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GOPHER STUDY1047 Summit Avenue · Raymond, Washington 98577 · (360) 562-5763 Key Environmental Solutions, LLC. August 26, 2023 City of Yelm Community Development Attn: Cody Colt, Public Services Director 106 2nd St SE Yelm, WA 98597 Re: RJ Development LLC., Prairie Habitat Critical Area Recon and ESA No Effect Letter, Thurston County Parcels #21724130302 & 21724131000. Located off Berry Valley Road SE and Tahoma Boulevard SE, Yelm, Washington, Section 24, Township 17 North, Range 01 East, W.M., and in accordance with and in accordance with the City of Yelm Code; Title 14 environmental., WDFW Management Recommendations for Washington Priority Habitats Oregon White Oak Woodlands and WDFW Habitat Management Recommendations for the Mazama Pocket Gophers, following the 2018, 2023 USFWS Mazama Pocket Gopher Screening Protocol and Thurston County’s 2023 survey protocol. Dear Mr. Colt, Key Environmental Solutions, LLC. (KES) has completed a Prairie Plant Habitat Area Recon on the above referenced parcels located off Berry Valley Road, Yelm, Thurston County, Washington. Fieldwork was conducted on July 14, 2023 and August 14, 2023. Project Description and Findings The parcels were reviewed are a total of approximately 13.74 acres are located in the eastern portion county off Berry Valley Road SE and Tahoma Boulevard SE near the town of Yelm. Parcels 21724130302 & 21724131000 are currently undeveloped. The parcels are surrounded by Tahoma Boulevard SE to the south, a medical facility and parking lot to the east, undeveloped parcel to the west and businesses and parking to the north. The parcels were reviewed for prairie habitat, oaks and Mazama Pocket Gophers. When the parcels are developed there will be not any “Take” of any state or federally listed species of prairie plants. There were no Mazama Pocket Gopher mounds observed onsite, there will be not any “Take” of any state or federally listed species. There will be “No Effect” on prairie habitat, Mazama Pocket Gophers or any other critical areas or buffer impacted. KES carefully reviewed Washington Department of Fish and Wildlife’s (WDFW) Priority Habitat Species (PHS) lists and maps and there were no listed species shown to occur onsite. KES did not find any occurrence of gopher’s onsite or immediately adjacent to the site. Adjacent areas were also looked at for any critical areas or listed species and RJ Development LLC.- 21724130302 & 21724131000 Key Environmental Solutions, LLC. Prairie Habitat Recon & No Effect August 26, 2023 2 The project area was required to be reviewed due to the presence of prairie soils (See Table below). KES reviewed the Natural Resource Conservation Service Soils (NRCS) maps and verified that prairie soils did not exist in the project area. Soil Types Prairie Soil Spanaway gravelly sandy loam, 0 to 3% slopes Yes Spanaway stony sandy loam, 0 to 3% slopes Yes Mapped prairie soils do not necessarily mean that the area is a prairie –vegetation, landuse, development, and historical land practices may have changed the soil conditions. Current site conditions may or may not accurately reflect mapped soils. Conversely, prairies may be found in areas where the soils are not mapped as prairie soils. Federal ESA Species, Habitats and No Effect There are no Federal ESA species or habitats that exist within the parcels. There will be “No Effect” and/or “No Take” from the proposed project. Historically, the parcels were most likely a Douglas fir stand. Since 2009 the southeast corner was cleared and compacted. KES has performed two site visits as required. KES determined that parcels do not meet the definition of prairie from USFWS and that there has been no Mazama Gopher occurrence found on adjacent parcels or anywhere in the vicinity. The open portion of the parcels were mowed 3 weeks prior to survey. A large portion of the parcels were covered in very dense Scotch broom, which made walking transects impossible. Vegetation on the parcel consists of: Common Name Sc. Name Status alder Alnus rubra FAC beaked hazelnut Corylus cornuta FACU black cottonwood Poplus balsamifera trichocapa FAC black hawthorn Crataegus douglasii FAC bracken fern Pteriduim aquilinum FACU bull thistle Cirsium vulgare FACU Canadian thistle Cirsium arvense FACU carrot Daucus carota FACU common dandelion Taraxacum officinale FACU dock Rumex obtusifolius FAC Douglas fir Pseudotsuga menziesii FACU fireweed Chamaenerion angustifolium FACU fleabane Conyza canadensis var,glabrata FACU foxglove Digitalis purpurea FACU RJ Development LLC.- 21724130302 & 21724131000 Key Environmental Solutions, LLC. Prairie Habitat Recon & No Effect August 26, 2023 3 hairy cat's ear Hypochaeris radicata FACU Himalayan blackberry Rubus armeniacus FACU holly Ilex aquifolium FACU Indian plum Oemleria cerasiformis FACU Juniper haircap moss Polytrichum juniperinum FACU Klamath weed Hypericum perforatum FACU kneeling angelica Angelica genuglexa FACU lamb’s quarter Chenopodium album FACU lessor trefoil Lotus micracanthus FACU oat grass Avena sativa NI Oregon grape Mahonia aquifolium FACU Oregon white oak (2 saplings) Quercus garryana UPL orchardgrass Dactylis glomerata FACU oxeye daisy Leucanthemum vulgare FACU parentucellia Parentucellia viscosa FACU pepper grass Lepidium densiforum FACU pine trees FACU pineapple weed Matricaria discoidea FACU plantain Plantago lanceolata FAC red clover Trifolium pratense FACU red elderberry Sambucus racemosa FACU Reeds canarygrass Phalaris arundinacea FACW Robert’s geranium Geranium robertianum FACU salal Gaultheria shallon FACU Scotch broom (dense) Cytisus scoparius FACU service berry Amelanchier alnifolia FACU sheep sorrel Rumex acetosella FACU snowberry Symphoricarpos albus FACU spirea (little) Spiraea douglasii FACW St. John’s wort Hypericum perforatum FACU sweet pea Lathyrus nevadensis FACU tansy Tanacetum vulgare FACU trailing blackberry Rubus ursinus FACU vetch Vicia americana FACU white clover Trifolium repens FAC Based on physical, environmental, and biological conditions on and near the project site, KES has determined that no further site visits are necessary. There were no Mazama Pocket Gopher mounds found to occur onsite. Two oak saplings were found to occur onsite. It is KES’s professional opinion that the parcels located off Berry Valley Road and Tahoma Boulevard SE, do not have any endangered prairie species and when the parcels are developed there will not be any impacts to any prairie species or any other critical areas and should be permitted. RJ Development LLC.- 21724130302 & 21724131000 Key Environmental Solutions, LLC. Prairie Habitat Recon & No Effect August 26, 2023 4 Area that was able to be mowed. Area that was able to be mowed. Typical vegetation where it wasn’t able to be Typical vegetation where it wasn’t able to be mowed. mowed. Area of dense Scotch broom. Area of dense Scotch broom. Area of dense Scotch broom. Area of dense Scotch broom. RJ Development LLC.- 21724130302 & 21724131000 Key Environmental Solutions, LLC. Prairie Habitat Recon & No Effect August 26, 2023 5 Mowed area on small parcel. Mowed area on small parcel. Professional Standard of Care: Please be advised that KES personnel has provided professional services that are in accordance with the degree of care and skill generally accepted in the performance of this environmental evaluation. Fish and Wildlife Habitat Assessments together with wetland delineations, mitigation plans, classifications, ratings, streamtyping, riparian planting plans, ordinary high-water line determinations, fish removal and other critical area analysis should be reviewed and approved by the agency with permitting authority and potentially other agencies with regulatory authority prior to extensive site design or development. No warranties are expressed or implied by this assessment until approved by the appropriate resource and permitting agency. The findings expressed in this report are based on field investigations, best available data, best available science, and our professional judgement. The services described in this report were performed consistent with generally accepted professional consulting principles and practices. The services performed were consistent with our agreement with our client. Key Environmental Solutions, LLC, (KES) is not responsible for the impacts of any changes in environmental standards, practices, or regulations after the date of this report. KES does not warrant the accuracy of supplemental information incorporated in this report that was supplied by others. Thank you for the opportunity to evaluate this project and please contact us if you have any questions regarding this information, our findings, conclusions, or recommendations at (360) 562-5763. Sincerely, Key McMurry Owner/Professional Stream and Wildlife Biologist, SPWS The information included on this map has been compiled by Thurston County staff from a variety of sources and is subject to change without notice. Additional elements may be present in reality that are not represented on the map. Ortho-photos and other data may not align. The boundaries depicted by these datasets are approximate. This document is not intended for use as a survey product. ALL DATA IS EXPRESSLY PROVIDED ‘AS IS’ AND ‘WITH ALL FAULTS’. Thurston County makes no representations or warranties, express or implied, as to accuracy, completeness, timeliness, or rights to the use of such information. In no event shall Thurston County be liable for direct, indirect, incidental, consequential, special, or tort damages of any kind, including, but not limited to, lost revenues or lost profits, real or anticipated, resulting from the use, misuse or reliance of the information contained on this map. If any portion of this map or disclaimer is missing or altered, Thurston County removes itself from all responsibility from the map and the data contained within. The burden for determining fitness for use lies entirely with the user and the user is solely responsible for understanding the accuracy limitation of the information contained in this map. Authorized for 3rd Party reproduction for personal use only. Soils 5,369Scale 1: 0 6/10/2023 Note: Legend 250 500 Feet Published: Map Created Using GeoData Public Website Mazama Pocket Gopher Soils Less Preferred More Preferred Soils (USDA) Alderwood gravelly sandy loam, 0 to 3% slopes Alderwood gravelly sandy loam, 15 to 30% slopes Alderwood gravelly sandy loam, 3 to 15% slopes Alderwood gravelly sandy loam, 30 to 50% slopes Baldhill very stony sandy loam, 0 to 3% slopes Baldhill very stony sandy loam, 15 to 30% slopes Baldhill very stony sandy loam, 3 to 15% slopes Baldhill very stony sandy loam, 30 to 50% slopes Baumgard loam, 10 to 40% slopes Baumgard loam, 40 to 65% slopes Baumgard-Pheeney Comples, 40 to 65% slopes Baumgard-Pheeney complex, 10 to 40% slopes Baumgard-Rock outcrop complex, 40 to 65% slopes Bellingham silty clay loam Boisfort silt loam, 20 to 40% slopes Boisfort silt loam, 5 to 20% slopes Bunker gravelly silt loam, 30 to 65% slopes Bunker gravelly silt loam, 5 to 30% slopes 2023©Thurston County Parcel Number:CAO prairie criteria met?Yes or No Property Owner:Mima mounds present? Yes or No Surveyor(s):Oaks (Quercus garryana ) present? Yes or No Date: Mature: Composition of Vegetation:Sapling: Seedling: X Target species Class* (circle) Apocynum androsaemifolium 1 2 3 4 5 N/A Lupinus albicaulis 1 2 3 4 5 N/A Balsamorhiza deltoidea Present / Absent Lupinus lepidus var. lepidus 1 2 3 4 5 N/A Bistorta bistortoides Present / Absent Lupinus polyphyllus 1 2 3 4 5 N/A Brodiaea coronaria 1 2 3 4 5 N/A Micranthes integrifolia (Saxifraga i.)Present / Absent Camassia leichtlinii 1 2 3 4 5 N/A Micranthes oregana (Saxifraga o.)1 2 3 4 5 N/A Camassia quamash Present / Absent Microseris laciniata Present / Absent Carex densa Present / Absent Perideridia gairdneri 1 2 3 4 5 N/A Carex feta 1 2 3 4 5 N/A Plagiobothrys figuratus 1 2 3 4 5 N/A Carex inops ssp. inops 1 2 3 4 5 N/A Plectritis congesta Present / Absent Carex tumulicola 1 2 3 4 5 N/A Polemonium carneum Present / Absent Carex unilateralis 1 2 3 4 5 N/A Potentilla gracillis Present / Absent Castilleja hispida 1 2 3 4 5 N/A Ranunculus alismifolius 1 2 3 4 5 N/A Castilleja levisecta Present / Absent Ranunculus occidentalis Present / Absent Danthonia californica 1 2 3 4 5 N/A Ranunculus orthorhynchus 1 2 3 4 5 N/A Delphinium menziesii 1 2 3 4 5 N/A Sericocarpus rigidus Present / Absent Delphinium nuttallii 1 2 3 4 5 N/A Sidalcea malviflora var. virgata Present / Absent Deschampsia cespitosa 1 2 3 4 5 N/A Silene scouleri Present / Absent Deschampsia danthonioides 1 2 3 4 5 N/A Sisyrinchium idahoense 1 2 3 4 5 N/A Dodecatheon hendersonii 1 2 3 4 5 N/A Solidago missouriensis 1 2 3 4 5 N/A Downingia yina 1 2 3 4 5 N/A Solidago simplex (S. spathulata)1 2 3 4 5 N/A Erigeron speciosus 1 2 3 4 5 N/A Toxicoscordion venenosum var. venenosum (Zigadenus venenosus)1 2 3 4 5 N/A Eriophyllum lanatum Cover: ___ m2 N/A Trifolium willdenowii (T. tridentatum)1 2 3 4 5 N/A Eryngium petiolatum Present / Absent Triteleia grandiflora 1 2 3 4 5 N/A Festuca roemeri (F. idahoensis)1 2 3 4 5 N/A Triteleia hyacinthina 1 2 3 4 5 N/A Fragaria virginiana Cover: ___ m2 N/A Veratrum californicum 1 2 3 4 5 N/A Fritillaria affinis 1 2 3 4 5 N/A Veratrum viride 1 2 3 4 5 N/A Hieracium scouleri 1 2 3 4 5 N/A Viola adunca 1 2 3 4 5 N/A Hosackia pinnata (Lotus pinnatus)Present / Absent Viola praemorsa var. nuttallii 1 2 3 4 5 N/A Koeleria macrantha (K. cristata)1 2 3 4 5 N/A Leptosiphon bicolor (Linanthus b.)1 2 3 4 5 N/A Lomatium bradshawii Present / Absent Lomatium nudicaule 1 2 3 4 5 N/A Lomatium triternatum 1 2 3 4 5 N/A Lomatium utriculatum Present / Absent 2023 Thurston County Critical Areas Ordinance (CAO) Prairie Screening Data Sheet *Species Count Class: 1 = < 25 2 = 25 -49 3 = 50 -74 4 = 75 -100 5 = >100 Prairie Plant Manual: cped-cp-docs-Thurston-Prairie-Plant- Manual.pdf (amazonaws.com) 21724130302 & 21724131000 2 RJ Development LLC. Key McMurry, Key Environmental Solutions, LLC. 7/14/23, 8/14/23 Species Notes 1 1 2 2 3 3 4 4 5 5 6 6 7 7 8 8 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 Non-CAO vegetation notes: Prairie Habitat Criteria: If at any point at least three target species, totaling in general at least 25 plants each are encountered within 5 meters of each other (WDFW 2015), the area in question meets the criteria to be established as occurrence of prairie. For certain plants such as WNHP rare plants (indicated here in bold), or species which serves as nectar or host plants for both TCB and either SCC or SGCN butterflies, presence is enough to meet prairie habitat criteria for such species, even if their count is less than 25 individual plants. 5 = >100 Alnus rubra Corylus cornuta Poplus balsamifera trichocapa Crataegus douglasii Pteriduim aquilinum Cirsium vulgare Cirsium arvense Daucus carota Taraxacum officinale Rumex obtusifolius Pseudotsuga menziesii Chamaenerion angustifolium Conyza canadensis var,glabrata Digitalis purpurea Hypochaeris radicata Rubus armeniacus Ilex aquifolium Oemleria cerasiformis Polytrichum juniperinum Hypericum perforatum Angelica genuglexa Chenopodium album Lotus micracanthus Avena sativa Mahonia aquifolium Quercus garryana Dactylis glomerata Leucanthemum vulgare Parentucellia viscosa Lepidium densiforum Matricaria discoidea Plantago lanceolata Trifolium pratense Sambucus racemosa Phalaris arundinacea Geranium robertianum Gaultheria shallon Cytisus scoparius Amelanchier alnifolia Rumex acetosella Symphoricarpos albus Spiraea douglasii Hypericum perforatum Lathyrus nevadensis Tanacetum vulgare Rubus ursinus Vicia americana Trifolium repens Site Name and Parcel # Parcel #: _________________________________________________ Project #: ________________________________________________ Site/Landowner: __________________________________________ How were the data collected? (circle the method for each) Transect: Trimble Garmin Aerial Mounds Trimble Garmin Aerial Notes: ___________________________________________________ Field Team Personnel: (Indicate all staff present, CIRCLE who filled out form) Name: Name: Name: Others onsite (name/affiliation) Site visit # (CIRCLE all that apply) 1st 2nd Unable to screen Notes: Do onsite conditions preclude the need for further visits? Yes No Dense woody cover that encompasses the entire site (trees/shrubs) that appears to preclude any potential MPG use. Impervious Compacted Graveled Flooded Other ______________ Notes: Describe visibility for mound detection: Poor Fair Good Notes: Request mowing? (CIRCLE and DESCRIBE WHERE MOWING IS NEEDED and SHOW ON AERIAL PHOTO Yes No N/A Notes: 20 23 Thurston County Mazama Pocket Gopher Screening Field Form Site Visit Date: ______________ 21724130302 & 21724131000 7/14/2023 1022.01 RJ Development LLC. Key McMurry, Key Environmental Solutions, LLC. SW corner of large parcel was compacted and had been cleared in 2009 Mounds observed over the whole site are characteristic of: Quantify or describe amount of each type and approx. # of mounds Group = 3 mounds or more No MPG mounds (circle) MPG mounds in GPS? (CIRCLE and DESCRIBE) If MPG mounds present, entered in GPS? None All Most Some Notes: Yes No N/A Does woody vegetation onsite match aerial photo? Yes No - describe differences and show on parcel map/aerial: What portion(s) of the property was screened? (CIRCLE and DESCRIBE) All Part - describe and show on parcel map/aerial: Notes - Describe, and show on parcel map/aerial if applicable: Team reviewed and agreed to data recorded on form? (CIRCLE, and EXPLAIN if “No”) Yes No Reviewed by initials: _____ _____ _____ _____ Notes: MPG Mounds Likely MPG Mounds Indeterminate Likely Mole Mounds Mole Mounds The Scotch broom was much more dense covering most of the parcel. Areas of very dense Scotch broom was not able to be walked. KM 0 0 0 0 87 Site Name and Parcel # Parcel #: _________________________________________________ Project #: ________________________________________________ Site/Landowner: __________________________________________ How were the data collected? (circle the method for each) Transect: Trimble Garmin Aerial Mounds Trimble Garmin Aerial Notes: ___________________________________________________ Field Team Personnel: (Indicate all staff present, CIRCLE who filled out form) Name: Name: Name: Others onsite (name/affiliation) Site visit # (CIRCLE all that apply) 1st 2nd Unable to screen Notes: Do onsite conditions preclude the need for further visits? Yes No Dense woody cover that encompasses the entire site (trees/shrubs) that appears to preclude any potential MPG use. Impervious Compacted Graveled Flooded Other ______________ Notes: Describe visibility for mound detection: Poor Fair Good Notes: Request mowing? (CIRCLE and DESCRIBE WHERE MOWING IS NEEDED and SHOW ON AERIAL PHOTO Yes No N/A Notes: 20 23 Thurston County Mazama Pocket Gopher Screening Field Form Site Visit Date: ______________ 21724130302 & 21724131000 8/14/2023 1022.01 RJ Development LLC. Key McMurry, Key Environmental Solutions, LLC. SW corner of large parcel was compacted and had been cleared in 2009 Mounds observed over the whole site are characteristic of: Quantify or describe amount of each type and approx. # of mounds Group = 3 mounds or more No MPG mounds (circle) MPG mounds in GPS? (CIRCLE and DESCRIBE) If MPG mounds present, entered in GPS? None All Most Some Notes: Yes No N/A Does woody vegetation onsite match aerial photo? Yes No - describe differences and show on parcel map/aerial: What portion(s) of the property was screened? (CIRCLE and DESCRIBE) All Part - describe and show on parcel map/aerial: Notes - Describe, and show on parcel map/aerial if applicable: Team reviewed and agreed to data recorded on form? (CIRCLE, and EXPLAIN if “No”) Yes No Reviewed by initials: _____ _____ _____ _____ Notes: MPG Mounds Likely MPG Mounds Indeterminate Likely Mole Mounds Mole Mounds The Scotch broom was much more dense covering most of the parcel. Areas of very dense Scotch broom was not able to be walked. KM 0 0 0 0 91 July 14, 2023 and August 14, 2023 Green is dense Scotch broom