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HomeMy WebLinkAboutRS_Final_Mitigation_PlanCRITICAL AREAS REPORT AND CONCEPTUAL MITIGATION PLAN SOUNDERS FC CENTER AT LONGACRES RENTON, WASHINGTON Prepared for: Unico Properties, LLC 1215 Fourth Avenue Suite 600 Seattle, Washington 98161 Prepared by: TALASAEA CONSULTANTS, INC. Woodinville, Washington 7 October 2022 (Revised 20 January 2023) Critical Areas Report and Conceptual Mitigation Plan Sounders FC Center At Longacres Renton, Washington Prepared for: Unico Properties, LLC 1215 Fourth Avenue Suite 600 Seattle, Washington 98161 Prepared by: Talasaea Consultants, Inc. 15020 Bear Creek Road NE Woodinville, Washington 98077 (425) 861-7550 7 October 2022 (Revised 20 January 2023) Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page i EXECUTIVE SUMMARY EXECUTIVE SUMMARY The attached Critical Areas Report and Conceptual Mitigation Plan (“Mitigation Plan”) informs the entitlement and development of the proposed Sounders FC Center at Longacres (the “Site”), location on a portion of the Longacres “Campus1.” Previously, Talasaea prepared and submitted the Critical Areas Existing Conditions Report dated 22 April 2022 (“Existing Conditions Report”). Based on Otak’s 3rd party review comments2, the City of Renton (“City”) concurred with the Existing Conditions Report’s conclusion that only Wetland A is subject to the City’s critical areas regulations as it relates to the Sounders’ entitlement and development of the Site. The City also concurred that Wetland A requires a 100’ buffer from the proposed improvements. This Mitigation Plan concludes that the proposal has no direct impact to Wetland A, although it will alter approximately 30,452 sf of Wetland A’s buffer. Wetland A and its associated buffer impact is identified in Figure 9 and depicted below. Following the guidelines outlined by the Washington State Department of Ecology Publication 21-06- 003, the alteration will be achieved through the use of Wetlands as Buffers (often referred to as “paper fill”). Conversion of wetland into buffer does not actually fill any wetland; wetland converted into buffer still functions as a wetland in the landscape. Approximately 16,331 sf of Wetland A will be indirectly impacted. There will be no net loss of wetland area or function resulting from the proposed development plan. Proposed Mitigation: Springbrook Creek Wetland Mitigation Bank Credit Purchase. Unico will mitigate the 16,331 sf of indirect wetland impacts at the nearby Springbrook Creek Mitigation Bank. As authorized by the Springbrook Creek Wetland and Habitat Mitigation Bank Instrument, the applicant proposes a mitigation ratio of 50 percent (i.e., 0.5:1.0, or 8,166 sf) for its indirect impact to Wetland A that causes no or only partial loss of ecological functions to the wetland. The 50 percent ratio is also consistent with other wetland mitigation banks in Washington State and is in general agreement with the Washington State Department of Ecology Publication 21-06-003. Buffer Enhancement. In addition, Unico proposes to enhance the upland buffer of Wetland A existing between the proposed field locations and the wetland edge, an area of approximately 30,452 sf in size. Most of this buffer area is in good ecological condition; however, some areas are dominated by invasive plant species and would benefit from significant enhancement. Unico proposes buffer enhancement of approximately 5,500 sf within the adjacent buffer area located between the proposed fields and Wetland A, along with maintenance and monitoring for a period of five years as set forth in RMC 4-3-050L(2) and RMC 4-3-050L(3). 1 The “Site” and “Campus” are defined in Section 2.1 2 Otak Peer Review Memorandum, Longacres Unico Property (Seattle Sounders FC Performance Center) – Wetlands Peer Review, dated 9 June 2022. Depiction of wetland buffer Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page ii The Mitigation Plan also provides a Biological and Habitat Assessment (Ch. 4). The Biological and Habitat Assessment identifies five ESA-listed or candidate species potentially within the Project-affected areas. This Mitigation Plan concludes that the construction and operation of the Sounders facilities will not directly affect any ESA-listed or candidate species and will not result in a “take” as defined by the Endangered Species Act. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page iii TABLE OF CONTENTS Chapter 1. Introduction..............................................................................................................1 1.1 Purpose of Report..............................................................................................1 1.2 Statement of Accuracy.......................................................................................1 1.3 Qualifications.....................................................................................................1 Chapter 2. General Property Description and Land Use...........................................................2 2.1 Project Location.................................................................................................2 2.2 General Property Description............................................................................2 2.3 Methodology......................................................................................................3 2.4 Background Data Reviewed..............................................................................3 2.5 Field Investigation.............................................................................................3 Chapter 3. Results......................................................................................................................4 3.1 Analysis of Existing Information ......................................................................4 3.1.1 USFWS Wetlands Online Mapper (National Wetlands Inventory) ..................4 3.1.2 Natural Resources Conservation Service Soil Survey.......................................5 3.1.3 SalmonScape and StreamNet Databases ...........................................................5 3.1.4 WDFW Priority Habitats and Species Database ...............................................5 3.1.5 City of Renton Critical Areas Mapping.............................................................5 3.2 Analysis of Existing Field Conditions...............................................................5 3.2.1 Wetland A..........................................................................................................6 3.2.2 Wetland C..........................................................................................................6 3.2.3 Wetland F...........................................................................................................6 3.2.4 Pond B ...............................................................................................................7 3.2.5 Feature D ...........................................................................................................7 3.2.6 Feature G ...........................................................................................................7 3.3 Vegetation..........................................................................................................7 3.4 Wildlife Observations........................................................................................8 Chapter 4. Biological & Habitat Assessment............................................................................9 4.1 Species & Habitat Information..........................................................................9 4.2 Listed Species & Critical Habitat Potentially Occurring.................................10 4.2.1 Puget Sound Chinook ESU..............................................................................11 4.2.2 Puget Sound Steelhead DPS............................................................................13 4.3 Effects Analysis...............................................................................................14 4.3.1 Direct Effects...................................................................................................14 4.3.2 Indirect Effects.................................................................................................15 4.3.3 Accidental Release of Contaminants...............................................................15 4.3.4 Permanent Stormwater & New Impervious Surfaces......................................15 4.4 Effects Determinations....................................................................................16 4.4.1 Marbled Murrelet.............................................................................................16 4.4.2 Streaked Horned Lark......................................................................................16 4.4.3 Yellow-Billed Cuckoo.....................................................................................16 4.4.4 Bull Trout Coastal-Puget Sound DPS..............................................................17 4.4.5 Puget Sound Chinook ESU..............................................................................17 Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page iv 4.4.6 Puget Sound Steelhead DPS............................................................................17 4.5 Compliance with Sections 7 & 9 of the Endangered Species Act (ESA)........18 Chapter 5. Regulatory Review ................................................................................................18 5.1 Federal and State Regulations .........................................................................18 5.1.1 Washington State Regulations.........................................................................18 5.1.2 Federal Regulations.........................................................................................18 5.2 City of Renton Municipal Code – Wetlands ...................................................18 Chapter 6. Proposed Development & Impacts........................................................................19 6.1 Project Description..........................................................................................19 6.1.1 Proposed Stormwater Management.................................................................19 6.2 Wetland Buffer Alteration...............................................................................20 Chapter 7. Mitigation ..............................................................................................................20 7.1 Agency Policies and Guidance........................................................................20 7.2 Proposed Mitigation ........................................................................................20 7.2.1 Mitigation via Springbrook Creek Mitigation Bank........................................20 7.2.2 Wetland Buffer Enhancement..........................................................................21 7.3 Wetland Buffer Enhancement Details.............................................................21 7.3.1 Decompaction and Topsoil..............................................................................21 7.3.2 Habitat Features...............................................................................................22 7.3.3 Planting Plan....................................................................................................22 7.3.4 Temporary Irrigation System...........................................................................22 7.3.5 Mitigation Goals, Objectives, & Performance Standards................................22 Chapter 8. Mitigation Sequencing...........................................................................................23 8.1 Mitigation Sequencing.....................................................................................23 8.2 Mitigation Alternatives & Location.................................................................28 8.3 Mitigation Timing............................................................................................29 8.3.1 Post-Construction Approval ............................................................................29 8.3.2 Post-Construction Assessment.........................................................................29 Chapter 9. Monitoring Plan.....................................................................................................30 9.1 Monitoring Reports..........................................................................................30 9.2 Monitoring Methods........................................................................................30 9.2.1 Assessment of Vegetation Survival.................................................................30 9.2.2 Photo Documentation ......................................................................................31 9.2.3 Wildlife............................................................................................................31 9.2.4 Site Stability.....................................................................................................31 Chapter 10. Maintenance & Contingency.................................................................................31 Chapter 11. Surety Devices.......................................................................................................32 Chapter 12. Summary................................................................................................................33 Chapter 13. References..............................................................................................................35 Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page v LIST OF FIGURES Figure 1. Vicinity & Driving Directions Figure 2. Parcel Map Figure 3. National Wetlands Inventory Figure 4. NRCS Soil Map Figure 5. Fish Passage & Salmonid Presence Figure 6. Priority Habitat and Species (PHS) Figure 7. City of Renton GIS – Critical Areas Figure 8. Existing Conditions Figure 9. Proposed Site Plan with Buffer Figure 9a. Proposed Site Plan with Buffer - Enlargement Figure 10. Conceptual Mitigation Planting Plan Figure 11. Conceptual Mitigation Planting Plan – Enlargement 1 Figure 12. Conceptual Mitigation Planting Plan – Enlargement 2 Figure 13. Conceptual Mitigation Planting Plan – Enlargement 3 Figure 14. Candidate Plant List Figure 15. Candidate Plant List (Continued) Figure 16. Details Figure 17. General Notes for Habitat Features LIST OF TABLES Table 1. Wildlife species observed on the Longacres Campus......................................................8 Table 2. Projected schedule for performance monitoring and maintenance events.....................30 LIST OF APPENDICES Appendix A. Wetland Rating Forms and Figures, Talasaea Consultants, Inc., 2022 Appendix B. Wetland Determination Data Forms, Talasaea Consultants, Inc., 2022 Appendix C. Peer Review Memorandum, Otak, Inc., 2022 Appendix D. USFWS Information for Planning and Conservation Report Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2021 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 1 CHAPTER 1. INTRODUCTION 1.1 Purpose of Report This report is the result of a critical areas study for the Sounders FC Center at Longacres that is proposed for construction on the Unico Longacres property (referred to hereinafter as the “Project Site” or “Site”) located west of Oakesdale Avenue SW in Renton, Washington. The purpose of this report is to identify and describe the critical areas (wetlands, streams, fish, and wildlife habitat areas, etc.) on or within the vicinity of the Site and provide a detailed discussion of impacts to critical areas and required mitigation. This report has been prepared to comply with the City of Renton Municipal Code (RMC) Section 4-3-050 Critical Areas Regulations. This report will provide and describe the following information: General Property Description; Methodology for Critical Areas Investigation; Results of Critical Areas Background Review and Field Investigation; Current Existing Condition Descriptions; Regulatory Review; Critical Area Analysis; Description of the Proposed Project; Impacts and Mitigation; Maintenance and Contingency; Financial Guarantees; and Project Summary. 1.2 Statement of Accuracy Stream and wetland assessments and classifications were conducted by trained professionals at Talasaea Consultants, Inc., and adhered to the protocols, guidelines, and generally accepted industry standards available at the time the work was performed. The conclusions in this report are based on the results of analyses performed by Talasaea Consultants and represent our best professional judgment. To that extent and within the limitation of project scope and budget, we believe the information provided herein is accurate and true to the best of our knowledge. Talasaea Consultants does not warrant any assumptions or conclusions not expressly made in this report or based on information or analyses other than what is included herein. 1.3 Qualifications Field investigations and evaluations were conducted by Talasaea staff including Bill Shiels, Principal; David Teesdale, PWS, Senior Ecologist; Tim Nightengale, Senior Ecologist; and Jacob Prater, Ecologist. Bill Shiels has a Bachelor’s Degree in Biology from Central Washington University and a Master’s Degree in Biological Oceanography from the University of Alaska. He has over 40 years of experience in wetland delineations and mitigations. David Teesdale has a Bachelor’s Degree in Biology from Grinnell College, Iowa, and a Master’s Degree in Ecology from Illinois State University. He has over 20 years of experience in wetland delineations and biological evaluations. Tim Nightengale has a Bachelor’s Degree in Wildlife Biology from the University of Nebraska-Kearney and a Master’s Degree in Fishery Resources from the University of Idaho. He has over 20 years of experience in biological evaluation, ecological research, and environmental science. Jacob Prater has a Bachelor’s Degree in Environmental Studies with a focus in Ecological Systems from Seattle University and a Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 2 Master’s Degree in Systems Ecology from the University of Montana. He has three (3) years of experience in ecological science and environmental evaluation and a year of experience in wetland delineations and mitigations. CHAPTER 2. GENERAL PROPERTY DESCRIPTION AND LAND USE 2.1 Project Location The Seattle Sounders FC Performance Center at Longacres is proposed to be located at the Longacres Office Park in Renton, Washington (the “Campus”, Figure 1). The approximately 108-acre Campus is composed of 18 parcels located west of Oakesdale Avenue SW in Renton, Washington (Figure 2). The Sounders “Site” (also “Project Site”) includes all or a portion of seven of these parcels (King County tax parcels 0886700110 (Lot 11), 0886700120 (Lot 12), 0886700130 (Lot 13), 0886700140 (Lot 14), 0886700220 (Lot 22), 0886700210 (Lot 21), and 0886700370 (Tract B))3. The Public Land Survey System location of the Site is the SE ¼ of Section 24, Township 23 North, Range 4 East, Willamette Meridian (W.M.). The property is bordered to the north by Parcel 2423049022, developed with an office building and associated parking, and the location of Wetland F, to the west by Tract A, to the south by office buildings and associated parking, and to the east by Oakesdale Avenue Southwest. The Site includes office building 25-20 located on Parcel 0886700220 (Lot 22). Shared parking facilities are located on Parcel 0886700210 (Lot 21), where a portion of the existing parking lot will be redeveloped for Sounders’ secure first-team players' parking. The Site (excluding the office building and shared parking) is approximately 22 acres in size and is bordered to the west by Wetland A and Pond B. The Site, including Building 25-20 and shared parking, is bordered on the east by Oakesdale Avenue SW, which provides access to the Site. 2.2 General Property Description The Longacres Unico property is considered fully developed regardless of the appearance of the Site. Aside from the built environment captured by the buildings and associated parking areas, much of the remainder of the property has undergone manipulation since the 1930s. The majority of the eastern and northern portions of the property are developed and feature two large office buildings and associated parking areas, with various other access roads and infrastructure throughout the Site. The Site also features two large ponds and various other stormwater features. Many of these features were the result of mitigation associated with the initial Boeing development that took place during the 90s and early 2000s (see Existing Conditions Letter Report, 29 April 2022; Talasaea Consultants 2022). The areas directly adjacent to the buildings and parking areas are vegetated by maintained lawn and other landscape plantings. Other plant communities across the site are composed of native tree species, including black cottonwood (Populus balsamifera ssp. trichocarpa) and red alder (Alnus rubra), with occasional Douglas-fir (Pseudotsuga menziesii), western redcedar (Thuja plicata), bigleaf maple (Acer macrophyllum), and others. The Site also features several shrubs 3 Lot and Tract references provided are from the Boeing Longacres Property Second Amended Binding Site Plan, recorded at King County Recording No. 20050504000673, City of Renton, King County, WA, (the “BSP”). Minor adjustments to a few lot lines will be made by lot line adjustment to fit the final field/site configuration. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 3 and saplings including Sitka willow (Salix sitchensis), salmonberry (Rubus spectabilis), vine maple (Acer circinatum), and others. Throughout the Site, there is a prevalence of non-native and invasive Himalayan blackberry (Rubus armeniacus), reed canarygrass (Phalaris arundinacea), and English ivy (Hedera helix). 2.3 Methodology This critical area analysis consists of preliminary assessments of the Site and the immediate surrounding area using published environmental information. This information includes: 1) Wetland and soils information from resource agencies; 2) Critical Areas information from the City of Renton and King County; 3) Orthophotography and LiDAR imagery; and, 4) Relevant studies completed or ongoing in the vicinity of the Site. The second part consisted of site investigations where direct observations and measurements of existing environmental conditions were made. Observations included plant communities, soils, hydrology, and stream conditions. This information was used to help characterize the Site and define the limits of critical areas on-site and off-site for regulatory purposes. 2.4 Background Data Reviewed Background information from the following sources was reviewed prior to field investigations: US Fish and Wildlife Service (USFWS) Wetlands Online Mapper (National Wetlands Inventory, NWI) (https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands-mapper/); Natural Resources Conservation Service (NRCS), Web Soil Survey (www.websoilsurvey.nrcs.usda.gov/app); King County iMap (King County, 2022); City of Renton COR Maps (City of Renton, 2022) Washington Department of Fish and Wildlife (WDFW) Priority Habitats and Species (PHS) Database on the Web (https://geodataservices.wdfw.wa.gov/hp/phs/); Washington Department of Natural Resources (DNR) Natural Heritage GIS database, 2022; Fish usage data from SalmonScape (http://apps.wdfw.wa.gov/salmonscape/map.html), StreamNet (https://www.streamnet.org/home/data-maps/sn-mapper/) and the Northwest Indian Fisheries Commission (https://geo.nwifc.org/swifd/); and Orthophotography from Earth Explorer (2022), Google Earth (2022); and Historic Aerials (www.historicaerials.com, 2022); LiDAR-derived and manipulated from the Washington State Department of Natural Resources (DNR) Lidar Portal (https://lidarportal.dnr.wa.gov/) 2.5 Field Investigation The Site was evaluated by Talasaea Consultants on 22 and 25 February, and 1 March 2022. During the February site visits, Talasaea staff performed a full Site reconnaissance and delineation of all wetland areas within the study area. During the 1 March site visit, the remaining area of the property (outside of the primary study area) was documented, although no formal test plots or delineations were recorded. Although the entire property spans both sides of Oakesdale Avenue SW, our investigation focused on the areas directly adjacent to the north and Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 4 south ponds (Wetland A and Pond B discussed below). Although we recognize that there may be other critical areas found east of Oakesdale Avenue SW, those features are not discussed herein. Wetland determinations were made using the routine approach described in the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (U.S. Army Corps of Engineers 2010). Plant species were identified according to the taxonomy of Hitchcock and Cronquist (Hitchcock, et al. 2018). Taxonomic names were updated and plant wetland status was assigned according to the National Wetland Plant List, Version 3.5 (U.S. Army Corps of Engineers, 2020). Wetland classes were evaluated with the U.S. Fish and Wildlife Service’s system of wetland classification (Cowardin, et al. 1979). Vegetation was considered hydrophytic if greater than 50% of the dominant plant species had a wetland indicator status of facultative or wetter (i.e., facultative, facultative wetland, or obligate wetland). Wetland hydrology was evaluated based on the presence of hydrologic indicators listed in the Corps Regional Supplement. These indicators are separated into Primary Indicators and Secondary Indicators. To confirm the presence of wetland hydrology, one (1) Primary Indicator or two (2) Secondary Indicators must be demonstrated. Indicators of wetland hydrology may include, but are not necessarily limited to, drainage patterns, drift lines, sediment deposition, watermarks, stream gauge data and flood predictions, historic records, visual observation of saturated soils, and visual observation of inundation. Soils on the Site were considered hydric if one or more of the hydric soil indicators listed in the Corps Regional Supplement were present. Indicators include the presence of organic soils, reduced, depleted, or gleyed soils, or redoximorphic features in association with reduced soils. Wetland boundary flagging and test pit locations were recorded with an Eos Arrow 100 submeter GNSS receiver unit in tandem with an iPhone 12. Talasaea ecologists took standard photos at each waypoint using the GPS Kit app to record photo points, which were exported as KMZ and GPX files to provide GPS coordinates for mapping in GIS. The Arrow 100 unit was equipped with an AGS350 multi-GNSS survey antenna, giving the unit submeter accuracy (30-60 cm real- time accuracy using SBAS). CHAPTER 3. RESULTS This section describes the results of our in-house research and field investigations. For the purpose of this report, the term “vicinity” or “Study Area” describes an area 300 feet surrounding the Project Site. See Section 2.1 for the description of the Project Site, and Figure 1 for a depiction of the Project Site within the Longacres Office Park (LOP). 3.1 Analysis of Existing Information The following sources provided information on site conditions based on data compiled from resource agencies and local government publicly available resources: 3.1.1 USFWS Wetlands Online Mapper (National Wetlands Inventory) The National Wetlands Inventory (NWI) does not map any critical areas on the property but maps numerous in the general vicinity of the Site (Figure 3). The NWI maps a Riverine, Lower Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 5 Perennial, Unconsolidated Bottom, Permanently Flooded, Excavated Stream (R2UBHx) to the North / Northeast of the Site which corresponds with the general location of Springbrook Creek. NWI further maps Palustrine, Emergent, Persistent, Seasonally Flooded wetlands (PEM1C) to the east, southeast, and southwest, and two Palustrine, Forested, Seasonally Flooded Wetlands (PFOC) to the southeast of the Site. 3.1.2 Natural Resources Conservation Service Soil Survey The Natural Resources Conservation Service (NRCS) Soil Survey maps Urban Land (Ur) as the only soil type occurring on the property (Figure 4). Areas mapped as Ur consist mostly of sites for buildings, paved roads, and parking lots. Areas of this unit require onsite investigation and evaluation for most land use decisions. 3.1.3 SalmonScape and StreamNet Databases SalmonScape and StreamNet both use databases of hydrology and fish presence (documented or presumed). Both SalmonScape and StreamNet classify the nearby Springbrook Creek as a fish- bearing stream (Figure 5). Both databases map the documented presence of Fall Chinook (Oncorhynchus tshawytscha), Winter Steelhead (O. mykiss), Coho Salmon (O. kisutch), and Resident Coastal Cutthroat Trout (O. clarkii). Additionally, rearing of Coho Salmon has been documented in Springbrook Creek by WDFW within the study area, and the creek is considered Gradient Accessible for the presence of Fall Chum (O. keta). No salmonid presence is documented on the Project Site. 3.1.4 WDFW Priority Habitats and Species Database The Washington Department of Fish and Wildlife’s Priority Habitats and Species (PHS) database shows no priority habitats or species on the Unico Longacres property but does indicate several priority habitats within 300 feet (Figure 6). The PHS database lists Springbrook Creek as a priority habitat, which supports multiple priority salmonid species (Fall Chinook, Winter Steelhead, Coho, and Resident Coastal Cutthroat Trout). Additionally, several wetland areas along Springbrook Creek, referred to as “Longacres Wetlands”, along with wetlands from the NWI, are shown as priority habitats within 300 feet of the property. 3.1.5 City of Renton Critical Areas Mapping The City of Renton Map Viewer (COR Maps) shows multiple wetland areas on the Longacres property, along with the wetland area adjacent to Springbrook Creek and the track area in the practice track, both to the east of Oakesdale Ave SW (Figure 7) 3.2 Analysis of Existing Field Conditions Three (3) wetlands were identified within the area of the property investigated. Two (2) other areas were identified within the same area and formally documented and determined not to be regulated features. Various other areas that have previously been identified as wetlands were also investigated and documented. These features were found not to be wetlands but are discussed herein regardless. Included in the discussion of each feature below are the vegetative, hydrologic, and soil conditions of the feature (aside from Area D and Area H). Wetland rating forms are included in Appendix A. Wetland delineation forms are included in Appendix B. The City of Renton’s peer reviewers concurred with Talasaea’s assessment and delineation of jurisdictional wetlands on site (Otak 2022, Appendix C). Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 6 3.2.1 Wetland A Wetland A is a Category II depressional wetland and the northern-most pond located on the property. Wetland A scored 7 points for Improving Water Quality, 8 points for Hydrologic Functions, and 6 points for Habitat Functions (Appendix A). Pursuant to RMC 4-3-050G(2), Category II wetlands with moderate habitat scores located within land use areas other than low impact land use require a 150-foot standard buffer, although the buffer is 100 feet when it abuts low intensity uses. Wetland A hydrology is provided by direct precipitation, surface runoff, and from Pond B located to the south (discussed below). Pursuant to the Shapiro Mitigation Plan (1999) Wetland A was designed as part of the LOP Stormwater Management Plan and receives stormwater from the LOP Site. Vegetation within Wetland A is characterized by red alder, black cottonwood, salmonberry, slough sedge (Carex obnupta), and Cattail (Typha latifolia). Soils within Wetland A were generally a dark, greyish brown (10YR 3/2-4/2 and 2.5Y 4/2) loam or silty clay loam dependent on the location within the Wetland. Dark yellowish brown to dark brown redox features (10YR 4/2-4/6) were commonly found within Wetland A (Appendix B). 3.2.2 Wetland C Wetland C is a Category II depressional wetland located to the northwest of Wetland A. Wetland C scored 7 points for Improving Water Quality, 8 points for Hydrologic Functions, and 5 points for Habitat Functions (Appendix A). Pursuant to RMC 4-3-050G(2), Category II wetlands with moderate habitat scores (5-7) located within land use areas other than low impact land use require a 150-foot standard buffer. Wetland C hydrology is provided by direct surface flow during rain events and potentially from Wetland A during above-average rain events. Vegetation within Wetland C is characterized by red alder, Sitka willow, and hairy bitter cress (Cardamine hisuta). Soils within Wetland C are a dark grayish brown (2.5Y 4/2) silty clay loam with yellowish brown (10YR 5/8) redoximorphic features (Appendix B). 3.2.3 Wetland F Wetland F is a Category II depressional wetland located to the east of Wetland A and directs water from Wetland A towards the CTSE Wetlands located east of Oakesdale Avenue SW. It is the only wetland located on the property where the open water habitat has any measurable flow, although the flow velocity is minimal. Wetland F scored 7 points for Improving Water Quality, 8 points for Hydrologic Functions, and 6 points for Habitat Functions (Appendix A). Pursuant to RMC 4-3-050G(2), Category II wetlands with moderate habitat scores (5-7) located within land use areas other than low impact land use require a 150-foot standard buffer. Wetland F hydrology is provided by direct surface flow during rain events and from Wetland A located to the west. Vegetation within Wetland F is similar to other wetlands found on the property, with a prevalence of red alder, Sitka willow, slough sedge, and several Western redcedars. Soils within Wetland F were generally dark grayish brown (10YR 3/2-4/2) sandy/silty loam. A gravel fill layer occupied the upper stratum of the soil profiles collected within and around Wetland F. Dark yellowish brown and strong brown redox features (10YR 3/6-4/4 and 7/5YR 5/8) were commonly found within Wetland F (Appendix B). Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 7 3.2.4 Pond B Pond B is a stormwater detention and treatment pond located directly south of Wetland A. Pond B hydrology is provided by direct surface flow during rain events and from the stormwater detention pond located to the south. Pursuant to the Shapiro Mitigation Plan (1999), Pond B is designed to receive and treat stormwater from the LOP Site. Vegetation within and adjacent to Pond B is characterized by red alder, black cottonwood, salmonberry, slough sedge, and cattail. Soils within Pond B are generally a black to dark, greyish brown (10YR 2/1-3/2) sandy or silty loam, dependent on the location within the Pond. Dark yellowish to grayish brown redox features (10YR 4/3-5/4) were commonly found within Pond B (Appendix B). 3.2.5 Feature D Feature D is an upland area located upslope and east of Pond B. This area, much like Pond B, is visually indicative of a wetland. However, both test plots conducted within Feature D failed to satisfy the requirements of a hydrology indicator, and one of the two test plots failed to satisfy the requirements of either a hydrology or hydric soil indicator. Feature D hydrology, when present, appears to be historically provided by an installed irrigation system that draws water directly from Pond B. Aside from the installed irrigation system, hydrology can only otherwise be provided by direct precipitation due to local topography. Feature D is an area that is indicative of intentional plantings designed to make the area visually appear as a wetland. Vegetation within Feature D is almost entirely dominated by slough sedge, with various red alders, black cottonwoods, and Sitka willows. The soil profile within Feature D was characterized by a dark brown (10YR 3/3) coarse sandy loam overlying a very dark gray to dark brown (10YR 3/1-3/3) dense restrictive layer composed of silty loam/clay (Appendix B). 3.2.6 Feature G Feature G is an unregulated, depressional wetland located east of Pond B. Feature G hydrology is largely supported by direct precipitation on compacted soils. However, Feature G has been noted as being a site of stormwater treatment in as-built plans which indicate private surface water mains entering and exiting the area. Sverdrup Civil (1998) shows that a temporary water quality treatment and control pond was once constructed on the location of Feature G. This temporary water treatment pond was constructed sometime during the late 1990s and removed within two years following the construction of the present-day Pond B. Vegetation within Feature G is characterized by a predominance of invasive species such as reed canarygrass and Himalayan blackberry with various other grass species such as bent grass (Agrostis sp.) and velvet grass (Hocus lanatus). The soil profile within Feature G is characterized by a dark gray (10YR 4/1) silty clay loam with strong brown (10YR 4/6) redoximorphic features overlying a dense, restrictive clay layer (Appendix B). 3.3 Vegetation The area directly adjacent to the buildings and parking areas is vegetated by maintained lawn and other landscape plantings. Other plant communities across the site are composed of native tree species, including black cottonwood (Populus balsamifera ssp. trichocarpa) and red alder (Alnus rubra), with occasional Douglas-fir (Pseudotsuga menziesii), western redcedar (Thuja plicata), bigleaf maple (Acer macrophyllum), and others. The Site also features several shrubs and saplings including Sitka willow (Salix sitchensis), salmonberry (Rubus spectabilis), vine maple (Acer circinatum), and others. Throughout the Site, there is a prevalence of non-native and Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 8 invasive Himalayan blackberry (Rubus armeniacus), reed canarygrass (Phalaris arundinacea), and English ivy (Hedera helix). 3.4 Wildlife Observations The Longacres Campus area supports a wide array of wildlife species among the wetlands, ponds, and buffer areas. Wildlife observations were made during site visits on 22 and 25 February, 1 March 2022, and 19 July 2022, and are listed in Table 1. Table 1. Wildlife species observed on the Longacres Campus. Common Name Scientific Name Amphibians Bullfrog Lithobates catesbeianus Pacific treefrog (Chorus frog)Pseudacris regilla Birds American Crow Corvus brachyrhychos American Coot Fulica americana American Robin Turdus migratorius Black-capped Chickadee Poecile atricapillus Canada Goose Branta canadensis Common Merganser Mergus merganser Dark-eyed Junco Junco hyemalis Downy Woodpecker Dryobates pubescens Great Blue Heron Ardea herodias Hooded Merganser Lophodytes cucullatus House Finch Haemorhous mexicanus House Sparrow Passer domesticus Lesser Scaup Aythya affinis Mallard Anas platyrhynchos Northern Flicker Colaptes auratus Pileated Woodpecker Dryocopus pileatus Red-winged Blackbird Agelaius phoeniceus Song Sparrow Melospiza melodia Steller's Jay Cyanocitta stelleri Mammals Coyote Canis latrans Eastern Cottontail Sylvilagus floridanus Eastern Gray Squirrel Sciurus carolinensis Mule Deer Odocoileus hemionus North American Beaver Castor canadensis Raccoon Procyon lotor Townsend mole Scapanus townsendii Reptiles Painted turtle Chrysemys picta Pond slider Trachemys scripta Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 9 CHAPTER 4. BIOLOGICAL & HABITAT ASSESSMENT 4.1 Species & Habitat Information Species listed under the Endangered Species Act fall under the jurisdiction of one of two federal agencies: the U.S. Fish and Wildlife Service (USFWS) for terrestrial and freshwater species, and the National Oceanographic and Atmospheric Administration (NOAA) National Marine Fisheries Service (NMFS) for marine and anadromous species. We obtained information regarding listed or proposed species and designated or proposed critical habitats for the Project Area and vicinity of Renton, Washington, from the USFWS (2022) and NMFS (2022). Critical habitat is defined as “the specific areas occupied by a species with the physical or biological features that are essential to the conservation of the species.” As indicated in the USFWS Information for Planning and Conservation Report (IPaC; USFWS 2022; Appendix C), a total of five ESA-listed or candidate species are potentially within the Project-affected area, or may be affected by the proposed action: Marbled Murrelet (Brachyramphus marmoratus), designated as Threatened. Streaked Horned Lark (Eremophila alpestris strigata), designated as Threatened. Western Yellow-billed Cuckoo (Coccyzus americanus), designated as Threatened. Bull Trout (Salvelinus confluentus), designated as Threatened. Monarch Butterfly (Danaus plexippus), designated as a Candidate. Consultation with the U.S. Fish and Wildlife Service under section 7 of the Endangered Species Act is not required for candidate species, and therefore, will not be discussed in this Biological Assessment. The IPaC web application compiles the species list based on the defined project area limits provided by the user. All terrestrial species listed are not within the Project-affected area, nor have designated critical habitats within the Project-affected area. There is final designated critical habitat for Bull Trout on the Green River, which is outside of the Project-affected area. The NOAA Fisheries website (NMFS 2022) was used to review listed species within the vicinity of Renton and the Puget Sound area. Additional information regarding the presence of listed species within the Project-affected area was obtained from the Washington Department of Fish and Wildlife’s (WDFW) Priority Habitats and Species (PHS) on the Web (WDFW 2022). Two ESA-listed Pacific salmon species are potentially within the Project-affected area, or may be affected by the proposed action: Puget Sound Chinook (Oncorhynchus tshawytscha), designated as Threatened, and Puget Sound Steelhead (Oncorhynchus mykiss) designated as Threatened. There is final designated critical habitat for both salmon species within the Project-affected area, Springbrook Creek (70 FR 52629; 81 FR 9251). A search of the Washington Department of Natural Resources (DNR) Natural Heritage Program online database revealed no records of any listed plants, high-quality ecosystems, or other significant natural features within the Project-affected area (DNR 2022). Springbrook Creek is approximately 1,150’ distant from the Sounders’ proposed facilities. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 10 4.2 Listed Species & Critical Habitat Potentially Occurring Of the ESA-listed species identified in this section, many of them are not expected to occur in Project-affected area because of a lack of suitable habitat. The ESA-listed species not expected to occur in the Project-affected area are: Marbled Murrelet (Brachyramphus marmoratus) The marbled murrelet was federally listed as a threatened species in Washington, Oregon, and northern California effective September 28, 1992 (57 FR 45328). It is a small diving seabird in the family Alcidae that breeds along the Pacific coast of North America from the Aleutian Archipelago and southern Alaska south to central California. Marbled murrelets have a unique life history strategy that differs from most seabirds. Although they feed primarily on fish and invertebrates in nearshore marine waters, marbled murrelets fly inland up to 70 miles (113 kilometers) to nest on large limbs of mature conifers (USFWS 1997). The marbled murrelet is the only alcid known to nest in trees. Murrelets nest in stands varying in size from several acres to thousands of acres. However, larger, unfragmented stands of old growth appear to be the highest quality habitat for marbled murrelet nesting (Ralph et al 1995). This critical habitat was designated in 1996 (61 FR 26256; June 24, 1996), with approximately 1,631,300 acres in Washington. No stands of large, mature conifers are present in the Project-affected area, which is located in a commercial/industrial urban area. The nearest critical habitat is located approximately 28.5 miles east of the Project Area, in the Snoqualmie National Forest along Interstate-90 east of North Bend, Washington (61 FR 26256; June 24, 1996). Streaked Horned Lark (Eremophila alpestris strigata) The streaked horned lark is a rare, distinctive subspecies of the horned lark and is an endemic Pacific coastal form found only in western Washington and Oregon. Surveys conducted during the breeding seasons in 1999 and 2000 found streaked horned larks present at only 11 locations in Pierce, Thurston, Mason, Pacific, Grays Harbor, and Wahkiakum Counties; they were not detected during surveys north of Pierce County (Stinson 2005). Within the Puget Sound region, streaked horned lark breeding and nesting habitat consists of large expanses of grass-dominated habitat, such as airports or native prairies, with very few trees or woody shrubs (Pearson and Altman 2005). The subspecies no longer breeds in southern British Columbia, the northern Puget trough (San Juan Islands and other coastal areas north of Tacoma), along the Washington Coast north of Grays Harbor, and in the Rogue River Valley (Pearson and Altman 2005). Given this information, there is no suitable breeding habitat or population currently present or available within the proposed Project-affected area. Western Yellow-billed Cuckoo (Coccyzus americanus) Yellow-billed cuckoos were listed as a threatened species under the ESA by the USFWS in October 2014 (79 FR 59991; October 3, 2014). The western yellow-billed cuckoo has experienced a major decline in its breeding range since the 1800s and is now extirpated throughout most of its historical range and is now restricted to small isolated areas from southeastern Idaho and northern California to northwestern Mexico and western Texas (78 FR 61621; 79 FR 59991; Wiles and Kalasz 2017). Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 11 The western yellow-billed cuckoo nesting occurs almost exclusively in low to moderate elevation mature riparian woodlands dominated by cottonwoods (Populus spp.) and willows (Salix spp.) (78 FR 61621). USFWS indicates that blocks of mature riparian habitat covering 50 acres or more are generally required within the arid to semiarid landscapes throughout the western range, but also potentially in moister habitats of the western Pacific Northwest where they historically occurred (78 FR 61621; 79 FR 59991). Western yellow-billed cuckoos rarely nest within habitat patches less than 50 acres in size, and patches less than 37 acres and less than 328 feet (100 m) wide are considered unsuitable habitat (Laymon and Halterman 1989). Given these requirements, there is no suitable breeding habitat currently present or available within the proposed Project-affected area. Bull Trout (Salvelinus confluentus) Bull trout are a cold-water fish belonging to the char subgroup of the family Salmonidae and are native to relatively pristine stream and lake habitats of the Pacific Northwest United States and western Canada. In November 1999, all five distinct population segments of bull trout within the coterminous United States were listed as a threatened species pursuant to the ESA, as amended (Act) (64 FR 58910; November 1, 1999). The Coastal-Puget Sound Distinct Population Segment is significant to the species as a whole because it contains the only anadromous forms of bull trout in the coterminous United States (USFWS 2004). The final critical habitat was designated for bull trout and was published on October 18, 2010 (75 FR 63897), including 32 critical habitat units (CHUs) in the final bull trout critical habitat listing rule, reflecting single core areas or groups of core areas that are included in 6 recovery units. The Project-affected area lies within the Puget Sound CHU (Unit 2) (75 FR 63897). The nearest designated critical area for bull trout is the Green River, which is outside of the Project-affected area. The PHS database (WDFW 2022) indicates that bull trout are not present within the Springbrook Creek sub-watershed. Bull trout have been occasionally reported in the lower Green/Duwamish River, but data are insufficient to assess the status of this species (King County 2019). Of native salmonids in the Pacific Northwest, bull trout have some of the most specific habitat requirements (Rieman and McIntyre 1993), often referred to as “the four Cs”: Cold, Clean, Complex, and Connected habitat. These requirements include cold water temperatures compared to other salmonids (often less than 12 degrees Celsius [54 degrees Fahrenheit]); the cleanest stream substrates; complex stream habitat including deep pools, overhanging banks, and large woody debris; and connectivity between spawning and rearing (SR) areas and downstream foraging, migration, and overwintering (FMO) habitats (USFWS 2015). Given these requirements, there is no suitable FMO habitat currently present or available within the proposed Project-affected area. 4.2.1 Puget Sound Chinook ESU (Evolutionary Significant Unit) Chinook Salmon (Oncorhynchus tshawytscha) are the largest species of Pacific salmon with adults often exceeding 40 pounds; reports of adults over 100 pounds are common. Chinook at sea display blue-green back with silver flanks, similar to coho salmon, but are distinguishable by their large size, small black spots on both lobes of the tail, and black pigment along the base of their teeth. Like all anadromous Pacific salmonids, adults migrate from marine environments and Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 12 spawn in freshwater, while juveniles rear in freshwater for varying periods of time before migrating out to saltwater where they mature. Two primary life history patterns occur in Chinook salmon, based on the times of river entry and spawning, and are linked to the duration of juvenile freshwater residence: stream-type and ocean- type. Spring (stream-type) Chinook adults enter mainstem rivers in late-March through May and spawn between mid-July and early-September (Myers et al. 1998). Fry emerge from the gravel the following spring, between the end of March and early-May, and remain in fresh water for a full year, before smolting and migrating downstream to saltwater. A small proportion of juveniles may remain in fresh water for a second year. Summer/Fall (ocean-type) Chinook adults enter mainstem rivers from July to late September and spawn between mid-September and mid-November. Fry emerge from mid-March to mid-April, migrate downstream during their first spring, and enter the estuary, where they remain until reaching sizes of 2.4 to 2.8 inches. A portion of these emergent fry may remain in the river and rear for up to two months and then migrate downstream to the estuary and beyond (Hayman et al. 1996). Historically, both spring-run and summer/fall-run Chinook salmon spawned and reared in the Duwamish/Green River basin (King County 2019). Spring Chinook adults migrated to the upper Green River basin and parts of the White River, holding for several weeks or months before spawning (King County 2019). When the White River was re-routed from the Duwamish Basin, access to the headwaters habitat typically used by spring Chinook was eliminated. However, while rerouting of the Cedar and White Rivers reduced the overall habitat accessible to fall Chinook, enough habitat remained in the Green River to maintain the population of fall Chinook and distributed it throughout the watershed (King County 2019). Spawning occurred from approximately RM 24 to RM 91, as well as in larger tributaries such as Newaukum Creek and tributaries in the Upper Green River. Current distribution maps show that Chinook spawn in the Middle Green River below the Tacoma Diversion, and tributaries such as Soos Creek and Newaukum Creek (Kerwin and Nelson 2000). Juvenile Chinook salmon have been observed in tributaries in the lower Green River basin, including within Springbrook Creek above the Black River Pump Station (confluence at RM 11) (WDFW 2022; Kerwin and Nelson 2000). A proposed rule for the listing of Puget Sound Chinook and three other Chinook evolutionarily significant units (ESUs) as threatened was published in the Federal Register (63 FR 11482) on March 9, 1998. The Final Determination (64 FR 14308) was issued on March 24, 1999. In 2004, NMFS issued a proposed policy for the consideration of hatchery-origin fish in ESA listing determinations (69 FR 33102; June 14, 2004). In June 2005, NMFS issued final listing determinations for 16 ESUs of Pacific salmon (including the Puget Sound Chinook ESU) with revisions to 4(d) protective regulations for consistency between ESUs and DPSs (Distinct Population Segment) (70 FR 37159, June 28, 2005). On February 16, 2000, a designation was published which indicated that critical habitat encompassed dozens of major river basins and an array of essential habitat types, including juvenile rearing areas, juvenile migration corridors, areas for growth and development to adulthood, adult migration corridors and spawning areas (65 FR 7764). A revised Critical Habitat Designation for Puget Sound Chinook was published in the Federal Register on December 14, 2004 (69 FR 74571), with a final rule issued on September 2, 2005 (70 FR 52629). Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 13 Springbrook Creek, a potential Project-affected area, is designated as critical habitat located within the Duwamish Subbasin (1711001303) (70 FR 52629). The Primary Constituent Elements (PCEs) for Chinook salmon critical habitat within the Project- affected area include: 1. Freshwater rearing sites with water quantity and floodplain connectivity to form and maintain physical habitat conditions and support juvenile growth and mobility; water quality and forage supporting juvenile development; and natural cover such as shade, submerged and overhanging large wood, log jams and beaver dams, aquatic vegetation, large rocks and boulders, side channels, and undercut banks. 2. Freshwater migration corridors free of obstruction and excessive predation; with water quantity and quality conditions supporting juvenile and adult mobility and survival; and natural cover such as submerged and overhanging large wood, aquatic vegetation, large rocks and boulders, side channels, and undercut banks supporting juvenile and adult mobility and survival. 4.2.2 Puget Sound Steelhead DPS Steelhead (Oncorhynchus mykiss) are the anadromous form of rainbow trout. They reside in fresh water for their first one to three years before emigrating to the ocean for one to three years. Steelhead express two major life-history types related to the degree of sexual development at the time of adult freshwater entry (Hard et al. 2007): summer-run and winter-run. Summer-run steelhead are stream-maturing, entering fresh water at an early stage of maturation, usually from May to October, migrating to headwater areas, and then holding for several months prior to spawning in the spring. The life history of summer-run steelhead is highly adapted to specific environmental conditions that are not common in Puget Sound; therefore, the relative incidence and size of summer-run steelhead populations are substantially less than that for winter-run steelhead. Winter-run steelhead are ocean-maturing fish, returning as adults to the tributaries of Puget Sound in fall or winter and spawn in spring, as late as late June. Prior to spawning, maturing adults hold in pools or in side-channels to avoid high winter flows. The winter run of steelhead is the predominant run in Puget Sound, in part because there are relatively few basins in the Puget Sound ESU with the geomorphological and hydrological characteristics necessary to establish the summer-run life history. The Green River Winter Run steelhead is a demographically independent population (DIP) identified within the Central and South Puget Sound major population group (NMFS 2019). Both the native Green River stock and the winter steelhead hatchery stock were federally listed as Threatened in 2007 (72 FR 26722). The hatchery steelhead typically spawn between January and March while the native stock spawns primarily between March and May. Steelhead tend to spawn in moderate to high-gradient sections of streams. In contrast with other species of Pacific salmon, steelhead are iteroparous, capable of repeat spawning. Steelhead females do not guard their redds, or nests, but return to the ocean following spawning (Hard et al. 2007). Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 14 Unlike most salmonids in Puget Sound, steelhead do not rear extensively in estuaries or nearshore habitats, but instead in rivers and streams for extended periods. High-quality slow- water margin habitat is important to small juveniles, while larger juveniles are typically associated with fast-water riffle and run habitats (NMFS 2019). These preferred juvenile habitats are very limited in the Lower Green River and are primarily found in the upper reaches (King County 2019). However, fish distribution maps indicate some steelhead use of tributaries to the Lower Green River, including Springbrook Creek (Kerwin and Nelson 2000; WDFW 2022). Juvenile steelhead display a longer period of freshwater rearing than most other species, with one to three years of freshwater residence. The majority of steelhead juveniles reside in fresh water for two years before emigrating to marine habitats. Two-year-old naturally produced smolts are usually 140-160 mm in length (Hard et al. 2007). Smoltification and seaward migration occur principally from April to mid-May (Hard et al. 2007). Steelhead smolts typically migrate directly from natal freshwater streams and rivers to the ocean very rapidly, spending only a few days to a couple of weeks in Puget Sound (NMFS 2019). Once the fish leave Puget Sound they commonly spend two to three years at sea before returning to Puget Sound as maturing steelhead and migrating to their native rivers and streams to spawn (NMFS 2019). In 2004, National Marine Fisheries Service was petitioned to list Puget Sound steelhead under the Endangered Species Act (ESA) as threatened or endangered. The petition prompted a new status review (Hard et al. 2007) and based on its findings, Puget Sound steelhead were ESA- listed as a threatened species effective June 11, 2007 (72 FR 26722). A final rule (81 FR 9251) was issued by NMFS on February 24, 2016, designating critical habitat under the Endangered Species Act for two threatened species—lower Columbia River coho salmon (Oncorhynchus kisutch) and Puget Sound steelhead (O. mykiss). Springbrook Creek, a potential Project-affected area, is designated as critical habitat located within the Duwamish Subbasin (1711001303) The Primary Constituent Elements (PCEs) for steelhead critical habitat within the Project- affected area include: 1. Freshwater rearing sites with water quantity and floodplain connectivity to form and maintain physical habitat conditions and support juvenile growth and mobility; water quality and forage supporting juvenile development; and natural cover such as shade, submerged and overhanging large wood, log jams and beaver dams, aquatic vegetation, large rocks and boulders, side channels, and undercut banks. 2. Freshwater migration corridors free of obstruction and excessive predation; with water quantity and quality conditions supporting juvenile and adult mobility and survival; and natural cover such as submerged and overhanging large wood, aquatic vegetation, large rocks and boulders, side channels, and undercut banks supporting juvenile and adult mobility and survival. 4.3 Effects Analysis 4.3.1 Direct Effects Construction and operation of the Sounders facilities will not directly affect ESA-listed species. The entirety of the site development work takes place in an urban area with no significant habitat features (Figure 6) for any of the species listed and discussed in Section 5. The project parcel is Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 15 located nearly 1,900 feet from the Green River and is outside of its drainage basin. The project is located within the Springbrook Creek/Black River subbasin area. The Sounders facilities are approximately 1,150 feet from Springbrook Creek and have no direct connection or impact to Springbrook Creek. A depressional wet area that is part of a stormwater pond complex4 is located approximately 35 feet to the west of the Project Area (Figure 9). However, this wet area is approximately 8.5 acres, which is not of sufficient size to support populations of yellow-billed cuckoos (requires mature riparian habitat covering 50 acres or more)5. 4.3.2 Indirect Effects In accordance with the NPDES, a Construction Stormwater Permit will be required for the project. The contractor for the project will install a temporary construction stormwater management system per the permit. The contractor will develop a stormwater pollution prevention plan (SWPPP) that details how they will manage stormwater at the site during the construction of the project to prevent adverse water quality issues. The SWPPP will identify best management practices and temporary erosion and sediment control measures will be utilized during the project to avoid impacts to ESA-listed species and critical habitats. It is anticipated that stormwater will be contained within the Project Area during construction and will not be allowed to enter Pond A unless in compliance with State water quality standards (WAC 173-201A). As such, construction stormwater is not expected to affect the environment beyond the immediate Project Area. Any stormwater that does exit the site would be routed through stormwater Pond B, which would allow for any sediments to settle out before release into Pond A or Springbrook Creek. 4.3.3 Accidental Release of Contaminants There is a potential for impacts to water quality resulting from spilling hazardous materials or petroleum-based products associated with fueling or maintaining construction machinery and equipment (there would be no fueling of vehicles on the site). Potential impacts to water quality, such as spilling hazardous materials or petroleum-based products associated with construction will be managed through proper implementation of a Spill Prevention Control and Countermeasures plan, which will include developing a containment area where any equipment fueling would occur. 4.3.4 Permanent Stormwater & New Impervious Surfaces In accordance with current City of Renton drainage requirements for new and redeveloped sites, Project Engineers have developed a Stormwater Mitigation Site Plan to not only meet applicable minimum requirements, but also incorporate floodplain mitigation measures to negate the impact of the development on the regional waterways, as required by Special Requirement #2 of the 2022 Renton Surface Water Design Manual (SWDM). Stormwater design is based on the Department of Ecology’s 2019 Stormwater Management Manual for Western Washington, and 4 The stormwater pond complex is comprised of a series of constructed ponds and created wetlands connected by culverts and stormwater control structures that eventually empty into Springbrook Creek via a 36-inch culvert. 5 The Western Distinct Population Segment of yellow-billed cuckoo has not been sighted in the greater Seattle area since 1925 and is considered extirpated statewide. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 16 the drainage infrastructures and storm systems have been designed to flow control requirements per the 2022 Renton SWDM. Stormwater management will be achieved by utilizing the existing storage in Pond B. Pond B was designed for the Boeing Master Plan and was constructed to accommodate the full detention requirements for the overall Longacres Campus with a targeted coverage of approximately 71%. The Seattle Sounders FC Headquarters and Training Center is located within this design basin and matches the impervious coverage used to design Pond B. This project does not propose to provide any additional detention. All the fields will be routed through an enhanced basic water quality treatment system designed according to Chapter 6 of the 2022 Renton SWDM. The project will install a General Use Level Designation (GULD)-approved open bioscope system downstream of the fields along the edge of Pond B. From there water will be discharged into Pond B to the west. Floodplain mitigation will be provided under the synthetic turf fields 3, 4, and 5 utilizing the CULTEC Recharger or StormTech systems. These systems consist of chambers surrounded by clean, crushed, angular stone with an industry-standard porosity of 40%. This stone serves as a structural component while allowing conveyance and storage of stormwater. 4.4 Effects Determinations Based on our understanding of the project, a synopsis of probable effects to ESA-listed species and their critical habitat is presented below. 4.4.1 Marbled Murrelet The project will result in no effect to marbled murrelets because: There are no marbled murrelets or their preferred nesting habitat (old growth forests) present within the Project Area or Action Area. The designated critical habitat for marbled murrelets is outside of the Project and Project- affected areas. 4.4.2 Streaked Horned Lark The project will result in no effect to streaked horned larks because: There is no suitable breeding habitat or streaked horned lark population currently present or available within the proposed Project Area or Action Area. The designated critical habitat for streaked horned larks is outside of the Project and Project-affected areas. 4.4.3 Yellow-Billed Cuckoo The project will result in no effect to yellow-billed cuckoos because: There are no yellow-billed cuckoos or their preferred habitat (50 acres of riparian forest) present within the Project Area. The designated critical habitat for yellow-billed cuckoos is outside of the Project and Project-affected areas. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 17 The Western DPS of yellow-billed cuckoo is likely extirpated statewide with no breeding pairs identified since 1925. 4.4.4 Bull Trout Coastal-Puget Sound DPS The project will result in no effect to bull trout because: There are no bull trout or their preferred habitat present within Springbrook Creek. the Project Area. The designated critical habitat for bull trout is outside of the Project and Project-affected areas. 4.4.5 Puget Sound Chinook ESU Springbrook Creek is designated critical habitat for Puget Sound Chinook, which may be present from March through September during their upstream migration. The project is not likely to adversely affect Puget Sound Chinook and their critical habitat because: The project is located approximately 1,150 feet from Springbrook Creek, so no direct impacts to Puget Sound Chinook or their habitat are expected. The project’s internal drainage system is a subsurface stormwater detention designed to store stormwater onsite with a controlled release to a treatment system before entering the stormwater pond/wetland complex, which will further provide treatment before ultimately discharging to Springbrook Creek. Stormwater detention is designed so that there is no downstream increase in volumes for the 100-year storm event and is also designed to meet the Enhanced Basic water quality treatment requirements (outlined by Renton and the DOE). The project’s green infrastructure/LID installations (as described above) will effectively reduce levels of heavy metals and petroleum by-products (e.g., PHCs) leaving the site. Any contribution of stormwater runoff from the site to Springbrook Creek would be negligible to the overall volumes treated within the adjacent stormwater pond complex and the corresponding flow volumes that occur within Springbrook Creek. No other project effects are likely to have a negative impact on PCEs for Puget Sound Chinook critical habitat. 4.4.6 Puget Sound Steelhead DPS Springbrook Creek is designated critical habitat for Puget Sound Steelhead, which may be present at any time during the year. The project is not likely to adversely affect Puget Sound Steelhead and their critical habitat because: The project is located approximately 1,150 feet from Springbrook Creek, so no direct impacts to Puget Sound Steelhead or their habitat are expected. The project’s internal drainage system is subsurface stormwater detention designed to store stormwater onsite with a controlled release to a treatment system before entering the stormwater pond complex, which will provide additional treatment to stormwater before ultimately discharging to Springbrook Creek. Stormwater detention is designed so that there is no downstream increase in volumes for the 100-year storm event, and the stormwater system is Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 18 also designed to meet the Enhanced Basic water quality treatment requirements (outlined by Renton and the DOE). The project’s green infrastructure/LID installations (as described above) will effectively reduce levels of heavy metals and petroleum by-products (e.g., PHCs) leaving the site. Any contribution of stormwater runoff from the site to Springbrook Creek would be negligible to the overall volumes treated within the adjacent stormwater pond complex and the corresponding flow volumes that occur within Springbrook Creek. 4.5 Compliance with Sections 7 & 9 of the Endangered Species Act (ESA) This BA is prepared in accordance with legal requirements set forth under regulations implementing Section 7 of the Endangered Species Act (50 CFR 402; 16 U.S.C. 1536 (c)). It is being prepared at the request of the City of Renton to comply with conditions established in a NMFS Biological Opinion on the implementation of the National Flood Insurance Program in the Puget Sound Region (NMFS 2008). Section 9 of the ESA prohibits the “take” of a listed species. The term “take” means to harass, harm, pursue, hunt, shoot, wound, kill, trap, capture, collect, or attempt to engage in any such conduct. The proposed project would not result in the “take” of a threatened or endangered species for the reasons outlined in this biological assessment for lack of adverse effects. CHAPTER 5. REGULATORY REVIEW 5.1 Federal and State Regulations 5.1.1 Washington State Regulations Critical areas on the Site are subject to regulation at the State level primarily by the following statutes: State Water Pollution Control Act (administered by DOE); Section 401 of the Federal Clean Water Act (administered by DOE); Hydraulic Code of Washington (administered by WDFW); DOE uses Section 401 of the State Water Quality Certification (WQC) as the primary mechanism for implementing the provisions of the State Water Pollution Control Act. Section 401 WQC is typically issued in conjunction with Section 404 permits from the US Army Corps of Engineers (Corps). Any impacts to streams would also be regulated under the Hydraulic Code of Washington as part of the Hydraulic Project Approval (HPA) permit process. 5.1.2 Federal Regulations Critical areas on or adjacent to the Site may be subject to Federal regulations under Section 404 of the Clean Water Act (Federal Register 2002). The US Army Corps of Engineers (USACE) is responsible for administering compliance with Section 404 via the issuance of Nationwide or Individual Permits for any fill or dredging activities within wetlands or streams. 5.2 City of Renton Municipal Code – Wetlands Wetlands and other critical areas within the City of Renton are currently regulated under RMC 4- 3-050. Specifically, buffers are regulated under RMC 4-3-050G, while alterations to critical areas and their buffers are regulated under RMC 4-3-050H. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 19 Wetland A is rated as a Category II wetland with a moderate habitat score (see Chapter 3.2, above). Thus, the code establishes a 150-foot standard buffer (for nonexempt uses that are not low-intensity land uses), and a 100-foot buffer for low-intensity land uses (RMC 4-3-050.G.2). Currently, Wetland A on the Site is bordered by a paved trail. The code defines low-impact land use as those uses “which are not likely to have a significant adverse impact on critical areas because of the low intensity of the use, minimal levels of human activity, limited use of machinery or chemicals, site design or arrangement of buildings and structures, incorporation of mitigation measures, or other factors." The City of Renton and their secondary reviewer (Otak) agreed that the soccer pitches and keeper training area are low-intensity land uses; therefore, buffer alterations adjacent to the fields will be calculated based on a low-impact 100-foot buffer (Figure 9). Pond B, Feature D, and Feature G (discussed in Chapter 3.2) are not wetlands subject to critical areas regulations and do not require buffers (RMC 4-3-050B.1). CHAPTER 6. PROPOSED DEVELOPMENT & IMPACTS 6.1 Project Description The proposal is for the development of the Sounders FC Center at Longacres, at the Sounders Site (see Site Details in Section 2.1 and the broader Project Narrative attached to the Conditional Use Permit application). Unico’s Longacres Campus is larger than the Sounders Site. Unico recently purchased the Longacres Campus and independently has plans to redevelop a substantial portion of the Campus property in the future. This Critical Areas Report examines only the Sounders’ proposal, which includes the construction of five (5) full-sized training pitches and a Goal Keepers Field, the utilization of an existing office building for office space that will house the club’s operations and front office personnel, as well as training facilities for the first, second, and academy teams, an indoor recreational use. The Proposal also includes a secure parking area for players and an approximately 4,000 sf Maintenance Building. The Sounders’ proposal may be implemented in one or more construction phases. 6.1.1 Proposed Stormwater Management In accordance with current City of Renton drainage requirements for new and redeveloped sites, Project Engineers have developed a Stormwater Mitigation Site Plan to not only meet applicable minimum requirements, but also incorporate floodplain mitigation measures to negate the impact of the development on the regional waterways, as required by Special Requirement #2 of the 2022 Renton SWDM. Stormwater design is based on the Department of Ecology’s 2019 Stormwater Management Manual for Western Washington and the drainage infrastructures and storm systems have been designed to flow control requirements per the 2022 Renton SWDM. Stormwater management will be achieved by utilizing the existing storage in Pond B. Pond B was designed for the Boeing Master Plan and was constructed to accommodate the full detention requirements for the overall Longacres Campus with a targeted coverage of approximately 71%. The Seattle Sounders FC Headquarters and Training Center is located within this design basin and matches the impervious coverage used to design Pond B. This project does not propose to provide any additional detention. Runoff from all the fields will be routed through an enhanced basic water quality treatment system designed according to Chapter 6 of the 2022 Renton SWDM. The project will install a GULD-approved open bioscope system downstream of the fields along the edge of Pond B. From there water will be discharged into Pond B to the west. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 20 Floodplain mitigation will be provided under the synthetic turf of fields 3, 4, and 5, utilizing the CULTEC Recharger or StormTech systems. These systems consist of chambers surrounded by clean, crushed, angular stone with an industry-standard porosity of 40%. This stone serves as a structural component while allowing conveyance and storage of stormwater. 6.2 Wetland Buffer Alteration Pursuant to RMC 4-3-050G(9)(d)(ii) – Independent Buffer Study and RMC 4-3-050J(4) – Criteria for Approving Wetland Alterations, Unico will pursue an alteration to Wetland A. Following the guidelines outlined by the Washington State Department of Ecology Publication 06-06-011a (updated by Publication 21-06-003), the alteration will be achieved through the use of “Wetlands as Buffers” (often referred to as “paper fill”). Approximately 16,331 sf of wetland area would be indirectly impacted through conversion into buffer (Figure 9a). Conversion of wetland into buffer does not fill any wetland; wetland converted into buffer still functions as a wetland in the landscape, pursuant to the definition of no net loss in RMC 4-3-050J(4)(a): “to create, restore and/or enhance a wetland so that there is no reduction to total wetland acreage and/or function”. Due to the topography of the property, the extent of the existing functional buffer, and the minimal contribution of this buffer to the biological function of Wetland A, the buffer can be viewed as marginally functioning. Buffer enhancement and the use of low impact development strategies will result in higher buffer function. The compensatory mitigation for these indirect impacts to Wetland A is outlined in the following chapters. CHAPTER 7. MITIGATION 7.1 Agency Policies and Guidance The proposed mitigation plan was designed per the policies and guidance provided in the following documents: City of Renton Municipal Code Section 4-3-050L – Mitigation, Maintenance and Monitoring; and The Washington State Department of Ecology (DOE) Publication #21-06-003, Wetland Mitigation in Washington State – Part 1: Agency Policies and Guidance (Version 2), dated April 2021 (DOE, USACE, and USEPA 2021); and The Washington State Department of Ecology (DOE) Publication #06-06-011b Wetland Mitigation in Washington State – Part 2: Developing Mitigation Plans (Version 1), dated March 2006 (DOE, USACE, and USEPA 2006b). 7.2 Proposed Mitigation Unico proposes both on-site wetland buffer enhancement and use of the Springbrook Creek Wetland and Habitat Mitigation Bank. The Sounders Site is located within the service area of the Springbrook Creek Mitigation Bank (refer to Figures 1-3 in the Mitigation Bank Instrument). 7.2.1 Mitigation via Springbrook Creek Mitigation Bank Pursuant to RMC 4-3-050G(9)(e)(iii) – Mitigation Banks, Unico proposes to mitigate 16,331 sf of indirect wetland impacts at the Springbrook Creek Mitigation Bank. The applicant proposes a mitigation ratio of 50 percent (i.e., 0.5:1.0) for its indirect impact to Wetland A that would cause no or only partial loss of functions to the wetland. The number of mitigation credits to be Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 21 purchased is 8,166 sf. The 50 percent ratio is consistent with how other wetland mitigation banks in Washington State have dealt with mitigation for indirect wetland impacts6 and the Springbrook Creek Wetland and Habitat Mitigation Bank Instrument (“MBI”) (WSDOT and City of Renton 2006). The MBI (WSDOT and City of Renton 2006) establishes a baseline 1:1 ratio for either direct or indirect impacts to a Category II wetland (MBI, p. 4-2). Significantly, however, the MBI also provides a standard to lower the baseline ratio in two circumstances. One circumstance is directly applicable here: "the ratios may be lowered in instances where functions of the impacted wetlands have previously been severely degraded or when project impacts are indirect and cause only partial loss of functions to a wetland." (MBI, p. 4-3, emphasis added). This is in agreement with “Wetland Mitigation in Washington State – Part 1: Agency Policies and Guidance” document (DOE, USACE, and USEPA 2021) which states that agencies determine the amount of compensation necessary to offset unavoidable wetland impacts on a case-by-case basis. The amount of compensation the applicant will need to provide is affected by several factors, including the type of impact. Specifically, the document states, “For impacts that are not permanent or do not result in a complete loss of all wetland functions, the amount of compensation required may be less than the amount of wetland area and functions disturbed. Indirect impacts result in the degradation of some wetland functions, but they generally do not result in a complete loss of wetland area and functions. Therefore, indirect impacts may require less compensation.” As described in this wetland mitigation report, project impacts to Wetland A are indirect, i.e., no actual wetland fill, and will cause no or only partial loss of functions to a wetland. Impacts to the wetland would, therefore, be much less than if a portion of the wetland were to be filled. As such, the 50 percent ratio would be authorized by the Springbrook Creek MBI, consistent with other standard wetland mitigation bank practices in the State. 7.2.2 Wetland Buffer Enhancement In addition, Unico proposes to enhance portions of the upland buffer of Wetland A between the proposed field locations and the wetland edge, within an area of approximately 30,452 sf (Figure 9). Most of this buffer area is in a fairly good ecological condition; however, some areas are dominated by invasive plant species and could benefit from significant enhancement (Figures 10-17). Unico proposes buffer enhancement of approximately 5,500 sf within the adjacent 30,452 sf buffer area located between the proposed fields and Wetland A. 7.3 Wetland Buffer Enhancement Details 7.3.1 Decompaction and Topsoil Any existing non-native vegetation within mitigation areas will be removed. These areas will be enhanced through the decompaction of existing soils, as necessary, and the importation of high- quality topsoil and/or the addition of soil amendments. 6 Other Mitigation Bank Instruments include: Keller Farm Mitigation Bank (Habitat Bank LLC 2019), Snohomish Basin Mitigation Bank, and East Fork Lewis Mitigation Bank. Also, see Section 6B.4.7 Compensating for Indirect Impacts (Wetland Mitigation in Washington State – Part 1 (Version 2)). Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 22 7.3.2 Habitat Features Down logs, rootwads, and stumps will be incorporated into the mitigation areas to provide ecologically important habitat features for wildlife. All down woody material shall be coniferous species (western red cedar, Douglas fir, western hemlock, or Sitka spruce (Picea sitchensis)) obtained from the Project Site or imported, if necessary. Woody material will be delivered and installed with the appropriately sized machinery, resulting in 1500 sq ft of temporary disturbance adjacent to the trail and construction areas. Hazardous trees identified in the buffer areas will be converted to snags and replaced at a minimum mitigation ratio of 3:1. Woody material from felled trees will be placed in the buffer areas as additional wildlife habitat enhancements. Down logs and stumps provide the slow release of nutrients as the wood decays, and also provide cover for amphibians, small mammals, and other wildlife. Boulders recovered from site excavation (if available) will be placed in small piles throughout the mitigation area. These piles can provide habitat for reptiles and small mammals. All disturbed areas will be restored following construction activities in the buffer areas. 7.3.3 Planting Plan Plant species were chosen for a variety of qualities, including adaptation to specific water regimes, value to wildlife, value as a physical or visual barrier, patterns of growth (structural diversity), and aesthetic values. Native tree, shrub, and herbaceous species were chosen to increase both the structural and species diversity of the mitigation areas, thereby increasing the value of the area to wildlife for food and cover. We expect that seeds and berries from adjacent native species will be recruited by natural processes (wind, rain, birds) into the mitigation areas and will enhance species diversity and cover. Monitoring efforts will be conducted for a period of five years after installation, ensuring that performance standards for the enhanced areas are met and remain on a trajectory for long- term success. Any invasive species that occur within the mitigation area identified during the 5- year monitoring period shall be removed by hand. Due to the relatively small planting area, herbicide treatments should not be necessary. 7.3.4 Temporary Irrigation System A temporary irrigation system may not be needed for enhancement plantings within existing vegetated buffer areas. Plantings shall be installed in the dormant season to help reduce transplant shock and encourage successful establishment. Plants shall be watered immediately after planting and shall be provided with supplemental irrigation during the dry season if drought stress is evident during the establishment period (generally the first growing season after planting). Supplemental irrigation can be provided by hand if necessary. 7.3.5 Mitigation Goals, Objectives, & Performance Standards Objective A: Create structural and species diversity within plant communities of the enhanced wetland buffer areas. Performance Standard A1: At least 12 species of desirable native plants will be present during the monitoring period. Species may be comprised of both planted and naturally colonized vegetation. To count towards the 12 species total, a given species must cover at least 10 square feet. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 23 Performance Standard A2: Percent survival of planted woody species must be at least 100% at the end of Year 1 (per contactor warranty), and at least 80% for each subsequent year of the monitoring period. Performance Standard A3: Total percent areal woody plant coverage must be at least 55% by Year 4 and 70% by Year 5. Woody coverage may be comprised of both planted and recolonized native species; however, to maintain species diversity, at no time shall a recolonized species (e.g., red alder) comprise more than 35% of the total woody coverage. There must be at least three native species providing at least 20% each, four native species providing at least 15% each, or five native species providing at least 10% of the total areal woody plant coverage in the enhanced buffer area. Objective B: Increase the overall habitat functions of the Wetland A enhanced buffer areas by incorporating habitat features (i.e., snags with bird nest boxes or bat roosting boxes, down logs, snags, rootwads, and stumps) into the buffer enhancement areas. Performance Standard B1: After construction and for the entirety of the monitoring period, the mitigation areas will contain 29 habitat features within the 5,500 sf of enhancements (1 piece/159 sf) including down woody material (logs, rootwads, etc.), snags, and brush piles. Down logs shall be a minimum of 18 feet in length and 15" diameter, with or without roots. Snags shall be cedar or fir species, a minimum of 24 feet in length and 20” diameter at ground level after installation, with a minimum of eight main branches. Stumps shall be either part- decayed relocated stumps or cut live rootwads with a minimum of three feet of trunk and a minimum 20” diameter. Stumps will be placed both upright and lying down. Additional habitat features can be placed within the mitigation areas only after specified quantities and sizes have been met. There will also be a bird nest box or bat roosting box installed on each snag. Objective C: Limit the amount of invasive and exotic species within the wetland buffer enhancement areas. Performance Standard C1: After construction and following every monitoring event for the duration of the monitoring period, exotic and invasive plant species will be maintained at levels of 10% or less total cover throughout the mitigation areas. These s exotic and invasive plant species include, but are not limited to: Scot’s broom, Himalayan and evergreen blackberry, Japanese knotweed, purple loosestrife, hedge bindweed, morning glory, and creeping nightshade. CHAPTER 8. MITIGATION SEQUENCING 8.1 Mitigation Sequencing Pursuant to RMC 4-3-050L(1)(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. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 24 The inquiry into mitigation sequencing begins with understanding the need for and programmatic requirements of the proposal. The project proponent, Seattle Sounders FC, has provided the following narrative regarding the need for a new headquarters and training facility, and what that facility needs to provide for a professional Major League Soccer team. A facility-needs evaluation and a county-wide site selection process led the Sounders FC to the proposed location at Longacres Park. Statement from Seattle Sounders FC Simply stated, Seattle Sounders FC has outgrown their current facility, about 1/2 mile away at Starfire Sports. Starfire Sports was a state-of-the-art facility for one team in 2009. The modern Major League Soccer (MLS) professional club now includes multiple teams and many more players and, as such, Sounders FC has outgrown its existing facilities. Sounders FC’s hunt for a new home has been years in the making. To define the programmatic and physical requirements for a state-of-the-art training and headquarters facility, Sounders FC engaged Generator Sports, a national architectural firm specializing in professional sports venues. Working with Generator, Sounders FC established the following program requirements and priorities for a new training facility: 4-5 full international-sized soccer fields and a Goal Keepers (GK) Field, to serve five teams (Sounders FC has a first and second team, and academy teams, including the Next Academy Team). Professional training field sizes are as determined by FIFA/International Soccer Rules, MLS standards, and ideally match the club’s Competition Facility (Lumen Field), generally 75y x 116y with 10’ of safety clearance/runout on all sides. Professional sports facilities require field/competition areas that are directly adjacent to the supportive and necessary indoor training, rehabilitation, activation, and performance facilities, which is also required to comply with the MLS and MLS Players Association collective bargaining agreement. The Sounders determined that approximately 40,000 - 50,000 sf of indoor training and headquarters space, preferably on two levels, would be needed to accommodate all players plus operations and business employees together in one facility. The most efficient layout of the field complex requires fields to be contiguously laid out, which supports management, operation, and use of the facility, as well as reducing the impact area to its smallest footprint. Training protocols require players to be able to easily rotate from one field of play to another. Contiguous fields with level topography best allow players to rotate quickly and safely. The facility will require approximately 250 parking stalls, including a secure parking area for players with at least 50 stalls. During its work with Generator, Sounders FC worked in parallel with local real estate consultant Heartland to perform a rigorous search for possible sites. Heartland helped Sounders FC to determine a search area and criteria. Programmatic requirements determined that a minimum 12- to 20-acre site would be required, depending upon site conditions and configuration. The most acceptable geographic area was King County. Criteria critical to the organization’s mission were applied, starting with the foregoing programmatic requirements. In addition, site selection criteria captured the need for a Sounders-controlled environment for safety and security, the ability to partner with youth academy clubs and U.S. Soccer; sufficient site control and visibility Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 25 from a high-traffic corridor to enable ancillary revenue streams (such as naming rights and sponsorships); retention of current employees; equal or improved travel and transportation for employees and players, and for future talent pool; and nearby amenities. Appropriately zoned land to expedite time to entitlement and construction was also a key factor, with Seattle bidding to host the FIFA World Cup 2026. (NOTE: Since site selection, Seattle has been selected as a host city for FIFA World Cup 2026 and this site is part of the required infrastructure to host the event successfully. Therefore the Sounders must expedite site development to host.) Sounders FC's site selection process focused on locales in north, south, and east King County as being within the necessary geographic area and providing the greatest possibility to have large contiguous sites available. The strategy avoided the highly developed Seattle and Bellevue metropolitan core areas where adequately sized sites would be unavailable or prohibitively expensive. Another key factor was to find sites that were relatively level to accommodate contiguous fields and manage site size and grading impacts, and sites that would allow the Sounders to continue to be accessible in the community. Transportation considerations were also an important site selection criterion. Sounders FC organization prioritized a 30-minute travel shed for all employees and players—including youth amateur academy players, similar to the existing condition at Starfire. Proximity to good public transportation options is also important to meet the travel-shed priority and to minimize transportation and greenhouse gas impacts of the new facility. Re-use of existing entitlements, buildings, and parking areas helps minimize construction impacts and meet construction timeline constraints. Large sites in single ownerships also help expedite the business transaction and meet development timelines. After defining focus areas within the County and identifying specific properties within them, the candidate sites were sifted through a suitability rating system, to arrive at a shortlist. A deeper round of due diligence on the short list of properties rated Longacres the best, with a few other properties as possible contenders. Due to the size of sites under review, even within the shortlist, most properties had some form of critical area on-site or nearby that would require regulatory compliance measures. Regulatory complexity was a factor in site selection. From a critical areas perspective, the proposed site is outside of shoreline jurisdiction and does not require any wetland fill to meet programmatic requirements. Early conversations with City staff identified that the Longacres site is within the site availability area for the purchase of Springbrook Wetland Bank credits. The proposal to utilize a “wetland as buffer” strategy to address the proximity of the fields to the adjacent Wetland A, and purchase credits from the Springbrook Bank to offset that alteration, appeared to provide the least impactful approach to achieving critical areas compliance. After 3 years in the site selection process, Sounders FC entered into a Lease for the proposed site within Longacres, including Building 25-20. The site is in single ownership and meets programmatic requirements and site selection criteria. Mitigation sequencing (avoidance and minimization) is discussed below. 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). Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 26 As described above, the need for a new training facility for Sounders FC is unavoidable. Sounders FC has rigorously evaluated other potential sites and found them programmatically inadequate, uneconomic, and/or subject to similar critical area site constraints. Accordingly, locating the Sounders FC headquarters and training center at another site is not feasible. After a comprehensive and extensive site selection process, the Longacres Office Park was identified as the location that best accomplishes the team’s facility requirements and program objectives, including remaining within the South King County area and its proximity to other facilities for competition, travel, events, and future soccer opportunities. In addition, the existing infrastructure on-site, including the existing office building, allow for the Sounders to meet delivery expectations for the site to serve FIFA World Cup 2026 needs. As part of the site selection, Sounders FC also evaluated another location within Longacres Office Park, on the west side of Wetland A. Based upon alternative configurations explored, that site had a similar or even more extensive frontage along Wetland A, which would pose the same regulatory issues. It also was adjacent to Wetland C and other possibly regulated wetland features. That particular Longacres site was relatively narrow, which, after accounting for wetland buffers (even with buffer averaging) made it challenging to configure the fields contiguous to a building. It was also encumbered by third-party parking easements. Locating training fields in other areas on the Longacres Campus is also not possible, as the fields must be located in proximity to the Training facility building, which will be located within the Sounders FC headquarters in Building 25-20. Future developments are anticipated for the Longacres Campus and were not provided as options for the Sounders project 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. The proposed Sounders Site project area at Longacres Office Park includes the most efficient and least environmentally impactful configuration at Longacres that can fit the required 4-5 fields and a Goal Keepers (GK) Field to serve five teams. The field complex includes a mix of grass and artificial turf fields, which supports the performance and development of professional soccer players from under 10 years old through the First Team competing in MLS, and it accommodates both training- and weather-related flexibilities to support that cohesive environment. On the Sounders Site, the proposal locates the grass fields nearest to Wetland A (Fields 1, 2, and GK Field), which are placed as far away from the wetland as can be done while meeting field size and training facility adjacency requirements. The grass fields located nearest to the wetland are those that are the least intensively used, minimizing impacts to the wetland. Earlier field configurations proposed Field 1 farther north on the Site, to be centered on the frontage of Building 25-20. The field layout was redesigned to move Field 1 farther south, with just enough frontage along Building 25-20 to retain direct access, while reducing the intrusion into the wetland buffer. For maximum efficiency and performance practices, players in the First Team field (Field 1) need direct and proximate access to locker rooms, training rooms, conditioning, and Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 27 performance-related services that will be located within the Training facility building. The Training facility will be located within Building 25-20, which necessitates locating Field 1 directly west of the Building. The most efficient layout of the field complex requires fields to be contiguously laid out, which supports management, operation, and use of the facility as well as reduces the impact area to its smallest footprint. The proposed program layout accomplishes this objective while responding to the site constraints of the project area. At substantial expense to the project, the proposal removes 106,400 sf of existing surface parking, paved paths, and helicopter pad to make room for the playing fields as far south and east on the site as possible to avoid impacts to Wetland A. The placement of Fields 4 and 5, which will be artificial turf, allows for the southern part of the complex to be used when available for Greater Renton Youth Soccer and other local soccer organizations. This placement locates the more intensively used artificial turf fields the farthest away from Wetland A. Field 1 and the GK Field, located east of a trail that borders Wetland A, will be the least intensely used fields of the Sounders FC Performance Facility. These are grass fields, which will be used approximately 2-5 hours per day, exclusively for professional soccer training and team activities. The fields will be fenced, and although lighting will be provided, Field 1 and the GK Field will not be used for evening practices, so the lights would be used rarely. During the growing season, these grass fields would be mowed approximately every 2-3 days, with mowing occurring less frequently outside the growing season. Surface runoff from the fields will be collected primarily through under- field drains and will be routed through an enhanced stormwater quality treatment and detention system before being discharged into Pond B. 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. The wetland area and much of the wetland buffer area located adjacent to the project parcels are in good ecological condition, yielding little opportunity for rehabilitation or restoration efforts for on-site mitigation. However, a few small areas within this adjacent buffer area are dominated by invasive plant species and could benefit from significant enhancement efforts. Unico proposes buffer enhancement of approximately 5,500 sf within the adjacent 30,452 sf buffer area located between the proposed fields and Wetland A. Some small areas of buffer must be temporarily cleared for construction of the fields, drainage system, fencing, and utilities, but are not needed for ongoing project operations (with the possible exception of occasional maintenance activities). Those areas will be replanted with native plant species to continue as functional buffer in the developed condition. IV. Minimizing or eliminating the hazard by restoring or stabilizing the hazard area through engineered or other methods. No specific hazard is evident from the proposed Project. Detailed in Chapter 6.1.1, the Project Site will indirectly impact approximately 16,331 sf of wetland area through conversion into buffer. No actual wetland fill is required or proposed. The conversion of Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 28 wetland to buffer will be mitigated via on-site wetland buffer enhancement, as well as the use of the Springbrook Creek Wetland and Habitat Mitigation Bank. A total of 8,166 sf of mitigation credits will be purchased to offset the 16,331 sf of indirect wetland impact (0.5:1 ratio). The Project has also developed a Stormwater Mitigation Site Plan to not only meet applicable minimum requirements, but also incorporate several flood control measures to minimize the impact of the development on Wetland A and successive regional waterways downstream (see Chapter 6.1.1). V. Reducing or eliminating the adverse impacts or hazard over time by preservation and maintenance operations over the life of the action. Maintenance operations are proposed for the restored areas (Chapter 10), but specific activities such as removal and control of weedy and/or exotic invasive plants, removal of trash and debris, and thinning and removal of dead or diseased portions of trees/shrubs, would be applied to the entirety of the buffer area on and adjacent to the project parcels. Such maintenance activities throughout the adjacent buffer area would assist in improving and maintaining buffer functions in the five-year period following project completion. VI. Compensating for adverse impacts to wetlands, Wellhead Protection Areas, flood hazard areas, and habitat conservation areas by replacing, enhancing, or providing substitute resources or environments. As detailed in Chapter 7.1, Unico will pursue mitigating for the remaining 16,331 sf of indirect wetland impacts at the Springbrook Creek Mitigation Bank. The applicant proposes a mitigation ratio of 50 percent (i.e., 0.5:1.0) for its indirect impact to Wetland A that causes no or only partial loss of functions to the wetland. A total of 8,166 sf of mitigation credits will be purchased to offset the 16,331 sf of indirect wetland impact (0.5:1 ratio). The 50 percent ratio would be consistent with standard wetland mitigation bank practices across Washington State. VII. Monitoring the hazard or other required mitigation and taking remedial action when necessary. As detailed in Chapter 9, mitigation monitoring would be conducted following the final approval of the completed on-site buffer enhancements. This performance monitoring would occur for a period of five years. Performance standards (Chapter 7.3.5) will be assessed regularly to ensure that the mitigation efforts are successful. 8.2 Mitigation Alternatives & Location According to RMC 4-3-050L(1)(d), mitigation is to take place in the following locations in order of preference: 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 Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 29 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. This Critical Areas Report is for the proposed Sounders FC Center at Longacres. The Sounders “Site” accounts for seven parcels (King County tax parcels 2423049022, 0886700110, 0886700120, 0886700130, 0886700140, 0886700220, and 0886700370) on the 108-acre campus. The Sounders Site is fully needed for its programmatic functions, except in the locations where the existing wetland buffer will be maintained. Buffer enhancement in those locations is proposed. Future re-development plans for the remainder of the Longacres Campus restrict mitigation options adjacent to the Sounders’ Site. Accordingly, the Site does not afford reasonable opportunities for wetland creation or enhancement within the Sounders Site. The proposal will undertake those limited opportunities for on-site buffer enhancement that are available. Unico proposes mitigating for the 16,331 sf of indirect wetland impacts at the Springbrook Creek Mitigation Bank. The applicant proposes a mitigation ratio of 50 percent (i.e., 0.5:1.0) for its indirect impact to Wetland A that causes no or only partial loss of ecological functions to the wetland. The total number of mitigation credits to be purchased is 8,166 sf. The 50 percent ratio would be consistent with standard wetland mitigation bank practices across Washington State. This would provide in-kind mitigation at the Springbrook Creek Mitigation Bank, located near the Sounders Site. 8.3 Mitigation Timing 8.3.1 Post-Construction Approval Talasaea Consultants shall notify the City of Renton when the mitigation planting is completed for a final site inspection and subsequent final approval. Once final approval is obtained in writing, an as-built drawing will be prepared, and the monitoring period will begin. 8.3.2 Post-Construction Assessment Once construction is approved, a qualified wetland ecologist from Talasaea Consultants shall conduct a post-construction assessment. The purpose of this assessment will be to establish baseline conditions at Year 0 of the 5-year monitoring period. A Baseline Assessment report will be submitted to the City of Renton after planting is complete. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 30 CHAPTER 9. MONITORING PLAN Table 2. Projected schedule for performance monitoring and maintenance events. Year Date Maintenance Review Performance Monitoring Report Due to City Year 0, Baseline Assessment Fall X X X Spring X X1FallXX X* Spring X X2FallXX X Spring X3FallX X X Spring X4FallX X X Spring X5FallX X X* *Obtain final approval from the City (presumes performance criteria are met). 9.1 Monitoring Reports Each monitoring report will include: 1) Project Overview, 2) Requirements, 3) Summary Data, 4) Maps and Plans, and 5) Conclusions. If the performance criteria are met, monitoring for the City will cease at the end of year five (5). 9.2 Monitoring Methods The following monitoring methods may be used to evaluate the approved performance standards. 9.2.1 Assessment of Vegetation Survival Vegetation monitoring methods may include counts; photo-points; random sampling; sampling plots, quadrats, or transects; stem density; visual inspection; and/or other methods deemed appropriate by the permitting agency. Vegetation monitoring components shall include general appearance, health, mortality, colonization rates, percent cover, percent survival, volunteer plant species, and invasive weed cover. Permanent vegetation sampling plots, quadrats, and/or transects will be established at selected locations to adequately sample and represent all of the plant communities within the mitigation project area. The number, exact size, and location of transects, sampling plots, and quadrats will be determined at the time of the baseline assessment. Percent areal cover of woody vegetation will be evaluated through the use of point-intercept sampling methodology. Using this methodology, a tape will be extended between two permanent markers at each end of an established transect. Woody vegetation intercepted by the tape will be identified, and the intercept distance recorded. Percent cover by species will then be calculated by adding the intercept distances and expressing them as a total proportion of the tape length. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 31 Percent areal cover of herbaceous vegetation (emergent plant communities) will be measured using quadrats and/or sampling plots. Quadrats may be randomly located within the herbaceous community or may be located along established transects. The established vegetation sampling locations will be monitored and compared to the baseline data during each performance monitoring event to aid in determining the success of plant establishment. Percent survival of woody vegetation will be evaluated in a 10-foot-wide strip along an established transect. The species and locations of all woody vegetation within this area will be recorded at the time of the baseline assessment and will be evaluated during each monitoring event to determine percent survival. 9.2.2 Photo Documentation Locations will be established within the mitigation area from which panoramic photographs will be taken throughout the monitoring period. These photographs will document the general appearance and relative changes within the plant community. A review of the photos after the 5- year monitoring period will provide a semi-quantitative representation of plant survival. Photo point locations will be shown on a map and submitted with the baseline assessment report and subsequent performance monitoring reports. 9.2.3 Wildlife Birds, mammals, reptiles, amphibians, and invertebrates observed in the mitigation areas (either by direct or indirect means) will be identified and recorded during scheduled monitoring events, and at any other times observations are made. Direct observations include actual sightings, while indirect observations include tracks, scat, nests, song, or other indicative signs. The kinds and locations of the habitat with the greatest use by each species will be noted, as will any breeding or nesting activities. 9.2.4 Site Stability Observations will be made of the general site stability within all the mitigation areas during each monitoring event. Any erosion caused by either natural or anthropomorphic events will be recorded and corrective measures will be taken. CHAPTER 10. MAINTENANCE & CONTINGENCY Eleven maintenance reviews will be performed according to the schedule presented in Table 2 to address any conditions that could jeopardize the success of the mitigation project. Following maintenance reviews by the biologist or ecologist, required maintenance on the site will be implemented within ten business days of submission of a maintenance memo to the maintenance contractor and permittee. Established performance standards for the project will be compared to the Spring and Fall monitoring results to judge the success of the mitigation. If during the monitoring period, there appears to be a significant problem with achieving the performance standards, the permittee shall work with the City to develop a Contingency Plan in order to get the project back into compliance with the performance standards. Contingency plans can include, but are not limited to, the following actions: additional plant installation, erosion control, bank stabilization, modifications to hydrology, and plant substitutions of type, size, quantity, and/or location. If Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 32 required, a Contingency Plan shall be submitted to the City by December 31st of any year when deficiencies are discovered. The following list includes examples of maintenance (M) and contingency (C) actions that may be implemented during the monitoring period. This list is not intended to be exhaustive, and other actions may be implemented as deemed necessary. • Following each maintenance review, replace all dead woody plant material (M). • Replace dead plants with the same species or a substitute that meets mitigation plan goals and objectives, subject to Talasaea and agency approval (C). • Re-plant area after the reason for failure has been identified (e.g., moisture regime, poor plant stock, disease, shade/sun conditions, wildlife damage, etc.) (C). • After consulting with City staff and potentially other permitting agencies, minor excavations, if deemed to be more beneficial to the existing conditions than currently exists, will be made to correct surface drainage patterns (C). • Remove/control weedy or exotic invasive plants (e.g., English ivy, reed canarygrass, Himalayan blackberry, purple loosestrife, etc.) manually. The use of herbicides or pesticides within the mitigation area would only be implemented if other measures failed or were considered unlikely to be successful and would require prior agency approval. All non-native vegetation must be removed and disposed of off-site. (C & M). • Weed all trees and shrubs to the dripline and provide 3-inch-deep mulch rings 24 inches in diameter for shrubs and 36 inches in diameter for trees (M). • Remove trash and other debris from the mitigation areas twice a year (M). • Selectively prune woody plants under the direction of Talasaea Consultants to meet the mitigation plan's goal and objectives (e.g., thinning and removal of dead or diseased portions of trees/shrubs) (M). CHAPTER 11. SURETY DEVICES Pursuant to RMC 4-3-050L(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. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 33 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. CHAPTER 12. SUMMARY The Sounders FC Center at Longacres is proposed to be located at the Longacres Office Park in Renton, Washington. The proposed development includes the construction of five (5) full-sized training pitches and the utilization of 50,000 sf of office space that will be a training center and house the club’s operations and front office personnel, as well as the first, second, and academy teams. The Site was evaluated by Talasaea Consultants on 22 and 25 February, and 1 March 2022. During the February site visits, Talasaea staff performed a full Site reconnaissance and delineation of all wetland areas within the study area. During the 1 March site visit, the remaining area of the property (outside of the primary study area) was documented, although no formal test plots or delineations were recorded. Although the entire property spans both sides of Oakesdale Avenue SW, our investigation focused on the areas directly adjacent to the north and south ponds (Wetland A and Pond B). Wetland A is rated as a Category II wetland with a moderate habitat score. Thus, the code establishes a 150-foot standard buffer (for non-exempt uses that are not low-intensity land uses), and a 100-foot buffer for low-intensity land uses (RMC 4-3-050.G.2). Currently, Wetland A on the Site is bordered by a paved trail. The code defines low-impact land use as those uses “which are not likely to have a significant adverse impact on critical areas because of the low intensity of the use, minimal levels of human activity, limited use of machinery or chemicals, site design or arrangement of buildings and structures, incorporation of mitigation measures, or other factors.". The City of Renton and their secondary reviewer (Otak) agreed that the soccer pitches and keeper training areas are low-intensity land uses; therefore, buffer alterations adjacent to the fields will be calculated from the low-impact 100-foot buffer. Pond B, Feature D, and Feature G are not wetlands subject to critical areas regulations and do not require buffers (RMC 4-3- 050B.1). Unico proposes an alteration to the buffer of Wetland A. Following the guidelines outlined by the Washington State Department of Ecology Publication 21-06-003, the alteration will be achieved through the use of Wetlands as Buffers (often referred to as “paper fill”). Due to the topography of the property, the existing functional buffer, and the minimal contribution of the area directly adjacent to Wetland A, the upland buffer may be considered very minimal. Approximately 16,331 sf of Wetland A would be indirectly impacted through conversion into buffer (wetland as buffer or “paper fill”). Conversion of wetland into buffer does not fill any wetland; wetland converted into buffer still functions as a wetland in the landscape. Unico will pursue mitigating for the remaining 16,331 sf of indirect wetland impacts at the Springbrook Creek Mitigation Bank. The applicant proposes a mitigation ratio of 50 percent (i.e., 0.5:1.0) for its indirect impact to Wetland A that causes no or only partial loss of ecological functions to the wetland. A total of 8,166 sf of mitigation credits will be purchased to offset the 16,331 sf of indirect wetland impact (0.5:1 ratio). The 50 percent ratio is consistent with other wetland mitigation banks in Washington State and is in agreement with the Washington State Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 34 Department of Ecology Publication 21-06-003 and the Springbrook Creek Wetland and Habitat Mitigation Bank Instrument. In addition, Unico proposes to enhance the upland buffer of Wetland A residing between the proposed field locations and the wetland edge, an area of approximately 30,452 sf in size. Most of this buffer area is in a fairly good ecological condition; however, some areas are dominated by invasive plant species and could benefit from significant enhancement. Unico proposes buffer enhancement of approximately 5,500 sf within the adjacent buffer area located between the proposed fields and Wetland A, along with maintenance and monitoring for a period of five years. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 35 CHAPTER 13. REFERENCES 57 FR 45328. 1992. 50 CFR Part 17. Final rule listing the Marbled Murrelet as threatened in Washington, Oregon, and California, United States. U.S. Fish and Wildlife Service (USFWS). Federal Register 57(191):45328-45337. 61 FR 26256. 1996. 50 CFR Part 17. Endangered and Threatened Wildlife and Plants; Final Designation of Critical Habitat for the Marbled Murrelet. U.S. Fish and Wildlife Service (USFWS). Federal Register 61(102):26256-26320. 63 FR 11482. 1998. 50 CFR Parts 222, 226, and 227. Endangered and Threatened Species: Proposed Endangered Status for Two Chinook Salmon ESUs and Proposed Threatened Status for Five Chinook Salmon ESUs; Proposed Redefinition, Threatened Status, and Revision of Critical Habitat for One Chinook Salmon ESU; Proposed Designation of Chinook Salmon Critical Habitat in California, Oregon, Washington, Idaho. National Marine Fisheries Service (NMFS). Federal Register 63(45): 11482-11520. 64 FR 14308. 1999. 50 CFR Parts 223 and 224. Endangered and Threatened Species; Threatened Status for Three Chinook Salmon Evolutionarily Significant Units (ESUs) in Washington and Oregon, and Endangered Status for One Chinook Salmon ESU in Washington. National Marine Fisheries Service (NMFS). Federal Register 64(56): 14308-14328. 64 FR 58910. 1999. 50 CFR Part 17. Endangered and threatened wildlife and plants; determination of threatened status for bull trout in the conterminous United States. U.S. Fish and Wildlife Service (USFWS). Federal Register 64(210): 58910-58933. November 1, 1999. 65 FR 7764. 2000. 50 CFR Part 226. Designated Critical Habitat: Critical Habitat for 19 Evolutionarily Significant Units of Salmon and Steelhead in Washington, Oregon, Idaho, and California. National Marine Fisheries Service (NMFS). Federal Register 65(32): 7764-7787. 69 FR 74571. 2004. 50 CFR Part 226. Endangered and Threatened Species; Designation of Critical Habitat for 13 Evolutionarily Significant Units of Pacific Salmon (Oncorhynchus spp.) and Steelhead (O. mykiss) in Washington, Oregon, and Idaho. National Marine Fisheries Service (NMFS). Federal Register 69(239): 74571-74846. 70 FR 37159. 2005. 50 CFR Parts 223 and 224. Endangered and Threatened Species: Final Listing Determinations for 16 ESUs of West Coast Salmon, and Final 4(d) Protective Regulations for Threatened Salmonid ESUs. National Marine Fisheries Service (NMFS). Federal Register 70(123): 37159-37204. 70 FR 52629. 2005. 50 CFR Part 226. Endangered and Threatened Species; Designation of Critical Habitat for 12 Evolutionarily Significant Units of West Coast Salmon and Steelhead in Washington, Oregon, and Idaho. National Marine Fisheries Service (NMFS). Federal Register 70(170): 52629-52858. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 36 72 FR 26722. 2007. 50 CFR Part 223. Endangered and Threatened Species: Final Listing Determination for Puget Sound Steelhead. National Marine Fisheries Service (NMFS). Federal Register 72(91): 26722-26735. 75 FR 63897. 2010. 50 CFR Part 17. Endangered and threatened wildlife and plants; revised designation of critical habitat for bull trout in the coterminous United States; final rule. U.S. Fish and Wildlife Service (USFWS). Federal Register 75(200):638987-64070. October 18, 2010. 78 FR 2725. 2013. 50 CFR Part 226. Endangered and Threatened Species; Designation of Critical Habitat for Lower Columbia River Coho Salmon and Puget Sound Steelhead. National Marine Fisheries Service (NMFS). Federal Register 78(9): 2725-2796. 78 FR 61621. 2013. 50 CFR Part 17. Endangered and threatened wildlife and plants; proposed threatened status for the western distinct population segment of the Yellow-billed Cuckoo (Coccyzus americanus). U.S. Fish and Wildlife Service (USFWS). Federal Register 78(192): 61622–61666. 79 FR 48547. 2014b. 50 CFR Part 17. Endangered and threatened wildlife and plants; designation of critical habitat for the western distinct population segment of the Yellow- billed Cuckoo. U.S. Fish and Wildlife Service (USFWS). Federal Register 79(158): 48547–48652. 79 FR 59991. 2014a. 50 CFR Part 17. Endangered and threatened wildlife and plants; determination of threatened status for the western distinct population segment of the Yellow-billed Cuckoo (Coccyzus americanus). U.S. Fish and Wildlife Service (USFWS). Federal Register 79(192): 59992–60038. 81 FR 9251. 2016. 50 CFR Parts 223 and 226. Endangered and Threatened Species; Designation of Critical Habitat for Lower Columbia River Coho Salmon and Puget Sound Steelhead. National Marine Fisheries Service (NMFS). Federal Register 81(36): 9251-9325. City of Renton Municipal Code. 2022. “Critical Areas Regulations” Section 4-3-050. Cowardin, L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. U.S. Fish and Wildlife Service, Department of the Interior. FWSOBS-70/31. DNR (Washington Department of Natural Resources). 2022. Washington Natural Heritage Program Element Occurrences – Current. Accessed online on March 30, 2022, at: https://wadnr.maps.arcgis.com/apps/webappviewer/index.html?id=5cf9e5b22f584ad7a4e 2aebc63c47bda DOE (Washington State Department of Ecology), U.S. Army Corps of Engineers (USACE), and U.S. Environmental Protection Agency (USEPA). 2021. Wetland Mitigation in Washington State – Part 1: Agency Policies and Guidance (Version 2), dated April 2021. Washington State Department of Ecology Publication #21-06-003. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 37 DOE (Washington State Department of Ecology), U.S. Army Corps of Engineers (USACE), and U.S. Environmental Protection Agency (USEPA). 2006. Wetland Mitigation in Washington State – Part 2: Developing Mitigation Plans (Version 1), dated March 2006. Washington State Department of Ecology Publication #06-06-011b. Hard, J.J., J.M. Myers, M.J. Ford, R.G. Cope, G.R. Pess, R.S. Waples, G.A. Winans, B.A. Berejikian, F.W. Waknitz, P.B. Adams. P.A. Bisson, D.E. Campton, and R.R. Reisenbichler. 2007. Status review of Puget Sound steelhead (Oncorhynchus mykiss). U.S. Dept. Commer., NOAA Tech. Memo. NMFS-NWFSC-81, 117 p. Hayman, R.A., E. Beamer, and R.E. McClure. 1996. FY 1995 Skagit River Chinook Restoration Research. Progress Report No. 1. Skagit System Cooperative, LaConner, WA. Hitchcock, C.L. and A. Cronquist. 2018. Flora of the Pacific Northwest. Seattle: University of Washington Press. Hruby, T. 2006. Washington State Wetland Rating System for Western Washington. Olympia, WA: Washington State Department of Ecology Publication #04-06-025. Kerwin, J., and T. Nelson (editors). 2000. Habitat Limiting Factors and Reconnaissance Assessment Report, Volume 1: Green/Duwamish and Central Puget SoundWatersheds (Water Resource Inventory Area 9 and Vashon Island). December 2000. Washington Conservation Commission and the King County Department of Natural Resources. King County. 2019. System-wide Improvement Framework. Lower Green River, King County, Washington. Prepared by King County Water and Land Resources Division for the King County Flood Control District. February 2019. King County. 2022. “King County iMap” Accessed [March 2022]. Laymon, S. A. and M. D. Halterman. 1989. A proposed habitat management plan for Yellow- billed Cuckoos in California. Pages 272–277 in D. L. Abell, technical coordinator. Proceedings of the California Riparian Systems Conference: protection, management, and restoration for the 1990s. USDA Forest Service General Technical Report PSW-110, USDA Forest Service, Berkeley, California. Lichvar, R.W., D.L. Banks, W.N. Kirchner, and N.C. Melvin. 2016. The National Wetland Plant List: 2016 wetland ratings. Phytoneuron 2016-30: 1-17. Published 28 April 2016. ISSN 2153 733X Meyers, J.M., R.G. Kope, G.J. Bryant, D. Teel, L.J. Lierheimer, T.C. Wainwright, W.S. Grant, F.W. Waknitz, K. Neely, S.T. Lindley, and R.S. Waples. 1998. Status review of chinook salmon in Washington, Idaho, Oregon, and California. NOAA Technical Memorandum NMFS-NWFSC-35. Seattle, Washington. NMFS (National Marine Fisheries Service). 2008. Endangered Species Act – Section 7 Consultation Final Biological Opinion and Magnuson-Stevens Fishery Conservation and Management Act Essential Fish Habitat Consultation Implementation of the National Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 38 Flood Insurance Program in the State of Washington Phase One Document – Puget Sound Region. September 22, 2008. NMFS Tracking No.: 2006-00472. NMFS (National Marine Fisheries Service). 2019. ESA Recovery Plan for the Puget Sound Steelhead Distinct Population Segment (Oncorhynchus mykiss). National Marine Fisheries Service. Seattle, WA. NMFS (National Marine Fisheries Service). 2022. Species Directory: Pacific Salmon & Steelhead. Accessed online on March 12, 2020, at: https://www.fisheries.noaa.gov/species/pacific-salmon-and-steelhead l Pearson, S.F., and B. Altman. 2005. Range-wide Streaked Horned Lark (Eremophila alpestris strigata) Assessment and Preliminary Conservation Strategy. Washington Department of Fish and Wildlife, Olympia, WA. 25pp. Ralph, C. John; Hunt, George L., Jr.; Raphael, Martin G.; Piatt, John F., Technical Editors. 1995. Ecology and conservation of the Marbled Murrelet. Gen. Tech. Rep. PSW-GTR- 152. Albany, CA: Pacific Southwest Research Station, Forest Service, U.S. Department of Agriculture; 420 p. Rieman, B.E., and J.D. McIntyre. 1993. Demographic and habitat requirements for conservation of bull trout. U.S. Forest Service, Intermountain Research Station, Boise, Idaho. General Technical Report INT-302. Salmonscape. 2022. Wdfw.wa.gov/mapping/salmonscape/index.html. Accessed [March 2022]. Soil Survey Staff, Natural Resources Conservation Service, United States Department of Agriculture. 2022. Web Soil Survey. https://websoilsurvey.sc.egov.usda.gov/. Accessed [March 2022]. Stinson, D. W. 2005. Washington State Status Report for the Mazama Pocket Gopher, Streaked Horned Lark, and Taylor’s Checkerspot. Washington Department of Fish and Wildlife, Olympia. 129+ xii pp. StreamNet. 2021. “StreamNet Mapper.” StreamNet. http://map.streamnet.org/website/. Accessed [March 2022]. U.S. Army Corps of Engineers. 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (Version 2.0). Final Report, U. S. Army Corps of Engineers, Wetlands Regulatory Assistance Program. U.S. Fish and Wildlife Service. 2022. National Wetland Inventory, Wetlands Online Mapper. http://wetlandsfws.er.usgs.gov/wtlnds/launch.html. Accessed [March 2022]. USFWS (U.S. Fish and Wildlife Service). 1997. Recovery Plan for the Threatened Marbled Murrelet (Brachyramphus marmoratus) in Washington, Oregon, and California. Portland, Oregon. 203 pp. USFWS (U.S. Fish and Wildlife Service). 2004. Draft recovery plan for the Coastal-Puget Sound distinct population segment of bull trout (Salvelinus confluentus). Puget Sound Management Unit, Portland, Oregon. 389 + xvii p. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Page 39 USFWS (U.S. Fish and Wildlife Service). 2015. Recovery plan for the coterminous United States population of bull trout (Salvelinus confluentus). Portland, Oregon. Xii + 179 pages. USFWS (U.S. Fish and Wildlife Service). 2022. Information for Planning and Conservation database (IpaC). Queried on March 22, 2022. Available online at: https://ipac.ecosphere.fws.gov/. Washington State Department of Fish and Wildlife. 2022. “Priority Habitats and Species Database.” http://apps.wdfw.wa.gov/phsontheweb/. Accessed [March 2022]. Wiles, G.J., and K.S. Kalasz. 2017. Status Report for the Yellow-billed Cuckoo in Washington. Washington Department of Fish and Wildlife, Olympia, Washington. 32+ iv pp. Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Figures FIGURES Figure 1. Vicinity & Driving Directions Figure 2. Parcel Map Figure 3. National Wetlands Inventory Figure 4. NRCS Soil Map Figure 5. Fish Passage & Salmonid Presence Figure 6. Priority Habitat and Species (PHS) Figure 7. City of Renton GIS – Critical Areas Figure 8. Existing Conditions Figure 9. Proposed Site Plan with Buffer Figure 9a. Proposed Site Plan with Buffer - Enlargement Figure 10. Conceptual Mitigation Planting Plan Figure 11. Conceptual Mitigation Planting Plan – Enlargement 1 Figure 12. Conceptual Mitigation Planting Plan – Enlargement 2 Figure 13. Conceptual Mitigation Planting Plan – Enlargement 3 Figure 14. Candidate Plant List Figure 15. Candidate Plant List (Continued) Figure 16. Details Figure 17. General Notes for Habitat Features Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Appendix A APPENDIX A. Wetland Rating Forms and Figures, Talasaea Consultants, Inc., 2022 Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Appendix B APPENDIX B. Wetland Determination Data Forms, Talasaea Consultants, Inc., 2022 Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Appendix C APPENDIX C. Peer Review Memorandum, Otak, Inc., 2022 Sounders FC Center At Longacres Critical Areas Report & Conceptual Mitigation Plan 20 January 2023 Copyright © 2022 Talasaea Consultants, Inc. Longacres Critical Areas Report & Conceptual Mitigation Plan Appendix D APPENDIX D. USFWS Information for Planning and Conservation (IPaC) Report