HomeMy WebLinkAboutKala Point Bluff Management Plan Parcel 965 000 348KALA POINT BLUFF MANAGEMENT PLAN
Approved by the Board of Directors, Revised April 14, 2015, Version 4.0
SECTION ONE—INTRODUCTION
1.1 This document is the Bluff Management Plan, and is referred to herein as the "plan" or the
"BMP". References to the "association" and the "board" are to the Kala Point Owners Association
and to its Board of Directors, respectively. The "bluff common area" means those parcels of KPOA
common area, which are shown as three sectors on the map in Appendix A.
1.2 Effective and consistent management of the bluff common area cannot be accomplished without a
thoughtful and forward-looking plan. Decisions made only in response to separate tree action requests
by individual members do not result in a coordinated, positive, effective or equitable outcome.
1.3 This plan serves as a roadmap defining how we want our bluff vegetation to be managed and
maintained into the future. It is a tool that should be adjusted and refined as our knowledge of the
bluff grows.
1.4 The Ad hoc BluffNiew Task Force was created by the Board to explore and implement a
structured process to address tree actions on the bluff. The Board instructed the ad hoc Bluff View
Task Force committee to develop a clear policy with intelligent and informed standards that integrate
the consideration of protecting the KPOA bluff common area, while preserving marine views to the
extent that it does not compromise the protection of the bluff. Protection includes bluff stability,
wildlife habitat, and the overall aesthetics of the bluff common area. It is important to understand that
the KPOA governing documents do not guarantee that native vegetation on the bluff common area will
not eventually grow into someone's view over time. With photographic documentation of the changes
in view from the time when the current owner purchased property and when applying for a tree action,
consideration should be given to the request. However, tree actions should not occur at the expense of
bluff stability, wildlife habitat, or in the face of significant concerns expressed to the KPOA Board by
other members. This plan collects and explains those policies and standards.
1.5 The objective of the plan is to define the character that we want for our bluff and the actions that
we must take in order to achieve and maintain that character with consistency into the future.
1.6 The specific goals of the plan are to define policies and procedures that will:
(a) Maintain and protect the value, desirability, and attractiveness of our community,
including the marine views enjoyed by many residents to Kala Point;
(b) Promote the health, safety, and attractiveness of the bluff common area by providing
long-range comprehensive vegetation policies that will encourage:
(1) Native plant diversity, including trees as well as shrubs and other ground cover;
(2) Preservation of large trees that help maintains the wooded character of our
community;
(3) Low growing trees that do not diminish marine views with root structure that promote
soil stability; and
(4) A vigorous understory;
(c) Ensure consistent, equitable and intelligent management of the bluff common area
vegetation, including replanting or other mitigation measures where appropriate;
(d) Assure community participation in the decision-making process at an early stage in order
to gain consensus and reduce the potential for discord;
(e) Assist current and prospective owners in understanding the process and, to the extent
possible, allow them to reasonably predict the likely disposition of view -related requests for
modifying bluff common area vegetation;
(t) Implement a process that identifies, inventories, and organizes information relating to
existing conditions and past decisions on tree actions. This should help members better
understand conditions on the bluff so that the cumulative impacts of BMAC decisions can
be recognized and effectively managed; and
(g) Establish standardized methods to ensure that decision makers consider all pertinent
factors and record their findings in evaluating tree action requests so that all KPOA
members can appreciate how a decision was reached.
1.7 The BMP is organized into six sections. Each section begins with an overview, and then a
statement of policy, followed by a comment that is intended to explain or help interpret the
policy. Each policy concludes with defined actions that will implement the policy.
1.8 It is intended that guidelines for bluff stability and marine view will be used by the
Community and decision makers in evaluating tree action requests related to vegetation on the
bluff common area.
1.9 This plan should be liberally construed and interpreted in order to give full effect to its
purposes, goals, objectives, and policies.
1.10 A specialized vocabulary is necessary in the BMP to discuss and communicate with other
governmental and nongovernmental organizations concerned with marine bluffs. Appendix F is a
glossary that introduces and defines many of these terms.
SECTION TWO—GOVERNING PRINCIPLES
2.1 Overview — The following principles establish basic concepts that underpin the goals,
policies and procedures of the plan.
2.2 Policy— We must protect the marine views and the wooded character of Kala Point, which
makes it a special place.
Comment: The plan strives to maintain mature trees on the bluff while adjusting for view
maintenance by careful tree actions that reflect community -wide aesthetic values and protect
bluff stability. The KPOA CC&Rs specifically recognize the importance of marine views to
homeowners. The term "marine view" will be taken to mean views of the sea and related
objects that appear near in conjunction with the sea. Thus, a member's marine view could
include views of Port Townsend, nearby islands, distant mountains that appear just above
the water, and boats and ships on Puget Sound. A marine view does not mean a full (I80 -
degree) or unobstructed view free of trees.
The KPOA CC&Rs also recognize that Kala Point is a wooded area. This wooded character
should be maintained to the extent that it can be preserved, but not to the extent that trees or
new tree growth are allowed to unreasonably interfere with marine views.
Action: Foster a broadly accepted aesthetic vision of the bluff by encouraging community
discussion, and participation in decision making by members.
2.3 Policy — Effective vegetation practices should be employed to minimize (as much as is
reasonable) erosion and landsliding of the bluff.
Comment: The Kala Point bluff is gradually receding as waves erode the toe of the bluff
during high tide and windstorms and transport the eroded material along the beach. Wave
erosion occurs more frequently, with greater intensity, and for longer durations from late fall
through early spring, especially during the King Tides. Vegetation contributes to the
stabilization of steep slopes and, thus, can slow undercutting of the bluff. The Kala Point
Homeowners Association recognizes that decisions relating to bluff stability are best left to
experts in this field.
Action: To this end, and as required by the Jefferson County Shoreline Management
Program (SMP), the KPOA Board will commission Jefferson County required geotechnical,
biologist, and arborist studies to determine if requested actions could adversely impact bluff
stability and habitat.
2.4 Policy — Effective vegetation practices should be employed to preserve and protect the
health and vitality of the Kala Point lagoon and surrounding wetlands.
Comment: A significant portion of Kala Point's southern shoreline is a coastal lagoon and
salt marsh. This 8.5 -acre tract performs many important hydrologic functions, such as
slowing and storing floodwaters, storing sediment eroded from the adjacent bluffs, and
reducing the erosion of shorelines. In addition, it serves as a home and breeding area for a
diverse array of wildlife, including invertebrates, fish, amphibians, reptiles, birds, and
mammals.
Action:
(a) Utilize available resources such as publications of the Washington State Department
of Ecology and other available sources.
(b) Increase community understanding of the importance of maintaining a healthy lagoon
and the contribution made by vegetation by sponsoring educational meetings for
members with experts, and regulators.
(c) When appropriate, encourage salt -tolerant vegetation on the barrier beach that
protects the lagoon.
(d) Identify areas that would benefit from the planting of additional vegetation with
appropriate plant species contained on the County approved plant list.
(e) Consider tree density, proximity to shoreline, and the shading from the direct sun
provided by the tree(s) in question.
SECTION THREE—PROCEDURE
3.1 Overview — The Bluff Management Advisory Committee (`GMAC") is created as a KPOA
standing committee as per BMAC APP XV.
Comment: The Bluff Management Advisory Committee (BMAC) will be created at Kala Point to
manage the bluff. The BMAC will improve communication between members and help reduce
community discord. The CC&Rs provide that "[t]he Architectural Committee or the Grounds
Committee shall review and approve all requests for clearing, tree removal or limbing in the
Common Area" (CC&Rs, Art. IV, Paragraph B, section 15). Just as the Tree Committee was
created under the umbrella of the Architecture Committee, the BMAC is created under the
umbrella of the Grounds Committee; BMAC will report and make recommendations directly to
the Board. The members of BMAC should come from diverse backgrounds and bring energy and
expertise to the task.
Action:
(a) Appropriate and necessary supplemental administrative procedures and policies (APPS) for
the BMAC should be drafted and adopted by the Board.
(b) The Board will approve members selected by the BMAC to 511 committee vacancies as
they occur.
3.2 Policy — BMAC members are subject to and entitled to the protection provided by the KPOA
Committee Membership Policy (APP 11-30).
Comment: It is important that the same rules and rights be applied to members appointed to the
BMAC as to other standing committees of the KPOA.
Action:
(a) The committee will elect a Chairperson, Vice -Chairperson, and Secretary each January.
Members of BMAC may perform the duties of Secretary on a rotating basis; if so, the
Chairperson shall determine the rotation schedule.
(b) Prepare and publish accurate minutes of all BMAC meetings.
3.3 Policy — The BMAC will gather, organize and preserve information necessary to understand and
manage conditions on the bluff.
Comment: It is understood that the impact of a tree action or vegetation request on bluff stability
should be left to the experts in the field. It is also understood that maintaining view in
conjunction with aesthetics and woodland appearance is also important to the Community.
Understanding existing conditions on the bluff and the natural processes that affect them is
prerequisite to the making of informed, consistent, and equitable decisions. Information that will
be useful already exists or is readily available in a library of printed documents maintained by
BMAC at the KPOA Administration Office and in electronic form on the KPOA website.
Records of the Tree Committee, photographs, geotechnical reports, the KPOA Bluff Management
Report, and substantial literature will be helpful. BMAC relies primarily on the Board
commissioned geotechnical, arborist, and biologist reports. As new information is acquired, it
will be incorporated in the established reference library.
Action:
(a) Establish a library of useful materials that is easily accessed by BMAC members and the
KPOA membership.
(b) For each set of requests, the KPOA Board will initiate a geotechnical, arborist, and habitat
management study in accordance with the requirements of the Jefferson County SMP and
the CAO (Critical Areas Ordinance). The county currently allows KPOA to use its recent
Coastal Bluff Study as a collective geotechnical report for our entire bluff. Because
geologic factors influence large portions of the landscape, a broader analysis is used rather
than a tree -specific study as is done with the arborists and habitat management studies.
3.4 Policy — All tree action requests relating to trees on the bluff common area must be referred
to the BMAC for screening and review. The BMAC will accept requests for tree actions from
individual households to maintain and preserve views. The Board, in consultation with the
BMAC, will commission geotechnical, arborist and habitat management studies covering the
trees in each request. BMAC will review, screen, evaluate and make recommendations to the
Board regarding those tree actions. BMAC will not accept combined requests. Individuals
should submit requests for tree and vegetation actions that most closely affect them. Submitted
photos must (as required by Jefferson County) be from the actual residence of the requester
without zooming or magnification. Following its evaluation of the tree requests and the receipt
and consideration of community input, the BMAC will issue a report presenting its
recommendation to the Board.
Comment: Consistency in decisions and procedure regarding management of the vegetation
on the blurt common area requires that the same guidelines, standards, and opportunity for
community -wide participation be followed in all cases. The BMAC, however, is principally
an advisory committee. Its primary job is to inform and be informed. It will make
recommendations to the Board rather than make decisions.
The BMAC will develop a form to be used in submitting tree requests. A deposit of $250
must accompany each request for the Jefferson County Review. This deposit will be totally
refunded, if for any reason, the request is withdrawn or denied by the Board. After
receiving the cost of the County review, any part of the deposits not spent will be divided
among the requesters. If the County charges more than was collected for the deposit, this
cost will be passed on to the requesters.
The requesters will share the cost of the geotechnical, arborist, and habitat management
studies. After all requests are in and estimates are received for the County -required studies,
the BMAC will hold a meeting to explain the prorated costs to the requesters. At this point,
any requester may withdraw his request and have his deposit returned. A withdrawal of a
request will result in a redistribution of the costs to the remaining requesters. The fees will
be collected at this time and, once the studies have been commissioned, these fees will not
be refunded. However, if the completed studies come in lower than the estimated cost, any
overage will be refunded on a prorated basis.
3.5 Policy — Each request will be assigned a case number, a case manager, and a case co-
manager to evaluate the request. The case manager will be the primary contact with the
requester, the BMAC and the Board.
Action:
(a) Interview requester and complete appropriate form. Only one request can be made
per tree. If multiple requests are made for the same tree, the requesters will be asked
to combine the requests for that tree into a single request with one identified
responsible individual.
(b) Identify and characterize the trees that have been requested for some action.
(c) Review the history of any past requests or actions related to that tree.
(d) Complete necessary research in order to fully understand the consequences of the
request.
(e) Evaluate consultant reports commissioned by the Board specific to the requests.
(t) Prepare an evaluation and recommendation for BMAC and the Board.
3.6 Policy — The BMAC will review, screen, evaluate and will make recommendations to the Board
regarding those tree actions. Following its evaluation of the tree requests and the receipt and
consideration of community input, the BMAC will publish a report describing its preliminary
recommendations to the Board, including vegetation management unrelated to views, consistent with
the BMP and the KPOA Vegetation and Tree Policy (APP II -22).
Comment: The BMAC is an advisory committee. Its primary job is to inform and be informed.
It will make recommendations to the Board concerning approval/disapproval of vegetation action
requests. The Board makes all final decisions related to these requests.
3.7 Policy — The BMAC will facilitate communication and cooperation among members regarding
tree action requests.
Comment: Recommendations and decisions can only be made when all of the necessary
information is available to the affected members. The BMAC will help members understand the
guidelines laid out in the BMP and used by the BMAC to make decisions. It will also assist in the
organization and preparation of tree action requests that they are more likely to conform to the
guidelines.
Action:
(a) Inform the Community about pending tree actions under evaluation and solicit their
comments either through a Town Hall Meeting or through posting on the KPOA Website.
3.8 Policy— The bluff common area is divided into three sectors as shown in the map in Appendix A
Comment: The bluff common area at Kala Point is slightly longer than one mile and contains
many thousands of trees and even more shrubs and plants. The bluff is divided into three sectors,
each of which is reviewed on a three-year basis to reduce the annual workload of the BMAC.
The three sectors are shown in detail in Appendix A. Generally, the south sector begins at the
southern boundary of Kala Point, includes the lagoon, and stretches to a point several hundred
yards north of the boat storage racks on the beach. The central sector starts at this point and
extends north to a point just south of the Seaview Condominiums. The north sector extends from
this point to the northern boundary of Kala Point.
Map in Appendix "A" is approximate. Consult with BMAC or General Manager to confirm accurate
sector boundaries as per lot locations.
3.9 Policy—Trees subject to an action must be identified.
Comment: A system is necessary for identifying which trees are under consideration for an
action, or have been the subject of an action in the past. Member participation in the evaluation
cannot occur unless the tree under consideration can be identified. Consistency cannot be
maintained without a record of past actions concerning a particular tree.
Action:
(a) Construct and install control points that can be used for reference in locating a subject tree.
(b) For those trees pending evaluation and decision, provide prominent colored tags that allow
members to locate the tree.
(c) For those trees that have been the subject of a Board decision, institute a permanent
marking system, referenced to a case number that uses metal tags or other relatively
permanent marker.
3.10 Policy — The General Manager will coordinate review by governmental agencies where
required.
Comment: All approved actions relating to trees on the bluff must be reviewed by Jefferson
County. This review insures that all tree actions conform to the requirements of the Shoreline
Management Program, the Critical Areas Ordinance, and various State and Federal wildlife
protection laws.
Action:
(a) Appoint one or more members to work with KPOA staff to coordinate and present
information that may be required to evaluate Board approved actions.
(b) Establish early contact, and develop a good relationship, with county representatives so that
useful information can be exchanged.
3.11 Policy—The BMAC will monitor implementation of Board approved tree action requests.
Comment: Cost benefits may accrue by aggregating separate tree actions. Upon approval by
county authorities, KPOA staff and/or BMAC representatives will supervise tree work and
monitor any conditions attached to each approval.
3.12 Policy—The BMAC will review the BMP and propose changes to the Board where appropriate.
Comment: Members should understand that this plan will be amended and modified as needed.
Action:
(a) Develop a method of obtaining community suggestions for improvement.
(b) Review and utilize information gained from past tree request evaluations.
3.13 Policy — The BMAC will prepare a written annual report to the Board and the Community,
which summarizes the number and description of the tree actions carried out during the preceding
year.
Comment: A permanent record of tree actions is necessary to measure changes of the bluff
vegetation over time. This will help us evaluate progress and effectiveness. Cumulative effects
are difficult to see when looking only atindividual actions.
Action: Develop a format for record keeping that can be used from year to year.
3.14 Policy — The requester shall bear the cost of tree work relating to view maintenance. Those non -
requesting members who will benefit from a tree action may be asked to, on a voluntary basis, share
the costs of fees and subsequent tree actions.
Comment: Since most tree actions to create or maintain views will only benefit relatively small
number of residents, the cost should be bome by those who benefit. In addition, there will be
some actions that are necessary for bluff stability or safety that will incidentally benefit views:
these actions will be the responsibility of the association and the association will pay for them.
Action:
(a) Rough estimates of the cost of the work should be prepared by the requester as tree action
requests are received.
(b) Members interested in a tree action may enlist neighbors who will benefit from the action to
share costs associated with the request.
3.15 Policy — Tree actions relating to view will be considered by the BMAC in only one sector each
year. Each sector will receive attention every three years in rotation.
Comment: This policy allows for a more organized and systematic approach to bluff and view
maintenance, while also placing this work on a regular schedule that lets residents know when
they can anticipate making tree action requests. All requests for a particular sector will be
considered together by the BMAC.
In rare cases, it may be possible to submit a request out of order; such permission must be
obtained from the Board of Directors.
3.16 Policy —The work of the BMAC and the Board will be scheduled carefully so that all tasks under
consideration relating to the bluff sector can be completed in one year.
Comment: It is essential that all of the view related work of the BMAC with respect to a sector be
completed within one year so that full attention may be given to the next sector in the following
year. The chart in Appendix B illustrates a typical schedule that BMAC will follow.
Each year the BMAC will collect tree/vegetation requests during February and March. As
requests come in, the BMAC chairperson will assign case managers to each request. The Board,
in accordance with Section 2.3 and in consultation with the BMAC, will commission site-specific
geotechnical, arborist and habitat management studies covering all the requests. The case
managers will collect information about each case and fill out standardized forms including a
description of the desired action and interviews with KPOA residents that might be affected by
the requested action.
BMAC will oversee geotechnical, arborist, and habitat management studies commissioned by the
Board. All members of BMAC will then examine each case in detail and arrive at a preliminary
set of recommendations. BMAC's final recommendations will then be posted and forwarded to
the Board of Directors. The Board will hold a special meeting to consider these recommendations
and arrive at its final decision regarding each case. The Board will provide an opportunity during
this meeting for all interested members of the Community to comment on these cases.
The final recommendations of the Board will be published, and during a 15 -day period starting on
the day of publication, any member may file a request for reconsideration. The Board will then
hold a special meeting to consider any requests for reconsideration. At the conclusion of this
meeting, the Board will render its decisions.
The Board's final decisions will then be forwarded collectively to Jefferson County for their
consideration and approval.
3.17 Policy — BMAC members and the Board will use standard worksheets in order to promote
consistency.
3.18 Policy — The BMAC will review and screen all pertinent information and recommend actions to
the Board of Directors. The Board will make all final determinations, which will then be subject to
review by Jefferson County.
Comment: The Association is responsible for the maintenance of vegetation on common areas
including the bluff common area. [CC&Rs, Art. I, Sect. 8, Art. IV, Para. B, Sect. 15, and Art. V,
Sect. I(b), and Articles of Incorporation of KPOA, Art. VI]. This responsibility includes
protecting marine views and preventing bluff erosion as much as reasonably feasible. [CC&Rs,
Art. Sect. 9(a) and (b), Sect. 15, and KPOA APP 11-22, Vegetation and Trees Policy, Rules and
Regulations, 11 A 6(b)].
3.19 Policy — The BMAC shall submit its final recommendations to the Board and the Board shall
publish those recommendations in a report to the Community.
Comment: It is important that the proposed tree actions be widely publicized so that all
community members will have an opportunity for comment.
3.20 Policy — The Board encourages community input prior to making any final decision regarding a
tree action and will provide the opportunity for a full hearing on contested proposed actions.
3.21 Policy — The Board shall consider the recommendations of the BMAC in a special meeting
dedicated for that purpose and shall, within 10 days thereafter, adopt, modify, or reject any or all of the
recommendations, and shall make preliminary decisions as appropriate. Notice of such decisions shall
be published to the membership so that any member, or members, whether or not directly affected by a
preliminary tree decision may within 15 days of the publication of such notice, file a request with the
secretary of the Board that the Board reconsider any or all of the decisions. In the event that there are
multiple requests, they shall be combined, and upon receipt of such requests, the Board shall schedule
a hearing to reconsider the decisions and to receive and consider all relevant evidence or statements
offered by members in support of, or opposition to, the decisions made. Following the hearing, the
Board shall make the final decisions.
Comment: This process allows the Community and the Board to carefully consider decisions
that have important and lasting consequences. It provides opportunity for all points of view to be
considered and gives an opportunity for members who are unsatisfied with a decision to present
materials in a reconsideration hearing. It gathers all of the objections of all of the members into one
hearing so that inconsistent decisions can be avoided. It provides for the completion of the decision
making process, with allowance for reconsideration, in a relatively short period.
SECTION FOUR—BLUFF EVALUATION
4.1 Overview – Understanding existing conditions on the bluff is a prerequisite to planning
effective management of the bluff. In accordance with the Jefferson County SMP, the Board
will commission geotechnical, arborist and habitat management studies covering each set of
requests. Knowledge of the vegetation, habitat, and geology will be accumulated gradually,
although a considerable amount of general information and information specific to the Kala
Point bluff already has been collected. All this information should be organized and maintained
as a library that is accessible to the Board, the BMAC and members of the Community.
4.2 Policy – An understanding of the general geologic characteristics, including slope height
and angle, position of crest and toe, drainage conditions, and soil characteristics will result in
better vegetation management decisions.
Comment: Bluff stability can best be evaluated by professionals that understand the
processes acting on the bluff.
Action:
(a) The BMAC shall examine the bluff carefully at least once each year by walking the
beach and crest, and examining from a boat to identify problem areas.
(b) The BMAC should establish a system of physical control points, or monuments, along
the crest and the toe of the bluff, where feasible, that can be used to identify the
location of tree actions and problem areas. GPS coordinates may serve this purpose
where monuments cannot be placed.
(c) The KPOA Board will commission geotechnical, arborist and habitat management
studies that cover the requested tree actions. At the present time, the 2012 Board -
commissioned Coastal Bluff Study conducted by Shannon and Wilson serves as an
appropriate study of bluff stability. General information on factors that can affect
bluff stability is contained in that geotechnical report, specifically sections 8.0 and 9.0
(available on the KPOA website).
SECTION FIVE—VEGETATION AND MARINE VIEWS
5.1 Overview – Written guidelines that are followed consistently will make decisions more
predictable and fair. One of the main reasons that written view and bluff stability policies are
important is that they help owners and prospective owners predict likely tree action results before
making a tree request. Predictability is lost, however, when decision makers apply policies
differently from the way they have been applied in past decisions relating to the same or very
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similar trees. Decisions made without accepted reasons are often perceived to be arbitrary and
lead to claims of discrimination.
5.2 Policy — The guidelines that are defined in this plan are the policies and philosophies that
have historically been applied in past tree action decisions here in Kala Point.
Comment: Decisions on tree actions relating to view have been made here in Kala Point
since the creation of the association by applying generally accepted, but unwritten, criteria.
Adopting and defining these standards in writing will help members understand them and
aid decision makers in applying them. Community understanding and consistent application
of these guidelines should promote harmony and fairness.
5.3 Policy —No final determination of an action relating to a tree shall be modified or reversed
without a showing of a significant change in circumstances after the final determination was
made.
Comment: Considerable weight should be given to prior Board decisions relating to the
same tree, whether in response to a request by the same or another member, and whether
that determination was made by the current Board or a previous Board. No reconsideration
shall be made unless there has been a significant change in circumstances concerning that
tree since the making of that decision, or a change in policy adopted by the Board.
Reconsideration should not occur merely because a request is made by a different owner or
a different Board is considering it. Determining whether a change of circumstances is
significant will call for a subjective judgment. For example, with respect to tree growth, it
is not appropriate to set an arbitrary measure in number of feet.
Action: Compliance with this policy guideline will require that an accurate record be kept
of the disposition of every tree action. This record should be detailed enough to locate and
identify the tree subject to the requested action and the reasons for that decision. Control
points or monuments should be used to relocate the tree.
5.4 Policy — A tree action may be appropriate where the extent of interference with the amount
of marine view is, or soon will be, significant.
Comment: An evaluation of the extent of the loss of marine view is necessary. Insignificant
view obstruction will notjustify a tree action. However, this factor should also consider the
cumulative effect of numerous otherwise insignificant obstructions. It is based on marine
view rather than the obstruction of a particular feature on the horizon, since every tree
obstructs such views for some owners. Most successful tree action requests will focus on
trimming or removing trees that are growing into a view rather than on mature trees that
have been in existence for many years, even if these trees partially block marine views.
5.5 Policy — This Policy is deleted.
5.6 Policy— large, aesthetically appealing trees should receive additional consideration.
Comment: This category includes trees of great height, particularly handsome specimens,
and trees that otherwise highlight the wooded beauty of Kala Point. Due to its subjective
nature, caution should be exercised when applying this policy. It is not intended to override
other decision factors and merely emphasizes the fact that, despite the predominant value of
marine views, balanced forest accents also deserve consideration.
For trees in this category, it may be appropriate to minimize tree actions, or disallow tree
removal, to achieve the view objective.
5.7 Policy — The effect that a tree decision (either granting or denying a request) is likely to
have on property value should be considered in making any decision.
Comment: The extent of marine view, as a percentage of the total view, has a direct bearing
on property value. Jefferson County places greater value (and higher property taxes) on lots
with marine views. In general, and other things being equal, the greater amount of water in
the view, the greater the market value. However, the presence of some trees on the bluff
may add to the overall value of homes in our Community. The contribution of trees to bluff
stability may also affect property value. One of the principal purposes of our CC&Rs is the
enhancement and protection of the value of our property. An opinion of a specific dollar
gained or lost is of little help. it is sufficient to acknowledge and give consideration to the
fact that significant monetary consequences may be attached to tree decisions.
5.8 Policy— Wildlife habitat should not be significantly impaired by a tree action.
Comment: Protection of wildlife habitat is an important value to Kala Point. In addition,
State and Federal Law provide for the protection of wildlife and may significantly limit
possible tree and vegetation actions.
Action: In accordance with the Jefferson County SMP, the KPOA Board will commission a
habitat management study covering the areas of requested tree actions. These reports will
be considered by the BMAC in making its recommendations to the Board. It is understood
that recommendations made in the habitat management plan may override those made in the
geotechnical and arborist studies.
5.9 Policy — One of the factors to be considered is the extent of marine view at the time the
owner purchased the home.
Comment: The extent of marine view that existed at the time a current owner purchased
their home should be considered. Tree actions should be favored that preserve or restore a
marine view to at least that condition, to the greatest extent reasonably practical. High-
quality photographs should be taken of the view, without zoom or magnification, to
document the view from that home at the time the current owner acquired or completed it.
Photographs must be filed with the KPOA office.
SECTION SIX—MITIGATION AND RECOVERY
6.1 Overview — Achievement of the goals of the BMP will require proactive management.
Effective management may call for measures such as the planting of desirable plant species that
will help control erosion in areas of the bluff where vegetation is sparse and replanting where
tree removal is approved or anticipated. Community education regarding landscaping practices
may help reduce the amount of ground water that reaches the bluff and thus enhance bluff
stability.
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There are many things that can be done to maintain or improve the stability of the bluff. Surface
and ground waters are increasing as Kala Point builds out. Intelligent landscaping practices
upland of the bluff can help reduce the amount of water that reaches the bluff. Good home,
garden and landscape irrigation drainage design, and the reduction of drain field loads through
conservation methods can make a meaningful difference in the amount of groundwater that
reaches the bluff. Trees and low -growing vegetation often are an effective method for the
removal of ground water and the stabilization of soil on the bluff. Maintenance of a buffer of
native vegetation at and immediately upland from the crest will help minimize surface erosion.
6.2 Policy — Consideration should be given to the nature of vegetation used in replanting.
Comment: Some native trees and plants are better than others for slope stabilization and many of
them will not grow so tall that they interfere with views. The BMP should strive for native plant
diversity. The Plant Selection Guide published by the Washington State Department of Ecology
is a good resource to identify appropriate trees and plants.
6.3 Policy — The education of members regarding landscaping practices can reduce ground water that
otherwise would reach the bluff.
Comment: Groundwater contributes to bluff instability. A statement of how we can reduce it is
found in Appendix D.
6.4 Policy — This policy is deleted. Soft armoring is a mitigation technique that is deemed too
expensive for implementation at Kala Point
13
APPENDIX A
Map is approximate. Consult with BMAC or General Manager to confirm accurate sector boundaries.
Bluff Common
sectors
14
for
�l sector
outh Sector
APPENDIX B
. Deleted at April 14, 2015 Board Meeting
APPENDIXB
APPENDIXB. BLUFF VEGETATION REVIEW PROCESS
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15
APPENDIX C
Bluff Stability at Kala Point
KPOA Board Commissioned Coastal Bluff Study 2012
A geotechnical study of the common areas for our entire bluff was commissioned and funded by
the KPOA Board of Directors and performed in 2012 by Shannon & Wilson, a geotechnical firm
located in Seattle. Jefferson County currently accepts this bluff wide baseline study as a
substitute for individual site-specific geotechnical reports. Unlike arborists and wildlife habitat
studies, the geotechnical aspects of a specific tree action have a broader basis since slope
stability and landslide issues tend to be large-scale features. Please refer to the KPOA website
in the BMAC section for a digital copy or to the KPOA administration office for a printed copy.
This document is available to all KPOA members.
16
APPENDIX D
How to Conserve Water and Reduce Groundwater
Groundwater is one of the five critical factors that affect landsliding on Kala Point's bluff.
Groundwater influences the bluff in a variety of ways. When groundwater percolates downward
through more granular permeable sandy soils, it may reach an impermeable layer of clay or clay-
like sediment that causes it to move laterally toward the unconstrained bluff face. Seeps and
springs are common at the contact between different hydrologic units along the face of steep
slopes and bluffs. Water always seeks the path of least resistance and in this instance water that
cannot go down moves laterally to the bluff face. This weakens the bluff and if slippage occurs,
it takes trees and other vegetation, if present, with it. This lateral movement of groundwater
undermines the overlying strata by undercutting the bluff face, reducing support and causing
collapse of the overlying strata. This collapse takes anything connected to or upon that particular
block of soil (KPOA Bluff Management Report).
As Kala Point has been developed, groundwater has increased. There are more homes generating
groundwater from septic systems and irrigation systems. There is greater runoff from house
roofs, driveways and streets, and there is inherently less vegetation to absorb the water. In
addition, there is less vegetation to intercept upstream surface waters.
All of the homes in Kala Point direct their indoor waste water into individual and communal
septic systems; from there it either is reduced by evapotranspiration or percolates into the
subsurface. As water users, we can lessen the amount of groundwater we generate and thereby
help stabilize the bluff by choosing from among many different water -use efficiency practices.
They fall into two categories:
I. Engineering practices: practices based on modifications in plumbing, fixtures, or
operating procedures for water use (such as low flow toilets and showers and more efficient
washing machines).
2. Behavioral practices: practices based on changing water use habits.
The following sections present examples of conservation and water -use efficiency practices that
can benefit individual property owners and the Kala Point bluff, our common property.
Engineering Practices
An engineering practice for individual residential water users is the installation of indoor
plumbing fixtures that use less water. Low -flow plumbing fixtures and retrofit programs are
permanent, on-time conservation measures that can be implemented easily with little or no
additional cost over their lifetimes. In some cases, they can even save the resident money over
the long term in terms of water costs.
Low -Flush Toilets
Residential demands account for about three-fourths of the total urban water demand. Indoor use
accounts for roughly 60% of all residential use, and of this, toilets (at 3.5 gallons per flush) use
nearly 40%. Toilets, showers and faucets combined represent two-thirds of all indoor water use.
The average American uses about 9,000 gallons of water to flush 230 gallons of waste down the
toilet per year (EPA).
Conventional toilets use 3.5 to 5 gallons or more of water per flush, but the low -flush toilets use
only 1.6 gallons of water or less (60% to 80% less than their counterparts). If your home was
built before 1992 and the toilets have never been replaced, then it is very likely that you do not
17
have a water -efficient toilet (1.6 gallon per flush). The cost for the replacement of a conventional
toilet with a low -flush toilet could be recovered in a few years, depending on the cost of the
replacement toilet and household usage ofthe toilet.
Toilet Displacement Devices
Plastic containers (such as plastic milk jugs) can be filled with water or pebbles and placed in a
toilet tank to reduce the amount of water used per flush. By placing one to three such containers
in the tank (making sure that they do not interfere with the flushing mechanisms or the flow of
water), more than I gallon of water can be saved per flush.
Low -Flow Showerheads
Showers account for about 20% of total indoor water use. By replacing standard 4.5 -gallon -per -
minute showerheads with 2.5 gallon -per -minute heads, a family can save a significant number of
gallons of water per year.
Faucet Aerators
Faucet aerators, which break the flowing water into fine droplets and entrain air while
maintaining wetting effectiveness, are inexpensive devices that can be installed in sinks to reduce
water use. Aerators can be easily installed and can reduce the water use at a faucet as much as
60% while still maintaining a strong flow.
Landscaping
Lawn and landscape maintenance often requires large amounts of water, particularly in Port
Townsend with its low summer rainfall. Nationally, lawn care accounts for about 30% of the
total residential outdoor use. Other outdoor uses in Kala Point include washing automobiles and
cleaning driveways.
Landscape irrigation
One method of water conservation in landscaping uses plants that need little water, thereby
saving not only water but labor and fertilizer as well. A similar method is grouping plants with
similar irrigation needs. Scheduling lawn and garden irrigation for early morning or evening
hours can reduce water wasted due to evaporation during daylight hours. Drip irrigation systems
deliver water to specific plants, thereby saving significant water over sprinkler like systems.
Some experts estimate that more than 50% of landscape water use goes to waste due to
evaporation or runoff caused by over watering. One consultant recently stated that lawns are
about 2/3rds as impermeable as asphalt, thus transmitting significant water to surface flow on
slight to moderate slopes.
Most water is wasted in your garden by watering when your plants do not need the water or by
not maintaining the irrigation system. Be attentive if you are manual watering with a sprinkler by
setting your oven timer or some other reminder to move the water promptly. Look for sprinklers
that produce droplets — not mist— and install rain shut-off devices and moisture sensors.
Rain Barrels
Install 55 -gallon rain barrels around your home to collect the water run-off from your roof. For
every inch of rain that falls on a catchment area of 1,000 square feet, there is approximately 600
gallons of water run-off. Your roof catchment area is equal to the total square feet of your house
plus the extension of your eaves. In Kala Point, the minimum roof catchment area is 1,500
square feet, which can generate approximately 900 gallons of water run-off.
18
Theoretically thousands of barrels of water a year could be collected in a well-designed
catchment system. Fifty-five gallon barrels, however, are in reality token collection systems,
gathering water in the winter for use in the summer, but every 55 gallons collected and used in
the garden are 55 gallons saved.
Owners should attempt to increase the density of vegetation (shrubs and manageable trees) on all
properties. This will help offset the vegetation removed during construction of your home and
that associated with Kala Point's development.
Tight lines
Tight lines are drainage pipes that convey roof and other waters from the perimeter of a house to
another location. Older tight lines in Kala Point drain to low spots like ditches, newer ones are
connected to dry wells (gravel filled trenches) by County building code. Those along the bluff,
which is particularly susceptible to erosion, drain to local drainage channels or to the beach.
Tight lines should be constructed of solid sturdy pipe (see definition of terms, Appendix F), laid
underground on homeowners lot, then draped over that bluff and extending to beach level. A
diffuser should be placed at the lower end of the tight line, preventing excessive outlet pressure
(fire hose effect). Tight lines should be inspected on a regular basis to insure that they are serving
their intended purpose.
Behavior Practices
Behavioral practices involve changing water -use habits so that water is used more efficiently,
thus reducing the overall water consumption in your home. These practices require a change in
behavior, not modifications in the existing plumbing or fixtures in your home. Behavioral
practices for residential water users can be applied both indoors in the kitchen, bathroom and
laundry room and outdoors.
In the kitchen, for example, 10 to 20 gallons of water a day can be saved by running the
dishwasher only when it is fill. If dishes are washed by hand, water can be saved by filling the
sink or a dishpan with water rather than running the water continuously. An open conventional
faucet lets about 2.5 gallons of water flow every minute (or 150 gals/hr.).
Water can be saved in the bathroom by turning off the faucet while brushing teeth or shaving.
Take a shower instead of a bath. A full bath requires about 70 gallons of water, while taking a
five-minute shower uses 10 to 25 gallons. Water can be saved by taking short showers rather
than long showers or baths and turning the water off while soaping.
Water can be saved in the laundry room by adjusting water levels in a top -loading washing
machine to match the size of the load. Better yet, when you replace your worn-out top -loading
washing machine, replace it with a front -loading machine. It uses significantly less water and is
far more efficient.
Outdoor water use can be reduced by watering the lawn and garden early in the morning or late
in the evening and on cooler days.
As much as 150 gallons of water can be saved when washing a car by turning the hose off
between rinses.
Additional savings of water can result from sweeping or blowing driveways instead of hosing or
power washing them down. Washing a driveway with a hose uses about 50 gallons of water
every 5 minutes.
19
Finally, and most important, check your indoor water using appliances for leaks. Leaky faucets
that drip at the rate of one drop per second can waste up to 2,700 gallons of water each year. If
you are unsure whether you have a leak, read your water meter before and after a two-hour
period when no water is being used. If the meter does not read exactly the same, you probably
have a leak.
A leaky toilet can waste about 200 gallons of water every day. To tell if your toilet has a leak,
place a drop of food coloring in the tank; if the color shows in the bowl without flushing, you
have a leak.
Another large water waster can be leaks in your irrigation system. Fix irrigation system leaks
quickly, inspect your sprinklers, and drip sprayers regularly for leaks during the daytime since
the optimal time to water is in the nighttime hours when you cannot observe the leaks.
In conclusion, bluffs erode — It's natural, but as individuals and as a community we are
accelerating this erosion. One way we can decelerate this process is acting more thoughtfully
about our water usage. The less water we use, the less groundwater we generate, which means
less seepage and landsliding along the bluff. Efforts need to be made to replace trees that have
been removed with other moisture absorbing plant material. Everyone plays an important role in
this cycle. The Kala Point bluff belongs to all of us, and it is integral to the beauty and value of
our community.
20
APPENDIX E
Glossary
ARBORIST: A specialist in the cultivation and care of trees and shrubs.
BIOTECHNICAL: In slope stability engineering, refers to the use of both live plant material
and inert structures to stabilize and reinforce slopes.
BLUFF CREST: Upper edge or margin of a shoreline bluff.
BLUFF COMMON PROPERTY: See Appendix A for map.
BLUFF FACE: The sloping portion of a high bank.
BLUFF STABILITY: The state of the bluff represented by conditions that maintain, reduce, or
limit the natural erosive processes on the bluff.
BLUFF TOE: The base of a bluff where it meets the beach.
BUFFER ZONE: The area adjacent to a shoreline or critical area that separates and protects the
area from adverse impacts associated with adjacent land uses. A buffer is measured horizontally
and perpendicularly from the ordinary high water mark, and includes the three-dimensional
airspace above. (SMP) See STANDARD BUFFER.
CANOPY: The collective branches and foliage of a singletree or group of trees. Aggregate or
collective tree crowns. A canopy can be closed or partially closed as in a forest or woodland
stand, or composed of both individual trees and closed canopy groups as in an urban forest
canopy.
CANOPY COVER: The drip line area for an individual tree. For a stand of multiple trees it is
the sum of the drip line areas of each tree less any overlap.
CASE: A request as viewed in the context of BMAC processing. A KPOA member submits a
request. A BMAC member handles the request as an assigned case. Each case is identified by a
permanently assigned number.
CASE MANAGER: Each CASE will be assigned a manager and an assistant manager from
among the BMAC members. They will be responsible for evaluating the REQUEST and
processing it through to its conclusion, when any approved action is implemented after the
county's approval.
CATCH BASIN: A structure usually buried, where surface water is captured and conveyed into
pipes and/or where piping (often of different sizes) is connected.
CURTAIN DRAIN: Drainage trench that is excavated into an impermeable soil layer to collect
groundwater that is perched on that layer. Trench is backfilled with drain rock (gravel) that is
enclosed in a geotextile. A perforated pipe is placed within to collect and convey the
groundwater to a suitable discharge point.
DRIP LINE: The area measured from the trunk of the tree outward to a point at the perimeter of
the outermost branch structure of the tree. (SMP, Article 2 Definitions). Stated another way,
assuming the sun stands directly overhead, the perimeter of the shaded area below a tree or
shrub.
GEOTECHNICAL: Refers to the application of civil engineering to some aspect of the earth.
21
GROUNDWATER: Water within the pores between soil particles. Usually a permanent
groundwater table is evident. This is a source of water for wells and springs. If water percolating
through the soil encounters barriers such as clay or hardpan before reaching the permanent
groundwater table, a perched water table may form.
HAZARD TREE: Any tree that presents a risk to persons or property due to a high probability
of falling in the near future because of a debilitating disease, a structural defect, a root ball
significantly exposed, or having been exposed to wind throw within the past ten years.
Hazardous trees include, but are not limited to, conditions where a permanent, primary structure
or appurtenant or accessory structure or public right of way is within one and one half tree
lengths of the base of the trunk. Where not immediately apparent to the CASE MANAGER, the
hazard tree determination shall be made after review of a report prepared by a certified arborist.
HYDROLOGY: Refers to the properties, distribution, discharge, re -charge, and movement of
surface and sub -surface water.
INTERLIMBING: The removal of entire branch whorls or individual branches throughout the
canopy allow more light to pass through, as well as reducing wind resistance of the tree.
LIMBING: The removal of one or more branches of a tree. (CC&R, Article IV.B, Section 9b)
MARINE VIEW: Views of the sea and related objects that appear near in conjunction with the
sea. Thus, a member's marine view could include, but is not limited to, views of Port Townsend,
nearby islands, distant mountains that appear just above the water, and boats and ships on Puget
Sound.
MATURE TREE: Any tree larger than six (6) inches in diameter (19 inches in circumference)
measured at three (3) feet above the trunk base. (APP II -22)
MEDIATION: The act or process of mediating; especially: intervention between conflicting
parties to promote reconciliation, settlement, or compromise (Merriam -Webster).
MITIGATION: Active vegetation management along the BLUFF COMMON PROPERTY to
assure conditions for its STABILITY and to avoid, minimize, lessen, or compensate for adverse
impacts.
NATURAL TREE: Any tree that is not planted by or for a member (APP II -22). In other words,
a tree planted by nature. A plant specimen pre -dating lot development or spontaneously seeded
thereafter.
ORDINARY HIGH WATER MARK or OHWM: That mark that will be found by examining
the bed and banks and ascertaining where the presence and action of waters are so common and
usual, and so long continued in all ordinary years, as to mark upon the soil a character distinct
from that of the abutting upland, in respect to vegetation as that condition exists on June 1, 1971,
as it may naturally change thereafter, or as it may change hereafter in accordance with permits
issued by Jefferson County or the Department of Ecology. On a site-specific basis, Department
of Ecology has the final authority on determining where the ordinary high water mark is located.
(RCW 90.58.030)
PERCHED WATER: Groundwater that accumulates over an impervious soil layer from rainfall
or other sources that finds release on bluff faces. Perched water is released on bluff faces as
seeps and springs.
REMOVAL: Cutting down a tree to ground or to a stump. (APP II -22)
22
REPLACEMENT TREE: Members may, at their discretion, plant a tree to replace a mature
natural tree that has died, has been blown down, was diseased, or was removed for safety or
similar reasons. A member may apply to the appropriate committee (Tree, Grounds, or
Architectural) to have such a tree formally categorized as a "Replacement Tree" in which case
this tree will be treated as a mature natural tree in all future proposed vegetation/tree actions.
(APP II -22)
REQUEST: An application for tree or plant action along the BLUFF COMMON PROPERTY
as seen from the REQUESTER's property.
REQUESTER: One KPOA member who submits an application and fee for tree or plant action
along the BLUFF COMMON PROPERTY. He or she will be the spokesperson for the request.
SECTOR: The BLUFF COMMON PROPERTY is divided into three sectors, designated
South, Central and North. See map in Appendix A.
SELECTIVE LIMBING: See VEGETATION TRIMMING.
SKIRTING UP: Limbing the tree up from the bottom allows a clear line of sight. Instead of an
obscuring mass of foliage, the tree trunk is the only object between you and the view.
SHORELINE MASTER PROGRAM (SMP): The Jefferson County Shoreline Master
Program (SMP) is the local instrument by which Jefferson County and the State Department of
Ecolocy jointly administer the 1971 Shoreline Management Act (SMA), Chapter 90.58 of the
Revised Code of Washington (RCW). The overarching goal of the SMA is "to prevent the
inherent harm in an uncoordinated and piecemeal development of the state's shorelines." In
Jefferson County, the SMA applies to land use and development proposals in and near all marine
waters and certain streams rivers, and lakes.
SIGNIFICANT TREES: These include handsome existing mature trees standing relatively
isolated from other similar trees that are of exceptional height or significant age, or a subordinate
immature tree that is identified as the replacement for an adjacent significant tree that is expected
to die, or be removed, in the very near future.
SOFT ARMORING: Soft shore protection and restoration techniques used to protect property
and forage fish spawning habitat and coastal processes. Indigenous materials such as gravel,
sand, logs, and root masses are used to enhance natural beach shape and processes. Soft shore
armoring is a successful long-term method of addressing the erosion concerns that led to
shoreline armoring while at the same time restoring degraded habitat.
STABILITY: See BLUFF STABILITY.
STANDARD BUFFER: The standard buffer shall be measured landward in a horizontal
direction perpendicular to the ordinary high water mark (OHWM) of the shoreline water body,
and is a three dimensional space that includes the airspace above, as follows: Marine shores - A
minimum buffer of 150 feet shall be maintained in all shoreline environments. See BUFFER.
TIGHTLINE (SOLID PIPE): Typically used to describe a continuous length of solid wall,
rigid or flexible pipe used to transport water down a steep or sensitive slope, either buried or
positioned along the ground surface with appropriate dif aser at the discharge end. A tight line
does not have slots or holes like a perforated pipe. The most appropriate type of pipe to use is
solid -wall, sturdy non -corrugated high-density polyethylene (HDPE) owing to its strength and
resistance to corrosion. Corrugated thin-wall drainage pipe is a poor choice; it is easily broken
by vegetation, minor soil collapse, and fauna.
23
TOPPING: The removal of a substantial portion of the upper tree trunk in conifers and the
cutting of all branches at a particular height for deciduous trees.
TRANSPIRTATION: The process by which water vapor is lost to the atmosphere from living
plants and trees.
TREE ACTION REQUEST: See REQUEST.
TRIMMING: The removal of living plant matter from any type of vegetation; includes
limbing, thinning, shaping, tree pruning and topping. (SMP, Article II Definitions)
UNDERSTORY: Trees or other plants that tolerate reduced-light conditions and normally grow
beneath the forest canopy.
VEGETATION TRIMMING: Techniques shall include selective pruning, windowing and
other measures that preserve native plant composition and structure. No more than twenty-five
(25) percent of a single tree's leaf bearing crown may be removed and no more than twenty-five
(25) percent of the canopy cover of any stand of trees may be removed for view preservation. If
additional trimming is requested in subsequent years, the cumulative removal may not exceed
25%. Limbing or crown thinning shall comply with Tree Care Industry Association pruning
standards, unless the tree is a hazard tree as defined by the Program. Tree topping is prohibited.
(SMP, Article 6,4)
VEGETATION REMOVAL: All vegetation removal within the buffer area must comply with
Article 6.I.D.S. In no instance shall vegetation removal exceed twenty (20) percent of the
required buffer area or fifteen (15) linear feet of the water frontage, whichever is greater. Outside
the buffer, vegetation removal shall be the minimum necessary for maintaining shoreline views
from the primary structure and to provide lawns or ground cover, and must comply with other
applicable requirements such as clearing and grading, forest practices, and protection standards
for fish and wildlife habitat. (SMP, Article 6, 4)
VIEW CLEARANCENIEW CREATION (INITIAL): The initial establishment of a view,
usually during the construction of a home on a lot as approved by the Architectural Committee
prior to the refund of all architectural deposits. (CC&R, Article IV.B, Section 9b)
VIEW MAINTENANCE: Preservation of a view. (APP 11-22)
WETLANDS: Means areas that are inundated or saturated by surface water or ground water at
a frequency and duration sufficient to support, and that under normal circumstances support, a
prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands
generally include swamps, marshes, bogs and similar areas. Wetlands do not include those
artificial wetlands intentionally created for non-wetland sites, including, but not limited to,
irrigation and drainage ditches, grass lined swales, canals, detention facilities, wastewater
treatment facilities, farm ponds, and landscape amenities or those wetlands created after July 1,
1990, that were unintentionally created as a result of the construction of a road, street, or
highway. Wetlands may include those artificial wetlands intentionally created from non-wetland
areas to mitigate the conversion of wetlands. (SMP Article 11 Definitions)
WILDLIFE HABITAT: The natural environment for the fauna of the region.
WINDOWING: This practice allows a view "window" through the existing foliage of the tree's
canopy. In pruning major limbs and branch whorls, sections that obscure a view are removed.
24