Washington State Department of Fish and Wildlife biologist Doug Hennick's letter
This letter concludes that the proposal "involving decreased stream and wetland buffers will damage the aquatic system of Brookside Creek which flows through the site." More specifically, it states:
The stream and areas of the wetland that are open water in winter should be managed as salmonid stream habitat, with at least 100-foot wide buffers beyond the ordinary high water mark, because when the downstream illegal barriers to salmon on Brookside Creek are removed, no doubt salmon will once again return to this site.
I have no doubt that juvenile coho salmon migrated into, and reared in, the stream and open-water wetlands presently on the Hill site.
Therefore I request that the stream and wetlands be preserved and protected with adequate buffers for salmonid habitat. The downstream barriers will be removed in the future, because they are in violation of RCW 75.20.060.
It is well documented that buffers are vital for protecting the functions of streams and wetlands, and for several reasons headwaters wetlands such as those on the Hill site are very important to salmonid survival lower in the watershed. They cause streams to flow less violently in winter by storing stormwater, and they cause streams to flow more reliably in summer by slowly releasing that water. Scour from winter storms is presently the worst habitat problem for salmonids in urban streams because eggs and juveniles get killed by the violence of storm flows. Low summer flow in small streams is historically the limiting factor for coho salmon production. So the water storage function of wetlands is vital. Also vital is the rearing habitat they provide. Typically coho salmon juveniles migrate far upstream seeking flooded wetland in winter in which they can forage for food and escape scouring flows in stream channels. Headwaters wetlands also produce fish food which is exported downstream to the benefit of salmonid populations. Because wetlands such as those on the Hill site are so important to salmonids, and because buffers are vital to protect wetlands, I request that no variance be given to diminish the width of the buffers.
I understand the proposal will involve reducing stream buffers to 50 feet rather than 100 feet, and reducing wetland buffers to even less than 50 feet, with buffer enhancement planting proposed as an attempt to maintain buffer functions. I request that full 100-foot stream buffers and 50-foot wetland buffers be maintained with the understanding that the pond on site is part of the stream.
It is well documented that fish life in streams is impacted when buffers are less than 100-feet wide. I am not aware of any report which concludes that in the long term streams will be protected equally well by 50-foot buffers which are well-planted immediately, compared with 100-foot buffers which are protected from further impact and allowed to grow naturally. Buffers that are 100-foot wide are the minimum width for salmonid streams that scientific studies can support.
The WDFW document "Management Recommendations for Washington's Priority Habitats, Riparian (Knutson and Naef, 1997) recommends 150-foot wide buffers for streams such as the one on the Hill site. This report evaluated nearly 1,500 pieces of literature in coming to this conclusion, and represents the best available science.
The Department of Ecology recommends for category II wetlands buffers 100 feet wide in low-intensity land use areas, and 200-feet wide in high intensity land use areas. Single family residences are high intensity land use because experience has shown that buffers are often not adequately protected near houses.
Thus the statements in the applicant's Wetland Delineation and Mitigation Report are contrary to the experience of [Dept. of] Ecology.
The hard-to-support statements in the applicant's
report include: "The proposed mitigation plan should enhance the
existing habitat"; and "After home construction and during
occupancy, the threat to the wetland is minimal." In my judgment those
statements are incorrect. Buffers 50-feet wide are already too narrow for
this wetland. Decreasing them further is not justifiable. Diminishment of
buffers to the extent requested in the variance proposal hurts wetlands and
streams, and thus hurts the salmon in the streams that are associated with
the wetlands.
For the full text of the letter, please click the links below:
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