HEX Decision_PLN52110 SSDEA_COBI- Jones - Burke-Jones SSDE Appeal (10.3.22)
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 1 of 30
BEFORE THE HEARING EXAMINER
FOR THE CITY OF BAINBRIDGE ISLAND
In the Matter of the Appeal of ) No. HEA-2012-01*
) No. PLN52110 SSDE
Paul D. Jones and Becky Ann )
Burke-Jones )
)
Of a Shoreline Exemption ) FINDINGS, CONCLUSIONS, AND
Amendment Denial ) DECISION
SUMMARY OF DECISION
This appeal addresses whether the Planning Director of the City of Bainbridge Island (City) erred
in denying a request for an amendment to a previously approved emergency shoreline exemption
that would allow for the construction of a rock bulkhead with accompanying wingwalls, concrete
steps, and a stormwater diffuser as “emergency” protection measures to address the failure of an
existing concrete bulkhead on the subject property. Because substantial evidence in the record
supports the determination that the proposed emergency construction would not be consistent
with the policies of the Shoreline Management Act or the City Shoreline Master Program, the
City did not clearly err in denying the emergency shoreline exemption amendment request.
Accordingly, the Director’s decision is AFFIRMED, and the appeal is DENIED.
SUMMARY OF PROCEEDINGS
Hearing Date:
The City of Bainbridge Island Hearing Examiner held an open record appeal hearing on June 7,
14, and 24, 2022, using remote access technology. The record was held open until July 8, 2022,
to allow the parties to submit closing briefs.
Testimony:
The following individuals presented testimony under oath in this matter:
Appellant Witnesses:
Erik Andersen, P.E., Principal Geotechnical Engineer, Aspect Consulting, LLC
Paul Jones, Appellant
Ryan Lewis, Project Manager, Sealevel Bulkhead Builders, Inc.
Jennifer Rotsten, Officer, Sealevel Bulkhead Builders, Inc.
Alison Dennison, LEG, Senior Engineering Geologist, Aspect Consulting, LLC
* The Hearing Examiner notes that this matter was inadvertently labeled as “HEA-2012-01” in the initial
pre-hearing order sent to the parties but should have been identified as “HEA-2022-01.” All submissions
by the parties since that time have (understandably) referred to this matter as “No. HEA-2012-01.” To
avoid confusion, the Hearing Examiner has determined it would be best to leave his own error uncorrected.
That said, the record clearly reflects this matter involves an appeal from 2022 (not from 2012).
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 2 of 30
City Witnesses:
Jim Johannessen, MS & LEG, Principal Coastal Geologist, Coastal Geologic Services, Inc.
Wei Chen, PhD, P.E., Senior Coastal Engineer, Coastal Geologic Services, Inc.
Peter Best, MMA, City Senior Planner
Paul Nylund, P.E., City Engineering Manager
Attorneys Piper Thornburgh and Stephanie E. Marshall represented the Appellant at the appeal hearing.
Attorney James E. Haney represented the City of Bainbridge Island at the appeal hearing.
Exhibits:
The following documents were submitted to the Hearing Examiner for review and admitted as
exhibits:
Appellant Exhibits:
A-1. Emergency Shoreline Exemption Amendment Decision, dated March 14, 2022
A-2. Emergency Shoreline Exemption Decision, dated December 1, 2021
A-3. Hydraulic Project Approval, issued March 14, 2022
A-4. Geotechnical Assessment of Bulkhead Repair Project, Aspect Consulting, LLC, dated
January 6, 2022
A-5. PLN52110 SSDEA (Jones Emergency Bulkhead) Code Analysis, sent February 11, 2022
A-6. Site Plan, revised December 13, 2021
A-7. Hydraulic Project Approval, issued December 1, 2021
A-8. Hydraulic Project Approval, issued January 14, 2022
A-9. Email from Peter Best to Jenny Rotsten, dated January 20, 2022, with email string
A-10. Email from Jenny Rotsten to Peter Best, dated February 3, 2022, with email string
A-11. Email from Peter Best to Jenny Rotsten, dated February 11, 2022, with email string
A-12. Email from Alison Dennison to Peter Best, dated February 11, 2022, with email string
A-13. Email from Alison Dennison to Peter Best, dated February 14, 2022
A-14. Email from Jenny Rotsten to David Greetham, dated February 15, 2022
A-15. Jones Bulkhead Timeline, dated March 25, 2022
A-16. Agreement for Professional Services between City of Bainbridge Island and Wood
Environment and Infrastructure Solutions, Inc., dated February 22, 2022
A-17. Agreement for Professional Services between City of Bainbridge Island and Associated
Earth Sciences, Inc., dated February 22, 2022
A-18. Agreement for Professional Services between City of Bainbridge Island and Aspect
Consulting, LLC, dated February 22, 2022
A-19. Site Photograph (Low Tide 1)
A-20. Site Photograph (Low Tide 2)
A-21. Site Photograph (Low Tide 3)
A-22. Site Photograph (Looking South from North)
A-23. Site Photograph (Looking South from North)
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 3 of 30
A-24. Site Photograph (North)
A-25. Jones Short Plat, dated November 19, 2013
A-26. Erik Andersen Resume
A-27. Alison Dennison Resume
City Exhibits:
C-1. Emergency Shoreline Exemption Amendment Decision, dated March 14, 2022, with the
following attachments:
a. Review Timeline, undated
b. Eight (8) Site Photographs, various dates
c. Emergency Shoreline Exemption Decision, dated December 1, 2021
d. Email from Peter Best to Jenny Rotsten and Alison Denison, dated December 2,
2021, with email string
e. Site Plan, revised February 3, 2022
f. Geotechnical Assessment of Bulkhead Repair Project, Aspect Consulting, LLC,
dated January 6, 2022
g. Email from Peter Best to Jenny Rotsten, dated February 11, 2022, with email
string
h. Email from Alison Dennison to Peter Best, dated February 23, 2022, with email
string
i. Appendix H: Expedient Coastal Protection
j. PLN52110 SSDEA (Jones Emergency Bulkhead) Code Analysis, undated
C-2. Master Land Use Application, dated February 3, 2022
C-3. Jones Project Narrative, undated
C-4. Hydraulic Project Approval, issued January 14, 2022
C-5. Peter Best Curriculum Vitae
C-6. Jones Emergency Shoreline Exemption Amendment (PLN52110 SSDEA) Photo
Comparison, prepared May 24, 2022
C-7. Paul Nylund Resume
C-8. Coastal Geologic Evaluation of Proposed Jones Temporary Shore/Slope Protection,
Coastal Geologic Services, Inc., dated May 31, 2022
C-9. Jim Johannessen Resume
C-10. Wei Chen Resume
Orders, Motions, & Briefs
• Appeal, dated March 25, 2022
• Letter from Attorney Piper Thornburgh, dated March 25, 2022
• Email from Attorney Piper Thornburgh, dated April 18, 2022
• Pre-Hearing Order, dated May 6, 2022
• Appellant’s Dispositive Motion, dated May 17, 2022
• City’s Response to Appellant’s Dispositive Motion, dated May 24, 2022
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 4 of 30
• Declaration of James Haney in Response to Appellant’s Dispositive Motion, dated May
24, 2022
• Notice of Association of Counsel, dated May 25, 2022
• Appellant’s Witness and Exhibit List, dated May 30, 2022
• City’s Witness and Exhibit List, dated May 31, 2022
• City’s Prehearing Brief, dated May 31, 2022
• Appellant’s Motions in Limine and Request for Site Visit, dated June 3, 2022
• City’s Response to Appellant’s Motion in Limine and Request for Site Visit, dated June
6, 2022
• Decision on Appellant’s Pre-Hearing Motions, dated June 6, 2022
• Appellant’s Closing Argument, dated July 8, 2022
• City’s Post-Hearing Brief and Closing Argument, dated July 8, 2022
FINDINGS
Background
1. Paul D. Jones and Becky Ann Jones (Appellant) own waterfront property at 11376 Arrow
Point Drive. The property is located along the Puget Sound shoreline (Manzanita Bay)
and is developed with a 2,395 square foot, two-story single-family residence, 812 square
foot detached garage, 560 square foot cabin, and 195 square foot boathouse. The
property slopes slightly down from the east property line to the top of a steep slope along
the Manzanita Bay shoreline to the west, with approximately 44 feet of elevation loss.
An approximately 31-foot-wide, level bench ran from the toe of the slope to the top of a
concrete bulkhead that extended along the property’s 140 feet of shoreline, which was
constructed sometime prior to 1969. The boathouse structure was constructed within this
level bench area in 2013, pursuant to a permit granted by the City of Bainbridge Island
(City) in 2012. The foundation system for the boathouse consists of a concrete slab-on-
grade with thickened edges, with the base of the concrete footing located approximately
two feet below the existing ground surface. The single-family residence, detached
garage, and cabin are located to the west of the boathouse, on relatively level ground
above the bluff. Exhibit A-4; Exhibits A-19 through A-25; Exhibit C-1; Appeal, dated
March 25, 2022.
2. Given concerns over the age and long-term stability of the existing concrete bulkhead on-
site, the Appellant contracted with Aspect Consulting, LLC, (Aspect) in 2021 to evaluate
the conditions of the existing concrete bulkhead. On September 9, 2021, Aspect
determined that the 8.5-foot-tall concrete bulkhead was beginning to fail, observing
evidence of large cracks, shallow embedment of the footing, corrosion of the tieback
anchors, and a slight lean toward the water. On October 19, 2021, Appellant Paul Jones,
Jenny Rotsten of Sealevel Bulkhead Builders (Sealevel), and Alison Dennison of Aspect,
attended a remote pre-application conference with City Senior Planner Peter Best and
City Public Works Engineering Manager Paul Nylund to discuss permitting requirements
for the repair of the failing concrete bulkhead. At the preapplication conference, the
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 5 of 30
Appellant discussed a bulkhead repair/replacement proposal that would consist of
removing the existing concrete bulkhead, installing 50 feet of new rock bulkhead just
landward of the existing concrete bulkhead to the west of the boathouse, installing an
additional 20-foot rock wing wall extending to the northeast to provide additional
protection to the boathouse, and installing a second (new) rock wing wall at the northern
property line to provide protection to the existing bulkhead on the adjacent property to
the north. The proposal also included soft bulkhead protection measures for the
remaining shoreline areas. The Appellant contends that City staff viewed the proposal
favorably at that time, but the City disagrees with this characterization. Exhibit A-4;
Exhibit A-6; Exhibit A-15; Exhibit A-19 through A-25; Exhibit C-1; Appeal, dated March
25, 2022; Appellant’s Dispositive Motion, dated May 17, 2022; City’s Response to
Appellant’s Dispositive Motion, dated May 24, 2022.
3. On November 29, 2021, following heavy rainfalls in September through November of
2021, the Appellant saw that the entire 140-foot length of the existing concrete bulkhead
had collapsed onto the beach. The next day, a site meeting was held at the subject
property to discuss emergency measures to protect the boathouse in light of the collapsed
concrete bulkhead, with Appellant Paul Jones, Alison Dennison, Ryan Lewis of Sealevel,
Peter Best, and Paul Nylund in attendance. The same day, the Appellant applied for an
emergency shoreline exemption to allow for emergency measures consisting of placing
filter fabric and sandbags along up to 70 feet of exposed slope behind the failed concrete
bulkhead, which was approved, with conditions, by City Interim Planning Director Mark
Hofman on December 1, 2021. The same day, the Appellant also obtained expedited
Hydraulic Project Approval (HPA) from the Washington State Department of Fish and
Wildlife (WDFW) to allow for the temporary emergency erosion control measures. The
Appellant thereafter installed the approved filter fabric and sandbags, consistent with the
approved emergency shoreline exemption and the expedited HPA. Exhibits A-2 through
A-4; Exhibit A-15; Exhibits A-19 through A-24; Exhibit C-1; Appeal, dated March 25,
2022.
4. On December 2, 2021, City Senior Planner Peter Best emailed Jenny Rotsten and Alison
Dennison to provide guidance on the requirements for obtaining a shoreline substantial
development permit (SSDP) to allow for permanent shoreline stabilization measures. Mr.
Best noted that provisions of the City Shoreline Master Program (SMP) allowing for the
repair of up to 50 percent of existing damaged structural stabilization would not apply to
the current situation on the subject property given the complete (100 percent) failure of
the concrete bulkhead and that SMP policies do not allow for structural stabilization
modifications or for the replacement of existing hard shoreline stabilization structures
unless necessary to protect a primary structure, which would not include the accessory
boathouse structure. He further noted that replacement shoreline stabilization measures
would not likely meet the criteria for a shoreline variance. Mr. Best suggested addressing
the issue by modifying and/or moving the boathouse onto a pile foundation, moving it to
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 6 of 30
an allowed location not requiring shoreline stabilization with a rock bulkhead, or
removing it from the property. Exhibit C-1.d.
5. On December 8, 2021, Paul Jones, Alison Dennison, and Ryan Lewis attended a site
meeting with WDFW Habitat Biologist Nam Siu to discuss an expedited bulkhead
replacement proposal. No members of City staff were in attendance at this site meeting.
Following the site meeting, the Appellant applied for an expedited HPA to allow for the
bulkhead replacement proposal described above in Finding 2. The Appellant withdrew
the expedited HPA application on December 27, 2021, after Mr. Siu advised that the
proposal would require an alternatives analysis. On January 7, 2022, the Appellant
resubmitted the application for an expedited HPA with a geotechnical assessment and
alternatives analysis provided by Aspect, dated January 6, 2022, which WDFW approved
on January 14, 2022. Exhibit A-3; Exhibit A-8; Exhibit A-15; Exhibit C-4; Appeal, dated
March 25, 2022.
6. The January 6, 2022, geotechnical assessment determined that the proposed rock
bulkhead would “provide adequate long-term protection of the existing boathouse, the
shared stormwater infrastructure along the southern property line, and the existing
rockery along the northern property line.” The assessment also included an alternatives
analysis as required by Revised Code of Washington (RCW) 77.55.231(1)(b), which
asserts in pertinent part:
• The existing concrete bulkhead is no longer functioning as intended, and if
nothing is done to repair the portion of bulkhead directly in front of the
boathouse, the shoreline will continue to erode, and the boathouse will fall into
Manzanita Bay imminently, in a matter of weeks.
• There is no other suitable place within the level bench area on the property in
which to move the boathouse, and moving the boathouse with large slab-on-grade
with thickened footings would be cost prohibitive.
• Replacing the concrete bulkhead with soft armoring would be cost prohibitive and
would not provide adequate protection for the boathouse structure.
• There is insufficient space in which to construct an upland retaining wall that
would protect the boathouse structure.
• The existing bulkhead could be partially replaced with hard bulkhead landward of
the existing bulkhead to protect the boathouse structure.
Exhibit A-4; Exhibit C-1.f.
7. On January 19, 2022, the Appellant provided the City with the expedited HPA approved
by WDFW, and requested that the City provide written approval of an emergency
exemption to commence the emergency work. The next day, Mr. Best responded that the
City could not approve the proposed emergency bulkhead proposal because it would not
be consistent with the SMA and the City SMP, as was explained in his earlier December
2, 2021, preapplication guidance letter/email. The Appellant later requested guidance
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 7 of 30
from the City on the submittal requirements for an application to amend the previously
approved emergency shoreline exemption, which the City provided on February 2, 2022.
Exhibit A-9; Exhibit A-10.
Emergency Shoreline Exemption Amendment Request
8. On February 3, 2022, the Appellant applied for an amendment to the emergency
shoreline exemption to allow for the construction of a repair/replacement rock bulkhead,
wing walls, concrete steps, and a stormwater diffuser as emergency protection measures
to address the failure of the existing concrete bulkhead. The Appellant provided a project
narrative, which specifically described the proposal as follows:
The proposal includes the removal of the fallen approximately 140-foot
concrete bulkhead. Approximately 70 feet of the bulkhead will be
replaced with rock, around 50 feet in front of the boathouse and a 20-foot
wing wall to the north. The base rocks will be keyed in about 3 feet with
the remaining stacked on top to a total above grade of approximately 7
feet. Quarry spalls will be installed behind the armor rock and filter fabric
placed between the spalls and the bank. Precast concrete steps will be
built into the bulkhead for beach access. The remaining approximate 70
feet will be smoothed out to restore to nature. All access will be by barge.
The old concrete bulkhead material will be removed from the beach. A
wing wall will be built along the north property line to protect the
neighboring bulkhead, as recommended by the geotechnical engineer.
Additionally, the existing drainage will be extended to outlet within this
wing wall and above the ordinary high-water mark. The area being
restored will have temporary erosion control placed until the native
plantings are installed, which may include jute mat, straw, and/or seed.
Planting will be done during the next suitable season.
Exhibit C-3.
9. On February 11, 2022, while the emergency shoreline exemption amendment application
was being processed, Mr. Best provided the Appellant with a code analysis indicating
that the proposed bulkhead replacement project would not meet criteria for approval of an
emergency shoreline exemption. Mr. Best explained that a permanent solution would
undergo full due process review through the regular permitting process and that, in the
meantime, the City would support temporary protection measures that could include: the
placement of sandbags covering filter fabric or coconut matt on the face of the slope in
front of the boathouse and along the north flank of the boathouse in any location where
erosion reaches within 10 feet of the boathouse; the shoring/bracing of the north concrete
wing wall and temporary sandbagging if erosion continues landward of the wingwall.
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 8 of 30
The same day, Ms. Dennison and Professional Engineer Erik Anderson, of Aspect,
provided a response stating that, in their professional opinion:
• There is an imminent risk to the environment from the collapse of the boathouse
into the waterway.
• The collapsed concrete bulkhead is currently providing protection of toe erosion.
• Removing the concrete bulkhead and replacing it with sandbags, jute/coir matting,
fabric, or otherwise would not provide adequate protection to the boathouse for
any amount of time, and it would continue to be an imminent risk to the
environment.
Ms. Dennison provided an additional response on February 14, 2022, which stated that an
engineered sandbag revetment would not be feasible due to existing slopes on the
property. Exhibit A-5; Exhibits A-11 through A-13.
Decision Denying Emergency Shoreline Exemption Amendment
10. On March 14, 2022, City Interim Planning Director Mark Hofman issued a decision
denying the request for an emergency shoreline exemption amendment, which included
the following findings:
1) On October 19, 2021, the applicant attended a staff consultation meeting
with their contractor and engineering geologist to discuss replacement of
their concrete bulkhead which was at risk of failure. During that meeting,
the applicant was informed of applicable requirements and procedures,
including:
• The SMP's non-conforming rules do not apply to shoreline
stabilization. [SMP 4.2.1.1].
• Replacement shoreline stabilization would only be allowed if
determined to be necessary to protect the house or primary
appurtenances [SMP 6.1.3(1) and 6.1.5(2)] and the least impacting
alternative was selected based on the required alternatives analysis
[SMP 6.2.8(1)] and no net loss analysis [SMP 4.1.2.4].
• The SMP does not authorize shoreline stabilization to protect a
boathouse because it is not a "primary appurtenance." [SMP
6.1.3(1), 6.1.5(2), & 8.0].
• The SMP prohibits shoreline stabilization for the protection of
landfill. [SMP 6.2.4(3)].
2) The concrete bulkhead on the subject property was approximately 8-feet
tall and 140 linear feet long. The face of the bulkhead was the ordinary
high water mark. The bulkhead was retaining landfill approximately 8-
feet deep at the bulkhead which likely reduced in depth over a horizontal
distance of approximately 28-feet landward to the existing toe of slope. A
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 9 of 30
boathouse was built on the landfill located approximately 13-feet
landward of the bulkhead.
3) The concrete bulkhead is presumed to have been legally established prior
to the establishment of the Shoreline Management Act. The boathouse
was legally established in 2012 under City permit (BLD17525MIS) for
water-dependent use common to a boathouse but was observed on
November 30, 2021, being used instead as an illegal living space with
bunkbeds and other furnishings. The boathouse has power but does not
have plumbing or cooking facilities.
4) On November 28, 2021, the entire concrete bulkhead fronting the subject
property failed and fell face forward onto the beach, which is a
documented forage fish spawning beach.[1] The landfill immediately
began to erode placing the boathouse at risk, as well as potentially placing
at risk the end of the bulkhead that is located on the adjacent property to
the north.
5) On November 30, 2021, the City conducted a site visit and pre-application
meeting attended by the applicant with their contractor and engineering
geologist. During the site visit, all parties acknowledged the house and
primary appurtenances were not at risk. Subsequently, the geotechnical
report does not state that the house or primary appurtenances are at risk,
and the currently proposed design does not propose shoreline stabilization
to protect the house or primary appurtenances.
6) On December 1, 2021, an emergency shoreline substantial development
exemption (SSDE) was issued by the City, which authorized emergency
construction to temporarily stabilize the eroding soil in front of the
boathouse while a long-term solution could be developed and permitted.
The City acknowledged that future emergency SSDE amendments could
be considered if additional temporary stabilization was necessary.
7) On December 2, 2021, a pre-application letter was issued by the City,
which:
• Provided SMP requirements and guidance applicable to shoreline
stabilization.
• Clarified that replacing only 50 percent of the linear length of the failed
bulkhead does not qualify as “repair” per SMP 6.2.7(2).
1 Senior Planner Peter Best testified that characterization of the beach as a documented forage fish
spawning beach was inaccurate. Testimony of Mr. Best. This fact is immaterial to the outcome of the
current decision.
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 10 of 30
• Provided guidance on potential long-term options for the boathouse, which
included:
o Relocating the boathouse elsewhere on the property where it would
no longer be at risk.
o Modifying the boathouse by putting it on piles so that erosion
could occur underneath it without putting it at risk.
o Removing the boathouse from the property.
• Stated that additional temporary protection measures could be considered
if necessary to buy time for the design and permitting of a long-term
solution for the boathouse.
8) On February 4, 2022, the applicant submitted an application for an
amendment to the emergency SSDE proposing to install rock rip-rap
bulkheads, concrete steps, and stormwater diffuser.
• The proposed amendment was requested:
o 14 weeks after the initial staff consultation; and
o 8 weeks after the emergency SSDE was issued, the pre-
application meeting was held, and the pre-application letter
was issued.
• During the 8-week period the applicant:
o Completed project design for a rock rip-rap bulkhead;
o Completed a geotechnical report with an alternatives
analysis based on Washington State Department of Fish
and Wildlife (WDFW) requirements; and
o Coordinated closely with WDFW on a Hydraulic Project
Approval (HPA) for permanent rock rip-rap bulkheads,
which was issued on January 14, 2022.
• During the 8-week period the applicant could have, but did not,
simultaneously:
o Coordinate with the City regarding the proposed design and
applicable SMP requirements.
o Complete an alternatives analysis as required by the SMP
which is slightly different from WDFW alternatives
analysis requirements.
o Submit an application for the proposed project.
• The concrete steps and stormwater diffuser are not necessary to
abate the emergency.
9) On February 11, 2022, City staff:
• Provided applicable code analysis demonstrating the proposed
design was not consistent with the requirements for an emergency
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 11 of 30
exemption and clarifying why the proposed design would not
qualify as "repair" under SMP 6.2.7(2).
• Requested revisions to the amendment for a more temporary
solution.
10) Between February 11, 2022, and February 23, 2022, City staff and the
applicant corresponded by email and phone regarding the revision request.
• The City provided the applicant with US Army Corps of Engineers
guidance for "expedient coastal protection" in Alaska that included
engineering guidance for the use of temporary engineered sandbag
revetments which the City believes is applicable and scalable to the
subject property.
• Temporary engineered sandbag revetments were not considered in
the geotechnical report prepared for the HPA. Since the City's
revision request, WDFW has confirmed they would permit a
temporary engineered sandbag revetment at the subject property.
• The applicant's responses were not adequate to clearly rule out the
use of a temporary engineered sandbag revetment and did not
provide enough analysis to support third-party review.
• The applicant did not suggest or evaluate other temporary
approaches that would abate the emergency while final permitting
on a long-term solution was completed.
11) On March 7, 2022, City staff met with the applicant hoping to discuss
revisions to the emergency SSDE amendment and the process for
permitting a long-term solution.
• Attending the meeting were:
o City: Planning Director, Planning Manager, Public Works
Engineering Manager, Senior Planner, City Attorney
o Applicant: Owner, contractor, engineering geologist,
attorney
o WDFW Area Habitat Biologist
• The applicant requested a decision as soon as possible on the
emergency SSDE amendment application as submitted.
12) Per WAC 173-27-040(1)(a):
• Exemptions shall be construed narrowly. Only those
developments that meet the precise terms of one or more of the
listed exemptions may be granted exemption from the substantial
development permit process.
• The burden of proof that a development or use is exempt from the
permit process is on the applicant.
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 12 of 30
13) Staff analysis demonstrates that the current proposal does not meet the
requirements of WAC 173-27-040(2)(d).
The decision denying the request for an emergency shoreline exemption amendment
noted that the City would be willing to consider:
• New emergency SSDE amendment applications for temporary protection
measures that would be consistent with applicable requirements while a
long-term solution is permitted; and
• An expedited review of an application proposing a long-term solution.
Exhibit A-1; Exhibit C-1.
Appeal, Subsequent Materials, and Motions
11. On March 25, 2022, Attorney Piper Thornburgh, on behalf of the Appellant, filed an
appeal of the City’s decision denying the emergency shoreline exemption amendment.
The appeal asserts that substantial evidence does not support the Director’s findings 1, 3
through 10, and 13 and contends:
• The parties do not dispute that there is an emergency as a matter of fact and law
within the meaning of the City SMP, and the Appellant’s proposed emergency
construction is consistent with policies of the SMA and the City SMP.
• The issue of whether the proposed emergency construction would constitute a
repair under the City SMP is not pertinent to the determination of whether the
construction should be authorized under an emergency shoreline exemption.
Rather, this is an issue to be addressed by the City during its review of the after-
the-fact permit that the Appellant would apply for after the emergency is abated.
Denying the emergency shoreline exemption amendment on this basis constitutes
a denial of due process.
• When it is determined that an emergency exists, the City’s authority in
considering an emergency shoreline exemption to allow measures to abate the
emergency is ministerial, rather than discretionary.
• The City circumvented the abbreviated, ministerial emergency exception process
and predetermined a future permit for which no application has been submitted.
This is clearly outside the City’s authority and defeats the entire purpose and
intent of the allowance of exemptions to SSDP permit requirements to provide an
immediate course for protecting property, health, and safety in the event of an
emergency.
• A permit for the rock bulkhead, recommended by Aspect, would be sought after
the emergency has been abated. The objections that the City raises in its code
analysis can be fully examined at a future hearing. To deny the emergency permit
on the basis of other standards besides the emergency process puts the Appellant
in jeopardy given the danger of the boathouse collapsing into Manzanita Bay.
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 13 of 30
• The City has withheld its approval despite determinations by the Appellant’s
geologist and engineer that an untested idea of a sandbag revetment, which has
not been considered by the State, is not workable and that hard stabilization is
necessary. The City merely disagrees with this expert opinion but offers no
expert of licensed professional opinion of its own. Although the City has
proposed to contract for third-party review, it has not followed through on that
proposal and, instead, rejected the Appellant’s engineer’s analysis based on the
City Planner’s belief and based on the application of City SMP standards that do
not apply until the emergency is abated and an after-the-fact permit is sought.
• The Appellant would bear the risk of having to remove the proposed shoreline
stabilization measures after the emergency is abated if an after-the-fact permit is
not approved.
• The decision denying the emergency shoreline exemption should be reversed
because it is not supported by substantial evidence, is based on error of law, is an
erroneous application of the facts to the law, is arbitrary and capricious, is outside
the authority of the City, and constitutes a denial of the Appellant’s constitutional
rights.
Appeal, dated March 25, 2022.
12. On May 6, 2022, the Hearing Examiner issued a pre-hearing order that set an open record
appeal hearing date for June 7, 2022, and that provided instructions and deadlines for the
filing of dispositive motions and the submission of witness lists and documentary
evidence. Pre-Hearing Order, dated May 6, 2022.
13. Consistent with the pre-hearing order, the Appellant filed a dispositive motion requesting
that the Hearing Examiner summarily grant the appeal as a matter of law, asserting:
• If an applicant establishes that there is an emergency, the City’s authority in
considering an application for an emergency shoreline exemption under WAC
173-27-040(2)(d) is merely ministerial and not discretionary. Because it is
undisputed that an emergency exists, the City lacked discretion to deny the
Appellant’s request for an emergency shoreline exemption amendment.
• The City does not have authority to deny an emergency shoreline exemption
based on the belief that a project would not meet after-the-fact permit standards.
Under WAC 173-27-040(2)(d), these after-the-fact permitting standards cannot
constitute a legal basis for the denial of temporary protective measures necessary
to abate an emergency. The City bears no risk associated with approving a
structure that cannot meet the more rigorous review associated with an SSDP.
The Appellant, however, could be required to remove the structure if an SSDP
application is denied.
• The City arbitrarily rejected the only expert-recommend shoreline stabilization
solution. The City’s denial of the emergency shoreline exemption amendment
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 14 of 30
was therefore arbitrary and capricious and consisted a violation of procedural and
substantive due process.
• Because an emergency shoreline stabilization project is considered and approved
on an immediate, urgent basis, there is not time for a municipality to contract for
or seek out third-party review. The City’s only questions to be answered at this
time are whether there is an emergency and, if so, whether the proposed fix would
address the immediate situation. This is a ministerial review process, without
required notice or opportunity to comment or a hearing. Any third-party review
could occur at the later after-the-fact permitting stage.
Appellant’s Dispositive Motion, dated May 17, 2022.
14. The City submitted a response to the Appellant’s dispositive motion, asserting:
• The rules governing the open record appeal hearing do not contemplate a
summary determination on the merits by motion, and the City has the right to
present evidence and testimony at the hearing, which would become part of the
record for deciding the appeal.
• The dispute over whether the proposed emergency shoreline stabilization
measures would be “appropriate” under WAC 173-27-040(2)(d) forms a central
question in this appeal. The City is currently working with a third-party
consultant to provide an opinion and testimony at the hearing concerning, among
other things, the appropriateness of the proposed bulkhead. Therefore, the City
has not finalized the evidence it will present at the hearing and cannot respond to
the Appellant’s dispositive motion with that evidence.
• The Appellant asserts that several “undisputed facts” support its dispositive
motion, but the City disagrees with many of these assertions.
• Contrary to the assertions in the Appellant’s dispositive motion, the City’s review
process for emergency shoreline exemption requests is not purely ministerial, and
WAC 173-27-040(2)(d) provides the City with discretion to determine whether
proposed protective structure would be “the appropriate means to address the
emergency situation.”
• Under 173-27-040(1)(b), the City must consider policies and provisions of the
SMA and the City SMP when deciding a request for an emergency shoreline
exemption. Although the emergency process allows an applicant to construct a
protective structure without going through the ordinary permitting process, it does
not allow an applicant to construct a structure that would otherwise fail to meet
applicable standards.
• The City did not arbitrarily reject the proposal. The proposal includes new
construction where none previously existed, disqualifying it from emergency
shoreline exemption, and also fails under applicable SMA and City SMP policies,
guidelines, and regulations. The City asked the Appellant to consider alternative
emergency measures, but the Appellant chose to not rule out other possible
alternatives and, instead, requested a decision on their submitted emergency
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 15 of 30
application. Although the Appellant characterizes the City’s denial of the
application as being based on a personal agenda, the City based its decision on the
submitted application, as requested by Appellant. The Appellant had the burden
of proof, and they failed to rule out other alternatives sufficient to demonstrate
their proposal was the appropriate means for addressing the emergency.
City’s Response to Appellant’s Dispositive Motion, dated May 24, 2022.
15. On May 31, 2022, Engineering Geologist Jim Johannessen of Costal Geologic Services,
Inc., completed his third-party review of the proposal at the City’s request. The third-
party review report determined that additional bank erosion had been minimal since the
geotextile fabric was installed in accordance with the previously approved emergency
shoreline exemption and that the proposed rockery wall appears to involve significantly
more structure and footprint than would be required for temporary protection of the
boathouse structure. The report recommended emergency protective measures that
would include placing a larger cross-share width of geotextile that would be covered with
a temporary geo-bag revetment and leaving the toppled concrete wall in place during this
temporary emergency measure to protect the toe of the slope during the pendency of
shoreline permit review. Exhibit C-8.
16. On June 3, 2022, the Appellant filed motions in limine and a request that the Hearing
Examiner conduct a site visit prior to or shortly after the scheduled open record appeal
hearing. The motions in limine requested that the Hearing Examiner exclude the City’s
third-party review report, discussed above, and any testimony related to the report, as
well as any testimony or argument concerning bulkhead repair versus bulkhead
replacement. On June 6, 2022, the City filed a response opposing the Appellant’s
motions in limine, which asserted that the motions are inconsistent with the open record
appeal hearing process, that evidence concerning the third-party review of the proposal is
highly relevant to whether the proposed rock bulkhead would be an appropriate
emergency measure, and that testimony regarding repair versus replacement is relevant to
the issue of whether the proposed rock bulkhead would be consistent with City SMP
policies. Appellant’s Motion in Limine and Request for a Site Visit, dated June 3, 2022;
City’s Response to Appellant’s Motion in Limine and Request for a Site Visit, dated June
6, 2022.
17. On June 6, 2022, the Hearing Examiner issued a decision on the Appellant’s pre-hearing
motions, which determined:
Given the limited timeframe in which to consider the Appellants’ motions
and the City’s responses, the Hearing Examiner has determined that it
would be appropriate to hear oral argument on the motions at the outset of
the appeal hearing on June 7, 2022. The Hearing Examiner will then
make any applicable oral rulings on the various motions prior to
commencement of the Appellants’ case-in-chief related to the appeal.
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 16 of 30
. . .
[T]he Hearing Examiner notes that he is currently under quarantine,
having tested positive for COVID-19 recently. Accordingly, a site visit
would not be safe at this time. At the conclusion of the hearing, however,
the Appellants may renew the request for a site visit and the parties can
discuss whether such visit is necessary or appropriate for the Hearing
Examiner’s ultimate determination of the motions and/or appeal.
Decision on Appellant’s Pre-Hearing Motions, dated June 6, 2022.
Pre-Hearing Brief
18. The City submitted a pre-hearing brief, dated May 31, 2022, arguing:
• The Appellant bears the burden of proving that the proposed amendment qualifies
for an emergency shoreline exemption and that the Director’s decision denying
the amendment was clearly erroneous. As will be addressed in the hearing
testimony presented by the City, the Appellant cannot meet this standard, and the
appeal must be denied.
• The Director’s denial of the requested amendment was correct because the
proposed rock bulkhead does not qualify for an emergency shoreline exemption
under WAC 173-27-040(2)(b). Specifically, the proposal does not meet the
requirements of WAC 173-27-040(2)(b) because it includes new protective
structures where none currently exist, it would not be the appropriate means to
address the emergency situation, and it would not be consistent with the policies
of the SMA and City SMP.
City’s Prehearing Brief, dated May 31, 2022.
Testimony2
19. At the outset of the hearing, the Hearing Examiner addressed the Appellant’s unresolved
pre-hearing motions. Following argument by the parties, and as detailed further in the
conclusions below, the Hearing Examiner ultimately denied the Appellant’s motion to
summarily grant the appeal, reasoning that the City’s decision to grant or deny a request
for a shoreline exemption is not ministerial in nature and, contrary to the Appellant’s
arguments, requires discretionary review of the proposal by the City. The Hearing
Examiner also denied the Appellant’s motions in limine, reasoning that an appeal of this
type involves an open record hearing and, accordingly, it would be inappropriate to
preclude submitted evidence (by either party) that may have probative value in
2 As noted above, the hearing on this matter occurred over the course of three days. For scheduling
reasons, the testimony of some witnesses was taken out-of-order. As these details do not impact the result,
they are not fleshed out in the current decision. Moreover, the Hearing Examiner has only briefly
summarized the testimony and, further, focused the testimony findings on those matters impacting the
outcome of the appeal. The Hearing Examiner acknowledges, however, that such summary does not reflect
all the information conveyed by the parties’ witnesses and should not be considered a verbatim transcript of
the testimony.
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 17 of 30
determining whether the City erred in denying the emergency exemption request. The
Hearing Examiner acknowledged that the City’s third-party review report, in particular,
was not available and/or relied on by the Director when he issued his denial but
determined that review and analysis of such a report (and testimony from the applicable
witnesses) would assist the Examiner in determining whether the City erred in issuing its
denial. In addition, the Hearing Examiner ruled that it would be inappropriate to exclude
all testimony related to “repair” versus “replacement” in the context of the Appellant’s
proposal because analysis of this issue is contemplated by the controlling regulation,
WAC 173-27-040, and may be highly fact specific. Oral Rulings of the Hearing
Examiner.
Appellant Witness
20. Principal Geotechnical Engineer Erik Andersen, of Aspect Consulting, LLC, testified on
behalf of the Appellant and explained that he worked in concert with others (including
staff from Sealevel Bulkhead Builders, Inc.) on the design and configuration of the
proposal. Mr. Andersen stressed that, in his professional opinion, the proposal would
appropriately address the emergency situation present on the property. He noted that, in
his experience, third party review is not uncommon when reviewing a bulkhead proposal
like this one, but such review would normally occur during the regular permitting process
(as opposed to during review of an emergency exemption). Mr. Andersen also explained
that, typically, third party review addresses whether code criteria and regulatory
requirements have been satisfied and that he has not previously seen third party review
where a detailed alternative solution/proposal is provided. That said, Mr. Andersen
reviewed the City’s third-party review evaluation from Coastal Geologic Services, Inc.
(Exhibit C-8) and determined that, while the suggested alternative of using soft bank
stabilization measures would provide temporary relief from the current emergency, a
permanent solution would still be necessary within a year or so. On cross-examination,
Mr. Andersen further acknowledged that the alternative suggestion proposed by Coastal
Geologic Services would be reasonable as a temporary measure. On re-direct, however,
Mr. Andersen stressed that installation of a permanent solution is preferred in such
circumstances to minimize construction impacts. Testimony of Mr. Andersen.
21. Property owner and Appellant Paul Jones testified about the history of the property and
his experiences with the failing bulkhead. He noted that he was left with a positive
impression of the proposal following the preapplication meeting with City staff, prior to
the complete failure of the bulkhead. After the failure, he believed that temporary
protection measures would be approved on a very short-term basis until final approval of
the suggested proposal occurred. Mr. Jones testified about his interactions with Nam Sui,
from WDFW, and his understanding that WDFW did not want the existing, failed
bulkhead to remain in place as part of any emergency measures. Mr. Jones noted that he
offered to pay for third-party review of the Appellant’s proposal to expedite the process
but that the City did not accept that offer. Finally, Mr. Jones emphasized that this has
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 18 of 30
been a stressful ordeal, particularly because he has felt that the City’s position about the
bulkhead proposal has changed over time. Testimony of Mr. Jones.
22. Project Manager Ryan Lewis, of Sealevel Bulkhead Builders, Inc. (Sealevel), testified
about his involvement with the proposal and efforts to obtain approval for the
repair/replacement bulkhead. He noted that, in the past, the City approved several similar
bulkhead repair/replacement projects to the one the Appellant has proposed, so long as
the bulkhead “replacement” did not involve significant alterations to more than 50
percent of the linear footage of the original bulkhead structure. Mr. Lewis stated that, in
discussing the project initially with City staff—prior to the complete failure of the
bulkhead—he was left with the impression that the proposal would receive permit
approval. He noted that, after this, the City’s position appeared to change. Mr. Lewis
also discussed working with WDFW to obtain approval for temporary/emergency
measures and that WDFW stressed the importance of avoiding detrimental impacts to
area fish, in particular. Mr. Lewis also testified about the logistics of
installing/constructing a project like this and explained that it requires significant
coordination because of limited allowable work windows and the need to use very heavy
equipment and a barge. Because of this, he had begun the process of scheduling work on
the proposal in advance of obtaining a decision on the emergency exemption request
from the City. On cross-examination, Mr. Lewis acknowledged that he did not receive
verbal approval from City staff at any point during the process. Testimony of Mr. Lewis.
23. Jennifer Rotsten, of Sealevel, testified about her experience with bulkhead construction
projects, including experience with similar proposals on Bainbridge Island in the recent
past, and her involvement with the current proposal. Ms. Rotsten testified that, similar to
the impressions of Paul Jones and Ryan Lewis, she left the preapplication meeting with
the firm belief that the City would approve the bulkhead repair/replacement proposal and
that additional communications thereafter did not raise any “red flags” in her mind. She
stated that, in reviewing the City’s denial decision from March 14, 2022, it appeared that
many of the issues of concern were not earlier addressed or conveyed to the Appellant
during the project review process because, otherwise, additional redesign or project
assessment would likely have occurred. Ms. Rotsten discussed steps that Sealevel took to
obtain an emergency Hydraulic Project Approval (HPA) from WDFW after failure of the
existing bulkhead in November 2021, and explained that the initial emergency exemption
measures the Appellant sought approval of from the City were meant to be temporary
(i.e., only as a short-term fix for a few weeks) to abate the emergency. She also
explained that the Appellant did not seek approval of an additional emergency exemption
from the City concurrently with seeking approval from WDFW for an emergency HPA
because this is not a regulatory requirement, and that the Appellant was later surprised by
the City’s position. In terms of addressing emergency situations under WAC 173-27-
040, Ms. Rotsten conveyed her belief that, once an emergency is acknowledged and an
applicant’s engineer proposes a solution that would abate such emergency, approval
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 19 of 30
should be granted. She also noted that, based on her experience, it seems unlikely that
WDFW would approve the use of non-biodegradable sandbags as an emergency solution
to the situation or in conjunction with an emergency HPA. Ms. Rotsten also testified
about her past experiences with third-party review and that the nature of such review in
these circumstances was unusual. She also stressed that a single solution is preferable
from a construction standpoint. On cross-examination, Ms. Rotsten acknowledged that
the only basis to deny an emergency HPA is because a project would have detrimental
impacts on aquatic wildlife and that WDFW does not review compliance with a
jurisdiction’s Shoreline Master Program (SMP) when assessing an emergency HPA. She
also noted that she did not recall the details of Mr. Best’s December 2021 email and the
concerns therein about the rock bulkhead proposal. On re-direct, Mr. Rotsten stressed her
belief that the City’s view of the proposal changed after the existing bulkhead failed but,
despite this, the Appellant’s team believed approval of the proposal would still be
possible. Testimony of Ms. Rotsten.
24. Senior Engineering Geologist Alison Dennison, of Aspect Consulting, testified on behalf
of the Appellant and explained her involvement with the current proposal. She reiterated
the view expressed by the other Appellant witnesses that the City seemed amenable to the
proposal prior to the existing bulkhead collapsing and that the City’s position seemed to
later change. Ms. Dennison testified that, in her view, the existing bulkhead has not
entirely (or 100 percent) failed such that any requirements related to repair versus
replacement could still be satisfied. On cross-examination, Ms. Dennison acknowledged
that the emergency situation has not put the Jones’ residence in danger but stated that she
still believes the Appellant’s solution is allowable and appropriate as a repair of the
existing bulkhead. Testimony of Ms. Dennison.
City Witnesses
25. Coastal Geologist Jim Johannessen, of Coastal Geologic Services, Inc., testified on behalf
of the City and explained the analysis he performed in producing the third-party
evaluation of the Appellant’s project (Exhibit C-8). He noted that he limited his
evaluation to the scope suggested by the City, which included assessing the need for
installation of a rock retaining wall to address the emergency situation (as proposed by
the Appellant) and the potential for alternative, temporary measures to address the
emergency during the pendency of permit review for a long-term and permanent solution.
Mr. Johannessen discussed scientific aspects of coastal processes and wave energy and
his determination that, given the current situation, feasible emergency measures falling
fall short of installation of a new rock bulkhead would be possible. He then discussed the
suggested emergency solution proposed by his colleague at Coastal Geologic Services,
Dr. Wei Chen, and his belief that such solution—involving the installation of additional
geotextile fabric and use of non-biodegradable sandbags—would serve to abate any
emergency during the pendency of permit review for a permanent solution. Mr.
Johannessen also emphasized that, in his experience, “temporary” protection measures
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 20 of 30
often become permanent solutions so it is important to limit emergency measures, where
possible, if the proposed measures would not satisfy regulatory requirements. On cross-
examination, Mr. Johannessen elaborated further on the limited scope of his analysis
based on information provided by the City (i.e., he did not address potential impacts to
neighboring properties) and acknowledged that the alternative emergency solution
proposed by Coastal Geologic Services requires keeping the toppled/failed bulkhead in
place. He also noted that, in his view, the temporary solution proposed would likely only
abate the emergency conditions for a year or two. In response to additional questioning,
Mr. Johannessen stated that he concurs with the proposition that the Appellant’s proposal
would abate the emergency situation and, also, that a single construction/installation
project may have fewer ecological impacts than could occur with installation of further
temporary measures then, later, construction/installation of a final project. He stressed,
however, that it is important to consider the long-term impacts of any “final” project
proposed. Finally, on re-direct, Mr. Johannessen stated that he believed two years would
be a sufficient amount of time, in his experience, for an applicant to obtain necessary
shoreline permits for a permanent solution to a situation like this one. Testimony of Mr.
Johannessen.
26. Senior Coastal Engineer Wei Chen, of Coastal Geologic Services, Inc., testified about the
alternative, temporary solution to the emergency situation on the Jones’ property that he
suggested as part of third-party review. Dr. Chen noted that the use of sandbags is a
common solution in emergency situations and that this is often the approach the U.S.
Army Corps of Engineers (USACE) employs. Dr. Chen noted that, from an engineering
perspective, long-term solutions are preferable, but each situation is circumstance specific
and that, here, the Appellant is requesting approval for an emergency exemption from
normal shoreline permit processes. Accordingly, in his view, a temporary solution—
defined in his experience, including his understanding of professional norms, as one that
would adequately address an emergency situation for at least a year—is appropriate if a
solution is not readily available that would satisfy both short-term and long-term needs.
Dr. Chen stressed that, here, the Appellant’s solution of installing a replacement rock
bulkhead would not satisfy regulatory requirements when reviewed in the long-term and,
accordingly, it would be inappropriate as a short-term emergency fix. On cross-
examination, Dr. Chen explained that his proposed temporary solution is conceptual at
this point and that, because of this, he did not “stamp” Mr. Johannessen’s report. Finally,
on re-direct, Dr. Chen again noted that it is important to consider additional permitting
and other regulatory requirements, along with environmental impacts, when proposing
engineering solutions in situations like the one that currently exists on the Jones’
property. Testimony of Dr. Chen.
27. City Senior Planner Peter Best testified about his involvement with the project, including
his preparation of the “code analysis” that served as the foundation for the Director’s later
decision denying the emergency exemption. Mr. Best stressed that, in the early stages of
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 21 of 30
the review—including with the preapplication meeting—the City did not suggest or
intend to suggest that approval of a repair or replacement rock bulkhead would be
approved. He also explained that, whether the Appellant’s proposal would have been
possible as a “repair” under the City’s SMP and other regulatory requirements prior to the
complete failure of the existing bulkhead is immaterial but, regardless, a boathouse is not
the type of primary appurtenance that warrants the types of repair/replacement the
Appellant has suggested. Mr. Best explained that, in the code interpretation, he sought to
provide guidance to the Appellant and was not dictating or requiring any particular
solution to the emergency situation. The point, instead, was to stress that any emergency
measures would still need to comply with the City’s SMP and that the Appellant’s
proposed solution would not. Mr. Best noted that, in his view, he never conveyed to the
Appellant and their consultants that any particular proposal or solution would be
approved in advance of further City review—either before or after the existing bulkhead
failed. Mr. Best also explained that the “alternatives analysis” required by WDFW for
approval of an emergency HPA is different than what the City determined would be
required for approval of an emergency shoreline exemption under WAC 173-27-040.
Mr. Best stressed that the emergency exemption process does not exempt an applicant
from the need to comply with substantive regulations of the Shoreline Management Act
or a jurisdiction’s SMP but, instead, exempts someone from the need to comply with the
procedural requirements necessary to obtain a Shoreline Substantial Development Permit
(SSDP), in advance of construction/installation, in an emergency situation. To that end,
Mr. Best reiterated his belief that installation of a new/replacement rock bulkhead would
not be necessary to abate the emergency on the property and that the Appellant’s proposal
to that effect would not be consistent with requirements of the City’s SMP. Mr. Best also
discussed third-party review and explained that the City did not have such a review
performed in advance of the denial because it was waiting on additional information from
the Appellant, including the requested alternatives analysis. Mr. Best stressed that he is
confident that the SSDP process for a permanent solution to the issues on the property
could be accomplished within a year.
On cross-examination, Mr. Best acknowledged that the City’s SMP can be a challenging
document to work with but, despite this, stressed his belief that WAC 173-27-040 is clear
in terms of when an emergency exemption is appropriate. Mr. Best testified that,
recently, the Jones proposal for an emergency exemption is the only matter that was
denied. He also acknowledged that he is aware that WDFW would, contrary to the
emergency solution proposed by Coastal Geologic Services, like to have the failed
concrete bulkhead removed even during the pendency of the emergency situation. On re-
direct, Mr. Best stressed that the SMP does not distinguish between temporary and
permanent situations and that, in his view, WAC 173-27-040 clearly envisions that
emergency measures must still comply with SMP requirements. Testimony of Mr. Best.
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 22 of 30
28. City Engineering Manager Paul Nylund testified about his involvement with the proposal
and review of the Appellant’s various submittals. He stressed that he did not leave the
preapplication meeting with any particular impression—either positive or negative—
about the initial proposal prior to the failure of the existing bulkhead. He noted that, in
his experience, third-party review of emergency proposals is not common and, here, he
did not determine that third-party review of the Appellant’s proposal was necessary from
an engineering standpoint. On cross-examination, Mr. Nylund stated that he believes the
City’s position about this proposal (and other bulkhead proposals) has remained fairly
consistent and stressed that, for emergency situations, there is no requirement that a
proposal involve a temporary solution, but concurred with the position of other city staff
that any proposal must still adhere to regulatory requirements of the City SMP.
Testimony of Mr. Nylund.
Closing Briefs
29. The Hearing Examiner left the record open until July 8, 2022, to allow the parties to
submit closing briefs. Oral Ruling of the Hearing Examiner.
30. The Appellant submitted a closing brief, which asserts:
• The City has argued that WAC 173-27-040(2)(d) contemplates emergency
construction to be “temporary” and limited to “the minimum necessary” to abate
the emergency. The City, however, is not entitled to read in new terms that do not
appear in the plain language of the WAC. The City’s interpretation of the WAC
in include these requirements is an error of law that led to an unfair outcome and
denial of due process for the Appellant.
• There is nothing in WAC 173-27-040(2)(d) that provides the City with discretion
to deny an emergency application when the provisions of the process are met and
when the application is supported by a stamped engineering report. The City has
held the Appellant’s application for approval of an emergency fix to the wrong
standards, which is clearly erroneous. The reference in WAC 173-27-040(2)(b) to
consistency with policies of the SMA and SMP does not provide a green light to
the City to bootstrap in all standards tat are reserved for full review after the
emergency is abated.
• The project meets all requirements for emergency shoreline exemption approval
under WAC 173-27-040(2)(d). The Appellant does not propose a new permanent
structure where none previously existed. The City’s interpretation of DOE’s
regulation to require that a repair needs to be in the precise location of the former
bulkhead in order to comply with the SMP leads to absurd results because it
would mandate denial of any new structure placed further landward from the
location of the original protective structure.
• The City improperly subjected the project to full SSDP review. A full review of
the proposed structure in an after-the-fact permitting review is not ripe. To the
extent that the Hearing Examiner determines that any future standards for an
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 23 of 30
after-the-fact permit may be considered, the Appellant should only have to
establish potential application approval, which would be analogous to a prima
facie showing. The Appellant has made a prima facie showing that the project
would fall under the definition of repair.
Appellant’s Closing Brief, dated July 8, 2022.
31. The City submitted a closing brief in which it argues:
• The Director’s decision denying the application is entitled to substantial weight,
and the Appellant has not met the burden of proving that the decision was clearly
erroneous.
• The evidence demonstrates that the proposed rock bulkhead is not consistent with
the policies of the City SMP. The City SMP allows for structural stabilization
modifications and for the replacement of hard shoreline stabilization structures
only when necessary to protect primary structures and primary appurtenances.
Boathouses and yards are not primary structures or primary appurtenances as
those terms are used in SMP Sections 6.1.3(1) and 6.2.3(5).
• The Appellant’s witnesses admitted that the proposed rock bulkhead was intended
to be permanent and that new protective structures were proposed where none
previously existed.
• The Appellant failed to prove that the proposed rock bulkhead was the appropriate
means of addressing the emergency.
• The substantial evidence test is not applicable in this appeal but is nevertheless
met by the evidence presented at the hearing.
• The arbitrary and capricious standard of review does not apply in this appeal.
Nevertheless, the Director’s decision denying the emergency shoreline exemption
amendment was not arbitrary and capricious.
• The Hearing Examiner lacks jurisdiction to address the Appellant’s constitutional
claims.
City’s Post-Hearing Brief and Closing Argument, dated July 8, 2022.
CONCLUSIONS
Jurisdiction and Criteria
The Hearing Examiner has jurisdiction to hear and decide appeals from an administrative
decision by the City Director of Planning and Community Development, or his or her designee,
to grant, deny, or conditionally approve a shoreline substantial development exemption. BIMC
Table 2.16.010-1; BIMC 2.16.165.E.
WAC 173-27-040 addresses exemptions from the requirement for a shoreline substantial
development permit and provides in relevant part:
(1) Application and interpretation of exemptions.
(a) Exemptions shall be construed narrowly. Only those
developments that meet the precise terms of one or more of the
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 24 of 30
listed exemptions may be granted exemption from the substantial
development permit process.
(b) An exemption from the substantial development permit process is
not an exemption from compliance with the [Shoreline
Management Act] or the local master program, nor from any other
regulatory requirements. To be authorized, all uses and
developments must be consistent with the policies and provisions
of the applicable master program and the Shoreline Management
Act. A development or use that is listed as a conditional use
pursuant to the local master program or is an unlisted use, must
obtain a conditional use permit even though the development or
use does not require a substantial development permit. When a
development or use is proposed that does not comply with the
bulk, dimensional and performance standards of the master
program, such development or use can only be authorized by
approval of a variance.
(c) The burden of proof that a development or use is exempt from the
permit process is on the applicant.
(d) If any part of a proposed development is not eligible for
exemption, then a substantial development permit is required for
the entire proposed development project.
. . .
(2) The following developments shall not require substantial development
permits:
. . .
(d) Emergency construction necessary to protect property from
damage by the elements. An “emergency” is an unanticipated and
imminent threat to public health, safety, or the environment which
requires immediate action within a time too short to allow full
compliance with this chapter. Emergency construction does not
include development of new permanent protective structures where
none previously existed. Where new protective structures are
deemed by the administrator to be the appropriate means to address
the emergency situation, upon abatement of the emergency
situation the new structure shall be removed or any permit which
would have been required, absent an emergency, pursuant to
chapter 90.58 RCW, these regulations, or the local master
program, obtained. All emergency construction shall be consistent
with the policies of chapter 90.58 RCW and the local master
program. As a general matter, flooding or other seasonal events
that can be anticipated and may occur but that are not imminent are
not an emergency. . . .
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 25 of 30
Consistent with these requirements, BIMC 2.16.165.E.3.a provides the following criteria for a
director’s decision on a request for an emergency shoreline exemption:
Exemptions shall be narrowly construed. When making the determination, the
administrator[3] shall grant a statement of exemption only when the development
proposed is consistent with the following:
i. The applicable policies, guidelines, and regulations of the Shoreline
Management Act of 1971; Chapter 90.58 RCW, as amended; and Chapters
173-26 and 173-27 WAC or their successors;
ii. The goals, policies, objectives and regulations of the city of Bainbridge
island shoreline master program;
iii. The city of Bainbridge Island comprehensive plan and municipal code; all
other applicable law; and any related documents and approvals.
BIMC 2.16.020.R.1 provides the procedure for appealing an administrative review decision,
stating in relevant part:
a. Applicability. All administrative decisions, departmental rulings and
interpretations made in accordance with administrative review procedures of
BIMC 2.16.030 . . . may be appealed to a hearing examiner.
. . .
i. Appeal Hearing. . . . The appeal shall be held at an open record public hearing.
Participation in an appeal hearing is limited to the applicant, the applicant’s
representative, the appellant, the appellant’s representative, appropriate city staff
and consultants, any witnesses called by each and any nonparty who submitted
written comments during the public comment period if the hearing examiner
determines that the testimony will be relevant to the issue on appeal and
nonrepetitive of the testimony of other witnesses.
. . .
ii. In an appeal of a substantive decision made by the city, the criteria shall
be whether (A) the proceedings were materially affected by failure to comply with
adopted procedures, or (B) the decision is inconsistent with the BIMC criteria for
that type of approval, or (C) the evidence in the record was not adequate to
support the decision.
. . .
k. Decision. Upon completion of the appeal hearing, the hearing examiner
shall (i) affirm the decision, (ii) reverse the decision, (iii) affirm the
decision with conditions, or (iv) remand the decision to the department
director for further consideration of identified issues. The decision of the
3 BIMC 2.16.165.B.1 provides that the “administrator” is “[t]he city of Bainbridge Island director of
planning and community development or his/her designee.”
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 26 of 30
director shall be accorded substantial weight by the hearing examiner.
The hearing examiner may include conditions as part of a decision
granting or granting with conditions an appeal to ensure conformance with
BIMC, the city’s comprehensive plan and other applicable laws or
regulations.
Finally, the Hearing Examiner’s decision shall be final unless, within 21 days after issuance of
the decision, a person with standing appeals it in accordance with Chapter 36.70C RCW or its
successor. BIMC 2.16.020.R.2.
Conclusions Based on Findings
The Appellant has not met its burden of showing that the City erred in denying the request
for an emergency shoreline exemption. The Appellant’s principal argument in this appeal is
that the City failed to adhere to the specific process for emergency shoreline exemption review
under WAC 173-27-040(2)(d) by analyzing, and ultimately denying, the Appellant’s requested
emergency shoreline exemption based on City SMP standards and policies that are contemplated
to be reviewed only as part of a later request for a shoreline substantial development permit
(SSDP) upon abatement of the emergency. In this regard, the Appellant contends that, once an
emergency requiring immediate action has been established (i.e., acknowledged by both parties),
the City lacks discretion to deny proposed measures designed to address the emergency that are
proposed by a qualified engineering professional even if those measures would fail to meet the
regulatory requirements for SSDP approval under the City SMP. The Hearing Examiner
disagrees with this contention—as he did when addressing the Appellant’s motion to summarily
grant the appeal on this basis at the open record appeal hearing—because the Appellant’s
argument does not comport with the plain language of WAC 173-27-040(2)(d).
The rules of statutory interpretation apply to the interpretation of regulations under the
Washington Administrative Code. Silverstreak v. State Dep’t of Labor, 159 Wn.2d 868, 154
P.3d 891, 898 (2007); Cannon v. Dep’t of Licensing, 147 Wn.2d 41, 56, 50 P.3d 627 (2002).
When interpreting a statute, the court’s fundamental objective is to ascertain and
give effect to the legislature’s intent. We begin with the plain meaning of the
statute. In doing so, we consider the text of the provision in question, the context
of the statute in which the provision is found, related provisions, amendments to
the provision, and the statutory scheme as a whole. If the meaning of the statute
is plain on its face, then we must give effect to that meaning as an expression of
legislative intent. If, after this inquiry, the statute remains ambiguous or unclear,
it is appropriate to resort to aids of construction and legislative history.
Lenander v. Dep’t of Ret. Sys., 186 Wn.2d 393, 405, 377 P.3d 199 (2016).
WAC 173-27-040(1) contains provisions related to the interpretation and application of all
shoreline exemptions listed under WAC 173-27-040(2). These provisions clearly and
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 27 of 30
unambiguously establish the following: (1) the burden is on the applicant to prove that a
proposed development is exempt from the shoreline substantial development permit process; (2)
shoreline exemptions are to be construed narrowly, such that “[o]nly those developments that
meet the precise terms of one or more of the listed exemptions may be granted exemption” from
the SSDP process; (3) to be authorized for a shoreline exemption, a proposed developments must
be consistent with the policies and provisions of the applicable SMP and the SMA; and (4) if
“any part of a proposed development is not eligible for exemption, then a substantial
development permit is required for the entire proposed development project.” WAC 173-27-
040(1)(a)-(d) (emphasis added). Accordingly, to obtain the requested shoreline exemption, the
Appellant was required to prove that the entirety of the proposed emergency proposal and its
component measures would meet the precise terms for emergency construction under WAC 173-
27-040(2)(d) and that the proposed emergency measures would be consistent with the policies
and provisions of the SMA and the City SMP.
WAC 173-27-040(2)(d) provides in relevant part:
An “emergency” is an unanticipated and imminent threat to public health, safety,
or the environment which requires immediate action within a time too short to
allow full compliance with this chapter. Emergency construction does not include
development of new permanent protective structures where none previously
existed. Where new protective structures are deemed by the administrator to be
the appropriate means to address the emergency situation, upon abatement of the
emergency situation the new structure shall be removed or any permit which
would have been required, absent an emergency, pursuant to chapter 90.58 RCW,
these regulations, or the local master program, obtained. All emergency
construction shall be consistent with the policies of chapter 90.58 RCW and the
local master program.
Although the Hearing Examiner agrees with the Appellant’s contention that the emergency
construction provisions of WAC 173-27-040(2)(d) are designed to bypass the typical permit
requirements for an SSDP in order to address an “unanticipated and imminent threat to public
health, safety, or the environment which requires immediate action,” the Hearing Examiner
disagrees that these emergency provisions thereby divest the City of any regulatory authority to
deny emergency construction proposals on the basis that such proposals would be contrary to
regulatory requirements and substantive provisions of the City SMP. The City’s retention of
such authority is made clear both under the general provisions of WAC 173-27-040(1) requiring
that all proposed developments comply with local shoreline master programs and under specific
language in WAC 173-27-040(2)(d) requiring that “[a]ll emergency construction shall be
consistent with the policies of . . . the local master program.”
Moreover, WAC 173-27-040(2)(d) contains additional language that, contrary to the Appellant’s
claims on appeal, clearly and unambiguously limit the range of emergency construction
measures available to an applicant. For example, WAC 173-27-040(2)(d) states that
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 28 of 30
“[e]mergency construction does not include development of new permanent protective structures
where none previously existed” and that proposed “new protective structures” must be “the
appropriate means to address the emergency situation.” WAC 173-27-040(2)(d)’s use of the
term “appropriate” clearly indicates that the emergency shoreline exemption does not allow for
any and all protective measures so long as they would abate an emergency and have been
proposed by someone with appropriate engineering expertise. Rather, the provision clearly
provides “the administrator” with discretionary authority to “deem” certain new protective
structures as “appropriate” to address the emergency and, conversely, to deem other protective
measures as inappropriate. While the administrator’s discretionary authority is not boundless, it
must be upheld absent a clear showing of an abuse of such discretion. See e,.g., Wash. Dep’t of
Labor and Indus. V. Higgings, 21 Wn. App. 268, 273, 505 P.3d 579 (2022) (“Appellate bodies
review discretionary administrative decisions for an abuse of discretion.”).
Having established that, contrary to the Appellant’s contention, the emergency shoreline
exemption review process is not merely ministerial in nature and that the Director retained
discretionary authority to approve or deny the Appellant’s proposed emergency construction
measures, this decision turns to whether the Director abused his discretion here. “‘A clear abuse
of discretion may be shown by demonstrating the discretion was exercised in a manner which
was manifestly unreasonable or exercised on untenable grounds or for untenable reasons.’”
Schuh v. State Dep’t of Ecology, 100 Wn.2d 180, 186, 667 P.2d 64 (1983) (quoting Wilson v.
Board of Governors, 90 Wn.2d 649, 656, 585 P.2d 136 (1978)). Decisions that are “manifestly
unreasonable or based on untenable grounds include those that are unsupported by the record or
result from applying the wrong legal standard.” Gilmore v. Jefferson Cnty. Pub. Transp. Benefit
Area, 190 Wn.2d 483, 494, 415 P.3d 212 (2018). The Hearing Examiner determines that the
Director properly exercised his discretion to deny the emergency shoreline exemption.
First, the record establishes that the Director correctly determined the Appellant’s proposal to
address the emergency situation through the installation of a replacement rock bulkhead with
associated wing walls and other features as contrary to City SMP policies that do not allow for
structural stabilization modifications or for the replacement of existing hard shoreline
stabilization structures unless necessary to protect a primary structure. Specifically, SMP
Section 6.1.3(1) provides:
Allow structural shoreline modifications only where it is demonstrated to be
necessary to support or protect an allowed primary structure and primary
appurtenances, or a legally existing principal use that is in danger of loss or
substantial damage or are necessary for reconfiguration of the shoreline for
mitigation or enhancement purposes.
(Emphasis added).
Additionally, SMP Section 6.2.3(5) provides:
Allow existing “hard” shoreline stabilization structures to be replaced if there is a
demonstrated need to protect the principal use or primary structure from erosion
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 29 of 30
and the replacement structure is designed, located, sized and constructed to assure
no net loss of ecological functions and ecosystem-wide processes.
Here, the evidence clearly demonstrates that the proposed protective measures were required only
for the protection of the boathouse structure and not the primary residence and associated primary
appurtenances located above the bluff. Accordingly, the proposed measures would not comply
with these applicable City SMP policies and, therefore, would not comply with the requirement
under WAC 173-27-040(2)(d) that the proposed emergency construction be consistent with the
City’s local shoreline master program. For this reason alone, the Hearing Examiner must uphold
the Director’s decision denying the emergency shoreline exemption request. The Appellant does
not address these applicable SMP policies but, instead, relies on its argument that the Director
erred by analyzing the proposal against these policies and thereby thwarted the expedited review
process for emergency shoreline exemptions. The Hearing Examiner has rejected this argument
but notes in this regard that the City had notified the Appellant of these deficiencies as early as
December 2, 2021, before the Appellant sought the City’s approval of the proposed emergency
measures on January 19, 2022, and well before the Appellant formally applied for the emergency
shoreline exemption on February 3, 2022. Therefore, any claim that the Director’s analysis of
these SMP policies to deny the application actually thwarted the expedited emergency shoreline
exemption review process is belied by the record in this matter.
The record also establishes that the Director correctly determined the Appellant’s proposal
included the development of new permanent protective structures where none previously existed,
contrary to the prohibition under WAC 173-27-040(2)(d). It is uncontested that the proposed
new rock bulkhead would be located landward of the location of the existing concrete bulkhead
and, further, would include additional features such as the wing walls, stairs, and stormwater
features. Although the Appellant argues that the Director’s interpretation of this prohibition
would lead to absurd results because it would mandate the denial of any new structure placed
further landward from the location of the original protective structure, that is what is required
under the language of the provision, and WAC 173-27-040(1)(a) explicitly requires proposals to
meet the “precise terms” of listed exemptions. In addition, the inclusion of concrete steps
providing beach access is clearly not a protective structure necessary to address the emergency
situation and WAC 173-27-040(1)(d) explicitly provides that if any component of a proposed
development is ineligible for a shoreline exemption, then the entire proposal is subject to the
requirement for an SSDP. Accordingly, the Hearing Examiner affirms the Director’s decision
for this reason as well.
While the Hearing Examiner acknowledges that testimony provided at the open record hearing,
as well as evidence in the record, supports a conclusion that the Appellant’s proposal would
abate the emergency situation on the property and, further, that WDFW has expressed its support
for said proposal, this does not undermine City staff’s determination that the proposal for a
permanent, rock bulkhead with wing walls and other features, would not be consistent with
regulatory requirements of the City’s SMP. Further, while City staff (particularly, Senior
Findings, Conclusions, and Decision
City of Bainbridge Island Hearing Examiner
Jones/Burke-Jones, Appeal of a Shoreline Exemption Amendment Denial
No. HEA-2012-01; No. PLN52110 SSDE
Page 30 of 30
Planner Peter Best) suggested alternative measures that would meet the requirements for an
emergency shoreline exemption prior to denial of the request, and (later) its third-party
consultant suggested a similar solution involving use of a sandbag revetement, the Hearing
Examiner does not wish to suggest that an Appellant in these circumstances must adopt the
City’s suggested solution, only that any solution presented by the Appellant when requesting an
emergency shoreline exemption must satisfy the regulatory requirements of the City SMP.
Because the Appellant did not do so here, denial of the requested exemption was appropriate.
Findings 1 – 31.
DECISION
Because substantial evidence in the record supports the City’s determination that the proposed
emergency construction would not be consistent with the regulatory policies of the Shoreline
Management Act or the City Shoreline Master Program, the City did not clearly err in denying
the Appellant’s emergency shoreline exemption amendment request. Accordingly, the City’s
decision is AFFIRMED, and the appeal is DENIED.
DECIDED this 3rd day of October 2022.
ANDREW M. REEVES
Hearing Examiner
Sound Law Center