HomeMy WebLinkAboutEX12_RS_Addendum_Biological_Assessment_and_Critical_Areas_Study_Re-Align_Environmental_240729_v1Addendum #1 - Critical Areas Report
1828 NE 20th St., Renton, Wa.
T23N R5E S5 - Renton, WA
Prepared for: Yin Yin Leong
c/o Ms. Tracy Hung
17404 161st Ave SE,
Renton, WA 98058
Prepared by: Re-Align Environmental
Bill Granger, Owner
14056 180th Ave SE
Renton, WA
(206) 790-6132
Bill@Re-alignenv.com
February 2, 2024
Docusign Envelope ID: 104DBDA6-11CD-4791-91FF-7DA2A96942C7
Addendum #1 - Critical Areas Report
1828 NE 20th St, Renton, Wa
February 2, 2024 i
Table of Contents
1.0 INTRODUCTION ................................................................................................................................. 1
4.0 DEVELOPMENT PLAN AND REGULATORY FINDINGS ........................................................................ 1
4.1.2 Monitoring Plan .................................................................................................................... 1
5.0 QUALIFICATIONS OF THE AUTHOR ................................................................................................... 3
6.0 REFERENCES ...................................................................................................................................... 4
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Addendum #1 - Critical Areas Report
1828 NE 20th St, Renton, Wa February 2, 2024
1
1.0 INTRODUCTION
On November 30, 2023, Re-Align Environmental submitted a critical areas report (Re-Align
Environmental, 2023) regarding the proposed development of the 1.17 acre parcel located at
1828 NE 20th Street, Renton, WA (Parcel #3343903201). On December 22, 2023, The City of
Renton staff provided comments on the CAR (City of Renton, 2023):
• An updated survey completed by a qualified surveyor showing the entire parcel of land and the
wetland boundary is needed. The provided survey from 2018 doesn’t appear to have the most
recent wetland delineation.
• It doesn’t appear that a typical cross section view of the wetland and its buffer to scale were
provided.
• It does not appear that the mitigation plan criteria in RMC 4-3-050L, Mitigation, Maintenance and
Monitoring were specifically addressed.
In subsequent dialog, it was agreed that the updated information in response to these comments
could be provided in an addendum to the CAR. This Addendum #1 is intended to fulfill this
agreement.
Figure 1 shows the formal survey of the wetland delineation flagging. Figure 2a – c show cross-
sections across the property and wetland/buffer. Figure 3 shows the detailed mitigation plan as
described in the original CAR1. Appendix A provides a code analysis addressing RMC 4-3-050L,
Mitigation, Maintenance and Monitoring. Appendix B provides a response to the comments. The
text below represents a revision and update to specific text from the CAR.
4.0 DEVELOPMENT PLAN AND REGULATORY FINDINGS
4.1.2 Monitoring Plan
The buffer restoration area will be monitored for a period of five years. Monitoring will be
conducted by a qualified wetland professional, including site inspections, reporting, and where
possible, participation in site maintenance.
Year 0 monitoring will include photo-documentation of the before and after site conditions.
Permanent photo stations will be established in the field and these stations will be maintained
throughout the 5-year monitoring period. Photos will be taken before removal of Himalayan
blackberry, after removal of alder saplings, and again within 30 days of completion of the
plantings. This third site visit will include evaluation of the plantings to ensure that the plantings
have been installed according to the planting plan.
1 The plan-sized PDFs shown in Figures 1 – 3 are being submitted separately from this document. The
required bond worksheet for the mitigation plan is also being submitted separately.
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1828 NE 20th St, Renton, Wa February 2, 2024
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Annual monitoring will be conducted beginning in Year 1 as follows:
• Year 1:
1 visit in Quarter 1 to monitor and maintain the site/plantings
1 visit in Quarter 2 to monitor and maintain the site/plantings
1 visit in Quarter 3 to monitor and maintain the site/plantings
1 visit in Quarter 4 to monitor and maintain the site/plantings
• Year 2: 1 visit early in the growing season to maintain the site/plantings
1 dry season visit to assess the need for irrigation
1 monitoring event in September
• Year 3: 1 visit early in the growing season to maintain the site/plantings
1 dry season visit to assess the need for irrigation
1 monitoring event in September
• Year 4: 1 visit early in the growing season to maintain the site/plantings
1 dry season visit to assess the need for irrigation
1 monitoring event in September
• Year 5: 1 visit early in the growing season to maintain the site/plantings
1 dry season visit to assess the need for irrigation
1 monitoring event in September (including final assessment)
Monitoring will consist of percentage aerial cover measurements taken at permanent
monitoring stations, which will be established after establishment of the mitigation site, or
during the initial Year 1 monitoring visit. While onsite, the assessment will include a general
walkover of the site to assess invasive species, survivability of planted materials, wildlife
observations, and needed maintenance (e.g., removal of invasives, trash and debris removal,
irrigation). Finally, the monitoring will include photographs taken from the permanent photo
points.
Woody vegetation will be evaluated for percentage cover by establishing 30-foot, circular plots,
which will be established during the initial Year 1 monitoring visit. Trees and shrubs within
these plots will be recorded by species and percentage aerial cover within the plot. In these
plots, herbaceous species will also be measured by species and percentage aerial cover within
the plot.
Within 30 days after the completion of each monitoring site visit, a summary letter report will
be provided to the city documenting the maintenance that was performed, monitoring results,
comparison to the goals and objectives, and any further recommended maintenance actions.
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Addendum #1 - Critical Areas Report
1828 NE 20th St, Renton, Wa February 2, 2024
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5.0 QUALIFICATIONS OF THE AUTHOR
Bill Granger is a Wetland Biologist with extensive training and experience in wetland and stream
science, aquatic and shoreline habitat restoration, wetland mitigation project design, wetland and
stream assessments and delineation, aquatic ecology, and development planning and permitting.
Bill earned a Bachelor’s Degree in Biology from Alfred University (NY) in 1987. Bill earned his
Master’s Degree in Aquatic and Wetlands Ecology from the Duke University School of Forestry
and Environmental Studies (NC) in 1988. Bill was issued Professional Wetland Scientist (PWS)
certification #366 by the Society of Wetland Scientists. Bill is also a Certified Erosion and Sediment
Control Lead (CESCL) in the state of Washington and is recognized as a CESCL by the Environmental
Protection Agency (EPA).
Bill has worked in the field of wetland delineation, permitting, and mitigation since the 1987 Corps
Manual was developed. In this capacity, he has conducted hundreds of delineations, mitigation
projects, and related reports for a wide range of development proposals, with a focus on
residential development. Bill has been involved in watershed restoration project planning for ski
areas in the Pacific Northwest, including riparian and wetland restoration in high-elevation,
mountainous terrain. Bill has also been the project manager and biologist for several salmon
habitat restoration projects along the Duwamish Waterway in Seattle, WA, including tidal wetland
creation and riparian corridor enhancement.
Bill is a Corps-certified wetland delineator, and is also a King, Pierce, and Snohomish County
Wetland Specialist. For a list of representative projects, please contact him at Re-Align
Environmental (Bill@Re-alignenv.com).
I certify that I prepared this report based upon my review of the subject property and the available
information from Masterbuilder Construction regarding past analysis of the subject property.
2-2-2024
Bill Granger – Owner Date
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Addendum #1 - Critical Areas Report
1828 NE 20th St, Renton, Wa
February 2, 2024 4
6.0 REFERENCES
City of Renton, 2023. E-mail from Andrew Van Gordon, Associate Planner, City of Renton, to Bill
Granger of Re-Align Environmental. Fri, Dec 22, 2023, 10:15 AM.
Re-Align Environmental, 2023. Critical Areas Report, 1828 NE 20th St., Renton, Wa. November
20, 2023.
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Figures
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Figure 1 - Survey
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Figure 2a - Cross-Sections
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Figure 2b - Cross-Sections
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Figure 2c - Cross-Sections
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Figure 3 - Mitigation Plan
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Appendix A – Code Analysis
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CAR Addendum Appendix A – Code Analysis - RMC 4-3-050L, Mi�ga�on, Maintenance and Monitoring
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Code Cita�on Applica�on to Proposed Project
4. Criteria for Approving Wetland
Alterations: Wetland alterations may only be
authorized after the City makes a written finding that
the proposal is consistent with the following criteria:
a. No Net Loss: Activities that adversely affect
wetlands and/or wetland buffers shall include
mitigation sufficient to achieve no net loss of
wetland function and acreage and to achieve,
where practicable, a net resource gain in
wetlands over present conditions. The concept
of “no net loss” means to create, restore
and/or enhance a wetland so that there is no
reduction to total wetland acreage and/or
function.
This proposed excep�on includes no impacts to
wetlands. The proposal is to install a new driveway in
the loca�on of an exis�ng driveway that has become infested with a monotypic thicket of Himalayan
Blackberry, and therefore has low habitat value. Due
to the configura�on of the lot, with a pipestem
driveway, the proposed site plan would redevelop the
exis�ng driveway in the pipestem, resul�ng in 0.14
acre of impact to the buffer. As compensa�on for this
unavoidable buffer impact, enhancement of the 0.23-
acre wetland is proposed to increase plant diversity
and to improve wildlife forage opportuni�es in the
wetland, which is currently dominated by young Red
Alder trees and also has low habitat value. Restora�on
of the 0.23-acre, remaining buffer area outside of the
driveway is also proposed to improve plant diversity
and to improve wildlife forage opportuni�es in the
remaining buffer. With 0.46 acre of restora�on/
enhancement proposed, the ra�o of buffer impact to
mi�ga�on would be 3.3:1.
b. Compensation for wetland alterations shall
occur in the following order of preference:
i. Re-establishing wetlands on upland
sites that were formerly wetlands.
ii. Rehabilitating wetlands for the purposes of repairing or restoring natural
and/or historic functions.
iii. Creating wetlands on disturbed upland
sites such as those consisting primarily of
nonnative, invasive plant species.
iv. Enhancing significantly degraded
wetlands.
v. Preserving Category I or II wetlands
that are under imminent threat;
provided, that preservation shall only be
allowed in combination with other forms
of mitigation and when the Administrator
determines that the overall mitigation
package fully replaces the functions and
values lost due to development.
vi. Cooperative compensation to
mitigation banks or in-lieu fee programs,
as indicated in subsection G9e of this
Section.
The proposal is to rehabilitate the onsite wetland area
and buffer area by removing invasive species, reducing
the dominance of Red Alder, and enhancing both with
plan�ngs to increase plant diversity and forage species
for wildlife, as specified in item ii.
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d. Mitigation Ratios for Wetland Buffer Impacts: Compensation for wetland buffer
impacts shall occur at a minimum one to one
(1:1) ratio. Compensatory mitigation for buffer
impacts shall include enhancement of degraded
buffers by planting native species, removing
structures and impervious surfaces within
buffers, and other measures.
With 0.46 acre of restora�on/ enhancement proposed,
the ra�o of buffer impact to mi�ga�on would be 3.3:1.
Enhancement of the 0.23-acre wetland is proposed to
increase plant diversity and to improve wildlife forage
opportuni�es in the wetland. Restora�on of the 0.23-
acre, remaining buffer area is also proposed to
improve plant diversity and to improve wildlife forage
opportuni�es in the remaining buffer.
g. Location: Compensatory mitigation shall be
provided on site or off site in the location that
will provide the greatest ecological benefit and
have the greatest likelihood of success.
Mitigation shall occur as close as possible to the impact area, within the same watershed sub-
basin, and in a similar habitat type as the
permitted alteration unless the applicant
demonstrates to the satisfaction of the
Administrator through a watershed- or
landscaped-based analysis that mitigation
within an alternative sub-basin of the same
watershed would have greater ecological
benefit.
The proposed compensatory mi�ga�on is proposed to
take place within the onsite wetland and buffer and
en�rely within the property limits.
h. Protection: All mitigation areas whether on
or off site shall be permanently protected and
managed to prevent degradation and ensure protection of critical area functions and values
into perpetuity. Permanent protection shall be
achieved through protective covenant in
accordance with this Section.
A 4-foot tall, wildlife passable fence (e.g., wood rail
fence) is proposed to be installed along the wetland
buffer boundary with wetland/sensi�ve area signs are installed on the fence every 100 feet. It is envisioned
that the wetland and buffer would be a dedicated
sensi�ve area easement as part of the excep�on
approval process.
4-3-050L MITIGATION, MAINTENANCE AND
MONITORING:
1. Mitigation Plan Required:
a. Criteria: Mitigation plans required through
the application of subsections G4 to G9 of this
Section shall comply with chapter 4-8 RMC. In
addition, the applicant shall:
i. Demonstrate sufficient scientific
expertise, the supervisory capability, and
the financial resources to carry out the
mitigation project; and
ii. Demonstrate the capability for
monitoring the site and making
corrections during the monitoring period
if the mitigation project fails to meet
projected goals; and
iii. Protect and manage, or provide for the
protection and management, of the
mitigation area to avoid further
development or degradation and to
provide for long-term environmental
health of the mitigation area; and
i. The applicant is self-funding the
mi�ga�on project with funds that are
already in place. The acquisi�on of
mi�ga�on material, installa�on of the
materials, monitoring, and maintenance
will be bonded up front with financial
guarantees, as part of the excep�on
process. Funds are also in place to retain
an environmental professional to manage
the mi�ga�on project.
ii. The applicant has retained Re-Align
Environmental to prepare the CAR and
mi�ga�on plan. The applicant plans to
use this firm, or another qualified
wetland consultant for monitoring and
correc�ve ac�ons.
iii. It is expected that the mi�ga�on area will
be placed into a sensi�ve area easement
as part of the excep�on process. The
en�re cri�cal area will be fenced off and
signed. In addi�on, the proposed house
and ADU represent the maximum
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iv. Provide for project monitoring and
allow City inspections; and
v. Avoid mitigation proposals that would
result in additional future mitigation or
regulatory requirements for adjacent or
abutting properties.
allowable development under the zoning
for the site and the cri�cal areas present
onsite.
iv. The CAR includes monitoring and
con�ngency measures to ensure the
long-tern environmental health of the
mi�ga�on area.
v. The proposed mi�ga�on would all be on
the subject property and has been
designed not to impact the development
poten�al of any adjacent proper�es. b. Mitigation Sequencing: If alterations to
critical areas are proposed for a non-exempt activity, the applicant shall evaluate alternative
methods of developing the property using the
following criteria in this order and provide
reasons why a less intrusive method of
development is not feasible. In determining
whether to grant permit approval pursuant to
RMC 4-3-050C, a determination shall be made
as to whether the feasibility of less intrusive
methods of development has been adequately
evaluated and that less intrusive methods of
development are not feasible.
i. Avoiding the impact altogether by not
taking a certain action or parts of an
action (usually by either finding another
site or changing the location on the site).
ii. Minimizing adverse impacts by limiting
the magnitude of the action and its
implementation, by using appropriate
technology, or by taking affirmative steps, such as project redesign, relocation, or
timing, to avoid or reduce impacts.
iii. Rectifying adverse impacts to
wetlands, Wellhead Protection Areas,
flood hazard areas, and habitat
conservation areas by repairing,
rehabilitating, or restoring the affected
environment to the historical conditions
or the conditions existing at the time of
the initiation of the project.
iv. Minimizing or eliminating the hazard
by restoring or stabilizing the hazard area
through engineered or other methods.
v. Reducing or eliminating the adverse
impacts or hazard over time by
preservation and maintenance operations
over the life of the action.
vi. Compensating for adverse impacts to
wetlands, Wellhead Protection Areas,
flood hazard areas, and habitat
i. The impact to the buffer is effec�vely the
re-development of the exis�ng driveway through the buffer. Because this
driveway is located with a pipestem, no
alterna�ve access is possible, and the
buffer impact cannot be avoided to allow
development of the property.
ii. The applicant’s development team has
prepared a s�e plan that minimizes the
impact to the buffer by providing the
minimum driveway width that is allow
able under City regula�ons, including fire
code.
iii. The exis�ng and proposed driveway in
the buffer will not allow for rec�fying the
impact area – it will remain driveway.
Wetland and buffer enhancements are
proposed to compensate for the
proposed buffer impact.
iv. See above.
v. As stated in ii., the proposed driveway is the minimum, allowable width. The
en�re enhanced wetland and remaining
enhanced buffer are proposed to be
enhanced and preserved for the li� of
the ac�on.
vi. The applicant has proposed wetland and
buffer enhancements as compensatory
mi�ga�on, to improve species diversity
and forage opportuni�es for wildlife, as
compared to the exis�ng condi�on. The
CAR includes a monitoring plan and
con�ngencies for remedial ac�on, when
necessary. These are included in the
financial guarantee for the mi�ga�on
proposal.
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conservation areas by replacing,
enhancing, or providing substitute
resources or environments. c. Based on Best Available Science: The
applicant shall demonstrate that the mitigation
is based on consideration of the best available
science as described in WAC 365-195-905; or
where there is an absence of valid scientific
information, the steps in RMC 4-9-250F are
followed.
No valid scien�fic informa�on is available for the
wetlands and buffer on this property. Previous
wetland evalua�ons are discussed in the CAR. The
CAR iden�fies the invasive species and prevalence of
Red Alder in the wetland and buffer, indica�ng low
plant species diversity and low forage opportuni�es
for wildlife. The CAR proposes the wetland and buffer
enhancement/ restora�on with a goal of improving
plant species diversity and forage opportuni�es for
wildlife. The CAR documents the qualifica�ons of the author to prepare such a mi�ga�on plan, mee�ng this
requirement.
d. Mitigation Alternatives and Location:
i. On-Site Mitigation: Mitigation shall be
provided on site, unless on-site mitigation
is not scientifically feasible due to
physical features of the property. The
burden of proof shall be on the applicant
to demonstrate that mitigation cannot be
provided on site.
ii. Off-Site Mitigation: When mitigation
cannot be provided on site, mitigation shall be provided in the immediate
vicinity of the permitted activity on
property owned or controlled by the
applicant, and identified as such through
a recorded document such as an
easement or covenant, provided such
mitigation is beneficial to the habitat area
and associated resources.
iii. In-Kind Mitigation: In-kind mitigation
shall be provided except when the
applicant demonstrates and the City
concurs that greater functional and
habitat value can be achieved through
out-of-kind mitigation.
i. Onsite mi�ga�on is proposed in the CAR.
ii. N/A
iii. The proposed impact to buffer is the re-
development of an exis�ng driveway in
the buffer, including the removal of a
thicket of Himalayan Blackberry in the
driveway and adjacent buffer. The
proposed compensatory mi�ga�on is the
enhancement and restora�on of the
remaining buffer and the wetland area on the subject property. Therefore, the
mi�ga�on can be considered “in-kind”.
e. Timing of Mitigation Plan – Final Submittal
and Mitigation Commencement: When a
mitigation plan is required, the proponent shall
submit a final mitigation plan for the approval
of the Administrator prior to the issuance of
building or construction permits for
development. The proponent shall receive
written approval of the mitigation plan prior to
commencement of any construction activity.
Where the City requires increased buffers
rather than standard buffers, it shall be noted
on the subdivision plan and/or site plan.
The Conceptual Mi�ga�on Plan is included with the
CAR and has been updated in this Addendum,
including a detailed mi�ga�on plan�ng plan and bond
worksheet. The proponent will not commence any
works associated with the project un�l all necessary
permits are issued.
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f. Timing of Construction and/or Building Permit Issuance: In order to ensure no loss of
critical area functions and values, development
permits shall not be issued prior to installation
and acceptance of all required mitigation unless
a surety device in an amount of three hundred
percent (300%) of the mitigation installation
contract amount is provided to the satisfaction
of the City. Mitigation activities shall be timed
to occur in the appropriate season based on
weather and moisture conditions.
The proponent is prepared to provide a surety device
in the amount of 300% of the mi�ga�on installa�on
contract amount. No contract has been prepared with
a contractor to date. However, a bond worksheet has
been submited with this CAR addendum.
2. Surety Devices:
a. Required for Mitigation Plans: For any mitigation plans required as a result of the
application of these regulations, a surety device
shall be required to ensure performance
consistent with RMC 4-1-230. The King County
Critical Areas Mitigation Bond Quantity
Worksheet may be used by applicants to
determine appropriate amounts sufficient to
cover the cost of conformance with the
conditions of this Section, including corrective
measures associated with work that is not
completed. After the Administrator determines
that mitigation has been successfully
completed in compliance with the approved
mitigation plan and the monitoring period has
expired, the surety device shall be released. The
City may collect against the surety device and
require the property owner to sign a property
access release form when work, which is not
completed, is found to be in violation of the conditions set forth in the mitigation plan
and/or the Administrator determines that the
site is in violation of the purposes of this
Section.
b. Time Period: The surety device shall be
sufficient to guarantee that structures,
improvements, and mitigation required by
permit condition perform satisfactorily for a
minimum of five (5) years after they have been
completed.
a. See above.
b. The CAR Addendum includes an updated
monitoring plan for the mi�ga�on site, including a
minimum of five years of monitoring according to RMC
4-3-050L, Mi�ga�on, Maintenance and Monitoring.
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Appendix B – Response to Comments
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Response to Comments:
Comment #1: An updated survey completed by a qualified surveyor showing the entire parcel of land and
the wetland boundary is needed. The provided survey from 2018 doesn’t appear to have the most recent
wetland delineation.
Response: Correct. The survey from 2018 was provided as part of the discussion regarding past
wetlands assessments on the site. The current delineation and survey has been provided in this
Addendum #1, Figure 1. The full sheet PDF of the survey has been submitted separately from this
Addendum.
Comment #2: It doesn’t appear that a typical cross section view of the wetland and its buffer to scale were
provided.
Response: The project engineer has prepared a set of plans showing three cross-sections across
the site. These are included in this Addendum #1, Figures 2a – 2c. The full sheet PDF of the cross-
sections has been submitted separately from this Addendum.
It does not appear that the mitigation plan criteria in RMC 4-3-050L, Mitigation, Maintenance and
Monitoring were specifically addressed.
Response: Revisions to Sections 4 and 5 of the CAR are included in this Addendum #1 to address
the mitigation plan criteria, and Appendix A of the CAR Addendum #1 includes a code analysis
addressing the pertinent criteria in RMC 4-3-050L.
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