HomeMy WebLinkAbout07-25-23 Public Comment - C. Nixon - K.1 Wetland Protection MitigationFrom:Chris Nixon <pres@sacajaweaaudubon.org>
To:Agenda
Subject:[EXTERNAL]Comment for Tonights Commission Work Session Item K.1 Wetland Protection Mitigation
Date:Tuesday, July 25, 2023 10:45:32 AM
Attachments:Public Comment for Wetland Working Session 2023.07.25.pdf
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Mayor and Commissioners,
Please see attached letter of comment for tonight's Commission meeting Item K.1 Wetland
Protection Mitigation Work Session
Thank You for your public service!
Chris Nixon
President, Sacajawea Audubon Society
406-544-4901
Dear Mayor and Commissioners,
Sacajawea Audubon Society (SAS)is in support of the City of Bozeman’s plans to revise the
city UDC with the goal to protect,enhance and restore wetlands in our watershed.We are
providing this letter as further support of your efforts.SAS is also grateful for the support and
assistance we have received from the Bozeman Transportation and Engineering staff to move
forward the development of a wetland mitigation bank at the Indreland Audubon Wetland
Preserve (IAWP)in east Bozeman.Ultimately we hope that the future wetland mitigation bank at
the IAWP is just the first of a series of wetland banks to be located here in our local watershed.
The following comments will hopefully help persuade everyone of the importance of wetland
protection and enhancement in our valley.
SAS’s membership of nearly 1000 residents within the Greater Yellowstone Ecosystem of
Montana encourages you to act within your duties to protect public health,safety,and welfare of
the citizens under your charge.In order to do so,you must take measures within your power to
ensure that stream,riparian,and wetland services are retained within the immediate watershed
of the East Gallatin River.Please,take this opportunity to provide requested direction to
Bozeman City Staff,for important updating of the Bozeman UDC Division 38.610.-Wetland
Regulations.We ask that you provide all means possible to retain our stream,riparian,and
wetland services,functions,and benefits here within the East Gallatin Watershed.Any future
impacts to streams,riparian areas,and wetland areas within the City and East Gallatin
Watershed should be mitigated in the same.
Climate instability is now further bringing to light how damaging and destructive it is to remove
stream,riparian,and wetland services from an area.It is becoming more apparent that the
value of flash flood control,water infiltration and subsequent slowing of surface water runoff and
subsurface flows is critical to both water resources and to built environments.In fact,the State’s
2015 Water Plan states the following,“Integrating existing natural systems and promoting the
protection and restoration of natural systems into Montana’s water management practices will
support late season flows,help to mitigate the impact of drought cycles,and provide
environmental benefits.”
We suggest that we all reflect on the fact that the sole intent of providing the option of utilizing
the mechanism of Stream,Riparian,and Wetland Mitigation Banking was to prevent the loss of
valuable wetland services and functions in an area.These include financial benefits such as
flood mitigation,flood prevention,groundwater recharge,and decreasing the spread of wildfires;
which can all help decrease risks to homes,businesses,infrastructure,and other assets of the
local economy.These services not only reduce the risk of financial losses and impacts for we
humans,but also provide habitat and benefits to the other creatures that call the Gallatin
Watershed home.
The allowance of the option to utilize a wetland mitigation bank to prevent wetland service loss
was NEVER conceived as a mechanism by which one could cut the cost of a project.Use of a
mitigation option was to provide a path forward for other needed services such as highways,
water treatment facilities,waste treatment facilities,and business -without losing existing
wetland services and benefits.The intent of the protective measures of the laws/rulings were to
provide the option of utilizing a Mitigation Bank to guarantee that there is no net loss of wetland
services in a given area and "YET"make it possible for a municipality,government,individual,or
business to gain the option to undertake a desired project when there was no way to prevent
impacts at the given site.
Again,the option of utilizing a Mitigation Bank was not conceived as a method of cutting cost,it
was conceived as a means to make development possible.Therefore,ensuring the lowest cost
for mitigating project impacts should not be "a"factor when considering if a project is a viable
project.
Determining the best means of replacing impacted wetland functions as closely as possible to
the original impact site best suits long term goals of no net loss of wetlands.Retaining the
valued services in the immediate community or municipality for the citizens that are being
impacted is the intent of the laws and regulations.Loss of those wetland services will likely lead
to future,long term economic detriment through increased risk from flood,fire,and drought.
Riparian and wetland habitats in the western states are generally less extensive and more
dependent on snowmelt than those in the eastern half of the country where precipitation is more
consistent year round.Thus,it is even more important to require permitted wetland impacts and
losses to be mitigated or replaced as close to the original impact site as possible.
Continued mitigation of wetland losses within the upper Gallatin Watershed at mitigation banks
located in distant watersheds does not protect the health,safety,and welfare of the citizens of
Bozeman and of the immediate surrounding citizens within Gallatin County.The attractiveness
of Bozeman and the Gallatin Valley is due in part to recreational access to the beautiful
surrounding landscape and abundant wildlife.When we diminish those qualities,we risk the
value of the whole.These services are being lost because at this time wetland losses are being
replaced at mitigation banks outside of our watershed.They should be replaced here at local
market value.Allowing these services to be lost and replaced at lower cost in a part of the state
where land values are not as pricey as here in the Gallatin Watershed is simply shipping our
ecological services outside of the scope of local taxpayers and depriving those local taxpayers
of the valuable services they have benefitted from.SAS intends to value bank credits at the
IAWP based on fair market value.As with everything,market costs for mitigation credits have
increased substantially in 2023.
Setting regulations into place does not prevent investments and developments.Setting
regulations simply establishes a level playing field and protects,for the future,developments
and investments that are made today.Regulations allow us to also take into account the future,
long term needs and earnings rather than simply the immediate gains.
An additional $300,000.00 -$400,000.00 for adequate staffing each year is indeed substantial to
protect local wetlands.But that cost likely pales when compared to the future cost if we don't
take the proper steps at this time.Fixing a system or infrastructure is always more costly than
building it correctly the first time.As an aside,it might be of interest to know that SAS and other
local non profit conservation &education organizations have invested greatly in our wetlands.
Volunteer community members are out today working to enhance local wetland and the riparian
zones that support them.The University of Montana is out today at the IAWP providing
education on how to protect and enhance wetlands.Just looking at SAS contributions,our
board and membership have put in volunteer time greater than 5 FTE positions in the past 5
years.SAS has financially invested over a million dollars in the creation of a mitigation bank.
We are asking the City to invest in local wetlands by adding the adequate staffing,revamp and
create UDCs that keep our wetlands in our watersheds,and find ways to assist developers to
protect wetlands and riparian areas they support.
Once the Draft UDC is released,SAS will likely have more specific suggestions regarding
wetlands,riparian areas and wildlife mitigation efforts.
We urge you to be courageous at this time and set the standard on how to properly address
these important matters for now and the future.Set the standard for building resiliency into our
landscapes by insisting on UDC regulations that require local wetland mitigation.Set the
standard for reducing risk from environmental disasters in our landscape.Set the standard for
reducing future loss of homes,businesses and infrastructure from coming predicted disasters.
Remember,risk management is ultimately cost management.
Sincerely,
Chris Nixon
President,Sacajawea Audubon Society
on behalf of the Board of Directors and Membership
406-544-4901