Dairy Creek Prospectus

February 28, 2019

WETLAND MITIGATION BANK PROSPECTUS FOR:

THE DAIRY CREEK MITIGATION BANK

Located in Banks, Washington County, Oregon

Sponsored by: Wolverine LLC 6770 Canyon Drive Portland, Oregon 97225

and

Lone Oak Land and Investments LLC 34059 NW Mountaindale Road North Plains, Oregon 97133

Prepared by: C. Jonas Moiel, Senior Ecologist Green Banks LLC 14200 SE McLoughlin Blvd, Suite A Milwaukie, Oregon 97267 (503) 477-5391

TABLE OF CONTENTS

1. INTRODUCTION AND OVERVIEW………………………………………..1 2. SITE AND SPONSOR INFORMATION...... 1 3. PURPOSE…………………………………………………………………….2 4. SITE SUITABILITY AND FUNCTION GAINS……………………………..3 4.1 Site Suitability…………………………………………………………3 4.2 DSL Principal Objective OAR 141-085-0680………………………4 5. TECHNICAL FEASIBILITY…………………………………………………..8 5.1 Soils…………………………………………………………………….8 5.2 Hydrology………………………………………………………………9 5.3 Vegetation……………………………………………………………..9 6. ESTABLISHMENT AND OPERATION…………………………………….10 7. LONG-TERM PLAN………………………………………………………….11 8. MITIGATION MARKET ANALYSIS………………………………………...11 9. SERVICE AREA………………………………………………………………12

MAPS AND FIGURES :

Figure 1a: Site Location Map Figure 1b: Tax Lot Map Figure 2: NRCS Soils Map Figure 3a: Recent Aerial Photo Figures 3b-c: Historic Aerial Photos Figure 4a: Hydrological Degradation Map Figure 4b: Conceptual Design Map Figure 4c: Conceptual Vegetation Class Map Figure 4d: Conceptual HGM Class Map Figure 5: Service Area Map Figure 6: Topography Map from LiDAR (2007)

DAIRY CREEK MITIGATION BANK PROSPECTUS i 1. INTRODUCTION AND OVERVIEW A mitigation bank is an aquatic habitat created, restored, enhanced, or preserved in accordance with state and federal regulations to compensate for unavoidable adverse impacts to wetlands and other aquatic resources, as authorized by the Oregon Department of State Lands (DSL) and/or the U.S. Army Corps of Engineers (Corps). This Prospectus for a mitigation bank has been provided to solicit comments from natural resources agencies, nearby landowners, and interested parties in order to identify issues of concern to be addressed in development of a more detailed Mitigation Bank Instrument, to be submitted for review and approval by DSL and the Corps. A DSL and/or Corps permit may be needed for construction of the bank. This wetland mitigation bank Prospectus was prepared for the Dairy Creek Mitigation Bank (DCMB) which is located in Banks, Oregon; within the Tualatin River basin. The proposed project site is approximately 134.1 acres and would be separated into Phases; Phase I being approximately 98.0 acres, and Phase II being 36.1 acres. The site is currently in agricultural production of grass seed (tall fescue), but was historically (pre-settlement) dominated by riverine and sloped wetlands that have been drained by agricultural tiling and ditching. The project site is directly adjacent to the eastern boundary of the Killin Wetlands Nature Park, an ecologically unique 590-acre wetland managed by Metro. The purpose of the Dairy Creek Mitigation Bank is to provide wetland mitigation options for private and public developers within the Tualatin River watershed. The potential for developing stream mitigation will also be investigated during the bank establishment process.

2. SITE AND SPONSOR INFORMATION The Dairy Creek Mitigation Bank is proposed on 134.1 acres located in Banks, Oregon (Figure 1); Township 2 North, Range 4 West, Section 36, utilizing a portion of tax lot 800 (144.40 ac); Longitude -123.121295, Latitude 45.616498. Much of the project area is within the 100-year floodplain of the West Fork of Dairy Creek. The northern to northwestern edge of tax lot 800 is bound by the West Fork of Dairy Creek. The DCMB land is owned by Wolverine LLC and the Lone Oak Land and Investments LLC. A new Limited Liability Company (LLC), the Dairy Creek Mitigation Bank LLC, will be established between both owners prior to project approval, which will serve as the bank sponsor. The sponsor team has contracted Green Banks LLC to manage the mitigation bank establishment and operations. Green Banks LLC is a natural resource consulting and land management firm that was established in 2008; located in Milwaukie, Oregon. Green Banks’ scientists have nearly 20 years of experience in environmental consulting, habitat management and mitigation banking. Green Banks is also the consultant and land manager for the Tualatin Valley Environmental Bank in Hillsboro, Oregon; and the Marion Mitigation Bank near Marion, Oregon. Green Banks has the scientific expertise to provide natural resource consulting services for bank establishment and management, as well as a staff of natural resource technicians that provide habitat management services such as chemical and mechanical weed control. Green Banks’ experience with the management of mitigation banks will help to ensure the success of this project.

DAIRY CREEK MITIGATION BANK PROSPECTUS 1

Contact Information for project team: Sponsor: Wolverine LLC Sponsor: Lone Oak Land and Contact: Bob Bobosky, Member Investments LLC Phone: (503)292-8261 Contact: Marty Cropp, Member Email: [email protected] Phone: (503)939-3507 Address: 6770 Canyon Drive Email: [email protected] Portland, Oregon 97225 Address: 34059 NW Mountaindale Rd North Plains, Oregon 97133 Consultant: Green Banks LLC Contact: C. Jonas Moiel, Senior Ecologist Phone: (503)477-5391 Email: [email protected] Address: 14200 SE McLoughlin Blvd, STE A Milwaukie, Oregon 97267

3. PURPOSE The purpose of the DCMB is to restore, create, and enhance wetlands and upland buffers to generate wetland mitigation credits within the Tualatin River watershed. The goals of the project include: improving the functions provided from the wetland areas, increasing the acreage of wetlands, developing diverse native plant communities and buffers, and ensuring a mechanism for long-term protection and management.

The primary objectives of the Dairy Creek Mitigation Bank include: • To improve and replace locally important wetland and stream functions through the removal of artificial drainage features and topography, and planting of native species. • Restoring wetland hydrology to historic wetlands through the de-activation of agricultural drain tiling and ditching. • Creating wetlands in areas adjacent to existing hydric soils with similar elevations and soil types through minor grading of approximately 6-inches or less. • Enhancing existing wetlands through the restoration of hydrology and conversion to native dominated plant communities. • Converting all of the Bank lands into native dominated plant communities. • Identifying a Long-Term Land Steward to manage and maintain the bank area indefinitely. The Bank sponsor would develop a long-term management plan and provide an endowment fund to the Steward prior to bank closure. The secondary objectives include: • Developing several unimproved perimeter access trails for vegetation management access and for passive recreational activities such as bird and wildlife viewing and walking.

DAIRY CREEK MITIGATION BANK PROSPECTUS 2 • Investigating the potential to generate Stream Mitigation Credits. The State and Federal stream mitigation program is under development with a final guidance expected around the summer of 2019. The project area likely has potential for stream mitigation due to the historic straightening of the West Fork of Dairy Creek which caused the de-watering of the more sinuous channel. Some of the channel straightening occurred within the project area and there is potential to develop an intermittent side-channel which curves through a portion of the property. If it is determined that stream mitigation is an option, a separate prospectus may be developed and circulated for public comment at that time. It is predicted that the DCMB will generate roughly 88 wetland mitigation credits (Figure 4b); a more accurate estimate will be made after soils and hydrology studies are completed. This estimate is based on the Natural Resource Conservation Service’s (NRCS) soils mapping, a previous wetland delineation completed on the site, and a preliminary soils survey completed by Green Banks LLC. The existing hydrogeomorphic (HGM) classes of wetlands on-site include Slope/Flats and Riverine. The future HGM classes will remain the same; however, the wetland acreage will greatly increase (Figure 4d). The current vegetation within the project area is tall fescue (grass) and will be converted to Palustrine Emergent (PEM), Palustrine Scrub-Shrub (PSS), Palustrine Forested (PFO) wetlands, and uplands, based on the Cowardin classification system (Cowardin et al. 1979)(Figure 4c). Table 1 displays a summary of the proposed mitigation types and acreages.

Table 1: DCMB Proposed Mitigation Types Type Acres Credits Restoration (1:1) (w/approx. 40% creation) 84.6 70 Creation (1.5:1) 21.3 14.2 Enhancement (3:1) 7.9 2.6 Buffers (10:1) 20.3 2 TOTAL 134.1 88.8 PFO 78.9 PSS 15.6 PEM 19.3 Upland Buffers 20.3 Riverine Flow-Through 55.4 Slope/Flats 58

Note: If stream credits are produced, the wetland and aquatic credit ledgers would be coordinated to ensure that the same functional gains are not sold to multiple markets. 4. SITE SUITABILITY AND FUNCTION GAINS 4.1 Site Suitability The proposed Dairy Creek Mitigation Bank is located in an area highly suited for ecological restoration. The existing wetlands have low functionality which can be greatly improved through the implementation of the project. The NRCS mapped 93.6 acres of hydric soils within the project area; however, most of the area has been drained yielding a small acreage of existing wetland based on a wetland delineation completed by

DAIRY CREEK MITIGATION BANK PROSPECTUS 3 Pacific Habitat Services in 2008. The locations of active and historic drainage features are shown on Figure 4a as well as historic aerial imagery (Figures 3b-c) and can be reversed during construction of the project. The West Fork of Dairy Creek was straightened along the tax lot boundary prior to 1936 (our earliest historic aerial), and one of the sinuous curves of the creek was de-watered/ disconnected around 1963. The functionality of the creek and adjacent wetlands can be improved through the removal of artificial debris which armors the channel above the top-of-bank, allowing the creek to be re-connected with the floodplain, and/or through the creation of a new intermittent stream channel within the project area. The project area was historically a forested wetland complex and is now entirely in agricultural production. The lands surrounding the project area and adjacent land uses are compatible with mitigation banking. The lands to the north and south are primarily in agriculture, zoned EFU, and are compatible with mitigation banking. The Killin Wetlands Nature Park is directly to the west, and lands to the east of the project area are primarily in residential and commercial development. The eastern perimeter of the project area will be developed into a forested buffer to limit any negative effects from adjacent land uses. There are no airports in close vicinity (within 1-mile radius) to the project area. The Rieben airport, a small private airport, is located approximately 2.1 miles to the southeast. 4.2 DSL Principal Objective OAR 141-085-0680 The proposed mitigation bank will meet DSL’s principal objective OAR 141-085-0680 as described below. (a) Replace functions and values lost at the removal-fill site. The DCMB will provide wetland mitigation for impacts within the Tualatin River watershed. Based on a review of removal/fill permits submitted within the watershed over the last decade, most of the wetland impacts are to Riverine and Slope/Flats, HGM class wetlands. The impacted wetlands are typically low- functioning for biological functions, with a range of functionality for chemical functions. An Oregon Rapid Wetland Assessment Protocol (ORWAP) has not yet been completed for the project area. However, Green Banks’ scientists have conducted a preliminary soils survey of the project area and investigated the West Fork of Dairy Creek, and are familiar with the baseline conditions. Based on our experience in using ORWAP, it is assumed that the baseline conditions of the DCMB would score Low to Medium in all functional categories. Please see Table 2 which includes a summary of predicted current and future (after construction) conditions.

Table 2: Wetland Function Prediction ORWAP Functional Predicted Predicted Detail Categories Current Future Water Storage & Delay (WS) Low-Med Med- Current: Floodplain is partially disconnected from creek, High has ditching and tiling, vegetation is grass only. Future: Improved creek connection from floodplain. Removal of drainage features, increased topological complexity, addition of trees and shrubs.

DAIRY CREEK MITIGATION BANK PROSPECTUS 4 Sediment Retention & Low-Med Med- Current: Vegetation is grass only; some evidence of Stabilization (SR) High erosion from flooding. Future: Vegetation will be mixed herbs, trees, and shrubs that better retain sediments, and deeper roots will improve stabilization. Complex topography will also improve retention. Phosphorus Retention (PR) Low-Med Med- Current: Vegetation is grass only, little topological variation, High small wetland acreage, artificial drainage. Future: Addition of trees and shrubs with deeper rooting will have potential for translocation deeper below ground with less potential for entering the water column. Chemical adsorption is optimal in clayey soils and the increase of wetland acreage will improve retention. Improved topological complexity will increase sedimentation. Removal of artificial drainage will improve surface water filtration. Agricultural fertilizers will also no longer be used. Nitrate Removal & Retention Low-Med Med- Current: Vegetation is grass only, little topological variation, (NR) High small wetland acreage, artificial drainage. Future: Addition of trees, shrubs and herbs will increase nitrogen removal rates. Increased microbes will improve de-nitrification rates. Removal of artificial drainage will improve surface water filtration. Agricultural fertilizers wi ll also no longer be used. Water Cooling (WC) Low Med- Current: Project area is covered by grass with a narrow High forested buffer on W Fork Dairy Creek. Future: Most of project area will be shaded by tree or shrub cover. Emergent areas will be partially shaded and additional forested buffers will provide shade to the creek. Carbon Sequestration (CS) Low Low- Current: Small acreage of wetlands with limited seasonal Med ponding, non-native grass community. Future: Larger acreage of wetlands with increased seasonal ponding. Native tree, shrub and herb community. Methane production would be limited due to seasonal inundation. Organic Matter Export (OE) Low Med Current: Partially disconnected floodplain with outlet, non - native grass plant community. Future: Improved floodplain connection and outlet, increased inundation and wetland acreage, native dominated plant community with emergents. Aquatic Invertebrate Habitat Low Low- Current: Drained wetlands, no persistent ponding, non - (INV) Med native vegetation, actively farmed. Future: Increased wetland acreage, increased seasonal ponding duration, dominated by native vegetation. Anadromous Fish Habitat Low Low- Current: Creek partially disconnected from floodplain, non - (FA) Med native vegetation. Future: Creek connected to floodplain. Planted native vegetation will improve floodplain habitat. The W. Fork Dairy Creek is considered essential salmonid habitat. Non-Anadromous Fish Low Low- Current: Creek partially disconnected from floodplain, non - Habitat (FR) Med native vegetation. Future: Creek connected to floodplain. Planted native vegetation will improve floodplain habitat. The W Fork Dairy Creek is considered essential salmonid habitat.

DAIRY CREEK MITIGATION BANK PROSPECTUS 5 Amphibian & Reptile Habitat Low Med- Current: No native vegetation, grass only, small wetland (AM) High acreage. Future: Increased wetland acreage; restored hydrology. Diverse native plant assembleges. Complex topography. Waterbird Feeding Habitat Low Med Current: Drained wetlands, limited surf ace water. No native (WBF) vegetation. Future: Increased surface water retention (seasonal ponding). Diverse native plants will provide forage and habitat. The largely forested project area will limit the size of the WBF habitat. Waterbird Nesting Habitat Low Med Current: Drained wetlands, limited surface water. No native (WBN) vegetation. Future: Increased surface water retention (seasonal ponding). Diverse native plants will provide forage and habitat. In close proximity to Killin wetlands which provides excellent forage opportunities. The largely forested project area will limit the size of the WBN habitat. Songbird, Raptor & Mammal Low Med- Current: No habitat structure, small wetland acreage, non - Habitat (SBN) High native plant community. Future: Diverse native plant community, increased wetland acreage, increased seasonal ponding, increased biodiversity. Pollinator Habitat (POL) Low High Current: 100% non -native grass community, small acreage of wetlands with seasonal ponding. Future: Diverse native plant community of flowering plants. Increased wetland acreage and ponding. Native Plant Diversity (PD) Low High Current: 100% non -native plant community. Future: Diverse native plant community.

It is predicted that functional lift will occur in all ORWAP categories if the project is implemented; additionally, the wetland acreage would be increased greatly.

The DCMB will mitigate for functions and values lost at the removal fill site(s) as it is predicted to have functional gains in all categories. Most wetland impact sites within the watershed are not highly functioning; therefore, the DCMB will replace and potentially provide a net gain of wetland function. (b) Provide local replacement for locally important functions and values, where appropriate. The DCMB is located within the Dairy-McKay sub basin within the Tualatin River Watershed. The Tualatin River Watershed Council (TRWC) provided a description of major watershed issues in their Dairy-McKay Watershed Analysis (2001); these issues are similar to those identified in the larger Tualatin River watershed. The major issues included: • Erosion; primarily in areas with timber harvest, agriculture, and along stream channels. “ The West Fork of Dairy Creek, in particular, appeared to be particularly susceptible to stream bank erosion problems .”; • Hydrology issues such as wetland drainage and stream canalization . “Stream banks were built up to facilitate log driving. These activities contributed to hydrologic disconnection of streams from their floodplain .”;

DAIRY CREEK MITIGATION BANK PROSPECTUS 6 • Water quality issues such as high temperature, phosphorus and bacteria levels. The West Fork of Dairy Creek has “ summertime dissolved oxygen levels limiting to aquatic life ”; • Aquatic species habitat loss related to channelization, de-forestation, water quality issues, and impassible culverts. Several salmonid species utilize Diary Creek, including steelhead trout, cutthroat trout and Coho salmon. Lamprey also occupy the watershed. Amphibian species of concern are found within the watershed including red-legged frog, tailed frog, and Columbia torrent salamander; • Terrestrial species habitat loss caused by de-forestation and conversion to agriculture. • Vegetation conversion from native forests and prairies for agriculture. Riparian corridors “have been diminished and are generally narrow ”. “Invasive weed species are present throughout disturbed and non-forested portions of the watershed. Himalayan blackberry, reed canarygrass, and Scotch broom are particularly notable examples. ”; The Dairy Creek Mitigation Bank will replace locally important functions and values by reducing erosion through the planting of perennial native plants, including trees and shrubs which are deeply rooted; restoring historic hydrology through the removal of drainage features and creek channel armoring; improving water quality parameters by providing shade and native plants to remove nutrients and retain sediment; and improving aquatic, semi-aquatic, and terrestrial species habitat through the addition of topological complexity, increased wetland acreage and conversion to diverse native plant communities. It is predicted that there will be functional lift in all ORWAP categories if the project is implemented, therefore some level of functional replacement would occur for all locally important functions lost within the watershed. (c) Enhance, restore, create or preserve wetlands or tidal areas that are self-sustaining and minimize long-term maintenance needs. The DCMB will be designed to be self-sustaining with minimal long-term maintenance needs. The construction of the project will include the reversal of artificial drainage features such as the de-activation of tiling and filling of ditches; no water control structure that would require maintenance will be installed. Most of the DCMB will be planted in forests and shrub dominated plant communities which will require little to no maintenance on the long-term. Areas of emergent wetland will be located in areas with heavier clay substrate and will be buffered by native forest. Densely planted upland shrub and forested buffers will surround the perimeter of the DCMB, which will limit the influx of non-native plant species. (d) Ensure the siting of CWM in ecologically suitable locations considering: local watershed needs and priorities; appropriate landscape position for the wetland types, functions and values sought; connectivity to other habitats and protected resources, and the absence of contaminants or conflicting adjacent land uses that would compromise wetland functions. The DCMB is sited in an appropriate landscape position to develop the wetland and vegetation class types proposed. The area was historically dominated by Riverine and Slope/Flats wetlands (pre-settlement) and a majority of the soils are mapped as hydric by NCRS. It is in an excellent location for improving functions related to watershed needs and priorities as described in Section 4.2b. The DCMB is directly adjacent to the Killin Wetlands Nature Park, a 590-acre preserve managed by Metro. The project area is also connected to many other natural areas through a series of forested and aquatic

DAIRY CREEK MITIGATION BANK PROSPECTUS 7 corridors, such as along the West Fork of Dairy Creek which runs along the north and northwestern project area boundaries. There is a small area on the adjacent tax lot 600, near the southeastern corner of the Phase 1, that has been determined to have lead contamination. If this contamination is determined to extend onto the project area, recommended remediation actions will be taken to ensure that the pollutant doesn’t negatively impact the project’s functions. The eastern project area boundary is in close proximity to residential and commercial development. The potential negative impacts from the adjacent development include noise, air, and water pollution; as well as invasive species transport and human disturbance. In an effort to reduce these potential impacts, densely forested and shrub dominated buffers will be established adjacent to the eastern project area boundary. Perennial and evergreen plants with varying height classes will be used as much as possible, to establish a vegetated barrier around the site. Forested and shrub wetlands will also be established adjacent to these upland buffers to expand the effective buffer width with regard to several of these potential impacts (e.g. noise, air, weed seed transport). (e) Minimize temporal loss of wetlands and tidal waters and their functions and values. Mitigation banking inherently minimizes the temporal loss of wetlands and their functions and values due to banking projects being installed in advance of providing wetland mitigation credit. Mitigation banking projects can last ten years or more and the mitigation wetlands may provide functions for many years prior to credit being sold to offset a project’s functional losses. 5. TECHNICAL FEASIBILITY The following section describes the technical feasibility of the project in terms of soils, hydrology, and vegetation. Please refer to Figures 4a-d for conceptual design and degradation maps, and the current and historic aerial photography (Figures 3a-c). A wetland delineation was conducted by Pacific Habitat Services (PHS) in 2008 which received DSL concurrence in 2009 (WD# 08-0516). A total of 7.73 acres of wetland and 1.13 acres of ditches were delineated. The delineation has expired and will need to be updated, but on-site conditions appear to be similar. 5.1 Soils The NRCS soil survey maps approximately 93.6 acres of hydric Wapato silty clay loam within the project area; 59.5 acres within Phase 1, and 34.1 acres within Phase 2 (Figure 2). McBee silty clay loam is mapped on approximately 36.1 acres, with 35.6 acres within Phase 1, and 0.5 acres within Phase 2. Mcbee silty clay loam is a non-hydric soil with hydric inclusions. A small portion of the project area (approx. 4.4 acres) are mapped as non-hydric Woodburn silt loam. Green Banks’ scientists have conducted soils surveying on most of the project area, including more than 30 soil test plots within the mapped Wapato silty clay loam. In general, the NRCS soils mapping is roughly accurate with some areas of hydric soils extending further than shown, and some areas of non-hydric soils within the Wapato soil type. A poorly drained, clay-loam to clay textured layer exists, starting within about 6 to 16 inches of the soil surface in the Wapato mapped soils. These clayey textures were also observed in

DAIRY CREEK MITIGATION BANK PROSPECTUS 8 many areas mapped as McBee silty clay loam. It was noted that even though the soil textures and colors were fairly consistent throughout the Wapato mapped series, that some of the soil test locations did not meet the definition of a hydric soil based on the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Valleys, Mountains and Coast Region (Version 2.0, 2010). The most common hydric soil indicator observed was Redox Dark Surface (F6), which by definition starts within the top eight inches of the soil profile and must be at least 4 inches thick. In some cases, a matrix value of 3 or less with a chroma of 2 or less with 5% or more distinct or prominent redox concentrations (parameters of F6) were observed starting slightly below eight inches of the ground surface. These areas are well suited for wetland creation. The project area has been in agriculture for more than 100 years and some plowing and discing of soils has occurred, as well as soil movement associated with the constructing and de-commissioning of ditches and access roads. During our soils investigation, we noted evidence of shallow soil disturbance (<13 inches in depth) in a few areas likely due to farming practices. The DCMB is proposed on 134.1 acres, 70% (93.3 acres) of which is mapped as having hydric soils by NRCS. Green Banks’ preliminary soils survey determined that the NRCS soils mapping is roughly accurate. The soil types located within the project area are excellently suited for wetland restoration and creation as they are poorly drained, clayey in texture, and appropriately located within the landscape. 5.2 Hydrology The Dairy Creek Mitigation Bank has three primary hydrology sources: surface water and high groundwater table associated with the West Fork of Dairy Creek, groundwater seeps from the gentle hillslopes along the eastern portion of the project area, and precipitation. Figure 4a displays the known historic and current hydrologic degradation that has occurred on-site. Currently, the primary sources of hydrologic degradation include tiling of the Phase 1 wetlands located in the eastern portion of the site, tiling of the northern and centrally located hydric soil areas within Phase 1, and ditching and tiling located in Phase 2. These artificial sources of degradation can be de-activated during project construction by excavating and removing tiling, and filling (plugging) ditches. The West Fork of Dairy creek has earthen berms and artificial material (e.g. concrete, rock) above the top- of-bank which is partially disconnecting the creek from the floodplain. During project construction, the creek bank located within the project area will be restored to its natural grade and artificial debris will be removed. The creek typically floods the site between December and March. The DCMB has natural hydrology sources (Riverine, Slope) which should not change in the foreseeable future. The reversal of artificial drainage features will likely provide the hydrology necessary to restore areas of drained hydric soils, and create wetlands in areas of similar soil types and topography. It is predicted that minor grading of 6 inches or less will be required to create wetlands in some areas; these areas have hydric soil indicators slightly deeper than specified in the definition of a hydric soil for wetland delineation. Water rights will not be needed for this project as there will be no irrigation or water control structures. 5.3 Vegetation Nearly all of the project area is currently planted in tall fescue ( Schedonorous arundinaceus ) and very few weeds exist within the farmed area. The current fescue crop was installed approximately five years ago. The

DAIRY CREEK MITIGATION BANK PROSPECTUS 9 area has also been planted in other crops such as wheat and clover. The small wetlands located in the eastern portion of the project area are dominated by reed canarygrass ( Phalaris arundinacea ). Very few trees exist within the project area; a narrow-forested buffer of approximately 5 to 20 feet exists adjacent to the West Fork of Dairy Creek in proximity to the northern project area boundary. The historic vegetative communities within the project area likely consisted of deciduous wetland forest, emergent wetland, and mixed upland forest. The western project area boundary is adjacent to a mature Oregon ash forest ( Fraxinus latifolia ); a small portion of this forest can be observed in the Phase 2 area in 1940 (Figure 3c) prior to deforestation. Emergent wetlands would have likely existed in the low elevation areas that have shallow, clayey soils. Mixed forests dominated by Oregon white oak, red alder, big leaf maple, and Douglas fir, can be observed in nearby upland areas such as in the Killin Wetlands Nature Park and would be well suited for the upland areas within the DCMB. The project area currently has very low weed cover and has not had soil manipulation since the last agricultural seeding approximately five years ago. It is anticipated that conversion of the site from agriculture to native plant communities will include site preparation for approximately one growing season followed by dense seeding and planting of native species. Native species will be planted in ecologically suitable locations and not require irrigation. Native plant communities will also be developed to be self-sustaining and require low maintenance. Invasive species known to be common in the vicinity include reed canarygrass, Armenian (Himalayan) blackberry ( Rubus armeniacus ), Canada thistle ( Cirsium arvense ), bull thistle ( Cirsium vulgare ), and teasel (Dipsacus sylvestris ). These species, as well as other non-native invasives, will be monitored and controlled during the bank establishment period and for the long-term. The mitigation planting plan will locate species assemblages in a manner that will limit the chance for invasive species establishment. Additionally, densely planted tree and shrub buffers will limit the influx of weed seed from adjacent properties. 6. ESTABLISHMENT AND OPERATION The Dairy Creek Mitigation Bank will be sponsored by the Dairy Creek Mitigation Bank LLC, with a consulting and management contract with Green Banks LLC. The DCMB LLC owns the bank land and will permanently protect it with a deed restriction and/or conservation easement. Green Banks will be the primary source of contact for the project and manage all other aspects of the bank. Green Banks will also provide the following services: environmental consulting, land management, construction, maintenance, monitoring, credit accounting and sales, and project management. The project is proposed to be implemented in two phases. The primary reasoning for phasing the project is to ensure that there is enough demand for the mitigation credit. It is anticipated that Phase 2 of the project will be implemented approximately five years after Phase 1. The separation of the project into phases is ecologically feasible because the de-activation of artificial drainage features in Phase 1 will not likely cause substantial change on the Phase 2 lands. The southern portion of Phase 1, adjacent to the Phase 2 area, will be planted in native forest which will provide a buffer between phases in case the second phase is never implemented. Establishment of the mitigation bank will include vegetative site preparation, construction (earthwork), seeding and planting, and implementation of access controls. Vegetative site preparation will take place over a growing season and primarily include herbicide application. Construction of the project will include the

DAIRY CREEK MITIGATION BANK PROSPECTUS 10 excavation of drain tiling and replacing with native soils, filling of ditches with native soils, gentle grading in some areas for wetland creation and topological complexity, and the removal of earthen and artificial berms along portions of the West Fork of Dairy creek. All areas where earthwork is completed will have soils gently compressed. Some of the excavated soils will be placed outside of the floodplain to provide a net gain in floodplain storage. Construction would occur in the summer with seeding and planting occurring in the fall through spring. Native seed with be sown using a mix of drilling and aerial flailing. Most seeding would occur prior to October 1 st to ensure some vegetative cover on areas of bare ground prior to the rainy season. Most trees and shrubs would be planted during the winter months in the form of bare root and live-stake. Woody species would be planted at high densities to ensure quick establishment and low maintenance on the long- term. Fencing will be installed from the eastern to southern perimeter of the site, with gated access. The western perimeter of the site is directly adjacent the Killin Wetlands Nature Park and is partially fenced, and the northern perimeter is primarily bound by the West Fork of Dairy Creek. After initial construction of the bank, a portion of the credits will be made available for sale to permit applicants. The bank sponsor will continue activities needed to establish target vegetation and wetland functions, and will submit annual monitoring reports to the agencies to support further credit releases or to identify any plan modifications or remedial actions needed. The bank sponsor will assume liability for the mitigation obligations represented by the credit sales. When the project is completed and monitoring confirms that the objectives have been met and maintained for the requisite time period, management of the site will be turned over to a long-term stewardship entity approved by the regulatory agencies. 7. LONG-TERM PLAN The project area will be managed by the DCMB LLC and Green Banks LLC for approximately ten years (per phase) and then management responsibility will be transferred to a reputable long-term land steward. A long-term management plan will be developed to detail the roles and responsibilities of the steward, and an endowment fund will be provided to fund the costs associated with management. The primary goal of long- term management is to ensure the protection of wetland and aquatic functions in perpetuity. The sponsor anticipates completing a fee-title transfer of the bank land to the steward upon bank closure; a conservation easement may also be established. The DCMB will likely be a desirable acquisition as it is will be ecologically diverse and low-maintenance. Due to the close proximity to the Killin Wetlands Nature Park the most suitable long-term steward for the project is Metro. Metro has the capability and experience to manage a site like the DCMB. Other potential entities for stewardship include the Tualatin Soil and Water Conservation District, Clean Water Services, the Wetlands Conservancy, Columbia Land Trust, and the U.S. Fish and Wildlife Service. 8. MITIGATION MARKET ANALYSIS There is a need for additional mitigation options within the Tualatin River watershed. The watershed includes most of Washington County and small portions of Clackamas and Multnomah Counties, including the cities of Banks, Beaverton, Cornelius, Forest Grove, Hillsboro, King City, Lake Oswego, North Plains, Oregon City, Portland, Sherwood, Tualatin, and West Linn.

DAIRY CREEK MITIGATION BANK PROSPECTUS 11 “Washington County’s total population has grown strongly in the 2000s, with an average annual growth rate of 1.8 percent between 2000 and 2010...Total population in Washington County and its sub-areas outside of the county’s Metro boundary will likely grow at a faster pace in the near term (2017-2035) compared to the long-term...total population is forecast to increase by close to 176,000 over the next 18 years (2017-2035) and by more than 269,000 over the second part of the forecast period (2035-2067). ” (Coordinated Population Forecast for Washington County, its Urban Growth Boundaries and Areas Outside UGBs; Population Research Center, Portland State University 2017). An increase in population size will cause increased residential, public and commercial development. The county is also home to large businesses such as Nike and Intel, and it is anticipated that other commercial and industrial development will continue to occur in the future.

Local Wetland Inventory (LWI) map data were available for 10 cities within the proposed service area: Banks, Beaverton, Cornelius, Forest Grove, Hillsboro, North Plains, Sherwood, Tigard, Tualatin, and West Linn. The LWI map data provided coarse mapping and general summary information about the wetlands that were located within the urban growth boundaries of these cities. There was a total of approximately 1,890 acres of wetlands identified, a majority of which were associated with a stream or river. The most common HGM classes identified were Riverine Flow-Through, Riverine Impounding, Slope/Flats and Depressional Outflow. The predominant vegetation class within these wetlands was PEM, encompassing approximately 930 acres, or 50% of the total wetlands identified. There were approximately 520 acres of PFO wetlands, which was approximately 30% of the total wetlands identified. The lesser common wetland types were PSS (15%) and Palustrine Open Water (POW)(5%), with approximately 440 acres total. Historically, there was a much higher proportion of PFO wetlands within the watershed, but deforestation for agriculture has transitioned many of them into degraded PEM wetlands. There are thousands of acres of wetlands remaining within the watershed, many of which may be impacted by urban growth. There are three wetland mitigation options for developers within the watershed; the Tualatin Valley Environmental Bank (approx. 8.5 credits remain), the Butler Bank (approx. 26 credits remain), and the Half Mile Lane In-Lieu Fee Bank (approx. 8.3 credits remain); for a total of approximately 42.8 credits. Over the past five years (2014-2018), a total of approximately 6 to 8 mitigation credits were purchased through mitigation banks annually, with 2018 having the highest demand. Based on this rate of demand, the remaining mitigation credits in the watershed (42.8) may be used within the next 5 to 6 years; or around 2024. The DCMB has the potential to provide mitigation options for many years and will be developing wetland types which are similar to those most commonly impacted (PEM, PSS, PFO; Slope/Flats, Riverine). 9. SERVICE AREA The Dairy Creek Mitigation Bank is proposed to have a service area within the Tualatin River Watershed, 4 th Field Hydrologic Unit Code (HUC) 17090010, below 1,000 feet in elevation (Figure 5). The NRCS mapped Wapato silty clay loam (hydric) observed within the project area has been found to occur within the region at elevations between 100 and 2,500 feet. The DCMB is proposing a lower service area elevation limit of 1,000 feet because most of the bank site is located within a low elevation floodplain (at approximately 190ft in elevation).

DAIRY CREEK MITIGATION BANK PROSPECTUS 12 MAPS AND FIGURES :

DAIRY CREEK MITIGATION BANK FIGURES L

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Figure 1a: Dairy Creek Mitigation Bank Location L R

O D O W K S A A R V I Y K U I D T S O N

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A R T ELDERBERRY E S DEER L YS H R E H 26 T C R ¤£ R

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W H T L A I R 47 L TW L £ I M L ¤ A IC H K L E L T G E

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S T LIPPERT R DIERICKX O H M AY E R

S W E IL K A E V S E B Y O R CL O AP SH AW

HI LL GREENVILLE

R O RE Y REASU K T A N REILING S A S

C I N T Y S A H P I M LL R S S E R I E ME D L L E A HA T C D N B E O SALZWEDEL G R O U G

T H

E B $ OTIS BREEZY

GA NNA 47 S ¤£ R 0 1 2 Miles E Project Area V

T KEMPER E H A T HEYNDERICKX C OSTER H MAN E Hill shade and streets layer provided by RLIS. R Figure 1b: Tax Lot Map (T2N R4W S36)

Project Area

PHASE 1 (98.0 ac)

PHASE 2 (36.1 ac) $

Project Area

Tax lot map provided by ormap.net Figure 2: Natural Resource Conservation Service (NRCS) Soils Map k ree iry C 43 Da ork st F We

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30- P1: 35.6 ac, P2: 0.5 ac 43- P1: 59.5 ac, P2: 34.1 ac 45A- P1: 0.1 ac 45B4- 5PA1: 3.2 ac, P2: 1.1 ac 43 Soils

43 Hydric Soils 1

45B Soil Symbol Soil Name

45A 1 Aloha silt loam

30 McBee silty clay loam ¤£6

43 Wapato silty clay loam HYDRIC NW Wilso n Rive r Hwy 1 45A Woodburn silt loam, 0 to 3 $ percent slopes 0 500 1,000 Feet 1 45B Woodburn silt loam, 3 to 7 percent slopes 1 inch = 500 feet when printed on 8.5"x11" paper

Soils layer downloaded from NRCS Web Soil Survey https://websoilsurvey.sc.egov.usda.gov/App/WebSoilSurvey.aspx Figure 3a: Aerial Photography July 2018

k ree iry C Da ork st F We

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1 inch = 500 feet when printed on 8.5"x11" paper Aerial photograhy provided by Google Earth Figure 3b: Aerial Photography February 1968

k ree iry C Da ork st F We

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0 500 1,000 Feet Project Area

1 inch = 500 feet when printed on 8.5"x11" paper Aerial photograhy provided by US Army Corps of Engineers Figure 3c: Aerial Photography August 1940

k ree iry C Da ork st F We

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1 inch = 500 feet when printed on 8.5"x11" paper Aerial photograhy provided by the US Army Corps of Engineers Figure 4a: Hydrological Degradation Map

k ree iry C Da ork

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F Tile F APPROXIMATE F CULVERT Debris LOCATION

F F F Stream F ¤£6 DITCHES FROM 2009 DELINEATION 0 250 500 1,000 Feet N W Wils 1 inch = 500ft when printed on 8.5"x11" paper on Riv er Hwy Figure 4b: Conceptual Design Map

7.8 ac k ree iry C Da ork st F We

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PHASE 1 Credit Prediction: Restoration (1:1)- 70 credits 1.2 ac PHASE 2 (some creation assumed within) Creation (1.5:1)- 14.2 credits Enhancement (3:1)- 2.6 credits Upland Buffers (10:1)- 2 credits TOTAL credits predicted= 88.8

30.3 ac Project Area Restoration Creation Enhancement $ 0.8 ac Buffers

6 3.5 ac ¤£ Acreage Totals: Restoration- 84.6 ac (P1- 54.3 ac, P2- 30.3 ac) NW Wils on Ri Creation- 21.3 ac (P1- 21.3 ac) ver Hw y Enhancement- 7.9 ac (P1- 5.9 ac, P2- 2.0 ac) 0 250 500 1,000 Feet Upland Buffers- 20.3 ac (P1- 16.8 ac, P2- 3.5 ac)

1 inch = 500 feet when printed on 8.5"x11" paper

Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community Figure 4c: Conceptual Vegetation Class Map

7.8 ac k ree iry C Da ork st F We

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k r o F 15.6 ac t s e W 49.6 ac

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N Upland Buffer (P1- 16.8 ac, P2- 3.5 ac) W Wils 0 500 1,000 Feet on Riv er Hwy

1 inch = 500 feet when printed on 8.5"x11" paper

Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community Figure 4d: Conceptual HGM Class Map

k ree iry C Da ork st F We

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1 inch = 500 feet when printed on 8.5"x11" paper

Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community 1996 Flood Extent line provided by RLIS Figure 5: Service Area Map Ridgefield

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Contours produced from LIDAR provided by the State of Oregon Service Layer Credits: Source: Esri, DigitalGlobe, GeoEye, Earthstar Geographics, Department of Geology and Minearl Industries. Acquisition date(s): CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community Mar 16 to Apr 15, 2007.