Attach_14_Wetlands_and_other_Waters_Delineation_Report_Nov_4,_2015.pdf

Wetlands and Other Waters Delineation Report Paradise Inn Annex and Snowbridge Rehabilitation Mount Rainier National Park, Washington

November 2015

National Park Service U.S. Department of the Interior

Mount Rainier National Park Washington

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WETLANDS AND OTHER WATERS

DELINEATION REPORT

PARADISE INN ANNEX AND

SNOWBRIDGE REHABILITATION

MOUNT RAINIER

NATIONAL PARK, WASHINGTON

Prepared for—

National Park Service Department of the Interior

Prepared by—

ERO Resources Corporation 1842 Clarkson Street

Denver, Colorado 80218

(303) 830-1188

November 2015

ERO Project #9144 i

CONTENTS

Introduction

Methods Assessment Area Wetland Delineation Cowardin Classification Wetland Functional Assessment Preliminary Jurisdictional Determination

Results Wetlands

Wetland 1 Wetland 2 Wetland 3 Unvegetated Ditches

Cowardin Classification Preliminary Jurisdictional Determination Wetland Functional Assessment

Water Quality Functions Hydrologic Functions Habitat Functions

Conclusions and Recommendations Wetlands and Other Waters

References

TABLES

Table 1. Summary of wetlands and other waters in the Assessment Area Table 2. Summary of wetland functions

FIGURES

Figure 1. Vicinity Map Figure 2. Wetlands Figure 3. Hydrology Figure 4. Watershed Boundary

APPENDICES

Appendix A Species List Appendix B Data Forms – Routine Wetland Determination Appendix C Photos Appendix D Functional Assessment Form

DRAFT WETLANDS AND OTHER WATERS DELINEATION REPORT

PARADISE INN ANNEX AND SNOWBRIDGE REHABILITATION

MOUNT RAINIER NATIONAL PARK, WASHINGTON

NOVEMBER 2015

Introduction Mount Rainier National Park (park) is proposing to rehabilitate the Paradise Inn

Annex and Snowbridge (Figure 1). The proposed project would complete the rehabilitation of the Paradise Inn that began with rehabilitation of the main Paradise Inn building from 2006 to 2008. The Annex and Snowbridge are in danger of collapse from seismic events or excessive snow accumulation and do not meet current safety codes. The proposed project would include installing a new concrete foundation and replacing the existing rubble with a replica veneer created by cutting the backs of the rocks. The project would also include rehabilitation of the Annex building to improve safety and drainage and bring the structure into compliance with modern building codes. Additional descriptions of these activities and an analysis of potential impacts to wetlands and aquatic resources will be provided in the Environmental Assessment, to be completed in

February 2016. Drainage improvements and staging activities proposed as part of the project have the potential to affect wetlands. The NPS retained ERO Resources

Corporation (ERO) to delineate wetlands and other waters potentially affected by the project.

Methods Assessment Area

Delineations of wetlands and other waters were conducted within an area north, east, and south of the Paradise Inn at the park. The area surveyed for wetlands and other waters (Assessment Area) is shown on Figure 2.

Wetland Delineation Before conducting the wetland delineation, ERO researched wetland delineation requirements specific to the Seattle, Washington office of the U.S. Army Corps of

Engineers (Corps). ERO also reviewed National Wetland Inventory maps, U.S.

Geological Survey topographic maps, and aerial photographs of the Assessment Area. On

DRAFT WETLANDS AND OTHER WATERS DELINEATION

August 4 and 5, 2015, Steve Butler, an ecologist with ERO, visited the Assessment Area to map the boundaries of wetlands and other waters (August 2015 site visit). The weather during fieldwork varied from sunny and clear to overcast to light rain.

Wetlands were delineated using methods outlined in the 1987 Corps of Engineers

Wetlands Delineation Manual (Environmental Laboratory 1987), the Regional

Supplement to the Corps Wetland Delineation Manual: Western Mountains, Valleys, and

Coast Region (Version 2.0) (Corps 2010), and NPS Procedural Manual #77-1: Wetland

Protection (NPS 2012). Wetlands were determined based on the presence of three wetland indicators: hydrophytic vegetation, wetland hydrology, and hydric soils. Soil data were collected at representative observation points for each vegetation community.

Hydric soils were assumed at sites where all dominant vegetation consisted of obligate or facultative wetland species (with an abrupt transition to uplands) and wetland hydrology was present. A Munsell Soil Color Chart was used to determine soil color. Wetland indicator status for vegetation (Appendix A) was based on the most current National

Wetland Plant List (Lichvar et al. 2014). The authority for nomenclature for plant species was taken from “The PLANTS Database” (U.S. Department of Agriculture Natural

Resource Conservation Service (USDA NRCS) 2015).

The Assessment Area is within an area of Washington that is experiencing severe to exceptional drought (intensity D2 to D4) according to the United States Drought Monitor program (U.S. Drought Monitor 2015). The winter of 2014-2015 was unseasonably warm and the snowpack was unusually low. The unseasonably warm weather caused a disproportionate amount of precipitation to fall as rain instead of snow. As of May 15, 2015, the total snowfall at Paradise was about 266 inches, compared with 600 inches in an average year, making 2014-2015 one of the lowest total snowfall years on record. The hydrology source for wetlands in the Assessment Area is snowmelt, and the delineation took into account the drier than normal conditions. Park staff indicated that the wetlands mapped in the Assessment Area during the August 2015 site visit are typically saturated at the surface during the growing season in most years. In cooperation with the park, ERO identified patterns of surface flow and mapped the boundaries of the watershed containing the Assessment Area. Surface flow patterns are shown in Figure 3 and the watershed boundary is shown in Figure 4.

Identification of hydric soils in the Assessment Area was complicated by the presence of soils derived from volcanic ash. The soils in the Assessment Area were mapped by the NRCS as Mountwow-Littletahoma-Unicornpeak complex, 10 to 65 percent slopes (USDA NRCS 2015). These soils are derived from volcanic ash over colluvium. Soil pits at DP1 and DP2 (Figure 2) contained identifiable layers of ash, popcorn-sized fragments of pumice, and a layer of rocks likely associated with a past lahar. Indicators of wetland soils may not form in volcanic soils because these soils are inherently low in iron, manganese, and sulfur. In addition, the NPS requested that ERO limit the number of soil pits in the Assessment Area to limit damage to cultural and natural resources. For these reasons, the delineation did not rely on the presence of hydric soil indicators, and hydric soils were assumed where indicators of wetland vegetation and hydrology were present.

Wetland determination data forms were completed at six sample points (Appendix

B). ERO mapped wetland boundaries and data point locations using a Trimble Global

Positioning System (GPS) unit. GPS data were differentially corrected using the

UNAVCO, Greenwater, Washington base station. All differential correction was completed using Trimble Pathfinder Office 5.4 software. All GPS information was recorded as NAD 1983 UTM coordinates. The GPS data were incorporated onto aerial photography at a scale of 1 inch equals 120 feet.

Data forms were completed at representative locations to document wetland and upland conditions (Appendix B). Photos of each wetland are in Appendix C.

Cowardin Classification Classification of wetland or deep water system, subsystem, class, and subclass was based on Cowardin et al. (1979). The Cowardin classification uses a hierarchical structure of systems, subsystems, and classes to classify both wetlands and deepwater habitats.

Wetlands with persistent vegetation are classified in the Cowardin system as palustrine, which typically includes wetlands referred to as marshes, fens, wet meadows, and sloughs. The palustrine system also includes small, shallow, permanent, or intermittent water bodies such as ponds. Palustrine wetlands may be situated shoreward of lakes and river channels, on river floodplains, in isolated catchments, or on slopes (Cowardin et al.

1979). Under the palustrine system, wetlands are classified as emergent (erect, rooted, herbaceous, and usually perennial hydrophytes that remain standing until at least the next growing season); scrub-shrub (woody vegetation less than 20 feet tall); or forested

(woody vegetation 20 feet or taller).

The riverine system includes wetlands and deepwater habitats contained within a channel, with the exception of wetlands dominated by trees, shrubs, and emergent vegetation. The riverine system usually contains flowing water and is bounded on the landward side by uplands, channel banks, or other wetlands. Within the riverine system, wetlands are divided into the tidal, lower perennial (low gradient and slow water), upper perennial (high gradient and fast water), and intermittent subsystems. Within these subsystems, riverine wetlands are further classified as unconsolidated bottom, aquatic bed, streambed, rocky shore, unconsolidated shore, and emergent wetland

(nonpersistent).

Wetland Functional Assessment ERO evaluated wetland functions broadly using the Washington State Wetland

Rating System (Washington Rating System) for Western Washington (Hruby 2014). The

Washington Rating System categorizes wetlands based on specific attributes such as rarity, sensitivity to disturbance, and the functions they provide. This functional assessment method uses a classification system that combines the U.S. Fish and Wildlife

Service’s (Service) Cowardin classification system (Cowardin et al. 1979) with a hydrogeomorphic (HGM) approach (Brinson 1993), and provides a landscape context to the Service classification. HGM classes found in western Washington are saltwater tidal fringe, freshwater tidal fringe, flats, lacustrine fringe, slope, riverine, and depressional.

The Cowardin classification is discussed above.

For each function and value, the Washington Rating System provides a rating of low, moderate, or high based on observations and responses to questions. Once the total functional points for wetlands are calculated, each wetland is assigned to one of four categories. Wetlands are assigned to one of the following categories based on total functional points and other criteria described in the Washington Rating System:

• Category I: Wetlands of exceptionally high quality that are generally rare.

Category I wetlands are those that 1) represent a unique or rare wetland type, or 2) are more sensitive to disturbance than most wetlands, or 3) are relatively undisturbed and contain ecological attributes that are impossible to replace within a human lifetime, or 4) provide a high level of functions. Any risk of degradation to these wetlands should be avoided because their functions and values are too difficult to replace. Generally, these wetlands are not common and make up a small percentage of the wetlands in the region.

• Category II: Category II wetlands are difficult, though not impossible, to replace, and provide high levels of some functions. These wetlands occur more commonly than Category I wetlands but still need a relatively high level of protection.

Category II wetlands in western Washington include: smaller estuarine wetlands, wetlands scoring between 20-22 points (out of 27) on the questions related to the functions present, and interdunal wetlands larger than 1 acre or those in a mosaic.

• Category III: Category III wetlands are 1) wetlands with a moderate level of functions (scores between 16-19 points), 2) can often be adequately replaced with a well-planned mitigation project, and 3) interdunal wetlands between 0.1 and 1 acre in size. Wetlands scoring between 16-19 points generally have been disturbed in some ways and are often less diverse or more isolated from other natural resources in the landscape than Category II wetlands.

• Category IV: Category IV wetlands have the lowest levels of functions (scores fewer than 16 points) and are often heavily disturbed. These wetlands should be able to be replaced, and in some cases improved. However, experience has shown that replacement cannot be guaranteed in any specific case. These wetlands may provide some important functions and need to be protected.

Wetlands with similar characteristics were grouped together for the purposes of the functional assessment if they had similar plant communities and hydrology and provide similar functions. Functional assessment data forms are in Appendix D.

Preliminary Jurisdictional Determination To assist the Corps in making a preliminary jurisdictional determination, ERO reviewed the proximity and potential surface water connection of wetlands and other waters to known jurisdictional waters of the U.S. using aerial photo interpretation. The volume, duration, and frequency of flow in the wetlands were not determined during the field review. Wetlands or waters that have a surface water connection to the Paradise

River or its tributaries may provide more than a speculative or an insubstantial effect on the chemical, physical, or biological integrity of traditionally navigable waters.

Information on potential surface water connections of wetlands and other waters are provided in Table 1.

Table 1. Summary of wetlands and other waters in the Assessment Area.

Feature Label

Wetland Area

(acres)

Cowardin Classification Hydrology Source1 Surface Water Connection to Waters of the U.S.

Wetland 1 0.91

Palustrine emergent persistent/ forested needle-leaved evergreen

Slope seepage, snowmelt, surface runoff

Potential surface water connection to the Paradise River

Wetland 2 0.17 Palustrine emergent persistent

Slope seepage, snowmelt, surface runoff

Potential surface water connection to the Paradise River

Wetland 3 0.28 Palustrine emergent persistent

Slope seepage, snowmelt, surface runoff, snow removal from parking area

Potential surface water connection to the Paradise River

Total 1.36 1Based on topographic position observed in the field and review of aerial photography.

Results Wetlands and other waters in the Assessment Area are described below. Commonly occurring plant species in the Assessment Area are listed in Appendix A.

Wetlands Wetlands in the Assessment Area generally occur in low areas and adjacent slopes where snow persists late into the growing season. Snow-removal activities at the Paradise

Inn parking area may also contribute additional snow to the wetlands. Examination of historical aerial photos on Google Earth showed snow persisting until mid-August in some years. Table 1 summarizes the wetlands mapped in the Assessment Area and lists each wetland name and its wetland type.

Wetland 1 Wetland 1 is in a low area east of the Paradise Inn and slopes to the west. The water source for the wetland is snowmelt, water flowing from Wetland 2 (described below) via a culvert under the parking area to the northwest, and surface runoff from the watershed to the north (Figure 2). A diverse plant community is present in Wetland 1 dominated by

Idaho bent (Agrostis idahoenis), black alpine sedge (Carex nigricans), and Barclay’s willow (Salix barclayi). Other species present include various sedges (Carex sp.), rushes

(Juncus sp.), Lewis’ monkeyflower (Mimulus lewisii), Gray’s licorice root (Ligusticum grayi), arrowleaf groundsel (Senecio triangularis), and many other species. The portions of Wetland 1 closest to the Paradise Inn and Annex have been directly and indirectly affected by past disturbance associated with original construction of the Paradise Inn and

Annex. When the Annex and adjacent parking area were constructed in the 1920, fill material was likely placed in these areas. Despite the past disturbance, these areas have wetland vegetation and hydrology. The portion of Wetland 1 to the south and east is relatively natural and undisturbed. Wetland 1 also contains a small area of forested wetland with a sparse overstory of subalpine fir (Abies lasiocarpa).

Wetland boundaries were identified by a transition to upland and facultative upland species such as blueberry (Vaccinium deliciosus), subalpine lupine (Lupinus arcticus), pink heather (Phyllodoce empetriformis), and leafy aster (Symphotrichum foliaceum).

The change in vegetation between the upland and wetland plant communities is typically distinct and relatively abrupt. Wetland hydrology was indicated by saturation at the surface, surface water, drainage patterns, and a dry-season water table. Not all areas within the wetland were saturated at the surface at the time of the August 2015 site visit;

however, the Assessment Area received lower than normal snowfall during the most recent winter, and park staff indicated the wetland is saturated during a normal year. The soils in the wetland are derived from volcanic ash and are problematic hydric soils, as described above in the Wetland Delineation Methods section.

Wetland 2 Wetland 2 is in a low area north of the Paradise Inn (Figure 2). The water source for the wetland is snowmelt and surface water runoff from surrounding areas. Water flows from Wetland 2 via a culvert at its south end and flows into Wetland 1. Vegetation in

Wetland 2 is dominated by black alpine sedge (Carex nigricans) and showy sedge (C.

spectabilis). Other plant species in Wetland 2 include mountain sedge (Carex scopulorum), Gray’s licorice root, mountain bog gentian (Gentiana calycosa), arrowleaf groundsel, green false hellebore (Veratrum viride), Lewis’ monkeyflower, and Barclay’s willow. Wetland boundaries were identified by a transition to upland and facultative upland species such as blueberry, subalpine lupine, and pink heather. Wetland hydrology was indicated by saturation at the surface, surface water, and drainage patterns. Not all areas within the wetland were saturated at the surface at the time of the August 2015 site visit; however, the Assessment Area received lower than normal snowfall during the most recent winter, and the wetland is likely saturated at the surface in a normal year. The soils in the wetland are derived from volcanic ash and are problematic hydric soils, as described above in the Wetland Delineation Methods section.

Wetland 3 Wetland 3 is in a low area south of the Paradise Inn and Annex, east of the parking lot for the Jackson Visitor Center (Figure 2). The water source for the wetland appears to be primarily snowmelt. Wetland 3 drains via a channel to the west and toward the lower

(easternmost) end of the Paradise parking area, where the Valley Road begins. Some water drains from Wetland 3 via the access road on the west end of the Annex, Wetland 3 hydrology is supplemented by snow removal equipment more than the other wetlands. At the south end of the wetland, water flows into a rock-lined ditch and then into the lower end of Wetland 1. Dominant plant species in Wetland 3 are mountain cinquefoil

(Potentilla flabellifolia), mountain sedge (Carex scopulorum), and Barclay’s willow.

Wetland boundaries were identified by a transition to facultative upland species such as pink heather, subalpine lupine, and partridge foot (Luetkea pectinata). Wetland hydrology was indicated by soil surface cracks, drainage patterns, geomorphic position, and FAC-neutral test. Not all areas within the wetland were saturated at the surface at the time of the August 2015 site visit; however, the Assessment Area received lower than normal snowfall during the most recent winter, and the wetland is likely saturated at the surface in a normal year. The soils in the wetland are derived from volcanic ash and are problematic hydric soils, as described above in the Wetland Delineation Methods section.

Unvegetated Ditches Two unvegetated ditch channels were identified during the August 2015 site visit.

These ditch channels flow southeast and northeast toward a culvert under the Paradise

Valley Road. These two ditch channels are shown in Figure 2.

Cowardin Classification The Assessment Area contains palustrine wetlands. Although shrubs are present in

Wetlands 1 through 3, shrubs generally cover less than 30 percent of the surface area and, thus, most of the wetlands are considered palustrine emergent persistent wetlands. One area within Wetland 1 has a sparse overstory of trees, and was mapped as a palustrine forested wetland. Several small open channels with standing or flowing water are present in the wetlands. These areas were mapped as open waters (Figure 2), but because these channels are less than 6.6 feet deep, they are considered part of the emergent wetlands for the purposes of the Cowardin classification.

Preliminary Jurisdictional Determination Water from Wetlands 1 and 2 flows through a culvert under Paradise Valley Road.

Wetland 3 drains to a culvert which also connects to the culvert under Paradise Valley

Road. From this culvert, water flows south toward the Paradise River. A continuous surface connection to the Paradise River was not verified in the field, but is likely in most years, based on examination of aerial photography and observations of park staff. The

Paradise River is a tributary to the Nisqually River, which has a surface connection to the

Pacific Ocean. Based on the likely connection to the Paradise River, the wetlands in the

Assessment Area are assumed to be jurisdictional waters of the U.S.

Wetland Functional Assessment The portions of Wetland 1 closest to the Paradise Inn and Annex, while still retaining wetland vegetation and hydrology, have been impacted by past disturbance associated with original construction of the Inn and Annex. The portion of the wetland to the south and east is relatively natural and undisturbed. For the purposes of the functional assessment, Wetland 1 was divided into two areas, Wetland 1a, which is relatively unaffected by development, and Wetland 1b, which has been affected by past construction. Wetlands in the Assessment Area are surrounded on all sides by disturbance, including the Paradise Inn and Annex, Paradise Valley Road, and the visitor center parking area. Wetlands 1b and 3 have been modified by construction of the inn and parking area, and continue to be affected by additional runoff and snow-removal activities from nearby parking areas and roads.

The Washington Rating System assigns an overall rating to each wetland from I

(highest functional rating) to IV (lowest functional rating). Functional assessment rankings were based on the following criteria: water quality functions, hydrologic functions, and habitat functions. These functions are described below. The functional assessment ratings of each wetland are provided in Table 2.

Table 2. Summary of wetland functions.

Function Wetlands 1a and 2 Wetland 1b Wetland 3

Improving Water Quality – Site Potential M L M Improving Water Quality – Landscape Potential M M M Improving Water Quality – Value L L L Hydrologic – Site Potential L L L Hydrologic – Landscape Potential M L M Hydrologic – Value L L L Habitat – Site Potential M L L Habitat – Landscape Potential M M M Habitat – Value H M L Overall Wetland Category III IV IV

Key to ratings: H = high, M = medium, L = low.

Water Quality Functions Water quality functions include the potential for the wetland to improve water quality by receiving and retaining pollutants, potentially improving or maintaining the water quality of downstream waters. Wetlands in the assessment area were rated low to moderate for potential to improve water quality because they are expected to receive sediment from surrounding land, are vegetated with wetland vegetation, have limited evidence of ponding, contain a restricted outlet, and are not within a basin or sub-basin with substantial water quality issues.

Hydrologic Functions Hydrologic functions include the potential for the wetland to reduce flooding and erosion by storing water. The hydrologic functions of the wetlands in the assessment area were rated low to moderate because although they receive some runoff from surrounding impervious surfaces, they are “headwater” wetlands and are not subject to overbank flooding. The water source for the wetlands is mostly snow that accumulates in or adjacent to the wetlands, and melts gradually during the growing season; thus, the wetlands are not likely to contribute to or store floodwaters.

Habitat Functions Habitat functions are the potential for the site to provide habitat for wildlife. Wildlife observed in the wetlands during the August 2015 site visit included deer, Cascades frogs, tailed frogs, and songbirds. Cascades frogs and tailed frogs are considered species of concern by NPS. Wildlife habitat in Wetlands 1a and 2 was rated moderate to high because of the presence of a moderate diversity of habitat types (emergent and scrub-shrub vegetation); the presence of permanently flooded, temporarily flooded, and saturated areas; high plant species richness; moderate interspersion of habitats; and the presence of breeding populations of Cascades frogs and tailed frogs. Special habitat features in the Assessment Area include large downed woody debris and undercut banks in a few areas, providing habitat for amphibians. While the area immediately adjacent to the wetlands contains some development such as buildings, roads, and heavily used hiking trails, the surrounding landscape is an extremely scenic area and is an extraordinary natural resource within a national park. Although the wetlands do not provide habitat for any federally listed threatened or endangered species and have not been mapped as locations for any individual Washington Department of Fish and

Wildlife priority species, Wetlands 1a and 2 contain habitat for NPS frog species of concern.

Conclusions and Recommendations Wetlands and Other Waters

There are 1.36 acres of wetlands in the Assessment Area (Table 1). The boundaries of wetlands shown in Figure 2 and the jurisdictional determinations should be considered preliminary until reviewed and approved by the Corps. Prior to placing fill material within the wetlands in the Assessment Area, a Section 404 permit is required from the

Corps and Washington State Department of Ecology.

References Brinson, M.M. 1993. A hydrogeomorphic classification of wetlands. U.S. Army Corps of

Engineers, Waterways Experiment Station. Wetlands Research Program, Technical Report WRP-DE-4.

Cowardin, L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of wetlands and deepwater habitats of the United States. U.S. Fish and Wildlife Service, Office of Biological Services Program. FWS/OBS-79/31.

Environmental Laboratory. 1987. Corps of Engineers Wetland Delineation Manual.

Technical Report Y-87-1, U.S. Army Engineer Waterways Experiment Station, Vicksburg, MS.

Hruby, T. 2014. Washington State Wetland Rating System for Western Washington:

2014 Update. (Publication #14-06-029). Olympia, WA: Washington Department of Ecology.

Lichvar, R.W., M. Butterwick, N.C. Melvin, and W.N. Kirchner. 2014. The National Wetland Plant List: 2014 Update of Wetland Ratings. Phytoneuron 2014-41:1-42.

National Park Service (NPS). 2012. National Park Service Procedural Manual #77-1:

Wetland Protection.

National Park Service (NPS). 2015. Paradise Inn and Annex Rehabilitation Draft Environmental Assessment. [To be prepared in fall 2015]

U.S. Army Corps of Engineers (Corps). 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region (Version 2.0). U.S. Army Engineer Research and Development Center, Vicksburg, MS.

U.S. Department of Agriculture Natural Resource Conservation Service (USDA NRCS).

2015. The PLANTS Database. Available at: http://plants.usda.gov. Last accessed:

August 2015. National Plant Data Center, Baton Rouge, LA 70874-4490 USA.

U.S. Drought Monitor. 2015. National Drought Mitigation Center. Available at:

http://droughtmonitor.unl.edu/Home.aspx. Last accessed: August 5, 2015.

http://plants.usda.gov/

Project Area

Figure 1 Vicinity Map

Mount Rainier National Park – Paradise Inn Wetland Delineation

Portions of this document include intellectual property of ESRI and its licensors and are used herein under license. Copyright © 2015 ESRI and its licensors. All rights reserved.

0 1,500750 Feet

WASHINGTON

Location

Section 13, T15N, R8E; Willamette Meridian UTM NAD 83: Zone 10N; 596668mE, 5182225mN

Latitude, Longitude: 46.786578°N, 121.733459°W

USGS Mount Rainier East, WA Quadrangle Pierce County, Washington Prepared for: NPS

File: 9144 Figure 1.mxd [dlH] August 10, 2015

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Snowbridge

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Wetland 3

Wetland 2

Wetland 1b

Wetland 1b

Wetland 1a

Figure 2 Wetlands

Mount Rainier National Park – Paradise Inn Wetland Delineation

0 12060 Feet

Assessment Area ") Culvert !( Data Point

Stream Channel

Ditch Channel

Culvert

Edge of Disturbed Area

Emergent Wetland

Forested Wetland

Previously Disturbed Area

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Aerial Image: © Copyright 2013 USDA NAIP

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Snowbridge

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Culvert discharges to stream that connects to Paradise River

Wetland 1a

Wetland 3

Wetland 2

Wetland 1b

Wetland 1b

Wetland 1a

Figure 3 Hydrology

Mount Rainier National Park – Paradise Inn Wetland Delineation

0 12060 Feet

Assessment Area

") Culvert

Flow Direction

Edge of Disturbed Area

Wetland

Previously Disturbed Area

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Figure 4 Watershed Boundary

Mount Rainier National Park – Paradise Inn Wetland Delineation

Portions of this document include intellectual property of ESRI and its licensors and are used herein under license. Copyright © 2015 ESRI and its licensors. All rights reserved.

0 2,0001,000 Feet

Project Area Watershed

HUC 8 Watershed Boundary

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A-1

APPENDIX A

SPECIES LIST

Commonly occurring plant species in the Assessment Area.

Common Name Scientific Name Wetland Indicator

Status1

Herbaceous Arrowleaf groundsel Senecio triangularis FACW Bistort Bistorta bistortoides FACW Black alpine sedge Carex nigricans FACW Canby's licorice-root Ligusticum canbyi FAC Cow parsnip Heracleum lanatum FAC Creeping white clover Trifolium repens FAC Dagger-leaf rush Juncus xiphoides FACW Drummond’s rush Juncus drummondii FACW Fireweed Chamaenerion angustifolium FACU Gray's licorice-root Ligusticum grayi FAC Green false hellebore Veratrum viride FAC Horsetail Equisetum arvense FAC Idaho bent Agrostis idahoensis FACW Lakeshore sedge Carex lenticularis FACW Leafy aster Symphotrichum foliaceum FACU Lewis' monkey-flower Mimulus lewisii FACW Merten’s rush Juncus mertensianus OBL Mountain bog gentian Gentiana calycosa FACW Mountain cinquefoil Potentilla flabellifolia FAC Mountain sedge Carex scopulorum OBL Partridge foot Luetkea pectinata FACU Pearly everlasting Anaphalis margaritacea UPL Rosy paintbrush Castilleja parviflora FAC Showy sedge Carex spectabilis FACW Sitka valerian Valeriana sitchensis FAC Subalpine lupine Lupinus arcticus ssp. subalpinus FACU

Shrubs Barclay’s willow Salix barclayi FACW Cascade blueberry Vaccinium deliciosum UPL Pink heather Phyllodoce empetriformis FACU Rosy spirea Spiraea splendens UPL Sitka alder Alnus sinuata FACW Sitka mountain ash Sorbus sitchensis FAC Willow Salix sp. Unknown

Trees Mountain hemlock Tsuga mertensiana FACU Subalpine fir Abies lasiocarpa FACU 1Obligate (OBL) – plants that always occur in standing water or in saturated soils; facultative wet (FACW) – plants that nearly always occur in areas of prolonged flooding or require standing water or saturated soils but may, on rare occasions, occur in nonwetlands; facultative (FAC) – plants that occur in a variety of habitats, including wetland and mesic to xeric nonwetland habitats, but commonly occur in standing water or saturated soils; facultative upland (FACU) – plants that typically occur in xeric or mesic nonwetland habitats but may frequently occur in standing water or saturated soils; and upland (UPL) – plants that almost never occur in water or saturated soils. (Source: Lichvar et al.

2014).

APPENDIX B

DATA FORMS – ROUTINE WETLAND DETERMINATION

US Army Corps of Engineers Western Mountains, Valleys, and Coast – Version 2.0

WETLAND DETERMINATION DATA FORM – Western Mountains, Valleys, and Coast Region

VEGETATION – Use scientific names of plants Tree Stratum (Plot size: ) Absolute

% Cover Dominant Species?

Indicator Status Dominance Test Worksheet:

1. Number of Dominant Species That Are OBL, FACW, or FAC: 3 (A)

2.

3. Total Number of Dominant Species Across All Strata: 3 (B)

4.

50% = , 20% = = Total Cover Percent of Dominant Species That Are OBL, FACW, or FAC: 100 (A/B)

Sapling/Shrub Stratum (Plot size: 10'x20')

1. Salix barclayi 10 yes FACW Prevalence Index worksheet:

2. Total % Cover of: Multiply by:

3. OBL species x1 =

4. FACW species x2 =

5. FAC species x3 =

50% = , 20% = 10 = Total Cover FACU species x4 =

Herb Stratum (Plot size: 10'x20') UPL species x5 =

1. Agrostis idahoensis 40 yes FACW Column Totals: (A) (B)

2. Carex nigricans 40 yes FACW Prevalence Index = B/A =

3. Carex spectabilis 5 no FACW Hydrophytic Vegetation Indicators:

4. Mimulus lewisii 5 no FACW 1 – Rapid Test for Hydrophytic Vegetation

5. Ligusticum grayi 5 no FAC 2 - Dominance Test is >50%

6. Senecio triangularis 2 no FACW 3 - Prevalence Index is <3.01

7. Spirea splendens 2 no UPL

4 - Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) 8.

9. 5 - Wetland Non-Vascular Plants1

10. Problematic Hydrophytic Vegetation1 (Explain) 11.

1Indicators of hydric soil and wetland hydrology must be present, unless disturbed or problematic. 50% = , 20% = 97 = Total Cover

Woody Vine Stratum (Plot size: )

1.

Hydrophytic Vegetation Present?

Yes No 2.

50% = , 20% = = Total Cover

% Bare Ground in Herb Stratum

Remarks: Very diverse plant community - see plant list in delineaton report

Project Site: Paradise Inn Annex and Snowbridge - Mt Rainier NP City/County: NA/Pierce Sampling Date: 8/5/15

Applicant/Owner: NPS State: WA Sampling Point: DP1

Investigator(s): Steve Butler Section, Township, Range:

Landform (hillslope, terrace, etc.): slope and depression Local relief (concave, convex, none): concave Slope (%): 5-30

Subregion (LRR): LRR - A Lat: 46.78623652 Long: -121.7331189 Datum: NAD83

Soil Map Unit Name: Mountwow-Littletahoma-Unicornpeak complex, 10 to 65 percent slopes NWI classification: PEM/PSS

Are climatic / hydrologic conditions on the site typical for this time of year? Yes No (If no, explain in Remarks.)

Are Vegetation , Soil , or Hydrology , significantly disturbed? Are “Normal Circumstances” present? Yes No

Are Vegetation , Soil , or Hydrology , naturally problematic? (If needed, explain any answers in Remarks.)

SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Hydrophytic Vegetation Present? Yes No

Is the Sampled Area within a Wetland? Yes No Hydric Soil Present? Yes No

Wetland Hydrology Present? Yes No

Remarks:

Low area in drainage east of Paradise Inn, including adjecent slope to the west. Volcanic soils. Drought/low snowpack conditions.

SOIL Sampling Point: DP1 Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)

Depth Matrix Redox Features

(inches) Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks

0-2 10YR3/2 100 sandy loam roots and plant material

2-14 10YR3/2 100 sandy loam

14+ 10YR3/2 sandy loam rock/cobbly

1Type: C= Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10)

Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2)

Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12)

Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks)

Depleted Below Dark Surface (A11) Depleted Matrix (F3)

3Indicators of hydrophytic vegetation and wetland hydrology must be present, unless disturbed or problematic.

Thick Dark Surface (A12) Redox Dark Surface (F6)

Sandy Mucky Mineral (S1) Depleted Dark Surface (F7)

Sandy Gleyed Matrix (S4) Redox Depressions (F8)

Restrictive Layer (if present):

Hydric Soils Present? Yes No

Type:

Depth (inches):

Remarks: Problematic hydric soil composed of volcanic ash

HYDROLOGY

Wetland Hydrology Indicators:

Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required)

Surface Water (A1) Water-Stained Leaves (B9) Water-Stained Leaves (B9)

High Water Table (A2) (except MLRA 1, 2, 4A, and 4B) (MLRA 1, 2, 4A, and 4B)

Saturation (A3) Salt Crust (B11) Drainage Patterns (B10)

Water Marks (B1) Aquatic Invertebrates (B13) Dry-Season Water Table (C2)

Sediment Deposits (B2) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9)

Drift Deposits (B3) Oxidized Rhizospheres along Living Roots (C3) Geomorphic Position (D2)

Algal Mat or Crust (B4) Presence of Reduced Iron (C4) Shallow Aquitard (D3)

Iron Deposits (B5) Recent Iron Reduction in Tilled Soils (C6) FAC-Neutral Test (D5)

Surface Soil Cracks (B6) Stunted or Stresses Plants (D1) (LRR A) Raised Ant Mounds (D6) (LRR A)

Inundation Visible on Aerial Imagery (B7) Other (Explain in Remarks) Frost-Heave Hummocks (D7)

Sparsely Vegetated Concave Surface (B8)

Field Observations:

Surface Water Present? Yes No Depth (inches): 12"

Wetland Hydrology Present?

Yes

No

Water Table Present? Yes No Depth (inches): 6"

Saturation Present?

(includes capillary fringe) Yes No Depth (inches): 0"

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available: Anecdotal data from the park indicates this area and the slope to the west is saturated at the surface in a normal year.

Remarks: This part of Washington is experiencing a D2-D4 (moderate to exceptional) drought. Snowpack at Paradise in winter 2014-2015 was less than half of normal.

Project Site: Paradise Inn

% Cover Dominant Species?

Indicator Status Dominance Test Worksheet:

1. Number of Dominant Species That Are OBL, FACW, or FAC: 0 (A)

2.

3. Total Number of Dominant Species Across All Strata: 4 (B)

4.

50% = , 20% = = Total Cover Percent of Dominant Species That Are OBL, FACW, or FAC: 0 (A/B)

Sapling/Shrub Stratum (Plot size: 15' radius)

1. Phyllodoce empetriformis 15 yes FACU Prevalence Index worksheet:

2. Vaccinium deliciosus 10 yes UPL Total % Cover of: Multiply by:

3. Abies lasiocarpa 5 no FACU OBL species x1 =

4. FACW species x2 =

5. FAC species x3 =

50% = 15, 20% = 6 30 = Total Cover FACU species x4 =

Herb Stratum (Plot size: 10' radius) UPL species x5 =

1. Lupinus arcticus 30 yes FACU Column Totals: (A) (B)

2. Symphotrichum foliaceum 15 yes FACU Prevalence Index = B/A =

3. Carex spectabilis 10 no FACW Hydrophytic Vegetation Indicators:

4. Ligusticum grayi 5 no FAC 1 – Rapid Test for Hydrophytic Vegetation

5. Bistorta bistortoides 2 no FACW 2 - Dominance Test is >50%

6. 3 - Prevalence Index is <3.01 7.

4 - Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) 8.

9. 5 - Wetland Non-Vascular Plants1

10. Problematic Hydrophytic Vegetation1 (Explain) 11.

1Indicators of hydric soil and wetland hydrology must be present, unless disturbed or problematic. 50% = 41, 20% = 16.4 82 = Total Cover

Woody Vine Stratum (Plot size: )

1.

Hydrophytic Vegetation Present?

Yes No 2.

50% = , 20% = = Total Cover

Project Site: Paradise Inn Annex and Snowbridge - Mt Rainier NP City/County: NA/Pierce Sampling Date: 8/5/15

Applicant/Owner: NPS State: WA Sampling Point: DP2

Investigator(s): Steve Butler Section, Township, Range:

Landform (hillslope, terrace, etc.): slope Local relief (concave, convex, none): convex Slope (%): 20

Subregion (LRR): LRR - A Lat: 46.78623135 Long: -121.7331035 Datum: NAD83

Soil Map Unit Name: Mountwow-Littletahoma-Unicornpeak complex, 10 to 65 percent slopes NWI classification: N/A

Are climatic / hydrologic conditions on the site typical for this time of year? Yes No (If no, explain in Remarks.)

Are Vegetation , Soil , or Hydrology , significantly disturbed? Are “Normal Circumstances” present? Yes No

Are Vegetation , Soil , or Hydrology , naturally problematic? (If needed, explain any answers in Remarks.)

SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Is the Sampled Area within a Wetland? Yes No Hydric Soil Present? Yes No

Upland adjacent to DP1. Volcanic soils. Drought/low snowpack conditions.

SOIL Sampling Point: DP2 Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)

Depth Matrix Redox Features

(inches) Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks

0-1 10YR3/2 100 sandy loam roots and plant material

1-2 10YR2/1 100 sandy loam

2-15 10YR3/3 100 sandy loam

15+ 10YR3/3 sandy loam rock/cobbly

1Type: C= Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10)

Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2)

Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12)

Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks)

Depleted Below Dark Surface (A11) Depleted Matrix (F3)

3Indicators of hydrophytic vegetation and wetland hydrology must be present, unless disturbed or problematic.

Thick Dark Surface (A12) Redox Dark Surface (F6)

Sandy Mucky Mineral (S1) Depleted Dark Surface (F7)

Sandy Gleyed Matrix (S4) Redox Depressions (F8)

Restrictive Layer (if present):

Hydric Soils Present? Yes No

Type:

Remarks: Problematic soil derived from volcanic ash. Non-hydric because wetland vegetation and hydrology are lacking.

Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required)

Surface Water (A1) Water-Stained Leaves (B9) Water-Stained Leaves (B9)

High Water Table (A2) (except MLRA 1, 2, 4A, and 4B) (MLRA 1, 2, 4A, and 4B)

Saturation (A3) Salt Crust (B11) Drainage Patterns (B10)

Water Marks (B1) Aquatic Invertebrates (B13) Dry-Season Water Table (C2)

Sediment Deposits (B2) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9)

Drift Deposits (B3) Oxidized Rhizospheres along Living Roots (C3) Geomorphic Position (D2)

Algal Mat or Crust (B4) Presence of Reduced Iron (C4) Shallow Aquitard (D3)

Iron Deposits (B5) Recent Iron Reduction in Tilled Soils (C6) FAC-Neutral Test (D5)

Surface Soil Cracks (B6) Stunted or Stresses Plants (D1) (LRR A) Raised Ant Mounds (D6) (LRR A)

Inundation Visible on Aerial Imagery (B7) Other (Explain in Remarks) Frost-Heave Hummocks (D7)

Sparsely Vegetated Concave Surface (B8)

Surface Water Present? Yes No Depth (inches):

Water Table Present? Yes No Depth (inches):

(includes capillary fringe) Yes No Depth (inches):

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks: This part of Washington is experiencing a D2-D4 (moderate to exceptional) drought. Snowpack at Paradise in winter 2014-2015 was less than half of

% Cover Dominant Species?

Indicator Status Dominance Test Worksheet:

1. Number of Dominant Species That Are OBL, FACW, or FAC: 2 (A)

2.

3. Total Number of Dominant Species Across All Strata: 2 (B)

4.

50% = , 20% = = Total Cover Percent of Dominant Species That Are OBL, FACW, or FAC: 100 (A/B)

Sapling/Shrub Stratum (Plot size: )

1. Prevalence Index worksheet:

2. Total % Cover of: Multiply by:

3. OBL species x1 =

4. FACW species x2 =

5. FAC species x3 =

50% = , 20% = = Total Cover FACU species x4 =

Herb Stratum (Plot size: 10' radius) UPL species x5 =

1. Carex nigricans 50 yes FACW Column Totals: (A) (B)

2. Carex spectabilis 20 yes FACW Prevalence Index = B/A =

3. Ligusticum grayi 10 no FAC Hydrophytic Vegetation Indicators:

4. Gentiana calycosa 3 no FACW 1 – Rapid Test for Hydrophytic Vegetation

5. Senecio triangularis 3 no FACW 2 - Dominance Test is >50%

6. 3 - Prevalence Index is <3.01 7.

4 - Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) 8.

9. 5 - Wetland Non-Vascular Plants1

10. Problematic Hydrophytic Vegetation1 (Explain) 11.

1Indicators of hydric soil and wetland hydrology must be present, unless disturbed or problematic. 50% = 43, 20% = 17.2 86 = Total Cover

Woody Vine Stratum (Plot size: )

1.

Hydrophytic Vegetation Present?

Yes No 2.

50% = , 20% = = Total Cover

% Bare Ground in Herb Stratum 14

Remarks: Very diverse plant community - see plant list in delineaton report. Other species present in the wetland include Veratrum viride (FAC), Mimulus lewisii (FACW), Carex scopulorum (OBL), Salix barclayi (FACW), Juncus mertensianus (OBL).

Project Site: Paradise Inn Annex and Snowbridge - Mt Rainier NP City/County: NA/Pierce Sampling Date: 8/5/15

Applicant/Owner: NPS State: WA Sampling Point: DP3

Investigator(s): Steve Butler Section, Township, Range:

Landform (hillslope, terrace, etc.): slope and depression Local relief (concave, convex, none): concave Slope (%): 20

Subregion (LRR): LRR - A Lat: 46.78750568 Long: -121.7332068 Datum: NAD83

Soil Map Unit Name: Mountwow-Littletahoma-Unicornpeak complex, 10 to 65 percent slopes NWI classification: PEM

Are climatic / hydrologic conditions on the site typical for this time of year? Yes No (If no, explain in Remarks.)

Are Vegetation , Soil , or Hydrology , significantly disturbed? Are “Normal Circumstances” present? Yes No

Are Vegetation , Soil , or Hydrology , naturally problematic? (If needed, explain any answers in Remarks.)

SUMMARY OF FINDINGS – Attach site map showing sampling point locations, transects, important features, etc.

Is the Sampled Area within a Wetland? Yes No Hydric Soil Present? Yes No

Low area in drainage south of Paradise Inn, including adjecent slopes toward building. Volcanic soils. Drought/low snowpack conditions.

SOIL Sampling Point: DP3 Profile Description: (Describe to the depth needed to document the indicator or confirm the absence of indicators.)

Depth Matrix Redox Features

(inches) Color (moist) % Color (moist) % Type1 Loc2 Texture Remarks

1Type: C= Concentration, D=Depletion, RM=Reduced Matrix, CS=Covered or Coated Sand Grains. 2Location: PL=Pore Lining, M=Matrix

Hydric Soil Indicators: (Applicable to all LRRs, unless otherwise noted.) Indicators for Problematic Hydric Soils3:

Histosol (A1) Sandy Redox (S5) 2 cm Muck (A10)

Histic Epipedon (A2) Stripped Matrix (S6) Red Parent Material (TF2)

Black Histic (A3) Loamy Mucky Mineral (F1) (except MLRA 1) Very Shallow Dark Surface (TF12)

Hydrogen Sulfide (A4) Loamy Gleyed Matrix (F2) Other (Explain in Remarks)

Depleted Below Dark Surface (A11) Depleted Matrix (F3)

3Indicators of hydrophytic vegetation and wetland hydrology must be present, unless disturbed or problematic.

Thick Dark Surface (A12) Redox Dark Surface (F6)

Sandy Mucky Mineral (S1) Depleted Dark Surface (F7)

Sandy Gleyed Matrix (S4) Redox Depressions (F8)

Restrictive Layer (if present):

Hydric Soils Present? Yes No

Type:

Remarks: Problematic hydric soil derived from volcanic ash. Did not dig soil pit due to NPS concerns about resource impacts. Likely the same as DP1.

Primary Indicators (minimum of one required; check all that apply) Secondary Indicators (2 or more required)

Surface Water (A1) Water-Stained Leaves (B9) Water-Stained Leaves (B9)

High Water Table (A2) (except MLRA 1, 2, 4A, and 4B) (MLRA 1, 2, 4A, and 4B)

Saturation (A3) Salt Crust (B11) Drainage Patterns (B10)

Water Marks (B1) Aquatic Invertebrates (B13) Dry-Season Water Table (C2)

Sediment Deposits (B2) Hydrogen Sulfide Odor (C1) Saturation Visible on Aerial Imagery (C9)

Drift Deposits (B3) Oxidized Rhizospheres along Living Roots (C3) Geomorphic Position (D2)

Algal Mat or Crust (B4) Presence of Reduced Iron (C4) Shallow Aquitard (D3)

Iron Deposits (B5) Recent Iron Reduction in Tilled Soils (C6) FAC-Neutral Test (D5)

Surface Soil Cracks (B6) Stunted or Stresses Plants (D1) (LRR A) Raised Ant Mounds (D6) (LRR A)

Inundation Visible on Aerial Imagery (B7) Other (Explain in Remarks) Frost-Heave Hummocks (D7)

Sparsely Vegetated Concave Surface (B8)

(includes capillary fringe) Yes No Depth (inches): 0"

Describe Recorded Data (stream gauge, monitoring well, aerial photos, previous inspections), if available:

Remarks: This part of Washington is experiencing a D2-D4 (moderate to exceptional) drought. Snowpack at Paradise in winter 2014-2015 was less than half of normal. The lower portions of the wetland contained standing water and drainage patterns. Not all portions of the wetland were saturated at the surface, but likely would be in a normal year.

% Cover Dominant Species?

Indicator Status Dominance Test Worksheet:

1. Number of Dominant Species That Are OBL, FACW, or FAC: 0 (A)

2.

3. Total Number of Dominant Species Across All Strata: 1 (B)

4.

50% = , 20% = = Total Cover Percent of Dominant Species That Are OBL, FACW, or FAC: 0 (A/B)

Sapling/Shrub Stratum (Plot size: 10' radius)

1. Vaccinium deliciosus 80 yes UPL Prevalence Index worksheet:

2. Sorbus sitchensis 5 no FAC Total % Cover of: Multiply by:

3. OBL species x1 =

4. FACW species x2 =

5. FAC species x3 =

50% = 42.5, 20% = 17 85 = Total Cover FACU species x4 =

Herb Stratum (Plot size: ) UPL species x5 =

1. Column Totals: (A) (B)

2. Prevalence Index = B/A =

3. Hydrophytic Vegetation Indicators:

4. 1 – Rapid Test for Hydrophytic Vegetation

5. 2 - Dominance Test is >50%

6. 3 - Prevalence Index is <3.01 7.

4 - Morphological Adaptations1 (Provide supporting data in Remarks or on a separate sheet) 8.

9. 5 - Wetland Non-Vascular Plants1

10. Problematic Hydrophytic…