CRITICAL AREAS STUDY

CRITICAL AREAS STUDY

DOUGLAS-SOUTH CHURCH ROAD

PHASE 4

COMPREHENSIVE WETLAND HYDRIC SOIL ASSESSMENT

SOUTH CHURCH ROAD PROPERTY FERNDALE, WASHINGTON 98595

48.84570 N; -122.61560 E

Prepared For

Bill Kramer South Douglas LLC 1442 Sunset Avenue Ferndale, WA 98248

Prepared By

SOUND ECOLOGICAL ENDEAVORS, LLC 19325 32nd Avenue N.W.

Stanwood, WA 98292 206.595.7481

AUGUST 2015

PattiPapetti

Text Box

EXHIBIT 29

PattiPapetti

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RECEIVED 06/04/2021 BY: PATTI GEARHART 21001-APL

8/19/15 01Kramer WetandRpt.doc Sound Ecological Endeavors, LLC ii

TABLE OF CONTENTS

Page

1.0 INTRODUCTION & BACKGROUND .............................................................................................. 1

2.0 METHOD .............................................................................................................................................. 2

3.0 RESULTS .............................................................................................................................................. 4

4.0 DISCUSSION ........................................................................................................................................ 6

5.0 CONCLUSIONS ................................................................................................................................... 8

6.0 REFERENCES ...................................................................................................................................... 9

LIST OF FIGURES

Figure Title

1 Site Location 2 Current Site Plan

8/19/15 01Kramer WetandRpt.doc Sound Ecological Endeavors, LLC 1

1.0 INTRODUCTION & BACKGROUND

In 2006, a wetland delineation and mitigation plan was submitted by Aqua-Terr Systems, Inc.

(ATSI) for the Douglas Long Plat, which is located in the northwest quarter of section 30, Township 39N

and Range 2E at the north end of South Church Road in southwest portion of the City of Ferndale (City),

Washington (Figures 1 and 2), at an elevation of approximately 95 feet (ft) above mean sea level. An off-

site wetland mitigation area was approved providing adequate mitigation for the Douglas Long Plat and

another distinct residential development project. However, after mitigation was completed for the other

project, changes in the Whatcom County code requiring protection of farmland, disallowed use of the

existing already approved mitigation area for any mitigation related to the Douglas Long Plat. At that

point in time, at significant cost, the approved Douglas Long Plat was altered and phased to permit

development of a portion of the original plat without impacting wetlands. Construction phases 1, 2, and 3

have now been completed (Figure 2). This comprehensive wetland investigation was conducted for Phase

4, within a parcel located in the northern portion of the original Douglas Long Plat, with Geographic

Parcel ID#: 3902300214560000 (subject property; Figure 2).

In 2013, a hydrogeomorphic wetland investigation of the subject property was conducted by SNR

Company. SNR’s hydrogeologic studies indicate that near surface ground water is not present on the

subject property and that saturated soil conditions are not present, which means the aquic conditions

required to create hydric soils also are not present. Further, SNR collected five soil samples from test pits

excavated in areas where Horton storage accumulated in minor depressional areas. These soil samples

were tested by AmTest, a Washington State Department of Ecology (Ecology) certified laboratory, for

oxidation-reduction potential (ORP) and pH. The test results indicate that soils were oxidizing, not

reducing, and that anaerobic (i.e. wetland) conditions were not present. Given two of three indicators

were determined not to be present, SNR concluded that wetland hydrology (saturated soil conditions as

defined on page A11 of the 1987 Corps manual or aquic conditions as defined by the NTCHS and NRCS)

and hydric soil were not present in the study area. While no agency technical review of the SNR report

was conducted, the SNR findings were summarily discounted because the report was not in a “standard”

format, and because the soil ORP samples were removed from the ground and sent to the laboratory,

rather than having ORP measured in-situ.

In order to address the criticism of soil sample removal and laboratory testing, this investigation

used platinum-electrode containing soil probes to measure in-place (i.e., in situ) soil ORP. This is the

official wetland method defined by the National Technical Committee for Hydric Soils (NTCHS) and

accepted by reference in City law.


2.0 METHOD

By federal, state, county, and City legal definition, wetlands are those areas that contain

vegetation adapted for “saturated” soil conditions. Also by scientific and many legal definitions, a

“saturated” soil condition requires water pressures greater than atmospheric pressure (i.e., a stable water

table). This is the water pressure at which oxygen does not easily re-enter the soil column, promoting the

depletion of soil oxygen through aerobic bacterial respiration, which, when combined with the presence

of enough organic material as food for anaerobic bacteria present in the soil, can lead to the anaerobic and

then chemically-reduced (i.e. aquic) conditions required for the formation and development of a hydric

soil. Water that is flowing readily over the surface or through the shallow subsurface cannot create water

pressures greater than atmospheric, precisely because it is flowing too fast, creating negative pressure as it

flows through soil pores similar in some ways to, but at a smaller scale than, a venturi effect. Because

water pressure greater than atmospheric (i.e., “saturation”) is very difficult to measure, but must lead to

anaerobic and chemically-reduced soil conditions for the required “wetland” hydric soils to form, the

chemical oxidation-reduction state within soils can be used as a surrogate for the presence of wetland

hydric soil conditions.

The Corps of Engineers (Corps; 1987 and 2010) wetland guidance, incorporated into City law,

provides that determination of the presence of wetland hydric soils may be evaluated according to the

current NTCHS technical standard, which is provided in NTCHS Technical Note 11 (NTCHS, 2007).

Specifically, wetland hydric soils require anaerobic and chemically reduced conditions (a.k.a., aquic

conditions). If either of these are not present, according to the prescribed definitions, then neither wetland

hydric soil nor wetland conditions exist. However, as described above, it is saturated conditions which

lead indirectly to anaerobic and reduced conditions. Therefore, measures of the reducing conditions are

of primary concern and provide evidence of the presence or lack of saturated soil conditions.

In accordance with NTCHS Technical Note 11 anaerobic conditions assessment for loamy soils

found at the subject property, five platinum ORP electrodes mounted into fiberglass probes (PaleoTerra,

Amsterdam, The Netherlands, http://www.paleoterra.nl) were pushed into native soils, to a depth of 25

cm. An eleventh electrode placed at the same depth recorded soil temperature. The probes were placed

in an 3 meter arc such that each probe (and electrode) was approximately equidistant from a centrally

located silver/silver chloride reference electrode pushed approximately 6 cm into, and sealed with, native

soil. These electrodes were attached to a Hypnos III data logger (Vorenhout et al., 2011). This data

logger has a 10 TeraOhm impedance on each electrode. This extreme impedance, the resistance against

flow of electric current, is needed to remove any influence of electrodes on their surrounding

http://www.paleoterra.nl/


environment. With a lower impedance a small current can occur between the reference probe and the

measuring probe, causing measurement-induced reduction and/or oxidation in the medium under study

(Rabenhorst, 2009). The probes were placed for eleven days in Wetland A and twelve days in Wetland

B. Both locations (Figure 3) were selected because they were visually identified as the wettest area

within the two wetlands, both with inundation of the soil surface by water.

The Hypnos measured ORP at each electrode every 15 minutes over the course of the

investigations. These data were recorded on a mini computer disc and were readily imported directly

from the disc into Microsoft Excel format. The soil redox potential (Eh) was calculated in millivolts

(mV) by adding the temperature adjusted potential from the reference electrode (Eref) to the measured

potential (Em):

Eh = Em + Eref Equation 1

and adjusting the Eh for site-specific soil pH:

Eh-corrected = Eh – (60*(7-pH)) Equation 2

The temperature adjusted Eref potential for the 3 molar KCl silver/silver chloride reference electrode was

extrapolated from multiple sources to be 220 mV at 10 degrees Celsius, decreasing with higher

temperature. Given the measured soil temperatures were 10 degrees Celsius or less the temperature

adjusted Eref potential of 220 mV was used to adjust the Em for both data sets. The in-situ pH was 6,

measured to the nearest half a point with a calibrated soil probe. This pH also was verified using a field

pH meter in water within an adjacent 6 inch deep pit, and is lower (i.e., more protective) than that

measured by the lab in the SNR Company investigation. Given a pH of 6, the Eh-corrected was

calculated by subtracting 60 mV from the reference adjusted Eh. The resulting reference-adjusted and

pH-corrected ORP measurements were plotted for comparison to the NTCHS wetland hydric soil

threshold of 175 mV.


3.0 RESULTS

Individual ORP measures for each of the five probes were downloaded from the Hypnos data

logger into Microsoft Excel format, tabulated, temperature-reference electrode adjusted, pH adjusted, and

then plotted. The data plots for Wetland A and Wetland B are provided below.

8/19/15 01Kramer WetandRpt.doc Sound Ecological Endeavors, LLC5

In both wetland locations, more probes exhibited ORP conditions above the wetland hydric soil

threshold than below. Daily temperature related variation is visible, providing evidence of the

stabilization of readings within two to three days of placement.

In non-groundwater related wet areas such as those on the subject property, precipitation is

critical to the presence of water, which in turn must be present to result in chemically-reduced soil

conditions. January, February, March, and April 2015 precipitation data at the Ferndale 2.2 NW station

(National Climate Data Center: http://www.ncdc.noaa.gov/) were 6.29, 2.45, 6.44, and 1.47 inches,

respectively. This weather station is 1.6 miles north of the subject property. The precipitation for these

months was regionally (Puget Sound Lowlands) normal for January, well above normal for March, and

about half of normal for February and April. When compared to San Juan Island averages, precipitation

was normal for February and April, and well over normal for January and March. Over the four month

period, rainfall at the subject property was approximately one inch less than normal compared to the

Puget Sound Lowlands average. When compared to the San Juan Island area four month average,

precipitation at the subject property was about 6 inches above normal.

http://www.ncdc.noaa.gov/


4.0 DISCUSSION

Regional average weather (precipitation) data provided by the National Climate Data Center

(NCDC) are only readily available for certain regions. The subject property lies north of the NCDC Puget

Sound Lowlands region and west of the San Juan Island region. Given local precipitation over the four

month period from January to April was above average for the San Juan Island region, but slightly below

average for the Puget Sound Lowlands, it is deemed likely that the four month average precipitation was

approximately normal for the subject property which lies between these two regions. Thus, soil moisture

during the data gathering period is considered normal, and being measured at the end of the wet season

provided ample time for hydric conditions to develop.

The ORP data plots provided in Section 3.0 show that in each of wetlands A and B, at least three

out of the five soil probes indicated an absence of wetland hydric soil conditions (ORP below 175 mV).

These results were obtained from the wettest observed locations in the two wetlands near the end of the

wet season, and thus are considered representative of the entire wetland complex at the subject property,

which is entirely within the same pasture and has been subjected to the same farming practices over the

past century.

The data plots also show some of the probes were within less common areas of chemical

reduction, known as “micro-sites” of reduction. It is common for micro-sites of reduction to be present,

but for wetland hydric soil conditions to be present, the soil must be in a predominantly reduced

condition. The ORP results show this is not the case. Similarly, probe 1 in Wetland B has an ORP of

about 400, which is indicative of a lack of water surrounding the electrode. This shows that even in the

wettest areas, highly oxidized conditions may be present, very clearly supporting the fact that water

within the shallow subsurface soil is unsaturated zone flow, not a saturated groundwater condition that

would always be below 300 mV, and required to meet the legal definition of a wetland.

The wetland hydric soil threshold of 175 mV as an indicator for wetland hydric soils is not well

supported in the literature. The NTCHS provides this value in its Technical Note 11, but provides no

supporting documentation on its development. Based on some geochemical oxidation-reduction

diagrams, this appears to be the point at which certain iron complexes begin to be reduced, in certain

soils. However, iron is most often shown to be reduced at or below 100 mV, and not completely reduced

until soil conditions are at or below 0 mV, which also is the most commonly documented point where

soils are considered to be anaerobic. Thus, the 175 mV is not a well-founded geochemical threshold, but

rather, a value developed to conform to the presence of facultative wetland vegetation and micro-sites of


iron reduction. It is not the point of anaerobic soil conditions that are required for the formation of true

hydric soils, but rather the beginning point of what are considered to be wetland hydric soils. As such,

175 mV is a conservative (i.e., protective) threshold that is not necessarily indicative of legally defined

wetland “saturated” conditions. A reduction potential also is not a direct measure of saturation, and thus,

while 175 mV is provided as a threshold for determining jurisdictional wetlands, it is not a direct measure

of saturated conditions (pressures greater than atmospheric), which likely are more often associated with

0 mV or less.


5.0 CONCLUSIONS

The available ORP data collected from the wettest portions of Wetlands A and B show that

wetland hydric soil conditions do not exist at the subject property. They also confirm that saturated soil

conditions do not exist. These findings are consistent with the earlier SNR Company findings that

saturated soil conditions could not exist because the soil moisture is flowing across the sloped subject

property and is not associated with a saturated groundwater zone. Given the predominance of “oxidized”

conditions in subject property soils and obvious unsaturated zone water flow across the property, wetland

hydric soils and saturated condition are not present, and therefore, legally defined jurisdictional wetlands

do not exist at the subject property.


6.0 REFERENCES

Aqua-Terr Systems, Incorporated (ATSI). 2006. Wetland Mitigation Plan for Douglas Long Plat. Prepared for Ron Fisher, South Douglass, LLC, Ferndale, WA. http://www.aquaterrsystemsinc.com/.

National Techincal Committee for Hydric Soils (NTCHS). 2007. Technical Note 11: Technical Note for Hydric Soils. Deliberations of the National Technical Committee for Hydric Soils. (http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs142p2_051608.pdf)

Rabenhorst, M.C., W. D. Hively and B. R. James. 2009. Measurements of Soil Redox Potential. Soil Sci. Soc. Am. J. Volume 73.

SNR Company. 2013. Hydrogeomorphic Report: GMA Critical Areas Wetland. 55XX Fisher Place, Ferndale, WA 98248. Prepared for: South Douglas, LLC. www.snrcompany.com.

Vorenhout, M., H.G. van der Geestc, and E.R. Hunting. 2011. An Improved Datalogger and Novel Probes for Continuous Redox Measurements in Wetlands. Intern. J. Environ. Anal. Chem. Vol. 91: 801-810. [email protected].

http://www.aquaterrsystemsinc.com/

http://www.nrcs.usda.gov/Internet/FSE_DOCUMENTS/nrcs142p2_051608.pdf

http://www.snrcompany.com/

mailto:[email protected]

Figure

1Site Location

South Church Road Property48.84570 N; -122.61560 E

Subject Property

Washington

Sound Ecological Endeavors; 08/19/2015 11:20 AM

Figure

2

Current Conditions & Previously Delineated Wetlands

South Church Road Property48.84570 N; -122.61560 E

Sound Ecological Endeavors; 08/17/2015 6:14 PM

Approximate Scale: 1 inch = 150 feet

Oxidation-Reduction Test Locations

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