HomeMy WebLinkAboutFONSI comments
Comment Letter 1
1
Katie Carroz
From:Loftsgaarden, Kirk (FHWA) <Kirk.Loftsgaarden@dot.gov>
Sent:Tuesday, August 09, 2016 3:28 PM
To:Morrow, Stephen (FHWA); Gray Rand
Cc:Katie Carroz
Subject:FW: Upper Hoh River Bank Stabilization EA
FYI – I sent Mr. Lewis the link again and followed up with a call to make sure he received my email. So far, no
feedback on whether the link I sent him worked.
Kirk
From: Dave Lewis [mailto:dclewis3939@msn.com]
Sent: Monday, August 08, 2016 2:32 PM
To: Loftsgaarden, Kirk (FHWA)
Subject: Upper Hoh River Bank Stabilization EA
Kirk,
The link shown on your Notice of Availability, August 8, 2016 will not work for us. Would you send us an
email with the EA attached. A map showing the location of the improvements and section details would be most
helpful.
Thank you,
Dave and Carol Lewis dclewis3939@msn.com Summer Phone: 253-863-9740 Carol's Cell Phone 253-208-
6520
Comment Letter 2
1
Katie Carroz
From:Loftsgaarden, Kirk (FHWA) <Kirk.Loftsgaarden@dot.gov>
Sent:Monday, August 15, 2016 12:57 PM
To:Gray Rand; Katie Carroz; Morrow, Stephen (FHWA)
Subject:FW: Upper Hoh River Road Bridge
FYI - here is another comment.
-----Original Message-----
From: Ben Kashdan [mailto:btkashdan@gmail.com]
Sent: Monday, August 15, 2016 11:54 AM
To: Loftsgaarden, Kirk (FHWA)
Subject: Upper Hoh River Road Bridge
Hi there,
I was wondering what the upcoming work schedule will be for the bridge work on the Upper Hoh River Road. I work for
the park and just want to make sure I can avoid the most congested periods when I go to work at the Hoh. Please let me
know when active construction is being planned for that bridge that will block passage. Thanks!
Ben Kashdan
423.534.0791
btkashdan@gmail.com
Comment Letter 3
1
Katie Carroz
From:Morrow, Stephen (FHWA) <stephen.morrow@dot.gov>
Sent:Tuesday, August 09, 2016 3:44 PM
To:Katie Carroz
Cc:Gray Rand; Loftsgaarden, Kirk (FHWA)
Subject:FW: Upper Hoh River Road Bank Stabilization - Environmental Assessment Notice of
Availability
Katie:
Would you be able to mail a hard copy of the EA to Elaine Somers? Thanks!
Steve Morrow
Environmental Protection Specialist
FHWA (Western Federal Lands)
610 E 5th Street
Vancouver, WA 98661
(360) 619-7811
stephen.morrow@dot.gov
From: Somers, Elaine [mailto:somers.elaine@epa.gov]
Sent: Monday, August 08, 2016 4:56 PM
To: Morrow, Stephen (FHWA)
Subject: RE: Upper Hoh River Road Bank Stabilization - Environmental Assessment Notice of Availability
Hello, Stephen,
If you have one available, would you mind sending me a hard copy of this EA? I would be so grateful.
Thank you!
Elaine Somers
US Environmental Protection Agency
1200-6th Ave., Suite 900, 20th Floor
Office of Environmental Review and Assessment
Environmental Review and Sediment Management Unit
Seattle, WA 98101
Somers.elaine@epa.gov
206-553-2966
From: Morrow, Stephen (FHWA) [mailto:stephen.morrow@dot.gov]
Sent: Thursday, August 04, 2016 1:28 PM
To: Somers, Elaine <somers.elaine@epa.gov>
Subject: FW: Upper Hoh River Road Bank Stabilization - Environmental Assessment Notice of Availability
2
From: Morrow, Stephen (FHWA)
Sent: Thursday, August 04, 2016 1:22 PM
To: allison@setrust.net; theresa.powell@dfw.wa.gov; Rebecca McAndrew (rebecca.e.mcandrew@usace.army.mil);
'lisa_turecek@nps.gov'; MReinders@co.jefferson.wa.us; 'mhagen@Hohrivertrust.org'; 'bridget.kaminski‐
richardson@dnr.wa.gov'; Acker, Marty (marty_acker@fws.gov); Kingsbury, Lori (ECY) (loch461@ECY.WA.GOV)
Cc: Loftsgaarden, Kirk (FHWA); Gray Rand (Ogr@deainc.com); Katie Carroz (Katie.Carroz@deainc.com)
Subject: Upper Hoh River Road Bank Stabilization - Environmental Assessment Notice of Availability
Greetings:
The Western Federal Lands Highway Division of the Federal Highway Administration (WFLHD), in partnership with
Jefferson County, plan to construct bank stabilization and bridge and culvert improvements in six locations along the
Upper Hoh River Road (UHRR). The proposed improvements’ purpose is to prevent the road from washing away at these
locations and provide safe and consistent access to residents, businesses and Olympic National Park (ONP) visitors via
UHRR. WFLHD has recently completed the 30% design detail plan set for the project and will be soliciting public
comments on the draft Upper Hoh River Road Project Environmental Assessment (EA) starting next week, August 8
through September 7, 2016. This email is to provide you an ‘advance copy’ of the EA. The EA can be found at the link
below:
https://flh.fhwa.dot.gov/projects/wa/upper-hoh/
Thank again for your time and input on this project, we look forward to continuing to work with you all to move this
project to a successful conclusion.
Steve Morrow
Environmental Protection Specialist
FHWA (Western Federal Lands)
610 E 5th Street
Vancouver, WA 98661
(360) 619-7811
stephen.morrow@dot.gov
Comment Letter 4
1
Katie Carroz
From:Loftsgaarden, Kirk (FHWA) <Kirk.Loftsgaarden@dot.gov>
Sent:Tuesday, August 16, 2016 3:27 PM
To:Gray Rand; Katie Carroz
Cc:Morrow, Stephen (FHWA)
Subject:FW: comments on the Upper Hoh River Road Bank Stabilization Project Environmental
Assessment.
FYI – See comment below from DNR.
From: Kaminski-Richardson, Bridget (DNR) [mailto:Bridget.Kaminski-Richardson@dnr.wa.gov]
Sent: Tuesday, August 16, 2016 3:11 PM
To: Loftsgaarden, Kirk (FHWA)
Subject: comments on the Upper Hoh River Road Bank Stabilization Project Environmental Assessment.
Hi Kirk,
Thank you for taking comments on the Upper Hoh River Road Bank Stabilization Project Environmental Assessment. My
only comment is to please send me a JARP for any work that will be performed on state-owned aquatic land to start the
authorization process.
Thanks,
Bridget
Bridget Kaminski-Richardson
Aquatic Land Manager
Aquatic Resources Division, Orca-Straits District
Washington State Department of Natural Resources (DNR)
Phone 360-732-0934
bridget.kaminski-richardson@dnr.wa.gov
www.dnr.wa.gov
Comment Letter 5
1
Katie Carroz
From:Morrow, Stephen (FHWA) <stephen.morrow@dot.gov>
Sent:Friday, August 19, 2016 10:19 AM
To:Katie Carroz
Cc:Loftsgaarden, Kirk (FHWA); Gray Rand
Subject:FW: Upper Hoh River Road Bank Stabilization - Environmental Assessment Notice of
Availability
Katie:
Would you mind burning a CD of the EA and mailing to Theresa Powell?
From: Powell, Theresa E (DFW) [mailto:Theresa.Powell@dfw.wa.gov]
Sent: Friday, August 19, 2016 10:17 AM
To: Morrow, Stephen (FHWA)
Subject: RE: Upper Hoh River Road Bank Stabilization - Environmental Assessment Notice of Availability
Hello Stephen
I have attempted many times to download the zipped Draft Environmental Assessment for the Upper Hoh project and
have not been successful (utilizing https://flh.fhwa.dot.gov/projects/wa/upper-hoh/). Is there another link? Or could I
have disc copy sent to the address below?
Theresa Powell
Habitat Biologist
WDFW/Habitat Program
332 E 5th St #230
Port Angeles WA 98362
office: 360-417-1434
cell: 360-461-4263
theresa.powell@dfw.wa.gov
From: Morrow, Stephen (FHWA) [mailto:stephen.morrow@dot.gov]
Sent: Thursday, August 04, 2016 1:22 PM
To: allison@setrust.net; Powell, Theresa E (DFW); Rebecca McAndrew (rebecca.e.mcandrew@usace.army.mil);
lisa_turecek@nps.gov; MReinders@co.jefferson.wa.us; mhagen@Hohrivertrust.org; bridget.kaminski‐
richardson@dnr.wa.gov; Acker, Marty (marty_acker@fws.gov); Kingsbury, Lori (ECY)
Cc: Loftsgaarden, Kirk (FHWA); Gray Rand (Ogr@deainc.com); Katie Carroz (Katie.Carroz@deainc.com)
Subject: Upper Hoh River Road Bank Stabilization - Environmental Assessment Notice of Availability
Greetings:
The Western Federal Lands Highway Division of the Federal Highway Administration (WFLHD), in partnership with
Jefferson County, plan to construct bank stabilization and bridge and culvert improvements in six locations along the
Upper Hoh River Road (UHRR). The proposed improvements’ purpose is to prevent the road from washing away at these
locations and provide safe and consistent access to residents, businesses and Olympic National Park (ONP) visitors via
UHRR. WFLHD has recently completed the 30% design detail plan set for the project and will be soliciting public
comments on the draft Upper Hoh River Road Project Environmental Assessment (EA) starting next week, August 8
2
through September 7, 2016. This email is to provide you an ‘advance copy’ of the EA. The EA can be found at the link
below:
https://flh.fhwa.dot.gov/projects/wa/upper-hoh/
Thank again for your time and input on this project, we look forward to continuing to work with you all to move this
project to a successful conclusion.
Steve Morrow
Environmental Protection Specialist
FHWA (Western Federal Lands)
610 E 5th Street
Vancouver, WA 98661
(360) 619-7811
stephen.morrow@dot.gov
Comment Letter 6
1
Katie Carroz
From:Nicolas Pfeffer-Taggart <nicolas.pfeffer-taggart@hohtribe-nsn.org>
Sent:Friday, August 26, 2016 9:17 AM
To:Katie Carroz
Cc:kirk.loftsgaarden@dot.gov; Steve Allison
Subject:Upper Hoh River Road Project Draft EA
Greetings Ms. Carroz,
I am writing to request a copy of the proposed project locations as presented in the July 2016 Preliminary Draft
EA to be made available in a GIS format (shapefile, personal/file geodatabase, or kml). These data will greatly
assist our staff in reviewing the proposed project activities and help us formulate comments, suggestions and
concerns in a timely manor. If you have any questions or need clarification, feel free to email or call me at 360-
780-0412.
Thanks for your help,
Nic
--
Nicolas Pfeffer-Taggart
GIS Specialist - Hoh Tribe Natural Resources
Cell 360-780-0412
Comment Letter 7
1
Katie Carroz
From:Morrow, Stephen (FHWA) <stephen.morrow@dot.gov>
Sent:Friday, August 26, 2016 1:07 PM
To:Loftsgaarden, Kirk (FHWA); Gray Rand
Cc:Katie Carroz
Subject:FW: Hoh Road ELJ's and Hoh River Trust
See comment below…
Gray, I know you get back August 31, after some initial morning catch-up would you be available for a
conference call at 11:00 to discuss some of the comments/concerns raised by the Hoh River Trust?
From: Acker, Marty [mailto:marty_acker@fws.gov]
Sent: Friday, August 26, 2016 12:58 PM
To: Morrow, Stephen (FHWA)
Subject: Hoh Road ELJ's and Hoh River Trust
Steve,
The Hoh River Trust (HRT) called me this morning because I am the USFWS contact in Washington State for
the Cooperative Endangered Species Conservation Fund (aka Section 6 grants). Our grants (exceeding 12m
between 2003 and 2006) were instrumental to the conservation acquisitions by HRT near the Upper Hoh River
Road Bank Stabilization project area. Our grant program requires that the lands be managed for the benefit of
the listed species and HRT has worked diligently to ensure that outcome. The HRT expressed a few concerns to
me about details of the UHRR stabilization project, and they also shared some positive remarks about the recent
improvements to the project design, preferring the ELJs over the previously described barbs.
HRT's concerns that I heard today:
One of the concerns expressed was that some of the work is proposed on lands owned by HRT and they seek
coordination with WFLHD about operations on their lands, particularly as it pertains to the meeting the purpose
of the grants they received (protection of habitats for listed species).
Another concern HRT expressed was that, by their judgment, the ELJs will deflect the river into their land on
the Schmidt Bar with significant likelihood of eroding away HRT lands, including likely occupied murrelet
habitat.
Finally, HRT mentioned that the community around the project area typically relies on dial-up internet
connections, so the NEPA documentation is too large for many people to download, leading to excess demand
for the library copies. Separate from my Section 7 consultation, I wanted to pass along to you that it appears the
community is having trouble accessing enough copies of the NEPA documents. Hopefully additional copies can
be made available. I do not know who or where that is sought.
My questions:
For my work with the grant-acquired lands, could you help me understand exactly what portions of the project
are on HRT lands, particularly on those lands acquired through our grant program? How is WFLHD
approaching these issues? Is WFLHD coordinating with HRT?
2
For my work on the Section 7 Consulation, can you help me to assess the whether there is a likelihood of
damage to murrelet habitat as a result of ELJ installation? Does that concern match WFLHD's hydrogeomorphic
assessments? If so, my analysis will need to consider this as a significant effect of the project, which is not
something I was anticipating.
Your insights are appreciated.
Best,
Marty
Marty Acker Marty_Acker@fws.gov
USFWS Endangered Species Ecologist
510 Desmond Dr. SE, Lacey, WA 98503
O: 360-753-9073 C: 360-951-6970
Comment Letter 8
1
Katie Carroz
From:Loftsgaarden, Kirk (FHWA) <Kirk.Loftsgaarden@dot.gov>
Sent:Wednesday, August 31, 2016 9:27 AM
To:Katie Carroz; Morrow, Stephen (FHWA)
Cc:Leon, Sven A (FHWA)
Subject:FW: Upper Hoh River Bank Stabilization EA
FYI – here is another comment. This is similar to Hoh Trust comments.
Kirk
From: Dave Lewis [mailto:dclewis3939@msn.com]
Sent: Wednesday, August 31, 2016 9:13 AM
To: Loftsgaarden, Kirk (FHWA)
Subject: Re: Upper Hoh River Bank Stabilization EA
Kirk,
Please consider the following to be our comments for the above noted project:
It appears that the proposed work along the right (North) bank of the Hoh River is not being performed up
stream or adjacent to our property located along the left bank of the Hoh River. Please keep in mind that any
work which would extend into the river channel will effect the river channel upstream and downstream of such
encroachment. Encroachments, constructed in the past, have already caused damage to property along the left
bank of the Hoh River. Please keep us informed of the projects process. Thank you for the opportunity to
comment.
Dave and Carol Lewis dclewis3939@msn.com Summer Phone: 253-863-9740 Carol's Cell Phone 253-208-
6520
From: Dave Lewis <dclewis3939@msn.com>
Sent: Wednesday, August 10, 2016 11:59 AM
To: Loftsgaarden, Kirk (FHWA)
Subject: Re: Upper Hoh River Bank Stabilization EA
Thanks Kirk. The link worked. Do not know why I could not get the address to work when I typed it in. We will
be sending comments.
Dave and Carol Lewis dclewis3939@msn.com Summer Phone: 253-863-9740 Carol's Cell Phone 253-208-
6520
From: Loftsgaarden, Kirk (FHWA) <Kirk.Loftsgaarden@dot.gov>
Sent: Monday, August 8, 2016 2:41 PM
To: Dave Lewis
Subject: RE: Upper Hoh River Bank Stabilization EA
2
Dave –
Give this one a try.
https://flh.fhwa.dot.gov/projects/wa/upper-hoh/
FLH > Projects > Washington > Upper Hoh River Road Phase 2
flh.fhwa.dot.gov
Public Involvement. The information is based on best available data and will be updated as better
data becomes available. Upper Hoh River Road Project Information ...
Kirk Loftsgaarden
FHWA
360-619-7512
From: Dave Lewis [mailto:dclewis3939@msn.com]
Sent: Monday, August 08, 2016 2:32 PM
To: Loftsgaarden, Kirk (FHWA)
Subject: Upper Hoh River Bank Stabilization EA
Kirk,
The link shown on your Notice of Availability, August 8, 2016 will not work for us. Would you send us an
email with the EA attached. A map showing the location of the improvements and section details would be most
helpful.
Thank you,
Dave and Carol Lewis dclewis3939@msn.com Summer Phone: 253-863-9740 Carol's Cell Phone 253-208-
6520
Comment Letter 9
1
Katie Carroz
From:Loftsgaarden, Kirk (FHWA) <Kirk.Loftsgaarden@dot.gov>
Sent:Thursday, September 08, 2016 11:15 AM
To:Katie Carroz; Gray Rand
Cc:Morrow, Stephen (FHWA)
Subject:FW: Upper Hoh River River Road Project
Importance:High
FYI – another comment.
From: john richmond [mailto:watermaps@hotmail.com]
Sent: Wednesday, September 07, 2016 4:10 PM
To: Loftsgaarden, Kirk (FHWA)
Subject: Upper Hoh River River Road Project
Importance: High
ATTN:
Kirk Loftsgaarden
Western Federal Lands Highway
Federal Highway Administration
610 E. Fifth Street
Vancouver, Washington 98661
I have reviewed a hard copy of said project Environmental Assessment and offer the following comments:
From childhood, was raised on the Hoh River, and have memories back to 1940, where at the age of 4,
remember my father loading logs on trucks to haul on the Upper Hoh Road about 10 miles to US Highway 101.
I continue to be a landowner of nearly 100 acres along the river. As such, I have used the Upper Hoh Road as
access to school along the proposed project areas, via the Huelsdonk Bridge until it was decommissioned in
1966.
I feel that I have a reliable basis of historical data and knowledge of past efforts to manage the road
infrastructure along the project sites.
The river channel location was frequently influenced by a large log jam accumulated on a gravel bar and even
by a small, 1-ft. diameter tree toppled to cause the formation of a new long-term channel.
Efforts to stabilize a bank of the river consisted of cutting key logs of a jam at the downstream and waterside to
allow flotation by the next seasonal flood. Landowners without significant financial resources would resort to
tying logs to trees along the bank, or by caballing the tree prior to felling it into the stream. Infrequently, a
bulldozer was available to manipulate a gravel bar or deepen a channel to divert flow in a desired direction.
When quarried rock was available, it was tried with varying success to stabilize the banks near roads. Drifting
logs and trees or undermining would impact the stability of even the carefully placed rip-rap. The greater
problem is the undercutting of the toe of the riprap. The rock is often simply dumped until it quits rolling and
yet not back-filling from below the depth of the Thalweg. The deposits on the channel bottom need to be
2
excavated to a width of not less than 20 ft. and depth of about twice the size of the large dimension of the rip-
rap to be placed.
The stability of rip-rap containing logs with the roots attached is affected whether the logs are cabled to piling
or dead-man anchors on shore, leverage from flotation effect, vibration from water flow, and snagging of, and
impact from floating drift logs. The length along the shoreline and shape of upstream and downstream termini
needs to ensure avoiding back-eddies. Use of Dolosse may aid in stabilizing the infrastructure, if carefully
placed.
Due to severe erosion of the Tower Creek (H-14) channel bottom, it would appear that Class 4 rip-rap treatment
should be extended below and across the channel.
Do the calculations include the 2016 mandate for increased flow?
Would the fish be impacted? Yes, as a result of planned construction or repeated emergency repair activity. The
fish will find a place to spawn away from the activity. They have done in the past.
Should the project be done? Yes, the Upper Hoh River Road is important to residents, visitors, resource
utilization and protection and the economy far beyond the river drainage.
Please proceed with the project as intended, allowing for effects of natural events.
Sincerely,
John C. Richmond
1702 Owl Creek Rd.
P.O. Box 536
Forks, WA 98331
Comment Letter 10
1
Katie Carroz
From:Morrow, Stephen (FHWA) <stephen.morrow@dot.gov>
Sent:Thursday, September 01, 2016 5:19 PM
To:Gray Rand; Loftsgaarden, Kirk (FHWA)
Cc:Katie Carroz; Leon, Sven A (FHWA)
Subject:RE: Parcel ownership maps
All:
I had a good phone conversation with Mike Hagan at the Hoh River Trust earlier this afternoon. Overall, HRT is very
much in support of the proposed project, but had some concerns. The HRT will submit a letter formally identifying the
concerns, but here’s a summary:
• Concern about large tree removal. HRT wants to establish & enhance murrelet habitat (large conifers). I explained
that the project will limit to what it can removal of large conifer trees. I told him I thought it was something on
the order ~20 large conifer (had to check the BA after the phone call – I think that’s right, yes?). Also explained
part of the purpose and need of the project is to prevent future degradation of the riverbanks and further loss of
the old growth conifers, which he agreed.
• Property Maps in the EA – not very accurate. HRT recommends getting the Jefferson County Assessor’s maps
(thanks Gray for the great GIS maps today!)
• Access during construction – easements from HRT are difficult to obtain any easement must also be approved &
signed off by USFWS and DNR. HRT has extended/expanded existing Jefferson County easements to
accommodate previous Jefferson County bank stabilization projects. Will also have to obtain construction access
permits to work on or go through HRT land during construction
• Tower Creek Bridge – one corner of the proposed bridge has 4 landowners: HRT, WA DNR, Jefferson County, NPS
• Schmidt Bar – HRT has lost ~80 acres of forest from the river reclaiming land through its meanders. HRT recognizes
this is a dynamic river, the concern is that just downstream of the ELJ’s at C1 – just downstream of Willoughby
Creek is a remnant stand of old growth on the HRT Schmidt Bar property. HRT concern is the possibility the
protection work could potentially direct flow into that stand and accelerate the erosion & tree loss
Comment/concern he relayed to me, not HRT…
• Peak 6 Tours (Gary Peterson) concern the ELJs could be navigation hazards for recreational rafting
On September 20 (3rd Tuesday) the resource agencies, NGO’s and other local groups have a regular meeting at the Forks
ONRC, they would be interested in hearing from us…. Perhaps we can discuss this next week.
Steve Morrow
Environmental Protection Specialist
FHWA (Western Federal Lands)
610 E 5th Street
Vancouver, WA 98661
(360) 619-7811
stephen.morrow@dot.gov
From: Gray Rand [mailto:Ogr@deainc.com]
Sent: Thursday, September 01, 2016 3:39 PM
To: Morrow, Stephen (FHWA); Loftsgaarden, Kirk (FHWA)
Cc: Katie Carroz
Subject: Parcel ownership maps
Michael Hagen
Executive Director
P.O. Box 3068
Port Angeles, WA 98362
Cell: 360-908-0311
mhagen@hohrivertrust.org
Sept 20, 2016
Mr. Kirk Lofsgaarden
Western Federal Lands Highway
Federal Highway Administration
610 E. Fifth Street
Vancouver, Washington 98661
Comments on the Western Federal Lands Highway Division of the Federal Highway
Administration (WFLHD) Upper Hoh River Road Bank Stabilization Project
Thank you for the opportunity to comment on the proposed project on the Upper Hoh
River Road in western Jefferson County.
HRT is impacted as much as anybody else by the frequent washouts of the County road,
as well as the repairs which follow. We are in favor of a one time fix which could end this
yearly waste of time, resources and money.
We will focus on worksites that fall on our ownership and then look at landscape level
aspects of the proposed project.
Background: The Hoh River Trust (HRT) was formed in 2005 to preserve from
development and restore a forested river corridor reaching from the interior Olympic
National Park boundary to the coast. We currently own close to 7000 acres along the
river, some of it adjacent to the proposed project. Funding for our project was obtained
via grants from the U. S. Fish and Wildlife Service (and others). Our management plan
was co written with the U. S. Fish and Wildlife Service. We plan to restore suitable
habitat for Federally listed species including Marbled Murrelet, Northern Spotted Owl
and Bull Trout. We also protect Bald Eagle habitat under our own more restrictive
conditions (the old Federal rules) rather than what is now allowed under Washington
State protocols. While we use restoration forestry techniques and allow suitable public
use and recreation - we are basically a wildlife refuge.
Many of the practices proposed in this draft – especially the extensive pile driving- would
require our consultation with U. S. Fish and Wildlife Service if we had proposed them.
We will concur with the results of the formal consultation conducted by the project
proponents.
We are also limited by many Washington DNR Riparian Open Space Conservation
Easements (each covering different areas) which limit development of new roads,
structures, new easements, operation of rock pits, new subdivision and even aged stand
management beyond that allowed in our management plan. We can not sell our land or
allow its purpose to change, without repayment of funds. Major changes to existing
easements or new easements will have to be negotiated with our funding agencies and
may require condemnation.
HRT, along with the Hoh Tribe, was an early participant in this planning process and
attended the sessions at the Olympic National Park Headquarters. Much valuable input
was made and is now seemingly forgotten. HRT feels that this plan is much better than
earlier proposals which featured extensive bank armoring using large riprap. However,
as an affected Landowner at at least two and possibly three work sites (depending on
verification of property lines and final plans), HRT has some concerns and comments
about this version of the project.
The colored exhibit showing work sites does not show the “large wood debris jam” (lwd
jam) installation at the upper end of Site c4. (page 241 of the Plan) While this is an ideal
location for a very substantial jam, this is on HRT ownership and will necessitate
removing some large trees, some of which look like suitable Murrelet nesting habitat and
Bald eagle roosts. Shifting the location a bit may spare the largest trees. Any trees taken
should be added to the lwd jam or left free to float in the river. The cleared site should be
revegetated with large stock and have appropriate surface and slope restoration. Soil,
bark, mulch and seed should be certified weed free. We and our partners have spent
years, large sums of money and much physical effort to control noxious weeds on the
Hoh.
This site is quite likely to have shallow alluvium or glacial till over bedrock. Pile driving
using wooden piles may be a problem.
The property line with the U. S. Forest Service is nearby. USFS management here is for
Late Seral Stage restoration.
This site is located adjacent to and across from a well used Chinook spawning bar which
runs from the mouth of Pole Cr. down to Tower Cr. The “Koontz” bar, just upstream, is
also a regular spawning site. All these bars shift yearly.
The downstream portion of c4 shows three lwd jams which will also protect the mouth of
Tower creek. These lie on former HRT land, which is now under the active channel.
This reach is a high stress location during winter flood events. Fish passage into Tower
creek (as is true of all the north bank streams entering the Hoh) was dependent on a
wide alluvial fan left from debris torrents issuing from Tower Cr. These deposits were
washed away last year but can be expected to rebuild (See Bureau of Reclamation
Report). These lwd jams should not only protect bridge infrastructure but encourage
sediment deposition to rebuild the steep creek entrance.
The c3 site is located near a common property corner with the U. S. Forest Service,
HRT, Jefferson County and the Upper Hoh road right of way. Depending on where
construction and clearing may take place, quite a few suitable Murrelet trees may be
taken. As before, we prefer that these be put into lwd jams or the river.
Site c5 at Canyon Creek is, in our opinion, the lowest priority of the work sites. The
culvert has a lot of life left in it and restoring fish access to the upper stream will not be
much of a gain. Its a small system, steep and gets fine sediment runoff from the nearby
rock pit. The lower end of Canyon creek- actually a semi stable side channel system-
has supported a very productive juvenile salmon nursery for decades. Anchoring (or
enhancing) the natural logjams at the upper end of the river bar would be part of some
real mitigation for construction impacts to fish populations in the river and may help to
restore fish access to Spruce cr, just downstream. It should be noted that across the
river on the Huelsdonk/ Fletcher ranch side, there is an old embedded rip rap wall which
protects the ranch.
This site (c5) is adjacent to a well known deep seated slope instability.
If the bridge is built as planned, we would prefer that it not have firm grade controls or
riprap set into the stream bed. The stream needs to regrade naturally to allow
accumulated sediment to pass through and fish to pass up. Bridge footings should be
set accordingly. As at other sites, we would like the conifer wood within the clearing
limits to be put into the creek.
On a landscape scale:
• Long Term Monitoring (by either WDFW and the Hoh Tribe) needs to be
incorporated as part of this project.
• This variety of LWD jam is experimental but looks promising. We all have a
problem securing large enough logs with rootwads to function in LWD projects.
HRT is curious (and concerned) about what these structures may become after
the small diameter wood involved decomposes and nothing is left but dolosse
and steel cable. If these become hazards, who will remove them? What will be
the eventual impact on river rafters and drift boats?
• Boat launches are in short supply. The community has lost put-ins at Canyon Cr,
Spruce Cr., Minnie’s bar and Koontz bar.
On the positive side:
• We are in favor of naturally recruiting log jams which encourage deposition of
sediment to form stable, vegetated river bars. Jams should be designed to catch
and hold floating LWD and operate without the need for maintenance.
• We are opposed to extensive rock armor, especially that which is put in during
emergency repairs to road washouts. These are seldom mitigated and even
when revegetated do not substitute for forested riparian habitat.
• We are in favor of removal of existing riprap / bank armor in areas where there is
undeveloped land in long term open space management.
Thank you for your time and consideration,
Michael Hagen
Hoh River Trust
Comment Letter 11
Comment Letter 12
Comment Letter 13
HOH INDIAN TRIBE
PO BOX 2196 ● FORKS, WASHINGTON 98331
TELEPHONE (360) 374-6582 ● FAX (360) 374-6549
September 10, 2016
Kirk Loftsgaarden
Federal Highway Administration (FHA)
Western Federal Lands Highway Division
610 East Fifth Street
Vancouver, WA 98661-3801
Regarding: Upper Hoh River Road Projects
Dear Mr. Loftsgaarden,
Thank you for considering the Hoh Tribe’s comments regarding the Upper Hoh Road Project(s)
scheduled for the summer of 2017. We can appreciate the difficult erosional issues associated with
trying to maintain road infrastructure adjacent to this dynamic and powerful rain-dominated,
alluvially-bedded coastal river. We offer these general comments related to the project planning,
design and documentation including the draft Environmental Assessment and 30% design detail plan
set. We also offer more specific comments and recommendations related to the fishery resources of
the Hoh River which will be impacted during the project and forward into perpetuity.
Environmental Assessment (David Evans and Associates, INC. July, 2016)
⦁The Hoh Tribe is not a stakeholder (as listed p.1-3), the Hoh Tribe is co-manager and owner of
the fisheries resources impacted by this project. The Hoh Tribe Department of Natural
Resources could be correctly identified and consulted appropriately as the fisheries resource
managing agency.
⦁There is no mention of fish exclusion in the work plans (p.3-5). Plans to remove fish from all
work sites and exclude fish during construction must be developed during planning and
implemented during construction. We need to discuss specific methods to be applied for fish
removal and fish exclusion. Hoh Tribal staff will be available to develop fish removal and
exclusion plans to assist. Hoh Tribal staff will be available to help in the fish removal activities
throughout construction.
⦁In Appendix E, “Biological Survey” the fish species list appears incorrect and incomplete. Giant
Pacific Lamprey, Southern Green Sturgeon and Eulochon are all ESA listed fish found in the
Hoh River. Western Cutthroat Trout does not occur in the Hoh River, though Coastal Cutthroat
Trout do occur.
⦁Property ownership maps are not accurate in the documents provided, namely Hoh River Trust
ownership adjacent to site C4
⦁Hoh Tribe was not consulted by either National Marine Fisheries Service (NMFS) or U.S. Fish
and Wildlife Service (USFWS) during the federal project review. With proposed activities,
particularly pile driving, requiring review by USFWS, we anticipated consultation with regards
to their biological opinions
⦁Hoh Tribe disagrees with “Environmental Baseline” assertions, table 6. Page 24 regarding
Habitat Elements and Watershed Conditions incorrectly characterized as “PF” properly
functioning include: “Large Pools”, “Off-channel habitat”, “Refugia”. None of these habitats are
properly functioning. Hoh River staff were not consulted as to these subjective opinions and
subsequent assertions were generated without Hoh Tribal input. We object to the
characterization of the “environmental baseline.”
⦁Strongly disagree with “Analysis of Effects” table 11, Page 38 of the Biological Assessment.
Assertions made in this section appear incorrect and not supported by data, for example:
Large Woody Debris will not be improved by bank stabilization. The project will eliminate natural
recruitment of wood into the system. Dolosse may recruit wood if installed correctly, but this wood
will already be in the system. These projects will reduce natural recruitment of wood where bank
stabilization has occurred
Large Pools will not be maintained by this project, and this habitat is nt functioning properly on
the Hoh River.
Off-channel Habitat will not be maintained by this project. We understand that bank armoring and
stabilization as proposed in this project will have the effect of entraining the river immediately adjacent to
the rip-rap. Particularly at sites C2 and C4 the effect will be the opposite, off-channel habitat will be
reduced, not maintained. Also, this habitat type is not functioning properly.
Refugia will not be improved, we consider off-channel habitat to be refugia. Access to off-channel
refugia will be destroyed by the installation of bank stabilization systems. The dolosse are not
Engineered Log Jams (ELJ), and though dolosse may offer more complexity than rip-rap alone, we must
remember that the initial, natural complexity in these areas was destroyed when the road was installed.
The net result of the upper Hoh road is a loss in near-bank refugia and access to off-channel refugia.
This subjective and unsubstantiated “analysis of effects” is flawed at many points. Bull Trout
“Subpopulation size” will not be “improved in the long term” by this project. This assertion is unproven.
Bank Stabilization destroys habitat by causing the river to become entrained, promoting depth and
scouring, reducing the capacity for natural meander. Furthermore, kinetic energy is drastically increased
adjacent to bank stabilization, and downstream impacts include scouring of redds, loss of property and
further destruction of off-channel spawning habitat and overwintering refugia. We have seen this process
occur on multiple occasions. The “analysis of effects” is incorrect.
Width to Depth Ratio will be compromised at all sites with bank stabilization, however the analysis only
considers the bridges, not the bank stabilization.
Streambank conditions are destroyed, they are not improved when streambanks are “stabilized”. Who
thinks this? Please see the above comment regarding river entrainment, kinetic energy, scouring, loss of
off-channel habitat, loss of natural wood recruitment… This analysis is simply incorrect.
⦁Table 12, response and Exposure matrix is also incorrect. For example, the “Potential Stressor”
section is incomplete. Installation of ELJ’s with any pile-driving will be a stressor on fish in the
area. The adjacent gravel will be filled with wild steelhead eggs and alevin in addition to
juvenile steelhead, juvenile bulltrout, juvenile cutthroat, juvenile chinook, juvenile coho, sculpin,
juvenile giant pacific lamprey, western brook lamprey, whitefish in addition to adult chinook,
coho, cutthroat, bulltrout and steelhead.
⦁Appendix A of the Biological Assessment is incorrect in the assertion that “Bank stabilization
will likely improve habitat functions for these salmonids in the long term”. For all the reasons
stated above, bank stabilization has negative impacts upon salmon habitat for the long-term.
Normal riparian function will be compromised, the river will be entrained, kinetic energy
increased and downstream habitat destruction and scouring will be promoted. This cnstitutes
long-term habitat failure.
Design Comments
⦁We are encouraged that FHA is considering a repair to the road using more than rip-rap
exclusively, and though dolosse may offer more complexity and potential to grow log-jams by
recruiting wood, they must be located in the water in order to recruit and function properly.
Dolosse should be placed below road grade, such that they are able to function properly. It
appears on some designs that the dolosse placement is at road grade, they must be lower to
facilitate the proposed objective.
⦁During previous ELJ projects on Highway 101 there were massive installations with steel
pilings driven to 40 foot depth. Your design which calls for wooden pilings to be driven 10 feet
will not be sufficient. The wood will shatter upon hitting bed-rock. 10 feet is not deep enough.
The road should be relocated in the areas of C2 and C4 as a long term strategy, otherwise
much larger ELJ installations similar to those located on highway 101 will be required. Until
then we are concerned that more rip-rap will be needed to replace that which will inevitably fall
into the river and the deep channel that will be developed adjacent to the rip-rap. The
associated increase in kinetic energy is extremely detrimental to fish and habitat stability. Have
we learned these lessons along the Hoh already?
Species Specific Comments
Spring/Summer Chinook
⦁Native Spring/Summer Chinook are a stock of critical concern, with chronic under-escapement
this highly prized run of wild fish has been the most constraining to Hoh Tribal Fisheries over
the past decade.
⦁The majority of spawning will happen above the worksite, from early September through
mid-October. Therefore almost 1000 wild chinook must pass beyond all 5 work sites. It is
critical that a fish-passable corridor be maintained adjacent to all work stations. Working
should not occur during crepuscular or night-time hours, as this is the time chinook are most
likely to be migrating past the work sites.
⦁Careful consideration of technology or techniques which might reduce the negative impacts of
pile driving upon wild chinook would be appreciated.
⦁Fish removal must occur at all locations, and fish exclusion must be maintained throughout the
work period.
⦁All locations will be rearing habitat for juvenile chinook, including spring/summer stock.
Therefore fish removal and fish exclusion is important for juvenile chinook
⦁Sites C2 and C4 are located where there is a history of wild chinook spawning. Therefore there
may be spawning activity immediately adjacent to these locations at the end of the work
window. Must be vigilant to avoid impacting active spawning behavior.
⦁Site C5, though valuable, is not mitigation for damage to chinook habitat. Therefore
alternatives need to be developed as mitigation. The Hoh Tribe has several ideas we would
like to discuss.
Winter Steelhead
⦁Wild winter steelhead are likely to be impacted to the greatest extent by the proposed projects
primarily because there is very dense spawning activity adjacent to sites C2 and C4, in
particular C4 is located on the river the MOST DENSE spawning activity in the entire system
(see attached maps of spawning distribution). There may be over 40 wild steelhead redds in
the IMMEDIATE VECINITY. There will be fertilized eggs and viable alevin and fry in these
redds during the beginning of the work window. Contractors must be vigilant as the in-water
work locations may be immediately adjacent to redds, if not super-imposed. In the event that
there are viable steelhead redds at the work sites, the Hoh Tribe expects FHA and the
contractors to consult immediately with Hoh Tribal Staff and WDFW staff to develop a strategy
in order for the project to move forward.
⦁Juvenile steelhead will occur at all work sites during the entire duration of the project. There
will be young of the year, yearling and two and three year old juveniles. Four age cohorts will
be represented in the juvenile fish utilizing all 5 work sites. Fish removal and fish exclusion
must be better defined and coordinated. We can help.
Coho
⦁Historically abundant, the coho population crashed in 2015. The Hoh Tribe was forced to close
our coho fishery in 2015, and again in 2016 as a response the unprecedented low abundance.
Returns in 2015 failed to achieve minimum spawning escapement, and our snorkeling surveys
in the summer of 2016 revealed all-time low abundance. The Hoh Tribe coho directed fishery
was closed in 2016. Therefore the juveniles produced by these valuable adult returns will be
found during the summer of 2017 at the work site. Again, fish removal and fish exclusion must
be defined and coordinated at all work locations. The Hoh Tribe is willing to help with these
efforts.
Thank You for considering our comments. We have included maps with additional comments
and data supporting our assertions regarding spawning fish for your consideration. We look
forward to working with you to achieve success managing this difficult situation we all must
face.
Sincerely,
Joseph Gilbertson, Primary Contact
Fisheries Management Biologist, Hoh Tribal Department of Natural Resources
360-374-6737
360-928-5200
Bernard Afterbuffalo
Fisheries Habitat, Waterquality technician, Hoh Tribal Department of Natural Resources
Hoh Tribal Council
Nicolas Pfeffer-Taggart
GIS, Computational Biology, Technology Specialist, Hoh Tribal Department of Natural
Resources
Site C2
Site C1
Culve rt
RM18.
8
-
2
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:
M
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an'sCrossing
RM0 -0:E l k C r e e k S C
RM17.4-18.8 :W i l l o u g h b y C r e e k
1 inch = 1,000 f eet °FHA Project L oca tion sSpawning Be ds/Ha bita t Notes "n Surve y Rea ch L imits
Morgan 's Xin g to Willough by Cr.ONP Bou ndary to Morgan's Xin g
0 250 500Met ers
0 2,000Feet
Site C3
Site C4 Downstre am Site C4 Upstream
Spawn ing b ed area for Ch inook, Cohoand Stee lh ead from Au g. - June . Ve rygood sp awning bed are a an d is ver ystable h ere.
High w ater spawn ing area for steelhe ad.River mo ved to other side and chan nelis d ry most of the time. March - June isspawning timing
Chin ook a nd Stee lhead spawn in g ar ea.But getting fill ed with bigge r rocks an dless spawnin g he re o ver the last 5 yea rs.Sept. - De c. is spa wni ng time fo r Chin ook.March thru June is spa wni ng time fo r Steelh ead
R M 2 3 -2 4 .2:Coon'sBar
R M 1 8 .8 -2 3 :M o r g a n 's C r o s s i n g
R M 2 4 .2 -2 6 .5 :S p r u c e C a n y o n
1 inch = 1,000 f eet °FHA Project L oca tion sSpawning Be ds/Ha bita t Notes "n Surve y Rea ch L imits
Morgan 's Xin g to Willough by Cr.ONP Bou ndary to Morgan's Xin g
0 250 500Met ers
0 2,000Feet
Site C5
R M 27.1 -29.5:ONPBo u n d a r y
RM0-0:Fle tcher 's SC
RM0-0:BrandebarySC
RM26.5-27.1:Owl C r e e k
1 inch = 1,000 f eet °FHA Project L oca tion sSpawning Be ds/Ha bita t Notes "n Surve y Rea ch L imits
Morgan 's Xin g to Willough by Cr.ONP Bou ndary to Morgan's Xin g
0 250 500Met ers
0 2,000Feet
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Comment Letter 14
State of Washington
DEPARTMENT OF FISH AND WILDLIFE
Mailing Address: 600 Capitol Way N · Olympia, WA 98501-1091 · (360) 902-2200, TTY (800) 833-6388
Main Office Location: Natural Resources Building · 1111 Washington Street SE · Olympia, WA
September 23, 2016
U.S. Department of Transportation
Federal Highways Administration
Western Federal Lands Highway Division
Mr. Kirk Loftsgaarden, Project Manager
610 E. 5th Street
Vancouver, WA 98661
Dear Mr. Loftsgaarden,
Subject: Upper Hoh River Road – Environmental Assessment in Jefferson County,
Washington
The Washington Department of Fish and Wildlife (WDFW) reviewed the Environmental
Assessment (EA) dated July, 2016. The EA is the result of earlier meetings and conversations
with constituents and stakeholders to develop a plan to protect the upper Hoh River Road. The
WDFW is authorized under RCW 77.55.100 to regulate construction activities as proposed in the
EA and encourage potential applicants to consult with us early in their planning process. We
appreciate the opportunity to review and comment on the project proposal prior to submittal of a
Hydraulic Project Application.
The WDFW appreciates the US Department of Transportation (USDOT) efforts to be proactive
in their efforts to maintain access to the upper Hoh River in an environmentally sensitive
manner. Maintaining access to the upper Hoh River poses many challenges in developing
solutions that provide access and protect fish and wildlife at the same time. There are many
examples from the last two decades when last minute emergency projects involved placing riprap
in the river to prevent imminent loss of the road. Unfortunately, in many of these cases
emergency funds only covered placement of the riprap and did not include any mitigation for
impacts to fish or fish habitat. Some of this work continues to impact fish habitat to this day and
many have not been mitigated due to the lack of funding.
It is our understanding bank stabilization is proposed at three locations in addition to replacement
of three stream crossing structures for a total of six projects (Table 1).
Table 1 Project locations
Site Action milepost river
mile
length
in feet
river bed
displacement in
square feet
C1 Bank protection 3.6-3.8 18.5-
18.9
600 9,000
C2 Bank protection 4.0-4.4 19.1-
19.5
2,100 35,000
C2/MP 4.38 culvert Replace culvert 4.38 19.5
2
C3 Tower creek Replace bridge 7.5 23.3
C4 East
C4 West
Bank protection
Bank protection
7.5-7.6
7.9
23.3
23.6
400
100
6,000
C5 Canyon creek Replace culvert
with bridge
10.2 27.1
We offer the following information and comments at this time and will provide additional
comments as the opportunity and project designs progress.
Resources at risk:
We appreciate the level of thoroughness that went into the documentation of fish and wildlife
resources in Section 4.6 of the EA. As mention in the EA, the Hoh River is home to a number of
fish species including depressed spring/summer chinook, fall chinook, coho, chum, sockeye,
steelhead and bull trout. All of these species are present in the mainstem of the river at some
point in their life cycle. We expect adult spring/summer chinook and steelhead in the river
during the part of the instream construction window. Juvenile salmonids and other aquatic
species are present throughout the year and will also be impacted by construction activities.
We intended to provide chinook and steelhead spawner information to illustrate the proximity of
spawning activity relative to the project sites but we were unable to acquire the information prior
to this letter. We are willing to provide this information at a later date if you wish to have it. We
discussed the EA with Hoh Tribal fish management staff since they are co-managers on the Hoh
River. It is our understanding that they will be commenting to the EA and will be providing
additional biological data, including spawning location information relative to the project sites.
Specific project site comments:
C2/MP 4.38 Culvert Replacement: WDFW supports this culvert replacement. The habitat gain
would be 2,146 linear meters for searun cutthroat trout, resident cutthroat trout and steelhead
(WDFW online fish passage barrier database). We are concerned a culvert may not function
properly with changing river elevations over time since it is immediately adjacent to the river.
C3 Tower Creek Bridge: WDFW recognizes the need and supports the bridge replacement
concept. WDFW does not support the design proposal of riprap in the stream channel, buried
under streambed material as it disrupts natural stream processes.
C5 Canyon Creek Bridge: During earlier discussions, it was our understanding the final
proposed projects were specifically identified to maintain the Upper Hoh River Road. Upon
review of the EA, we learned the Canyon Creek project was included as mitigation for other
proposed project impacts. We agree the Canyon Creek fish barrier correction is a good project.
Replacing the Canyon Creek barrier will open up access to 1,491 linear meters of habitat that
may be utilized by searun cutthroat, resident cutthroat and steelhead (WDFW online fish passage
barrier database). Fish passage staff documented an impassable waterfall at 1,491 meters above
the Upper Hoh River Road.
While certainly commendable, barrier correction at Canyon Creek does not mitigate impacts to
adult spring/summer chinook and steelhead that will be present during the instream bank
protection work. In particular, the barrier correction does not mitigate the loss of approximately
3
50,000 sq ft of Hoh River bed or the loss of approximately 3,200 linear feet of riparian area. It
also does not mitigate construction impacts such as disturbance from pile driving or placement of
wood and doloose structures. Appendix C from the Army Corps of Engineers (ACOE) meeting
on July 18, 2015 indicated that for Canyon Creek to be considered mitigation, it would have to
serve the same fish and habitats impacted by the project. Since the habitat upstream of the road
crossing on Canyon Creek would not be utilized by chinook and provides limited use for winter
steelhead, this would not be considered mitigation by WDFW, or ACOE based on the meeting
notes.
Recommendations:
The WDFW offers the following recommendations to minimize and/or mitigate impacts to fish
and fish habitat from construction of the proposed projects.
1. The combination use of doloose and wood structures is a relatively new technique to
reducing river bank erosion. We recommend Federal Highways provide funding for long
term monitoring and maintenance of the project sites. Climate change and the receding Hoh
glacier are contributing to changes in river flow and sediment transport. This should be
considered when developing a monitoring and maintenance plan. We also recommend this
monitoring and maintenance plan be developed jointly with WDFW, Hoh Tribe and other
interested stakeholders. It is imperative that maintenance of the structures be done in an
expeditious manner; therefore Federal Highways should identify funding and responsible
parties.
2. We are concerned the culvert installation at site C4 will not function over time as the river
moves and bed elevation fluctuates. To improve the likelihood of success for long term fish
passage, we recommend a bridge be installed at this location. A bridge is much less likely to
require long term maintenance as the river continues to move around and the bed elevation
changes.
3. We may have missed it in the report, but we did not see any mention of fish exclusion for
instream work. We recommend adding a plan to exclude fish from the worksites during
construction to minimize impacts to fish. Minimizing the impacts to fish also reduces the
level of mitigation required for the project.
4. We encourage you to work with WDFW, Hoh Tribe and stakeholders to develop a mitigation
plan that appropriately mitigates project impacts to fish and fish habitat. The meeting notes
from the US Army Corps of Engineers in Appendix C of the EA, also contain ideas to
mitigate project impacts and provide long term benefits for fish. Below are a couple of
additional examples of alternative mitigation we believe could provide greater long term
benefit to fish.
a. Fund research to evaluate and increase or improve existing off channel habitat.
b. Fund research to evaluate and implement alternatives to armoring the river which
contributes to loss of habitat.
c. Floodplain land acquisitions that protect habitat.
4
Summary:
The WDFW appreciates the opportunity to provide technical assistance early in the design
process which will facilitate quicker processing of the Hydraulic Project Application when the
project enters the permitting stage. We have been a participant in earlier meetings to discuss
options that would be proactive and maintain public access to the upper river. We strongly
encourage you to re-examine the earlier alternative of relocating the road away from the river
where appropriate. The Hoh River is a very dynamic river and all indications are that the river
bed is aggrading. As bed material continues to aggrade in the river, the road will be under
constant threat of erosion necessitating future bank stabilization projects to protect the road.
We would also point out that one of the limiting factors for the Hoh River is the loss of large
wood which provides stream complexity and fish habitat. As long as the road exists in the
riparian area of the river, it is unlikely trees will grow to substantial size and ultimately provide
the needed wood. Without a healthy riparian area, the lack of large wood will continue to be a
limiting factor. Any tree that falls across the road obviously needs to be removed to provide road
access and these trees are cut into smaller pieces to facilitate removal.
Another strong point is that the Treaty Tribes of Washington produced a document titled “Treaty
Rights at Risk”, and a document titled “State of Our Watersheds”. Both documents share tribal
concerns about their ability to continue harvesting fish if we do not do a better job of protecting
fish habitat. We have listed quotes below to illustrate their concerns; the first one speaks
specifically to the Hoh River.
“There is a misconception that the Hoh watershed is relatively pristine and its fish
stocks are healthy, but the system has been heavily impacted by timber harvests,
road construction, infrastructure protection and other anthropogenic influences.”
(2016 State of Our Watersheds Report Hoh River Basin, page 2)
“For more than two decades, harvest rates in all fisheries have been sharply
reduced to compensate for the precipitous decline of salmon abundance in
Washington state waters, but today harvest cuts can no longer compensate for
losses in salmon spawning and rearing habitat.” (2016 State of Our Watersheds
Report Hoh River Basin, page 14)
“We know that we cannot stop the massive population growth anticipated in this
region over the coming decades, but we can ensure that the associated
development is designed and implemented in ways that will better protect salmon
and its habitat.” (Treaty Rights At Risk Ongoing Habitat Loss, the Decline of the
Salmon Resource, and Recommendations for Change - July 14, 2011, page 7)
These few quotes illustrate the concerns of the Hoh Tribe and the Treaty Tribes of Washington.
There are many other published documents produced by the restoration community and local
stakeholders that voice similar concerns. Healthy and harvestable fish populations are an
important social and economic driver in small communities like Forks, Washington.
5
For future projects, we encourage the USDOT to re-engage WDFW, Hoh Tribe, the local
community and the many other stakeholders in new discussions to find solutions that provide
long term protection of the river and maintain public access.
Thank you for the opportunity to provide these comments. If you have any questions, please
contact me at 360-417-1434 or theresa.powell@dfw.wa.gov.
Sincerely,
Theresa Powell
Habitat Biologist
Cc:
Nicolas Pfeffer-Taggert, Hoh Tribe
Joe Gilbertson, Hoh Tribe
Lisa Turecek, NPS
Rebecca McAndrew, USACE
Marty Ackers, USFWS
Lori Kingsbury, WDOE
Bridget Kaminski-Richardson, WDNR
Monte Reinders, Jefferson County Public Works
Dave Kloempken, WDFW
Chris Waldbillig, WDFW
Franklin Hanson, NPCLE
6
References
Treaty Rights at Risk Ongoing Habitat Loss, the Decline of the Salmon Resource, and
Recommendations for Change July 14, 2011.
2016 State of Our Watersheds Report-Hoh River Basin, Northwest Indian Fisheries Commission
Comment Letter 15
1
Katie Carroz
From:Loftsgaarden, Kirk (FHWA) <Kirk.Loftsgaarden@dot.gov>
Sent:Friday, October 14, 2016 12:44 PM
To:Morrow, Stephen (FHWA); Gray Rand
Cc:Katie Carroz
Subject:FW: Draft Upper Hoh River Road EA
FYI – another comment.
From: Eberlein, Mark [mailto:Mark.Eberlein@fema.dhs.gov]
Sent: Friday, October 14, 2016 11:24 AM
To: Loftsgaarden, Kirk (FHWA)
Cc: Love, Sharon (FHWA)
Subject: Draft Upper Hoh River Road EA
Mr. Loftsgaarden,
I received a notice about the Upper Hoh River Road Phase 2 Draft Environmental
Assessment two weeks ago. I realize the comment period is over.
FEMA is currently reviewing several completed projects that Jefferson County has requested
funding for on the Hoh River downstream of your project. It involved extensive riprap. I
wanted you to be aware of this work for your evaluation of the baseline river conditions,
particularly as it pertains to cumulative effects, with your proposed project.
Additionally, your draft EA stated that FEMA was involved in the scoping and interagency
meeting last summer. Can you provide me with the name of the individual(s) that
participated? I need to improve our internal coordination for these types of FHWA sponsored
DOT activities to help ensure FEMA has the right participant(s) supporting DOT.
Thank you and please add me as the FEMA Region 10 Point of Contact for any future NEPA
related requests for comment or participation from your office.
Sincerely,
Mark Eberlein
Regional Environmental Officer
FEMA Region 10
425 487 4735.