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Home My WebLink AboutC_Secondary Review_Longacres_Memo_22_0609 2828 Colby Avenue, Suite 401 | Everett, WA 98201 | Phone 425.493.5221 | otak.com k:\project\20700\20796\05 documents\reports\review1\longacres_memo_22_0609.docx Peer Review Memorandum To: Jill Ding, Senior Planner City of Renton From: Jeff Gray, PWS (Otak) Kevin Corrigan (Otak) Copies: File Date: June 9, 2022 Subject: Longacres Unico Property (Seattle Sounders FC Performance Center) - Wetlands Peer Review Project No.: Renton: PRE21-000410 Otak: 20796.000 Otak, Inc. (Otak) conducted a review of the Critical Areas – Existing Conditions Letter Report (Letter Report) dated April 29, 2022, prepared by Talasaea Consultants, Inc. (TCI) for the proposed Seattle Sounders FC Performance Center (Project) on the Longacres Office Park (LOP) property in the City of Renton. The project proponents are proposing a new training facility for the Sounders FC that will include five full-sized soccer training fields, a goalkeeper field, operations building, a maintenance facility, restroom facilities, a deck addition to the existing structure, and realignment of existing trails. The City of Renton (City) requested Otak to review the classificat ion and delineation of the existing wetlands on site described in the Letter Report for consistency with Renton Municipal Code (RMC) Critical Area Regulations (RMC 4-3-050). The LOP is 108 acres in size and comprised of 18 property parcels. The Project will be located on seven of the 18 parcels, including: 2423049022, 08867001100, 0886700120, 0886700130, 0886700140, 0886700220, and 0886700370. The LOP property previously hosted a horse racetrack until The Boeing Company purchased the property and developed the Customer Services Training Center in the early 1990s and the LOP in the mid-1990s. Development also included the implementation of the wetland mitigation project titled Surface Water Management Project and Conceptual Mitigation Plan (Shapiro Associates 1999). The following materials were reviewed by Otak: • Critical Areas – Existing Conditions Letter Report (32 pages), prepared by TCI, dated April 29, 2022, including Executive Summary (3 pages) and Attachments 1-14 (952 pages). Methods Otak biologists completed background research using available published information, and completed a site investigation on May 18, 2022 to verify delineated wetland boundaries. Wetland boundary flags were observed in the field that matched the nomenclature of the wetland identifiers in the Letter Report. Wetland boundaries were reviewed for consistency with the 1987 USACE Wetland Delineation Manual Page 2 of 4 Longacres Property – Wetland Peer Review June 9, 2022 k:\project\20700\20796\05 documents\reports\review1\longacres_memo_22_0609.docx and the 2010 Regional Supplement per RMC 4-3-050 and WAC 173-22-035, and wetland categories were reviewed for consistency with the Washington State Wetland Rating System for Western Washington. Wetlands are defined at RMC 4-3-050.B.1 and 4-11-230: “Areas that are inundated or saturated by surface water or groundwater at a frequency and duration sufficient to support, and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions. Wetlands generally include swamps, marshes, bogs, and similar areas. Wetlands do not include those artificial wetlands intentionally created from nonwetland sites, including, but not limited to, irrigation and drainage ditches, grass-lined swales, canals, detention facilities, wastewater treatment facilities, farm ponds, and landscape amenities, or those wetlands created after July 1, 1990, that were unintentionally created as a result of the construction of a road, street, or highway. Wetlands include artificial wetlands created from nonwetland areas to mitigate the conversion of wetlands.” Due to the abundance of biological wetlands on site and the site’s development history, Otak’s review of the Letter Report focused on confirming wetland boundaries, evaluating whether delineated wetlands met the definition of regulated wetlands per RMC, and then reviewing the categories of the regulated wetlands. Findings - Wetland Boundary Delineation and Wetland Classifications The Letter Report from TCI describes three wetlands (Wetlands A, C, and F) and five stormwater management features (Pond B, Feature D, Feature G, and two unnamed stormwater ponds). Wetlands A, C, and F were all classified as depressional and rated as Category II using the 2014 Wetland Rating System for Western Washington. All other features either did not meet the three-parameter definition of a wetland (Feature D), or were determined to be non-regulated wetlands (Pond B, Feature G, and two unnamed stormwater ponds) per RMC 4-11-230. See Figure 3 from the TCI Letter Report included with this memorandum. Per the Letter Report, the main distinguishing factor between all of the features is that the regulated wetlands were artificially created to mitigate the conversion of wetlands, and that the non-regulated wetlands were intentionally created from nonwetland sites, including drainage ditches and detention facilities. The Letter Report includes multiple sources of backup documentation to support jurisdictional assessments of the wetland areas on site, such as chronological photo documentation, as -built drawings, previous studies completed for the Boeing projects in the 1990’s, site plans, and two recent wetland delineation reports completed by other consultants [AMEC Foster Wheeler (2016) and NV5 (2021)]. Fourteen attachments are included in all. The Letter Report includes wetland determination data forms, but wetland rating forms were not included to support wetland classifications. The findings of Otak’s report review and site investigation are as follows: 1. Table 1 lists all of the wetland features on site, TCI’s jurisdictional assessment, and Otak’s opinion and rationale. In summary, Otak agrees with TCI’s assessment and delineation of jurisdictional wetlands on site based on the information provided in the Letter Report. Documentation of the intentional creation of wetlands from uplands for the purpose of stormwat er detention includes as-built drawings, drainage reports, and chronological photo documentation. Page 3 of 4 Longacres Property – Wetland Peer Review June 9, 2022 k:\project\20700\20796\05 documents\reports\review1\longacres_memo_22_0609.docx Table 1. Summary of Jurisdictional Wetland Features on the Longacres Property Wetland/Feature per Letter Report (TCI April 2022) Regulated per TCI Letter Report? Otak Opinion Otak Rationale Boundary Verified? Wetland A Yes Concur Mitigation wetlands (RMC 4-3-050B.1) Yes, with caveat (additional wetland areas observed along northern boundary) Pond B No Concur Meets definition of artificial (constructed stormwater pond) per RMC 4-3-050B.1. Not applicable Wetland C Yes Concur Mitigation wetlands (RMC 4-3-050B.1) Yes, with caveat (additional wetland areas observed north of delineated boundary) Feature D No Concur Does not meet three parameter criteria for wetland identification (no hydrology) Not applicable Wetland F Yes Concur Mitigation wetlands (RMC 4-3-050B.1) Yes, with caveat (current map excludes gravel trail and berm between two wetland cells) Feature G No Concur Meets definition of artificial (constructed stormwater pond) per RMC 4-3-050B.1. Not applicable Storm Pond and Conveyance (south of Pond B on Figure 3) No Concur Constructed in 2016; Meets definition of artificial (constructed stormwater pond) per RMC 4-3-050B.1. Not applicable 2. The Letter Report addresses wetland boundaries for the entire LOP property; however, the proposed Project will only occur on a portion of the entire property. Boundaries of Wetlands A, C, and F were reviewed on site, and additional wetland areas were observed on the north side of Wetlands A and C. The delineation of Wetland F includes a raised gravel berm that bisects two wetland cells that is not represented on Figure 3. The additional wetland areas and map revisions do not affect the area of the proposed Project. See annotations on Figure 3. 3. Wetland boundaries were flagged in the field and verified during the May 18, 2022 site investigation. However, the Letter Report does not include a mapping accuracy statement indicating if the flags were professionally surveyed, located with a GPS, or estimated using aerial photography and previously prepared maps by others. Action by the applicant: Provide an accuracy statement for the wetland boundaries shown on Figures 3 and 4 in the Letter Report. Page 4 of 4 Longacres Property – Wetland Peer Review June 9, 2022 k:\project\20700\20796\05 documents\reports\review1\longacres_memo_22_0609.docx 4. Wetlands A, C, and F are classified as Category II wetlands with moderate habitat scores (5-7). Wetlands were rated using the Washington State Wetland Rating System for Western Washington – 2014 Update per RMC 4-3-050G.9, and rating forms and figures were provided. Per the rating forms, Wetlands A, C, and F are Category II wetlands. Wetland A has a habitat score of 6, and Wetlands C and F have habitat scores of 5. The rating form for Wetland F is labeled Wetland E, but the figures are accurate. It is assumed that wetlands E and F were originally rated separately and then combined into a single unit, which is acceptable per the Rating System for depressional wetlands that have a hydrological connection that allows water to flow in both directions. Figure 3 shows Wetland F to have a habitat score of 5 whereas the rating form shows a habitat score of 6. However, the difference does not result in a change of wetland category or standard buffer width (150 feet). Wetland ratings were verified in the field and through desktop review. Whereas some questions could have been answered differently, any changes would not have resulted in a change to the category or buffer width of the wetlands. As such, the wetland categories and buffer widths for Wetlands A, C, and F described in the Letter Report and shown on Figure 3 are consistent with RMC 4-3-050.F and 4-3-050.G. 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