HomeMy WebLinkAbout83 Pomona Woods 2022-09-26 Wet.land Response to Appellent Report CommentsWet.land, LLC 8201 164th Ave NE, Suite 200, PMB 141, Redmond, WA, 98052 206-309-8100
25 September 2022
Courtney Kaylor
REFERENCE: Pomona Woods (MLA21-0006, ZON21-00040)
SUBJECT: Appellant Report Comments
Dear Courtney:
Comments were provided by Diane Brewster of Touchstone EcoServices (TES) on 23 September
2022 for critical area comments related to the Pomona Woods project. Below are screenshots of
comments made by the appellant, followed by our responses.
TES Comment:
Wet.land response:
Given that this wetland occurred in the corner of the Site and understory vegetation was dense,
the offsite portions of this wetland were challenging to observe. We had to make assumptions
about the wetland, since we could only estimate boundaries and characteristics based on the
onsite component and what was visible offsite from our Project.
The prepared graphics clearly state the source of the contours as NOAA lidar. However, a land
surveyor would not be able to collect topographic data on an adjacent parcel, so again,
assumptions had to be made.
Exhibit 83
Exhibit 83 Page 1053
25 September 2022 PAGE 2
TES Comment:
Wet.land response:
A majority of this wetland did not occur onsite and thus was not available for direct review. We
observed no standing water in the offsite portions of the wetland that were visible from the Site.
The wetland was clearly located on a slope. However, the onsite portion did occur in a small
depressional area. The rating manual states that where a component is less than 10% of the total
wetland area, the dominant HGM class is used. However, given that assumptions had to be made
and to err on the side of caution, the wetland was rerated as a depressional wetland to
acknowledge that the wetland may be comprised of both slope and depressional components.
The rating and thus the buffer did not change. See additional responses below on other rating
elements.
TES Comment:
Wet.land response:
Question 1 above – Does the wetland discharge directly to a (waterbody) on the 303(d) water quality
list? – was answered correctly. Puget Sound is not treated as a single water body due to its size
and geometry. While the Site does discharge to Puget Sound within 1 mile, the portions of Puget
Sound that are listed as 303(d) waters are well beyond 1 mile from the Site. This question was
answered correctly. No change to rating forms.
Exhibit 83 Page 1054
25 September 2022 PAGE 3
Question 2 above – Is the wetland in a base(sic) or sub-basin where an aquatic resource is on the
303(d) list? – was reevaluated based on TES comments. This score was changed to “yes” with this
bumping the rating up by 1 point. There was no change to the wetland category or buffer. This
applies to all wetlands rated.
Question 3 above – Has the Site been identified in a watershed… (answer yes if there is a TMDL for
the basin…)? - Wet.land rating Figure C clearly shows that the wetlands located on the Pomona
Woods project are not located within a TMDL. The Puget Sound Nutrient Source Reduction Project
is not a TMDL. This question was answered correctly. No change to rating forms.
TES Comment:
Wet.land response:
Screen captures were not included from the Water Quality Atlas by Wet.land, however the most
recent GIS data from that same database was used to create the figures referenced in the CAR.
The source of the drawing in the bottom left corner is “WA DEPARTMENT OF ECOLOGY WATER
QUALITY ATLAS”.
Exhibit 83 Page 1055
25 September 2022 PAGE 4
TES includes several screenshots of waters listed on the 303(d) list, but many of them are not
directly downstream of the wetlands onsite.
TES Figure 1 depicts 303(d) listed waters in the vicinity of the Project.
TES Figure 2 identifies Listing ID 84150, which is 3.2 miles from the estimated wetlands (see
screen capture below). This is an inappropriate example of a 303(d) listed water within one mile of
the site.
TES Figure 3 identifies Listing ID 84152, which is 1.45 miles from the estimated wetlands (see
screen capture below). This is an inappropriate example of a 303(d) listed water within one mile of
the site.
Exhibit 83 Page 1056
25 September 2022 PAGE 5
TES Figure 4 identifies Listing ID 40319, which is 2.7 miles from the estimated wetlands (see
screen capture below). This is an inappropriate example of a 303(d) listed water within one mile of
the site.
TES Comment:
Wet.land response:
Below is the screenshot.
Exhibit 83 Page 1057
25 September 2022 PAGE 6
The figure label was incorrect, and the wetland rating was accurate. No further changes necessary
to S1.3. Vegetation was not greater than 90% in this wetland.
TES Comment:
Wet.land response:
The photo represents the onsite wetland condition, which does not represent over 90% of the
wetland as a whole. The wetland condition offsite did not include dense, uncut, rigid plants at
over 90% cover. Thus, this was not selected.
TES Comment:
Exhibit 83 Page 1058
25 September 2022 PAGE 7
Wet.land response:
Responses for these wetland revisions provided above and summarized below.
WETLAND A: No change to rating or buffer
Exhibit 83 Page 1059
25 September 2022 PAGE 8
WETLAND B: No change to rating or buffer
WETLAND D: No change to rating or buffer
WETLAND E: No change to rating or buffer
Exhibit 83 Page 1060
25 September 2022 PAGE 9
TES Comment:
Wet.land response:
No changes were made that changed the wetland ratings or the associated buffer widths.
TES Comment:
Wet.land response:
Noted.
Please don’t hesitate to contact me with any additional questions.
Sincerely,
Jennifer Marriott, PWS
Owner
Wet.land, LLC
Exhibit 83 Page 1061