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Revised Wetland Report and Response Letter 8-14-18.pdf8-14-2018 Responses to May 17 letter from the City of Edmonds: RECEIVED AUG 14 2018 #1 : Response by Blue Heron Services is included in this packet DEVELOPMENT SERVIG ,'rCOUNTER #2 Flood hazard per May 9 memorandum was accounted for in the design of the structure and we will be working with the building dept. to provide more information as needed when we are granted the C.U.P. for the ADU. #3 the overall height stated on the drawings submitted reflects measurements already taken by our surveyor and bring the new structure overall height in at less than 25' above the average original grade as computed using City of Edmonds code. #4 For clarification , Unit as designed is 787 sq. ft. of living space. This is the total usable space inside of the exterior walls. Sincerely, Jon Parrott CITY OF EDMONDS 121 5a' Avenue North, Edmonds WA 98020 Phone: 425.771.0220 • Fax: 425.771.0221 • Web: www.edmondswa.gov DEVELOPMENT SERVICES DEPARTMENT • PLANNING DIVISION May 17, 2018 James and Julie Rose 7219 Lake Ballinger Way Edmonds, WA 98026 Subject: Letter of Completeness and Request for Additional Information Accessory Dwelling Unit Application Number PLN20180032 Mr. & Mrs. Rose: On behalf of the City of Edmonds Planning Division, I have reviewed the application for an Accessory Dwelling Unit (ADU) at 7219 Lake Ballinger Way for completeness pursuant to Edmonds Community Development Code (ECDC) 20.02.002 and 20.21.025. The City has determined that the application meets the procedural submission requirements and therefore is complete. Please accept this letter as the City's notice to applicant of determination of completeness pursuant to ECDC 20.02.003. While the application is procedurally complete, additional information and clarifications are needed for continued review of the application. Please 'respond to the following so review of this application may proceed: 1. Critical Area: The wetland report submitted with the application does not meet the requirements of ECDC 23.50.010 or 23.50.030. The wetland report claims no wetland indicators are present on the subject property, but no data forms were included with the j V ,fW wetland report to support this conclusion. The wetland report also states that a wetland report requires "natural conditions" for a delineation. The City has received many y i wetland determinations for properties around Lake Ballinger with conditions similar to the subject property. A wetland delineation was recently conducted on a property one parcel over (7315 Lake Ballinger) from the subject property and was determined to have &F a Category IV wetland present. The critical area checklist prepared for the adjacent property directly east indicated yes to the question "obvious wetland present on site." Please revise the wetland report and provide data form to support the conclusion dthat no wetland indicators or wetlands are present on the subject property. v� A portion of your property lies within the Flood Hazard Area adjacent to Lake Ballinger. % Please review enclosed memorandum dated May 9, 2018 from the Building Division. If ` you have any questions regarding the comments in this memorandum, please contact Leif Bjorback, Building Official at (425) 771-0220 or Lei£Bjorback a,edmondswa.aov 3. Building Height: The property is zoned RSW-12 and the maximum height in the zone is 25 feet. Pursuant to ECDC 21.40.030.A, height is measured from the average original grade of the site. Additionally a datum point will be required to establish a starting mark CITY OF EDMONDS 121 5t' Avenue North, Edmonds WA 98020 Phone: 425.771.0220 • Fax: 425.771.0221 • Web: www.edmondswa. "ov DEVELOPMENT SERVICES DEPARTMENT • PLANNING DIVISION '0C. 189V May 17, 2018 James and Julie Rose 7219 Lake Ballinger Way Edmonds, WA 98026 Subject: Letter of Completeness and Request for Additional Information Accessory Dwelling Unit Application Number PLN20180032 Mr. & Mrs. Rose: On behalf of the City of Edmonds Planning Division, I have reviewed the application for an Accessory Dwelling Unit (ADU) at 7219 Lake Ballinger Way for completeness pursuant to Edmonds Community Development Code (ECDC) 20.02.002 and 20.21.025. The City has determined that the application meets the procedural submission requirements and therefore is complete. Please accept this letter as the City's notice to applicant of determination of completeness pursuant to ECDC 20.02.003. While the application is procedurally complete, additional information and clarifications are needed for continued review of the application. Please respond to the following so review of this application may proceed: 1. Critical Area: The wetland report submitted with the application does not meet the requirements of ECDC 23.50.010 or 23.50.030. The wetland report claims no wetland indicators are present on the subject property, but no data forms were included with the wetland report to support this conclusion. The wetland report also states that a wetland report requires "natural conditions" for a delineation. The City has received many wetland determinations for properties around Lake Ballinger with conditions similar to the subject property. A wetland delineation was recently conducted on a property one parcel over (7315 Lake Ballinger) from the subject property and was determined to have a Category IV wetland present. The critical area checklist prepared for the adjacent property directly east indicated yes to the question "obvious wetland present on site." Please revise the wetland report and provide data form to support the conclusion that no wetland indicators or wetlands are present on the subject property. 2. A portion of your property lies within the Flood Hazard Area adjacent to Lake Ballinger. Please review enclosed memorandum dated May 9, 2018 from the Building Division. If you have any questions regarding the comments in this memorandum, please contact Leif Bjorback, Building Official at (425) 771-0220 or Lei f.Bjorback a edmondswa.gov 3. Building Height: The property is zoned RSW-12 and the maximum height in the zone is 25 feet. Pursuant to ECDC 21.40.030.A, height is measured from the average original grade of the site. Additionally a datum point will be required to establish a starting mark to compute grade elevation of the designated four corners for the building height calculations. The datum point must be a permanent point of reference, such as the top of a manhole cover, fire hydrant, or street monument. On the site plan describe the datum point and show its location and elevation. Sheet'/z shows the maximum allowable height as 25'-9", however that would be 25' maximum from average original grade per code. 4. Size Criteria: Your cover letter indicates that the proposed ADU is 835 square feet when including the width of the walls in the calculation, but that measuring the size of the ADU to the interior walls is 45 square feet less. With new construction, the maximum allowed size of an ADU is limited to 800 square feet of livable area. Thus, you can exclude the wall width from the area of the ADU, but this area must be below 800 square feet. Please confirm that the proposed ADU will be consistent with this requirement. According to ECDC 20.02.003.1), the above requested information must be submitted within 90 days (or by August 15, 2018) or the application will expire. Since the application has been determined to be complete, a notice of application will be posted on the subject property and mailed to adjacent property owners within the next two weeks consistent with ECDC 20.03.002. If you have any questions of me, please contact me at 425-771-0220 or via email at m ichele.szafran�i4edmondswa.gay. Sincerely, Michele Q. Szafran Planner Date: To: From: Subject: MEMORANDUM May 9, 2018 Michele Szafran, Planner Leif Bjorback, Building Official Rose Garage/ADU addition 7219 Lake Ballinger Way PLN2018-0032 The City of Edmonds Building Division has performed a preliminary building code review of the plans that were submitted under the referenced application number, and have the following comments. 1. A soils investigation and report may be required for the project due to the adjacent ascending slope to the east of the structure. A more detailed and legible plot plan will be necessary in order to determine this requirement. 2. The house and proposed addition appear to be located within the Zone A flood hazard area of Lake Ballinger. (The City established base flood elevation for the lake is 286.14 NAVD88.) An elevation survey will be required for the project, and all new construction will need to comply with the requirements of section R322 of the International Residential Code. Thank you. City of Edmonds cQ Building Department SOIL Sampling Point: Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth Matrix Redox Features (Inches) Color (moist) ° Color (moist) % Tvpe Loci Texture Remarks 1g 2 too to u JA so; Con�ISm t�l at -1.611Z -5/3 - ---14_ - 41 t �, San ,I 'T o: C=Concentration D=De lotion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 21-ocation: PL=Pore Lining, M=Matrix. Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils : _ Histosol (A1) _ Sandy Redox (S5) _ 2 cm Muds (A10) Hlstic Epipedon (A2) _ Stripped Matrix (S6) _ Red Parent Material (TF2) Black HLatic (A3) _ Loamy Mucky Mineral (F1) (except MLRA 1) _ Very Shallow Dark Surface (TF12) — Hydrogen Sulfide (A4) _ Loamy Gleyed Matrix (F2) _ Other (Explain In Remarks) _ Depleted Below Dark Surface (Al 1) _ Depleted Matra (F3) _ Thick Dark Surface (Al2) _ Redox Dark Surface (F6) 31ndIcaWrs of hydrophytic vegetation and _ Sandy Mucky Mineral (S1) _ Depleted Dark Surface (F7) wetland hydrology must be present, _ Sandy Gleyed Matra (84) _ Redox Depressions (F8) unless disturbed or problematic. Restrictive Layer (if present): Type: Depth (Inches): Hydric Soil Present? Yes No Remarks: HYDROLOGY Wetland Hydrology Indicators: Primary Indicators (minimum of one required- Mwk all that nnnrv) Secondary Indicators (2 or more required) _ Surface Water (Al) _ Water -Stained Leaves (B9) (except _ Water -Stained Leaves (B9) (MLRA 1, 2, _ High Water Table (A2) MLRA 1, 2, 4A, and 4B) 4A, and 4B) _ Saturation (A3) ` Salt Crust (B11) _ Drainage Patterns (B10) _ Water Marks (131) _ Aquatic Invertebrates (B13) ` Dry -Season Water Table (C2) — Sediment Deposits (1212) _ Hydrogen Sulfide Odor (Cl) _ Saturation Visible on Aerial Imagery (C9) — Drift Deposits (83) _ Oxidized Rhtzospheres along Living Roots (C3) _ Geomorphic Position (132) _ Algal Mat or Crust (B4) _ Presence of Reduced Iron (C4) _ Shallow Aquitard (133) _ Iron Deposits (135) _ Recent Iron Reduction In Tilled Soils (C6) _ FAC-Neutral Test (135) _ Surface Soil Cracks (136) _ Stunted or Stressed Plants (131) (LRR A) _ Raised Ant Mounds (DG) (LRR A) Y Inundation Visible on Aerial Imagery (B7) _ Other (Explain in Remarks) _ Frost -Heave Hummocks (137) _ Sparsely Vegetated Concave Surface (138) ricia uDservations: Surface Water Present? Yea No Depth (inches): Water Table Present? Yes No Depth (inches): Saturation Present? Yes No Depth (inches): Wetland Hydrology Present? Yes No includes capillary fringe) Describe Recorded Data (stream gauge, rnonitoring well, aerial photos, previous inspections), if available: US Army Corps of Engineers Western Mountains, Valleys, and Coast — Version 2.0 Project/Site: Applicant/OM Investigator(s): Landform (hillsiope, terrace, etc.): Subregion (LRR): Soil Map Unit Name: D,/, C- 14r�� WETLAND DETERMINATION DATA FORM - Western Mountains, Valleys, and Coast Region Kim Peterson BHSINC Lat: Sampling Date: -_ �� ' 4 - I , State: _WA Sampling Point: Section, Township, Range: -3 Z l Z.1 -UT Local relief (concave, convex, none): Slope (%): Long: Datum: NWI classification: Are climatic / hydrologic conditions on the site typical for this time of year? Yes / No (if no, explain in Remarks.) Are Vegetation Sol[ , or Hydrology significantly disturbed? Are "Normal Circumstances" present? Yes X No Are Vegetation , Soil . . or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transacts. important features. etc, Hydrophytic Vegetation Present? Yes No Hydric Soil Present? Yes No �_ Is the Sampled Area 1/ Wetland Hydrology Present? Yes No _� within a Wetland? Yes No Remarks: t ► Its (P0 f �%eae- cid Q� �1.��%LdN/ S7"j�j ��%► LanG{� l Sik Q/kr�C�, h VEGETATION - Use scientific names of nlantie Absolute Dominant Indicator Treetratun (Plot size: _T) r °6 Cover Species? Status i. k5et�Jv( r �c Nr�h �� �S, j y 2.l?i�S V 3. 4. = Sapllncl/Shrub Stratum (Plot size: Total Cover 1. 2. 3. 4. ti. = Total Cover Herb Stratum (Plot size: � 1. - 2. -- �- 3. 4. 5. B. 7. 8. 9. 10. 11. _ Woody Vine Stratum (Plot size: Total Cover 1. 2. `- / = Total Cover Dominance Test worksheet: Number of Dominant Species That Are OBL, FACW, or FAC: (A) Total Number of Dominant z Species Across All Strata: `� (B) Percent of Dominant Species 't7V That Are OBL, FACW, or FAC: WB) Prevalence Index worksheet: Total % Cover of: Multioiv bv- OBL species X 1 = FACW species x 2 = FAC speciesx 3 = FACU species _8 Q x 4 = 37-0 UPL species x 5 = Column Totals: —Lq_ Q (A) s n o (B) Prevalence Index = B/A = 3 Hydrophytic Vegetation Indicators: _ 1 - Rapid Test for Hydrophytic Vegetation _ 2 - Dominance Test is >5o% 3 - Prevalence Index is S3.0' _ 4- Morphological Adaptations' (Provide supporting data in Remarks or on a separate sheet) 5 - Wetland Non -Vascular Plants' _, Problematic Hydrophytie Vegetation' (Explain) 'Indicators of hydric soil and wetland hydrology must be present, unless disturbed or problematic. Hydrophytic Vegetation Present? Yes No % Bare Ground In Herb Stratum Remarks: fs Ca Ularldsco fou lawnlp,,, n N of (r OQ_U�", r-\ j lu US Amty Corps of Engineers Western Mountains, Valleys, and Coast - Version 2.0 spa 10` sq lbal wel WETLAND DETERMINATION DATA FORM — Western Mountains, Valleys, and Coast Region ' L %%,. Jj Project/Site: rU� � c%� %I Sampling Date: ApplicantKMmr. �iJ [ i State: IVlr Sampling Point Investigator(s): IGM Peterson BHSTNC section, Township, Range: 3Z"2.'!-�0, - l a AIlorm 00slope, terrace, etc.): Lneal relief (concave, convex, none): Slope (9L): Subregion (LRR): Let: Long: Datum: Soil Map Unit Name: NWI ossification: Are climatic I hydrologic conditions on the site typical for this time of year? Yes V No (If no, explain in Remarks.) Are Vegetation . Soil or Hydrology significantly disturbed? Are "Normal Circumstances" present? Yes % No Are Vegetation Soil or Hydrology naturally problematic? (If needed, explain any answers in Remarks) , SUMMARY OF FINDINGS - Attach site map showing sampling point locations, transecis, important features, etc. Hydrophytic Vegetation Present? Yes No--Y,_, Hydite Sol Present? Wetland Hydrology Present? Yes NO Yes No Is the Sampled Area within a Wetland? Yes No Remarks: / IS !$ COD , f'GCrr cid a VEGETATION — Use scientific names of plants. Tree Stratum (Plot eke: ) 1. 2. 3. 4. SaplingiShrub Stratum (Plot site: 1. 2. 3. 4. 5. Absolute Dominant Indicator Dominance Test worksheet: % Cover Soecles? Status Number of Dominant Species That Are OBL, FACW, or FAC: (A) Total Number of Dominant Species Across All Strata: (B) Total Cover Herb tu Stram (Plot size: 1 Total Cover 2. 3. 4. 5. 6. 7. 8. 9_ 10. 11. Total Cover Woody Vine Stratum (Plot size: ) 1. 2. % Bare Ground in Herb Stratum -Total Cover Remarks: Percent of Dominant Species That Are OBL, FACW, or FAC: (RIB) Prevalence Index worksheet: Total % Ceyar nf• MulfiDIV bv: OBL species x 1 = FACW species x 2 = FAC species t 00 x 3 = -'SO 0 FACU species x 4 = UPL species X5. Column Totals: 0" (A) SD Q (B) Prevalence Index = BIA = Hydrophytic Vegetation Indicators: _ 1 - Rapid Test for Hydrophytic Vegetation _ 2 - Dominance Test is >5o% _ 3 - Prevalence index is sa.W 4 - Morphological Adaptations' (Provide supporting data in Remarks or on a separate sheet) 5 - Wetland Non -Vascular Plants' Problematic Hydrophytic Vegetation' (Explain) 'Indicators of hydric soil and wetland hydrology must be present, unless disturbed or problematic. Hydrophytic Vegetation Present? Yes US ftW Corps of Engineers Westem Mountains, Valleys, and Coast- Version 2.0 SOIL Sampling Point: 2.— Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth Matrix Redox Features (inches) Color (moist) % Color (moist) % Type, Texture Remarks D _ _ 7.5 z S(rtnup� ✓ s I Z „�.w 'Type: C=Concentration D=De lotion RM=Reduced Matrix CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix. Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils': Histosol (Al) _ Sandy Redox (S5) _ 2 cm Muck (A10) _ Histic Epipedon (A2) _ Stripped Matrix (S6) _, Red Parent Material (TF2) _ Black Histic (A3) Loamy Mucky Miners] (F1) (except MLRA 1) _ Very Shallow Dark Surface M12) Hydrogen Sulfide (A4) _ Loamy Gleyed Matrix (F2) _ Other (Explain in Remarks) Depleted Below Dark Surface (Al 1) _ Depleted Matrix (123) _ Thick Dark Surface (Al2) _ Redox Dark Surface (F6) 3indicatom of hydrophy is vegetation and _ Sandy Mucky Mineral (S1) — Depleted Dark Surface (F7) wetlend hydrology must be present, _ Sandy Gloyod Matrix (S4) _ Redox Depressions (FS) unless disturbed or problematic. Restrictive Layer (if present): Type: �CrZ I S a GI�Ld �( t l Y1 C� lr) f' Depth (inches): Hydric Soil Present? Yes No Remarks: ,T� k 'rs i 3 a n � �� I-1, -� \ Sol 1 iG► r �u�, ov tk e cff "i WKWL%JWT Wetland Hydrology Indicators: Prirrrary Indicators (minimum of nnn required' rheckatr tapply) Secondary Indicators (2 or more required) — Surface Water (Al) — Water -Stained Leaves (89) (except ^ Water -Stained Leaves (69) (MLRA 1, 2, _ High Water Table (A2) MLRA 1, 2, 4A, and 413) 4A, and 48) -- won (A3) _ Salt Crust (811) _ Drainage Patterns (B10) _ Water Marks (B1) _ Aquatic Invertebrates (B13) _ Dry -Season Water Table (C2) --- Sediment Deposits (B2) _ Hydrogen Sulfide Odor (C1) _ Saturation Visible on Aerial Imagery (C9) Drift Deposits (B3) _ Oxidized Rhizospheres along Living Roots (C3) — Geomorphic Position (132) _ Algal Mat or Crust (B4) _ Presence of Reduced Iron (C4) _ Shallow Aquitard (D3) iron Deposits (85) _ Recent Iron Reduction in Tilled Soils (06) _ FAC-Neutral Test (D5) — Surface Soil Cracks (136) _ Stunted or Stressed Plants (131) (LRR A) _ Raised Ant Mounds (06) (LRR A) _ Inundation Visible on Aerial Imagery (s _ Other (Explain in Remarks) _ Frost -Heave Hummocks (D7) _ Sparsely Vegetated Concave Surface (B8) Field Observations: Surface Water Present? Yes No Depth (inches): Water Tattle Presets? Yes No Depth (inches): Saturation Present? Yes No includes ra ilia Erin e Depth (inches): Wetland Hydrology Present? Yes No Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), it available: Remarks: US ArmY Corps of Erglneere Western Mountains, Valleys, and Coast — Version 2.0 Blue Heron Services Blue Heron Services Inc PO 393 Index WA 98256 360 793 7767 (phone) bheron@seanet.com DATE: 5 18 2018 Critical Area Assessment for Jon Parrott 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 Contact: Parrott.fam i( comcast.net Proposed Development: Application for construction of an ADU Legal Description: LAKE BALLINGER LAND CO SUBDIV 1 BLK 008 D-01 - E 120FT LOT 1 MEAS ALG S LN TGW THATPTN OF 30FT VAC RD LY S OF & AD] TO SD E120FT EXC S 16FT OF SD VAC RD TO ST OF WA BY QCD 441-225 AF NO 931508 ON 10/13/49 TGW SHRLDS OF 2ND CLASSIN FRONT OF ADJ TO & ABTG THOF 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 1 updated May 2018 Overview: The site is located on the south end of Lake Ballinger (listed as Ballinger Lake on some State documentation). The home is listed on the County tax files as being built in 1953, making this one of the first homes on the lake. Since that time the home has been occupied and landscaped over the decades creating a lake side lot which has little to no interaction with the natural environment. The site is in WRIA 08, which is part of the Cedar-Sammamish watershed area. Lake Ballinger is a 100 acres in size and listed as a lake in the City of Edmonds, Mountlake Terrace and in Snohomish County. The lake is used recreationally, with public access points, in addition to the residential make-up of the shoreline. The lake receives most of its inflow from Hall Creek at the north end of the lake along with various permitted and unpermitted stormwater outlets contributing flow to the lake. Much of the outflow (and in flow) are piped at various portions of the system from north to south. McAleer Creek is listed as the single outlet and this stream drains to Lake Washington. Recent studies have indicated that McAleer Creek can support anadromous fish at times and fish have been spotted at the fish ladder and in the flood control system, though there are many and significant blockages in the stream system. Approach to existing home from Ballinger Way. All lakes experience impacts from development in one form or another. Historical data indicates that Ballinger Lake was dug from a wetland decades ago and now, in modern times, portions of the lake are beginning to fill in though the natural process often takes thousands of years. 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 2 updated May 2018 Historically notes indicate that in the 1970's the lake was showing signs of `Eutrophication' which is the natural process of lakes aging and nutrient content increasing to produce greater algae and plant growth. As a lake fills with sediment and organic matter, it can gradually disappear and take on the characteristics of a wetland or meadow. The study by Mount Lake Terrace in 2014 makes the comment that Lake Ballinger may eventually become a large marsh/wetland complex with a stream channel flowing between the current outlet of Hall Creek at the north end and McAleer Creek at the south end, but at this time the lake itself is defined as a lake and as such is subject to the Shoreline Management Act. Current zoning and development around the lake, in each of the legal entities, has created a living unit density of five to eight dwellings per acre along the lake shore edge, except in the public access areas. The Lake Ballinger shoreline is developed with single family residences and recreation, most of the homes also have piers, docks and/or bulkheads. Lake Ballinger includes a monitoring system for lake elevations which warns residents of possible flooding due to fluctuation of the lake level in storms. National Wetland Inventory has identified Lake Ballinger as a `lake' with a strip of adjacent wetlands on the west and north, though not in this review area. (see green on map) 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 3 updated May 2018 May 18 2018 Additional information at the request of the city. As noted on page 7 The previous report noted This specific lot does not include any wetland indicators within the lot and there is no wetland area associated with the lakes ordinary high water mark due to the structural features of the lot and adjacent parcel conditions. There is a well-defined bulkhead at the lake edge on this parcel except on the most eastern corner edge where there is a fence and landscaping on both sides of the lot line. Most homes in the area have landscaped to the lake edge which leaves few if any natural features at the water's edge. On site the lawn and landscaping are highly maintained and urbanized with imported materials and structural development as close as 10 feet from the lake, all of which have been in place for decades. In review of the Army Corps Manual for identification I have determined that this site, within the boundaries of the legal developed lot, did not include conditions that meet the criteria noted: `and that under normal circumstances do support, a prevalence of vegetation typically adapted for life in saturated soil conditions'. Supporting information includes: jam..*• ��� . .. � � .: i! ON ..4 This photo shows typical lot conditions looking Lake Ward from the SFR. Lawn and landscaping which had taken place over 60 years has significantly altered any `natural' conditions within the lot. While some soils may provide a profile that could be identified as hydric, this development has not only constructed a large bulkhead at the lake to prevent any interface with the natural hydrology, the landscaping on this parcel has been largely installed, at the lot lines, to separate soils and vegetation from natural conditions. 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 4 updated May 2018 The National Wetlands Inventory photo may provide the clearest example of site conditions available on a public map. The lots to the west of this parcel have natural and naturalized connections to the lake which allow those parcels to be impacted by the rise and fall of the lake as well as possibly including a capillary fringe soil condition on those lots. The City of Edmonds letter dated May 17`h, requesting information, noted that a lot "one parcel" over has reported a Category IV wetland on site. The address provided was 7315 Lake Ballinger Way. I am unable to find an address in the Snohomish County data base for 7315 but I assume this is within the lot currently addressed as 7317, which is the second lot to the west of the review parcel. To the best of my knowledge the lot to the west is (on county mapping) 7225 7225 lake Ballinger Way, 00488800800102. If the City does have a wetland report indicating a wetland on a site adjacent to this parcel, or a location which would be critical in the city's final determination, please provide that location for mapping and I can add that and define a buffer if needed. The Snohomish County and USDA soil mapping services define the soil issues on this and adjacent parcels with the maps below. This first the map is from the County web site and reports some "mapped" critical areas at this general location, the second map is from the USDA soil mapping system. Both clearly indicate that a soil called Mukilteo Muck is/could be present on all the lots in the area. Based on the historical background for the development of the lake (excavating an existing wetland) these soils would be typical in many locations. 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 5 updated May 2018 I have included two data sheets taken at this site. One is the road edge slope (proposed site development) location and one from the lawn (about 10 feet from the bulkhead) which represents the typical vegetation and soil throughout the lot. In�ei,ta ien lw.a,,,, Enwgh,t WetlnrA 3 Some areas of the lot, along the edges, included landscape plantings and development and the soils in this area I would list as "urbanized" due to he amount of alteration which has taken place. I did not find a site condition, on this lot, which met the criteria for a wetland condition based on the Army Crops definition. This evaluation was made on the lot 00488800800101 only. There are visible clues that wetland rated vegetation (FACW and OBL) may be present off site, and the lake itself is a type of wetland on some available mapping features. Since the proposed development is to the south side of the existing home, without any impacts to the lake areas, the need to explore meticulous data regarding the adjacent lot conditions did not seem to be necessary. 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 6 updated May 2018 ESA / Listed Species: In the City of Edmonds Shoreline Inventory and Characterization for Shorelines, the Ballinger Lake habitat is stated as having no formally designated presence or habitat for listed species of fish. The study does note that eagles may be present along the shoreline in some areas. The lake is listed for recreational fishing opportunities that include stocked Rainbow Trout and resident Coastal Cutthroat Trout, Largemouth Bass, and Yellow Perch. Black Crappie and Bullhead Catfish. In the State & County mapping program, updated on a regular basis, there is indication that ESA species are associated with the lake and shows mapping for Chinook, Pinks, Coho and Steelhead as associated with the stream flows through the lake. ESA Listing Units Fcp Lasting Unit' • Spring Chinook ESUs Summer Chlnnok ESUs Fall Chinook ESUs Summer Chum ESUs Fall Chum ESUs Winter Chum ESUs Coho ESL's Pink Odd Yeal ESUs Pink Even Year ESUs Sockeye ESUs Minter Steelhead DPSs Summer Steelhead DPS �lrtl It til i.� - — ��-�+m .Nviic�,rlb.. - � W"L hF tlPi b-- :IN Salmonseape mapping November 2017 Lake Ballinger is listed on Washington State's 303(d) list for failing to meet the U.S. Environmental Protection Agency (EPA) human health criteria for total phosphorus. Various air photos indicate there are large algal blooms at times and the lake is being studied and treated for high level of nutrients and phosphorus. Aerial photos reveal many individual structures that extend into the lake. These structures alter the shoreline characteristics due to physical and ecologic changes though the effects are difficult to estimate and define on an individual basis since the lake edge is so highly developed and human created. No additional in or on water work is proposed for this project, there will be no new impacts adjacent to the lake. This specific lot does not include any wetland indicators within the lot and there is no wetland area associated with the lakes ordinary high water mark due to the structural features of the lot and adjacent parcel conditions. There is a well-defined bulkhead at the lake edge on this parcel except on the most eastern comer edge where there is a fence and landscaping on both sides of the lot line. Most homes in the area have landscaped to the lake edge which leaves few if any natural features at the water's edge. 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 7 updated May 2018 On site the lawn and landscaping are highly maintained and urbanized with imported materials and structural development as close as 10 feet from the lake, all of which have been in place for decades. Site In checking the Priority Species Listing (11 2017) three items are noted by the mapping system. This identified the lake as having emergent wetland conditions and a high waterfowl concentration and the viable habitat for these species. Freshwater Emergent Null Aquatic Habitat Wetland (show) Wetlands (show) Null Aquatic Habitat Waterfowl Null Regular Concentrations (show) Concentration 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 8 updated May 2018 The State Water Typing map indicates that Fish rated streams do impact the waters of Lake Ballinger. Water Bodies Water Bodies Flats;Gravel Bars Ice Man Made Features Open'Nater 'Net Area Streams Streams — Type S — Type F — Type N. Np, Ns -- U unknown Based on the City of Edmonds Code 23.90.040 the protected buffer for ESA waters are listed as Type F anadromous fishbearing stream adiacent to reaches with anadromous fish access: 100 feet; Type F anadromous fishbearing stream adjacent to reaches without anadromous fish access: 75 feet; The other important regulatory tool appears to be the Shoreline Master Program regarding the State of Washington and the plan and recent updates as adopted by the City of Edmonds. The City has defined this area of Lake Ballinger as Shoreline Residential III which allows homes and ADU's as part of the development scheme. Shoreline Designation Shoreline Residential III nd SMP Designations vatic I Shoreline Residential III Planning Segement Brea vatic I Urban Mixed Use I OHW nservancy • Urban Mixed Use II Edmonds City Limits tural Urban Mixed Use III oreline Residential I � Urban Mixed Use IV Railroad oreline Residentia II 1 Urban Railroad �� stream City of Edmonds Shoreline Master Program Update 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 9 updated May 2018 k'I In the Shoreline Master Plan there is documentation that future restoration and rehabilitation is slated for areas to the west of this site and in areas belonging to other regulatory agencies. ❑ While there appears to be an invasive plant issue (based on landowners information) the mapping system did not clearly define this an issue in this area. Ell The lake is not indicated as a Biological Resource in the City mapping, nor is it listed as an area of geological hazard. The beach edge and lake bottom soils are mapped as mixed coarse substrate and kelp. ❑ Existing land use is noted as Residential Single family ❑ The basin inventory indicates that over 808 aces drains into Ballinger Lake. Conclusion: In the June 2, 2017 letter to the applicant, the City staff asks that future documentation submitted to the City include a delineation of the wetland and assessment of the wetland category for a buffer width in Compliance with City of Edmonds Code 23.40 and 23.50. Based on the information I have found in reviewing the various critical area issues related to this site, I would propose instead to address each of the possible Critical Area Protection widths which could apply to the lot and define how those would or would not be impacted by the proposed development. This site, at this location on the lake edge, does not appear to meet any regulatory definitions for a wetland on or adjacent to the lot. A wetland determination requires natural conditions exist for the delineation and then have the presence of hydric soils, this (and adjacent) sites are so significantly altered (with non -conforming legal development) that is not possible to discern. The City of Edmonds Shoreline Management Plan regulates the area within 200 feet of the ordinary high water mark of the lake. This Shoreline edge would be located in Ballinger Way and encompasses the whole parcel. City of Edmonds Shoreline Management Plan has designated this area as Residential III. In agreement with the proposed development the Shoreline Code and the zoning code support the use of the lot as a residential site with an ADU. There is no conflict with the City of Edmonds Shoreline Management Plan or city Zoning. The City of Edmonds Fish and Wildlife Conservation and Critical Areas Code indicate this area may or may not be an ESA water due to the association with streams inflowing and out falling from the lake. A stream with a designation of Np (a perennial non fish bearing steam) requires a 50 foot buffer. Based on the location of the streams (which are not near the site), there is no conflict with the proposed development and the required buffer width for these streams. 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 10 updated May 2018 If this water is reviewed as an ESA rated water in the City of Edmonds, the lake could have a buffer related to the stream and the primary association to fish which would be 75 feet (if the fish were not making it into the lake due to restrictions created by humans or other blockages), and 100 feet of buffer width if the fish were using habitat in the lake. As such neither a 75 foot or 100 foot protective buffer would impact the proposed area of development on this site. The existing home is between 60 and 88 feet from the lake edge. There would be no conflict with the proposed ADU development based on these buffer width areas. It is important to note the new development may have to meet the City of Edmonds drainage code and comply with the requirements for stormwater control during construction and after. A designed drainage plan could incorporate new disturbance within one of these buffer areas addressed. If so a review of that development proposal would be needed. Kim Peterson Blue Heron Services Inc PO 393 Index WA 98256 360 793 7767 (o) 425 327 5799 (c ) bheron@seanet.com 5 182018 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 11 updated May 2018 Reference: "Wetlands" means those areas that are inundated or saturated by ground or surface water 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 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. However, wetlands may include those artificial wetlands intentionally created from nonwetland areas created to mitigate conversion of wetlands if permitted by the city (WAC 365-190-030(22)). Wetlands are further classified into Categories 1, 2, 3 and 4. (See ECDC 1 (B).) City Category and Ratings Minimum Buffer Buffer Width Buffer Width Bufferwidth Width (Wetland Wetland Category (wetlandscores 5 (Wetland scores 6 (Wetland scores 8 scores 3 - 4 habitat points) - 7 habitat points) - 9 habitat points) habitat points) Category 1 75 ft 105 ft 165 ft 225 ft Based on total score Category 1 190 ft 190 ft 190 It 225 It Bogs and wetlands of high conservation value Category I 75 ft 105 ft 165 ft 225 ft orested Category 1 150 ft 150 ft 150 ft 150 ft Estuarine Category If: 75 ft 105 ft 165 It 225 ft Based on score Category III (all) 60 ft 105 ft 165 ft 165 ft Category IV (all) 40 ft 40 ft 40 ft 40 ft Protection of the buffer areas should include: 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 12 updated May 2018 Disturbance Required Measures to Minimize Impacts Lights Direct lights away from wetland Noise Locate activity that generates noise away from wetland • ffwarrented enhance exlsling buffer with nadvevegeladon plantings adlacenito noise source • For activilles that generate relatively continuous, potentially disruptive noise, such as certain heavy industry or mining, establish an additional 10 it heavily vegetated buffer strip immediately w4acenl to the outer wetland buffer Toxic runoff • Route all new, untreated runoff away from wetland white ensuring wadand is not dewalered • Establish covenants limiting use of pestlddes within 150 ft of wetland • Apply Integrated pest management Slone water runoff Retrofit storm water detention and treatment for roads and existing adjacent development • Prevent channelhed flow from lawns that directly enters the buffer • Use low impact development techniques (per Puget Sound Acdon Teem publication on LID techniques) Change In water • Infiltrate or treat detain, and disperse Into buffer new runoff from Impervious regime surfaces and new lawns Pals and human • Use privacy fendng OR plant dense vegetation to delineate buffer edge and to disturbance discourage disturbance using vegetation appropriate for the ewragion • Place wetland and Its buffer Ina separate tractor protect with a conservation easement Dust • Usa best management practices to control dust Disruption of corridors I.ta'nta.n connwtAni to off-sde aref5 that ire rnois;vihed or connections Pestow ccvndors or connections to o9•s-1e hatoo-s b; •orlon•, 1) 23.90.040 Development standards — Specific habitats. A. Endangered, Threatened, and Sensitive Species. 1. No development shall be allowed within a fish and wildlife habitat conservation area or buffer with which state or federally endangered, threatened, or sensitive species have a primary association, except that which is provided for by a management plan established by the Washington Department of Fish and Wildlife or applicable state or federal agency. 2. Whenever activities are proposed adjacent to a fish and wildlife habitat conservation area with which state or federally endangered, threatened, or sensitive species have a primary association, such area shall be protected through the application of protection measures in accordance with a critical areas report prepared by a qualified professional and approved by the director. Approval for alteration of land adjacent to the fish and wildlife habitat conservation area or its buffer shall not occur prior to consultation with the Washington Department of Fish and Wildlife for animal species, the Washington State Department of Natural Resources for plant species, and other appropriate federal or state agencies. 3. Bald eagle habitat is subject to the Federal Bald and Golden Eagle Protection Act. Washington State bald eagle protection rules (WAC 232-12-292) shall not be required as long as bald eagles are not listed as a state endangered or threatened species. 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 13 updated May 2018 1. Standard Stream Buffer Widths. Buffers for streams shall be measured on each side of the stream, from the ordinary high water mark. The following shall be the standard buffer widths for streams based upon the Washington State Department of Natural Resources water typing system and further classification based upon fish presence (fishbearing vs. nonfishbearing) for the Type F streams existing in the city of Edmonds: a. Type S: 150 feet; b. Type F anadromous fishbearing stream adjacent to reaches with anadromous fish access: 100 feet; c. Type F anadromous fishbearing stream adjacent to reaches without anadromous fish access: 75 feet; d. Type F nonanadromous fishbearing stream: 75 feet; e. Type Np: 50 feet; f. Type Ns: 40 feet. Drainage Requirements 18.30.060 1. The thresholds outlined in this section are only applicable to this subsection See also the Edmonds Stormwater Addendum for supplemental information on thresholds. a. All development shall be required to comply with Minimum Requirement No. 2. b. Category 1 project sites shall comply with Minimum Requirements No. 1 through No. 5. Category 1 includes projects that: i. Result in 2,000 square feet, or greater, of new plus replaced hard surface area; or Minimum Requirement No. 1 — Preparation of Stormwater Site Plans. Minimum Requirement No. 2 — Construction Stormwater Pollution Prevention Plan (SWPPP). Minimum Requirement No. 3 — Source Control of Pollution Minimum Requirement No. 4 — Preservation of Natural Drainage Systems and Outfalls Minimum Requirement No. 5 — On -Site Stormwater Management Alderwood Typical profile H1 - 0 to 7 inches: gravelly ashy sandy loam E' H2 - 7 to 35 inches: very gravelly ashy sandy loam F; H3 - 35 to 60 inches: gravelly sandy loam Properties and qualities 0 Slope: 2 to 8 percent El Depth to restrictive feature: 20 to 40 inches to densic material El Natural drainage class: Moderately well drained El Capacity of the most limiting layer to transmit water (Ksat): Very low to moderately low (0.00 to 0.06 in/hr) El Depth to water table: About 18 to 36 inches MI Frequency of flooding: None 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 14 updated May 2018 Frequency of ponding: None Available water storage in profile: Low (about 3.0 inches) Mukilteo Muck Typical profile R; H1 - 0 to 4 inches: muck El H2 - 4 to 35 inches: mucky peat El H3 - 35 to 54 inches: mucky peat ED H4 - 54 to 60 inches: fine sandy loam Properties and qualities El Slope: 0 to 1 percent ElDepth to restrictive feature: More than 80 inches El Natural drainage class: Very poorly drained El Capacity of the most limiting layer to transmit water (Ksat): Moderately high to high (0.57 to 1.98 in/hr) El Depth to water table: About 0 to 12 inches El Frequency of flooding: None E; Frequency of ponding: None s; Available water storage in profile: Very high (about 25.0 inches) 7219 Lake Ballinger Way, Edmonds Tax number: 00488800800101 page 15 updated May 2018