REVIEWED PLN_RESUB1 BLD2022-1025+WETLAND INFO+9.25.2022_11.26.28_PM+3127653 2BLD2022-1025
ENVIRONMENTAL CONSULTING
September 19, 2022
City of Edmonds
Development Services Department
Attn: Michele Q, Szafran
121 5th Ave N
Edmonds, WA 98208
RESUB
Sep 26 2022
CITY OF EDMONDS
DEVELOPMENT SERVICES
DEPARTMENT
Reviewed by
City of Edmonds :
Planning Division
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RE: Critical Areas Comment Response for the Duffy SFR — BLD2022-1025 — 23511
74th Ave W
The City of Edmonds has provided comments regarding the Addendum to the Wetland
Delineation Report for Snohomish County Tax Parcel 27043200200100, prepared on July 15,
2022, by Wetland Resources, Inc. This document lists the provided critical areas comments below in
italics with Wetland Resources responses following in standard text.
4(a). Shed in Buffer: The shed has been recently constructed as evidenced by aerial imagery without the benefit
of a permit within a critical area buffer, which is an alteration of a critical area and subject to a restoration/mitigation
plan. The critical area report needs to address this alteration, additionally the shed may not be placed within the
buffer and the building setback per ECDC 23.40.280. There may be an option to provide buffer width averaging
with buffer enhancement pursuant to ECDC 23.50.040.3., but the buffer width at any single location may not be
reduced more than 25% of the standard buffer width. If wetland buffer width averaging with buffer enhancement
does not work, then the structure must be removed, and restoration must be provided. Please address.
The shed is currently outside of the standard 60-foot buffer from the low habitat Category III
wetland. However, this area will be incorporated into the expanded buffer area. Therefore, the
shed will be removed and its footprint restored back to its pre-existing condition. All bare ground
areas associated with the removal of the shed and its gravel pad will be grass seeded with a mixture
consistent with the surrounding lawn.
4(b). Native Plantings: The report discusses compliance with ECDC 23.50.040(F)(1)(e), (fi and (g. Per
the report the wetland is a category III Wetland with a low habitat score which requires a 60 foot buffer pursuant
to ECDC 23.50.040(F)(1)(e). Mitigation measures pursuant to ECDC 23.50.040(F) (1) 0 are discussed in the
report, and the applicant has proposed an increased buffer to 75 feet with no native plantings proposed. Being that
the buffer primarily consists of nonnative vegetation and the proposal to increase the buffer alone does not appear to
add to the existing conditions, and the fact that a shed has been placed within the buffer it's not clear that a widened
buffer will ensure adequate functions of the buffer are being provided.
9505 191h Avenue SE, Suite 106, Everett, WA 98208 425.337.3174 www.wetlandresources.com
There appears to be an opportunity to enhance the predeveloped conditions by providing some level of native vegetation
within the buffer, please have the critical area consultant provide an enhancement plan.
EDC 23.50.040(1�(1)(d) states "The buffer widths in subsections (]�(1)(e) and JF (1)(g) of this section
assume that the buffer is vegetated with a native plant community appropriate for the ecoregion.
If the existing buffer is unvegetated, sparsely vegetated, or vegetated with invasive species that do
not perform needed functions, the buffer should either be planted to create the appropriate
plant community, or the buffer should be widened (Emphasis added) to ensure that adequate
functions of the buffer are provided." The applicant has chosen to widen the buffer to 75 feet
rather than implement an enhancement plan. This increased buffer will allow for more dispersal
time across the lawn for the benefit of water quality and stormwater management. In addition,
this increase in buffer is consistent with the requirements of EDC 23.50.040(1�(1)(d) and the
Washington State Department of Ecology Update on Wetland Buffers: The State of the Science Final Report,
October 2013.
4(c). Please note that a mitigation plan will requirefinancialguarantees pursuant to ECDC 23.40.130.F to ensure
the mitigation plan is fully implemented. The critical area report must provide a cost estimate for the plantings which
will determine the amount of the performance bond and maintenance bond per ECDC 23.40.290. The maintenance
bond will be held for 5years following completion and inspection of the required plantings.
The only mitigation proposed is grass seeding the pad associated with the shed. The cost associated
with this is di minimus and below a threshold that would require a financial guarantee, monitoring,
or maintenance.
4(d). Please show the required 15 foot building setback from the buffer on the site plan consistent with ECDC
23.40.280.
The 15-foot building setback from the edge of the increased 75-foot buffer has been added to the
site plan as requested
5. Floodplain: Please include the attached floodplain habitat assessment worksheet with the building permit, only
the applicable sections need to be filled out.
The applicable sections of the floodplain habitat assessment worksheet have been filled out and are
attached for review.
Wetland Resources, Inc
Scott Brainard PWS
Principal Ecologist
Wetland Resources, Inc. Duffy SFR
September 21, 2022 2 WRI # 17009