20201104122836 Cardno Report 3-16-18March 16, 2018
Tom Messmer
Vice President — Special Projects
Federal Way Campus, LLC
8847 Imperial Highway, Suite H
Downy CA, 90242
COMMUr FEDERAL
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Cultural Resources Archival Study, Greenline Business Park Project,
Federal Way, Washington
Subject:
�� Card►rio
Shaping the Future
CONFIDENTIAL
Dear Mr. Messmer:
RESUBMITTED
APR 3 U 2018
Cardno
801 Second Avenue
Suite 700
Seattle, WA 98104
USA
Phone 206 269 0104
Toll -free 800 368 7511
Fax 206 269 0098
www.cardno.com
This letter report describes the results of the archival study conducted by Cardno, Inc. (Cardno) for the Greenline
Business Park Project (project), located within the former Weyerhaeuser Company (Weyerhaeuser) campus at
32901 32nd Drive South in Federal Way, Washington. The 77-acre project area includes portions of parcels
152104-9178, 162104-9030, 228500-0010, as well as the entirety of parcels 162104-9013 and 162104-9056, which
have recently been purchased by the Industrial Realty Group, LLC (IRG) from Weyerhaeuser (King County Tax
Assessor's Office 2018). The project straddles the western half of Section 15 and the eastern half of Section 16 of
Township 21 North, Range 4 East of the Willamette Base Meridian (Figures 1 through 3).
The proposed Greenline Business Park project includes the construction of three buildings of varying sizes totaling
approximately 1,068,000 square feet (ft) surrounding the former Weyerhaeuser Technology Center (WTC), now
referred to as the Greenline Technology Center (ESM Consulting Engineers, LLC 2017). Additional site
improvements include reconfiguration and expansion of the existing parking lot at the Greenline Technology
Center, construction of five stormwater ponds, and frontage improvements along Weyerhaeuser Way South and
South 336th Street.
An inventory to document the historical and architectural significance of the project area was requested by the City
of Federal Way upon their review of the Federal Campus Way, LLC's application under the Washington State
Environmental Policy Act (SEPA) (Revised Code of Washington [RCW] 43.21 C) and implementing rules contained
in Washington Administrative Code (WAC) 197-11. As outlined in the SEPA checklist submitted to the local
planning authority with applications for development, the following questions must be satisfactorily addressed to
demonstrate that cultural and historic resources will not be adversely affected by the proposed development:
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.
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.
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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.
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.
On behalf of Federal Campus Way, LLC, Cardno completed an archival study to assess the cultural significance of
the project area and to provide a recommendation concerning the potential effects of this project on cultural
resources, including those that may be eligible for listing in the Washington Heritage Register (WHR) and/or the
National Register of Historic Places (NRHP) (termed "historic properties"). Cardno also conducted a field visit to
note the existing conditions of the project area and a historic resources survey for the building located at 32901
32nd Drive South (within parcel 162104-9013).
The archival study consisted of a literature review of existing cultural resource records for previously recorded
historic, ethnohistoric, and precontact archaeological and built environment resources; a review of any local, state,
and national register nomination forms; a review of previously conducted cultural resources investigations; and a
review of any known or potential Traditional Cultural Properties (TCPs) located within 1.0 mile (1.6 kilometer [km])
of the project area. This research included a records search at the Department of Archaeology and Historic
Preservation's (DAHP's) Washington Information System for Architectural and Archaeological Records Data
(W ISAARD). Additional resources that were consulted include historic -era aerial photographs and county atlases,
as well as U.S. Geological Survey (USGS), General Land Office (GLO), and Sanborn Fire Insurance maps.
The results of the research were compared to the proposed project plans to determine any potential disturbance to
previously recorded cultural resources or historic properties, and to assess the potential for currently unknown
cultural resources to exist in the project area and their significance. This study also evaluated potential project -
related effects on any known historic properties or cultural resources that may be eligible for listing in the WHIR or
NRHP. The building at 32901 32nd Drive South does not meet the age requirement at this time to be eligible for the
NRHP or trigger Criteria Consideration G of the NRHP eligibility criteria, but it maintains enough architectural merit
that it should be reevaluated when it is 50 years old.
CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com
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March 16, 2018
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Project area plotted on USGS topographic quadrangle
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March 16, 2018
Environmental Setting
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The project is located along the eastern border of the City of Federal Way between the Puyallup and Green River
Valleys in the Puget Lowland physiographic province. This physiographic province is a low-lying area between the
Cascade Range to the east and the Olympic Mountains to the west. The Puget Sound was shaped by widespread
continental glaciation that extended south from British Columbia to the northern Puget Lowland and along the
western flanks of the Cascade Range (Miss 2008). This area is also known as the Puget Sound Trough
physiographic province, which extends to the Cowlitz and Chehalis Rivers (Franklin and Dyrness 1988). The
Vashon Stade of the Fraser Glaciation was the last glacial maximum in the region and is dated between ca. 19,000
and 16,000 years before present (BP) (Easterbrook 2003). During the maximum extent of this glaciation, most of
the northern third of Washington lay beneath a nearly continuous sheet of glacial ice (Easterbrook 2003). The
outwash deposited during the southward advance of the Puget lobe of the Cordilleran ice sheet filled the Puget
Sound basin, forming an extensive low-lying area bounded on the west by the Olympic Mountains and on the east
by the Cascade Range. Sometimes called the "great Lowland Fill," the surface of this fill rarely rises above 500-ft
elevation (Booth and Goldstein 1994). The Federal Way area is located at elevations between 300 and 500 ft on an
undulating landform defined as the Des Moines Drift Upland. This upland landform was a long, narrow island that
stretched between Seattle and Tacoma, with Puget Sound to the west and marine waters filling the fjord of the
Duwamish Embayment on the east (Forsman et al. 1999). The land experienced isostatic rebound between 13,000
and 7,000 years BP as global sea levels rose and tectonism began to shape the Puget Sound shoreline (Dragovich
et al. 1994; Miss 2008).
At the regional scale, the larger Pleistocene glacial troughs are occupied by marine waters or large freshwater
lakes today. Subglacial incision when the ice sheet overrode the advance outwash, and subglacial incision during
maximum extent and subsequent retreat of the ice sheet, created a number of large, deep troughs and meltwater
channels. As a result, the geomorphology of the region is now dominated by well-defined north -trending troughs
separated by extensive fluted drift uplands, like the Des Moines Drift Upland. The surfaces of the uplands are
characterized by numerous surface depressions, now occupied by small lakes and peat bogs, created as glacial ice
retreated (Mullineaux 1970). The largest of these bodies of water in the Seattle metropolitan area include the Puget
Sound, the Duwamish-Green River Valley, Lake Washington, and Lake Sammamish (Liesch et al. 1963; Yount et
al. 1993). Freshwater lakes that have filled glacial depressions and are local to the Federal Way vicinity include
Steel Lake, Mirror Lake, Five -Mile Lake, Lake Geneva, Star Lake, Mud Lake, Lake Dolloff, and North Lake, which
borders the project area to the east (Caster 2004). Approximately 13 acres of subsurface peat have been identified
along the north rim of North Lake (Caster 2004). The postglacial environment of the project area around 15,000
years BP was a grassland savanna composed of scattered pine trees, and it remained as such until approximately
6,000 or 5,000 years BP, when the contemporary Western hemlock (Tsuga heterophylla) and Douglas fir
(Pseudotsuga menziesii) forest developed (Brubaker 1991).
The Des Moines Drift Upland remained an island until approximately 5,700 years BP, when the Osceola Mudflow, a
massive lahar that resulted from a large-scale summit and flank collapse on Mount Rainier, traveled down the
White River Valley from Mount Rainier and deposited large quantities of mud in both the Green River Valley and
the Puyallup River delta. After passing through the White River bedrock gorge upstream of what is now Mud
Mountain Dam, the mudflow blanketed glacial drift valleys and plains with as much as 100 ft of clay -rich gravel,
cobbles, and boulders (Forsman et al. 1999). Osceola Mudflow deposits cover an area of about 550 square km in
the Puget Lowland, extending at least as far as the Seattle suburb of Kent and to Commencement Bay (Dragovich
et al. 1994; Mullineaux 1970; Palmer 1997; Vallance and Scott 1997). Post-lahar fluvial aggradation and delta
progradation eventually filled the ancient Puyallup and Duwamish arms of the Puget Sound to their present
positions. Both mudflow materials and upriver alluvial sediments extended the leading edge of the delta
northwestward, filling Commencement Bay at a rate of approximately 8.2 ft (2.5 meters [m]) per year (Weaver
2003:6).
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March 16, 2018
L,r`9 cardnca
The U.S. Department of Agriculture's (USDA's) Natural Resources Conservation Service (NRCS) Soil Data
Explorer classifies soils in the general project area as Alderwood gravelly sandy loam, which belongs to the soil
taxonomy order Inceptisol (USDA 2018). The Alderwood series consists of moderately well -drained soils located on
uplands and terraces. These soils formed under conifers in glacial deposits on slopes that range from 0 to 70
percent (Snyder et al. 1973:8).
GeoEngineers, Inc. conducted a geotechnical engineering study at the project area in 2017 to evaluate the on -site
subsurface sediments and provide recommendations for the proposed development (Helvey and Overbay 2017).
The study evaluated previously excavated test pit explorations from 2016 and conducted additional explorations in
July 2017. As described by GeoEngineers, the top stratum typically consisted of forest duff and/or topsoil that
extended from the ground surface to depths that ranged between 1 and 18 inches below ground surface. This
organic -rich stratum was typically underlain by medium dense grayish brown silty fine to medium sand with some
gravel and cobbles, identified as weathered glacial till, and extended from 3 to 5 ft below surface. The weathered till
interfaced with very dense and moist brownish gray silty fine to medium sand with some gravel and cobbles (i.e.,
native glacial till material). Each exploration terminated in these native glacial till deposits. In explorations placed
within the existing parking lot surfaces and surrounding the south-central retention ponds, loose to dense fill was
encountered between 1.75 and 7.5 ft below surface of explorations. The fill consisted of medium dense silty sand
and interfaced with native glacial till.
The regional climate is characterized by a maritime regime, with cool, typically dry summers and mild, wet winters.
Since the last glacial episode, the climate has experienced several cycles of warming/drying and cooling/increasing
moisture. Following the last glacial advance, a period of rapid warming and reduced precipitation marked the
climate until approximately 7,000 years BP, at which time precipitation levels began increasing and temperatures
began cooling, similar to modern conditions. From 4,500 to 2,000 years BP, this cooling/increased precipitation
trend continued throughout what is known as the Neoglacial. During this period, conditions were substantially
wetter and cooler than at present. The last major fluctuation, the Little Ice Age, occurred from approximately 500 to
100 years BP and was a period of increased precipitation and cooler temperatures (Ames and Maschner 1999).
The project lies within the western hemlock vegetation zone in the Puget Lowland, which provides a highly
productive ecological system with a complex mosaic of microenvironments. Historically, the zone includes the
climax species that defines it, as well as western redcedar (Thuja plicata) (Franklin and Dyrness 1988). The overall
modern regional vegetation profiles were not established until approximately 5,000 to 3,000 years BP (Ames and
Maschner 1999). Forests are currently dominated by western hemlock, Douglas fir, coast red elderberry
(Sambucus racemosa var arborescens), and western redcedar. The understory consists of mostly undisturbed low
brush including hardhack (Spiraea douglash), Labrador tea (Rhododendron spp.), crab apple (Malus spp.), and
cascara buckthorn (Rhamnus purshiana), as well as various small herbs and some mosses (Caster 2004).
However, historical and modern land use, such as commercial, residential, and urban development; logging; and
small-scale farming, have greatly modified the vegetative profile of the area.
In precontact times, the region was rich in faunal resources whose predictable seasonal migrations were vital to the
native inhabitants of the Puget Sound region, especially the salmon species that would migrate up Hylebos Creek
toward present-day Federal Way (Williams et al. 1975). Anadromous fish species continue migrate seasonally to
spawning streams throughout the region, including Chinook (Oncorhynchus tshawytscha), coho (O. kisutch), chum
(O. keta), rainbow trout (O. mykiss), and char (Salvelinus spp.). Prior to the Euro-American settlement of the region,
a variety of terrestrial animals once thrived in the microenvironments associated with freshwater rivers, streams,
springs, ponds, and swamps of the Puget Lowland. However, the diversity of microenvironments, and, as a
consequence, the diversity of faunal species, has been greatly affected by settlement and development. The few
species not pushed out by these activities include black -tailed deer (Odocoileus hemionus), beaver (Castor
canadensis), marmot (Marmota caligata), raccoon (Procyon lotor), various avian species, and suckers.
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Archaeology
The earliest known occupations in western Washington, termed Paleo-Indian, are evidenced by the appearance of
large, fluted projectile points dating to approximately 12,800 years BP (Ames and Maschner 1999; Carlson 1990).
Paleo-Indians were primarily hunter -gatherers with small populations and high levels of mobility. Some researchers
have argued that these early people were maritime oriented (Carlson 2003; Dixon 1993; Fedje and Christensen
1999; Fladmark 1979). In western Washington, sites from this period are rare. Much of the late Pleistocene terrain
was uninhabitable due to glaciers, and the lands that were occupied by Paleo-Indians were predominately coastal
reaches. During the glaciation period, ocean levels fell almost 400 ft globally (Kirk and Daugherty 2007), but with
the onset of the warming Holocene, ocean levels rose and submerged many of these coastal sites. However, some
sites are not submerged, and instead are located above the present shoreline due to eustatic, tectonic, and
isostatic effects that vary throughout the region (Fedje and Christensen 1999).
The Archaic period dates from approximately 12,500 to 6,400 years BP (Ames and Maschner 1999; Carlson 1990).
Archaic -period sites, similar to Paleo-Indian sites, are poorly represented. Changes in sea level and vegetation
have obscured many Archaic -period sites along the coast (Ames and Maschner 1999). However, as the glaciers
receded, people were able to occupy larger expanses in the interior of the Puget Sound. Archaic -period peoples
likely maintained small populations, high levels of mobility, and focused on a combination of maritime, littoral, and
terrestrial economies. Archaic -period occupations are largely characterized by stone tool assemblages that are
typically composed of large, stemmed lanceolate projectile points and bifaces. In addition, the Pacific Northwest
Archaic period saw an introduction of microblades, which are sometimes present in stone tool assemblages (Ames
and Maschner 1999).
Pacific -period sites date from approximately 6,400 to 250 years BP. The period ends at the introduction of smallpox
to the region (Ames and Maschner 1999). The Early Pacific period (6,400 to 3,800 years BP) was marked by the
increased use of marine resources, the appearance of human burials in middens and cemeteries, a diversification
in subsistence activities, the disappearance of microblade technology, and the increased use of bone, antler, and
ground stone tools. Major developments also included the appearance of ground stone celts (adze blades) and a
proliferation in chipped -stone tool forms and styles and decorative/ornamental pieces, which likely represent
contact and trade with groups in neighboring cultural areas (Kirk and Daugherty 2007). The Middle Pacific period
(3,800 to 1,800/1,500 years BP) displays major developments including the appearance of long-term settlements
(plank houses), intensification of salmon capture (appearance of wooden fish weirs and girdled/drilled net sinkers),
and diversification in tool form and style. Late Pacific period (1,800/1,500 to 250 years BP) developments are
represented by the appearance of heavy-duty woodworking tools, an overall decline in the use of chipped -stone
tools, and an increase in funerary ritual/burial activities. Sea levels became stable by the start of the Middle Pacific
period, and sites representing the Middle and Late periods are located across the Northwest Coast region (Ames
and Maschner 1999).
Ethnography
The proposed project is located within the traditional territory of the Muckleshoot and Puyallup, two Puget Salish or
Lushootseed-speaking groups (Suttles and Lane 1990). As speakers of the Southern Coast Salish dialect, the
Muckleshoot and Puyallup were among a set of closely related peoples in the Puget Sound region that included the
Snoqualmie, Suquamish, Skykomish, Snohomish, Skokomish, Duwamish, and Nisqually (Suttles and Lane 1990).
In their aboriginal language, the Puyallup were known as the spuyalepabs, meaning "generous and welcoming
behavior to all people (friends and strangers) who enter our lands," which indicates the frequency and nature of
Puyallup precontact interactions (Puyallup Tribe of Indians 2018). Following increased conflict in the 1850s on
account of Euro-American settlement encouraged by the Donation Land Claim Act, a new treaty combined the
White River tribes under the Muckleshoot name and established what remains as the only Indian reservation now
within the boundaries of King County.
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March 16, 2018
�,r`7 Cardnv
Both the Muckleshoot and Puyallup groups lived in winter villages along the Puyallup and White Rivers, and inland
from the historic shorelines of Commencement Bay and Hylebos Creek (Haeberlin and Gunther 1930; Smith 1940).
They preferred locations above the tideflats at confluences of major creeks, which would provide protection from
the elements, fresh water, and access to fishing sites. The tideflats, with marine and freshwater environments,
provided a rich subsistence base that was dominated by salmon and supplemented by hunting and gathering.
Winter villages consisted of multifamily longhouses made from cedar planks and ranged from a single building to up
to 10 houses (Haeberlin and Gunther 1930). During the spring, these groups traveled throughout their territory for
resource procurement, which extended throughout the current project area, as well as across Puget Sound to
Vashon Island, and southeast to the tributaries of the Green, Puyallup, Carbon, and Stuck Rivers toward Mount
Rainier (Rinck et al. 2012; Roedel et al. 2003; Smith 1940). Small, mobile groups constructed temporary, mat -
covered structures at fishing and plant -gathering camps during seasonal procurement rounds. At the camps, they
smoked fish, shellfish, and game and dried berries and roots to take back to the village sites for winter supplies
(Rinck et al. 2012). Salmon constituted the bulk of the food supply, providing for immediate consumption, winter
stores, and surplus for exchange (Suttles and Lane 1990).
Cardno is not aware of any known ethnographic place names within the project area. However, there are several
ethnographic place names recorded along Commencement Bay, Lake Doloff, and the Puyallup River and its
tributaries in the general vicinity of the project area (Dailey n.d.; Waterman et al. 2001), as listed below. Non -
English names are Lushootseed.
• XaxtL! translates to "brushy," which refers to Hylebos Creek. A Catholic missionary named Hylebos
founded St. George's School along this creek.
• LtcELEb refers to the tideflats where shipyards stood during the early twentieth century.
• Tcaua'lgo translate to "hidden water," which refers to Brown's Point on the north side of Commencement
Bay. A freshwater spring was observed along the shoreline at this location, which was concealed by
immature alder trees.
• 81skwa'dis translates to "where there are whales," and refers to Lake Dolloff, which is the source of Mill
Creek. It was believed that whales used to swim into this lake via an underground channel.
• s'HAWHT'1-ahbch refers to the location in present-day northeast Tacoma where Hylebos Creek empties
into Commencement Bay. People from this village were said to have moved across Puget Sound to
establish a village at present-day Gig Harbor, TWAH-well-kawh. Silver salmon were plentiful in Hylebos
Creek.
Historical Context
British Naval Captain George Vancouver was the first Euro-American to document the eastern Puget Sound
shoreline in 1792. His initial observations of the region reported clouds of smoke on the high bluffs as the local
Native Americans had set brush fires to drive out game for hunting (Stein 1999a, 2003). Over the next three
decades, several military and commercial expeditions explored the greater region to chart the coastline and scout
the interior for resources.
William Fraser Tolmie was the first settler in the region of the Puyallup River Valley, and was a medical officer for
the Hudson's Bay Company in the early 1830s. Led by Nuckalkat, a Puyallup Indian, and several other Native
American guides, Dr. Tolmie passed through the valley, where approximately 2,000 Puyallup Indians lived, on his
way to Mount Rainier (City of Puyallup 2018). As the influx of Euro-American settlers encroached on Puyallup land
during the subsequent decades, encouraged by the 1850 Donation Land Claim Act, the Puyallup negotiated the
Treaty of Medicine Creek in 1854, which ceded most of their territories and forced the tribe onto a reservation of
1,280 acres (Chesley 2008). Several years of conflict ensued following the signing of the treaty between the
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March 16, 2018
10 CCarcino
tribal members of the Nisqually, Muckleshoot, Puyallup, and Klickitat Tribes against the U.S. military and local
militiamen, which is typically referred to as the Puget Sound Indian Wars. The Puyallup Indian Reservation was
subsequently enlarged to 18,062 acres in January 1856 (Becker 2006).
Euro-American settlement of the Green River Valley began at the time the Washington Territory was established in
1853. Around this time, wagon trains began to arrive over the Naches Pass using a crude military road that passed
from Fort Steilacoom to Fort Walla Walla through present-day Auburn (Lentz 1990). Many of the early settlers took
advantage of the Donation Land Claim Act that allowed pioneers to claim 160 acres. The city of Auburn, east of
Federal Way, lays claim to some of the earliest Euro-American settlements in King County (Stein 1999b). A small
community was established there in the early 1850s at the confluence of the Green and White Rivers, which were
fed by the predictable snowmelt from the Cascade Range. The abundance of resources soon created a vibrant hub
for farming, trading, and industry. As this growing settlement encroached on the valley's original inhabitants, the
Skopamish, Smalhkamish, and Stkamish Indian Tribes, conflict soon followed. Settlement of the valley was slowed
by conflicts with Indian tribes during the mid-1850s when many of the early pioneer families left their farms in the
valley for Seattle during the conflict (Peto et al. n.d.).
In contrast, the Federal Way region, nestled between the Puyallup and Green River Valleys, was relatively
uninhabited by Euro-Americans during the nineteenth century prior to the waterfront settlement that emerged in the
latter half of the century (Forsman et al. 1999). While settlers were drawn to the idyllic flat prairies around the White
River, which require little clearing, and abundant resources at the mouth of the Puyallup River, the densely wooded
forests and glacial till substrate that made up the Federal Way region was not ideal for agriculture, and thus
permanent settlements took longer to become entrenched.
Federal surveyors platted the area in the 1850s in preparation for the construction of a military road between Forts
Bellingham and Steilacoom (Stein 2003). Aptly named Military Road, it was completed by 1860 and connected
Seattle with Pierce County. Early homesteaders, including Ernst Ferdinand Lange, Sam Stone, and John Barker,
flocked to the Poverty Bay shoreline at what is now known as Redondo in order to maintain proximity to reliable
marine resources (Caster 2015). By the end of the nineteenth century, the shoreline homesteaders had turned their
attention to inland resources, and Redondo became one of the first logging settlements on Puget Sound (Caster
2004).
Two sawmills emerged at Steel Lake in 1890 and at Star Lake in 1909 in order to process and export the abundant
harvested timber (Caster 2015). The Weyerhaeuser Timber Company incorporated in 1900 when Frederick
Weyerhaeuser and 15 partners convened in Tacoma and purchased 900,000 acres of land in Washington from the
Northern Pacific Railway, including what was to become Federal Way (Weyerhaeuser 2018). By 1913, due to
intensive logging practices, many of the large -diameter trees, defined as trees with greater than 15-ft diameter, had
been entirely logged (Caster 2015).
In order to meet the transportation demands of the growing region with the advent of the automobile, construction
of a 24-mile-long strip of federal highway began in 1915 that would connect Tacoma and Seattle, with the ultimate
goal of traversing the entire western coast of the U.S. (Caster 2015; Stein 2003). This federal highway was to be
named Highway 99, but was referred to as Pacific Highway South. The historical Military Road served as the
footprint for much of this federal highway, which was initially unpaved until a tax restructure in 1927 allocated state
taxes for building and paving highways (Caster 2015). On account of its proximity to the federal highway, a newly
constructed elementary school that consolidated five districts was given the name Federal Way School (Caster
2015). The name "Federal Way" was officially accepted by the local Chamber of Commerce in the 1950s, although
the town was still part of unincorporated King County (Earley 2005).
Federal Way mainly served as a culinary and shopping destination for travelers along Highway 99 during the mid -
twentieth century (Stein 2003). Community growth climbed sharply in the latter half of the twentieth century when
large corporations moved into the region, particularly Boeing and Weyerhaeuser in the 1960s. In 1968,
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March 16, 2018
11 col) Ga►rclimp
Weyerhaeuser purchased 430 acres of land and began construction on its new corporate headquarters, which
would be the "first major application of open -landscape office design in the U.S." (Weyerhaeuser 2018). Although
the city unsuccessfully tried to incorporate in 1971, 1981, and 1985, the community approved incorporation of
Federal Way in 1990 (Stein 2003).
Historical Map Review
The 1868 GLO cadastral survey plat plots North Lake in its present-day orientation and shows the project area as
sectioned but undeveloped (Bureau of Land Management [BLM] 2018). No human -made features or structures are
shown to have been constructed within any of the parcels constituting the project area at that time. Less than 1.0
mile (1.6 km) east of the project area, the "Military and Telegraph Road" is plotted meandering around large natural
landforms (i.e., elevation changes, bodies of water), roughly trending north/south. This plotted road is the same
aforementioned Military Road that was built to connect Fort Bellingham to Fort Steilacoom by way of Seattle and
Tacoma, and served as the footprint to the highway that ultimately brought Euro-Americans into the Federal Way
region (Stein 2003). The GLO plat shows the Puyallup Indian Reservation located in the very southwestern corner
of the township/range (BLM 2018). Records show that the land patent for the portion of the project area within
Section 15 (T21 N, R4E) was purchased by the Northern Pacific Railroad Company on May 10, 1895 (BLM 2018).
The land patent for Section 16 (T21 N, R4E) was purchased by the State of Washington on November 11, 1889
(BLM 2018). USGS topographical maps convey that by 1897 neither land holder had developed within the project
area (USGS 2018). A topographic map from 1900 plots a single structure southwest of North Lake outside of the
current project area, but within what would eventually become the' Weyerhaeuser campus. Historical topographic
maps from the turn of the twentieth century to the World War II era are not readily available online. However, by
1949, a network of roads had been built that nearly surrounded the entirety of North Lake, along which countless
residential structures had been constructed. By 1968, Interstate 5 (1-5) had been constructed and bisected Section
16 northeast/southwest, and several additional structures had been built toward the interior of Section 16, west of
North Lake. The 1973 USGS topographic map is the first to show the Weyerhaeuser Headquarters building and
associated pond south of 336th Street; by 1981, the WTC and associated road network appear to have been
constructed (USGS 2018).
King County atlases that date to 1907 show that the southwest quarter of the northwest quarter of Section 15
(T21 N, R4E) was owned by William Hatfield (Anderson Map Company 1907). The portion of Section 16 (T21 N,
R4E) within the project area appears under the generalized ownership of "School," without further qualification.
Puget Sound Electrical Company and Weyerhaeuser Timber Companies appear as large land -holding entities in
the surrounding area at this time. By 1912 and through to 1936, Section 16 appears once again as being owned by
the State of Washington, which may indicate continuous ownership of this portion of the project area, given the
previous operation of a state -funded school in the area (Kroll Map Company 1912, 1926; Metsker 1936). The
eastern half of the southeaster quarter of Section 16 (i.e., Lots 1 and 2) appears to have been temporarily
purchased from the state by C.B. Niblock in 1912, then sold back to the state by 1926. In 1936, these parcels are
owned by Purdy's Resort (Metsker 1936). Meanwhile, the portion of project area land within Section 15 had
changed hands from William Hatfield to Minerva Fullenwider by 1912, to J. Combs and H. Raymond by 1926, and
to "Goldens (sic) Lake" by 1936. Readily available King County atlases from the mid- to later -twentieth century do
not provide sufficient detail to provide relevant land -holding information (Metsker 1940, 1950, 1980; Thomas Bros.
1955).
In 2015, the project area was zoned as a Corporate Park, under a special condition Ordinance #93-190 (City of
Federal Way 2015). Historic -era municipal zoning maps for the city of Federal Way do not exist or are not readily
available, likely because the city did not incorporate until 1990 (Stein 2003). Additionally, there are no historic -era
Sanborn Fire Insurance Company maps for the Federal Way region (Digital Sanborn Maps 1867-1970).
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12 C.car-c no
Archival Research
Cardno conducted a background search and literature review of existing cultural resource records; local, state, and
national register nomination forms; previous cultural resources investigations; and any known or potential TCPs in
and within 1.0 mile (1.6 km) of the project area. According to the DAHP's predictive model available on the
WISAARD online database, the majority of the project area has low risk for encountering buried archaeological
deposits. A small portion of the northeastern portion of the project area has moderately low risk for encountering
buried archaeological deposits.
Previous Investigations
Six cultural resources surveys were previously conducted within 1.0 mile (1.6 km) of the project area between 1999
and 2014 (Table 1). There are no previously conducted surveys that overlap with the current project area.
Table 1 Cultural Resources Investigations within 1.0 Mile of the Project Area
1999
Forsman
Regional Express/Federal Way and Star Lake
1339832
Survey Report
0.1 and 0.5
et al.
Project Cultural Resource Assessment, Federal
mile W
Way Alternative
2005
Earley
Cultural Resources Assessment of the
1345011
Survey Report
0.15 mile W
Thompson Park Project, Federal Way
2005
Luttrell
Letter to Kimberly Farley Regarding 1-5: Pierce
1345762
Survey Report
0.5 mile SSW
County Line to Tukwila Stage 4 HOV Project
2006
Bard and
FINAL REPORT: Cultural Resources Discipline
1348206
Survey Report
0.1 mile SW
Durio
Report for 1-5 SR 161/SR 18 Triangle
Improvements
2006
Luttrell
Cultural Resources Investigations for
1348213
Survey Report
0.9 mile NNE
Washington Department of Fish and Wildlife's
Lake Dolloff Access Redevelopment Proiect
2014 Baldwin Cultural Resources Assessment for the Pacific 1685856 Survey Report 0.6 mile W
Highway South HOV Lanes Phase V (S 340th
Street to S 359th Street) Project, Federal Way
Notes: HOV = high occupancy vehicle(s); I = Interstate; LAAS = Larson Anthropological Archaeological Services; SR = State Route
Sverdrup Civil, Inc. retained Larson Anthropological Archeological Services, Limited (LAAS) to conduct a cultural
resources assessment for the Federal Way Alternative of the Regional Express/Federal Way and Star Lake Project
(Forsman et al. 1999). Each project location that was designated for proposed ground disturbance was surveyed
for archaeological materials. Two project locations are located approximately 0.1 mile (0.2 km) and 0.5 mile (0.8
km) west of the current project area. No archaeological resources were identified during the survey. A survey of the
historic structures in the vicinity of these project locations determined that this project would have no adverse effect
on structures listed or eligible for listing in the NRHP.
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13 �,, Cardna
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The City of Federal Way proposed site improvements to Thompson Park in Federal Way, Washington, and retained
Northwest Archaeological Associates, Inc. (NWAA) to conduct a cultural resources assessment for the project,
located approximately 0.15 mile west of the current project area (Earley 2005). The assessment, which included
both pedestrian and subsurface investigations, did not encounter any precontact or historic -era cultural resources
and recommended that no further cultural investigations were necessary for the project to proceed (Earley 2005).
On behalf of the Washington State Department of Transportation (WSDOT), Archaeological and Historical Services
(AHS) of Eastern Washington University conducted a cultural resources evaluation of a historical foundation
(45KI00719) inadvertently discovered during vegetation grubbing (Luttrell 2005a). See below for additional details
on the historic -era site.
In 2006, a cultural resources discipline team composed of eight engineering and consulting firms prepared a
discipline report to evaluate the effects that the proposed WSDOT project would have on cultural resources within
the study area (Bard and Durio 2006). This project was located at the intersections of 1-5 with State Route (SR)-18
and SR-161, the closest of which was approximately 0.1 mile southwest of the current project area. The study did
not identify any precontact or historic -period archaeological resources, TCPs, or historic structures eligible for listing
in the NRHP.
AHS was retained by the Washington State Department of Fish and Wildlife (WDFW) in 2006 to conduct a cultural
resources investigation for the Lake Dolloff Access Redevelopment Project, located approximately 0.9 mile north-
northwest of the current project area (Luttrell 2006). The project surveyed 2.71 acres along Lake Dolloff,
encountering only non -diagnostic modern debris, likely the result of recreational litter. AHS recommended that no
further cultural resources work was necessary for the proposed project (Luttrell 2006).
In 2014, Drayton Archaeology (DA) conducted a cultural resources assessment on behalf of Widener and
Associates for a highway expansion project located 0.6 mile west of the current project area (Baldwin 2014). The
cultural resources assessment, which consisted of pedestrian survey, visual reconnaissance, and a review of soil
borehole logs previously excavated within the project area, did not identify any cultural resources. As such, DA
recommended that no historic properties were affected by the undertaking.
Archaeological Resources
The records indicate that no archaeological sites have been previously recorded within the project area. One known
historic cultural resource was identified within 1.0 mile (1.6 km) of the project area (Table 2). No TCPs were
identified within the 1.0-mile (1.6-km) search radius.
Table 2 Previously Recorded Archaeological Resources within 1.0 Mile of the Project Area (n=1)
45KI00719 - Historic residential Not Eligible 1345762 Luttrell 2005b 0.5 mile SSW
structure Bartoy 2013
Site 45KI00719 is a historic residential structure and associated historic debris scatter that was identified at the
western extent of the South 348th Street cul-de-sac and west of 1-5, approximately 0.5 mile south-southwest of the
current project area. The structure's foundation measured approximately 20 ft by 18 ft and appeared to have been
constructed from both water -round and angular cobbles and boulders (Luttrell 2005b). At the time of recording in
2005, the tallest point of the foundation measured approximately 6 ft high, but portions of the foundation were
observed to be crumbling. Additional structural materials observed in the vicinity of the foundation included large
disturbed boulders, small concrete slabs, flat window glass, brick, plywood, and lumber, among other materials.
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14 C� Gar-dna
March 16, 2018
WSDOT recommended that the site was not eligible for inclusion in the NRHP in 2005; DAHP concurred with the
eligibility determination for the site (Griffith 2005).
Eastern Washington University's AHS revisited the site in 2013
and found that the site had been removed by WSDOT during right-of-way construction, and no longer exists (Bartoy
2013).
Historic Resources
The records search indicates that 22 historic properties are located within the 1.0-mile (1.6-km) search radius of the
project area (Table 3). Of the 22 historic properties within the search radius, 2 properties have been determined
eligible for listing in historic registers, 19 properties
have been determined not eligible for listing in historic registers,
and 1 property has not been formally evaluated.
Table 3 Previously Recorded Historic Resources within 1.0 Mile of the Project Area (n=22)
28910 Weyerhaeuser 33663 Weyerhaeuser
Building 1969 Eligible 0.2 mile S
Headquarters Way S
40945 Stevenson 32330 Pacific Hwy S
Building 1945 Unevaluated 0.8 mile W
Motel
86451 33570 Pacific Hwy S
Building - Not Eligible 0.5 mile W
86947 Stevenson 33330 Pacific Hwy S
Building 1948 Not Eligible 0.5 mile W
Motel
100773 Calvary 2415 S 320th St
Building 1956 Eligible 0.3 mile NW
Lutheran
Church
673607 - 31405 18th Ave S
Building 1959 Not Eligible 1.0 mile NW
674015 31612 28th Ave S
Building 1951 Not Eligible 0.5 mile N
674016 31250 28th Ave S
Building 1968 Not Eligible 0.7 mile N
674017 31228 28th Ave S
Building 1943 Not Eligible 0.7 mile N
674018 Steel Lake 31130 28th Ave S
Building 1959 Not Eligible 0.8 mile N
Maintenance
Facility
674019 31104 28th Ave S
Building 1959 Not Eligible 0.9 mile N
674027 31016 28th Ave S
Building 1963 Not Eligible 0.9 mile N
674028 - 31004 28th Ave S
Building 1943 Not Eligible 0.9 mile N
674029 - 31000 28th Ave S
Building 1943 Not Eligible 1.0 mile N
674117 - 31458 Pacific Hwy S
Building 1970 Not Eligible 0.9 mile NW
674119 31254 Pacific Hwy S
Building 1961 Not Eligible 1.0 mile NW
674318 Belmor Mobile 2101 S 324th St
Building 1966 Not Eligible 0.4 mile W
Home Park
674674 Marie Wells 3911 328th St
Building 1960 Not Eligible 0.2 mile E
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15 �� Gardna
March 16, 2018
675339 Shell Gas 31660 Pacific Hwy S Building 1957 Not Eligible 0.8 mile NW
Station and
Food Mart
675407 - 31675 Pacific Hwy S Building 1968 Not Eligible 0.8 mile NW
675408 Church's 31717 Pacific Hwy S Building 1969 Not Eligible 0.8 mile NW
Chicken
709523 - 3409 20th Ave S Building Not Eligible 0.8 mile NW
Cultural Significance
Cardno's Senior Archaeologist, Jennifer M. Ferris, MA, RPA, conducted a field visit on February 9, 2018. During
her visit, she documented the existing conditions and photographed the substantial twentieth century land use
modification of the project area (Figures 4 through 8).
Archival research indicates that a low level of human activity may have taken place within or adjacent to the project
area during precontact and historic times. Of the few studies that have been conducted in the region, none have
identified any precontact cultural materials. Little evidence suggests any long-term precontact occupation within the
project area; rather, the land that encompasses the current project area was only traversed for resource
procurement during seasonal collection. Furthermore, the deposits within the project area consist of a shallow
organic -rich sod/forest duff stratum, underlain by native glacial till material (Helvey and Overbay 2017). The glacial
till deposited by glacial retreat (Dragovich et al. 2002), which indicates that cultural items, if present, would not be
deeply buried. The area underwent significant historic -era and modern land use modification including logging and
commercial development, which would have disturbed the shallow glacial till.
Cardno concludes that the potential for encountering surficial and/or subsurface precontact archaeological deposits
between the modern surface and the base of the Holocene sediments is low. Though low potential, it is possible
that archaeological resources currently unknown within the project area may hold importance as properties of
religious and cultural significance (including TCPs) to Indian tribes. Cardno also concludes that the potential for
encountering surficial and/or subsurface historic archaeological materials between the modern surface and the
base of the Holocene sediments is low. Historic archaeological deposits that may exist in the area are likely to be
associated with the Weyerhaeuser campus and/or historic -era timber operation (e.g., saw blades, spring -board
stump features).
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March 16, 2018
16 �,j� Cal -rind
Figure 4 Overview of the former WTC building from turnaround in northern portion of the project
area; facing southeast.
Figure 5 Overview of the north entrance road into the former WTC campus and present land use
modification; facing south.
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March 16, 2018
17 �'7 Car-dnv
Figure 6 Foot trail around the former WTC campus toward retention pond along the western margins
of the project area; facing north.
Figure 7 Overview of retention pond from the southwestern portion of the project area; facing
northeast.
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March 16, 2018
18 Gardnn
Figure 8 Overview of Weyerhaeuser Way South and existing utility infrastructure from the eastern
portion of the project area; facing northeast.
Architectural Significance
Cardno's Project Architectural Historian, Michelle Sadlier, MA, conducted a historic resources survey on February
6, 2018. She documented and photographed the WTC building, located at 32901 32nd Drive South (within parcel
162104-9013) and its associated outbuildings. Given that the WTC building and its associated outbuildings are
younger than 50 years in age, a Historic Property Inventory form was not completed.
Narrative
The project is located 0.2 mile from the central Weyerhaeuser Headquarters campus and consists of the WTC
grounds and a number of adjacent, undeveloped parcels. Construction drawings for the WTC indicate that it was
designed in 1976 by Skidmore, Owings & Merrill, which is the firm that also designed the 1969 NRHP-eligible
Weyerhaeuser Headquarters. Construction of the WTC was completed in late 1977/early 1978 (Figure 9) (Seattle
Times 1977; King County Tax Assessor's Office 2018).
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March 16, 2018
19 '� Card►io
Weyerhaeuser Technology Ctr. r J!
March 7, 1977
SiGa..y� a Yi
Figure 9 Construction of the Weyerhaeuser Technology Center; facing east. (Source: Weyerhaeuser
company files)
As designed, the purpose of the WTC was to combine all of Weyerhaeuser's research, development, and
engineering services previously located in other offices around the country into one, centralized campus (Figures
10 through 14). It served this purpose for 40 years. Since the Weyerhaeuser Headquarters' recent move to Seattle,
however, the number of Weyerhaeuser staff occupying the WTC has dropped significantly. The campus was sold to
IRG and name of the facility changed to the Greenline Technology Center. Today, much of the square footage of
the former WTC is leased to the company International Paper (Bylin 2018).
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March 16, 2018
20 <�:� Car-dnv
r
7
J.
A
Figure 10 Entrance to the Weyerhaeuser Technology Center; north elevation.
.i.
"-.
tip`". - -..� •� �.-, _• -.-•�,,.'-�,1�+F���... _
Figure 11 Weyerhaeuser Technology Center; north elevation.
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March 16, 2018
21 V� Camino
Figure 12 Weyerhaeuser Technology Center; south elevation.
Figure 13 South elevation of Weyerhaeuser Technology Center as viewed from the service yard. The
fire hydrant marks the original boundary of the yard, with the pavement in the foreground
located within the 1990s expansion area.
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March 16, 2016
22r7 L:ar-clno
Figure 14 Some of the outbuildings that have been constructed outside the WTC since the 1990s
expansion of the yard; facing south.
Historic Property Evaluation
The WTC was constructed 40 years ago in 1977/1978, and outbuildings located in its service yard were
constructed after this time. So, while the WTC is not without architectural merit, its date of construction places it
outside of the 45-year threshold for consideration for eligibility for local, state, and national registers of historic
places under SEPA.
The WHIR and NRHP ordinarily use an age threshold of 50 years old or older for determinations of eligibility.
However, because the Weyerhaeuser Headquarters campus was itself determined eligible prior to reaching the 50-
year threshold for consideration for NRHP eligibility, Cardno evaluated the WTC for potential eligibility under
Criteria Consideration G: a property achieving significance within the past 50 years if it is of exceptional importance.
While the WTC was designed by the same architects responsible for the Weyerhaeuser Headquarters, it was not
conceived as part of that innovative, award -winning master plan. Archival research has failed to identify a
noteworthy and widespread level of contemporary or retrospective public or professional interest in the design of
the building. Despite the quality of design of the building, Cardno concludes that, on its own merits, the WTC does
not achieve the level of exceptional importance needed to be considered eligible for the NRHP under Criteria
Consideration G.
Recommendations
Due to the dates of construction, Cardno recommends that the WTC and its associated outbuildings are Not
Eligible for listing in the WHIR or NRHP. In addition, although the City of Federal Way appears to be in the process
of establishing a register of historic places, formal agreements are not yet in place. Therefore, no buildings are
eligible for a local register either. As an ineligible property, the WTC and its associated outbuildings do not merit
consideration of project effects for the proposed development project. Cardno recommends the WTC and its
outbuildings be evaluated in 10 years when the building meets the NRHP's minimum age threshold of 50 years old.
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L'" 3
March 16, 2018 23 Carcina
Given the low potential for encountering buried cultural resources, Cardno does not recommend an intensive
archaeological survey be completed for the proposed project. However, Cardno does recommend that a Monitoring
and Inadvertent Discovery Plan (MIDP) be developed to outline steps to be taken by Federal Way Campus, LLC to
minimize potential impacts to any currently unknown intact archaeological resources in the event of an inadvertent
discovery during construction. These steps would serve to minimize damage to any inadvertently discovered
archaeological resources during ground -disturbing activities, which may include small, deeply buried, and/or widely
dispersed historic or precontact cultural materials (e.g., saws, saw blades, railroad ties, stakes, and footings; glass
bottles; sanitary cans; chipped -stone tools; ground stone; beads; shell; faunal remains; human remains; funerary
objects; and objects of cultural patrimony).
Steps included in the MIDP would outline the applicable local laws and regulations, stop -work and notification
protocols, discovery protection measures, assessment by professional archaeologists, and consultation with the
DAHP and any affected Indian tribes. In the state of Washington, archaeological sites are protected from knowing
disturbance on both public and private lands. RCW 27.44 and RCW 27.53.060 require that a person obtain a permit
from the DAHP before excavating, removing, or altering Native American human remains or archaeological
resources in Washington. A failure to obtain a permit is punishable by civil fines and penalties under RCW
27.53.095 and criminal prosecution under RCW 27.53.090.
Cardno recommends spot monitoring of project -related ground -disturbing activities within Holocene sediments by a
professional archaeologist who meets the Secretary of the Interior's (SOI's) professional qualifications standards
(36 Code of Federal Regulations [CFR] Part 61) for archaeology or by a qualified archaeologist supervised by a
professional archaeologist who meets the SOI standards. Spot monitoring entails a weekly site visit to the project
area during ground -disturbing activities and allows for a previously unexamined substrate to be observed by
personnel qualified in the identification of archaeological materials in order to evaluate the subsurface deposition of
the project area. Ground -disturbing activities include removal of any existing asphalt that extends into native fill and
alluvial sediments, site grading, development of staging areas, and installation of utilities and structural foundation
pilings. Monitoring should occur on a schedule determined in consultation with Federal Way Campus, LLC, the
SOI-qualified archaeologist, and the DAHP only during ground disturbance that extends from the ground surface to
the base of the Holocene sediments, which will vary in elevation across the project area, but typically do not exceed
18 inches below ground surface. The spot schedule should be determined during development of the MIDP. In
addition, the monitor should be available on -call to respond to any potential inadvertent discoveries that would be
reported in the manner outlined in the MIDP.
Please feel free to contact Ms. Ferris should you have any questions regarding the assessment of cultural
significance or recommendations.
Sincerely,
Daniel B. Costa
Staff Archaeologist
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24 (-' Cardno
March 16, 2018
Michelle Sadlier, MA
Project Architectural Historian
Jennifer Ferris, MA, RPA
Senior Archaeologist
PNW Cultural Resources Practice Lead
Direct Line: 206.239.7390
Email: iennifer.ferris@cardno.com
\ITIAI \1AT GAD 01101 11% r" www.cardno.com
25 C� Gardna
March 16, 2018
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