HomeMy WebLinkAbout09-09-25 Public Comment - J. Trilling - City Commission Public Comment 9.9.25 wetlands and watercoursesFrom:Jared Trilling
To:Bozeman Public Comment
Subject:[EXTERNAL]City Commission Public Comment 9.9.25 wetlands and watercourses
Date:Tuesday, September 9, 2025 9:46:10 AM
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Dear Mayor Cunningham and City Commission,
I support the City's proactive efforts to strengthen wetland and watercourse protectionsessential for our community's water quality, flood control, and wildlife habitat. As a former
wetland scientist who has written many wetland delineation reports and conducted wetlandpermitting, I have seen how the current federal regulations that purport to 1) avoid wetlands
impacts, 2) where wetlands impacts cannot be avoided, minimize wetlands impacts, and 3)when wetlands impacts are incurred, mitigate the impacts have good intentions but
ultimately fall short primarily because this process is not enforced until the developer alreadyhas designs inplace for the site. At which point the process often goes straight to mitigation. I
see the same potential issue in the current wetland code up for consideration, and offer thefollowing suggestions to avoid this pitfall.
Require Delineation Reports Before Site Design: To truly prioritize wetlandprotection, the ordinance should require that aquatic resource delineation reports be
submitted and reviewed before any site design begins. Specify that an “aquatic resourcedelineation” is required at Pre-application and Concept Plan Review in the development
review process.
Defer the USACE Approved Jurisdictional Determination (AJD): The requirement
for an AJD in the aquatic resources delineation report should be moved later in thereview process. This federal determination can take months or even over a year, making
submitting this report as early as possible in the planning process impractical orinefficient due to this requirement. Requiring it later in the planning process, rather than
upfront, would be more efficient.
Relocate the "Avoidance Narrative" in the Aquatic Resource Delineation Report:
It is illogical to require a narrative on how a design will avoid impacts before a designeven exists. This requirement should be submitted with a preliminary site plan after the
wetland boundaries are known.
Thank you for your consideration,
Jared Trilling, Project ManagerGallatin Watershed Councilhttp://gallatinwatershedcouncil.org
Cell: 406.218.1580