We are now facing enormous nearshore developments in Budd Inlet. On the West Side, West Bay Development Group wants to develop 478 market-rate apartments and more than 20,000 square feet of commercial space at the old Hardel site. On the East Side, The Port of Olympia is planning administrative buildings, mixed use, hotels, retail and other waterfront structures. This scale of development along the shoreline will impede ecological function, reduce opportunities for cleanup of legacy contamination and greatly reduce restoration potential.
Stopping any of these is going to be difficult because the City has pulled its own regulatory teeth. Coincidentally, the City’s Shoreline Master Program (SMP) is currently under Periodic Review and comments will be accepted.
The SMP is dominated by make believe. There’s no dioxin contamination, there are no stream estuaries or other ecological structure, and good science is sorely lacking. And where it might count, the SMP is ignored.
A. Dioxin is the most biologically damaging non-radioactive substance known. It is present in Budd Inlet sediments in concentrations that exceed every threshold and continues to flow into the bay from undetermined sources. The Olympia Shoreline Master Program (SMP) barely mentions this most significant problem. In the early 1980s 1.1 million cubic yards of contaminated sediments were dredged from in front of Cascade Pole and used as fill along the eastern side of the Port Peninsula, adjoining East Bay. Dredge spoils since have gone into a containment cell with steel sheet piling and slurry walls that will inevitably fail.
The Sediment Characterization Study, dated 2008, page 20, is an aerial showing the dioxin hotspots just northeast of the Hardel Site and at the southeast corner of East Bay. Surface contamination is generally an indication of an ongoing source. We should, after 12 years, have identified these sources. The Budd Inlet Sediment Dioxin Source Study dated March of 2016 does not attempt to locate specific sources or pathways of dioxin hotspots.
B. East Bay has the poorest water quality in Budd Inlet. It fails for virtually every parameter including bacteria, temperature, dissolved oxygen, fine sediment and nutrient loading. These failures are directly related to loss of ecological function through dredging and filling the bay and running its tributaries through long culverts.
One of the stated goals of the SMP is “To ensure, at a minimum, no net loss of shoreline ecological functions and processes and to plan for restoring shorelines that have been impaired or degraded by adopting and fostering the policy contained in RCW 90.58.020,” Where has this ever happened?
The SMP suggests four improvements for East Bay:
1. “Plant 2,300 linear feet of shoreline to create a functional riparian zone”. No mention of what is meant by planting “shoreline”, no mention of species. And no explanation as to how planting shoreline will “create and functional riparian zone” or provide “ecological function”.
2. “Reconstruct the mouth of Indian/Moxlie Creek and estuary”. No explanation of what this means. I’d hypothesize that Daylighting the estuary out of its half mile long culvert is the only way to do it. Once again, where’s the science?
3. Plant approximately 1,500 feet of nearshore riparian vegetation along East Bay Drive”. Is this part of number 1 or something additional?
4. Plant approximately 4,200 linear feet of riparian vegetation. 1, 3 and 4 all seem to be part of the same effort. They total 8000 linear feet and the Port doesn’t have 8000 linear feet available for this kind of thing.
Allowed building setbacks are 30 feet from the high water mark. Given that some of this is riprap and other armoring and waterfront trails and other features, the width of planting will be less. Riparian buffers composed of vegetation become effective at somewhere between 16ft and 1920 ft of width depending on site characteristics and the nature of contaminants. Given the critical nature of estuarine environments, we might hope for the higher number.
The riparian buffer does not exist in a vacuum. In marine nearshore environments where beaches are fringed with riparian vegetation, the upper intertidal wrack zone accumulates organic debris from algae, seagrass, and terrestrial plants and provides food and shelter for many organisms. Armored beaches have substantially less organic matter and ecological connectivity. A narrow riparian planting will do little if placed on top of a pile of rock.
There’s some discussion of bulkhead removal and replacement of hardened shoreline with soft structural stabilization measures “water‐ward of Ordinary High Water Mark (OHWM) where appropriate”. The long culverts of Moxlie and Schneider Creeks are intertidal. Both are water-ward of the high water mark.
C. No science.
a. There’s no classic scientific inquiry, the clear statement of observation> hypothesis> test> conclusion.
b. There’s no analysis of primary production and no analysis of the impacts of physical parameters on chemical and biological production.
D. The SMP is ignored in practice where it would count.
Under 2.34 Restoration and Enhancement Policies:
“A. Olympia recognizes the importance of restoration of shoreline ecological functions and processes and encourages cooperative restoration efforts and programs… to address shorelines with impaired ecological functions and processes”. Really?
“B. Restoration actions should restore shoreline ecological functions and processes as well as shoreline features and should be targeted towards meeting the needs of sensitive and/or locally important plant, fish and wildlife species as well as the biologic recovery goals for State and federally listed species and populations” Sounds good. Never happens.
“F. Incorporate restoration and enhancement measures into the design and construction of new uses and development, public infrastructure (e.g., roads, utilities), and public recreation facilities”. Never happens.
“G. Shoreline restoration and enhancement should be considered as an alternative to structural stabilization and protection measures where feasible”. Never happens.
“M. Restoration and enhancement projects may include shoreline modification actions provided the primary purpose of such actions is clearly restoration of the natural character and ecological functions of the shoreline”. A dream.
Under appendix June 12, 2012
“To meet current Shoreline Master Program requirements, at a minimum the Restoration Plan must consider and address the following subjects (WAC 173‐26‐201(2)(f)): Identify degraded areas, impaired ecological functions, and sites with potential for ecological restoration; Establish overall goals and priorities for restoration of degraded areas and impaired ecological functions.. the Restoration Plan is intended to identify shoreline, or areas upland that impact shorelines, that need to be restored to a healthy and functioning condition. The Plan is for the purpose of identifying potential projects and programs that would contribute or achieve restoration for those degraded areas”. Where? When?
“Salmon have been confirmed in Mission, Moxlie, and Schneider Creeks, which all empty into Budd Inlet”. That’s it?
“When prioritizing restoration actions, the City will give highest priority to measures that have the greatest chance of re‐establishing shoreline ecological functions and processes.” This would be restoring estuaries.
“Reconnect Fish Passage to Budd Inlet, and Restore Mouths of Tributary Streams. Expanding available fish habitat and spawning opportunities for fish is a high priority. Perhaps the most frequently encountered fish passage barriers are culverts that are improperly designed, installed, or maintained, and channel alterations that result in impassable conditions (Harry & Konovsky 1999)”. All talk no action.
“Ongoing or recommended restoration projects or programs that would restore and improve fish passage and mouths of tributary streams include”: At this point we might expect to see a list of “restoration projects and programs” but what we see is a list of non-profit and other groups.
“Critical Areas regulations in effect on October 1, 2013, contained in the Olympia Municipal Code (OMC) Chapter 18.32 and 16.70, require “that current and potential ecological functions be identified and understood when evaluating new or expanded uses and developments”, that “adverse impacts to be mitigated in a manner that ensures no net loss of shoreline ecological functions” and that this “shall include avoidance as a first priority” and that there be “incentives to restore shoreline ecological functions where such functions have been degraded by past actions”. Once again it never happens.
“The protection, restoration and enhancement of shoreline ecological functions and system‐wide processes, especially as they pertain to the long‐term health of Budd Inlet, are high priorities of Olympia’s Shoreline Program”. How’s that?
Ecology states:: “In regards to scientific data and ecological functions, protection of the shoreline environment is an essential statewide policy goal, consistent with the other policy goals of the Shoreline Management Act (Act). To satisfy the requirements for the use of scientific and technical information in RCW 90.58.100(l), the Guidelines require local governments to identiff and assemble the most curent, accurate, and complete scientific and technical information available, and to base their Master Program provisions on an analysis that incorporates this information. WAC I73-26-201(2)(a) states that local governments should be prepared to identif three things: the scientific information and management recommendations on which the Master Program provisions are based; assumptions made concerning and data gaps in the scientific information; and risks to ecological functions associated with Master Program provisions fthrough the process identified in WAC 113-26-201(3Xd)]….”when determining allowable uses and lesolving use conflicts on shorelines”, local governments must apply the following preferences and priorities in the order listed below: Number one (i) Protect and restoring ecological functions…” Olympia is not complying with these provisions.