21-101348_WetlandDelineation@LeeFedWay_4-7-2021-VIWetland Delineation
for the James Lee Commercial 3-Lots
in Federal Way
Site located at
31200 1st Ave. S., Federal Way, WA 98003
Tax Parcel No. 0821049167
Situated in the
SW ¼ of the NW ¼ of
Section 8-T21N-R4E, W.M.,
King County, Washington
Prepared for
James K. Lee & Mimi D. Lee (Clients/Property Owners)
4005 96th Ave SE
Mercer Island, WA 98040
Phone: 206-427-6415
E-mail: jimlamlee08@gmail.com
April 1, 2021
Prepared by
JOHN COMIS ASSOCIATES, LLC
Consulting for Wetlands, Streams & Mitigation Designs since 1989
1027 North Oakes Street
Tacoma, WA 98406
Office: 253-272-6808
Mobile: 253-686-4007
E-mail: jcomis@johncomisassociates.com
(JCA Job #200813)
Lee Wetland Delineation @ Federal Way
By John Comis Associates (JCA)
Date: 04/01/21
Page 1 of 34
JOHN COMIS ASSOCIATES, LLC
Consulting for Wetlands, Streams & Mitigation Designs since 1989
1027 North Oakes Street
Tacoma, WA 98406
Phone: 253-272-6808
Mobile: 253-686-4007
E-mail: jcomis@johncomisassociates.com
April 1, 2021
City of Federal Way
Community and Economic Development Department
33325 8th Avenue South
Federal Way, WA 98003-6325
SUBJECT: Wetland Delineation for the James Lee Commercial 3-Lots in Federal Way, located at
31200 1st Ave. S., Federal Way, WA 98003, Parcel No. 0821049167, situated in the SW ¼ of the NW ¼ of
Section 8-T21N-R4E, W.M., King County, WA (Job#200813)
To Whom It May Concern:
On 8/20/20, John Comis Associates (JCA) delineated the entire onsite wetland boundary around Wetland
“A” as it exists in the southern part of the project site. This work includes a routine onsite delineation 1 of
the wetland that was originally identified by JCA in 2018, and published in the Wetland Reconnaissance
Report by JCA dated 5/12/2018 (JCA Job#180510). This wetland is also indicated on the Critical Area
Mapping by the City of Federal Way.
BACKGROUND:
On 5/11/2018, John Comis Associates (JCA) conducted a site visit and wetland verification, without a
detailed rating and no buffer plan was prepared at that time. JCA found that there was an onsite wetland at
the southern-most part of the southern lot, Parcel No. 0821049167. The project site consisted of 3 large
lots that extend along the east side of 1st Ave. S. This wetland does not appear to be associated with any
local fish or wildlife stream.
JCA found that the Project Site would require future field work to delineate the onsite wetland boundaries
and document existing onsite conditions in order to complete a detail rating for critical area review by City
of Federal Way Planning Department (the City). For details about the findings and mapping used for this
verification, please refer to the attached map figures that are included with this report.
Current Wetland Delineation & Rating:
These services include a routine onsite determination for the presence or absence of regulated wetlands
using field indicators for hydrophytic vegetation, hydric soils, and wetland hydrology. Wetland
delineations are based on the current US Army Corps of Engineers (USACE) Regional Supplement to the
Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region
1 Wetlands are delineated using the current manual required by all state agencies in the application of state laws and regulations as
well as city or county regulations for the implementation of regulations under the Growth Management Act. This methodology is
consistent with the current US Army Corps of Engineers (USACE) Regional Supplement to the Corps of Engineers Wetland
Delineation Manual: Western Mountains, Valleys, and Coast Region (USACE, 2010)
Lee Wetland Delineation @ Federal Way
By John Comis Associates (JCA)
Date: 04/01/21
Page 2 of 34
(USACE, 2010). Wetland categorization or rating are based on the current “Washington State Wetland
Rating System for Western Washington: 2014 Update”, effective January 2015 (WDOE Pub #04-06-029).
Please note that offsite wetlands and/or streams were evaluated if they are located within 315 feet 2 of the
Project Site, but not with the same detail or flagging.
The Field Note Sketch Map (FNSM) shows consecutively numbered data points around the boundary of the
delineated Wetland “A”. These data points are flagged with colored ribbons as noted and shown on the
FNSM. The field notes also show other data points such as sample test plots (TP’s), storm drain features
(such as possible or ‘found’ culverts), vegetation lines, fences, and various other site-specific information
such as the abandoned Hobo Encampments (see attached FNSM for details).
At this time, the data points are located by Azure-Green Consultants LLC, and plotted to scale on a site
plan map that is used by JCA to prepare the detailed “Wetland Delineation & Buffer Plan for the Lee Site in
Federal Way” (Figure 5). JCA has add applicable notes and information to the final drawing to show the
regulated wetland and buffer areas, together with a buffer modification plan.
JCA has delineated the onsite wetland boundary that extends around the wetland with flagged data points
as noted on the FNSM and the “Wetland Delineation & Buffer Plan”. This work includes test holes dug by
hand to depths of 16 to 20 inches at various locations within the project site to determine possible wetland
indicators and identify onsite wetlands.
JCA has prepared this report describing our findings and recommendations about the wetland rating and
buffer width requirements. JCA has recommended a wetland rating based on parameters that are in
accordance with current City of Federal Way Municipal Code (PMC) requirements for critical wetland
areas.
SURVEYED:
The data points are flagged with colored ribbon marked as follows:
• "WETLAND DELINEATION-number" (pink ribbon, tied to vegetation, see circled numbers on
the sketch map)
• “TEST PLOT-#number” (blue & green ribbons, tied to vegetation, see triangles on the sketch
map)
The number and description of these data points are as follows:
• 22 Wetland delineation points: #A1 to #A20, including #A1.1 and A10.1 [see FNSM for details]
• 3 Sample test plots: TP#1, TP#2 & TP#3
• 3 Drainage culverts: one was “found” but other 2 are supposed to be located within or near the
west side of this project site (see attached City drainage map of this area)
• Any “save” trees (unmarked by JCA) that are situated within about 50 feet of the delineated
wetland “A” boundary that are greater than 12” DBH
SUMMARY OF WETLAND FINDINGS:
No drainage culvert or other outlet structure was found to the south under 312th Street that may drain
surface water runoff that accumulates in this topographic depression. There may be some sort of outlet
structure under 312th, but it was overgrown at this time and JCA was not able to locate it for the wetland
study.
2 The 315-foot distance is the maximum buffer width for the highest rated Category 1 wetland, plus 15 feet for building setback from
the buffer boundary line. This represents a reasonable distance from which a “regulated activity” should not impact a “regulated
wetland.
Lee Wetland Delineation @ Federal Way
By John Comis Associates (JCA)
Date: 04/01/21
Page 3 of 34
The drainage basin that is tributary to this pothole depression appears to extend north and west of the
intersection at 1st Avenue and 312 Street SW. However, it does not include the roadways as their surface
water runoff appears to be contained within the storm drains in these roadways.
Vegetation classes within the delineated wetland are clearly established by forested and scrub-shrub
vegetation including salmonberry, red osier dogwood, and Himalayan blackberries at the wetland edges.
Wetland “A” is evaluated in accordance with the FWMC for critical wetland areas. The vegetation classes
are generally characterized in accordance with Cowardin et al 3 as follows:
WL: SYSTEM CLASS WATER REGIME (abbreviation)
A Palustrine Forested/
scrub-shrub
seasonally flooded (P,FO/SS,C)
Wetland “A” is rated a Category III wetland in accordance with the current 2014 WDOE Updated Rating
methods. It is classified as “depressional” per the WDOE hydrogeomorphic classification system. Scores
have been computed at this time by JCA (see Appendix 3), and this rating is based on our field
observations of wetland conditions that we find at this study area.
Wetland “A” has a habitat value that is rated less than 5 points. A minimum buffer width for this category
of wetland is 80 feet with a habitat score of 4 points. Please refer to the FWMC 19.145.420—Wetland
Rating and Buffers, for details about buffer requirements. Also, new buildings would be required to have a
minimum building setback line (BSL) at 15 feet measured landward from the buffer boundary line.
Wetland “A” is 3,521 square feet in size (0.085 acres). It is densely forested with scrub-shrub vegetation
growing in the central part of the wetland. It has 2 direct inlets—one from the west side and one from the
south side. Both direct inlets provide sufficient hydrology for this wetland to function and no groundwater
was observed by JCA during the 3 times that this wetland was examined. Lighting may be required to be
directed away from wetland buffers unless otherwise determined by the City.
A new commercial development for this property is required to have a minimum 60-foot upland buffer
preserved around the wetland that is measured landward from the delineated wetland boundary. This
distance is based on the category of wetland, levels of habitat functions, and potential impacts of land use
imposed by the new development on the wetland. That minimum buffer width may be proposed to be
modified using “Buffer Reduction” or “Buffer Averaging” in accordance with FWMC requirements.
STANDARD OF CARE:
Please be advised that JCA has provided professional services that are in accordance with the degree of
care and skill generally accepted in the performance of this environmental evaluation, including wetland
determinations, delineations, classifications, ratings and other analysis. This should be reviewed and
approved by the local government agency with permitting authority and potentially other agencies with
regulatory authority prior to extensive site design or development. No warranties are expressed or implied
by this study until approved by the appropriate resource and permitting agencies.
The wetlands described in this report correctly represent determinations and delineations made by me or
under my direct supervision. The findings and recommendations expressed in this report are based on my
professional judgment together with onsite and offsite investigations that include data obtained from
various sources as indicated in this report.
If you have any questions or comments regarding this report, our findings or recommendations, or if you
need additional copies, please feel free to call me at your earliest convenience.
3 US Fish and Wildlife Service's “Classification of Wetlands and Deepwater Habitats of the United States”, FWS/OBS-79/31
(Cowardin et al, 1979)
Lee Wetland Delineation @ Federal Way
By John Comis Associates (JCA)
Date: 04/01/21
Page 4 of 34
Respectfully,
4/1/2021
John G. Comis, PWS Date
Professional Wetland Scientist (PWS #00810)
Certified Wetlands Specialist
File: \LeeWetlandDelineation@FedWayRpt.doc (JCA Job#200813)
Cc: James K. Lee & Mimi D. Lee (Clients/Property Owners), 4005 96th Ave SE, Mercer Island, WA 98040,
E-mail: jimlamlee08@gmail.com, Phone: 206-427-6415
Enclosures:
FIGURES:
Figure 1. Vicinity Map for Lee Site in Fed Way
Figure 2. Aerial Photo Map for Lee Site in Fed Way
Figure 3. Terrain Map for Lee Site in Fed Way
Figure 4. Terrain Map with overall drainage
Figure 5. Wetland Delineation & Buffer Plan for the Lee Site in Federal Way (by JCA & CBay, 11/19/2020)
APPENDICES:
Appendix 1. Methodology Used for Wetland Determination, Delineation, Regulation and Buffer Standards
Appendix 2. Field Data Forms with Field Note Sketch Maps and GPS Data Plots
Appendix 3. Wetland Rating Form with Map Information
Appendix 4. Photographs of Existing Site Conditions including Adjacent Offsite Areas
Appendix 5. Resumes for Wetland and Wildlife Consultants
Appendix 6. References for Wetland and Wildlife Habitat Analysis
Pictometry International Corp., King County
King County iMap
Date: 5/10/2018
Notes:±The information included on this map has been compiled by King County staff from a variety of sources and is subject to
change without notice. King County makes no representations or warranties, express or implied, as to accuracy,
completeness, timeliness, or rights to the use of such information. This document is not intended for use as a survey
product. King County shall not be liable for any general, special, indirect, incidental, or consequential damages including,
but not limited to, lost revenues or lost profits resulting from the use or misuse of the information contained on this map.
Any sale of this map or information on this map is prohibited except by written permission of King County.
Legend
index contours - 100
foot
contours - 5 foot
(below 1000 feet) and
10 foot
Potential landslide
hazard areas (2016,
see explanation--->)
Potential steep slope
hazard areas (2016,
see explanation--->)
Erosion hazard (1990
SAO)
Seismic hazard (1990
SAO)
Coal mine hazard
(1990 SAO)
Stream (1990 SAO)
class 1
class 2 perennial
class 2 salmonid
class 3
unclassified
Wetland (1990 SAO)
Sensitive area notice
on title
Streams
Pictometry International Corp., King County
King County iMap
Date: 5/10/2018
Notes:±The information included on this map has been compiled by King County staff from a variety of sources and is subject to
change without notice. King County makes no representations or warranties, express or implied, as to accuracy,
completeness, timeliness, or rights to the use of such information. This document is not intended for use as a survey
product. King County shall not be liable for any general, special, indirect, incidental, or consequential damages including,
but not limited to, lost revenues or lost profits resulting from the use or misuse of the information contained on this map.
Any sale of this map or information on this map is prohibited except by written permission of King County.
Legend
Parcels
index contours - 100
foot
contours - 5 foot
(below 1000 feet) and
10 foot
Potential landslide
hazard areas (2016,
see explanation--->)
Potential steep slope
hazard areas (2016,
see explanation--->)
Erosion hazard (1990
SAO)
Seismic hazard (1990
SAO)
Coal mine hazard
(1990 SAO)
Stream (1990 SAO)
class 1
class 2 perennial
class 2 salmonid
class 3
unclassified
Wetland (1990 SAO)
Sensitive area notice
on title
Streams
King County
King County iMap
Date: 5/10/2018
Notes:±The information included on this map has been compiled by King County staff from a variety of sources and is subject to
change without notice. King County makes no representations or warranties, express or implied, as to accuracy,
completeness, timeliness, or rights to the use of such information. This document is not intended for use as a survey
product. King County shall not be liable for any general, special, indirect, incidental, or consequential damages including,
but not limited to, lost revenues or lost profits resulting from the use or misuse of the information contained on this map.
Any sale of this map or information on this map is prohibited except by written permission of King County.
Legend
Parcels
index contours - 100
foot
contours - 5 foot
(below 1000 feet) and
10 foot
Potential landslide
hazard areas (2016,
see explanation--->)
Potential steep slope
hazard areas (2016,
see explanation--->)
Erosion hazard (1990
SAO)
Seismic hazard (1990
SAO)
Coal mine hazard
(1990 SAO)
Stream (1990
class 1
class 2 perennial
class 2 salmonid
class 3
unclassified
Wetland (1990
Sensitive area notice
on title
Streams
Lee Wetland Delineation @ Federal Way
By John Comis Associates (JCA)
Date: 04/01/21
Page 5 of 34
APPENDIX 1
METHODOLOGY USED FOR WETLAND
DETERMINATION, DELINEATION,
REGULATION AND BUFFER
STANDARDS
Lee Wetland Delineation @ Federal Way
By John Comis Associates (JCA)
Date: 04/01/21
Page 6 of 34
METHODOLOGY
A. Manual Methods Used for Wetland Determination and Delineation
The identification of “wetlands” by John Comis Associates (JCA) for this analysis was consistent with
applicable manual methods and in accordance with the City of Federal Way Municipal Code (FWMC)
requirements. JCA used the most recent editions of the federal and state wetland manuals and applicable
regional supplements as approved and adopted by the Washington State Department of Ecology (WDOE).
This appendix describes the methods used including key definitions, criteria, abbreviations, regulation
standards and applicable portions of code requirements used in this analysis.
“Wetlands” are delineated using the current US Army Corps of Engineers (USACE) Regional Supplement
to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region
(USACE 2010).4 The field investigation is limited to a determination of the presence or absence of
"regulated wetlands" on or near the project site, including offsite areas within 315 feet 5 of the site
boundary. If an offsite wetland or stream is known or suspected to be within 315 feet of the project, then
the wetland or stream must be evaluated and delineated based on the best available data for offsite areas.
[See report figures for depictions of radii around the wetland unit that were used for this analysis.]
For an area to be determined a “wetland” it must necessarily meet the scientific definition and triple
parameter criteria. These criteria which an investigator must use to determine if a sample test plot is in a
“wetland” or “non-wetland” area is limited to the presence of all 3 wetland criteria: hydrophytic
vegetation, hydric soils, and persistent wetland hydrology. This means that to make a positive wetland
determination, all 3 criteria must be present. The absence of one, two, or all three of the criteria should
result in a non-wetland determination.
The presence or absence of “field indicators” is used to determine if a criterion is met. If a field indicator is
absent, then an indirect indicator may be used. For example, the absence of inundation or saturation during
a dry summer field investigation could result in the hydrology criterion not being met. However, the
presence or absence of encrusted detritus on twigs or blackened leaves on bare ground in a depression may
be used to help verify sufficient inundation during a wetter period of the growing season.
The 2010 Regional Supplement Manual stipulates 3 key provisions of the definition of wetlands include:
a. Inundated or saturated soil conditions resulting from permanent or periodic inundation or
saturation by ground water or surface water (saturation within 12 inches of the surface for at least 20 to 30
consecutive days during periods in the Mesic growing season [March thru October]). In accordance with
the USACE 2010 “Manual” (pages 65 & 123): “This standard requires 14 or more consecutive days of
flooding, ponding, or a water table 12 inches (30 cm) or less below the soil surface, during the growing
season at a minimum frequency of 5 years in 10 (50% or higher probability) (National Research Council
1995) …”
b. A prevalence of vegetation typically adapted for life in saturated soil conditions (i.e. dominance
of hydrophytic vegetation).
c. The presence of “normal circumstances”.
The selection of a specific method and procedure for identifying wetlands may follow one of the following
methods:
4 Wetlands are required to be delineated by all state agencies in the application of any state laws and regulations as well as any city
or county in the implementation of any regulations under the Growth Management Act. This methodology has been modified to be
consistent with the current US Army Corps of Engineers (USACE) Regional Supplement to the Corps of Engineers Wetland
Delineation Manual: Western Mountains, Valleys, and Coast Region (USACE 2010).
http://www.usace.army.mil/Portals/2/docs/civilworks/regulatory/reg_supp/west_mt_finalsupp.pdf
5 The 315-foot distance is the standard buffer width for the highest rated Category 1 wetland, plus 15 feet for a building setback.
This represents a reasonable distance from which a “regulated activity” should not impact a “regulated wetland” (per PCC 18E.10.050
(definitions), 18E.20.030 (exemptions) and 18E.30.060 (buffers).
Lee Wetland Delineation @ Federal Way
By John Comis Associates (JCA)
Date: 04/01/21
Page 7 of 34
• the "routine determination method" for undisturbed and non-problem area wetlands;
• the "offsite determination method" for areas within 300' of the site boundary; and/or
• the "disturbed area and problem area wetland determination procedures" for areas with disturbed or
atypical vegetation, soils or hydrology. If an area is disturbed, then a higher level of analysis such as a
"Comprehensive" determination method may be required.
The preferred and simplest method is the "ROUTINE Determination Method" for typical, generally
undisturbed areas with normal environmental conditions. The routine method is used in areas where the
vegetation, soils and hydrology condition can be readily observed.
For areas that are complex, atypical, disturbed or altered environmental conditions, a
“COMPREHENSIVE Determination Method" may be used. The comprehensive method employs
transect sampling procedures that may require deeper test holes to be dug in areas that have been filled or
graded.
Generally, the investigator is looking for a portion of the site (called a test plot) where a “typical condition”
exists--where a well-established plant community is present with no evidence of recent clearing, grubbing,
filling, grading, or soil drainage activities. This situation should occur during a period when “normal
circumstances” are present. That is during periods of the year when normal environmental conditions such
as moderate rainfall and average antecedent moisture conditions (AMC) exist within a wetland or a
watershed area.
For the hydrophytic vegetation criterion to be met, a dominant number (i.e. more than 50%) of “OBL,
FACW and/or FAC” indicator species must be present in the sample plot (see the discussion of these
abbreviations in a later section of this appendix). The vegetation analysis is based on the 3-dominant
species in each of 4 vegetation layers (or strata: trees, saplings/shrubs, herbs/grasses, and woody vines). Or
if only 1 or 2 vegetation layers exist at the test plot, then 5 dominant species are used to make the
determination.
If a test plot has no well-established vegetation due to recent clearing and grubbing, or the soils have been
severely disturbed due to excavation, filling or grading activities, the test plot is called an "atypical
situation". In atypical or disturbed situations, the wetland determination may be based only on soil borings
into the undisturbed soil stratum below the fill line and by hydrology criteria. If an area is disturbed, then a
higher level of analysis such as a "comprehensive" determination method may be required.
The procedure used for each test plot is indicated on the individual data sheets. The environmental
conditions that exist at the site on the day of the field investigations are indicated in field notes and marked
in the appropriate “normal” (or not normal) blank at the top of the data sheet. If the vegetation, soils or
hydrology are found disturbed, this is explained at the bottom of the sheet. The results for each test plot are
recorded on data forms and included with this report in Appendix 2.
B. KEY DEFINITIONS USED
For this study, "wetlands” are defined using the adopted State of Washington's Growth Management Act
definition in RCW 36.70A.030(21):
“Wetland” or “wetlands” means areas that are inundated or saturated by surface water or ground
water at a frequency and duration sufficient to support, and that under normal circumstances do
support, a prevalence of vegetation typically adapted for life in saturated soils conditions.
Wetlands generally include swamps, marshes, bogs, and similar areas." (Corps of Engineers
Regulation 33 CFR 328.3, 1988) (Federal Resister 1982), the Environmental Protection Agency
(Federal Register 1985), the Shoreline Management Act (SMA), and the Growth Management Act
(GMA)
Lee Wetland Delineation @ Federal Way
By John Comis Associates (JCA)
Date: 04/01/21
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In addition, the SMA and GMA definitions added: “Wetlands do not include those artificial
wetlands intentionally created from non-wetland sites, including but not limited to, irrigation and
drainage ditches, grass-lined swales, canals, detention facilities, wastewater treatment facilities,
farm ponds, and landscape amenities, or those wetlands created after July 1, 1990, that were
unintentionally created as a result of the construction of a road, street, or highway. Wetlands may
include those artificial wetlands intentionally created from non-wetland areas to mitigate the
conversion of wetlands."
Other key definitions may also apply that are in the adopted City of Federal Way Municipal Code
(FWMC), Chapter 19, Critical Areas Regulations [Note that the City uses a WDOE 4-tiered rating system
for categorizing wetlands]. Please refer to Section E in this appendix for details about applicable FMC
regulations.
C. WETLAND IDENTIFICATION AND DELINEATION CRITERIA
By Vegetation:
When “normal circumstances” exist on the site, vegetation is used where plants are established and
relatively undisturbed. These circumstances are considered “typical” situations as compared to “atypical
salutations” where one or more of the 3 parameters (vegetation, soil, and/or hydrology) have been
sufficiently altered or disturbed. The legal definition of wetlands 6 contains the phrase “under normal
circumstances,” which was included because there are instances in which the vegetation in wetlands may
have been inadvertently or purposely removed or altered as a result of recent natural events or human
activities. “Recent” is defined to mean that period of time since legal jurisdiction of an applicable law
began.
Field Data Form is used for “routine wetland determination” when the 3-parameters (vegetation, soil and/or
hydrology) have not been sufficiently altered by recent human activities or natural events to preclude the
presence of wetland indicators.7 Test plot in which vegetation, soils, and/or hydrology have not been
significantly altered are indicated on the forms by YES for “Do normal circumstances exist?” and by NO
for “Is the site significantly disturbed (Atypical situation)?”
Do normal circumstances exist on the site? Yes No
Is the site significantly disturbed (Atypical situation)? Yes No
Is the area a potential problem area? Yes No
“Problem areas” apply to certain wetland types (or difficult conditions) that may make application of field
indicators of one or more parameters difficult to determine, at least at certain times of the year. These are
not considered to be “atypical situations”. Instead they are types of wetlands in which an indicator(s) of
one or more parameters may be periodically lacking due to normal environmental conditions or seasonal
or annual variations in environmental conditions that result from causes other than human activities or
catastrophic natural events. 8
For this study, vegetation is used as a primary field indicator, documented at 3 individual test plots (TP’s)
and recorded on Field Data Forms (see Appendix 2). The interpretation of data for determining areas as
“wetland” or “non-wetland” is based on dominance of hydrophytic vegetation, which means that the
presence of hydrophytes is more than 50% of the listed indicator species at each test plot.
A plant species is considered dominant in a test plot if more than 10% of the plants growing in that area
appear to be the same species. This is an estimate of the relative density of a species in a sample area. By
routine methods, this is usually made by visual inspection of the dominant plants in a representative sample
area. As defined in the USACE 2010 Manual, a dominant species exerts a controlling influence on or
6 WDOE 1997 Manual, paragraph 25a, page 9, Definition (from Federal Register, SMA and GMA)
7 Based on WDOE 1997 Manual, Appendix A, Glossary definition for “Atypical situation”
8 WDOE 1997 Manual, paragraph 77, page 81, Section G: Problem Areas
Lee Wetland Delineation @ Federal Way
By John Comis Associates (JCA)
Date: 04/01/21
Page 9 of 34
defines the character of a plant community. Dominance on the other hand is used as a descriptor of
vegetation that is related to the standing crop of a species in an area, usually measured by height, aerial
cover, or basal area (for trees). This should not to be confused with a vegetation class that must comprise
more than 30% of the aerial cover in the entire wetland (or upland).
The TP locations are shown on the Wetland Delineation & Buffer Plan Map (Figure 5) and on our Field
Note Sketch Map (FNSM, Appendix 2). Onsite data are extrapolated to adjacent offsite areas where
applicable. These upland or non-wetland areas are indicated as “UP” or “non” on the maps provided in the
report (see field note sketch maps in Appendix 2).
Plant indicator species are listed on the Field Data Forms in all the areas where vegetation is relatively well
established and can be identified. Onsite vegetation is not significantly disturbed and are generally used for
“wetland” and “non-wetland’ determination. If more than 50% (i.e. 51 or more percent) of the dominant
plant species in a test plot are OBL, FACW and FAC, then the hydrophytic vegetation criteria is said to be
met and it is marked “yes” on the field data form.
The specie identifications are based on available plant keys such as Hitchcock and Cronquist's Flora of the
Pacific Northwest (1973). To determine whether plant species exhibit hydrophytic adaptations, if they are
native or non-native (introduced), and which strata (tree, shrub, herb) they normally occupy, we use the
National List of Plant Species That Occur in Wetlands: Northwest (Region 9), published by the US Fish
and Wildlife Service, May 1988. The indicator statuses for the various species found in the area are
determined based on the National List together with the December 1993 supplement for the Northwest
Region.
The indicator status describes the estimated probability of a plant species occurring in wetlands.
Parenthesis ( ) around an indicator signifies the status is assigned by JCA. A question mark (?) after an
indicator signifies it is tentative based on JCA field experience & observations. Indicators are:
OBL = Obligate Wetland species: "almost always occurs", >99% probability
FACW = Facultative Wetland species: "usually occurs", 67-99% probability
FAC = Facultative species: "equally likely to occur", 34-66% probability
FACU = Facultative Upland species: "usually occurs in non-wetlands", 67-99% probability
UPL = Upland species: "almost always occurs in non-wetlands", >99% probability
NI = No Indicator assigned: if a species does not occur in wetlands in any region of the National List, then “no
indicator is assigned”.
+ = Slightly more frequently found in wetlands
- = Slightly less frequently found in wetlands
* = Tentative assignment based on either limited information or conflicting reviews from the 1993 Northwest
Supplement of the National List.
By Soils:
For wetland (or “hydric”) soil determinations, we use the hydric soil criterion prescribed in Part III of the
1993 Washington State Wetland Manual. Hydric soils are defined as "a soil that formed under conditions
of saturation, flooding, or ponding long enough during the growing season to develop anaerobic conditions
in the upper part” (USDA-NRCS 1995, Federal Register, 7/13/94, Vol. 59, No. 133, pp. 35680-83). The
National Technical Committee for Hydric Soils (NTCHS) has established the ‘criteria’ for soil
classification and ‘field indicators’ for hydric soil determination (see Reference in Appendix <<6). In
general, a hydric soil determination is made based on primary soil color indicators and secondary indicators
in representative sample test plots that we examine onsite in the upper 12" to 16” of the soil profile. If a
soil is saturated long enough, then that soil may be determined as hydric based on its color indicators.
Notice that the hydrology criteria usually mean that the soil remains saturated for at least 20 or more
consecutive days during the early growing season when soil temperatures are above biologic zero (41oF) as
measured at a depth of 16” below the soil surface.
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In general, "organic hydric soils" develop as a result of prolonged anaerobic conditions with long periods of
saturation impeding decomposition (peat or muck) and have greater than 16" of organic matter in the
surface layer (Histosols). "Mineral hydric soils" have less than 16" of organic matter (if some is present,
then it may have a 'histic epipedon'). They are saturated for more than 15 consecutive days during the
growing season (the period when soil temperatures are above biologic zero, 41oF, as defined by "Soil
Taxonomy", 1975; usually March-October), and contain dominant gleying and/or redoximorphic features.
The soil color and/or presence of redoximorphic features 9 or gleying in a sample are primary field
indicators of whether a mineral soil is either hydric or non-hydric soil. Non-hydric soils are generally a
dark brown to rusty red or yellowish brown in their matrix color. Hydric soils are generally black, very
dark brown, grayish brown to gray, or washed out in color. A field indicator for a saturated organic hydric
soil is a rich black matrix color of say 2/1 or 2/2. A field indicator for a saturated mineral soil is a leached
matrix color of say 3/1 or 4/1 or 5/1 or 6/1). A hydric mineral soil may have a low chroma color feature (at
least 1 if no redoximorphic features are present or a chroma 2 if prominent redox features are present in the
soil matrix).
Gleying and prominent redoximorphic features are color indicators of prolonged saturation and indicate
that anaerobic conditions probably exist for sufficient periods of time to develop wetland soils. Gleyed
soils are generally bluish-green to grayish-green in color throughout the soil mass or in mottles (spots or
streaks) interspersed within the dominant soil color (matrix color) in a layer (soil horizon). Gleying results
from the leaching of the dissolved (reduced) iron and manganese minerals out of the soil matrix. Soils
gleyed to the surface or to the surface layer of organic material are generally considered hydric. Soils that
are saturated throughout the year are usually uniformly gleyed to the surface (Tiner and Veneman 1987).
Redoximorphic features or “mottles” are generally yellow to reddish brown blotches or spots accumulating
in mineral soil due to a fluctuating water table during the growing season. The size, number and color of
redox features reflect the duration of soil saturation and thus whether the soil is hydric. Redox features in
hydric soils should be "distinct" or "prominent" in the upper horizon. Mineral soils that have a dark grayish
matrix color (chroma 2 or less) with distinct or prominent redox features are hydric if the features are not
relic. Mineral soils with a predominantly brown or yellow matrix color (chroma of 3 or more) and light
gray redox features are not usually hydric. 10
The National Technical Committee for Hydric Soils has developed criteria for identifying hydric soils and a
list of the Nation's hydric soils is maintained by the National Resource Conservation Service (NRCS
[formerly Soil Conservation Service, SCS], 1987). A federal manual has also been published by the
USDA-NRCS that describes current methods and limitations for identifying hydric soils for the National
and State lists.
The NRCS maintains the list of hydric soil map units for each county in the US. The list is used for
identifying which soils are hydric based on the local soil series descriptions. These soil series descriptions
for soil map units are indicated by this study as within or associated with the project site. The soil
descriptions for the mapped areas may be found in the 1973 [NRCS] Soil Survey of King County (see the
References appendix for information about the Pierce County Soil Survey Report).
By Hydrology:
Hydrology observations at each sample plot are indicated on the Field Data Forms provided with this report in
Appendix 2. The saturation and water level data together with the respective date that the measurement was
made are shown on the data form.
9 “Redoximorphic features” are formed by the processes of reduction, translocation, or oxidation of Fe and Mn oxides
(formerly called mottles and low chroma colors). Redox concentrations (reddish mottles) occur as pore linings along root
channels and ped faces (Vepraskas, 1994). “Distinct” and “prominent” are defined in the glossary of the reference text
Field Indicators of Hydric Soils in the United States.
10 Hydric Soils Guidebook, Washington State Department of Ecology, Pub #90-20, July 1990
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For wetland hydrology determination, we use the “USACE 2010 Manual” for wetland hydrology indicators. The
presence of inundation and/or saturation for a sufficient "hydroperiod" is determined based on the depth to
saturation including capillary fringe. This depth must be 12" or less as measured from the ground surface. In
wetland margins this may also include observations or assumptions based on the presence or absence of hydric
soils and hydrophytic vegetation when there is a general lack of saturation or standing water due to observations
made during dry periods during the water year.
Other field indicators are also used to help determine the presence or absence of sufficient hydrology for positive
or negative wetland determinations. These indicators include topographic features and elevations, encrusted
detritus or debris, silt lines, hydraulic gradients, free-water in a pit or soil probe hole, and tributary area analysis
of onsite and offsite drainage.
If the saturation level is determined to be below 12” for more than 7 consecutive days during the growing
season, then the primary indicator for saturation may not sufficient for a positive wetland determination. If the
saturation level falls below 12” during the period before or after the 12” measurement is made, then the test plot
is determined to be non-wetland by hydrology.
After a wetland determination is made, the wetland area is analyzed to determine if it is a high quality
wetland or if it has any of several irreplaceable ecological functions. The wetland is then analyzed for any
significant habitat values such as size, classifications, plant species diversity, structural diversity, special
habitat features, buffer conditions, and connection to streams or other habitat areas.
D. WETLAND CLASSIFICATION (NON-TIDAL)
CATEGORIES
Different types of wetlands are separated from one another on the basis of wetland class and wetland
category. Wetland class is a scientific system based upon dominant plant communities, substrate
conditions, hydrologic regime, and location in the watershed. Wetland classification is a categorization
system used to regulate land uses adjacent to wetlands.
Wetland Class: a science-based classification system is used based on a U.S. Fish and Wildlife Service
publication titled Classification of Wetlands and Deep-Water Habitats of the United States that was edited
by Lewis M. Cowardin, et al, and published in December 1979. Cowardin divides wetlands into five
systems (Marine, Estuarine, Riverine, Lacustrine, and Palustrine), eight subsystems (Subtidal, Intertidal,
Tidal, Lower Perennial, Upper Perennial, Intermittent, Limnetic, and Littoral), 10 classes, and numerous
modifiers. A combination of the system name, subsystem, name, class, and a modifier code are used to
designate the wetland class.
WDOE expanded the term wetland class by incorporating use of the Hydrogeomorphic Method (HGM)
classification into the “Washington State Wetland Rating System for Western Washington: 2014 Update”
(WDOE Publication No. 04-06-029). The HGM is based on the “landscape” location of a wetland or
portion of a wetland. The HGM classes are Depressional, Riverine, Lake-fringe, Slope, Flats, and
Freshwater Tidal.
Wetlands identified by this study are classified using a hierarchical multi-level approach developed by the
US Fish and Wildlife Service for their scientific classification system. The classification system is
published in the report titled Classification of Wetlands and Deep-Water Habitats of the United States,
FWS/OBS-79/31, by Cowardin, et al. (December 1979).
The system of classification divisions is based on habitats that share the influence of similar hydrology,
geomorphology, chemical, or biological factors. The wetland systems involved in the project site are
generally limited to "Palustrine" systems. Palustrine wetlands (these are the only wetlands identified
within this study area) are divided into 9 classes with 24 different subclasses. These are determined by
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either the substrate material or the ‘dominance vegetation’ associated with a respective non-tidal area. The
classes of non-tidal palustrine systems are as follows:
CLASS [NON-TIDAL]
(RB) Rock Bottom
(UB) Unconsolidated Bottom
(AB) Aquatic Bed
(US) Unconsolidated Shore
(ML) Moss-Lichen
(EM) Emergent
(SS) Scrub-Shrub
(FO) Forested
(OW) Open Water (unknown bottom)
The subclasses are not identified in this study area but if assigned they would be based on the substrate
material or ‘dominance vegetation’ associated with the non-tidal area. ‘Dominance types’ may also be
characterized within freshwater Palustrine Systems based on different invertebrate fauna that typically
inhabit these areas.
Water regimes are assigned for each class based on the hydroperiod or duration of flooding (inundation) or
saturation associated with the non-tidal area. These are defined for non-tidal (freshwater) areas as follows:
WATER REGIME [NON-TIDAL]
(A) Temporarily flooded: flooded (inundation by surface water) for brief periods during growing season but
the water table is otherwise well below the soil surface
(B) Saturated: substrate is saturated for an extended period during growing season but surface water is
seldom present
(C) Seasonally flooded: flooded for extended periods during the growing season, but usually no surface water
by the end of the growing season
(D) Seasonally flooded/well drained
(E) Seasonally flooded/saturated: flooded for periods, but usually saturated by groundwater at or near the
surface thru most of the growing season
(F) Semipermanently flooded: flooded throughout growing season in most years, when surface water is
absent, water table is at or near the surface
(G) Intermittently exposed: flooded throughout year except in years of extreme drought
(H) Permanently flooded: flooded (water covers land surface) throughout the year in all years
(J) Intermittently flooded: surface is usually exposed with surface water present for variable periods with no
seasonal pattern
(K) Artificially flooded
(W) Intermittently flooded/temporary
(Y) Saturated/semi-permanent/seasonal
(Z) Intermittently exposed/permanent
(U) Unknown
SPECIAL MODIFIERS
(b) beaver
(d) partially drained/ditched
(f) farmed
(h) diked/impounded
(r) artificial substrate
(s) spoil
(x) excavated
Other modifiers for water chemistry and soil may also be employed to more adequately describe the
wetland and deepwater habitats. These may be applied at the class or lower level in the hierarchy. The
farmed modifier may also be applied to the ecological system.
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The class of a particular wetland describes its general appearance in terms of either the dominant vegetation
or the substrate. When over 30% cover by vegetation is present, a vegetation class is used (e.g.,
"emergent", "scrub-shrub" and/or "forested"). When less than 30% of the substrate is covered by
vegetation, then a substrate class is used (e.g., "unconsolidated bottom", "aquatic bed", or "moss-lichen").
Typical demarcations of these classes of palustrine wetland systems are shown in the Cowardin report.
[Also, reference is made to the current (1988) National Wetlands Inventory (NWI) map and legend.]
Wetlands that have a single vegetation species that dominate 90% of the total wetland area are called a
"mono-type". This may occur where more than the one species is present but the total area of their
coverage is less than 10%. If another vegetation class or species dominates more than 10% of the wetland,
then it has higher habitat diversity. This can be based on the number of plant species found in a class, the
number and quality of the structural layers and the interspersion of classes which creates increased “edge
effect” and habitat diversity. This may also result in a higher wetland “rating”.
E. CITY OF FEDERAL WAY CRITICAL AREA REGULATIONS AND BUFFER
STANDARDS
The standards adopted in the City of Federal Way Municipal Code (FWRC) for ENVIRONMENTALLY
CRITICAL AREAS are covered in Chapter 19.145. The sections under Article III cover “Fish and
Wildlife Habitat Conservation Areas”, which include streams and lakes. The sections under Article IV
cover “Wetlands”:
Article IV. Wetlands
19.145.410 Wetland identification and delineation.
19.145.420 Wetland rating and buffers.
19.145.430 Development within wetlands.
19.145.440 Development within wetland buffers.
19.145.410 Wetland identification and delineation.
(1) Generally. Identification of wetlands and delineation of their boundaries pursuant to this chapter shall
be done in accordance with the approved federal wetland delineation manual and applicable regional
supplements. All areas within the city meeting the wetland designation criteria are hereby designated
critical areas and are subject to the provisions of this chapter. Wetland delineations are valid for five years;
after such date the city shall determine whether a revision or additional assessment is necessary.
(2) Evaluation. If the city determines that a wetland may exist on or within 225 feet of the subject property,
the director may require the applicant to submit a wetland report prepared by a qualified professional. The
written report and the accompanying plan sheets shall contain the following information:
(a) Critical area report information identified in FWRC 19.145.080.
(b) Identification of all local, state, and/or federal wetland related permit(s) required for the
proposal.
(c) Documentation of fieldwork, including field data sheets, rating system forms, and baseline
hydrologic data.
(d) Description of the methodologies used to conduct the wetland delineations, rating system
forms, or impact analyses, including references.
(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.
(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;
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(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
(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).
(g) An evaluation of the functions of the wetland and adjacent buffer. Include reference for the
method used and data sheets.
(Ord. No. 15-797, § 22, 6-16-15.)
19.145.420 Wetland rating and buffers.
(1) Rating. Wetlands shall be rated according to the Washington Department of Ecology wetland rating
system, as set forth in the Washington State Wetland Rating System for Western Washington – 2014
Update (Ecology Publication No. 14-06-029, or as revised and approved by Ecology), which contains the
definitions and methods for determining whether the criteria below are met:
(a) Category I wetlands represent a unique or rare wetland type; are more sensitive to disturbance
than most wetlands; are relatively undisturbed and contain ecological attributes that are impossible
to replace within a human lifetime; or provide a high level of function. The following types of
wetlands are Category I:
(i) Wetlands of high conservation value that are identified by scientists of the Washington
Natural Heritage Program/Department of Natural Resources;
(ii) Bogs;
(iii) Wetlands with mature and old growth forests larger than one acre; and
(iv) Wetlands that perform functions at high levels (wetlands that score 23 points or more
based on functions).
(b) Category II wetlands are difficult, though not impossible, to replace, and provide high levels of
some functions. Category II wetlands are those wetlands that score between 20 and 22 points
based on functions.
(c) Category III wetlands are wetlands with a moderate level of functions that score between 16
and 19 points based on functions.
(d) Category IV wetlands are wetlands with the lowest level of functions (scoring less than 16
points based on functions) and are often heavily disturbed.
(2) Wetland buffers shall be measured perpendicular from the wetland boundary as delineated and marked
in the field. Buffer widths are established as follows in Table 1:
Table 1
Wetland Category Buffer Width (wetland
scores 3-5 habitat points)
Buffer Width (wetland
scores 6-7 habitat points)
Buffer Width (wetland
scores 8-9 habitat
points)
Category I: Bogs and wetlands of
high conservation value
250 feet 250 feet 300 feet
Category I: Forested and based on
function score
100 feet 150 feet 300 feet
Category II 100 feet 150 feet 300 feet
Category III 80 feet 150 feet 300 feet
Category IV 50 feet 50 feet 50 feet
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(3) No wetland buffer is required for those isolated wetlands 1,000 square feet or less in total area.
(4) All compensatory mitigation sites shall have buffers consistent with the buffer requirements of this
section. Buffers shall be based on the expected or target category of the proposed wetland mitigation site.
(5) Lighting shall be directed away from wetland buffers unless otherwise determined by the director.
(6) All lots approved in a recorded subdivision or binding site plan that contain wetlands and their
associated buffer in a native growth protection easement or tract may be improved pursuant to easement or
tract boundaries established in the plat regardless of subsequent regulatory buffer increases or natural
migration.
(7) All wetland and wetland buffer boundaries shown on an approved use process decision and/or building
permit shall be honored regardless of subsequent regulatory buffer increases or natural migration.
(Ord. No. 19-873, §21, 7-2-19; Ord. No. 15-797, §22, 6-16-15.)
19.145.430 Development within wetlands.
(1) Generally. No development or improvement may be located within a wetland except as provided in this
section.
(2) Development within wetlands. The specific location and extent of development within a wetland must
constitute the minimum necessary encroachment as determined through application of mitigation
sequencing set forth in FWRC 19.145.130. The city will review and decide upon development within a
wetland using process IV in Chapter 19.70 FWRC, based on the following criteria:
(a) It will not adversely affect drainage or stormwater retention capabilities;
(b) It will not lead to unstable earth conditions nor create erosion hazards;
(c) It will not be materially detrimental to any other property in the area of the subject property nor
to the city as a whole, including the loss of open space;
(d) It will result in no net loss of wetland area, function or value upon completion of compensatory
mitigation;
(e) The project is in the best interest of the public health, safety or welfare;
(f) The applicant has demonstrated sufficient scientific expertise and supervisory capability to
carry out the project; and
(g) The applicant is committed to monitoring the project and to making corrections if the project
fails to meet projected goals.
(3) Requirements for compensatory mitigation. Compensatory mitigation shall be used only for impacts
that cannot be avoided or minimized and shall achieve equivalent or greater biologic functions.
Compensatory mitigation plans shall be consistent with Wetland Mitigation in Washington State – Part 2:
Developing Mitigation Plans – Version 1 (Ecology Publication No. 06-06-011b or as revised), and
Selecting Wetland Mitigation Sites Using a Watershed Approach (Western Washington) (Ecology
Publication No. 09-06-32).
(4) Mitigation. Acceptable methods to mitigate wetland impacts include creation, re-establishment,
rehabilitation, and enhancement of in-kind wetland types within the same drainage basin that results in no
net loss of wetland area, function, or value. If approved by the city, the applicant may locate a portion or all
of the compensatory mitigation using alternative mitigation including, but not limited to, an approved and
certified in-lieu fee program or mitigation bank, and/or advanced mitigation if it is determined that off-site,
out-of-basin, and/or out-of-kind mitigation would provide a greater overall benefit to the watershed and not
result in adverse impacts to the city’s stormwater management system and/or wildlife habitat. Alternative
mitigation methods are discretionary and may become an option following an operating agreement between
the city and mitigation receiving area.
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(a) In-lieu fee. Credits from an in-lieu fee program approved under state and federal rules may be
used at the discretion of the city and when all of the following are met:
(i) The city determines that it would provide environmentally appropriate compensation
for the proposed impacts;
(ii) The proposed use of credits is consistent with the terms and conditions of the
approved in-lieu fee program instrument; and
(iii) The compensatory mitigation agreement occurs in advance of the authorized impacts.
(b) Mitigation bank. Credits from a wetland mitigation bank that is certified under state rules may
be used at the discretion of the city and when all of the following are met:
(i) The city determines that it would provide environmentally appropriate compensation
for the proposed impacts;
(ii) The proposed use of credits and replacement ratios are consistent with the terms and
conditions of the certified bank instrument; and
(iii) The compensatory mitigation agreement occurs in advance of the authorized impacts.
(c) Advance mitigation. Mitigation for projects with pre-identified impacts to wetlands may be
constructed in advance of the impacts at the discretion of the city and if the mitigation is
implemented according to federal rules, state policy on advance mitigation, and state water quality
regulations.
(5) Wetland mitigation ratios. The following are ratios for providing creation, re-establishment,
rehabilitation, or enhancement of impacted wetlands. Ratios for rehabilitation and enhancement may be
reduced when combined with 1:1 replacement through creation or re-establishment pursuant to Table 1a,
Wetland Mitigation in Washington State – Part 1: Agency Policies and Guidance –Version 1 (Ecology
Publication No. 06-06-011a, or as revised). Creation, re-establishment, rehabilitation, and enhancement
definitions and intent shall be pursuant to Ecology Publication No. 06-06-011a, or as revised.
Category and Type of Wetland
Creation or
Re-establishment Rehabilitation Enhancement
Category I: High conservation value and bogs Not considered
possible
Case-by-case Case-by-case
Category I: Mature and old growth forests
greater than one acre
6:1 12:1 24:1
Category I: Based on functions 4:1 8:1 16:1
Category II 3:1 6:1 12:1
Category III 2:1 4:1 8:1
Category IV 1.5:1 3:1 6:1
Mitigation requirements may also be determined using the credit/debit tool described in Calculating Credits
and Debits for Compensatory Mitigation in Wetlands of Western Washington: Final Report (Ecology
Publication No. 10-06-011, or as revised) if approved by the director.
(6) Compensatory mitigation plan. As part of any request under this section, the applicant shall submit a
mitigation plan prepared by a qualified professional that includes the following minimum standards:
(a) Contents of wetland delineation report identified in FWRC 19.145.410(2).
(b) Compensatory mitigation written report and plan sheets. Full guidance on the following report
requirements can be found in Wetland Mitigation in Washington State – Part 2: Developing
Mitigation Plans (Version 1) (Ecology Publication No. 06-06-011b, or as revised):
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(i) Description of how the project design has been modified to avoid, minimize, or reduce
adverse impacts to wetlands;
(ii) Description of the existing wetland and buffer areas proposed to be altered. Include
acreage, water regime, vegetation, soils, landscape position, surrounding land uses, and
functions. Describe impacts in terms of acreage by Cowardin classification,
hydrogeomorphic classification, and wetland rating;
(iii) Description of the compensatory mitigation site, including location and rationale for
selection. Include an assessment of existing condition: acreage of wetlands and uplands,
water regime, sources of water, vegetation, soils, landscape position, surrounding land
uses, and functions;
(iv) Description of the proposed actions for compensation of wetland and upland areas
affected by the project. Include overall goals of the proposed mitigation, including a
description of the targeted functions, hydrogeomorphic classification, and categories of
wetlands;
(v) Description of the proposed mitigation construction activities and timing of activities;
(vi) Discussion of ongoing management practices that will protect wetlands after the
subject property has been developed, including proposed monitoring and maintenance
programs; and
(vii) Bond estimate for the entire compensatory mitigation project, including the
following elements: site preparation, plant materials, construction materials, installation
oversight, maintenance twice per year for up to five years, annual monitoring field work
and reporting, and contingency action for a maximum of the total required number of
years for monitoring.
(c) Scaled plan sheets for the compensatory mitigation that contains the following contents:
(i) Surveyed edges of the existing wetland and buffer, proposed areas of wetland impacts,
location of proposed wetland compensation actions.
(ii) Existing and proposed topography measured at two-foot intervals in the proposed
compensation area. Existing and proposed cross sections of the proposed compensation
area and impact area measured in one-foot intervals.
(iii) Surface and subsurface hydrologic conditions, including an analysis of existing and
proposed hydrologic regimes for enhanced, created, or restored compensatory mitigation
areas. Illustrations of how data for existing hydrologic conditions were used to determine
the estimates of future hydrologic conditions.
(iv) Conditions expected from the proposed actions on site, including hydrogeomorphic
types, vegetation community types by dominant species (wetland and upland), and future
water regimes.
(v) Required wetland buffers for existing wetlands and proposed compensation areas.
(vi) Plant schedule for compensation area, including all species by proposed community
type and water regime, size and type of plant material to be installed, spacing of plants,
typical clustering patterns, total number of each species by community type, and timing
of installation.
(vii) Performance standards that provide measurable benchmarks reflective of years post-
installation for upland and wetland communities, monitoring schedule, and maintenance
schedule.
(d) Alternative mitigation plans (in-lieu fee, mitigation banks, and advanced mitigation) shall
provide items (6)(a), (b)(i) and (ii) from this section, responses to subsection (4)(a), (b), or (c) of
this section, and any other information deemed necessary by the city to adequately consider the
alternative mitigation proposal.
(7) Monitoring. Mitigation monitoring shall be required for a minimum of five years to establish that
performance standards have been met. The mitigation plan shall include monitoring elements that ensure
certainty of success for the proposal’s natural resource values and functions. The applicant remains
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responsible for restoration of the natural resource values and functions if the mitigation goals are not
obtained with the five-year monitoring period. Additional monitoring and corrective actions may be
required by the director in order to meet goals within the approved mitigation plan.
(Ord. No. 15-797, §22, 6-16-15.)
19.145.440 Development within wetland buffers.
(1) Generally. Except as allowed in this section, no development or improvement may be located within a
wetland buffer.
(2) Trails. The director may provide written approval for passive pedestrian recreation facilities designed in
accordance with an approved critical area report and the following standards:
(a) Trails are composed of pervious surfaces no more than five feet in width. Raised boardwalks
and wildlife viewing structures composed of non-treated pilings may also be considered;
(b) Trails are generally located parallel to the perimeter of the wetland and within the outer 25
percent of the buffer; and
(c) Trails shall avoid the removal of mature trees.
(3) Stormwater management facilities. The director may provide written approval for stormwater
management facilities limited to stormwater dispersion outfalls and bioswales within the outer 25 percent
of the buffer of category III and IV wetlands if the location of such facilities will not degrade the functions
or values of the wetland.
(4) Permanently altered buffer. 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.
(5) Buffer averaging. The city will review and decide upon buffer averaging using process III in Chapter
19.65 FWRC, based on the following criteria that shall be added to the critical areas report:
(a) The total area of the buffer after averaging is equal to the area required without averaging;
(b) The buffer is increased adjacent to the higher functioning area of habitat or more sensitive
portion of the wetland and decreased adjacent to the lower functioning or less sensitive portion;
(c) The buffer at its narrowest point is not reduced to less than 75 percent of the required width;
and
(d) Unless authorized in writing by a consenting neighboring property owner, the averaging will
remain on the subject property.
(6) Buffer reduction with enhancement. Buffers may be reduced by up to 25 percent on a case-by-case basis
if the project includes a buffer enhancement plan that clearly substantiates that an enhanced buffer will
improve and provide additional protection of wetland functions and values. Buffer reductions may not be
used in combination with buffer averaging. The city will review and decide upon buffer reductions using
process III in Chapter 19.65 FWRC, based on the following criteria:
(a) It will not adversely affect water quality;
(b) It will not adversely affect the existing quality of the wetland or buffer wildlife habitat;
(c) It will not adversely affect drainage or stormwater retention capabilities;
(d) It will not lead to unstable earth conditions nor create erosion hazards;
(e) It will not be materially detrimental to any other property or the city as a whole; and
(f) All exposed areas are stabilized with native vegetation, as appropriate.
A buffer enhancement plan, prepared by a qualified professional, shall be incorporated into the critical area
report. The plan shall assess the habitat, water quality, stormwater retention, groundwater recharge, and
erosion protection functions of the existing buffer; assess the effects of the proposed modification on those
functions; and address the six approval criteria of this section.
Lee Wetland Delineation @ Federal Way
By John Comis Associates (JCA)
Date: 04/01/21
Page 19 of 34
(7) Buffer increases. The director shall require increased buffer widths, on a case-by-case basis, when a
larger buffer is necessary to protect functions, values or hazards based on site-specific conditions. This
determination shall be supported by appropriate documentation showing that additional buffer width is
reasonably related to protection of the functions and values of the wetland, and/or protection of public
health, safety and welfare. Such determination shall be attached as permit conditions. The determination
must include but not be limited to the following criteria:
(a) The wetland contains habitat for species listed as threatened, endangered, candidate, sensitive,
monitored, or documented priority species or habitats by state or federal agencies, and additional
buffer is necessary to maintain viable functional habitat;
(b) The adjacent land is susceptible to severe erosion, and erosion control measures will not
effectively prevent adverse wetland impacts; or
(c) The adjacent land has minimal vegetative cover or slopes greater than 30 percent.
(Ord. No. 15-797, §22, 6-16-15.)
Lee Wetland Delineation @ Federal Way
By John Comis Associates (JCA)
Date: 04/01/21
Page 20 of 34
APPENDIX 2
FIELD DATA FORMS,
FIELD NOTE SKETCH MAP (FNSM)
AND GPS DATA MAP (2020)
Completed by John Comis Associates (JCA)
Date: 8/20/2020
Source: US Army Corps of Engineers Regional Supplement to the Corps of Engineers Wetland
Delineation Manual: Western Mountains, Valleys, and Coast Region (USACE 2010).
INTRODUCTION:
For test plot locations, see Figure 5 in the report and the Field Note Sketch Maps (FNSMs) and Global
Positioning System (GPS) Map in this appendix. The sample test plot data are recorded to verify the
“wetland” and “non-wetland” conditions identified by JCA for regulatory purposes within and around
Wetland “A” using the updated 2010 US Army Corps of Engineers Regional Supplement to the Corps of
Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (USACE 2010). 11
This information is included to support a determination made by JCA in accordance with current City of
Federal Way Municipal Code (FWMC) requirements.
11 Wetlands are delineated using the 2010 US Army Corps of Engineers Regional Supplement to the Corps of Engineers Wetland
Delineation Manual: Western Mountains, Valleys, and Coast Region (USACE 2010). This wetland manual is required to be used by
all state agencies in the application of any state laws and regulations as well as any city or county in the implementation of any
regulations under the Growth Management Act.
http://www.usace.army.mil/Portals/2/docs/civilworks/regulatory/reg_supp/west_mt_finalsupp.pdf
Lee Wetland Delineation @ Federal Way
By John Comis Associates (JCA)
Date: 04/01/21
Page 21 of 34
APPENDIX 3
WETLAND RATING FORM
Completed by John Comis Associates (JCA)
Date: 8/20/2020
Source: Washington State Department of Ecology, “Washington State Wetlands Rating System, Western
Washington, 2014 Update”, WDOE Pub #04-06-029
INTRODUCTION:
This categorization (or rating) of the wetland area associated with the project site is done for regulatory
purposes based on the 4-tiered system that is required and specified by the City of Federal Way Municipal
Code (FWMC). This rating is applicable to buffer standards and setback requirements. The current
WDOE Wetland Rating Form is completed by JCA to support the rating, which may be approved by the
City in accordance with Code requirements.
This appendix includes a copy of maps used by JCA for this analysis, which are noted and highlighted to
show various features. These maps are:
W1, 1 Km Radius around Wetland Unit “A”
W2, 150’ & 330’ Radius around Wetland Unit “A”
W3, (Figures 3&4) Hydroperiods & Contributing Basin Map for Wetland Unit “A”
W4, WDOE 303(d) List, Water Quality Map
W5, USDA-NRCS Soils Survey Map
W6, USF&W National Wetland Inventory (NWI) Map
Certain data requirements are called out in various parts of the rating form and described in detail in the
2014 WDOE rating manual. The list of figures on page 2 of the rating form indicate the maps that are
required and which are used for that information. See the List of Figures on Page 2 of the rating form for
details.
Wetland name or number ______
Wetland Rating System for Western WA: 2014 Update 1
Rating Form – Effective January 1, 2015
Score for each
function based
on three
ratings
(order of ratings
is not
important)
9 = H,H,H
8 = H,H,M
7 = H,H,L
7 = H,M,M
6 = H,M,L
6 = M,M,M
5 = H,L,L
5 = M,M,L
4 = M,L,L
3 = L,L,L
RATING SUMMARY – Western Washington
Name of wetland (or ID #): _________________________________ Date of site visit: _____
Rated by____________________________ Trained by Ecology?__ Yes ___No Date of training______
HGM Class used for rating_________________ Wetland has multiple HGM classes?___Y ____N
NOTE: Form is not complete without the figures requested (figures can be combined).
Source of base aerial photo/map ______________________________________
OVERALL WETLAND CATEGORY ____ (based on functions___ or special characteristics___)
1. Category of wetland based on FUNCTIONS
_______Category I – Total score = 23 - 27
_______Category II – Total score = 20 - 22
_______Category III – Total score = 16 - 19
_______Category IV – Total score = 9 - 15
FUNCTION
Improving
Water Quality
Hydrologic
Habitat
Circle the appropriate ratings
Site Potential H M L H M L H M L
Landscape Potential H M L H M L H M L
Value H M L H M L H M L TOTAL
Score Based on
Ratings
2. Category based on SPECIAL CHARACTERISTICS of wetland
CHARACTERISTIC CATEGORY
Estuarine I II
Wetland of High Conservation Value I
Bog I
Mature Forest I
Old Growth Forest I
Coastal Lagoon I II
Interdunal I II III IV
None of the above
Wetland name or number ______
Wetland Rating System for Western WA: 2014 Update 2
Rating Form – Effective January 1, 2015
Maps and figures required to answer questions correctly for
Western Washington
Depressional Wetlands
Map of: To answer questions: Figure #
Cowardin plant classes D 1.3, H 1.1, H 1.4
Hydroperiods D 1.4, H 1.2
Location of outlet (can be added to map of hydroperiods) D 1.1, D 4.1
Boundary of area within 150 ft of the wetland (can be added to another figure) D 2.2, D 5.2
Map of the contributing basin D 4.3, D 5.3
1 km Polygon: Area that extends 1 km from entire wetland edge - including
polygons for accessible habitat and undisturbed habitat
H 2.1, H 2.2, H 2.3
Screen capture of map of 303(d) listed waters in basin (from Ecology website) D 3.1, D 3.2
Screen capture of list of TMDLs for WRIA in which unit is found (from web) D 3.3
Riverine Wetlands
Map of: To answer questions: Figure #
Cowardin plant classes H 1.1, H 1.4
Hydroperiods H 1.2
Ponded depressions R 1.1
Boundary of area within 150 ft of the wetland (can be added to another figure) R 2.4
Plant cover of trees, shrubs, and herbaceous plants R 1.2, R 4.2
Width of unit vs. width of stream (can be added to another figure) R 4.1
Map of the contributing basin R 2.2, R 2.3, R 5.2
1 km Polygon: Area that extends 1 km from entire wetland edge - including
polygons for accessible habitat and undisturbed habitat
H 2.1, H 2.2, H 2.3
Screen capture of map of 303(d) listed waters in basin (from Ecology website) R 3.1
Screen capture of list of TMDLs for WRIA in which unit is found (from web) R 3.2, R 3.3
Lake Fringe Wetlands
Map of: To answer questions: Figure #
Cowardin plant classes L 1.1, L 4.1, H 1.1, H 1.4
Plant cover of trees, shrubs, and herbaceous plants L 1.2
Boundary of area within 150 ft of the wetland (can be added to another figure) L 2.2
1 km Polygon: Area that extends 1 km from entire wetland edge - including
polygons for accessible habitat and undisturbed habitat
H 2.1, H 2.2, H 2.3
Screen capture of map of 303(d) listed waters in basin (from Ecology website) L 3.1, L 3.2
Screen capture of list of TMDLs for WRIA in which unit is found (from web) L 3.3
Slope Wetlands
Map of: To answer questions: Figure #
Cowardin plant classes H 1.1, H 1.4
Hydroperiods H 1.2
Plant cover of dense trees, shrubs, and herbaceous plants S 1.3
Plant cover of dense, rigid trees, shrubs, and herbaceous plants
(can be added to figure above)
S 4.1
Boundary of 150 ft buffer (can be added to another figure) S 2.1, S 5.1
1 km Polygon: Area that extends 1 km from entire wetland edge - including
polygons for accessible habitat and undisturbed habitat
H 2.1, H 2.2, H 2.3
Screen capture of map of 303(d) listed waters in basin (from Ecology website) S 3.1, S 3.2
Screen capture of list of TMDLs for WRIA in which unit is found (from web) S 3.3
(No Outlet)
Wetland name or number ______
Wetland Rating System for Western WA: 2014 Update 3
Rating Form – Effective January 1, 2015
HGM Classification of Wetlands in Western Washington
1. Are the water levels in the entire unit usually controlled by tides except during floods?
NO – go to 2 YES – the wetland class is Tidal Fringe – go to 1.1
1.1 Is the salinity of the water during periods of annual low flow below 0.5 ppt (parts per thousand)?
NO – Saltwater Tidal Fringe (Estuarine) YES – Freshwater Tidal Fringe
If your wetland can be classified as a Freshwater Tidal Fringe use the forms for Riverine wetlands. If it
is Saltwater Tidal Fringe it is an Estuarine wetland and is not scored. This method cannot be used to
score functions for estuarine wetlands.
2. The entire wetland unit is flat and precipitation is the only source (>90%) of water to it. Groundwater
and surface water runoff are NOT sources of water to the unit.
NO – go to 3 YES – The wetland class is Flats
If your wetland can be classified as a Flats wetland, use the form for Depressional wetlands.
3. Does the entire wetland unit meet all of the following criteria?
___The vegetated part of the wetland is on the shores of a body of permanent open water (without any
plants on the surface at any time of the year) at least 20 ac (8 ha) in size;
___At least 30% of the open water area is deeper than 6.6 ft (2 m).
NO – go to 4 YES – The wetland class is Lake Fringe (Lacustrine Fringe)
4. Does the entire wetland unit meet all of the following criteria?
____The wetland is on a slope (slope can be very gradual),
____The water flows through the wetland in one direction (unidirectional) and usually comes from
seeps. It may flow subsurface, as sheetflow, or in a swale without distinct banks,
____The water leaves the wetland without being impounded.
NO – go to 5 YES – The wetland class is Slope
NOTE: Surface water does not pond in these type of wetlands except occasionally in very small and
shallow depressions or behind hummocks (depressions are usually <3 ft diameter and less than 1 ft
deep).
5. Does the entire wetland unit meet all of the following criteria?
____The unit is in a valley, or stream channel, where it gets inundated by overbank flooding from that
stream or river,
____The overbank flooding occurs at least once every 2 years.
For questions 1-7, the criteria described must apply to the entire unit being rated.
If the hydrologic criteria listed in each question do not apply to the entire unit being rated, you
probably have a unit with multiple HGM classes. In this case, identify which hydrologic criteria in
questions 1-7 apply, and go to Question 8.
Wetland name or number ______
Wetland Rating System for Western WA: 2014 Update 4
Rating Form – Effective January 1, 2015
NO – go to 6 YES – The wetland class is Riverine
NOTE: The Riverine unit can contain depressions that are filled with water when the river is not
flooding
6. Is the entire wetland unit in a topographic depression in which water ponds, or is saturated to the
surface, at some time during the year? This means that any outlet, if present, is higher than the interior
of the wetland.
NO – go to 7 YES – The wetland class is Depressional
7. Is the entire wetland unit located in a very flat area with no obvious depression and no overbank
flooding? The unit does not pond surface water more than a few inches. The unit seems to be
maintained by high groundwater in the area. The wetland may be ditched, but has no obvious natural
outlet.
NO – go to 8 YES – The wetland class is Depressional
8. Your wetland unit seems to be difficult to classify and probably contains several different HGM
classes. For example, seeps at the base of a slope may grade into a riverine floodplain, or a small
stream within a Depressional wetland has a zone of flooding along its sides. GO BACK AND IDENTIFY
WHICH OF THE HYDROLOGIC REGIMES DESCRIBED IN QUESTIONS 1-7 APPLY TO DIFFERENT
AREAS IN THE UNIT (make a rough sketch to help you decide). Use the following table to identify the
appropriate class to use for the rating system if you have several HGM classes present within the
wetland unit being scored.
NOTE: Use this table only if the class that is recommended in the second column represents 10% or
more of the total area of the wetland unit being rated. If the area of the HGM class listed in column 2
is less than 10% of the unit; classify the wetland using the class that represents more than 90% of the
total area.
HGM classes within the wetland unit
being rated
HGM class to
use in rating
Slope + Riverine Riverine
Slope + Depressional Depressional
Slope + Lake Fringe Lake Fringe
Depressional + Riverine along stream
within boundary of depression
Depressional
Depressional + Lake Fringe Depressional
Riverine + Lake Fringe Riverine
Salt Water Tidal Fringe and any other
class of freshwater wetland
Treat as
ESTUARINE
If you are still unable to determine which of the above criteria apply to your wetland, or if you have
more than 2 HGM classes within a wetland boundary, classify the wetland as Depressional for the
rating.
Wetland name or number ______
Wetland Rating System for Western WA: 2014 Update 5
Rating Form – Effective January 1, 2015
DEPRESSIONAL AND FLATS WETLANDS
Water Quality Functions - Indicators that the site functions to improve water quality
D 1.0. Does the site have the potential to improve water quality?
D 1.1. Characteristics of surface water outflows from the wetland:
Wetland is a depression or flat depression (QUESTION 7 on key) with no surface water leaving it (no outlet).
points = 3
Wetland has an intermittently flowing stream or ditch, OR highly constricted permanently flowing outlet.
points = 2
Wetland has an unconstricted, or slightly constricted, surface outlet that is permanently flowing points = 1
Wetland is a flat depression (QUESTION 7 on key), whose outlet is a permanently flowing ditch. points = 1
D 1.2. The soil 2 in below the surface (or duff layer) is true clay or true organic (use NRCS definitions).Yes = 4 No = 0
D 1.3. Characteristics and distribution of persistent plants (Emergent, Scrub-shrub, and/or Forested Cowardin classes):
Wetland has persistent, ungrazed, plants > 95% of area points = 5
Wetland has persistent, ungrazed, plants > ½ of area points = 3
Wetland has persistent, ungrazed plants > 1/10 of area points = 1
Wetland has persistent, ungrazed plants <1/10 of area points = 0
D 1.4. Characteristics of seasonal ponding or inundation :
This is the area that is ponded for at least 2 months. See description in manual.
Area seasonally ponded is > ½ total area of wetland points = 4
Area seasonally ponded is > ¼ total area of wetland points = 2
Area seasonally ponded is < ¼ total area of wetland points = 0
Total for D 1 Add the points in the boxes above
Rating of Site Potential If score is: 12-16 = H 6-11 = M 0-5 = L Record the rating on the first page
D 2.0. Does the landscape have the potential to support the water quality function of the site?
D 2.1. Does the wetland unit receive stormwater discharges? Yes = 1 No = 0
D 2.2. Is > 10% of the area within 150 ft of the wetland in land uses that generate pollutants? Yes = 1 No = 0
D 2.3. Are there septic systems within 250 ft of the wetland? Yes = 1 No = 0
D 2.4. Are there other sources of pollutants coming into the wetland that are not listed in questions D 2.1 -D 2.3?
Source_______________ Yes = 1 No = 0
Total for D 2 Add the points in the boxes above
Rating of Landscape Potential If score is: 3 or 4 = H 1 or 2 = M 0 = L Record the rating on the first page
D 3.0. Is the water quality improvement provided by the site valuable to society?
D 3.1. Does the wetland discharge directly (i.e., within 1 mi) to a stream, river, lake, or marine water that is on the
303(d) list? Yes = 1 No = 0
D 3.2. Is the wetland in a basin or sub-basin where an aquatic resource is on the 303(d) list? Yes = 1 No = 0
D 3.3. Has the site been identified in a watershed or local plan as important for maintaining water quality (answer YES
if there is a TMDL for the basin in which the unit is found)? Yes = 2 No = 0
Total for D 3 Add the points in the boxes above
Rating of Value If score is: 2-4 = H 1 = M 0 = L Record the rating on the first page
Wetland name or number ______
Wetland Rating System for Western WA: 2014 Update 6
Rating Form – Effective January 1, 2015
DEPRESSIONAL AND FLATS WETLANDS
Hydrologic Functions - Indicators that the site functions to reduce flooding and stream degradation
D 4.0. Does the site have the potential to reduce flooding and erosion?
D 4.1. Characteristics of surface water outflows from the wetland:
Wetland is a depression or flat depression with no surface water leaving it (no outlet) points = 4
Wetland has an intermittently flowing stream or ditch, OR highly constricted permanently flowing outletpoints = 2
Wetland is a flat depression (QUESTION 7 on key), whose outlet is a permanently flowing ditch points = 1
Wetland has an unconstricted, or slightly constricted, surface outlet that is permanently flowing points = 0
D 4.2. Depth of storage during wet periods: Estimate the height of ponding above the bottom of the outlet. For wetlands
with no outlet, measure from the surface of permanent water or if dry, the deepest part.
Marks of ponding are 3 ft or more above the surface or bottom of outlet points = 7
Marks of ponding between 2 ft to < 3 ft from surface or bottom of outlet points = 5
Marks are at least 0.5 ft to < 2 ft from surface or bottom of outlet points = 3
The wetland is a “headwater” wetland points = 3
Wetland is flat but has small depressions on the surface that trap water points = 1
Marks of ponding less than 0.5 ft (6 in) points = 0
D 4.3. Contribution of the wetland to storage in the watershed: Estimate the ratio of the area of upstream basin
contributing surface water to the wetland to the area of the wetland unit itself.
The area of the basin is less than 10 times the area of the unit points = 5
The area of the basin is 10 to 100 times the area of the unit points = 3
The area of the basin is more than 100 times the area of the unit points = 0
Entire wetland is in the Flats class points = 5
Total for D 4 Add the points in the boxes above
Rating of Site Potential If score is: 12-16 = H 6-11 = M 0-5 = L Record the rating on the first page
D 5.0. Does the landscape have the potential to support hydrologic functions of the site?
D 5.1. Does the wetland receive stormwater discharges? Yes = 1 No = 0
D 5.2. Is >10% of the area within 150 ft of the wetland in land uses that generate excess runoff? Yes = 1 No = 0
D 5.3. Is more than 25% of the contributing basin of the wetland covered with intensive human land uses (residential at
>1 residence/ac, urban, commercial, agriculture, etc.)? Yes = 1 No = 0
Total for D 5 Add the points in the boxes above
Rating of Landscape Potential If score is: 3 = H 1 or 2 = M 0 = L Record the rating on the first page
D 6.0. Are the hydrologic functions provided by the site valuable to society?
D 6.1. The unit is in a landscape that has flooding problems. Choose the description that best matches conditions around
the wetland unit being rated. Do not add points. Choose the highest score if more than one condition is met .
The wetland captures surface water that would otherwise flow down -gradient into areas where flooding has
damaged human or natural resources (e.g., houses or salmon redds):
Flooding occurs in a sub-basin that is immediately down-gradient of unit. points = 2
Surface flooding problems are in a sub-basin farther down-gradient. points = 1
Flooding from groundwater is an issue in the sub-basin. points = 1
The existing or potential outflow from the wetland is so constrained by human or natural conditions that the
water stored by the wetland cannot reach areas that flood. Explain why _____________ points = 0
There are no problems with flooding downstream of the wetland. points = 0
D 6.2. Has the site been identified as important for flood storage or flood conveyance in a regional flood control plan?
Yes = 2 No = 0
Total for D 6 Add the points in the boxes above
Rating of Value If score is: 2-4 = H 1 = M 0 = L Record the rating on the first page
Wetland name or number ______
Wetland Rating System for Western WA: 2014 Update 13
Rating Form – Effective January 1, 2015
These questions apply to wetlands of all HGM classes.
HABITAT FUNCTIONS - Indicators that site functions to provide important habitat
H 1.0. Does the site have the potential to provide habitat?
H 1.1. Structure of plant community: Indicators are Cowardin classes and strata within the Forested class. Check the
Cowardin plant classes in the wetland. Up to 10 patches may be combined for each class to meet the threshold
of ¼ ac or more than 10% of the unit if it is smaller than 2.5 ac. Add the number of structures checked.
____Aquatic bed 4 structures or more: points = 4
____Emergent 3 structures: points = 2
____Scrub-shrub (areas where shrubs have > 30% cover) 2 structures: points = 1
____Forested (areas where trees have > 30% cover) 1 structure: points = 0
If the unit has a Forested class, check if:
____The Forested class has 3 out of 5 strata (canopy, sub-canopy, shrubs, herbaceous, moss/ground-cover)
that each cover 20% within the Forested polygon
H 1.2. Hydroperiods
Check the types of water regimes (hydroperiods) present within the wetland. The water regime has to cover
more than 10% of the wetland or ¼ ac to count (see text for descriptions of hydroperiods).
____Permanently flooded or inundated 4 or more types present: points = 3
____Seasonally flooded or inundated 3 types present: points = 2
____Occasionally flooded or inundated 2 types present: points = 1
____Saturated only 1 type present: points = 0
____Permanently flowing stream or river in, or adjacent to, the wetland
____Seasonally flowing stream in, or adjacent to, the wetland
____Lake Fringe wetland 2 points
____Freshwater tidal wetland 2 points
H 1.3. Richness of plant species
Count the number of plant species in the wetland that cover at least 10 ft 2.
Different patches of the same species can be combined to meet the size threshold and you do not have to name
the species. Do not include Eurasian milfoil, reed canarygrass, purple loosestrife, Canadian thistle
If you counted: > 19 species points = 2
5 - 19 species points = 1
< 5 species points = 0
H 1.4. Interspersion of habitats
Decide from the diagrams below whether interspersion among Cowardin plants classes (described in H 1.1), or
the classes and unvegetated areas (can include open water or mudflats) is high, moderate, low, or none. If you
have four or more plant classes or three classes and open water, the rating is always high.
None = 0 points Low = 1 point Moderate = 2 points
All three diagrams
in this row
are HIGH = 3points
Wetland name or number ______
Wetland Rating System for Western WA: 2014 Update 14
Rating Form – Effective January 1, 2015
H 1.5. Special habitat features:
Check the habitat features that are present in the wetland. The number of checks is the number of points.
____Large, downed, woody debris within the wetland (> 4 in diameter and 6 ft long).
____Standing snags (dbh > 4 in) within the wetland
____Undercut banks are present for at least 6.6 ft (2 m) and/or overhanging plants extends at least 3.3 ft (1 m)
over a stream (or ditch) in, or contiguous with the wetland, for at least 33 ft (10 m)
____Stable steep banks of fine material that might be used by beaver or muskrat for denning (> 30 degree
slope) OR signs of recent beaver activity are present (cut shrubs or trees that have not yet weathered
where wood is exposed)
____At least ¼ ac of thin-stemmed persistent plants or woody branches are present in areas that are
permanently or seasonally inundated (structures for egg-laying by amphibians)
____Invasive plants cover less than 25% of the wetland area in every stratum of plants (see H 1.1 for list of
strata)
Total for H 1 Add the points in the boxes above
Rating of Site Potential If score is: 15-18 = H 7-14 = M 0-6 = L Record the rating on the first page
H 2.0. Does the landscape have the potential to support the habitat functions of the site?
H 2.1. Accessible habitat (include only habitat that directly abuts wetland unit).
Calculate: % undisturbed habitat + [(% moderate and low intensity land uses)/2] = _______%
If total accessible habitat is:
> 1/3 (33.3%) of 1 km Polygon points = 3
20-33% of 1 km Polygon points = 2
10-19% of 1 km Polygon points = 1
< 10% of 1 km Polygon points = 0
H 2.2. Undisturbed habitat in 1 km Polygon around the wetland.
Calculate: % undisturbed habitat + [(% moderate and low intensity land uses)/2] = _______%
Undisturbed habitat > 50% of Polygon points = 3
Undisturbed habitat 10-50% and in 1-3 patches points = 2
Undisturbed habitat 10-50% and > 3 patches points = 1
Undisturbed habitat < 10% of 1 km Polygon points = 0
H 2.3. Land use intensity in 1 km Polygon: If
> 50% of 1 km Polygon is high intensity land use points = (- 2)
≤ 50% of 1 km Polygon is high intensity points = 0
Total for H 2 Add the points in the boxes above
Rating of Landscape Potential If score is: 4-6 = H 1-3 = M < 1 = L Record the rating on the first page
H 3.0. Is the habitat provided by the site valuable to society?
H 3.1. Does the site provide habitat for species valued in laws, regulations, or policies? Choose only the highest score
that applies to the wetland being rated.
Site meets ANY of the following criteria: points = 2
It has 3 or more priority habitats within 100 m (see next page)
It provides habitat for Threatened or Endangered species (any plant or animal on the state or federal lists)
It is mapped as a location for an individual WDFW priority species
It is a Wetland of High Conservation Value as determined by the Department of Natural Resources
It has been categorized as an important habitat site in a local or regional comprehensive plan, in a
Shoreline Master Plan, or in a watershed plan Site has 1 or 2 priority habitats (listed on next page) within 100 m points = 1
Site does not meet any of the criteria above points = 0
Rating of Value If score is: 2 = H 1 = M 0 = L Record the rating on the first page
Wetland name or number ______
Wetland Rating System for Western WA: 2014 Update 15
Rating Form – Effective January 1, 2015
WDFW Priority Habitats
Priority habitats listed by WDFW (see complete descriptions of WDFW priority habitats, and the counties in which they can
be found, in: Washington Department of Fish and Wildlife. 2008. Priority Habitat and Species List. Olympia, Washington.
177 pp. http://wdfw.wa.gov/publications/00165/wdfw00165.pdf or access the list from here:
http://wdfw.wa.gov/conservation/phs/list/)
Count how many of the following priority habitats are within 330 ft (100 m) of the wetland unit: NOTE: This question is
independent of the land use between the wetland unit and the priority habitat.
Aspen Stands: Pure or mixed stands of aspen greater than 1 ac (0.4 ha).
Biodiversity Areas and Corridors: Areas of habitat that are relatively important to various species of native fish and
wildlife (full descriptions in WDFW PHS report).
Herbaceous Balds: Variable size patches of grass and forbs on shallow soils over bedrock.
Old-growth/Mature forests: Old-growth west of Cascade crest – Stands of at least 2 tree species, forming a multi-
layered canopy with occasional small openings; with at least 8 trees/ac (20 trees/ha ) > 32 in (81 cm) dbh or > 200
years of age. Mature forests – Stands with average diameters exceeding 21 in (53 cm) dbh; crown cover may be less
than 100%; decay, decadence, numbers of snags, and quantity of large downed material is generally less than that
found in old-growth; 80-200 years old west of the Cascade crest.
Oregon White Oak: Woodland stands of pure oak or oak/conifer associations where canopy coverage of the oak
component is important (full descriptions in WDFW PHS report p. 158 – see web link above).
Riparian: The area adjacent to aquatic systems with flowing water that contains elements of both aquatic and
terrestrial ecosystems which mutually influence each other.
Westside Prairies: Herbaceous, non-forested plant communities that can either take the form of a dry prairie or a wet
prairie (full descriptions in WDFW PHS report p. 161 – see web link above).
Instream: The combination of physical, biological, and chemical processes and conditions that interact to provide
functional life history requirements for instream fish and wildlife resources.
Nearshore: Relatively undisturbed nearshore habitats. These include Coastal Nearshore, Open Coast Nearshore, and
Puget Sound Nearshore. (full descriptions of habitats and the definition of relatively undisturbed are in WDFW report –
see web link on previous page).
Caves: A naturally occurring cavity, recess, void, or system of interconnected passages under the earth in soils, rock,
ice, or other geological formations and is large enough to contain a human.
Cliffs: Greater than 25 ft (7.6 m) high and occurring below 5000 ft elevation.
Talus: Homogenous areas of rock rubble ranging in average size 0.5 - 6.5 ft (0.15 - 2.0 m), composed of basalt, andesite,
and/or sedimentary rock, including riprap slides and mine tailings. May be associated with cliffs.
Snags and Logs: Trees are considered snags if they are dead or dying and exhibit sufficient decay characteristics to
enable cavity excavation/use by wildlife. Priority snags have a diameter at breast height of > 20 in (51 cm) in western
Washington and are > 6.5 ft (2 m) in height. Priority logs are > 12 in (30 cm) in diameter at the largest end, and > 20 ft
(6 m) long.
Note: All vegetated wetlands are by definition a priority habitat but are not included in this list because they are addressed
elsewhere.
King County Assessor's Office, King County GIS Center, King County, King county Assessor's Office,
King County GIS Center, EagleView Technologies, Inc.
King County
Date: 11/10/2020
The information included on this map has been compiled by King County staff from a variety of sources and is subject to change
without notice. King County makes no representations or warranties, express or implied, as to accuracy, completeness, timeliness,
or rights to the use of such information. This document is not intended for use as a survey product. King County shall not be liable
for any general, special, indirect, incidental, or consequential damages including, but not limited to, lost revenues or lost profits
resulting from the use or misuse of the information contained on this map. Any sale of this map or information on this map is
prohibited except by written permission of King County.±
King County, EagleView Technologies, Inc.
King County iMap
Date: 11/10/2020
Notes:±The information included on this map has been compiled by King County staff from a variety of sources and is subject to change without notice. King County
makes no representations or warranties, express or implied, as to accuracy, completeness, timeliness, or rights to the use of such information. This document is
not intended for use as a survey product. King County shall not be liable for any general, special, indirect, incidental, or consequential damages including,
but not limited to, lost revenues or lost profits resulting from the use or misuse of the information contained on this map. Any sale of this map or information on
this map is prohibited except by written permission of King County.
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APPENDIX 4
PHOTOGRAPHS OF EXISTING ONSITE
AND ADJACENT OFFSITE AREAS
By John Comis Associates (JCA)
Taken: 5/11/2018, 8/20/2020 & 10/8/20
INTRODUCTION:
Photographs in this appendix were taken at the Project site by JCA during a site visits on July 20 and
October 8, 2020. These photos document conditions within the project site and in adjacent offsite areas.
They show existing vegetation, topography, soils at test holes and drainage features in various parts of the
site. The location and direction that each photo was taken is described in the caption under each
photograph, together with what of note was observed by JCA at that time. The image (IMG) numbers after
each description match the digital photos on file at JCA. Additional photos that were taken by JCA at these
times may be obtained from JCA upon request if they are needed.
Please note the following:
1. Site conditions are generally “dry” during the field inspections as shown in these photos.
2. Pink flags indicate “Wetland Delineation” points marked by JCA (A1 thru A20) as shown on
Figure << and on FNSMs in Appendix 2.
3. Blue and Green flags together indicate sample Test Plots by JCA (TP1, TP2 & TP3) as shown on
Figure << and described on Field Data Forms in Appendix 2.
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Photo #1: Looking east at sample Test Plot #1 (TP1) in the central part of Wetland “A”. Note the dense scrub shrub
(SS) and forested (FO) vegetation that extends across the entire wetland area. Also note the blackened leaves in the
bottom of the wetland that indicate periods of standing water. However, the depth of temporary inundation appears to
be rather shallow (estimated 6” to 12” deep). (IMG-4180, 8/20//20)
Photo #2: Looking south from the central part of Wetland “A” toward the edge of the wetland at “A6”, the pink flag
tied on an overhanging tree branch. Note these larger trees are all just outside of the wetland edge, and smaller trees
and shrubs are established within the wetland aera. (IMG-4174, 8/20//20)
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Photo #3: Looking north from the southern boundary of the site from the sidewalk at the FO and SS Wetland “A”
during the site reconnaissance by JCA in 2018. Note the pink flag on the left was relocated by JCA in 2020 when the
wetland was delineated in detail. The fallen tree across the wetland remained there in 2020. (IMG-0006, 5/11//18)
Photo #4: Looking northeast from the sidewalk across the eastern end of Wetland “A” in 2018 that remained
overgrown with native scrub-shrub and forested vegetation in 2020. However, the interior of the project site had many
more homeless encampments and much more garbage and debris piles in 2020. (IMG-0003, 5/11//20)
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Photo #5: Looking north from the central part of Wetland “A” toward the northern edge at “A1.1”, the pink flag tied to
an overhanging tree branch. Note the garbage and debris left by homeless vagrants in this area, which should be
removed and disposed of offsite. (IMG-4172, 8/20//20)
Photo #6: Looking south from TP2 toward “A1.1 in the background behind the old chair, and “A1” on the right in this
photo. Note the test plot soil shown in the lower left of the photo is determined to be non-hydric (see Appendix 2). The
garbage and debris in this area is typical of the many encampments that were found scattered around the entire project
site area. (IMG-4170, 8/20//20)
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Photo #7: Looking northwest in the northwestern part of the project site at the outlet end of the 12” dia. concrete
culvert pipe that comes from the City street, 1st Ave. S. Note the outlet pipe was clear in June of 2019, but overgrown
with vegetation in 2020 (see next photo). (IMG-0007, 6/1/19)
Photo #8: Looking east from the sidewalk overlooking the outlet culvert pipe situated in the northwestern part of the
site that is overgrown in 2020. No stream or drainage course was found by JCA in 2020 downgradient from the outlet
pipe that drains toward a depression where TP3 (non-wetland) was dug and evaluated. (IMG-4186, 8/20//20)
Lee Wetland Delineation @ Federal Way
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Photo #9: Looking east from the north embankment below South 312th Street at the location where an outlet culvert
should be located if it existed under 312th. No drainage culvert was found on either side of 312th in this area after
extensive investigation by JCA along both of the lower sides of the embankment. (IMG-0033, 10/8/20)
Photo #10: Looking north at the southern side of the embankment below South 312th Street where no culvert was
found on either side of the road. The water that appears to accumulates in Wetland “A” does not drain directly to the
south under the roadway as indicated by the City of Federal Way “Drainage Area Map” (see Figure 4). Water must
pond up and be retained within Wetland “A”, then infiltrate and/or evapotranspirate away. (IMG-0034, 10/8/20)
Lee Wetland Delineation @ Federal Way
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APPENDIX 5
RESUMES
FOR WETLAND AND WILDLIFE
CONSULTANTS
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Resumes for Consultants: Wetland Delineations, Mitigation Plans & Landscape
Designs, Mitigation Monitoring & Wildlife Biology
JOHN G. COMIS
Professional Wetland Scientist (PWS, Certification No. 000810, dtd Nov 27, 1995)
Wetlands Specialist (Listed as Certified “Wetlands Specialist” by Pierce County, since 1992)
EDUCATION: Bachelor of Science, Environmental Bioengineering,
University of Washington, Seattle, 1973
EMPLOYMENT HISTORY:
Consoer, Townsend & Associates, junior engineer, 1974-77
Pierce County Public Works, civil engineer II, planning & drainage engineer, 1977-89
John Comis Associates, principal as a sole proprietorship, 1989-2005
JCA, Incorporated (Inc.), 2005 to 2010
JCA, Limited Liability Corp. (LLC), 2010 to present
QUALIFICATIONS: Mr. Comis has worked a total of 47 years in both public sector surface water
management (15 years) and private sector wetland consulting (32 years). Mr. Comis' education,
research, and experience combine the highly technical fields of water biology and water
engineering. John has applied his experience and knowledge to preparing wetland delineations
and mitigation plans for clients for all manner of large and small-scale projects.
Private projects have dealt with all aspects of wetland consulting including identification,
delineation, mitigation, restoration, and simply setback avoidance for new developments. Wetland
projects include over 800 sites and developments in Pierce, King, Kitsap, Lewis, Thurston and
Grays Harbor Counties, including work that was done within the Cities of Algona, Auburn,
Bellevue, Bothell, Bonney Lake, Buckley, Enumclaw, Edgewood, Federal Way, Fife, Fircrest,
Issaquah, Kent, Lakewood, Milton, Olympia, Ocean Shores, Pacific, Puyallup, Renton, Sumner,
Tacoma and University Place. John has also assisted clients with flood plain and drainage studies
including runoff modeling and backwater analysis.
Public sector experience involves many aspects of drainage and surface water management from
basin level planning to site specific analysis and design. John has experience with computer
models used for estimating runoff, routing stream flows, calculating flood plain elevations and
sizing retention/detention facilities. On many projects, John has worked closely with soil
scientists, fishery biologists, civil engineers, surveyors, and regulatory agency staffs at all levels of
government. He has frequently been involved with interdisciplinary project teams at both the
planning and implementation stages of project development.
In academic research, John directed two National Science Foundation projects for an
interdisciplinary research team on Kelsey and Coal Creeks, King County, Washington while he
was attending the University of Washington. He has conducted drainage and flood studies at all
levels of project development. This has provided opportunities to put theory into "on-the-ground"
applications for stream studies, FEMA floodplain analysis and mapping, and writing flood plain
management regulations together with other aspects of surface water management.
AFFILIATIONS: Member, Society of Wetland Scientists (SWS-PNW Chapter); Society for Ecological
Restoration (SER); Washington Native Plant Society (WNPS); National Audubon Society;
Association of State Wetland Managers (ASWM)
File: \RES-JGC1.doc (Jan. 2021)
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CATHERINE A. COMIS
Wildlife Biologist and Native Landscape Designer for Natural Systems Designs
EDUCATION: Bachelor of Arts, Near Eastern Studies,
University of Washington, Seattle, 1972 Bachelor of Science, Landscape Architecture (BSLA),
University of Washington, Seattle, 1978
EMPLOYMENT HISTORY:
US Army, Lieutenant, Military Intelligence Corps, 1972-1976
TRA, landscape designs, park plans, and comprehensive master plans, 1978-1982
Richard Haag & Associates, landscape designs, 1983
Edward Chaffee & Associates, residential & commercial landscape designs, 1983-1987
Natural Systems Designs, woman owned business for native landscape designs, wetland
restoration and mitigation plans, habitat assessments and small mammal (bat) studies,
1989 to present
QUALIFICATIONS: Kate has continued her studies in wildlife science with courses in Basic Bird
Biology Cornell University (10-week Program), 1995, and Master Birding Workshops for avian
identifications and general habitat assessment. Kate has continued to work and study both in the US and
abroad with wildlife biologists at Bat Conservation International (BCI) workshops and sponsored
research projects, 1998 thru 2009. The bat research projects include “Bats in the Mexican Coffee Agro-
ecosystem”, Chiapas, Mexico in 2007; “Founder’s Bat Conservation International Workshop Instructor”,
western Uganda in 2008; and “Vertical Canopy Utilization of Bat Carnivores and Frugivores”, Barro,
Panama in 2009. Bat management and research training include protocols for netting, handling, and
acoustics identification at the Bat Grid Workshops in Moses Coulee, WA, June 2010.
Kate Comis has served as both a designer and project manager for numerous residential and commercial
landscape design and comprehensive master plan projects including park projects. She has served as a
team member for landscape designs and recreational plans that included studies of wildlife habitats,
wetland and stream mitigation and restorations.
Her experience includes stream corridor restoration for park and recreation facility design; multi-use
equestrian, pedestrian and bike trails. Preparations of site plans include all aspects of site surveys, cost
estimating, construction drawings, specification writing, project inspections and management. She has
worked on wildlife studies and consulted with other project biologists doing habitat evaluations and
enhancements on Public Utility District (PUD) projects.
Various parks and recreation projects in eastern Washington State include the Chelan County "Entiat Park",
"Lincoln Rock Park" and "Daroga Park Master Plan" at the Rocky Reach Reservoir. She has worked on
the Chelan County PUD projects for "Mason Park" at Lake Chelan and "Douglas County River Park" at
Rock Island Reservoir. These parks were established as a minimum requirement for recreational area
development along the reservoirs after damming of the Columbia River.
She also worked for private clients on designs for recreational projects such as Camp Benbow @ Lake
Tanwax, Pierce County Jewish Camping Association; Camp Orkila @ Orcas Island, YMCA of Greater
Seattle; and Camp Sealth @ Vashon Island, Seattle-King County Campfire Council.
AFFILIATIONS: Society for Ecological Restoration; National Audubon Society; the Wildlife Society,
Bat Conservation International (BCI), American Society of Mammologists and Acta Chiroptera.
File: \RES-CAC1.doc (Jan. 2021)
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APPENDIX 6
REFERENCES
FOR WETLAND & WILDLIFE HABITAT
ANALYSIS
Lee Wetland Delineation @ Federal Way
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Date: 04/01/21
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PROJECT-SPECIFIC REFERENCES
1. City of Federal Way Municipal Code (FWMC) for Critical Areas Regulations, Chapter 19.145.410
thru 440, [See Appendix 1, Part E, for excerpts and details]
2. Cooke, Sarah Spear (Editor). 1997. A Field Guide to the Common Wetland Plants of Western
Washington & NW Oregon. Seattle Audubon Society & Washington Native Plant Society, Seattle,
Washington.
3. Cowardin, L.M., V. Carter, F.C. Golat and E.T. LaRoe. 1979. Classification of Wetlands and Deep-
Water Habitats of the United States. U.S. Department of Interior, Fish and Wildlife Service,
Washington, D.C., Publication FWS/OBS-79/31, 131 pages. (Also referred to in the Federal
Geographic Data Committee Standard, FGDC-STD-004, see reference below)
http://www.npwrc.usgs.gov/resource/wetlands/classwet/index.htm (Version 04DEC1998), or
http://www.fws.gov/wetlands/_documents/gNSDI/ClassificationWetlandsDeepwaterHabitatsUS.pdf
4. Guard, B. Jennifer. 1995. Wetland Plants of Oregon and Washington. Lone Pine Publishing, Redmond,
Washington.
5. Hitchcock, C.L., A. Cronquist. 1977. Flora of the Pacific Northwest. University of Washington Press,
Seattle, Washington.
6. Hruby, T. 2006. Washington State Wetland Rating System for Western Washington, Updated 2014.
Washington Department of Ecology (WDOE) Publication #04-06-029 [original published: Aug 2004;
revised v.2 2006; updated Oct 2014, effective Jan 2015].
https://fortress.wa.gov/ecy/publications/documents/1406029.pdf
7. Jacobson, Arthur Lee. November 2001. Wild Plants of Greater Seattle, a field guide to native and
naturalized plant of the Seattle area, published by Arthur Lee Jacobson, Seattle, WA.
8. Knobel. 1980. Field Guide to the Grasses, Sedges and Rushes of the United States. Dover Press, New
York.
9. Kollmorgen Corp. 1975. Munsell Soil Color Charts. Baltimore, Maryland.
10. Pojar, J., and A. MacKinnon. 1994. Plants of the Pacific Northwest Coast. BC Forest Service Research
Program. Lone Pine Publishing, Vancouver, Canada.
11. Tiner, R.W. 1993. Primary Indicators Method - A Practical Approach to Wetland Recognition and
Delineation in the United States. Wetlands 13(1): 50-64. This method is typically used for verifying
USFWS Wetland Database wetlands on the ground,
http://www.fws.gov/wetlands/_documents/gOther/PrimaryIndicatorsMethod.pdf
12. Tiner, R.W. 2003. Geographically Isolated Wetlands of the United States. Wetlands 23(3): 494-516.
This is prepared for the Society of Wetland Scientists, August 23, 2002; Revised: February 12, 2003;
Accepted: June 4, 2003, https://doi.org/10.1672/0277-5212(2003)023[0494:GIWOTU]2.0.CO;2
13. US Army Corps of Engineers (USACE). 2010. Regional Supplement to the Corps Of Engineers
Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (Version 2). Army
Engineer Research and Development Center, Vicksburg, Mississippi. ERDC/EL TR-10-3. [also see
reference for Washington (WDOE) Manual, below]
http://www.usace.army.mil/Missions/CivilWorks/RegulatoryProgramandPermits/reg_supp.aspx
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14. US Army Corps of Engineers (USACE). 2012 (updated 2014). National Wetland Plant List (NWPL).
Replaces the 1988 NWPL of Species that Occur in Wetlands for use in Clean Water Act wetland
delineations or determinations: http://geo.usace.army.mil/wetland_plants/index.html
15. US Department of Agriculture (USDA) Natural Resource Conservation Service (NRCS). 2010. Field
Indicators of Hydric Soils in the United States, Version 7.0. L.M. Vasilas, G.W. Hurt, and C.V. Noble
(eds.). USDA, NRCS in cooperation with the National Technical Committee for Hydric Soils, most
recent version: ftp://ftp-fc.sc.egov.usda.gov/NSSC/Hydric_Soils/FieldIndicators_v7.pdf
16. USDA, NRCS. 1973 to current. Soil Survey of King County Area, Washington. In cooperation with the
Washington Agricultural Experiment Station. Web Soil Survey: National Cooperative Soil Survey,
parts of King County, Washington. Accessed: Nov. 2020. Available:
https://websoilsurvey.nrcs.usda.gov/app/WebSoilSurvey.aspx.
17. US Fish and Wildlife Service (USFWS). Current. National Wetland Inventory (NWI), used to identify
mapped wetlands in the study area (original map data published in 1988). Digital wetland map
information, http://www.fws.gov/wetlands/Data/Mapper.html
18. US Geological Survey (USGS). 2001. 7.5' Quadrangle Topographic Maps or Digital Raster Graphic
(DRG). Topography map showing base map data from 1953 with photo-revisions dated 1981, used to
illustrate tributary watersheds, drainage features and streams in the study area at 1:24,000 (1”=2000’)
or 1:12,000 (1”=1000’) scales, http://topomaps.usgs.gov/drg
19. Washington Department of Agriculture (WDA). 2018. Washington State Noxious Weed List.
Washington State Noxious Weed Control Board, Olympia, Washington. Accessed: Nov. 2020.
Available: https://www.nwcb.wa.gov/printable-noxious-weed-list.
20. Washington Department of Ecology (WDOE), US Army Corps of Engineers (USACE) Seattle District,
and US Environmental Protection Agency (USEPA) Region 10. March 2006. Wetland Mitigation in
Washington State – Part 1: Agency Policies and Guidance (Version 1). WDOE Publication #06-06-
011a. Olympia, WA.
21. Washington Department of Ecology (WDOE). 2021. 303(d) Listed Segment of a Waterbody or
upstream of a listed segment that may result in further exceedances of the specific listed parameter.
Accessed: Nov 10, 2020. Map data available at:
https://apps.ecology.wa.gov/ApprovedWQA/ApprovedPages/ApprovedSearch.aspx