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HomeMy WebLinkAboutMEP2024-00013 - HMP Habitat Managment Plan - 5/22/2024 rn ee 202-4 - 0001 RECEIVED Habitat Management Plan MAY 22 2124 615 W. Alder Street Parcel: 22125-42-90062 XXXX E North Island Dr Shelton, WA 98584 Mason County Report prepared for: Meagan & Pete Ross 2120 Beverly Beach Dr NW Olympia, WA 98502 Prepared by: Rob Nagel PO Box 2466 Shelton, WA 98584 rob@arctos-environmental.com (360) 229-3118 Arctos Environmen+cd LLG Project: 2024-H M P-004 March 2024 Project:2024-HMP-004 March 2024 Arctos Environmental LLG Table of Contents Overview............................................................................................................1 PropertyDescription...........................................................................................2 Analysisof Impacts.............................................................................................3 MitigationMeasures...........................................................................................4 Monitoring........................................................................................................10 Summary..........................................................................................................10 References........................................................................................................11 Appendix: Site Photos.......................................................................................12 List of Figures Figure1: Vicinity Map.........................................................................................2 Figure2: Site Map...............................................................................................7 i Project: 2024-HMP-004 March 2024 Arr—tos Environmental LLG Habitat Management Plan 22125-42-90062 XXXX E North Island Dr Shelton, WA 98584 Overview This report details a Habitat Management Plan (HMP) for the above referenced property in Mason County, Washington. The purpose of this report is to address adverse impacts from the construction of an unpermitted access road within a Category III Depressional Wetland and to propose an alternate access road that avoids direct impacts to the wetland. The total development area of the existing road within the wetland is ±250ft2. The existing road and proposed road impact an estimated ±3,350ft' within the regulated 110ft wetland buffer. This HMP proposes restoring the area impacted by the unpermitted access road and proposes mitigation to offset the impacts of the proposed access road on the ecological functions of the wetland buffer. Mitigation sequencing has been followed to avoid, minimize, and mitigate impacts to the buffer area by proposing the new road as far from the wetland as possible in an area which minimizes the need to remove trees within the buffer area. Measures include best-management practices for construction planting a restoration and mitigation area with an estimated ±3,100ft2 area combined, and enhancing the ecological functions of the remaining buffer area with placement of large-woody debris (LWD), snag creation, and planting native vegetation to create a sub-canopy layer that is currently lacking (±9,OOOft'). The objectives of this report are as follows: • Identify impacts of the unpermitted road, as well as the proposed relocated road on the wetland and its buffer's ecological functions and fish and wildlife habitat. • Determine mitigation measures that would offset those impacts and result in no-net-loss to ecological functions and fish and wildlife habitat. 1 MASON COUNTY Mason County Permit Center Use: COMMUNITY SERVICES MEP 2.6,A - DODO?) Building,Planning,Environmental Health,Community Health Date Rcvd y,zz— 615 W.Alder St.—Bldg.8,Shelton,Wa 98584 Phone:(360)427-9670 exc 352 ♦Fax:(360)427-7798 OMASON ENVIRONMENTAL PERMIT(RESIDENTIAL):$1 15 RECEIVED Q HABITAT MANAGEMENT PLAN:$300 0 MASON ENVIRONMENTAL PERMIT(NON-RESIDENTIAL):$1500 MAY 2 2 2024 ®CONDITIONAL USE: $2000 615 W. Alder Street Mason County Resource Ordinance(Chapter 17.01 MCC) ENVIRONMENTAL PERMIT APPLICATION The purpose of the Resource Ordinance is to protect Mason County's natural resource lands and critical areas and is under the authority of Chapters 36.32,36.70A,39.34,58.17, 76.09, 84.33, 84.34 and 90.58 RCW. PLEASE PRINT 1.PROPERTY OWNERPeter & Margaret Ross Name: Mailing Address:2120 Beverly Beach Dr NW, Olympia, WA 98502 Work Phone: Home/Cell Phone:(360) 481 -4990 Email Address:weepeet a@gmailxom, mmmrmeagan@gmail.com If an agent is actin or the property owner during the permit process, complete#2. 2.AUTHORIZED AGENT Name: Rob Nagel -Arctos Environmental LLC Mailing Address:PO Box 2466, Shelton, WA 98584 Work Phone:(360) 229-3118 THome/Cell Phone: Email Address:rob@a rctos-envi ron mental.com 3. PROJECT SITExxxx E North Island Dr Site Address:Parcel#: 22125-42-90062 TLegal Description:L 6�SP 111 2Vf1Tf 9 G.L2 SURVEYS 8W.1 1.&3W237 Directions to Site: From the bridge to the island,turn left.Veer right off of E North Island Dr at an orange gate at 3900 E North Island Dr Attach a site plan showing the following: Lot Dimensions,Flood Zones,Existing Structures,Fences, Water Lines, Driveways,Drainage Plans,Shorelines,Septic System,Topography,Proposed Improvements,Easements,North Arrow,and Scale.Also draw a separate topography diagram. Rev.August 2022 4. State which section requires permit: ❑ Long Term Commercial Forest,Chapter 8.52.060 ❑ Frequently Flooded Areas,Chapter 8.52.130 ❑ Mineral Resource Lands,Chapter 8.52.090 ❑ Geologically Hazardous Areas,Chapter 8.52.140 ❑ Critical Aquifer Recharge Area,Chapter 8.52.120 ❑ Seismic Hazard Areas,Chapter 8.52.150 ❑ Erosion Hazard Area,Chapter 8.52.160 ❑ Fish&Wildlife Habitat Conservation Areas,Chapter ❑ In-Holding Lands,Chapter 8.52.070 8.52.170 ® Wetlands,Chapter 8.52.110 5. Identify current use of the property with existing improvements: The property has an existing driveway and a pop-up canopy. 6. Identify and describe the proposed project,including the type of materials to be used,constructionmethods, principle dimensions,and other pertinent information(attach additional sheets,if needed): This project proposes relocating an existing rock driveway outside of a wetland. 7. Describe why the action requiring this permit cannot be avoided. The existing driveway has already been installed and the proposed driveway is as far from the wetland as feasible. 8. Will there be an alteration of a wetland and/or wetland vegetation area(circle one)? Yes O No O 9. Identify any surface water on or adjacent to property(circle one): Saltwater O Lake ® Stream® Pond ® Wetland @ Drainage Ditch Q 10. Identi€y existing septic/sewer connection(circle one): If septic is located on project site,include records. Connected to SepticoConnected to Community Septic O Connected to Sewer©None Existing@ 11. Identify existing water supply(circle one): Public Water Supply O Well O 11.Type of Job(circle one): New O Add O Alteration @ Repair O Demolition O Other: R09 PJA6EL 4_- s/ZO/Zg Print Name Signature Date Rev.August 2022 �,��► MASON COUNTY COMMUNITY SERVICES 2024-0023 615 W ALDER STREET BLD 8 SHELTON, WA 98584 (360) 427-9670 EXT 352 FAX (360) 427-7798 INVOICE - Customer Name PETER & MARGARET ROSS Date 5/22/2024 Address 2120 BEVERLY BEACH DR NW P.O. No. City OLYMPIA State WA ZIP 98502 Rep Phone 1.360.481.4990 FOB Qty Description Unit Price TOTAL 1 MEP2024-00013 $115.00 $115.00 1 HABITAT MANAGEMENT PLAN REVIEW FEE $300.00 $300.00 Please contact Genie with questions 1.360.427.9670 ext.284 or e-mail gmm@masoncountywa.gov �J G �V TOTAL $415.00 Office Use Only For more information or if you have questions, please contact Anna Schaffran 360.427.9670 ext 321 orAschaffran@masoncountywa.gov Project: 2024-HMP-004 March 2024 Arcfos Environmental LLG l I r Figure 1:Vicinity Map of project Property Description & Project Background The parcel is 2.01 acres in size and located in section 25, Township 21 North, Range 2 West. A "grandfathered" road provides access from E North Island Dr to the west end of the property. The access road was built on top of a large depressional wetland and currently bisects the wetland. Two culverts provide a hydrologic connection between the two sides of the bisected wetland. High water levels are matched on both sides of the wetland and water flows back and forth through the culverts. Typical wetland adapted vegetation growing within the wetland includes red alder (Alnus rubra), Oregon ash (Fraxinus latifolia), salmonberry (Rubus spectabilis), and slough sedge (Carex obnupta). The upland vegetation on the property immediately adjacent to the wetland is characterized by Douglas-fir (Pseudotsuga menziesii) sword fern (Polystichum munitum), Salal (Goultheria shallon), and bracken fern (Pteridium aquilinum). A driveway to access the subject parcel was installed recently by the previous owner. The driveway was placed across a narrow portion of the wetland with a ±6-inch pipe installed as a culvert. The current property owners received a County Notice of Violation for the activity, and this report is in response to that violation. The driveway consists of crushed rock occupying ±250ft2 to cross the wetland, and another ±2,000ft2 within the 110ft wetland buffer. 2 Project: 2024-HMP-004 March 2024 Arctos Environmental LLG Analysis of Impacts Vegetated buffers serve an important role in protecting critical public resources from adverse impacts associated with development, as well as providing valuable habitat for native species. Below are the potential adverse impacts to ecological functions associated with the construction of the unpermitted access road and the newly proposed alternative access road within the wetland buffer. - Loss of wildlife habitat The development footprint of the unpermitted access road within the wetland and its buffer is an estimated ±250ft2 and 2,000ft2 respectively. The proposed access road will avoid direct impacts to the wetland, but will occupy ±2,850ft2 of area within the wetland buffer, but within an area that will minimize vegetation removal. Approximately 1,500ft2 of the proposed road will overlap with the existing road within the wetland buffer area for a total estimated area of impact of±3,600ft2. - Impervious surfaces Increasing impervious surfaces on a lot can increase storm water run-off and erosion potential. No trees will be removed for this project and mitigation plantings will improve the remaining buffer's ability to filter sediment and nutrients from any potential runoff from the property. No increased risk of erosion is anticipated if construction BMPs prescribed in this report are followed. - Increased disturbance from noise pollution A temporary increase in noise from construction activities is likely to occur. but activities will be limited to daylight hours, and the project is located in a rural residential area where human noises are a daily occurrence. Also, no known nesting sites or individual occurrences of priority habitats and species have been identified near the project site. 3 Project: 2024-HMP-004 March 2024 Arcfos Environmental LLG - Solar input No trees will be removed in order to implement this plan. Trees planted within the mitigation area will eventually contribute to shading the edge of the wetland from excessive solar input as they mature, which will have a net benefit on the wetland. Mitigation Measures To avoid, minimize, and mitigate for the adverse impacts identified above, the following have been identified as appropriate measures for this project: - Minimizing/avoiding impact Because the unpermitted actions have already happened and there is no way to completely avoid impacts to the wetland and its buffer. This report proposes minimizing impacts to the wetland and its buffer by removing the crushed rock and culvert placed within the wetland and its buffer and constructing an alternative access road outside the delineated edge of the wetland. The proposed access road will follow a path through the wetland buffer that will minimize vegetation removal. The portion of the wetland and buffer impacted by the existing road will be restored. - Best Management Practices for construction Construction activities related to this project will be restricted to favorable weather conditions and best management practices for reducing disturbance will be followed, including erecting silt fencing below the project area, and placing straw over any exposed areas until they are re-vegetated. Any equipment used will be checked daily for leaks and all fuel, lubricant, and chemicals will be stored off-site. - Clustering of development All activities related to this project will be clustered to the extent possible without impacting more of the wetland buffer than necessary. Equipment and materials will be stored outside the buffer when not immediately necessary for construction activities. 4 Project: 2024-HMP-004 March 2024 Arctos Environmental LLG - Noxious weed removal All occurrences of Himalayan blackberry and English holly will be removed. Plants will be hand pulled with as much root material as possible, then bagged and brought to the landfill. - Restoration area within the wetland The crushed rock and culvert placed within the wetland will be removed and graded during the dry months of the summer. The area will be replanted with wetland specific vegetation according to the planting guidelines below. Large-woody debris (LWD) will also be placed within the wetland to enhance the habitat and ecological functions of the wetland. A dense planting of willows will also be installed along the edges of the wetland. The minimum number of native plants required to be installed in order to satisfy this requirement are as follows: o Trees: 5 o Shrubs: 25 o Ferns/ground covers: 40 - Restoration/mitigation area outside of the wetland (within buffer area) A mitigation area of approximately 2,850ft2 will be planted with native trees, shrubs, and ferns according to the planting guidelines below. The minimum number of native plants required to be installed in order to satisfy this requirement are as follows: o Trees: 28 o Shrubs: 110 o Ferns/ground covers: 170 - Enhancement area The approximately 9,000ft2 of remaining wetland buffer that will remain undisturbed will be enhanced to improve its ecological functions and value to society. Enhancement actions will consist of placing LWD from the trees that were previously removed throughout the area. A total of three mature trees will also be girdled by removing a section of bark all 5 Project: 2024-HMP-004 March 2024 Ar'cfos Environmental LLG of the way around the trunk of the trees. This will slowly kill the trees and create snags within the wetland buffer. These snags are very important habitat features in the landscape, which are missing from this area of the buffer. Additionally, a mix of Western red cedar (Thuja plicata) and vine maple (Acer circinatum) will be selectively planted throughout the enhancement area. These will grow slowly and eventually create a valuable sub-canopy habitat layer. Planting Guidelines for the Mitigation Area Earthwork Machinery earthwork will be restricted to the minimum necessary to implement this plan; planting holes for specified vegetation installation will be hand dug. Native Plantings Native plantings will be installed within the mitigation area parallel to the edge of the wetland to achieve the following minimum densities: Trees— 5' on center within the wetland, 10' on center outside the wetland Shrubs — 3' on center within the wetland, 5' on center outside the wetland Ferns/groundcovers — 2' on center within the wetland, 4' on center outside the wetland. The plan calls for installing single trees on 10ft centers, and single shrubs on ±5ft centers. The areas between the trees and shrubs will be filled with ferns or groundcovers on ±4ft centers. Exact placement of installed materials will be up to the landscape installer, following the basic spacing pattern described above. Trees may be installed within 10ft of existing mature trees on site. Installed plants must be flagged to aid in monitoring visits. Native plants suitable for the mitigation area include, but are not limited to the following: Trees: Big-leaf maple (Acer macrophyllum) *Western red cedar (Thuja plicata) *Oregon ash (Froxinus latifolia) *Black Cottonwood (Populus balsomifera **Shorepine (Pinus contorta) 6 Project: 2024-HMP-004 March 2024 /krctos Environmental LLG Shrubs: Salal (Gaultherio shallon) Oregon grape (Mohonia oquifolium) Evergreen huckleberry (Vaccinium ovatum) Beaked hazelnut (Corylus cornuta) Oceanspray (Holodiscus discolor) *Salmonberry (Rubus spectabilis) *Pacific willow (Salix lucida) *Scowlers willow (Salix scouleriano) **Vine maple (Acercircinatum) **Nootka rose (Rosa nutkana) Ferns/groundcovers: Western swordfern (Polystitchum munitum) Wild strawberry (Fragaria virginiana) *Western lady-fern (Athyrium filix femina) *Slough sedge (Carex obnupta) *These plants must be planted within the wetland boundary **These plants should be installed along the edge, but outside the wetland boundary. All planting should occur during winter dormancy. The optimum time for planting is from November to March. Installation Installation of the prescribed vegetation will be performed by experienced landscapers familiar with planting native vegetation in natural settings. Installation will be performed during the first winter planting season after approval of this plan. Installed plants will be flagged to aid in monitoring requirements. Fertilizing Due to the proximity of the mitigation area to the wetland, NO fertilizer will be used during plant installation or maintenance. Project: 2024-HMP-004 March 2024 Arc-to-, Environmental LLG Maintenance Maintenance of the installations will be the responsibility of the property owner. Maintenance is to include any weeding or watering necessary to ensure plant survival for at least five years after the date of installation. 8 Project: 2024-HMP-004 March 2024 Arctos Environmental LLG Monitoring A baseline monitoring report will be submitted to the Mason County Planning Department when all construction is complete and mitigation measures have been implemented. This initial report will establish photo points and document the location and general size of installed vegetation. An annual monitoring report will also be submitted to the county for 3 years to document the success of the mitigation area. If the survival rate of installed vegetation falls below 80% in the first three years, the area will be re-planted to meet the original target densities. The 80% threshold will be assessed annually at each monitoring visit and replanted the following planting season if required. The reports will also include photos from the photo points established in the baseline monitoring report and document any occurrence of noxious weeds in the vicinity of the project site or mitigation area. Any noxious weeds observed will be removed. Summary This report details a Habitat Management Plan (HMP) for the above referenced Property in Mason County, Washington. The purpose of this report is to address adverse impacts from the unpermitted construction of an access road within a category III depressional wetland and its buffer as well as the proposed construction of an alternative access road which avoids direct impacts to the wetland. Mitigation measures have been designed to offset the impacts of the roads on the ecological functions and fish and wildlife habitat of the wetland and its buffer. Measures include wetland and buffer restoration, best-management practices for construction, noxious weed removal, LWD placement, snag creation, and planting a ±3,100ft' mitigation area with native vegetation. Proper implementation of this plan will result in no-net-loss of ecological function to the wetland and its buffer from the development proposed by the applicant. 10 Project: 2024-HMP-004 March 2024 Arc-to-, Environmental LLG References Guard,J. 1995. Wetland Plants of Oregon &Washington. Lone Pine Publishing. 240 pp. Edmonton, Alberta, Canada. Hruby,T. (2014). Washington State Wetland Rating System for Western Washington: 2014 Update. (Publication#14-06-029).Olympia, WA: Washington Department of Ecology. Munsell Color(Firm). (2009). Munsell soil color charts:with genuine Munsell color chips. Grand Rapids, MI Pojar,J. and A. MacKinnon. 1994. Plants of the Pacific Northwest Coast (Revised Edition 2014). Lone Pine Publishing. 528 pp. Vancouver, British Columbia,Canada. United States Department of Agriculture, Natural Resources Conservation Service. 2010. Field Indicators of Hydric Soils in the United States,Version 7.0. L.M.Vasilas, G.W. Hurt, and C.V. Noble (eds.). USDA, NRCS, in cooperation with the National Technical Committee for Hydric Soils. U.S. Army Corps of Engineers 2020. National Wetland Plant List,version 3.4, http://wetland- plants.usace.army.mil/U.S.Army Corps of Engineers, Engineer Research and Development Center Cold Regions Research and Engineering Laboratory, Hanover, NH U.S. Army Corps of Engineers. 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual:Western Mountains,Valleys, and Coast Region (Version 2.0),ed.J. S. Wakeley, R. W. Lichvar, and C.V. Noble. ERDC/EL TR-10-3. Vicksburg, MS: U.S. Army Engineer Research and Development Center. Washington Department of Fish and Wildlife. 2008. Priority Habitat and Species List. Olympia, Washington. 292pp. 11 Project: 2024-HMP-004 March 2024 Arc-to-5 Environmentol LLG Appendix: Site Photos 4 ,. �r N # yf� �'�: ':�• ;�'OF �s �v✓ ✓--'..--.i•v" _ 't .yam _ �'�' �' -.�� � _. _A _ •ten! Site Photo 1:Image showing the unpermitted road where it crosses the Category 111 wetland. 12 Project: 2024-HMP-004 March 2024 Arc-+os Environmental LLG 4 v yy is ,,cs ,.3 - °i-' it,31£•- ar.`-�r� _.✓;x�_ _.y.Y_�-,.a�:f�ir'�.�_�f:. ._�+,:t ��F�: .i�►iiT��"'.. .'�fr3i'►.1�. n��w�'�"`�.. Site Photo 2:Image showing a portion of the proposed mitigation area along the main access road. 13 Project: 2024-HMP-004 March 2024 Rrctos Environmental LLG r� _ t I-V I, A s _ tiA Y } , Site Photo 3:Image showing a portion of the proposed mitigation area along the main access road. 14 Project: 2024-HMP-004 March 2024 Rrctos Environmental LLG 4 Y 1 All f �4>F• S I f f �•K ..sVV..+ hf� t~_ • �la'� b�.4, j A.a ... �A o VkA Site Photo 4:Image showing the location of the proposed alternate access road,which avoids direct impacts to the wetland. 15 Project: 2024-HMP-004 March 2024 Arc+os Environmental LLG �� � I rya /�i� �� S - • .a_ r r / t l a 5 e� _t s i�� _ 'jvw * 4� - L Z�,� k y R • w r _,.. � •tit 5 Site Photo S:Image showing the few saplings which must be removed to allow the new access road to be installed. 16 Project:2024-HMP-004 March 2024 Arc-tos Environmer+oi LLL �rs s .f. T:`e . '} y A, i_ 'A e 4 7 s Site Photo 6:image showing a portion of the proposed mitigation area. 17 Project: 2024-HMP-004 March 2024 Arctos Environmental LLG e 07 e IL e _ , Site Photo 7:Image showing a portion of the proposed mitigation area. 18 n 3� r `r F'>*� Ifs IiR.,�' - r {�J:•� ` .�, a.y�`t � t •;.. /'.l 1• k 'Z id3a Iq �' J�-Q �M'T'�p.1' \fit' t \� - .. \ +•��t, ,S r,,,•� a� 1�' i' .fta g.�':! ALI � /�"�� Y �� J. ., �•�� "�' , t `��►��a. \'1 }ymo�d ���;� � '-«,- . `�+ •� � {• d � � t � fie• d / i /I I / 1 I 1 I • 1 1/I I I I • I "I Project: 2024-HMP-004 March 2024 Arc-to-, Environmental LLG �,�, �► Atwl Awl- elk g2 W- - 44 +� 1` Site Photo 9:Image showing a portion of the proposed mitigation area. 20 Project: 2024-HMP-004 March 2024 Arc+os Environmental LLG r 9- L +' s 7 � t,1jL'e � _ � 'K�`�• eif+'� ..' lip At- � �S� ti i AW, f+� JJt` � "sa. ..�a yr e. •G! -."� - Site Photo 10:Imoge'showing a portion of the proposed mitigation area. 21 Project: 2024-HMP-004 March 2024 ArG+05 Environmental LLG Ir yy *s Site Photo 11:Image showing the mature Douglas fir canopy layer and established shrub layer within the remaining intact buffer area.The HMP proposes planting a sub-canopy layer of understory cedar and vine maple to enhance the habitat. 22 Project: 2024-HMP-004 March 2024 Ar-ctos Environmental LLG F f ` •'..Asa ��-d,. i �� �=�:��,;� as.. ti rT� t• ,. 4 .may ai fit• a't'��,, �, :.�. � w. ��, :�' M> �� shy � �" �i� ���\, �'�►`� �A�.��►},� _ 7� .1• ..,�����...,,,ppp`/////{i{:: r, 'p ." ill mot. Site Photo 12:Image showing some of the invasive English holly observed on-site,which is proposed to be removed as mitigation. 23 Project: 2024-HMP-004 March 2024 Rrc+os Environmentol LLG °I � -;� f hoc ^��" yy •�, 7 uj { : .i, bed Site Photo 13:Image showing the LWD on the property which will be used to enhance the habitat of the wetland restoration and mitigation areas. 24 Project: 2024-HMP-004 March 2024 Arc-to-, Environmental LLG Legend Q 1 - Category III Depresional Wetland ArGt05 C3 2 - 110ft Wetland Buffer i Environmental LLG } ;;,. 3 - 125ft Wetland Structure Setback h, _4_�. '� ` �`����'��; , 4 - Existing "grandfathered" Access Road •�' `" 0 5 - Proposed Alternate Access Road Environmental Consulting I Drone Imagery 6 - Proposed Mitigation & Restoration Areas (t3,100ft2 Total) �� _ '��• "` 4x� t � ' f� t PO Box 2466 7 - Proposed Buffer Enhancement Areas (t9,000ft2 Total) ; . �E•: Shelton, WA 98584 Q Aproximate Parcel Boundaries T3 - www,arctos-environmental.com w Z Q • J r .. a_ 0 • �4. O Q �d 0) CDcOQ � mG- y F .................................................................................... NOW . ..,. , W O0N > o ~UOOUi N .................. N Z O .................................... LL, a-i a. 0O Cif -. -k LLJ Q Uzw Ln Z J y ^ CL 1 .� X 0 w Q s: • Ffl V) Q .... 5 , M•• -- • -• ap created by: Rob Nagel .. t� � March 4th, 2024 Revison: i t,` a• a�. ��, l dr .M- �{ ro.;• �.� � k Nam... _ a_ .R t -� N R rr' `p�,•.y',,,, '` -'+` * " �� + �`'c .Y 0 10 20 30 40 ft 1►'t�y`. `; as 1 s This is not a survey map. Measurements are approximate and _y� l r � z .+".i - > `♦.. > -, Scale: 1 " - 20' b• _ �,, ;: -. � ';- �- must be field verified. .: ..... i•l• � ♦/�J 1. 1