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17-105489-Addendum to Critical Areas Report-11-12-2021-V2 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