9. NO NET LOSS OF ECOLOGICAL FUNCTIONS, NO ADVERSE IMPACT, and MONITORING

The current CAO has two performance criteria for wetland buffer decreases:  (1) “provide as great or greater functions and values as…under the standard buffer”  (also referred to as “equivalent functions and values”) and (2) “no adverse impact” for buffer averaging. […}

7. SPECIALISTS AND REPORTS

There are multiple ecological functions of buffers. Evaluation of functions may require expertise in wetlands, streams, habitat, soil science, hydrology, hydrogeology, and/or stormwater.

Currently, the department appears to rely entirely on wetland reports and habitat management plans from wetland specialists and fish/wildlife biologists, respectively. However, their expertise may not extend to all the technical areas necessary for adequate evaluation of buffer functions. […}

5. BOUNDARY MARKING AND MEMORIALIZATION

For critical area or buffer boundaries to be honored in the future they must be memorialized for future owners and residents. Current code lacks such provisions and transgression of boundaries is not uncommon. It is too tempting and easy for a current owner to extend a garden or yard by importing fill. The current requirement allowing wood posts, even if treated, is only a short-term solution. […}

CLARITY

Standard buffer widths. Actual standard buffer widths must be inferred. Tables 19.200.220(B) through (D) and Table 19.300.315 should be identified as “Widths of Standard Buffers” or “Standard Buffer Widths.” […}