21-104125-Critical Areas Report-9-28-22WETLAND DELINEATION • MITIGATION DESIGN • COMPLIANCE MONITORING
September 21, 2022
Project No. 20030
VSM
Attention: Sikander Sekhon
PO Box 1226
Kent, Washington 98035
Regarding: Critical Area Report: Wetlands and Streams
Proposed VSM Plat - Federal Way, Washington
Sikander,
1.0 INTRODUCTION
This critical area report has been prepared for the proposed VSM Plat located in Federal Way,
Washington. The project includes the subdivision of two existing residential properties into eleven
residential lots. Plat improvements encroach the outer limits of a Type Ns stream buffer and several
Category IV wetland buffers. To offset proposed buffer impacts 10,831 sf of combined wetland and
stream buffer enhancement is proposed. This report has been prepared per Federal Way Revised Code
(FWRC) 19.148.080 to address wetland and stream buffer impacts and should be reviewed in combination
with the mitigation plan entitled “Wetland and Stream Buffer Mitigation Plan – VSM Plat” dated
September 21, 2022 and all subsequent revisions.
2.0 REPORT AUTHORIZATION, SCOPE OF SERVICES, & QUALIFICATIONS
Authorization to prepare this report was granted by Sikander Sekhon on August 29, 2022. This report has
been prepared per the critical area reporting requirements established in FWRC 19.148.080 to describe
existing wetland and stream conditions as well as proposed impacts and buffer enhancements. The
qualifications I maintain to complete this report include a Bachelor of Science degree in Environmental
Science, certification as a Professional Wetland Scientist (PWS), and nearly 24 years of environmental
consulting experience within the Puget Sound area of Washington State.
3.0 PROJECT SITE & LANDSCAPE SETTING
The project site includes the developed residential properties located at 2625 and 2641 S 298th Street in
Federal Way, Washington. The sites exist within the southeast quarter of Section 4, Township 21 North,
Range 4 East, W.M. King County tax parcel numbers for the two properties are 768380-0280 and 768380-
0290. The project site has a total area of 177,756 SF (4.08 AC) and compromises flat to gently sloping
land. Two primary residential structures and several accessory residential structures exist within the site.
PO Box 1721
Issaquah, Washington 98027
(425) 677-7166
www.evergreenarc.com
Critical Area Report: Wetlands and Streams
Proposed VSN Plat – Federal Way, Washington
Page 2
Vegetation throughout the site is predominantly grass with scattered trees. Land use surrounding the site
is principally single-family residential, though Wildwood Elementary School is located southwest of
project site and Laurelwood Park is located northwest of the site.
4.0 CRITICAL AREAS
A Type Ns stream and four Category IV wetlands exist in a low lying area located within the western portion
of the project site. Wetland and stream conditions were assessed in January 2021 and summarized in a
“Critical Area Delineation and Rating Report” dated March 15, 2021. Delineated wetland and stream limits
were surveyed by Encompass Engineering and Surveying and are shown on applicable engineering and
design drawings prepared for the VSM plat.
The Type Ns stream is a low gradient linear aquatic feature that measures an average of three feet wide by
six inches deep. The stream drains to the northwest across the project site. Stream flow is derived from the
concentration of stormwater generated by impervious surfaces in the residential subdivision located south
of the project site. A 35 foot wide buffer extends away from the ordinary high water mark (OHWM) of the
stream and a 15 foot setback is required from the outer limits of the stream buffer for buildings and other
structures.
Four Category IV wetlands exist within shallow landforms along the Type Ns stream. Vegetation within the
wetlands is dominated by tall fescue (Festuca arundinacea, FAC) with occasional
creeping jenny (Lysimachia nummularia, FACW), common rush (Juncus effusus, FACW), bird’s-foot
trefoil (Lotus corniculatus, FAC), and creeping buttercup (Ranunculus repens, FACW). The wetlands were
assigned a Category IV rating based on a total score of 15 that they received for functions. Category IV
wetlands have the lowest level of functions because they are often heavily disturbed or otherwise
significantly altered from a natural condition (Hruby 2014). A 50 foot buffer extends away from the
delineated limits of each wetland and a 15 foot setback is required from the outer limits of each wetland
buffer for buildings and other structures.
5.0 PROPOSED PROJECT
The proposed project includes clearing, grading, and platting of the project site to accommodate the
construction of eleven new single-family lots, a stormwater tract, a critical area tract, a public access road,
and utilities. New residential lots will be consolidated in the central and eastern portion of the site. A new
access road as well as water and sewer services will extend south from S 298th Street to serve the new
residential lots. The existing residence on parcel 768380-0280 will be retained within Lot 1. Ten new
single-family homes will be constructed on the remaining lots. Street frontage improvements will occur
along S 298th Street, though frontage improvements located in the northwest corner of the site have been
included with the proposed project in concept only. The plat developer plans to apply for an exemption
or variance during final engineering design to eliminate the frontage improvements in the northwest
corner of the site.
Stormwater generated by new impervious surfaces within the plat (i.e., rooftops, sidewalks, driveways and
roads) will be routed to a new stormwater pond located near the southern property line in the central
Critical Area Report: Wetlands and Streams
Proposed VSN Plat – Federal Way, Washington
Page 3
portion of the plat. The detention pond will be bordered by the critical area tract to the west, Lot 4 to the
north, and Lot 5 to the east. The pond will provide a total detention volume of 34,050 CF. A four foot by
twelve foot Oldcastle BioPod water quality vault will be located upstream of the detention pond to
provide enhanced basic water quality treatment of stormwater that is directed towards the pond. The
pond will outlet via a control structure (dispersion trench) located west of Lot 3 and Lot 4. The dispersion
trench and related piping will be located within an easement. The proposed stormwater pond and outlet
structure encroach the outer portion of the Type Ns stream and Category IV wetland buffers.
6.0 CRITICAL AREA IMPACTS
Unavoidable critical area impacts related tot the proposed project include the construction of stormwater
infrastructure along the outer portion of a Type Ns stream buffer and the outer portion of several
Category IV wetland buffers. Work will include excavation and grading to construct the stormwater pond,
the stormwater pond emergency overflow, and the related dispersion trench and piping. Total buffer
impact area is 2,305 sf, which includes overlapping wetland and stream buffers. Wetland buffer impact is
2,186 sf and results in a localized reduction of the standard 50 ft wetland buffer to a minimum width of
37.5 feet. Stream buffer impact is 505 sf and results in a localized reduction of the 35 foot standard
stream buffer to a minimum width of 25.6 feet. Currently, the buffers support gently to modestly sloping
topography vegetated with a mixture of pasture grasses and occasional herbaceous weeds.
FWRC 19.145.130 requires an applicant to apply sequential measures (“mitigation sequencing”) to reduce,
avoid, and mitigate impacts to critical area buffers. The location, size, and type of the proposed
stormwater control infrastructure has been designed per the latest edition of the King County Surface
Water Design Manual and the City of Federal Way’s Addendum to the King County Surface Water Design
Manual. The location and type of infrastructure is based on engineering and design considerations such
as topography, soil conditions, hydraulics, water quality and detentions standards, and proximity to plat
development. The proposed stormwater control infrastructure completely avoids work within the on-site
wetlands and the stream and buffer impacts have been minimized by consolidating the proposed
infrastructure along the outer portion of the related buffers. The proposed infrastructure will be
constructed using high quality/low maintenance materials to ensure sustainability over time. A
geotechnical assessment by Earth Solutions NW, LLC (2022) determined that alternatives to the current
design such as infiltration were infeasible or potentially problematic due to existing soil conditions.
7.0 PROPOSED MITIGATION
A detailed mitigation plan has been prepared for the proposed project. The primary purpose of the plan
is to describe the proposed buffer enhancements necessary to offset unavoidable buffer impacts. Specific
mitigation goals, objectives, and performance standards are detailed on the mitigation plan. The overall
goal and objective of the mitigation is to enhance ecological functioning within retained wetland and
stream buffers located west of proposed plat development. The performance standards established on
the mitigation plan assess the specific physical attributes of the enhanced buffers to ensure the
completed work achieves the mitigation plan goals and objectives.
Proposed mitigation for wetland and stream buffer impacts includes the installation of dense native
Critical Area Report: Wetlands and Streams
Proposed VSN Plat – Federal Way, Washington
Page 4
plantings within 10,831 sf of retained overlapping wetland and stream buffer located west of proposed
buffer impacts. Given the combined proposed impact area of 2,305 sf, the resulting mitigation ratio is
4.71:1 (area of mitigation:area of impact).
The mitigation area currently includes modestly sloping topography vegetated with a mix of pasture
grasses and occasional herbaceous weeds. Proposed native plantings include a mix of trees and shrubs
installed per industry standards of nine feet on-center spacing for trees and six feet on-center spacing for
shrubs. The resulting net on-center spacing for the enhancement plantings is approximately five feet on-
center.
The proposed buffer enhancements ensure a diverse assemblage of native plants and high native plant
coverage. It is expected that over time, the plantings will develop into a native plant community typical of
the Puget Sound area of the western hemlock forest zone described by Franklin & Dyrness (1988), though
modified slightly to address the specific environmental conditions the currently exist on the site. The
proposed plantings will increase the distribution and abundance of native vegetation within on-site
buffers and will provide opportunities for ecological functioning that currently either does not exist or is
otherwise limited within on-site buffers.
Critical area signage and fencing will be installed at the reduced buffer limits along the limits of plat
improvements.
The proposed mitigation will be completed by the plat developer prior to final plat approval.
A maintenance and monitoring plan is included on the mitigation plan. This work includes specific
inspections and oversight by a qualified professional during construction as well as a detailed
maintenance and monitoring program. The maintenance program is designed to promote the successful
establishment and vigorous growth of the installed plants. The monitoring program is designed to
effectively evaluate the buffer enhancement and assess performance of the mitigation relative to the
standards established for the project.
A detailed contingency planning process is also included on the mitigation plan. Should monitoring
reveal that the performance standards are not met, appropriate contingency plans will be developed by
the landowner to address any deficiency.
8.0 WETLAND AND STREAM BUFFER FUNCTIONAL ANALYSIS
FWRC 19.145.330 requires that an applicant requesting stream buffer intrusions to demonstrate that the
remaining and enhanced stream buffer will function at an equivalent or higher level than the standard
buffer. Similarly, FWRC 19.145.440(6) requires that an applicant proposing wetland buffer reduction with
enhancement clearly substantiate that the enhanced buffer will improve and provide additional protection
of wetland functions and values. In both cases, buffer functions to be assessed include habitat, water
quality, stormwater retention, groundwater recharge, and erosion protection. This report section
describes how the proposed buffer mitigation satisfies the functional standards established in FWRC
19.145.330 and FWRC 19.145.440(6). For simplicity, the higher standard of “improvement and additional
protection” is applied to the assessment.
Critical Area Report: Wetlands and Streams
Proposed VSN Plat – Federal Way, Washington
Page 5
8.1 Habitat
Habitat functions are the ability of a buffer to provide space or conditions for reproduction, resting,
hiding, and migration as well as food production and delivery for riparian and wetland-dependent
birds, invertebrates, mammals, amphibians, and native fish. Suitable habitat for a wide range of native
fauna can be provided by a broad range of vegetation structures, high plant species richness, and the
interspersion of different habitat types (McMillan 2000; Sheldon et. al 2005). Existing habitat function
within on-site wetland and stream buffers is extremely limited because existing vegetation is limited
to a simple plant community comprising pasture grasses and herbaceous weeds. The proposed
mitigation improves and provides additional protection to habitat functions by requiring the
installation of dense native plantings comprising a diversity of tree and shrub species. The proposed
vegetation will develop into multi-layered plant community that will provide valuable habitat niches
and connectivity pathways for wetland/riparian dependent wildlife species.
8.2 Water Quality
Water quality functions are the ability of a wetland or stream buffer to filter and prevent sediment and
nutrients (primarily nitrogen and phosphorus) from entering a wetland or stream. Ideal filtering
conditions include gradual slopes, organic soils, and dense forest or grass vegetated areas with high
surface roughness coefficients (Sheldon et. al 2005; McMillan 2000; Mitsch and Goesselink 2000).
Existing water quality functions within on-site buffers are limited due to sloping landform and a
simple plant community comprising pasture grasses and herbaceous weeds of variable densities. The
proposed mitigation improves and provides additional protection to water quality functions by
requiring the installation of native plants, that once established, will provide the resilient vegetative
structure needed to physically filter sediments and increase the ability of the buffer to trap pollutants
through biological uptake.
8.3 Stormwater Retention
Stormwater retention functions are the ability of the buffer to trap and permanently store surface
water runoff. Stormwater retention functions require specific soil and topographic conditions to be
present. Neither of the required conditions exist within on-site buffers. The existing buffer slopes
towards the stream and wetlands and exists within mapped Alderwood gravelly sandy loam, 0 to 8
percent slopes (AgB) and Arnets, Alderwood material, 6 to 15 percent slopes (AmC) soil types. Both
soil types are classified as moderately well drained soils. Test pit #4 logged by Earth Solutions NW,
LLC (2022) just outside of the standard stream/wetland buffer documented the presence of a thin
topsoil overlying thick silty sand with gravel. The proposed project maintains existing soil and
topographic conditions. It is not possible to improve or provide additional protection of stormwater
retention functions without degrading or negatively affecting other buffer functions.
8.4 Groundwater Recharge
Groundwater recharge is the ability of a buffer to detaining and infiltrating surface water within buffer
areas. Test pit #4 logged by Earth Solutions NW, LLC (2022) just outside of the standard
stream/wetland buffer documents minimal root penetration within the upper one foot of existing soil
near the on-site buffer. Existing groundwater recharge functions within on-site buffers are limited
Critical Area Report: Wetlands and Streams
Proposed VSN Plat – Federal Way, Washington
Page 6
due to a sloping landform and the presence of a simple herbaceous plant community of variable
density that presents limited root penetration into existing soils. The proposed mitigation improves
and provides additional protection to groundwater recharge functions by requiring the installation of
dense native plantings with roots that will penetrate buffer soils to a depth greater than existing the
existing pasture grasses and herbaceous weeds. The density of proposed plantings combined with
the increase depth of root penetration will increase the ability of the buffer to infiltrate surface water.
8.5 Erosion Protection
Erosion protection is the ability of a buffer to limit the effects of erosion. The existing buffer is
vegetated by a variable density grass and herbaceous weed plant community. The proposed project
improves and provides additional protection to erosion protection functions by providing additional
physical structure (i.e., trees and shrubs) that will shield the soil surface from precipitation as well as
bind soil particles with the deep penetrating roots.
9.0 REGULATORY COMPLIANCE
9.1 Intrusion into Stream Buffers (FWRC 19.145.330)
The proposed project requires 505 sf of stream buffer impact and results in a localized reduction of
the 35 foot standard stream buffer to a minimum width of 25.6 feet. FWRC 19.145.330 requires
review of stream buffer intrusions by the City of Federal Way using Process III subject to the following
decisional criteria:
1. Stream buffer intrusions may be permitted with a buffer enhancement plan. The plan
shall provide an assessment of the following existing functions and conditions of the
buffer and the effects of the proposed buffer modification on those functions: (a) habitat;
(b) water quality; (c) stormwater retention capabilities; (d) groundwater recharge; and (e)
erosion protection.
See report section 8.0.
2. The City of Federal Way may approve a stream buffer intrusion based on the following
criteria:
(a) It will not adversely affect water quality.
The project conforms to this standard. The proposed stream buffer intrusion will not
adversely affect water quality because the proposed stormwater control infrastructure has
been designed per current engineering standards and the proposed buffer mitigation
provides resilient vegetative structure that increases the ability of the buffer to physically
filter sediments and trap pollutants.
(b) It will not adversely affect the existing quality of wildlife habitat within the stream or
buffer area.
Critical Area Report: Wetlands and Streams
Proposed VSN Plat – Federal Way, Washington
Page 7
The project conforms to this standard. The proposed stream buffer intrusion will not
adversely affect the existing quality of wildlife habitat within on-site buffers because the
proposed buffer impacts will occur along the outer portion of the buffer within areas of
low quality habitat and the proposed mitigation requires the installation of dense native
plantings within retained buffer areas.
(c) It will not adversely affect drainage or stormwater retention capabilities.
The project conforms to this standard. The proposed stream buffer intrusion will not
adversely affect drainage capabilities because the proposed stormwater control
infrastructure has been designed to match pre-development stormwater characteristics.
The proposed project will not adversely affect stormwater retention capabilities because
neither the soil nor topographic conditions exist within on-site buffers to provide
appreciable stormwater retention capabilities under existing or proposed conditions.
(d) It will not lead to unstable earth conditions nor create erosion hazards.
The project conforms to this standard. The proposed stream buffer intrusion will not lead
to unstable earth conditions nor create erosion hazards because appropriate temporary
erosion and sediment control best management practices will be employed during
construction and affected areas will be permanently stabilized following construction. In
addition, proposed native plantings within retained buffer areas will provide the physical
structure to shield the soil surface from precipitation and bind soil particles with deep
penetrating roots typical of native plant species.
(e) It will not be materially detrimental to any other property in the area of the subject
property nor the city as a whole.
The project conforms to this standard. The proposed stream buffer intrusion will not be
materially detrimental to any other property in the area of the subject property nor the
City of Federal Way as a whole because the purpose of the proposed buffer impacts is to
mitigate the effects of stormwater generated by the proposed plat. The proposed
stormwater control infrastructure has been designed to match pre-development
stormwater discharge durations and rates and a downstream analysis documented no
existing problems or limitations within the affected drainage subbasin. The proposed
project will preserve and protect the Type Ns stream and related buffer within a critical
area tract. The proposed stream buffer mitigation has been designed to offset proposed
buffer impacts by enhancing the ecological functioning of retained buffers.
(f) It Is necessary for reasonable development of the subject property.
The project conforms to this standard. The proposed stream buffer intrusion is necessary
for reasonable development of the subject property. Proposed site development has been
consolidated into the eastern and central portion of the site. The location and type of
Critical Area Report: Wetlands and Streams
Proposed VSN Plat – Federal Way, Washington
Page 8
stormwater control infrastructure is based on engineering and design considerations such
as topography, soil conditions, hydraulics, water quality and detentions standards, and
proximity to plat development. The proposed stormwater control infrastructure
completely avoids work within the on-site wetlands and the stream by locating the
infrastructure at the outer limits of each buffer and impacts have been minimized by
configuring the infrastructure along the outer limits of the buffer. A geotechnical
assessment by Earth Solutions NW, LLC (2022) determined that alternatives to the current
design such as infiltration were infeasible or potentially problematic due to existing soil
conditions.
9.2 Development within Wetland Buffers (FWRC 19.145.440.[6])
The proposed project requires 2,298 sf of wetland buffer permanent impacts and results in localized
reduction of the standard 50 ft wetland buffer to a minimum width of 37.5 feet. FWRC 19.145.440(6)
requires review of wetland buffer reductions with enhancement by the City of Federal Way using
Process III subject to the following decisional criteria:
(a) It will not adversely affect water quality.
The project conforms to this standard. The proposed wetland buffer reduction will not adversely
affect water quality because the proposed stormwater control infrastructure has been designed
per current engineering standards and the proposed buffer mitigation provides resilient
vegetative structure that increases the ability of the buffer to physically filter sediments and trap
pollutants.
(b) It will not adversely affect the existing quality of the wetland or buffer wildlife habitat.
The project conforms to this standard. The proposed wetland buffer reduction will not adversely
affect the existing quality of the wetland or buffer wildlife habitat because the proposed buffer
impacts will occur along the outer portion of the buffer within areas of low quality habitat and the
proposed mitigation requires the installation of dense native plantings within retained buffer
areas.
(c) It will not adversely affect drainage or stormwater retention capabilities.
The project conforms to this standard. The proposed wetland buffer reduction will not adversely
affect drainage capabilities because the proposed stormwater control infrastructure has been
designed to match pre-development stormwater characteristics. The proposed project will not
adversely affect stormwater retention capabilities because neither the soil nor topographic
conditions exist within on-site buffers to provide appreciable stormwater retention capabilities
under existing or proposed conditions.
(d) It will not lead to unstable earth conditions nor create erosion hazards.
The project conforms to this standard. The proposed wetland buffer reduction will not lead to
unstable earth conditions nor create erosion hazards because appropriate temporary erosion and
Critical Area Report: Wetlands and Streams
Proposed VSN Plat – Federal Way, Washington
Page 9
sediment control best management practices will be employed during construction and the
affected areas will be permanently stabilized following construction. In addition, proposed native
plantings within retained buffer areas will provide the physical structure to shield the soil surface
from precipitation as well as the ability to bind soil particles with deep penetrating roots typical of
native plant species.
(e) It will not be materially detrimental to any other property or the city as a whole.
The project conforms to this standard. The proposed wetland buffer reduction will not be
materially detrimental to any other property in the area of the subject property nor the City of
Federal Way as a whole because the purpose of the proposed buffer impacts is to mitigate the
effects of stormwater generated by the proposed plat. The proposed stormwater control
infrastructure has been designed to match pre-development stormwater discharge durations and
rates and a downstream analysis found no existing and potential drainage problems within the
affected drainage subbasin. The proposed project will preserve and protect the existing Category
IV wetlands and related buffers within a critical area tract. The proposed wetland buffer
mitigation has been designed to offset proposed buffer impacts by enhancing the ecological
functioning of retained buffers.
(f) All exposed areas are stabilized with native vegetation, as appropriate.
The project conforms to this standard. The proposed wetland buffer mitigation includes the
installation of dense native vegetation.
10.0 CLOSURE
The proposed VSM Plat includes subdivision of two existing residential properties into eleven residential
lots. Plat improvements encroach the outer limits of a Type Ns stream buffer and three Category IV
wetland buffers. To offset proposed buffer impacts 10,831 sf of combined wetland and stream buffer
enhancement is proposed. The project conforms to the buffer intrusion and reduction decisional criteria
established in FWRC 19.145.330 and FWRC 19.145.440(6).
Within the limitations of scope, schedule, and budget, the critical area consulting services summarized in
this report conform to the generally accepted standard of care in effect at the time the work was
conducted. No other warranty, express or implied, is made. The purpose of the work described in this
report is to describe site and impacts conditions per the City of Federal Way critical area regulations in
effect at the time of report preparation. All opinions presented in this report should be considered
preliminary until reviewed and confirmed by the City of Federal Way.
I trust that this report meets your present needs. If you have any questions regarding the information
presented in this report or require additional assistance with this project, please do not hesitate to call me
at (425) 864-3244 or email me at psuper@evergreenarc.com.
Critical Area Report: Wetlands and Streams
Proposed VSN Plat – Federal Way, Washington
Page 10
Sincerely,
EVERGREEN AQUATIC RESOURCE CONSULTANTS, LLC
Issaquah, Washington
Peter P. Super
Professional Wetland Scientist
Attachments:
1. Photographs of Buffer Reduction Area
11.0 REFERENCES
Castelle, A.J., C. Conolly, M. Emers, E.D. Metz, S. Meyer, M. Witter, S. Mauermann, T. Erickson, S.S. Cooke.
(1992). Wetland Buffers: Use and Effectiveness. Adolfson Associates, Inc. Shorelands and Coastal Zone
Management Program, Washington Department of Ecology, Olympia. Pub. No. 92-10.
Earth Solutions NW, LLC. 2022. Geotechnical Engineering Study: VSM Short Plat. Prepared for VSM.
January 13, 2022.
Encompass Engineering & Surveying. 2021. Preliminary Technical Information Report: City of Federal
Way for VSM Plat. Prepared for Sikander Sekhon. October 4, 2021.
Hruby, T. (2014). Washington State Wetland Rating System for Western Washington: 2014 Update.
Washington State Department of Ecology Publication #14-06-029. Olympia, Washington:
Washington State Department of Ecology.
King County. (2004). Best Available Science: Volume I – A Review of Scientific Literature. King County
Executive Report. Department of Natural Resources Division: Water and Land Resources Division.
February 2004.
McMilan. A. (2000). The Science of Wetland Buffers and Its Implication for the Management of Wetlands. MS.
Evergreen State Collage, Olympia, Washington. August 2000.
Mitsch, W.J. and J.G. Gosselink. (2000). Wetlands: Third Edition. John Wiley & Sons, Inc. June 2000
Sheldon, D., T. Hruby, P. Johnson, K. Harper, A. McMillan, T. Granger, S. Stanley, and E. Stockdale. (2005).
Wetlands in Washington State - Volume 1: A Synthesis of the Science. Washington State Department of
Ecology. Publication #05-06-006. Olympia, WA.
Critical Area Report: Wetlands and Streams
Proposed VSN Plat – Federal Way, Washington
Page 11
JANUARY 15, 2021 PHOTO SHOWING THE SOUTHERN PORTION OF WETLAND/STREAM BUFFER NEAR PROPOSED BUFFER
INTRUSION.
Critical Area Report: Wetlands and Streams
Proposed VSN Plat – Federal Way, Washington
Page 12
JANUARY 15, 2021 PHOTO SHOWING CENTRAL/NORTHERN PORTION OF WETLAND/STREAM BUFFER NEAR PROPOSED
BUFFER INTRUSION.