22-104290-AG Updated SEPA Checklist 7-18-23Department of Community Development
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
www.cityoffederalway.com
Bulletin #050 – October 17, 2016 Page 1 of 17 k:\Handouts\Environmental Checklist
SEPA ENVIRONMENTAL CHECKLIST
Purpose of Checklist
Governmental agencies use this checklist to help determine whether the environmental impacts of your
proposal are significant. This information is also helpful to determine if available avoidance, minimization
or compensatory mitigation measures will address the probable significant impacts or if an environmental
impact statement will be prepared to further analyze the proposal.
Instructions for Applicants
This environmental checklist asks you to describe some basic information about your proposal. Please
answer each question accurately and carefully, to the best of your knowledge. You may need to consult with
an agency specialist or private consultant for some questions. You may use “not applicable” or "does not
apply" only when you can explain why it does not apply and not when the answer is unknown. You may also
attach or incorporate by reference additional studies reports. Complete and accurate answers to these
questions often avoid delays with the SEPA process as well as later in the decision-making process.
The checklist questions apply to all parts of your proposal, even if you plan to do them over a period of
time or on different parcels of land. Attach any additional information that will help describe your proposal
or its environmental effects. The agency to which you submit this checklist may ask you to explain your
answers or provide additional information reasonably related to determining if there may be significant
adverse impact.
Instructions for Lead Agencies
Please adjust the format of this template as needed. Additional information may be necessary to evaluate the
existing environment, all interrelated aspects of the proposal and an analysis of adverse impacts. The
checklist is considered the first but not necessarily the only source of information needed to make an
adequate threshold determination. Once a threshold determination is made, the lead agency is responsible
for the completeness and accuracy of the checklist and other supporting documents.
Use of Checklist for Nonproject Proposals
For nonproject proposals (such as ordinances, regulations, plans and programs), complete the applicable
parts of sections A and B plus the SUPPLEMENTAL SHEET FOR NONPROJECT ACTIONS (part D). Please
completely answer all questions that apply and note that the words “project,” “applicant,” and “property or
site” should be read as “proposal,” “proponent,” and “affected geographic area,” respectively. The lead
agency may exclude (for non-projects) questions in Part B - Environmental Elements –that do not contribute
meaningfully to the analysis of the proposal.
Department of Community Development
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
www.cityoffederalway.com
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A. BACKGROUND
1. Name of proposed project, if applicable:
Wild Waves Concomitant Development Agreement (CDA) Amendment
2. Name of applicant:
EPI Realty Holdings, Inc.
3. Address and phone number of applicant and contact person:
Applicant: Contact Person:
Property Owner Ann M. Gygi
Wild Waves Theme & Water Park Hillis Clark Martin & Peterson P.S.
36201 Enchanted Parkway S 999 Third Avenue, Suite 4600
Federal Way, WA 98003 Seattle, WA 98104
(253) 661-8057 (206) 470-7638
4. Date checklist prepared:
April 2023
Updated July 2023
5. Agency requesting checklist:
City of Federal Way
6. Proposed timing or schedule (including phasing, if applicable):
As soon as possible.
7. Do you have any plans for future additions, expansion, or further activity related to or connected with
this proposal? If yes, explain.
Not at this time.
8. List any environmental information you know about that has been prepared, or will be prepared,
directly related to this proposal.
The existing Concomitant Development Agreement was subject to SEPA review in 1998, and the most
recent amendment to the CDA approved in 2017 underwent SEPA review. Any future project
development proposal related to this amendment would be required to undergo project-specific
SEPA review.
Department of Community Development
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
www.cityoffederalway.com
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9. Do you know whether applications are pending for governmental approvals of other proposals directly
affecting the property covered by your proposal? If yes, explain.
Wild Waves Park is operated by a separate entity than the property owner, EPI. Wild Waves
Park has a pending project application to remove two water rides and replace them with one
new water ride. That is a separate application unrelated to this CDA amendment proposal.
10. List any government approvals or permits that will be needed for your proposal, if known.
City of Federal Way approval of proposed amendment to the CDA, under FWRC 19.85.200.
11. Give brief, complete description of your proposal, including the proposed uses and the size of the
project and site. There are several questions later in this checklist that ask you to describe certain
aspects of your proposal. You do not need to repeat those answers on this page. (Lead agencies may
modify this form to include additional specific information on project description.)
The existing CDA covers the entire Wild Waves/Enchanted Parks property, which is
approximately 66.5 acres in size. The CDA prescribes allowed uses and conditions on the
Property, and is subject to a 20-year term, of which approximately 15 years remain. The
proposal is to amend the CDA to extend the term from 20 to thirty years, to improve the ability
of the Park operator to finance Park improvements. The proposal would also amend the CDA to
allow for outright permitted warehousing and distributing uses, and to remove the five-acre
limitation from the currently allowed hotel use. There is no development proposal that
accompanies this amendment request. Any subsequent development proposal would be subject
to project-specific SEPA review. Development conditions, such as height limits and stormwater
requirements, as well as Park operation and improvement provisions, of the existing CDA would
remain as set forth in the CDA and applicable City development regulations.
12. Location of the proposal. Give sufficient information for a person to understand the precise location of
your proposed project, including a street address, if any, and section, township, and range, if known. If
a proposal would occur over a range of area, provide the range or boundaries of the site(s). Provide a
legal description, site plan, vicinity map, and topographic map, if reasonably available. While you
should submit any plans required by the agency, you are not required to duplicate maps or detailed
plans submitted with any permit applications related to this checklist.
The proposal is located entirely internal to the existing Wild Waves Theme and Water Park, a
portion of Sec. 28, 29, 32, and 33, Township 21N, R. 4E, WM, in City of Federal Way, King
County, WA. Wild Waves is located east of and adjacent to I-5 and Milton Road, south of
SR161. The park is bounded by S. 369th Street to the south, and 19th Way South on the east.
B. ENVIRONMENTAL ELEMENTS
1. Earth
a. General description of the site:
(circle one): Flat, rolling, hilly, steep slopes, mountainous, other _____________
b. What is the steepest slope on the site (approximate percent slope)?
Department of Community Development
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Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
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The property generally slopes to Mud Lake at slopes ranging from 1 to 40% slopes.
c. What general types of soils are found on the site (for example, clay, sand, gravel, peat, muck)? If
you know the classification of agricultural soils, specify them and note any agricultural land of
long-term commercial significance and whether the proposal results in removing any of these soils.
The soils found on the site are classified Aldercut (AgC) by the U.S. Soil Conservation Service.
The soil type is gravely sandy soil.
d. Are there surface indications or history of unstable soils in the immediate vicinity? If so, describe.
None known.
e. Describe the purpose, type, total area, and approximate quantities and total affected area of any
filling, excavation, and grading proposed. Indicate source of fill.
None anticipated with the CDA Amendment. There is no development proposal related to this
amendment request.
f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe.
NA to the non-project CDA amendment proposal.
g. About what percent of the site will be covered with impervious surfaces after project construction
(for example, asphalt or buildings)?
NA to the non-project CDA amendment proposal.
h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any:
NA to the non-project CDA amendment proposal.
2. Air
a. What types of emissions to the air would result from the proposal during construction, operation,
and maintenance when the project is completed? If any, generally describe and give approximate
quantities if known.
NA to the non-project CDA amendment proposal..
b. Are there any off-site sources of emissions or odor that may affect your proposal? If so, generally
describe.
NA to the non-project CDA amendment proposal.
c. Proposed measures to reduce or control emissions or other impacts to air, if any:
NA to the non-project CDA amendment proposal.
3. Water
Department of Community Development
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
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a. Surface Water:
1) Is there any surface water body on or in the immediate vicinity of the site (including year-round and
seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type and provide names. If
appropriate, state what stream or river it flows into.
Yes, “Mud Lake” is a closed depression pond located in the Park. As a surface water
retention pond in a closed depression “Mud Lake” is not subject to regulations under FWRC
Ch. 15.05, “Shoreline Management” and Ch. 15.10, “Environmentally Critical Areas” of the
FWCC. See Section 3.3.1 of the Development Agreement.
2) Will the project require any work over, in, or adjacent to (within 200 feet) the described waters? If
yes, please describe and attach available plans.
NA to the non-project CDA amendment proposal.
3) Estimate the amount of fill and dredge material that would be placed in or removed from surface
water or wetlands and indicate the area of the site that would be affected. Indicate the source of fill
material.
NA to the non-project CDA amendment proposal.
4) Will the proposal require surface water withdrawals or diversions? Give general description,
purpose, and approximate quantities if known.
NA to the non-project CDA amendment proposal.
5) Does the proposal lie within a 100-year floodplain? If so, note location on the site plan.
No.
6) Does the proposal involve any discharges of waste materials to surface waters? If so, describe the
type of waste and anticipated volume of discharge.
NA to the non-project CDA amendment proposal.
b. Ground Water:
1) Will groundwater be withdrawn from a well for drinking water or other purposes? If so, give a
general description of the well, proposed uses and approximate quantities withdrawn from the well.
Will water be discharged to groundwater? Give general description, purpose, and approximate
quantities if known.
No.
2) Describe waste material that will be discharged into the ground from septic tanks or other sources, if
any (for example: domestic sewage; industrial, containing the following chemicals. . . ; agricultural;
etc.). Describe the general size of the system, the number of such systems, the number of houses to
be served (if applicable), or the number of animals or humans the system(s) are expected to serve.
Department of Community Development
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
www.cityoffederalway.com
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NA to the non-project CDA amendment proposal.
c. Water runoff (including stormwater):
1) Describe the source of runoff (including storm water) and method of collection and disposal, if any
(include quantities, if known). Where will this water flow? Will this water flow into other waters? If
so, describe.
Stormwater from the site is collected in an existing storm drain system and discharged into
the existing drainage system. No changes to stormwater management are included with this
proposal. Any future change of use proposal would need to meet the current stormwater code at the
time of application.
2) Could waste materials enter ground or surface waters? If so, generally describe.
NA to the non-project CDA amendment proposal..
3) Does the proposal alter or otherwise affect drainage patterns in the vicinity of the site? If so, describe.
NA to the non-project CDA amendment proposal.
d. Proposed measures to reduce or control surface, ground, and runoff water, and drainage pattern
impacts, if any:
NA to the non-project CDA amendment proposal.
4. Plants
a. Check the types of vegetation found on the site:
____deciduous tree: alder, maple, aspen, other
_X__evergreen tree: fir, cedar, pine, other
_X__shrubs
_X___grass
____pasture
____crop or grain
____ Orchards, vineyards or other permanent crops.
____ wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other
____water plants: water lily, eelgrass, milfoil, other
____other types of vegetation
b. What kind and amount of vegetation will be removed or altered?
NA to the non-project CDA amendment proposal
c. List threatened and endangered species known to be on or near the site.
None known.
d. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on
the site, if any:
Department of Community Development
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
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NA to the non-project CDA amendment proposal.
e. List all noxious weeds and invasive species known to be on or near the site.
None known.
5. Animals
a. List any birds and other animals which have been observed on or near the site or are known to be on
or near the site. Examples include:
birds: hawk, heron, eagle, songbirds, other:
mammals: deer, bear, elk, beaver, other:
fish: bass, salmon, trout, herring, shellfish, other:
b. List any threatened and endangered species known to be on or near the site.
None known.
c. Is the site part of a migration route? If so, explain.
The property falls within the Pacific Fly Migration route, which includes the entire state of
Washington.
d. Proposed measures to preserve or enhance wildlife, if any:
NA to the non-project CDA amendment proposal.
e. List any invasive animal species known to be on or near the site.
None known.
6. Energy and Natural Resources
a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet the
completed project's energy needs? Describe whether it will be used for heating, manufacturing, etc.
NA to the non-project CDA amendment proposal.
b. Would your project affect the potential use of solar energy by adjacent properties? If so, generally
describe.
No. There is no proposal to change existing height limits or setbacks on the Property.
c. What kinds of energy conservation features are included in the plans of this proposal? List other
proposed measures to reduce or control energy impacts, if any:
NA to the non-project CDA amendment proposal.
Department of Community Development
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
www.cityoffederalway.com
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7. Environmental Health
a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and
explosion, spill, or hazardous waste, that could occur as a result of this proposal? If so, describe.
1) Describe any known or possible contamination at the site from present or past uses.
None known.
2) Describe existing hazardous chemicals/conditions that might affect project development and
design. This includes underground hazardous liquid and gas transmission pipelines located
within the project area and in the vicinity.
None known.
3) Describe any toxic or hazardous chemicals that might be stored, used, or produced during the
project's development or construction, or at any time during the operating life of the project.
NA to the non-project CDA amendment proposal. No change of use is proposed that
depends upon toxic or hazardous chemical usage.
4) Describe special emergency services that might be required.
None anticipated with the CDA Amendment.
5) Proposed measures to reduce or control environmental health hazards, if any:
None proposed with the CDA Amendment.
b. Noise
1) What types of noise exist in the area which may affect your project (for example: traffic,
equipment, operation, other)?
Existing noise in the area is from off-site traffic (I-5 and Milton Road), mechanical noise
from existing amusement attractions and loud voices from park visitors and riders of the
park attractions. No types of noise in the area are anticipated to affect the uses addressed
by the proposed CDA amendment.
2) What types and levels of noise would be created by or associated with the project on a short-
term or a long-term basis (for example: traffic, construction, operation, other)? Indicate what
hours noise would come from the site.
None anticipated with the CDA Amendment.
3) Proposed measures to reduce or control noise impacts, if any:
None proposed with the CDA Amendment. Project-level noise impacts would be
addressed with project-level SEPA review.
Department of Community Development
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
www.cityoffederalway.com
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8. Land and Shoreline Use
a. What is the current use of the site and adjacent properties? Will the proposal affect
current land uses on nearby or adjacent properties? If so, describe.
Current use of the site is Amusement Park. The site is entirely surrounded by right
of way. Nearby uses include residential and the I 5 Freeway. The proposal will not
directly affect nearby land uses.
b. Has the project site been used as working farmlands or working forest lands? If so,
describe. How much agricultural or forest land of long-term commercial significance will
be converted to other uses as a result of the proposal, if any? If resource lands have not
been designated, how many acres in farmland or forest land tax status will be converted
to nonfarm or nonforest use?
No.
1) Will the proposal affect or be affected by surrounding working farm or forest land
normal business operations, such as oversize equipment access, the application of
pesticides, tilling, and harvesting? If so, how:
No.
c. Describe any structures on the site.
The amusement park contains a variety of rides and support facilities.
d. Will any structures be demolished? If so, what?
None proposed with the CDA Amendment.
e. What is the current zoning classification of the site?
The current zoning classification is Office Park (OP4) and subject to the existing CDA.
f. What is the current comprehensive plan designation of the site?
The Comprehensive Plan designation of the site is Commercial Recreation. The
Comprehensive Plan CR designation recognizes that the CDA has established the Office-Park
4 zoning for the Property.
g. If applicable, what is the current shoreline master program designation of the site?
Not Applicable.
h. Has any part of the site been classified as a critical area by the city or county? If so, specify.
Parcel Q of the site (as shown on Exhibit J to the CDA) may include sensitive area(s).
Department of Community Development
33325 8th Avenue South
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253-835-2607; Fax 253-835-2609
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i. Approximately how many people would reside or work in the completed project?
No one resides on the property; it is not zoned for residential use and the proposal does not
request residential use. Also, because there is no project development associated with the
proposal, no new employees will be required in connection with the CDA Amendment. A
project-level SEPA analysis would be required with any specific project proposal involving a
change of use from Commercial Recreation on the property.
j. Approximately how many people would the completed project displace?
None.
k. Proposed measures to avoid or reduce displacement impacts, if any:
None proposed with the CDA Amendment.
l. Proposed measures to ensure the proposal is compatible with existing and projected land
uses and plans, if any:
The proposal includes only uses that are already approved under the CDA, but allows greater
flexibility to implement warehouse and distribution and hotel uses. There is no request to
change the current height limits in the CDA that pertain to those uses. Project-level SEPA
review would be required for any warehouse/distribution or hotel project proposal under the
amended CDA.
m. Proposed measures to reduce or control impacts to agricultural and forest lands of long-term
commercial significance, if any:
Not applicable.
9. Housing
a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low-
income housing.
None.
b. Approximately how many units, if any, would be eliminated? Indicate whether high-, middle-, or
low-income housing.
None.
c. Proposed measures to reduce or control housing impacts, if any:
Not applicable.
10. Aesthetics
Department of Community Development
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a. What is the tallest height of any proposed structure(s), not including antennas; what is the principal
exterior building material(s) proposed?
No structures are proposed with the CDA amendment. No changes to existing height limits
are proposed with the amendment.
b. What views in the immediate vicinity would be altered or obstructed?
No views are proposed to be obstructed or altered with the CDA amendment.
c. Proposed measures to reduce or control aesthetic impacts, if any:
None proposed.
11. Light and Glare
a. What type of light or glare will the proposal produce? What time of day would it mainly occur?
No light or glare is proposed with the CDA Amendment.
b. Could light or glare from the finished project be a safety hazard or interfere with views?
No light or glare is proposed with the CDA Amendment.
c. What existing off-site sources of light or glare may affect your proposal?
None.
d. Proposed measures to reduce or control light and glare impacts, if any:
None.
12. Recreation
a. What designated and informal recreational opportunities are in the immediate vicinity?
Enchanted Parks is an amusement park/water park which provides a wide variety of
recreational opportunities for visitors of all ages.
b. Would the proposed project displace any existing recreational uses? If so, describe.
No. The proposal to amend the CDA would extend the CDA term to improve financeability
for Park improvements. The proposal also would increase flexibility in the future for other
uses already allowed under the CDA.
c. Proposed measures to reduce or control impacts on recreation, including recreation opportunities to
be provided by the project or applicant, if any:
None applicable.
Department of Community Development
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
www.cityoffederalway.com
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13. Historic and Cultural Preservation
a. Are there any buildings, structures, or sites, located on or near the site that are over 45 years old listed
in or eligible for listing in national, state, or local preservation registers ? If so, specifically describe.
None known.
b. Are there any landmarks, features, or other evidence of Indian or historic use or occupation? This
may include human burials or old cemeteries. Are there any material evidence, artifacts, or areas of
cultural importance on or near the site? Please list any professional studies conducted at the site to
identify such resources.
None known.
c. Describe the methods used to assess the potential impacts to cultural and historic resources on or
near the project site. Examples include consultation with tribes and the department of archeology
and historic preservation, archaeological surveys, historic maps, GIS data, etc.
Not applicable.
d. Proposed measures to avoid, minimize, or compensate for loss, changes to, and disturbance to
resources. Please include plans for the above and any permits that may be required.
Not applicable.
14. Transportation
a. Identify public streets and highways serving the site or affected geographic area and describe
proposed access to the existing street system. Show on site plans, if any.
The Wild Waves Park facility is served from the north by SR 161 and from the west by
Milton Road.
b. Is the site or affected geographic area currently served by public transit? If so, generally describe. If
not, what is the approximate distance to the nearest transit stop?
The nearest known transit stop is the existing Park and Ride lot at South 348th Street and 9th
Avenue South.
c. How many additional parking spaces would the completed project or non-project proposal have?
How many would the project or proposal eliminate?
No additional parking spaces are proposed and no parking spaces will be eliminated with the
CDA Amendment. Parking needs would be evaluated as part of any future project-level
proposal.
Department of Community Development
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
www.cityoffederalway.com
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d. Will the proposal require any new or improvements to existing roads, streets, pedestrian, bicycle or
state transportation facilities, not including driveways? If so, generally describe (indicate whether
public or private).
No. This proposal will not generate additional traffic over present levels. The applicant has
prepared a programmatic level transportation analysis including trip generation estimates
that could be associated with property use changes under the CDA amendment, which is
attached as Attachment 1, and a supplemental transportation memorandum addressing
combined uses, attached as Attachment 2. A project-level SEPA analysis would be required
with any specific project proposal involving a change of use from Commercial Recreation on
the property. The programmatic transportation analysis forecasts that vehicle trips associated
with the Property would decrease if a change of use from Commercial Recreation to
warehouse distribution or hotel use were to occur in the future.
e. Will the project or proposal use (or occur in the immediate vicinity of) water, rail, or air transportation?
If so, generally describe.
No.
f. How many vehicular trips per day would be generated by the completed project or proposal? If
known, indicate when peak volumes would occur and what percentage of the volume would be
trucks (such as commercial and nonpassenger vehicles). What data or transportation models were
used to make these estimates?
No vehicular trips will be generated by the proposed CDA amendment.
g. Will the proposal interfere with, affect or be affected by the movement of agricultural and forest
products on roads or streets in the area? If so, generally describe.
No.
h. Proposed measures to reduce or control transportation impacts, if any:
Because the requested CDA amendment does not include any project development proposal,
no new transportation management measures are proposed.
15. Public Services
a. Would the project result in an increased need for public services (for example: fire protection,
police protection, public transit, health care, schools, other)? If so, generally describe.
No additional public services are proposed with the CDA Amendment.
b. Proposed measures to reduce or control direct impacts on public services, if any.
None proposed with the CDA Amendment.
16. Utilities
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D. SUPPLEMENTAL SHEET FOR NONPROJECT ACTIONS
(IT IS NOT NECESSARY to use this sheet for project actions)
Because these questions are very general, it may be helpful to read them in conjunction with the list of the
elements of the environment. When answering these questions, be aware of the extent the proposal, or the
types of activities likely to result from the proposal, would affect the item at a greater intensity or at a faster
rate than if the proposal were not implemented. Respond briefly and in general terms.
1. How would the proposal be likely to increase discharge to water; emissions to air; production, storage,
or release of toxic or hazardous substances; or production of noise?
No such increases are anticipated to occur with the non-project proposal. A future change of use
to hotel or warehouse and distribution could increase impervious area and discharge to water,
but are not anticipated to increase production, storage, or release of toxic or hazardous
substances. A future principal use of warehouse and distribution could increase the number of
trucks accessing the site, which could increase emissions to air, or truck noise. Warehouse HVAC
systems could generate noise.
Proposed measures to avoid or reduce such increases are:
Any future change of use development proposal would need to meet the current stormwater code
at the time of application. If a future warehouse use is proposed, the site is large enough to
accommodate a warehouse site design that would provide ample distance to the property
boundary to attenuate any excess noise. In addition future uses must meet the City’s noise code
and OSHA requirements for worker safety, compliance with which would be evaluated at the
time of application. Operating controls on idling trucks can attenuate air emissions and noise.
Noise mitigation measures, if demonstrated to be needed at the project-level, can include
temporary construction noise barriers, and/or permanent noise barriers around truck
courtyards, enclosure of HVAC units and other sound dampening measures to be addressed at
the time of project proposal.
2. How would the proposal be likely to affect plants, animals, fish, or marine life?
The proposal is for an existing developed site. No such increases are anticipated to occur with the
proposal.
Proposed measures to protect or conserve plants, animals, fish, or marine life are:
A project-level SEPA analysis would be required with any specific project proposal involving a
change of use from Commercial Recreation on the property.
3. How would the proposal be likely to deplete energy or natural resources?
No such depletions are anticipated to occur with the proposal.
Department of Community Development
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253-835-2607; Fax 253-835-2609
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Proposed measures to protect or conserve energy and natural resources are:
Compliance with building and regulatory codes and inclusion of energy conservation measures
and reusable energy sources at the project stage can provide effective mitigation.
4. How would the proposal be likely to use or affect environmentally sensitive areas or areas designated
(or eligible or under study) for governmental protection; such as parks, wilderness, wild and scenic
rivers, threatened or endangered species habitat, historic or cultural sites, wetlands, floodplains, or prime
farmlands?
The proposal is for an existing developed site. No use of or impacts to environmentally sensitive
areas, parks, wilderness, river, threatened or endangered species habitats, historic or cultural
sites, wetlands, floodplains or prime farmlands are anticipated to occur with the proposal.
Proposed measures to protect such resources or to avoid or reduce impacts are:
Compliance with regulatory codes at the project stage generally protects environmentally
sensitive areas. A project-level SEPA analysis would be required with any specific project
proposal involving a change of use from Commercial Recreation on the property and would
identify any specific impacts not adequately mitigated by regulations. Mitigation measures would
need to be designed to meet the identified impact.
5. How would the proposal be likely to affect land and shoreline use, including whether it would allow or
encourage land or shoreline uses incompatible with existing plans?
The Property is not within the shoreline jurisdiction, and there are no associated shoreline
impacts.
The proposal may facilitate investment in future Park improvements, which are subject to
existing development standards under the CDA and applicable City code provisions. If the Park
were to close, the proposal would encourage transition to another allowed commercial use under
the CDA, however, those land uses would be consistent, not incompatible, with existing plans, and
proposed development would be subject to project-level SEPA review.
Proposed measures to avoid or reduce shoreline and land use impacts are:
The proposal does not include changing any height limits associated with the uses for which
greater flexibility is requested, thereby avoiding land use impacts. Future project-level change of
use proposals would be subject to SEPA review. The site is of adequate size to allow building
setbacks, buffers and landscaping to mitigate developed conditions.
6. How would the proposal be likely to increase demands on transportation or public services and utilities?
The proposed CDA amendment would not have any direct impact on transportation, public
services or utilities. The applicant has prepared a programmatic level transportation analysis
including trip generation estimates that could be associated with property use changes under the
Department of Community Development
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
www.cityoffederalway.com
Bulletin #050 – October 17, 2016 Page 17 of 17 k:\Handouts\Environmental Checklist
CDA amendment, which is attached as Attachment 1. In response to City comments, the
applicant has provided a supplemental Transportation Memo that addresses trip generation
levels associated with combined uses including hotel or warehousing with Park uses, using the
ITE trip generation manual 8th edition (2002-2003), at Attachment 2. The programmatic
transportation analysis forecasts that vehicle trips associated with the Property would decrease if
a change of use from Commercial Recreation to warehouse distribution or hotel use were to occur
in the future.
The site is presently served by water, sanitary sewer, and electricity, natural gas and telephone. It
is not anticipated that the proposed change allowing hotel and warehousing as principal uses on
the site would require additional utilities or public services or create significant impacts to public
services or utilties.
Proposed measures to reduce or respond to such demand(s) are:
By potentially shortening the length of time that the Property remains vacant awaiting
entitlement to a potential new use, the proposal could mitigate demands on public services.
Vacant properties in the post-covid environment present a particular public health and safety
challenge, demanding heightened police, medic and fire services to respond to unlawful activities
that are attracted to vacant properties.
A project-level SEPA analysis would be required with any specific project proposal involving a
change of use from Commercial Recreation on the property or adding a new prinicipal use to the
property.
7. Identify, if possible, whether the proposal may conflict with local, state, or federal laws or requirements
for the protection of the environment.
No anticipated conflicts between the proposal and local, state or federal laws or requirements for
the protection of the environment.
12131 113th Avenue NE, Suite 203, Kirkland, WA 98034 | 425.821.3665 |
MEMORANDUM
Date: April 26, 2023 TG:1.22327.00
To: Keith Niven, Community Development Director, City of Federal Way
From: Dan McKinney and Stefanie Herzstein, PE
cc: Ann Gygi, Hillis Clark Martin & Peterson P.S.
Subject: Enchanted Parks Concomitant Agreement Amendment – Trip Generation for
proposed Hotel and Warehouse uses
The following memo provides trip generation characteristics associated with the land uses that
could be developed as part of the proposed Concomitant Development Agreement (CDA)
amendment between the City of Federal Way and Enchanted Parks, Inc.
The existing CDA covers the entire Wild Waves/Enchanted Parks property, which is approximately
66.5 acres in size. The CDA prescribes allowed uses and conditions on the Property, and is
subject to a 20-year term, of which approximately 15 years remain. The applicant proposal is to
amend the CDA to extend the term from 20 to 30 years to improve the ability of the Park operator
to finance Park improvements. The proposal would also amend the CDA to allow for outright
permitted warehousing and remove the five-acre limitation from the currently allowed hotel use.
There is no development proposal that accompanies this CDA amendment request. Any
subsequent development proposal would be subject to project-specific SEPA review.
To provide context, trip generation characteristics associated with a potential warehouse or hotel
use are compared to the existing approved and mitigated traffic from the Park. In general, the
peak traffic characteristics for the Park are higher than what a warehouse or hotel use would
generate on the site.
Trip Generation
Mitigated Trip Generation for the Existing Park
This section outlines the existing trip generation or levels of vehicular traffic that have been
approved for the Park. Section 4.3 of the Concomitant Development Agreement between
Enchanted Parks and the City of Federal Way outlines that traffic generated by the existing uses
and activities on the Enchanted Park Property has been mitigated up to the attendance and trip
levels established in the year 2002 as set forth in Table 1 of Section 4.3. A copy of CDA Table 1 is
provided below.
Attachment 1
2
As illustrated in Table 1 of the CDA, the existing Park is mitigated to a level of 413 PM peak hour
trips on an average day.
Trip Generation for Alternative Land Uses
This section outlines trip generation associated with alternative land uses that are proposed as
part of the revised CDA. Calculations and comparison of trip generation associated with both Hotel
and Warehousing land uses are provided. Weekday Daily, AM and PM peak hour trip generation
for the two uses are estimated based on the land use size and trip rates from the Institute of
Transportation Engineers’ (ITE) Trip Generation Manual, 11th Edition for Hotel (LU 310) and for
Warehousing (LU150).
The Hotel land use was assumed to include 450 rooms and is summarized in the table below.
As shown, a 450-room hotel would generate 266 PM peak hour trips during a typical weekday.
This hotel trip generation is 147 PM peak hour trips less than the 413 average day PM peak hour
trips approved in the current CDA.
3
The Warehousing land use was assumed to include 1,000,000 square-feet of space and is
summarized in the table below.
As shown, a 1,000,000 square-foot warehouse would generate 180 PM peak hour trips during a
typical weekday. This warehousing trip generation is 233 PM peak hour trips less than the 413
average day PM peak hour approved in the current CDA.
Summary
The Hotel or Warehouse land uses that could be developed as part of the proposed Concomitant
Development Agreement between the City of Federal Way and Enchanted Parks, Inc. would result
in less PM peak hour traffic than what is currently approved in the existing Agreement.
12131 113th Avenue NE, Suite 203, Kirkland, WA 98034 | 425.821.3665 |
MEMORANDUM
Date: July 17, 2023 TG:1.22327.00
To: Keith Niven, Community Development Director, City of Federal Way
From: Dan McKinney and Stefanie Herzstein, PE
cc: Ann Gygi, Hillis Clark Martin & Peterson P.S.
Subject: Enchanted Parks Concomitant Agreement Amendment – Response to Public
Works Traffic Comments
The following memo responds to technical review comments from the City of Federal Way Public
Works Traffic Division in a letter to Ann Gygi dated June 2, 2023. This specifically responds to
comments 3 and 4, which are as follows:
3) Need professional trip generation information that addresses having multiple uses on the
property at the same time, such as regional commercial recreation facility and warehousing.
4)Trip generation for any new proposal would be based on ITE trip generation manual 8th edition
(2002-2003).
In response to these comments, updated trip generation calculations are provided below using the
ITE trip generation manual 8th Edition. Trip generation was calculated for a few scenarios to
illustrate the volume of traffic that could be generated by other uses being proposed as part of the
updated Concomitant Development Agreement (CDA).
This section outlines trip generation associated with alternative land uses that are proposed as
part of the revised CDA. Calculations and comparison of trip generation associated with Hotel,
Warehousing, Resort Hotel, and mix of Hotel and Warehousing land uses are provided. It is not
anticipated that this facility would be able to exist with another land use; however, a scenario
assuming half of the facility remains, and half of another use is proposed is provided below.
Weekday Daily, AM and PM peak hour trip generation are estimated based on the land use size
and trip rates from the Institute of Transportation Engineers’ (ITE) Trip Generation Manual, 8th
Edition for Hotel (LU 310), Resort Hotel (LU 330) and for Warehousing (LU150).
All Hotel Land Use
The Hotel land use was assumed to include 450 rooms as summarized in the Table 1 below.
Table 1. Estimated Weekday Vehicle Trip Generation - Hotel (LU 310)
Land Use Size
Daily Trips AM Peak Hour Trips PM Peak Hour Trips
Trip Rate Total Trip Rate Total Trip Rate Total
Hotel
(LU 310) 450 rooms 8.17 trips per room 3,676 0.56 trips per room 252 0.59 trips per room 266
1. Based on ITE Trip Generation (8th Edition, 2008)
As shown, a 450-room hotel would generate 266 PM peak hour trips during a typical weekday.
This hotel trip generation is 147 PM peak hour trips less than the 413 average day PM peak hour
trips approved in the current CDA.
Attachment 2
2
All Resort Hotel Land Use
The Resort Hotel land use was assumed to include 450 rooms as summarized in the Table 2.
Table 2. Estimated Weekday Vehicle Trip Generation - Hotel (LU 330)
Land Use Size
Daily Trips AM Peak Hour Trips PM Peak Hour Trips
Trip Rate Total Trip Rate Total Trip Rate Total
Resort Hotel
(LU 330) 450 rooms 5.82 trips per room 2,620 0.31 trips per room 140 0.42 trips per room 189
1. Based on ITE Trip Generation (8th Edition, 2008)
As shown, a 450-room resort hotel would generate 189 PM peak hour trips during a typical
weekday. This resort hotel trip generation is 224 PM peak hour trips less than the 413 average
day PM peak hour trips approved in the current CDA.
All Warehouse Land Use
The Warehousing land use was assumed to include 1,000,000 square-feet (sf) as summarized in
the Table 3.
Table 3. Estimated Weekday Vehicle Trip Generation - Warehouse (LU 150)
Land Use Size
Daily Trips AM Peak Hour Trips PM Peak Hour Trips
Trip Rate Total Trip Rate Total Trip Rate Total
Warehousing
(LU 150) 1,000,000 sf 3.56 per 1,000 sf 3,560 0.30 per 1,000 sf 300 0.30 per 1,000 sf 320
Note: sf = square-feet
1. Based on ITE Trip Generation (8th Edition, 2008)
As shown, a 1,000,000 sf warehouse would generate 320 PM peak hour trips during a typical
weekday. This warehousing trip generation is 93 PM peak hour trips less than the 413 average
day PM peak hour approved in the current CDA.
Mixed Warehouse and Hotel Land Use
The Warehousing and Hotel land uses were assumed to include half of the full development level
with 500,000 sf of warehousing and 225 hotel rooms as summarized in the Table 4.
Table 4. Estimated Weekday Vehicle Trip Generation - Warehouse (LU 150) and Hotel (LU 310)
Land Use Size
Daily Trips AM Peak Hour Trips PM Peak Hour Trips
Trip Rate Total Trip Rate Total Trip Rate Total
Warehousing
(LU 150) 500,000 sf 3.56 per 1,000 sf 1,780 0.30 per 1,000 sf 150 0.30 per 1,000 sf 160
Hotel
(LU 310) 225 rooms 8.17 trips per room 1,838 0.56 trips per room 126 0.59 trips per room 133
Net Total
Vehicle Trips - - 3,618 - 276 - 293
Note: sf = square-feet
1. Based on ITE Trip Generation (8th Edition, 2008)
As shown, the mixed usage of hotel and warehouse would generate 293 PM peak hour trips
during a typical weekday. This mixed usage of hotel and warehouse vehicle trip generation is 120
PM peak hour trips less than the 413 average day PM peak hour approved in the current CDA.
3
Mixed Regional Recreation Facility and Warehouse
A scenario assuming half of the existing Regional Recreation Facility and Warehouse is provided
in Table 5, assuming half of the full development level of each. This scenario is likely not feasible
but is provided to illustrate that this combination is still less than the existing mitigated trip levels.
Table 5. Estimated Weekday Vehicle Trip Generation - Warehouse (LU 150) and Regional Recreational
Facility
Land Use Size
Daily Trips AM Peak Hour Trips PM Peak Hour Trips
Trip Rate Total Trip Rate Total Trip Rate Total
Warehousing
(LU 150) 500,000 sf 3.56 per 1,000 sf 1,780 0.30 per 1,000 sf 150 0.30 per 1,000 sf 160
Regional
Recreation
Facility
Half Existing 2,294 207
Net Total
Vehicle Trips - - 4,074 - - - 367
Note: sf = square-feet
1. Based on ITE Trip Generation (8th Edition, 2008)
As shown, the mixed usage of hotel and warehouse would generate 367 PM peak hour trips
during a typical weekday, generating 46 vehicle trips less than the 413 average day PM peak hour
trips approved in the current CDA.
All of the scenarios above would generate less than the 413 average day PM peak hour approved
in the current CDA.