HomeMy WebLinkAboutC_WDFW Comments
State of Washington
Department of Fish and Wildlife, Region 4
Region 4 information: 16018 Mill Creek Blvd, Mill Creek, WA 98012 | phone: (425)-775-1311
June 11, 2025
City of Renton
ATTN: Jill Ding
jding@rentonwa.gov
Dear Jill Ding,
We would like to discuss the Raabe Townhomes project (SEPA # 202502225) located at 8225 S
132nd St, Renton, WA 98059, on behalf of Jessica Bruce. The Washington Department of Fish
and Wildlife (WDFW) is responsible for preserving, protecting, and perpetuating the state’s fish,
wildlife, and ecosystems while providing sustainable recreational and commercial opportunities
for fish and wildlife. Recognizing our responsibilities, we will submit the following comments for
Raabe Townhomes. Other comments may be offered in the future.
Fish and Wildlife Resources and Recommendations:
• The applicant proposes to reduce the buffer on an on-site regulated stream to 40 feet
with a development within a critical area. Given the proximity of these developments to
a stream meeting the criteria for salmonids, the Department is concerned that reducing
the buffer distance on the tributary to Lake Washington and Cedar River may adversely
impact fish and their aquatic habitat (WAC 220-660-100). Per the City of Renton’s
Critical Areas Ordinance, this proposed buffer does not meet your F-type stream's
required buffer setback area. The plans denote a Type Ns stream, but based on our
report extracted from the Washington Department of Fish and Wildlife’s (WDFW) Fish
Passage and Diversion Screening Inventory Database (FPDSI), the stream located on the
south side of the project site is listed as a fish-bearing stream. More information on
these reports can be found on the WDFW Fish Passage map.
• Per the Department’s management recommendations, riparian vegetation should be
retained to its fullest potential. We recommend restoring the riparian buffer to the
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“site-potential tree height” of the dominant tree species at age 200 years (SPTH200).
Riparian areas provide shade, pollutant removal, bank stabilization, and habitat for
aquatic and terrestrial species. To ensure no net loss (WAC 220-660-080) of ecological
functions and values occurs (WAC 365-190-080), WDFW recommends a minimum buffer
width of 202 feet, or a width of 100 feet for the function of pollution removal,
whichever is larger. More information about recommended riparian management
zones and SPTH can be found in "Riparian Ecosystems, Volume 2: Management
Recommendations" on the WDFW website.
• Additionally, if the mitigation sequence (WAC 197-11-768) is assessed and avoidance of
impacts is infeasible, then considering the benefits lost from the removal of mature
trees, our recommendation is a minimum replacement ratio of 3:1.
Thank you for taking the time to consider our comments on this proposal, which aim to better
align it with state regulations and the best available science for fish and wildlife habitats and
ecosystems. If you have any questions or need our technical assistance or resources during this
process, please do not hesitate to contact me or Julian Douglas (206.584.9808 or
julian.douglas@dfw.wa.gov).
Sincerely,
Beck Sessa
Biologist, Habitat Division
Washington Department of Fish and Wildlife
R4Splanning@dfw.wa.gov
425.651.9790
Cc: Stewart Reinbold, Assistant Regional Habitat Program Manager (Stewart.Reinbold@dfw.wa.gov)
Morgan Krueger, Regional Land Use Planner (Morgan.Krueger@dfw.wa.gov)
Julian Douglas, Habitat Biologist (julian.douglas@dfw.wa.gov)
Beck Sessa, Habitat Biologist 2 (R4Splanning@dfw.wa.gov)