21-100325-CO-Building B ESA Response Letter-07-07-2022-V1Wet.land, LLC 8201 164th Ave NE, Suite 200, PMB 141, Redmond, WA, 98052 206-309-8100
7 July 2022
Stacey Welsh
Principal Planner
City of Federal Way
Jessica Redman
Ecologist (3rd Party Reviewer)
Env ironmental Science Associates
REFERENCE: Woodbridge Building “B” Building Permit Critical Area Review
SUBJECT: ESA 4 May 2022 Comments
Dear Stacey and Jessica :
ESA comments on this Project were provided in a memo dated 4 May 2022 . Our responses to those
comments are provided below as well as incorporated into the main City response letter prepared
by ESM.
CORRECTIONS
Condition 4
Work is not allowed within Wetlands DP, DT, Stream EA, and associated buffers, as stream
setback intrusions and improvements/land surface modifications in non -CZA exempt
wetland setbacks require Use Process IV application review and approval per FWCC Sections
22-1312(c) and 22-1359(d).
ESA believes this condition has been met. All work proposed in the CAR Addendum is
outside of Wetlands DP, DT, Stream EA, and associated buffers as shown in Figure W1.1 of
the CAR Addendum. However, Sheet SD-02 in the Construction Plans for Woodbridge
Building “B”, does not show the correct buffer for Wetland DT and currently shows an
extruded curb as well as portions of a trash enclosure proposed within the buffer. It is
recommended the applicant revises the construction plans to show the correct buffer
before construction commences.
3 February 2022 PAGE 2
The Construction Plans prepared by ESM have been revised to reflect the correct
post-construction buffers for Wetland DT and to not show any elements within the
post-construction buffer.
Condition 9
The following amendments shall be made to the critical area report before issuance of a
building permit:
a) Include an analysis of wetland functions as required by Section 22-1356(b) of the 1994
FWCC.
The CAR Addendum includes a functional analysis of Wetland DT that includes all
requirements under Section 22 -1356(b)(7) of the 1994 FWCC. ESA agrees that all other
requirements under Section 22 -1356(b) (i.e., 1 through 6) were previously addressed in
the Critical Areas Report dated June 26, 2018, and included as Appendix A. ESA also
agrees that an evaluation for Wetland DP is not warranted as no modification to this
wetland, or its associated buffer, is being proposed. ESA believes this condition has
been met.
Noted. Condition met.
b) If Talasaea is considering the built -condition of Building “A” to be the existing conditions
for the Building “B” proposal, Sheet W1.0 of the revised report shall be revis ed to show the
reduced buffers for Stream EA and Wetlands DT, DR, and DQ to be consistent with the
proposed buffers on Sheet W1.2 of the report for Woodbridge Building “A.” Currently,
Sheet W1.0 shows the buffers as if Building “A” was not built.
The Existing Conditions Plan (Sheet W1.0) of the CAR Addendum has been revised to
show the reduced buffers for Stream EA and Wetlands DT, DR, and DQ, as they have
been approved post-construction of Building A. ESA believes this condition has been
met.
Noted. Condition met.
c) The applicant shall show/label on Sheet W1.1 the size of each area of buffe r reduction and
replacement to demonstrate that each reduction is compensated for at the location of the
critical area where that reduction occurs. Adjustments shall be made if necessary.
Sheet W1.1 of the CAR Addendum shows the size of the total stream an d wetland buffer
reductions and replacements, not the size of each individual buffer area proposed for
reduction or addition as required by the condition. This condition has not been met.
3 February 2022 PAGE 3
This comment on Condition 9c requested that “the size of each individual buffer
area proposed for reduction or addition” be shown on the Mitigation Plan. The
buffer modification legend on Sheet W1.1 o f the Mitigation Plans has been revised.
The revised Mitigation Plans, dated 10 June 2022, are attached for review and
reflect an updated tally by buffer reduction and addition area, rather than a sum
total by feature .
d) The “buffer replacement for Parcel A” shown on Sheet W1.1 is not approved and shall be
removed from Sheet W1.1.
The “buffer replacement for Parcel A” that was shown near the driveway entrance off
Weyerhaeuser Way in the CAR dated June 26, 2018 has been removed from Sheet W1.1
in the CAR Addendum. The revised sheet only shows the buffer replacements that were
approved as part of the Building “A” project. However, it is recommended that Sheet
W1.1 be further revised to clarify that the buffer replacement for Parcel A that is located
on Parcel B was part of the utility lin e installation work for the Building “A” project. The
legend should be amended to make this clarification.
This comment on Condition 9d requested that the project legend on Sheet W1.1 be
revised to clearly reflect that the buffer replacement for Parcel A that occurred on
Parcel B was part of the utility line installation work for the Building “A” project.
The reques ted legend on Sheet W1.1 has been revised.
e) When ESA’s comments on inconsistencies between report text, figures, and the plan sheets
are resolved in the submittal for Buildin g “A,” the submittal documents for Building “B”
shall be revised where necessary.
The inconsistencies between report text, figures, and the plan sheets were resolved in
the review of the building permit application for Building A. Additionally, according t o
Section 6 of the CAR Addendum, the buffer modifications for the Building “A” project
had an effect on the original Building B buffer modifications. Therefore, a new
assessment of critical area buffer impacts and mitigation was completed in light of the
current Building B site plan and the Process III -approved Building A site plan. This
condition has been met.
Noted. Condition met.
Condition 10
Plan sheets that show the proposed development shall show the buffers post -development,
including the averaged wetland and stream buf fers.
3 February 2022 PAGE 4
The plan sheets included in the Construction Plans for Woodbridge Building “B” that show
the proposed development show the buffers post -development. ESA believes this
condition has been met.
Noted. Condition met.
Condition 11
Areas of wetland and stream buffer replacem ent shall be enhanced with native vegetation,
as necessary, to ensure buffer function continues post -development. Planting details shall
be shown on the landscape plan submitted with the building permit.
ESA believes this condition has been met. According to the Planting Plan included in the
CAR Addendum (Sheets W2.0 and W3.0) the stream buffer and wetland buffer replacement
areas outside of the 50 -foot managed forest buffer will undergo the removal of invasive
species, soil stabilization with mulch, and planted with a mix of native trees and shrubs.
These activities are also included in the Woodbridge Building “B” Landscape Plan
submitted with the Building Permit Application.
Noted. Condition met.
Condition 12
Installation of permanent signs and split rail fencing is require d at the outer edge of the
wetland buffers for Wetland DT and shall be completed before final inspection for the
building permit.
ESA believes this condition has been met. Open board fencing is proposed along the
perimeter of the post-construction buffer as shown on the Planting Plan included in the
CAR Addendum (Sheets W2.0 and W3.0).
Noted. Condition met.
Condition 13
The boundary between the wetland buffer and contiguous land shall be identified with
permanent signs, which shall be a city -approved type designed for high du rability. Signs
must be posted at an interval of one per every 150 feet and maintained by the property
owner in perpetuity.
Sheet W3.1 of the Planting Plan included in the CAR Addendum shows details for
permanent signs to be placed no greater than 150 fee t apart along the critical area
fencing. However, this detail has not been approved by the City. This condition has not
been met. ESA recommends that the Planting Plan be revised to include City -approved
sign detail for critical area signage.
3 February 2022 PAGE 5
The critical area sign detail on Sheet W3.1 of the Mitigation Plan has been revised
with the updated sign detail as provided to us by the City.
Condition 14
The city shall not issue any approvals to fill wetlands until all state, federal, or other agency
permits as may be required to fill the wetlands have been obtained and verification provided
to the city.
ESA believes this condition has been met. To dat e, the City has received a Hydraulic
Project Approval from the Washington State Department of Fish and Wildlife (dated
December 16, 2021); an Administrative Order from the Department of Ecology (dated
November 18, 2021); and a jurisdictional determination from the U.S. Corps of Engineers
(dated July 27, 2021) stating that wetlands and streams in the project area are excluded
from Clean Water Act jurisdiction.
Noted. Condition met.
Please don’t hesitate to contact me with any additional questions.
Sincerely,
Jennifer Marriott, PWS
Owner
Wet.land, LLC
Enclosure: Revised Mitigation Plans, Sheets W1.0 – W4.0, revised 10 June 2022