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Home My WebLink AboutLog154 l e e State of Washington DEPARTMENT OF FISH AND WilDLIFE Region 6 Office: 48 Devonshire Road - Montesano, Washington 98563-9618 - (360) 249-4628 October 3,2002 (5), IE ~ IE n 'W IE ~ llIl NOV -, 2002 lW Reid Middleton, Inc. ATTENTION: Nicole Faghin 728 134th Street SW Suite 200 Everett, W A 98204 JEFFERSON COUNTY DEPT. OF COMMUNITY DEVELOPME.NT Dear Ms. Faghin: SUBJECT: Mitigation Plan; Port Ludlow Marina Expansion, Port Ludlow Bay, Tributary to Puget Sound, Jefferson County Washington Department of Fish and Wildlife (WDFW) has reviewed the revised drawings for the Port Ludlow Marina Expansion received September 30, 2002, and offers the following comment at this time. Other comments may be offered as the project progresses. WDFW has evaluated the application for the proposed marina expansion under RCW 77.55.100 which outlines a clear mitigation sequence of: 1. avoidance of impacts is the highest mitigation priority then, 2. minimization of impacts by limiting the degree or magnitude of the action and lastly, 3. compensation of unavoidable impacts through restoration, creation and enhancement or a combination. The goal of RCW 77.55.100 is no net loss of habitat functions and values and net gain through restoration, creation and enhancement. Since adverse impacts of the marina expansion to intertidal and subtidal habitat cannot be avoided or minimized sufficiently to achieve no net loss of habitat functions or values, a mitigation plan should be submitted for review by WDFW. The white paper, Overwater Structures: Marine Issues (Nightingale and Simenstad, 2001) identified a number of potential adverse impacts from pilings and floating docks. WDFW recognizes the proposed project incorporates several design elements to avoid the necessity of making up for lost habitat. However, the proposed project will result in additional substrate changes from the new floats and associated piling that are unavoidable. Dock pilings result in a direct loss of benthic habitat previous used by biota. In addition, shellhash accumulating at the base of the piling due to sea star predation on mussels and other shellfish results in changes to the biologic community. Although floating docks and piers support a large number of organisms, they are not preferred prey for juvenile salmonids which are epibenthic feeders. The Puget Sound ~ -\;'~ r~:: Tv~j ""~,",,,,_1~~__,,,,,,,,._~,,.,.",. ".~~,..._l_._.,. ..:~...._... , e - Ms. Faghin October 3,2002 Page 2 Expedition conducted by Cohen surveyed 26 marinas and identified 39 non-indigenous species living on the floats. The expedition concluded the biotic communities on the floats were encrusting and usually dominated by mussels and ulva and with the exception of pile perch, the floating community did not reflect habitat rich in prey resources for juvenile salmonids or other teleost fishes. The magnitude of the shade and loss of benthic habitat on primary production supporting prey resources would be determined, in part, by depth, structure size and design and water clarity. WDFW recognizes the proposed project concentrates the expansion in deeper water with a net increase of 1330 square feet of overwater coverage in less than -20 feet MLLW and a net increase of 37,400 square feet of overwater coverage in greater than -20 feet MLLW. However, the eelgrass survey of the fuel dock and D dock conducted September 12, 2001 did document macro algae to a depth of -32 ft MLLW. It appears, WDFW does not have a record of a eelgrass/macroalgae survey for the entire area of the proposed expansion (September 24, 2002 plan view). Please contact me to discuss conducting a eelgrass/macroalgae survey to document vegetation present in the vicinity of the proposed expansion or forward me the survey results and corresponding documentation if the survey has been conducted. When evaluating compensatory mitigation, WDFW considers the following guidelines: · On-site, in-kind mitigation is the highest priority, followed by, in decreasing priority, off- site, in-kind; on-site, out of kind; and off-site, out of kind. · For off-site mitigation to be accepted, the project proponent must demonstrate that greater habitat function and value can be achieved off-site than on-site. · For off-site fish mitigation, mitigation must occur in the same WRIA as the impacts. · Project proponents have the ability to request off-site mitigation for hydraulic projects. For federal endangered or threatened species, mitigation must occur within the habitat supporting the same Evolutionary Significant Unit (ESU). · Proven mitigation techniques must be used. · Mitigation must proceed along with project construction. · The landowner and WDFW will determine impacts and mitigation. · Cumulative impacts of projects must be considered. · Project proponent pays mitigation costs. . Mitigation should be protected for the life of the project. WDFW will evaluate the plan to determine whether the mitigation provides equal or better habitat functions, values, compared to the existing conditions. ~-.. .,'"~-"!~ ,._"~ _._"-;:.'-.-' . -....."''''" ,~"-:.,L...'"~"".~-__ J e - M ~ .. .I Oi Mmcd' / ff~ Page ~ Thank you for the opportunity to provide this information. If you have any questions or want to discuss potential compensatory mitigation, please contact me at (360) 895-6123. Sincerely, Randi L. Thurston Area Habitat Biologist RL T:r1t:GC- E7804-04 cc: Shandra O'Halleck, NMFS Bob Burkle, WDFW Steve Kalinowski, WDFW Josh Peters, Jefferson County Mark Dorsey, Port Ludlow Associates ..c.,...L~.u -""","..J",...,,,,,,...~",,,",,,,,,_,.,,",,_. a.... ". :?z >'h""""""''-''-u'" -:..',,:",;..:', - .""-..-, 'W_ '..,.,_~