LAI Hwang Critical Areas Peer Review_TM_Final_08-05-20Technical Memorandum
130 2nd Avenue South • Edmonds, Washington 98020 • (425) 778-0907
TO: Stacey Welsh, AICP, Principal Planner, City of Federal Way
FROM: Steven Quarterman
DATE: August 5, 2020
RE: Peer Review
Hwang Property — Wetland/Stream Delineation
32604 45th Court SW
Parcel No. 8732180230 (File No. 19-105382-AD [19-105202-PC])
Federal Way, Washington
LAI Project No. 0238092.010
Introduction
This technical memorandum provides Landau Associates, Inc.’s (LAI’s) peer review comments on the
32604 45th Court SW, Wetland and Stream Delineation Report-Revision for Short Plat, dated January
30, 2020 (January 2020 Report), prepared by The Watershed Company (The Watershed Company
2020).1 The assessment evaluated wetland and fish and wildlife habitat at the parcel noted above,
referred to as the subject property.
The purpose of this peer review was to provide a professional opinion regarding applicable regulatory
requirements in the City of Federal Way (City) Revised Code (FWRC) Title 19.145 (Environmentally
Critical Areas), specific to Article III, Fish and Wildlife Habitat Conservation Areas and Article IV,
Wetlands.
Peer Review Summary
Peer review comments regarding the January 2020 Report are as follows:
1) LAI staff conducted reconnaissance of the subject property on July 14, 2020 and, based on the
observations of that reconnaissance, agree with the delineated boundary of Wetland A, Wetland
B, and Wetland C, and ordinary high water mark (OHWM) of Joes Creek included in the January
2020 Report. However, if available, LAI would like to request a figure showing surveyed flag
locations and elevation contours as LAI was able to locate most, but not all, boundary flagging (i.e.
“Flags” and “New Flags”) referenced on the Delineation Sketch in the January 2020 Report. LAI
also observed a drainage channel in the north end of the property, which appears to intercept
runoff from Hoyt Road SW, and is not regulated as a stream pursuant to the definition provided in
FWRC 19.05.190.
2) LAI concurs with the water type of Joes Creek as Type F (fish habitat stream) based on observed
stream conditions and criteria provided in accordance with Washington Administrative Code
(WAC) 222-16-031.
3) LAI concurs with the rating of Wetland A, Wetland B, and Wetland C, and notes that the following
comment specific to the rating forms associated with Wetland A and Wetland B does not change
the habitat score or overall rating as Category III wetlands:
1 The Watershed Company. 2020. 32604 45th Court SW, Wetland and Stream Delineation Report – Revision for Short Plat
Proposal. January 30. Reference No. 180723.
Landau Associates
Peer Review - Hwang Property – Wetland and Stream Delineation Report
Federal Way, Washington 2 August 5, 2020
i. H 1.2, LAI believes seasonally flowing stream or river in, or adjacent to, the wetland should
be selected; and updates would maintain Rating of Site Potential of “M” for Wetland B
and “L” for Wetland C.
4) LAI is clarifying that buffer width for Wetland B and Wetland C is 80 feet. The January 2020 Report
indicates a buffer width of 100 feet for these wetlands, which is inconsistent with the width provided
in FWRC 19.145.420(2) for Category III wetlands with habitat score of 3 to 5.
5) The January 2020 Report does not satisfy all of the evaluation criteria provided in FWRC 19.145.080(2),
specifically items:
(b) Vicinity Map
• Figure provided in the report is limited to a Wetland and Stream Delineation Sketch.
(c) The dates, names, and qualifications of the persons preparing the report and documentation of
any reconnaissance on site;
• Qualifications of the persons preparing the report are not provided; however, LAI
acknowledges that The Watershed Company website provides summaries and hyperlinks
to staff qualifications, and currently includes experience biographies for Grace Brennan,
Sam Payne, and Roen Hohfeld, who are staff referenced in the January 2020 Report.
(d) A scaled site plan depicting critical areas, buffers, setbacks, and proposed improvements;
• Wetland and stream buffers are required to be shown on a scaled site plan (e.g.,
Delineation Sketch provided in the January 2020 Report).
6) The January 2020 Report does not satisfy all of the evaluation criteria provided in FWRC
19.145.410(2), specifically item (e), and if necessary, item (f):
(e) Identification and characterization of all wetlands and buffers on and within 225 feet of the
subject property. For off-site areas with limited or no access, estimate conditions using best
available information.
• LAI acknowledges the Delineation Sketch provided in the January 2020 Report identifies
Wetland A extending south of the subject parcel and that the report references a “study
area,” but it is not clear if online mapping and inventory resources and field evaluation
identify additional wetlands within 225 feet of the subject property.
(f) Provide the following for each wetland identified on and/or within 225 feet of the subject
property. Acreage estimates, classifications, and ratings shall be based on entire wetland
complexes, not only the portion present on the subject property:
i. Wetland rating and score for each function;
ii. Required buffers;
iii. Hydrogeomorphic classification;
iv. Wetland acreage;
v. Cowardin classification of vegetation communities;
vi. Habitat elements;
vii. Soil conditions based on site assessment and/or soil survey information; and
Landau Associates
Peer Review - Hwang Property – Wetland and Stream Delineation Report
Federal Way, Washington 3 August 5, 2020
viii. To the extent possible, hydrologic information such as location and condition of inlet/
outlets, estimated water depths within the wetland, and estimated hydroperiod
patterns based on visual cues (e.g., algal mats, drift lines, and flood debris).
7) LAI is clarifying that the city’s critical areas regulations apply within incorporated city limits. The
section on Local Regulations in the January 2020 Report references “unincorporated Federal
Way”.
8) LAI acknowledges the intent of the January 2020 Report was to provide a summary of existing
conditions on the subject property, and omits information related to proposed improvements,
permit documentation, and mitigation sequencing referenced in FWRC 19.145.080(2) (a, d, g, and
h), FWRC 19.145.410(2)(b), and applicable criteria presented in Article III relative to proposed
improvements on the subject property. Discussions of impacts, mitigation sequencing, and other
applicable development requirements included in FWRC 19.145.080(2) (g through j), Article III,
and FWRC 19.145.410(2)(b) are expected to be included in subsequent development application
submittals, as necessary.
* * * * *
This technical memorandum has been prepared for use by the City in evaluating the adequacy of the
summary of baseline conditions presented in the January 20, 2020 Hwang Property Wetland and
Stream Delineation Report. The purpose of this review was to assess the adequacy of the submitted
documents for compliance with City requirements, as promulgated in FWRC Title 19, and
conformance with conventionally accepted wetland/waterway delineation practices. No other party is
entitled to rely on the information, conclusions, and recommendations included in this document
without the express written consent of LAI. Further, the reuse of information, conclusions, and
recommendations provided herein for extensions of the project or for any other project, without
review and authorization by LAI, shall be at the user’s sole risk. LAI warrants that within the
limitations of scope, schedule, and budget, these services have been provided in a manner consistent
with that level of care and skill ordinarily exercised by members of the profession currently practicing
in the same locality under similar conditions as this project. LAI makes no other warranty, either
express or implied.
LAI appreciates this opportunity to be of service to the City. Please contact me if you have any
questions or if I may be of further service.
LANDAU ASSOCIATES, INC.
Steven Quarterman
Senior Associate
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