20220816 4th Ltr (Woodbridge Bus Pk-Tech Rev) 2200534.30
Civil Engineers
Structural Engineers
Landscape Architects
Community Planners
Land Surveyors
Neighbors
TACOMA
2215 North 30th Street
Suite 300
Tacoma, WA 98403-3350
253.383.2422 TEL
www.ahbl.com
August 16, 2022
Eric LaBrie
ESM Consulting Engineers, LLC
33400 8th Avenue South, Suite 205
Federal Way, WA 98003
Eric.labrie@esmcivil.com
Project: City Project Nos. 17-105489-UP, 17-105490-SE, and 21-104771-SH
AHBL No. 2200534.30
Subject: Technical Review Comments
Woodbridge Business Park (aka Greenline Business Park)
327xx Weyerhaeuser Way South, Federal Way
Dear Mr. LaBrie:
The City received a resubmittal of plans and documents associated with the Process IV and
SEPA review of the above project on November 21, 2021. You subsequently provided
authorization for my continued review of the application on December 8, 2021, and I received
the files on December 9, 2021. You also submitted a Shoreline Substantial Development
Permit application that was deemed completed on February 4, 2022 (No. 21-104771-SH).
These comments reflect staff review comments for all of the above referenced applications.
The City has the following comments in response to the resubmittal.
Summary of Proposed Revisions
The primary modifications in the revised proposal include:
• Stormwater pond revisions have occurred, including the addition of two vaults.
• Wetland and buffer impact reductions. The proposal includes a revised mitigation plan
and in-lieu fee proposal for wetland and buffer impacts.
• You have withdrawn the Boundary Line Adjustment (BLA) proposal.
• The perimeter boundaries of the project have been reduced to exclude parcels on the
northeast and southwest.
• With the perimeter boundary changes, frontage improvements to South 336th Street are
reduced in the southern segments.
• You have submitted a Shoreline Substantial Deve lopment Permit application for impacts
within the shoreline jurisdiction caused by roadway improvements.
• The landscape plan depicts additional tree plantings.
• There are no changes to the building sizes or locations.
Eric LaBrie
August 16, 2022
2200534.30
Page 2 of 13
Governing Regulations
The proposal is subject to the provisions of the 1994 Weyerhaeuser Company Concomitant Pre-
Annexation Development Agreement (CZA), and Corporate Park Zone (CP-1) zoning regulations in effect
on August 23, 1994. Critical areas are to be reviewed under the City’s current Critical Areas regulations of
the Federal Way Revised Code (FWRC) Chapter 19.145, and the Shoreline Permit is being reviewed
under FWRC Chapter 15.05. Drainage for new development shall be designed to comply with current
Federal Way drainage requirements and the land use procedural requirements are to follow FWRC Title
19.
Some comments provided herein are required to be addressed and some are informative, while others
may be applicable during future steps of the project. Comments in this letter that need to be addressed
prior to issuance of a SEPA threshold determination and/or the land use application staff report, are
provided in bold text. Questions regarding technical review comments should be addressed to the
referenced staff representative.
Lisa Klein – Contract Planner, (253) 651-7907, lklein@ahbl.com
Jim Harris – Planning Division, (253) 835-2652, jim.harris@cityoffederalway.com
1. Technical comments made about an item on one sheet may necessitate changes to other sheets
and related documents, and it is the applicant’s responsibility to determine any such necessary
adjustments. Please ensure consistent information is communicated throughout the plan set
and associated application materials.
Parking
2. Off-street parking shall comply with the 1994 Federal Way zoning code (FWCC) as modified by the
provisions of Section XIII of the CP-1 regulations. Required parking is one parking space per 300
square feet of gross floor area (GFA) for office, and one parking space for every 1,000 square feet
of GFA for warehouse. A floor plan has not been submitted, so the exact breakdown of office and
warehouse space has not been determined. You have explained, however, that a user has not
been identified and you provided an aggregate number of parking spaces and a Parking Analysis
(prepared by TENW, updated September 1, 2021), both of which acknowledge that the current site
plan does not meet the minimum requirements. You have requested that the City impose a
condition requiring the building permit application plan set to include a parking analysis that
demonstrates compliance with the required parking ratios. The City will not recommend approval of
the land use application with this condition. We disagree that this type of condition on the project
would be consistent with the Woodbridge Building B Finding #8 and Condition of Approval #3
because it includes more than one building, involves a parking space deficiency; is contrary to
Process IV decision criteria, and requires Use Process IV (see also Comment 5, below). The
following is required prior to issuance of a staff report to the Hearing Examiner:
a. The Site Plan and Parking Analysis do not provide the number of parking spaces per
building, just an aggregate number. Section XIII of the CP-1 regulations provided in the CZA
provide that existing development and uses are deemed to comply with the minimum
required number of spaces (i.e., the WTC Building parking), but new development is
required to comply with the following (emphasis added in underlined text):
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August 16, 2022
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“New development shall require compliance with applicable off-street parking minimums,
except in computing off-street parking requirements, the aggregate of all proposed and
existing uses on the property may, subject to approval of the Director, be considered as a
whole in establishing the minimum number of vehicle spaces required, based on the
following:
(1) Any excess capacity in existing parking spaces lying within 800 feet of a proposed
development may be used to reduce the requirement for additional parking
development.
(2) If the occupant of a proposed use provides van or alternative service between the
proposed use and remote parking facilities, any excess parking on the entire property
may be used to reduce the requirement for additional parking development.”
Our interpretation of the above requirements is that you are to provide the code-required
minimum parking spaces per building (existing spaces for WTC Building). Alternatively, if
you have an excess of parking for one building, but the overall aggregate parking quantity
meets code, you may choose to share any excess spaces among other buildings. In this
scenario, you must request the Director’s approval of the aggregate parking quantity and
demonstrate compliance with Items (1) and (2) above.
Depict the code-required parking quantities per building on the site plan. If you are
unable to meet the requirements per building, but the aggregate meets the
requirements, request Director approval and demonstrate compliance with Section
XIII.B. (1) and (2) provided above. Alternatively, you may apply for a Variance;
however, please note that it is not likely that a variance could be approved when
building sizes could be reduced to accommodate additional parking , among other
alternatives.
View Impacts to Historic District
3. The resubmittal included additional information that responds to previous City comments; however,
concerns remain about the visual impact of the buildings to the historic viewshed of the
Weyerhaeuser Campus. The Woodbridge Business Park project will have significant view impacts
and the burden is on the applicant to provide and demonstrate adequate screening and aesthetic
enhancements to mitigate the impact (FWRC 19.70.120).
Additionally, the Washington State Department of Archaeology and Historic Preservation (DAHP)
issued a letter dated October 21, 2020, that read:
“Weyerhaeuser Corporate Headquarters Historic District is eligible for listing gin the National
Register of Historic Places at the National level of significance and represents a potential National
Historic Landmark. We also concur with your determination that the project as proposed will have
an Adverse Effect on this historic property by diminishing its historic integrity of design and setting .”
The City has determined that it is necessary to hire a Historic and Cultural Resources consultant to
interpret all documentation prepared to date, and to advise the City on its SEPA environmental
review responsibilities specific to historic and cultural resources. We have initiated that process and
intend to select a consultant within the next few weeks. At this time, we have been able to identify
that the following additional information is needed for the consultant’s review:
a. The DAHP letter describes their “review of materials.” We have received the Cardno Cultural
Resources Archival Study dated March 16, 2018, but suspect there is at least one additional
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study to be reviewed. Please submit any other cultural or historic information that has
not been provided to date for the City consultant’s review.
b. Explain the status of the Memorandum of Agreement (MOA) with DAHP. Provide a
copy of the draft or final MOA.
c. Please note that per FWRC Chapter 19-100-040, the costs of the consultants’ investigations,
analyses, or reports are necessary for a determination of direct impact and shall be borne by
the applicant.
4. We have reviewed the Hearing Examiner’s decision on the Administrative Appeal of the Greenline
Warehouse A project (HEX 18-003;19-001) specific to the interpretation provided for Historic
Impacts and the requirements for protection of the view corridor (see Finding #13 on pages 12
through 14). One key conclusion from the Hearing Examiner’s Determination is the following
statement:
“From the testimony summarized above, it is determined that to avoid probably significant adverse
impacts to historical resources, the tree buffers must be wide enough to obscure Warehouse A
from sight and the building must not encroach into the view corridors to and from the headquarters
building.”
It is unclear how the current Woodbridge Business Park proposal impacts the view corridor. We
have the following comments that pertain to view protection in the potential “historic corridor”:
a. View Impact Assessment – The Visual Renderings you submitted dated November 12, 2021,
do not provide sufficient information to assess view impacts of the proposal . The
assessment needs to clearly show building size and scale, as well as the landscaping and
tree retention proposed to mitigate for the impacts. The original Visual Impact Assessment
dated March 22, 2018, is a good example of what the City is looking for, together with the
additional viewpoints the City requested and that you provided in the recent resubmittal.
Prepare and provide a Visual Impact Exhibit that demonstrates how the landscaping
and tree retention will mitigate view impacts from each of the six viewpoints depicted
on the Visual Renderings dated November 22, 2021.
b. Vegetative Screening as Mitigation – Your narrative describes that, as mitigation for view
impacts, you are providing a 50-foot wide tree buffer. You also state that storm pond #3 was
relocated to maintain a 50-foot buffer along the meadow. We do not see a 50-foot wide tree
buffer on the civil or landscape plans. We see vegetation retention area of varying widths,
some of which is meadow and provides no screening. There will be clearing for stormwater
pond and parking lot construction between Interstate 5 and the buildings. If you are referring
to the managed forest buffer, to our knowledge there are no trees proposed, or
recommended, within the section of the managed forest buffer located adjacent to the
meadow. Depict the 50-foot wide view mitigation tree buffer on the civil and landscape
plans and/or provide additional clarification of your intended view mitigation
proposal.
Eric LaBrie
August 16, 2022
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c. View of Rear of WTC Building – In response to our comments, you have revised the storm
ponds located between Interstate 5 and the existing and proposed buildings and added
some trees for screening on the eastern edges of the wetland areas. While the changes are
improvements from the previous proposal, we remain concerned that the rear elevation of
the existing WTC Building will be visible from Interstate 5 once trees are cleared for
stormwater pond construction. The condition of the rear of the building has deteriorated and
requires improvements and enhanced screening (see Comment 9, below) to mitigate for
view impacts. The rear elevation is to be restored to like-new condition prior to
approval of the clearing and grading and/or site development permit, whichever
comes first. Provide a commitment to enhance the rear side of the WTC Building to
like-new condition.
5. The Woodbridge Business Park proposal is different from the Greenline Building A and Greenline
Building B proposals in that it is larger in scale, in a more visible location , and required to follow
Use Process IV, which has different procedural requirements than Use Process III. The primary
difference in procedures is that the Decision on the application is made by the Hearing Examiner
following a public hearing. The Use Process IV procedures require staff to prepare a Staff Report to
the Hearing Examiner, complete with all written comments received by the department, an analysis
of the application under relevant code provisions and the comprehensive plan , a statement of the
facts found by the director and the conclusions drawn from those facts , and a recommendation on
the application. The other primary difference in Use Process IV is that the Decision is appealed to
the Superior Court, the outcome for which is dependent on the quality of the application materials
and City analysis. As such, we will require responses to outstanding comments and resolution of
outstanding issues prior to going to hearing on the project.
Building Elevations and Design Brief
6. In our March 2021 technical review letter, we provided staff analysis of the CZA and FWCC design
requirements affecting development specific to building design and options to address the
deficiencies. Your response to the comments was to refer staff to the previous approval of
Woodbridge Buildings A and B and proposed no building design changes . Staff interprets the
scale, location, and visibility of the project as uniquely different from Buildings A and B, and the
Use Process IV requirements as requiring a higher bar (see Comment 5, above). Based on the
CZA requirements and previous staff analysis in our March 2021 letter, we have the following
comments:
a. At this location, the overall design of the buildings is not representative of the CZA
requirement that the buildings be of superior quality. The existing campus and the design
details of the headquarters and WTC buildings provide guidance as to what was intended by
“superior quality.” Additionally, when multiple buildings are provided on the same site, they
should create a unified, campus-like development (a current code requirement, but a
common prerequisite for a site with multiple buildings). The existing headquarters and visible
sides of the WTC buildings are relatively timeless in their design (i.e., not trendy), with strong
horizontal and rectangular lines and a significant amount of glazing. Given their highly visible
location, the proposed building design is not complementary to, or reminiscent of the existing
buildings. The mountain-themed paint scheme serves to break up the façade but does not
correlate to the existing buildings or legacy of the site, which is more about trees and timber
than mountain views. Revise the building exterior design. Staff’s recommendation is to
eliminate the mountain paint scheme and expand the vertical wood panels. Additional
windows would also improve the building’s quality of design and provide a more
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August 16, 2022
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complementary design to the existing buildings’ legacy of the campus. Staff is open
to other options for improvements to the building design that the architect may
propose that are more representative of the intentions of the CZA than the building
design proposed.
Managed Forest Buffer, Landscape Plans, and Tree Retention
7. The screening of the truck bays on the north side of Building A to the future right-of-way and
properties to the north may require enhancement. The WFC Plan describes the western half of this
area as containing Forest Cover Type III. Forest Cover Type III is described in the WFC Plan as
being poorly stocked with 30 trees per acre and containing large gaps where shade tolerant
conifers, such as western red cedar, could be planted. Interplanting with a shade tolerant tree
species would improve this buffer over time and screen the truck bays from the future right-of-way.
In lieu of revising the landscape plans at this time to include the addition of shade tolerant tree
species within Forest Cover Type III, you have requested a condition of approval that the buffer be
assessed post-construction to determine where infill plantings should occur, if needed . Staff
concurs that this approach is acceptable. The condition of approval will require assessment of the
buffer post-construction, and infill plantings provided in conjunction with the forester’s
recommendations for shade tolerant trees in this location.
8. There are concerns about the location of the storm vault northeast of Building 1 (see the Traffic
Division comments, below). If the vault is to remain in this location, any portions not required
to be free of cover shall be landscaped with grass or other groundcover.
9. FWCC Sec. 22-1564(b) requires all outside storage areas be fully screened by Type I landscaping
a minimum of 5 feet in width. According to aerial photographs and Sheet Ex-01, there is currently
an outside storage area in the rear/west side of the existing WTC Building. The rear elevation
appears to be in poor condition and, while the plans show reconstruction of the rear parking lot,
there is no indication if outside storage is intended to remain. The landscape plans provide a
landscape buffer around the exterior of the parking lot; however, it is not clear that they are solid
sight barriers and the landscape plans do not specifically describe the landscaping as Type I .
Indicate if outdoor storage is planned to continue on the rear side of the existing WTC
Building. If outdoor storage is intended to remain, the landscape plans shall be revised to
fully screen the rear side of the WTC Building with Type I landscaping a minimum of 5 feet
in width located on the west, north, and south sides of the parking lot.
10. FWCC Sec. 22-1567 requires Type IV landscaping within interior parking lot areas. For industrial
developments with more than 50 parking stalls, 22 square feet of landscape area shall be provided
per parking stall. The proposal seeks to provide 1,520 standard vehicle parking stalls, which
requires a total of 33,440 square feet of landscape area. The proposal is also providing 31 trailer
parking spaces, but the FWCC does not indicate a specific requirement for anything other than
standard vehicle stalls. Sheet LA-03 indicates that a total of 115,638 square feet of parking lot
landscape area is provided, far exceeding the minimum. However, there is not a breakdown of the
landscape area per building parking lot. Provide the number of parking spaces per building
and the parking lot landscape area per building.
Eric LaBrie
August 16, 2022
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Shoreline Substantial Development Permit Review Comments
11. The proposal seeks to make improvements to Weyerhaeuser Way S outh that are partially within
200 feet of the Shoreline Management Zone of North Lake, a shoreline of the state regulated by
FWRC Title 15. Transportation Facilities are a permitted use within the shoreline environment with
approval of a Shoreline Substantial Development Permit (SSDP) (FWRC 15.05.070(5)). To
continue our review of the SSDP application, the following additional information is needed:
a. Per 15.05.075(2)(c), provide the location of existing trees, their size (diameter at breast
height), and their species located in and adjacent to the area planned for roadway
widening that is within the shoreline jurisdiction.
b. Provide a revegetation plan for those areas within the shoreline jurisdiction that will
be disturbed as a result of the construction of the roadway widening . See FWRC
15.05.075(2)(d) and (3) for specific requirements for the revegetation plan.
c. Per FWRC 15.05.090(3)(f), all developments and uses shall result in no net loss of
ecological functions and shall be consistent with the impact mitigation requirements of
FWRC 15.05.040(1). The Addendum to the April 9, 2020, Critical Areas Report and
Proposed Mitigation Plan does not address the road improvements. Provide new or
revised Addendum that addresses the roadway improvements in the shoreline and
provides a no net loss analysis.
d. Transportation facilities are an allowed shoreline use within the Urban Conservancy
environment under the requirements of FWRC 15.05.080(5)(a)(v). Transportation facilities
for commercial uses are to incorporate low impact development (LID) designs to minimize
stormwater runoff. Provide a response to this requirement demonstrating either how
LID is proposed to be utilized or an explanation of why LID measures are not
proposed.
e. Provide a cross section extending from the ordinary high water mark (OHWM) through
the roadway improvements within the shoreline jurisdiction. Include existing ground
elevations, proposed ground elevations, and the OHWM.
f. Depict the 50-foot setback and the distance from the OHWM to the proposed roadway
improvements on the plans.
12. Review and address the shoreline comments in the enclosed May 20, 2022, review letter from
ESA, the City’s wetland consultant.
Wetlands and Streams
13. Review and address each comment in the enclosed May 20, 2022, review letter from the City’s
wetland consultant, ESA.
SEPA Checklist
14. As described in Comment 3.a above, provide all cultural resources studies, draft or final
agreements, and all tribe and DAHP correspondence, that has been completed to date for this site
and project so that the City’s historical and cultural resources consultant can fully complete SEPA
environmental review.
Eric LaBrie
August 16, 2022
2200534.30
Page 8 of 13
15. Question A.9 : Add that King County needs to approve the fee-in-lieu mitigation plan.
16. Question B.1.e provides that a net cut quantity of 29,000 CY based on the overall cut and fill . The
math does not add up and is inconsistent with the quantities on the grading plans . Revise the
SEPA checklist cut/fill quantities.
17. Question B.3.a.1 describes 63 onsite wetlands. The in-lieu fee plans describe that there are 48
onsite wetlands and the Critical Areas Addendum lists 45 wetlands , but only 33 are onsite. Provide
updated data pertaining to onsite wetlands in all documents.
18. Section 10, Aesthetics and Section 13, Historic and Cultural Resources may need to be revised in
the future, depending on the recommendations of the historical/cultural resources consultant.
Other Details
19. There are discrepancies with the Impervious Surface Exhibit calculations and the Technical
Information Report (TIR) calculations for impervious area. The existing vs. proposed impervious
areas are potentially transposed on the TIR. Review the calculations in each and revise to be
consistent.
20. There are discrepancies in the project area. Sheets ST-02, EX-02, SD-02, LA-02, GR-02 and TR-
01 all depict that Tax Parcel 228500-0010 is not a part of the project. The Critical Areas Mitigation
Plan Sheet WI.4 depicts temporary construction impacts and buffer restoration within this parcel.
Either remove the construction impacts in this area or revise the parcel boundaries.
21. Label what appears to be an easement in the northeast corner of Sheet ST-01.
22. A boundary line adjustment will need to be approved and recorded prior to issuance of building
permits that depicts compliance with the project’s governing regulations, including setbacks. This
will be a condition of approval.
23. Walls have been added between the buildings and Weyerhaeuser Way South, but wall heights are
not provided. Provide all wall heights on the grading plan.
24. The TIR states the project area is 146 acres. This is different than the site plan and cover letter,
which provide a project area of 97.66 acres. Revise the TIR to reflect the project area changes.
Cole Elliot – Public Works Development Services, (253) 835-2730,
Cole.elliott@cityoffederalway.com
Prior to Land Use Approval, the applicant shall address the following c omments on the November 2021
resubmittal:
25. The applicant has stated that a portion of the site that drains to the Sphagnum Bog, to the
northwest of the site, will be directed into the proposed onsite flow control and water quality
treatment systems, and that Figure 1.2 in the TIR depicts the drainage basin area of the site that
drains to the bog. However, Fig 1.2 does not appear to show this area. The applicant will need to
update this figure and show the area of the site that currently drains to the Sphagnum Bog and
include the basin area on this figure.
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August 16, 2022
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26. Pond 1 has been relocated into an underground vault on the west side of Weyerhaeuser Way
South. Section 4.1.1.B. of the City’s Development Standards states that flow control facilities for
private commercial developments outside the City Center Core shall be open, or above ground
ponds, unless approved by the Public Works Department. For this underground vault to be
approved, a separate modification request shall be applied for Public Works revie w and approval.
The modification request form is available by contacting the Public Works Review Engineer.
27. Statements in the TIR indicate that water quality treatment for the new/widened Weyerhaeuser
Way South will be provided in relocated roadside swales. Roadside swales do not provide the
required level of water quality treatment (Enhanced Basic treatment is required). Some form of
water quality treatment that meets the Enhanced Basic Treatment menu of the King County
Surface Water Design Manual (KCSWDM) shall be provided for the roadway. The City allows
treatment options identified in the KCSWDM or those treatment options that meet the Enhanced
Basic Treatment criteria and have General Use Level Designation (GULD) by the Washington
State Department of Ecology.
28. The City has now adopted the 2021 KCSWDM. All stormwater systems for the project shall be
designed per the requirements of that manual.
Sarady Long – Public Works Traffic Division, (253) 835-2743, sarady.long@cityoffederalway.com
The Public Works Traffic Division has finished its review of the submitted materials and has provided the
following technical review comments. Please note, traffic related comments/ concerns by the Washington
State Department of Transportation (WSDOT) and other agencies must be addressed and approved by
the respective agency.
Plans Comments
29. Revise plans to show street improvement and right-of-way dedication along the entire frontage that
abuts the subject property on South 336th Street, Weyerhaeuser Way South, and at the
Weyerhaeuser Way South roundabout. Unless a street modification is granted/approved by the
Public Work Director, the submitted plans must show the improvements and right-of-way dedication
along the entire property frontage on Weyerhaeuser Way South, South 336th Street, and at the
roundabout, as required by code (FWCC 22-1474). ADA-compliant pedestrian facilities must be
provided at the roundabout.
30. The project trip assignment in the Traffic Impact Analysis (TIA) depicted about 50% of the truck
trips will travel on Weyerhaeuser Way South to and from SR 18 ramp terminal intersections.
Weyerhaeuser Way South, north of the SR 18 ramp terminal intersection, is a non-truck route,
except for delivery. As such, the entire truck route (Weyerhaeuser Way South) must be designed to
accommodate the expected truck traffic. The pavement along the truck travel route on
Weyerhaeuser Way South, including the roundabouts, must be designed to accommodate the
expected truck traffic. Additionally, a truck turning path/diagram should be provide d to ensure the
roundabouts on Weyerhaeuser Way South can accommodate the expected trucks (WB-67).
31. The proposed right-of-way dedication depicted as a 106-foot development reservation for the future
South 324th Street extension connecting to Weyerhaeuser Way South is not consistent with the
City Center Access preferred alternative improvements. The preferred alternative identified two
roundabouts on South 324th Street, at 23rd Avenue South and Weyerhaeuser Way South.
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Coordinate with the City Center Access Study team to determine the future alignment and
intersection roundabout design at Weyerhaeuser Way South.
32. The proposed northerly driveway and detention vault 1A should be relocated further south away
from the future South 324th Street and Weyerhaeuser Way South roundabout intersection. Based
on a conceptual design layout, the South 324th Street extension would intersect with Weyerhaeuser
Way South at the proposed northerly driveway. Coordinate with the City Center Access Study team
to determine the future alignment and intersection roundabout design.
33. Driveways should be constructed to the commercial, industrial driveway approach standard. A
street modification will need to be submitted and approved by the Public Works Director to use
radius driveway and any driveway’s width exceeding the maximum 30 feet. Per FWCC 22-1542, for
driveways that serve uses other than residential uses, the maximum driveway width is 30 feet for a
two-lane, two-way driveway that intersects an arterial street and 26 feet for a two-way driveway that
intersects a local street. Driveway widths may be increased to provide adequate width for vehicles
that may be reasonably expected to use the driveway, as determined by the Public Works Director.
34. Adequate throat length should be provided at access driveways to minimize traffic backing up onto
through street.
35. The AutoTURN exhibit did not show driveway width. Revise AutoTURN exhibit to include driveway
width at all access driveways with WB-67 trucks. Driveway widths may be increased or modified to
radius driveways to provide adequate width for vehicles that may be reasonably expected to use
the driveway, as determined by the Public Works Director.
36. Show conceptual street lighting along the entire property frontage on South 336th Street and
Weyerhaeuser Way South on the plans. Details design is not required at this time.
37. Per the TIA, a southbound right-turn lane is warranted and, as such, the plans must be revised to
include a southbound right-turn lane at all access driveways. Please note, additional right-of-way
dedication would be needed for the turn lane.
38. Confirm if there is a 25-foot wide managed forest buffer within the proposed 106-foot development
reservation (right-of-way) for the future South 324th Street extension.
TIA Review Comments
39. WSDOT has jurisdiction over South 320th Street/SR 5 and Weyerhaeuser Way South/ SR 18 ramp
terminal intersections, and therefore its respective LOS standards shall apply. The TIA should
clearly specify study intersections under WSDOT control. Coordinate with WSDOT on technical
review comments.
40. For future 2023 year analysis at signalized intersections, use a default PHF of 1.0 for the entire
intersection and existing approach PHFs for unsignalized intersections. This is for information only
because this revision will not likely alter the LOS result.
41. Please note, the LOS standard specified in the TIA is based on the current adopted standard. It is
staff’s understanding that this project is subject to the concomitant agreement and 1994 code,
which is LOS E or better with v/c less than 0.90.
Eric LaBrie
August 16, 2022
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42. Truck trips depicted in Table 4 (Trip Generation Summary) are not consistent with the Appendix D
Trip Generation Calculations. Table 4 depicts 16 truck trips (4%) for both AM and PM peak hours.
However, Appendix D (Trip Generation Calculations) and trip figures in the TIA depict 39 trips
(10%) for both AM and PM peak hours. Verify and revise the trip figures and the LOS analysis
accordingly.
43. Provide a separate trip assignment figure showing only the expected truck travel route.
44. The proposed pipeline trips from surrounding developments are acceptable. However, the TIA
should provide a separate figure of these trips.
45. Horizon year shown in Table 5 and Table 8 should be consistent with the LOS printout output.
Horizon year in the TIA specified 2023 future year and the LOS printout for Saturday analysis
specified 2022.
46. Page 7 – Transit Service: Coordinate with King County Metro and Pierce Transit for any onsite or
offsite transit related improvements requirement.
47. Credit for right-of-way dedication for the future South 324th Street extension against the traffic
impact fee (TIF) would be subjected to FWRC 19.91.090. Traffic impact fees for commercial
developments shall be calculated based on the impact fee schedule in effect at the time a
completed building permit application is filed and paid prior to permit issuance , per FWRC 19.91.
48. The City concurs with using the Transportation Institute Engineer (ITE) Trip Generation Manual
10th Edition LUC 130 (Industrial Park) to estimate the trip generation for the development. Because
the actual tenant(s) is still unknown, Industrial Park land use consisting of manufacturing, service,
and warehouse facilities is appropriate. Please note, additional analysis may be required if the trips
generated by the actual uses exceed the trips identified in the traffic report.
49. The trip assignment in Figure 6 through Figure 8 (AM, PM, and Saturday Trip Assignment)
depicted about 50% of truck trips traveling on Weyerhaeuser Way South to and from SR 18 ramp
terminal intersections. Weyerhaeuser Way South, north of SR 18, is designated as a non-truck
route, except for local deliveries, due to the existing road pavement. Furthermore, based on this
distribution, the pavement on Weyerhaeuser Way South would need to be evaluated and improved
from the site to SR 18 (truck travel route) to accommodate the expected truck traffic load.
50. The signalized intersection LOS results for 2023 AM and PM depicted in Table 6 are not the same
as the LOS calculations printout in Appendix C. Verify and update Table 6 accordingly.
51. The LOS calculation printout in Appendix C for Weyerhaeuser Way South and South 320th Street
intersection depicted v/c ratio of 0.98 for 2023 without project and v/c ratio of 1.1 for 2023 with
project. Mitigation measures should be identified to address this LOS failure.
52. Per code, the proposed site access driveway locations meet the minimum spacing of 1 50 feet from
any street’s intersection or to any other driveways. However, further analysis should be conducted
to ensure that the driveway will not be located within turn lane storage, taper, queues, etc., of the
existing and future intersection. For example, the north driveway depicted on the latest site plan
would be located within the future South 324th Street and Weyerhaeuser Way South roundabout
splitter island.
Eric LaBrie
August 16, 2022
2200534.30
Page 12 of 13
53. The City does not agree with the traffic study recommendation not to install a southbound right-turn
lane at the three driveway locations. The TIA identified that all three driveway locations met
WSDOT Design Manual guidelines for a southbound right-turn lane. Given that almost 20% of the
3,063 daily trips are truck trips, a right-turn lane should be installed at all driveway locations to
reduce interference and delay to the through movement.
54. Weyerhaeuser Way Assessment: The City concurs that the 2023 future with project is expected to
meet the minimum street design standards for a Type K street. However, the street should be
designed using 20 years projection traffic volume. Please note, this is based on the current
development standard.
55. WSDOT has jurisdiction over South 320th Street/SR 5 and Weyerhaeuser Way South/ SR 18 ramp
terminal intersections, and therefore its respective LOS standards shall apply. Any LOS failure and
mitigation measures must be reviewed and approved by WSDOT. Coordinate with WSDOT on
technical review comments.
SEPA Checklist - Transportation
56. Transportation 14(a): Update this section to include that Weyerhaeuser Way South connects to
South 320th Street, which connects to Interstate 5 and SR 18.
57. Transportation 14(c): The mitigation section in the TIA did not specify mitigation measures for the
signalized intersection of Weyerhaeuser Way South and westbound SR 18. However, the TIA
identified that a southbound turn lane is warranted at all access driveways . Update this section
accordingly.
58. Transportation 14(e): The trip generation summary in the TIA specified trucks account for 18% of
daily site trips and 10% of the AM and PM peak site trips. Update this section to be consistent with
the TIA.
59. Transportation 14(g): Revise this section to include southbound right-turn lane at the three
driveway locations.
Pavement Analysis Report
60. The pavement design guidance for the southern section is still valid for this northern section. The
pavement design for Weyerhaeuser Way South shall be in accordance with the procedure in the
AASHTO Guide for Design of Pavement Structures (1993). The WSDOT Pavement Policy
September 2018 may be used as guidance for local data if applicable.
61. For general design criteria, the total daily traffic data to calculate ESAL should be based on two-
way annual average daily traffic (AADT). Also, change the reliability from 85% to 95% if the EASL
exceed 10,000,000.
62. The TIA uses 2019 traffic data and, as such, the pavement analysis should use the same data
instead of 2017 counts.
63. Specify if the daily truck load in the report includes truck trips generated by development south of
the site (Warehouses A and B).
Eric LaBrie
August 16, 2022
2200534.30
Page 13 of 13
64. Once the pavement design is approved by the City, the developer shall perform full depth
pavement reconstruction on Weyerhaeuser Way South from curb to curb.
Closing
Please be aware that this review does not preclude the City from requesting additional information related
to any of the topics discussed above. Please submit be electronic submittal (Document Upload Link or
https://www.cityoffederalway.com/node/4588) revised application materials as appropriate, a letter
explaining how these comments have been addressed, and the completed “Resubmittal Information
Form” (enclosed).
Please note the original application fees collected at submittal cover the initial review and one resubmittal
only. A resubmittal fee will be charged for each review following the first resubmittal.
Pursuant to FWRC 19.15.050, if an applicant fails to provide additional information within 180 days of
being notified that such information is requested, the application shall be deemed null and void and the
City shall have no duty to process, review, or issue any decisions with respect to such an application.
If you have any questions regarding this letter, please contact either Jim Harris or me (see contact
information provided above).
Sincerely,
Lisa Klein, AICP
Contract Planner for City of Federal Way
LK/lsk
Encl: Technical Review Letter from ESA dated July 20, 2022
Resubmittal Information Form
c: Brian Davis, Community Development Director
Stacey Welsh, Principal Planner, stacey.welsh@cityoffederalway.com
Jim Harris, Senior Planner, Jim.Harris@cityoffederalway.com
Cole Elliot, Public Works Development Services Manager, cole.elliott@cityoffederalway.com
Sarady Long, Senior Transportation Planning Engineer, Sarady.Long@cityoffederalway.com
Brian Asbury, Lakehaven Water and Sewer District, basbury@lakehaven.org
Sean Nichols, South King Fire and Rescue, sean.nichols@southkingfire.org
Dana Ostenson, dostenson@industrialrealtygroup.com
Q:\2020\2200534\WORDPROC\Letters\Drafts\20220803 Draft 4th Ltr (Woodbridge Bus Pk-Tech Rev) 2200534.30 (wp update).docx
July 20, 2022
Jim Harris, City of Federal Way Department of Community Development
Jessica Redman
Critical Areas Addendum and Supporting Documents Review: Woodbridge Business Park
At the request of the City of Federal Way (City), Environmental Science Associates (ESA) reviewed several
documents for the property at approximately 32901 Weyerhaeuser Way South in Federal Way, Washington. The
136-acre site is a combination of five parcels (King County Tax Parcel Numbers 1621049056, 1621049013,
1621049030, 1621049036, and 2285000010) currently owned by Federal Way Campus, LLC.
This property was originally reviewed by ESA between May and August of 2017 as part of the Tech Center
Boundary Line Adjustment project. Several site visits were conducted to evaluate wetland boundaries. Results
were reported to the City in the Existing Conditions Report – Tech Center Boundary Line Adjustment technical
memo (dated August 22, 2017) and the Review of the Letter titled “Response to Comments dated 22 August
2017” Existing Conditions Report – Tech Center Boundary Line Adjustment (letter dated August 22, 2017)
technical memo (dated October 16, 2017). Previous versions of the critical areas report and conceptual mitigation
plan (dated October 27, 2018 and April 9, 2020) were also reviewed by ESA. Findings of the most recent review
of the critical areas report (dated April 9, 2020) were presented to the City in the Critical Areas Report and
Conceptual Mitigation Plan Review: Woodbridge Business Park technical memorandum (dated January 25,
2021). In response to ESA’s comments and recommendations in the January 25, 2021 technical memo, the
applicant has submitted the following documents that are included in this review:
The technical memo titled Addendum to 9 April 2020 Critical Areas Report and Proposed Mitigation
Plan (prepared by Wet.land, LLC and dated October 10, 2021;
The technical memo titled Response to City Comments (prepared by Wet.land, LLC and dated October
10, 2021);
Woodbridge Business Park Project In-Lieu Fee Plan (prepared by Wet.land, LLC and dated October 10,
2021);
Woodbridge Business Park Critical Areas Mitigation Plan (prepared by Talasaea and dated September 9,
2021); and
Woodbridge Business Park Plan Set (prepared by ESM Consulting Engineers and dated November 12,
2021).
Critical Areas Addendum and Supporting Documents Review: Woodbridge Business Park
2
The current application involves the construction of three new buildings that will provide approximately 961,390
square feet (SF) of new warehouse and office space. The Tech Center building will remain and the existing
parking lot will be reconfigured to maximize space. Associated infrastructure to be constructed includes new
stormwater detention facilities, parking for cars and trucks, and maneuvering space for the anticipated truck
traffic around these buildings.
Site Background and Purpose of Review
In 1994, the Weyerhaeuser Company entered into a pre-annexation zoning agreement with the City, known as the
Concomitant Agreement, to ensure that once annexed, the Weyerhaeuser Company Campus was developed “with
maximum flexibility which will insure optimal development, while preserving the unique natural features of the
site” (Weyerhaeuser Company Concomitant Pre- Annexation Zoning Agreement, 1994). The purpose of this
review is to determine if the proposed project is in compliance with Concomitant Agreement, Chapter 19.145
(Critical Areas) of the Federal Way Revised Code (FWRC), and Chapter 15.10 (Critical Areas in Shoreline
Management Areas) of the FWRC.
Review of Documents
ESA reviewed the documents listed above. Generally, the project has not changed since ESA reviewed the project
in 2020. According to the documents, 48 wetlands and one stream occur within the site of the Business Park
project (the Project). The site is also adjacent to North Lake, a shoreline of the state. The stormwater pond and
wetland creation east of Weyerhaeuser Way have been removed, resulting in a reduction of wetland impacts from
approximately 12,000 square feet (SF) to 8,492 SF. Seven wetlands would be insufficiently buffered, and
therefore are being considered indirectly impacted due to site development encroachments, resulting in an
additional 7,840 SF (0.18 acre) of indirect wetland impact. An additional 3,024 SF (0.07 acres) of permanent
buffer impacts and 29,819 SF (0.68 acre) of temporary construction impacts are anticipated for the construction
of detention ponds and associated access roads. No work will occur within the ordinary high water of the stream
and no permanent impacts are proposed to the stream buffer. The applicant has decided to adjust the proposed
mitigation to purchase credits through the King County In -Lieu Fee program so that mitigation through all
agencies is consistent, as detailed in the Woodbridge Business Park Project In-Lieu Fee Plan.
Review Comments and Recommendations
Based on the document review for consistency with the City of Federal Way requirements and regulations, we have
the following comments and recommendations:
1. The critical areas report dated April 9, 2020 states that 48 wetlands were identified on the project site.
However, technical memo titled Addendum to 9 April 2020 Critical Areas Report and Proposed Mitigation
Plan (hereinafter referred to as the CAR Addendum) only identifies 45 wetlands, 21 of which are outside of
the project area. It is recommended that the critical areas report be revised to include all delineated wetlands or
provide an explanation as to why three wetlands (Wetlands BA, BB, and BD) were omitted.
2. According to Table 1 in the technical memo titled Response to City Comments (hereinafter referred to as
the Comment Response), Figure 2 in the Woodbridge Business Park Project In-Lieu Fee Plan (hereinafter
referred to as the ILF Plan), and the summary of proposed wetland impacts & mitigation table on Sheet W1.4
of the Woodbridge Business Park Critical Areas Mitigation Plan (hereinafter referred to as the Mitigation
Plan) the project will result in a total of 8,492 SF of direct wetlands impact. However, the actual total of the
direct wetland impacts in these tables equals 8,612 SF, a difference of 772 SF. It is recommended that these
Critical Areas Addendum and Supporting Documents Review: Woodbridge Business Park
3
tables be corrected and the credit analysis be revised, as needed. Additionally, these tables include mitigation
ratios and wetland creation requirements. It is recommended that these values be removed as no wetland
creation is being proposed.
3. The text in the CAR Addendum is inconsistent with the figures in the Mitigation Plan. For example, in
Section 2.1, the CAR Addendum states that 5,413 SF of the buffer of Wetland AG will be temporarily
impacted and 2,926 SF of new buffer will be added. However, Sheet W1.4 of the Mitigation Plan, calls out
6,248 SF of temporary buffer impacts and 3,100 SF of buffer replacement. Additionally, Section 2.2. states
that 406 SF of Wetland AV will be indirectly impacted but Sheet W1.3 of the Mitigation Plan calls out 380
SF. ESA recommends the text in the CAR Addendum or the Mitigation Plan be revised to be consistent.
4. Table 1 in the CAR Addendum states that the square footage of buffer reduction for several wetlands was
included for wetlands that either had indirect wetland impacts that modified the standard buffer, or lacked a
full standard buffer due to existing constraints of the Site. It is recommended that the amount of buffer
reduction for all wetlands be included to ensure that the proposed buffer creation is sufficient.
5. As stated in our January 25, 2021 review memo, the City considers grading within a wetland buffer to be
development, and therefore, simply restoring the buffer post-construction does not meet FWRC requirements.
The applicant needs to show that the proposed temporary buffer impacts due to site grading meet the criteria
under FWRC 19.145.440 – Development within wetland buffers, including requirements for buffer averaging
and/or buffer reduction if proposed. ESA does not believe this has been met. For example, according to the
CAR Addendum, 5,413 SF of the buffer of Wetland AG will be temporarily impacted through site grading
and only 2,926 SF of buffer will be added, which does not meet the requirements of buffer averaging per
FWRC 19.145.440(5).
6. According to the CAR Addendum, 17,531 SF of temporary buffer impacts will occur through the
restoration of an existing trail to functioning buffer. It is recommended that a description of the proposed
restoration be included in the critical areas report. Similar to grading, this work may be considered to be
development by the City and would need to meet the criteria under FWRC 19.145.440. The same is
recommended for the restoration of the unpaved access road to functioning buffer proposed in the buffer of
Wetland AV.
7. According to Section 2.3 of the CAR Addendum a small swale is proposed within the buffer of Wetland
BR that will temporarily disturb 362 SF of buffer. The construction of this feature would likely require
grading and therefore be considered to be development by the City and would need to meet the criteria under
FWRC 19.145.440. Additionally, this does not appear to be a temporary impact and should be included in the
permanent buffer impact calculations.
8. According to the CAR Addendum the indirect impacts to Wetland AV exceed the 25% buffer reduction
allowed per FWRC 19.145.440(6). Because this does not meet code requirements, this should not be part of
the proposal.
9. The applicant is proposing reducing several of the wetland buffers by 25 percent. According to FWRC
19.145.440(6), this is done on a case-by-case basis with the decision is based on the following criteria:
(a) It will not adversely affect water quality;
Critical Areas Addendum and Supporting Documents Review: Woodbridge Business Park
4
(b) It will not adversely affect the existing quality of the wetland or buffer wildlife habitat;
(c) It will not adversely affect drainage or stormwater retention capabilities;
(d) It will not lead to unstable earth conditions nor create erosion hazards;
(e) It will not be materially detrimental to any other property or the city as a whole; and
(f) All exposed areas are stabilized with native vegetation, as appropriate.
It is recommended the critical areas report be revised to include a discussion on how the proposed buffer
reductions meet these requirements.
10. According to Section 2.12 of the CAR Addendum, the indirect impacts to Wetland GB-North were
calculated based on a 45-foot minimum buffer, or the reduced buffer. It is our understanding that when
proposing wetland as buffer, the standard buffer should be used as the requirements for buffer reduction in
FWRC 19.145.440(6) have not been met.
11. In the January 25, 2021 memo, ESA stated the wetland buffers on the Site Plan are inconsistent with the
wetland buffers on the figures in the Revised Report. We agree with the Comment Response that Site Plan
has been revised to reflect the buffers presented in the Report and Mitigation Plan.
12. As stated in our January 25, 2021 review memo, sheets of the Site Plan that contain the proposed
development should only show the buffers post-development and should not include existing buffers for
wetlands that will be filled or indirectly impacted. We agree with the Comment Response that the Site Plan
sheets have been sufficiently revised to meet this request.
13. In the January 25, 2021 memo, it was recommended that the methodology used to flag the ordinary high
water mark (OHWM) of North Lake be included in the critical areas report. ESA agrees that Section 1.1 of
the CAR Addendum sufficiently meets this recommendation. ESA will verify the location of the OHWM in
the field during the application review. It recommended that the applicant reflag the OHWM of North Lake
before field verification is conducted.
14. In the January 25, 2021 memo, it was recommended that the line representing the 200-foot Shoreline
Management Zone be added to all relevant figures. ESA agrees that this revision has been made to the figures
in the Mitigation Plan. However, it is recommended that revised figures showing the Shoreline Management
Zone (SMZ) also be included in future revisions of the critical area report.
15. According to the Comment Response, road improvements will occur within the SMZ. A discussion of this
work is not included in the CAR Addendum. It is recommended that a description of this work, as well as an
analysis of how this work may impact shoreline functions be included in the critical areas report. This
information, including a no net loss analysis, could be submitted to the City in an additional addendum to the
CAR.
Bulletin #129 – January 20, 2022 Page 1 of 1 k:\Handouts\Resubmittal Information
RESUBMITTAL INFORMATION
This completed form MUST accompany all resubmittals.
Additional or revised plans or documents for an active project will not be accepted
unless accompanied by this completed form. Changes to drawings must be clouded.
Submit plans by electronic submittal (Document Upload Link or
https://www.cityoffederalway.com/node/4588)
Project Number: ___ ___ - ___ ___ ___ ___ ___ ___ - ___ ___ - ___ ___
Project Name: _______________________________________________ ____
Project Address: _ _____________________________________________________
Project Contact: ________________________________________________________
Phone: _________________________ Email: ________________________________
RESUBMITTED ITEMS:
# of Copies DETAILED Description of Item
Resubmittal Requested by: _______________________ Letter Dated: _____/_____/_____
(Staff Member)
Please note, the application fee collected at initial submittal covers the initial review and one resubmittal only. The City is
charging applicants for any additional staff time necessary to complete each review following the first resubmittal.
OFFICE USE ONLY
RESUB #: _______ Distribution Date:___________ By:___________
Dept/Div Name #Description
Building
Planning
PW
Fire
Other
DEPARTMENT OF COMMUNITY DEVELOPMENT
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
www.cityoffederalway.com