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cTn, f• <br />State of Washington <br />DEPARTMENT OFFISH AND WILDLIFE <br />South Central Region • Region 3 • 1701 South 24t' Avenue, Yakima, WA 98902.-572t'� <br />Telephone: (509) 575-2740 . Fax: (509) 575-2474 <br />July 22, 2024 <br />Jamey Ayling <br />Kittitas County Community Development Services <br />411 N. Ruby Street, Suite 2 <br />Ellensburg, WA 98926 <br />SUBJECT: WDFW COMMENTS ON DV-24-00001 <br />Dear Mr. Ayling, <br />Thank you for the opportunity to comment on DV-24-00001 concerning the request for a <br />development agreement for 30 years from the approval date for Swauk Creek Planned Unit <br />Development (z-06-27). Washington Department of Fish and Wildlife (WDFW) has reviewed the <br />application and supporting documents. Our comments are regarding the project's impact on priority <br />fish and wildlife habitats, particularly the riparian habitat of Swauk Creek and its associated <br />floodplain. Specifically, our comments are to ensure that if the application is approved that the <br />development will not result in loss of Fish and Wildlife Habitat Conservation Areas (FWHCA) <br />under Kittitas County Critical Areas Ordinance (CAO). <br />The Master Site Plan, submitted as part of the review, shows recreational elements potentially in <br />both the riparian area and floodplain. These elements may contain some passive recreation, but <br />various infrastructure elements are listed, including campgrounds, event centers, parking, <br />equestrian boarding, employee housing, and shop facilities. These activities are likely to have <br />impacts to the riparian area and floodplain of Swauk Creek through either vegetation removal <br />and/or prevention of future riparian and floodplain vegetation recruitment. Swauk Creek is a <br />critical stream to various fish and wildlife species and is one of the primary streams identified in <br />the Yakima Steelhead Recovery Plan (YBFWRB 2009). Streamside recreation and increased <br />development in the riparian area and floodplain are both called out under limiting factors in the <br />plan. <br />While the original site plan was authorized under a previous Critical Areas Ordinance (CAO) <br />and Shoreline Management Plan (SMP), those previous standards do not meet the current <br />standards of Best Available Science, nor are consistent with the current CAO and SMP. Under <br />the current CAO, Swauk Creek is a fish -bearing stream within the Cascade Ecoregion and within <br />the jurisdiction of the Kittitas County SMP. The Riparian Management Zone (RM[Z) is defined <br />here under Kittitas County Critical Areas Code as 150 foot. <br />WDFW requests that if the development agreement is extended, as is proposed, that all <br />development activities within the SMP and CAO riparian areas and floodplains be held to the <br />current CAO and SMP standards. Both the CAO and SMP standards are to ensure no net loss of <br />