Implementation and Effectiveness Monitoring of Hydraulic Projects: Year-One Progress Report

To help ensure that hydraulic structures are compliant with current rules and that current rules effectively protect fish habitats, WDFW is monitoring its hydraulic project approval (HPA) program. The main purpose of monitoring is to provide information which overtime helps us to improve both implementation of the current hydraulic code rules and the effectiveness of those rules at protecting fish habitats.

In 2013 we limited the scope of implementation and effectiveness monitoring to new and replacement culverts on fish-bearing streams in western Washington and new and replacement marine shoreline armoring in Puget Sound. Only these two types of hydraulic structures were monitored in 2013 because: 1) these two types are the most common types and both have a potential to damage fish habitats, and 2) limitations imposed by funding forced us to concentrate our efforts on only two types of hydraulic structures.

The purpose of implementation monitoring is process improvement. Two entities are involved in implementation of a hydraulic project: WDFW (the permittor) and the permittee. The success or failure of project implementation depends on the performance of both entities. Hence, implementation monitoring collects information that could be used to improve the performance of both WDFW and the permittee. Successful implementation of hydraulic projects occurs when the issued permit is in agreement (i.e., accordance) with the hydraulic code rules (WAC 220-110-070)¹ and/or follows WDFW’s design guidelines, and the hydraulic structure fully complies with the permit.

Effectiveness monitoring is done to determine whether or not hydraulic projects are yielding the desired habitat conditions. For culverts, the desired condition is �"no-net-loss of productive capacity of fish and shellfish habitat” (WAC 220-110-070). For marine shoreline armoring, the intended habitat protection is no �"permanent loss of critical food fish or shellfish habitat” (WAC 220-110-285).

Monitoring of Culverts

In 2013 we conducted implementation monitoring on 54 culverts in western Washington. Implementation monitoring focused on four critical structural dimensions: culvert width at streambed, culvert slope, countersunk depth at outlet, and culvert length. We also estimated bankfull width (BFW) at each site. In 2013 we attempted to answer two questions about the HPA permitting process: 1) Did permittees comply with their HPA permits?, and 2) Did hydraulic structures agree with the hydraulic code rules or follow WDFW’s design guidelines?

For the purposes of process improvement, the most important findings in 2013 are related to the measurement of channel width. The most important parameter for culvert design is channel width, and yet information on channel width was unreported for roughly half of 54 HPA permits that we reviewed, including engineering drawings and other supporting documentation. WDFW’s operational definition of channel width is bankfull width, and yet only 20% of permittees reported a bankfull width estimate for their project site. From culvert plans and other supporting documents, we found that instead of reporting BFW, many permittees reported estimates for �"stream width”, �"stream size”, �"streambed width”, �"channel bed width”, �"width at ordinary high water mark”, or something called �"top channel width.”

We also found that when permittees explicitly reported a BFW estimate, 80% of the time their estimate was narrower than our monitoring team’s estimate and it was about 22% narrower, on average. The difference between our monitoring team’s BFW estimate and the permittee’s estimate may be due to the lack of a widely accepted, standard procedure for estimating mean BFW. In other words, some permittees and our monitoring team likely use different methods for estimating mean BFW, and different methods lead to different estimates. Apparently many permittees do not know what they should be measuring or how they should be measuring it.

Our second most important finding was that a significant proportion of HPA permits lacked information necessary to determine whether the culvert’s dimensions will be consistent with rules and/or design guidelines. We assessed 53 culverts for permit compliance. About one-fifth of these permits lacked a specification for at least one critical structural dimension. In all cases, information missing from the permit included culvert width at the streambed.

For the purposes of process improvement, our third most important finding was the considerable difficulty in locating information essential to the hydraulic project approval process. We searched the permit, plans, JARPA, and other materials submitted by the applicant. Basic information such as channel width, channel slope, culvert design type, and critical structural dimensions were missing or difficult to find. These difficulties greatly reduced the efficiency of our monitoring efforts, and we suspect these same difficulties must plague habitat biologists as well. Substantial increases in efficiency for permitting, rule enforcement, and monitoring might be realized if key information â€" such as bankfull width, channel slope, culvert design type, and culvert dimensions â€" were reported and easy to find.

The fourth most important finding is the permittee compliance rate. The permittee compliance rate for the four critical structural dimensions was 76% (N=45). Five noncompliant culverts were too narrow and six were countersunk too shallow. Only two culverts were noncompliant for more than one of the four critical structural dimensions. The compliance rate varied by design type. The compliance rate for no-slope culverts was 85% and for stream simulation culverts was 60%.

The fifth most important finding is the permit accordance rate. For the purposes of determining hydraulic structure agreement with rules or design guidelines, no-slope culverts were compared to specifications in the hydraulic code rules and stream simulation culverts were compared to design guidelines. We found that 50% of the 40 culverts for which design type was known did not agree with the hydraulic code rules or culvert design guidelines. The low rate of accordance was mainly due to one structural dimension - streambed width at culvert outlet, which was too narrow. However, the lack of a widely accepted, standard procedure for measuring BFW means that permittees, permittors, and monitoring staff are likely to be estimating streambed width in different ways, and this is likely to result in different estimates. Therefore, we question the reliability of the permit accordance rate in 2013. We do not have the same concern about the calculation of compliance rates.

The rates of agreement with hydraulic code rules or design guidelines (i.e., accordance) varied greatly by design type. Stream simulation culverts had the lowest rate of accordance: 27%, that is, 73% were not built according to the guidelines. The accordance rate for no-slope culverts was 47%, and the most common reason for nonaccordance was insufficient culvert width at the streambed. In contrast, the permittee compliance rates for stream simulation and no-slope culverts were 60% and 85%, respectively.

We found that permittee compliance with an HPA permit (provisions and project plans) does not necessarily result in hydraulic structure accordance with the hydraulic code rules or design guidelines. Our monitoring results revealed a discrepancy between the permittee compliance rate (76%) and the permit accordance rate (50%). This occurs when a permittee complies with his/her permit but that permit is not in accordance with the hydraulic code rules or culvert design guidelines. Accordance with the rules and guidelines is the responsibility of the permittor issuing the permit. We found that the culvert width at streambed for many no-slope and stream simulation culverts complied with the permit but was not in accordance with rules or guidelines, respectively. The size of this discrepancy may be largely due to different methods for estimating channel or streambed width as mentioned above.

We monitor culvert effectiveness through two processes: 1) fish passage over time, and 2) changes in channel morphology over time. Fish passability is monitored over time using Level A and Level B fish passage barrier assessments. In year one we were able to determine that 83% of the new culverts we monitored passed the Level A fish passage barrier assessment. We were unable to make a determination regarding fish passage for the other 17% of culverts because we did not do measurements required for the Level B fish passage barrier assessment. We will in 2014.

Monitoring of Marine Shoreline Armoring

In 2013 all the monitoring of HPAs for marine shoreline armoring occurred in Kitsap and San Juan Counties as the work was primarily funded through a grant provided to these counties to cooperatively assess the shoreline armoring permitting process. We reviewed 106 marine shoreline armoring permits: 31% were new/extension projects, 49% were replacement projects, and 20% were repair projects. Eighty-eight percent of projects used primarily hard armoring, and 8% and 4% used soft armoring or a combination of hard and soft armoring, respectively.

The most critical information for marine shoreline armoring projects is the length of armoring and the location of armoring with respect to the ordinary high water line. We found 40 of 106 (38%) of HPA permits had no clear statement of the project¡¦s length. We also found that while almost all permits, 99%, provided some measure of the maximum water ward extent of armoring, many used a benchmark or reference point that could be altered or made difficult to access after the project was completed. Of 26 hard armoring permits (new or extension), only 12% of the permits described the project¡¦s location as a distance to a benchmark or permanent structure that would not change as a result of project activities. For the other 88% of permits, determining compliance with the permitted location of shoreline armoring was difficult if not impossible.

In 2013 we surveyed 13 marine shoreline armoring projects for implementation monitoring ¡V 10 were post-construction surveys and three were pre-construction surveys. According to our measurements, nine of 10 projects surveyed post-construction had at least one measurement that was greater than indicated in the permit. Half of the projects were longer than indicated in the permit, 30% were taller, and 60% were further water ward relative to at least one reference elevation. However, it should be noted that the terminus of projects were often difficult to identify in the field and the reference elevations identified in permits were subject to change by construction activities and natural processes, resulting in a high degree of uncertainty when comparing field measurements with permit specifications.

Recommendations

The first year of implementation and effectiveness monitoring of culverts leads us to make the following recommendations for improving the HPA permitting process:

• Language referring to stream channel width should be identical in hydraulic code rules, permit provisions, and culvert design guidelines.
• Standard procedures for estimating mean bankfull width and channel slope should be developed by WDFW and widely distributed for use by HPA applicants.
• Key information ¡V such as bankfull width, channel slope, culvert design type, and culvert dimensions ¡V should be reported and easy to find. We recommend a mandatory form for all HPA applications to be completed by the applicant.
• Bankfull width measurements submitted by HPA applicants should be checked by WDFW or some other credible organization.
• For no-slope culverts, channel slope submitted by HPA applicants should be checked by WDFW or some other credible organization.
• Standard permit provisions for culverts used by WDFW habitat biologists should be reviewed for consistency with hydraulic code rules and design guidelines.

The first year of implementation and effectiveness monitoring of marine shoreline armoring leads us to make the following recommendations for improving the HPA permitting process:

• Key information ¡V such as bulkhead length, bulkhead height, bulkhead design type ¡V should be reported and easy to find. We recommend a mandatory form for all HPA applications to be completed by the applicant.
• The location of the ends and water ward extent of marine shoreline armoring should be described in HPA applications with respect to engineering benchmarks or permanent structures in the upland that will not change over time.

¹ In November 2014 WDFW promulgated revised hydraulic code rules. All references to hydraulic code rules in this report refer to the rules in effect immediately prior to November 2014.