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2.3.2 Site Selection Rationale Wetland functions targeted for use in the KFMB include restoring hydrology and floodplain connectivity to existing and created aquatic areas and increasing habitat functions for anadromous fish and other aquatic dependent wildlife by re-establishing wetland and riparian vegetation communities on a 75.2-acre in the Bear Creek Basin and floodplain environment. Wetlands A and Wetland B are isolated wetlands that contain substantial amounts of non-native,invasive species that provide limited functions relative to the larger wetland area; therefore, full wetland function compensation is better provided elsewhere, through a consolidated mitigation program that has greater potential to provide valuable wetland functions and that has the landscape potential to maintain each function. In order to maximize and efficiently use the buildable space available, the entire project site will be developed. Therefore, onsite mitigation through wetland creation or enhancement is infeasible and not practical. Offsite permittee-responsible wetland mitigation has been carefully considered but determined to be infeasible. The challenges of creating and restoring relatively small areas of wetland are alleviated though mitigation banking where the mitigation is completed on a large scale and the benefits of the purchased credits provide watershed scale benefits, with longer term maintenance and management than is normally provided with permittee-responsible-mitigation. The wetlands created through mitigation banking will have much higher habitat and ecological value than that provided by the onsite wetlands proposed to be filled. Joint USACE and EPA rules (USACE&EPA, 2008) and interagency guidance (WSDOE&USACE 2006; Hruby et al., 2009) have been established that require more careful mitigation planning efforts utilizing a watershed approach in site selection, establishment of enforceable performance standards, and preference for use of mitigation banks wherever possible. The subject property is currently located within the KFMB's Primary Service Area(Appendix B),thus allowing for the proposed project to utilize the approved mitigation banking program for compensatory mitigation within the same watershed as project impacts. The overarching goals of the KFMB are to improve hydrologic,water quality, and habitat functions at the KFMB site; and to reconnect Bear Creek to its historic floodplain while providing self-sustaining interconnected aquatic and terrestrial habitats that will not require continued maintenance. The purchase of mitigation banking credits will allow for the proposed project to achieve no net loss of aquatic resource functions. The KFMB, sponsored by Habitat Bank, LLC, has a rigorous 10-year monitoring schedule in which credits are released by regulatory agencies only after achieving site-specific performance standards to ensure successful mitigation actions. Oversight of this mitigation banking program is provided by an Interagency Review Team (IRT) that includes representatives from the USACE,WSDOE,tribes,and other federal, state, and local regulatory agencies. 2.3.3 Proposed Mitigation Credits The proposed project will result in a total of 11,041 square feet of permanent direct impacts to Wetland A and 502 square feet of permanent direct impacts to Wetland B. Wetlands A and B are classified as Category III wetlands. Utilizing the 1:1 ratio for direct Category III wetland impacts described in the KFMB Mitigation Banking Instrument (Habitat Bank, LLC, 2019), this equates to 0.265-acre credits to be purchased. Table 2, below, summarizes the proposed wetland impacts and required bank credits for purchase through the KFMB. 1345.0029—Benton Square 10 Soundview Consultants LLC Conceptual Mitigation Bank Use Plan April 1,2022