17-105489-Response to Technical Review Comments-02.16.23
February 10, 2023 Job No. 1886-001-016-0016
Ms. Lisa Klein, AICP
Contract Planner for City of Federal Way
City of Federal Way
33325 8th Avenue S
Federal Way, WA 98003-6325
RE: City Project Nos. - 17-105489-UP, 17-105490-SE & 21-104771-SH
AHBL No. 2200534.30
Woodbridge Business Park - 327XX Weyerhaeuser Way South, Federal Way
TECHNICAL REVIEW COMMENTS – Response Letter
Dear Ms. Klein:
This letter is written on behalf of Federal Way Campus, LLC to provide detailed responses to
the consolidated comment letter provided by AHBL dated August 16, 2022, and the Critical
Areas Addendum comments from ESA dated July 20, 2022. In an effort to provide concise and
direct responses, we have copied the abbreviated portion of the review comments that need to
be addressed prior to issuance of a SEPA threshold determination and/or the land use
application staff report below in italics and added our responses in bold.
Comments from AHBL letter dated August 16, 2022:
1. Please ensure consistent information is communicated throughout the plan set and
associated application materials.
We strive to ensure consistency throughout all submitted materials; however, please
recognize that a vast amount of data has been required and some materials change
over time in response to jurisdictional comments.
Parking
2a. 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.
The project is providing the code-required minimum parking quantities for each
building (within 800’ of each building). This information has been added to the plan
set (sheet CV-01). A parking exhibit showing how parking is allocated to each building
is also included in the resubmittal.
Ms. Lisa Klein
February 10, 2023
Page 2
Please note that there are 225 parking spaces within 187’ of the rear of the WTC.
These are shown in order to meet the code-required minimum parking for the overall
development and the WTC. Depending on the future parking needs of users within the
WTC, this area may instead be used for loading or building access, which is currently
the case. We recognize that a future parking modification is required in order not to
provide these spaces. Historically, users within the WTC do not require the codified
minimum parking quantity and a parking modification will be submitted under separate
cover at such time as it may be necessary.
View Impacts to Historic District
3a. Please submit any other cultural or historic information that has not been provided to
date for the City consultant’s review.
We are including the following reports, which have all been submitted to the Corps
under the Section 106 process:
Tavel, January, and Corey Lentz. 2023. Federal Way Woodbridge Business Park
Project: Historic Resources Effects Assessment, Federal Way, Washington.
January 3. Report prepared for Federal Way BP LLC, Los Angeles. Report
prepared by ICF, Seattle. On file, Federal Way BP LLC, Los Angeles.
Ferris, Jennifer. 2022. Archaeology Review of Woodbridge Business Park
Project. December 23. Report prepared for Federal Way BP LLC, Los Angeles.
Report prepared by HDR, Inc., Bellevue. On file, Federal Way BP LLC, Los
Angeles.
Sadlier, Michelle, Becky Strickler, and Jennifer Ferris. 2020. Built Environment
Survey of the Former Weyerhaeuser Corporate Headquarters Campus, Federal
Way, Washington. July 29. Cardno, Seattle, Washington. Prepared for Federal
Way Campus, LLC, Los Angeles, California. On file, Federal Way BP, LLC, Los
Angeles.
Stipe, Frank. 2017. Greenline Business Park Property Cultural Resource Survey.
Tetra Tech, Bothell. Prepared for Talasaea Resource & Environmental Planning,
Woodinville. On file, Federal Way BP, LLC, Los Angeles.
3b. Explain the status of the Memorandum of Agreement (MOA) with DAHP. Provide copy
of the draft or final MOA.
The US Army Corps of Engineers does not have jurisdiction over the wetlands on the
Building A and Building B sites; therefore, there is no draft or final MOU with DAHP.
3c. Informative comment, no response required.
4a. 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.
The Visual Impact Exhibit and Visual Impact Study letter from Nelson are included in
the resubmittal package. The study is a visibility assessment of the proposed Business
Ms. Lisa Klein
February 10, 2023
Page 3
Park buildings 1, 2, and 3 from adjacent roads and the Weyerhaeuser Headquarters
building based on several data points. Specifically, the assessment is based on a 3D
model that includes existing grades, proposed building slabs located in plan and
elevation height based on the civil engineering drawings, building elevations based on
architectural drawings, and tree heights based on LiDAR tree mapping.
In combining all this information, we were able to determine what extents of the
buildings would be visible from adjacent property, taking into account anticipated tree
buffer enhancement. The view from the Weyerhaeuser headquarters building is taken
from the 5th level on the far west end of the building because this is the vantage point
that provides the most direct, unobstructed view toward the Business Park property.
As can be seen in the visibility study, the Business Park buildings will be hidden by the
forested buffers and existing vegetation.
4b. 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.
Please see callouts on sheets LA-01 and LA-02 depicting the minimum 50’-wide tree
buffer along the meadow. Also note the large wetland and buffers that will remain
undisturbed that exist southwest of Building 1, directly west of the WTC and northwest
of Building 3.
4c. 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.
Please provide the basis for the request to restore the rear elevation to like-new
condition. Since the term “like-new” is subjective and undefined, it may be impossible
to determine the exact extent of the requested renovations, especially since the
building is approximately 44-years old and this elevation has been subject to
modifications over the years.
Please note that this elevation will be screened from public view from the meadow and
from Interstate 5 by over 250’ of existing forested vegetation (50’ of tree buffer along
the meadow plus over 200’ of wetlands and buffers).
5. Informative comment, no response required.
Building Elevations and Design Brief
6a. 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 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.
Staff’s recommendations rely on the intent and purpose clauses of the CZA. In the
Examiner’s Ruling on Motion for Partial Dismissal dated May 26, 2019, in the seventh
section of the Conclusions of Law, the Examiner rules that “Purpose Clauses Serve as
Ms. Lisa Klein
February 10, 2023
Page 4
Interpretive Guides Only.” The Examiner goes on to state that “Zoning district purpose
clauses do not serve as development restrictions on the project site.” If this were the
case, all buildings, including the two project houses, the recreation center and all
outbuildings would have had to comply, which they do not.
The perimeter buffers surrounding the site will provide visual screening of the proposed
buildings; therefore, no elevation changes are proposed.
Managed Forest Buffer, Landscape Plans, and Tree Retention
7. Informative comment, no response required.
8. 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.
The landscape plans have been revised to show groundcover or shrubs over the
landscape islands within the vault perimeter.
9. 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.
Outdoor storage is proposed to continue in the rear (west side) of the WTC. Additional,
supplemental 10' tall trees, shrubs and groundcover are proposed outside of wetland
buffers on the west side of the WTC and proposed Building 3, and on the south side of
Building 3 adjacent to Detention Pond 4. This additional planting constitutes Type I
level landscaping. The north side of the WTC is directly adjacent to the loading docks
of proposed Building 1; therefore, no Type 1 landscaping is required there.
10. Provide the number of parking spaces per building and the parking lot landscape area
per building.
Please see the Process IV cover sheet for a table of parking spaces provided and
required per building, along with the separate Parking Exhibit included in this submittal.
Please also see sheet LS-03 for the parking lot landscape area calculations.
Shoreline Substantial Development Permit Review Comments
11a. 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.
An updated survey of the OHWM of North Lake shows that all proposed improvements
fall outside of the 200’ Shoreline Jurisdiction; therefore, the Shoreline Permit is no
longer necessary. Please refer to sheet EX-02 and the Shoreline Jurisdictional Detail
exhibit provided with this submittal.
Ms. Lisa Klein
February 10, 2023
Page 5
11b. 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.
The Shoreline Permit is no longer necessary.
11c. Provide new or revised Addendum that addresses the roadway improvements in the
shoreline and provides a no net loss analysis.
The Shoreline Permit is no longer necessary.
11d. 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.
The Shoreline Permit is no longer necessary.
11e. 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.
The Shoreline Permit is no longer necessary.
11f. Depict the 50-foot setback and the distance from the OHWM to the proposed roadway
improvements on the plans.
The Shoreline Permit is no longer necessary.
12. Review and address each comment in the enclosed May 20, 2022, review letter from
the City’s wetland consultant, ESA.
The Shoreline Permit is no longer necessary.
Wetland and Streams
13. Review and address each comment in the enclosed May 20, 2022, review letter from
the wetland consultant, ESA.
Please refer to the separate letter from Wet.Land, dated February 9, 2023 and
enclosed with this submittal.
SEPA Checklist
14. As described above 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.
Please see reports listed under comment #3a. above. No final agreements have been
negotiated with any jurisdictions at this time.
Ms. Lisa Klein
February 10, 2023
Page 6
15. Question A.9 : Add that King County needs to approve the fee-in-lieu mitigation plan.
King County does not approve ILF Plans in jurisdictions other than their own. For the
use of the King County ILF program, the ILF Program does not approve the ILF Plans.
The agencies with jurisdiction over the Project approve the ILF Plan which is then
provided to the ILF Program for final processing of payment. The SEPA checklist
question A.9. has been revised to reflect this information.
16. Revise the SEPA checklist cut/fill quantities.
The cut/fill quantities have been updated in the SEPA checklist to match the Process
IV plans.
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.
See CAR addendum and revised Mitigation Plan for a summary of the wetlands. The
wetlands that were omitted no longer occur within the Project or Study Area.
18. Informative comment, no response required.
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.
The Impervious Area Exhibit is for all parcels in the CP-1 zone, not including public
rights-of-way. The Business Park total impervious area is 59.76 acres, rounded on the
Impervious Area Exhibit to 59.8 acres. This onsite impervious area includes both
existing impervious and replaced impervious areas, which are also described on the
exhibit. The TIR has been revised to match this information as well as supplement
with new impervious area for frontage improvements and replaced impervious area for
pavement reconstruction in the right-of-way of Weyerhaeuser Way South.
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.
The Critical Areas Mitigation Plan Sheet WI.4 has been revised to remove the
construction impacts in this area.
21. Label what appears to be an easement in the northeast corner of Sheet ST-01.
Ms. Lisa Klein
February 10, 2023
Page 7
The 60’ gas line easement, 25’ managed forest buffer, and 106’ development
reservation areas have been labeled. The only other dashed line at the northeast
corner represents the wetland buffer for Wetland FB.
22. Informative comment, no response required.
23. Provide all wall heights on the grading plan.
The wall heights have been added to the grading plans.
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.
The TIR has been revised to reflect the site plan area of 97.66 acres (tax parcels
162104-9030, 162104-9013, and 162104-9056).
Cole Elliott – Public Works Development Services
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.
Figure 1.2 has been updated to reflect the Sphagnum Bog drainage basin.
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 review and approval. The modification
request form is available by contacting the Public Works Review Engineer.
Noted. A separate modification request will be made submitted for the proposed
underground vault. A copy of the Modification Request for Underground Vaults letter
has been included in the submittal.
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.
Ms. Lisa Klein
February 10, 2023
Page 8
The TIR has been revised to reflect the enhanced basic water quality treatment
requirements for new and replaced pollution generating impervious areas.
28. The City has now adopted the 2021 KCSWDM. All stormwater systems for the project
shall be designed per the requirements of that manual.
This comment has been noted and the stormwater report has been revised to
reference and address the requirements of the 2021 KCSWDM.
Sarady Long – Public Works Traffic Division – 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.
The project has been reduced in size and no longer includes tax parcel 228500-0010.
As such, the frontage on South 336th St is minimal, and the plans have been updated
to address this comment. Full frontage improvements and the necessary dedications
have been shown on Weyerhaeuser Way S and the roundabout at the intersection of
Weyerhaeuser Way South and South 336th St.
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 provided to ensure the
roundabouts on Weyerhaeuser Way South can accommodate the expected trucks
(WB-67).
Attachment A includes the turning path of a WB-67 truck at the S 336th Street and S
33rd Place roundabouts on Weyerhaeuser Way which shows that the turn paths can
be accommodated at both. No additional widening or channelization is necessary to
accommodate the WB-67 trucks. Please see the Response to City Technical Review
Comments Letter by TENW , dated December 9st, 2022
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. Coordinate with the City Center Access Study
team to determine the future alignment and intersection roundabout design at
Weyerhaeuser Way South.
Ms. Lisa Klein
February 10, 2023
Page 9
We have coordinated with the City Center Access team and have modified our plans
and the development reservation area to accommodate the proposed roundabouts and
freeway offramp with the preliminary design presented by the City.
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.
We have coordinated with the City Center Access team and there is no need to relocate
the northerly driveway or detention vault to accommodate the design presented by the
City.
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.
The proposed Woodbridge Business Park development will have four access points
into the project site from Weyerhaeuser Way South, which is an arterial roadway (City
of Federal Way Section K). Three access points have drive aisles that are 30 feet
wide, as allowed by code, but they flare out at the entrance to allow for truck turning
movements. The fourth access point will also have a drive aisle that is 30 feet wide
with a standard driveway approach for passenger vehicles, as required by code. A
street modification reflecting this design will be submitted under separate cover and a
copy of the letter is included with this resubmittal.
As shown on the attached AutoTurn Analysis completed by TENW on January 18,
2023, the radii curvature proposed at the three site access points with Weyerhaeuser
Way South are the minimum necessary to accommodate the anticipated vehicle types.
34. Adequate throat length should be provided at access driveways to minimize traffic
backing up onto through street.
WSDOT minimum right turn pocket storage has been provided and will accommodate
a truck as it exits the street into the site. There is not expected to be truck back-ups
entering the site.
Concurrent truck movements have been confirmed for trucks entering/exiting the
driveways. See AutoTURN memo for more info.
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
Ms. Lisa Klein
February 10, 2023
Page 10
vehicles that may be reasonably expected to use the driveway, as determined by the
Public Works Director.
The AutoTurn Memo has been revised and driveway widths are called out. Please see
the TENW Auto Turn Analysis, dated November 30th, 2022, for additional details.
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.
Street lighting for the Weyerhaeuser Way South frontage improvements is shown on
Sheets ST-01 and ST-02 of the Process IV plan set.
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.
Southbound right-turn lanes are being proposed for the project at the 2nd and 4th
driveways (heading southbound). While the future traffic volumes at the 1st driveway
may suggest a right-turn lane be considered, the project is not proposing to construct
one due to the proximity to the City’s future roundabout at the new Weyerhaeuser Way
S/S 324th Street intersection. The 3rd driveway would be a lower traffic volume
driveway and a right-turn lane is not proposed. See Memorandum from TENW dated
December 19, 2022.
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.
The 25-foot-wide managed forest buffer is fully contained within the 106’ development
reservation. Please refer to the Department of Community Development Code
Interpretation #18-01 for further details.
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.
All study intersections are under City of Federal Way jurisdiction with exception to the
S 320th Street/I-5 and Weyerhaeuser Way S/SR-18 ramp intersections. The LOS
standard for City of Federal Way intersections is LOS D and a maximum v/c ratio of
1.2 for signalized intersections and 1.0 for all movements at unsignalized intersections.
The LOS standard for WSDOT intersections is LOS D. WSDOT also utilizes different
LOS methodologies for evaluation of LOS compared to City of Federal Way. See
Memorandum from TENW dated December 9, 2022.
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.
Ms. Lisa Klein
February 10, 2023
Page 11
Comment noted. No changes to the analysis were made. See Memorandum from
TENW dated December 9, 2022.
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.
The analysis presented in the TIA is based on the current City adopted standards,
which is standard practice and consistent with the analysis completed for Buildings A
and B. No changes to the analysis were made. See Memorandum from TENW dated
December 9, 2022.
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.
The trip generation estimates shown in Appendix D were correct and the values shown
in Table 4 were incorrect. The analysis presented in the TIA was based on the trip
generation estimates included in Appendix D. Revisions to Table 4 have been made
and are shown in Attachment B. Therefore, no changes were made to the analysis.
See Memorandum from TENW dated December 9, 2022.
43. Provide a separate trip assignment figure showing only the expected truck travel route.
A truck travel route figure is included in Attachment C. Please see the Response to
City Technical Review Comments by TENW dated December 9, 2022 for additional
details.
44. The proposed pipeline trips from surrounding developments are acceptable. However,
the TIA should provide a separate figure of these trips.
Figures showing the pipeline trips from surrounding developments are included in
Attachment D. See Memorandum from TENW dated December 9, 2022.
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.
The horizon year shown in the LOS printout for Saturday was a typo error. The
analysis presented in the TIA is based on a future buildout of 2023 and the
corresponding LOS printout labels have been corrected and are included in
Attachment E. No changes to the analysis or conclusions were made. See
Memorandum from TENW dated December 9, 2022.
46. Page 7 – Transit Service: Coordinate with King County Metro and Pierce Transit for any
onsite or offsite transit related improvements requirement.
Ms. Lisa Klein
February 10, 2023
Page 12
Comment noted. Future coordination efforts are anticipated with King County Metro
and Pierce Transit to consider potential transit improvements along the site frontage.
Please see the Response to City Technical Review Comments by TENW dated
December 9, 2022 for additional details.
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.
Comment noted. See Memorandum from TENW dated December 9, 2022.
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.
Comment noted. See Memorandum from TENW dated December 9, 2022.
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.
An updated pavement analysis was conducted by GeoEngineers, Inc (dated Jan 12,
2023) and is included with this resubmittal. Process IV plans have also been revised
to note the pavement reconstruction requested in this comment.
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.
The results shown in Appendix C of the TIA were correct. An updated Table 6 is shown
in Attachment F. See Memorandum from TENW dated December 9, 2022.
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.
The S 320th Street/Weyerhaeuser Way S intersection (#6) is a City of Federal Way
intersection. This intersection is anticipated to operate at acceptable levels (LOS D or
better, v/c < 1.2) per City standards. Therefore, no mitigation is required. See
Memorandum from TENW dated December 9, 2022.
Ms. Lisa Klein
February 10, 2023
Page 13
52. Per code, the proposed site access driveway locations meet the minimum spacing of
150 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.
Comment noted. The location and final design of the northern site access driveway is
anticipated to be reviewed and determined as the design of the future City roundabout
progresses.
We understand that the City Center Access Plan is currently at the ±10% design stage.
The enclosed plan does not conflict with lane storage, tapers or queues. See
Memorandum from TENW dated December 9, 2022.
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.
Southbound right-turn lanes are proposed at the 2nd and 4th driveways (heading
southbound). While the future traffic volumes at the 1st driveway may suggest a right-
turn lane be considered, the project is not proposing to construct one due to the
proximity to the City’s future roundabout at the new Weyerhaeuser Way S/S 324th
Street intersection. Site access #3 would be a lower volume driveway and no right-
turn lane is proposed. See Memorandum from TENW dated December 9, 2022.
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.
Based on the traffic scoping sheet provided by the City, the Weyerhaeuser Way S
roadway capacity assessment has been conducted based on the anticipated future
buildout year for Woodbridge Business Park. Analysis of future buildout year is
consistent with roadway capacity assessment completed by other projects in the area.
Additionally, the analysis of future buildout year is consistent with all prior versions of
the TIA. Based on comments from the City on prior versions of the TIA, the City
concurred with the analysis presented (future buildout year). See Memorandum from
TENW dated December 9, 2022.
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.
Ms. Lisa Klein
February 10, 2023
Page 14
The LOS standard for WSDOT intersections is LOS D. Each of the S 320th Street/I-5
and Weyerhaeuser Way S/SR-18 ramp signalized intersections are anticipated to
operate at LOS D or better in 2023 with the proposed project, meeting WSDOT
standards. See Memorandum from TENW dated December 9, 2022.
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.
Comment noted. This section of the SEPA checklist has been updated. See
Memorandum from TENW dated December 9, 2022, and the updated SEPA Checklist
dated February 2023.
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.
Comment noted. This section of the SEPA checklist has been updated. See
Memorandum from TENW dated December 9, 2022, and the updated SEPA Checklist
dated February 2023.
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.
Comment noted. This section of the SEPA checklist has been updated. See
Memorandum from TENW dated December 9, 2022, and the updated SEPA Checklist
dated February 2023.
59. Transportation 14(g): Revise this section to include southbound right-turn lane at the
three driveway locations.
Comment noted. This section of the SEPA checklist has been updated. See
Memorandum from TENW dated December 9, 2022, and the updated SEPA Checklist
dated February 2023.
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.
These documents have been used for updated pavement analysis prepared by
GeoEngineers, Inc. (dated Jan. 12, 2023) and included with this resubmittal.
Ms. Lisa Klein
February 10, 2023
Page 15
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.
As noted above, the pavement analysis is using AASHTO 1993. This guidance states
in section 1.4.1 Evaluation of Traffic: “The equivalent loads derived from many traffic
prediction procedures represent the totals for all lanes for both directions of travel. This
traffic must be distributed by direction and by lanes for design purposes. Directional
distribution is usually made by assigning 50-percent of the traffic to each direction,
unless available measured traffic data warrant some other distribution.” Using the full
two-way AADT for design appears inconsistent with AASHTO 93 methods. We
received traffic data that divides the traffic by each direction, and we used that data
per AASHTO. Design ESALs do not 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.
The Pavement Analysis Report prepared by GeoEngineers, Inc has revised its
analysis done previously with updated 2019 traffic data provided by TENW.
63. Specify if the daily truck load in the report includes truck trips generated by
development south of the site (Warehouses A and B).
The pavement analysis report prepared by GeoEngineers, Inc includes the expected
truckloads and is based on the existing daily traffic volume with an additional 293 truck
and trailers per day traveling north of the Woodbridge Business Park (47 northbound
and 246 southbound) and an additional 261 truck and trailers per day traveling south
of the Woodbridge Business Park (31 northbound and 230 southbound).
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.
This comment has been noted and the developer will comply as required.
Critical Areas Addendum Review Comments and Recommendations- ESA
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.
See CAR addendum and revised Mitigation Plan for a summary of the wetlands. The
wetlands that were omitted no longer occur within the Project or Study Area.
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
Ms. Lisa Klein
February 10, 2023
Page 16
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 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.
The tables have been updated with accurate numbers based on the new site plan with
the new values carried throughout these revised documents. The updated direct and
indirect impacts to wetlands are as follows in Table 1. The ILF Plan has also been
updated accordingly to reflect the below impact areas for a total number of credits to
be purchased from the ILF Program adjusted to 20.96 units. Please see the Revised
Critical Area Report Addendum dated February 9th, 2023, Table 1. Summary of Direct
& Indirect Wetland Impacts for more details.
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.
Both the CAR addendum and Mitigation Plan have been revised to be consistent and
reflect the most recent site plan. Additional plan sheets have been added to the
Mitigation Plan that show the wetland and buffer impacts and averaging wetland by
wetland for a clear and concise accounting of impacts.
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.
The Mitigation Plan has been revised to reflect the new Site Plan. All impacts have
been recalculated based on the new Site Plan and are reflected in both the new CAR
addendum and the revised Mitigation Plan. Additional plan sheets have been added
to the Mitigation Plan that show the wetland and buffer impacts and averaging wetland
by wetland for a clear and concise accounting of impacts.
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
Ms. Lisa Klein
February 10, 2023
Page 17
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).
Noted. Where grading within buffers is required, buffers have either been modified
through identifying areas of indirect impacts where impacts exceed the 25% allowable
reduction from the standard buffer, or through buffer averaging. See the Addendum
for more details.
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.
Noted. The buffer impacts for trail restoration are discussed in the revised CAR
Addendum in more detail.
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.
The swale has been shortened so that it no longer extends into the minimum wetland
buffer. There is still a small encroachment but only into the outer 25% of the wetland
buffer that has been replaced elsewhere adjacent to the remaining wetland buffer. See
CAR Addendum for detailed discussion.
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.
Impacts to Wetland AV have been modified with the new site plan. There are several
impact areas of note that are discussed in more detail in the revised CAR Addendum.
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;
(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
Ms. Lisa Klein
February 10, 2023
Page 18
(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.
Pure buffer reduction with enhancement is not proposed for this Project. Where buffers
are reduced, they are either reduced beyond the allowable reduction per code and
mitigated for through the purchase of ILF credits, or buffer averaging has been used to
give back at least an equal amount of buffer for no net loss of buffer area. See the
revised CAR Addendum for the updated discussion on buffer modifications proposed
for this Project.
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.
The USACE allows buffers less than the standard for the calculations for indirect
wetland impacts where buffer averaging is applied to ensure no net loss of buffer
areas. Based on that guidance, indirect impacts were only calculated for ILF credit
purchase where buffer reductions were below the 25% reduction allowable by code.
Where buffer averaging could be applied, it was applied for no net loss of buffer area
before and after the Project proposed.
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.
Noted. No further response.
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.
Noted. No further response.
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.
The OHWM of North Lake was redelineated on November 10, 2022 and subsequently
reviewed by ESA Staff as the 3rd party reviewer for the City. A discussion of the
findings and updated photos are included in the revised CAR Addendum.
Ms. Lisa Klein
February 10, 2023
Page 19
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.
Noted. The 200-foot shoreline management zone line has been adjusted based on
the redelineation of the North Lake OHWM and updated on all relevant figures and
plan sheets.
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.
The redelineation of the North Lake OHWM resulted in an adjustment to the 200-foot
shoreline management zone. The proposed road improvements are no longer within
the shoreline management zone.
If there are any questions or a need for further clarification, please feel free to contact me at
(253) 838-6113 and I would be happy to discuss them with you.
Sincerely,
ESM CONSULTING ENGINEERS, LLC
ERIC G. LaBRIE, A.I.C.P.
President
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