Comments on Draft SMP Polices by Don Flora

8/7/2019 Comments on Draft SMP Polices by Don Flora

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(r , ' : :" . \ l

L287'l l'lanzanita Road

Bainbridge Island

Washington 98110

25 Apri l 2011

Rrand: R:rror Ci frr M:n:nor

Ryan Er ickson, Shore Pl-annerDavrd Sa1e, ETAC ChairSMP Workqroup

Re: Comnents on Draft SMP Policies

IVtry I'n Writing:

Since 2042, when the latest SMP revision began, I 've been puzzled bysome of the proposals and, as a former researcher, have pored throughI i teral ly thousands of references on buffers, bulkheads, shorel ine

dynamics, mar ine-related invertebrates and related subjects. I ,vewrr-Lten a score of manuscr ipt reports on the pert inence of thesematters to the Is land and Kitsap County; Ryan Erickson has received anrrmhar af l-ho rpapers.

Riqht now I 'm wondering how I can conment on Sect ion IV, whatever i tis, by tomorrow when that sect ion is missinq from the Web.

About Terms of Reference

At what point wi l - l - users of these ru les be told the meaning of

"ecol-ogical funcl ions"? And "ecosystem-wide processes"? (p. 3)

"No net loss" is certa in ly preferabl -e to "restorat ion " for severaL

reasons about which I 've wri t ten. However I 'm surprised at the

several references to "-restorat ion" in the text, g iven DOE's recent

adlustment of their posit ion and the text 's fai fure to ident i fy what 's

broke.

What does "naturaf character" mean (p.1)?

fn t imes past the staf f has general ly proceeded as i f leqal

inpl icat ions are somebody e-Zse's business. Perhaps so, but the

semant ics can make a d i f ference.

About Drift CelI Dlmamics and Bulkheads

At the pol icy level Lhe concern here is presumably to mainlain current

amounts of sediment movement al-ong the shore. The pr imary issue is

"Why?" Wel-I , to maintain sandspits, and,/or have the r ight amount (not

too much, not too l i t t le) smaf l gravel for upper-beach spawning places

Page 1 of 1



for forage f ish, and/or for sedlmenL movement out f rom shore tosl tnn1^1rl mal i ne -r ^- '^ ^-r ^ I -a a F'nr rrnno. beaches an d Of f ShOf euyyvL L rrrqrrr lu }, Id l rLJ AllU aaVqs- IU I u}J}/v r

needs, too much can be as harmful as too l- i t t le.

Now factor in dr i f t cel l-s and feeder bluf fs, about which much has been

said and you have maps. At Ehe sediment-receiving ("accret ion") end

of a long ceI I facing wide waters and backed by high bluf fs, so muchcol- luvium may plop onto the beach as to smother habitats, in some

cases for many decades. Al l of thj,s in natural set t ings. And even on

low-energy (smaff fetch) beaches where sediments is carr ied awayslowly.

Tf voi l have been LOld that Sandsni I s : re qhr;^r. i -^ i I r1 r ln, t COme f fOm! ) /vu r lqvu vuul r Lvrv urrqu oorruolJaLJ qrs Jl rr i r r^rr lY

the two shore geologists who've addressed you recent ly. Both were

unabfe to ci te cases here- This is an interest ing, perhaps cr i t ica l

sub- issue.

Natura l forces have been dragging sediment down and along beaches for

4000 years. Whi le not profound in the short run, a s ix- inch rate of

fandward bank ret reat can l -ead to upper-beach lower ing of a half- inchper year, a Iarge Lruckload annual ly f rom a typical resident iaf beach.

That 's enough to st r ip away a l - l - the surf smel t habi tat every 3 years.

Without bulkheads.

The share that goes of fshore versus longshore is unmeasured, as are

sediment f-[ow rates of f weather ing, ravel ing, and co- l ]apsing bluf fs;

resul t ing accret ion and deplet ion beach prof i 1es; and habi LaL

consequences. Nei ther for natura l nor protected beaches.

ALl these factors and mult lpTe unknowns arque for pol icy that is l ight

on the l -and. Why? Because afLer 150 years of shore proLecLion, with

haff the Isfand's beaches now bulkheaded, and harm unfound in vaf id

studies, the Badness of Bufkheads hardfv cr ies out for cont rof .

About Shorel-ine Buffers

The pol icy issues here are whether buf fers can and should be di f ferent

from what we have, and whether alternat ives to buf fers can meet the

exner-t ,af i ons we have f or no-torrr -h \ /eclFt: t eci corr idors.

In seeming contrast to Puget Sound beach and bluf f dynamics, there is

a very large l i terature being passed around rel -at ive to buffers. Most

is f rom farm count ry, where concent rat ions of manure or exposed soifs

impinge on streamwater qual i ty. And there are other signi f icant

d i f ferences from Puget Sound condi t ions. There is f i terature from

forest st reams (1 've been involved in some of that). I can provide

explanat ions of the i r re l -evance of most of th is research to Puget

Sound nearshores. 842-0109 -

The key rat ionafe for buf fers, wherever

seconcla rv f t tnct i on i s nrocl r r r - r ion. You

!L^* i q nrntoctinn AE PU L Ll lElttr f D Pr U LEU LIUII .

shoufd consider some specif ics,

1aaa 2 af



not just broad, vacuous terms like "ecosystem funct ions" and"degradat j-on". Here are some protecLion and producLion funct j-ons thatwider buffers won' t perform:

Better protect the Sound against stormwater-borne pollutants

Improve shade for surf smelt spawning

Provide more insects for safmon dletsTmprove nutr ient f fows to t idewater prey organisms

Speed the dynamics of inter t idal dr i f t zones

Slow the loss of backshore to the sea

Provide more sediment to dr i f t zones

Regulate t idewater temperatures to reduce plankton blooms orfncrease benthic invertebrate product ion

Improve the nutr i t lon of passing salmon

Increase eelgrass product ion

Increase the abundance of juveni le nor adult salmonProtect ocean-bound f ish f rom predators

Increase marine habitat dlversity

Restore marine condlt ions to beckon lost cod and herr ingIncrease diversity of upland landscapes

Enhance Lhe aLLr ibutes of nat ive pLant speciesDiscourage invasive animal species

Provide a better home for smaf l mammals

Enlarge depleted habitat for cavity-nest ing blrdsProvide more shoreside perches for eagles, k ingf ishersConserve water for inf i l t rat ion to aquifers

Protect aquj- fers f rom water-borne pollutants

Preserve play space for chi ldren

Nor perform better than a number of af ternat ives

Your goals may not be on th is l is t . I f they do, and you disagree withtheir appearance here, cal l me for wr it ten explanat ions. 842-0109. Ican provide manuscr ipt reports, wi th l- i t c i ts and al l , to support eachitem. My thesis is that wider buffer ing wil l not increase the

wel, fare of saJ-mon, other creatures, nor the beach i tsef f . Therel -^+f^ -

a! u vsLLU! woVS.

But what about our present buffers, 50 feet wide for most of us? Dof hev work" Are thev nrof er-f .i nn nrnrl , ,n i nn? Bett ef than therrrYr t/!vvuui r lY.

alternat ive, which, a long most Isfand shores, is resident ial

landscaping ? We have l i t t le data at the habi tat and organism fevel -s.

But we can aLf fook: Does our neighbor with a current ly correct buffer

have a bet ter-- looking beach, more b i rds or cuter cri t ters than we with

yards ?

At the pol icy leveL we shoufd consider the current status of shorel-1ne

biota and whether habitats are reaf lv in f l -ux.

About Re].evant Buffer Science

Page 3 of 1



I t 's hard to come by, for the Island and for the whole Sound. And toomuch of what we have is blemished. As Ryan Erickson can conf irm, f 'vefound faults in a number of the technicaf references cited to you byBrennan, Herrera, and others. The part iculars are avaifable from Lhestaf f or me (842-0109) .

Another matter is that "best" science has changed. For example, weall know that shaded streams have cooler water, and that is good forf ish. However a dozen Northwest studies have shown that product ion of€rtt i / i rrrrani lo f ishl is oreetof WithOUt Shade. Wafm Watef qlnn.rr1_ q--J

\Juwvrrr4v !+vrr / rv Y! YY f Lrrvuu Jrrqus. vvql rLL wquE! Juvvvt Lo

more prey and hastens growth so that even when some f ish die from theha:i_ nrrarr l I l - l iomass nrodrrr- l ion is oreater. A fathef SUlnris inr^l hrr l v!vuuuu r vrr EqLL! . n I o u l tgr Ju!yrf Jf l rv uuu

repl icated f inding.

And we've learned that l-arge numbers of juveni le salmon swim in manydi rect ions away from the sea, crossing open waters rather than edgingalong shores. And that predatory f ish do not lurk under resident ialdocks and f loats, whi l -e young salmon are not dif f ident about suchpLaces. I t 's al-so clear that few insects consumed by young salmon

der ive from trees; most are aquat ic. I can provide background on al l -of these science development.s. 842-0109.

At the po) icy levef , iL may be prudent to stay with the buf fer ingdimensions that we understand, leav ing the door open for opt ions whoseetf f icacv can L->r. qr lnnn rf ad hrt annl 'i aanf < nr f ttr f har <f r tr . l ttLUt CtreL JLUVy

-

About Natiwe Vegetation

I have attached a statement that quest ions the importance ofnat iveness - Here I point to the vufnerabi l i ty of popular nat ive

shrubs and trees. Dogwoods are g'onersf up and down the coast .

Madrones are infested by a rust (?) , apparenL along Highway 305 andelsewhere on the rs-l ,and. Rhododendrons have acqui red an insectparasi te that causes brooming and eventual death, one branch at at ime. Whelher Lhese pesls are nat ive or fore ign is i r refevant ; Lheypoint to the vulnerabi l i ty of nat ive species.

At the pol icy levef , i t seems whol ly prudent Lo leave veqetaLjon

decis ions up to owners, landscapers, garden experts, entomologists andpathol-oqists.

About "Conservancy" Notions

Conservancy" designat ions appear to be rooted in dogma more thanscience. Imposing the extra constraints envisioned here are not basedon speciaJ- problems nor unique resource va_Lues. Examples:

Dubbing shoref lnes "conservancy" because they (a) have talf

VAdA A AT



bluffs or (b) have lost some indicat ion of former erodibi l i tyl

lets myr iad shores be taggedz because most have those features.

And so they are, 40% of the shoref ine as f understand the current

proposal . Yet neither Johannessen nor anybody else has

quant. i f ied a re lat ionship between bluf f height and sediment

f lows, nor between sediment f fows and any measure of habitat

welfare- We have not even mapped areas of "starved" beaches,much less wri t ten cr i ter ia bv which such beaches can be known.

The inner waters of our several bays are tentat ively conservancy-

t .agged. These places are a l ready inhabi ted, including commercia l

venLures, yet they are also highly product ive of wifdl i fe, part fy

because at Least f ive have been improved for f ish passage. They

serve wel l as pausing p laces, in their present state, for

anadromous f ish coming and going, and it is hard to see what gain

can come from conscr ipt ive designat ions and rufes. These areas

front on t idef lats, created not by beach dri f t but rather by

st reambed erosion across the centur ies. One is so product ive of

pJ-ant matter that i t st inks. T do not see wi-sdom in implant ing

such places with speciaJ- designat ions.

I understand that outboard motors are to be banned from inner

bays. This may add Lo Lranqui l iLy, but Lhere are myr iad t ranquiJ

places on the Isfand. After 50 years here we feef that more can

be gained for mar ine b i rds by enforc ing exist ing speed l imi ts,

and doing something about jerks who tear through f locks af loat.

Let the inner-harbor folks put t about with their smal l outboards,

their only pract ica l means away; they l ive there after af l . One

eagle causes more a l -arm in the inner harbor than any smal l

motorboat.

AL a poJicy level , Lhe devi l seems Eo l- ie in the detaifs, which should

be few-

l{hat Goes Around Coneg Around

Imposing view corr idors on residences is an incredible intrusion.

And, once appf ied to shorel ines, i t coufd easi ly be spread across the

Is land. Perhaps condo owners should be requi red to leave certain

windows uncovered, to enhance aesthet ics and educat ion of passers-by.

About the Contradictory Vegetation Policies

Scat tered through are not only requi rements to remove vegetaLion, but

'See the Coastal Ceologic Serv ices bLutt mapping rcporL, pages l5ff ,

2" Is-Land Conservancy - Residentia1"

Page 5 of

20ff







Ma nr rsr- r r nf Ren91l

July,2008

SOME NOTES ON VEGETATION T{ATIVENESS

Vegetation is native if it ,s from Puget Sound.

The County CAO's def ini t ion of nat ive vegetat ion refers to speciesthaL dre indigenous Lo Lhe Puget Sound lowl"ands. This presumably

includes recent arr iva ls l ike Douglas f ir that has been here only 3-4t-hnrrc:nd \taarc- At m6.1sl e ioht f i r- trpF.lpnefdtiOnS- It CertainlV

includes Oregon white oak, which has been here longer. And OregondranA Araann;qql_ Ore6r6n erabannIe- OreOOn Iaa-lraa arIi fOfniaY'" ts* L!Lv,

rose-h;r r . ,r I I tnat ivest.""L

'Tndigenous' includes planLs Lhat arrjved here before an d afLer acool ing of the cl imate several mil l .ennia ago. Clear ly ,nat ive, is a

relat ive term, especia l ly s ince none were here ten mi l lennia aqo. Inshort , nat iweness is an elast ic mat-ter.

The Growth Management Act poi:nts out ttrat ttre worth of wegetation

depends on it s 'functions and wal.uesr.

These aren' t l isted buL presumably funcLions inc- iude protect ion ofr- l -ra nrnrrn.l

^^ntrol of stormwaler movemenLs. sf ahi l i - inn qloneq_ an d vvrrsrvr rrrvvLrrrLr iLr, rf-f

rr v r fvpsJ, ar lv

>lnnn l_ l- ,o qhar^ iA i^^ habiLaL for shore_l ine- inhabiLrno wi lc l l i fe- yI v L I v l JI lvLsf J l ls f l r r rouf UIr I\, '

Wildl i fe nurture may be considered a value, albert both good and bad.

OLher values are aesLheLics and protect ion of property rights, thel; f ter sner: i t ic.r l l w ment ioned in GMA.

Structural functions do not depend on species nativeness-

Stormwater st reamrng toward the Sound, ro l l ing over land or r id ing

about hardpan soi ls, is of course indif ferent to nat- ivenes.s - What

mat ters is physical barr iers in the form of stems, roots, and grass

blades - Nat ive shrubs and grasses do t -h is as wel l as otherspresumably. None do j t weII , ' Lhis is the subjecL of another paper.

Stabi l izing Lhe shore, at tr ibuted Lo root wads, is ei ther good or bad

depending upor) whether the occasional fa i lure of\ feeder

bluf fs,( i .e. , a l l bar :ks and bluf fs) is preferred- Some of our betterg ' r - lppers are exot ic, e.g. Scotch broom. Others, . l ike Cascara, are

regional nat ives. Unfortunately good grippers, with their dense rootnaJ-r.,nr lzc :1ca pn6-.)ttracre saJ.rtfat iOn Of ShOfe-fon soi ls- lead.i nc toLfvl l v! rf rvru LvlJ rvi rr t feqvr l lv

slope fa i l -ures. An advantage of Scotch broom and other shrubs isthat they never grow tal l , heavy t runks that l -ever t rees and their



rootwads over the side.

Nor are Ki'tsap wildJ.ife very discriminating.

Wildl i fe depend on nat ive pl-ants. We wish. L ike non-nat ive roses/

non-nat ive raspberr ies, and non-nat ive geraniums.

Densi i_ z. r rer f i r : .a st r r r r : l - r r re- succulence and hrrr to i ness seem Lo f avor"r rrr i€^ ^'*1qf re6Tarj leqq nF n:f i r l i {- ,, A ororrnj enrtar nf i rrr l i qWILULIICt OIl tturL !sVa!ulsJJ UL IfdLIVILy. n VLUurru uuvLL .-f

seemingly more usefu l to ground-abid ing bi rds and animals than the

-r+^-^-+ i - -^ ' rh ich appears of ten to be bracken ferns and weeds. Truea Lgr l lO L l VE, V

f i rs from afar at t ract raccoons, smal1 birds, eag. les, and more, as

wel l as nat ive f i rs.

But J.andscapers certainJ.y are.

With mi les of buf fers under discussj -on, many of those buf fers would bei n n | :noc t- -r: ]_ would oLherwise be Iandscaped

-The prospect of PugeL

Soundfs rather narrow array of species, repeated endlessly, is an

affront to homeowners who Lake pr ide in designing and main la jn ing their

surrounds. The populari ty of d jvers i ty js clear during tours of homes

and vis i ts to nurser ies. tndeed, nurser ies would be sorely af fecLed bya nat rveness const ra int .

Aesthel icaIIl -r mAn\/ necrnle nrefar qa\/ rpel manleq nr/Fr n:f i rze mrnloq:. .- . .L"qf , rvv e r lLuvruJ,

scar let oaks to nat ive Oregon whi te oaks; non-nat ive, showy cuf t ivars of

rhododendrons over the rather uninterest ing nat ive species, ' tasty and^-^ i , -^+

i .-^1: !vqu,crvc apples over Lhe nat ive crabapples; Lhe sdme argument for non-^-+ i - '^ - - r ' - -^ end cherr ies relat ive to nat ives, ' redwoods rel-at iwe tolaurvs Plu lrrJ c

f i rs; mountain ferns relat ive to lowland nat ives, weeping b i rches over

locals, cult i -vated roses over thorny nat ives, al ien daffodi ls over

nat ive di tchgrass, and so on. Few KiLsap yards have whol ly nat ive

species. While, with a st retch, one may point to hundreds of nat ive

Puget lowland plant species, "exot icsrt of fer us thousands.

The usual arguments against non-natives are ttrese:

Durabi l i tV - Non-nat iwes aren't at tuned to our cl imate. Generalfv

untrue; meanwhife some of our nat ives, including oaks and dogwoods,

are fading- I .4any non-naLives come f rom cl imates s imi lar to ours,and our c l imate is c lear ly favorable for plant growth. Owners seemwi l l inn fo ni \/e eXLfa Cafe to qppminnlrr fr .3oi le nl .3nts- a^A r^h]

-^^LU Jss lrrr i ry l y LLaY) rs yr o l lu-t o l lu !s IJ louc

those that fai l . That means extra ef for t and expense, but i t is anopt ion that owners should have.

Durabi l- i tv relat ive to insects and diseases. Actual ly aconcentrat ion of any species invites at tack. Nat ive forest t reesare having a rough t ime because of beet les. Gypsy morhs aresweeping toward us, at tacking al l- broadl-eaf species. Nat ive



dogwoods are dying. Nat ive bracken ferns are fess ewident.Counterpart species f rom eLsewhere are chosen, in some cases, fortheir resistance to pesLs and pest- i-Lence.

Native apples, cherr ies, and plums have been bred away f rom thei r

suscept ibi l i ty to insects and disease. We've been glad to see

variet ies other than nat ive crabapples, Indian plums, and wi ld^L^--.i ^- ^- ]

i^ €-^^-^ r

i ,,-- l - .; r ; f ,, FA^-

1f ^rnative.- r uE r!vrrr dF)Peq!qrruE dlru uu!dv!!rLy, Llrs arLs

species save us from having to search T&Crs produce bins for worm-fraa nrorlrrea rnr] airre rr< : hr^-t^- ,

^€ ! , - * i ^ ts i^^ , , I , i lF makinnurru va vL uD a ur uduul dr ldy ul vd l luLf,E>t wllaf g tlrdt-ar19

f ru i t more economic for both qrower and consumer.

Invasi -veness - Nat ive plant and animal species are here because of

their invasiveness over recent centur ies- Indeed, every species on

earth is invasive. And every nat ive species is invasive wi th j -n i tsnr^ \/ inee nr i f ic . . . l icn l \-- i ? .nnn \ /oar< a-^ +tr^ F*^ ,,- i l ih^ n lrn{-tJ ruw!lru= v! rL l> urrPrd!=u v luqrr ug v Lrrs PrswdrrrrrY yro lrL

species here were oaks and grasses. Even wi thrn i ts shady domain,lh e qhrr f r i l l i r rm nrpqqAq nrrtrr :rd:o:inqf alr -^ ^ nh\/inrrqlruuILt

tr rLJJLD VULWOI U OYqITIJL oJ J UUl l lg I) , a l lU vvvrvuJ r i

wins wi th some frequency- Sal,al and sa- lmonberry, nat iwes both,

have become invasive nuisances west of the mountains and especia l ly

toward the coast - So using ' invasiveness' as an argument against

non-nat ives seems i ronic.

A11 organisms are invasive,ne errnrr i nn

-r

ra t ro>f inn

(noad\ :nr ' l qn:rt- in , /h :r ] \\Yvvu,/ urrv JlJur u lr ld \udu,/ .

ennqi :nt l rr nrnhinn inf rrrr l i r, .- .--r.19,

This has been wide- ly seen ln salmon

Local nurseries are replete wi th invasives--p lants that, givennl c:q:nt antl i rnnmenf q on I :rno i hei r n:rr lanrrr:,,urrLJ, I presence-

Al- l nat ive species are invasive jn thei r provinces, or they would

not be here- Sala l and sal -monberry, both nat iwes, have become

invasive nuisances a long the coasts of Washington and Oregon. Even

wiLhin i ts shady domain, the shy l r j l l ium presses ouLwdrd againsta l l comers, and obviously wins wi th some frequency-

Invasion includes mowement across bare ground- Without

invasiveness vegetat ion would not spread across d isturbed areas.

By ru l ing out invasive exot ics we foreclose most perennia ls. And

indeed most usefu l exot ics. Landscapers wil l not be pLeased.

Nor wi l l - they be pleased if we prohib i t invasive nat ives- Yet the

ecol ooi c ef fects -"^L ^ --- ino mrlqqeq From fescues or vi ,-e \/FrqA -UULr )Uu1I aJ JdV f L i \, r ! vr l t LCJUUCJ UL Va--

wor r I c l l ' re r-nmne rable -

Meanwhi le the State has compi led lra f rrr ' l I u hrrm€111 Porh:nq ni f .i nauLuaf f y l lq l l rr lu r

-!s rrrays urLf tr g

fnrhiddinc al I evn1- ie <nocio-rr sn v Llu Jlrguf sD-

i qf q nF >onroqcirr^ ^1 --+nf l - ' - {

-F ^V\,TLJJIVS I, Iqr lL> LIIqL d Is

Lhis l is t is more usefuf tharr

Don Flora

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Comments on Draft SMP Polices by Don Flora