HomeMy WebLinkAboutSWP272171(29) Wetland Mitigation Bank
Issue Paper
Wetland Enhancement
1/20/94
Wetland Enhancement vs. Creation and Restoration
Currently, the City's Wetland Ordinance does not recognize enhancement as an
acceptable form of compensatory mitigation for impacts to wetlands. Acceptable
compensation includes wetland creation, which is the creation of a new wetland in
a location where none previously existed, or wetland restoration, which is the re-
establishment of an historic wetland that no longer exhibits wetland functions due
to activities such as filling or draining. The latter of these approaches is generally
thought to be more likely to succeed.
Though definitions vary slightly, the Washington Department of Ecology in their
model ordinance defines enhancement as "actions performed to improve the
condition of existing degraded wetlands so that the functions they provide are of a
higher quality." The Environmental Law Institute similarly defines it as, "altering an
existing wetland to add, or increase, particular wetland values and functions to
levels not present under previous natural conditions, or to slow the natural
impairment of existing values and functions."
In the process of writing the City's Wetland Ordinance, enhancement was
considered as type of compensatory mitigation but was ultimately not included in
the Ordinance. The reasons for this are not entirely clear, but apparently City staff
felt that it would be too difficult to determine whether or not an enhancement effort
had successfully replaced the functions lost from the impacted wetland. This is a
legitimate concern, since it is difficult to accurately and consistently measure
wetland functions in the first place, and therefore would be difficult to objectively
measure the increase in value from an enhancement project. It was also felt that
allowing enhancement would result in a net loss of wetland acreage.
The use of wetland enhancement requires some method of wetland functional
valuation to determine adequate function replacement requirements. Wetland
functions can be measured by using semi-quantitative assessment techniques such
as the Wetland Evaluation Technique (WET) or the Habitat Evaluation Procedure
(HEP), but results from these methods can vary with the specific functions, values
and wetland types to be assessed. WET and HEP produce a quantitative rating by
evaluating a number of different characteristics of a wetland. Generally, these
assessment techniques should supplement qualitative assessment performed by
well qualified wetland specialists. All evaluation methods are ultimately subjective
making it unrealistic to expect consistent assessments even of the same wetland.
Under the City's current Ordinance, the amount of wetland compensation required
is based on acreage and wetland category. For example, a project impacting one-
half an acre of a Category III wetland must create or restore one acre of Category
III wetland elsewhere. The category (I, II, III) and type (forested, scrub-shrub,
emergent), as well as the area of a wetland impact are determined by a qualified
wetland ecologist. The created/restored wetland is intended to replace these lost
features. If allowed, enhancement would likely be based on similar area
replacement ratios. Still, some method of determining the increase in function
would be needed.
Do Other Jurisdictions Allow Enhancement?
Department of Ecology Model Ordinance
The Department of Ecology's Model Ordinance discusses enhancement stipulating
that applicants proposing enhancement shall identify how enhancement conforms
to the overall goals and requirements of a city's ordinance and established regional
goals. An enhancement project is deemed acceptable as long as enhancement for
one function or value will not degrade another function or value and that acreage
replacement ratios shall be doubled to recognize existing functional values. Also,
category I wetlands cannot be enhanced.
Kirkland
Kirkland's wetland mitigation requirements are explained in a memorandum titled
"Wetland Impact Analysis Guidelines." Mitigation plan guidelines are quite general
and do not exclude enhancement as a form of compensation. In all cases, the
project proponent must submit a mitigation plan to the city's wetland consultant for
review. Apparently, Kirkland has a very flexible approach relying heavily upon the
judgment of it's wetland consultant to determine whether or not a wetland
enhancement plan adequately replaces the wetland functions and values to be lost.
Redmond
Redmond's Wetland Ordinance allows enhancement stipulating that enhanced
wetlands shall have higher wetland values and functions than the altered wetland.
It also requires that the values and functions transferred shall be of equal or greater
quality to assure no net loss of wetland values and functions. Redmond's
enhancement ratio for impacts to Type II and III wetlands is 1 :1, and for Type I
wetlands is 2:1 .
Tukwila
Tukwila allows enhancement at a ratio of 1.5:1.
Should Renton Allow Enhancement?
Enhancing a wetland is technically feasible and usually results in improved functions
and values. The difficulty with enhancement as a compensatory mitigation is in
determining how much enhancement of a degraded wetland is needed to replace
the functions and values lost at the impacted wetland. Most city staff are not
qualified to make this judgment and the opinions of wetland ecologists will vary
making it difficult to objectively and consistently evaluate enhancement efforts.
While enhancement is possible, it is a mitigation approach that requires caution.
Introducing new functions or stimulating particular functions over others could
compromise the functions of an existing wetland. It is also difficult to know
whether new or enhanced functions proposed for a wetland can be sustained and
are ecologically sound.
Enhancement would benefit the City's mitigation bank project because it
would allow the City to alter and improve the low quality wetlands on the
mitigation bank sites. This would increase the number of wetland credits
the City could offer for sale from the bank sites and possibly decrease the
cost of creating credits.
On the other hand, enhancement could provide a less expensive alternative
to wetland creation or restoration and may be more easily pursued on-site,
thus reducing the potential users of the mitigation bank. Enhancement does
not generally increase the volume of floodwater that can be stored in a
wetland, and flooding is a significant concern in the lower portion of the
Black River drainage basin. Also, at the expense of the increase in
functional value, enhancement results in a net-loss of wetland acreage.
Conclusion
Many jurisdictions in the Puget Sound Region allow enhancement as a form of
compensatory mitigation. However, the cities surveyed did not have extensive
guidance on how enhancement should occur and be evaluated. Most stipulate that
the enhancement should replace the functions lost from the wetland impacted and
most required a wetland area greater than the impact to be enhanced.
Allowing enhancement gives the City more flexibility in restoring wetlands on the
mitigation bank sites, and probably will result in the creation of more "credits."
However, allowing enhancement city-wide may also make on-site mitigation less
expensive for a developer than using the City's mitigation bank, reducing the
potential number of customers and thus, the return on the City's investment in the
bank.
One possible approach to allowing enhancement on the bank sites and not
elsewhere could be the inclusion of a waiver in the Ordinance that would permit
enhancement for special, comprehensive projects, such as the mitigation bank
project, which are committed to and effective at increasing the City's wetland
functions and values (see 4-32-5.D in the Ordinance).
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TAZ ACRES ACRES ACRES ACRES TAZ RURAL URBAN URBAN URBAN TAZ RURAL URBAN JOBS
W _A=$ ACRE ACRE ACRE ACRE POP POP
40 0.00 137.96 43.11 181.07 40 0.00 11.45 0.20 11.66 40 0.00 1580.17 27.98
41 20.94 40.15 61.92 123.01 41 0.43 8.75 8.42 17.17 41 9.00 351.29 338.00
42 46.81 254.51 156.00 457.31 42 0.43 6.36 4.24 10.60 42 20.13 1619.12 1078.43
43 0.00 93.30 38.56 131.86 43 0.00 8.74 7.34 16.08 43 0.00 815.40 685.24
44 0.00 138.64 1.18 139.82 44 0.00 0.00 0.00 0.00 44 0.00 0.0 5 0.00
45 16.75 25.39 13.02 55.15 45 0.43 12.17 0.47 12.64 45 7.20 308.8 12.00
46 10.33 61.98 21.48 93.79 46 0.38 7.37 0.16 7.53 46 3.88 456.95 10.00
47 0.00 110.38 22.75 133.14 47 0.00 13.25 0.08 13.33 47 0.00 1462.59 9.00
48 75.74 117.57 105.59 298.90 48 0.38 8.04 1.62 9.66 48 28.48 945.14 191.00
49 43.43 12.71 37.49 93.63 49 0.38 47.68 0.00 47.68 49 16.33 605.98 0.00
50 25.51 16.53 33.00 75.04 50 0.56 4.63 1.03 5.66 50 14.39 76.57 17.00
51 50.63 117.51 97.32 265.47 51 0.56 18.73 0.47 19.20 51 28.56 2200.65 55.59
52 0.00 44.48 63.06 107.54 52 0.00 6.21 0.22 6.44 52 0.00 276.36 10.00
53 0.00 96.21 14.28 110.49 53 0.00 22.65 1.87 24.53 53 0.00 2179.56 180.00
54 0.00 14.80 1.90 16.70 54 0.00 5.88 0.00 5.88 54 0.00 87.04 0.00
55 0.00 0.00 0.00 0.00 55 0.00 0.00 0.00 0.00 55 0.00 0.00 0.00
56 0.00 0.00 0.00 0.00 56 0.00 0.00 0.00 0.00 56 0.00 0.00 0.00
57 15.64 37.47 40.40 93.50 57 0.44 7.39 1.60 9.00 57 6.91 277.05 .00
58
58 0.00 47.82 17.76 65.58 58 0.00 7.71 1.21 8.92 58 0.00 368.53 58.00
59 0.00 65.18 45.09 110.27 59 0.00 2.45 2.75 5.20 69 0.00 159.86 179.00
60 0.00 60.46 5.54 66.00 60 0.00 14.11 0.24 14.35 60 0.00 853.06 14.60
61 0.00 69.32 32.40 101.72 61 0.00 7.24 0.27 7.51 61 0.00 501.67 19.00
62 0.00 0.00 0.03 0.03 62 0.00 . 0.00 0.00 0.00 62 0.00 0.00 0.00
63 0.00 5.50 9.68 15.18 63 0.00 16.39 0.18 16.57 63 0.00 90.22 1.00
64 0.00 0.00 0.79 0.79 64 0.00 0.00 0.00 0.00 64 0.00 0.00 0.00
65 0.00 0.40 0.97 1.37 65 0.00 t4.
0.00 0.00 65 0.00 0.00 0.00
66 0.00 97.24 46.61 143.85 66 0.00 0.93 8.73 66 0.00 758.03 90.58
67 6.49 20.53 27.78 54.79 67 0.44 0.15 9.72 67 2.87 196.52 3.00
68 0.00 60.99 38.86 99.85 68 0.00 32.15 36.61 68 0.00 271.59 1961.00
69 0.00 0.15 1.73 1.89 69 0.00 0.00 0.00 69 0.00 0.00 0.00
70 0.00 0.00 1.48 1.48 70 0.00 0.00 0.00 0.00 70 0.00 0.00 0.00
71 54.18 99.36 137.41 290.95 71 0.44 27.40 7.29 34.69 71 24.06 2722.06 724.65
72 0.00 82.09 34.80 116.88 72 0.00 0.24 9.80 10.04 72 0.00 19.32 804.83
73 16.94 64.41 21.27 102.61 73 0.00 0.00 17.49 17.49 73 0.00 0.00 1126.33
74 0.00 49.93 35.54 85.47 74 0.00 7.41 15.47 22.88 74 0.00 369.84 772.29
75 0,00 76.33 29.55 105.88 75 0.00 0.00 18.92 18.92 75 0.00 0.00 1443.94
S 76 68.02 26.05 24.72 118.79 76 0.00 0.00 24.80 24.80 76 0.00 0.00 645.92
77 63.33 56.18 0.08 119.59 77 0.00 0.00 4.00 4.00 77 0.00 0.00 225,00
78 0.00 151.17 1.83 153.01 78 0.00 0.00 72.76 72.76 76 0.00 0.00 11000.00
79 0.00 95.08 44.31 139.39 79 0.00 0.09 30.89 30.98 79 0.00 8.28 2937.02
80 0.00 4676 47.51 94.27 80 0.00 0.24 10.52 10.75 80 0.00 11.04 491.81
el 0.00 73.25 17.221 90.471 811 0.00 0.41 15.04 15.45 81 0.00 30.36 1101.78
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RURAL URBAN UNUSED TOTAL POP./ POP./ JOBS/ POP+JOB/ TOTAL TOTAL TOTAL
FA ACRES ACRES ACRES ACRES TAZ RURAL URBAN URBAN URBAN TAZ RURAL URBAN JOBS
ACRE ACRE ACRE ACRE POP POP
0.00 0.00 0.00 0.00 166 0.00 0.00 0.00 0.00 166 0.00 0.00 0.00
0.00 0.00 0.00 0.00 167 0.00 0.00 0.00 0.00 167 0.00 0.00 0.00
0.00 0.00 0.00 0.00 168 0.00 0.00 0.00 0.00 168 0.00 0.00 0.00
0.00 0.00 1.81 1.81 169 0.00 0.000.00 0.00 169 0.00 0.00 0.00
0.00 0.00 0.00 0.00 170 0.00 0.000.00 0.00 170 0.00 0.00 0.00
0.00 0.00 0.00 0.00 171 0.00 0.00 0.00 0.00 171 0.00 0.000.00
0.00 1.46 0.47 1.93 172 0.00 0.00 0.00 0.00 172 0.00 0.00 0.00
173 0.00 15.91 13.86 29.77 173 0.00 0.00 55.05 55.05 173 0.00 0.00 875.80
174 0.00 24.13 3.34 27.47 174 0.00 0.00 36.27 36.27 174 0.00 0.00 875.00
175 0.00 31.52 4.70 36.22 175 0.00 0.00 24.59 24.59 175 0.00 0.00 775.00
176 0.00 47.67 14.34 62.01 176 0.00 0.00 10.39 10.39 176 0.00 0.00 495.14
177 0.00 16.19 18.22 34.41 177 0.00 1.35 26.87 28.21 177 0.00 21.84 435.00
178 0.00 26.37 29.39 55.76 178 0.00 0.00 12.04 12.04 178 0.00 0.00 317.44
179 0.00 44.37 4.16 48.53 179 0.00 0.00 39.55 39.55 179 0.00 0.00 1755.00
180 0.00 28.18 10.62 38.80 180 0.00 0.00 39.29 39.29 180 0.00 0.00 1107.00
181 0.00 17.26 13.37 30.63 181 0.00 0.64 0.00 0.64 181 0.00 11.04 0.00
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Interested Agencies fNOMOVA s James Schafer 705-7Y„3 Bob Lyon
Wash State Dept of Transportation Soos Creek Water/Sewer
P O Box 47329 P O Box 58039
Olympia WA 98504-7329 Renton WA 98058-1039
Jonathan Fordge Heather Stout 7 9(,- e z i 3 R. O. Aye
Metro King County Surface Water Mgmt Wash State Dept of Transportation
821 Second Avenue MS 81 111 Third Avenue STE 1100 P O Box 330310
Seattle WA 98104 Seattle WA 98101 Seattle WA 98133-9710
Bill Wolinski Dennis Dowdy Ross Ernst
City of Kent Public Works Tim Carlaw Phil Fraser
220 Fourth Avenue South City of Auburn Public Works City of Tukwila Public Works
Kent WA 98032-5895 25 West Main 6200 Southcenter Bldg
Auburn WA 98001-4998 Tukwila WA 98188
John E. Nelson .)P(-k/I 1416Nlow"o-
King County Drainage District#1 Z /VI WR.Sonu , sT)F tug
601 West Gowe SE r�E� WO, r�g1o9
Kent WA 98032
H:DOCS:Agency2:SSW:ps
Wetland Mitigation Bank Project
Attendees of 10/21/93 Public Meeting:
Tim Puryear Jim Douma H. Seelig
700 5th Avenue - STE 7600 521 Wall Street P 0 Box 1925
Seattle, WA 98104 Seattle WA 98121 Bellevue WA 98009
223-6292 448-4699 454-0885
Janet Garrow Rhys Sterling Paul B. Crane
701 - 5th Avenue - STE 7000 800 Bellevue Way NE-#376 The Boeing Company
Seattle WA 98104 Bellevue WA 98004 P O Box 3707 - MS 6;=44
587-0700 454-8272 Seattle WA 98124
965-1170
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H:DOCS:93-1035a:SSW:ps
Wetland Mitigation Bank Project
Attendees of 10/20/93 Public Meeting:
Colleen Cole-Bowron Martha Parker Laurinda Johnsen
601 Cedar Avenue South 18028 - 187th Ave SE P. O. Box 161
Renton WA 98055 Renton WA 98058 Renton WA 98057
432-5498
Ray E. Fournier Kent Lind T. Steger
4700 Talbot Road South 6027 - 28th Avenue NE 6209 - 30th Avenue NE
Renton WA 98055 Seattle WA 98115 Seattle WA 98115
526-0789 528-6019
Sally L. Steiner Richard Chase
17818 - 109th Avenue SE City of Kent
Renton WA 98055 220 -4th Avenue South
228-0124 Kent WA 98032-5895
859-3950
H:DOCS:93-1033a:SSW:ps
To Do
1 . setup date for second agency meeting
2. contract for surveying and wetland monitoring wells
3.
Products
agenda bills
committee reports
request for legal approval
request for risk management approval
issue paper
budget adjustment ordinance
sepa checklist
storm drainage report
project narrative
shoreline justification
neighborhood detail map
site plan
grading plan
landclearing/tree cutting plan
landscape plan
variance justification
conditional use permit justification
site plan approval justification
fill and grade justification
notice of shoreline permit
notice of sepa determination
shoreline permit decision
hydraulic project approval application
404 permit application
short term water quality modification permit
erc determination
erc staff report
hearing examiners staff report
preliminary design drawings
bid documents (special provisions)
license from drainage district no. 1
predesign report
final design report
fill disposal site permits (boeing/others)
sale agreement for fill
preconstruction vegetation management permit
right-of-entry
alternative analysis report
meeting minutes and agenda
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CITY OF RENTON Ly E I V D
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MEMORANDUMY . , �?
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DATE: April 28, 1992
TO: Larry
FROM: Lynn Guttmann
i
STAFF CONTACT: Mary Lynne Myer
SUBJECT: Purchase of Glacier Park Property from Surface Water
and Transportation Funds
We are considering expenditure of transportation and surface water utility funds in the
amount of$310,000 for the purchase of Parcel 1, wetlands, in the Glacier Park
Auction Group. There are two justifications for the purchase of this property:
Stormwater flood control and water quality, and transportation benefits. However, we
have several questions which need answers before we can proceed with the transaction.
SURFACE WATER
Surface Water Section will contribute $50,000 towards the purchase price of Parcel 1,
3, and 4. Parks will contribute the remaining $50,000 for a total of$100,000 purchase
price. An additional $260,000-270,000 would be needed to remove the LID
encumbrances on the property. This money would come from the Transportation
Division.
TRANSPORTATION
Our justification for the $260,000-270,000 expenditure is the possible future benefit to
the transportation system of the proposed 27th Street HOV lanes. The benefits to this
project are based upon right of way needed for widening 27th, access rights needed for
the facilitation of the operation of the HOV lanes and wetland banking costs as required
by the City's wetland ordinance and likely by the Corps of Engineers' regulations due
to the amount of fill which may be required for widening.
Transportation Division estimates the following fill requirements:
Parcel 1
1000 ft long by 30 ft. width = 3000 sq ft. (.68 acre)
The acknowledged value of the right of way which would be used for the widening is
$180,000. (1000 ft long x 30 ft wide x approximately $4-6 a sq ft = $120,000-
180,000)
This wetland is likely a Category 1, shrub-scrub wetland which must be replaced at a
3:1 ratio, according to our wetlands ordinance. (see attached description of the
wetlands from the Black River Water Quality Wetlands Inventory, Jan 1992, Jones and
Stokes, for the Stormwater Division.) In addition, mitigation will be needed for the
filling of another .68 acre on the adjoining City of Renton wetlands, also necessary for
widening of 27th Street. In total, 1.36 acres of wetland would be filled. At a 3:1 ratio,
4.08 acres of mitigation would be needed. Assuming that 4.08 acres of mitigation
would cost $22,000-$25,000 an acre, total costs for mitigation would be $88,000-
90,000.
The Transportation Division i n to cont' + $90,000 = 270,
for this strip of land. e understanding must be that the Transportation Division as
o way easement on this strip on Parcel 1 adjacent to 27th Street while Surface
Water Utility would be the owner of the parcel itself. It also must be understood that
the Transportation Division has "reserved" 4.08 acres in one of the newly acquired
wetland mitigation bank parcel thus meeting the project's obligation to the City's
wetland ordinance.
QUESTIONS
Is the wetland bank "reservation" concept legally feasible?
Is it possible for Surface Water Division to issue a right of way easement for this strip
of land to Transportation Division?
If not, can Transportation Division refund Surface Water Utility for the purchase price
of this strip of land and retain ownership?
We would appreciate your response as soon as possible as time is short, as you know.
cc: John Webley, Community Services Department
Mel Wilson, Transportation
Ron Straka, Utility
Priscilla Pierce, Administration
Lee Haro, Transportation
Lee Wheeler, Fire Department
attachment
CITY OF RENTON
MEMORAIINDUM
DATE: April28, 1992
TO: Lynn Guttmann
Mel Wilson
FROM: Mary Lynne Myer
SUBJECT: Wetland banking options for wetland parcel 1
Parcel 1 is not a low grade wetland by the definitions in the wetlands ordinance. The
Storm Water's Wetland Inventory— Black River Water Quality Management
Plan/ESGRW (p. 24) describes it as:
Size : one of the largest wetlands in the study area. Covers entire area between
27th Street, Lind Avenue, Springbrook Creek and southern boundary of
property.
Elevation: the wetland is at original valley floor elevation and has not been
filled.
Ground water recharge: high values
Infiltration and recharge: high values due to its lack of a surface water inlet
which allows flood flows to remain in the wetland for exceeded lengths of time.
Flood storage capability: very high values. Wetland is at original elevation and
is considerably lower than surrounding fill area. Function is enhanced because
of large size, dense vegetation, and location to fill.
Shoreline anchoring: very high values. Dense vegetation line the banks adjacent
to Springbrook reducing turbulence from overland flow during flood event.
Water purification: very high values. Large size, dense stands of cattails, and
long residence time of water contribute to this value.
Food chain support: medium values due to lack of open water.
Wildlife habitat: medium values due to lack of open water.
Active passive recreation: high values.
Memo to Lynn Guttmann and Mel Wilson
April 28, 1992
Page 2
Although it has not been officially classified by a wetlands specialist, I would guess it
is a Class 1 wetland, shrub-scrub vegetation class. Replacement ratios under the
ordinance are 3:1.
If portions of the wetland were filled for any reason, some other area would have to be
excavated and established as a wetland for mitigation in order to keep with the
ordinance's requirement for no net loss. Because this wetland does not contain any fill
at all, another area would be needed for replacement.
The ordinance does allow variances for projects which meet several public purpose
tests. It appears that this project would meet 2 of 4 variance criteria for public projects.
My major concern is how do we address the net loss of wetland area if fill is placed in
the wetland. We have adequate area in the wetland mitigation bank but we do not have
any money for a plan or for excavation. If a mitigation plan can be funded for the
bank area, and if we can pay for excavation it would seem we have met the
requirements of our own ordinance and we would also meet DOE and COE
requirements.