Wildes Rd Clear-cut Proposal Deficient

Properties to be clear-cut with steep slopes in red and showing streams and wetlands (credit ICGeoMap).

Re: Public Comment on Forest Practice Application NW‑FPA‑26‑8637 Proposed 37‑acre clear-cut at Quade Creek headwaters, Maxwelton Watershed

Dear Mr. Becker,

I am submitting this comment on behalf of Whidbey Climate ACTION and Regenerative Whidbey to express strong opposition to Forest Practice Application NW‑FPA‑26‑8637, proposing the clear-cutting of approximately 37 acres at the headwaters of Quade Creek within the Maxwelton Watershed.

This proposal represents a severe and unacceptable ecological risk to one of Whidbey Island’s most fragile aquifer recharge zones. The application, as submitted, fails to demonstrate adequate due diligence, omits critical hydrological and geomorphological analysis, and does not acknowledge the well‑documented vulnerabilities of the Maxwelton Watershed.

1. The Maxwelton Watershed Is a Critical Aquifer Recharge Area

The Maxwelton Watershed is not an ordinary forested parcel. It is one of Whidbey’s most sensitive freshwater lenses, where shallow groundwater “floats” atop denser saltwater. “South coastal lenses: Maxwelton, Cultus Bay, Useless Bay, where shallow freshwater floats on saltwater and summer irrigation can quickly cause drawdown.”

This means that any reduction in forest cover directly reduces aquifer recharge, increases summer drawdown, and accelerates saltwater intrusion.

Forests are not simply scenery—they are living recharge infrastructure. Their root networks, fungal webs, and soil‑building processes create the permeability and organic sponge layers that allow rainfall to infiltrate rather than run off. Removing 37 acres of mature forest in this location would:

• Reduce infiltration capacity

• Increase stormwater velocity and erosion

• Degrade water quality

• Accelerate aquifer depletion

• Increase saltwater intrusion risk

The applicant has provided no hydrological modeling, no recharge analysis, and no assessment of downstream impacts on Quade Creek, Maxwelton Creek, or the aquifer.

This is a fundamental due‑diligence failure.

2. Sea‑Level Rise and the Ghyben‑Herzberg Relationship Magnify the Risk

The Maxwelton freshwater lens is already thinning due to sea‑level rise. Under the Ghyben‑Herzberg Relationship, a 6‑inch rise in sea level can reduce freshwater thickness by 20 feet in the subsurface. The U.S. Geological Survey projects 1–4 feet of sea‑level rise on Whidbey by 2050–2100. Along Maxwelton Beach, this will dramatically compress the freshwater lens, making wells far more vulnerable to irreversible saltwater intrusion.

Clear-cutting in this context is not merely ill‑timed—it is reckless.

A thinning freshwater lens combined with reduced recharge from forest removal is a double‑impact scenario that could permanently contaminate wells serving all of Maxwelton Beach households.

3. The Midvale Peat Bog and Upland Wetlands Are Already Compromised

The upland Midvale peat bog—historically one of the watershed’s primary recharge engines—has already lost significant capacity due to past disturbance. This means the remaining forested uplands are even more essential for maintaining recharge and slowing runoff.

The applicant’s materials do not acknowledge:

• The peat bog’s diminished recharge function

• The watershed’s impaired infiltration capacity

• The cumulative impacts of forest removal on a compromised system

This omission is unacceptable for a project of this magnitude.

4. Documented Pollution, Silt Accumulation, and Erosion Risks

Residents within the Maxwelton Watershed have reported significant silt accumulation at the watershed’s lower reaches. Island County Department of Health has documented high levels of pollution in the Maxwelton Watershed.

Clear-cutting steep slopes and wetland‑adjacent areas will:

• Increase sedimentation

• Mobilize pollutants

• Harm fish-bearing streams

• Further degrade water quality

• Exacerbate chronic watershed impairment

These are the places where peak water (where extraction exceeds recharge) appears first as seasonal brackish wells, lower summer water tables, and greater ecological stress. The applicant has provided no erosion control plan, no sediment transport analysis, and no water‑quality mitigation strategy.

5. The Application Lacks Required Specificity and Environmental Review

Multiple reviewers—including experienced watershed advocates—have noted that the permit file is “seriously lacking details” regarding:

• Wetlands

• Steep slopes

• Stream proximity

• Hydrological complexity

• Recharge zones

• Downstream impacts

• Cumulative effects

A project of this scale, in this location, requires a full environmental impact analysis. Proceeding without one would constitute ecological negligence and expose the community to long‑term harm.

6. A Community Invitation to Stewardship

Regenerative Whidbey believes that protecting our aquifer is not merely a regulatory obligation—it is a shared community responsibility. Every resident with a downspout and a thirst for clean water has a role in caring for the systems that sustain us.

We extend a neighborly invitation to DNR to join us in this stewardship.

This is not about stopping progress. It is about choosing the kind of future we want for Whidbey Island—one where forests, wetlands, salmon, birds, frogs, and human communities all continue to thrive.

Request:

Given the documented vulnerabilities, the scientific evidence, and the applicant’s failure to demonstrate due diligence, we respectfully request that DNR:

DENY Forest Practice Application NW‑FPA‑26‑8637

OR, at minimum:

Require a full environmental impact analysis (EIA) including hydrological modeling, recharge analysis, erosion and sediment transport studies, and cumulative impact assessment.

Anything less would place the Maxwelton Watershed—and the people who depend on it—at unacceptable risk.

Thank you for your attention to this matter and for your stewardship of Washington’s natural resources.

Sincerely,

David Haskell

On behalf of Whidbey Climate Action & Regenerative Whidbey