Attachment 22 - Wetlands ReportRECEIVED
Dec 28 2020
CITY OF EDMONDS
DEVELOPMENT SERVICES
DEPARTMENT
WETLANDS' WILDLIFE
Environmental Consulting
CRITICAL AREAS RECONNAISSANCE REPORT
POINT EDWARDS HOA
INCORPORATED CITY OF EDMONDS, WASHINGTON
PREPARED FOR:
Point Edwards Homeowners Association
Attn: Bel Johnson
93 Pine Street
Edmonds, WA 98020
PRFPARFn RY'
Wetlands & Wildlife, Inc.
7721-153rd Street SE
Snohomish, Washington 98296
(425) 337-6450
November 10, 2014
Attachment 22
TABLE OF CONTENTS
INTRODUCTION AND BRIEF SITE DESCRIPTION
STATEMENT OF QUALIFICATIONS TO CONDUCT THIS CRITICAL AREAS EVALUATION
METHODOLOGIES OF CRITICAL AREAS EVALUATION
RESULTS AND FINDINGS OF CRITICAL AREAS EVALUATION
CRITICAL AREAS IMPACT DETERMINATION
LIMITATIONS AND USE OF THIS REPORT
REFERENCES AND LITERATURE REVIEWED
2
3
4
5
6
Attachment 22
INTRODUCTION AND BRIEF SITE DESCRIPTION
Wetlands & Wildlife, Inc. conducted a Critical Areas reconnaissance site visit on the Point Edwards
condominiums property. For reference, the maintenance office location is located at 93 Pine Street,
situated within the incorporated city of Edmonds, Washington. The site is currently developed as a large
condominium complex, primarily comprised of developed areas and associated maintained lawns and
landscaped areas.
Wetlands & Wildlife, Inc. was retained to conduct an evaluation of the subject property in relation to the City
of Edmonds Critical Areas Regulations outlined in Chapters 23.50 (Wetlands) and 23.90 (Wetlands and Fish &
Wildlife Habitat Conservation Areas) of the Edmonds Community Development Code (ECDC). Wetlands &
Wildlife, Inc. conducted a site visit to the property on October 17, 2014 for the purpose of conducting a
Critical Areas reconnaissance of the property, pursuant to ecological professional industry standards and
City of Edmonds requirements and standards. Specifically, Wetlands & Wildlife, Inc. was retained to
determine if any wetlands, streams, or associated protective buffer areas regulated by the ECDC exist on
the property. In addition to assessing the northern portion of the Point Edwards property, Wetlands &
Wildlife, Inc. also visually assessed the surrounding properties within approximately 200 feet to the north of
the property to the extent feasible without accessing adjacent properties due to a lack of legal access.
Please review the RESULTS AND FINDINGS OF CRITICAL AREAS EVALUATION section of this report for further
information.
STATEMENT OF QUALIFICATIONS TO CONDUCT THIS CRITICAL AREAS EVALUATION
The following provides a brief overview of my experience and credentials to conduct this Critical Areas
evaluation. I am the Founder, Owner, and Principal Wetland and Wildlife Ecologist of Wetlands & Wildlife,
Inc. I attended the University of Montana where I graduated cum laude with a degree in Wildlife Biology.
As of 2014, 1 have 13 years of direct experience as a professional Biologist/Ecologist in western
Washington and 17 years of overall experience completing natural resource assessments among many
different ecosystems across the western United States. I have worked as a professional Biologist/Ecologist
for federal, state, and county environmental agencies, as well as several private environmental consulting
firms with specialties in wetlands, streams, rivers, lakes, and wildlife habitat. In my 17 years of experience,
I have specialized in review of proposed land use and building development permit applications as they
pertain to Critical Areas (wetlands, rivers, streams, lakes, and habitats of protected fish and wildlife
species). Much of that experience came as a Senior Reviewing Ecologist for King County DDES and a
Regulatory Biologist for Snohomish County PDS.
I am listed on several Preferred / Qualified Consultant Rosters throughout western Washington. I am highly
experienced with the required U.S. Army Corps of Engineers and Washington state wetland delineation
methods. In addition to the wetland delineation certification, I am trained by the Washington Department of
Ecology and have 9 years of experience in the use of the required Wetland Rating Form for western
Washington. I am trained by the Washington Department of Ecology to determine Ordinary High Water
Mark (OHWM) locations for rivers, streams, and lakes. In addition to my expertise related to wetlands and
streams, I have many years of experience conducting surveys of special status wildlife species in the
Wetlands & Wildlife, Inc.
Critical Areas Reconnaissance Report
Point Edwards HOA (City of Edmonds, WA)
November 10, 2014
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western U.S. I received certifications from the Washington Department of Fish and Wildlife for terrestrial
wildlife habitat assessments and wildlife surveys of special status wildlife species in Washington.
Over the past 17 years, I have conducted literally over 1,300 biological I ecological assessments in different
capacities on properties with many habitat types and zoning designations, from small, urban properties
(0.25 acres) to large, rural properties (up to 2,000 acres in size). I have been selected by several local city
agencies to provide on -call 3rd-party environmental reviews of proposed projects for compliance with local
Critical Areas Ordinances and the FEMA Floodplain Habitat Assessment requirements.
METHODOLOGIES OF CRITICAL AREAS EVALUATION
Wetlands & Wildlife, Inc. used methodologies described in Determining the Ordinary High Water Mark on
Streams in Washington State (Washington Department of Ecology Publication #08-006-001, April 2008) to
make a determination regarding the Ordinary High Water Marks (OHWM) located on the subject site.
Wetlands & Wildlife, Inc. used the routine methodologies described in the Washington State Wetlands
Identification and Delineation Manual (Washington State Department of Ecology Publication #96-94, March
1997) to make a determination regarding the presence of any regulated wetlands. In addition, Wetlands &
Wildlife, Inc. evaluated the site using the U.S. Army Corps of Engineers Wetland Delineation Manual produced
in 1987 and the U.S. Army Corps of Engineers Regional Supplement to the Corps of Engineers Wetland
Delineation Manual: Western Mountains, Valleys, and Coast Region produced in May 2010 (hereinafter
referred to as the "Regional Supplement"). The Regional Supplement is designed for concurrent use with the
1987 Corps Wetland Delineation Manual and all subsequent versions. The Regional Supplement provides
technical guidance and procedures for identifying and delineating wetlands that may be subject to regulatory
jurisdiction under Section 404 of the Clean Water Act. Where differences in the two documents occur, this
Regional Supplement takes precedence over the Corps Manual for applications in the Western Mountains,
Valleys, and Coast Region.
According to the federal and state methodologies described above, identification of wetlands is based on a
three -factor approach involving indicators of hydrophytic vegetation, hydric soils, and presence or evidence
of persistent hydrology. Except where noted in the manuals, the three -factor approach discussed above
requires positive indicators of hydrophytic vegetation, hydric soils, and wetland hydrology to make a
determination that an area is a regulated wetland. Using the aforementioned manuals, the site
characteristics for making a wetland determination include the following:
1.) Examination of the site for hydrophytic vegetation (species present/percent cover);
2.) Examination for the presence of hydric soils in areas where hydrophytic vegetation is present; and
3.) Examination to determine if adequate hydrology exists for sufficient durations during the early part of the
growing season in the same locations as the previous two steps.
Per industry standards, Wetlands & Wildlife, Inc. examined the areas of interest identified by Ms. Bel
Johnson, Point Edwards Landscape Manager. Per industry standards and City requirements, Wetlands &
Wildlife, Inc. also assessed the nearby properties adjacent to the project site's northern boundary, to the
Wetlands & Wildlife, Inc. November 10, 2014
Critical Areas Reconnaissance Report
Point Edwards HOA (City of Edmonds, WA) Page 2
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maximum extent possible without entering adjacent properties. While a detailed assessment of Critical
Areas on adjacent properties was not possible due to lack of legal access, Wetlands & Wildlife, Inc.
conducted a review of all readily available information to assess the presence of off -site Critical Areas in
close proximity to the subject site. The evaluation of adjacent properties is necessary to determine if any
regulated Critical Areas exist off -site which would cause associated protective buffers to extend onto the
property and potentially affect a development proposal on the subject property.
In addition to on -site field reviews, Wetlands & Wildlife, Inc. examined aerial photographs and topographical
data (elevation contours) on Snohomish County's Snoscape system. National Wetlands Inventory (NWI)
maps produced by the U.S. Fish and Wildlife Service (USFWS), SalmonScape fish distribution maps
produced by the Washington Department of Fish and Wildlife (WDFW), StreamNet fish distribution maps
produced by Pacific States Marine Fisheries Commission, and Priority Habitats and Species (PHS) maps
produced by the Washington Department of Fish and Wildlife (WDFW) were also evaluated as part of our
consultation and evaluation of the subject property.
RESULTS AND FINDINGS OF CRITICAL AREAS EVALUATION
No regulated wetlands, streams, fish and wildlife habitats of importance, or associated protective buffer
areas were located on the subject property. However, Wetlands & Wildlife, Inc. did locate a few areas that
appear to meet wetland parameters which were unintentionally created from previously non -wetland areas.
As part of our consultation, Wetlands & Wildlife, Inc. examined State Environmental Policy Act (SEPA)
documents that were submitted to the City of Edmonds for review in 2003 and 2005. These SEPA
documents were submitted to the City in conjunction with the proposed Point Edwards condominium
development. Section 3.a.(1) of the submitted 2003 SEPA checklist states clearly that no regulated
wetlands were located on -site prior to development of the condominiums, and the 2005 SEPA document
submitted to the City as part of the Point Edwards proposal referred to the 2003 SEPA document as well.
The City of Edmonds approved the Point Edwards project in part based on those SEPA documents,
thereby agreeing with the project proponents that no regulated surface waters existed on -site prior to the
development of the site with the Point Edwards condominiums. In addition, it is in our professional opinion
that the non -regulated areas which currently display some wetland parameters were unintentionally created
due to their landscape position in relation to the unlined detention pond and the off -site asphalt driveways
along the northern property line. All of the areas that currently display wetland characteristics are located
down -gradient from the artificially constructed detention pond, and the water from the detention pond likely
leaks from the detention pond, travel subsurface, and then re -surface in the locations that are currently
displaying some wetland characteristics. In addition, one of the non -regulated areas that currently displays
wetland characteristics is located immediately adjacent to (south of) an asphalt road/driveway area on the
Unocal property to the north of the Point Edwards property. The Washington State Wetlands Delineation
Manual (1997) states that "Wetlands do not include those artificial wetlands intentionally created from non -
wetland 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." Based on the information gathered and reviewed for this project, it is apparent that no
regulated wetlands are located on the subject property, and that all areas which may currently display
Wetlands & Wildlife, Inc.
Critical Areas Reconnaissance Report
Point Edwards HOA (City of Edmonds, WA)
November 10, 2014
Page 3
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wetland characteristics were unintentionally created by the construction of the detention pond and/or the
asphalt driveway/road along the northern property line. The SEPA documents which were submitted to the
City of Edmonds in 2003 and 2005 (and subsequently approved by the City of Edmonds) provide strong
evidence that no regulated wetlands are located on the property.
While no regulated wetlands or streams were located on the project site, there are regulated wetlands and
streams located north of the Point Edwards property on Snohomish County tax parcel 27032300409400.
The off -site wetland is Edmonds Marsh, and Edmonds Marsh appears to be located approximately 220 feet
from the nearest potential project location. Wetlands & Wildlife, Inc. did not have access to the property
which contains Edmonds Marsh in order to accurately rate the wetland using the Revised Wetland Rating
Form for Western Washington. However, pursuant to section 23.50.040.F.1 of the ECDC, the largest
potential wetland buffer width (associated with a Category I wetland) in the City of Edmonds jurisdiction
equals 200 feet, measured from the wetland boundary. Therefore, it appears that the buffer from the off -
site Edmonds Marsh would not extend into the future proposed project area because Edmonds Marsh
appears to be farther than 200 feet from the any future project area.
Snohomish County's SnoScape map system, StreamNet, SalmonScape and WDFW PHS maps depict two
fish -bearing streams being located to the north of the Point Edwards property (on Unocal property). Both
of these streams are mapped as Shorelines of the State (Type S streams) on Snohomish County's
SnoScape map. Based on map research, Willow Creek is the stream which is closest in proximity to the
Point Edwards property, and Willow Creek appears to be located approximately 280 feet to the north /
northeast of the potential project area at its closest location. Pursuant to the Edmonds City Code and
Community Development Code (Chapter 23.90), Type S streams require a standard buffer width of 150
feet, measured from the Ordinary High Water Mark (OHWM) of the stream. Therefore, the buffer
associated with the off -site Type S stream (Willow Creek) would not extend into the project area.
CRITICAL AREAS IMPACT DETERMINATION
Based on the information discussed above, it is the professional opinion of Wetlands & Wildlife, Inc. that no
regulated wetlands, streams, or associated buffers are located on the Point Edwards property. This
determination is a result of detailed review of the previously approved SEPA documents associated with
the property, review of the City of Edmonds' current Critical Areas Regulations, and review of several
publicly available map systems and online resources. Based on our determination that no regulated
wetlands, streams, or buffers are located on the project site, it is our professional opinion that no adverse
environmental impacts will occur to any such regulated Critical Areas or associated protective buffer areas
as a result of any future project activity on the subject parcel. However, we do recommend that temporary
erosion and sediment control best management practices (TESC BMP's) are installed north of any
proposed project activity on the Point Edwards property in order to ensure that no sediment is able to travel
north from the site toward the off -site wetland and streams.
Wetlands & Wildlife, Inc.
Critical Areas Reconnaissance Report
Point Edwards HOA (City of Edmonds, WA)
November 10, 2014
Page 4
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LIMITATIONS AND USE OF THIS REPORT
This Critical Areas Reconnaissance Report is supplied to Bel Johnson at Point Edwards Owners
Association as a means of determining whether any wetlands, streams, and/or wildlife habitat conservation
areas regulated by the Edmonds Community Development Code exist on the site or within close proximity
of the site which would affect any future permit requirements or future proposed activities on the site. This
report is intended to provide information deemed relevant in the applicant's attempt to comply with the
regulations currently in effect. Please note that Wetlands & Wildlife, Inc. did not have legal access to
traverse adjacent properties and determine the extent, location, and classification of Critical Areas on
adjacent properties.
The work for this report has conformed to the standard of care employed by professional ecologists in the
Puget Sound region. No other representation or warranty is made concerning the work or this report. This
report is based largely on readily observable conditions and, to a lesser extent, on readily ascertainable
conditions. No attempt has been made to determine hidden or concealed conditions. If such conditions
arise, the information contained in this report may change based upon those conditions. Please note that
Wetlands & Wildlife, Inc. did not provide detailed analysis of other permitting requirements not discussed in
this report (i.e. structural, drainage, geotechnical, or engineering requirements).
The laws applicable to Critical Areas are subject to varying interpretations. While Wetlands & Wildlife, Inc.
upheld professional industry standards when completing this review, the information included in this report
does not guarantee approval by any federal, state, and/or local permitting agencies. Therefore, the work
associated with this proposal shall not commence until permits have been obtained from all applicable
agencies.
If any questions arise regarding this review, please contact me directly at (425) 337-6450.
Wetlands & Wildlife, Inc.
Scott Spooner
Owner / Principal Wetland & Wildlife Ecologist
Wetlands & Wildlife, Inc.
Critical Areas Reconnaissance Report
Point Edwards HOA (City of Edmonds, WA)
November 10, 2014
Page 5
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REFERENCES AND LITERATURE REVIEWED
Cowardin, et al, 1979. Classification of Wetlands and Deepwater Habitats of the United States. U.S.D.I.
Fish and Wildlife Service. FWS/OBS-79/31. December 1979.
Environmental Laboratory. (1987). "Corps of Engineers Wetlands Delineation Manual," Technical Report Y-
87-1, U.S. Army Engineer Waterways Experiment Station, Vicksburg, Miss.
Hruby, T. 2004. Washington State wetland rating system for western Washington — Revised. Washington
State Department of Ecology Publication # 04-06-025.
PHS on the Web. Web -based interactive map administered by the Washington Department of Fish and
Wildlife. http://wdfw.wa.gov/mapping/phs/. Website last visited for this project on November 3, 2014.
SalmonScape. Interactive Mapping website administered by the Washington Department of Fish and
Wildlife. http://wdfw.wa.gov/mapping/salmonscape/index.html. Website last visited for this project on
November 3, 2014.
Snohomish County Landscape Imaging Interactive Map (SnoScape). Snohomish County GIS Center in
conjunction with Snohomish County Planning and Development Services.
http://gis.snoco.org/maps/snoscape/index.htm. Website last visited for this project on November 3, 2014.
Edmonds City Code and Community Development Code. Chapters 23.90 (Wetlands and Fish & Wildlife
Habitat Conservation Areas) and 23.50 (Wetlands). City of Edmonds, Washington.
StreamNet. Fish Data for the Northwest. Administered by the Pacific States Marine Fisheries Commission.
http://www.streamnet.org/. Website last visited on November 3, 2014.
U.S. Army Corps of Engineers (2010). "Regional Supplement to
Delineation Manual: Western Mountains, Valleys, and Coast Region
U.S. Army Engineer Research and Development Center, Vicksburg, MS
U.S. Fish and Wildlife Service. National Wetlands
http://107.20.228.18/Wetlands/WetlandsMapper.html#.
the Corps of Engineers Wetland
(Version 2.0)," ERDC/EL TR-10-3,
Inventory Wetlands Mapper.
Washington State Wetlands Identification and Delineation Manual. Washington State Department of
Ecology. Publication #96-94. March 1997.
Wetlands & Wildlife, Inc.
Critical Areas Reconnaissance Report
Point Edwards HOA (City of Edmonds, WA)
November 10, 2014
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