07-1015530
` CITY OF
M Federal
April 19, 2007
Hugh L. Travis
4222 SW 3250' Street
Federal Way, WA 98023 -2456
• FILE
CITY HALL
Way 33325 8th Avenue South
Mailing Address: PO Box 9718
Federal Way, WA 98063 -9718
(253) 835 -7000
www. cityoffederalway. com
RE: File No. 07- 101553- 00 -AD; LAKE LORENE SHORELINE EROSION INQUIRY
Travis, 4222 SW 325`h Street
Dear Mr. Travis:
This letter responds to your March 23, 2007 inquiry, regarding the shoreline erosion and bulkhead
construction requirements for your property abutting Lake Lorene at 4222 SW 3250' Street. The Federal
Way City Code (FWCC) classifies Lake Lorene as a regulated lake which is an environmentally critical
area.
As discussed at the April 17, 2007, site meeting with Larry Fisher from Washington State Department of
Fish and Wildlife (WDFW), rather than constructing a hardened bulkhead, we encourage you to
implement an environmentally - friendly, bio- engineered shoreline stabilization project by use of
vegetation planting.
Below, I have outlined the requirements and City process for implementing shoreline stabilization
through vegetation planting and alternatively by constructing a bulkhead. In summary, the shoreline
stabilization by vegetation planting requires minimal procedural requirements. Conversely, the bulkhead
process requires fairly significant procedural requirements and also requires application processing fees as
identified below.
The following section will outline the procedural requirements for shoreline stabilization and erosion
control thru vegetation planting.
Bio- Engineering/Vegetation Planting Stabilization
Pursuant to FWCC Section 22 -1335, shoreline stabilization by means of vegetation planting would be
classified as "rehabilitation" pursuant to FWCC Section 22 -1335. City staff encourages you to implement
your project in this fashion as discussed with Larry Fisher during the site visit.
Prior to conducting any work or planting, you would need to submit two copies of a "stabilization plan"
for the City's review and approval. The Director of Community Development Services may
administratively permit an applicant to rehabilitate a lake shoreline. Upon submittal of your plan and
letter request to the City, the Director will issue a written decision on the rehabilitation request and
vegetation planting plan. There are no City permit requirements other than the Director's approval for this
type of activity.
With your letter request, you will need to provide a scaled drawing, showing the proposed work including
type, size and spacing of any materials to be planted. Also indicate the type and location of any geo- fabric
Mr. Travis
April 19, 2007
Page 2
or other erosion control fabric that would be installed. Mr. Fisher encouraged the use of red $tern
dogwood shrubs as a native planting material to be used for stabilization. The City supports the use of red
stem dogwood, and/or other appropriate native deep rooted shrubs and/or trees appropriate for the specific
environment.
When developing a vegetation and stabilization plan, it would be helpful to review the principles of using
vegetation for shoreline stabilization provided in publications on the Washington State Department of
Ecology website at http: / /www.ecy.wa.gov /programs /sea/publications.htm.
Shoreline Bulkhead Requirements
The following section outlines FWCC procedural and technical requirements for constructing a shoreline
bulkhead along the Lake Lorene shoreline.
Pursuant to FWCC Section 22 -1336, a Process III land use application is required for the
constructing of a bulkhead on Lake Lorene, since the lake is classified as a regulated lake under the
FWCC. Process III review is an administrative review process, with public notification and a written
decision by the Director of Community Development Services.
The following development standards from FWCC Section 22 -1336 apply to the project. As project .
applicant, please provide a written response to how a shoreline bulkhead meets each of the three
following criteria:
(c)(1) The bulkhead is needed to prevent significant erosion.
(c)(2)The use of vegetation will not sufficiently stabilize the shoreline to prevent the
significant erosion.
(d) A bulkhead may not be located between a regulated lake and a wetland. Changes in
the horizontal or vertical configuration of the land must be kept to a minimum. The
bulkhead must be designed to minimize the transmittal of wave energy to other
properties.
2. State Environmental Policy Act (SEPA) — The bulkhead proposal is subject to environmental review
under SEPA. The Director of Community Development Services issues environmental threshold
determinations, with any appeals decided by the Hearing Examiner.
SEPA and land use review noticing provisions require the applicant to submit two sets of mailing
envelopes addressed to all owners of property within 300 feet of all property boundaries. All mailing
envelopes must be stamped and addressed, with the City's return address. Along with the mailing
envelopes, lists of owners' addresses must be submitted, and an assessor's map showing the 300 -foot
radius from all property boundaries. Please clearly label and identify the sets of mailing envelopes. A
handout detailing procedures for obtaining mailing labels is enclosed.
Fees — The shoreline bulkhead proposal requires the following fees: Process III, $2,196.00, and
$869.50 SEPA fee, which equals $ 3,065.50 total fee required.
4. Miscellaneous — An important element of the City's review of a bulkhead is the project's potential
impact on flooding around Lake Lorene. An engineering analysis must be provided that identifies
07- 101553 Doc. I.A. 40420
�J
Mr. Travis
April 19, 2007
Page 3
0
how the bulkhead proposal does not adversely impact the flood storage capacity of Lake Lorene.
Contact Will Appleton, Development Services Manager at 253- 835 -2730 regarding this item.
This correspondence in no way warrants or implies the project for a bulkhead will be approved by the City,
as the decisional criteria identified in item 1 above would need to be met by the applicant. The items listed
above may not include all regulations applicable to the subject proposal. In preparing your application, all
pertinent portions of the City's land use code must be consulted.
Summary
In summary, we encourage you to implement environmentally friendly shoreline stabilization through
vegetation planting.
Please be sure to coordinate with the Department of Fish and Wildlife regarding any technical or
procedural requirements of that agency for either of the alternatives discussed above.
If you have any questions regarding this correspondence or need additional information, contact me at
253- 835 -2649 orjim.harris@cityoffederalway.com.
Sincerely,
Jim Harris
Senior Planner
enc: FWCC Section 22 -1331 — 22 -1336
Process III Handout
SEPA Checklist
Mailing Label Handout
c: Larry Fisher, WDFW, via e-mail: fisheldf @dfw.wa.gov
Will Appleton, Public Works Development Services Manager
07- 101553 Doc. 1.D.40420
7 -�- b7- /Clls33 -cc
From:
"Golden Key Solutions" <lee @goldenkeysolutions.com>
To:
"Isaac Conlen" <Isaac. Con len@cityoffederalway.com>
Date:
3/23/2007 4:46:11 PM
Subject:
FW: Erosion Problem
Mr. Conlen,
Thank you for your assistance in dealing with my erosion issue.
Please find below the message i originally wrote to Mr. Nordby,
As I mentioned in our tel /con, I'm starting out at square one and simply
need to understand my options for reparation and recovery; then, of course,
what administrative steps I need to take to insure all bureaucratic
requirements are met at all levels to satisfy local and state authorities.
The pictures can be downloaded from a link
( http:// www. goldenkeysolutions. com /Erosion/Travis- Erosion.ZIP) and are about
1.8MB in size so I didn't attach them not know if your system would filter
them out.
Thanks again.
H. Lee Travis
4222 SW 325th Street
Federal Way, WA 98023 -2456
Phone: 253.835.5062
Cell: 206.931.6062
Email: hieet @goldenkeysolutions.com
- - - -- Original Message---- -
From: Golden Key Solutions (mailto :lee @goldenkeysolutions.com]
Sent: Monday, March 19, 2007 9:51 AM
Isaac Conlen - FW: Erosion Problem
To: ' martin .nordby @cityoffederalway.com'
Subject: Erosion Problem
Mr. Nordby,
Good day, Sir. It was recommended I first contact you by Trish Mcrae of our
Twin Lakes HOA regarding my problem. She said you were, ".very
knowledgeable about the rules and regulations regarding the lakes."
The truth of the matter is, after last Fall and Winter's flooding our Lake
Lorene (which I live on), I've lost another two (2) feet of my shoreline to
erosion. In some cases the soil simply washed out from under the sod. In
other parts, its just gone.
My property is the second parcel away from the mouth of the small creek that
feeds into the lake on what would be (I believe) the southwest side: 4222 SW
325th Street.sorry, I don't know the legal definition right off hand; but I
believe that complicates matters as it further defines my property as
federally protected "wetlands."
It is my understanding that there is a complex process, which you may be
able to assist me with, in getting approval for securing the shoreline
against losing the hard property. I'm not certain as to what my options
even are, but I've lost nearly four (4) feet - in some places - in the five
years I've been in the home and at this rate the high water line will be at
my foundation in short order if some corrections are not made.
Pictures speak louder than words. I didn't know if attachments would make
it through your email system so I uploaded some to my site if you'd care to
see them: http:// www. goldenkeysolutions. com /Erosion/Travis- Erosion.ZIP.
Simply download the compressed packet and Unzip them.
I suppose what I need from you is counsel as to the steps I need to take to
safeguard my property and it's value against erosion. Simply let me know if
need to set up a meeting with you or you'd rather just come out to look at
the'damage first. I am retired and except for Wednesday and Thursday this
week (I have jury duty), I would be available for either. My contact
information is below in my signature tag.
I thank you in advance for your time and prompt reply.
onien - FW: Erosion Problem
Regards,
H. Lee Travis
4222 SW 325th Street
Federal Way, WA 98023 -2456
Phone: 253.835.5062
Cell: 206.931.6062
Email: hieet @goldenkeysolutions.com
0
Jim Harris - Re: Travis Shoreline Erosion
From:
Jim Harris
To:
Golden Key Solutions
Date:
4/2/2007 10:50 AM
Subject:
Re: Travis Shoreline Erosion
Mr. Travis:
Page 1 of 2
Yes I have received your inquiry letter and I'll be preparing a written response to you this week. Since you
provided a great bunch of photos, I won't need to do a site visit at this time.
I have not reviewed the code requirements yet, however my letter will explain the technical and
procedural requirements.
The best way to reach me is by e-mail, at the address below. thanks Ji
Jim Harris
Senior Planner �,"
City of Federal Way (,o(
jim.harris @citvoffederalway.com
253 835 -2649m )
>>> "Golden Key Solutions" <lee @goldenkeysolutions.com> 04/02/07 9:48 AM >>>
Mr. Harris,
I believe you've been assigned to guide me through the process of appraisal and restoration of my
residential shoreline due to erosion.
I'm not certain as to exactly what the steps are or even what I'm able to do as part or all of my
shoreline is designated as protected "wetlands" and from what I've been told that can be a tricky
mine field to navigate.
I write to you today to inform you of possible schedule conflicts this week in case for your
planning purposes.
I have a business meeting today which I'm leaving for at 10AM that will consume the balance of
today. I'm sitting as a jurist on the Federal Grand Jury and am committed every other
Wednesday and Thursday.and unfortunately this week is that commitment. That, by the way, is
an 18 month commitment.
So, if you planned to meet with me or come look at the property I will not be available those
days, however you don't need me here to look at the trouble. My mother -in -law lives down stairs
and I simply need to inform her of your coming if that be the case.
I originally was recommended to see Martin Nordby, but was informed he has moved on. I had
provided him some digital images and in case they did not get forwarded to you, here is a link to
download them:
http_11 Qlden.key-sQlqtions.com/Erosion/Travis-Ero-s-i-on.ZIP
Basically what I need you for is two -fold:
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0 Page 2 of 2
1. I need find out exactly what I'm able to do under the guidelines of the restrictions in order
to build some sort of bulkhead or reinforcement to stop the erosion process.
2. Once that is determined, what administrative permits are required at
local /county /state /federal levels (and in what order) to move forward with my little project?
My goal is to get the things moving as quickly as possible so as to have the project done by
Fall /Winter rains and avoid further damage.
I thank you in advance for your time and regard.
H. Lee Travis
4222 SW 325th Street
Federal Way, WA 98023 -2456
Phone: 253.835.5062
Cell: 206.931.6062
Email: hleet @goldenkeysolutions.com
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Page 1 of 1
Jim Harris - Re: Coir Logs
From: Jim Harris
To: Golden Key Solutions
Subject: Re: Coir Logs
Lee; FWCC Section 22 -1333 allows a moorage structure as the only improvement allowed
waterward of the ordinary high water (OHW) mark of a lake.
Therefore, I need to real careful about permitting improvements waterward of the OHW.
would suggest that some minimal use of a single layer of coir log, or better yet, using the
coir log as a stake (rather than perpendicular to the shoreline) to secure the coir fabric. With
the minimal use of the coir log, supplementing the vegetative planting, we can get this
permitted under rehabilitation 22 -1335.
Sketch up a plan and submit to the City as previously directed.
>>> "Golden Key Solutions" <lee @goldenkeysolutions.com> 04/27/07 10:26 AM >>>
Hi Jim,
I'm working with a landscaper and require clarification as to whether I'm able to utilize what Larry
Fisher described as "coir logs" to tuck down around the toe of the shoreline without obtaining that
monster money bulkhead permit.
My plan is then to stake down the coir fabric to hold things in place ... and place a planting of red
osier dogwoods in a hedge -like pattern ... and reseed with a thyme or low- growing grass on top of
the coir fabric.
But before he (the landscaper) can draw things up, I need to know about that "coir log" thing. Is
using one or two of those at the toe of the erosion problem going to require more than the
Director's letter of approval?
I thank you in advance for your prompt response.
Lee
H. Lee Travis
4222 SW 325th Street
Federal Way, WA 98023 -2456
Phone: 253.835.5062
Cell: 206.931.6062
Email: hleet @goldenkeysolutions.com
about:blank 5/3/2007
Jim Harris - Coir Logs
From: "Golden Key Solutions" <lee @goldenkeysolutions.com>
To: "Jim Harris" < jim .harris @cityoffederalway.com>
Date: 4/27/2007 10:30 AM
Subject: Coir Logs
CC: "Larry Fisher" <fisheldf @dfw.wa.gov>
Hi Jim,
I'm working with a landscaper and require clarification as to whether I'm able to utilize what Larry
Fisher described as "coir logs" to tuck down around the toe of the shoreline without obtaining that
monster money bulkhead permit.
My plan is then to stake down the Coir fabric to hold things in place ... and place a planting of red
osier dogwoods in a hedge -like pattern ... and reseed with a thyme or low- growing grass on top of
the Coir fabric.
But before he (the landscaper) can draw things up, I need to know about that "coir log" thing. Is
using one or two of those at the toe of the erosion problem going to require more than the
Director's letter of approval?
I thank you in advance for your prompt response.
Lee
H. Lee Travis
4222 SW 325th Street
Federal Way, WA 98023 -2456
Phone: 253.835.5062
Cell: 206.931.6062
Email: hleet @goldenkeysolutions.com
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