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State of Washington                              DEPARTMENT OF FISH AND WILDLIFE            Mailing Address: 600 Capitol W...
Bell Hill Lots 1 & 2October 26, 2010Page 2 of 3    •   Special conditions and circumstances exist that are peculiar to the...
Bell Hill Lots 1 & 2October 26, 2010Page 3 of 3        roads, ditches, or chain link fences should be avoided within this ...
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Bell hill-lots-wdfw-letter-to-du pont-10-18-2010


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Bell hill-lots-wdfw-letter-to-du pont-10-18-2010

  1. 1. State of Washington DEPARTMENT OF FISH AND WILDLIFE Mailing Address: 600 Capitol Way N, Olympia WA 98501-1091, (360) 902-2200, TDD (360) 902-2207 Main Office Location: Natural Resources Building, 1111 Washington Street SE, Olympia WAOctober 25, 2010City of DupontBill Kingman, Senior Planner1700 Civic DriveDupont, WA 98327Dear Mr. Kingman:SUBJECT: Notice of Sensitive Area Application Comments, Bell Hill Lots 1 & 2, Wetland Tributary to Sequalitchew Creek, Section 25, Township 19 North, Range 01 East, Pierce County, WRIA 12.0019The Washington Department of Fish and Wildlife (WDFW) received for review and response the abovenoted proposal and offers the following comments at this time. Additional comments may be offered asproject review progresses.Wetland Buffer ReductionThis project proposes to reduce a wetland buffer from 200 feet to 100 feet. This documented wetland areais associated with Sequalitchew creek and also documented as providing significant wintering waterfowlhabitat and general wildlife habitat. Wetland vegetation provides several benefits to fish and wildlife thatare found in and around streams. These benefits include but are not limited to water qualityimprovements, food and habitat for fish and wildlife, flood control, and shoreline erosion control. Manyvarieties of waterfowl and non-game birds depend on wetlands for feeding and resting areas during theirspring and fall migration.Wetland buffers reduce adverse impacts to wetland functions from adjacent development. The literatureindicates that buffers reduce wetland impacts by moderating the effects of storm water runoff includingstabilizing soil to prevent erosion; filtering suspended solids, nutrients and harmful or toxic substances,and moderating water level fluctuations. Buffers also reduce the adverse impacts of human disturbanceon wetland habitats including blocking noise and glare; reducing sedimentation and nutrient input;reducing direct human disturbance from dumped debris, cut vegetation, and trampling; and providing avisual separation. Wetland-associated species also use buffer habitat for feeding, roosting, breeding andrearing of young, and cover for safety, mobility, and thermal protection. Riparian/wetland areas arecritical to the ecological integrity of all upstream and downstream habitat areas and should be protectedby appropriate buffers with limitations on development.Recommendation: A minimum 200 to 300 foot wide buffer is typically recommended for avoiding orminimizing disturbance to feeding/nesting waterfowl and wading birds. A reduction should only be grantedonly if the applicant demonstrates that the requested action conforms to all of the criteria set forth asfollows:
  2. 2. Bell Hill Lots 1 & 2October 26, 2010Page 2 of 3 • Special conditions and circumstances exist that are peculiar to the land, the lot, or something inherent in the land, and that are not applicable to other lands in the same district; The special conditions and circumstances do not result from the actions of the applicant; • A literal interpretation of the provisions of this Title would deprive the applicant of all reasonable economic uses and privileges permitted to other properties in the vicinity and zone of the subject property under the terms of this Title, and the requested buffer reduction is the minimum necessary to provide the applicant with such rights; • Granting the buffer reduction will not confer on the applicant any special privilege that is denied by this Title to other lands, structures, or buildings under similar circumstances; • The granting of the buffer reduction is consistent with the general purpose and intent of this Title, and will not further degrade the functions or values of the associated critical areas or otherwise be materially detrimental to the public welfare or injurious to the property or improvements in the vicinity of the subject property; • The decision to reduce the buffer includes the best available science and gives special consideration to conservation or protection measures necessary to preserve or enhance anadromous fish habitat; • The granting of the buffer reduction is consistent with the general purpose and intent of the city of Dupont’s Code and adopted development regulations.Construction within Wetland BufferA sewer line installation is proposed to be constructed within a wetland buffer.Recommendations: In an effort to offset the impacts to the wetland buffers, WDFW recommendscompensatory mitigation in the form of wetland restoration of more than or equal to the square feet ofnegatively impacted areas. The applicant should develop and implement a wetland enhancement plan tore-establish a functional wetland buffer in and adjacent to the area of impact. This plan should include butnot be limited to: • Minimize removal of existing trees and/or stumps/root wads. • Re-establish wetlands with a diverse list of native trees and shrubs that are common to riparian areas in Western Washington. • Best Management practices used to ensure that sediment-laden water is not allowed to enter the wetlands.Western Pond TurtleA western pond turtle was potentially found in Edmonds Marsh north of the development, and is currentlyunder review with Michelle Tirhi, District Wildlife Biologist. Western Pond Turtles are a state listedendangered species. This species uses aquatic habitats such as ponds, marshes, streams, and protectedshallow areas for resting and feeding cover. Additionally, the turtles use upland habitats for nesting andoverwintering. This species is extremely shy and easily disturbed. They also may have a home range thatincludes separate bodies of water, such as a series of ponds. Below are the recommendations should thisturtle be confirmed as a western pond turtle: • The western pond turtle should be considered when managing any watercourse within 1 km (0.5 mi) of a site known to contain this species. Efforts to manage for western pond turtles only in small portions of a watercourse or in discreet ponds, may not help this species over time, since individual turtles range overland between aquatic sites. • A no disturbance buffer between 400-500 m (1,300 - 1,600 ft) should be employed around all bodies of water inhabited by western pond turtles. The construction of barriers such as bulkheads,
  3. 3. Bell Hill Lots 1 & 2October 26, 2010Page 3 of 3 roads, ditches, or chain link fences should be avoided within this distance, as should activities such as timber harvest, road building, burning, and recreation. • Emergent logs and stumps should not be removed from waters where western pond turtles occur. Consider providing logs and other basking surfaces if basking sites are lacking or limited. • Alterations to wetlands used by western pond turtles, such as draining, dredging, or filling should be avoided. • The elimination of protected shallow areas in wetlands should be avoided. • Disturbances that could cause vegetation in and around wetlands to become extremely dense, possibly inhibiting the turtles movements, should be avoided. • Banks, sunny slopes, and other open sites on adjacent uplands should be protected from excessive trampling by livestock, people, and vehicles. • Herbicides should not be applied if such action will destroy all available cover in all or part of a wetland. Applications of herbicides, pesticides and other chemicals that could eliminate food sources or have a toxic effect on turtles should also be avoided near sites occupied by western pond turtles.Oregon White OakOregon White Oak and state threatened western gray squirrels are documented within ½ a mile of thisproperty, which are a state priority habitat and species. Oregon white oak woodlands are used by anabundance of mammals, birds, reptiles, and amphibians. Many invertebrates, including various moths,butterflies, gall wasps, and spiders, are found exclusively in association with this oak species. The westerngray squirrel is also almost exclusively dependent on oak stands, which provide essential mast food sourcesand cavities for hiding cover, food caching, and nesting. Oregon White oaks should be surveyed for and ifidentified on this property, the following recommendations apply: • Mitigation should retain connective corridors between oak on the project site and adjacent parcels. • To minimize project impact, new roads, structures and other facilities should be located outside and away from these critical areas. • Do not cut Oregon white oak woodlands except for habitat enhancement. • Allow only early spring, low-impact cattle grazing. • Allow low-impact recreation (hunting, fishing, hiking, mushroom and acorn collecting). • Retain large, dominant oaks and standing dead and dying trees. • Leave fallen trees, limbs, and leaf litter for foraging, nesting, and denning sites.Thank you for the opportunity to provide these comments. If you have any questions you may contact meat (360) 895-3965 or,Gina PiazzaArea Habitat Biologist