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Chapter 2. Conceptual Mitigation Plan <br /> The proposed compensatory mitigation actions for the project attempt to strike a balance between <br /> achieving project goals as well as a positive result in terms of ecological lift. In general, joint USACE <br /> and EPA rules have been established that require more careful mitigation planning efforts utilizing a <br /> watershed approach in site selection, establishment of enforceable performance standards, and <br /> preference for use of mitigation banks or in-lieu fees (ILF's) whenever ecologically appropriate <br /> (USACE&EPA,2008). The proposed wetland impacts and compensatory mitigation actions attempt <br /> to closely adhere to these rules while also utilizing the best available science (Granger et al., 2005; <br /> Hruby et al., 2009; Sheldon et al., 2005;WSDOE et al., 2006; and WSDOE et al., 2021) and adhering <br /> to the requirements of EMC 19.37.125.A.1. <br /> 2.1 Purpose and Need <br /> The Applicant proposes to develop high density housing within the City of Everett to help alleviate <br /> the shortage of housing in the Everett area. <br /> 2.2 Description of Unavoidable Impacts <br /> The Applicant proposes residential development of the subject property to include 23 townhomes <br /> and associated infrastructure including an internal access road, turnaround for fire and other safety <br /> access, and associated utilities. Due to the centralized location of Wetland A and Wetland B, no <br /> practical site design was identified that would result in lesser impacts to onsite critical areas while <br /> achieving the applicant's development objectives. Therefore, the unavoidable fill of Wetland A <br /> (10,253 square feet) and Wetland B (502 square feet) is required to accommodate the proposed <br /> residential development. An additional 788 square feet of Wetland A exists offsite to the west and <br /> the north of the subject property. Although these areas are not proposed to be filled,they will become <br /> isolated and non-functioning following the fill of the onsite portion of Wetland A. Therefore, the <br /> project will consider these areas as being directly impacted for calculating total impacted wetland areas, <br /> and as such are included in the compensatory mitigation accordingly. No impacts direct or indirect <br /> impacts are proposed for Offsite Wetland 1 as an existing paved road interrupts the buffer. Table 1 <br /> below summarizes the proposed impacts to Wetland A and Wetland B. <br /> Table 1. Sum ma of Wetland Impacts <br /> Impacted WSDOE Cowardin 3 Impact Area <br /> Wetland Rating' Class2 HGM Class Impact Type (sq. ft.) <br /> Wetland A III PFO/SSC Depressional Direct (Fill) 11,041 <br /> Wetland B III PEMB T—Depressional Direct (Fill) 502 <br /> Notes: <br /> 1. WSDOE rating according to Washington State wetland rating system for Western Washington—Revised(Hruby,2014). <br /> 2. Cowardin et al.(1979)or NWI Class based on vegetation:PFO=Palustrine Forested;PSS=Scrub-Shrub;PEM=Emergent;Modifiers for <br /> Water Regime:B=Seasonally Saturated;C=Seasonally Flooded <br /> 3. Brinson,M.M.(1993). <br /> 2.2.1 Impacted Wetland Functions <br /> The proposed project will directly impact two Category III wetlands (Wetland A and Wetland B) <br /> onsite. A wetland function impact analysis is provided below. <br /> 1345.0029—Benton Square 7 Soundview Consultants LLC <br /> Conceptual Mitigation Bank Use Plan April 1,2022 <br />