Loading...
HomeMy WebLinkAboutWetland Mitigation 821291002 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN NOVEMBER 10, 2020 BGE19_0170.030 BGE ENVIRONMENTAL, LLC. WETLAND CONSULTING AND LAND USE PLANNING NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN NOVEMBER 10, 2020 PROJECT LOCATION IRON MOUNTAIN QUARRY STATE ROUTE 104 PORT LUDLOW, WA PREPARED FOR JIM BURNETT IRON MOUNTAIN QUARRY BOTHELL, WA PREPARED BY BGE ENVIRONMENTAL LLC 2102 BRASHEM AVE BREMERTON, WA 98310 360.710.6066 www.bgeenvironmental.com BGE19_0170.030 BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 1 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN INTRODUCTION Iron Mountain Quarry’s New Shine Quarry (NSQ) is an approved phased mining operation in Jefferson County. The facility, operations, and mining area are located within an approximate 142 acre parcel owned by Rayonier (formerly Pope Resources) and leased by Iron Mountain Quarry. A critical area inventory of wetlands and streams was completed in 2009 (ENVIRON). The land use action for the NSQ was reviewed under the authority of Jefferson County (County). A jurisdictional determination was concluded with the U.S. Army Corps of Engineers (Corps) and the Washington Department of Ecology (Ecology). Twenty-one (21) wetlands were identified within the project area. Eleven were determined and confirmed by the Corps as not being waters of the U.S. (NWP-2009-981 dated July 25, 2011). NSQ has requested the Corps’ concurrence, through a stand-alone Corps Approved JD (33 CFR 331). The NSQ is currently in operation and is now seeking County approval of Phase 2. Several conditions of the County’s SEPA threshold determinations, a Mitigated Determination of Non- significance (MDNS), apply to the review and approval of this phase. Specifically, conditions 14 through 20. Wetlands were reviewed, assessed, and quantified for jurisdiction in 2019. The Wetland inventory update is documented in the New Shine Quarry Wetland Inventory Update by BGE dated September 21, 2020 (BGE19_0170.020). Wetland impacts with both Phases of the project, direct and indirect, amount to 0.75 acres of Category IV wetlands. Wetland buffer impacts total 3.88 acres. Advanced mitigation was completed through a covenant, recorded in 2013, as preservation of 16.3 acres of Category I broad-leaved forested and estuarine emergent wetland. Enhancement of 3.7 acres of broad-leaved forested to conifer-dominated forest is scheduled for completion, December 2020. On-site mitigation includes buffer averaging to impacted Phase 1A buffers for no net loss of area up to twenty-five percent of the impact. On-site wetland creation, concurrent with Phase 2 stormwater facility construction, mitigates the final balance of impacts with the NSQ operations. On-site wetland creations is not less than 0.31 acres . This document is the Final NSQ Mitigation Plan to address the conditions of approval for Phase 1B, Phase 1A, and Phase 2. For reference the MDNS conditions are provided below. This report includes a determination of impacts associated with the implementation of Phase 1B and Phase 1A and all known and anticipated impacts with the approval of Phase 2. BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 2 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN SEPA MDNS MITIGATION CONDITIONS JEFFERSON COUNTY MDNS (2012) NSQ Each of these conditions contains some elements that are relevant to the final wetland mitigation plan for the phases of the NSQ. Each condition is reproduced as it appears in the MDNS under Surface Water (Streams and Wetlands) Conditions 14 through 20 as modified by the SEPA Addenda issued by the County on September 28, 2012 . 14. The Final Wetland Mitigation Plan for each phase of the project shall be reviewed by Jefferson County for consistency with codes and standards. The plans shall be based on mitigation guidance specified in the Jefferson County Code and in Wetland Mitigation in Washington State (2006) prepared by Ecology, USACE, and USEPA. 15. The following will be a precondition of the Phase 1B Stormwater Management Permit1: The Phase 1B Final Wetland Mitigation Plan shall feature a table that includes the following information for all phases of the project: wetland category, wetland buffer width, direct wetland impact area, indirect wetland impact area, wetland buffer impact area, total wetland mitigation area and ratios (per table JCC 18.22.35), proposed onsite mitigation (type and acreage), proposed offsite mitigation (type and acreage), and the phases during which the impacts and mitigation will occur. It is understood that the wetland impact numbers would be worst-case scenario, are subject to change after Phase 1B, and shall be updated (if necessary) in the Phase 1A and/or Phase 2 Final Wetland Mitigation Plans. 16. Wetland hydrology monitoring shall be conducted during Phase 1B and 1A to determine if onsite wetlands, including but not limited to wetlands A, C, D, and E, increase or decrease in size as a result of storm water management (e.g., infiltration/dispersion tren ches). This monitoring shall be correlated with how the trenches are functioning. All other onsite wetlands that have the potential to be indirectly affected by the project activity shall be re - delineated before Phase 1A or Phase 2 commences, and the bou ndaries shall be confirmed by the County and/or the U.S. Army Corps of Engineers. New wetland boundaries shall be surveyed and documented either in a revised wetland report or in the Final Wetland mitigation Plan for the next phase of the project. All results of the wetland hydrology monitoring shall also be included in the report/plan. The report/plan shall be provided to Jefferson County for approval. 17. An increase in size to Wetlands A, C, D and E as a result of the infiltration/dispersion trenches may be used to satisfy wetland mitigation requirements, pursuant to these conditions: 1 A precondition is required before issuance of a permit. BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 3 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN a. Any proposal to use the new wetland areas as mitigation credit shall be detailed in the Final Wetland Mitigation Plan for the next phase of the project. The new wetland delineation shall clearly reveal that 1) wetland criteria have been met in these expanded areas, per Jefferson County Code, and 2) other onsite wetlands have not been indirectly affected and/or are now smaller in size. b. Larger wetlands must be rated again, including the new wetland area, and this information shall be included either in a revised wetland report or in the Final Wetland Mitigation Plan for the next phase of the project. c. These new wetland areas shall be planted with native vegetat ion if they are unvegetated, and shall be included in the wetland mitigation monitoring plan. d. Trenches shall be functioning correctly and consistently so that constant wetland hydrology is expected throughout the life of the quarry operations. 18. Timing of the mitigation activities shall be as follows: a. Prior to Phase 1B approval, advance offsite critical areas mitigation in the for m of wetland preservation (securing and protecting the offsite estuarine intertidal wetland) shall be completed for th e wetland buffer impacts proposed to occur in Phase 1B. b. Prior to Phase 1A approval, offsite critical areas mitigation (in the form of wetland preservation, and/or wetland enhancement) shall be completed for the critical area impacts proposed to occur in Phase 1A. In, addition, onsite wetland creation for indirect wetland impacts to Wetland L, shall be completed at the end of Phase 1A. c. Prior to Phase 2 permit issuance, offsite critical areas mitigation (in the form of wetland and buffer preservation, restoration, rehabilitation, and/or enhancement) and onsite critical areas mitigation (in the form of buffer restoration and wetland creation and/or re-establishment in the Phase 1A area) shall be completed for the critical areas impacts proposed to occur in Phase 2. 19. Wetland mitigation monitoring plans shall be included in the Phase 1B, Phase 1A, and Phase 2 Final Wetland Mitigation Plans submitted for the proposed mining activities. 20. Contingency plans shall be included in the Phase 1B, Phase 1A, and Phase 2 Final Wetland Mitigation Plans submitted for the proposed mining activities. Contingency measures should provide direction in the event that a proposed wetland mitigation plan fails, or in case critical area impacts are greater than anticipated. BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 4 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN PROJECT ACTIONS The NSQ is defined and approved to two phases. The first phase is referenced as Phase 1B (14.8 acres) and Phase 1A (21.9 acres). Phase 1B was defined as a secondary processing and stockpile area which included some mining activities. Elements of this phase included a basin/action specific stormwater control pond. Phase 1A is mining. Direct wetland impacts were not anticipated until Phase 2, although indirect impacts were conservatively anticipated and likely overestimate (ENVIRON) with the incremental mining of Phases 1B and 1A. To date, Phase 1B was not used to support processing. Rather the existing Shine Quarry, adjacent to and northwest of the NSQ has been and continues to be used for operations. Actions occurring within Phase 1B included limited clearing for stockpiles, road improvements, and a modest detention pond. Phase 1A is delineated with clearing limits , stormwater facilities are complete, and mining operations are on -going. Mitigation has been provided as preservation to an offsi te, in basin 20-acre Category I wetland. The preserved wetland is a broad-leaved forested and estuarine emergent complex, with acreages of 10.5 and 5.8 respectively. Enhancement of natural succession patterns to 3.7 acres of broad-leaved forested wetland is currently being implemented. The boundaries of all wetlands were objectively reviewed and assessed in 2019. Wetland determinations were completed in August 2020 using the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region. Wetland Regulatory Assistance Program, Army Corps of Engineer. May 2010. All wetlands have been rated using the most recent version of the Washington State Department of Ecology’s rating system for Western Washington (Hruby 2014). The investigation and findings are presented in the New Shine Quarry 2019 Wetland Inventory Update by BGE dated September 21, 2020 (BGE19_0170.020). A final mitigation plan is conditioned to the permitting of Phase 2. Project impacts, direct and indirect, have been quantified and addressed in this Final wetland mitigation plan. BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 5 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN WETLAND INVENTORY UPDATE The NSQ wetlands, ratings, and associated buffers (2019) are shown on Exhibit A. There are twenty-one (21) wetlands within the proposed mine lease area. Wetland BB is an extension of Wetland B and is not identified as a separate wetland. All NSQ wetlands were field reviewed to determine potential changes, increase or decrease in size, since the original delineation in 2009, as a result of NSQ Phase 1B and Phase 1A (MDNS Condition 16). The wetlands were objectively reviewed in March 2019 by a Senior Professional Wetland Scientist (SPWS). All wetlands were relocated with plan maps and confirmed with remnant flagging based on the 2009 delineation by ENVIRON. Wetland flagging was frequently encountered. Where absent, the boundary was field walked and confirmed for accuracy to the projects plan maps (survey). The observed wetland boundary was evaluated for consistency and concluded as having no change, larger, smaller, or non-wetland. Assessment data was taken for determination of function, value and category rating for processing wetland category to the current guidance using the Western Washington Wetland Rating System-2014 Update by the Department of Ecology (Ecology). BGE completed the wetland determinations in August 20202. Wetland ratings and standard JCC buffers were assessed at Category II, Category III, and Category IV complexes. Standard buffers are 300, 150, and 50 feet, respectively. A table summary of the wetland delineation and ratings for the 2009 versus the 2019 assessment is provided in Appendix A. The NSQ wetland assessment was compiled into the New Shine Quarry 2019 Wetland Inventory Update by BGE dated September 21, 2020 (BGE19_0170.020). The 2019 wetland review concludes that Wetland F is non wetland where hydrophyte coverage is limited to individuals and hydrology was absent. Wetland S is larger than delineated in 2009. All other subject wetlands are unchanged. It should be noted that the Hruby (2004b) wetland rating methods indicates that the rating system for wetlands smaller than 4,356 sq ft (0.1 acre) “will not work well”. Many NSQ wetlands are less than 0.1 acre, and related scores are presumed to overestimate the potential function. With the updated 2014 version of the rating system, most of these small wetlands resulted in Category IV system. A summary of the updated findings and standard buffers for all NSQ wetlands is provided in Table 1 below. Delineated wetlands, ratings, and standard JCC buffer widths are shown on Exhibit A. 2 Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region. Wetland Regulatory Assistance Program, Army Corps of Engineer. May 2010. BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 6 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN Table 1. Summary of NSQ Wetland Update 2019 Wetland Area (acres) HGM 1 Water Quality Hydrologic Habitat Rating 2 Buffer (ft) A 0.37 S 3 3 6 IV 50 B/BB 0.38 S 4 4 7 IV 50 C 1.13 S 4 4 8 III 300 D ND 3 R 5 6 9 II 300 E 0.90 S 3 3 8 IV 50 F 4 0.05 S Wetland is no longer present in 2019 G 0.03 S 3 3 6 IV 50 H 0.25 S 3 3 6 IV 50 I 0.40 D 4 4 7 IV 50 II 0.06 D 4 4 6 IV 50 J 0.03 D 4 3 6 IV 50 K 0.12 D 5 4 6 IV 50 L 0.77 D 6 4 7 III 150 M 1.53 D 5 4 7 III 150 N 0.01 D 4 3 6 IV 50 O 0.03 D 5 4 6 IV 50 P 0.15 D 4 3 6 IV 50 Q 0.06 D 5 4 6 IV 50 R 1.02 5 D 5 4 8 III 300 S 2.88 5 D 5 5 7 III 150 T 0.70 S 4 3 7 IV 50 1 HGM: S= SLOPE, R=RIVERINE, D=DEPRESSIONAL 2 Washington State Wetland Rating System for Western Washington, 2014 Update 3 Not Delineated (ND). Wetland off-site 4 Function and rating scores taken from ENVIRON analysis, 2004 Rating Methodology 5 On-site area only, wetland continues off-site to the nth degree BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 7 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN PROJECT IMPACTS WETLAND AND WETLAND BUFFER IMPACT ASSUMPTIONS & CONCLUSIONS To evaluate potential mitigation requirements, the Final Phase 1B & 1A Wetland Mitigation Plan hypothesized conservatively, that indirect impacts will occur based on three factors. The first is the change, or loss, of hydrology with the mining in close proximity to wetland boundaries . Interception of hydrologic sources and sinks to the wetlands is likely. Indirect impacts were openly overestimated, and Wetland L and M were assumed to be completely lost from indirect impacts with the mining. This hypothesis failed as the wetland boundaries were unchanged in 2019 despite the mining that has occurred . The second hypothesis considered the effects of stormwater management facilities (detention/water quality ponds in series with infiltration/dispersion trenches) overflow to the downstream receiving wetlands. Outfalls were designed, directed, and managed to Wetlands A, C, D, and E. The discharges would supposedly mitigate upslope mining by supplementing the wetlands hydrology long term. Should the receiving wetlands expand in area with the stormwater management facilities, credit could be sought in accordance with MDNS Condition 17. The downslope, stormwater receiving wetlands were observed to be relatively unchanged in boundary in 2019. To date, the hypothesis that wetlands will be expanded with the infiltration and/or sheet flow from the upslope stormwater facilities has failed. However, these facilities have only recently been completed with designed discharge now fully functioning. Currently the wetland boundaries are static so the stormwater management faci lities are presumed to have adequately mitigated anticipated hydrologic changes upslope . These overflows could likely result in larger wetlands in the future. The third hypothesis was based on the retention of forested cover within the wetlands contributing drainage basin. It was presumed that if less than 50 percent of the wetland watershed was left undisturbed, 100 percent of the wetland would be lost indirectly. This hypothesis provided mitigation projections for compensatory planning to Phase 1A & 1B. In summary, the 2009 Report assumed indirect impacts to Wetlands A, F, L, and M. Anticipated impacts to Wetland A were likely mitigated with the stormwater facilities, which occurred. Wetland F was confirmed as absent in 2019, agreeing that loss of basin forest cover indirectly impacted this wetland. The boundary of Wetland L is relatively unchanged despite, the adjacent BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 8 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN mining, having removed 46% of the basin forest cover. Wetland M drainage basin is retained to date at 89% forest cover with no discernable changed identified to the wetland boundary. The forested basin hypothesis passed. A summary of the indirect impact via forested basin retention among phases is provided in Table 2 and shown in Exhibit B. Mined (sq ft) Forested (sq ft) Percent Forested Mined (sq ft) Forested (sq ft) Percent Forested Mined (sq ft) Forested (sq ft) Percent Forested Direct (sq ft) Indirect (sq ft) A 16,236 IV 359,662 292,963 66,699 19%- 66,699 19%0 66,699 19%0 0 0 1 A B & BB 16,505 IV 244,610 14,150 230,460 94%0 230,460 94%0 230,460 94%0 0 B & BB C 49,141 III 160,606 2 30,706 129,900 81%0 129,900 81%0 129,900 81%0 0 C D ND III ND 3 0 0 0 0 D E 39,085 IV 523,057 245,791 277,266 53%0 277,266 53%7,898 269,368 51%0 0 E F 2,221 NA 195,687 175,836 19,851 10%0 19,851 10%0 19,851 10%0 2,221 2,221 F G 1,284 IV 34,518 0 34,518 100%0 34,518 100%0 34,518 100%0 0 G H 11,070 IV 138,055 34,163 103,892 75%0 103,892 75%1,005 102,887 75%0 0 H I 17,622 IV 87,979 0 87,979 100%0 87,979 100%82,099 5,880 7%17,622 0 17,622 I II 2,844 IV 125,104 0 125,104 100%66,691 58,413 47%46,178 12,235 10%2,844 0 2,844 II J 1,411 IV 213,037 0 213,037 100%212,636 401 0%184,943 401 0%1,411 0 1,411 J K 5,266 IV 63,726 13,031 50,695 80%0 50,695 80%0 50,695 80%0 0 K L 33,509 III 393,597 180,105 213,492 54%0 213,492 54%0 213,492 54%0 0 L M 66,836 III 521,492 58,708 462,784 89%699 462,085 89%0 462,085 89%0 0 M N 738 IV 175,581 0 175,581 100%86,250 89,331 51%0 89,331 51%0 0 N O 1,240 IV 82,824 23,268 59,556 72%9,398 50,158 61%0 50,158 61%0 0 O P & Q 9,137 IV 183,262 0 183,262 100%95,708 87,554 48%0 87,554 48%0 9,137 9,137 P&Q R 44,836 III ND 3 0 0 0 0 0 R S 136,089 III ND 3 0 0 0 0 0 S T 30,353 IV 138,551 16,060 122,491 88%122,491 88%0 122,491 88%0 0 T 21,877 11,358 33,235 0.50 0.25 0.75 1 Hydrology maintained by pond(s), dispersion tranches 2 Contributing basn not fully delieateed, only contains area on-site 3 Not Delineated, extends well outside of action area Total Impacts (sq ft) Total Impacts (acres) Table 2. Direct and indirect wetland impact determination & forested basin assessment, all phases of mining actions. Wetland Wetland Area (sq ft) Rating Contributing Basin (sq ft) PHASE 1 PHASE 2A PHASE 2B IMPACTS Mitigation Area (sq ft) BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 10 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN WETLAND AND BUFFER IMPACT SUMMARY Wetland and wetland buffer impacts from the different phases of the project have been identified. All wetland buffer impacts have occurred with Phase 1. Buffers associated with wetlands not disturbed with Phase 2 are avoided. Wetland character, complex, ratings, and impacts are summarized in Table 3. Wetland and buffer impacts are shown in E xhibit C. Table 3. Wetland and buffer impact summary Impact (D)=Direct, (I)=Indirect Area (acres) HGM 1 FUNCTIONS Rating Water Quality Hydrologic Habitat Wetland (I) Wetland F 2, 3 0.05 Slope 5 1 20 IV (D) Wetland I 0.40 Depression 4 4 7 IV (D) Wetland II 3 0.06 Depression 4 4 6 IV (D) Wetland J 3 0.03 Depression 4 3 6 IV (I) Wetland P 0.15 Depression 4 3 6 IV (I) Wetland Q 3 0.06 Depression 5 4 6 IV Total Wetland Impact 0.75 Buffer (acres) Buffer C 0.54 Buffer L 2.57 Buffer M 0.77 Total Wetland Buffer Impact 3.88 1 Hydrogeomorphic (HGM) type 2 Function and rating scores taken from ENVIRON analysis, 2004 Rating Methodology 3 Category IV wetland <0.1 acres are exempt from replacement requirements of JCC BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 11 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN MITIGATION STANDARDS All wetlands have been rated using the most recent version of the Washington State Department of Ecology’s rating system for Western Washington (Hruby 2014). All impacts with the project are Category IV, slope and depressional, complexes. Mitigation standards and con clusions are provided in the Final 1A and 1B Wetland Mitigation Plan 3 which states, ‘Wetland buffer impacts are only included for impacts to buffers of wetlands that will remain intact. For those wetlands eliminated by the project, the impact for the loss of wetlands has been counted but not the buffer. To calculate the adequacy of mitig ation, the loss of wetland buffers is considered equivalent to the loss of a “Category III” wetland’. This standard is adjusted to the current and most recent category rating for impacts as Category IV. Mitigation requirements, at the time of the lease and permit approval of Phase 1, was approved as preservation and enhancement to an off-site, in basin 20-acre Category I wetland. The mitigation area provided partial mitigation in advance of any wetland impacts for all phases of the NSQ operations. The Category I wetland complex has been recorded for preservation in a covenant dated January 17, 2013 (Appendix B). The off-site mitigation area includes 10.5 acres of palustrine broad -leaved deciduous forest and 5.8 acres of estuarine emergent intertidal wetland. The remaining 3.7 acres of the preservation area is enhancement of natural succession patterns to a broad-leaved deciduous forest. Enhancement is currently being implemented. The offsite mitigation area is shown on Exhibit D, replicated Figure 4 (ENVIRON 2012). Mitigation includes on-site creation for the all additional areas of direct and indirect impacts with the Phased mining operations. Creation is proposed at 1:1 ratio for Category IV wetlands located to the Phase 1A mining area. Restoration of wetland buffers shall include robust plantings to standard widths for reforestation. Mitigation for both wetland and buffer are consistent with the interagency regional mitigation guidance4 and JCC Title Table 18.22.740(1). 3 Table 1. Estimated direct and indirect wetland and wetland buffer impacts and proposed onsite and offsite compensatory wetland mitigation and mitigation replacement ratios and net mitigation benefits at p. 3. Attachment A Response to June 7, 2012 Stormwater Permit Application Review Comments. June 22, 2012. ENVIRON. 4 Table 1a. Mitigation Ratios for Western Washington at p. 73. Washington State Department of Ecology, U.S. Army Corps of Engineers Seattle District, and U.S. Environmental Protection Agency Region 10. March 2006. Wetland Mitigation in Washington State – Part 1: Agency Policies and Guidance (Version 1). Washington State Department od Ecology Publication #06-0-011a. Olympia, WA. BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 12 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN ON-SITE MITIGATION ON-SITE BUFFER AVERAGING Buffer impacts to Wetlands C (0.54 acres), Wetland L (2.57 acres), and Wetland M (0.77 acres) occurred in conjunction with the Phase 1 mining area. Phase 2A is designed to avoid direct impacts to outlying wetland buffers. Opportunity to mitigate for existing buffer impacts exists to Wetlands L and M through buffer averaging. To compensate for loss of buffer area, twenty-five percent of the impacted buffer is applied to mature forested uplands adjacent to the standard buffers, see Exhibit E. The averaging results in replacing 0.64 acres of Wetland L buffer and 0.20 acres of Wetland M buffer. The averaging is established at 1:1 for no net loss of buffer area. The remaining cumulative buffer impacts to Wetlands L and M are 2.5 acres. ON-SITE WETLAND CREATION A minimum of 0.31 acres of wetland will be created to a forested mixed canopy wetland complex within Phase 1A upon completion of the current mining and stormwater pond construction (Phase 2B). The mitigation area will be designed to the topographical position in the existing landscape. Hydrologic support will be secured with overflow and dispersion from the Phase 2B stormwater pond. Soils will be amended from the excavations of Wetland I and Wetland II accordingly. Plantings shall be robust densities of native trees and limited shrub species to promote structural complexity and habitat forming niches found in natural forested wetlands. Design elements shall include habitat features such as snags and logs, and may include native seeding for discovery of success. Restoration of buffers shall include robust plantings to standard widths for reforestation. The proposed location of this created wetland is illustrated on Exhibit F. OFF-SITE MITIGATION ENHANCEMENT Enhancement of natural succession patterns to conifer -dominated forested wetlands is currently underway to 3.7 acres extending from the toe-of-slope of South Point Road to the west as shown in Exhibit D. The prescribed reforestation is moderate density se edlings considering a deciduous BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 13 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN forest already exists. The prescribed density is 100 trees/acres and includes western red cedar (139), Sitka spruce (138), and western hemlock (93). These species are suited to the landscape and hydrologic regime. It is expected that a fraction of these trees will survive to maturity. Plantings promote the establishment of multiple tiers within the overstory with a mixed stand - age to enhance the ecological processes truncated as a consequence of periodic timber harvest activities. MONITORING Minimal monitoring is proposed to the enhancement area. Permanent photostations will be established to the enhancement area and perimeter. An as-built report will be produced once all plantings are complete. The as-built will include established photostations with GPS coordinates, directions, photographs, planting details, and success standards. Periodic photographs shall be taken to document survival and maturation of planted conifers. Monitoring and success shall be evaluated on the observed successional trajectory of the planted conifers over a minimum period of ten years. PRESERVATION The entire 55.5 acre area has been recorded in a covenant. An area of 20 acres is earmarked as mitigation for the NSQ. The preservation area is 16.3 acres Category I palustrine broad-leaved deciduous forest and estuarine emergent intertidal wetland 5. The offsite mitigation is shown on Exhibit D, replicated Figure 4 Final Phase 1B & 1A Wetland Mitigation Plan (ENVIRON 2012). ESTUARINE EMERGENT INTERTIDAL WETLAND Tidally influenced, this salt marsh intertidal wetland is well defined with dense emergent complexity along tidal channels. Vegetation inventory includes pickleweed (Sarcocornia perennis), seashore saltgrass (Distichlis spicata), potentilla (Potentilla anserine), and softstem bulrush (Schoenoplectus tabernaemontani). Farther away from the active channels, softstem bulrush forms dense stands throughout much of the 5.8 acre estuarine intertidal emergent wetland preservation area identified on the attached off-site wetland mitigation figure, Exhibit 5 Wetland nomenclature by ENVIRON 2012. BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 14 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN PALUSTRINE BROAD-LEAVED DECIDUOUS FORESTED WETLAND A total of 10.5 acres of this wetland type is present to the preservation area. Complexity is a common lowland forest of red alder (Alnus rubra) and Pacific willow (Salix lucida). Dominate understory is skunk cabbage (Lysichiton americanus), salmonberry (Rubus spectabilis), slough sedge (Carex obnupta), and black twinberry (Lonicera involucrate). Invasive species are abundant locally to areas disturb ed along the right-of-way to South Point Road. TIMING Off-site preservation is complete (Appendix B) and enhancement is underway, to be completed in December 2020. On-site creation will not occur until Phase 2B with final construction of the stormwater pond. The wetland creation design details will be completed in the future concurrent to the findings models and production of construction grade facility plans to comply with MDNS condition 18 and 19. BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 15 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN COMPLIANCE The combined mitigation strategy for preservation, enhancement, and creation is consistent with the approved mitigation targets in the Final Phase 1B & 1A Wetland Mitigation Plan and the interagency mitigation guidelines. A summary of impact type, phase , and compensatory mitigation is provided in Table 4. Due to the phased approach and large landscape of the mining operations, impacts to wetlands and buffers have a high temporal variability. Over ninety (90) percent of the impacts are mitigated in advance to high quality Category I wetlands in the same watershed . These wetland function at a higher level, providing habitat value to multiple prior ity species of fish and wildlife. The remainder of the mitigation, on-site creation, is in the later time frame and concurrent with Phase 2B. Once successfully complete the mitigation elements comply with the policies for no net loss of area and re-establishes functional parameters of impacted wetlands within the watershed. CONTINGENCY Should any action of wetland creation or enhancement fails to satisfy the goals for establishment to such an extent that the failure cannot be adequately addressed through standard maintenance activities, a contingency plan shall be developed. A detailed contingency plan cannot be developed until the specific items that need to be address ed are known. Compliance with the installation procedures and maintenance plans are measures to properly promote a successful mitigation project. Where the performance is less than satisfactory, attention shall be given to, but not limited to, soil conditions, species installation, and temporal variations. Adaptive management actions taken to ensure success, when practical, are an acceptable means to ensure survival and growth of the planted species. This contingency plan complies with MDNS condition 20. Table 4. Summary of impacts and compensatory mitigation for all mining phases; final Phase Impacts (acres) Total Wetland and Buffer Impacts Wetland Mitigation (acres) Replacement Ratios & Credits Total Mitigation Benefit Wetland Buffer Wetland 1 Category IV On-site Off-site On-site Off-site Direct Indirect R/C PRES 2 ENH 3 R/C 4 PRES 10:1 ENH 2:1 1A 2.50 5 0.05 6 2.55 16.3 1.63 1.63 1B 0.54 [7] 0.54 3.7 1.85 1.85 2A 0.03 8 0.21 9 0.24 2B 0.46 10 0.46 0.31 0.31 0.31 TOTAL 3.04 0.49 0.26 3.79 0.31 16.3 3.7 0.31 1.63 1.85 3.79 [1] All wetlands have been rated using the most recent version of the Washington State Department of Ecology’s rating system for Western Washington (Hruby 2014). [2] The off-site preservation area is 16.3 acres Category I palustrine broad -leaved deciduous forest and estuarine emergent intertidal wetland. [3] The off-site enhancement appears to meet the definition of rehabilitation , see Final Phase 1B and 1A Final Wetland Mi tigation Plan report (ENVIRON 2012) [4] On-site re-establishment/creation proposed at a minimum ratio of 1:1. Conceptual mitigation proposes 0.31 acres of on -site wetland creation. [5] Buffer Wetland L = 2.57 acre (112,105 sq ft), Wetland M = 0.77 acre (33,455 sq ft): Reduced by 25% with buffer averaging [6] Wetland F = 0.05 acre (2,221 sq ft) [7] Buffer Wetland C = 0.54 acre (23,328 sq ft) [8] Wetland J = 0.03 acre (1,411 sq ft) [9] Wetland P= 0.15 acre (6,447 sq ft) & Wetland Q = 0.06 acre (2,690 sq ft) [10] Wetland I = 0.4 acre (17,622 ft) & Wetland II = 0.06 acre (2,844 sq ft) EXHIBIT A WETLANDS & BUFFER NEW SHINE QUARRY Wetland Consulting & Land Use Planning BGE Environmental, LLC BGE19_0170.030 J E C B A I H G FT L M K II O S R SHINE QUARRY N D Q & P CATEGORY IV CATEGORY III CATEGORY II 2019 Delineation replicated with professional judgement to remnant flagging. Aerial photography Google Earth 2018 BB EXHIBIT B WETLAND DRAINAGE BASIN IMPACTS NEW SHINE QUARRY BB J E C A I H G F T L M K II P & Q O N S R PHASE 1APHASE 1B PHASE 2A Wetland Consulting & Land Use Planning BGE Environmental, LLC BGE19_0170.030 PHASE 2B Basin replication Environ 2011 Wetland Consulting & Land Use Planning BGE Environmental, LLC BGE19_0170.030 BB J E C B A I H G FT L M K II O S R SHINE QUARRY N D Q & P WETLAND BUFFER IMPACTS INDIRECT WETLAND IMPACTS DIRECT WETLAND IMPACTS PHASE 2A PHASE 1A MINING EXHIBIT C WETLAND & BUFFER IMPACTS NEW SHINE QUARRY PHASE 2B PHASE 1B Wetland Consulting & Land Use Planning BGE Environmental, LLC BGE19_0170.030 EXHIBIT D OFFSITE PRESERVATION 20 ACRES CATEGORY I WETLAND Wetland Consulting & Land Use Planning BGE Environmental, LLC BGE19_0170.030 BB J E C B A I H G FT L M K II O S R SHINE QUARRY N D Q & P WETLAND BUFFER REDUCTION WETLAND BUFFER IMPACTS PHASE 2A PHASE 1A MINING EXHIBIT E BUFFER AVERAGING NEW SHINE QUARRY PHASE 2B PHASE 1B WETLAND BUFFER AVERAGING Wetland Consulting & Land Use Planning BGE Environmental, LLC BGE19_0170.030 BB E C B A H G T L M K O S R SHINE QUARRY N D Q & P PHASE 2A PHASE 1A MINING EXHIBIT F REMAINING INTACT FOREST AND ON-STE WETLAND MITIGATION NEW SHINE QUARRY PHASE 2B PHASE 1B WETLAND CREATION 0.31 ACRES BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 17 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN REFERENCES BGE Environmental, LLC. September, 2020. New Shine Quarry Wetland Inventory Update. Brinson, M. M. (1993). “A hydrogeomorphic classification for wetlands,” Technical Report WRP- DE-4, U.S. Army Engineer Waterways Experiment Station, Vicksburg, MS. http://el.erdc.usace.army.mil/wetlands/pdfs/wrpde4.pdf Cowardin, L. M., V. Carter, F. C. Golet, E. T. LaRoe. 1979. Classification of wetlands and deepwater habitats of the United States. Government Printing Office, Washington, D.C. http://www.fws.gov/nwi/Pubs_Reports/Class_Manual/class_titlepg.htm ENVIRON International Corporation. July 2009. New Shine Quarry Wetland Delineation and Inventory. Project 30-22731. ENVIRON International Corporation. June 13, 2011. Addendum to Wetland Delineation and Inventory Report for the New Shine Quarry (NSQ). ENVIRON International Corporation. May, 2012. New Shine Quarry Final Phase 1B & 1A Wetland Mitigation Plan. ENVIRON International Corporation. June 22, 2012. Attachment A to Responses to June 7, 2012 Stormwater Permit Application Review Comments . Hruby, T. (2014). Washington State Wetland Rating System for Western Washington: 2014 Update. (Publication #14-06-029). Olympia, WA: Washington Department of Ecology. Jefferson County Code (JCC). Title 18.22 Critical areas. https://www.codepublishing.com/WA/JeffersonCounty/#!/JeffersonCounty18/JeffersonCounty18 .html Lichvar, R.W., D.L. Banks, W.N. Kirchner, and N.C. Melvin. 2016. The National Wetland Plant List: 2016 wetland ratings. Phytoneuron 2016-30: 1-17. Published 28 April 2016. ISSN 2153 733X. http://wetland- plants.usace.army.mil/nwpl_static/data/DOC/lists_2016/National/National_2016v2.pdf U.S. Army Corps of Engineers. 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, a nd Coast Region (Version 2.0), ed. J. S. Wakeley, R. W. Lichvar, and C. V. Noble. ERDC/EL TR -10-3. Vicksburg, MS: U.S. Army Engineer Research and Development Center. BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 PAGE | 18 NEW SHINE QUARRY FINAL WETLAND MITIGATION PLAN VanNess, Feldman, GordonDerr. May 9, 2012. Iron Mountain Quarry-Response to 3/15/12 Letter and 4/20/12 MDNS (copy) Washington State Department of Ecology, U.S. Army Corps of Engineers (Seattle District), and U.S. Environmental Protection Agency (Region 10). 2006a. wetland Mitigat ion in Washington State – Part 1: Agency Policies and Guidance (Version 1). Washington State Department of Ecology Publication #06-06-011a. Washington State Department of Ecology, Lacey, WA. BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 BGE19_0170.030 NEW SHINE QUARRY FINAL DRAFT WETLAND MITIGATION PLAN APPENDIX A Summary comparison wetland rating and buffer; 2009 (ENVIRON) AND 2019 (BGE) WETLAND AREA (acres) HGM 2009 2019 RATING BUFFER (ft) RATING BUFFER (ft) A 0.37 Slope III 150 IV 50 B/BB 0.38 Slope III 150 IV 50 C 1.13 Slope III 150 III 300 D ND1 Riverine II 300 II 300 E 0.90 Slope III 150 IV 50 F 0.05 Slope IV 50 Non Wetland G 0.03 Slope IV 50 IV 50 H 0.25 Slope IV 50 IV 50 I 0.40 Depressional III 150 IV 50 II 0.06 Depressional III 150 IV 50 J 0.03 Depressional III 150 IV 50 K 0.12 Depressional II 150 IV 50 L 0.77 Depressional III 150 III 150 M 1.53 Depressional III 150 III 150 N 0.02 Depressional IV 50 IV 50 O 0.03 Depressional III 80 IV 50 P 0.15 Depressional III 80 IV 50 Q 0.06 Depressional III 80 IV 50 R 1.022 Depressional III 150 III 300 S 2.882 Depressional III 150 III 150 T 0.70 Slope III 150 IV 50 Quarry 0.07 Depressional III 80 - - - - 1 Not Delineated (ND). Wetland off-site 2 On-site area only, wetland continues off-site to the nth degree BGE ENVIRONMENTAL, LLC NOVEMBER 10, 2020 BGE19_0170.030 NEW SHINE QUARRY FINAL DRAFT WETLAND MITIGATION PLAN APPENDIX B Declaration of Wetland Preservation Covenants 2102 Brashem Ave Bremerton, WA 98310 (360) 710-6066 www.bgeenvironmental.com BGE ENVIRONMENTAL, LLC. Wetland Consulting and Land Use Planning