Twin Lakes Veterinary Review_2021_0803
August 3, 2021
Stacey Welsh, Principal Planner City of Federal Way
Jessica Redman, PWS & Aaron Ellig
Twin Lakes Veterinary Expansion – Critical Areas Study Review
At the request of the City of Federal Way (City), Environmental Science Associates (ESA) reviewed the Critical
Areas Study for Twin Lakes Veterinary Hospital (Revised and dated February 22, 2021; hereinafter referred to as
the Critical Areas Study) prepared by Altmann Oliver Associates for the property located at 1060 SW 320th
Street in Federal Way, Washington. A site visit was conducted by ESA biologists on June 22, 2021, to assess the
site and verify wetland conditions. The approximately 5-acre site (Parcel No. 072104-9202) is currently
developed with an existing veterinary clinic along the south side. The center of the site consists of a large wetland
complex (identified as Wetland A) that extends off-site to the east and west. Wetland A was categorized as a
Category III wetland with a habitat score of 6 points. Category III wetlands with a habitat score of 6 points
require a standard buffer width of 150 feet per FWRC 19.145.420.2. The applicant proposes to expand the
existing veterinary facility to the north, in an area that is currently maintained as mowed lawn within a fence.
Based on the project description in the Critical Areas Study, it is our understanding that the applicant would like
this project to be considered an essential service for educational purposes. The proposed project will impact
approximately 1,079 square feet (sf) of wetland buffer. The applicant proposes an equal area (1:1 impact to
mitigation ratio) of buffer replacement to compensate for impacts. The buffer replacement area consists of intact
forested wetland buffer along the eastern edge of the property.
Supplemental application materials were reviewed in conjunction with the Critical Areas Study. However, the
2021 Critical Area Study and the accompanying Twin Lakes Veterinary Hospital Addition Plan Set (developed
by Austincina Architects and dated February 25, 2021) are the focus of this review. ESA reviewed these
documents for compliance with the Federal Way Revised Code (FWRC) – Chapter 19.145, Environmentally
Critical Areas.
Our comments and recommendations based on document review and the site visit are summarized below:
1. Generally, ESA agrees with the delineated boundary of Wetland A. Flags were still visible along the
southern wetland boundary at the time of the site visit. ESA also agrees that Wetland A is Category III
wetland and allotted a 150-foot buffer per FWRC 19.145.420.2.
Twin Lakes Veterinary Expansion – Critical Areas Study Review
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2. ESA agrees that the structure is proposed in an area of the wetland buffer that is already disturbed, and
therefore, provides little to no functional benefit to Wetland A. Approximately 663 sf of the structure is
proposed to be constructed over existing asphalt and concrete, with the remaining 446 square feet is
proposed over existing lawn area. The lawn is regularly maintained (mowed) and utilized as a part of
standard business operations. Additionally, the entire lawn is fenced, providing limited opportunity for
transitional habitat for terrestrial species.
3. FWRC 19.145.440.4 (Permanently Altered Buffers) states, “The director may provide written approval
for a buffer reduction when existing conditions are such that portions of the required buffer exist in a
permanently altered state (e.g., roadways, paved parking lots, and permanent structures) and do not
provide any buffer function. The buffer may be reduced up to the area where the altered conditions exist.”
The Critical Areas Study indicates that the City made previous comments that they do not consider
mowed lawn to qualify as permanently altered, and therefore, the project does not meet the criteria for
development within a wetland buffer per FWRC 19.145.440.4. ESA agrees with the City's determination
that the project does not fully satisfy the requirements for a permanently altered buffer because the
majority of the buffer area consists of maintained lawn and not a permanent structure as defined by the
City.
4. FWRC 19.145.440.5 (Buffer Averaging) and 19.145.440.6 (Buffer Reduction with Enhancement) allow
for buffer reductions through buffer averaging or through buffer reduction with enhancement,
respectively. Each reduction method allows for buffer reductions up to 25 percent of the standard buffer
width (i.e. 37.5-foot reduction for Wetland A). The FWRC also does not allow these methods to be
combined if it would result in a greater than 25 percent reduction. According to the Critical Areas Report,
“The proposed project cannot be accomplished using standard buffer reduction or buffer averaging
provisions.” However, the applicant does not clearly state why the project does not meet these allowable
reductions. There are no measurements stating what the proposed buffer reduction is or what the post-
construction buffer width for Wetland A would be. Additionally, the proposed mitigation is consistent
with what would typical be associated with buffer averaging. ESA recommends the Critical Areas Report
be revised to include the buffer of Wetland A pre- and post-construction.
5. The Critical Areas Study states, “…the modification will be allowed by the City since the building
expansion is for educational purposes and is thereby considered an essential service.” It is unclear how
the proposed project would be considered as an essential service. If the City has determined this to be an
essential service, ESA recommends the Critical Areas Report be revised to include such language to
demonstrate how the project meets the requirements for development within a wetland buffer.