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17-105489-Wetland Comment Response Letter-11-12-2021-V1 Wet.land, LLC Jennifer Marriott, PWS 15803 Bear Creek Parkway Unit E513 Redmond, WA 98052 10 October 2021 Jim Harris City of Federal Way Department of Community Development PROJECT: Woodbridge Business Park, Federal Way, Washington SUBJECT: Response to City Comments Dear Jim, The City provided comments on this Project in the spring of 2021. ESA outlined their review of this application in a letter dated 25 January 2021. The following is provided in response to those comments. The original comments are in normal font with responses following in bold font. 1. We agree with the wetland delineation boundaries, rating forms, and rating classifications established by Talasaea for wetlands occurring on the proposed project site. Noted. No further response. 2. We generally agree with the conceptual mitigation plan and believe that the proposed mitigation site appears to be an adequate location for wetland creation. As the mitigation design progresses, we continue to strongly recommend that the applicant perform further environmental investigations (groundwater level monitoring, soil analysis, etc.) at the proposed mitigation site to acquire the necessary data and information to inf orm mitigation feasibility and design. PAGE 2 The decision has been made to adjust the mitigation proposed to purchase credits through the King County In-Lieu Fee program so that mitigation through all agencies is consistent. An in-lieu fee plan is attached and outlines the total credits proposed to be purchased to offset critical area impacts. The Site Plan has been revised based on several factors that has resulted in a change in the wetland impacts proposed. The stormwater pond and wetland creation have been removed from the parcel east of Weyerhaeuser Way, so proposed direct wetland impacts have been reduced from 12,000 square feet to 8,492 square feet (0.19-acre) (see table below). No change to indirect wetland impacts proposed has changed. Figure 1. Revised Direct and Indirect Wetland Impact Table with Mitigation Calculations. 3. We agree that 38,901 SF or wetland creation is adequate for 19,901 SF of direct and indirect wetland impacts based on the guidance in Ecology’s Wetland Mitigation in Washington State – Part 1: Agency Policies and Guidance (2006) and FWRC 19.145.430(5). However, we recommend the applicant increase the proposed area of wetland creation by 5 to 10 percent of the total mitigation area (approximately 2,000-4,000 SF) to account for the risk of failure, uncertainties, and the temporal loss of original wetland functions and area, ensuring that the mitigation to impact ratios are successfully met. PAGE 3 The onsite wetland creation has been removed from the site plan. An in-lieu fee plan will be prepared instead outlining the purchase of mitigation credits to compensate for the proposed wetland fill. Mitigation moving forward will consist of the purchase of mitigation credits through the King County In-Lieu Fee Program and the buffer modifications and vegetative enhancements or restoration efforts proposed around the Project footprint west of Weyerhaeuser Way as described in the revised Mitigation Plan (attached). 4. The previous version of the critical areas report and conceptual mitigation plan (dated October 27, 2018) described 63 wetlands within the Project site. The Revised Report only discusses 48 wetlands within the Project site. ESA understands that six wetlands (Wetlands CB, CD, BE, BF, BK, and BL) are located on the parcel that was removed from the project (King County Tax Parcel Number 7978200520); and therefore, should not be included in the Revised Report. However, the Revised Report does not account for nine wetlands that were previously reported as occurring on the project site, and confirmed by ESA in the field. It is our recommendation that the Revised Report be corrected to include Wetlands CE, FA, KG, KH, KI, KJ, KK, KL, and KM or provide details on why they were omitted. The wetland boundaries, labels, and status have shifted over time. Wetlands KG, KH, KI, KJ, KK, KL, and KM were removed because these areas were reevaluated and removed from the plans due to their extremely small size. However, since these features were identified within the Boundary Line Adjustments (BLA) for this area, these seven (7) wetlands are being added back into the critical areas report. The attached revised Critical Areas plan sheets and mitigation plan have been revised to reflect the presence of these wetlands. The below table identifies each of the above listed wetlands and its status. Table 1. Summary of Missing Wetlands and Actions Wetland ID Reason Not Included in 2021 Documents Correction CE Determined to be stormwater feature – this feature was constructed and receives water from an outfall at the east side of W. Way South. It was believed that this feature connected to Wetland CB – but that was determined to be inaccurate. This feature was not included in any of the subsequent boundary line adjustment documents because of this fact. None FA Determined to not meet definition of a wetland. While this feature was included on the graphics of the initial Business Park application, note that this feature was later removed and was not included in the approved BLA. None KG These features were less than 50 square feet a piece that were flagged during very wet conditions and their delineations never adjusted accordingly once more normal Graphics adjusted to re-include these seven (7) wetlands. Rather KH KI PAGE 4 KJ conditions were present. However, these features were identified on the BLAs completed for this area, so are being readded to the report for consistency. than revise the report to add these small wetlands, an addendum to the Critical Areas Report has been prepared that includes the revised items in response to the comments within this letter. KK KL KM Wetlands KA, KB, KC, KD, KF, KN, KT, KU, KV, KW (previously included) and Wetlands KG, KH, KI, KJ, KK, KL, and KM (readded back in) These wetlands are a series of small slope and depressional wetlands that occur north of South 336th Street. These herbaceous wetlands are dominated by pasture grasses, typically a mix of rye (Lolium spp.), fescues (Festuca spp.), bentgrasses (Agrostis spp.), velvet grass (Holcus lanatus), sweet vernal grass (Anthoxanthum odoratum), and others. 5. In our November 30, 2018 review memo we recommended several areas of the design be reevaluated to minimize impacts to wetlands and wetland buffers. We agree that Talasaea has sufficiently reduced direct impacts to wetlands to the greatest extent feasible for the proposed development, as presented in the Comment Response. No further response required. 6. As stated in our November 30, 2018 review memo, the City considers grading within a wetland buffer to be development, and therefore, simply restoring the buffer post-construction does not meet FWRC requirements. The applicant needs to show that the proposed temporary buffer impacts due to site grading meet the criteria under FWRC 19.145.440 – Development within wetland buffers, including requirements for buffer averaging and/or buffer reduction if proposed. ESA recommends that the Revised Report be amended to include a clear description of how the Project meets these criteria. This information is provided in the attached addendum to the previously prepared Critical Areas Report. PAGE 5 7. As stated in our November 30, 2018 review memo, the wetland buffers on the Site Plan are inconsistent with the wetland buffers on the figures in the Revised Report. For example, buffers for Wetlands BA -2, PK, and BB appear larger on the Site Plan than on Figure WI.1 in the Report. ESA cont inues to recommend the Site Plan be revised to reflect the buffers presented in the Report. Both the site plan and Sheet W1.1 have been reviewed and modified as needed so that both sheets accurately reflect the wetland buffers for the onsite wetlands. Buffers for these wetlands were not accurately reflected previously. 8. As stated in our November 30, 2018 review memo, sheets of the Site Plan that contain the proposed development should only show the buffers post-development and should not include existing buffers for wetlands that will be filled or indirectly impacted. It was recommended the Site Plan be revised to show post- development buffers and an existing conditions figure be added to the Site Plan. Site Plan sheets ST -01, ST- 02, ST-03, GR-01, GR-02, and GR-03 continue to show wetlands and wetland buffers that will be impacted as a result of the Project. ESA continues to recommend the Site Plan be revised to only show post-development buffers on these pages. ESA considers the topographic survey sheets (Sheets EX-01, EX-02, and EX-03) to sufficiently represent existing conditions. Site Plan sheets ST-01, ST-02, ST-03, GR-01, GR-02, and GR-03 have been revised to only show post- development wetlands and buffers. 9. According to the Comment Response, the ordinary high water mark (OHWM) of North Lake was flagged in the field. However, no methodology or date of fieldwork is provided in the Revised Report. ESA recommends that this information be added to the report. This information is provided in the attached addendum to the previously prepared Critical Areas Report. PAGE 6 10. ESA recommends that the line representing the 200-foot Shoreline Management Zone be added to all relevant figures in the Revised Report to ensure that the only work in this area will be the installation of enhancement plantings and minor grading, which according to the Revised Report, would not trigger a shoreline development permit. Currently, according to Sheet ST-03 of the Site Plan, it appears that road improvements are proposed in the vicinity of Wetland BL, within the 200-foot Shoreline Management Zone. Additionally, because the proposed mitigation area is within the Shoreline Management Zone, we recommend that the Section 6 – Regulatory Review of the Revised Report be amended to include justification of why a shoreline development permit would not be required. The 200-foot Shoreline Management Zone has been added to relevant figures and graphics. Road improvements are necessary at the located noted near Wetland BL and do occur within the 200-foot SMZ. A shoreline development permit will be submitted for this proposed road work. 11. According to the Mitigation Grading Plan (Sheet W2.0) of the Revised Report, an existing upland swale in the proposed mitigation area will be graded to a similar elevation as portions of the proposed wetland creation area. Wetland-suitable plants are also proposed to be installed in this area per the planting plan (Sheet W3.1). According to Sheet W1.3, this area is considered to be wetland buffer restoration. However, the proposed grading and planting is consistent with wetland creation. ESA recommends that this area be revisited to ensure that wetland buffer is successfully restored here, and the created wetland is adequately buffered, as proposed. Mitigation has been revised as described above. This question is no longer applicable. 12. ESA agrees that the 10-foot-wide sewer easement been added to existing figures sheets of the Site Plan (Sheets EX-01, EX-02, and EX-03). However, the easement has not been included on the project sheets of the Site Plan (Sheets ST-01, ST-02, and ST-03). Additionally, the easement is not labeled on the figures in the Revised Report. ESA recommends that the sewer easement is labeled an included on all sheets of the Site Plan as well as in Plan Legend on all sheets in the Revised Report. Mitigation has been revised as described above. This question is no longer applicable. 13. ESA agrees that the mitigation plan in the Revised Report clearly shows the wetland creation and buffer creation areas outside of existing buffers as recommended in our November 30, 2018 memo. Noted. No further response. PAGE 7 14. ESA agrees that the plans have been adequately revised to remove any mitigation from the sewer easement as originally recommended in the November 30, 2018 memo. Noted. No further response. Should you have any questions or require additional information regarding this Project, please contact me at jen@wet.land (cell: 813-846-1684). Jennifer Marriott, PWS Owner, Wet.land, LLC Attachments: 1. Addendum to the Critical Areas Report, Wet.land, LLC, 10 October 2021 2. Revised Mitigation Plan, Talasaea Consultants, 20 September 2021 3. In Lieu Fee Plan, Wet.land, LLC, 10 October 2021 ATTACHMENT 1 Attachment 1 Addendum to the Talasaea Critical Areas Report, Wet.land, LLC, 10 October 2021 Wet.land, LLC Jennifer Marriott, PWS 15803 Bear Creek Parkway Unit E513 Redmond, WA 98052 10 October 2021 Jim Harris City of Federal Way Department of Community Development PROJECT: Woodbridge Business Park, Federal Way, Washington SUBJECT: Addendum to 9 April 2020 Critical Areas Report and Proposed Mitigation Plan Dear Jim, The City provided comments on this Project in the spring of 2021 that included ESA’s review of the critical areas information provided as part of this application. ESA’s review covered the most recent critical areas report titled Critical Areas Report and Proposed Mitigation Plan, dated 9 April 2020 as prepared by Talasaea Consultants. I have been part of this Project since its beginnings, and have continued my role even after leaving Talasaea in March of 2020. In order to respect the Project documents, rather than revise the April 2020 Talasaea Report or create a new report, this letter will serve as an addendum to the April 2020 Talasaea critical areas report . Responses to ESA’s comments on this application are provided as a separate document. EXISTING CONDITIONS PAGE 2 1. Existing Conditions 1.1 Ordinary High Water Mark (OHWM) The ordinary high water marks (OHWM) of the onsite streams and North Lake were determined based on the Washington State Department of Ecology (ECY) guidance document Determining the Ordinary High Water Mark for Shoreline Management Act Compliance in Washington State (October 2016, Publication No. 16-06-029). Delineations were done between in late winter to spring of 2016. Stream AC was delineated based on the location of the tops of bank for this artificial channel. North Lake was more complicated as the north end of the lake extends into a large wetland complex. The lake OHWM was also used as the starting location to determine the extent of the Shoreline Management Zone (SMZ). The OHWM of North Lake was established based on a clear topographic break along the western lake edge. Where wetlands occur adjacent to the open water portion of the lake, the OHWM was established based on the species of vegetation present. Aquatic plants and other obligate (OBL) plants were considered to be within the OHWM based on ECY guidance, while Facultative Wetland (FACW) or drier plants remained outside of the OHWM. Wetland vegetation along the western edge of the lake typically lacks both aquatic vegetation and OBL wetland vegetation, so the OHWM focused on the presence of a clear topographic break (bank) and the edge of the open water portion of the lake. Wetland conditions that extended up the hill were dominated by FACW or facultative (FAC) species, and thus were excluded from the OHWM delineation. The OHWM was more complicated at the north end of the lake, east of the WDFW boat ramp, due to the large wetland complex (Wetland CD) that occurs there. The upper limits of Wetland CD (not in Project Area) was delineated as part of the greater critical areas evaluations of the Woodbridge Property, and included within the Lakefront Boundary Line Adjustment application. The OHWM is located through Wetland CD such that this wetland occurs both inside and outside of the OHWM of the lake. The OHWM was not field delineated through this specific parcel/Wetland CD. Rather, the OHWM was approximated based on aerial imagery with field spot checks to be located outside of the OBL wetland vegetation. Spot elevations at certain locations and the use of lidar elevations combined were used to delineate the OHWM at this location. The remainder of the OHWM to the west and south where the OHWM is adjacent to the Project Area was field delineated. In addition to the OHWM of North Lake, this lake is also a Shoreline of the State. Therefore, in addition to delineating the OHWM of the lake, the OHWM was then used to identify areas that occur within the Shoreline Management Zone (SMZ). The SMZ extends 200 feet from the delineated OHWM of North Lake, and extends to encompass the entirety of any wetlands that occur even partially within the 200-foot SMZ. This inclusion of wetlands within the SMZ that occur even partially within the SMZ was the main reason why a field delineation of the OHWM of North Lake northeast of the Project Area was not conducted or deemed an efficient use of time. 1.2 Wetlands Clarification Wetlands KG, KH, KI, KJ, KK, KL, and KM were removed because these areas were reevaluated and removed from the plans due to their extremely small size. However, since these features were identified within the Boundary Line EXISTING CONDITIONS PAGE 3 Adjustments (BLA) for this area, these seven (7) wetlands are being added back into the critical areas report. The attached revised Critical Areas plan sheets and mitigation plan have been revised to reflect the presence of these wetlands. Wetlands KA, KB, KC, KD, KF, KN, KT, KU, KV, KW (previously included) and Wetlands KG, KH, KI, KJ, KK, KL, and KM (readded back in) These wetlands are a series of small slope and depressional wetlands that occur north of South 336th Street. These herbaceous wetlands are dominated by pasture grasses, typically a mix of rye (Lolium spp.), fescues (Festuca spp.), bentgrasses (Agrostis spp.), velvet grass (Holcus lanatus), sweet vernal grass (Anthoxanthum odoratum), and others. WETLAND BUFFER IMPACTS DISCUSSION PAGE 4 2. Wetland Buffer Impacts Discussion Certain development within buffers is allowed as outlined in FWRC 19.145.440 Development within wetland buffers, including trails and stormwater management facilities, with buffer averaging or enhancement allowed to modify buffers where needed. A detailed assessment of buffer modifications is outlined below. This assessment excludes all wetlands that are proposed to be fully filled as these wetlands will not have post-development buffers remaining. As a quick summary: Buffer Impacts 3,024 square feet-Permanent • Permanent Buffer Impacts 3,024 square feet • Stormwater Ponds Nos 2 and 3 maintenance access road • Temporary Disturbances 29,819 square feet • Grading Impacts (multiple wetlands) • Existing Trail Restoration (multiple wetlands) • Hydrologic connection swale (Wetland BR) Buffer Mitigation 60,116 square feet • Wetland Buffer Replacement 3,184 square feet • Replacement for Permanent Buffer Impacts • Wetland Buffer Creation 27,113 square feet • New buffer added between wetlands and Project (multiple wetlands) • Wetland Buffer Restoration 29,819 square feet • Restoration of grading related impacts (multiple wetlands) • Restoration of existing unpaved trail (multiple wetlands) • Restoration of buffer around hydrologic connection swale (Wetland BR) Table 1. Summary of Wetland Buffer Standards, Impacts, and Mitigation Proposed. # Wetland ID Impact Status Standard Buffer (feet), FWRC Ch.19 25% Reduced Buffer (feet), FWRC Ch.19 Post-Development Buffers Minimum Buffer Width (feet) Buffer Reduced (Loss) (square feet) Buffer Creation (Gain) (square feet) Buffer Restoration (Temporary Impacts*)(square feet) 1 AE Filled 60 N/A N/A N/A N/A N/A 2 AF Filled 60 N/A N/A N/A N/A N/A 3 AG Partial Fill 60 45 46.3 ** 3,100 6248 4 AH Filled 60 N/A N/A N/A N/A N/A 5 AI OUT OF PROJECT AREA 6 AJ 7 AL 8 AM WETLAND BUFFER IMPACTS DISCUSSION PAGE 5 # Wetland ID Impact Status Standard Buffer (feet), FWRC Ch.19 25% Reduced Buffer (feet), FWRC Ch.19 Post-Development Buffers Minimum Buffer Width (feet) Buffer Reduced (Loss) (square feet) Buffer Creation (Gain) (square feet) Buffer Restoration (Temporary Impacts*)(square feet) 9 AO 10 AR 11 AS 12 AV No Impact 60 45 30** ** 8473 N/A 13 BA-2 OUT OF PROJECT AREA 14 BR No Impact 105 78.75 105 None None 362 15 BS (N) Filled 60 N/A N/A N/A N/A N/A 16 BS (S) No Impact 40 30 40 None None None 17 CG OUT OF PROJECT AREA 18 DE Partial Fill 60 45 45 ** 11860 5678 19 DF No Impact 60 45 60 None None None 20 DG No Impact 60 45 60 None None None 21 DH No Impact 60 45 60 None None None 22 DI No Impact 60 45 60 None None None 23 DK Indirect Impact 60 45 ** ** 3250 0 24 EI Filled 40 N/A N/A N/A N/A N/A 25 EJ Filled 60 N/A N/A N/A N/A N/A 26 EK Filled 60 N/A N/A N/A N/A N/A 27 EL Filled 60 N/A N/A N/A N/A N/A 28 EM Filled 60 N/A N/A N/A N/A N/A 29 FB No Impact 60 45 60 None None None 30 FD Filled 40 N/A N/A N/A N/A N/A 31 FE Filled 105 N/A N/A N/A N/A N/A 32 FF Filled 40 N/A N/A N/A N/A N/A 33 GB (N) No Impact 60 45 60 None 430 0 34 IA OUT OF PROJECT AREA 35 KA 36 KB 37 KC 38 KD 39 KF 40 KN 41 KT 42 KU 43 KV 44 KW 45 PK Trail Restoration 17531 TOTALS 27,113 29819 *Temporary impacts related to buffer restoration values exclude the trail restoration. The trail restoration values are listed as separate from any specific wetland. **These wetlands either had indirect wetland impacts that modified the standard buffer, or lacked a full standard buffer due to existing constraints of the Site. Details by wetland are discussed below. WETLAND BUFFER IMPACTS DISCUSSION PAGE 6 2.1 Wetland AG Partial fill of Wetland AG is proposed with associated indirect wetland impacts. Direct fill of 2,063 square feet of Wetland AG is proposed for a permanent impact to 32% of this wetland for filling the northern arm of this wetland that wraps around an existing stormwater pond. This impact is required for the modification of this existing stormwater pond into a newly designed pond that will meet current requirements. As part of this direct fill, indirect wetland impacts are proposed to 427 square feet of this wetland to ensure a minimum 45-foot buffer from the remainder of this wetland post-development. All of the direct and indirect wetland impacts are proposed to be mitigated through the purchase of in-lieu fee credits. Buffer impacts are not being directly calculated for this wetland because partial wetland fill is required. The indirect wetland impacts address the wetland as buffer to ensure a minimum 45-foot buffer is maintained consistent with the minimum requirements for both buffer averaging and enhancement which allow for a 25% buffer reduction of the standard 60-foot buffer for this wetland. Additional buffer modifications for this wetland include 5,413 square feet of buffer that will be temporarily impacted through site grading that will be restored post-construction with an additional 2,926 square feet of new buffer added as additional compensation for impacted buffers. Other temporary buffer impacts proposed during construction will result from the restoration of an existing pedestrian trail into forested, functional buffer. These temporary impacts for trail to buffer restoration are not tallied based on FWRC 19.145.440 as these are existing trails that will be restored as buffer in place through removal of the trail substrate, soil decompaction and amendments as needed, and subsequent replanting concurrent with other onsite buffer mitigation activities. Figure 1. Snip from Revised Mitigation Plans showing dimensions of impacts and mitigation. WETLAND BUF FER IMPACTS DISCUSSION PAGE 7 2.2 Wetland AV Wetland AV is an irregularly-shaped wetland that is constrained by existing features on 3 of 4 sides. No direct impacts are proposed to Wetland AV. However, indirect impacts of 406 square feet (3% of the total wetland area) will result due to a necessary access road to the proposed stormwater ponds #3 and 4, discussed in more detail below. Additional temporary impacts will result from the restoration of an existing unpaved access road to functional buffer. This unpaved access road has deep ditches on either side of it that have a negative impact on wetland hydrology in this area. Current buffers for Wetland AV range between almost none (south end) to roughly 11-12 feet to the east and west due to existing development constraints that have vegetative and hydrologic impacts on this wetland. The buffer at the north end overlaps with buffers from Wetland DK, thus there is no “outer” 25% of the buffer for this wetland where a standard application of FWRC 19.145.440 could be implemented. The same is true around the entirety of this wetland due to the constrained existing conditions of this wetland and its buffer. Figure 2. Snip from Revised Mitigation Plans for Wetland AV (south end, left; north end, right). Large stormwater ponds are required to accommodate this Project due to the large area of impervious surfaces proposed. Restrictions on development into the meadow west of the proposed project footprint due to this area being of historical significance to the view corridor associated with the headquarters building to the south heavily restricts where stormwater ponds can be placed. The use of vaults has been evaluated and are being used to a limited extent where feasible to reduce the stormwater pond area requirements. Despite this, extensive ponds are still necessary, and where ponds are placed, maintenance access is necessary. Multiple locations were evaluated for placement of the maintenance access to the stormwater ponds, and it was decided the most direct route was best to reduce the footprint of this access road within the critical areas that occur between the ponds and the interior roads of the proposed development. Consideration was given to using the existing unpaved trail. However, the current conditions of this trail are not adequate for safe access of maintenance vehicles, so work would have been required to expand this feature into a safe access road. Proximity of this trail to Wetland AV was also a consideration so the proposed access road location moves this road to the most direct route, thus limiting buffer impacts, while also keeping this trail a maximum, feasible distance from all wetlands. Based on this assessment, it was determined that the section of buffer between Wetlands AV and DK was the best location with the remainder WETLAND BUFFER IMPACTS DISCUSSION PAGE 8 of the unpaved access road to be restored as functional buffer with the side ditches removed to also restore more natural surface water movement through this area. The indirect impacts proposed to the Wetland AV buffer to accommodate this access road will be compensated for through the purchase of in-lieu fee credits. The stormwater maintenance access road located through the buffers between Wetlands AV and DK will result in 3,024 square feet of buffer loss that will be replaced with the addition of 3,184 square feet of buffer, as required by buffer averaging. The indirect impacts resulting from this buffer intrusion exceed the 25% reduction allowed per code due to the existing constraints of this location, but the nearest interpretation of buffer averaging as feasible given existing conditions was applied to this location. Additional buffer was added adjacent to Wetland AV totaling 7,792 square feet between the wetland and the proposed development to the east as the existing edge of development was adjusted. These areas of new buffer will be restored to a fully vegetation condition, including removal of all existing structures within these areas currently. Restoration of the unpaved vehicular/pedestrian trail that extends along the southern and western boundaries of Wetland AV will provide expanded buffers in those areas that will have a net positive benefit to both vegetation and hydrology. 2.3 Wetland BR Wetland BR will remain unimpacted with no substantial buffer impacts anticipated. A segment of a pedestrian trail does occur within the buffer of Wetland BR that will be restored in place, requiring temporary impacts for the restoration work. A small swale is also proposed within the Wetland BR buffer that will temporarily disturb 362 square feet of buffer for construction of this swale (see Figure 1 above). No dispersion trench or other structure is proposed in association with this swale. This swale is not associated with the Project’s stormwater infrastructure, but rather is intended to provide a clear hydrologic connection between Wetland AV and Wetland BR. The swale will be field-located during construction to avoid any impacts to trees, and will be hydroseeded with a native grass blend. 2.4 Wetland BS-South Wetland BS-South will remain unimpacted with the only buffer impact proposed being the pedestrian trail restoration. 2.5 Wetland DE Direct placement of fill into Wetland DE will total 264 square feet (1% of the total wetland area) with an additional 3,961 square feet of indirect wetland impacts resulting from the insufficiently buffered wetland. The indirect impacts were determined based on the minimum wetland area required to provide a minimum 45-foot buffer. Both direct and indirect wetland impacts will be compensated for through the purchase of in-lieu fee credits. New buffer totally 11,860 square feet will be added east of the wetland in an area already vegetated with native species, but supplemental mid-canopy and understory species will be added to enhance the existing conditions. This area of buffer is dominated by native conifers with a sparse understory and low species diversity. This exceeds WETLAND BUFFER IMPACTS DISCUSSION PAGE 9 the requirements for buffer averaging by giving back more than what was lost. Portions of the remaining buffer north of the indirect impacts proposed will be temporarily disturbed for construction, but will be restored post- construction as native buffer. Figure 3. Snip from Revised Mitigation Plans of Wetland DE. 2.6 Wetland DF Wetland DF will remain unimpacted by this Project. No buffer impacts to this wetland are proposed. 2.7 Wetland DG Wetland DG will remain unimpacted by this Project. No buffer impacts to this wetland are proposed. 2.8 Wetland DH Wetland DH will remain unimpacted by this Project. No buffer impacts to this wetland are proposed. 2.9 Wetland DI Wetland DI will remain unimpacted by this Project. No buffer impacts to this wetland are proposed. WETLAND BUFFER IMPACTS DISCUSSION PAGE 10 2.10 Wetland DK Wetland DK has a standard 60-foot buffer that overlaps the Wetland AV buffer to the south. No direct impacts to this wetland are proposed. However, indirect impacts totaling 1,981 square feet are proposed to accommodate the maintenance access road for the proposed stormwater ponds west of this wetland. A detailed discussion on the location of this access road was provided above under Section 2.2. Portions of the unpaved access road also occur within the buffer of this wetland that will be temporarily impacted for restoration activities. The stormwater pond maintenance access road will require the loss of 3,024 square feet of buffer that overlaps both Wetlands AV and DK. Buffer averaging will be used to accommodate this buffer impact with a total of 3,184 square feet of buffer added to the standard buffers of this and adjacent wetlands. In addition to the targeted buffer replacement of 3,184 square feet, an additional 3,250 square feet of buffer will be provided adjacent to the Wetland DK buffer. Figure 4. Snip from Revised Mitigation Plans of Wetland DK. 2.11 Wetland FB Wetland FB will remain unimpacted by this Project. No buffer impacts to this wetland are proposed. 2.12 Wetland GB-North Wetland GB-North will remain mostly unimpacted by this Project. No direct wetland impacts are proposed. Indirect impacts totally 18 square feet are proposed due to the encroachment into the standard 60-foot buffer for this wetland. The indirect wetland impacts were calculated based on a required 45-foot minimum buffer. Temporary buffer impacts will occur to the outer 25% of the buffer of this wetland to accommodate the Project with these areas being restored post-construction to restore the full 60-foot buffer except where the indirect wetland impact is proposed. Buffer replacement is provided north of Wetland GB-North totaling 430 square feet. In addition to WETLAND BUFFER IMPACTS DISCUSSION PAGE 11 these buffer modifications, the trail identified to be restored also occurs through the eastern buffer for this wetland for additional temporary buffer disturbances that will ultimately be restored to fully functional, native buffer. Figure 5. Snip from Revised Mitigation Plans for Wetland GB-North. SUMMARY PAGE 12 3. Summary As described above – in addition to all direct and indirect wetland impacts being compensated for through the purchase of in-lieu fee credits, buffer intrusions are generally kept within the allowable thresholds of no more than 25% reductions except where existing conditions lack a full standard buffer. Permanent buffer impacts are restricted to only 3,024 square feet which will be directly offset through the addition of 3,184 square feet of replacement buffer. Temporary buffer impacts are proposed to accommodate the site plan grading, restore an existing unpaved access road/trail as forested buffer, and to construct a hydrologic connection swale between Wetlands AV and BR that will be field located to avoid any tree impacts. All temporary buffer impacts will be fully restored post-construction for no net loss of buffer functions. Beyond these buffer modifications, voluntary buffer totaling an added 27,113 square feet will be provided around the remaining wetlands on the Site. These combined efforts will ensure there will be no net loss of wetland buffers. Should you have any questions or require additional information regarding this Project, please contact me at jen@wet.land (cell: 813-846-1684). Jennifer Marriott, PWS Owner, Wet.land, LLC ATTACHMENT 2 Attachment 2 Revised Mitigation Plan, Talasaea Consultants, 20 September 2021 *Annotated by Wet.land, LLC Know what'sbelow.Callbefore you dig. Know what'sbelow.Callbefore you dig. Know what'sbelow.Callbefore you dig. Know what'sbelow.Callbefore you dig. Know what'sbelow.Callbefore you dig. Know what'sbelow.Callbefore you dig.THIS AREA IS PROTECTEDTO PROVIDE WILDLIFE HABITATAND TO MAINTAIN CRITICALAREA(S) FUNCTIONS/VALUES.PLEASE DO NOT DISTURB THISVALUABLE RESOURCECRITICAL AREAPROTECTION AREACONTACT CITY OF FEDERAL WAYFOR MORE INFORMATION Know what'sbelow.Callbefore you dig.¼ Know what'sbelow.Callbefore you dig. Know what'sbelow.Callbefore you dig. Know what'sbelow.Callbefore you dig.½½¼½½¾½ ATTA CHMENT 3 Attachment 3 In Lieu Fee Plan, Wet.land, LLC, 10 October 2021 PREPARED FOR: Federal Way Campus, LLC PREPARED BY: Jennifer Marriott, PWS Wet.land, LLC 813-846-1684 Wet.land jen@wet.land In-Lieu Fee Plan Woodbridge Business Park Project Federal Way, Washington 10 October 2021 CONTENTS 1. REPORT PURPOSE ...................................................................................................................... 1 1.1 Project Name and Purpose ------------------------------------------------------------------------------------------------------ 1 1.2 Applicant ----------------------------------------------------------------------------------------------------------------------------- 1 1.3 Report Purpose --------------------------------------------------------------------------------------------------------------------- 1 1.4 Preparer Qualifications ----------------------------------------------------------------------------------------------------------- 1 2. PROJECT DETAILS .................................................................................................................... 2 2.1 Project Description ---------------------------------------------------------------------------------------------------------------- 2 3. EXISTING CONDITIONS ........................................................................................................... 3 4. AVOIDANCE AND MINIMIZATION OF IMPACTS TO WATERS OF THE US ............... 5 5. JUSTIFICATION FOR USING AN IN-LIEU FEE PROGRAM ............................................ 6 5.1 Description of Compensatory Mitigation Options Considered --------------------------------------------------------- 6 5.2 In-Lieu Fee Program Selection Rationale ------------------------------------------------------------------------------------ 6 6. PROPOSED IN-LIEU FEE CREDITS ....................................................................................... 8 6.1 Proposed Wetland Impacts ------------------------------------------------------------------------------------------------------ 8 6.2 Credit-Debit Analysis -------------------------------------------------------------------------------------------------------------- 8 6.3 Credit Purchase or Transfer Timing ------------------------------------------------------------------------------------------- 9 TABLE OF FIGURES Figure 1. Project Location (pulled from Figure 1 of CAR) ............................................................................................. 2 Figure 2. Summary of Wetland Impacts proposed, as reflected from revised Mitigation Plan, prepared by Talasaea, 20 September 2021. ........................................................................................................................................................ 5 TABLE OF FIGURES Table 1. Summary of Wetlands. .................................................................................................................................... 3 Table 2. Summary of Credit-Debit Analysis. ................................................................................................................. 8 TABLE OF ATTACHMENTS Attachment 1. Wetland Rating Forms, Talasaea Consultants Attachment 2. Credit-Debit Calculations REPORT PURPOSE PAGE 1 1. Report Purpose 1.1 Project Name and Purpose The Applicant proposes to construct a new business park with three (3) new warehouses with office space and associated infrastructure. The existing Weyerhaeuser Tech Center will remain but the existing parking lots will be reconfigured. Direct and indirect wetland impacts totalling 8,492 square feet (0.19 acres) and 7,840 square feet (0.18-acre), respectively, are proposed to accommodate this Project. These impacts will be compensated for through the purchase of in-lieu fee credits. On-site mitigation will occur for other buffer modifications proposed outside of the direct and indirect wetland impacts. 1.2 Applicant The Applicant for the Project is Federal Way Campus, LLC, represented by Dana Ostenson: Dana Ostenson, 11100 Santa Monica Blvd, Suite 850, Los Angeles, CA 90025 Email: dostenson@industrialrealtygroup.com 1.3 Report Purpose This report has been prepared to outline the intent to use the King County In-Lieu Fee Program to compensate for wetland impacts proposed for this Project. 1.4 Preparer Qualifications Field investigations and delineations were previously completed and/or directed by Jennifer Marriott while employed at Talasaea Consultants. Jennifer Marriott has a Bachelor’s Degree and a Master’s Degree in Biology from University of Central Florida, and a second Master’s Degree in Environmental Soil Science from the University of Florida. She has 18 years of experience in wetland delineations and environmental permitting. PROJECT DETAILS PAGE 2 2. Project Details 2.1 Project Description The Site is an assemblage of five parcels currently owned by Federal Way Campus, LLC (Figure 1). The approximate address is 32901 Weyerhaeuser Way South in the City of Federal Way, Washington. The Site is approximately 136 acres in size. The remainder of the associated parcels under Federal Way Campus, LLC ownership are not a part of this project. The Public Land Survey System location of the Site is Sections 16 and 21, Township 21 North, Range 4 East, Willamette Meridian. Figure 1. Project Location (pulled from Figure 1 of CAR) The Applicant proposes to construct a new business park comprised of three (3) new warehouses with office space and associated infrastructure. The Weyerhaeuser Tech Center will be retained, but the existing parking lots will be reconfigured to a more compact arrangement around the Tech Center. Associated infrastructure to be constructed includes five (5) new stormwater detention facilities, reconfiguring the existing stormwater pond, parking for both cars and trucks, and enough maneuvering space for the truck traffic anticipated around these buildings. The proposed Site Plan has been designed to minimize impacts to critical areas to the greatest extent practicable, as outlined in the Critical Areas Report prepared by Talasaea Consultants, dated 9 April 2020 and the addendum prepared by Wet.land, LLC, dated 10 October 2021 that includes the revised Mitigation Plan, as revised by Talasaea Consultants, dated 20 September 2021. EXISTING CONDITIONS PAGE 3 3. Existing Conditions A Critical Areas Report and Mitigation Plan were completed by Talasaea Consultants on 9 April 2020 that was provided to the Applicant. Portions of 48 wetlands, one (1) stream, and North Lake are located on or adjacent to the Site. Details of the existing conditions are provided in Chapter 4 of the CAR. A summary of the critical areas present onsite includes: Table 1. Summary of Wetlands. # Wetland ID Cowardin HGM 2014 DOE Wetland Rating Acreage Square Footage** Standard Buffer (feet), FWRC Ch.19 Category Habitat Score 1 AE PEM Depressional III 4 0.0055 239 60 2 AF PEM Depressional III 4 0.0109 473 60 3 AG PFO Depressional III 4 0.1469 6,397 60 4 AH PSS Depressional III 4 0.0163 712 60 5 AI PEM Slope IV 3 0.0699 3,044 40 6 AJ PEM Slope IV 3 0.0012 51 40 7 AL PEM Slope IV 3 0.0246 1,072 40 8 AM PEM Slope IV 3 0.0303 1,319 40 9 AO PEM Slope IV 3 0.0018 79 40 10 AR PEM Slope IV 3 0.0006 26 40 11 AS PEM Slope IV 3 0.0068 295 40 12 AV PFO Depressional III 4 0.2831 12,332 60 13 BA-2 PSS Depressional III 4 0.0154 670 60 14 BR PEM Depressional III 5 0.0508 2,211 105 15 BS (N) PFO Depressional III 4 0.0616 2,683 60 16 BS (S) PEM Depressional IV 3 0.0044 192 40 17 CG PFO Depressional IV 4 0.0794 3,458 40 18 DE PFO Depressional III 3 0.4948 21,554 60 19 DF PFO Depressional III 3 0.0019 81 60 20 DG PFO Depressional III 3 0.0253 1,103 60 21 DH PFO Depressional III 3 0.0062 271 60 22 DI PFO Depressional III 3 0.0052 227 60 23 DK PFO Depressional III 3 0.1454 6,332 60 24 EI PFO Depressional IV 3 0.0040 175 40 25 EJ PSS Depressional III 3 0.0053 231 60 26 EK PSS Depressional III 3 0.0041 179 60 27 EL PSS Depressional III 3 0.0085 372 60 28 EM PSS Depressional III 3 0.0070 306 60 29 FB PSS Depressional III 4 0.1688 7,353 60 30 FD PFO Depressional IV 3 0.0157 686 40 31 FE PFO Depressional III 5 0.0074 324 105 32 FF PSS Depressional IV 3 0.0225 978 40 33 GB (N) PSS Depressional III 3 0.0775 3,377 60 34 IA PEM Slope IV 3 0.0603 2,625 40 35 KA PEM Slope IV 4 0.0238 1,038 40 36 KB PEM Slope IV 5 0.0003 15 40 37 KC PEM Slope IV 6 0.0072 314 40 38 KD PEM Slope IV 7 0.0407 1,771 40 39 KF PEM Slope IV 8 0.0087 378 40 EXISTING CONDITIONS PAGE 4 # Wetland ID Cowardin HGM 2014 DOE Wetland Rating Acreage Square Footage** Standard Buffer (feet), FWRC Ch.19 Category Habitat Score 40 KN PEM Slope IV 10 0.0156 678 40 41 KT PEM Slope IV 11 0.0055 239 40 42 KU PEM Slope IV 12 0.0013 55 40 43 KV PEM Slope IV 13 0.0017 74 40 44 KW PEM Slope IV 14 0.0176 765 40 45 PK PFO Depressional III 4 0.0310 1,350 60 46 BA PFO Depressional N/A N/A 0.1980 8,626 100 47 BB PFO Depressional N/A N/A 0.0687 2,992 25 48 BD (N) PFO/PSS Depressional N/A N/A 2.6667 116,160 100 AVOIDANCE AND MINIMIZATION OF IMPACTS TO WATERS OF THE US PAGE 5 4. Avoidance and Minimization of Impacts to Waters of the US The Project has reduced wetland impacts to the greatest extent practicable, as described in Sections 7, 8, and 9 of the CAR. The proposed site plan has been designed to minimize impacts to critical areas to the greatest extent practicable while meeting the criteria for development of a viable project and conforming to the City of Federal Way standards. In attempting to avoid wetland impacts on the Site, several different configurations were evaluated to find the best configuration and scale for the project needs. Despite these efforts, some impacts to critical areas are unavoidable in order to achieve a viable project. Portions of 48 wetlands, one (1) stream, and North Lake are located on or adjacent to the Site. Construction of the proposed development would directly impact (fill) 8,492 square feet (0.19 acres) of wetlands for the buildings, parking, and stormwater facilities. An additional 7,840 square feet (0.18 acres) of wetland as being considered indirect wetland impacts due to site development encroachments. For the construction of a stormwater pond (Nos 2 and 3) maintenance access road, permanent and temporary wetland buffer impacts are proposed east of the existing Tech Center. No impacts to Stream AC or its buffer are proposed. No development activities are proposed on or adjacent to North Lake. Figure 2. Summary of Wetland Impacts proposed, as reflected from revised Mitigation Plan, prepared by Talasaea, 20 September 2021. The wetland impacted by the Project will be mitigated for through the purchase of credits from the King County In- Lieu Fee Program. No additional monitoring or maintenance will be required once the purchase of credits is final. Credit purchase is finalized after receipt of final Agency permits. Additional onsite mitigation is proposed to compensate for buffer impacts beyond those direct and indirect wetland impacts discussed here. JUSTIFICATION FOR USING AN IN -LIEU FEE PROGRAM PAGE 6 5. Justification for Using an In-Lieu Fee Program 5.1 Description of Compensatory Mitigation Options Considered Allowable mitigation options for the City are outlined in Federal Way Revised Code (FWRC) 19.145.430(4), and include in-lieu fee credits as well as mitigation banks, in addition to advanced mitigation and other Permittee- responsible options. The USACE identifies mitigation banks and in-lieu fee programs as preferential mitigation options, followed by on-site Permittee Responsible then off-site Permittee Responsible mitigation. No mitigation banks occur that cover the Site location. The King County In-Lieu Fee program does cover the Site location. The Site generally contains areas where onsite mitigation could be done. However, these locations are either within shoreline jurisdiction, already contain existing native vegetation that is less desirable to remove, or have hydrologic constraints such that without an artificial source of hydrology these locations make for poor wetland creation potential. Given that the USACE has a preference for in-lieu fee over Permittee-responsible mitigation, the decision was made to use the King County In-Lieu Fee Program. While offsite wetland creation may be potentially possible, available land in the area for wetland creation is limited given the dense urban development. This is also the least preferential for the USACE, and thus, inherently problematic. Onsite mitigation is proposed to compensate for additional buffer modifications proposed to accommodate the Project. However, all mitigation for wetland fill (direct impacts) and associated insufficiently buffered (indirect) wetland impacts will be provided through the purchase of in-lieu fee credits. 5.2 In-Lieu Fee Program Selection Rationale Mitigation sequencing is required by local, State, and Federal regulations. The below list is outlined in FWRC 19.145.430(2), and is consistent with those requirements of the Washington Department of Ecology and the USACE. (a) It will not adversely affect drainage or stormwater retention capabilities; (b) It will not lead to unstable earth conditions nor create erosion hazards; (c) It will not be materially detrimental to any other property in the area of the subject property nor to the city as a whole, including the loss of open space; (d) It will result in no net loss of wetland area, function or value upon completion of compensatory mitigation; (e) The project is in the best interest of the public health, safety or welfare; (f) The applicant has demonstrated sufficient scientific expertise and supervisory capability to carry out the project; and (g) The applicant is committed to monitoring the project and to making corrections if the project fails to meet projected goals. JUSTIFICATION FOR USING AN IN -LIEU FEE PROGRAM PAGE 7 How the Project has met each of these requirements is outlined in Section 4 above as well as discussed in detail in the CAR prepared by Talasaea Consultants and the subsequent addendum prepared by Wet.land, LLC. PROPOSED IN -LIEU FEE CREDITS PAGE 8 6. Proposed In-Lieu Fee Credits 6.1 Proposed Wetland Impacts Direct impacts (fill) totalling 8,492 square feet (0.19 acres) and 7,840 square feet (0.18 acres) of indirect impacts to wetlands will be accounted for in the credit purchase to address both direct wetland impacts for the proposed development and for indirect wetland impacts where the Project would leave the remainder of the onsite wetlands insufficiently buffered. 6.2 Credit-Debit Analysis The results of the credit-debit analysis are outlined below in Table 1. The rating sheets from the CAR prepared by Talasaea are provided only for the wetlands proposed for impact (Attachment 1). The calculations that form the foundation for the table below is attached as Attachment 2. A total of 23.06 units of Debits will result from the proposed wetland fill to accommodate this Project, resulting in the purchase of an equivalent number of Credits from the King County In-Lieu Fee Program to compensation for the Project impacts to wetlands. Table 2. Summary of Credit-Debit Analysis. Summary of Credits and Debits Summary Worksheet 10 October 2020 DEBITS (all numbers are acre- points) Improving Water Quality (sum of all impacts) Hydrologic Function (sum of all impacts) Habitat Function (sum of all impacts) Wetland AE/AF 0.336 0.288 0.192 Wetland DE/DK 3.976 3.408 1.704 Wetland AG/AV/BS(N) 3.584 3.072 2.048 Wetland FE 0.196 0.168 0.14 Wetland EI 0.096 0.08 0.048 Wetland EJ/EK/EL/EM/GB(N) 0.525 0.45 0.225 Wetland AH 0.336 0.288 0.192 Wetland FD 0.288 0.288 0.144 Wetland FF 0.396 0.396 0.198 PROPOSED IN -LIEU FEE CREDITS PAGE 9 Total (in acre-points) 9.73 8.44 4.89 CREDITS (all numbers are acre- points) Improving Water Quality (sum of all impacts) Hydrologic Function (sum of all impacts) Habitat Function (sum of all impacts) Creation/Re- establishment Rehabilitation Enhancement Wetland Preservation Upland Preservation Total Credits Available (in acre-points) 0.00 0.00 0.00 BALANCE Credits - Debits -9.73 -8.44 -4.89 TOTAL CREDITS TO BE PURCHASED -23.06 6.3 Credit Purchase or Transfer Timing Credit purchase should occur simultaneously with the start of the proposed Project following issuance of required permits from applicable regulatory agencies. Proof of mitigation credit purchase will be supplied to the regulatory agencies upon receipt. ATTACHMENT 1 Attachment 1 Wetland Ratings prepared by Talasaea Consultants Woodbridge Business Park Critical Areas Report and Proposed Mitigation Plan 9 April 2020 Copyright © 2020 Talasaea Consultants, Inc. 1572C Critical Areas Report and Proposed Mitigation Plan V6.docx Appendix D APPENDIX D WETLAND RATING FORMS, TALASAEA CONSULTANTS, 2016 & 2017 ATTACHMENT 2 Attachment 2 Summary of Credit-Debit Calculations Calculating Debits for Compensatory Mitigation in Wetlands of Western WashingtonDebit WorksheetProject: Woodbridge Business ParkApplicant: Federal Way Campus, LLCMitigation Project is: Delayed (King County ILF)Improving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatSite Potential (H,M,L)MMLMMLMMLMHLMMLMMLMMLMMLMMLLandscape Potential (H,M,L)MMLMMLMMLMLML L LMMLMML LML LMLValue (H,M,L)HMMHML HMMHMMHML HML HMMHML HMLScore for Wetland Unit764763764765653763764663663Acres of non‐forested impacts0.0160000.0250.0160.0160.022Basic mitigation requirement (BMR)0.112 0.096 0.0640000000000000.175 0.15 0.075 0.112 0.096 0.064 0.096 0.096 0.048 0.132 0.132 0.066Temporal loss factor3.03.0 3.0 3.0 3.0DEBITS0.336 0.288 0.1920000000000000.525 0.45 0.225 0.336 0.288 0.192 0.288 0.288 0.144 0.396 0.396 0.198Acres of forest impacts0.1420.1280.0070.0040Basic mitigation requirement (BMR)000 0.994 0.852 0.426 0.896 0.768 0.512 0.049 0.042 0.035 0.024 0.02 0.012000000000000Temporal loss factor4.04.04.04.0DEBITS0 0 0 3.976 3.408 1.704 3.584 3.072 2.048 0.196 0.168 0.14 0.096 0.08 0.048000000000000Acres of Evergreen forest impactsBasic mitigation requirement (BMR)000000000000000000000000000Temporal loss factorDEBITS000000000000000000000000000Acres of Cat. 1 Deciduous forest Basic mitigation requirement (BMR)000000000000000000000000000Temporal loss factorDEBITS000000000000000000000000000Acres of Cat. 1 Evergreen forest Basic mitigation requirement (BMR)000000000000000000000000000Temporal loss factorDEBITS000000000000000000000000000TOTALSFunctionImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatImproving Water Quality Hydrologic HabitatAcre‐Points0.336 0.288 0.192 3.976 3.408 1.7043.5843.072 2.048 0.196 0.168 0.14 0.096 0.08 0.048 0.525 0.45 0.225 0.336 0.288 0.192 0.288 0.288 0.1440.396 0.396 0.198Total Debits by FunctionImproving Water Quality Hydrologic HabitatAcre‐Points9.733 8.438 4.89123.062Wetland AE/AFWetland FDWetland FDWetland EJ/EK/EL/EM/GB(N)Wetland EJ/EK/EL/EM/GB(N)Wetland AG/AV/BS(N)Wetland FEWetland AG/AV/BS(N)Wetland FEWetland AE/AFWetland DE/DKWetland EIWetland AHWetland FFWetland DE/DKWetland EIWetland AHWetland FF