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ESA Memo Woodlands at Redondo Mitigation Plan ReviewFrom: Jessica Redman <JRedman@esassoc.com> Sent: Tuesday, June 16, 2020 9:50 AM To: Becky Chapin Subject: Woodlands at Redondo Mitigation Plan Review [EXTERNAL EMAIL WARNING] This email originated from outside of the City of Federal Way and may not be trustworthy. Please use caution when clicking links, opening attachments, or replying to requests for information. If you have any doubts about the validity of this email please contact IT Help Desk at x2555. Hi Becky, Please see below for ESA’s findings and recommendation on The Woodlands at Redondo Critical Areas Mitigation Plan: At the request of the City of Federal Way (City), ESA reviewed the Critical Areas Mitigation Plan – “Woodlands at Redondo” prepared by Sewell Wetland Consulting Inc. (dated April 1, 2020) for the property located off of Pacific Highway South and South 304th Street (Tax Parcels 042049012 & 042049221). The applicant proposes to construct a 68 lot residential subdivision with associated infrastructure, including a stormwater detention pond. To accommodate the proposed development, the applicant proposes to reduce the onsite wetland buffer by 18,674 square feet (SF). An additional 19,188 SF of buffer will be added to the northern side of the wetland buffer further downstream, resulting in a net increase of 514 SF of wetland buffer. ESA has reviewed this property twice before: First, in August 2019 when a site visit was conducted on August 28, 2019 to review the wetland boundary and the rating form submitted in a previous version of the critical areas report. The second review, a review of a revised version of the critical areas report, occurred in February, 2020. Findings of these reviews were presented to the City on memos dated September 6, 2019 and February 7, 2020, respectively. The mitigation plan under this current review is in response to the recommendations made by ESA in the February 7, 2020 review memo, where ESA recommended: 1) Buffer enhancement be proposed in the buffer addition area, and 2) A mitigation plan be developed for the buffer impacts along South 304th Street. In response to these recommendations, the applicant is currently proposing 2,589 SF of buffer enhancement along South 304th Street; 5,924 SF of buffer restoration in existing buffer (in the south end of the proposed project); and 2,788 SF of buffer restoration in the buffer addition area immediately adjacent to the detention pond. Enhancement and restoration activities include the removal of trash, controlling noxious weeds, and installation of native plants. ESA agrees with the buffer enhancement/restoration in the existing wetland buffer and along South 304th Street. However, it is unclear why only 2,788 SF of the 19,188 SF buffer addition area is being enhanced. The Mitigation Plan does not describe the current condition of the buffer addition area, inside or outside of where buffer enhancement is proposed. In order to ensure that the buffer averaging proposed will not result in an loss of ecological buffer function, ESA recommends that the applicant describe the current conditions of this area; describe the rationale of selecting the 2,788 SF restoration area and not enhancing the rest of the 19,188 SF area; and provide photos if possible. Please let me know if you have any questions. Thanks, Jessica Redman, PWS Associate Scientist ESA | Environmental Science Associates Celebrating 50 Years of Work that Matters! 5309 Shilshole Avenue NW, Suite 200 Seattle, WA 98107 206.789.9658 main jredman@esassoc.com | esassoc.com