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Home My WebLink AboutC_Response_Letter_Wetland Resources_2003120_v1.pdf 9505 19th Avenue SE, Suite 106, Everett, WA 98208 425.337.3174 www.wetlandresources.com February 25, 2020 Blue Fern Development LLC Attn: Evan Mann 11232 120th Ave NE, #204 Kirkland, WA 98033 RE: Response to City of Renton comments provided for the Canopy PUD Preliminary Plat application Wetland Resources, Inc. (WRI) has reviewed the comment letter from the City of Renton (dated January 28, 2020). Comments received are cited below in italics with WRI responses following. 10. Stream Buffer Averaging – It does not appear the proposal is eligible for stream buffer averaging as indicated on page 9 of the Critical Area Study and Conceptual Mitigation Plan prepared by Wetland Resources. RMC 4-3- 050I.2.b.i clearly states that buffer width averaging may be allowed only where, in part, there are existing physical improvements in or near the water body and associated riparian area. The Critical Areas Study does not provide an applicable response to this criterion. Reevaluation of this method will be necessary. An existing dam and multiple downstream culverts are located within Stream S, downstream of the subject site. In addition, multiple disturbances are present within the buffer of the stream, including: maintained landscaping, structures, roads and driveway. The dam and culverts within the stream channel as well and the disturbances within the buffer represent existing physical improvement within the waterbody. Thus, stream buffer averaging is allowed. 11. Wetland Buffer Averaging – Similar to the above reference stream buffer averaging eligibility, wetland buffer averaging requires an existing physical improvement in or near the wetland pursuant to RMC 4-3-050I.3.b.i. Page 11 of the Critical Areas Study does not provide an applicable response to this criterion. Reevaluation of this method will be necessary. Lincoln Ave NE and its associated right of way (ROW) is located immediately adjacent to Wetland B. This maintained city road and ROW is a clear existing physical improvement immediately adjacent to the wetland. Thus, wetland buffer averaging is allowed. 12. Wetland B Buffer Impacts – Page 14 of the Critical Areas Study asserts the proposed 240 square foot wetland buffer impacts are exempt for frontage improvements. The identified exemption in the report is intended for Wetland Resources, Inc. Blue Fern Development LLC - Canopy February 25, 2020 WRI #18158 2 utilities, traffic control, walkways, bikeways within existing improved right-of-way or easements. Please provide clarification that the area of proposed impacts is within existing improved right-of-way. The report has been updated to clarify that the proposed buffer impacts are within an existing improved right-of-way. 19. Muckleshoot Tribe Comments – Please find the enclosed comments prepared by the Muckleshoot Indian Tribe Fisheries Division. Reevaluation of the stream typing based on the Tribe’s comments will be necessary. Please provide responses and clarifications regarding the stream and stormwater treatment methods indicated in the comment letter. WRI has reviewed the City of Renton’s stream classification map which depicts a Type F stream terminating near the location of the existing dam. WRI agrees with the City’s mapping of the Type F stream to that point. WRI further determined the typing of the stream upstream of the dam adjacent to and on-site based on a gradient analysis, which was submitted as part of the original Critical Area Study (See attached figure page). The analysis was submitted to Larry Fisher of WDFW for confirmation of WRI’s determination. The attached email provides confirmation of WDFW’s review of the gradient analysis and confirmation of the Type Np stream determination. (L. Fisher, pers. comm. February 10, 2020). The Critical Area Study and Conceptual Mitigation Plan for this project have been revised. Please review the revised report as part of our response to the comment letter and markups. Should you have any questions or concerns, please don’t hesitate to call our office at (425) 337-3174. Wetland Resources, Inc. Alia Richardson Associate Ecologist & Wildlife Biologist From:Fisher, Larry D (DFW)Larry.Fisher@dfw.wa.gov Subject:RE: 18158 Blue Fern - Slope Analysis Fig.pdf Date:February 10, 2020 at 3:22 PM To :Scott Brainard scott@wetlandresources.com I am pretty busy right now, so would rather not do a site visit for this. From: Scott Brainard <scott@wetlandresources.com> Sent: Monday, February 10, 2020 2:33 PM To: Fisher, Larry D (DFW) <Larry.Fisher@dfw.wa.gov> Subject: Re: 18158 Blue Fern - Slope Analysis Fig.pdf Thanks Larry! The data is based on an actual physical survey of the site, so it’s more accurate that the lidar or clinometer that we normally use. Would you be interested in a site visit? Scott On Feb 10, 2020, at 2:28 PM, Fisher, Larry D (DFW) <Larry.Fisher@dfw.wa.gov> wrote: Hi Scott: The ﬁgure appears reasonable to me. Provided the data is accurate, I would agree with the call. Larry Fisher WDFW Area Habitat Biologist 16018 Mill Creek Boulevard Mill Creek, WA 98012 Cell: 425-449-6790 – Please note phone change to just my cell phone. <'){{}}>< <'){{}}>< From: Scott Brainard <scott@wetlandresources.com> Sent: Monday, February 10, 2020 1:02 PM To: Fisher, Larry D (DFW) <Larry.Fisher@dfw.wa.gov> Subject: 18158 Blue Fern - Slope Analysis Fig.pdf Hi Larry, We’re working on a site in the City of Renton near its boundary with Newcastle and we made a Type N stream call based on the following data/figure. Wondering if you would have time to take a look at the attached and meet me Wondering if you would have time to take a look at the attached and meet me out site to provide an opinion. Thanks and I look forward to hearing from you! Scott From:Scott Brainard scott@wetlandresources.com Subject:18158 Blue Fern - Slope Analysis Fig.pdf Date:February 10, 2020 at 1:01 PM To :Larry D Fisher larry.ﬁsher@dfw.wa.gov Hi Larry, We’re working on a site in the City of Renton near its boundary with Newcastle and we made a Type N stream call based on the following data/ﬁgure. Wondering if you would have time to take a look at the attached and meet me out site to provide an opinion. Thanks and I look forward to hearing from you! Scott