1. Overall, the general lack of explanations within the RUE is concerning. Some have no answers, many are 1 word answers, and many do not provide the minimum answers asked by the questions. In general, not enough information has been provided to approve the proposed project.

2. Lyons Creek floods frequently, and some addition of Large Woody Material in the stream
a. We normally like to see more large wood added to the system, but here it would likely add to the flooding problems that Lyons Creek experiences.

3. Question 3(v) asks if the proposal lies within a 100 year floodplain- The answer says NO
a. That is not correct and work does occur within the 100 year floodplain

4. The culvert that conveys Lyons Creek underneath NE 205th St and through the site is a partial barrier for fish passage, and the plans will have to provide enough space for a Fish Barrier Correction Project to occur in the future.
a. The fish barrier correction culvert will be much larger than the one currently there, and the plans are lacking adequate space for a Fish Passage Barrier Removal Project to take place

5. Under Plants, Evergreen trees were not checked
a. I can see from arial photographs and Google Maps Street View that there is at least 2 cedar trees on site.

6. The plans propose to replace large trees in a 1:1 ratio with new plantings
a. A young, newly planted tree does not account for the removal of a large, mature tree.

7. Under the “Animals” section, all questions are answered with “n/a”
a. There are certainly animals using the site including birds, fish, and mammals
i. WDFW records show that Cutthroat Trout and Coho salmon have been documented in this reach of Lyons Creek
ii. The local biologist also told me that the reach on this site has High Quality Spawning Habitat, which is of high importance to the conservation and recovery of Coho Salmon populations
iii. If Coho salmon are present, then they will likely migrate upstream to spawn, and juveniles will likely migrate downstream on their way out to the Puget Sound and Pacific Ocean.

8. There appears to be little to no proposals for habitat enhancement
a. This will be necessary to mitigate the impacts that will occur while developing this site. WDFW’s “No Net Loss” standard has not been met in the proposal

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Dan

Compliance Biologist
Washington Department of Fish and Wildlife