A.H. Rossford Holdings, LLC 8079 Wales Road Northwood, Ohio 43619

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1 OHIO ENVIRONMENTAL PROTECTION AGENCY OHIO ISOLATED WETLAND PERMIT, LEVEL 2 REVIEW PROJECT RED WOOD COUNTY, OHIO March 7, 217 Prepared for: A.H. Rossford Holdings, LLC 879 Wales Road Northwood, Ohio Prepared by: 219 S. Erie Street Toledo, Ohio 4364

2 TABLE OF CONTENTS PAGE Cover Letter LIST OF APPENDICES Appendix A Appendix B Appendix C Appendix D Appendix E Appendix F Appendix G Level 1 and Level 2 Isolated Wetland Permit Application Forms. Isolated Wetland Determination Wetland Delineation Report ORAM Data Sheets Figures Mitigation Bank Credit Reservation ODNR Endangered Species Review HULL & ASSOCIATES, INC. FEBRUARY 217 TOLEDO, OHIO AHR1.1.3

3 March 8, 217 Ms. Heather Allamon Ohio EPA NWDO 41/Isolated Wetlands Section 347 N. Dunbridge Road Bowling Green, OH 4342 RE: Application for an Ohio Isolated Wetland Permit, Level 2 Review, for Project RED, Wales Road, Rossford, Wood County, Ohio (Site); AHR1.1.3 Ms. Allamon: Hull & Associates, Inc. (Hull), acting on behalf of A.H. Rossford Holdings, LLC, is submitting this application for an Ohio Isolated Wetland Permit, Level 2 Review. The project will result in a new commercial development near the existing Hollywood Casino to serve northwest Ohio, including a hotel, shopping, and entertainment features. This proposed project is necessary to help provide lodging and entertainment to the existing Hollywood Casino, located less than a quarter-mile from the Site. The proposed project will result in economic benefits to the City of Rossford, including short-term and long-term jobs and tourism revenue. In this submittal, Ohio EPA is being provided with eleven items required by the Ohio Isolated Wetlands application completeness checklist, as described below: 1. Complete Level 1 and Level 2 Isolated Wetland Permit Application Forms. These complete forms are attached as Attachment A. 2. A copy of the United States Army Corps of Engineers (USACE) jurisdictional determination letter. The USACE issued a Jurisdictional Determination (JD) for the wetlands on the Site on April 18, 216. The three wetlands on the site were determined to be isolated. The JD letter is attached as Attachment B. 3. An acceptable wetland delineation performed in accordance with the most recent USACE wetland delineation manual. A wetland delineation report was prepared by Hull & Associates, Inc. dated June 215, and a delineation report addendum was issued on February 1, 216. The USACE has determined that all wetlands on the Site have been delineated accurately. The delineation report and addendum are attached as Attachment C. 4. A completed Ohio Rapid Assessment Method (ORAM) wetland characterization form for each isolated wetland on the project site, including: Background Information, Scoring Boundary Worksheet, and Narrative Rating. A completed 1-page ORAM form for the isolated wetlands on the Site is attached as Attachment D. Also included with the ORAM is a response from the Ohio Department of Natural Resources to a request for Ohio Biodiversity Inventory data on the Site. 5. A detailed description of the project. A detailed description of the project is included in the General Isolated Wetland Permit Application (Level 1 Review), attached as Attachment A. 6. A description of the acreage of isolated wetland that will be subject to filling (including a map showing the project footprint and wetlands). 219 South Erie Street, Toledo, Ohio

4 Ms. Heather Allamon AHR1.1.3 March 8, 217 Page 2 Figures showing the proposed area of isolated wetland impact under the various Practicable On- Site Alternatives are attached as Attachment E. 7. Photographs of each isolated wetland with a photograph location map. Photographs are included in the Hull surface water delineation report, attached as Attachment C. 8. An acceptable mitigation proposal in accordance with ORC Sections (D) and , including the location and proposed legal mechanism for protecting the property in perpetuity. If the mitigation is to occur at a mitigation bank, also submit a demonstration that the appropriate type and amount of credits have been reserved. Attachment F is proof of A.H. Rossford Holdings, LLC s reservation of mitigation bank credit with the North Coast Regional Council of Park Districts. 9. Applicable permit fees. Applicable permit fees are attached. 1. An analysis of practicable on-site and off-site alternatives to the proposed filling that would have less adverse impact on the isolated wetland ecosystem. This analysis is included in the Individual Isolated Wetland Permit Application (Level 2 Review) attached as Attachment A. 11. Information indicating whether high quality waters are to be avoided by the proposed filling. This information is included in the Individual Isolated Wetland Permit Application (Level 2 Review) attached as Attachment A. Please advise on the completeness of this permit application at your earliest convenience. I may be reached for questions or requests for more information by phone or . Sincerely, Kristin Gardner Project Scientist Hugh F. Crowell, MS, PWS Ecology & Wetlands Practice Leader Enclosures ct: Armin Hunger, A.H. Rossford Holdings, LLC Bernd Hunger, A.H. Rossford Holdings, LLC

5 APPENDIX A Level 1 and Level 2 Isolated Wetland Permit Application Forms HULL & ASSOCIATES, INC. FEBRUARY 217 TOLEDO, OHIO AHR1.1.3

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10 Additional Sheet Attachment to Ohio Isolated Wetland Level 2 Permit Application Project RED (Rossford Entertainment District) Exhibit 1: Block 1 (continued) PROJECT RED DEVELOPMENT: OVERVIEW AND ALTERNATIVES ANALYSIS The concept of Project RED is to contribute to the creation of a healthy and attractive environment for business growth in northwest Ohio. Project RED will meet the demand for new commercial development with a hotel, shopping, and entertainment features less than a quarter-mile from the existing Hollywood Casino. Along with development of Project RED comes the creation of hundreds of high-quality full and part-time employment opportunities in northwest Ohio. Several hundred construction jobs will be supported during the development phase of Project RED. More than 35 permanent, living-wage jobs and over 1 part-time jobs will invigorate the local economy. The estimated annual payroll is expected to approach $12 million. The City of Rossford will facilitate the development of infrastructure necessary to service the property. Infrastructure will include public roadways, water and sanitary sewer services, natural gas, fiber optics, telephone, and cable television service. The Ohio Department of Transportation (ODOT) will begin construction on a public roadway through the site in July 217. ANALYSIS OF PRACTICABLE ON-SITE ALTERNATIVES Given the need to avoid and minimize impacts to isolated wetlands on the Site to the extent practicable, the Applicant has developed a series of practicable on-site and off-site alternatives for the proposed development. All of the Alternatives described below are capable of being constructed and would fulfill the basic project purpose. In this alternatives analysis, the applicant demonstrates its efforts to avoid and minimize impacts to the isolated wetland ecosystem. Alternative 1 (Preferred) Development of the Entire Site (Appendix E, Figure 2) Isolated wetland impact = 2.62 acres. Impacts to wetlands are from filling and grading to prepare the site for construction, and for construction of a hotel, shopping strip mall, parking garage, gondola, and amphitheater. There is no practicable opportunity for avoidance, maintenance and on-site preservation of any small, isolated wetland fragments. Development will allow for the all needs to be met (lodging, shopping, recreation). Development will create needed economic opportunities in the area and create more than 35 permanent employment opportunities. Efficient use of the entire property is necessary for the area to receive a local economic benefit. A minimum number of roadways with minimal curves will keep design and engineering costs as low as possible for the development. These savings will be passed on to potential tenants and customers. Development utilizes a planned ODOT road that is scheduled to begin construction through the Site in July 217. Alternative 2 Minimal Degradation On-Site Alternative (Appendix E, Figure 3) Isolated Wetland Impact =.88 acres. Impacts to wetlands are from filling and grading to prepare the site for construction. Avoided isolated wetlands would be preserved on site within a conservation easement, although perpetual hydrologic maintenance of these small, low-quality isolated wetlands and wetland fragments would be difficult. Isolated Wetland JB would largely be avoided and preserved on site. Ongoing maintenance of hydrology in the avoided wetland area would be difficult. Hydrology from surface runoff would likely be altered by installation of storm water drainage for buildings and pavement, leading to indirect loss of the isolated wetlands. Lot sizes would be decreased and the layout would be altered to accommodate 1.74 acres of preserved wetland and associated upland buffer at the southern end of the site.

11 Restrictions on lot sizes and shapes would limit the types of businesses or number of tenants. Largely avoiding Wetland JB would cause a potential loss of up to 1 useable acres, and at a cost of $45, per acre would cost the development $45,. That expenditure would result in loss of employment opportunities and potential failure of the project. Alternative 3 Non-Degradation On-Site Alternative (Appendix E, Figure 4) No impact to isolated wetlands. Upland areas would buffer isolated wetlands. Restrictions on lot sizes and shapes would limit the types of businesses and number of tenants. Ongoing maintenance of hydrology in the avoided wetland areas would be difficult. Hydrology from surface runoff is likely to be altered by installation of efficient storm water drainage for buildings and pavement leading to indirect loss of the isolated wetlands. Complete avoidance of Wetlands JA, JB, and JC would cause a potential loss of up to 1 useable acres, and at a cost of $45, per acre would cost the development $45,. That expenditure would result in loss of employment opportunities and potential failure of the project. Alternative 4 Off-Site Alternative A 19-acre parcel, located near the proposed project site, was identified in the MLS. The parcel is not owned by the Applicant, making further consideration as an alternative difficult. The parcel currently has one point of access and will not be located along the ODOT roadway scheduled to begin construction in July 217. To our knowledge, potential surface waters on this site have not been delineated. Therefore, it is unknown whether development would impact isolated or non-isolated wetlands. This property is currently zoned for heavy manufacturing and would need to be re-zoned for commercial use through the City of Rossford Planning Commission. Analysis and Conclusion Although all of the alternatives presented could be constructed and each would fulfill the basic purpose of the project (to create hotel, retail, and entertainment jobs in the communities of Rossford and Northwood), only the Preferred Alternative meets all of the project goals in a cost-efficient manner. The available on-site alternatives would restrict the lot sizes and configurations that would make the most efficient use of the site for a hotel, parking, retail, and entertainment facilities. An off-site alternative is not under the Applicant s ownership and lacks the access needed for the proposed project.

12 Alternatives Comparison Matrix for Practicability Practicability Alternative 1 Alternative 2 (Minimal Alternative 3 (No Alternative 4 (Off-site Factor Category (Preferred) Degradation; On-site) Degradation; On-site) Alternative) Availability Available for YES YES YES YES acquisition Applicant owns parcel Applicant owns parcel Applicant owns parcel Listed in MLS Logistics Sufficient parcel size YES YES YES YES 17 acres 17 acres 17 acres 19 acres Logistics Appropriate existing NO YES YES YES zoning Heavy Industrial Logistics Availability of utilities YES YES YES YES Adjacent to parcel Adjacent to parcel Adjacent to parcel Utilities on site Logistics Accessibility YES YES YES NO ODOT road (217) ODOT road (217) ODOT road (217) One point of access Existing Site conditions feasible technology for construction YES YES YES YES Cost Reasonable acquisition YES YES YES YES cost Applicant owns parcel Applicant owns parcel Applicant owns parcel Within market costs Cost Local economic benefit YES Acceptable employment and revenue NO Insufficient employment and revenue NO Insufficient employment and revenue YES Acceptable employment and revenue Practicable? YES NO NO NO Practicable Alternatives Comparison Matrix for Environmental Factors Environmental Factor Alternative 1 Wetland Impacts (acres) 2.62 Stream Impacts (linear feet) Open Water Impacts (acres) Floodplain Impacts (acres) Least Environmentally Damaging Practicable Alternative? YES

13 APPENDIX B Isolated Wetland Determination HULL & ASSOCIATES, INC. FEBRUARY 217 TOLEDO, OHIO AHR1.1.3

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16 APPENDIX C Wetland Delineation Report HULL & ASSOCIATES, INC. FEBRUARY 217 TOLEDO, OHIO AHR1.1.3

17 SURFACE WATER DELINEATION REPORT FOR THE: INDUSTRIAL DEVELOPERS LTD. WALES ROAD DEVELOPMENT WOOD COUNTY, OHIO PREPARED FOR: INDUSTRIAL DEVELOPERS LTD. 675 WALES ROAD, SUITE 1 NORTHWOOD, OHIO PREPARED BY: HULL & ASSOCIATES, INC. 341 GLENDALE AVE, SUITE 3 TOLEDO, OHIO JUNE 215

18 TABLE OF CONTENTS PAGE 1. SUMMARY INTRODUCTION DELINEATION CRITERIA INVESTIGATION METHODS General Wetland Delineation Methods Hydrology, Precipitation, and Hydrologic Indicators at the Site Wetland Evaluation Methods Stream Delineation Methods Stream Evaluation Methods Surveying and Mapping Methods DELINEATION RESULTS Wetlands Wetland JA Wetland JB Wetland JC Streams Upland Plant Communities REPORT LIMITATIONS REFERENCES LIST OF TABLES Table 1 Wales Road Development Wetland Summary Table LIST OF FIGURES Figure 1 Figure 2 Figure 3 Site Location Map Mapped NWI Wetlands and Soils Index Surface Water Delineation Map LIST OF APPENDICES Appendix A Appendix B Appendix C Photographs Wetland Delineation Data Sheets ORAM Wetland Data Sheets HULL & ASSOCIATES, INC. i JUNE 215 TOLEDO, OHIO IDL2.1.2

19 1. SUMMARY Hull & Associates, Inc. (Hull) conducted a surface water delineation on an approximately 17-acre area located on Wales Road in Northwood, Wood County, Ohio (Site; see Figure 1) on May 28, 215. Hull identified three (3) wetlands within the proposed project area. All of the wetlands were isolated depressional wetlands that were dominated by emergent (non-woody) vegetation. All three of the wetlands were classified as Ohio Category 1. Wetland quality evaluations were performed using the Ohio Rapid Assessment Method for Wetlands Version 5. (ORAM), a multi-metric, semi-quantitative wetland assessment method developed by the Ohio Environmental Protection Agency (Ohio EPA). Photographs of the study area resources are located in Appendix A. Delineation data sheets for Wetlands JA, JB, and JC are located in Appendix B. ORAM data sheets for Wetlands JA, JB, and JC are located in Appendix C. HULL & ASSOCIATES, INC. 1 JUNE 215 TOLEDO, OHIO IDL2.1.2

20 2. INTRODUCTION Hull & Associates, Inc. (Hull) conducted a surface water delineation on an approximately 17-acre area located on Wales Road in Northwood, Wood County, Ohio on May 28, 215. The purpose of the delineation was to determine the extent and quality of wetlands and other surface waters in the project area that may be subject to regulation under Section 1 of the Rivers and Harbors Act, Sections 44 and 41 of the Clean Water Act (CWA 1987, as amended), and/or the Ohio Isolated Wetland Permit Program. This report contains a description of an investigation conducted to delineate wetlands and streams and to assess the value of surface waters found on the project site. The report includes: a summary of findings, a description of wetland and stream delineation criteria, a summary of resource materials used to plan and conduct field activities, and descriptions of the wetlands, streams, and ecological habitat types identified within the proposed project area. A surface water delineation report is a necessary component of determining whether an entity must submit notification or permit applications to the USACE and/or the Ohio EPA for planned project activities. The USACE issues CWA Section 44 permits, which are required for anyone who plans to discharge dredged or fill material into waters of the U.S., including non-isolated wetlands. The Ohio EPA issues CWA Section 41 water quality certifications, which must be obtained before a Section 1 or 44 permit can be granted, and verifies wetland and stream evaluations. The Ohio EPA is also responsible for administering the Ohio Isolated Wetland permitting program. Wetlands not connected to or directly abutting or adjacent to other surface waters are considered isolated waters of the State and are therefore regulated solely by the Ohio EPA. HULL & ASSOCIATES, INC. 2 JUNE 215 TOLEDO, OHIO IDL2.1.2

21 3. DELINEATION CRITERIA Federal regulations define a jurisdictional wetland as an area that is inundated or saturated by surface or ground water at a frequency and duration sufficient to support, and that under normal circumstances does support, a prevalence of vegetation typically adapted for life in saturated soil conditions. According to USACE-established wetland criteria, a wetland has: (1) hydric (i.e., wetland) soils, (2) evidence of inundated or saturated conditions (wetland hydrology), and (3) a predominance of wetland (hydrophytic) vegetation. When all three of these criteria are met, a wetland is present and is subject to Federal and/or State regulations and permitting. During wetland delineation activities, data are collected concerning the vegetation, soils, and hydrology present in various plant communities to determine if the criteria for a jurisdictional wetland are met and the wetland/non-wetland boundaries are then flagged. Hydric soils are those soils that have formed under conditions of saturation, flooding, or ponding long enough during the growing season to develop anaerobic conditions in the upper part. The presence or absence of hydric soils is determined in the field by digging a soil pit, characterizing the soil profile, and applying the criteria for hydric soils contained in Field Indicators of Hydric Soils in the United States, Version 7. (21). The presence of wetland hydrology is determined using field indicators including directly observable evidence such as inundation and soil saturation, and evidence of recent inundation such as water marks on trees and sediment or drift deposits. Evidence of current or recent soil saturation may also be present, such as the presence of reduced iron or crayfish burrows. Plants are placed into indicator status categories depending on their probability of occurring in a wetland. There are five indicator status categories for plants: 1. Obligate wetland plants (OBL): plants that occur almost always (>99%) in wetlands in natural conditions, but which may also occur rarely (<1%) in non-wetlands; 2. Facultative wetland plants (FACW): plants that occur usually (>67-99%) in wetlands but also occur (1-33%) in non-wetlands; 3. Facultative plants (FAC): plants with a similar likelihood (33-67%) of occurring in both wetlands and non-wetlands; 4. Facultative upland plants (FACU): plants that occur sometimes (1-<33%) in wetlands, but occur more often (>67-99%) in non-wetlands; and HULL & ASSOCIATES, INC. 3 JUNE 215 TOLEDO, OHIO IDL2.1.2

22 5. Obligate upland plants (UPL): plants that occur rarely (<1%) in wetlands, but occur almost always (>99%) in non-wetlands under natural conditions. These categories were originally developed and defined by the USFWS National Wetlands Inventory (NWI) and subsequently modified by the National Plant List Panel. Once delineated using the three-criterion approach, the wetland/non-wetland boundaries and the sample locations are surveyed and placed on a site map. From the wetland map, the acreage of each wetland can be calculated. A preliminary determination is also made as to whether each wetland is isolated and thus under the jurisdiction of the State of Ohio Isolated Wetland Permit Program, or non-isolated, and thus under federal Clean Water Act jurisdiction. In stream delineation, the location and length of streams is determined from existing mapping information and/or via surveying streams in the field. Note that some streams too small to be included on U.S. Geological Survey (USGS) topographic maps may nevertheless be under CWA jurisdiction. Jurisdictional streams generally have a defined channel, an Ordinary High Water Mark (OHWM), show evidence of flow with discernible bed and bank features, and may have other morphological features typical of streams including riffles and pools, meanders, and a floodplain. The USACE has sole authority to verify delineations of surface waters and to determine whether wetlands or other water bodies are isolated or non-isolated. Verification occurs after review of a delineation report and a field visit by USACE staff. Delineations are typically valid for a period of five years from the date of the USACE delineation verification letter. HULL & ASSOCIATES, INC. 4 JUNE 215 TOLEDO, OHIO IDL2.1.2

23 4. INVESTIGATION METHODS 4.1 General Prior to visiting the project site, Hull compiled the following existing information about the area: Natural Resources Conservation Service (NRCS) Soil Survey of Wood County, Ohio The soil survey identifies soil mapping units within the site, including hydric soil mapping units, non-hydric soil mapping units that may contain inclusions of hydric soil units, and non-hydric soil mapping units (Figure 2). Non-hydric soil mapping units that may contain inclusions of hydric soil units may occur on terraces, in depressions, on floodplains, and in drainage ways. County Listings of Hydric Soils and Non-hydric Soils with Hydric Inclusions A Hydric or non-hydric status for each soil unit was determined using the Natural Resources Conservation Service Web Soil Survey 2.. United States Department of Interior National Wetlands Inventory (NWI) Maps These data provide an indication of the presence of wetland and open-water areas within the study area, as defined by the U.S. Fish and Wildlife Service (USFWS) classification system (Cowardin et al., 1979). The notation of a wetland on a NWI Map indicates that wetlands may occur or have occurred in the area. Often, those wetlands depicted on NWI maps are the wettest spots in a given area. NWI map information is used to supplement knowledge about a site and cannot take the place of field observations due to minimal ground truthing, map age, map scale, and wetland criteria that differ from USACE wetlands criteria. See Figure 2 for NWI mapped areas located within the study area. Hull used this preliminary information to perform screening of the project area to plan and focus on site investigations. All areas of the site were examined using confirmatory soil sampling and wetland data collection. 4.2 Wetland Delineation Methods Hull located wetland edges in the field using procedures outlined in the 1987 USACE wetlands delineation manual (Environmental Laboratory, 1987), the 212 Regional Supplement to the delineation Manual for the Northcentral and Northeast Region Version 2., subsequent USACE memoranda and regulatory guidance, and basic principles of plant community ecology. Plant communities on the site were characterized using the three-criterion wetland delineation approach. The wetland indicator status of plant species was determined using the National Wetland Plant List (Lichvar, et al. 214). After characterizing the vegetation, hydrology and soils of a plant community type, and becoming familiar with the soil, vegetation, and/or hydrologic cues that indicate wetland edge, Hull flagged the wetland edges with periodic collection of additional soil, vegetation or hydrologic data to refine the edge. Wetland delineation data sheets are located in Appendix B. HULL & ASSOCIATES, INC. 5 JUNE 215 TOLEDO, OHIO IDL2.1.2

24 4.3 Hydrology, Precipitation, and Hydrologic Indicators at the Site The hydrology of the delineated wetlands is driven mainly by precipitation. Field indicators of hydrology noted for the delineated wetlands primarily included surface water (primary hydrologic indicator A1), high water table (primary hydrologic indicator A2), soil saturation (primary hydrologic indicator A3), waterstained leaves (primary indicator B9), oxidized rhizospheres on living roots (primary indicator C3), visible saturation on aerial imagery (secondary indicator C9), geomorphic position (secondary hydrologic indicator D2) and a positive FAC-neutral test (secondary hydrologic indicator D5). 4.4 Wetland Evaluation Methods Hull performed an evaluation of wetlands using the Ohio Rapid Assessment Method for Wetlands (Mack, 21), Final Version 5. (ORAM). The ORAM value assessment is based on review of resource materials, data obtained in the field, and the acreage as determined by delineation and mapping. The wetland value information is provided to the Ohio EPA for the purpose of placing wetlands into the appropriate wetland Antidegradation Category described in Ohio s Wetland Water Quality Standards (Sections and Sections through ). The ORAM wetland value information is included in Appendix C. There are three possible Ohio Wetland Antidegradation Categories to which wetlands may be assigned: Category 1 Lowest value category. Generally limited to small, low-diversity wetlands and wetlands with a predominance of non-native invasive species. Category 2 Middle value category. Wetlands in this category are of moderate diversity but do not contain rare, threatened, or endangered species. They are generally degraded, but are capable of attaining higher value. Most wetlands in Ohio are expected to fall into this category. Category 3 Highest value category. Wetlands in this category may be large, diverse, represent rare plant community types, contain rare, threatened or endangered species, or any combination of these and several other factors. 4.5 Stream Delineation Methods Streams identified on US Geological Survey (USGS) topographic maps are generally found to be under the Clean Water Act jurisdiction of the USACE. Additional streams may be identified in the field by the presence of a defined bed and bank and other stream morphological features. Suspected stream channels are examined upstream to identify the source of water and downstream to determine if the channel ends in a wetland, a confluence with another stream, a culvert inlet, or other feature. 4.6 Stream Evaluation Methods Hull utilizes the Ohio Qualitative Habitat Evaluation Index (QHEI) scoring method to evaluate streams with a drainage area greater than one square-mile and/or pools greater than 4 centimeters deep. On streams HULL & ASSOCIATES, INC. 6 JUNE 215 TOLEDO, OHIO IDL2.1.2

25 with a drainage area less than one square-mile and with pools less than or equal to 4 centimeters deep, Hull uses the Ohio Headwater Habitat Evaluation Index (HHEI). These methods yield a numerical score for the stream reach evaluated, which is then used to estimate the provisional or probable existing aquatic life use of each stream. When biotic evaluation of streams is necessary, Hull uses appropriate qualitative methods or quantitative methods including the Index of Biotic Integrity (IBI) and Invertebrate Community Index (ICI) for larger streams, and classifies perennial headwater streams as either having or lacking potential coldwater-equivalent performance. Larger streams have sufficient amounts of water throughout the year to support fish communities and smaller streams can support a diverse community of invertebrates, salamanders, and can also support fish. Scores from the QHEI are used to assign each stream to one or more of the following aquatic life use designations, as defined by Ohio Water Quality Standards Water Use Designations (OAC ): Warmwater Habitat (WWH) Capable of supporting and maintaining a balanced community of warmwater aquatic organisms. This is the most widely applied use designation assigned to rivers and streams in Ohio. Limited Warmwater Habitat (LWWH) Temporary aquatic life habitat use designation created in the 1978 Ohio Water Quality Standards for streams not meeting specific warmwater habitat criteria. This aquatic life use designation is being phased out. Exceptional Warmwater Habitat (EWH) Capable of supporting and maintaining an exceptional or unusual community of warmwater aquatic organisms with the general characteristics of being highly intolerant of adverse water quality conditions and/or being rare, threatened, endangered, or of special status. Modified Warmwater Habitat (MWH) Incapable of supporting and maintaining a balanced community of warmwater aquatic organisms because of extensive and irretrievable modifications to the physical habitat. Seasonal Salmonid Habitat (SSH) Capable of supporting the passage of salmonids from October to May, and large enough to support recreational fishing. Coldwater Habitat (CWH) Capable of supporting populations of coldwater aquatic organisms on an annual basis and/or put-and-take salmonid fishing. These water bodies are not necessarily capable of supporting the successful reproduction of salmonids and may be periodically stocked. Limited Resource Water (LRW) Incapable of supporting and maintaining a balanced community of aquatic organisms because of natural background conditions or irretrievable human-induced conditions. 4.7 Surveying and Mapping Methods The boundaries of all wetland areas and sample points were captured in the field using Trimble GeoXT mapping-level portable Global Positioning System (GPS) receivers. Differentially corrected GPS data were HULL & ASSOCIATES, INC. 7 JUNE 215 TOLEDO, OHIO IDL2.1.2

26 determined to be accurate within.5 feet to 1. foot. The wetland areas and sample points were placed in a GIS database and assembled with other available geographically referenced information using ARC- GIS v.9. software. HULL & ASSOCIATES, INC. 8 JUNE 215 TOLEDO, OHIO IDL2.1.2

27 5. DELINEATION RESULTS 5.1 Wetlands Hull s team of Ecologists and certified Professional Wetland Scientists identified three (3) wetlands in the project area (Table 1; Figure 3). Details for each of the individual wetlands below are provided in Table Wetland JA Wetland JA is a.74-acre isolated depressional wetland dominated by a community of emergent wetland plants. The herb stratum is dominated by Phragmites australis (FACW) and Lolium perenne (FACU). The sapling and shrub layer is dominated by green ash (Fraxinus pennsylvanica; FACW). Wetland JA is located in an area mapped as loamy Udorthents (UcA) with -1 percent slopes. The soils of this wetland have a depleted matrix (F3). Hydrology for the wetland is provided by direct precipitation. Two primary hydrologic indicators (water-stained leaves (B9), and oxidized rhizospheres on living roots (C3)) and two secondary hydrologic indicators (visible saturation on aerial imagery (C9) and positive FAC-neutral test (D5)) were identified for this wetland. Based on the ORAM narrative criteria, Wetland JA is likely an automatic Category 1 wetland. The wetland is less than 1 acre in size, is hydrologically isolated, and has 8% aerial cover of Phragmites australis. Based on a quantitative rating, Wetland JA is an Ohio Category 1 wetland with an ORAM score of 18. The score is negatively influenced by its extensive coverage of invasive plants (Phragmites australis) Wetland JB Wetland JB is located at the southern end of the site and continues south beyond the survey area. Within the survey area is a 1.82-acre isolated emergent wetland that is dominated by Phragmites australis (FACW) and Typha angustifolia (OBL). Wetland JB is located in an area mapped as loamy Udorthents (UcA) with - 1 percent slopes. The soils of this wetland have a depleted matrix (F3). One primary indicator of wetland hydrology (surface water (A1)) and two secondary indicators (visible saturation on aerial imagery (C9) and positive FAC-neutral test (D5)) were identified. Hydrology for the wetland is provided by direct precipitation. Wetland JB is an Ohio Category 1 wetland with an ORAM score of 2. The ORAM score is negatively influenced by extensive cover of invasive plants. HULL & ASSOCIATES, INC. 9 JUNE 215 TOLEDO, OHIO IDL2.1.2

28 5.1.3 Wetland JC Wetland JC is a.6-acre isolated emergent wetland located west of Wetland JA. Wetland JC is dominated by Typha angustifolia (OBL), Lolium perenne (FACU), and Cornus alba (FACW). Wetland JC is located in an area mapped as loamy Udorthents (UcA) with a 2 percent slope. The soils and hydrology of this wetland have been significantly disturbed during filling and grading activities at the site. None of the hydric soil indicators, and only one secondary indicator of wetland hydrology (positive FAC-neutral test), were identified at this location. However, the dominant presence of Typha angustifolia an obligate wetland plant indicates the presence of a wetland. Hydrology for the wetland is provided by direct precipitation. Wetland JC is an Ohio Category 1 wetland with an ORAM score of Streams Hull s team did not identify any streams in the project area. 5.3 Upland Plant Communities Hull s ecologists also characterized a representative upland plant community in the project area. The upland community around Wetlands JA, JB, and JC was dominated by herbaceous vegetation consisting primarily of Lolium perenne (FACU) and Asclepias syriaca (UPL). The upland area did not have features characteristic of wetland hydrology or soils. The data sheet for upland documentation plot can be found in the back of Appendix B, behind the Wetland Delineation data sheets. HULL & ASSOCIATES, INC. 1 JUNE 215 TOLEDO, OHIO IDL2.1.2

29 6. REPORT LIMITATIONS The conclusions presented herein are based on the level of effort and investigative techniques defined under the Scope of Work between Hull and the Client. Hull & Associates, Inc. has conducted this investigation in a manner consistent with published guidance, sound ecological practices, and best professional judgment. No other warranty or guarantee, expressed or implied, is made. This report does not attempt to evaluate past or present compliance with Federal, State and Local environmental or land use laws and regulations. Furthermore, Hull & Associates, Inc. makes no guarantees regarding the completeness or accuracy of any information obtained in review of public or private files or previous investigations at the Site not conducted by Hull & Associates, Inc. The results of the surface water delineation and the surface water evaluation are subject to verification by the USACE and Ohio EPA, respectively. HULL & ASSOCIATES, INC. 11 JUNE 215 TOLEDO, OHIO IDL2.1.2

30 7. REFERENCES Cowardin, L.M., V. Carter, F.C. Golet and E.T. LaRoe, Classification of Wetlands and Deepwater Habitats of the United States, US Department of the Interior, Fish and Wildlife Service, BSP, Washington DC, 13p. Environmental Laboratory, Corps of Engineers Wetlands Delineation Manual, Technical Report Y-87-1, US Army Engineer Waterways Experiment Station, Vicksburg Miss. Environmental Laboratory, April 212. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Eastern Mountains and Piedmont Region (Version 2.), Technical Report 9-19, U.S. Army Engineer Research and Development Center, Vicksburg, MS. Environmental Laboratory, January 212. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Northcentral and Northeast Region (Version 2.), U.S. Army Engineer Research and Development Center, Vicksburg, MS. Lichvar Robert, W., M. Butterwick, N.C. Melvin, and W.N. Kirchner The National Wetland Plant List: 214 Update of Wetland Ratings. Phytoneuron. 41: Mack, John J. 21. Ohio Rapid Assessment Method for Wetlands v. 5., User s Manual and Scoring Forms. Ohio EPA Technical Report WET/21-1. Ohio Environmental Protection Agency, Division of Surface Water, 41/Wetland Ecology Unit, Columbus, Ohio. Ohio Environmental Protection Agency, Division of Surface Water, 212. Field Evaluation Manual for Ohio s Primary Headwater Habitat Streams (HHEI). Columbus, Ohio. Ohio Environmental Protection Agency, Division of Surface Water, 26. Methods for Assessing Habitat in Flowing Waters: Using the Qualitative Habitat Evaluation Index (QHEI). Columbus, Ohio. U.S. Army Corps of Engineers, Standard Operating Procedures for the Regulatory Program. U.S. Department of Agriculture, Natural Resources Conservation Service (NRCS) Web Soil Survey. U.S. Department of Agriculture, Natural Resource Conservation Services. 21. Field Indicators of Hydric Soils in the United States: A guide for Identifying and Delineating Hydric Soils, Version 7.. L.M. Vasilas, G.W. Hurt and C.V. Noble (eds.). USDA, NRCS, in cooperation with the national Technical Committee for Hydric Soils. U.S. Environmental Protection Agency and US Army Corps of Engineers. 28. Memo entitled: Clean Water Act Jurisdiction following the US Supreme Court s Decision in Rapanos v. United States and Carabell v. United States. December 28, 12 pp. U.S. Fish and Wildlife Service (USFWS). 22. National Wetlands Inventory. U.S. Fish and Wildlife Service, St. Petersburg, FL. U.S. Geological Survey (USGS) Topographical quadrangle maps (7.5-minute series). Rossford, Ohio quadrangle. U.S. Department of the Interior. Washington, D.C. HULL & ASSOCIATES, INC. 12 JUNE 215 TOLEDO, OHIO IDL2.1.2

31 TABLES HULL & ASSOCIATES, INC. JUNE 215 TOLEDO, OHIO IDL2.1.2

32 SURFACE WATER DELINEATION REPORT WALES ROAD DEVELOPMENT TABLE 1 WETLAND SUMMARY TABLE Wetland ID Latitude Coordinates Longitude Isolation Status 1 Cowardin Classification USGS 8-digit HUC ORAM Score Measured Category Size (Acres) Wetland JA Isolated Palustrine Emergent (PEM) Category 1.74 Wetland JB Isolated Palustrine Emergent (PEM) Category Wetland JC Isolated Palustrine Emergent (PEM) Category = Determined by Hull; Isolated = isolated from other relatively permanent waters of the U.S. USGS = United States Geological Survey HUC = Hydrologic Unit Code ORAM = Ohio Rapid Assessment Method for Wetlands HULL & ASSOCIATES, INC. TOLEDO, OHIO JUNE 215 IDL2.1.1.XLSX

33 FIGURES HULL & ASSOCIATES, INC. JUNE 215 TOLEDO, OHIO IDL2.1.2

34 215, Hull & Associates, Inc. Site Site Location Ohio DISCLAIMER Hull & Associates, Inc. (Hull) has furnished this map to the company identified in the title block (Client) for its sole and exclusive use as a preliminary planning and screening tool and field verification is necessary to confirm these data. This map is reproduced from geospatial information compiled from third-party sources which may change over time. Areas depicted by the map are approximate and may not be accurate to mapping, surveying or engineering standards. Hull makes no representation or guarantee as to the content, accuracy, timeliness or completeness of any information or spatial location depicted on this map. This map is provided without warranty of any kind, including but not limited to, the implied warranties of merchantability or fitness for a particular purpose. In no event will Hull, its owners, officers, employees or agents, be liable for damages of any kind arising out of the use of this map by Client or any other party. Industrial Developers Ltd. 5 1, 2, Date: 1:24, Feet Quad: Rossford Source: The topographic map was acquired through the USGS Topographic Map web service. The aerial photo in the inset was acquired through the ESRI Imagery web service. Aerial photography dated 214. June Glendale Ave Suite 3 Toledo, Ohio Phone: (419) Fax: (419) Site Location Map Wales Road Northwood, Wood County, Ohio File Name: IDL2_1_Fig1_SLM.mxd Edited: 5/29/215 By: mopel Figure 1 Produced using ArcGIS 1.2

35 215, Hull & Associates, Inc :2,4 Feet Ur UcA SuE2 UcE FzA FuA Notes: The aerial photo was acquired through the ESRI Imagery web service. Aerial photography dated 214. Produced using ArcGIS Glendale Ave Suite 3 Toledo, Ohio UcA Phone: (419) Fax: (419) DISCLAIMER Hull & Associates, Inc. (Hull) has furnished this map to the company identified in the title block (Client) for its sole and exclusive use as a preliminary planning and screening tool and field verification is necessary to confirm these data. This map is reproduced from geospatial information compiled from third-party sources which may change over time. Areas depicted by the map are approximate and may not be accurate to mapping, surveying or engineering TpA standards. Hull makes no representation or guarantee as to the content, accuracy, timeliness or completeness of any information or spatial location depicted on this map. This map is provided without warranty of any kind, including but not limited to, the implied warranties of merchantability or fitness for a particular purpose. In no event will Hull, its owners, officers, employees or agents, be liable for damages of any kind arising out of the use of this map by Client or any other party. SuC2 Property Boundary National Wetlands Inventory Non-Hydric Soils Non-Hydric w/ Hydric Inclusions Soils Hydric Soils FzA June 215 Industrial Developers Ltd. National Wetlands Inventory and Soils Map Wales Road Northwood, Wood County, Ohio File Name: IDL2_1_Fig2_SoilsNWI.mxd Figure 2 Edited: 5/29/215 By: mopel

36 215, Hull & Associates, Inc :2,4 Feet Wetland JC WET-JC WET-JA Wetland JA UPL-JB WET-JB Wetland JB Wetland Continues Property Boundary Wetland Wetland Data Point Upland Data Point Notes: The aerial photo was acquired through the ESRI Imagery web service. Aerial photography dated Glendale Ave Suite 3 Toledo, Ohio Phone: (419) Fax: (419) DISCLAIMER Hull & Associates, Inc. (Hull) has furnished this map to the company identified in the title block (Client) for its sole and exclusive use as a preliminary planning and screening tool and field verification is necessary to confirm these data. This map is reproduced from geospatial information compiled from third-party sources which may change over time. Areas depicted by the map are approximate and may not be accurate to mapping, surveying or engineering standards. Hull makes no representation or guarantee as to the content, accuracy, timeliness or completeness of any information or spatial location depicted on this map. This map is provided without warranty of any kind, including but not limited to, the implied warranties of merchantability or fitness for a particular purpose. In no event will Hull, its owners, officers, employees or agents, be liable for damages of any kind arising out of the use of this map by Client or any other party. June 215 Industrial Developers Ltd. Surface Water Delineation Wales Road Northwood, Wood County, Ohio Figure 3 Produced using ArcGIS 1.2 File Name: IDL2_1_Fig3_SWDelin.mxd Edited: 5/29/215 By: mopel

37 APPENDIX A Photographs HULL & ASSOCIATES, INC. JUNE 215 TOLEDO, OHIO IDL2.1.2

38 PHOTO 1: View of Wales Road survey area facing north PHOTO 2: View of Wetland JA (background) and Wetland JC (foreground) facing east Wales Road Development Date: Industrial Developers Ltd. June Glendale Avenue Suite #3 Toledo, Ohio , Hull & Associates, Inc. Phone: (419) Fax: (419) Site Photographs Wales Road Northwood, Wood County, Ohio Project Number:IDL2 File Name: IDL2.1.2.XLSX

39 PHOTO 3: View of Wetland JB facing south PHOTO 4: View of upland data point UPL-JA Wales Road Development Date: Industrial Developers Ltd. June Glendale Avenue Suite #3 Toledo, Ohio , Hull & Associates, Inc. Phone: (419) Fax: (419) Site Photographs Wales Road Northwood, Wood County, Ohio Project Number:IDL2 File Name: IDL2.1.2.XLSX

40 APPENDIX B Wetland Delineation Data Sheets HULL & ASSOCIATES, INC. JUNE 215 TOLEDO, OHIO IDL2.1.2

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53 APPENDIX C ORAM Wetland Data Sheets HULL & ASSOCIATES, INC. JUNE 215 TOLEDO, OHIO IDL2.1.2

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95 February 1, 216 Mr. Dallas Paul Industrial Development 675 Wales Road Northwood, Ohio RE: Addendum to the Surface Water Delineation Report for Wales Road Site, Northwood, Wood County, Ohio (Site); Hull Doc. No. IDL2.1.6 Mr. Paul: Hull & Associates, Inc. (Hull) and Industrial Development Ltd. met with the U.S Army Corps of Engineers (USACE) and Ohio EPA at the Site referenced above on August 4, 215 to review the findings of the Surface Water Delineation Report, which identified three (3) isolated wetlands on the Site. During the Site visit, the USACE asked whether there was a surface water connection (or significant nexus) to a navigable water, which would make Wetland JB federally jurisdictional. It appeared to the USACE that a railroad drainage ditch visible on the railroad property to the south might provide a surface water connection to a navigable water. Access could not be obtained to evaluate the railroad property south of the Site. Hull continued to coordinate the Jurisdictional Determination (JD) Request with the USACE in January and February 216, and the USACE requested additional information needed to demonstrate that Wetland JB is isolated. Wetland JB is located at the southern end of the Site. Wetland JB within the survey area is a 1.82-acre isolated emergent wetland that is dominated by Phragmites australis (FACW) and Typha angustifolia (OBL). Wetland JB continues off-site approximately 25 feet south of the survey area. Wetland JB is located in an area mapped as loamy Udorthents (UcA) with -1 percent slopes. The soils of this wetland have a depleted matrix (F3). One primary indicator of wetland hydrology (surface water, A1) and two secondary indicators (visible saturation on aerial imagery, C9) and positive FAC-neutral test, D5) were identified. Hydrology for the wetland is provided by direct precipitation. Wetland JB is an Ohio Category 1 wetland with an ORAM score of 2. On February 4, 216, Hull was able to access public areas northeast and southwest of the Site to investigate whether the manmade drainage swale had any surface water connection or significant nexus to navigable waters. Hull was able to view the northeastern and southwestern termini of the manmade drainage swale. Hull also reviewed historical and current aerial imagery for the Site and adjacent areas where we were unable to gain access. Hull identified a manmade drainage swale that runs parallel to the CSX railroad, located in between the Site and the railroad tracks (see updated Surface Water Delineation Figure 3, attached). It appears that Wetland JB extends slightly off-site and is connected to the manmade drainage swale, which runs northeast until it terminates west of Oregon Road, as shown in Photo 7 in Attachment A and Figure 1 in Attachment B. At the northeast terminus of the drainage swale, there is a water-filled borrow pit (visible on Photo 6) containing open water - this borrow pit also appears to be isolated due to surrounding road berms and development. The manmade swale terminates southwest of the Site at the access area for CSX near the intersection of Elm Street and Beech Street, as shown in Photo 8 in Attachment A. Hull did not identify any culvert or surface connection between the southwest terminus of the drainage swale and the nearest mapped surface water which is 395 to the southwest across a topographic rise. Also, Hull did not identify any railroad culverts connecting the northern and southern edges of the railroad bed. Hull also determined that the drainage swale is not located within a mapped floodplain nor does it connect to a floodplain. Based on USACE guidance in effect at the time of this report, Hull concludes that Wetland JB is an isolated, Ohio Category 1 wetland that connects to an isolated manmade drainage swale that runs parallel to the CSX 341 Glendale Avenue, Toledo, Ohio fax

96 Mr. Dallas Paul IDL1.1.9 February 1, 216 Page 2 railway. Wetland JB, and all other wetlands on the Site, are isolated and under the jurisdiction of the Ohio Environmental Protection Agency (Ohio EPA) Isolated Wetland Permitting Program. If you have any questions, feel free to contact me at (419) or kgardner@hullinc.com. Sincerely, Kristin Gardner, MS Scientist II Hugh F. Crowell, MS, PWS Ecology & Wetlands Practice Leader Attachments: Photolog, Figures ct: Paul Wetzel, U.S. Army Corps of Engineers Heather Allamon, Ohio EPA Hugh Crowell, PWS, Hull & Associates, Inc.

97 ATTACHMENT A Photolog HULL & ASSOCIATES, INC. FEBRUARY 216 TOLEDO, OHIO IDL2.1.6

98 PHOTO 1: Drainage swale located south of the Site, facing southwest. PHOTO 2: Drainage swale located south of the Site, facing south toward CSX railroad. Wales Road Development Date: Industrial Developers Ltd. February Glendale Avenue Suite #3 Toledo, Ohio , Hull & Associates, Inc. Phone: (419) Fax: (419) Site Photographs Wales Road Northwood, Wood County, Ohio Project Number: IDL2 File Name: IDL2.1.3.xlsx

99 PHOTO 3: View of Wetland JB south of the Site, facing west. PHOTO 4: Drainage swale connected to Wetland JB located south of the Site, facing south toward CSX railroad. Wales Road Development Industrial Developers Ltd. Date: February 216 Site Photographs 341 Glendale Avenue Suite #3 Toledo, Ohio , Hull & Associates, Inc. Phone: (419) Fax: (419) Wales Road Northwood, Wood County, Ohio Project Number: IDL2 File Name: IDL2.1.3.xlsx

100 PHOTO 5: View of the northeast termination of the non-jd drainage swale, facing southwest from Oregon Road. 341 Glendale Avenue Suite #3 Toledo, Ohio , Hull & Associates, Inc. PHOTO 6: View of the northeast termination of the non-jd drainage swale, facing northeast from Oregon Road. Phone: (419) Fax: (419) Wales Road Development Industrial Developers Ltd. Site Photographs Wales Road Northwood, Wood County, Ohio Date: Project Number: IDL2 File Name: IDL2.1.3.xlsx February 216

101 PHOTO 7: View of the southwest termination of the non-jd drainage swale, facing northeast from the CSX access road. Wales Road Development Date: Industrial Developers Ltd. February Glendale Avenue Suite #3 Toledo, Ohio , Hull & Associates, Inc. Phone: (419) Fax: (419) Site Photographs Wales Road Northwood, Wood County, Ohio Project Number: IDL2 File Name: IDL2.1.3.xlsx

102 ATTACHMENT B Figures HULL & ASSOCIATES, INC. FEBRUARY 216 TOLEDO, OHIO IDL2.1.6

103 SHARON DR 215, Hull & Associates, Inc. MIAMI ST WET-JC ( Wetland JC Wetland JA ( WET-JA WOODMORE ST :6, Feet W FLORENCE AVE I UPL-JB ( W ANDRUS RD ( WET-JB Wetland Continues Off-Site Wetland JB ROSEDALE DR LAWNDALE DR MARYLAND PL WATER ST ELM ST SHEFFIELD PL BRENTWOOD DR BACON ST BERGIN AVE GLENWOOD RD WALNUT ST SUPERIOR ST MAPLE ST BEECH ST OAK ST 7 Man-Made Drainage Swale CHELSEA DR I 75 S OREGON RD DILLROSE DR FARNSTEAD DR VENICE DR MARYLAND PL WALES RD NORMA PL JAMESTOWN DR Property Boundary Stream Wetland National Wetlands Inventory ( Wetland Data Point ( Upland Data Point Non-Jurisdictional Drainage Swale Photo Locators Notes: The aerial photo was acquired through the ESRI Imagery web service. Aerial photography dated 214. Produced using ArcGIS 1.2 SANTUS DR 341 Glendale Ave Suite 3 Toledo, Ohio Phone: (419) Fax: (419) I 75 N DISCLAIMER Hull & Associates, Inc. (Hull) has furnished this map to the company identified in the title block (Client) for its sole and exclusive use as a preliminary planning and screening tool and field verification is necessary to confirm these data. This map is reproduced from geospatial information compiled from third-party sources which may change over time. Areas depicted by the map are approximate and may not be accurate to mapping, surveying or engineering standards. Hull makes no representation or guarantee as to the content, accuracy, timeliness or completeness of any information or spatial location depicted on this map. This map is provided without warranty of any kind, including but not limited to, the implied warranties of merchantability or fitness for a particular purpose. In no event will Hull, its owners, officers, employees or agents, be liable for damages of any kind arising out of the use of this map by Client or any other party. LAUREN LN February 216 Industrial Developers Ltd. Surface Water Delineation Addendum Wales Road Northwood, Wood County, Ohio File Name: IDL2_2_Fig1_SWDelin.mxd Figure 1 Edited: 2/9/216 By: jslifer

104 215, Hull & Associates, Inc Wetland JA WET-JC 62 Wetland JC ( WET-JA ( I Feet :6, UPL-JB ( ( WET-JB 6 61 Wetland JB Notes: 62 2 The aerial photo was acquired 6through the ESRI Imagery web service. Aerial photography dated Glendale Ave Suite 3 61 Toledo, Ohio Phone: (419) Fax: (419) DISCLAIMER Hull & Associates, Inc. (Hull) has furnished this map to the company identified in the title block (Client) for its sole and exclusive use as a preliminary planning and screening tool and field verification is necessary to confirm these data. This map is reproduced from geospatial information compiled from third-party sources which may change over time. Areas depicted by the map are approximate and may not be accurate to mapping, surveying or engineering standards. Hull makes no representation or guarantee as to the content, accuracy, timeliness or completeness of any information or spatial location depicted on this map. This map6is 2 provided without warranty of any kind, including but not limited to, the implied warranties of merchantability or fitness for a particular purpose. In no event will Hull, its owners, officers, employees or agents, be liable for damages of any kind arising out of the use of this map by Client or any other party Property Boundary Stream Wetland National Wetlands Inventory ( Wetland Data Point ( Upland Data Point Non-Jurisdictional Drainage Swale Flood Hazard Areas Zone A - 1 Year Floodplain (No Base Elev. Determined) Zone AE - 1 Year Floodplain (Base Elev. Determined) Floodway Areas in Zone AE Areas of.2% Annual Chance Flood LiDAR Contours (2' Interval) Index Intermediate February 216 Industrial Developers Ltd. Figure LiDAR Contour Map Produced using ArcGIS Man-Made Drainage Swale Wetland Continues Off-Site 2 Wales Road Northwood, Wood County, Ohio File Name: IDL2_2_Fig2_LiDAR.mxd Edited: 2/9/216 By: jslifer

105 APPENDIX E Figures HULL & ASSOCIATES, INC. FEBRUARY 217 TOLEDO, OHIO AHR1.1.3

106 ODOT ROAD (JUNE 217) HOTEL WETLAND JA WETLAND JC PARKING GARAGE AMPHITHEATER POND WETLAND JB WETLAND IMPACTS WETLAND ORAM CATEGORY IMPACT JA 1.74 JB JC 1.6 TOTAL 2.62 INDUSTRIAL DEVELOPERS LTD. BROWNFIELDS SHALE OIL & GAS WASTE MANAGEMENT C 217 Hull & Associates, Inc. 219 South Erie StreetPhone: (419) ENVIRONMENTAL Toledo, Ohio 4364 Fax: (419) PROJECT NO.: ALTERNATIVE ENERGY CAD DWG FILE: FIGURE 1 PREFERRED ALTERNATIVE AHR1 WALES ROAD NORTHWOOD, WOOD COUNTY, OHIO AHR1.1.4 SAH SUBMITTAL DATE: PLOT DATE: JANUARY 217 1/3/17

107 ODOT ROAD (JUNE 217) HOTEL WETLAND JA ROAD WETLAND JC PARKING ROAD STORMWATER POND WETLAND JB WETLAND WETLAND IMPACTS ORAM CATEGORY IMPACT JA 1.74 JB 1.8 JC 1.6 TOTAL.88 INDUSTRIAL DEVELOPERS LTD. FIGURE 2 MINIMAL DEGRADATION ALTERNATIVE BROWNFIELDS SHALE OIL & GAS WALES ROAD WASTE MANAGEMENT C 217 Hull & Associates, Inc. NORTHWOOD, WOOD COUNTY, OHIO 219 South Erie StreetPhone: (419) ENVIRONMENTAL Toledo, Ohio 4364 Fax: (419) PROJECT NO.: AHR1 SUBMITTAL DATE: JANUARY 217 ALTERNATIVE ENERGY CAD DWG FILE: AHR1.1.5 SAH PLOT DATE: 1/3/17

108 HOTEL WETLAND JA WETLAND JC PARKING POND WETLAND JB WETLAND WETLAND IMPACTS ORAM CATEGORY IMPACT JA 1. JB 1. JC 1. TOTAL. INDUSTRIAL DEVELOPERS LTD. BROWNFIELDS SHALE OIL & GAS WASTE MANAGEMENT C 217 Hull & Associates, Inc. 219 South Erie StreetPhone: (419) ENVIRONMENTAL Toledo, Ohio 4364 Fax: (419) PROJECT NO.: ALTERNATIVE ENERGY CAD DWG FILE: FIGURE 3 NON-DEGRADATION OPTION AHR1 WALES ROAD NORTHWOOD, WOOD COUNTY, OHIO AHR1.1.6 SAH SUBMITTAL DATE: PLOT DATE: JANUARY 217 1/3/17

109 APPENDIX F Mitigation Bank Credit Reservation HULL & ASSOCIATES, INC. FEBRUARY 217 TOLEDO, OHIO AHR1.1.3

110 NCRCPD In-Lieu Fee Program Advance Credit Request October 215 Applicant Information: Name Address A.H. Rossford Holdings, LLC Armin Hunger 879 Wales Road Northwood, OH Telephone Consultant/Agent Information: Name Address Hull & Associates, Inc. Kristin Jenkins 219 S. Erie Street Toledo, OH 4364 Telephone Project Information: Project Name or Other Identifier Project RED Street or Other Descriptive Location, e.g. County, Wales Road, Wood County Township If known, Project Coordinates N, W USGS 8-digit HUC Code 419 Project Permit Information: Please note all permit applications that have been or will be submitted and provide applicable additional details requested. Level 1 Isolated Wetland Permit Date: Submit February 217 SWIMs#: Ohio EPA Reviewer: Status of Completeness Review: Level 2 or 3 Isolated Wetland Permit Date: Submit February 217 SWIMs#: Ohio EPA Reviewer: Status of Completeness Review: Nationwide Permit Date: NW Permit #: ACOE Application #: ACOE Project Manager: Status of PCN Completeness Review: 44 Permit Date: ACOE Application #: ACOE Project Manager: Date of Public Notice: 41 Water Quality Certification Date:

111

112 NCRCPD In-Lieu Fee Program Buffalo District Acknowledgment of Reservation of Advance Credits Date: February 1, 217 Applicant s Name: A. H. Rossford Holdings, LLC Applicant s Address: 879 Wales Road, Northwood, OH Applicant s Project Name/Identifier: Rossford Entertainment District Ohio ACOE # ; OEPA ID #: Project Location: Wales Road, Wood County, Advance Credits Reserved*: Resource Type Service Area Reservation Period Credit Price/Unit Number of Credits Nonforested Wetland days $25, 5.3 (Maumee River) Reservation Period: 3 calendar days from date above for credits requested for level 1 isolated wetland impacts. 9 calendar days from date above for credits requested for level 2 or 3 isolated wetland and all jurisdictional wetland impacts. 9 calendar days from date above for credits requested for all stream impacts. Vicki B. Derr Mitigation Coordinator vderr@envirotechcon.com *North Coast policies on credit reservations and sales should be reviewed and are available at March 215

113 APPENDIX G ODNR Endangered Species Review HULL & ASSOCIATES, INC. FEBRUARY 217 TOLEDO, OHIO AHR1.1.3

114 Ohio Division of Wildlife Raymond W. Petering, Chief 245 Morse Rd., Bldg. G Columbus, OH Phone: (614) May 4, 216 Kristin Gardner Hull & Associates, Inc. 341 Glendale Ave. Toledo, OH Dear Ms. Gardner, After reviewing the Natural Heritage Database, I find the Division of Wildlife has no records of rare or endangered species in the Dixie Highway Commercial Development project area, including a one mile radius, in Rossford, Wood County, Ohio. We are unaware of any unique ecological sites, geologic features, animal assemblages, scenic rivers, state wildlife areas, nature preserves, parks or forests, national wildlife refuges, parks or forests or other protected natural areas within a one mile radius of the project area. We also have no records for Indiana Bat (Myotis sodalis) capture locations within a five mile radius or hibernacula within a ten mile radius of the project site. Our inventory program has not completely surveyed Ohio and relies on information supplied by many individuals and organizations. Therefore, a lack of records for any particular area is not a statement that rare species or unique features are absent from that area. This letter only represents a review of rare species and natural features data within the Ohio Natural Heritage Database. It does not fulfill coordination under the National Environmental Policy Act (NEPA) or the Fish and Wildlife Coordination Act (48 Stat. 41, as amended; 16 U.S. C. 661 et seq.) and does not supersede or replace the regulatory authority of any local, state or federal agency nor relieve the applicant of the obligation to comply with any local, state or federal laws or regulations. Please contact me at if I can be of further assistance. Sincerely, Debbie Woischke Ohio Natural Heritage Database Program

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