Friends Research Highlights Issues with Shoreline Armor Enforcement and Permitting

By Madeline Feaster and Tina Whitman

As you know, Friends of the San Juans protects and restores natural shorelines to support forage fish, salmon, and the Southern Resident orca. In addition, Friends also conducts research on these shoreline habitats. We recently completed a Shoreline Armor Mapping, Change Analysis, and Regulatory Review project that provides an accurate snapshot of how much shoreline armor (bulkheads, seawalls, and rip rap) has been built or removed in the past decade. Importantly, this original research also includes a detailed assessment of permits for new armor that was installed during that time. The results are astounding! By identifying how many shoreline projects were (or were not) fully permitted, we have provided county and state managers with detailed information that can help them improve the effectiveness of regulatory protections.

Shoreline armoring like bulkheads, seawalls, and riprap can cause concerns because they impact the natural, coastal processes and habitats that are essential to rearing juvenile salmon and their prey. These armoring structures directly bury beach and backshore habitat, disconnecting riparian areas and wetlands from beaches and marine waters. They also disrupt the sediment supply and transport processes that form and maintain beaches.

Using Friends’ 2009 countywide inventory of shoreline modifications as a baseline, we re-mapped armoring on all 400+ miles of marine shoreline in 2019. These armor-mapping results were then analyzed to document changes in armoring over the ten-year period; next, we conducted an analysis of permitting and enforcement actions for the newly armored sites. As with all of our shoreline research, the findings will be used to inform on-the-ground habitat and protection efforts.


Our 2019 mapping results documented that in a ten-year period new armoring was installed at 108 locations (totaling 1.8 miles) and armor was removed from 17 sites (totaling 0.24 miles); the mapping effort also confirmed the continued existence of 875 armor segments (totaling 25 miles).

For the 108 new shoreline armor structures we identified, Friends of the San Juans then worked with graduate student intern Madeline Feaster to complete a detailed review of all corresponding permit and enforcement records. Authorizations from both the local government and the state are required for new shoreline armoring installations, so we researched, compiled, and reviewed both county and state permit records during this comprehensive analysis.

While over a quarter of these new armor sites had some of the required local and state permits, just 9% of the 108 documented new sites possessed all of the required permits before the structure was installed. Thus, 91% of new shoreline armoring that was installed in San Juan County between 2009 and 2019 happened without all the proper authorizations. This is important because it’s the permitting process that allows our county and state officials to make sure that crucial, legally-required environmental protections are put in place. These low compliance results clearly demonstrate that better tracking of on-the-ground conditions, coupled with improved effectiveness of enforcement efforts, must be a top priority for our community.

For those sites with permits, each component of the permit was investigated, including application materials, consultant reports, permit decisions, and conditions. Ultimately, in addition to the low overall compliance rates, for those sites with permits we also found many deficiencies in mitigation, enforcement, and overall tracking.

Right now, Friends is presenting these findings to our partners, as well as to state and county regulators, opening up conversations about the research results and identifying data-driven solutions. By talking constructively — with this new hard data in hand — about the current enforcement and permitting systems, we can help prompt discussions about how to improve and strengthen environmental stewardship across the San Juan Islands and Puget Sound. A priority for Friends this year is to ensure that these results lead to changes in the effectiveness of existing county and state programs, especially compliance, and that they ultimately ensure that the region’s habitats and species are protected from the known negative impacts of shoreline armoring.

This project has been funded wholly or in part by the United States Environmental Protection Agency under assistance agreement PC-01J22301 through the Washington Department of Fish and Wildlife. The contents of this document do not necessarily reflect the views and policies of the Environmental Protection Agency or the Washington Department of Fish and Wildlife, nor does mention of trade names or commercial products constitute endorsement or recommendation for use.

It’s important to us that any organization we are involved with actually gets things done, and the work that the Friends takes on so capably really does make a difference.

Ken and Mariann Carrasco

members, Orcas Island