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20-102489-Correspondence-Wetland-2020-05-22-V1 Soundview Consultants LLC Environmental Assessment • Planning • Land Use Solutions 2907 Harborview Dr., Suite D, Gig Harbor, WA 98335 Phone: (253) 514-8952 Fax: (253) 514-8954 1 779.0002 Papé Properties 1 Soundview Consultants LLC Response to Third Party Comments May 22, 2020 Technical Memorandum To: Stacey Welsh, City of Federal Way File Number: 1779.0002 From: Matt DeCaro, Soundview Consultants LLC Date: May 22, 2020 Re: Response to Third-Party Comments Papé Kenworth NW – Federal Way (City File No. 19-105322-AD and LAI Project No. 0238090.010) Dear Ms. Welsh, Soundview Consultants LLC (SVC) is assisting Papé Properties Inc. (Applicant) with wetland assessments and critical areas compliance efforts on a 19.94-acre property located at 3014 South 320th Street and 31625 32nd Avenue South in Federal Way, Washington (King County Tax Parcel Numbers 0921049028, 0921049139, 0921049140, 0921049160, 0921049187, 0921049206 and 0921049316). This Technical Memorandum has been prepared in response to review comments provided by the City of Federal Way’s (City) third-party reviewer (Landau Associates, 2020) regarding the review of SVC’s Wetland and Fish and Wildlife Habitat Assessment Report and Buffer Averaging Plan dated March 5, 2020. Requested portions of the report have been updated to address these comments (see enclosed revised report dated May 22, 2020). The following are the third-party reviewer’s comments (italicized) followed by SVC’s responses: Comment 1: LAI is clarifying that the net gain of the proposed buffer is 617 square feet, as opposed to 612 square feet identified in the March 2020 Report. After further modifications to the site layout and buffer modification plan (see response to Comment 2 below), the proposed buffer will have a net gain of 471 square feet. The updated buffer averaging plan proposes 951 square feet of buffer reduction and 1,422 square feet of buffer increase, which totals 471 square feet net gain. Comment 2: LAI concurs with the proposed buffer averaging plan, provided that additional descriptions and/or representative photographs of referenced “native vegetation” and “invasive species and fill material” in the area of the buffer increase area and buffer impact area, respectively, are provided. The response provided to criteria in FWRC 19.145.440(5)(b) references that the buffer increase area contains native species, but does not provide details of the species present. The response also identifies that the area of buffer encroachment is located within a relatively low- functioning area from a habitat standpoint due to the presence of invasive species and fill material, but does not provide details regarding the type of invasive species or fill in the area. Based on LAI’s review of the site from the reconnaissance conducted on December 18, 2019, LAI recalls trails located in the buffer encroachment area, which are also shown on 1779.0002 Papé Properties 2 Soundview Consultants LLC Response to Third Party Comments May 22, 2020 the base survey of the project area provided by the City (separate from the March 2020 Report). The presence of these trails may provide additional justification for the lower quality of buffer functions. In response to this comment, SVC performed a follow-up investigation in May 2020 to assess vegetation conditions in the buffer decrease and increase areas. Based on our observations, the location of the proposed buffer increase area has been revised to overlap with a higher functioning area that is dominated by native plants. Additional details are below, and the revised plan is included in the enclosed wetland report. The buffer reduction area (951 square feet) currently has low species diversity, and is degraded by fill material and non-native invasive vegetation such as Himalayan blackberry (Rubus armeniacus), poison hemlock (Conium maculatum), and English holly (Ilex aquifolium). A few native species are scattered in the buffer reduction area including red alder (Alnus rubra), however, the majority of the area is dominated by non-native invasive Himalayan blackberry. This area is currently the lower functioning portion of the buffer. The newly proposed buffer increase area (1,422 square feet) is located within and adjacent to a higher functioning habitat area as it contains native vegetation and does not exhibit past anthropogenic disturbances. The buffer increase area consists of native vegetation with an overstory of western red cedar (Thuja plicata), red alder, and bigleaf maple (Acer macrophyllum), and an understory of salal (Gaultheria shallon), snowberry (Symphoricarpos albus), vine maple (Acer circinatum), western swordfern, Pacific bleeding heart (Dicentra formosa), and Siberian spring beauty (Claytonia sibirica). The buffer increase area exhibits native species diversity within all three strata. The proposed buffer averaging plan will improve ecological functions by reducing the lower functioning portion of the buffer and adding to the higher functioning portion of the buffer, resulting in an overall net increase in wetland buffer area (471 square feet) and gain in ecological functions. Photographs of the buffer decrease and increase areas are provided in Attachment B of the enclosed, revised wetland report. I trust this Technical Memorandum addresses Landau Associates’ comments. Please do not hesitate to contact me with any question or concerns you may have. Sincerely, _____________________________________ Matt DeCaro Senior Scientist / Environmental Planner Enclosed: Revised Wetland and Fish & Wildlife Habitat Assessment & Buffer Averaging Plan; Papé Kenworth NW – Federal Way (May 22, 2020) 1779.0002 Papé Properties 3 Soundview Consultants LLC Response to Third Party Comments May 22, 2020 References City of Federal Way. 2020. Files #20-100968-AD Technical Review, Papé Kenworth Northwest. Prepared April 24, 2020. Federal Way Revised Code. 2020. Chapter 19.145 Environmentally Critical Areas. Passed March 3, 2020. Landau Associates, Inc. 2020. Peer Review: Papé – Wetland and Fish and Wildlife Habitat Assessment and Buffer Averaging Plan (File No. 19-105322-AD and LAI Project No. 0238090.010). Prepared April 15, 2020. Soundview Consultants (SVC). 2020. Wetland Delineation and Fish and Wildlife Habitat Assessment Report and Buffer Averaging Plan – Papé Kenworth NW. Prepared March 5, 2020.