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, r <br /> have been toad by expertt�familiar r�rith tho�e st.uclies Lhat thc�se instances where buli'ers of <br /> more Chan 30 feet are rec�mmended it was in sii;uatic>ns wh�ce,yau have: <br /> • Steep sltrpes, <br /> . Tight soils and <br /> • Receiving high concenl;rations of channelized flows from agricultural feeciiote. <br /> I t;alked to a numbor o�experts ana I think in l:he end even MCWD staff agreed that any <br /> buf£er vf more than 3�feet result;ed in de minimis return�on the issue of.water quality. <br /> F{'urther why EOR wtta suggesting wider buffers it vrias for the pwcpase of wildlife habitat nat <br /> water quality. <br /> I.et's l;ake as an example Preserve wetlands. The progosed rule providos fux a 75 foot buffer. <br /> Iiowevex all of the reports pzovided ta us support that whcn evakxating watc�r yut�lity, ' <br /> an,ything more than 30 feet:�rovidos diminishing rci:urns. We were t:�ld Lhat was to �iso <br /> addresH habitat,but from my research I have becn t.old that generall,y you need 30{?feet fc�r <br /> habitat..This propa.9ed rule results in the worRe of both warlds. You have groatl,y increased <br /> tho amount of the buffer. without significantly increasing t;he quality of wat;e.r quaiity and <br /> yet you have nnt creaCed nearl,y enough buffer ta provide for meaningful habitat;. <br /> As far as buffer.s f.or downgr.adient wetlantls, i echa the comments of ot;her�. <br /> �3uffer Wiclths(nase 8) <br /> 1:agree u�ith t;he approach of looking at wetland function inst;ead of si�e. <br /> I�m concernetl however. about the methcxi of assessment. For example it is my <br /> under�f:anding i:hat a wetland which is ar�jacent to a lake or stream,even if oC lower. quality <br /> in most oEthe functions evr�luated, will still lx�Created as�.preserve merel,y�,y virtuc of <br /> being adjacent I;o a lake or stream...On�t's face that may sc�c�m�ne,but I ask you t�r lo�k se <br /> the implicativns. Under the pmpos�d rulF, the buffer fox this wetland is a mir�imum of 7Ci <br /> f�et. The impl.icAtion zs that under this r.uie you would b�creating increased buffc�rs fllong <br /> lakes and creeks in Lhe District i;hat grenll}�exceed th�current 7�ft buffer from the OFiWL. <br /> I Suspect no one has discussed the implicai:ions of a chang�as signifc;ani,as this. <br /> While generall,y 1 support the apprc�ch of adjusting buffer widths to address t;he features of <br /> a particular wei;land,I question how it is imposed in this rule. My�roblem is that�his rule <br /> mixes"apples and ar.anges". If you �vere using the 30€oot buffer which is recorr�mended for <br /> maximum benefii;per cost for water c�uality, �hen it would m;ake aense I;o consider increasin� <br /> il;for ti�ht soils or slopc�s�r to lessen it unc�er ot;h�r conditions, but as noted�bove, the rule <br /> alresd,v doubles the bul�et for. Pr.ererve Wetlanda to 7G fceC. This i.ncrease i�far. habif;al;and <br /> nther anaenities. 'I'his addition�I�IS feet shouid be more than adequat;e to addr.ess site issues <br /> such as slope. By increasing the buffor beyond 75 fest;��ou�re getting virtually no incraase <br /> in water qualii:g. <br /> Just as an aside, our of�ice looked at a situation in which there mi.ght be 3 feet of <br /> encroachment in a Preserve VVetland. Unde�a lif:er.al intex�rctation the r.esu)t could be the <br /> need to have a l07 foot buf�'er. I am unawar.e of xny evidenca to 5uppor.t that this width o£ <br /> buffer has a demonstzable benefit in relation to th�impact, <br /> Main _.nanee �page 10) <br /> This is r�n admirAble goa]. However. .in many cases it is nol:practical. In part:icular I am <br /> referri�g to the languags in section f(a)which reyuires 75%of the s�eciefi to be naLive. If <br /> you aze neflr or adjAcent to areas that have non native species i1;could be ver�expensive <br /> and virl;uHlly impossSble to m�inl:ain. <br /> , Other Items. <br /> Sectian 5 (U) (i). Iiow is slope ca]culai;ed? Over wha1;disGanco? Whal;if the 91ope <br /> undulatc�s? <br />