idotea (Idotea) rufescens

Idotea (Penldotea) resecata

Idotea (Penidotea) wosnesenskii

Saduria entoraon
Flabellifera

Aegidae sp.

Cirolana kincaidi

Gnorismosphaeroma oregonensis
Epicaridea

Argeia pugettensis

Bopyrus sp.
Oniscoidea

Lygidia palsaii
Amphipoda

Gammaridea

Allorchestes angusta

Amphithoe sp.

Anisogammarus confervicolus

Ceradocus spinicaudus

Corophium acherusicum

Corophium oaklandense

Corophium spinicorne

Corophium stimpsoni (later identified as C. salmonis)

Dogielinotus loquax

Eohaustorius sp .

Hyale ancepts

Hand ibu lop hoxus gilesi

Orchestia traskiana

Orchestoidea pugettensis

Orchomene pacif ica

Paraphoxus milleri

Photis brevipes

Pontogeneia inermis
Caprellidea

Caprella borealis

Caprella californica

Caprella incisa
Eucarida

Decapoda

Notantia

Caridea
Crangonidae

Crangon alba
Crangon f ranciscorum
Crangon nigricauda
Reptantia

Astacura

Thallasinoidea

Callianassidae

1-15

Callianassa calif orniensis
Upogebia pugettensis
Brachyura

Brachygnatha

Brachyrhyncha

Cancer magister
Cancer oregonensis
Cancer productus
HemigLapsus nudus
Hemigrapsuoregonensis
Insecta

Collembola

Arthropleona

Anurida Maritima
Diptera

Aphrosylus sp.
Saunderia sp.
HEMICHORDATA

Enteropneusta

Unidentified genus

SOURCE: Appendix E, Maintenance Dredging and the Environment of
Grays Harbor.

1-16

SPECIES COMPOSITION OF FISHES IN GRAYS HARBOR

Petrorayzontidae - lampreys

*Pacific lamprey - Lampetra tridentata

Squalidae - dogfish sharks

Spiny dogfish - Squalus acanthias

Rajidae - skates

Big skate - Raja binoculata

Acipenseridae - sturgeons

White sturgeon - Acipenser transmontanus
Green sturgeon - Acipenser medirostris

Clupeidae - herrings

American shad - Alosa sapidissima
Pacific herring - Clupea harengus pallasi
Pacific sardine - Sarinops sagax

Engraulidae - anchovies

Northern anchovy - Engraulis mordax

Salraonidae - salmon, trout, and char
Chum salmon - Oncorphynchus keta
Coho salmon - Oncorphynchus kisutch
*Chinook salmon - Oncorphynchus tshawytscha
^Cutthroat trout - Salmo clarki
*Steelhead trout - Salmo gairdneri
Dolly Varden - Salvelinus malma

Osmeridae - smelts

Surf smelt - Hypomesus pretiosus
Longfin smelt - Spirinchus dilatus
*Eulachon - Thaleichthys pacificus

Cyprinidae - minnows

*Peamouth - Mylocheilus caurinus

Northern squawfish - Ptychocheilus oregonensis

Gadidae - codfishes

Pacific tomcod - Microgadus proximus

Atherinidae - silversides

Topsmelt - Atherinops affinls affinis

1-17

Gasterosteidae - sticklebacks

Threespined stickleback - Gasterosteus aculeatus

Syngnathidae - pipefishes

Bay pipefish - Syngnathus griseolineatus

Embiotocidae - surfperches

Redtail surfperch - Amphistichus rhodoterus
Shiner perch - Cymatogaster cgg-egate
Striped seaperch - Embiotoca lateralis
Walleye surfperch - Hyperprosopon argenteum
Silver surfperch - Hyperprosopon ellipticum
White seaperch - Phanerodon furcatus
Pile perch - Rhacochilus vacca

Pholidae - gunnels

Saddleback gunnel - Pholls ornata

Aramodytidae - sand lances

Pacific sand lance - Ammodytes hexapterus

Gabiidae - gobies

Arrow goby - Clevelandia ios

Hexagrammidae - greenlings

Kelp greenling - Hexagrammos decagrammus
Masked greenling - Hexagrammos octogrammus
Lingcod - Ophiodon elongatus

*Scorpaenidae - rockfishes

Black rockfish - Sebastodes melanops

Cottidae - sculpins

^Prickly sculpin - Cottus asper

Pacific staghorn sculpin - Leptocottus armatus

Padded sculpin - Antedius fenestrailis

Buffalo sculpin - Enophrys bison

Cabezon - Scorpaenichthys marmoratus

Stickaeidae - pricklebacks

Snake prickleback - Lumpenus sagitta

Agonidae - poachers

Sturgeon poacher - Agonus acipenserinus
Wartysea poacher - Occa verrucosa

Cyclopteridae - lumpfishes and snailfishes

Blacktail snail fish - Careproctus melanurus

I-ll

Bothidae - lefteyed flounders

Pacific sanddab - Citharichthys sordidus

Pleuronectidae - righteyed flounders

English sole - Parophyrys vetulus
Starry flounder - Platichthys stellatus
Sand Sole - Psettichthys melanostictus

*taken by Deschamps and Wright (1970) but did not appear in 1973
sampling.

Source: Appendix G, Maintenance Dredging and the Environment of
Grays Harbor.

1-19

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