Figure 24: View west of barn.

Figure 25: View north of concrete in foreground and barn and shed in background.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 37

Figure 26: View west of shed.

Figure 27: View south of shed.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 38

Figure 28: View east of cobble pile from nursery business.

Figure 29: View east of nursery warehouse.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 39

Figure 30: View west of nursery warehouse.

6.2 Subsurface Survey On May 21, 2020 ERCI archaeologists carried out a program of subsurface shovel testing that included 9 shovel tests (ST) placed judgmentally across the property, with a total of 1.05 cubic meters (m3) of sediment excavated. ST locations are shown on Figure 21. STs were not in the north half of the property due to facility buildings, concrete and piles of asphalt and concrete chunks. All STs were negative for archaeological resources.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 40

Figure 31: View south, ST 1 in foreground with creek and College Way in background.

Figure 32: View east of ERCI crew at ST 10.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 41

Figure 33: View south, overview of geotechnical test.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 42

Figure 34: Plan view, ST 5 profile, examples of M1 and M2.

Figure 35: Plan view, ST 7 profile, example of M4, M5, and M6.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 43

Figure 36: Plan view, ST 8 profile example of M1 and M3.

6.3 Discussion ERCI’s archaeological investigation for the HASC Family Housing Project encountered no cultural resources. Such surveys are intended to yield information about moderate-to-large buried cultural deposits, and are not intended to reveal the existence of isolated artifacts, small sites or features.

7.0 MANAGEMENT RECOMMENDATIONS No protected cultural resources were identified during our fieldwork. The management recommendations that we are now providing are based on our findings from this initial investigation. We recommend that: 1. The proposed project proceed as planned, following an unanticipated discovery protocol (UDP) training given to all construction personnel by a professional archaeologist. A copy of the Unanticipated Discoveries Protocol (UDP) to be on site at all times (Appendix 3). 2. In the event that any ground-disturbing activities or other project activities related to this development or in any future development uncover protected cultural material (e.g., bones, shell, stone or antler tools), all work in the immediate vicinity should stop, the area should be secured, and any equipment moved to a safe distance away from the location. The on- site superintendent should then follow the steps specified in the UDP (Appendix 3). 3. In the event that any ground-disturbing activities or other project activities related to this development or in any future development uncover human remains, all work in the immediate vicinity should stop, the area should be secured, and any equipment moved to a safe distance away from the location. The on-site superintendent should then follow the steps specified in the UDP (Appendix 3).

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ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 51 and Associates. On file at the Washington State Department of Archaeology and Historic Preservation, Olympia. Kopperl, Robert, Charles Hodges, Christian Miss, Johonna Shea, and Alicia Spooner 2016 Archaeology of King County, Washington: A Context Statement for Native American Archaeological Resources. SWCA Environmental Consultants, Seattle. Submitted to the King County, Washington, Historic Preservation Program. On file at Washington State Department of Archaeology and Historic Preservation, Olympia. Koziarski, Ralph 2011 State of Washington Archaeological Site Inventory Form (SK00445). On file at the Washington State Department of Archaeology and Historic Preservation, Olympia. Lane, Robert and Barbara Lane 1977 Indians and Indian Fisheries of the Skagit River System. Report prepared for the Skagit River System Cooperative, 11426 Moorage Way, La Conner, WA 98257-0368. A copy of the manuscript is on file at ERCI in Mount Vernon, Washington. Lewarch, Dennis E., Lynn L. Larson, Elizabeth C. Reetz, Nichole Gillis, Donald E. Tatum, Sarah L. Sterling, Gretchen A. Kaehler, Hayley E. Kanipe, Stephanie E. Trudel, Steven J. Greenawalt, and Katherine Vaughn 2005 Fieldwork Status Report, Data Recovery Excavation and Archaeological Construction Monitoring at the Tse-whit-zen Site (45CA523), Clallam County, Washington. Larson Anthropological Archaeological Services. Submitted to Washington State Department of Transportation, Olympic Region, Tumwater. On file at Washington State Department of Archaeology and Historic Preservation, Olympia. Mack, C.A., James C. Chatters, and Anna M. Prentiss 2010 Archaeological Data Recovery at the Beech Creek Site (45LE415), Gifford Pinchot National Forest, Washington. United States Department of Agriculture, Forest Service, Pacific Northwest Region, Heritage Program, Gifford Pinchot National Forest. On file at Washington State Department of Archaeology and Historic Preservation, Olympia. Mansfield, Emily 1993 Balance and Harmony: Peacemaking in Coast Salish Tribes of the Pacific Northwest. Meditation Quarterly 10(4):339–353. Matson, R.G. (editor) 1976 The Glenrose Cannery Site. Mercury Series, National Museum of Man, Archaeological Survey of Canada Paper No. 52. National Museums of Canada, Ottawa. 2010 The Crescent Beach Site and the Place of the Locarno Beach Phase. Laboratory of Archaeology, University of British Columbia. Electronic document, http://anth.sites.olt.ubc.ca/files/2013/05/FrontMatter.pdf, accessed July 22, 2016. Matson, R.G., and Gary Coupland 1995 The Prehistory of the Northwest Coast. Academic Press, San Diego. Matson, R.G., Gary Coupland, and Quentin Mackie (editors) 2003 Emerging from the Mist: Studies in Northwest Coast Culture History. Pacific Rim Archaeology. UBC Press, Vancouver and Toronto. Mattson, John L. 1971 A Contribution to Skagit Prehistory. Unpublished Master's thesis, Department of Anthropology, Washington State University. Pullman. 1989 Puget Sound prehistory: postglacial adaptations in the Puget Sound basin with archaeological implications for a solution to the "Cascade Problem." Ph.D. dissertation, University of North Carolina, Chapel Hill. U.M.I. Dissertation Information Service, Ann Arbor, Michigan. McLaren, Duncan, Daryl Fedje, Murray B. Hay, Quentin Mackie, Ian J. Walker, Dan H. Shugard, Jordan B.R. Eamerd, Olav B. Liane, and Christina Neudorf

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 52 2014 A post-glacial sea level hinge on the central Pacific coast of Canada. Quaternary Science Reviews 97:148–169. Meltzer, D.J. 2004 Peopling of North America. In The Quaternary Period in the United States, edited by A.R. Gillespie, S.C. Porter, and B.F. Atwater, pp. 505–563. Developments in Quaternary Science. Elsevier, Seattle, Washington. Meltzer, D.J., and R.C. Dunnell 1987 Fluted Points from the Pacific Northwest. Current Research in the Pleistocene 4:64-67. Metsker, Charles F. 1925 Metsker’s Atlas of Skagit County. Metsker, Tacoma, Washington. 1941 Metsker’s Atlas of Skagit County. Metsker, Tacoma, Washington. 1972 Metsker’s Atlas of Skagit County. Metsker, Tacoma, Washington. 1996 Metsker’s Atlas of Skagit County. Metsker, Tacoma, Washington. Mierendorf, Robert R., Franklin F. Foit, Jr., and Darby C. Stapp 2018 Holocene Geochronology and Archaeology at Cascade Pass, Northern Cascade Range, Washington. Journal of Northwest Anthropology Memoir 16. Northwest Anthropology LLC, Richland, Washington. Miller, Bruce G. 1993 The Press, the Boldt Decision, and Indian–White Relations. American Indian Culture and Research Journal 17(2):75–97. 1995 Folk Law and Contemporary Coast Salish Tribal Code. American Indian Culture and Research Journal 19(3):141–164. 1997 The “Really Real” Border and the Divided Salish Community. BC Studies No. 112:63–79. 1998 The Great Race of 1941: A Coast Salish Public Relations Coup. The Pacific Northwest Quarterly 89(3):127–135. 2001 The Problem of Justice: Tradition and Law in the Coast Salish World. University of Nebraska Press, Lincoln. Miller, Bruce G., and Daniel L. Boxberger 1994 Creating Chiefdoms: The Puget Sound Case. Ethnohistory 41:267–293. Mitchell, Donald H. 1971 Archaeology of the Gulf of Georgia Area, a Natural Region and its Culture Types. Syesis 4:1–228. 1990 Prehistory of the Coasts of Southern British Columbia and Northern Washington. In Northwest Coast, edited by W. Suttles, pp. 340–358. Handbook of North American Indians. vol. 7, W.C. Sturtevant, general editor. Smithsonian Institution, Washington, D.C. Mooney, Kathleen A. 1976 Urban and Reserve Coast Salish Employment: A Test of Two Approaches to the Indian’s Niche. Southwestern Journal of Anthropological Research 32:390–410. Moss, Madonna 1986 Native American Religious use in the Pacific Northwest: A Case Study from the Mt. Baker– Snoqualmie National Forest. Northwest Anthropological Research Notes 20:191–201. Moss, Madonna L., Dorothy M. Peteet, and Cathy Whitlock. 2007 Mid-Holocene culture and climate on the Northwest Coast of North America. In Climate change and cultural dynamics: a global perspective on mid-Holocene transitions, edited by David G. Anderson, Kirk A. Maasch, and Daniel H. Sandweiss, pp. 491–530. Academic Press, London. Mount Vernon Record 1897 Mount Vernon advertisements. October 7, 1897, Volume 4, Issue 48. Electronic document, http://www.skagitriverjournal.com/SCounty/Library/Newspapers/MV/MVRecord18971007.ht ml, accessed April 16, 2018. National Cooperative Soil Survey

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 53 2012 Skikopa Series. Electronic document, https://soilseries.sc.egov.usda.gov/OSD_Docs/S/SKIPOPA.html, accessed June 2019. 2000 Bellingham Series. Electronic document, https://soilseries.sc.egov.usda.gov/OSD_Docs/B/BELLINGHAM.html Nelson, Charles M. 1990 Prehistory of the Puget Sound Region. In Northwest Coast, edited by Wayne Suttles, pp. 481–484. Handbook of North American Indians, Vol. 7, William C. Sturtevant, general editor. Smithsonian Institution, Washington, D.C. Newcomb, Steven 2012 The 1887 Dawes Act: The U.S. Theft of 90 Million Acres of Indian Land. Electronic document, https://newsmaven.io/indiancountrytoday/archive/the-1887-dawes-act-the-u-s-theft- of-90-million-acres-of-indian-land-mhhCiBXdrU-pUbgWKwpOaQ/, accessed July 23, 2019. Northwestern University Library 2003 “Goat-hair Blanket—Cowichan,” by Edward S. Curtis. Electronic document, http://curtis.library.northwestern.edu/plates_curtis/ct09/ct09036r.jpg, accessed July 23, 2019. 2003 “Mat House—Skokomish,” by Edward S. Curtis. Electronic document, http://curtis.library.northwestern.edu/curtis/viewPage.cgi?showp=1&size=2&id=nai.09.port.00 000010.p&volume=9, accessed July 23, 2019. 2003 “Puget Sound Baskets,” by Edward S. Curtis. Electronic document, http://curtis.library.northwestern.edu/plates_curtis/cp09/cp09017r.jpg, accessed July 23, 2019. Oakley, Janet 2004 Skagit County—Thumbnail History. Electronic document, http://www.historylink.org/File/5663, accessed April 13, 2018. Pojar, Jim, and Andy MacKinnon 1994 Plants of the Pacific Northwest Coast. Lone Pine, Vancouver, British Columbia. Porter, Stephen C., and Terry W. Swanson 1998 Radiocarbon age constraints on rates of advance and retreat of the Puget Lobe of the Cordilleran ice sheet during the last glaciation. Quaternary Research 50:205–213. Pratt, Heather Lynn 1992 The Charles culture of the Gulf of Georgia: a re-evaluation of the culture and its three sub- phases. Master's thesis, Department of Anthropology, University of British Columbia. Prentiss, Anna Marie, and Ian Kuijt 2012 People of the Middle Fraser Canyon: An Archaeological History. University of British Columbia Press, Vancouver. Prentiss, William C., and Ian Kuijt (editors) 2004 Complex Hunter-Gatherer Evolution and Organization of Prehistoric Communities on the Plateau of Northwestern North America. University of Utah Press, Salt Lake City. Purchas, Samuel 1906 [1625] Hakluytus Posthumus or Purchas His Pilgrimes: Contayning a History of the World in Sea Voyages and Lande Tavells by Englishmen and others. Volume XIV. University of Glasgow Press, Glasgow, Scotland. Electronic document, https://archive.org/details/hakluytusposthu15purcgoog, accessed November 5, 2017. Riley, Carroll L. 1974 [1953] Ethnological Field Investigation and Analysis of Historical Material Relative to Group Distribution and Utilization of Natural Resources Among Puget Sound Indians. In Coast Salish and Western Washington Indians, Volume 2, edited by David Agee Horr, pp. 27–88. Garland, New York. Robbins, William G. 2019 Oregon Donation Land Act. Electronic document, https://oregonencyclopedia.org/articles/oregon_donation_land_act/#.WfIrQduZNTZ, accessed July 23, 2019.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 54 Roberts, Natalie 1975 A History of the Swinomish Indian Tribal Community. Ph.D. dissertation, Department of Anthropology, University of Washington, Seattle. Rooke, Lara C., and Michelle M. Hannum 2000 Cultural Resource Assessment of Portions of East College Way, Mount Vernon, Skagit County, Washington. Hemisphere Field Services. Submitted to Transpec Engineering. On file at the Washington State Department of Archaeology and Historic Preservation, Olympia. Ruby, Robert H., and John A. Brown 1986 A Guide to the Indian Tribes of the Pacific Northwest. University of Oklahoma Press. Norman. Sampson, Chief Martin J. 1972 Indians of Skagit County. Skagit County Historical Society, La Conner, Washington. Shantry, Kate 2007 State of Washington Archaeological Site Inventory Form for 45SK468, English Lumber Company Logging Railroad. On file, Washington State Department of Archaeology and Historic Preservation Sherrod, B.L., R.C. Bucknam, and E.B. Leopold 2000 Holocene relative sea level changes along the Seattle Fault at Restoration Point, Washington. Quaternary Research 54:384–393. Smith, Harlan I. 1900 Archaeological Investigations on the North Pacific Coast in 1899. American Anthropologist 3:563–567. 1907 Archaeology of the Gulf of Georgia and Puget Sound. American Museum of Natural History Memoir 4, Part 6, pp. 301–441. American Museum of Natural History, New York. Smith, Harlan I., and Gerald Fowkes 1901 Cairns of B.C. and Washington. American Museum of Natural History Memoir 4, Part 2, pp. 55–755. American Museum of Natural History, New York. Smith, Marian 1941 The Coast Salish of Puget Sound. American Anthropologist 43:197–211. 1950 The Nooksack, the Chilliwack, and the Middle Fraser. Pacific Northwest Quarterly 41:330– 341. 1956 The Cultural Development of the Northwest Coast. Southwestern Journal of Anthropological Research 12:272–294. Snyder, Sally 1954 Aboriginal Saltwater Fisheries: Swinomish, Lower Skagit, Kikialus, and Samish Tribes of Indians. Master's thesis, Department of Sociology and Anthropology, University of Windsor, Ontario. 1964 Skagit Society and its Existential Basis: An Ethnofolkloric Reconstruction. Unpublished Ph.D. dissertation, University of Washington, Seattle, Washington. 1980 Aboriginal Settlements in the Skagit Drainage System. In Cultural Resource Overview and Sample Survey of the Skagit Wild and Scenic River Study Area on the Mt. Baker–Snoqualmie National Forest, Washington State, Volume 2, by Astrida R. Blukis Onat, Lee A. Bennett, and Jan L. Hollenbeck, pp. 19–39. Prepared for the Mt. Baker–Snoqualmie National Forest by the Institute of Cooperative Research. On file at the Washington State Department of Archaeology and Historic Preservation, Olympia. 1981 Swinomish, Upper Skagit and Sauk-Suiattle. In Inventory of Native American Religious Use, Practices, Localities and Resources: Study Area on the Mt. Baker–Snoqualmie National Forest, Washington State, edited by Astrida R. Blukis Onat and Jan L. Hollenbeck, pp. 213– 308. Report prepared for Mt. Baker–Snoqualmie National Forest, Seattle, Washington. Institute of Cooperative Research, P.O. Box 20275, Broadway Station, Seattle, Washington 98102. Soil Survey Staff, Natural Resources Conservation Service, United States Department of Agriculture

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 55 2019 Web Soil Survey—Skagit County Area. Electronic document, http://websoilsurvey.nrcs.usda.gov, accessed June 2019 Spier, Leslie 1935 The Prophet Dance of the Northwest and its Derivatives: The Source of the Ghost Dance. George Banta, Menasha, Wisconsin. 1936 Tribal Distribution in Washington. General Series in Anthropology 3. George Banta, Menasha, Wisconsin. Stauss, Joseph H. 2002 The Jamestown S’Klallam Story: Rebuilding a Northwest Coast Indian Tribe. Jamestown S’Klallam, Sequim, Washington. Stein, J. K. 1984 Interpreting the Stratigraphy of Northwest Coast Shell Middens. Tebiwa 2:26–34. 2000 Exploring Coast Salish Prehistory: The Archaeology of San Juan Island. Burke Museum of Natural History and Culture, University of Washington Press, Seattle. Stern, Bernhard J. 1934 The Lummi Indians of Northwest Washington. Columbia University Press, Morningside Heights, New York. Stewart, Hilary 1973 Artifacts of the Northwest Coast Indians. Hancock House, Surrey, British Columbia. 1977 Indian Fishing: Early Methods on the Northwest Coast. Douglas & McIntyre, Vancouver. 1979 Looking at Indian Art of the Northwest Coast. Douglas & McIntyre, Vancouver. 1984 Cedar: Tree of Life to the Northwest Coast Indians. University of Washington Press, Seattle. 1996 Stone, Bone, Antler & Shell: Artifacts of the Northwest Coast. 2nd ed. Douglas & McIntyre, Vancouver. Suttles, Wayne 1957 The Plateau Prophet Dance Among the Coast Salish. Southwestern Journal of Anthropology 13(4):352–396. 1958 Private Knowledge, Morality, and Social Classes among the Coast Salish. American Anthropologist 60:497–507. 1960 Affinal Ties, Subsistence, and Prestige among the Coast Salish. American Anthropologist 62:296–305. 1974 [1951] Coast Salish and Western Washington Indians I: Economic Life of the Coast Salish of Haro and Rosario Straits. [PhD dissertation, Department of Anthropology, University of Washington, Seattle.] Garland, New York. 1987 Coast Salish Essays. University of Washington Press, Seattle. 1990a Central Coast Salish. In Northwest Coast, edited by Wayne Suttles, pp. 453–475. Handbook of North American Indians, Volume 7. Smithsonian Institution, Washington, D.C. 1990b Northwest Coast. Handbook of North American Indians. No.7. Smithsonian Institution, Washington, D.C. Suttles, Wayne, and Barbara Lane 1990 Southern Coast Salish. In Northwest Coast, edited by Wayne Suttles, pp. 485–502. Handbook of North American Indians, Volume 7. Smithsonian Institution, Washington, D.C. Taylor, Amanda K., Julie K. Stein, Stephanie A.E. Jolivette 2011 Big Sites, Small Sites, and Coastal Settlement Patterns in the San Juan Islands, Washington, USA. Journal of Island and Coastal Archaeology 6:287–313. Taylor, Herbert C., Jr. 1953 Anthropological Investigation of the Medicine Creek Tribes Relative to Tribal Identity and Aboriginal Possession of Lands. In Coast Salish and Western Washington Indians Volume 2, pp. 401–474. Garland, New York. 1960 The Fort Nisqually Census of 1838-1839. Ethnohistory Vol 7, No. 4.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 56 1984 Mollusks, Western Washington Indians, and the Steven’s Treaties of 1854–1856. George Banta, Menasha, Wisconsin. Thomas/Lane & Associates & Bill Mundy and Associates 2014 A Draft Report Analyzing Skagit County’s AgroIndustrial Cluster. Thompson, Dennis B. 1989 Logging Railroads in Skagit County. Northwest Short Line. Seattle, Washington. Thorson, Robert M. 1980 Ice-sheet Glaciation of the Puget Lowland, Washington, During the Vashon Stade (late Pleistocene). Quaternary Research 13:303–312. 1989 Glacio-isostatic Response of the Puget Sound Area, Washington. Geological Society of America Bulletin 101:1163–1174. Tollefson, Kenneth D. 1987 The Snoqualmie: A Puget Sound Chiefdom. Ethnology 26(2):121–136. 1989 Political Organization of the Duwamish. Ethnology 28:135–50. 1992a Cultural Survival of the Snoqualmie Tribe. American Indian Culture and Research Journal 16(4):29–53. 1992b The Political Survival of Landless Puget Sound Indians. American Indian Quarterly 16: 213–35. 1996 In Defense of a Snoqualmie Political Chiefdom Model. Ethnohistory 43:145–72. Tollefson, Kenneth, and Martin Abbott 1993 From Fish Weir to Waterfall. American Indian Quarterly 17:209–25. 1998 Snoqualmie Ethnicity. American Indian Quarterly 22:415–31. Tollefson, Kenneth, Martin Abbott, and Eugene Wiggins 1996 Tribal Estates: A Comparative and Case Study. Ethnology 35:321–38. Tremaine, D.G. 1975 Indian and Pioneer Settlement of the Nooksack Lowland, Washington to 1890. Occasional Paper #4, Center for Pacific Studies, Western Washington State College, Bellingham. Turner, Nancy J. 1995 Food Plants of Coastal First Peoples. Royal British Columbia Museum Handbook. Victoria, British Columbia. Tweddell, Collin Ellidge 1974 [1953] A Historical and Ethnological Study of the Snohomish Indian People: A Report Covering Their Aboriginal and Continued Existence and Their Effective Occupation of a Definable Territory. In Coast Salish and Western Washington Indians, Volume 2, edited by David Agee Horr, pp. 475–694. Garland, New York. United States 1859 Treaty between the United States and the Dwámish, Suquámish, and other allied and subordinate Tribes of Indians in Washington Territory. Concluded at Point Elliott, Washington Territory, January 22, 1855, ratified by the Senate, March 8, 1859. Proclaimed by the President of the United States, April 11, 1859. United States Statutes at Large, Treaties, and Proclamations of the United States of America XII:927. United States Court of Claims 1933 The Duwamish, Lummi, Whidbey Island, Skagit, upper Skagit, Swinomish, Kikiallus, Snohomish, Snoqualmie, Stillaguamish, Suquamish, Samish, Puyallup, Squaxin, Skokomish, upper Chehalis, Muckleshoot, Nooksack, Chinook and San Juan Islands tribes of Indians, claimants, vs. the United States of America, defendant. No. F-275. Argus Press, Seattle. Vance-Sherman, Anneliese 2015 Skagit County Profile. Washington State Employment Security Office. Electronic document, https://fortress.wa.gov/esd/employmentdata/reports-publications/regional- reports/county-profiles/skagit-county-profile, accessed April 16, 2018. Waterman, T.T.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 57 1920 Puget Sound Geography. Microform of manuscript on file, Suzzallo Library, Microfilm A3435. University of Washington, Seattle. Waterman, T.T., Hilbert, Vi, J. Miller, and Zalmai Zahir (editors) 2001 Puget Sound Geography. Original manuscript from T.T. Waterman [1921]; edited with additional material from Vi Hilbert, Jay Miller, and Zalmai Zahir. Lushootseed Press, Federal Way, Washington. Waters, Michael R., Thomas W. Stafford Jr., H. Gregory McDonald, Carl Gustafson, Morten Rasmussen, Enrico Cappellini, Jesper V. Olsen, Damian Szklarczyk, Lars Juhl Jensen, M. Thomas P. Gilbert, and Eske Willerslev. 2011 Pre-Clovis Mastodon Hunting 13,800 Years Ago at the Manis Site, Washington. Science 334(6054):351–353. Wessen, Gary C. 1988 Prehistoric Cultural Resources of Island County, Washington. On file with Washington State Department of Archaeology and Historic Preservation, Olympia. 1989 A Report of Archaeological testing at the Dupont Southwest Site (45-PI-72), Pierce County, Washington. Western Heritage, Olympia, Washington. Submitted to Weyerhaeuser Real Estate Company Land Management Division Tacoma, Washington. On file at the Washington State Department of Archaeology and Historic Preservation, Olympia. White, William S. 2013 National Register of Historic Places Nomination Form (45CA523). On file at the Washington State Department of Archaeology and Historic Preservation, Olympia. Willis, Margaret 1973 Chechacos All: The Pioneering of Skagit. Skagit County Historical Series No. 3, Skagit County Historical Society, Mount Vernon, Washington. 1975 Skagit Settlers: Trials and Triumphs, 1890-1920. Skagit County Historical Series No. 4, Skagit County Historical Society, Mount Vernon, Washington. Wray, Jacilee (editor) 2002 Native Peoples of the Olympic Peninsula: Who We Are. University of Oklahoma Press, Norman. 2012 From the Hands of a Weaver: Olympic Peninsula Basketry through Time. University of Oklahoma Press, Norman.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 58 9.0 APPENDICES Appendix 1: Shovel Test Descriptions, Particle Size Classes and Matrix Descriptions Particle Size Classes Scale Clay Silt Sand Gravel Pebble Cobble Boulder in <.00015 .00015–.0025 .0025–.08 .08–1 1–4 4–10 >10 mm <.004 .004–.062 .062–2 2–25.4 25.4–102 102–254 >254

Matrix Descriptions Matrix 1: 7.5 YR 2.5/2 gray dark brown, 80% silt, 5% gravels, 15% roots, damp, disturbed local fill Matrix 2: 5 YR 4/1-5/1 dark gray to gray, 20% silt, 30% coarse sand, 30% gravels, 20% rounded to sub rounded pebbles, wet local fill Matrix 3: 10 YR 4/4 dark yellowish brown, 90% silty fine sand, 5% gravels, 5% pebbles, dry- intact glacial outwash Matrix 4: 100% coarse sand fill (imported) Matrix 5: 40% coarse sand, 60% angular gravels (crushed), imported gravel fill Matrix 6: Wood debris- bark and chips- imported debris

Shovel Test Descriptions ST Depth Dia Matrix Description Comments (cm) (cm)

1 70 40 0-36: M1 – red rope @ ~30cm dbs Negative 36-70: M2 – green glass fragment at superior interface, ~36cm dbs Terminate: Water table 2 86 53 0-58: M1- small amount of trash throughout Negative 58-86: M2- water table at base ~80cm dbs Terminate: Water table 3 69 40 0-40: M1- saw cut bone @~10-20cm dbs- Negative non human per A. Rollins. 40-55: M1+M3 Terminate: Glacial 55-69: M3 blueish gray with depth 4 97 51 0-61: M1- less pebbles and gravels than Negative previous M1 profiles 61-97: M2- less pebbles and gravels Terminate: Water compared to previous M2 profile also more table silt than sand compared to previous.

*water table at approx. 90cm dbs 5 61 41 0-16: M1 many roots Negative 16-61: M2 39 – 61 M3 Terminate: water table 6 33 57 0-33: M1- minimal pebbles or gravels, Negative large root obstructing base of hole Terminate: root obstruction

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 59 ST Depth Dia Matrix Description Comments (cm) (cm) 7 37 42 0-6: M4 coarse sand fill Negative 6-21: M5 sand and crushed gravel fill 21-29: M6 wood debris and decomposing Terminate: wood chips/bark Compaction 29-37: M5 dense compaction, sand and gravel fill, few pebbles 8 100 46 0-50: M1- disturbed with minimal gravels Negative or pebbles 50-100: M3- dense compaction silt with Terminate: 1m bluish sand toward base- minimal gravels reached or pebbles 9 63 45 0-37: M1 Negative 37-52: M1mixed with M3 52-63: M3 Terminate: glacial

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 60 Appendix 2: Photograph Log Number View Description 200522JQW001 S ST2 without scale 200522JQW002 S ST2 with scale 200522JQW003 SW ST2 overview 200522JQW004 S ST2 mesh area 200522JQW005 N ST2 mesh area 200522JQW006 SW ST4 without scale 200522JQW007 SW ST4 with scale 200522JQW008 SW ST4 overview 200522JQW009 NW ST4 overview with creek 200522JQW010 S DELETE 200522JQW011 S ST6 with scale 200522JQW012 E ST6 root 200522JQW013 W ST6 overview 200522JQW014 S ST6 without scale 200522JQW015 W ST8 without scale 200522JQW016 W ST8 with scale 200522JQW017 SE ST8 overview 200522JQW018 SE ST8 overview 200522JQW019 - Geotech test 200522JQW020 - Geotech test 200522JQW021 S Geotech test 200522JQW022 E ST9 without scale 200522JQW023 E ST9 with scale 200522JQW024 E ST9 overview 200522CMS001 P Binder 200522CMS002 S ST1 with scale 200522CMS003 S ST1 with scale 200522CMS004 S ST1 without scale 200522CMS005 S ST1 overview shows creek and college way 200522CMS006 NE ERCI at ST2 and creek 200522CMS007 N Overview- willow trees and ST1 on right 200522CMS008 P Black tarp 200522CMS009 P Black tarp 200522CMS010 N Black tarp near ST1 shows willow 200522CMS011 E Black tarp near ST3 shows willow 200522CMS012 P Saw cut bone from ST3 200522CMS013 P Saw cut bone from ST3 200522CMS014 P Saw cut bone from ST3 200522CMS015 P Saw cut bone from ST3

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 61 Number View Description 200522CMS016 P Saw cut bone from ST3 200522CMS017 P Saw cut bone from ST3 200522CMS018 P Saw cut bone from ST3 200522CMS019 P Saw cut bone from ST3 200522CMS020 P Saw cut bone from ST3 200522CMS021 P Saw cut bone from ST3 200522CMS022 P Saw cut bone from ST3 200522CMS023 P Saw cut bone from ST3 200522CMS024 P Saw cut bone from ST3 200522CMS025 P Saw cut bone from ST3 200522CMS026 P Saw cut bone from ST3 200522CMS027 P Saw cut bone from ST3 200522CMS028 P Saw cut bone from ST3 200522CMS029 P Saw cut bone from ST3 200522CMS030 P Saw cut bone from ST3 200522CMS031 P Saw cut bone from ST3 200522CMS032 P Saw cut bone from ST3 200522CMS033 P Saw cut bone from ST3 200522CMS034 P Saw cut bone from ST3 200522CMS035 P Saw cut bone from ST3 200522CMS036 P Saw cut bone from ST3 200522CMS037 P Saw cut bone from ST3 200522CMS038 P volcanic rock from ST3 200522CMS039 P volcanic rock from ST3 200522CMS040 P volcanic rock from ST3 200522CMS041 NW ST3 with scale 200522CMS042 NW ST3 without scale 200522CMS043 NW ST3 without scale 200522CMS044 W ST3 overview taken from ST2 200522CMS045 SE ST 3 overview 200522CMS046 S ST5 with scale 200522CMS047 S ST5 without scale 200522CMS048 NE ST3 overview shows sign 200522CMS049 E Overview "Deciduous trees and shrubs" sign and bridge over creek 200522CMS050 S ST7 with scale 200522CMS051 S ST7 without scale 200522CMS052 SE ST7 overview 200522CMS053 SE ST7 overview pond 200522CMS054 SE ST7 overview pond 200522CMS055 N Concrete slab (barn and shed in background)

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 62 Number View Description 200522CMS056 W Shed 200522CMS057 S Shed 200522CMS058 E Shed 200522CMS059 N Shed 200522CMS060 E Rock pile container (cobbles) 200522CMS061 E Rock pile container (boulders) 200522CMS062 W Barn 200522CMS063 N Barn 200522CMS064 E Barn 200522CMS065 S Barn 200522CMS066 N Concrete N of barn and N fenceline 200522CMS067 S Long outbuilding 200522CMS068 W Long outbuilding 200522CMS069 W Long outbuilding 200522CMS070 N Long outbuilding 200522CMS071 E Long outbuilding 200522CMS072 E Long outbuilding 200522CMS073 E ERCI at ST10 200522CMS074 S Entrance and parking lot

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 63 Appendix 3: Unanticipated Discovery Protocol In the event that any ground-disturbing activities or other project activities related to this development or any future development uncover protected cultural material (see below), the following actions should be taken: 1. If the cultural material is a historic or precontact object (glass bottle, tin can, stone, bone, horn or antler tool); a historic or precontact feature (hearth, building foundation, privy), then the on- site supervisor should avoid the object, secure the location and relocate work activities to a different part of the Project area. The Project manager should then call a professional archaeologist to evaluate the discovery. 2. If ground disturbing activities encounter human skeletal remains during the course of construction, then all activity will cease that may cause further disturbance to those remains. The area of the find will be secured and protected from further disturbance. The finding of human skeletal remains will be reported to the Skagit County Coroner (360-416-1996) and Mount Vernon Police (360-336-6271) in the most expeditious manner possible. The remains will not be touched, moved, or further disturbed. The county medical examiner/coroner will assume jurisdiction over the human skeletal remains and make a determination of whether those remains are forensic or non-forensic. If the county medical examiner/coroner determines the remains are non-forensic, then they will report that finding to the Department of Archaeology and Historic Preservation (DAHP) who will then take jurisdiction over the remains. The DAHP will notify any appropriate cemeteries and all affected tribes of the find. The State Physical Anthropologist, Dr. Guy Tasa (360-586-3534), will make a determination of whether the remains are Indian or Non-Indian and report that finding to any appropriate cemeteries and the affected tribes. The DAHP will then handle all consultation with the affected parties as to the future preservation, excavation, and disposition of the remains. Cultural material that may be protected by law could include but is not limited to: • Logging, mining, railroad, or agriculture equipment older than 50 years • Historic bottles, china and soldered dot cans (Figure 37, Figure 38) • Buried cobbles that may indicate a hearth feature (Figure 39) • Non-natural sediment or stone deposits that may be related to activity areas of people • Stone tools or stone flakes, projectile points (arrowheads), ground stone adzes or grinding stones (abraders) (Figure 40–Figure 43) • Bone, shell, horn, or antler tools that may include scrapers, cutting tools, wood working wedges (Figure 44, Figure 45) • Human remains

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 64

Figure 37: Example of historic glass artifacts for UDP.

Figure 38: Example of historic solder dot can for UDP

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 65

Figure 39: Example of protected rock-lined hearth feature for UDP.

Figure 40: Example of projectile point for UDP.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 66

Figure 41: Example of protected adze blade for UDP.

Figure 42: Example of stone tool for UDP.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 67

Figure 43: Example of stone tool for UDP.

Figure 44: Example of bone awl for UDP.

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 68

Figure 45: Example of worked bone, and spines for UDP. CONTACT LIST Housing Authority of 360-428-1959 Melanie Corey [email protected] Skagit County ext. 212 Mount Vernon Police Mount Vernon 360-336-6271 [email protected] Coroner Skagit County 360-416-1996 [email protected] Jackie Ferry Samish Indian Nation 360-770-7784 [email protected] Swinomish Indian Tribal Josephine Jefferson 360-466-7352 [email protected] Community Scott Schuyler Upper Skagit Indian Tribe 360-982-8218 [email protected] DAHP, State Robert Whitlam PhD 360-586-3080 [email protected] Archaeologist DAHP, State Physical Guy Tasa PhD 360-586-3534 [email protected] Anthropologist Kelly Bush Archaeologist (ERCI) 360-661-0356 [email protected]

ERCI—Housing Authority of Skagit County, East College Way Parcels P113507 and P24832, Mount Vernon 69 MEMORANDUM

DATE February 26, 2021 TO Melanie Corey, Executive Director for the Housing Authority of Skagit County FROM Jackalyn Kandle, Fulcrum Environmental Consulting, Inc. RE National Environmental Policy Act Environmental Assessment – Noise Summary SUBJECT 4100 East College Way, Mount Vernon, Washington

The Housing Authority of Skagit County (HASC) intends to develop 51-units of affordable residential housing on two parcels located at 4100 East College Way in Mount Vernon, Washington (site or project site). See Figure 1 for general site location. The HASC Family Housing project is for low-income farmworkers, homeless veterans, people with disabilities and their families in need. The completed project will receive a portion of funding from the United States Department of Housing and Urban Development (HUD). Prior to project funding approval, an evaluation of the noise characteristics based on The Noise Guidebook is necessary to meet the HUD requirements.

Fulcrum Environmental Consulting, Inc. (Fulcrum) has prepared this noise summary to evaluate the estimated noise characteristics of the HASC Family Housing project based on current site plan drawings and determine if additional noise attenuation may be required to meet the HUD noise standards for residential housing.

1.0 Background

According to the HUD guidelines associated with the Noise Control Act of 1972, and the Quiet Communities Act of 1978 as amended, average sound level measurements for noise sensitive uses are applicable to residential settings, or quiet sensitive commercial uses such as hospital or libraries. The proposed HASC Family Housing project is considered a noise sensitive use. As described in the HUD guidelines the average sound level values are to be achieved in the interior noise sensitive use building spaces, not necessarily at the generating source. The HUD guidelines state that an exterior day/night average sound level (DNL) of 65 decibel (dB) or less is normally acceptable for noise sensitive use and that standard construction is assumed to provide an average of 20 dB of noise attenuation. Sound levels that are more than 65 dB but less than 75 dB are considered by HUD to be normally unacceptable and require some form of attenuation to reduce sound levels to below 65 dB for quiet outdoor spaces. While HUD does not have a standard for interior noise levels, they have set a goal of achieving 45 dB for indoor living spaces.

2.0 Outdoor Noise Sources

The primary focus of a noise study is the identification of noise sources and the noise levels they create. Consistent with the HUD Noise Assessment Guidelines, this study considered all significant roads within 1,000 feet (ft), railroads within 3,000 ft, and military or civilian airports within 15 miles of the project site.

HASC Family Housing 1 Noise Summary 2.1 Busy Roads or Highways within 1,000 Feet

East College Way, also known as State Route 538, is within 1,000 ft of the site and meets the HUD definition of a busy street. East College Way forms the adjacent southern boundary of the site and extends east to west. The closest intersection to the site is North Waugh Road located approximately 1,041 ft west of the proposed site buildings. See Attachment A for Google Earth images showing the distance from the proposed site buildings to various Outdoor Noise Sources.

No stop signs are present on East College Way within 1,000 ft of proposed project.

The Washington State Department of Transportation (WSDOT) Annual Average Daily Traffic (AADT) Counts provide the 24-hour count for both directions of traffic. The WSDOT AADT east of the intersection of East College Way and North Waugh consisted of 9,400 for 2019 and did not segregate or estimate the number of cars, medium trucks or heavy trucks. The WSDOT segregation of vehicle type at this monitoring location was last completed in 2002 and reported 3.98 percent (%) Single Unit Trucks, 0.96% Double Unit Trucks, and 0.62% Triple Unit Trucks. For purposes of the noise assessment, Single Unit Trucks were considered Medium Trucks, and Double and Triple Unit Trucks were considered Heavy Trucks. See Attachment B for excerpts from the WSDOT traffic counts east of the intersection of East College Way and North Waugh.

The City of Mount Vernon produced a 2013 traffic study from Idax which provided a Two-Hour Count Summary from the intersection of East College Way and North Waugh Road, and segregated the number of heavy trucks. The percent of heavy trucks were recorded as about 1.50% of the total traffic counts. This value is approximately the same as the 1.58% combined WSDOT percentage for Double and Triple Unit Trucks recorded in 2002, suggesting that the percentage of heavy truck traffic has remained relatively constant between 2002 and 2013. See Attachment B for the city of Mount Vernon two-hour traffic count summary at the Waugh College Way intersection.

The HASC tenants may own vehicles that will travel along East College Way and contribute to the traffic counts. However, some of these individuals may elect to carpool, or travel to and from the site using the Skagit Transit City of Mount Vernon public bus service. Skagit Transit currently provides service with regular stops located immediately adjacent the project on East College Way to the west and along North Waugh Road.

The HASC Family Housing project identifies a minimum of 2 parking spaces per residential unit, for a total of 100 residential parking spaces with 6 identified as handicap parking spaces. An additional 17 parking spaces are allotted for ancillary parking, visitors, maintenance staff, etc., bringing the total number of parking spaces at the complex to 117. See Figure 2 for design site plan drawing and subsequent parking space locations.

For purposes of cumulative effect evaluation, each of the 117 parking spaces was assumed to contribute to an equivalent potential increase in traffic counts, resulting in a potential for about 117 additional persons to travel along East College Way and indirectly contribute to noise. At two trips per day per individual this

HASC Family Housing 2 Noise Summary equates to an increase of 234 average daily trips (ADT). This number of ADT may be less if some adults utilize alternative means of transportation, like carpooling, or riding the readily available public transit.

The Skagit County population is expected to increase by approximately 1% annually, as is consistent with the trend for the past approximate 5 years. The WSDOT AADT east of the intersection of East College Way and North Waugh was a total of 9,400 for 2019. Anticipating a 1% annual growth in ADT, the 2021 ADT is anticipated to be 9,589. As the project may result in an increase in an additional 234 ADT, Fulcrum adjusted the estimated 2021 ADT to 9823 to reflect the cumulative effect of the project. Additionally, the 10-year projection assumed a 1% growth rate and resulted in an estimated 2031 ADT of 10,851.

For purposes of DNL calculations, the HUD medium truck value was assessed using the 2002 WSDOT value of 3.98% for Single Unit trucks. The HUD heavy truck value was assessed using the combined 2002 WSDOT values for Double and Triple Unit trucks of 0.96 and 0.62 percent (1.58 percent total).

2.2 Railroads within 3,000 Feet

There are no rail lines located within 3,000 ft of the site. The closest railroad is owned by Mount Vernon Terminal Railway and is located approximately 10,228 ft west of the site. There is no direct line of site between the subject site and the rail line. The 2018 US Department of Transportation (DOT) Washington State Rail System by Owner indicates an additional rail line located directly north of the site approximately 19,035 ft and is owned by BNSF. There is no direct line of site between the subject site and the rail line.

Railroads are not expected to be a contributor to the noise characteristics of the property based on separation distances from the site to the railway systems. See Attachment A for Google Earth images showing the distance between the proposed project and the Mount Vernon Terminal Railway and BNSF Railway.

2.3 Civil or Military Airfields within 15 Miles

There is one civil and no military airfields located within 15 miles of the site. The Skagit Regional Airport is located approximately 33,207 ft (6.29 miles) to the northwest of the site. The Whidbey Island Naval Air Station is located approximately 97,026 ft (18.38 miles) southwest of the proposed project. See Attachment A for Google Earth images showing the distances between the proposed project and the two airports.

Skagit Regional Airport is within the 15 miles of the site location of 4100 East College Way in Mount Vernon and is approximately 6.29 miles by air. All other military air bases are greater than the indicated distance of 15 miles and were not included as a noise generator.

The Skagit Regional Airport provides daily flights from Mount Vernon to major airports including but not limited to Spokane, Seattle, and Burlington within Washington State and Denver, Colorado utilizing Single- Engine Piston, Multi-Engine Piston, Turboprop, Jet, and Helicopter aircrafts. Total aircraft operations totaled 32,094 in 2016 and have increased since 2013 from 23,823 total aircraft operations.

HASC Family Housing 3 Noise Summary The Skagit Regional Airport Master Plan Update, dated September 2007 Integrated Noise Model (INM) was reviewed under Chapter 5 Environmental Review. Noise contours were described and assessed surrounding the airport for 55, 60, 65, 70, and 75 DNL and were projected for the year of 2025. See Figures 5-1 to 5-3 under Attachment C for the years of 2004, 2010, and 2025 noise contours. The DNL noise contours for 2025 have expanded slightly in comparison to 2010 and 2004 maps but appear to remain on airport property.

The projected 2025 noise contours were used for the purposes of this noise summary. The shortest distance (D2) from the NAL to the flight path is approximately 33,207 ft. The measured distance (D1) from the flight path to the 65 dB contours is approximately 300 ft. The D2 to D1 ratio is 110.69 which would correspond to an estimated air-craft noise exposure level of 25 dB at the proposed project. See Attachment C for a copy HUD Chapter 5 Table 2 Extended Aircraft Noise Ration curve.

3.0 2019 Site Plan Drawings – Noise Assessment Locations

New construction of 51 new affordable housing units organized into five residential buildings, an onsite manager’s building, and central play area for children is planned by the HASC. The residential buildings are multi-leveled located in the north center and north east side of the property with parking and driveway constructed nearby to service each resident. The play area is in the center of the west group of residential units where high visibility is available. Additionally, a footbridge to the southeast that crosses College Way Creek, provides access to a walking trail on the southeast portion of the property.

Fulcrum reviewed the Market Study Report, dated September 17, 2019 site plan drawings for the HASC Family Housing and Environmental Works Community Design Center, August 4, 2020 and identified two noise assessment locations (NALs) as being representative of the potential noise sensitive indoor and outdoor site uses. See Figure 2 for the selected NAL locations.

3.1 Identification of Indoor Noise Sensitive Use

Buildings F is the closest structure to East College Way, the primary identified noise source. The residential units are subject to indoor noise sensitive uses and was selected as NAL #1. The south wall of apartment building F is facing directly towards East College Way. Interior building designs include double pane vinyl framed windows on all building walls, and city development setback standards of 25 ft from arterial streets are exceeded within development plans. The south wall of building F is about 260 ft from the center of East College Way. Additionally, a vegetative buffer occurs within the southeast portion of the site, surrounding College Way Creek, which places a break in the line of site from nearly all of the buildings and noise generated from the roadway daily usage.

3.2 Identification of Outdoor Noise Sensitive Uses

The units are multi-story flats in a garden style walk-up design with the play area surrounded by the center most buildings A and C. There are outdoor patio spaces included within the project design facing towards

HASC Family Housing 4 Noise Summary the east and west on varying residential buildings. There are no residential patios facing south towards East College Way. There are no outdoor patio spaces between building F and East College Way.

There is a walking path that loops between East College Way and the planned residential buildings south of College Way creek in the southeast portion of the site. The walking path located on the southeast portion of the site is the closest outdoor recreational site use to East College Way. There are no benches, picnic tables or other features planned in the southeast portion of the site that would encourage an outdoor community gathering area, however, it is a potential quiet outdoor recreational use area and was there selected as NAL #2.

The southern boundary walking path is approximately 107 ft from the centerline of East College Way. The walking path is the only outdoor potential gathering location identified on the Environmental Works Community Design Center, August 4, 2020 that has a direct line of site to East College Way.

3.3 Selected Noise Assessment Locations

Two different NALs were evaluated to define the noise levels at the property. NAL #1 is an area between East College Way and the single-level managers building F. NAL #2 is an area between East College Way and the southeast walking path. The final selected NAL point was measured from a location approximately 6.5 ft south of the south facing building wall or walking path. See Figure 2 for the NAL locations.

4.0 Day and Night Noise Level Calculation

The Day/Night Noise Level Calculator Electronic Assessment Tool (DNL Calculator) available through the HUD Exchange https://www.hudexchange.info/programs/environmental-review/dnl-calculator/, was used to predict the outdoor DNL average sound in dB at the predicted noise assessment locations. See Figure 2 for the for the NAL locations. See Attachment A for distances between the various noise sources.

4.1 NAL #1 – South Facing Wall of Building F

A location adjacent to the south wall of building F faces East College Way and was selected as NAL#1. The distance from the building’s southernmost wall to East College Way is approximately 260 ft. Consistent with HUD guidelines, the NAL was located 6.5 ft from the building, resulting in a distance between the NAL#1 and East College Way of 253.5 ft. A rounded distance of 253 ft was used in the DNL Calculator as input is limited to whole numbers.

The distance to NAL#1 was entered into the DNL Calculator, along with the ADT estimates for 2021 and 2031, and estimated 2025 airport noise. The resultant predicted noise level at NAL #1 from the combination of East College Way and Skagit Regional Airport was 59 dB both for 2021 and for 2031. See Attachment D for a copy of the DNL Calculator results for NAL #1 building F. This DNL is within the normally acceptable range established by HUD for noise sensitive use and will not require additional evaluation.

HASC Family Housing 5 Noise Summary 4.2 NAL #2 – Southeast Walking Path

The southeast walking path was selected for NAL #2 as it represents the closest outdoor recreational use area. There is a direct line of site from the southeast walking path to East College Way. A distance from the southeast walking path to the center of East College Way was estimated to be 107 ft. Consistent with HUD guidelines, the NAL was located 6.5 ft from the south boundary of the walking path, resulting in a distance between NAL #2 and East College Way of about 100.5 ft. A rounded distance of 100 ft was used as the DNL Calculator input is limited to whole numbers.

The distance to NAL#2 was entered into the DNL Calculator, along with the ADT estimates for 2021 and 2031, and estimated 2025 airport noise. The resultant predicted noise level at the NAL #2 from the combination of East College Way and the Skagit Regional Airport was 65 dB for both 2021 and 2031. This DNL is within the normally acceptable range established by HUD for noise sensitive outdoor use area and will not require additional evaluation. See Attachment D for a copy the DNL Calculator results for NAL #2 southeast walking path.

4.5 Day and Night Noise Level Calculation Summary

Fulcrum evaluated two locations at the proposed project using the DNL Calculator to predict the associated estimated noise value at each selected NAL. Following is a summary of the projected DNL for each NAL.

. NAL #1 – Building F south facing exterior wall, 253 ft north of East College Way: 59 dB – Normally Acceptable

. NAL #2 – Southeast walking path, 100 ft north of East College Way: 65 dB – Normally Acceptable

The noise assessment calculated DNL for NAL #1 and NAL #2 were found to be within HUD’s normally acceptable range for outdoor noise levels. No additional evaluation of attenuation is required for each.

5.0 Conclusions

The noise environment is considered normally acceptable if the predicted external noise environment is 65 dB or below. Levels above 65 dB require noise attenuation characteristics of either building construction materials, barriers or combinations of these factors, be implemented to reduce the indoor predicted noise levels to 45 dB, and the predicted outdoor noise levels in outdoor living spaces, quiet outdoor areas, or outdoor community gathering areas to 65 dB.

Fulcrum completed a noise summary to determine the predicted DNL at two NAL locations associated with the proposed HASC site of 4100 East College Way, Mount Vernon, Washington. Following are Fulcrum’s conclusions:

HASC Family Housing 6 Noise Summary . NAL #1 – The predicted DNL at Building F is 59 dB and is within HUD’s Normally Acceptable range for outdoor noise levels. No noise attenuation or mitigation is required for NAL #1.

. NAL #2 – The predicted DNL at the southeast walking path is 65 dB and is within HUD’s Normally Acceptable range for outdoor noise levels. No noise attenuation or mitigation is required for NAL #2.

The noise summary as presented is a part of the NEPA EA review process in accordance with HUD noise review.

HASC Family Housing 7 Noise Summary FIGURES

Figure 1: Site Location Map Figure 2: Site Plan for HASC Family Housing, dated August 4, 2020 and NAL Noise Assessment Locations

NEPA EA Noise Summary Project Site

This report includes information from the following map source provided by EDR Historical Topo Map Report 5156772.4 (2014) with QuadMatch within the Summersun Greenhouse Phase I Environmental Site Assessment Report, dated January 2018.

0 Miles 0.25 0.5 1 1.5

Fulcrum Environmental Consulting, Inc. FIGURE 406 N. 2nd Street Yakima, WA 98901 4100 East College Way Site Location Map P: 509.574.0839 F: 509.575.8453 efulcrum.net Mount Vernon, Washington 1 Technical Memorandum 203055.00 JAK 9/17/2020 Southeast Walking Path 100 Feet

NAL #2

NAL #1

Building F South Facing Exterior Wall 253 Feet

FIGURE 2

Environmental Works Community Design Center provided HASC details on the building structure design. NAL locations are indicated in red.

APPENDIX A

A.1 Distance to East College Way and Waugh Road A.2 Distance to Mount Vernon Railway A.3 Distance to BNFS Railway A.4 Distance to Skagit Airport A.5 Distance to Naval Air Station in Whidbey Island

NEPA EA Noise Summary Subject Site

Distance is within 1,000 feet to a major roadway from the closest planned development.

East College Way is immediately located to the south of the closest planned development on site and is approximately 250 feet away from the roadway of the proposed project construction. North Waugh Road is located 1,041 feet to the west of the closest planned development on site, and is just outside of the 1,000 feet distance for inclusion.

Fulcrum Environmental Consulting, Inc. 406 North Second Street, Yakima, Washington 98901 4100 East College Way, Distance to East College Way and Appendix p: 509.574.0839 f: 509.575.8453 efulcrum.net Mount Vernon, Washington North Waugh Road A.1 HASC NEPA EA . 203055.00 . JAK . 08/19/2020 Subject Site

Distance is greater than 3,000 feet of a railroad to the West

Fulcrum Environmental Consulting, Inc. Appendix 406 North Second Street, Yakima, Washington 98901 4100 East College Way, Distance to Mount Vernon p: 509.574.0839 f: 509.575.8453 efulcrum.net Mount Vernon, Washington A.2 HASC NEPA EA . 203055.00 . JAK . 08/19/2020 Terminal Railway Subject Site

Distance is greater than 3,000 feet to a railroad to the North

Fulcrum Environmental Consulting, Inc. 406 North Second Street, Yakima, Washington 98901 4100 East College Way, Appendix Distance to BNSF Railway p: 509.574.0839 f: 509.575.8453 efulcrum.net Mount Vernon, Washington A.3 HASC NEPA EA . 203055.00 . JAK . 08/03/2020 Subject Site

Distance is 6.29 miles to a civilian airport and is less than 15 miles away

Fulcrum Environmental Consulting, Inc. Appendix 406 North Second Street, Yakima, Washington 98901 4100 East College Way, Distance to Skagit Regional Airport p: 509.574.0839 f: 509.575.8453 efulcrum.net Mount Vernon, Washington A.4 HASC NEPA EA . 203055.00 . JAK . 08/19/2020 Subject Site

Distance is 18.38 miles from a military airport

Fulcrum Environmental Consulting, Inc. 406 North Second Street, Yakima, Washington 98901 4100 East College Way, Distance to Naval Air Station Appendix p: 509.574.0839 f: 509.575.8453 efulcrum.net Mount Vernon, Washington in Whidbey Island A.5 HASC NEPA EA . 203055.00 . JAK . 08/19/2020

APPENDIX B

B.1 Washington State Department of Transportation Average Annual Daily Trips 2019 Excerpt B.2 City Of Mount Vernon Traffic Counts Excerpt

NEPA EA Noise Summary p State Related Related Single Unit Double Unit Route Route Route Travel Accumulated Truck Unit Truck Truck Route ID Number Type Qualifier Direction Route Mile Percent Percent Percent AADT Year Location Latitude Longitude 538 538 Bothways 2.27 3.60 1.68 0.03 12,000 2019 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 3.60 1.68 0.03 12,000 2018 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 3.60 1.68 0.03 12,000 2017 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 3.26 1.00 0.01 11,000 2016 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 3.26 1.00 0.01 11,000 2015 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 3.26 1.00 0.01 11,000 2014 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.19 1.11 0.42 11,000 2013 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.19 1.11 0.42 11,000 2012 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.19 1.11 0.42 11,000 2011 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.19 1.11 0.42 10,000 2010 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.19 1.11 0.42 10,000 2009 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.19 1.11 0.42 9,800 2008 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.19 1.11 0.42 10,000 2007 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.19 1.11 0.42 9,500 2006 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.19 1.11 0.42 11,000 2005 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.19 1.11 0.42 11,000 2004 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.19 1.11 0.42 11,000 2003 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.19 1.11 0.42 10,000 2002 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.71 0.36 0.26 9,400 2001 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.71 0.36 0.26 9,300 2000 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.71 0.36 0.26 10,000 1999 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.71 0.36 0.26 9,700 1998 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 6.71 0.36 0.26 9,600 1997 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 8,600 1996 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 8,500 1995 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 9,400 1994 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 9,100 1993 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 8,800 1992 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 8,100 1991 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.27 7,800 1990 Before Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554571 -122.2920353 538 538 Bothways 2.29 9,400 2019 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 9,400 2018 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 9,000 2017 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 8,700 2016 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 8,500 2015 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 8,300 2014 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 8,300 2013 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 8,300 2012 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 8,300 2011 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 7,800 2010 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 7,800 2009 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 7,800 2008 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 8,100 2007 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 7,600 2006 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 8,400 2005 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 8,300 2004 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 8,300 2003 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 3.98 0.96 0.62 7,200 2002 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 3.98 0.96 0.62 7,000 2001 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 p State Related Related Single Unit Double Unit Route Route Route Travel Accumulated Truck Unit Truck Truck Route ID Number Type Qualifier Direction Route Mile Percent Percent Percent AADT Year Location Latitude Longitude 538 538 Bothways 2.29 3.98 0.96 0.62 7,000 2000 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 3.98 0.96 0.62 7,600 1999 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 3.98 0.96 0.62 7,300 1998 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 3.98 0.96 0.62 7,200 1997 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 4.94 1.50 0.19 6,500 1996 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 4.94 1.50 0.19 6,400 1995 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 7,200 1994 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 6,900 1993 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 6,700 1992 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 6,600 1991 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 6,300 1990 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 2.29 5,600 1989 After Milepost 2.28 A: RIGHT INTERSECTION WAUGH RD, LEFT INTERSECTION MARTIN RD 48.43554515 -122.2916038 538 538 Bothways 3.60 9,100 2019 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 9,100 2018 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 8,800 2017 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 8,500 2016 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 8,300 2015 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 8,000 2014 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6.66 3.16 1.25 7,800 2013 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6.66 3.16 1.25 7,800 2012 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6.66 3.16 1.25 7,900 2011 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6.66 3.16 1.25 7,500 2010 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6.66 3.16 1.25 7,400 2009 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6.66 3.16 1.25 7,300 2008 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6.66 3.16 1.25 6,700 2007 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6.66 3.16 1.25 6,300 2006 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6.66 3.16 1.25 6,900 2005 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6.66 3.16 1.25 6,800 2004 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6.66 3.16 1.25 6,900 2003 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 4.05 0.78 0.24 7,200 2002 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 3.60 1.20 0.60 6,300 2001 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 3.58 1.20 0.56 6,100 2000 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 3.58 1.20 0.56 6,700 1999 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 3.58 1.20 0.56 6,500 1998 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 3.58 1.20 0.56 6,400 1997 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6,800 1996 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 5,800 1995 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 5,600 1994 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 5,400 1993 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6,100 1992 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 5,900 1991 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 5,400 1990 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 4,800 1989 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 6,000 1988 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 538 538 Bothways 3.60 4,900 1987 Before Milepost 3.62 A: BOTHWAYS ROUNDABOUT SR 9, END ROUTE 48.4300285 -122.2648858 www.idaxdata.com

WAUGH COLLEGE

Date: Wed, Nov 13, 2013 N Peak Hour Count Period: 4:00 PM to 6:00 PM Peak Hour: 4:45 PM to 5:45 PM 92 103 0 27 37 39 WAUGH COLLEGE 0

322 23 267 0 37 TEV: 1,140 220 2 0 443 PHF: 0.96 24 628 148 517 0

COLLEGE 1

75 32 35 HV %: PHF

EB 1.4% 0.93 0

WAUGH WB 1.5% 0.90 NB 1.4% 0.85

209 142 SB 0.0% 0.89 TOTAL 1.3% 0.96 Two-Hour Count Summaries COLLEGE COLLEGE WAUGH WAUGH Interval 15-min Rolling Start Eastbound Westbound Northbound Southbound Total One Hour LT TH RT LT TH RT LT TH RT LT TH RT 4:00 PM 5 89 37 7 75 3 13 10 8 7 11 12 277 4:15 PM 11 107 38 4 56 8 17 8 10 10 19 7 295 4:30 PM 6 95 21 10 72 3 20 6 9 6 8 5 261 4:45 PM 8 105 31 5 52 9 16 11 9 12 13 4 275 1,108 5:00 PM 12 117 31 4 53 8 25 8 9 6 10 10 293 1,124 5:15 PM 7 124 37 9 61 4 17 5 9 13 4 7 297 1,126 5:30 PM 10 97 49 6 54 2 17 8 8 8 10 6 275 1,140 5:45 PM 4 83 34 5 56 6 17 11 10 13 12 2 253 1,118 Count Total 63 817 278 50 479 43 142 67 72 75 87 53 2,226 Peak Hr 37 443 148 24 220 23 75 32 35 39 37 27 1,140 Note: Two-hour count summary volumes include heavy vehicles but exclude bicycles in overall count.

Interval Heavy Vehicle Totals Bicycles Pedestrians (Crossing Leg) Start EB WB NB SB Total EB WB NB SB Total East West North South Total 4:00 PM 1 1 2 1 5 0 0 0 0 0 0 0 3 0 3 4:15 PM 3 2 0 1 6 0 1 0 0 1 2 0 1 0 3 4:30 PM 1 2 2 0 5 0 0 0 0 0 0 0 1 0 1 4:45 PM 3 0 1 0 4 0 0 0 0 0 0 1 0 0 1 5:00 PM 5 1 1 0 7 0 0 0 0 0 0 1 0 1 2 5:15 PM 1 0 0 0 1 0 0 0 0 0 0 0 0 0 0 5:30 PM 0 3 0 0 3 0 0 0 0 0 0 0 0 0 0 5:45 PM 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 Count Total 14 9 6 2 31 0 1 0 0 1 2 2 5 1 10 Peak Hr 9 4 2 0 15 0 0 0 0 0 0 2 0 1 3

Mark Skaggs: 425 - 250 - 0777 [email protected]

APPENDIX C

C.1 Regional Airport Master Plan Update 2007 INM Airport Noise Maps C.2 HUD Chapter 5 Table 2 Extended Airport Curve

NEPA EA Noise Summary

Dba Ratio 65 1 64 1.12 63 1.26 62 1.41 HUD Chapter 5, Table 2 Extended Aircraft Noise Ratio 61 1.58 120 60 1.78 59 2 58 2.24 57 2.51 56 2.82 100 55 3.16

80

60 Ratio Expon. (Ratio)

‐0.115x 40 y = 1788.8e R² = 1

20

0 90 80 70 60 50 40 30 20 10 0 APPENDIX D

D.1 Building F 2021 DNL Calculations D.2 Building F 2021 DNL Calculations D.3 Southeast Walking Path 2021 DNL Calculations D.4 Southeast Walking Path 2031 DNL Calculations

NEPA EA Noise Summary Home (/) > Programs (/programs/) > Environmental Review (/programs/environmental- review/) >DNL Calculator

DNL Calculator The Day/Night Noise Level Calculator is an electronic assessment tool that calculates the Day/Night Noise Level (DNL) from roadway and railway traffic. For more information on using the DNL calculator, view the Day/Night Noise Level Calculator Electronic Assessment Tool Overview (/programs/environmental-review/daynight-noise-level-electronic-assessment-tool/).

Guidelines • To display the Road and/or Rail DNL calculator(s), click on the "Add Road Source" and/or "Add Rail Source" button(s) below. • All Road and Rail input values must be positive non-decimal numbers. • All Road and/or Rail DNL value(s) must be calculated separately before calculating the Site DNL. • All checkboxes that apply must be checked for vehicles and trains in the tables' headers. • Note #1: Tooltips, containing field specific information, have been added in this tool and may be accessed by hovering over all the respective data fields (site identification, roadway and railway assessment, DNL calculation results, roadway and railway input variables) with the mouse. • Note #2: DNL Calculator assumes roadway data is always entered.

DNL Calculator Site ID HASC Family Housing - Current Building F NAL#1

Record Date 11/13/2020

User's Name Peggy Williamson

Road # 1 Name: East College Way

Road #1

Vehicle Type Cars Medium Trucks Heavy Trucks

Effective Distance 253 253 253

Distance to Stop Sign

Average Speed 45 45 45

Average Daily Trips (ADT) 9277 391 155

Night Fraction of ADT 15 15 15

Road Gradient (%) 0

Vehicle DNL 55 51 54

Calculate Road #1 DNL 59 Reset

Add Road Source Add Rail Source

Airport Noise Level 25

Loud Impulse Sounds? Yes No Combined DNL for all 59 Road and Rail sources

Combined DNL including Airport 59

Site DNL with Loud Impulse Sound

Calculate Reset

Mitigation Options If your site DNL is in Excess of 65 decibels, your options are:

• No Action Alternative: Cancel the project at this location • Other Reasonable Alternatives: Choose an alternate site • Mitigation ◦ Contact your Field or Regional Environmental Officer (/programs/environmental- review/hud-environmental-staff-contacts/) ◦ Increase mitigation in the building walls (only effective if no outdoor, noise sensitive areas) ◦ Reconfigure the site plan to increase the distance between the noise source and noise-sensitive uses ◦ Incorporate natural or man-made barriers. See The Noise Guidebook (/resource/313/hud-noise-guidebook/) ◦ Construct noise barrier. See the Barrier Performance Module (/programs/environmental-review/bpm-calculator/)

Tools and Guidance Day/Night Noise Level Assessment Tool User Guide (/resource/3822/day-night-noise-level- assessment-tool-user-guide/)

Day/Night Noise Level Assessment Tool Flowcharts (/resource/3823/day-night-noise-level- assessment-tool-flowcharts/)

Home (/) > Programs (/programs/) > Environmental Review (/programs/environmental- review/) >DNL Calculator

DNL Calculator The Day/Night Noise Level Calculator is an electronic assessment tool that calculates the Day/Night Noise Level (DNL) from roadway and railway traffic. For more information on using the DNL calculator, view the Day/Night Noise Level Calculator Electronic Assessment Tool Overview (/programs/environmental-review/daynight-noise-level-electronic-assessment-tool/).

Guidelines • To display the Road and/or Rail DNL calculator(s), click on the "Add Road Source" and/or "Add Rail Source" button(s) below. • All Road and Rail input values must be positive non-decimal numbers. • All Road and/or Rail DNL value(s) must be calculated separately before calculating the Site DNL. • All checkboxes that apply must be checked for vehicles and trains in the tables' headers. • Note #1: Tooltips, containing field specific information, have been added in this tool and may be accessed by hovering over all the respective data fields (site identification, roadway and railway assessment, DNL calculation results, roadway and railway input variables) with the mouse. • Note #2: DNL Calculator assumes roadway data is always entered.

DNL Calculator Site ID HASC Family Housing - Current Building F NAL#1

Record Date 11/13/2020

User's Name Peggy Williamson

Road # 1 Name: East College Way

Road #1

Vehicle Type Cars Medium Trucks Heavy Trucks

Effective Distance 253 253 253

Distance to Stop Sign

Average Speed 45 45 45

Average Daily Trips (ADT) 10248 432 171

Night Fraction of ADT 15 15 15

Road Gradient (%) 0

Vehicle DNL 56 52 55

Calculate Road #1 DNL 59 Reset

Add Road Source Add Rail Source

Airport Noise Level 25

Loud Impulse Sounds? Yes No Combined DNL for all 59 Road and Rail sources

Combined DNL including Airport 59

Site DNL with Loud Impulse Sound

Calculate Reset

Mitigation Options If your site DNL is in Excess of 65 decibels, your options are:

• No Action Alternative: Cancel the project at this location • Other Reasonable Alternatives: Choose an alternate site • Mitigation ◦ Contact your Field or Regional Environmental Officer (/programs/environmental- review/hud-environmental-staff-contacts/) ◦ Increase mitigation in the building walls (only effective if no outdoor, noise sensitive areas) ◦ Reconfigure the site plan to increase the distance between the noise source and noise-sensitive uses ◦ Incorporate natural or man-made barriers. See The Noise Guidebook (/resource/313/hud-noise-guidebook/) ◦ Construct noise barrier. See the Barrier Performance Module (/programs/environmental-review/bpm-calculator/)

Tools and Guidance Day/Night Noise Level Assessment Tool User Guide (/resource/3822/day-night-noise-level- assessment-tool-user-guide/)

Day/Night Noise Level Assessment Tool Flowcharts (/resource/3823/day-night-noise-level- assessment-tool-flowcharts/)

Home (/) > Programs (/programs/) > Environmental Review (/programs/environmental- review/) >DNL Calculator

DNL Calculator The Day/Night Noise Level Calculator is an electronic assessment tool that calculates the Day/Night Noise Level (DNL) from roadway and railway traffic. For more information on using the DNL calculator, view the Day/Night Noise Level Calculator Electronic Assessment Tool Overview (/programs/environmental-review/daynight-noise-level-electronic-assessment-tool/).

Guidelines • To display the Road and/or Rail DNL calculator(s), click on the "Add Road Source" and/or "Add Rail Source" button(s) below. • All Road and Rail input values must be positive non-decimal numbers. • All Road and/or Rail DNL value(s) must be calculated separately before calculating the Site DNL. • All checkboxes that apply must be checked for vehicles and trains in the tables' headers. • Note #1: Tooltips, containing field specific information, have been added in this tool and may be accessed by hovering over all the respective data fields (site identification, roadway and railway assessment, DNL calculation results, roadway and railway input variables) with the mouse. • Note #2: DNL Calculator assumes roadway data is always entered.

DNL Calculator Site ID HASC Family Housing - current southeast walking path

Record Date 11/13/2020

User's Name Peggy Williamson

Road # 1 Name: East College Way

Road #1

Vehicle Type Cars Medium Trucks Heavy Trucks

Effective Distance 100 100 100

Distance to Stop Sign

Average Speed 45 45 45

Average Daily Trips (ADT) 9277 391 155

Night Fraction of ADT 15 15 15

Road Gradient (%) 0

Vehicle DNL 61 57 60

Calculate Road #1 DNL 65 Reset

Add Road Source Add Rail Source

Airport Noise Level 25

Loud Impulse Sounds? Yes No Combined DNL for all 65 Road and Rail sources

Combined DNL including Airport 65

Site DNL with Loud Impulse Sound

Calculate Reset

Mitigation Options If your site DNL is in Excess of 65 decibels, your options are:

• No Action Alternative: Cancel the project at this location • Other Reasonable Alternatives: Choose an alternate site • Mitigation ◦ Contact your Field or Regional Environmental Officer (/programs/environmental- review/hud-environmental-staff-contacts/) ◦ Increase mitigation in the building walls (only effective if no outdoor, noise sensitive areas) ◦ Reconfigure the site plan to increase the distance between the noise source and noise-sensitive uses ◦ Incorporate natural or man-made barriers. See The Noise Guidebook (/resource/313/hud-noise-guidebook/) ◦ Construct noise barrier. See the Barrier Performance Module (/programs/environmental-review/bpm-calculator/)

Tools and Guidance Day/Night Noise Level Assessment Tool User Guide (/resource/3822/day-night-noise-level- assessment-tool-user-guide/)

Day/Night Noise Level Assessment Tool Flowcharts (/resource/3823/day-night-noise-level- assessment-tool-flowcharts/)

Home (/) > Programs (/programs/) > Environmental Review (/programs/environmental- review/) >DNL Calculator

DNL Calculator The Day/Night Noise Level Calculator is an electronic assessment tool that calculates the Day/Night Noise Level (DNL) from roadway and railway traffic. For more information on using the DNL calculator, view the Day/Night Noise Level Calculator Electronic Assessment Tool Overview (/programs/environmental-review/daynight-noise-level-electronic-assessment-tool/).

Guidelines • To display the Road and/or Rail DNL calculator(s), click on the "Add Road Source" and/or "Add Rail Source" button(s) below. • All Road and Rail input values must be positive non-decimal numbers. • All Road and/or Rail DNL value(s) must be calculated separately before calculating the Site DNL. • All checkboxes that apply must be checked for vehicles and trains in the tables' headers. • Note #1: Tooltips, containing field specific information, have been added in this tool and may be accessed by hovering over all the respective data fields (site identification, roadway and railway assessment, DNL calculation results, roadway and railway input variables) with the mouse. • Note #2: DNL Calculator assumes roadway data is always entered.

DNL Calculator Site ID HASC Family Housing - 10 year southeast walking path

Record Date 11/13/2020

User's Name Peggy Williamson

Road # 1 Name: East College Way

Road #1

Vehicle Type Cars Medium Trucks Heavy Trucks

Effective Distance 100 100 100

Distance to Stop Sign

Average Speed 45 45 45

Average Daily Trips (ADT) 10248 432 171

Night Fraction of ADT 15 15 15

Road Gradient (%) 0

Vehicle DNL 62 58 61

Calculate Road #1 DNL 65 Reset

Add Road Source Add Rail Source

Airport Noise Level 25

Loud Impulse Sounds? Yes No Combined DNL for all 65 Road and Rail sources

Combined DNL including Airport 65

Site DNL with Loud Impulse Sound

Calculate Reset

Mitigation Options If your site DNL is in Excess of 65 decibels, your options are:

• No Action Alternative: Cancel the project at this location • Other Reasonable Alternatives: Choose an alternate site • Mitigation ◦ Contact your Field or Regional Environmental Officer (/programs/environmental- review/hud-environmental-staff-contacts/) ◦ Increase mitigation in the building walls (only effective if no outdoor, noise sensitive areas) ◦ Reconfigure the site plan to increase the distance between the noise source and noise-sensitive uses ◦ Incorporate natural or man-made barriers. See The Noise Guidebook (/resource/313/hud-noise-guidebook/) ◦ Construct noise barrier. See the Barrier Performance Module (/programs/environmental-review/bpm-calculator/)

Tools and Guidance Day/Night Noise Level Assessment Tool User Guide (/resource/3822/day-night-noise-level- assessment-tool-user-guide/)

Day/Night Noise Level Assessment Tool Flowcharts (/resource/3823/day-night-noise-level- assessment-tool-flowcharts/) Fulcrum Environmental Consulting, Inc. 406 North Second Street, Yakima, Washington 98901 4100 East College Way, FIGURE Sole Source Aquifer Map p: 509.574.0839 f: 509.575.8453 efulcrum.net Mount Vernon, Washington 1 HASC NEPA EA . 203055.00 . JAK . 07/31/2020

Preliminary Jurisdictional Determination Summersun Greenhouse

April 2018, Final

Preliminary Jurisdictional Determination Summersun Greenhouse

Contact Information Document Information Cardno 801 2nd Avenue, Suite 700 Seattle, WA 98104 USA Prepared for Telephone: 206-269-0104 Housing Authority Skagit County www.cardno.com 1650 Port Dr., Burlington, WA 98233 USA

Project Name Preliminary Jurisdictional Determination Summersun Greenhouse

File Reference SummersunGreenhouse_PJD_Report_Final

Job Reference E318200700 Author(s) Ingrid Kimball Date April 2018, Final Senior Staff Scientist Version Number 2.0

Effective Date April 3, 2018 Date Approved April 3, 2018

Approved By Emily Merickel Senior Staff Scientist

Document History Version Effective Date Description of Revision Prepared by Reviewed by 1.0 03/28/2018 Draft Report Ingrid Kimball Emily Merickel, Malini Roberts, Alison Uno 2.0 04/03/2018 Final Report Ingrid Kimball Alison Uno

© Cardno. Copyright in the whole and every part of this document belongs to Cardno and may not be used, sold, transferred, copied or reproduced in whole or in part in any manner or form or in or on any media to any person other than by agreement with Cardno. This document is produced by Cardno solely for the benefit and use by the client in accordance with the terms of the engagement. Cardno does not and shall not assume any responsibility or liability whatsoever to any third party arising out of any use or reliance by any third party on the content of this document.

April 2018, Final Cardno Document Information i SummersunGreenhouse_PJD_Report_Final.docxFinal Preliminary Jurisdictional Determination Summersun Greenhouse

This Page Intentionally Left Blank

ii Document Information Cardno April 2018, Final SummersunGreenhouse_PJD_Report_Final.docx Preliminary Jurisdictional Determination Summersun Greenhouse

Table of Contents 1 Introduction ...... 1 1.1 Project Location ...... 1 1.2 Regulatory Framework ...... 1 Federal Regulatory Framework ...... 1 The Rapanos Decision ...... 4 State Regulatory Framework ...... 4 State of Washington Wetlands Rating Method ...... 4 2 Methods ...... 5 3 Results ...... 6 3.1 Desktop Analysis ...... 6 3.2 Field Results ...... 8 Wetland Delineation ...... 8 Ordinary High Water Mark Determination ...... 9 4 Conclusions ...... 11 4.1 College Way Creek (Perennial Stream; PS-1) ...... 11 4.2 PEM1A: Emergent Palustrine (0.15 acre) ...... 11 4.3 Washington State Wetland Rating Summary ...... 11 5 References ...... 15

Appendices Appendix A Photo Log Appendix B Wetland Data Forms Appendix C Washington State Wetland Rating Form: 2014 update

Tables Table 1 Monthly Precipitation Data for Arlington, Washington ...... 7 Table 2 Daily Precipitation Records 10 Days Preceding Fieldwork for Mount Vernon ...... 8 Table 3 Summary of Sample Points ...... 9

Figures Figure 1 Aerial map showing the location of the project site...... 2 Figure 2 Topographic map showing the location of the project site. Based on the Mount Vernon, Washington, USGS 7.5’ series quadrangle map (1:24,000 scale)...... 3 Figure 3 NWI mapped wetlands around the project site...... 3-6 Figure 4 WDFW Priority Habitat Species mapped in the vicinity of the project site ...... 7

April 2018, Final Cardno Table of Contents i SummersunGreenhouse_PJD_Report_Final.docx Preliminary Jurisdictional Determination Summersun Greenhouse

Figure 5 Elevation profile of project site based on bare earth imaging (Source: Puget Sound LiDAR Consortium 2004)...... 10 Figure 6 Aerial Summersun Greenhouse Project wetland delineation map...... 13 Figure 7 LiDAR map of Summerson Greenhouse Wetland Delineation Map (Puget Sound LiDAR Consortium 2004)...... 14

ii Table of Contents Cardno April 2018, Final SummersunGreenhouse_PJD_Report_Final.docx Preliminary Jurisdictional Determination Summersun Greenhouse

1 Introduction

Cardno conducted a routine wetland delineation and completed this preliminary jurisdictional determination (PJD) to assist the Housing Authority of Skagit County (HASC) and the City of Mount Vernon in their determination of potential waters of the United States (WOUS) and jurisdictional wetlands within the property located at 4100 East College Way, Mount Vernon, Washington (Summersun Greenhouse). This report describes the wetland delineation conducted by Cardno and the PJD to help inform possible site development so impacts to jurisdictional wetlands and WOUS can be minimized or avoided. Attachments to this report include project area photographs, wetland data forms, and the Washington State Wetland Rating Form: 2014 Update (Appendices A through C).

1.1 Project Location The project site is located within Mount Vernon city limits in Skagit County, Washington, in Section (S) 15, Township (T) 34 North, Range (R) 4 East, Willamette Meridian (Figure 1). It is positioned within a valley bottom located in the Lower Skagit watershed (Hydrologic Unit Code [HUC] 17110007; Figure 2). The project site is approximately 653 feet wide by 0.25 mile long, or roughly 4.5 acres. It is within a mix of residential, agricultural, and undeveloped land uses and immediately bordered by an unnamed tributary to the north, East College Way to the south, an apartment complex to the west, and a single-family home to the east. The majority of the project site is covered by concrete slab or pavement with derelict buildings from its past use as a commercial nursery. Therefore, the wetland survey area focused on the southeast portion of the project site, where College Way Creek flows from the southwest to northeast, in an area approximately 520 feet wide by 456 feet long, or 1.15 acres.

1.2 Regulatory Framework

Federal Regulatory Framework The Clean Water Act (CWA) regulates construction activities associated with Traditional Navigable Waters (TNWs), tributaries of TNWs, and wetlands adjacent to TNWs. Section 404 of the CWA grants federal jurisdiction over TNWs and their tributaries extending to the ordinary high water mark (OHWM), in the absence of adjacent wetlands. When adjacent wetlands are present, CWA jurisdiction extends beyond the OHWM to the limits of the adjacent wetlands. A TNW is defined as a waterway that is susceptible to use, or was historically used, in interstate or foreign commerce and includes relatively permanent waters, their adjacent wetlands, and other water bodies determined to have a significant nexus with the TNW. A significant nexus exists if the tributary, in combination with all of its adjacent wetlands, has an effect on the chemical, physical, or biological integrity of the TNW. The U.S. Army Corps of Engineers (USACE) and U.S. Environmental Protection Agency (USEPA) published the Jurisdictional Determination Form Instructional Guidebook to support an agency jurisdictional determination for a particular water body. All determinations for non-navigable, isolated waters must be submitted to USACE and USEPA for review before a final decision on the jurisdictional determination can be made. Only USACE is able to make a jurisdictional determination for WOUS, including wetlands. Any impacts to wetlands or WOUS require that a Joint Application for Permits be submitted and approved, as required under Section 404 of the CWA, for dredged or fill materials being placed in WOUS, and for filling or dredging work within continuously flowing streams.

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Figure 1 Aerial map showing the location of the project site.

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Figure 2 Topographic map showing the location of the project site. Based on the Mount Vernon, Washington, USGS 7.5’ series quadrangle map (1:24,000 scale).

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The Rapanos Decision The consolidated cases Rapanos v. United States and Carabell v. United States, 126 S. Ct. 2208 (2006) are referred to as Rapanos. The Supreme Court’s decision in these consolidated cases was to address where the federal government can apply the CWA—specifically by determining whether a wetland or tributary is a WOUS. As a result of the Rapanos decision, the agencies have jurisdiction over the following waters:  TNWs;  Wetlands adjacent to TNWs;  Non-navigable tributaries of TNWs that are relatively permanent where the tributaries typically flow year-round or have continuous flow at least seasonally (e.g., typically 3 months); and  Wetlands that directly abut such tributaries. The agencies generally will not assert jurisdiction over the following features:  Swales or erosional features (e.g., gullies, small washes characterized by low-volume, infrequent, or short duration-flow); and  Ditches (including roadside ditches) excavated wholly in and draining only uplands, and that do not carry a relatively permanent flow of water.

State Regulatory Framework The State of Washington defines “Waters of the State” to include lakes, rivers, ponds, streams, inland waters, underground water, salt waters, estuaries, tidal flats, beaches and lands adjoining the seacoast of the state, sewers, and all other surface waters and watercourses within its jurisdiction. Projects that do not require a federal permit may still result in dredge or fill in Waters of the State. Such projects may be regulated by Washington State Department of Ecology (Ecology) in conjunction with the local municipality. The Department of Natural Resources (DNR) defines streams through its Water Typing System (Washington Administrative Code 222-16-030), which is then used by local county and city municipalities to define waterways and associated buffers in order to help protect natural resources. An example is the Mount Vernon city ordinance for fish and wildlife habitat conservation areas, which “contains standards, guidelines, criteria and requirements intended to identify, evaluate and mitigate potential impacts to habitat conservation areas within the city”(Mount Vernon Municipal Code [MVMV] 15.40.080). Washington State’s primary role in wetland regulation and protection involves filling gaps in federal wetland jurisdiction by using various authorities in the state Water Pollution Control Act. Washington’s Growth Management Act also plays a significant role in wetlands regulation through its requirement for local governments to protect critical areas, which include wetland habitats. The state policy also assists local governments in the development of comprehensive growth management plans, shoreline master programs, regulations, and ordinances. Similar to the incorporation of DNR stream types into critical area regulations, many counties and cities have incorporated the use of Ecology’s Wetlands Rating Method (see below) to guide wetland buffers and mitigation needs.

State of Washington Wetlands Rating Method The Washington State Wetlands Rating Method is a rapid functional assessment process used to quantify, describe, and categorize wetlands affected by proposed development projects based on a four- tier scale. This state function and value assessment is also used to evaluate the applicability and scale of mitigation when mitigation is deemed necessary and appropriate.

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Use of the Washington State Wetlands Rating Method: 2014 Update is required if a project will require approval from Ecology and is also mandated by MVMC 15.40.090 as part of the Mount Vernon’s critical areas regulations. The four tiers used by this method are listed below.  Category I wetlands include wetlands of exceptionally high quality that provide primary value as rare wetlands, special wildlife habitat, and exceptional ecological functions, and exhibit value for flood attenuation capability.  Category II wetlands provide high levels of some functions (water quality improvement, hydrological function, and/or high-quality habitat) and would be difficult, though not impossible, to replace.  Category III wetlands are more common wetlands and generally isolated or smaller in function and size.  Category IV wetlands are generally the smallest and most isolated, exhibiting the least amount of biological diversity. These categories help determine the scale of mitigation needed when mitigation is deemed necessary and appropriate.

2 Methods

Prior to initiating the field evaluation, Cardno completed a desktop analysis of the project site to identify the potential occurrence of USACE and Ecology jurisdictional wetlands and WOUS. This included review of:  Ecology’s 2011 Wetland Inventory;  U.S. Fish and Wildlife Service (USFWS) National Wetlands Inventory (NWI) (Version 2 modified October 1, 2017) data (USFWS 2016);  U.S. Geological Survey (USGS) 24K:1 Mount Vernon 7.5-minute series quadrangle topographic map review to identify mapped wetlands, wells, blue lines, and other potential water-conveying features;  Federal Emergency Management Agency (FEMA) Flood Zone Map (FEMA 2018);  Washington Department of Fish and Wildlife (WDFW) Priority Habitat Species (PHS) online data (WDFW 2016);  Hydrologic geospatial data (WETS precipitation table) from the U.S. Department of Agriculture (USDA) Natural Resources Conservation Service (NRCS 2018); and  USDA NRCS Web Soil Survey (accessed March 2018) (USDA NRCS 2015). This wetland delineation was conducted in accordance with the 1987 USACE Wetlands Delineation Manual (Environmental Laboratory 1987), USACE and USEPA’s Jurisdictional Determination Form Instructional Guidebook (May 2007), and the USACE’s Regional Supplement to the USACE Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region Version 2.0 (May 2010). A Level 2 Onsite Inspection was conducted (as defined in the Wetlands Delineation Manual), evaluating three parameters that identify and delineate the boundaries of jurisdictional wetlands: (1) the dominance of wetland vegetation; (2) the presence of hydric soils; and (3) hydrologic conditions that result in periods of inundation or saturation on the surface from flooding or ponding. The USACE State of Washington 2016 Wetland Plant List (Lichvar 2016) and NRCS 2017 Field Indicators of Hydric Soils in the United States

April 2018, Final Cardno Methods 5 SummersunGreenhouse_PJD_Report_Final.docx Preliminary Jurisdictional Determination Summersun Greenhouse publications were used to determine the wetland indicator status of plants and soils observed in the project site. For the purpose of this evaluation, WOUS were identified based on the current regulatory definition as described in Determining the Ordinary High Water Mark for Shoreline Management Act Compliance in Washington State (Anderson et al. 2016). On March 15, 2018, Cardno staff collected field data to identify the boundaries of potential wetlands and WOUS. Twelve representative soil pits were analyzed during the wetland delineation. Data on vegetation, soils, and hydrologic characteristics of features were recorded in the field on data forms for the Western Mountains, Valleys, and Coast Region (Appendix A). The survey area included the approximate 4.5-acre project site and all features within the property footprint. However, the wetland survey area was focused on the less-developed southeast 1.15-acre portion of the project site. All potentially jurisdictional features identified as a result of the data review were photographed, documented, field-verified, and reviewed for potential USACE jurisdictional status. Prior to fieldwork, the project site and NWI mapped wetland feature were uploaded to the ArcGIS Collector Application linked with a Garmin GLO (Bluetooth) on an iPad for sub-3-meter position accuracy. Post-fieldwork, the global positioning system (GPS) data were differentially corrected to reflect field conditions accurately using 2018 aerial imagery as a guide.

3 Results

3.1 Desktop Analysis The project site is located within feature on the USGS Mount Vernon 7.5-minute series quadrangle the Lower Skagit watershed (HUC (Figure 2), a freshwater forested/shrub wetland by the USFWS NWI 17110007, Water Resource (Figure 3), and a fish-bearing stream by the WDFW PHS (Figure 4). Inventory Area 3), which is College Way Creek flows southwest to northeast into Nookachamps approximately 284,302 acres with Creek, which then drains into the Skagit River. USFWS NWI and hydrology primarily driven by WDFW PHS also mapped a seasonally flooded emergent wetland precipitation. The largest river and along the southern portion of the project site. No wetlands were principal drainage in this system identified in the project site by Ecology’s 2011 Wetland Inventory. is the Skagit River, a TNW, which flows west into the Puget Sound. Six federal and/or state-listed endangered or threatened salmonid species have been documented within the watershed: Chinook (Oncorhynchus tshawytscha), chum (Oncorhynchus keta), coho (Oncorhynchus kisutch), sockeye salmon (Oncorhynchus nerka), and steelhead (Oncorhynchus mykiss). The project site was mapped within an A7 Zone by FEMA, meaning there is a 1 percent chance of annual inundation or 100-year flood. Additionally, College Way Figure 3 NWI mapped wetlands around the project site. Creek was identified as a blue line

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Figure 4 WDFW Priority Habitat Species mapped in the vicinity of the project site. NRCS mapped two soil units within the project site, Skipopa silt loam and Bellingham silt loam; both are rated as hydric. Historical precipitation records were reviewed prior to the field survey in order to determine hydrological conditions (Tables 1 and 2).

Table 1 Monthly Precipitation Data for Arlington, Washington Long-term Rainfall Recordsa Products Condition Month of Month and Condition 3 Yrs in Average 3 Yrs in Rainfalla (dry, wet, Weight Previous Year Valuec 10 Less 10 More normal)b Value Two Than Than Columns February 2.90 4.13 4.91 8.84 Wet 3 3 9 2018 January 3.63 5.75 6.94 8.01 Wet 3 2 6 2018 December 4.46 5.93 6.92 6.42 Normal 2 1 2 2017 Sum 17d

Notes: a Source: AgACIS for Skagit County (USDA NRCS 2018) b Conditions are considered normal if they fall within the low and high range. c Normal = 2; Wet = 3 d Sum between 15 and 18 indicates that period has been wetter than normal

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Table 2 Daily Precipitation Records 10 Days Preceding Fieldwork for Mount Vernon Date (2018) Daily Precipitation (inches) Though precipitation was heavier 3 months prior to the field survey, it was lighter than the March 14 0.00 historical average for the 10 days leading up to March 13 0.26 the survey, resulting in expected normal hydrological conditions during the site survey. March 12 0.00 March 11 0.00 March 10 0.00 March 9 0.00 March 8 0.11 March 7 0.01 March 6 0.00 March 5 0.00 Source: Weather Underground 2018

3.2 Field Results

Wetland Delineation Twelve representative soil pits (W1 through W12; Figure 6) were analyzed during the wetland delineation. Five plots were taken just above the top of bank or observed OHWM on the north bank and seven were analyzed to the south of College Way Creek in the less developed area, which historically contained a shrub and sapling nursery. The results are discussed below.

3.2.1.1 Vegetation Two vegetative communities were observed within the wetland survey area and, based on the dominance test, were determined to be hydrophytic, or adapted to survive extended periods of inundation. Vegetation bordering College Way Creek comprised an overstory of red alder (Alnus rubra) and weeping willow (Salix babylonica), a shrub layer dominated by Himalayan blackberry (Rubus armeniacus), and an understory dominated by largeleaf avens (Geum macrophyllum). The second vegetative community, located on the southern side of College Way Creek, lacked an overstory, had a minimal shrub layer dominated by Himalayan blackberry, and had an understory dominated by a mixture of reed canary grass (Phalaris arundinacea,), common rush (Juncus effusus), creeping buttercup (Ranunculus repens), and various perennial herbs.

3.2.1.2 Soils Only two soil pit locations were found to be hydric based on the presence of an iron (Fe3+) depleted matrix and oxidized iron (Fe2+) concentrations within the matrix: W7 and W9. Other soil pits were either entirely dark brown (10YR 2/2) or had a dark upper layer with paler lower layers (5Y 6/3 or 4/1), which may have had some redox concentrations. However, the layers were too deep, the depleted coloring was not the majority of the matrix (over 60%), or the pits did not exhibit low enough chroma to be considered hydric.

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Preliminary Jurisdictional Determination Summersun Greenhouse

3.2.1.3 Hydrology Hydrological conditions were expected to be normal during the site visit, as noted above, with wetland hydrology indicators observed in W3, W4, W6, W7, W9, and W11. Plots W4 and W9 had the primary indicator of saturation (A3) and a high water table (A2), respectively, while the remainder of the plots had a combination or secondary hydrologic indicators including water-stained leaves (B9), drainage pattern (B10), geomorphic positioning (D2), and/or facultative (FAC)-neutral vegetation (D5). Collected sample points within the wetland survey area are summarized in Table 3.

Table 3 Summary of Sample Points Sample Point Sample Point in Hydric Vegetation Soils Hydrology Wetland W1 No Yes No No W2 No Yes No No W3 No Yes No Yes – D2, D5 W4 No Yes No Yes – A3 W5 No Yes No No W6 No Yes No Yes – A2 W7 Yes Yes Yes – F3 Yes – D2, D5 W8 No Yes No No W9 Yes Yes Yes – F3 Yes – A2 W10 No Yes No No W11 No Yes No Yes – B9, D5 W12 No Yes No No

Ordinary High Water Mark Determination OHWM was determined concurrently with the wetland delineation and based upon field observation and light detection and ranging (LiDAR) analysis (Figure 5). The OHWM boundary ranges between elevations 43 and 42 feet, decreasing from west to east respectively and generally 1 foot or less below the top of bank. College Way Creek is incised with the left bank generally higher than the right and a cobble streambed. One sand bench was observed below W3. Little to no vegetation was observed below the OHWM with red alder and Himalayan blackberries dominating the top of bank. Clean cobbles and lack of soil horizons were observed below the OHWM, with overbank deposits by the drainage located by W6. Based on FEMA mapping, the area is prone to flooding events though historical aerials showed no evidence of these.

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Figure 5 Elevation profile of project site based on bare earth imaging (Source: Puget Sound LiDAR Consortium 2004).

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4 Conclusions

4.1 College Way Creek (Perennial Stream; PS-1) One perennial stream, College Way Creek, is located in the project site. This continuous perennial stream (PS-1) runs roughly 326 linear feet southwest to northeast through the southern portion of the project site in a west to east unidirectional flow (Figure 6 and 7). It is generally 2 to 3 feet in width. The OHWM was characterized by exposed banks, minimal shelving, lack of soil horizons, and top of bank vegetation. It is a WDNR Type F stream since it runs year-round and provides fish habitat where coho are known to occur. 4.2 PEM1A: Emergent Palustrine (0.15 acre) One occasionally flooded palustrine emergent wetland (PEM1A; Cowardin1979) was identified of approximately 0.15 acre in size (6,728 square feet) located on the southeast portion of the property between the former tree nursery to the south, College Way Creek to the north, a drainage to the east, and higher positioned land to the west. This area meets the USACE wetland three-parameter criteria. 4.3 Washington State Wetland Rating Summary The wetland rating score for the wetland unit in the project area is calculated as follows: Emergent Wetland Water Quality Function: 7 points Hydrologic Function: 5 points Habitat Function: 4 points Total = 16 points (Class III) Result: The wetland on the property is classified a Class III Wetland, which are described as wetlands that are generally small, isolated, and common. Any new developments on the project site will need to follow the buffer and mitigation requirements outlined by USACE Section 404 permitting and the City of Mount Vernon Critical Areas Ordinance. Under MVMC 15.40, development within 200 feet of known federally listed threatened species habitat requires a Habitat Management Plan (HMP) to determine necessary buffers and avoiding impact to natural resources (MVMC 15.40.080). Additionally, a 75-foot buffer or a Wetland Mitigation Plan is required if development occurs near or within a Class III wetland (MVMC 15.40.090). However, MVMC 15.40.110, Managed Ecosystem Alternative, does allow for different buffer standards within a developed area in the upper reaches of the Nookachamps Basin if application of these alternative buffers would avoid any buffer variance. Using this method, a 75-foot stream buffer could be applied along College Way Creek (though the 75-foot wetland buffer would remain). In some circumstances, buffer requirements can be waived or modified for development on existing impermeable areas where pre-existing developed areas may be grandfathered in. Cardno recommends consulting with the City of Mount Vernon for further direction regarding site development limitations, buffer requirements, permits, fees and other measures that may be required for development of the Summersun Greenhouse property.

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Figure 6 Aerial Summersun Greenhouse Project wetland delineation map.

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Figure 7 LiDAR map of Summerson Greenhouse Wetland Delineation Map (Puget Sound LiDAR Consortium 2004).

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5 References

Anderson, P.S., S. Meyer, P. Olson, and E. Stockdale. 2016. Determining the Ordinary High Water Mark for Shoreline Management Act. Department of Ecology Publication No. 16-06-029. Available at https://fortress.wa.gov/ecy/publications/documents/1606029.pdf. Cowardin, L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. Report No. FWS/OBS79/31. http://www.charttiff.com/pub/WetlandMaps/Cowardin.pdf. U.S. Department of the Interior, Fish and Wildlife Service, Office of Biological Services, Washington, D.C. Government Printing Office, Washington, D.C. Environmental Laboratory. 1987. Corps of Engineers Wetland Delineation Manual (Technical Report Y- 87-1). U.S. Army Corps of Engineers. Waterways Experimental Station. Vicksburg, Mississippi. Federal Emergency Management Act (FEMA). 2018. FEMA Flood Map Service Center: Search by Address. Available at https://msc.fema.gov/portal/search. 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 Puget Sound LiDAR Consortium. 2004. LiDAR Bare Earth DEM [computer file]. (2000-2004). Available at: http://pugetsoundlidar.ess.washington.edu/index.htm [April 27th, 2004]. Puget Sound LiDAR Consortium, Seattle, WA. U.S. Army Corps of Engineers (USACE). 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valley, and Coast Region (Version 2.0). May 2010. U.S. Army Corps of Engineers (USACE) and U.S. Environmental Protection Agency (USEPA). 2007 Jurisdictional Determination Form Instructional Guidebook. May 2007. U.S. Department of Agriculture, Natural Resources Conservation Service (NRCS). 2015. Web Soil Survey. Available at: http://websoilsurvey.nrcs.usda.gov/. U.S. Department of Agriculture, Natural Resources Conservation Service (NRCS). 2018. Field Office Technical Guide. AgACIS for Skagit County. Available at: http://agacis.rcc-acis.org/?fips=53057/. U.S Fish and Wildlife Service (USFWS). 2016. National Wetland Inventory Mapper V2. Available at: https://www.fws.gov/wetlands/data/mapper.html. U.S. Geological Survey (USGS). 2014. Mount Vernon Quadrangle, Washington-Skagit Co., 7.5-Minute Series. Available at https://prd- tnm.s3.amazonaws.com/StagedProducts/Maps/USTopo/1/20140/7068414.pdf. Washington State Department of Ecology (Ecology). 2011. 2011 Wetland Inventory. Available at: http://waecy.maps.arcgis.com/apps/OnePane/basicviewer/index.html?appid=22edd2e4e7874bad bef2a907a3cd4de6 Washington Department of Fish & Wildlife (WDFW). 2016. PHS on the Web. Available at: http://apps.wdfw.wa.gov/phsontheweb/. Weather Underground. 2018. Weather Underground History: Weather History for KNUW - March, 2018. Available at: https://www.wunderground.com/history/airport/KNUW/2018/3/14/MonthlyHistory.html?&reqdb.zip =&reqdb.magic=&reqdb.wmo=.

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APPENDIX A PHOTO LOG

Preliminary Jurisdictional Determination Summersun Greenhouse

Looking north from W2, March 15, 2018.

Looking north from W5, March 15, 2018.

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W9 looking west, March 15, 2018.

W10 looking west, March 15, 2018.

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Creek bed looking upstream from drainage (W6), Drainage feature (W6) looking south, March 15 March 15 2018. 2018.

Creek bed looking upstream, March 15 2018.

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W1 Soil Pit, March 15 2018. W2 Soil Pit, March 15 2018.

Mixed matrix observed in W2, March 15 2018. W3 Soil Pit, March 15 2018.

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W4 Soil Pit, March 15 2018. W5 Soil Pit, March 15 2018.

Depleted matrix observed in W5, March 15 2018. W6 Soil Pit, March 15 2018.

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Standing water with sheen observed in W6 Soil W7 Soil Pit, March 15 2018. Pit, March 15 2018.

W8 Soil Pit, March 15 2018. W8 Standing water, March 15 2018.

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W10 Soil Pit, March 15 2018.

W11 Soil Pit, March 15 2018.

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W12 Soil Pit, March 15 2018.

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APPENDIX B WETLAND DATA FORM

Summersun Greenhouse

APPENDIX C WASHINGTON STATE WETLAND RATING FORM: 2014 UPDATE

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April 2018, Final Cardno C-1 SummersunGreenhouse_PJD_Report_Final.docx

About Cardno Cardno is an ASX-200 professional infrastructure and environmental services company, with expertise in the development and improvement of physical and social infrastructure for communities around the world. Cardno’s team includes leading professionals who plan, design, manage, and deliver sustainable projects and community programs. Cardno is an international company listed on the Australian Securities Exchange [ASX:CDD].

Cardno Zero Harm At Cardno, our primary concern is to develop and maintain safe and healthy conditions for anyone involved at our project worksites. We require full compliance with our Health and Safety Policy Manual and established work procedures and expect the same protocol from our subcontractors. We are committed to achieving our Zero Harm goal by continually improving our safety systems, education, and vigilance at the workplace and in the field. Safety is a Cardno core value and through strong leadership and active employee participation, we seek to implement and reinforce these leading actions on every job, every day.

www.cardno.com

Buffer Buy Down Areas Description Area Rate Cost Running Total A Main site 109,209 sq ft $1.50 /sq ft $163,814 B Pond to north 4,329 sq ft $4.00 /sq ft $17,316 C Pond to west 9,942 sq ft $1.50 /sq ft $14,913 D Pond NW corner 1,360 sq ft $4.00 /sq ft $5,440 E East of Bldgs D & E 3,878 sq ft $4.00 /sq ft $15,512 F South of Bldg F 1,295 sq ft $4.00 /sq ft $5,180 $222,175 G Path to bridge 235 sq ft $4.00 /sq ft $940 H Path S of bridge 374 sq ft $4.00 /sq ft $1,496 I Walk & lawn at SE 2,953 sq ft $1.50 /sq ft $4,430 $229,040 J Main area at SE 19,659 sq ft $1.50 /sq ft $29,489 $258,529 K Wetland buffer W of lawn 750 sq ft $4.00 /sq ft $3,000 L Wetland buffer E of lawn 2,684 sq ft $4.00 /sq ft $10,736 $272,265

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1 Site Plan - Buffer Buy-Down Areas Project No. A1.1A Scale: 1" = 30'-0" 18-015A

A1.1

STREAM & WETLAND STUDY WITH MANAGED ECOSYSTEM ALTERNATIVE & CONCEPTUAL ENHANCEMENT PLAN

FOR

HOUSING AUTHORITY OF SKAGIT COUNTY FAMILY HOUSING 4100 East College Way Mount Vernon, WA 98273

Skagit County Parcels P24832 & P113507 City of Mount Vernon, WA Bachman Environmental Job No. 2022

August 14, 2020

For: Housing Authority of Skagit County Attn: Melanie Corey 1650 Port Drive Burlington, WA 98233

Bachman Environmental, LLC

P.O. Box 471 ! Anacortes, WA 98221 Ph. 206.963.2909 ! [email protected]

TABLE OF CONTENTS

INTRODUCTION ...... 4 PURPOSE ...... 5 PROJECT DESCRIPTION ...... 5 MANAGED ECOSYSTEM ALTERNATIVE ...... 6 ASSESSMENT METHODS ...... 7 FIELD METHODS ...... 7 DOCUMENT REVIEW ...... 8 Discussion ...... 8 FIELD INVESTIGATION ...... 9 Overview ...... 10 DELINEATION RESULTS ...... 11 Wetland A ...... 11 Wetland B ...... 11 4.2.2 WETLAND BUFFERS ...... 12 WETLAND FUNCTIONS AND VALUES ASSESSMENT ...... 12 Methods ...... 12 Assessment ...... 12 WILDLIFE OBSERVATIONS ...... 14 FISH & WILDLIFE HABITAT CONSERVATION AREAS ...... 14 On-site Tributary – Type F ...... 14 Off-site Trumpeter Creek – Type F ...... 14 ALTERNATIVES ANALYSIS ...... 15 IMPACT EVALUATION ...... 16 EXISTING CONDITIONS ...... 16 DIRECT IMPACTS ...... 16 CONSERVATION MEASURES ...... 16 EFFECTS OF STORM WATER MANAGEMENT ...... 16 CLEARING AND GRADING IMPACTS ...... 17 EFFECTS OF INCREASED NOISE ...... 17 LIGHT OR HUMAN INTRUSION ...... 17 TEMPORARY CONSTRUCTION IMPACTS ...... 18 MITIGATION APPROACH ...... 18 CUMULATIVE IMPACTS ...... 19 CONCLUSION ...... 19 BUFFER RESTORATION/ENHANCEMENT PLAN ...... 19 OVERVIEW & CONSTRUCTION SEQUENCE ...... 19 PLANT SCHEDULES ...... 20 Planting Zone #1: Stream Buffer Plantings (10,580 SF) ...... 20 Planting Zone #2: Live Willow and Dogwood Stakes in Wetland B (267 SF) ...... 21 Planting Zone #3: Wetland Buffer Plantings (7,770 SF) ...... 21 CRITICAL AREA SIGNS ...... 22 POST-MITIGATION FUNCTIONS AND VALUES ...... 22 PROJECT NOTES ...... 23 GOALS, OBJECTIVES, AND PERFORMANCE STANDARDS ...... 24 ii GOAL 1. ESTABLISH A NATIVE SCRUB-SHRUB/FOREST HABITAT ...... 24 Performance standards: ...... 24 Evaluation method: ...... 25 Contingency: ...... 25 GOAL 2. ESTABLISH STRUCTURAL COMPLEXITY FOR A FUNCTIONAL LIFT IN FAUNAL SUPPORT...... 25 Performance standards ...... 25 Evaluation method: ...... 25 Contingency: ...... 25 GOAL 3. ESTABLISH HABITAT COMPLEXITY WITH LARGE PIECES OF WOOD ...... 25 Performance standards ...... 25 Evaluation method: ...... 25 Contingency: ...... 26 PROJECT MONITORING AND MAINTENANCE PROGRAM ...... 26 VEGETATION MONITORING ...... 26 MAINTENANCE ...... 26 CONTINGENCY PLAN ...... 26 ESTIMATED PROJECT COST ...... 27 USE OF THIS REPORT ...... 27 REFERENCES ...... 28

LIST OF ATTACHMENTS Corps of Engineers Wetland Determination Data Forms (S1-S5) Department of Ecology Rating Form with Rating Figures " Figure 1: Vegetation & Hydroperiods " Figure 2a: 1KM Polygon Around Units A & B " Figure 2b: 1KM Polygon Around Unit C " Figure 3: 303(d) Listed Waters

Critical Areas and Conceptual Enhancement Plan (Sheet 1of 1)

iii INTRODUCTION

The Housing Authority of Skagit County (HASC), herein referred to as the applicant, proposes to construct 51 multi-family residential units within six structures on the subject site located at 4100 E College Way (formerly the site of Summersun Greenhouse & Nursery).

The subject site consists of two parcels (P24832 & P113507), totaling 4.58 acres in the city of Mount Vernon, WA. The Public Land Survey System (PLSS) locator for this site is Section 15, Township 34N, Range 04E, W.M.

Figure A. Project vicinity map. Subject property highlighted in yellow. Image source: Skagit County iMap.

Bachman Environmental performed a site investigation on May 11, 2020 to identify and delineate jurisdictional wetlands and streams. In the project vicinity are two Type F streams, two Category III wetlands, and one Category II wetland.

The two identified streams include Trumpeter Creek located off-site to the north and its tributary situated on the subject site. Both streams are documented habitats for Coho salmon and cutthroat trout. No state or federally listed threatened or endangered species are documented or known to occur on-site or in the vicinity.

Through careful site design, the applicant intends to altogether avoid direct impacts to critical areas. However, to achieve the site's project goals, the applicant is proposing to implement the Managed Ecosystem Alternative approach to reduce standard buffers. This approach requires paying into the City’s Critical Areas Management Fund and implementing on-site buffer restoration/enhancement measures.

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

4 This report facilitates efforts to address the Mount Vernon Municipal Code (MVMC) Section 15.40 and ensure that environmental impacts are avoided or minimized, as required during the permitting process.

PROJECT PURPOSE AND DESCRIPTION

PURPOSE This development project aims to meet the needs for more affordable housing in the urban areas of Skagit County.

PROJECT DESCRIPTION The proposed project involves constructing a 51-unit multi-family residential apartment complex comprising a total of six buildings. The apartment buildings will vary in height from single to 3-stories. The majority of the 2 and 3-bedroom units are intended for farmworker families. The 1-bedroom units and several of the 2-bedroom units are intended for people with disabilities and homeless veterans. The project includes outdoor parking, lawn areas, landscaping, and stormwater detention.

Access into the site will be gained via the existing access driveway in the southwestern part of the site. The project does not propose the expansion of paved areas. Instead, some pavement is to be removed to maintain a 25-foot maximum managed buffer for the on-site stream. The access road construction is consistent with the performance standards outlined under MVMC 15.40.040(E).

The applicant anticipates that many of the tenants will have families with young children. To provide a safe outdoor space of enjoyment for families, the applicant has identified the southeastern corner of the subject site as an ideal area to dedicate for passive recreation. The preferred plans include constructing new bridge access over the on-site stream channel and connect the bridge to paved trail. The designated area for a short loop trail will be cleaned up, remnant nursery debris and trellises removed, invasive blackberry removed, and converted to meadow grass with scattered trees in the canopy. The bridge will have footings outside the ordinary high water mark and above the stream bank.

As part of the proposal for a new bridge, the applicant will remove an existing wooden bridge currently not suitable for regular pedestrian use. Following removal of the existing bridge, bare soils will be restored with grasses and ground covers. The proposed bridge will be consistent with the performance standards outlined under MVMC 15.40.040(G). Additionally, the applicant understands that a Hydraulic Project Approval (HPA) is needed from the Washington Department of Fish and Wildlife (WDFW) as part of new bridge construction. During a consultation with WDFW, the appropriate timeframe for the bridge installation and removal of the old bridge will be determined.

To achieve the development goals on this site, the applicant plans to implement Mount Vernon’s Managed Ecosystem Alternative program (a.k.a. buffer “buy down”), as described in detail in Section 3.0. The program requires the applicant to pay into the City's Critical Areas Management Fund and restoration and enhancement of remaining buffer areas, where appropriate.

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

5 The project proposes to restore and enhance a total of 18,350 (10,580 + 7,770) square feet of buffer areas and 267 square feet of wetland areas. Restoration and enhancement involve removing existing paved surfaces, trash, and invasive species and then establishing native vegetation and large woody debris to protect and improve the site's ecological functions.

MANAGED ECOSYSTEM ALTERNATIVE

The applicant plans to implement the city of Mount Vernon’s unique Managed Ecosystem Alternative Program (MVMC 15.40.110) to achieve reductions of the standard buffers. This program involves buffer restoration/enhancement and a monetary contribution to the City’s Critical Areas Management Fund.

On this site, the Managed Ecosystem Alternative Program will apply to the buffers of three critical areas within the development corridor. These critical areas are identified below:

• Type F stream (<1% gradient) known as Trumpeter Creek, located off-site to the north; • Category II wetland labeled as Wetland C, located off-site to the east; and • Category III wetlands labeled as Wetlands A & B and Type F tributary (1-2% gradient), located on-site as a combined system.

The critical areas listed above are considered Maintain Systems, as the abutting on-site upland areas are not intact with more than 50 feet of buffer vegetation and have been manipulated by ornamental landscaping, turf, hardened surfaces, rock, and fill associated with the preceding nursery and greenhouse uses on the site.

For above-listed critical areas, located within the Trumpeter Creek Subbasin, the Maximum and Minimum Managed Buffer Widths are as follows:

Table 1: Steams & Wetlands – Maximum and Minimum Managed Buffer Width Maintained System Type F Streams Max Manage Buffer Min Managed Buffer Off-site Trumpeter Creek, low gradient 50’ 25’ On-site tributary, medium gradient 25’ 25’ Maintained System Category II & III Wetlands Max Manage Buffer Min Managed Buffer Wetlands A, B, & C 50’ 25’

Note: The City of Mount Vernon Streams, Drainage Basins, & Potential Wetlands Map was used in identifying subbasin, stream types, and gradients associated with each relevant stream reach.

For the development of the subject site, all paved surfaces, buildings, lawns, graded areas comprised of structural fill (berms and side slopes) are included in the buffer buy down calculations. The new impervious surfaces between the Management Zone Boundary (200') and the identified Maximum Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

6 Managed Buffers amount to 125,091 square feet and the new impervious surfaces between the Maximum Managed Buffer and the critical areas amount to 17,735 square feet. No native canopy removal is proposed. The Buffer Buy Down sheet A1.1 depicts the anticipated new impervious surface areas. The table below establishes the monetary contribution to the city's critical areas management fund per the management fund schedule displayed under MVMC 15.40 Table 15.40.110(C).

Table 2: Monetary Contributions for New Impervious Surfaces1 within Specified Management Zones New impervious surfaces Proposed Impervious within the defined Cost per sq. ft. Estimated Costs Surfaces (sq. ft) management zones Between 200' Management Zone & Maximum Managed 125,091 $1.50/sq. ft. $187,637.00 Buffers Maximum Managed Buffers 17,735 SF $4.00/sq. ft. $70,940.00 & critical area Total = $258,577.00

As part of this plan, the remaining buffers between the critical areas and the proposed development will be marked on-site with signs to ensure long-term protection. The areas will be enhanced with native vegetation and permanently protected. Approximately 18,350 (10,580 + 7,770) square feet of buffer areas and 267 square feet of wetland areas are planned for restoration and enhancement.

Summary As proposed in the table above, the applicant will contribute a total of $258,577.00 to the City’s Critical Areas Management Fund and enhance the remaining designated buffer areas with native vegetation (see Section 10.0 for enhancement plan). This proposal adequately addresses the requirements under the Managed Ecosystem Alternative requirements under MVMC15.40.110. The remainder of this report includes a detailed wetland site assessment, supplemental stream study, alternative analysis, impact assessment, and buffer restoration/enhancement plan to comply with all other goals and objectives under MVMC15.40.

ASSESSMENT METHODS

FIELD METHODS Wetlands Wetland areas are determined using the routine determination approach described in the Corps of Engineers Wetlands Delineation Manual (Environmental Laboratory 1987) and the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (Version 2.0) (U.S. Army Corps of Engineers 2010). This guidance complies with Mount Vernon Municipal Code (MVMC), Chapter 15.40.

1 Impervious Surfaces are defined as "surfaces which shed rather than contain and filter stormwater, including but not limited to paved, graveled or lawn surfaces, and other surfaces with similar runoff characteristics as determined by the director, and surfaces covered by structures." Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

7 To be considered a wetland, an area must have hydrophytic vegetation, hydric soils, and wetland hydrology. Bachman Environmental collected data on these parameters in areas representative of typical site conditions.

Streams The ordinary high water mark (OHWM) of streams is evaluated using the methodology described in the Washington State Department of Ecology document Determining the Ordinary High Water Mark for Shoreline Management Act Compliance in Washington State (October 2016 Final Review) (Publication no. 16-06-029). The identified stream was classified according to the water typing system provided in the Washington Administrative Code (WAC), section 222-16-030.

DOCUMENT REVIEW Before the site visit, Bachman Environmental reviewed several online public resources. The following were considered:

• National Wetland Inventory (NWI) maps of the U.S. Fish and Wildlife Service (USFWS) • Washington Dept. of Fish & Wildlife (WDFW) Priority Habitats & Species (PHS) on the web • Washington Dept. of Natural Resources (WDNR) Forest Practices Application Review System (FPARS) water type map. • WDFW SalmonScape • Soil Web on Google Earth • Washington State Coastal Atlas • City of Mount Vernon Streams, Drainage Basins, & Potential Wetlands Map

Discussion National Wetland Inventory (NWI) maps of the U.S. Fish and Wildlife Service (USFW) The U.S. Fish and Wildlife Service (FWS) established the NWI to conduct a nationwide inventory of U.S. wetlands to provide biologists with information on the distribution and type of wetlands to aid in conservation efforts. Mapped wetlands were produced from reconnaissance level interpretation of vegetation, hydrology, and topography found on high altitude imagery.

NWI displays two palustrine emergent wetlands and a palustrine shrub-shrub wetland on-site and several more palustrine emergent wetlands in the vicinity.

Washington Dept. of Fish & Wildlife (WDFW) Priority Habitats & Species (PHS) on the web The PHS on the web displays two freshwater emergent wetlands on the site and documented occurrence/migration of Coho salmon (Oncorhynchus kisutch) and Cutthroat (Oncorhynchus clarki) within Trumpeter Creek and its on-site tributary.

Washington Dept. of Natural Resources (WDNR) Forest Practices Application Review System (FPARS) water type map The FPARS displays both Trumpeter Creek (located off-site to the north) and the on-site tributary as Type F stream channels.

WDFW SalmonScape Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

8 Salmonscape displays a documented presence of Coho.

Washington State Coastal Atlas According to the Washington State Coastal Atlas Flood Hazard Areas Map, the subject site is within a special flood hazard area (SFHA) labeled as Zone A.

Soil Web on Google Earth According to the Web Soil Survey, the site is comprised of Skipopa silt loam (0 to 3 percent slopes) and Bellingham silt loam. The Skipopa series is described as very deep, somewhat poorly drained soil which formed on terraces. The Bellingham series is comprised of very deep, poorly drained soil which formed in depressions. The Bellingham series is listed as hydric soil in Washington State.

City of Mount Vernon Streams, Drainage Basins, & Potential Wetlands Map The Mount Vernon map displays Trumpeter Creek to the north as a Fish Bearing Stream on a Low Gradient (slope 0-1%) and the on-site tributary as a Fish Bearing Stream on a Medium Gradient (slope >1% and <2%). The map also displays wetlands associated with the on-site tributary.

FIELD INVESTIGATION Bachman Environmental performed a field investigation on May 11, 2020. During the site visit, the weather was mostly sunny, and the temperature was 72-76 degrees Fahrenheit. The study area included the entire subject property and off-site areas that could be observed on the subject property and from public roads.

Bachman Environmental used aerial photograph interpretation and published inventories to assess off-site conditions. Bachman Environmental did not access or field-verify off-site conditions beyond what could be observed from public roads and across property or fence lines because permission to access adjacent properties was not granted. Critical areas could occur in the areas that could not be physically observed or have not been inventoried.

LANDSCAPE SETTING

The subject site is accessed from an existing driveway entrance in the southwest corner, off College Way. It is situated on a gentle slope (1-2% gradient) to the northeast. A perennial stream channel flows from southwest to northeast through the southeastern corner.

For decades, the subject site and abutting lands to the north were occupied by a commercial nursery. Within the last 10-15 years, the lands have been gradually converted to residential use. The subject site is the last to be redeveloped.

More than three-quarters of the subject site is devoid of intact native vegetation. It currently consists of a mix of paved driveways, walkways, and abandoned buildings left over from the nursery. There are remnant nursery-related materials and features, such as ground covers, water features, trellises, and ornamental plant species growing among native pioneer species.

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

9 The only well-vegetated area is within the southeastern corner, predominantly of pioneer red alder, black cottonwood in the canopy with Himalayan blackberry in the understory.

Figure B. Existing conditions of the subject property (outlined in yellow). Image source: Google Earth

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© 2020 Google 400 ft © 2020 Google

WETLAND ASSESSMENT

Overview Near the project, there are two on-site wetlands and one off-site wetland. The on-site wetlands are labeled as Wetlands A and B, and the off-site wetland is labeled as Wetland C in this report and respective drawings.

Wetland A was rated based on a depressional hydrogeomorphic (HGM) classification. It received a total score of 18 points for functions on the Ecology 2014 Wetland Rating Form. The score of 18 points equates to a Category III classification.

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

10 Wetland B is a slope wetland sourced by groundwater seeps located on the west side of the on-site stream. It received 16 points for functions on the 2014 Wetland Rating Form, which equates to a Category III classification.

The off-site Wetland C is a depressional wetland previously identified and recorded as a Category II wetland under the preceding classification system. Since the adjacent property owner denied access to verify the wetland boundary, we based our approximations of the wetland edge using a recorded city plat number LU06-057. We noted the general condition and characteristics of the wetland, looking over the existing electrical fence and looking at available online resources. According to the 2014 updated Wetland Rating Form, Wetland C received a total score of 20 points for functions, which equates to a Category II classification.

Table 3. Wetlands within the Project Area Wetland Classification Wetland Wetland Ecology Local Cowardin HGM Size (2014 update) Jurisdiction A PFO1C Depressional III III 440 SF B PSS1B Slope III III 304 SF C PFO1C Depressional II II 50,000 SF

DELINEATION RESULTS Wetland A The soil profile within Wetland A is very dark grayish brown (10YR 3/2) silt loam from the surface to 4 inches below, and very dark gray (10YR 3/1) silt loam with up to 15% dark brown (10YR 3/3) redox features from 4-16 inches below the surface. These soil characteristics most closely resemble the hydric soil indicator of Redox Dark Surface (F6).

The dominant vegetation within the area identified as Wetland A consists of red alder (Alnus rubra, FAC), red-osier dogwood (Cornus sericea, FACW), Himalayan blackberry (Rubus armeniacus, FAC), and field horsetail (Equisetum arvense, FAC).

Positive indicators for hydrology included two secondary indicators: Geomorphic Position (D2) and FAC-Neutral Test (D5).

Conclusion: Based on the presence of positive field indicators for hydrophytic plants, hydric soils, and wetland hydrology, the investigated area meets the criteria of a wetland.

Wetland B The soils underlying the area identified as Wetland B are very dark grayish brown (10YR 3/2) silty clay loam from the surface to 6 inches below and greenish-gray (Gley 5/10Y) silt loam with 30% dark yellowish-brown (10YR 3/6) redox features from 6 to greater than 16 inches. The soil profile most closely resembled the hydric soil indicator of Loamy Gleyed Matrix (F2).

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

11 The dominant vegetation in Wetland B is comprised of Himalayan blackberry (Rubus armeniacus, FAC), field horsetail (Equisetum arvense, FAC), and reed canarygrass (Phalaris arundinacea, FACW).

Positive indicators for hydrology included Saturation (A3).

Conclusion: Based on the presence of positive field indicators for hydrophytic plants, hydric soils, and wetland hydrology, the investigated area meets the criteria of a wetland.

4.2.2 WETLAND BUFFERS The dominant vegetation in upland areas adjacent to the wetlands included red alder (Alnus rubra, FAC), bitter cherry (Malus fusca, FAC), Himalayan blackberry (Rubus armeniacus, FAC), snowberry (Symphoricarpos albus, FAC), salmonberry (Rubus spectabilis, FAC), reed canary grass (Phalaris arundinacea, FACW), herb Robert (Geranium robertum, UPL), and field horsetail (Equisetum arvense, FAC).

The soils underlying the areas mapped as uplands are dark grayish brown (10YR 3/2) from the surface to 16 inches and dark grayish brown (10YR 4/2) below 16 inches. No redox features were detected. No positive or secondary hydrology indicators were detected.

Conclusion: Based on the lack of all three wetland field indicators, the areas mapped as non-wetlands do not meet wetland criteria.

WETLAND FUNCTIONS AND VALUES ASSESSMENT Methods Bachman Environmental referred to the best available science documentation adopted by the city of Mount Vernon as part of the development of this functions and values analysis. Documents included the Washington Department of Ecology Wetland Rating System (2014 update) and the Guidebook to Assessment of Riverine, Slope, and Depressional Waters/ Wetlands in the City of Mount Vernon, Washington. Functions considered include hydrology, water quality/ biogeochemistry, plant community, habitat.

Assessment Wetland A Wetland A is a small, shallow wetland with a depressional hydrogeomorphic (HGM) class located adjacent to the south bank of the on-site stream channel. Although it is adjacent to the stream, there was no obvious outlet detected. Due to the dense overstory of red alder, the understory is relatively sparse. Generally, adjacent buffers are degraded to the north and off-site to the east but are moderately intact to the south.

Because it has no outlet and is depressional, it has a moderate potential to provide hydrologic control functions. Being located within a 100-year flood zone makes this wetland highly valuable to society concerning hydrologic control functions.

Wetland A contains a good amount of leaf litter and woody debris, but overall sediment movement is low. Adjacent buffer conditions are moderate to poor. These existing conditions limit the wetland's ability to offer water quality functions on-site. The wetland's proximity to high-intensity land uses and 303(d)-listed waters elevate this wetland’s value on the landscape and societal levels. Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

12

Plant diversity within Wetland A is poor. Furthermore, special features or interspersions of habitats are low, and land-use intensity over most of the surrounding landscape is high. As such, Wetland A offers low-level habitat functions to the subject site and the surrounding landscape. Its proximity to riparian and instream habitat increases its value to society somewhat.

Based on existing conditions, the typical depressional wetland functions offered by Wetland A are limited on-site and on the landscape levels but are higher on the societal level.

Wetland B Wetland B contains a slope hydrogeomorphic (HGM) class and appears to be sourced by a groundwater seep. Hydrology flows at the surface in a single direction, without being impounded, toward the on-site stream where it enters. It is sparsely vegetated, predominantly with invasive species, and lacks leaf litter and woody debris. Adjacent buffer conditions and continuity are degraded.

Based on existing conditions, Wetland B offers severely limited abilities to provide hydrologic and biogeochemical/water quality functions. However, being located within a 100-year flood zone makes this wetland highly valuable to society concerning hydrologic control functions. Wetland B's proximity to high-intensity land uses and 303(d)-listed waters elevate this wetland’s value on the landscape and societal levels.

Plant diversity within Wetland B is poor, and special features and interspersions of habitats are low. The land-use intensity in the surrounding landscape is high. Wetland B, therefore, has a low potential to offer habitat functions to the subject site or the surrounding landscape. Its proximity to riparian and instream habitat increases its value to society somewhat.

Based on existing conditions, the typical slope wetland functions offered by Wetland B are limited on- site and on the landscape level but are higher on the societal level.

Wetland C Wetland C abuts the subject development site to the east. It is a shallow depressional wetland comprised of a forested vegetation class with an herbaceous understory dominated by reed canarygrass. The tributary to Trumpeter Creek abuts Wetland C on the south side.

Wetland C has a moderate potential to provide hydrologic control functions on the site. Being located within a 100-year flood zone makes this wetland highly valuable to society concerning hydrologic control functions.

Wetland C's ability to offer water quality functions on-site is moderate. It can support some leaf litter and woody debris from its existing red alder canopy, but overall, sediment movement is low. Adjacent on-site buffer conditions are degraded, but off-site buffer conditions are moderately intact. The wetland's proximity to high-intensity land uses and 303(d)-listed waters elevate this wetland’s value on the landscape and societal levels.

Plant diversity within Wetland C is poor, but habitat interspersion is moderate. Land-use intensity over most of the surrounding landscape is high. As such, Wetland C offers reasonable levels of habitat Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

13 functions to the subject site or the surrounding landscape. Its proximity to riparian and instream habitat increases its value to society somewhat.

Based on existing conditions, the typical depressional wetland functions offered by Wetland C are moderately high for water quality and hydrologic functions and moderate for wildlife habitat. This is reflected by its score of 20 points on the DOE wetland rating form.

WILDLIFE OBSERVATIONS Avian species detected on the site are typically adapted to urban settings. These included: common crow, European starling, robin, house finch, and black-capped chickadee. Mammalian species detected in the area included whitetail deer. Juvenile salmonids (species not confirmed) were observed within the on-site stream channel.

FISH & WILDLIFE HABITAT CONSERVATION AREAS

On-site Tributary – Type F The drainage course identified on this site is a tributary of Trumpeter Creek. A perennial stream, it enters the site from the south via a 6-foot wide corrugated metal pipe with a gravel bottom. It flows in a moderately incised, meandering channel approximately 10 feet wide between the bankfull widths in the southeastern corner before exiting the site to the east. It eventually flows into Trumpeter Creek, about 570 feet downstream to the northeast. This stream meets the criteria of a Type F stream because it is wider than 2 feet on a <2% gradient. It has also been documented as habitat for Coho salmon and cutthroat trout.

The vegetated corridor in which this stream flows is limited to less than 25 feet wide. The dominant vegetation in the riparian area is dominated by red alder, black cottonwood, willows, and Himalayan blackberry. There are an overhanging tree canopy and woody debris in the channel, but the overall potential for large woody debris recruitment remains moderate.

No sloughing or slope instability was observed. Rooted vegetation appears to maintain adequate bank integrity.

The stream was flowing with clear water at the time of the site investigation. Its substrate consists of sand and gravel. The sinuosity of the channel has resulted in a suitable pool and riffle habitat for salmonids. At the time of the site visit, juvenile salmonids (species not confirmed) were observed within the on-site stream channel.

Off-site Trumpeter Creek – Type F The channel of Trumpeter Creek flows off-site within as little as 16 feet from the northern property line. This stream segment was once degraded and in a closed system but was restored within the last ten years as part of a land-use action to convert the area from agriculture greenhouses to residential use.

The top of the Trumpeter Creek (Type F) in the abutting property to the north has been identified using existing surveys and LIDAR images. Bachman Environmental did not obtain access to examine Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

14 the off-site segment of Trumpeter Creek in the vicinity of the project area. However, it is known to meet the criteria of a Type F stream because it is wider than 2 feet on a low gradient. It has also been documented as habitat for Coho salmon and cutthroat trout.

Upon examining current aerial imagery and observations from the subject site, the vegetated corridor in which this stream flows is about 100 feet wide and comprises a diversity of young evergreen/deciduous trees and shrubs as part of the channel restoration project. It is presumed that the off-site segment of Trumpeter Creek near the proposed project is functioning as designed.

ALTERNATIVES ANALYSIS

Through careful site design considerations, the applicant’s development plans ensure no direct impacts to wetlands or fish and wildlife habitat conservation areas.

However, total avoidance of buffers cannot be achieved because critical areas and buffers encumber more than three-quarters of the subject site. The project needs a minimum number of apartment units to make it economically feasible. The layout also requires a minimum number of parking spaces, lawn/landscaping areas, a stormwater detention facility, relatively quiet and private space for the older tenants, and safe outdoor space for the tenants with families. To achieve these minimum standards, encroachment into currently degraded buffer areas is necessary.

Given the site's constraints, the applicant's design team explored several different design scenarios, particularly for stormwater management. The preferred method being proposed includes a single stormwater detention pond, without walls, in the northern part of the site. This approach was determined to have the least impact on stream and wetland buffers compared to alternative designs that involved two ponds, including one in the southern part of the site that would directly discharge to the stream.

All temporarily disturbed areas and areas proposed for graded berms and side slopes will be revegetated with grasses and landscape vegetation or enhancement plantings.

To provide a lift in functions adjacent to critical areas and to ensure permanent protection, the project includes restoration and vegetation enhancement of approximately 18,350 (10,580 + 7,770) square feet of buffer areas and 267 square feet of wetland areas. The plan consists of removing invasive vegetation, trash, and debris, installing critical area signs along the buffer edge, and then implementing a monitoring and maintenance program.

In conclusion, the discussion above demonstrates that significant efforts have been made to avoid, minimize, and mitigate impacts to the greatest extent possible, as required by MVMC 15.40.120.F.2. Improvements to the site will be implemented through buffer enhancement, maintenance, and monitoring measures.

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

15 IMPACT EVALUATION

EXISTING CONDITIONS The hydrologic, biogeochemical, vegetative, and habitat functions of the buffers have been impacted mostly by the historical uses of the site and surrounding areas. Excessive runoff from impervious surfaces from the surrounding landscape has caused some down cut of the on-site channel.

The on-site buffers contain only a narrow swath of established trees along the channel, enough to provide shade. In-channel large woody debris is limited. The buffers also contain a significant amount of invasive plants and the accumulation of rubbish and debris related to abandoned nursery operations. The condition of the on-site stream channel and its riparian management zone is therefore considered moderately degraded.

The off-site segment of Trumpeter Creek was observed from the subject property and appeared to be intact. This is because the stream segment was recently restored and is being carefully monitored and maintained to ensure that it meets the minimum requirements for success. As such, the off-site segment of the riparian area associated with Trumpeter Creek is presumed to be properly functioning.

DIRECT IMPACTS No direct in-stream or wetlands impacts are anticipated.

CONSERVATION MEASURES BMP erosion control measures will be installed on the downslope sides of the construction area between critical and development areas. Once installed, it will be inspected for correct location and functionality. After the site is stabilized, the BMP measures can be removed.

Any inadvertent disturbances within the designated critical areas will be immediately restored.

After installing the buffer enhancement measures, critical area signs will be installed along the buffer perimeter.

EFFECTS OF STORM WATER MANAGEMENT The stormwater management plans have been designed to balance the pre and post-developed hydrologic patterns on the site, according to the 2012 DOE Stormwater Manual, as required by the city of Mount Vernon.

Stormwater from most of the site will be directed to a single stormwater detention pond. The pond is to be constructed in the northern part of the site. It will extend west into the adjacent parcel P24844, which is also owned and managed by HASC. It is designed as a wetland pond surrounded by a berm and planted with appropriate vegetation. Once treated, overflow is designed to outfall toward Trumpeter Creek (approximately 25 feet from the creek) in a rock-lined level spreader trench in the northeastern corner of the site. Please refer to the project engineer's stormwater site plan for more information.

Runoff from the easternmost buildings is designed to discharge into level spreaders along the east side of the property toward the off-site Category II. The level spreader discharge toward the off-site Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

16 wetland is intended to maintain a hydrology source to the wetland, like current conditions. The level spreaders will be placed in the outermost portions of the buffer and slightly depressional to spread the flows out.

No impacts caused by bank erosion or impacts on hydrologic functions are expected. No significant vegetation is expected to be disturbed because the area designated for discharge are currently degraded. The areas surrounding the levels spreaders are planted with native species, which will be adaptable to intermittent sheet flows. Given the existing degraded conditions of the site and anticipated improvements from enhancement and restoration, the proposed enhancement measures are expected to offset the level spreaders' placement.

Overall, the stormwater management plan has been carefully designed to mitigate hydrologic, erosion, water quality, and vegetation impacts to the greatest extent possible.

CLEARING AND GRADING IMPACTS Site preparations will include demolishing and removing existing paved surfaces, structures, and landscape features, and disposing of them in an appropriate facility off-site.

Vegetation clearing will be limited to removing remnant nursery plantings, approximately 1/2 acre of Himalayan blackberry, and pioneer red alder saplings. No significant trees are to be removed within the vegetated riparian areas.

Grading work is expected as part of the site preparations to raise the site above the 100-year floodplain. The anticipated fill ranges from 2 to 5 feet, depending on the area of the site. No grading is proposed in the vicinity of any areas of concern for bank stabilization.

Clearing and grading activities will be mitigated by installing BMP erosion control measures, as described earlier. Exposed soil on the graded berms and side slopes on this site will be grassed or planted according to the project landscape plan.

EFFECTS OF INCREASED NOISE The noise from construction and trucks entering and leaving the site will be limited to daytime hours and temporary. The temporary noise is not expected to impact in-water habitats.

There will be moderate increases in noise in the long term as the land-use intensity increases. Increased noise over the long term is unlikely to significantly impact habitat functions within the riparian area. Any wildlife species using the area are presently adapted to noises from surrounding high-intensity land uses.

LIGHT OR HUMAN INTRUSION The development will have building lights and headlights from cars in parking areas. These are unavoidable in this urban setting. Vegetation enhancement will filter the new lights between the development and critical areas to the greatest extent possible.

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

17 TEMPORARY CONSTRUCTION IMPACTS Temporary construction impacts are expected as part of site preparations and grading work. Before beginning construction, the established critical area buffers shall be identified and marked with orange construction fencing to ensure protection. BMP erosion control measures shall also be installed where appropriate. Any unanticipated clearing will be immediately evaluated and restored according to the city biologist's recommendations.

Construction materials and equipment may be staged in upland areas outside of the designated buffer areas. Following the project's completion, all disturbed areas will be grass seeded and landscaped, as needed.

MITIGATION APPROACH According to Chart #3 of the City’s CAO Guidebook, on-site evaluation of existing conditions is done by city staff or the City's contracted biologist, who provides the prescriptive restoration and enhancement requirements to the applicant. To help expedite this process, Bachman Environmental provides some recommendations in this report. These recommendations are based on the May 11th site assessment results and supporting information in the CAO Guidebook. Below is an overview of the proposed mitigation approach. See Section 10.0 for more details.

The subject site mostly closely resembles a Moderately Degraded Site, as described in the CAO Guidebook. It has moderate to significant disturbance, with abandoned buildings, paved surfaces, landscape features, debris, and ornamental vegetation left from the previous nursery operations. Invasive Himalayan blackberry is a pioneer species occurring throughout the site and within critical areas buffers but is not yet dominant. The analyses provided in this report demonstrate that most of the typical ecological functions have been somewhat impacted. Based on these existing conditions, restoration and enhancement are needed to reestablish ecological functions.

Proposed measures include the restoration and enhancement of all designated buffer areas between the proposed development and critical areas. Essentially, these areas are along the north side of the on-site tributary and Wetland B and the buffer associated with off-site Wetland C.

The areas proposed for enhancement include 18,350 (10,580 + 7,770) square feet of buffer areas and 267 square feet of wetland areas. Restoration/enhancement first involves site preparations, such as identifying the proposed buffer areas on-site and removing remnant paved surfaces, landscape features, trash/debris, ornamental and invasive species. Pioneer red alder saplings will be thinned, as needed. These preparations are likely to require motorized equipment, such as a track hoe. The undesirable items to be removed will be exported off-site to an appropriate disposal facility.

Following the site preparations, the designated areas will be planted with a diversity of native trees, shrubs, and herbs. See Section 10.0 for the recommended plant schedule.

To provide a functional lift within the riparian corridor, up to 8 pieces of large woody debris will be placed within the buffer adjacent to the stream channel.

Note: While the CAO Guidelines list micro-depressions as a possible restoration measure, these are not recommended here since the buffer north of the on-site stream channel is so narrow, and the Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

18 lands south of the channel currently do support some micro-depressional topography (including Wetland A).

Overall, the proposed mitigation measures are expected not only to replace but also to improve the site's functions. Upon approval of this conceptual mitigation plan, a final mitigation plan shall be prepared for city approval.

CUMULATIVE IMPACTS The combination of impacts described above is the cumulative impacts associated with the project.

Much of the project area is currently degraded due to historical land-use practices. Native forest vegetation was cleared several decades ago, and surfaces were previously modified for agricultural use and greenhouses.

The project will result in increased land-use intensity and new impervious surfaces. On-site stormwater management is expected to balance the hydrologic flow patterns and allow only clean stormwater to enter downstream systems. Other measures, including erosion control measures and buffer enhancement, will offset the cumulative impacts to the greatest extent possible.

CONCLUSION The project is expected not to detrimentally affect the fish and wildlife habitat functions. This conclusion is based on the fact that buffer impacts have been minimized and mitigated to the greatest extent possible. BMP erosion control measures and all other mitigation measures will be fully implemented to ensure the permanent protection of critical areas and buffers.

BUFFER RESTORATION/ENHANCEMENT PLAN

OVERVIEW & CONSTRUCTION SEQUENCE The enhancement plan intends to establish a diversity of native trees and shrubs, structural complexity, and hydrologic and water quality management functions within the buffer (see Section 14.0 Goals, Objectives, and Performance Standards).

Measures for buffer enhancement will generally follow the sequence of steps listed below: 1) Conduct a pre-construction meeting with the landscape contractor, city's biologist, and consulting biologist to discuss the existing conditions, site preparation, and construction methods, and planting. 2) Before site clearing, all trees and native vegetation to be protected will be identified. Orange construction fencing will be installed around the drip lines of the trees and the shrubs. Erosion control fencing will be installed on-site, along the downslope side of the work area to prevent erosion and sedimentation from entering the stream channel. 3) Commence with the removal of paved areas, remnant landscaped features, trash/debris, and invasive blackberries using appropriate mechanical equipment, which will be agreed upon during the pre-construction meeting.

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

19 4) Blackberry cuttings should be exported off-site or converted to a fine mulch if left on-site. Multiple visits for mowing may be needed throughout a single growing season to promote the lasting removal of blackberries. 5) Where blackberry areas are removed, the bare areas created must be stabilized with mulch or revegetated with native plants to prevent erosion and repopulation of invasive species. 6) Where designated buffers are temporarily disturbed from grading work or removal of hard surfaces, additional topsoil will be brought to those areas. Up to 12" of quality topsoil with high organic content will be used. The estimated quantities of topsoil needed is not likely to exceed 400 cy. 7) Apply 4-6 inches of wood chips to bare ground areas from the top of the bank to the buffer's outer extent to minimize potential regrowth of invasive plants and help protect the new plantings. Following this method, any regrowth of invasives can be removed by hand-held tools and covered again with wood chips until the project is deemed successful. 8) Distribute up to 8 pieces of large wood throughout the buffer areas, near the top of the bank. The wood pieces will come from conifer species (such as Douglas fir) and will be a minimum 16 inches thick and at least 12-25 feet long. The wood may or may not have root balls attached. 9) The city’s consulting biologist will conduct an inspection to determine the correct site and wood preparation. 10) When City’s biologist deems it appropriate, the final step is to plant the native plants in the late fall or early spring (following successful eradication of blackberries). 11) Plant the different zones according to the proposed planting schedules below. Ensure that the bases of all potted plants are mulched and that all plants are marked with a ribbon.

PLANT SCHEDULES There are three proposed planting zones for this enhancement project. These zones are labeled as Planting Zones 1-3 below and on the accompanying plan. • Planting Zone #1 consists of trees, shrubs, and ferns over the remainder of the northern on- site stream buffer; • Planting Zone #2 is a list of willow and red-osier dogwood whips to be planted in Wetland B; and • Planting Zone #3 consists of trees, shrubs, and ground cover to be planted throughout the remainder of the Wetland C buffer.

Please note: Conditions on-site, especially following site preparations, could change. The plant species, quantities, and sizes recommended in the following planting schedules may be adjusted if deemed necessary during a pre-planting meeting or installation. Any deviations from the approved mitigation plan would be addressed in an as-built plan.

Details for the different planting zones are provided as follows:

Planting Zone #1: Stream Buffer Plantings (10,580 SF) A total of 10,580 square feet of the stream buffer will be enhanced with the list of native plants provided below. This list of plant species was selected based on their high likelihood of survivability on this site.

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

20 Plants will be arranged in two to three like species to simulate natural, asymmetric vegetation establishment patterns. Trees will be planted 12 feet apart and shrubs 3 feet apart in a triangular planting pattern. Roughly 25% of the area will be planted with fern clusters 2 feet apart.

Planting Zone #1 (10,580 SF) Type Common Name Scientific Name Size Spacing (ft) Quantity T Western red cedar Thuja plicata 1-gal 12 50 T Western hemlock Tsuga heterophylla 1-gal 12 50 T Douglas fir Pseudotsuga menziesii 1-gal 12 50 T Big leaf maple Acer macrophyllum 1-gal 12 20 S Beaked hazelnut Corylus cornuta 1-gal 3 400 S Oso-berry Omelaria cerasiformis 1-gal 3 400 S Vine maple Acer circinatum 1-gal 3 400 S Salmonberry Rubus spectabilis 1-gal 3 400 S Ocean spray Holodiscus discolor 1-gal 3 384 S Red elderberry Sambucus racemosa 1-gal 3 384 S Serviceberry Amelanchier alnifolia 1-gal 3 300 S Bitter cherry Prunus emarginata 1-gal 3 300 G Sword fern Polystichum 4”pot 2 1,500

Planting Zone #2: Live Willow and Dogwood Stakes in Wetland B (267 SF) Wetland B (267 SF) is a slope wetland located just above the north bank of the on-site stream channel. Invasive blackberries dominate this small wetland area. To reestablish vegetation in this wetland, dense plantings of willow and dogwood whips are recommended. An experienced landscape contractor should install the stakes. Stakes will be cut from living trees or shrubs. Each stake will be a minimum of 3 feet long and 0.5 - 2 inches in diameter. Stakes will be left in water for at least 12 hours before planting. Typically, the best time to plant willow stakes is when they are dormant. The stakes should be placed a minimum 18 inches deep with the buds pointing up. The stakes will be randomly placed approximately 2.5-3 feet apart in a triangular planting pattern. The following list of stakes is proposed.

Planting Zone #2 (267 SF) Common Name Scientific Name Size Spacing (ft) Quantity Red-osier dogwood Cornus sericea stake 2.5-3 40 Pacific willow Salix lucida stake 2.5-3 35 Scouler’s willow Salix scouleriana stake 2.5-3 25

Planting Zone #3: Wetland Buffer Plantings (7,770 SF) A total of 7,770 square feet of the remaining Wetland C (off-site) and a portion of the Trumpeter Creek buffer that encumber the development site will be enhanced with the list of native plants provided below. This list of plant species was selected based on their high likelihood of survivability on this site.

Plants will be arranged in two to three like species to simulate natural, asymmetric vegetation establishment patterns. Trees will be planted 12 feet apart and shrubs 3 feet apart in a triangular planting pattern. Roughly 30% of the area will be planted with ferns and Oregon grape 2 feet apart as ground cover.

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

21 Planting Zone #3 (7,770 SF) Type Common Name Scientific Name Size Spacing (ft) Quantity T Western red cedar Thuja plicata 1-gal 12 45 T Western hemlock Tsuga heterophylla 1-gal 12 40 T Douglas fir Pseudotsuga menziesii 1-gal 12 40 S Ocean spray Holodiscus discolor 1-gal 3 200 S Red elderberry Sambucus racemosa 1-gal 3 250 S Beaked hazelnut Corylus cornuta 1-gal 3 300 S Oso-berry Omelaria cerasiformis 1-gal 3 300 S Vine maple Acer circinatum 1-gal 3 300 S Salmonberry Rubus spectabilis 1-gal 3 300 S Salal Gaultheria shallon 1-gal 3 350 G Cascade Oregon-grape Berberis nervosa 4”pot 2 680 G Sword fern Polystichum munitum 4”pot 2 680

CRITICAL AREA SIGNS

Permanent signs shall be made of an enamel-coated metal face and attached to a metal post or other nontreated material of equal durability. Signs must be posted at an interval of one per lot or every 50 feet, whichever is less and must be maintained by the property owner in perpetuity. The sign shall be worded as follows or with alternative language approved by the director and will identify the type of critical area:

Protected Fish and Wildlife Habitat Conservation Area Do Not Disturb Contact City of Mount Vernon Department of Community and Economic Development Regarding Uses and Restriction

POST-MITIGATION FUNCTIONS AND VALUES

The proposed development project will result in site clean-up and buffer restoration. The project will provide a functional lift in the hydrologic, biogeochemical, plant community, and faunal support functions through a correct implementation. The planted areas will be permanently protected and allowed to establish and grow under the newly developed conditions. Over time, a vegetated barrier will be established between the development and the critical areas. Enhanced riparian vegetation will function to shade the stream channel, and provide nutrients and protection for aquatic species. The planted areas will increase cover, foraging, perching, and eventually nesting opportunities birds. Based on anticipated conditions, the correctly executed enhancement measures are expected to significantly improve the habitat functions and values on the site over that which existed before mitigation.

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

22 PROJECT NOTES

Pre-construction. The outer perimeter of the wetland buffer shall be marked in the field, so no unauthorized intrusion will occur and is subject to inspection before the commencement of permitted activities. This temporary marking shall be maintained throughout construction and shall not be removed until directed by a city representative until permanent signs are in place.

Pre-planting meeting. Before implementing the mitigation measures, a pre-installation meeting should be held with the landscape contractor and the consulting biologist to discuss the installation's details. At that time, the consulting biologist should also have the opportunity to inspect the plantings to be installed and to address any foreseeable issues.

Invasive plant removal. Blackberry cuttings should be exported off-site or converted to a fine mulch if left on-site. Multiple visits for mowing may be needed throughout a single growing season to promote the lasting removal of blackberries. Where areas of blackberry are removed, the bare areas created must be stabilized with mulch or revegetated with native plants to prevent erosion and repopulation of invasive species. Following this method, any regrowth of invasive plants can be more easily removed by hand-held tools and covered again with wood chips until the project is deemed successful.

Erosion control. For the floodplain benches, install erosion control silt fencing along the downslope side of the designated work areas, between the low-flow water line and the ordinary high water line. As needed or determined during construction monitoring, place additional measures such as sandbags in the upslope side of the silt fencing.

If bare soils would be exposed for a prolonged period between the time of site preparation/invasive vegetation removal and mulching throughout the remainder of the enhancement area, then the city’s biologist may determine that sediment and erosion control measures, such as silt fencing, will be required along the entire length of the top of the stream bank.

Timing. For the excavation activities, work during the driest time of year - between June 15 to September 30 - when stream flow levels are at the lowest.

Planting shall take place in the early spring or late fall. Plants should be obtained from a reputable nursery. All plant materials recommended in this plan are typically available from local and regional sources, depending on seasonal demand. Some limited species substitution may be allowed, only with the agreement of the consulting biologist or city's biologist. Care and handling of plant materials are critical to the overall success of the project.

Arrangement. The plants shall be arranged with the appropriate numbers, sizes, species, and distribution to achieve the required vegetation coverage. The actual placement of individual plants shall simulate natural, asymmetric vegetation patterns found on similar undisturbed sites in the area.

Once construction commences, and installation has begun, site conditions may require additional plantings, materials or other items not explicitly detailed in this plan. Any changes to the design will be discussed with and approved by the City. Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

23

Mulch. Wood chips, or other suitable material, shall be used to mulch in the planting areas to prevent weeds and retain moisture around the plantings. Mulch shall be placed in a two-foot diameter around each planting at a depth of 4-6 inches. A four-inch diameter ring around the base of each plant shall be kept free of mulch.

Marking. Colored surveyors’ ribbons, or other approved marking devices, shall be attached to each planted tree and shrub to assist in locating the plants while removing the competing non-native vegetation and assisting in monitoring the plantings.

Tree Protectors or Cages. To prevent browsing from deer and rabbits, tree shelters or wire cages may be used around the newly planted trees and shrubs.

The tree protectors/shelters are tubes made of recycled polyethylene or a biodegradable material that come in varied heights of 3-5 feet. Generally, the tubes are placed around the plant and secured with bamboo or wooden stake. Tubes should be in place for a minimum 2-5 years. When necessary, they should be removed and properly disposed of if they are not biodegradable.

Irrigation / Watering. Regardless of natural precipitation received on-site, irrigation will be required during the dry season (July 1 through October 15) for the first two years after installation to ensure plant survival and establishment. A temporary above-ground irrigation system should provide water. Water should be applied at a rate of one inch of water per week for Years 1 and 2. Consult with the contracted landscaper for installation and scheduled removal of the irrigation system.

GOALS, OBJECTIVES, AND PERFORMANCE STANDARDS

GOAL 1. ESTABLISH A NATIVE SCRUB-SHRUB/FOREST HABITAT

Performance standards: • Plant survival: 80%. • Percent cover of native tree species in forest communities: Greater than or equal to 10% after 1 year, 20% after 3 years, 40% after 5 years, 50% after 7 years, and 60% after 10 years. • Percent cover of native shrub species in forest communities: Greater than or equal to 5% after 1 year, 10% after 3 years, 15% after 5 years, 25% after 7 years, and 40% after 10 years. Not to exceed 75%. • Percent cover of native shrub species in shrub community along the east streambank: Greater than or equal to 10% after 1 year, 15% after 3 years, 20% after 5 years, 40% after 7 years, and 70% after 10 years. • Percent cover of invasive species from the top of bank to the outer edge of the buffer shall not exceed 20 percent. This excludes the east bank that is to be densely planted with willow and dogwood stakes.

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

24 Evaluation method: • Establish up to five (5) 50’x50’ monitoring plots to measure plant species abundance and composition. • A permanent photo point at each plot with photos taken in each cardinal direction.

Contingency: • Replace tree and shrub mortality. • If mortality is high, identify the likely cause. Install tree protectors or alter species composition as needed. • Perform continued monitoring and maintenance of weeds.

GOAL 2. ESTABLISH STRUCTURAL COMPLEXITY FOR A FUNCTIONAL LIFT IN FAUNAL SUPPORT.

Performance standards • Vegetative strata: Forest community should average two strata (i.e., trees and shrubs) after 5-10 years. • Faunal diversity: Restoration site attracts greater than or equal to two classes of fauna after 5-10 years. • Canopy cover by two strata: Greater than or equal to 10% after 1 year, 20% after 3 years, 40% after 5 years, 60% after 7 years, and 80% after 10 years.

Evaluation method: • Establish (mark and GPS) up to five (5) 50’x50’ monitoring plots to measure plant species abundance and composition. Can be the same plots used for evaluation method for Goal 1. • A permanent photo point at each plot with photos taken in each cardinal direction.

Contingency: • Replace tree and shrub mortality. • If mortality is high, identify the likely cause. Install tree protectors or alter species composition as needed. • Perform continued monitoring and maintenance of weeds.

GOAL 3. ESTABLISH HABITAT COMPLEXITY WITH LARGE PIECES OF WOOD

Performance standards • Install 10 pieces of wood throughout the enhanced areas.

Evaluation method: • As-built inspection/survey and photo documentation

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

25 Contingency: • Complete specified grading and ensure micro topography features remain stable. Re- grade if necessary.

PROJECT MONITORING AND MAINTENANCE PROGRAM

VEGETATION MONITORING Monitoring to document compliance with the project goals, targets and standards for the buffer shall be completed as follows: 1) Baseline monitoring inspection (time zero) with baseline/completed measures documented. 2) Fall monitoring in Years 1, 2, 3, 5, 7, and 10 with fall monitoring reports submitted to the city. 3) Spring reconnaissance-level monitoring in Years 1, 2, 3, 5, 7, and 10 to discuss conditions and maintenance recommendations (as needed) with applicant.

Also, monitoring using the City's hydrogeomorphic approach to the assessment of waters/wetlands' functions shall be completed at baseline and the end of years 5 and 10. The city's biologist will conduct this additional monitoring at the applicant's expense. All monitoring reports shall be completed by qualified biologists and shall be submitted to the City.

A total of five (5) 50’x50’ transects or plots will be established at the time of the initial Year 0 inspection. At each plot, at a minimum, record location, cover, number, and composition of plants installed as well as percent cover and composition of invasive species. Plant survival will be estimated in each planting area during each monitoring visit. Visual observations of fauna will be recorded.

Monitoring reports will be prepared and submitted to the City in the fall of each monitoring year. The reports will summarize the overall conditions of the planting areas and discuss whether the performance standards are being met. Photos of the planting areas will also be provided. In year 10, the final monitoring report will be prepared and determined if the mitigation plan has been successful per the established goals, objectives, and performance standards. If the mitigation plan is deemed unsuccessful, contingency actions will be utilized or the monitoring period may be extended.

MAINTENANCE

The planting areas may require periodic maintenance during the monitoring period. Maintenance may include, but will not be limited to repairing the irrigation system, removing competing grasses and invasive vegetation (by hand if necessary), replacing plant mortality, or the replacing mulch.

CONTINGENCY PLAN

If 20 percent of the installed plants are severely stressed during any of the inspections, or it appears 20 percent may not survive, additional plantings of the same species may be added to the planting areas. Additional contingency elements may include, but will not be limited to: more aggressive weed

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

26 control, animal control, mulching, replanting with larger plant material, species substitution, fertilization, soil amendments, and/or irrigation.

ESTIMATED PROJECT COST

Estimated project costs include the cost of plant materials and labor to install plants and the cost of amended topsoil and hog fuel for mulch and ground cover.

Estimated cost of mitigation measures: Estimated cost for 5,263 one-gallon plants ($10.00/plant) = $ 52,630.00 Estimated cost of 2,860 four-inch pots: $5.00/plant = $14,300.00 Estimated cost for 100 willow stakes ($1.00/stake) = $ 100.00 Estimated cost for 400 cy compost mulch ($18.50/yard) = $7,400 Estimated cost for 300 cy of mulch ($12.00/yard) $3,600 Estimated Projects Cost = $78,030.00

USE OF THIS REPORT

This report is supplied to the Housing Authority of Skagit County as a means of determining critical area conditions and buffer mitigation measures, as required by the city of Mount Vernon during the permitting process.

Bachman Environmental utilized the Mount Vernon Municipal Code Chapter 15.40 for guidance and conformed to the accepted standards and methods employed by ecologists in Western Washington. The analysis and conclusions supplied in this report are based on best professional judgment. No attempt has been made to determine hidden or concealed conditions. The laws applicable to critical areas are subject to varying interpretations and may be changed at any time by the courts or legislative bodies.

Should you have any questions or concerns about this report's findings, please feel free to call at (206) 963-2909.

Andrea Bachman, PWS

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

27 REFERENCES

Ecosystem Science and Natural Resource Management Services. (2008). Draft Operational Guidebook to Assessment of Riverine, Slope and Depressional Waters/Wetlands Functions in the City of Mount Vernon, Washington.

Ecosystem Science & Restoration Services. (2007). Restoration and Enhancement of Waters/Wetlands and Buffers.

Hruby, T. (2014). Washington State Wetland Rating System for Western Washington: 2014 Update. (Publication #14-06-029). Olympia, WA: Washington Department of Ecology.

Hruby, T., K. Harper, and S. Stanley (2009). Selecting Wetland Mitigation Sites Using a Watershed Approach. Washington State Department of Ecology Publication #09-06-032.

Mount Vernon Municipal Code (MVMC), Chapter 15.40. October 2016.

USDA NRCS Web Soil Survey. https://websoilsurvey.nrcs.usda.gov/. Accessed on 5/11/20.

U.S. Fish & Wildlife Service (USFWS). National Wetlands Inventory (NWI) Online Mapper. http://www.fws.gov/wetlands/Data/Mapper.html. Accessed on

5/11/20. W.A. 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 of Ecology Publication #06-06-011a. Olympia, WA.

W.A. Department of Fish & Wildlife (WDFW). Priority Habitat and Species (PHS) Interactive Map. http://apps.wdfw.wa.gov/phsontheweb/. Accessed on 5/11/20.

W.A. Department of Natural Resources Forest Practices Application Mapping. https://fortress.wa.gov/dnr/protectiongis/fpamt/default.aspx. Accessed on 5/11/20.

Stream & Wetland Study with Managed Housing Authority of Skagit County Ecosystem Alternative & Enhancement Plan August 14, 2020

28 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region

Project/Site: Housing Authority of Skagit County - College Way City/County: Mount Vernon/Skagit Sampling Date: 5/11/20 Applicant/Owner: Housing Authority of Skagit County State: WA Sampling Point: S1 Investigator(s): A. Bachman Section, Township, Range: S15, T34N, R4E, W.M. Landform (hillslope, terrace, etc.): Terrace Local relief (concave, convex, none): concave Slope (%): 1-2 Subregion (LRR): LRR-A Lat: Long: Datum: Soil Map Unit Name: Skipopa silt loam, 0 to 3 percent slopes NWI classification: PEM1C Are climatic / hydrologic conditions on the site typical for this time of year? Yes ✔ No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes ✔ No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

✔ Hydrophytic Vegetation Present? Yes No Is the Sampled Area Hydric Soil Present? Yes ✔ No within a Wetland? Yes ✔ No Wetland Hydrology Present? Yes ✔ No Remarks:

VEGETATION – Use scientific names of plants. Absolute Dominant Indicator Dominance Test worksheet: Tree Stratum (Plot size: 10x10) % Cover Species? Status Number of Dominant Species 1. Alnus rubra 25 Y FAC That Are OBL, FACW, or FAC: 4 (A) 2. Total Number of Dominant 3. Species Across All Strata: 4 (B) 4. Percent of Dominant Species 25 = Total Cover That Are OBL, FACW, or FAC: 100 (A/B) Sapling/Shrub Stratum (Plot size: 10x10) 1. Cornus sericea 35 Y FACW Prevalence Index worksheet: 2. Rubus armeniacus 10 Y FAC Total % Cover of: Multiply by: 3. OBL species x 1 = 0 4. FACW species x 2 = 0 5. FAC species x 3 = 0 45 = Total Cover FACU species x 4 = 0 Herb Stratum (Plot size: 10x10) UPL species x 5 = 0 1. Equisetum arvense 5 Y FAC Column Totals: 0 (A) 0 (B) 2. 3. Prevalence Index = B/A = 4 4. Hydrophytic Vegetation Indicators: 5. Rapid Test for Hydrophytic Vegetation 6. Dominance Test is >50% 1 7. Prevalence Index is !3.0 1 8. Morphological Adaptations (Provide supporting data in Remarks or on a separate sheet) 9. Wetland Non-Vascular Plants1 10. Problematic Hydrophytic Vegetation1 (Explain) 11. 1Indicators of hydric soil and wetland hydrology must 5 = Total Cover be present, unless disturbed or problematic. Woody Vine Stratum (Plot size: ) 1. Hydrophytic 2. Vegetation 5 = Total Cover Present? Yes ✔ No % Bare Ground in Herb Stratum 95 Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: S1 Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth Matrix Redox Features (inches) Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-4 10YR 3/2 100 - - - - silo slightly moist 4-16+ 10YR 3/1 85 10YR 3/3 15 C M silo moist

1Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix. 3 Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils : Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10) Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3) Thick Dark Surface (A12) ✔ Redox Dark Surface (F6) 3Indicators of hydrophytic vegetation and Sandy Mucky Mineral (S1) Depleted Dark Surface (F7) wetland hydrology must be present, Sandy Gleyed Matrix (S4) Redox Depressions (F8) unless disturbed or problematic. Restrictive Layer (if present): Type:______Depth (inches):______Hydric Soil Present? Yes ✔ No Remarks:

HYDROLOGY Wetland Hydrology Indicators: Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1) Water-Stained Leaves (B9) (except MLRA Water-Stained Leaves (B9) (MLRA 1, 2, High Water Table (A2) 1, 2, 4A, and 4B) 4A, and 4B) Saturation (A3) Salt Crust (B11) Drainage Patterns (B10) Water Marks (B1) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Sediment Deposits (B2) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Drift Deposits (B3) Oxidized Rhizospheres along Living Roots (C3) ✔ Geomorphic Position (D2) Algal Mat or Crust (B4) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Iron Deposits (B5) Recent Iron Reduction in Tilled Soils (C6) ✔ FAC-Neutral Test (D5) Surface Soil Cracks (B6) Stunted or Stressed Plants (D1) (LRR A) Raised Ant Mounds (D6) (LRR A) Inundation Visible on Aerial Imagery (B7) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Sparsely Vegetated Concave Surface (B8) Field Observations: Surface Water Present? Yes No ✔ Depth (inches): Water Table Present? Yes No ✔ Depth (inches): Saturation Present? Yes No ✔ Depth (inches): Wetland Hydrology Present? Yes ✔ No (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region

Project/Site: Housing Authority of Skagit County - College Way City/County: Mount Vernon/Skagit Sampling Date: 5/11/20 Applicant/Owner: Housing Authority of Skagit County State: WA Sampling Point: S2 Investigator(s): A. Bachman Section, Township, Range: S15, T34N, R4E, W.M. Landform (hillslope, terrace, etc.): Terrace Local relief (concave, convex, none): none Slope (%): 2 Subregion (LRR): LRR-A Lat: Long: Datum: Soil Map Unit Name: Skipopa silt loam, 0 to 3 percent slopes NWI classification: PEM1C Are climatic / hydrologic conditions on the site typical for this time of year? Yes ✔ No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes ✔ No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

✔ Hydrophytic Vegetation Present? Yes No Is the Sampled Area Hydric Soil Present? Yes No ✔ within a Wetland? Yes No ✔ Wetland Hydrology Present? Yes No ✔ Remarks:

VEGETATION – Use scientific names of plants. Absolute Dominant Indicator Dominance Test worksheet: Tree Stratum (Plot size: 10x10) % Cover Species? Status Number of Dominant Species 1. Alnus rubra 25 Y FAC That Are OBL, FACW, or FAC: 3 (A) 2. Malus fusca 15 Y FACW Total Number of Dominant 3. Species Across All Strata: 6 (B) 4. Percent of Dominant Species 40 = Total Cover That Are OBL, FACW, or FAC: 50 (A/B) Sapling/Shrub Stratum (Plot size: 10x10) 1. Symphoricarpus albus 25 Y FACW Prevalence Index worksheet: 2. Rubus spectabilis 20 Y FAC Total % Cover of: Multiply by: 3. Acer saccharum 15 Y NOL OBL species x 1 = 0 4. Rubus armeniacus 10 N FAC FACW species x 2 = 0 5. FAC species x 3 = 0 60 = Total Cover FACU species x 4 = 0 Herb Stratum (Plot size: 10x10) UPL species x 5 = 0 1. Phalaris arundinacea 30 Y FACW Column Totals: 0 (A) 0 (B) 2. Geranium robertum 10 Y NOL 3. Circaea alpina 10 Y NOL Prevalence Index = B/A = 4 4. Hydrophytic Vegetation Indicators: 5. Rapid Test for Hydrophytic Vegetation 6. Dominance Test is >50% 1 7. Prevalence Index is !3.0 1 8. Morphological Adaptations (Provide supporting data in Remarks or on a separate sheet) 9. Wetland Non-Vascular Plants1 10. Problematic Hydrophytic Vegetation1 (Explain) 11. 1Indicators of hydric soil and wetland hydrology must 40 = Total Cover be present, unless disturbed or problematic. Woody Vine Stratum (Plot size: ) 1. Hydrophytic 2. Vegetation = Total Cover Present? Yes No ✔ % Bare Ground in Herb Stratum Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: S2 Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth Matrix Redox Features (inches) Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-16 10YR 3/2 100 - - - - silo slightly moist 16+ 10YR 4/2 100 - - - - silo slightly moist

1Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix. 3 Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils : Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10) Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3) Thick Dark Surface (A12) Redox Dark Surface (F6) 3Indicators of hydrophytic vegetation and Sandy Mucky Mineral (S1) Depleted Dark Surface (F7) wetland hydrology must be present, Sandy Gleyed Matrix (S4) Redox Depressions (F8) unless disturbed or problematic. Restrictive Layer (if present): Type:______Depth (inches):______Hydric Soil Present? Yes No ✔ Remarks:

HYDROLOGY Wetland Hydrology Indicators: Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1) Water-Stained Leaves (B9) (except MLRA Water-Stained Leaves (B9) (MLRA 1, 2, High Water Table (A2) 1, 2, 4A, and 4B) 4A, and 4B) Saturation (A3) Salt Crust (B11) Drainage Patterns (B10) Water Marks (B1) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Sediment Deposits (B2) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Drift Deposits (B3) Oxidized Rhizospheres along Living Roots (C3) Geomorphic Position (D2) Algal Mat or Crust (B4) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Iron Deposits (B5) Recent Iron Reduction in Tilled Soils (C6) FAC-Neutral Test (D5) Surface Soil Cracks (B6) Stunted or Stressed Plants (D1) (LRR A) Raised Ant Mounds (D6) (LRR A) Inundation Visible on Aerial Imagery (B7) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Sparsely Vegetated Concave Surface (B8) Field Observations: Surface Water Present? Yes No ✔ Depth (inches): Water Table Present? Yes No ✔ Depth (inches): Saturation Present? Yes No ✔ Depth (inches): Wetland Hydrology Present? Yes No ✔ (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region

Project/Site: Housing Authority of Skagit County - College Way City/County: Mount Vernon/Skagit Sampling Date: 5/11/20 Applicant/Owner: Housing Authority of Skagit County State: WA Sampling Point: S3 Investigator(s): A. Bachman Section, Township, Range: S15, T34N, R4E, W.M. Landform (hillslope, terrace, etc.): Terrace Local relief (concave, convex, none): none Slope (%): 2 Subregion (LRR): LRR-A Lat: Long: Datum: Soil Map Unit Name: Skipopa silt loam, 0 to 3 percent slopes NWI classification: PEM1C Are climatic / hydrologic conditions on the site typical for this time of year? Yes ✔ No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes ✔ No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

✔ Hydrophytic Vegetation Present? Yes No Is the Sampled Area Hydric Soil Present? Yes No ✔ within a Wetland? Yes No ✔ Wetland Hydrology Present? Yes No ✔ Remarks:

VEGETATION – Use scientific names of plants. Absolute Dominant Indicator Dominance Test worksheet: Tree Stratum (Plot size: 10x10) % Cover Species? Status Number of Dominant Species 1. That Are OBL, FACW, or FAC: 4 (A) 2. Total Number of Dominant 3. Species Across All Strata: 4 (B) 4. Percent of Dominant Species = Total Cover That Are OBL, FACW, or FAC: 100 (A/B) Sapling/Shrub Stratum (Plot size: 10x10) 1. Rubus armeniacus 35 Y FACW Prevalence Index worksheet: 2. Rubus spectabilis 15 Y FAC Total % Cover of: Multiply by: 3. OBL species x 1 = 0 4. FACW species x 2 = 0 5. FAC species x 3 = 0 50 = Total Cover FACU species x 4 = 0 Herb Stratum (Plot size: 10x10) UPL species x 5 = 0 1. Phalaris arundinacea 30 Y FACW Column Totals: 0 (A) 0 (B) 2. Equisetum arvense 10 Y FAC 3. Prevalence Index = B/A = 4 4. Hydrophytic Vegetation Indicators: 5. Rapid Test for Hydrophytic Vegetation 6. Dominance Test is >50% 1 7. Prevalence Index is !3.0 1 8. Morphological Adaptations (Provide supporting data in Remarks or on a separate sheet) 9. Wetland Non-Vascular Plants1 10. Problematic Hydrophytic Vegetation1 (Explain) 11. 1Indicators of hydric soil and wetland hydrology must 40 = Total Cover be present, unless disturbed or problematic. Woody Vine Stratum (Plot size: ) 1. Hydrophytic 2. Vegetation = Total Cover Present? Yes ✔ No % Bare Ground in Herb Stratum Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: S3 Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth Matrix Redox Features (inches) Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-16 10YR 3/2 100 - - - - silo slightly moist 16+ 10YR 4/2 100 - - - - silo slightly moist

1Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix. 3 Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils : Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10) Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3) Thick Dark Surface (A12) Redox Dark Surface (F6) 3Indicators of hydrophytic vegetation and Sandy Mucky Mineral (S1) Depleted Dark Surface (F7) wetland hydrology must be present, Sandy Gleyed Matrix (S4) Redox Depressions (F8) unless disturbed or problematic. Restrictive Layer (if present): Type:______Depth (inches):______Hydric Soil Present? Yes No ✔ Remarks:

HYDROLOGY Wetland Hydrology Indicators: Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1) Water-Stained Leaves (B9) (except MLRA Water-Stained Leaves (B9) (MLRA 1, 2, High Water Table (A2) 1, 2, 4A, and 4B) 4A, and 4B) Saturation (A3) Salt Crust (B11) Drainage Patterns (B10) Water Marks (B1) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Sediment Deposits (B2) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Drift Deposits (B3) Oxidized Rhizospheres along Living Roots (C3) Geomorphic Position (D2) Algal Mat or Crust (B4) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Iron Deposits (B5) Recent Iron Reduction in Tilled Soils (C6) FAC-Neutral Test (D5) Surface Soil Cracks (B6) Stunted or Stressed Plants (D1) (LRR A) Raised Ant Mounds (D6) (LRR A) Inundation Visible on Aerial Imagery (B7) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Sparsely Vegetated Concave Surface (B8) Field Observations: Surface Water Present? Yes No ✔ Depth (inches): Water Table Present? Yes No ✔ Depth (inches): Saturation Present? Yes No ✔ Depth (inches): Wetland Hydrology Present? Yes No ✔ (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region

Project/Site: Housing Authority of Skagit County - College Way City/County: Mount Vernon/Skagit Sampling Date: 5/11/20 Applicant/Owner: Housing Authority of Skagit County State: WA Sampling Point: S4 Investigator(s): A. Bachman Section, Township, Range: S15, T34N, R4E, W.M. Landform (hillslope, terrace, etc.): terrace Local relief (concave, convex, none): slope Slope (%): 2 Subregion (LRR): LRR-A Lat: Long: Datum: Soil Map Unit Name: Skipopa silt loam, 0 to 3 percent slopes NWI classification: PEM1C Are climatic / hydrologic conditions on the site typical for this time of year? Yes ✔ No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes ✔ No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

✔ Hydrophytic Vegetation Present? Yes No Is the Sampled Area Hydric Soil Present? Yes ✔ No within a Wetland? Yes ✔ No Wetland Hydrology Present? Yes ✔ No Remarks:

VEGETATION – Use scientific names of plants. Absolute Dominant Indicator Dominance Test worksheet: Tree Stratum (Plot size: 10x10) % Cover Species? Status Number of Dominant Species 1. That Are OBL, FACW, or FAC: 3 (A) 2. Total Number of Dominant 3. Species Across All Strata: 3 (B) 4. Percent of Dominant Species = Total Cover That Are OBL, FACW, or FAC: 100 (A/B) Sapling/Shrub Stratum (Plot size: 10x10) 1. Rubus armeniacus 65 Y FAC Prevalence Index worksheet: 2. Total % Cover of: Multiply by: 3. OBL species x 1 = 0 4. FACW species x 2 = 0 5. FAC species x 3 = 0 65 = Total Cover FACU species x 4 = 0 Herb Stratum (Plot size: 10x10) UPL species x 5 = 0 1. Equisetum arvense 20 Y FAC Column Totals: 0 (A) 0 (B) 2. Phalaris arundinacea 15 Y FACW 3. Prevalence Index = B/A = 4 4. Hydrophytic Vegetation Indicators: 5. Rapid Test for Hydrophytic Vegetation 6. Dominance Test is >50% 1 7. Prevalence Index is !3.0 1 8. Morphological Adaptations (Provide supporting data in Remarks or on a separate sheet) 9. Wetland Non-Vascular Plants1 10. Problematic Hydrophytic Vegetation1 (Explain) 11. 1Indicators of hydric soil and wetland hydrology must 30 = Total Cover be present, unless disturbed or problematic. Woody Vine Stratum (Plot size: ) 1. Hydrophytic 2. Vegetation = Total Cover Present? Yes ✔ No % Bare Ground in Herb Stratum Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: S4 Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth Matrix Redox Features (inches) Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-6 10YR 3/2 100 - - - - siclo saturated 6-16+ Gley 5/10Y 70 10YR 3/6 30 C M silo saturated

1Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix. 3 Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils : Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10) Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) ✔ Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3) Thick Dark Surface (A12) Redox Dark Surface (F6) 3Indicators of hydrophytic vegetation and Sandy Mucky Mineral (S1) Depleted Dark Surface (F7) wetland hydrology must be present, Sandy Gleyed Matrix (S4) Redox Depressions (F8) unless disturbed or problematic. Restrictive Layer (if present): Type:______Depth (inches):______Hydric Soil Present? Yes ✔ No Remarks:

HYDROLOGY Wetland Hydrology Indicators: Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1) Water-Stained Leaves (B9) (except MLRA Water-Stained Leaves (B9) (MLRA 1, 2, High Water Table (A2) 1, 2, 4A, and 4B) 4A, and 4B) ✔ Saturation (A3) Salt Crust (B11) Drainage Patterns (B10) Water Marks (B1) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Sediment Deposits (B2) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Drift Deposits (B3) Oxidized Rhizospheres along Living Roots (C3) Geomorphic Position (D2) Algal Mat or Crust (B4) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Iron Deposits (B5) Recent Iron Reduction in Tilled Soils (C6) FAC-Neutral Test (D5) Surface Soil Cracks (B6) Stunted or Stressed Plants (D1) (LRR A) Raised Ant Mounds (D6) (LRR A) Inundation Visible on Aerial Imagery (B7) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Sparsely Vegetated Concave Surface (B8) Field Observations: Surface Water Present? Yes No ✔ Depth (inches): Water Table Present? Yes No ✔ Depth (inches): Saturation Present? Yes ✔ No Depth (inches): 0 Wetland Hydrology Present? Yes ✔ No (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region

Project/Site: Housing Authority of Skagit County - College Way City/County: Mount Vernon/Skagit Sampling Date: 5/11/20 Applicant/Owner: Housing Authority of Skagit County State: WA Sampling Point: S5 Investigator(s): A. Bachman Section, Township, Range: S15, T34N, R4E, W.M. Landform (hillslope, terrace, etc.): terrace Local relief (concave, convex, none): none Slope (%): 2 Subregion (LRR): LRR-A Lat: Long: Datum: Soil Map Unit Name: Skipopa silt loam, 0 to 3 percent slopes NWI classification: PEM1C Are climatic / hydrologic conditions on the site typical for this time of year? Yes ✔ No (If no, explain in Remarks.) Are Vegetation , Soil , or Hydrology significantly disturbed? Are “Normal Circumstances” present? Yes ✔ No Are Vegetation , Soil , or Hydrology naturally problematic? (If needed, explain any answers in Remarks.) SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

✔ Hydrophytic Vegetation Present? Yes No Is the Sampled Area Hydric Soil Present? Yes No ✔ within a Wetland? Yes No ✔ Wetland Hydrology Present? Yes No ✔ Remarks:

VEGETATION – Use scientific names of plants. Absolute Dominant Indicator Dominance Test worksheet: Tree Stratum (Plot size: 10x10) % Cover Species? Status Number of Dominant Species 1. That Are OBL, FACW, or FAC: 2 (A) 2. Total Number of Dominant 3. Species Across All Strata: 2 (B) 4. Percent of Dominant Species = Total Cover That Are OBL, FACW, or FAC: 100 (A/B) Sapling/Shrub Stratum (Plot size: 10x10) 1. Rubus armeniacus 80 Y FAC Prevalence Index worksheet: 2. Total % Cover of: Multiply by: 3. OBL species x 1 = 0 4. FACW species x 2 = 0 5. FAC species x 3 = 0 80 = Total Cover FACU species x 4 = 0 Herb Stratum (Plot size: 10x10) UPL species x 5 = 0 1. Equisetum arvense 10 Y FAC Column Totals: 0 (A) 0 (B) 2. 3. Prevalence Index = B/A = 4 4. Hydrophytic Vegetation Indicators: 5. Rapid Test for Hydrophytic Vegetation 6. Dominance Test is >50% 1 7. Prevalence Index is !3.0 1 8. Morphological Adaptations (Provide supporting data in Remarks or on a separate sheet) 9. Wetland Non-Vascular Plants1 10. Problematic Hydrophytic Vegetation1 (Explain) 11. 1Indicators of hydric soil and wetland hydrology must 10 = Total Cover be present, unless disturbed or problematic. Woody Vine Stratum (Plot size: ) 1. Hydrophytic 2. Vegetation = Total Cover Present? Yes ✔ No % Bare Ground in Herb Stratum Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 SOIL Sampling Point: S5 Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.) Depth Matrix Redox Features (inches) Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks 0-16 10YR 3/2 100 - - - - silo mixed with gravel; disturbed; covered by landscaped fabric

1Type: C=Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix. 3 Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils : Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10) Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2) Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12) Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks) Depleted Below Dark Surface (A11) Depleted Matrix (F3) Thick Dark Surface (A12) Redox Dark Surface (F6) 3Indicators of hydrophytic vegetation and Sandy Mucky Mineral (S1) Depleted Dark Surface (F7) wetland hydrology must be present, Sandy Gleyed Matrix (S4) Redox Depressions (F8) unless disturbed or problematic. Restrictive Layer (if present): Type:______Depth (inches):______Hydric Soil Present? Yes No ✔ Remarks:

HYDROLOGY Wetland Hydrology Indicators: Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required) Surface Water (A1) Water-Stained Leaves (B9) (except MLRA Water-Stained Leaves (B9) (MLRA 1, 2, High Water Table (A2) 1, 2, 4A, and 4B) 4A, and 4B) Saturation (A3) Salt Crust (B11) Drainage Patterns (B10) Water Marks (B1) Aquatic Invertebrates (B13) Dry-Season Water Table (C2) Sediment Deposits (B2) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9) Drift Deposits (B3) Oxidized Rhizospheres along Living Roots (C3) Geomorphic Position (D2) Algal Mat or Crust (B4) Presence of Reduced Iron (C4) Shallow Aquitard (D3) Iron Deposits (B5) Recent Iron Reduction in Tilled Soils (C6) FAC-Neutral Test (D5) Surface Soil Cracks (B6) Stunted or Stressed Plants (D1) (LRR A) Raised Ant Mounds (D6) (LRR A) Inundation Visible on Aerial Imagery (B7) Other (Explain in Remarks) Frost-Heave Hummocks (D7) Sparsely Vegetated Concave Surface (B8) Field Observations: Surface Water Present? Yes No ✔ Depth (inches): Water Table Present? Yes No ✔ Depth (inches): Saturation Present? Yes No ✔ Depth (inches): Wetland Hydrology Present? Yes No ✔ (includes capillary fringe) Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks:

US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0 Wetland name or number ______A

RATING SUMMARY – Western Washington Name of wetland (or ID #): ______Wetland A Date of site visit: _____5/11/20 Rated by______A. Bachman Trained by Ecology?__✔ Yes ___No Date of training______5/15 HGM Class used for rating______DEPRESSIONAL Wetland has multiple HGM classes?___Y ____N✔

NOTE: Form is not complete without the figures requested (figures can be combined). Source of base aerial photo/map ______iMap/GoogleEarth

OVERALL WETLAND CATEGORY ____III (based on functions___ or special characteristics___)

1. Category of wetland based on FUNCTIONS ______Category I – Total score = 23 - 27 Score for each ______Category II – Total score = 20 - 22 function based ✔ on three ______Category III – Total score = 16 - 19 ratings (order of ratings ______Category IV – Total score = 9 - 15 is not important) FUNCTION Improving Hydrologic Habitat Water Quality 9 = H,H,H Circle the appropriate ratings 8 = H,H,M Site Potential H M L H M L H M L 7 = H,H,L Landscape Potential H M L H M L H M L 7 = H,M,M Value H M L H M L H M L TOTAL 6 = H,M,L 6 = M,M,M Score Based on 5 = H,L,L Ratings 7 4 18 5 = M,M,L

4 = M,L,L 3 = L,L,L 2. Category based on SPECIAL CHARACTERISTICS of wetland

CHARACTERISTIC CATEGORY Estuarine I II Wetland of High Conservation Value I Bog I Mature Forest I Old Growth Forest I Coastal Lagoon I II Interdunal I II III IV None of the above ✔

Wetland Rating System for Western WA: 2014 Update 1 Rating Form – Effective January 1, 2015 Wetland name or number ______A Maps and figures required to answer questions correctly for Western Washington Depressional Wetlands Map of: To answer questions: Figure # Cowardin plant classes D 1.3, H 1.1, H 1.4 1 Hydroperiods D 1.4, H 1.2 Location of outlet (can be added to map of hydroperiods) D 1.1, D 4.1 Boundary of area within 150 ft of the wetland (can be added to another figure) D 2.2, D 5.2 Map of the contributing basin D 4.3, D 5.3 1 km Polygon: Area that extends 1 km from entire wetland edge - including H 2.1, H 2.2, H 2.3 2A polygons for accessible habitat and undisturbed habitat Screen capture of map of 303(d) listed waters in basin (from Ecology website) D 3.1, D 3.2 3 Screen capture of list of TMDLs for WRIA in which unit is found (from web) D 3.3 Riverine Wetlands

Map of: To answer questions: Figure # Cowardin plant classes H 1.1, H 1.4 Hydroperiods H 1.2 Ponded depressions R 1.1 Boundary of area within 150 ft of the wetland (can be added to another figure) R 2.4 Plant cover of trees, shrubs, and herbaceous plants R 1.2, R 4.2 Width of unit vs. width of stream (can be added to another figure) R 4.1 Map of the contributing basin R 2.2, R 2.3, R 5.2 1 km Polygon: Area that extends 1 km from entire wetland edge - including H 2.1, H 2.2, H 2.3 polygons for accessible habitat and undisturbed habitat Screen capture of map of 303(d) listed waters in basin (from Ecology website) R 3.1 Screen capture of list of TMDLs for WRIA in which unit is found (from web) R 3.2, R 3.3 Lake Fringe Wetlands

Map of: To answer questions: Figure # Cowardin plant classes L 1.1, L 4.1, H 1.1, H 1.4 Plant cover of trees, shrubs, and herbaceous plants L 1.2 Boundary of area within 150 ft of the wetland (can be added to another figure) L 2.2 1 km Polygon: Area that extends 1 km from entire wetland edge - including H 2.1, H 2.2, H 2.3 polygons for accessible habitat and undisturbed habitat Screen capture of map of 303(d) listed waters in basin (from Ecology website) L 3.1, L 3.2 Screen capture of list of TMDLs for WRIA in which unit is found (from web) L 3.3 Slope Wetlands

Map of: To answer questions: Figure # Cowardin plant classes H 1.1, H 1.4 Hydroperiods H 1.2 Plant cover of dense trees, shrubs, and herbaceous plants S 1.3 Plant cover of dense, rigid trees, shrubs, and herbaceous plants S 4.1 (can be added to figure above) Boundary of 150 ft buffer (can be added to another figure) S 2.1, S 5.1 1 km Polygon: Area that extends 1 km from entire wetland edge - including H 2.1, H 2.2, H 2.3 polygons for accessible habitat and undisturbed habitat Screen capture of map of 303(d) listed waters in basin (from Ecology website) S 3.1, S 3.2 Screen capture of list of TMDLs for WRIA in which unit is found (from web) S 3.3 Wetland Rating System for Western WA: 2014 Update 2 Rating Form – Effective January 1, 2015 Wetland name or number ______A

HGM Classification of Wetlands in Western Washington

For questions 1-7, the criteria described must apply to the entire unit being rated. If the hydrologic criteria listed in each question do not apply to the entire unit being rated, you probably have a unit with multiple HGM classes. In this case, identify which hydrologic criteria in questions 1-7 apply, and go to Question 8.

1. Are the water levels in the entire unit usually controlled by tides except during floods?

NO – go to 2 YES – the wetland class is Tidal Fringe – go to 1.1 1.1 Is the salinity of the water during periods of annual low flow below 0.5 ppt (parts per thousand)?

NO – Saltwater Tidal Fringe (Estuarine) YES – Freshwater Tidal Fringe If your wetland can be classified as a Freshwater Tidal Fringe use the forms for Riverine wetlands. If it is Saltwater Tidal Fringe it is an Estuarine wetland and is not scored. This method cannot be used to score functions for estuarine wetlands. 2. The entire wetland unit is flat and precipitation is the only source (>90%) of water to it. Groundwater and surface water runoff are NOT sources of water to the unit.

NO – go to 3 YES – The wetland class is Flats If your wetland can be classified as a Flats wetland, use the form for Depressional wetlands. 3. Does the entire wetland unit meet all of the following criteria? ___The vegetated part of the wetland is on the shores of a body of permanent open water (without any plants on the surface at any time of the year) at least 20 ac (8 ha) in size; ___At least 30% of the open water area is deeper than 6.6 ft (2 m).

NO – go to 4 YES – The wetland class is Lake Fringe (Lacustrine Fringe) 4. Does the entire wetland unit meet all of the following criteria? ____The wetland is on a slope (slope can be very gradual), ____The water flows through the wetland in one direction (unidirectional) and usually comes from seeps. It may flow subsurface, as sheetflow, or in a swale without distinct banks, ____The water leaves the wetland without being impounded. NO – go to 5 YES – The wetland class is Slope NOTE: Surface water does not pond in these type of wetlands except occasionally in very small and shallow depressions or behind hummocks (depressions are usually <3 ft diameter and less than 1 ft deep). 5. Does the entire wetland unit meet all of the following criteria? ____The unit is in a valley, or stream channel, where it gets inundated by overbank flooding from that stream or river, ____The overbank flooding occurs at least once every 2 years.

Wetland Rating System for Western WA: 2014 Update 3 Rating Form – Effective January 1, 2015 Wetland name or number ______A

NO – go to 6 YES – The wetland class is Riverine NOTE: The Riverine unit can contain depressions that are filled with water when the river is not flooding 6. Is the entire wetland unit in a topographic depression in which water ponds, or is saturated to the surface, at some time during the year? This means that any outlet, if present, is higher than the interior of the wetland.

NO – go to 7 YES – The wetland class is Depressional 7. Is the entire wetland unit located in a very flat area with no obvious depression and no overbank flooding? The unit does not pond surface water more than a few inches. The unit seems to be maintained by high groundwater in the area. The wetland may be ditched, but has no obvious natural outlet.

NO – go to 8 YES – The wetland class is Depressional

8. Your wetland unit seems to be difficult to classify and probably contains several different HGM classes. For example, seeps at the base of a slope may grade into a riverine floodplain, or a small stream within a Depressional wetland has a zone of flooding along its sides. GO BACK AND IDENTIFY WHICH OF THE HYDROLOGIC REGIMES DESCRIBED IN QUESTIONS 1-7 APPLY TO DIFFERENT AREAS IN THE UNIT (make a rough sketch to help you decide). Use the following table to identify the appropriate class to use for the rating system if you have several HGM classes present within the wetland unit being scored.

NOTE: Use this table only if the class that is recommended in the second column represents 10% or more of the total area of the wetland unit being rated. If the area of the HGM class listed in column 2 is less than 10% of the unit; classify the wetland using the class that represents more than 90% of the total area.

HGM classes within the wetland unit HGM class to being rated use in rating Slope + Riverine Riverine Slope + Depressional Depressional Slope + Lake Fringe Lake Fringe Depressional + Riverine along stream Depressional within boundary of depression Depressional + Lake Fringe Depressional Riverine + Lake Fringe Riverine Salt Water Tidal Fringe and any other Treat as class of freshwater wetland ESTUARINE

If you are still unable to determine which of the above criteria apply to your wetland, or if you have more than 2 HGM classes within a wetland boundary, classify the wetland as Depressional for the rating.

Wetland Rating System for Western WA: 2014 Update 4 Rating Form – Effective January 1, 2015 Wetland name or number ______A

DEPRESSIONAL AND FLATS WETLANDS Water Quality Functions - Indicators that the site functions to improve water quality D 1.0. Does the site have the potential to improve water quality? D 1.1. Characteristics of surface water outflows from the wetland: ✔ Wetland is a depression or flat depression (QUESTION 7 on key) with no surface water leaving it (no outlet). points = 3 Wetland has an intermittently flowing stream or ditch, OR highly constricted permanently flowing outlet. 3 points = 2 Wetland has an unconstricted, or slightly constricted, surface outlet that is permanently flowing points = 1 Wetland is a flat depression (QUESTION 7 on key), whose outlet is a permanently flowing ditch. points = 1 D 1.2. The soil 2 in below the surface (or duff layer) is true clay or true organic (use NRCS definitions).Yes = 4 No = 0 0 D 1.3. Characteristics and distribution of persistent plants (Emergent, Scrub-shrub, and/or Forested Cowardin classes): Wetland has persistent, ungrazed, plants > 95% of area points = 5 Wetland has persistent, ungrazed, plants > ½ of area points = 3 5 1 Wetland has persistent, ungrazed plants > /10 of area points = 1 1 Wetland has persistent, ungrazed plants < /10 of area points = 0 D 1.4. Characteristics of seasonal ponding or inundation: This is the area that is ponded for at least 2 months. See description in manual. Area seasonally ponded is > ½ total area of wetland points = 4 Area seasonally ponded is > ¼ total area of wetland points = 2 ✔ Area seasonally ponded is < ¼ total area of wetland points = 0 Total for D 1 Add the points in the boxes above 8 Rating of Site Potential If score is: 12-16 = H ✔ 6-11 = M 0-5 = L Record the rating on the first page

D 2.0. Does the landscape have the potential to support the water quality function of the site? D 2.1. Does the wetland unit receive stormwater discharges? Yes = 1 No = 0

D 2.2. Is > 10% of the area within 150 ft of the wetland in land uses that generate pollutants? Yes = 1 No = 0 D 2.3. Are there septic systems within 250 ft of the wetland? Yes = 1 No = 0 D 2.4. Are there other sources of pollutants coming into the wetland that are not listed in questions D 2.1-D 2.3? Source______Yes = 1 No = 0 Total for D 2 Add the points in the boxes above 2 Rating of Landscape Potential If score is: 3 or 4 = H 1 or 2 = M 0 = L Record the rating on the first page

D 3.0. Is the water quality improvement provided by the site valuable to society? D 3.1. Does the wetland discharge directly (i.e., within 1 mi) to a stream, river, lake, or marine water that is on the 303(d) list? Yes = 1 No = 0 1 D 3.2. Is the wetland in a basin or sub-basin where an aquatic resource is on the 303(d) list? Yes = 1 No = 0 D 3.3. Has the site been identified in a watershed or local plan as important for maintaining water quality (answer YES if there is a TMDL for the basin in which the unit is found)? Yes = 2 No = 0 2 Total for D 3 Add the points in the boxes above 4 Rating of Value If score is: 2-4 = H 1 = M 0 = L Record the rating on the first page

Wetland Rating System for Western WA: 2014 Update 5 Rating Form – Effective January 1, 2015 Wetland name or number ______A

DEPRESSIONAL AND FLATS WETLANDS Hydrologic Functions - Indicators that the site functions to reduce flooding and stream degradation D 4.0. Does the site have the potential to reduce flooding and erosion? D 4.1. Characteristics of surface water outflows from the wetland: ✔ Wetland is a depression or flat depression with no surface water leaving it (no outlet) points = 4 Wetland has an intermittently flowing stream or ditch, OR highly constricted permanently flowing outletpoints = 2 4 Wetland is a flat depression (QUESTION 7 on key), whose outlet is a permanently flowing ditch points = 1 Wetland has an unconstricted, or slightly constricted, surface outlet that is permanently flowing points = 0 D 4.2. Depth of storage during wet periods: Estimate the height of ponding above the bottom of the outlet. For wetlands with no outlet, measure from the surface of permanent water or if dry, the deepest part. Marks of ponding are 3 ft or more above the surface or bottom of outlet points = 7 Marks of ponding between 2 ft to < 3 ft from surface or bottom of outlet points = 5 0 Marks are at least 0.5 ft to < 2 ft from surface or bottom of outlet points = 3 The wetland is a “headwater” wetland points = 3 Wetland is flat but has small depressions on the surface that trap water points = 1 Marks of ponding less than 0.5 ft (6 in) points = 0 D 4.3. Contribution of the wetland to storage in the watershed: Estimate the ratio of the area of upstream basin contributing surface water to the wetland to the area of the wetland unit itself. The area of the basin is less than 10 times the area of the unit points = 5 The area of the basin is 10 to 100 times the area of the unit points = 3 5 The area of the basin is more than 100 times the area of the unit points = 0 Entire wetland is in the Flats class points = 5 Total for D 4 Add the points in the boxes above 9 Rating of Site Potential If score is: 12-16 = H ✔ 6-11 = M 0-5 = L Record the rating on the first page D 5.0. Does the landscape have the potential to support hydrologic functions of the site? D 5.1. Does the wetland receive stormwater discharges? Yes = 1 No = 0 D 5.2. Is >10% of the area within 150 ft of the wetland in land uses that generate excess runoff? Yes = 1 No = 0 1 D 5.3. Is more than 25% of the contributing basin of the wetland covered with intensive human land uses (residential at >1 residence/ac, urban, commercial, agriculture, etc.)? Yes = 1 No = 0 Total for D 5 Add the points in the boxes above 2 Rating of Landscape Potential If score is: 3 = H 1 or 2 = M 0 = L Record the rating on the first page

D 6.0. Are the hydrologic functions provided by the site valuable to society? D 6.1. The unit is in a landscape that has flooding problems. Choose the description that best matches conditions around the wetland unit being rated. Do not add points. Choose the highest score if more than one condition is met. The wetland captures surface water that would otherwise flow down-gradient into areas where flooding has damaged human or natural resources (e.g., houses or salmon redds):  Flooding occurs in a sub-basin that is immediately down-gradient of unit. points = 2  Surface flooding problems are in a sub-basin farther down-gradient. points = 1 2 Flooding from groundwater is an issue in the sub-basin. points = 1 The existing or potential outflow from the wetland is so constrained by human or natural conditions that the water stored by the wetland cannot reach areas that flood. Explain why ______points = 0 There are no problems with flooding downstream of the wetland. points = 0 D 6.2. Has the site been identified as important for flood storage or flood conveyance in a regional flood control plan? Yes = 2 No = 0 Total for D 6 Add the points in the boxes above Rating of Value If score is: 2-4 = H 1 = M 0 = L Record the rating on the first page

Wetland Rating System for Western WA: 2014 Update 6 Rating Form – Effective January 1, 2015 Wetland name or number ______A

These questions apply to wetlands of all HGM classes. HABITAT FUNCTIONS - Indicators that site functions to provide important habitat H 1.0. Does the site have the potential to provide habitat? H 1.1. Structure of plant community: Indicators are Cowardin classes and strata within the Forested class. Check the Cowardin plant classes in the wetland. Up to 10 patches may be combined for each class to meet the threshold of ¼ ac or more than 10% of the unit if it is smaller than 2.5 ac. Add the number of structures checked. ____Aquatic bed 4 structures or more: points = 4 ____Emergent 3 structures: points = 2 0 ____Scrub-shrub (areas where shrubs have > 30% cover) 2 structures: points = 1 ____Forested✔ (areas where trees have > 30% cover) 1 structure: points = 0 If the unit has a Forested class, check if: ____The Forested class has 3 out of 5 strata (canopy, sub-canopy, shrubs, herbaceous, moss/ground-cover) that each cover 20% within the Forested polygon H 1.2. Hydroperiods Check the types of water regimes (hydroperiods) present within the wetland. The water regime has to cover more than 10% of the wetland or ¼ ac to count (see text for descriptions of hydroperiods). ____Permanently flooded or inundated 4 or more types present: points = 3 ____Seasonally flooded or inundated 3 types present: points = 2 ____Occasionally flooded or inundated 2 types present: points = 1 1 ____Saturated only 1 type present: points = 0 ____Permanently flowing stream or river in, or adjacent to, the wetland ____Seasonally flowing stream in, or adjacent to, the wetland ____Lake Fringe wetland 2 points ____Freshwater tidal wetland 2 points

H 1.3. Richness of plant species Count the number of plant species in the wetland that cover at least 10 ft2. Different patches of the same species can be combined to meet the size threshold and you do not have to name the species. Do not include Eurasian milfoil, reed canarygrass, purple loosestrife, Canadian thistle If you counted: > 19 species points = 2 5 - 19 species points = 1 < 5 species points = 0 H 1.4. Interspersion of habitats Decide from the diagrams below whether interspersion among Cowardin plants classes (described in H 1.1), or the classes and unvegetated areas (can include open water or mudflats) is high, moderate, low, or none. If you have four or more plant classes or three classes and open water, the rating is always high.

None = 0 points Low = 1 point Moderate = 2 points

All three diagrams in this row are HIGH = 3points

Wetland Rating System for Western WA: 2014 Update 13 Rating Form – Effective January 1, 2015 Wetland name or number ______A

H 1.5. Special habitat features: Check the habitat features that are present in the wetland. The number of checks is the number of points. ____Large,✔ downed, woody debris within the wetland (> 4 in diameter and 6 ft long). ____Standing✔ snags (dbh > 4 in) within the wetland ____Undercut banks are present for at least 6.6 ft (2 m) and/or overhanging plants extends at least 3.3 ft (1 m) over a stream (or ditch) in, or contiguous with the wetland, for at least 33 ft (10 m) ____Stable steep banks of fine material that might be used by beaver or muskrat for denning (> 30 degree 2 slope) OR signs of recent beaver activity are present (cut shrubs or trees that have not yet weathered where wood is exposed) ____At least ¼ ac of thin-stemmed persistent plants or woody branches are present in areas that are permanently or seasonally inundated (structures for egg-laying by amphibians) ____Invasive plants cover less than 25% of the wetland area in every stratum of plants (see H 1.1 for list of strata) Total for H 1 Add the points in the boxes above 4 Rating of Site Potential If score is: 15-18 = H 7-14 = M ✔ 0-6 = L Record the rating on the first page H 2.0. Does the landscape have the potential to support the habitat functions of the site? H 2.1. Accessible habitat (include only habitat that directly abuts wetland unit). Calculate: % undisturbed habitat 0 + [(% moderate and low intensity land uses)/2] 12 = ______12 % If total accessible habitat is: 1 > /3 (33.3%) of 1 km Polygon points = 3 1 20-33% of 1 km Polygon points = 2 ✔ 10-19% of 1 km Polygon points = 1 < 10% of 1 km Polygon points = 0 H 2.2. Undisturbed habitat in 1 km Polygon around the wetland. Calculate: % undisturbed habitat 20 + [(% moderate and low intensity land uses)/2] = ______%32 Undisturbed habitat > 50% of Polygon points = 3 Undisturbed habitat 10-50% and in 1-3 patches points = 2 Undisturbed habitat 10-50% and > 3 patches points = 1 Undisturbed habitat < 10% of 1 km Polygon points = 0 H 2.3. Land use intensity in 1 km Polygon: If > 50% of 1 km Polygon is high intensity land use points = (- 2) -2 ≤ 50% of 1 km Polygon is high intensity points = 0 Total for H 2 Add the points in the boxes above 0 Rating of Landscape Potential If score is: 4-6 = H 1-3 = M < 1 = L Record the rating on the first page

H 3.0. Is the habitat provided by the site valuable to society?

H 3.1. Does the site provide habitat for species valued in laws, regulations, or policies? Choose only the highest score that applies to the wetland being rated. Site meets ANY of the following criteria: points = 2  It has 3 or more priority habitats within 100 m (see next page)  It provides habitat for Threatened or Endangered species (any plant or animal on the state or federal lists)  It is mapped as a location for an individual WDFW priority species  It is a Wetland of High Conservation Value as determined by the Department of Natural Resources  It has been categorized as an important habitat site in a local or regional comprehensive plan, in a Shoreline Master Plan, or in a watershed plan Site has 1 or 2 priority habitats (listed on next page) within 100 m points = 1 Site does not meet any of the criteria above points = 0 Rating of Value If score is: 2 = H 1 = M 0 = L Record the rating on the first page

Wetland Rating System for Western WA: 2014 Update 14 Rating Form – Effective January 1, 2015 Wetland name or number ______A

WDFW Priority Habitats Priority habitats listed by WDFW (see complete descriptions of WDFW priority habitats, and the counties in which they can be found, in: Washington Department of Fish and Wildlife. 2008. Priority Habitat and Species List. Olympia, Washington. 177 pp. http://wdfw.wa.gov/publications/00165/wdfw00165.pdf or access the list from here: http://wdfw.wa.gov/conservation/phs/list/) Count how many of the following priority habitats are within 330 ft (100 m) of the wetland unit: NOTE: This question is independent of the land use between the wetland unit and the priority habitat.

 Aspen Stands: Pure or mixed stands of aspen greater than 1 ac (0.4 ha).

 Biodiversity Areas and Corridors: Areas of habitat that are relatively important to various species of native fish and wildlife (full descriptions in WDFW PHS report).

 Herbaceous Balds: Variable size patches of grass and forbs on shallow soils over bedrock.

 Old-growth/Mature forests: Old-growth west of Cascade crest – Stands of at least 2 tree species, forming a multi- layered canopy with occasional small openings; with at least 8 trees/ac (20 trees/ha ) > 32 in (81 cm) dbh or > 200 years of age. Mature forests – Stands with average diameters exceeding 21 in (53 cm) dbh; crown cover may be less than 100%; decay, decadence, numbers of snags, and quantity of large downed material is generally less than that found in old-growth; 80-200 years old west of the Cascade crest.

 Oregon White Oak: Woodland stands of pure oak or oak/conifer associations where canopy coverage of the oak component is important (full descriptions in WDFW PHS report p. 158 – see web link above).

✔ Riparian: The area adjacent to aquatic systems with flowing water that contains elements of both aquatic and terrestrial ecosystems which mutually influence each other.

 Westside Prairies: Herbaceous, non-forested plant communities that can either take the form of a dry prairie or a wet prairie (full descriptions in WDFW PHS report p. 161 – see web link above).

 Instream: The combination of physical, biological, and chemical processes and conditions that interact to provide functional life history requirements for instream fish and wildlife resources.

 Nearshore: Relatively undisturbed nearshore habitats. These include Coastal Nearshore, Open Coast Nearshore, and Puget Sound Nearshore. (full descriptions of habitats and the definition of relatively undisturbed are in WDFW report – see web link on previous page).

 Caves: A naturally occurring cavity, recess, void, or system of interconnected passages under the earth in soils, rock, ice, or other geological formations and is large enough to contain a human.

 Cliffs: Greater than 25 ft (7.6 m) high and occurring below 5000 ft elevation.

 Talus: Homogenous areas of rock rubble ranging in average size 0.5 - 6.5 ft (0.15 - 2.0 m), composed of basalt, andesite, and/or sedimentary rock, including riprap slides and mine tailings. May be associated with cliffs.

 Snags and Logs: Trees are considered snags if they are dead or dying and exhibit sufficient decay characteristics to enable cavity excavation/use by wildlife. Priority snags have a diameter at breast height of > 20 in (51 cm) in western Washington and are > 6.5 ft (2 m) in height. Priority logs are > 12 in (30 cm) in diameter at the largest end, and > 20 ft (6 m) long.

Note: All vegetated wetlands are by definition a priority habitat but are not included in this list because they are addressed elsewhere.

Wetland Rating System for Western WA: 2014 Update 15 Rating Form – Effective January 1, 2015 Wetland name or number ______A CATEGORIZATION BASED ON SPECIAL CHARACTERISTICS Wetland Type Category

Check off any criteria that apply to the wetland. Circle the category when the appropriate criteria are met. SC 1.0. Estuarine wetlands Does the wetland meet the following criteria for Estuarine wetlands?  The dominant water regime is tidal,  Vegetated, and  With a salinity greater than 0.5 ppt Yes –Go to SC 1.1 No= Not an estuarine wetland SC 1.1. Is the wetland within a National Wildlife Refuge, National Park, National Estuary Reserve, Natural Area Preserve, State Park or Educational, Environmental, or Scientific Reserve designated under WAC 332-30-151? Cat. I Yes = Category I No - Go to SC 1.2 SC 1.2. Is the wetland unit at least 1 ac in size and meets at least two of the following three conditions?  The wetland is relatively undisturbed (has no diking, ditching, filling, cultivation, grazing, and has less than 10% cover of non-native plant species. (If non-native species are Spartina, see page 25) Cat. I  At least ¾ of the landward edge of the wetland has a 100 ft buffer of shrub, forest, or un-grazed or un- mowed grassland. Cat. II  The wetland has at least two of the following features: tidal channels, depressions with open water, or contiguous freshwater wetlands. Yes = Category I No = Category II SC 2.0. Wetlands of High Conservation Value (WHCV) SC 2.1. Has the WA Department of Natural Resources updated their website to include the list of Wetlands of High Conservation Value? Yes – Go to SC 2.2 No – Go to SC 2.3 Cat. I SC 2.2. Is the wetland listed on the WDNR database as a Wetland of High Conservation Value? Yes = Category I No = Not a WHCV SC 2.3. Is the wetland in a Section/Township/Range that contains a Natural Heritage wetland? http://www1.dnr.wa.gov/nhp/refdesk/datasearch/wnhpwetlands.pdf Yes – Contact WNHP/WDNR and go to SC 2.4 No = Not a WHCV SC 2.4. Has WDNR identified the wetland within the S/T/R as a Wetland of High Conservation Value and listed it on their website? Yes = Category I No = Not a WHCV SC 3.0. Bogs Does the wetland (or any part of the unit) meet both the criteria for soils and vegetation in bogs? Use the key below. If you answer YES you will still need to rate the wetland based on its functions. SC 3.1. Does an area within the wetland unit have organic soil horizons, either peats or mucks, that compose 16 in or

more of the first 32 in of the soil profile? Yes – Go to SC 3.3 No – Go to SC 3.2 SC 3.2. Does an area within the wetland unit have organic soils, either peats or mucks, that are less than 16 in deep over bedrock, or an impermeable hardpan such as clay or volcanic ash, or that are floating on top of a lake or pond? Yes – Go to SC 3.3 No = Is not a bog SC 3.3. Does an area with peats or mucks have more than 70% cover of mosses at ground level, AND at least a 30% cover of plant species listed in Table 4? Yes = Is a Category I bog No – Go to SC 3.4 NOTE: If you are uncertain about the extent of mosses in the understory, you may substitute that criterion by measuring the pH of the water that seeps into a hole dug at least 16 in deep. If the pH is less than 5.0 and the plant species in Table 4 are present, the wetland is a bog. Cat. I SC 3.4. Is an area with peats or mucks forested (> 30% cover) with Sitka spruce, subalpine fir, western red cedar, western hemlock, lodgepole pine, quaking aspen, Engelmann spruce, or western white pine, AND any of the species (or combination of species) listed in Table 4 provide more than 30% of the cover under the canopy? Yes = Is a Category I bog No = Is not a bog

Wetland Rating System for Western WA: 2014 Update 16 Rating Form – Effective January 1, 2015 Wetland name or number ______A

SC 4.0. Forested Wetlands Does the wetland have at least 1 contiguous acre of forest that meets one of these criteria for the WA Department of Fish and Wildlife’s forests as priority habitats? If you answer YES you will still need to rate the wetland based on its functions.  Old-growth forests (west of Cascade crest): Stands of at least two tree species, forming a multi-layered canopy with occasional small openings; with at least 8 trees/ac (20 trees/ha) that are at least 200 years of age OR have a diameter at breast height (dbh) of 32 in (81 cm) or more.

✔ Mature forests (west of the Cascade Crest): Stands where the largest trees are 80- 200 years old OR the species that make up the canopy have an average diameter (dbh) exceeding 21 in (53 cm).

Yes = Category I No = Not a forested wetland for this section Cat. I SC 5.0. Wetlands in Coastal Lagoons Does the wetland meet all of the following criteria of a wetland in a coastal lagoon?  The wetland lies in a depression adjacent to marine waters that is wholly or partially separated from marine waters by sandbanks, gravel banks, shingle, or, less frequently, rocks  The lagoon in which the wetland is located contains ponded water that is saline or brackish (> 0.5 ppt) during most of the year in at least a portion of the lagoon (needs to be measured near the bottom) Cat. I Yes – Go to SC 5.1 No = Not a wetland in a coastal lagoon SC 5.1. Does the wetland meet all of the following three conditions?  The wetland is relatively undisturbed (has no diking, ditching, filling, cultivation, grazing), and has less than 20% cover of aggressive, opportunistic plant species (see list of species on p. 100). Cat. II  At least ¾ of the landward edge of the wetland has a 100 ft buffer of shrub, forest, or un-grazed or un- mowed grassland. 1 2  The wetland is larger than /10 ac (4350 ft ) Yes = Category I No = Category II SC 6.0. Interdunal Wetlands Is the wetland west of the 1889 line (also called the Western Boundary of Upland Ownership or WBUO)? If you answer yes you will still need to rate the wetland based on its habitat functions. In practical terms that means the following geographic areas:  Long Beach Peninsula: Lands west of SR 103  Grayland-Westport: Lands west of SR 105 Cat I  Ocean Shores-Copalis: Lands west of SR 115 and SR 109 Yes – Go to SC 6.1 No = not an interdunal wetland for rating

SC 6.1. Is the wetland 1 ac or larger and scores an 8 or 9 for the habitat functions on the form (rates H,H,H or H,H,M Cat. II for the three aspects of function)? Yes = Category I No – Go to SC 6.2 SC 6.2. Is the wetland 1 ac or larger, or is it in a mosaic of wetlands that is 1 ac or larger? Yes = Category II No – Go to SC 6.3 Cat. III SC 6.3. Is the unit between 0.1 and 1 ac, or is it in a mosaic of wetlands that is between 0.1 and 1 ac? Yes = Category III No = Category IV Cat. IV Category of wetland based on Special Characteristics If you answered No for all types, enter “Not Applicable” on Summary Form N/A

Wetland Rating System for Western WA: 2014 Update 17 Rating Form – Effective January 1, 2015 Wetland name or number ______A

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Wetland Rating System for Western WA: 2014 Update 18 Rating Form – Effective January 1, 2015 Wetland name or number ______

RATING SUMMARY – Western Washington Name of wetland (or ID #): ______Date of site visit: _____ Rated by______Trained by Ecology?__ Yes ___No Date of training______HGM Class used for rating______Wetland has multiple HGM classes?___Y ____N

NOTE: Form is not complete without the figures requested (figures can be combined). Source of base aerial photo/map ______

OVERALL WETLAND CATEGORY ____ (based on functions___ or special characteristics___)

1. Category of wetland based on FUNCTIONS ______Category I – Total score = 23 - 27 Score for each ______Category II – Total score = 20 - 22 function based on three ______Category III – Total score = 16 - 19 ratings (order of ratings ______Category IV – Total score = 9 - 15 is not important) FUNCTION Improving Hydrologic Habitat Water Quality 9 = H,H,H Circle the appropriate ratings 8 = H,H,M Site Potential H M L H M L H M L 7 = H,H,L Landscape Potential H M L H M L H M L 7 = H,M,M Value H M L H M L H M L TOTAL 6 = H,M,L 6 = M,M,M Score Based on 5 = H,L,L Ratings 5 = M,M,L

4 = M,L,L 3 = L,L,L 2. Category based on SPECIAL CHARACTERISTICS of wetland

CHARACTERISTIC CATEGORY Estuarine I II Wetland of High Conservation Value I Bog I Mature Forest I Old Growth Forest I Coastal Lagoon I II Interdunal I II III IV None of the above

Wetland Rating System for Western WA: 2014 Update 1 Rating Form – Effective January 1, 2015 Wetland name or number ______Maps and figures required to answer questions correctly for Western Washington Depressional Wetlands Map of: To answer questions: Figure # Cowardin plant classes D 1.3, H 1.1, H 1.4 Hydroperiods D 1.4, H 1.2 Location of outlet (can be added to map of hydroperiods) D 1.1, D 4.1 Boundary of area within 150 ft of the wetland (can be added to another figure) D 2.2, D 5.2 Map of the contributing basin D 4.3, D 5.3 1 km Polygon: Area that extends 1 km from entire wetland edge - including H 2.1, H 2.2, H 2.3 polygons for accessible habitat and undisturbed habitat Screen capture of map of 303(d) listed waters in basin (from Ecology website) D 3.1, D 3.2 Screen capture of list of TMDLs for WRIA in which unit is found (from web) D 3.3 Riverine Wetlands

Map of: To answer questions: Figure # Cowardin plant classes H 1.1, H 1.4 Hydroperiods H 1.2 Ponded depressions R 1.1 Boundary of area within 150 ft of the wetland (can be added to another figure) R 2.4 Plant cover of trees, shrubs, and herbaceous plants R 1.2, R 4.2 Width of unit vs. width of stream (can be added to another figure) R 4.1 Map of the contributing basin R 2.2, R 2.3, R 5.2 1 km Polygon: Area that extends 1 km from entire wetland edge - including H 2.1, H 2.2, H 2.3 polygons for accessible habitat and undisturbed habitat Screen capture of map of 303(d) listed waters in basin (from Ecology website) R 3.1 Screen capture of list of TMDLs for WRIA in which unit is found (from web) R 3.2, R 3.3 Lake Fringe Wetlands

Map of: To answer questions: Figure # Cowardin plant classes L 1.1, L 4.1, H 1.1, H 1.4 Plant cover of trees, shrubs, and herbaceous plants L 1.2 Boundary of area within 150 ft of the wetland (can be added to another figure) L 2.2 1 km Polygon: Area that extends 1 km from entire wetland edge - including H 2.1, H 2.2, H 2.3 polygons for accessible habitat and undisturbed habitat Screen capture of map of 303(d) listed waters in basin (from Ecology website) L 3.1, L 3.2 Screen capture of list of TMDLs for WRIA in which unit is found (from web) L 3.3 Slope Wetlands

Map of: To answer questions: Figure # Cowardin plant classes H 1.1, H 1.4 Hydroperiods H 1.2 Plant cover of dense trees, shrubs, and herbaceous plants S 1.3 Plant cover of dense, rigid trees, shrubs, and herbaceous plants S 4.1 (can be added to figure above) Boundary of 150 ft buffer (can be added to another figure) S 2.1, S 5.1 1 km Polygon: Area that extends 1 km from entire wetland edge - including H 2.1, H 2.2, H 2.3 polygons for accessible habitat and undisturbed habitat Screen capture of map of 303(d) listed waters in basin (from Ecology website) S 3.1, S 3.2 Screen capture of list of TMDLs for WRIA in which unit is found (from web) S 3.3 Wetland Rating System for Western WA: 2014 Update 2 Rating Form – Effective January 1, 2015 Wetland name or number ______

HGM Classification of Wetlands in Western Washington

For questions 1-7, the criteria described must apply to the entire unit being rated. If the hydrologic criteria listed in each question do not apply to the entire unit being rated, you probably have a unit with multiple HGM classes. In this case, identify which hydrologic criteria in questions 1-7 apply, and go to Question 8.

1. Are the water levels in the entire unit usually controlled by tides except during floods?

NO – go to 2 YES – the wetland class is Tidal Fringe – go to 1.1 1.1 Is the salinity of the water during periods of annual low flow below 0.5 ppt (parts per thousand)?

NO – Saltwater Tidal Fringe (Estuarine) YES – Freshwater Tidal Fringe If your wetland can be classified as a Freshwater Tidal Fringe use the forms for Riverine wetlands. If it is Saltwater Tidal Fringe it is an Estuarine wetland and is not scored. This method cannot be used to score functions for estuarine wetlands. 2. The entire wetland unit is flat and precipitation is the only source (>90%) of water to it. Groundwater and surface water runoff are NOT sources of water to the unit.

NO – go to 3 YES – The wetland class is Flats If your wetland can be classified as a Flats wetland, use the form for Depressional wetlands. 3. Does the entire wetland unit meet all of the following criteria? ___The vegetated part of the wetland is on the shores of a body of permanent open water (without any plants on the surface at any time of the year) at least 20 ac (8 ha) in size; ___At least 30% of the open water area is deeper than 6.6 ft (2 m).

NO – go to 4 YES – The wetland class is Lake Fringe (Lacustrine Fringe) 4. Does the entire wetland unit meet all of the following criteria? ____The wetland is on a slope (slope can be very gradual), ____The water flows through the wetland in one direction (unidirectional) and usually comes from seeps. It may flow subsurface, as sheetflow, or in a swale without distinct banks, ____The water leaves the wetland without being impounded. NO – go to 5 YES – The wetland class is Slope NOTE: Surface water does not pond in these type of wetlands except occasionally in very small and shallow depressions or behind hummocks (depressions are usually <3 ft diameter and less than 1 ft deep). 5. Does the entire wetland unit meet all of the following criteria? ____The unit is in a valley, or stream channel, where it gets inundated by overbank flooding from that stream or river, ____The overbank flooding occurs at least once every 2 years.

Wetland Rating System for Western WA: 2014 Update 3 Rating Form – Effective January 1, 2015 Wetland name or number ______

NO – go to 6 YES – The wetland class is Riverine NOTE: The Riverine unit can contain depressions that are filled with water when the river is not flooding 6. Is the entire wetland unit in a topographic depression in which water ponds, or is saturated to the surface, at some time during the year? This means that any outlet, if present, is higher than the interior of the wetland.

NO – go to 7 YES – The wetland class is Depressional 7. Is the entire wetland unit located in a very flat area with no obvious depression and no overbank flooding? The unit does not pond surface water more than a few inches. The unit seems to be maintained by high groundwater in the area. The wetland may be ditched, but has no obvious natural outlet.

NO – go to 8 YES – The wetland class is Depressional

8. Your wetland unit seems to be difficult to classify and probably contains several different HGM classes. For example, seeps at the base of a slope may grade into a riverine floodplain, or a small stream within a Depressional wetland has a zone of flooding along its sides. GO BACK AND IDENTIFY WHICH OF THE HYDROLOGIC REGIMES DESCRIBED IN QUESTIONS 1-7 APPLY TO DIFFERENT AREAS IN THE UNIT (make a rough sketch to help you decide). Use the following table to identify the appropriate class to use for the rating system if you have several HGM classes present within the wetland unit being scored.

NOTE: Use this table only if the class that is recommended in the second column represents 10% or more of the total area of the wetland unit being rated. If the area of the HGM class listed in column 2 is less than 10% of the unit; classify the wetland using the class that represents more than 90% of the total area.

HGM classes within the wetland unit HGM class to being rated use in rating Slope + Riverine Riverine Slope + Depressional Depressional Slope + Lake Fringe Lake Fringe Depressional + Riverine along stream Depressional within boundary of depression Depressional + Lake Fringe Depressional Riverine + Lake Fringe Riverine Salt Water Tidal Fringe and any other Treat as class of freshwater wetland ESTUARINE

If you are still unable to determine which of the above criteria apply to your wetland, or if you have more than 2 HGM classes within a wetland boundary, classify the wetland as Depressional for the rating.

Wetland Rating System for Western WA: 2014 Update 4 Rating Form – Effective January 1, 2015 Wetland name or number ______

SLOPE WETLANDS Water Quality Functions - Indicators that the site functions to improve water quality S 1.0. Does the site have the potential to improve water quality? S 1.1. Characteristics of the average slope of the wetland: (a 1% slope has a 1 ft vertical drop in elevation for every 100 ft of horizontal distance) Slope is 1% or less points = 3 Slope is > 1%-2% points = 2 Slope is > 2%-5% points = 1 Slope is greater than 5% points = 0 S 1.2. The soil 2 in below the surface (or duff layer) is true clay or true organic (use NRCS definitions): Yes = 3 No = 0 S 1.3. Characteristics of the plants in the wetland that trap sediments and pollutants: Choose the points appropriate for the description that best fits the plants in the wetland. Dense means you have trouble seeing the soil surface (>75% cover), and uncut means not grazed or mowed and plants are higher than 6 in. Dense, uncut, herbaceous plants > 90% of the wetland area points = 6 Dense, uncut, herbaceous plants > ½ of area points = 3 Dense, woody, plants > ½ of area points = 2 Dense, uncut, herbaceous plants > ¼ of area points = 1 Does not meet any of the criteria above for plants points = 0 Total for S 1 Add the points in the boxes above Rating of Site Potential If score is: 12 = H 6-11 = M 0-5 = L Record the rating on the first page

S 2.0. Does the landscape have the potential to support the water quality function of the site?

S 2.1. Is > 10% of the area within 150 ft on the uphill side of the wetland in land uses that generate pollutants? Yes = 1 No = 0 S 2.2. Are there other sources of pollutants coming into the wetland that are not listed in question S 2.1? Other sources ______Yes = 1 No = 0 Total for S 2 Add the points in the boxes above Rating of Landscape Potential If score is: 1-2 = M 0 = L Record the rating on the first page

S 3.0. Is the water quality improvement provided by the site valuable to society? S 3.1. Does the wetland discharge directly (i.e., within 1 mi) to a stream, river, lake, or marine water that is on the 303(d) list? Yes = 1 No = 0 S 3.2. Is the wetland in a basin or sub-basin where water quality is an issue? At least one aquatic resource in the basin is on the 303(d) list. Yes = 1 No = 0 S 3.3. Has the site been identified in a watershed or local plan as important for maintaining water quality? Answer YES if there is a TMDL for the basin in which unit is found. Yes = 2 No = 0 Total for S 3 Add the points in the boxes above Rating of Value If score is: 2-4 = H 1 = M 0 = L Record the rating on the first page

Wetland Rating System for Western WA: 2014 Update 11 Rating Form – Effective January 1, 2015 Wetland name or number ______

SLOPE WETLANDS Hydrologic Functions - Indicators that the site functions to reduce flooding and stream erosion S 4.0. Does the site have the potential to reduce flooding and stream erosion? S 4.1. Characteristics of plants that reduce the velocity of surface flows during storms: Choose the points appropriate 1 for the description that best fits conditions in the wetland. Stems of plants should be thick enough (usually > /8 in), or dense enough, to remain erect during surface flows. Dense, uncut, rigid plants cover > 90% of the area of the wetland points = 1 All other conditions points = 0 Rating of Site Potential If score is: 1 = M 0 = L Record the rating on the first page

S 5.0. Does the landscape have the potential to support the hydrologic functions of the site? S 5.1. Is more than 25% of the area within 150 ft upslope of wetland in land uses or cover that generate excess surface runoff? Yes = 1 No = 0 Rating of Landscape Potential If score is: 1 = M 0 = L Record the rating on the first page

S 6.0. Are the hydrologic functions provided by the site valuable to society? S 6.1. Distance to the nearest areas downstream that have flooding problems: The sub-basin immediately down-gradient of site has flooding problems that result in damage to human or natural resources (e.g., houses or salmon redds) points = 2 Surface flooding problems are in a sub-basin farther down-gradient points = 1 No flooding problems anywhere downstream points = 0 S 6.2. Has the site been identified as important for flood storage or flood conveyance in a regional flood control plan? Yes = 2 No = 0 Total for S 6 Add the points in the boxes above

Rating of Value If score is: 2-4 = H 1 = M 0 = L Record the rating on the first page

NOTES and FIELD OBSERVATIONS:

Wetland Rating System for Western WA: 2014 Update 12 Rating Form – Effective January 1, 2015 Wetland name or number ______

These questions apply to wetlands of all HGM classes. HABITAT FUNCTIONS - Indicators that site functions to provide important habitat H 1.0. Does the site have the potential to provide habitat? H 1.1. Structure of plant community: Indicators are Cowardin classes and strata within the Forested class. Check the Cowardin plant classes in the wetland. Up to 10 patches may be combined for each class to meet the threshold of ¼ ac or more than 10% of the unit if it is smaller than 2.5 ac. Add the number of structures checked. ____Aquatic bed 4 structures or more: points = 4 ____Emergent 3 structures: points = 2 ____Scrub-shrub (areas where shrubs have > 30% cover) 2 structures: points = 1 ____Forested (areas where trees have > 30% cover) 1 structure: points = 0 If the unit has a Forested class, check if: ____The Forested class has 3 out of 5 strata (canopy, sub-canopy, shrubs, herbaceous, moss/ground-cover) that each cover 20% within the Forested polygon H 1.2. Hydroperiods Check the types of water regimes (hydroperiods) present within the wetland. The water regime has to cover more than 10% of the wetland or ¼ ac to count (see text for descriptions of hydroperiods). ____Permanently flooded or inundated 4 or more types present: points = 3 ____Seasonally flooded or inundated 3 types present: points = 2 ____Occasionally flooded or inundated 2 types present: points = 1 ____Saturated only 1 type present: points = 0 ____Permanently flowing stream or river in, or adjacent to, the wetland ____Seasonally flowing stream in, or adjacent to, the wetland ____Lake Fringe wetland 2 points ____Freshwater tidal wetland 2 points

H 1.3. Richness of plant species Count the number of plant species in the wetland that cover at least 10 ft2. Different patches of the same species can be combined to meet the size threshold and you do not have to name the species. Do not include Eurasian milfoil, reed canarygrass, purple loosestrife, Canadian thistle If you counted: > 19 species points = 2 5 - 19 species points = 1 < 5 species points = 0 H 1.4. Interspersion of habitats Decide from the diagrams below whether interspersion among Cowardin plants classes (described in H 1.1), or the classes and unvegetated areas (can include open water or mudflats) is high, moderate, low, or none. If you have four or more plant classes or three classes and open water, the rating is always high.

None = 0 points Low = 1 point Moderate = 2 points

All three diagrams in this row are HIGH = 3points

Wetland Rating System for Western WA: 2014 Update 13 Rating Form – Effective January 1, 2015 Wetland name or number ______

H 1.5. Special habitat features: Check the habitat features that are present in the wetland. The number of checks is the number of points. ____Large, downed, woody debris within the wetland (> 4 in diameter and 6 ft long). ____Standing snags (dbh > 4 in) within the wetland ____Undercut banks are present for at least 6.6 ft (2 m) and/or overhanging plants extends at least 3.3 ft (1 m) over a stream (or ditch) in, or contiguous with the wetland, for at least 33 ft (10 m) ____Stable steep banks of fine material that might be used by beaver or muskrat for denning (> 30 degree slope) OR signs of recent beaver activity are present (cut shrubs or trees that have not yet weathered where wood is exposed) ____At least ¼ ac of thin-stemmed persistent plants or woody branches are present in areas that are permanently or seasonally inundated (structures for egg-laying by amphibians) ____Invasive plants cover less than 25% of the wetland area in every stratum of plants (see H 1.1 for list of strata) Total for H 1 Add the points in the boxes above Rating of Site Potential If score is: 15-18 = H 7-14 = M 0-6 = L Record the rating on the first page H 2.0. Does the landscape have the potential to support the habitat functions of the site? H 2.1. Accessible habitat (include only habitat that directly abuts wetland unit). Calculate: % undisturbed habitat + [(% moderate and low intensity land uses)/2] = ______% If total accessible habitat is: 1 > /3 (33.3%) of 1 km Polygon points = 3 20-33% of 1 km Polygon points = 2 10-19% of 1 km Polygon points = 1 < 10% of 1 km Polygon points = 0 H 2.2. Undisturbed habitat in 1 km Polygon around the wetland. Calculate: % undisturbed habitat + [(% moderate and low intensity land uses)/2] = ______% Undisturbed habitat > 50% of Polygon points = 3 Undisturbed habitat 10-50% and in 1-3 patches points = 2 Undisturbed habitat 10-50% and > 3 patches points = 1 Undisturbed habitat < 10% of 1 km Polygon points = 0 H 2.3. Land use intensity in 1 km Polygon: If > 50% of 1 km Polygon is high intensity land use points = (- 2) ≤ 50% of 1 km Polygon is high intensity points = 0 Total for H 2 Add the points in the boxes above Rating of Landscape Potential If score is: 4-6 = H 1-3 = M < 1 = L Record the rating on the first page

H 3.0. Is the habitat provided by the site valuable to society?

H 3.1. Does the site provide habitat for species valued in laws, regulations, or policies? Choose only the highest score that applies to the wetland being rated. Site meets ANY of the following criteria: points = 2  It has 3 or more priority habitats within 100 m (see next page)  It provides habitat for Threatened or Endangered species (any plant or animal on the state or federal lists)  It is mapped as a location for an individual WDFW priority species  It is a Wetland of High Conservation Value as determined by the Department of Natural Resources  It has been categorized as an important habitat site in a local or regional comprehensive plan, in a Shoreline Master Plan, or in a watershed plan Site has 1 or 2 priority habitats (listed on next page) within 100 m points = 1 Site does not meet any of the criteria above points = 0 Rating of Value If score is: 2 = H 1 = M 0 = L Record the rating on the first page

Wetland Rating System for Western WA: 2014 Update 14 Rating Form – Effective January 1, 2015 Wetland name or number ______

WDFW Priority Habitats Priority habitats listed by WDFW (see complete descriptions of WDFW priority habitats, and the counties in which they can be found, in: Washington Department of Fish and Wildlife. 2008. Priority Habitat and Species List. Olympia, Washington. 177 pp. http://wdfw.wa.gov/publications/00165/wdfw00165.pdf or access the list from here: http://wdfw.wa.gov/conservation/phs/list/) Count how many of the following priority habitats are within 330 ft (100 m) of the wetland unit: NOTE: This question is independent of the land use between the wetland unit and the priority habitat.

 Aspen Stands: Pure or mixed stands of aspen greater than 1 ac (0.4 ha).

 Biodiversity Areas and Corridors: Areas of habitat that are relatively important to various species of native fish and wildlife (full descriptions in WDFW PHS report).

 Herbaceous Balds: Variable size patches of grass and forbs on shallow soils over bedrock.

 Old-growth/Mature forests: Old-growth west of Cascade crest – Stands of at least 2 tree species, forming a multi- layered canopy with occasional small openings; with at least 8 trees/ac (20 trees/ha ) > 32 in (81 cm) dbh or > 200 years of age. Mature forests – Stands with average diameters exceeding 21 in (53 cm) dbh; crown cover may be less than 100%; decay, decadence, numbers of snags, and quantity of large downed material is generally less than that found in old-growth; 80-200 years old west of the Cascade crest.

 Oregon White Oak: Woodland stands of pure oak or oak/conifer associations where canopy coverage of the oak component is important (full descriptions in WDFW PHS report p. 158 – see web link above).

 Riparian: The area adjacent to aquatic systems with flowing water that contains elements of both aquatic and terrestrial ecosystems which mutually influence each other.

 Westside Prairies: Herbaceous, non-forested plant communities that can either take the form of a dry prairie or a wet prairie (full descriptions in WDFW PHS report p. 161 – see web link above).

 Instream: The combination of physical, biological, and chemical processes and conditions that interact to provide functional life history requirements for instream fish and wildlife resources.

 Nearshore: Relatively undisturbed nearshore habitats. These include Coastal Nearshore, Open Coast Nearshore, and Puget Sound Nearshore. (full descriptions of habitats and the definition of relatively undisturbed are in WDFW report – see web link on previous page).

 Caves: A naturally occurring cavity, recess, void, or system of interconnected passages under the earth in soils, rock, ice, or other geological formations and is large enough to contain a human.

 Cliffs: Greater than 25 ft (7.6 m) high and occurring below 5000 ft elevation.

 Talus: Homogenous areas of rock rubble ranging in average size 0.5 - 6.5 ft (0.15 - 2.0 m), composed of basalt, andesite, and/or sedimentary rock, including riprap slides and mine tailings. May be associated with cliffs.

 Snags and Logs: Trees are considered snags if they are dead or dying and exhibit sufficient decay characteristics to enable cavity excavation/use by wildlife. Priority snags have a diameter at breast height of > 20 in (51 cm) in western Washington and are > 6.5 ft (2 m) in height. Priority logs are > 12 in (30 cm) in diameter at the largest end, and > 20 ft (6 m) long.

Note: All vegetated wetlands are by definition a priority habitat but are not included in this list because they are addressed elsewhere.

Wetland Rating System for Western WA: 2014 Update 15 Rating Form – Effective January 1, 2015 Wetland name or number ______CATEGORIZATION BASED ON SPECIAL CHARACTERISTICS Wetland Type Category

Check off any criteria that apply to the wetland. Circle the category when the appropriate criteria are met. SC 1.0. Estuarine wetlands Does the wetland meet the following criteria for Estuarine wetlands?  The dominant water regime is tidal,  Vegetated, and  With a salinity greater than 0.5 ppt Yes –Go to SC 1.1 No= Not an estuarine wetland SC 1.1. Is the wetland within a National Wildlife Refuge, National Park, National Estuary Reserve, Natural Area Preserve, State Park or Educational, Environmental, or Scientific Reserve designated under WAC 332-30-151? Cat. I Yes = Category I No - Go to SC 1.2 SC 1.2. Is the wetland unit at least 1 ac in size and meets at least two of the following three conditions?  The wetland is relatively undisturbed (has no diking, ditching, filling, cultivation, grazing, and has less than 10% cover of non-native plant species. (If non-native species are Spartina, see page 25) Cat. I  At least ¾ of the landward edge of the wetland has a 100 ft buffer of shrub, forest, or un-grazed or un- mowed grassland. Cat. II  The wetland has at least two of the following features: tidal channels, depressions with open water, or contiguous freshwater wetlands. Yes = Category I No = Category II SC 2.0. Wetlands of High Conservation Value (WHCV) SC 2.1. Has the WA Department of Natural Resources updated their website to include the list of Wetlands of High Conservation Value? Yes – Go to SC 2.2 No – Go to SC 2.3 Cat. I SC 2.2. Is the wetland listed on the WDNR database as a Wetland of High Conservation Value? Yes = Category I No = Not a WHCV SC 2.3. Is the wetland in a Section/Township/Range that contains a Natural Heritage wetland? http://www1.dnr.wa.gov/nhp/refdesk/datasearch/wnhpwetlands.pdf Yes – Contact WNHP/WDNR and go to SC 2.4 No = Not a WHCV SC 2.4. Has WDNR identified the wetland within the S/T/R as a Wetland of High Conservation Value and listed it on their website? Yes = Category I No = Not a WHCV SC 3.0. Bogs Does the wetland (or any part of the unit) meet both the criteria for soils and vegetation in bogs? Use the key below. If you answer YES you will still need to rate the wetland based on its functions. SC 3.1. Does an area within the wetland unit have organic soil horizons, either peats or mucks, that compose 16 in or

more of the first 32 in of the soil profile? Yes – Go to SC 3.3 No – Go to SC 3.2 SC 3.2. Does an area within the wetland unit have organic soils, either peats or mucks, that are less than 16 in deep over bedrock, or an impermeable hardpan such as clay or volcanic ash, or that are floating on top of a lake or pond? Yes – Go to SC 3.3 No = Is not a bog SC 3.3. Does an area with peats or mucks have more than 70% cover of mosses at ground level, AND at least a 30% cover of plant species listed in Table 4? Yes = Is a Category I bog No – Go to SC 3.4 NOTE: If you are uncertain about the extent of mosses in the understory, you may substitute that criterion by measuring the pH of the water that seeps into a hole dug at least 16 in deep. If the pH is less than 5.0 and the plant species in Table 4 are present, the wetland is a bog. Cat. I SC 3.4. Is an area with peats or mucks forested (> 30% cover) with Sitka spruce, subalpine fir, western red cedar, western hemlock, lodgepole pine, quaking aspen, Engelmann spruce, or western white pine, AND any of the species (or combination of species) listed in Table 4 provide more than 30% of the cover under the canopy? Yes = Is a Category I bog No = Is not a bog

Wetland Rating System for Western WA: 2014 Update 16 Rating Form – Effective January 1, 2015 Wetland name or number ______

SC 4.0. Forested Wetlands Does the wetland have at least 1 contiguous acre of forest that meets one of these criteria for the WA Department of Fish and Wildlife’s forests as priority habitats? If you answer YES you will still need to rate the wetland based on its functions.  Old-growth forests (west of Cascade crest): Stands of at least two tree species, forming a multi-layered canopy with occasional small openings; with at least 8 trees/ac (20 trees/ha) that are at least 200 years of age OR have a diameter at breast height (dbh) of 32 in (81 cm) or more.

 Mature forests (west of the Cascade Crest): Stands where the largest trees are 80- 200 years old OR the species that make up the canopy have an average diameter (dbh) exceeding 21 in (53 cm).

Yes = Category I No = Not a forested wetland for this section Cat. I SC 5.0. Wetlands in Coastal Lagoons Does the wetland meet all of the following criteria of a wetland in a coastal lagoon?  The wetland lies in a depression adjacent to marine waters that is wholly or partially separated from marine waters by sandbanks, gravel banks, shingle, or, less frequently, rocks  The lagoon in which the wetland is located contains ponded water that is saline or brackish (> 0.5 ppt) during most of the year in at least a portion of the lagoon (needs to be measured near the bottom) Cat. I Yes – Go to SC 5.1 No = Not a wetland in a coastal lagoon SC 5.1. Does the wetland meet all of the following three conditions?  The wetland is relatively undisturbed (has no diking, ditching, filling, cultivation, grazing), and has less than 20% cover of aggressive, opportunistic plant species (see list of species on p. 100). Cat. II  At least ¾ of the landward edge of the wetland has a 100 ft buffer of shrub, forest, or un-grazed or un- mowed grassland. 1 2  The wetland is larger than /10 ac (4350 ft ) Yes = Category I No = Category II SC 6.0. Interdunal Wetlands Is the wetland west of the 1889 line (also called the Western Boundary of Upland Ownership or WBUO)? If you answer yes you will still need to rate the wetland based on its habitat functions. In practical terms that means the following geographic areas:  Long Beach Peninsula: Lands west of SR 103  Grayland-Westport: Lands west of SR 105 Cat I  Ocean Shores-Copalis: Lands west of SR 115 and SR 109 Yes – Go to SC 6.1 No = not an interdunal wetland for rating

SC 6.1. Is the wetland 1 ac or larger and scores an 8 or 9 for the habitat functions on the form (rates H,H,H or H,H,M Cat. II for the three aspects of function)? Yes = Category I No – Go to SC 6.2 SC 6.2. Is the wetland 1 ac or larger, or is it in a mosaic of wetlands that is 1 ac or larger? Yes = Category II No – Go to SC 6.3 Cat. III SC 6.3. Is the unit between 0.1 and 1 ac, or is it in a mosaic of wetlands that is between 0.1 and 1 ac? Yes = Category III No = Category IV Cat. IV Category of wetland based on Special Characteristics If you answered No for all types, enter “Not Applicable” on Summary Form

Wetland Rating System for Western WA: 2014 Update 17 Rating Form – Effective January 1, 2015 Wetland name or number ______

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Wetland Rating System for Western WA: 2014 Update 18 Rating Form – Effective January 1, 2015 Wetland name or number ______Offsite

RATING SUMMARY – Western Washington Name of wetland (or ID #): ______Offsite Wetland Date of site visit: _____5/11/20 Rated by______A. Bachman Trained by Ecology?__✔ Yes ___No Date of training______5/15 HGM Class used for rating______DEPRESSIONAL Wetland has multiple HGM classes?___Y ____N✔

NOTE: Form is not complete without the figures requested (figures can be combined). Source of base aerial photo/map ______iMap/GoogleEarth

OVERALL WETLAND CATEGORY ____II (based on functions___ or special characteristics___)

1. Category of wetland based on FUNCTIONS ______Category I – Total score = 23 - 27 Score for each ______✔ Category II – Total score = 20 - 22 function based on three ______Category III – Total score = 16 - 19 ratings (order of ratings ______Category IV – Total score = 9 - 15 is not important) FUNCTION Improving Hydrologic Habitat Water Quality 9 = H,H,H Circle the appropriate ratings 8 = H,H,M Site Potential H M L H M L H M L 7 = H,H,L Landscape Potential H M L H M L H M L 7 = H,M,M Value H M L H M L H M L TOTAL 6 = H,M,L 6 = M,M,M Score Based on 5 = H,L,L Ratings 7 6 20 5 = M,M,L

4 = M,L,L 3 = L,L,L 2. Category based on SPECIAL CHARACTERISTICS of wetland

CHARACTERISTIC CATEGORY Estuarine I II Wetland of High Conservation Value I Bog I Mature Forest I Old Growth Forest I Coastal Lagoon I II Interdunal I II III IV None of the above ✔

Wetland Rating System for Western WA: 2014 Update 1 Rating Form – Effective January 1, 2015 Wetland name or number ______Offsite Maps and figures required to answer questions correctly for Western Washington Depressional Wetlands Map of: To answer questions: Figure # Cowardin plant classes D 1.3, H 1.1, H 1.4 1 Hydroperiods D 1.4, H 1.2 Location of outlet (can be added to map of hydroperiods) D 1.1, D 4.1 Boundary of area within 150 ft of the wetland (can be added to another figure) D 2.2, D 5.2 Map of the contributing basin D 4.3, D 5.3 1 km Polygon: Area that extends 1 km from entire wetland edge - including H 2.1, H 2.2, H 2.3 2B polygons for accessible habitat and undisturbed habitat Screen capture of map of 303(d) listed waters in basin (from Ecology website) D 3.1, D 3.2 3 Screen capture of list of TMDLs for WRIA in which unit is found (from web) D 3.3 Riverine Wetlands

Map of: To answer questions: Figure # Cowardin plant classes H 1.1, H 1.4 Hydroperiods H 1.2 Ponded depressions R 1.1 Boundary of area within 150 ft of the wetland (can be added to another figure) R 2.4 Plant cover of trees, shrubs, and herbaceous plants R 1.2, R 4.2 Width of unit vs. width of stream (can be added to another figure) R 4.1 Map of the contributing basin R 2.2, R 2.3, R 5.2 1 km Polygon: Area that extends 1 km from entire wetland edge - including H 2.1, H 2.2, H 2.3 polygons for accessible habitat and undisturbed habitat Screen capture of map of 303(d) listed waters in basin (from Ecology website) R 3.1 Screen capture of list of TMDLs for WRIA in which unit is found (from web) R 3.2, R 3.3 Lake Fringe Wetlands

Map of: To answer questions: Figure # Cowardin plant classes L 1.1, L 4.1, H 1.1, H 1.4 Plant cover of trees, shrubs, and herbaceous plants L 1.2 Boundary of area within 150 ft of the wetland (can be added to another figure) L 2.2 1 km Polygon: Area that extends 1 km from entire wetland edge - including H 2.1, H 2.2, H 2.3 polygons for accessible habitat and undisturbed habitat Screen capture of map of 303(d) listed waters in basin (from Ecology website) L 3.1, L 3.2 Screen capture of list of TMDLs for WRIA in which unit is found (from web) L 3.3 Slope Wetlands

Map of: To answer questions: Figure # Cowardin plant classes H 1.1, H 1.4 Hydroperiods H 1.2 Plant cover of dense trees, shrubs, and herbaceous plants S 1.3 Plant cover of dense, rigid trees, shrubs, and herbaceous plants S 4.1 (can be added to figure above) Boundary of 150 ft buffer (can be added to another figure) S 2.1, S 5.1 1 km Polygon: Area that extends 1 km from entire wetland edge - including H 2.1, H 2.2, H 2.3 polygons for accessible habitat and undisturbed habitat Screen capture of map of 303(d) listed waters in basin (from Ecology website) S 3.1, S 3.2 Screen capture of list of TMDLs for WRIA in which unit is found (from web) S 3.3 Wetland Rating System for Western WA: 2014 Update 2 Rating Form – Effective January 1, 2015 Wetland name or number ______Offsite

HGM Classification of Wetlands in Western Washington

For questions 1-7, the criteria described must apply to the entire unit being rated. If the hydrologic criteria listed in each question do not apply to the entire unit being rated, you probably have a unit with multiple HGM classes. In this case, identify which hydrologic criteria in questions 1-7 apply, and go to Question 8.

1. Are the water levels in the entire unit usually controlled by tides except during floods?

NO – go to 2 YES – the wetland class is Tidal Fringe – go to 1.1 1.1 Is the salinity of the water during periods of annual low flow below 0.5 ppt (parts per thousand)?

NO – Saltwater Tidal Fringe (Estuarine) YES – Freshwater Tidal Fringe If your wetland can be classified as a Freshwater Tidal Fringe use the forms for Riverine wetlands. If it is Saltwater Tidal Fringe it is an Estuarine wetland and is not scored. This method cannot be used to score functions for estuarine wetlands. 2. The entire wetland unit is flat and precipitation is the only source (>90%) of water to it. Groundwater and surface water runoff are NOT sources of water to the unit.

NO – go to 3 YES – The wetland class is Flats If your wetland can be classified as a Flats wetland, use the form for Depressional wetlands. 3. Does the entire wetland unit meet all of the following criteria? ___The vegetated part of the wetland is on the shores of a body of permanent open water (without any plants on the surface at any time of the year) at least 20 ac (8 ha) in size; ___At least 30% of the open water area is deeper than 6.6 ft (2 m).

NO – go to 4 YES – The wetland class is Lake Fringe (Lacustrine Fringe) 4. Does the entire wetland unit meet all of the following criteria? ____The wetland is on a slope (slope can be very gradual), ____The water flows through the wetland in one direction (unidirectional) and usually comes from seeps. It may flow subsurface, as sheetflow, or in a swale without distinct banks, ____The water leaves the wetland without being impounded. NO – go to 5 YES – The wetland class is Slope NOTE: Surface water does not pond in these type of wetlands except occasionally in very small and shallow depressions or behind hummocks (depressions are usually <3 ft diameter and less than 1 ft deep). 5. Does the entire wetland unit meet all of the following criteria? ____The unit is in a valley, or stream channel, where it gets inundated by overbank flooding from that stream or river, ____The overbank flooding occurs at least once every 2 years.

Wetland Rating System for Western WA: 2014 Update 3 Rating Form – Effective January 1, 2015 Wetland name or number ______Offsite

NO – go to 6 YES – The wetland class is Riverine NOTE: The Riverine unit can contain depressions that are filled with water when the river is not flooding 6. Is the entire wetland unit in a topographic depression in which water ponds, or is saturated to the surface, at some time during the year? This means that any outlet, if present, is higher than the interior of the wetland.

NO – go to 7 YES – The wetland class is Depressional 7. Is the entire wetland unit located in a very flat area with no obvious depression and no overbank flooding? The unit does not pond surface water more than a few inches. The unit seems to be maintained by high groundwater in the area. The wetland may be ditched, but has no obvious natural outlet.

NO – go to 8 YES – The wetland class is Depressional

8. Your wetland unit seems to be difficult to classify and probably contains several different HGM classes. For example, seeps at the base of a slope may grade into a riverine floodplain, or a small stream within a Depressional wetland has a zone of flooding along its sides. GO BACK AND IDENTIFY WHICH OF THE HYDROLOGIC REGIMES DESCRIBED IN QUESTIONS 1-7 APPLY TO DIFFERENT AREAS IN THE UNIT (make a rough sketch to help you decide). Use the following table to identify the appropriate class to use for the rating system if you have several HGM classes present within the wetland unit being scored.

NOTE: Use this table only if the class that is recommended in the second column represents 10% or more of the total area of the wetland unit being rated. If the area of the HGM class listed in column 2 is less than 10% of the unit; classify the wetland using the class that represents more than 90% of the total area.

HGM classes within the wetland unit HGM class to being rated use in rating Slope + Riverine Riverine Slope + Depressional Depressional Slope + Lake Fringe Lake Fringe Depressional + Riverine along stream Depressional within boundary of depression Depressional + Lake Fringe Depressional Riverine + Lake Fringe Riverine Salt Water Tidal Fringe and any other Treat as class of freshwater wetland ESTUARINE

If you are still unable to determine which of the above criteria apply to your wetland, or if you have more than 2 HGM classes within a wetland boundary, classify the wetland as Depressional for the rating.

Wetland Rating System for Western WA: 2014 Update 4 Rating Form – Effective January 1, 2015 Wetland name or number ______Offsite

DEPRESSIONAL AND FLATS WETLANDS Water Quality Functions - Indicators that the site functions to improve water quality D 1.0. Does the site have the potential to improve water quality? D 1.1. Characteristics of surface water outflows from the wetland: Wetland is a depression or flat depression (QUESTION 7 on key) with no surface water leaving it (no outlet). points = 3 Wetland has an intermittently flowing stream or ditch, OR highly constricted permanently flowing outlet. 1 points = 2 ✔ Wetland has an unconstricted, or slightly constricted, surface outlet that is permanently flowing points = 1 Wetland is a flat depression (QUESTION 7 on key), whose outlet is a permanently flowing ditch. points = 1 D 1.2. The soil 2 in below the surface (or duff layer) is true clay or true organic (use NRCS definitions).Yes = 4 No = 0 0 D 1.3. Characteristics and distribution of persistent plants (Emergent, Scrub-shrub, and/or Forested Cowardin classes): Wetland has persistent, ungrazed, plants > 95% of area points = 5 Wetland has persistent, ungrazed, plants > ½ of area points = 3 5 1 Wetland has persistent, ungrazed plants > /10 of area points = 1 1 Wetland has persistent, ungrazed plants < /10 of area points = 0 D 1.4. Characteristics of seasonal ponding or inundation: This is the area that is ponded for at least 2 months. See description in manual. Area seasonally ponded is > ½ total area of wetland points = 4 2 Area seasonally ponded is > ¼ total area of wetland points = 2 Area seasonally ponded is < ¼ total area of wetland points = 0 Total for D 1 Add the points in the boxes above 8 Rating of Site Potential If score is: 12-16 = H ✔ 6-11 = M 0-5 = L Record the rating on the first page

D 2.0. Does the landscape have the potential to support the water quality function of the site? D 2.1. Does the wetland unit receive stormwater discharges? Yes = 1 No = 0

D 2.2. Is > 10% of the area within 150 ft of the wetland in land uses that generate pollutants? Yes = 1 No = 0 D 2.3. Are there septic systems within 250 ft of the wetland? Yes = 1 No = 0 D 2.4. Are there other sources of pollutants coming into the wetland that are not listed in questions D 2.1-D 2.3? Source______Yes = 1 No = 0 Total for D 2 Add the points in the boxes above 2 Rating of Landscape Potential If score is: 3 or 4 = H 1 or 2 = M 0 = L Record the rating on the first page

D 3.0. Is the water quality improvement provided by the site valuable to society? D 3.1. Does the wetland discharge directly (i.e., within 1 mi) to a stream, river, lake, or marine water that is on the 303(d) list? Yes = 1 No = 0 D 3.2. Is the wetland in a basin or sub-basin where an aquatic resource is on the 303(d) list? Yes = 1 No = 0 D 3.3. Has the site been identified in a watershed or local plan as important for maintaining water quality (answer YES if there is a TMDL for the basin in which the unit is found)? Yes = 2 No = 0 Total for D 3 Add the points in the boxes above 4 Rating of Value If score is: 2-4 = H 1 = M 0 = L Record the rating on the first page

Wetland Rating System for Western WA: 2014 Update 5 Rating Form – Effective January 1, 2015 Wetland name or number ______Offsite

DEPRESSIONAL AND FLATS WETLANDS Hydrologic Functions - Indicators that the site functions to reduce flooding and stream degradation D 4.0. Does the site have the potential to reduce flooding and erosion? D 4.1. Characteristics of surface water outflows from the wetland: Wetland is a depression or flat depression with no surface water leaving it (no outlet) points = 4 Wetland has an intermittently flowing stream or ditch, OR highly constricted permanently flowing outletpoints = 2 1 ✔ Wetland is a flat depression (QUESTION 7 on key), whose outlet is a permanently flowing ditch points = 1 Wetland has an unconstricted, or slightly constricted, surface outlet that is permanently flowing points = 0 D 4.2. Depth of storage during wet periods: Estimate the height of ponding above the bottom of the outlet. For wetlands with no outlet, measure from the surface of permanent water or if dry, the deepest part. Marks of ponding are 3 ft or more above the surface or bottom of outlet points = 7 Marks of ponding between 2 ft to < 3 ft from surface or bottom of outlet points = 5 0 Marks are at least 0.5 ft to < 2 ft from surface or bottom of outlet points = 3 The wetland is a “headwater” wetland points = 3 Wetland is flat but has small depressions on the surface that trap water points = 1 Marks of ponding less than 0.5 ft (6 in) points = 0 D 4.3. Contribution of the wetland to storage in the watershed: Estimate the ratio of the area of upstream basin contributing surface water to the wetland to the area of the wetland unit itself. The area of the basin is less than 10 times the area of the unit points = 5 The area of the basin is 10 to 100 times the area of the unit points = 3 5 The area of the basin is more than 100 times the area of the unit points = 0 Entire wetland is in the Flats class points = 5 Total for D 4 Add the points in the boxes above 6 Rating of Site Potential If score is: 12-16 = H ✔ 6-11 = M 0-5 = L Record the rating on the first page D 5.0. Does the landscape have the potential to support hydrologic functions of the site? D 5.1. Does the wetland receive stormwater discharges? Yes = 1 No = 0 D 5.2. Is >10% of the area within 150 ft of the wetland in land uses that generate excess runoff? Yes = 1 No = 0 1 D 5.3. Is more than 25% of the contributing basin of the wetland covered with intensive human land uses (residential at >1 residence/ac, urban, commercial, agriculture, etc.)? Yes = 1 No = 0 Total for D 5 Add the points in the boxes above 2 Rating of Landscape Potential If score is: 3 = H 1 or 2 = M 0 = L Record the rating on the first page

D 6.0. Are the hydrologic functions provided by the site valuable to society? D 6.1. The unit is in a landscape that has flooding problems. Choose the description that best matches conditions around the wetland unit being rated. Do not add points. Choose the highest score if more than one condition is met. The wetland captures surface water that would otherwise flow down-gradient into areas where flooding has damaged human or natural resources (e.g., houses or salmon redds):  Flooding occurs in a sub-basin that is immediately down-gradient of unit. points = 2  Surface flooding problems are in a sub-basin farther down-gradient. points = 1 2 Flooding from groundwater is an issue in the sub-basin. points = 1 The existing or potential outflow from the wetland is so constrained by human or natural conditions that the water stored by the wetland cannot reach areas that flood. Explain why ______points = 0 There are no problems with flooding downstream of the wetland. points = 0 D 6.2. Has the site been identified as important for flood storage or flood conveyance in a regional flood control plan? Yes = 2 No = 0 Total for D 6 Add the points in the boxes above Rating of Value If score is: 2-4 = H 1 = M 0 = L Record the rating on the first page

Wetland Rating System for Western WA: 2014 Update 6 Rating Form – Effective January 1, 2015 Wetland name or number ______Offsite

These questions apply to wetlands of all HGM classes. HABITAT FUNCTIONS - Indicators that site functions to provide important habitat H 1.0. Does the site have the potential to provide habitat? H 1.1. Structure of plant community: Indicators are Cowardin classes and strata within the Forested class. Check the Cowardin plant classes in the wetland. Up to 10 patches may be combined for each class to meet the threshold of ¼ ac or more than 10% of the unit if it is smaller than 2.5 ac. Add the number of structures checked. ____Aquatic bed 4 structures or more: points = 4 ✔ ____Emergent 3 structures: points = 2 1 ____Scrub-shrub (areas where shrubs have > 30% cover) 2 structures: points = 1 ____Forested (areas where trees have > 30% cover) 1 structure: points = 0 If the unit has a Forested class, check if: ____The Forested class has 3 out of 5 strata (canopy, sub-canopy, shrubs, herbaceous, moss/ground-cover) that each cover 20% within the Forested polygon H 1.2. Hydroperiods Check the types of water regimes (hydroperiods) present within the wetland. The water regime has to cover more than 10% of the wetland or ¼ ac to count (see text for descriptions of hydroperiods). ____Permanently flooded or inundated 4 or more types present: points = 3 ____Seasonally flooded or inundated 3 types present: points = 2 ____Occasionally flooded or inundated 2 types present: points = 1 2 ____Saturated only 1 type present: points = 0 ____Permanently flowing stream or river in, or adjacent to, the wetland ____Seasonally flowing stream in, or adjacent to, the wetland ____Lake Fringe wetland 2 points ____Freshwater tidal wetland 2 points

H 1.3. Richness of plant species Count the number of plant species in the wetland that cover at least 10 ft2. Different patches of the same species can be combined to meet the size threshold and you do not have to name the species. Do not include Eurasian milfoil, reed canarygrass, purple loosestrife, Canadian thistle If you counted: > 19 species points = 2 5 - 19 species points = 1 < 5 species points = 0 H 1.4. Interspersion of habitats Decide from the diagrams below whether interspersion among Cowardin plants classes (described in H 1.1), or the classes and unvegetated areas (can include open water or mudflats) is high, moderate, low, or none. If you have four or more plant classes or three classes and open water, the rating is always high.

None = 0 points Low = 1 point Moderate = 2 points

All three diagrams in this row are HIGH = 3points

Wetland Rating System for Western WA: 2014 Update 13 Rating Form – Effective January 1, 2015 Wetland name or number ______Offsite

H 1.5. Special habitat features: Check the habitat features that are present in the wetland. The number of checks is the number of points. ____Large,✔ downed, woody debris within the wetland (> 4 in diameter and 6 ft long). ____Standing✔ snags (dbh > 4 in) within the wetland ____Undercut banks are present for at least 6.6 ft (2 m) and/or overhanging plants extends at least 3.3 ft (1 m) over a stream (or ditch) in, or contiguous with the wetland, for at least 33 ft (10 m) ____Stable steep banks of fine material that might be used by beaver or muskrat for denning (> 30 degree 2 slope) OR signs of recent beaver activity are present (cut shrubs or trees that have not yet weathered where wood is exposed) ____At least ¼ ac of thin-stemmed persistent plants or woody branches are present in areas that are permanently or seasonally inundated (structures for egg-laying by amphibians) ____Invasive plants cover less than 25% of the wetland area in every stratum of plants (see H 1.1 for list of strata) Total for H 1 Add the points in the boxes above 8 Rating of Site Potential If score is: 15-18 = H ✔ 7-14 = M 0-6 = L Record the rating on the first page H 2.0. Does the landscape have the potential to support the habitat functions of the site? H 2.1. Accessible habitat (include only habitat that directly abuts wetland unit). Calculate: % undisturbed habitat 20 + [(% moderate and low intensity land uses)/2] 10 = ______30 % If total accessible habitat is: 1 > /3 (33.3%) of 1 km Polygon points = 3 ✔ 20-33% of 1 km Polygon points = 2 10-19% of 1 km Polygon points = 1 < 10% of 1 km Polygon points = 0 H 2.2. Undisturbed habitat in 1 km Polygon around the wetland. Calculate: % undisturbed habitat 30 + [(% moderate and low intensity land uses)/2] = ______%40 Undisturbed habitat > 50% of Polygon points = 3 Undisturbed habitat 10-50% and in 1-3 patches points = 2 Undisturbed habitat 10-50% and > 3 patches points = 1 Undisturbed habitat < 10% of 1 km Polygon points = 0 H 2.3. Land use intensity in 1 km Polygon: If > 50% of 1 km Polygon is high intensity land use points = (- 2) 0 ≤ 50% of 1 km Polygon is high intensity points = 0 Total for H 2 Add the points in the boxes above 4 Rating of Landscape Potential If score is: 4-6 = H 1-3 = M < 1 = L Record the rating on the first page

H 3.0. Is the habitat provided by the site valuable to society?

H 3.1. Does the site provide habitat for species valued in laws, regulations, or policies? Choose only the highest score that applies to the wetland being rated. Site meets ANY of the following criteria: points = 2  It has 3 or more priority habitats within 100 m (see next page)  It provides habitat for Threatened or Endangered species (any plant or animal on the state or federal lists)  It is mapped as a location for an individual WDFW priority species 1  It is a Wetland of High Conservation Value as determined by the Department of Natural Resources  It has been categorized as an important habitat site in a local or regional comprehensive plan, in a Shoreline Master Plan, or in a watershed plan Site has 1 or 2 priority habitats (listed on next page) within 100 m points = 1 Site does not meet any of the criteria above points = 0 Rating of Value If score is: 2 = H 1 = M 0 = L Record the rating on the first page

Wetland Rating System for Western WA: 2014 Update 14 Rating Form – Effective January 1, 2015 Wetland name or number ______Offsite

WDFW Priority Habitats Priority habitats listed by WDFW (see complete descriptions of WDFW priority habitats, and the counties in which they can be found, in: Washington Department of Fish and Wildlife. 2008. Priority Habitat and Species List. Olympia, Washington. 177 pp. http://wdfw.wa.gov/publications/00165/wdfw00165.pdf or access the list from here: http://wdfw.wa.gov/conservation/phs/list/) Count how many of the following priority habitats are within 330 ft (100 m) of the wetland unit: NOTE: This question is independent of the land use between the wetland unit and the priority habitat.

 Aspen Stands: Pure or mixed stands of aspen greater than 1 ac (0.4 ha).

 Biodiversity Areas and Corridors: Areas of habitat that are relatively important to various species of native fish and wildlife (full descriptions in WDFW PHS report).

 Herbaceous Balds: Variable size patches of grass and forbs on shallow soils over bedrock.

 Old-growth/Mature forests: Old-growth west of Cascade crest – Stands of at least 2 tree species, forming a multi- layered canopy with occasional small openings; with at least 8 trees/ac (20 trees/ha ) > 32 in (81 cm) dbh or > 200 years of age. Mature forests – Stands with average diameters exceeding 21 in (53 cm) dbh; crown cover may be less than 100%; decay, decadence, numbers of snags, and quantity of large downed material is generally less than that found in old-growth; 80-200 years old west of the Cascade crest.

 Oregon White Oak: Woodland stands of pure oak or oak/conifer associations where canopy coverage of the oak component is important (full descriptions in WDFW PHS report p. 158 – see web link above).

✔ Riparian: The area adjacent to aquatic systems with flowing water that contains elements of both aquatic and terrestrial ecosystems which mutually influence each other.

 Westside Prairies: Herbaceous, non-forested plant communities that can either take the form of a dry prairie or a wet prairie (full descriptions in WDFW PHS report p. 161 – see web link above).

 Instream: The combination of physical, biological, and chemical processes and conditions that interact to provide functional life history requirements for instream fish and wildlife resources.

 Nearshore: Relatively undisturbed nearshore habitats. These include Coastal Nearshore, Open Coast Nearshore, and Puget Sound Nearshore. (full descriptions of habitats and the definition of relatively undisturbed are in WDFW report – see web link on previous page).

 Caves: A naturally occurring cavity, recess, void, or system of interconnected passages under the earth in soils, rock, ice, or other geological formations and is large enough to contain a human.

 Cliffs: Greater than 25 ft (7.6 m) high and occurring below 5000 ft elevation.

 Talus: Homogenous areas of rock rubble ranging in average size 0.5 - 6.5 ft (0.15 - 2.0 m), composed of basalt, andesite, and/or sedimentary rock, including riprap slides and mine tailings. May be associated with cliffs.

 Snags and Logs: Trees are considered snags if they are dead or dying and exhibit sufficient decay characteristics to enable cavity excavation/use by wildlife. Priority snags have a diameter at breast height of > 20 in (51 cm) in western Washington and are > 6.5 ft (2 m) in height. Priority logs are > 12 in (30 cm) in diameter at the largest end, and > 20 ft (6 m) long.

Note: All vegetated wetlands are by definition a priority habitat but are not included in this list because they are addressed elsewhere.

Wetland Rating System for Western WA: 2014 Update 15 Rating Form – Effective January 1, 2015 Wetland name or number ______Offsite CATEGORIZATION BASED ON SPECIAL CHARACTERISTICS Wetland Type Category

Check off any criteria that apply to the wetland. Circle the category when the appropriate criteria are met. SC 1.0. Estuarine wetlands Does the wetland meet the following criteria for Estuarine wetlands?  The dominant water regime is tidal,  Vegetated, and  With a salinity greater than 0.5 ppt Yes –Go to SC 1.1 No= Not an estuarine wetland SC 1.1. Is the wetland within a National Wildlife Refuge, National Park, National Estuary Reserve, Natural Area Preserve, State Park or Educational, Environmental, or Scientific Reserve designated under WAC 332-30-151? Cat. I Yes = Category I No - Go to SC 1.2 SC 1.2. Is the wetland unit at least 1 ac in size and meets at least two of the following three conditions?  The wetland is relatively undisturbed (has no diking, ditching, filling, cultivation, grazing, and has less than 10% cover of non-native plant species. (If non-native species are Spartina, see page 25) Cat. I  At least ¾ of the landward edge of the wetland has a 100 ft buffer of shrub, forest, or un-grazed or un- mowed grassland. Cat. II  The wetland has at least two of the following features: tidal channels, depressions with open water, or contiguous freshwater wetlands. Yes = Category I No = Category II SC 2.0. Wetlands of High Conservation Value (WHCV) SC 2.1. Has the WA Department of Natural Resources updated their website to include the list of Wetlands of High Conservation Value? Yes – Go to SC 2.2 No – Go to SC 2.3 Cat. I SC 2.2. Is the wetland listed on the WDNR database as a Wetland of High Conservation Value? Yes = Category I No = Not a WHCV SC 2.3. Is the wetland in a Section/Township/Range that contains a Natural Heritage wetland? http://www1.dnr.wa.gov/nhp/refdesk/datasearch/wnhpwetlands.pdf Yes – Contact WNHP/WDNR and go to SC 2.4 No = Not a WHCV SC 2.4. Has WDNR identified the wetland within the S/T/R as a Wetland of High Conservation Value and listed it on their website? Yes = Category I No = Not a WHCV SC 3.0. Bogs Does the wetland (or any part of the unit) meet both the criteria for soils and vegetation in bogs? Use the key below. If you answer YES you will still need to rate the wetland based on its functions. SC 3.1. Does an area within the wetland unit have organic soil horizons, either peats or mucks, that compose 16 in or

more of the first 32 in of the soil profile? Yes – Go to SC 3.3 No – Go to SC 3.2 SC 3.2. Does an area within the wetland unit have organic soils, either peats or mucks, that are less than 16 in deep over bedrock, or an impermeable hardpan such as clay or volcanic ash, or that are floating on top of a lake or pond? Yes – Go to SC 3.3 No = Is not a bog SC 3.3. Does an area with peats or mucks have more than 70% cover of mosses at ground level, AND at least a 30% cover of plant species listed in Table 4? Yes = Is a Category I bog No – Go to SC 3.4 NOTE: If you are uncertain about the extent of mosses in the understory, you may substitute that criterion by measuring the pH of the water that seeps into a hole dug at least 16 in deep. If the pH is less than 5.0 and the plant species in Table 4 are present, the wetland is a bog. Cat. I SC 3.4. Is an area with peats or mucks forested (> 30% cover) with Sitka spruce, subalpine fir, western red cedar, western hemlock, lodgepole pine, quaking aspen, Engelmann spruce, or western white pine, AND any of the species (or combination of species) listed in Table 4 provide more than 30% of the cover under the canopy? Yes = Is a Category I bog No = Is not a bog

Wetland Rating System for Western WA: 2014 Update 16 Rating Form – Effective January 1, 2015 Wetland name or number ______Offsite

SC 4.0. Forested Wetlands Does the wetland have at least 1 contiguous acre of forest that meets one of these criteria for the WA Department of Fish and Wildlife’s forests as priority habitats? If you answer YES you will still need to rate the wetland based on its functions.  Old-growth forests (west of Cascade crest): Stands of at least two tree species, forming a multi-layered canopy with occasional small openings; with at least 8 trees/ac (20 trees/ha) that are at least 200 years of age OR have a diameter at breast height (dbh) of 32 in (81 cm) or more.

✔ Mature forests (west of the Cascade Crest): Stands where the largest trees are 80- 200 years old OR the species that make up the canopy have an average diameter (dbh) exceeding 21 in (53 cm).

Yes = Category I No = Not a forested wetland for this section Cat. I SC 5.0. Wetlands in Coastal Lagoons Does the wetland meet all of the following criteria of a wetland in a coastal lagoon?  The wetland lies in a depression adjacent to marine waters that is wholly or partially separated from marine waters by sandbanks, gravel banks, shingle, or, less frequently, rocks  The lagoon in which the wetland is located contains ponded water that is saline or brackish (> 0.5 ppt) during most of the year in at least a portion of the lagoon (needs to be measured near the bottom) Cat. I Yes – Go to SC 5.1 No = Not a wetland in a coastal lagoon SC 5.1. Does the wetland meet all of the following three conditions?  The wetland is relatively undisturbed (has no diking, ditching, filling, cultivation, grazing), and has less than 20% cover of aggressive, opportunistic plant species (see list of species on p. 100). Cat. II  At least ¾ of the landward edge of the wetland has a 100 ft buffer of shrub, forest, or un-grazed or un- mowed grassland. 1 2  The wetland is larger than /10 ac (4350 ft ) Yes = Category I No = Category II SC 6.0. Interdunal Wetlands Is the wetland west of the 1889 line (also called the Western Boundary of Upland Ownership or WBUO)? If you answer yes you will still need to rate the wetland based on its habitat functions. In practical terms that means the following geographic areas:  Long Beach Peninsula: Lands west of SR 103  Grayland-Westport: Lands west of SR 105 Cat I  Ocean Shores-Copalis: Lands west of SR 115 and SR 109 Yes – Go to SC 6.1 No = not an interdunal wetland for rating

SC 6.1. Is the wetland 1 ac or larger and scores an 8 or 9 for the habitat functions on the form (rates H,H,H or H,H,M Cat. II for the three aspects of function)? Yes = Category I No – Go to SC 6.2 SC 6.2. Is the wetland 1 ac or larger, or is it in a mosaic of wetlands that is 1 ac or larger? Yes = Category II No – Go to SC 6.3 Cat. III SC 6.3. Is the unit between 0.1 and 1 ac, or is it in a mosaic of wetlands that is between 0.1 and 1 ac? Yes = Category III No = Category IV Cat. IV Category of wetland based on Special Characteristics If you answered No for all types, enter “Not Applicable” on Summary Form N/A

Wetland Rating System for Western WA: 2014 Update 17 Rating Form – Effective January 1, 2015 Wetland name or number ______Offsite

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Wetland Rating System for Western WA: 2014 Update 18 Rating Form – Effective January 1, 2015 OFFSITE WETLAND FORESTED & EMERGENT PERMANENTLY FLOWING OUTLET OCCASIONALLY FLOODED & SATURATED CONTRIBUTING BASIN IS <10 TIMES AREA OF UNIT

150' BOUNDARY AROUND DEPRESSIONAL WETLAND UNITS (FOR RATING PURPOSES)

WETLAND A FORESTED, NO OUTLET OCCASIONALLY FLOODED, SATURATED CONTRIBUTING BASIN IS <10 TIMES AREA OF UNIT

WETLAND B FORESTED & SCRUB-SHRUB DENSE, RIGID VEGETATION = 50-90% SATURATED ONLY

Scale 1" = 100' APPROX. 150' AREA 0 50 100 150 200 WETLAND UNITS STREAM AROUND UNITS

FIGURE 1 WETLAND RATING FIGURE 1 VEGETATION & HYDROPERIODS DATE: 5/11/20 PO Box 471 Anacortes, WA 98221 HASC - COLLEGE WAY Ph. 206.963.2909 [email protected] CITY OF MOUNT VERNON, WA JOB NO: 2022 UNDISTURBED HABITAT (20%) 5/11/20 NO: 2022 MODERATE INTENSITY (26%) FIGURE 2A DATE: JOB HIGH INTENSITY LAND USE (54%) 1 KM POLYGON AROUND UNITS & A WA UNITS WAY

24% WETLAND UNITS

A & B B AROUND COLLEGE RATING FIGURE RATING 2A - MOUNT VERNON, OF MOUNT HASC CITY POLYGON WETLAND 1KM 98221

WA Anacortes, 471 PO Box andrea@bachmanenvironmental .com 206.963.2909 Ph. HIGH (26%) MODERATE INTENSITY HABITATUNDISTURBED (20%) INTENSITY LAND USE (54%) USE LAND INTENSITY 1 KM POLYGON KM 1 AROUND WETLAND OFF-SITE UNIT UNIT

WETLAND RATING FIGURE 2B FIGURE 2B 1KM POLYGON AROUND OFF-SITE WETLAND UNIT DATE: 5/11/20 PO Box 471 Anacortes, WA 98221 Ph. 206.963.2909 andrea@bachmanenvironmental .com HASC - COLLEGE WAY CITY OF MOUNT VERNON, WA JOB NO: 2022 SITE

FIGURE 3 WETLAND RATING FIGURE 3 303(d) LISTED WATERS DATE: 5/11/20 PO Box 471 Anacortes, WA 98221 CITY OF MOUNT VERNON, WA Ph. 206.963.2909 [email protected] JOB NO: 2022 "TRUMPETER CREEK" TYPE F STREAM LOW GRADIENT (<1%)

25' 50'

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39 40 41 42 43 TRASH

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ESTIMATED

44 LOCATION 63 OF OFF-SITE 18 CATEGORY II

45 64 WETLAND

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66 PLANTING ZONE #3 7,770 SF

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EXISTING ELECTRIC FENCE

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82 83 84 85 NEW PRE-FABRICATED 86 BRIDGE WITH WOOD CHIP87 TRAIL 109 88

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95 94 93 92 91 90 89 S2 PLANTING ZONE #2

111 267 SF 25' S1 S3

96

112 S5

97 50' BRIDGE TO BE REMOVED WETLAND A 98 CATEGORY III WETLAND B S4

99 CATEGORY III 25'

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101 114 PLANTING ZONE #1 10,580 SF

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107 25'

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108 TYPE F STREAM TRIBUTARY TO TRUMPETER CREEK MEDIUM GRADIENT (1-2%)

N

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S LEGEND Scale 1" = 20' MAXIMUM MANAGED PLANTING ZONE # 1 BUFFER 0 10 20 30 40 (10,580 SF)

APPLICANT: SHEET TITLE: SHEET: 1 OF 1 PLANTING ZONE # 2 MINIMUM MANAGED BUFFER CRITICAL AREAS & (267 SF) CONCEPTUAL ENHANCEMENT PLAN Housing Authority of Skagit County SCALE: 1" = 20' Attn: Melanie Corey PLANTING ZONE # 3 LARGE PIECES OF WOOD 1650 Port Drive SITE LOCATION: 4100 East College Way DATE: AUGUST 14, 2020 (7,770 SF) Burlington, WA 98233 Mount Vernon, WA 98273 CRITICAL AREA SIGN Parcels P24832, P113507, & P24844 BY: A. BACHMAN a portion Section 15, Township 34N, Range 04E, W.M. PH: (206) 963-2909 WETLAND WETLAND S1 S5 DETERMINATION SAMPLE SITES 1 - 5 Skagit River

Recreational Use Portion

Subject Site

Wild And Scenic River Portion

Fulcrum Environmental Consulting, Inc. 406 North Second Street, Yakima, Washington 98901 4100 East College Way, FIGURE National Wild and Scenic Rivers Map p: 509.574.0839 f: 509.575.8453 efulcrum.net Mount Vernon, Washington 1 HASC NEPA EA . 203055.00 . JAK . 08/03/2020 Subject Site

Nooksack River

Subject Site

Deer Creek

Fulcrum Environmental Consulting, Inc. 406 North Second Street, Yakima, Washington 98901 4100 East College Way, FIGURE Nationwide Rivers Inventory Map p: 509.574.0839 f: 509.575.8453 efulcrum.net Mount Vernon, Washington 2 HASC NEPA EA . 203055.00 . JAK . 08/03/2020 MEMORANDUM

DATE March 11, 2021 TO Shelley Kjos, Skagit County Public Health FROM Peggy Williamson, Fulcrum Environmental Consulting, Inc. RE Environmental Justice – Determination Basis Subject HASC Family Housing - 4100 East College Way, Mount Vernon, Washington

The Housing Authority of Skagit County (HASC) proposes to develop approximately 50 affordable family housing units at 4100 East College Way in Mount Vernon, Washington adjacent to the existing Mount Baker Meadows 20-unit farmworker complex operated by HASC. The purpose of the project is to provide affordable housing for farmworkers and extremely low-income people with disabilities and that give residents a sense of connection to the larger community.

Fulcrum Environmental Consulting, Inc. (Fulcrum) was retained by the HASC to complete necessary review of Environmental Justice factors as a portion of the National Environmental Protection Agency (NEPA) Environmental Assessment (EA) for a proposed action located at 4100 East College Way in Mount Vernon, Washington (project footprint or site), and referred to has the HASC Family Housing Project. A portion of the post-construction funding will be sourced from the United States (US) Department of Housing and Urban Development (HUD) and the NEPA will be completed under the 24 Code of Federal Regulation (CFR) Part 58 requirements. Skagit County is the Responsibly Entity for completion of the HUD compliant NEPA EA.

Fulcrum has prepared the Environmental Justice Determination of the proposed HASC Family Housing project under Executive Order 12898, Federal Actions to Address Environmental Justice in Minority Populations and Low Income Populations, and HUD guidance to assist HASC and Skagit County meet NEPA EA requirements.

1. Project Description

The Housing Authority of Skagit County (HASC) proposes to develop approximately 50 family housing units at 4100 East college Way in Mount Vernon, Washington adjacent to the existing Mount Baker Meadows 20-unit farmworker complex operated by HASC.

The project proposes to develop a former greenhouse/nursery parcel consisting of 4.58 acres located Skagit County into the family housing complex. The HASC Family Housing project will create about 50 units of affordable housing with about 38 units for farmworkers and their families and about 12 units for people with disabilities. Twenty-five units will be for households below 30% of the area median income and 25 units will be for households below 50% of the area median. Eight of the disabled units will be set-aside for homeless Veterans. There will be one unrestricted onsite manager's unit. The property will be comprised of about five separate garden style walk up residential buildings, one community building and about 110 surface parking spaces. There will be approximately 10 to 12 1-bedroom, 19 to 21 2-bedroom and 18 to 20 3-bedroom units. A large grass lawn area and play area has been designed in the middle of the buildings that will allow children to play outside in a safe area where their parents can see them from their unit.

College Way Creek, a Type F stream, and an unnamed Class III wetland, are located on the southeastern portion of the property, with additional wetlands on adjacent properties. The project includes replacement of a footbridge that crosses College Way Creek. The project has been designed in accordance with the Mount Vernon wetland buffer requirements while also utilizing the City's buffer buydown program that allows for reduced setbacks.

The site is also located along the western margin of the Skagit River Floodplain. As a portion of the development, engineered fill will be placed onsite to bring the foundation elevations a minimum of one foot above the base flood elevation.

Under the proposed action, the 50-unit affordable housing complex would be constructed at the 4100 East College Way site, additional affordable housing stock would be created within the boundary of the City of Mount Vernon for alleviating the very low vacancy rates. Approximately two to five feet of fill at a cost of approximately $530,000 would be imported to approximately 3.4 acres of the site to raise the buildings foundation floor elevations above the base flood elevation. The approximate 116,000 square feet of existing impervious roads, foundations and floor surfaces associated with the former greenhouse and nursery operations may be broken into small chunks and reused onsite in select areas, as a portion of the fill. The estimated cost of site fill combined with other site grading and foundation work was within the budgetary estimate for project construction. The stream and wetland buffers would be established consistent with the City of Mount Vernon Managed Ecosystem Alternative criteria and would be restored and enhanced. The proposed site is located adjacent to an existing HASC housing complex and has been designed for residents of both developments to access common features such as children's play areas and a community building. The site meets all the selection criteria.

2. Historic Site Use, Past Land Uses and Patterns (such as lending discrimination and exclusionary zoning)

The proposed action site was historically occupied by a residence and/or farm-related structures from about 1908 to 1969. In 1978 the site was redeveloped as a greenhouse/nursery operation that continued until about 2000. From 2001 until preset the site has been vacant, though the former greenhouse buildings and ancillary site development features remain.

The site is located within the City of Mount Vernon which is described as a small metro area surrounded by agricultural uses. The City of Mount Vernon is in the western portion of Skagit County and is about 60 miles north of Seattle, about 34 miles north of Everett, and about 30 miles south of Bellingham. Project vicinity land use includes a mixture of commercial, industrial, agriculture and residential developments.

The site is well located within a residential area with commercial uses found at major intersections. The site is currently zoned R-4, Multifamily Residential with a unit density range between 10 and 15 units per acre. The proposed action was designed to have between 11 and 12 units per acre.

The report titled "Market Study Report Mount Vernon Apartments 4100 East College Way Mount Vernon, Washington 98273" (Market Study), published by CBRE Group, Inc. September 17, 2019 reported the population of the Mount Vernon-Anacortes, WA Metropolitan Statistical area to be 127,663 in 2019. The 2019 population is a 10,762 increase over the 2010 value and reflects an annual increase of 1.0%. Projections indicated that by 2024 the population will have increased an additional 6,980, reflecting an 1.1% annual population growth.

As reported in the Market Study, the area average household income is $85,913 and the median household income is $64,405. Over the next 5 years the household income is expected to increase by 15.7%, or $2,016 per annum. The area was reported in the Market Study to have 59,273 employees with a 4.0% unemployment rate in 2019.

3. Determine the demographic profile of the people using the project and/or living and working in the vicinity of the project.

Fulcrum utilized EPA’s environmental justice geographic assessment tool to review demographic information: http://epamap14.epa.gov/ejmap/entry.html associated with the proposed action site and the surrounding area.

According to the EJSCREEN ACS Summary Report for an approximate 1-mile radius around the project site has an approximately 44% minority population, while the larger Mount Vernon region has a minority population of 41%. There project area does not have a minority population that is appreciably different than the City of Mount Vernon. The minority population in the Mount Vernon and proposed action site is slightly higher than the reported State value of 30 to 31% minority population.

The EJSCREEN ACS Summary Report for an approximate 1-mile radius around the project site has a low- income population of 31% as compared to the 36% present in the larger Mount Vernon region. The project area does not have a low-income population that is appreciably different that the City of Mount Vernon. The low-income population in the project area and the City of Mount Vernon is slightly higher than the State reported values of 27 to 28%.

4. Describe the adverse environmental impact you identified in your environmental review.

Identify adjacent land uses, paying particular attention to toxic sites, dumps, incinerators, hazardous materials (e.g. asbestos), and other issues with the potential to have adverse human health effects.

(This may already have been considered in your review of toxic and hazardous substances.)

The following areas of potential adverse environmental conditions identified during the environmental assessment: Flood Insurance, Contamination and Toxic Substances, Endangered Species, Floodplain Management, and Wetlands Protection. As a result of the project these potential adverse environmental conditions will be mitigated. At the conclusion of the project no adverse environmental impacts will remain. Following is a description of each of these areas of concern.

a. Flood Insurance. According to the attached Flood Insurance Rate Map Panel Number 530158 0001 B, effective January 3, 1985 the proposed action site is in the 100-year floodplain and is designated with Flood Zone A7. The flood insurance coverage will be maintained at a value at least the total project cost or the maximum coverage limit of the National Flood Insurance Program, whichever is less.

b. Contamination and Toxic Substances. Site contamination was evaluated as follows: ASTM Phase I ESA, ASTM Phase II ESA, Remediation, ASTM Vapor Encroachment Screening. The REC identified in the Phase I ESA were subsequently investigated with two localized areas of contamination identified, one containing Lindane pesticide and one containing diesel. Both areas were remediated by excavating contaminated soil for transport offsite to appropriately permitted facilities. Confirmation samples collected from the excavation extents documented the contaminant concentrations to be below Ecology's applicable cleanup levels. Following remediation, project documentation was submitted to the Washington State Department Ecology (Ecology) for review. Ecology issued a No Further Action (NFA) Determination for the site February 8, 2019. No nearby toxic, hazardous, or radioactive substances were found that could affect the health and safety of project occupants or conflict with the intended use of the property.

c. Endangered Species. A formal consultation was completed with the National Marine Fisheries Service (NMFS) and the United States Fish and Wildlife Service (USFWS) pursuant to section 7 of the Endangered Species Act (ESA) of 1973 and the Magnuson-Stevens Fishery Conservation and Management Act, essential fish habitat (EFH). Based on comment received by NMFS the project stormwater design was modified to include the Contech’s Filterra system, a Washington State Department of Ecology approved emerging stormwater treatment technology. Based on final design review NMFS and USFWS concluded that the project “May Affect, but is Not Likely to Adversely Affect” the identified ESA species or EFH.

d. Floodplain Management. To raise the elevation of the new building foundation floors, approximately two to five feet of fill will be imported to approximate 3.4 acres of the site that will be disturbed during development. The area of fill represents about a 0.005 square mile of the 71.6 square miles of the Nookachamps drainage sub-basin, or approximately 0.007% of the drainage area. Additionally, the conceptual hydraulic analysis has shown that the proposed action will not result in a significant change to the base flood elevation and is not in the main flow path of the Skagit River. The 8-Step process for Floodplains and Wetlands was completed and no comments were received from the public.

e. Wetlands Protection. There will be no direct impact to the Type F stream or two small, isolated Class III wetlands on site, or the Type F stream and Class II wetland located to the northeast. However, restoration activities in the newly established buffers may indirectly impact the wetlands. The proposed action potential impact to the streams and wetlands by defining buffers consistent with the City of Mount Vernon requirements, eradicating invasive species within the buffers, increasing native vegetation diversity, directing stormwater from potential pollution generating impervious surfaces (PGIS) through an approved emerging technology treatment system, and maintaining the onsite stormwater drainage basin volume discharges. The 8-step Process for wetlands was completed concurrent with the 8-step floodplain process. See the Floodplain Management section for a copy of the combined 8-step Floodplain and Wetlands documentation.

5. Consider how the adverse environmental impact and any potentially harmful adjacent land uses would impact the people using and/or surrounding the project. 6. Consider whether market-rate development exists in the aera. If not, would this project succeed as a market-rate project at the proposed site? The report titled "Market Study Report Mount Vernon Apartments 4100 East College Way Mount Vernon, Washington 98273" (Market Study), published by CBRE Group, Inc. September 17, 2019 analyzed comparable market rent values. The average rents ranged from $1,275 for a one-bedroom one-bath unit, to $1,750 for a three-bedroom two-bath unit, with $1,520 the average comparable rent value. The proposed action will restrict tenants to those meeting the 30% and 50% area median income (AMI) level. As a result, restricted rents are estimated to be 23.3% to 51.9% of the corresponding market rents.

With average rents increasing 22.5% in 2019 and vacancies remaining below 5% in the past four years, there expected to be high demand for those meeting the 30% to 50% AMI demographic.

In summary the subject area is forecasted to experience a continued decrease in available units to rent, with a continued increase in population and rent values.