July 14, 2016

Mo-chi Lindblad Klickitat County Planning Department 228 W Main St #17 Goldendale, WA 98620 Via email: [email protected]

Re: Proposed Shoreline Jurisdiction for Klickitat County SMP Update

Dear Mo-chi:

The Watershed Company has developed a set of preliminary maps showing the proposed shoreline jurisdiction for the Klickitat County Shoreline Master Program Update.

The proposed shoreline jurisdiction shown in these maps was determined based upon the State Shoreline Management Act (SMA) and current Washington Department of Ecology (Ecology) rules and guidance documents. The following areas are regulated as “Shorelines of the State” under the state guidelines:

• Streams and rivers with over 20 cubic feet per second (cfs) mean annual flow, and floodway and contiguous floodplain areas extending 200 feet from the floodway;

• Lakes 20 acres or greater in size, measured from the ordinary high water mark (OHWM);

• Shorelands 200 feet landward from the OHWM of jurisdictional streams, rivers, and lakes; and

• Associated wetlands that are hydrologically connected to any of the shorelines described above, located within 200 feet of a jurisdictional waterbody, or are entirely/partly located within the waterbody’s 100-year floodplain.

EXISTING SHORELINE JURISDICTION PER CURRENT SMP

Under the County’s current Shoreline Master Program (SMP), the following waterbodies are shorelines of the state (as named on Pages 103-108 of the 1996 SMP):

• Trout Lake Creek1 • Gilmer Creek • White Salmon River1 • Klickitat River1

wa M. Lindblad 14 July 2016 Page 2 of 9

• Outlet Creek • Bowman Creek • White Creek • Rock Creek • Buck Creek • Major Creek • Rattlesnake Creek • Columbia River1 • Summit Creek • Spearfish Lake2 • Dead Canyon Creek • Horsethief Lake2 • Swale Creek • Chamberlain Lake2 • Synder Canyon Creek • Rowland Lake2 • Little Klickitat River • Locke Lake2,3 • Mill Creek • Carp Lake

1Shoreline of Statewide Significance 2Associated with the Columbia River System 3Locke Lake is listed in the text of the current SMP as a shoreline associated with the Columbia River system, but was not included in the 2014 shoreline environment designation GIS layer provided by the County.

Existing shoreline jurisdiction includes the shorelands extending landward 200 feet from the ordinary high water mark; floodways and contiguous floodplain areas landward two hundred feet from such floodways; and all associated wetlands, including wetlands located within the 100-year floodplain.

PROPOSED SHORELINE JURISDICTION

Our first step towards updating the County’s shoreline jurisdiction was to review the precise shoreline boundaries and associated wetlands definitions found in the SMA and Ecology rules and guidance documents. We then compiled and reviewed existing GIS data to determine the best available data from which to assemble shoreline jurisdiction. Table 1 below lists the specific GIS data components that were used to assemble shoreline jurisdiction.

Table 1. Klickitat County Shoreline Jurisdiction Component Data Source Source Component Source Layer Name Layer Notes on Usage Layer Date Agency 20 CFS, 200 SMA_Pnts_Sugg.shp (Point) Ecology September This layer CFS, and 2010 provides the 300 square upstream extent miles of of proposed drainage jurisdiction for area points streams and rivers likely to qualify as "shorelines" and "Shorelines of Statewide Significance” based on a 2003 USGS study M. Lindblad 14 July 2016 Page 3 of 9

Source Source Component Source Layer Name Layer Notes on Usage Layer Date Agency SMA_Arcs_Sugg.shp (Line) Ecology September This layer 2010 provides streams and rivers estimated to qualify as Shorelines of the State based on their flow NHDFlowline.shp USGS February Shows streams 2015 and rivers and provides hydrologic order and classification information Lakes 20 SMA_Poly_Sugg.shp (Polygon) Ecology September This layer acres or 2010 provides greater in waterbodies size estimated to qualify as Shorelines of the State based on their area NHDWaterbody.shp USGS February Identifies and 2015 classifies bodies of open water. Ordinary stlkpoly.shp (Line) Klickitat May 2016 County stream high water County locations line

NHDArea.shp USGS February OHWM for bodies 2015 of open water, including some rivers Floodway Klickitat-q3_04-28-14 FEMA April 2014 Areas coded FW under “Floodway” field 100 year Klickitat-q3_04-28-14 FEMA April 2014 Areas coded Floodplain either A or AE under “Zone” field Potentially WA_wetlands.shp (Polygon) USFWS October These wetlands Associated 2015 are included in Wetlands the National Wetland Inventory. They have not been field verified and are for informational purposes only M. Lindblad 14 July 2016 Page 4 of 9

While the proposed shoreline jurisdiction reflects the best available data, the level of accuracy remains limited and ground truthing will be required at the time of development action review. Particularly in areas with dynamic ecological processes, site-specific analysis of the OHWM, wetland boundary and hydrologic connectivity may be needed. Each jurisdiction map therefore includes the following disclaimer, derived from Ecology’s recommendation:

“All features depicted on this map are approximate. They have not been formally delineated or surveyed and are intended for planning purposes only. Additional site-specific evaluation may be needed to confirm/verify information shown on this map. All features depicted on this map are approximate and have not been formally delineated or surveyed and are intended for planning purposes only.”

Streams and Rivers The upstream limit of shoreline jurisdiction for streams and rivers is that point where the mean annual flow is 20 cfs for all downstream areas. The upstream 20 cfs point is based on a 2003 study by USGS1 provided by Ecology. For purposes of this preliminary map set, shoreline jurisdiction is shown extending up to the USGS points, as directed by Ecology.

As far as lateral shoreline jurisdiction for streams and rivers, the preliminary map set shows jurisdiction as the greater of lands extending 200 feet landward in all directions from the OHWM, or the floodway plus contiguous floodplain extending 200 feet landward from the floodway, plus any associated wetlands. FEMA Q3 flood data (2014) was used to determine areas of additional shoreline jurisdiction resulting from the presence of floodways and floodplains. Such areas are shown in two places on the maps: along the Klickitat River near the confluence with Snyder Canyon Creek and on the Little Klickitat River in the vicinity of the City of Goldendale. Stream and river shoreline jurisdiction also includes several waterbodies adjacent to the Columbia River, including Lake Umatilla, Horsethief Lake, Rowland Lake and Chamberlain Lake. These waterbodies are considered lakes and are included in the lakes section below.

East of the crest of the Cascades, rivers that either have mean annual flow of 200 cfs or greater or are located downstream of 300 square miles of drainage area are considered “Shorelines of Statewide Significance.” Consistent with the existing SMP, County rivers that qualify as Shorelines of Statewide Significance include:

• Columbia River • Klickitat River • White Salmon River • Trout Lake Creek

1 http://pubs.usgs.gov/wri/wri034042/pdf/wri034042.pdf M. Lindblad 14 July 2016 Page 5 of 9

Proposed shoreline jurisdiction shown on the included maps includes the same streams and rivers as the current shoreline jurisdiction with the following exceptions:

The following streams and rivers, or portions thereof, have been removed based on the current Ecology data: 1. Buck Creek - approximately 4,900 linear feet removed from upstream extent 2. Trout Lake (on Trout Lake Creek)- removed as a shoreline waterbody, but included as a potentially associated wetland due to the presence of wetland characteristics visible on aerial imagery 3. Little Klickitat River - approximately 13,500 linear feet removed from upstream extent 4. Rock Creek - all removed (approximately 52,000 linear feet); only the Paterson Slough portion is now included as shoreline waterbody, adjacent to Columbia River

The following streams and rivers, or portions thereof, have been added based on the current Ecology stream flow data: 1. Little White Salmon River- western border of county, upstream to T05NR10E31 2. Cave Creek- from confluence with White Salmon River, upstream to T06NR10E32 3. Dry Creek- from confluence with Cave Creek upstream to western County border 4. Major Creek, west fork- from confluence with Major Creek, upstream to T03NR11E02. Previously, only Major Creek mainstem was included in jurisdiction. 5. Snyder Canyon Creek - additional upstream length added, to T04NR13E08. Approximately 8,400 additional linear feet. 6. Swale Creek - additional upstream length added, to T03NR15E15. Approximately 20,000 additional linear feet. 7. Mill Creek - additional upstream length added, to T05NR15E15. Approximately 45,100 additional linear feet. 8. Bowman Creek - additional upstream length added, to T05NR14E14. Approximately 23,800 additional linear feet. 9. Dead Canyon Creek - additional upstream length added, to T05NR13E02. Approximately 1,350 additional linear feet. 10. Trout Creek- from confluence with Klickitat River to northern County border 11. Camas Ditch & Outlet Creek- current jurisdiction includes just a portion of “Outlet Creek”, the Ecology data refers to the waterbody as “Camas Ditch and Outlet Creek” and suggests that an additional upstream length be added, to the confluence with Holmes Creek. 12. Holmes Creek- from confluence with Camas Ditch & Outlet Creek, upstream to T05NR11E02. With Camas Ditch & Outlet Creek extension, approximately 64,700 additional linear feet. 13. Frasier Creek- from confluence with Camas Ditch & Outlet Creek, to northern County border M. Lindblad 14 July 2016 Page 6 of 9

14. White Creek - additional upstream length added, to northern County border. Approximately 10,500 additional linear feet. 15. Summit Creek - additional upstream length added, to northern County border. Approximately 43,000 additional linear feet. 16. Satus Creek- from northern County border, upstream to T06NR18E05. Approximately 4,000 linear feet.

Two streams near the community of Trout Lake were identified in Ecology’s data as meeting the 20 cfs flow requirement per the USGS study, but are not included in the proposed shoreline jurisdiction: Gotchen Creek and Hole in the Ground Creek. These waterbodies are not included in shoreline jurisdiction under the current SMP and do not appear to meet the criteria for a shoreline waterbody based on the following evidence. Per Ecology’s GIS data layer, these two streams flow southward from Yakima County into an agricultural area north of Sunnyside Road where they appear to become part of the agricultural ditch system. However, upon further investigation, the system of irrigation ditches originate from direct flow out of the White Salmon River and are not connected to either Gotchen Creek or Hole in the Ground Creek. A 2012 study of the Trout Lake area by Anderson Perry & Associates identifies two agricultural ditches near Sunnyside Road as Hoke and Coate ditches (see enclosed map). These two ditches are documented in the study as having a gated control along the White Salmon River that can, and is, shut off when they are not being used for irrigation, thereby stopping all flow in the ditches. A windshield survey on 12 July 2016 was unable to locate Hole in the Ground Creek and Gotchen Creek or any hydrologic connections from stream into these two agricultural ditches. Furthermore, the 2003 USGS study does not show any connection between these two streams and the White Salmon River or any other downstream waterbody. Therefore, we have excluded these areas from the proposed shoreline jurisdiction maps.

Lakes Lakes larger than 20 acres qualify as Shorelines of the State. According to Ecology’s shoreline data, there are six suggested lakes present in the County that may be 20 acres or greater. The majority of these are associated with the Columbia River system, as noted above (Lake Umatilla, Horsethief Lake, Rowland Lake and Chamberlain Lake). The two lakes not associated with the Columbia River system are Mill Pond, which is associated with Camas Ditch and Outlet Creek, and Carp Lake.

The County does not have any lakes that qualify as Shorelines of Statewide Significance (greater than 1,000 acres).

Proposed shoreline jurisdiction includes the same lakes as the current shoreline jurisdiction with the following exceptions:

Locke Lake and Spearfish Lake were removed from shoreline jurisdiction because they are not 20 acres. M. Lindblad 14 July 2016 Page 7 of 9

Carp Lake was removed from shoreline jurisdiction because a review of aerial imagery and on-the-ground accounts indicate it is now dry. It may be a wetland but no longer meets the criteria to be considered a shoreline lake, and is not associated with any other shoreline waterbody.

Mill Pond was added to shoreline jurisdiction. It is 26 acres, associated with Camas Ditch and Outlet Creek.

Note that Spearfish Lake is included in the current Ecology shoreline waterbody dataset, however, the Ecology data and USDS data show it measuring as 15 acres, and therefore it has been excluded from the proposed jurisdiction based on size. The adjacent waterbody, Little Spearfish Lake is not included in the Ecology shoreline dataset and does not appear to have a permanent connection to Spearfish Lake, therefore it was not included in the size calculation.

Lake Umatilla, which is part of the Columbia River system, is currently included as part of the Columbia River shoreline jurisdiction but is not referred to as Lake Umatilla. The proposed jurisdiction maps identify it as Lake Umatilla, consistent with the Ecology dataset. Some additional areas adjacent to, and hydrologically connected to Lake Umatilla are included in the proposed shoreline jurisdiction.

Associated Wetlands Associated wetlands are those wetlands that are “in proximity to and either influence or are influenced by … a lake or stream subject to the Shoreline Management Act” and “[t]he entire wetland is associated if any part of it lies within the area 200 feet from either the ordinary high water mark or floodway” or “if any part is located within the 100 year floodplain of a shoreline.”2 Wetlands meeting the latter two criteria are labeled “Potentially Associated Wetland” in the attached map set. Location and boundary of these wetlands were drawn from the October 2015 USFWS National Wetlands Inventory (NWI) GIS data.

Non-associated wetlands were intentionally omitted from this map set but will be depicted on other maps as part of the Shoreline Inventory Map Folio. However, wetlands that are either outside of the floodplain or the 200-foot standard shorelands area may still be associated on the basis of a hydraulic connection to the shoreline. Wetlands that are separated by an obvious topographic break from the shoreline are not associated, provided that they are outside the shoreland zone and that the break is not an artificial feature such as a berm or road. These possible additional associated wetlands can only be determined on a project-level basis at the time of development action review. Further, the NWI wetland data were generated using high- altitude imagery and photo interpretation techniques to produce an inventory of reconnaissance

2 http://www.ecy.wa.gov/programs/sea/sma/st_guide/jurisdiction/Shorelands.html M. Lindblad 14 July 2016 Page 8 of 9

level of wetland location, type and size. Therefore, actual wetland presence and boundaries must be verified at the project level.

OPTIONAL SHORELINE JURISDICTION BOUNDARIES

The information above describes assembly of the minimum shoreline jurisdiction. The County may further elect to expand jurisdiction to include 1) all or part of the 100-year floodplain, and/or 2) buffers of associated wetlands3 that would otherwise encompass areas outside of shoreline jurisdiction. Under either of these options, the area of shoreline jurisdiction increases and additional properties or areas of properties would be subject to the SMP and its additional layer of permitting requirements.

These options should be considered by the County. The attached maps do not depict the expansion of shoreline jurisdiction to include critical area buffers and/or floodplain. Classification of associated wetlands, which would ultimately determine the regulatory buffer, has not been conducted and would be done on a site-by-site basis at the time of a development application. Evaluation of the impact from expanding jurisdiction to include floodplains can be assessed by viewing the floodplain maps which will be provided in the Shoreline Inventory Map Folio at a later date.

RCW 36.70A.480(6) says “If a local jurisdiction's master program does not include land necessary for buffers for critical areas that occur within shorelines of the state, as authorized by RCW 90.58.030(2)(f), then the local jurisdiction shall continue to regulate those critical areas and their required buffers pursuant to RCW 36.70A.060(2).” Ecology’s SMP Handbook chapter on Shoreline Jurisdiction explains the implications of this RCW as follows:

If the local government chooses not to extend its shoreline jurisdiction under RCW 90.58.030(2)(f)(ii), the CAO will protect the entire critical area and its buffers (see RCW 36.70A.480(6)). The CAO will continue to apply to the entire critical area and its buffers, even after SMP approval. However, the SMP will also apply to the portion(s) of the critical area and its buffers that lie within shoreline jurisdiction. This means the subject critical area and some or all of its buffers will have “dual coverage” with regulation by both the SMP and the CAO.

Please call if you have any questions.

3 The RCW actually allows for expansion of jurisdiction to include critical area buffers, not just wetland buffers. However, this generally is limited to wetland buffers in practice. The nature of non-shoreline streams as a mostly perpendicular element to a shoreline waterbody already brings their full buffer into shoreline jurisdiction. Geologically hazardous areas are generally assigned a setback, not a buffer. Critical aquifer recharge areas (CARAs) are not addressed in the SMA or SMP Guidelines, and CARAs further are not assigned a setback or a buffer. M. Lindblad 14 July 2016 Page 9 of 9

Sincerely,

Dan Nickel Environmental Engineer

Enclosures

DRAFT KLICKITAT COUNTY PRELIMINARY SHORELINE JURISDICTION - WHITE SALMON NORTH Page 1 of 8 S k a m a n i a Y a k i m a

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k e re Yakama Indian Reservation Ca ve C Cave Creek City UGA

County Boundary Dry Creek «¬141 Data sources: US Fish and Wildlife Service, US Geological Survey, Washington State Department of Ecology, Klickitat County, The Watershed Company

Date: 7/12/2016

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Little White Salmon River DRAFT KLICKITAT COUNTY PRELIMINARY SHORELINE JURISDICTION - WHITE SALMON SOUTH Page 2 of 8

Little White Salmon River

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«¬141 Data sources: US Fish and Wildlife Service, US Geological Survey, Washington State Department of Ecology, Klickitat County, The Watershed Company

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All features depicted on this map are approximate. They have not been formally delineated or surveyed and are intended for planning purposes only. Additional site-specific evaluation may be needed to confirm/verify information shown on this map. Bowman Creek Bowman DRAFT KLICKITAT COUNTY PRELIMINARY SHORELINE JURISDICTION - KLICKITAT RIVER SOUTH Page 4 of 8

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Data sources: US Fish and Wildlife Service, US Geological Survey, Washington State Department of Ecology, Klickitat County, The Swale Creek Swale Creek Watershed Company

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The Dalles Dam DRAFT KLICKITAT COUNTY PRELIMINARY SHORELINE JURISDICTION - LITTLE KLICKITAT RIVER NORTH Page 5 of 8

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M A P L E G E N D Preliminary Shoreline Satus Creek Jurisdiction SMP Stream

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«¬97 Data sources: US Fish and Wildlife Service, US Geological Survey, Washington State Department of Ecology, Klickitat County, The Watershed Company

Date: 7/12/2016

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Little Klickitat River DRAFT KLICKITAT COUNTY PRELIMINARY SHORELINE JURISDICTION - LITTLE KLICKITAT RIVER SOUTH Page 6 of 8

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Data sources: US Fish and Wildlife Service, US Geological Survey, Washington State Department of Ecology, Klickitat County, The Centerville Watershed Company

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Miller Island DRAFT KLICKITAT COUNTY PRELIMINARY SHORELINE JURISDICTION - LAKE UMATILLA WEST Page 7 of 8

M A P L E G E N D Preliminary Shoreline Jurisdiction SMP Stream

SMP Waterbody Potentially Associated Wetlands State Highway

Parcel Boundary

Yakama Indian Reservation

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County Boundary

Data sources: US Fish and Wildlife Service, US Geological Survey, Washington State Department of Ecology, Klickitat County, The Watershed Company

Date: 7/12/2016

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