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20-104505_Mitigation plan REV 2 11-3-2021 FINAL MITIGATION PLAN for Reasonable Use Permit P & M Development Parcels PARCEL # 1421039069, 1421039087, & 1421039043 33305 43rd Avenue Southwest and adjacent east CITY OF FEDERAL WAY WASHINGTON REVISED IN RESPONSE TO CITY OF FEDERAL WAY COMMENTS OF OCTOBER 22, 2021 City File folders #20-104505, 21-100016, 21-100-17 Prepared for: Ms. Michelle Henry, PE P & M Development LLC 35001 NE 147TH AVE Yacolt, WA 98675 p.m.development@outlook.com 360-281-8195 Prepared by Beaver Creek Environmental Services POB 731695 Puyallup, WA 98373 253 732-6515 MHeckert@Q.com REVISION 2 November 2, 2021 EXECUTIVE SUMMARY The P&M development, 33305 43rd Avenue Southwest and adjacent east (parcel #s 1421039069, 1421039087, & 1421039043) is located generally west of Hoyt Rd. SW, in the City of Federal Way, Washington. The project site is three parcels approximately 73,495 sq. ft. (1.7 acre). The site is bounded on the south, east, and west by residential development, and on the north by a vacant parcel. The site is vacant of development. As part of the site planning process an assessment of the project site was completed following the procedures outlined in the Washington State Wetlands Identification and Delineation Manual (Wash. Manual) and the Corps of Engineers Wetland Delineation Manual (2010 Supplement). Drainage corridors were also assessed in accordance with the criteria established by the City of Federal Way and the State of Washington Department of Natural Resources (WDNR) Forest Practice Rules (WAC 222 -16-030). These assessment activities resulted in the identification of one wetland area and one stream (See Wetland and Drainage Corridor Evaluation and Delineation Report and Conceptual Mitigation Plan for Reasonable Use exception, P&M Development, BCES, July 16, 2021). The site is totally encumbered by wetlands, stream, and their buffers. The selected site development action for this project site is the development of three single-family residences consistent with the City of Federal Way comprehensive plan and local land use zoning. Through site planning the project team has been able to design the house and associated utilities and access to avoid adversely impacting the identified onsite wetlands or stream. However, to obtain reasonable use of the parcels to accommodate single-family houses, the buffer of the on-site wetland and the stream will be reduced. To mitigate for the encroachment into the standard buffer, the reduced buffer area will be revegetated with native trees and shrubs. TABLE OF CONTENTS INTRODUCTION............................................................................................................. 1 STUDY PURPOSE ......................................................................................................... 1 SITE DESCRIPTION ..................................................................................................... 1 MITIGATION PLAN ....................................................................................................... 1 REASONABLE USE STANDARD AND ADHERENCE............................................. 3 DESCRIPTION OF THE MITIGATION PROGRAM ................................................... 3 GOAL AND OBJECTIVE OF THE MITIGATION PLAN ........................................... 4 SELECTED PLANT COMMUNITIES .......................................................................... 5 RESTORATION PLANTING GUIDELINES ............................................................... 7 CONSTRUCTION INSPECTION ................................................................................. 8 MITIGATION CONSTRUCTION SCHEDULE ........................................................... 9 STANDARDS OF SUCCESS ........................................................................................ 9 Vegetation Sampling Methodology and Monitoring Schedule ................................... 9 Vegetation Monitoring ................................................................................................ 9 WILDLIFE OBSERVATIONS .................................................................................... 11 COVERAGE FOR EXPOSED BUFFER AREA .......................................................... 11 CONTINGENCY PLAN .............................................................................................. 11 PLANTING NOTES ..................................................................................................... 12 REFERENCE LIST ........................................................................................................ 13 ATTACHMENT 1 - Bond Quantity Worksheet…….……………………………….......15 ATTACHMENT 2-5 - Mitigation Plan Drawings ………………………………………16 ATTACHMENT 6 - Reasonable Use Application Letter 9-15-21 with Attachments 20 ATTACHMENT 7 - Storm Water Narrative 9-15-21 with TIR Attached …………… STANDARD OF CARE Prior to extensive site planning, this document should be reviewed and the wetland boundaries verified by the appropriate resource and permitting agencies. Wetland boundaries, wetland classifications, wetland ratings, proposed buffers, and proposed compensatory mitigation should be reviewed and approved by City of Federal Way Planning dept. personnel and potentially other resource agency staff. BCES has provided professional services that are in accordance with the degree of care and skill generally accepted in the nature of the work accomplished. No other warranties are expressed or implied. BCES is not responsible for design costs incurred before this document is approved by the appropriate resource and permitting agencies. Mark Heckert Beaver Creek Environmental Services [BCES] 1 P&M FedWay Mitigation Plan REV. 2 INTRODUCTION This report details activities to mitigate for unavoidable impacts to regulated City of Federal Way Environmentally Critical Areas as an initial element of the site planning process for the P&M DEVELOPMENT (Parcel #s 1421039069, 1421039087, & 1421039043). The project site is three parcels, approximately 73,495 sq. ft.. The site is bounded on the south, east, and west by residential development, and on the north by a vacant parcel. The site is vacant of development. STUDY PURPOSE This purpose of this document is to present the plan for mitigation of unavoidable impacts to the regulated wetland buffer within the project site. This study was designed to accommodate site planning and potential regulatory actions. This report is suit able for submittal to federal, state, and local authorities for wetland boundary verification and permitting actions. SITE DESCRIPTION The site is irregular, approximately 1.7 ac., sloping to the north throughout, and located within an urbanizing area of the City of Federal Way. Movement of surface water runoff across the site is generally to the north to the stream (Joes Cr.), and to the wetland. The majority of onsite surface water runoff pools on -site and infiltrates. MITIGATION PLAN The selected site development action for the P&M Development is the development of three single-family residences consistent with the City of Federal Way comprehensive plan and local land use zoning. The creation of these residences will include the estab lishment of houses and internal access for driveway and utilities. Through site planning the project team has been able to design the homesite and associated utilities to avoid unnecessarily adversely impacting the identified onsite wetland and stream. However, site characteristics, including parcel size, the proximity of regulated stream and wetlands, and the size of their respective buffers, makes reasonable development of the parcels to single-family houses impossible. The standard buffers of the stream and wetland must be reduced more than allowed by standard regulation to accommodate reasonable use of the site. Therefore, proponent requests permitting of these parcels under City of Federal Way Title 19.145.090 Reasonable use of the subject property (below). 2 P&M FedWay Mitigation Plan REV. 2 19.145.090 Reasonable use of the subject property. (1) The provisions of this section establish a mechanism whereby the provisions of this chapter may be modified or waived on a case-by-case basis if their implementation would deprive an applicant of all reasonable use of the subject property. (2) An applicant may apply for a modification or waiver of the provisions of this chapter using process IV; except, that applications for projects on single-family residential lots may use process III. (3) The city may approve a modification or waiver of the requirements of this chapter on a case- by-case basis based on the following criteria: (a) The application of the provisions of this chapter eliminates all reasonable use of the subject property; RESPONSE: see “Reasonable Use Application Letter 9-15-21 with Attachments” attached. (b) No feasible and reasonable on-site alternatives to the proposal are possible, such as changes to site layout and/or reduction of impervious improvements; RESPONSE: see “Reasonable Use Application Letter 9-15-21 with Attachments” attached. (c) It is solely the implementation of this chapter, and not other factors, that preclude all reasonable use of the subject property; RESPONSE: see “Reasonable Use Application Letter 9-15-21 with Attachments” attached. (d) The applicant has in no way created or exacerbated the condition that forms the limitation on the use of the subject property, nor in any way contributed to such limitation; and RESPONSE: see “Reasonable Use Application Letter 9-15-21 with Attachments” attached. (e) The waiver or modification will not lead to, create nor significantly increase the risk of injury or death to any person or damage to improvements on or off the subject property. RESPONSE: see “Reasonable Use Application Letter 9-15-21 with Attachments” attached. 3 P&M FedWay Mitigation Plan REV. 2 Intrusion into Stream Buffers The stormwater plan and TIR compliments the Wetland and Drainage Corridors Evaluation & Delineation Report (Wetland Report) and the Final Mitigation Plan to provide buffer enhancements that meet the provisions of the Federal Way Revised Code 19.145.330 for intrusion into the stream buffers. FWRC 19.145.330 (2) Stream buffer intrusions may be permitted with a buffer enhancement plan. The applicant shall demo nstrate that the remaining and enhanced reduced buffer will function at an equivalent or higher level than the standard buffer. The plan shall provide an assessment of the following existing functions and conditions of the buffer and the effect of the prop osed modification on those functions: (a) Habitat (b) Water quality (c) Stormwater retention capabilities (d) Groundwater recharge, and (e) Erosion protection The proposed stormwater design protects habitat with a proposed method for flow control and water quality that enhances the stream buffer to provide the same ecological benefit as enhanced areas outside of the stormwater flow paths. Habitat is addressed mo re fully within the project’s wetland report. The proposed project supports wildlife in critical areas and the critical area buffers. The proposed naturally vegetated flow paths that provide full dispersion of stormwater runoff improve the buffer function to provide both flow control and water quality per BMP provided in the KCSWDM, Appendix C.2.1 for full dispersion. The NVFP collects stormwater runoff from impervious surfaces and pollution generating pervious surfaces and slowly infiltrates the stormwater with some overland flow and naturally slows and filters the flow by using native vegetation, providing a natural pre-development discharge flow to critical areas. It also provides for long term erosion protection since soils will be stabilized with native vegetation to generate a sediment free discharge from the buffer regions to the stream. The prescriptive methods for this stormwater BMP, naturally vegetated flow paths, has been provided in the KCSWDM as a stormwater management method allowed within critical area buffers and meets all the provisions of FWRC 19.145.330 (3) since naturally vegetated flow paths enhance the buffer function and; (a) will not adversely affect water quality, (b) will not adversely affect the existing quality of wildlife habita t within the stream or buffer area, (c) will not adversely affect drainage or stormwater retention capabilities, (d) will not lead to unstable earth conditions or create erosion hazards, (e) will not be materially detrimental to any other property in the a rea of the subject property nor to the city as a whole, and (f) is necessary for reasonable development of the subject property. The stormwater TIR evaluates this method of flow control and water quality in more detail in Chapter 4 starting on page 22 and includes an offsite analysis to show stormwater 4 P&M FedWay Mitigation Plan REV. 2 runoff from the proposed development will not generate any adverse impacts downstream. ✓ The provisions of FWRC 19.145.330 (2) for instruction into stream buffers have been met. Development in Wetland Buffers The stormwater TIR and plan in combination with the Wetland and Drainage Corridors Evaluation & Delineation Report (Wetland Report) and the Final Mitigation Plan provide for buffer enhancements. The project cannot meet Federal Way Revised Code 19.145.440 (6) Development in Wetland Buffers which states, ‘Buffers may be reduced up to 25% on a case by case basis if the project includes a buffer enhancement plan that clearly substantiates that the enhanced buffer will improve and provide additio nal protection of wetland functions and values.’ The existing roadway has already reduced the buffer width by more than 25%. The project seeks a Reasonble Use Exception to reduce the buffer width to provide for reasonable use of each lot. There is a total of 51,444 SF of buffer area on all three lots which is contiguous to the wetland across all three lots on the northern portions of each project site. The proposed clearing and grading of 8,315 SF intrudes beyond the existing roadway into the wetland buffer. The stormwater BMP described using naturally vegetated flow paths for full dispersion will be constructed on all lots with construction of the first lot to meet public works requirements for stormwater treatment of the existing roadways improved imper vious surfaces. In general, 1,000 SF (10’ W x 100’ L) of naturally vegetated flow path provides for full dispersion of runoff from 1,400 SF of impervious, per the KCSWDM Section C.2.1.7 Table for Full Dispersion, page 38. The stormwater plan proposes a t otal of 8,750 SF of naturally vegetated flow paths within three separate enhanced buffer regions to improve the buffer function with stormwater flow control and water quality using this method to protect the buffers and wetland. These areas are clearly identified on the Stream Buffer and Wetland Buffer Intrusion maps. The proposed stormwater enhancement areas improving buffer function for stormwater are in addition to the mitigation enhancement areas with some overlap as identified on the Stream Buffer and Wetland Buffer Maps that have been provided for each lot. Both the enhanced buffer for stormwater treatment and the additional buffer areas for mitigation serve the same purpose with dual function to protect critical areas and improve habitat to meet the provisions of FWRC 19.145.440 for Development within wetland buffers by improving water quality, improving the existing quality of the wetland and buffer for wildlife habitat, improving drainage and stormwater retention capabilities, controlling erosion wi th native vegetation to stabilize soils, and will bring value to the community and city. As per FWRC 19.145.440 Development within wetland buffers, the buffer enhancements improve water quality, improves the quality of the wetland and wildlife habitat, control 5 P&M FedWay Mitigation Plan REV. 2 stormwater, provide stabilized soils for erosion control with natural vegetation, and will not be materially detrimental in any way. REV. 2 Discussion of Stream & Wetland Buffers Intrusion into Stream Buffers The stormwater plan and TIR compliments the Wetland and Drainage Corridors Evaluation & Delineation Report (Wetland Report) and the Final Mitigation Plan to provide buffer enhancements that meet the provisions of the Federal Way Revised Code 19.145.330 for intrusion into the stream buffers. FWRC 19.145.330 (2) Stream buffer intrusions may be permitted with a buffer enhancement plan. The applicant shall demonstrate that the remaining and enhanced reduced buffer will function at an equivalent or higher leve l than the standard buffer. The plan shall provide an assessment of the following existing functions and conditions of the buffer and the effect of the proposed modification on those functions: (f) Habitat (g) Water quality (h) Stormwater retention capabilities (i) Groundwater recharge, and (j) Erosion protection The proposed stormwater design protects habitat with a proposed method for flow control and water quality that enhances the stream buffer to provide the same ecological benefit as enhanced areas outside of the stormwater flow paths. Habitat is addressed more fully within the project’s wetland report. The proposed project supports wildlife in critical areas and the critical area buffers. The proposed naturally vegetated flow paths that provide full dispersion of stor mwater runoff improve the buffer function to provide both flow control and water quality per BMP provided in the KCSWDM, Appendix C.2.1 for full dispersion. The NVFP collects stormwater runoff from impervious surfaces and pollution generating pervious sur faces and slowly infiltrates the stormwater with some overland flow and naturally slows and filters the flow by using native vegetation, providing a natural pre-development discharge flow to critical areas. It also provides for long term erosion protection since soils will be stabilized with native vegetation to generate a sediment free discharge from the buffer regions to the stream. The prescriptive methods for this stormwater BMP, naturally vegetated flow paths, has been provided in the KCSWDM as a stormwater management method allowed within critical area buffers and meets all the provisions of FWRC 19.145.330 (3) since naturally vegetated flow paths enhance the buffer function and; (a) will not adversely affect water quality, (b) will not adversely affect the existing quality of wildlife habitat within the stream or buffer area, (c) will not adversely affect drainage or stormwater retention capabilities, (d) will not lead to unstable earth conditions or create erosion hazards, (e) will not be 6 P&M FedWay Mitigation Plan REV. 2 materially detrimental to any other property in the area of the subject property nor to the city as a whole, and (f) is necessary for reasonable development of the subject property. The stormwater TIR evaluates this method of flow control and water quality in more de tail in Chapter 4 starting on page 22 and includes an offsite analysis to show stormwater runoff from the proposed development will not generate any adverse impacts downstream. ✓ The provisions of FWRC 19.145.330 (2) for instruction into stream buffers have been met. Development in Wetland Buffers The stormwater TIR and plan in combination with the Wetland and Drainage Corridors Evaluation & Delineation Report (Wetland Report) and the Final Mitigation Plan provide for buffer enhancements. The project cannot meet Federal Way Revised Code 19.145.440 (6) Development in Wetland Buffers which states, ‘Buffers may be reduced up to 25% on a case by case basis if the project includes a buffer enhancement plan that clearly substantiates that the enhanced buffer will improve and provide additional protection of wetland functions and values.’ The existing roadway has already reduced the buffer width by more than 25%. The project seeks a Reasonable Use Exception to reduce the buffer width to provide for reasonable use of each lot. There is a total of 51,444 SF of buffer area on all three lots which is contiguous to the wetland across all three lots on the northern portions of each project site. The proposed clearing and grading of 8,315 SF intrudes beyond the existing roadway into the wetland buffer. The stormwater BMP described using naturally vegetated flow paths for full dispersion will be constructed on all lots with construction of the first lot to meet public wor ks requirements for stormwater treatment of the existing roadways improved impervious surfaces. In general, 1,000 SF (10’ W x 100’ L) of naturally vegetated flow path provides for full dispersion of runoff from 1,400 SF of impervious, per the KCSWDM Section C.2.1.7 Table for Full Dispersion, page 38. The stormwater plan proposes a total of 8,750 SF of naturally vegetated flow paths within three separate enhanced buffer regions to improve the buffer function with stormwater flow control and water quality using this method to protect the buffers and wetland. These areas are clearly identified on the Stream Buffer and Wetland Buffer Intrusion maps. The proposed stormwater enhancement areas improving buffer function for stormwater are in addition to the mitigation enhancement areas with some overlap as identified on the Stream Buffer and Wetland Buffer Maps that have been provided for each lot. Both the enhanced buffer for stormwater treatment and the additional buffer areas for mitigation serve the same purpose with dual function to protect critical areas and improve habitat to meet the provisions of FWRC 19.145.440 for Development within wetland buffers by improving water quality, improving the existing quality of the wetland and buffer for wildlife 7 P&M FedWay Mitigation Plan REV. 2 habitat, improving drainage and stormwater retention capabilities, controlling erosion with native vegetation to stabilize soils, and will bring value to the community and city. As per FWRC 19.145.440 Development within wetland buffers, the buffer enhancements improve water quality, improves the quality of the wetland and wildlife habitat, control stormwater, provide stabilized soils for erosion control with natural vegetation, and will not be materially detrimental in any way. Mitigation Sequencing: Mitigation planning for this site followed standard and accepted mitigation sequencing protocol of Avoidance, Minimization, Mitigation. The development cannot be avoided to obtain use of the parcels. The development is minimized by siting the development as far to the south boundary as possible, in an area of previous impact. The development envelopes are minimized, and accessed through a common access. Planting is proposed for all unvegetated areas, resulting in the greatest mitigation possible on the site. An encroachment into the identified buffer for the on -site wetland and stream is required to establish the home sites. The proposed development is the minimum required to achieve reasonable use of the site. The development is situated as far from the wetland and stream as practicable. Mitigation for the required buffer impact at the eastern boundary of the project site will be provided by re planting the retained buffer, as well as the Flow Control BMP Vegetated Flow Paths (FCVFP) and the areas would be planted with a variety of native trees and shrubs. Wetland enhancement and a reduction in the front-yard setback were also proposed as additional mitigation for the required buffer reduction. Th ese measures were disallowed be the city reviewer. The proposed measures are the maximum mitigation possible on these parcels while still providing for reasonable development. Through this compensatory mitigation the development would not result in a “net loss” of regulated wetland area, function, or value consistent with City of Federal Way Zoning Code. REV.2 numbers revised Stream Buffer Impact & Mitigation Areas Analysis – (in sq. ft.) PARCEL # Development Impact Mitigation Enhancement Stormwater Enhancement Enhancement Overlap Total Enhancement Mitigation ratio MITIGATION : IMPACT 9069 1080 4822 4365 (4025 +340) 1575 (1300 +275) 7612 6.2 : 1 9087 2820 3370 1090 400 4060 1.4 : 1 9043 2325 2450 1515 0 3965 1.7 : 1 TOTAL 6225 10642 6970 1975 15673 2.5 : 1 8 P&M FedWay Mitigation Plan REV. 2 Wetland Buffer Impact & Mitigation Areas Analysis – (in sq. ft.) PARCEL # Development Impact Mitigation Enhancement Stormwater Enhancement Enhancement Overlap Total Enhancement Mitigation ratio MITIGATION : IMPACT 9069 3170 2062 6160 (4880 +1500) 1575 (1300 +275) 6647 2.1 : 1 9087 2820 2130 1090 400 2820 1 : 1 9043 2325 2450 0 0 2450 1.1 : 1 TOTAL 8315 6642 7250 1975 11917 1.4 : 1 The Mitigation Enhancement Area and the FCVFPs are areas of fill placed on presumably wetland many years prior. The FCVFPs will be channeling stormwater thru the sites to the wetland. As such, a matrix of FAC, FACU, and FACW species are proposed to vegetate what may be a complex water regime. Fencing: A fence will be installed at the southern reduced buffer boundary of the wetland and stream. City of Federal Way wetland buffer boundary will be attached on every third post. No further activity will occur within the fenced area once enhancement planting is complete. The existing wetland in the interior of the site has been degraded by prior filling and clearing of vegetation. Potential impacts to habitat from the development are: 1). Short-term construction disruption. This impact will be mitigated thru the placement of silt fence barriers in every area which may flow into the wetland and stream (see P&M development Site Civil Plans, erosion control Plan) and oversight by the project biologist during construction. The project biologist will observe and consult with construction crews during construction to ensure compliance with best management practices during the excavation of the buffer area. 2). Long-term impacts from development: a). Permanent loss of habitat area. There will be no functional loss of habitat area. The present wetland and buffer in the mitigation area is poor functional. Functional buffer area will increase as a result of installation of trees. b). Loss of habitat utility due to light and noise from the development and increased visitation by people. Lighting of the developed area will increase “spillover” of light to the mitigated buffer and wetland. All lighting will be directed away from the mitigation area. A boundary planting of shrubs will be placed within the retained buffer to provide light and auditory shading. The boundary fence will be a 2-post cedar fence to inhibit intrusion by people. REV. 2 Functional Comparison removed 9 P&M FedWay Mitigation Plan REV. 2 DESCRIPTION OF THE MITIGATION PROGRAM 1. As mitigation for the unavoidable impact to 8,315 sq. ft. of City of Federal Way regulated Category 2 Wetland and 6,225 sq. ft. of Type F Stream buffers (overlapping) at the north boundary of the project site, the retained buffer of 10,642 sq. ft. will be restored with native trees and shrubs (Stream Buffer and Wetland Buffer Maps, attached). The Flow Control BMP Vegetated Flow Paths (FCVFP) of 6970 sq. ft. will be enhanced with native shrubs (Storm Water Narrative 9-15-21 with TIR Attached, attached). The upland area to be enhanced is presently dominated by reed canarygrass. The FCVFP areas to be enhanced will be cleared of exotic species and planted with native shrubs around existing vegetation. Supportive hydrolog y will continue to be provided by the existing stream corridor. Additional hydrology will be supplied by storm drains to the FCVFP areas. FCVFP areas will be hydroseeded with wetland buffer emergents. 2. Temporary and long-term erosion control measures will be implemented (see Storm Water Narrative 9-15-21 with TIR Attached, attached). These measures include silt fencing during site preparation and buffer enhancement, retention of all possible existing vegetation and planting of new vegetation. 3. All onsite activities will be monitored by the project biologist. Following the completion of onsite planting activities, a "record-drawing" plan will be prepared and submitted to City of Federal Way. A five-year monitoring program will be undertaken to assure the success of the buffer enhancement program. A series of financial guarantees will also be implemented to assure that the proposed work is completed and is successful. 4. The outer boundaries of the established buffer tract would be marked with standard City of Federal Way buffer boundary signs. The buffer boundaries will be fenced to limit human intrusions between the upland boundary of the remaining buffer and the developed portion of the site. In addition, the project team will remove the trash, debris, and invasive shrubs within the retained wetland and buffer areas. 5. Wetland, stream and buffer vegetation cleared or otherwise damaged during the installation of the mitigation plan shall be revegetated with appropriate native plants installed at an appropriate density to restore the damaged condition. These plants shall be subject to the same performance standards indicated in the mitigation plan. REV. 2 no inwater work. 6. No mitigation activity will occur waterward of the Ordinary High Water Mark GOAL AND OBJECTIVE OF THE MITIGATION PLAN The GOAL of the Mitigation Plan is to fully compensate for the unavoidable adverse impact to regulated buffer areas. Upon the completion of this mitigation plan there will be 10 P&M FedWay Mitigation Plan REV. 2 no net loss of wetland acreage, functions, or values; and an increase in the potential f or the buffer to protect aquatic habitats. To achieve the defined GOAL, the following OBJECTIVES and PERFORMANCE CRITERIA have been established to apply to the compensatory mitigation wetland area.: Objective A. The retained & enhanced buffer area will total 10,642 sq. ft. and be located directly north of the houses. The enhanced buffer will be hydrologically connected to the adjacent City of Federal Way Category II wetland and Type F Stream. The enhanced buffer area will exhibit a scrub/shrub vegetation class within five years following initial planting. Rev. 2 Trees added Performance Criterion #A1: As defined by plant counts 100% of the trees and shrubs installed as a part of the initial planting phase will be alive at the end of the first growing season. Performance Criterion #A2: As defined by plant counts 80% of the trees and shrubs installed as a part of the initial planting phase will be alive at the end of the fifth growing season. Performance Criterion #A3: As defined by aerial cover, invasives will cover less than 10% of the planting area in any one year. Objective B. The Flow Control BMP Vegetated Flow Paths (FCVFP) of 6,970 sq. ft. will be located adjacent to the houses. The FCVFP will be hydrologically connected to the City of Federal Way Category II wetland and Type F Stream. The enhanced FCVFP areas will exhibit a shrub vegetation class within five years following initial planting. Performance Criterion #B1: As defined by plant counts 100% of the shrubs installed as a part of the initial planting phase will be alive at the end of the first growing season. Performance Criterion #B2: As defined by plant counts 80% of the shrubs installed as a part of the initial planting phase will be alive at the end of the fifth growing season. Performance Criterion #B3: As defined by aerial cover, invasives will cover less than 10% of the planting area in any one year. SELECTED PLANT COMMUNITIES 11 P&M FedWay Mitigation Plan REV. 2 The plant communities and plants selected for the created wetland and buffer areas will be obtained as nursery stock. These selected species are native and commonly occur in the local area. The plant species prescribed are selected to increase plant diversity, match present onsite communities, increase wildlife habitats, and enhance the aquatic environment. Plantings will be located as depicted on the attached P&M Development Mitigation Plan drawing. The overlapping areas of the Mitigation Enhancement Area and the FCVFPs will be planted as Mitigation Enhancement Area. REV. 2 areas changed MITIGATION ENHANCEMENT PLANTING AREA: RETAINED BUFFER – 10,642 sq. ft. @ 0.012/sq. ft. = 128 trees COMMON NAME SCIENTIFIC NAME LOCATION PROPOSED SPACING (oc) PROPOSED SIZE INDICATOR STATUS 19 Western red cedar (THP) Thuja plicata Buffer 9 ft 4 ft height minimum FAC 19 Sitka spruce (PIS) Picea sitchensis Buffer 9 ft 4 ft height minimum FAC 18 Oregon ash (FRL) Fraxinus latifolia Buffer 9 ft 4 ft height minimum FACW 18 Western Paper Birch(BEP) Betula papyrifera Buffer 9 ft 4 ft height minimum FAC 18 Scouler willow(SAC) Salix scouleriana Buffer 9 ft 4 ft height minimum FAC 18 Cascara (RAP) Rhamnus purshiana Buffer 9 ft 4 ft height minimum FAC 18 Western (black) Hawthorne (CRD) Crataegus douglasii Buffer 9 ft 4 ft height minimum FAC 10,642 sq. ft. @ 0.028/sq. ft. = 298 shrubs COMMON NAME SCIENTIFIC NAME LOCATION PROPOSED SPACING (oc) PROPOSED SIZE INDICATOR STATUS 28 Western crabapple (PYF) Pyrus fusca Buffer 6 ft 2 gal FACW 28 Vine maple (ACC) Acer circinatum Buffer 6 ft 2 gal FACU 28 Wild rose (ROG) Rosa gymnocarpa Buffer 6 ft 2 gal FACU 28 Black twinberry (LOI) Lonicera involucrata Buffer 6 ft 2 gal FAC+ 28 Pacific ninebark (PHC) Physocarpus capitatus Buffer 6 ft 2 gal FACW- 28 Hazelnut (COC) Corylus cornuta Buffer 6 ft 2 gal FACU 12 P&M FedWay Mitigation Plan REV. 2 28 Red-osier dogwood(COS) Cornus stolonifera Buffer 6 ft 2 gal FACW 28 Wild Gooseberry(RID) Ribes divaricatum Buffer 6 ft 2 gal FAC 28 Nootka Rose(RON) Rose nutkana Buffer 6 ft 2 gal FAC 28 Stink currant(RIB) Ribes bracteosum Buffer 6 ft 2 gal FAC 28 Thimbleberry(RUP) Rubus parviflorus Buffer 6 ft 2 gal FAC- FCVFP 1 PLANTING AREA: – 1,500 sq. ft. @ 0.028/sq. ft. = 42 shrubs COMMON NAME SCIENTIFIC NAME LOCATION PROPOSED SPACING (oc) PROPOSED SIZE INDICATOR STATUS 7 Western crabapple (PYF) Pyrus fusca FCVFP 6 ft 2 gal FACW 7 Vine maple (ACC) Acer circinatum FCVFP 6 ft 2 gal FACU 7 Wild rose (ROG) Rosa gymnocarpa FCVFP 6 ft 2 gal FACU 7 Black twinberry (LOI) Lonicera involucrata FCVFP 6 ft 2 gal FAC+ 7 Pacific ninebark (PHC) Physocarpus capitatus FCVFP 6 ft 2 gal FACW- 7 Hazelnut (COC) Corylus cornuta FCVFP 6 ft 2 gal FACU FCVFP 2 PLANTING AREA: – 4,365 sq. ft. @ 0.028/sq. ft. = 122 shrubs COMMON NAME SCIENTIFIC NAME LOCATION PROPOSED SPACING (oc) PROPOSED SIZE INDICATOR STATUS 12 Western crabapple (PYF) Pyrus fusca FCVFP 6 ft 2 gal FACW 12 Vine maple (ACC) Acer circinatum FCVFP 6 ft 2 gal FACU 12 Wild rose (ROG) Rosa gymnocarpa FCVFP 6 ft 2 gal FACU 12 Black twinberry (LOI) Lonicera involucrata FCVFP 6 ft 2 gal FAC+ 13 P&M FedWay Mitigation Plan REV. 2 12 Pacific ninebark (PHC) Physocarpus capitatus FCVFP 6 ft 2 gal FACW- 12 Hazelnut (COC) Corylus cornuta FCVFP 6 ft 2 gal FACU 12 Red-osier dogwood(COS) Cornus stolonifera FCVFP 6 ft 2 gal FACW 12 Wild Gooseberry(RID) Ribes divaricatum FCVFP 6 ft 2 gal FAC 12 Nootka Rose(RON) Rose nutkana FCVFP 6 ft 2 gal FAC 12 Stink currant(RIB) Ribes bracteosum FCVFP 6 ft 2 gal FAC 12 Thimbleberry(RUP) Rubus parviflorus FCVFP 6 ft 2 gal FAC- FCVFP 3 PLANTING AREA: – 1,515 sq. ft. @ 0.028/sq. ft. = 42 shrubs COMMON NAME SCIENTIFIC NAME LOCATION PROPOSED SPACING (oc) PROPOSED SIZE INDICATOR STATUS 6 Western crabapple (PYF) Pyrus fusca Buffer 6 ft 2 gal FACW 6 Vine maple (ACC) Acer circinatum Buffer 6 ft 2 gal FACU 6 Wild rose (ROG) Rosa gymnocarpa Buffer 6 ft 2 gal FACU 6 Black twinberry (LOI) Lonicera involucrata Buffer 6 ft 2 gal FAC+ 6 Hazelnut (COC) Corylus cornuta Buffer 6 ft 2 gal FACU 6 Red-osier dogwood(COS) Cornus stolonifera Buffer 6 ft 2 gal FACW 6 Thimbleberry(RUP) Rubus parviflorus Buffer 6 ft 2 gal FAC- ENHANCEMENT PLANTING GUIDELINES 1. Trees 9’ O.C., or 0.012 per square foot of area; (this assumes 2 -5 gal. size) — such trees are to be at least 50% conifers; 2. Plus shrubs 6’ O.C., or 0.028 per square foot (this assumes 1 -2 gal. size); CONSTRUCTION INSPECTION Essential to the success of the compensatory mitigation program is the accurate inspection of onsite activities immediately prior to and during the wetland creation and 14 P&M FedWay Mitigation Plan REV. 2 planting phases. These activities include pre-construction site inspection, onsite inspection and technical direction during wetland creation and planting activities, and post-creation/planting site inspection and evaluation. The pre-creation site inspection allows the project proponent and the project biologis t to evaluate and, if necessary, adjust the onsite construction steps. These steps include analysis of project site elevation features, project sequencing and timing, final grade analysis, unforeseen required minor modifications to the original establishm ent plan, and the establishment of environmental protections (silt fences, etc.) required during construction. Interaction with City of Federal Way wetland staff is also an essential element during pre-construction site inspections and discussions. Onsite technical inspection during construction and planting activities will be implemented by the project biologist. The project biologist will perform oversight and address minor unforeseen difficulties to assure that the intent of the wetland mitigation plan is met. The project biologist shall also be responsible for ensuring that the species and sizes of native plants selected are utilized during initial planting. If selected native species become unavailable, the project biologist will consult with C ity of Federal Way wetland staff for substitute plant species to ensure that the intent of the wetland mitigation plan is met. Post-creation site inspection/evaluation will include the preparation of a "record drawing” which will be submitted to City of Federal Way wetland staff. VEGETATION MAINTENANCE PLAN Maintenance of the created wetland and buffer plant communities may be required to assure the long-term health and welfare of the wetland's and buffer's environmental functions. The overall objective is to establish undisturbed plant communities that do not require maintenance. The reduced wetland buffer will require irrigation for the monitoring period. Irrigation will be supplied June 1 thru September 1 at a rate of 1 inch per week. Activities will include, but are not limited to, the removal of invasive non -native vegetation and the additional irrigation of selected areas. Established maintenance activities include the removal of any trash within the buffer. MITIGATION CONSTRUCTION SCHEDULE PROJECT TASK TASK SCHEDULE (On or before) Onsite pre-creation meeting September, 2021 Placement of protective fencing, final marking, and identification of work area. September, 2021 Planting of enhancement wetland & buffer November, 2021 15 P&M FedWay Mitigation Plan REV. 2 Record-drawings report to City December,2021 PROJECT MONITORING Following the successful completion of the proposed compensatory mitigation plan a five- year monitoring and evaluation program will be undertaken. The purpose of this program is to assure the success of the selected mitigation as measured by an establishe d set of performance criteria (see above). This monitoring will also provide valuable information on the effectiveness of mitigation procedures. STANDARDS OF SUCCESS Vegetation Sampling Methodology and Monitoring Schedule Onsite monitoring will count and clearly identify each tree and shrub installed during the initial planting phase. Such monitoring will also include any subsequent planting required to meet the performance criteria. These defined performance criteria wil l be applied at the time of monitoring. All installed trees and shrubs will be visually evaluated to determine the rate of survivorship, health, and vigor of each plant. Vegetation Monitoring 1. Upon the completion of initial planting and as a part o f each monitoring period the project biologist will count the number of live plants which were planted within the wetland and buffer areas. Plants will be identified to species and observations of general plant condition (i.e., plant health, amount of new growth) are to be recorded for each plant. 2. The project biologist will count the number of undesirable invasive plants and estimate the aerial coverage (as if the observer were looking straight down from above) of these invasive plants. Undesirable plants include blackberries, Scot’s broom, tansy ragwort, and other such plants listed in the Washington State Noxious Weed List. 3. The project biologist will count the number of desirable "volunteer" plants and estimate the aerial coverage of these plants within the mitigation area. 4. The project biologist will take photographs that show the entire mitigation area. During the five-year monitoring period photos will be taken in the same direction and at the same location to provide a series of photos. These photos will show plant growth, plant species, and plant coverage. 5. Upon the completion of the initial project planting and upon the completion of each monitoring period the project biologist will prepare a report defining methods, 16 P&M FedWay Mitigation Plan REV. 2 observations, and results along with the date the observations were completed. Each report will be sent to the City of Federal Way Planning Dept.. 6. The monitoring schedule is defined as: A. At the completion of initial project planting. This report will include a “record drawing” defining the species used, locations, and general site conditions. This report will also include a “lessons learned” section to assist in future monitoring and final project assessment. This “record drawing” and report will be provided to the City within two weeks after the completion of onsite planting. B. Once per year for five years following the completion of initial onsite planting. Onsite monitoring will be completed once near the end of the growing season (late September). For each onsite monitoring activity, a report will be prepared and provided to the city within two weeks after the completion of onsite monitoring. The last monitoring report will include notification to the City biologist that the monitoring program has concluded and that City review and site inspection is required for project analysis and release of the financial guarantee. This final report will also in clude a “lessons learned” section to assist and final project assessment and to potentially assist in the evaluation other mitigation projects. Vegetation Monitoring Sequencing IDENTIFIED TASK DATE OF COMPLETION (On or before) First growing season fall plant inspection September 30, 2022 First growing season fall report October 15, 2022 Second growing season fall plant inspection September 30, 2023 Second growing season fall report October 15, 2023 Third growing season fall plant inspection September 30, 2024 Third growing season fall report October 15, 2024 Fourth growing season fall plant inspection September 30, 2025 Fourth growing season fall report October 15, 2025 Fifth growing season fall plant inspection September 30, 2026 Fifth growing season fall report October 15, 2026 WILDLIFE OBSERVATIONS Observations of wildlife will coincide with the onsite activities undertaken as part of the Vegetation Monitoring Program. The onsite team will document the extent of bird species 17 P&M FedWay Mitigation Plan REV. 2 abundance, site utilization, nesting and feeding activities, and species di versity. In addition, documentation of terrestrial and aquatic reptiles, amphibians, and mammals observable without trapping will also be documented. Wildlife observations will be documented within the Vegetation Monitoring Reports noted above. REMOVAL OF INVASIVE NON-NATIVE VEGETATION As a contingency, should the removal of invasive non-native vegetation become necessary, the project proponent will contact City of Federal Way wetland staff to establish and define specific actions to be taken. Resultant contingency plan activities will be implemented when the ongoing vegetation monitoring program indicates that plants listed in the Washington State Noxious Weed List and Scot's broom are becoming dominant in the community (greater than 20%). Following initial planting of the wetland and buffer areas the project team will undertake an invasive vegetation control program through the five-year monitoring program. This control program will focus on biannual hand-removal of re-sprouting invasive shrubs and will not adversely impact the desirable plants within the wetland and buffer. SALVAGE AND REUSE OF WOODY MATERIAL Woody material salvaged from trees cleared for construction of the new home will be salvaged and installed as large woody debris in the retained wetland and the wetland mitigation planting areas. No woody material will be imported to the site. Vegetation Control Program Schedule TASK TO BE COMPLETED ON OR ABOUT First growing season fall removal September 15, 2022 Second growing season fall removal September 15, 2023 Third growing season fall removal September 15, 2024 Fourth growing season spring removal September 15, 2025 Fifth growing season fall removal September 15, 2026 COVERAGE FOR EXPOSED BUFFER AREA Coverage for all exposed surfaces within the mitigation area will be completed within two weeks following the completion of onsite grading. Coverage will be by hydroseeding wetland buffer mix. CONTINGENCY PLAN As a contingency, should the proposed compensatory plan fail to meet the performance criteria the project proponent will undertake required remedial actions. Where plant 18 P&M FedWay Mitigation Plan REV. 2 survival is the failing component the project proponent will replant and ensure the success of this second planting which would be held to the same standard of success as measured by threshold criteria and monitoring processes. Should additional remedial actions be required, the project proponent will meet with City of Federal Way environmental staff to establish and define actions to be taken to meet the desired goal of this program. PLANTING NOTES All plant materials shall be native to the southern Puget Sound Region. The project biologist shall inspect plant materials to ensure the appropriate plant schedule and plant characteristics are met. The project proponent shall warrant that all plants wi ll remain alive and healthy for a period of one year following completion of planting activities. The project proponent shall replace all dead and unhealthy plants with plants of the same specifications. 19 P&M FedWay Mitigation Plan REV. 2 REFERENCE LIST Adamus, P.R., E.J. Clairain Jr., R.D. Smith, and R.E. Young. 1987. Wetland Evaluation Technique (WET); Volume II: Methodology, Operational Draft Technical Report Y -87, U.S. Army Engineer Waterways Experiment Station, Vicksburg, Mississippi. Cowardin, L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. Office of Biological Services, U.S. Fish and Wildlife Service, U.S. Department of the Interior, FWS/OBS-79/31. Environmental Laboratory. 1987. "Corps of Eng ineers Wetlands Delineation Manual," Technical Report Y-87-1, US army Engineer Waterways Experiment Station, Vicksburg, Miss. Hitchcock, C.L., A. Cronquist. 1977. Flora of the Pacific Northwest. University of Washington Press. Seattle, Washington. Reppert, R.T., W. Sigleo, E. Stakhiv, L. Messman, and C. Meyers. 1979. Wetland Values - Concepts and Methods for Wetland Evaluation. Research Report 79-R1, U.S. Army Corps of Engineers, Institute for Water Resources, Fort Belvoir, Virginia. U.S. Army Corps of Engineers. 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and C oast Region (Version 2.0), ed. J. S. Wakeley, R. W. Lichvar, and C. V. Noble. ERDC/EL TR-10-3. Vicksburg, MS: U.S. Army Engineer Research and Development Center. U.S. Department of Agriculture, Soils Conservation Service. Soils Survey of King County Area Washington, February 1979. Washington State Department of Ecology. 1997. Washington State Wetlands Identification and Delineation Manual. Publication Number 96-94. Date: 7/2/2021 Prepared by: Project Number: Applicant:Phone: 360-281 8195 PLANT MATERIALS (includes labor cost for plant installation) Type Unit Price Unit Quantity Cost PLANTS: Potted, 4" diameter, medium $5.00 Each $ - PLANTS: Container, 1 gallon, medium soil $11.50 Each $ - PLANTS: Container, 2 gallon, medium soil $20.00 Each 482.00 $ 9,640.00 PLANTS: Container, 5 gallon, medium soil $36.00 Each 102.00 $ 3,672.00 PLANTS: Seeding, by hand $0.50 SY $ - PLANTS: Slips (willow, red-osier)$2.00 Each $ - PLANTS: Stakes (willow)$2.00 Each $ - PLANTS: Stakes (willow)$2.00 Each $ - PLANTS: Flats/plugs $2.00 Each $ - TOTAL $ 13,312.00 Type Unit Price Unit Cost Compost, vegetable, delivered and spread $37.88 CY $ - Decompacting till/hardpan, medium, to 6" depth $1.57 CY $ - Decompacting till/hardpan, medium, to 12" depth $1.57 CY $ - Hydroseeding $0.51 SY 325.00 $ 165.75 Labor, general (landscaping other than plant installation)$40.00 HR 25.00 $ 1,000.00 Labor, general (construction)$40.00 HR $ - Labor: Consultant, supervising $55.00 HR $ - Labor: Consultant, on-site re-design $95.00 HR $ - Rental of decompacting machinery & operator $70.00 HR $ - Sand, coarse builder's, delivered and spread $42.00 CY $ - Staking material (set per tree)$7.00 Each $ - Surveying, line & grade $250.00 HR $ - Surveying, topographical $250.00 HR $ - Watering, 1" of water, 50' soaker hose $3.62 MSF $ - Irrigation - temporary $3,000.00 Acre 0.20 $ 600.00 Irrigation - buried $4,500.00 Acre $ - Tilling topsoil, disk harrow, 20hp tractor, 4"-6" deep $1.02 SY $ - TOTAL $ 1,765.75 ITEMS Unit Cost Unit Cost Fascines (willow) $ 2.00 Each $ - Logs, (cedar), w/ root wads, 16"-24" diam., 30' long $1,000.00 Each $ - Logs (cedar) w/o root wads, 16"-24" diam., 30'$400.00 Each $ - Logs, w/o root wads, 16"-24" diam., 30' long $245.00 Each $ - Logs w/ root wads, 16"-24" diam., 30' long $460.00 Each $ - Rocks, one-man $60.00 Each $ - Rocks, two-man $120.00 Each $ - Root wads $163.00 Each $ - Spawning gravel, type A $22.00 CY $ - Weir - log $1,500.00 Each $ - Weir - adjustable $2,000.00 Each $ - Woody debris, large $163.00 Each $ - Snags - anchored $400.00 Each $ - Snags - on site $50.00 Each $ - Snags - imported $800.00 Each $ - * All costs include delivery and installation TOTAL $ - EROSION CONTROL ITEMS Unit Cost Unit Cost Backfill and Compaction-embankment $ 4.89 CY $ - Crushed surfacing, 1 1/4" minus $30.00 CY $ - Ditching $7.03 CY $ - Excavation, bulk $4.00 CY $ - Fence, silt $1.60 LF 440.00 $ 704.00 Jute Mesh $1.26 SY $ - Critical Areas Mitigation Bond Quantity Worksheet Description Mark Heckert Project Description: Buffer restoration & Enhancement Project Name: P&M DEVELOPMENT FEDERAL WAY Location: Parcel # 1421039069, 1421039087, & 1421039043 P&M DEVELOPMENT INSTALLATION COSTS ( LABOR, EQUIPMENT, & OVERHEAD) HABITAT STRUCTURES* Mulch, by hand, straw, 2" deep $1.27 SY $ - Mulch, by hand, wood chips, 2" deep $3.25 SY 55.00 $ 178.75 Mulch, by machine, straw, 1" deep $0.32 SY $ - Piping, temporary, CPP, 6"$9.30 LF $ - Piping, temporary, CPP, 8"$14.00 LF $ - Piping, temporary, CPP, 12"$18.00 LF $ - Plastic covering, 6mm thick, sandbagged $2.00 SY $ - Rip Rap, machine placed, slopes $33.98 CY $ - Rock Constr. Entrance 100'x15'x1'$3,000.00 Each $ - Rock Constr. Entrance 50'x15'x1'$1,500.00 Each $ - Sediment pond riser assembly $1,695.11 Each $ - Sediment trap, 5' high berm $15.57 LF $ - Sediment trap, 5' high berm w/spillway incl. riprap $59.60 LF $ - Sodding, 1" deep, level ground $5.24 SY $ - Sodding, 1" deep, sloped ground $6.48 SY $ - Straw bales, place and remove $600.00 TON $ - Hauling and disposal $20.00 CY $ - Topsoil, delivered and spread $35.73 CY $ - TOTAL $ 882.75 GENERAL ITEMS ITEMS Unit Cost Unit Cost Fencing, chain link, 6' high $18.89 LF $ - Fencing, chain link, corner posts $111.17 Each $ - Fencing, chain link, gate $277.63 Each $ - Fencing, split rail, 3' high (2-rail)$10.54 LF 440.00 $ 4,637.60 Fencing, temporary (NGPE)$1.20 LF $ - Signs, sensitive area boundary (inc. backing, post, install)$28.50 Each 12.00 $ 342.00 TOTAL $ 4,979.60 $ 20,940.10 ITEMS Percentage of Construction Cost Unit Cost Mobilization 10%1 $ 2,094.01 Contingency 30%1 $ 6,282.03 TOTAL $ 8,376.04 MAINTENANCE AND MONITORING Maintenance, annual (by owner or consultant) Less than 1,000 sq.ft. and buffer mitigation only $ 1.08 SF $ - Less than 1,000 sq.ft. with wetland or aquatic area mitigation $ 1.35 SF $ - Larger than 1,000 sq. ft. but less than 5,000 sq.ft. of buffer mitigation $ 180.00 EACH $ - Larger than 1,000 sq. ft. but less than 5,000 sq.ft. of wetland or aquatic area mitigation $ 270.00 EACH $ - Larger than 5,000 sq.ft. but < 1 acre -buffer mitigation only $ 360.00 EACH 5.00 $ 1,800.00 Larger than 5,000 sq.ft. but < 1 acre with wetland or aquatic area mitigation $ 450.00 EACH $ - Larger than 1 acre but < 5 acres - buffer and / or wetland or aquatic area mitigation $ 1,600.00 DAY $ - Larger than 5 acres - buffer and / or wetland or aquatic area mitigation $ 2,000.00 DAY $ - Monitoring, annual (by owner or consultant) Larger than 1,000 sq.ft. but less than 5,000 wetland or buffer mitigation $ 720.00 EACH $ - Larger than 5,000 sq.ft. but < 1 acre with wetland or aquatic area impacts $ 900.00 EACH 5.00 $ 4,500.00 Larger than 1 acre but < 5 acres - buffer and / or wetland or aquatic area impacts $ 1,440.00 DAY $ - Larger than5 acres - buffer and / or wetland or aquatic area impacts $ 2,160.00 DAY $ - TOTAL $ 6,300.00 Total $35,616.14 (16 hrs @ $90/hr) (24 hrs @ $90/hr) (10 hrs @ $45/hr) (WEC crew) (1.25 X WEC crew) (8 hrs @ 90/hr) (10 hrs @ $90/hr) (4hr @$45/hr) (8 hrs @ 45/hr) (3 X SF total for 3 annual events; Includes monitoring) (3 X SF total for 3 annual events; Includes monitoring) (6hr @$45/hr) NOTE: Projects with multiple permit requirements may be required to have longer monitoring and maintenance terms. This will be evaluated on a case-by- case basis for development applications. Monitoring and maintance ranges may be assessed anywhere from 5 to 10 years. (Construction Cost Subtotal) OTHER P & M Development, LLC – 35001 NE 147TH AVE, YACOLT, WA 98675 – (360) 263-4873 September 15, 2021 (REVISED October 29, 2021) TECHNICAL MEMORANDUM – STORMWATER REQUIREMENTS To: Ms. Chaney Skadsen City of Federal Way From: Michelle Henry, PE RE: Stormwater Narrative Henry Reasonable Use, Process III Applications 20-105405-UP, 21-100016-UP, 21-100017-UP This is an executive summary of the stormwater Technical Information Report (TIR) and stormwater plan provided as basis for design with the proposed project seeking Reasonable Use for each single family lot through the above referenced Process III applications. This is to show the stormwater requirements have been met for the proposed intrusion into the stream buffer and into the wetland buffer. In general, the site is comprised of three residential lots zoned RS15.0 with a wetland to the north and a creek through the middle that divides the drainage area into two as shown in Figure 1.3 on page 11 of the stormwater TIR. The site’s topology is sloped such that all stormwater that falls on the site flows to the creek and then to the wetland or directly to the wetland with a natural discharge location on the north end shown in figure 1.28 on page 9 of the stormwater TIR. The stormwater TIR and plan meet the 2016 King County Surface Water Design Manual (KCSWDM) for runoff control and water quality treatment. A Level 1 downstream analysis was included in the stormwater report to show the proposed development would not adversely impact areas offsite downstream of the development. The project protects critical areas from stormwater runoff by enhancing areas within the buffers to to provide flow control, ensure water quality, and improve the buffers ecological function. The enhanced buffer areas provided in the stormwater report are for full dispersion per the KCSWDM best management practices (BMP) for flow control and water quality using naturally vegetated flow paths (NVFP) which are allowed within the buffers of critical areas per KCSWDM, Appendix C.2.1 p.31. These enhanced areas improve the buffer function to protect the stream and wetland, and support habitat. The following summary table from page 16 of the TIR identifies how each of the 9 core elements and special requirements in drainage design for meeting the KCSWDM stormwater requirements were addressed if applicable. Pages 16-19 in the stormwater TIR summarize these in more detail and subsequent chapters in the stormwater TIR go into further detail. P & M Development, LLC – 35001 NE 147TH AVE, YACOLT, WA 98675 – (360) 263-4873 REQUIREMENTS: How being met if applicable: Core Reqmt #1: Discharge at the Natural Location No change to the natural discharge location. Core Reqmt #2: Offsite Analysis Level 1 offsite analysis completed (Section 3) Core Reqmt #3: Flow Control Full Dispersion (Section 4) Core Reqmt #4: Conveyance System Gravel channels and oversized drainpipes for roof downspouts for capacity exceeding the peak flow during a 100-year rainfall event. (Sizing analysis in Section 5) Core Reqmt #5: Erosion and Sediment Control ESC measures during construction and in final design. Core Reqmt #6: Maintenance and Operations Property owners will be responsible to maintain natural vegetated areas. Core Reqmt #7: Financial Guarantees and Liability Private Facilities/NVFP Area Covenant Core Reqmt #8: Water Quality Full Dispersion (Section 4) Core Reqmt #9: Flow Control BMPs NVFP -Full Dispersion (onsite), Sheet Flow Dispersion (offsite), Simple Detention Special Reqmt #1: Other Adopted Area-Specific Requirements Critical Areas: wetlands and stream to be protected. The project area lies within the South Lower Puget Sound Subbasin. Special Reqmt #2: Flood Hazard Area Delineation N/A – Not within the 100-yr flood plain. Special Reqmt #3: Flood Protection Facilities N/A – Not within an area of flooding. Special Reqmt #4: Source Control N/A - Single Family Special Reqmt #5: Oil Control N/A – Sindle Family The stormwater plan shows the project will retain approximately 64,062 SF of natural vegetation within the combined three lots of 76,826 SF, making up 83% of the overall project site. The remaining 17% will consist of the existing roadway, roofs, driveways, and lawn areas (TIR p.35). Below is a table from p.10 of the stormwater TIR that provides a breakdown of the stormwater surfaces shown within the project and shown on the stormwater plan which will require stormwater management. The stormwater design provides treatment of the existing impervious surfaces (SW 333RD Place) as well as new impervious surfaces (building and driveways), along with pollution generating pervious surfaces (grass lawns). The project plans provide construction details for each stormwater management BMP per the KCSWDM on plan sheet 7 of the project plan set. DESCRIPTION TYPE AREA (SF) METHOD/BMP Pavement (onsite, max 20-ft wide) PGIS 4939 FULL DISPERSION/BMP FC-NVFP KCSWDM C2.1 P & M Development, LLC – 35001 NE 147TH AVE, YACOLT, WA 98675 – (360) 263-4873 Pavement (offsite, 10-ft wide strip) PGIS 1900 STRIP (SHEET FLOW) DISPERSION /BMP KCSDM C2.2 LOT -9043 - SFR Non-PGIS 1486 FULL DISPERSION/BMP FC-NVFP KCSWDM C2.1 LOT -9087 - SFR Non-PGIS 1300 FULL DISPERSION/BMP FC-NVFP KCSWDM C2.1 LOT -9069 - SFR Non-PGIS 1563 FULL DISPERSION/BMP FC-NVFP KCSWDM C2.1 LOT -9043 -Lawn PGPS 1225 SIMPLE DETENTION POND/KCSWDM Chapter 5.1.7 LOT -9087- Lawn PGPS 1200 SIMPLE DETENTION POND/KCSWDM Chapter 5.1.7 LOT -9069 - Lawn PGPS 1300 SIMPLE DETENTION POND/KCSWDM Chapter 5.1.7 Note, because the buffer intrusion areas are exempt from including the existing roadway of 333rd Place per the FWRC 19. 145.440 (4) and FWRC 19.145.270 (4) Permanently altered buffers, the areas for impervious and pervious surfaces listed above are different than the areas of intrusion as defined by the clearing and grading limits for each lot. The stormwater plan provides details showing the direction and flow of surface discharges for control and treatment in the enhanced buffer regions recognized as an approved BMP for flow control and water quality. These areas are identified as NVFP on the site improvement plans. The applicant recognizes that all naturally vegetated flow paths proposed with the project will need to be constructed on all lots with the construction of the first lot to meet public works requirement for stormwater treatment of the improved existing roadway. Though the new paved surface replaces an existing impervious surface, replacement impervious is not exempt from stormwater treatment. Attached: Stormwater TIR P & M Development, LLC – 35001 NE 147TH AVE, YACOLT, WA 98675 – (360) 263-4873 September 15, 2021 Ms. Chaney Skadsen City of Federal Way Community Development 33325 8th Avenue South Federal Way, Washington 98003 RE: Henry Reasonable Use (Burden of Proof) Process III, 20-105405-UP, 21-100016-UP, 21-100017-UP Dear Ms. Skadsen: In meeting the decisional criteria in FWRC.65.100(2), please find convincing evidence provided in this letter that shows the provisions of the code requirements for reasonable use within the wetland buffer and stream buffer have been met. Each lot is zoned RS 15.0 and FWRC 19.145.090 (3) items a. through e. are met for each proposed single family residence as follows: FWRC 19.145.090 (3) a. The applications of the provisions of this chapter eliminates all reasonable use of the subject property. • 20-105405-UP: Lot 9043 shown on the attached wetland buffer and stream buffer intrusion map is encumbered as follows by critical areas: 9043 Lot Size: 36,744 SF SFR Bldg Footprint: 1,486 SF Wetland: 5,320 SF Wetland Buffer: 26,122 SF WB Intrusion: 3,350 SF (12.8% buffer reduction) Stream Buffer: 36,744 SF SB Intrusion: 3,350 SF (9.1% buffer reduction) The stream buffer encumbers the entire lot. A wetland and its 150-ft buffer encumber all but 5,302 SF in the southwest corner of the lot that is only accessible by crossing the stream. Previous single-family use of the lot cleared areas of the site accessible with an existing gravel road where a proposed new single-family home with a 1486 SF footprint is proposed. • 21-100016-UP: Lot 9069 as shown on the attached wetland buffer and stream buffer intrusion maps is encumbered as follows: 9069 Lot Size: 18,000 SF P & M Development, LLC – 35001 NE 147TH AVE, YACOLT, WA 98675 – (360) 263-4873 SFR Bldg Footprint: 1,563 SF Wetland: 5,450 SF Wetland Buffer: 12,550 SF WB Intrusion: 3,250 SF (25.8% buffer reduction) Stream Buffer: 11,830 SF SB Intrusion: 1,080 SF (9.1 % buffer reduction) The wetland and its 150-ft buffer encumber the entire lot. All but 6,170 SF in the southeast corner of the lot is encumbered by the stream buffer. The proposed single family pushes up against setback limitations in the southeast corner with required building setbacks and a minimum 5-ft setback from buffer enhancements proposed to manage stormwater runoff. Intrusion for the proposed single-family use with a building footprint of 1563 SF will be split between the area of the lot only encumbered by the wetland buffer with the area encumbered by both wetland and stream buffers. • 21-100017-UP: Lot 9087 as shown on the attached wetland intrusion maps is encumbered as follows: 9087 Lot Size: 22,082 SF SFR Bldg Footprint: 1,300 SF Wetland: 9,310 SF Wetland Buffer: 12,772 SF WB Intrusion: 2,900 SF (22.7% buffer reduction) Stream Buffer 22,030 SF SB Intrusion: 2900 SF (13.1% buffer reduction) This lot is fully encumbered by wetland and wetland buffers. It is also fully encumbered by the stream buffer except for 52 SF in the southeast corner. The proposed single- family footprint on this lot of 1300 SF will intrude into both wetland and stream buffers. Please find for each lot there is no alternative practical buildable area due to the location of the critical areas, critical area buffers, and setbacks as evidenced above and shown on the stream buffer and wetland buffer maps that are attached. As evidenced by this the provisions of Chapter 19.145 eliminate all reasonable use of the subject properties. ✓ FWRC 19.145.090 (3) a. applies to all three lots. FWRC 19.145.090 (3) b. No feasible and reasonable on-site alternatives to the proposal are possible, such as changes to site layout and or reduction of impervious uses. ALL LOTS As outlined above, all lots are fully encumbered by critical areas and the buffers of those critical areas. Each proposed single family house is average size or smaller. The footprints of less than 1600 SF each and push up against the minimum required setbacks to minimize intrusion and create maximum separation from the wetland and the stream. P & M Development, LLC – 35001 NE 147TH AVE, YACOLT, WA 98675 – (360) 263-4873 Please also recognize the existing gravel road identified as SW 333rd Place on King County Plat Maps in the King County Archives/Records Annex, as pictured below. The existing roadway extends through the south boundary of lot 9087 and lot 9069 onto lot 9043 as shown below in the 2019 topological survey pictured below and is proposed to be paved with the project to meet minimum site access requirements. The existing roadway of SW 333rd Place is considered an existing impervious surface and meets the provisions in the code FWRC 19.145.440(4) and FWRC 19.145.270(4) as Permanently Altered Buffer. A street modification request under Federal Way application 20-101257-SM was approved May 19, 2020 to reduce the pavement width of the existing road and will slightly reduce the intrusion of this road into the stream and wetland buffers. Due to the location of the roadway and minimum required setbacks relevant to the previously described buffer areas, the proposed project meets this item in the Reasonable Use Provisions P & M Development, LLC – 35001 NE 147TH AVE, YACOLT, WA 98675 – (360) 263-4873 ✓ FWRC 19.145.90 (3) b. applies since no feasible and reasonable on-site alternatives to the proposal are possible, such as changes to site layout and or reduction of impervious uses. FWRC 19.145.090 (3) c. It is solely the implementation of this chapter, and not other factors that preclude all reasonable use of the subject property. Please find the proposed project has either met or has been identified the ability to meet all the following OTHER permit requirements which will facilitate the proposed single- family construction on each lot: • Utilities – Each lot will have access to public water and sewer with the proposed project. The Lakehaven Sewer District has identified a path forward for permitting public sewer to all three lots and a proposed sewer crossing the creek is shown on the plans. Tacoma Water has identified an existing water service and ability to provide water service to all three lots. Power exists on the site and the existing power pole is shown on the plans. • SEPA - The sewer crossing of the creek on lot 9043 requires a SEPA. This was addressed by SEPA application 21-100014-SE. A Determination of Non-significance was issued for the project on July 16, 2021. • HPA permit– The sewer crossing requires a Hydraulic Project Approval permit from the Washington Department of Fish and Wildlife. The HPA permit was approved on July 29, 2021 under permit number 2021-4—518-01. • Public Works – Proposed road improvements and the stormwater management plan have been approved through the reasonable use process and submitted for engineering permits under Federal Way permit application 21-103216-PW. • Traffic – Certificates of Concurrency were approved and issued for each lot on February 4, 2021 as follows; 21-100029-CN (lot 9043), 21-100030-CN (lot 9087), and 21-100031 (lot 9069). In addition, the previously mentioned street modification requested to reduce pavement widths was approved und application 20-101257-SM in May of 2020. • Fire – Fire has approved the project with the condition that each new single-family residence include fire sprinklers due to limited access. Fire sprinkler plans will be submitted to meet these fire sprinkler requirements. • Building – Once Reasonable Use has been determined through the Process III application, the single-family building codes will be met for each proposed house. This shows that all other permits are viable for the construction of a single family home on each lot and it is solely the implementation of Chapter 19.145, and not other factors that preclude all reasonable use of the subject property. ✓ FWRC 19.145.90 (3) c. applies to all three lots. FWRC 19.145.090 (3) d. The applicant has in no way created or exacerbated the condition that forms the limitation on the use of the subject property, nor in anyway contributed to such limitation. P & M Development, LLC – 35001 NE 147TH AVE, YACOLT, WA 98675 – (360) 263-4873 Attached is the Notice of Violation provided to the previous owners by Federal Way Code Compliance Officer, Angie Villalovos, in March of 2019. Please find the issues identified in the violation notice as evidence of the condition of the site when the current owners purchased the property. Also attached is an email dated April 19, 2019, from the Code Compliance Officer with photographic evidence that the current owners cleaned up the site. The pictures not only show the cleanup effort but also show the buffer areas where each home construction that is proposed had been previously cleared with previous uses. The areas on each lot where each house is proposed were deplete of any vegetation and the vegetation that is there now is what has since grown in during this land use process. In addition, as written in the project narrative dated December 1, 2019, submitted with the application process, the applicant upon taking ownership immediately consulted with Beaver Creek Environmental Services to identify the critical areas and performed a major clean-up effort to remove all the garbage, debris, and environmental hazards from the buffers and critical areas. Please find as proof that the applicant did no create or exacerbate the condition limiting the use or contribute to such limitation the attached preliminary Critical Areas Designation report prepared by Beaver Creek Environmental Services on May 18, 2019 upon the applicant taking ownership of the site. ✓ FWRC 19.145.090 (3) d. The applicant has in no way created or exacerbated the condition that forms the limitation on the use of the subject property, nor in anyway contributed to such limitation. Please also find that the project as proposed with the mitigation enhancement areas proposed improves the ecological function of the buffers and critical areas. FWRC 19.145.090 (3) e. The waiver or modification will not lead to, create nor significantly increase the risk of injury or death to any person or damage to improvements on or off the subject property. The site has a history of nefarious activities and criminal elements that were occurring on the property and neighboring sites as documented by City of Federal way police and explained to the applicant while working with the owner upon taking ownership. Please find that the proposed project provides each lot a purpose in providing safe and secure homes in support of a strong community. The proposed development will preserve and restore ecological functions, enhance the critical areas, and improve not only the site but the surrounding neighborhood with development compatible to neighboring properties. Please find the project as proposed in the submitted plans and reports support a strong and healthy residential community. ✓ FWRC 19.145.090 (3) e. has been met through the following documentation which has all been submitted during this process. P & M Development, LLC – 35001 NE 147TH AVE, YACOLT, WA 98675 – (360) 263-4873 • Completed Process III Submittal Requirements for Use Process III form • Project Narrative and Vicinity Map • Concurrency Application • Master Land Use Application • Plan Set – Survey, Topo, Tree Plan, Site Plan, Stormwater, Utilities, Road • Stormwater Report • Tree Unit Calculations • Sewer Availability – Lakehaven Sewer District • Water Availability – Tacoma Water District • Site Photos (E, W, N, S) • Wetlands and Drainage Corridors Evaluation & Delineation &, • Conceptual Mitigation Plan for Reasonable Use Exception • Final Mitigation Plan for Reasonable Use Exception • SEPA – environmental checklist • Title Report • Letter addressing technical review comments (3-31-21) • Variance request to reduce setback. • Letter to rescind variance request to reduce setback. • Letter addressing public comments. • Letter addressing technical review comments (7-19-21) • Stream and Wetland Buffer Maps • HPA Approved Permit Please find all the codes for the proposed reasonable use criteria have been met as supported by this letter and documentation provided in the Process III application process for your review and approval. Sincerely, Michelle Henry, PE Attached: Lot 9043 Stream Buffer and Wetland Buffer Intrusion Map Lot 9069 Stream Buffer and Wetland Buffer Intrusion Map Lot 9087 Stream Buffer and Wetland Buffer Intrusion Map Notice of Violation March 2019 Email dialog and documented photographs of site in April 2019 Preliminary Critical Areas Designation (5-18-2019) &ƌŽŵ͗ŶŐŝĞsŝůůĂůŽǀŽƐ ^ĞŶƚ͗&ƌŝĚĂǇ͕Ɖƌŝůϭϵ͕ϮϬϭϵϰ͗ϭϬWD dŽ͗ΖWĂƚĂŶĚDŝĐŚĞůůĞ,ŽŵĞΖ ^ƵďũĞĐƚ͗Z͗ϯϯϯϬϱϰϯƌĚǀĞ^t ,ŝDŝĐŚĞůůĞ͕ /ǁĂƐŽƵƚƚŽǇŽƵƌƉƌŽƉĞƌƚŝĞƐƚŽĚĂǇ͘/ǁĂƐĂďůĞƚŽƚĂŬĞƉŚŽƚŽƐ͕ƚŚĞƐĞĂƌĞƚŚĞƉŚŽƚŽƐ/ǁŝůůƵƐĞƚŽĐůŽƐĞŽƵƚ ƚŚĞĐĂƐĞ͘ůů/ƐĞĞůĞĨƚĂƌĞƐŽŵĞϱŐĂůůŽŶƉĂŝŶƚďƵĐŬĞƚƐĂŶĚƚŚŝƐƉŝůĞŽĨůĂƌŐĞƐĐƌĂƉŵĞƚĂů͘/ƚƌƵƐƚƚŚĞƐĞ ŝƚĞŵƐǁŝůůďĞŐŽŶĞƐŽŽŶ͘/͛ůůďĞĐůŽƐŝŶŐŽƵƚƚŚĞǀŝŽůĂƚŝŽŶƐǁŝƚŚĐŽĚĞĐŽŵƉůŝĂŶĐĞŽŶĂůůƚŚƌĞĞƉĂƌĐĞůƐ͕ĂŶĚ ůĞƚǇŽƵǁŽƌŬǁŝƚŚǇŽƵƌtĞƚůĂŶĚŝŽůŽŐŝƐƚĂŶĚƚŚĞŝƚǇ͛ƐWůĂŶŶŝŶŐĞƉĂƌƚŵĞŶƚĂƐĨĂƌĂƐďƵŝůĚŝŶŐŐŽĞƐ͘/Ĩ ǇŽƵĞǀĞƌŶĞĞĚƚŽƐƉĞĂŬƚŽƚŚĞWůĂŶŶĞƌŽŶƵƚǇŚĞƌĞĂƚƚŚĞŝƚǇĨŽƌƋƵĞƐƚŝŽŶƐ͕ƚŚĞŝƌŶƵŵďĞƌŝƐϮϱϯͲϴϯϱͲ Ϯϲϱϱ͘&ŽƌƋƵĞƐƚŝŽŶƐƌĞŐĂƌĚŝŶŐWĞƌŵŝƚƐ͕ƚŚĞŶƵŵďĞƌŝƐ ϮϱϯͲϴϯϱͲϮϲϬϳ͘ &ĞĞůĨƌĞĞƚŽĐŽŶƚĂĐƚŵĞƐŚŽƵůĚǇŽƵŚĂǀĞĂŶǇŽƚŚĞƌĨƵƌƚŚĞƌƋƵĞƐƚŝŽŶƐ͘ dŚĂŶŬǇŽƵDŝĐŚĞůůĞ͘ ŶŐŝĞsŝůůĂůŽǀŽƐ ͮŽĚĞŽŵƉůŝĂŶĐĞKĨĨŝĐĞƌ ϯϯϯϮϱϴƚŚ ǀĞ^ŽƵƚŚ ͮ&ĞĚĞƌĂůtĂǇ͕tϵϴϬϬϯ Ϯϱϯ͘ϴϯϱ͘Ϯϲϯϭ ŽƌϮϱϯ͘Ϯϳϴ͘ϲϰϰϭ ͮϮϱϯ͘ϴϯϱ͘ϮϲϬϵ ŶŐŝĞ͘sŝůůĂůŽǀŽƐΛĐŝƚǇŽĨĨĞĚĞƌĂůǁĂǇ͘ĐŽŵ )URP3DWDQG0LFKHOOH+RPH>PDLOWRSDWDQGPLFK#PVQFRP@ 6HQW7KXUVGD\$SULO30 7R$QJLH9LOODORYRV 6XEMHFW5HUG$YH6: ,QWHUHVWLQJQHLJKERUVVDLGLWDOOFDPHRXWRIWKRVHWZRKRXVHV *HW2XWORRNIRU$QGURLG &ƌŽŵ͗ŶŐŝĞsŝůůĂůŽǀŽƐфŶŐŝĞ͘sŝůůĂůŽǀŽƐΛĐŝƚǇŽĨĨĞĚĞƌĂůǁĂǇ͘ĐŽŵх ^ĞŶƚ͗dŚƵƌƐĚĂǇ͕Ɖƌŝůϭϴ͕ϮϬϭϵϯ͗ϰϳ͗ϯϮWD dŽ͗ΖWĂƚĂŶĚDŝĐŚĞůůĞ,ŽŵĞΖ ^ƵďũĞĐƚ͗Z͗ϯϯϯϬϱϰϯƌĚǀĞ^t ,ŝ͕ dŚĂŶŬƐDŝĐŚĞůůĞ͕/͛ůůƚĂŬĞĂĚƌŝǀĞŽƵƚƚŽŵŽƌƌŽǁƚŽĚŽĂĨŽůůŽǁͲƵƉƐŝƚĞŝŶƐƉĞĐƚŝŽŶŽĨƚŚĞƉƌŽƉĞƌƚŝĞƐ͘ /ĚŝĚƐƉĞĂŬǁŝƚŚdŽŶǇĂŶĚĂĚǀŝƐĞĚŚŝŵƚŚĂƚƚŚĞŶĞǆƚƐƚĞƉŝƐƚŚĞŝƐƐƵĂŶĐĞŽĨĂĨŝŶĞ͘,ĞƐĂǇƐƚŚĂƚƚŚĂƚƐƉŽƚ ŝƐĂĐŽŵŵŽŶĚƵŵƉŝŶŐŐƌŽƵŶĚƐĨŽƌĂŶǇŽŶĞƚŽĚƌŝǀĞƚŚƌŽƵŐŚ͕ĚƵŵƉ͕ĂŶĚŬĞĞƉŐŽŝŶŐ͘ŶĚŚĞŝƐĐŽƌƌĞĐƚ͘ &ŽƌǀŝĐƚŝŵƐŽĨĚƵŵƉŝŶŐůŝŬĞƚŚĂƚǁĞĚŽŚĂǀĞĂƌĞƐŽƵƌĐĞƚŚƌŽƵŐŚ<ŝŶŐŽƵŶƚǇƚŽŽĨĨĞƌƉĞŽƉůĞĨƌĞĞĚƵŵƉ ǀŽƵĐŚĞƌƐ͕ŽĨĐŽƵƌƐĞƚŚĂƚůĞĂǀĞƐƚŚĞŝŶĚŝǀŝĚƵĂůǁŝƚŚƚŚĞƌĞƐƉŽŶƐŝďŝůŝƚǇŽĨŚĂǀŝŶŐĂƚƌƵĐŬĂŶĚŚĂƵůŝŶŐŝƚ ƚŚĞƌĞƚŽƚŚĞĚƵŵƉ͘dŽŶǇĚĞĐůŝŶĞĚƚŚĞĨƌĞĞĚƵŵƉǀŽƵĐŚĞƌĂŶĚĂƐƐƵƌĞĚŵĞŚĞǁŽƵůĚďĞƉŝĐŬŝŶŐƵƉƚŚĂƚ ĨƵƌŶŝƚƵƌĞƚŚŝƐǁĞĞŬĞŶĚĂŶĚŚŝƌŝŶŐĂĐƌĞǁƚŽĐůĞĂŶƵƉ͕ŚĞŝƐƐƵƉƉŽƐĞĚƚŽůĞƚŵĞŬŶŽǁǁŚŽŚĞŚŝƌĞĚĂŶĚ ǁŚĞŶĐůĞĂŶƵƉŝƐƐĐŚĞĚƵůĞĚĨŽƌ͘ /ƌĞĂůůǇĂƉƉƌĞĐŝĂƚĞǇŽƵƌŚĂƌĚǁŽƌŬŝŶĐůĞĂŶŝŶŐƵƉƚŚŝƐůĂŶĚ͘ dŚĂŶŬƐ͕ ŶŐŝĞsŝůůĂůŽǀŽƐ ͮŽĚĞŽŵƉůŝĂŶĐĞKĨĨŝĐĞƌ ϯϯϯϮϱϴƚŚ ǀĞ^ŽƵƚŚ ͮ&ĞĚĞƌĂůtĂǇ͕tϵϴϬϬϯ Ϯϱϯ͘ϴϯϱ͘Ϯϲϯϭ ŽƌϮϱϯ͘Ϯϳϴ͘ϲϰϰϭ ͮϮϱϯ͘ϴϯϱ͘ϮϲϬϵ ŶŐŝĞ͘sŝůůĂůŽǀŽƐΛĐŝƚǇŽĨĨĞĚĞƌĂůǁĂǇ͘ĐŽŵ )URP3DWDQG0LFKHOOH+RPH>PDLOWRSDWDQGPLFK#PVQFRP@ 6HQW7KXUVGD\$SULO30 7R$QJLH9LOODORYRV 6XEMHFW5HUG$YH6: +L$QJLH-XVWDTXLFNQRWHWROHW\RXNQRZRXUWKUHHSDUFHOVKDYHEHHQFOHDUHGDQGFOHDQHGXS 8QIRUWXQDWHO\7RQ\ZRXOGQ WZRUNZLWKXVWRFOHDQXSKLVPHVVDQGVWLOOKDVWUDVKHYHU\ZKHUH 0LFKHOOH *HW2XWORRNIRU$QGURLG &ƌŽŵ͗ŶŐŝĞsŝůůĂůŽǀŽƐфŶŐŝĞ͘sŝůůĂůŽǀŽƐΛĐŝƚǇŽĨĨĞĚĞƌĂůǁĂǇ͘ĐŽŵх ^ĞŶƚ͗dŚƵƌƐĚĂǇ͕Ɖƌŝůϰ͕ϮϬϭϵϭ͗ϯϬ͗ϬϲWD dŽ͗ΖƉĂƚĂŶĚŵŝĐŚΛŵƐŶ͘ĐŽŵΖ ^ƵďũĞĐƚ͗ϯϯϯϬϱϰϯƌĚǀĞ^t ,ĞůůŽDŝĐŚĞůůĞ͕ ,ĞƌĞŝƐƚŚĞEŽƚŝĐĞŽĨsŝŽůĂƚŝŽŶtĂƌŶŝŶŐŽŶĂůůƚŚƌĞĞƉĂƌĐĞůƐ͘ WƌŽƉĞƌƚǇŽǁŶĞƌĨŽƌϯϯϯϬϯϰϯƌĚ ǀĞ^tĂŶĚϰϯϬϲ^tϯϯϯƌĚ ^ƚŝƐŽǁŶĞĚďǇdŽŶǇ:ƵϮϬϲͲϳϴϴͲϳϳϭϭ͘ tŚĞŶǇŽƵĂƌĞƌĞĂĚǇĨŽƌŵĞƚŽĐŽŵĞŽƵƚƚŽƚĂŬĞƉŚŽƚŽƐůĞƚŵĞŬŶŽǁ͕ǇŽƵĚŽŶŽƚŶĞĞĚƚŽďĞƉƌĞƐĞŶƚŽŶ ƚŚĞƉƌŽƉĞƌƚǇĨŽƌŵĞƚŽĚŽƚŚĂƚ͘ dŚĂŶŬǇŽƵĨŽƌĐŽŶƚĂĐƚŝŶŐŵĞ͊ ŶŐŝĞsŝůůĂůŽǀŽƐ ͮŽĚĞŽŵƉůŝĂŶĐĞKĨĨŝĐĞƌ ϯϯϯϮϱϴƚŚ ǀĞ^ŽƵƚŚ ͮ&ĞĚĞƌĂůtĂǇ͕tϵϴϬϬϯ Ϯϱϯ͘ϴϯϱ͘Ϯϲϯϭ ŽƌϮϱϯ͘Ϯϳϴ͘ϲϰϰϭ ͮϮϱϯ͘ϴϯϱ͘ϮϲϬϵ