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14-105671 (2)arr of �. Federal Way CITY HALLFILE 33325 8th Avenue South Federal Way, WA 98003-6325 (253) 835-7000 www.cityoffederalway.com Kenneth Canfield October 31, 2014 Lakehaven Utility District PO Box 4249 Federal Way, WA 98063-4249 RE: File #14-105671-00-AD; LAKEHAVEN UTILITY DISTRICT PUMP STATION 33 Landscape Modification, Parcel #292104-9163 Dear Mr. Canfield: The Community Development Department is in receipt of your letter, dated October 8, 2014, regarding a proposed landscape modification as part of the Lakehaven Utility District Pump Station 33 project. Your project includes a proposed 50% reduction in a portion of a required .10' perimeter landscape strip. The following is a non -binding assessment of your landscape modification request. At the time of formal permit submittal, the entire proposal will be evaluated against applicable code and a formal determination with regard to the proposed landscape modification will be made. CODE REQUIREMENT In accordance with Federal Way Revised Code (FWRC) 19.125.100, modifications to the landscape code can be administratively approved by the Director of Community Development. Your proposal as described in your October 8th letter appears to qualify as a "special condition" per FWRC 19.125.100(c) (compliance with special easements) and (e) (unique site uses). Your proposed landscape modification is to utilize FWRC 19.125.100(5): "Perimeter landscape strips may be averaged, provided the minimum width shall not be less than 50 percent of the underlying width requirement." You have indicated your ability to supplement the area of landscape reduction elsewhere on the site. As required in FWRC 19.25.100.8, at time of permit submittal please provide the appropriate application materials to address the landscape modification and show on the landscape plan the specific areas of reduction and addition (in square feet for clarity). As a reminder, this project requires a Use Process IV submittal due to land surface modifications within regulated wetlands and buffers, and a State Environmental Policy Act (SEPA) checklist. Due to the potential presence of wetlands both on- and off -site a wetland report will be required as part of the permit submittal; see enclosed FWRC 19.175 regarding wetlands for further details. CLOSING We look forward to working with you on this project. Any questions concerning your application may be directed to Stacey Welsh, at 253-835-2634 or Stacey.welsh@cityoffederalway.com. Sincerely, Isaac Conlen Planning Manager enc. Letter dated October 8, 2014 FWRC 19.175 14-105671 Doc. I.D. 67178 ,�Nt_ L4 - 1115 LAKEHAVEN UTILITY DISTRICT o 31627 15` Ave South • P.O. Box 4249 • Federal Way, Washington 98063-4249 ��� Federal Way: 253-941-1516 • Tacoma: 253-927-2922 www.lakehaven.org RECEIVED BY tL11tY DIST1� COMMUNITY &ECONOMIC October 8, 2014 DEVELOPMENT DEPARTMENT Isaac Conlen, Planning Manager PV r-f s��an 3-3 OCT 10 2014 City of Federal Way tea„ �p (%4,Wj P.O. Box 9718 Federal Way, Washington 98063-9718 o S Ref: Lakehaven Utility District Pump Station 33 — 50 Percent Reduction of a Portion of the Landscape Strip Dear Isaac: This correspondence is a follow-up to a meeting I had with you regarding constructing a portion of the new Lakehaven Utility District Pump Station within the 10 foot perimeter landscaping strip. The zoning for the area is Suburban Estates. The District acquired 0.78 (parcel number 292104-9163) acres for the pump station. Because of groundwater issues, the District is proposing installing the 30 inch gravity sewer line between Pac Hwy and the pump station in a bored casing using micro - tunneling technology. This methodology will greatly reduced the amount of dewatering required to construct the 30 inch pipeline. The boring alignment has to be a straight line from Pac Hwy to the pump station. The existing locations of the District's property, easements, and a house owned by Mr. Don Barovic limits the boring alignment corridor possibilities. In order for the District to be able to use this boring technology, the pump station must be located 5 feet into the 10 foot wide perimeter landscaping strip as shown on the attached drawing. According to section 19.125.100 Modification Options (5) of the Federal Way Revised Code, "Perimeter landscaping strips may be averaged, provided the minimum width shall not be less than 50 percent of the underlying width requirement". The 50 percent landscape strip reduction would be located between the 20 foot access gates. The portion of the District property to be used for the pump station site will be fenced. Two 20 foot gates will be installed on either side of the pump station to allow maintenance staff to access the site using a circular driveway. The pump station site is not be visible from PAC Hwy to the east or the Brooklake Community Church to the north. The parcel to the south is primarily wetlands and trees, and most likely will never be developed. Mr. Barovic owns the homes to the east and west of the pump station site. The house to the east is adjacent to the pump station site. The house to west is located west of Hylebos Creek. I would propose increasing the landscape strip width along the east and west sides of the District property to offset the 50 percent reduction between the two access gates. Leonard D. Englund Charles I. Gibson Timothy A. McClain Donald L.P. Miller Ronald E. Nowicki Commissioner Commissioner Commissioner Commissioner Commissioner October 8, 2014 Page 2 of 2 You indicated that you could provide a non -binding written response that the proposed pump station could possibly be located in the landscape stripe, provided that intent of City of Federal Way Revised Code Section 19.125.100 is met. You also said that you would offer suggestions to meet of the City of Federal Way revised Code, if the rational presented in this letter is not adequate. It is our understanding that a final binding decision would not be provided by the City until after the project has been submitted for review. The District is nearing the completion of the pump station design and anticipates submitting it to the City for review by December this year. Should you need any additional information or have any questions, please contact me. Sincerely, Kenneth R. CanfOd Project Engineer, P.E. Enclosure Cc: File Leonard D. Englund Charles I. Gibson Timothy A. McClain Donald L.P. Miller Ronald E. Nowicki Commissioner Commissioner Commissioner Commissioner Commissioner w 0 � ) 5309 Shilshole Avenue NW Suite 200 Seattle, WA 98107 206.789.9658 phone 206.789.9684 fax memorandum date March 25, 2015 to Kenneth Canfield, Lakehaven Utility District from Claire Hoffman and, Michael Muscari subject Wetland Delineation on parcel 2921049088 www.esassoc.com Introduction Environmental Science Associates (ESA) was contracted by the Lakehaven Utility District (LUD) to conducte a wetland reconnaissance and partial delineation of the property (Tax Parcel 2921049088) on the corner of Pacific Highway South and South 359th Street in Federal Way (the property). The LUD is considering purchasing this property for a potential relocation of the existing pump station on the adjacent property. Background Information ESA performed a review of existing information regarding wetlands and streams. Sources of information included current aerial photographs, City of Federal Way maps, and National Wetland Inventory (NWI) data. The majority of the property is mapped by NWI as palustrine forested wetland, with the exception of the eastern edge (USFWS, 2015). The City of Federal Way Critical Area Map shows the entire property as a wetland with a stream on the western edge (Federal Way, 2012). The Spring Valley Open Space lies to the north and south of the property and a fish bearing tributary to Hylebos Creek runs north/south on the adjacent property to the east (Federal Way, 2008). Wetland Delineation and Reconnaissance On February 10, 2015 Claire Hoffman and Michael Muscari from ESA conducted a wetland delineation and reconnaissance of the property. During this site visit, ESA staff and Ken Canfield (LUD) walked the perimeter of the property as well as a diagonal path through the center of the property to observe and assess wetland conditions. A second site visit was conducted on February 13, 2015 by Michael Muscari and Scott Olmsted to complete data collection. The wetland was identified and delineated based on conditions at the time of the field visit by applying the wetland determination method described in the Regional Supplement (Western Mountains, Valleys, and Coast) to the Corps of Engineers 1987 Wetland Delineation Manual Corps (Corps, 2010). A Trimble Geo-XT GPS unit was used to record the location of the eastern wetland boundary, the remaining boundary was estimated. The wetland was classified according to the Washington State Department of Ecology's (Ecology) Wetland Rating System for Western Washington (Hruby, 2014) and City of Federal Way Revised Code (FWRC 19.175.020). Several data plots were established along the eastern property boundary in order to delineate the wetland boundary. Wetland indicators were present for hydrology, vegetation, and soils at each plot determined to be within the wetland boundary. Soils were saturated from the surface to a depth of at least 16 inches. Dominant vegetation consisted of wetland tolerant species. Soils exhibited hydric soil characteristics including redox dark surface and depleted matrix. The wetland on the property is part of a larger wetland complex (>30 acres), which includes a tributary to Hylebos Creek and extends from approximately South 359th Street to just north of South 373rd Street between Pacific Highway South and I-5. Just north of South 373rd Street, the tributary joins West Hylebos Creek. Figure 1 shows the extent of the wetland on the subject property. The wetland covers the majority of the property with a narrow section on the eastern edge of uplands along the paved driveway to the existing pump station. The wetland on the property is forested with many large trees including Western red cedar, Douglas fir, red alder, and vine maple. The dominant shrub is salmonberry, which provides moderately dense cover. Skunk cabbage and other native herbaceous plants are common throughout the site. The eastern edge of the wetland is emergent wetland as the wetland extends out of the forest into the driveway easement. This area is dominated by various grass species, including reed canary grass and soft rush. Shallow groundwater appears to be the primary source of hydrology to the wetland. There are also at least three culverts draining into the subject property. Two carry water under South 359`h Street from the wetland to the north; one near the one-third point (from the intersection of Pacific Highway and South 359`' Street) of the north property boundary, a second near the northwest corner of the property, and a third under Pacific Highway South near the mid -point of the west property boundary. At the time of the site visit the culverts had low flow. The water emerging from the northwestern culvert and the northerly culvert appear to merge and cross as a stream through the center of the property. A constructed ditch (likely decades old) runs approximately the length of the property near the southern boundary and is likely connected to the aforementioned western culvert. Under FWRC 19.175.020, this wetland would likely be considered a Category I because it has high function for wildlife habitat, water quality improvement, and hydrologic support. Habitat complexity is apparent because the wetland has three or more wetland classes, one of which is open water. Open water and emergent wetland classes are visible on aerial photography to the south of the subject property. Although these portions of the wetland are not on the subject property they are part of the wetland unit and thus considered in the rating. Structural complexity in the vegetation community also provides a high level of wildlife habitat functions. Ecology's rating system also categorizes it as a Category I wetland. Federal Way requires a 200-foot buffer around Category I wetlands (FWRC 19.175.020). References Corps (U.S. Army Corps of Engineers). 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region. Version 2. Wetlands Regulatory Assistance Program. May 2010. ERDC/EL TR-10-3. http://www.usace.army.mil/CECW/Documents/cecwo/reg/west_mt finalsupp.pdf. Federal Way. 2008. Current Land Use Map. Accessed March 24, 2015. Available at http://www.cityoffederalway.com/DocumentCenter/HomeNiew/457. Federal Way. 2012. Critical Areas Map. Accessed March 24, 2015. Available at http://wa- federalway.civicplus.com/DocumentCenter/HomeNiew/460. Hruby, T. 2014. Washington State Wetland Rating System for Western Washington — 2014 Update. Ecology publication number 14-06-029. Olympia, WA. USFWS. 2015. National Wetlands Inventory Wetland Mapper. Accessed March 24, 2015. Updated May 1, 2014. Available at: http://www.fws.gov/wetlands/Data/Mapper.html Photographs {Y y� S• �i ,f^• r i- ��=. f j_xp- ,.ram:• ... ••j i, •� � �., r .. �L �'I]�v _\ t , - �,� - L ._ ---•tea r,�.w..,•� � �1 � ..1_y: � 'l 1 {: �y. ram'^ •�.1 ti`.�c� �� .. `I it � � ,kY � � !• � •- J Photo 2. Eastern edge of wetland along driveway easement, facing north (February 13, 2015). south (February 13, 2015). SOURCE: ESA 2015, OSM 2014, King County 2014, ESRI 2013 Lakehaven Pumpstation. 206061.14 Figure 1 Lakehaven Utility District Pump Station Investigation Site 5309 Shilshole Avenue NW vMv.adolison.coni Suite 200 Seattle, WA 98107 206.789.9658 phone 206.789.9684 fan date August 14, 2009 'To Ken Canfield; Lakehaven Utility District from Laura Brock and Michael Muscari subject Lakehaven Utility )(District, )3arovic Property (Pa reel 2921049098) Critical Areas (Delineations, Federal Way, Washington ESA Adolfson is pleased to present our critical areas delineations findings for the Barovic Property (King County Parcel 2921049098), located at 35929 Pacific Highway South, approximately 600 feet west of the intersection of Pacific Highway South and S. 359th St, in Federal Way, Washington (NW '/a, Section 29, Township 21N, Range 4E; Figure 1). ESA Adolfson conducted these critical areas delineations at the request of Lakehaven Utility District (LUD), which is considering the parcel as a possible location for a utility corridor associated with the P33 Pump Station. The property is accessed from a gravel driveway on the adjacent parcel to the east (King County Parcel 2921049020) and is currently developed with a single family residence and several associated outbuildings (Figure 2). In addition to the single family residence, the property is also used for grazing small livestock (goats and chickens) and tree harvesting. A mix of open -canopy forest, closed -canopy forest, and meadows covers the property. The property slopes down from the east and west towards a stream which flows through the center of the property. Two small bridges provide access to the residence, which is located west of the stream. ESA Adolfson previously conducted delineations on a parcel to the east (King County Parcel 2921049020); the results of those investigations were also used during this study. Methodology ESA Adolfson biologists Michael Muscari,and Laura Brock conducted wetland and stream delineations on the Barovic property on June 25, 2009. Biologists Laura Brock and Rosemary Baker made a return site visit on June 30, 2009 to complete the delineations. Wetland boundaries were delineated using the Washington State Wetlands Identification and Delineation Manual (Washington Department of Ecology, 1997) and the Western Mountains, Valleys, and Coast Interim Regional Supplement (US Army Corps of Engineers, 2008). Wetland boundaries were marked with pink "Wetland Boundary" flagging tape, and data plot locations were marked with orange flagging tape. Stream boundaries were marked with blue and white striped flagging tape along the ordinary high water marls (OHWM). The flagged wetland and stream boundaries were professionally surveyed by INCA during July 2009. Critical area categories and buffer requirements were determined using Federal Way Revised Code (FWRC) Title 19, Division V—Critical Areas. Lakehaven Utility District, Barovic Critical Areas Study August 14, 2009 Findings Four wetlands (Wetlands 4, 5, 6, and 7) and one stream (Stream 2) were delineated on the Barovic property (Figure 2). Additionally, small wetlands were identified extending east and west approximately five to 15 feet upslope of the stream OHWM, where groundwater was emerging as seeps. These seeps are located between Wetlands 4 and 5, in the central portion of the property. These wetlands were not delineated because they appeared to be less than 2,500 square feet in size, below the regulatory threshold in Federal Way, and are entirely contained within the stream buffer. A description of the delineated wetlands, stream, and uplands follows. Wetland Descriptions Wetland 4 Wetland 4 (estimated to be greater than one acre), located along the southwestein edge of the property, is a palustrine, forested wetland adjacent to the stream running through the center of the property (Figure 2). The portion of the wetland that is on the Barovic property slopes down, to the south and east towards Stream 2. Red alder (Alnus rubra) provides tree canopy over the majority of the wetland. Salmonberry (Rubes spectabilis), stinging nettle (Urtica dioica), skunk cabbage (Lysichiron ramericanum), lady fern (Athryivm felix fenzina), and giant horsetail (Equisetunz telrnateia) are the dominant plants in the understory. Wetland 4 receives water primarily from a high groundwater table, and exhibits characteristics of both depressional and slope hydrogeomarphic classes. On the June 25 and 30, 2009 site visits, soil within a large portion of the wetland interior was saturated to the surface. Water leaves the wetland primarily through the stream. Soil within Wetland 4 met requirements for hydric soil indicator F1, Loamy Mucky Mineral. A black (10 YR 2/1) mucky modified mineral layer greater than four inches deep was observed throughout the wetland. The wetland continues off -site, to the south. Wetland 5 Wetland 5 (estimated to be greater than 1 acre), located on the northwestern portion of the property, is a palustrine, forested wetland adjacent to Stream 2 (Figure 2). The majority of the wetland continues off -site to the north. The portion of the wetland on the Barovic property slopes down to the east and west towards the stream. Red alder douunates the canopy cover of the wetland; several Iarge alders and a large hemlock, which appeared to be greater than 21 inches in diameter, were observed in the wetland off -site to the north. Water parsley (Denanthe sarmentosa), skunk cabbage, and salmonber7ry dominate the understory. Wetland 5 receives water primarily from a high groundwater table and from small off --site streams running into Stream 2. During the June 25 and 30, 2009 site visits, soil was saturated to the surface or was observed to have.several inches of flowing water present. According to hydrogeomorphic classification, the wetland exhibits riverine and slope hydrogeomorphic characteristics. Steam 2, a tributary to West Hylebos Creek, is the wetland's inlet and outlet. On the Barovic property, soil within Wetland 5 met requirements for hydric soil indicators Al 1, Depleted Below Dark Surface, 'and F3, Depleted Matrix. A black (10 YR 2/1) silt loam was observed in the surface layer, and gray (2.5 Y 6/1) silt with dark yellowish brown (10 YR 516) and strong brown (7.5 YR 4/6) redoximorphic features was observed in the subsoil. The wetland interior was observed to have organic soil. Wetland 5 is separated from wetlands contiguous with the West Hylebos Wetland Park, a Category 1 wetland complex, by the road bed fill supporting S. 356111 Street; off -site to the north of the property. However, Stream 2, 9 M Lakelraven Utility District, Barovic Critical Areas Stud)I August 14, 2009 a tributary to West Hylebos Creels provides a comiection between these wetlands byway of a culvert beneath the roadway. Wetland 6 Wetland 6 (2,059 square feet), located within a ditch running east to west along the north side of the residence, is a palustrine emergent wetland (Figure 2). Velvet: grass (Holcus lanaw) and creeping buttercup (Ranuneulus repens) dominate the wetland, with a few red alders lining the ditch. An eight -inch culvert, located at the west end of the wetland, is the wetland's inlet. Wetland 6 receives water primarily from surface flows from the surrounding area and presumably flood flows from Wetland 5. Water from the wetland flows through the ditch and into Stream 2. According to hydrogeomorphic classification, the wetland exhibits riverine hydrogeomorphic characteristics. During the June 25 and 30, 20o9 site visits, soil was saturated to the surface in the wetland interior. Soil within Wetland 6 met requirements for hydric soil indicators All, Depleted Below Dark Surface, and F3, Depleted Matrix. A very dark brown (10 YR 2/2) sandy Ioam was observed in the surface layer, and gray (2.5 Y 511) silt with dark yellowish brown (10 YR 4/6) and strong brown (7.5 YR 416) redoximorphic features was observed in the subsoil. Wetland 7 Wetland 7 (257 square feet), located in a small depression in the southeast portion of the property, is a palustrine emergent wetland (Fig= 2). Timothy grass (Phlown pratense), creeping buttercup, and bentgrass (Agrosfis sp.) dominate the wetland. Red alders sparsely sir Tound the depression. Wetland 7 receives water primarily from surface flows from the surrounding area. According to hydrogeomorphic classification, the wetland exhibits depressional hydrogeomorphic, characteristics. An outlet is present at the west edge of the wetland, where a ten - inch culvert directs water flow under a gravel roadway and onto an adjacent slope. During the June 30, 2009 site visit, water was observed seeping into the soil pit at 20-inches. We assume that the water table is higher earlier in the growing season. Soil within Wetland 7 met requirements for hydric soil indicator F1, Loamy Mucky Mineral. :,A. modified mucky loans was observed to a depth of 20 inches within the wetland. According to FWRC 1.9.175.020, Wetland 7 is not regulated by the City of Federal Way because it is less than 2,500 square feet. Stream Description Stream 2 (West Fork of Hylebos Creels) is approximately five to ten feet wide where it flows through the center of the property north to south (Figure 2), The stream meanders through forest at the north end Of the property, and fine silts, sands and small gravels forin the st varn substrate. At the center of the property, the stream enters an incised ravine with no shade cover. The ravine extends approximately 500 feet through the center of the property, and continues off -site to the south. Large cobbles and gravels form the stream substrate, which was covered with algae in June 2009. As the stream continues to the south, stream bank incision increases and signs of bank erosion are prevalent. Farther to the south, the stream reenters forest. Riffles and pools were observed along the southern portion of the stream within the forest. Stream 2 is documented to support anadromous sahnonids. Lakehaven Utility District, BarovicCritical,lreasStudy ktgust 14, 2009 Upland Description Uplands on the Barovic property generally consist of open -canopy forest, closed -canopy forest, and meadows. Red alder, big leaf maple (Ater rnacrophyllum), black cottonwood (Populus balsoinijera), Douglas fir (Psuedotsuga rnen:iesii), Western red cedar (Tln ja plicata), and western hemlock (Tsuga heterophylla) line the edges of slopes and previously cleared areas of the property. Hunalayan blackbeny (Rubus aremeniacus), snowberry (Symphoricwpos albus), and salnronberry were observed in the forest understory along the edges of clearings. Meadows dominated by Timothy, velvetgrass, and bentgrass are located in the central portion of the property, with tree islands interspersed throughout. Conclusion and Summary Portions of four wetlands (Wetlands 4, 5, 6, and 7) and one stream (Stream 2) were delineated and classified for this investigation. A summary of these critical areas and their buffer requirements is given below and in Table 1.. Required buffers are shown on Figure 2. GPetland Categories According to FWRC 19.175.020, Wetland 4 is considered a Category 2 wetland because it is estimated to be greater than one acre in size and is contiguous with Stream 2, which supports anadromous sahnonids. According to FWRC 19.175.020, Wetland 5 is considered a Category 1 wetland because of its association with Stream 2, which has documented anadromous sahnonid fish presence. The small tributaries which flow into Stream 2 likely contain fish habitat as well. Additionally, the wetland appears to be a mature forested wetland (trees greater than 21 inches in diameter) as defined by the Washington Department of Fish and Wildlife (WDFW), which provides irreplaceable ecological functions and local significance. According to FWRC 19.175.020, Wetlands 6 and 7 and the wetland seeps adjacent to Stream 2 are not regulated by the City of Federal Way because they are less than 2,500 square feet. The City of Federal Way does not regulate wetlands less than 2,500 square feet in size, regardless of whether the wetland is isolated or connected to a water body. Therefore, even though Wetland 6 and the wetland seeps are contiguous with Stream 2, they are not regulated by the City and have no buffer .requirement. The seeps are located entirely within the Stream 2 buffer. Table 1. Wetland Summary Table Wetland ID Estimated Total Area Cowardin Class HGM Class 'Wetland Category Buffer Require exit 4 > 1 acre PFO Depressional/Sloe _ 2 100 ft. 5 > 1 acre PFO R_ iyerine/Slope 1 200 ft. 6 < 2,500 s . ft. PEM Riverine Not regulated by the City n/a 7 < 2,500 s . ft. PEM Depressional Not regulated by the City n/a Stream Rating According to the City of Federal Way, the stream is rated as a major stream (Federal Way, 2005). The FWRC 19.05.130 defines a major stream as "any stream, and the tributaries to any stream, which contains or supports, or Lakehaven Utility District, Barovic CriticalflreasStudy flz(gust 14, 2009 under normal circumstances contains or supports, resident or migratory fish." According to FWRC 19.16,5.010,, major streams require a 100-foot buffer. Limitations Vithin the limitations of schedule, budget, and scope -of -work we warrant that this study was conducted in accordance with generally accepted environmental science practices, including the technical guidelines and criteria in effect at the time this study was perforined. The results and conclusions of this report represent the authors' best professional judgment, based upon site conditions present at the time of the investigation and information provided by the project proponent in addition to that obtained du�iug the course of this study. No other waitnanty, expressed or implied, is made. Thank you for the opportunity to prepare this material for you. If you have any questions, please call 206-789- 9658. Attach)nents Figure 1: Site Vicinity Map Figure 2: Wetland Map References Federal Way. 2005, Stream Ratings Map. Accessed at: htt -. xvwww.citvoffederalwa .coin/folders/liomelbusinesseconamicdevela nient/ci (pia s/enviroiuneneattu aaslstreanis.pdf US Army Corps of Engineers. 2008. Western Mountains, Valleys, and CoastInferirn Regional Supplement.. Washington Department of Ecology. 1997. Washington State Wetlands Identification and Delineation Manual. Ecology Publication #96-94. Lakehaven Design .26061.2 SOURCE: ESAAdolfson, 2009; IGng.County, 2008 (2002Air Photo) Figure I Vicinity Map federal Way, Washington w r i I • 'A* rg E'_ e h � - 1. . 4 ` � .' r - � ��'�`�f� oft♦ Yt"t'' 'i��P ��i � Z� � 1 .. ;�� 1' ?=•1' �' r�a'�y` '1'tr►r+tv�l�O�J` ��r � � �' � •y. .•..�.. S. +tip, ��±". .di . I� i�' •���+i ;•S��iyi��+.+•J�'�LCJY.TY• � � 't�'' I .. . ': J.''..%✓�.ryrJ�3�ti���rR� . =`S�i. � .�� Fi�A'.—�11 �_fiii'[ �1• �J-r _ , _ 5309 Shilshole Avenue NW www.adolfson.com ESSuite 200 Seattle, WA 98107 206.789.9658 phone 206.789.9684 fax date March 19, 2009 to Kenneth R. Canfield, Project Engineer Lakehaven Utility District 31623 1" Ave South Federal Way, WA 98063-4249 -from Michael Muscari, Senior Wetland Scientist Rosemary Balser, Project Scientist subject LUD Project 5204401 and 5205503, Amendment, Task 4 Barovic Property Wetland Study Background At the request of the Lakehaven Utility District, BSA Adolfson, Inc. (Adolfson) identified and delineated wetlands within the 1.8-acres Barovic Property located at 35935 Pacific Highway South (I-99) in Federal Way, Washington (SW quarter Section 29, Township 21N, Range 4E) (Figure 1). This parcel is being considered as a possible location for the P33 Puinp Station. The Barovic property lies on a relatively flat upland bench between tributaries of the Hylebos Creel-, Watershed. The surrounding area remains as a forested and relatively undeveloped section of land along the Pacific Highway South corridor. Some residential development occurs within 1,000 feet of the property. West Hylebos State Park lies within a quarter mile to the north, east, and south. A single-family residence with several out buildings are .located on the east end of the Barovic property, and a wooden roof was recently constructed over an existing well east of the home. Two gravel driveways enter the property from Pacific Highway South, converging into one driveway approximately 500 feet west of the entrance. Methods T�vo levels of investigation were conducted for the analysis of wetlands on the subject property; a review of existing information and an on -site investigation. Several;esources were reviewed: 0 U.S. Geological Survey (USGS), 196�1—Poverty Bay, WA. Topographic map; Q National Wetland Inventory (NWI) Poverty Bay quadrangle (U.S. Fish and Wildlife Service (USFWS), 1989); C. WDFW Priority Habitats and Species (PHS) Data, October 2008; o City of Federal Way Wetlands Inventory mapping (2005). .lurisdictional wetlands were identified based on field conditions observed at the time of the investigation and applying the wetland determination method described in the Washington State Wetlands Identification and Deli7ieation Manzral (Washington Department of Ecology publication No. 96-94, 1997). The Federal Way Municipal Code (FWMC) definition of regulated wetlands and buffers (FWMC 22.1356 and FWMC 22.1) was used to further determine regulatory constraints on the site. Areas meeting the three parameters required for wetland determinations were flagged or recorded with Global Positioning System (GPS) datapoints. Biologists Michael Muscari and Rosemary Balser from ESA Adolfson began the site investigation on February 4, 2009, and biologists Rosemary Baker and Laura Brock finished on February 5, 2009. INE Existing information Data from the NWi/USFWS Wetlands Online Mapper does not indicate wetlands on the Barovic property,. however immediately to the south a large palustrine forested wetland is mapped. As depicted by this map, the wetland to the south connects to a tributary of West Hylebos Creels. According to WDFW PHS data there are no wetlands or priority habitats or species located on the property. PHS data does indicate an off -site salmon -bearing tributary of West Hylebos Creels and Hylebos Wetlands to the north, west, and south of the property within one quarter -mile. Hylebos stream and wetland buffers do not extend on to the Barovic property. City of Federal Way Wetlands Inventory Mapping data (2005) also indicate a wetland on the parcel to the immediate south of the Barovic property, but no wetlands are mapped on the project site. Wetland A Wetland A is located on the property between the residence and Pacific Highway South (Figure 2) and is approximately 0.09-acres in size. Wetland A has a hydrogeomorphic (HGM) class of slope with both forested and scrub -shrub vegetation. Data plot (DP) 1 and DP3 describe the wetland. Data plot 2 is located in the adjacent upland. A small stream uriginates in the wetland (see stream description below). Hykolo The source ofhydiology for Wetland A appears to be a groundwater -fed spring, as well as precipitation, and stormwater runoff originating from the house and driveways. A small ditch originating from the north driveway extends south through Wetland A, connecting to the on -site stream (see stream description below). No surface ponding or flowing water was observed in this ditch duringthe survey: Data Plot 1 was located in a relatively flat area along the south edge of the wetland, within one toot of the flowing stream. Wetland hydrology indicators included saturation at 8 inches below the surface and a hydrogen sulfide odor. Data Plot 3 was located at the sloped north end of Wetland A. Saturation was present at the surface, and free water in the pit was found at 8 inches below the surface. An additional indicator of wetland hydrology at DP3 was hydrogen sulfide odor. Soils At DP 1, the soil matrix was black (IOYR 211) sandy loath from the surface to a depth of 3 inches. 13etweetn 3 and 13 inches below the surface, the soil was gravelly sandy loan with a black (IOYR 2/1) matrix color. Saprie peat was found at a depth of 22 inches. Hydric soil indicators at DPI include a thick dark surface layer and low chrorna below the surface horizon. At DP3, the soil was very dark brown (1 OYR 2/2) mucky sandy loam from the surface to a depth of 4 inches. From 4 to 8 inches in depth, the soil was a very dark brown (1OYR 2/2) sapric muck, with a few pieces of Undecomposed wood. From 8 to 18 inches in depth; the soil was a black (IOYR 2/1) gravelly sandy loaitz. The, hydric soil indicator at DP3 was a histic epipedon., Ve� e�tation Wetland A contained a forested vegetation community. Dominant vegetation at DPI was red alder (rAlnus i•adira), salmonberrY (nubus spectabilis), and creeping buttercup (Ra?wncuhis repens). Dominant vegetation at DP3 was red alder (Alnus rubra), salmonberry (Rebus spectabilis), lady fern (Ath}rriuiit frlix,fewina), and creeping buttercup. Other hydric vegetation observed in the wetland included small -fruited bulrush (Schpus nliai Qcarpus), youth -on -age (Tolrirei4 memzaiesii), mannagrass (Glyceria spp.), Nootka rose (Rosa nuLkana), red elderberry (5ainbucus racemosa), and slcunk cabbage (Lysichito,z ajnerfcanum). The wetland vegetation criterion was met, as 100 percent of the dominant plants were hydrophytic species. Wetland B Wetland 13 is approximately 0.01-acres in size, positioned at the northeast corner of the property, abutting both. Pacific Highway South and a paved driveway (Figure 2). A very small portion of this wetland extends on to the adjacent parcel to the north. The wetland and surrounding upland appeared to have been recently mowed, grazed, and seeded with grasses. Some mowed shrubs were present in areas. Wetland B is a palustrine emergent wetland in the depressional HGM class. Data Plot 4 characterizes the wetland and DP5 characterizes the upland. H droloa The source of hydrology for Wetland B appears to be a combination of precipitation and starrnwater from a ditch along the gravel driveway, and possibly runoff from Pacific Highway South. Groundwater discharge may also occur in the wetland. At DP4, saturation was present at the surface and 2 inches of surface water was present in what appeared to be a wheel rut. Soils At DP4, the surface soil to a depth of 18 inches was 45 percent very dark gray (10YR 3/1) and 45 percent black (10YR 211) gravelly sandy loam, with 10 percent pockets of sand located at 12 inches below the surface. Below 18 inches in depth, the matrix color was gleyed greenish gray (10Y 511) sandy loan with cobble and undecomposed organic matter, with 1 percent light olive brown (25Y 516) redoxirnorphic features. V tion Wetland B vegetation is predominantly emergent with a few inowed or grazed shrubs on the west side. Dominant species were small -fruited bulrush, bittercress (Cardamine spp.), sahnonberry, and Himalayan blackberry (IRubus ar me-niamq). Small amounts of reed canary -grass (iahalaris cm-undinacea) and American speedwell (Veronica annericana) were also present. Wetland C Wetland C is located along the south property boundary and extends south of the Barovic Property (Figure 2). Only a small portion of this wetland is located on site. The north edge of this wetland lies within 10 to 20 feet of the south property line for most of the parcel. The on -site portion of Wetland C is approximately 0.01 acres in size and appears to be a depressional HGM class wetland with forested and shrub -scrub vegetation. Data Plot 9 describes the wetland however observations were limited by lack of access to the neighboring property. Data Plot 6, DP7, and DP8 describe the upland, Hydrology Based on reference with allSGS topographic map, NWI maps, and visual survey from the Barovic property, the predominant wetland hydrology in Wetland C appears to be precipitation and groundwater discharge. In addition, a small stream (described below) originating in Wetland A enters the northeast corner of Wetland C augmenting hydrology in the east portion of the wetland. Based upon review of existing information (USGS topographic maps, and NWI mapping) Wetland C is located on a bench above a tributary of West Hylebos Creek to the west. NWI/USFWS maps indicate a surface connection between Wetland C and West Hylebos Creek and other nearby Hylebos wetlands. However, based on review of topographic maps and visual survey in the field, a north -south ridge appears to separate Wetland C fiom West Hylebos Creek. Although NWI and WDFW PHS streams and wetland xnapping both indicate a hydrologic connection to the Hylebos tributary to the West, the City of Federal Way Wetland Inventory Map and the observed ridgeline to the west indicate a hydrologic connection to the east of Pacific Highway South. We observed surface water from Wetlands A and C flowing east into a culvert beneath Pacific Highway South. A hydrologic connection between Wetland C and.Hylebos Creek or Hylebos Wetlands to the south is also possible but is'not known at this time due to lack of access to the site. Small areas of ponding were observed just off -site to the south, surface saturation was present, and the water table occurred at 6 inches below the surface on the project site. Other hydrologic indicators included water -stained leaves and drainage patterns. An outlet was observed from the eastern edge of the wetland, with water flowing east into a 1-foot diameter culvert as described below. Soils Wetland soil was black (10YR 2/1) muck from the surface to 18 inches in depth. The soil was henuc in texture with undecomposed wood throughout. Below 18 inches, the matrix color was light gray (2.5Y 7/1) with less than 5 percent yellow (5Y 7/6) redoximorphic features. Hydric soil indicators included a histic epipedon, thick dark surface, and a hydrogen sulfide odor. A gravelly sand restrictive layer was also found at 18 inches. Veaetation Observed vegetation in Wetland 3C include forested and shrub -scrub communities. Forested portions of Wetland C were dominated by red alder, salmonberry, Indian plum (Oenderia cerasiformus), and red elderberry (Sanibucus racemosa) and false -lily -of -the -valley olianthenmum dilatatuin). Shrub -scrub portions of Wetland C were dominated by red -osier dogwood (Corpus sericea), willow (Salix sp.), and Hardhack (Spiraea douglasii). The wetland also contained numerous wildlife habitat features such as fallen logs and snags. Stream The onsite spring fed stream, originating in Wetland A, flows south out of the wetland through a small (four inch - diameter) culvert under the south gravel driveway, and drains south into adjacent Wetland C (Figure 2). After 2 entering Wetland C, the stream turns east and enters a ditch along Pacif c Highti��ay South. On -site, the stream contained a muddy substrate and width varied between 1 and 3 feet. Regulatory implications Wetlands are regulated atthe federal, state, and local levels. Agencies with jurisdiction include the U.S. Army Corps of Engineers (Corps), Washington State Departinent of Ecology (Ecology), and the City of Federal Way. The Washington Department of Fish and Wildlife regulates warlc within streams. Regulatory implications associated with development in wetlands include, but may not be limited to, those discussed in this section. All applicable permits should be obtained prior to developuig or otherwise altering streams or wetlands. Federal Regulations The Corps regulates discharges of dredged or fill materials into waters of the United States, including wetlands, tinder Section 404 of the Clean Water Act. The Corps has established two types o f perinit programs under Section 404: nationwide and individual. Nationwide permits are issued when a proposed activity will have minimal adverse impacts to wetlands, All other projects are evaluated under the individual permitting process. The Corps determines which permitting process is used for a proposed project. The Corps will require that wetland impacts be avoided or minimized to the extent practicable, and mitigation will likely be required for unavoidable wetland irnpacts. State Regulations The state certification process under Section 401 of the federal Clean Water Act is usually triggered through a Section 404 permit application. Section 401 directs each state to certify that proposed in -water activities will not adversely affect water quality or violate state aquatic protection laws. In Washington state, Ecology is -responsible for administering the state certification program. Ecology may issue approval, approval with conditions, denial, or a request for delay due to lack of information. And conditions attached to the 401 certification become part of the Section 404 pen -nit. -ICing County is one of the 15 coastal counties in Washington regulated under the Washington State Coastal Zone Management (CZM) Program. Activities that would affect coastal resources and involve approvals fiom the federal government (such as a Sectioa404 permit) must be evaluated for CZM compliance through a process call "federal consistency." The Washington State Department of Ecology administers the CZM program in this state. If relocation or alteration of stream culverts or other in -stream work is proposed as part of the project, aHydraulic Project Approval (HPA) would be required from the Washington Department of Fish and Wildlife under the state Hydraulic Code (RCW 77.55, WAC 220-110)., Local regulations The Sarovic property is Jocated within the City of Federal Way. Critical Areas are discussed in the Federal Way Municipal Code under Article XIV, Chapter 22. The following describes the ratings for Wetlands A,13, and C and their regulated buffers as described in FW1bIC 22,1357. 6 Wetlands Wetland A merits a Category III rating based on size (approximately 0.09 ac/3,920 sf) and relatively simple vegetation structure (see Table 1 below). Wetland B also merits a Category III rating, however due to its small size, it appears to be smaller than the 2,500 sf threshold, and is therefore likely exempt from Federal Way regulation (see Table 1 below). The code is not specific on regulation of wetlands smaller than 2,500 sf in size. Wetland C received a tentative Category II rating based on: a conditions observed from the Barovic property and from along Pacific Highway South, P topographic maps, and a assumptions made regarding connectivity to other wetlands in the area. However, this rating for Wetland C cannot be confirmed without access to the adjacent property. WDFW Priority Habitat and Species data did not indicate any "presence of species or documented habitat recognized by state or federal agencies as endangered or threatened, or extirpated plant, fish or animal species" in Wetland C. It remains uncertain whether Wetland C is contiguous with larger wetlands to the south, which might raise Wetland C to a Category I Wetland. Stream According to the definition of major and minor streams in the FWMC, the seasonal spring -fed stream flowing through Wetland A into Wetland C and then into the ditch along Pacific Highway South, would be categorized as a minor stream (FWMC 22.1) (see Table 1 below). Minor streams receive a 50-foot buffer under FWMC 22.1306. Off -site to the south, the stream enters a small (1-foot diameter) culvert under Pacific Highway South, which is likely a blockage to fish passage. ,r m i Wae1.-1 ii..rl .Qf -pam i"atPonries and Buffers Type - Categmy Buffer (fi) Wetland A 111 25 Wetland B III likely exempt Wetland C II 100 Stream 1 Minor Stream 50 According to FWMC 22.1306, "no land surface modification or improvements may take place or be located in a stream or within setback areas..." Listed exceptions to this include any segment of a stream running through a culvert; unless that strearn will be taken out of the culvert as part of development on the subject property. Section 22.1307 of the FWMC states that stream relocation is permitted if the applicant submits a stream relocation plan that includes but is not limited to the following: specifications to create natural meander, gentle side slopes, application of erosion control measures, utilization of natuta.l materials, revegetation using native riparian species, and creation of habitat and stream flows that best suit fish populations. The previous stream channel must also be -filled and revegetated (FWMC 22.1307). Section 22.1312 states the city may permit the placement of an. essential public facility, public utility or other public improvements in a setback Rom a stream if they judge no Feasible ,alternative location exists: Compensatory mitigation requirements for impacts to wetland habitat on the subject property are found in FWMC 22.1358 and are listed in the following table: Tattle 2. Federai Way'FN a and Re iaeef0cut Iiatias for Cate ai 11 and 111 Wetlands Wetland Creation and ratarmry Restoration Enhancement tegory II: Forested 3:1 6:1 Scrub -shrub 2:1 4:1 Emer ent 2:1 4:1 to ory III: Forested 2:1 4:1 Scrub -shrub 1.5:1 _ 3:1 PmarnPrnt 1.25:1 2.5:1 Attachments Figure 1 Vicinity Map Figure 2 — Site Map of wetlands and buffers 7 Waterbodies . ._i Parlcs Lakehaveh Design . 26061.2 SOURCE: ESA Adolfson, 2009; King County, 2008 (2002Air Photo) Figure 1 Vicinity Map Federal Way, Washington u? CV u1 C d O o N- L N = Q o,LL r U) Q N m N CIS m c0 J L a) Q} LL.. 1 O O L a N O O N_ co O O N C 7 O U r C 0 O O N C O O U Q Q w W W U D O O s 5309 Shilshole avenue NW ymmadolfson.com Suite 200 F" ESA Seattle, WA 9810T 206.789.9658 phone '206'789.9684 fax memorandum date December 24, 2007 'to Ken Canfield, Lakehaven Utility District from Karmen Martin; Ilon.Logan RECEIVED AUG 12 2015 CITY OF FEDERAL WAY CDS subject Lakehaven Utility District P33 Conveyance - Preliminary Evaluation Introduction This technical memorandum was prepared as part of the -Preliminary Evaluation Phase for the Lakehaven Utility District Pump Station 33 Conveyance Project. The purpose of our evaluation is to identify existing conditions that may influence the siting of a new pump station (P33) and selection of an alignment for a new force main. The memorandum summarizes the results of ESA Adolfson's literature review and wetland reconnaissance for four alternative force main alignments and two pump station locations. Our evaluation consisted of a preliminary review of available literature and a field investigation to identify the presence of wetland and streams. Our evaluation also included a literature review to identify documented occurrences of threatened and endangered species in the project area. Project Description The Lakehaven Utility District P33 Conveyance Project includes the following components: v Construction of a new 4,500 — 6,000 GPM pump station. Construction of a new 18 to 24-inch-diameter force main between the new P33 pump station to the Panther Lake Sewer Trunk Line connection point at either manhole #1 located near SW Campus Drive and 2"d Avenue SW, or Manhole 8 located approximately 100 feet north of the 4" Place SW cul-de-sac (352"d block), approximately 1,300 feet south of Manhole 1. Construction of a new 24-inch gravity sewer line in South 359th Street (west of 14'h Place South) and in the existing pump station easement access road to replace an existing 12-inch gravity sewer line. The project area is located in the southern portion of the City of Federal Way (Figure 1). The project area is generally bounded by South 348'h Street on the north, South 359th Street on the south, 14th Place South on the east, and 7th Avenue South on the west. The force main alternative alignments are generally centered around this West Hylebos Wetlands Park. Single-family residential development is the predominant land use in the area located west of 1" Avenue South and south of the project area. Commercial areas are located along Pacific Highway South and office uses are located north of South 348th Street, Pump Station Site Alternatives The Lakehaven Utility District has identified two alternative locations for the new pump station for preliminary evaluation (Figure 2). Site 1 is City -owned property located east of Pacific Highway South and south of South P33 Preliminary Evaluation i December 24, 2007 359'" Street. Site 2 is a private parcel located west of Pacific Highway South. The District would be required to get an easement from the owner of the site that is selected. At either potential site, the new pump station would require a construction footprint of approximately 100 feet by 100 feet. The finished pump station site dimensions would be approximately 75 feet by 75 feet (0.13 acre). Force Main Alignment Alternatives The District identified three conceptual alignments for the force main as part of the project pre -design. A fourth alignment (the District's preferred alignment.) was identified in September 2007 and is also evaluated in this memo. The force main alignment alternatives, designated as Alternatives 1, 2 and 3, and the Preferred Alternative, are shown on Figure 2. The District indicated that a combination of horizontal directional drilling (HDD) and open -cut construction methods are being considered for these alternatives. Under all the alternatives, the majority of the force main would be constructed within existing roads or sidewalks, thus avoiding most impacts to streams and wetland areas. The force main pipeline would be a maximum of 24 inches in diameter, and any permanent easements would extend on both sides of the pipeline. Temporary construction easements would be wider, and would also depend on the location of the staging areas and drilling shafts for the pipeline installation. 24-inch Gravity Sewer Line Construction of the 24-inch gravity sewer line would occur entirely within the built roadway of 359t ` Street and the access road for the pump station, except for that portion constructed from the access road to the pump station. No alternatives to this alignment were identified by the District. Methods Existing Information According to the National Wetland Inventory (NWI) Poverty Bay Quadrangle (USFWS, 1987) several wetlands are mapped on or in the vicinity of the project (Figure 2). The West Hylebos Wetlands are generally mapped as palustrine forested (PFO) wetlands with smaller patches of palustrine scrub -shrub (PSS) communities within the larger complex. Brook Lake and Marlake, which lie within the West Hylebos wetland complex, are mapped as open water wetlands that are permanently flooded. The dataset for NWI mapping was developed from aerial photograph interpretation and soil survey, with no field confirmation. Therefore, the NWI wetlands shown on Figure 2 do not accurately represent wetland boundaries, but rather give a general idea where wetlands occur. On a regional level, wetlands and streams in the City of Federal Way were identified in 1998 as part of a critical areas. survey and are shown on the City of Federal Way Critical Areas Map (2005). The map shows three major streams extending through northeast and northwest portions of the project area near both of the proposed pump station locations. A branch of Hylebos Creek is mapped near both of the proposed pump station sites (Figure 2). The Soil Survey of King CountyArea (Snyder et al., 1973) maps several soil types in the project area that can often indicate the. presence of wetland (hydric) soils. These soil types include: Bellingham silt loam, Seattle snuck, Norma loam. The mapping of these soils types is generally consistent with the locations of wetlands identified on the City's critical areas map. A search of the Washington Department of Fish and Wildlife (WDFW) Priority Habitats and Species database found that no threatened or endangered wildlife species listed under the Endangered Species Act (ESA) are known to occur in the project area (WDFW, 2007). The closest known bald eagle nest is approximately 1.5 miles northeast of the project area on the east side of I-5. Priority fish species present include coho salmon in the portion of Hylebos Creek that flows from the center of the project area south and West Hylebos Creek located east of the existing pump station site. Winter steelhead are also present in West Hylebos Creek, which were recently listed P33 Preliminary Evaluation 2 December 24, 2007 as threatened by NOAA. Downstream reaches of Hylebos Creek are known to support Chinook salmon, an ESA listed species (WDFW, 2007). Field Investigation Adolfson staff Steve Krueger, Ron Logan, Aaron Booy, and Karmen Martin conducted field investigations of the pump station locations and alternative alignments in October 2006, and August and October 2007. The on -site investigation of wetlands followed the methods outlined by the Washington State Wetlands Identification and Delineation Manual (Ecology Publication No. 96-94, March 1997), which is consistent with the methodology used to identify and define wetlands using the 1987 Corps of Engineers Wetlands Delineation Manual. The reconnaissance was performed during the late growing season after a period of low rainfall. Visual observations and soil investigations were made from existing utility easements and right-of-way. No formal data plots were established. Results Pump Station Site 9 Adolfson staff investigated both sides of the paved road that provides access to the existing pump station from South 359g' Street. Our investigation focused on approximately 100 feet from the edge of pavement. The areas investigated are shown on Figure 2 and identified as "pump station study area." On the west side of the access road, we identified a forested wetland that covers the majority of the pump station study area. The boundary of the wetland is located approximately 25 feet from the edge of the access road for the entire road length, between South 359 h Street and the existing pump station. Given the footprint needed for the pump station, avoiding this large forested wetland would not be feasible. On the east side of the access road, a stream and forested wetland are present, but are located further from the edge of the pavement. The stream is a seasonal channel that connects to West Hylebos Creek to the east. The wetland boundary is closer to the access road at the southern end of the access road (near the existing pump station). Two potential sites for the pump station were identified on the east side of the access road: Site lA and Site 1B. Pump Station Site IA. Near South 359 b Street, the wetland boundary appears to be at least 100 feet from the edge of the pavement of the access road. Construction of the pump station at this location appears feasible and would avoid direct impacts to the wetland (Photo 1). Pump Station Site 1B. North of the existing pump station is an area of historic fill that does not exhibit wetland conditions.. A narrow ditch or swale is adjacent to the paved road on the east side located just north of the existing pump station. The swale conveys surface flows and meets wetland criteria. Construction of the pump station at this -location also appears feasible as it would avoid impacts to the larger wetland associated with the stream, but would result in impacts to the narrow swale wetland (Photo 2). Both Site lA and Site 1B would result in wetland buffer impacts and require review and approval by the City of Federal Way Department of Community Development under the City's Critical Areas Regulations. If either site is selected, several options are available under the City's Critical Areas Regulations (Federal Way Municipal Code (FWMC 22-1359). Under FWMC 22-1359(c) Structures, Improvements and Land Surface Modification within Regulated Wetland Buffers, the Director of Community Development may permit the placement of a public utility or other public improvements in a regulated wetland buffer if it is determined that no feasible or alternative location exists "based on an analysis of technology and system efficiency." The specific location and extent of the intrusion into the buffer must constitute the minimum necessary encroachment to meet the P33 Preliminary Evaluation 3 December 24, 2007 requirements of the public facility or utility. Other options may be available, including buffer averaging (FWMC 22-1359(b)) and would need to be discussed with the Department of Community Development. Site 1B would require placement of fill in the narrow swale wetland north of the existing pump station. This would trigger review by the U.S. Army Corps of Engineers (Corps) and the Washington Department of Ecology (Ecology) under Section 404 and Section 401 of the Clean Water Act. A Nationwide Permit (NWP) from the Corps would likely be required. The appropriate NWP would be determined by the Corps upon their receipt and review of a completed JARPA application. Because a Corps permit would be required, Endangered Species Act (ESA) Section 7 review requirements would be triggered. The timeline for review/issuance of a Corps NWP (including an ESA Biological Evaluation) varies considerably, but generally granges from four to nine months from submittal of permit application to issuance. This wetland is likely below the size threshold (2,500 square. feet) for regulated wetlands in the City of Federal Way. Locating the new pump station closer to South 359'h Street (Site 1A) would avoid any direct wetland impacts and would thereby avoid the need for a federal permit. Photo 1— Site IA: Area of upland on east side of access road (from access gate at S 3591 Street facing SE) P33 Preliminary Evaluation 4 December 24, 2007 Photo 2 — Site 1B: North side of existing pump station: Narrow wetland Swale is present parallel to road. Pump Station Site 2 Adolfson investigated undeveloped portions of a private parcel that abuts Pacific Highway South (Figure 2). Investigations extended approximately 100 feet west of the edge of road pavement. Approximately 50 feet from the road, a stream originates from a spring near the center of the site. The stream flows to the south and provides hydrology for an emergent wetland that extends west and south. Construction of the pump station at this location would result in direct impacts to wetlands and streams. Unlike the allowances in the critical area regulations for utility construction in wetland buffers (described in relation to Pump Station Site 1), there are no similar allowances or provisions within the City's critical areas regulations for utility improvements within regulated wetlands. It is expected that a "Modification" from critical areas requirements under FWMC 22-1358(d) would be required using City permit process IV. Permit process IV requires a public hearing and a Hearing Examiner's decision. Mitigation for wetland impacts would also be required. This process is lengthier than the critical areas -review described for Pump Station Site 1 and would be costlier in terms of providing mitigation for wetland impacts. In addition to City requirements, the excavation or the placement of fill in wetlands would trigger review by the Corps and Ecology under Section 404 and Section 401 of the Clean Water Act as described above for Pump Station 1B. ESA Section 7 review requirements would also be triggered. In addition, if the stream were impacted by construction, a Hydraulic Project Approval (HPA) would be required from Washington Department of Fish and Wildlife (WDFW) for any in -water work. P33 Preliminary Evaluation 5 December 24, 2007 Force Main Alternative 9 Alternative 1 includes construction of the pipeline entirely within built roads or road shoulders with the exception of a small section at the intersection of 15t Avenue South and South 348'h Street (see Figure 2). At this location, the pipeline alignment is proposed within an existing utility easement located below street elevation, west of 1st Avenue South. We were able to locate the easement corridor by locating manholes in the field. No wetlands appear to occur within the easement or adjacent to the easement. Hylebos Creek is located west of the easement, flows south and eventually crosses below I' Avenue South through a culvert. Alternative 1 crosses Hylebos Creek and associated wetlands where it flows under South 356" Street. At this location, we understand that the pipeline would be constructed using directional drill methods that would bore under the existing culverts along the outer edge of the right-of-way. Boring under both streams and associated wetlands would avoid impacts, but could require an HPA from WDFW. Staging areas for drilling equipment would also need to be located outside of wetland and stream buffers to avoid impacts to these locally regulated critical areas. Force Main Alternative 2 Alternative 2 includes construction within an existing 10-foot easement that parallels an unnamed stream between South 351" Street and South 348" Street (see Figure 2). During our investigation, the stream was dry through the entire section. No wetlands appear to be associated with the stream in the southern half of the corridor. In the northern half, the stream channel widens and forested wetland is present on both sides of the stream. We found pink flagging in the field (dated 12/5/05 by Parametrix, Inc.) marking the edge of the wetland and the ordinary high water mark of the stream and agreed with the flag locations. Wetland areas do not appear to extend into the easement corridor east of the stream. Thus, it appears that construction of the pipeline would only result in impacts to stream buffer and would likely be granted an exception or variance from the City of Federal Way, We recon—uncnd limiting tree rt,rnm,al to the greatest extent possible in. this section. A -portion of the alignment would parallel an existing 10-inch force main located in an easement that occurs just east of Pacific Highway South. We were able to locate the easement corridor by observing orange stakes that mark the corridor centerline. A scrub -shrub and emergent wetland is present within the easement corridor for approximately 175 feet between South 359ffi Street and a gravel pullout east of the highway (see Figure 2). The wetland appears to extend to the east eventually connecting to Hylebos Creek. At this location, the pipeline would be constructed entirely within the road prism and would avoid impacts to the wetland. P33 Preliminary Evaluation 6 December 24, 2007 Photo 3 — Stream at South 34e Street (I0-footeasement to right of stream) Force Main Alternative 3 Alternative 3 follows an existing pipeline in a 20-foot wide easement through The Reserve apartment complex (see Figure 2). No wetlands or streams occur within or near the easement. South of the apartment complex, the alignment turns east and extends downslope through upland forest dominated by large conifer trees. The alignment continues through forested areas until connecting to 1 ' Avenue South. The forest is primarily composed of mature Douglas fir and western hemlock with some western red cedar also present. Construction along this alignment would potentially impact a large number of these mature trees. No wetlands or streams were located in this area. The remainder of the alignment follows the route described under Force Main Alternative 1 above. This alternative would cross Hylebos Creek at multiple locations, including one on S 356 h Street and two places on 1" Avenue S. It is our understanding that the District intends to directionally drill below or construct the pipe over the culvert sections of Hylebos Creek at all crossings. Boring under both streams and associated wetlands would avoid impacts, but could require an HPA from WDFW. Staging areas for drilling equipment would also need to be located outside of wetland and stream buffers to avoid impacts to these locally regulated critical areas. P33 Preliminary Evaluation 7 December 24, 2007 Force Main Preferred Alternative A Preferred Alternative was identified by the District in September 2007 and is shown on Figure 2. The Preferred Alternative follows much of the same route as the alignment sections described under Alternatives 1, 2 and 3 above. Near The Reserve apartment complex, this alternative would utilize existing roads/driveways to avoid construction through the mature conifer forest. No additional wetlands were identified along this alignment during, our October 2007 field investigation. The route would cross Hylebos Creek at multiple locations, including one on S 356`h Street and two places on l�` Avenue S. It is our understanding that the District intends to directionally drill below or construct the pipe over the culvert sections of Hylebos Creek at all crossings. Boring under both streams and associated wetlands would avoid impacts, but could require a HPA from WDFW. Staging areas for drilling equipment would also need to be located outside of wetland and stream buffers to avoid impacts to these locally regulated critical areas. 24-inch Gravity Sewer Line Construction of the 24-inch gravity sewer line within the built right of way of 359"' Street (see Figure 2) would avoid impacts to wetlands, streams, and wildlife habitat. Construction within the access road to the pump station site would similarly avoid impacts. Construction of the connection point from the access road to the pump station would have the same issues as discussed above for Pump Station Sites IA and 1B. Alternatives Evaluation Summary. Pump Station Site Based on our investigation of the two pump station sites, the least encumbered location for a new pump station would be at Pump Station Site 1 on the east side of the paved access road and abutting South 359s' Street (Site 1 A). At this location, construction of the pump station would likely result in wetland buffer impacts, but not in impacts to wetlands or streams. Placement of the pump station as close as possible to the existing road would minimize the amount of buffer impacts. Locating the new pump station on the north side of the existing pump station (Site 1B) would likely result in some minimal impacts to the wetland swale located next to the paved road, as well as buffer impacts. The wetland is very small and likely below the size threshold (2,500 square feet) for regulated wetlands in the City of Federal Way. However, placement of fill in the wetland Swale would require permit review by the U.S. Army Corps of Engineers and Washington Department of Ecology under Section 404 and Section 401 Clean Water Act requirements and compliance with Section 7 of the Endangered Species Act, Impacts to the buffer at either pump station location at Site 1 would require review and approval under the City of Federal Way Critical Areas Regulations. As part of the project's review under the critical areas regulations, the District will need to establish that no feasible or alternative location exists based on an analysis of technology and system efficiency and that the location constitutes the minimum necessary encroachment into the wetland buffer to meet the utility requirements (FWMC 22-1359 (c)). We recommend that we discuss these requirements with the Department of Community Development during Task 2 to establish the requirements and criteria. Force Main Alignment Based on our investigation of the four force main alternative alignments, the alternative that would have the least impacts to wetlands and streams would be the Preferred Alternative. Alternatives 1, 3 and the Preferred Alternative would all have crossings of Hylebos Creek that would be bored, but could require an IPA from WDFW. P33 Preliminary Evaluation a December 24, 2007 Alternative 1 would have stream buffer impacts in the northwest portion of the alignment. All other impacts would be avoided as long as directional drilling and staging on South 356"' Street occurs outside wetland and stream buffers. Alternative 2 would result in buffer impacts to the stream in the northeast portion of the alignment, north of South 3515t Street. Construction of the pipeline would require removal of trees in the riparian area of the stream. While Alternative 3 would not involve impacts to any wetlands, streams, or their buffers, it would require extensive tree removal. The Preferred Alternative utilizes existing roads/driveways to avoid extensive tree removal and impacts to wildlife habitat in its northern portion. Impacts to wetland and streams and wetland and stream buffers would be avoided as long as directional drilling and staging areas occurred outside of these areas. None of the alternatives are expected to have impacts on threatened or endangered species. Impacts to listed fish species should not occur if all in. -water work within streams is avoided. 'Based on this review, the Preferred Alternative would be the only alternative to avoid wetland, buffet, and. significant tree impacts and is, therefore, expected to have the lowest degree of permit complexity. The highest degree of permit complexity is associated with Alternative 2; however, we do not anticipate that permitting would be a significant obstacle to completing the project. Under the City of Federal Way's Critical, Area Regulations, mitigation is required to restore or improve critical areas to offset these impacts. It appears that. mitigation can be accomplished onsite through restoration and/or enhancement. Within the next ten years, the City of Federal Way is planning to make major improvements to both 1" Avenue and 356"' Street along the potential alignments for Alternative 1, 3, and the Preferred Alternative. These road improvements could cause disruption or require the District to make modifications to sewer systems located within these roads. Alternative 2 would avoid these planned road improvements / utility conflicts. Summary of Impacts r Direct Buffer Stream Wetland: I Impacts Crossmgs j Impacts Pump Station Site Pump Station Site lA (abutting X 359") Pump Station Site 1B (north of X X existin PS site) Y _ Puma Station Site 2 X X Force Main Alternatives Force Main Alternative 1 Force Main Alternative 2 Force Main Alternative 3 Force Main Preferred Alternative X X X Significant Tree Impacts X �— X X X _l Planned Road Improvements / Utiility Conflicts X X X P33 Preliminary Evaluation 9 December 24, 2007 Limitations Within the limitations of schedule, budget, and scope -of -work, we warrant that this study was conducted in accordance with genemily accepted environmental science practices, including the technical guidelines and criteria in effect at the time this study was performed, as outlined in the Methods section. The results and conclusions of this report represent the authors' best professional judgment, based upon information provided by the project proponent in addition to that obtained during the course of this study. No other warranty, expressed or implied, is made. P33. Preliminary Evaluation 10 December 24, 2007 References City of Federal Way. 2005. City of Federal Way Critical Areas Maps, Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. Technical Report Y-87-1, U.S. Army Eiqveer Waterways Experiment Station, Vicksburg, Massachusetts. Snyder, D.E., P.S. Gale, and R.F. Pringle. 1973. Soil Survey of King County Area, Washington. U.S. Soil Conservation Service, Washington, DC. USFWS (U,S, Fish and Wildlife Service). 1987, National Wetland Inventory (NWI) poverty Pay quadrangle, WDF'W (Washington Department of Fish and Wildlife). 200.7. Priority Habitats and Species (PHS) database ,search. 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