April 28, 1997
City of Chehalis
Robert Nacht, Community Development Division
Community Services Dept.
P.O. Box 871
Chehalis, WA 98532

SUBJECT: Mitigated Determination of Non-Significance (MDNS, Log Number 197-11-970), Elaine Clark, 25,000 cubic yards of fill for commercial development at 821 West Main Street, Chehalis, Washington, along Dillenbaugh Creek in Lewis County.

Dear Mr. Nacht:

We have received the above reference MDNS and appreciate the opportunity to comment. I would like to begin our response by referencing a letter sent to you on March 22, 1993 by Mike Barber, former Department of Fisheries Area Habitat Biologist. Mike's comments were made in a written response to a SEPA determination (SEPA Log No. 21391) issued by the City of Chehalis for a similar fill project at 750 West Main Street adjacent to the current proposal.

"Given the flood problems that have occurred in the Centralia-Chehalis area over the last several years,, it is difficult to understand the continuous permitting of filling in the floodplain by local officials. This is especially perplexing given that funding is being sought by these same jurisdictions for flood control projects that may have significant adverse impacts to fish life and habitat as well -as downstream residents."

"Filling in the floodplain displaces water and can increase the extent and duration of flooding elsewhere. This transfer of flooding effects can impact fish life and habitat by altering stream channel configuration and flow dynamics. 'This can also lead to an increase in bank protection and flood protection projects which may have negative impacts on fish life and habitat."

"The past and present practice of not restricting filling in tile floodplain will be taken into consideration when reviewing projects that are proposed to alleviate flooding problems or to repair damage caused by flooding."

Unfortunately, over four years later, local jurisdictions are continuing to permit fill within the floodplain. Permitting this activity is especially discouraging in light of the recent Hydraulic Project Approval Application submitted by the City of Chehalis Public Works Department to remove illegally placed concrete ecology blocks from Dillenbaugh Creek. The Public Works Department alleges that the ecology blocks are causing water from Dillenbaugh Creek to backup into the City's storm water system and cause public safety concerns, i.e., exposing manholes by causing manhole lids to be lifted. Has the City of Chehalis evaluated what the permitting of 25,000 cubic yards of fill in the floodplain of Dillenbaugh Creek (within 200 feet of the ecology blocks) will do to city storm water problems?

Even though the Department of Fish and Wildlife has no authority to regulate activities outside of the ordinary high water mark we do not condone filling in the floodplain. This site is within the floodplain of Dillenbaugh Creek. The placement of fill within this area will have off-site impacts. The Dillenbaugh Creek watershed has been the recipient of intensive efforts on the part of the Lewis County Conservation District (LCCD), Chehalis River Council (CRC), United States Fish and Wildlife Service (USFWS), and Chehalis Basin Fisheries Task Force (CBFTF) to improve water quality and fish and wildlife habitat within the basin. Funding and technical support for this endeavor has been provided by Washington Department of Ecology (WDOE), USFWS, Washington Department of Fish and Wildlife (WDFW), Washington Department of Natural Resources (WDNR), and CBFTF. Labor has been provided by local school children and volunteers from the local community. At a public meeting held by the CRC, on March 10, 1993, for residents of the basin, there was strong support for the restoration of the watershed. A number of property owners have volunteered to have projects constructed on their property and most have contributed materials, money, and labor towards the projects.

WDFW has conducted an extensive review of the scientific literature and has developed management recommendations for riparian habitat. We recommend that along Type I and I+ waters such as Dillenbaugh Creek, a minimum 325-foot vegetated buffer be established to protect fish and wildlife habitat. Riparian habitat is utilized by approximately 90 percent of Washington wildlife and supports a high fish and wildlife diversity by providing essential food, cover, water, and space needs during all times of the year. It is important seasonal habitat because of its moist and mild microclimate, and it provides movement corridors between ecosystem types. Riparian areas are essential to healthy, productive fish habitat and aquatic systems and enhance the value and utility of upland habitats for wildlife. Riparian areas also have important social values, including water purification, flood control, recreation, and aesthetics.

Dillenbaugh Creek currently provides spawning and rearing habitat for coho salmon, steelhead, and cutthroat trout. The portion of the creek along the proposed project area is primarily used as overwintering habitat. During the winter, while in fresh water, coho salmon seek out off-channel areas, such as beaver ponds, wetlands, side channels, and back-water areas for rearing habitat. Summer use near the project area is limited due to high stream temperatures.

We recommend that this project be denied as proposed due to the reduction of flood water storage capacity and the associated negative impacts on fish and wildlife populations. We appreciate your cooperation in our efforts to protect, perpetuate and manage the fish and wildlife resources of the State of Washington. If you have any questions please call me at (360) 664- 4672.

Andy Carlson
Area Habitat Biologist

cc: Bryan Cowan, WDFW
Jane Banyard, WDFW
Anna Bruce, WDFW
Jo Sohneronne, DOE
Barbara Ritchie, DOE Back to Index Page
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