2021-8-31_WDF_Leslie_King
STATE OF WASHINGTON
DEPARTMENT OF FISH AND WILDLIFE
2315 N Discovery Place • Spokane Valley, Washington 99216-1566 • (509) 892-1001 FAX (509) 921-2440
August 31, 2021
City of Spokane Valley
Attn: Lori Barlow
10210 E. Sprague Avenue
Spokane Valley, WA 99206
RE: Painted Hills Planned Unit Residential Development Project, project file numbers
PRD-2015-0001, SUB-2015-0001, EGR-2016-0066 and FPD-2016-0007. Draft
Environmental Impact Statement
Dear Lori,
The Washington Department of Fish and Wildlife (WDFW) would like to submit the
following comments for consideration pertaining to the Draft Environmental Impact
Statement (DEIS):
The Painted Hills PRD Biological Evaluation, Critical Areas Report and Habitat
Management Plan dated February 28, 2019 explores three separate alternatives of
proposal for development. Alternative # 2 and #3 employ buffer averaging to allow
encroachment into the buffer and provide mitigation to off-set it. We look forward in the
future to more in depth discussions regarding the buffers and mitigation.
The Department of Fish and Wildlife continues to stand by the comment submitted on
November 16, 2018 to the proposed Conditional Letter of Map Revision- Fill (CLOMR-
F) which declares Chester Creek a fish bearing stream and does not support re-typing
from F to Ns. Not only does Chester Creek meet the physical characteristics of a fish
bearing stream according to WAC 222-16-031 (3), but there are also resident fish
observed living within the system. It has been observed that fish do get transported
downstream, likely on an annual basis, during normal run off conditions.
Page 73 of the DEIS cites the consulting biologist stating that the on-site reach of Chester
Creek does not provide fish habitat. The Washington Department of Fish and Wildlife
would respectfully disagree with this statement. While this may not be premier fish
habitat due to past alternations and periodic drying, it does provide for regular seasonal
use.
The Department of Fish and Wildlife has concerns under the Proposed Flood Control
Plan. Flood water of Chester Creek will be captured and conveyed to an artificial water
retention system. This has the potential to transport and trap fish into a stormwater
system which serves the planned residential development. Upon reviewing the materials
provided in the DEIS, it is unclear how the proposed flood water system will keep fish
from entering the flood water/storm water system and how they will escape this system.
It appears the effects to fish life are not being recognized as an impact and therefore no
mitigation is proposed to off-set these impacts. We recommend this loss of fish life is
recognized and assessed and then is addressed through appropriate mitigation
sequencing.
Lastly as mentioned in the previous comment, any work conducted on structures such as
culverts and pedestrian bridges within the project area will require a Hydraulic Project
Approval (HPA) from WDFW and be designed to meet fish passage standards.
Thank you for your time and the opportunity to provide comments.
Sincerely,
Leslie King
WDFW Habitat Biologist