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HomeMy WebLinkAboutLog029 ~ '--/ J' State of Washington DEPARTMENT OF FISH AND WILDLI Region 6 Office: 48 Devonshire Road - Montesano, Washington 9856~9618 - ( ~~; ~o~ @ ) 249 --- EFFERSON COUNTY OfPT. Of COMMUNITY DEVELOPMENT September 12, 2000 Jefferson County ATTENTION:fushPcte~ DCD 621 Sheridan Street Port Townsend, Washington 98368 Dear Mr. Peters: SUBJECT: State Environmental Policy Act Document; ,Olympic Discovery Group Proponent, Marina Expansion, Port Ludlow Bay, Tributary to Admiralty Inlet, Jefferson County, WRIA 17.MARI The Washington Department ofFish and Wildlife (WDFW) has reviewed the above-referenced State Environmental Policy Act (SEP A) document received on 28 August 2000, and offers the following comments at this time. Other comments may be offered as the project progresses. The project includes the addition of 100 new slips to the Port Ludlow Marina. The WDFW is now responsible for managing habitat for federally listed saImonid species, including Hood Canal summer chum and Puget Sound chinook. The proposed marina expansion offers significant risk to critical habitat used by both of these species, as well as other saImonids. Specifically: I)Both Hood Canal summer chum and Puget Sound chinook use shorelines of the subject property as a migratory corridor; 2) Port Ludlow Creek, just west of the proposed expansion, is an important saImonid resource that has showed declines in use over the last 15 years; 3) Sand lance and surf smelt, collectively known as baitfish, and cited by state law as critical saImonid food resource, are documented to spawn adjacent to the subject property., and 4) Nearshore areas within the existing marina are indicating severe water quality problems, including anoxia and ulvoid blooms. These impacts will only increase with expansion. Project impacts to these critical resources and habitats include: 1) Significant increase in overwater structure from both marina and boats in nearshore areas; 2) Decreased water quality and increased pollution due to both increased boat volumes and decreased flushing from additional overwater structure, and; 3) Increased scour in nearshore from increased boat volume (particularly in the fuel dock area). These are top priorities for concern, and should be addressed. WDFW feels potential adverse impacts to finfish resources from this marina expansion should be thoroughly addressed in' the project design before the project is approved. To summarize: there are two ESA species, and a number of other critical species, that use tidelands of or immediately adjacent to the subject property. The project, as currently designed, LOG ITEM L t". # z,1 ;' . _,page of_ " <', ~, -- Mr. Peters September 12, 2000 Page 2 will negatively affect critical habitat of these species, which the WDFW is mandated to prevent through both state WAC and federal Endangered Species Act (Section 10 and Section 7). Specifically, overwater structure from both marina and boats in nearshore areas, disruption of migratory corridor for fish using Port Ludlow creek and nearshore Port Ludlow Bay, further degraded water quality and increased pollution from increased boat use and limiting of flushing, and increased scour in nearshore from increased boat volume (particularly in the fuel dock area) are top priorities for concern, and should be addressed to eliminate, or otherwise mitigate, impacts as defined by WAC 220-11 0-020(41). Specifically, reducing overall overwater structure, (including decreasing number of slips and dock widths), assessing impact of marina to fish migration along the nearshore as well as to and from Port Ludlow cree~ and decreasing nearshore fueling activities are suggested areas to start with. Thank you for the opportunity to provide these comments. If you have any questions, please contact me at (360) 457-2634. Sincerely, I~~ 1. Anne Shaffer Area Marine Habitat Biologist JAS:jas:00E7804.01s cc: SEP A Coordinator, WDFW SEPA Coordinator, Ecology WRIA File, Olympia CoE (Gossett) DNR Olympic (Shreck) NMFS (Longenbach) Jefferson County (Peters) DoE shorelines (Stewart) # " ,,..;..; ITEM '?( , Page 2- ~ot~- ... "--'