HomeMy WebLinkAboutApp. E. - Updated Wetland Status 07-22-2020 N Morrison
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MEE Maierle 2880 TECHNOLOGY BLVD.W • P.O.BOX 1113• BOZEMAN,MT 59771
engineers-surveyors,planners.scientists 406.587.0721 • www.rr m.net
June 13, 2019
Kilday and Stratton, Inc.
Attn: Greg Stratton
2880 Technology Boulevard West
Bozeman, MT 59718
Subject: Norton Ranch East Subdivision Phase 5, Wetland Determination
M M I#: 5418.002.046
Dear Greg:
This letter outlines the next steps for the Norton East Ranch Subdivision Phase 5 wetland work.
I've been in touch with Barb Vaughn, who has worked on the property for several years, for
background on the project area. She let me know that she submitted a jurisdictional
determination request to the US Army Corps of Engineers (USAGE) last year for the excavated
overflow channel at the north end of the lot. USACE replied to let her know that data points
needed to be collected within the channel during the growing season.
Based on a preliminary review of the site data and a review of the National Wetland Inventory
(NWI) map, the area does not appear to exhibit wetland characteristics. MMI will collect
necessary data in the month of July to satisfy the USACE's request for additional information
and follow-up with the USACE to complete the jurisdictional determination.
Thanks for the opportunity to perform this work for Kilday and Stratton. If you have any
questions regarding the information provided, please feel free to contact me at (406) 922-6846
or cpearcy@m-m.net.
Sincerely,
MORMSON-MMERLE,INC.
Christine A. Pearcv
Environmental Scientist
We create solutions that build better communities
AN EMPLOYEE-OWNED COMPANY • AN EQUAL OPPORTUNITY EMPLOYER-MINORITIES I FEMALES f DISABLED t VETERANS
Environmental Services 406-586-6909*Cell:406-581-0655#bvaughn@montana.com
8353 Saddle Mountain Road •Bozeman,Montana W15
Attn: Timothy McNees
US Army Corps of Engineers
Helena Regulatory Office
10 West 15'Street,Suite 2200
Helena,Montana 59626-0014
Re: JD request for preservation wetland NWO-MTH-2007—01084,Norton East Ranch
October 21,2019
Dear Tim,
This is a request for a jurisdictional status determination for the preservation wetland
protected under a Covenant of Dedication for the original 2007 Individual Permit NWO-2007-01084.
Kevin Spencer, owner of Norton East Ranch, submitted the preliminary plat application for Phase 5
of Norton East Ranch in 2018. The City Planner required a new wetland delineation although the
development was not going to impact the preservation wetland or any jurisdictional wetlands. A
wetland delineation was completed on the Norton East Ranch land north of West Babcock Street
between September 14 and October 5, 2018,using methodology developed by the USACE and other
federal agencies for implementation of Section 404 of the Clean Water Act. The delineation results
were not submitted to the City until 2019. The 2018 delineation result indicated that the preservation
mitigation wetland had expanded since 2006. This was the result of several upgradient sources of
water that have since been abandoned or diverted to a french drain installed at the south end of the
property.
The 2019 plat layout will not impact the preservation wetland but it will impact the non-
jurisdictional wetland area that has developed since 2010 around the perimeter of the preservation
wetland. There have been no changes to the area downgradient of the preservation wetland. There
are no downgradient waters of the US north of the preservation wetland or connected to the
preservation wetland. The data forms, USGS,NWI, aerial maps, and JD form are included with this
submittal. The project history is also included with this submittal. Google Earth maps from 1995 to
2014 show the transition of the area prior to and during construction.
Delineation procedures involved a review of existing site-specific information and
completion of an onsite field investigation based on guidelines for the Routine Determination Method
presented in the Field Guide for Wetland Delineation and the Regional Supplement to the Corps of
Engineers Mountains, Valleys, and Coast Region. Vegetation indicator status for this investigation
was derived from the Western Mountains, Valleys, and Coast 2016 Regional Wetland Plant List.
Taxonomic references included Dorn 1984, Hitchcock 1971, Lackschewitz 1991, and Lesica and
Husby 2001. Eleven test pits were excavated throughout Phase 5 to determine the wetland
boundaries based on conformance with the USACE wetland criteria for plants, soil, and hydrology.
The wetland data was entered on the eleven Wetland Determination Data Forms included with this
submittal. Photographs taken during the 2018 wetland delineation field investigation are also
included.
The 2018 wetland delineation boundaries and test pit locations are shown on the enclosed
Wetland Delineation Exhibit (EXI) provided by C&H Engineering. Included on the exhibit are the
original 2006 wetland delineation boundaries showing the 8.64-acre preservation wetland,the 25-foot
upland buffer, and the meets and bounds of the area protected by the Covenant of Dedication signed
and recorded on April 11,2008. The preservation of the non jurisdictional wetland and upland buffer
and the drafting of the Covenant of Dedication protecting the wetland in perpetuity were conditions of
the original 2007 Individual permit for Norton East Ranch. The preservation wetland is still
considered non jurisdictional based on the lack of a permanent downgradient surface water
connection or significant nexus to a water of the US. There have been no unapproved impacts to the
mitigation wetland since it was created in 2007. The easement for Laurel Glen Parkway across the
mitigation wetland was shown in the Covenant of Dedication. The road crossing the preservation
wetland has been constructed within the past five years.
A temporary drain ditch was excavated in January 2015 at the north end of the preservation
wetland parallel to the north property boundary to prevent surface water from inundating the Lakes
Subdivision to the north (see enclosed Photo 8.0 from March 2015). Several permanent solutions
have since been implemented sitewide to address the flooding issues. The temporary drainage ditch
is no longer necessary and has been abandoned. A sub-surface draintile has been installed at the
south property boundary, the temporary ditch excavated between the historic spring box and
preservation wetland has been abandoned and filled, and the dewatering activities have ceased. The
following paragraphs detail the flooding issues that have occurred sitewide since construction began
in 2010.
The wetland boundaries of the original preservation wetland expanded west of Laurel
Parkway between 2010 and 2014, as shown on the 2018 wetland exhibit. The recent wetland
expansion was the result of three temporary and artificial sources of surface water that occurred after
Norton East Subdivision construction began in 2010. The historic landowner prior to Kevin Spencer
of Norton E Ranch had installed two drain tiles within the parcel to reduce groundwater levels to
facilitate hay cultivation. The underground drain tiles were broken during construction in 2010,
which resulted in groundwater surfacing from the underground pipe to an historic spring box located
near the south property boundary. The spring box had been abandoned and dry until the drain tile
was broken. The outflow from the spring box coupled with dewatering activities created flooding
sitewide. A ditch was excavated in upland by the contractors from the south boundary to the west
edge of the preservation wetland,continuing north to the adjacent property. The excess surface water
resulted in flooding on the property to the north,the Lakes at Valley West, which created a pond and
channel in uplands that were slated for development. A temporary drainage trench was excavated in
2015 at the northwest edge of the preservation wetland to divert excess surface water on Norton East
property to Aajker Creek before it crossed the boundary to Valley West. The drainage ditch
excavation was completed after a meeting between the Lakes owner Greg Stratton, Barbara Vaughn,
and Todd Tillinger, director of the USACE, in March 2014. The drainage ditch was intended to be a
temporary solution to allow the Lakes development to proceed until the draintile system on the
Norton property could be installed. The drainage ditch at the north property boundary was dry during
July 2018 and has been abandoned permanently.
The surface water sources that created the westward expansion of the wetland have been
terminated. The draintile system was installed at Fallon Street near the south property boundary to
collect groundwater and divert it offsite to Aajker Creek. The location of the 12-inch draintile installed
by March 18, 2017, was shown on the Phase 4 plans. A groundwater model showing the zone of
influence was completed by Michael Nicklin to obtain the 404 permit authorization. The October 18,
2016, Nationwide 29 permit authorization (NWO-2007-1084-MTH), for the offsite discharge of
groundwater from the draintile to Aajker Creek was provided to the City.
The non jurisdictional wetland area west of the west boundary of the preservation wetland
developed between 2010 and 2014 as a result of temporary and artificial sources of surface water. The
water sources have been terminated. The expanded wetland area exhibits marginal wetland conditions
dominated by field meadow foxtail (Alopecurus pratensis — FAC), reed canary grass (Phalaris
arundinacea—FACW), Canadian thistle (Cirsium arvense—FAQ, field sow thistle (Sonchus arvensis
—FACU), and smooth brome(Bromus inermis—UPL). The soil in the wetland test pits was dominated
by black silt clay with redox features, depleted matrix, or depleted dark surface. The wetland test pits
generally displayed saturation to the ground surface, saturation at 18 inches below the ground surface,
high ground water table, and geomorphic position.
The supporting wetland hydrology for the expanded palustrine wetland no longer exists and the
functional value of the newly developed wetland is low based on the lack of structural and plant
diversity, lack of water, and prevalence of invasive species. There is no value to reusing the field
meadow foxtail and reed canary grass sod, which are both aggressive dominant species. Trees and
shrubs will be planted in the north half of the preservation wetland. Please contact my office if you
require further information.
Sincerely,
Barbara Vaughn
Environmental Engineer,MS
Cc: Kevin Spencer,Norton East Ranch LLC
Matt Hausauer,C&H Engineering
Enclosures: Wetland Determination Data Forms
2018 Site Photos
Wetland Delineation Exhibit—EX
WETLAND REVIEW REQUIRED MATERIALS:
NORTON EAST RANCH SUBDIVISION: Phase 5
KEVIN SPENCER,OWNER;
March 17,2020
APPLICATION SETS:
Plan sets that include all required items listed on the wetland checklist listed below.
• See enclosed 11 x 17 Preliminary Plat Map of Norton East Ranch—Phase 5
STATUTE:
Enclosed is information required for all activities proposed in or adjacent to regulated wetland areas
as mandated in Section 38.30 of the Bozeman Municipal Code. The boundaries of waters of the
US were originally identified within the Phase 5 Norton East Ranch parcel boundaries on October
13 and 14,2006 using methodology developed by the US Army Corps of Engineers(USACE)and
other federal agencies for implementation of Section 404 of the Clean Water Act. An updated
wetland delineation with the Phase 5 boundaries was completed in September and October 2018 as
discussed in Number 7 of the checklist.
The Individual Permit for impacts to Waters of the US associated with development of Norton East
Subdivision was authorized on April 28,2008. The wetland identified in 2006 that is located within
Phase 5,W-5-05,was classified by the USACE as a non jurisdictional wetland. Non jurisdictional
Wetland-5-05,encompassing 8.68 acres of depression,palustrine wetland,was preserved as part of
the compensatory mitigation plan. Covenant of Dedication Number 2299907 recorded on May 14,
2008, by Charlotte Mills of Gallatin County, protects in perpetuity the preservation wetland and
the Baxter Creek corridor including 50-foot watercourse setbacks. The areas associated with the
ROWS for Laurel Parkway and West Babcock streets were specifically excluded from protection
under the Covenant. The Covenant of Dedication is included with this submittal.
APPLICATION FEE:
WETLAND REVIEW CHECKLIST:
1. The Pre-Application Plat of Phase 5 Norton East Subdivision shows the boundaries of
the preservation wetland including the limits of the ROW associated with Laurel
Parkway. The development of Phase 5 will not impact the preservation wetland except
for the completion of Laurel Parkway,which was authorized in the April 18,2008,404
permit,and was shown on the Covenant of Dedication,and Master Plan.
2. Phase 5 development will avoid impacts to the preservation wetland. Trails will be
constructed at the outside edge of the preservation wetland. Laurel Parkway has been
partially constructed as a gravel road. The roadway will be completed as part of Phase
5 development. The ROW for the parkway crossing through the preservation wetland
was authorized by the 404 permit and specifically mapped on the Covenant of
Dedication.
3. A majority of the original wetland delineation information and boundaries defined for
the non jurisdictional preservation wetland was obtained from the Norton East Ranch
Property Wetland Delineation Report drafted by Morrison-Maierle, Inc.
Environmental Services Group in October 2006.Morrison-Maierle,Inc.completed the
delineation of waterways and wetlands on the 245.6-acre parcel owned by Norton
Properties, LLC, on October 13 and 14, 2006. An amendment to the original 2006
permit approved on October 18,2016, authorized the installation of a drain tile at the
south end of Norton East Ranch. The drain tile was intended to collect and discharge
the groundwater released to the surface when an historic drain tile was broken during
the onset of construction in 2010. A Waters of the US Delineation Report dated May
9, 2016, characterized the wetland boundaries at the discharge point of the drain tile
that extends west then north from Norton Property to Aajker Creek. The May 2016
report is included with this submittal (see project history in No.7). The October 18,
2016,permit amendment letter from the USACE authorizing construction of the drain
pipe and discharge point is included with this submittal.
4. The site plan shows the delineated wetland boundary for the preserved non-
jurisdictional wetland W-5-05,the property boundary,existing and proposed structures,
streets and hardscape including sidewalks and pathways, watercourses and
drainageways on and within 100 feet of the property. The preserved non jurisdictional
wetland(W-5-05)within the Phase 5 Norton Ranch boundaries will not be directly or
indirectly impacted by the proposed activities. No 404 permit will be required for the
Phase 5 development if the USACE concurs that the preservation wetland and the 2018
wetland fringe located southwest of the preservation wetland are non jurisdictional. If
the area is determined to be jurisdictional,a 404 permit would likely be required unless
the plat layout is revised to avoid wetland impacts.
5. If the Jurisdictional Status Determination classifies the preservation wetland as non-
jurisdictional,the Phase 5 Norton East Ranch development will not impact any Waters
of the US including wetlands and, consequently,will not require a 404 permit. If the
preservation wetland is classified as jurisdictional,a 404 permit will likely be required
unless wetland impacts can be avoided. Trails will be constructed outside the boundary
of the preservation wetland,if the wetland is classified as non jurisdictional. The trail
location may have to be revised and impacts associated with the trail may have to be
permitted if the preservation wetland and wetland fringe area are classified as
jurisdictional.
6. Copies of the original 2006,404 permit and subsequent amendments are enclosed with
this submittal. The preserved non jurisdictional wetland (W-5-05) protected by a
Covenant of Dedication within the Phase 5 Norton Ranch boundaries will not be
directly or indirectly impacted by the proposed activities. No 404 permit will be
required for the Phase 5 development if the USACE concurs that the preservation
wetland and the 2018 wetland fringe located southwest of the preservation wetland are
non jurisdictional. If the area is determined to be jurisdictional, a 404 permit would
likely be required unless the plat layout is revised to avoid wetland impacts.
7. Norton East Ranch Subdivision was originally permitted by the USACE under
Reference Number NWO-2007-1084-MTH,authorized on April 28,2008. Morrison-
Maierle, Inc. Environmental Services Group completed the original delineation of
waterways and wetlands on the 245.E-acre parcel owned by Norton Properties, LLC,
on October 13 and 14,2006. The 2008 permit authorized 0.75 acres of impact located
within the property boundaries of the Norton Ranch East Subdivision. An additional
0.25 acres of offsite impacts were necessary to provide access to the subdivision
through the extension of West Babcock and Fallon streets across the 64-acre parcel
owned by Joe Billion. Mitigation for 1.0 acre of wetland impacts was provided by the
enhancement and preservation of 8.68 acres of a non jurisdictional wetland(W-5-05),
maintenance of a 25-foot upland buffer(1.92 acres)around the perimeter of a majority
of the preservation wetland, and the preservation of 4.0 acres of the Baxter Creek
riparian corridor,which includes 50-foot watercourse setbacks.
A permit amendment dated October 18,2016,authorized the installation of a new drain
tile located south of Fallon Street. The drain tile was installed parallel to the south
boundary in April 2017 to prevent groundwater from surfacing via a broken subsurface
drain tile that had been installed in the 1970's for agricultural purposes. The historic
drain tile located near the south boundary was broken at the beginning of construction
activities on Norton East in 2010. The broken drain the resulted in groundwater
surfacing at an abandoned spring box,which ultimately flooded Phase 5 of the Norton
property and the adjacent Lakes property located at the north boundary where the
preservation wetland W-5-05 previously terminated.
Before the drain the was installed in 2017,surface water from the broken drain tile on
Norton East was collected in a small ditch excavated in an area previously classified
as upland that diverted water from the spring box to the preservation wetland. The
excess surface water flooded the Lakes property accumulating in a pond located just
north of the north property boundary with Norton. Todd Tillinger of the USACE stated
during a March 2014 meeting in Helena that the Lakes could take measures to prevent
the overflow from Norton from entering their property. A trench was excavated in
upland at the northwest edge of the preservation wetland to divert surface water west
on Norton East property to Aajker Creek,intercepting the surface water flow before it
crossed the boundary to the Lakes. The trench excavated from the edge of the
preservation wetland to Aajker Creek had the intended result of draining the excess
surface water and pond on the Lakes property. The drain tile installed at Fallon Street
in April 17, 2017,currently collects and diverts groundwater from the south property
boundary to the discharge point on Aajker Creek, which is located west of the west
property boundary for Norton.. The 2017 drain tile was installed to prevent
groundwater from surfacing from the broken historic drain tiles.
Because over five years had elapsed since the 2006 delineation,the City of Bozeman
required a new wetland delineation of Phase 5 in 2018,which included the preservation
wetland. A wetland delineation was completed on the Norton East Ranch land north
of West Babcock Street between September 14 and October 5, 2018, using
methodology developed by the USACE and other federal agencies for implementation
of Section 404 of the Clean Water Act. The delineation results were submitted to the
City in 2019. The 2018 delineation results indicated that the edges of the preservation
mitigation wetland had expanded since 2006. This was the result of excess surface
water from the broken drain tile that has since been diverted to Aajker Creek via a new
drain tile and dewatering activities that have since been terminated.
A request for a new jurisdictional status determination for the preservation wetland
was submitted to Tim McNew with the USACE on October 21, 2019. The 2019 plat
layout will not impact the preservation wetland but it will impact the wetland fringe
identified in 2018 that has developed since 2010 around the perimeter of the
preservation wetland. If the preservation wetland and adjacent wetland fringe is
classified as non jurisdictional,impacts to the expanded wetland fringe will not require
a 404 permit. If the preservation wetland and adjacent wetland fringe are determined
to be jurisdictional, a 404 permit will be required unless wetland impacts to the
expanded wetland fringe are avoided. The 2018 data forms,USGS,NWI,aerial maps,
and JD form were included with the JD request. The project history was also included
with this submittal. Google Earth maps from 1995 to 2014 showed the transition of
the area prior to and during construction.
The temporary drain ditch excavated in January 2015 at the northwest end of the
preservation wetland and parallel to the north properly boundary was dug to prevent
surface water from inundating the Lakes subdivision to the north. Several permanent
solutions have since been implemented sitewide to address the flooding issues that
started in 2010. The excess overland surface water flow on the Norton property has
been eliminated. A subsurface drain tile has been installed at the south property
boundary, the temporary ditch excavated between the historic spring box and
preservation wetland has been abandoned and filled,and the dewatering activities have
been terminated. The temporary drainage ditch between the preservation wetland and
Aajker Creek at the north property boundary is no longer necessary and has been
abandoned.
Tim McNew has indicated that the temporary ditch channel and area surrounding the
ditch must be reviewed during the growing season in 2020 to confirm that the ditch no
longer exhibits wetland characteristics. The area was identified as wetland in the 2018
delineation although no test pits were excavated in the area. The drainage ditch was
dry in October 2018. Potential wetland characteristics will be evaluated during the
growing season 2020. If any one of the wetland criteria is not present,the ditch will
be classified as a non-wetland,which will confirm that there are no WUS downgradient
of the preservation wetland and expanded wetland fringe. The preservation wetland
will then meet the criteria for a non jurisdictional wetland, and, consequently, the
expanded wetland buffer zone. Non jurisdictional wetlands are regulated by the City
of Bozeman. The preservation wetland will be enhanced with trees and shrubs to
develop structural diversity as illustrated in the Norton Ranch Landscape Plans,which
were designed according to the City of Bozeman Municipal Code.
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