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 WA

October 25, 2010 City of Dupont Bill Kingman, Senior Planner 1700 Civic Drive Dupont, WA 98327 Dear 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 12.0019

The Washington Department of Fish and Wildlife (WDFW) received for review and response the above noted proposal and offers the following comments at this time. Additional comments may be offered as project review progresses. Wetland Buffer Reduction This project proposes to reduce a wetland buffer from 200 feet to 100 feet. This documented wetland area is associated with Sequalitchew creek and also documented as providing significant wintering waterfowl habitat and general wildlife habitat. Wetland vegetation provides several benefits to fish and wildlife that are found in and around streams. These benefits include but are not limited to water quality improvements, food and habitat for fish and wildlife, flood control, and shoreline erosion control. Many varieties of waterfowl and non-game birds depend on wetlands for feeding and resting areas during their spring and fall migration. Wetland buffers reduce adverse impacts to wetland functions from adjacent development. The literature indicates that buffers reduce wetland impacts by moderating the effects of storm water runoff including stabilizing 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 disturbance on 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 a visual separation. Wetland-associated species also use buffer habitat for feeding, roosting, breeding and rearing of young, and cover for safety, mobility, and thermal protection. Riparian/wetland areas are critical to the ecological integrity of all upstream and downstream habitat areas and should be protected by appropriate buffers with limitations on development. Recommendation: A minimum 200 to 300 foot wide buffer is typically recommended for avoiding or minimizing disturbance to feeding/nesting waterfowl and wading birds. A reduction should only be granted only if the applicant demonstrates that the requested action conforms to all of the criteria set forth as follows:

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• 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 Buffer A 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 recommends compensatory mitigation in the form of wetland restoration of more than or equal to the square feet of negatively impacted areas. The applicant should develop and implement a wetland enhancement plan to re-establish a functional wetland buffer in and adjacent to the area of impact. This plan should include but not 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 Turtle A western pond turtle was potentially found in Edmonds Marsh north of the development, and is currently under review with Michelle Tirhi, District Wildlife Biologist. Western Pond Turtles are a state listed endangered species. This species uses aquatic habitats such as ponds, marshes, streams, and protected shallow areas for resting and feeding cover. Additionally, the turtles use upland habitats for nesting and overwintering. This species is extremely shy and easily disturbed. They also may have a home range that includes separate bodies of water, such as a series of ponds. Below are the recommendations should this turtle 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,

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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 Oak Oregon White Oak and state threatened western gray squirrels are documented within ½ a mile of this property, which are a state priority habitat and species. Oregon white oak woodlands are used by an abundance 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 western gray squirrel is also almost exclusively dependent on oak stands, which provide essential mast food sources and cavities for hiding cover, food caching, and nesting. Oregon White oaks should be surveyed for and if identified 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 me at (360) 895-3965 or gina.piazza@dfw.wa.gov. Sincerely,

Gina Piazza Area Habitat Biologist