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Ecology Permitting of Dynamic Revetments

Shoreline & Coastal Planners Group, Sept. 16, 2025

Zach Meyer, Ecology Shorelands Technical and Regulatory Lead

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Photo: North Cove Dynamic Revetment, https://wacoastalnetwork.com/north-cove-dynamic-revetment/

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Overview of applicable Ecology regulations

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404/401 Clean Water Act, Ecology & Corps

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Shoreline Management Act, Ecology & Local Gov

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Coastal Zone Management Act, Ecology

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Clean Water Act 404/401

Project must impact water of the US (below high tide line for coastal armoring projects)
Recommend Corps jurisdictional determination
Ecology 401 requirements would largely be related to water quality protections and ecological impacts

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So for the Clean Water Act, the project has to impacts a water of the US, meaning the project has to occur below high tide line.

The majority of dynamic revetment projects permitted to date have been determined to be above Corps jurisdiction and not required a 404/401. One that did require 404/401 was the graveyard spit project in Tokeland which Chelsea from DOT will talk a little bit more from a project applicants point of view of the 404/401 process.

I would recommend a Corps JD or consultation early in the process as some projects (such as the Westport by the Sea dynamic revetment) were determined to be above high tide line and outside of Corps jurisdiction.

Generally, Ecology’s 401 requirements are going to be related to water quality during construction, so monitoring for exceedance of any of the states water quality standards, methods for dewatering work areas, or ecological impacts such as wetland impacts and compensatory mitigation.

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Coastal Zone Management Act

For projects with federal action (federal project or permit)
ECY review of enforceable policies

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Shoreline Management Act�RCW 90.58

Local/State partnership

Shoreline Master Programs

Specific regulations related to shoreline stabilization in SMPs based on requirements of WAC 173-26-231(3)(a).

Dynamic revetments likely to trigger Shoreline Conditional Use Permits

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There is not sufficient time to get into all the specifics and background of the SMA, I am part of a team that does a muli-day training on shoreline permitting, but I will touch on some important pieces to discuss shoreline permitting as it relates to shoreline stabilization projects such as dynamic revetments.

Each local government develops a Shoreline Master Program with Ecology and in these local master programs there are specific regulations related to shoreline stabilization. Generally, SMPs have three overarching principles, coordinated shoreline development focusing on preferred uses such as water dependent and single family residences, protection of ecological functions, and providing/improving public access.

In practice, most dynamic revetments have triggered a conditional use permit under the local SMP, which gets reviewed and approved by Ecology and the local gov. I am going to chat about some of the specifics of the shoreline stabilization requirements in SMPs as well as the CUP criteria used to review these sort of proposals. You will look to the specific SMP to determine if a CUP is triggered, but generally things like armoring or fill below OHWM is going to trigger a CUP, so I have included a discussion of this today. Both the Westport by the Sea and North Cove dynamic revetment projects received CUPs for their projects.

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Shoreline stabilization requirements �(WAC 173-26-231(3)(a))

Geotechnical analysis

Ecological impacts

Public access

CUP criteria (WAC 173-27-160)

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Westport by the Sea dynamic revetment

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Geotechnical analysis

Required by SMPs for armoring projects

Demonstration of need

Alternative analysis

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The first being the geotechnical analysis.

Any shoreline stabilization project is going to require a licensed Geotech to prepare a geotechnical analysis. There are very specific questions listed in the SMP to answer. For example, quantifying the rate of erosion, quantifying the timeline for when a structure is at threat, looking at the history of a site. All of this helps provide the demonstration of need.

This analysis is the base of an application for armoring, and is also providing an alternative analysis on ways to address the problem that is presented.

Most SMPs have a specific section on the requirements of a geotechnical report that supports an armoring proposal, so be sure to consult the applicable SMP.

One item to keep in mind, and the first decision point that occurs, to determine if any armoring can be permitted comes from the demonstration of need. Is there a primary structure at threat within the next few years that needs protecting. In the cases where dynamic revetments have been permitted (Westport and North Cove) this was obvious, but putting numbers to the situation is a requirement.

Ecology and WDFW both now have engineering teams to review these type of reporting and we would welcome consultation if you are considering the need for armoring.

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Ecological impacts and mitigation

Shoreline/buffer vegetation

Wetlands

Sediment transport

Edge effect erosion

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All shoreline projects are held to a no-net-loss of ecological function standard. You are going to hear this from Lauren as well regarding HPAs as this no-net-loss of ecological function theme crosses many state laws. If there are any impacts are identified, they would typically require compensatory mitigation.

Generally, projects are going to include some sort of dune plantings/restoration. If there are other impacts identified such as wetland fill or perhaps impacts to a feeder bluff impacting sediment transport the proposal would have to compensate for these sort of ecological impacts.

Overall, since dynamic revetments are nature based solutions, we have not seen any approved that have had significant ecological impacts. Some have had dune plantings behind the revetment. The potential ecological impacts is something that will be addressed on a case-by-case basis.

Shown is the graveyard spit project which again Chelsea will chat more about specifics, but part of that proposal includes dune and wetland restoration, and the dynamic revetment itself is protecting coastal wetlands and high quality habitat. Although that specific project did not get shoreline permits as it qualified for a wdot exception (certain dot project are not required to get shoreline permits) and some of this was on tribal land where SMA does not apply, Ecology still considered the requirements of the SMA during is CZM review.

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Public access

Project can not limit public access

Opportunities to provide better/improved public access

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Public beach access trail

Photo: WA state Parks

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Conditional Use Permit Criteria (WAC 173-27-160)

Consistency criterion, WAC 173-27-160(1)(a)
Normal public use criterion, WAC 173-27-160(1)(b)
Compatibility criterion, WAC 173-27-160(1)(c)
Adverse effects criterion, WAC 173-27-160(1)(d)
Public interest criterion, WAC 173-27-160(1)(e)
Cumulative impacts criterion, WAC 173-27-160(2)

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Besides the specific standards just discussed, there are some generally review criteria for any shoreline project that triggers a conditional use permit.

If a conditional use permit is triggered, it will require review and approval from local gov and Ecology, and this has been the case for most dynamic revetment projects. Ecology has a 50 page guidance doc on these review criteria so again I could talk about this for a lot longer, but I will provide some highlights. CUPs are often triggered for armoring projects or for fill below OHWM which is often part of a dynamic revetment proposal. See specific SMP where a project is proposed for the permitting pathways, and Ecology is also available to discuss or provide technical assistance as needed.

That the proposed use is consistent with the policies of RCW 90.58.020 and the master program; Consistency with goals of SMA which are planning for preferred uses (which includes single family residences or water dependent uses (like ports), protecting ecological functions, and public access
That the proposed use will not interfere with the normal public use of public shorelines; Public access. Would this interrupt beach walking? Access trails?
That the proposed use of the site and design of the project is compatible with other authorized uses within the area and with uses planned for the area under the comprehensive plan and shoreline master program; Compatibility with uses in the area as well as potential visual impacts. Dynamic revetments are good here as they have a more natural assetic compared to other armoring alternatives.
That the proposed use will cause no significant adverse effects to the shoreline environment in which it is to be located; Potential impacts as described on previous slide. May require some mitigation to achieve no-net-loss of ecological function. Often these projects are planting/reestablishing dune behind the revetment. and
That the public interest suffers no substantial detrimental effect. This again brings in visual intrusions, public access,

2) In the granting of all conditional use permits, consideration shall be given to the cumulative impact of additional requests for like actions in the area. For example, if conditional use permits were granted for other developments in the area where similar circumstances exist, the total of the conditional uses shall also remain consistent with the policies of RCW 90.58.020 and shall not produce substantial adverse effects to the shoreline environment. In this, we must consider the implications of similar projects on similar stretches of beach and if there is a detrimental effect.

Overall, in cases where a demonstration of need has been established, a dynamic revetment has been identified as a ecologically appropriate fit and effective to address the situation, any ecological and public access impacts have been avoided or mitigated for, then we should be meeting most of this criteria. Each project gets its own analysis and will have unique attributes to consider.

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��Is a dynamic revetment the appropriate solution for the problem?

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12/27/22 - King Tide on Mutiny Bay

Erosion not threatening a primary structure.

Mutiny Bay 12/2022

There are some regulatory considerations for when it is appropriate to propose a dynamic revetment, and keep in mind that this is not a one-size fits all solution for all coastal issues. For example, coastal flooding, locations where structures are not threatened, or perhaps a locations where a dynamic revetement doesn’t make sense for a specific landscape setting are all places where armoring may not be appropriate or permittable or some other solution is warranted.

Keep in mind, if there is no demonstration of need (primary structure at threat) then armoring can not be authorized under the shoreline management act. All the situations I can think of that the agencies have permitted dynamic revetments have had a clear demonstration of need and had been experiencing significant erosion for many years.

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Emergency Shoreline Exemption Authorizations

Only in specific circumstances
Local gov, WDFW, and potentially Corps involved
After-the-fact shoreline permitting to retain
Risks associated with this approach, potential design changes during permit review

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Ecology guidance document:

https://apps.ecology.wa.gov/publications/documents/2306001.pdf

Although not the typical permitting process, I should note the emergency authorizations as I know of one dynamic revetment style project that was authorized as an emergency and will be going through after-the-fact permitting.

Emergencies are unanticipated events posing an imminent threat to health, safety, or the environment that do not allow for site specific design, detailed study, or standard permitting processes… typically shoreline erosion is not technically going to fit the WAC definition of emergency, but I have seen it used to permit one dynamic revetment project so it is worth mentioning.

You will want to coordinate with agencies, and specifically the local gov, WDFW, and potentially the Corp all should be issuing emergency authorization for work.

With an emergency shoreline exemption, the project needs to go through after-the-fact permitting to be retained. There is some risk with this approach as the design or specifics of the project may get changed or altered during the permit review resulting in work being undone or re-done. It is best if there is an erosion threat to get this stuff permitted appropriately up front. Additionally, emergencies are generally only for unanticipated threats and temporary measures, so observations of multiple years of erosion may not be viewed as appropriate for emergency approval.

Ecology has a guidance document on how these shoreline emergency exemptions work which I would encourage folks to check out for more detail.

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Updating SMP Guidelines

HB 1181 (RCW 90.58.630) directs Ecology to:

“…update its shoreline master program guidelines to require shoreline master programs to address the impact of sea level rise and increased storm severity on people, property, and shoreline natural resources and the environment.”

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Updating SMP Guidelines

Ecology is currently conducting rulemaking to amend shoreline rules.

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Updating SMP Guidelines

Rulemaking opportunities:

Better differentiate hazards and provide pathways to appropriately address coastal flooding, erosion, and permanent inundation
Establish new process and content requirements to ensure that SMPs address sea level rise impacts (e.g., vulnerability assessments)

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Image credit: Stuart Isett, www.isett.com

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Updating SMP Guidelines

Rulemaking limitations:

Shoreline management is only one lever for sea level rise adaptation, other initiatives needed
Updated local SMP policies and regulations are years away

2029

2030

2032

Periodic review due dates

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In closing: Lessons learned

Only a few of these have been permitted, and each one has been unique
Agency coordination
Importance of geotechnical reporting
Keeping public access to beaches open
Monitoring requirements to gain useful information about performance, ecological impacts, and maintenance needs of these structures

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To close, I want to provide some of the lessons learned in reviewing and approving dynamic revetment projects on the coast.

Shifting regulatory landscape with upcoming new SMP rules, and site specific differences whether that is geological, biological, or regulatory, each project is going to be unique.

This highlights the importance of coordination with regulatory agencies early in the project. Talk to us before too much is invested.

Geotechnical reporting is an important requirement, and Ecology as well as WDFW have geotechnical engineers reviewing this stuff. Again, coordinate with the agencies to get on the same page.

Think about impacts to public access and how to prevent these, improve access.

Permitted shoreline stabilization projects are generally going to have some monitoring component to them to gain understanding of the specific projects performance and its impacts, as well as inform the gritter knowledge of these relatively new type of shoreline stabilization measures.

I have said it a few times just on this slide, but reach out to us if you are in the early stages of these sort of projects.

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Thank you

Zach Meyer

Dept. of Ecology

Shorelands Technical and Regulatory Lead

zachary.meyer@ecy.wa.gov

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