WDFWJuly 28, 2008
Mr. Grant Beck
City of Yelm Development Services
105 Yelm Avenue West
Yelm, Washington 98597
SUBJECT: Thurston Highlands Master Planned Community; Draft EIS Review Comment Letter
Dear Mr. Beck:
I apologize for the last minute response, which will require me to send this letter by email. Due to a lack of time available to review and comment on the subject DEIS, I was only able
to review the Fish and Wildlife Species and Habitats Inventory, Impacts and Mitigation Recommendations report prepared by The Coot Company, April 2008. I shall only be able to provide
comment regarding the natural drainages and potential fish use.
The Coot Company report indicates that several mapped drainages associated with the subject property are erroneously mapped and/or classified for fish use. This shall require an informal
or formal process to verify the findings in order to make the necessary Water Typing Modifications through Washington Department of Natural Resources (WDNR).
Since stream / wetland types dictate the appropriate critical area buffers for habitat protection, the Washington State Department of Fish and Wildlife (WDFW) respectfully requests an
informal field review of the mapped and potential unmapped natural drainage courses on the subject property. This informal review shall be made by WDFW (myself), WDNR (Regional
Forest Practices forester), Washington Department of Ecology (Wetlands and Shorelands Specialist) and the affected tribe(s).
The Coot Company has indicated that no fish occurrence was documented within the Thurston Highlands project area. WDFW requests further testimony as to how this was determined. This
argument shall be necessary in order to substantiate the need to down-grade certain stream types through the WDNR process.
WDFW realizes that the much of Thompson Creek drainage is prone to cessation, but arguably, there are perennial sections of stream / wetland habitat that should be considered refuge
habitat during the low flow periods of year. Since trout and other fish are opportunistic, I am of the opinion that during fall/winter high flow periods in the Thompson Creek watershed,
fish and other aquatic resources are migrating to and from the existing habitat on the subject property.
Based on the current hydraulic connectivity from wetland H and channel 4 (including the wetland A complex) to channel 7, the potential for resident trout use the habitat on the subject
property appears to exist. Furthermore, the wetland and natural drainage connectivity of channel 4 / wetland A appears to afford the three-spine stickleback fish to migrate to the available
low gradient stream and wetland habitat that exists on the subject property. As stated on page 18 of the Coot Company report, the future additional groundwater input to the Thompson
Creek, should have a beneficial affect on the habitat within Thompson Creek (channel numbers are from fig. 2 of the Coot Company report).
In closing, I believe that the informal field review for the necessary stream typing modification process (conducted by all affected parties) will allow for the reasonable conclusions
as to what the appropriate designation of the stream and wetland habitat should be on the WDNR maps and the Thurston Highlands property.
Please contact me at 360-902-2579 or kunzjpk@dfw.wa.gov in order to arrange for the stream typing modification review process.
Sincerely,
Jason Kunz