December 3-4, 2015 - LCDC Salem <br />Agenda Item 4, Attachment H <br />gon <br />Kate Brown, Governor <br />November 13, 2015 <br />HB2254/197A.300-325 RAC and DLCD Staff <br />And the Land Conservation and Development Commission <br />c/o Cassaria Taylor <br />Department of Land Conservation and Development <br />635 Capitol Street NE, Suite 150 <br />Salem, Oregon 97301-2540 <br />Department of State Lands <br />775 Summer Street NE, Suite 100 <br />Salem, OR 97301-1279 <br />(503) 986-5200 <br />FAX (503) 378-4844 <br />www.oregon.gov/dsl <br />State Land Board <br />Kate Brown <br />Governor <br />Jeanne P. Atkins <br />Secretary of State <br />Ted Wheeler <br />Re: Comments on the 9/10/15 draft Division 38 and Division 24 rules; State Treasurer <br />and proposed location rule changes of 11/05/2015. <br />The Department of State Lands (DSL) appreciates being included as a member of the Division <br />38 Rules Advisory Committee (RAC) and the opportunity to make comment on this rule making <br />effort. DSL provides the following comments on the 9/10/2015 draft Division 38 rules, <br />proposed changes to Division 24 rules and supporting documents. These comments are in <br />addition to the comments that were previously provided on the 8/20/2015 version of these draft <br />rules to the RAC, Department of Land Conservation and Development (DLCD) and Land <br />Conservation and Development Commission (LCDC). <br />Wetlands Policy in Oregon <br />It is the policy of the State of Oregon to promote the protection, conservation and best use of <br />wetland resources, their functions and values. This is accomplished by integrating and <br />coordinating statewide planning goals, local comprehensive plans, and state and federal <br />regulatory programs. Further, it is the policy of this State to promote the protection of wetland <br />values on private lands by developing and using public recognition programs, incentives and <br />other nonregulatory actions (196.672(1) & (9)). <br />The Legislature found that wetlands serve multiple valuable functions as listed in ORS <br />196.668. These findings continue to be supported and augmented through scientific studies. <br />Examples of functions that may contribute the most to the resilience and livability of urban and <br />urbanizing areas include: <br />• Flood delay and retention - flow may be slowed and capacity provided to decrease flood <br />risk to the built environment; <br />• Water quality - wetlands may improve multiple factors contributing to water quality; <br />• Carbon sequestration; and <br />• Contribute to habitat and migration corridors for birds, wildlife and fish. <br />