The URL can be used to link to this page

17-105489CITY OF Federal Way Centered on Opportunity Mr. Eric LaBrie ESM Consulting Engineers 33400 8 h Avenue South, Suite 205 Federal Way, WA 98003 eric.labrie@esmcivil.com FtLE, CITY HALL 33325 8th Avenue South Federal Way, WA 98003-6325 (253) 835-7000 www. cityoffederalway.. com Jim Ferrell, Mayor May 14, 2018 Re: File Nos. 17-105489-00-UP & 17-105490-00-SE; NOTICE OF COMPLETE APPLICATION Greenline Business Park, 32901 Weyerhaeuser Way South, Federal Way Dear Mr. LaBrie: The Department of Community Development has conducted a cursory review of information you submitted to the city on April 30, 2018, in order to determine if the application is complete for the proposed Greenline Business Park Use Process IV and State Environmental Policy Act (SEPA) reviews. Your submittal is in response to the City's December 12, 2017 Notice of Incomplete Application. Your proposed project includes construction of 3 buildings totaling approximately 1,060,000 square feet and associated site improvements. NOTICE OF COMPLETE APPLICATION Please consider this correspondence a formal Letter of Complete Application. Pursuant to Federal Way Revised Code (FWRC) 19.15.045 and 14.10.020, the application is deemed complete as of the date of this letter. The complete application determination is based on a review of your submittal relative to those requirements as set forth in FWRC 19.15.040 and 14.10.020. The submittal requirements are not intended to determine if an application conforms to the City of Federal Way codes; they are used only to determine if all required materials have been submitted. CLOSING Formal processing and review of your application will now begin. Technical review comments will follow at a later date. A Notice of Application will be posted on site, published in the Federal Way Mirror, posted on the city's official notice boards, and mailed to the persons within 300 feet of each boundary of the subject property within 14 days of this letter. Any questions concerning your applications may be directed to me at 253-835-2652, orjim.barris@cityoffederalway.com. Sincerely, im Harris Planner c: Tom Messmer, tmessmer@industrialrealtygroup.com Brian Davis, Director of Community Development Kevin Peterson, Engineering Plans Reviewer Sarady Long, Senior Transportation Engineer Brian Asbury, Lakehaven Utility District, via email Dac. LD. 77725 17-105489-00-UP 41k CITY OF Federal Way NOTICE OF MASTER LAND USE APPLICATION Project Name: Greenline Business Park Project Description: Construction of three buildings totaling approximately 1,068,000 square feet, five new stormwater ponds, revisions to existing parking lot and addition of approximately 806 parking stalls, filling approximately 13,500 square feet of wetlands, roadway improvements, and associated site improvements on 146 acres. Applicant: Federal Way Campus, LLC, 11100 Santa Monica Blvd, Suite 850, Los Angeles, CA 90025 Agent: ESM Consulting Engineers, LLC, 33400 8d' Avenue South, Suite 205, Federal Way, WA 98003 Project Location: Approximately 329XX Weyerhaeuser Way South, Federal Way, WA, King County Parcels 162104-9056, -9013, -9030 and152104-9178 Date of Application: November 14, 2017 Date Determined Complete: May 14, 2018 Date of Notice of Application: May 18, 2018 Public Comments Due: June 4, 2018 Requested Decision and Other Permits Included with this Application: The applicant requests a Use Process IV Hearing Examiner decision (File #17-105489-UP) pursuant to Federal Way Revised Code (FWRC) Chapter 19.70. Additional permits and/or approvals in conjunction with the Use Process IV decision include a threshold determination pursuant to State Environmental Policy Act (SEPA) Rules WAC 197-11 (File #17- 105490-SE), Transportation Concurrency (File #17-105491-CN), Boundary Line Adjustment (File #18- 100123-SU), and Forest Practices Class IV General Permit. Environmental Documents: Environmental Checklist, Wetland Report and Conceptual Mitigation Plan, Visual Impact Exhibit, Geotechnical Report, Transportation Impact Analysis, Pavement Analysis, Parking Study, Stormwater Technical Information Report, Air Quality Report, Environmental Noise Report, Cultural Resources Study, Evaluation of Trees. Development Regulations to Be Used for Project Mitigation: Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement and applicable 1994 development codes, including Federal Way City Code (FWCC) Chapter 18, "Environmental Protection"; Chapter 20, "Subdivisions"; Chapter 21, "Surface and Stormwater Management"; and Chapter 22, "Zoning." Consistency with Applicable City Plans and Regulations: The project will be reviewed for consistency with all applicable codes and regulations including the Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement, which vests the project to regulations in place in 1994; FWRC 19.145; 2016 King County Surface Water Design Manual as amended by the City of Federal Way; and the Public Works Department Development Standards. Any procedural requirements must meet today's codes (FWRC Title 19). Public Comment & Appeals: The official project file is available for public review at the Community Development Department (City Hall, 2°d Floor, 33325 8`h Avenue South, Federal Way, WA 98003). The initial public comment and notice period ends June 4, 2018. However, any person may submit written comments to the Hearing Examiner by delivering these comments to the Department of Community Development prior to the public hearing date (which has yet to be determined) or by giving these directly to the Hearing Examiner at the public hearing. Only the applicant, persons who submit written or oral comments to the Hearing Examiner, or persons who specifically request a copy of the written decision may appeal the Hearing Examiner's decision. Details of the appeal procedures for the requested land use decision will be included with the written decision. Comments sent by email should be directed to plann i n g.-7c ityoffedera I way. coin . Availability of File and Environmental Documents: The official project file and referenced environmental documents are available for public review during normal business hours at the Community Development Department (address above) or on the City's FTP site at ftp://ftp.cityo Efederalway.corn/Outbox/GreenlineSubmittalDocuments/BusinessPark Staff Contact: Planner Jim Harris, 253-835-2652, jim.harris@cityoffederalway.com Printed in the Federal Way Mirror May 18, 2018. B Jim Harris From: LeSmith, Rose <Rose.LeSmith@kingcounty.gov> Sent: Friday, November 09, 2018 12:22 PM To: Ping Inquiry; Stacey Welsh Cc: Taniguchi, Harold; Taylor, John; Brown, Laurie; Brater, Rick; Harvey, Ruth Subject: City of Federal Way SEPA Determination MDNS Greenline Warehouse'A' (File No:16-102948-SE) Importance: High November 9, 2018 TO: Stacey Welsh, Senior Planner, Federal Way FR: Rose LeSmith, P.E., County Traffic Engineer, King County Road Services Division RE: City of Federal Way SEPA Determination MDNS Greenling Warehouse `A' File No:16-102948-SE Thank you for the opportunity to comment on Federal Way's Mitigated Determination of Nonsignificance (MDNS) for the proposed Greenline Warehouse 'A' Project (File No:16-102948-SE). The proposed project, reviewed through this SEPA action, will result in the construction of a 45-foot tall, 225,950 square foot warehouse with 287 parking spaces. The proposed Greenline Warehouse 'A' is one of five significantly -sized warehouses proposed to be built on the former Weyerhaeuser site. Cumulatively, these five warehouses will result in over 1.5 million square feet of industrial warehouse space, yet the city has yet to complete a SEPA review of the entire five warehouse development project. It appears that the Greenline Warehouse 'A' project level SEPA determination is an incremental project -level approach to SEPA compliance and is insufficient to address anticipated increases to traffic volumes and congestion on already congested local, regional and state roads. King County Road Services Division reviewed the Greenline Warehouse `A' threshold determination package and has concerns regarding the MDNS, given the limited scope of its Traffic Impact Analysis (TIA), which was limited to city intersections, ingress/egress from the property, pavement condition of Weyerhaeuser Way South and the two nearby WSDOT interchanges. The TIA did not assess the proposed development's contribution of additional traffic volumes to already congested local and state roads. We concur with the City of Federal Way's findings that the SEPA threshold determination's traffic study does not demonstrate how the applicant will prevent the alternative truck route (1-5/South 320th Street interchange, South 336th Street and Weyerhaeuser Way South) from being utilized. We also concur that the applicant has not demonstrated mitigation of additional truck traffic onto the non -designated truck routes mentioned above. King County is also concerned for the potential impacts of increased congestion in the following locations: the I-5/South 320th Street interchange, South 320`h Street from Weyerhaeuser Way South to 1-5, and east of the South 320th Street and Military Road South intersection. Increased traffic volumes and congestion along South 320th Street and at the I-5/South 320th Street interchange could result in drivers seeking alternate routes to 1-5, such as to the route north on Military Road South to South 272"d Street to the I-5/South 272"d Street interchange. The TIA did not address these scenarios. Please accept this email communication as a formal comment regarding Federal Way's threshold determination. The project scale MDNS associated with the proposed Greenline Warehouse 'A' Project does not sufficiently address anticipated traffic impacts to the overall roadway system surrounding the proposed development. King County requests that Federal Way conduct additional traffic evaluation to better understand and address these anticipated impacts and recommend appropriately scaled mitigation measures. King County also requests that the five warehouses proposed to be built on the former Weyerhaeuser property, be reviewed together under SEPA, to ensure that cumulative traffic volume and congestion impacts to the regional road network are understood and appropriately mitigated. We look forward to working with you to scope out an expanded traffic impact analysis that produces mitigation measures commensurate with the scope of this proposed warehouse development project. ram. Washington State Department of Transportation November 9, 2018 Stacey Welsh, Senior Planner City of Federal Way 33325 8th Avenue South Federal Way, WA 98003-6325 Subject: Greenline Warehouse "A" MDNS File No. 16-102948-SE Dear Ms. Welsh: Northwest Region Sno-King Local Agency and Development Services 15700 Dayton Ave. N P.O. Box 330310 Seattle, WA 98133 This letter is in response to the Greenline Warehouse "A" MDNS that we received from the City. The proposed project includes the development of up to 225,950 sq ft of warehouse building area on a currently vacant site. The project site is located between I-5 and Weyerhaeuser Way S, north of SR-18. Vehicle access is proposed at three locations; two via the existing loop road that connects to Weyerhaeuser Way S to the north and the other along Weyerhaeuser Way S via a new driveway aligned with S 341 st Street, which is a private drive. The driveways on the loop road will serve passenger vehicles, and the access on Weyerhaeuser Way S will be limited to trucks only. Our comments are as follows. 1. There are four project proposals within the Federal Way campus (former Weyerhaeuser campus): Warehouse A, Warehouse B, Davita, and Greenline. The traffic impact analysis (TIA) for Warehouses A and B incorporated new trips generated by both warehouses but did not include traffic volume generated by the Davita and Greenline proposals. The four projects must be analyzed together. Separate TIAs have been submitted for the four projects, so it is assumed the projects will be developed within a similar timeframe. The four projects are within the same campus, so the cumulative traffic generated will have an impact on the I-5 and SR 18 ramp terminal intersections adjacent to the campus. The four project proposals must be analyzed together to fully access the direct, indirect, and cumulative impacts of all four developments to WSDOT's facilities and their function. 2. In the AM peak hour, Warehouse A is anticipated to add 30 new trips (22 non - truck, 10 truck) to the intersection of westbound SR 18 at Weyerhaeuser Way S. Warehouse B is anticipated to add an additional 31 new trips (22 non -truck, 9 truck) to the saine intersection. Both of these projects independently exceed the vehicular trip threshold in the Developer Services Manual for determining whether a highway improvement should be requested. Northwest Region .7 Washington State Sno-King Local Agency and Development Services Department of Transportation 15700 Dayton Ave. N P.O. Box 330310 Seattle, WA 98133 From the TIA, a Synchro analysis of the AM peak hour westbound off -ramp for 2020 with project calculated a 95th percentile queue length of 142 feet. This exceeds the available right turn storage of approximately 100 feet. The percentage of time the storage would be blocked was calculated to be 28%. The analysis was conducted with a heavy vehicle percentage of 5% for the westbound off -ramp. 4. Additional right -turn storage of the westbound SR 18 off -ramp should be included as part of the mitigation for the proposed projects. An analysis that incorporated the additional projects would result in even more trips being assigned to the intersection. The increased number of trucks, plus the added vehicle length and reduced acceleration compared to passenger vehicles, will result in a greater percentage of time where the right -turn storage is exceeded. Exceeding the right -turn storage will block vehicle access to the left -turn lane, adding to the overall queue length. 5. The right -turn storage should be extended to 300 feet to mitigate for the impact to the westbound off -ramp. We are still reviewing the hydraulics report for this proposed development for its possible impact to SR 18 right of way and drainage system. We expect to send our comments on the hydraulics report to the City by November 27, 2018. If you have any questions or require additional information, please contact me at (206) 440-4710 or azooki-Q-Owsdot.wa. gov OR Felix Palisoc of my Local Agency and Development Services section at 206-440-4713 or via e-mail at palisof@wsdot.wa.gov Sincerely, wo�, 0 A^ 47 Ramin Pazooki Utilities and Developer Services Manager cc: Project File 5309 Shilshole Avenue, NW Suite 200 Seattle, WA 96107 206.789.9658 phone 206.789.9664 fax memorandum date November 30, 2018 to Jim Harris, City of Federal Way Department of Community Development wv,, m.esassoc.com from Jessica Redman and Ilon Logan subject Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park — FINAL At the request of the City of Federal Way (City), Environmental Science Associates (ESA) reviewed the Critical Areas Report and Conceptual Mitigation Plan — Greenline Business Park (dated October 27, 2017) prepared by Talasaea Consultants Inc. for the property at approximately 32901 Weyerhaeuser Way South in Federal Way, Washington. The 146-acre site is a combination of six parcels (King County Tax Parcel Numbers 1621049056, 1521049178, 1621049013, 1621049030, 2285000010, and 7978200420) currently owned by Federal Way Campus, LLC. This property was 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). The current application involves the construction of three new buildings that will provide approximately 1,068,000 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 five 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 Critical Areas Report and Conceptual Mitigation Plan — Greenline Business Park (dated October 27, 2017 and hereinafter referred to as the Report) and the Greenline Business Park Site Plan prepared by ESM Consulting Engineers (dated November 15, 2017). According to the documents, sixty-three wetlands and Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park — FINAL 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. Construction of the three buildings, stormwater facilities, and parking areas would impact 13,428 SF (0.31 acre) of wetlands. Four wetlands would be insufficiently buffered, and therefore are being considered indirectly impacted due to site development encroachments, resulting in an additional 4,912 SF (0.11 acre) of impact. The total 18,340 SF (0.42 acre) of direct and indirect wetland impacts would be mitigated for through 36,023 SF (0.82 acre) of wetland creation and 2,020 SF (0.05) of wetland enhancement. Wetland mitigation will meet and exceed ratios provided in FWRC 19.145.430(5) and will occur onsite in the vicinity of North Lake. In addition, 98,168 SF (2.3 acres) wetland buffer will be created around the area of wetland creation. No work will occur within the ordinary high water of the stream. However, the buffer on the east side of the stream would be reduced by 25 percent (from 100 feet to 75 feet) to accommodate the development. The total stream buffer reduction of 12,545 SF (0.29 acre) will be mitigated for by adding an additional 14,489 SF (0.33 acre) of stream buffer to the west side of the stream. In addition, 94,266 SF (2.2 acres) of the existing and proposed stream buffer will also be enhanced by removing invasive species and subsequently planting native trees and shrubs. Finally, an existing gravel path and berm that occur within the site will be removed and replanted with native trees and shrubs. This will account for approximately 35,689 SF (0.8 acre) of wetland and stream buffer enhancement. Review Comments and Recommendations As documented in our previous review of the Tech Center BLA (memo dated August 22, 2017), we agree with the wetland delineation boundaries, rating forms, and rating classifications established by Talasaea for wetlands occurring on the proposed project site. We generally agree with the conceptual mitigation plan and believe that the proposed mitigation site appears to be an adequate location for wetland creation. As the mitigation design progresses, we strongly recommend that the applicant perform further environmental investigations (groundwater level monitoring, soil analysis, etc.) at the proposed mitigation site to acquire the necessary data and information to inform mitigation feasibility and design. ■ Impacts to wetlands and wetland buffers should be minimized to the extent possible. It appears that in several areas, impacts could be further minimized, if not avoided, by minimal design and layout modifications while still resulting in a viable project. These areas include the following: o The proposed 820 SF of wetland fill in Wetland DE near the southwest corner of Building A; o The proposed filling of Wetland CG and the intrusion into the buffers of Wetland BA and PK, by the construction of Detention Pond 1; o The proposed intrusion of the eastern edge of Detention Pond 2 into the buffer of Wetland AV; e—The proposed intrusion -of the -southeast corner-of-Detention-Pond-3into-the-buffer of Wetland----- - - -- - - - BR; o The proposed intrusion of the western edge of Detention Pond 4 into the buffer of Wetland AH; o The proposed intrusion of the southwest corner of Building B into the buffer of Stream AC. Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park — FINAL We recommend the current design and layout, which results in the proposed impacts to wetlands and wetland buffers, is reevaluated for the areas described above and included in the mitigation sequencing process. • The City considers grading within a wetland buffer to be development, and therefore, 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. Additionally, the applicant shall demonstrate that temporary buffer impacts have been avoided or minimized to the extent possible, per FWRC 19.145.130. Temporary buffer impacts should also be included on the figures in the Report. • The wetland buffers on the Site Plan are inconsistent with the wetland buffers on the figures in the Report. For example, buffers for Wetlands BA-2, PK, and BB appear larger on the Site Plan than on Figure WI.1 in the Report. The Site Plan should be revised to reflect the buffers presented in the Report. • 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. Site Plan sheets should be revised to show post -development buffers and an existing conditions figure should be added to the Site Plan. • We recommend the ordinary high water mark (OHWM) of North Lake, within the project area, be delineated in order to accurately calculate and assess proposed impacts and activities in the shoreline. • If the proposed mitigation area or any other development is within 200 feet of the OHWM of North Lake, then shoreline review is triggered under FWRC 15.05 — Shoreline Management. We recommend Section 6 — Regulatory Review of the Report be revised to include all required permits. • Referring to Figure WI.3 of the Report, it appears that buffer creation is proposed in the existing buffer of Wetlands BB and BD North. This area cannot be considered as new buffer and the Report and figures should be revised to reflect any changes. • The areas shown as buffer creation and wetland creation areas on Figures W 1.3 and W3.1 of the Report are inconsistent. Areas of the mitigation area between the southern end of Wetland BB and the northern end of Wetland BD North are shown as wetland buffer creation on Figure W 1.3 and shown as emergent and scrub -shrub wetland creation, as well as buffer enhancement, on Figure W3.1. We recommend the figures be revised to show the correct proposed mitigation actions, consistently across all relevant Report figures. A 10-foot wide sewer easement runs through the proposed mitigation area. The sewer was installed approximately 18 years ago along with its corresponding impact mitigation area, which is apparently located north of the existing boat launch access. Future application materials should show this area of previous mitigation so that it is clear the area is not included within the current mitigation proposal. A portion of the buffer enhancement area on Figure W3.1 of the Report encroaches into the existing sewer easement. This area should be removed from the mitigation calculations. Some planting will be allowed within the terms of the easement agreement, but this area cannot be secured in perpetuity as mitigation for the Greenline Business Park wetland impacts. Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park — FINAL ■ Within the mitigation area, some portions of the wetland creation areas that are closest to the sewer easement, will have less than a 25-foot buffer. The wetland creation area should be relocated or reconfigured so that it can be adequately buffered. Jim Harris From: Ann Dower Sent: Thursday, October 18, 2018 7:34 AM To: Stacey Welsh; Doc Hansen; Jim Harris; Brian Davis; Cole Elliott; Kevin Peterson Cc: Paul Heller Subject: FW: PTI Preliminary Comments on JARPA Application NWS-2017-1077 Follow Up Flag: Follow up Flag Status: Flagged I have no idea why Paul Heller and I were sent this email, but the Planning Department was not. You all definitely need to see this. Ann Dower Senior Engineering Plans Reviewer 0110 o+ Federal Way Public Works Department 33325 8th Ave S, Federal Way, WA 98003 Desk:253.835.2732 1 Fx:253.835.2709 it #f deralwa .corn From: Char Naylor [mailto:Char.Naylor@PuyallupTribe-nsn.gov] Sent: Wednesday, October 17, 2018 3:37 PM To: 'Kristin.L.Mcdermott@usace.army.mil' Cc: Russ Ladley; Lisa Anderson; Paul Heller; Ann Dower Subject: PTI Preliminary Comments on JARPA Application NWS-2017-1077 Kristin: Below are our preliminary comments regarding NWS-2017-1077. The Tribe disagrees with the COE's treatment of NWS-2017-155 as being "separate and not interdependent" of NWS-2017-1077, as stated in the DARPA. While it may be true from a business perspective that the development of the Greenline Business Park may occur separately from the development of Greenline Buildings A and B, this is irrelevant as to the question of assessing impacts to the fishery, habitat, treaty fishing grounds and practices, hydrology and hydrologic function, water quality, cultural resources, and forest practices for proposals that encompass almost 2 million square feet of warehouses and 5 buildings on 6 contiguous parcels under common ownership. The adopted King County Stormwater Manual and Federal Way 2017 Addendum treats these 6 contiguous parcels as a single site by definition, for the purposes of managing and treating stormwater, so it alludes us as to why the COE views this project as being separate and not interdependent given the magnitude and potential impact this proposal will have on Hylebos Creek, situated in the Puyallup Tribe's Treaty Area. A sufficient and complete assessment of impacts and mitigation is not possible if you bifurcate these applications. By piece mealing these proposed developments and thus all the permit applications including the JARPAs (NWS-2017-155 and NWS-2017-1077), it isn't clear how the applicant has met the avoidance of impact requirement under Section 404. This is also a threshold question in which the City of Federal Way, as lead agency under SEPA, has also erred by not requiring the applicant to develop an EIS to analyze impacts, including cumulative effects, as well as scope and analyze site alternatives. The proposed warehouses and business park facilities will cover an approximate 45 acres, not counting associated impervious surfaces associated with parking. There is no information in either application regarding the flows associated with roof runoff or parking lot runoff that will ultimately be discharged downstream to the Hylebos system. The filling of wetlands in the Building A and Building B footprints and adjacent parking areas not only will permanently impact site wetland hydrology, but will also impact downstream flows to Hylebos Creek. ESA species, including steelhead, chinook and bull trout utilize the Hylebos system and the Tribe and others have spent millions of dollars to restore over the last several decades. Preservation of base flows to the creek and quality of runoff to the creek are of paramount importance to the tribe. As such, the Tribe requests infiltration of roof water on -site so that creek base flows are maintained and natural filtration of the solids and metals leaching off the roof are captured before discharging to the creek. In addition, we request construction of ponds similar to the WADOT Puyallup River bridge storm pond being constructed on the Reservation. This pond includes dual celled constructed wetlands and a polishing filter. We are happy to share the design with the COE and the applicant. A conceptual mitigation plan for the Business Park is available but it isn't clear if a mitigation plan that explains the basis of the proposed mitigation ratios, buffer averaging, and how the loss of functions and values are replaced with the creation of a wetland that is hydrated with stormwater. The Business Park Plan states that a final mitigation plan will be prepared and submitted once preliminary concurrence has been provided. Has concurrence been attained? It is unclear why the JARPA is based on a conceptual plan? The 2017 Talasea Critical Areas Report for the Business Park states that several different configurations were evaluated on -site to avoid wetland impacts, yet it isn't clear what other configurations were evaluated. Direct and indirect impacts associated with filling 9 of the 63 wetlands on -site isn't insignificant (not to mention the filling of wetlands associated with the Business Park), nor have the direct or indirect hydrologic impacts been evaluated. Has a master drainage plan been completed for this site? How have the requirements of the King County Stormwater Management Manual and the City of Federal Way's 2017 addendum been fulfilled? The figures attached to the JARPA application are very difficult to review as the plates are so bifurcated it is difficult to get an overall understanding of the project, impacts and proposed mitigation. The building footprints are not included on the figures. The storm ponds and outfalls don't appear to be included as well? It also isn't clear where the stream and wetland buffer enhancements are located and what the enhancements consist of. At your earlies convenience, it would be helpful to meet with you to discuss your thoughts and understanding of this project so that we can do a more thorough review. Thank you for the consideration. .Char Naylor Assistant Habitat Director/ Water Quality Program Manager phone 253-680-5520 cell 253-405-7815 e-mail char.navlor@DuvaIluptribe.com December 5, 2016 Mayor Jim Ferrell Federal Way City Council Members 33325 Eighth Ave. S. Federal Way, WA 98003 Dear Mayor Ferrell and City Council Members, I was CEO of Weyerhaeuser when we annexed the corporate campus to Federal Way in 1994.1 am writing to clarify the intent and proper interpretation of the pre -annexation zoning agreement that I signed on behaff of the company. We worked with the city staff to develop the specific zoning for the campus that would allow Weyerhaeuser's existing uses to continue without requiring special permits. Those uses included typical office activities, research and development facilities, and shipping and receiving facilities — but no true industrial uses or large warehouses_ We sought maximum flexibility for optimal development, but intended any additional construction to be limited and of superior- quality design and aesthetics. In drafting the concomitant agreement with the city, we also intended to retain the unique character of the campus. We sought to preserve its open spaces, forested areas, wildlife and trail system, as well as its natural features, including the rhododendron garden, bonsai collection and the shoreline of Borth take. As stewards of the concomitant agreement and the proper development of this historic campus, you should reject any proposal that doesn't meet the agreement's intent. I would like to propose that you provide some specific provisions regarding the purchasers of the property. The warehouses and seafood processing plant would generate substantial truck traffic which would present a potential safety hazard for the property and the people in the area. All of this would exceed the bounds of content in concomitant language and should not be approved. The proposal would destroy the unique situation of Federal Way — a large park -like structure adjacent to industrial property. Sincerely yours, r J;�n2zVl�V�Creig ht 3fi 1 — 130th Ave NE Bellevue WA 98005 ESA memorandum date April 11, 2018 5309 Shilshole Avenue, NW Suite 200 Seattle, WA 98107 206.789.9658 phone 206.789.9684 fax to Jim Harris, City of Federal Way Department of Community Development from Jessica Redman and Ilon Logan www.esassoc.com subject Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park - DRAFT At the request of the City of Federal Way (City), Environmental Science Associates (ESA) reviewed the Critical Areas Report and Conceptual Mitigation Plan — Greenline Business Park (dated October 27, 2017) prepared by Talasaea Consultants Inc. for the property at approximately 32901 Weyerhaeuser Way South in Federal Way, Washington. The 146-acre site is a combination. of six parcels (King County Tax Parcel Numbers 1621049056, 1521049178, 1621049013, 1621049030, 2285000010, and 7978200420) currently owned by Federal Way Campus, LLC. This property was 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). The current application involves the construction of three new buildings that will provide approximately 1,068,900 square feet (S.F) 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 five 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 Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park - DRAFT ESA reviewed the Critical Areas Report and Conceptual Mitigation Plan — Greenline Business Park (dated October 27, 2017 and hereinafter referred to as the Report) and the Greenline Business Park Site Plan prepared by ESM Consulting Engineers (dated November 15, 2017). According to the documents, sixty-three 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. Construction of the three buildings, stormwater facilities, and parking areas would impact 13,428 SF (0.31 acre) of wetlands. Four wetlands would be insufficiently buffered, and therefore are being considered indirectly impacted due to site development encroachments, resulting in an additional 4,912 SF (0.11 acre) of impact. The total 18,340 SF (0.42 acre) of direct and indirect wetland impacts would be mitigated for through 36,023 SF (0.82 acre) of wetland creation and 2,020 SF (0.05) of wetland enhancement. Wetland mitigation will meet and exceed ratios provided in F"NRC 19.145.430(5) and wiii occur onsite in tree vicinity of North Lake. In addition, 98,168 SF (2.3 acres) wetland buffer will be created around the area of wetland creation. No work will occur within the ordinary high water of the stream. However, the buffer on the east side of the stream would be reduced by 25% to 75-feet to accommodate the development. The total stream buffer reduction of 12,545 SF (0.29 acre) will be mitigated for by adding an additional 14,489 SF (0.33 acre) of stream buffer to the west side of the stream. 94,266 SF (2.2 acres) of the existing and proposed stream buffer will also be enhanced by removing invasive species and subsequently planting native trees and shrubs. Finally, a gravel path and berm that occur within the site will be removed and replanted with native trees'and shrubs. This will account for approximately 35,689 SF (0.8 acre) of wetland and stream buffer enhancement. Review Comments and Recommendations { `' As documented in our previous review of the Tech Center BLA (memo dated August 22, 2017), we agree with the wetland delineation boundaries, rating forms, and rating classifications established by Talasaea for wetlands occurring on the proposed project site. We generally agree with the conceptual mitigation plait and believe that the proposed mitigation site appears to be an adequate location for wetland creation. As the mitigation design progresses, we strongly recommend that the applicant perforhi further enviioiunental investigations (groundwater level monitoring, soil analysis, etc.) at the proposed mitigation site to acquire the necessary data and informationto inform mitigation feasibility and design. : Impacts to wetlands should be minimized to the exterit possible. It appears that the proposed 820 SF of wetland fill in Wetland DE may be avoided by minimal design alterations while still resulting in a viable project. We recommend impacts to this wetland are reevaluated. 9 • The City considers grading within a wetland buffer to be development, and therefore, the applicant should show that the proposed temporary buffer impacts due to site grading meet the criteria under FWRC 19.145.440—Developinent within wetland buffers. Temporary buffer impacts should also be mcluded on the gores m t-ie leport. Referring to Figure WI.3 of the Report, it appears that buffer creation is proposed in the existing buffer of Wetlands BB and BD North. This area should not be considered to be new buffer and the Report and figures should be revised to reflect any changes. 2 -4 Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park - DRAFT The wetland buffers on the Site Plan are inconsistent with the wetland buffers on the figures in the Report. For example, buffers for Wetlands BA-2, PK, and BB appear larger on the Site Plan than on Figure WI.1 in the Report. The Site Plan should be revised to reflect the buffers presented in the Report. 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. Site Plan sheets should be revised to show post -development buffers and anexisting conditions figure should be added to the Site Plan. 'M Washington State Department of Transportation November 9, 2018 Stacey Welsh, Senior Planner City of Federal Way 33325 8th Avenue South Federal Way, WA 98003-6325 Northwest Region Sno-King Local Agency and Development Services 15700 Dayton Ave. N �p P.O. Box 330310 Seattle, WA 98133 +z Subject: Greenline Warehouse "A" MDNS File No. 16-102948-SE Dear Ms. Welsh: This letter is in response to the Greenline Warehouse "A" MDNS that we received from the City. The proposed project includes the development of up to 225,950 sq ft of warehouse building area on a currently vacant site. The project site is located between I-5 and Weyerhaeuser Way S, north of SR-18. Vehicle access is proposed at three locations; two via the existing loop road that connects to Weyerhaeuser Way S to the north and the other along Weyerhaeuser Way S via a new driveway aligned with S 341 st Street, which is a private drive. The driveways on the loop road will serve passenger vehicles, and the access on Weyerhaeuser Way S will be limited to trucks only. Our comments are as follows. 1. There are four project proposals within the Federal Way campus (former Weyerhaeuser campus): Warehouse A, Warehouse B, Davita, and Greenline. The traffic impact analysis (TIA) for Warehouses A and B incorporated new trips generated by both warehouses but did not include traffic volume generated by the Davita and Greenline proposals. The four projects must be analyzed together. Separate TIAs have been submitted for the four projects, so it is assumed the projects will be developed within a similar timeframe. The four projects are within the same campus, so the cumulative traffic generated will have an impact on the 1-5 and SR 18 ramp terminal intersections adjacent to the campus. The four project proposals must be analyzed together to fully access the direct, indirect, and cumulative impacts of all four developments to WSDOT's facilities and their function. In the AM peak hour, Warehouse A is anticipated to add 30 new trips (22 non - truck, 10 truck) to the intersection of westbound SR 18 at Weyerhaeuser Way S. Warehouse B is anticipated to add an additional 31 new trips (22 non -truck, 9 truck) to the same intersection. Both of these projects independently exceed the vehicular trip threshold in the Developer Services Manual for determining whether a highway improvement should be requested. Northwest Region Alffik Washington State Sno-King Local Agency and Development Services Department of Transportation 15700 Dayton Ave. N FAFP.O. Box 330310 Seattle, WA 98133 From the T1A, a Synchro analysis of the AM peak hour westbound off -ramp for 2020 with project calculated a 95th percentile queue length of 142 feet. This exceeds the available right turn storage of approximately 100 feet. The percentage of time the storage would be blocked was calculated to be 28%. The analysis was conducted with a heavy vehicle percentage of 5% for the westbound off -ramp. 4. Additional right -turn storage of the westbound SR 18 off -ramp should be included as part of the mitigation for the proposed projects. An analysis that incorporated the additional projects would result in even more trips being assigned to the intersection. The increased number of trucks, plus the added vehicle length and reduced acceleration compared to passenger vehicles, will result in a greater percentage of time where the right -turn storage is exceeded. Exceeding the right -turn storage will block vehicle access to the left -turn lane, adding to the overall queue length. 5. The right -turn storage should be extended to 300 feet to mitigate for the impact to the westbound off -ramp. We are still reviewing the hydraulics report for this proposed development for its possible impact to SR 18 right of way and drainage system. We expect to send our comments on the hydraulics report to the C'.ity by November 27, 2018. If you have any questions or require additional information, please contact me at (206) 440-4710 or azookr a:wsdot.wa. Lov OR Felix Palisoc of my Local Agency and Development Services section at 206-440-4713 or via e-mail at palisof@wsdot.wa.gov Sincerely, Ramin Pazooki Utilities and Developer Services Manager cc: Project File dahpOL. - November 8, 2018 Ms. Stacey Welsh Senior Planner City of Federal Way PO Box 599 Black Diamond, WA 98010 Allyson Brooks Ph.D., Director State Historic Preservation Officer In future correspondence please refer to: Project Tracking Code: 2016-08-06001 Re: Greenline Warehouse "A" File No: 16-102948-SE (formerly Preferred Freezer/Orca Bay Seafoods Notice of Master Land use Applications Dear Ms. Welsh: The Washington State Department of Archaeology and Historic Preservation (DAHP) has reviewed the Notice of Mitigated Determination of Nonsignificance (MDNS) prepared by the City of Federal Way.This was received from a concerned citizens group. We understand that the applicant proposes construction of a 45 foot -tall, 225,950 square -foot general commodity warehouse with 287 parking spaces and associated site work, including wetland fill located on a parcel that is part of the former Weyerhaeuser Corporation headquarters campus. It is our understanding that this proposal is a re -submittal of the Preferred Freezer/Orca Bay Seafoods application to the City made in August of 2016 and to which DAHP provided letters with comments and recommendations dated August 23, 2016 and April 27, 2017 (copies attached). In response and based upon our review of the MDNS we are providing the following comments and recommendations: A. DAHP does not agree with the MDNS determination for this application. This determination is based upon our review of the MDNS indicating that our previously submitted comments were not appropriately considered during the review and comment period. Citing from our April 24, 2017 letter, our comments/recommendations are excerpted herein as follows: 2) While addressing archaeological resources in the two project areas, the reviewed materials are not responsive to our recommendations to conduct a comprehensive survey and inventory of the former Weyerhaeuser headquarters campus. As clearly stated in our letter, we request and recommend that the campus be surveyed and recorded by professionals with expertise in architectural history as well as cultural resources to document historic and cultural resources on the entire campus. Our recommendations are reprinted here as follows: ...Therefore, an inventory of the proposed site and surrounding Weyerhaeuser campus is needed to help evaluate the property for its historical and architectural significance. This information is needed to assist the City and DAHP in fully evaluating the impact of the application on this highly visible and prominent location. In order to complete inventory data requested, we recommend that the Weyerhaeuser campus be inventoried by qualified cultural resource professionals with expertise in architectural history and archaeology and using C% AT,�• p.F State of Washington • Department of Archaeology & Historic Preservation a P.O. Box 48343 • Olympia, Washington 98504-8343 • (360) 586-3065 www.dahp.wa.gov 4k ti rreo DAHP's on-line Historic Property Inventory and Archaeological Site Inventory databases. Given the high potential that the subject site and surrounding Weyerhaeuser property is significant for its design, landscape, and plan, we recommend that the City consider the impact of the proposal on the character and quality of this location and on Federal Way's heritage as well as its future. Please note that our recommendation includes an evaluation of the property for its historical and architectural significance. Design, landscape, and plan are specifically called out as areas of significance that need to be addressed during the survey process. B. In our October 31, 2017 letter (copy attached) to an interested member of the public, DAHP issued the opinion that the campus is eligible for the National Register of Historic Places summarizing: "...the Weyerhaeuser Headquarters would easily qualify for listing on the National Register of Historic Places (under criteria A & C) as a ground breaking design that has been studied by generations of architects, architectural historians, landscape architects and historians." C. Based upon the above considerations and previously stated recommendations, we recommend the MDNS is not an appropriate finding and a thorough exploration of alternative proposals be conducted. In the event that the current proposal is accepted, we recommend that additional mitigation measures be identified and included in the City's determination document. D. In the event that the proposal is found to be subject to the Section 106 of the National Historic Preservation Act consultation process due to a federal nexus, our recommendations may be revised. E. Finally, In future, please notify DAHP of the City's SEPA notification and decision -making process related to this and other proposals being reviewed by the City. To help us expedite our review process, please email all SEPA documents to DAHP's email in -box at SEPA@dahp.wa.gov. Thank you for the opportunity to review and comment. Please ensure that the DAHP Project Number (a.k.a. Project Tracking Code) is shared with any hired cultural resource consultants and is attached to any communications or submitted reports. If you have any questions, please feel free to contact me. Sincerely, J Holly Borth Project Compliance Reviewer (360) 586-3533 holly.borth@dahp.wa.gov cc: Laura Murphy (THPO, Muckleshoot Indian Tribe); Brandon Reynon (THPO, Puyallup Tribe); Steve Mullen -Moses (THPO, Snoqualmie Indian Tribe); Rhonda Foster (THPO, Squaxin Island Tribe); Dennis Lewarch (THPO, Suquamish Tribe); Richard Young (Tulalip Tribes); Jennifer Mortenson, Chris Moore (Washington Trust of Historic Places); Jennifer Meisner (King County Historic Preservation Program); Jean Parietti (Save Weyerhaeuser Campus); State of Washington • Department of Archaeology & Historic Preservation P.O. Box 48343 • Olympia, Washington 98504-8343 • (360) 586-3065 www.dahp.wa.gov GTAry C 4 Lance Lundquist (US Army Corps of Engineers); Eugenia Woo (Docomomowewa) State of Washington • Department of Archaeology L Historic Preservation P.O. Box 48343 • Olympia, Washington 98504-8343 • (360) 586-3065 www.dahp.wo.gov ARAmBURU & EUsus, LLP .ttornevs at Law J. Richard Aramburu rick@arariburu-eustir,.com Jeffrey M. Eustis eur,tis@aramburu,eustis.com Brian Davis Community Development Director City of Federal Way 33325 8th Ave. S. Federal Way, WA 98003 720 'Third Avenue, Suite 2000 Seattle, WA 98104 Tel 206.625.9515 Fax 206.682.1376 www.aramburu-eusds.com November 15, 2018 Submitted by Email to: Bdan.Davis@cltyoffederalway.com Re: MDNS for Greenline Building "A" Development {File No. 16-102948-SE ) Dear Mr. Davis: Last week I sent you, as the Federal Way responsible official, a comment letter on the draft MDNS that you advertised for this project, on behalf of Save Weyerhaeuser Campus (SWC), a community organization dedicated to protect and preserve the community and natural values of the Weyerhaeuser Campus and adjacent areas. We have now had the opportunity to review comment letters from other individuals, agencies, tribal governments and organizations. The attached "Summary of Agency and Tribal Comments on Warehouse 'A' MDNS" provides the most important excerpts from the agency and tribal comments. As you can see, these comments concern traffic and transportation, stormwater, fisheries impacts and historic values, all core "Elements of the Environment" under WAC 197-11-444. These comments provide overwhelming evidence of the significance of the proposed uses of the Weyerhaeuser Campus by the current developer and the need to review cumulatively the impacts from the several proposals with pending applications. Many of the other commenters support these views. SWC urges you to carefully consider the comments from the City's agency and tribal partners in management of the values and resources of this important part of the community. The comments clearly lead to a conclusion that an environmental impact statement, considering the cumulative impacts of these pending proposals, is the responsible and legally required action under SEPA. Any course of action that would November 15, 2018 Page 2 continue the flawed MDNS, requiring an expensive and time consuming appeal for all involved, is not appropriate. Thank you for your consideration of these views. Please advise us immediately of your decision regarding the MDNS. Sincerely, ARAM 'URu EUSTIs LP J. Richard Aramburu J RA:cc cc: Clients Bch Avenue South, Suite 205 Fed Fderal Way, WA 96003 II II MEMORANDUM TO: COLE ELLIOTT, PE, CITY OF FEDERAL WAY FROM: LAURA BARTENHAGEN, PE RE: MASTER DRAINAGE PLAN (MDP) SCOPING, GREENLINE BUSINESS PARK JOB #: 1886-001-016 DATE: REVISED AUGUST 24, 2018 The purpose of this memorandum is to provide a scoping document for the Greenline Business Park MDP. The scoping memorandum has been revised per Herrera recommendations provided on April 27, 2018 into three separate sections: 1) Guidance Documents. 2) Scoping Outline —how the MDP will be developed. 3) Preliminary MDP Outline — includes the content of the first Preliminary MDP to the City of Federal Way. 1) Guidance Documents The following guidance documents will be used to further develop the MDP scoping and ultimately guide the MDP development process. [A] — Master Drainage Planning for Large Site Developments, Process and Requirement Guidelines, May 1995; hitps://www.kiiigcoujity,.gov/--/`m dialde tsl ermiain -enviro mental- reviewld erldocumentslformsJle= uide-md - df.ashx?la=en [B] - Appendix - Guidelines for Monitoring and Studies; htt s://www.kiiicou ovJ-/m dialde is rmitiin -environmental- reviewldperldocum nislformsllg- uide-monitor-pdf.a�hx?la=en [C] — 2016 King County Surface Water Design Manual; https:/lvour.kingcounly+_ og v/dnrp/library/water-and-landlstormwater/surface-water-design- manualJSWDM%20201 G9o2Ocomplete%20document%20FINAL%20first%20errata°/o206°/d 2015%202016. df [D] — 2016 King County Surface Water Design Manual, Appendix B — Master Drainage Plan Objective, Criteria and components, and Review Process; https:IJvour.ki n g_cou nty.ggov/diirl2/library/water-a nd-land/stormwater/surface-water-d esi cgn- manual/Appendix B FINAL 4 18 2016.pdf [E] — 2017 City of Federal Way Addendum to the King County Surface Water Design Manual; Civil Engineering • Land Surveying • Project Management • Public Works • Land Planning • Landscape Architecture Phone 253.838,6113 800.345-5694 Fax 253.838.7104 http:Ilwww:ci[yoffederalway.corn/sites/default/files/ Documents/Department/PW/City%20Ad dendum%20[o%202016%20KCSWDM.12df [F] — East Branch Hylebos Creek Documents; Executive Proposed Basin Plan, Hylebos Creek and Lower Puget Sound (July 1991): https://your.kincgcourity,gov/dnrp/library/1991/kcr773.pdf East Hylebos Creek 2001 Monitoring Program Final Report (July 2002): h[tp5:llvour.kitigcourrty.00v/dnrp/library+/2002/kcr1095/EHylebosMfln Report.pdf Lower Hylebos Restoration, Karileen Restoration Project (August 2007): hitp://www.gc.noaa.gov/oc-cd/071108•geiiiiiet app Hylebos Watershed Plan, EarthCorps (July 2016): https://www.earl.hcorps.org/ftp/ECScience/Hylebos/HylebosWatershedPlan 2016.pdf 2) Scoping Outline Task 1 — Project Management • The MDP document will be completed in the recommended phases outlined in Task 6. The first submittal of the MDP to the City will occur at the same time as addressing comments for the Process IV and SEPA reviews. • The MDP document will be revised per City and King County comments as necessary. ■ Coordination meetings will be held as necessary before submittals or after receipt and review of City comments. • Upon receipt of City comments to the Greenline Business Park Process IV and SEPA, a schedule will be provided to the City, outlining tasks, submittals and reviews, in line with the Process IV and SEPA submittals. Task 2 — Regulatory Compliance • Regulatory codes and sections will be identified and reviewed as part of this task. • The guidance documents listed above will be used for regulatory compliance as well as any additional requirements provided during City review. • ESM will identify any potential compliance issues and variances as part of the draft MDP, including coordination with City and King County. Task 3 — Data/Information Compilation and Review • Per guidance document [D] (page B-3) listed above, ESM will define the study area including the site and natural resources that may be affected by the proposed development both upstream and downstream of the site, including the following: o Delineation of sub -basins of appropriate size/land use for computer model characterization and hydraulic analysis of all tributary flows. o Location and size of all existing and proposed hydrologic features and facilities in the sub -basins. This includes lakes, ponds, wetlands, swales, streams, pipes, and culverts. o Overall plan/profile and cross -sections of conveyance systems and identification of the floodplain and floodway and frequency of flooding for existing and developed conditions. o Identify areas of in -stream erosion, sedimentation and/or unstable slopes. o Identify site soils for use in hydrologic modeling and preliminary analysis for controlling erosion during construction. o Identify upstream and downstream habitat conditions, e.g.., fish spawning, rearing, and migration areas; pools, riffles, and other in -stream habitat features; and documented species and their population status. 2 1 P a g e o Identify general required building setbacks, clearing limits and Native Growth Protection Easements in areas of steep slopes and drainage features. Compile existing data on site and natural resources listed above, including existing drainage system flows. Coordinate with City and King County as necessary to identify data gaps necessary to fill to support analyses of environmental impacts/risk, including hydrologic modeling. Task 4 — Baseline Monitoring/Data Collection Upon completion of Task 3 and coordination with City and King County — evaluate if and where additional data collection as well as monitoring is needed, including but not limited to the following items: • Determine type, purpose, frequency, and duration of monitoring/data collection — consult guidance document [B] listed above. o Geotechnical (e.g., subsurface exploration, hydrologic characterization, infiltration characteristics, groundwater levels, geomorphology, etc.) o Hydrological (e.g., lake bathymetry, stage -discharge relationship, ordinary high water, surface area, maximum dead and live storage volumes, 100- year floodplain, stream flow rates, wetland delineation and corresponding water levels, precipitation characteristics, etc.) o Fisheries (e.g., fish use, habitat, water quality, and riparian condition) o Water quality (e.g., nutrients, temperature, pH, Secchi depth, dissolved oxygen, sediment metals, macrophytes, bacteria, etc.) ■ Develop and document monitoring QA/QC and data validation protocols. • Collect baseline monitoring data per scope items listed above. Task 5 — Analyses and Design • Perform all analyses to support identification of impacted resources potentially including soils, hydrology (lake, stream, and wetlands), fisheries, and water quality. This may be done concurrently with various phases of the baseline/monitoring data collection in Task 4. o Off -Site Analysis ■ Perform Level 1 downstream analysis ■ As necessary, perform Level 2 or 3 downstream analysis, depending on the presence of existing or predicted flooding, erosion, or nuisance problems identified in the Level 1 analysis o Hydrologic Modeling • Develop hydrologic modeling approach, including inputs, assumptions, and calibration steps • Develop model and perform calibration ■ Perform existing conditions modeling and post -development modeling • Analyze modeling results to evaluate potential impacts to onsite and offsite hydrology ■ Grading/Drainage Plan o Plan shall include site plan components, topography, natural features, sensitive areas, buffers, lot layout, road right-of-way, drainage subbasin boundaries, drainage pathways, road and lot drainage conveyance routing, drainage easements, drainage facility locations, facility types, design standards, facility outfalls, and constructed mitigation measures. ■ Mitigation Measures 3 1 P a g e o Mitigation measures shall be developed for any impacts that remain following all possible refinements to the grading/drainage plan. Task 6 — MDP Development • MDP development shall occur in phases as described below and as described in guidance document [A] listed above. Each phase corresponds with a submittal to the City for concurrence and feedback. • Preliminary MDP (see p. 11 of guidance document [A] and 3) Preliminary MDP Outline) o Most studies and analyses should be substantially complete at this stage; however, some more complex or longer duration aspects of the MDP may not yet be completed. o Write preliminary MDP document, which shall include, but not be limited to: • summary of all compiled data • mapping of existing and proposed conditions • summary of all modeling, studies, and analyses, including detailed description of potential impacts • conceptual drainage/grading plan • proposed mitigation measures • Draft MDP (see p. 12 of guidance document [A]) o Draft MDP is a refinement of the Preliminary MDP, based on City review comments and incorporation of elements that were incomplete in the Preliminary MDP. o Write Draft MDP document, which shall include, but not be limited to: • additional information collected on existing conditions • additional analyses of potential impacts, including hydrologic modeling results and more detailed off -site analyses, if warranted • refined grading/drainage plan, including grading volumes, runoff conveyance routing, and preliminary drainage facility siting • refined mitigation measures • summary of code compliance and variances • draft Technical Information Report (TIR) • proposed post -development monitoring plan, which should account for uncertainty in potential impacts • Recommended MDP (see p. 13 of guidance document [A]) o This represents the proposed final MDP that would be recommended for formal City approval as part of permitting. o The Recommended MDP shall include, but not be limited to: • completed data collection and analyses of all potential impacts • final grading/drainage plan • final mitigation measures (should be consistent with the Process IV and SEPA reviews), including maintenance and operation plan • final post -development monitoring plan • all agreements/contracts/scopes associated with MDP It final TIR and all supporting special reports and studies • Final MDP (see p. 14 of guidance document [A]) o Occurs with City and administrative permit approval and shall include any modifications necessary to comply with permit conditions including any specific agreements on the post -development monitoring plan. 4 1 P a g e 3) Preliminary MDP Outline Section 1. Project Overview This section will provide an overview of the MDP for the Greenline Business Park. Section 2. Conditions and Requirements Summary and Compliance with Regulations This section will describe in detail how each technical elements and mapping requirements of Appendix B of the 2016 KCSWDM are met as well as the requirements of the King County MDP for Large Site Developments Process and Requirement Guidelines dated May 1995. We will also include requirements provided by King County DPER related to the East Branch Hylebos Creek study. Section 3. Off -Site Analysis This section will include upstream and downstream basins and associated habitat conditions as well as narrative related to the sphagnum bog near the site. Two defined Point of Compliance (POC) locations are present at the natural discharge locations of the site. One POC is North Lake and the second was determined in the meeting with the City on January 3, 2018 to be directly south of SR-18. For the second POC, existing conditions stormwater flows will be used for the existing basin areas. Section 4. Analysis and Design This section will include the analysis and design necessary to address the technical elements and mapping requirements described in Section 2 of the 2016 KCSWDM Appendix B as well as any mitigation requirements provided by King County DPER. The technical requirements will be addressed using the outline provided by the MDP for Large Site Developments Process and Requirement Guidelines dated May 1995, as follows: Drainage Plan The drainage plan will include site plan components, topography, natural features, existing sensitive areas and associated buffers, floodplain, and floodway locations, proposed building layout and associated setbacks, frontage improvements, clearing limits, road right- of-way, drainage subbasin boundaries, drainage pathways, road and building drainage conveyance routing, drainage easements, drainage facility locations, facility outfalls, plan/profiles and cross -sections of conveyance systems, and constructed mitigation measures. Hydrologic Model and Calculations As discussed in the meeting with the City on January 3, 2018, WWHM 2012 hydrologic model will be used for the project site. The methodology will be described in detail in this section, including assumptions, hydraulic performance data, input data parameters for flow control, water quality, and flow control BMPs data, floodplain analysis, conveyance and backwater data, and an erosion analysis. Mitigation Measures Mitigation measures, as necessary will be identified. Post -Development Monitoring Plan A general scope for a monitoring and implementation plan will be provided in this section, including monitoring during construction, monitoring performance of stormwater infrastructure and facilities monitoring, and monitoring of existing resources such as 5 1 P a g e wetlands and streams. A detailed operations and maintenance manual will also include these elements with the final Technical Information Report for the project. Agreements/Contracts/Scopes Any agreements that result from the preliminary application phase and the work scopes for baseline monitoring, the MDP content, and post -development monitoring would be included in this section as approved by the City. Section 5. Special Reports and Studies This section will include additional reports that provide support information by wetland biologist and geotechnical engineer as well as the approved storm report and as -built information on the revised weir for the Weyerhaeuser Pond. Section 6. References This section will include references to all relevant reports, as related to ecological and geotechnical analysis previously provided to the City of Federal Way. Appendix This section will include the stormwater calculations for existing and proposed on -site and off -site drainage systems, including WWHM 2012 input and output files. \\es m8\en gr\esm-jobs\1886\001 \016-0016\document\me mo-001. docx 6 1 P a g e Summary of Agency and Tribal Comments on Warehouse "A" MDNS Washington State Department of Transportation ■ All four project proposals — Warehouse A, Warehouse B, Greenline Business Park and the DaVita office building — must be analyzed together to fully assess the "direct, indirect, and cumulative impacts of all four developments to WSDOT's facilities and their function." These projects will have an impact on the 1-5 and SR 18 ramps adjacent to the campus. • Warehouse A and Warehouse B "independently exceed the vehicular trip threshold for determining whether a highway improvement should be requested"; additional projects will add to those trips. WSDOT requests the city require 300 feet to of "storage" to decrease backups for right -turning traffic coming off the westbound SR 18 off ramp onto Weyerhaeuser Way. • WSDOT is reviewing the project's hydraulic report for impacts to SR 18's right of way and drainage system, and will submit comments by Nov. 27, 2019. King County, Department of Transportation KCDOT requests that all five warehouses "be reviewed together underSEPA, to ensure that cumulative traffic volume and congestion impacts to the regional road network are understood and appropriately mitigated." The city's apparent "incremental project -level approach" is insufficient. The scope of the applicant's Traffic Impact Analysis (TIA) should be expanded, with additional evaluation of impacts to surrounding streets and alternate routes trucks will use to access Interstate 5, including Military Road between South 320th Street and the South 272nd Street interchange. The applicant has not demonstrated mitigation of additional truck traffic onto these alternate routes. King County Department of Natural Resources and Parks The applicant's technical information report (TIR) should "explicitly address how the project's stormwater design is meeting or exceeding the standards ... in the Executive Proposed Basin Plan/Hylebos Creek and Lower Puget Sound." A downstream analysis must include "all available information on the downstream area to fully identify existing drainage and water quality problems." The analysis has only been done for one -quarter mile downstream; it potentially must extend further under the regulations of the 2016 King County Surface Water Design Manual, which the city of Federal Way has adopted. The Hylebos basin is within the WRIA 10 salmon recovery jurisdiction, so Federal Way should be working with the recovery forum and the Puyallup Tribe to ensure the SEPA review is consistent with that plan. Washington State Department of Archeology and Historic Preservation 0 DAHP disagrees with the MDNS because comments it previously submitted to the city "requesting an evaluation of the property for its historical and architectural significance" have not been appropriately considered. The campus is eligible for listing on the National Register of Historic Places. "Given the high potential that the subject site and surrounding Weyerhaeuser property is significant for its design, landscape, and plan, we recommend that the City consider the impact of the proposal on the character and quality of this location and on Federal Way's heritage as well as its future." • A comprehensive survey and inventory should be completed, and there should be a thorough exploration of alternative proposals. If the current proposal is approved, "we recommend that additional mitigation measures be identified and included in the City's determination document." Puyallup Tribe of Indians • The Puyallup Tribe requests that the city require an Environmental Impact Statement to address significant site and cumulative impacts. Filling wetlands where Warehouse A and B are proposed "not only will permanently impact site wetland hydrology, but will also impact downstream flows to Hylebos Creek," used by Endangered Species Act species such as steelhead, chinook and bull trout. The Tribe and others have spent millions of dollars to restore the system over the last several decades • "It continues to allude us why the agencies and city are bifurcating these development proposals, other than to circumvent environmental review and analysis of impacts. We strongly disagree with the decisions to review these proposals separately. As we have stated, a sufficient and complete assessment of impacts cannot be completed based on the available information. This is not only inconsistent with SEPA requirements, but City Ordinance 94-219, adopted in 1994, as part of the annexation of the Weyerhaeuser Campus. " Muckleshoot Indian Tribe ■ The Muckleshoot Indian Tribe agrees with the Puyallup Tribe's comments regarding cumulative impacts. Analysis must include watershed planning efforts as required by the 2016 King County Surface Water Design Manual, which the City has adopted. • More information is needed about required road improvements to determine further direct or indirect impacts to wetlands, onsite Stream EA or the East Fork of Hylebos Creek. • The culvert connected to Stream EA is a fish -passage barrier and must be replaced by 2030 under a federal court injunction. If not for the culvert, this stream has the potential to be a fish - bearing water; the stream needs to be reassessed to determine if it meets the criteria for presumed fish habitat under the Washington Administrative Code. • Tribal treaty rights must be respected and successful resolution of tribal concerns addressed, both with the City and with the United States Army Corps of Engineers, not by the applicant. Fa 41k CITY OF 4� Federal Way COMMUNITY DEVELOPMENT DEPARTMENT EE33325 8"' Avenue South RESUBMIT-1 E D Federal Way, WA 98003-6325 253-835-2607;Fax 253-835-2609 J U L 12 2018 planning(a)cityoffederalway.corn ww .citvoffederaiway.com ! I I Y' (),F Fr--1)E AL WAY y ,,h ,IU' 11 DkVELDPME,PdI NOTICE OF APPLICATION SIGN INSTALLATION CERTIFICATE Project Name: GREEC 1 V L Project File No: _ 1 1— 105 416!— LP F Project Address: U W Installed By: Date of Installation: .l 1 Location of Installation: 1 *Please forward pictures of the posted sign to the project's planner.* 161 V :S3O� 1 11i�1 11 1/ill lull !1 11 R/ 11 �1 �� ■1 !1 �1 !� ■! i1 !lill ll�i1 �1 11 �1 �l lli■till 11��1 i w. �..w. .w. •w, y. •w. w. •w. •_. •w. •w. •w. •w. •w. •w. �w. w. •w. w. *. •w. w. •w• •w• •w• w• w• •w• •w• w• w• •w• I hereby testify that the sign installed fully complies with the installation standards outlined in Federal Way Revised Code (FAIRC) Title 19 `Zoning and Development Code' and that the sign will be maintained until a final decision is issued on the land use action and/or environmental threshold determination. I understand that failure to return this certificate within five days of posting may result in delays, notice of corrections, and re -mailings at the applicant's expense. M�4ReAer Installer's Name lli?ai" I . oi�� l6aller's Signature -7 11/ 1!6 Date �53-%3�'-�� Phone - Bulletin #036 —March 7, 2018 Page 1 of 1 k:\Handouts\Sign Installation Certificate r,� .'i so • I .117- • i . 1 �� •'3t►�1� r'i i4 ST �r: k GY"JrI *2 �:- �. �. Noa olf\ W w,� . l •1 1 3 � zr ITS fix A �a lit D S� U,� Z-� {yyi;Iiii il + f f I i W CITY OF Federal Way COMMUNITY DEVELOPMENT DEPARTMENT RESUBMITTED 33325 81" Avenue South Federal Way, WA 98003-6325 MAY g 2018 253-835-2607; Fax 253-835-2609 tannin &@cit offederaIwa .coin CRY OF FEDERAL www.cit offederai��a .cam COMMUNI7Y DEVELOPMENT NOTICE OF APPLICATION SIGN INSTALLATION CERTIFICATE Project Name: (� � " -� W -- (� Ion Project File No: � • Project Address: Installed By:C Jr Date of Installation: Location of Installation: ©c�- r->�- U) *Please forward pictures of the posted sign to the project's planner.* -3 -3c�—, iy1i�Fi"ii-ii-i1®iI'ii-i1_Li-i0 %5 %1—i1%i%d-ii—Fiji; ii-i;al1%1`iI'id'id"i1%d'�1%d'ii—ii-i i a %• •mr •ar •ar •ar •ar ar �� •ar a. Isar •�. •«r ,er �r•r •ter •wr ar r ar •ter •wr •nr •ar •ar mr •ter •ar •wr •..r .rr I hereby testify that the sign installed fully complies with the installation standards outlined in Federal Way Revised Code (FWRC) Title 19 `Zoning and Development Code' and that the sign will be maintained until a final decision is issued on the land use action and/or environmental threshold determination. I understand that failure to return this certificate within five days of posting may result in delays, notice of corrections, and re -mailings at the applicant's expense. Installer's Name JA, 9"42 Installer's Signature Sllot" I I% Date Phone Bulletin #036 -March 7, 2018 Page I of 1 k:\Handouts\Sign Installation Certificate All 19 q CRArr a r c h i t e c t s I� ST-01 ! EX-01 / SD-01 / GR-01 I �- �.'� ® r l II PONo, [:LOT 2 =0 DETENTION ' PAgCELF BUILDING W 1 � l 1 � {� • �� PARCEL F 1 � Ca l II E7fD ,rc v 90IL Bi,ILD1Np `1• `i �I �� II LIILD111G-C' @Q f } I View #3 ST-03 / EX-03 - -- ST-02 / EX-02 / SD-02 / GR-02 ---_ Visual Impact Exhibit GREENLINE BUSINESS PARK FEDERAL WAY, WA 3/22/2018 RESUBMITTED APR 3 0 2018 CITY OF FEDERAL WAY COMMUNfTY DEVELOPMENT +♦ IRG i_LC IITCILI�trlal Realty Group, View #1 GREENLINE BUSINESS PARK 1RG C R^rlr- Visual Impact Exhibit FEDERAL WAY, WA 3/22/2018 Industrial Realty Group, l.LG .i � [ f� I i f.• [ 1 5 err• -- � - CRArr a r C h i t e[ t S oe Visual Impact Exhibit View #2 GREENLINE BUSINESS PARK FEDERAL WAY, WA 3/22/2018 716 _ [FIG lndustrtiD! Ficalcy GI orfp, 1_.LC: 4A Ai 4e, IN -AA wr, ANL. 4-1 Ull �%T TES Ap, I ot AW Ll FU CD 11 c ap O C N C O C C C C Y L Y C d y 0¢ V O C L O L .L-+ Y C ai - L- ca — d U= lw/J _, co aJ ._rN caN ,� ca �-E o c..+ o¢� c off:-. `-c" `o o= w-- � E c . E m 1 0 E a n 7 O o c- O ca m a� c c c N N 'o O oaf U 0 c am O o o a a, 3 0� �' n- 0 U > x c o n E a� E„ t° a '= c M eo G'�nai cUva �>OU EC�U�T pi UUNca coda _nd TO _NXy'Oa� Ca�O y r C C aJ ++ a-+ a— C L W ` ` a0 T ¢ C a N rL-. d o U 01 d O a> Y m ` c c c c w uO m�vL�v > m}o� Ew= off- E E �•- o y - m a�i ,y �aL mF N CO V U U m = cc U D to W d d y-+ 2 'UO OJ 0>.l p O L L 3 c o c Uo a rn y. a w' vi O O �-- U - C — ca L N N c/J = Ui OJ GJ E ?� U OJ L y +-+ E d N n- .— z c- y Nm NR-_�w}'o �c E �wooc �c�cc�Exox -�c�-�za-��n0 E c r d 3 a nv o y N> _ c� x a� h �L a a w U �' E a> m n E r. x Eo a � n o a`�+� tf0i -�'E_� c m c E co �' Uco E may coca= ao E c E R c U on• E U co m }' - r co m E a' E o f a a c� >�maaci a°� =coi cn Ec„ Q�c��oo c,°3�a�ocin�`a -`nvc a�--N-'-m Ica y 0 �-- c6 Q O— }, C 4 U =. n �-+ Q- aJ = N U m O ca � y L fa d— N U ca C N C cE � c� ov aE Q n a o mop c ca o aci Q m E o c E� m 32 ca°L= E- LL E nL 3'� �_ °v w c m >'> E dl n`a �ia� °' E v T� a` a� c o 0 o c o o �m m=LL E O) C Y L L� L a1 ¢> d n C 12 aJ — O C .O i C OJ ca O h N w N O c> C U orc� 70 c �� > c � CL,3=v m c N > v> c wu O�� p O� c o c m is = c t rn a> c rn a� ¢ '- o a> o '- as T'cy U m o- a w _ O 3m a dr E�.� _ L E a`� o �, ca c E c E c U `° o v c Ty �.�'- �aci-'- m E=° aciH= E� c U-o X a'""'w E� co c� Y c c o._ "-- U N O O U C X c C aci c� !' O ca a0 C L w_ a> W - ♦N+ U a� c N ._' U U C ®� u7 E '� - c x E m a� c m a� c•a c-� ca o'Y +'}' 2 c °J a. a�"- E c~ V c�a n a' c a> E� c c c nc c,c-,- = - a) E c _ p-cLm 3cnacvE�Ec•.c'ia¢aE�c-UaUa�ocxa�OUCvc"aoiNoo�ccxaaEc`�-'E� .vo�3::2 =omE>�^_V=�m_ c a> S a c m E c a E a` o- c o V- E d C a�i W-� N O a/ O a`mi m e 7 a> 7 a>i M a0 a`� c X a> = a> d a O= N d d- L O> O C` o m •. E N E w N c caw= = cn_ V m S w¢._cnc�� n�acr-M�-mrn o_EwMw,��x ca c� 3-0� <n c�QO aw c..� mw tea:=. � 6 A aJ ` o c. ' o ¢ L x O' — to d -6 L_ - � — N Ga N Z �y '� c oU mMornY cca o V 4- E-L cw�w cw� ate¢ O •OQ O- y ca M aJ uj r O O N N 7 N > y al v v N d nL p 'y n o r aEi `r �rnM¢M c o_z a� E Er c—Na c Lu Ecr a yaa V O p j a p N U Ol cn ¢ 9) CO aro C a`�J .N >. N 0 r �_ E U O O m E. d 6 O y n CO J C T f� O v1 U fa C L cn j U C C OJ ¢) w a J Y_ C n O• T J¢ U aJ T N taa d O. > O U N C U O Y� cn H co a O W O E J c. M O E c - ca C U O U W ca O al n a ca . ao _ E . w J a ca 2� N � co ca -- 3 w c t :== -o n mom c z v' ¢w �o y.�._ c i o ca E—o aj U = o¢ c xa cx E w N� r C C i cn n J u� X ca T r caa N a n C -ii ¢ O Y¢ U m m O. _ O a1 U � a� -' >. O n 3 E m5 - 2 a' al '- c co � c c m cf is m = w o U n o c a> V c °� n °> cn a F m a' z LL o va J N CA x R Tn E m= p Ocvia OE m=¢wo EYcoc°LwBr`cc wn can�a� n E>`m ¢m E� 2 c > Nam w i o °' y Y� � -'c O m o o y c m c c cw c c W c ` C" 0 c =,L co O Qn C c scar c,�¢ new Ex5 ¢ 2� O cc_ C: C c n (/i C O a— Z n aJ m C y O C VJ C 7 _ 2L nE a N C/�N E Q 7 c ca i c y a c c� V to c a W C C n ca E— O c O y n._ ._ ca O c O O +-' U a> N ` O ca m oom y' �a N= C ca� CO V p0 O cx nL aUi �dHm ca m c ani c=w m o� Q m ca 3._� c c O a u U n� cw a¢ E t m a' C7 a c m m m o ar io N aJ C 'v '- > d —Lu --- a.+ — y V C y O w co U L 1f01 d V V al N Q �j O c ui U VJ — Y w [>a ~ O O ++ U a`a aD— E o Qcn E C a O-O C O E aJ O c Y m.-+ -' "' O cn ti Q O O O o_— O O r M ca a� N aJ c y ca c c J c car Q Z E -0 ¢ m cp n V Oa 0a N m al m oC , C V Z cn a' n� oU c 0 w� aawoaQ Y O v' U�� cy ¢vvrw E "o-c -� OC a D 4i�iii ., m? m ca cn ro as ` v o V '^ E o` o " ._ o 0 0 ,, �rr'I r u v c '�- c n d � r 'E O D V a1 0- E Tr r O s ca v' to E +Y O a' arm i a' m c c w w cr Y a/ Y' 7 r ar o r m. c� o: E_c. . w cn % Z E E'E o Q= amo o'> o aai cow o c o� v._ mr o c o a"ci orr°O aci c== ao> c c c ar t�`� �(t,�ri aa� a�oo w ca¢cnrn¢¢d�c�r00�am 3xV cad�agcc7wc��c6¢cnc7c�ati •E5•. .t1 e � ;z��yP CSC � • •. �? •t '; G Fes- CrY "; cf ;N c bA L: N cn oj a� a=W� aU .. o ° oo 3 on. P4 � . U boo 4w c� >, 03clo tows C 0 b o P. a, ¢+ O oo .., b '�C N �'� N 42 �C 06 O N o Co � O � U r--' E O 4-4 cz cd ~ rr I � S, I., r,Q. WO s N� cd O o 0f0 =P=*'n 3 E� ��rra C7U 41k CITY OF Federal Way NOTICE OF MASTER LAND USE APPLICATION Project Name: Greenline Business Park Project Description: Construction of three buildings totaling approximately 1,068,000 square feet, five new stormwater ponds, revisions to existing parking lot and addition of approximately 806 parking stalls, filling approximately 13,500 square feet of wetlands, roadway improvements, and associated site improvements on 146 acres. Applicant: Federal Way Campus, LLC, 11100 Santa Monica Blvd, Suite 850, Los Angeles, CA 90025 Agent: ESM Consulting Engineers, LLC, 33400 8t' Avenue South, Suite 205, Federal Way, WA 98003 Project Location: Approximately 329XX Weyerhaeuser Way South, Federal Way, WA, King County Parcels 162104-9056, -9013, -9030 and152104-9178 Date of Application: November 14, 2017 Date Determined Complete: May 14, 2018 Date of Notice of Application: May 18, 2018 Public Comments Due: June 4, 2018 Requested Decision and Other Permits Included with this Application: The applicant requests a Use Process IV Hearing Examiner decision (File #17-105489-UP) pursuant to Federal Way Revised Code (FWRC) Chapter 19.70. Additional permits and/or approvals in conjunction with the Use Process IV decision include a threshold determination pursuant to State Environmental Policy Act (SEPA) Rules WAC 197-11 (File #17- 105490-SE), Transportation Concurrency (File #17-105491-CN), Boundary Line Adjustment (File #18- 100123-SU), and Forest Practices Class IV General Permit. Environmental Documents: Environmental Checklist, Wetland Report and Conceptual Mitigation Plan, Visual Impact Exhibit, Geotechnical Report, Transportation Impact Analysis, Pavement Analysis, Parking Study, Stormwater Technical Information Report, Air Quality Report, Environmental Noise Report, Cultural Resources Study, Evaluation of Trees. Development Regulations to Be Used for Project Mitigation: Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement and applicable 1994 development codes, including Federal Way City Code (FWCC) Chapter 18, "Environmental Protection"; Chapter 20, "Subdivisions"; Chapter 21, "Surface and Stormwater Management"; and Chapter 22, "Zoning." Consistency with Applicable City Plans and Regulations: The project will be reviewed for consistency with all applicable codes and regulations including the Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement, which vests the project to regulations in place in 1994; FWRC 19.145; 2016 King County Surface Water Design Manual as amended by the City of Federal Way; and the Public Works Department Development Standards. Any procedural requirements must meet today's codes (FWRC Title 19). Public Comment & Appeals: The official project file is available for public review at the Community Development Department (City Hall, 2r'a Floor, 33325 8a' Avenue South, Federal Way, WA 98003). The initial public comment and notice period ends June 4, 2018. However, any person may submit written comments to the Hearing Examiner by delivering these comments to the Department of Community Development prior to the public hearing date (which has yet to be determined) or by giving these directly to RECEIVED Save Weyerhaeuser Campus' SAV EW EYERHAEUSERCAMPUS.ORG PO Box 4402 Federal Way, WA 98063-4402 savethecampus@gmail.com June 4, 2018 SENT VIA EMAIL AND HAND DELIVERY Brian Davis, Community Development Director Jim Harris - Planner City of Federal Way 33325 8th Ave. S. Federal Way, WA 98003 plaTInitlg@citvc)ffederalway.com JUN 0 4 2018 COMMUNrTY�DEVELOPMENT RE: Citizen Comments on the Use Process IV Hearing Examiner decision (File #17- 105489UP); State Environmental Policy Act (SEPA) Submittal (File #17-105490-SE); Transportation Concurrency application (File #17-105491-CN); Boundary Line Adjustment (File #18-100123-SU); and Forest Practices Class IV General Permit. Dear Mr. Davis and Mr. Harris: We are writing in response to the city's request for comments on the application for a Master Land Use Permit, submitted by Federal Way Campus, LLC, for Greenline Business Park: Construction of three buildings totaling approximately 1,068,000 square feet, five new stormwater ponds, revisions to existing parking lot and addition of approximately 806 parking stalls, filling approximately 13,500 square feet of wetlands, roadway improvements, and associated site improvements on 146 acres. The following comments are offered by our organization, Save Weyerhaeuser Campus, to supplement individual comments offered by our individual members. We are joined in these comments by the board Pg. 1 of 24 and members of the North Lake Improvement Club, the board of the Lake Killarney Homeowners Association, and community members in Federal Way and beyond. We urge the City to deny the application for a Master Land Use Permit for all of the reasons we identify below. Additionally, to the extent the City intends to grant the permit, we respectfully request the City include the conditions and restrictions we have identified, so as to minimize the substantial and irreversible negative effects that Greenline Business Park will have on our community, the historic Weyerhaeuser corporate campus, and the City of Federal Way as a whole. Who "We" Are: Save Weyerhaeuser Campus is a nonprofit grass -roots organization formed in August 2016 after Industrial Realty Group, the new owner of the historic Weyerhaeuser Campus, submitted an application for a freezer warehouse and fish -processing plant (now called Warehouse A) on a land adjoining Warehouse B and now Greenline Business Park proposal. We have an active community of supporters on our Facebook group (543 members who freely share with other groups and individuals), plus 1,095 followers of our Facebook page. Since September 2016, our website has logged nearly 9,700 visitors looking for information about the proposals on the campus (nearly 22,500 page views). In addition, more than 500 people receive our email updates. Organized groups that are working in coalition with us are the North Lake Improvement Club, comprised of some 60 families living on the lake and its vicinity and the Lake Killarney Homeowners Association, comprised of homeowners residing south of Warehouse A & Warehouse B (across Highway 18) and who will be substantially negatively impacted by this new proposed project; also joining us is Rainier Audubon, concerned about the environment, fish and wildlife impacts from this proposal, and the Washington Trust for Historic Preservation, which in May 2017 named the historic Weyerhaeuser campus to its "Most Endangered Properties" list (both these groups are submitting separate comments on the Greenline Business Park proposal). Under separate cover, we are submitting a community letter, signed electronically by nearly 500 concerned people (and counting). All these parties are equally troubled by the transformation of the property from corporate campus to industrial park, and the degradation the proposed development will have on the community and environment. We are all concerned citizens of Federal Way, King County and beyond, who have a vested interest in the City of Federal Way: its natural resources and heritage, its economy and business interests, and the future of the community. What We Want: We urge the City to deny the application for Greenline Business Park, as it does not meet any of the requisite conditions for approval under city, state or federal law. The proposed development does not meet the goals and policy in the city's comprehensive plan for the Corporate Park zone and office park zones: By clear -cutting forested land, it will damage wetlands and drainage that feeds the fish -bearing Hylebos Creek. It will bring dangerous freight traffic — a low estimate of 400 semi -trucks per day (combined with Warehouse A & B's 400 semi -trucks — for a total of 800) — to Weyerhaeuser Way, a walkable area with office parks and forested land that blend into the long-standing North Lake residential neighborhood and North Lake itself. In addition, the Greenline Business Park is likely to operate during more than regular business hours, creating noise that will impact the nearby neighborhood. Pg. 2 of 24 Pursuant to FWRC 19.65.100(2)(a), the City may not approve the Master Land Use Permit Application for the following reasons, any one of which is sufficient to warrant denial: ■ The proposed project is not consistent with the Federal Way Comprehensive Plan; and • The proposed project is not consistent with all applicable provisions of Title 19, Zoning and Development, of the FWRC; and • The proposed project is not consistent with the public health, safety, and welfare; and • The streets and utilities in the area of the subject property are not adequate to serve the anticipated demand from the proposal; and ■ The proposed access to the subject property is not at the optimal location and configuration; and, • Traffic safety impacts for all modes of transportation, both on and off site, are not adequately mitigated. What We Reviewed: For the purpose of lending credibility to our comments and creating an administrative record, we provide the following brief summary of the materials, available on the city's FTP site, which we reviewed to assist with preparing these comments: • ESM cover letter, 11.14.2017 + Master Land Use Application • Traffic Concurrency Application Summary letter from pre-app letter ■ Title Report ■ Letters of Water and Sewer + Site photos ■ Signed SEPA Checklist, 4.30.2018 ■ Process IV plan set • Building elevations design intent • Impervious Surface Area ■ Preliminary technical information • Transportation impact analysis • Parking Analysis ■ Critical areas report and conceptual mitigation plan • Geotechnical report ■ Pavement analysis report • Evaluation of Trees at Greenline Business Park ■ Public Notice Mailing List ■ Visual Impact Exhibit • Air Quality Report Pg. 3 of 24 ■ Noise Report • JARPA • Response to Letter of Incompleteness As we did when commenting in August 2016 on the neighboring Warehouse A proposal, and again in October 2017 on the Warehouse B proposal, we have also reviewed the Concomitant Agreement between the City and Weyerhaeuser, dated April 1994, as well as Ordinance 94-219 and any and all available public records relating to the passage of said Ordinance. We reserve the right to supplement these comments in advance of the City's decision on the Master Land Use Permit Application, and also reserve the right to refer to any and all of the documents in the City's record for this project, on appeal (regardless of whether they are listed herein). Following are several of the specific issues and reasons the Save Weyerhaeuser Campus organization believes the City should deny the application for Greenline Business Park, as it does not meet any of the requisite conditions for approval under city, state or federal law: 1) TRAFFIC ISSUES CONCERNS: a. Much more definition of the warehouse functions is needed to understand the traffic and parking consequences. The configuration of Business Park Building A, a massive space with loading docks on both sides, suggests it could serve as a package hub or possibly a fulfillment center. It has 165 loading dock doors and parking for 111 trucks. Trip and parking characteristics can differ substantially for various warehouse functions with fulfillment and package hubs generating more traffic than other more traditional warehouses. So far, only general warehouse uses have been assumed in the initial trip and parking projections. b. The parking memo projects demand for both new warehouses and the Tech Center building. However, it assumes warehouse use of the Tech Center — that seems odd for what is basically an office building, and therefor probably underestimates parking demand. c. The floor area cited in the parking memo for the Tech Center building seems too high. Memo says 1,327,500 gsf — that's hard to believe unless below -grade floors exist. d. Staff instructed the applicant to include trips from occupancy of the former Corporate Headquarters building in the TIA. Although we understand this building is not yet occupied — we would suggest that the applicant use assumed numbers for this building (former headquarters) as well as the Tech Center at full capacity. City also must assume the full capacity of both the current DaVita and future DaVita buildings when considering the impacts. e. The parking memo argues for reducing the zoning code parking requirement by about 35 percent. Curiously, it projects (wrongly as noted in d. above ) demand for 981 spaces, but offers to build 1,577 parking spaces, less than the code -required 2,396. This is a highly -confusing proposition for these reasons: i) It relies on ITE data that applies only to general warehouses. ITE's data base (Parking Generation, 4th ed.) doesn't include data specific to different kinds of warehouses, and certainly not fulfillment or package centers. ii) Again, the land use assumption for the Tech Center seems wrong, so the zoning required total and demand projection reflect unreasonable assumptions about warehouse use — unless the applicant means to redevelop the Tech Center buildings. Pg. 4 of 24 iii) It is unclear why the applicant requests a reduction in required parking but offers to build 60 percent more parking than demand indicates is needed (1,577 spaces vs 981). This could be a hedge on the eventual type of warehouse use. f. This project triggers the need to dedicate ROW and build a portion of the South 324th Street Extension, a big addition to the City's arterial street network, as envisioned in the Comprehensive Plan. g. The site plan shows parking wrapping the Tech Center, bringing lots much closer to Weyerhaeuser Way, a move contrary to the city staffs recommendation to include the best of the current parking -lot design. This is a character -defining element and the new plan would destroy the park- like characteristics that now grace the campus. Overall, an EIS would be appropriate and expected for these reasons: The scale of new development (Greenline Business park when combined with Warehouse A and Warehouse B) with over 1.5 million square feet proposed is significant in terms of traffic generation, with nearly 6,000 new daily trips, including a significant share of truck trips (on the order of 20 percent of the total). Alternative sizes and mixes of land use should be evaluated for their traffic differences. Those alternatives could include different types of warehouse operations that could cover fulfillment centers and package hubs so that their impacts can be understood should the applicant sign such a tenant. • It's in an area with a modest street network and a highway interchange already known to have capacity constraints and poor traffic operations. m A new arterial connection is required (South 324th Street extension) that will have major impacts. Substantial rebuilding of Weyerhaeuser Way to support trucks appears necessary. • The potential need to widen Weyerhaeuser Way north of South 336th Street is a major impact. • Designs more consistent with the campus' architectural and landscape character should be evaluated. 2) CRITICAL AREA Wetland Watershed ISSUES: a. Proiect Timeline. Of concern is the IRG timeline for the project, which proposes to start in Spring 2018, construct in Summer 2018 and complete building by Summer of 2019. JARPA has conflicting information that the start date is 2018 and completion is 2021. A realistic time frame that includes more complete documentation is needed. b. Piecemea_ line. IRG states the Greenline Business Park is a single land use project as though it is unrelated to Warehouse A and B. This is a classic example of what the U.S. Army Corps of Engineers calls "piecemealing" a project — a developer isolates components of a larger development into smaller parcels, each below the limit for filling and disturbing wetlands, so that it does not trigger the need for a Corps or state permit, while cumulatively the project exceeds the threshold for a Corps permit. i. The city of Federal Way has adopted state law under SEPA, that similar proposals or parts of proposals that are related closely enough to be a single course of action shall be evaluated in the same environmental document. ii. IRG's three pending applications are similar applications that must be considered in a single environmental document. The stormwater and mitigation of all of the warehouses Pg. 5 of 24 — A, B and Greenline Business park — are interconnected and should be considered as one. c. Filling Wetlands under Federal State and Local regulations. Filling of wetlands under federal, state and local regulations is supposed to be limited to "water dependent uses." Wanting to fill wetlands for storage facilities and a business park, all of which can literally be situated anywhere, is counter to the intent of the Clean Water Act and state and local critical areas protection laws. d. Impervious Surface Imj2acts i. According to IRG's SEPA and IRG Consultant ESM, there are 63 wetlands; however, according to IRG's JARPA application and Talasaea, there are 57 wetlands. Accurate number of wetlands must be defined. ii. The project states that 0.421-acre (18,430 SF) of all or parts of 16 different wetlands will be directly impacted. There is no mention of what 24.1 percent of impervious surface and grading, with the significant amounts of cut and fill, will do to the surface flows and groundwater of the sensitive Hylebos system. (NOTE: the SEPA impervious checklist is wrongly listing impervious surface as 21 percent not 24.1 percent.). An EIS is required. e. Downstream Analysis i. There is no downstream analysis. The drainage study — Preliminary Technical Information Analysis Report — addressing Relevance of 9 Core and 5 Special Requirements of the 2016 King County Surface Water Design Manual (9/20/17) and ESM Consulting Engineers — only covers one -quarter mile downstream in their "offsite analysis," and it only covers surface flows, not groundwater that appears at the surface downstream in lower topography. Looking at one -quarter mile does not constitute a downstream analysis A downstream analysis greater than one -quarter mile is required. ii. The important aspects of the hydrograph that are known to affect the wetlands and streams and their associated vegetation and wildlife are the depth, duration and frequency of inundation. None of these aspects of the hydrology were examined for IRG's study. IRG's failure to address depth, duration and frequency of inundation in no way adds to our understanding of wetland and watershed delineation and the significance of the watershed to North Lake and the East Hylebos stream system. In-depth study of hydrological aspects, including depth, duration and frequency of inundation are required to understand impacts and mediation to wetland and streams and their associated vegetation and wildlife. iii. IRG's stormwater flows will take the Greenline Business Park's 32 acres of impervious surface and divert it solely as surface water flows through its stormwater drainage plan and the water will flow 'to' its natural areas. Because all storm water is being channeled into downstream flow, no storm water is being infiltrated into the groundwater — a natural area. Impacts need to be assessed. f. Groundwater IMpgas. Groundwater with regards to maintenance of streams and wetlands is not covered by any of the IRG studies. Groundwater removal is discussed in SEPA Checklist, but no mention is made of what will happen to the recharge of groundwater as a result of the 32 acres of building and the compaction of the till (required to make foundations for buildings and roads). Of concern is the fact that 32 acres of impervious surface will be collected and not infiltrated but instead discharged to the "downstream Hylebos system." Pg. 6 of 24 i. 32 acres of water, in addition to the huge amount of water being collected from Warehouse A and B and the associated parking and roads, will be added to the surface flows of the Hylebos system. Draining 32 acres of buildings into one 'natural area' (the Hylebos system) does not mimic the pre -development drainage pattern of that 32 acres. The Hylebos system has never historically carried this amount of flow. An EIS is needed to understand the surface flow stormwater flow and its im acts on the H lebos system J. IRG's response to SEPA Checklist question "Does the Proposal alter or otherwise effect drainage patterns in the vicinity of the site?" is: "No. Discharge will occur at the `natural location'." IRG has overlooked the fact that drainage is not just surface water. Dumping 32-acres worth of water into one 'natural drainage' (aka the East Hylebos) where it never was received in this vast amount before is a major issue. iii. Infiltration to groundwater and then discharge of groundwater at a lower elevation where it becomes surface water has not even been considered. There will be significant change in natural drainage patterns from pre -development conditions. iv. Water quality is the only treatment that IRG discusses. Again, water quantity and habitat need to be addressed. The JARPA asks, "Name each species listed under the federal Endangered Species Act that occurs in the vicinity of the project area or might be affected by the proposed work." IRG's answer is oriented toward water quality, with no mention of potential impacts from the change in hydrologic regime (both surface and ground water). It will be necessary to monitor any remaining wetlands pre -development and post -development to be sure the hydrologic regime is maintained. V. Groundwater is not discussed in the King County Surface Water Design Manual Report and the entire report for this project addresses the surface water and compliance with King County Surface Water Design manual. ESM does not consider groundwater in their stormwater modeling. The modeling must include infiltration, which is a critical part of designing stormwater to pre -development conditions. vi. Lakehaven Utilities' Capital Improvement plan includes a 2018 $320,000 water treatment project to upgrade Wellhead 10C, which is located on the east side of North Lake — close proximity to IRG's proposed Business Park project. Up until now, Lakehaven has only used Wellhead 10C to access water from the Eastern Upland Aquifer; however, with increased water demands, Lakehaven will be activating Wellhead 10C. Studies are needed to understand how IRG's plan not to infiltrate stormwater on the Greenline Business Park, Warehouse A and B will affect the Eastern Upland Aquifer. g. Wetland Delineations and Ratings i. The ratings of the wetlands seem low; however, this could be because of the methodology used to rate the wetlands. There is a significant amount of research that shows a wetland's importance has nothing to do with size. Research shows that 25-foot buffers are not viable as they do not protect the wetland function, which includes all of the following: water quality, water quantity and wildlife habitat. While we appreciate the efforts of city staff to follow the letter of the law, we need to ensure the best codes are in place to protect our environment. City code should protect water guality,water quantity and wildlife habitat and incorporate the state's wetland rating methodology which uses Best Available Science parameters. Pg. 7 of 24 ii. Wetland functions include protection of water quality, water quantity and wildlife habitat. IRG's plans only address water quality and not water quantity and habitat (wildlife and plant). h. Wetland and Buffer Mitigation i. The mitigation plan does not have hydrologic modeling for the created wetlands. A hydrologic regime should be proposed (with depth, duration, and frequency of inundation) and should be evaluated in the spring, summer and early fall; as well, determination that the proposed plants fit that regime or the amount of time of the water should be changed. None of this information has been provided, and with the tight timing of this proiect there is no way to ensure this design is appropriate before the Proposed approval and construction will occur. ii. The only wetland and buffer mitigation is for water quality — omits water quantity and vegetation and wildlife habitat. iii. The buffer enhancement design should also focus on enhancement of habitat —especially since so much existing habitat will be lost to concrete buildings and the wildlife that remains will need the remaining habitat to be high -quality. iv. The wetland and buffer mitigation does not include a planting plan or species list, no hydrologic modeling for the wetlands and no real details with which to evaluate if the wetland and buffer mitigation proposed is viable and will, in fact, replace the areas proposed to be impacted. V. A functional assessment stating the functional scores of the wetlands that are being impacted and what the design criteria for the replacement wetlands will be that will replace those scores at the same or higher level should be discussed in the report. It isn't feasible for the City and their third -party reviewers to evaluate this "plan" and approve permits by next month as the IRG proposed schedule states. vi. What are the temporary construction impacts to buffers of Wetlands AG, AV, DE and GB? Meeting code requirements requires application materials to show how the proposed temporary impacts meet the criteria for land surface modifications within setback areas under Section 22-1359(d) of 1994 Federal Way Code (FWC). vii. While the currently submitted Wetland and Buffer Mitigation plan is meant to be a conceptual mitigation plan, given the timing proposed for development by IRG, a much more detailed and final plan should have been submitted. Detailed performance standards and monitoring protocols matching those standards should have been included in this plan. viii. The five-year monitoring of the Wetland and Buffer Mitigation Plan is given to satisfy the City's requirements; however, the Army Corps and Department of Ecology will require 10 years of monitoring. ix. The plan should have included standards such as "x percent survival", "Y aerial coverage by woody species after years 3, 5, 7 and 10" and so on. Methods to evaluate these standards should have also been included in the report. i. Existing barriers to passage from Hi lebos Creek. Though there are existing barriers to passage from Hylebos Creek, this has not been investigated. The Washington Department of Fish and Wildlife (WDFW) should require a salmonid survey for resident fish prior to issuing a Hydraulic Pg. 8 of 24 Permit Approval (HPA) for the overall project (Greenline Business Park, Warehouse A and Warehouse B). The Temporary Erosion and Sediment Plan (TESC) should be verified and there should be an inspector on site whenever there is work being done near a water body to be sure erosion control measures are being implemented — especially at the southern end where the project dumps into the Hylebos system, where there are salmonids. 3) FORESTRY/EVALUATION OF TREES: a. The Concomitant Zoning Agreement (CZA), p. c-11 states "Provisions of the FWC relating to selection and spacing of plant material and identification of significant trees shall not apply in the CP-1 Zone." Yet the applicant, through the submission of the Gilles Consulting report Evaluation of Trees at Greenline Business Park, September 20, 2017, cites Federal Way Code (no code location referenced) definition of "Significant Trees" as healthy trees greater than 8 inches in diameter at 4.5 feet above the ground. Section 22-1568 FWC of 1994 defines significant trees as being 12 inches in diameter, which is not designated per the CZA and is different from the definition used in FWC 1994. b. In addition, the 1994 code above states that the purpose of identifying Significant Trees is to 1) establish standards to limit the removal of and ensure the replacement of trees sufficient to safeguard the ecological and aesthetic environment of a community, 2) discourage the unnecessary clearing and disturbance of land so as to preserve the natural and existing vegetation...". The applicant's documents do not make a case for 1) or 2) above. c. The Gilles report cited above has not submitted two plans which are critical to the evaluation of this application: 1. A Management Plan for the Managed Forest Buffer for the Greenline Business Park (CZA Page 3) and 2. A Tree Retention Plan (CZA Page 3). d. The methodology for accessing the number of trees to be removed by proposed development is poorly documented and inconsistent with standard forestry measurement procedures. Gilles cites the creation of a number of transects on the property (Gilles p. 3) and includes an aerial photo (Gilles p.10) which has some general squares marked on it with letters A-F, which when the squares are measured with the graphic scale included on the photo, are about 150 feet square or approximately one-half acre. No explanation was given as to how these square plots were located. The forestry definition of a transect is "a narrow sample strip or a measured line laid out through vegetation..." (Dictionary of Forestry, John A. Helms, editor, Society of American Foresters, 1998). By definition, a transect is not a square. e. Standard forestry measurement procedures updated in 2014 by the Northwest Certified Forestry Natural Resource Group & Stewardship Forestry "Forest Inventory and Monitoring Guidelines" outline the procedure for inventorying forest resources: "Inventory plots of a specific dimension are randomly located throughout a stand using a systematic sampling technique." (p.12). A stand (Helms above) in ecological terms is "a contiguous group of similar plants," which in this application is dominantly trees. The Gilles report does divide the subject property into contiguous groups and labels them in on page 11 (some labels appear without definition as HET Forest I and II) but no explanation of a systematic sampling rocedure is provided. Pg. 9 of 24 f. "Transect" square "A" straddles two vegetation types, Douglas Fir Forest and Douglas Fir Farm, which is inconsistent with standard forestry measurement procedures documented above. Furthermore no "transects" were placed in the major forest type of Mixed Coniferous Forest in the northwest corner of the application plat (Attachment 1) adjacent to Weyerhaeuser Way South. g. An analysis of the Tree Inventory/Condition Spreadsheets at the end of Gilles tree report reveals significantly different results from those summarized on page 6 of the report. A summary of the "Significant" trees on "transects" A-H (omitting F as it is only a partial "transect"), 460 trees are tallied for an average of 66 trees per "transect." Given that each of the square transects is about one half -acre (3-above), on a per -acre basis this would represent 132 significant trees (greater than 8 inches in diameter and of "F" (presumably fair, not defined) condition or better. That is significantly different than the "Average # of Significant Trees per acre" reported on page 6 of the Giles report of 28.64; 28.64 trees per acre equate to trees spaced on the average of 39 feet apart. h. Mr. Gilles presents references and identifies himself as a Consulting Arborist, not certified as a forester by the Society of American Foresters. The dictionary of forestry defines an arborist as "one who possesses the technical skills, through experience and related training, to care for individual trees and related woody plants in the residential, commercial and public landscape" and arboriculture as "the planting, care and scientific cultivation of trees and woody vegetation in a nonforest context..." Contrastingly a forester is defined as "a professional engaged in the science and profession of forestry" and forestry "the profession embracing the science, art, and practices of creating, managing, using, and conserving forests and associate resources for human benefit..." Forests as "an ecosystem characterized by more or less dense and extensive tree cover, often consisting of stands varying in characteristic such as species, composition, structure, age class, and associated processes, and commonly including meadows, streams, fish, and wildlife. The CZA (p. C-3) notes "That the purpose of the Managed Forest Buffer is to represent the character of a softwood forest at 50 years or more of maturity and to provide open meadows consistent with the present undeveloped area of the subject property" and "The property owner shall designate a qualified Forester whose responsibility shall be to maintain and preserve the Buffer." Under the Weyerhaeuser management of the property, a forester was in charge of managing not only the buffer, but the entire forest property during the time the CZA was legislated. Weyerhaeuser's approach to forest management in the 1990s is documented in a Forest History Today, Spring, Fall, 2009, article, "Weyerhaeuser Company and Sustained -yield Forestry" by Ted Nelson (pages 22-30). The Gilles report encompasses the Managed Forest Buffer (p. 6), but neither the documented qualifications of the author nor adherence to the development of a forest as specified in the CZA. 4) ZONING ISSUES: a. The City Should Change the Zoning Scheme for the Weyerhaeuser Pro ert . We understand that the City has taken the position that the Property is currently zoned Corporate Park 1 or CP-1, a zoning classification found only in the 1994 Concomitant Agreement between the City and the Property's former owner, Weyerhaeuser. By Ordinance No. 94-219, the City Pg. 10 of 24 annexed the Property, subject to the Zoning Designation Map and development provisions and standards set forth in the Concomitant Agreement. However, it is axiomatic that the City retained its police power as it relates to zoning even after signing the Agreement. City Staffs position that the zoning scheme set out in the Concomitant Agreement is intractable is contrary to long- standing Washington law.' While the Concomitant Agreement contains a provision stating the Agreement shall remain in full force and effect until terminated by mutual agreement of the parties, the City's performance obligations under the Agreement ceased once it codified by Ordinance the zoning schema and development regulations set out in the Agreement. The zoning and development regulations became law; law that can be changed by the City without repercussion in the same manner as the other portions of the FWRC may be revised. Although the City Council could have set a temporal limitation as to the binding nature of the Ordinance and development regulations — which is typical, and sets out an "adjustment period" during which time the City cannot modify the regulations to ease the transition — nothing in either provided for: The time interval following an annexation during which the ordinance or resolution adopting any such proposed regulation, or any part thereof, must remain in effect before it may be amended, supplemented or modified by subsequent ordinance or resolution adopted by the annexing city or town. See RCW 35A.14.330(4). Absent a temporal limitation, the Agreement does not (and cannot) extend forever. Stated differently, by adopting Ord No. 94-219 the City of Federal Way affirmatively did not agree to forever foreclose upon its ability to re -zone the parcel pursuant to its police power, nor to give up its rights to amend the development regulations applicable to the parcel.' Assuming the City Council anticipated the eventual sale of the property to multiple buyers and developers (as is the case here), it would have been ultra vires' for the City's legislative body to sign away its right to ever modify the zoning and development regulations of the property but for the acquiescence of the Property's owner(s). The Washington State Constitution provides the City with the police power to regulate for the protection of the public health, safety, morals and welfare. This is a nondelegable duty, and — if City Staffs position that the Concomitant Agreement requires the property owners' agreement to rezone — the City illegally contracted to restrict its ability to legislate and exercise its police powers forever. While other cities are fighting to preserve the delicate green and open spaces they have within their corporate limits, and passing regulations to preserve a tree canopy and the lakes and streams that pass through their boundaries, Federal Way is allowing developers to pave over mature forests and fill in wetlands. ' Zoning ordinances are not to be extended beyond clear scope of legislative intent as manifest in their language. Keller Y. Cfty of 13ellin ham 92 Wn.2d 726, 730, 600 P.2d 1276, 1279 (1979). 2 An ordinance of the City Council is presumed to mean exactly what it says, and those words are given their plain and ordinary meaning. See Ockerman v. King County Dept of Development and Environmental Services, 102 Wn. App. 212, 216, 6 P.3d 1214 (2000). 3 Ultra wires acts are those performed with no legal authority and are characterized as void on the basis that no power to act existed, even where proper procedural requirements are followed. Importantly, ultra vires acts cannot be validated by later ratification or events. Pg. 11 of 24 b. The project does not meet the goals and policy of the city's Comprehensive Plan Regarding the historic Weyerhaeuser campus, zoned CP-1, the Comprehensive Plan states that the city will "work with the seller, future owner(s), and the surrounding community to realize the property's potential, while maintaining compatibility with surrounding uses." (emphasis added) Stated goals are to "create office and corporate park development that is known regionally, nationally, and internationally for its design and function," (emphasis added) and "Work collaboratively to evaluate and realize the potential of the (former) Weyerhaeuser properties in East Campus." Policy LUP 49 states: "In the East Campus Corporate Park area, encourage quality development that will complement existing uses (emphasis added) and take advantage of good access to 1-5, Highway 18 and future light rail as well as proximity to the City Center." As it relates to this Project, we urge the City to consult legal counsel as to the zoning of the Property.a As a matter of long-standing Washington law, the City has a statutory right to regulate and control the use of the property — both primary and accessory uses — and may impose conditions upon the allowance of either a primary or accessory use. The preservation of the City's neighborhoods is a key value expressed in the City's Comprehensive Plan, the City's zoning code (FWRC 19.240.020), and is expressly echoed in Ord. No. 94-219 and the Concomitant Agreement. One of the goals of the City's Comprehensive Plan is to protect previously established residential areas by regulating those nearby commercial and industrial activities that may create offensive noise, vibration, smoke, dust odors, heat, glare, fire hazards, and other objectionable influences to those areas which are appropriate for those uses. This is echoed in the FWRC, which states: "[M]anufacturing, fabrication, preparation of food products, warehouse and wholesale distribution facilities," "may not be located on property that adjoins a low or medium density residential zone." FWRC 19.240.020. New ownership of the historic Weyerhaeuser campus means the property is no longer owned by a conscientious steward of the land. Instead, the property's owner intends to carve up the land, piecemeal, and believes the property is zoned for a warehouse distribution center. The City Council adopted the proposed zoning regulations, in large part, because: • "The proposed Concomitant Agreements will have a beneficial effect upon the community." • "Unusual environmental features of the site will be preserved, maintained and incorporated into the design to benefit the development in the community because the Subject Property has widely recognized natural features ranging from North Lake and Lake Killarney to the Weyerhaeuser Bonsai Collection and Rhododendron Garden which attracts visitors on an international scale. The Concomitant Agreement will provide property owners the means to preserve and protect these natural features as well as providing the City with the ability to ensure that all natural features are adequately protected." 4 As discussed above, we believe the Concomitant Agreement was ultra vires and therefor void. We urge the City to consult legal counsel on this point as well; if the Agreement is void, the consequences are substantial, including the possible reversal of the annexation. Pg. 12 of 24 e "The character of the Subject Property will be preserved under the Concomitant Agreement." Ord. 94-219, at 6(C). The proposed uses for the Property stated in the application do not comply with the plain language of the zoning regulations adopted by the City at Ord. No. 94-219, nor with the intent of the Concomitant Agreement. The agreement must be read in conjunction with the annexation ordinance, as well as council discussions at the time, and the intent of the Weyerhaeuser leadership — George Weyerhaeuser and Jack Creighton — who sought and formulated the agreement. Both men recently stated in letters provided to the city (attached) that a warehouse distribution center was not the intent of the Concomitant Agreement. Although allowed in the language of the Concomitant Agreement, warehousing was not intended as the major use for the entire campus. A warehouse distribution or manufacturing center does not complement the surrounding office park zones. 5) The Proposal Does Not Meet the Decisional Conditions Under FWRC 19.65.100(2)(a). We urge the City to deny the application for all of the aforementioned reasons. The following further analysis is offered to further encourage an outright denial of the application, as it meets none of the requisite elements set out in FWRC 19.65.100(2)(a). a. The proposed project is not consistent with the Federal Way Comprehensive Plan. This Project is decidedly inconsistent with the City's Comprehensive Plan in ways which necessitate the denial of the permit. The City needs to look no further than the plain language of the Comprehensive Plan, which values: • "Limiting growth outside the City Center to areas that are already urbanized." This proposal allows substantial growth outside the City Center, and in an area that is neither urbanized nor developed in any manner. O "Protecting environmentally sensitive areas." This proposal would destroy environmentally sensitive areas, including North Lake, wetlands on the Property, and the Hylebos watershed. While other cities (including Auburn and Tacoma) are expanding their critical area regulations and preserving their tree canopies, Federal Way would be destroying one of the few natural resources within our boundaries and creating an industrial park in its stead, which would be a blight on our environment and reputation. e "Retain open space, enhance recreational opportunities, conserve fish and wildlife habitat, increase access to natural resource lands and water, and develop parks and recreational facilities." Approval of this Project would directly contradict the City's goals of conservation and preservation of natural resources. More than 2,400 significant trees (in addition to the 1,500 on Warehouse A & B) are expected to be lost to construction of the Greenline Pg. 13 of 24 Business Park. Parts of the campus trail system used by the public for nearly 50 years will also be lost. a "Protect the environment and enhance the state's high quality of life, including air and water quality and the availability of water." As discussed below, this Project introduces exhaust from nearly 400 semi -truck trips per day (and the additional 200 from Warehouse A & 200 from Warehouse B), into our surrounding neighborhoods and Federal Way as a whole. This area features a prevailing south wind, which would dump these pollutants into our community. • "Identify and encourage the preservation of lands, sites, and structures that have historical or archaeological significance." The Washington State Department of Archaeology & Historic Preservation has issued a letter of determination (attached) that the former Weyerhaeuser corporate headquarters building is eligible for listing on the National Register of Historic Places. It also determined that the original 260-acre headquarters campus is likely eligible for national listing — a setting intentionally designed by renowned landscape architect Peter Walker to provide natural open vistas, while tucking the headquarters building, and later the Technology Center, into the trees to preserve views, buffer noise and create a peaceful environment. This historic campus has been declared "Most Endangered" by the Washington Trust for Historic Preservation and an at -risk landscape by The Cultural Landscape Foundation in Washington, D.C. Building a warehouse distribution center — of which the Greenline Business Park, as well as Warehouse A & B, would be a part — does nothing to preserve the architecturally and historically significant site, where a grove of the world's first cloned trees still thrive and George H.W. Bush visited as vice president. The city must require a complete historic and archaeological survey of the entire campus, including the Greenline Business Park property, which meets the requirements of the Washington State Department of Archaeology & Historic Preservation (which has previously requested this action). Further study must be required to determine the specific details as to the boundaries of a listing, as noted by the state DAHP in its determination letter. The construction of Greenline Business Park, with elimination of thousands of significant trees, will certainly have an aesthetic impact on this historic property. i "Create an attractive, welcoming and functional built environment." Greenline Business Park will do nothing to meet this requirement. The city must require a higher standard of design for all developments on the campus, as required by the Concomitant Agreement. Not only is the landscape of the Weyerhaeuser corporate building exhibited in many books, but landscape architectural students from all over the world visit this site as a model of how landscaping can enhance a building and the greater environment. It seems shortsighted to start destroying one of our few gems. The landscape was designed with the conviction that landscape can restore the human spirit. Erecting Greenline Business Park will do the opposite. Pg. 14 of 24 "Use development standards and design guidelines to maintain neighborhood character and ensure compatibility with surrounding uses." As stated above, a warehouse distribution center is not compatible with two nearby residential communities, gardens, museums, churches and schools and two quiet community lakes, where loud, polluting gas motors aren't even allowed. e A goal is to "Preserve and protect Federal Ways single-family neighborhoods." Traffic, pollution and noise from a warehouse distribution center will have negative impacts to the nearby North Lake neighborhood. As occurs in other warehousing districts in South King County, semi -trucks will park on nearby streets day and night, while drivers wait to pick up or deliver loads, and catch up on required rest periods. Since Weyerhaeuser Way can't accommodate truck parking, these trucks will park wherever they can find a space — whether it's in the adjoining office parks, or on narrow neighborhood streets around Lake Killarney to the south and North Lake to the east. These trucks will bring the potential of trash, air pollution and illegal activity. a A City policy is to "Protect residential areas from impacts of adjacent non-residential uses." "Ensure compatibility between non-residential developments and residential zones by regulating height, scale, setbacks, and buffers." The City must ensure that the Lake Killarney and North Lake residential communities are not negatively impacted by the introduction of warehouses and freight traffic adjacent to homes. Noise, light and exhaust pollution must be adequately addressed. • Require development to be compatible and well -integrated into its surroundings and adjacent zones through site and building design and development standards that reduce or eliminate land use conflicts and nuisance impacts; ensure project aesthetics; promote sharing of public facilities and services; and improve vehicular and pedestrian traffic flow and safety, including access control and off-street interconnectivity between adjoining properties where feasible. This goal is a perfect summation of our concerns: the design is inadequately integrated into in the campus and neighboring office and residential zones, and creates (rather than eliminates) land -use conflicts over our natural resources and substantial nuisance impacts from noise and pollutants. Moreover, it will damage (rather than improve) vehicular and pedestrian traffic flow and safety, by introducing semi -trucks into an area known for walkability. As a general matter, this Project will prevent the City from meeting its development and open space goals. By way of one example, the City has as an imperative goal the preservation of its tree canopy. The City notes the benefits in maintaining its urban tree canopy as: "[s]tabilizing and enriching soil; [i]mproving air and water quality; [p]rotecting fish and wildlife habitat; [r]educing the impacts of storm water runoff; and [m]itigating the heat island effect." These goals are destroyed by this Project. While Tacoma recently created its EverGreen Tacoma program to manage, protect and expand Tacoma's tree canopy from 19 Pg. 15 of 24 percent to 30 percent by 2030, Federal Way will garner notoriety as doing the opposite: forever destroying its existing tree canopy of forest. By way of another example, the City has goals for the diversity of uses of the land within the City's limits. Currently, 2 percent of the City's land is designated for industrial uses, with the remaining 98 percent divided among commercial, residential and other uses. The City's goals as it relates to this diversity include: ■ "Preservation of environmentally sensitive areas;" and even ■ "Well -designed commercial and office developments." Where our resources are limited, and the City recognizes undeveloped land is scarce, it has prioritized all other forms of development more vital to our community over expanded industry. This is echoed throughout the Comprehensive Plan. Building three large-scale warehouses, in addition to Warehouse A and Warehouse B — all part of a distribution center — turns that goal on its head, and should be rejected. b. The proposed project is not consistent with all applicable provisions of Title 19, Zoning and Development, of the FWRC. As stated throughout these comments, the City is taking the position that the applicable zoning and development regulations for this Project are found in the Concomitant Agreement. We believe the Concomitant Agreement is ultra vires and void. However, for the purposes of these comments, we will focus on the substantial and detrimental ways in which the application does not meet the zoning and development regulations set out in the Concomitant Agreement. First, the proposal ignores a myriad of requirements set out in the Concomitant Agreement. For example, while the Concomitant Agreement requires the preservation of trails, the Developer intends to destroy those trails and replace them with sidewalks. Similarly, the Concomitant Agreement requires that the proposed structure is of "superior quality." Although the developer has made efforts to add design elements to the Greenline Business Park (and its nearly identical neighboring Warehouse A & B), these are still concrete warehouses lacking the requisite architectural style to complement and blend with the historic, acclaimed headquarters building and integrated landscape. The provision requiring future development — including landscape, open spaces and buildings — to be of "superior quality" was inserted to ensure the campus maintained its cohesive, unified, award -winning appearance. The Concomitant Agreement requires management of the forested buffer pursuant to a plan developed by a qualified Forester. As we stated earlier, the developer has retained an arborist who states he is a member of the Society of American Foresters (membership is open to a variety of forestry -related professionals) but offers no proof of certification as a forester through the organization. The city must require a qualified, certified forester to manage these crucial buffers. Moreover, the Concomitant Agreement acknowledges that "[t]he property is a unique site, both in terms of its development capacity and natural features. Weyerhaeuser desires to develop its property with maximum flexibility which will insure optimal development, while preserving the unique natural features of the site." The Agreement makes clear the signatories' intent, made binding by their signature, that the trees, meadows, trails, pond, and generally natural setting of the property should be preserved to the Pg. 16 of 24 greatest extent possible. Recent letters from George Weyerhaeuser Jr., who commissioned the campus, and Jack Creighton, who signed the Concomitant Agreement, make clear their intent was never to build a complex of warehouses (see letters attached). The Developer has decided the property's highest use is to be paved over, made into a huge warehouse and distribution center, that if completed under the overall vision, would be visited by more than 800 (combined Greenline Business Park and Warehouses A & B) semi -trucks daily, clogging the roads, affecting thousands of Federal Way motorists and visitors, and invading the quiet residential neighborhoods, churches and schools in the immediate area. This proposed use is not in conformity with the Concomitant Agreement and should be rejected. Due, in part, to the stewardship of the former major landholder on North Lake, the dedicated residents with lakeside properties, along with the State of Washington and the City of Federal Way, the lake has an abundance of native wildlife and plant life, which includes returning protected species such as the Bald Eagle and Blue Heron. Hylebos Creek is a tributary and a sensitive habitat. Surrounding it with huge warehouses is in no way responsible or sensitive. This project will harm the wildlife habitat unique to this Property and sought to be preserved under the Concomitant Agreement. Again, while the City's Comprehensive Plan and the Concomitant Agreement speak to the preservation of our natural resources, this Project will help destroy one of this City's preeminent attributes. c. The proposed project would substantially and irrevocably injure public health, safety, and welfare. The noise and air pollution reports for this project are both based on general commodity warehousing. Both reports indicate insignificant increase levels of noise and air pollution compared to a 'no build' scenario. Neither report takes into consideration the worst -case scenario, which should include actual usage, cumulative high traffic volumes and significant tree loss. A detailed review of final operating conditions should be compiled to ensure that potential noise and air pollution are reflected accurately. As we stated in our earlier section about critical areas, we are concerned about wetlands and storm water runoff and loss of wildlife habitat caused by clear -cutting for the Greenline Business Park. The environmental impacts of the Greenline Business Park should be considered to be in addition to those of Warehouse A & B, and reviewed as cumulative. An environmental impact statement (EIS) should be required, as part of the larger development scheme on the entire campus, which acknowledges and analyzes the interconnection of North Lake, the wetlands on the Property and the Hylebos watershed. 1. Dangerous Freight Traffic. Greenline Business Park will add nearly 400 (on the low end) of semi -truck trips through the North Lake area, per day, and an additional 2,800 passenger vehicles onto our roadways each day. This is in addition to a somewhat higher amount of traffic from the nearby Warehouse B (200 semi -truck trips and 760 passenger vehicles) and Warehouse A (199 semi -truck trips and 795 passenger vehicles), which is expected to be permitted by the city soon. These projects cannot be looked at individually; the city must take a comprehensive approach to determining the traffic impacts not just to Weyerhaeuser Way, but to the already -congested routes accessing it — Interstate 5, South 320th Street and Highway 18. The North Lake area is a walkable community, already replete with motorists using neighborhood roads to circumvent the constant congestion at the Pg. 17 of 24 Highway 18/1-5 interchange. When considering the combined projects — Greenline Business Park, Warehouse A and Warehouse B — adding nearly 800 semi -trucks and more than 4,300 additional passenger vehicles to the area will substantially and negatively impact our safety and the flow of traffic. The City's own Bicycle and Pedestrian Master Plan indicates that a "[h]igh exposure to freight" creates an imminent safety concern to bicyclists and pedestrians. Similarly, the Comprehensive Plan laments fossil fuel pollution, while this Project will inject fossil fuel emissions directly into the neighborhoods adjoining this project. "The loss of land cover and vegetation to impervious surfaces, including buildings and pavement, also contributes to climate change —although not as significantly as the burning of fossil fuels." Comp Plan, at Ch. 2, p. II-3 Again, this Project will be a blight on the City's environment and its reputation. Beyond that, it will likely cause irreparable harm to the well-being and health of its citizenry. 2. Nuisance Noises Will Abound. The constant noise associated with the nearly 400 daily semi -truck trips (plus the additional 200 from the adjoining Warehouse A and 200 from Warehouse B) will likewise have auditory and non -auditory effects on our health, including but not limited to hypertension and psychological disorders (both linked with noise pollution by the best available science). The SEPA Checklist does not address impacts of threats to our community's health, safety and welfare, including: the introduction of dangerous semi -truck traffic and related pedestrian/vehicular conflicts within our existing single family neighborhoods; concerns regarding semi -truck speed limits; impact of 24/7 operational hours, including floodlighting and glare, constant noise (primarily from semi -truck traffic and overhead loading dock doors) and the substantial impacts of the Project during construction, including dust, debris, noise, and pollutants from heavy machinery. d. The streets and utilities in the area of the subject property are not adequate to serve the anticipated demand from the proposal. The proposed access to the subject property is not at the optimal location and configuration. Traffic safety impacts for all modes of transportation, both on and off site, are not adequately mitigated. The flow of traffic onto South 320th Street and then onto the Interstate 5 interchanges that are already overburdened and congested, has not been adequately addressed by the developer. Plans for two entrances serving 1.1 million square feet of warehouses, with 400 semi -trucks and 4,300 passenger vehicles, in close proximity to the Interstate 5/South 320th Street interchange, will create traffic tie-ups as semi -trucks queue up on 320th and the 1-5 ramps on their way to and from the property. Although the developer states truck traffic will access the site only from Weyerhaeuser Way, there is no guarantee — when traffic is tied up on surrounding highways, truckers will take alternate routes, including through residential neighborhoods. We have already seen this happening in the North Lake neighborhood, even without a warehouse in operation. The City must verify all the input, analysis, and conclusion of the traffic study, and require the developer to address these very real issues. Pg. 18 of 24 6) Conclusion and Recommendations. We encourage the City to reject the proposed Greenline Business Park, as it violates the City's Comprehensive Plan, and will irreparably harm the welfare, health and safety of Federal Way's citizens. To the extent the City is intent on approving Greenline Business Park, we offer the following further comments regarding ways in which the Developer can address some of the aforementioned concerns. By offering these comments we in no way waive our right to appeal the City's determination, and to pursue our other civil remedies as it relates to zoning of the Property. 1. The City should require the developer to prepare an environmental impact statement (EIS) for the entire campus, which acknowledges and analyzes the interconnection between North Lake, the wetlands on the Property and the Hylebos watershed. 2. The congestion of semi -trucks entering and exiting the facilities is likely to create substantial backups. Exiting trucks will often encroach on the median and opposite lane of travel. These safety concerns should be addressed, as well as requiring mitigation so that backups do not worsen the level of service of the Interstate 5/South 320th Street interchange, South 320th Street, the Highway 18/Weyerhaeuser Way interchange, associated freeway ramps and the freeways themselves. The cumulative impacts of traffic should be addressed, including from Greenline Business Park, Warehouses A and B, the DaVita project, and the Tech Center and the headquarters building when they are fully occupied. 3. Require the Developer retain a certified forester to design and manage the forested buffer, specified under "Section III. Minimum requirements" (CA). Since, at a minimum, the buffer is required along the perimeter of the CP-1 zone, we ask that the city go beyond the minimum and require a forested buffer along both sides of Weyerhaeuser Way adjacent to the business park project. This buffer should be 100 feet to capture more mature trees, or at least deep enough to screen the views the three Greenline Business Park warehouses from Weyerhaeuser Way. A tree buffer should remain along the western edge of the business park where the warehouses would be built, thus helping to protect the views from and to the award -winning headquarters building and helping somewhat to maintain the unique character of the campus and its natural features. At a bare minimum, require the Developer measure the 50-foot tree buffer from the start of the green space (not to include the sidewalk or any portion of the right of way), and plant additional trees to ensure the continuity of the buffer. Further, the forested buffer should be preserved in perpetuity, and neither the Developer nor the City shall be entitled to reduce the width of the buffer to allow for required street improvements for future development projects on the historic Weyerhaeuser campus. 4. Require, as a condition before approval, further study to determine the specific details as to the boundaries of a historic listing, as noted by the state DAHP in its determination letter as well as a complete survey of the entire campus (the entire CP-1 zone) for historic and archaeological assets. This work must be done in conjunction with, and meet the requirements of DAHP. This survey must be completed before any land -use permit is issued for Warehouse A, Warehouse B, or the Greenline Business Park, to provide a full picture of the site's historic and archaeological assets before any ground is broken. Pg. 19 of 24 5. Require the construction of a sound barrier of superior quality (i.e., state -of -the -art -technology) in compliance with the Concomitant Agreement, to protect the nearby residential communities. 6. Require natural fencing material as specified in the Concomitant Agreement. 7. Reduced construction hours for Project, to accommodate the nearby residential communities. 8. The design of the Greenline Business Park should be further revised to reflect the requirement that it be of "superior quality," consistent with the unique nature of the campus and its architecturally significant buildings. Require the developer to work with historical preservationists, architects and the community to create a structure that blends with and complements its surroundings. Future development at the former Weyerhaeuser site should build on and bolster the original campus design by use of integrated designs such as: • Rethinking the Entry: Focusing the main truck traffic along the western edge of the site (closer to the 1-5 corridor), to prioritize and preserve the natural setting and experience along North Lake. Trucks would access the site at the northern end, and a loop road inside the project area would provide access to all three warehouses, funneling trucks off Weyerhaeuser Way. • Reducing the Scale: Consider breaking the development into a series of `smaller' buildings that bear the benefit of future convertibility — 120-foot wide bars can become office, residential or retail. • Usingthe Easement: Stitching together non-invasive trails and activities through the easement could keep much of the warehouse impact away from the campus edge. • Reducing the Mass: Lower the height of the warehouses by sinking them into the ground to reduce the visual impact. • Screening the Mass: Require screens —either natural materials or artistic expression — that can dramatically change the perception and experience of a massive business park. ■ Making it Occupiable: Use the height of the warehouses as a green perch, providing the public a vertical park while the developer gets its industrial infrastructure. The Greenline Business Park is the next step in defacing the beautiful and historically important former Weyerhaeuser campus. The developer has stated they are not marketing warehouses, but have to plan for the worst -case scenario. If warehouses with massive amounts of semi -truck traffic are the worst case, then warehouses should not be proposed. Pg. 20 of 24 As we said in our comments on Warehouse A and Warehouse B, and are repeated again here in these comments for the Greenline Business Park, the residents of Federal Way deserve a development that carries the stewardship legacy of Weyerhaeuser into the future, that preserves the trails and forests they have enjoyed for nearly five decades — a development that protects and maintains the unique character of this special property, rather than inviting thousands of semi -trucks and massive concrete boxes to mar this gem forever. Regards, Save Weyerhaeuser Campus North Lake Improvement Club Lake Killarney Improvement Association Save Weyerhaeuser Campus Board Members: Lori Sechrist lasechrist@comcast.net President Mike Brown mbss09l789@gmail.com Vice President Lois Kutscha kutscha@comcast.net Secretary Craig Rice craig.rice6903I@grnail.com Treasurer Koorus Tahghighi koorust@yahoo.com Board Member Laurie Brown laurienbrown@yahoo.com Board Member Jean Parietti jmparietti@aol.com Board Member Debra Hanson dragonflycove@comcast.net Board Member Julie Cleary cleary4@comcast.net Board Member Tashawna Nash tnash@terramai.com Board Member Dick Pearson econoforester@msn.com Board Member Mary Aronen Mmcclellan2k@earthlink.net Board Member Cindy Flanagan camcalcin@hotmail.com Advisor Charlie Archer charlotte.a.archer@gmail.com Advisor Lake Killarney Improvement Association Board Members Norm Fiess Robert Johnson & Debbie Reece Debbie Caddell 3111 S 349th St 3704 S 348th St 35029 37th Ave S Federal Way 98003 Auburn, WA 98001 Auburn, WA 98001 Jim & Christine Devine Steve & Vicky Ransom Karen Smith 35106 30th Ave S 35316 28th Ave S 35205 34th Ave S Federal Way, WA 98003 Federal Way, WA, 98003 Auburn, WA 98001 J Pg. 21 of 24 North Lake Improvement Club Board Members: Lori Sechrist, President Julie Cleary, Treasurer Terry Thomas 32917 38th Ave S cleary4@comcast.net 33467 33rd Pl. S. Federal Way, WA 98001 Federal Way, WA 98001 lasechrist comcast.net terry@p!!wgroup.com Debra Hanson Mike Brown Simone Perry 32805 38th Ave S 3626 S 334th St 33030 38th Ave. So. Federal Way, WA 98001 Federal Way, WA 98001 Federal Way, WA 98001 draaonflvcove@comcast.net mbss09l789@gmaii.com info@time-in-a-box.com Tony Boddie Karen Langridge John Swaw 33461 33rd Pl. S. 33439 33rd Pl S 3636 S. 334" St. Federal Way, WA 98001 Federal Way, WA 98001 Federal Way, WA 98001 t boddie@yahoo.com KarenL63@comcast.net linex'ohn outlook.com Bill Eichholtz 33049 38th Ave S Federal Way, WA 98001 Bill.eichholtz hotmail.com NLIC Members at Large: Mary Aronen 33211 38th Ave S Federal Way, WA 98001 Wendy and Ron Beckerdite 33485 33rd Pl S Federal Way, WA 98001 Tony Boddie and Laurie Brown 33461 33rd Place S Federal Way, WA 98001 Sherry and Mike Brown 3626 S 334 St Federal Way, WA 98001 Jim and Jane Chastain 32849 38th Ave S Federal Way, WA 98001 Scott and Kim Clifton 33019 38th Ave S Federal Way, WA 98001 George and Claudia Curtis 33033 38th Ave S Federal Way, WA 98001 Jennifer Baker 602 Cedar St #3 San Carlos, CA 94070 Ross and Ardith Bentson 33009 38th Ave S Federal Way, WA 98001 Charlotte Booth and Bill Henry 33443 33rd Pl S Federal Way, WA 98001 Mike and Tina Callahan 3808 S 328th St Federal Way, WA 98001 Brian and Julie Cleary Federal Way, WA 98001 Doug and Cheryl Collins 1704 23rd Ave Milton, WA 98354 Bill Eichholtz 33049 38th Ave S Federal Way, WA 98001 Pg. 22 of 24 Jofree and Kelly Elred Bruce and Toni Findt 33619 33rd Pl S 32857 38th Ave S Federal Way, WA 98001 Federal Way, WA 98001 Larry and Marie Flesher Mike and Karen Fobes 33223 38th Ave S 4715 S 352nd St Federal Way, WA 98001 Auburn, WA 98001 David Fulford Jerry and Jane Graham 33415 33rd Pl S 32829 38th Ave S Federal Way, WA 98001 Federal Way, WA 98001 Debra Hansen and Don Walls Roger and Karen Hazzard 32805 38th Ave S 3610 S 334 St Federal Way, WA 98001 Federal Way, WA 98001 Kris Holden and Hal Russell Wendy and Brian Honey 33411 33rd Pl S 3800 S 328th St Federal Way, WA 98001 Federal Way, WA 98001 Charlene Hudon Melodie Hurst 10721 28th Ave SW 3318 S 334th Seattle, WA 98145 Federal Way, WA 98001 John Thorburn & Paula Wilson Chris and Patty Johnson 33449 33rd Pl. S. 33403 33rd Pl S Federal Way, WA 98001 Federal Way, WA 98001 Bill Jones Theresa Jovanovich PO Box 4471 33409 33rd Pl S Federal Way, WA 98063 Federal Way, WA 98001 Dorothea King Wayne and Nancy Kiser 111 D. White Birch Pl. 33012 38th Ave S Cashmere, WA 98001 Federal Way, WA 98001 Constance Klick Norm and Lois Kutscha 33421 33rd Pl S 33021 38th Ave S Federal Way, WA 98001 Federal Way, WA 98001 Karen Langridge Kelly and Cherisse LeProwse 33439 33rd Pl S 3632 S 334th St. Federal Way, WA 98001 Federal Way, WA 98001 Marsi Lowrie Daryl Miller and Lisa Dotson 33057 38th Ave S PO Box 3185 Federal Way, WA 98001 Kent, WA 98089 Pg. 23 of 24 Gary and Anne Mingus Tim Mironyk 33603 33rd PI S 3815 S. 328th St. Federal Way, WA 98001 Federal Way, WA 98001 Darron and Tashawna Nash Lynn Naumann 3300 S 334th St 32811 38th Ave S Federal Way, WA 98001 Federal Way, WA 98001 Margaret Nieuwhof John and Judy Olano 33453 33rd PI S 33435 33rd Pl. So. Federal Way, WA 98001 Federal Way, WA 98001 SK Panda Jean Parietti and Will Self 3312 S. 334th St. 33256 38th Ave S Federal Way, WA 98001 Federal Way, WA 98001 James and Simone Perry Richard and Gail Pierson 33030 38th Ave S 3516 S 336th St Federal Way, WA 98001 Federal Way, WA 98001 Lloyd and Carol Qually Brett and Diane Radford 3328 S. 334th St. 32837 37th Ave S Federal Way, WA 98001 Federal Way, WA 98001 Dan and Lori Sechrist Paul, Gina and Nick Schmidt 32817 38th Ave S 33050 38th Ave S Federal Way, WA 98001 Federal Way, WA 98001 John & Kathy Swaw Dennis and Wendy Sundstrom 3636 S. 334th St. 3809 S 325th St Federal Way, WA 98001 Federal Way, WA 98001 Koorus Tahghigi Terry and Sandy Thomas 33206 38th Ave S 33467 33rd Pl S Federal Way, WA 98001 Federal Way, WA 98001 Mike Trout Jana VanAmburg 3118 S. 337th St. 33453 33rd PI S Federal Way, WA 98001 Federal Way, WA 98001 Randy and Tracy Westbrook Larry Zimnisky, Sr. 3806 S 328th St 33625 33rd PI S Federal Way, WA 98001 Federal Way, WA 98001 Dave & Valerie Danforth Gary Heil 3718 S. 334t' St. 32802 38t' Ave. S. Federal Way, WA 98001 Federal Way, WA 98001 Pg. 24 of 24 GEORGE H. W=RHAEUSER P.O. Box 1278 - TACOMA, WASHINGTON 98401-1278 TELEPHONE: (253) 272-8336 October 26, 2016 Mayor Tim Ferrell Federal Way City Council Members i 33325 Eighth Avenue South Federal Way; WA 98003 Dear Mayor Ferrell and City Council Members, colpy I was surprised and concerned when I recently learned about proposals to build a fish -processing; factory and warehouses on the former Weyerhaeuser Company campus. In developing the property for Weyerhaeuser's world headquarters in the late 1960s, I never imagined it would be used for industrial development or large warehouses. Instead, my vision was to create a campus that took advantage of the site's natural merits, with forests and meadows to shelter wildlife, provide scenic vistas and include walking trails so the natural environment could be enjoyed by employees as well as community members. Aside from the headquarters building, structures were to be screened with timber, as was done with the Technology Center. Any future buildings were envisioned to be much smaller than that and also screened by trees. I don't know how ypu have reached this point, where you are faced with changing the appearance of the campus forever. But I urge you to consider the following - When I was CEO of Weyerhaeuser, one of our company policies spoke to recreation vs. economics on our lands: Sometimes the recreational value exceeds the value of any other land use, and sites with historic interest should be preserved for the public to enjoy. And as I once told an interviewer, it's important to consider that major developments will alter things permanently. When the change involves a unique asset, you must carefully weigh whether economic progress is worth what will be lost. So, I am asking you to work with the new owners to preserve the low -density, open -space character of this campus and to protect its unique features for the community, as was agreed upon when Weyerhaeuser joined the city in 1994. SiincArely yours, ; George H. eyedmuser June 3, 2018 Mr. Jim Harris Department of Community Development 33325 811 Ave. S. Federal Way, WA 98003 Dear Mr. Harris: In response to the posting application for the Greenline Business Park Master Land Use Application of November 14, 2017, 1 submit the following as a retired forest economist currently managing forest properties in Washington, Arkansas, Minnesota and New Zealand and board member of Save Weyerhaeuser Campus. 1-The Concomitant Zoning Agreement (CZA), p. C-11 states "Provisions of the FWC relating to selection and spacing of plant material and identification of significant trees shall not apply in the CP-1 Zone." Yet the applicant through the submission of the Gilles Consulting report Evaluation of Trees at Greenline Business Park, September 20, 2017 (Gilles Report) cites Federal Way Code (no code location referenced) definition of "Significant Trees" as healthy trees greater than eight inches in diameter at 4.5 feet above the ground. Section 22-1568 FWC of 1994 defines significant trees as being 12 inches in diameter which is not designated per the CZA and different from the definition used in FWC 1994. In addition the 1994 code above states that the purpose of identifying Significant Trees is to " 2) establish standards to limit the removal of and ensure the replacement of trees sufficient to safeguard the ecological and aesthetic environment of a community, 3) discourage the unnecessary clearing and disturbance of land so as to preserve the natural and existing vegetation. The applicant's documents do not make a case for 2) or 3) above and the reason for defining "Significant Trees" greater than eight inches in diameter is not documented. 2- The Gilles report cited above, lacks two plans which are critical to the evaluation of this application and are not part of the city of Federal Way "official project file" web site as of this date: 1. A Management Plan for the Managed Forest Buffer for the Greenline Business Park (Page 3) and, 2. A Tree Retention Plan (Page 3). 3- The methodology for quantifying the number of trees to be removed by proposed development is poorly documented and inconsistent with forestry measurement procedures. Gilles cites the creation of a number of "transects" on the property (p. 3) and includes an aerial photo (p.10) which has squares marked on it with letters A-F. The squares measured with the graphic scale included on the photo are about 150 feet square or approximately one half acre. No explanation was given as to how these square plots were located. The forestry definition of a transect is "a narrow sample strip or a measured line laid out through vegetation..." (Dictionary of Forestry, John A. Helms, editor, Society of American Foresters, 1998). By definition a transect is not a square. Forestry measurement procedures updated in 2014 by the Northwest Certified Forestry Natural Resource Group & Stewardship Forestry "Forest Inventory and Monitoring Guidelines" outline the procedure for inventorying forest resources: "Inventory plots of a specific dimension are randomly located throughout a stand using a systematic sampling technique." (p. 12). A stand (Helms above) in ecological terms is "a contiguous group of similar plants" which in this application are dominantly trees. The Gilles report does divide the subject property into contiguous groups and labels them in on page 11 (although some labels appear without definition as HET Forest I and II) but no explanation of a systematic sampling procedure is provided. "Transect" square "A" straddles two vegetation types, Douglas Fir Forest and Douglas Fir Farm which is inconsistent with forestry measurement procedures documented above. Furthermore no "transects" were placed in the major forest type of Mixed Coniferous Forest in the Northwest corner of the application plat (Attachment 1) adjacent to Weyerhaeuser Way South. 4-An analysis of the Tree Inventory/Condition Spreadsheets at the end of Gilles report reveal significantly different results from those summarized on page 6 of the report. The sum of the "Significant" trees on "transects" A-H (omitting F as it is only a partial square) is 460 trees for an average of 66 trees per square ("transect"). Given that each of the square ("transects") is one half acre (3-above), on a per acre basis this would represent 132 significant trees (greater than eight inches in diameter and of "F" (presumably fair, not defined) condition or better. That is significantly different than the "Average # of Significant Trees per acre" reported on page 6 of the Giles report of 28.64. 28.64 trees per acre equate to trees spaced on the average of thirty nine feet apart. In addition the Gilles report includes V of Significant Trees in the Managed Forest Buffer" (p. 6) in the "TREE COUNT AND RETENTION AT GREENLINE BUSINESS PARK" table but does not document the procedure for estimating the number of trees in the Managed Forest Buffer. 5-1 find no reference or know of any FWCC or CZA reference which supports the following sentence "If there is a bank of Significant Trees somewhere else on the property they can be switched out with a tree or more that needs to be removed unexpectedly." (Giles Report, p. 6) 6- The CZA (p. C-3) notes "The that the purpose of the Managed Forest Buffer is to represent the character of a softwood forest at 50 years or more of maturity and to provide open meadows consistent with the present undeveloped area of the subject property." Under the Weyerhaeuser management of the property a forester was in charge of managing not only the buffer but the entire forest. Weyerhaeuser's approach to forest management in the 1990's is documented in Forest History Today, Spring, Fall, 2009 pages 22-30 article "Weyerhaeuser Company and Sustained - yield Forestry" by Ted Nelson. 7- The CZA (p.C-3) states that "The property owner shall designate a qualified Forester whose responsibility shall be to maintain and preserve the Buffer." In addition the CZA (p.C-11) states that "Selection and installation of plant material in all forested areas shall be the responsibility of the designated Forester." Mr. Gilles presents references and identifies himself as a Consulting Arborist and not certified as a forester by the Society of American Foresters or other state forester certification. The dictionary cited in 3-above defines an arborist as "one who possesses the technical skills, through experience and related training, to care for individual trees and related woody plants in the residential, commercial and public landscape" and arboriculture as "the planting, care and scientific cultivation of trees and woody vegetation in a nonforest context... "(p.9). Contrastingly a forester is defined as "a professional engaged in the science and profession of forestry" and forestry "the profession embracing the science, art, and practices of creating, managing, using, and conserving forests and associate resources for human benefit..." Forests are defined as "an ecosystem characterized by more or less dense and extensive tree cover, often consisting of stands varying in characteristic such as species, composition, structure, age class, and associated processes, and commonly including meadows, streams, fish, and wildlife" (p. 70). The CZA requires a forester to manage the forests comprehensively on this property and not by an arborist in a "nonforest" context (definition above). It seems to me that by not using a forester the current owners are acting inconsistently with the 1994 CZA. Respectfully submitted, ficahard Pierson 3516 South 3361" Street Federal Way, WA 98001 d (-,- ii h P ppoteot the post, Shope the lusure ML *11 October 31, 2017 Ms. Jean Parietti Save Weyerhaeuser Campus Federal Way, WA In future correspondence please refer to: Project Tracking Code: 2016-08-06001 Property: Weyerhaeuser Headquarters Re: DOE Dear Ms. Parietti Allyson Brooks Ph.D., Director State Historic Preservation Officer Thank you for contacting the Department of Archaeology and Historic Preservation (DAHP) regarding the Weyerhaeuser Headquarters in Federal Way. Per your request I have reviewed the building for its eligibility for listing on National Register of Historic Places. While not yet 50 years old the Weyerhaeuser Headquarters would easily qualify for listing on the National Register of Historic Places (under criteria A & C) as a ground breaking design that has been studied by generations of architects, architectural historians, landscape architects and historians. In fact, the project's architectural achievements were acknowledged shortly after its completion when it received a 1972 National Honor Award from the American Institute of Architects (AIA); a distinction bestowed upon only the most respected architectural designs in the country. Thirty years later, recognizing the importance of the building, in 2001 the project received the AIA's Twenty-five YearAward, an honor that showcases buildings that set an architectural/design precedent. The project as a whole was a collaboration of the work of a virtual who's who of top-notch mid- century design firms including: the New York architectural firm of Skidmore Owings and Merrill (San Francisco Office, Edward C. Bassett, principle -in -charge) and the landscape architecture firm of Sasaki, Walker and Associates (Peter Walker, partner -in -charge). Other important collaborators included landscape architect Richard A. Vignolo (roof garden); landscape architect William Callaway (Sethar Memorial Garden); landscape architect Thomas L. Berger Associations (Pacific Rim Bonsai Collection); and space planners Sidney Rogers Associates. Completed in 1971, the 300,000 sq ft., $15 million dollar building housed nearly 900 managerial and administrative employees, including the company's executive group. The building used an open office landscape with furniture, dividers, and planters, rather than walls separating work areas. At the time of construction it was the first major corporate headquarters building in the United States to utilize this open office landscape treatment. Further innovations were found at the exterior walls of plate glass, which were cemented into single units with no vertical framing, providing the longest uninterrupted spans of glass exterior walls in the world at the time of construction. Custom office furniture, design by SOM and Knoll International of New York and then manufactured at Weyerhaeuser's Marshfield, Wisconsin hardwood plant. srnre ate. State of Washington • Department of Archaeology L Historic Preservation o • y. P.O. Box48343 • Olympia, Washington 98504-8343 • (360) 586-3065 www.dahp.wa.gov T ,� Specific details as to the boundaries of a listing would need to be defined after further study but most likely includes the full 260 acres as initially developed by Sasaki, Walker & Associates. In such a document various landscape elements and character defining features would be called out as contributing or non-contributing elements. The design firms were deliberate in their approach. They wanted the buildings to merge seamlessly into the landscape. Such elements included parking lot terraces which are found on each level of the building with its pedestrian circulation defined by formal rows of sycamore trees that contrasted with the indigenous forest beyond. The steep banks and building tiers were planted with English ivy. The clipped beds of ivy and carefully maintained lawns transition to plantings of ferns and rhododendrons and then to dogwoods and vine maples, all specifically planed out by the team. The surrounding forest was then purposefully sculpted, removing underbrush and creating woodland trails for the enjoyment of employees. We would welcome a National Register application for the building anytime. However keep in mind that per federal regulations, National Register listing requires owner consent. Thank you for the opportunity to review and comment. Should you have any questions, please feel free to contact me. Sincerely, Michael Houser State Architectural Historian (360) 586-3076 Michael. Houseradah .wa.4ov CC: Chris Moore, WA Trust for HP Eugenia Woo, Historic Seattle Stacey Welsh, City of Federal Way Jim Harris, City of Federal Way STATg State of Washington • Department of Archaeology & Historic Preservation P.O. Box 48343 • Olympia, Washington 98504-8343 • (360) 586-3065 www.dahp.wa_gov ARAMBURU & Eusus, LLP Attorneys at Law J. Richard Aranburu rick@aramburu-eustis.com Jeffrey M. Eustis eustis@aramburu,eustis.com May 29, 2018 City of Federal Way 33325 8th Ave. S. Federal Way, WA 98003 Attn: Brian Davis, Director Department of Community Development And Jim Harris Planner 720 Third Avenue, Suite 2000 Seattle, WA 98104 Tel 206.625.9515 Fax 206,682.1376 www.aramburu-eustis.com Via Email: Brian. Davis@cityoffederalway.com Jim.Hards@cityoffederalway.com Re: Greenline Business Park Application (File #17-105491); Proposals for Warehouse A (#16-102947-00-UP, 16-102948-00-SE) and Warehouse B (#17-104236-UP, 17-104237-SE). Dear City of Federal Way: This office represents Save Weyerhaeuser Campus, a Washington nonprofit corporation organized and existing to protect and preserve the community and natural values of the Weyerhaeuser Campus. On May 14, 2018, the City of Federal Way determined that the application for the Greenline Business Park (GBP) was complete. That proposal, made by Industrial Realty Group of Los Angeles (IRG), includes the construction of three buildings totaling approximately 1,068,000 square feet on a parcel of 146 acres and revisions to an existing parking lot adding 806 parking stalls, which will involve, among other activities, filling wetland and improving existing roads in the vicinity. On May 18, 2018, the City issued a Notice of Master Land Use Application, initiating a fourteen day comment period. The Notice indicates that the proposal will be reviewed under the "Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement" (CA), which places the property in the CP-I zone created by the CA. Previously, FRG submitted complete applications for two other construction projects also located in the CP-1, Warehouses A and B. Warehouse A is a 225,950 square foot warehouse building on 13.7 acres with 245 parking stalls; Warehouse B is a 217,300 June 4, 2018 Page 2 square foot warehouse building with 244 parking spaces immediately adjacent to Warehouse A. The Warehouse A/B proposals will use a common access road and the same stormwater detention pond. These two projects are owned by the same applicant as for the Greenline Business Park. The City has not issued a threshold determination under SEPA for either of IRG's Warehouse proposals. In this letter, SWC provides comment on the rules, regulations and standards applicable to the pending permit applications. First, any review of the business park proposal under both current zoning and the State Environmental Policy Act (SEPA) must consider the consolidated and cumulative impacts of all three pending proposals and cannot proceed with separate, individual, fragmented review. Second, the existing rules and regulations, including the CA, cannot be read to vest applications to rules and standards adopted twenty-four years ago. In several specific areas, the City should apply current standards and regulations adopted after Ordinance 94-219 (including the CA and its zoning) was adopted in 1994. These issues will be addressed below. 1. THE CITY MUST CONDUCT COMBINED AND CONSOLIDATED REVIEW OF THE THREE PENDING PROPOSALS. 1.1. SEPA REVIEW. Because of the background of this proposal, the City is required to conduct consolidated land use and environmental review of the pending applications, not segmenting or bifurcating review. This is based on the following. A. ONE OWNER. The entire 426-acre Weyerhaeuser Campus was purchased in 2016 by IRG, a California developer of warehouses and business parks. B. THREE CURRENTLY PENDING APPLICATIONS. IRG has filed applications for use of significant portions of the Weyerhaeuser Campus, including the GBPark, Warehouse A and Warehouse B, which have all been deemed complete by the City. These three applications will be referenced herein as the "IRG Applications." Each of the applications is currently pending and no threshold determination has been issued for any of them. Comments on the GBP are due on June 4, 2018. C. SAME ZONE FOR ALL PARCELS. The IRG Applications are all in the CP-1 zone. That zone is only applicable to the Weyerhaeuser Campus parcels and not to any other properties in the city. D. UNDER SEPA, THE THREE PENDING APPLICATIONS MUST BE CONSIDERED IN A SINGLE ENVIRONMENTAL DOCUMENT. The City of Federal Way has adopted by reference most of the Washington State SEPA Rules, WAC Chapter 197-11, into Federal Way's code in FWC 14.05.020. June 4, 2018 Page 3 Included in this adoption is WAC 197-11-060, including Subsection (b). This section provides as follows: (b) Proposals or parts of proposals that are related to each other closely enough to be, in effect, a single course of action shall be evaluated in the same environmental document. (Phased review is allowed under subsection (5).) Proposals or parts of proposals are closely related, and they shall be discussed in the same environmental document, if they: (i) Cannot or will not proceed unless the other proposals (or parts of proposals) are implemented simultaneously with them; or (ii) Are interdependent parts of a larger proposal and depend on the larger proposal as their justification or for their implementation. In addition, WAC 197-11-060(c) provides as follows: (c) (Optional) Agencies may wish to analyze "similar actions" in a single environmental document. (i) Proposals are similar if, when viewed with other reasonably foreseeable actions, they have common aspects that provide a basis for evaluating their environmental consequences together, such as common timing, types of impacts, alternatives, or geography. This section does not require agencies or applicants to analyze similar actions in a single environmental document or require applicants to prepare environmental documents on proposals other than their own. (ii) When preparing environmental documents on similar actions, agencies may find it useful to define the proposals in one of the following ways: (A) Geographically, which may include actions occurring in the same general location, such as a body of water, region, or metropolitan area; or (B) generically, which may include actions which have relevant similarities, such as common timing, impacts, alternatives, methods of implementation, environmental media, or subject matter. These provisions were considered in Indian Trail Property Owner's Assn v. City of Spokane, 76 Wn.App. 430', 886 P.2d 209 (1994). There a shopping center redevelopment and expansion were under review, including a large grocery store and other features. However, two parts of the overall proposal were not included in the original environmental checklist and threshold determination, a car wash and large underground storage tanks, and were proposed for later environmental review. On a challenge to this segmented environmental review, the Court of Appeals said as follows: Cumulative Effects. We note at the onset that the responsible official's initial evaluation of the underground fuel storage tanks separate from other phases of the proposal was in error. Parts of proposals which are "related to each other June 4, 2018 Page 4 closely enough to be, in effect, a single course of action shall be evaluated in the same environmental document." WAC 197-11-060(3)(b). Here, a phased review of the project was clearly inappropriate because it would serve only to avoid discussion of cumulative impacts. WAC 197-11-060(5)(d)(ii). See also WAC 197- 11-060(3)(b). However, the error was cured when the original MDNS and DNS were withdrawn, and the cumulative effects of the entire project considered before a new MDNS was issued. Redevelopment of the shopping district also included plans for a car wash. In 131 zones, a car wash requires a special permit. When addressing neighborhood concerns about the noise impacts from the car wash, the hearing examiner responded "there is no car wash in this application and a special permit must be applied for before a car wash can be built in conjunction with this use". To the extent the hearing examiner was approving separate SEPA review for the car wash, he was in error. WAC 197-11-060(3)(b). However, the error was harmless because the responsible official considered the impact of the car wash when making the threshold determination and required mitigation measures for it. 76 Wn.App. at 443. As noted above, the IRG Applications have a common owner (IRG), common timing (all have complete pending applications), common geography (all on the Weyerhaeuser Campus), common impacts and common zoning (CP-1, applicable only to this property). The most significant impacts of the combined proposals affect traffic and transportation, with significant impacts to off -site city roads and state highways including 1-5 and SR 18. Complete and accurate traffic and transportation analysis should include not only the three current proposals, but an accurate analysis for the future use of the Weyerhaeuser Headquarters building (more than 300,000 square feet), which is currently offered for lease by IRG to a single tenant. Currently, the traffic report for Warehouse A, for example, does not include potential traffic from Warehouse B, the GBP, or the Weyerhaeuser headquarters building. The projects, individually and cumulatively, will also impact downstream water resources, including the Hylebos stream, Milton's East Hylebos Ravine, Fife's Lower Hylebos Nature Park and associated wetlands and habitat. The GBP proposal alone will total 1,441,000 square feet of impervious surface. Under the applicable regulations and caselaw, it would be error for the City to conduct separate environmental review for IRG's proposals. The City should require IRG to submit an environmental checklist that includes the cumulative impact of all three projects. There appears to be little question that a proposal with more than 2,000,000 square feet of structure and other impervious surfaces will have a significant impact on the environment and accordingly requires an environmental impact statement (EIS). June 4, 2018 Page 5 1.2. LAND USE REVIEW. In addition, the three development proposals are included within the "Corporate Park 1" or "CP-1" zone, which was adopted by the City in Ordinance 94-219 as a part of the annexation of this and other nearby property in 1994. The CP-1 zone only applies to the former Weyerhaeuser Campus. Ordinance 94-219 also reached certain "Conclusions of Law," beginning at page 4; these Conclusions applied to the entire annexation area, including the property where the three pending proposals are located. Conclusion B states that the property, as a whole, has "unusual environmental features" and that the ordinance is the "means to preserve and protect these natural features," again referencing the entire annexation area. Conclusion C states that "any development in the corporate headquarters area is low density characterized by large expanses of open space." The applicant contends that the 1994 CA controls development on the Weyerhaeuser Campus. While that is not entirely correct, as pointed out below, it is apparent that the CA requires that the entire site be considered when development proposals are made. For example, under Paragraph 14.2 of the CA, existing streets had "been constructed to meet capacity needs for on - site development up to an additional 300,000 square feet of Corporate Office Park development;" this provision regarding street capacity is applicable to the entire site. The CP-1 zone found at Exhibit C to the CA also stresses that the entire site is to be considered together in review and analysis. The CP-1 zone states its Purpose and Objectives, saying that the properties in the zone: ...are characterized by large contiguous sites with landscape, open space amenities, and buildings of superior quality. The property appropriate for such uses is unique, and demands for such uses are rare. Consequently special land use and site regulations are appropriate for such properties. CP-1 Zone, page C-1. Subsection A states "This property is subject to its own unique standards of review processes as set forth in the Agreement." Id. The same is true of provisions for "Off -Street Parking" found in Exhibit C, in Section XIII at page C-18, that although new development shall require compliance with applicable off-street parking requirements: the aggregate of all proposed and existing uses on the property may, subject to the approval of the Director, be considered as a whole in establishing the minimum number of vehicles spaces required, .. . It is wholly inconsistent with the CP-1 zoning, and the background of the CA and Ordinance 94-219, to separately consider individual projects when the City recognizes that the proposals are located on a unique property. This is especially true when IRG, the property owner, has three complete and pending applications to use substantially all of the CP-1 zoned area. Based on the foregoing, it is apparent that since 1994 the City has considered the Weyerhaeuser Campus unique and has adopted unique standards June 4, 2018 Page 6 of review applicable to the entire site. Site development, by a common property owner, must be considered as a consolidated whole for permitting purposes. 2. THE CITY IS REQUIRED TO APPLY CURRENT CODES AND STANDARDS, NOT THOSE IN EFFECT IN 1994. As noted above, Ordinance 94-219 is now twenty-four years old, but the applicant for the three pending projects claims that the ordinance, and the CA, vest these new proposals to rules, regulations and standards in effect when the ordinance was adopted. The City should reject that proposition and apply current adopted standards.' The applicant seeks to apply certain provisions of the CA to its current land use applications. Among others, the applicant asks the City to follow certain criteria in review of its proposals, including the following provisions of the development agreement that are contrary to codes. 1) The agreement "not to require any dedication or conveyance of the Property or any portions thereof for public purposes .... Paragraph 12, page 10. 2) Agreement to consider roads adequate for the addition of 300,000 square feet of new Corporate Office Park development that might be located anywhere on the site. Paragraph 14.2, page 11. 3) Agreement that the property owners "shall be vested for purposes of roadway capacity requirements and any concurrency requirements and Weyerhaeuser shall not be required for pay for any new public streets within the Property area or traffic mitigation fees for these streets in connection with the Additional Development. Paragraph 14.2, page 11, Paragraph 15, page 13. 4) Agreement that areas of the Property which are "classified as environmentally sensitive" shall comply with the critical areas ordinance in effect in 1994, except for special provisions found at pages C-12 to C-18. Exhibit C to Ordinance 94-219, Section XII. Washington law is clear that no city may establish fixed land use and development regulations that cannot be ever modified or changed. As described above the City should consider IRG's three pending proposals together as a single application following evaluation of the whole proposal under SEPA. June 4, 2018 Page 7 A) Washington Law Prohibits One Legislative Body from Binding Future Councils. The effect of the CA as interpreted by the applicant is that no later rules, regulations, legislation or council action can modify the agreement; it is permanent and never capable of modification. This concept is not consistent with Washington law for the following reasons. Under settled Washington law, a municipality "cannot enter into contracts binding on future boards of commissioners." See State ex. rel. Schlarb v. Smith, 19 Wn.2d 109, 112, 141 P.2d 651 (1943). See also Miller v. City of Port Angeles, 38 Wn.App. 904 (1984) where it is recognized that a local government cannot contract away its police power. It is recognized that this rule must be construed in the context of whether the contract involves its legislature function or its administrative/proprietary function. This issue was considered in some detail in AGO 2012, No. 4, which concluded as follows: If a contract impairs the "core" legislative discretion, eliminating or substantially reducing the discretion future bodies might exercise, the courts are likely to find that the contract has improperly impaired the legislative authority of future commissioners." Moreover, the CA permits deviations from the current city standards. For example, at Paragraphs 14.2 and 15, the CA prohibits the city from collecting impact fees for an additional 300,000 square feet of corporate office development, an indulgence not permitted under existing codes. Similarly, Section XII of the CP-1 zoning allowed deviations from even the then -existing sensitive area ordinances, making it inconsistent with those codes. Indeed, Paragraph 4.1 of the CA (page 5) specifically provides that "to the extent Federal Way policies impose development standards conflicting with this Agreement, this Agreement shall control." Accordingly, the CA, which is claimed to bind all Federal Way councils forever, is ultra vires. It is also important to note that the CA in question is different from contract rezones or other similar legislative actions. These agreements ordinarily set forth what will, or will not, be done on a property as a part of a rezone; in such cases, the work will be completed as a part of the contract rezone. The CA here is not related to any project proposed when it was executed; its sole intention is to limit the authority of the City to take actions in the future and to allow undefined future development. B) Washington Law Regulating Annexation Zoning Ordinances Does Not Permit Ordinances That Last Forever. As a city formed under the Optional Municipal Code (OMC), RCW Title 35, Federal Way must comply with the terms of chapter 35.14 when annexing new territory. June 4, 2018 Page 8 In particular, RCW 35A.14.330 allows an OMC city to prepare a zoning regulation to become effective in an area to be annexed. Subsections (1) and (2) define the scope of a potential pre -annexation zoning, while subsection (4) provides as follows: (4) The time interval following an annexation during which the ordinance or resolution adopting any such proposed regulation, or any part thereof, must remain in effect before it may be amended, supplemented or modified by subsequent ordinance or resolution adopted by the annexing city or town. As described, this legislation allows an OMC city to establish only a "time interval" during which the pre -annexation zoning regulation "must remain in effect." Without such a "time interval," a local legislative authority could amend the interim zoning ordinance at any time, as described above. RCW 35A.14.330(4) plainly requires zoning have a "time interval" during which the pre -annexation zoning will be binding before it may be amended or modified. Nothing in this statute allows the local government to make permanent pre -annexation zoning, any more than zoning adopted pursuant to the planning and zoning chapter of the OMC, chapter 35A.63, could be made permanent. The statute is supported by Washington caselaw regarding the permanency of zoning, as discussed in Bishop v. Town of Houghton, 69 Wn.2d 786, 792, 420 P.2d 368 (1966): We have no quarrel with respondents' basic theme to the effect that while zoning implies a degree of permanency, it is not static and zoning authorities cannot blind themselves to changing conditions. Thus, when conditions surrounding or in relation to a zoned area have so clearly changed as to emphatically call for revisions in zoning, the appropriate zoning authorities are under a duty to initiate proceedings and consider the necessity of pertinent modifications of their zoning ordinances. Otherwise, outmoded zoning regulations can become unreasonable, and the zoning authorities' failure to suitably amend or modify their ordinances can become arbitrary, in which event courts can and should grant appropriate relief. 2 Metzenbaum, Zoning, 1125 (2d ed. 1955). Land use regulations cannot be frozen in time nor be immune to new priorities, changed circumstances, scientific study or community needs. A zoning ordinance that can never be modified is inconsistent with the authority granted to the City of Federal Way and is thus void. June 4, 2018 Page 9 C) The GMA Requires Updating of Development Regulations on a Periodic Basis• The CA Cannot be Immune from the Obligation of Continuin Review. Federal Way is not only subject to the rules established by the OMC, but also to the Growth Management Act, RCW chapter 36.70A (GMA). One of the obligations imposed by the GMA under RCW 36.70A.130 is for continuing review on a periodic basis. Under this statute each local Comprehensive Plan and the local development regulations: shall be subject to continuing review and evaluation by the county or city that adopted them. Except as otherwise provided, a county or city shall take legislative action to review and, if needed. revise its comprehensive land use plan and development reg ulq ations to ensure the plan and regulations comply with the requirements of this chapter according to the deadlines in subsections (4) and (5) of this section. (Emphasis supplied.)2 Subsection (1)(c) further states: "(c) The review and evaluation required by this subsection shall include, but is not limited to, consideration of critical area ordinances...." These sections requiring periodic review were imposed by the legislature after the adoption of Federal Way's Ordinance 94-219 in 1994. The provisions are to assure that local government regulations remain current with scientific advancements and needs of the community. In addition, when considering amendment of a comprehensive plan or development regulations, the City is obligated to "establish and broadly disseminate to the public a public participation program identifying procedures providing for early and continuous public participation in the development and amendment of comprehensive land use plans and development regulations implementing such plans." RCW 36.70A.140. As it relates to critical areas, since the adoption of Ordinance 94-219 by the City, new legislation has modified the content of critical area rules. In 1995, the Legislature adopted RCW 36.70A.172, which requires as follows: (1) In designating and protecting critical areas under this chapter, counties and cities shall include the best available science in developing policies and development regulations to protect the functions and values of critical areas. In 2 Use of the word "shall" by the legislature has a distinct meaning in Washington jurisprudence: Moreover, "shall" when used in a statute, is presumptively imperative and creates a mandatory duty unless a contrary legislative intent is shown. Phil. 11 v. Gregoire, 128 Wash.2d 707, 713, 911 P.2d 389 (1996); State v. Krall, 125 Wash.2d 146, 148, 881 P.2d 1040 (1994). Goldmark v. McKenna, 172 Wn.2d 568, 575, 259 P.3d 1095, (2011). June 4, 2018 Page 10 addition, counties and cities shall give special consideration to conservation or protection measures necessary to preserve or enhance anadromous fisheries. This section mandated that local governments take account of best available information in adopting critical area regulations, including publications such as "Wetlands in Washington State - Volume 2: Guidance for Protecting and Managing Wetlands." See https://fortress.wa.gov/ecy/publications/summarypages/0506008.html. As noted above, the applicant seeks to opt out of these provisions by reliance on Ordinance 94-219. However, the City has recently adopted Ordinance 15-797, codified as Chapter 19.145 of the Federal Way Code, which regulates Environmentally Critical Areas (ECA) in the City. The purpose of this ordinance is as follows: The purpose of this chapter is to protect the environment, human life, and property from harm and degradation. This is to be achieved by precluding or limiting development in areas where development poses serious or special hazards; by preserving and protecting the quality of drinking water; and by preserving important ecological areas such as steep slopes, streams, lakes and wetlands. The public purposes to be achieved by this chapter include protection of water quality, groundwater recharge, stream flow maintenance, stability of slope areas, wildlife and fisheries habitat maintenance, protection of human life and property and maintenance of natural stormwater storage and filter systems. FWC 19.145.010. FWC 19.145.015 provides as follows: "Except as otherwise established in this chapter, if a proposed development activity requires city approval, this chapter will be implemented and enforced as part of that process." FWC 19.145.020 clarifies its application: "The provisions of this division apply throughout the city and must be complied with regardless of any other conflicting provisions of this title." The provisions of this title that do not conflict with the provisions of this division apply to the subject property. Conflicts with the CP-1 zoning are resolved in favor of the adopted critical area ordinances. Accordingly, the property in the CP-1 zone must be consistent with the revised ECA ordinance; no provision of the current code exempts the CP-1 zone from its application or allows a completely out of date code to be applied in the city. D) The Attempt _in the CA to Vest to Future Permit Activity is Inconsistent with Washington Law. In 1987, the Washington Legislature established the rules for vesting of development applications in RCW 19.27.095 and 58.17.033. In this legislation, either a building permit or a plat would vest when a "fully complete application" was made. As noted in Snohomish County v. Pollution Control Hearings Board, 386 P. 3d 1064, 187 June 4, 2018 Page 11 Wash. 2d 346, 105 Wash.2d 778, 789, 719 P.2d 531 (2016): "Washington's vested rights doctrine originated at common law, but is now statutory", citing Town of Woodway v. Snohomish County, 180 Wn.2d 165, 173 (2014) (emphasis supplied). The applicant here claims that it is vested to 1994 standards by virtue of the CA, but the terms of Washington law do not allow vesting in advance of the filing of a complete building permit or plat application. There was no complete building permit or plat application filed when the CA was agreed to in 1994. Our courts have held that the statutory vesting doctrine only applies when an applicant files "a completed application for a building permit." Potala Village Kirkland, LLC v. City of Kirkland, 183 Wn.App. 191, 334 P.3d 1143 (2014). In Potala, the Court rejected the proposition that an application for a substantial development permit would vest rights against zoning changes. In the present case, the applicant claims the Pre -Annexation Zoning Agreement and the CP-1 Zoning in the CA vest it to development regulations in effect at the time, some twenty-four years ago. But, nowhere has the legislature adopted a rule that allows pre -annexation zoning under RCW 35A.14.330 to vest development rights. The rules established in 1987 codified the vested rights doctrine and limited its application to building permits, plats and later (1995) development agreements. Attempts to vest rights based on this pre -annexation zoning are not effective and any review of the current applications should be consistent with existing land use regulations and controls. 3. CONCLUSION. The applicant's proposals violate basic standards for review. First, with three complete applications on the CP-1 zoned property, Washington law and local ordinances require that project review be consolidated. This applies not only to review for consistency with the city codes, but also SEPA review and analysis. An environmental checklist should be prepared that identifies and reviews the entirety of the three pending applications. This does not present a hardship to the applicant because it has already assembled data for its projects, all that is required is the consolidation of this information. Second, the city should apply current zoning, environmental and critical area ordinances to the three applications. Consideration of the pending applications under twenty-four year old ordinances is completely inconsistent with Washington law that prohibits ordinances that would bind local governments forever, especially in light of the statutory requirement to continually assure that zoning and environmental regulations are updated to take account of the latest standards and considerations. June 4, 2018 Page 12 Thank you for consideration of SWC's views. Please do not hesitate to contact me if you have any questions. Sincerely, �A4RM URu & EuSTI , LLP J. Richard Arambu JRA:cc cc: Save Weyerhaeuser Campus CDNSIiLTING ENGINEERS LLC �. - FIESugM1l-TED April 30, 2018 0 201% Job No.1886-001-016-0016 WAY GfTy DF F`~��E 0ppMF� CAµµOM Mr. Jim Harris, Senior Planner City of Federal Way Community Development Department 33325 81h Avenue South Federal Way, WA 98003 RE: File Nos.17-105489-00-UP & 17-105490-00-SE; NOTICE OF INCOMPLETE APPLICATION Greenline Business Park, 32901 Weyerhaeuser Way S, Federal Way Dear Jim: On behalf of Federal Way Campus, LLC, ESM Consulting Engineers, LLC is providing this letter in response to the Notice of Incomplete Application for Greenline Business Park, dated December 12, 2017. For ease of review, we have followed the same format and numbering in your letter and have included our responses in Bold. INCOMPLETE APPLICATION During the course of the City's review, the following items were found to be missing or incomplete. In order for your application to be considered complete and ready for processing, the items below must be provided. Transportation Impact Analysis (TIA) Four copies of a Transportation Impact Analysis (TIA) prepared by TENW has been included with this resubmittal. Analysis also includes Saturday PM Peak hour trips as requested by the City of Federal Way Traffic Division. Noise Analysis Four copies of a Noise Analysis prepared by Ramboll has been included with this resubmittal. Air Quality Analysis Four copies of an Air Quality Analysis prepared by Rambo[[ has been included with this resubmittal. Visual Impact Analysis ESM federal Way ESM Everett Civil Engineering Land Planning 33400 8th Ave S, Ste 205 1010 SE Everett Mall Way, Ste 210 Land Surveying Landscape Architecture Federal Way, WA 98003 Everett, WA 98208 425.297.9900tel 3DLaser Scanning GIS 253.838.6113tel 800.345.5694 toll free 800.345.5694 toll free www.esmcivii.com 753-839.7104 tax 05.797-9961 fax Mr. Jim Harris April 30, 2018 Page 2 Four copies of a Visual Impact Analysis prepared by Craft Architects has been included with this resubmittal. Washington State Department of Archeology and Historic Preservation Analysis as follows: Provide an inventory of the project site and surrounding Weyerhaeuser campus to evaluate the property for its historical and architectural significance. The inventory shall be conducted by qualified cultural resource professionals with expertise in architectural history and archaeology and that have knowledge of using DAHP's on-line Historic Property Inventory and Archaeological Site Inventory databases. Be aware that DAHP requires that all documents related to project reviews be submitted electronically. Correspondence, reports, notices, photos, etc. must now be submitted in PDF or JPG format. For more information about how to submit documents to DAHP please visit: htt ://www.dah .vva. ovl ro rams/sh o-cgM fiance. ii. To assist in conducting a cultural resource survey and inventory effort, DAHP has developed guidelines, including requirements for survey reports, which is available on their website. A previous response was provided to the City on January 25"1, 2018 requesting clarification for this requirement More so, we requested the city retract this requirement for accepting the application. In response, you provided an email (2/07/2018) which concurs that a Washington State Department of Archeology and Historic Preservation Analysis is not an application completeness item. Furthermore, your email explained that previous Greenline projects received similar comments from DAHP requesting this analysis. We have taken the liberty to have a Cultural Resource Archival Study prepared which meets the requirements of DAHP. Please feel free to forward to DAHP as part of the SEPA packet Please find the following items included with this resubmittal as part of our Process IV Land Use Review and SEPA Application: 1. This Response Letter 2. SEPA Checklist Dated 4/30/2018 (8 copies); 3. Transportation impact Analysis (4 copies); 4. Visual Impact Exhibit (4 copies); 5. JARPA (4 copies); 6. Air Quality Technical Report (4 copies); 7. Environmental Noise Report (4 copies); 8. Cultural Resources Archival Study (4 copies); 9. Compact Disk Including Above Items and Prior Documents to make a Complete Application Submittal (1 copy) Mr. Jim Harris April 30, 2018 Page 3 If you have any questions, please feel free to contact me at 253-838-6113, and I look forward to your response. Sincerely, ESM GN ULTING ENGINEERS, LLC n Z' MATT REIDER Assistant Planner I lesm8lengrles m-jobs1188610011016-00161d ocumentl letter-005.dou GREENLINE BUSINESS PARK: COMMUNITY COMMENTS June 4, 2018 Brian Davis, Community Development Director Jim Harris, Planner City of Federal Way 33325 8"' Ave. S. Federal Way, WA 98003 RE: Greenline Business Park Application File #17-10549-UP, File #17-105490-SE, File #17- 105491-CN and Forest Practices Class IV General Permit Dear Mr. Davis and Mr. Harris: We are residents of Federal Way and other communities in the Puget Sound region, submitting comments about the Greenline Business Park application for the historic Weyerhaeuser corporate campus. This property has environmental, historic and community significance. We oppose construction of warehouses on this land. It is just not in the interest of the public health, safety and welfare of the residents of Federal Way. Our opposition to this application is much like that which we stated against Warehouse A and Warehouse B. But now that all three applications are in the pipeline and no environmental determination has been made on any of them, it would be egregious for the city to consider them as separate projects. We request a comprehensive environmental review be completed covering the impacts from all three applications. We have many concerns about this Greenline Business Park application. We are highlighting the main ones here: TRAFFIC — We believe the estimate of 400-plus semi -truck trips per day is low. After all, the largest warehouse alone (638,000 square feet) has 165 loading dock doors and parking for 111 trucks. In its JARPA application, the applicant states the project's purpose is: "to provide warehouse distribution centers..." But a warehouse of this size and configuration suggests use as a package hub or possibly a fulfillment center, which can generate substantially more traffic than more traditional warehouses. These warehouses must be assessed for traffic on the worst -case scenario based on their size and configuration. Even with 400 trucks, this project will have huge impacts on South 3201h Street and the 320t'linterstate 5 interchange. We request that the applicant be required to widen the 320th Street overpass to provide queuing and turning space for semi -trucks entering and leaving the interchange to prevent gridlock at an already congested area in our growing city. In addition, the traffic impacts from such a massive project cannot be considered separately from the 400 semi - truck trips estimated from Warehouses A and B at the south end of the campus, as if there were a concrete barrier across Weyerhaeuser Way to prevent these trucks from traversing the campus or cutting through neighborhoods. THE ENVIRONMENT — We are concerned about: clear -cutting huge swaths of forest in exchange for concrete structures and parking lots; reduced habitat for wildlife; and air pollution from hundreds of semi -trucks each day, which will affect people and wildlife (especially with the loss of the tree canopy); damage to wetlands, impacts to North Lake (loss of a large portion of its watershed) and storm water runoff that will impact Hylebos Creek, especially downstream where federal dollars have been spent to rehabilitate the salmon -bearing system. We are also concerned about the potential for arsenic (from the defunct Asarco plant in Tacoma) in soil that will be disturbed during clearing and construction (the University of Washington is studying arsenic levels in North Lake, including from runoff). As with traffic, the environmental impacts can't be piecemealed; the city must require them to be considered comprehensively, which we believe will require an Environmental Impact Statement. BUFFERS — The 1994 Concomitant Agreement specifies the managed forest buffer under "Section III. Minimum requirements." Since, at a minimum, the buffer is required along the perimeter of the CP-1 zone, we ask that the city go beyond the minimum and require a forested buffer along the length of Weyerhaeuser Way at the edge of the proposed business park property. This buffer should be deep enough and with an understory to not only screen views of the warehouses from Weyerhaeuser Way, but also to provide wildlife habitat — to help meet the 1994 Concomitant Agreement's original intent of preserving and protecting the unique character of the campus. HISTORIC PRESERVATION — The state Department of Archaeology and Historic Preservation has determined that the former Weyerhaeuser headquarters building and much of the original campus is eligible for listing on the National Register of Historic Places. The entire campus has been declared a "Most Endangered" property by the Washington Trust for Historic Preservation. The intentionally designed landscape of the entire campus —including the north and south meadows — has also been declared at -risk by The Cultural Landscape Foundation in Washington, D.C. Allowing concrete warehouses with multiple truck bays to be built on this property endangers the historic value of the entire property. We disagree with Tetra Tech's assessment that "the Greenline Business Park project will have no effect on any cultural resource property listed on, or eligible for nomination to, the National Register of Historic Places." We also support the more extensive comments being submitted separately by the grassroots community group, Save Weyerhaeuser Campus. Thank you for your consideration of our efforts to preserve what's special about our community. Donna Brown 32721 4t` Place South Federal Way, WA 98003 CITY OF FEDERAL WAY COMMUNITY DEVELOPMENT DEPARTMENT DEVELOPMENT REVIEW COMMITTEE TRANSMITTAL DATE: May 3, 2018 yAJi r P TO: 1 1se']e—E•ITlr�rtt, Development Services Manager l Peter Lawrence, Plans Examiner ` Sarady Long, Senior Traffic Engineer U ,Brian Asbury, Lakehaven Water & Sewer District Chris Cahan, South King Fire & Rescue ) ) FROM: }""` f�W �J�.IJ Jim Harris FOR DRC MTG. ON: May 24, 2018 DATE - Internal Discussion to review if application is now complete, and timeframe for technical review comments. FILE NUMBER(s): 17-105490-00-SE & 17-105489 UP RELATED FILE NOS.: Lots PROJECT NAME: GREENLINE BUSINESS PARK PROJECT ADDRESS: *NO SITE ADDRESS* ZONING DISTRICT: CP-1 PROJECT DESCRIPTION: Environmental review for development of (3) new dings of varying sizes, reconfiguration and addition of associated parking spaces, ROW dedication and frontage improvements. Existing Greenline Technology Center will remain. LAND USE PERMITS: PROJECT CONTACT: "i 3�7 ERIC LABRIE - ESM MATERIALS SUBMITTED: See Green Resubmittal Sheet New SEPA checklist TIA Visual Impact Analysis DARPA Air Quality Report Cultural Resources Study Cover Letter from ESM, dated April 30, 2018 Federal Way MODIFIED NOTICE OF MASTER LAND USE APPLICATION 'Updated To Eliminate Initial Public Comment Deadline - Written Comments May Be Submitted As Specified Below` Project Name: 4reenline Business Park Project Description: Construction of three buildings totaling approximately 1,068,000 square feet, five new stormwater ponds, revisions to existing parking lot and addition of approximately 806 parking stalls, filling approximately 13,500 square feet of wetlands, roadway improvements, and associated site improvements on 146 acres. Applicant: Federal Way Campus, LLC, 11100 Santa Monica Blvd; Suite 850. Los Angeles, CA 90025 Agent: ESM Consulting Engineers, LLC, 33400 8th Avenue South, Suite 205, Federal Way, WA 98003 Project Location: Approximately 329XX Weyerhaeuser Way South, Federal Way, WA, King County Parcels 162104-9056, -9013. -9030 and 152104-9178 Date of Application: November 14, 2017 Date Determined Complete: May 14, 2018 Date of Notice of Application: May 18, 2018 Date of Modified Notice of Application: July 13, 2018 Requested Decision and Other Permits'Included with this Application: The applicant requests a Use Process IV Hearing Examiner decision (File 117-105489-UP) pursuant to Federal Way Revisea Code (FWRC) Chapter 19.70. Additional permits and/or approvals in conjunction with the Use Process IV decision include a threshold determination pursuant to State Environmental Policy Act (SEPA) Rules WAC 197-11 (File #17- 105490-SE), Transportation Concurrency (File #17-105491-CN), Boundary Line Adjustment (File #18-100123-SU), and Forest Practices Class IV General Permit. Environmental Documents: Environmental Checklist, Wetland Report and Conceptual Mitigation Plan, Visual Impact Exhibit, Geotechnical Report, Transportation Impact Analysis, Pavement Analysis, Parking Study, Stormwater Technical Information Report, Air Quality Report, Environmental Noise Report, Cultural Resources Study, Evaluation of Trees. Development Regulations to Be Used for Project Mitigation: Weyerhaeuser Company Pre - Annexation Concomitant and Zoning' Agreement and applicable 1994 development codes, including Federal Way City Code (FWCC) Chapter 18, "Environmental Protection"; Chapter 20, "Subdivisions% Chapter 21, 'Surface and Stormwater Management"; and Chapter 22, "Zoning:" Consistency with Applicable City Plans and Regulations: The project will be reviewed for consistency with all applicable codes and regulations including the Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement, which vests the project to regulations in place in 1994; FWRC 19.145; 2016 King County Surface Water Design Manual as amended by the City of Federal Way; and the Public Works Department Development Standards. Any procedural requirements must meet today's codes (FWRC Title 19). Public Comment & Appeals: The official project file is available for public review at the Community Development Department (City Hall, 2nd Floor, 33325 8th Avenue South, Federal Way, WA 98003). Any person may submit written comments to City staff or the Hearing Examiner and may appear at the public hearing of the Hearing Examiner to give comments orally. Any person may submit written comments to the Hearing Examiner by delivering these comments to the Department of Community Development prior to the public hearing date (which has yet to be determined) or by giving these directly to the Hearing Examiner at the public hearing. Only the applicant, persons who submit written or oral comments to the Hearing Examiner, or persons who specifically request a copy of the written decision may appeal the Hearing Examiner's decision. Details of the appeal procedures for the requested land use decision will be included with the written decision. Comments sent by email should be directed to planning0clWf tederalway.com . Availability of File and Environmental Documents: The official project file and referenced environmental documents are available for public review during normal business hours at the Community Development Department (address above) or on the City's FTP site at 9 5u 6 m i tta I'lo 200 ocymenislBusl ness °�20Pa rkl Staff Contact: Planner Jim Harris, 253-835-2652, lim.harris@cityoffederalway.com Printed in the Federal Way Mirror July 13, 2018. #816627. STATE OF WASHINGTON, COUNTY OF KING } AFFIDAVIT OF PUBLICATION PUBLIC NOTICE Ken Spurrell, being first duly sworn on oath that she is the Legal Advertising Representative of the Federal Way Mirror a weekly newspaper, which newspaper is a legal newspaper of general circulation and is now and has been for more than six months prior to the date of publication hereinafter referred to, published in the English language continuously as a weekly newspaper in King County, Washington. The Federal Way Mirror has been approved as a Legal Newspaper by order of the Superior Court of the State of Washington for King County. The notice in the exact form annexed was published in regular issues of the Federal Way Mirror (and not in supplement form) which was regularly distributed to its subscribers during the below stated period. The annexed notice, (Ad# 816627) a: Public Notice was published on July 13, 2018. The full amount of the fee ch ged for said foregoing publication is the sum of $212.50. Ken purrell ��1e`�►► Legal Advertising Representative, Federal Way.4 r j �1 Subscribed and sworn to me this 13thd day c 3i"y,`+� �� 'f s ° 5 PUBUG z Allen F. Nemec, Na ry Public for the State of �ing in Tacoma, Washington s� CIT Federal Way DEPARTMENT OF COMMUNITY DEVELOPMENT 33325 8t" Avenue South Federal Way WA 98003 253-835-7000; Fax 253-835-2609 www.c[tyoffederalway.com DECLARATION OF DISTRIBUTION I, hereby declare, under penalty of perjury of the laws of the State of Washington, that a: mod,5;�e� Notice of Land Use pplication/Action ❑ Notice of Determination of Significance (DS) and Scoping Notice ❑ Notice of Environmental Determination of Nonsignificance (SEPA, DNS) ❑ Notice of Mitigated Environmental Determination of Nonsignificance (SEPA, MDNS) ❑ Notice of Land Use Application & Optional DNS/MDNS ❑ FWRC Interpretation ❑ Other ❑ Land Use Decision Letter ❑ Notice of Public Hearing before the Hearing Examiner ❑ Notice of Planning Commission Public Hearing ❑ Notice of LUTC/CC Public Hearing ❑ Notice of Application for Shoreline Management Permit ❑ Shoreline Management Permit ❑ Adoption of Existing Environmental Document was OCmailed ❑ faxed ❑ e-mailed and/or ❑ posted to or at each of the attached addresses on 2018. Project Name gr e P I d �us 5,� :L r h File Number(s) % / b 5 V Signature Date 7 - l - 1 K:\CD Administration Files\Declaration of Distribution.doc/Last printed 1 /4/2018 12:02:00 PM CITY OF Federal Way MODIFIED NOTICE OF MASTER LAND USE APPLICATION *Updated To Eliminate Initial Public Comment Deadline - Written Comments May Be Submitted As Specified Below* Project Name: Greenline Business Park Project Description: Construction of three buildings totaling approximately 1,068,000 square feet, five new stormwater ponds, revisions to existing parking lot and addition of approximately 806 parking stalls, filling approximately 13,500 square feet of wetlands, roadway improvements, and associated site improvements on 146 acres. Applicant: Federal Way Campus, LLC, 11100 Santa Monica Blvd, Suite 850, Los Angeles, CA 90025 Agent: ESM Consulting Engineers, LLC, 33400 8`h Avenue South, Suite 205, Federal Way, WA 98003 Project Location: Approximately 329XX Weyerhaeuser Way South, Federal Way, WA, King County Parcels 162104-9056, -9013, -9030 and 152104-9178 Date of Application: November 14, 2017 Date Determined Complete: May 14, 2018 Date of Notice of Application: May 18, 2018 Date of Modified Notice of Application: July 13, 2018 Requested Decision and Other Permits Included with this Application: The applicant requests a Use Process IV Hearing Examiner decision (File #17-105489-UP) pursuant to Federal Way Revised Code (FWRC) Chapter 19.70. Additional permits and/or approvals in conjunction with the Use Process IV decision include a threshold determination pursuant to State Environmental Policy Act (SEPA) Rules WAC 197-11 (File #17- 105490-SE), Transportation Concurrency (File #17-105491-CN), Boundary Line Adjustment (File #18- 100123-SU), and Forest Practices Class IV General Permit. Environmental Documents: Environmental Checklist, Wetland Report and Conceptual Mitigation Plan, Visual Impact Exhibit, Geotechnical Report, Transportation Impact Analysis, Pavement Analysis, Parking Study, Stormwater Technical Information Report, Air Quality Report, Environmental Noise Report, Cultural Resources Study, Evaluation of Trees. Development Regulations to Be Used for Project Mitigation: Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement and applicable 1994 development codes, including Federal Way City Code (FWCC) Chapter 18, "Environmental Protection"; Chapter 20, "Subdivisions"; Chapter 21, "Surface and Stormwater Management"; and Chapter 22, "Zoning." Consistency with Applicable City Plans and Regulations: The project will be reviewed for consistency with all applicable codes and regulations including the Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement, which vests the project to regulations in place in 1994; FWRC 19.145; 2016 King County Surface Water Design Manual as amended by the City of Federal Way; and the Public Works Department Development Standards. Any procedural requirements must meet today's codes (FWRC Title 19). Public Comment & Appeals: The official project file is available for public review at the Community Development Department (City Hall, 2°d Floor, 33325 8`b Avenue South, Federal Way, WA 98003). Any person may submit written comments to City staff or the Hearing Examiner and may appear at the public hearing of the Hearing Examiner to give comments orally. Any person may submit written comments to the Healing Examiner by delivering these comments to the Department of Community Dcvelopment prior to the public hearing date (which has yet to be determined) or by giving these directly to the Hearing Examiner at the public hearing. Only the applicant, persons who submit written or oral comments to the Hearing Examiner, or persons who specifically request a copy of the written decision may appeal the Hearing Examiner's decision. Details of the appeal procedures for the requested land use decision will be included with the written decision. Comments sent by email should be directed to planning(a),cityoffederalway.com. Availability of File and Environmental Documents: The official project file and referenced environmental documents are available for public review during normal business hours at the Community Development Department (address above) or on the City's FTP site at ftp://ftp.cityoffederalway.corn/Outbox/Greenline°/a2OS ubmittal%2ODocuments/Business%2OPark/ Staff Contact: Planner Jim Harris, 253-835-2652, jim.harris@cityoffederalway.com Printed in the Federal Way Mirror July 13, 2018. ME Greenline Business Park Public Notice Mailing List (300' Buffer from Project Boundary) Parcel number Taxpayer name Owner Address City State Zip code 1521049022 BARCELO HOMES LLC PO BOX 1733 AUBURN WA 98071 1521049026 KREMER LYLE 32629 39TH AVE S AUBURN WA 98001 1521049030 GASSER LIANE 32723 39TH AVE S AUBURN WA 98001 1521049037 GILLESPIE DANIEL R 15738 MIDVALE AVE N SHORELINE WA 98133 1521049052 HIGHMARK INVESTMENTS LLC 1214140TH AVE CT E SUMNER WA 98390 1521049123 HONEY WENDY+BRIAN 3800 S 328TH ST FEDERAL WAY WA 98001 1521049141 GASSER LIANE E 32719 39TH AVE S AUBURN WA 98002 1521049142 SUNDSTROM DENNIS A 3809 S 325TH PL AUBURN WA 98001 1521049145 SUNDSTROM DENNIS A+WENDY R 3fi16S 325TH PL AUBURN WA 98002 1521049153 MAYOR ROMEO A -TTEE 29824 2 N D AVE SW FEDERAL WAY WA 98023 1521049167 VANDENBERG MELVIN W 1621 AMHERST DR AMES IA 50014 1521049178 iRGRA 4020 KINROSS LAKES PKWY RICHFIELD OH 44286 1521049201 WA DEPT OF FISH&WILDLIFE 600 CAPITOL WY N OLYMPIA WA 98501 1621049013 IRGRA 4020 KINROSS LAKES PKWY RICHFIELD OH 44286 1621049030 IRGRA 402J KINROSS LAKES PKWY RICHFIELD OH 44287 1621049036 IRGRA 4022 KINROSS LAKES PKWY RICHFIELD OH 44288 1621049056 IRGRA 1023 KINROSS LAKES PKWY RICHFIELD OH 44289 2154650080 LEASE 06998.100-RENT DEPT PO BOX 1476 TACOMA WA 98401 2154650100 WESTERN WA CONF OF SDA 32229 WEYERHAEUSER W FEDERAL WAY WA 98001 2154650110 GENESIS KC DEVELOPMENT LLC 200016TH ST DENVER CO 80202 2154650120 GENESIS KC DEVELOPMENT LLC 2001 16TH ST DENVER CO 80202 2154650140 EAST CAMPUS CORPORATE PARK 1201 PACIFIC AVE STE 1400 TACOMA WA 98402 2154650160 EAST CAMPUS CORPORATE PARK 12 2 PACIFIC AVE STE 1400 TACOMA WA 98402 2154650170 EAST CAMPUS CORPORATE PART{ 1 03 PACIFIC AVE STE 1400 TACOMA WA 98402 2154650180 EAST CAMPUS CORPORATE PARK 1204 PACIFIC AVE STE 1400 TACOMA WA 98402 2285000010 FEDERAL WAY CAMPUS LLC 11100 SANTA MONICA BLVD #850 LOS ANGELES CA 90025 7978200480 FEDERAL WAY CAMPUS LLC 1101 SANTA MONICA BLVD #850 LOS ANGELES CA 90025 7978200515 IRGRA 4020 KINROSS LAKES PKWY RICHFIELD OH 44286 7978200520 IRGRA 4q,',T KINROSS LAKES PKWY RICHFIELD OH 44287 RECEIVED MAY 15 201 CiiY OF FEDERAL -WAY COMMUNrTY DEVROPMEW 05-15-2018 CIT Federal Way DEPARTMENT OF COMMUNITY DEVELOPMENT 33325 8th Avenue South Federal Way WA 98003 253-835-7000; Fax 253-835-2609 www.cityoffederalway.com DECLARATION OF DISTRIBUTION i, hereby declare, under penalty of perjury of the laws of the State of Washington, that a: mod: ej Notice of Land Use Application/Action ❑ Notice of Determination of Significance (DS) and Scoping Notice ❑ Notice of Environmental Determination of Nonsignificance (SEPA, DNS) ❑ Notice of Mitigated Environmental Determination of Nonsignificance (SEPA, MDNS) ❑ Notice of Land Use Application & Optional DNS/MDNS ❑ FWRC Interpretation ❑ Other was ❑ mmailed ❑ faxed w[ 2018. Project Name File Number(s) Signature : ❑ Land Use Decision Letter ❑ Notice of Public Hearing before the Hearing Examiner ❑ Notice of Planning Commission Public Hearing ❑ Notice of LUTC/CC Public Hearing ❑ Notice of Application for Shoreline Management Permit ❑ Shoreline Management Permit ❑ Adoption of Existing Environmental Document XJ e-mailed and/or ❑ posted to or at each of the attached addresses on Date -7-I1 -1 & K:\CD Administration Files\Declaration of Distribution.doc/Last printed 1 /4/2018 12:02:00 PM 1 r� 1�k CITY OF Federal Way MODIFIED NOTICE OF MASTER LAND USE APPLICATION *Updated To Eliminate Initial Public Comment Deadline - Written Comments May Be Submitted As Specified Below* Project Name: Greenline Business Park Project Description: Construction of three buildings totaling approximately 1,068,000 square feet, five new stormwater ponds, revisions to existing parking lot and addition of approximately 806 parking stalls, filling approximately 13,500 square feet of wetlands, roadway improvements, and associated site improvements on 146 acres. Applicant: Federal Way Campus, LLC, 11100 Santa Monica Blvd, Suite 850, Los Angeles, CA 90025 Agent: ESM Consulting Engineers, LLC, 33400 8tl' Avenue South, Suite 205, Federal Way, WA 98003 Project Location: Approximately 329XX Weyerhaeuser Way South, Federal Way, WA, King County Parcels 162104-9056, -9013, -9030 and152104-9178 Date of Application: November 14, 2017 Date Determined Complete: May 14, 2018 Date of Notice of Application: May 18, 2018 Date of Modified Notice of Application: July 13, 2018 Requested Decision and Other Permits Included with this Application: The applicant requests a Use Process IV Hearing Examiner decision (File #17-105489-UP) pursuant to Federal Way Revised Code (FWRC) Chapter 19.70. Additional permits and/or approvals in conjunction with the Use Process IV decision include a threshold determination pursuant to State Environmental Policy Act (SEPA) Rules WAC 197-11 (File #17- 105490-SE), Transportation Concurrency (File #17-105491-CN), Boundary Line Adjustment (File #18- 100123-SU), and Forest Practices Class IV General Permit. Environmental Documents: Environmental Checklist, Wetland Report and Conceptual Mitigation Plan, Visual Impact Exhibit, Geotechnical Report, Transportation Impact Analysis, Pavement Analysis, Parking Study, Stormwater Technical Information Report, Air Quality Report, Environmental Noise Report, Cultural Resources Study, Evaluation of Trees. Development Regulations to Be Used for Project Mitigation: Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement and applicable 1994 development codes, including Federal Way City Code (FWCC) Chapter 18, "Environmental Protection"; Chapter 20, "Subdivisions"; Chapter 21, "Surface and Stormwater Management"; and Chapter 22, "Zoning." Consistency with Applicable City Plans and Regulations: The project will be reviewed for consistency with all applicable codes and regulations including the Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement, which vests the project to regulations in place in 1994; FWRC 19.145; 2016 King County Surface Water Design Manual as amended by the City of Federal Way; and the Public Works Department Development Standards. Any procedural requirements must meet today's codes (FWRC Title 19). Public Comment & Appeals: The official project file is available for public review at the Community Development Department (City Hall, 2nd Floor, 33325 8d' Avenue South, Federal Way, WA 98003). Any person may submit written comments to City staff or the Hearing Examiner and may appear at the public hearing of the Hearing Examiner to give comments orally. Any person may submit written comments to the Hearing Examiner by delivering these comments to the Department of Community Development prior to the public hearing date (which has yet to be determined) or by giving these directly to the Hearing Examiner at the public hearing. Only the applicant, persons who submit written or oral comments to the Hearing Examiner, or persons who specifically request a copy of the written decision may appeal the Hearing Examiner's decision. Details of the appeal procedures for the requested land use decision will be included with the written decision. Comments sent by email should be directed to plannin cit affederalwa .com. Availability of File and Environmental Documents: The official project file and referenced environmental documents are available for public review during normal business hours at the Community Development Department (address above) or on the City's FTP site at ft ://-ft .cit offederalway.comlOtitbox/Gi-cenline%20Submittal%20Documents/Business%20Park/ Staff Contact: Planner Jim Harris, 253-835-2652, jim.harris@cityoffederalway.com Printed in the Federal Way Mirror July 13, 2018. I Tamara Fix From: Ken Spurrell <legals@tacomadailyindex.com> Sent: Wednesday, July 11, 2018 11:23 AM To: Tamara Fix Subject: Confirmation Confirming receiving the 4th notice to pub in FWM. thanks Ken DEPARTMENT OF COMMUNITY DEVELOPMENT 33325 8th Avenue South Federal Way WA 98003-6325 CITY OF 253-835-7000; Fax 253-835-2609 Federal Way www.cif offederalwa .cam DECLARATION OF DISTRIBUTION hereby declare, under penalty of perjury of the laws of Y P Y P l rY the State of W shington, that a: Notice of Land Use Application/Action ❑ Land Use Decision Letter ❑ Notice of Determination of Significance (DS) and Scoping Notice ❑ Notice of Environmental Determination of Nonsignificance (SEPA, DNS) ❑ Notice of Mitigated Environmental Determination of Nonsignificance (SEPA, MDNS) ❑ Notice of Land Use Application & Optional DNS/MDNS ❑ FWRC Interpretation ❑ Other ❑ Notice of Public Hearing before the Hearing Examiner ❑ Notice of Planning Commission Public Hearing ❑ Notice of LUTC/CC Public Hearing ❑ Notice of Application for Shoreline Management Permit ❑ Shoreline Management Permit ❑ Adoption of Existing Environmental Document was ❑ mailed ❑ faxed ❑ e-mailed and/or fisted to or at each of the attached addresses on 2018. Project Name File Number(s) Signature Gff& l?k QU Date K:\PLANNING INTERN\Declaration of Distribution notices\Declaration of Distribution with Posting Sites.doc Posting Sites: Federal Way City Hall - 33325 8th Avenue Federal Way Regional Library - 34200 1 It Way South Federal Way 320th Branch Library - 848 South 320th Street Subject Site - K:\PLANNING INTERN\Declaration of Distribution notices\Declaration of Distribution with Posting Sites.doc CITY OF Federal Way MODIFIED NOTICE OF MASTER LAND USE APPLICATION *Updated To Eliminate Initial Public Comment Deadline - Written Comments May Be Submitted As Specified Below* Project Name: Greenline Business Park Project Description: Construction of three buildings totaling approximately 1,068,000 square feet, five new stormwater ponds, revisions to existing parking lot and addition of approximately 806 parking stalls, filling approximately 13,500 square feet of wetlands, roadway improvements, and associated site improvements on 146 acres. Applicant: Federal Way Campus, LLC, 11100 Santa Monica Blvd, Suite 850, Los Angeles, CA 90025 Agent: ESM Consulting Engineers, LLC, 33400 8fl' Avenue South, Suite 205, Federal Way, WA 98003 Project Location: Approximately 329XX Weyerhaeuser Way South, Federal Way, WA, King County Parcels 162104-9056, -9013, -9030 and 152104-9178 Date of Application: November 14, 2017 Date Determined Complete: May 14, 2018 Date of Notice of Application: May 18, 2018 Date of Modified Notice of Application: July 13, 2018 Requested Decision and Other Permits Included with this Application: The applicant requests a Use Process IV Hearing Examiner decision (File #17-105489-UP) pursuant to Federal Way Revised Code (FWRC) Chapter 19.70. Additional permits and/or approvals in conjunction with the Use Process IV decision include a threshold determination pursuant to State Environmental Policy Act (SEPA) Rules WAC 197-11 (File #17- 105490-SE), Transportation Concurrency (File #17-105491-CN), Boundary Line Adjustment (File #18- 100123-SU), and Forest Practices Class IV General Permit. Environmental Documents: Environmental Checklist, Wetland Report and Conceptual Mitigation Plan, Visual Impact Exhibit, Geotechnical Report, Transportation Impact Analysis, Pavement Analysis, Parking Study, Stormwater Technical Information Report, Air Quality Report, Environmental Noise Report, Cultural Resources Study, Evaluation of Trees. Development Regulations to Be Used for Project Mitigation: Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement and applicable 1994 development codes, including Federal Way City Code (FWCC) Chapter 18, "Environmental Protection"; Chapter 20, "Subdivisions"; Chapter 21, "Surface and Stormwater Management"; and Chapter 22, "Zoning." Consistency with Applicable City Plans and Regulations: The project will be reviewed for consistency with all applicable codes and regulations including the Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement, which vests the project to regulations in place in 1994; FWRC 19.145; 2016 King County Surface Water Design Manual as amended by the City of Federal Way; and the Public Works Department Development Standards. Any procedural requirements must meet today's codes (FWRC Title 19). Public Comment & Appeals: The official project file is available for public review at the Community Development Department (City Hall, 2nd Floor, 33325 8d' Avenue South, Federal Way, WA 98003). Any person may submit written comments to City staff or the Hearing Examiner and may appear at the public hearing of the Hearing Examiner to give comments orally. Any person may submit written comments to the Hearing Examiner by delivering these comments to the Department of Community Development prior to [lie public hearing date (which has yet to be determined) or by giving these directly to the Hearing Examiner at the public hearing. Only the applicant, persons who submit written or oral comments to the Hearing Examiner, or persons who specifically request a copy of the written decision may appeal the Hearing Examiner's decision. Details of the appeal procedures for the requested land use decision will be included with the written decision. Comments sent by email should be directed to planning [..cityoffederalway.com. Availability of File and Environmental Documents: The official project file and referenced environmental documents are available for public review during normal business hours at the Community Development Department (address above) or on the City's FTP site at R :ll .cit offederalwa.com/OutboxlGreenline°/u20Submittal%20DocuinentsBusiness%20Park/ Staff Contact: Planner Jim Harris, 253-835-2652, jim.harris@cityoffederalway.com Printed in the Federal Way Mirror July 13, 2018. DEPARTMENT OF COMMUNITY DEVELOPMENT A�k' 33325 8th Avenue South Federal Way WA 98003 CITY OF 253-835-7000; Fax 253-835-2609 Federal Way `^"^ w.cifyoffederalway.cr�rri DECLARATION OF DISTRIBUTION I, hereby declare, under penalty of perjury of the laws of the State of Washington, that a: Notice of Land Use Application/Action ❑ Notice of Determination of Significance (DS) and Scoping Notice ❑ Notice of Environmental Determination of Nonsignificance (SEPA, DNS) ❑ Notice of Mitigated Environmental Determination of Nonsignificance (SEPA, MDNS) ❑ Notice of Land Use Application & Optional DNS/MDNS ❑ FWRC Interpretation ❑ Other ❑ Land Use Decision Letter ❑ Notice of Public Hearing before the Hearing Examiner ❑ Notice of Planning Commission Public Hearing ❑ Notice of LUTC/CC Public Hearing ❑ Notice of Application for Shoreline Management Permit ❑ Shoreline Management Permit ❑ Adoption of Existing Environmental Document was ❑ mailed ❑ faxed Dte-mailed and/or ❑ posted to or at each of the attached addresses on -fG 2018. Project Name File Number(s) Signature -ID57Ya Date S -/6 - / R K:\CD Administration Files\Declaration of Distribution.doc/Last printed 1 /4/2018 12:02:00 PM CITY OF Federal Way NOTICE OF MASTER LAND USE APPLICATION Project Name: Greenline Business Park Project Description: Construction of three buildings totaling approximately 1,068,000 square feet, five new stormwater ponds, revisions to existing parking lot and addition of approximately 806 parking stalls, filling approximately 13,500 square feet of wetlands, roadway improvements, and associated site improvements on 146 acres. Applicant: Federal Way Campus, LLC, 11100 Santa Monica Blvd, Suite 850, Los Angeles, CA 90025 Agent: ESM Consulting Engineers, LLC, 33400 8`h Avenue South, Suite 205, Federal Way, WA 98003 Project Location: Approximately 329XX Weyerhaeuser Way South, Federal Way, WA, King County Parcels 162104-9056, -9013, -9030 and152104-9178 Date of Application: November 14, 2017 Date Determined Complete: May 14, 2018 Date of Notice of Application: May 18, 2018 Public Comments Due: June 4, 2018 Requested Decision and Other Permits Included with this Application: The applicant requests a Use Process IV Hearing Examiner decision (File #17-105489-UP) pursuant to Federal Way Revised Code (FWRC) Chapter 19.70. Additional permits and/or approvals in conjunction with the Use Process IV decision include a threshold determination pursuant to State Environmental Policy Act (SEPA) Rules WAC 197-11 (File #17- 105490-SE), Transportation Concurrency (File #17-105491-CN), Boundary Line Adjustment (File #18- 100123-SU), and Forest Practices Class IV General Permit. Environmental Documents: Environmental Checklist, Wetland Report and Conceptual Mitigation Plan, Visual Impact Exhibit, Geotechnical Report, Transportation Impact Analysis, Pavement Analysis, Parking Study, Stormwater Technical Information Report, Air Quality Report, Environmental Noise Report, Cultural Resources Study, Evaluation of Trees. Development Regulations to Be Used for Project Mitigation: Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement and applicable 1994 development codes, including Federal Way City Code (FWCC) Chapter 18, "Environmental Protection"; Chapter 20, "Subdivisions"; Chapter 21, "Surface and Stormwater Management"; and Chapter 22, "Zoning." Consistency with Applicable City Plans and Regulations: The project will be reviewed for consistency with all applicable codes and regulations including the Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement, which vests the project to regulations in place in 1994; FWRC 19.145; 2016 King County Surface Water Design Manual as amended by the City of Federal Way; and the Public Works Department Development Standards. Any procedural requirements must meet today's codes (FWRC Title 19). Public Comment & Appeals: The official project file is available for public review at the Community Development Department (City Hall, 2nd Floor, 33325 8d' Avenue South, Federal Way, WA 98003). The initial public comment and notice period ends June 4, 2018. However, any person may submit written comments to the Hearing Examiner by delivering these comments to the Department of Community Development prior to the public hearing date (which has yet to be determined) or by giving these directly to the Hearing Examiner at the public hearing. Only the applicant, persons who submit written or oral comments to the Hearing Examiner, or persons who specifically request a copy of the written decision may appeal the Hearing Examiner's decision. Details of the appeal procedures for the requested land use decision will be included with the written decision. Comments sent by email should be directed to planning{a,cityoffederalway.coin. Availability of File and Environmental Documents: The official project file and referenced environmental documents are available for public review during normal business hours at the Community Development Department (address above) or on the City's FTP site at ftp://ftp.citvoffederalway.com/Outbox/GreenlineSubmittalDocuments/BusinessPark Staff Contact: Planner Jim Harris, 253-835-2652, jim.harris@cityoffederalway.com Printed in the Federal Way Mirror May 18, 2018. 0 Tamara Fix From: Sent: To: Subject: Attachments: Good Morning Tamara, Linda Mills <lmills@kentreporter.com> Wednesday, May 16, 2018 10:57 AM Tamara Fix Re: Greenline NOA 2131465.pdf I have received your notice (re: Greenline NOA 17-105489) to be published in the Federal Way Mirror on Friday, May 18, 2018. Thank you, Linda 2131465 Linda Mills Legal/Public Notice Advertising - Obituary Representative Auburn, Bellevue, Bothell/Kenmore, Covington/Maple Valley/Black Diamond, Issaquah/Sammamish,Kent, Kirkland, Mercer Island, Redmond and Renton Reporters, Federal Way Mirror, Seattle, Weekly, Snoqualmie Valley Record, and Okanogan Valley Gazette -Tribune ❑irect:253-234-3506 Internal:36027 Fax:253-437-6016 19426 68th Ave. S., Ste A, Kent, WA 98032 Map Print Rates Online Rates Media Kit Sound Info On Wed, May 16, 2018 at 10:37 AM, Tamara Fix CTamara.Fix Ocityoffederalway.com> wrote: Please publish the attached legal notice (Greenline NOA, 17-105489) in Friday's (May 18, 2018) issue. Please confirm and issue an affidavit of publication. Thanks! 1 . A�k CIT Federal Way DEPARTMENT OF COMMUNITY DEVELOPMENT 33325 8t" Avenue South Federal Way WA 98003 253-835-7000; Fax 253-835-2609 www.cit offederalwa .Cam DECLARATION OF DISTRIBUTION 1,qllev YUQ- hereby declare, under penalty of perjury of the laws of the State of Was ington, that a: Notice of Land Use Application/Action ❑ Land Use Decision Letter ❑ Notice of Determination of Significance (DS) and Scoping Notice ❑ Notice of Environmental Determination of Nonsignificance (SEPA, DNS) ❑ Notice of Mitigated Environmental Determination of Nonsignificance (SEPA, MDNS) ❑ Notice of Land Use Application & Optional DNS/MDNS ❑ FWRC Interpretation ❑ Other was ❑ ma i ed ❑ faxed 2012, Project Name File Number(s) Signature ❑ Notice of Public Hearing before the Hearing Examiner ❑ Notice of Planning Commission Public Hearing ❑ Notice of LUTC/CC Public Hearing ❑ Notice of Application for Shoreline Management Permit ❑ Shoreline Management Permit ❑ Adoption of Existing Environmental Document ❑ e-mailed and/or /Posted to or at each of the attached addresses on Date �,V/)-Oi o I:\Declaration of Distribution.doc/Last printed 8/11 /2017 11:45:00 AM Posted Sites: Federal Way City Hall: 33325 8th Ave South Federal Way Library: 34200 1 st Way South Federal Way 320th Library: 848 S. 320th St I:\Declaration of DisMbufion.doc/Last printed 8/11 /2017 11:45:00 AM CITY OF Federal Way NOTICE OF MASTER LAND USE APPLICATION Project Name: Greenline Business Park Project Description: Construction of three buildings totaling approximately 1,068,000 square feet, five new stormwater ponds, revisions to existing parking lot and addition of approximately 806 parking stalls, filling approximately 13,500 square feet of wetlands, roadway improvements, and associated site improvements on 146 acres. Applicant: Federal Way Campus, LLC, 11100 Santa Monica Blvd, Suite 850, Los Angeles, CA 90025 Agent: ESM Consulting Engineers, LLC, 33400 8d` Avenue South, Suite 205, Federal Way, WA 98003 Project Location: Approximately 329XX Weyerhaeuser Way South, Federal Way, WA, King County Parcels 162104-9056, -9013, -9030 and 152104-9178 Date of Application: November 14, 2017 Date Determined Complete: May 14, 2018 Date of Notice of Application: May 18, 2018 Public Comments Due: June 4, 2018 Requested Decision and Other Permits Included with this Application: The applicant requests a Use Process IV Hearing Examiner decision (File #17-105489-UP) pursuant to Federal Way Revised Code (FWRC) Chapter 19.70. Additional permits and/or approvals in conjunction with the Use Process IV decision include a threshold determination pursuant to State Environmental Policy Act (SEPA) Rules WAC 197-11 (File #17- 105490-SE), Transportation Concurrency (File #17-105491-CN), Boundary Line Adjustment (File #18- 100123-SU), and Forest Practices Class IV General Permit. Environmental Documents: Environmental Checklist, Wetland Report and Conceptual Mitigation Plan, Visual Impact Exhibit, Geotechnical Report, Transportation Impact Analysis, Pavement Analysis, Parking Study, Stormwater Technical Information Report, Air Quality Report, Environmental Noise Report, Cultural Resources Study, Evaluation of Trees. Development Regulations to Be Used for Project Mitigation: Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement and applicable 1994 development codes, including Federal Way City Code (FWCC) Chapter 18, `Environmental Protection"; Chapter 20, "Subdivisions"; Chapter 21, "Surface and Stormwater Management"; and Chapter 22, "Zoning." Consistency with Applicable City Plans and Regulations: The project will be reviewed for consistency with all applicable codes and regulations including the Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement, which vests the project to regulations in place in 1994; FWRC 19.145; 2016 King County Surface Water Design Manual as amended by the City of Federal Way; and the Public Works Department Development Standards. Any procedural requirements must meet today's codes (FWRC Title 19). Public Comment & Appeals: The official project file is available for public review at the Community Development Department (City Hall, 2nd Floor, 33325 8d' Avenue South, Federal Way, WA 98003). The initial public comment and notice period ends June 4, 2018. However, any person may submit written comments to the Hearing Examiner by delivering these comments to the Department of Community Development prior to the public hearing date (which has yet to be determined) or by giving these directly to the Hearing Examiner at the public hearing. Only the applicant, persons who submit written or oral comments to the Hearing Examiner, or persons who specifically request a copy of the written decision may appeal the Hearing Examiner's decision. Details of the appeal procedures for the requested land use decision will be included with the written decision. Comments sent by email should be directed to planning,P,ciWffederalway.cam. Availability of File and Environmental Documents: The official project file and referenced environmental documents are available for public review during normal business hours at the Community Development Department (address above) or on the City's FTP site at ftp-//ftT)cityoffederalway.conVOutboxlGreenlineSubmittalDocuments/BusinessPark Staff Contact: Planner Jim Harris, 253-835-2652, jim.harris@cityoffederalway.com Printed in the Federal Way Mirror May 18, 2018. B 4§� CITY OF Federal Way DEPARTMENT OF COMMUNITY DEVELOPMENT 33325 8th Avenue South Federal Way WA 98003 253-835-7000; Fax 253-835-2609 www.cityoffederalway.com DECLARATION OF DISTRIBUTION 1 I,J hereby declare, under penalty of perjury of the laws of the State of Washington, that a: Pq Notice of Land Use Application/Action ❑ Notice of Determination of Significance (DS) and Scoping Notice ❑ Notice of Environmental Determination of Nonsignificance (SEPA, DNS) ❑ Notice of Mitigated Environmental Determination of Nonsignificance (SEPA, MDNS) ❑ Notice of Land Use Application & Optional DNS/MDNS ❑ FWRC Interpretation ❑ Other - was Kmailed ❑ faxed 2018. Project Name File Number(s) Signature ❑ Land Use Decision Letter ❑ Notice of Public Hearing before the Hearing Examiner ❑ Notice of Planning Commission Public Hearing ❑ Notice of LUTC/CC Public Hearing ❑ Notice of Application for Shoreline Management Permit ❑ Shoreline Management Permit ❑ Adoption of Existing Environmental Document ❑ e-mailed and/or ❑ posted to or at each of the attached addresses on C- e 7- los y Date -) 7 K:\CD Administration Files\Declaration of Distribution.doc/Last printed 1 /4/201 B 12:02:00 PM 4ik CITY OF Federal Way NOTICE OF MASTER LAND USE APPLICATION Project Name: Greenline Business Park Project Description: Construction of three buildings totaling approximately 1,068,000 square feet, five new stormwater ponds, revisions to existing parking lot and addition of approximately 806 parking stalls, filling approximately 13,500 square feet of wetlands, roadway improvements, and associated site improvements on 146 acres. Applicant: Federal Way Campus, LLC, 11100 Santa Monica Blvd, Suite 850, Los Angeles, CA 90025 Agent: ESM Consulting Engineers, LLC, 33400 8d' Avenue South, Suite 205, Federal Way, WA 98003 Project Location: Approximately 329XX Weyerhaeuser Way South, Federal Way, WA, King County Parcels 162104-9056, -9013, -9030 and 152104-9178 Date of Application: November 14, 2017 Date Determined Complete: May 14, 2018 Date of Notice of Application: May 18, 2018 Public Comments Due: June 4, 2018 Requested Decision and Other Permits Included with this Application: The applicant requests a Use Process IV Hearing Examiner decision (File #17-105489-UP) pursuant to Federal Way Revised Code (FWRC) Chapter 19.70. Additional permits and/or approvals in conjunction with the Use Process IV decision include a threshold determination pursuant to State Environmental Policy Act (SEPA) Rules WAC 197-11 (File #17- 105490-SE), Transportation Concurrency (File #17-10549 1 -CN), Boundary Line Adjustment (File #18- 100123-SU), and Forest Practices Class IV General Permit. Environmental Documents: Environmental Checklist, Wetland Report and Conceptual Mitigation Plan, Visual Impact Exhibit, Geotechnical Report, Transportation Impact Analysis, Pavement Analysis, Parking Study, Stormwater Technical Information Report, Air Quality Report, Environmental Noise Report, Cultural Resources Study, Evaluation of Trees. Development Regulations to Be Used for Project Mitigation: Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement and applicable 1994 development codes, including Federal Way City Code (FWCC) Chapter 18, `Environmental Protection"; Chapter 20, "Subdivisions"; Chapter 21, "Surface and Stormwater Management"; and Chapter 22, "Zoning." Consistency with Applicable City Plans and Regulations: The project will be reviewed for consistency with all applicable codes and regulations including the Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement, which vests the project to regulations in place in 1994; FWRC 19.145; 2016 King County Surface Water Design Manual as amended by the City of Federal Way; and the Public Works Department Development Standards. Any procedural requirements must meet today's codes (FWRC Title 19). Public Comment & Appeals: The official project file is available for public review at the Community Development Department (City Hall, 2❑d Floor, 33325 8d' Avenue South, Federal Way, WA 98003). The initial public comment and notice period ends June 4, 2018. However, any person may submit written comments to the Hearing Examiner by delivering these comments to the Department of Community Development prior to the public hearing date (which has yet to be determined) or by giving these directly to the Hearing Examiner at the public hearing. Only the applicant, persons who submit written or oral comments to the Hearing Examiner, or persons who specifically request a copy of the written decision may appeal the Hearing Examiner's decision. Details of the appeal procedures for the requested land use decision will be included with the written decision. Comments sent by email should be directed to -plannin o)ciiyoftederalway.com. Availability of File and Environmental Documents: The official project file and referenced environmental documents are available for public review during normal business hours at the Community Development Department (address above) or on the City's FTP site at ftp.lip.cityoffederalway.com/Outbox/GreenlineSubinittalDocuments/BusinessPark Staff Contact: Planner Jim Harris, 253-835-2652, jim.harris@cityoffederalway.com Printed in the Federal Way Mirror May 18, 2018. Greenline Business Park Public Notice Mailing List (300' Buffer from Project Boundary) Parcel number Taxpayer name Owner Address City State Zip code 1521049022 BARCELO HOMES LLC PO BOX 1733 AUBURN WA 98071 1521049026 KREMER LYLE 32629 39TH AVE S AUBURN WA 98001 1521049030 GASSER LIANE 32723 39TH AVE S AUBURN WA 98001 1521049037 GILLESPIE DANIEL R 15738 MIDVALE AVE N SHORELINE WA 98133 1521049052 HIGHMARK INVESTMENTS LLC 1214140TH AVE CT E SUMNER WA 98390 1521049123 HONEY WENDY+BRIAN 3800 S 328TH ST FEDERAL WAY WA 98001 1521049141 GASSER LIANE E 32719 39TH AVE S AUBURN WA 98002 1521049142 SUNDSTROM DENNIS A 3809 S 325TH PL AUBURN WA 98001 1521049145 SUNDSTROM DENNIS A+WENDY R 3810 S 325TH PL AUBURN WA 98002 1521049153 MAYOR ROMEO A -TTEE 29824 2ND AVE SW FEDERAL WAY WA 98023 1521049167 VANDENBERG MELVIN W 1621 AMHERST DR AMES IA 50014 1521049178 IRGRA 4020 KINROSS LAKES PKWY RICHFIELD OH 44286 1521049201 WA DEPT OF FISH&WILDLIFE 600 CAPITOL WY N OLYMPIA WA 98501 1621049013 IRGRA 4020 KINROSS LAKES PKWY RICHFIELD OH 44286 1621049030 IRGRA 4021 KINROSS LAKES PKWY RICHFIELD OH 44287 1621049036 IRGRA 4022 KINROSS LAKES PKWY RICHFIELD OH 44288 1621049056 IRGRA 4023 KINROSS LAKES PKWY RICHFIELD OH 44289 2154650080 LEASE 06998.100-RENT DEPT PO BOX 1476 TACOMA WA 98401 2154650100 WESTERN WA CONF OF SDA 32229 WEYERHAEUSER W FEDERAL WAY WA 98001 2154650110 GENESIS KC DEVELOPMENT LLC 2000 16TH ST DENVER CO 80202 2154650120 GENESIS KC DEVELOPMENT LLC 2001 16TH ST DENVER CO 80202 2154650140 EAST CAMPUS CORPORATE PARK 1201 PACIFIC AVE STE 1400 TACOMA WA 98402 2154650160 EAST CAMPUS CORPORATE PARK 1202 PACIFIC AVE STE 1400 TACOMA WA 98402 2154650170 EAST CAMPUS CORPORATE PARK 1203 PACIFIC AVE STE 1400 TACOMA WA 98402 2154650180 EAST CAMPUS CORPORATE PARK 1204 PACIFIC AVE STE 1400 TACOMA WA 98402 2285000010 FEDERAL WAY CAMPUS LLC 11100 SANTA MONICA BLVD #850 LOS ANGELES CA 90025 7978200480 FEDERAL WAY CAMPUS LLC 11101 SANTA MONICA BLVD #850 LOS ANGELES CA 90025 7978200515 IRGRA 4020 KINROSS LAKES PKWY RICHFIELD OH 44286 7978200520 IRGRA 4021 KINROSS LAKES PKWY RICHFIELD OH 44287 RECEIVED MAY 15 2018 CfTY OF FEDERAL WAY COMMUNITY DEVELOPMENT 05-15-2018 ResueMm ',b MAY 16 2018 3340D Bth Avenue South, Suite 205 Federal Way, WA 90DD3 MEMORANDUM TO: JIM HARRIS, SENIOR PLANNER, CITY OF FEDERAL WAY FROM: MATT REIDER RE: REVISED PUBLIC NOTICE MATERIALS, GREENLINE BUSINESS PARK JOB #: 1886-001-016 DATE: MAY 16, 2018 The original Process IV Land Use Approval with SEPA application for Greenline Business Park was applied for on November 14, 2017. Included with that application submittal was a map delineating a 300-foot buffer around the entire Federal Way Campus, LLC property; self-addressed, stamped envelopes; and a list of mailing addresses for all property owners included in that buffer. Upon careful consideration and review of City of Federal Way application requirements we have determined that the appropriate delineation should only include the property owners within the 300-foot buffer surrounding the Greenline Business Park "subject property and not the entire campus. As such, we are resubmitting the following materials as part of the Greenline Business Park Process IV Land Use Approval with SEPA application: 1. Self-addressed, stamped business sized envelopes (3 sets); 2. Separate list of mailing addresses with parcel numbers (1 copy); 3. Full sized Assessor's Map Showing 300-foot boundary (1 copy); and 4. CD Containing this Memo, Mailing List, and Assessor's Map (1 copy) It is our understanding that the above -mentioned materials satisfy the Public Notice Requirements listed on Bulletin #001 and as codified in FWRC 19.15.040. We look forward to posting the notice of application on site at the time determined by the City of Federal Way. Civil Engineering • Land Surveying • Project Management • Public Works • Land Planning • Landscape Architecture Phone 253.838.6113 800.345-5694 Fax 253.838.7104 Prepared for: Federal Way Campus, LLC Prepared by: Ramboll US Corporation April 2018 Project Number: 1690002846 GREENLINE BUSINESS PARK DEVELOPMENT, FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT RESUBMITTED APR 3 0 2018 CFFY Or- FEDERAL WAY COMMON; Y DEVELOPMEW FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT EXECUTIVE SUMMAP Ramboll US Corporation (Ramboll) completed a study of noise -related issues surrounding the proposed development of three new buildings of varying sizes for Federal Way Campus, LLC. The Technology Center (Tech Center) at the existing site will remain; however, the parking lot associated with the Tech Center will be reconfigured to allow for the construction of the new warehouse buildings (the Project). Building A will be 638,000 square feet in size, Building B will be 282,500 square feet in size, and Building C will be 147,500 square feet in size. Existing sound levels were measured to document the ambient noise environment at a residential property located immediately southeast of the Project. The measurement location was considered representative of existing sound levels at several residential and commercial properties in the Project vicinity. Acoustically significant equipment anticipated during normal operations of the Project were assumed to include rooftop HVAC units, Make -Up Air units, exhaust fans, ground -level cooling towers, and truck traffic for loading and unloading of products. Using noise source data from previously measured equipment similar to what is existing and anticipated at the Project buildings, a noise model was prepared to estimate noise levels received at nearby residential and commercial locations. An assessment of noise impact was based on compliance with the applicable WAC noise limits, and on the predicted increase over existing ambient conditions. The assessment found that noise associated with the proposed Project would result in negligible increases in ambient noise and would be within compliance of applicable noise limits. An evaluation of the actual facility design, once submitted, should be completed to ensure that the equipment to be installed at the warehouses, as well as warehouse activities, are consistent or similar to those identified in this report. Executive Summary i Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT CONTENT Executive Summary..................................................................................................i Contents..................................................................................................................11 Acronymsand Abbreviations..................................................................................iii 1. Introduction....................................................................................................1 1.1 Project Description......................................................................................1 1.2 Rationale for Noise Study..............................................................................1 2. Noise Terminology and Descriptors.................................................................2 3. Regulatory Setting...........................................................................................4 3.1 City of Federal Way.....................................................................................4 3.2 Washington Administrative Code...................................................................4 4. Existing Environment.......................................................................................6 4.1 Affected Environment..................................................................................6 4.2 Existing Noise Environment.......................................................................... 6 S. Noise Impact Assessment................................................................................9 5.1 Construction Noise Assessment.....................................................................9 5.1.1 Construction Noise Best Management Practices...................................10 5.2 Operational Noise Assessment.................................................................... 10 5.2.1 Noise Prediction Model...................................................................... 11 5.2.2 Emission Sources............................................................................ 11 5.2.3 Noise Sensitive Receivers................................................................. 13 5.2.4 Noise Modeling Results - Assessment of Compliance with WAC Limits..., 13 5.2.5 Noise Modeling Results - Assessment of Increase over Existing Conditions...................................................................................... 14 5.2.6 Additional Considerations - Loading Docks ......................................... 14 5.2.7 Additional Considerations - Off Site Traffic.........................................15 5.2.8 Operational Noise Assessment Results Summary. ................................ 16 6. Conclusions...................................................................................................19 APPENDICIES Appendix A - Figures Contents ii Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT ACRONYMS AND ABBREVIATIONS Acoustically neutral ............... A description of equipment or material such as a wind screen used over a sound level meter microphone that, due to its composition, has little or no effect on the sound pressure levels reaching the microphone Day -night sound level (Ldn) ... A 24-hour sound level metric similar to a 24-hour Leq, except the Ldn includes an additional 10 dBA added to sound levels in each hour between 10 PM and 7 AM to account for increased sensitivity to noise during times when people are typically trying to sleep dB ....................................... decibel, referring to a unit measured on the decibel scale used to quantify sound levels dBA..................................... A -weighted decibel, a system for weighting measured sound levels to reflect the frequencies that people hear best Distance attenuation .............. the rate at which sound levels decrease with increasing distance from a noise source based on the dissipation of sound energy as the sound wave increases in size (think of a balloon getting thinner as it becomes more inflated) Equivalent sound level (Leq) ... A sound level metric that is the level that if held constant over the same period of time would have the same sound energy as the actual, fluctuating sound (i.e., an energy - average sound level) Leq..................................... . Equivalent sound level (see above) Ln........................................ Statistical noise level, the level exceeded during n percent of the measurement period, where n is a number between 0 and 100 (for example, L50 is the level exceeded 50 percent of the time) Noise criteria ........................ A set of definitions establishing the conditions under which a noise impact is determined to have occurred. Noise impact ......................... A measured or model -calculated condition in which the absolute (i.e., total) sound level and/or a project -related sound level increase exceed a defined noise impact criterion. Noise metric ........................ One of a number of measures used to quantify noise (e.g., Leq, or Lmax) SLM ................... . ................. Sound level measurement Sound level ......................... Sound pressure level (see below) Sound power level ................. A measure of the sound energy emitted by noise source expressed as energy per unit of time. Not to be confused with sound pressure level. Contents i i P Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT Sound pressure level .... , ....... Ten times the base-10 logarithm of the square of the ratio of the mean square sound pressure, in a stated frequency band (often weighted), and the reference mean -square sound pressure of 20 pPa (micro pascals, a standard reference unit of pressure), which is approximately equal to the threshold of human hearing at 1 kilohertz. Sound pressure level is expressed in decibels. Type I meter ........................ A type of sound level meter defined by American National Standards Institute as being to measure sound pressure levels to an accuracy within 0.5 dBA Contents iv Ramball FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT INTRODUCTION 1.1 Project Description Federal Way Campus, LLC is proposing to develop three new buildings of varying sizes. The Technology Center (Tech Center) will remain; however, the parking lot associated with the Tech Center will be reconfigured to allow for the construction of the new warehouse buildings (the Project). Building A will be 638,000 square feet in size, Building B will be 282,500 square feet in size, and Building C will be 147,500 square feet in size. The Project will include accessory parking for up to 1,466 vehicles. Site access will be provided by four driveways located on Weyerhaeuser Way South. Right -of -Way dedication and frontage improvements to meet the City's Comprehensive Plan area are also proposed as part of the Greenline Business Park Development. At the time of this analysis, the exact use of the warehouses had not been established. However it is anticipated that the warehouses will be used for general commodities that do not require cold storage. Furthermore, the warehouses will not include processing or manufacturing facilities. Equipment typical of a general commodities warehouses include HVAC units to provide heating and cooling to office spaces; air handling equipment, such as make-up air units (MUAs), to provide heat and ventilation to warehouse spaces; rooftop exhaust vents; emergency generators; and access for truck deliveries and product loadout. 1.2 Rationale for Noise Study The City of Federal Way has established submittal requirements for Process III applications. These requirements include topographical surveys, site plans, drainage, building design, and noise studies to support the application. The City is also requiring a SEPA checklist be submitted as part of the application. The checklist includes the following questions pertaining to noise: ID SEPA 7(b)(1): What types of noise existing in the area that may affect your project? • SEPA 7(b)(2): What types and levels of noise would be created by or associated with the project on a short-term or a long-term basis? • SEPA 7(b)(1): Proposed measures to reduce or control noise impacts, if any? The following noise assessment has been prepared to respond to the requirements of the City's Process III application and to support SEPA checklist and threshold determination. The noise assessment evaluates both short-term noise from construction of the Project and long-term noise from operation of the Project. The assessment of operational noise evaluates compliance with applicable noise limits and the potential for noise impacts due to increases over existing sound levels. Introduction 1 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT NOISE TERMINOLOGY AND DESCRIPTORS Noise is sometimes defined as unwanted sound. This report makes no such distinction, and the terms noise and sound are used more or less synonymously. The human ear responds to a very wide range of sound intensities. The decibel scale (dB) used to describe sound is a logarithmic rating system which accounts for the large differences in audible sound intensities. This scale accounts for the human perception of a doubling of loudness as an increase of 10 dB. Therefore, a 70-dB sound level will sound about twice as loud as a 60-dB sound level. People generally cannot detect differences of 1 or 2 dB. In ideal laboratory situations, differences of 2 or 3 dB can be detected by people, but such a change probably would not be noticed in a typical outdoor environment. A 5-dB change would probably be clearly perceived by most people under normal listening conditions. On the logarithmic decibel scale used to describe noise, a doubling of sound -generating activity (i.e., a doubling of the sound energy) causes a 3-dB increase in average sound produced by that source, not a doubling of the loudness of the sound (which requires a 10- dB increase). For example, if traffic along a road is causing a 60 dB sound level at some nearby location, twice as much traffic on this same road would cause the sound level at this same location to increase to 63 dB. Such an increase might not be discernible in a complex acoustical environment. When addressing the effects of noise on people, it is useful to consider the frequency response of the human ear. Sound -measuring instruments are therefore often programmed to "weight" measured sounds based on the way people hear. The frequency -weighting most often used is A -weighting because it approximates the frequency response of human hearing and is highly correlated to the effects of noise on people. Measurements from instruments using this system are reported in "A weighted decibels" or dBA. All sound levels in this evaluation are reported in A weighted decibels. Relatively long, multi -source "line" sources, such as roads with continuous traffic, emit cylindrical sound waves. Due to the cylindrical spreading of these sound waves, sound levels from such sources decrease with each doubling of distance from the source at a rate of about 3 dBA. Sound waves from discrete events or stationary "point" sources, such as a car horn, spread as a sphere, and sound levels from such sources decrease 6 dBA per doubling of the distance from the source. Conversely, moving half the distance closer to a source increases sound levels by 3 dBA and 6 dBA for line and point sources, respectively. For a given source, a number of factors affect the sound transmission from the source, which in turn affect the potential for noise impacts. Important factors include distance from Noise Terminology and Descriptors 2 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT the source, frequency of the sound, atmospheric conditions, absorbency and roughness of the intervening ground surface, the presence or absence of intervening obstructions (e.g., buildings), and the duration of the noise -producing event. The degree of impact on humans also depends on who is listening (individual physiological and psychological factors) and on existing sound levels (background noise). Noise Terminology and Descriptors 3 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT 3. REGULATORY SETTING 3.1 City of Federal Way The City of Federal Way has established a noise ordinance in the Federal Way Revised Code (FWRC) Chapter 7.10, Noise. FWRC 7.10.050(1) adopts the maximum permissible sound level limits identified in the Chapter 173-60 of the Washington Administrative Code (WAC 173-60, see Section 3.2). FWRC 7.10.020, Public Disturbance Noise, also identifies activities and events that are considered by the City to cause a public disturbance. FWRC 7.10.020(8) identifies construction noise as a public disturbance noise when it occurs between the hours of 8:00 p.m. and 7:00 a.m. on weekdays and 8:00 p.m. and 9:00 a.m. on weekends. 3.2 Washington Administrative Code The City of Federal Way adopts the sound level limits established in WAC 173-60. WAC 173-60 identifies limits on sounds crossing property boundaries based on the Environmental Designation for Noise Abatement (EDNA) of the sound source and the receiving properties. EDNA classifications are typically designated based on land uses as follows: EDNA Class A: Lands where human beings reside and sleep (e.g., residences, hospitals). EDNA Class B: Lands involving uses requiring protection against noise interference with speech (e.g., commercial and retail businesses, offices, public services). EDNA Class C: Lands involving economic activities of such a nature that higher noise levels than experienced in other areas is normally to be anticipated (e.g., industrial property; warehouse and distribution facilities). The applicable noise limits for EDNA source and receiver combinations are listed in Table 1. Table 1. WAC Maximum Permissible Sound Level Limits EDNA of Source Property EDNA of Receiving Property Class A (a) Class B Class C Class A 55 57 60 Class B 57 60 65 Class C 60 65 70 (a) The limitations for noise received in Class A EDNAs are reduced by 10 dBA during nighttime hours, defined in the state rule as 10 p.m. to 7 a.m. Source: WAC 173-60-40 Regulatory Setting 4 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT The "maximum permissible" environmental noise levels may be exceeded for short periods by a total of not more than 15 minutes in any one -hour period. The allowed short-term increases follow: up to 5 dBA for no more than 15 minutes in any hour, or up to 10 dBA for no more than 5 minutes of any hour, or up to 15 dBA for no more than 1.5 minutes of any hour. These allowed short-term increases can be described in terms of noise metrics that represent the percentage of time certain levels are exceeded. For example, the hourly L25 metric represents the sound level that is exceeded 25 percent of the time or 15 minutes in an hour. Similarly, the L8.3 and L2.5 are the sound levels exceeded 5 and 1.5 minutes in an hour, respectively. The maximum permissible levels are not to be exceeded by more than 15 dBA at any time, and this limit is represented by the Lmax noise metric. The zoning for the Project site is Corporate Park (CP-1). The proposed use of the site as warehouses or distribution facility would result in its classification as a Class C EDNA noise source. Residential properties in the Project vicinity are classified as Class A receiving properties. Adjacent commercial buildings are designated Class B EDNA receivers. Regulatory Setting 5 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT 4. EXISTING ENVIRONMEN' 4.1 Affected Environment The Project would be located on three adjoining parcels encompassing approximately 99.5 acres, and the three new warehouses would cover approximately 1,068,000 square foot area (see Appendix A, Figure 3), with additional area for parking and truck loading. The warehouses would be bordered to the east by Weyerhaeuser Way S and the west shore of North Lake, beyond which are residential land uses; to the north by commercial buildings; to the west by I-5, beyond which are residential land uses; and to the south by commercial property currently operated by Weyerhaeuser. The Weyerhaeuser Tech Center is located on the existing Project site, surrounded by densely wooded vegetation. The Tech Center will remain, however the parking lot associated with the Tech Center will be reconfigured and some of the densely wooded area would be cleared to make room for the new warehouse buildings, parking lots, and driveways. 4.2 Existing Noise Environment The existing acoustic environment within the Project vicinity is typical of a suburban area relatively close to major highways and/or local roadways. The main source of noise in the Project vicinity is from traffic along I-5 and Weyerhaeuser Way South. A sound level measurement was taken in December 2016 to characterize the existing noise environment in the project vicinity. The sound level measurement was conducted over a period of four days, including both weekdays and weekend days, at a location representative of residential properties in the vicinity of the Project, at 33636 30th Avenue S in Federal Way. The meter was placed in the backyard of this property to represent noise levels experienced at outdoor residential use areas near North Lake. The measurement location is illustrated in Appendix A, Figure 1. The sound level measurement was taken using a Larson Davis model LxT Class I sound level meter set to capture hourly data over the four -day period. The meter's microphone was placed in an acoustically -neutral wind screen positioned approximately five (5) feet above ground. The meter was factory calibrated within the previous 12 months and was field calibrated immediately prior to use. The meter was located below the grade of Weyerhaeuser Way S and there was no direct line of sight between the meter and Weyerhaeuser Way S. However, when present, traffic noise from this road was a dominant noise source. Traffic noise from I-5, approximately 2,200 Existing Environment 6 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT feet northwest, was observed as continuous and a steady source of background noise. Additional noise sources included infrequent miscellaneous residential activity and birds. Sound level measurement data are summarized in Table 2 and depicted graphically in Figure 2. Included in Table 2 is the range of hourly average Leq' and hourly Ln2 sound level data for daytime (7 a.m. to 10 p.m.) and nighttime (10 p.m. to 7 a.m.) periods, as well as the day -night sound level (Ldn3) for each day. Table 2. Ambient Noise Monitoring Summary (dBA) Time of Range of Hourly Sound Levels (b), (`) Period of Day (a) Ldn Leq Range Us L8.2 Lz.s Lmax Measurement Day 51-59 52-59 54-62 56-65 63-77 59 - 60 Weekday Night 50-58 49-58 51-62 53-65 59-76 Day 52-58 50-56 53-62 59-66 67-78 59 Weekend Night 46-55 47-54 48-61 49-65 54-73 (a) "Day" refers to the hours between 7 a.m. and 10 p.m., "Night" to the hours between 10 PM and 7 AM. (b) Contributing sound sources included traffic from Weyerhaeuser Way S, 1-5, and SR-18, as well as nearby residential activity and birds. (`) The L2.5, L8.3, and L25 levels are defined previously in this report in the discussion of the regulatory noise limits. Source: Ramboll The range of data provided in Table 2 indicate that daytime sound levels varied only slightly between weekday and weekend day and night periods. As indicated, the applicable WAC sound level limits are based on maximum permissible sound levels and allowed exceedances of these limits (e.g., L25, L8.3,. etc.). This assessment of existing conditions includes a computation of these WAC metrics for 1 The Leq is the level that if held constant over the same period of time would have the same sound energy as the actual, fluctuating sound. As such, the Leq can be considered an energy -average sound level. This metric should not be confused with an arithmetic average which tends to de- emphasize high and low values. The Leq noise metric has been found to be highly correlated to community response to noise, and is often the metric calculated by noise models used to assess potential impacts and the need for mitigation. z The "n" in Ln is the percent of time that a sound level is exceeded and is used describe the range of sound levels recorded during the measurement period. For example, the L8.3 level is the noise level that is exceeded 8.3% of the time (e.g., 5 minutes in any one hour). 3 The day -night sound level, Ldn, is similar to a 24-hour Leq, Leq(24), except that a 10-decibel penalty is added to sound levels between 10 p.m. and 7 a.m. to account for potential sleep interference. Existing Environment 7 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT comparison, however note that the WAC limits apply only to an assessment of compliance of the future Project, relative to noise received at nearby residential properties. The highest levels of noise occurred during the typical morning commute period (i.e., between 6 a.m. and 8 a.m.) and evening commute period (i.e., between 5 p.m. and 7 p.m.). Although Ramboll staff were not present during all measurement hours, it is likely that traffic on Weyerhaeuser Way S was the source of the highest levels of noise received during these peak commute periods. A full tabulation of all hourly sound level data can be made available upon request. See Appendix A, Figure 2 for a graphical overview of hourly sound level measurement results. Note that the proposed Project is assumed to operate 24 hours per day, 7 days per week, although truck traffic activity and generator testing would occur only during daytime hours. Therefore, the lowest nighttime hourly sound level (46 dBA, Leq), measured between 4 a.m. and 5 a.m. on Sunday, December 18, 2016, was used to represent the average existing noise environment when assessing the potential for a worst -case increase over ambient nighttime conditions (i.e., operation of the Project during nighttime hours). During daytime hours, the lowest measured sound level was 51 dBA, Leq, measured between 12 p.m. and 1 p.m. on Thursday, December 15, 2016, and was used to represent the average existing noise environment during daytime hours. The nighttime and daytime sound levels have been assumed to be representative of the existing noise environment at all residential receiving properties east of the Project. West of the Project, the nearest residential properties are located adjacent to I-5 and dominated by highway traffic noise. Existing noise levels west of I-5 have been assumed to be 50 dBA during nighttime hours and 60 dBA during daytime hours. Existing Environment 8 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT ;. NOISE IMPACT ASSESSMENT 5.1 Construction Noise Assessment During construction of the proposed warehouses, there would be temporary increases in sound levels near active construction areas of the properties due to the use of heavy equipment and along roadways used for hauling construction materials and for removal of clearing material (e.g., trees, earth). The increases in noise levels would depend on the type of equipment being used and the amount of time it is in use. Expected activities include clearing, grading, excavation, road building, paving, and building construction. Table 3 displays typical noise levels produced by equipment that could be used during construction of the Project. Noise from construction equipment decrease at a rate of about 6 dBA for each doubling of distance from the source. Typical construction sound levels are given for distances of 100, 200, and 400 feet to give some idea of equipment sound levels at varying distances. Table 3. Typical Noise Levels From Construction Activities & Equipment (dBA) Activity Range of Hourly Leqs At 100 Feet At 200 Feet At 400 Feet Clearing 77 71 65 Grading 69-82 63-76 57-70 Paving 66-82 60-76 54-70 Erection 66-78 60-72 54-66 Types of Equipment Range of Hourly Sound Levels At 100 Feet At 200 Feet At 400 Feet Bulldozer 71-90 65-84 59-78 Dump Truck 76-88 70-82 64-76 Scraper 74-87 68-81 62-75 Paver 80-82 74-76 68-70 Generators 65-76 59-70 53-64 Compressors 68-75 62-69 56-63 Source: EPA and others, compiled by Ramboll Noise Impact Assessment 9 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT Site development and construction of the proposed warehouses could generate relatively high sound levels on and near the project property, particularly at commercial facilities to the north. Primary sound sources could include excavation and grading equipment, large haul trucks used for materials such as concrete, and earth and tree removal. Other smaller pieces of equipment may include generators, compressors, and pumps all with the potential to contribute to cumulative noise emissions during construction. As summarized above in Section 3, FWRC 7.10.020(8) states that sounds from construction sites during nighttime hours are considered a public disturbance (nighttime hours are defined by the City of Federal Way as between 8:00 p.m. and 7:00 a.m. on weekdays and between 8:00 p.m. and 9:00 a.m. on weekends). During daytime hours, when Project construction is expected to occur, construction activities could result in elevated levels of noise near the Project site. Although daytime construction could be perceived as intrusive at residential properties, the temporary nature of construction activities, as well as the limitation of construction to daytime hours only, is expected to minimize the potential for noise impacts. In addition, the developer would be expected to employ best management practices to reduce construction noise. 5.1.1 Construction Noise Best Management Practices The following best management practices, if employed by the construction contractor, would reduce the potential for high levels of noise during construction activities, and may reduce the potential for perceived noise impact: • Require that all equipment be fitted with properly sized mufflers, and if necessary, engine intake silencers • Require that all equipment be in good working order. • Use quieter construction equipment models if available, and whenever possible use pneumatic tools rather than diesel or gas -powered tools. • Place portable stationary equipment as far as possible from existing residential and noise -sensitive commercial areas, and if necessary, place temporary barriers around stationary equipment. • For mobile equipment, consider replacing typical pure -tone backup alarms with ambient - sensing and/or broadband backup alarms. 5.2 Operational Noise Assessment Operation of the proposed warehouses is expected to generate noise emissions that would be received at nearby residential and commercial facilities. Noise from stationary equipment, as well as from mobile sources such as trucks, are common at a light industrial business parks. The following summarizes the assessment completed to evaluate operational noise from these sources and includes a summary of the noise model used for Noise Impact Assessment 10 RamboH FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT the assessment, details of the expected sound sources, a review of nearby noise sensitive receiving properties, and assessment results. 5.2.1 Noise Prediction Model Ramboll completed noise modeling using the CadnaA noise model, based on the noise propagation algorithms established in ISO 9613-2. CadnaA is a computerized noise prediction model that can calculate sound levels after considering the noise reductions or enhancements of a range of factors including distance, topography, ground surface types, intervening structures, atmospheric absorption, and meteorological conditions. Noise sources were based on frequency -specific measurements of representative equipment or on estimates of equipment noise levels based on relative throughput ratings for specified equipment. The modeling considered noise emissions from all Project -related sources and predicted off -site sound levels at nearby receptor locations. The Project buildings were modeled at an assumed height of 30 feet, and local topography was imported from a publicly -available online source. Ground was assumed to be soft, or acoustically "absorptive", with the exception of paved roads, parking lots, and North Lake. 5.2.2 Emission Sources Noise modeling was completed based on assumed business park operations for each of the proposed new warehouses. Note that the existing building also was included in the modeling assessment to fully assess overall noise emissions from the business park. Sound level data for typical warehouse sources were taken from Ramboll's sound source library and included the sources identified in Table 4. Noise Impact Assessment 11 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT Table 4. Noise Source Summary by Building Building Equipment Type Total Number of Units b'` Operating Period Tech Center (Existing Building) HVAC 3 Day / Night Exhaust Fan 20 Day / Night Make Up Air Unit 8 Day /Night Cooling Tower a 2 Day / Night Emergency Generator 1 Day Building A HVAC 5 Day / Night Exhaust Fan 10 Day / Night Make Up Air Unit 15 Day / Night Emergency Generator 1 Day Building B HVAC 6 Day / Night Exhaust Fan 15 Day / Night Make Up Air Unit 12 Day / Night Emergency Generator 1 Day Building C HVAC 3 Day / Night Exhaust Fan 12 Day / Night Make Up Air Unit 6 Day / Night Emergency Generator 1 Day Truck Routes (All Buildings) Building A, North Side 19 trucks/hr Day Building A, South Side 19 trucks/hr Day Building B & C 19 trucks/hr Day cap Each cooling tower assumed to have 2 fans, modeled as 2 sources per tower (b) Each unit modeled as an individual noise source (`) All units assumed to be operating continuously over an hour Source: Ramboll As noted in Table 4, all sound sources were assumed to operate continuously and concurrently during daytime hours (i.e., between 7 a.m. and 10 p.m.). Note that the assessment also assumes that all emergency power generators would be tested simultaneously for a full hour, an unlikely and worst -case operating scenario. During nighttime hours, there would be no truck traffic at the business park and no testing of the emergency power generators. Noise Impact Assessment 12 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT An illustration of the assumed location of equipment at each warehouse is found in Appendix A, Figure 4. Table 5 provides a tabular summary of the sound levels for each source used in this assessment. Table 5. Noise Source Sound Levels (dBA) Source Type Number of Units Sound Power Level Per Unit (dBA) Rooftop HVAC Unit 17 86 dBA (a) Rooftop Exhaust Fan 62 90 dBA (a) Rooftop MUA Unit 36 88 dBA (a) Cooling Tower Fan 4 88 dBA 1a) Emergency Generator 4 100 dBA (61 Truck Route 56 per hour total over 3 routes (19 each) 104 dBA (per truck) (a) (d) Sound power level based on sound level measurements taken by Ramboll (e) Sound level for generator based on manufacturer specifications for 30 kW generator plus 5 dBA penalty added to conservatively estimate potentially larger generators at the Project. Source: Ramboll 5.2.3 Noise Sensitive Receivers Noise modeling was completed to estimate operational noise levels at receptors in the Project vicinity. A graphical illustration of noise -sensitive receiving locations is found in Figure 3. 5.2.4 Noise Modeling Results — Assessment of Compliance with WAC Limits Model -calculated sound levels are presented in Table 7, and graphical representations of results for daytime and nighttime hours are found in ADaendix A, Figure 5 and Figure 6, respectively, illustrating noise contours for each time period. At the nearest Class A EDNA receiver represented by R8, located west of I-5 (see Figure 3), predicted worst -case operating conditions would result in an hourly nighttime sound level of 40 dBA, well below the applicable nighttime limit of 50 dBA. During daytime hours the predicted sound levels at R8 would be 45 dBA, well below the applicable daytime limit of 60 dBA. East of the Project, the nearest residences are represented by receptor R4 (see Figure 3), representing west -facing waterfront property on North Lake. At R4, Project sound levels could reach up to 44 dBA during daytime hours and 38 dBA during nighttime hours. Noise Noise Impact Assessment 13 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT levels in this range are far below the applicable WAC day and night limits of 60 dBA and 50 dBA, respectively. At the nearest Class B EDNA receiver, represented by C1, located adjacent to the north of the Project (see Figure 3), predicted worst -case operating conditions would result in an hourly sound level of 54 dBA, well below the applicable limit of 65 dBA (applicable during both daytime and nighttime hours). Operational sound levels at all remaining Class B EDNA receivers are predicted to be lower than 54 dBA. Operation of the Project is expected be in compliance with the applicable WAC sound level limits at all nearby Class A and Class B EDNA receivers during both daytime and nighttime hours. 5.2.5 Noise Modeling Results — Assessment of Increase over Existing Conditions The assessment of increase in noise over ambient conditions is determined by adding Project noise to ambient noise levels, and evaluating against ambient noise levels without the Project. Note that Project noise levels that are 10 dBA or more below ambient conditions, when added to ambient noise levels, would result in no net increase in noise. The nearest Class A EDNA receiver (R8), is located on the west side of I-5, very near the highway, and very likely dominated by I-5 traffic noise. As indicated, ambient sound levels at this location conservatively have been assumed to be 50 dBA during nighttime hours and 60 dBA during daytime hours. Therefore Project -related noise levels of 40 dBA during nighttime hours and 45 dBA during daytime hours would result in no noise increase and would not be audible at this location. East of the Project site, on the east side and north of North Lake, noise sensitive receptors currently are exposed to much quieter ambient noise levels, assumed to be similar to measured levels (see Table 2). Worst -case and unlikely Project operating conditions during nighttime hours would be up to 38 dBA at the most affected receptor, R4. The Project therefore would be well below the quietest nighttime sound level of 46 dBA, and would result in an acoustically negligible increase of 1 dBA over ambient conditions. During daytime hours, worst -case operation of the Project would be up to 44 dBA at this location, well below the quietest daytime hour sound level of 51 dBA during weekdays, and resulting in an acoustically negligible increase of 1 dBA over ambient conditions (see Table 2). Note that increases over ambient conditions are not evaluated for commercial receivers. 5.2.6 Additional Considerations — Loading Docks Noise emissions from up to 56 trucks per hour, divided equally over 3 truck routes, would include driveways for ingress and egress, as illustrated in Figure 4. Although trucks would Noise Impact Assessment 14 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT be expected to load and unload at warehouse loading docks, noise from typical loading dock activities would be negligible when compared to noise from truck movement. Therefore, loading dock activity is not anticipated to generate noise emissions that would exceed the sources evaluated for this study. 5.2.7 Additional Considerations —Off Site Traffic Noise from traffic traveling on public roadways is exempt from WAC 173-60 for vehicles regulated under WAC 173-62 (WAC 173-60-50(4)(a)). Therefore, noise from traffic accessing the Project would be exempt from the WAC (and therefore from FWRC) when traveling on public roadways. However, increases in traffic volumes on area roadways may result in increases in ambient noise levels during peak Project hours. Trucks accessing the Project (maximum assumed total volume of 56 trucks per hour) are expected to arrive along Weyerhaeuser Way South to/from SR-18 to the south, or S 320th Street to the north. Automobile traffic accessing the Project, including staff and visitors, would access the site using the ingress/egress points on Weyerhaeuser Way South. Class A EDNA receivers identified along the potential access routes are south of the Project, north of the roundabout at Weyerhaeuser Way South and 33rd Place S (in the vicinity of R7). Applying traffic volumes from the Project's traffic study, during the a.m. or p.m. peak - hour periods, existing sound levels at the Class A EDNA (residence) near the roundabout are estimated to be approximately 62 dBA. A future No Build scenario (i.e., without the Project) would result in sound levels of 63 dBA. With the Project, sound levels during the a.m. and p.m. peak hour periods increase to 64 dBA, a 1-dBA increase over the No Build peak periods. Note that a 1-dBA increase is acoustically insignificant and would be not be noticed. Therefore Project -related traffic is not expected to result in off -site traffic -related impacts. Results are summarized in Table 6. Table 6. Off -Site Traffic Noise near R7 (dBA) Existing Sound Levels Future No Build Scenario Future With Project Scenario Increase, With (AM & PM Peak Period) (a) (AM & PM Peak Period) jai (AM & PM Peak Period) (b) Project over No BuildScenario 1 62 1 63 1 64 1 1 1 Notes: AM and PM peak period traffic volumes result in approximately identical sound levels near R7 Traffic modeling based on an assumed traffic composition of 97% cars, 2% medium duty trucks, 1% heavy duty trucks (b) Traffic modeling based on same existing and No Build traffic composition, plus an assumed additional 28 heavy-duty trucks, representative of half of all Project -related truck traffic during the peak -hour periods Source: Ramboll Noise Impact Assessment 15 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT 5.2.8 Operational Noise Assessment Results Summary As indicated, operation of the Project is expected to comply with WAC noise limits at all nearby Class A and Class B EDNA receivers, as is summarized in and _ . The predicted worst -case increase over existing conditions during nighttime and daytime hours is not expected to be perceptible at the nearest Class A EDNA receivers. Noise mitigation measures are not warranted at this time for on -site sources of noise. In addition, off -site increases in traffic noise due to the Project are estimated to be acoustically insignificant and would not result in off -site traffic noise impacts. Noise Impact Assessment 16 Ramboll z� �a w =w �o z z gw f W Z LU iy LU w z LU m u u C 3 M1, o R s C VI U � o a Q V) v VI Vf V) VI {n VI v V) a, VI v V) +, O y E °c v Q a` u o u � O d E z u W Ln v d Z C LnlD H IA a C 3 r + o °' °' O 0 a o ++ C : d .a O .... ++ N c0 7 C O 41 -0 0 7" Q O O O r-I r-I a --I O O O v o= N N O c V LA R ai cuo c — w, ' U m O O O O CO > N u C c N E in cYi c O O } C H Q O W c u O N O Ln O 3c C -O u 4� a) CU y E 0. 7 m O` V) VI C W U u + lD lD LD 1, I, n LD O L, O L,' y^ v� �� Q �+ c L Ql aE > > o >. 'W 'a � a m o m E � m u u IA N 4+ w w j a L Q Q Q Z z Z 00 IA5 '0 3 041 ao�mm Ln c v, 7 2 j y O m two c�a 0 y c 08 U U E > 0 3 o O O m c ':- Ln m .D m Ln m oo m oo m I- m ui m o O v m Q N - O N no o > *' m m aui Z m y y E u u �n LD of c = a C. Q Q 4' Z Z 00 c 1� N O In (a fa v `u ` O #+' ^ O u W C NkD ao C C Q r- > Z O Ln v E c ++ N t v1 LnN ._ C'^ i - > x +`n' c z Z b- N — Y N Ch vOi W o) 4-1 O O Z u m dA °+�' v E E E 00 Co V)fa a a dr-i cNc m-;t Ln ko r� 000 a) U w ~ Q Q 3 OC ° g S " N 0 m E ce C E H d y Q 1�0 a E U) 'O Z (D0- z) \LU 0 \F- }� 00 $\ E � ■ � k 0 _ ■ E � e a � � � Ch c � � 0 � ■ � f � ■ � ■ � a) m=to k� J LL 2 211 \ \ \ \ \ \ \ \ \ \ ƒ v § 0 3m % E k . « / § 2 3 L a ■ u S m � �� a » i w § + g e . 0 ) { am, m o f§ e 2 0_ 0_j e 0 0 0 0 I {\ W. X M ■ © co [ @ ; — o CO e s 2 t E c # /f1- ICL \C\/ CD { o 2 0 2 -CO) y ( z e e� _ 0 0= § ° % u - r Ln Ln Ln Ln Ln tD w- E 2 /K $§ w 2 c C> > 2 a 0& 3 5 E aE\ }} � 7 k z z � E ��=R00 q E2 �Z//f2 § § 0 § ! 2 £ 2 $ 2§ E a$= u u 0 > 0 2 41 CO S. # m� 0 Ln m#< o - ;2 © o # « - _ $ / -0 _ - o 0 $ -� ; M m > @ £ a a � tD c — a2 § \2W m2»0t \c ba �� \ \/V, E ; § W e Cl) �— k _ $� o E r 2 _�--- _ «->§ G S I 1 M t- a J 2 _� - \ x k� z z ; 4- ba 2' afI§E/tf z \ E-02 C- 7 co\) k V M 2 & § § w J##§ l cc w w J£ƒ w= E u§ Q 2 0 a « S I I m E ce co § § � a � E JA z FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT CONCLUSIONS The proposed Project would be located on three adjoining parcels encompassing approximately 99.5 acres, and the three warehouses would cover approximately 1,068,000 square foot area in Federal Way, Washington. The noise assessment was prepared to respond to the requirements of the City's Process III application and to support the Project's SEPA checklist. Sound level measurements were taken at a residential property located immediately southeast of the proposed business park, on a property owned by Weyerhaeuser, and considered representative of residential properties evaluated for this study. Construction of the Project is expected to comply with the public disturbance nighttime timing restrictions established within the Federal Way Revised Code. Temporary daytime construction noise is expected to result in short-term increases in noise that may be mitigated by simple, common sense techniques to reduce construction noise. During operation, noise emissions for equipment common to warehouses were assumed for the Project including rooftop HVAC units, Make -Up Air units, and exhaust fans; cooling towers; emergency generators, and; truck traffic. A noise model was prepared to estimate operational noise at nearby residential (Class A EDNA) and commercial (Class B EDNA) receivers. An assessment of noise impact was based on compliance with the applicable WAC noise limits, and on the predicted increase over existing ambient conditions at EDNA Class A receivers. The noise study found that the proposed Project would comply with all applicable WAC limits during both daytime and nighttime hours. Further, the Project is expected to result in insignificant or no increases over the existing ambient noise environment at the nearest residential properties during both nighttime and daytime hours. Project related traffic is expected to result in acoustically insignificant increases in off -site traffic noise along nearby access routes, when compared with a No Build scenario. Noise mitigation measures are not recommended at this time. A detailed review of final operating conditions should be completed to ensure that this noise study accurately and conservatively reflects future Project operation. Conclusions 19 Ramboll FEDERAL WAY, WASHINGTON ENVIRONMENTAL NOISE REPORT APPENDIX A Figures Appendix A Ramboll •, 1'. err• : z Oki ■r1p4, iVaR11t �t;�.i� l?r. f �+ s • �—� � fake . - • ti_l � ` �"`• , -71 * ' �fi t+ it fr7 r4 ti. • •S � • �•� • • 7 CrEdlls: 57urcB: Esr€r p ; . , i r 7islIIrG[bglaphlr�rr CN 1'�T15. � .- r`:, ��,S• "-�; •n rk'.',. p �bA, A1( GelmapA, Ate !t- �, .. •k� • ' z p (Da u, z =w �O z �z z Qw f wz p0 Lu� z lL m 4-j 0 N � O N d1 L � m � N M N to N � N OL J � 3 Q O N r-I w aN—I b4 C O _J to d LO CO r4 �N-I N � a SG n� 4 ta ER Ln Ln v $ (Vgp)1aAw1 punos poinseew O m E a a x c d a a a r1Yi Y'i �i1'f 7 + Of its- � tip•- �: - '. =.1i[. 1• � ;.. Legend ;. 0 Residential Receivers r Commercial ti 900: �i.aoa SCrY1CY f-r.� 4 r[•�s1A.: Property �r GtmopGIS tG' ss;na Feet, Sh+GiS r w r _'��.- " •-. ,". 1[hSfff+ri � {�.iaf A+X�S7rt �� ..��m-++ r � .:.ice � •s Cs'■r•�i�y • , . o O p .. .. ■ yflsw••rxl4•.il7ti ►!':1 ,;+� r /�� Via.,.---�—� -3''- + ty. f s- Legend TW • Residential Receivers Commercial Receivers= { Property Boundary Truck t m� !► h Route Rooftop Sources M:O Cooling Tower P -i� AD Exhaust Fan .y . .► '�' Emergency xi •HVAC Se+virr• t.yn f SSIiM : F:.r3, OfSNt �K;lutw�C ti'nFYC:�art rGacyrnphrcz, f ..a��. .y Cfq F-S, I.6 05. US'US.0 Make �croGftl4, i ' {,• l :r-:.r�. - - -� • Airrend l},p' ,ril'IRY 'S �rBBt - .. " `�7-OWE,% . �= .. '...ri.'--s. L i {- ^", i' •} it Y:s` 'AU +� � • � 35 40• - L fir►, p -1F fyF• r �, {'• a , _yy r It. '� ^ ii t'•r Ilk y. y ,"• . io Ak 41 04 Legend 0 Residential Receivers � S ��. Se,rlta.4nygv[rgAl[�t,S9llr -f:sl�, 0 _'f90l3 1.B�fl Commercial - 6lplutk;ln6n, GCuCyt; FAr[ , Gcogrnyl,3[s. .. - CNC5lAfrhk* T)S, OS GS. ncri-lKW, S f •fir �� ^ • Boundary and the [:F „uilitr- CITY OF Fede, cal Way. Department of Community Development Services _33325 8th Avenue South Federal 98003-6325RESUBMITTE� -L APR 3 0 2018 CITY OF FEDERAL WAY COMMUNITY DEVELOPMENT SEPA. ENVIRONMENTAL CH :KLIS Purpose of checklist: Governmental agencies use this checklist to help determine whether the environmental impacts of your proposal are significant. This information is also helpful to determine if available avoidance, minimization, or compensatory mitigation measures will address the probable significant impacts, or if an environmental impact statement will be prepared to further analyze the proposal. Instructions for applicantr. This environmental checklist asks you to describe some basic information about your proposal. Please answer each question accurately and carefully, to the best of your knowledge. You may need to consult with an agency specialist or private consultant for some questions. You may use `not applicable" or "does not apply" only when you can explain whyit does not apply and not when the answer is unknown. You may also attach or incorporate by reference additional studies and/or reports. Complete and accurate answers to these questions often avoid delays with the SEPA process, as well as later in the decision -making process. The checklist questions apply to all parts ofyourproposal, even if you plan to do them over a period of time or on different parcels of land. Attach any additional information that will help describe your proposal or its environmental effects. The agency to which you submit this checklist may ask you to explain your answers or provide additional information reasonably related to determining if there may be significant adverse impact. Instructions for LeadAgemies. Additional information may be necessary to evaluate the existing environment, all interrelated aspects of the proposal, and an analysis of adverse impacts. The checklist is considered the first, but not necessarily the only source of information needed to make an adequate threshold determination. Once a threshold determination is made, the lead agency is responsible for the completeness and accuracy of the checklist and other supporting documents. Use of checklist for nonprojectproposals: ViLIW For nonproject proposals (such as ordinances, regulations, plans, and programs), complete the applicable parts of sections A and B, plus the SUPPI.I1MENI'A1. 91 If?1Ts1.' r-olt NONP1tC]m r A nom part D)_ Please completely answer all questions that apply and note that the words "project," "applicant," and "property or site" should be read as "proposal," "proponent," and "affected geographic area," respectively. The lead agency may exclude (for nonprojects) questions in Part B (Environmental Elements) that do not contribute meaningfully to the analysis of the proposal. Bulletin #050 — May 1, 2014 Page 1 of 14 k-.\Handouts\Environmental Checklist May 2014 A. BACKGROUND 1. Name of proposed project, if applicable: V1e10 "Greenline Business Park" 2. Name of applicant: "el Applicant: Federal Way Campus, LLC Agent: ESM Consulting Engineers, LLC 3. Address and phone number of applicant and contact person: Dielo Applicant: Tom Messmer c/o Federal Way Campus, LLC Address: 11100 Santa Monica Blvd, Suite 850 Los Angeles, CA 90025 310-261-4382 Agent: Eric LaBrie c/o ESM Consulting Engineers, LLC Address: 33400 8th Avenue South, Suite 205 Federal Way, WA 98003 (253) 838-6113 4. Date checklist prepared: DaelW April 30, 2018 5. Agency requesting checklist: DIdIpI City of Federal Way 6. Proposed timing or schedule (including phasing, if applicable): iel Land Use Process Approval Winter 2018 Ground Work Spring 2018 Construction Summer 2018 Completion Summer 2019 Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal? If yes, explain. iel No this proposal is a single project that will not require future additions, or further activity outside of building construction. 8. List any environmental information you know about that has been prepared, or will be prepared, directly related to this proposal. DLeIW • Evaluation of Trees by Brian Gilles Consulting, dated 9/20/17; • Title Report by Chicago Title, dated 8/8/2017; • Wetland Delineation and Mitigation Report by Talasaea, dated 10/27/17; • Geotechnical Report by GeoEngineers, dated 9/19/17; Pavement Analysis by GeoEngineers, dated 8/29/17; ® Noise Study by Ramboll dated April 2018; Air Quality Report by Ramboll dated April 2018; • Transportation Impact Analysis by TENW dated April 27, 2018; Bulletin #050 — May 1, 2014 Page 2 of 14 k:\Handouts\Environmental Checklist May 2014 ■ Preliminary Technical Information Report addressing relevance of the 9 Core and 5 Special Requirements of 2016 King County Surface Water Design Manual by ESM Consulting Engineers, LLC, dated 9/20/17; • Cultural resources Archival Study, Greenline Business Park Project, Federal Way, Washington by Cardno, Inc dated 3/16/18; • Visual Impact Exhibit prepared by Craft Architects, dated 3/22/2018; • JARPA prepared by Talasaea and submitted to United States Army Corps of Engineers on 10/19/2017 9. Do you know whether applications are pending for governmental approvals of other proposals directly affecting the property covered by your proposal? If yes, explain. haelw An administrative decision has been applied for with the City of Federal Way to authorize underbrush removal on portions of the property of which the proposed Greenline Business Park is located. A Joint Aquatic Resource Permit Application has also been submitted to USACE and DOE for review. 10. List any government approvals or permits that will be needed for your proposal, if known. hel Section 404 U.S. Army Corps of Engineers, Commercial Grade & Fill City of Federal Way, SEPA Threshold Determination, Process IV Land Use Review, NPDES Construction Stormwater Discharge Permit, Right -of -Way Use Permit, and Forest Practice Class -IV- General Application. 11. Give brief, complete description of your proposal, including the proposed uses and the size of the project and site. There are several questions later in this checklist that ask you to describe certain aspects of your proposal. You do not need to repeat those answers on this page. (Lead agencies may modify this form to include additional specific information on project description.) hel �t The proposal for Greenline Business Park seeks to develop 3 new buildings of varying sizes. The Technology Center will remain; however, the parking lot associated with the Tech Center will be reconfigured to allow for construction of the new buildings. Building A will be ±638,000 SF in size, Building B will be ±282,500 SF in size, and Building C will be ±147,500 SF in size. Pond #1 that receives stormwater runoff from Building A and associate parking will be located across Weyerhaeuser Way S. Ponds # 2, #3, #4 and #5 will be located between the property boundary adjacent to 1-5 and wetlands located west of the existing loop road that travels behind the Tech Center. Site access will be vrvi Y provided by 4 driveways located on Weyerhaeuser Way S. Right -of -Way dedication and frontage improvements along Weyerhaeuser Way S. and S 336th Street required to meet the City's Comprehensive Plan are also proposed as part of the Greenline Business Park Development. 12. Location of the proposal. Give sufficient information for a person to understand the precise location of your proposed project, including a street address, if any, and section, township, and range, if known. If a proposal would occur over a range of area, provide the range or boundaries of the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if reasonably available. While you should submit any plans required by the agency, you are not required to duplicate maps or detailed plans submitted with any permit applications related to this checklist. hIel 0 A site plan with vicinity map has been included with the Land Use Application package. The current site address for the Weyerhaeuser Technology Center (WTC) is 32901 WEYERHAEUSER WAY S FEDERAL WAY, WA 98001. The northern portion of the development is located in the NE Quarter, of Section 16, Township 21, Range 4. The southern portion of the development is located in the SE Quarter of Section 16, Township 21, Range 4. See Exhibit A of the title report included with the Land Use application for a complete legal description of the property. Bulletin #050 — May 1, 2014 Page 3 of 14 k:\Handouts\Environmental Checklist May 2014 i-1) The largest building will be located north of the WTC and the two other buildings will be located south of the WTC. B. ENVIRONMENTAL ELEMENTS Ihel 1. Earth a. General description of the site VIOW (underline/circle one): Flat, rolling,hiUy, steep slopes, mountainous, other The site slopes down to the west and south from about Elevation 450 feet in the northwest to about Elevation 394 feet in the south. b. What is the steepest slope on the site (approximate percent slope)? VLelpj ±15 c. What general types of soils are found on the site (for example, clay, sand, gravel, peat, muck)? If you know the classification of agricultural soils, specify them and note any agricultural land of long-term commercial significance and whether the proposal results in removing any of these soils. VLelp4 Varying thicknesses of forest duff and/or topsoil and sod were encountered from ground surface to depths ranging from about 1 to 18 inches in most of the explorations. All explorations encountered and Were terminated in glacial deposits. Dense to very dense glacial till was typically encountered beneath a loose to dense or stiff to very stiff weathered till. d. Are there surface indications or history of unstable soils in the immediate vicinity? If so, describe. �l None e. Describe the purpose, type, total area, and approximate quantities and total affected area of any filling, excavation, and grading proposed. Indicate source of fill. JhelPJ The purpose of site fill and grad activities is to provide an adequate and level building and parking surface. There will be ±308,200 cubic yards of cut and ±275,700 cubic yards of fill for a net cut quantity of ±32,500 cubic yards. During final engineering, additional work will be done to balance the site. CVuti; �`"` ' ( �J`►1 f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe. Zel Erosion could occur as a result of clearing and construction, particularly if earthwork is completed during periods of rainfall. TESC measures will be implemented as approved by the City prior to construction. g. About what percent of the site will be covered with impervious surfaces after project construction (for example, asphalt or buildings)? Lhel 32 acres (±1,393,920 Square Feet) out of 146 acres= ±21% of the site h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: iel The owner will institute an erosion control plan to be used during earthwork and construction. 2. Air Bulletin #050 — May 1, 2014 Page 4 of 14 k:\Handouts\Environmental Checklist May 2014 a. What types of emissions to the air would result from the proposal during construction, operation, and maintenance when the project is completed? If any, generally describe and give approximate quantities if known. hel Some heavy machinery exhaust and dust particulates generated primarily by construction equipment. 5A,t, 5��c b. Are there any off -site sources of emissions or odor that may affect your proposal? If so, generally describe. BLelpi No c. Proposed measures to reduce or control emissions or other impacts to air, if any:D-ielpj All construction equipment will be in proper working order and regulated for emissions by the manufacturer and local emissions laws. Vehicles entering and leaving the site will also be regulated for emissions by state and local emissions laws. During construction the site will be watered as necessary to keep any dust from impacting surrounding air quality. 3. Water a. Surface Water el 1) Is there any surface water body on or in the immediate vicinity of the site (including year-round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type and provide names. If appropriate, state what stream or river it flows into. DLelw There is 1 man-made fish -bearing stream on -site that originates from the discharge point of the on -site stormwater pond for the Tech Center. There are 63 wetlands within the Site. North Lake abuts the eastern edge of the Site. See attached Wetland report prepared by Talasaea Associates for more details. All wetlands ultimately discharge to Hylebos Creek to the south via surface or groundwater connections. 2) Will the project require any work over, in, or adjacent to (within 200 feet) the described waters? If yes, please describe and attach available plans. lDieIW Yes. Approximately 0.421-acre (18,340 square feet) of wetlands will be impacted. While no impacts are proposed to the onsite stream feature, the stormwater pond which provides the majority of flow to the stream will be modified as part of the proposed development. See attached plans for details. 3) Estimate the amount of fill and dredge material that would be placed in or removed from surface water or wetlands and indicate the area of the site that would be affected. Indicate the source of fill material. DWO - -___1 Total wetland fill to equal 1 43 q are feet (0.308 acres). Source of fill will be from site native soil or structural fill fro an approved provider. 4) Will the proposal require surface water withdrawals or diversions? Give general description, purpose, and approximate quantities if known. Vidlo No 5) Does the proposal lie within a 100-year floodplain? If so, note the location on the site plan. VLe1pJ No 6) Does the proposal involve any discharges of waste materials to surface waters? If so, describe the type of waste and anticipated volume of discharge. Le_1 J Bulletin #050 — May 1, 2014 Page 5 of 14 k:\Handouts\Environmental Checklist May 2014 No b. Ground Water 1) Will groundwater be withdrawn from a well for drinking water or other purposes? If so, give a general description of the well, proposed uses, and approximate quantities withdrawn from the well. Will water be discharged to groundwater? Give general description, purpose, and approximate quantities if known. Ihel No 2) Describe waste material that will be discharged into the ground from septic tanks or other sources, if any (for example: domestic sewage; industrial containing the following chemicals... ; agricultural; etc.). Describe the general size of the system, the number of such systems, the number of houses to be served (if applicable), or the number of animals or humans the system(s) are expected to serve. lV e1W N/A c. Water runoff (including stormwater): 1) Describe the source of runoff (including stormwater) and method of collection and disposal, if any (include quantities, if known). Where will this water flow? Will this water flow into other waters? If so, describe. l2LIp4 Run-off from impervious surfaces will be collected and directed into on -site stormwater detention and water quality treatment facilities. Once detained and treated for water quality, the storm water will be released to the downstream system, including the off -site wetlands. 2) Could waste materials enter ground or surface waters? If so, generally describe. hie Not as proposed 3) Does the proposal alter or otherwise affect drainage patterns in the vicinity of the site? If so, describe. No - discharge will occur at the natural location. d. Proposed measures to reduce or control surface, ground, and runoff water, and drainage pattern impacts, if any: The project contractors, users, and personnel will utilize onsite Best Management Practices. Attached drainage plans show runoff from impervious surfaces will be directed to on site stormwater detention pond.•^- 4. Plants VLe1W a. Check the types of vegetation found on the site: iel _X_deciduous tree: alder, maple, aspen, other _X_evergreen tree: fir, cedar, pine, other _X-shrubs _ X _grass pasture crop or grain orchards, vineyards, or other permanent crops _X_wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other Bulletin #050 — May 1, 2014 Page 6 of 14 k:\Handouts\Environmental Checklist May 2014 water plants: water lily, eelgrass, milfoil, other other types of vegetation b. What kind and amount of vegetation will be removed or altered? Liel4 Native Native trees and shrubs will be removed during site construction, as well as areas of non-native trees, and a small portion of open field. Some wetlands will be impacted, but the remaining wetlands will remain post -development with their associated buffers. c. List threatened and endangered species known to be on or near the site. hhel No native threatened and endangered plant species observed or known to occur on or immediately adjacent to the site. d. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on the site, if any. Djelp4 -A Buffer enhancement with native trees and shrubs will be done as appropriate.��` C[ZL"�_ e. List all noxious weeds and invasive species known to be on or near the site. Himalayan blackberry, English ivy, English holly, creeping buttercup 5. Animals a. List any birds and other animals which have been observed on or near the site, or are known to be on or near the site. Examples include: Ihel birds: hawk, songbirds, other: eagle mammals: rabbits, squirrels, coyote fish: no fish were observed within the stream; North Lake is stocked with rainbow trout, and has large -mouthed bass. b. List any threatened and endangered species known to be on or near the site. hiel o No listed species are known to occur on or near the Site. North Lake is adjacent to the eastern edge of the Site at its closest point, and bald eagles are known to periodically use this lake for foraging. c. Is the site part of a migration route? If so, explain. VILIW The entire region is known to be part of the Pacific Flyway. The Pacific Flyway includes Alaska and the Aleutian Islands and the Rocky Mountains and Pacific coast regions of Canada the United States and Mexico, south to where it becomes blended with other flyways in Central and South America. However, the site is not known to be used by migratory fowl. d. Proposed measures to preserve or enhance wildlife, if any.DLe-IPJ A corridor will be provided between remaining wetlands with their associated buffers and the required forested buffer along the western property boundary. e. List any invasive animal species known to be on or near the site. Bullfrog, large -mouthed bass 6. Energy and Natural Resources Bulletin #050 — May 1, 2014 Page 7 of 14 k:\Handouts\Environmental Checklist May 2014 a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet the completed project's energy needs? Describe whether it will be used for heating, manufacturing, etc. VLelp4 Electrical energy will be the primary source of power serving the project. Natural gas maybe used to satisfy incidental energy needs. b. Would your project affect the potential use of solar energy by adjacent properties? If so, generally describe. h.�-e1W No. Proposed building heights will not exceed 42 feet above grade. No existing development utilizes solar energy in proximity to which the shadow cast from the building has any effect. c. What kinds of energy conservation features are included in the plans of this proposal? List other proposed measures to reduce or control energy impacts, if any. V160 No, plans included in the Commercial Grade & Fill Permit. Energy conservation will be addressed in the building permit documents. 7. Environmental Health a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste that could occur as a result of this proposal? If so, describe. DjeIW None known. 1) Describe any known or possible contamination at the site from present or past uses. None known. c 2) Describe existing hazardous chemicals/conditions that might affect project development and design. This includes underground hazardous liquid and gas transmission pipelines located within the project area and in the vicinity. None known. 3) Describe any toxic or hazardous chemicals that might be stored, used, or produced during the project's development or construction, or at any time during the operating life of the project. None Known at this Time 4) Describe special emergency services that might be required. None anticipated 5) Proposed measures to reduce or control environmental health hazards, if any. State regulations regarding safety and the handling of hazardous materials will be followed during the construction process. Equipment refueling areas would be located in areas where spill could be quickly contained and where the risk of hazardous materials entering surface water is minimized. b. Noise 1) What types of noise exist in the area which may affect your project (for example: traffic, equipment, operation, other)? V1 14 The primary source of noise near the project site is from vehicular traffic along Weyerhaeuser Way S, Hwy-18, and Interstate-5. It is not anticipated to materially impact the proposed project in any way. ], `' 1 � 5 �-'I Bulletin #050 — May 1, 2014 Page 8 of 14 kAHandouts\Environmental Checklist May 2014 2) What types and levels of noise would be created by or associated with the project on a short-term or a long-term basis (for example: traffic, construction, operation, other)? Indicate what hours noise would come from the site. PILIW Short-term impacts would result from the use of construction equipment during the site development. Construction would occur during permitted construction hours and always in compliance with the City of Federal Way noise regulations. Long-term impacts would be those vehicular trips associated with R&D-, distribution-, manufacturing or office -type uses. Noise generated from the proposed building and office operations is not expected to impact surrounding properties. 3) Proposed measures to reduce or control noise impacts, if any: Dit1w Construction activity will be limited to permitted construction hours and construction equipment will not be allowed to idle for continuous periods of time, which will help mitigate the impacts of potential construction noise. 8. Land and Shoreline Use skLjttl a. What is the current use of the site and adjacent properties? Will the proposal affect current land uses on nearby or adjacent properties? If so, describe. JhelpJ Existing uses on these parcels include the Weyerhaeuser Technology Center, passive and active private recreation spaces, access and parking areas, and stormwater facilities. This proposal is in conformance with the Concomitant Agreement made by and between the City of Federal Way and Weyerhaeuser Company on August 23, 1994, as well as the applicable portions of the 1994 Federal Way Code that was in effect at that time. North- Office Park (OP-01) East- North Lake, Single Family Residentialu West- Interstate-5 South- Corporate Park (CP-01) The proposed development may have a minor, long term impact with respect to the additional traffic of deliveries and employee rE �s. b. Has the project site been used as worldng farmlands or worldng forest lands? If so, describe. How much agricultural or forest land of long-term commercial significance will be converted to other uses as a result of the proposal, if any? If resource lands have not been designated, how many acres in farmland or forest land tax status will be converted to nonfarm or nonforest use? fhelW No 1) Will the proposal affect or be affected by surrounding worldng farm or forest land normal business operations, such as oversize equipment access, the application of pesticides, tilling, and harvesting? If so, how. No impact. The site exists on land previously owned by Weyerhaeuser Company and home to the Weyerhaeuser Technology Center (to remain). c. Describe any structures on the site. thel Bulletin #050 — May 1, 2014 Page 9 of 14 k:\Handouts\Environmental Checklist May 2014 The Weyerhaeuser Technology Center is used as office space and includes lab spaces for R & D. The shape is slightly irregular but primarily rectangular. The front fagade is covered with glass windows the exterior construction is primarily reinforced concrete. d. Will any structures be demolished? If so, what? h[�el No e. What is the current zoning classification of the site? zel Corporate Park- 01 f. What is the current comprehensive plan designation of the site? V161W Corporate Park g. If applicable, what is the current shoreline master program designation of the site? Vitlpj Urban Conservancy h. Has any part of the site been classified as a critical area by the city or county? If so, specify. iel Yes, site reconnaissance conducted by Talasaea resulted in discovery of 63 wetlands within the Site. North Lake abuts the eastern edge of the Site. A copy of the wetland delineation (existing conditions) report was submitted with this environmental checklist. i. Approximately how many people would reside or work in the completed project? 91610 It is anticipated that approximately 900± people would work at the completed project at varying shifts. j. Approximately how many people would the completed project displace? "el None k. Proposed measures to avoid or reduce displacement impacts, if any. DLelw N/A 1. Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans, if any. VILIpj The project will be developed in accordance with applicable City of Federal Way development and land use codes and the approved Annexation and Concomitant Agreement to ensure the project is consistent with the goals and policies of the Comprehensive Plan and applicable Development Regulations. m. Proposed measures to ensure the proposal is compatible with nearby agricultural and forest lands of long-term commercial significance, if any. None proposed 9. Housing a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low- income housing. "el N/A b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low- income housing. "el N/A Bulletin #050 — May 1, 2014 Page 10 of 14 k:\Handouts\Environmental Checklist May 2014 c. Proposed measures to reduce or control housing impacts, if any. Vi,e14 N/A 10. Aesthetics a. What is the tallest height of any proposed structure(s), not including antennas; what is the principal exterior building material(s) proposed? DLelp4 ± 42 feet, 1- story, concrete cast formed walls or blocks b. What views in the immediate vicinity would be altered or obstructed? V1,L1W 6 There is a 100' managed forested buffer running parallel to 1-5 and a 50' managed forest buffer Cc-(" running parallel to the northern property line. Views north from S 336th ST would be altered by 0" C. the site of Building B and Building C. No regulated views will be impacted. 4o. Proposed measures to reduce or control aesthetic impacts, if any. hM The Concomitant and Pre -Annexation agreement have provided measures to control aesthetic impacts through the requirement of the managed forest buffers as well as the Landscape provisions. 11. Light and Glare a. What type of light or glare will the proposal produce? What time of day would it mainly occur? iel Parking lot lighting would occur dusk through dawn at completed project. Minimal glare would occur from sunlight reflected off parked cars. Additionally, the headlights of traveling vehicles would occur any time of day. b. Could light or glare from the finished project be a safety hazard or interfere with views? No c. What existing off -site sources of light or glare may affect your proposal? iel None 7 d. Proposed measures to reduce or control light and glare impacts, if any. IV --,N/A Q I f.� Lv' 12. Recreation a. What designated and informal recreational opportunities are in the immediate vicinity? hel Private pedestrian trails meander throughout property, and a public fishing access is located on North Lake to the east. b. Would the proposed project displace any existing recreational uses? If so, describe. DILIO A portion of the private trails (within the wooded area) will be covered by the proposed site development. c. Proposed measures to reduce or control impacts on recreation, including recreation opportunities to be provided by the project or applicant, if any. Vaglo A continuous sidewalk will be installed along Weyerhaeuser Way S which will provide for pedestrian connectivity. Bulletin #050 — May 1, 2014 Page 11 of 14 k:\Handouts\Environmental Checklist May2014 13. Historic and cultural preservation a. Are there any buildings, structures, or sites, located on or near the site that are over 45 years old listed in or eligible for listing in national, state, or local preservation registers located on or near the site? If so, specifically describe. Ihel The Weyerhaeuser Technology Center was constructed in 1978 and is located on the site. The Weyerhaeuser Headquarters building located near the site was constructed in 1969, which makes it 48 years old. Pursuant to CFR 36, Chapter I, subsection 60.4 criteria for evaluation, the Weyerhaeuser Headquarters building may be eligible. b. Are there any landmarks, features, or other evidence of Indian or historic use or occupation? This may include human burials or old cemeteries. Are there any material evidence, artifacts, or areas of cultural importance on or near the site? Please list any professional studies conducted at the site to identify such resources. Ihel No known landmarks or evidence have been observed on or near the project site. As listed in SEPA Checklist item A.8, a professional study of the project site and surrounding area was conducted by Cardno, Inc and their findings documented in the included report dated 3/16/18. c. Describe the methods used to assess the potential impacts to cultural and historic resources on or near the project site. Examples include consultation with tribes and the department of archeology and historic preservation, archaeological surveys, historic maps, GIS data, etc. Jhel The methods used to assess the potential impacts included GIS data analysis, WISAARD GIS data review, site investigation and archival review as documented in the included report by Cardno, Inc, 03/16/18. d. Proposed measures to avoid, minimize, or compensate for loss, changes to, and disturbance to resources. Please include plans for the above and any permits that may be required. Cardno, Inc recommends that a Monitoring and Inadvertent Discovery Plan (MIDP) be developed to outline steps to be taken by the applicant to minimize potential impacts to any currently unknown intact archeological resources in the event of an inadvertent discovery during construction. If any such historic or cultural evidence is encountered during construction or installation of improvements, work will be halted in the area and a state -approved archeologist/historian will be engaged to investigate, evaluate and/or move or curate such resources, as appropriate. 14. Transportation a. Identify public streets and highways serving the site or affected geographic area and describe proposed access to the existing street system. Show on site plans, if any. Daelpj The project site is primarily served by Weyerhaeuser Way S, with a southern boundary bordered by S 336t" St. There are 4 access points proposed along Weyerhaeuser Way S, which connects to S 320t" St which connects to 1-5. b. Is the site or affected geographic area currently served by public transit? If so, generally describe. If not, what is the approximate distance to the nearest transit stop? Vielpi The site is serviced by Pierce County Transit route 501. The closes transit stop is located within a half mile to the south on S 336t" St. c. How many additional parking spaces would the completed project or non -project proposal have? How many would the project or proposal eliminate? zel Bulletin #050 — May 1, 2014 Page 12 of 14 k:\Handouts\Environmental Checklist May 2014 There were originally 660 parking stalls serving the Technology Center. The final project will result in a total of 1,466 parking stalls. Will the proposal require any new or improvements to existing roads, streets, pedestrian, bicycle, or state transportation facilities, not including driveways? If so, generally describe (indicate whether public or private). hf elf] Yes, the frontage along Weyerhaeuser Way South will require frontage improvements per City of Federal Way Road Section K; however, the Transportation Impact Analysis identified a need for an additional SB lane on Weyerhaeuser Way S. A modified Section K will likely need to be installed. FW Road Section K, provides 3 vehicle lanes (2 for each direction of travel plus a turning lane), a 5' bike lane (for each direction of travel, 6' of planter strip, and 8 feet of sidewalk on each side of the ROW. d. Will the project or proposal use (or occur in the immediate vicinity of) water, rail, or air transportation? If so, generally describe. hel Not expected. J in i�O VJ:-IV e. How many vehicular trips per day would be generated by the completed project or proposal? If known, indicate when peak volumes would occur and what percentage of the volume would be trucks (such as commercial and non -passenger vehicles). What data or transportation models were used to make these estimates? Ihel For new building area of 1,068,000 SF, the site is estimated to generate 3,217 new vehicle trips per day with 427 trips occurring during the weekday AM peak hour and 427 trips during the weekday PM peak hour. Trucks are estimated to account for 13% of the site trips. These estimates were based on the ITE Trip Generation Manual, loth edition. f. Will the proposal interfere with, affect, or be affected by the movement of agricultural and forest products on roads or streets in the area? If so, generally describe. Not expected. g. Proposed measures to reduce or control transportation impacts, if any. DIL10 Applicant provided street improvements to Weyerhaeuser Way South and payment of the City's transportation impact fees is expected, which will help fund City-wide transportation improvements. 15. Public services �),�_(�, 5� '� a. Would the project result in an increased need for public services (for example: fire protection, police protection, public transit, health care, schools, other)? If so, generally describe. Vidlo The completed building/office facilities would result in a slight increased need for public services to include fire protection, police protection, and health care. b. Proposed measures to reduce or control direct impacts on public services, if any. VLe1PJ The increased demand will be offset by impact fees, levies, and taxes required to be paid by the applicant as part of this development. Also the proposal has been designed in a manner that will provide adequate access for fire, medic, and police vehicles. 16. Utilities Bulletin #050 — May 1, 2014 Page 13 of 14 k:\Handouts\Environmental Checklist May 2014 a. Underline/circle utilities currently available at the site: el electricity, natural gas, water, refuse service telephone, sanitm sewer, septic system, other The above listed utilities are either available on -site or will be extended as necessary to serve the site. b. Describe the utilities that are proposed for the project, the utility providing the service, and the general construction activities on the site or in the immediate vicinity which might be needed. hel Lakehaven Utility District will provide water and sewer connection. Puget Sound Energy will supply electricity and gas Telephone: Century Link, Verizon, Comcast Fire Protection: South King Fire & Rescue C. SIGNATURE HELP The above answers are true and complete to the best of my knowledge. I understand that the lead agency is relying on them to make its decision. Signature. fi�W4 Printed Name of Signee: Matthew Reider Position and Agency/Organization: Assistant Planner at ESM Consulting Engineers, LLC Date Submitted: N 5ph U Bulletin #050 — May 1, 2014 Page 14 of 14 k:\Handouts\Environmental Checklist May 2014 Prepared for: Federal Way Campus, LLC Prepared by: Ramboll US Corporation Lynnwood, Washington April 2018 Project Number: 1690002846 GREENLINE BUSINESS PARK DEVELOPMENT, FEDERAL WAY, WASHINGTON AIR QUALITY TECHNICAL REPORT RESUBMITTED APR 3 0 2018 CffY OF FEDERAL WAY COMMUNE DE:'ELOPMENT. AIR QUALITY TECHNICAL REPORT CONTENTS Contents................................................................................................................... i Acronymsand Abbreviations...................................................................................ii 1. Introduction....................................................................................................1 1.1 Background and Project Description...............................................................1 2. Affected Environment......................................................................................2 2.1 Regulatory Overview...................................................................................2 2.2 Existing Air Quality......................................................................................3 2.2.1 Carbon Monoxide..............................................................................3 2.2.2 Ozone..............................................................................................4 2.2.3 Inhalable Particulate Matter — PM10 and PM2.5.....................................4 2.2.4 Greenhouse Gases and Global Climate Change ...................................... 5 2.3 Local Climate and Terrain.............................................................................6 3. Air Quality Impacts..........................................................................................8 3.1 Impacts during Construction.........................................................................8 3.2 Impacts during Operation.............................................................................8 3.2.1 Traffic -Related Air Quality..................................................................8 3.2.2 Emergency Equipment..................................................................... 12 3.2.3 Mobile Source Air Toxics(MSATs)...................................................... 12 3.2.4 Greenhouse Gas Emissions............................................................... 13 4. Mitigation......................................................................................................15 4.1 Mitigation during Construction.................................................................... 15 4.2 Mitigation during Operation..................................................................... . .. 16 5. Conclusion.....................................................................................................17 Contents i Ramboll AIR QUALITY TECHNICAL REPORT ACRONYMS AND ABBREVIATIONS Ambient air quality standard... health -based standard representing a pollutant concentration in the ambient air usually over some averaging period like I hour, intended to protect the health and welfare of people with a margin of safety Ambient air .......................... the air in outdoor locations to which the public has access, e.g., outside the property boundary of an emissions source Attain ment/Nonattainment..... a determination and classification made by EPA indicating whether ambient air quality in an area complies with (i.e., attains) or fails to meet (i.e., nonattainment) the requirements of one or more NAAQS Averaging time ..................... a specific length of time (e.g., I hour, 24-hours, I year) over which measured or model -calculated concentrations of an air pollutant are averaged for comparison with the NAAQS based on the same averaging period. Note that some NAAQS are also based on multi -year averages of certain percentiles of measured or calculated concentrations. CO ...................................... carbon monoxide, a criteria air pollutant CO2..................................... carbon dioxide, a greenhouse gas (GHG) CO2e.................................... Greenhouse gas equivalents (emissions of GHGs expressed in terms of their "global warning potential" compared to CO2) Criteria air pollutant .............. an air pollutant specifically governed by the Federal Clean Air Act for which ambient air quality standards have been set. Criteria air pollutants include carbon monoxide, particulate matter, sulfur dioxide, nitrogen dioxide, ozone, and lead. DEEP.. . .................... . ........... Diesel engine exhaust particulate matter — usually based on stack sampling and therefore usually focused on directly emitted particles that can be captured on filters. DEEP therefore usually ignores condensable particles that form with cooling and mixing with air. See also DPM. Design value ......................... a statistical value representing a pollutant concentration that describes the air quality status of a given location relative to the level of the NAAQS. Design values are defined to be consistent with the individual NAAQS. Design values are typically used to designate and classify nonattainment areas, as well as to assess progress towards meeting the NAAQS. DPM.................................... Diesel particulate matter — sometimes a superset of DEEP that includes both directly emitted particles and condensable particles that form after mixing and cooling with air. Ecology ................................ Washington State Department of Ecology Acronyms and Abbreviations ii Ramboll AIR QUALITY TECHNICAL REPORT EPA/USEPA.................. , ...... , , US Environmental Protection Agency Fugitive dust ......................... Potential air pollutant in the form of dust (or other pollutant) emitted from a non -point or non -mobile source such as dust from a road or from a storage pile caused by wind GHG.................................... Greenhouse gas (e.g., carbon dioxide, methane, nitrous oxide) that contributes to the process of a gradual warming of the atmosphere that can result in global climate change Global warming potential......., A measure of the potential of a gas to have an effect that could lead to climate change due to prolonged residence time in the atmosphere. This is a standard measure, typically based on a 100-year time horizon, used to compare GHGs with the global warming potential of carbon dioxide (COA the most abundant GHG. Maintenance area .................. an area that was once designated as nonattainment that has since come into compliance with the ambient air quality standard but where air quality control measures may remain in effect (in perpetuity). Metric ton ............................. 1,000 kilograms (kg) = 2,204.6 pounds = tonne (see also short ton and long ton) MSAT................................... Mobile source air toxics are air pollutants from mobile sources, such as vehicles. Of the 188 air toxics that EPA regulates, 93 compounds were identified as emitting from mobile sources. EPA has identified 9 of these compounds as significant contributors to the national and regional -scale cancer risk drivers. MTCO2e................................ metric tons of greenhouse gas equivalents. See also CO2e. NAAQS................................. National Ambient Air Quality Standard NO2..................................... nitrogen dioxide, a criteria air pollutant Nonattainment area ............... an area delineated by regulatory agencies including US EPA and the Washington Department of Ecology in which an ambient air quality standards have been violated and where there is a program in place designed to reduce air pollution so that the standard attained. NOx..................................... oxide of nitrogen, a general class of air pollutant without a specific air quality standard but used in monitoring air quality Particulate matter (PM).......... air pollutant comprised of solid or liquid particles; PM is usually characterized based on the particle size. See also PM10 and PM2.5. PSCAA.................................. Puget Sound Clean Air Agency; the designated local air quality control agency in the project area PMio.................................... "Coarse" inhalable particulate matter with an aerodynamic size less than or equal to 10 micrometers (microns) Acronyms and Abbreviations iii Ramboll AIR QUALITY TECHNICAL REPORT PM2.5................................... "Fine" inhalable particulate matter with an aerodynamic size less than or equal to 2.5 micrometers (microns) p p b ..................................... parts per billion (a metric used in quantifying concentrations of air pollutants) ppm.................................... parts per million (a metric used in quantifying concentrations of air pollutants) SO2............................... I..... Sulfur dioxide, a criteria air pollutant TAP ..................................... Toxic air pollutant tpy...................................... tons per year, an estimate of annual emissions pg/ ................................... micrograms per cubic meter (a metric used in quantifying concentrations of air pollutants in terms of the mass per volume of air) Acronyms and Abbreviations iv Ramboll AIR QUALITY TECHNICAL REPORT 1L. INTRODUCTION 1.1 Background and Project Description Federal Way Campus, LLC is proposing to develop three new buildings of varying sizes. The Technology Center (Tech Center) will remain; however, the parking lot associated with the Tech Center will be reconfigured to allow for the construction of the new warehouse buildings (the Project). Building A will be 638,000 square feet in size, Building B will be 282,500 square feet in size, and Building C will be 147,500 square feet in size. The Project will include accessory parking for up to 1,466 vehicles. Site access will be provided by four driveways located on Weyerhaeuser Way South. Right -of -Way dedication and frontage improvements designed to meet the City of Federal Way's Comprehensive Plan are also proposed as part of the Greenline Business Park Development. At the time of this analysis, the exact use of the warehouses had not been established. However it is anticipated that the warehouses will be used for general commodities that do not require cold storage, processing, or manufacturing facilities. Sources of air pollution typical of a general commodities warehouse include emergency generators and vehicle exhaust from employee commuter trips and truck deliveries. Introduction Ramboll AIR QUALITY TECHNICAL REPORT 2, AFFECTED ENVIRONMENT 2.1 Regulatory Overview Air quality is generally assessed in terms of whether concentrations of air pollutants are higher or lower than ambient air quality standards established to protect human health and welfare. Three agencies have jurisdiction over ambient air quality in the project area: the U.S. Environmental Protection Agency (EPA), the Washington Department of Ecology (Ecology), and the Puget Sound Clean Air Agency (PSCAA). These agencies establish regulations that govern both the concentrations of pollutants in the outdoor air and contaminant emissions from air pollution sources. Although their regulations are similar in stringency, each agency has established its own standards. Unless the state or local jurisdiction has adopted more stringent standards, the EPA standards pertain. To track air quality conditions over time, Ecology and PSCAA maintain a network of monitoring stations throughout the Puget Sound region. These stations are typically located where air quality problems may be expected to occur, and so are usually in or near urban areas or close to specific large air pollution sources. Other stations are used to indicate regional air pollution levels. Based on monitoring information collected over a period of years, the EPA and Ecology designate regions as being "attainment" or "nonattainment" for particular air pollutants. Attainment status is therefore a benchmark of whether air quality in an area complies with the National Ambient Air Quality Standard (NAAQS) for one or more "criteria" air pollutants.(') Regions that were once designated nonattainment that have since attained the standard are considered air quality "maintenance" areas through two 10- year cycles of review, after which the area achieves "attainment" if the ambient standards have been maintained. The project area is located in the former King County CO and Ozone maintenance areas, but as of 2017 these areas are considered to be in attainment. Pertinent air pollutants are discussed in greater detail below. A complete list of local, state, and federal ambient air quality standards are displayed in Table 1. (1) The criteria air pollutants are particulate matter, CO, S02r NO2, ozone, and lead. Affected Environment Ramboll AIR QUALITY TECHNICAL REPORT ir"i i. AAr"Nixamt Air fSualk-w Ctanriarrle fnr Criteria Pnllutants Pollutant Terms of Compliance (a) Concentration Inhalable Particulate Matter 150 (PM10) Not to be exceeded more than once per pg/m3 24-Hour Average (Ng/m3) year, averaged over 3 years Fine Particulate Matter (PM2.5) Annual Average (Ng/m3) The 3-year average of the annual mean 12 pg/m3 must not exceed 24-Hour Average (Ng/m3) The 3-year average of the 98th percentile of 35 pg/m3 daily concentrations must not exceed Carbon Monoxide (CO) 8-Hour Average (ppm) The 8-hour average must not exceed more 9 ppm than once per year 1-Hour Average (ppm) The 1-hour average must not exceed more 35 ppm than once per year Ozone (03) 8-Hour Average (ppm) The 3-year average of the 4th highest daily 0.07 ppm maximum 8-hour average must not exceed Note: Ng/m3 = micrograms per cubic meter; ppm = parts per million (a) All limits are federal and state air quality standards and represent "primary" air quality standards intended to protect human health. 2.2 Existing Air Quality 2.2.1 Carbon Monoxide Carbon monoxide is a by-product of incomplete combustion. CO is generated by vehicular traffic and other fuel -burning activities, such as residential space heating, especially space heating using solid fuels such as coal or wood. There are two short-term air quality standards for CO: a 1-hour average standard of 35 ppm and an 8 hour average standard of 9 ppm. The impacts of CO are usually localized near the source(s), with the highest ambient concentrations typically occurring near congested roadways and intersections during periods of cold temperatures (autumn and winter months), light winds, and stable atmospheric conditions. Such weather conditions reduce the atmospheric mechanisms that disperse and dilute pollutants. The project area is located within the former Puget Sound region CO nonattainment area (established in 1991) that encompassed a large portion of Everett -Seattle -Tacoma urban area. By 1996, CO levels in King County had improved and the area was redesignated as a maintenance area for CO, following EPA approval of the State's Implementation Plan (SIP). SIPs are prepared to ensure an area will meet the NAAQS for a 20-year period through the Affected Environment Ramboll AIR QUALITY TECHNICAL REPORT adoption of two 10-year maintenance plans. The Washington State SIP for King County included annual CO emissions budgets and programs for the 20-year period, ending in October 2016. During the 20-year maintenance period, King County met the annual CO emissions budgets and monitoring stations did not measure any CO concentrations exceeding the NAAQS. Therefore, the study area located within King County is now considered in attainment for CO.(2) 2.2.2 Ozone Ozone is a reactive form of oxygen created by sunlight -activated chemical transformations of nitrogen oxides and volatile organic compounds (hydrocarbons) in the atmosphere. Ozone problems tend to be regional in nature because the atmospheric chemical reactions that produce ozone occur over a period of time, during which ozone precursors can be transported far from their sources. Transportation sources like automobiles and trucks are among the sources that produce ozone precursors. In the past, due to violations of the federal 1-hour ozone standard, the Puget Sound region was designated as nonattainment for ozone. In 1997, EPA determined that the Puget Sound ozone nonattainment area had attained the health -based ozone standard in effect at that time. EPA then reclassified the Puget Sound region as attainment for ozone and approved the associated air quality maintenance plan. In 2005, EPA revoked the 1-hour ozone standard in most areas of the US including the Puget Sound region, which ended the ozone maintenance status of this region. In March of 2008, the EPA adopted a new more stringent 8-hour average ozone standard of 75 parts per billion (ppb). The 8-hour standard was later strengthened to 70 ppb for most areas, effective December 2015.(3) Based on ozone measurements over the last few years, the Puget Sound region may again be on the brink of becoming nonattainment for ozone. Under present plans and policies, the ozone attainment/nonattainment status of the area would have no direct effects on the proposed project. 2.2.3 Inhalable Particulate Matter — PM10 and PM2.5 Particulate matter air pollution is comprised of particles either emitted directly into the air (e.g., dust) or formed when hot gases cool and condense. Such air pollution is generated primarily by industrial activities and operations involving fuel combustion and material handling, and by other fuel combustion sources like motor vehicle engines, vessel engines, and residential wood burning. Federal, state, and local regulations set limits for particle (2) Based on conversations with Joanna Ekrem, State Implementation Planning, Washington State Department of Ecology (January 2017). (3) 80 Fed. Reg. 65,292 (Oct. 26, 2015). Affected Environment Ramboll AIR QUALITY TECHNICAL REPORT concentrations in the air (i.e., weight per unit volume) based on the size of the particles and the related potential threat to health. When first regulated, particle pollution limits were based on "total suspended particulate," which included all size fractions. As sampling technology improved and the importance of particle size and chemical composition became more apparent, ambient standards were revised to focus on the size fractions thought to be most dangerous to human health. Based on the most recent studies, EPA has redefined the size fractions and set new, more stringent standards for particulate matter based on fine and coarse inhalable particulate matter to focus control efforts on the smaller size fractions. There are currently health -based ambient air quality standards for PMio, or particles less than or equal to about 10 micrometers (microns) in diameter, as well as for PM2.5, or particulate matter less than or equal to 2.5 microns in diameter. The latter size fraction and even smaller (ultra -fine) particles are now considered the most dangerous size fractions of airborne particulate matter because such small particles (e.g. a typical human hair is about 100 microns in diameter) can be breathed deeply into lungs. In addition, such particles are often associated with toxic substances that are deleterious in their own right that can adsorb to the particles and be carried into respiratory system. With the revocation of the federal annual standard for PMio in October 2006, the focus of ambient air monitoring and control efforts related to particle air pollution in the Puget Sound region has been almost entirely on fine particulate matter (PM2.5). The nearest PM2.5 nonattainment area to the Project site encompasses Tacoma and surrounding lowland areas in Pierce County.(4) However, the Project site is not in this area and is considered to be in attainment of the PM2.5 standards. 2.2.4 Greenhouse Gases and Global Climate Change The phenomenon of natural and human -caused effects on the atmosphere that cause changes in long-term meteorological patterns is known as climate change. Due to the importance of the greenhouse effect and related atmospheric warming to climate change, the gases that affect such warming are called greenhouse gasses (GHGs). The GHGs of primary importance are CO2, methane, and nitrous oxide. Because CO2 is the most abundant of these gases, GHGs are usually quantified in terms of CO2e (carbon dioxide equivalent), based on their relative longevity in the atmosphere and the related "global warming potential" of these constituents. CO2 is not considered an air "pollutant" that causes direct health -related effects, so it is not subject to ambient air quality standards used to gauge pollutant concentrations in the air. (4) The nonattainment area is called the Wapato Hills -Puyallup River Valley area. See information and maps at: http•//www.egy.wa.gov/proQrams air/Nonattainment/Nonattainment.htm. Affected Environment Ramboll AIR QUALITY TECHNICAL REPORT Fuel combustion used for transportation is a significant source of GHG emissions, primarily through the burning of gasoline and diesel fuels. National estimates indicate the transportation sector (including on -road, construction, airplanes, and vessels) accounts for about 31 percent of total domestic COZe emissions from fossil fuels in 2014.(5) In an interim tabulation of 2012 emissions within Washington, Ecology estimated transportation accounted for about 46 percent of statewide GHG emissions;(6) the higher percentage is due to lower GHG emissions from electrical generation because the state relies heavily on hydropower for electricity. No specific federal, state, or local emission reduction requirements or targets are applicable to the proposed Project, and there are no generally accepted emission level thresholds against which to assess potential localized or global consequences of GHG emissions. In the Washington State GHG emissions inventory for 2010-2013, Ecology estimated state-wide annual GHG emissions in 2013 at about 94 million MTCOZe. (7) Estimated annual worldwide GHG emissions for 2010 were about 46 billion MTCOZe. (8) The GHG emissions associated with project operation were analyzed in this report using the King County Department of Development and Environmental Services SEPA GHG Emissions Worksheet.(9) 2.3 Local Climate and Terrain Weather is one of several variables that influence air quality, with wind (speed and direction) and atmospheric stability being two major factors that affect dispersion. Periods with stable high-pressure systems and periods that include nighttime thermal inversions due to the low solar heating of the land in winter create stable atmospheric conditions. It is during these very stable atmospheric conditions when little vertical dispersion occurs, and high concentrations of air pollutants emitted at ground level typically occur. Ground -level emitted pollutants include CO from motor vehicles and particulate matter from vehicles and wood stoves. In the Puget Sound region, summers are cool and comparatively dry and winters are mild, wet, and cloudy. The winter months are dominated by a stronger south wind and frequent precipitation. Annual average precipitation in the region is around 38 inches. Annual mean (5) Inventory of U.S. Greenhouse Gas Emissions and Sinks: 1990-2014, April 2016, htt s:llwww.epa.gov/siteslproduction/files12016- 4ldocuments/us-gha-inventory-2016-chla r--3- energy.odf. {6J 2012 Washington State Greenhouse Gas Inventory Report Table, htt ww.ecy.wa.gov/cJirnatechange/doc-s/2012GHGta-.b.le,pdf (') httl2://www.ecy.wa..qovlcllmatechan-ge/ghginv ❑ .htm (8) https:1119ianuary2017snapshot.e a. ov c€ima - icators down) ads-indic tors -re ort.htrnl (9)The King County Department of Development and Environmental Services SEPA GHG Emissions Worksheet, accessed December 2017, is available at: h www.kin count ❑v de is errnittin - environm nt l-review 'info Si e5 ecific ClimateChan e.a x Affected Environment Ramboll AIR QUALITY TECHNICAL REPORT temperature in the urban areas of Seattle/Tacoma is about 53°F. The annual mean wind speed is about seven mph, with a predominately southerly wind direction (i.e., from the south). The Puget Sound Clean Air Agency (PSCAA) maintains records of wind data, and wind roses are available on their web site at: (http://oscleanair.o[g/154 Air-QualitY-Data). However, PSCAA does not measure wind parameters near the project area. In some instances terrain can also influence air quality. While the greater Puget Sound area is located between mountainous terrains, the study area includes low level hills and is located less than four miles from Puget Sound. Affected Environment Ramboll AIR QUALITY TECHNICAL REPORT 3. AIR QUALITY IMPACTS 3.1 Impacts during Construction Construction of the proposed project could temporarily change localized air quality. For example, dust from construction activities would contribute to ambient concentrations of suspended particulate matter. Construction contractor(s) would have to comply with the PSCAA regulations requiring all reasonable precautions be taken to minimize fugitive dust emissions. Construction would require the use of heavy trucks and smaller equipment such as generators and compressors. These engines would emit air pollutants that would slightly degrade local air quality. There is little or no danger of these emissions resulting in pollutant concentrations that would exceed a health -based ambient air quality standard. Nonetheless, emissions from construction equipment, and especially from diesel -fueled engines, are coming under increasing scrutiny because of their suspected risk to human health, and pollution control agencies are now urging that emissions from diesel -powered equipment be minimized to the extent practicable in order to reduce potential health risks. Some phases of construction would cause odors detectable to some people in the area. This would be particularly true during paving operations using asphalt. The construction contractor(s) would have to comply with the PSCAA regulations during activities that emit odor bearing air contaminants. Such odors from paving operations would be short term. Construction equipment and material hauling can affect traffic flow in a project area. Given that there is heavy traffic during some periods of the day, scheduling haul traffic during off peak times (e.g., between 9 a.m. and 4 p.m.) would have the least effect on other traffic and would minimize indirect increases in traffic related emissions. With implementation of required measures to provide reasonable controls of dust and odors, construction of the proposed project would not be expected to result in significant air quality impacts. 3.2 Impacts during Operation 3.2.1 Traffic -Related Air Quality The Project would result in new vehicular traffic to and from the facility that would increase traffic in the Project vicinity and result in increased traffic -related emissions. To assess and quantify the potential for localized air quality impacts due to this increase in traffic -related emissions, projected future traffic conditions with and without the project were evaluated using the Washington State Intersection Screening Tool (WASIST). This analysis focused on Air Quality Impacts Ramboll AIR QUALITY TECHNICAL REPORT the potential for carbon monoxide (CO) emissions to cause localized "hot spots" based on EPA guidance. ('0) EPA guidance recommends screening for intersections with "level of service" (LOS) "D" or worse because longer traffic delays have a greater potential to result in CO air quality impacts. This hot spot review evaluated signalized intersections in the vicinity of the Project that would be most affected by Project -related traffic during peak - hour periods. LOS and per -vehicle delay for the AM and PM peak periods are provided in Table 2. As shown in the table below (with gray highlighting), projected intersection conditions indicate the I-5 South Bound (SB) ramps with S 320th Street and Pacific Highway (Hwy) S with S 336th Street intersections would perform worse during the PM peak period. In addition, Weyerhaeuser Way S and SR-18 West Bound (WB) ramps intersection would perform worse during the AM peak period. Although other intersections closer to the site of the Project would be affected by larger volumes of facility -related traffic, by considering the potential for air quality problems at the most congested intersections at the worst peak periods, it is possible to screen for peak -period air pollutant hot spots where concentrations might exceed the health -protective ambient air quality standards. Therefore, the AM and PM peak - period traffic conditions for these respective intersections were the focus of the air quality screening -modeling analysis. (lo) U.S. Environmental Protection Agency (U.S. EPA). 1992. Guideline for Modeling Carbon Monoxide from Roadway Intersections. Office of Air Quality Planning and Standards. Technical Support Division. Research Triangle Park, North Carolina. EPA-454/R-92-005. Air Quality Impacts Ramboll AIR QUALITY TECHNICAL REPORT Existing (2018) 2020 No Build 2020 Build Signalized Intersection LOS Delay sec LOS Delay sec LOS Delay sec AM Peak Period I-5 SB Ramps / B 19.4 C I 21.3 C 22.2 S 320th Street I-5 NB Ramps / C 26.3 C 29.7 C 33.2 S 320th Street 32nd Ave S / A 4.8 A 6.2 A 7.4 S 320th Street Weyerhaeuser Way S A 9.4 B 10.4 B 11.6 / S 320th Street Pacific Hwy S / D 38.5 D 38.2 D 38.3 S 336th Street 20th Ave S / A 8.1 A 9.7 B 10.0 S 336th Street Weyerhaeuser Way S C 29.2 E 65.1 E 66.7 / SR-18 WB Ramps Weyerhaeuser Way S B 15.6 B 19.3 B 19.6 / SR-18 EB Ramps PM Peak Period I-5 SB Ramps / D 46.5 D 46.7 S 320th Street I-5 NB Ramps / B 18.5 B 18.9 S 320th Street 32nd Ave S / C 34.6 D 36.5 S 320th Street Weyerhaeuser Way S B 18.4 C 20.5 / S 320th Street Pacific Hwy S / -_ __ E 60.8 E 59.7 S 336th Street 20th Ave S / __ -_ B 18.8 C 21.1 S 336th Street Weyerhaeuser Way S D 45.5 D 48.0 / SR-18 WB Ramps Weyerhaeuser Way S D 46.1 D 45.2 / SR-18 EB Ramps Source: Level of service (LOS) and delay provided by Transportation Engineering North West, 2018. For additional information refer to the Traffic Impact Analysis memorandum. Air Quality Impacts Ramboll AIR QUALITY TECHNICAL REPORT Air quality screening modeling was conducted using the latest version of the WSDOT WASIST tool. (11) This screening modeling tool applies worst -case assumptions to estimate CO concentrations at nearby locations. This model uses vehicle emission factors estimated using the latest available tool from the EPA, the MOVES2014 model. (12) WASIST also includes a selection of preconfigured intersections, including three options for intersections with one-way streets. The one-way "2 x 2 w/1 Lt Turn" intersection type was selected as the best fit for the I-5 SB ramps and S 320th Street and Weyerhaeuser Way S and SR-18 ramp intersections. The four-way "4 x 4 w/4 Lt Turn (2 Dbl Lns)" intersection type was selected for the Pacific Highway Hwy S and S 336th Street intersection. Near -road receptors were placed along both sides of each roadway at 3, 25, 50, and 100 meters from cross streets, 3 meters from the nearest traffic lane, and 1.8 meters above the ground (i.e., typical sidewalk locations at breathing height). The WASIST modeling results are listed in Table 3. As shown under assumed worst -case conditions, modeling results indicate CO concentrations near the most congested intersections in the Project study area would be far less than the 35 ppm 1-hour and 9 ppm 8-hour health based ambient air quality standards. Model results also demonstrate that at these intersections, Project -related traffic would not increase CO concentrations over future No Build conditions. These findings indicate that the Project would not likely cause or contribute to any significant traffic -related air quality impacts. (") Washington State Intersection Screening Tool (WASIST) Version 3.0, Washington State Department of Transportation, June 2015. (12) Jim Laughlin, WSDOT Air, Noise, and Energy Program Technical Manager, email of 5/18/2015 announcing the release of WASIST 3.0 Air Quality Impacts Ramboll AIR QUALITY TECHNICAL REPORT Table 3. WASIST Calculated PM Peak -Period CO Concentrations Existing (2018) 2020 No Build 2020 Build Concentration Concentration Concentration Signalized Averaging Intersection Period m m m I-5 SB Ramps / 1-Hour 5.7 6.0 6.0 8-Hour 5.5 5.7 5.7 S 320th Street (a) Pacific Hwy S / 1-Hour 5.5 5.9 5.9 8-Hour 5.3 5.6 5.6 S 336th Street (a) Weyerhaeuser Way S / 1-Hour 5.4 5.4 5.4 8-Hour 5.3 5.3 5.3 SR-18 WB Ramps (b) Notes: Model concentrations include a 5-ppm background to reflect the potential contribution from other traffic or sources in the vicinity. This is a very conservative assumption. (a) Existing modeling results for AM peak period and future modeling results for PM peak period (b) Existing and future modeling results for AM peak period Source: Ramboll, based on modeling using the WSDOT WASIST tool 3.2.2 Emergency Equipment One or more emergency generators may be required to ensure safe and consistent operation of the Project. Emissions associated with emergency generators result from the combustion of fossil fuels and would occur during emergency use or routine testing of the generators. PSCAA Regulation I, Section 6.0(c) exempts some sources of air pollution from Notice of Construction applications and Order of Approvals. Sources defined in 6.03(c) are not expected to cause or contribute to local air quality impacts. Stationary internal combustion engines, including emergency generators, with less than 50 horsepower output or those that are operated less than 500 hours per year are included in these exemptions. If the Project identifies a need for larger emergency engines or engines that operate more than 500 hours per year, a permit would be required to ensure the emissions would not cause or contribute to an air quality impact. 3.2.3 Mobile Source Air Toxics (MSATs) In addition to the "criteria" air pollutants like CO discussed above, there are a variety of other potentially hazardous air pollutants for which health -based ambient air quality standards have not been established. Of the identified hazardous air pollutants, some have been designated as mobile source air toxics (MSATs). MSATs are emitted by on -road and off -road vehicles with internal combustion engines burning biofuels, diesel, or gasoline. Of these vehicles, heavy-duty diesel trucks are the largest contributor of MSATs. Actual data Air Quality Impacts Ramboll AIR QUALITY TECHNICAL REPORT related to potential effects of MSATs as well as the mechanisms related to analyzing dispersion of MSATs are incomplete or unavailable, so specific analyses of these substances are not as yet typically performed. However, the FHWA has released interim guidance for consideration during the process of NEPA evaluations for transportation projects subject to FHWA review. While the Project is not subject to FHWA review, FHWA guidance for screening level review of MSATs was applied in the event there is interest or concern regarding such emissions related to this project. The traffic impact analysis indicates a total of 3,217 daily passenger and truck trips (1,609 inbound, 1,608 outbound) would result due to the Project. The daily project -related traffic volumes are far fewer than the 140,000 to 150,000 annual average daily traffic (AADT) threshold that FHWA states may result in a higher potential for MSAT effects. In addition, MSAT emissions in future years are expected to decline compared with existing levels of emissions as a result of national emission control programs. For example, FHWA projects MSAT reductions from on -highway vehicles of 90 percent between 2010 and 2050.(13) 3.2.4 Greenhouse Gas Emissions The GHG emissions associated with the proposed development were calculated using King County's SEPA GHG Emissions Worksheet. King County's GHG worksheet estimates all GHG emissions that are created over the life span of a project from construction materials, fuel used during construction, energy consumed during a building operation, and transportation by building occupants. Note that is analysis does not quantify or consider any potential efforts to reduce either GHG emissions or resource consumption by incorporating sustainable features into the development. However, it is assumed that sustainable features would be incorporated into the Project to reduce such impacts. These sustainable features would be considered in the approach to the design of buildings, and in ongoing site programming and management. (13) Federal Highway Administration (FHWA). 2016. Updated Interim Guidance on Air Toxic Analysis in NEPA Documents. Web Page Accessed April 2018: htt s: www.fhwa. Dt. ovenviron en it qualitylair toxics/policy and guidanceLmsat/. Air Quality Impacts Ramboll AIR QUALITY TECHNICAL REPORT Table 4: Estimated Greenhouse Gas Emissions (MTCO2e) Components Area Lifespan(a) Annual (b) s .ft. Emissions Emissions Warehouse and Storage M 1,068,000 610,626 9,770 Notes: (a) Estimated of lifecycle emissions are based on an assumed average useful life of about 62 years for all types of structures that are not considered residential. These emissions are reported in MTCO2e representing to metric tons (tonnes) of carbon dioxide equivalent, or 2,204.62 pounds ofCO2. This metric is a standard measure of CO2 equivalent emissions that include CO2 and other GHGs. (b) Annual emissions estimates are based on dividing total emissions by assumed facility useful lifespan as indicated in note (b) above. (`) Defined as buildings used to store goods, manufactured products, merchandise, raw materials, or personal belongings (such as self -storage). Source: Ramboll The Project is expected to produce about 611,000 metric tons (tonnes) of CO2 equivalent (MTCO2e) over a 62.5 year lifespan. Annually this corresponds to about 9,800 tonnes. To put these values into context, in the Washington State GHG emissions inventory for 2010- 2013 (as mentioned in section 2.2.4), Ecology estimated state-wide annual GHG emissions in 2013 were about 94 million MTCO2e. Estimated annual worldwide GHG emissions for 2010 were about 46 billion MTCO2e. Thus, the Project annual GHG emissions represents approximately 0.01 percent of estimated annual 2013 GHG emissions within Washington, and much smaller percentages of worldwide emissions. It is important to note that the scale of global climate change is so large that the impacts from one project, no matter the size, would almost certainly have no discernible effect on increasing or decreasing global climate change. In reality, any such effects can only be considered on a "cumulative" basis. It is, therefore, appropriate to conclude that the Project's GHG emissions would combine with emissions across the City, County, State, nation, and planet to cumulatively contribute to increases or decreases in the rate and effects of global climate change. And to reiterate, the estimates of Project GHG emissions do not consider any potential efforts to reduce GHG emissions and/or resource consumption by incorporating sustainable features into the development, although such sustainable features would be incorporated into the Project by virtue of the City and State Building and Energy Code requirements and the likely use of green building technologies. The GHG emissions associated with the Project would contribute to the cumulative carbon footprint of King County. No significant climate change impacts would be expected due to project -related GHG emissions. Air Quality Impacts Ramboll AIR QUALITY TECHNICAL REPORT MITIGATION 4.1 Mitigation during Construction The construction contractor(s) would be required to comply with all relevant federal, state, and local air quality laws, and would be required to control dust and odors sufficiently to comply with PSCAA regulations. The Washington Associated General Contractors brochure Guide to Handling Fugitive Dust from Construction Projects and PSCAA suggest a number of methods for controlling dust and reducing the potential exposure of people to emissions from diesel equipment. The following is a list of possible mitigation measures that could be implemented to reduce potential air quality impacts during construction of the project. • Use only equipment and trucks that are maintained in optimal operational condition • Require all off road equipment to be retrofit with emission reduction equipment (i.e., require participation in Puget Sound region Diesel Solutions by project sponsors and contractors), including particulate matter traps and oxidation catalysts to reduce MSATs • Use biodiesel or other lower -emission fuels for vehicles and equipment • Use carpooling or other trip reduction strategies for construction workers • Stage construction to minimize overall transportation system congestion and delays to reduce regional emissions of pollutants during construction • Implement restrictions on construction truck idling (e.g., limit idling to a maximum of 5 minutes) • Locate construction equipment away from sensitive receptors such as fresh air intakes to buildings, air conditioners, and sensitive populations Locate construction staging zones where diesel emissions won't be noticeable to the public or near sensitive populations such as the elderly and the young • Spray exposed soil with water or other suppressant to reduce emissions of PMio and deposition of particulate matter • Pave or use gravel on staging areas and roads that would be exposed for long periods • Cover all trucks transporting materials, wet materials in trucks, or provide adequate freeboard (space from the top of the material to the top of the truck bed), to reduce PMio emissions and deposition during transport • Provide wheel washers to remove particulate matter that would otherwise be carried off site by vehicles to decrease deposition of particulate matter on area roadways Mitigation Ramboll AIR QUALITY TECHNICAL REPORT Remove particulate matter deposited on paved, public roads, sidewalks, and bicycle and pedestrian paths to reduce mud and dust; sweep and wash streets continuously to reduce emissions C Cover dirt, gravel, and debris piles as needed to reduce dust and wind blown debris • Route and schedule construction trucks to reduce delays to traffic during peak travel times to reduce air quality impacts caused by a reduction in traffic speeds 4.2 Mitigation during Operation The analyses described above indicate the proposed project would be unlikely to result in any significant adverse air quality impacts. Consequently, no operational mitigation measures are warranted or proposed. Mitigation Ramboll AIR QUALITY TECHNICAL REPORT CONCLUSION With the appropriate application of some or all of the mitigation measures described above and consistent use of best management practices, no significant air quality impacts are expected with the proposed Project in Federal Way, Washington. Conclusion Ramboll March 16, 2018 Tom Messmer Vice President — Special Projects Federal Way Campus, LLC 8847 Imperial Highway, Suite H Downy CA, 90242 �� Cardrio Shaping the Future RESUg"eT.ED Cardno AIR 3 0 2018 801 Second Avenue Suite 700 Seattle, WA98104 Cfiy OF FEt1E COMMUN17yDEVE OPMENT USA Phone 206 269 0104 Toll -free 800 368 7511 Fax 206 269 0098 www.cardno.com Subject: Cultural Resources Archival Study, Greenline Business Park Project, Federal Way, Washington CONFIDENTIAL Dear Mr. Messmer: This letter report describes the results of the archival study conducted by Cardno, Inc. (Cardno) for the Greenline Business Park Project (project), located within the former Weyerhaeuser Company (Weyerhaeuser) campus at 32901 32nd Drive South in Federal Way, Washington. The 77-acre project area includes portions of parcels 152104-9178, 162104-9030, 228500-0010, as well as the entirety of parcels 162104-9013 and 162104-9056, which have recently been purchased by the Industrial Realty Group, LLC (IRG) from Weyerhaeuser (King County Tax Assessor's Office 2018). The project straddles the western half of Section 15 and the eastern half of Section 16 of Township 21 North, Range 4 East of the Willamette Base Meridian (Figures 1 through 3). The proposed Greenline Business Park project includes the construction of three buildings of varying sizes totaling approximately 1,068,000 square feet (ft) surrounding the former Weyerhaeuser Technology Center (WTC), now referred to as the Greenline Technology Center (ESM Consulting Engineers, LLC 2017). Additional site improvements include reconfiguration and expansion of the existing parking lot at the Greenline Technology Center, construction of five stormwater ponds, and frontage improvements along Weyerhaeuser Way South and South 336th Street. An inventory to document the historical and architectural significance of the project area was requested by the City of Federal Way upon their review of the Federal Campus Way, LLC's application under the Washington State Environmental Policy Act (SEPA) (Revised Code of Washington [RCW] 43.21 C) and implementing rules contained in Washington Administrative Code (WAC) 197-11. As outlined in the SEPA checklist submitted to the local planning authority with applications for development, the following questions must be satisfactorily addressed to demonstrate that cultural and historic resources will not be adversely affected by the proposed development: A. Are there any buildings, structures, or sites, located on or near the site that are over 45 years old listed in or eligible for listing in national, state, or local preservation registers ? If so, specifically describe. B. Are there any landmarks, features, or other evidence of Indian or historic use or occupation? This may include human burials or old cemeteries. Are there any material evidence, artifacts, or areas of cultural importance on or near the site? Please list any professional studies conducted at the site to identify such resources. Australia • Belgium • Canada • Colombia • Ecuador • Germany • Indonesia • Italy Kenya • New Zealand • Papua New Guinea - Peru • Tanzania • United Arab Emirates United Kingdom • United States • Operations in 85 countries March 16, 2018 C�r7 Cardno C. Describe the methods used to assess the potential impacts to cultural and historic resources on or near the project site. Examples include consultation with tribes and the department of archeology and historic preservation, archaeological surveys, historic maps, GIS data, etc. D. Proposed measures to avoid, minimize, or compensate for loss, changes to, and disturbance to resources. Please include plans for the above and any permits that may be required. On behalf of Federal Campus Way, LLC, Cardno completed an archival study to assess the cultural significance of the project area and to provide a recommendation concerning the potential effects of this project on cultural resources, including those that may be eligible for listing in the Washington Heritage Register (WHR) and/or the National Register of Historic Places (NRHP) (termed "historic properties"). Cardno also conducted a field visit to note the existing conditions of the project area and a historic resources survey for the building located at 32901 32nd Drive South (within parcel 162104-9013). The archival study consisted of a literature review of existing cultural resource records for previously recorded historic, ethnohistoric, and precontact archaeological and built environment resources; a review of any local, state, and national register nomination forms; a review of previously conducted cultural resources investigations; and a review of any known or potential Traditional Cultural Properties (TCPs) located within 1.0 mile (1.6 kilometer [km]) of the project area. This research included a records search at the Department of Archaeology and Historic Preservation's (DAHP's) Washington Information System for Architectural and Archaeological Records Data (W ISAARD). Additional resources that were consulted include historic -era aerial photographs and county atlases, as well as U.S. Geological Survey (USGS), General Land Office (GLO), and Sanborn Fire Insurance maps. The results of the research were compared to the proposed project plans to determine any potential disturbance to previously recorded cultural resources or historic properties, and to assess the potential for current€y unknown cultural resources to exist in the project area and their significance. This study also evaluated potential project - related effects on any known historic properties or cultural resources that may be eligible for listing in the WHIR or NRHP. The building at 32901 32nd Drive South does not meet the age requirement at this time to be eligible for the NRHP or trigger Criteria Consideration G of the NRHP eligibility criteria, but it maintains enough architectural merit that it should be reevaluated when it is 50 years old. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com 3 C�"� Camino March 16, 2018 _ I Farn ooJ l ,r4 i Vedwn Ktnt I 1 _ - lur lann , Lake Marlon Bwrydalc Federal Pro ectArea. — . Lakeland gana I� South vuA Lake Flfe Tapp Sumnw ` Walter W. •'J \ Mrdl\ d ` AvoJt, r1Gn NAD 89 UTM Zone 18N 0 t 2 4 Mlles F3 Project Area 8 2 4 6 Kilometers 17200AM GrFaernline a slness Park Project J ogft� in dustriat Renity GrouP, LLC King County. Washington BolSccantlawnueSub7U)SWWWA9EI0= P�ww l•1)r_e�:69d10A Fu l�l)2o5i6SOD90 U5�S 7pap4rJU°lc &T;ertinp Figure 1 Project location. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com 4 (:, card►�Q March 16, 2018 .. } .I ,�) ••rj .il '04 r 59eel Luke so SIP �n' �w t � � -mot• •f; t f' r ; r]Il tom, imkwl i ram _ , � f tip � � ,�; �•' :,:' 'ti. V, y ,- `� �� w � Lit � ' i.y = �'I ��' .i —. _ ``'_ \I. � �-' � �• I 1.4 �1 . � 4`~,.i �• r l7� �'� �.I �r �n � - � foGorn.r,�.' -'��.`L \�� rI.4�`� Pro�4�rroe:,Nno as urM rcRc-+ou _ 1 ' _ ! i. ' G., "•` 0 600 1'000 2,000 ft 0 200 400 600 In Project Area Q 1.0-mile Buffer Greenline Business Park Project m"50I AM A_ Industrial Realty Group, LLC King County, Washington 5111e 1.. s.'-wnIM- I P^ona (.1)_06=fiSA10a m I.1)2�_64C096 IIIL v caeno cam USGS 7 5' Poverty Bay (199712003) Quadrangle Figure 2 Project area plotted on USGS topographic quadrangle (USGS 1997/2003). CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 5 �,r� carcino o zoo 400 000 n Project Parcel a too 20 m j Project Area . a.oaa - 1:. • •r� : . , �; Greenling s s ark ?ro ri! � s>r,pynlr•�-- Industrial Realty Grqup, LLC ilr King County, Washm Mon ,. Plbtl l+ll YO6Y89-010� F41i11=06•'�9-W9E C3RI V:arh}lrnl7c•7N .:� Imm anio:on Figure 3 Project area displayed on aerial imagery. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 Environmental Setting <.:� Car-cincr The project is located along the eastern border of the City of Federal Way between the Puyallup and Green River Valleys in the Puget Lowland physiographic province. This physiographic province is a low-lying area between the Cascade Range to the east and the Olympic Mountains to the west. The Puget Sound was shaped by widespread continental glaciation that extended south from British Columbia to the northern Puget Lowland and along the western flanks of the Cascade Range (Miss 2008). This area is also known as the Puget Sound Trough physiographic province, which extends to the Cowlitz and Chehalis Rivers (Franklin and Dyrness 1988). The Vashon Stade of the Fraser Glaciation was the last glacial maximum in the region and is dated between ca. 19,000 and 16,000 years before present (BP) (Easterbrook 2003). During the maximum extent of this glaciation, most of the northern third of Washington lay beneath a nearly continuous sheet of glacial ice (Easterbrook 2003). The outwash deposited during the southward advance of the Puget lobe of the Cordilleran ice sheet filled the Puget Sound basin, forming an extensive low-lying area bounded on the west by the Olympic Mountains and on the east by the Cascade Range. Sometimes called the "great Lowland Fill," the surface of this fill rarely rises above 500-ft elevation (Booth and Goldstein 1994). The Federal Way area is located at elevations between 300 and 500 ft on an undulating landform defined as the Des Moines Drift Upland. This upland landform was a long, narrow island that stretched between Seattle and Tacoma, with Puget Sound to the west and marine waters filling the fjord of the Duwamish Embayment on the east (Forsman et al. 1999). The land experienced isostatic rebound between 13,000 and 7,000 years BP as global sea levels rose and tectonism began to shape the Puget Sound shoreline (Dragovich et al. 1994; Miss 2008). At the regional scale, the larger Pleistocene glacial troughs are occupied by marine waters or large freshwater lakes today. Subglacial incision when the ice sheet overrode the advance outwash, and subglacial incision during maximum extent and subsequent retreat of the ice sheet, created a number of large, deep troughs and meltwater channels. As a result, the geomorphology of the region is now dominated by well-defined north -trending troughs separated by extensive fluted drift uplands, like the Des Moines Drift Upland. The surfaces of the uplands'are characterized by numerous surface depressions, now occupied by small lakes and peat bogs, created as glacial ice retreated (Mullineaux 1970). The largest of these bodies of water in the Seattle metropolitan area include the Puget Sound, the Duwamish-Green River Valley, Lake Washington, and Lake Sammamish (Liesch et al. 1963; Yount et al. 1993). Freshwater lakes that have filled glacial depressions and are local to the Federal Way vicinity include Steel Lake, Mirror Lake, Five -Mile Lake, Lake Geneva, Star Lake, Mud Lake, Lake Dolloff, and North Lake, which borders the project area to the east (Caster 2004). Approximately 13 acres of subsurface peat have been identified along the north rim of North Lake (Caster 2004). The postglacial environment of the project area around 15,000 years BP was a grassland savanna composed of scattered pine trees, and it remained as such until approximately 6,000 or 5,000 years BP, when the contemporary Western hemlock (Tsuga heterophylla) and Douglas fir (Pseudotsuga menziesb) forest developed (Brubaker 1991). The Des Moines Drift Upland remained an island until approximately 5,700 years BP, when the Osceola Mudflow, a massive lahar that resulted from a large-scale summit and flank collapse on Mount Rainier, traveled down the White River Valley from Mount Rainier and deposited large quantities of mud in both the Green River Valley and the Puyallup River delta. After passing through the White River bedrock gorge upstream of what is now Mud Mountain Dam, the mudflow blanketed glacial drift valleys and plains with as much as 100 ft of clay -rich gravel, cobbles, and boulders (Forsman et al. 1999). Osceola Mudflow deposits cover an area of about 550 square km in the Puget Lowland, extending at least as far as the Seattle suburb of Kent and to Commencement Bay (Dragovich et al. 1994; Mullineaux 1970; Palmer 1997; Valiance and Scott 1997). Post-lahar fluvial aggradation and delta progradation eventually filled the ancient Puyallup and Duwamish arms of the Puget Sound to their present positions. Both mudflow materials and upriver alluvial sediments extended the leading edge of the delta northwestward, filling Commencement Bay at a rate of approximately 8.2 ft (2.5 meters [m]) per year (Weaver 2003:6). CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 The U.S. Department of Agriculture's (USDA's) Natural Resources Conservation Service (NRCS) Soil Data Explorer classifies soils in the general project area as Alderwood gravelly sandy loam, which belongs to the soil taxonomy order Inceptisol (USDA 2018). The Alderwood series consists of moderately well -drained soils located on uplands and terraces. These soils formed under conifers in glacial deposits on slopes that range from 0 to 70 percent (Snyder et al. 1973:8). GeoEngineers, Inc. conducted a geotechnical engineering study at the project area in 2017 to evaluate the on -site subsurface sediments and provide recommendations for the proposed development (Helvey and Overbay 2017). The study evaluated previously excavated test pit explorations from 2016 and conducted additional explorations in July 2017. As described by GeoEngineers, the top stratum typically consisted of forest duff and/or topsoil that extended from the ground surface to depths that ranged between 1 and 18 inches below ground surface. This organic -rich stratum was typically underlain by medium dense grayish brown silty fine to medium sand with some gravel and cobbles, identified as weathered glacial till, and extended from 3 to 5 ft below surface. The weathered till interfaced with very dense and moist brownish gray silty fine to medium sand with some gravel and cobbles (i.e., native glacial till material). Each exploration terminated in these native glacial till deposits. In explorations placed within the existing parking lot surfaces and surrounding the south-central retention ponds, loose to dense fill was encountered between 1.75 and 7.5 ft below surface of explorations. The fill consisted of medium dense silty sand and interfaced with native glacial till. The regional climate is characterized by a maritime regime, with cool, typically dry summers and mild, wet winters. Since the last glacial episode, the climate has experienced several cycles of warming/drying and cooling/increasing moisture. Following the last glacial advance, a period of rapid warming and reduced precipitation marked the climate until approximately 7,000 years BP, at which time precipitation levels began increasing and temperatures began cooling, similar to modern conditions. From 4,500 to 2,000 years BP, this cooling/increased precipitation trend continued throughout what is known as the Neoglacial. During this period, conditions were substantially wetter and cooler than at present. The last major fluctuation, the Little Ice Age, occurred from approximately 500 to 100 years BP and was a period of increased precipitation and cooler temperatures (Ames and Maschner 1999). The project lies within the western hemlock vegetation zone in the Puget Lowland, which provides a highly productive ecological system with a complex mosaic of microenvironments. Historically, the zone includes the climax species that defines it, as well as western redcedar (Thuja plicata) (Franklin and Dyrness 1988). The overall modern regional vegetation profiles were not established until approximately 5,000 to 3,000 years BP (Ames and Maschner 1999). Forests are currently dominated by western hemlock, Douglas fir, coast red elderberry (Sambucus racemosa var arborescens), and western redcedar. The understory consists of mostly undisturbed low brush including hardhack (Spiraea douglasit), Labrador tea (Rhododendron spp.), crab apple (Malus spp.), and cascara buckthorn (Rhamnus purshiana), as well as various small herbs and some mosses (Caster 2004). However, historical and modern land use, such as commercial, residential, and urban development; logging; and small-scale farming, have greatly modified the vegetative profile of the area. In precontact times, the region was rich in faunal resources whose predictable seasonal migrations were vital to the native inhabitants of the Puget Sound region, especially the salmon species that would migrate up Hylebos Creek toward present-day Federal Way (Williams et al. 1975). Anadromous fish species continue migrate seasonally to spawning streams throughout the region, including Chinook (Oncorhynchus tshawytscha), coho (O. kisutch), chum (O. keta), rainbow trout (O. mykiss), and char (Salvelinus spp.). Prior to the Euro-American settlement of the region, a variety of terrestrial animals once thrived in the microenvironments associated with freshwater rivers, streams, springs, ponds, and swamps of the Puget Lowland. However, the diversity of microenvironments, and, as a consequence, the diversity of faunal species, has been greatly affected by settlement and development. The few species not pushed out by these activities include black -tailed deer (Odocoileus hemionus), beaver (Castor canadensis), marmot (Marmots caligata), raccoon (Procyon lotor), various avian species, and suckers. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 Archaeology �,'� Cardna The earliest known occupations in western Washington, termed Paleo-Indian, are evidenced by the appearance of large, fluted projectile points dating to approximately 12,800 years BP (Ames and Maschner 1999; Carlson 1990). Paleo-Indians were primarily hunter -gatherers with small populations and high levels of mobility. Some researchers have argued that these early people were maritime oriented (Carlson 2003; Dixon 1993; Fedje and Christensen 1999; Fladmark 1979). In western Washington, sites from this period are rare. Much of the late Pleistocene terrain was uninhabitable due to glaciers, and the lands that were occupied by Paleo-Indians were predominately coastal reaches. During the glaciation period, ocean levels fell almost 400 ft globally (Kirk and Daugherty 2007), but with the onset of the warming Holocene, ocean levels rose and submerged many of these coastal sites. However, some sites are not submerged, and instead are located above the present shoreline due to eustatic, tectonic, and isostatic effects that vary throughout the region (Fedje and Christensen 1999). The Archaic period dates from approximately 12,500 to 6,400 years BP (Ames and Maschner 1999; Carlson 1990). Archaic -period sites, similar to Paleo-Indian sites, are poorly represented. Changes in sea level and vegetation have obscured many Archaic -period sites along the coast (Ames and Maschner 1999). However, as the glaciers receded, people were able to occupy larger expanses in the interior of the Puget Sound. Archaic -period peoples likely maintained small populations, high levels of mobility, and focused on a combination of maritime, littoral, and terrestrial economies. Archaic -period occupations are largely characterized by stone tool assemblages that are typically composed of large, stemmed lanceolate projectile points and bifaces. In addition, the Pacific Northwest Archaic period saw an introduction of microblades, which are sometimes present in stone tool assemblages (Ames and Maschner 1999). Pacific -period sites date from approximately 6,400 to 250 years BP. The period ends at the introduction of smallpox to the region (Ames and Maschner 1999). The Early Pacific period (6,400 to 3,800 years BP) was marked by the increased use of marine resources, the appearance of human burials in middens and cemeteries, a diversification in subsistence activities, the disappearance of microblade technology, and the increased use of bone, antler, and ground stone tools. Major developments also included the appearance of ground stone celts (adze blades) and a proliferation in chipped -stone tool forms and styles and decorative/ornamental pieces, which likely represent contact and trade with groups in neighboring cultural areas (Kirk and Daugherty 2007). The Middle Pacific period (3,800 to 1,800/1,500 years BP) displays major developments including the appearance of long-term settlements (plank houses), intensification of salmon capture (appearance of wooden fish weirs and girdled/drilled net sinkers), and diversification in tool form and style. Late Pacific period (1,800/1,500 to 250 years BP) developments are represented by the appearance of heavy-duty woodworking tools, an overall decline in the use of chipped -stone tools, and an increase in funerary ritual/burial activities. Sea levels became stable by the start of the Middle Pacific period, and sites representing the Middle and Late periods are located across the Northwest Coast region (Ames and Maschner 1999). Ethnography The proposed project is located within the traditional territory of the Muckleshoot and Puyallup, two Puget Salish or Lushootseed-speaking groups (Suttles and Lane 1990). As speakers of the Southern Coast Salish dialect, the Muckleshoot and Puyallup were among a set of closely related peoples in the Puget Sound region that included the Snoqualmie, Suquamish, Skykomish, Snohomish, Skokomish, Duwamish, and Nisqually (Suttles and Lane 1990). In their aboriginal language, the Puyallup were known as the spuyalepabs, meaning "generous and welcoming behavior to all people (friends and strangers) who enter our lands," which indicates the frequency and nature of Puyallup precontact interactions (Puyallup Tribe of Indians 2018). Following increased conflict in the 1850s on account of Euro-American settlement encouraged by the Donation Land Claim Act, a new treaty combined the White River tribes under the Muckleshoot name and established what remains as the only Indian reservation now within the boundaries of King County. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 Both the Muckleshoot and Puyallup groups lived in winter villages along the Puyallup and White Rivers, and inland from the historic shorelines of Commencement Bay and Hylebos Creek (Haeberlin and Gunther 1930; Smith 1940). They preferred locations above the tideflats at confluences of major creeks, which would provide protection from the elements, fresh water, and access to fishing sites. The tideflats, with marine and freshwater environments, provided a rich subsistence base that was dominated by salmon and supplemented by hunting and gathering. Winter villages consisted of multifamily longhouses made from cedar planks and ranged from a single building to up to 10 houses (Haeberlin and Gunther 1930). During the spring, these groups traveled throughout their territory for resource procurement, which extended throughout the current project area, as well as across Puget Sound to Vashon Island, and southeast to the tributaries of the Green, Puyallup, Carbon, and Stuck Rivers toward Mount Rainier (Rinck et al. 2012; Roedel et al. 2003; Smith 1940). Small, mobile groups constructed temporary, mat - covered structures at fishing and plant -gathering camps during seasonal procurement rounds. At the camps, they smoked fish, shellfish, and game and dried berries and roots to take back to the village sites for winter supplies (Rinck et al. 2012). Salmon constituted the bulk of the food supply, providing for immediate consumption, winter stores, and surplus for exchange (Suttles and Lane 1990). Cardno is not aware of any known ethnographic place names within the project area. However, there are several ethnographic place names recorded along Commencement Bay, Lake Doloff, and the Puyallup River and its tributaries in the general vicinity of the project area (Dailey n.d.; Waterman et al. 2001), as listed below. Non - English names are Lushootseed. • XaxtL! translates to "brushy," which refers to Hylebos Creek. A Catholic missionary named Hylebos founded St. George's School along this creek. • LtcELEb refers to the tideflats where shipyards stood during the early twentieth century. • Tcaua'lgo translate to "hidden water," which refers to Brown's Point on the north side of Commencement Bay. A freshwater spring was observed along the shoreline at this location, which was concealed by immature alder trees. • Blskwa'dis translates to "where there are whales," and refers to Lake Dolloff, which is the source of Mill Creek. It was believed that whales used to swim into this lake via an underground channel. • s'HAWHT'1-ahbch refers to the location in present-day northeast Tacoma where Hylebos Creek empties into Commencement Bay. People from this village were said to have moved across Puget Sound to establish a village at present-day Gig Harbor, TWAH-well-kawh. Silver salmon were plentiful in Hylebos Creek. Historical Context British Naval Captain George Vancouver was the first Euro-American to document the eastern Puget Sound shoreline in 1792. His initial observations of the region reported clouds of smoke on the high bluffs as the local Native Americans had set brush fires to drive out game for hunting (Stein 1999a, 2003). Over the next three decades, several military and commercial expeditions explored the greater region to chart the coastline and scout the interior for resources. William Fraser Tolmie was the first settler in the region of the Puyallup River Valley, and was a medical officer for the Hudson's Bay Company in the early 1830s. Led by Nuckalkat, a Puyallup Indian, and several other Native American guides, Dr. Tolmie passed through the valley, where approximately 2,000 Puyallup Indians lived, on his way to Mount Rainier (City of Puyallup 2018). As the influx of Euro-American settlers encroached on Puyallup land during the subsequent decades, encouraged by the 1850 Donation Land Claim Act, the Puyallup negotiated the Treaty of Medicine Creek in 1854, which ceded most of their territories and forced the tribe onto a reservation of 1,280 acres (Chesley 2008). Several years of conflict ensued following the signing of the treaty between the CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 10 C"7 Camino tribal members of the Nisqually, Muckleshoot, Puyallup, and Klickitat Tribes against the U.S. military and local militiamen, which is typically referred to as the Puget Sound Indian Wars. The Puyallup Indian Reservation was subsequently enlarged to 18,062 acres in January 1856 (Becker 2006). Euro-American settlement of the Green River Valley began at the time the Washington Territory was established in 1853. Around this time, wagon trains began to arrive over the Naches Pass using a crude military road that passed from Fort Steilacoom to Fort Walla Walla through present-day Auburn (Lentz 1990). Many of the early settlers took advantage of the Donation Land Claim Act that allowed pioneers to claim 160 acres. The city of Auburn, east of Federal Way, lays claim to some of the earliest Euro-American settlements in King County (Stein 1999b). A small community was established there in the early 1850s at the confluence of the Green and White Rivers, which were fed by the predictable snowmelt from the Cascade Range. The abundance of resources soon created a vibrant hub for farming, trading, and industry. As this growing settlement encroached on the valley's original inhabitants, the Skopamish, Smalhkamish, and Stkamish Indian Tribes, conflict soon followed. Settlement of the valley was slowed by conflicts with Indian tribes during the mid-1850s when many of the early pioneer families left their farms in the valley for Seattle during the conflict (Peto et al. n.d.). In contrast, the Federal Way region, nestled between the Puyallup and Green River Valleys, was relatively uninhabited by Euro-Americans during the nineteenth century prior to the waterfront settlement that emerged in the latter half of the century (Forsman et al. 1999). While settlers were drawn to the idyllic flat prairies around the White River, which require little clearing, and abundant resources at the mouth of the Puyallup River, the densely wooded forests and glacial till substrate that made up the Federal Way region was not ideal for agriculture, and thus permanent settlements took longer to become entrenched. Federal surveyors platted the area in the 1850s in preparation for the construction of a military road between Forts Bellingham and Steilacoom (Stein 2003). Aptly named Military Road, it was completed by 1860 and connected Seattle with Pierce County. Early homesteaders, including Ernst Ferdinand Lange, Sam Stone, and John Barker, flocked to the Poverty Bay shoreline at what is now known as Redondo in order to maintain proximity to reliable marine resources (Caster 2015). By the end of the nineteenth century, the shoreline homesteaders had turned their attention to inland resources, and Redondo became one of the first logging settlements on Puget Sound (Caster 2004). Two sawmills emerged at Steel Lake in 1890 and at Star Lake in 1909 in order to process and export the abundant harvested timber (Caster 2015). The Weyerhaeuser Timber Company incorporated in 1900 when Frederick Weyerhaeuser and 15 partners convened in Tacoma and purchased 900,000 acres of land in Washington from the Northern Pacific Railway, including what was to become Federal Way (Weyerhaeuser 2018). By 1913, due to intensive logging practices, many of the large -diameter trees, defined as trees with greater than 15-ft diameter, had been entirely logged (Caster 2015). In order to meet the transportation demands of the growing region with the advent of the automobile, construction of a 24-mile-long strip of federal highway began in 1915 that would connect Tacoma and Seattle, with the ultimate goal of traversing the entire western coast of the U.S. (Caster 2015; Stein 2003). This federal highway was to be named Highway 99, but was referred to as Pacific Highway South. The historical Military Road served as the footprint for much of this federal highway, which was initially unpaved until a tax restructure in 1927 allocated state taxes for building and paving highways (Caster 2015). On account of its proximity to the federal highway, a newly constructed elementary school that consolidated five districts was given the name Federal Way School (Caster 2015). The name "Federal Way" was officially accepted by the local Chamber of Commerce in the 1950s, although the town was still part of unincorporated King County (Earley 2005). Federal Way mainly served as a culinary and shopping destination for travelers along Highway 99 during the mid - twentieth century (Stein 2003). Community growth climbed sharply in the latter half of the twentieth century when large corporations moved into the region, particularly Boeing and Weyerhaeuser in the 1960s. In 1968, CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 11 (,.� CardnP Weyerhaeuser purchased 430 acres of land and began construction on its new corporate headquarters, which would be the "first major application of open -landscape office design in the U.S." (Weyerhaeuser 2018). Although the city unsuccessfully tried to incorporate in 1971, 1981, and 1985, the community approved incorporation of Federal Way in 1990 (Stein 2003). Historical Map Review The 1868 GLO cadastral survey plat plots North Lake in its present-day orientation and shows the project area as sectioned but undeveloped (Bureau of Land Management [BLM] 2018). No human -made features or structures are shown to have been constructed within any of the parcels constituting the project area at that time. Less than 1.0 mile (1.6 km) east of the project area, the "Military and Telegraph Road" is plotted meandering around large natural landforms (i.e., elevation changes, bodies of water), roughly trending north/south. This plotted road is the same aforementioned Military Road that was built to connect Fort Bellingham to Fort Steilacoom by way of Seattle and Tacoma, and served as the footprint to the highway that ultimately brought Euro-Americans into the Federal Way region (Stein 2003). The GLO plat shows the Puyallup Indian Reservation located in the very southwestern corner of the township/range (BLM 2018). Records show that the land patent for the portion of the project area within Section 15 (T21 N, R4E) was purchased by the Northern Pacific Railroad Company on May 10, 1895 (BLM 2018). The land patent for Section 16 (T21 N, R4E) was purchased by the State of Washington on November 11, 1889 (BLM 2018). USGS topographical maps convey that by 1897 neither land holder had developed within the project area (USGS 2018). A topographic map from 1900 plots a single structure southwest of North Lake outside of the current project area, but within what would eventually become the Weyerhaeuser campus. Historical topographic maps from the turn of the twentieth century to the World War II era are not readily available online. However, by 1949, a network of roads had been built that nearly surrounded the entirety of North Lake, along which countless residential structures had been constructed. By 1968, Interstate 5 (1-5) had been constructed and bisected Section 16 northeast/southwest, and several additional structures had been built toward the interior of Section 16, west of North Lake. The 1973 USGS topographic map is the first to show the Weyerhaeuser Headquarters building and associated pond south of 336th Street; by 1981, the WTC and associated road network appear to have been constructed (USGS 2018). King County atlases that date to 1907 show that the southwest quarter of the northwest quarter of Section 15 (T21N, R4E) was owned by William Hatfield (Anderson Map Company 1907). The portion of Section 16 (T21N, R4E) within the project area appears under the generalized ownership of "School," without further qualification. Puget Sound Electrical Company and Weyerhaeuser Timber Companies appear as large land -holding entities in the surrounding area at this time. By 1912 and through to 1936, Section 16 appears once again as being owned by the State of Washington, which may indicate continuous ownership of this portion of the project area, given the previous operation of a state -funded school in the area (Kroll Map Company 1912, 1926; Metsker 1936). The eastern half of the southeaster quarter of Section 16 (i.e., Lots 1 and 2) appears to have been temporarily purchased from the state by C.B. Niblock in 1912, then sold back to the state by 1926. In 1936, these parcels are owned by Purdy's Resort (Metsker 1936). Meanwhile, the portion of project area land within Section 15 had changed hands from William Hatfield to Minerva Fullenwider by 1912, to J. Combs and H. Raymond by 1926, and to "Goldens (sic) Lake" by 1936. Readily available King County atlases from the mid- to later -twentieth century do not provide sufficient detail to provide relevant land -holding information (Metsker 1940, 1950, 1980; Thomas Bros. 1955). In 2015, the project area was zoned as a Corporate Park, under a special condition Ordinance #93-190 (City of Federal Way 2015). Historic -era municipal zoning maps for the city of Federal Way do not exist or are not readily available, likely because the city did not incorporate until 1990 (Stein 2003). Additionally, there are no historic -era Sanborn Fire Insurance Company maps for the Federal Way region (Digital Sanborn Maps 1867-1970). CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 2 (..:7 cardna Archival Research Cardno conducted a background search and literature review of existing cultural resource records; local, state, and national register nomination forms; previous cultural resources investigations; and any known or potential TCPs in and within 1.0 mile (1.6 km) of the project area. According to the DAHP's predictive model available on the WISAARD online database, the majority of the project area has low risk for encountering buried archaeological deposits. A small portion of the northeastern portion of the project area has moderately low risk for encountering buried archaeological deposits. Previous Investigations Six cultural resources surveys were previously conducted within 1.0 mile (1.6 km) of the project area between 1999 and 2014 (Table 1). There are no previously conducted surveys that overlap with the current project area. Table 1 Cultural Resources Investigations within 1.0 Mile of the Project Area n=6 1999 Forsman et al. 2005 Earley 2005 Luttrell 2006 Bard and Durio Regional Express/Federal Way and Star Lake 1339832 Survey Report 0.1 and 0.5 Project Cultural Resource Assessment, Federal mile W Way Alternative Cultural Resources Assessment of the Thompson Park PrviFct, Federal Way Letter to Kimberly Farley Regarding 1-5: Pierce County Line to Tukwila Stage 4 HOV Project _ FINAL REPORT: Cultural Resources Discipline Report for 1-5 SR 161/SR 18 Triangle Improvements 1345011 Survey Report 0.15 mile W 1345762 Survey Report 0.5 mile SSW 1348206 Survey Report 0.1 mile SW 2006 Luttrell Cultural Resources Investigations for 1348213 Survey Report 0.9 mile NNE Washington Department of Fish and Wildlife's Lake Dolloff Access Redevelopment Project 2014 Baldwin Cultural Resources Assessment for the Pacific 1685856 Survey Report 0.6 mile W Highway South HOV Lanes Phase V (S 340th Street to S 359th Street) Project. Federal Way Notes: HOV = high occupancy vehicle(s); I = Interstate; LAAS = Larson Anthropological Archaeological Services; SR = State Route Sverdrup Civil, Inc. retained Larson Anthropological Archeological Services, Limited (LAAS) to conduct a cultural resources assessment for the Federal Way Alternative of the Regional Express/Federal Way and Star Lake Project (Forsman et al. 1999). Each project location that was designated for proposed ground disturbance was surveyed for archaeological materials. Two project locations are located approximately 0.1 mile (0.2 km) and 0.5 mile (0.8 km) west of the current project area. No archaeological resources were identified during the survey. A survey of the historic structures in the vicinity of these project locations determined that this project would have no adverse effect on structures listed or eligible for listing in the NRHP. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com 13 ►� Martina March 16, 2018 The City of Federal Way proposed site improvements to Thompson Park in Federal Way, Washington, and retained Northwest Archaeological Associates, Inc. (NWAA) to conduct a cultural resources assessment for the project, located approximately 0.15 mile west of the current project area (Earley 2005). The assessment, which included both pedestrian and subsurface investigations, did not encounter any precontact or historic -era cultural resources and recommended that no further cultural investigations were necessary for the project to proceed (Earley 2005). On behalf of the Washington State Department of Transportation (WSDOT), Archaeological and Historical Services (AHS) of Eastern Washington University conducted a cultural resources evaluation of a historical foundation (45KI00719) inadvertentlydiscovered during vegetation grubbing (Luttrell 2005a). See below for additional details on the historic -era site. In 2006, a cultural resources discipline team composed of eight engineering and consulting firms prepared a discipline report to evaluate the effects that the proposed WSDOT project would have on cultural resources within the study area (Bard and Durio 2006). This project was located at the intersections of 1-5 with State Route (SR)-18 and SR-161, the closest of which was approximately 0.1 mile southwest of the current project area. The study did not identify any precontact or historic -period archaeological resources, TCPs, or historic structures eligible for listing in the NRHP. AHS was retained by the Washington State Department of Fish and Wildlife (WDFW) in 2006 to conduct a cultural resources investigation for the Lake Dolloff Access Redevelopment Project, located approximately 0.9 mile north- northwest of the current project area (Luttrell 2006). The project surveyed 2.71 acres along Lake Dolloff, encountering only non -diagnostic modern debris, likely the result of recreational litter. AHS recommended that no further cultural resources work was necessary for the proposed project (Luttrell 2006). In 2014, Drayton Archaeology (DA) conducted a cultural resources assessment on behalf of Widener and Associates for a highway expansion project located 0.6 mile west of the current project area (Baldwin 2014). The cultural resources assessment, which consisted of pedestrian survey, visual reconnaissance, and a review of soil borehole logs previously excavated within the project area, did not identify any cultural resources. As such, DA recommended that no historic properties were affected by the undertaking. Archaeological Resources The records indicate that no archaeological sites have been previously recorded within the project area. One known historic cultural resource was identified within 1.0 mile (1.6 km) of the project area (Table 2). No TCPs were identified within the 1.0-mile (1.6-km) search radius. Table 2 Previously Recorded Archaeological Resources within 1.0 Mile of the Project Area (n=1) 45KI00719 - Historic residential Not Eligible 1345762 Luttrell 2005b 0.5 mile SSW structure Bartoy 2013 Site 45KI00719 is a historic residential structure and associated historic debris scatter that was identified at the western extent of the South 348th Street cul-de-sac and west of 1-5, approximately 0.5 mile south-southwest of the current project area. The structure's foundation measured approximately 20 ft by 18 ft and appeared to have been constructed from both water -round and angular cobbles and boulders (Luttrell 2005b). At the time of recording in 2005, the tallest point of the foundation measured approximately 6 ft high, but portions of the foundation were observed to be crumbling. Additional structural materials observed in the vicinity of the foundation included large disturbed boulders, small concrete slabs, flat window glass, brick, plywood, and lumber, among other materials. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com 14 (,., Gardncr March 16, 2018 WSDOT recommended that the site was not eligible for inclusion in the NRHP in 2005; DAHP concurred with the eligibility determination for the site (Griffith 2005). Eastern Washington University's AHS revisited the site in 2013 and found that the site had been removed by WSDOT during right-of-way construction, and no longer exists (Bartoy 2013). Historic Resources The records search indicates that 22 historic properties are located within the 1.0-mile (1.6-km) search radius of the project area (Table 3). Of the 22 historic properties within the search radius, 2 properties have been determined eligible for listing in historic registers, 19 properties have been determined not eligible for listing in historic registers, and 1 property has not been formally evaluated. Table 3 Previously Recorded Historic Resources within 1.0 Mile of the Project Area (n=22) 28910 Weyerhaeuser 33663 Weyerhaeuser Building 1969 Eligible 0.2 mile S Headquarters Way S 40945 Stevenson 32330 Pacific Hwy S Building 1945 Unevaluated 0.8 mile W Motel 86451 - 33570 Pacific Hwy S Building - Not Eligible 0.5 mile W 86947 Stevenson 33330 Pacific Hwy S Building 1948 Not Eligible 0.5 mile W Motel 100773 Calvary 2415 S 320th St Building 1956 Eligible 0.3 mile NW Lutheran Church 673607 31405 18th Ave S Building 1959 Not Eligible 1.0 mile NW 674015 31612 28th Ave S Building 1951 Not Eligible 0.5 mile N 674016 31250 28th Ave S Building 1968 Not Eligible 0.7 mile N 674017 - 31228 28th Ave S Building 1943 Not Eligible 0.7 mile N 674018 Steel Lake 31130 28th Ave S Building 1959 Not Eligible 0.8 mile N Maintenance Facility 674019 - 31104 28th Ave S Building 1959 Not Eligible 0.9 mile N 674027 31016 28th Ave S Building 1963 Not Eligible 0.9 mile N 674028 31004 28th Ave S Building 1943 Not Eligible 0.9 mile N 674029 - 31000 28th Ave S Building 1943 Not Eligible 1.0 mile N 674117 - 31458 Pacific Hwy S Building 1970 Not Eligible 0.9 mile NW 674119 - 31254 Pacific Hwy S Building 1961 Not Eligible 1.0 mile NW 674318 Belmor Mobile 2101 S 324th St Building 1966 Not Eligible 0.4 mile W Home Park 674674 Marie Wells 3911 328th St Building 1960 Not Eligible 0.2 mile E CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 15 4,'� Gar-dna i 675339 Shell Gas Station and Food Mart 31660 Pacific Hwy S Building 1957 Not Eligible 0.8 mile NW 675407 - 31675 Pacific Hwy S Building 1968 Not Eligible 0.8 mile NW 675408 Church's Chicken 31717 Pacific Hwy S Building 1969 Not Eligible 0.8 mile NW 709523 - 3409 20th Ave S Building Not Eligible 0.8 mile NW Cultural Significance Cardno's Senior Archaeologist, Jennifer M. Ferris, MA, RPA, conducted a field visit on February 9, 2018. During her visit, she documented the existing conditions and photographed the substantial twentieth century land use modification of the project area (Figures 4 through 8). Archival research indicates that a low level of human activity may have taken place within or adjacent to the project area during precontact and historic times. Of the few studies that have been conducted in the region, none have identified any precontact cultural materials. Little evidence suggests any long-term precontact occupation within the project area; rather, the land that encompasses the current project area was only traversed for resource procurement during seasonal collection. Furthermore, the deposits within the project area consist of a shallow organic -rich sod/forest duff stratum, underlain by native glacial till material (Helvey and Overbay 2017). The glacial till deposited by glacial retreat (Dragovich et al. 2002), which indicates that cultural items, if present, would not be deeply buried. The area underwent significant historic -era and modern land use modification including logging and commercial development, which would have disturbed the shallow glacial till. Cardno concludes that the potential for encountering surficial and/or subsurface precontact archaeological deposits between the modern surface and the base of the Holocene sediments is low. Though low potential, it is possible that archaeological resources currently unknown within the project area may hold importance as properties of religious and cultural significance (including TCPs) to Indian tribes. Cardno also concludes that the potential for encountering surficial and/or subsurface historic archaeological materials between the modern surface and the base of the Holocene sediments is low. Historic archaeological deposits that may exist in the area are likely to be associated with the Weyerhaeuser campus and/or historic -era timber operation (e.g., saw blades, spring -board stump features). CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 16 C"') Car-cina Figure 4 Overview of the former WTC building from turnaround in northern portion of the project area; facing southeast. Figure 5 Overview of the north entrance road into the former WTC campus and present land use modification; facing south. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 18 (Z') Cardnv Figure 8 Overview of Weyerhaeuser Way South and existing utility infrastructure from the eastern portion of the project area; facing northeast. Architectural Significance Cardno's Project Architectural Historian, Michelle Sadlier, MA, conducted a historic resources survey on February 6, 2018. She documented and photographed the WTC building, located at 32901 32nd Drive South (within parcel 162104-9013) and its associated outbuildings. Given that the WTC building and its associated outbuildings are younger than 50 years in age, a Historic Property Inventory form was not completed. Narrative The project is located 0.2 mile from the central Weyerhaeuser Headquarters campus and consists of the WTC grounds and a number of adjacent, undeveloped parcels. Construction drawings for the WTC indicate that it was designed in 1976 by Skidmore, Owings & Merrill, which is the firm that also designed the 1969 NRHP-eligible Weyerhaeuser Headquarters. Construction of the WTC was completed in late 1977/early 1978 (Figure 9) (Seattle Times 1977; King County Tax Assessor's Office 2018). CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 19 �Z� Gar-cino Figure 9 Construction of the Weyerhaeuser Technology Center; facing east. (Source: Weyerhaeuser company files) As designed, the purpose of the WTC was to combine all of Weyerhaeuser's research, development, and engineering services previously located in other offices around the country into one, centralized campus (Figures 10 through 14). It served this purpose for 40 years. Since the Weyerhaeuser Headquarters' recent move to Seattle, however, the number of Weyerhaeuser staff occupying the WTC has dropped significantly. The campus was sold to IRG and name of the facility changed to the Greenline Technology Center. Today, much of the square footage of the former WTC is leased to the company International Paper (Bylin 2018). CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 20 (11 7 Gar-dna Figure 10 Entrance to the Weyerhaeuser Technology Center; north elevation. Figure 11 Weyerhaeuser Technology Center; north elevation. CONFIDENTIAL- NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 21 ! Gardno Figure 12 Weyerhaeuser Technology Center; south elevation. Figure 13 South elevation of Weyerhaeuser Technology Center as viewed from the service yard. The fire hydrant marks the original boundary of the yard, with the pavement in the foreground located within the 1990s expansion area. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 22 L,�7 Gardno Figure 14 Some of the outbuildings that have been constructed outside the WTC since the 1990s expansion of the yard; facing south. Historic Property Evaluation The WTC was constructed 40 years ago in 1977/1978, and outbuildings located in its service yard were constructed after this time. So, while the WTC is not without architectural merit, its date of construction places it outside of the 45-year threshold for consideration for eligibility for local, state, and national registers of historic places under SEPA. The WHIR and NRHP ordinarily use an age threshold of 50 years old or older for determinations of eligibility. However, because the Weyerhaeuser Headquarters campus was itself determined eligible prior to reaching the 50- year threshold for consideration for NRHP eligibility, Cardno evaluated the WTC for potential eligibility under Criteria Consideration G: a property achieving significance within the past 50 years if it is of exceptional importance. While the WTC was designed by the same architects responsible for the Weyerhaeuser Headquarters, it was not conceived as part of that innovative, award -winning master plan. Archival research has failed to identify a noteworthy and widespread level of contemporary or retrospective public or professional interest in the design of the building. Despite the quality of design of the building, Cardno concludes that, on its own merits, the WTC does not achieve the level of exceptional importance needed to be considered eligible for the NRHP under Criteria Consideration G. Recommendations Due to the dates of construction, Cardno recommends that the WTC and its associated outbuildings are Not Eligible for listing in the WHIR or NRHP. In addition, although the City of Federal Way appears to be in the process of establishing a register of historic places, formal agreements are not yet in place. Therefore, no buildings are eligible for a local register either. As an ineligible property, the WTC and its associated outbuildings do not merit consideration of project effects for the proposed development project. Cardno recommends the WTC and its outbuildings be evaluated in 10 years when the building meets the NRHP's minimum age threshold of 50 years old. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com 23 �'� Cal-cina March 16, 2018 Given the low potential for encountering buried cultural resources, Cardno does not recommend an intensive archaeological survey be completed for the proposed project. However, Cardno does recommend that a Monitoring and Inadvertent Discovery Plan (MIDP) be developed to outline steps to be taken by Federal Way Campus, LLC to minimize potential impacts to any currently unknown intact archaeological resources in the event of an inadvertent discovery during construction. These steps would serve to minimize damage to any inadvertently discovered archaeological resources during ground -disturbing activities, which may include small, deeply buried, and/or widely dispersed historic or precontact cultural materials (e.g., saws, saw blades, railroad ties, stakes, and footings; glass bottles; sanitary cans; chipped -stone tools; ground stone; beads; shell; faunal remains; human remains; funerary objects; and objects of cultural patrimony). Steps included in the MIDP would outline the applicable local laws and regulations, stop -work and notification protocols, discovery protection measures, assessment by professional archaeologists, and consultation with the DAHP and any affected Indian tribes. In the state of Washington, archaeological sites are protected from knowing disturbance on both public and private lands. RCW 27.44 and RCW 27.53.060 require that a person obtain a permit from the DAHP before excavating, removing, or altering Native American human remains or archaeological resources in Washington. A failure to obtain a permit is punishable by civil fines and penalties under RCW 27.53.095 and criminal prosecution under RCW 27.53.090. Cardno recommends spot monitoring of project -related ground -disturbing activities within Holocene sediments by a professional archaeologist who meets the Secretary of the Interior's (SOI's) professional qualifications standards (36 Code of Federal Regulations [CFRj Part 61) for archaeology or by a qualified archaeologist supervised by a professional archaeologist who meets the SOI standards. Spot monitoring entails a weekly site visit to the project area during ground -disturbing activities and allows for a previously unexamined substrate to be observed by personnel qualified in the identification of archaeological materials in order to evaluate the subsurface deposition of the project area. Ground -disturbing activities include removal of any existing asphalt that extends into native fill and alluvial sediments, site grading, development of staging areas, and installation of utilities and structural foundation pilings. Monitoring should occur on a schedule determined in consultation with Federal Way Campus, LLC, the SOI-qualified archaeologist, and the DAHP only during ground disturbance that extends from the ground surface to the base of the Holocene sediments, which will vary in elevation across the project area, but typically do not exceed 18 inches below ground surface. The spot schedule should be determined during development of the MIDP. In addition, the monitor should be available on -call to respond to any potential inadvertent discoveries that would be reported in the manner outlined in the MIDP. Please feel free to contact Ms. Ferris should you have any questions regarding the assessment of cultural significance or recommendations. Sincerely, Daniel B. Costa Staff Archaeologist CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 Michelle Sadlier, MA Project Architectural Historian Jennifer Ferris, MA, RPA Senior Archaeologist PNW Cultural Resources Practice Lead Direct Line: 206.239.7390 Email: men nifer.ferris@cardno.com 24 (�.', Cardno www.cardno.com March 16, 2018 References Cited 25 � Car_c la Ames, K.M., and H.D.G. Maschner 1999 Peoples of the Northwest Coast. Their Archaeology and Prehistory. Thames and Hudson, Ltd., London. Anderson Map Company 1907 Page 14 - Township 21 North, Range 4 East. From King County 1907, Washington. Anderson Map Co. Electronic document, http://www.historicmapworks.com/. Baldwin, G.L. 2014 Cultural Resources Assessment for the Pacific Highway South HOV Lanes Phase V (S 340th Street to S 359th Street) Project, Federal Way. Report prepared by Drayton Archaeology. Report prepared for Widener and Associates. On file, Department of Archaeology and Historic Preservation, Olympia. Bard, J.C., and L. Durio 2006 FINAL REPORT: Cultural Resources Discipline Report for 1-5 SR 161/SR 18 Triangle Improvements. Report prepared by BERGER/ASAM Engineers, Inc. Report prepared for Washington State Department of Transportation. On file, Department of Archaeology and Historic Preservation, Olympia. Bartoy, K.M. 2013 Site 45KI00719 Washington Archaeological Site Inventory Form Update. On file, Washington State Department of Archaeology and Historic Preservation, Olympia. Becker, P. 2006 Pierce County — Thumbnail History. HistoryLink Essay No. 8001. Electronic document, hftp://www.historylink.org/. Booth, D.B., and B. Goldstein 1994 Patterns and Processes of Landscape Development by the Puget Lobe Ice Sheet. In Regional Geology of Washington State, edited by R. Lasmanis and E.S. Cheney, pp. 207-218. Washington State Department of Natural Resources Division, Olympia, Washington. Brubaker, L.B. 1991 Climate Change and the Origin of Old -Growth Douglas -Fir Forests in the Puget Sound Lowland. In Wildlife and Vegetation of Unmanaged Douglas -Fir Forests, edited by Leonard F. Ruggiero, Keith B. Aubry, Andrew B. Carey, and Mark F. Huff, pp 17-24. U.S. General Technical Report PNW-GTR-285. Department of Agriculture, Forest Service, Pacific Northwest Research Station, Portland. Bureau of Land Management (BLM) 2018 General Land Office Records. Electronic document, https://glorecords.blm.gov/search/default.aspx?searchTabindex=0&searchByTypeIndex=1 Bylin, A. 2018 Personal communication with the Operations and Facility Manager for the Weyerhaeuser Technology Center. February 23, 2018. Carlson, C.C. 2003 The Bear Cove Fauna and the Subsistence History of Northwest Coast Maritime Culture. In Archaeology of Coastal British Columbia: Essays in Honour of Philip M. Hobler, edited by R.L. Carlson, pp. 65-86. Archaeology Press, Simon Fraser University, Burnaby. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com L ] March 16, 2018 26 carcincr Carlson, R.L. 1990 Cultural Antecedents. In Northwest Coast, edited by Wayne Suttles, pp. 60-69. Handbook of North American Indians, Vol. 7, William C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C. Caster, D. 2004 Natural History, Geology and Geography of the Federal Way Area. Historical Society of Federal Way, Federal Way, Washington. 2015 Historical Society of Federal Way Timeline. Historical Society of Federal Way, Federal Way, Washington. Chesley, F. 2008 Puyallup — Thumbnail History. HistoryLink Essay No. 8447. Electronic document, hftp://www.historylink.org/File/8447. City of Federal Way 2015 Official Zoning Map. Electronic document, http://www.ci.federal- way.wa.us/sites/default/files/maps/Zoning_0. pdf. City of Puyallup 2018 History: The Land of the Generous People. Electronic document, hftp://www.ci.puyallup.wa.us/524/History. Dailey, T. No date. Coast Salish Villages of Puget Sound: Village Descriptions Puyallup -Tacoma. Electronic document, http://www.coastsalishmap.orgNillage_Descriptions_Puyallup-Tacoma.htm#1 3. Digital Sanborn Maps 1867-1970 Fire Insurance Maps. Sanborn Map Company, New York. Electronic document, http://sanborn.umi.com.ezproxy.spi.org/, accessed January 2018. Dixon, E.J. 1993 Quest for the Origins of the First Americans. University of New Mexico Press, Albuquerque. Dragovich, J.D., P.T., Pringle, and T.J. Walsh 1994 Extent and geometry of the mid -Holocene Osceola Mudflow in the Puget Lowland: Implications for Holocene sedimentation and paleogeography. Washington Geology 22(3):3-2. Dragovich, J.D., R.L. Logan, H.W. Schasse, T.J. Walsh, W.S. Lingley, Jr., D.K. Norman, W.J. Gerstel, T.J. Lapen, J.E. Shuster, and K.D. Meyers 2002 Geologic Map of Washington - Northwest Quadrant. Geologic Map Gm-50. Washington Division of Geology and Earth Resources, Olympia, Washington. Earley, A. 2005 Cultural Resources Assessment of the Thompson Park Project, Federal Way, King County, Washington. Report prepared by Northwest Archaeological Associates, Inc. Report prepared for the City of Federal Way. On file, Department of Archaeology and Historic Preservation, Olympia. Easterbrook, D.J. 2003 Quaternary Geology of the United States: INQUA 2003 Field Guide Volume. The Desert Research Institute, Reno, Nevada. On file, Department of Archaeology and Historic Preservation, Olympia. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 27 L,'� Cardno ESM Consulting Engineers, LLC 2017 Greenline Business Park, Process IV Land Use Application with SEPA. Letter to Jim Harris, Community Development Department, from Matt Reider, ESM Consulting Engineers, LLC, Federal Way, WA. Fedje, D.W., and T. Christensen 1999 Modeling paleoshorelines and locating early Holocene coastal sites in Haida Gwaii. American Antiquity 64:635-652. Fladmark, K.R. 1979 Routes: alternate migration corridors for early man in North America. American Antiquity 44:55-69, Forsman, L.A., D.W. Lewarch, J.B. Cooper, and L.L. Larson 1999 Regional Express/Federal Way and Star Lake Project Cultural Resource Assessment Federal Way Alternative. Report prepared by LAAS. Report prepared for Sverdrup, Inc. On file, Department of Archaeology and Historic Preservation, Olympia. Franklin, J.F., and C.T. Dyrness. 1988 Natural Vegetation of Oregon and Washington. U.S. Department of Agriculture Forest Service, General Technical Report PNW-8. Portland, Oregon. Griffith, G. 2005 1-5 Pierce County Line to Tukwila Stage 4 HOV project, Chessman house site. Letter to Craig Holstine, WSDOT, from Gregory Griffith, Department of Archaeology and Historic Preservation, Olympia, Washington. Haeberlin, H.K., and E. Gunther 1930 The Indians of Puget Sound. University of Washington Press, Seattle. Helvey, S.W., and D.C. Overbay 2017 Geotechnical Engineering Services Report, Greenline Business Park former Weyerhaeuser Site Federal Way Washington. Prepared by GeoEngineers, Inc. Report prepared for Federal Way Campus, LLC. King County Tax Assessor's Office 2018 King County Parcel Viewer KCGIS Center. Electronic document, http://gismaps.kingcounty.gov/pareelviewer2/. Kirk, R., and R.D. Daugherty 2007 Archaeology in Washington. University of Washington Press, Seattle. Kroll Map Company 1912 Township 21 North, Range 4 East. From King County 1912, Washington. Kroll Map Co. Electronic document, http://www.historicmapworks.com/. 1926 Plate 014 - T. 21 N., R. 4 E., Edgewood, Jovita, Pacific City, Auburn, Puget Sound. From King County 1926, Washington. Kroll Map Co. Electronic document, http://www.historicmapworks.com/. Lentz, F.K. 1990 Kent Valley of Opportunity. Windsor Publications, Inc., Chatsworth, California. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 28 qc.:� cai- ina Liesch, B.A., C.E. Price, and K.L. Walters 1963 Geology and ground -water resources of northwestern King County, Washington. Water Supply Bulletin No. 20. Division of Water Resources, Department of Conservation, Olympia, Washington. Luttrell, C.T. 2005a Letter to Kimberly Farley Regarding 1-5: Pierce County Line to Tukwila Stage 4 HOV Project. Report prepared by Archaeological and Historical Services of Eastern Washington University. Report prepared for Washington State Department of Transportation. On file, Department of Archaeology and Historic Preservation, Olympia. 2005b Site 45KI00719 Washington Archaeological Site Inventory Form. On file, Washington State Department of Archaeology and Historic Preservation, Olympia. 2006 Cultural Resources Investigations for Washington Department of Fish and Wildlife's Lake Dolloff Access Redevelopment Project. Report prepared by Archaeological and Historical Services of Eastern Washington University. Report prepared for Washington State Department of Fish and Wildlife. On file, Department of Archaeology and Historic Preservation, Olympia. Metsker, C.F. 1936 Township 21 N., Range 4 E., Auburn, Jovita, Pacific City, Buenna. From King County 1936, Washington. Chas. F. Metsker. Electronic document, http://www.historicmapworks.com/. 1940 King County 1940c. From King County 1940, Washington. Chas. F. Metsker. Electronic document, hftp://www.historicmapworks.com/. 1950 King County 1950c. From King County 1950, Washington. Chas. F. Metsker. Electronic document, hftp://www.historicmapworks.com/. 1980 King County 1980 to 1996 Tracing. From King County 1980 to 1996 Tracing, Washington. Chas. F. Metsker. Electronic document, http://www.historicmapworks.com/. Miss, C.J. 2008 SR 99: Alaskan Way Viaduct & Seawall Replacement Program: Results of the Archaeological Core Collection Program, Phase I. Northwest Archaeological Associates, Inc. On file, Department of Archaeology and Historic Preservation, Olympia. Mullineaux, D.R. 1970 Geology of the Renton, Auburn, and Black Diamond Quadrangles, King County, Washington. U.S. Geological Survey, Professional Paper 672, Washington, D.C. Palmer, S.P. 1997 Holocene Geologic History and Sedimentology of the Duwamish and Puyallup Valleys, Washington. Washington Department of Natural Resources, Geology and Earth Resources Division, Olympia, Washington. Peto, E., A. McGlone, and D. Eggers n.d. Written history. Kent School District. Electronic document, http://l 64.116.204.29/curriculum/vtours/kent/site—info/index.html. Puyallup Tribe of Indians 2018 Our Tribe. Electronic document, http://www.puyallup-tribe.com/ourtribe/. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 29 Rinck, B., J. Piper, and E. Heideman 2012 Preliminary Cultural Resources Assessment of the Upper Clear Creek Mitigation Property Habitat Restoration, Tacoma. Report prepared by Northwest Archaeological Associates and SWCA Environmental Consultants. Report prepared for Port of Tacoma. On file, Department of Archaeology and Historic Preservation, Olympia. Roedel, K.W., L.A. Forsman, D.E. Leward, and L.L. Larson 2003 Salishan Redevelopment Archaeological Resources and Traditional Cultural Places Assessment, City of Tacoma, Pierce County, Washington. Report prepared by Larson Anthropological Archaeological Services, Ltd. Report prepared for Parametrix, Inc. and Tacoma Housing Authority. On file, Department of Archaeology and Historic Preservation, Olympia. Seattle Times 1977 Weyerhaeuser Center nears completion. Seattle Times, October 2, 1977: H19. Smith, M.W. 1940 The Puyallup-Nisqually. New York, Columbia University Press. Snyder, D.E., P.S. Gale, and R.F. Pringle 1973 Soil Survey of King County Area, Washington. U.S. Department of Agriculture, Soil Conservation Service. Stein, A.J. 1999a Des Moines Thumbnail History. HistoryLink Essay No. 697. Electronic document, hftp://www.HistoryLink.org. 1999b Auburn Thumbnail History. History Link Essay No. 675. Electronic document, http://www.historylink.org/index.cfm?DisplayPage=output.cfm&file_id=675. 2003 Federal Way- Thumbnail History. HistoryLink Essay No. 4215. Electronic document, hftp://www.Historylink.org. Suttles, W., and B. Lane 1990 Prehistory of the Puget Sound Region. In Northwest Coast, edited by Wayne Suttles, pp. 485-502. Handbook of North American Indians, Vol. 7, William C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C. Thomas Bros. 1955 King County 1955. From King County 1955, Washington. Thomas Bros. Electronic document, hftp://www.historicmapworks.com/. United States Department of Agriculture (USDA) 2018 National Resources Conservation Service - Web Soil Survey. Electronic document, https://websoilsurvey.sc.egov.usda.gov/AppNVebSoilSurvey.aspx. United States Geological Survey (USGS) 1997 Poverty Bay quadrangle, Washington. Map. 1:24,000-scale 7.5-minute topographic quadrangle. U.S. Geological Survey, Reston, Virginia. 2003 Tacoma South quadrangle, Washington. Map. 1:24,000-scale 7.5-minute topographic quadrangle. U.S. Geological Survey, Reston, Virginia. 2018 Historic Topographic Map Explorer. Electronic document, http://historicalmaps.arcgis.com/usgs/. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com March 16, 2018 30 Vallance, J.W., and K.M. Scott 1997 The Osceola Mudflow from Mount Rainier: Sedimentology and hazard implications of a huge clay -rich debris flow. GSA Bulletin 109:143-163. Waterman, T.T., V. Hilbert, J. Miller, and Z. Zahir 2001 Puget Sound Geography. Original Manuscript from T.T. Waterman. Lushootseed Press, Federal Way, Washington. Weaver, R.M. 2003 Puyallup River Side Channel Habitat Restoration Project, Cultural Resources Section 106 Assessment. Report prepared for the City of Tacoma, Environmental Engineering Department, by the Environmental History Company, Seattle. Weyerhaeuser Company 2018 History Since 1900. Electronic document, https://www.weyerhaeuser.com/company/history/. Williams, R.W., R.M. Laramie, and J.J. Ames 1975 A Catalog of Washington Streams and Salmon Utilization, Volume 1, Puget Sound Region. Washington State Department of Fisheries, Olympia. Yount, J.C., J.P. Minard, and G.R. Dembroff 1993 Geologic Map of Surficial Deposits in the Seattle 30 X 60 Quadrangle. OFR 93-233. U.S. Geological Survey, Washington, D.C. CONFIDENTIAL - NOT FOR PUBLIC DISCLOSURE www.cardno.com ry 5309 Shilshole Avenue, NW www.esassoc.com l Suite 200 J Seattle, WA 98107 206.789.9658 phone 206.789.9684 fax L d L . memorandum' date April 11, 2018 to Jim Harris, City of Federal Way Department of Community Development from Jessica Redman and Ilon Logan subject Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park - DRAFT . f� f ; IV%� At the request of the City of Federal Way (City), Environmental Science Associates (ESA) reviewed the Critical Areas Report and Conceptual Mitigation Plan — Greenline.Business Park (dated October 27, 2017) prepared by Talasaea Consultants Inc. for the property at approximately 32901 Weyerhaeuser Way South in Federal Way, Washington. The 146-acre site is a combination of six parcels (King County Tax Parcel Numbers 1621049056, 1521049178, 1621049013, 1621049030, 2285000010, and 7978200420) currently owned by Federal Way Campus, LLC. `1 IV This This property was 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). The current application involves the construction of three new buildings that will provide approximately 1,068,000 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 five 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, 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 Critical Areas Report and Conceptual Mitigatior, in Review: Greenline Business Park - DRAFT ESA reviewed the Critical Areas Report and Conceptual Mitigation Plan — Greenline Business Park (dated October 27, 2017 and hereinafter referred to as the Report) and the Greenline Business Park Site Plan prepared by ESM Consulting Engineers (dated November 15, 2017). According to the documents, sixty-three 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. Construction of the three buildings, stormwater facilities, and parking areas would impact 13,428 SF (0.31 acre) of wetlands. Four wetlands would be insufficiently buffered, and therefore are being considered indirectly impacted due to site development encroachments, resulting in an additional 4,912 SF (0.11 acre) of impact. The total 18,340 SF (0.42 acre) of direct and indirect wetland impacts would be mitigated for through 36,023 SF (0.82 acre) of wetland creation and 2,020 SF (0.05) of wetland enhancement. Wetland mitigation will meet and exceed ratios provided in FWRC 19.145.430(5) and will occur onsite in the vicinity of North Lake. In addition, 98,168 SF (2.3 acres) wetland buffer will be created around the area of wetland creation. No work will occur within the ordinary high water of the stream. However, the buffer on the east side of the stream would be reduced by 25% to 75-feet to accommodate the development. The total stream buffer reduction of 12,545 SF (0.29 acre) will be mitigated for by adding an additional.14,489 SF (0.33 acre) of stream buffer to the west side of the stream. 94,266 SF (2.2 acres) of the existing and proposed stream buffer will also be enhanced by removing invasive species and subsequently planting native trees and shrubs. Finally, a gravel path and berm that occur within the site will be removed and replanted with native trees and shrubs. This will account for approximately 35,689 SF (0.8 acre) of wetland and stream buffer enhancement. Review Comments and Recommendations • As documented in our previous review of the Tech Center BLA (memo dated August 22, 2017), we agree with the wetland delineation boundaries, rating forms, and rating classifications established by Talasaea for wetlands occurring on the proposed project site. • We generally agree with the conceptual mitigation plan and believe that the proposed mitigation site appears to be an adequate location for wetland creation. As the mitigation design progresses, we strongly recommend that the applicant perform further environmental investigations (groundwater level monitoring, soil analysis, etc.) at the proposed mitigation site to acquire the necessary data and information to inform mitigation feasibility and design. Impacts to wetlands should be minimized to the extent possible. It appears that the proposed 820 SF of wetland fill in Wetland DE may be avoided by minimal design alterations while still resulting in a viable project. We recommend impacts to this wetland are reevaluated. The City considers grading within a wetland buffer to be development, and therefore, the applicant should show that the proposed temporary buffer impacts due to site grading meet the criteria under FWRC 19.145.440 — Deuelopinent within wetland buffers. Temporary buffer impacts should also be included on the figures in the Report. • Referring to Figure WI.3 of the Report, it appears that buffer creation is proposed in the existing buffer of Wetlands BB and BD North. This area should not be considered to be new buffer and the Report and figures should be revised to reflect any changes. 2 Critical Areas Report and Conceptual Mitigatioi...an Review: Greenline Business Park - DRAFT • The wetland buffers on the Site Plan are inconsistent with the wetland buffers on the figures in the Report. For example, buffers for Wetlands BA-2, PK, and BB appear larger on the Site Plan than on Figure WI.1 in the Report. The Site Plan should be revised to reflect the buffers presented in the Report. • 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. Site Plan sheets should be revised to show post -development buffers and an existing conditions figure should be added to the Site Plan. Jim Harris From: Stacey Welsh Sent: Tuesday, April 10, 2018 9:20 AM To: Jim Harris Subject: FW: Greenline Business Park -- Temporary Buffer Impacts From: Jessica Redman [mailty:JRedman@esassoc.com] Sent: Tuesday, April 10, 2018 9:16 AM To: Stacey Welsh Cc: Ilon Logan Subject: Greenline Business Park -- Temporary Buffer Impacts Hi Stacey, I'm currently reviewing the Greenline Business Park Critical Areas Report. The project is proposing 20,498 square feet of temporary impacts to wetland buffers during construction to accommodate site grading. I know temporary impacts were an issue with Warehouse A because the 1994 code does not address temporary impacts. Also, the temporary impact was the installation of a large pipe in that proposal. Under the current code, temporary impacts are also not discussed, and development in wetland buffers requires buffer averaging or buffer reduction to occur. I was curious how the City handles grading in the wetland buffer under the current code. Would buffer averaging be necessary or would restoration post -construction suffice? Thanks, Jessica II l ld a600 (j 0�^�c Jessica Redman Associate Scientist ESA I Northwest Biological Resources Group \ x� 5309 Shilshole Avenue NW, Suite 200 Seattle, WA 98107 206.789-9658 1 206.789-9684 fax jredman _esassoc.com c JL c. �Jrc 65Y of�� Alk CITY 4P Federal Way NOTICE OF MASTER LAND USE APPLICATION *Revised to Eliminate Initial Public Comment period deadlin Written comments may be submitted as specified below* Project Name: Greenline Business Park Project Description: Construction of three buildings totaling approximately 1,068,000 square feet, five new stormwater ponds, revisions to existing parking lot and addition of approximately 806 parking stalls, filling approximately 13,500 square feet of wetlands, roadway improvements, and associated site improvements on 146 acres. Applicant: Federal Way Campus, LLC, 11100 Santa Monica Blvd, Suite 850, Los Angeles, CA 90025 Agent: ESM Consulting Engineers, LLC, 33400 8t` Avenue South, Suite 205, Federal Way, WA 98003 Project Location: Approximately 329XX Weyerhaeuser Way South, Federal Way, WA, King County Parcels 162104-9056, -9013, -9030 and152104-9178 Date of Application: November 14, 2017 Date of Notice of Application: May 18, 2018 July May 13, 2018 Date Determined Complete: May 14, 2018 Date of Re -Issued Notice of Application: Requested Decision and Other Permits Included with this Application: The applicant requests a Use Process IV Hearing Examiner decision (File #17-105489-UP) pursuant to Federal Way Revised Code (FWRC) Chapter 19.70. Additional permits and/or approvals in conjunction with the Use Process IV decision include a threshold determination pursuant to State Environmental Policy Act (SEPA) Rules WAC 197-11 (File #17- 105490-SE), Transportation Concurrency (File #17-105491-CN), Boundary Line Adjustment (File #18- 100123-SU), and Forest Practices Class IV General Permit. Environmental Documents: Environmental Checklist, Wetland Report and Conceptual Mitigation Plan, Visual Impact Exhibit, Geotechnical Report, Transportation Impact Analysis, Pavement Analysis, Parking Study, Stormwater Technical Information Report, Air Quality Report, Environmental Noise Report, Cultural Resources Study, Evaluation of Trees. Development Regulations to Be Used for Project Mitigation: Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement and applicable 1994 development codes, including Federal Way City Code (FWCC) Chapter 18, "Environmental Protection"; Chapter 20, "Subdivisions"; Chapter 21, "Surface and Stormwater Management"; and Chapter 22, "Zoning." Consistency with Applicable City Plans and Regulations: The project will be reviewed for consistency with all applicable codes and regulations including the Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement, which vests the project to regulations in place in 1994; FWRC 19.145; 2016 King County Surface Water Design Manual as amended by the City of Federal Way; and the Public Works Department Development Standards. Any procedural requirements must meet today's codes (FWRC Title 19). Public Comment & Appeals: The official project file is available for public review at the Community Development Department (City Hall, 2nd Floor, 33325 8°h Avenue South, Federal Way, WA 98003). Any person may submit written comments to City staff or the Hearing Examiner and may appear at the public hearing of the Hearing Examiner to give comments orally. Any person may submit written comments to the Hearing Examiner by delivering these comments to the Department of Community Development prior to the public hearing date (which has yet to be determined) or by giving these directly to the Hearing Examiner at the public hearing. Only the applicant, persons who submit written or oral comments to the Hearing Examiner, or persons who specifically request a copy of the written decision may appeal the Hearing Examiner's decision. Details of the appeal procedures for the requested land use decision will be included with the written decision. Comments sent by email should be directed to -planning r,�ityoffederalway.cotn. Availability of File and Environmental Documents: The official project file and referenced environmental documents are available for public review during normal business hours at the Community Development Department (address above) or on the City's FTP site at ftp://ftp.cityoffederalway. com/Outbox/Greenline%20Submittal%20DocumentsBusiness%20Park/ Staff Contact: Planner Jim Harris, 253-835-2652, jim.harris@cityoffederalway.com Printed in the Federal Way Mirror July 13, 2018. .-1 Q ' • 'US Army Corps WASHINGTON STATE ❑Engimersv SD 1111p O[5[AG+ Joint Aquatic Resources Permit Application (JARPA) Form1,2 h[ M USE BLACK OR BLUE INK TO ENTER ANSWERS IN THE WHITE SPACES BELOW. RESUBMITTED APR 3 0 20% ect Identification crnOFFEDERAL `I/AY Part 1—Proj ect COMMUNITY pEVELflpMENT 1. Project Name (A name for your project that you create Greenline Business Park Y-----------------"-------------------- 1 AGENCY USE ONLY r Date received: r 1 � 1 � 1 � Agency reference #: 1 + Tax Parcel #(s): , r � r `------_-------------------------------: Examples: Smith's Dock or Seabrook Lane Development) hel Part 2—Applicant The person and/or organization responsible for the project. h( eM 2a. Name (Last, First, Middle) Messmer, Tom 2b. Organization (if applicable) Federal Way Campus, LLC 2c. Mailing Address (Street or Po Box) 11100 Santa Monica Boulevard, Suite 850 2d. City, State, Zip Los Angeles, California 90025 2e. Phone (1) 1 2f. Phone (2) 2g. Fax (310) 261-4382 2h. E-mail tmessmer@industrialrealtygroup.com lAdditional forms may be required for the following permits: • If your project may qualify for Department of the Army authorization through a Regional General Permit (RGP), contact the U.S. Army Corps of Engineers for application information (206) 764-3495. • If your project might affect species listed under the Endangered Species Act, you will need to fill out a Specific Project Information Form (SPIF) or prepare a Biological Evaluation. Forms can be found at htt :11www.nws.usace.arm . m i IN is sions/Givi Works/ Reg uIata /PermitGuideboaWEndan ered5 Pecies.as x. • Not all cities and counties accept the JARPA for their local Shoreline permits. If you need a Shoreline permit, contact the appropriate city or county government to make sure they accept the JARPA. 2To access an online JARPA form with [help] screens, go to http://www.epermitting.wa.gov/site/alias resourcecenterf'a a jar a form/9984/'ar a form.as x. For other help, contact the Governor's Office for Regulatory Innovation and Assistance at (800) 917-0043 or heingoda.wa.gov. ORIA-16-011 Page 1 of 14 Part 3—Authorized Agent or Contact Person authorized to represent the applicant about the project. (Note: Authorized agent(s) must sign 11 b of this application.) hel 3a. Name (Last, First, Middle) Shiels, William, E 3b. Organization (If applicable) Talasaea Consultants, Inc. 3c. Mailing Address (street or PO Box) 15020 Bear Creek Road NE 3d. City, State, Zip Woodinville, Washington 98077 3e. Phone (1) X Phone (2) 3g. Fax (425) 861-7550 3h. E I _ bshie Part 4—Property Owner(s) Contact information for people or organizations owning the property(ies) where the project will occur. Consider both upland and aquatic ownership because the upland owners may not own the adjacent aquatic land. hel ER Same as applicant. (Skip to Part 5.) ❑ Repair or maintenance activities on existing rights -of -way or easements. (Skip to Part 5.) ❑ There are multiple upland property owners. Complete the section below and fill out JARPA Attachment A for each additional property owner. ❑ Your project is on Department of Natural Resources (DNR)-managed aquatic lands. If you don't know, contact the DNR at (360) 902-1100 to determine aquatic land ownership. If yes, complete JARPA Attachment E to apply for the Aquatic Use Authorization. 4a. Name (Last, First, Middle) 4b. Organization (if applicable) 4c. Mailing Address (Street or PO Box) 4d. City, State, Zip 4e. Phone (1) 0. Phone (2) 4g. Fax 4h. E-mail ORIA-16-011 Page 2 of 14 Part 5—Project Location(s) Identifying information about the property or properties where the project will occur. heI ❑ There are multiple project locations (e.g. linear projects). Complete the section below and use JARPA Attachment B for each additional project location. 5a. Indicate the type of ownership of the property. (Check all that apply.) h[ eel ® Private ❑ Federal ❑ Publicly owned (state, county, city, special districts like schools, ports, etc.) ❑ Tribal ❑ Department of Natural Resources (DNR) — managed aquatic lands (Complete JARPA Attachment E) 5b. Street Address (Cannot be a PO Box. If there is no address, provide other location information in 5p.) hel 32901 Weyerhaeuser Way South 5c. City, State, Zip (If the project is not in a city or town, provide the name of the nearest city or town.) Federal Way, Washington 98001 5d. County he[ II King County 5e. Provide the section, township, and range for the project location. hf p-M 1/4 Section Section Township 16 & 21 21 N 5f. Provide the latitude and longitude of the project location. hel • Example: 47.03922 N lat. /-122.89142 W long. (Use decimal degrees - NAD 83) 47.306768 N lat./-122.296774 W long. (NAD 83) 5g. List the tax parcel number(s) for the project location. hel • The local county assessor's office can provide this information. 1621049056, 1521049178, 1621049013, 1621049030, 2285000010, and 7978200420 5h. Contact information for all adjoining property owners. (If you need more space, use DARPA Attachment C.) hel Name Mailing Address East Campus Corporate Park 1 32275 32"d Ave S, Federal Way, 98003 Genesis KC Development, LLC Highmark Investments, LLC Berube Art 3600 S 320th St, Federal Way, 98001 Tax Parcel # (if known) 215465-0170, 215465- 0080, 215465-0160, 215465-0180 215465-0110, 215465-0120 152104-9052 152104-9037 ORIA-16-011 Page 3 of 14 51. List all wetlands on or adjacent to the project location. net There are 57 wetlands on the project parcels. Please see Critical Areas Report and Conceptual Mitigation Plar for a complete list (Appendix B). 5j. List all waterbodies (other than wetlands) on or adjacent to the project location. h[ M Stream AC 5k. Is any part of the project area within a 100-year floodplain? hel ❑ Yes ® No ❑ Don't know 51. Briefly describe the vegetation and habitat conditions on the property. hei The majority of the project site is mixed conifer and deciduous forest with a series of gravel roads and paths traversing the site. The Weyerhaeuser Tech Center is located in the center of the project site. Associated parking occurs to the north and south of the Tech Center. Fifty-seven (57) wetlands, one stream, and North Lake occur on or adjacent to the Site. The on -site stream is fed by the stormwater pond and flows south into Weyerhaeuser Pond. Also see attached Critical Areas Report and Conceptual Mitigation Plan. 5m. Describe how the property is currently used. hf eM The site is developed with parking and road infrastructure which supports the Weyerhaeuser Tech Center. There is also a series of passive recreation trails throughout the undeveloped forest, and there is a sand volleyball court in the northwest corner of the site. One stormwater pond is located in the southern portion of the site, which receives water from approximately 2/3 of the site. A vacant single-family residence is located along the east side of Weyerhaeuser Way South. 5n. Describe how the adjacent properties are currently used. help The site is abutted on three sides by roads: Interstate 5 to the west, Weyerhaeuser Way S to the east, and South 336th Street to the south. Properties to the north are developed with an office park and stormwater facilities. Parcels to the east are undeveloped. 5o. Describe the structures (above and below ground) on the property, including their purpose(s) and current condition. h[ elp] The site is developed with the Weyerhaeuser Tech Center, parking lots associated with the existing building, and both gravel and paved roads to access the site. The single-family residence located at 32820 32"d Ave S in the eastern parcel was constructed in 1970 and is used as a meeting space. 5p. Provide driving directions from the closest highway to the project location, and attach a map. nei From downtown Seattle, take 1-5 south to South 320th Street toward Federal Way, turn left onto South 320' Street, follow about'/2 mile, then turn right onto Weyerhaeuser Way South. Destination is on the right — it is possible to turn right into the Tech Center for access as the site surrounds the Tech Center. See attached Vicinity Map & Driving Directions (Figure 1 of Critical Areas Report and Conceptual Mitigation Plan). ORIA-16-011 Page 4 of 14 Part 6—Project Description 6a. Briefly summarize the overall project. You can provide more detail in 6b. hei The Applicant proposes to construct approximately 1,068,000 square feet of new warehouse and office space divided amongst three new buildings. The Weyerhaeuser Tech Center will remain, but the existing parking lots will be reconfigured to a more compact arrangement around the Tech Center to maximize space. Associated infrastructure to be constructed includes five new stormwater detention/treatment facilities, including reconfiguration of the existing stormwater pond, parking for both cars and trucks, and enough maneuvering space for the truck traffic anticipated around these buildings. 6b. Describe the purpose of the project and why you want or need to perform it. hey The purpose of the project is to provide warehouse distribution centers and in response to market demands of the region within an area zoned CP-1 (Commercial Business Park). 6c. Indicate the project category. (Check all that apply)[held ® Commercial ❑ Residential ❑ Institutional ❑ Transportation ❑ Recreational ❑ Maintenance ❑ Environmental Enhancement 6d. Indicate the major elements of your project. (Check all that apply) [help] ❑ Aquaculture ❑ Bank Stabilization ❑ Boat House ❑ Boat Launch ❑ Boat Lift ❑ Bridge ❑ Bulkhead ❑ Buoy ❑ Channel Modification ® Other: Wetland fill ❑ Culvert ❑ Dam / Weir ❑ Dike / Levee / Jetty ❑ Ditch ❑ Dock / Pier ❑ Dredging ❑ Fence ❑ Ferry Terminal ❑ Fishway ❑ Float ❑ Floating Home ❑ Geotechnical Survey ® Land Clearing ❑ Marina / Moorage ❑ Mining ❑ Outfall Structure ❑ Piling/Dolphin ❑ Raft ❑ Retaining Wall (upland) ❑ Road ❑ Scientific Measurement Device ❑ Stairs ® Stormwater facility ❑ Swimming Pool ❑ Utility Line ORIA-16-011 Page 5 of 14 6e. Describe how you plan to construct each project element checked in 6d. Include specific construction methods and equipment to be used. LLeid • Identify where each element will occur in relation to the nearest waterbody. • Indicate which activities are within the 100-year floodplain. The majority of the site would be cleared of vegetation using heavy construction machinery with appropriate erosion and sediment control measures utilized. Appropriate construction methods and equipment will be used for each element of the project. Five stormwater facilities will be constructed using appropriate construction methods through a designated construction contractor. Erosion control measures will be used. No work in floodplains is proposed; only wetland fill is proposed. See Critical Areas Report and Conceptual Mitigation Plan for additional details and graphics. 6f. What are the anticipated start and end dates for project construction? (MonthNear) hel • If the project will be constructed in phases or stages, use JARPA Attachment D to list the start and end dates of each phase or stage. Start Date: 2018 End Date: 2021 ❑ See JARPA Attachment D 6g. Fair market value of the project, including materials, labor, machine rentals, etc. hel $100,000,000.00 (very rough value) 6h. Will any portion of the project receive federal funding? hel • If yes, list each agency providing funds. ❑ Yes ® No ❑ Don't know Part 7—Wetlands: Impacts and Mitigation ® Check here if there are wetlands or wetland buffers on or adjacent to the project area. (If there are none, skip to Part 8.) hf eM 7a. Describe how the project has been designed to avoid and minimize adverse impacts to wetlands ❑ Not applicable hel Various site configurations were evaluated to find the footprint with the fewest adverse impacts to wetlands. Unfortunately, development of several large warehouse buildings precludes many avoidance options. 7b. Will the project impact wetlands? hel ® Yes ❑ No ❑ Don't know 7c. Will the project impact wetland buffers? hf eio ® Yes ❑ No ❑ Don't know ORIA-16-011 Page 6 of 14 7d. Has a wetland delineation report been prepared? hel • If Yes, submit the report, including data sheets, with the JARPA package ® Yes ❑ No 7e. Have the wetlands been rated using the Western Washington or Eastern Washington Wetland Rating System? Lel If Yes, submit the wetland rating forms and figures with the JARPA package. ® Yes ❑ No ❑ Don't know 7f. Have you prepared a mitigation plan to compensate for any adverse impacts to wetlands? Lel • If Yes, submit the plan with the JARPA package and answer 7g. If No, or Not applicable, explain below why a mitigation plan should not be required. ® Yes ❑ No ❑ Don't know 7g. Summarize what the mitigation plan is meant to accomplish, and describe how a watershed approach was used to design the plan. Lel Wetland impacts will be mitigated through a multi -part mitigation plan that includes elements of wetland creation, wetland enhancement, wetland and stream buffer restoration and enhancement, and stream buffer replacement. Temporary construction impacts resulting from site grading will be restored post -construction. Wetland creation is currently proposed at an approximately 2:1 ratio — accounting for some of the wetlands only requiring a 1.5:1 ratio for compensation. Selecting a mitigation site using a watershed approach is a step -wise process of determining both the suitability and sustainability of a potential mitigation site within the landscape. The process aims to guide potential mitigation to those areas within the landscape where success is most likely to occur. The process is outlined in "Selecting Wetland Mitigation Sites Using a Watershed Approach" (Hruby, et al., 2009). A watershed plan does not exist for this area. This mitigation site was chosen based on its availability (under same ownership) as well as its connectivity to other critical areas, consistent with the watershed approach. 7h. Use the table below to list the type and rating of each wetland impacted, the extent and duration of the impact, and the type and amount of mitigation proposed. Or if you are submitting a mitigation plan with a similar table, you can state (below) where we can find this information in the plan. Lei Activity (fill, Wetland Wetland Impact Duration Proposed Wetland drain, excavate, Name' type and area (sq. of impact3 mitigation mitigation area flood, etc.) rating ft. or type (sq. ft. or category2 Acres) acres) See table in PFO/SS, Fill Comment III/IV 13,428 sf Permanent Creation 36,023 sf Letter If no official name for the wetland exists, create a unique name (such as "Wetland n. The name should be consistent with other project documents, such as a wetland delineation report. 2 Ecology wetland category based on current Western Washington or Eastern Washington Wetland Rating System. Provide the wetland rating forms with the JARPA package. s Indicate the days, months or years the wetland will be measurably impacted by the activit . Enter"permanent' if applicable. ORIA-16-011 Page 7 of 14 Creation (C), Preservation Page number(s) for similar information in the mitigation plan, if available: 71. For all filling activities identified in 7h, describe the source and nature of the fill material, the amount in cubic yards that will be used, and how and where it will be placed into the wetland. h[ ell Clean structural fill to be used for filling wetlands will be pulled from a City -approved location. Final details on the exact volume of fill required has not been completed at this time. All or part of 16 wetlands are proposed to be filled, and subsequently compensated for through the provided mitigation plan submitted as part of this PCN. 7j. For all excavating activities identified in 7h, describe the excavation method, type and amount of material in cubic yards you will remove, and where the material will be disposed. n No excavating is proposed. Part 8—Waterbodies (other than wetlands): Impacts and Mitigation In Part 8, "waterbodies" refers to non -wetland waterbodies. (See Part 7 for information related to wetlands.) hel ® Check here if there are waterbodies on or adjacent to the project area. (If there are none, skip to Part 9.) 8a. Describe how the project is designed to avoid and minimize adverse impacts to the aquatic environment. hel ❑ Not applicable The project was designed to avoid all impacts to Stream AC and North Lake. Only minor modifications may be necessary to upgrade an existing outfall structure at the origin of Stream AC by the existing stormwater pond. This minor modification would not impact Stream AC. 8b. Will your project impact a waterbody or the area around a waterbody? k ❑ Yes ® No ORIA-16-011 Page 8 of 14 8c. Have you prepared a mitigation plan to compensate for the project's adverse impacts to non -wetland waterbodies? hf eM • If Yes, submit the plan with the JARPA package and answer 8d. If No, or Not applicable, explain below why a mitigation plan should not be required. ❑ Yes ® No ❑ Don't know There are no impacts to non -wetland waterbodies, but a report has been prepared. Minor modifications may be necessary to upgrade an existing outfall structure, but no impacts to Stream AC are expected. 8d. Summarize what the mitigation plan is meant to accomplish. Describe how a watershed approach was used to design the plan. ■ If you already completed 7g you do not need to restate your answer here. hem No mitigation plan is prepared to address non -wetland waterbodies, as the only impacts are to wetlands. 8e. Summarize impact(s) to each waterbody in the table below. h[ el Activity (clear, Waterbody Impact Duration Amount of material Area (sq. ft. or dredge, fill, pile name' location' of impact3 (cubic yards) to be linear ft.) of drive, etc.) placed in or removed waterbody from waterbody directly affected i exists, create a unique name (such as "Stream 1 ") The name should be consistent with other documents I Indicate the days, months or -years the waterbody will be measurably impacted by the work. Enter "permanent" if a olicable. 8f. For all activities identified in 8e, describe the source and nature of the fill material, amount (in cubic yards) you will use, and how and where it will be placed into the waterbody. [hel Not applicable. ORIA-16-011 Page 9 of 14 89. For all excavating or dredging activities identified in 8e, describe the method for excavating or dredging, type and amount of material you will remove, and where the material will be disposed. heI Not applicable. Part 9—Additional Information Any additional information you can provide helps the reviewer(s) understand your project. Complete as much of this section as you can. It is ok if you cannot answer a question. 9a. Agency Name 1 Contact Name hf elpl Phone Most Recent 9b. Department of Ecology's 3O3(d) List? hj eU • If Yes, list the parameter(s) below. • If you don't know, use Washington Department of Ecology's Water Quality Assessmen h ttp://www.ecy.wa.uov/l)rogramWn/303d/. 9c. • Go to http://cfpub.et)a.gov/surf/locate/iiidex.cfm to help identify the HUC. 9d. • Go to htto://www.ecy.wa.govlwaterlwria/index.html to find the WRIA #. Date of Contact _ 1 ORIA-16-011 Page 10 of 14 9 W he in -water construction work comply with the State of Washington water quality standards for turbidity? Lelpi • Go to http:Ilwww.ecv.wa.clov/pMrams/wo/swos/criteria.html for the standards. ❑ Yes ❑ No ® Not applicable 9f. If the project is within the jurisdiction of the Shoreline Management Act, what is the local shoreline environment designation? hel • If you don't know, contact the local planning department. For more information, go to: http:llwww.ecy.wa.00vinrogramslsealsmallaws rules/1 73-261211 designations.html. ® Urban ❑ Natural ❑ Aquatic M Conservancy ❑ Other: 9g. What is the Washington Department of Natural Resources Water Type? h[ eel ] C Go to http-Jlwww.dnr.wa-gov/forest-practices-water-tvping for the Forest Practices Water Typing System. ® Shoreline ® Fish ❑ Non -Fish Perennial ❑ Non -Fish Seasonal 9h. Will this project be designed to meet the Washington Department of Ecology's most current stormwater manual? hel • If No, provide the name of the manual your project is designed to meet. ❑ Yes ® No Name of manual: King County Surface Stormwater Design Manual 2016 l 91. Does the project site have known contaminated sediment? hel ■ If Yes, please describe below. ❑ Yes ® No 9j. If you know what the property was used for in the past, describe below. hf elpl The subject property has been owned and managed by Weyerhaeuser since the 1970s until a recent acquisition by Federal Way Campus, LLC. The site has been used for passive recreation and the Weyerhaeuser Tech Center. 9k. Has a cultural resource (archaeological) survey been performed on the project area? hel • If Yes, attach it to your JARPA package. ® Yes ❑ No ORIA-16-011 Page 11 of 14 91. Name each species listed under the federal Endangered Species Act that occurs in the vicinity of the project area or might be affected by the proposed work. nei No listed species are noted as occurring on the site. Bald eagles are likely to use North Lake for foraging, and salmonids may occur within North Lake and surrounding waters. Man-made obstructions appear to restrict movement of salmonids upstream from Hylebos Creek, which has known populations of salmonids. Stream AC on -site, North Lake, and nearby off -site streams have the potential for salmonids. Stormwater discharges from the site have the potential to affect salmonids downstream, though extensive on -site treatment will minimize the potential, thus justifying a "may affect but likely to adversely effect" determination for listed species. 9m. Name each species or habitat on the Washington Department of Fish and Wildlife's Priority Habitats and Species List that might be affected by the proposed work. hf eM See comments above on Federally -listed species. ORIA-16-011 Page 12 of 14 Part 10—SEPA Compliance and Permits Use the resources and checklist below to identify the permits you are applying for. • Online Project Questionnaire at http:l/apps.oria.wa.govlopas/. • Governor's Office for Regulatory Innovation and Assistance at (800) 917-0043 or.help@_oria.wa.gov. • For a list of addresses to send your JARPA to, click on agency addresses for completed JARPA. Oa. Compliance with the State Environmental Policy Act (SEPA). (Check all that apply.) h[ eld • For more information about SEPA, go to www.ecy.wa.goviprograms/sea/seoa/e-review.htmi. lJ Local Government Shoreline permits: ❑ ❑ Other City/County permits: El Check the box below in 10b. hel (Check all that apply.) hel LOCAL GOVERNMENT El a1f►i r WUVCMrvmCrvi Washington Department of Fish and Wildlife: ® ❑ Washington Department of Natural Resources: Complete JARPA Attachment F and submit a check for $25 payable to the Washington Department of Natural Resources. Do not send cash. Washington Department of Ecology: FEDERAL GOVERNMENT United States Department of the Army permits (U.S. Army Corps of Engineers): ® discharges into waters of the U.S. ❑ work in navigable waters United States Coast Guard permits: ❑ 1-1 for non -bridge projects ORIA-16-011 Page 13 of 14 Part 11—Authorizing Signatures Signatures are required before submitting the JARPA package. The JARPA package in the JARPA form, project plans, photos, etc. hf elnl 11a. Applicant Signature (required) i,[ 9m I certify that to the best of my knowledge and belief, the information provided in this application is true, complete, and accurate. I also certify that I have the authority to carry out the proposed activities, and I agree to start work only after I have received all necessary permits. I hereby auth a the agent named in Part 3 of this application to act on my behalf in matters related to this application. (initial) By initialing here, I state that I have the authority to grant access to the property. I also give my consent to the permitting agencies entering the property where the project is located to inspect the project site or any work related to the project. (initial) Applicant Printed Name Applicant Signature Date 11 b. Authorized Agent Signature [help] I certify that to the best of my knowledge and belief, the information provided in this application is true, complete, and accurate. I also certify that 1 have the authorit• o- _ .6ut a proposed activities and I agree to start work only after all necessary permits have been i Z rT Au rized Agent Printed Name Authorized Ag i nat Date 11 c. Property Owner Signature (if not applicant). hel Not required if project is on existing rights -of -way or easements. I consent to the permitting agencies entering the property where the project is located to inspect the project site or any work. These inspections shall occur at reasonable times and, if practical, with prior notice to the landowner. Property Owner Printed Name Property Owner Signature Data 18 U.S.0 §1001 provides that: Whoever, in any manner within the jurisdiction of any department or agency of the United States knowingly falsifies, conceals, or covers up by any trick, scheme, or device a material fact or makes any false, fictitious, or fraudulent statements or representations or makes or uses any false writing or document knowing same to contain any false, fictitious, or fraudulent statement or entry, shall be fined not more than $10,000 or imprisoned not more than 5 years or both. If you require this document in another format, contact The Governor's Office of Regulatory Assistance (ORA). People with hearing loss can call 711 for Washington Relay Service. People with a speech disability can call (877) 833-6341. ORA publication number: ENV-019-09 JARPA 2010 v1 3/3012010 Page 13 of 13 Greenline Business Park Public Notice Mailing List (300' Buffer from Project Boundary) Parcel number Taxpayer name Owner Address City State Zip code 1521049022 BARCELO HOMES LLC PO BOX 1733 AUBURN WA 98071 1521049026 KREMER LYLE 32629 39TH AVE S AUBURN WA 98001 1521049030 GASSER LIANE 32723 39TH AVE S AUBURN WA 98001 1521049037 GILLESPIE DANIEL R 15738 MIDVALE AVE N SHORELINE WA 98133 1521049052 HIGHMARK INVESTMENTS LLC 1214140TH AVE CT E SUMNER WA 98390 1521049123 HONEY WENDY+BRIAN 3800 S 328TH ST FEDERAL WAY WA 98001 1521049141 GASSER LIANE E 32719 39TH AVE S AUBURN WA 98002 1521049142 SUNDSTROM 0ENNIS A 3809 S 325TH PL AUBURN WA 98001 1521049145 SUNDSTROM DEN N15 A+WENDY R 3810 S 325TH PL AUBURN WA 98002 1521049153 MAYOR ROMEO A -TTEE 29824 2ND AVE SW FEDERAL WAY WA 98023 1521049167 VANDENBERG MELVIN W 1621 AMHERST DR AMES IA 50014 1521049178 - IRGRA 4020 KINROSS LAKES PKWY RICHFIELD OH 44286 1521049201 WA DEPT OF FISH&WILDLIFE 600 CAPITOL WY N OLYMPIA WA 98501 1621049013 IRGRA 4020 KINROSS LAKES PKWY RICHFIELD OH 44286 1621049030 IRGRA 4021 KINROSS LAKES PKWY RICHFIELD OH 44287 1621049036 IRGRA 4022 KINROSS LAKES PKWY RICHFIELD OH 44288 1621049056 IRGRA 4023 KINROSS LAKES PKWY RICHFIELD OH 44289 2154650080 LEASE 06998.100-RENT DEPT PO BOX 1476 TACOMA WA 98401 2154650100 WESTERN WA CON OF S€]A 32229 WEYERHAEUSER W FEDERAL WAY WA 98001 2154650110 GENESIS KC DEVELOPMENT LLC 200016TH ST DENVER CO 80202 2154650120 GENESIS KC DEVELOPMENT LLC 2001 16TH ST DENVER CO 80202 2154650140 EAST CAMPUS CORPORATE PARK 1201 PACIFIC AVE STE 1400 TACOMA WA 98402 2154650160 EAST CAMPUS CORPORATE PARK 1202 PACIFIC AVE STE 1400 TACOMA WA 98402 2154650170 EAST CAMPUS CORPORATE PARK 1203 PACIFIC AVE STE 1400 TACOMA WA 98402 2154650180 EAST CAMPUS CORPORATE PARK 1204 PACIFIC AVE STE 1400 TACOMA WA 98402 2285000010 FEDERAL WAY CAMPUS LLC 11100 SANTA MONICA BLVD #850 LOS ANGELES CA 90025 7978200480 FEDERAL WAY CAMPUS LLC 11101 SANTA MONICA BLVD #850 LOS ANGELES CA 90025 7978200515 IRGRA 4020 KINROSS LAKES PKWY RICHFIELD OH 44286 7978200520 IRGRA 4021 KINROSS LAKES PKWY RICHFIELD OH 44287 RECEIVED MAY 15 2018 CITY OF FEDERAL WAY COMMUNITY DEVELOPMENT 05-15-2018 TING E RESUSM11-T D April 30, 2018 Job No. 1886-001-016-0016 C--,f QEVE DPM �OMMuN Mr. Jim Harris, Senior Planner City of Federal Way Community Development Department 33325 8th Avenue South Federal Way, WA 98003 RE: File Nos.17-105489-00-UP & 17-105490-00-SE; NOTICE OF INCOMPLETE APPLICATION Greenline Business Park, 32901 Weyerhaeuser Way S, Federal Way Dear Jim: On behalf of Federal Way Campus, LLC, ESM Consulting Engineers, LLC is providing this letter in response to the Notice of Incomplete Application for Greenline Business Park, dated December 12, 2017. For ease of review, we have followed the same format and numbering in your letter and have included our responses in Bold. INCOMPLETE APPLICATION During the course of the City's review, the following items were found to be missing or incomplete. In order for your application to be considered complete and ready for processing, the items below must be provided. • Transportation Impact Analysis (TIA) Four copies of a Transportation Impact Analysis (TIA) prepared by TENW has been included with this resubmittal. Analysis also includes Saturday PM Peak hour trips as requested by the City of Federal Way Traffic Division. • Noise Analysis Four copies of a Noise Analysis prepared by Ramboll has been included with this resubmittal. • Air Quality Analysis Four copies of an Air Quality Analysis prepared by Ramboll has been included with this resubmittal. • Visual Impact Analysis II 0 ESM Federal Way ESM Everett Civil Engineering Land Planning 33400 8th Ave S, Ste 205 1010 SE Everett Mall Way, Ste 210 Land Surveying Landscape Architecture Federal Way, WA 98003 Everett, WA 98208 253.838.6113tel 425.297.9900tel 3D Laser Scanning GIS 800.345.5694 toll free 800.345.5694 toll free www.esmcivil.com 253.838.7304 fax 425.297.9901 fax Mr. Jim Harris April 30, 2018 Page 2 Four copies of a Visual Impact Analysis prepared by Craft Architects has been included with this resubmittal. Washington State Department of Archeology and Historic Preservation Analysis as follows: Provide an inventory of the project site and surrounding Weyerhaeuser campus to evaluate the property for its historical and architectural significance. The inventory shall be conducted by qualified cultural resource professionals with expertise in architectural history and archaeology and that have knowledge of using DAHP's on-line Historic Property Inventory and Archaeological Site Inventory databases. Be aware that DAHP requires that all documents related to project reviews be submitted electronically. Correspondence, reports, notices, photos, etc. must now be submitted in PDF or JPG format. For more information about how to submit documents to DAHP please visit: htlp://www.dahp.wa.gov/12ro-grams/shpo-compliance. ii. To assist in conducting a cultural resource survey and inventory effort, DAHP has developed guidelines, including requirements for survey reports, which is available on their website. A previous response was provided to the City on January 25th, 2018 requesting clarification for this requirement More so, we requested the city retract this requirement for accepting the application. In response, you provided an email (2/07/2018) which concurs that a Washington State Department of Archeology and Historic Preservation Analysis is not an application completeness item. Furthermore, your email explained that previous Greenline projects received similar comments from DAHP requesting this analysis. We have taken the liberty to have a Cultural Resource Archival Study prepared which meets the requirements of DAHP. Please feel free to forward to DAHP as part of the SEPA packet Please find the following items included with this resubmittal as part of our Process IV Land Use Review and SEPA Application: 1. This Response Letter 2. SEPA Checklist Dated 4/30/2018 (8 copies); 3. Transportation impact Analysis (4 copies); 4. Visual Impact Exhibit (4 copies); 5. JARPA (4 copies); 6. Air Quality Technical Report (4 copies); 7. Environmental Noise Report (4 copies); 8. Cultural Resources Archival Study (4 copies); 9. Compact Disk Including Above Items and Prior Documents to make a Complete Application Submittal (1 copy) RESUBMITTED MY OF Date: City: FEB 14 2018 CITY OF FSDEFiAWAYCOMMIUNrY CEv ' -0PMIE:MT MEMORANDUM Community Development Department WETLAND CONSULTANT AUTHORIZATION FORM December 12, 2017 Community Development Department 33325 8's Avenue South Federal Way, WA 98003 Consultant: Ilon Logan, ESA 5309 Shilshole Avenue NW, Suite 200 Seattle, WA 98107 iloian,-ale sa55ac.coM Project: Greenline Business Park — Critical Areas Report and Conceptual Mitigation Plan, 32901 Weyerhaeuser Way South File No.: 17-105489-UP Project Proponent: ESM Consulting Engineers 33400 8`h Avenue South, Suite 205 Federal Way, WA 98003 gric.lab:rie w Ti civiI.coin City Staff Contact: Senior Planner Jim Harris — 253.835.2652, 'ii m.lsarrisrcrcit offederalwa corn Project Background: Applicant has proposed three new warehouse buildings totaling approximately 1.1 million square feet, plus utilities, parking, parking area revisions, five storm drainage ponds, etc. The property is located north of South 3361" Street, between Interstate-5 and Weyerhaeuser Way. ESA has previously reviewed and approved the critical area classifications and delineations for these properties. Documents Provided: o Critical Areas Report and Conceptual Mitigation Plan — Greenline Business Park, by Talasaea, October 27, 2017 (item 015 in ftp folder) Preliminary Engineering Plan Set, by ESM (item 009 in ftp folder) Both documents are available on the city's ftp site: ftp: fry�Ci�aifederalwa .Corn/OUtb�7f�fdfECliline�/ax��Ul]Iilitl31°f 0Do cumentsi Task Scope: ■ Review report for compliance with current FWRC critical area regulations. ■ Review proposed mitigation for compliance with current FWRC requirements. ® Conduct site visit as necessary. Provide written response to findings, recommendations, and request additional information from applicant if needed. ■ Possible meeting with applicant's wetland biologist. ■ Two meetings with City staff. ■ Hearing Examiner public hearing meeting attendance. ® Review of resubmitted/corrected documents as needed. Task Schedule: Provide a task cost estimate ASAP. Review work is not authorized until authorized in writing by city. Task Cost: Not to exceed without a prior written amendment to this Task Authorization. Acceptance: 114 sultant) ate City tafl) Date (Applicant) Date rn 3 0 n m .7r 3.1 M F� '.CD-h tV C . _ 1F 1511 �ocmi� any �m� �w �34 x S o ors" �U'~IT aF � ate[ C if Rnt, CZII F f CD x LSD [��TI DG�I m 1s c Z f[' II II it * II Z d 11 i i A Q C3. D m r �-+ x >E v+ x I a y 'x, 1-0 Z iF I PY CO 3!� o Cr . F 2:3 -¢ � it - i ['�fl W � It 'A- CAD a[• co CO 9E 8 9F O C-) a i P i4 o Dore oCD 41, xolo o ' CO 0 RESUBMITTED f~ JAN 2 5 2018 CiTY OF FEDERAL WAY C*MMUNITY DEVELOPMENT CONSULTING ENGINEERS. LLC January 25, 2018 Mr. Jim Harris Senior Planner City of Federal Way Community Development Department 33325 8th Avenue South Federal Way, WA 98003 Job No.1886-001-016-0016 RE: File Nos. 17-105489-00-UP & 17-105490-00SE; NOTICE OF INCOMPLETE APPLICATION Greenline Business Park, 32901 Weyerhaeuser Way S, Federal Way Dear Jim: On behalf of Federal Way Campus, LLC, ESM Consulting Engineers, LLC is providing this letter in response to the Notice of Incomplete Application for Greenline Business Park, dated December 12, 2017. For ease of review, we have followed the same format and numbering in your letter and have included our responses in Bold. INCOMPLETE APPLICATION During the course of the City's review, the following items were found to be missing or incomplete. In order for your application to be considered complete and ready for processing, the items below must be provided. Transportation Impact Analysis (TIA) A Transportation Impact Analysis (TIA) is currently being prepared as a result of coordination between the City of Federal Way Traffic Division and Transportation Engineers Northwest A final scope was agreed upon by the City on January 7, 2018 via email from Sarady Long. Noise Analysis A Noise Analysis cannot be provided until a majority of the TIA has been completed. Some of the items required by the Noise Analysis are dependent on information provided by the TIA ESM Federal Way ESM Everett Civil Engineering Land Planning 33400 8th Ave S, Ste 205 1010 SE Everett Mall Way, Ste 210 Land Surveying Landscape Architecture Federal Way, WA 98003 Everett, WA 98208 253.838.6113tel 425.297.9900tel 3D Laser Scanning GIS 800.345.5694toll free 800.345.5694 toll free www.esmcivil.com 253.838.7104 fax 425.297.9901 fax Mr. Jim Harris January 25, 2018 Page 2 Air Quality Analysis As with the Noise Analysis, an Air Quality Analysis cannot be provided until a majority of the TIA has been completed. Some of the items required by the Air Quality Analysis are dependent on information provided by the TIA. Visual Impact Analysis A Visual Impact Analysis is currently being prepared for the Greenline Business Park project Washington State Department of Archeology and Historic Preservation Analysis as follows: Provide an inventory of the project site and surrounding Weyerhaeuser campus to evaluate the property for its historical and architectural significance. The inventory shall be conducted by qualified cultural resource professionals with expertise in architectural history and archaeology and that have knowledge of using DAHP's on-line Historic Property Inventory and Archaeological Site Inventory databases. Be aware that DAHP requires that all documents related to project reviews be submitted electronically. Correspondence, reports, notices, photos, etc. must now be submitted in PDF or JPG format. For more information about how to submit documents to DAHP please visit: http:llwww,dahp.wa.gov/programs/shoo-compliance. ii. To assist in conducting a cultural resource survey and inventory effort, DAHP has developed guidelines, including requirements for survey reports, which is available on their website. We are unclear how this analysis is required in order to deem the application complete for processing. It is not listed on the City's checklist for Submittal Process for Use Process IV (Bulletin No. 001), and it is not listed under FWRC 19.15.040 as a submittal item. It has come to our attention through review of publicly available documents, that adjacent properties currently being developed under similar land uses processes have recently been deemed complete for processing without providing similar reports on visual, noise or air impacts and were not required to conduct an archeology and historic preservation analysis either. Please help us understand why the City is not applying the same application requirements for similar development applications on adjacent properties. Mr. Jim Harris January 25, 2018 Page 3 We respectfully request that the City retract this requirement for accepting the application. If the request is presented to the applicant as a review comment, we suggest that you also provide the following: 1. Reference to the City ordinance and/or code citation which justifies the request 2. Clarify the boundaries of what is considered to be the "surrounding Weyerhaeuser Campus" 3. A list of other projects in the vicinity of the Greenline Business Park that have been subject to this requirement If you have any questions, please feel free to contact me at 253-838-6113, and I look forward to your response. Sincerely, ESM CONSU TING ENGINEERS, LLC MATT REIDER Assistant Planner Ilesm8lengrlesm-jobs1188610011016-00161docu mentl letter-004.docx March 16, 2018 Tom Messmer Vice President — Special Projects Federal Way Campus, LLC 8847 Imperial Highway, Suite H Downy CA, 90242 LIA� we ✓�Ipdfr� awe ✓z' Pa✓f A no� RESUBM177ED APR 3 0 2018 PrTyNEOpCOM1 Y FEDERAL Subject: Cultural Resources Archival Study, Greenline Business Park Project, Federal Way, Washington CONFIDENTIAL Dear Mr. Messmer: Gavdno' Shaping the Future Cardno 801 Second Avenue Suite 700 Seattle, WA 98104 USA Phone 206 269 0104 Toll -free 800 368 7511 Fax 206 269 0098 www.cardno.com This letter report describes the results of the archival study conducted by Cardno, Inc. (Cardno) for the Greenline Business Park Project (project), located within the former Weyerhaeuser Company (Weyerhaeuser) campus at 32901 32nd Drive South in Federal Way, Washington. The 77-acre project area includes portions of parcels 152104-9178, 162104-9030, 228500-0010, as well as the entirety of parcels 162104-9013 and 162104-9056, which have recently been purchased by the Industrial Realty Group, LLC (IRG) from Weyerhaeuser (King County Tax Assessor's Office 2018). The project straddles the western half of Section 15 and the eastern half of Section 16 of Township 21 North, Range 4 East of the Willamette Base Meridian (Figures 1 through 3). The proposed Greenline Busi[iess Park project includes the construction of three buildings of varying sizes totaling approximately 1,068,000 square feet (ft) surrounding the former Weyerhaeuser Technology Center (WTC), now referred to as the Greenline Technology Center (ESM Consulting Engineers, LLC 2017). Additional site improvements include reconfiguration and expansion of the existing parking lot at the Greenline Technology Center, construction of five stormwater ponds, and frontage improvements along Weyerhaeuser Way South and South 336th Street. An inventory to document the historical and architectural significance of the project area was requested by the City of Federal Way upon their review of the Federal Campus Way, LLC's application under the Washington State Environmental Policy Act (SEPA) (Revised Code of Washington [RCW] 43.21 C) and implementing rules contained in Washington Administrative Code (WAC) 197-11. As outlined in the SEPA checklist submitted to the local planning authority with applications for development, the following questions must be satisfactorily addressed to demonstrate that cultural and historic resources will not be adversely affected by the proposed development: A. Are there any buildings, structures, or sites, located on or near the site that are over 45 years old listed in or eligible for listing in national, state, or local preservation registers ? If so, specifically describe. B. Are there any landmarks, features, or other evidence of Indian or historic use or occupation? This may include human burials or old cemeteries. Are there any material evidence, artifacts, or areas of cultural importance on or near the site? Please list any professional studies conducted at the site to identify such resources. Australia • Belgium • Canada • Colombia • Ecuador • Germany • Indonesia • Italy Kenya • New Zealand • Papua New Guinea • Peru • Tanzania • United Arab Emirates United Kingdom • United States • Operations in 85 countries Classified Proof ury aW Federal Way CRY OF Federal way Centered an Opportunity NOTICE OF OEPARTMENTOF COMMUNITY DEVELOPMENT INTERPRETATION 08-01 (18-108277•UP) On September 10, 2018. McCullough Will Leary, PS requested an interpretation on behalf of Dana Os- tenson and Federal Way Campus LLC ("Applicant') to seek a determination regarding: Managed Forest tiuffar ("MFB'} depth: and MFB relocatlon. The CP•1 zoning regulations are contained VAthin Ex- hibit 10" of the Weyerhaeuser Company Concomi- tant Pre -Annexation Tuning Agreement ('CZW). Section 19.50.010 of the federal Way Revised Code ('FWRC') authorizes the Director of Commu- nity Development (" Director") to interpret the pro- visions of a concomitant agreement. Citation of Code Provision Pursuant to the Applicant's request submitted to the City on September 12, 2018, the Applieant seeks a determination that: -The Managed Forest Buffer (MFB) on the northern boundary of the CP•1 property betymen 1,5 and %leyerhaeuser Way South has a depth of zero feet; and -if the Applicant dedicates land secluding the MF8 to the City of Federal Way (City) for the fuhlrs ex- tension of S. 324M Street, then fhe MF8 remains on the land acquired by the Clay and does not relo- cate to the property retained by the Applicant. Summary Statement of Interpretation in response to the first interpretation request, the Director notes that the C711 does not identify the depth of the MFB on the perimeter of CP-1 proper- ty when abutting a 'compatible" —as opposed to an Incompatible"— use. Under this development scenario a Managed Forest Buffer depth of setback for compatible uses is determined and interpreted to be a minimum width of 25 feet_ In response to the second Interpretation request, Proofed by Boyd, Maggie, 03/07/2019 02:10:56 pm Page: 2 Classified Proof the Director notes that the CZA does not address the future extension of South 324th Street, and does not address how dedication of land for a new rightof-way would affect the location of the MFB. It Is hereby determined and Interpreted t Applicant (or a luture owner of the project site) dsdlcatrs or conveys land containing MFB to the City of Federal Way for the future extension of South•324th Street right-of-way, then the MFB remains on the land ac- qulmd ) the City and the MFB does not relocate to the CP-1 property retained by the Applicant or fu- ture owner. Date of Interpretation November 9, 2018 Availability of Official File The official project file (#18-105277-UP) is available for review at the City of Federal Way De- partment of Community Development (Federal Way City Hall, 33325 81 Avenue South, Federal Way, WA 98063-9118), 253.835.2607, or permit center@cltyoffederalway.com, from 9:00 a.m. to 4:00 p.m., Monday through Friday. The interpretation can be. read In its entirety at: ftpJthp.cltyoffederal way.coiri/Dutboxl Comm unity%200evalcpment%201 nterpretation% 202018/ Right to Appeal Any person .,,ho is aggrieved by an Interpretation Issued by the Dlrectof may appeal that interpreta. don. A written notice of appeal must be delivered to the Department of Community Development by November 27, 201S. The notice of appeal must In- dicate how the interpretation affects the appellant and present any relevant arguments or information on the correctness of the interpretation. The notice of ,appeal must be accompanied by cash 4r a chadk, payable to Gte CW of Federal Way, in the amount of the fee at established by the City. An appeal of thfs Interpretation will be reviewed and decided upon using the process for appeals outlined in FWRC 19.50.060 and Chapter 19.70 FWRC. Deadline for Filing an Appeal 5:00 p.m., November 27, 2018 City Staff Contact Senior Planner Jim Harris, 253.835-2652, or jim.harris@cltyoffederalway.com Published in the Federal Way Mirror on November 9,2018. # 833732 Proofed by Boyd, Maggie, 03/07/2019 02:10:56 pm Page: 3 Jim Harris From: Jim Harris Sent: Wednesday, February 07, 2018 2:11 PM To: matt.reider@esmcivil.com Cc: Brian Davis Subject: Greenline Business Park Application Completeness 17-105490 SE Matt: This is in response to your January 25, 2018 letter regarding the Notice of Incomplete Application for the Greenline Business Park. After review of your request, we concur that the requested Washington State Department of Archeology and Historic Preservation "inventory of the project site and surrounding Weyerhaeuser Campus to evaluate the property for its historical and architectural significance" is not an application completeness item. This item is more appropriately a technical review comment that we have previously received from DAHP in response to public notices for other Greenline proposals. Based on previous comments from DAHP on other Greenline proposals, we anticipate DAHP will provide this similar comment and technical information request for the Greenline Business Park application. Let me know if you have any further questions. Jim Harris Planner �► Fee �1Ja 33325 8th Avenue South Federal Way, WA 98003-6325 Phone:253/835-2652 Fax: 253/835-2609 www.citvoffede ralway.corn Office Hours Mon - Thur, 8:00 AM — 4:30 PM or by appointment Federal Way Mirror Affidavit of Publication State of Washington } County of King } ss Maggie Boyd being first duly sworn, upon oath deposes and says: that he/she is the legal representative of the Federal Way Mirror a weekly newspaper. The said newspaper is a legal newspaper by order of the superior court in the county in which it is published and is now and has been for more than six months prior to the date of the first publication of the Notice hereinafter referred to, published in the English language continually as a weekly newspaper in King County, Washington and is and always has been printed in whole or part in the Federal Way Mirror and is of general circulation in said County, and is a legal newspaper, in accordance with the Chapter 99 of the Laws of 1921, as amended by Chapter 213, Laws of 1941, and approved as a legal newspaper by order of the Superior Court of King County, State of Washirqpn, by order dated June 16, 1941, and that the annexed is a true copy of FWM933732 as it was published in the regular and entire issue of said paper and not as a supplement form thereof for a period of 1 issue(s), such publication commencing on 11/09/2018 and ending on 11/09/2018 and that said newspaper was regularly distributed to its subscn-bers during all of said period. The amount of the fee for such publication is $194.04. 5ubscrlbed and sworn before me on this � �t�P L■`B`+E,,q�� !! ZJJII day of atARh '0 OF 11iii411111PI Notary Public in and for the State of Washington. Cny ofrederL! wsy - racnL.ans E s,•axaic Jim Harris From: Jim Harris Sent: Wednesday, February 07, 2018 2:11 PM To: matt.reider@esmcivil.com Cc: Brian Davis Subject: Greenline Business Park Application Completeness 17-105490 SE Matt: This is in response to your January 25, 2018 letter regarding the Notice of Incomplete Application for the Greenline Business Park. After review of your request, we concur that the requested Washington State Department of Archeology and Historic Preservation "inventory of the project site and surrounding Weyerhaeuser Campus to evaluate the property for its historical and architectural significance" is not an application completeness item. This item is more appropriately a technical review comment that we have previously received from DAHP in response to public notices for other Greenline proposals. Based on previous comments from DAHP on other Greenline proposals, we anticipate DAHP will provide this similar comment and technical information request for the Greenline Business Park application. Let me know if you have any further questions. Jim Harris Planner Y co Federal Ways or 33325 8th Avenue South Federal Way, WA 98003-6325 Phone:253/835-2652 Fax: 253/835-2609 www.citvoffederalway.com Office Hours Mon - Thur, 8:00 AM — 4:30 PM or by appointment Jim Harris From: Jim Harris Sent: Tuesday, February 20, 2018 10:23 AM To: Ton Logan' Cc: Stacey Welsh Subject: RE: Greenline Attachments: 20180220100607.pdf lion: Attached is the signed and executed Task Authorization for the Greenline Business Park project review. This is your authorization to proceed with this review. I will send you a hard copy and a quick cover letter in the next day or two authorizing this review work. Let me know if you have any questions. Jim Harris Planner 4& Federal Way 33325 8th Avenue South Federal Way, WA 98003-6325 Phone:253/835-2652 Fax: 253/835-2609 www.citvoffederalwaV.com Office Hours Mon - Thur, 8:00 AM —4:30 PM or by appointment From: Ilon Logan [ma!Ito:ILogan@esassoc.com] Sent: Friday, December 29, 2017 8:14 AM To: Tamara Fix; Jim Harris Cc: Stacey Welsh; Robert Hansen Subject: RE: Greenline Hi Tamara and all, Attached is ESA's signed task authorization for this project — Greenline Business Park (City #17-105489-UP). We were delayed in getting an estimate completed due to the holidays/vacation. Happy New Year! lion Logan From: Tamara Fix [ma ilto:Tamara.Fix@citvoffederaIwa_y.com] Sent: Wednesday, December 13, 2017 9:52 AM To: lion Logan <ILogan@esasso_c.com> Subject: Greenline Attached are documents from the City of Federal Way regarding the above -mentioned project. The originals are being mailed out to you today. 1 RESUBMITTED JAN 2 5 2018 CFTY OF FEDERAL WAY COMMUNITY DEVELOPMENT January 25, 2018 Mr. Jim Harris Senior Planner City of Federal Way LL i "e 1o, ME Job No. 1886-001-016-0016 �L fly V i'cv ^41 Community Development Department d r.-S L y ti 333258 Avenue South Federal Way, WA 98003 n �!P,I RE: File Nos. 17-105489-00-UP & 17-105490-00-SE; NOTICE OF INCOMPLETE APPLICATION Greenline Business Park, 32901 Weyerhaeuser Way S, Federal Way vd Dear Jim: S�nA On behalf of Federal Way Campus, LLC, ESM Consulting Engineers, LLC is providing this /k✓:�,, letter in response to the Notice of Incomplete Application for Greenline Business Park, dated December 12, 2017. For ease of review, we have followed the same format and numbering in your letter and have included our responses in Bold. INCOMPLETE APPLICATION During the course of the City's review, the following items were found to be missing or incomplete. In order for your application to be considered complete and ready for processing, the items below must be provided. Transportation Impact Analysis (TIA) A Transportation Impact Analysis (TIA) is currently being prepared as a result of coordination between the City of Federal Way Traffic Division and Transportation Engineers Northwest A final scope was agreed upon by the City on January 7, 2018 via email from Sarady Long. • Noise Analysis A Noise Analysis cannot be provided until a majority of the TIA has been completed. Some of the items required by the Noise Analysis are dependent on information provided by the TIA. ESM Federal Way ESM Everett I Civil Engineering Land Planning 33400 8th Ave S, Ste 205 1010 SE Everett Mall Way, Ste 210 Land Surveying Landscape Architecture Federal Way, WA 98003 253.838.6113te1 Everett, WA 98208 425.297.9900tel 3D Laser Scanning GIS 800.345.5694 toll free 800.345.5694 toll free www.esmcivil.com 253.838.7104 fax 425.297,9901 fax Mr. Jim Harris January 25, 2018 Page 2 Air Quality Analysis As with the Noise Analysis, an Air Quality Analysis cannot be provided until a majority of the TIA has been completed. Some of the items required by the Air Quality Analysis are dependent on information provided by the TIA. Visual Impact Analysis A Visual Impact Analysis is currently being prepared for the Greenline Business Park project Washington State Department of Archeology and Historic Preservation Analysis as follows: Provide an inventory of the project site and surrounding Weyerhaeuser campus to evaluate the property for its historical and architectural significance. The inventory shall be conducted by qualified cultural resource professionals with expertise in architectural history and archaeology and that have knowledge of using DAHP's on-line Historic Property Inventory and Archaeological Site Inventory databases. Be aware that DAHP requires that all documents related to project reviews be submitted electronically. Correspondence, reports, notices, photos, etc. must now be submitted in PDF or JPG format. For more information about how to submit documents to DAHP please visit: http:llwww.dahp.wa.govlprograms/shpo-compliance. To assist in conducting a cultural resource survey and inventory effort, DAHP has developed guidelines, including requirements for survey reports, which is available on their website. We are unclear how this analysis is required in order t deem the a licatio complete for processing. It is not listed on the City's checklist for Submittal Process for Use Process IV (Bulletin No. 001), and it is not listed under FWRC 19.15.040 as a submittal item. It has come to our attention through review of publicly available documents, that adjacent properties currently being developed under similar land uses processes have recently been deemed complete for processing without providing similar reports on visual, noise or air impacts and were not required to conduct an archeology and historic preservation analysis either. Please help us understand why the City is not applying the same application requirements for similar development applications on adjacent properties. Mr. Jim Harris January 25, 2018 Page 3 We respectfully request that the City retract this requirement for accepting the application. If the request is presented to the applicant as a review comment we suggest that you also provide the following: 1. Reference to the City ordinance and/or code citation which justifies the request 2. Clarify the boundaries of what is considered to be the surrounding Weyerhaeuser Campus." 3. A list of other projects in the vicinity of the Greenline Business Park that have been subject to this requirement If you have any questions, please feel free to contact me at 253-838-6113, and I look forward to your response. Sincerely, ESM CCNSU TING ENGINEERS, LLC MATT RODER Assistant Planner Ilesm8lengrlesm-jobs1188610011016-00161documentl letter-004.d ocx Jim Harris From: Brian Davis Sent: Friday, August 13, 2021 11:24 AM To: 'barbaralmcm@gmail.com' Cc: Jim Ferrell; Ryan Call; Bill Vadino; Keith Niven; Stacey Welsh; Jim Harris; 'Mindi_Linquist@murray.senate.gov'; 'jami_burgess@cantwell.senate.gov'; 'shana.chandler@mail.house.gov'; 'kcexec@kingcounty.gov'; 'info@tclf.org'; 'cmoore@preservewa.org'; 'eugeniaw@historicseattle.org'; 'pete.vonreichbauer@kingcounty.gov'; 'claire.wilson@leg.wa.gov'; 'Jesse.Johnson@leg.wa.gov'; 'Jamila.Taylor@leg.wa.gov'; 'CouncilOffices@puyalluptribe- nsn.gov'; 'lasechrist@comcast.net'; 'craig.hartman@som.com'; 'adamg@pwpla.com' Subject: RE: Suspension of Section 106 conversations concerning former Weyerhaeuser campus Ms. McMichael, Thank you for taking the time to express your concerns. Mayor Ferrell shared your email with me and asked that I respond since this is a land use matter that has already been appealed twice. The City strives to honor the environmental legacy of this unique property. At the same time, we respect the property rights that Weyerhaeuser added to their 1994 zoning contract which states, "Weyerhaeuser desires to develop its Property with maximum flexibility while preserving the unique natural features of the site." The City honored these two conflicting wishes of Weyerhaeuser -- develop and preserve — by issuing a development permit for the proposed Warehouse A with over 40 conditions that allow construction with limitations that reduce impact to the iconic Headquarters building, its adjacent pond and meadow, the Bonsai Museum, and Rhododendron Garden. The City determined this was a reasonable balance of maximum development flexibility and preservation. Courts in two subsequent appeals agreed with our approach. One of the 40+ conditions upheld on the two appeals was concurrence from the U.S. Army Corps of Engineers (USACE). USACE's jurisdictional review of the development proposal (Section 106) is separate and independent from the City. You mentioned in your message that after several meetings USACE determined they do not have jurisdiction on this matter. If that is the case, this City's condition regarding concurrence from USACE would be satisfied. Should IRG propose to redevelop the Rhododendron Garden or Bonsai Museum, the City would consider that on its merits and methodically apply adopted development and preservation criteria. A list similar to the 40+ conditions imposed on the Warehouse A approval -- in which the Rhododendron Garden and Bonsai Museum were preserved -- would likely apply to such a proposal by IRG. For this and other reasons, redeveloping the Rhododendron Garden and Bonsai Museum would be extremely difficult if not impossible. Thank you again for your email. The City will continue to honor Weyerhaeuser's codified wishes to "develop [the] Property with maximum flexibility while preserving the unique natural features of the site." Brian Davis Community Development Director A City of Federal Way, WA Office: 253-835-2612 From: Barbara McMichael <barbaralmcm@gmail.com> Date: August 12, 2021 at 5:31:01 PM PDT To: Jim Ferrell <Jim.Ferrell@cityo_ffederalway.com> Cc: Mindi Lin uist murra .senate. ov, 'ami bur ess cantwell.senate. ov shana.chandler@mail.house.gov, kcexec@kingcountv.gov, Charles Birnbaum <info@tclf.org>, Chris Moore <cmoore@preservewa.or >, Eugenia Woo <eugeniaw@historicseattle.org>, ete.vonreichbauer kin count ov, claire.wilson@leg.wa.Qov, Jesse.]ohnson@leg.wa.gov, Jamila.Taylor@leg.wa.goy, CouncilOffices@puyalluptribe-nsn.gov, LORI A SECHRIST <lasechrist@comcast.net>, "Hartman, Craig" <craig.hartman@som.com>, Adam Greenspan / PWP <adam w la.com> Subject: Suspension of Section 106 conversations concerning former Weyerhaeuser campus [EXTERNAL EMAIL WARNING] This email originated from outside of the City of Federal Way and may not be trustworthy. Please use caution when clicking links, opening attachments, or replying to requests for information. If you have any doubts about the validity of this email please contact IT Help Desk at x2555. Dear Mayor Ferrell: For the past 10 months, I have participated as a consulting party in the Section 106 discussions concerning the proposed development of the southeast corner of the former Weyerhaeuser campus. As you know, California developer IRG (Industrial Realty Group) plans to take down several acres of trees to build two large warehouses that will bring an estimated 900 semi -trucks daily to the property. At the Section 106 meetings, I represented SoCoCulture (the South King County Cultural Coalition). Both the Pacific Bonsai Museum and the Rhododendron Species Botanical Garden are members of SoCoCulture. As tenants of IRG, they are not in a position to advocate for their own interests in this case, but SoCoCulture wanted to see that the well-being of these two organizations, both of which are internationally recognized cultural treasures, were considered as the Section 106 negotiations went fo rwa rd. Mayor Ferrell, I want to be sure you understand that these Section 106 meetings drew consistent attention and attendance from a number of very high profile entities. Participants included the King County Historic Preservation Program, the Washington Trust for Historic Preservation, Docomomo US- WEWA (which promotes appreciation and awareness of modern architecture and design in Western Washington), The Washington State Department of Archaeology and Historic Preservation, representatives from the nationally acclaimed architectural firm of Skidmore, Owings & Merrill that designed the Weyerhaeuser headquarters building, along with Mr. Peter Walker (the highly esteemed landscape architect who oversaw design of the campus and today is the sole surviving member of that original design team), the Puyallup Tribe as well as other tribes in the region, the Cultural Landscape Foundation, which is based in Washington DC, the National Trust for Historic Preservation (also based in the nation's capital) as well as SoCoCulture, and several Federal Way citizens and former Weyerhaeuser employees who were involved with the Save Weyerhaeuser Campus group. From October through July, this veritable braintrust met twice every month in hour -and -a -half -long meetings that were hosted by the Army Corps of Engineers. We sincerely tried to work with IRG and encouraged them to tap into the connections represented by our organizations in order to preserve and expand upon the longstanding and well-known cultural benefits of the campus. But I'm sorry to say that IRG's stance was combative in every meeting, and their representatives treated even the nationally prominent participants not only with disregard but with disrespect. In what turned out to be our final meeting, IRG Vice President Dana Ostensen even refused - multiple times - to say that the RSBG and Bonsai Museum were assured of a future on the campus - contending that Weyerhaeuser sold IRG that property as "developable" land. After all those months of negotiations, and without any advance warning, the Army Corps of Engineers abruptly ruled late last month that it didn't have jurisdiction over the property, so the Section 106 process was over, along with our hopes to achieve meaningful mitigation for the negative effects of those massive warehouses. If you haven't seen it yet, The Cultural Landscape Foundation, which invested considerable time and expertise in the hopes of preserving this campus, filed this report: tcif.org/penn-station-moment-postwar-desipn I've been trying to collect my thoughts about this whole process. In this drawn -out Section 106 experience, it was my observation that IRG demonstrated no interest in being a collegial or cooperative corporate citizen in Federal Way. If the city allows IRG's developments to continue as proposed, I fear that you will be letting a corporate bully continue to run roughshod without regard to the concerns of local citizens or, frankly, the local city hall. Two precious cultural organizations that are unique not just to our region, but on a national and even international scale, are at high risk of being negatively impacted - possibly even evicted. And a spectacular corporate campus that has garnered worldwide acclaim is going to be chopped up, bulldozed, and filled in with massive warehouses. This is a pitiful result that many of us fought very hard to prevent - and it is going to be a truly terrible legacy for your administration - unless you summon the political will to prevent it from happening. Sincerely, Barbara McMichael SoCoCulture info@sococulture.o 206-878-6912 0 March 19, 2021 � Eric LaBrie ESM Consulting Engineers, LLC 33400 8th Avenue South, Suite 205 Federal Way, WA 98003 Eric.labrie@esmcivil.com RE: City Project No. 17-105489-UP and 17-105490-SE Technical Review Comments Woodbridge Business Park (aka Greenline Business Park) Civil Engineers 327xx Weyerhaeuser Way South, Federal Way AHBL No. 2200534.30 Structural Engineers Dear Mr. LaBrie: The City received a resubmittal of plans and documents associated with the Process IV and Landscape Architects SEPA review of the above project on April 9, 2020. The City has the following comments in response to the resubmittal. The proposal has been modified to include the construction of Community Planners three new buildings totaling 971,390 square feet, construction of approximately 1,551 vehicle and truck parking spaces, construction of five stormwater ponds, and associated site work and improvements. Approximately 12,070 square feet of wetlands would be directly impacted, Land Surveyors and seven wetlands would be insufficiently buffered, causing 7,849 square feet of indirect impacts. Additional grading impacts to wetland buffers are proposed. The proposal includes a mitigation plan for wetland and buffer impacts. Neighbors You have also applied for a Boundary Line Adjustment (BLA). The City has provided separate comment letters for the review of the east and west BLA application and those are both currently on hold. 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 current critical areas regulations. Drainage for new development shall be designed to comply with current Federal Way drainage requirements. The land use procedural requirements must meet today's code, Federal Way Revised Code (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 need to be addressed prior to issuance of a SEPA threshold determination and land use application decision, or as otherwise noted. Questions regarding technical review comments should be addressed to the referenced staff representative. Lisa Klein — Contract Planner, (253) 651-7907, Iklein@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 TACOMA necessary adjustments. Please ensure consistent information is communicated throughout the plan set and associated application materials. 2215 North 30th Street Suite 300 2. See the separate City technical review letters pertaining to the proposed BLA. Tocoma,WA 98403-3350 253.3831422 TEL www.ahbi.com Eric LaBrie ■ March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE s Page 2 of 15 Parking Analysis Off-street parking shall comply with the 1994 zoning code 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 for every 1,0000 square feet of GFA for warehouse. No floor plan has been submitted, so the exact breakdown of office and warehouse space has not been determined, however, if we were to assume that 10 percent of each building is office space, the provided number of parking spaces does not meet the minimum requirements. As an alternative to meeting the code minimum parking requirements, a Parking Analysis was prepared by Transportation Engineering Northwest dated March 10, 2020. The following comments pertain to review of the onsite parking and the TENW Parking Analysis. 3. 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: "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." Either provide a breakdown of parking per building demonstrating that each building meets the required number of parking spaces or provide a response for the Director's consideration to the CZA provisions listed above. 4. The TENW Parking Analysis provides a parking calculation that is based on the Warehouse LUC 150. A calculation for office space associated with the warehouse use was not provided and the office space use may increase the parking requirement. Provide the office space calculation per the ITE Parking Generation Manual or explain why the office space calculation is not provided (for example, if office space is presumed to be an accessory use to the warehouse use). 5. The Traffic Impact Analysis (TIA) used a different LUC than the Parking Analysis (LUC 130 — Industrial Park). Either modify the technical documents for consistency or clarify why the Parking Analysis and TIA would use different LUCs. 6. As requested in the City's comment letter dated March 7, 2019, if the proposal is not meeting City code requirements for parking, the Parking Analysis shall provide comparisons to other existing similar uses with similar land use characteristics in the Greater Puget Sound region. 7. The size provided for the existing WTC building on the site plan (Sheet CV-01) is 239,354 square feet. The size of the WTC building provided in the Parking Analysis is 450,000 square feet. The size of the WTC building provided by the King County Assessor is 468,457 square feet. Clarify which building size is correct for the WTC building and correct the plans and Parking Analysis accordingly oaoo Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 3 of 15 Plan Statistics 8. The Cover Sheet of the Plan Set (Sheet CV-01) depicts the site area as 136 acres. Sheet SD-01 provides the site area as 145.99 acres. Clarify which statistic is correct and modify the plans and documents as needed to correct the discrepancy. 9. There are discrepancies in the impervious surface numbers provided for the project area. The Architectural site plan provides 60.7 acres of impervious, Sheet SK-01 provides 45.79 acres of impervious surface, and the SEPA checklist identifies 61.02 acres of impervious surface (45 percent of 135.61-acre site). Clarify which statistic is correct and modify the plans and documents as needed to correct the discrepancy. 10. Section III of the CP-1 regulations states, "The aggregate impervious surface coverage by all permitted uses, primary and accessory, shall not exceed 70 percent of the total CP-1 zoned property." The "Impervious Area Exhibit' prepared by ESM, September 9, 2017, shows the existing impervious coverage in the CP-1 zone is 8.6 percent and the construction of the proposed project would increase it to 24.1 percent. We believe that the exhibit is now outdated based on recent project changes. Revise/update the exhibit to match the current proposal. Managed Forest Buffer, Landscape Plans, and Tree Retention Section 111.13 of the Exhibit C of the CZA states that a continuous Managed Forest Buffer (MFB) shall be provided around the entire perimeter of the CP-1 property. On November 18, 2018, the City issued Interpretation #18-01 (18-105277-UP) that describes the location and depth of the MFB on the CP-1 zoned property. Washington Forestry Consultants, Inc. prepared a Forest Management/Maintenance Plan dated March 23, 2020 (the WFC Plan) which was submitted together with qualifications information on the preparer. The WFC Plan describes the location and vegetation types and quantities for each of the MFB areas. In general, the WFC plan is acceptable, however the site plan revisions described herein will require revisions. 11. The CZA states a "Managed Forest Buffer shall be provided around the entire perimeter of the CP-1 property." The CP-1 perimeter extends to the northeastern parcel along the North Lake shoreline (Lot F on EX-01), which is the lot currently proposed to contain a stormwater pond and wetland mitigation area, and where a Managed Forest Buffer (MFB) is not provided. The east boundary of the northeastern parcel is adjacent to single-family zoned land (including the adjacent access road, which is zoned single-family). The property zoned for single-family is currently owned by Washington Department of Natural Resources and used for a boat launch and public access for fishing, which is an incompatible use to the CP-1 zone. The CZA provides that a 50-foot MFB is to be provided adjacent to incompatible use. Provide a 50-foot MFB on the east boundary of the northeastern parcel. Update the Forest Management/Maintenance Plan to include this area. 12. Section III.B.4 of the CZA describes that widening of rights of way "shall not require relocation of any boundaries of the required Buffer for developed lots" (emphasis added). Section VIII.A.8 of the CZA describes that only perpendicular access roads are permitted in the MFB. The northern 25-foot MFB shall be located outside of the 106-foot Development Reservation area that is to be dedicated for right of way. �Rf HJB L Eric LaBrie March 19, 2021 . 00 City Project No. 17-105489-UP and 17-105490-SE Page 4 of 15 NINE 13. The screening of the truck bays on the north side of Building A to the future right of way and properties to the north requires 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 redcedar 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. The landscape plans shall be revised to include the addition of shade tolerant tree species within Forest Cover Type III located within the northern 25-foot MFB that infill the existing trees. Per Section XI.A.3 of the CZA, the selection and installation of plant material in the MFB shall be the responsibility of the Forester. A letter approving the landscape plans for this specific area shall be provided by WFC. 14. The Tree Retention Plan Sheet TR-01 is not consistent with the grading plans SD-01 and SD-02, the Visual Impact Exhibit, or the landscape plans. It depicts no tree retention adjacent to Weyerhaeuser Way South between the road and new buildings. The Grading Plans, however, depict that a large portion of the landscape buffer in this area will not be graded, which would allow for tree retention. The grading plans also depict greater potential for tree retention around the south and west sides of Buildings 2 and 3 and stormwater ponds 4 and 5 than shown on Sheet TR-01. The Visual Impact Exhibit also depicts the retention of the mature vegetation in these areas. The landscape plans depict new plantings in these areas to supplement the native vegetation. Per Section XI.A.1 of the CZA, all portions of the property not used for buildings, future buildings, parking, storage, or accessory uses, and proposed landscaping areas shall be retained in a "native" or predeveloped state. Revise Sheet TR-01 to match the grading plans, landscape plans, and Visual Impact Exhibit. All plans need to be consistent. Site Plan 15. Provide all easements to be retained and new easements proposed on the site plan sheets to determine any potential conflicts. 16. Sheet EX-01 depicts a small dashed line setback from the north and eastern perimeter of Parcel F. Identify the purpose of the line. Visual Impact Exhibit 17. The following modifications to the Visual Impact Exhibit are required a. Update the exhibit to reflect the current site plan. Revise the building references in the exhibit to correlate with the site plan for ease of reference (i.e., number designations instead of letters). b. Provide additional view locations as depicted below in Figure 1 depicting the change in view resulting from tree removal and the site development. 13©aQ ;-1 Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 5 of 15 licnal ne•,r from -5 J ' M1 i+ �+ 1 � I . 14 K 1 Pr"de additional ;� ¢ wew from 1-5 � arn+na. 1 it � ►},'� � � 1 1�1 lj�r View #1 r ;,i lew�#�; a 3 lc ' �47 fl 7 J ,. View #3 ST-03 / EX-03 l�'4 l c+oz —� VIEW 10oKing toward Buildin B 111 I Figure 1 - View Impact Exhibit - Additional View Locations Building Elevations and Design Brief The site and building design are required to comply with the CZA, and, where indicated, the FWCC. The specific CZA and FWCC design requirements affecting development of the property are stated below in "a — d" followed by staff technical comments as to how they apply to the Woodbridge Business Park: a. "The property is unique in terms of its development capacity and natural features. Weyerhaeuser desires to develop its Property with maximum flexibility which will insure optimal development, while preserving the unique natural features of the site." b. "CP-1 properties are characterized by large contiguous sites with landscape, open space amenities, and buildings of superior quality. The property appropriate for such Uses is unique and demands for such uses are rare. Consequently, special land use and site regulations are appropriate." Staff Analysis: The CZA's meaning and intent to `preserve the unique natural features of the site," as described in "a," is critical in understanding how the CP-1 properties are to be developed. Understanding the intent of "a" is assisted by the additional characterizations of the site provided in "b,"i.e., the unique natural features to be preserved are the unique "landscape and open space amenities." The CZA intent is to preserve the meadow, a unique landscape OMOO Eric LaBrie March 19, 2021 . 00 City Project No. 17-105489-UP and 17-105490-SE � Page 6 of 15 MI R feature that provides an open space amenity. Also to be preserved is the Managed Forest Buffer and the foresbnative vegetation located outside of the development footprint (described below in (d.A.1)), which form the landscape. The preservation of these areas will allow for "optimal development" of the site. Provision "b" further describes the existing condition of the CP-1 properties as containing buildings (such as the headquarters building and WTC building) that are of superior quality. It acknowledges that the site is unique and deserves "special land use and site regulations." The special regulations include regulations that require new buildings be of superior quality and that the development preserve the unique natural features. How the intent of the CZA is specifically applied to the proposal is provided below. c. Section X General Development Conditions: "Provisions of the FWC relating to fagade measurement, modulation, distance between structures, or materials, other than those specified herein, shall not apply to this zone." Staff Analysis: This provision is clear that prescriptive building design requirements typically found in design standards do not apply. Removal of specific design standards requires reliance upon the existing buildings and landscape for guidance in determining the intent of superior building design. Section VLB requires that proposed landscaping comply with Section XI (Landscaping). Section XI provides specific modifications to Chapter 22, Article XVII (Landscaping) that are applicable in the CP-1 zoning district, including: o A.1 "All portions of the property not used for buildings, future buildings, parking, storage or accessory uses, and proposed landscape areas shall be retained in a "native" or predeveloped state. Alterations to existing landscaping shall match or be compatible with existing vegetation." o A.2 "Alterations to existing landscaping in connection with new development shall match or be compatible with existing vegetation. Extensions of, or duplication of existing plant material in connection with future development is preferred." Staff Analysis: These provisions clearly intend for the existing vegetation to be retained to the greatest extent possible, and, when required to be removed for future buildings, parking, storage or accessory uses, the replacement plantings shall match or be compatible with existing vegetation. 18. Based on the CZA requirements and the staff analysis described above, we have the following comments on the building and site design: a. As previously commented by the City, the site and building design, as viewed from the high -profile public street roundabout, do not represent "buildings of superior quality" or an "altered site that matches existing vegetation." We understand you have reduced the size of Building 2 and pulled it away from the public right-of-way; however, the concerns remain that at this prominent location, the combination of the proposed tree removal for the storm pond, proposed plantings, and the building aesthetics do not meet the CZA requirements. The following would improve the building and landscaping COBB er Eric LaBrie . March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE S Page 7 of 15 AW 7 ■11■ aesthetics at this location and better comply with the CZA. The city is open to alternatives that provide an equivalent or superior approach to site and building design: Construction of storm pond #5 and its maintenance access road requires removal of mature vegetation and limits the planting of replacement vegetation that would otherwise screen the building. Relocation of the storm pond maintenance access road to a location that extends from the parking lot instead of Weyerhaeuser Way would allow the existing trees in that location to remain and new trees to be planted along this prominent frontage for additional screening. Relocate the pond maintenance access road to minimize tree removal. Provide additional trees between Weyerhaeuser Way and the stormwater pond for building screening. ii. The landscape plans provide new evergreen tree plantings between the street frontage and storm pond #5; however, the landscape plans do not indicate tree sizes. The City will require that the trees at this location be at least 10 feet in height at the time of planting. Add this note to the landscape plans. iii. The southeast corner of Building 2 marks the entry point to the new campus and this corner is not architecturally emphasized. Consider mimicking the building corner treatments provided at the main building entry at the northeast corner and/or the entry at the southwest corner or provide other architectural building elements that enhance building design at this high -profile location. b. As provided above, the meadow is a "unique natural feature of the site that is to be preserved." In order for the meadow to be preserved/retained in its native/predeveloped state, the City will require the meadow be protected from development through the recording of a conservation easement. This will be a condition of approval. c. The City is concerned about view impacts from Interstate 5 as a result of the pond and building construction. If view impacts are not adequately mitigated, the City may determine that a SEPA Determination of Significance is appropriate and an EIS will be required. The following comments provide our analysis of the impacts and potential opportunities to mitigate the impacts. Additional analysis will likely be required following plan changes and receipt of the updated View Impact Analysis to evaluate if the impacts are adequately mitigated. The Visual Impact Exhibit demonstrates that Buildings 2 and 3 will be visible from Interstate 5, impacting the view of the site across the meadow, a "unique natural feature of the site" that, per the CZA, shall be preserved (see staff interpretation above). The retention of the existing trees between the meadow and the buildings provides some screening of the building, however the screening is limited. The existing vegetation that is to remain at this location is narrow in width (particularly at the south end) in the existing condition, and these trees are largely deciduous trees, which will result in significantly less screening during the fall and winter than what is depicted on the Visual Impact Exhibit. Additionally, the height of Building 2 will clearly exceed the height of the retained trees as viewed from Interstate 5. Additional screening is required. One option could be to plant additional evergreen trees of a type that will exceed the height of the building at maturity. If this option is selected, WFC (the forester) shall recommend a suitable tree type for this location that will grow quickly and that 00190 Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE FE `t Page 8 of 15 ■1 �• will eventually exceed the building height. The new trees shall be no less than 10 feet in height at the time of planting. The City is open to considering other options at this location. The selected screening shall be depicted on the revised View Impact Analysis. Storm Pond #3 is partially located within the northern portion of the meadow and in an area where the adjacent managed forest buffer is also meadow (i.e. has no trees in its natural predeveloped condition). Construction of Storm Pond #3 will therefore impact the meadow, which is not acceptable as described above, and will require removal of trees that could otherwise provide screening of the rear elevation of Building 3 as viewed from Interstate 5. Storm Pond #3 shall be relocated (potentially placed in an underground facility) so as not to impact the meadow or screening of Building 3 as viewed from Interstate 5. Alternatively, you may propose relocation of the above ground pond in a manner that demonstrate that view impacts will be mitigated. iii. Storm Pond #2 is located between the 100-foot-wide Managed Forest Buffer adjacent to Interstate 5 and the palustrine-forested and scrub -shrub wetlands located adjacent to the rear side of the existing WTC building. The rear side of the WTC building contains a storage yard and loading area that is not visible from Interstate 5 today and the rear and south building elevations have deteriorated and have no modulation or architectural elements that are required for buildings of superior quality that will be visible from a public right of way. Construction of Pond #2 will require removal of a 145 — 170-foot-wide swath of mature trees and native vegetation that will open the view of the south and rear elevations of the existing WTC building. The remaining vegetation will be the 100-foot wide Managed Forest Buffer (which is partially meadow grass and transitions to forest to the north) and the sparsely vegetated wetlands and wetland buffers. The following menu of potential options for screening and mitigating view impacts caused by Storm Pond #2 shall be considered and depicted on the View Impact Analysis for additional review. Alternatively, you may propose relocation or redesign of the pond in a manner that demonstrates that view impacts will be mitigated. • Provide additional plantings in the Managed Forest Buffer. The forester shall provide recommendations for the additional plantings that retain the integrity of the "native" or predeveloped conditions" of the MFB and are planted so as to provide additional screening. New plantings shall be evergreen trees that are at least 10 feet in height at the time of planting. • Provide additional screening of the rear side of the WTC building by augmenting the wetland buffer plantings with additional evergreen trees that are at least 10 feet in height at the time of planting. Provide documentation that the additional plantings have been approved by the wetland biologist. • Provide additional landscape screening within the reconfigured rear parking/storage area of the existing WTC building. The screening would need to be of a depth and type that provides effective screening. a Modify the rear and south elevation of the existing WTC building to provide architectural treatments that are complementary to the new buildings and represent "superior quality." 10000 Eric LaBrie ■ March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 9 of 15 dW ■I NN Relocate or redesign Storm Pond #2 to retain the trees in this area. In lieu of an open pond, consider an underground facility in the parking areas. 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 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. The proposed building design, however, is not complementary to, or reminiscent of the existing buildings. The mountain-themed paint scheme serves to break up the fagade but does not correlate to the existing buildings or legacy of the site, which is more about trees and timber than mountain views. Staff recommends elimination of the mountain paint scheme, expansion of the vertical wood panels and incorporation of additional windows to improve the building's quality of design, and to provide a more complementary design to the existing buildings and a design that is representative of the legacy of the campus and of superior quality. Wetlands and Streams 19. Review and address each comment in the enclosed January 25, 2021, review letter from the City's wetland consultant, ESA. 20. Add the North Lake 200-foot Shoreline Management Zone to the plans, including the area where improvements are planned to Weyerhaeuser Way (near Wetland BL) and, if required, submit for a Shoreline Substantial Development Permit. See the ESA letter, comment #10, for more details. SEPA Checklist 21. The revised SEPA checklist does not reflect all of the plan changes and additional environmental information that has been prepared or updated. Update the SEPA Checklist to reflect the updates and revisions made to the project. In particular, the following is noted as needing to be updated: a. Update the environmental information listed in A.8 to reflect revised/updated studies and newly completed studies. b. See the ESA comment letter on the review of the Talasaea Critical Areas Report and Proposed Mitigation Plan dated April 9, 2020. Update the SEPA Checklist in accordance to any updates/revisions made to the Critical Areas Report. In particular, if a shoreline permit is required, update the list of government approvals provided in A.10. c. Include the wetland impacts and mitigation proposal in the project description in A.11. d. Update the wetlands information provided in B.3 and B.8.h to match the updated Critical Areas Report and Mitigation Plan dated April 9, 2020, or as updated based on ESA comments. The statistics provided appear out of date. A H B LJ Eric LaBrie March 19, 2021 0■ City Project No. 17-105489-UP and 17-105490-SE t Page 10 of 15 NINE e. Update B.7 to address the existing pipelines (see Technical Review memo from the Public Works Department dated November 3, 2020). f. Update B.10.b and 6.10.c to address altered views from Interstate 5 and how the view impacts will be mitigated. g. Are measures proposed to control light and glare impacts? Amend section B.11 to address proposed light and glare mitigation measures. h. Provide further clarification of what is meant by your intent to reconfigure onsite trails in Section B.12. Which trails will be removed, and which will be reconfigured to avoid dead -ends? Your comment response letter dated April 2, 2020, indicates that many of the trails throughout the property will be retained in accordance with the CZA purpose statement (your Comment 5). Please clarify. i. Update section B.13. Include a description of the Cardno Cultural Resources Study dated March 16, 2018 and address the findings. 22. The Cardno Report did not include information regarding correspondence with DAHP or the Tribes. Your letter responding to public comments indicates in Item 4 that the report will be submitted to DAHP. Did you provide a copy of the report to DAHP for their comment? If so, provide copies of all correspondence and/or comments that were received following DAHP's review of the Cardno report. Kevin Peterson — Public Works Development Services, (253) 835-2734, Kevin.peterson@cityoffederalway.com Prior to Land Use approval, the applicant shall address the following Technical Review comments: Use Process 23. Provide a breakdown of impervious surfaces on the site plan cover sheet: total impervious area for the entire project, total new impervious area (as defined in the King County Surface Water Design Manual - KCSWDM), and total replaced impervious area. 24. Based on the Boundary Line Adjustment (BLA) currently under review for this project, it appears that Pond 1 is isolated on a separate parcel, without adequate space to locate a building, and therefore cannot be allowed as it does not create a 'buildable lot', as defined in FWRC Section 19.105.010. In addition, it appears that the current proposed BLA property lines may either cross through or are very close to Ponds 2 and 3. These ponds shall be located completely within property boundaries and meet property line setbacks as required in the design criteria of the KCSWDM. Clearly show the proposed new property ,lines that are delineated on the BLA(s) currently under review with the City. 25. Pond 5: Access to this pond shall be provided on -site, no access allowed from either S 3361h St or Weyerhaeuser Way S. 26. It is difficult to see what, if any, Solid Waste & Recycling amenities are being provided. Show and/or otherwise indicate on the plans where the SW&R facilities are located and provide some basic design details on the enclosures. [RJH B Eric LaBrie March 19, 2021 0■ W City Project No. 17-105489-UP and 17-105490-SE Page 11 of 15 7 27. Street trees shall be 2.5-inch caliper, per City standards. Technical Information Report (TIR) 28. Based on the information provided, it appears the project is under the threshold for Large Project Drainage Review and is now subject to Full Drainage Review requirements of the 2016 KCSWDM. 29. There appear to be essentially 2 primary threshold discharge locations — 1 to the south and into the Weyerhaeuser Pond and 1 to the east into North Lake, which eventually discharges into the Weyerhaeuser Pond. In the Existing condition, approximately 24 acres of the site discharges to North Lake, yet in the Developed condition, it appears only 13.14 acres are discharging to North Lake, with the remainder discharging to the Weyerhaeuser pond. The requirement is to maintain, as closely as possible, the hydrology to each discharge location so as not to create adverse impacts by increasing or decreasing flows to one basin or the other. 30. The report indicates that an additional 3.43 AC -FT of live storage from this project is being directed to the Weyerhaeuser Pond on the old headquarters building site: a. Provide an estimated depth of water that will be added across the existing pond (i.e., x.xx-feet +/- depth of water added across the existing pond surface; existing WS Elev=xxx.xx', New WS Elevation=xxx.xx'). b. Provide a copy of the approved and/or as -built plans for the 2004 headworks modification to the Weyerhaeuser Pond. 31. Pond 2, as currently designed, has a detention capacity greater than 10 acre-feet with an impounding berm over 6-feet in height. As such, this detention pond will need to comply with the State Department of Ecology regulations and review process for dam safety (KCSWDM Section 5.1.1, WAC 173-175) — this should be identified in the TIR. 32. The WWHM analysis for Pond 5 shows it to FAIL. The analysis needs to indicate the facility to PASS, and the pond shall be designed and analyzed to meet the PASS condition. Otherwise, provide a narrative in the TIR that provides an explanation of the Pond 5 analysis FAIL condition. 33. From the November 2017 pre -application meeting summary letter: '...the site is near an identified Sphagnum Bog (Core Requirement 6.1.4 of the KCSWDM). The applicant's engineer shall demonstrate in their storm water technical analysis if and/or how the project does (or does not) impact this bog, and the means of providing water quality treatment to meet the Sphagnum Bog treatment criteria if storm water runoff affects the bog.' Based on the topographic mapping provided, it appears that some portion of the site, at the NE corner, does discharge into the Bog, including a portion that is being developed with parking and drive aisles. Please provide the analysis as requested from the pre -application meeting summary. 34. The TIR must also examine the Hylebos Executive Proposed Basin Study and the projects impacts upon the East Hylebos recommendations and the Basin Wide recommendations. The TIR shall include a section that provides an analysis of the project and how it meets the requirements of - and/or does not further impact - drainage -related issues that are identified in the study. Q©OM Eric LaBrie March 19, 2021 W FE City Project No. 17-105489-UP and 17-105490-SE Page 12 of 15 MINE SEPA 35. According to the plans and survey provided, as well as project materials reviewed by the City in the immediate vicinity of this site (and unrelated to this project), there is a buried, 14-inch Olympic oil pipeline that runs through the west side of the project site. There may also be a buried gas main that extends south through the northeast portion of the site. These 2 pipelines shall be disclosed/identified under section B.7.a.2 of the SEPA checklist, with proposed measures to protect these pipelines under section B.7.a.5 of the checklist. 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. The following technical review items must be address. Please note, these comments did not include comments from WSDOT. Traffic related comments/concerns by WSDOT must be addressed and approved by WSDOT. Plans Comments 36. The submitted plans depicted the correct Type K street section and right-of-way dedication for S 336th St and Weyerhaeuser Way S. However, the plans did not show street improvement and potential right-of-way dedication at the S 336th St and Weyerhaeuser Way S roundabout. ADA compliant pedestrian facilities must be provided at the roundabout. Unless a street modification is approved by the Public Work Director, the submitted plans must show improvement at the roundabout. 37. Provide a truck turning diagram to ensure the roundabouts on Weyerhaeuser Way S can accommodate the expected trucks. 38. Pavement design and upgrade may be necessary on Weyerhaeuser Way S and S 336th St in order to accommodate the expected truck traffic generate by the proposal. The applicant must perform pavement evaluation demonstrating that the standard pavement section for a Type "K" street is adequate to handle the expected traffic load generating by the proposal. 39. The proposed northerly driveway must meet separation distance from the future S 324th St and Weyerhaeuser Way S intersection. Please coordinate with the City Center Access Study team to determine the future intersection and S 324th St alignment. 40. Submit a Vehicle Turning Diagram to the Public Works Traffic Division showing how the appropriate design vehicle can enter, maneuver, and leave the site without encroaching onto opposing traffic lanes or mounting a curb. Please note, the maximum driveway width is 30 feet for a two-lane two-way driveway and 40 feet for a three -lane two-way driveway (FWRC 19.135.270). Driveway widths may be increased or modified to radius driveways in order to provide adequate width for vehicles that may be reasonably expected to use the driveway, as determined by the Public Works Director. 41. Show conceptual street lighting along the property frontage on S 336th St and Weyerhaeuser Way S on the plans. Details design is not required at this time. W©DM Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 13 of 15 42. The depicted 25'wide manage forest buffer should not be within the proposed 106' development reservation (right-of-way) for future S 324th St extension. TIA Review Comments 43. Page 3 — The TIA identified the project buildout in 2022. However, the concurrency application identified 2023 buildout. Please address this discrepancy. 44. Table 1 Page 7: Revise Weyerhaeuser Way S from S 320th St. to S 336th St classification to a Minor Arterial instead of a Principal Collector. The remaining portion from S 336th St (Roundabout) to SR 18 is classified as a Minor Arterial. 45. Page 7 — Transit Service: Add King County Metro Route 181 on S 320th St approximately mile north of the site. Coordinate with Pierce Transit for any on site transit related improvements requirement. 46. The TIA need to clarify or provide narrative on how the proposed ITE LUC 130 (Industrial Park) is applicable to the development. From a technical perspective, 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. Since the actual tenant(s) is still unknown, Industrial Park land use consisted 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. 47. The TIA appears to utilize the same truck trip percentage for all analysis periods. Clarify if the truck trip percentage from ITE Trip Generation Manual is specifically for all analysis periods (weekday, AM, PM, and Saturday). If not, the TIA should address how the proposed 15 percent truck trips would be applicable to all analysis periods. 48. The proposed 2 percent annual traffic growth rate is acceptable. 49. The proposed pipeline trips from surrounding developments such is acceptable. However, the TIA should provide a separate figure or spreadsheet of these trips for tracking purposes. 50. Page 14 — Project Trip Distribution and Assignment: Provide clarifications on the AM, weekday, and Saturday trip distribution. The narrative of the project trip distribution and assignment appears to indicate that the AM, weekday, and Saturday project trips distribution is generated and provided by the City. The Emme model plot provided by the City is based on PM only with no distinction between car or truck trips. 51. The adopted City Center LOS is based on average V/C and not individual V/C ratio of each intersection. Provide narrative to clarify why other intersections in the City Center were not included. 52. The report identified all site access locations would operate at LOS D or better with v/c less than 1.0. Provide right turn lane warrant analysis for truck access and storage pocket at driveway with the highest volume. 53. The AM and PM LOS analysis for S 320th St and 32nd Ave S is showing cycle length of 173 seconds. The cycle length should not exceed 160 seconds. Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE ON W Page 14 of 15 :� �: 54. Show critical movement for Stop controlled intersections. For example, Weyerhaeuser Way S and S 323rd St is showing 0.00 v/c ration but the NBT and SBT has 0.10 v/c ratio. 55. The trip assignment in Figure 6 through 8 depicted truck trips utilizing non truck routes and traveling through residential neighborhood. Revise the truck trip assignment at intersection 5, 7, 9, 10 and 12 and recalculate the LOS for AM, PM, and Saturday. For example, intersection #9 in Figure 6 depicted 5 truck trips west of the S 336th St and Weyerhaeuser Way roundabout, which has been designated no truck except for local deliveries. Also, intersection #7 (32nd Ave S & S 323rd St) has 18 truck trips going through the office complex roundabout. These truck trips should be reassigned to intersection #6 (S 320th St & Weyerhaeuser Way S). 56. Intersection #2 (25th Ave S & S 320th St) — Change pm+pt to D.P+P. 57. Intersection #5 (32nd Ave S & S 320th St) — Change EBL and WBL from pm+pt to D.P+P. 58. Intersection #6 (Weyerhaeuser Way S & S 320th St) — Change WBL from pm+pt to D.P+P. 59. Table 6 on page 16 (Future 2022 Weekday Peak Hour Level of Service Summary): Some of the study intersection does not match with Figure 10-13. For example, intersection #6 in Table 6 depicted as Pacific Highway S / S 336th St. Update Table 6 to match Figure 10-13. 60. Weyerhaeuser Way Assessment — The City concurs that the 2022 future with project is expected to meet the minimum street design standards for a Type K street. 61. Traffic impact fee for commercial developments, fees 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. 62. The City has determined that the S 320th St. / SR 5 and Weyerhaeuser Way S / SR 18 ramps intersections are located within WSDOT limited access. As such, WSDOT has jurisdiction over these intersection and its respective LOS standards shall apply. Any LOS failure and mitigation measures must be reviewed and approved by WSDOT. 63. Forward update TIA to WSDOT for technical review comments. SEPA Checklist - Transportation 64. Transportation 14(c) — Revise this section to including right-of-way dedication of 106' for future S 324th St extension. 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 revised application materials as appropriate, accompanied by the completed "Resubmittal Information Form" (enclosed). 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. 1310MB ESA 5309 Shilshole Avenue, NW Suite 200 Seattle, WA 98107 206.789.9658 phone 206.789.9684 tax memorandum date January 25, 2021 to Jim Harris, City of Federal Way Department of Community Development from Jessica Redman and Ilon Logan subject Critical Areas Report and Proposed Mitigation Plan Review: Woodbridge Business Park www.esassoc.com At the request of the City of Federal Way (City), Environmental Science Associates (ESA) reviewed the Critical Areas Report and Proposed Mitigation Plan — Woodbridge Business Park (dated April 9, 2020) prepared by Talasaea Consultants Inc. 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). A previous version of the critical areas report and conceptual mitigation plan (dated October 27, 2018) was also reviewed. by ESA in 2018. This previous review was under the former name of the project, "Greenline Business Park" and included a sixth parcel (King County Tax Parcel Number 7978200520). Findings were presented to the City in the Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park — FINAL technical memorandum (dated November 30, 2018). In response to ESA's comments and recommendations in the November 30, 2018 technical memo, Talasaea revised the critical areas report to its current April 9, 2020 version and submitted a Response to ESA Review Memorandum dated 30 November 2018 technical memo (dated April 1, 2020). The April 1, 2020 memo, as well as the latest version of the Woodbridge Business Park plan sheets (prepared by ESM Consulting Engineers and dated March 31, 2020) are also part of this review. 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 five new stormwater detention facilities, parking for cars and trucks, and maneuvering space for the anticipated truck traffic around these buildings. Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 15 of 15 If you have any questions regarding this letter, please contact either Jim Harris or me (see contact information provided above). Sincerely, �A� ao�� Lisa Klein, AICP Contract Planner for the City of Federal Way I rM enc: Technical Review Letter from ESA dated January 25, 2020 Resubmittal Information Form c: Brian Davis, Community Development Director Stacey Welsh, Planning Manager Jim Harris, Senior Planner, Jim. Harris@cityoffederalway.com Kevin Peterson, Senior Engineering Plans Reviewer, Kevin.Peterson@cityoffederalway.com Cole Elliot, Public Works Development Services Manager 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:12020\22005341WORDPROC1Letters120210319 Ltr (Woodbridge Bus Pk -Tech Rev) 2200534.30.docx i11: 010133 CITY OF Federal Way Centered on Opportunity November 27, 2019 Mr. Eric LaBrie ESM Consulting Engineers 33400 81h Avenue South, Suite 205 Federal Way, WA 98003 Eric.labrie@esmcivil.com CITY HALL 33325 8th Avenue South Federal Way, WA 98003-6325 (253) 835-7000 www. cityoffederalway.. com FILE Re: File Nos.17-105489-00-UP & 17-105490-SE; 2°a APPLICATION EXTENSION Woodbridge Business Park, 32901 Weyerhaeuser Way South, Federal Way Dear Mr. LaBrie: Jim Ferrell, Mayor The Department of Community Development is in receipt of your November 13, 2019, extension request for the Woodbridge Business Park, Use Process IV application (city file 17-105489-UP). Pursuant to Federal Wray Rernsed Code (FWRC) 19.15.050, and based on the factors cited in your request, an application extension is hereby approved until April 3, 2020. Failure to submit additional information to further the application processing will result in cancellation of the application. If you have any questions or need additional information, please contact Senior Planner Jim Harris at 835- 2652, or jim.harris@cityoffederalway.com. Sincerely, &-�-/2f� Brian Davis Director of Community Development c: Jim Harris, Senior Planner Kevin Peterson, Senior Engineering Plans Reviewer Sarady Long, Senior Transportation Engineer Brian Asbury, Lakehaven Water and Sewer Dana Ostenson, cf=_-�Iscna'intiusz �lrrilnl=rr,u�rtl�t Doc. I.D. 79900 17-105489-00-UP C:FIVED NOV 131 2019 Community Development Department November 13, 2019 Mr. Brian Davis Community Development Director City of Federal Way 33325 8th Avenue S Federal Way WA 98003 CONSULTING ENG.[NEER_]S L(c Job No. 1886-001-016-0016 Re: Woodbridge Business Park City File No. 17-105489-UP Application Extension Request Dear Mr. Davis: On behalf of IRG, ESM Consulting Engineers is requesting an application extension for the Process IV land use review of Woodbridge Business Park, City File No. 17-105489- UP. A prior application extension was requested on October 1, 2019. Due to continuing extenuating circumstances, additional time is needed to facilitate a proper response to the requested information in the City's Technical Review Comment Letter dated March 7, 2019. With respect, we ask the City of Federal Way to extend the application resubmittal deadline for File No. 17-105489-UP, Woodbridge Business Park one last time, until January 31, 2019. The following criteria for an extension have been met: That circumstances beyond the applicant's control prevent compliance with the time limits of subsection (1) of this section; Preparation of a revised site plan is largely dependent on the city determining a preferred alternative for the S 324th off -ramp as part of the Federal Way City Center Access Project, which is out of the applicant's control. This includes the following key factors: • The Project Study Support Team has identified their preferred alternatives for the City Center Access Project. ■ The various alternatives have varying degrees of impact on the applicant's property proposed for the Woodbridge Business Park. • The city council identified a preferred alternative on November 4, 2019, and this alternative is scheduled to be on the consent agenda on November 19, 2019. Approval of the preferred alternative will allow preliminary design of the off -ramp and S 324th Street to begin. ■ Identification of a preferred alternative allowed the applicant to adjust the conceptual site plan for the Business Park to avoid or minimize potential future conflicts between the projects. 33400 8th Ave S Ste 205 Tat (253) 838 6113 Everett (425) 297 9900 Civil Engineering Land Planning Federal Way. WA 98003 Fax (253) 838 7104 ToLL Free (800) 345 5694 Land Surveying Landscape Architecture www esmciviL corn 3D Laser Scanning GIS Mr. Brian Davis November 13, 2019 Page 2 2. That the applicant is making substantial progress in responding to the request for information so that review of the application can be furthered when that information is submitted. The applicant has made substantial progress to date. The applicant has revised the site plan to accommodate the identified preferred alternative and will know if further changes to the site plan are necessary after the city council approves a preferred alternative on November 19, 2019. Now that the site plan has been updated, more time is needed in order to provide adequate and complete information in associated reports, which are based in part on the site plan. Furthermore, the technical comment letter requested extensive information from the applicant and as a result, requires more time to provide a comprehensive and thorough response. 3. The number of additional calendar days necessary to provide the requested information. We respectfully request that the deadline for applicant responses be extended until January 31, 2020. Very truly yours, ESM CONSULTING ENGINEERS, L.L.C. ERIC G. LaBRIE, A.I.C.P. President cc: Courtney Kaylor, McCullough Hill Leary, PS Dana Ostenson, Federal Way Campus, LLC \\esm8\engr\esm-jobs\1886\001 \016-0016\document\letter-011.docx -`-' RESUBMITTED OCT 01 2019 CITY OF FE[]ERAL WAY COMMUNrry I�EVELOPMQrT TI N G ENGINEERS LLC .. October 1, 2019 Mr. Brian Davis Community Development Director City of Federal Way 33325 8th Avenue S Federal Way WA 98003 Re: Woodbridge Business Park City File No. 17-105489-UP Application Extension Request Dear Mr. Davis: Job No. 1886-001-016-0016 On behalf of IRG, ESM Consulting Engineers is requesting an application extension for the Process IV land use review of Woodbridge Business Park, City File No. 17-105489-UP. A prior application extension was requested on August 1, 2019. On September 3, 2019, we received a letter granting a 30-day extension until October 3, 2019. Due to extenuating circumstances, additional time is needed to facilitate a proper response to the requested information in the Technical Review Comment dated March 7, 2019 from City of Federal Way, Senior Planner, Jim Harris. With respect, we ask the City of Federal Way to extend the application resubmittal deadline for File No. 17-105489-UP, Woodbridge Business Park, sixty (60) days from October 3, 2019, until December 2, 2019. The following criteria for an extension have been met: That circumstances beyond the applicants control prevent compliance with the time limits of subsection (1) of this section; Preparation of a revised site plan is largely dependent on the following factors out of the applicants control: ■ The last site plan that was submitted triggered a scoping process for a Master Drainage Plan. The amount of site plan revisions and/or report preparation requires additional time. Y Federal Way City Center Access Project: o The Project Study Support Team is in the process of evaluating altematives for the City Center Access Project o The City Council held a Special Study session on September 17, 2019. Before the study session, the surrounding business owners were invited to comment on proposed alternatives of the South 324th Street interchanges and signalizations through stakeholder interviews; o Proposed alternatives have varying degrees of impact on the applicants property proposed for the Woodbridge Business Park; o Additional open houses are scheduled online and in person in the first couple of weeks in October 2019; Everett (425) 297 9900 Civit Engineering Land Planning 33400 Bth Ave S Ste 205 Tel (253) 838 6113 Federal Way WA 96003 Fax (253) B38 7104 Toll Free (800) 345 5694 Land Surveying Landscape Architecture www esmciviL.com 3D Laser Scanning GIS Mr. Brian Davis October 1, 2019 Page 2 o The Citys Land Use Transportation Committee is scheduled to discuss proposed altematives on November 4, 2019; o The City of Federal Way City Council will meet on November 5, 2019 to review the preferred alternative; o City Council is scheduled to adopt the preferred alternative on November 19, 2019. This is not a final decision on what alternative will be adopted. That decision will not be made until after the EIS process is complete. However, the discussion of altematives and identification of a preferred alternative will allow the applicant to better evaluate the potential future impact, if any, on the project 2. That the applicant is making substantial progress in responding to the request for information so that review of the application can be furthered when that information is submitted. The applicant is making substantial progress in evaluating if changes to the site plan are necessary. The applicant has evaluated the potential impacts of various alternatives for the City Center Access Plan provided by the City prior to the Study Session. The applicant will continue to evaluate potential impacts as alternatives are further discussed and refined. Discussions with city staff and review of city council decisions will help the applicant make a determination on a suitable site plan configuration for the Woodbridge Business Park. Additionally, while progress is being made on updates to the site plan, more time is needed in order to provide adequate and complete information in associated reports. Furthermore, the technical comment letter requested extensive information from the applicant and as a result, requires more time to provide a comprehensive and thorough response. 3. The number of additional calendar days necessary to provide the requested information. We request that the deadline for applicant responses be extended an additional 60 days from the response deadline of October 3, 2019. This would put the new deadline for submittal at December 2, 2019. Very truly yours, ESM CONSULTING ENGINEERS, L.L.C. //; 44� x(" MATT REIDER Land Use Planner Enc: As noted CC: Courtney Kaylor, McCullough Hill Leary, PS Dana Ostenson, Federal Way Campus, LLC Ilesm&enghesm-jobsO 886=1 V 6-00MdocumentlIetter-009.docx November 11, 2019 Mr. Rick Perez City Traffic Engineer City of Federal Way 33325 8th Avenue S Federal Way WA 98003 jJEsut; iTTi:ED NOV 12 2019 CITY OF FEDERAL WAY COMMUNr Y DEVELOPMENT CONSULTING � Job No. 1886-001-016-0016 Re: Woodbridge Business Park, City Application No. 17-105491-CN Traffic Concurrency Application Modification Dear Mr. Perez: With this letter, amended Traffic Concurrency Review Application, updated Trip Generation table and enclosed site plan, ESM Consulting Engineers is requesting an amendment to the current Traffic Concurrency Review Application for the Woodbridge Business Park, which was submitted November 14, 2017. As you may know, there have been some major adjustments to the site plan for the proposed project, which have resulted in a significantly smaller development. As such, we respectfully request that the City adjust their concurrency review to reflect this proposed development outlined in the enclosed materials. The proposed changes to the Business Park are a direct result of addressing the City's most recent comments, as well as respecting the current City Center Access Plan preferred offramp alternatives for the proposed S 324th Street extension to Weyerhaeuser Way S. We are currently in the process of coordinating with all of the other consultants and updating our plans and reports to match this proposal and anticipate a complete submittal of the revised materials in late 2019 or early 2020. Meanwhile, we wanted to submit this request as soon as possible since it may have an impact on other projects located throughout the City. The following table is provided to summarize the proposed changes to the Traffic Concurrency Review Application for quick comparison: Nov 14, 2017 Nov 12, 2019 Gross Square Footage. Existing 468,457 468,457 Gross Square Foota e, New 1,068,000 972,700 Parcel Size 99.5 97.7 Will the Project be Phased No No Development Build -Out Year 2020 2023 Est. New Daily Trips Generated 3,779 3,064 Est. New PM Peak Hour Trips 271 389 33400 8th Ave S Ste 205 Federal Way, WA 96003 Tel (253) 838 6113 Everett (425) 297 9900 I Civit Engineering Land Planning Fax (253) 838 7104 Toll Free (800) 345 5694 II4 Land Surveying Landscape Architecture www esmciviL.com 3D Laser Scanning GIS Mr. Rick Perez November 11, 2019 Page 2 We look forward to answering any questions you may have and receiving a Certificate of Transportation Capacity in the near future. Thank you for your attention to this request. Very truly yours, ESM CONSULTING ENGINEERS, L.L.C. ERIC G. LaBRIE, A.I.C.P. President Enc: As noted cc: Brian Davis, Federal Way Community Development Director (wlenc.) Courtney Kaylor, McCullough Hill Leary, PS Dana Ostenson, Federal Way Campus, LLC Jeff Schramm, TENw \\esm8\engr\esm jobs\1886\001\016-0016\document\letter-010.docx c�er c. �t. _.. Federal Way PUBLIC WORKS DEPARTMENT 33325 8 b Avenue South Federal Way WA 98003-6325 253-835-2700;Fax 253-835-2709 www.cif oifederalwa .coni 2019 TRAFFIC CONCURRENCY REVIEW APPLICATION APPLICATION N -105 491_ - CA (Revi5ec-�' Date 11- 31.2019 Project Name ODp32.,D(4E 13LWAJM ?AU_ Fo Mg&Ly G2EEn1l.iAJE Property Address/Location GQ1ftALuf *62901 �-iammajsm S 5 �(p-, - � ParcelNumber(s) CP 21 — J013 50 rjcp Project Description RiUt5eAT- pex t cp f p L)L�e.0 rss �,v i t G e.,r b�l �df s anc� t�.ss rr��C,.• nib^vbl�"r ---- APPLICANT (if different than Name: c r� I Address: 1 OR. CA` Email: Signature: Type of Development permit to be applied for: Phone/Fax: City/State/Zip: Cell: PIP Commercial ❑ Multifamily (MF) ❑ Subdivision ❑ Short Subdivision ❑ Single Family (SF) ❑ None (Feasibility only) ❑ Other Approval for City to perform Concurrency analysis: 4Yes ❑ No If NO: Applicant's Traffic Engineer must perform Concurrency analysis consistent with City procedures; however, the application fee remains the same. Required Information — Application is incomplete and will be returned if not filled out. Gross Square Feet (Commercial) Existing 4G?), 4 J I Proposed 9 T 700 Number of Dwelling Units Existing '— Praposed_ Number of Employees Existing WA Proposed p� Parcel size (acres or square footage) Existing /7� 7 Proposed g7- P7 Has the property previously been reviewed for concurrency? 'L If yes, date of original application 11- 14 - D 9ri Is this an amendment to an existing Concurrency Certificate? Will the project be phased? IVDI Development Build -Out Year 2O Z 5 Yes Y Concurrency Pen -nit No: Yes No No Note: - Commercial subdivisions and other projects constructed in phases shall be evaluated for concurrency as each phase is submitted for applicable development permits. - Once the concurrency test result has been determined, any changes to the development project require additional review will be billed on an hourly basis. Estimated Number of New Trip Generated by Project per Pre -application Summary: 20 I If the applicant's engineer has prepared a trip generation analysis, please provide the following. If not, staff will calculate the trip generation based on the above information. Existing PM Peak Hour Trips (if applicable) Proposed PM Peak Hour Trips Net New PM Peak Hour Trips$�J `,C61 (CtAAJ&9t* TEST EXPIRATION &WrRO `I A (,oncurresacy Reserve CertifidatddCRG) is valid until the underlying develbVivi ist'permit expires, is withdrawn or ( cancelled, whichever 6Qcurs;first..in that,case, a new concurrency applicatibrl w -ld,be regt4red. — 1 A Concurrency Reserve Cerlii--scate:is v"a only for the specific develrigmei ,apprpy consistent with the D.�: development ara . ' ' -Ci e �J p p e#Dr K� xY fit. itaaer within the CRC issued: _:+ 3t{0111- 1 A concurrency Rt siv i ei pfic>st (t)rtt;rts withthe land, and carat be'ed toa±differentparcel. ...� ��keq+ii�lii i[♦e�l.�iiii{.1.1i ��-- '171F�!i�ir�._.�::ii.j.t� I have read the above information regarding expiration deadlines. I further understand that issuance of a concurrency certificate is not a guarantee that the City will issue a development permit or building permit, Property Owner/Agent Signature Date SUBMITTAL REQUIREMENTS — STAFF USE ONLY Permit Submittal: The following items are required for all applications: 0 Completed and signed Concurrency Application o Concurrency Application Fee paid (See Below) Net New PM Peak Hour Trip Less than 10 11 - 50 51 - 500 Greater than 500+ 2019 Application Fee $1,721.00 $4,938.00 $9,032.00 $14,479.00 E:\TR Media Information\FW Concurency Application Rev. Jan2019.doe .�g £ ) an : k 0 ■ Col) OD { / \ ) CCl) C00 l)w § 3_ Cl) \� § (4 \ 17 z j § § \ q ® \co 00 CO 00 Cl)� m ` m r 2 � ) I ([ e Q S (N m « LU CO Cl) u Cl) CO { 0 r CD Cl) Cl)\ § \e \- 3 § § r" ^ § k a,§ # Lq co cc ) \ _ — =Ci � � c ) 0 7 c \ a « G $ k s 4) \ ° \ ° a,Ol ~ X \ \ § ® k 2 z A cm ® \ � co\ § z G ) LU \ ) ) ) ) @ ol ) ƒ � } % Ad ¢§e §, )§3 0 �& 0�2 «_£ _£ G- o��— �2{ �0 ��— ®$§{ ��s G§§ ;0.0 )�£c £f2 ƒCL A/\ I Z w F- 6% 41k REQUEST FOR ADM ISTRATwE DECISION circa RECEIVED COMMUNITY DEVELOPMENT DEPARTMENT 33325 8`h Avenue South Federal Way Federal Way, WA 9800 2019 253-835-2607;Fax 253-835-2609 www.cityoffedcralway.com FILE NUMBER 1 9— - j— V Date Applicant NAME L'p- L)�9P-1 PRIMARY PHONE BUSINESS/ORGANIZATION ALTERNATE PHONE 45 • IZ' MAILING ADDRESS E-MAIL mac' e-c'm c i' V� CITY STATE ZIP FAX Property AddressfLocation Description of Request ('1 f d' v PA [ � 1111 i S -&S a Kk- List/Describe Attachments -l"l o �rn For Staff Use ❑ Code Interpretation/Clarification ❑X Critical Areas Letter/Analysis/Peer Review Request for Extension (Land Use/Plat Approval) ❑ Revisions to Approved Permit ❑ Tree Removal ❑ Zoning Compliance Letter C&f - 60 Bulletin #079 — January 4, 2016 Page I of I k:\Handouts\Request for Administrative Decision CITY OF . Federal Way Centered on Opportunity September 3, 2019 Mr. Matt Reider ESM Consulting Engineers 33400 8th Avenue South, Suite 205 Federal Way, `y/A 98003 ntarr.teidcrfr%rstn - ril. CITY HALL 33325 8th Avenue South Federal Way, WA 98003-6325 (253) 835-7000 www cityoffederalway. com FILE Re: File Nos. 17-105489-00-UP; APPLICATION EXTENSION Woodbridge Business Park, 32901 Weyerhaeuser Way South, Federal Way Dear Mr. Reider: Jim Ferrell, Mayor The Department of Community Development is in receipt of your August 1, 2019, extension request for the Woodbridge Business Park, Use Process IV application (city file 17-105489-UP). Pursuant to Federal Way 2ev&ed Cade (FWRC) 19.15.050, and based on the factors cited in your request, an application extension is hereby approved Until October 3, 2019. Failure to submit additional information to further the application processing will result in cancellation of the application. If you have any questions or need additional information, please contact Senior Planner Jim Harris at 835- 2652, or jim.harris@cityoffederal-,vay.com. Sincerely, Brian Davis Director of Coma-nunity Development c: Jim Harris, Senior Planner Kevin Peterson, Senior Engineering Plans Reviewer Sarady Long, Senior Tmnsportation Engineer Brian Asbury, I.akehaven Utility District Dana OSEemson, da4rolmn i4i",1irlusrri.ti lmy�s' n�-rum Doc LD, 79566 17-1 O5489-0O-CP C a N August 1, 2019 RECEIVE® Job No. 1886-001-016-0016 AUG 01 2019 CITY OF FEDERgLWAY Mr. Brian Davis COMMUNfTY DEVELOPMENT Community Development Director City of Federal Way 33325 8th Avenue S Federal Way WA 98003 Re: Woodbridge Business Park City File No. 17-105489-UP Application Extension Request Dear Brian: On behalf of IRG, ESM Consulting Engineers is requesting an application extension for the Process IV land use review of Woodbridge Business Park, City File No. 17-105489-UP. ESM received a request for additional information in the form of a Technical Review Comment letter dated March 7, 2019 from City of Federal Way, Senior Planner, Jim Harris. The Technical Review Comment letter says that if additional information is not provided to the City within 180 days of being notified that such information is requested, the application shall be deemed null and void. Therefore, the deadline to provide additional information is September 3, 2019. Pursuant to FWRC 19.15.050(2), ESM is submitting this request for an extension 30 days prior to the lapse of the 180-day notification. The following criteria for an extension have been met: 1. That circumstances beyond the applicant's control prevent compliance with the time limits of subsection (1) of this section; Preparation of a revised site plan was/is largely dependent on the following factors out of the applicant's control: • The last site plan that was submitted triggered a scoping process for a Master Drainage Plan. The amount of site plan revisions and/or report preparation requires additional time. • The City approved the Comprehensive Plan amendment for the realignment and extension of South 324th Street on April 2, 2019. This extension affects the property that the proposed Woodbridge Business Park is located on. More time is requested for revisions to account for this change. • The public comment period during the notice of application generated over 60 public comments. The applicant's consultant team needs more time to read and formulate a response as requested in the Technical Comment Letter. 33400 8th Ave S. Ste 205 Tel (253) 838 6113 Everett (425) 297 9900 Federal Way. WA 98003 Fax (253) 838 7104 Toll Free (800) 345 5694 www.esmcivil com Mr. Brian Davis August 1, 2019 Page 2 2. That the applicant is making substantial progress in responding to the request for information so that review of the application can be furthered when that information is submitted; and Responses to the request for additional information has required revisions to the site plan and consequently, to technical reports associated with the site plan. While progress is being made on updates to the site plan, more time is needed in order to provide adequate and complete information in associated reports. Furthermore, the technical comment letter requested extensive information from the applicant and as a result requires more time to provide a comprehensive and thorough response. 3. The number of additional calendar days necessary to provide the requested information. We request that the deadline for applicant responses be extended an additional 30 days from the response deadline of September 3, 2019. This would put the new deadline for submittal at October 3, 2019. Very truly yours, ESM CONSULTING ENGINEERS, L.L.C. t r MATT REIDER Land Use Planner Enc: As noted CC: Courtney Kaylor, McCullough Hill Leary, PS Dana Ostenson, Federal Way Campus, LLC Ilesm81engrlesm-jobsO 886M01 V 6-00Mdocumentlletter-008.dou CITY OF Federal Allay Centered on Opportunity March 7, 2019 Mr. Eric LaBrie ESM Consulting Engineers, LLC 33400 8th Avenue South, Suite 205 Federal Way, WA 98003 erl .la esrnc .c CITY HALL 33325 8th Avenue South Federal Way, WA 98003-6325 (253) 835-7000 www. cityoffederalway.. com Jim Ferrell, Mayor FILE Re: Files #17-105489-UP & 17-105490-SE; TECHNICAL REVIEW COMMENTS Woodbridge Corporate Park (aka - Greenline Business Park), 327XX Weyerhaeuser Way South, Federal Way Dear Mr. LaBrie: The Planning Division has the following preliminary comments in response to the Greenline Business Park SEPA and Process IV applications. The proposal includes: construction of three new buildings totaling approximately 1.1 million square feet; construction of approximately 1,577 vehicle parking and truck parking stalls; approximately 18,000 square feet ofwetiand fill; construction of five stormwater ponds; and associated site work and improvements. This 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. Any procedural requirements must meet today's code, Federal W lay Revised Code (FWRC) Title 19. Some comments provided herein are required and some are informative, while others may be applicable during future steps of the project. Comments in this letter need to be addressed prior to issuance of a SEPA threshold determination and land use application decision, or as otherwise noted. Questions regarding technical review comments should be addressed to the referenced staff representative. City staff has been informed that the applicant will be submitting a revised Business Park proposal. These comments are not a complete code based review of the proposal, and does not identify environmental impacts resulting from the proposal. These comments should be addressed in any future submittal on the project application. Jim Harris — Planning Division, (253) 835-2652, jim.harris ci offeder a .com 1. Technical comments made about an item on one sheet may necessitate changes to other related 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. Use Process IV 2. Plan Set— Please address the following comments: Mr. Eric LaBrie Page 2 of 8 March 7, 2019 a. The "Site Data" section of the site plan on Sheet ST-01 lists several parcels as part of the project. The parcels on the plan sheets are not current to the parcel configuration and legal descriptions following recording of the Lakefront Boundary Line Adjustment (BLA, city file 18-100123-SU). Please revise accordingly. b. Revise and amend the site data block for city reporting purposes with at least the minimum following information: • Under the site area, identify the size of each parcel; • Include the existing building area; 6 List the size of each existing and proposed building; • Identify the proposed building height; • List the existing and proposed uses of each buildings; • Include the total building square footage; • Include the impervious area (identify both paved area, building area, and total); • Include the stormwater area square footage; • Included the Managed Forest Buffer Area square footage; • Included the wetland and buffer area square footage; ■ Included the existing parking stall count; • Included the code required and proposed parking stall count; • Included the area of public dedication (square footage) and purpose; and • Included -the landscape area square footage. 3. Parking and Parking Stall Reduction Request — Off -street parking shall comply with the 1994 zoning code 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 for every 1,000 square feet of gfa for warehouse. No floor plan has been submitted, so the exact breakdown of office and warehouse space has not been determined. In summary, based on the November 10, 2017, ESM Parking Analysis memo, the applicant is requesting a reduction of 819 parking stalls from the minimum count required by the Federal Way City Code (FWCC). The ESM memo summarizes: o Code requires 2,396 stalls (2,395,550 SF warehouse). o Site plan provides 1,577 stalls (1,466 car stalls & 111 trailer stalls). o Parking stall count reduction request of 819 stalls (2,396 - 1,577 = 819). o ESM memo (ITE) concludes actual parking demand is 981 stalls. In order for city staff to further evaluate the parking stall reduction request, please provide the following information: 17-105489-00=UP Doc ID 17344 M r Mr. Eric LaBrie Page 3 of 8 March 7, 2019 Identify the existing uses and square footage of the existing Tech Center building, and anticipated uses of the Tech Center building. City staff understands that a portion of the building is used as an office. Office use has a higher parking rate than warehouse use. Pursuant to FWCC Section 22-1398, a decrease in the required number of parking spaces under Section 22-1377 may be permitted if a thorough parking study documents that fewer parking spaces will be adequate to fully serve the uses. Provide a thorough parking study prepared by a licensed PE in the transportation field addressing the parking count reduction request. The parking study shall address all existing and anticipated uses of all building area, and shall also include comparisons to other exiting similar uses with similar land use characteristics in the Greater Puget Sound region. Pursuant to FWCC Section 22-1397, a parking stall count reduction would be considered (and decided) as part of the land use review process based on the criteria in FWCC Section 22-1398. 4. Process IV— Please provide a written response to how the proposal meets the Hearing Examiner Process IV decisional criteria in FWRC 19.70.150(3)(a-0. 5. Budding and Site Design — In general, the existing parking area layout (including ample landscape areas and open space on the west side of the Tech Center, and vast landscape area east of the Tech Center building) generally meets the CZA Exhibit C purpose statement as the existing development is characterized by large contiguous sites with landscape, open space amenities, and buildings of superior quality. In general, the proposed Business Park site plan, buildings, and parking layout is short of meeting the CZA objective of a superior quality, as the proposed site plan layout and parking areas have minimal unique or superior quality characteristics. a. The site and building design at the southeast corner of proposed Building B needs to be addressed. From this high profile corner at the large high visibility public street roundabout, looking toward the site from the public roadway the linear appearance is proposed as: a large geometric shaped stormwater pond; storm pond vehicle maintenance access; then a six foot tall retaining wall (unidentified finish materials); then a drive aisle and parking stalls above the wall; and then a 42 foot tall building corner. Address how this site and building design are superior quality design; as noted as one of the site objectives identified in the Section I of the CP-1 regulations (Exhibit C to CZA). This corner is a very high aesthetic value signature area of the campus. Please reconsider and revise the plans to incorporate and implement superior quality design in this location, as well as all areas of the site. b. Implement screening of all truck areas, wing walls, or comparable and/or dense landscape or other architectural screening between the Building A truck bays and Weyerhaeuser Way. c. Identify the proposed screening methods between the truck bays on the north side of Building A to the properties to the north. d. Provide and delineate pedestrian connectivity the from right-of-way sidewalks to the buildings, between buildings, and from buildings to the parking areas. e. FWCC Section 22-1564(u) requires building walls which are uninterrupted by a window, door, or other architectural feature; that are 240 square feet or greater in area; and not located on a property line, to be screened by landscaping. Identify how this code requirement is being met. f. Identify retaining wall designs, materials, and architectural treatments. Doc ID 17344 17-105489-00=UP Mr. Eric LaBrie Page 4of8 March 7, 2019 6. Rooftop and Ground Mounted Equipment— The submittal does not provide detail on the location and screening for ground mounted and rooftop mechanical equipment. Will rooftop equipment be fully or partially screened and with what type of material? a. For rooftop mechanical equipment, per FWCC Section 22-960(a), vents, mechanical penthouses, elevator equipment, and similar appurtenances that extend above the roofline must be surrounded by a solid sight -obscuring screen that meets the following criteria: (a) the screen must be integrated into the architecture of the building; and (b) the screen must obscure the view of the appurtenances from adjacent streets and properties. b. For ground mounted equipment, per FWCC Section 22-1565(a)(1), Type I landscaping is intended to provide a solid sight barrier to totally separate incompatible land uses. This landscaping is typically found "... around outdoor storage yards, service yards, loading areas, mechanical or electrical equipment, utility installations, trash receptacles, etc." 7. Wetlands and dreams — Please address the following comments: a. Review and address each comment in the enclosed November 30, 2018, review letter from the city's wedand consultant, ESA. b. Please confirm that the project applicant has opted to comply with and process this application under the current FWRC critical area regulations, rather than the critical area and wetland and stream regulations contained in the 1994 FWCC, and additional wetland regulations contained within the CZA. 8. Managed Forest Buffer Please address the following comments: a. Show the Managed Forest Buffer (MFB) on the north end of the CP-1 property per the November 8, 2018, City of Federal Way MFB Interpretation (city file 18-105277-UP). b. Include and identify the 50-foot wide MFB along all lengths and both sides of Weyerhaeuser Way South, and on the north side of South 336th Street as required in CZA Exhibit C Section III.B.2. El niinate all intrusions into the 50 foot MFB, except those uses specifically allowed by the CZA. c. Provide a General Maintenance Plan for the MFB by a Qualified Forester and identify who will be the required ongoing Qualified Forester per the CZA. 9. Si gnicant Trees — a. Address the following comments on Sheet TR-01 and revise/provide additional information to supplement the Gilles Evaluation of Trees as necessary: i. The table on plan sheet TR-01 and in the Gilles report simply identifies the following: ■ 4,182 significant trees exist on site; ■ 1,736 significant trees are to be retained; ■ 41.5 percent of the significant trees will be retained; and ■ There is an average of 28.64 significant trees per acre. There is minimal to no supporting documentation in the application materials and Gilles Report of how the numbers above were derived and extrapolated. 17-103489-00=UP Doc ID 17344 Mr. Eric LaBrie Page 5 of 8 March 7, 2019 If tree data is being proposed through representative sampling of trees as it appears, then you need to provide a comprehensive table of data, and associated maps/plans, showing at a minimum the following: ■ Size of each representative vegetation area; ■ Size of each vegetation type area; ■ Location of representative sample areas; (this is shown areas a-h on Gilles attachment 1 vegetation map); • Number of significant trees in each representative sample area; ■ Extrapolate (show the math) concluding how many significant trees exist in each representative vegetation type area. of This data and analysis needs to be provided for each Vegetation Type and each transect in Attachment 2 of the Gilles Report Attachment 1 in the Gilles report--questions/comments to address: ii. Why are the two side -by -side transects (E and F) in the same vegetation type area? Why would this be appropriate? iii. Why are there no representative samples/transects in the blue Wet Forest Type? iv. If there are no transects in the Wet Forest Area, how was an average tree count per acre derived in this vegetation type? v. Visually, the vegetation area east of Weyerhaeuser Way seems a fairly different vegetation type from the vegetation type west of Weyerhaeuser Way; however, in attachment A to Gilles Report, both areas are classified as the sa=vegetation type (Western Red Cedar Forest). Please confirm this vegetation type is accurate for both sides of Weyerhaeuser Way. vi. Provide sample area/transect for areas in Western Red Cedar Forest on both sides of Weyerhaeuser Way South. These should be separate vegetation areas. vii. The meadow area north of 336th Street is not identified on Attachment A; however, on TR-01 it is identified that 1,731 significant trees are existing/retained in "undisturbed vegetation" area, the undisturbed area on TR-01 is primarily the Meadow, and the Meadow is largely void of trees. Please explain. viii. A separate vegetation category type must be made for the MFB areas, and identify the MFB correctly on TR-01. ix. Provide a detailed and easy to follow table demonstrating and concluding support for the significant tree count and retention count as identified on TR — 01, and in the Gilles Report. x. The Gilles Report and the general maintenance plan need to identify the name, phone number, and email contact of the owner representative of the site in regard to the Tree Protection Fence and tree protection measures identified on page 15 of the Gilles Report. Do not put the City of Federal Way Code Compliance phone number and email as the contact. It is the owner's responsibility to insure adequate protection. The owner/representative needs to have a 24-hour phone access number posted. b. The significant tree count and retention count must only include properties on the west side of Weyerhaeuser Way South, and only that portion of property proposed for development on the east side of Weyerhaeuser Way Nvith this application. Properties should be reflective of current property boundaries. Doc ID 17344 17-105489-00=UP Mr. Eric LaBrie Page 6 of 8 March 7, 2019 c. A separate significant tree count and analysis must occur for the portions of the property that is being developed as part of this proposal on the east side of Weyerhaeuser Way. See the comments above on how to prepare a tree count and analysis. d. Brian Gilles has not provided credentials that he is a qualified Forester as required by the CZA. Please provide these credentials, or at a minimum have a Qualified Forester prepare and certify this tree information discussed. 10. Landscape Plan — A code based review of the landscape plan is not being conducted at this time as the site plan is being modified. 11. Forest Practices — A Forest Practices Class IV -General Application is required, as more than 5,000 board feet of merchantable timber will be harvested from the property in conjunction with the development activity. The city will review the proposed Class IV -General Forest Practices in conjunction with SEPA review, and review of associated development permits or approvals. 12. Noise Report— An April 2018 Environmental Noise Report by Ramboll was submitted with the application. At this time, city staff requests the following comments be addressed in regard to the Nose Report. a. On page 11 of the noise report, an assumed building height of 30 feet was used for the Noise Prediction Model. Will an actual building height of 42 feet as identified in the SEPA checklist result in any changed or different analysis or conclusions in the noise report? b. The noise report does not address the proposed removal of approximately 2,446 significant trees from the site as identified in the Gilles Tree Report. Will the removal of approximately 2,446 significant trees from the site result in any changed or different analysis or conclusions in the noise report? How does implementation/retention of the MFB affect site noise? c. The noise report does not specifically address the open water lake east of the proposed development and how potential noise could be impacted by the open water environment. Please address if the presence of the existing open water lake environment will result in any changed or different analysis or conclusions in the noise report? 13. Geotechnical Reports —A code based review of the geotechnical report is not being conducted at this time as there are no known geologically hazardous areas on the site. 14. Drainage Plan and Downstream Analysis and Potential off Site Improvements — All required off -site drainage analysis, improvements, and mitigation needs to be evaluated concurrent with this review. No information on off -site impacts and mitigation has been provided. Any potential off -site improvements may be required to be evaluated for SEPA compliance and FWCC based review for potential impacts to downstream critical areas and associated procedural requirements. 15. Use Process IV Decisional Criteria — Provide a narrative demonstrating how the proposal satisfies FWRC 19.70.150(3)(a-�. You should also a provide analysis and justification of the project compliance with the requirements of the CZA. 16. Burden of Proof— In this letter, staff members have identified items that require additional information to be submitted for city review. During the Notice of Application comment period, the city received a . number of public comments. Please review and address the comments to support your project, which can be opened in Outlook here: ftp://ftp.cityQf(e,der-,tl.�M.com/Outbox/CD/Publit°/o2OComment Gr nline°fo20Business°/a?OPark. _ee 17-105489-00=UP Doc ID 17344 r. N r Mr. Eric LaBrie Page 7 of 8 March 7, 2019 FWRC 19.70.120, Burden of Proof "The applicant has the responsibility of persuading the hearing examiner by a preponderance of the evidence that, under the provisions of this chapter, the applicant is entitled to the requested decision as specified in FWRC 19.70.120." SEPA Checklist — Please revise and update the SEPA checklist to address the following comments: 17. Environmental Documents — The submitted checklist lists needs to be revised/updated to address each of the following comments: A. 10. Building permits. B. Le, Identify cut/fill quantities on the property on the east side of Weyerhaeuser Way. B. 2. Reference the Air Quality Analysis submitted with the application; and findings and mitigation measures proposed; etc. B. 3. Reference appropriate wetland delineations and evaluations prepared for the site. B. 3. Reference the Wetland Mitigation and Wedand Creation Plan prepared for the site. B 3. Reference the Master Drainage Plan, or other drainage plan as appropriate, for the site in accord with the King County Surface Water Design Manual (KCSWDM) and City of Federal Way standards. B. 7 Identify any contaminants from the Tacoma Assarco Smelter Plume. B. 7 Reference the noise report prepared and submitted for the proposal, and proposed mitigation. B. 8 Reference the adjacent public boat launch, fishing, and recreational access on North Lake. B. 8. Checklist identifies the existing tech center as office, and the parking analysis identifies it as warehouse. Please rectify. B. 8. Identify if any portion of the proposal is within 200 feet of the OHWM of North Lake. B. 11. Any measures proposed to control light and glare impacts? B. 13 Reference the name, date, author, and summary of the Cultural Resources Archival Study prepared for the site. B. 13. Reference the name, date, author, and summary of the Transportation Impact Analysis prepared for the site. Identify mitigation proposed. 18. Aesthetics — A visual impact analysis of the proposed Greenline Business Park development is requested to determine its cumulative impact on public views of the three proposed warehouses. Views of a three- dimensional computer model, combining the existing site conditions and the proposed development, shall be provided from Interstate-5, South 3366 Street, and Weyerhaeuser Way South, from various points along each route. It is requested that a three-dimensional laser scanning visual impact analysis be used to capture and display the density of existing and retained on -site vegetation from any point in the area, to accurately allow determination of the aesthetic impact from the development, and to determine mitigation measures if any are needed. 19. Historic Preservation — Address the October 31, 2017, comments from the Washington State Department of Archeology and Historic Preservation (DAHP). 20. Public Works Department Comments — Comments on stormwater drainage have been previously provided regarding the required Master Drainage Plan as required in the KCSWDM, as adopted by the city. The Traffic Division has not provided any comments. We will forward comments on the Traffic Analysis review when prepared. Doc ID 17344 17-105489-00=UP Mr. Eric LaBrie Page 8of8 March 7, 2019 21. Agency Review and Coordination - We strongly encourage you to proactively address transportation comments and concerns raised by WSDOT (contact Ramin Pazooki, Local Agency & Development Services Manager) and King County (contact Rose LeSmith, P.E., County Traffic Engineer, King County Road Services Division). 22. Lakehaven Water and Sewer issued Certificates of Water & Sewer Availability for the proposed application/project on August 4, 2017. Updates of these certificates will need to be provided to the city. No other application has been submitted to Lakehaven that is necessary to be able to more specifically determine the applicant's requirements for connection to Lakehaven's water and/or sewer systems to serve the subject property. As previously noted, the applicant will need to submit an application for either a Developer Pre -Design Meeting or Developer Extension Agreement for Lakehaven to formally commence the water and/or sewer plan review process. Lakehaven encourages owners, developers, and applicants to apply for Lakehaven processes separately to Lakehaven, and sufficiently early in the pre- design/planning phase to avoid delays in overall project development. 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 revised application materials as appropriate, accompanied by the completed "Resubmittal Information Form" (enclosed). Pursuant to FWRC 19.15.050, if an applicant fails to provide additional information to the city 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 me at iim.harri.stc2c-iWoffederalway.com or 253 835-2652. Sincerely, arris Senior Planner enc: November 30, 2018, Review Memo from ESA Resubmittal Information Form Brian Davis, Community Development Director Robert "Doc" Hansen, Planning Manager Stacey Welsh, Senior Planner Kevin Peterson, Engineering Plans Reviewer Cole Elliot, Public Works Development Services Manager Sarady Long, Senior Transportation Planning Engineer Brian Asbury, Lakehaven Water & Sewer District Chris Cahan, South King Fire & Rescue Dana Ostenson, n� d trialreal au .c Matt Reider, hfatt.Reidernesmcivil.cnm Ramin Pazooki, WSDOT, •.r kr wsd rt.wn. v Rose LeSmith, King County Road Services, rasc.lcsr it�th kiln county .gov 17-105489-00=UP Doc ID 17344 RESUBMITTED F � .'3 1 1 LU13 DEPARTMENT OF ComwiwrY DEVELOPMENT EpALAY 33325 8`h Avenue South CITY OFLN441m G�� OF � �p ENTFederal Way, WA 98003-6325 253-835-2607;Fax 253-835-2609 Federal Way www.clt►+offederalwa .com RESUBM ITTAL INFORMATION This completed form MUST accompany all resubmitials. Additional or re vised plans or documents for an active project will not be accepted unless accompanied by this completed form. Changes to drawings must be clouded. Applicants will be required to affix the City's date stamp on each page of resubmitted plans and to collate loose plans into existing plan sets. You are encouraged to contact the Permit Center prior to submitting if you are not sure about the number of copies required. Project Number: 1 _ Project Name; Project Address: G(ezn I dM�Q �)wA3 3 k Project Contact: '7 Phone: — E-mail � ��. �(� �• .� .Gv� 1 fC ��'' �� RESUBMITTED ITEMS: # of Copies Detailed Description of Item Resubmittal Requested by: �V . Letter Dated �(S a e er F_ OFFICE USE ONL Y RESUB #.• Buildir Planni PW Fire Other Distribution Name # 41 _ IZ- __, 1 Descri By.• 0-0 0 Bulletin #129 — September 24, 2018 Page 1 of 2 k:\Handouts\Resubmittal Information February 8, 2019 Mr. Brian Davis Community Development Director City of Federal Way 33325 8th Avenue S Federal Way, WA 98003-6325 CW j Job No. 1886-001-016 RE: Federal Way Campus, LLC Renaming of Current Land Use Projects Dear Mr. Davis: On behalf of Industrial Realty Group and Federal Way Campus, LLC, ESM Consulting Engineers is submitting this letter as a formal request to relabel the following land use permit applications: Greenline Building "A" File Nos. 16-102947-UP & 16-102948-SE to be renamed as Woodbridge Building "A"; Greenline Building "B" File Nos. 17-104236-UP & 17-104237-SE to be renamed as Woodbridge Building "B"; Greenline Business Park File Nos. 17-105489-UP 17-105490-SE to be renamed as Woodbridge Corporate Park. Please note that the change from Greenline to Woodbridge does not reflect a change to the proposed land use for each of the development applications. Industrial Realty Group respectfully requests that future correspondence including land use and environmental decisions from the City of Federal Way reflect the requested name based on the corresponding file number. Thank you for your time and review of this matter. Please do not hesitate to contact me with any comments, questions, or concerns during your review. Sincerely, ESM Consulting Engineers, LLC Industrial Realty Gr up, LLC ERIC LABRIE DANA President Executive Vice President CC: Dana Ostenson Jack McCullough, McCullough Hill Leary PS Ilesm8lengrlesm-jobs11886\00110161documentlletter-018.docx 33400 6th Ave. S. Ste 205 Tel (253) 838 6113 Everett (425) 297 9900 Civit Engineering Land Planning Federal Way. WA 98003 Fax (253) 838 7104 Toll Free (800) 345 5694T3D Land Surveying Landscape Architecture www esmcivil.com Laser Scanning GIS AR -A IBURU & EusuS, LLP Attorneys at Law J. Richard Aramburu rick@aramburu-eustis.com Jeffrey M. Eustis eustis@.aramburu-eustis.com May 29, 2018 City of Federal Way 33325 8th Ave. S. Federal Way, WA 98003 Attn: Brian Davis, Director Department of Community Development And Jim Harris Planner 720 Third Avenue, Suite 2000 Seattle, WA 98104 Tel 206.625.9515 Fax 206.682.1376 www.aramburu-eustis.com Via Email: Brian. Davis@cityoffederalway.com Jim.Harris@cityoffederalway.com Re: Greenline Business Park Application (File #17-105491); Proposals for Warehouse A (#16-102947-00-UP, 16-102948-00-SE) and Warehouse B (#17-104236-UP, 17-104237-SE). Dear City of Federal Way: This office represents Save Weyerhaeuser Campus, a Washington nonprofit corporation organized and existing to protect and preserve the community and :natural values of the Weyerhaeuser Campus. On May 14, 2018, the City of Federal Way determined that the application for the Greenline Business Park (GBP) was complete. That proposal, made by Industrial Realty Group of Los Angeles (IRG), includes the construction of three buildings totaling approximately 1,068,000 square feet on a parcel of 146 acres and revisions to an existing parking lot adding 806 parking stalls, which will involve, among other activities, filling wetland and improving existing roads in the vicinity. On May 18, 2018, the City issued a Notice of Master Land Use Application, initiating a fourteen day comment period. The Notice indicates that the proposal will be reviewed under the "Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement" (CA), which places the property in the CPA zone created by the CA. Previously, FRG submitted complete applications for two other construction projects also located in the CP-1, Warehouses A and B. Warehouse A is a 225,950 square foot warehouse building on 13.7 acres with 245 parking stalls; Warehouse B is a 217,300 June 4, 2018 Page 2 square foot warehouse building with 244 parking spaces immediately adjacent to Warehouse A. The Warehouse A/B proposals will use a common access road and the same stormwater detention pond. These two projects are owned by the same applicant as for the Greenline Business Park. The City has not issued a threshold determination under SEPA for either of IRG's Warehouse proposals. In this letter, SWC provides comment on the rules, regulations and standards applicable to the pending permit applications. First, any review of the business park proposal under both current zoning and the State Environmental Policy Act (SEPA) must consider the consolidated and cumulative impacts of all three pending proposals and cannot proceed with separate, individual, fragmented review. Second, the existing rules and regulations, including the CA, cannot be read to vest applications to rules and standards adopted twenty-four years ago. In several specific areas, the City should apply current standards and regulations adopted after Ordinance 94-219 (including the CA and its zoning) was adopted in 1994. These issues will be addressed below. 1. THE CITY MUST CONDUCT COMBINED AND CONSOLIDATED REVIEW OF THE THREE PENDING PROPOSALS. 1.1. SEPA REVIEW. Because of the background of this proposal, the City is required to conduct consolidated land use and environmental review of the pending applications, not segmenting or bifurcating review. This is based on the following. A. ONE OWNER. The entire 426-acre Weyerhaeuser Campus was purchased in 2016 by IRG, a California developer of warehouses and business parks. B. THREE CURRENTLY PENDING APPLICATIONS. IRG has filed applications for use of significant portions of the Weyerhaeuser Campus, including the GBPark, Warehouse A and Warehouse B, which have all been deemed complete by the City. These three applications will be referenced herein as the "IRG Applications." Each of the applications is currently pending and no threshold determination has been issued for any of them. Comments on the GBP are due on June 4, 2018. C. SAME ZONE FOR ALL PARCELS. The IRG Applications are all in the CP-1 zone. That zone is only applicable to the Weyerhaeuser Campus parcels and not to any other properties in the city. D. UNDER SEPA, THE THREE PENDING APPLICATIONS MUST BE CONSIDERED IN A SINGLE ENVIRONMENTAL DOCUMENT. The City of Federal Way has adopted by reference most of the Washington State SEPA Rules, WAC Chapter 197-11, into Federal Way's code in FWC 14.05.020. June 4, 2018 Page 3 Included in this adoption is WAC 197-11-060, including Subsection (b). This section provides as follows: (b) Proposals or parts of proposals that are related to each other closely enough to be, in effect, a single course of action shall be evaluated in the same environmental document. (Phased review is allowed under subsection (5).) Proposals or parts of proposals are closely related, and they shall be discussed in the same environmental document, if they: (i) Cannot or will not proceed unless the other proposals (or parts of proposals) are implemented simultaneously with them; or (ii) Are interdependent parts of a larger proposal and depend on the larger proposal as their justification or for their implementation. In addition, WAC 197-11-060(c) provides as follows: (c) (Optional) Agencies may wish to analyze "similar actions" in a single environmental document. (i) Proposals are similar if, when viewed with other reasonably foreseeable actions, they have common aspects that provide a basis for evaluating their environmental consequences together, such as common timing, types of impacts, alternatives, or geography. This section does not require agencies or applicants to analyze similar actions in a single environmental document or require applicants to prepare environmental documents on proposals other than their own. (ii) When preparing environmental documents on similar actions, agencies may find it useful to define the proposals in one of the following ways: (A) Geographically, which may include actions occurring in the same general location, such as a body of water, region, or metropolitan area; or (B) generically, which may include actions which have relevant similarities, such as common timing, impacts, alternatives, methods of implementation, environmental media, or subject matter. These provisions were considered in Indian Trail Property Owner's Assn v. City of Spokane, 76 Wn.App. 430, 886 P.2d 209 (1994). There a shopping center redevelopment and expansion were under review, including a large grocery store and other features. However, two parts of the overall_ proposal were not included in the original environmental checklist and threshold determination, a car wash and large underground storage tanks, and were proposed for later environmental review. On a challenge to this segmented environmental review, the Court of Appeals said as follows: Cumulative Effects. We note at the onset that the responsible official's initial evaluation of the underground fuel storage tanks separate from other phases of the proposal was in error. Parts of proposals which are "related to each other June 4, 2018 Page 4 closely enough to be, in effect, a single course of action shall be evaluated in the same environmental document:" WAC 197-11-060(3)(b). Here, a phased review of the project was clearly inappropriate because it would serve only to avoid discussion of cumulative impacts. WAC 197-11-060(5)(d)(ii). See also WAC 197- 11-060(3)(b). However, the error was cured when the original MDNS and DNS were withdrawn, and the cumulative effects of the entire project considered before a new MDNS was issued. Redevelopment of the shopping district also included plans for a car wash. In 131 zones, a car wash requires a special permit. When addressing neighborhood concerns about the noise impacts from the car wash, the hearing examiner responded "there is no car wash in this application and a special permit must be applied for before a car wash can be built in conjunction with this use". To the extent the hearing examiner was approving separate SEPA review for the car wash, he was in error. WAC 197-11-060(3)(b). However, the error was harmless because the responsible official considered the impact of the car wash when making the threshold determination and required mitigation measures for it. 76 Wn.App. at 443. As noted above, the I RG Applications have a common owner (I RG), common timing (all have complete pending applications), common geography (all on the Weyerhaeuser Campus), common impacts and common zoning (CP-1, applicable only to this property). The most significant impacts of the combined proposals affect traffic and transportation, with significant impacts to off -site city roads and state highways including 1-5 and SR 18. Complete and accurate traffic and transportation analysis should include not only the three current proposals, but an accurate analysis for the future use of the Weyerhaeuser Headquarters building (more than 300,000 square feet), which is currently offered for lease by IRG to a single tenant. Currently, the traffic report for Warehouse A, for example, does not include potential traffic from Warehouse B, the GBP, or the Weyerhaeuser headquarters building. The projects, individually and cumulatively, will also impact downstream water resources, including the Hylebos stream, Milton's East Hylebos Ravine, Fife's Lower Hylebos Nature Park and associated wetlands and habitat. The GBP proposal alone will total 1,441,000 square feet of impervious surface. Under the applicable regulations and caselaw, it would be error for the City to conduct separate environmental review for IRG's proposals. The City should require iRG to submit an environmental checklist that -includes the cumulative -impact of all three projects. There appears to be little question that a proposal with more than 2,000,000 square feet of structure and other impervious surfaces will have a significant impact on the environment and accordingly requires an environmental impact statement (EIS). June 4, 2018 Page 5 1.2. LAND USE REVIEW. In addition, the three development proposals are included within the "Corporate Park 1" or "CP-1" zone, which was adopted by the City in Ordinance 94-219 as a part of the annexation of this and other nearby property in 1994. The CP-1 zone only applies to the former Weyerhaeuser Campus. Ordinance 94-219 also reached certain "Conclusions of Law," beginning at page 4; these Conclusions applied to the entire annexation area, including the property where the three pending proposals are located. Conclusion B states that the property, as a whole, has "unusual environmental features" and that the ordinance is the "means to preserve and protect these natural features," again referencing the entire annexation area. Conclusion C states that "any development in the corporate headquarters area is low density characterized by large expanses of open space." The applicant contends that the 1994 CA controls development on the Weyerhaeuser Campus. While that is not entirely correct, as pointed out below, it is apparent that the CA requires that the entire site be considered when development proposals are made. For example, under Paragraph 14.2 of the CA, existing streets had "been constructed to meet capacity needs for on - site development up to an additional 300,000 square feet of Corporate Office Park development;" this provision regarding street capacity is applicable to the entire site. The CP-1 zone found at Exhibit C to the CA also stresses that the entire site is to be considered together in review and analysis. The CP-1 zone states its Purpose and Objectives, saying that the properties in the zone: ...are characterized by large contiguous sites with landscape, open space amenities, and buildings of superior quality. The property appropriate for such uses is unique, and demands for such uses are rare. Consequently special land use and site regulations are appropriate for such properties. CP-1 Zone, page C-1. Subsection A states "This property is subject to its own unique standards of review processes as set forth in the Agreement." Id. The same is true of provisions for "Off -Street Parking" found in Exhibit C, in Section XIII at page C-18, that although new development shall require compliance with applicable off-street parking requirements: the aggregate of all proposed and existing uses on the property may, subject to the approval of the Director, be considered as a whole in establishing the minimum number of vehicles spaces required, .. . It is wholly inconsistent with the CP-1 zoning, and the background of the CA and Ordinance 94-219, to separately consider individual projects when the City recognizes that the proposals are located on a unique property. This is especially true when IRG, the property owner, has three complete and pending applications to use substantially all of the CP-1 zoned area. Based on the foregoing, it is apparent that since 1994 the City has considered the Weyerhaeuser Campus unique and has adopted unique standards June 4, 2018 Page 6 of review applicable to the entire site. Site development, by a common property owner, must be considered as a consolidated whole for permitting purposes. 2. THE CITY IS REQUIRED TO APPLY CURRENT CODES AND STANDARDS, NOT THOSE IN EFFECT IN 1994. As noted above, Ordinance 94-219 is now twenty-four years old, but the applicant for the three pending projects claims that the ordinance, and the CA, vest these new proposals to rules, regulations and standards in effect when the ordinance was adopted. The City should reject that proposition and apply current adopted standards.' The applicant seeks to apply certain provisions of the CA to its current land use applications. Among others, the applicant asks the City to follow certain criteria in review of its proposals, including the following provisions of the development agreement that are contrary to codes. 1) The agreement "not to require any dedication or conveyance of the Property or any portions thereof for public purposes .... Paragraph 12, page 10. 2) Agreement to consider roads adequate for the addition of 300,000 square feet of new Corporate Office Park development that might be located anywhere on the site. Paragraph 14.2, page 11. 3) Agreement that the property owners "shall be vested for purposes of roadway capacity requirements and any concurrency requirements and Weyerhaeuser shall not be required for pay for any new public streets within the Property area or traffic mitigation fees for these streets in connection with the Additional Development. Paragraph 14.2, page 11, Paragraph 15, page 13. 4) Agreement that areas of the Property which are "classified as environmentally sensitive" shall comply with the critical areas ordinance in effect in 1994, except for special provisions found at pages C-12 to C-18. Exhibit C to Ordinance 94-219, Section XII. Washington -law is clear that no city may establish fixed land usdamd development regulations that cannot be ever modified or changed. ' As described above the City should consider IRG's three pending proposals together as a single application following evaluation of the whole proposal under SEPA. , June 4, 2018 Page 7 A) Washington Law Prohibits One Legislative Body from Binding Future Councils. The effect of the CA as interpreted by the applicant is that no later rules, regulations, legislation or council action can modify the agreement; it is permanent and never capable of modification. This concept is not consistent with Washington law for the following reasons. Under settled Washington law, a municipality "cannot enter into contracts binding on future boards of commissioners." See State ex. rel. Schlarb v. Smith, 19 Wn.2d 109, 112, 141 P.2d 651 (1943). See also Miller v. City of Port Angeles, 38 Wn.App. 904 (1984) where it is recognized that a local government cannot contract away its police power. It is recognized that this rule must be construed in the context of whether the contract involves its legislature function or its administrative/proprietary function. This issue was considered in some detail in AGO 2012, No. 4, which concluded as follows: If a contract impairs the "core" legislative discretion, eliminating or substantially reducing the discretion future bodies might exercise, the courts are likely to find that the contract has improperly impaired the legislative authority of future commissioners." Moreover, the CA permits deviations from the current city standards. For example, at Paragraphs 14.2 and 15, the CA prohibits the city from collecting impact fees for an additional 300,000 square feet of corporate office development, an indulgence not permitted under existing codes. Similarly, Section XII of the CP-1 zoning allowed deviations from even the then -existing sensitive area ordinances, making it inconsistent with those codes. Indeed, Paragraph 4.1 of the CA (page 5) specifically provides that "to the extent Federal Way policies impose development standards conflicting with this Agreement, this Agreement shall control." Accordingly, the CA, which is claimed to bind all Federal Way councils forever, is ultra vires. It is also important to note that the CA in question is different from contract rezones or other similar legislative actions. These agreements ordinarily set forth what will, or will not, be done on a property as a part of a rezone; in such cases, the work will be completed as a part of the contract rezone. The CA here is not related to any project proposed when it was executed; its sole intention is to limit the authority of the City to take actions in the future and to allow undefined future development. B) Washington Law Regulating Annexation Zoning Ordinances Does Not Permit Ordinances That Last Forever. As a city formed under the Optional Municipal Code (OMC), RCW Title 35, Federal Way must comply with the terms of chapter 35.14 when annexing new territory. June 4, 2018 Page 8 In particular, RCW 35A.14.330 allows an OMC city to prepare a zoning regulation to become effective in an area to be annexed. Subsections (1) and (2) define the scope of a potential pre -annexation zoning, while subsection (4) provides as follows: (4) The time interval following an annexation during which the ordinance or resolution adopting any such proposed regulation, or any part thereof, must remain in effect before it may be amended, supplemented or modified by subsequent ordinance or resolution adopted by the annexing city or town. As described, this legislation allows an OMC city to establish only a "time interval" during which the pre -annexation zoning regulation "must remain in effect." Without such a "time interval," a local legislative authority could amend the interim zoning ordinance at any time, as described above. RCW 35A.14.330(4) plainly requires zoning have a "time interval" during which the pre -annexation zoning will be binding before it may be amended or modified. Nothing in this statute allows the local government to make permanent pre -annexation zoning, any more than zoning adopted pursuant to the planning and zoning chapter of the OMC, chapter 35A.63, could be made permanent. The statute is supported by Washington caselaw regarding the permanency of zoning, as discussed in Bishop v. Town of Houghton, 69 Wn.2d 786, 792, 420 P.2d 368 (1966): We have no quarrel with respondents' basic theme to the effect that while zoning implies a degree of permanency, it is not static and zoning authorities cannot blind themselves to changing conditions. Thus, when conditions surrounding or in relation to a zoned area have so clearly changed as to emphatically call for revisions in zoning, the appropriate zoning authorities are under a duty to initiate proceedings and consider the necessity of pertinent modifications of their zoning ordinances. Otherwise, outmoded zoning regulations can become unreasonable, and the zoning authorities' failure to suitably amend or modify their ordinances can become arbitrary, in which event courts can and should grant appropriate relief. 2 Metzenbaum,-Zoning, 1125 (2d ed. 1955). Land use regulations cannot be frozen in time nor be immune to new priorities, changed circumstances, scientific study or community needs. anebmed iinnstentihhathot--- zoffingordinance tKatnee weury granted to the City of Federal Way and is thus void. June 4, 2018 Page 9 C) The GMA Requires Updating of Development Regulations on a Periodic Basis: The CA Cannot be Immune from the Obligation of Continuing Review. Federal Way is not only subject to the rules established by the OMC, but also to the Growth Management Act, RCW chapter 36.70A (GMA). One of the obligations imposed by the GMA under RCW 36.70A.130 is for continuing review on a periodic basis. Under this statute each local Comprehensive Plan and the local development regulations: shall be subject to continuing review and evaluation by the county or city that adopted them. Except as otherwise provided, a county or city shall take legislative action to review and, if needed, revise its comprehensive land use plan and development regulations to ensure the plan and regulations comply with the requirements of this chapter according to the deadlines in subsections (4) and (5) of this section. (Emphasis supplied.)2 Subsection (1)(c) further states: "(c) The review and evaluation required by this subsection shall include, but is not limited to, consideration of critical area ordinances...." These sections requiring periodic review were imposed by the legislature after the adoption of Federal Way's Ordinance 94-219 in 1994. The provisions are to assure that local government regulations remain current with scientific advancements and needs of the community. In addition, when considering amendment of a comprehensive plan or development regulations, the City is obligated to "establish and broadly disseminate to the public a public participation program identifying procedures providing for early and continuous public participation in the development and amendment of comprehensive land use plans and development regulations implementing such plans." RCW 36.70A.140. As it relates to critical areas, since the adoption of Ordinance 94-219 by the City, new legislation has modified the content of critical area rules. In 1995, the Legislature adopted RCW 36.70A.172, which requires as follows: (1) In designating and protecting critical areas under this chapter, counties and cities shall include the best available science in developing policies and development regulations to protect the functions and values of critical areas. In 2 Use of the word "shall" by the legislature has a distinct meaning in Washington jurisprudence: Moreover, "shall" when used in a statute, is presumptively imperative and creates a mandatory duty unless a contrary legislative intent is shown. Phil. 11 v. Gregoire, 128 Wash.2d 707, 713, 911 P.2d 389 (1996); State v. Krall, 125 Wash.2d 146, 148, 881 P.2d 1040 (1994). Goldmark v. McKenna, 172 W n.2d 568, 575, 259 P.3d 1095, (2011). June 4, 2018 Page 10 addition, counties and cities shall give special consideration to conservation or protection measures necessary to preserve or enhance anadromous fisheries. This section mandated that local governments take account of best available information in adopting critical area regulations, including publications such as "Wetlands in Washington State - Volume 2: Guidance for Protecting and Managing Wetlands." See https://fortress.wa.gov/ecy/publications/summarypages/0506008.html. As noted above, the applicant seeks to opt out of these provisions by reliance on Ordinance 94-219. However, the City has recently adopted Ordinance 15-797, codified as Chapter 19.145 of the Federal Way Code, which regulates Environmentally Critical Areas (ECA) in the City. The purpose of this ordinance is as follows: The purpose of this chapter is to protect the environment, human life, and property from harm and degradation. This is to be achieved by precluding or limiting development in areas where development poses serious or special hazards; by preserving and protecting the quality of drinking water; and by preserving important ecological areas such as steep slopes, streams, lakes and wetlands. The public purposes to be achieved by this chapter include protection of water quality, groundwater recharge, stream flow maintenance, stability of slope areas, wildlife and fisheries habitat maintenance, protection of human life and property and maintenance of natural stormwater storage and filter systems. FWC 19.145.010. FWC 19.145.015 provides as follows: "Except as otherwise established in this chapter, if a proposed development activity requires city approval, this chapter will be implemented and enforced as part of that process." FWC 19.145.020 clarifies its application: "The provisions of this division apply throughout the city and must be complied with regardless of any other conflicting provisions of this title." The provisions of this title that do not conflict with the provisions of this division apply to the subject property. Conflicts with the CP-1 zoning are resolved in favor of the adopted critical area ordinances. Accordingly, the property in the CP-1 zone must be consistent with the revised ECA ordinance; no provision of the current code exempts the CP-1 zone from its application or allows a completely out of date code to be applied in the city. D) The Attempt in the CA to Vest to Future Permit Activity is Inconsistent with Washington Law. In 1987, the Washington Legislature established the rules for vesting of development applications in RCW 19.27.095 and 58.17.033. In this legislation, either a building permit or a plat would vest when a "fully complete application" was made. As noted in Snohomish County v. Pollution Control Hearings Board, 386 P. 3d 1064, 187 June 4, 2018 Page 11 Wash. 2d 346, 105 Wash.2d 778, 789, 719 P.2d 531 (2016): "Washington's vested rights doctrine originated at common law, but is now statutory", citing Town of Woodway v.. Snohomish County, 180 Wn.2d 165, 173 (2014) (emphasis supplied). The applicant here claims that it is vested to 1994 standards by virtue of the CA, but the terms of Washington law do not allow vesting in advance of the filing of a complete building permit or plat application. There was no complete building permit or plat application filed when the CA was agreed to in 1994. Our courts have held that the statutory vesting doctrine only applies when an applicant files "a completed application for a building permit." Potala Village Kirkland, LLC v. City of Kirkland, 183 Wn.App. 191, 334 P.3d 1143 (2014). In Potala, the Court rejected the proposition that an application for a substantial development permit would vest rights against zoning changes. In the present case, the applicant claims the Pre -Annexation Zoning Agreement and the CP-1 Zoning in the CA vest it to development regulations in effect at the time, some twenty-four years ago. But, nowhere has the legislature adopted a rule that allows pre -annexation zoning under RCW 35A.14.330 to vest development rights. The rules established in 1987 codified the vested rights doctrine and limited its application to building permits, plats and later (1995) development agreements. Attempts to vest rights based on this pre -annexation zoning are not effective and any review of the current applications should be consistent with existing land use regulations and controls. 3. CONCLUSION. The applicant's proposals violate basic standards for review. First, with three complete applications on the CP-1 zoned property, Washington law and local ordinances require that project review be consolidated. This applies not only to review for consistency with the city codes, but also SEPA review and analysis. An environmental checklist should be prepared that identifies and reviews the entirety of the three pending applications. This does not present a hardship to the applicant because it has already assembled data for its projects, all that is required is the consolidation of this information. Second, the city should apply current zoning, environmental and critical area ordinances to the three applications. Consideration of the pending applications under twenty-four year old ordinances is completely inconsistent with Washington law that prohibits ordinances that would bind local governments forever, especially in light of the statutory requirement to continually assure that zoning and environmental regulations are updated to take account of the latest standards and considerations. June 4, 2018 Page 12 Thank you far consideration of SWC's views. Please do not hesitate to contact me if you .have any questions. Sincerely, Fu:RU & EusTi , LLP AV--,Vz J. Richard Arambu JRA:cc cc: Save Weyerhaeuser Campus .L~ LSA memorandum date November 30, 2018 5309 Shilshole Avenue, NW Suite 200 Seattle, WA 98107 206.789.9658 phone 206.789.9684 fax to Jim Harris, City of Federal Way Department of Community Development from Jessica Redman and Ilon Logan wwmesassoc,com subject Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park — FINAL At the request of the City of Federal Way (City), Environmental Science Associates (ESA) reviewed the Critical Areas Report and Conceptual Mitigation Plan — Greenline Business Park (dated October 27, 2017) prepared by Talasaea Consultants Inc. for the property at approximately 32901 Weyerhaeuser Way South in Federal Way, Washington. The 146-acre site is a combination of six parcels (King County Tax Parcel Numbers 1621049056, 1521049178, 1621049013, 1621049030, 2285000010, and 7978200420) currently owned by Federal Way Campus, LLC. This property was 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). The current application involves the construction of three new buildings that will provide approximately 1,068,000 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 five 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 Critical Areas Report and Conceptual Mitigation Plan — Greenline Business Park (dated October 27, 2017 and hereinafter referred to as the Report) and the Greenline Business Park Site Plan prepared by ESM Consulting Engineers (dated November 15, 2017). According to the documents, sixty-three wetlands and Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park — FINAL 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. Construction of the three buildings, stormwater facilities, and parking areas would impact 13,428 SF (0.31 acre) of wetlands. Four wetlands would be insufficiently buffered, and therefore are being considered indirectly impacted due to site development encroachments, resulting in an additional 4,912 SF (0.11 acre) of impact. The total 18,340 SF (0.42 acre) of direct and indirect wetland impacts would be mitigated for through 36,023 SF (0.82 acre) of wetland creation and 2,020 SF (0.05) of wetland enhancement. Wetland mitigation will meet and exceed ratios provided in FWRC 19.145.430(5) and will occur onsite in the vicinity of North Lake. In addition, 98,168 SF (2.3 acres) wetland buffer will be created around the area of wetland creation. No work will occur within the ordinary high water of the stream. However, the buffer on the east side of the stream would be reduced by 25 percent (from 100 feet to 75 feet) to accommodate the development. The total stream buffer reduction of 12,545 SF (0.29 acre) will be mitigated for by adding an additional 14,489 SF (0.33 acre) of stream buffer to the west side of the stream. In addition, 94,266 SF (2.2 acres) of the existing and proposed stream buffer will also be enhanced by removing invasive species and subsequently planting native trees and shrubs. Finally, an existing gravel path and berm that occur within the site will be removed and replanted with native trees and shrubs. This will account for approximately 35,689 SF (0.8 acre) of wetland and stream buffer enhancement. Review Comments and Recommendations As documented in our previous review of the Tech Center BLA (memo dated August 22, 2017), we agree with the wetland delineation boundaries, rating forms, and rating classifications established by Talasaea for wetlands occurring on the proposed project site. We generally agree with the conceptual mitigation plan and believe that the proposed mitigation site appears to be an adequate location for wetland creation. As the mitigation design progresses, we strongly recommend that the applicant perform further environmental investigations (groundwater level monitoring, soil analysis, etc.) at the proposed mitigation site to acquire the necessary data and information to inform mitigation feasibility and design. Impacts to wetlands and wetland buffers should be minimized to the extent possible. It appears that in several areas, impacts could be further minimized, if not avoided, by minimal design and layout modifications while still resulting in a viable project. These areas include the following: o The proposed 820 SF of wetland fill in Wetland DE near the southwest corner of Building A; o The proposed filling of Wetland CG and the intrusion into the buffers of Wetland BA and PK, by the construction of Detention Pond 1; o The proposed intrusion of the eastern edge of Detention Pond 2 into the buffer of Wetland AV; o The proposed intrusion of the southeast corner of Detention Pond 3 into the buffer of Wetland BR; o The proposed intrusion of the western edge of Detention Pond 4 into the buffer of Wetland AH; o The proposed intrusion of the southwest corner of Building B into the buffer of Stream AC. 2 Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park — FINAL We recommend the current design and layout, which results in the proposed impacts to wetlands and wetland buffers, is reevaluated for the areas described above and included in the mitigation sequencing process. ■ The City considers grading within a wetland buffer to be development, and therefore, 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. Additionally, the applicant shall demonstrate that temporary buffer impacts have been avoided or minimized to the extent possible, per FWRC 19.145.130. Temporary buffer impacts should also be included on the figures in the Report. • The wetland buffers on the Site Plan are inconsistent with the wetland buffers on the figures in the Report. For example, buffers for Wetlands BA-2, PK, and BB appear larger on the Site Plan than on Figure WI.1 in the Report. The Site Plan should be revised to reflect the buffers presented in the Report. • 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. Site Plan sheets should be revised to show post -development buffers and an existing conditions figure should be added to the Site Plan. • We recommend the ordinary high water mark (OHWM) of North Lake, within the project area, be delineated in order to accurately calculate and assess proposed impacts and activities in the shoreline. • If the proposed mitigation area or any other development is within 200 feet of the OHWM of North Lake, then shoreline review is triggered under FWRC 15.05 — Shoreline Management. We recommend Section 6 — Regulatory Review of the Report be revised to include all required permits. ■ Referring to Figure WI.3 of the Report, it appears that buffer creation is proposed in the existing buffer of Wetlands BB and BD North. This area cannot be considered as new buffer and the Report and figures should be revised to reflect any changes. • The areas shown as buffer creation and wetland creation areas on Figures W 1.3 and W3.1 of the Report are inconsistent. Areas of the mitigation area between the southern end of Wetland BB and the northern end of Wetland BD North are shown as wetland buffer creation on Figure W 1.3 and shown as emergent and scrub -shrub wetland creation, as well as buffer enhancement, on Figure W3.1. We recommend the figures be revised to show the correct proposed mitigation actions, consistently across all relevant Report figures. 4 A 10-foot wide sewer easement runs through the proposed mitigation area. The sewer was installed approximately 18 years ago along with its corresponding impact mitigation area, which is apparently located north of the existing boat launch access. Future application materials should show this area of previous mitigation so that it is clear the area is not included within the current mitigation proposal. A portion of the buffer enhancement area on Figure W3.1 of the Report encroaches into the existing sewer easement. This area should be removed from the mitigation calculations. Some planting will be allowed within the terms of the easement agreement, but this area cannot be secured in perpetuity as mitigation for the Greenline Business Park wetland impacts. Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park — FINAL ■ Within the mitigation area, some portions of the wetland creation areas that are closest to the sewer easement, will have less than a 25-foot buffer. The wetland creation area should be relocated or reconfigured so that it can be adequately buffered. MCCULLOUGH HILL LEAKY, PS SEP 1 1 2018 September 10, 2018 CITY OF FE0£PA. WAY GOMMUNI7Y DEVELOPMENT VIA ELECTRONIC MAIL Marwan Salloum, P.E. Public Works Director City of Federal Way 33325 8th Ave. S. Federal Way, WA 98003 Re: Request for Impact Fee Credit Dear Mr. Salloum: We represent Federal Way Campus LLC ("Applicant"), the developer of the project known as the Greenhne Business Park ("Project") and owner of the property on which the Project is located C`Property" ). Pursuant to Federal Way Municipal Code ("City Code" or "FWMC"} 19.91.090, the Applicant seeks an Impact Fee Credit. The credit sought is for the dedication of land for the future extension of S. 320' Street. This project is identified in the rate study as the basis for calculating the impact fee. The legal description of the land to be dedicated is attached as Exhibit A. The Applicant will not provide improvements in connection with the extension of S. 324"' Street so no credit is sought for improvements. The Applicant requests that this credit be applied to impact fees due in connection with development of the Greenline Business Park project ((File Nos. 17-105489- 00-UP & 17-105490-00-SE). This claim is timely because no impact -fee has yet been paid and no building permit or change in use permit has yet been issued for this project. Sincerely, � o n C. McCullough cc: Mark Orthmann Client 701 Fifth Avenue • Suite 6600 • Seattle, Washington 98104 •206.812.3388 • Fax 206.812.3389 • www.mhseattle.com Greenline Business Park Job No.1886-001-016 July 5, 2018 _C0NSULTIN0 ENGINEERS L L C EXHIBIT A LEGAL DESCRIPTION The north 106 feet of Lot 2 of City of Federal Way Boundary Line Adjustment No. 17- 100455-SU as recorded under Recording No. 20171108900002, situate in the northeast quarter of Section 16, Township 21 North, Range 4 East, W.M., City of Federal Way, IGng County, Washington. Containing 222,640 square feet, (5.111 acres), more or less. Written By: CAF 11esm8%engAesm-jobs11886100110161documenttld-008.doc fe V -07-0/ 33400 Bth Ave S. Ste 205 Tel (253) 830 6113 Everett (425) 297 9900 I cn Fng!neenn9 Land Pl z11 nina Federal Way. WA 98003 Fax (253) 838 7104 Toll Free (800) 3455694 l cnd sur;ey•,g Lams.-,3P r` cn:,zcura www.esmclvlL.com Lasar F,,, ��inq ri3 CITY or - Federal Way MODIFIED NOTICE OF MASTER LAND USE APPLICATION *Updated To Eliminate Initial Public Comment Deadline - Written Comments May Be Submitted As Specified Below* Project Name: Greenline Business Park Project Description: Construction of three buildings totaling approximately 1,068,000 square feet, five new stormwater ponds, revisions to existing parking lot and addition of approximately 806 parking stalls, filling approximately 13,500 square feet of wetlands, roadway improvements, and associated site improvements on 146 acres. Applicant: Federal Way Campus, LLC, 11100 Santa Monica Blvd, Suite 850, Los Angeles, CA 90025 Agent: ESM Consulting Engineers, LLC, 33400 8a' Avenue South, Suite 205, Federal Way, WA 98003 Project Location: Approximately 329XX Weyerhaeuser Way South, Federal Way, WA, King County Parcels 162104-9056, -9013, -9030 and 152104-9178 Date of Application: November 14, 2017 Date Determined Complete: May 14, 2018 Date of Notice of Application: May 18, 2018 Date of Modified Notice of Application: July 13, 2018 Requested Decision and Other Permits Included with this Application: The applicant requests a Use Process IV Hearing Examiner decision (File #17-105489-UP) pursuant to Federal Way Revised Code (FWRC) Chapter 19.70. Additional permits and/or approvals in conjunction with the Use Process IV decision include a threshold determination pursuant to State Environmental Policy Act (SEPA) Rules WAC 197-11 (File #17- 105490-SE), Transportation Concurrency (File #17-105491-CN), Boundary Line Adjustment (File #18- 100123-SU), and Forest Practices Class IV General Permit. Environmental Documents: Environmental Checklist, Wetland Report and Conceptual Mitigation Plan, Visual Impact Exhibit, Geotechnical Report, Transportation Impact Analysis, Pavement Analysis, Parking Study, Stormwater Technical Information Report, Air Quality Report, Environmental Noise Report, Cultural Resources Study, Evaluation of Trees. Development Regulations to Be Used for Project Mitigation: Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement and applicable 1994 development codes, including Federal Way City Code (FWCC) Chapter 18, "Environmental Protection"; Chapter 20, "Subdivisions"; Chapter 21, "Surface and Stormwater Management"; and Chapter 22, "Zoning." Consistency with Applicable City Plans and Regulations: The project will be reviewed for consistency with all applicable codes and regulations including the Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement, which vests the project to regulations in place in 1994; FWRC 19.145; 2016 King County Surface Water Design Manual as amended by the City of Federal Way; and the Public Works Department Development Standards. Any procedural requirements must meet today's codes (FWRC Title 19). Public Comment & Appeals: The official project file is available for public review at the Community Development Department (City Hall, 2nd Floor, 33325 8d' Avenue South, Federal Way, WA 98003). Any person may submit written comments to City staff or the Hearing Examiner and may appear at the public hearing of the Hearing Examiner to give comments orally. Any person may submit written comments to the Hearing Examiner by delivering these comments to the Department of Community Development prior to the public hearing date (which has yet to be determined) or by giving these directly to the Hearing Examiner at the public hearing. Only the applicant, persons who submit written or oral comments to the Hearing Examiner, or persons who specifically request a copy of the written decision may appeal the Hearing Examiner's decision. Details of the appeal procedures for the requested land use decision will be included with the written decision. Comments sent by email should be directed to planning &cityoffederalway.cotm. Availability of File and Environmental Documents: The official project file and referenced environmental documents are available for public review during normal business hours at the Community Development Department (address above) or on the City's FTP site at ftp://ftp.ci tyoffederalwa y.com/Outfox/Green 1 ine%fl2OSubmittal%20Documents/Business%20Park/ Staff Contact: Planner Jim Harris, 253-835-2652, jim.harris@cityoffederalway.com Printed in the Federal Way Mirror July 13, 2018. r1h geoAdvantage: King County of Washington State (App3) Page 1 of 1 C - P 3a "tip �I http://geo.sentrydynamics.net/wa—king/Default.aspx 8/11/2017 N N N N N N N N N N N N N N N N W lD lD l0 W (D W W (D W W W In W W W O O O O O O O O O -P� A -P- A 4 O, O1 f71 O, Dl Ql O, Ol Ql Ol Q1 Q1 Ql Dl Dl Q1 O O O O O O O O O m m O M W W W O O O O O O O O O O O O O O O O V V V F- O O O O O O O O F-- F, F" lD Ol W N O lD P- I--' O m W W P" w V m W W O O W W W O W O O O O O O O 0 > m n m G) m (D N O (D 0 O (D S (D A A F- I -A m m m m m O O W W W W W A 0 0 0 0 0 lD lD I-" A NJ F" O w O m O O O O O F-+ V p z n= x �o= K = m m E m m m m m 0 w 0 = w O O w iU rD W W W m S C C `01' `0�' 3 Q- E Q W N r+ r+ rr r+ in r+ 3 ID (p n SUQcn ofCL a N O O1 Ol N 01 v 0 3 QC — O CG 3 O 3 n (D Ln rD C C C C C (n (n (n (n (n (n p n n W n n n n to O v O O O O r n O a O r O O 3 O O O O n L' d r- w v d w r+ r o n m u o D L v -0 -0(n N w ni w N X, X,77X-X- N w In W N P. W W W m w I -A 1-1 F" O w W O F- A O LO A A w F" V F, NJ N N N O w (n l0 w I-, W w m W F" N w O O O O O, O 0U N Nil N 00 I--' O N O W F-' 1- F-' F' F" W N W 0 r O N m U, W W O 0 N '+ d N w r N N M Z F--� Gl G1 N d X W ,..F G n n n (, lD w Z n r+ w 3 m o, _ N<< O_ 0 << M W< j<< D D rt N (D m rNr �' Ln to W r++ (D m m m m N Ln rn N N m r+ 1+ -r r+ -a [7 p < m m m (D m O F+ W A � OO m O O O C)3 W O O O O N O N � N W �_; F; N F; �_; F; �-+ �-i -0 W W W W W In W W W W N N N N N N N N N N n O O O O O O O O O O — LO kDD Lo w Lo LDD kDD kDD Lo w p L F" F- P" O O O O O W 4�- A .4- N W W W N N W W N I-- W N V O M N K= p p r cG D r r O O O m m lu (D - ni � � 3 3 3 3 (D 3 m O_ m (D 3 O In' �' •< Z 3 T m m nr N O1 v , O rD N m 3 In (A Q O Q Q- 3 S C l�if n 3 m ((n m m o w+ (n (mD m 3 C fD (D _ (D N O i3 3 cu O z 3 M rr 6 O OkD 2 n kD O m 3 3 _ O r p v 00 ~ Q0 < 3 lu T n I� (D m r* < o O s Ln �+ ", o Qo 3 n O m m n 3 � h (Art - (n Cl. p C r ni m n -0 w-0 m N W w W w W N w W-0 Q O ry p 0 M W 00 M N W A W N ry Q N O N m O O V O W N V m OJj Lo O n F+ A lD lD O O W l�D lND OW rD X X Ol D Ln N N Lnx - �D F, 3 r" w w w w w F, w w N D CL V '< V N L W CNi, 000 w S s W O- V (D rn CLA < s� y s s O- D y w r+ m NLn r (<D h < rD (<D m Z (^ N (D to W N I W m F- rn rD W N T -nW m m-0 -m m m W 7C D —i - -nm m� p D M D D D m T� D m D O M m wm rD =- m (D m m �' C CU CU nU C C� m m m C m C� Q Q ;:P0 O_ Q 0 Q O_ O_ = 7� n n n n 0-0_ Q n `G 3 0_ s a CrO_ Q- 3 Cr CL O- m m m m m m m m m O O O O O m m m O 3 rD m O O m m r+ O m O 3 r < N m Ol Ol � Ol O1 X• w w N 0 Q W w w w w N T N d �_, N 3 3 3 6) 3 N 3 n `G n * * * * * m `G * `G `< `G `G � v c, c, c, a) v v r„ Iv ED v v lu ED Z DD DD DDDD DDDDDDDDDDDDDDDDDD O D N D 0 D D m W N r+ OJ rD m 0 lD lD 00 lO lD lD 00 lD lD lD lO lD 00 lO lD lD lD lD w lD w W W W lD w w w w w w w w 3 O O F- WOO 00 0 0 0 0 0 4�- ? 4:- AOO O A WOO 00 O O O O O O O N O O In In O 04�- O O O O W F- O O O O m O 0 0 0 ry 0 0 0 0 0 A 0 0 V _ W W 0 M W W 4�. W W W A W 4::. N N N N W W F- h- F- A W F-' F� N F- F- N I-' F- P" V V V V V A A A A A N N N N N N N N N N N N N N N N N N N N N N N N N A A A A A N N N F, F, F, I-, N F, F, F, F, F, F, F, F, F, D1 01 Q1 Ol Ol N N N N N N N N W W W W W lD lD W W W w w w w w w w O O O O O F, F, F, F, F, I-, F, F, F, I-, F, I-, F, F, F, F, I-, O O O O O O O O O O O O O A A A O O O O O O O O O O O O O O O O O O O O O O O O O O O w w w O O O O O O O O O O O O O O F, O O F, O O O O O O O O O O O O 00 00 V V V V F, F, 0 0 0 0 0 0 Lm w 00 O M Lm Lm W W N F, F, O A W O N F, N N F, O N O W W Ln A W O O U'I A LM O F, O w O w w O w O F, m O O O Ln O w O O O w nN O w w O Ui O K K K W K M on .< on W= < ,(D< rD s s ET 0 77 O d m m m Q s as a, cu a Di rD (D m r D D D T r r r z Gl G1 fl 2 01 n� 7 7 v+ to in S 01 Gl < rD O o c, a O ou O O Q Q rD Q N '+ '+ W ,c Di a rD m 0 h < C C In rrt to O O to ti 7 3 O Gi S r F rF 3 r F Q. Q (D (D N (a 7 Q S (� aQ (D O O < < `< `< fD (D v O 0) O a.-r° aq °rr° r* v+ v+ (n (A (A 'O O 0 m o < O < rD (A :3C 7 c 3 3 LO Ln ri rD imrD -n rD O C ou c s ('i sz z O_ CL cn E90 (+ c O ((D rD = ao O s i 3 v - < m H h < 6 n O -O r r r _ rD (D O_ < O W r+ W -o W W W A W W A W -0-0 N W W W W W W W W W W W W W Q) Ul W N A p F, F, F, N w F, N F, p p O A A A A A A A A A A A A A 0) O A lD O F, F, w Ln O O W I, A 00 00 00 00 00 00 00 00 00 00 00 00 00 00 O Ul Do 00 00 V a) a) 0o W W F, N N N N F, O F' F, N N N N fV rD 0mj O m N O x LA N 00 . N N N 00 O Ln F, F, V F, U7 Cn A A O 00 W LD F, — �n 1,f1 N W l0 W W O1 rD W W rD W V 00 N V V V V V V V V V V 00 00 00 V) Z lD w W V W W , Ln N W N W V O r+ r+ r+ r+ r+ r+ r+ r+ r+ r-r r+ r+ r+ O r+ M V r+ r+ rVr S r+ j rVr + rV+ F' Q S S S S S S S S S S S S D S h s s s D Q s D D D D D D D D D N D D D D r D N N N < Q (n Q N < < < < < < < < < < < < < W < N r+ r+ r+ rD T rN+ r+ T r-r (D (D (D rD rD U7 (D rD (D (D rD (D rD M rD (D r+ (A � � N (n U7 Ln U9 Ln kn Ln Ln U9 V7 3 cn GC O C "O 4* r+ (D N S O 3 N N N Ln T T T T m (n m m N m n T 7C m m m m m m m m T -n T D -n N to TI TI (D rD (D (D fD rD fD rD (D rD 0J (D rD fD (D fD (D (D rD (D rD fD (D (D � fD rD 07 (D rD O_ i1 Q O_ O_ W Q O_ W CL Q 7 IZ Q Q Q Q Q Q. O_ r1 CL Q Cr IZ W r* O_ 0- 0C] a) GCJ 6C1 0CC] (D GC7 NC_ (D 007 0) OCC) 0CC) w NC_ NC_ w cu NC_ NCC 0CC1 NC_ 0CC) aLID (D 0CC7 6CC7 G C < < G < G < Q < G < G < G G G < G G G G [7 G G 07 Ol N w w 0J 01 0) w w O) w w w w w w d w w 0J w 07 :E * * * * * ::E * * * D * * * * * * * * * * * * * * * * C * � D D D D D D D D D D D D D D D D D D D D D D D D D D D D lD l0 lD lD lD lD lD lD lD lD lD lD l0 tD lD lD lD lD lD lD lD lD lD V7 lD lD lD Oo lD lD 00 00 00 00 00 00 00 00 00 00 N 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 00 A 00 00 O m O O N 0 0 0 0 0 F, m W O O O O fv 0 0 0 0 0 0 0 0 N Ul O O W W I-, F, W F, F, F, F, F, m W N W W W W W W W W W W W N W F, 0 W W Gilles Consulting Brian K. Gilles 4 2 5 - 8 2 2 - 4 9 9 4 EVALUATION OF TREES AT GREENLINE BUSINESS PARK Weyerhaeuser Way South Federal Way, WA September 20, 2017 PREPARED FOR: Federal Way Campus, LLC Attn: Tom Messmer 11100 Santa Monica Boulevard Los Angeles, CA 90025 R PREPARED BY: GILLES CONSULTING �'� ov r ko Brian K. Gilles, Consulting Arborist CITY OF FFGra� ISA Certified Arborist # PN-0260A eoMMUNrrY nEvELON, ASCA Registered Consulting Arborist # RCA-418 ISA TRAQ Qualified ISA TR,4Q Certified Instructor PACIIc NORTNWSST 4D 0 �CN..TS. ,�• VMI :r = eW I Ry4: CERTIFIED opit ; . ARBORIST fax: 425-822-6314 email: bkgilles@comcast.net P.O. Box 2366 Kirkland, WA 98083 Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 2 of 23 CONTENTS ASSIGNMENT.................................................................................................................. 3 SCOPEAND METHODOLOGY................................................................................... 3 Evaluation of Trees & Status Determination................................................................ . . 3 AdditionalTesting......................................................................................................... 4 Failure........................................................................................................... ....... I ......... 4 OBSERVATIONS............................................................................................................. 4 Small Native Trees/Small Shrubs Observed................................................................... 4 Low Growing Native Shrubs and Ground Covers Observed: ................ ....................... 4 InvasiveSpecies Observed: ............................................................................................ 5 TreeData......................................................................................................................... 5 DISCUSSION.................................................................................................................... 6 RequiredTree Retention................................................................................. .. .. . . ... ...... 6 Tree Protection Measures..........................................................................................---.. 6 Habitat Tree, Nurse Log, and Brush Pile Creation and Benefits .................................... 7 WAIVEROF LIABILITY............................................................................................... 7 ATTACHMENTS............................................................................................................. 9 Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 3 of 23 ASSIGNMENT Tom Messmer, of the Federal Way Campus LLC, contracted with Gilles Consulting to develop this report of the trees at the Greenline Business Park property on Weyerhaeuser Way South in Federal Way, Washington. In compliance with the Concomitant Pre - Annexation Zoning Agreement, dated August 23, 1994, between the Weyerhaeuser Company and the City of Federal Way, the 1994 definitions of "significant trees" was utilized to measure and evaluate the condition of the trees on the property. Note: A Management Plan for the Managed Forest Buffer for the Greenline Business Park Project Site is under a separate report. While the trees and general description of the Managed Forest Buffer is included here, the management plan is separate. SCOPE AND METHODOLOGY Evaluation of Trees & Status Determination First, an inventory of the existing vegetation of the property was conducted by creating a number of transects on the property, then using this data and aerial photographs to extrapolate the tree count to the entire site. In each transect this included documenting the species present, their relative size, and their condition. Each tree was tagged with a unique number and its trunk measured at 4.5 feet above the average ground level to determine diameter, (DBH). Current Federal Way City Code defines Significant Tree is a tree that is: 1) Eight inches in diameter or greater measured four and one-half feet above the ground; and 2) In good health and structure; and 3) Not a hazard or otherwise detrimental to the community (e.g. is not diseased, dying, or likely of falling into public open space or right-of-way, etc.) or obscuring safe sight distance requirements. Using FWCC Standards, calculations for tree retention were calculated and a Tree Retention Plan has been included in the permit documents, but not as a part of this Tree Evaluation Report or the Managed Forest Buffer Management Plan. This is because all of the trees in the MFB are to be retained —unless they pose a threat to life and property. These retained trees shall be protected as defined in the Tree Protection Measures section below. Trees were also evaluated for risk to determine whether or not any of the trees proposed for retention pose an unacceptable level of risk to life and property. The goal was to identify any potential hazard trees and manage them down to a safe level during clearing and grading phases of the project. We followed the protocol of the International Society of Arboriculture known as Tree Risk Assessment Qualification, TRAQ. This is a scientifically based process that includes a roots to shoots evaluation of each tree to Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 4 of 23 determine health, structural stability, and likelihood of failure. Trees were then rated as Significant or Non -Significant based upon criteria above and the size of their trunk at 4.5 feet as measured with a diameter tape measure. Additional Testing The trees all presented signs and/or symptoms that were readily discernible using the visual tree evaluation system of a Level II risk assessment. These signs and/or symptoms indicate extensive internal decay and/or structural defects in some trees and solid trunks and lack of disease in others. Therefore, no additional tests were performed during these site visits. Failure While no one can predict with absolute certainty which trees will or will not fail, we can, by using this scientific process, assess which trees are most likely to fail and take appropriate action to minimize injury and damage. OBSERVATIONS The property of the Greenline Business Park is located in the north end of the campus between Interstate 5 and Weyerhaeuser Way South. The forest community is very complex. While the understory shrub and ground cover layer are typical of lowland Puget Sound Forests, the tree canopy is complex due to the existing buildings, associated parking lots, as well as the forest areas having had management in the past to very different goals and objectives. As noted above, the shrub and ground cover layers consisted of plants typical of lowland Puget Sound. Plants observed include: Small Native Trees/Small Shrubs Observed Vine Maple, Acer circinatum • Western Hazelnut, Corylus cornuta • Indian Plum, Oemleria cerasiformis • They are all in Fair to Excellent Condition. Low Growing Native Shrubs and Ground Covers Observed: + Salal, Gaultheria shallon Trailing Blackberry, Rubus ursinus + Snowberry, Symphoricarpos albs 0 Oregon Grape, Mahonia nervosa Brecken Fern, Pteridium aquilinum ® They are all in Fair to Very Good Condition. Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 5 of 23 Invasive Species Observed: ■ Himalayan Blackberry, Rubus armeniacus • English Ivy, Hedera helix ■ English Holly, Ilex aquifolium. • While small in number they appear healthy at this time. Tree Data Tree species in this area of the campus are very different than previous parcels reviewed. Along with the native species, there are many landscape species that were introduced as part of landscape plans around buildings and parking lots. Tree observed on site include: Blue Atlas Cedar, Cedrus atlantica Black Cottonwood, Po ulus trichocarpa Big Leaf Maple, Acer macro h lum Cascara, Rhamnus purshiana Coast Redwood, Sequoia sem erwrens Deodar Cedar, Cedrus deodara Douglas Fir, Pseudotsu a menziezii European Beech, Fagus sylwtica European Hazelnut (Filbert), Co us avellana European Mountain Ash, Sorbus aucu ria Flowedng Cherry, Prunus sp. Fruiting Cherry, Prunus s . Green Ash, Fraxinus pennsylvanica Japanese Maple, Acer palmatum Large Leaf Linden, Tilia /at h los Mountain Ash, Sorbus americana Noble Fir, Abies pTcera Norway Maple, Acer platanoides Oregon Ash, Fraxinus latifolia Pacific Dogwood, Comus nuttallii Pacific Madrone, Arbutus menziesii Pacific Willow, Salix lasiandra Red Alder, Alnus rubra Sweet um, Li uidambar styraciflua Silver Maple, Acer saccharinum Scouler Willow, Salix scouleriana Vine Maple, Acer circinatum Weeping Katsura, Cercidi h /um 'a onicum 'Pendula' Westem Larch (Tamarack), Larix occidentalis White Oak, Quercus alba Westem Red Cedar, Thuja plicata In an effort to present the information and conclusions for each tree in a manner that is clear and easy to understand, as well as to save paper, I have included a detailed Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 6 of 23 spreadsheet, Attachment Z Tree Invenlo /Condition S readsheet. All the same information from the ISA Tree Hazard Form is included in this spreadsheet and the attached glossary. The descriptions on the spreadsheet were left brief in order to include as much pertinent information as possible and to make the report manageable. The attached glossary provides a detailed description of the terms used in the spreadsheet and in this report. It can be found in Attachment 3. Glossary. A brief review of these terms and descriptions will enable the reader to rapidly move through the spreadsheet and better understand the information. DISCUSSION Required Tree Retention Retention of course, needs to take into account the location of the trees and the location of the proposed improvements. However, strongly advocate retaining as many more trees as possible over the minimum required if development allows. This affords significant flexibility during construction when unforeseen circumstances and events require the removal of trees that were at first planned for retention. If there is a bank of extra Significant Trees somewhere else on the property they can be switched out with a tree or more that needs to be removed unexpectedly. Tree Count Data for Greenline Business Park: The trees on the entire 146 acre site can be summarized as follows: TREE COUNTAND RETENTION AT GREENUNE BUSINESS PARK #of Signifiant Trees on site: 4,182 #of Significant Trees in the Managed Forest Buffer: 175 Average # of Significant Trees per Acre: 28.64 (4182 / 146 = 28.64) #of Significant Trees in the undisturbed areas: 1736 Total Significant Tree Retention Rate: I 41.50•� (1736/4182=0.415) Tree Protection Measures In order for trees to survive the stresses placed upon them in the construction process, tree protection must be planned in advance of equipment arrival on site. If tree protection is not planned integral with the design and layout of the project, the trees will suffer needlessly and possibly die. With proper preparation, often costing little or nothing extra to the project budget, trees can survive and thrive after construction. This is critical for tree survival because damage prevention is the single most effective treatment for trees on construction sites. Once trees are damaged, the treatment options available are limited. Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 7 of 23 The minimum Tree Protection Measures in Attachment 4, Tree Protection Measures are on three separate sheets that can be copied and introduced into all relevant documents such as site plans, permit applications and conditions of approval, and bid documents so that everyone involved is aware of the requirements. These Tree Protection Measures are intended to be generic in nature. They will need to be adjusted to the specific circumstances of your site that takes into account the location of improvements and the locations of the trees. Habitat Tree. Nurse Log, and Brush Pile Creation and Benefits When trees need to be managed to reduce potential danger to life and property, it is recommended that they be converted to Habitat Trees, Nurse Logs, and Brush piles to benefit desirable wildlife. • Habitat Trees, are standing trees, dead or alive, that are short enough that they will not impact a target when the eventually do fall. ■ Nurse Logs, are portions of tree trunks lain on the ground. They can be lain across a slope to minimize erosion and provide microclimates for wildlife and replanting of trees and shrubs. ■ Brush Piles, are stakes of branches and twigs to provide essential cover for desirable wildlife. Please refer to Attachment S, Habitat Tree, Nurse Log, and Brush Pile Creation and Benefits for important information about these critical urban/suburban elements. WAIVER OF LIABILITY There are many conditions affecting a tree's health and stability, which may be present and cannot be ascertained, such as, root rot, previous or unexposed construction damage, internal cracks, stem rot and more which may be hidden. Changes in circumstances and conditions can also cause a rapid deterioration of a tree's health and stability. Adverse weather conditions can dramatically affect the health and safety of a tree in a very short amount of time. While I have used every reasonable means to examine these trees, this evaluation represents my opinion of the tree health at this point in time. These findings do not guarantee future safety nor are they predictions of future events. The tree evaluation consists of an external visual inspection of an individual tree's root flare, trunk, and canopy from the ground only unless otherwise specified. The inspection may also consist of taking trunk or root soundings for sound comparisons to aid the evaluator in determining the possible extent of decay within a tree. Soundings are only an aid to the evaluation process and do not replace the use of other more sophisticated diagnostic tools for determining the extent of decay within a tree. As conditions change, it is the responsibility of the property owners to schedule additional site visits by the necessary professionals to ensure that the long-term success Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 8 of 23 of the project is ensured. It is the responsibility of the property owner to obtain all required permits from city, county, state, or federal agencies. It is the responsibility of the property owner to comply with all applicable laws, regulations, and permit conditions. If there is a homeowners association, it is the responsibility of the property owner to comply with all Codes, Covenants, and Restrictions (CC&R's) that apply to tree pruning and tree removal. This tree evaluation is to be used to inform and guide the client in the management of their trees. This in no way implies that the evaluator is responsible for performing recommended actions or using other methods or tools to further determine the extent of internal tree problems without written authorization from the client. Furthermore, the evaluator in no way holds that the opinions and recommendations are the only actions required to insure that the tree will not fail. A second opinion is recommended. The client shall hold the evaluator harmless for any and all injuries or damages incurred if the evaluator's recommendations are not followed or for acts of nature beyond the evaluator's reasonable expectations, such as severe winds, excessive rains, heavy snow loads, etc. This report and all attachments, enclosures, and references, are confidential and are for the use of the client concerned. They may not be reproduced, used in any way, or disseminated in any form without the prior consent of the client concerned and Gilles Consulting. Thank you for calling Gilles Consulting for your arboricultural needs. Sincerely, 8u,��, # Brian K. Gilles, Consulting Arborist ISA Certified Arborist # PN-0260A ASCA Registered Consulting Arborist # RCA-418 ISA TRAQ Qualified ISA TRAQ Certified Instructor Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 9 of 23 ATTACHMENTS ATTACHMENT 1 - VEGETATION MAP.............................................................. ---.-- 10 ATTACHMENT 2 - TREE INVENTORY/CONDITIONS SPREADSHEET ................ 12 ATTACHMENT3 - GLOSSARY.................................................................................... 13 ATTACHMENT 4 - TREE PROTECTION MEASURES .............................................. 14 ATTACHMENT 5 - HABITAT TREE, NURSE LOG, BRUSH PILE CREATION AND BENEFITS........................................................................................................................ 19 ATTACHMENT 6 - BIBLIOGRAPHY........................................................................... 22 ATTACHMENT 1- VEGETATION MAP Prepared by Talasaea Consultants staff. VESCTAT I Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 10 of 23 CAZAPHIG SCALE [ IN PEST) Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 11 of 23 IF.—OrETATI ON T I P�! Lr=0t -'.:N L"; VC-GETATION TYPO ra -r4 %*. rR r =r r,.r [� rt�.al. sue. P1t 1~+rid�+l TAIL � fd� fl!r uHr Lo-w Na) PLAffM IN fWMs HI&V MZAMAb Fi l t "xlAc P. [cam, A-@4R MV Al- VM MET iOFE-5 r 11 1 Ke-wm PArzr=I% Un scsm rApr v, un Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 12 of 23 ATTACHMENT 2 - TREE INVENTORY/CONDITIONS SPREADSHEET In an effort to make the report formatting easier to manage, the spreadsheet is provided as a separate document. Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 13 of 23 ATTACHMENT 3 - GLOSSARY Terms Used in This Report, on the Tree Condition / Inventory Spreadsheet, and Their Significance In an effort to clearly present the information for each tree in a manner that facilitates the reader's ability to understand the conclusions I have drawn for each tree, I have collected the information in a spreadsheet format. This spreadsheet was developed by Gilles Consulting based upon the Tree Risk Assessment in Urban Areas and the Urban/Rural Interface course manual and the Tree Risk Assessment Form, both sponsored by the Pacific Northwest Chapter of the International Society of Arboriculture, and the Hazard Tree Evaluation Form from the book, The Evaluation of Hazard Trees in Urban Areas, by Matheny and Clarke. The descriptions were left brief on the spreadsheet in an effort to include as much pertinent information as possible, to make the report manageable, and to avoid boring the reader with infinite levels of detail. However, a review of these terms and descriptions will allow the reader to rapidly move through the report and understand the information. 1) TREE LOCATION Relative placement of the tree. 2) TREE #-the unique tag number of each tree. 3) SPECIES —this describes the species of each tree with both most readily accepted common name and the officially accepted scientific name. 4) DBH—Diameter Breast Height. This is the standard measurement of trees taken at 4.5 feet above the average ground level of the tree base. i) Occasionally it is not practical to measure a tree at 4.5 feet above the ground. The most representative area of the trunk near 4.5 feet is then measured and noted on the spreadsheet. For instance, a tree that forks at 4.5 feet can have an unusually large swelling at that point. The measurement is taken below the swelling and noted, e.g. `28.4" at 36"'. ii) Trees with multiple stems are listed as a "clump of x," with x being the number of trunks in the clump. Measurements may be given as an average of all the trunks, or individual measurements for each trunk may be listed. (1) Every effort is made to distinguish between a single tree with multiple stems and several trees growing close together at the bases. 5) GREATER THAN 8" DBH: is the DBH 8.0 inches or greater. 6) STATUS —Based upon the Federal Way Code a tree is Significant if it is 8 inches or more measured at 4.5 feet above the average ground level, is healthy, structurally sound, and does not pose a threat to the public. Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way�WA Gilles Consulting September 20, 2017 Page 14 of 23 ATTACHMENT 4 - TREE PROTECTION MEASURES In order for trees to survive the stresses placed upon them in the construction process, tree protection must be planned in advance of equipment arrival on site. If tree protection is not planned integral with the design and layout of the project, the trees will suffer needlessly and will possibly die. With proper preparation, often costing little, or nothing extra to the project budget, trees can survive and thrive after construction. This is critical for tree survival because damage prevention is the single most effective treatment for trees on construction sites. Once trees are damaged, the treatment options available are limited. The following minimum Tree Protection Measures are included on three separate sheets so that they can be copied and introduced into all relevant documents such as site plans, permit applications and conditions of approval, and bid documents so that everyone involved is aware of the requirements. These Tree Protection Measures are intended to be generic in nature. They will need to be adjusted to the specific circumstances of your site that takes into account the location of improvements and the locations of the trees. Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 15 of 23 TREE PROTECTION MEASURES Tree Protection Fencing: a. Tree Protection Fences will need to be placed around each tree or group of trees to be retained. i. Tree Protection Fences are to be placed according to the approved limits of clearing. ii. The area inside the fences is the Tree Protection Zone. iii. The area outside the fences is the development zone or the construction zone. iv. Tree Protection Fences must be inspected prior to the beginning of any clearing, grading, or construction work activities. v. Nothing must be parked or stored within the Tree Protection Fences —no equipment, vehicles, soil, debris, or construction supplies of any sorts. b. Signs: i. The Tree Protection Fences need to be clearly marked with the following or similar text in four inch or larger letters: "TREE PROTECTION FENCE DO NOT ENTER THIS AREA DO NOT PARK OR STORE MATERIALS WITHIN THE PROTECTION AREA Any questions, call Federal Way Code Compliance at: 253 835-2617 or h:Hcitvoffederalway.coiii/iiode/17 2. Cement Trucks: a. Cement trucks must not be allowed to deposit waste or wash out materials from their trucks within the Tree Protection Fences. 3. Canopy Pruning: a. The canopies of the edge trees may need to properly pruned to allow building and construction clearance. b. The pruning must be done by an International Society of Arboriculture, (ISA) Certified Arborist using current industry standard pruning techniques. (ANSI A300 Pruning Standards and ANSI Z131.1 Safety Standards as well as all OSHA, WISHA, and local standards must be followed.) Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 16 of 23 c. The pruning as much as possible should be done from a lift truck to allow tip pruning and he smallest cuts possible or by using clean climbing techniques. If a lift truck is not practical, an ISA-Certified Arborist using clean climbing techniques must be utilized. d. Plant debris can be chipped and utilized on site for the mulch under the preserved/retained trees. Excavation: a. When excavation occurs within the driplines of trees that are scheduled for retention, the following procedure must be followed to protect the long term survivability of the tree: b. An International Society of Arboriculture, (ISA) Certified Arborist must be working with all equipment operators. i. The Certified Arborist should be outfitted with a shovel, hand pruners, a pair of loppers, a handsaw, and a power saw (a "sawsall" is recommended). c. The Hoe: i. The hoe used at first must be a small landscape sized hoe with a thumb attachment. ii. The hoe must be placed to gently comb back the duff layer using the depth of the bucket tines as the amount of each stroke of the bucket. Gently comb the soil in theses gradual layers working the soil directly away from the trunks. d. Root Exposure and Pruning: i. When any roots of 1.5 inch diameter or greater, of the tree to be retained, is exposed, the Certified Arborist shall stop the hoe operator, hand dig to expose the root, then properly prune the root using the most appropriate sharp and clean tool from the list above. The arborist will then instruct the operator to continue the excavation. ii. This excavation procedure shall continue until Certified Arborist determines that the excavation is deep enough that no more significant roots will likely be exposed. e. The small hoe can then excavate down to its limits of depth. f. The larger hoe can then take over the excavation to the proper depth and of the rest of the site. 6. Putting Utilities Under the Root Zone: a. If it is necessary to place utilities within the dripline, it must be accomplished with trenchless technology such as boring under the root systems of trees (and other vegetation). This work shall be done under the supervision of an ISA Certified Arborist. Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 17 of 23 b. This is to be accomplished by excavating a limited trench or pit on each side of the critical root zone of the tree and then hand digging or pushing the pipe through the soil under the tree. The closest pit walls shall be a minimum of 7 feet from the center of the tree and shall be sufficient depth to lay the pipe at the grade as shown on the plan and profile. c. Tunneling under the roots of trees shall be done under the supervision of an ISA Certified Arborist in an open trench by carefully excavating and hand digging around areas where large roots are exposed. No roots 1 inch in diameter or larger shall be cut. d. The contractor shall verify the vertical and horizontal location of existing utilities to avoid conflicts and maintain minimum clearances; adjustment shall be made to the grade of the new utility as required. Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 18 of 23 Significant Existing Tree Continuous chain link Fencing Post @ Max V O.C. Install as shown on plans at dripline of tree(s) Six-foot high temporary chain link fence shall be placed as shown on plans. Fence shall com- pletely encircle tree(s). Install fence posts using pier blocks only. Avoid driving posts or stakes into major roots. Make a clean straight cut to remove damaged portion of root for all roots over 1" in diameter damaged during construction. Al! exposed roots shall be temporarily covered with damp burlap and covered with soils the same day, if possible, to prevent drying. If not possible, burlap must be kept moist at all times. Work with the protection fencing shall be done manually. No stockpiling of materials, soil, de- bris, vehicle traffic, or storage of equipment or machinery shall be allowed within the limit of the fencing. Cement trucks must not be allowed to deposit waste or wash out materials from their trucks within the Tree Protection Fences. The area within the Tree Protection Fencing must be covered with wood chips, hog fuel, or similar materials to a depth of 8 to 10 inches. The materials should be placed prior to be- ginning construction and remain until the Tree Protection Fencing is taken down. Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 19 of 23 ATTACHMENT 5 - HABITAT TREE, NURSE LOG, BRUSH PILE CREATION AND BENEFITS There are occasions where hazardous trees need not be completely removed. Shortening is the preferred method in these types of areas rather than complete removal. Standing dead trees, also known as "vertical structure " in forest ecology terms, provide important wildlife habitat. Recent studies at the University of Washington have shown that the third most significant reason for the decline of songbirds in the Puget Sound region is the lack of standing dead trees, nurse logs, and brush piles. (The primary reason for the decline of desirable wildlife is loss of habitat. The second reason is predation by dogs, cats, Grey Squirrels, and Opossums.) These studies reveal that as many as 54% of desirable urban wildlife utilize standing dead trees, nurse logs and brush piles on the ground in one or more important life cycle. For instance, Black Capped Chickadees must excavate a new cavity every spring in order to successfully mate and produce a brood of off spring. The opportunity exists here to remove the dangerous portions of these trees and leave the snags standing for wildlife. You can also place the upper trunk sections carefully on the ground as nurse logs. The logs, if in contact with the ground, soak up moisture and release it slowly throughout the summer. This supports plants and animals in the immediate area. Brush piles strategically placed for birds and mammals to use as safe areas also have important wildlife benefits. These two measures have the added benefit of reducing the cost because a tree service does not need to do as much clean up or removal. The tree service selected can spend a few extra minutes on the top of each snag to make the cut look like it was snapped off in the wind — jagged and irregular. This enhances the aesthetic appeal of the tree. Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 20 of 23 VALUE OF BRUSH PILES In general, the concept of shelter is important to urban wildlife. In his book, Landscaping for Wildlife in the Pacific Northwest, Wildlife Biologist Russell Link writes, "Shelter, (also called cover) is a place to raise young, hide from predators, and avoid the heat, cold, and wind. Shelter also provides a place to feed, play, and rest safely. The quality of shelter is particularly important for young animals in a nest. Unlike an animal that can flee when a predator approaches, young birds or small mammals must rely entirely upon the cover and the camouflage of the nest itself." Different birds and mammals will use different parts of the brush pile as Table 1 Wildlife that use and average -size brush pile from page 123 of Mr. Link's book notes: TABLE I. WILDUFE THAT USE AN AVERAGE --SIZE BRUSH PILE Birds That Will Use the Inside of the Brush Pile: Birds That Will Use the Outside of the Brush Pile: Mammals That Will Use•the Inside of the Brush Pile: Reptiles and Amphibians That Will Use the Base of the Brush Pile: Bushtits Grouse Chipmunks Alligator Lizards Chickadees Hummingbirds Cottontail Rabbits Salamanders Dark -eyed Juncos Jays Fox Snakes Flycatchers Pheasants Ground Squirrels Toads Golden -crowned Sparrows Robins Mice Turtles Grouse Song Sparrows Rabbits Pheasants Towhees Shrews Quail Warblers Skunks Song Sparrows White -Crowned Sparrows Voles Thrushes Woodpeckers Weasels Towhees Woodrats White -Crowned Sparrows Wrens For instance, insects will be attracted to the inside of brush piles that will become food or other animals. "The inside of the pile can also protect wildlife from sun, rain, and predators. During strong winds, birds that would ordinarily use an evergreen tree for evening shelter may instead use a brush pile located on the ground out of the wind. Far into a pile, mammals and some birds find nesting cover in the tight network of strong twigs. The outside, where the sticks protrude from the pile, provides places for birds to perch and sign, preen, and catch insects. If the base of the pile contains large limbs or logs, salamanders, snakes, and lizards may hibernate there. Ants, worms, beetles, and other insects will life and feed in the rich soil beneath a pile. Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 21 of 23 When snow covers a brush pile, a complex array of snow free spaces and runways provides important habitat for protection and foraging by small mammals." From pages 122 & 123, Landscaping for Wildlife in the Pacific Northwest by Russell Link. Brush piles can be simple hand thrown piles of bio-debris and rocks or they can be large designed piles. A large brush pile from many trees piled together. This one is older with the foliage all fallen from the branches and twigs. But, it can provide cover for years. CI An example of a simple Christmas tree brush pile. A schematic design for three more complex brush piles. Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 22 of 23 ATTACHMENT 6 - BIBLIOGRAPHY 1. Dirr, Michael A. Manual of Woody Landscape Plants, Their Identification, Ornamental Characteristics, Culture, Propagation, and Uses. Champaign: Stipes Publishing Company, 1990. 2. Dunster, Dr. Julian A., R.P.F., M.C.I.P. Documenting Evidence, Practical Guidance for Arborists, First Choice Books, Victoria, BC, Canada. 2014. 3. Eric Allen, et al. Common Tree Diseases of British Columbia. Victoria: Canadian Forest Service, 1996. 4. Goheen, Ellen Michaels and Elizabeth A Willhite, Field Guide to the Common Diseases and Insect Pests of Oregon and Washington Conifers, R6-NR-FID-PR- 01-06.2006. USDA Forest Service, Pacific Northwest Region. 5. Harris, Richard W, James Clark, and Nelda Matheny. Arboriculture, Integrated Management of Landscape Trees, Shrubs, and Vines. 4'h ed. Upper Saddle River: Prentice Hall, 2004. 6. Link, Russell, Landscaping for Wildlife in the Pacific Northwest, The University of Washington Press, Seattle, WA. 1999. 7. Matheny, Nelda P. and Clark, James R. Evaluation of Hazard Trees. 2nd ed. Savoy: The International Society of Arboriculture Press, 1994. 8. Matheny, Nelda P. and Clark, James R. Trees & Development, A Technical Guide to Preservation of Trees During Land Development. Savoy: The International Society of Arboriculture Press, 1998. 9. Mathews, Daniel. Cascade -- Olympic Natural History. Portland, Oregon: Raven Editions with the Portland Audubon Society, 1992. 10. Mattheck, Claus and Breloer, Helge. The Body Language of Trees, A Handbook for Failure Analysis. London: HMSO, 1994. 11. Pacific Northwest Chapter-ISA. Tree Risk Assessment in Urban Areas and the Urban/Rural Interface. Course Manual. Release 1.5. PNW-ISA: Silverton, Oregon, 2011. Evaluation of Trees at the Greenline Business Park Weyerhaeuser Way South, Federal Way, WA Gilles Consulting September 20, 2017 Page 23 of 23 12. Petrides, George A. and Wehr, Janet. A Field Guide to Eastern Trees, Eastern United States and Canada including the Midwest. New York: Houghton Mifflin Company, 1998. 13. Scharpf, Robert F. Diseases of Pacific Coast Conifers. Albany, California: USDA Forest Service, Agriculture Handbook 521, rev. June 1993. 14. Sinclair, Wayne A., Lyon, Howard H., and Johnson, Warren T. Diseases of Trees and Shrubs. Ithaca, New York: Cornell University Press, 1987. 15. Smiley, E. Thomas, Nelda Matheny, and Sharon Lilly, Tree Risk Assessment Best Management Practices, ANSI A300 Part 9: Tree, Shrub, and Other Woody Plant Management —Standard Practices (Tree Risk Assessment a. Tree Structure Assessment). The International Society of Arboriculture Press. Champaign. IL. 2011. 16. Watson, Gary W., and Neely, Dan, eds. Trees & Building Sites. Savoy: The International Society of Arboriculture Press, 1995. C W m � � O 7 ° 0 R � 2 ID'a O O o n W O o+ m fi m CL E c m N E 10 m80 ID @ c m E m m a m 'c E c �mm c 0 or c p � � u c m= G c a 4 In C P n m q3 N r ; = C m ro O m @ m m C R m r@ @ m 0) Ln G N P 10 L x a m N O C_ Gp7 7 m U =m m O 2 m m~ � _E 'p r m c m LI) ZUl W p 0 L�) m z J in a e w a v m E ca a 14 c m5 R'�� Cpa mar m mp �Em m20 i° 1�* cn�pfiwm m b to m � jw @ n ty -cE yn�- m mm E m c3c R�Ncg� �' m 7 'y `m mbO w C.} I a2h.q-O;�Q� a O R 0. c aa�{ c 4 7L m$ ¢= h81y 1= a � Uq-e W x Qcnvr a E m fU w U [] E y . l7 �' n m r J ��`pv¢c v a L7 Lei j s= a'XmmyyQ o .c ad;0) N m� Co mm �'+.a W yyJE v Uq LO mE m @ am @=.2 �¢ m �y 3S Q m'p p F m 2 2 my�' @ O a Q= di C�i J W 0 @ m Q L. -t C C C IE J I @ j z@@z O_2 mcai-. �n m E t°�mmm 7 W y m c�or��uwwuwc7 7 O 7 7 d CL 10 -,��azDaaiocrwinr�i73�� iE O O❑ W W tl— ❑ 5@ m= m 000.-dog C i P P P � r 7 C G7 RPM @PP [•! [7 [7 [7 m[v PO Ci 07 � �L]� � � E °�UV} � w4•' N It U � Vl N yyNQU �(7U arorninMMLL.c �mm�UU❑pwtuW�wLQ7-��z�dp, rnv77��7r7r �❑ 0. 0. 0. 0. 0. a s � � O F . d a F- y N lh a, `O @ m a Tree Inventory/Condition Spreadsheet Greenline Business Park Transect A 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater inches than 8 DBH Status A 2152 DF 9.2" P TRUE Not -Significant A 2153 DF 18.9" F TRUE Significant A 2154 DF 26.2" G TRUE Significant A 2155 DF 25.2" F TRUE Significant A 2156 DF 26.5" G TRUE Significant A 2157 DF 23.5" F TRUE Significant A 2158 AP 9.5" G TRUE Significant A 2159 DF 29.5" G TRUE Significant A 2160 DF 30.0" VG TRUE Significant A 2161 DF 27.8" G TRUE Significant A 2162 DF 23.7" F TRUE Significant A 2163 DF 28.2" F TRUE Significant A 2164 DF 33.0" G TRUE Significant A 2165 DF 21.2" F TRUE Significant A 2166 DF 31.0" G TRUE Significant A 2167 DF 24.2" F TRUE Significant A 2168 DF 24.6" G TRUE Significant A 2169 DF 21.0" G TRUE Significant A 2170 DF 30.8" G TRUE Significant A 2171 DF 9.9" F TRUE Significant A 2172 DF 18.1" F TRUE Significant A 2173 WRC 16.5" G TRUE Significant A 2174 DF 31.0" P TRUE Not -Significant A 2175 DF 26.4" VG TRUE Significant A 2176 DF 34.9" VG TRUE Significant A 2177 DF 9.3" P TRUE Not -Significant A 2178 DF 11.8" G TRUE Significant A 2179 DF 19.8" G TRUE Significant A 2180 DF 34.0" G TRUE Significant A 2181 AP 8.8" G TRUE Significant A 2182 DF 8.1" Dying TRUE Not -Significant A 2183 DF 8.2" P TRUE Not -Significant A 2184 DF 8.5" Dying TRUE Not -Significant A 2185 DF 30.6" G TRUE 1 Significant A 2186 DF 26.1" G TRUE Significant A 2187 DF 34.0" G TRUE Significant A 2188 WRC 19.1" VG TRUE Significant A 2189 WRC 23.2" VG TRUE Significant A 2190 DF 25.8" G TRUE Significant A 2191 DF 29.2" P TRUE Not -Significant A 2192 DF 30.9" VG TRUE Significant A 2193 DF 44.2" E TRUE Significant A 2194 DF 29.0" G TRUE Significant A 2195 DF 29.4" G TRUE Significant A 2196 DF 28.6" P TRUE Not -Significant A 2197 DF 9.8" G TRUE Significant A 2198 DF 27.0" P TRUE Not -Significant A 2199 DF 14.7" F TRUE Significant A 2200 DF 10.9" P TRUE Not -Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect A 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater inches than 8 DBH Status A 2201 DF 12.7" F TRUE Significant A 2202 DF 9.3" P TRUE Not -Significant A 2203 DF 9.4" Dying TRUE Not -Significant A 2204 DF 30.4" G TRUE Significant A 2205 WRC 11.3" F TRUE Significant A 2206 WRC 10.4" F TRUE Significant A 2207 Pinus M 17.1" G TRUE Significant A 2208 DF 15.9" Dying TRUE Not -Significant A 2209 DF 16.3" P TRUE Not -Significant A 2210 DF 15.8" F TRUE significant A 2211 DF 16.5" G TRUE Significant A 2212 DF 13.5" F TRUE Si nificant A 2213 DF 14.6" G TRUE Significant A 2214 DF 12.9" F TRUE Significant A 2215 LD 11.8" F TRUE Significant A 2216 DF 12.0" F TRUE Significant A 2217 DF 11.5" F TRUE Significant A 2218 DF 8.8" F TRUE Significant A 2219 DF 13.6" F TRUE Significant A 2220 DF 11.8" F TRUE Significant A 2221 DF 8.4" P TRUE Not -Significant A 2222 DF 12.9" F TRUE Significant A 2223 DF 12.2" F TRUE Significant A 2224 DF 11.8" F TRUE Significant A 2225 DF 8.6" F TRUE Significant A 2226 DF 13.4" F TRUE Significant A 2227 DF 11.2" D TRUE Not -Si nificant A 2228 DF 14.0" F TRUE Significant A 2229 DF 10.8" F TRUE Significant A 2230 DF 9.6" D TRUE Not -Significant A 2231 DF 10.0" P TRUE Not -Significant A 2232 DF 12.1" F TRUE Significant A 2233 DF 12.8" F TRUE Significant A 2234 DF 9.8" F TRUE Significant A 2235 DF 12.6" F TRUE Significant A 2236 DF 10.8" P TRUE Not -Significant A 2237 DF 12.2" F TRUE Significant A 2238 DF 15.2" G TRUE Significant A 2239 DF 15.2" G TRUE Significant A 2240 DF 10.5" D TRUE Not -Significant A 2241 DF 29.2" VG TRUE Significant A 2242 DF 23.6" VG TRUE Significant A 2243 DF 12.0" G TRUE Significant A 2244 DF 9.5" G TRUE Significant A 2245 DF 38.2" E TRUE Significant A 2246 DF 42.8" E TRUE Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect B 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater inches than 8 Status B 2601 DF 13.8 P TRUE Not -Significant B 2602 DF 13.5 P TRUE Not -Significant B 2603 DF 11.6 P TRUE Not -Significant B 2604 DF 14.2 P TRUE Not -Significant B 2605 DF 14.7 P TRUE Not -Significant B 2606 DF 12.3 P TRUE Not -Significant B 2607 DF 13.9 P TRUE Not -Significant B 2608 DF 9.5 P TRUE j Not -Significant B 2609 DF 9.6 P TRUE Not -Significant B 2610 DF 12.8 P TRUE Not -Si nificant B 2611 DF 13.7 P TRUE Not -Significant B 2612 DF 13.4 P TRUE Not -Significant B 2613 DF 13.4 P TRUE Not -Significant B 2614 DF 16.7 F TRUE Si nificant B 2615 DF 15.4 P TRUE Not -Significant B 2616 DF 14.2 P TRUE Not -Significant B 2617 DF 15.2 P TRUE Not -Significant B 2618 DF 9.1 D TRUE Not -Significant B 2619 DF 12 P TRUE Not -Significant B 2620 DF 16.3 P TRUE Not -Significant B 2621 DF 11.5 P TRUE Not -Significant B 2622 Acer Spp 11 F TRUE Significant B 2623 DF 15 P TRUE Not -Significant B 2624 DF 14.3 P TRUE Not -Significant B 2625 DF 13.7 P TRUE Not -Significant B 2626 DF 16.2 P TRUE Not -Significant B 2627 DF 14.1 P TRUE Not -Si nificant B 2628 DF 11 P TRUE Not -Significant B 2629 DF 11.9 P TRUE Not -Significant B 2630 DF 10.8 P TRUE Not -Si nificant B 2631 DF 13.5 P TRUE Not -Si nificant B 2632 DF 11.9 P TRUE Not -Significant B 2633 DF 9.8 P TRUE Not -Si nificant B 2634 DF 12.5 P TRUE Not -Si nificant B 2635 DF 9.7 P TRUE Not -Si nificant B 2636 DF 9 D TRUE Not -Significant B 2637 DF 11.2 D TRUE Not -Significant B 2638 DF 14.6 P TRUE Not -Significant B 2639 DF 11.7 P TRUE Not -Si nificant B 2640 DF 15.6 F TRUE Significant B 2641 DF 8.6 D TRUE Not -Significant B 2642 DF 16 P TRUE Not -Significant B 2643 DF 11 P TRUE Not -Significant B 2644 DF 8.7 P TRUE Not -Significant B 2645 Acer Spp 14.9 G TRUE Significant B 2646 Acer Spp 16 G TRUE Significant B 2647 DF 14.4 F TRUE Significant B 2648 DF 13.3 F TRUE Si nificant B 2649 Acer Spp 13 G TRUE Significant B 2650 DF 12.9 P TRUE Not -Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect B 1 2 3 4 6 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater inches than 8 Status B 2651 DF 11.5 P TRUE Not -Significant B 2652 DF 10.5 P TRUE Not -Significant B 2653 DF 12 P TRUE Not -Significant B 2654 DF 13.6 P TRUE Not -Significant B 2655 DF 10.2 D TRUE Not -Si nificant B 2656 DF 9.9 D TRUE Not -Significant B 2657 DF 13 F TRUE Significant B 2658 DF 14 F TRUE Significant B 2659 DF 15 F TRUE Si nificant B 2660 DF 10.9 G TRUE Si nificant B 2661 DF 8.5 G TRUE Significant B 2662 DF 8.4 P TRUE Not -Significant B 2663 DF 11.5 P TRUE Not -Si nificant B 2664 DF 14.4 F TRUE Significant B 2665 DF 9.2 D TRUE Not -Significant B 2666 DF 15.2 P TRUE Not -Significant B 2667 Acer Spp 11.2 G TRUE Significant B 2668 Acer Spp 12.9 G TRUE Significant B 2669 DF 8.2 D TRUE Not -Significant B 2670 Acer S p 17.5 G TRUE Significant B 2671 DF 15.6 F TRUE Significant B 2672 DF 13.8 F TRUE Significant B 2673 DF 12.1 P TRUE Not -Si nificant B 2674 DF 18.4 F TRUE Significant B 2675 Acer S p 14.8 G TRUE Significant B 2676 DF 15.1 F TRUE Significant B 2677 DF 15 F TRUE Si nificant B 2678 DF 14.3 P TRUE Not -Significant B 2679 DF 8.9 D TRUE Not -Significant B 2680 DF 9.4 D TRUE Not -Significant B 2681 DF 8 P FALSE Not -Significant B 2682 DF 16.5 F TRUE Significant B 2683 DF 9.5 D TRUE Not -Significant B 2684 DF 12 P TRUE Not -Significant B 2685 DF 17.2 F TRUE Significant B 2686 DF 13.4 F TRUE Significant B 2687 Acer S p 14.6 G TRUE Significant B 2688 Acer Spe 12.2 G TRUE Significant B 2689 DF 12.2 P TRUE Not -Significant B 2690 DF 13.8 D TRUE Not -Si nificant B 2691 DF 12.3 P TRUE Not -Significant B 2692 DF 9.2 D TRUE Not -Significant B 2693 DF 12.6 F TRUE Significant B 2694 DF 8.5 D TRUE Not -Significant B 2695 DF 14.5 P TRUE Not -Significant B 2696 DF 16 F TRUE Significant B 2697 DF 12.6 F TRUE Significant B 2698 DF 9.7 D TRUE Not -Significant B 2699 DF 14 F TRUE Significant B 2700 DF 14.3 F TRUE Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect B 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater inches than 8 Status B 2701 DF 12 P TRUE Not -Significant B 2702 DF 13.8 P TRUE Not -Significant B 2703 DF 14.3 P TRUE Not -Significant B 2704 DF 11.6 P TRUE Not -Significant B 2705 DF 14.3 F TRUE Significant B 2706 DF 14.2 F TRUE Significant B 2707 DF 13 P TRUE Not -significant B 2708 WRC 31.8 G TRUE Significant B 2709 Acer Spp 11.9 G TRUE Significant B 2710 Acer Spp 15.5 G TRUE Significant B 2711 Acer Spp 11.6,10.4 G TRUE Significant B 2712 Acer Spp 15.9 G TRUE Significant B 2713 DF 16.8 F TRUE Significant B 2714 DF 14.1 F TRUE Significant B 2715 DF 10.8 D TRUE Not -Significant B 2716 DF 11.9 F TRUE Significant B 2717 DF 12.5 F TRUE Significant B 2718 DF 14.1 F TRUE Significant B 2719 DF 10 D TRUE Not -Significant B 2720 DF 12.4 P TRUE Not -Si nificant B 2721 DF 17.6 F TRUE Significant B 2722 DF 12.3 P TRUE Not -Significant B 2723 DF 12.6 D TRUE Not -Significant B 2724 DF 13.2 P TRUE Not -Significant B 2725 DF 16.9 F TRUE Significant B 2726 Acer Spp 14.4 G TRUE Si nificant B 2727 DF 13 F TRUE Significant B 2728 DF 15.4 F TRUE Significant B 2729 DF 15.2 P TRUE Not -Significant B 2730 DF 18 F TRUE Significant B 2731 DF 12.9 F TRUE Si nificant B 2732 DF 10.2 P TRUE Not -Significant B 2733 DF 15.1 F TRUE Significant B 2734 Ash 8.5 F TRUE Si nificant B 2735 DF 10.9 D TRUE Not -Significant B 2736 DF 13.9 F TRUE Significant B 2737 DF 17.4 F TRUE Significant B 2738 DF 12.8 P TRUE Not -Significant B 2739 DF 14.7 F TRUE Significant B 2740 DF 14 F TRUE Significant B 2741 DF 12.8 F TRUE Significant B 2742 DF 14.2 F TRUE Significant B 2743 DF 11.4 P TRUE Not -Significant B 2744 DF 12.9 P TRUE Not -Si nificant B 2745 DF 10.3 P TRUE Not -Significant B 2746 DF 15.9 F TRUE Significant B 2747 DF 15.9 G TRUE Significant B 2748 DF 9 D TRUE Not -Significant B 2749 DF 13.6 P TRUE Not -Si nificant B 2750 DF 12 P TRUE Not -Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect B 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater inches than 8 Status B 2751 DF 13.2 P TRUE Not -Significant B 2752 DF 17.8 P TRUE Not -Significant B 2753 Ash 13.5 G TRUE Significant B 2754 DF 11.8 Dying TRUE Not -Si nificant B 2755 DF 9.8 F TRUE Significant B 2756 Ash 11.1 G TRUE Significant B 2757 DF 9.2 D TRUE Not -Significant B 2758 DF 15.8 F TRUE Significant B 2759 DF 11 D TRUE Not -Significant B 2760 DF 9.8 P TRUE Not -Significant B 2761 DF 13.9 F TRUE Significant B 2762 DF 14.5 F TRUE Significant B 2763 DF 11.7 F TRUE Significant B 2764 DF 12.2 F TRUE Significant B 2765 DF 11.8 P TRUE Not -Significant B 2766 DF 13.8 P TRUE Not -Significant B 2767 DF 10.2 P TRUE Not -Significant B 2768 DF 12.9 P TRUE Not -Significant B 2769 DF 11.6 P TRUE Not -Sign cant B 2770 DF 14.2 F TRUE Significant B 2771 DF 12.5 Dying TRUE Not -Si nificant B 2772 DF 13.7 F TRUE Significant B 2773 DF 10.4 P TRUE Not -Significant B 2774 DF 8.9 P TRUE Not -Si nificant B 2775 DF 15 F TRUE Significant B 2776 DF 12.3 D TRUE Not -Significant B 2777 DF 11.2 P TRUE Not -Si nificant B 2778 DF 14.6 F TRUE Si nificant B 2779 DF 12.2 F TRUE Significant B 2780 DF 16.2 F TRUE Significant B 2781 DF 12.8 P TRUE Not -Significant B 2782 DF 9.8 P TRUE Not -Si nificant B 2783 DF 13.8 P TRUE Not -Significant B 2784 DF 11.9 F TRUE Significant B 2785 DF 11.4 F TRUE Significant B 2786 DF 10.9 D TRUE Not -Significant B 2787 DF 11.8 P TRUE Not -Significant B 2788 DF 15.7 F TRUE Significant B 2789 DF 13.6 F TRUE Significant B 2790 Ash 11.1 G TRUE Significant B 2791 DF 11.1 P TRUE Not -Significant B 2792 Ash 13.1 G TRUE Significant B 2793 DF 13.8 F TRUE Significant B 2794 DF 12.8 F TRUE Significant B 2795 DF 8.9 P TRUE B 2796 DF 15.7 P TRUE B 2797 DF 15.6 F TRUE Significant B 2798 DF 8.8 D TRUE Not -Significant B 2799 DF 16.9 F TRUE Significant B 2800 DF 14 P TRUE Not -Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect B 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater inches than 8 QBH Status B 2801 DF 10 P TRUE Not -Si nificant B 2802 DF 14.8 P TRUE Not -Si nificant B 2803 DF 15.4 P TRUE Not -Significant B 2804 DF 12.1 F TRUE Significant B 2805 DF 13.8 P TRUE Not -Si nificant B 2806 DF 12.2 P TRUE Not -Significant B 2807 DF 11.1 P TRUE Not -Significant B 2808 DF 12.9 F TRUE Significant B 2809 DF 13.6 P TRUE Not -Si nificant B 2810 DF 16.6 F TRUE Significant B 2811 DF 12.8 P TRUE Not -Significant B 2812 DF 14.7 F TRUE Significant B 2813 DF 15 F TRUE Significant B 2814 DF 14.4 P TRUE Not -Si nificant B 2815 DF 8 P FALSE Not -Significant B 2816 DF 8.5 D TRUE Not -Significant B 2817 DF 10.9 Dying TRUE Not -Significant B 2818 DF 14.7 F TRUE Significant B 2819 DF 10.9 D TRUE Not -Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect C 1 2 3 4.0 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater than 8 inches QBH STATUS C 2820 DF 12.6 P TRUE Not -Significant C 2821 DF 10.3 P TRUE Not -Significant C 2822 DF 15.0 F TRUE Significant C 2823 DF 12.0 P TRUE Not -Significant C 2824 DF 9.8 F TRUE Significant C 2825 DF 13.1 F TRUE Significant C 2826 DF 14.9 F TRUE Significant C 2827 DF 14.8 P TRUE Not -Significant C 2828 DF 11.8 F TRUE Significant C 2829 DF 13.0 P TRUE Not -Significant C 2830 DF 12.0 P TRUE Not -Significant C 2831 DF 10.6 D TRUE Not -Significant C 2832 DF 11.1 P TRUE Not -Significant C 2833 Ash 13.2 G TRUE Significant C 2834 DF 9.0 P TRUE Not -Significant C 2835 DF 13.3 P TRUE Not -Significant C 2836 DF 13.3 F TRUE Significant C 2837 DF 11.7 D TRUE Not -Significant C 2838 DF 15.2 F TRUE Significant C 2839 DF 10.6 P TRUE Not -Significant C 2840 DF 13.7 P TRUE Not -Significant C 2841 DF 14.1 F TRUE Significant C 2842 DF 12.6 F TRUE Significant C 2843 DF 13.5 F TRUE Significant C 2844 WRC 33.4 G TRUE Significant C 2845 DF 15.1 D TRUE Not -Significant C 2846 DF 9.5 P TRUE Not -Significant C 2847 DF 11.1 P TRUE Not -Significant C 2848 DF 16.3 D TRUE Not -Significant C 2849 DF 11.1 D TRUE Not -Significant C 2850 DF 11.4 P TRUE Not -Significant C 2851 DF 12.5 D TRUE Not -Significant C 2852 DF 15.5 F TRUE Significant C 2853 DF 8.5 P TRUE Not -Significant C 2854 DF 12.2 P TRUE Not -Significant C 2855 DF 14.2 F TRUE Significant C 2856 DF 13.6 F TRUE Significant C 2857 DF 15.5 P TRUE Not -Significant C 2858 DF 9.2 D TRUE Not -Significant C 2859 DF 10.8 P TRUE Not -Significant C 2860 DF 10.7 P TRUE Not -Significant C 2861 DF 18.0 P TRUE Not -Significant C 2862 TH 12.0 Ding TRUE 'Not -Significant C 2863 DF 16.5 F TRUE Significant C 2864 DF 11.4 Dying TRUE Not -Significant C 2865 DF 11.3 Dying TRUE Not -Significant C 2866 DF 12.6 D TRUE Not -Significant C 2867 DF 9.0 D TRUE Not -Significant C 2868 DF 11.4 P TRUE Not -Significant I C 2869 WRC 35.7 G TRUE Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect C 1 2 3 4.0 5 6 7 TREE LOCATION TREE # SPECIES DISH Condition Greater than 8 inches DBH STATUS C 2870 DF 8.0 P FALSE Not -Significant C 2871 DF 13.8 F TRUE Significant C 2872 DF 16.9 P TRUE Not -Significant C 2873 DF 11.4 D TRUE Not -Significant C 2874 DF 10.7 D TRUE Not -Significant C 2875 DF 14.4 D TRUE Not -Significant C 2876 DF 13.5 D TRUE Not -Significant C 2877 DF 8.0 P FALSE Not -Significant C 2878 DF 9.0 P TRUE Not -Si nificant C 2879 DF 13.5 P TRUE Not -Significant C 2880 DF 13.2 D "ng TRUE Not -Significant C 2881 DF 14.3 F TRUE Significant C 2882 DF 15.0 P TRUE Not -Significant C 2883 DF 10.6 P TRUE Not -Significant C 2884 DF 10.4 D TRUE Not -Significant C 2885 DF 15.5 D TRUE Not -Significant C 2886 DF 8.5 D TRUE Not -Significant C 2887 DF 24.5 G TRUE Significant C 2888 WRC 33.0 G TRUE Significant C 2889 DF 9.4 P TRUE Not -Significant C 2890 Acer Spp 10.8 G TRUE Significant C 2891 DF 9.9 P TRUE Not -Significant C 2892 DF 9.5 P TRUE Not -Significant C 2893 DF 13.9 P TRUE Not -Si nificant C 2894 DF 16.5 Ding TRUE Not -Significant C 2895 DF 12.3 P TRUE Not -Significant C 2896 DF 9.4 P TRUE Not -Significant C 2897 DF 11.2 P TRUE Not -Significant C 2898 DF 17.5 G TRUE Significant C 2899 DF 12.4 P TRUE Not -Significant C 2900 DF 12.4 P TRUE Not -Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect D 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater inches than 8 DIBH Status D 2247 WRC 39.0" G TRUE Significant D 2248 WRC 35.9" G TRUE Significant D 2249 WRC 35.8" G TRUE Significant D 2250 WRC 43.4" G TRUE significant D 2251 WRC 33.8" D TRUE Not -Significant D 2252 WRC 36.5" P TRUE Not -Significant D 2253 WRC 26.3" F TRUE Significant D 2254 WRC 23.211 (topbless ng TRUE Not -Significant D 2255 WRC 38.6" VG TRUE Significant D 2256 WRC 30.2" G TRUE Significant D 2257 WRC 22.6" D TRUE Not -Significant D 2258 WRC 28.0" P TRUE Not -Significant D 2259 WRC 20.3" P TRUE Not -Significant D 2260 WRC 25.4" dying TRUE Not -Significant D 2261 WRC 20.2" G TRUE significant D 2262 WRC 37.3" VG TRUE Significant D 2263 DF 28.6" G TRUE Si nificant D 2264 WRC 24.0" F TRUE Significant D 2265 WRC 23.5" G TRUE Significant D 2266 WRC 32.2" G TRUE Significant D 2267 WRC 12.2" F TRUE Significant D 2268 WRC 28.0" G TRUE Si nificant D 2269 WRC 30.2" VG TRUE Significant D 2270 WRC 42.2" E TRUE Significant D 2271 TH 27.3" VG TRUE Significant D 2272 WRC 11.5" G TRUE Si nificant D 2273 DF 29.6" G TRUE Significant D 2274 DF 17.3" D TRUE Not -Significant D 2275 DF 17.5" D TRUE Not -Significant D 2276 DF 21.0" F TRUE Si nificant D 2277 TH 19.7" G TRUE Significant D 2278 TH 14.2" D TRUE Not -Significant D 2279 DF 14.7" F TRUE Significant D 2280 DF 28.4" VG TRUE Significant D 2281 WRC 29.4" F TRUE Significant D 2282 DF 18.9" P TRUE Not -Significant D 2283 WRC 16.2" G TRUE Significant D 2284 DF 13.2" F TRUE Sign ficant D 2285 WRC 13.8" G TRUE Significant D 2286 DF 30.5" G TRUE Significant D 2287 TH 11.6" P TRUE Not -Significant D 2288 TH 19.6" G TRUE Significant D 2289 WRC 31.3" G TRUE Sign fiGant D 2290 WRC 18.3" G TRUE Significant D 2291 TH 2O.3" P TRUE Not -Significant D 2292 WRC 38.4" G TRUE Significant D 2293 TH 17.6" dying TRUE Not -Significant D 2294 TH 21.6" P TRUE Not -Significant D 2295 DF 17.5" F TRUE Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect D 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater inches than 8 DBH Status D 2296 DF 10.2" D TRUE Not -Significant D 2297 WRC 41.5" E TRUE Significant D 2298 TH 23.0" D TRUE Not -Significant D 2299 WRC 28.8" G TRUE Si nificant D 2300 WRC 30.6" G TRUE Significant D 2301 WRC 33.0" G TRUE Significant D 2302 WRC 29.2" F TRUE Significant D 2303 WRC 28.6" F TRUE Significant D 2304 WRC 31.3" VG TRUE Si nificant D 2305 WRC 28.4" G TRUE Significant D 2306 WRC 39.5" VG TRUE Significant D 2307 WRC 24.2" G TRUE Significant D 2308 WRC 38.0" G TRUE Si nificant D 2309 WRC 46.3" E TRUE Significant D 2310 WRC 28.0" din9 TRUE Not -Significant D 2311 WRC 50.0" E TRUE Significant D 2312 WRC 18.2" F TRUE Significant D 2313 WRC 48.8" VG TRUE Sign! cant D 2314 WRC 20.0" G TRUE Significant D 2315 WRC 32.9" G TRUE Si nificant D 2316 WRC 43.3" E TRUE Significant D 2317 WRC 24.7" G TRUE Significant D 2318 WRC 39.2" VG TRUE Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect E 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater inches than 8 QBH Status E 2319 WRC 15.8" G TRUE Significant E 2320 WRC 13.9" G TRUE Significant E 2321 Aa 13.6" G TRUE Significant E 2322 Aa 15.0" VG TRUE Significant E 2323 DF 30.4" G TRUE Significant E 2324 Ash spp 14.5" G TRUE Significant E 2325 Ash spp 14.2" G TRUE Significant E 2326 Ash spp 8.7" G TRUE Significant E 1 2327 Ash spp 10.4" G TRUE Significant E 2328 Ash spp 11.9" G TRUE Significant E 2329 DF 22.1 dying TRUE Not -Significant E 2330 Ash spp 11.3" G TRUE Significant E 2331 Ash spp 9.1" G TRUE Significant E 2332 Ash spp 15.7" G TRUE Significant E 2333 Ash s2P 12.5" G TRUE Significant E 2334 Ash spp 15.4" G TRUE Significant E 2335 Ash spp 10.4" G TRUE Significant E 2336 Ash spp 12.7" G TRUE Significant E 2337 Ash sep 16.2" G TRUE Significant E 2338 Ash spp 13.7" G TRUE Significant E 2339 Ash spp 12.6" G TRUE Significant E 2340 WRC 9.1" Dying TRUE Not -Significant E 2341 WRC 10.5" Dying TRUE Not -Significant E 2342 WRC 12.4" G TRUE Significant E 2343 WRC 14.5" F TRUE Significant E 2344 DF 39.0" VG TRUE Significant E 2345 WRC 28.2" G TRUE Significant E 2346 WRC 36.4" G TRUE Significant E 2347 WRC 28.3,41.3 VG TRUE Significant E 2348 WRC 20.1" F TRUE Significant E 2349 WRC 10.1" P TRUE Not -Significant E 2350 LD 12.8" G TRUE Significant E 2351 Ash spp 15.2" G TRUE Significant E 2352 WRC 9.0" Dying TRUE Not -Significant E 2353 WRC 9.0" P TRUE Not -Significant E 2354 WRC 8.5" Dying TRUE Not -Significant E 2355 WRC 12.2" F TRUE Significant E 2356 WRC 9.5" P TRUE Not -Significant E 2357 WRC 9.8" G TRUE Significant E 2358 LD 10.5" G TRUE Significant E 2359 WRC 8.6" G TRUE Significant E 2360 WRC 14.0" G TRUE Significant E 2361 WRC 8.3" G TRUE Significant E 2362 WRC 14.2" G TRUE Significant E 2363 WRC 8.3" G TRUE Significant E 2364 WRC 8.4" G TRUE Significant E 2365 WRC 38.7" F TRUE Si nificant E 2366 WRC 30.2" G TRUE ISignificant E 2367 WRC 26.7" G TRUE ESigni!fiE!cant E 2368 WRC 24.7" G TRUE nt Tree Inventory/Condition Spreadsheet Greenline Business Park Transect E 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater inches than 8 DBH Status E 2369 WRC 25.9" G TRUE Significant E 2370 WRC 20.0" G TRUE Significant E 2371 WRC 18.4" G TRUE Significant E 2372 WRC 35.2" G TRUE Significant E 2373 DF 19.8, .9 VG TRUE Significant E 2374 WRC 34.2" VG I TRUE ISignificant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect F 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater inches than 8 DBH Status F 2375 WRC 13.8,13.8 G TRUE Significant F 2376 WRC 35.6,35.4 VG TRUE Significant F 2377 WRC 26.5" G TRUE Significant F 2378 WRC 10.7" F TRUE Significant F 2379 WRC 26.7" G TRUE Significant F 2380 WRC 35.6" G TRUE Si nificant F 2381 DF 22" F TRUE Significant F 2382 WRC 9.7" G TRUE Significant F 2383 WRC 27.2" G TRUE Significant F 2384 DF 27.3" VG TRUE Significant F 2385 WRC 16.3" G TRUE Significant F 2386 TH 921 Dying TRUE Not -Significant M N U C V w y COC (1) 2 C F- C a) N C � •+ C w+ C ++ C .-+ C ♦+ C ++ C ++ C r.+ C rr C rr C C � ++ C C � �+ C r-. C C � r.+ C a+ C C a7 U ..+ C ..+ C rr C C a3 U C N U +.. C +.+ C .«+ C .r C +.. C �-+ C ..+ C +. C .� C .... C }. C .. C M U m m w m m w m as m m U ;� (a U as a7 U CC a3 a7 iC as as a7 :� _ a7 (� U ai U as U a3 U m U m U a3 U a7 U a3 U «S U ai U C U U U ?�- U ;C_ U � U = U ;C_ U = U � U = C U w C U _ U C O == U C U _ U w U C C U 4_ ;_ E 4_ !E E 4_ = E ;C_ ;_ N C C C C C C C C C C C C NLoll C C C C C C C C C C C C C C C C C O(nfn(A(nfnfnUfgfnfl1 fn (!JfA pfn0 p!AfnIn O p!�Ufnfn(nfnfnfnfAlAUfn Z Z Z Z Z Z Z CID L p IW W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W W H i- H H H H H H H H H H H H H H H f H H H H H H H H R V ILL V � C 0 L a o o ao(.9o(D(9c9ooQ- o a-LLLLaLLL.LOc9c9u-EL jc9LLc9c9c9c9C7c7c7c� c 0 0 .4 =�� m coO CO��TDO CV Nm �(fl M cM O O(D0�(D co IAr000 .p �r�Cflr��00 LO0Inrtn o0 w 6c6 CO to In Orrr TTN 0 co co 0 In r M r 0 ap O r aO TON r r r M T r N r T r r r T T r T aD O r r r M M M M a WIS a cl CL a a ammmmuoulJOID U m U C C U a a M a C Op MU M L M L M L (A L a Q a- Q M L M L d Q M L E E E E >> >> Q' > O Q Q> > M= U a3 (aa > Q Q Q Q Q W Q C N Q Q Q Q Q Q Q U U U J JU= = 15) U U U W I- p�wwmm0000000�00000000000rTrT�-rrTrTN a0 O O r N M 'cY l() CO ti a0 0 O r N Mlqt In CO l*- CO O O r N MIt In (O ti O O O r N•NN N M N W MMMMMMMMMMMMMst��'��'t't�� " 'tIct �It 'IT Z O r LuQ C9C9C9C9C9C9C9C7C9C7C9C9C9C9C9C9C9C9C9C9C9C9C9C9C9(�C9C9C9C9C9C9c7C9C9C9C9 H V O C 2 _ F- m �+ C (Q ++ ++ ++ �+ W � rt+ �+ ++ C (a Y w+ �+ ++ W. c (O w �+ rt+ Y W. �+ c (9 U ++ C ++ C �I c w+ C W. C W. C ++ c ++ C W. c rt+ c M•+ c ++ c fA a3 U a3 U ca U c0 U N U N U to U as U a7 U a3 U _ N U N U N U N U N U co U ca U M U m U m U W U M U M U M U M U MM U U M U M U M U M U M U M U c Ncm c � � c c c c c c c c� c c c c c� c c c c c c � c c c c c c c c c c c o��t) (1)U)U) cm cm o n FoFooFo oininwU)ini1) ocni�c�cnv�ia Lm w�cnin�in Z Z Z Z ao mawwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwwiwwww > > > > > > > > > > > D > > > > > > > > > > D > > > > > > > > > > d d F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- F- H H F-• I- H H � v c 0-1 c O v c9 a C9 C9 c9 c9 c9 c9 c9 C9 c9 a c9 C9 c9 c9 U- a c9 C9 j U- U- 9 U- U- U- U- U- U- c O t� 2 M��NNOrCpNti += a7 0MMN0�r0NMMN��OMNMC'7h�f�� N Nh eF m Q NOc6porCOcM"'CMOOCOr0000wO,c:) r r N r r r r r r N r r iic6c6NOOMNN`-MMc6OOOrr T N O r r r r r N `- W C a) U c a) C W c CD U a U •O c U Cl N w cy C cc CX N w CL a N U U a M Cl co N U U U a N co N m U a N m U M V w v=a cUQQ�� Nv c� �vv�2 c c�UQ a � �Q CXMW a m �C9 �_ �U �� Q3r yww w = 2 mw 0� 7�2 11 y J J J J o�UQ J 7 m 7 7 7 O 3 7 O d dQd d du dd d Cy w NNNNNNMMcoMMMCM Cof-CDMOrNM�Cn0tiCn•MOrNM�OCOr-OMOrNM MCM M�'t I'll 'IT � 'IT 'IT It 000000000000 "tin COI,-C7000 N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N N F- Z LU O r LUQ C90CD0000C (9C9C9CD0(D00(90CDC9C900(DED(D(9C7C9(90(90(D000) F- V O J N CID C � m H C C N N N N 7 (CQ C) U U CU ICC U t� ICO V ICO U ICO U t� ICO U ICO U C C C C C N C C C� C Z Z CD sp w w w w w w w w w w w w to N ` C C 0 w a U-U- a.u-> c 0 t� = OD In N m r*'� CR In ti 'It m Q GOOOOD6NrLOr"tmNln M r N N r N w 0. N eh W �QQQwUQC-�C-�Q ci N W r IO0IOw00wCD0f_I-_f- INM -t 0 0 r— M M CDr •N CI-t 't It Rt't � It 9t It It Iqt F- INININNININININNNNIN Z O LU Q 0 C9 0 C9 0 C9 0 CD C9 CD 0 CD H V O J Tree Inventory/Condition Spreadsheet Greenline Business Park Transect H 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater than 8 inches DBH Status H 2473 TH 19.7 VG TRUE Significant H 2474 TH 13.3 VG TRUE Significant H 2475 WRC 16.8 G TRUE Significant H 2476 WRC 44 VG TRUE Significant H 2477 WRC 45.3 P TRUE Not -Significant H 2478 WRC 33.9 G TRUE Significant H 2479 TH 23.5 P TRUE Not -Significant H 2480 WRC 8.4 G TRUE Significant H 2481 WRC 8.6 G TRUE Significant H 2482 DF 29.8 G TRUE Significant H 2483 WRC 17.4 G TRUE Significant H 2484 WRC 33.2 VG TRUE Significant H 2485 WRC 14.4 F TRUE Significant H 2486 WRC 12 G TRUE Significant H 2487 WRC 14.6 G TRUE Significant H 2488 P Syly. 8.6 P TRUE Not -Significant H 2489 P Sylv. 9 P TRUE Not -Significant H 2490 WRC 31.2 VG TRUE Significant H 2491 WRC 28.2 G TRUE Significant H 2492 WRC 24.7 G TRUE Sign ficant H 2493 WRC 19.4 F TRUE Significant H 2494 WRC 27.4 G TRUE Significant H 2495 DF 8.2 F TRUE Significant H 2496 P Syly. 12.6 P TRUE Not -Significant H 2497 P Syly. 10.7 F TRUE Significant H 2498 P S Iv. 8 P FALSE Not -Significant H 2499 P S Iv. 8.9 F TRUE Significant H 2500 Cedrus 12.8 P TRUE Not -Significant H 2501 WRC 28.9 G TRUE Significant H 2502 P S Iv. 9.7 F TRUE Significant H 2503 P Syly. 10.5 F TRUE Significant H 2504 WRC 21.2 F TRUE Significant H 2505 P Sylv. 9.9 P TRUE Not -Significant H 2506 WRC 20.5 G TRUE Significant H 2507 FS 10.2 G TRUE Significant H 2508 ACER SPP 9.3 G TRUE Significant H 2509 P Syly. 9.5 P TRUE Not -Significant H 2510 1 P Sylv. 8.4 P TRUE Not -Significant H 2511 CH 14.0,14.7 P TRUE Not -Significant H 2512 CH 18.6 P TRUE Not -Significant H 2513 WRC 14.1 D TRUE Not -Significant H 2514 WRC 11.2 F TRUE Significant H 2515 CALOCEDRUS 10.5 F TRUE Significant H 2516 WRC 12,9.2 G TRUE Significant H 2517 TH 19 G TRUE Significant H 2518 LINDEN 17.4 VG TRUE Significant H 2519 SEQ G 11 P TRUE Not -Significant H 2520 CALOCEDRUS1 8.4 P TRUE Not -Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect H 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater than 8 inches DBH Status H 2521 FS 8.7 G TRUE Significant H 2522 DF 8.9 P TRUE Not -Si nificant H 2523 LINDEN 18.5 VG TRUE Significant H 2524 WRC 29.2 G TRUE Significant H 2525 P Syly. 11.1 P TRUE Not -Significant H 2526 FS 8 G FALSE Significant H 2527 j SEQ G 10.5 F TRUE Significant H 2528 TH 16.2 D TRUE Not -Significant H 2529 DF 30.2 G TRUE Significant H 2530 ACER SPP 8.5 F TRUE Significant H 2531 CH 14 F TRUE Significant H 2532 ACER SPP 18.5 G TRUE Significant H 2533 SEQ G 11.4 F TRUE Significant H 2534 P Sylv. 9 F TRUE Significant H 2535 ASH 9.5 G TRUE Significant H 2536 ASH 9.7 G TRUE Significant H 2537 PICEA SPP 8.5 F TRUE Significant H 2538 PICEA SPP 10.8 P TRUE Not -Significant H 2539 LEYLAND 21.4 F TRUE Significant H 2540 LEYLAND 15.2,14.8 G TRUE Significant H 2541 WRC 10.4,12.9,11.1 F TRUE Significant H 2542 WRC 24.5 G TRUE Significant H 2543 WRC 30.2,31 VG TRUE Significant H 2544 WRC 20 G TRUE Significant H 2545 TH 15 F TRUE Significant H 2546 WRC 31.5 VG TRUE Significant H 2547 LEYLAND 25 G TRUE Significant H 2548 WRC 23.3 F TRUE Significant H 2549 TH 19 G TRUE Significant H 2550 WRC 18.4 G TRUE Significant H 2551 WRC 9 F TRUE Significant H 2552 ACER SPP 14.4 G TRUE Significant H 2553 PLATANUS 15.3 G TRUE Significant H 2554 AP 15.9 G TRUE Significant H 2555 FS 9.4 G TRUE Significant H 2556 LINDEN 15.1 VG TRUE Significant H 2557 DF 20.2 G TRUE Significant H 2558 LINDEN 13.8 VG TRUE Significant H 2559 LINDEN 15.5 VG TRUE Significant H 2560 WRC 12.2,11.5,18 G TRUE Significant H 2561 DF 32.3 G TRUE Significant H 2562 WRC 39.3 G TRUE Significant H 2563 WRC 34.8,9.8 G TRUE Significant H 2564 WRC 37.7 G TRUE Significant H 2565 WRC 41.2 G TRUE Significant H 2566 WRC 51.7,14.9 G TRUE Significant H 2567 WRC 19.8,33.4 G TRUE Significant H 2568 WRC 9.4 G TRUE Significant Tree Inventory/Condition Spreadsheet Greenline Business Park Transect H 1 2 3 4 5 6 7 TREE LOCATION TREE # SPECIES DBH Condition Greater than 8 inches DBH Status H 2569 WRC 42.6 G TRUE Significant H 2570 WRC 17.7 G TRUE Significant H 2571 WRC 8.5 G TRUE Significant H 2572 DF 8 F FALSE Not -Significant H 2573 DF 8.5 G TRUE Significant H 2574 Cedrus 13.8 P TRUE Not -Significant H 2575 LEYLAND 13.4 P TRUE Not -Significant H 2576 LEYLAND 20.9 P TRUE Not -Significant H 2577 WRC 9.3 F TRUE Significant H 2578 LINDEN 9.3 G TRUE Significant H 2579 WRC 8 F FALSE Not -Significant H 2580 LEYLAND 14.9 P TRUE Not -Significant H 2581 WRC 20.8 G TRUE Significant H 2582 DF 25 G TRUE Significant H 2583 WRC 16.2 F TRUE Significant H 2584 AP 32.5 G TRUE Significant H 2585 WRC 18.1 G TRUE Significant H 2586 AP 14.8 G TRUE Significant H 2587 WRC 9.6,9 G TRUE Significant H 2588 WRC 8.3 G TRUE Significant H 2589 WRC 22.2 G TRUE Significant H 2590 WRC 20.4 F TRUE Significant H 2591 WRC 16.8 F TRUE Significant H 2592 WRC 28.3 VG TRUE Significant H 2593 ACER SPP 15.6 G TRUE Significant H 2594 ACER SPP 10.8 G TRUE Significant H 2595 WRC 34.8 G TRUE Si nificant H 2596 DF 26.5 G TRUE Significant H 2597 WRC 43.2 D TRUE Not -Significant Geotechnical Engineering Services Report Greenline Business Park Former Weyerhaeuser Site Federal Way, Washington for Federal Way Campus, LLC September 19, 2017 GMENGINEER� 1101 South Fawcett Avenue, Suite 200 Tacoma, Washington 98402 253.383.4940 Geotechnical Engineering Services Report Greenline Business Park Former Weyerhaeuser Site Federal Way, Washington File No. 22247-003-00 September 19, 2017 Prepared for: Federal Way Campus, LLC 11100 Santa Monica Blvd., Suite 850 Los Angeles, California 90025 Attention: Tom Messmer, Vice President- Special Projects Prepared by: GeoEngineers, Inc. 1101 South Fawcett Avenue, Suite 200 Tacoma, Washington 98402 253.383.4940 r Stepp n W. Helvey, LG, LEG, LHG Senior Engineering Geologist Debra C. Overbay, PE Associate SWH:DCO:tt �r C. 0 of W ashi �nr�.r- :alvgisl 0 eased 3—TEP :�l Y1AYl�E HELV�Y ��fi�,� 5�!7 � �Ss�al� Disclaimer, Any electronic form, facsimile or hard copy of the original document (email, text, table, and/or figure), If provided, and any attachments are only a copy of the original document The original document Is stored by GeoEngineers, Inc. and will serve as the official document of record. GEOENGINEERi. I I 1 J Table of Contents INTRODUCTION AND PROJECT UNDERSTANDING.................................................................................................1 SCOPEOF SERVICES...............................................................................................................................................I SITECONDITIONS.....................................................................................................................................................2 SurfaceConditions...............................................................................................................................................2 MappedGeologic Conditions..............................................................................................................................3 SubsurfaceConditions........................................................................................................................................3 Summaryof Soil Conditions.........................................................................................................................3 Groundwater........................................................................................................................................................4 CONCLUSIONSAND RECOMMENDATIONS............................................................................................................4 SiteDevelopment and Earthwork.......................................................................................................................5 Strippingand Clearing..................................................................................................................................5 SubgradeEvaluation.....................................................................................................................................6 Excavation.....................................................................................................................................................6 ExcavationSupport.......................................................................................................................................6 WetWeather Construction...........................................................................................................................7 FillMaterials.........................................................................................................................................................8 On -site Soils...................................................................................................................................................8 SelectGranular Fill........................................................................................................................................9 PipeBedding.................................................................................................................................................9 CrushedRock................................................................................................................................................9 FillPlacement and Compaction..........................................................................................................................9 AreaFills and Bases......................................................................................................................................9 TrenchBackfill............................................................................................................................................ 10 Temporaryand Permanent Slopes.. ................................................................................................................ 10 Groundwater and Drainage Considerations.................................................................................................... 11 SeismicDesign Considerations........................................................................................................................ 11 2015 IBC Seismic Design..........................................................................................................................11 FoundationSupport.......................................................................................................................................... 12 ShallowFoundations.................................................................................................................................. 12 BearingCapacity........................................................................................................................................ 12 Footing Bearing Surface Preparation........................................................................................................ 12 FoundationSettlement.............................................................................................................................. 12 LateralResistance..................................................................................................................................... 12 BuildingPad and Floor Slabs.................................................................................................................... 13 RetainingStructures......................................................................................................................................... 13 PavementRecommendations.......................................................................................................................... 14 PavementDesign....................................................................................................................................... 14 Stormwater Infiltration Evaluation................................................................................................................... 15 LIMITATIONS.....................................................................................................................................................I....15 GEOENGINEER� September 19, 2017 Page i File No. 22247-003-00 LIST OF FIGURES Figure 1. Vicinity Map Figure 2. Site Plan, Existing Condition Figure 3. Site Plan, Proposed Condition Figure 4. Schematic Drawing Hillside Fill APPENDICES Appendix A. Greenline Business Park Site Plan and Cross Sections Appendix B. Field Explorations and Laboratory Testing Figure B-1 - Key to Exploration Logs Figures B-2 through B-8 - Log of Test Pits Figures B-9 through B-11 - Log of Borings Figures B-12 through B-14 - Sieve Analysis Results Appendix C. Explorations and Laboratory Results - July 2016 Appendix D. Explorations and Laboratory Results - August 2016 Appendix E. Report Limitations and Guidelines for Use GEOENGINEERS� September 19, 2017 Page ii File No. 22247-003-00 INTRODUCTION AND PROJECT UNDERSTANDING This report presents the results of our geotechnical engineering services for the proposed Greenline Business Park, to be located generally in the north part of the former Weyerhaeuser Federal Way Campus site. The approximate location of the site is shown in Figure 1, Vicinity Map and Figures 2 and 3, Site Plan. The proposed development area covers about 146 acres, located in the north part of the former Weyerhaeuser Campus. The project site is bounded by Interstate 5 and a meadow area to the west, an office building and undeveloped property to the north, Weyerhaeuser Way South to the east and South 336th Street to the south. The project site wraps around the north, west and south sides of an existing Weyerhaeuser (WTC) building. The existing conditions are shown in Figure 2. GeoEngineers provided preliminary geotechnical studies in July and September 2016 for previously considered warehouse developments on this site. Previous development considerations comprised four warehouse buildings, ranging in size from 775,500 to 133,000 square feet. We understand the currently proposed development includes three buildings within the project site, Buildings A, B, and C. The location of the proposed structures is shown in Figure 3. The proposed buildings are rectangular and range from 638,000 square feet to 147,500 square feet in plan dimension. Parking and loading dock areas are planned around the building perimeters. Four ponds are planned within the west and southwest portions of the site. A fifth pond is planned to be located east of the northeast corner of the site, east of Weyerhaeuser Way South. We understand the ponds will likely detain stormwater and will not be designed for infiltration. The north part of the site is relatively flat and slopes slightly downward to the east. The south part of the site generally slopes downward to the south/southeast. We understand that cuts and fills are planned for the site to achieve level building pads. The distribution of planned cuts and fills are shown in Appendix A, Greenline Business Park Site Plan and Cross Sections. Excavations of up to about 15 feet below existing grade are planned for the north part of the site, north of Building "A." Fills up to about 15 feet thick are planned for the south portion of the site, at the south end of proposed Building "B." Geologic materials mapped within and around the site comprise Vashon-age glacial till. As previously stated, we completed subsurface explorations (test pits) and performed preliminary design studies for others (KG Investment) on the subject site. We understand that this information is available for this project. SCOPE OF SERVICES The purpose of our services is to provide preliminary geotechnical engineering recommendations for the proposed Greenline Business Park development. Federal Way Campus, LLC authorized our services on June 30, 2017. GeoEngineers performed the following tasks: 1. Review readily available published geologic data and our in-house files for existing information on soil and groundwater conditions in the project vicinity. GEOENGINEER� September 19, 2017 Pagel File No. 22247-003-00 2. Review the proposed Greenline Business Park project plans provided by the design team. This includes a proposed clearing and grading plan and site cross sections. Copies of these documents are contained in Appendix A. 3. Review the previously completed subsurface explorations and compare the depth and distribution of these explorations with the currently proposed development. Develop an exploration plan to supplement the existing data. Mobilize to the site to locate the proposed explorations. Coordinate utility locates for the explorations using the One -Call utility notification center and a private utility locate subcontracted to GeoEngineers. 4. Supplement the existing subsurface data by completing six test pit excavations and three borings. The borings extended to depths of about 20 feet below ground surface (bgs). 5. Perform laboratory tests on selected soil samples obtained from the supplemental explorations to evaluate pertinent engineering characteristics. Bulk samples were obtained from the test pits directly from the backhoe bucket. Driven soil samples were collected from the borings. Tests included moisture content determinations, fines content determinations and particle size analyses. 6. Characterize site conditions based on our site observations, existing data review and the results of our supplemental subsurface exploration and testing. 7. Develop preliminary recommendations for site preparation and earthwork based on the data and our understanding of the proposed site development. We include an evaluation of the suitability of on -site soil for use as structural fill beneath the building and pavement areas. We also discuss gradation criteria for imported fill, possible adverse effects of weather on construction activities and suitability of on -site soil during wet weather conditions. 8. Provide geotechnical seismic design information in accordance with 2015 International Building Code (IBC) criteria. We also present our opinion on the potential for liquefaction and lateral spreading at the site. 9. Provide general shallow foundation design recommendations, including suitable bearing materials, allowable soil bearing pressure, subgrade preparation criteria, lateral load resistance values and estimated post -construction settlements. 10. Provide recommendations for support of on -grade floor slabs, including modulus of subgrade reaction, capillary break, vapor retarder and underslab drainage, as appropriate. 11. Provide layer thickness recommendations for asphalt concrete (AC) pavement design sections, including subgrade preparation and typical pavement sections for heavy and light traffic areas based on our experience. 12. Provide a discussion of suitability of site soils for stormwater infiltration. SITE CONDITIONS Surface Conditions The site slopes down to the west and south from about Elevation 450 feet in the northwest to about Elevation 394 feet in the south. GEOENGINEER September 19, 2017 Page 2 File No. 22247-003-00 The north portion of the site is presently occupied by existing access roads, asphalt -paved parking areas and landscaped/forested areas. The southwest and west parts of the site are occupied by a grass -covered meadow/field area. The remainder of the site is vegetated with a moderate to thick stand of second or third growth fir, cedar and deciduous trees with a moderate to thin understory of brush. We observed a generally thinner understory of ferns and brush in part of the proposed east pond area. A network of trails including a gravel road and foot paths exists within some of the forested areas. A small, man-made pond is located within the central part of the site. I Mapped Geologic Conditions General geologic conditions in the site vicinity were evaluated by reviewing "Geologic Map of the Poverty Bay 7.5 Minute Quadrangle, King and Pierce Counties, Washington, 2004" prepared for the United States Geological Survey (USGS). Native geologic materials mapped at and in the site vicinity consist of Vashon-age Glacial Till (map symbol Qvt). Vashon till was deposited by and directly beneath the advancing Vashon-age glacier as it moved south through the site area. The deposit typically consists of a dense to very dense mixture of silt, sand, gravel, cobbles and some boulders. Subsurface Conditions Subsurface soil and groundwater conditions at the site were evaluated by reviewing logs of test pit explorations completed at the site in July and August 2016, and supplementary explorations completed in July 2017. Details of the supplementary field exploration and laboratory testing programs are presented in Appendix B. Supplementary exploration logs and results of the laboratory testing program are also presented in Appendix B. Logs and laboratory testing data for test pits completed in the northern portion of the site in July 2016 are contained in Appendix C. Similarly, logs and laboratory testing data for test pits completed at the site in August 2016 are contained in Appendix D. The approximate locations of all the explorations are shown in Figures 2 and 3. _ Summary of Soil Conditions Varying thicknesses of forest duff and/or topsoil and sod were encountered from ground surface to depths ranging from about 1 to 18 inches in most of the explorations. All explorations encountered and were J terminated in glacial deposits. Dense to very dense glacial till was typically encountered beneath a loose to dense or stiff to very stiff weathered till. Loose to dense fill was encountered above the native glacial deposits in the following test pit explorations: r, July 2016 test pits TP-3, TP-15, TP-16, TP-20, TP-23, TP-24 and TP-30. The fill extends to depths ranging between about 2 and 7.5 feet at the test pit locations. F- August 2016 test pits TP-5 through TP-7, TP-10, TP-12, TP-15, TP-20, TP-24, TP-25, TP-27, TP-29 and TP-31. The fill extends to depths ranging between 1.75 and 5.5 feet at the test pit locations. Fill was not encountered in the supplemental explorations completed for this study. Fill encountered in the 2016 explorations consisted of medium dense silty sand and appeared to be reworked native till materials. GEOENGINEERS� September 19, 2017 Page 3 File No. 22247-003-00 Weathered till and unweathered till generally comprised a mixture of silty gravel and silty sand with varying amounts of gravel and occasional cobbles and boulders. Layers or lenses of medium stiff to hard silt with sand and gravel was present within the weathered glacial till at the location of the following explorations: Ej July 2016 test pit TP-1 August 2016 test pits TP-1, TP-17, TP-20 and TP-27 n July 2017 test pits TP-3N, TP-4N, TP-7N This material may exist in other portions of the site not explored by our test pits and borings. Laboratory testing on samples of fill, weathered and unweathered till encountered in our explorations yielded fines contents (material passing the U.S. No. 200 sieve) ranging from 26 to 94 percent. In -place moisture contents ranged from 6 to 26 percent. Recessional outwash was encountered to the full depth explored in test pit TP-5N, located in a proposed pond area in the northeast corner of the site. This material comprised medium dense to dense silty sand and sand with silt. Fines contents of the outwash ranged from 7 to 19 percent. Percent moisture ranged from 4.5to8. Groundwater Groundwater was not observed in any of the test pits at the time of excavation. Groundwater was encountered in the three borings at depths ranging from 17.5 to 20 feet bgs. Based on our experience a seasonal, perched groundwater table often forms on top of the dense to very dense glacial till material or where relatively permeable weathered till or surficial fill or outwash overlies the till. We expect groundwater seepage amounts and the depths at which it occurs will vary with season and precipitation. Zones of shallow perched groundwater should be expected/anticipated during the wetter winter and early spring months. Groundwater encountered in the borings may represent seepage in the cleaner lenses of the glacial till or a deeper, regional groundwater table. CONCLUSIONS AND RECOMMENDATIONS Based on the results of our subsurface exploration and testing program, it is our opinion that the site is generally suited for the proposed warehouse structure development. We understand that cuts and fills will be required to create level building surfaces at the site. A summary of the primary geotechnical considerations for the proposed buildings is provided below. The summary is presented for introductory purposes only and should be used in conjunction with the detailed recommendations presented in this report. ❑ The native and fill soils contain a moderate to very high percentage of fines and are very sensitive to small changes in moisture content. These soils are susceptible to disturbance from construction traffic when the moisture content is more than a few percent above the optimum moisture content for compaction. These soils will be difficult, if not impossible, to work or compact when wet or if earthwork is performed in wet weather. Therefore, we recommend that earthwork be performed during the GEoENGINEER September 19, 2017 Page 4 File No 22247-003-00 normally drier periods of the year. Moisture conditioning of site soils will be required in order to obtain the required compaction. a We anticipate that some of the native and fill soils will only be suitable for use as structural fill during extended periods of dry weather. The silt soils encountered in some of the test pits will not be suitable for use as structural fill regardless of weather conditions. We recommend imported granular soils be used for structural fill if construction occurs during periods of wet weather. uu Up to 15 feet of cuts and fills will be required to establish site grades. We recommend graded areas be protected before the onset of rainy weather because of the highly moisture sensitive character of much of the on -site soil. 11 We recommend constructing temporary haul roads underlain by quarryspalls or coarse crushed ballast material to help protect subgrades from disturbance and degradation under construction traffic. * Shallow foundations may be designed using an allowable bearing pressure of 3,000 pounds persquare foot (psf) where footings are founded on structural fill or the recompacted surficial native soils. If dense native till is exposed at foundation level, the allowable bearing pressure can be increased to 5,000 psf. Where existing fill is exposed at footing subgrade, we recommend a minimum 2-foot-thick zone of structural fill underlie the footings. All new fill placed at the site should be compacted to the structural fill standard described in this report. We recommend floor slabs be underlain by a minimum 4-inch-thick capillary break consisting of coarse grained aggregate with negligible sand or silt (similar to AASHTO Grading No. 67). Site Development and Earthwork Site development work will likely include removing existing trees and vegetation, stripping of forest duff, stripping of AC drive and parking areas, stripping of topsoil and root layers, excavation in the approximate center of proposed Building B and the north parts of proposed Buildings B and C, and placing fill in select portions of the proposed building sites to achieve level building pads. We recommend that the existing storm pond at the site, near the south edge of proposed Building C, be drained and disconnected from stormwater delivery systems prior to earthwork. The site soils are highly moisture sensitive due to moderate to very high fines content. Grading and reuse of the on -site soils at this site will only be practical during the dry season (typically July through September). Moisture conditioning necessaryto obtain proper compaction of on -site soil will likely not be practical during the cooler and wetter winter months. Accordingly, we recommend a contingency be included in the project budget and schedule for export of unsuitable wet on -site soil and import of select granular soil if earthwork will occur in the winter months. Stripping and Clearing The existing trees, shrubs, grass, topsoil, unsuitable native soils, AC, unused utilities and unsuitable fill soils should be stripped and removed from all proposed building and pavement areas. Based on our explorations, the depth of stripping to remove unsuitable surface organic materials should generally vary between 6 and 12 inches. Greater stripping depths will be required to remove localized zones of loose or organic -rich soil and tree roots, and to remove unsuitable materials within the pond. The primary root systems for trees and shrubs should be completely removed. Required stripping depths should be GEOENGINEERS� September 19, 2017 Page 5 File No. 22247-003-00 evaluated based on observations during the stripping operation. Stripped organic material should be transported off site for disposal or processed and used as fill in landscaping areas. Existing fill was encountered in TP-7, TP-27 and TP-31 (4.5- to 5.5-foot depth). Unsuitable fills might be present in other parts of the site not explored by our test pits and borings. The contractor should be prepared to selectively remove debris or other unsuitable materials if encountered in existingfill at this site. AC within existing road and parking areas should be removed, or pulverized and utilized on site as approved by the geotechnical engineer. Abandoned subgrade utilities should be anticipated and removed as necessary throughout the site particularly near the existing parking lots and roads. Unsuitable materials including organic and soft soil deposits within the pond should be stripped and removed during mass grading. Stormwater piping and other delivery system features should also be removed. Subgrade Evaluation After stripping and excavation to planned subgrade is complete we recommend the exposed soil be proofrolled or probed and then compacted to a firm and unyielding condition. If dry weather conditions persist, we recommend that the subgrade be evaluated by proofrolling with a loaded dump truck or similar heavy rubber -tired construction equipment to identify soft, loose or unsuitable areas. The proofrolling should be conducted prior to placing fill. If the subgrade is prepared during or exposed to wet weather, we recommend that it be evaluated by probing with a steel probe rod. The proofrolling/probing should be observed by a qualified geotechnical engineer, who will evaluate the suitability of the subgrade and identify any areas of yielding, which are indicative of soft or loose soil. If soft or otherwise unsuitable areas revealed during proofrolling cannot be compacted to a stable and uniformly firm condition, we recommend that: (1) the subgrade soils be scarified (e.g., with a ripper or a farmer's disc), aerated and recompacted, or (2) the unsuitable soils be excavated to firm soil and replaced with structural fill, as recommended by the geotechnical engineer. Excavation We anticipate large dozers with rippers may be required for mass grading where the subgrade comprises unweathered glacial till. Conventional earthmoving equipment in proper working order should be capable of making necessary excavations for utilities and footings. We recommend that footing and trench excavations be performed using a smooth -blade bucket to prevent excessive disturbance of the excavation base. Boulders and large cobbles are often present in glacial till and recessional outwash deposits in the area and will likely be encountered during grading and/or utility excavations. Accordingly, the contractor should be prepared to remove boulders, if encountered. Boulders may be removed from the site or buried in landscape areas. Voids caused by boulder removal must be backfilled with structural fill. Excavation Support Shallow excavations (4 feet or less) in dense glacial deposits should stand at near vertical inclinations, provided groundwater seepage is not present in the cut face. Excavations deeper than 4 feet must be shored or laid back at a stable slope if workers are required to enter. GEoENGINEERS� September 19, 2017 , Page 6 File No. 22247-003-00 Shoring for utility excavations must conform with the provisions of Title 296 Washington Administrative -1 Code (WAC), Part N, "Excavation, Trenching and Shoring." Regardless of the soil type encountered in the l excavation, shoring, trench boxes or sloped sidewalls will be required under Washington Industrial Safety and Health Act (WISHA). While this report describes certain approaches to excavation and dewatering, the contract documents should specify that the contractor is responsible for selecting excavation and dewatering methods, monitoring the excavations for safety and providing shoring, as required, to protect personnel and adjacent structures. Wet Weather Construction Trafficability of the on -site soils will be severely limited during wet weather, or if the subgrade moisture content is more than a few percentage points above optimum. When wet, the on -site soils are susceptible to disturbance and generally will not provide adequate support for construction equipment. The on -site soils will be difficult, if not impossible, to adequately work or compact during periods of wet weather. Site Grading If site grading and fill placement occurs during wet weather conditions the following recommendations should be included in the development plan. Stripping and site preparation should be accomplished using track -mounted equipment and subgrade protection measures should be used. For example, a track - mounted excavator equipped with a smooth -edged bucket could be used working from the currently developed surface or a granular pad and loading into trucks supported on granular haul roads or working outward from the stripped surface. If the site subgrade is wet, it should be evaluated by probing with a steel rod, ratherthan by proofrolling. Soil that is disturbed duringsite preparation activities during wet conditions, _ as well as soft or loose zones identified during probing, should be removed and replaced with compacted structural fill. Granular Haul Roads and Working Blankets Wet weather construction in the silty native or fill soils will require granular haul roads and granular pads under the building structures to protect the subgrade. If the pavement areas are constructed during wet weather, they will also require a granular working blanket. The use of granular haul roads will be necessary for support of construction traffic during the rainy season (typically from October through June). Based on our experience, 18 to 24 inches of sand and gravel (which could be gravel base or fill material), crushed rock or quarry spalls with little to no fines will be necessary to provide support for construction equipment. Use of a geotextile fabric can reduce mixing of the subgrade and road support materials. It also may reduce the thickness of surfacing required. If gravel base material 1 is used, the temporary roads could be constructed above the finished subgrades and extra material bladed onto other areas of the site when the roads are no longer necessary. Wet -Weather Fill We recommend fill placed during wet weather be select granular fill (pit run) or crushed rock as described in the "Fill Materials" section of this report. Erosion and Sedimentation Control The site will be susceptible to erosion during wet weather conditions, particularly if large segments of exposed subgrades are exposed to rainfall. Development and implementation of an Erosion and Sedimentation Control Plan should reduce the project impact on erosion -prone areas. The Plan should be GEOENGINEERS� September 19, 2017 Page 7 File No 22247-003-00 designed in accordance with applicable city, county and/or state standards. The Plan should incorporate basic planning principles, including: scheduling grading and construction to reduce soil exposure; re -vegetating or mulching denuded areas; * directing runoff away from exposed soils; * reducing the length and steepness of slopes with exposed soils; a, decreasing runoff velocities; * preparing drainage ways and outlets to handle concentrated or increased runoff; © confining sediment to the project site; and inspecting and maintaining control measures frequently. Some sloughing erosion and raveling of exposed or disturbed soil on slopes should be expected, particularly if the work is completed during the wet season. We recommend that disturbed soil be restored promptly so that surface runoff does not become channeled. Temporary erosion protection should be used and maintained in areas with exposed or disturbed soils to help reduce erosion and transport of sediment to adjacent areas and receiving waters. Permanent erosion protection should be provided by paving, structure construction or landscape planting. Until the permanent erosion protection is established and the site is stabilized, site monitoring may be required by qualified personnel who will evaluate the effectiveness of the erosion control measures and recommend repairs and/or modifications as appropriate. Provision for modifications to the erosion control system based on monitoring observations should be included in the Erosion and Sedimentation Control Plan. Fill Materials The workability of material used as structural fill will depend on the gradation and moisture content of the soil. As the amount of fines (material passing the U.S. No. 200 sieve) increases, soil becomes increasingly sensitive to small changes in moisture content and adequate compaction becomes more difficult, if not impossible to achieve. We recommend that select granular fill or crushed rock be used as structural fill during the rainy season. The following paragraphs summarize the material requirements for fill and backfill. On -site Soils The native glacial till soils may be considered for use as structural fill during periods of extended dry weather, provided they can be properly moisture conditioned. Soils encountered in our explorations, particularly the silt materials, will be difficult, if not impossible, to work or adequately compact during periods of wet weather or if the in -place moisture condition of these soils is over optimum during dry weather. On -site materials used as structural fill must be free of roots, organic matter and other deleterious materials and particles larger than 3 inches in diameter. GEoENGINEERs� September 19, 2017 , Page 8 File No. 22247-003-00 Select Granular Fill Select granular fill (pit run) must consist of imported well -graded sand, sandy gravel, or crushed rock with a maximum particle size of 3 inches and less than 5 percent passing a U.S. No. 200 sieve. Organic matter, debris, or other deleterious material must not be present. Granular fill used during periods of prolonged dry weather may have up to 12 percent passing a U.S. No. 200 sieve. Pipe Bedding Trench backfill forthe bedding and pipe zone must consist of well -graded granular material with a maximum particle size of 3/4 inch and less than 5 percent passing the U.S. No. 200 sieve. The material must be free of roots, debris, organic matter, and other deleterious material. Crushed Rock Crushed rock fill must consist of clean, durable, crushed angular rock that has a maximum particle size of 4 inches, is well graded between coarse and fine sizes, and has less than 5 percent fines (material finer than a U.S. No. 200 sieve). A smaller maximum particle size will be required for some applications as discussed in other sections of this report. Gravel materials should be crushed to have at least two fractured faces. Organic matter, debris, or other deleterious material must not be present. Fill Placement and Compaction Fill soils should be compacted at a moisture content near optimum. The maximum allowable moisture content varies with the soil gradation, and should be evaluated during construction. Clayey soils and other fine granular soils may be difficult or impossible to compact during persistent wet conditions. Fill and backfill material should be placed in uniform, horizontal lifts, and uniformly densified with vibratory compaction equipment. The maximum lift thickness will vary depending on the material, compaction equipment used, and possibly weather conditions, but should generally not exceed 10 inches in loose thickness if select granular fill, as described in this report, is used. Thinner lifts will be required if on -site materials are used as structural fill. Typical loose lift thicknesses for re -used glacial till material should be no thickerthan 4 inches to achieve the recommended compaction. Thinner liftthicknesses may be required depending on soil and site conditions. Area Fills and Bases Fill placed to raise site grades and aggregate base materials under foundations, slabs, and pavements should be placed on a prepared subgrade that consists of firm, inorganic native soils or compacted fill. Fill must be compacted to at least 95 percent of the maximum dry density (MDD) determined by ASTM International (ASTM) Test Method D 1557 (modified Proctor). Where footings are founded on existing fill, the upper 2 feet of fill should be recompacted to the structural fill criteria (95 percent), or excavated and replaced with import structural fill. In pavement areas, the compaction criteria can be reduced to 92 percent below a depth of 2 feet from finished subgrade. During wet weather or in areas that are particularly sensitive to subgrade disturbance, we recommend placing a woven geotextile between the subgrade and the first lift of fill. The first lift, provided it is select granular fill, should be 10 inches thick and should be densified by static rolling until it supports the vibratory compaction equipment. GEOENGINEERS� September 19, 2017 Page 9 File No. 22247-003-00 Slope Fill Placement Based on our understanding of the proposed development, earth fills will be placed on existing sloping ground. In such cases we recommend that the material be placed and compacted using hillside grading techniques, as provided below. The constructed fill should be benched into the existing slope face. Bench excavations should be level and extend into the slope face until a vertical step of about 3 feet is constructed. The upper layer of organic soil beneath the existing slope face should be removed and wasted. The remaining soil excavated from each bench can be spread into the next lift of structural fill. A typical cross -sectional drawing of slope fill is shown on Figure 4, Schematic Drawing Hillside Fill. Trench Backfill Backfill in the bedding and pipe zone should be compacted to 90 percent of the MDD as determined by ASTM Test Method D 1557, or as recommended by the pipe manufacturer. In nonstructural areas, trench backfill above the pipe zone should be compacted to at least 85 percent of the MDD as determined by ASTM Test Method D 1557. Suitable native soils or select granular soils should be acceptable in non-structural areas. Within structural areas, trench backfill placed above the pipe zone at depths greater than 2 feet below the finished subgrade, must be compacted to at least 92 percent of the MDD as determined by ASTM Test Method D 1557 and to 95 percent MDD when placed within 2 feet of finished subgrade. Trench backfill in structural areas should consist of select granular fill or crushed rock as described in the previous sections. Temporary and Permanent Slopes We recommend that permanent cut and fill slopes be inclined no steeperthan 2H:1V (horizontal to vertical). Flatter cut slopes may be necessary in areas where persistent groundwater seepage or zones of soft or loose soils are encountered. Temporary cut slopes should be inclined no steeper than about 11/2H:1V. A steeper temporary cut of 1H:1V is feasible in the glacial till soils, provided seepage is not present. Surface loads should be kept at a minimum distance of at least one-half the depth of the cut away from the top of temporary slopes. Temporary cut slopes and shoring must comply with the provisions of Title 296 WAC, Part N, "Excavation, Trenching and Shoring." The contractor performing the work must have the primary responsibility for protection of workmen and adjacent improvements, determining whether shoring is required, and for establishing the safe inclination for open -cut slopes. Fill slopes should be carefully compacted on the slope face. Alternatively, the fill embankment can be over- built and cut back to expose properly compacted soil. To reduce the potential for erosion, newly constructed slopes should be planted or hydroseeded shortly after completion of grading. Some sloughing and raveling of the slopes should be expected until the vegetation is established. This may require localized repairs and reseeding. Temporary covering, such as heavy plastic sheeting, jute fabric, loose straw, or excelsior matting should be used to protect unvegetated slopes during periods of rainfall. GEOENGINEERS� September 19, 2017 Page 10 File No. 22247-003-00 Groundwater and Drainage Considerations We recommend that pavement surfaces be sloped so that surface drainage flows away from the buildings. We recommend that all roof drains be collected in tightlines and routed into the storm drain system. Perched groundwater will likely develop on top of the very dense glacial till in unpaved areas during the rainy season, which may impact construction activities. We recommend a perimeter footing drain be constructed around the building footprint to capture perched groundwater zones. This is critical on glacial till sites due to the potential for perched groundwater flow, moving laterally on the glacial till contact and within cleaner sand seams in the till. Seismic Design Considerations 2015 IBC Seismic Design We recommend the parameters in Table 1 for use in seismic design in accordance with 2015 IBC. TABLE 1. SEISMIC DESIGN PARAMETERS 2015 IBC Seismic Design Parameters Spectral Response Acceleration at Short Periods (Ss) 1.29g Spectral Response Acceleration at 1-Second Periods (St) 0.49g Site Class C Design Peak Ground Acceleration (PGA) 0.54g Design Spectral Response Acceleration at Short Periods (SDS) 0.86g Design Spectral Response Acceleration at 1-Second Periods (SDI) 0.43g Liquefaction Potential Liquefaction refers to a condition where vibration or shaking of the ground, usually from earthquake forces, results in development of excess pore pressures in loose, saturated soils and subsequent loss of strength in the deposit of soil so affected. In general, soils that are susceptible to liquefaction include loose to medium dense sands to silty sands that are below the water table. Based on the soil type, and relative density of the soils encountered, it is our opinion that the potential for liquefaction within the proposed development portion of the site area is low. Lateral Spreading Potential Lateral spreading related to seismic activity typically involves lateral displacement of large, surficial blocks of non -liquefied soil when a layer of underlying soil loses strength during seismic shaking. Lateral spreading usually develops in areas where sloping ground or large grade changes (including retaining walls) are present. Based on our understanding of the subsurface conditions and current site topography, it is our opinion that the risk of lateral spreading is low. Ground Rupture Because of the anticipated infrequent seismic event recurrence, the site location with respect to the nearest known active crustal faults and the presence of thick glacial deposits overlying bedrock, it is our opinion that the risk of ground rupture at the site due to crustal faulting is low. GEoENGINEERS� September 19, 2017 Page 11 File No. 22247-003-00 J Foundation Support Shallow Foundations We anticipate that warehouse -type buildings can be supported on continuous wall or isolated column footings established on undisturbed native soils, on structural fill placed over undisturbed native soils, or on a minimum 2-foot thickness of structural fill overlying existing fill soils. For preliminary purposes, we recommend that isolated column and continuous wall footings have minimum widths of 24 and 18 inches, respectively. The exterior footings should be established at least 18 inches below the lowest adjacent grade. The recommended minimum footing depth is greater than the anticipated frost depth. Interior footings can be founded a minimum of 12 inches below the top of the floor slab. Bearing Capacity We recommend that footings founded on recompacted surficial soils or new structural fill be proportioned using a maximum allowable soil bearing pressure of 3,000 psf. If the building footings are founded on undisturbed dense to very dense glacial till a maximum allowable soil bearing pressure of 5,000 psf could be considered. However, footing embedment would likely be greater than the minimum value for frost protection. Where existing fill is exposed at footing subgrade elevation, we recommend a minimum 2-foot zone of structural fill underlie the footing. These bearing pressures applyto the total of dead and long-term live loads and may be increased by one-third when considering earthquake or wind loads. This is a net bearing pressure. The weight of the footing and overlying backfill can be ignored in calculating footing sizes. Footing Bearing Surface Preparation Footing excavations should be performed using a smooth -edged bucket to limit bearing surface disturbance. Loose or disturbed materials present at the base of footing excavations should be removed or compacted. Foundation bearing surfaces should not be exposed to standing water. If water infiltrates and pools in the excavation, it must be removed and the bearing surface reevaluated before placing structural fill or reinforcing steel. We recommend that an experienced geotechnical engineer observe all foundation excavations before placing reinforcing steel in order to confirm that adequate bearing surfaces have been achieved and that the soil conditions are as anticipated. Unsuitable foundation subgrade soils must be removed and replaced with structural fill as recommended by the geotechnical engineer. It may be prudent to place a thin mud mat of lean concrete to protectthe bearing surface if footing excavations are to remain open in wet weather. Foundation Settlement We estimate that settlements of footings designed and constructed as recommended will be less than 3/4 inch, forthe anticipated loading conditions. Differential settlements between comparably loaded isolated column footings or along 50 feet of continuous footing will be less than % inch. Settlement is expected to occur rapidly as loads are applied. Lateral Resistance The ability of the soil to resist lateral loads is a function of frictional resistance, which can develop on the base of footings and slabs and the passive resistance, which can develop on the face of below -grade GEOENGINEERS� September 19, 2017 Page 12 File No 22247-003-00 elements of the structure as these elements tend to move into the soil. For footings and floor slabs founded in accordance with the recommendations presented above, the allowable frictional resistance may be computed using a coefficient of friction of 0.35 applied to vertical dead -load forces. The allowable passive resistance on the face of footings, grade beams or other embedded foundation elements may be computed using an equivalent fluid density of 300 pounds per cubicfoot (pcf) for undisturbed on -site soils or structural fill extending out from the face of the foundation element a distance at least equal to two and one-half times the depth of the element. The passive earth pressure and friction components may be combined provided that the passive component does not exceed two-thirds of the total. The passive earth pressure value is based on the assumptions that the adjacent grade is level and that groundwater remains below the base of the footing throughout the year. The top foot of soil should be neglected when calculating passive lateral earth pressures unless the foundation area is covered with pavement or is inside a building. The lateral resistance values include a safety factor of approximately 1.5. Building Pad and Floor Slabs A modulus of subgrade reaction of 150 pounds per cubic inch (pci) can be used for designing the building floor slab provided that the subgrade has been prepared in accordance with the "Subgrade Evaluation" section. We recommend that on -grade slabs be underlain by a minimum 4-inch-thick capillary break layer to reduce the potential for moisture migration into the slab. The capillary break material should consist of a coarse aggregate with negligible sand or silt similar to AASHTO Grading No. 67. The material should be placed as recommended in the "Fill Placement and Compaction" section. A vapor retarder should be used as necessary to control moisture penetration through the slab. This is especially important in areas where floor coverings, adhesives or tiles are planned. ` 1 Retaining Structures 1 Retaining structures for loading docks or other building walls that are free to rotate slightly around the base + should be designed for active earth pressures using an equivalent fluid unit weight of 35 pcf. This value is based on the following assumptions: 1. The walls will not be restrained against rotation when the backfill is placed. 2. The backfill is level. i 3. The backfill for a distance of at least 12 inches behind the wall consists of free -draining granular Jmaterials. 4. Hydrostatic pressures will be controlled by a back drain. If retaining walls are restrained against rotation during backfilling, they should be designed for an at -rest equivalent fluid unit weight of 55 pcf. Surcharge loads applied closer than one-half of the wall height should be considered as uniformly distributed horizontal pressures equal to one-third of the distributed vertical surcharge pressure. Footings for retaining walls should be designed as recommended for shallow foundations. 1 GEoENGINEER� September 19, 2017 Page 13 File No. 22247-003-00 I Backfill should be placed and compacted as recommended in the "Fill Placement and Compaction" section of this report. The backfill should include drainage provisions to prevent hydrostatic pressures from developing behind walls. Measures should be taken to prevent overcompaction of the backfill behind the wall. This can be done by placing the zone of backfill located within 5 feet of the wall in lifts not exceeding 6 inches in loose thickness and compacting this zone with hand -operated equipment such as a vibrating plate compactor orjumping jack. Pavement Recommendations Pavement Design Based on our experience, we provide typical asphalt concrete (AC) and Portland cement concrete (PCC) pavement sections below. These pavement sections are typical for commercial facilities in this area but may not be adequate for heavy construction traffic loads such as those imposed by concrete transit mixers, dump trucks or cranes or for unusual design traffic conditions. Additional pavement thickness may be necessary to prevent pavement damage during construction or if anticipated truck traffic for this facility is higher than typical. We can provide a specific design if detailed truck traffic loading information is provided. The recommended sections assume that final improvements surrounding the pavement will be designed and constructed such that stormwater or excess irrigation waterfrom landscape areas does not accumulate below the pavement section or pond on pavement surfaces. Pavement subgrade must be prepared as previously described. Crushed surfacing base course and subbase must be moisture conditioned to near optimum moisture content and compacted to at least 95 percent of MDD (ASTM D 1577). Crushed surfacing base course must conform to applicable sections of 4-04 and 9-03.9(3) of the Washington State Department of Transportation (WSDOT) Standard Specifications. Hot mix asphalt must conform to applicable sections of 5-04, 9-02 and 9-03 of the WSDOT Standard Specifications. PCC must conform to applicable sections of 5-05, 9-01 and 9-03 of the WSDOT Standard Specifications. Standard -Duty AC Pavement - Automobile Driveways and Parking Areas r 2 inches of hot mix asphalt, class 1/2 inch, PG 58-22 F. 4 inches of crushed surfacing base course € 6 inches of subbase consisting of select granularfill to provide uniform grading and pavement support, to maintain drainage, and to provide separation from fine-grained subgrade soil m Native subgrade or structural fill prepared in accordance with the "Site Development and Earthwork" section Heavy -Duty AC Pavement - Areas Subject to Truck Traffic t 3 inches of hot mix asphalt, class 1/2 inch, PG 58-22 LL! 6 inches of crushed surfacing base course L! 6 inches of subbase consistingof select granularfill to provide a uniform gradingsurface and pavement support, to maintain drainage, and to provide separation from fine-grained subgrade soil u Native subgrade or structural fill prepared accordance with the "Site Development and Earthwork" section GEoENGINEERS� September 19, 2017 Page 14 File No 22247-003-00 PCC Pavement - Areas Subject to Heavy Truck Traffic L 6 inches of PCC pavement (28-day compressive strength of 6,000 pound per square inch [psi] and a modulus of rupture of 600 psi) r 6 inches of crushed surfacing base course v- Native subgrade or structural fill prepared accordance with the "Site Development and Earthwork" section Stormwater Infiltration Evaluation As previously described the site soils generally consist of weathered till over unweathered till. Grain -size j distribution analyses of these soils indicate fines contents ranging between about 26 and 95 percent. The 1 unweathered till is typically in a dense to very dense condition and has very low permeability with respect to the vertical and horizontal flow of water. Based on the soil gradation data, and our experience, it is our opinion there is very limited infiltration potential at this site. Because of these factors we recommend that stormwater detention be used for site development. Recessional outwash was encountered in one test pit TP-5N. This pit is within the proposed pond located east of Weyerhaeuser Road, east of the northeast corner of the site. Outwash was not encountered in two I other test pits completed within the proposed pond area. It is possible that some measure of stormwater infiltration within this pond is achievable. However, further study will be required to evaluate the vertical and lateral extent of the outwash material, and the permeability of the outwash. LIMITATIONS We have prepared this geotechnical report for use by Federal Way Campus, LLC and their agents for the proposed development project described in this report. The project agents may distribute copies of this report to authorized agents and regulatory agencies as may be required for the project. Within the limitations of scope, schedule and budget, our services have been executed in accordance with generally accepted practices in the field of geotechnical engineering in this area at the time this report was prepared. No warranty or other conditions express or implied should be understood. Please refer to Appendix E, Report Limitations and Guidelines for Use, for additional information pertaining Jto use of this report. GEOENGINEERS� September 19, 2017 Page 15 File No. 22247-003-00 J federal Way High a „� n•la M.d45chool Sthool � N — {y $ lake 0olbll Elementary ^ < 4 5308[h SL S308th St �, School Sad' a �� S3l 2S 310th St — r a PI for ® C , It 3 J 5 3121h St 5 3121h St 5 312[h S,Steel lake Party n S 312th StS a 3121h StN S J s 5313th St Q wS 3141h St 5314th St D a o e +in L c a S ` > Mirror Lake Elementary 5 3151h St art n S 53hy5 Y S 315[h PI School 5 3161 h St t} S 31015 tnlli PI S316th SL "' (A)HStrvman High �3171h St a School < 5 317th St S 316th PI S 316[h St N , D S 320[h S1 w ® : 320th S[ S 320th St S 32Ut St h Sou1h Commons n a a Sp Q¢ S c 5322nd St s 1, ^ rn r y the Commom Al m n $ ^ Federal Way 532Sth S, 8 S324th St 5324th St 2 Ninged Foot Way y _ 'yerion a n S f Way n s a` v S 32 8th Sl n .f• Old. —Park . S238[h PI = e � m w £ 'J',2, J, y0 5 330th St - ✓, SITE St .. 5332nd N 5 333rd 5t a S 333rd 5[ Nc tr f $ S 336th St 5 336th St v a 53331* h 5 y a ♦a W w T v c 71 TB r 3 Good Samaritan t Church S 3381h St .� t S 338th SS rhnnian Faith a — °1 Q D Center ^ i n ^ S KITTS CORNER s '15 341sl PI N c S 343rd Sr c 53441h St 5344[h St ti } 6lh A-5 m Franc, Haapnal S 348th St Renton Union Kent Shei[on Tacoma P D a s y Notes: v 1. The locations of all features shown are approximate. 2. This drawing is for information purposes. It is intended to assist in showing features discussed in an attached document. GeoEngineers, Inc. cannot guarantee the accuracy and content y of electronic files. The master file is stored by GeoEngneers, 3 Inc. and will serve as the official record ofthis communication. e Data Source: Mapbox Open Street Map, 2017 Projection: NAD 1983 UTM Zone ION L' %n a' 342nd St l R' 3441h Way 534; Ih St r �� H 53hSS�S N c S 348[h St Z S N w B S 2,000 0 2,000 Feet Vicinity Map Proposed Greenline Business Park Federal Way, Washington GEOENGINEERS� Figurel Legend _ TP-1N* Test Pits by GeoEngineers, 2017 B-1N* Borings by GeoEngineers, 2017 TP 1-> Test Pit Completed in July 2016 I.ti " ', `� •ti titi ' i ` ~ ` TP-1-* Test Pit Completed in August 2016 `-•: a4'•��.: -ti TP-26W `4W@Y£r%aE� `; serWaygti�,` TP-30 �� ----{TP-22.. VLN ' ■ .` .- �y \ > tip■ . ti � IL4 } I f A Ek� ��. TP_ �� 1 III' \ � � �_ � ��` 1• • t � i� \ 1 \1 1 1 rlll �,. _..�1�'rl} r 1 If '' ! j 4 .i f_ .r' S,r�`►1►.}►'' I L �� } t 1 I i.- B-2N{= j r! II Jt7r 7P•20 _ + ar ! s� 4r i '�' ~�� I. ir. /r1 i r 4 ! �' ! r1 i� ► ` ti �. _ _may ]�,�}r'-c r • I ExistingWFC y —'r . ■' , r r �� ■ r r ' ti - �� —~ J_~T _ A• I Jfr -- - - - _ I.... ti r �+r r r�l . �.t 11 1 r r.� *�. r, � ~' �� f r 1 1 �r r y 1 r � f r+ 1 � + � �� r \ \ •.r ''f1 i �\?�'F j� rr ,' �^• � rr I I !/ � � r TP�fi ' ! I � -_ /� \\ ��,` i I% � - . Y 1� .Y 1� � r '�- \\�y� ,�\t} f 4ti"r� �I / TP-13 �,--� ,{�� i■ pY j e I �' f y '� l 1 V 1 } I I ► '# . r ti • ' TP 19 f 9 ` ; `TR7 r TP-_ ' Y1� , , • �j(� j y 1 °_ ` TP 1B r } } s yy ■ \ { �. r f -'� - -„'� tam r _ -.lT�� 6� ! ri I T `' 1 r l `. !f a `�, r= ' ;f 1 I l 1 \ i V w TP 24 #TP 29 \ l.r I I 1 TP-10 _ r Y7t l `® a� �— ! #TP-7N ,• \ �- i T1x11 ^ l r rr r rr Y 1— 1 i- �1J r1.r •TP-2 �A1 r . rf r1^T rl ate/ �I TA"3J� TP-2�- i � rr7-��l S j i� '� .•r�:.:r� r- } r -'Ti�•28 ! + r -• Ir — ; � - 1. and '• f I I r S 1 I C ! i. _ — I I,•I r r rr rr I� =t-, I 1 1 }'� r• is r r' TP�—�} 1 ■ 1 4 I,• 1 ,1� r f r r •.,r[ I t •, ......... r' r r } wTP 1 4 r r •' ► 1■ I i } i` ! r I =� -•__ 1 . I r �� `1 �: } lC '=�fR•94-•'-.•• 1� 1 1 � 4 �" ! i .TP-23'_:�•��—�� }' TP-3-0- ' }► `� TP'� 1 ►, �■ } TP-2N r ` r- _• iP�1 =�^ Ir I I ■ � ■ } i I I r I } } I I ►-�— r• ^ i - Pond fP1l -t Tp2T r1 _ rr + f -____ ` TP-1fi �� Pond �, - TP2'0 , / r : f r i ,5kkV ;ice _ y-iTP-1N z�.` —1 �� by ! r Ir ■ ! I .1 i 1►11 a— �_ �::. 1 •- 1 .'� I i i ■ I rf I I i f ► 1 1 TP-9TP-7fi-I ,I ! ' Ir ' 1 .i'i } ► } �''� TP26r_-- _ ,' r r I ■ r �, I 1 TP 30^* ■ ` `� t J. Notes: 1. The locations of all features shown are approximate. 2. This drawing is for information purposes. It is intended to assist in showingfeatures discussed in an attached document. GeoEngineers, Inc. cannot guarantee the accuracy and content of electronic files. The master file is stored by GeoEngineers, Inc. and will serve as the official record of this communication. Data Source: Base CAD files from ESM Consulting Engineers, LLC dated 7/24/17. Projection: NAD83 WA State Planes, North Zone, US Foot ii 0 <<0 Feet j Site Plan Existing Conditions Proposed Greenline Business Park Federal Way, Washington GMENGINEERS� Figure J • t \lam � .•—y-. _ TP 26 TP 28_- ` - - - B-3N \ P-21 \ r r B-21 TP-4N = wey rh \ TP-29 - e aeuserjNaY AIMS \\ TP 25 TP-20- TP-15 rr r TP 14 ' TPti3 i punn�„ $ jr 1 TP-] 2 -1 7P 18' 1 , L - r TP-3 \ 1 \ rr .Pond y17 Pond \' r I i TP-16 \-TP 1N I ---y -- ��- �-� 11 .ti it �_ \ \\ � / J f ! ■ Pond I TR3N \. _TP-23 2N 'I TP-27-k TP-20# .r TP-22� TP-26# 1 I I i l + l 4 1 1 � ■ Legend TP-IN* Test Pits by GeoEngineers, 2017 B-IN* Borings by GeoEngineers, 2017 TP-1-�- Test Pit Completed in July 2016 TP-1-* Test Pit Completed in August 2016 Notes: 1. The locations of all features shown are approximate. 2. This drawing is for information purposes. It is intended to assist in showing features discussed in an attached document. GeoEngineers, Inc. cannot guarantee the accuracy and content of electronic files. The master file is stored by GeoEngineers, Inc. and will serve as the official record of this communication. Data Source: Base CAD files from ESM Consulting Engineers, LLC dated 7/24/17. Projection: NAD63 WA State Planes, North Zone, US Foot 3 300 0 300 IMM Feet Site Plan Proposed Conditions Proposed Greenline Business Park Federal Way, Washington GMENG[NEERS Figure Native Soil Cap Ground Surface /°-�QD oD v OP D.p 00 0004 Backfill: Freedraining Sand and/or Rock. Minimum 1' °p0 Enclosure of Pipe, Balance of Backfill Below Cap . �aa Should be Sand or Rock. Variable 0�d o 0. coO.fl'e_ a�o�a 6"0 Pipe HDPE or PVC Perforated o P 0 - o. °pQ np p . a- p-per L 2'--J Bench Drain Not to Scale Final Fill Surface Profile Native Building Subgrade \ Conceptual Arrangement of J Bench Cuts Into Native Soil. -- Native Soil �Fill Soil—// Pre -development Ground Surface If Seepage Encountered During Benching, Place Drain At This Location. Drain Detail is Shown Above. 8' MIN. Not to Scale Notes: 1. The locations of all features shown are approximate. 2. This drawing is for information purposes. It is intended to assist in showingfeatures discussed in an attached document GeoEngineers, Inc. cannot guarantee the accuracy and content of electronic files. The masterfile is stored by GeoEngineers, Inc. and will serve as the official record of this communication. Data Source: Drawing created from sketch provided by GeoEngineers' personnel. Keyway Schematic Drawing Hillside Fill Proposed Greenline Business Park Federal Way, Washington GMENGINEER5� Figure APPENDIX A Greenline Business Park Site Plan and Cross Sections APPENDIX B FIELD EXPLORATIONS AND LABORATORY TESTING Field Explorations Subsurface conditions at the site were previously explored during two phases of work. Thirty test pits were excavated in the north part of the site between July 5 and July 7, 2016. Thirty-one test pits were excavated in the middle and south parts of the site between August 15 and August 17, 2016. Supplemental explorations (seven test pits and three borings) were completed on July 19 and July 24, 2017. Borings were drilled to depths of 21 feet. Test pits were excavated to depths ranging from 4 to 9 feet bgs. Test pits were excavated using a rubber -tired backhoe provided by Kelly's Excavating of Pacific, Washington. Borings were completed using tracked drilling equipment owned and operated by Holocene Drilling of Puyallup, Washington. ^� The site explorations were continuously monitored by a member of GeoEngineers geotechnical staff. Our representative maintained a detailed log of the soils encountered, obtained soil samples and observed groundwater conditions. Figures 2 and 3 shows the approximate locations of the explorations. Explorations 1 were mapped using commercial -grade GPS equipment and should be considered accurate only to the Jl extent implied by the method used. - Soil samples were obtained from the borings using standard penetration tests (SPTs) performed in general j conformance with ASTM International (ASTM) Test Method D 1586. The sampler was driven with a 140-pound hammerfalling 30 inches. The number of blows required to drive the sampler the last 12 inches or other indicated distance, into the soils is shown adjacent to the sample symbols on the boring logs. Disturbed samples were obtained from the split barrel for subsequent classification and index testing. Bulk soil samples from the test pits were collected directly from the trackhoe bucket and placed in plastic bags. Soils encountered in the borings were classified in the field in general accordance with ASTM Standard Practice D 2488, the Standard Practice for the Classification of Soils (Visual -Manual Procedure), which is j described in Figure B-1. Soil classifications and sampling intervals are shown on the exploration logs. ` Inclined lines at the material contacts shown on the logs indicate uncertainty as to the exact contact 1 elevation, rather than the inclination of the contact itself. Figures B-2 through B-11 present the supplementary exploration logs. Logs from the earlier phases of work at the site are contained in j Appendices C and D. Laboratory Testing Soil samples obtained from the explorations were brought to our laboratory and reviewed to confirm field classifications. Selected samples were tested to determine their moisture content and grain -size distribution in general accordance with applicable ASTM standards. The moisture content of selected samples was determined in general accordance with ASTM Test Method D 2216. The test results are presented in the respective exploration logs in Appendix A. Grain -size distribution (sieve analyses) was conducted in general accordance with ASTM Test Method D 422. Atterberg Limits Tests were conducted in general accordance with ASTM Test Method D 4318. The results of previous laboratory testing are presented in Appendices C and D. Laboratory testing of samples collected from the supplementary explorations are contained in Figures B-12 through B-14. GEOENGINEERS� September 19, 2017 Page B-1 File No. 22247-003-00 SOIL CLASSIFICATION CHART ADDITIONAL MATERIAL SYMBOLS MAJOR DIVISIONS SYMBOLS TYPICAL DESCRIPTIONS GRAPH LETTER ) GRAVEL CLEAN GRAVELS 0 Q0 o GW WELL -GRADED GRAVELS, GRAVEL - SAND MIXTURES AND GRAVELLY SOILS (LITTLE OR NO FINES) 0 0 0 0 O O GP POORLY -GRADED GRAVELS, GRAVEL -SAND MIXTURES GRAVELS WITH FINES GM SILTY GRAVELS, GRAVEL - SAND • SLT MIXTURES COARSE GRAINED SOILS MORETHAN 50% OF COARSE FRACTION RETAINE ON No 4SIEVE (APPRECIABLE AMOUNT OF FINES) Gfi CLAYEY GRAVELS, GRAVEL -SAND - CLAY MIXTURES CLEAN SANDS SW WELL -GRADED SANDS, GRAVELLY SANDS MORE THAN 50% SAND SP POORLY -GRADED SANDS, GRAVELLY SAND RETAINED ON NO 200 SIEVE AND SANDY (LITTLE OR NO FINES) SOILS SANDS WITH SM SILTYSANDS, SAND - SILT MIXTURES MORETHAN 50% OF COARSE FINES FRACTION PASSING SC CLAYEY SANDS, SAND -CLAY MIXTURES ON NO 4 SIEVE (APPRECIABLE AMOUNT OF FINES) OF FIN INORGANIC SILTS, ROCK FLOUR, ML CLAYEY SLTS WITH SLIGHT PLASTICITY FINE GRAINED SILTS AND CLAYS LIQUID LIMITV/z LESS THAN 50 CL INORGANIC CLAYS OF LOW TO MEDIUM PLASTICITY, GRAVELLY CLAYS, SANDY CLAYS, SILTY CLAYS, LEAN CLAYS OL ORGANIC SILTS AND ORGANIC SILTY CLAYS OF LOW PLASTICITY SOILS MORE THAN 50% PASSING MH INORGANIC SILTS, MICACEOUS OR DIATOMACEOUS SILTYSOILS NO 200 SIEVE CH INORGANIC CLAYS OF HIGH PLASTICITY SILTSAND LIQUID LIMIT GREATER CLAYS THAN 50 OH ORGANIC CLAYS AND SILTS OF MEDIUM TO HIGH PLASTICITY HIGHLY ORGANIC SOILS PT PEAT, HUMUS, SWAMP SOILS WITH HIGH ORGANIC CONTENTS NOTE: Multiple symbols are used to indicate borderline or dual soil classifications Sampler Symbol Descriptions ® 2.4-inch I.D. split barrel ® Standard Penetration Test (SPT) ■ Shelby tube ® Piston Direct -Push m Bulk or grab ® Continuous Coring Blowcount is recorded for driven samplers as the number of blows required to advance sampler 12 inches (or distance noted). See exploration log for hammer weight and drop. "P" indicates sampler pushed using the weight of the drill rig. "WOH" indicates sampler pushed using the weight of the hammer. SYMBOLS TYPICAL DESCRIPTIONS GRAPH LETTER AC Asphalt Concrete CC Cement Concrete CR Crushed Rock/ Quarry palls I SOD Sod/Forest Duff TS Topsoil Groundwater Contact TMeasured groundwater level in exploration, _ well, or piezometer VMeasured free product in well or piezometer Graphic Log Contact Distinct contact between soil strata _ Approximate contact between soil strata Material Description Contact Contact between geologic units _ _ __ Contact between soil of the same geologic unit Laboratory / Field Tests %F Percent fines %G Percent gravel AL Atterberg limits CA Chemical analysis CP Laboratory compaction test CS Consolidation test DO Dry density DS Direct shear HA Hydrometer analysis MC Moisture content MD Moisture content and dry density Mohs Mohs hardness scale OC Organic content PM Permeability or hydraulic conductivity PI Plasticity index PP Pocket penetrometer SA Sieve analysis TX Triaxial compression UC Unconfined compression VS Vane shear Sheen Classification NS No Visible Sheen SS Slight Sheen MS Moderate Sheen HS Heavy Sheen NOTE: The reader must refer to the discussion in the report text and the logs of explorations for a proper understanding of subsurface conditions. Descriptions on the logs apply only at the specific exploration locations and at the time the explorations were made; they are not warranted to be representative of subsurface conditions at other locations or times. Key to Exploration Logs GWENGINEERS / FigureB-1 I Total Logged By CRG Date 7/19/2017 Depth (ft) 7 Checked By SM Surface Elevation (ft) 439 Easting ()Q Vertical Datum NAVD88 Northing(Y) Excavator Kelys Excavating Equipment Mni Trackhoe Grouml%vaternot observed Caving rot observed 1276740 Coordinate System WA State Plane North 1Jw10 Horizontal Datum NAD83 (feet) REMARKS Y w SAMPLE MATERIAL —* F N a in DESCRIPTION m « 6 c c Y N a C C W � H Fes- C7 C7 U ML Organio-rich brown sandy silt with gravel (loose, moist) i GM Gray- and rust -mottled silty coarse gravel with sand (dense, moist) (weathered till) a� y �6 b IJ 3 2 2 10 38 4 a� 5 3 SM Gray silty fine to medium sand with fine gravel (dense, moist) (till) a s - anti 7 Notes: See Figure B-1 for explanation of symbols. The depths on the test pit I Dgs are based on an average of measurements across the test pit and should be considered accurate to 1/2foot. Coordinates Data Source: Horizontal approximated based on Goode Earth, Vertical approximated based on DEM Log of Test Pit Tx1N Project Proposed Greenline Business Park G EO E N G I N E E RS Project Location: Federal Way, Washington Figure B-2 Project Number. 22247-0034D0 Sheet 1 of 1 Date Total Wgged By CRG Excavator Kelys Excavating Groundwater not observed Excavated 7/19/2017 Depth (ft) 7 Checked By SWH Equipment Mrw Tmckhoe Caving not observed Surface Elevation (ft) 429 Easting P9 1276910 Coordinate System WA State Plane North Vertical Datum NAVD88 Northing (Y) 114720 HonZ0nt8l Datum NAM (feet) SAMPLE d E MATERIAL REMARKS o tot N DESCRIPTION go 02. yay W O 6N1 N H F- 2 C7 e m 00 r2 0 ILL C7 Duff Forest duff 1 � v0 b � ♦ SM Gray4ed-rattled silty fine to medium sand with fine gravel (dense, b moist) (weathered till) 2 b� 3 2 a b ybT. 5 SM Gray silty fine to medium sand with gravel (dense, moist) (till) 19 b 6 3 bbry 7 Notes: See Figure I}1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 1/2 foot. Coordinates Data Source: Horirontad approximated based on Gcoge Earth, Vertical approximated based on DEM Log of Test Pit TPR2N Project Proposed Greenline Business Park G EO E N G I N E E R Project Location: Federal Way, Washington —_ �� Figure B-3 Project Number: 22247-003400 sheet 1 of 1 Date Total Logged By CRG Excavator Kellys Excavating Groundwater not observed 7/19/2017 Depth 9 Checked By SWH Equipment Mini Trackhoe Caving not observed Surface Elevation (ft) 415 Fasting (X) 1277000 coordinate System WA State Plane North Vertical Datum NAVD88 Northing (Y) 114380 Horizontal Datum NAD83 (feet) SAMPLE MATERIAL REMARKS 2 E w DESCRIPTION O v N C C N U G 7 �jC C U C mCp a)N W 0 H F C7 a U W C7 N� Brown organio-rich silt with sand and occasional gravel (medium dense, dry) i a^a t H- f Gray- and r st-rr fine sandy slit with occasional organic debris and fine gravel (stiff, moLA) (weathered till) a^^ 4--h I I I 1 24 1 66 5 0 0 01 a e 0 a sM Gray silty fine to medium sand with fine to coarse gravel (very dense, 10 35 " waist) (till) Notes: See Figure B-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 1/2 foot Coordinates Data Source: Horizontal apprmmwed based on Goog)e FaRh. Vertical approwmmed based on DEM Log of Test Pit TP aN Project Proposed Greenline Business Park G M E N G I N E E R Project Location: Federal Way, Washington Project Number: 22247-003-00 Figure B-4 Sheet 1 of 1 Dam Total Wgged By ' Excavator Kellys Excavating Groundwater not observed Excavated 7/19/2017 g 5 Depth (ft) Checked By SWH + Equipment Mni Trackhoe Caving not observed Surface Elevation (ft) 419 Easting (Q 1278840 Coordinate System WA State Plane North Vertical Datum NAVD88 Northing (Y) 116340 Horizontal Datum NAD83 (feet) y SAMPLE a W c MATERIAL MATE REMARKS o y m m N DESCRIPTION «p G iL 0 N N H F G 7 N o 2 y c C7 C7 U lL i.1 Duff Forest duff e 1 W Brown sandy silt and organic debris (medium stiff, moist) (weathered t p^ till?) 2 2 19 50 %F 4 sp p y i p B i - 7 sm Gray silty fine to medium sand with gravel, some rust staining (mottled) (dense, mast) (till) a 14 37 %F p $ Notes: See Figure B-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pa and should be considered accurate to 1/2foot Coordinates Data Source: Horizontal awoximrled based on Googie Earth, Vertical approximated based on DEM Log of Test Pit TPAN Project Proposed Greenline Business Park G M E N G I N E E R 5 Jf`. Project Location: Federal Way, Washington -- -- Figure B-5 Project Number. 22247-003-00 Sheet 1 of 1 Logged By CRG Excavator Kelys Excavating Groundwater not observed Date 7/19/2017 Total (ft) 9 Checked By SWH Equipment Win! Trackhoe Caving not observed Surface Elevation (ft) 417 East!ng (X) 1278980 Coordinate System WA State Plane North Vertical Mum NAVD88 Northing (Y) 116470 Horizontal Datum NAD83 (feet) I Log of Testpit TR6N Project Proposed Greenline Business Park GMENGINEERS Project Location: Federal Way, Washington $ Figure B-7 Project Number. 22247-003-00 sheet 1 of 1 j a alw Fad Total Drilled 7/24/2017 7/24/2017 Depth (ft) Surface Elevation (ft) 446 Vertical Datum NAVD88 Fasting (X) 1277390 Northing(y) 116710 Notes: 21 Logged By CRG Driller Holocene Drilling Inc. l Checked By SWH Hammer Autornatic Drilling Data 140 (Ibs) / 30 (in) Drop Equipment System WA State Plane North0g Datum NAD63 (feet) DrillingHollows Auger Mettlod Diedrich D50 Track Rig Uepm fo ) fH1 Elevation M) Yes FIELD DATA a 2 MATERIAL REMARKS DESCRIPTION >u c y w G �� m w F 3 m c7 o i8 m LLc4 0 c4 csU SM Mottled browngjaysiltyfinetomedium sand with aay gravel (very dense, waist) (till) 18 48 1 5 sM Gray/brown silty fine to medium sand with gravel Apo (very dense, moist to wet) (till) 50/6" 2 10 6 50/6' 3 15 p 1 50/5' a Groundwater observed at 171/2 feet at time of exploration 20 a 2 50/6' 5 Note: See Figure &1 for explanation of symbols. Coordinates Data Source, Horizontal approximated based on Google Earth, Vertical approximated based on DEM Log of Boning EI N Project Proposed Greenline Business Park G M E N G I N E E RS Project Location: Federal Way, Washington — — Figure B-9 Project Number. 22247-0034D0 sheet 1 of 1 otal TDepth Drilled 7/24/ 17 7/24/2017 (ft) Surface Elevation (ft) 461 Vertical Datum NAVD88 EastJrtg(X) 1277810 NcathinAM 116700 21 1 ekeBy d CRG Driller Holocene Drilling, Inc. SWH Hammer Automatic Drilling illipnrnerrt Data M (Ibs) / 30 (in) Drop i System WA State Plane North a9LUMU Datum NAD83 (feet) Drill Hollow -stem Auger Diedrich D50Track Rig Depth to nX�tI Elevatim (ft) Yes Drilled 7/24/2017 7/24/2017 TDepth (ft) ed 21.25 (Hammer CRG Driller Holocene Drilling Inc. DnlMeth�od Hollow -stem Auger Surface Elevation (ft) Vertical Datum 457 NAVD88 Data Automatic 140 Otis) / 30 (in) Drop Drilling Equipment Diedrich D50 Track Rig Easting ()Q Northing (Y) 1278350 116680 hem Datum WA State Plane North NAD83 (feet) am Depth to Yes Notes FIELD DATA w o d a s �, > �o 0 MATERIAL REMARKS s to c 3 t 12 a• DESCRIPTION m �? c 07 d r o o d a`� m a m 7: oM g c w m ¢ m H 3 a 0E5 Ifl ors LLc4 0 SM Brown silty fine to coarse sand with gravel (very loose, dry) 3 1 1 SA 9 32 Very rough drilling at 5 feet sM Gray siltyfine to medium sand with gravel (very dense, moist to wet) (till) �h0 -� 14 67 2 S4 9 34 10 y i 15 D J 15 88/ir 4 20 93/6, 5 Groundwater observed at 20 feet at time of exploration Note: See Figure B-1 for explanation of symbols Coordinates Data Source: Horizontal approximated biased on Google Earth, Vertical approximated based on DEM Log of Boring B3N Project Proposed Greenline Business Park G M E N G I N E E R S rl)" Project Location: Federal Way, Washington .,�:,- — Figure B-11 Project Number: 22247-003-00 sheet 1 of 1 ■■■■■■■■■■■■■■■■■■■■ ■■■■■■■■■■■■■■■■■■■■ ■■■■■■■■■■■■■■■■■■■■ CO CO En ■■■■■■■■■■■■ ■■■ ■■■■ ■■■■■■■■■■■■ ■■■■■■■ CD ■■■■■■■■■■■■■■■■■■■■ ..�... ....C...��.....�. EMiir ■■��IN■■■■■■■■■■ m!!L Jf.Rf.Ji:i!!!!.!!!!! �iiIAI/iI1. rw.iii. ii iii►/.i! riffmiiiiiiliiii ii •ii it• �iiiiiiiiiii �►i/.�■i iliiiiiiii. iiii NMiiAii W7liiiiiiii • i ii iiiiii i i 7�' i i iiii i1011111111000ii �. r�so■■o■ommommo■ns■os ..■■■■■■■■■■.■■■■■■. r!!..!!..!l...!!..!M �iiiiiliiiiiiiiiiiii iiiiiiiiliiiii L ■■■■■■■■■■■■■■■■■ ■■■■■ ■■■■■■■■■■soon � i i�iiii r.� iii•��i r.• � isi�• {fi 2 LL Ln m m O U L 5 cn d Y � O N L j N w �= Q i o D L :3cc cc N 3 'N N N N N T In E N C O _ O O N IA a v U In N O C Y N i a e LO O I_N `.11 c0 C t Q N LO LO LO LO a) w c0 N Ih c'M 0 V Z Z Z Z LO io (0 � `o aZ cL a cL a r r r m / O N Sieve Analysis Results Proposed Greenline Business Park Federal Way, Washington GEOENGINEERS FigureB-13 ■■■■■■■■■■■1■ ��F. ■�iiii� i �iiiii��ii _ iiiiii_ii Fw• i i iiiii ■■■■I�■�W OMEN■■■■■■■■ ��r+.ter, �■�� i.� i►��iii�� iii i��iiii� ■� A1■111EE■■■E■NN ■■doll■■■■■■MMENEM■■ 0 l 1 1 I I APPENDIX C Explorations and Laboratory Results - July 2016 n j I I Date Excavated 7/6/2016 total Depth (ft) 7 Logged By KM Checked By SWH Excavator Kelly's Excavating Excavation Equipment Kumatsu WB-140 Rubber Tired Backhce Surface Elevation (ft) 520 Easting (X) 1194370 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725708 Datum NAD83 (feet) SAMPLE A MATERIAL o m co 3 DESCRIPTION a REMARKS j n F A? a N 0U c m o c o w 0 N 0 LLD 1A h 7 3 5 inches thick forest duff, small roots sM Brown silty fine to medium sand with occasional gravel and cobbles (loose to medium dense, moist) (weathered till) sM i Brown gray silty fine to medium sand with occasional gravel and cobbles (dense, moist) (glacial fill) Test pit completed at 7 feel No groundwater seepage observed No caving observed Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot Log of Test Pit TP-4 Project: KG Investment, Building "A" Site G EO E N G I N E E R S •'� Project Location: Federal Way, Washington ~mil Project Number: 9745-002-00 sgureo 5 Date Excavated 7/6/2016 Total Depth (ft) 7 Logged By YZ Checked By SWH Excavator Kelly's Excavating Excavation Equipment Kumatsu WB-140 Rubber Tired Backhoe Surface Elevation (ft) 530 Easting (X) 1194610 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 726105 Datum NAD83 (feet) SAMPLE -- E w o MATERIAL REMARKS o DESCRIPTION a t n c c y .W r a a y 2 y c 3m - - C m e W � H I-� 0 0 0 �U LLU • DUF 6 inches forest duff, roots 0.5 to 2 inches thick sM Brown gray silty fine to medium sand with occasional gravel and cobbles (medium dense, moist) (weathered till) �rt9 1 ht0 2 yy'1 3 SM Gray silty fine to medium sand with occasional gravel, cobbles, boulders (very dense, moist) (glacial till) a ytiy 5 x U w� V 4 6 2 2 �i Test pit completed at 7 feet o No groundwater seepage observed No caving observed 0 c� Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. fi Log of Test Pit TP-6 G M E N G I N E E R ��• - Project: KG Investment, Building "A" Site Project Location: Federal Way, Washington Figure A-7 Project Number: 9745-002-00 Sheet 1 of 1 F Date Excavated 7/6/2016 Total Depth (ft) 5 5 Logged By YZ Checked By SWH Excavator Kelly's Excavating l Excavation Equipment Kumatsu WB-140 Rubber Tired Backhoe Surface Elevation (ft) 465 Easting (X) 1194584 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725788 Datum NAD83 (feet) GEOENGINEER� Project: KG Investment, Building "A" Site Project Location- Federal Way, Washington Project Number: 9745-002-00 Figure A-10 Sheet 1 of 1 Date total Logged By YZ Excavation Kumatsu WB-140 Rubber Excavated 7/6/2016 Depth (ft) 6.5 Checked By SWH Excavator Kelly's Excavating Equipment Tired Backhoe Surface Elevation (ft) 500 Easting (X) 1194621 System WA State Plane,North I Vertical Datum NAVD88 Northing (Y) 725417 l Datum NAD83 (feet) J SAMPLE m E - o o MATERIAL REMARKS w 0 J �° DESCRIPTION m r d G c N t E E ach 2 �o oo "m �o W H Fes- (? 00 20 LLU 6 inches forest duff DUF sM Brown silty fine to medium sand with occasional gravel and cobbles (medium dense, moist) (weathered till) M � 2 _ p91 3 sM Grayish brown silty fine to medium sand with gravel and cobbles (dense, moist) (glacial fill) P°� 4 5 i Test ph completed at 6.5 feet No groundwater seepage observed No caving observed Notes: See Figure A-1 for explanation of symaols. The depths on the test pit logs are based an an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-10 Project: KG Investment, Building "A" Site G M E N G I N E E R S ' Project Location: Federal Way, Washington Figure A-11 Project Number: 9745-002-00 Sheet 1 of 1 Logged By YZ Excavation Kumatsu WB-140 Rubber Excavated 7/6/2016 Depth Date Total (ft) 6 Checked By SWH Excavator Kelly's Excavating Equipment Tired Backhoe Surface Elevation (ft) 450 Easting (X) 1195005 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 726133 Datum NAD83 (feet) Date Total Excavated 7/6/2016 Depth (ft) 6 Logged By YZ Checked By SWH Excavator Kellys Excavating Excavation Equipment Kumatsu WB-140 Rubber Tired Backhoe Surface Elevation (ft) 460 Easting (X) 1195038 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725924 Datum NAD83 (feet) Date 7/6/2016 I Total 7 Logged By YZ Excavator Kelly s Excavating Excavation Kumatsu WB-140 Rubber Equipment Tired Backhoe Excavated Depth (ft) Checked By SWH Surface Elevation (ft) 445 Easting (X) 1194805 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725783 Datum NAD83 (feet) SAMPLE MATERIAL w n DESCRIPTION @�? a REMARKS m m i d H H G C W 0 H Fm- (9 (9U ici LLv •. DUF 6 inches forest duff sM I Grayish brown silty fine to medium sand with occasional gravel and cobbles (dense, moist) (weathered tlll) 1 pP� by 3 ;---A 1 SM I Gray silty fine to medium sand with occasional gravel and cobbles (very dense, moist) (glacial tHl) �^ 4 �o 5 �9 a g - 2 Tesl pit completed at feel No groundwater seepage observed No caving observed Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. pl- Log of Test Pit TP-13 Project: KG Investment, Building "A" Site G W E N G I N E E R S� Project Location: Federal Way, Washington Figure A-14 Project Number: 9745-002-00 Sheet t of 1 Date 717/2016 Total 6 Logged By YZ Excavator Kelly's Excavating Excavation Kumatsu WB-140 Rubber Excavated Depth (ft) Checked By SWH Equipment Tired Backhoe Surface Elevation (ft) 450 Easting (X) 1194778 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725568 Datum NAD83 (feet) SAMPLE m ro a MATERIAL e REMARKS co U � _ 7 G 'N 'y n E 7 y L m - C Y m C W o F0— Fm- 00 U i ci U Forest duff 12 inches, roots up to 1 inch • DUF Ab9 • sM Brown silty fine to medium sand with occasional gravel and cobbles (medium dense, moist) (weathered till) 2 �1 3 � � �6 4 - h 5 cu Brown arav sikv sand with nmasinnal nraval Mama mnisf) Log of Test Pit TP-14 5 Project: KG Investment, Building "A" Site G W E N G I N E E R S Project Location: Federal Way, Washington `J� Project Number: 9745-002-00 Figure of 1 I Date 7/6/2016 Deptih 6 Excavated 1 (ft) Surface Elevation (ft) 500 Vertical Datum NAVD88 SAMPLE m W a w^ W co J c c a � a N Y1 W 0 N 0 0 2 A°p 6 Logged By DM Excavation Kumatsu WB-140 Rubber Checked By SWH ExcavatorKellys Excavating Equipment Tired Backhoe Easting (X) 1194079 System WA State Plane,North Northing (Y) 724728 Datum NAD83 (feet) o MATERIAL DESCRIPTION a� W u DUF B inches forest duff SM Light brown silty fine to medium sand w (loose to medium dense, moist) (fill) SM I Grayish brown silty fine to medium sand with occasional gravel (medium dense to dense, moist) (weathered glacial till) sM I Brownish gray silty fine to medium sand with occasional gravel (dense to very dense, moist) (glacial till) Test pit completed at 6 feet No groundwater seepage observed No caving observed d F 1 REMARKS LLU Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. a Log of Test Pit TP-16 Project: KG Investment, Building "A" Site G EO E N G I N E E R S !_ Project Location: Federal Way, Washington Project Number: 9745-002-00 FSheee of 1 Date Excavated 7/6/2016 Total Depth (ft) 8y DM I SWH Excavator Kelly'sExcavating Excavation Kumatsu WB-140 Rubber Equipment Tired Backhoe +Checked Surface Elevation (ft) 510g (X) 1194137 System WA State Plane,North Vertical Datum NAVD88ng (Y) 724957 Datum NAD83 (feet) SAMPLE n MATERIAL REMARKS O _ coDESCRIPTION Cl a N L C C t a ay 7 y C m iU m CD 2 22 U pCp tLL U • • • DUF 10 inches forest duff sm Light brown silly fine to medium sand with occasional gravel 09 h (loose to medium dense, moist) (weathered glacial till) e y 3� 11 Becomes grayish brown and medium dense to dense 06 I h q H1 SM I Brownish gray silty fine to medium sand with occa: gravel (dense to very dense, moist) (glacial till) arh� 6�, z y0' 7 Test pit completed at 8 feet No groundwater seepage observed No caving observed Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-17 Project: KG Investment, Building "A" Site G EO E N G I N E E R S,!� Project Location: Federal Way, Washington Figure A-18 Project Number: 9745-002-00 Sheet 1 of 1 Date 7/5/2016 Total 4 Logged By DM Excavator Kellys Excavating Excavation Kumatsu WB-140 Rubber Excavated Depth (ft) Checked By SWH Equipment Tired Backhoe Surface Elevation (ft) 490 Easting (X) 1195102 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725785 Datum NAD83 (feet) J SAMPLE m E o o MATERIAL REMARKS C w CO J W DESCRIPTION jp L m m C C m m L d !° a'y 7 ea f 0 O w 0 f- F. t7 C9 U r1U p i-iU • DUF 6 inches forest duff Grayish brown with slight oxidation staining silty fine to SM medium sand with occasional gravel (medium dense, a�a moist) (weathered glacial till) 0� a 2 a�1 3 sM Brownish gray silty fine to medium sand with occasional gravel (dense, moist) (glacial till) P� a 5 Log of Test Pit TP-18 o Project: KG Investment, Building "A" Site G M E N G I N E E R S Project Location: Federal Way, Washington - - Project Number: 9745-002-00 Figure of 1 Date 7/5/2016 Total 6 Logged By DM Excavator Kelly's Excavating Excavation Kumatsu WB-140 Rubber Equipment Tired Backhoe Excavated Depth (ft) Checked By SWH Surface Elevation (ft) 485 Fasting (X) 1195026 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725565 Datum NAD83 (feet) SAMPLE E w o MATERIAL REMARKS w n U DESCRIPTION O v p) p C C G 0.!E y N O O o G 0 a) W O F- Fes- C7 0L) 8 inches forest duff, root depth 12 inches 0 0 �U LLU — DUF SM 1 Grayish brown with oxidation staining silty fine to medium f sand with occasional gravel (medium dense to dense, moist) (weathered glacial till) SM I Brownish gray slily fine to medium sand with occasional gravel (dense to very dense, moist) (glacial till) 7 I 2e Test pit completed at S feel No groundwater seepage observed No caving observed Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-19 Project: KG Investment, Building "A" Site G EO N G I N E E R Project Location: Federal Way, Washington Figure A-20 Project Number: 9745-002-00 Sheet 1 of 1 Date 7/5/2016 Total 6 Logged By DM Kellys Excavating Excavation Kumatsu WB-140 Rubber Excavated Depth (ft) Checked By SWH�vator Equipment Tired Backhoe Surface Elevation (ft) 490 f Easting (X) 1195201 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725453 Datum NAD83 (feet) f SAMPLE I m m i; o MATERIAL REMARKS J iiiDESCRIPTION U a✓ C G 7 N .2 C m W m m F- F- 0 0 U 6 inches forest duff U r U DUF Light brown silty fine to medium sand with gravel (loose to sM medium dense, moist) (fill) �9 -a 1 DUF 6 inches buried forest duff horizon a Grayish brown with oxidation staining silty fine to medium sM z sand with occasional gravel (medium dense to dense, moist) (weathered glacial till) ae1 g 0rO b 4 sM Brownish gray silty fine to medium sand with occasional gravel (dense to very dense, moist) (glacial till) 5 z 6 Test pit completed at 6 feel No groundwater seepage observed No caving observed Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-20 GMENGINEERS Project: KG Investment, Building "A" Site . ;! I ;-: Project Location: Federal Way, Washington - _ Figure A-21 Project Number: 9745-002-00 Sheet 1 of 1 Date I Total 7/7/2016 6 Logged By YZ Excavator Kelly's Excavating Excavation Kumatsu WB-140 Rubber Excavated I Depth (ft) Checked By SWH Equipment Tired Backhoe Surface Elevation (ft) 490 Easting (X) 1195610 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725893 Datum NAD83 (feet) SAMPLE m m o o MATERIAL REMARKS w N -' DESCRIPTION a N m m c c 0a 2 m I° < < m w o m m H f. (� 00 20 LLU �. • • DUF Forest duff 3 inches thick sM Grayish brown fine to medium sand with occasional gravel and cobbles (medium dense, moist) (weathered till) P� 2 p01 3 0�O b q sM Grayish brown silty fine to medium sand with gravel and cobbles (dense, moist) (glacial till) �`' "-b 5 2 Log of Test Pit TP-22 Project: KG Investment, Building "A" Site G EO E N G I N E E R S J Project Location: Federal Way, Washington l A4 Project Number: 9745-002-00 9 eo-23 Date 7/5/2016 Total 9 Excavated Depth (ft) Surface Elevation (ft) 480 Vertical Datum NAVD88 SAMPLE -- m E W i; 0 C to rn J O Z. .� r m C C G = y W 0 F N C9 t:9 U • DUF b10 2 0 3 e 5 a e 6 b1� a'tti 2 sM sM Logged By DM Excavation Kumatsu WB-140 Rubber Checked By SWH Excavator Kelly's Excavating Equipment Tired Backhoe Easting (X) 1195440 System WA State Plane,North Northing (Y) 725781 Datum NAD83 (feet) MATERIAL DESCRIPTION ich forest duff, root depth 20 to 30 inches ht brown silty fine to medium sand with gravel and concrete debris (curb) and 2- to 3-Inch tree roots (loose to medium dense, dry to moist) (fill) wnish gray silty fine to medium sand with occasional gravel (dense to very dense, moist) (glacial fill) 9 1 30 REMARKS a Test pit completed at 9 feet No groundwater seepage observed Slight caving observed from 0 to 7 feet 2 91 Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-23 Project: KG Investment, Building "A" Site G EO E N G IN E E R S Project Location: Federal Way, Washington Figure A-24 Project Number: 9745-002-00 Sheet 1 of 1 Date 7/5/2016 Total 6 Logged By DM Excavator Kellys Excavating Excavation Kumatsu WB-140 Rubber Excavated Depth (ft) Checked By SWH Equipment Tired Backhoe Surface Elevation (ft) 510 Easting (X) 1195317 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725576 Datum NAD83 (feet) r SAMPLE I ro JR E o o MATERIAL m o v 0, DESCRIPTION r m tD c c m m t a 222 aE am oa o -_ co 0 00 iU LLU • • DUF 6 inches forest duff, root depth 24 to 36 inches SM Light brown silty fine to medium sand with gravel and tree roots''Y. to 4 inches diameter (loose to medium dense, yo9 i moist to dry) (fill) - 14 [e e SM I Brownish gray silty fine to medium sand with occasional gravel (dense to very dense, moist) (glacial till) e z � L h� 6 Test pit completed at 6 feet No groundwater seepage observed 51 No caving observed REMARKS Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-24 Project: KG Investment, Building "A" Site G EO E N G I N E E R Project Location: Federal Way, Washington Figure A-25 Project Number: 9745-002-00 Sheet 1 of 1 Date 7/5/201Total 6 6 Excavated Depth (ft) Surface Elevation (ft) 530 Vertical Datum NAVD88 SAMPLE m -- m a E ` 0 o w W C J U U .. G no > Ol W 0 2 Yl F Fes- LO (9 Q cc 0 U PIN, DUF 4P , y'V' h`t1 e 4 2 e sM Logged By DM Excavation Kumatsu WB-140 Rubber Checked By SWH] I �°ator Kelly's Excavating Equipment Tired Backhoe Easting (x) 1195392 System WA State Plane,North Northing (Y) 725394 1 Datum NAD83 (feet) MATERIAL :z — REMARKS DESCRIPTION �s OppO Cp �U LLU ches forest duff, 20 to 30 inches root depth iyish brown with oxidation staining silty fine to mediu sand with occasional gravel and tree roots (medium dense to dense, moist) (wealhered glaciat till) sM I Brownish gray with slight oxidation slain medium sand with occasional gravel dense, moist) (glacial till) Test pit completed at 6 feet No groundwater seepage observed No caving observed fine to to very Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. g G. Log of Test Pit TP-25 Project: KG Investment, Building A Site G W E N G I N E E RS Project Location: Federal Way, Washington Figure A-26 Project Number: 9745-002-00 Sheet 1 of 1 Date 7l7I2016 Total 6.5 Logged By YZ Excavator Kelly's Excavating Excavation Kumatsu WB-140 Rubber Excavated Depth (ft) Checked By SWH i Equipment Tired Backhoe Surface Elevation (ft) 510 Easting (X) 1195894 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 726028 Datum NAD83 (feet) SAMPLE m E JE d o o MATERIAL a REMARKS J� DESCRIPTION �? O v W L > m Ol Im C C 0 m U L a ,� K a W e 0 C .2 0 -< C O < Li H F- C9 C7 U i U LL U Forest duff 6 inches thick • • DUF •r Gray silty fine to medium sand with occasional gravel and sM cobbles (medium dense, moist) (weathered till) 1 2- 3— � 1 06 h { sM Brownish gray silty fine to medium sand with occasional gravel, cobbles and boulder (very dense, moist) (glacial eOg _ till) Test pit completed at 6.5 feel No groundwater seepage observed No caving observed Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. b wg yr � esi r�z � r-to Project: KG Investment, Building "A" Site G EO E N G I N E E R S Project Location: Federal Way, Washington - _ Figure A-27 - Project Number: 9745-002-00 Sheet 1 of 1 717I2016 6 Logged By YZ Excavator Kelly's Excavating Excavation Equipment Kumatsu WB-140 Rubber Tired Backhoe ExcavatedDate DepthTota Checked By SWH Surface(ft) Surface Elevation (ft) 550 Easting (X) 1195924 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725945 Datum NAD83 (feet) wy v1 I VbL rn I r-&o Project: KG Investment, Building "A" Site G EO E N G I N E E R S r Project Location: Federal Way, Washington Project Number: 9745-002-00 FSheee o29 Date Total 6 7!7/2016 Logged By YZ Excavator Kelly's Excavating Excavation Equipment Kumatsu WB-140 Rubber Tired Backhoe Excavated Depth (ft) Checked By SWH Surface Elevation (ft) 485 Easting (X) 1195880 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725659 Datum NAD83 (feet) Date Excavated 7/5/2016 Total Depth (ft) 8 Logged By YZ Checked By SWH Excavator Kelly's Excavating Excavation Equipment Kumatsu WB-140 Rubber Tired Backhoe Surface Elevation (ft) 515 Easting (X) 1195682 System WA State Plane,North Vertical Datum NAVD88 Northing (Y) 725570 Datum NAD83 (feet) SAMPLE r. J m E 5 MATERIAL 1-vg yr 1 U51 riz i r-Ou Project: KG Investment, Building "A" Site G EO E N G I N E E R S Project Location: Federal Way, Washington -:• ~ - Figure A-31 Project Number: 9745-002-00 Sheet 1 of 1 O O 6 e'I O O ei O W z LL N li W us W � 41 2 us z W N w in M Z Q Q U W z LL J W Q LLJ 0 C) i1 O O O O 0 00 OP- O LO le M COV 0 O ei e�l 1HS13M AS 9NISSdd 1N3383d 3 N d T N � N N N O L n U_ L O 3 N C C O a� E a 10 G C C GCJ Cv N N f0 � U w � � p J � > c > > U n N n N � f6 (O N N T L m p c a o c _ m M N O N m y 4-- m m a fA (A A - c '0 a� f0 U O O O�I] O �a N Y N n N N � D U) N N N r E c � L o c � W c m 0 o d `i O 00 o N M0\° G O` y < n S n ° t 5 c o m 3 16 o � � Q Gf Lq In M 3 c N M In M n c rU I n N i m X N � C O m a U N p M rl M 00 N o' C F a o ±� tLz � c �a 0 0 _ C L N IO � E O N n C G �j V l� ■ O L 0 z Sieve -Hydrometer Analysis Results KG Investment, Building "A" Site Federal Way, Washington GEOENGINEERS� FigureA-32 � % o |& )b o k a �0 - U) % ] %2S ) \ \ �) k - �/\ - ®® '- /.2 8 & LLP75 \) kLLJ m � kƒ @_ LU § 2 - m o S § E« I 2 z . §k k d / ® 2 ) 77) * } y - ;re 2 z } 2 ; ° } 20 / @_ {{i ` � o $7 +` [ o 104 _ - - § � W § - 8 % e m k / § § \ ) - S � /{ k }j ) ♦ El \ § m o M k � 2 2 $ M N � Tq 1 O1]m A emSSW 13 H3d \ Sieve -Hydrometer Anal y|s Results $ KG Investment, Bui mM■' 'S!i $ Federal Way, Was mngton § GEo E NG|N EERY � F■ ur Ada l I APPENDIX D Explorations and Laboratory Results - August 2016 I I I I j j Date Excavated 8/16/2016 Total Depth (ft) 5 Logged By DTM Checked By SWH Excavator Kelly's Excavating, Inc. Excavation Equipment Rubber Tired Backhce Surface Elevation (ft) 2630 Easting (X) 1194210 Coordinate 724630 Horizontal System Datum WA State Plane,South NAD83 Vertical Datum NAVD88 Northing (Y) SAMPLE w _ a c o MATERIAL REMARKS W C r to F DESCRIPTION O 6 C 6 C O W L C C m o iD C t n y E Q m C 00 C gCg 0 C9 0 W • DUF Approximately B inches forest duff; 14-inch root depth Probe depth: 12 inches ML Grayish brown oxidation staining sandy silt with gravel and Ap cobbles (stiff to very stiff, moist) (weathered till) 2 1 12 SD SA 1 ry6ti 3 ,y6 ' 4 SM 2 wnish gray silty fine to medium sand with occasional gravel and cobbles (very dense, moist) (till) Test pit completed at 5 feet No groundwater seepage observed No caving observed Probe depth: less than 1 inch Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-1 Project: KG Investment Parcel, South Property G EO E N G I N E E R5 Project Location: Federal Way, Washington Project Number: 9745-003-00 Figure A-2 Sheet 1 of 1 Date Excavated 8/15/2016 Total Depth (ft) 4.5 Logged By DTM Checked By SWH Excavator Kelly's Excavating, Inc. Excavation Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Eesting (X) 1194330 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 724520 Horizontal Datum NAD83 SAMPLE 0 o m E MATERIAL REMARKS oID N DESCRIPTION CL c c a CL to to e 3m m W O H N 0 a W iv LLU TS Less rhea 1 inch topsoil Probe depth: 2 to 3 inches 8rovmish gray silty fine to medium sand with occasional SM gravel and Bobbles (dense, moist) (weathered till) 1 tiyti 3 GM [40 4+�j 2SA r..INEEN Tree roots at 2 feet Grayish brown silly gravel with sand (very dense, moist) (till) Test pit completed at 4'/2 feet No groundwater seepage observed No caving observed 6 1 26 I Probe depth: less than 1 inch Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. a LOCJ of 1 eSi 1'li 1 r-L Project: KG Investment Parcel, South Property G EO E N G I N E E R Project Location: Federal Way, Washington Figure A-3 Project Number: 9745-003-00 Sheet 1 of 1 Date B116/2016 Total 5 Logged By DTM Excavator Kelly's Excavating, Inc. Excavation Equipment Rubber Tired Backhoe Excavated Depth (ft) Checked By SWH Surface Elevation (ft) 2630 Easting (X) 1194460 Coordinate System WA State Plane,South lertical Datum NAVD88 Northing (Y) 724590 Horizontal Datum NAD83 Date Excavated 8/16/2016 Total Logged By DTM Depth (ft) 4.5 Checked By SWH Excavation Excavator Kelly's Excavating, Inc. Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Easting (X) 1194680 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 724490 Horizontal Datum NAD83 SAMPLE 0 d JR m W 0 o MATERIAL REMARKS 0 -J m DESCRIPTION io iD m iP I,! a GN � Q m 7 O 6 � o W O H (9 [7 U a W U U • DUF Approximately 6 inches forest duff; 124nch root depth sM Brown silty fine to medium sand with gravel (medium dense, e moist) (weathered till) 1 SA ti H IsM Brownish gray silty fine to medium sand with o gravel and cobbles (very dense, moist) (till) 6R ry� 44-M 2 Test pit completed at 4% feet No groundwater seepage observed No caving observed 7 127 Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-4 Project: KG Investment Parcel, South Property G Eo E N G I N E E R �J I JJ Project Location: Federal Way, Washington �� Figure A-5 Project Number: 9745-003-00 Sheet 1 of 1 Date Excavated 8/16/2016 Total Depth (ft) 5 Logged By DTM Checked By SWH Excavation Excavator Kelly's Excavating, Inc. Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Easting (X) 1194780 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 724410 Horizontal Datum NAD83 Date Excavated 8/15/2016 Total Depth (ft) 4 1 Logged By DTM Checked By SWH Excavator Kelly's Excavating, Inc. Excavation Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Easting (X) 1194950 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 724290 Horizontal Datum NAD83 aM SAMPLE d a C o MATERIAL = w h J W U C DESCRIPTION > C G C C N tll G 3 W 7 W 0 H Fm— ('�� U W • DUF Approximately 3 inches forest duff; 84nch root depth SM Grayish brown silty fine to medium sand with occasional gravel and cobbles (medium dense, moist) (fill?) GM j Brownish gray silty fine to coarse f cobbles (very dense, moist) (t Test pit camp]eted at 4 feet No groundwater seepage observed No caving observed REMARKS CmC w m �O C Co �U �U Probe depth: 3 to 6 inches 7 1 30 1 Probe depth. less than 1 hich Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. L09 OT I e51 1-11 1 P'-9 Project: KG Investment Parcel, South Property G M E N G I N E E R S� Project Location: Federal Way, Washington Figure A-7 Project Number: 9745-003-00 Sheet 1 of 1 --a -- - --- - -- - - Project: KG Investment Parcel, South Property S Project Location: Federal Way, Washington Figure A-8 G EO E N G I N E E R ��++ Proiect Number: 9745-003-00 Sheet 1 of 1 ate icavated 8/15/2016 Total Depth (ft) 4 Logged By DTM Checked By SWH Excavator Kelly's Excavating, Inc. Excavation Equipment Rubber Tired Backhoe rface Elevation (ft) 2630 Easting (X) 1195160 Coordinate System WA State Plane,SOuth rtical Datum NAVD88 Northing (Y) 724200 Horizontal Datum NAD83 SAMPLE 2 m d a W m o c ° C m rn J m m c c c a M w y W H Fm- t9 (e7 U w` • DUF SEA F3 = I MATERIAL DESCRIPTION Brownish gray with light oxidation staining silty fine t< medium sand with occasional gravel and cobbles (dense, moist) (weathered till) Brownish gray silty fine to medium sand with of gravel and cobbles (very dense, moist) (till) I as[ pit completed at 4 feel No groundwater seepage observed No caving observed REMARKS 0o co �U uU Probe depth: 3 inches Probe depth: less than 1 inch Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-8 Project: KG Investment Parcel, South Property G EO E N G! N E E R,!' Project Location: Federal Way, Washington Figure A-9 Project Number: 9745-003-00 Sheet 1 of 1 Date Total Logged By DTM Excavation Excavated 8/16/2016 Depth (ft) 4 Checked By SWH Excavator Kelly's Excavating, Inc. Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Easting (X) 1193990 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 724570 Horizontal Datum NAD83 Date Excavated 8/15/2016 Total Depth (ft) 6 Logged By DTM Checked By SWH Excavator Kelly's Excavating, Inc. Excavation Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Easting (X) 1194390 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 724360 Horizontal Datum NAD83 j SAMPLE0. i I 2 E o o MATERIAL REMARKS co 3 W U m DESCRIPTION �? je n C C a m t a m a Vi =-� 20 W 7 . r O W 0 F Fm- C7 (7 U W i ti ii ci DUF Approximately 6 inches forest duff; 16- to 20-inch root depth probe depth: 12 inches Brown silty fine to medium sand with occasional gravel sM A (medium dense, moist) (fill?) _ tbti t 13 1 47 see Brownish gray silty fine to medium sand with occasional gravel, cobbles and oxidation staining (dense, moist) (weathered till) 1 I Brownish gray silty fine to medium sand with gravel and cobbles (very dense, moist) (till) 3 4 e Test pit completed at 6 feet No groundwater seepage observed No caving observed Probe depth: less than Iinch Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-10 G W E N G I N E E R S ~ Project: KG Investment Parcel, South Property Project Location: Federal Way, Washington Figure A-11 Project Number: 9745-003-00 Sheet 1 of 1 Date Total Logged By DTM Excavation Excavated 8/15/2016 Depth (ft) 4.5 Checked By SW H Excavator Kelly's Excavating, Inc. IEquipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Easting (X) 1194530 Coordinate System WA State Plane,South vertical Datum NAVD88 Northing (Y) 7242901 Horizontal Datum NAD83 SAMPLE d m m m a c V v MATERIAL REMARKS w - U d DESCRIPTION > t c c n ,0 �'N C oCD o W D H Fes- l',9 (7 U W 2U DUF Approximately 9 inches forest duff; 16-inch root depth Probe depth: 10 inches tib SM I- Grayish brown silty fine to medium sand with occasional 7 gravel and cobbles (dense, moist) (weathered till) t SM Brownish gray silty fine to medium sand with occasional 6 gravel and cobbles (very dense, moist) (till) SA Test pit completed at 4I2 feet No groundwater seepage observed No caving observed 10 1 39 1 Probe depth: less than 1 inch Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-11 Project: KG Investment Parcel, South Property G M E N G I N E E RS Project Location: Federal Way, Washington Project Number: 9745-003-00 Figure A-12 Sheet 1 of 1 LYy LAI 1 VOL rlL 1 r- IL Project: KG Investment Parcel, South Property G E4 E N G I N E E R5 Project Location: Federal Way, Washington ft%! ..::• — Figure A-13 Project Number: 9745-003-00 Sheel 1 or 1 Date Total Logged By DTM Excavation Excavated 8/15/2016 Depth (ft) 4.5 Checked By SWH Excavator Kelly's Excavating, Inc. Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Easting (X) 1195010 Coordinate System WA State Plane,South /ertical Datum NAVD88 Northing (Y) 724100 Horizontal Datum NAD83 1 I I I Date Excavated 6/15/2016 Total Depth (ft) 4 Logged By DTM Checked By SWH Excavation Excavator Kelly's Excavating, Inc. Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 FEasting (X) 1194270 Coordinate System WA State Plane,South Vertical Datum NAVD88 hing (Y) 724290 Horizontal Datum NAD83 Date Total Logged By DTM Excavation Excavated 8/15/2016 Depth (ft) 5 Checked By SWH Excavator Kelly's Excavating, Inc. Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Easting (X) 1194550 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 724180 Horizontal Datum NAD83 SAMPLE `m m ^ m E MATERIAL O _ n U DESCRIPTION _ L m C C m L t° d y 2 A C W 0 H F- 0 00 W _ Approximately 6 inches forest duff: 3-inch root depth • DUF Brown silty fine to medium sand with occasional gravel SM (medium dense, moist) (fill?) 9 161 --3 1 ,p yb j sM I Brownish gray silty fine to medium sand with of F 3 gravel and cobbles (very dense, moist) (till) 2 5� — Test pit completed at 5 feet No groundwater seepage observed No caving observed REMARKS c C a �U O M Probe depth: 12 inches Probe depth: less than 1 inch 91 Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-15 �-- Project: KG Investment Parcel, South Property G G EO E N G I N E E R S Project Location: Federal Way, Washington Proiect Number: 9745-003-00 Figure A-16 Sheet 1 of 1 n Log of Test Pit TP-16 Project: KG Investment Parcel, South Property G EO E N G I N E E R S �-7' Project Location: Federal Way, Washington I Figure A-17 9 Project Number: 9745-003-00 Sheet 1 of 1 9 Date Excavated 8/15/2016 Total Depth (ft) 4 Logged By DTM Checked By SWH Excavation Excavator Kelly's Excavating, Inc. Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Easting (X) 1194680 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 724000 Horizontal Datum NAD83 SAMPLE io m JR m 0 o ° 2 MATERIAL — REMARKS = w N W m DESCRIPTION O v •10 > a C = �a _N U 6 .0 2Yl C = C all c C 0 -r m c W 0 H 1-� C9 (9 U lL i U LL U DUF Approximately 3 inches forest duff; 12-inch root depth Probe depth: 3 inches SM Grayish brown silty fine to medium sand with occasional gravel and cobbles (dense, moist) (weathered till) ti6�9 1 1 sM Brownish gray silty fine to medium sand with occasional t gravel and cobbles (very dense, moist) (till) ti6ry 3 2 11 1 11 1 1 1 1 1 Probe depth: 1 inch TosI pit coin, [aled at 4 reel No groundwater seepage observed No caving observed Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-18 Project: KG Investment Parcel, South Property G EO E N G I N E E R Project Location: Federal Way, Washington Figure A-19 �� Project Number: 9745-003-00 Sheet 1 of 1 Date Total Excavated 8/16/2016 Depth (ft) 4 Surface Elevation (ft) 2630 Vertical Datum NAVD88 SAMPLE m m v J m E � J 0 O c y fie N C C G 10 Q w 0 H Fes- 6 00 W DUF SM e 4 1 0 ti6 3 SM 2 Logged By DTM Excavator Kelly's Excavating, Inc. Excavation Rubber Tired Backhoe Checked By SWH Equipment Easting (X) 1194830 Coordinate System WA State Plane,South Northing (Y) 723920 Horizontal Datum NAD83 MATERIAL DESCRIPTION Approximately 4 inches forest duff; 8-inch root depth Grayish brown silty fine to medium sand with occasio gravel and cobbles (dense, moist) (weathered till) Brownish gray silty fine to medium sand with occasional gravel and cobbles (very dense, moist) (till) Tes; pi; compleled at 4 feet No groundwater seepage observed No caving observed REMARKS Probe depth: 6 inches Probe depth: less than 1 inch Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-19 Project: KG Investment Parcel, South Property G EO E N G I N E E R Project Location: Federal Way, Washington Figure A-20 Project Number: 9745-003-00 Sheet 1 of 1 wg rit I r-AU Project: KG Investment Parcel, South Property G EO E N G I N E E R5 Project Location: Federal Way, Washington Figure A-21 Project Number: 9745-003-00 Sheet 1 of 1 1 Project: KG Investment Parcel, South Property G EO E N G I N E E R Project Location: Federal Way, Washington Figure A-22 Proiect Number: 9745-003-00 Sheet 1 of 1 Date Total Logged By DTM Excavation Excavated 8/16/2016 Depth (ft) 4 Checked By SWH Excavator Kelly's Excavating, Inc. Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Easting (X) 1193930 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 723900 Horizontal Datum NAD83 SAMPLE I'e m 2 EEE o MATERIAL co g -J2 U U m DESCRIPTION REMARKS > > a C C .N .N L a ay 2 N C - C - p C [7U W iU LL0 sM Brown silty fine to medium sand wtth occasional gravel and cobbles (dense, moist) (weathered till) Probe depth: 1 to 3 inches t 9 ry6ti 1 SM Gray silty fine to medium sand with cobbles (very dense, moist) (till) 't6 2 ,t1 `yb 3 2 ti6 ti6 4 U O ul u Test pH compleled at 4 feel No groundwater seepage observed No caving observed Probe depth: less than 1 inch Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-22 Project: KG Investment Parcel, South Property G EO E N G I N E E R S �� Project Location: Federal Way, Washington �" �' Figure A-23 Project Number: 9745-003-00 Sheet 1 of 1 Date Total Logged By DTM Excavation Excavated 8/16/2016 Depth (ft) 6 Checked By SH Excavator Kelly's Excavating, Inc. Equipment Rubber Tired Backhoe W Surface Elevation (ft) 2630 Easting (X) 1194290 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 723800 Horizontal Datum NAD83 )ate Excavated 8/17/2016 Total Depth (ft) 4 Logged By DTM Checked By SWH Excavator Kelly's Excavating, Inc. Excavation Equipment Rubber Tired Backhoe urface Elevation (ft) 2630 Easting (X) 1194600 Coordinate System WA State Plane,South 'ertical Datum NAVD88 Northing (Y) 723700 Horizontal Datum NAD83 SAMPLE I-u iu m E o ° >➢ C w CQ J U O C je L G C C 'y 'y L a ay W 0 H F C9 (7 U W • DUF SM MATERIAL DESCRIPTION REMARKS C C 6 0 o 2U ,U Approximately 6 inches forest duff; 484nch root depth Probe depth: 12 inches Brown silty fine to coarse sand with gravel and cobbles (loose to medium dense, moist) (fill?) Gray silty fine to medium sand with gravel and occasional cobbles (very dense, moist) (till) Test pit completed at 4 feet No groundwater seepage observed No caving observed Probe depth: less than 1 inch Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. is Log of Test Pit TP-24 c a Project: KG Investment Parcel, South Property G M E N G I N E E RProject Location: Federal Way, Washington Figure A-25 �� Project Number: 9745-003-00 Sheet 1 of 1 Date Excavated 8/17/2016 Total Depth (ft) 4 Logged By DTM Checked By SWH Excavation Excavator Kelly's Excavating, Inc. Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Easting (X) 1193880 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 723770 Horizontal Datum NAD83 j SAMPLE w IJ Y °' m U N a 7 y 70 �p CD N W 0 H Fes- 0 00 SM W - 6`t9 SM 6rt0 ,y1 2 MATERIAL DESCRIPTION lyish brown silty fine to medium sand with gravel and cobbles (dense, moist) (weathered till) Brownish gray silty fine to medium sand cobbles (very dense, moist) (till) Test pit completed at 4 feel No groundwater seepage observed No caving observed REMARKS m O O O C O mU iro Probe depth: 2 to 3 inches Probe depth: less than 1 inch Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-26 r Project: KG Investment Parcel, South Property G M E N G I N E E R 5 Project Location: Federal Way, Washington Figure A-27 Project Number: 9745-003-00 Sheet 1 of 1 Date Total Logged By DTM B117/2016 9 By SWH Excavator Kelly's Excavating, Inc. Excavation Equipment Rubber Tired Backhoe Excavated Depth (ft) Checked Surface Elevation (ft) 2630 Easting (X) 1194120 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 723710 Horizontal Datum NAD83 SAMPLE d E m c m MATERIAL REMARKS m c v O m V U m C DESCRIPTION it > C C C N N d 2 H 2 l0 U a 0 � O m C � � U SM Probe depth: 3 to 4 inches Grayish brown silty fine to medium sand with gravel, cobbles and occasional debris (medium dense to dense, moist) (fill) z SM Brown silty fine to medium sand with tree roots and e occasional gravel (medium dense, moist) (fill) fiery 4 ML Brownish gray oxidation staining silt with sand and occasional gravel (hard, moist) (weathered till) ryy rye 5 a -zo0 o rya a rye 6 — — — — — _— H sM Brownish gray with oxidation staining silty sand with gravel and cobbles (very dense, moist) (till) `tierye 7 rye a sM Grayish brown silty fine to medium sand with o gravel and cobbles (very dense, moist) (till) 4 ryery• 9 Test pit completed at 9 feet No groundwater seepage observed No caving observed Probe depth: 2 to 3 inches 26 I 94 I LL=29; PI=4 i I Notes: See Figure A-1 for explanation of symbols. LThe depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-27 S Project: KG Investment Parcel, South Property rn.�f� Project Location: Federal Way, Washington �] EO E N G I N E E R S - - Project Number: 9745-003-00 Figure A-28 Sheet 1 of 1 Date Excavated 8/17/2016 Total Depth (ft) 4 Logged By DTM Checked By SWH Excavator Kelly's Excavating, Inc. Excavation Equipment Rubber Tired Backhoe Surface Elevation (ft) 2630 Easting (X) 1194440 Coordinate System WA State Plane,South Jertical Datum NAVD88 Northing (Y) 723610 Horizontal Datum NAD83 SAMPLE -� v n w m � W i; o � MATERIAL � J U �° U m DESCRIPTION C C m L a y W c U W TS Approximately 6 inches topsoil with occasional debris; 6-inch root depth Grayish brown with oxidation staining silty fine to medium SM sand with occasional gravel (dense, moist) (weathered till) SM Brownish gray silty fine to medium sand with occasional gravel (very dense, moist) (till) 2 d o m e REMARKS a� m W �U L Probe depth: 7 inches ti9 tib t ti0 tb 2 tit `�6 3 Probe depth: less than 1 inch 14 4 Test pit completed at 4 feet No groundwater seepage observed No caving observed i� if 0. O 7� G H yg�g ■ m pO l45 75 Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-28 G EO E N G I N E E R S ��s', ~ Project: KG Investment Parcel, South Property Project Location: Federal Way, Washington Figure A-29 Project Number: 9745-003-00 Sheet 1 of 1 or Date g/17/2016 Total 4 Logged B DTM gg y Excavator Kelly's Excavating, Inc. Excavation Rubber Tired Backhoe Equipment Excavated i Depth (ft) Checked By SWH Surface Elevation (ft) 2630 Easting (X) 1194610 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 723540 Horizontal Datum NAD83 SAMPLE m m _ m E C rn J U m O t.. rr rn C C V L 6 Gy 7 C oU ID m m N 2 IO ` lL 0 E- F- t7 00 W SI MATERIAL DESCRIPTION = C m C 120 LL0 fwn silty fine to medium sand with occasional gravel and cobbles (medium dense, moist) (fill); 10-inch root depth Gray silty fine to medium sand with occasional gravel and cobbles (very dense, moist) (till) Test pit completed at feet No groundwater seepage observed No caving observed REMARKS Probe depth: 6 inches Probe depth: less than finch Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-29 Project: KG Investment Parcel, South Property G EO E N G I N E E R S Project Location: Federal Way, Washington Figure A-30 Project Number: 9745-003-00 Sheet 1 of 1 )ate g/17/2016 xcavated Total 4 Depth (ft) Logged By DTM ' Checked By SWH I Excavator Kelly's Excavating, Inc. Excavation Equipment Rubber Tired Backhoe urface Elevation (ft) 2630 Easting (X) 1193820 Coordinate System WA State Plane,South 'ertical Datum NAVD88 Northing (Y) 723520 Horizontal Datum NAD83 SAMPLE w m 2 CD E o o MATERIAL _ REMARKS C v W U m DESCRIPTION jp > t.. G N N W 7 q CO 0 C W 0 H Fm- 0 a ui i sM Probe depth: 2 to 4 inches Grayish brown silty fine to medium sand with gravel and cobbles (dense, moist) (weathered till) Y 1 `� 3 sM I I Brownish gray silty fine to medium sand with gravel and cobbles (very dense, moist) (till) 2 I I I I f I I e l 45 I Probe depth: less than 1 inch ti6ry6 4i_�i Test pit completed at 4 feet No groundwater seepage observed No caving observed Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-30 G S Project: KG Investment Parcel, South Property EO E N G I N E E R Project Location: Federal Way, Washington - Figure A-31 Project Number: 9745-003-00 Sheet 1 of 1 Date Total Logged By DTM Excavation 8/17/2016 7 SWH Excavator Kelly's Excavating, Inc. Equipment Rubber Tired Backhoe Excavated Depth (ft) Checked By Surface Elevation (ft) 2630 Easting (X) 1194200 Coordinate System WA State Plane,South Vertical Datum NAVD88 Northing (Y) 723430 Horizontal Datum NAD83 SAMPLE ., iP C a MATERIAL REMARKS C w N -J m DESCRIPTION �` Z6. .W t a) m c c o m a m y y Q W C q0 �U -o O C LLU lL r] ►- F- C7 C9 U w sM Grayish brown silty fine to medium sand with gravel, Probe depth: 3 inches M-1 cobbles and occasional debris (medium dense to dense, moist) (fill) 9 4 1 1 art$ `I 2 1r sM 1 Dark hrpwn sitty fine Ta medium sand wrih trace roots and 1 J I I occasions gravel (medium dense to dense, moist) (fill) 0 S 2 sM I j -Grayish brown with oxidation staining silty fine to medium sand with gravel and cobbles (dense, moist) (weathered till) SM Gray silly fine to medium sand with gravel and a II cobbles (eery dense, moist) (till) ry6ti 3 �6 7 Test pit completed at 7 feet No groundwater seepage observed No caving observed Probe depth: 1 to 4 inches S Notes: See Figure A-1 for explanation of symbols. The depths on the test pit logs are based on an average of measurements across the test pit and should be considered accurate to 0.5 foot. Log of Test Pit TP-31 Project: KG Investment Parcel, South Property G EO E N G I N E E R S ,/ Project Location: Federal Way, Washington Figure A-32 - - Project Number: 9745-003-00 Sheet 1 of 1 i i i i iiiii i iiii r■I� iii rcr mmmmm Mona Swoon i i i i lii�ylr ii i i i ■........�•. iiii_ iiiirfJiiii�►.LJ iiiiiiii iiiiiiiii ,. ■■■■■■iiiii■■■■■■■■■ ONE ■■■■■■ �N.rr,�.riiiii iic:'•7i� [i=il,�iiiiiiiiiii ■■■■■■■■■■■■■■■■■■■■ ■■■■■■■■■■■■■■■■■■■■ -------------------- ■■■■■■■■■■■■■■■■■■■■ ■■■■■■■■■■■■■■■■■■■■ MEMO■■■■■■■■■■■■■■■■ moommmummmmommmm ■■■■■■■■■■■■■■■■■■■■ ■■■■■■■■■■■■■■■■■■■■ iii�iii��iiiiA■iii�ii iiii��i�i �t �•~�Y�ii�i Hiiiii ■■■■■■ w i i iirli�l►Ili iiiii»iiiw i i� i i��i� 7 �iiii�ii i �!•ii A■ i 1�ii�iiri ��iii� A■ i i�A■ i R�� .. •i�i�iiii�iii�ii ar[ - ■i*sii�iiii�iii�� MEIN■■■ A� 1I i �A■ � i ii�iiii �A•iiA■ � i ■� i ii i i ii iiii i iiiii iw ■■■■■■■■■■■■■■■■■■o ■■■■■■■■■■■■■■■■■■■■ i i�ii i i �A•i i i �� iiiii Y � N 3 3 3 EO f�17 N N (n In fn d7 d 7 .o t CV y E d d d H Z N 0 0 o 3 N a� T N a) N O � n L � 3 N a 0 O O N ar O N n no N N o a o � m N T C C o m d o � o v O vi a O O O O O `� O � - yy j L O co Tf N N n N O a �- � V> O J N J N o W � p w 0 d N Z w ° m p CC o W N c7 o o m p Z Z ¢ o m N < Q R [] n Y o M P o o J o> �i C m N a M Ljj � - N w N C a � p jA 11.1 U1 q I m a o U eq O � � o c d 3 OJ $a 1 Y LLj o a C N m Q C t N T Ci T N C o n N N C N L a) N L O N t- O O O O O O O O 0 O O O `i O Z 0 O OD 1_ (0 IP) It M N ei 1HO13M AS JNISSdd 1N33HU n 0 Sieve Analysis Results KG Investment Parcel, South Property Federal Way, Washington Q 0 o GEOENGINEERS� FigureA-35 m c N Y cJc L � p c a �O � y N � i N o �O � 00 Q F M M a s N M � d d I � | I k 0 � .Go 0 � 2 E % k \\B a § $ /{k ( wa CD 2 \ � aa 2G; ] \\% o )/@ ( /{k \ \k\ � k \ 2 2 $ -\ k\{ Xam A1Ilol �d `Z £ /\} \ \\} \ /0 x � O & _ � � o '\ � & O �� . � ��. o 0 . � \ � d ® � � � o § 3 � / k m m � � � � . ■ � R � . � E / � � � W m 2 t 2 k 2 � � � k� Z � � W 2 � W � � ^ � \ § � $ /2/ .£� « E �\/ m _ {k/ m ^ 2k� �� 2 .k ) �2 - / « m APPENDIX E Report Limitations and Guidelines for Use I APPENDIX E -� REPORT LIMITATIONS AND GUIDELINES FOR USE1 This appendix provides information to help you manage your risks with respect to the use of this report. 1 Read These Provisions Closely It is important to recognize that the geoscience practices (geotechnical engineering, geology and environmental science) rely on professional judgment and opinion to a greater extent than other engineering and natural science disciplines, where more precise and/or readily observable data may exist. To help clients better understand how this difference pertains to our services, GeoEngineers includes the following explanatory "limitations" provisions in its reports. Please confer with GeoEngineers if you need to know more how these "Report Limitations and Guidelines for Use" apply to your project or site. Geotechnical Services are Performed for Specific Purposes, Persons and Projects This report has been prepared for Federal Way Campus, LLC for the project specifically identified and described in the report. The information contained herein is not applicable to other sites or projects. GeoEngineers structures its services to meet the specific needs of its clients. No party other than the party to whom this report is addressed may rely on the product of our services unless we agree to such reliance j in advance and in writing. Within the limitations of the agreed scope of services for the Project, and its 11 schedule and budget, our services have been executed in accordance with ourAgreement with Federal Way Campus, LLC dated June 27, 2017 and generally accepted geotechnlcal practices in this area at the time this report was prepared. We do not authorize, and will not be responsible for, the use of this report for any purposes or projects other than those identified in the report. A Geotechnical Engineering or Geologic Report is based on a Unique Set of Project -Specific Factors This report has been prepared for the proposed development, as described in this report, to be located in Federal Way, Washington. GeoEngineers considered a number of unique, project -specific factors when establishing the scope of services for this project and report. Unless GeoEngineers specifically indicates otherwise, it is important not to rely on this report if it was: o not prepared for you, e not prepared for your project, F not prepared for the specific site explored, or r completed before important project changes were made. Ji Developed based on material provided by ASFE, Professional Firms Practicing in the Geosciences; www.asfe.org. September 19, 2017 Page E-1 G W ENG I N E ERS� File No. 22247-003-00 For example, changes that can affect the applicability of this report include those that affect: I. the function of the proposed structure; I elevation, configuration, location, orientation or weight of the proposed structure; E. composition of the design team; or r, project ownership. If changes occur after the date of this report, GeoEngineers cannot be responsible for any consequences of such changes in relation to this report unless we have been given the opportunity to review our interpretations and recommendations. Based on that review, we can provide written modifications or confirmation, as appropriate. Environmental Concerns are Not Covered Unless environmental services were specifically included in our scope of services, this report does not provide any environmental findings, conclusions, or recommendations, including but not limited to, the likelihood of encountering underground storage tanks or regulated contaminants. Subsurface Conditions Can Change This geotechnical or geologic report is based on conditions that existed at the time the study was performed. The findings and conclusions of this report may be affected by the passage of time, by man-made events such as construction on or adjacent to the site, new information or technology that becomes available subsequent to the report date, or by natural events such as floods, earthquakes, slope instability or groundwater fluctuations. If more than a few months have passed since issuance of our report or work product, or if any of the described events may have occurred, please contact GeoEngineers before applying this report for its intended purpose so that we may evaluate whether changed conditions affect the continued reliability or applicability of our conclusions and recommendations. Geotechnical and Geologic Findings are Professional Opinions Our interpretations of subsurface conditions are based on field observations from widely spaced sampling locations at the site. Site exploration identifies the specific subsurface conditions only at those points where subsurface tests are conducted or samples are taken. GeoEngineers reviewed field and laboratory data and then applied its professional judgment to render an informed opinion about subsurface conditions at other locations. Actual subsurface conditions may differ, sometimes significantly, from the opinions presented in this report. Our report, conclusions and interpretations are not a warranty of the actual subsurface conditions. Geotechnical Engineering Report Recommendations are Not Final We have developed the following recommendations based on data gathered from subsurface investigation(s). These investigations sample just a small percentage of a site to create a snapshot of the subsurface conditions elsewhere on the site. Such sampling on its own cannot provide a complete and accurate view of subsurface conditions for the entire site. Therefore, the recommendations included in this report are preliminary and should not be considered final. GeoEngineers' recommendations can be finalized only by observing actual subsurface conditions revealed during construction. GeoEngineers GMENGINEERS� September 19, 2017 Page E-2 File No. 22247-003-00 cannot assume responsibility or liability for the recommendations in this report if we do not perform construction observation. We recommend that you allow sufficient monitoring, testing and consultation during construction by GeoEngineers to confirm that the conditions encountered are consistent with those indicated by the explorations, to provide recommendations for design changes if the conditions revealed during the work differ from those anticipated, and to evaluate whether earthwork activities are completed in accordance with our recommendations. Retaining GeoEngineers for construction observation forthis project is the most effective means of managing the risks associated with unanticipated conditions. If another party performs field observation and confirms our expectations, the other party must take full responsibility for both the observations and recommendations. Please note, however, that another party would lack our project - specific knowledge and resources. A Geotechnical Engineering or Geologic Report Could Be Subject to Misinterpretation Misinterpretation of this report by members of the design team or by contractors can result in costly problems. GeoEngineers can help reduce the risks of misinterpretation by conferring with appropriate members of the design team after submitting the report, reviewing pertinent elements of the design team's plans and specifications, participating in pre -bid and preconstruction conferences, and providing construction observation. Do Not Redraw the Exploration Logs Geotechnical engineers and geologists prepare final boring and testing logs based upon their interpretation of field logs and laboratory data. The logs included in a geotechnical engineering or geologic report should never be redrawn for inclusion in architectural or other design drawings. Photographic or electronic reproduction is acceptable, but separating logs from the report can create a risk of misinterpretation. Give Contractors a Complete Report and Guidance To help reduce the risk of problems associated with unanticipated subsurface conditions, GeoEngineers recommends giving contractors the complete geotechnical engineering or geologic report, including these "Report Limitations and Guidelines for Use." When providing the report, you should preface it with a clearly written letter of transmittal that: Ei advises contractors that the report was not prepared for purposes of bid development and that its accuracy is limited; and u encourages contractors to confer with GeoEngineers and/or to conduct additional study to obtain the specific types of information they need or prefer. Contractors are Responsible for Site Safety on Their Own Construction Projects Our geotechnical recommendations are not intended to direct the contractor's procedures, methods, schedule or management of the work site. The contractor is solely responsible for job site safety and for managing construction operations to minimize risks to on -site personnel and adjacent properties. GEOENGINEER September 19, 2017 Page E-3 File No. 22247-003-00 Biological Pollutants GeoEngineers' Scope of Work specifically excludes the investigation, detection, prevention or assessment of the presence of Biological Pollutants. Accordingly, this report does not include any interpretations, recommendations, findings or conclusions regarding the detecting, assessing, preventing or abating of Biological Pollutants, and no conclusions or inferences should be drawn regarding Biological Pollutants as they may relate to this project. The term "Biological Pollutants" includes, but is not limited to, molds, fungi, spores, bacteria and viruses, and/or any of their byproducts. A Client that desires these specialized services is advised to obtain them from a consultant who offers services in this specialized field. GMENGINEERS� September 19, 2017 Page E-4 File No. 22247-003-00