Appendix B
SHORELINE RESTORATION REPORT
I. Shoreline Management Act Restoration Principles
The Shoreline Management Act makes protection of shoreline environments an essential statewide goal, with an emphasis on maintenance, protection, restoration, and preservation.1 Local shoreline master programs include goals and policies for restoration of impaired shoreline ecological functions that are consistent with the principles embodied in WAC 173-26-186(8)(c) and (d).2 These principles include the following:
• For cities containing any shorelines with impaired ecological functions, master programs shall include goals and policies that provide for restoration of such impaired ecological functions.
• These master program provisions shall identify existing policies and programs that contribute to planned restoration goals and identify any additional policies and programs that local government will implement to achieve its goals.
• These master program elements regarding restoration should make real and meaningful use of established or funded nonregulatory policies and programs that contribute to restoration of ecological functions.
• These components should appropriately consider the direct or indirect effects of other regulatory or nonregulatory programs under other local, state, and federal laws, as well as any restoration effects that may flow indirectly from shoreline development regulations and mitigation standards.
• Local master programs shall evaluate and consider cumulative impacts of reasonably foreseeable future development on shoreline ecological functions and other shoreline functions fostered by the policy goals of the Act.
The Act also recognizes that restoration planning will vary dramatically between jurisdictions based on the jurisdiction’s size, extent and condition of its shorelines, availability of funding and restoration tools, and the nature of the ecological functions to be restored.
A. Opportunities for Protection and Restoration. In Burlington, potential areas of meaningful restoration are organized as follows:
1. Shorelines fronted by an extensive levee system along the Skagit River.
• Locations where there is significant open space between the levee and the river’s edge on land owned by the city or Dike District No. 12, including land outside the city limits. Johnson Bar is the major site as identified in the Skagit River Big Bend Reach Habitat Restoration Feasibility Study.3
• Future locations where the Dike District plans to build setback levees farther from the shoreline.
2. Gages Slough wetland corridor.
• Wetland buffer restoration sites identified through scientific study; 15 sites identified, three restored and in maintenance and monitoring phase, as spelled out in the Gages Slough management plan and related technical studies.4
• Opportunities for public access.
• Locations for water quality enhancement projects to achieve the result of clean water coming out of Gages Slough into the Skagit River to protect priority habitats and species.
• Listing ID 7124 (Bacteria – Category 4A) for Gages Slough was moved off the 303(d) List on September 1, 2000, when EPA approved the cleanup plan known as a TMDL.5 Category 4A indicates that EPA has approved a cleanup plan that is thought to be capable of returning the waters to Category 1 (meets tested standard). The water is still considered “impaired” until effectiveness monitoring shows the conditions have been resolved. The TMDL is very broad and does not include any specific program for Gages Slough management and cleanup. The adopted Gages Slough management plan will be evaluated and work program components prioritized to enhance efforts to meet standards.
• The Gages Slough management plan calls for getting the Slough into public ownership from Anacortes Street to the Skagit River. The Gages Slough Survey 2012 reinforces the need to make this happen as property owners are for the most part not interested in granting easements. Condemnation action is likely necessary.
B. Shoreline Management Program Restoration and Enhancement Goals.
1. Reestablish, rehabilitate, and/or otherwise improve impaired shoreline ecological functions and/or processes through actions that are consistent with this master program and guidelines provided in other local and regional restoration plans.
2. Encourage and facilitate cooperative restoration and enhancement programs between the city and state and federal public agencies, tribes, nonprofit organizations, developers, and landowners to address shorelines with impaired ecological functions and/or processes.
3. Restore and enhance shoreline ecological functions and processes as well as shoreline features through voluntary and incentive-based public and private programs.
4. Target restoration and enhancement with the goal of improving habitat requirements of priority and/or locally important wildlife species.
5. Ensure restoration and enhancement is consistent with and, where practicable, prioritized based on the biological recovery goals for salmon populations and other species and/or populations for which a recovery plan is available.
6. Integrate restoration and enhancement with parallel natural resource management efforts such as the 2005 Skagit Chinook Recovery Plan6 and Department of Ecology Water Resource Inventory Area (WRIA) No. 3 watershed planning activities.
C. Biological Goals and Objectives. These are the goals for the habitat conservation plan of the city so that any proposed activity does not appreciably reduce the likelihood of survival and recovery of the listed species under the Endangered Species Act7, and that the plan minimizes and mitigates the impact of the taking of any listed species or habitat to the maximum extent practical.
1. Preservation means acquiring a site, using conservation easements, donations, etc., to protect its current values. Land acquisition is in process for both the Skagit River and Gages Slough corridors.
2. Enhancement of a habitat means improving an existing site in some way that will encourage and retain fish and wildlife, such as increasing pond size or improving buffer. Following land acquisition, habitat enhancement is feasible. Public education is in process for encouraging land owners to use best management practices on their own property and to enhance habitat areas and values in their own backyards. Along the Skagit River, enhancement areas are Johnson Bar with potential for a major project, and the forested buffer at Whitmarsh fields, where evergreen trees and maples are being planted to improve the buffer.
3. Restoration means a damaged or degraded site will in some manner be improved.
a. The Gages Slough corridor is the prime target for restoration projects. There are a total of 15 sites in the Gages Slough corridor that have been identified and a reconnaissance level plan has been prepared for each one, including locations for installation of bioswales adjacent to the wetlands for water quality enhancement. The wetland restoration demonstration project in the Jack Doyle Memorial Neighborhood Park is the first example. The Goldenrod Bridge restoration project is in the fifth year of maintenance and monitoring, located west of Interstate 5 in a very visible location. The Unit 10 former city dump restoration site is in year two of monitoring and maintenance. Public/private partnerships are strongly encouraged.
b. Along the Skagit River, the three-bridge corridor levee setback area is a long-term future restoration project opportunity.
4. Long-term management of priority habitat sites includes strategies to protect the habitat values of the sites. Every site in the urban wildlife habitat designation has a monitoring and management plan that is tailored to the specific requirements of the location. This work includes removal of invasive species and replanting as necessary in a timeline based on the season.
5. To not appreciably reduce the likelihood of survival and recovery is the statutory goal for permit issuance under the Endangered Species Act. In Burlington, this includes a strategy that will keep floodwaters out of the developed urban area so that pollution from the city does not enter the Skagit River, and prevent fish stranding in polluted areas with no potential for survival. The city and Dike District No. 12 are working together to develop a plan for levee certification and accreditation by FEMA, to prevent or at least severely restrict urban flooding in flood events up to the 100-year base flood. This project is the topic of an environmental impact statement.8
D. Restoration and Enhancement Policies.
1. The city of Burlington has determined priority restoration sites.
2. This master program recognizes the importance of restoration of shoreline ecological functions and processes and encourages cooperative restoration efforts and programs between the city, county, state, and federal public agencies, tribes, nonprofit organizations, and landowners to address shorelines with impaired ecological functions and/or processes.
3. Additional opportunities for restoration may be created when Dike District No. 12 completes plans to construct a setback levee along the Skagit River through the three-bridge corridor.
4. Restoration actions should restore shoreline ecological functions and processes as well as shoreline features and should be targeted towards meeting the needs of sensitive and/or locally important plant, fish, and wildlife species as well as the biological recovery goals for early Chinook, bull trout populations, and other salmonid species and populations.
5. Restoration should be integrated with other natural resource management efforts such as the 2005 Skagit Chinook Recovery Plan and the Skagit River Big Bend Reach Habitat Restoration Feasibility Study 2004.
6. Priority should be given to restoration actions that:
a. Create dynamic and sustainable ecosystems.
b. Restore connectivity between river channels, floodplains, and hyporheic zones.
c. Restore historic back-channels to create refugia for migrating fish.
d. Mitigate peak flows and associated impacts caused by high storm water runoff volume.
e. Reduce sediment input to the Skagit River and associated impacts.
f. Improve Skagit River water quality through storm water facility upgrades.
g. Restore native vegetation and natural hydrologic functions of degraded and former wetlands to the extent practical.
h. Replant native vegetation in shoreline areas to restore functions where such actions are meaningful and consistent with this SMP and dike district guidelines.
i. Where practical, restore riverine ecosystem processes, such as sediment transport and creation of sandbars and accumulation of large woody debris that create and sustain fish habitat.
The Skagit is the only river system in Washington that supports all five species of salmon, containing some of the largest and healthiest wild Chinook salmon runs in Puget Sound and the largest pink salmon stock in the state. In all, there are 10 species of salmonids within the Skagit River basin. These include six Chinook stocks (spring, summer, and fall), pink salmon, chum salmon, sockeye salmon, summer and winter run steelhead, sea run cutthroat trout, Dolly Varden, and bull trout. Three of these, Puget Sound Chinook salmon, Puget Sound steelhead, and Coastal Puget Sound bull trout, are Endangered Species Act (ESA) listed.9
As a result, restoration planning in the Skagit River watershed has had a focus on policies and actions intended to aid in the recovery of migratory fish populations, in particular ESA listed species.
E. Adaptive Management Plan. An adaptive management strategy is used to address significant uncertainty associated with a particular habitat conservation plan, but it is not practicable (or possible) to require that all adaptive management strategies impose an elaborate experimental design, but rather to overcome data gaps. As foreseeable circumstances change, a contingency plan must be in place to address the issues. An example here might be changes in the Corps of Engineers levee vegetation maintenance standards, or a flood event that changes a planned restoration project.
F. Monitoring Program. Monitoring types include compliance monitoring, effect monitoring, and effectiveness monitoring. Today, water quality monitoring is a TMDL and NPDES II requirement and there is ongoing monitoring at the sewer plant and at storm water outfall locations, as well as in the Gages Slough corridor. Restoration planting projects have an initial five-year intense maintenance and monitoring program, with less frequent visits as the sites mature. Mitigation projects will each have a specific monitoring plan. (Ord. 1786 § 1, 2013).
II. Watershed Planning
In 1998, the State Legislature passed chapter 90.82 RCW, which sets forth a framework for developing local solutions to water resource issues on a watershed basis. Chapter 90.82 RCW states:
The legislature finds that the local development of watershed plans for managing water resources and for protecting existing water rights is vital to both state and local interests. ... The development of such plans serves the state’s vital interests by ensuring that the state’s water resources are used wisely, by protecting existing water rights, by protecting in-stream flows for fish and by providing for the economic well-being of the state’s citizenry and communities.
Chapter 90.82 RCW recognizes that watersheds are the logical planning unit for addressing water resource issues and the protection and restoration of fish and wildlife habitats. The RCW establishes general criteria and guidelines for state agencies and local jurisdictions to follow in developing and implementing watershed plans. The primary purpose of these plans is to equitably manage water resources between the competing demands of human use, protection of existing water rights, and the maintenance of in-stream flows for resident fish. Habitat restoration is an optional element in the development of local watershed plans under the RCW. However, given the requirements of the GMA relative to the SMA for shorelines, restoration would be an expected component for those watersheds that have experienced significant development and historically supported significant fish populations and riparian habitats.
Watershed planning is necessarily hierarchical in nature. Each major watershed is composed of smaller sub-basins that may differ substantially in the intensity of development, level of water resource use, types and extent of habitats, and functional characteristics. Federal and state agencies, tribes, and local governments have varying degrees of authority over watershed issues, resulting in a hierarchy of plans and regulations. Major watershed boundaries and tributaries also cross jurisdictional boundaries, requiring coordination between local communities, tribes, and private parties engaged in planning and restoration activities.
A. Watershed Resource Inventory Area No. 3. The state’s major watersheds have been mapped into 62 Water Resource Inventory Areas (WRIA), with each further divided into sub-basins based on the physical extent of primary tributaries. Burlington is located within WRIA No. 3 – Lower Skagit River. As a planning unit, the boundaries of WRIA No. 3 represent the upper tier of the watershed hierarchy for the Lower Skagit.
The Department of Ecology (DOE) is the agency responsible for coordinating and overseeing the development of watershed plans under chapter 90.82 RCW. The DOE further supports these efforts by conducting research and preparing studies on specific watershed issues, reporting on watershed planning activities, and maintaining a database of information specific to each WRIA.
B. Skagit Chinook Recovery Plan 2005. The Skagit Chinook Recovery Plan (plan) was completed in 2005 as a joint effort between the Skagit River System Cooperative (SRSC) and the Washington Department of Fish and Wildlife (WDFW). The process began in 1994, in response to the listing of Puget Sound Chinook salmon as threatened under the Endangered Species Act and during its development included the involvement of a variety of interested and affected parties. The plan document is intended to provide the basis for the Skagit Basin chapter of the Greater Puget Sound Chinook recovery effort.
The purposes of the plan are to:
• Define biologically based recovery goals.
• Identify what is known or assumed about factors that limit production of Skagit River Chinook.
• Propose scientifically based actions that will restore Skagit River Chinook to optimum levels, including fisheries management, artificial production, habitat protection, habitat restoration, effectiveness monitoring, and applied research.
The plan is built around the identification of four different juvenile Chinook salmon life history strategies in the Skagit: yearlings, parr migrants, tidal delta rearing migrants, and fry migrants. Due to the differences in habitat use, yearlings and parr migrants depend more on freshwater habitat, while tidal delta rearing migrants and fry migrants depend more on estuarine habitats.
This difference in habitat utilization by individual life history strategies shapes the habitat recovery actions proposed in the plan. Habitat recovery actions are recommended that benefit each life history strategy in an effort to maintain and strengthen Chinook population diversity and ensure spatial connectivity and abundance. The restoration strategy for the plan is based on an understanding of the limiting factors for each of the Skagit Chinook salmon stocks and the specific location of existing or potentially restorable habitat.
Relevant to Burlington are the plan’s recommended restoration actions for freshwater rearing habitat in large river floodplains, tributaries, and nontidal deltas. Large river floodplain restoration actions in the plan seek to improve freshwater conditions for all Chinook salmon fry, but in particular for those life history strategies that depend on freshwater habitat for extended rearing. Intact floodplain areas are especially important for freshwater rearing because the availability of complex main-stem edge habitat, backwaters, and off-channel habitat is essential for the foraging and refugia of all phases of freshwater life history. For example, stream type Chinook salmon spend over one year in freshwater habitat before migrating further downstream.
C. Burlington Wetland Restoration Program. Part of the flood hazard mitigation plan includes improving Gages Slough so that water can flow more readily during and after a flood event, specifically considering sediment removal and culvert installations. This planning effort will be more focused over the next few years and will comply with the shoreline master program.
Technical studies have been completed for Gages Slough with important information about the existing conditions. These include water quality monitoring as part of the Lower Skagit River Water Quality Study completed in 1993, the comprehensive surface water management plan adopted in 1992, and the Surface Water Management Plan Update and Facilities Pre-Design Report completed in 1996. Out of these initial studies, three major actions took shape. A coastal zone management grant provided funding for in-depth technical studies of Gages Slough in 1998, to set up a long-range management plan to facilitate removal of Gages Slough from its current listing as a 303(d) site, in violation of the Clean Water Act. Gages Slough was moved off the 303(d) List on September 1, 2000, when EPA approved the cleanup plan known as a TMDL. Category 4A indicates that EPA has approved a cleanup plan that is thought to be capable of returning the waters to Category 1 (meets tested standard). Concurrently, a new pump station was designed and constructed to provide for storm water management as the city grows and to facilitate management of the hydroperiod of Gages Slough, in response to the clear need for wetland restoration activities and the forecast demands of the comprehensive surface water plan. A citizen’s advisory committee was formed to develop the shoreline master program for Gages Slough and the Skagit River shorelines.
The problems associated with the degraded series of connected wetlands, Gages Slough, that crosses the community, and concerns about the need for very costly storm water management facilities in the floodplain, became the focus of every neighborhood meeting in the 1990s. Gages Slough had become a combination sewer and garbage dump. City staff was not aware of the history of Gages Slough and made the assumption that the upriver end of Gages Slough had some sort of direct connection via culvert into Hart Slough, and reported that as a fact to the technical consultants. However, the culvert connects only to Brickyard Creek, which is the ditched stream connected to the culvert/fish passage. There are no piped connections to Gages Slough. The recent history of the area began with the construction of the Sterling Dam blocking any above-grade connections to Gages Slough in 1899 because there were numerous floods that were affecting the railroad tracks. The Sterling Dam is owned and maintained by Dike District No. 12. It is located north of SR 20 adjacent to Holtcamp Road.
In 1998, a wetlands ecological study was completed for Gages Slough including delineation, a functional assessment using the Department of Ecology hydrogeomorphic modeling approach, along with a water level and water quality analysis, and a management and restoration plan has been designed and integrated into this master program. Existing uses along Gages Slough include single-family residential, commercial, agriculture and industrial use.
The first survey of all the property owners along Gages Slough (both in and outside the city limits) was taken in the winter of 1995-96, and the results were mailed to all property owners in March of 1996. Grave concerns about the future of the wetlands were expressed, particularly in light of the fact that there was a significant flood event on the Skagit River in the winter of 1995 and there was a lot of discussion about turning Gages Slough into a backup flood control channel. These activities and issues led to creation of the citizen’s advisory committee and to the request for the grant funding to get the essential elements of the long-range management plan established.
A second survey of Gages Slough property owners was conducted in the spring of 2012. Preliminary results have been tallied, but results will still be coming in following publication of this report.
Today, the Gages Slough management plan has been adopted as part of the overall comprehensive plan, the parks and recreation comprehensive plan and the comprehensive surface water management plan.10 The plan was completed in the spring of 1999, updated September 1999, August 2006, February 2007, and followed by a 2009 Gages Slough reconnaissance report identifying a series of restoration project sites. There are two wetland buffer restoration projects that are five years or older and there is one wetland buffer restoration project that was planted in 2011, at the site of an old city burn dump.
As a participant in the NPDES II municipal permit system, the public works department is actively increasing the focus on improvements to the Gages Slough corridor that enhance its ability to process storm water and return clean water to the Skagit River system. New improved water level monitoring instruments have been installed in Gages Slough. Bi-monthly water quality monitoring is completed by the public works department. In addition, the Skagit Conservation District Stream Team has a committed team of volunteers that also does regular water quality monitoring in Gages Slough for temperature, turbidity, and fecal coliform, the TMDL standards. (Ord. 1786 § 1, 2013).
III. Restoration Opportunities and Actions
A. Big Bend Reach Habitat Restoration Feasibility Study, 2004. The primary goal of the Skagit River Big Bend Reach Habitat Restoration Feasibility Study, prepared for the city of Mount Vernon in 2004, was to identify opportunities for improving the quality and quantity of rearing habitat available to juvenile salmon at various opportunity sites located in the Big Bend Reach of the Skagit River. There are remnant pockets of habitat to be found between the river and the existing levees. Some of these are actively engaged with the river. Most are currently isolated from river actions, except during high water events.
Thirteen opportunity sites were identified and analyzed for their existing habitat values and their ability to provide additional habitat benefits, extending from Johnson Bar downstream to Britt Slough. Johnson Bar is mostly owned by the city of Burlington, and this is the only significant restoration site along the Skagit River that the city has the potential to restore.
B. Gages Slough Restoration Plans, 2009 Update. This report provides an update on the identified restoration sites and sets a priority ranking for each site. Most of the sites have lots of invasive species including Himalayan blackberry and reed canary grass, and the need for shade and water quality improvement. The drainage utility is committed to funding the five-year and ongoing monitoring and maintenance program since 80 to 90 percent of the city’s storm water enters Gages Slough. The sites are available as mitigation sites to compensate for decreased wetland buffers and for off-site mitigation under the critical areas standards.
C. Implementation Timelines, Benchmarks and Strategies.
Identify timelines and benchmarks for implementing restoration projects and programs and achieving local restoration goals:
1. The NPDES II storm water cleanup program is focused on public education, water quality monitoring, and source control through annual maintenance. This program is partially funded by the drainage utility and through state-administered grant funds, along with a dedicated team of volunteers from the conservation district. The overall water quality is monitored by the Department of Ecology as part of the TMDL that includes Gages Slough. The program is a permanent component; whether or not the water quality meets standards at some point, the need for education and source control is critical. As part of the FEMA community rating system program, every drainage facility has annual inspection and maintenance requirements. The city is committed to deliver clean water to Puget Sound; the benchmarks are set, timelines are ongoing.
2. Construction of water quality treatment bioswales in Gages Slough corridor for increased capacity to treat storm water. This program is a top priority for storm water grant applications. Grant match funds are from the drainage utility. The restoration sites have been prioritized based on water pollution and the first key location has a pending grant application. All projects include five to 10 years of monitoring and maintenance; once mature, maintenance needs decrease, but there is ongoing maintenance and removal of invasive species.
3. Wetland Buffer Restoration Projects. Fifteen sites identified; three have been constructed and the remaining sites are available for public and private restoration opportunities. This includes land development that requires wetland mitigation anywhere in this area. Two sites were constructed using donations to the Burlington Parks Foundation. The drainage utility has committed funds for the five-to-10-year maintenance and monitoring program. To date, restoration activity has occurred at the rate of approximately one site every five years. The commitment to permanent maintenance and monitoring is funded by the drainage utility.
4. Skagit River – Johnson Bar Restoration Project. This is a regional project located adjacent to the city limits on the waterward side of the levee. It is a high priority by police, fire and parks to get rid of a place that is an ongoing problem site used to dump trash, stolen cars, junk, and allowing on- and off-road vehicles to speed around and tear up the dirt road. The plan of action is to coordinate the project with levee upgrade work in process by Dike District No. 12. Additional land acquisition is in process by the Dike District; schedule to be set in the next year.
5. Skagit River – Levee Upgrades and Maintenance. Burlington levees are in the Corps of Engineers PL 84-99 maintenance program and levee vegetation standards have been set through an ESA Section 7 consultation. This program is ongoing with annual inspection by the Corps of Engineers.11
Provide for mechanisms or strategies to ensure that restoration projects and programs will be implemented according to plans and to appropriately review the effectiveness of the projects and programs in meeting the overall restoration goals:
1. Uniquely situated in the floodplain adjacent to the Skagit River on the south and east, with long-term agricultural resource lands to the north and west, Burlington has a comprehensive plan in place that is monitored not only by the city, but by the FEMA Community Rating System program where everyone in the city now receives a 25 percent reduction in flood insurance rates through the continued monitoring, maintenance and protection of environmentally sensitive sites and critical areas. This program has intensive federal monitoring.
2. Burlington is required to participate in NPDES II, a national pollution discharge elimination system program that applies citywide, focused on clean water.
3. As a result of concerns over how the National Flood Insurance Program is managed, every project in Burlington is reviewed for compliance with the Endangered Species Act biological opinion that is focused on habitat restoration.12
4. Burlington is also a participant in the Skagit County natural hazards mitigation plan that is updated every five years countywide.13 (Ord. 1786 § 1, 2013).
Washington State Shoreline Management Act, chapter 90.58 RCW.
Washington Administrative Code regulations; chapter 173-26 WAC, Shoreline Master Program Guidelines.
Skagit River Big Bend Reach Habitat Restoration Feasibility Study, prepared by Miller Consulting, Skagit River System Cooperative, Pentec Environmental, and Wildlands of Washington, Inc., December 20, 2004.
City of Burlington, Shoreline Analysis Report and Shoreline Inventory 2012 – Appendix D. Gages Slough management plan including history of Sterling Dam, history of the Gages Slough management plan, technical studies, restoration sites, Puget Sound Partnership Watershed Characterization, and water quality monitoring data.
Lower Skagit River Fecal Coliform Total Maximum Daily Load Submittal Report Water Cleanup Plan, Publication No. 00-10-010, June 2000.
Skagit Chinook Recovery Plan, 2005, prepared by Skagit River System Cooperative and Washington Department of Fish and Wildlife; and Appendix C, Linking Freshwater Rearing Habitat to Skagit Chinook Salmon Recovery, November 4, 2005, prepared by Eric M. Beamer, Bob Hayman, and Devin Smith.
Endangered Species Act (ESA) of 1973, as amended.
City of Burlington Draft EIS February 2009, and Final EIS July 16, 2010, to Adopt a Strategic Program for Comprehensive Flood Hazard Mitigation in the Burlington Urban Area and Adjacent Land with a Range of Structural and Non-Structural Components.
Department of Commerce National Oceanic and Atmospheric Administration, 50 CFR Part 226, Designated Critical Habitat: Critical Habitat for 19 Evolutionarily Significant Units of Salmon and Steelhead in Washington, Oregon, Idaho, and California, Federal Register February 16, 2000, and Federal Register September 2, 2005.
City of Burlington 2005 comprehensive plan, 2009 parks and recreation comprehensive plan with urban wildlife habitat plan, 2005 comprehensive surface water management plan and related planning documents.
Biological Opinion, Consultation for Skagit River Levee Repair Projects, Skagit County, Washington: Flood Damage Repairs to Numerous Levees in Diking Districts 1, 3, 12, 17, and 22, prepared by U.S. Fish and Wildlife Service, Reference No. 13410-2010-F-0254, Agency U.S. Army Corps of Engineers Seattle District, May 27, 2011; and
Endangered Species Act (ESA) Section 7(a)(2) Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat (EFH) Consultation, Skagit River – Diking Districts 1, 3, 12, 17 and 22, Levees Rehabilitation of Flood Control Works Project in Skagit County, Washington; NMFS Consultation Number: 2011/0033, October 24, 2011.
Endangered Species Act – Section 7, Consultation Final Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Consultation, September 22, 2008, regarding National Flood Insurance Program and FEMA.
Skagit County Natural Hazards Mitigation Plan, September 2008.