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HomeMy WebLinkAbout001Asf 'S l0 PORT GAMBLE SWLALLAM TRIBE 31912 Little Boston Rood NE • Kingston, WA 98346 May 13, 1997 ` John Holgate, Senior Planner Jefferson County long Range Planning Division �''��'�" 7997 P.O. Box 1220 Port Townsend, WA 98366 Dear Mr, Holgate, Thank you for the opportunity to comment on the Draft Environmental Impact Statement (©EIS) for the Jefferson County Draft Comprehensive Plan, The Port Gamble 8XIallarn Tribe and other Point No Point Treaty Council Tribes have treaty -reserved resources within eastern Jefferson County that will be severely impacted by implementation of the proposed Comprehensive Plan. The DEIS does not fully address many of these impacts, nor propose adequate mitigatlon measures. 1. he DEiS does not consider impacts of an inadequate Critical Areas rdinance on water quality, fish, shellfish and wildlife. The Comprehensive Plan does not mention revision of the Interim Critical Areas Ordinance (ICAO), whioh currently does not provide adequate protection to wetlands, streams, shorelines or unstable slopes, These areas represent essential habitats for maintaining the public and tribal resources of water quality, fish, shellfish and wildlife, • The critical area buffers for wetlands and streams In the ICAO are generally one- half of the minimum width actually needed to protect these areas according to the best available science. • Small wetlands, locally significant habitats and lake and marine shorelines are not protected. s Shellflah beds and intertidal habitats are not protected. Unstable slopes are not adequately mapped, are not rated correctly for hazard level and are not protected with sufficient buffers and mitigating conditions, • Channel migration hazard zones for major rivers that meander across valley floors are not considered for protection. Scientific Information nseded to establish effective protection standards was provided by the Point No Point Treaty Council to the Board of County Commiesloners in letters dated November 30, 1993 (comments on draft 6 of ICAO) and March 31, 1994 (comments on draft 7 of ICAO). This Informatlon was not used in the development of the ICAO. 2-27 ! 2 (360) 297-260 (890) 478, 6) 484.7281 (840) 297-7097 Kingston Brtmtxmn seattie Fax T '.d 53: inOS38 1UH W071LITIS Dd Wd60:60 16, VT �,tW Comments on DEiS for Draft Jeff, Co. Comp, Plan From Port Gamble S'Klallam Tribe May 13, 1997 Page 2 of 2 The DEIS for the Draft Comprehensive Plan does not contain adequate informatic t because it does not discuss the impacts of county -wide development using an ordinance which provides inadequate critical areas protection, 2 The DEIS does not consider the impact of existing and potential county -owned roads that block fish passage to significant spawning and rearing habitats. County roads currently block access by coho, chum, steelhead, sea -run cutthroat, and resident cutthroat to significant historic spawning and rearing habitats. Washington Department of Fish and Wildlife (WDFW) has Identified 12 blockages as of May, 1997. An additional 10 blockages have been identified by the Hoh Tribe. Some of these blockages have been In existence for over 40 years, Blockages are generally caused by a culvert under the road which is under -sized, sloping or perched above the stream, blocking upstream fish migration. The existing blockages have resulted in a loss of minions of dollars of potential salmon production and represent a significant impact on declining salmon stocks, some of which may be in danger of extinction. The county has a clear legal responsibility to correct these fish passage problems under county -owned roads, yet has made little progress, Under an agreement between WDFW and the County, a comprehensive survey of county road culverts will be conducted by WDFW to be completed in 1999 and some cost -share money will probably be available from WDFW In 1998 to fix one or two blockages, However, the WDFW-county agreement falls far short of resolving Jefferson County's fish passage problems; especially considering that many more blockages may be found, particularly on the west end, Also, new blockages will continue to arise over time as some currently accessible road crossings erode at the outlet of culverts and form blockages. The County Comprehensive Plan does not address the fish blockage issue In the transportation section or in any other section. The DEIS needs to evaluate the Impacts to fish populations of this major oversight in the Comprehensive Plan. Sincerely, Peter Bahis vm Habitat Biologist cc Steve Hayden, Olympic Environmental Council Carol Bemthal, Point No Point Treaty Council Tim Rymer, Washington Department of Fish and Wildl Jerry Gorsline, Washington Environmental Council 4 . 2-28