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20-104351_Wetland Survey-11-06-2020 v1Shelterwood Consulting 7716 - 32nd Ave NW Seattle, WA 98117 8655 - Nahahum Canyon Rd. Cashmere, WA 98815 206.571.4249 September 18, 2018 Mr. Matt Chantry Director, Asset Management, Developer Shelter Resources, Inc. 2223 112th Ave NE, Suite 102 Bellevue, WA 98004 Re:276th and Pacific Highway S., Federal Way — undeveloped lots Dear Matt: Enclosed with this letter please find the limited wetland survey of King County Assessor lots nos: 7204800172 and 7204800174. As you can see, we were unable to locate any wetlands on the site. The evaluation begins with vegetation identification and the determining whether any hydric soils exist on site. This site did not meet any of the threshold keys for a wetland. The site has a history of being highly disturbed by human activities, including at the present time being used as a dump site and probably homeless encampment. If either you or King County have any questions or need any further information, please do not hesitate to contact me. Thank you for your consideration. Sincerely, Kim McDonald, Principal SHELTERWOOD CONSULTING Limited Wetland Survey of Two Parcels near 276th and Pacific Highway S. Federal Way, King County, Washington Shelter Resources, Inc. Kim McDonald, PhD Principal, Shelterwood Consulting 206.571.4249 shelterwood55@comcast.net Project No: 78434
 1 Table Of Contents: Executive Summary 3 Legal Description and Site Information 5 Delineation Methods and 7 Assessment of Wetland Presence Conclusions 9 Exhibits: 10 US Army Corps of Engineers Wetland Determination Data Form - Western Mountains, Valleys and Coast Region King County Flood Plain and Critical Areas Map City of Federal Way Critical Areas Map Soil map USFWS National Wetland Inventory Map of Area Photos of site Shelterwood Consulting biographic information
 2 EXECUTIVE SUMMARY Shelterwood Consulting was retained by Shelter Resources, Inc (SR) to provide a limited wetland survey of two parcels located in Federal Way, King County, Washington. Since we were retained to provide a limited wetland survey or assessment, formal classification under the Washington State Wetland Rating System for Western Washington was not completed. However, in site work and evaluation, the Army Corps of Engineers Wetland Determination Data Forms for Western Mountains, Valleys, and Coast Region was used as well as the Washington State Wetland Rating System. Site work was done on September 13, 2018. Three soil pits were dug to depths of twenty inches Vegetation was identified during the site visit and hydrology of the site was mapped pursuant to the requirements of the Army Corps of Engineers. During the site work, no surface water was present. The site itself has been extensively disturbed from recent development of adjacent building sites and is currently disturbed by significant human caused debris and possible homeless encampments. The western side of the site is fenced with a chain link fence and the eastern portion of the site is only accessed through private property, so we accessed the site on the northern side through a King County Park/Ride/Transit facility. Preliminary work included reviewing the National Wetland Inventory Map of the two parcels as well as the King County critical habitat designations. We also reviewed historic aerial photographs of the area, soils maps from the US Soil Survey, maps of flood zones, watershed information from Washington Department of Ecology. Our findings show that while some mature vegetation on the site is classified as “facultative” of wetlands, there is neither the hydric soil indicators nor any hydrologic indicators of a wetland. The presence of “facultative” vegetation is also an indication of the severity of prior disturbances to the site (as well as the prevalence of invasive species). 3 We were on site for 4.5 hours. As noted above, assessing the site was somewhat difficult due to access issues as well as the amount of human caused debris scattered throughout the site. We prepared plots and conducted a thorough vegetation inventory, dug three soil pits, examined the site for indications of the hydrology, all required under the Army Corps of Engineers Wetland Determination Data Form — Western Mountains, Valleys, and Coastal Regions. This determination is the threshold, if no wetland can be determined using the Army Corps data requirements, then there is no further requirement to rate the non-existent wetland under the Washington State Wetland Rating System - Western Region. However, in our site work and data analysis, we did review the site using the Washington Wetland Rating System for Western Region, attempting to determine if the site was possibly a slope or depression, both types of wetlands. Based upon our soil, vegetation, hydrology, and Wetland Rating System, we concluded there are no wetlands on this particular site. The soils show no hydric indicators, there are no indicators of any wetland hydrology. Using the vegetation methods, there does not seem to be wetland vegetation. However, this is a highly disturbed site and it is not unusual in disturbed sites for certain species such which are FAC to develop until more upland species are able to thrive. This site is a highly disturbed site with significant invasive species populations. Despite the fact the site is located in a watershed with Clean Water Act §303(d) and TDML issues, the lack of any wetland indicators does not make this site suitable for classification under the Washington State Wetland Rating System for Western Washington.
 4 LEGAL DESCRIPTIONS Tax Assessor’s # 7204800172 Legal Description: REDONDO HEIGHTS UNREC VALUE OF UNDEEDED STS & ALLEYS INCL IN ADJ LOT VAL POR LOT 24 & ADJ UNDEEDED ST DAF- E 1/2 OF NE 1/4 OF SW 1/4 OF NW 1/4 LESS POR SLY OF LN RNG W FR E LN 207 FT N FR SE COR TAP ON W LN 205 FT N OF SW COR STR 33-22-04 Lot size: 3.45 acres Elevation: 404’ 276th and Pacific Highway South Tax Assessor’s # 7204800174 Legal Description: REDONDO HEIGHTS UNREC POR E 1/2 OF NE 1/4 OF SE 1/4 OF NW 1/4 STR 33-22-04 DAF: BEG SE COR THOF TH N ALG E LN 207 FT TH W TO PT 205 FT N OF SW COR TH S 205 FT TH E TO POB Elevation: 404’ 276th and Pacific Highway South 5 DELINEATION METHODS Site visitation and field work occurred on September 13, 2018. The time during the field work was without precipitation and air temperature was around 63°. Prior to field work, satellite photos including historic data, was obtained through Google Earth/ Pro. During the initial field work, a complete tour of the site was made and after field work at the site, a complete inspection was made of the watershed within a 5 mile area. After the initial review of the area, plots were created. Vegetation inventories were made within 10’ radius for all classes of vegetation. The inventories were recorded on data sheets. Three soil pits were dug to 20” in the field. A thorough field examination for redox or other field indicators of hydric soils was made. The results of the three soil pits were recorded on data sheets. A thorough examination looking for any indications of surface water and several transects were made through the vegetated area and no surface water was found. Because the initial assessment revealed there was not a wetland present on site, a second inspection of the site was conducted prior to completing the field visit. Photographs of the site were taken and are attached in the Exhibits.
 6 WETLAND DELINEATION AND CLASSIFICATION The site is a highly disturbed two suburban lots, with adjacent developments of a large apartment complex to the west and a King County Transit facility to the north. This site is completely vegetated and appears to be currently used for dumping human debris and possible homeless encampment sites. In order to adequately assess the site, the Rating Summary forms from the State of Washington for Western Washington as well as the Army Corps of Engineers Wetland Determination Data Form for Western Mountains, Valleys, and Coastal Regions were used. It is standard practice to evaluate the site using the Army Corps of Engineers Wetland Determination Form prior to making any evaluation using the Washington state Wetland Rating System. In other words, the Corps Determination forms are the threshold. Because of the site location the site was assessed using the Wetland Determination Data Form - Western Mountains, Valleys, and Coastal Regions prior to determining whether the Washington State Wetland Classification Rating System - Western Washington should be used and if so, what “type” of wetland was present. The whole area was heavily vegetated with a dominance of mature hardwoods such as Alnus rubra (Red Alder) and Acer macrophyllum (Big leaf maple) and soft woods such as Pseudotsuga menziesii (Douglas fir) and Thuja plicata (Western red cedar). The understory was completely dominated by Rubus armeniacus (Himalayan blackberry) which is listed as an invasive species in King County, Washington. Most of the vegetation is in the tree stratum. Of these, two were FAC, and the rest were FACU. All vegetation were checked in the the Army Corps of Engineers( Western Mountains, Valley, and Coastal Regions (2016). There were only two species of Shrub stratum, Rubus armeniacus (Himalayan blackberry) and Cytisus scoparius (Scotch broom). The Rubus armeniacus is FAC and the Cytisus scoparius is UPL by default as not being listed. In analyzing the vegetation indicators, it is clear that some of the vegetation are wetland FAC. However, since this is a highly disturbed site, it is not unusual to find wetland indicator vegetation as developing in disturbed situations. 7 The next wetland indicator is soils. The 20” soil pits were dug. Since the soil was dry, a spray bottle was taken into the field to apply water in order to determine color using the Munsell Soil- Color Charts (2009 revised). The soil appeared well drained, showing no redox features. It was silty loam in texture and for the first 12” horizon at both sites the color, when moist, was 10YR 3/2 and for the next 8” was 10YR 3/2. There was some woody material in the soil samples, small roots perhaps indicating disturbed and plowed soils. The soils are Alderwood gravelly sandy loam (AgC) which is a moderately well drained glacial deposit soil. There were no signs of redox or any other hydric soil indicators. The soil until the depth of 20” was moderately fine in structure, slightly hard, and friable. There were many fine roots and a few small pebbles in the horizons. This type of soil is common in Western Washington, found in woodlands, pastures, orchards, vineyards; in other words, the well drained soils are good for vegetation growth. During the transects, time was spent looking for wetland hydraulic indicators. There were no watermarks, water stained leaves, saturation (no water seen), no thin muck surface, and after 20” in the soil pits, the water table was not found. In reviewing aerial photographs, including historic photos from 1996 to present day, inundation at the site is not visible. In doing wetland delineations the next step is to rate the wetland and depending upon location, use either the wetland rating system for Western or Eastern Washington. While the potential site has a slight depression and a slight slope, due to the lack of other wetland indicators in the Army Corps of Engineers Wetland Determination Data Form, the area does not need to be rated for either of these classifications. 8 CONCLUSIONS This site is very disturbed from adjacent development (and possible stormwater drainage into the site), prior human use, and current human disturbance with debris and probably homeless encampments. After a prolonged site visit with extensive field work, it was determined that a wetland does not exist on the site. While there are clearly wetland vegetation species present, they do not dominate the site per Army Corps of Engineers requirements and are no other indicators of wetland hydric soils nor any hydrologic indicators. 
 9 EXHIBITS 10 SHELTERWOOD CONSULTING Shelterwood Consulting has been providing natural resource and environmental consulting since 2001 for a variety of clients throughout Washington State. Kim McDonald, the principal of Shelterwood, has a Masters in Forestry and a PhD in Natural Resource Management. Her bachelors was a joint degree in English and Botany. She also holds a law degree. She has been certified by the State of Washington Department of Ecology on the Washington State Wetland Rating System for both eastern and western Washington (2014, 2015), as well as the Debit/Credit Method for Wetland Mitigation and delineating the Ordinary High Water Mark for eastern Washington. She is certified in identifying hydric soils by the US Army Corps of Engineers. In addition she has years of experience working on low impact stormwater management. Shelterwood Consulting has worked for a wide range of clients, including non-profit camps, tribes, vineyards, orchards, Vulcan Real Estate, and land trusts. Dr. McDonald currently sits on the Hydraulic Permit Advisory Committee for Washington Department of Fish and Wildlife and works closely with Trout Unlimited on in-stream mining issues. She is also a member of the Society of Wetland Scientists and Society of American Foresters (listed as a consulting forester for the Washington State Chapter).