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21-100325-CO-Building B ESA Response Letter-07-07-2022-V1Wet.land, LLC 8201 164th Ave NE, Suite 200, PMB 141, Redmond, WA, 98052 206-309-8100 7 July 2022 Stacey Welsh Principal Planner City of Federal Way Jessica Redman Ecologist (3rd Party Reviewer) Env ironmental Science Associates REFERENCE: Woodbridge Building “B” Building Permit Critical Area Review SUBJECT: ESA 4 May 2022 Comments Dear Stacey and Jessica : ESA comments on this Project were provided in a memo dated 4 May 2022 . Our responses to those comments are provided below as well as incorporated into the main City response letter prepared by ESM. CORRECTIONS Condition 4 Work is not allowed within Wetlands DP, DT, Stream EA, and associated buffers, as stream setback intrusions and improvements/land surface modifications in non -CZA exempt wetland setbacks require Use Process IV application review and approval per FWCC Sections 22-1312(c) and 22-1359(d). ESA believes this condition has been met. All work proposed in the CAR Addendum is outside of Wetlands DP, DT, Stream EA, and associated buffers as shown in Figure W1.1 of the CAR Addendum. However, Sheet SD-02 in the Construction Plans for Woodbridge Building “B”, does not show the correct buffer for Wetland DT and currently shows an extruded curb as well as portions of a trash enclosure proposed within the buffer. It is recommended the applicant revises the construction plans to show the correct buffer before construction commences. 3 February 2022 PAGE 2 The Construction Plans prepared by ESM have been revised to reflect the correct post-construction buffers for Wetland DT and to not show any elements within the post-construction buffer. Condition 9 The following amendments shall be made to the critical area report before issuance of a building permit: a) Include an analysis of wetland functions as required by Section 22-1356(b) of the 1994 FWCC. The CAR Addendum includes a functional analysis of Wetland DT that includes all requirements under Section 22 -1356(b)(7) of the 1994 FWCC. ESA agrees that all other requirements under Section 22 -1356(b) (i.e., 1 through 6) were previously addressed in the Critical Areas Report dated June 26, 2018, and included as Appendix A. ESA also agrees that an evaluation for Wetland DP is not warranted as no modification to this wetland, or its associated buffer, is being proposed. ESA believes this condition has been met. Noted. Condition met. b) If Talasaea is considering the built -condition of Building “A” to be the existing conditions for the Building “B” proposal, Sheet W1.0 of the revised report shall be revis ed to show the reduced buffers for Stream EA and Wetlands DT, DR, and DQ to be consistent with the proposed buffers on Sheet W1.2 of the report for Woodbridge Building “A.” Currently, Sheet W1.0 shows the buffers as if Building “A” was not built. The Existing Conditions Plan (Sheet W1.0) of the CAR Addendum has been revised to show the reduced buffers for Stream EA and Wetlands DT, DR, and DQ, as they have been approved post-construction of Building A. ESA believes this condition has been met. Noted. Condition met. c) The applicant shall show/label on Sheet W1.1 the size of each area of buffe r reduction and replacement to demonstrate that each reduction is compensated for at the location of the critical area where that reduction occurs. Adjustments shall be made if necessary. Sheet W1.1 of the CAR Addendum shows the size of the total stream an d wetland buffer reductions and replacements, not the size of each individual buffer area proposed for reduction or addition as required by the condition. This condition has not been met. 3 February 2022 PAGE 3 This comment on Condition 9c requested that “the size of each individual buffer area proposed for reduction or addition” be shown on the Mitigation Plan. The buffer modification legend on Sheet W1.1 o f the Mitigation Plans has been revised. The revised Mitigation Plans, dated 10 June 2022, are attached for review and reflect an updated tally by buffer reduction and addition area, rather than a sum total by feature . d) The “buffer replacement for Parcel A” shown on Sheet W1.1 is not approved and shall be removed from Sheet W1.1. The “buffer replacement for Parcel A” that was shown near the driveway entrance off Weyerhaeuser Way in the CAR dated June 26, 2018 has been removed from Sheet W1.1 in the CAR Addendum. The revised sheet only shows the buffer replacements that were approved as part of the Building “A” project. However, it is recommended that Sheet W1.1 be further revised to clarify that the buffer replacement for Parcel A that is located on Parcel B was part of the utility lin e installation work for the Building “A” project. The legend should be amended to make this clarification. This comment on Condition 9d requested that the project legend on Sheet W1.1 be revised to clearly reflect that the buffer replacement for Parcel A that occurred on Parcel B was part of the utility line installation work for the Building “A” project. The reques ted legend on Sheet W1.1 has been revised. e) When ESA’s comments on inconsistencies between report text, figures, and the plan sheets are resolved in the submittal for Buildin g “A,” the submittal documents for Building “B” shall be revised where necessary. The inconsistencies between report text, figures, and the plan sheets were resolved in the review of the building permit application for Building A. Additionally, according t o Section 6 of the CAR Addendum, the buffer modifications for the Building “A” project had an effect on the original Building B buffer modifications. Therefore, a new assessment of critical area buffer impacts and mitigation was completed in light of the current Building B site plan and the Process III -approved Building A site plan. This condition has been met. Noted. Condition met. Condition 10 Plan sheets that show the proposed development shall show the buffers post -development, including the averaged wetland and stream buf fers. 3 February 2022 PAGE 4 The plan sheets included in the Construction Plans for Woodbridge Building “B” that show the proposed development show the buffers post -development. ESA believes this condition has been met. Noted. Condition met. Condition 11 Areas of wetland and stream buffer replacem ent shall be enhanced with native vegetation, as necessary, to ensure buffer function continues post -development. Planting details shall be shown on the landscape plan submitted with the building permit. ESA believes this condition has been met. According to the Planting Plan included in the CAR Addendum (Sheets W2.0 and W3.0) the stream buffer and wetland buffer replacement areas outside of the 50 -foot managed forest buffer will undergo the removal of invasive species, soil stabilization with mulch, and planted with a mix of native trees and shrubs. These activities are also included in the Woodbridge Building “B” Landscape Plan submitted with the Building Permit Application. Noted. Condition met. Condition 12 Installation of permanent signs and split rail fencing is require d at the outer edge of the wetland buffers for Wetland DT and shall be completed before final inspection for the building permit. ESA believes this condition has been met. Open board fencing is proposed along the perimeter of the post-construction buffer as shown on the Planting Plan included in the CAR Addendum (Sheets W2.0 and W3.0). Noted. Condition met. Condition 13 The boundary between the wetland buffer and contiguous land shall be identified with permanent signs, which shall be a city -approved type designed for high du rability. Signs must be posted at an interval of one per every 150 feet and maintained by the property owner in perpetuity. Sheet W3.1 of the Planting Plan included in the CAR Addendum shows details for permanent signs to be placed no greater than 150 fee t apart along the critical area fencing. However, this detail has not been approved by the City. This condition has not been met. ESA recommends that the Planting Plan be revised to include City -approved sign detail for critical area signage. 3 February 2022 PAGE 5 The critical area sign detail on Sheet W3.1 of the Mitigation Plan has been revised with the updated sign detail as provided to us by the City. Condition 14 The city shall not issue any approvals to fill wetlands until all state, federal, or other agency permits as may be required to fill the wetlands have been obtained and verification provided to the city. ESA believes this condition has been met. To dat e, the City has received a Hydraulic Project Approval from the Washington State Department of Fish and Wildlife (dated December 16, 2021); an Administrative Order from the Department of Ecology (dated November 18, 2021); and a jurisdictional determination from the U.S. Corps of Engineers (dated July 27, 2021) stating that wetlands and streams in the project area are excluded from Clean Water Act jurisdiction. Noted. Condition met. Please don’t hesitate to contact me with any additional questions. Sincerely, Jennifer Marriott, PWS Owner Wet.land, LLC Enclosure: Revised Mitigation Plans, Sheets W1.0 – W4.0, revised 10 June 2022