22-102032-UP Critical Areas Study-5-4-22
5309 Shilshole Avenue NW
Suite 200
Seattle, WA 98107
206.789.9658 phone
206.789.9684 fax
esassoc.com
memorandum
date November 29, 2021
to Michael Kwaske, Federal Way School District Senior Capital Projects Manager
from Colleen Kroe, PWS
subject D202100688.00 – FWSD Illahee Middle School Critical Areas Study
Federal Way School District (FWSD) retained Environmental Science Associates (ESA) to complete an
investigation and reconnaissance of critical areas at Illahee Middle School and surrounding parcels for the
purpose of reconstructing the existing school. The approximately 33.5-acre study area encompassed three parcels
(study area) (Figure 1):
• King County parcel #302104-9013, located at 36001 1st Avenue South, Federal Way (Illahee Middle School)
• Eastern half of King County parcel #3021049029 (vacant)
• Eastern half of King County parcel #3021049030 (vacant)
The project study area is located entirely within the City of Federal Way, within the southeast ¼ of Section 30,
Township 21 North, Range 4 East. ESA staff reviewed the parcels per the scope of work and prepared this memo
in support of the effort. The site visit was conducted on September 8, 2021.
This critical areas memo adheres to the requirements described in the City of Federal Way Revised Code –
Environmentally Critical Areas (FWRC 19.145). The report discusses the general habitat conditions of the site.
The presence/absence of critical aquifer recharge areas, geologic hazards, or frequently flooded areas were not
evaluated as part of the scope. This memorandum verifies that there are no wetlands or fish and wildlife
conservation areas (streams) present within the study area as defined FWRC 19.05.230 and 19.05.060,
respectively.
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SW 362nd Pl
SW 361st St
2nd Ave SWS 363rd Pl
3rd Ave SW3rd Ave SSW 366th St
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Path: \\azr-file01\GIS_SHARE\GIS\GIS\Projects\2021xxx\D202100688_00_FWSD_Illahee_Middle_School_CAS\03_MXDs_Projects\VicinityMap\VicinityMap.aprx, CStruthers 11/24/2021Project AreaN
SOURCE: ESRI, 2020; King County, 2021 FWSD Illahee Middle School
Figure 1
Vicinity Map
0 200
Feet
Project
Area
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W A
D202100688.00 – FWSD Illahee Middle School Critical Areas Study
3
Document Review
Prior to conducting the field investigation, ESA reviewed the following information to determine if there was
documented presence of wetlands, hydric soils, or fish and wildlife conservation areas within the study area:
• King County GIS mapping website (iMap)
• Washington Department of Fish and Wildlife (WDFW) web-mapping tools (Priority Habitats and Species
[PHS] mapping and Salmonscape)
• U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory Wetland Mapper
• National Resources Conservation Service (NRCS) Web Soil Survey
• City of Federal Way Critical Areas Map, dated May 2016
• Washington Department of Natural Resources (WDNR), Washington Natural Heritage Program list of
Wetlands of High Conservation Value
• Statewide Integrated Fish Distribution database
None of the above resources identified wetlands, streams, or protected species or habitats within the study area.
The NRCS Web Soil Survey maps the study area soil as Everett-Alderwood gravelly sandy loams, 6 to 15 percent
slopes, with a somewhat excessively drained drainage class. Everett-Alderwood series soils are not hydric soils.
Findings
ESA biologists Colleen Kroe, PWS, and James Watson conducted a field investigation to document site
conditions and determine whether wetlands or streams were present within the study area. Vegetation, soil, and
hydrological characteristics of the study area were assessed using principals for identifying wetlands from the
1987 U.S. Army Corps of Engineers Wetland Delineation Manual and the 2014 Regional Supplement to the
Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region – Version 2.0.
Streams were assessed using methodology consistent with the definition of streams in FWRC 19.05.060.
The field investigation focused on the undeveloped portions of the southern and western boundaries of the parcel
on which the school is located, and on the eastern halves of the two vacant parcels, where critical areas would be
most likely to occur, as well as areas within a 225 foot buffer of the parcel. The study area also consists of school
facilities that include multiple buildings and sports fields, forested upland to the west, and residential
development in surrounding adjacent areas.
The three parcels slope east from a steep slope located west of the study area. Informal east-west transects were
walked on the school parcel, and perpendicularly to the lowest areas on the two vacant parcel. No standing water,
saturation, or other indicators of wetland hydrology were observed within the study area. ESA biologists
examined soils in the lowest areas on the three parcels and did not observe hydric soil indicators. Soils were a
brown (10YR 3/2) sandy loam with no redoximorphic features. Vegetation included forested areas dominated by
red alder (Alnus rubra), western redcedar (Thuja plicata), Douglas fir (Pseudotsuga menziesii), with an
understory of (Himalayan blackberry (Rubus armeniacus), red huckleberry (Vaccinium parvifolium), swordfern
D202100688.00 – FWSD Illahee Middle School Critical Areas Study
4
SOURCE: ESA, 2021 D202100688.00 FWSD Illahee Middle School Critical Areas Study
Photo 1
Representative photo of upland vegetation in study area.
(Polystichum munitum), salal (Gaultheria shallon), and trailing blackberry (Rubus ursinus). Other areas were
almost entirely dominated by Himalayan blackberry (Photo 1). These dominant species are considered facultative
(FAC) and facultative-upland (FACU); these species commonly occur in both wetland and moist upland areas.
However, paired with a lack of wetland hydrology and soil indicators, the vegetation does indicate t he presence of
hydrophytic vegetation. Additionally, no areas that met the definition of a stream were observed in the study area.
Based on the reviewed information and conditions examined during the site visit, ESA confirms that there are no
wetlands or streams in, or within 225 feet, of the study area.
Limitations
Within the limitations of schedule, budget, scope-of-work, and seasonal constraints, we warrant that this
investigation was conducted in accordance with generally accepted environmental science practices, including the
technical guidelines and criteria in effect at the time this investigation was performed. The results and conclusions
of this report represent the authors’ best professional judgment, based on information provided by the project
proponent in addition to that obtained during this study. No other warranty, expressed or implied, is made.