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HomeMy WebLinkAboutHMP Bulkhead - HMP Habitat Managment Plan - 1/21/2009 1 Habitat Management Plan Todd Bulkhead Project Harstine Island, Washington For: Donna Todd 771 E Windjammer Cir Shelton,WA 98584-9498 Prepared by: BioResources,LLC Kim Schaumburg Fisheries biologist,University of Washington, 1981 10112 Bay View Rd. KPN Vaughn,WA, 98394 (253) 884-5776 or 225-2973 Email: kimberly035*centurytel.net January 21,2009 Todd Habitat Management Plan 2 Table of Contents I. Project Description A. Project Location........................................................................ 3 B. Project Description..................................................................... 3-4 C. Action Area.............................................................................. 4-5 II. Species and Habitat Information A. Species and Habitat Information..................................................... 5 B. Federal Threatened and Endangered Species Puget Sound Chinook Salmon ESU..................................................... 6-7 Puget Sound Steelhead ESU............................................................... 7 Leatherback Turtle.......................................................................... 8 HumpbackWhale............................................................................ 8 KillerWhale................................................................................... 8 StellerSea Lion............................................................................... 8-9 BullTrout..................................................................................... 9-10 MarbledMurrelet............................................................................. 10 ForageFish.................................................................................... 10-11 C. Survey Results........................................................................... 11 D. Existing Environmental Conditions................................................... 11-12 III. Effects of the Action A. Direct Effects............................................................................ 12-13 B. Indirect Effects........................................................................... 13-15 C. Cumulative Effects....................................................................... 15 D. Take Analysis............................................................................. 15 E. Conservation Measures.................................................................. 15-16 F. Determination of Effect.................................................................. 16 IV. References............................................................ ...........................17-19 List of Attachments 1. Project location................................................................................. 20 2. Site plan......................................................................................... 21 3. Cross Section.................................................................................. . 22 4. Site Photograph....................................................................... .......... 23 5. Site Photograph.................................................................................. 24 Todd Habitat Management Plan 3 I. Project Description A. Project Location Section 19,Township 21N, Range 01 W WRIA 14 Tax Parcel#121195700044 771 E Windjammer Cir, Harstine Island(Attachment 1) B. Project Description This Mason County Habitat Management Plan has been submitted on behalf of Donna Todd to facilitate approval of a proposed project to construct approximately 110 feet of rock bulkhead along the shoreline that fronts her Harstine Island property(Attachment 2 &3). The parcel is located on Case Inlet and is part of the Harstene Pointe gated community,which owns the shoreline frontage. Winter storms in December of 2007&2008 have resulted in moderate erosion(mass wasting)to the medium-bank bluff at the site(Attachment 4& 5),endangering the applicant's single-family residence. The structure is located approximately 26 feet from the edge of the bluff and 31 feet from the toe of the beach at the proposed project site. The bank slope varies between approximately 70 to 90 degrees. The bluff crest is approximately 12 to 20 feet above the beach. Several small slides have deposited vegetation and sediments, including sand,gravel,clay,and cobble onto the beach. Several large native conifers along the bluff crest are also endangered. The proposed bulkhead shall be constructed of large angular rock, landward of the toe of the beach and the bluff,along approximately 110 lineal feet of frontage. The bulkhead shall be backed by filter fabric and 4 to 8 inch quarry spalls. Base rock shall be keyed into the ground a minimum or 18 to 24 inches below the existing beach grade, with the maximum height to be approximately 5 feet above the existing grade. The entire length of the bulkhead shall be constructed landward of MHHW and any slide sediments or vegetation that has been deposited on the beach. After construction is completed,existing pieces of large woody debris shall be anchored both perpendicular and parallel to the bulkhead in order to replicate natural conditions and provide habitat for juvenile salmonids. In addition,appropriate sized forage fish spawning gravel may be spread along the toe of the bulkhead,as per the HPA provisions from the Washington Department of Fish and Wildlife. All bulkhead equipment and materials will be barged to the site. The equipment will consist of two track excavators and various hand tools. Existing native vegetation shall be preserved wherever feasible(i.e. vegetation that has slid down the bluff is probably not salvageable). The WDFW's construction requirements(WAC 220-110-285)shall be strictly adhered to: (1)use of machinery on the beach will be limited to daylight hours and confined to a 25-foot wide corridor immediately waterward of the new bulkhead face or within the stockpile area,whichever is greater. The department may permit rock to be stockpiled within fifty feet of the new bulkhead face; (2)work at the site will take place during the allowed work windows for the protection of sand lance, surf smelt,and juvenile salmonids; (3)work will not occur when the project area, Todd Habitat Management Plan 4 including the work corridor(excluding the area occupied by a grounded barge), is inundated by tidal waters,or when tidal waters are within 30-feet of the bulkhead face; (4)excavated material will be placed within the designated work corridor and covered to prevent erosion. Excavated materials containing silt,clay,or fine-grained soil shall not be stockpiled below the ordinary high water line; (5)all trenches,depressions and/or holes created in the beach will be backfilled prior to inundation by tidal waters. Trenches excavated for the placement of the base rocks can remain open during construction, but fish must be prevented from entering the trenches(the turbidity barrier will help to fulfill this requirement); and(6)the appropriate sized forage fish spawning gravel will be spread on the beach following construction(as per the HPA provisions). Work on the project is tentatively scheduled to begin after the receipt of all required permits and approvals. Work will be completed in less than 14 days during daylight working hours normal to a rural residential neighborhood. In order to maintain the present water quality of Case Inlet during bulkhead construction, Best Management Practices will be implemented. BMP's are defined as physical, structural, and/or managerial practices that prevent or reduce the pollution of water(WSDE). The following applicable BMP's shall be used to insure that water quality is not degraded by erosion and sedimentation from rainfall at the site. 1)All existing native vegetation shall be preserved except where required to be removed for construction purposes. 2) Equipment shall be cleaned and checked for leaks, offsite and daily, before commencing work. 3) Large angular rock shall be clean before being placed on the shoreline. The following Spill Prevention Control measures shall also be followed: ])The contractor will supply the site with a portable bathroom so that solid waste will not become a source of stormwater pollution. 2)The contractor shall be responsible for alerting the appropriate authorities in the event of a hazardous spill. 3)The contractor shall be able to perform basic control,containment,and/or confinement operations within the capabilities of the resources and personnel protective equipment available. In other words, small spills, such as paint or oil, shall be promptly and fully collected and disposed of at a suitable disposal site. In the event of a significant spill,a fish kill,and/or if fish are observed in distress the Washington State Department of Ecology(800.258.5990)and the Washington State Department of Fish and Wildlife's Area Habitat Biologist, Margie Shirato(360.427.2179), shall be notified immediately. C. Action Area The action area is located on the shoreline of Case Inlet on Harstine Island at the proposed project site. Besides the proposed project location,the action area includes the area within a one-mile radius of the site in order to account for construction related noise that may affect species listed under the Endangered Species Act by the U.S. Fish and Wildlife Service as either endangered or threatened; specifically,nesting or foraging marbled murrelets, Steller sea lions, killer whales, and humpback whales. Several small Harstine Island streams that empty into Case Inlet and a manmade lagoon south of the site are part of the action area. The action area also includes the marine environment within a one-mile radius, in order to account for littoral drift. At high tide the disturbed substrate in the construction area will come into contact with water,resulting in increased turbidity and sedimentation that may impact listed fish. Site-specific conditions, including sand and pea gravel with some cobble at higher tidal Todd Habitat Management Plan 5 elevations and gravel at lower elevations are expected to result in moderate turbidity that will be confined to a localized corridor along the shoreline. A northeasterly drift pattern emerges from the primary drift cell in the area, MA-14-11 (WSDE 2002). The Washington State Department of Ecology reports that the beach is prograding in the vicinity of the proposed project site. II. Species and Habitat Information A. Species Information In the proposed project area, there are eight species listed under the Endangered Species Act by the U.S. Fish and Wildlife Service as either Endangered or Threatened: the humpback whale (Megaptera novaeangliae),the killer whale(Orcinus orca),the bull trout(Salvelinus confluentus),the Puget Sound Chinook salmon (Oncorhynchus tshawytscha),the Puget Sound Steelhead(Oncorhynchus mykiss),the marbled murrelet(Brachyramphus marmoratus marmoratus),the Steller sea lion(Eumetopias jubalus),and the leatherback turtle(Dermochelys coriacea). In addition,the Washington Department of Fish and Wildlife publishes a Priority Habitats and Species list(PHS)and a Species of Concern(SOC) list. The PHS list includes habitats, species,and species groups considered to be priorities for conservation and management. The project site is categorized as one of those habitat types--Marine/Estuarine Shoreline. The SOC list includes only native Washington Fish and Wildlife species that are listed as State Endangered,Threatened, Sensitive,or Candidates for these designations,or Federal Endangered,Threatened,Candidate,or Species of Concern. WDFW data revealed that three other species of anadromous salmonids on the State's PHS list may be found within the action area: the Puget Sound/Strait of Georgia Chum salmon (Oncorhynchus keta),the Puget Sound coho salmon(Oncorhynchus kisutch),and the Puget Sound/Coastal cutthroat(Oncorhynchus clarki clarki). The Puget Sound coho salmon is also an ESA listed Species of Concern. Species of Concern are not species that are being actively considered for listing under the ESA by the NMFS(National Marine Fisheries Service)or FWS. They have been identified as Species of Concern because of concerns or great uncertainties regarding biological status and threats. The stock status of Case Inlet summer chum and Deep South Sound Tribs coho are rated Healthy(WDFW 2002). The stock status of South Sound P.S./Coastal cutthroat is rated as Unknown(WDFW 2000). These three salmonid species will not be discussed further in this assessment. The beach at the proposed project site is a documented surf smelt spawning site(WDFW 2000);therefore,the three PHS listed species of forage fish will be discussed,due to their importance in the food chain. In addition, Mason County publishes a species of importance list. The species most likely to be found in the proposed project area include the Chinook salmon, bald eagle(Haliaetus leucocephalus), pileated woodpecker(Dr)copus pileatus), common loon(Gavia immer), Brandt's cormorant(Phalacrocorax penicillatus), great blue heron(Ardea herodias),band-tailed pigeon (Colmba fasciata),hooded merganser(Lophodytes cucullatus), harlequin duck(Histrionicus histrionicus),and purple martin(Progne subis). Conservation measures proposed in this report are expected/intended to minimize impacts to listed and/or unlisted species that may inhabit or utilize the proposed project site. Todd Habitat Management Plan 6 B. Federal Threatened or Endangered Species PUGET SOUND CHINOOK SALMON Puget Sound Chinook salmon were listed as threatened under the Endangered Species Act by NOAA Fisheries in March of 1999(64FR 14308). In April of 2002,critical habitat designation for the species and 18 other ESU(evolutionarily significant units)of Pacific salmon and steelhead was withdrawn--until further analysis of the economic impacts on affected businesses, communities, and individuals--after the U.S. District Court for the District of Columbia approved a NOAA Fisheries consent decree. A lawsuit was filed by the Pacific Coast Federation of Fishermen's Association and other plaintiffs,alleging that NOAA Fisheries Service failed to designate timely critical habitat for the 19 ESU for which critical habitat had been vacated. Ultimately,NOAA Fisheries agreed to file final critical habitat designations with the Federal Register by August 15, 2005. The designations include approximately 2,182 miles of near-shore habitat in Puget Sound and 1,683 stream miles. The boundaries of the Puget Sound ESU correspond generally with the boundaries of the Puget Lowland ecoregion. Chinook salmon are found in most of the rivers in this region. The ESU includes all naturally spawned populations of Chinook salmon from rivers and streams flowing into the Puget Sound, including the Strait of Juan de Fuca from the Elwha River eastward, including rivers and streams flowing into Hood Canal, South Sound,North Sound,and the Strait of Georgia in Washington State. The majority of Chinook salmon in this area exhibit an ocean- type life history and migrate to the ocean within their first year,as compared to the stream-type Chinook that reside in freshwater for a year or more following emergence(Gilbert 1912, Healey 1983). Due to their early outmigration to estuarine waters,ocean-type Chinook more extensively utilize estuaries and coastal areas for juvenile rearing(Nightingale and Simenstad 2001). The majority of benthic/epibenthic prey items such as amphipods that juvenile Chinook consume are associated with eelgrass and other macroalgae. In estuaries,Chinook fry are generally shoreline oriented, spending most of their time within 20 meters of shoreline(Weitkamp 2000). They have been observed utilizing nearshore areas including areas along shoreline structures, such as riprap, piers, and log rafts(Kask and Parker 1972; Ledgerwood et al. 1990; Meyer et al. 1980; Weitkamp et al. 1981; Weitkamp and Schadt 1982;Taylor and Willey 1997). Adults in marine waters forage on a large array of fish species,especially herring and sand lance(Scott and Crossman 1973). In most streams within the Puget Sound ESU,the overall abundance of indigenous Chinook salmon has declined substantially from historical levels. Factors contributing to this downward trend include widespread migratory blockages and degradation of freshwater and marine habitat, with many upper watersheds affected by poor forestry practices and the mid-and lower- watersheds affected by agriculture and urbanization. Commercial and recreational fishing are also partly responsible for the decline in native Chinook abundance,along with predation by non- native species, marine mammal or bird predation in areas of dwindling salmon run-size, competition from hatchery fish,and natural environmental conditions such as floods and droughts that reduce already limited spawning, rearing,and migration habitat. A Technical Recovery Team(TRT)was formed by NOAA Fisheries to assist recovery planning efforts for the chinook salmon. In 2001 and 2002,the TRT released technical reports describing independent populations of chinook salmon in Puget Sound(Ruckelshaus et al. 2001,2002). To date the TRT has identified 22 independent chinook populations: the North Fork Nooksack Todd Habitat Management Plan 7 River, South Fork Nooksack River, Lower Skagit River,Upper Skagit River, Lower Sauk River, Suiattle River, Upper Sauk River,Cascade River,North Fork Stillaguamish River, South Fork Stillaguamish River, Skykomish River, Snoqualmie River,North Lake Washington, Cedar River, Green/Duwamish River, Puyallup River, White River,Nisqually River, Skokomish River, Dosewallips River, Dungeness River,and Elwha River. Some naturally spawning aggregations of chinook were not recognized as part of these populations(e.g.,the Deschutes River in South Puget Sound). The TRT has concluded that chinook salmon using smaller streams in south and central Puget Sound probably did not occur there in large numbers historically and may be occupied due to hatchery releases. It has been theorized that few, if any, South Sound chinook are of strictly native origin(Hershberger 2000). The South Sound Tribs Chinook stock was not rated in 2002,due to the following rationale: (1) The independent tributaries in south Puget Sound are not typical Chinook habitat because of relatively small stream size and low flows during the late summer/early fall spawning season. (2) The current low escapements are likely the result of past hatchery plants or straying from either current South Sound hatchery production or viable south Sound natural populations. (3)Fall Chinook likely were not historically self-sustaining in these habitats and have little chance of perpetuating themselves through natural production(WDFW 2002). The nearest natural spawning is believed to occur in several streams throughout Case Inlet (WDFW 2002). A Washington State Department of Ecology GIS map(WSDOE 2007)reveals the presence of Chinook in Mill Creek,which is located approximately 10.0 lineal miles to the southwest of the proposed project site. Critical Habitat includes all near-shore marine areas of the Strait of Georgia, Puget Sound, Hood Canal,and the Strait of Juan de Fuca(to the western end of the Elwha River delta)from the line of extreme high tide out to a depth of 30 meters(70 FR 52688). Critical Habitat along the nearshore area of the proposed project site reveals foraging and migration habitat, so it is possible that foraging or migrating Chinook salmon may utilize the proposed project site. PUGET SOUND STEELHEAD On May 7'h 2007,the National Marine Fisheries Service listed the Puget Sound Steelhead as Threatened under the Endangered Species Act. Covered under the listing are naturally spawned steelhead from river basins in the Puget Sound, Hood Canal,and the eastern half of the Strait of Juan de Fuca, including more than 50 stocks of summer-and winter-run fish. The listing also covers two winter-run hatchery stocks: the Green River and the Hamma Hamma River. The steelhead,(Oncorhynchus mykiss),has the most complex life history of any Pacific salmon. Known as a rainbow trout if they remain in freshwater, steelhead usually spend two to four years in their home stream before heading to marine waters. They remain in saltwater for approximately three years,then return to their home stream to spawn. Steelhead are iteroparous and do not die as a result of spawning. Some will spawn a second or third time. NOAA Fisheries has identified 15 ESU of steelhead in Washington,Oregon, Idaho, and California. The WDFW reports that the status of Case Inlet winter steelhead was rated as Unknown in 2002. A WDFW GIS map(WDFW 2003)reveals the presence of steelhead in Mill Creek,which is located approximately 10.0 lineal miles to the southwest of the proposed project site. There is presently no designated critical habitat for the Puget Sound steelhead ESU. It is possible that foraging or migrating steelhead may be found in the action area. Todd Habitat Management Plan 8 LEAT14ERBACK TURTLE The Leatherback is listed as endangered throughout its range(Federal Register,June 2, 1970). There are no nesting sites in Washington State,though leatherbacks have been reported feeding as far north as British Columbia(NMFS 1998). There is no critical habitat for the species in Washington State. The most pelagic of sea turtles,it is unlikely that leatherbacks will be found in the vicinity of the proposed project site. HUMPBACK WHALE Exploitation of humpback whales from commercial whaling continued until 1966, leaving their numbers severely depleted. Listed as endangered under the Endangered Species Act,a North Pacific stock is known to occur seasonally off the Washington Coast(Calambokidis et al. 2000, 2001). Humpbacks occasionally venture into Puget Sound. Three years ago,a lone whale was spotted in the waters between Point Defiance and Vashon Island(Calambokidis 2004);however, since their favorite prey is krill,a pelagic zooplankton, it is doubtful that Case Inlet would be a prime feeding area. Presently,there is no designated critical habitat for the humpback whale. KILLER WHALE On November 15`h,2005 the Southern Resident Killer whale population was listed as an endangered species. The population,which currently stands at 89 whales,experienced a 20% decline in the 1990's and is still at risk from vessel traffic,toxic chemicals,and limited prey availability,namely salmon. Recent studies reveal that killer whales are among the most contaminated marine mammals in the world. Chemical contamination leaves the whales more susceptible to disease and may cause reproductive failure. Orcinus orca is the largest member of the dolphin family. Their life span in the wild is between 30 and 50 years. Males average 23 feet in length and weigh 7 to 10 tons. Females average 21 feet and 4 to 6 tons. They are found in all oceans of the world,but are most common in the Arctic and Antarctic or on the west coast of Canada and the United States. Orcas are highly social and travel in pods that usually consist of 5 to 30 whales. Pods are lead by females. On November 29,2006,NOAA Fisheries designated critical habitat for the Southern Resident Pod distinct population segment(DPS). Critical habitat includes the Summer Core Area in Haro Strait and waters around the San Juan Islands,Puget Sound,and the Strait of Juan de Fuca. The total area comprises approximately 2,560 square miles, including all marine waters relative to a contiguous shoreline delimited by the line at a depth of 20 feet(6.1 m)relative to extreme high water. Since killer whales occasionally venture into South Puget Sound, it is possible that they may be found foraging in the vicinity of the proposed project site. A transient pod was spotted in the spring of 2007 near Herron Island. STELLER SEA LION Steller sea lions are distributed throughout the rim of the North Pacific Ocean from California to northern Japan(Loughlin et al. 1984). In 1990 National Marine Fisheries Service listed the species as Threatened under the Endangered Species Act. In 1997 the population west of Cape Todd Habitat Management Plan 9 Suckling Alaska was reclassified as Endangered. There are no documented rookeries for Steller Sea Lions in Puget Sound,nor has any critical habitat been established for the species in Washington State. The Steller sea lion is a transitory visitor to Puget Sound,so it is possible that the species could be found foraging in the area. BULL TROUT Bull trout are members of the char subgroup of the salmon family and are native to the Pacific Northwest and western Canada. On November 1, 1999,the Coastal-Puget Sound population was listed as threatened under the Endangered Species Act. The Coastal-Puget Sound bull trout population segment encompasses all Pacific coast drainages within Washington,including Puget Sound. On September 23,2005,the U.S. Fish&Wildlife Service designated critical habitat for the bull trout,which in Washington State includes over 1,519 miles of streams and 966 miles of near-shore marine shoreline(70 FR 56304). Bull trout and Dolly Varden look very similar and were once considered the same species. Morphological analysises have confirmed the distinctiveness of the two species in their different, but overlapping geographic distributions(Haas and McPhail 1991),but because the two species are difficult to visually differentiate,the WDFW currently manages bull trout and Dolly Varden together as"native char." The U.S. Fish and Wildlife Service identified subpopulations for which status,distribution,and threats to bull trout were evaluated. Thirty-five subpopulations were identified in the Coastal-Puget Sound. Bull Trout reach sexual maturity between four and seven years of age and have been known to live as long as 12 years. Water temperature above 15 degrees Celsius is believed to limit bull trout distribution,as eggs and juveniles require extremely cold water for survival. Bull trout are also vulnerable to degraded stream habitat,poor water quality,dams and other stream blocking structures,and predation by non-native fish. Bull trout exhibit both resident and migratory life- history strategies(Rieman and McIntyre 1993). Resident bull trout complete their entire life cycle in the tributary(or nearby)streams in which they spawn and rear. Migratory bull trout spawn in tributary streams where juvenile fish remain for one to four years before migrating to either a lake(adfluvial),river(fluvial),or to saltwater(Fraley and Shepard 1989;Goetz 1989). The latter anadromous bull trout are the only form relevant to this assessment. The Washington Department of Fish and Wildlife indicates that the anadromous form of bull trout may exist in the Nisquallly River basin,although there is no documented evidence confirming this. The current abundance of "native char"in southern Puget Sound is likely lower than occurred historically and declining(T.Cropp 1993,F. Goetz 1994). Historical accounts indicate that anadromous char entered southern Puget Sound rivers in"vast numbers"during the fall and were harvested until Christmas(Suckley and Cooper 1880). "Native char"are now rarely collected in the southern drainages of the area. There is only one record of a"Native char" being collected in the Nisqually River,which was collected during a stream survey for salmon in the mid-1980's(G. Walter). Bull trout are vulnerable to increased water temperatures,degraded stream habitat,poor water quality,dams and other stream blocking structures, and predation by non-native fish. Critical habitat for the bull trout was designated in September of 2005,and it includes 966 miles of marine shoreline in Washington State,much of it in Puget Sound(70 FR 56304). Although the Todd Habitat Management Plan 10 shoreline along Case Inlet has not been designated Critical Habitat, it is possible that the proposed project site may be utilized by foraging or migrating bull trout. MARBLED MURRELET In September of 1992,USFWS listed the marbled murrelet as threatened Under the Endangered Species Act. A small,diving seabird in the family Alcidae, the marbled murrelet forages for small fish and invertebrates almost exclusively in nearshore marine waters,while nesting inland in old-growth or mature conifer forests. The primary threat to the species is the loss of nesting habitat due to the harvesting of old-growth forests. A life history strategy involving a relatively long life span,delayed sexual maturity,and low annual reproductive potential is also a problem. Beissinger(1995)suggests that productivity is below levels required to sustain the listed population. Critical habitat for the marbled murrelet was designated in May of 1996, but it is not located within close range of the project site in Case Inlet. The listed population size in Washington, Oregon,and California was estimated at 18,550 to 32,00 birds(Ralph et al. 1995,Nelson 1997). Marbled murrelet populations in those three states may be declining at a rate of 4 to 7 percent per year. USFWS indicates that marbled murrelet may occur in South Puget Sound. FORAGE FISH Forage fish represent an important link in the food chain between herbivores and predatory marine species. Pacific herring(Clupea harengus pallasi), Pacific sand lance(Ammodytes hexapterus),and surf smelt(Hypomesus pretiosus)are the foundation of fish prey supporting piscivores(consumers of fish)in Puget Sound(West 1997). These three species are also important food sources for most of the above-mentioned Endangered or Threatened species. Furthermore, surf smelt is the target of valuable commercial and recreational fisheries, while herring are an important source of commercial and sport fishing bait. Historical fishing by Indian tribes for herring and surf smelt has also been well documented(Stewart, 1977), and it remains an important part of their culture. Surf smelt spawn throughout the year,depositing semitransparent adhesive eggs on mixed sand- gravel beaches in the upper intertidal zone generally higher than+7 feet in tidal elevation. Overhanging vegetation helps egg development by providing shade that controls temperature and moisture on the beach(Pentilla 2001). As 80% of all Washington spawning has been found to occur in coarse sand and pea gravel, it is likely that substrate type and size may be the primary factor in spawning location(Nightingale& Simenstad 2001). Surf smelt feed on a wide variety of prey, including crustacea, copepods,amphipods, crab and shrimp larvae, and marine worms. Sand lance spawn in November to February,depositing adhesive eggs the size of sand grains in the upper intertidal zones of gravel-sand beaches. Spawning locations appear to be determined by the availability of sand substrate. The fine sandy beach material coats the eggs and likely serves to assist in moisture retention when they are exposed during low tides(Nightingale& Simenstad 2001). Sand lance larvae and juveniles have been found to feed in the upper water column during the day upon prey items such as copepods, crab larvae,amphipods, and diatoms (Tribble 2000). Todd Habitat Management Plan 11 Pacific herring spawn in January to April, depositing transparent adhesive eggs on objects such as eelgrass, kelp, or rocks,predominantly in shallow water between 0 and—10 feet in tidal elevation. Larval and juvenile herring feed upon prey items such as copepods, invertebrate eggs, diatoms, barnacle and mollusk larvae, bryozoans,rotifers,and young fishes. The Washington Department of Fish and Wildlife has designated and mapped critical spawning habitat for herring, sand lance,and surf smelt. The appropriate WDFW forage fish map(WDFW 2000)for the action area indicates that the shoreline at the property site is a documented spawning beach for surf smelt(Hypomesus pretiosus). C. Survey Results Field investigations were conducted on January 15, 2009 in the late afternoon. The project area was surveyed visually on foot during a low tide. The weather was overcast and the temperature around thirty-eight degrees Fahrenheit. The residence is located as close as 26 feet from the bluff crest at the proposed project site. The bluff's slope is nearly vertical and primarily unvegetated. It is probable that erosion to the bluff toe from tidal and wave action contributed to or caused the small slides(mass wasting)at the site. The beach was accessed via a community trail to the northeast of the site. A low tide exposed the littoral zone, which will be impacted during the brief construction period. The slope of the beach is shallow and the substrate consists primarily of sand and pea gravel at higher tidal elevations with gravel at lower elevations. A moderate amount of cobble was observed near the bluff toe at the west end of the frontage. The source of the cobble appears to be eroding bluff sediments. Moving eastward the bluff becomes low-bank,then no-bank. The beach at the site is depositional as evidenced by a significant buildup of sand and pea gravel in the upper littoral zone. The Washington State Department of Ecology reports that the beach is prograding (expanding seaward) in the vicinity of the proposed project site. The bluff and upland property at the site is vegetated with predominantly native species including the following: Western red cedar(Thuja plicata),red alder(Alnus rubra),hemlock(Tsuga heterophylla), Douglas-fir(Pseudotsuga menziesii),madrone (Arbutus menziesii),evergreen huckleberry(vaccinium ovatum),Rhododendron(Rhododendron spp.), salal (Gaultheria shallon), and carex(Carex sp.). The following invertebrate species were observed on the beach: barnacles(Balanus glandula)and snails(genus and species unknown). No eelgrass(Zostera marina or japonica)was observed. D. Existing Environmental Conditions The environmental baseline represents the existing set of conditions,to which the effects of the proposed action are then added. The environmental baseline is defined as"the past and present impacts of all Federal, state,and private actions and other human activities in the action area,the anticipated impacts of all proposed Federal projects in the action area that have already undergone formal or informal section 7 consultation,and the impact of state or private actions which are contemporaneous with the consultation process"(50 CFR 402.02). The proposed Todd Habitat Management Plan 12 project site is located in WRIA 14(Water Resource Inventory Area), on Case Inlet in Mason County. Both neighboring parcels support homes. The majority of the waterfront property in the neighborhood has been developed with single-family residences; however, a substantial percentage of the shoreline in the Harstene Pointe gated community is unarmored. WRIA 14 features an extensive network of low-elevation, low-gradient streams that are dependant on precipitation and groundwater for flow but has no major rivers. The majority of the fresh and marine waterbodies in WRIA 14 suffer from water quality issues. Case Inlet is listed on the state's 2004 Water Quality 303(d)-5 list of impaired waterbodies for the following parameters: fecal coliform,total PCB's, and bis(2-ethylhexyl)phthalate. The latter is a plasticizer used in the manufacture of PVC. It can be assumed that besides inorganic and organic pollutants, the existing environmental conditions in the area have been degraded by deforestation, shellfish aquaculture,and other anthropogenic changes that accompany urbanization. III. Effects of the Action A. Direct Effects Direct effects are the immediate effects of the project on the listed species and their habitats (FWS &NMFS 1998). The direct effect to the project site will be the construction of a rock bulkhead in an area that is Critical Habitat for one previously discussed salmonid species. Direct effects to the shoreline along Case Inlet include the alteration of littoral(intertidal)habitat from the placement of quarry spalls and large angular rock on the beach. Temporary direct effects caused by the proposed project include: ]) Sedimentation and/or siltation,and turbidity in Case Inlet. 2)Noise. 3)Water pollution from incidental release of fuel, oil, or other contaminants. 4)Damage done to the shoreline during the construction process. 1) Disturbed substrate from the installation of the rock bulkhead may result in increased turbidity and sedimentation and/or siltation,which might effect the migration of juvenile salmonids along the shoreline by creating a temporary barrier in the littoral zone. Juvenile salmonids are mobile, so it is possible that they will avoid the area of disturbance and not be impacted. Salmonids have been observed to move laterally and downstream to avoid turbidity plumes (Sigler et al. 1984, Lloyd 1987, Scannell 1988). Gregory and Northcote(1993)suggested that turbidity could be used as a protective cover by juvenile salmon. As previously discussed, BMP's will be strictly adhered to during construction in order to maintain the present water quality of Case Inlet and prevent runoff and pollution. In order to further minimize the adverse effects,the proposed new bulkhead project will not take place between March 15th and June 14th,when juvenile salmonid migration activity is high, or between July 1 and March 31, when surf smelt may be spawning (except within forty-eight hours after the location is inspected by an approved fisheries biologist to determine that no spawning has recently occurred). 2)The main source of construction noise will be the operation of heavy equipment. The project site is located in a rural residential neighborhood, so it is expected that the noise from heavy equipment will not be more excessive than noise normal to the neighborhood. 3) Potential water pollution from accidental release of fuel,oil, or other contaminants is another possible temporary direct effect. As previously discussed, Spill Prevention Control measures and BMP's shall be implemented during the proposed project. Todd Habitat Management Plan 13 4)A fourth possible temporary direct effect is damage done to the shoreline during the construction process. The grounding of the barge and movement of the track excavator in the upper intertidal area will cause some beach substrate disruption. As previously discussed,to reduce this type of impact the WDFW's construction requirements shall be strictly adhered to. Temporary direct effects caused by the construction process include noise; increased sedimentation and turbidity in Case Inlet due to runoff from disturbed substrate; potential water pollution from accidental release of fuel, oil, or other contaminants; and damage done to the shoreline during the construction process. B. Indirect Effects Indirect effects are those effects that are caused by or will result from the proposed action and are later in time, but are still reasonably certain to occur(50 CFR 402.02). Indirect effects from this proposed project include: 1)possible scouring and steepening of the beach in front of the new hard-armored section of shoreline. 2)the loss of shoreline vegetation. 3) A reduction in the accumulation of large drift logs on the beach. 4)the potential preservation of forage fish habitat. 1)When waves reflect off shoreline armoring structures, particularly concrete or other types of flat-faced bulkheads,they can cause scouring and hardening of the substrate. The sediment in front of a bulkhead will gradually become coarser as wave action and littoral drift removes the finer sediment and there is no sediment available for replenishment because it is impounded behind the bulkhead(Macdonald et al. 1994). Hard-armored bulkheads cut off sediment that was once available to feed the beach,thus adversely affecting natural beach-forming processes. Impoundment of sediment landward of the bulkhead can also result in potential loss of forage fish spawning habitat and a reduction in the amount of available shallow water habitat that juvenile salmonids rely on for food or cover(including eelgrass beds), although the Pentec Report(2003) reveals that the amount of eelgrass present along the open shoreline appears to be independent of the degree of shoreline modification. The proposed rock bulkhead will be located landward of MHHW and the ordinary high water line. Bulkheads located landward of MHHW cause fewer beach impacts than those at or below MHHW. Unlike concrete or wood bulkheads,the uneven surface and irregular form of a rock bulkhead is expected to dissipate some of the energy from wave action and lessen the previously discussed detrimental effects associated with hard-armoring. In addition,at least four pieces of large woody debris shall be anchored to the beach to further dissipate wave energy and create habitat for numerous species. As per the "FW's HPA provisions, appropriate sized surf smelt spawning gravel shall be spread along the bulkhead face. A recent King County beach accretion study revealed that toe erosion did not occur at bulkheaded sites, except in rare cases where very low or failing bulkheads allowed toe erosion to occur (Johannessen, MacLennan,and McBride 2005). The same study also found that,while mass wasting events were fairly common where the bluffs were not bulkheaded, slides occasionally occurred at bulkheaded areas(with debris extending over the bulkhead and onto the beach in some cases). A cluster of recent slides between Mukilteo and Picnic Point that was within the BNSF railroad revetment area, indicate that bluffs remain unstable and are subject to mass wasting, even though the bluffs have been armored for approximately 110 years(Johannessen, MacLennan,and McBride 2005). Todd Habitat Management Plan 14 This empirical evidence seems to confirm that the function of a bulkhead is to protect the toe of the bank/bluff from erosion due to wave action and not to act as a retaining wall. Therefore,the presence of a bulkhead at the proposed project site will only help to insure that no further mass wasting occurs due to toe erosion. Small slides may continue to spill over the top of the new bulkhead and feed the beach until erosion eventually moderates the angle of the bluff face, allowing adequate vegetation to become established. It should be noted that a majority of bulkhead impact studies appear to have been conducted in coastal areas(Atlantic Ocean)where the energy from wave action has the potential to be much stronger than in the sheltered waters of Puget Sound, so it seems reasonable to expect that the indirect effects of erosion and sediment impoundment would be less pronounced in Puget Sound. In fact, Puget Sound receives little to no swell from the eastern Pacific Ocean; waves are generated locally by wind and consequently have limited fetch and low energy compared with incident waves on the Pacific Coast(Finlayson 2006). Most Puget Sound beaches exhibit a composite profile with a narrow,steep foreshore,and a low-gradient, "low-tide"terrace (Finlayson 2006). In the South Sound, the sea floor of the inlets is not significantly deeper than the terrace platform; in these locations the lower nearshore grades gently into the sea floor without a significant break in slope(Finlayson 2006). Therefore, since the South Sound lacks the deeper troughs that characterize coastal waters and other parts of Puget Sound, it seems possible that sediments may be permanently available to the nearshore. This gives rise to two interesting hypothetical questions: are sediments in South Sound being re-circulated, and, if so, do sediment contributions from feeder bluffs represent natural fill? Clearly,more research is needed on the geomorphology of South Puget Sound beaches. 2) Another indirect/direct effect is the loss of vegetation directly landward of the bulkhead,due to the presence of quarry spalls and filter fabric. Without the quarry spalls and filter fabric the bulkhead would lose strength and integrity. Sediments would filter through and it would eventually collapse. Native shrubs with the potential to provide shade,organic matter,and terrestrial insect prey for salmonids shall be planted immediately landward of the filter fabric along the length of the frontage and on the bank where feasible. 3) Shoreline armoring can also limit the accumulation of large drift logs on the beach, as large woody debris is less likely to accumulate on beaches that have steepened due to the presence of a bulkhead(Macdonald et al. 1994). Large woody debris provide detrital input, food sources,and potential refuge for migrating juvenile salmon. As previously discussed,at least four pieces of large woody debris shall be anchored to the beach. 4) Empirical evidence suggests that by impounding sediments such as clay or cobble that do not constitute suitable forage fish spawning habitat, bulkheads sometimes act to create or preserve such habitat. A five year monitoring study of the reconstructed Redondo Seawall in King County revealed that the bulkhead created a depositional area where sand settled out and covered cobble in two of three sampling transects that were previously dominated by cobble(Shannon and Taylor 2003). The study concluded that the reconstructed wall does not appear to effect the documented spawning of surf smelt and that it may contribute to the previously undocumented spawning of Pacific sand lance in the area(Shannon and Taylor 2003). Another possible indirect effect is that the presence of a bulkhead at the proposed project site could preserve forage fish spawning habitat by lowering the probability of a large mass-wasting event that could bury the beach under tons of substrate and organic debris. A large slide could result in the permanent loss of beach and an alteration of the substrate from sand and gravel (sand lance and surf smelt spawning material)to predominantly cobble. Since shoreline buffers act to Todd Habitat Management Plan 15 filter out pollutants before they enter a water body,a mass-wasting event might also have serious water quality implications. In 2006,the U.S. Environmental Protection Agency reported that excessively high sediment loads can smother submerged aquatic vegetation beds,cover shellfish beds and tidal flats,fill in riffle pools,and contribute to increased levels of turbidity and nutrients. However,there are few research results that can be used to identify levels below which streambank and shoreline erosion is beneficial and above which it is a nonpoint source pollution problem(USEPA 2006). C. Cumulative Effects Cumulative effects are defined as"those effects of future state or private activities,not involving Federal activities,that are reasonably certain to occur within the action area of the action subject to consultation"(50 CFR 402.02). Cumulative impacts are difficult to access. Continued growth and urbanization is likely to detrimentally impact fish and wildlife resources. Global warming could raise the water level of Puget Sound,leaving many waterfront properties underwater. Over-fishing may deplete stocks of salmon,even as restoration of habitat in the watershed furthers their likelihood of survival. D. Take Analysis Section 9 of the ESA prohibits take of endangered or threatened species,"take"being defined in Section 3 as to harass,harm,pursue,hunt,shoot,wound,trap,capture,or collect listed species,or attempt to engage in any such conduct. "Harm"is further defined as a significant habitat modification or degradation that actually kills or injures listed species by"significantly impairing behavioral patterns such as breeding, spawning,rearing,migrating,feeding,and sheltering"(50 CFR 222.102). "Harass"is further defined as an intentional or negligent act which creates the likelihood of injury to wildlife by annoying it to such an extent as to significantly disrupt normal behavior patterns which include,but are not limited to,breeding,feeding,or sheltering(50 CFR 17.3). In regards to the proposed project and the existing development activities, it is extremely unlikely that any "take"will occur. The following conservation measures(some previously discussed)will further insure the likelihood that no"take"will occur. E. Conservation Measures 1. No Construction to take place during the prohibited work window between March 15 and June 14th,for the protection of juvenile salmonids,or between July 1 and March 31,when surf smelt may be spawning(except within forty-eight hours after the location is inspected by an approved fisheries biologist to determine that no spawning has recently occurred). 2. The WDFW's common saltwater technical provisions(WAC 220-110-270)to be strictly adhered to. Todd Habitat Management Plan 16 3. Previously discussed BMP's to be strictly adhered to. 4. At least four existing pieces of large woody debris shall be anchored to the beach (both perpendicular and parallel to the bulkhead face)to replicate natural conditions. 5. Peagravel(1/16 to '/4 inch)to be spread along the toe of the bulkhead to provide sand lance and surf smelt spawning habit,as per the HPA provisions from the Washington Department of Fish and Wildlife. 6. Manmade debris on the beach shall be removed from the site. 7. Following construction,native shrubs shall be planted landward of the bulkhead's filter fabric and quarry spalls. Recommended species include the following: vine maple(Ater Circinaturm),evergreen huckleberry(Faccinium ovatum),thimbleberry (Rubus parviorus),oceanspray(Holodiscus discolor),salal(Gaultheria shallon), and sword fern(Polystichum munitum). F. Determination of Effect A determination of May affect, not likely to adversely affect is the appropriate conclusion when effects on the species or their critical habitat are expected to be beneficial,discountable,or insignificant After reviewing the appropriate data and survey information,I have concluded that the proposed project will have an insignificant impact on the previously discussed Endangered or Threatened species if the previously discussed conservation measures are implemented. In my most honest and professional opinion,while the proposed project may impact individual Endangered or Threatened species in the project area,it is not likely to adversely affect or jeopardize the continued existence of those species or their designated Critical Habitat. The determination of effect for each of the listed species is: 1. Puget Sound chinook and their designated Critical Habitat Nay affect, not likely to adversely affect. 2. Puget Sound Steelhead--May affect, not likely to adversely affect. 3. Leatherback turtle and their designated Critical Habitat No effect. 4. Humpback whale—No effect. 5. Killer whale and their designated Critical Habitat---May affect, not likely to adversely affect. 6. Steller sea lion and their designated Critical Habitat--May affect, not likely to adversely affect. 7. Bull trout and their designated Critical Habitat--May affect, not likely to adversely affect. 8. Marble murrelet and their designated Critical Habitat--May affect, not likely to adversely affect. Todd Habitat Management Plan 17 IV. References Literature Angell,T. and K.C.Balcomb III. 1982. Marine Birds and Mammals of Puget Sound. Puget Sound Books. University of Washington Press, Seattle, WA. Brodeur,R.D.,K.W.Myers,and J.H.Wells. 2003. Research Conducted by the United States on the Early Ocean Life History of Pacific Salmon. North Pacific Anadromous Fish Comm.Bull. 3: 89-131. Druehl,Louis D. 2000. Pack Seaweeds. Harbour Publishing,Madeira Park,BC Canada. Federal Register/Vol. 70,No.170/September 2,2005/Rules and Regulations Federal Register/Vol. 70,No.185/September 26,2005/Rules and Regulations Federal Register/Vol. 63,No. 111 /June, 10, 1998/Proposed Rules Federal Register/Vol.64,No. 128/July,6, 1999/Proposed Rules Federal Register/Vol. 65,No. I /January 3,2000/Proposed Rules Gilbert,C.and Williams J. 2002. National Audubon Society Field Guide to Fishes, Alfred A Knopf,Inc.New York. Groot,C.and L.Margolis(eds.) 1991. Life history of Pacific salmon,UBC Press,Vancouver, British Columbia. Harbo,R. 1997. Shells&Shel 4h of the Pacific Northwest,Harbour Publishing,Madeira Park, British Columbia. Finlayson,D. 2006. The Geomorphology of Puget Sound Beaches. University of Washington, Seattle, WA. Finlayson,D.and Shipman H. 2003. Puget Sound Drift Cells: The importance of waves and wave climate. Puget Sound Notes,Issue No.47, September 2003. Johannessen,J.W.,A.MacLennan,and A.McBride. 2005. Inventory and Assessment of Current and Historic Beach Feeding Sources/Erosion and Accretion Areas for the Marine Shorelines of Water Resourse Inventory Areas 8&9. Coastal Geologic Services. Belllingham,WA. Pp.46- 47. Leigh,Michael. 1996. Grow your own native landscape: a guide to identifying,propagating,and landscaping with Western Washington native plants. Washington State University Cooperative Extension/Thurston County,Olympia,WA. Todd Habitat Management Plan 18 National Geographic. 2002. Field Guide to the Birds of North America. National Geographic Society, Washington,D.C.pp. 108, 226. NOAA Fisheries. 2003. Biological Opinion for the Duhon New Bulkhead and Stairs Project, Jefferson County,Washinton. Unpublished report for U.S.Army Corp of Engineers. NOAA Fisheries. 2004. Preliminary findings of NOAA Fisheries' Critical Habitat Analytical Review Team for Puget Sound and Ozette Lake ESUs. NOAA Fisheries Protected Resources Division,Portland,Oregon. Unpublished report. NOAA Fisheries. 2004. Biological Opinion for the Steve West Bulkhead Replacement,Thurston County,Washington. Unpublished report for U.S.Army Corp of Engineers. NOAA Fisheries. 2005. Fisheries agency lists Puget Sound killer whales as endangered. Internet report. http://www.noaanews.noaa.gov/stories2005/s2533.htm NOAA Fisheries. 2006. Proposed critical habitat for Southern Resident killer whales. Internet report. http://www.nwr.noaa.gov/Marine-Mammals/Whales-Dolphins-Porpoise/Killer- Whales/ES... Osborne,R.,J.Calambokidis,and E.M. Dorsey. 1988. A guide to marine mammals of greater Puget Sound. Island Publishers,Anacortes, WA. Penttila,Daniel E. 1995. Spawning areas of the Pacific herring(Clupea), surf smelt (Hypomesus),and the Pacific sand lance(Ammodytes)in central Puget Sound, Washington. Wash. Dept.of Fish and Wildlife Manuscript Report. Rodrick,E. and R.Milner(technical editors). 1991. Management recommendations for Washington's priority habitats and species. Washington Department of Wildlife,Wildlife Management, Fish Management,and Habitat Management Divisions,Olympia,WA. 17pp. Shannon,J.and W.Taylor. 2003. Monitoring Puget Sound Forage Fish Habitat: Lessons from the Redondo Seawall Mitigation and Monitoring Project. King County Department of Transportation, Seattle,WA. United States Environmental Protection Agency. 2006. Polluted Runoff(Nonpoint Source Pollution). 17 pp. Internet report. http://www.epa.gov/OWOW/NPS/MMGI/Chapter6/ch6- 4.html Washington State Department of Ecology. 1994. Shoreline Armoring Effects on Coastal Ecology and Biological Resources in Puget Sound, Washington. Coastal Erosion Management Studies,Volume 7. Washington State Department of Ecology. 2002. Net Shore-Drift in Washington State. WSDE, Olympia, WA. Washington Department of Fish and Wildlife. 2000. Critical spawning habitat for herring,surf smelt, sand lance,and rock sole in Puget Sound,Washington. Prepared by Fish Program, Olympia, WA. pp.3,4;maps 141, 147. Todd Habitat Management Plan 19 Washington Department of Fish and Wildlife. 2002. Salmon Stock Inventory of South Sound. Internet report. Website:http://wdfw.wa.gov Washington Department of Fish and Wildlife. 2008. Species of Concern in Washington State. Internet report. Website: http://wdfw.wa.gov/wlm/diversty/soc/soc.htm Wells,D.,L. Hennessee,and J Hill. 2003. Shoreling Erosion as a Source of Sediments and Nutrients Middle Coastal Bays,Maryland. Coastal and Estuarine Geology File Report No. 03-07. Maryland Geological Survey. Baltimore,MD. 12 pp. Todd Habitat Management Plan 20 Attachment 1 Vicinity Map. ' Fair Harbor _- f ! 3 Grapeview. 3 j r, d " TODD RESIDENCE N:, 771 E VY'INDJANINEF;CIR I, SHLETQN, WA Home ct�g Hartstene 44a.- _ Herron �rn 7_�ir" Grant PARCEL#121195700044 NO ADJOINING SEC19-T21 N-ROl W-W.M. BULKHEAD N47.18.01 W122.51.0 CASE INLET C/) D CL BLUFF CREST APPROX. PROPERTY -- - - - - - - - - - - - - - - - - N - - - - - LINE - - - - - - - - - - - - - - - - - - - - - - - - - - BULKHEAD SHALL BE m CONSTRUCTED OF LARGE ANGULAR ROCK, LANDWARD OF THE TOE OF THE SLOPE AT BEACH AND MHHW QUARRY SPALLS AND FILTER FABRIC SHALL BE USED BEHIND THE NEW BULKHEAD. RESIDENCE I APPROX. 110, 0 EXISTING VEGETATION SHALL BE PRESERVED WHEREVER IT IS FEASIBLE. EXISTING 0 WOODY DEBRIS SHALL BE ANCHORED TO THE BEACH. APPROX. --- -- -- -- -- - - _ _ PROPERTY --- - - -- - - - _ _ LINE - _ - - - NO ADJOINING BULKHEAD I N BULKHEAD PROPOSAL PROJECT NAME: TODD RESIDENCE NORTH DRA\MNGSCALE: V" 30' i FILE: SPI14YC PROJECTADDRESS: DONNATODD p DA K24-09 771 E WINDJAMMER CIR DATE:t-24 09 SHELTON,WA 98584-9498 ALL SITE DIMENSIONS ARE APPROXIMATE PARCEL#121195700044 SEC19-T21 N-R01WW M. / N47.18.01 W122.51.0 0D BULKHEAD SHALL BE can d CONSTRUCTED OF LARGE n = ANGULAR ROCK, LANDWARD (S 6 uu `�sI°E"� APPROX.26'TO BLUFF OF THE TOE OF THE SLOPE o cD CRESTAND 31'TO I AT BEACH AND MHHW QUARRY BEACH TOE SPALLSAND FILTER FABRIC SHALL coa m BE USED BEHIND THE NEW BULKHEAD. cQ cD 3 c� lK o� APPROX. 12'TO 20' EXISTING VEGETATION SHALL BE PRESERVED WHEREVER IT IS FEASIBLE. EXISTING FW H-bw, -- / WOODY DEBRIS SHALL y BE ANCHORED TO THE BEACH. ItUh V�>� h V MAX.ABOVE GRADE HEIGHT J ¢& MHHW 14.30' ... TODD RE5IDENCE N'^ I..IH ]]I E WINDJAMMER CIR ` 5h4ETON,WA Hum O 3 w s FILTER FABRIC a 18"MIN. QUARRY SPACES BASE ROCK SET BELOW BEACH GRADE BEACH GRADE. VICINITY MAP MAP BY MICROSOFT N BULKHEAD PROPOSAL TODD RESIDENCE PROJECT NAME. NORTH DRAWING SCALE: 1"=30' DONNA TODD ' 1„ FILE CSn43RODD PROJECTADDRESS: 0 BY. KLS/BMc 771 E WINDJAMMER CIR DATE 1-24-09 SHELTON,WA 98584-9498 ALL SITE DIMENSIONS ARE APPROXIMATE Todd Habitat Management Plan 23 Attachment 4 The SFR and bluff at the proposed project site. Id ... Habitat Management bluffAttachment 5 The at the proposed project fi y * r s