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Home My WebLink AboutCAPSTONE COTTAGES - FDP - FDP150046 - REPORTS - WETLANDS DOCUMENTSWETLAND MITIGATION PLAN CAPSTONE COTTAGES PROJECT FORT COLLINS, COLORADO Prepared for: CITY OF FORT COLLINS Colorado and Prepared by: RIPLEY DESIGN, INC. 419 Canyon Avenue, Suite 200 Fort Collins, CO 80521 and Cedar Creek Associates, Inc. Fort Collins, Colorado April 2016 I TABLE OF CONTENTS 1.0 INTRODUCTION ............................................................................................................................ 1 2.0 ENVIRONMENTAL SETTING ............................................................................................................ 2 3.0 EXISTING WETLANDS ..................................................................................................................... 3 3.1 Identification & Delineation .................................................................................................... 3 3.2 Description ............................................................................................................................. 3 3.3 Function & Values Assessment ............................................................................................. 4 3.4 Species of Concern ................................................................................................................ 5 4.0 WETLAND IMPACTS ...................................................................................................................... 6 5.0 WETLAND MITIGATION AND ENHANCEMENTS ................................................................................ 6 5.1 Mitigation Conceptual Plan .................................................................................................... 6 5.1.1 Wetland Mitigation ........................................................................................................... 6 5.2 Functions & Values ................................................................................................................ 8 5.3 Cost & Probability of Success ................................................................................................ 8 5.4 Timetable for Construction & Monitoring ............................................................................... 8 5.5 Maintenance & Monitoring ..................................................................................................... 9 5.5.1 Maintenance Activities..................................................................................................... 9 5.5.2 Monitoring ...................................................................................................................... 10 5.5.3 Success Criteria ............................................................................................................ 11 5.5.4 Annual Reporting ........................................................................................................... 12 6.0 LITERATURE CITED ...................................................................................................................... 13 APPENDIX A: FIGURES APPENDIX B: TABLES APPENDIX C: DOCUMENTS AND COMMUNICATIONS APPENDIX D: SITE PHOTOGRAPHS TAKEN AUGUST 23, 2013 AT THE CAPSTONE COTTAGES PROJECT SITE II ABBREVIATIONS/ACRONYMS Capstone Capstone Collegiate Communities-Fort Collins, LLC Cedar Creek Cedar Creek Associates, Inc. City City of Fort Collins CPW Colorado Parks and Wildlife FAC Facultative FACU Facilitative Upland FACW Facultative Wetland GPS Global Positioning System NRCS Natural Resources Conservation Service NWP Nationwide Permit OBL Obligate Wetland UPL Upland USACE U.S. Army Corps of Engineers 1 1.0 INTRODUCTION Capstone Collegiate Communities – Fort Collins, LLC (Capstone) plans to develop the Capstone Cottages Project, a student-oriented housing project, on a 21-acre area located on the northern extent of Fort Collins, Larimer County, Colorado. The proposed development site is currently vacant land located in the Northwest 1/4 of Section 7 (Township 7 North, Range 68 West) at the northeast corner of the intersection of Lemay Avenue and Lincoln Avenue (see Figure 1). The Bank of Colorado is located on the northeast intersection corner at Lincoln and Lemay avenues and the proposed project would be situated to the north and east of the bank. Undeveloped land is located to the north of the subject site, existing industrial uses are located to the east, and Buffalo Run Apartments and the Mulberry and Lemay Crossings shopping complex are located to the south of the property across Lincoln Avenue. The Woodward Campus, now under construction, is located to the southwest and undeveloped land exists on the west side of Lemay Avenue adjacent to the project site. The San Cristo/Andersonville and Alta Vista residential communities are located northwest of the project site with intervening road right-of-ways and I-Industrial zoned property. Capstone specializes in the development, construction and management of high-quality student housing developments in close proximity to major colleges and universities across the country. On this site, Capstone proposes to develop cottage-style student-oriented housing or small-scale, single-family and attached single-family units that are rented to 3 to 5 unrelated people. The project would be marketed to students but may also include tenants who are not attending college. In addition to the cottages, the project would also feature three-story, four-bedroom townhome units located to the south and to the interior of the site. The housing project would provide 202 rental units for the growing student population in Fort Collins within a managed setting with recreational opportunities on-site. The development would include features such as courtyards, open space, a resort-style pool, and a clubhouse that offers gathering places, fitness facilities, a theater and study rooms. Development of the proposed project would impact several small, low quality City of Fort Collins (City) regulatory wetlands; however, wetland mitigation, as described in this document would be created to replace these locations and maintain or enhance the wildlife values and water quality properties of the existing wetlands. Details of impacts to existing wetlands, proposed mitigation, and wetland creation are discussed in the following sections. 2 2.0 ENVIRONMENTAL SETTING The majority of the project area lies at approximately 4,941 feet above sea level and currently supports non-native grassland. Existing land uses within the property consist entirely of a cleared, abandoned farmstead area and fallow, non-native grassland pasture. Topography on the site is essentially level with a drainage gradient to the southeast. Environmental studies of the subject property were previously completed in 2005 and 2013 by Cedar Creek Associates, Inc. (Cedar Creek) and the results of those surveys and reporting were previously provided to the City of Fort Collins in the Environmental Characterization Study Report for the Capstone Cottages Project Site (Cedar Creek 2013) and are summarized here. A copy of the report is provided in Appendix C. The 2013 environmental characterization study of the property followed the ecological characterization checklist of information required by Fort Collins Land Use Code under 3.4.1 (D) (1) items (a) through (k). The 2005 study documented grazing use by horses and an abandoned farmstead on the property that had been cleared of all structures at the time of the surveys. An inactive prairie dog colony was also identified on the northern extent of the site in 2013 (see Figure 2). As also indicated during the August 2013 survey of the site, non-native grassland on the property is dominated primarily by smooth brome (Bromus inermis) with lesser amounts of Kentucky bluegrass (Poa pratensis), tall fescue (Festuca arundinacea), slender wheatgrass (Elymus trachycaulus), crested wheatgrass (Agropyron cristatum), western wheatgrass (Pascopyrom smithii), and cheatgrass (Bromus tectorum) (Cedar Creek 2013). Alfalfa (Medicago sativa) is also present as a sub-dominant species in non-native grassland over portions of the eastern half of the property. Western wheatgrass and slender wheatgrass are the only native species among those species present. Total vegetation cover at the time of the 2013 survey ranged from 10 percent, in the overgrazed prairie dog town area, to nearly 100 percent in the weed-dominated former farmstead area. The former farmstead area is now dominated by tall, dense stands of kochia (Bassia scoparia) and carelessweed (Cyclachaena xanthiifolia). Vegetation cover in the prairie dog town at the north edge of the property is sparse as a result of prairie dog overgrazing and is dominated primarily by weedy species including field bindweed (Convolvulus arvensis), cheatgrass, Russian thistle (Salsola tragus), and pitseed goosefoot (Chenopodium berlandieri) with minor amounts of smooth brome. Woody vegetation is restricted primarily to small (less than 6 inches in diameter) Russian olive (Elaeagnus angustifolia), eastern cottonwood (Populus deltoides), and peachleaf willow (Salix amygdaloides) trees (see attached Figure 2). Lance-leaf cottonwoods (Populus acuminata) at the southwest property corner north of the Bank of Colorado are the only potentially significant trees located on the property. Aside from the cottonwood trees and 3 small wetland areas as described in Section 3.0, the project area does not support any native vegetation or other unique habitat features, and no features of ecological value exist within 500 feet of the development site. Mice, voles, black-tailed prairie dog, and pocket gopher are 3 the principal species likely to establish resident mammal populations in non-native grassland. Songbirds such as western meadowlark, Brewer’s blackbird, common grackle, and black-billed magpie may also occasionally use non-native grassland/pasture habitat. Trees on the property may be used for perching, nesting, and foraging by urban-adapted songbirds, and Canada geese grass may occasionally graze the non-native grassland areas. No songbird nests were located in trees on the project area during the August 23, 2013 survey. No good quality wildlife movement corridors or perennial water features or natural drainages were noted on or near the property. 3.0 EXISTING WETLANDS Wetlands on the property were delineated by Cedar Creek on August 23, 2013. A summary of the wetlands identified during that survey is included in Sections 3.2 to 3.4. For a full description, the complete letter report, Waters of the U. S. Delineation for the Capstone Cottages Project (Cedar Creek 2014), that was submitted to the U.S. Army Corps of Engineers (USACE) on February 18, 2014, is provided in Appendix C. 3.1 Identification & Delineation Wetland delineation and sampling work for the wetlands and open water features within the project area was completed on August 23, 2013, using the methods and techniques specified for "routine on-site delineations" in the USACE’s publication Wetlands Delineation Manual (USACE 1987), supplemented by the document Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys and Coast Region (USACE 2010). The delineation was accepted as accurate and complete by the USACE on February 25, 2014. A copy of the USACE approval letter is provided in Appendix C. Figure 2 in Appendix A illustrates the boundaries of the wetlands identified on the property. 3.2 Description Three wetland areas, W-1, W-2, and W-3, totaling 0.22 acres, were identified during the August 2013 delineation completed by Cedar Creek and are mapped on Figure 2 (Appendix A) and summarized in Table 1, Appendix B. It should be noted that while hydric soils were present at all of the sample points selected to describe these wetlands, the wetland indicators for wetland types W-2 and W-3 were weak, indicating a drying trend across this project site. All three of the wetlands are believed to be isolated with no connection to a Water of the U. S. Soils in this area were mapped by the Natural Resource Conservation Service (NRCS) as Loveland clay loam, 1-3 percent slopes. This soils map unit is classified as having a high seasonal water table from 1.5 to 2.5 feet deep. No open water features or marshy conditions were identified for Wetlands W-2 and W-3. Runoff from adjacent commercial developments and Lincoln Avenue appears to be a significant hydrologic contributor to all three wetlands. 4 W-1: Borrow Ditch Wetland W-1 (0.18 acres) is a palustrine emergent wetland located in the narrow borrow ditch abutting Lincoln Ave (see Photo P-1, Appendix D). Some standing water less than 5 inches deep was observed at the site during the initial survey. The primary functions of Wetland 1 are flood control and soil stabilization. The vegetation community in this wetland is dominated by broadleaf cattails (Tyla latifolia), common dogbane (Apocynum cannabinum), and Emory sedge (Carex emoryi) established in a saturated soil moisture regime. This borrow ditch was classified as non-jurisdictional by the Corps as a result of a previous mapping effort in 2009. The cattail stand may provide some wildlife habitat, but its location adjacent to the road would severely limit this potential function. The wetland’s size, form and location also limits its overall value as a wetland habitat component. W-2: Depression Wetland W-2 (0.02 acres) is also a small palustrine emergent wetland located in a depression in an upland meadow area in the southeast property corner (see Photo P-2 in Appendix D). The wetland is dominated by arctic rush (Juncus arcticus [balticus]) with upland plant species making up a small percentage of the absolute cover. The value of the herbaceous strata of the site is comparatively low and synonymous with the surrounding upland meadow in terms of soil stabilization. Given the depression form, a shallow depth to a high water table is assumed based on the NRCS soils mapping. The function of the herbaceous plant strata, occurring over the major portion of Wetlands W-2, is limited to soil stabilization. W-3: Shallow Drainage Wetland W-3 (0.02 acres) is a small palustrine forested and emergent wetland located in an upland meadow adjacent to Wetland W-2 (see Photo P-3 in Appendix D). The plant community at this site is dominated by eastern cottonwood, dogbane, and roundfruit rush (Juncus compressus). This wetland has become established in a narrow, comparatively short and shallow drainage along the eastern project area border. Wetland W-3 is characterized by dominant species in the herbaceous, shrub, and tree strata. The function of the herbaceous plant strata, occurring over the major portion of Wetlands W-3, is limited to soil stabilization. Save for the shrub and tree strata, whose functions and value would be well compensated for through landscape plantings, the value of the herbaceous strata of Wetland W-3 is comparatively low and similar to the surrounding upland meadow in terms of soil stabilization. 3.3 Function & Values Assessment All of the wetlands identified on the site were evaluated for functions and values. All wetlands scored an average of 1.6 or less for functions and values during the evaluation, which was completed by Cedar Creek on April 4, 2016. As such, all wetlands on the property are considered to be Low Functioning wetlands. Table 2 in Appendix B includes the Wetland Functions and Values Evaluation completed for the site and provides details on the various characteristics evaluated. 5 3.4 Species of Concern The project area was evaluated with regards to potential habitat for state and federal listed threatened and endangered species in 2013 in the Environmental Characterization Study Report for the Capstone Cottages Project Site (Cedar Creek 2013). Review of the USFWS’ IPaC website (USFWS 2016) identified 13 federally listed species as potentially occurring in Larimer County; least tern (Sterna antillarum), Mexican spotted owl (Strix occidentalis lucida), piping plover (Charadrius melodus), whooping crane (Grus americana), 2 fish species, Ute ladies’-tresses orchid (Spriranthes diluvialis), Colorado butterfly plant (Gaura neomexicana coloradenis), North Park phacelia (Phacelia formosula), Western prairie fringed orchid (Platanthera praeclara), Arapahoe snowfly (Arsapnia arapahoe), Canada lynx (Lynx canadensis), and Preble’s meadow jumping mouse (Zapus hudsonius preblei). Of these 13 species, it was determined that the project site either lay outside of all of these species’ known range and/or suitable habitat for the species did not occur on the project site (Cedar Creek 2013, USFWS 2016). Colorado Parks and Wildlife (CPW) has identified 74 species as being threatened, endangered or of special concern in Colorado (CPW 2016). Of these 74 species, which include 2 mollusks, 23 fish, 19 birds, 13 mammals, 10 reptiles, and 7 amphibians, only the black-tailed prairie dog (Cynomys ludovicianus), a state species of concern, is known to occur on the property. Approximately 4 acres of a black-tailed prairie dog colony extends into the northern portion of the project area from the property adjacent to the site on the north. Little prairie dog activity was noted at the time of the August 2013 field survey except in the northeast portion of the colony where prairie dogs were observed aboveground. The entire prairie dog colony (see Figure 1, Appendix A) is well under 50 acres and Section 3.4.1 of the Land Use Code provides for no protection of prairie dog towns less than 50 acres in size. Section 3.4.1 (N)(6) does stipulate that before the commencement of grading or other construction on the development site, any prairie dogs inhabiting portions of the site within the development area shall be relocated or eradicated by the developer using city-approved methods as set forth in Chapter 4 of the City Code and, when applicable, using methods reviewed and approved by CPW. Habitat for the burrowing owl (Athene cunicularia), a state threatened species, potentially occurs in the black-tailed prairie dog colony on the northern extent of the project site; however, their presence has not been previously documented on the project site and no owls were observed during the August 2013 surveys. Suitable habitat for the common garter snake (Thamnophis sirtalis), also a state species of concern, is also present on the site; however, no sightings of this species have been made on the property to date. No natural communities, rare plants, riparian corridors, or critical wildlife habitat as identified by the Fort Collins Comprehensive Plan and Land Conservation and Stewardship Master Plan (City of Fort Collins 2011) were observed on the property. No raptor nests were observed on-site during the August 2013 survey 6 or in the immediate vicinity of the property. If the development proposal includes removal of any trees on the property, tree removal during the songbird nesting season (April 1 to July 31) could result in the loss or abandonment of a nest and would be in violation of the federal Migratory Bird Treaty Act. Because tree removal during the songbird nesting season could result in the loss or abandonment of a nest, it is recommended that tree removal or pruning occur outside of the songbird nesting season (April 1 – July 31), or trees be surveyed to ensure lack of nesting prior to removal during the nesting season. This mitigation recommendation should preclude the possible incidental take or disturbance of active songbird nests. 4.0 WETLAND IMPACTS As shown on Figure 2 in Appendix A and Table 2 in Appendix B, the proposed project would permanently impact City of Fort Collins regulatory Wetlands W-1, W-2, and W-3. The total City regulatory wetland impact is 0.22 acres, which would be mitigated at a 1:1 creation:impact ratio. The total wetland mitigation and enhancement would be 0.22 acres. 5.0 WETLAND MITIGATION AND ENHANCEMENTS A total of 0.22 acres of compensatory wetland would be constructed on site in the southeast corner of the property as shown on Figure 2 in Appendix A to replace the 0.22 acres of wetlands currently present on the site that would be removed under the proposed development scenario. Creation of this proposed wetland area is described in Sections 5.1 to 5.6. 5.1 Mitigation Conceptual Plan 5.1.1 Wetland Mitigation Location and Land Ownership. The Capstone Cottages Wetland Mitigation site would be constructed in the southeast corner of the property as shown on Figures 2 and 3 in Appendix A. The mitigation site is bordered on the east by commercial properties and on the south by Lincoln Avenue. Areas to the west and north of the site would be developed into residential housing for students. The property is currently owned by Capstone. Landform. In general, the property is relatively flat with drainage to the southeast of the site. A mitigation wetland area and stormwater detention pond would be shaped and graded in the southeast corner of the property as indicated on civil grading plans that are currently under review by the City of Fort Collins. No earth-moving activities will be permitted outside the boundaries of the mitigation area except as provided for in the site development plans. Adjunct disturbances related to the installation of emergency erosion control or site stabilization measures would also be excepted. Once grading is complete in the wetland/pond 7 to an elevation of 4,929 feet above sea level, the upper 12 inches of soil at bottom of the graded pond elevation (4,929 feet per plans contour “29”) will be removed, hauled away, and replaced with clean topsoil. If possible, soil from the W-2 and W-3 wetlands in the meadow area north of the proposed wetland/pond site will be salvaged during construction and used for part of the 12 inches of new soil replaced at the bottom of the pond. Soil from the ditch wetland (W-1) located along Lincoln Avenue will not be used unless cattail species are acceptable for final mitigation; the seed bank from ditch soils would contain numerous cattail seeds and rhizomes. Following soil placement, the bottom of the wetland/pond will be roughly shaped at the 4,929 elevation to form minor topographic variations. This minor topographic relief should create micro-climates that will improve germination conditions and the potential for plant establishment and diversity. Hydrology. If necessary, water to support wetland species planted in the created wetland/pond area could initially be supported by temporary site irrigation until the plants become established. The long term source of water for the created wetland area is expected to largely consist of surface water run-off to the constructed wetland/pond. In the report Geotechnical Engineering Report –Capstone Cottages of Fort Collins prepared by Terracon Consultants (2014), runoff calculations indicate that a notable amount of surface runoff water would drain to the proposed detention pond location during each month of the growing season, in an average or better precipitation year, and could support a wetland community planted in the bottom of the proposed detention pond. This equates to an estimated total of approximately 58,300 cubic feet of water per growing season month (April through September). As designed, the detention pond would detain and release this runoff after passing through a fore bay sediment treatment until the depth of water in the pond reaches 12 inches. The 12 inches would be held in the bottom of the mitigation pond to aide in supporting the compensatory wetland plant community to be established. Additional information regarding the hydrology that would support the proposed wetland site is provided in the March 10, 2014 letter to the City of Fort Collins Planning Services from Cedar Creek (2015). A copy of that letter is provided in Appendix C. Vegetation. The created wetland would include herbaceous and tree plantings. Planting would commence following grading and topsoil placement and would include both native wetland seed and live plants. Refer to the seed mix tables in Appendix B (Tables 3 and 4), the Natural Habitat Buffer Zone Landscape Material Quantities table in Appendix B, and to Figures L7, L11, and L13.0 in Appendix A for descriptions of planting locations, planting procedures, and the types of species that will be used in the wetland construction. Vegetation planting timing is discussed in Section 5.4. The greenhouse grown shrubs and trees, grasses, sedges/rushes, and forbs identified on Figure L13.0 will be planted in appropriate locations, depending on the success of the seed mix. An integrated weed management plan would be developed and implemented for the site. Populations of noxious or otherwise undesirable plant species will be eradicated to maintain a high quality and diverse wetland community. 8 5.2 Functions & Values The function and value of the proposed wetland area identified on Figure 2 was evaluated by Cedar Creek in April 2016 (see Table 2, Appendix B). The proposed wetland scored an average of 2.4 on wetland functions, which signifies Moderate or Average Functioning conditions; the existing wetlands all showed Low Functioning conditions. The proposed wetland also scored 1.5 in Wildlife Functions; which indicates a Low Functioning condition. The existing wetlands averaged 0.8 and 0.6 in wildlife functions. See Table 5 in Appendix B for factors used in determining the functional value of the proposed wetland and the rankings. With respect to the mitigation of pre-existing wetland functions and values of the wetlands lost to development, the proposed wetland mitigation area characteristics should adequately address such loss. The pre-existing wetlands had primary functions of soil stabilization and flood control. The creation of the wetland mitigation area as shown on current project plans addresses such functions directly. The pre-existing wetlands also provided limited wildlife habitat function with respect to the small tree grove on site, the cattail stand along Lincoln Avenue, and their relationship to various urban avian and small mammal species. The proposed planting program at the mitigation site would include 158 individual plantings, including 27 canopy trees, 16 evergreen trees, and 115 shrubs (including willows). The diversity of this planting array is significantly improved from the existing wetland areas in respect to the diversity of the community strata, site stabilization potential, microclimate moderation, wildlife habitat with respect to nesting, resting, and roosting cover, and food sources for a broad array of wildlife species. In summary, while the establishment of a compensatory wetland to address the loss of the delineated wetlands is uncertain, the planting plans for the wetland mitigation area serve to more than compensate for the loss of such wetland functions and values. 5.3 Cost & Probability of Success In the report Geotechnical Engineering Report –Capstone Cottages of Fort Collins prepared by Terracon Consultants (2014), runoff calculations indicated that runoff volume from the project area could support a wetland community planted in the bottom of the proposed detention pond. The potential for creating a successful compensatory wetland site appears reasonable given the calculated surface water contribution. Additional information regarding the hydrology that would support the proposed wetland site is provided in a March 10, 2014 letter to the City of Fort Collins Planning Services from Cedar Creek (2015). A copy of that letter is provided in Appendix C. 5.4 Timetable for Construction & Monitoring Excavation and grading may ordinarily occur during any month of the year. However, revegetation activities are typically more limited with respect to the time of year in which they should be completed and must be timed to coincide with a recognized planting season. The following table depicts the revegetation schedule that would be followed to achieve the mitigation objectives set for this project. 9 Site conditions and/or climatic variations may require that the schedule be modified somewhat to achieve revegetation success. The schedule does not reflect any weed control activities that may be employed on site and would be amended to incorporate such a program if required. TABLE 1: SPRING MITIGATION SCHEDULE Month Reclamation Technique J F M A M J J A S O N D Excavation/Grading Any month Resoiling and/or Ripping (if necessary) XXX Seedbed Material Sampling XXX Fertilization XX Seedbed Preparation XX Seeding XX Mulching (as specified) XX Shrub Seedling and Tree Planting XX Willow Cutting and Planting (before breaking bud) XX Note: Weather and surface conditions permitting, the earlier in the season spring planting is completed the higher the potential for revegetation success. 5.5 Maintenance & Monitoring 5.5.1 Maintenance Activities The permanent mitigation plantings will be inspected at least bi-monthly during the first three growing seasons following planting and immediately following intense rainstorms. Areas of poor “seed take” will be noted. Any area remaining unvegetated by desirable species throughout the first three growing seasons will be reseeded following the application of appropriate seedbed preparation techniques during the next Fall planting season. Shrub seedlings or tree plantings judged to be dead will be replaced as necessary to meet success requirements. If nutrient deficiency symptoms develop on revegetated areas, this condition will be remedied by adding the proper nutrients in the proper amounts. Where slips, slides, or slumps occur on slopes, such will be remedied as soon as soil conditions permit access. No mowing, trimming, or other similar vegetation modification activities will be permitted in the wetland mitigation area unless directly associated with a planned weed control activity. All erosion control measures will be kept in good condition until the mitigation plan is deemed acceptable by the City or it is obvious that the site is stable and the installed measures are no longer required as per City direction. Within this time frame, any erosion control measure removed prematurely or damaged will be immediately replaced / repaired. A weed control plan will be prepared for the project area if weeds are deemed to be detrimental to plant establishment success or are required to be eradicated as per regulations. No more than 10 percent weeds 10 (see below for “weed” definition), as estimated based on total plant cover, will be permitted in the project area at the end of each growing season. The project area will be evaluated twice per year for weed establishment; once in mid-growing season and once at the end of each growing season for a period of three years following construction and planting. The completed plan will be submitted to governmental agencies, including the City of Fort Collins as required for review and approval. The weed control plan will be prepared by a Licensed Commercial Pesticide Applicator (LCPA). All subsequent weed control activities will also be conducted by an LCPA. The plan will consist of an Integrated Pest Management Plan (IPM) that will consider all methods of control that would potentially be applicable to the project area. These methods include mechanical, chemical, cultural, and biological techniques. Prior to plan preparation, a visit to the project area will be conducted at the end of the first growing season by the LCPA accompanied by representatives of the City of Fort Collins, as appropriate. The objective of this site visit is to assess site conditions, routes of access, weedy species present, the relationship of surrounding water / wetland bodies to the proposed areas to be treated, potential sources of run-on and run-off, and any other factors relevant to the weed control planning process. Given the presence of wetlands adjacent to project area, initial emphasis will be given to weed control methods other than those of a chemical nature, though chemical controls do exist that are considered by the Corps of Engineers to be appropriate in such cases. Plant species to be considered as weeds and controlled and/or eradicated at this project site, as per City code, are those listed by the Larimer County Weed Control District and those listed as noxious by the Colorado Weed Law. Species listed by Larimer County and to be controlled include. Canada Thistle Russian knapweed Dalmatian toadflax Spotted knapweed Diffuse Knapweed Tamarisk (saltcedar) Leafy spurge Yellow toadflax Musk Thistle 5.5.2 Monitoring At the end of each of the first three full growing seasons following initial planting, the wetland mitigation site will be monitored quantitatively to determine the overall level of construction success, site stability, and vegetation establishment. The results of this assessment will be submitted to the City of Fort Collins in a report on or about December 31 (see Section 5.5.4). Specific vegetation sampling and analysis protocols will be developed prior to the first annual assessment. Monitoring will continue on an annual basis until the City judges this mitigation program to be successful. Disturbed areas revegetated to upland conditions will not be included in the annual monitoring assessments. 11 To determine the depth to which non-inundated soils are saturated, soil sample pits will be dug at two to three representative locations in the wetland mitigation area. Each pit will be dug to a depth of 12.0-16.0 inches. The depth to saturation or flooding, if occurring, will be recorded. Soil matrix colors will be recorded to assess soil moisture regime characteristics. The presence of gleying or mottling will be noted and the color and percent of mottles in the matrix will be recorded, if present. A sulfidic (H2S) odor will also be noted, if observed. Plant cover will be evaluated using the point-intercept method. A 100-foot tape will be laid out along the surface at two to three locations in the created wetlands. Transects will be sited to represent the vegetation conditions common within the mitigation and enhancement area. At each one-foot interval along each transect, a "hit" will be recorded. A hit will consist of vegetation (by species), “free water”, floating algae, or bare ground/rock/litter combined. The percent total plant cover will then be calculated for each transect. The relative cover contributed by both hydric and upland plant species will also calculated for the wetland transects. Shrub (excluding willow cuttings which will be evaluated as a part of ground cover) and tree planting success will be assessed by a simple tally of viable shrubs and trees (by species) present at the time of monitoring fieldwork. Plant vigor will be recorded for each individual planting as “viable”, “stressed”, or “dead”. Both viable and moderately stressed plants will be included in the success calculation. Seriously stressed plants will be selected for remedial planting on a case-by-case basis. Any indications of insect or animal damage will be noted as will any indications of nutrient deficiencies. The average depth of free water over the mitigation sites will also be reported as will an estimate of the percent of the vegetated mitigation area overlain by free surface water. Surface water occurring in a mosaic with wetland species and representing a typical marsh community will not be included in the estimate of percent of open water present. 5.5.3 Success Criteria Mitigation and revegetation success will be judged based on four criteria:  the size of the mitigation areas successfully established  the wetland soil moisture regimes created  the percent ground cover of wetland species present in the wetland mitigation area  the percent success of the shrub and tree plantings. The four criteria will be met when:  0.22 acres of vegetated wetlands have been created. 12  The wetland mitigation area exhibits saturated conditions in the upper 12.0 inches of the soil profile and/or shallow flooding throughout the majority of the growing season as evidenced either by soil characteristics or the presence of sufficient wetland indicator species.  After three growing seasons, the total ground cover contributed by all grass, forb, and shrub species (including willow cuttings) present in the wetland mitigation area (as identified via a point intercept method of measurement) is equal to or greater than 80 percent, on average  Wetland species (FAC, FACW, and OBL) in the created wetland area are dominant on site (51+ percent relative cover) as compared to upland (FACU and UPL) species. The percent of open water occurring over the surface of the mitigation basin will be considered a “null set” when calculating percent herbaceous ground cover, so long as such surface water does not indicate the formation of an "open water" system.  There is no evidence of erosion detrimental to vegetation establishment or site stability.  90 percent of the original numbers of shrubs and trees planted on the site are present after 3 years. In the case of shrubs and trees, volunteer plants will be included in the tally so long as they provide a commensurate habitat value.  Weed species do not exceed 10 percent, on average, of the total ground cover across the mitigation/buffer area as determined by herbaceous transect analysis. 5.5.4 Annual Reporting An annual site assessment report will be submitted to the City of Fort Collins in a report on or about December 31. Information and showings to be submitted with each annual quantitative monitoring report will include a project location map, a discussion of the conditions of the mitigation site and maintenance, including plantings, that have been completed, a summary of the data collected during monitoring as described in Section 5.5.2, a list of all species observed within the mitigation area, copies of all data sheets completed in the field, and a continuation of the photographic record submitted with the first annual report. As appropriate, recommendations will be made with respect to the continued maintenance and monitoring of the mitigation area. 13 6.0 LITERATURE CITED Cedar Creek Associates, Inc. 2013. Environmental Characterization Study Report for the Capstone Cottages Project Site. Letter report to John Acken, Capstone Collegiate Communities from M. Phelan, Cedar Creek. September 3, 2013. Cedar Creek Associates, Inc. 2014. Capstone Project Wetland Delineation Letter Report. Letter report to Terry McKee, U.S. Army Corps of Engineers from S. Long. February 18, 2014. Cedar Creek Associates, Inc. 2015. Surface Water Calculations. Letter communication with Ms. Stephanie Blochowiak, City of Fort Collins Planning Services. March 10, 2015. City of Fort Collins. 2011. City of Fort Collins Comprehensive Plan. February 15, 2011. Accessed at: http://www.fcgov.com/planfortcollins/pdf/cityplan.pdf. Accessed on April 7, 2016. Colorado Parks and Wildlife (CPW). 2016. Threatened and Endangered Species List. Accessed at: http://cpw.state.co.us/learn/Pages/SOC-ThreatenedEndangeredList.aspx. Accessed on; April 7, 2016. NRCS. 1980. Soil Survey of Larimer County Area, Colorado. United States Department of Agriculture. Natural Resource Conservation Service. U. S. Government Printing Office. Washington D.C. 173 pp. + maps. Terracon Consultants, Inc. 2014a. Geotechnical Engineering Report –Capstone Cottages of Fort Collins. Terracon Consultants, Inc. Fort Collins, Colorado. 22 pp. + appendices. U.S. Army Corps of Engineers (USACE). 1987. Wetlands Delineation Manual. Wetlands Research Program Technical Report Y-87-1 (on-line edition). January 1987 - Final Report. USACE. 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (Version 2.0). ERDC/EL TR-10-3. May 2010. U.S. Fish and Wildlife Service (USFWS). 2016. IPaC Trust Resources Report. Accessed at: https://ecos.fws.gov/ipac/project/ XONHW-6QEDV-AARER-2SOAN-YKB3Y4. Accessed on: April 6, 2016. APPENDIX A: FIGURES APPENDIX B: TABLES TABLE 1: SUMMARY OF PERTINENT VEGETATED WETLAND CHARACTERISTICS CAPSTONE COTTAGES PROJECT (No Other Waters of the U. S. Were Observed on Site) Feature Name Cowardin Classification Dominant Species1 Acreage Hydrologic Connection Sample Points/Photos W-1 Borrow Ditch PEM1B Apca, Tyla, Caem 0.18 None observed CC-1/P-1 W-2 Depression PEM1Y Juar 0.02 None observed CC-5/P-2 W-3 Shallow Drainage PFO/ PEM1Y Pode, Apca, Juco 0.02 None observed CC-7/P-3 TOTAL 0.22 1Apca = Apocynum cannabinum (common dogbane) Tyla = Typha latifolia (broadleaf cattail) Caem = Carex emoryi (Emory’s sedge) Juco = Juncus compressus (roundfruit rush) Pode = Populus deltoides (eastern cottonwood) Juar = Juncus articutus (balticus) (arctic rush) CAPSTONE COTTAGES PROJECT EXISTING WETLANDS W-1, W-2, AND W-3 Wetland Functions and Values Analysis Fieldwork Conducted April 4, 2016 A formal functions and values analysis was completed for wetlands located on the site by Cedar Creek on April 4, 2016. A wetland delineation had been previously completed on the site in August 2014 and identified 3 wetland locations on the property. This information was used to assess the uniqueness of the project wetlands, if any, with respect to the surrounding locale. The fieldwork was completed by traversing the project wetlands and the adjacent uplands and judging the potential of the project wetlands to provide a variety of wetland and wildlife functions. In assessing the potential to provide these functions, the field team considered the location and size of the project wetland; its uniqueness within the region; existing surficial conditions; vegetation communities, diversity and vegetation productivity; hydrologic condition and potential; and any wildlife observations. The team then considered the observations made and “scored” the project wetland functions from 1 (low value) to 4 (high value). The values were all tallied and averaged to generate an overall value for wetland and wildlife functions and the table included below was produced. A “not applicable” (NA) score was also applied where appropriate. From this functional analysis, the overall value of the project wetlands was determined. Wetland Function Ratings All 3 project wetlands score moderately well in terms of high biomass production. While much of the biomass is not suitable as fodder or food for wild or domesticated animals, the sites do provide a good level of soil stabilization, as no soil erosion was noted anywhere within the wetland boundaries. All sites rate good with respect to soil stabilization. W-1 rates well on bank erosion control and nutrient cycling due to the ditch topography. Overall, wetland functions were identified as low for all sites. Wildlife Function Ratings Wildlife function ratings for all three wetlands were low, mainly due to the lack of water and vegetation diversity. W-1 provides some cover availability, and roosting/nesting sites were accorded that project wetland. Use of the wetlands by passerine bird species, including mourning doves and red-winged blackbirds, is likely. It is believed that use by other wildlife species is limited. Project Wetland Value Rating The three wetlands at the Capstone property are neither large, notably diverse, do not have an open water component, and lie isolated from other wetlands and open water bodies. They do exhibit good biomass production and erosion control. The established cattail community in W-1 does provide wildlife cover for several species that is somewhat lacking in the local area. None of the sites exhibit suitable habitat for either the Ute ladies’-tresses orchid or the Preble’s meadow jumping mouse given the vegetation communities and hydrologic regime observed. Therefore, all three project wetlands are accorded a Low value, overall. TABLE 2: WETLAND FUNCTIONS AND VALUES EVALUATION CAPSTONE COTTAGES PROJECT SURVEY (Conducted April 4, 2016) (Averaged Scoring Protocol: 1 through 4; 1 = Low Value, 4 = High Value, NA = Not Applicable) Wetland Functions W-1 W-2 W-3 Aquatic diversity (no open water at time of survey) NA NA NA Sediment retention removal (sediment remains on site given topography at W-1) 1 NA NA Flood Control (minimal given depression topography for W-2 and W-3, W-1 collects road runoff) 2.5 NA NA Water quality improvement (water remains on site and is not discharged at W-1) 1 NA NA High biomass production (disregarding wildlife or grazing animal usage at all 3 sites) 1 3 3 Nutrient cycling (removes nitrogen from groundwater, possibly heavy metals at W-1) 2 NA NA Groundwater recharge (ditch topography serves to retain water) 1 NA NA Groundwater discharge (limited recharge to groundwater) NA NA NA Soil stabilization (no erosion observed at all 3 sites) 3 3 3 Bank stabilization (no banks surrounding depressions at W-2 and W-3, banks stable at W-1) 3 NA NA TOTAL AND AVERAGED VALUE (DIVIDED BY 10) 14.5/1.5 6/0.6 6/0.6 Wildlife Functions W-1 W-2 W-3 Refuge for T&E species (habitat for commonly considered species not present at any site) NA NA NA Wildlife habitat (poor quality cover and diversity at all 3 sites, slightly better at W-1) 1.5 1 1 Habitat diversity (limited variety of vegetation species present given the limited hydrologic diversity; few shrub and tree species present at all sites) 1 1 1 Water availability (no open water observed during survey at W-2 and W-3, <1 “ at W-1) 0.5 NA NA Forage availability (limited due to cattails at W-1, more grass and tree species at W-2 and W-3) NA 0.5 0.5 Cover availability (cover for specific passerine species not otherwise present in immediate area) 2.5 1 1 Roosting, nesting sites (cover for specific passerine species not otherwise present in immediate area) 1 1 1 Refuge for sensitive species (dominant/ subdominant wetland plant species in all wetlands are common to this area) NA NA NA TOTAL AND AVERAGE VALUE (DIVIDED BY 8) 6.5/0.8 4.5/0.6 4.5/0.6 TABLE 3: WETLAND POND BASIN SEED MIX (Subject to modification depending upon depth of constructed basin to groundwater) Preferred Rate Lbs./Acre PLS Species Varieties Planted (Broadcast) Seeded/Acre Alkali sacaton NA 1.00 1,175,000 Sporobolus airoides Bluejoint reedgrass Sourdough 0.50 1,135,000 Calamagrostis canadensis Prairie cordgrass NA 1.00 197,000 Spartina pectinata Switchgrass Grenville, Trailblazer 3.00 1,167,000 Panicum virgatum Western wheatgrass Arriba, Barton 4.00 504,000 Pascopyrum smithii Nebraska sedge NA 1.00 534,100 Carex nebrascensis Totals = 9.5 4,712,100 (~108 seeds/ sq. ft.) Note 1: Assume soils moist to saturated, but not continually flooded, throughout the major portion of the growing season. Note 2: Due to varying seed size, seed should be planted shallowly with limited seedbed treatment following seeding. TABLE 4: STABILIZATION MIXTURE + ESTHETICS AND WILDLIFE Preferred Rate Lbs./Acre Species Variety(s) Planted (Drilled) PLS Seeded/Acre Green needlegrass Cucharas, Lodorm 2.00 362,000 Nassella viridula Slender wheatgrass Primar, Revenue 3.00 480,000 Elymus trachycaulus Thickspike wheatgrass Critana 4.00 774,000 Elymus lanceolatus Western wheatgrass Arriba, Barton 5.00 630,000 Pascopyrum smithii Lewis flax Appar 1.00 285,000 Adenolinum lewisii (perenne) Upright prairie coneflower None 0.25 225,000 Ratibida columnifera Four-wing saltbush (see Notes ) Wytana 4.00 208,000 Atriplex canescens Totals = 19.25 2,964,000 (~68 seeds/sq. ft.) Note 1: Shrub planting rate is based on a broadcast application. Note 2: This seed mixture will be planted at twice the rate (excepting four-wing saltbush) shown when broadcast planting methods are used. TABLE 5: WETLAND FUNCTIONS AND VALUES EVALUATION CAPSTONE PROJECT CREATED WETLAND PROJECTION Conducted: April 8, 2016 (Scoring Protocol: 1 through 4; 1 = Low Value, 4 = High Value) Wetland Functions Aquatic diversity (will include both open water and wetlands) 2 Sediment retention removal (will capture stormwater runoff sediments) 3 Flood Control (wetland area will also serve as a detention pond) 4 Water quality improvement (will hold water on site, allow plants to fix metals) 2 High biomass production (numerous species to be planted) 3 Nutrient cycling (removes possible heavy metals from runoff) 2.5 Groundwater recharge (depression will retain water, some will percolate to groundwater) 2.5 Groundwater discharge (groundwater likely remains as such, no discharge) NA Soil stabilization (controls potential flooding erosion) 3 Bank stabilization (minimal banks and therefore minimal stabilization required)) 2 TOTAL AND AVERAGED VALUE (DIVIDED BY 10) 24/2.4 Wildlife Functions Refuge for T&E species (not creating habitat NA Wildlife habitat (shrubs and trees) 3 Habitat diversity 3 Water availability (stormwater loss to evaporation and intermittent flooding) 2.5 Forage availability NA Cover availability (not thick) 2 Roosting, nesting sites (cars and people) 2 Refuge for sensitive species NA TOTAL AND AVERAGED VALUE (DIVIDED BY 8) 12.5/1.5 CAPSTONE COTTAGES 4/5/2016 LANDSCAPE MATERIAL ITEM QUANTITY UNIT SIZE/CONDITION DECIDUOUS CANOPY TREES 16 2" CAL. B&B EVERGREEN TREES 28 6' HT. B&B DECIDUOUS SHRUBS 150 5 GAL. CONT. PERENNIALS 16 1 GAL. CONT. UPLAND SEEDED AREA (TEMP-IRRIGATED) 45,193 SF DETENTION BASIN SEED MIX WETLAND SEEDED AREA (NON-IRRIGATED) 11,000 SF WETLAND SEED MIX SHREDDED WOOD MULCH 1,730 SF 3" DEPTH COBBLE MULCH 91 SF 4-6" DEPTH BUFF SANDSTONE BOULDERS 168 TONS 42" HT. MIN. -160#/CF. COTTONWOOD TRUNK LOCATES 2 EA ON-SITE 12" TOPSOIL - WETLAND PLANTING AREA 11,000 SF IRRIGATED AREA -TEMPORARY IRR. TO ESTABLISHMENT 43,463 SF IRRIGATED AREA -DRIP TREES & SHRUBS 1,730 SF NATURAL HABITAT BUFFER ZONE LANDSCAPE MATERIAL QUANTITIES APPENDIX C: DOCUMENTS AND COMMUNICATIONS September 3, 2013 Mr. John Acken Capstone Collegiate Communities 431 Office Park Drive Birmingham, Alabama 35223 RE: Environmental Characterization Study Report for the Capstone Cottages Project Site This letter report documents the evaluation of habitat conditions on the proposed Capstone Cottages 21- acre development parcel in Fort Collins, Colorado. The proposed development site is located in Fort Collins, Larimer County, Colorado in the Northwest 1/4 of Section 7 (T. 7 N. R. 68 W.) at the northeast corner of the intersection of Lemay Avenue and Lincoln Avenue. Existing land uses within the property consist entirely of a cleared, abandoned farmstead area and fallow, non-native grassland pasture. Topography of the site is essentially level with a drainage gradient to the southeast. An environmental and wetland survey of the property was completed on August 23, 2013. The wetland delineation and sampling work for the wetlands within the project area were completed using the methods and techniques specified for "routine on-site delineations" in the publication, Corps of Engineers Wetlands Delineation Manual (USACOE 1987), and supplemented by the document, Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Great Plains Region, Version 2.0 (USACOE 2010) (see attached draft wetland report). The following provides the ecological characterization checklist of information required by Fort Collins Land Use Code under 3.4.1 (D) (1) items (a) through (k). (a) & (i) The majority of the project area supports non-native grassland. A previous ECSR report prepared by Cedar Creek for a portion of this property in August 2005 documented the presence of an abandoned farmstead on the property as well as grazing use by horses. This habitat has been converted to non-native grassland to support livestock grazing in the past (see attached Figure 1). Non-native grassland is dominated primarily by smooth brome (Bromus inermis)1 with lesser amounts of Kentucky bluegrass (Poa pratensis), tall fescue (Festuca arundinacea), slender wheatgrass (Elymus trachycaulus), crested wheatgrass (Agropyron cristatum), western wheatgrass (Pascopyrom smithii), and cheatgrass (Bromus tectorum). Alfalfa (Medicago sativa) is also present as a sub-dominant species in non-native grassland over portions of the eastern half of the property. Western wheatgrass and slender wheatgrass are the only native species among these. Total vegetation cover ranges from 10 percent, in the overgrazed prairie dog town area, to nearly 100 percent in the weed dominated former farmstead area. The former farmstead area has been cleared of all structures and is now dominated by tall, dense stands of kochia (Bassia scoparia) and carelessweed (Cyclachaena xanthiifolia). Vegetation cover in the prairie dog town at the north edge of the property is sparse as a result of prairie dog overgrazing and is dominated primarily by weedy species including field bindweed (Convolvulus arvensis), cheatgrass, Russian thistle (Salsola tragus), and pitseed goosefoot (Chenopodium berlandieri) with minor amounts of smooth brome. Woody vegetation is restricted primarily to small (less than 6 inches in diameter) Russian olive (Elaeagnus angustifolia), eastern cottonwood (Populus deltoides), and peachleaf willow trees (see attached Figure 1). Lance-leaf cottonwoods at the southwest property corner are the only potentially significant trees located on the property. 1 Scientific nomenclature follows USDA, NRCS Plants Database. Available online at: http://plants.usda.gov/java/ Acken, J September 3, 2013 Page 2 of 4 Aside from potentially significant trees and small wetland areas (see following Section b), the project area does not support any native vegetation or other unique habitat features, and no features of ecological value exist within 500 feet of the development site. Habitat value and wildlife use of non-native grassland/pasture and weedy habitats is limited by the general lack of woody vegetation, dominance by non-native grass species, and surrounding development and roads. Mice, voles, black-tailed prairie dog, and pocket gopher are the principal species likely to establish resident mammal populations in non-native grassland. Songbirds such as western meadowlark, Brewer’s blackbird, common grackle, and black- billed magpie may also occasionally use non-native grassland/pasture habitat. Trees on the property may be used for perching, nesting, and foraging by urban-adapted songbirds, and Canada geese grass may occasionally graze the non-native grassland areas. No songbird nests were located in trees on the project area during the August 23, 2013 survey. (b) According to the Soil Conservation Service’s (SCS) Soil Survey of Larimer County Area, Colorado project area soils are Loveland clay loam; Nunn clay loam, wet; and Caruso clay loam. Nunn clay loam, wet, is not a hydric (wetland) soil, but both Loveland clay loam and Caruso clay loam are classified as hydric. These two hydric soils cover about 70 percent of the property in the south half and northeast quarter. Although hydric soils are prevalent, only two wetland areas were delineated on the project area. They are located near the southeast corner of the property and near the southeast corner along the Lincoln Avenue borrow/drainage ditch (see Figure 1). A draft wetland report has been prepared and will be submitted to the COE for these wetlands once the boundaries are surveyed and their sizes (acres) are determined. The southeast corner wetlands are isolated and will likely not be classified as jurisdictional by the COE. A previous approved jurisdictional determination issued by the COE for Larimer County’s Lincoln Avenue/Link Lane intersection upgrade project determined that the wetlands and waters in the Lincoln Avenue ditch are non-jurisdictional (see COE File No. 200580352). A copy of the COE response letter for the Capstone Cottages report will be provided to the City once it is received. The borrow ditch wetland along Lincoln Avenue is characterized by a vegetation community dominated by cattails (Typha latifolia), dogbane (Apocynum cannabinum), and Emory sedge (Carex emoryi). The small depression wetlands in the southeast property corner are dominated by Baltic rush eastern cottonwood (Populus deltoides), dogbane, and round-fruit rush (Juncus compressus) with upland plant species making up a small percentage of the absolute cover. (c) The property does not provide any unobstructed views of significant landscape or topographical features. (d) Because of past farmstead development and pasture conversion of the property, the only native woody vegetation located on the property are few young (less than 6 inches in diameter) eastern cottonwood (Populus deltoides) trees, associated with the wetland area, and lance-leaf cottonwood (Populus acuminata) trees the western property boundary (see attached Figure 2). (e) There are no perennial water features or natural drainages on or near the property. (f) The project area was evaluated with regards to potential habitat for state and federal listed threatened and endangered species, and it was determined that no suitable habitat exists for Preble’s meadow jumping mouse (Zapus hudsonius preblei), Ute ladies’-tresses orchid (Spriranthes diluvialis), or Colorado butterfly plant (Gaura neomexicana coloradenis). A portion of a black-tailed prairie dog town extends into the northern portion of the project area. Little active prairie dog activity was noted at the time of the field survey except in the northeast portion of the town where prairie dog activity was observed. The prairie dog town is well under 50 acres acres, and Section 3.4.1 of the Land Use Code provides for no protection of prairie dog towns less than 50 acres in size. Section 3.4.1 (N)(6) does stipulate that before the commencement of grading or other construction on the development site, any prairie dogs inhabiting portions of the site within the LOD shall be relocated or eradicated by the developer using city-approved Acken, J September 3, 2013 Page 3 of 4 methods as set forth in Chapter 4 of the City Code and, when applicable, using methods reviewed and approved by the Colorado Division of Wildlife. (g) Because of past cultivation of non-native grass pasture over most of the property, there are no special habitat features present except for the larger trees noted on Figure and the small cluster of isolated wetlands near the southeast property corner (see Section b). (h) There are no suitable wildlife movement corridors on or near the property. (j) Because of the lack of natural habitat features on the project area, there are only two issues regarding the timing of property development and ecological features or wildlife use of the project area. If the development proposal includes removal of any trees on the property, tree removal during the songbird- nesting season could result in the loss or abandonment of a nest and would be in violation of the federal Migratory Bird Treaty Act. Prairie dogs in the proposed offsite detention pond area would need to be removed as indicated in paragraph (f) prior to the initiation of grading and construction activities. (k) Wetlands and lance-leaf cottonwood (Populus acuminata) trees 6 inches or greater in diameter on the property may require protection as per the City’s Land Use Code. Trees will need to be evaluated by the City Forester or a private arborist to determine which trees may be classified as significant. Loss of trees classified as significant would need to be mitigated with replacement trees as per Section 3.2.1 (F) of the Code. Most wetlands require protection, and based on Section 3.4.1(E)(1)(d) of the Land Use Code, the small (less than 0.3-acre) wetlands on the property would require a 50-foot non-development setback. Because tree removal during the songbird nesting season could result in the loss or abandonment of a nest, it is recommended that tree removal or pruning occur outside of the songbird nesting season (April 1 – July 31), or trees be surveyed to ensure lack of nesting prior to removal during the nesting season. This mitigation recommendation would preclude the possible incidental take or disturbance of active songbird nests. Prairie dogs in the proposed offsite detention pond area would need to be removed as indicated in paragraph (f) prior to the initiation of construction activities. John, this concludes my environmental assessment of the Capstone Villages project area. Please let me know if you have any questions. Sincerely, INC. T. Michael Phelan Principal Draft Wetland Report - the Final Report will be submitted to the ACOE once the flagged wetland boundaries are surveyed Mr. Terry McKee No Date Department of the Army Corps of Engineers, Omaha District Denver Regulatory Office 9307 South Wadsworth Blvd Littleton, Colorado 80128-6901 Re: Waters of the U. S. Delineation for the Capstone Cottages Project (No Corps Number Assigned to Date) Dear Mr. McKee: At the direction of Capstone Collegiate Communities, Cedar Creek Associates, Inc. completed a wetland and Other Waters of the U. S. delineation for the Capstone Cottages Project within the city limits of Fort Collins, Colorado. The project area is situated along Lincoln Avenue in Section 7, Township 7 North, Range 68 West (N 40.58982, W. -105.05337, NAD 83). The objective of this work is to develop the project area to provide campus housing opportunities for students. The objective of the delineation work is to fulfill the requirements of Section 404 of the Clean Water Act regarding the delineation of wetlands and other Waters of the U. S. prior to potential development activities. The vicinity map included with this submittal depicts the road network providing access to the site. The main project contact is: Mr. John Acken Capstone Collegiate Communities 431 Office Park Drive Birmingham, Alabama 35223 Phone: 205.414.6400 email: jacken@capstonemail.com Field Delineation Methodology Wetland delineation and sampling work for the wetlands and open water features within the project area was completed on August 23, 2013 using the methods and techniques specified for "routine on-site delineations" in the publication Corps of Engineers Wetlands Delineation Manual (Department of the Army 1987), supplemented by the document Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys and Coast Region (Department of the Army 2010). The project area was evaluated and potential wetland, transition zone, and upland vegetation communities were identified. Using the three-parameter approach, via test hole characteristics, the wetland/upland boundaries were flagged. Formal sample point locations were then identified. Sample point locations were selected to represent typical wetland, upland and transitional conditions on site. At each sample point, percent total cover of dominant plant species was estimated. Species were then classed as OBL (obligate wetland species), FACW (facultative wetland species), FAC (facultative species), FACU (facultative upland species) or UPL (upland species). Wetland soil indicators potentially included the presence of a histic epipedon, thick dark surface, redox features, gleying, depleted or reduced profile conditions, and high organic matter content and/or a stripped matrix in sandy soils. Potential wetland hydrology indicators included geomorphic position, presence of standing water and/or saturated soil profile conditions, drainage patterns, sediment deposits, water marks, and oxidized root channels in the upper 12 inches of the soil profile. Sample holes were dug to a depth of 16 inches unless 3 a restrictive layer was encountered. Formal field data sheets were completed for each sample point evaluated (CC-1 through CC-7). Wetland / upland boundaries and sample points were flagged with pink fluorescent tape and numbered orange pin flags tied with pink fluorescent tape, respectively, for subsequent surveying work. No open water features were encountered Adjunct test holes were also dug, where appropriate, to gain additional vegetation, soil, and hydrologic information used to aid in the characterization of wetlands, uplands, and transition zones. Data sheets were not completed for test holes. The results of the field delineation are summarized in the following paragraphs. Copies of the data sheets completed during the survey along with a delineation map and photos are included with this report to aid the Corps in completing an evaluation of this project site. Tables T-1 and T-2 are presented to support the report text. Project Area Characteristics Results – Uplands and Upland Transition Sites The project area was once a farmstead. At this time, the buildings have been removed and the fields have reverted primarily to a mixture of localized upland vegetation communities occurring across a nearly level topography with a few shallow, dry, drainage inclusions. A prairie dog colony occurs over a significant portion of the project area. Herbaceous shrub, and tree species have become established on site and are variably dominant depending upon the vegetation community under consideration. Native, introduced, and weedy species are represented. Dominant and other notable species include cheatgrass (Bromus tectorum - UPL), western wheatgrass (Pascopyrum smithii – FACU), slender wheatgrass – Elymus trachycaulus - FACU) smooth brome (Bromopsis inermis – UPL), tall fescue (Festuca arundinacea – FACU), kochia (Bassia sieversiana - FACU), alfalfa (Medicago sativa – UPL), Siberian elm (Ulmus pumila – UPL). Sample point CC-2 (paired with CC-1) and CC-6 (paired with CC-7) were selected to characterize upland wetland borders. Dominant species included western wheatgrass and smooth brome. No wetland soil or hydrology indicators were observed. Two upland transition sites were also mapped and described in the project area indicating, along with the wetland descriptions below, a project site that is believed to be drying. Sample point CC-3 is dominated by marsh elder (Cyclathaena xanthiifolia – FAC) and kochia while sample point CC-4 is dominated by Baltic rush (Juncus balticus – FACW). While hydric-classed species are dominant, all or in part at these sample points, no evidence of wetland soils or hydrology was observed. Therefore, these vegetation communities are considered to be upland transition sites. Results - Vegetated Wetlands Three types of wetlands, W-1, W-2, and W-3, were delineated within the project area boundaries and are characterized below. It may be noted that while hydric soils were present at the sample points selected to describe these wetlands, the wetland indicators for wetland types W-2 and W-3 were weak indicating a drying trend across this project site. W-1: Borrow Ditch (PEM1B; Photo P-1) This wetland is typified by a vegetation community dominated by cattails (Typha latifolia – OBL, dogbane (Apocynum cannabinum– FAC), and Emory sedge (Carex emoryi – OBL). The soil at sample point CC-1 has matrix chroma colors and mottling sufficient to qualify as a redox dark surface. Wetland hydrology indicators included saturation, drainage pattern, and geomorphic position. (This borrow ditch was classed as non-jurisdictional by the Corps as a result of a previous mapping effort.) W-2: Depression (PEM1Y; Photo 2) Sample point CC-5 was selected to characterize a group of small herbaceous wetlands located along the eastern project area border. The vegetation community is dominated by Baltic rush with upland plant 4 species making up a small percentage of the absolute cover. The matrix and mottle content of the matrix to a depth of 16 inches qualifies for a redox dark surface classification. Wetland hydrology indicators include a suitable drainage pattern and geomorphic position. Given the depression form, a shallow depth to a high water table is assumed based on the NRCS soils mapping. W-3: Shallow drainage (PFO1/PEMY1; Photo 3) This wetland has become established in a narrow, comparatively short and shallow drainage along the eastern project area border. Wetland W-3 is characterized by dominant species in the herbaceous, shrub, and tree strata and is classed as PFO/PEM1Y to account for this diversity (sample point CC-7). The dominant species are plains cottonwood (Populus deltoides – FAC), dogbane, and round-fruit rush (Juncus compressus – FACW). A redox dark surface wetland indicator was noted for the soil matrix and wetland hydrology indicators included water marks, drainage patterns, and a geomorphic position. I trust this letter report will fulfill your needs with respect to wetland and other Waters of the U. S. delineation requirements. We request that you evaluate our delineation report with a view to considering it accurate and complete. Please call (970-229-9278) if you have any questions regarding the delineation work completed for this project. Sincerely, CEDAR CREEK ASSOCIATES, INC. Stephen G. Long Principal 5 TABLE 1: SUMMARY OF SAMPLE POINT CHARACTERISTICS Sample Point # Dominant Species Hydric Soil Indicators Primary & Secondary Wetland Hydrology Indicator(s) COE Wetland CC-1 Apca, Tyla, Caem F6 A3, B10, D-2 PEM1B CC-2 Chna, Brin None None No CC-3 Ivxa, Basi None None No CC-4 Juba None None No CC-5 Juco F6 A2 (seasonal) B10, D2 PEM1Y CC-6 Pasm None None No CC-7 Pode, Apca, Juco F6 B1, B10, D2 PFO1/PEM1Y TABLE 2: SUMMARY OF PERTINENT VEGETATED WETLAND CHARACTERISTICS (No Other Waters of the U. S. Were Observed on Site) Feature Name Cowardin Classification Dominant Species Acreage (ac.) Hydrologic Connection Sample Points/ Photos Vegetated Wetlands W-1 Borrow Ditch PEM1B Apca, Tyla, Caem TBD None observed CC-1/P-1 W-2 Depression PEM1Y Juco TBD None observed CC-5/P-2 W-3 Shallow Drainage PFO1/PEM1Y Pode, Apca, Juco TBD None observed CC-7/P-3 6 PHOTO APPENDIX: PHOTOS TAKEN AUGUST 23, 2013 AT THE CAPSTONE COTTAGES PROJECT SITE 7 P-1: W-1 – Borrow Ditch P-2: W-2 – Depression 8 P-3: W-3 – Shallow Drainage 1 Mr. Terry McKee February 18, 2014 Department of the Army Corps of Engineers, Omaha District Denver Regulatory Office 9307 South Wadsworth Blvd Littleton, Colorado 80128-6901 Re: Waters of the U. S. Delineation for the Capstone Cottages Project (No Corps Number Assigned to Date) Dear Mr. McKee: At the direction of Capstone Collegiate Communities, Cedar Creek Associates, Inc. completed a wetland and Other Waters of the U. S. delineation for the Capstone Cottages Project within the city limits of Fort Collins, Colorado. The project area is situated along Lincoln Avenue in Section 7, Township 7 North, Range 68 West (N 40.58982, W. -105.05337, NAD 83). The primary objective of this work is to develop the project area to provide campus housing opportunities for students. The objective of the delineation work is to fulfill the requirements of Section 404 of the Clean Water Act regarding the delineation of wetlands and other Waters of the U. S. prior to potential development activities. The vicinity map included with this submittal depicts the road network providing access to the site. The main project contacts are: Mr. John Acken Capstone Collegiate Communities 431 Office Park Drive Birmingham, Alabama 35223 Phone: 205.414.6400 email: jacken@capstonemail.com Ms. Linda Ripley Ripley Design, Inc. 401 West Mountain Ave., Suite 100 Fort Collins, Colorado 80521-2604 Phone: 970-224-5828 Email: linda.ripley@ripleydesign.com Field Delineation Methodology Wetland delineation and sampling work for the wetlands and open water features within the project area was completed on August 23, 2013 using the methods and techniques specified for "routine on-site delineations" in the publication Corps of Engineers Wetlands Delineation Manual (Department of the Army 1987), supplemented by the document Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Great Plains Region - Version 2.0 (Department of the Army 2010). The project area was evaluated and potential wetland, transition zone, and upland vegetation communities were identified. Using the three-parameter approach, via test hole characteristics, the wetland/upland boundaries were flagged. Formal sample point locations were then identified. Sample point locations were selected to represent typical wetland, upland and transitional conditions on site. At each sample point, percent total cover of dominant plant species was estimated. Species were then classed as OBL (obligate wetland species), FACW (facultative wetland species), FAC (facultative species), FACU (facultative upland species) or UPL (upland species). Wetland soil indicators potentially included the presence of a histic epipedon, thick dark surface, redox features, gleying, depleted or reduced profile conditions, and high organic matter content and/or a stripped matrix in sandy soils. 2 Potential wetland hydrology indicators included geomorphic position, presence of standing water and/or saturated soil profile conditions, drainage patterns, sediment deposits, water marks, and oxidized root channels in the upper 12 inches of the soil profile. Sample holes were dug to a depth of 16 inches unless a restrictive layer was encountered. Formal field data sheets were completed for each sample point evaluated (CC-1 through CC-7). Wetland / upland boundaries and sample points were flagged with pink fluorescent tape and numbered orange pin flags tied with pink fluorescent tape, respectively, for subsequent surveying work. No open water features were encountered Adjunct test holes were also dug, where appropriate, to gain additional vegetation, soil, and hydrologic information used to aid in the characterization of wetlands, uplands, and transition zones. Data sheets were not completed for test holes. The wetland delineation wetland/upland borders and sample pit sites were surveyed in on February 18, 2014. The results of the field delineation are summarized in the following paragraphs. Copies of the data sheets completed during the survey along with a delineation map and photos are included with this report to aid the Corps in completing an evaluation of this project site. Tables T-1 and T-2 are presented to support the report text. Project Area Characteristics Results – Uplands and Upland Transition Sites The project area was once a farmstead. At this time, the buildings have been removed and the fields have reverted primarily to a mixture of localized upland vegetation communities occurring across a nearly level topography with a few shallow, dry, drainage inclusions. A prairie dog colony occurs over a significant portion of the project area. Herbaceous shrub, and tree species have become established on site and are variably dominant depending upon the vegetation community under consideration. Native, introduced, and weedy species are represented. Dominant and other notable species include cheatgrass (Bromus tectorum - UPL), western wheatgrass (Pascopyrum smithii – FACU), slender wheatgrass – Elymus trachycaulus - FACU) smooth brome (Bromopsis inermis – UPL), tall fescue (Festuca arundinacea – FACU), kochia (Bassia sieversiana - FACU), alfalfa (Medicago sativa – UPL), Siberian elm (Ulmus pumila – UPL). Sample point CC-2 (paired with CC-1) and CC-6 (paired with CC-7) were selected to characterize upland wetland borders. Dominant species included western wheatgrass and smooth brome. No wetland soil or hydrology indicators were observed. Two upland transition sites were also mapped and described in the project area indicating, along with the wetland descriptions below, a project site that is believed to be drying. Sample point CC-3 is dominated by marsh elder (Cyclathaena xanthiifolia – FAC) and kochia while sample point CC-4 is dominated by Baltic rush (Juncus balticus – FACW). While hydric-classed species are dominant, all or in part at these sample points, no evidence of wetland soils or hydrology was observed. Therefore, these vegetation communities are considered to be upland transition sites. Results - Vegetated Wetlands Three types of wetlands, W-1, W-2, and W-3, were delineated within the project area boundaries and are characterized below. It may be noted that while hydric soils were present at the sample points selected to describe these wetlands, the wetland indicators for wetland types W-2 and W-3 were weak indicating a drying trend across this project site. W-1: Borrow Ditch (PEM1B; Photo P-1) This wetland is typified by a vegetation community dominated by cattails (Tyla latifolia – OBL, dogbane (Apocynum cannabinum– FAC), and Emory sedge (Carex emoryi – OBL). The soil at sample point CC-1 has matrix chroma colors and mottling sufficient to qualify as a redox dark surface. Wetland hydrology indicators included saturation, drainage pattern, and geomorphic position. (This borrow ditch was classed as non-jurisdictional by the Corps as a result of a previous mapping effort.) 3 W-2: Depression (PEM1Y; Photo 2) Sample point CC-5 was selected to characterize a group of small herbaceous wetlands located along the eastern project area border. The vegetation community is dominated by Baltic rush with upland plant species making up a small percentage of the absolute cover. The matrix and mottle content of the matrix to a depth of 16 inches qualifies for a redox dark surface classification. Wetland hydrology indicators include a suitable drainage pattern and geomorphic position. Given the depression form, a shallow depth to a high water table is assumed based on the NRCS soils mapping. W-3: Shallow drainage (PFO1/PEMY1; Photo 3) This wetland has become established in a narrow, comparatively short and shallow drainage along the eastern project area border. Wetland W-3 is characterized by dominant species in the herbaceous, shrub, and tree strata and is classed as PFO/PEM1Y to account for this diversity (sample point CC-7). The dominant species are plains cottonwood (Populus deltoides – FAC), dogbane, and round-fruit rush (Juncus compressus – FACW). A redox dark surface wetland indicator was noted for the soil matrix and wetland hydrology indicators included water marks, drainage patterns, and a geomorphic position. I trust this letter report will fulfill your needs with respect to wetland and other Waters of the U. S. delineation requirements. We request that you evaluate our delineation report with a view to considering it accurate and complete. Please call (970-229-9278) if you have any questions regarding the delineation work completed for this project. Sincerely, CEDAR CREEK ASSOCIATES , INC. Stephen G. Long Principal 4 TABLE 1: SUMMARY OF SAMPLE POINT CHARACTERISTICS Sample Dominant Hydric Primary & Secondary Wetland COE Point # Species Soil Indicator(s) Hydrology Indicator(s) Wetland CC-1 Apca, Tyla, Caem F6 A3, B10, D-2 PEM1B CC-2 Chna, Brin None None No CC-3 Ivxa, Basi None None No CC-4 Juba None None No CC-5 Juco F6 A2 (seasonal) B10, D2 PEM1Y CC-6 Pasm None None No CC-7 Pode, Apca, Juco F6 B1, B10, D2 PFO1/PEM1Y TABLE 2: SUMMARY OF PERTINENT VEGETATED WETLAND CHARACTERISTICS (No Other Waters of the U. S. Were Observed on Site) Cowardin Dominant Acreage Hydrologic Sample Points/ Feature Name Classification Species (ac.) Connection Photos Vegetated Wetlands W-1 Borrow Ditch PEM1B Apca, Tyla, Caem 0.18 None observed CC-1/P-1 W-2 Depression PEM1Y Juco 0.02 None observed CC-5/P-2 W-3 Shallow Drainage PFO1/PEM1Y Pode, Apca, Juco 0.02 None observed CC-7/P-3 Mr. Steve Long Cedar Creek Associates, Inc. 916 Willshire Ave. Fort Collins, CO 80521 DEPARTMENT OF THE ARMY CORPS OF ENGINEERS, OMAHA DISTRICT DENVER REGULATORY OFFICE, 9307 SOUTH WADSWORTH BOULEVARD LITTLETON, COLORADO 80128-6901 February 25, 2014 RE: Wetland Delineation for the Capstone Cottages Project, Wetlands W-1, W-2 and W-3 Corps File No. 200680088 Dear Mr. Long: Mr. Terry McKee ofmy office has reviewed your February 18, 2014 wetland delineation report and map for this project located at 40.58982; -105.05337, Larimer County, Colorado. Mr. McKee considers your wetland report and map for this project accurate and acceptable. If any work associated with this project requires the placement of dredged or fill material, and any excavation associated with a dredged or fill project into wetlands WI, W2 and W-3, this office should be notified by a proponent ofthe project for Department of the Army permits or changes in permit requirements pursuant to Section 404 of the Clean Water Act. Work in wetlands Wl, W2 and W-3 should be identified and shown on a map identifYing the Latitude and Longitude in decimal degrees (example 40.55555; -104.55555) and the dimensions ofwork in wetlands W 1, W2 and W-3. Any loss of an aquatic site may require mitigation. Mitigation requirements will be determined during the Department of the Army permitting review. The Omaha District, Regulatory Branch is committed to providing quality and timely service to our customers. In an effort to improve customer service, please take a moment to complete our Customer Service Survey found on our website at http://per2.nwp.usace.army.mil/survey.html. If you do not have Internet access, you may call and request a paper copy of the survey that you can complete and return to us by mail or fax. (Completing the survey is a voluntary action) If there are any questions call Mr. Terry McKee at (720) 922-3851 and reference Corps No. 200680088. /J?r)rely, {j'!n:U? Chief, Denver Regulatory Office Ms. Stephanie Blochowiak March 10, 2015 Planning Services City of Fort Collins 281 North College Avenue P O Box 580 Fort Collins, Colorado 80522-0580 Ms.: Blochowiak As part of the Capstone Cottages project review process Round Number 2, City staff submitted a letter to Ripley Design, Inc. dated January 16 listing the comments staff had regarding the proposed development project. Comment Number 2, under the Department: Environmental Planning section, requested a letter “verifying that from a hydrologic perspective, but also based on the soils report and any other data, they believe that the current plans should support wetlands in the chosen locations.” This letter report is submitted to address this element of Comment Number 2. Documents and Data Reviewed The material reviewed to develop the following analysis included the following. 1.) The wetland delineation letter report prepared by Cedar Creek Associates, Inc. dated February 18, 2014. The Corps of Engineers deemed this report accurate and acceptable. 2.) Terracon Consultants, Inc. 2014. Geotechnical Engineering Report –Capstone Cottages of Fort Collins. Terracon Consultants, Inc. Fort Collins, Colorado. 22 pp. + appendices. 3.) Letter to Mr. John Acken. Re: Temporary Piezometer Installation and Initial Groundwater Measurements. Personal communication from Bryce C. Reeves. Terracon Consultants, Inc. November 3, 2014. 4.) NRCS. 1980. Soil Survey of Larimer County Area, Colorado. United States Department of Agriculture. Natural Resource Conservation Service. U. S. Government Printing Office. Washington D.C. 173 pp. + maps. 5.) A project map provided by Ripley Design, Inc. depicting the proposed location of the detention pond. 6.) Surface Water Calculations. Personal communication with Aaron Cvar. March 10, 2015 Characteristics of Existing Wetlands W-1, W-2, and W-3 Wetland 1 (0.18 acres) is located in the narrow borrow ditch abutting Lincoln Ave. The vegetation community is dominated by cattails and Emory sedge established in a saturated soil moisture regime. Wetland 2 (0.02 acres) is located in an upland meadow. The wetland plant community is dominated by round-fruit rush. Wetland 3 (0.02 acres), as noted for Wetland 2, is located in an upland meadow adjacent to Wetland 2. The plant community is dominated by round-fruit rush, dogbane and plains cottonwood. Both of these wetlands exhibit drainage patterns and geomorphic positions as their soil wetland hydrology indicators. All three of these wetlands are believed to be isolated and no connection to a Water of the U. S. was noted. This area was mapped by the NRCS as the Loveland clay loam, 1-3 percent slopes. This map unit is classed as having a high seasonal water table of from 1.5 to 2.5 feet deep. The primary functions of Wetland 1 are flood control and soil stabilization. The cattail stand may provide some wildlife habitat, but its location adjacent to the road would severely limit this potential function. The wetland’s size, form and location would also limit its overall value as a wetland habitat component. Wetlands 2 and 3 are notably small and occur immediately west of existing commercial developments. While the tree and shrub features would provide some wildlife habitat, primarily for avian species, the trees and shrubs are few in number given the size of Wetland 3. The function of the herbaceous plant strata, occurring over the major portion of Wetlands 2 and 3, is limited to soil stabilization. Save for the shrub and tree strata, whose functions and value would be well compensated for through landscape plantings, the value of the herbaceous strata of Wetlands 2 and 3 are comparatively low and are synonymous with the surrounding upland meadow in terms of soil stabilization. Pertinent Data Analysis, Summary, and Recommendations The Terracon document reported water depths in bore holes for two drilling projects completed on site. Five borings were completed in October of 2004. Borehole #4, closest to the proposed detention pond (aka mitigation site) location, exhibited a depth to the water table of 3.0 feet immediately after drilling. Eleven borings were completed on February 12 and 13 and March 1 of 2014. Three borings, including numbers 13, 14 and 16, were closest in proximity to the proposed pond location. Depths to groundwater in these wells at the time of drilling ranged from 3.0 to 5.0 feet. A few days after drilling, the water rose in Boring #13 to 2.2 feet. Monitoring well (piezometer) TP-5 was installed to the north-northwest of the proposed mitigation site in 2014 to measure the depth to groundwater through time at this location (Letter to Mr. John Acken). Depths to groundwater were measured and recorded every two months from July 1 through November 3. The depths measured from the ground surface were 4.5 feet (7/1/14), 8.1 feet (9/2/14), and 8.2 feet (11/3/14). These data indicate a variable depth to groundwater through the growing season as would be expected. Runoff calculations completed across the project site indicate there would be an average annual total of 8.03 acre feet of water that would be directed to the proposed detention pond based on average annual precipitation totals. This equates to an estimated total of approximately 58,300 cubic feet of water per growing season month (April through September). As designed, the detention pond would detain and release this runoff after passing through a fore bay sediment treatment until the depth of water in the pond reaches 12 inches. The 12 inches would be held in the bottom of the mitigation pond to aide in supporting the compensatory wetland plant community to be established. Overall, there appears to be a somewhat shallow groundwater table that would be accessible for developing a mitigation site. However, the depth range to groundwater during the growing season at the proposed mitigation site is uncertain at this time given the data at hand. Typically, to create a successful mitigation site of this type, excavation must occur to a reasonable depth that intercepts a groundwater level that is dependable and stable across the growing season from approximately April 15 to October 1. The limited monitoring data we have indicates a fluctuating groundwater depth that would not support a wetland community in the latter stages of the growing season. Runoff calculations indicate that a notable amount of water would be sent to the pond during each month of the growing season, in an average or better precipitation year to support a wetland community planted in the bottom of the pond. The potential for creating a successful compensatory wetland site appears reasonable given the calculated surface water contribution and the potential for an accessible groundwater table. However, additional data is needed to be certain of this potential. It is recommended that monitoring at piezometer TP-5 be continued this year from April on, as far as possible, to create a data set that would provide additional groundwater depth information from which to develop plans for creating a successful mitigation site. When measuring groundwater depths at TP-5, the measurement need reflect the depth from the ground surface and not the top of the piezometer. Monitoring should take place at least monthly, though semi-monthly would be more desirable from a mitigation planning standpoint. If an appropriate groundwater regime is indicated, in concert with the expected runoff contribution, then mitigation at the site could occur. Should the data indicate that a reliable and stable groundwater depth is not present at the site at a reasonable excavation depth to supplement the runoff contribution, then either an alternate mitigation site or contact with the City with respect to an in-lieu cash contribution to the appropriate City natural resources program should be considered. I trust this letter will meet the needs of the City and address the question as to the existing hydrologic characteristics of the project site relative to the creation of a successful mitigation site within the proposed detention pond. Sincerely, Stephen G. Long Principal APPENDIX D: SITE PHOTOGRAPHS TAKEN AUGUST 23, 2013 AT THE CAPSTONE COTTAGES PROJECT SITE P-1: W-1 – Borrow Ditch looking west along Lincoln Avenue P-2: W-2 – Depression 2 P-3: W-3 – Shallow Drainage