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Page 2 17A.04.030. Riparian management zones and buffers. • The section is titled riparian,but refers to both riparian and upland (terrestrial) habitats. Please clarify this applies to all FWHCA, both terrestrial and aquatic or split the terrestrial into its own section. • 17A.04.030 (8) (a). Any reduction or averaging of the RMZ should be recorded on the deed to ensure that these decisions are reflected in future decisions. • 17A.04.030 (10) (a) Add that agencies of expertise such as WDFW should be consulted prior to making the decision on whether the road or development creates a true interruption of all buffer functions. 17A.04.040. General protection standards. • 17A.04.040 (2) The mitigation requirement references 17A.04.030. We recommend that this be changed to reference 17A.04.070 which speaks to mitigation requirements. • 17A.04.050 (1) Provide reference that any clearing and grading in a fish and wildlife conservation area must be preceded by a CAO report and mitigation sequencing to offset the impacts. 17A.04.050. Permitted alterations and development. • 17A.04.050 (8) Add that the onsite sewage system must be placed outside of the Ordinary High Water Mark(OHWM) and the applicant must demonstrate that there will be no hydraulic connection to the aquatic habitat if placed in RMZ. This is to protect water quality of the aquatic habitat. 17A.04.070. Mitigation requirements. • The section is generally geared at riparian mitigation. The CAO should either make riparian mitigation its own category and separate from other FWHCA or add in other FWHCA such as shrubsteppe. • 17A.04.070 (2) Mitigation for impacts to RMZs should be within the RMZ. Mitigation outside of the RMZ should be treated as out of kind in mitigation sequencing and either discouraged or requiring a higher mitigation rate than in kind mitigation. • 17A.04.070 (3) States that impacts to RMZ shall be mitigated at a minimum of 1:1. A ratio of 1:1 will not fully offset spatial and temporal losses of riparian function(i.e., will not meet no net loss). Suggested change is "shall be mitigated at greater than a 1:1 ratio to account for spatial and temporal losses and shall be guided by site conditions and recommendations from WDFW" Thank you again for the opportunity to comment. Please contact Scott Downes at 509-607-3578 or Scott.Downes@dfw.wa.gov or Danny Didricksen at 509-571-559 or daniel.didricksen(d),dfw.wa.gov to set up a time to discuss these comments. Sincerely, r � Danny Didricksen WDFW Region 3 Habitat Program Manager