21-104105-Response to Third-Party Comments-04-19-2022 Soundview Consultants LLC
Environmental Assessment • Planning • Land Use Solutions
2907 Harborview Dr., Suite D, Gig Harbor, WA 98335
Phone: (253) 514-8952 Fax: (253) 514-8954
1310.0029 – Twin Trails Soundview Consultants LLC
Response to Third-Party Comments 1 April 14, 2022
Technical Memorandum
To: Jim Harris, City of Federal Way File Number: 1310.0029
From: Jon Pickett, Soundview Consultants LLC Date: April 14, 2022
Re: Response to Peer Review Twin Trails Subdivision – Wetland and Fish and Wildlife
Habitat Assessment (File No. 21-104105-SU)
Dear Mr. Harris,
Soundview Consultants LLC (SVC) has been assisting Prospect Development (Applicant) with a
wetland and fish and wildlife habitat assessment for the proposed residential redevelopment of a
17.33-acre site located at 1605 Southwest 341st Place in the City of Federal Way, King County,
Washington. The subject property consists of two parcels situated in the Northeast ¼ of Section 24,
Township 21 North, Range 3 East, W.M. (King County Tax Parcel Numbers 2421039008 and
2421039051). This Technical Memorandum has been prepared in response to review comments
provided on January 14, 2022 by the City of Federal Way’s (City) third-party reviewer (Landau
Associates Inc., 2022) regarding the review of SVC’s Wetland and Fish and Wildlife Habitat
Assessment Report prepared September 28, 2021. Revisions to the report have been completed to
include the responses specified in this memorandum. This memorandum supersedes any
inconsistencies that may remain between the memorandum and the revised report. The following is
the third-party review comments (italicized) followed by SVC’s responses:
1. The September 2021 Report does not satisfy all of the evaluation criteria provided in FWRC 19.145.080(2),
specifically items:
(e) Photographs of the site and critical areas
• LAI will collect photographs, which may be used to fulfill this requirement, from an upcoming site
reconnaissance.
SVC’s report has been revised to provide site photographs (Appendix C) of general upland
conditions, non-hydric soil profiles at each data point, and representative conditions of each offsite
wetland.
2. The September 2021 Report does not satisfy all of the evaluation criteria provided in FWRC 19.145.410(2),
specifically item (f)(i):
1310.0029 – Twin Trails Soundview Consultants LLC
Response to Third-Party Comments 2 April 14, 2022
(f) Provide the following for each wetland identified on and/or within 225 feet of the subject property. Acreage
estimates, classifications, and ratings shall be based on entire wetland complexes, not only the portion present
on the subject property:
i. Wetland rating and score for each function;
• LAI notes that wetland rating for offsite Wetlands 1, 2, and 3 are provided; however, scores for
each function and corresponding rating forms are not provided.
SVC’s report has been revised to include the offsite wetland rating forms and figures in
Appendices F and G, respectively.
3. LAI requests a figure identifying the location of offsite wetlands discussed in the September 2021 Report. LAI
presumes that FWRC 19.145.080(2)(d), which includes but is not limited to, a scaled site plan depicting critical
areas, applies to areas adjacent to the proposed improvements. LAI notes that the Technical Information Report
(TIR) prepared for the project includes a figure identifying two offsite wetlands, one of which appears to be
approximately 140 feet from the subject property.
SVC’s report has been revised to include an updated Existing Conditions Exhibit (Appendix D)
depicting the offsite wetlands.
4. LAI requests clarification to determine if the offsite wetlands were observed by Soundview staff. The September
2021 Report includes reference to delineation of these wetlands by Wetland Resources but it is not clear if the
description of the wetlands is based on the previous delineation by Wetland Resources or if Soundview was provided
access to the offsite property to collect their own observations.
SVC was provided access to the east-adjacent property on May 4, 2021 to perform a
reconnaissance to confirm the accuracy of the prior delineation and assessment of the offsite
wetlands. Photographs of each wetland are included in Appendix C of the revised report.
5. LAI understands that the City is investigating documentation (circa 1995) related to the Washington State
Department of Transportation Park and Ride adjacent to 21st Avenue SW identifying a regulated wetland on the
subject property, generally east of the southeast corner of the current Park and Ride lot. Once located, these files will
be provided to the applicant for incorporation into updated evaluation of background and existing conditions, as
necessary.
Section 4.6 (Previous Critical Area Studies) was added to SVC’s revised report to incorporate the
prior critical area findings provided in the City of Federal Way’s SPR 95-0026- Site Plan Approval
for the Twin Lakes Park and Ride Facility dated October 8, 1996. The previously identified
wetland from this approval does not currently meet wetland criteria as discussed in Section 5.1
(Onsite Wetland Absence) in the revised report.
6. LAI notes that a buffer may apply to Wetland 3, provided verification of rating and confirmation that the wetland
is isolated. FWRC 19.145.420(3) indicates that no wetland buffer is required for those isolated wetlands 1,000
square feet or less in total area. In addition, Wetland 3 may be beyond the 225-feet evaluation area limits identified
in FWRC 19.145.410(2)(e).
Although Wetland 3 is located approximately 280 feet from the subject property–beyond the 225-
foot evaluation area–a wetland rating form and associated rating figures are provided. Wetland 3
1310.0029 – Twin Trails Soundview Consultants LLC
Response to Third-Party Comments 3 April 14, 2022
is only approximately 898 square feet in size. In addition, the wetland is likely isolated given that
the unit is within a closed depression and the lack of hydrologic connection to the other identified
Wetlands 1 and 2 nearby or to any streams. Therefore, due to the units’ small size (< 1,000 square
feet) and isolated nature, offsite Wetland 3 is exempt from buffer regulations per FWRC
19.145.420(3).
The Wetland and Fish and Wildlife Habitat Assessment Report has been revised in response to the
third-party reviewer’s comments. Please do not hesitate to contact me with any questions or concerns
you may have.
Sincerely,
_____________________________________
Jon Pickett
Associate Principal
Office 253.514.8952
jon@soundviewconsultants.com
1310.0029 – Twin Trails Soundview Consultants LLC
Response to Third-Party Comments 4 April 14, 2022
References
Landau Associates. 2022. Peer Review, Twin Trails Subdivision — Wetland and Fish and Wildlife Habitat
Assessment 34220 21st Avenue SW, Federal Way, File No. 21-104105-SU, LAI Project No.
0238095.010. Prepared January 14, 2022 for the City of Federal Way