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DNS REVIEWED PLN RESUB7 BLD2020-0733+PLN_Response+2.8.2022_4.03.50_PM+2669630 (2)416 CITY OF EDMONDS PLAN REVIEW COMMENTS PLANNING DIVISION 425.771.0220 DATE: January 13, 2022 TO: Christopher Pichner; CHRISPICHNER@YAHOO.COM FROM: Michele Q. Szafran, Planner michele.szafran(@edmondswa.gov RE: Plan Check BLD2020-0733 8120 Talbot Rd. Retaining Walls On behalf of the Planning Division, I have reviewed the resubmittal on December 22, 2021, for the above referenced building permit application and have also taken into consideration the email response provided from Thomas McDonough dated January 6, 2022. Based on the email response provided, my comments below are made under the assumption that all retaining walls will be removed. Additional comments may follow once revised plans are submitted. Please respond to the following items: 1. Site Plan Site plan (Figure 6, attached) needs to expand the planting area to include the area of all the removed walls. These areas need to be restored with plantings consistent with the critical area consultant recommendations. The areas where the retaining walls were removed an additional 30 kinnikinnick plants were planted. Figure 6 is expanded and color coded to correspond to the planting plan zones. Show erosion control measures as recommended by the Geotech. Response taken from Geotech report dated January 26, 2022. The walls have been completely removed from the site, and the surface regraded to resemble previous natural slope grade. The removal has occurred during a persistent dry period of weather. No measurable rainfall has impacted the site during demolition. Replanting appears to have been completed, with new tree starters and vegetation cover having seeded and planted, with mulch over the majority of exposed surface sails • If trees are to be removed in the future the property owner must inquire with the city regarding tree removal permit requirements. No trees will be removed. 2. Critical Area Report Requirements: Include the area subject to the LLA as applicable. Stream Report: The restoration planting plan prepared by Alexander Callender dated December 21, 2020 must be expanded (see Figure 6 and pgs. 16-20 attached) to include the areas of the removed walls and the cost estimate must be updated as noted on page 19 of the stream report. An additional 30 kinnikinic plants will be added to the planting plan and positioned above zone 3 to provide ground cover for the area of the vacated retaining walls. The kinnikinic plants will be speced 2' apart to accommodate the average growth size of the plant to maximize the potential coverage needed. • Geotech Report: Provide an updated site plan to the Geotech regarding the full scope of work along with the required planting plan as noted above. Please have Geotech specifically address ECDC 23.80.060 and 23.80.070. The Geotech must also address wet season work. The report dated August 24, 2021, provided by Nelson GeotechnicaI Associates, Inc. (2" $, Pg. 6.) discusses the moisture -sensitive soils, the Geotech recommends that demo work take place during dry weather. If work is to be performed during the wet weather season, then the Geotech must address this. Quality Geo was provided an updated site plan, drafted by McDonough's Law Office on 01/13/2022. The removal has occurred during a persistent dry period of weather. No measurable rainfall has impacted the site during demolition. Geotech specifically address ECDC 23.80.060 and 23.80.070 and noted the following. Geotech specifically address ECDC 23.80.060 and 23.80.070 and noted the following. ECDC 23.80.060 23.80.060 Development standards — General requirements. Geotech performed general site reconnaissance to consider any indications of surface degradation or large-scale slope instability. No indications of deep-seated displacement were observed to cross within the slope or near to the residence. Topography was generally consistent and lacking: significantly over steepened areas, channelized runout zones, tension cracks, or hummocky zones. No obvious evidenceof rotational or translational failures or major toppling hazards was observed on the slopes in the proximity of the home. No significant failure features were observed onadjacent slope areas visible from the subject property during the visit. Review of available LiDAR imagery did not reveal any obvious historic or recent movement. B. Critical Facilities Prohibited. Critical facilities shall not be sited within geologically hazardous areas unless there is no other practical alternative. [Ord. 4026 § 1 (Att. A), 2016; Ord. 3527 § 2, 2004]. N/A 23.80.070 Development standards — Specific hazards. A. Erosion and Landslide Hazard Areas. Activities on sites containing erosion or landslide hazards shall meet the requirements of ECDC 23.80.060, Development standards -- General requirements,and the specific following requirements: 1. Minimum Building Setback. The minimum setback shall be the distance required to ensure the proposed structure will not be at risk from landslides for the life of the structure, considered to be 120 years, and will not cause an increased risk of landslides taking place on or off the site. A setback shall be established from all edges of landslide hazard areas. The size of the setback shall be determined by the director consistent with recommendations provided in the geotechnical report to eliminate or minimize the risk of property damage, death, or injury resulting from landslides caused in whole or part by the development, based upon review of and concurrence with a critical areas report prepared by a qualified professional; No new dwellings or structures are proposed, and original surface grades have been restored; therefore no setbacks will be encroached 2. Buffer Requirements. A buffer may be established with specific requirements and limitations, including but not limited to, drainage, grading, irrigation, and vegetation. Buffer requirements shall be determined by the director consistent with recommendations provided in the geotechnicaI report to eliminate or minimize the risk of property damage, death, or injury resulting from landslides caused in whole or part by activities within the buffer area, based upon review of and concurrence with a critical areas report prepared by a qualified professional; 3. Alterations. Alterations of an erosion or landslide hazard area, minimum building setback and/or buffer may only occur for activities for which a hazards analysis is submitted and certifies that: a. The alteration will not increase surface water discharge or sedimentation to adjacent properties beyond predevelopment conditions; b. The alteration will not decrease slope stability on adjacent properties; and C. Such alterations will not adversely impact other critical areas; Geotech does not anticipate any impacts on the slope, and surface stabilization is expected to exceed its original state 4. Design Standards within Erosion and Landslide Hazard Areas. Development within an erosion or landslide hazard area and/or buffer shall be designed to meet the following basic requirements unless it can be demonstrated that an alternative design that deviates from one or more of these standards provides greater long-term slope stability while meeting all other provisions of this title. The requirement for long-term slope stability shall exclude designs that require regular and periodic maintenance to maintain their level of function. The basic development design standards are: a. The proposed development shall not decrease the factor of safety for landslide occurrences below the limits of 1.5 for static conditions and 1.2 for dynamic conditions. If stability at the proposed development site is below these limits, the proposed development shall provide practicable approaches to reduce risk to human safety and improve the factor of safety for landsliding. In no case shall the existing factor of safety be reduced for the subject property or adjacent properties; b. Structures and improvements shall be clustered to avoid geologically hazardous areas and other critical areas; c. Structures and improvements shall minimize alterations to the natural contour of the slope, and foundations shall be tiered where possible to conform to existing topography; d. Structures and improvements shall be located to preserve the most critical portion of the site and its natural landforms and vegetation; e. The proposed development shall not result in greater risk or a need for increased buffers on neighboring properties; f. The use of retaining walls that allow the maintenance of existing natural slope area is preferred over graded artificial slopes; and g. Development shall be designed to minimize impervious lot coverage; Geotech indicated in his report that the proposed improvements are expected to increase the overall surface stability. 5. Vegetation Retention. Unless otherwise provided or as part of an approved alteration, removal of vegetation from an erosion or landslide hazard area or related buffer shall be prohibited; No vegetation to be removed 6. Seasonal Restriction. Clearing shall be allowed only from May 1st to October 1st of each year; provided, that the director may extend or shorten the dry season on a case -by -case basis depending on actual weather conditions, except that timber harvest, not including brush clearing or stump removal, may be allowed pursuant to an approved forest practice permit issued by the city of Edmonds or the Washington State Department of Natural Resources; N/A No clearing or removal 7. Point Discharges. Point discharges from surface water facilities and roof drains onto or upstream from an erosion or landslide hazard area shall be prohibited except as follows: a. Conveyed via continuous storm pipe downslope to a point where there are no erosion hazard areas downstream from the discharge; b. Discharged at flow durations matching predeveloped conditions, with adequate energy dissipation, into existing channels that previously conveyed storm water runoff in the predeveloped state; or c. Dispersed discharge upslope of the steep slope onto a low -gradient, undisturbed buffer demonstrated to be adequate to infiltrate all surface and storm water runoff, and where it can be demonstrated that such discharge will not increase the saturation of the slope; and Geotech report on Erosion Controls & Wet Weather Work: Walls have been removed, and planting plan completed at this time. Work was completed during consistently dry weather, successfully avoiding erosional concerns. While no further work is anticipated, if additional restoration or work is to be done in the future for upkeep, we recommend the following be considered by the property owner at such time: 8. Prohibited Development. On -site sewage disposal systems, including drain fields, shall be prohibited within erosion and landslide hazard areas and related buffers. N/A Pichner Deck and Wall Installation Critical Area and Fabitat Management Plan LANDSERVICES NIJ 120 STATE AVE NE #190QLYMPIA, IJA 98501 zt�r;E F1171--, -- — 16 Land Services Northwest December 15, 2020 Picnner Deck and Wall Installation Critical Area and Habitat Management Plan FIGURE 6 SITE PLAN IJITH PLANTINGZONES <NOT A SURVEY) Land Services Northwest 17 December 15, 2020 Pichner Deck and Wall Installation Critical Area and Habitat Management Plan nstalled downslope from any disturbed earth and all earth disturbance will be limited to the minimum necessary to achieve the purpose. No equipment or debris will be stored in the buffer. Stormwater from the home and nearby impervious surfaces will be directed away from the area until the vegetation has established. The bare slope will be mulched with 4 inches of mulch as soon as possible to prevent erosion. The work will be done when the danger of turbid discharge to the stream is minimized in the late spring. The slopes will be watered as needed to promote vegetation growth, but not so much that it will cause erosion. All plant installations will be done by hand to minimize the potential for erosion. Mulch will be applied four inches thick in order to improve moisture retention and reduce erosion. The planting plan was conducted by hand with hand tools (shovels, trowles, rakes, ect... ) with minimal foot traffic to minimize the impact on the stabilization of the critical area. Additionally, an extra 30 kinnikinick plants were integrated into the planting plan to cover the areas of the vacated retaining walls to bolster the stability of the slope above zone 3 of the planting plan Fig 6. 8.0 MITIGATION PLAN 8.1 Impacts The project will mitigate for the unavoidable impacts to 1,452 square feet of r parian habitat through the removal of invasive species such as English ivy and Himalayan frlackberry and replanting of 3,812 square feet with a robust combination of groundcover, shrubs and trees. These plants will lead to an improvement of functions and diversity ove- the existing conditions. A net gain or positive impact is expected in landscape roughness, habitat screening, food source, nutrient uptake and aesthetics and overall habitat resilience (Figure 5). See olanting plan 8.2 Mitigation Objectives We will mitigate for the removal of vegetation and the installation of lawn, steps and walls by providing a revegetation plan that will meet the projects objectives to: a. Improve habitat as a food source and screening for wildlife b. Prevent erosion c. Discourage intrusion/degradation of the buffer d. Provide aesthetic benefits for the residents in the viewshed of the projec_ e. Stem the intrusion of invasive species a 8.3 Buffer Mitigation Functions If the buffer enhancement performs as expected, we canexpect the following lift in functions. The semi quantitative method used in the Wetland Rating System (ECY, 2014) was adapted as the resolution of performance lift is only valid to the semi quantitative Low, Medium, and High Table 1 - Buffer Functions Comparison Before and After Mitigation Land Semites Northwest 18 December 15, 2020 lluiicA rcu criteria acreenmg'-""grient Snags Other Structure uptake and Habitat Los FeaturesBefore 7Medium mitigatingmeasures LOW Meidum Low Medium Medium 7allenualin f1er mitigating High High Low Medium HighHigh measures Land Services Northwest 19 December 15, 2020 Pichrer Deck and Wall Installation Critical Area and Habitat Management Plan 8.4 Planting plan The planting plan is provided. Trees will be planted at grade in holes 1-2 =imes the width of the container or root ball. The mulch will be applied around each tree 2-4 inches deep in a two -foot diameter around the tree with an edge to retain water. Rootbound trees will be cut with sharp shears on the bottom in an x pattern to promote root growth. Four cuts will be madte vertically to allow roots to spread. Trees will be thoroughly watered in after installation. Shrl-bs will be installed in a similar manner. The species selected are typical native northwest species that usually survive our summers; however, it may be necessary to irrigate during the first two years to ensure survival. The watering will be the minimal necessary to avoid creating erosion. All retaining walls will be planted with kinnikinic to provide screening from the walls. The first 15 feet along the creek will be planted with shrubs like Red osier dogwood, Pacific ninebark and Twinberry to provide erosion protection and structure over the creek which will provide allochthonous inputs like macroinvertebrates for the fish below. The second thirty feet will be primarily trees like Sitka spruce, Western hem ock and Western red cedar and Red flowering currant to provide shade that will attenuate temperatures and eventually shade out the invasive species that have become prevalent in the area. The remaining area near the wails will be planted with groundcover (Salal and Roses) for erosion protection. Land Services (Northwest 20 December 15, 2020 Pichrer Deck and Wall Installation Critical Area and Habitat Management Plan Table 2 Tree/Shrub Species Quantity and Spacing (3,812 sq ft) on rn EHemlock Scientific Name Tsuga heterophyfla Spacing 15 ft Zone 2 Quantity 5 Cost per unit $5.04 Total $25.00 Western reef cedar Thuja plicata 15 ft 2 5 $5.00 $25.00 Sitka spruce sicea sitchensis 15 ft 2 5 $20 40 $140 00 Clustered rose Nootka rose Red flowering Rosa pisocarpa Rosa nutkana Ribes sanguineum 5 ft 5 ft loft 3 3 2 5 5 10 $5.00 $5 04 $10.00 $25.00 $25 00 $100.00 current Red osier dogrrvood Cornus alba 5 ft 20 5 $5.00 $100. 00 Pacific Nine bark Physocarpa capitatus 5 ft 10 5 $5.00 $25.00 Twinoerry Lonicera involucrata 5 ft 1 5 $5.00 $25.00 kinnikinnick Arctostaphylos uva-ursi 2 ft Walls+ 20 $4.00 $80 40 Sal al Goutheria shallon 2 ft 3 20 $2.00 $40.40 Table 3 Total Costs 8.4 Performance Standards and Monitoring The site will be monitored for five years with the as -built as Year 0. Photo points will be established in 2 points that capture the overall condition of the planting area. Monitoring will begin in the spring following the installation of the plants. Year 1 will requi-e 100 percent survival. Year 2 must have 100 percent survival of planted native plants Years 3-5 will have Land Services Northwest 19 December 15, 2020 Pichrer Deck and wall Installation Critical Area and Habitat Management Plan an 80% survival rate, if the survival rate is not met in the final year, the deficit will be replanted, and the site will be monitored for 1 more year. The survival percentage will include 10 percent of a-iy native non-invasive volunteers. Monitoring will occur each spring after the plants have sprouted leaves. Management will require prior removal of any blackberries, scotch broom or holly or other invasive plants in the planting area and replacement of any dead plants as reg4ired to meet the performance standards. A report of management actions and photos of the area will go to the City of Edmonds Development Center within a month following each site monitoring event. The invasive removal area will be monitored as well. The invasive removal area will have any non-native blackberries grubbed out. Holly will be cut down and any other invasives encountered will be removed by hand. A bond will be put in place to account for 15% of the cost of plant installation which with the added 30 kinnikinnick plants come to a total of $700.00. Making the cost of the 15% bond at $ 10 .00 9.0 CONTINGENCIES The City will be consulted on any contingency measures that are developed. The report willbe in an email by the applicant and will include pictures that illustrate the condition of the mitigation site. Contingency/maintenance activities may include, but are not limited to. 1. Replacing plants lost to vandalism, drought, or disease, as necessary; 2. Irrigating the enhancement areas only as necessary during dry weather if plants appearto be too dry, with a minimal quantity of water; 3. Remulching areas to protect from dry weather 4. Providing protection from rodents 10.0 CONCLUSIONS Development activities accidently occurred in the riparian buffer when the applicant installedhis steps, retaining walls and other landscape amenities. A geotechnical report has shown that these structures can safely remain without destabilizing the slopes and causing damage to the property. The applicant has carefully considered the best options forrevegetaling the slopes with vegetation that is appropriate for limiting erosion and adding stability to the slope. This restoration will provide benefits to the area in many different ways but most importantly, it will maintain the functions and values of the stream for the citizens of Edmond. Land Services Northwest 20 December 15, 2020