REVIEWED PLN RESUB1 BLD2023-1148+CRITICAL AREA REPORT+12.18.2023_9.01.59_AM+3957505Reviewed by '
City of Edmonds
Planning Division
--------------'
RESUB
Dec 18 2023
CITY OF EDMONDS
DEVELOPMENT SERVICES
DEPARTMENT
:IIbyzIY491i§EE:3
WETLANDS�WIEDLIFE
Environmental Consulting
CRITICAL AREAS SITE ASSESSMENT REPORT
MCCALL PROPERTY --PROPOSED DECK REPLACEMENT
INCORPORATED CITY OF EDMONDS (PARCEL #00373600100306)
PREPARED FOR:
Burgess Construction, LLC
Attn: Nicole Hewlett, Operations Manager
8327 1641" Street SE
Snohomish, WA 98296
PRFPARFII RV'
Wetlands & Wildlife, Inc.
19410--179th Court NE
Woodinville, WA 98077
(425) 337-6450
Report Date: November 18, 2023
TABLE OF CONTENTS
INTRODUCTION AND BRIEF SITE DESCRIPTION
STATEMENT OF QUALIFICATIONS TO CONDUCT THIS CRITICAL AREAS EVALUATION
BRIEF PROJECT DESCRIPTION AND DISCUSSION REGARDING CITY COMMENT LETTER 2
METHODOLOGIES OF CRITICAL AREAS EVALUATIONS 2
RESULTS AND FINDINGS OF CRITICAL AREAS EVALUATIONS 3
PROJECT'S IMPACT DETERMINATION RELATED TO CRITICAL AREAS 5
LIMITATIONS AND USE OF THIS REPORT 5
REFERENCES AND LITERATURE REVIEWED 7
INTRODUCTION AND BRIEF SITE DESCRIPTION
The subject property is located within the incorporated City of Edmonds, Washington. The address for the
proposed project site is 20918 80t" Avenue W and the tax parcel number for the property follows:
00373600100306. Per the Snohomish County Assessor's office, the property encompasses approximately
0.27 acres and is currently owned by Adam McCall. The property currently contains an existing single-family
residence, a gravel driveway, concrete sidewalk, deck, and other associated infrastructure normal to single-
family residential development in the region.
Burgess Construction, LLC retained Wetlands & Wildlife, Inc. to evaluate the site features and proposed
project described in this report for compliance with the Edmonds Municipal Code (EMC) Title 23, Natural
Resources. Wetlands & Wildlife, Inc. conducted a site visit to the property on November 2, 2023 to conduct
detailed Critical Areas evaluations on the project site, pursuant to the EMC and professional ecological
industry standards. This report is intended to outline how the project proposal adheres to the requirements
outlined in EMC Title 23 related to regulated Critical Areas.
STATEMENT OF QUALIFICATIONS TO CONDUCT THIS CRITICAL AREAS EVALUATION
Per requirements outlined in the Edmonds Municipal Code (EMC), Title 23 (Natural Resources), a qualified
professional is required to perform Critical Areas evaluations and write accompanying reports for submittal.
Therefore, the following provides a brief overview of my experience and credentials to conduct the required
detailed Critical Areas evaluations on the subject property. 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 Iaude with a degree in Wildlife Biology. As of 2023,1 have 22 years of direct experience as a professional
Biologist / Ecologist in western Washington and 26 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 26 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). I gained some of that experience working as a Senior Reviewing
Ecologist for King County DDES and a Regulatory Biologist for Snohomish County PDS, while I also have
many years of experience as a private environmental consultant.
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 18 years of experience in the use of the required Wetland Rating Form for western
Washington (since its inception). 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 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.
Wetlands & Wildlife, Inc. November 18, 2023
Critical Areas Site Assessment Report —Burgess Construction, LLC (McCall Deck Replacement)
Incorporated City of Edmonds, Washington (Tax Parcel #00373600100306) Page 1
I have conducted over 2,300 biological / 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 jurisdictions to provide on -
call 3rd-party environmental reviews of proposed development projects for compliance with local Critical
Areas Ordinances and the FEMA Floodplain Habitat Assessment and Mitigation document.
BRIEF PROJECT DESCRIPTION AND DISCUSSION REGARDING CITY COMMENT LETTER
Burgess Construction, LLC submitted a permit application to the City of Edmonds related to the proposed
project. The property owner is proposing to demolish the existing deck on the subject property and construct
a replacement deck that encompasses approximately 84 square feet. The proposed replacement deck will
be constructed on top of areas that currently contain a deck and are located on top of existing gravel.
Therefore, the location where the proposed replacement deck will be located does not provide valuable
ecological functions to the surrounding area. The City of Edmonds provided a letter to the project team dated
September 29, 2023. In the City of Edmonds' letter dated September 29, 2023, the City of Edmonds informed
the applicant of the requirement to conduct a Critical Areas Determination related to a mapped wetland that
is located east of the subject property. For reference, the City's associated Critical Areas Determination
number follows: CRA2023-0148.
Based on our project -specific and site -specific ecological assessments, there is a mapped wetland located
east of the subject property. However, based on our assessments, it is apparent that the location and extent
of the mapped wetland depicted in the "Wetlands" layer on the City of Edmonds GIS Map is inaccurate.
Furthermore, an existing public asphalt roadway (80th Avenue W) is located between the proposed deck
replacement project and the potential off -site wetland, and the existing roadway creates an effective break of
ecological functions located between the proposed deck replacement and the potential off -site wetland.
Please see the RESULTS AND FINDINGS OF CRITICAL AREAS EVALUATIONS section of this report for more
information regarding our findings. Therefore, the proposed deck replacement will not have any adverse
impacts on regulated Critical Areas or associated protective buffers.
METHODOLOGIES OF CRITICAL AREAS EVALUATIONS
The routine methodologies described in the Washington State Wetlands Identification and Delineation
Manual (Washington State Department of Ecology Publication #04-06-029, October 2014) were used to
make a determination regarding the presence of any regulated wetlands, as required by the City of Edmonds.
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. ArmV 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 Corps Regional Supplement"). The Corps Regional Supplement
is designed for concurrent use with the 1987 Corps Wetland Delineation Manual and all subsequent versions.
The 2010 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.
Wetlands & Wildlife, Inc. November 18, 2023
Critical Areas Site Assessment Report —Burgess Construction, LLC (McCall Deck Replacement)
Incorporated City of Edmonds, Washington (Tax Parcel #00373600100306) Page 2
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 I 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 professional ecological industry standards, Wetlands & Wildlife, Inc. examined the entire subject site to
determine if any regulated Critical Areas are located on the property. Wetlands & Wildlife, Inc. also visually
assessed adjacent properties within approximately 300 feet of the proposed project limits, to the maximum
extent possible without entering adjacent private properties. While a detailed assessment of Critical Areas
on adjacent private properties was not possible due to lack of legal site access onto private properties,
Wetlands & Wildlife, Inc. conducted a review of all available information to assess the potential presence of
off -site Critical Areas within 300 feet of the subject site. This evaluation is necessary to determine if any
regulated Critical Areas exist off -site which would cause associated protective buffers to extend onto the
property and affect the development proposal. Wetlands & Wildlife, Inc. also used a laser rangefinder to take
distance measurements while standing on the subject property to aid in our findings described in this report.
In addition to on -site field evaluations, Wetlands & Wildlife, Inc. examined aerial photographs and
topographical data (elevation contours) on Snohomish County's PDS Map Portal map system and the City
of Edmonds GIS Map. Soil survey maps produced by the Natural Resources Conservation Service (NRCS),
National Wetlands Inventory (NWI) maps produced by the U.S. Fish and Wildlife Service (USFWS), Priority
Habitats and Species (PHS) maps produced by the Washington Department of Fish and Wildlife (WDFW),
and fish distribution maps produced by the WDFW (SalmonScape), Pacific States Marine Fisheries
Commission (StreamNet) and Washington Department of Natural Resources (DNR; Forest Practices
Application Mapping Tool [FPAMT]), and the City of Edmonds GIS data and maps were also evaluated as
part of this project review.
Please see the RESULTS AND FINDINGS OF CRITICAL AREAS EVALUATIONS section of this report for Information
regarding our findings.
RESULTS AND FINDINGS OF CRITICAL AREAS EVALUATIONS
Based on our detailed evaluations of the project site and among the vicinity of the project site, no regulated
Critical Areas are located on the subject property. However, an off -site wetland is mapped as being located
off -site to the east of the subject property. No other Critical Areas are located near the subject site that would
potentially affect the proposed development described in this report.
Wetlands & Wildlife, Inc. November 18, 2023
Critical Areas Site Assessment Report —Burgess Construction, LLC (McCall Deck Replacement)
Incorporated City of Edmonds, Washington (Tax Parcel #00373600100306) Page 3
As previously described in this report, an off -site wetland is mapped as being located east of the proposed
project site. The mapped wetland is located east of 801h Avenue W, and east of the nearest properties with
the following addresses: 20901 80th Avenue W, 20909 80th Avenue W, and 20921 80th Avenue W. These
properties are located east of the proposed project site on the east side of 80th Avenue W.
Based on our detailed evaluations, the extent and location of the wetland as depicted on the City of Edmonds
GIS Map is inaccurate. The City of Edmonds GIS Map depicts the western wetland boundary extending west
all the way to the east side of the house with the address of 20901 80th Avenue W. However, the wetland is
actually farther east than what the City of Edmonds GIS Map indicates. Based on our site evaluations, the
wetland is likely more accurately mapped on the Snohomish County PDS Map Portal. The Snohomish
County PDS Map Portal depicts the western boundary of the wetland being approximately 260 feet away
from the proposed replacement deck (at the closest location). While we were on -site conducting evaluations,
we assessed the tree species in the vicinity of where the wetland is mapped on the City of Edmonds GIS
Map. The dominant trees located east of the house on the property with an address of 20901 80th Avenue
W and east of the house on the property with an address of 20909 801h Avenue W are Douglas fir
(Pseudotsuga menziesii) and big -leaf maple (Acer macrophyllum) trees. Both of those tree species have a
wetland indicator status of Facultative Upland (FacU) in the Western Mountains, Valleys, and Coasts
(WMVC) Region, meaning that those tree species do not typically grow in wetland environments and are not
typically able to tolerate soils with prolonged saturation or inundation within the root zone. The maturity / age
of these trees indicates that the areas immediately east of those houses are not likely wetland areas. The
rangefinder measurements taken while on -site indicate those Douglas fir and big -leaf maples trees extend at
least 249 feet east of the proposed replacement deck, so it appears likely that the approximate wetland extent
as mapped on Snohomish County's PDS Map Portal (approximately 260 feet from the proposed project area)
is much more accurate than the approximate wetland depicted on the City of Edmonds GIS Map.
Per EMC sections 23.50.030.E and 23.50.0301, project applicants are required to assess the entire
proposed project area and all other areas within 200 feet of the project area for the potential presence of
regulated wetlands. As noted above, the off -site wetland to the east is located more than 200 feet from the
proposed project area, so a detailed Critical Areas Report is not required for this project. Furthermore, the
subject wetland would likely have a standard buffer width of significantly less than 200 feet if a Wetland Rating
Form was required to be completed for this proposed project (due to the landscape context of the wetland
area and the proposed project being located among an area which would preclude the wetland from receiving
a high habitat functions score on the wetland rating form). Based on these factors, the proposed replacement
deck would not be located within a wetland buffer even if the City of Edmonds required the applicant to
prepare a full-scale Critical Areas Report. With that said, Wetlands & Wildlife, Inc. confirmed via a phone call
with Rose Haas, City of Edmonds Planner, that the applicant is only required to prepare this Critical Areas
Site Assessment Report.
In accordance with professional ecological industry standards, the wetland buffer associated with the off -site
wetland to the east would not be required to extend across 80th Avenue W and onto the project even if the
proposed replacement deck was located in the standard buffer width (which it is not as demonstrated above).
Per professional ecological industry standards, a wetland buffer may be modified to the edge of the roadway
closest to the wetland when a legally established public asphalt roadway transects the standard buffer if the
part of the buffer on the other side of the roadway sought to be reduced provides insignificant biological,
Wetlands & Wildlife, Inc. November 18, 2023
Critical Areas Site Assessment Report —Burgess Construction, LLC (McCall Deck Replacement)
Incorporated City of Edmonds, Washington (Tax Parcel #00373600100306) Page 4
geological, or hydrological buffer functions relating to the portions of the buffer adjacent to the wetland and if
the portion of the buffer on the opposite side of the roadway from the wetland does not provide additional
ecological protection to the subject wetland. As previously discussed, a legally established asphalt roadway
(801h Avenue W) is located between the proposed project site and the off -site wetland that is located
approximately 260 feet from the proposed project area. The public roadway is an asphalt roadway which
receives very regular human use via vehicular traffic and the roadway effectively breaks the ecological
functions between the wetland and the subject property. The vegetation on the project site is limited to
maintained lawn and an immature hedge of Leyland cypress. Based on our assessments, the areas on the
project site which are located on the opposite side of 80th Avenue W provide insignificant biological,
geological, and hydrological functions to the wetland. The ecological functions associated with the wetland
and / or protective buffer areas on the east side of 80th Avenue W are effectively isolated from the proposed
project area in terms of ecological functions. As previously stated, the standard wetland buffer would not
extend into the project area even if the public roadway was not present. With these determinations in mind
and based on our phone conversation with Rose Haas, City of Edmonds Planner, Wetlands & Wildlife, Inc.
did not rate the off -site wetland to determine the current wetland category or current required standard buffer
width, but the standard wetland buffer would not extend across 80th Avenue W onto the subject property
regardless of the wetland category and standard buffer width.
PROJECT'S IMPACT DETERMINATION RELATED TO CRITICAL AREAS
As detailed in this report, it is the professional opinion of Wetlands & Wildlife, Inc. that the proposed deck
replacement project will be located outside of any regulated Critical Areas and outside of the associated
protective buffers of any regulated Critical Areas. Therefore, the proposed deck replacement project will
meet the professional ecological industry standards and will be completed in accordance with the current
regulations outlined in Title 23 (Natural Resources) of the City of Edmonds Code. Based on the detailed
site evaluations in conjunction with the applicant's project proposal, it is the professional opinion of Wetlands
& Wildlife, Inc. that no adverse ecological impacts will occur to any regulated Critical Areas or associated
protective buffer areas as a result of the proposed project outlined in this report. Therefore, no compensatory
mitigation efforts are proposed or required to accommodate the proposed project, since no adverse
ecological impacts will occur to any regulated Critical Areas or associated protective buffers.
LIMITATIONS AND USE OF THIS REPORT
This Critical Areas Report is supplied to Burgess Construction, LLC as a means of determining whether any
wetlands, streams, and / or wildlife habitat conservation areas regulated by City of Edmonds Critical Areas
Regulations exist on the site or within close proximity of the site which would affect the permit requirements
of the proposed development 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. 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
Wetlands & Wildlife, Inc. November 18, 2023
Critical Areas Site Assessment Report —Burgess Construction, LLC (McCall Deck Replacement)
Incorporated City of Edmonds, Washington (Tax Parcel #00373600100306) Page 5
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. does not provide analysis of other permitting requirements not discussed in this
report (i.e. structural, drainage, geotechnical, or engineering requirements) to determine whether the project
is in compliance with these aspects of the City of Edmonds Municipal Code.
While Wetlands & Wildlife, Inc. upheld professional industry standards when completing the evaluations
described in this report, 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 project 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 Site Assessment Report —Burgess Construction, LLC (McCall Deck Replacement)
Incorporated City of Edmonds, Washington (Tax Parcel #00373600100306)
November 18, 2023
Page 6
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.
City of Edmonds GIS. https://maps.edmondswa.gov/Html5Viewer/?viewer=Edmonds_SSL.HTML
Edmonds Municipal Code (EMC). Title 23. Natural Resources.
httas://www.codeDublishina.com/WA/Edmonds/#!/Edmonds23/Edmonds23.html
Hruby, T. & Yahnke, A. (2023). Washington State Wetland Rating System for Western Washington: 2014
Update (Version 2). Publication #23-06-009. Washington Department of Ecology.
SalmonScape. Interactive Mapping website administered by the Washington Department of Fish and
Wildlife. http://wdfw.wa.gov/mapping/salmonscape/index.html.
Snohomish County Map Portal. Snohomish County Planning and Development Services.
http://gismaps.snoco.org/Html5Viewer/Index.html?viewer=pdsmapportal.
U.S. Army Corps of Engineers (2010). "Regional Supplement to the Corps of Engineers Wetland Delineation
Manual: Western Mountains, Valleys, and Coast Region (Version 2.0)," ERDC/EL TR-10-3, U.S. Army
Engineer Research and Development Center, Vicksburg, MS.
U.S. Army Corps of Engineers (2020). National Wetland Plant List, version 3.5. U.S. Army Corps of
Engineers. Engineer Research and Development Center. Cold Regions Research and Engineering
Laboratory, Hanover, NH http://wetland-plants.usace.army.mil/
U.S. Fish and Wildlife Service. National Wetlands Inventory Wetlands Mapper.
httD://l 07.20.228.18/Wetlands/WetlandsMaaaer.html#.
Wetlands & Wildlife, Inc.
Critical Areas Site Assessment Report —Burgess Construction, LLC (McCall Deck Replacement)
Incorporated City of Edmonds, Washington (Tax Parcel #00373600100306)
November 18, 2023
Page 7