Reference: City of DuPont Critical Areas Ordinance Update Best Available Science Review

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1 Stantec Consulting Services Inc NE 33rd Place Suite 200, Bellevue WA May 16, 2017 File: Attention: Mr. Jeffrey S, Wilson, Community Development Director City of DuPont 1700 Civic DR DuPont, WA Reference: City of DuPont Critical Areas Ordinance Update Best Available Science Review Dear Mr. Wilson, It has been a distinct pleasure to assist the City of DuPont thus far with your Critical Areas Ordinance (CAO) update. As we near the public hearing process and ratification by the City Council soon, it is time to provide a Best Available Science (BAS) support document. Attached to this letter is the bibliography we employed to support our initial development of the draft CAO. This set of information was also much of the basis for the answers we provided to many Planning Commission questions over the past series of workshops. To summarize, BAS documents are part of every CAO update in Washington State. Recently in 2005 and 2016 there were several approved updates that included solid reviews of the base literature. Stantec reviewed these documents and, in consultation with you made the decision to work with these literature and science sources to meet the BAS review for DuPont. Given that these sources were recent and comprehensive we believe that DuPont has a solid foundation of science as a basis for the proposed CAO update. There are a few key documents that explain buffer widths that are helpful to all and were used in developing this CAO document. Bentrup (2008) was most helpful toward establishing buffer width recommendations in addition to Ecology (2005, 2013) that provides an update to the state of the science regarding wetland buffers. We reviewed these documents and compared the information with other jurisdictions and Washington State guidelines to place the proposed DuPont buffer parameters within accepted ranges for protection. Impact mitigation ratios were also developed based on BAS. Ecology (2005, 2006a, and 2006b) provides recommended language for CAOs (see Appendix 8-B of Ecology 2005). These documents provide solid scientific review and justification for wetlands protection, buffer width establishment, mitigation sequencing, and explanation for the types of mitigation such as in-kind and out-of-kind. Somerville (2010) offers added and specific guidance for stream assessment and mitigation approaches that helped craft the Fish & Wildlife Habitat Conservation Areas segment of the DuPont CAO.

2 May 16, 2017 Mr. Jeffrey S, Wilson, Page 2 of 3 Reference: City of DuPont Critical Areas Ordinance Update Best Available Science Review It is important to note the attached bibliography contains multiple literature sources that include the actual language of several recent CAO documents in local cities and counties in WA state as well as technical documents specific to the various critical areas addressed in the CAO update. Each of these files have been provided to you electronically in PDF format. Members of the Planning Commission asked what the best references were to gain a more in-depth understanding of the science surrounding critical areas protection. Those that I found helpful and offer a good reflection of the current science related to protection of critical area function and value are those produced for Edmonds and Kirkland. In addition to these, we recommend the technical references offered by state and federal agencies. All communities are a bit difference but these offer more similarities to DuPont as opposed to Seattle and Bellevue which are very densely populated urban communities. You will find the BAS reviews for those communities also useful but density plays a bigger role in developing CAOs. Although communities differ and indeed have element if uniqueness in their CAO language, they are all fundamentally consistent with each other based on BAS. Most cities and counties build their BAS foundation in a similar manner as taken with DuPont reviewing updates and advancements to previous science compilations and summaries. Guidance for CAO preparation provided by the State of Washington (Ecology 2005 Appendix 8-B) allows for some flexibility in CAO development provided sound science (emphasis added) is followed. For DuPont, buffers and land use guidance has been developed to assist your community to manage the developed nature of your community and allow for enhancement, rehabilitation and restoration as opportunities arise. The proposed CAO update offers better science-based clarification of the critical areas within DuPont, provides science-based tools to shape and guide land use actions to avoid, reduce or mitigation future impacts to critical areas, and offers the City more robust science-based methods to process applications and make land use decisions.

3 May 16, 2017 Mr. Jeffrey S, Wilson, Page 3 of 3 Reference: City of DuPont Critical Areas Ordinance Update Best Available Science Review This set of BAS documents was considered in all elements of the CAO. I believe the CAO update as proposed fits the need to incorporate BAS and meet the City of DuPont s objectives to preserve, protect, and improve critical areas within your community. Regards, STANTEC CONSULTING SERVICES INC. Wayne S. Wright, PWS, CF-P Principal Scientist Phone: (425) Wayne.Wright@stantec.com Attachment: BAS Bibliography c.

4 AMEC Environment & Infrastructure, Inc Best Available Science, Wetlands. Prepared for City of Sammamish, Bentrup, G Conservation Buffers; Design Guidelines for Buffers, Corridors, and Greenways. United States Department of Agriculture and Forest Service, Southern Research Station, General Technical Report SRS-109, September Bissonette, J. and P. Krausman Integrating People and Wildlife for a Sustainable Future. International Wildlife Management Congress, 10.6 Towards A Definition of Biological Corridor, pp , The Wildlife Society, Bethesda, Maryland, City of Bremerton City of Bremerton Critical Area Ordinance Best Available Science References, Exhibit A Attachment I. City of Bremerton City of Gold Bar. 2016a. City of Gold Bar, Critical Areas Ordinance Update. City of Gold Bar, Draft City of Gold Bar. 2016b. City of Gold Bar Determination of Nonsignificance, 2016 Critical Ordinance Update. City of Gold Bar, May 13, City of Gold Bar City of Gold Bar, Critical Areas Ordinance Update. City of Gold Bar, Draft March 15, City of Lynnwood City of Lynnwood Ordinance No. 3193, Chapter (Environmentally Critical Areas). City of Lynnwood, June 1, City of Nooksack City of Nooksack 2016 Critical Areas Regulations Updates, Chapter City of Nooksack, Draft April City of Port Townsend Port Townsend Municipal Code, Title 19 (Environmental Protection), Chapter (Critical Areas). City of Port Townsend, current through December 5, City of SeaTac SeaTac Municipal Code, Title 15 (SeaTac Zoning Code), Division VII (Critical Areas), Chapter (Critical Areas), Exhibit A, Draft Code Amds. Dft.17. City of SeaTac, Draft August 23, City of Seattle Geologic Hazards Best Available Science City of Seattle City of Seattle Environmentally Critical Areas Code Update: Best Available Science Review for Fish and Wildlife Habitat Conservation Areas. City of Seattle with Parametrix, Updated by Confluence Environmental Company. City of Seattle Department of Planning and Development, August 2005, Updated December Cowlitz County Cowlitz County Critical Areas Ordinance, Chapter 19.15, Edits for SEPA Review. Cowlitz County, September 21, Crose, T Critical Areas & Resource Lands Ordinance Update, Pacific County, Presentation Notes. Prepared for Pacific County Department of Community Development, March 31, 2016.

5 ECONorthwest The Economic Value of Beaver Ecosystem Services, Escalante River Basin, Utah. October Environmental Protection Agency (EPA) Connectivity of Streams & Wetlands to Downstream Waters: A Review & Synthesis of the Scientific Evidence. Office of Research and Development, United States Environmental Protection Agency, EPA/600/R-14/475F, January 2015, Washington, DC. Environmental Science Associates (ESA). 2015a. Final City of Edmonds Critical Areas Ordinance Update, Best Available Science Addendum. Prepared for City of Edmonds, March 16, Environmental Science Associates (ESA). 2015b. Final Island County Critical Areas Ordinance Update, Best Available Science Report. Prepared for Island County, GMA No , October Federal Emergency Management Agency (FEMA) Floodplain Habitat Assessment and Mitigation, Regional Guidance for the Puget Sound Basin. FEMA Region 10, August Granger, T., T. Hruby, A. McMillan, D. Peters, J. Rubey, D. Sheldon, S. Stanley, and E. Stockdale Wetlands in Washington State Volume 2: Guidance for Protecting and Managing Wetlands. Washington State Department of Ecology. Publication # , April 2005, Olympia, WA. Haddad, N., D Rosenberg, and B. Noon On Experimentation and the Study of Corridors: Response to Beier and Noss. Conservation Biology, Vol. 14, No. 5, pp , October Paper submitted December 22, 1999; revised manuscript accepted April 18, Herrera Environmental Consultants, Inc City of Bellevue Critical Areas Update, 2005 Best Available Science (BAS) Review. Prepared for City of Bellevue, March 23, Hinman, C Low Impact Development, Technical Guidance Manual for Puget Sound. Washington State University and Puget Sound Partnership. Publication # PSP , December Hruby, T Update on Wetland Buffers: The State of the Science, Final Report. Washington State Department of Ecology. Publication # , October Kitsap County Critical Areas Ordinance Update Best Available Science Review, Kitsap County Code, Title 19 (Critical Areas Ordinance), Chapter (Wetlands). Kitsap County Department of Community Development, Draft February 22, Kitsap County Supplemental Best Available Science Review and Required Changes 2016 Critical Areas Ordinance Update. Kitsap County, December 15, Lowell, N Abstract: Evaluating Agency Use of Best Available Science Under the Endangered Species Act Rosenberg, D., B. Noon, and E. Meslow Biological Corridors: Form, Function, and Efficacy. BioScience, Vol. 47. No 10, pp , November 1997.

6 Shannon & Wilson Wetland Review and Evaluation Report for the 2015 Seattle Environmentally Critical Areas Update. Prepared for City of Seattle, December 31, Sheldon, D., T. Hruby, P. Johnson, K. Harper, A. McMillan, T. Granger, S. Stanley, and E. Stockdale. Wetlands in Washington State Volume 1: A Synthesis of the Science. Washington State Department of Ecology. Publication # , March 2005, Olympia, WA. Somerville, D.E Stream Assessment and Mitigation Protocols: A Review of Commonalities and Differences, May 4, 2010, Prepared for the U.S. Environmental Protection Agency, Office of Wetlands, Oceans, and Watersheds (Contract No. GS-00F- 0032M). Washington, D.C. Document No. EPA 843-S Snohomish County Revised Draft Summary of Best Available Science for Critical Areas. Snohomish County Planning and Development Services, March 2006, Everett, WA. Towne, S Critical Areas Ordinance Update, Vancouver City Council Workshop, Presentation Notes. Prepared for City of Vancouver, Washington, August 22, Washington State Department of Ecology, U.S. Army Corps of Engineers Seattle District, and U.S. Environmental Protection Agency Region 10. March 2006a. Wetland Mitigation in Washington State Part 1: Agency Policies and Guidance (Version 1). Washington State Department of Ecology Publication # a. Olympia, WA. Washington State Department of Ecology, U.S. Army Corps of Engineers Seattle District, and U.S. Environmental Protection Agency Region 10. March 2006 b). Wetland Mitigation in Washington State Part 2: Developing Mitigation Plans (Version 1). Washington State Department of Ecology Publication # b. Olympia, WA. The Watershed Company. 2016a. City of Kirkland Critical Areas Regulations Technical Report, Part A- Review of Existing Conditions and Best Available Science. Prepared for City of Kirkland, January The Watershed Company. 2016b. City of Kirkland Critical Areas Regulations Technical Report, Part A- Review of Existing Conditions and Best Available Science and Part B-Gap Analysis. Prepared for City of Kirkland, January The Watershed Company. 2016c. Cowlitz County Critical Areas, Review of Existing Conditions and Best Available Science. Prepared with Parametrix for City of Cowlitz County, March The Watershed Company. 2016d. City of Bellevue Critical Areas Regulations Technical Report, Part 1- Update to Best Available Science and Existing Conditions. Prepared with Golder Associates for City of Bellevue Development Services Department, August The Watershed Company City of Bremerton Critical Areas Ordinance: Gap Analysis. Technical Memorandum from T. Brandon, S. Sandstrom, S. Stanley, and D. Nickel (The Watershed Company) to A. Satter (City of Bremerton), July 14, 2015.

7 The Watershed Company Final, Best Available Science Report, Use of Best Available Science in Skagit County Critical Areas Ordinance (Wetlands and Fish & Wildlife Habitat Conservation Areas). Prepared for Skagit County Department of Planning and Community Development, January 25, Whatcom County. 2016a. Whatcom County Critical Areas Ordinance 2016, Proposed Findings of Fact (as adopted by the Planning Commission). Draft Whatcom County. 2016b. Whatcom County Critical Areas Ordinance 2016 Update Best Available Science Review: Addendum for the 2005 BAS Report. Whatcom County Planning and Development Services, February 9, Whatcom County. 2016c. WWC Critical Areas Regulations, Edits and Notes. Whatcom County Planning and Development Services, Draft June 9, 2016.

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