July 26, 1998
US Army Corps of Engineers,
Seattle District
Steve Babcock, Project Manager
ATTN: CENWS-PM-CP
PO Box 3755
Seattle, WA 98124-3755
Dear Steve Babcock,
I am responding to your Public Notice TB-98-02 on behalf of the Sufrider Foundation, and the Washington State Chapter. Our response includes letters submitted to me from our National Staff, Environmental Issues Team, and individual members of Surfrider Foundation, including citizens from the local area of Westport Washington. These letters represent our widespread concern about the proposed project and our opposition to the way it is planned.
The Washington State Chapter of the Surfrider Foundation has the following concerns:
The beaches of Half Moon Bay are heavily used for recreation, and the Public Notice does not acknowledge this fact. Not only is the area part of the Westhaven State Park, but the area is frequently visited by people by way of the parking area and public observation tower on the northeast end of Half Moon Bay. The shoreline features many aspects that make the area unique and of high value to recreation. The shoreline is protected from the open ocean coast, which makes it friendly to children, kayakers, surfers, and elderly beachcombers. During times of windy and stormy weather that are frequent throughout the fall, winter, and spring, Half Moon Bay serves as a haven for beachgoers, and water recreationists. There are few, if any other places like Half Moon Bay that have the proximity to the ocean coast, but are still sheltered from the most severe elements. For all of these reasons, Half Moon Bay must be maintained for its recreational use, especially the beaches of the entire Bay. We believe the construction of the Point Chehalis Revetment project will increase erosion, resulting in the loss of replenished beach, changes in topography of the bay and beach profile. This will in turn create a loss of recreational resource, e.g., surfing. (See Surfrider Foundation Environmental Issues Team Comments, The Washington State Department of Ecology Southwest Coastal Erosion Study, Management of Washington's Open Ocean Beaches: A Banana Republic Approach, Orrin H. Pilkey and The Effects of Seawalls on the Beach: Part I and II, Nicholas C. Kraus and William G. McDougal.)
We have concerns regarding access to the limited number of beaches available to surfers. Washington State has a growing population of surfers and declining number of accessible surfing beaches. Up until 1985, the population in Washington hovered at approximately 4.4 million people. The population of full time surfers to our beaches did not exceed 25-30 surfers (summer). Today, the estimated population of Washington is approximately 5.5 million people and the estimated full time surfers to our waters exceeds 2000 people based on beach counts, surfboard sales and rentals and Surfrider Foundation membership and activities. By the year 2000, its estimated that the state's population will hover at 6 million people (WSCTED, 1998). The number of full time surfers to our waters will more than likely increase as well. As the state's population increases, recreational activities, e.g., surfing, will increase. Unfortunately, access to beach sites which afford people an opportunity to ride waves is decreasing. A recent case in point came last month when the Lower Elwha Tribe announced a total beach closure to Angeles Point. The action that the Lower Elwha Tribe took mimics what happened at Point Grenville in the early 70's when the Quinalt's closed the beach. There is also a good potential that access to several good places on the Makah Reservation will soon be closed. These closures, combined with the degradation of several surfing locations due to coastal developments (such as the "wave bumper" in Ocean Shores) and changes in beach topography due to coastal erosion and the loss of near shore sediment (such as Westhaven State Beach and Grayland) have reduced the number of surfable beaches within Washington State while the number of surfers continues to grow dramatically. Half Moon Bay has several surfing areas with in it. These Washington State recreational resources are endangered and need to be protected.
The public notice (USACE) TB-98-02 does not provide for ongoing monitoring of bottom contours with respects to the adverse impacts to surfing within Half Moon Bay. This type of monitoring needs to be maintained to show how the bottom contours respond to developments and how the recreational resources are effected.
We require direct mitigation for any loss of ridable, e.g., surfing, waves within Half Moon Bay.
The public notice (USACE) TB-98-02 cites "construction of approximately 100 feet of revetment beginning at the southern terminus of the existing Point Chehalis revetment and landward of the US Coast Guard Rear Range will require excavation and placement of rock directly along the Half Moon Bay Shoreline". This revetment will increase erosion and cause massive scouring for an approximate distance 1 as long as its construction or 175 feet.
This will create a loss of any beach seaward of its construction and south for approximately 75 feet. In turn, this will destroy a prime surfing location within Half Moon Bay located immediately seaward of this proposed construction. This surfing location remains surfable due to the existence of the beach combined with safe conditions. This section of the revetment will also eliminate a large area of beach within Half Moon Bay used by thousands of persons annually.
The proposed revetment in this public notice must be placed landward of its proposed location starting behind the existing revetment and remaining behind the berm or primary dune along Half Moon Bay. No direct beach placement of any revetment should be included in the proposal, including ties to the existing Point Chehalis revetment.
The location of the 2500' jetty extension must also be off the beach. It will be unacceptable to connect it to the revetment in this public notice as drawn in the public notice diagrams. As with this revetment, the future jetty extension, if it is to proceed, must be located behind the dunes and the beach along the entire bay shoreline. Otherwise there would be a major loss to public recreational benefits, not to mention the impacts to the beach and habitats.
We require direct mitigation for any new rock, quarry spalls or rip rap placed at shoreline.
Public Notice (USACE) TB-98-02 cites "The specific purpose for the proposed revetment extension is to protect public facilities, including the Westport Sewage Treatment Facility, the Westhaven State Park access road, and the US Coast Guard Tower." According to the findings of members of the Surfrider Foundation's Environmental Issues Team and the "Long Term Maintenance of the South Jetty at Grays Harbor, Washington, Evaluation Report", US Army Corps of Engineers, Seattle District", June 1997, Figures 13 and 14 there is no threat to the Westport Sewage Treatment Facility from erosion with the estimated 50 year shoreline. The only public facilities immediately threatened are those of Westhaven State Park and the US Coast Guard tower.
Both of these facilities can be relocated. The greatest danger to the City of Westport and the Sewage Treatment Facility lies in the potential from overtopping and tidal flooding due to the revetment being exposed. Seawalls create a greater risk of overtopping and tidal flooding if the beach is not maintained. This was clearly demonstrated during the early 1990's at the existing Point Chehalis revetment when severe overtopping and flooding was experienced.
We require direct mitigation to maintain the shoreline and beaches within Half Moon Bay at present position with sand.
The public notice (USACE) TB-98-02 does not satisfy the requirements of 33 CFR Part 335, Operation and Maintenance of the Army Corps of Engineers Civil Works Projects Involving the Discharge of Dredged or Fill Material into Waters of the U.S. or Ocean Waters which states, "Maintenance dredging and disposal activities may involve areas which possess recognized science, recreational or similar values. Full evaluation requires that due consideration be given to the effect which dredging and disposal of the dredged or fill material may have on the enhancement, preservation, or development of such values."
Public Notice (USACE) TB-98-02 does not follow accepted standards for revegetation of revetments. The primary dune should be maintained at a minimum of +27' or 2' above the top of the armor rock. The primary dune should be revegetated and maintained with native dune grass. This type of maintenance will also maintain beach access and safety.
Finally, it is our belief that the Public Notice improperly piecemeals the project by separating a single project into separate public notices. For the purposes of environmental review under NEPA and the Corps' own regulations, the entire project should be evaluated for adverse environmental impacts. For example, the Public Notice proposes three separate phases of public comment and environmental review, whereas the three phases are so closely associated that they must be evaluated as a single action.
It is the belief of the Washington State Chapter of the Surfrider Foundation that public notice (USACE) TB-98-02 does not adequately address the above stated concerns in addition to those concerns included in the following enclosures. As currently proposed, the US Army Corps of Engineers Point Chehalis Revetment Extension should not proceed. A more comprehensive analysis of the issues at hand is needed to create a truly sustainable design to maintain the natural resources, beauty, usefulness, and wave action of Half Moon Bay.
Sincerely,
Kevin Michael McNay Ranker
Washington State Chapter
Chairperson
Surfrider Foundation
Enclosures:
Statement from Eve J. Kliszewski
Statement from Michael Walther, P.E.
Statement from Orrin H. Pilkey, Ph.D.
Statement from Richard T. Bell
Statement from Bob Friedman
Statement from Randy D. Baugh
Statement from Gaelen Fechner
Statement from John H. Lake
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