Trickey, J.
¶ 1 David and Nancy Honeywell d/b/a Orca Dreams LLC (collectively, the Honeywells) appeal a decision of the Shorelines Hearings Board (SHB). The SHB affirmed the Washington State Department of Ecology's (DOE) $55,000 shoreline violation civil penalty against the Honeywells. The Honeywells argue
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