Kinnikinnick Chapter Of The Idaho Native Plant Society
December 15, 2004
Mr. James Brady
3706 Industrial Ave
South Coeur d’Alene, ID 83815
RE: Application for Commercial Marina at Dover
Our Chapter of the Idaho Native Plant Society would like to thank you for the opportunity to submit comments regarding the new application for a permit for a commercial marina as part of the development at Dover. On behalf of our 130+ local members, we want to share with you our priorities and concerns regarding the potential impact of this proposed project on native plants and their habitats.
The original application was denied by the Idaho Department of Lands, citing a number of concerns. Many of these concerns are still valid and we do not believe that the current application adequately addresses these. We would encourage the IDL to continue to address their original concerns. Specifically, from the IDL’s original “Findings of Fact and Conclusions”:
Item #11 indicates that there are concerns that the Marina will “contribute to an aggregate nonpoint source contamination in the watershed.” We would like to see this problem addressed more directly by the permittee. The new application mentions that a storm water pollution prevention plan will be developed, but does not go into details. We would urge the IDL to stipulate that an approved SWPP plan be a contingency of granting this application.
Item #13 indicates that the IDFG expressed concerns regarding, among other things: “Water quality from boat fueling” and “lack of a defined plan for sediment and erosion control.” The IDFG, according to this item, also “recommended that specific plans be developed to control water quality impacts.” The new application provides very few details regarding such plans, referring to “Best Management Practices” without defining these. Requiring defined and approved plans to address these issues should be a contingency of the permit. In addition a Spill Prevention Containment and Counter Measures (SPCC) plan should be required to address the threat to water quality from boat fueling and storage of fuels.
Item #14 recommends that a proposed boardwalk be moved back at least 30 feet from the shoreline to protect riparian areas. The new application does not make any reference to this boardwalk. Has it been moved or eliminated?
Item #16 indicates that the Tri State Water Quality Council mentions the need for a nutrient management plan, controls for Eurasian Milfoil and the use of Native riparian vegetation to help filter and stabilize shoreline. Any permit issued should require the inclusion of all three of these actions. The new application treats nutrient management and native vegetation in only the most oblique and vague manner. A required plan to address both of these items would, in our opinion, strengthen the value of this permit.
As for Eurasian Milfoil, we cannot stress enough the threat that this noxious weed poses to our waterways. As evidenced elsewhere on Lake Pend Oreille, its eradication is very time consuming, costly and largely ineffective. Requiring educational signage is a good start, but education alone is insufficient in addressing this threat. Simply put – there is no effective control or eradication strategy that will be successful against Eurasian Milfoil once it has been introduced. The environmental consequences of introduction are severe and the economic costs of even trying to control much less eradicate Eurasian Milfoil are staggering. It must be prevented. It seems that this permit should provide some opportunity to address this threat in a meaningful manner, such as requiring inspection of boats and other vessels along with mandating removal whether by hand or mechanical means.
We would also urge the IDL to address the threat of spreading noxious weeds during construction of the marina. Appropriate measures to eliminate this threat should be required.
Sincerely,
Molly O’Reilly
President
Kinnikinnick Chapter
Idaho Native Plant Society