July 27, 1998
US Army Corps of Engineers
Seattle District Regulatory Branch
Post Office Box 3755
Seattle Washington 98124-2255
Attn: CENWS-PM-CP
FAX: (206) 764-6602
Dear Mr. Steven Babcock, Project Manager and interested reviewers:
Enclosed please find the objections made by me, Arthur Grunbaum, a private citizen and a user of the public beaches and waterways of the State of Washington and the United States, to the above referenced matter. I am also a member of FOGH (Friends of Grays Harbor), Chehalis River Council, Chehalis Watershed Coalition, Audubon, Grays Harbor Chapter, Washington Environmental Council, Sierra Club, Sasquatch Chapter
The specific objections are:
The Grays Harbor estuary and ocean beach shoreline is extremely fragile and is currently experiencing widespread retreat and erosion. This is probably due to a variety of causes, ranging from human intrusion, seawalling and a rising Ocean level. A long-term study and policy to address coastal erosion for Washington State is being proposed, but has not yet been completed. Significant information still needs to be gathered.
The work proposes to stabilize the Half Moon Bay shoreline and the "associated shoreline erosion caused by the South Jetty," (Public Notice, Ref: TB-98-02, page 1). Remembering the recent failure of the jetty and the breaching of Half Moon Bay, I believe that the agency and proponent engages in self consultation which raises questions of its ability to objectively judge the merits of this project. Therefore an independent NEPA EIS should be required in order to provide balanced consistency to this waterway of State, National and International significance.
The fill and proposed armoring project will produce many adverse environmental impacts to recreational use, water habitat, water quality and wildlife habitat.
This piecemeal filling and armoring of the shoreline will have a cumulative adverse impact on water quality in the Grays Harbor Estuary. Ocean Shores is proposing similar armoring north of the North Jetty. I request the Corps document past success and consequences of filling in these two areas.
A beach surf zone such as Half Moon Bay is a poor choice for significant alteration or armored "development". While it may be true that "beach surf zones habitats have much lower productivity and diversity than rocky habitats, ..[they] may be the sole support for certain species (e.g., razor clam, Dungeness crab and spawning surf smelt", Olympic Coast National Marine Sanctuary FEIS, II-32) Fill will alter the character of the zone and adjacent land. I request that the Corps evaluate stormwater runoff from the proposed project and how it will effect the drainage patterns both upland and into the surf zone.
Sufficient information has not been provided regarding the present function of the wetlands and existing dunes along the proposed site.
Since there is insufficient baseline information no assurances can be made that wetland or dune functions will be replaced by any future proposed mitigation plan.
The effects and potential problems of placement of the proposed armor rock has not been documented and evaluated. I request that the Corps document and evaluate these techniques and their results.
The notice does not provide any information about the usage of the wetlands, dunes and waters of the bay by migratory or resident birds and wildlife which annually visit the South Shore of Grays Harbor, Bowerman Basin National Wildlife Refuge and the Olympic Coast National Marine Sanctuary. I request that the Corps document and evaluate the proposed action.
The type and nature of the fill material has not been adequately stated. The success or failure to the long range goals of the surrounding environment may depend upon the size of the underlying grain of sand.
The marine-resource industries, the habitat and viability of the crab, razor clam, oysters, salmon, sole, herring, surfperch, sturgeon and other important food and sport resources is in eminent danger from risky solutions to nature's natural processes.
Loss of habitat and degradation of water quality affects the survival abilities of marine organisms, this may be in direct conflict with the Treaty With The Quinault, Etc., 1855, (Olympic Coast National Marine Sanctuary, FEIS/Management Plan, Volume 2: Appendices, pp. D-3, 4 , 5). This may interfere with and/or limit fish, shellfish, waterfowl and plants presently relied upon by the Quinault Peoples for subsistence and Ceremonial purposes. (ibid., pp. E-7, 8, 9).
The Ocean Resources Management Act (ORMA, RCW 43.143) gives priority to activities that will not have adverse impacts on renewable resources. I request that the Corps document and evaluate the "intent" of ORMA with the proposed action.
The cumulative effects of development starting with the continued beachfront construction in both Ocean Shores and Westport will further degrade the water quality through pollution, runoff and loss of beach sand.
Alternate solutions have not yet been properly considered.
The Seashore Conservation Area law (RCW 43.51.650) declares all of the Washington Pacific Coast beach (under state ownership or control, such as Westhaven State Park) to be a conservation area for public recreation. The law assigns priority consideration to preserving such areas in a natural condition.
Half Moon Bay is used by the public for a variety of recreational purposes, which include: rock and agate hunting, surfing, beach combing, swimming, strolling, surf fishing and associated activities. The proposed action will dramatically effect and/or alter these recreations. I request that the Corps document and evaluate the action and its effects on these activities.
A NEPA EIS should be required for this action. The pubic interest will suffer substantial detrimental effect. If there were no detrimental effect there would be no need for a Shorelines Master Act or Shorelines Master Program of Grays Harbor. The Public by voting for the act implied that the Public has a stake in the protection of their shorelines and that interest could be damaged by the proposed action.
I appreciate the opportunity to comment on this project and hope that the Corps will decide to evaluate the proposed action as a partner in the upcoming policy decisions that will be made on behalf of the long-term solutions to Ocean changes. The decisions that we make now with solutions that have lifespans of one year or fifteen years are not appropriate. The oceans have been moving sand from area to area almost from the beginning of time. If we are to interfere with this process let's make sure that all considerations have been made. The ocean beaches belong to all of the citizens. Westport and Ocean Shores depend upon them, culturally and financially. Decisions, must be made with a global long-term outlook.
Thank you,
Arthur (R.D.) Grunbaum
1128 State Route 105
Aberdeen, Washington, 98520
olearycrk@aol.com