Loading...
HomeMy WebLinkAboutC_MKrueger_WDFW_Public_Comment_250924 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 1 September 24, 2025 City of Renton Mariah Kerrihard, Associate Planner 1055 S Grady Way Renton, WA 98057 RE: Submittal ID 2025-S-9806, WDFW’s comments for Renton’s Critical Area Ordinance Amendments Dear Ms. Kerrihard, On behalf of the Washington Department of Fish and Wildlife (WDFW), thank you for the opportunity to comment on Renton’s draft Critical Area Ordinance (CAO) amendments as part of the current periodic update. Within the State of Washington’s land use decision-making framework, WDFW is considered a technical advisor for the habitat needs of fish and wildlife and routinely provides input on the implications of land use decisions. We provide these comments and recommendations in keeping with our legislative mandate to preserve, protect, and perpetuate fish and wildlife and their habitats for the benefit of future generations – a mission we can only accomplish in partnership with local jurisdictions. Table 1. Recommended changes to proposed code language. Code Section Code Language (with WDFW suggestions in red) WDFW Comment 4-3-050A Purpose 1. Manage development activities to protect environmental quality, promote diversity of species, and habitat within the City by regulating critical areas, including wetlands, aquifer protection areas, fish and wildlife habitat conservation areas, frequently flooded areas, and geologically hazardous areas as defined by the We recommend the adjacent edit to align with state language (WAC 365-196-830). Regulations must designate specific requirements for conserving and protecting Fish and Wildlife Habitat Conservation Areas (FWHCAs). 2 Growth Management Act and RMC 4-11. 4-3-050B Applicability 1. Lands to Which These Regulations Apply and Non- regulated Lands: c. Fish and Wildlife Habitat Conservation Areas. See comment above. 4-3-050B Applicability g. Sites Separated from Critical Areas, Nonregulated: As determined by the Administrator, these regulations may not apply to development proposed on sites that are separated from critical areas by pre-existing, intervening, and lawfully created structures, roads, or other substantial existing improvements. For the purposes of this Section, the intervening lots/parcels, roads, or other substantial improvements shall be found to: i. Separate the subject upland property from the critical area due to their height or width; and ii. Substantially pPrevent or impair the delivery of most all functions and values from the subject upland property to the critical area. To align this section with the Growth Management Act (GMA), all critical area functions and values must be protected (WAC 365-196-830). We recommend incorporating the adjacent edits in red to align with state standards. Additionally, we strongly recommend defining and incorporating terminology for functionally isolated critical area buffers. Specific information can be found in Ecology’s guidance document. For example, Woodinville outlines: “If a portion of a riparian management zone is determined to be functionally isolated and physically separated from the watercourse due to existing, legally established public roadways, railroads or other legally established structures or paved areas...the director may exclude this area from a riparian management zone provided: (i) The area does not provide any of the primary riparian management zone functions of bank stability, shade, pollution control, contributions of detrital nutrients, wildlife habitat corridor connection, or recruitment of large woody debris; (ii) To the extent feasible, the remaining areas within the riparian management zone are restored or enhanced to achieve a net gain in ecological functions; and (iii) A critical areas report confirms the area of the riparian management zone as being functionally isolated and physically separated from the watercourse, and WMC 21.51.120(6)(c)(i) is satisfied,” which can be found in the July 24th, 2025 planning commission packet. Riparian management zone (RMZ) is used here in place of stream buffers as recommended by WDFW’s best available science (BAS). 4-3-050C Exempt, Prohibited, and Nonconforming Activities ...Whether the exempted activities are also exempt from permits will be determined based upon application of chapters 4-8 and 4-9 RMC, or other applicable sections We recommend adding the adjacent language. Exempt activities are not exempt from meeting state requirements for no net loss of critical area functions and values (WAC 365-196-830, WAC 365-190-080). 3 of the Renton Municipal Code. All activities within shoreline jurisdiction are subject to Shoreline Master Program Regulations in RMC 4-3-090 and 4- 10-095. All exempt activities must comply with state requirements to ensure no net loss of critical area functions and values. Table: EXEMPT ACTIVITIES – PERMITTED WITHIN CRITICAL AREAS... General comment. We recommend assigning table numbers to tables throughout this document. Table: EXEMPT ACTIVITIES – PERMITTED WITHIN CRITICAL AREAS AND ASSOCIATED BUFFERS Footnote 8: Limited to cutting of dangerous trees; such hazardous trees shall be retained as large woody debris in critical areas and/or associated buffers, where feasible. Does your CAO include all of the following provisions? - define a “hazard tree” as a threat to life, property, or public safety, - require that the method of hazard tree removal not adversely affect riparian ecosystem functions to the extent practicable, - encourage the creation of snags (Priority Habitat features) rather than complete tree removal, - involve an avoidance and minimization of damage to remaining trees and vegetation within the RMZ, and - require a qualified arborist to evaluate requests for hazard tree removal Table: EXEMPT ACTIVITIES – PERMITTED WITHIN CRITICAL AREAS AND ASSOCIATED BUFFERS New Surface Water Discharge Marked exempt for Fish and Wildlife Habitat Conservation Areas (FWHCAs) and Stream and Lakes Discharging stormwater into streams, lakes, or wetlands can cause flooding, erosion, water quality degradation, and impacts to fish and wildlife, even if covered under stormwater permits. Even if an NPDES permit applies, site- level impacts (like discharge directly into a salmon stream) may still require critical area protections that stormwater codes alone don’t cover. At a minimum, we recommend including the need to seek other permits for these activities even if exempt within city code, such as WDFW’s Hydraulic Project Approval (HPA) permit. Table: EXEMPT ACTIVITIES – PERMITTED E(ii.) Maintenance, Operation, and Repair of existing Parks, Trails, Roads, Facilities, and Utilities, and the Construction of New Trails This section might include: Construction of new passive recreation facilities, including nonmotorized walkways and trails, footbridges, wildlife viewing structures or 4 WITHIN CRITICAL AREAS AND ASSOCIATED BUFFERS platforms, benches, informational or educational signs, and other similar facilities, meeting the following requirements. - Walkways, trails and footbridges shall be no more than five feet in width and are limited to the least impactful pervious surfaces, with preference for natural materials. Raised boardwalks utilizing nontreated pilings may be acceptable. - Placement of any facilities shall be located to avoid the removal of significant trees. - An area equal in size to the disturbed area shall be vegetated with site-appropriate native plantings at natural densities. - New facilities shall be located only in the outer 25 percent of the buffer or riparian management zone. - New passive recreation facilities that do not meet the above criteria shall require submittal of a critical areas report and mitigation plan. 4-3-050D ADMINISTRATION AND INTERPRETATION 5. Review Authority: C(ii.) Streams and Lakes: (a) Approve proposals for buffer width reductions. (b) Approve proposals for buffer width averaging. See comments below for 4-3-050H ALTERATIONS TO CRITICAL AREAS AND/OR BUFFERS – GENERAL REQUIREMENTS. 4-3-050E MAPS General comment We recommend that this section include information regarding the mapping of FWHCAs, such as WDFW’s Priority Habitats and Species (PHS) mapping information. This information is considered BAS under the GMA. For downloadable mapping layers, please visit our website. 4-3-050E MAPS 5. Streams and Lakes We recommend encouraging applicants to reach out to WDFW to confirm the fish-bearing status of a stream, especially if the city plans to retain different stream buffers based on fish-bearing status. 4-3-050F SUBMITTAL REQUIREMENTS AND FEES: 2(b.) Fish and Wildlife Habitat Conservation Areas: Based upon subsection G6 of this Section, Fish and Wildlife Habitat Conservation Areas, the City shall require a habitat/wildlife assessment for activities that are located within or abutting a critical habitat, defined in RMC 4-11-030, We strongly recommend reviewing this chapter in its entirety and replacing ‘Habitat Conservation Areas’ with the correct term, ‘Fish and Wildlife Habitat Conservation Areas’ (FWHCA). Additionally, streams/lakes are typically classified as a type of FWHCA and are included within these sections, as outlined in WAC 365-190-130. See the City of Anacortes’ FWHCA section as an example. We also recommend removing ‘significant,’ as all 5 or that are adjacent to a critical habitat, and have the potential to significantly impact a critical habitat. The assessment shall determine the extent, function and value of the critical habitat and potential for impacts and mitigation consistent with report requirements in RMC 4-8-120D. critical area functions and values require protection. 4-3-050F SUBMITTAL REQUIREMENTS AND FEES: 2(c.) Streams and Lakes: The applicant shall be required to conduct a stream or lake study pursuant to RMC 4-8-120 if a site contains a water body or buffer area and changes to buffer requirements or alterations of the water body or its associated buffer are proposed, either administratively or via a variance request. A stream or lake study is also required when the project area is within three hundred feet (300’) one hundred feet (100') of a water body even if the water body is not located on the subject property. We recommend revising this section to require stream or lake studies within 300 feet rather than 100 feet. A 100-foot threshold does not adequately capture the ecological processes streams and lakes depend on, including shading, water quality, and large woody debris recruitment. WDFW’s BAS (Riparian Ecosystems Vol. 1) supports wider riparian management zones, often up to 250 feet or larger, to ensure alignment with no net loss standards. Another approach may include basing the need for a stream or lake study on a watershed-scale analysis, recognizing that projects upslope or outside a narrow buffer can still significantly affect hydrology, water quality, and habitat functions downstream. For example, a project at the top of a slope that substantially increases impervious surfaces could worsen flooding and runoff for property owners downslope and degrade stream conditions hundreds of feet away. 4-3-050F SUBMITTAL REQUIREMENTS AND FEES: 7. Waiver of Submittal Requirements: ...a. Habitat Assessment: In cases where a proposal iswill not likely to significantly impact the critical habitat and there is sufficient information to determine the effects of a proposal, an applicant may request that this report be waived by the Administrator. b. Streams and Lakes: i. Stream or Lake Study: ...(a) A road, building or other barrier exists between the water body and the proposed activity that results in functional isolation, or (b) The water body or required buffer area does not intrude on As mentioned above, we recommend aligning this chapter with no net loss requirements. No impacts to critical areas can occur without mitigation sequencing. Additionally, we strongly recommend defining and incorporating terminology for functionally isolated critical area buffers. See comments for 4-3- 050B(g) Applicability above. 6 the applicant’s lot, and based on evidence submitted, the proposal will not result in significant adverse impacts to nearby water bodies regulated under this Section; or... 4-3-050G DEVELOPMENT STANDARDS: 2. Critical Area Buffers and Structure Setbacks from Buffers: Structure Setbacks from Buffers: The following critical area buffers and structure setbacks from buffers are established for each critical area. - Channel migration zones - Erosion Hazard Area Riparian management zones (RMZs or stream buffers) shall be located on both sides of the stream and measured from the channel migration zone if one is present. If one is not present, the RMZ should be measured from the ordinary high water mark (OHWM) per WDFW’s BAS and management recommendations. This section should explicitly state the need for RMZs (stream buffers) to be measured from the edge of channel migration zones (CMZs). Additionally, the Cedar River Channel Migration Study, April 2015, describes setbacks that should be in place from the erosion hazard area that is not reflected in this table. 4-3-050G DEVELOPMENT STANDARDS: 2. Critical Area Buffers and Structure Setbacks from Buffers: The following critical area buffers and structure setbacks from buffers are established for each critical area. - Streams and Lakes The widths in this table do not meet WDFW’s BAS standards for riparian areas. All streams, independent of fish use, shall have protection measures that ensure no net loss of ecological values and functions. WDFW’s current best available science standards and management recommendations outline the need to use the Site Potential Tree Height at 200 years (SPTH200) to measure riparian management zone (RMZ) widths (see WDFW’s mapping tool and field delineation guidance). RMZ terminology should replace “stream buffer,” as RMZs should be considered a critical area and not a buffer to a critical area. To stop pollutants from entering streams, RMZs must be 100 feet wide and fully vegetated at a minimum. Meeting RMZ standards is especially critical in highly developed areas like Renton, where elevated levels of impervious surface contribute to increased stormwater runoff and water quality degradation. The importance of addressing water quality concerns is demonstrated by the listing of many water bodies within the city on Ecology’s 303(d) list, which outlines a trend of continued degraded biological integrity over time. Several urban jurisdictions have already aligned with WDFW’s recommendations. For example, 7 King County is proposing urban stream regulations that include 180–200-foot buffers for Type S and F streams. Woodinville is similarly advancing amendments aligned with WDFW’s BAS. Shoreline is proposing a standard 200-foot width for all stream types. These examples illustrate how urban jurisdictions are proactively collaborating with WDFW to incorporate scientifically based standards. 4-3-050G DEVELOPMENT STANDARDS: 3(d.) Standards... iii. The City may require enhancement of native growth protection areas to improve functions and values, reduce erosion or landslide potential, or to meet another identified purpose of these critical area regulations. A common addition to this section that many jurisdictions are utilizing includes: “Standard riparian management zone widths presume the area is densely vegetated with a native plant community appropriate for the ecoregion, consisting of an average of 80% native cover comprised of trees, shrubs and groundcover plants. If the existing area is sparsely vegetated or vegetated with invasive species, the buffer must either be enhanced through an approved mitigation plan or increased by 33%.” This ensures that there is an incentive to enhance degraded RMZs. Covington (Planning Commission meeting), Woodinville (planning commission packet), Skagit County (meeting agenda packet (14.24.530)), and other jurisdictions all utilize some version of the above language to incentivize healthy critical area buffers. 4-3-050G DEVELOPMENT STANDARDS: 6. Fish and Wildlife Habitat Conservation Areas: a. Classification of Critical Habitats: Habitats that have a primary association with the documented presence of non-salmonid or salmonid species proposed or listed by the Federal government or State of Washington as endangered, threatened, sensitive and/or of local importance. (Ord. 5976, 8-3-2020) Please review WAC 365-190-130, which outlines the types of FWHCAs that require specific protection standards. See the City of Anacortes’ FWHCA section as an example. Within this section, we recommend designating the riparian management zone (RMZ) as a type of FWHCA. We also recommend designating wildlife habitat corridors here. WAC 365-196-335 states, “Each county or city planning under the [growth management] act must identify open space corridors within and between urban growth areas. They must include lands useful for recreation, wildlife habitat, trails, and connection of critical areas as defined in RCW 36.70A.030.” If a method for identifying wildlife habitat corridors has not yet been established, the resources below may be helpful: - Page 72-82 of WDFW’s Washington Habitat Connectivity Action Plan and mapping resource. 8 - Reach out to King County staff to investigate how their iMap determined the bounds of their ‘Wildlife Habitat Networks.’ - See the Bellingham wildlife corridor analysis as an example methodology for mapping these corridors at the local level. 4-3-050G DEVELOPMENT STANDARDS: 7. Streams and Lakes: (a). Classification systems: The following classification system is hereby adopted for the purposes of regulating Streams and Lakes in the City. This classification system is based on the State’s Permanent Water Typing System WAC 222-16- 030. Stream and lake buffer widths are based on the following rating system: WAC 222-16-030 and WAC 222-16-31 are used to classify streams for Forest Practices under the Forest Practices Board. These stream determinations are used for temporary impacts associated with Forest Practices in forested areas and are not designed to be used for regulations for urban or permanent impacts. WDFW’s BAS finds that all streams are important for ecosystem services and salmon recovery, regardless of whether or not they are fish-bearing. Type Np and Ns streams provide cold water, sediment regulation, and organic inputs that are critical to maintaining the physical, chemical, and biological integrity of downstream fish-bearing waters. Np and Ns streams often function as stormwater overflow channels, a role that becomes especially critical in highly urbanized areas where extensive impervious land cover increases flooding risks. The loss or degradation of Np and Ns streams through reduced buffer widths or unregulated disturbance leads to cascading effects on water quality, which has cascading impacts on fish- bearing waters downstream and public safety. For these reasons, we do not recommend utilizing the Forest Practice stream typing system as a mechanism to help establish RMZ widths based on fish use. 4-3-050G DEVELOPMENT STANDARDS: 7(b.) Non-regulated: Waters that are considered “intentionally created” not regulated under this Section include irrigation ditches, grass-lined swales and canals that do not meet the criteria for Type S, F, Np, or Ns Non-regulated waters may also include streams created as mitigation. Purposeful creation must be demonstrated through documentation, photographs, statements and/or other persuasive evidence. Streams created as mitigation for a project are intended to replace the ecological functions and values of the impacted critical area and therefore must be regulated as one. 9 4-3-050G DEVELOPMENT STANDARDS: 7(c.) Measurement: i. Stream/Lake Boundary: The boundary of a stream or lake shall be considered to be its ordinary high-water mark (OHWM) as defined in RMC 4-11. The OHWM shall be flagged in the field by a qualified consultant when any study is required pursuant to this subsection G7. RMZs (stream buffers) shall be located on both sides of the stream and measured from the channel migration zone if one is present. If one is not present, the RMZ should be measured from the ordinary high water mark (OHWM) per WDFW’s BAS and management recommendations. 4-3-050G DEVELOPMENT STANDARDS: D(i)(b) Piped or Culverted Streams: (1) Building structures over a natural stream located in an underground pipe or culvert except as may be granted by a variance in RMC 4-9-250 are prohibited. Transportation or utility crossings or other alterations pursuant to subsection J of this Section are allowed. Pavement over a pre-existing piped stream is allowed. Relocation of the piped stream system around structures is allowed... (2) No buffers are required along segments of piped or culverted streams. The City shall require easements and setbacks from pipes or culverts consistent with stormwater requirements in RMC 4-6-030 and the adopted drainage manual. If a piped stream segment is not currently covered by pavement, we recommend prohibiting new pavement in these areas. The long-term goal should be to daylight streams where feasible. Additional paving would only create further obstacles to achieving that outcome and would likely result in a net loss of critical area functions and values. Additionally, due to age and environmental factors, piped stream segments will eventually fail and need to be replaced in compliance with current fish passage standards, as required by state law (WAC 220-660-190). With no buffer for these stream segments, future restoration efforts and infrastructure maintenance will be difficult to achieve. Development placed too close to piped stream segments may perpetuate non-conforming structures and increase public safety hazards related to flooding and erosion as storm intensities increase. A wider buffer for piped segments would provide better stormwater management support, water quality protections, and provide enough space to allow flexibility to meet state requirements for fish passage and/or flow capacity of water crossing structures (e.g., culverts) when aging infrastructure needs to be updated. 4-3-050H ALTERATIONS TO CRITICAL AREAS AND/OR BUFFERS – GENERAL REQUIREMENTS: 2. Authority and Documentation of Required Findings: Based upon an applicant’s request, and the acceptance of a wetland and/or stream or lake study, mitigation and enhancement plan, the Administrator may approve an alteration to the minimum buffer widths where the applicant can demonstrate that through We do not recommend stream buffer (RMZ) reductions or averaging. WDFW has found no scientific evidence supporting the idea that reducing a riparian buffer in one area while expanding it elsewhere achieves no net loss of ecological functions and values. WDFW’s Riparian Ecosystems, Volume 1: Science Synthesis and Management Implications (2020) shows that riparian buffer widths are established based on the specific ecological functions they are intended 10 enhancing the buffer and the use of low impact development strategies the reduced buffer will function at a higher level than the standard buffer. Determinations and evidence shall be included in the application file. The City shall also evaluate all proposals using the following criteria, in the order below. The development plan will: to support, which are directly tied to the width, continuity, and quality of vegetation within the buffer. If buffer averaging is retained, we strongly recommend adding a provision that no portion of the buffer may be reduced below 100 feet. Scientific research compiled in WDFW’s Best Available Science demonstrates that 100 feet is the minimum width necessary to provide basic functions such as pollution filtration. Allowing buffers narrower than this threshold would compromise water quality protection and fail to meet no net loss standards. An additional provision could specify that buffer averaging may only occur in portions of the stream buffer that currently provide no ecological function, such as paved parking lots. Importantly, areas with even limited function, such as a blackberry patch, should not be considered for averaging, as these types of areas still contribute ecological value. 4-3-050H ALTERATIONS TO CRITICAL AREAS AND/OR BUFFERS – GENERAL REQUIREMENTS: 2. Authority and Documentation of Required Findings: a. Avoid any disturbances to the critical area or buffer; b. Minimize any critical area or buffer impacts; c. Compensate for any critical area or buffer impacts; d. Restore any critical area or buffer temporarily impacted or lost; e. Create new critical areas and buffers for those lost; and f. Enhance an existing degraded buffer to compensate for lost functions and values in addition to restoring or creating a critical area. The adjacent section references the mitigation sequence, as defined in WAC 197-11-768. We strongly recommend elevating this into its own section so that it applies across the entire chapter, rather than being limited to situations where buffer width reductions are requested. The mitigation sequence is intended to guide all decisions related to potential impacts on critical areas and should serve as the overarching framework for how impacts are addressed. Importantly, the first step in this sequence is avoidance, which must be proven to the fullest extent. Language commonly found to help guide avoidance includes: “All feasible and reasonable measures as determined by the department have been taken to avoid impacts, including, where applicable; I) Alternative building locations on the property; II) Adjustments to the project footprint and orientation; III) Modification of setbacks, where feasible, as a first option before encroaching into critical areas or their buffers; IV) Multi-story design or alternate building design” 11 This should be required within all critical area reports. 4-3-050H ALTERATIONS TO CRITICAL AREAS AND/OR BUFFERS – GENERAL REQUIREMENTS: 3. Studies Required: The City’s determination shall be based on specific site studies by recognized experts. Impacts and mitigation shall be based on consideration of Wetland Mitigation in Washington State Part 1: Agency Policies and Guidance, Version 2 (Ecology Publication No. 21-06-003, April 2021) and Calculating Credits and Debits for Compensatory Mitigation in Wetlands of Western Washington (Ecology Publication No. #10-06-011, March 2012). This section highlights the need to organize this chapter by critical area type. By doing so, each type of critical area can have unique requirements that align with the needs of that critical area type. The adjacent section calls for the wetland mitigation document to apply across all critical area types, as currently worded. 4-3-050I ALTERATIONS TO CRITICAL AREAS BUFFERS: Streams and Lakes See comments for 4-3-050H ALTERATIONS TO CRITICAL AREAS AND/OR BUFFERS – GENERAL REQUIREMENTS: (2) above. 4-3-050J ALTERATIONS TO CRITICAL AREAS: 2. Alterations Within Streams and Lakes or Associated Buffers. ...Construction of vehicular or non- vehicular transportation crossings may be permitted in accordance with an approved stream/lake study subject to the following criteria: i. The proposed route is determined to have the least impact on the environment... ii. The crossing avoids the minimizes interruption of downstream movement of wood and gravel; and... Alterations follow the mitigation sequence and outline how avoidance of impacts was considered. This is an example of a section that would benefit from inclusion of the mitigation sequence. 4-3-050L MITIGATION, MAINTENANCE AND MONITORING: b. Mitigation Sequencing This provision should be placed earlier in the chapter and applied consistently across additional sections. 4-3-050L MITIGATION, g. When Stream or Lake Mitigation Plan Is Required: This section should clearly state the preference for on-site, in-kind mitigation over off-site mitigation 12 MAINTENANCE AND MONITORING: (a) On-Site Mitigation: On-site mitigation is required unless a finding is made that on-site mitigation is not feasible or desirable; for RMZs. Fish-bearing streams rely on intact ecosystem functions and values, such as shading, large wood recruitment, filtration, and habitat connectivity, precisely where they occur. These functions cannot be replicated elsewhere, as aquatic species depend on them across the watershed for survival and recovery. Off-site or mitigation banking may provide some benefits, but it does not often replace the localized functions critical to maintaining fish populations and overall watershed health. Please review WAC 220-660-080 4. b. for guidance that specifies WDFW’s requirements. For more information, please review the document State of Washington Alternative Mitigation Policy Guidance For Aquatic Permitting Requirements from the Departments of Ecology and Fish and Wildlife. 4-3-050L MITIGATION, MAINTENANCE AND MONITORING: G(iii.)(a) Equivalent or Greater Biological Functions: The Administrator shall utilize the Washington Department of Fish and Wildlife’s Best Available Science document, “Riparian Ecosystem, Volume 1: Science Synthesis and Management Implications,” and management recommendations document, “Riparian Ecosystems, Volume 2:Management Recommendations” the report “City of Renton Best Available Science Literature Review and Stream Buffer Recommendations” by AC Kindig and Company and Cedarock Consultants, dated February 27, 2003, unless superseded with a City-adopted study, to determine the existing or potential ecological function of the stream or lake or riparian habitat that is being affected... We strongly recommend consulting WDFW’s recent BAS document and management recommendations for riparian areas as mentioned in comments above: - WDFW’s Riparian Ecosystems, Volume 1: Science Synthesis and Management Implications - WDFW’s Riparian Ecosystems, Volume 2: Management Recommendations Thank you for taking the time to consider our recommendations to better reflect the best available science for fish and wildlife habitats and ecosystems. We value the relationship we have with your jurisdiction and the opportunity to work collaboratively with you throughout this periodic update cycle. If you have any questions or need our technical assistance or 13 resources at any time during this process, please don’t hesitate to contact me or the Regional Land Use Lead, Morgan Krueger (morgan.krueger@dfw.wa.gov). Sincerely, Marcus Reaves, Regional Habitat Program Manager (Marcus.Reaves@dfw.wa.gov) CC: Morgan Krueger, Regional Land Use Lead (Morgan.Krueger@dfw.wa.gov) Kara Whittaker, Land Use Conservation and Policy Section Manager (Kara.Whittaker@dfw.wa.gov) Marian Berejikian, Land Use Conservation and Policy Planner (Marian.Berejikian@dfw.wa.gov) Stewart Reinbold, Assistant Regional Habitat Program Manager (Stewart.Reinbold@dfw.wa.gov) Bethany Scoggins, Habitat Biologist (Bethany.Scoggins@dfw.wa.gov) Region 4 Southern District Planning Inbox (R4SPlanning@dfw.wa.gov) Ted Vanegas, WA Department of Commerce (Ted.Vanegas@commerce.wa.gov)