Activity Report Explorer

Cascade Volcanoes • Entered by Barb Fox-Kilgore on October 25, 2022

Petition and comment Writing

October 25, 2022 – October 25, 2022

Key Issue: Wildlife Protection
Activity Type: Advocacy (rallies, lobbying, meeting decision makers, letters/calls/emails)
Key Partners: Washington Environmental Council

Short Description of Activity

LETTER TO STATE BUILDING CODE COUNCIL:

Dear Members of the Fish and Wildlife Commission,

Thank you for the opportunity to provide comments on Washington Department of Fish and Wildlife’s (WDFW) Rule Proposal to incorporate SSB 5273 into the Hydraulic Code. We the undersigned urge you to adopt strong protections for salmon habitat, beginning with better practices for residential shoreline armoring.

As SSB 5273 identifies, coastal ecosystems are under significant pressure from climate change, including sea level rise, acidification, warming temperatures, and other impacts. Hard shoreline armor limits the ability of plant and animal communities to move landward as sea levels rise, significantly reducing adaptation potential. Armoring can worsen the beach erosion it aims to prevent, which may accelerate the impacts of sea level rise on adjacent shorelines and structures. Removing and softening shoreline stabilization structures where possible is an important aspect of enhancing the resilience of coastal ecosystems to climate change and protecting and improving salmon habitat.

We strongly support WDFW’s work to update the Hydraulic Code, and we identified changes in the proposed rule that would ensure that avoiding harm must be more than a paper exercise. This is consistent with the direction from the legislature to use the least impacting alternative when replacing marine shoreline stabilization structures to protect fish life.

First, WDFW must reinforce that the preferred option is avoiding stabilizing shorelines first and foremost if the action is not needed, which is consistent with the direction from the legislature. Specific edits are needed to Section 3 of the proposed rule:

Section (3)(a) First sentence should read: “To ensure the protection of fish life, a person must use the least impacting technically feasible shoreline stabilization alternative, if stabilization techniques are deemed necessary.”
Section (3)(a) Last sentence should read: “A person should propose a hard armor technique only after considering site characteristics such as the threat to major improvements, wave energy, and other factors in an alternatives analysis, and determining that the proposed technique is necessary given the site characteristics.”
Second, Section 4 needs to reinforce that designing shoreline stabilization techniques must be based on sea level rise, since sea level rise may exacerbate erosion at the base of bulkheads that may undermine footing and cause the bulkhead to topple.

Thank you to the Fish and Wildlife Commission for your work to protect salmon habitat for future generations. We work hard to pass strong environmental laws to protect and improve shorelines for decades, and adopting the above changes will strengthen how these laws are implemented.

Reflection/Evaluation

Put my input in. Hopefully many voices will make a difference