HomeMy WebLinkAbout05-18-21 Public Comment - W. Weaver - Montana Freshwater Partners Comment to Protect WetlandsFrom:Wendy Weaver
To:Agenda
Cc:jblank@montanaaquaticresources.org
Subject:[SENDER UNVERIFIED]Montana Freshwater Partners Comment to Protect Wetlands
Date:Tuesday, May 18, 2021 11:43:36 AM
Attachments:5.18.21 COB Comment from MFP_20210518.pdfRIPRAP.png
CAUTION: This email originated from outside of the organization. Do not click links or open attachments unless you
recognize the sender and know the content is safe.
Dear Commissioners-
Please accept our comments for public comment record and Commissioner review for the May
18th, 2021 commissioner meeting.
Sincerely,
Wendy
Wendy Weaver
Executive Director
Montana Freshwater Partners, formerly known at Montana Aquatic Resources Services (MARS)
Cell: (406) 579-2355
Page 1
May 17, 2021
City of Bozeman Commission
121 North Rouse
Bozeman, MT 59715
Re: City of Bozeman Strategic Plan Recommendations for Wetland Protection
Dear Commission:
As Montana’s Statewide In-Lieu Fee Aquatic Resource Mitigation Program sponsor and a nonprofit
conservation organization dedicated to conserving wetlands, streams and riparian areas, Montana
Freshwater Partners, formerly known as Montana Aquatic Resources Services (MARS) is engaged in both
regulatory and nonregulatory programs to protecting these resources. Drawing from both aspects of
our overall program, we are committed to the conservation of important wetland areas throughout
Montana.
Wetland loss in and around Bozeman has been steadily impacting our local watershed for the last 20+
years as a result of rapid growth and development. Several local and statewide studies document this
trend in loss to these important resources (1996 Critical Lands Study, 2016 Montana Natural Heritage
Program Wetland Ecological Vulnerability study, and 2018 MSU LRES Capstone Study). This loss has a
direct and indirect impact on City services and amenities with increased storm water runoff, degraded
water quality, and loss in community natural resources and green spaces.
We believe the number one way to reduce the amount of local wetland loss is to have local governance
close the loop-holes that the federal rules leave open. Many people assume that the US Army Corps of
Engineers (USACE) is the key to enforcing where and how wetland impacts will be mitigated – but it’s
not that simple. The USACE only requires mitigation on wetlands/waters that are federally
regulated. When mitigation is required, the USACE will determine which mitigation banks or mitigation
sites are appropriate locations for a given impact. In some cases, a permittee may have more than one
option to choose from and isn’t necessarily restricted to use the more local mitigation option. This is
where local rules are needed at the City and/or County level to ensure that when wetlands/waters are
impacted, that local mitigation or local offsets are given the priority. To do this, local governments need
to 1) encourage and enforce preservation where possible (avoiding loss in the first place is the most
effective way to keep local watershed functions in place); 2) encourage local mitigation whenever
possible either by incentivizing local mitigation (when local options are available), or conversely,
penalize permittees who still choose to mitigation outside of the local watershed; 3) incentivize and
support local restoration and enhancement efforts that have direct beneficial impacts to priority water
sources; and 4) determine the monetary value of wetland/waters loss on local government services to
Page 2
inform public policy and leverage additional funding sources to address local wetland/water loss (i.e.
storm water runoff, water quality, flooding/city infrastructure maintenance).
Thank you for your vision and leadership to suggest adding language to the City of Bozeman Strategic
Plan to consider habitat and work with partner organizations to identify at-risk, environmentally
sensitive parcels that contribute to water quality, wildlife corridors, and wildlife habitat. As you may be
familiar, Section 404 of the Clean Water Act states no net loss of wetland function. As Bozeman
continues to grow as a community, it is inevitable that this development will impact wetlands and
streams in the City of Bozeman and therefore it is critical to protect and preserve these valuable
resources into the future.
Montana Freshwater Partners strives to collaboratively work with watershed partners, government
agencies, conservations districts, and others to develop and implement innovative solutions to
protecting our valuable wetlands and streams so we appreciate this opportunity to work with the City of
Bozeman in the strategic planning process.
Thank you for your consideration and we look forward to this opportunity to work with the City of
Bozeman. Please keep us connected via email on future discussions and meetings regarding this topic.
Sincerely,
Wendy Weaver, Executive Director
Jeannette Blank, Project Manager
Montana Freshwater Partners, formerly known as Montana Aquatic Resources Services (MARS)