HomeMy WebLinkAboutEXECUTIVE SUMMARY�I1
TALASAEA
CONSULTANTS, INC.
WINTER 2023
EXECUTIVE SUMMARY
TO: Julia Reeve FROM: Bill Shiels
OF: Unico Properties LLC PROJECT: Unico Longacres
EMAIL: juliar@unicoprop.com TAL-1952
DATE: 20 January 2023
REFERENCE: UNICO Longacres — Renton, Washington
SUBJECT: Talasaea Response To Otak Mitigation Plan Peer Review (2 November 2022)
This memorandum contains the Executive Summary addressing the Peer Review comments made by
Otak on 2 November 2022 regarding the Critical Areas Report for the Unico Longacres project. The
Critical Areas Report and Conceptual Mitigation Plan will be forwarded with this memorandum for
reference.
EXECUTIVE SUMMARY
On November 2, 2022, Otak's Peer Review Memorandum included 18 comments. This Executive
Summary responds to each of the 18 items.
1. (Comment from previous peer review memo dated June 9, 2022) Wetland boundaries were flagged in
the field and verified during the May 18, 2022 site investigation. However, the Letter Report does not
include a mapping accuracy statement indicating if the flags were professionally surveyed, located
with a GPS, or estimated using aerial photography and previously prepared maps by others.
Action by the applicant: Provide an accuracy statement for the wetland boundaries shown on Figures
3 and 4 in the Letter Report.
Outcome: Resolved. The Mitigation Plan includes an accuracy statement describing that wetland
flags were located in the field with a hand-held GPS device with sub -meter accuracy.
RESPONSE: Resolved. No response necessary.
2. The wetland categories and buffer widths for Wetlands A, C, and F described in the Mitigation Plan
are consistent with the wetland boundaries, classifications, and buffer widths reviewed previously,
and are consistent with RMC 4-3-050.F and 4-3-050.G.
RESPONSE: Resolved. No response necessary.
3. Clarify if a conservation easement or similar protective instrument for the Boeing mitigation wetlands
area encumbers the northwest corner of the project site where the buffer impacts are proposed.
Conservation easements are commonly required for compensatory wetland mitigation projects. If a
conservation easement does exist, then it should be amended to reflect the future site condition and
recorded for compliance with RMC 4-3-050(G)(3) — Native Growth Protection Areas. If not, then the
applicant should address project compliance with RMC 4-3-050(G)(3).
RESPONSE: A conservation easement is not recorded against the property. The applicant proposes to
identify the buffer area when the Binding Site Plan is modified and to encumber the property with a single
conservation easement once the Master Plan for Longacres is complete and approved.
4. The potential buffer enhancement areas shown on sheets 9-9A are different than what is shown on
Figures 10, 11, and 12. Figure 9A should only show the 100-foot offset from the edge of the soccer
fields to determine indirect wetland impacts pursuant to Washington Department of Ecology's
(Ecology) Wetland Mitigation in Washington State, Part 1: Agency Policies and Guidance (Version 2,
dated April 2021, Publication 21-06-003). Clarify why potential buffer enhancement areas are limited
to only the west side of the paved pedestrian trail. Other potential buffer enhancement opportunities
appear to the north as proposed on Figures 10 and 11 in the Mitigation Plan.
RESPONSE: Figures are updated to include restoration on both sides of the pedestrian trail.
5. Remove the red post -construction buffer line shown on Figures 10, 11, and 12 of the Mitigation Plan.
If further buffer reduction is proposed as shown, then additional mitigation will be required after
justification is provided for the additional buffer reduction. Maximize all buffer enhancement
opportunities between the edge of development and Wetland A, excluding the paved trail, to minimize
impacts to habitat functions in Wetland A. Consider other buffer areas along the east side of Wetland
A north of the project but within the Unico Longacres property that are grass for additional buffer
mitigation (if feasible).
RESPONSE: Resolved. Figures have been updated to show correct buffer and mitigation areas.
6. The proposed 0.50 credit purchase from the Springbrook Wetland Mitigation Bank as mitigation for
indirect wetland impacts to Wetland A appears consistent with Section 3.4.5.1 (Determining the area
of indirect impact) of Ecology's Wetland Mitigation in Washington State, Part 1: Agency Policies and
Guidance (Version 2, dated April 2021, Publication 21-06-003), and is allowed per 4- 3-
050(J)(4)(b)(vi). Based on current Best Available Science, the inner wetland buffer typically provides
water quality functions and buffer beyond that is typically for wildlife functions. This partial loss of
functions is consistent with the partial credit purchase because the wetlands will still provide
hydrologic and water quality functions, but habitat functions will be partially reduced.
RESPONSE: Resolved. No response necessary. The CUP Decision acknowledges the requested ratio.
7. Include tree removal within the buffer between the edge of the sports fields and existing sidewalk as
shown on the Demo Plan sheets C1.01 and C1.04 as additional buffer impacts. Characterize these
impacts as temporary or permanent, and any temporal loss from temporary impacts. Per RMC 4-3-
050(H)(2), an approved alteration of the minimum buffer widths must include demonstration from the
application that through enhancing the buffer and use of the low impact development strategies the
reduced buffer will function at a higher level than the standard buffer.
RESPONSE: Resolved. See Chapter 6.2. Buffer enhancement will provide higher functionality through
species diversity and structure.
8. Identify the amount of buffer reduction from the proposed sports fields, indirect wetland impacts, and
total buffer enhancement. Include a no net loss statement pursuant to RMC 4-3-050(J)(4)(a).
RESPONSE: Buffer reduction areas are provided in Figure 9a, and in Chapter 7 of the report. No -net -loss
statement is provided in Chapter 6.2.
9. Identify and include temporary buffer impacts in the Mitigation Plan per RMC 4-3-050(H)(2), and
include these areas in the monitoring plans to ensure restoration following construction.
RESPONSE: Temporary buffer impacts will include disturbance due to invasive species removal and
habitat feature delivery and installation. All disturbances will be restored post construction. See Chapter
7.3.2.
10. Revise buffer impacts and the mitigation credit purchase as necessary.
RESPONSE: Revised buffer impacts are revised in Figure 9a. Credit purchase is not necessary since
mitigation will occur on the Site.
11. Chapter 7 of the Mitigation Plan should be revised to state that mitigation will be provided for 15,467
SF of indirect impacts to Wetland A. The report currently lists the potential buffer enhancement area
(15,151 SF) requiring the credit purchase. Update the credit purchase accordingly.
RESPONSE: Chapter 7 of the Mitigation Plan is revised to identify the revised calculations. Bank credits
will be used for indirect impacts to Wetland A. Buffer impacts will be mitigated on the Site.
12. The credit purchase and mitigation ratio are determined by the mitigation banking instrument per
RMC4-3-050(J)(4)(e). The applicant has provided clear rationale and justification for the proposed
0.5:1 impact to credit purchase ratio since the mitigation banking instrument does not provide a
standard ratio for indirect wetland impacts.
RESPONSE: Resolved. No response necessary.
13. The Mitigation Plan should be updated to address how the habitat logs will be delivered and installed,
identify any potential temporary impacts to existing riparian vegetation, and how any temporary
impacts will be restored if necessary.
RESPONSE: Habitat logs are identified in Figures 10-14. All temporary impacts will be restored with
native vegetation.
14. Consider snagging any hazard trees in the remaining buffers that are recommended to be felled by a
certified arborist following construction. Hazard trees removed in the buffers should be replaced at a
minimum mitigation ratio of 3:1.
RESPONSE: Noted. Hazard trees felled will be identified and replaced with a minimum mitigation ratio of
3:1. Woody material from felled trees will be placed in the buffer areas as additional wildlife habitat
enhancements.
15. Add an area qualifier (e.g., square feet) to Performance Standard 1A.
RESPONSE: Area qualifier added to Performance Standard 1A.
16. A mitigation sequencing statement is provided, and avoidance and minimization measures have been
identified and employed where feasible, including alternative site layouts and designs, pursuant to
RMC 4-3-050(L)(1)(b).
RESPONSE: Resolved. No response necessary.
17. The Mitigation Plan prepared by TCI generally the independent buffer study criteria per RMC 4-3-
050(G)(9)(d)(ii) that is necessary to authorize approval of alternate buffer widths.
RESPONSE: Resolved. No response necessary.
18. The project proposes using natural grass for two of the five sports fields plus the keeper/training area,
and artificial or synthetic turf for the remaining fields. The project site is approximately 1,150 feet from
Springbrook Creek, which has documented salmonid presence. The stormwater system includes a
water quality treatment system, but stormwater will discharge untreated at high flows to Pond B that
has a direct surface water connection to Wetland A and Wetland F that discharge to Springbrook
Creek. Synthetic turf fields have related environmental concerns with respect to using rubber tires as
fill, in addition to the recently documented toxic impacts to fish from 6PPD- quinone associated with
rubber tires. The applicant is looking to use environmentally friendly, non -toxic, materials for the fill.
The applicant has not decided on the fill material at this time. If rubber tires is selected, then the
findings in the Habitat Assessment (Chapter 4) should be updated and effects determinations
revisited based on the Best Available Science.
RESPONSE: Resolved via SEPA conditions included in CUP decision. No additional response required.
If you have any questions or need further clarification regarding any of the above information, please
contact Kirstie Englis or me at (425) 861-7550, or at bshiels@talasaea.com.
Sincerely,
TALASAEA CONSULTANTS, INC.
William E. Shiels
Principal