Bruce,

Reply to you and "your friend", also copied over from your website...

************************

Bruce,

"Your trying to use this a pulpit for your WSR agenda "

You're kidding, right? What I'm trying to do is get some of the passion that is apparent in the WSR issue in motion for something that we can all agree on, wsr or anti-wsr, and that is habitat destruction.

Here's some more information:

From Friends of the East Fork and FishFirst:



The East Fork of the Lewis River is our treasure, providing incredible scenic beauty, habitat, and a range of recreational activities. Unfortunately, the East Fork has also been stressed by population growth at the same time that it has been expected to provide profits for industrial interests. These pressures have pushed our river to the brink. In the past few years this precious resource, one of the last un-dammed rivers in the NW, was named one of the 13 most endangered rivers in America by American Rivers.



And, it could get MUCH worse.


Now the East Fork is further threatened by a proposed expansion of the Storedahl gravel mining operation at Daybreak, in the river’s floodplain. Storedahl’s current proposal would expand mining at Daybreak to include over 300 acres in the riverine (channel) migration zone. If this expansion is allowed scientists predict the East Fork will incur even more damage, including the high risk of:



-Reduced flow rates on the river, further endangering the three “Threatened” listed salmonid species

-Contamination and degradation of spawning beds with mining fines;

-Worsening erosion of the river’s banks and reducing our property rights & value;

-Destruction of riparian habitat & raising summer water temperatures to levels lethal to juvenile fish;

-Contamination of Troutdale Formation aquifer, it provides groundwater for Clark County and Portland.



Our best chance at stopping this threat to our river is coming up. On April 29th Clark County Hearings Examiner Dan Kearns will face two important decisions: Whether to allow rezoning, and whether the county can abandon its duty to conduct an independent Environmental Impact Statement by adopting a flawed EIS produced by Storedahl consultants for the federal government. The first hearing will be April 29, 7pm, at the Public Service Center, 6th floor hearing room, 1300 Franklin St., Vancouver. Comments must be submitted before 1pm, April 29th. The first date will probably involve the proponents case. On May 13th the 2nd part of the hearing will be time for public comment. There will likely be a 3rd hearing date for closing arguments. That date has not been set yet.



You can help save the East Fork by commenting to Clark County and relating to these key points.

It’s easy. Just send your comments—a letter, postcard, or e-mail— letting the County know that:

1. The proposed rezone is inconsistent with the Comprehensive Plan Map designation and I oppose it. And,

2. The proposed change is not consistent with Plan policies and locational criteria and the purpose statement of the zoning district (i.e. Project supporters must show a substantial change in circumstance since the original zoning) and I oppose the rezone. And,

3. The proposed rezone will not further public health, safety, and welfare of the community

–and I oppose it.

4. “I oppose the Storedahl request to change zoning from agricultural to mining; and it will have an adverse impact that cannot be mitigated, and,

5. I support the County conducting their own Environmental Impact Study of the proposed mining expansion, to allow for the best and most comprehensive scientific information.”



Comments can be faxed to 360-397-2011. E-mail comments to: Susan Rice: susan.rice@clark.wa.gov, or Josh Warner: joshua.warner@clark.wa.gov. Mail comments to: Development Services Division, Clark County Community Development, 1300 Franklin St., PO Box 9810, Vancouver, WA 98666-9810.

Testimony must include name and address and must be received before 1pm the day of the hearing.



And, share this with friends and family. Every comment counts!


*******************************


Letter sent by Wild Steelhead Coalition:



TO: Josh Warner, Planner

joshua.warner@clark.wa.gov (transmitted electronically)

Clark County Planning Department

1300 Franklin Street, 3rd Floor

Vancouver, WA 98666



FROM: Todd Ripley, VP Political Affairs

Wild Steelhead Coalition

218 Main St., Suite 264

Kirkland, WA 98033



RE: Storedahl Habitat Conservation Plan





Dear Mr. Warner:



The Wild Steelhead Coalition (WSC) would like to take this opportunity to comment publicly on the proposed Storedahl Daybreak Mine expansion HCP. The WSC firmly requests that the proposed expansion of gravel mining on the East Fork of the Lewis River not be allowed to take place.



The proposal requires a full independent examination by Clark County, and full consideration must be given to all the environmental impacts that a project such as this will assuredly entail; to do less would put the NMFS and the USFWS in the position of making a decision on the sufficiency of the HCP without the benefit of all the necessary information to make such a determination.



The WSC submits that all impacts must be adequately mitigated to protect the wild fish runs that spawn and rear in the E. Fk. Lewis, and those that are non-mitigable must not be allowed to take place. The staff recommendations from WDFW that some of the impacts are indeed non-mitigable should be strongly considered, as should staff recommendations from the Washington Departments of Ecology and Natural Resources.



Credence should also be given to private organizations who have been working on protection and restoration of the Lewis River. Fish First and Friends of the East Fork have a restoration plan in progress on the E. Fk. Lewis River, and that environmentally friendly program will be compromised by such a large scale expansion of the Daybreak Mine.

The East Fork of the Lewis River a major tributary to the lower Columbia River, and its wild fish runs are very important to the protection and recovery of fish runs in the Columbia. It also is the largest free-flowing river, free of dams, in that region.



In spite of those things, American Rivers has found it to be one of the most “threatened” rivers in the

United States, and projects such as the Daybreak Mine expansion will push the river from “threatened” to a footnote in the story documenting the further demise of Lower Columbia anadromous fish runs.



The WSC respectfully submits that Clark County make an extensive and thorough investigation of all the impacts involved in the proposed expansion, and make use of the county, state, and federal agencies charged with protecting the public resources of our state. The WSC further requests that it be notified at the above address of the further opportunities to provide testimony, whether it be written or in person, with regards to this proposal.



Thank you very much for your time and consideration, it is much appreciated.



Sincerely,





Todd A. Ripley

Vice President of Political Affairs

Wild Steelhead Coalition

************


Here is an excerpt, memo from NOAA Fisheries to NMFS:

1. effects of the pits on groundwater quantity and quality. The East Fork Lewis River (EFLR)is temperature impaired during the summer. We don’t want in make it worse. All local groundwater flow paths end up in the EFLR at. some point along the river. A porous matrix of cobbles and gravels is always a better insulator of water than floodplain gravel pits open of solar radiation and evaporation. Biochemical mechanisms in the shallow alluvial aquifer and hyporheic zone add nutrients and food that increase the overall productivity of the foodweb. Groundwater seeps and upwelling zones likely provide thermal refugia throughout the year. Remove the matrix of alluvium and you remove these benefits.

2. will the pits affect groundwater flow paths? Are the conclusions in the HCP/BO valid? I believe the pits will affect flow paths, but didn't have enough time to go through all the groundwater information. However, I provided some insight into this question/issue in part 1.

3. will the new pits increase the risk of an avulsion? Yes. The new pits are within the alluvial, geomorphic, active (and any other terms that mean "the river left it there and will be back") floodplain and are subject to the fluvial action of the EFLR. Further, the mere presence of a floodplain gravel pit increases the likelihood of an avulsion to that area of the bottomland, especially when the base level of said gravel pits are tens of feet below the bed of the adjacent river channel.

4. Will recovery, after an avulsion, only take 5 years? No. I couldn't find this in any of the information you sent, but the answer is a resounding NO—more on the order of hundreds to thousands of years. Pits could only be considered recovered when the river replaces all of the removed material and the channel is brought back up to grade. Pit recovery requires a supply of sediments, and the watershed can only produce a relatively fixed amount every year. Unfortunately, the river can't wait hundreds of years to refill an unnatural sediment sink, so it satisfies its immediate appetite by cannibalizing sediments stored in the riverbed and in banks,.This action usually acts in motion a string of events that are usually significantly negative to the riverscape and its inhabitants

5. The HCP predicts that an avulsion, if it occurs, will only take out the existing Daybreak Ponds. The new pits are outside the 100-year floodplain (in dispute) and therefore, according to the HCP, not vulnerable to an avulsion. The EFLR didn’t wait to fill the Mile 9 pit captured in 1995 before taking out the Ridgefield Pits in 1996. The proposed expansion site is within the geomorphic floodplain of the EFLR and therefore "in play" during a "100-year" flood. How do the Daybreak Ponds differ from the Ridgefield Pits, and how would the proposed ponds differ from both of these. Ask Storedahl for a derailed topographic map of the valley floor from bluff to bluff upstream from RM 5 to RM 10. The ribbons of alluvium that formerly separated the Ridgefield ponds from one another are likely differ by only a few feet from the elevation of similar ridges of dirt at the Daybreak Ponds, and from the ground surface at the proposed site. Then consider that the EFLR can easily climb a few feet as it floods...

6. Will the reclamation of the ponds (in-filling with fines) affect the groundwater flow, and therefore the EFLR? Yes, from both a water quality and volumetric standpoint See part 1.

7. Will sediments, if flushed from the ponds, settle onto downstream spawning gravels? (HCP says no, the EFLR is not sediment limited.) Possibly. This depends on the size of the fine sediment particles, the magnitude of sediment discharge, the discharge in the EFLR, and, to some degree, the temperature of the water in the EFLR (viscosity is inversely related to temperate). Timing is important- sediment delivery out of phase with the natural hydrograph is a bad thing for fish and the aquatic foodweb, regardless of the substrate it settles into. Thanks for your time, and the opportunity to provide comments on this project.

**************************

Fish on...

Todd