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OFFICE OF THE
MASON COUNTY PROSECUTING ATTORNEY
GARY P.BURLESON 411 N.FIFTH STREET
PROSECUTING ATTORNEY SHELTON,WASHINGTON 98584
PHONE(206)427-9670 ext.417
July 14, 1993
Gary H. Sexton
SEXTON, BARTHOLAMEW & JOHNSEN
Attorneys At Law
1126 Highland Avenue
Bremerton, WA 98310
RE: BYERLY v. MASON COUNTY
Dear Gary:
I discussed settlement of this case with Grace Miller, Mason County
Planner. She in turn contacted people over at the Department Of
Ecology for their ideas concerning settlement.
In a spirit of compromise, we propose the following offer of
settlement:
1. That your clients remove the gravel and other fill
material from the approximately 3/4 of an acre which covers
the wetland area. The removal would be done at a time when
representatives of the county and DOE can be present to define
the limits of excavation.
2 . That your clients move the excavated material, to a place
and in such a manner that there will be no erosion impact to
any wetland. Representatives of the county and DOE would
monitor this work.
3 . That your clients agree not to use the wetland portion of
the property for storage or for any other use unless or until
it gets proper approvals. Your clients would further agree
not to use the wetland area for storm or waste water discharge
purposes, or for any other purpose which in the county' s or
DOE' s judgment would detrimentally impact the wetland.
4 . In return, we would not require that your clients replant
the wetland areas. The wetland would reestablish itself.
This should save your clients a considerable amount of
expense.
5 . The suit against the county would be dismissed with
prejudice, with each side handling its own costs.
i a
Please discuss this offer with our clients and let us know their
position.
hank you for your continued cooperation.
e'y trulsy yours,
MIKE CLIFT
Chief Deputy Prosecuting Attorney
c: Grace Miller
Rebecca Todd, Assistant Attorney General
OFFICE OF THE
MASON COUNTY PROSECUTING ATTORNEY
GARY P.BURLESON 411 N.FIFTH STREET
PROSECUTING ATTORNEY SHELTON,WASHINGTON 98584
PHONE(206)427-9670 ext.417
July 14, 1993
Gary H. Sexton
SEXTON, BARTHOLAMEW & JOHNSEN
Attorneys At Law
1126 Highland Avenue
Bremerton, WA 98310
RE: BYERLY v. MASON COUNTY
Dear Gary:
I discussed settlement of this case with Grace Miller, Mason County
Planner. She in turn contacted people over at the Department Of
Ecology for their ideas concerning settlement.
In a spirit of compromise, we propose the following offer of
settlement:
1. That your client remove the gravel and other fill
material from the approximately 3/4 of an acre which covers
the wetland area, and agree not to use the wetland portion of
the property for storage or for any use which would
detrimentally impact the wetland.
2 . In return, we would not require that your clients replant
the wetland areas. The wetland would reestablish itself.
This should save your clients a considerable amount of
expense.
3 . The suit against the county would be dismissed with
prejudice, with each side handling its own costs.
Please consider this offer carefully and let us know your thoughts.
Very truly yours,
MIKE CLIFT
Chief Deputy Prosecuting Attorney
c: Grace Miller
Rebecca Todd, Assistant Attorney General
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SETTLEMENT AGREEMENT
This agreement is entered into between Plaintiffs, Jerry,
John, Bill and Bob Byerly, (Byerlys) , Defendant Mason County and
the State of Washington Department of Ecology as follows:
1. Plaintiffs agree to contract with and hire a contractor
to perform the work as herein agreed. Byerlys shall notify the
Department of Ecology designee Al Wald, (unless Al Wald shall
advise the attorney for plaintiffs that someone else shall provide
supervision, and shall be the designee) not less than 10 days
before the work is to begin of the name, address and phone number
for the contractor. The contractor is subject to prior approval by
the Department of Ecology designee. In the event that the
Department of Ecology should reject the Byerlys contractor, the
Byerlys shall name two additional proposed contractors. The
Department of Ecology designee shall then select between the three
named contractors.
2 . It is agreed that the maximum total expense and cap on
expense and/or work to which the Byerlys shall be subject to pay is
(1) Six Thousand Five Hundred Dollars ($6, 500. 00) , (2) the on site
equipment operation maximum hours as provided for in paragraph 3
herein, or (3) the arrival at the edges and depths of any
"wetlands" as identified by Ecology and herein established; which
ever contingency is met first.
3 . The maximum required equipment and operator time under
this agreement is 27 hours for on site operation time for site
preparation, material removal (soil, stumps, vegetation, etc. ) and
cleanup using a Case Crawler 1088, (tracked excavator, with a thumb
on the bucket and minimum reach of 20 feet) , or equivalent, at the
maximum rate of $120. 00 per hour including operator, plus a 10 yard
dump truck for a maximum 25 hours at a rate of $70. 00 per hour
including operator.
4 . The respective attorneys for plaintiffs (Gary Sexton) and
Mason County (Mike Clift) shall, prior to commencement of work,
meet on site and agree upon the Southwesterly and Northwesterly
lower edges of the fill area, and mark those locations. In the
event, for any reason, the attorneys cannot agree upon the two
westerly corners of the lowerly edge of the fill, the decision as
to location shall be subject to site visit and final determination
by Judge Toni Sheldon, or the presiding judge if for any reason she
is not available. It is agreed that the maximum limitation_ for
work and potential "wetland" location shall be 135 ' moving in an
easterly direction along the south property line of the Byerly
property, from the agreed Southwest corner of the fill, and 165 '
moving in an easterly direction along the north property line from
the agreed northwest corner of the fill.
5 . The Department of Ecology designee shall supervise the
work performed by the Byerly contractor, with material to be
removed beginning on the westerly edge and continuing on a
continuous basis toward the east. Work shall cease when the first
limitation and cap is achieved as provided for in paragraph 2
above. The Byerlys shall use their best efforts to comply with
terms of this agreement. Materials removed by contractor may be
placed onsite at locations selected by and at the discretion of the
Byerlys, excepting it shall not be placed on the hereinafter
defined wetland as established pursuant to paragraph 6 .
6. Upon the achieving of the first limitation or cap the
attorneys for the parties shall meet on site and stake the edge of
removal work. Thereafter, that property located easterly of the
stake area shall be considered by the parties to this agreement to
be "upland" property and the property to the West thereof shall be
"wetland" area for all state and county regulation purposes . It is
agreed that, in no event, shall the edge of the wetland area extend
furtherly eastward than the limitations provided for in paragraph
4 above.
7. The Department of Ecology designee shall make himself
available and accommodate the work schedule of the contractor, upon
48 hours advance notice by the contractor as to the date that
he/she intends to commence work. The contractor shall continuously
advise, in advance, regarding when he/she will be performing work._
Work shall be performed during normal business hours, which for
purposes of the agreement shall be between 7: 00 A.M. and 5 : 00 P.M.
Monday thru Friday. Work shall be completed not later than October
15, 1993 .
8 . It is agreed and understood that the proposed work under
this agreement required no permits from Mason County or the State
of Washington.
9 . Upon completion of the work as provided for herein, it is
further agreed that all claims and counter claims are dismissed
with prejudice and without costs to either parties. This agreement
is in full settlement of all claims, counter claims, and the issues
presented in testimony and exhibits in Mason County Superior Court
Cause No. 91-2-00078-0.
Dated this J day of August, 1993 .
SEXTON, BARTHOLOMEW & JOHNSEN
-r
GARY H. 9tXTON
Of Attorneys For Plaintiffs
ARY P. BURLESON
rosecuting Attorney
7
4
MIKE E. CLIFT
Chief Deputy Prosecuting Attorney
Of Attorneys For Defendants
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
ALAN WALD, Shorelands Division
Printed by Grace Miller 8/25/93 11: 08am
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From: Grace Miller
To: Permit system Group
Subject: Byerly' s in Belfair
- - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - - -
====NOTE_______________ 8/25/93 11 : 08am=
To all field inspectors:
Next week there will be some heavy
grading work going on in Belfair on the
west side of Hwy 3 on the John and
Jerry Byerly property. The property is
south of the Masonic Temple. PLEASE DO
NOT STOP to investigate or Stop Work
for the grading under any
circumstances . This is crucial
considering the history of the site and
lawsuit ' s settlement agreement.
The removal and restoration is part of
the settlement agreement reached in
recent lawsuit between the Byerlys and
County and DOE. They are removing
approx. 7000 cubic yards of fill from
an associated wetland of Hood Canal .
They are re-depositing the fill on same
piece of property but out of the
wetland. There is approx. 600 c.y. of
woodwaste within the fill .
Part of the settlement agreement
reached was that no permits would be
required for this work. Al Wald of DOE
will be on site supervising. If you
have any questions, please ask me or
Jason or Mike Clift. I will not be in
the office much of next week but Jason
is familiar with the situation. Jason
has informed me that there is a
recently installed septic system on the
property. Mike Clift will be
corresponding with the Byerlys to
insure the fill is not placed on the
system. Please contact Mike Clift and
Jason if you have ANY comments
regarding this work or would like to
see a copy of the settlement
agreement .
Please ignore this site if you are out
in the field next week - probably
Tuesday and Wednesday - and see work
taking place. It is a resolution to a
long standing violation. If you know
someone in Bldg. or Environmetal Health
who does not read their E-mail please
pass this message to them as it is very
urgent . Thank you.
SON.STq TF O
o A DEPARTMENT OF COMMUNITY DEVELOPMENT
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Z�OJ N Y y Planning - Landfill - Utilities
1864
January 24 , 1992
Mary Waters
USACOE
P.O. Box 3755
Seattle, WA 98124
Dear Ms . Waters :
On December 17, 1991 you requested a status report of two Corps
violations which occurred in Mason County. The first violation was
by a Mr. Clarence Luce. The County has not taken any action on this
violation since January of 1991 . At that time, staff had requested
removal of the bulkhead and fill in violation since 1987 . In
response to our request, Mr. Luce notified the County that he had
been in a serious automobile accident where he had suffered a brain
concussion and spinal injuries . He requested additional time to
remove the fill and bulkhead which the County granted. We have not
heard from Mr. Luce since February 28 , 1991 . I will attempt to
contact him again but from studying the history of this violation,
it does not appear to that Mr. Luce will cooperate.
The second violation was Jerry Byerly. It appears that this
violation has not been followed up on by Mason County. The Planning
Department turned the violation over to the Prosecutor' s office
approximately two years ago. Jerry Byerly, along with his family
have sued the County for not being able to use their property. I am
not aware of any court dates being set . I recommend that you
contact Mike Clift, the Mason County Assistant Prosecuting
Attorney, to learn of the status of the violation. Mike Clift' s
phone number is 427-9670 . Apparently, for reasons beyond the
Planning staff' s understanding, the Prosecuting Attorney has chosen
not to pursue the violation because of the lawsuit . If I can be of
any further assistance to you, do not hesitate to call either
myself or Erik Fairchild, Planning Coordinator. Thank you.
Sincerely,
Grace Miller, Planner
DEPT. OF COMMUNITY DEVELOPMENT
Gary Yando,Director of Community Development • Erik Fairchild,Planning Director
Mason County Bldg. III • 426 W. Cedar • P. O. Box 578 9 Shelton, WA 98584 • (206) 427-9670
Recycled
SON. STgTFo
P 'c
o A U N DEPARTMENT OF COMMUNITY DEVELOPMENT
=
i 0T Z
�0 N Y boy Planning - Landfill - Utilities
1864
January 27, 1992
Mary Waters
USACOE
P.O. Box 3755
Dear Ms . Waters :
On December 17, 1991 you requested a status report of two Corps
violations which occurred in Mason County. The first violation was
by a Clarence Luce. The County has not taken any action on this
violation since January 1991 . At that time, staff had requested
removal of the bulkhead and fill in violation since 1987 . In
response to our request, Mr. Luce notified the County that he had
been in a serious automobile accident where he had suffered a brain
concussion and spinal injuries . He requested additional time to
remove the fill and bulkhead. Mason County granted him an
unspecified extension for compliance. We have not heard from Mr.
Luce since February 28 , 1991 . I will attempt to contact him again
at this time.
The second violation was Jerry Byerly. The Planning Department
turned this violation over to the Mason County Prosecuting Attorney
approximately two years ago. Jerry Byerly, along with his family,
have sued the County for not being able to use their property. I
believe the court dates have been set for March of this year and
the Mason County Prosecuting Attorney is requesting the presence of
the Corps staff who were involved. I recommend that you contact
Mike Clift, the Mason County Asst . Prosecuting Attorney, to learn
of the status of the violation. Mike Clift' s phone number is 427-
9670 .
If I can be of any further assistance to you, please do not
hesitate to call either myself or Erik Fairchild, Planning
Coordinator. Thank you.
U7erely,
Grace Miller, Planner
DEPT. OF COMMUNITY DEVELOPMENT
Gary Yando,Director of Community Development - Erik Fairchild,Planning Director
Mason County Bldg. 111 - 426 W. Cedar - P. O. Box 578 9 Shelton, WA 98584 - (206) 427-9670
JUN
MASON Co. PLANNING DEFT.
MEMO TO: Friends in building/planning/zoning and other permitting processes
FROM: Robert D. Wilson-Hoss I
RE: County liability, employee mistakes, Mull v. Bellevue, 64 Wn.App. 245
(1992)
This is not an exhaustive review of all cases and law about municipal (city or
county) liability for errors made by municipal employees within a permitting
process. It is a discussion, for the personal use of friends, of some aspects of a recent
case. Particular questions about certain fact patterns should be referred to your own
attorney. No decisions about what to do should be made solely on the basis of this
memorandum.
I have noticed on occasion some confusion about municipal liability, for
example, certifying septic system designs and installations. What if a county
employee makes a mistake, and fails to inspect before a system is covered, or simply
gets the code requirements wrong? Is the county liable? What about building
permit mistakes - what if a foundation is not adequate, the problem should have
been caught, but wasn't, and a wall collapses on the owner? A building is approved
for height by mistake, and the neighbor sues?
Can I sue the county for any problems in my house caused by non-compliance
with building or other permits, when non-compliance was a mistake by the building
department?
Mull V. Bellevue, 64 Wn.App. 245 (1992) copy attached, is a recent case that
discusses the rules. Basically, the first rule is, when a municipal employee makes a
mistake in approving a project, the municipality is not responsible for harm to an
individual caused by non-compliance with building or similar codes unless there is
a special relationship between the individual and the municipality.
In order for a special relationship to exist, an individual must show:
1. direct contact between the individual and a responsible municipal
employee;
2. a clear question by the individual, that is clearly answered by an
assurance by the employee; and
3. the individual justifiably relies on that assurance.
If I ask an inspector if my house can be 26 feet high, and the code says 20 feet
maximum; but the inspector assures me that 26 feet is fine, can I sue the county,
when my neighbor sues me for having a building that is too tall?
Most of the cases deal with unclear requests or assurances. If the request is
clear, such as about allowable height for my house, the issue is, do I have a right to
rely on the inspector's advice?
I think I do, if the inspector knows I am going to rely on his or her advice, and
assures me that my house is going to be legal. But my guess is that a court may not
agree, for public policy reasons. It is better to say that no one can rely on an
inspector, and that the public has the duty to be sure about codes, than to allow
people to rely on inspectors, which would lead to people using building inspectors
to plan their projects for them.
If this is true, then when can a municipality be sued? One example is in
Rogers v. Toppenish, 23 Wn.App. 554 (1979) - the city did not keep up to date zoning
maps, so the only place to go for information was to ask the zoning administrator.
His answer to a clear question was wrong. Under these circumstances, the property
owner did have a special relationship with the administrator.
Similarly, there was a small seasonal wet area where we wanted to build the
Lake Limerick ballfield. I spoke to DOE wetlands people several times, and walked
the area with them three times, to see if we needed to do anything about wetlands.
Finally, the DOE employee said to go ahead and build the ballfield.
This was a clear request, and a clear assurance. What if he was wrong, and the
Sierra Club sues me? Can I sue D.O.E., or was I responsible for knowing the rules?
One answer could be in the availability of the rules. If the code in question is
available to the public, without the need for interpretation, then the public is likely
going to be held responsible.
On the other hand, if it is not available, or involves interpretations that
cannot be resolved by reference to the rules, but require a site inspection, then I
think the municipal employer may be responsible.
On the third hand, I am only guessing at most of this. I hope that this helps
clarify things at least a little for you.
Your best course of action is to make no mistakes.
Again, please talk to your own county or city attorney about particular
questions, and do not act in reliance solely on this memorandum.
To repeat my conclusions, when a municipal employee makes a mistake, and
there is damage:
1. Usually, people do not have the right to rely on building inspectors,
etc., to insure code compliance. People are responsible for code compliance on their
own projects.
2. If there is a special relationship with a municipal employee, a private
person may have the right to rely on that advice.
3. For a special relationship to exist, there must be a clear question, a clear
assurance by the employer in response to the question, and the private person must
have a right to rely on the assurance.
4. Usually, private people do not have a right to rely on an inspector's
assurance. They do, when they cannot otherwise access the rules and regulations.
One possible way of looking at this might be whether the regulations require
interpretation in light of particular facts.
5. There are no doubt other ways a special relationship can arise.
l �
INDEX
Pie
EXAMINATION BY CLIFT: 2 - 18
EXHIBITS •
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Byerly 'Ong
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over ra in coupon he
work order was posted
General Services -
A Belfair family has filed suit in Mason Coun to determine whattys the owners have S
Mason County Superior Court Departmeernmits they would need. property.
The suit say
against Mason County asking county p permits were subsequently received three let-
damages for loss of use of property They were told no p at the area was not ters, ber S
1990,
the have been directed to needed and tetlands,the suit says. telling them th y must remove eehe b
which y and filling. considered w laced becaus
stop grading Work on the project was in prog- fill which wasp
In the suit Jerry Byerly,Mr.and area is considered wetlands. rec
Mrs.William Byerly,Mr. and Mrs. ress between September 2 and 5, The court action asks for an a`h',
they were con- Wa
Robert Byerly and Mr. and Mrs. b9 he plaintiffs say,s.On September unspecified amount of damages �
John Byerly say they own p p y Lemore Marken of the
in Belfair which they planned to fill tacted by es and also asks for reimbursement the E
from the county for the cost of ha
and grade for commercial or b�usi- Department,who told athem they removing the fill if it is determined ha
ness use in September of 198ork, the would need a grading permit and the fill must be removed. lea
Before beginning
suit says, they contacted the on September 14, 1989, a stop-
inc
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A N DEPARTMENT OF COMMUNITY DEVELOPMENT
U =
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J x Y y Planning - Landfill - Utilities
1864
TO: Gary Burleson
FROM: Mason County Planning Department - Sean Orr & Erik
Fairchild
DATE: November 13, 1991
RE: Byerly enforcement action
On December 20, 1990 the Mason County Planning Department with
direction from the Mason County Prosecuting Attorneys Office sent
a final certified letter to Mr. John Byerly. Mr. Byerly did not
respond to the letter in the allotted time period, thus the file
was turned over to the Prosecutors Office for final enforcement
actions .
Mr. Byerly filled a biological wetland associated with Lynch Cove
in Hood Canal . A stop work order was posted on September 14, 1989 .
Over the last two years the county has repeatedly tried to resolve
the situation but has had little success . Therefore, the Planning
Department is requesting a response on the status of the file that
was turned over to the Prosecutor' s Office in January of 1991.
This action has resulted in the Byerly family filing a lawsuit
against the county for holding up development on their property.
At your convenience please provide this department with an update
on the status of this case.
1
Thank You,
Sean Orr
Gary Yando,Director of Community Development • Erik Fairchild,Planning Director
Mason County Bldg. 1111 9 426 W. Cedar • P. O. Box 578 9 Shelton,WA 98584 • (206) 427-9670
OFFICE OF THE
MASON COUNTY PROSECUTING ATTORNEY
GARY P. BURLESON 411 N. FIFTH STREET
PROSECUTING ATTORNEY SHELTON, WASHINGTON 98584
PHONE(206)427.9670 exr. 411
DATE. October 1, 1991
OCT - 11991
TO: Erik Fairchild, Mason County Planning Director j
FROM: Mike Clift, Deputy Prosecuting Attorney GENERAL SERVICES
RE: SHORELINE VIOLATION - BYERLY
Previously we discussed the impact of a General Services Policy Memo on a
pending application by John Byerly to erect a building on the same property
involved in a shoreline violation.
The policy memo forbids issuance of a building permit for property involved
in litigation. In other words, where the granting or denial of a previous
permit application is being appealed to either the Shorelines Hearings Board
or to the Courts, the policy has been to hold up processing of other permits
for the same property.
I reviewed the policy memo with you and concluded that its language is too
broad.
You have informed me that while Byerly's pending building permit application
is on the same parcel as the unlawful fill, it won't directly impact the filled
area which forms the subject matter of the current lawsuit against Mason County.
Site inspection reveals that if a building were to be erected according to
the site plan, it would not interfere with any court ordered restoration plan
for removing the fill.
Accordingly, we take the position that Mason County has no legal basis for
denying an otherwise lawful building permit solely because of an unrelated
shorelines violation which happens to be in litigation.
We hope this addresses your concerns.
MEMORANDUM
TO: Erik Fairchild
FROM: Sean Orr
DATE: September 27, 1991
RE: Byerly Pole Building
It is in my opinion that permitting this structure would have no
implications on the removal of the fill if it is determined that
the fill must be removed. However, the proposed pole building is
located on the property that is in litigation.
The only benefit in holding the permit would be that permits could
be used as a negotiating tool for fill removal .
.P CERTIFIED MAIL
,/a • DEPARTMENT OF THE ARMY
SEATTLE DISTRICT, CORPS OF ENGINEERS
J P.O. BOX C-3755
SEATTLE, WASHINGTON 9 8 1 24-2 255 1990
REPL TO JAN 1 2 iggn
ATTENTION OF
Regulatory Bran c6
11r. Gary H. sexton
S,:xtnn and 3ratt
1126 Highland Avenum
3rs +ertm, a.shilgton 98313
_ *ieference: +oy3-4--C13137
overly, John
oc�ar hr. Sexton:
Wa tsavp revie►3e.: your letter of 'GctQber 17, 191,19. T=)p area of
unauthorized fill (see enclosure 1) is flat and at the fcot of a stef--
slope. forested/Scrub-shrubI wetlands surround the fill area in question.
fit? is T SLlit, our })osit,jon that we"'1 ja fjavp, ^?ate f?il='t. £-`ti:.l�.f15 u,,c:!?an(jF'(�.
T I^ �-,n,.Ausure also ��!(A is the hydrolaqic conn4ct#on beetween the site anct
Homi Canal through Union SlcWh. Bec3ust, there are: no ep arent t raph11.
'creaks ont�:jnen t.,As connection arld the fill, the fill site I.C. considared
onticu ous wit,i Hood Canal. Fi4.
lling of tiiesp e*lancs would have recoir d
an tnjivioual 3epartmant of trio Armv Sectiai 404 per:--At. N&tio.jwio,�- Per,,f.t
#26 ��es nc)t ar4p ly.
We !iav : also received a letter fro:,*, Mason County dated 3anuary 4, 1989,
,-egi1rinG you tc, swriit plans for removal of the wetland fill. W_: supxrt
this .removal action and ramire a copy of Chis r oval plan by January 19,
199,% Thp unauthorized Pill r gust be removed down to the original rrouncj.
If restoration is -adpouately r(yviiplRted, we will resolve this violation.
Fa i Lure to reFxvn tnc unaUth.'r lZell fill fray result if' future laqpl action.
5! t.t1:1 you nave soy qL:sstxorts, please Mchntacf Mr. ^kris McAuliffe,
tole )hone (206) 764-3495.
Colonel, Corps of Err,tneers
01stricct End ineer
Copy f urni.s`►ed:
Envirun �:ntal ?rot,-,rtlon At!n-:y/Mr. ferry Voffr-an
mason County :.1e2art`-,,nt of Genera I%ryj,ce s/Ms.
nr. JoMi Byerly
f
r'
Law Offices of b w E ry
Gary f. Sexton
Attorney
Clary H.Sexton �k_j
RECHWE
JAN 2 3 193''
January 18, 1990 MASON COUNTY
PROSECUTING ATTORNEYS OFFICE
Mike Clift
Mason County Prosecutor ' s Office
411 N. Fifth
Shelton, WA 98584
RE: Byerly/Mason County
This letter is to confirm our telephone conversation of
January 17, 1990. As agreed, Mason County will take no
action in regard to those matters set out in Lenore Marken ' s
letter dated January 4, 1990, until after your office has
had an opportunity to discuss it further with Lenore and
after contact has been made with the undersigned .
Very truly yours,
GARY H XTON
GHS/cw
1126 Highland Avenue
Bremerton,Washington 98310
(206) 479-5808
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United States Region 10 Alaska __^ D
/ Environmental Protection 1200 Sixth Avenue Idaho Ara
Agency Seattle WA 98101 Oregon
Washington
EPA JAN 2 9 1990
Reply To
Attn Of: WD-138
Colonel Milton Hunter
District Engineer
Seattle District, Corps of Engineers
Post Office Box C-3755
Seattle, Washington 98113
ATTN: Chris McAuliffe
RE : 071 -OYB-4-013157, Joh=Byerly, January 12, 1990
Dear Colonel Hunter:
We have reviewed the referenced removal directive concerning the
unauthorized fill placed in wetlands adjacent to Hood Canal near Belfair,
Washington.
We support this removal directive and request a copy of any
correspondence which sets a deadline by which the fill is to be removed. We
recommend the fill removal and site restoration work be completed as soon as
possible, but no later than April 1 , 1990. EPA is not interested in taking
the enforcement lead at this time, but would be if the county and Corps cannot
obtain voluntary site restoration. Please keep us informed of significant
development in this case.
For further coordination, please contact Gary Voerman of my staff
at 442-8513.
Sincerely,
William M. Riley, Chief
Water Resources Assessment Section
cc : Ecology (Jim Anest)
i
STA
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889 D
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY JUN 0 8 1990
Mail Stop PV Olympia, Washington 98504-8711 • (2(Y)) 459-{)(X)()
GENERALSERVICES
June 7, 1990
Ms. Grace Miller
Mr. Erik Fairchild
Mason County Planning
P. 0. Box 186
Shelton, WA 98584
Subject: Shoreline site inspection field notes.
After attending the pre-construction meeting for the Sand Hill Road/SR-300
road widening project, I made the following site inspections.
1. Sims/Christiansen proposed bulkhead adjacent to SR-302 and North Bay,
Case Inlet.
Mr. Sims indicated that his front yard was inundated with water several
times a year. He attributed this high water primarily to tides higher than
about +12.5 feet with additional input from high creek flows near his
property and increased ground water flows. He noted that the high water
table would probably constrain his proposed septic system to be a 'curtain
type' installed at one of two high spots on his property. Much of the fresh
surface water on his property comes from the bluff behind his lot, across
SR-302. Also, a culvert on or adjacent to his property discharges water
from SR-302 ditches and this bluff.
The Ordinary High Water Mark (OHWM) definition that appears to apply in this
case is found in WAC 173-22-030 (6) (a) (ii) : . . . the landward limit of
salt tolerant vegetation. " It appeared the salt tolerant plant pickleweed
(salicornia) was growing in the front yard within 10 feet of the front
porch. However, this needs to be determined by a qualified botanist or
wetland ecologist. If salt tolerant plants are not present in the front
yard then the OHWM would appear to be the edge of the bank at the waterward
edge of the vegetated area of the front yard.
Since I do not have the precise location of the shoreline environment
boundaries , and because the Mason County Shoreline Master Plan (SMP) text
differs from the map, the property may be in a Rural, Conservancy, or
Natural area. Bulkheads and fills are not permitted in the Natural
environment. Non water dependent upland fill is a conditional use in the
Rural and Conservancy environments. Non water dependent fill waterward of
the OHWM is prohibited in all environments.
r
Grace Miller and Erik Fairchild
June 7, 1990
Page 2
2. Ernesto Iulliano wetland fill adjacent to SR-302 and North Bay, Case In-
let.
While standing on the east shoulder of SR-302 and looking down on the site,
it appears fill is still in the wetland and I could not see any indication
of fill at the disposal site, as indicated on the Plot Plan submitted to the
Shorelands Program on 5 March 1990. I understand that Mr. Iulliano is
currently searching for a wetland ecologist to delineate the wetland
boundary.
3. William Beyerly mobile home lot adjacent to SR-3 in Belfair.
Since there was no Mason County staff with me, I did not go on the site but
observed it from the west shoulder of SR-3. It appeared the are two levels
of fill, the western most being further down the slope, relatively flat and
covered with tall grass. This lower fill appears to be close to the edge of
a Palustrine Forested Seasonally Flooded wetland (National Wetlands
Inventory Map, copy enclosed) . It also appears the fill is above the 20
foot elevation contour and above the OHWM. However, the location of the
OHWM and the wetland identification should be made by a qualified wetlands
ecologist or botanist.
In determining the OHWM WAC 173-22-030 (6) will probably apply in this area,
southeast of the Union River and northwest of SR-3. Note there is a creek
less than 200 feet from the fill depicted on the "Plan View" . If this creek
is tidally influenced its banks may be the OHWM. Again, this determination
should be made by a qualified person.
4. Port of Dewatto Camp Grounds on the southeast shore of Dewatto Bay and
the Dewatto River.
This is actually two sites about 3/4 mile apart. The Old Oyster House site
was fenced and had a locked gate. A weathered sign advertised Camping and
Boat Launching cost $3.00 each. There was a locked fee collection box on
the Oyster House and a list of Camp Ground Rules. There was no sign of any
filling or camping use having occurred in the past several months.
The second site is east and upstream along the Dewatto River. This site
appeared to have been cleared and graded to accommodate 60 or more
unimproved camping sites. These sites did not appear to have any utility
connections. There were two portable restrooms and a covered community
kitchen facility built on a concrete slab.
Grace Miller and Erik Fairchild
June 7, 1990
Page 3
There was a fee collection box which was inspected by a person driving a
Port of Dewatto pickup truck while I was on-site. The Dewatto River is ap-
proximately 200 feet from the portable restrooms. No other vehicles or
persons were on-site at the time. The camp ground was surrounded and
flagged by red plastic tape. Several old gravel roadways leading to the
River were also blocked off by tape.
Signs were posted listing the camp ground rules and fees and stated that the
site was Port of Dewatto property. Camp fire sites and trash were present
within 50 feet of the River bank.
The boundaries of the Port's property and/or the campground need to be
determined. Then its location relative to the OHWM of the Dewatto River can
be determined. It should be noted that recreational facilities are a
conditional use in all shoreline environments. Shoreline substantial
development and conditional use permits are required for the camp ground if
it is within 200 feet of the OHWM Dewatto River.
Thank you for providing the site plans and maps. I am looking forward to
,joint site visits with all of your staff. Please call any time so we can
work out a schedule at (206) 459-6762 or SCAN 585-6762.
e: Sincerely,
I:
Donald J. Bales
Shorelands and Coastal Zone
Management Program
DJB:de1
Enclosure
t':
15:57 D.O.E. BAP,AN HALL p7
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ST ATC 01 lVA`+HINGTC i d
DEPARTMENT OF FCOLOGY
hldd Sf0p PV•11 • (1Y11.1pit. Washington 989.4 1i'11 • i20b) f 5l3-1WO
September 6, 1990
Mr. Erik Fairchild
Mat;on County Planning
411 North 5th Street
Shelton, WA 98584 '
Re; yS r_erl- aria! NrXhart Far s_S_ te_ Inspections
Dear Mr. Fairchild: .
Thank you for your patience in wait.inS fur our staff c:.ommerits on the above rM '
Site visits. We appreciate you and your staff taking time to arrange for ; `.
and attend these site inspections. For the record, those present for the
aitn inspections were:
Erik Fairchild & Dun Brush - Mason County Planning , ..
Chris MGCauliff - Corps of Engineers
Al Wald & John Marshal Ecology Shorelands Program d41
'1'tke BYERLY SITE, is a mobile home parking area adjacent to the west side of �Y
State Route 3 (SR-3) sout.h oC Bulfair, it-, approximately the NE quarter of
the NE quarter Section 32, Township 23 North, Raciee 1 West . The site in-
cludes a fill area cut from the adjavdLlt uplands And pushed into a wetland ;
tributary to Union Slough, '
The wetland includes a continuous, flowing stream tributary to Union Slough.
The flow rate was estimated ac 0.5 to 1.5 cubic feet pri %ec:uad (cfs) at the
time of the site inspecrion. The wetland extanda downstream to a farm road
and culvert that appears to be wiL11111 200 feet of the upper extent of tidal
influence from Hood Canal. The corps of Engineers considers- L11e wrLlnad and
stream to be "adjacent" for their purpoies. The wetland buffers both the
quantity and quality of runoff from SR-3 acid various commercial developments
along the highway. The filling on the Byerly site has impacted and lessened
the ability of the wetland to perform these fuitctiuiis. It is our 9PJnion
the wetland meets the hydraulic criteria for" assucIatiuti with Un on Slovkh
and Hood Cg Al
f
The NEYH'ART FARM SITE near the Tahuya River is upstream of its estuary on
the north shore of Hood Canal. The 1988 Flood Insurance Rate Map LtidiLdtGs
the Neyhart farm includes portions of the 100-year f•loodplain of the Tahuya
River. More detailed survey information is needed to confirm this. The
site includes recent fill on one of the side channels of rice Tahuya River.
The Farm manager reports the channel used to Garry flows during the winter.
Based on his walking inspection of the upper reach of this channel , it may t
currently reconnect with the main channel of the Tahuya River, 1
c,
rs- .
r 09,'05.`'30 15:58 L.Cl.E. BARP.14 HALL 005
`5
1
Mr, Erik Fairchild
September 6, 1990
Page 2
This side cha1111el has bVUiI completely blocked with several hundred cubit
Yards of local soils bulldozed from the surrounding area, It is our opinion
Lh1s 5itle %;ttarinel and adjacent wetlands i a functional part of the Tahuya
River and meets the hXdraulie criteria_ association
. f
Ba}ed oLt the forgoing we believe these two sites meet the definition of
"wetlands" in Chapter 90, 58,030(2) (f) RCW, and "Associated wetlands" in
Chapter 173-22-030 WAG. As such, the sites fill r,,indet 0,.e •jut•isdLcLiut). of ,
the Shoreline Management AcL and t.11e, Mason County Shoreline Master Program
(MCSMP) . TL appears truth sites contain unpermitted landfills in violation
of Chapter 7 .16.1.30 of the MCSMP, which stales in part-, r
t
Landfills are prohibited waterward of the ordinary high water mark or
on biolugic:xl wetlands, except that they may be permitted as a Condi- �
tional Use for aquac,ultural practices and water dependent uses where no
upland of structural alternative is possible. +
Lanklfllls arc not permitted on estuaries, tidelands, marshes, ponds or v
swamps, except Lhat they may be allowed for water dependent uses as a
Conditional Use.
Lattdfilla ary tiut permitted in floodplains unless it can be clearly }.
demonsL.cat-ecl (.ha Gl,e 8e.oltydraulis and fl.�vclplair, storsge capacl y will
not be .al:er.ed Lv lI1C=IEi1SC flood hi;.zard or other damage to life or
property. '
Y
Landfills shall not cl',srupt nonzr,&l s,,trfac:e water rrainagc , 1
As you are aware, local governments have primary responsibility for enforc-
ing their Shoreline Master Programs. Ecculugy' S Shurelands and Coastal Zone �rY4
Management F'rc%tam has sume rC,�uurces -available to pursue enforcement . Par
further assistance wish enforcement issues, please contaeC Jim A.ncst,
Shoreline Enforcement (:ourdina or at (206) 459-6795 or SCAN 585-6795,
Sincerly,
Donald J. Baies
ShOrelirle ri--IM I �lr�Ji t?1�1,Mt.`I
Shorelands and Coastal none
Mcin:.gement Pr grsm
DJB:del
cc: Al Wald
Jahn Marshal
i
Jim Anest
Joan VAlil<Anjp
Chris McOamliff, GOF
4.1
TA
s re o�
0 4
°
STATE OF WASHINGTON
DEPARTMENT OF ECOLOGY
Mail Stop PV-11 • Olympia, Washington 98504-87 1 1 • (206) 459-6000
September 6, 1990
Mr. Erik Fairchild
Mason County Planning
411 North 5th Street
Shelton, WA 98584
Re: Byerly and Neyhart Farms Site Inspections
Dear Mr. Fairchild:
Thank you for your patience in waiting for our staff comments on the above
site visits. We appreciate you and your staff taking time to arrange for
and attend these site inspections. For the record, those present for the
site inspections were:
Erik Fairchild & Don Brush - Mason County Planning
Chris McCauliff - Corps of Engineers
Al Wald & John Marshal - Ecology Shorelands Program
The BYERLY SITE is a mobile home parking area adjacent to the west side of
State Route 3 (SR-3) south of Belfair, in approximately the NE quarter of
the NE quarter Section 32, Township 23 North, Range 1 West. The site in-
cludes a fill area cut from the adjacent uplands and pushed into a wetland
tributary to Union Slough.
The wetland includes a continuous, flowing stream tributary to Union Slough.
The flow rate was estimated at 0.5 to 1.5 cubic feet per second (cfs) at the
time of the site inspection. The �..etland extends doi•n:stream to a farm road
and culvert that appears to be within 200 feet of the upper extent of tidal
influence from Hood Canal. The Corps of Engineers considers the wetland and
stream to be "adjacent" for their purposes. The wetland buffers both the
quantity and quality of runoff from SR-3 and various commercial developments
along the highway. The filling on the Byerly site has impacted and lessened
the ability of the wetland to perform these functions. It is our opinion
the wetland meets the hydraulic criteria for association with Union Slough
and Hood Canal.
The NEYHART FARM SITE near the Tahuya River is upstream of its estuary on
the north shore of Hood Canal. The 1988 Flood Insurance Rate Map indicates
the Neyhart Farm includes portions of the 100-year floodplain of the Tahuya
River. More detailed survey information is needed to confirm this. The
site includes recent fill on one of the side channels of the Tahuya River.
The Farm manager reports the channel used to carry flows during the winter.
Based on his walking inspection of the upper reach of this channel, it may
currently reconnect with the main channel of the Tahuya River.
3 �'3
Mr. Erik Fairchild
September 6, 1990
Page 2
This side channel has been completely blocked with several hundred cubic
yards of local soils bulldozed from the surrounding area. It is our opinion
this side channel and adjacent wetlands is a functional part of the Tahuya
River and meets the hydraulic criteria for association.
Based on the forgoing we believe these two sites meet the definition of
"wetlands" in Chapter 90.58.030(2)(f) RCW, and "Associated wetlands" in
Chapter 173-22-030 WAC. As such, the sites fall under the jurisdiction of
the Shoreline Management Act and the Mason County Shoreline Master Program
(MCSMP) . It appears both sites contain unpermitted landfills in violation
of Chapter 7.16.130 of the MCSMP, which states in part:
Landfills are prohibited waterward of the ordinary high water mark or
on biological wetlands, except that they may be permitted as a Condi-
tional Use for aquacultural practices and water dependent uses where no
upland of structural alternative is possible.
Landfills are not permitted on estuaries, tidelands, marshes, ponds or
swamps, except that they may be allowed for water dependent uses as a
Conditional Use.
Landfills are not permitted in floodplains unless it can be clearly
demonstrated that the geohydraulic and floodplain storage capacity will
not be altered to increase flood hazard or other damage to life or
property.
Landfills shall not disrupt normal surface water drainage.
As you are aware, local governments have primary responsibility for enforc-
ing their Shoreline Master Programs. Ecology's Shorelands and Coastal Zone
Management Program has some resources available to pursue enforcement. For
further assistance with enforcement issues, please contact Jim Anest,
Shoreline Enforcement Coordinator at (206) 459-6795 or SCAN 585-6795.
Sincerly,
_D/ '9�11X4 Z�C�
Donald J. Bales
Shoreline Permit Coordinator
Shorelands and Coastal Zone
Management Program
DJB:del
cc: Al Wald
John Marshal
Jim Anest
Joan Velikanje
Chris McCauliff, COE
Dear, Mr, . Dyer,-1 y".
U 1.)()n r,,e v i e w yuk.w, violati(:;)n (:::ase at the Ma4,,,:'C:)r.)
17 e 1:.i a I,--t m e I-)t i t, 1--i a s come to oLm afttentiori that 1)alli� 1::)een a
-tak:eri by yait..t tl--ie illegal, fill
Your. 1-.)1,-o 1.)e I--t y a t NE q ua. I,--t e I,- (-.if -the NE q u a e r' Sect j.on .12
'T'(::)w n i!. !-,I a.1::) 2:1 1\1 o r'''t 1--i , R as n g e 1. W e s t
Plewnie , 1::)e acJvi0.-.Bed , Mi. nyer-ly, that your catsm iiiii irl pr;;(l")C.....f"....�A"i..,."I
raf +o11(.:)w thr--ough and at all levels a f e n+o I-.c.e m e ri t
agger)cies involve(:J to this point.
zltc'aC::k:9r'•C:)Unc::1 (:::a ii,i e 1i i s t a r y r e v a 1.iii, exc(•?1:AJ. (::)r)a1, efforts 1:-.)y i n v(::)1.v e(:J
agen(:::ies wotk ir)
Y(::)L.L the Asses;smervt. of
YOU are her-c-,by penalizec.J J.n accordarice with C ..q:)ter '7. 32. 02C) (2) a
fir') . 'in tlie amoukrit c.)f Ili".50. 00 +or +ai ].Ure -tc::) t(::) a Natiw.-?
a f Vi(-)].iiktiori wr-iU-..en I..)(J sent 1::)y I'll i::i(::)n Co t_t ri t y D e I.)a I,-,t ryi e ri (,.),f
G.-Iener-al Ser-i v(:::ei:5 Jaru.tary 4 , 1-989.
This., pLmalty w i 1, 1. a c k.t In u 3,a t e a t :ate cm, $50. 00 a n t-1. 1
(:::(::)rAac:A.-. is made witi"I OUr-- Departmerit (:::cr)cer-ning r--emecfl.istion of the
sk.A.').je. ct w e t 1.a ri(I i:5 c::)I,,- t5 dayii4 from yout-
wh j, ch ever- is less.
A n(::)ri^ r--e i.iii 1,.,)(::)n cl;e a c t j. n a t erid o f :1.'5 d a y s"; will. initiate 6%
change in t 1--)e classificatiori of y(-.)ur-- v.i. (::)1atiori +r,om t 1--i e C.i vii, 1.
p)r o c e d U r e t o t I—)e Cr-iminal pro(:::(,"..?dUre iri w 1--1 i c h c a s e YOU Wi 11. be
1--i e I d g U i 1,t y 0 f a g I,--o s s (n i s c-.1 e M e a ri o r a n d C 0 Li 1 d r i s 1< i m 1::)1i sizi ca ri m e r0-...
Pens.-.O.ty paymerit will. ruxt. be :i.r') lie(A C'.)+ r..q)pr-opri ate and adeCjUz'..kte
vi e t I a ri d I,--e fn e(j 4 L a t i
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YOU-
Si
Wendy Van Eatc::)n I ev M.1. k e R y r ri e
Shoreline Planner- 0 i 1-
11 a i;.,(::)n C a u ri t y (3e ri e r a 3. e r vi (:e s
WVEL/wvel
MASON COUNTY
DEPARTMENT of GENERAL SERVICES
Mason County Bldg. III 426 W.Cedar
P.O. Box 186 Shelton, Washington 98584
(206) 427-9670
building environmental health fire marshall parks & recreation fair/convention center planning
Mr . John Byerly December 20 , 1990
P.O . Box 133
Bel fair , I,JA 985 $
RE: Wetland fill violation
Clear Mr . Bxer 1 `i ,
It has been determined that the wetland on your property is a
,jurisdictional wetland as delineated by the United States
Army Corps of Engineers and the Department of Ecology . Mason
County is therefore authorized to regulate this particular
wetland with the Mason County Shoreline Master Program which
states in Section 7. 16. 130 :
of Landfills are prohibited waterward of the Ordinary
High Water Mark or on biological wetlands, except that
they may be permitted as a Conditional Use for
aquacultural practices and water dependent uses where
no upland structural alternative is possible . "
You are hereby notified in this certified letter that you are
in violation of the Mason County Shoreline Master Program
under the above mentioned section . Immediate removal of the
fill that has been placed in the wetland and proper
restoration of the disturbed area must be completed .
You must subm i t plans _.ho!.ki i ng the removal of the f i 1 1 and the
erosion control measures to be incorporated and maintained
throughout the restoration period to our office within 15
days from the date of this letter .
I have discussed this matter with the prosecuter' s office and
they are prepared to file a criminal complaint or seek civil
penalties of $1 ,000 against you for this violation , if you do
not make a satisfactory response within 15 days.
R Tz:�u
,
Sean Orr , Planner
Mason County
CC : Gary H . Sexton , Attorney
Mike Clift , Prosecuting Attorney
Erik Fairchild, Planning Coordinator
Jim Anest , WDOE
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TO : Jim Anest
RE : Byerly wetland fill violation
Meeting : 12-27-90
The following is a timeline for your information on this
particular violation .
/14/89 - Stop work posted for landfill in biological wetland
Shorleine Master Program Sections 7.04 .030 &
7. 16 . 130 .
9 20/"89 - Site inspection with with Chris McAuliffe and Norm
Hanson of Army Corps of Engineers and Lenore Marken
and Erik: Fai rch i 1 d of Mason County to verify and
delineate the biological wetland associated with
Lynch Cove of Hood Canal .
10/2/89 - Certified letter sent to John Byerly explaining
stop work and reque�_ting removal of fill .
/
10/20/89 - Letter received by Lenore from Gary Sexton
Attorney for• John Byerly .
10/20 89 Send letter with facts and copies, Sections from
SMP . CC to Mike Cl ift ,
1/4/90 Revised letter sent to Mr . Sexton . Lent letter
certified to Mr . Sexton and Mr . Byerly . CC to
Mike Clift , Chris McAuliff , and Bruce Smith .
1/19'90 Received letter from USACOE notifying Mr . Byerly
of the violation .
IN f---1916190 Received letter from DOE about their site
inspection and recommendations.
sl '�I'—/ 1 1/22/90 Sean Orr drafted letter to be sent to Mr . Byerly
�pCf and his attorney requesting removal or further
action by the county will be taken .
12/20/90 Mike C:l ift approved letter to be sent to Byerly.
�oG Contacted Jim Anest , WDOE , about Bye1y fill and
� �av to request .joint action to be taken against
Byerly .
12/2O/?0 Sent certified letter to Jahn Byerly requesting he
submit plans for removal within 15 days or the
county would take further action to correct this
matter .
12/27/90 Site inspection with Jim Anest at. Byerly site .
MASON COUNTY
DEPARTMENT of GENERAL SERVICES
Mason County Bldg III 426 W. Cedar
P.O. Box 186 Shelton, Washington 98584
(206) 427-9670
building environmental health maintenance landfill parks&recreation fair/convention center planning sewer&water
Mr. Gary H. Sexton January 4, 1989
Sexton & Bratt
1126 Highland Ave.
Bremerton, WA. 98310
Dear Mr. Sexton,
In reply to your letter dated October 17, 1989, regarding the John
Byerly property, the Coastal Zone Atlas of Washington for Mason
County is not the primary controlling document regarding the right
to grade and fill. The Coastal Zone Atlas is used by the Planning
Department to determine critical biological areas, slope stability,
coastal flooding, geology and is used as a reference when doing
research and preparing staff reports.
Mason County does not presently have a clearing and grading
ordinance, but one of the regulating ordinances the Planning Staff
works with on a daily basis is the Shoreline Master Program.
According to the Shoreline Master Program, Section 7. 04. 030,
Ordinance No. 99-84, Environmental Policy, and the National
Wetlands Inventory Maps from the U. S. Department of the Interior,
Fish & Wildlife Service, 1987 a portion of the Byerly property is
an associated wetland of Lynch Cove and development within this
wetland is regulated by the Shoreline Master Program. According
to the Shoreline Master Program, Section 7. 16. 130 "landfills are
prohibited waterward of the ordinary high water mark or on
biological wetlands, except that they may be permitted as a
Conditional Use for aquacultural practices and water dependent uses
where no upland or structural alternative is possible. "
s
SZ1� --��1.A site inspection of the Byerly property on September 21, 1989
conducted by Mason County Planning Staff and Army Corps. of
Engineers Staff reconfirmed our prior determination : fill has been
placed in a biological wetland. Section 7. 32. 010 of the Shoreline
Master Program states "the administrator shall issue a notice and
order to the owner or tenant of such premises advising such person
of any violation and requiring him to take whatever action is
necessary to comply with the Act and this ordinance, " thus the
no✓ #�// 21g9 request for the removal of the fill in our letter to Mr. Byerly
dated October 2, 1989.
The consultations with the Mason County Planning Staff, as stated
in your letter, have been investigated and it has been determined
that the person inquiring about ordinances in our office
specifically asked for the Coastal Zone Atlas, researched what they
wanted to know and assumed it was the controlling document. To
this extent, four of the five Planners in the department use the
Coastal Zone Atlas as a reference, but all know it is not the
"controlling document" and do not use it as such.
As required by the Mason County Code, "Any person violating any of
the provisions or failing to comply with any of the mandatory
requirements of resolutions or ordinances of the County is guilty
of a misdemeanor. Any person convicted of a misdemeanor under the
resolutions or ordinances of the County shall be punished by a fine
of not more than five hundred dollars, or by imprisonment not to
exceed ninety days, or by both, unless otherwise required by state
law. Each such person is guilty of a separate offense for each and
every day during any portion of which any violation of any
provision of the resolutions or ordinances of the County is
committed, continued or permitted by any such person, and he shall
be punished accordingly. "
If the Mason County Planning Department does not receive plans
showing the removal of the fill from the wetlands and the erosion
control measures to be incorporated and maintained throughout the
restoration period with a time line or a similar, adequate response
within fifteen ( 15) days from the date of this letter, a citation
will be issued on January 19, 1990 and the matter will be turned
over to the Prosecuting Attorneys Office.
If you have any questions, please contact Mr. Mike Clift, Mason
County Prosecuting Attorney at 427-9670. We look forward to
hearing from you.
Sincerely,
Lenore Marken, Planner
Dept. of General Services
LM/lm
cc : Mr. John Byerly
Mike Clift, Prosecuting Attorney
Chris McAuliffe, Army Corps. of Engineers
Bruce Smith, Dept. of Ecology
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SJMASON COUNTY
DEPARTMENT of GENERAL SERVICES
Courthouse Annex I N. Fourth & W. Cedar
P.O. Box 186 Shelton, Washington 98584
(206) 427-9670
building environmental health maintenance landfill parks&recreation fair/convention center planning sewer&water
Mr . John Bverlv October 2. 1989
F . O. Bor. 1�-
Belfair , WA. 98528
Dear Mr . Byerly ,
On September- 14 , 1981' a Stop Work Order was posted on your prooerty
at NE 2'31-)1 Hwy . in Belfair because the creation -f :and
occurring on the site is in violation of the Mason County Shoreline
Master Program.
According to the Shoreline Master Proqram " landfills are prohibited
waterward of the ordinary high water mark or on biological
wetlands . " A portion of your property has been determined to be
wetlands associated with Lynch Cove and thus comes under the
jurisdiction of the Shoreline Master Program. I have enclosed
copies of the applicable sections of the Shoreline Master Proqram
for vour information .
On September 21 , 1989 staff members from the Mason County Plannina
Department once again visited the site along with staff members
from the U . S . Army Corps . of Engineers . During this inspection ,
the boundaries of the wetland were determined . All fill that has
been placed in the wetland , as shown on the enclosed copy of the
field notes , must be removed and the area must be restored to its
previous condition . i
Please submit plans showing the removal of fill in the wetland area
and the erosion control measures to be incorporated and maintained
throughout the restoration period to our office within 15 days of
this letter . We look forward to hearing from you .
Sincerely , T1 b
Lenore Marken , Planner
Dept . of General Services
LM/ lm
1-7
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Law Offices of
Sexton & Bratt
Attorneys at Law
Gary H.Sexton
Kent R.Bratt VV
October 17, 1989
OCT 2 01989
GENERAL SERVICES
Mason County Dept of General Services
Court House Annex 1
N. Fourth & W. Cedar
P.O. Box 186
Shelton, Wa 98584
ATTN: Lenore Marker
RE: John Byerly
Our office represents the Byerlys, including John Byerly. We
have received and reviewed your letter dated October 2, 1989
with great amazement.
On three occasions, prior to commencing the grading, the
Byerlys and a person performing the grading work, went to the
Mason County Department of General Services to determine if
any permits were required. On each occasion, a planning
department employee pulled out the Coastal Zone Atlas of
Washington for the Mason County area. On each occasion, the
department employee indicated that the Atlas was the primary
and controlling document regarding the right to grade and
fill . As you are aware, the Atlas is to scale, and is not
schematic. No where does that document indicate that it is
not accurate or cannot be relied upon for accuracy regarding
designations and use categories. Equally, no department
official suggested that the Atlas could not be relied upon.
The Atlas includes a color coded section entitled "Land
Cover/Land Use For Pierce, Thurston and Mason County. " On
each occasion mentioned above, the county employee assisted
and turned the Atlas to the color coded page for the Belfair
area. The depth for the Byerly property was discussed,
located, and measured on the map. The Atlas designates,
categorizes and describes the entire Byerly property as
"uplands, " and "Second Growth Mixed Forest" ( category 433 ) .
On each occasion, the county official agreed that the Byerly
property fell within that category. In fact, on site viewing
of the property confirms its designation as second growth
1126 Highland Avenue
Bremerton,Washington 98310
(206)479-5908
Page 2
Mason Cty Dept of General Services
October 17, 1989
mixed uplands.
The pre-existing Byerly property sloped downhill from south to
north. Additionally, a hill or mound ran along the
north/south centerline of the property, thus necessitating
removal of some stumps and a cut/fill of the existing ground
in order to obtain a level area. Only a very small part of
the northwest corner of the property ( not the large section
marked on the diagram attached to your letter) was marsh.
However, as you know, many properties contain dips or low
points. Naturally, that does not suggest that the small, low
area is "wetland" for development purposes.
Your letter of October 2, 1989 states further that the fill is
in violation of the Mason County Shoreline Master Program. In
that regard, it must be remembered that when the three
individuals previously met with the planning department
employees, they were led to and shown the Coastal Zone Atlas,
not the Shoreline Master Plan. The planning department did
not pull out, or discuss the Shoreline Master Plan.
Presumably, that was because the Byerly property is located
more than one-half (z) mile from the Hood Canal Shoreline. No
county employee suggested or indicated that the Byerly
property was subject to the Shoreline Master Plan .
In fact, the Mason County Shoreline Master Plan does not
reflect that the Byerly property is subject to that plan. The
Shoreline Master Plan map indicates that the plan extends only
200 feet from the Hood Canal mean high tide. A heavy b:I. ue
line around the end of Hood Canal designates the 200 foot
control or planning area. That 200 foot zone stops more than
1400 feet west of the Byerly property. The Coastal Zone Atlas
of Washington, discussed above, reflects that the Byerly
property is separated from the shoreline area by a large
"upland" farm or grassland. That upland has several homes,
barns and other structures located on it. Nothing within
Chapter 7. 16. 130, cited in your October 2, 1989 letter,
suggests or confirms that the Byerly property is subject to or
within the boundaries of the Shoreline Master Plan. At this
point, we do not understand how "a portion of your property
has been determined to be wetlands associated with Lynch
Cove" .
Finally, your October 2, 1989 letter directs that the fill
shown on the "field notes must be removed and the area
restored to its previous condition" . We are unaware of any
i
Page 3
Mason Cty Dept of General Services
October 17, 1989
authority for that directive. We find no such authority
within the Shoreline Master Plan, nor does your letter cite
any such authority. More importantly, the grading operation
was performed only after three consultations with the Mason
County Planning staff. As noted above, on all occasions the
planning staff actively participated and directed the persons
to the Coastal Atlas. Any fill performed contrary to county
shoreline regulations or other regulations was proximately
caused by the negligence of the Mason County Planning staff .
Therefore, any direction or instruction that fill should be
removed must be accompanied with a plan regarding how the
county plans to pay the cost thereof. Naturally, any such
instruction at this point appears contrary to Mason County
requirements, plans or authority.
Please feel free to call so that we can discuss this matter
further.
V?F tr y yours,
SE ON
GHS/cw
cc : Mike Clist
John Byerly
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