20230802 5th Ltr (Woodbridge Bus Pk-Tech Rev)
Civil Engineers
Structural Engineers
Landscape Architects
Community Planners
Land Surveyors
Neighbors
TACOMA
2215 North 30th Street
Suite 300
Tacoma, WA 98403-3350
253.383.2422 TEL
www.ahbl.com
August 2, 2023
Eric LaBrie
ESM Consulting Engineers, LLC
33400 8th Avenue South, Suite 205
Federal Way, WA 98003
Eric.labrie@esmcivil.com
Project: City Project Nos. 17-105489-UP, 17-105490-SE, and 21-104771-SH
AHBL No. 2200534.30
Subject: Technical Review Comments
Woodbridge Business Park (aka Greenline Business Park)
327xx Weyerhaeuser Way South, Federal Way
Dear Mr. LaBrie:
The City received a resubmittal of the plans and documents associated with the Process IV
and SEPA review of the above project on Feb. 16, 2023, they were routed internally on March
7 and March 10, and I received the files on March 24, 2023.
• Response to Technical Comments Letter prepared by ESM dated Feb. 10, 2023
• Revised Process IV Plan Set prepared by ESM dated Feb. 8, 2023 (17 Sheets including
Civil plans, Landscape Plans and Tree Retention Plan)
• Cultural Resources Reports:
o Archaeology Review prepared by HDR dated Dec. 23, 2023
o Built Environment Report Part 1 prepared by Cardno dated July 29, 2020
o Built Environment Report Part 2 (Appendix) prepared by Cardno dated July 29,
2020
o Cultural Resource Survey prepared by Tetra Tech dated July 17, 2017
o Historic Resources Effects Assessment prepared by ICF dated Jan. 2023
• Critical Areas Response to Comments Letter prepared by Wet.land dated Feb. 9, 2023
• Revised Critical Areas Report Addendum prepared by Wet.land dated Feb. 9, 2023
• Parking Exhibit prepared by ESM dated Oct. 18, 2022
• Pavement Analysis Final Report prepared by GeoEngineers dated Jan. 12, 2023
• Preliminary Technical Information Report dated Feb. 8, 2023
• Revised SEPA Checklist dated Feb. 2023
• Shoreline Jurisdictional Detail Exhibit prepared by ESM undated
• Response to Technical Review Comments prepared by TENW dated Dec. 9, 2022
• Visual Impact Exhibits prepared by Nelson dated Nov. 3, 2022
• Visual Impact Letter prepared by Nelson undated
In addition to the above items, you also submitted two requests for deviations from the Public
Works Department. These were responded to separately by the City.
Eric LaBrie
August 2, 2023
2200534.30
Page 2 of 9
These comments reflect City staff review comments for each of the above referenced
applications. The City has the following comments in response to the resubmittal. It is to be
noted that this is the 5th Technical Review Letter. If you would like a meeting with the City to
provide needed clarification or to help facilitate your response to these comments, please let us
know and we will get one set up.
Summary of Proposed Revisions
The primary modifications and information in the resubmittal include:
• Parking additions, with a parking exhibit
• Updated survey of the North Lake / Shoreline Ordinary Highwater Mark
• Site Driveways and Stormwater Vault Modification Requests
• Added southbound right-turn lanes at 2nd and 4th driveways
• Revised Visual Impact Exhibits
• Additional archaeological/historic/cultural resources survey information
Governing Regulations
The proposal is subject to the provisions of the 1994 Weyerhaeuser Company Concomitant Pre-
Annexation Development Agreement (CZA), and Corporate Park Zone (CP-1) zoning regulations in effect
on August 23, 1994. Critical areas are to be reviewed under the City’s current Critical Areas regulations of
the Federal Way Revised Code (FWRC) Chapter 19.145, and the Shoreline Permit is being reviewed
under FWRC Chapter 15.05. Drainage for new development shall be designed to comply with current
Federal Way drainage requirements and the land use procedural requirements are to follow FWRC Title
19.
Some comments provided herein are required to be addressed and some are informative, while others
may be applicable during future steps of the project. Comments in this letter that need to be addressed
prior to issuance of a SEPA threshold determination and/or the land use application staff report, are
provided in bold text. Questions regarding technical review comments should be addressed to the
referenced staff representative.
Lisa Klein – Contract Planner, (253) 651-7907, lklein@ahbl.com
Stacey Welsh – Planning Division, (253) 835-2634, stacey.welsh@cityoffederalway.com
1. Technical comments made about an item on one sheet may necessitate changes to other sheets
and related documents, and it is the applicant’s responsibility to determine any such necessary
adjustments. Please ensure consistent information is communicated throughout the plan set
and associated application materials.
Parking
2. Off-street parking shall comply with the 1994 Federal Way zoning code (FWCC) as modified by the
provisions of Section XIII of the CP-1 regulations. Required parking is one parking space per 300
square feet of gross floor area (GFA) for office, and one parking space for every 1,000 square feet
of GFA for warehouse. You submitted a Parking Exhibit and revised Civil Site Plan indicating that
the code required quantity would be met. You provided total building size and number of parking
spaces, but a floor plan has not been submitted, and the breakdown of office and warehouse space
has not been provided/determined.
Eric LaBrie
August 2, 2023
2200534.30
Page 3 of 9
a. Assuming that 10 percent of each building is office space, Table 1 below illustrates that
Buildings 1 and 2 are deficient in proposed parking (This allocation of parking is consistent
with previous City review of Greenline Warehouse A project (16-102947-UP)). Provide
additional parking spaces for Buildings 1 and 2 or reduce the building size to meet the
parking quantity calculation. Alternatively, if you anticipate that there will be less
than 10 percent of any building dedicated to office space, respond with the
anticipated size of the office space and provide the alternative calculation (there
should be an assumption of some office space for each building).
Table 1 – Parking Calculation Per Building
Existing
WTC
Building
Building 1 Building 2 Building 3
Total Building Area 468,457 SF 605,195 SF 240,275 SF 125,520 SF
Total Spaces
Provided
705 727 289 156
10% office space
assumption and
required parking
n/a 60,520 SF =
202 spaces
24,028 SF=
80 spaces
12,552 SF =
42 spaces
90% warehouse
space assumption
n/a 544,675 =
544 spaces
216,247 SF=
216 spaces
112,968 SF =
113 spaces
Total required
parking spaces
699 746 296 155
Difference in
required parking
+ 5 spaces - 19 spaces - 7 spaces + 1 space
b. FWCC 22-1398 Division 3 allows for parking to be located on a lot adjoining the subject
property, if the lot is in a zone that permits the use. The City will require a covenant or other
instrument requiring that the lot be devoted in whole or in part to required parking for the use
on another lot. The covenant must be recorded to run with all affected properties prior to
issuance of building permits. This may be a recommended condition of approval.
c. As you noted in the Response to Technical Review Comments letter, there are 225 parking
spaces located within 187 feet of the rear of the WTC building. Depending on the future
parking needs of users within the WTC, this area may instead be used for loading or building
access, which is currently the case. You have also indicated intent to provide outdoor
storage in the rear of the WTC Building. You cannot propose the code-required minimum
parking and at the same time state that the area may be used for loading or outdoor storage
within the area of the proposed parking spaces. Either remove the loading and outdoor
storage from the proposal or provide additional parking elsewhere for the WTC
Eric LaBrie
August 2, 2023
2200534.30
Page 4 of 9
building to meet the minimum parking requirement. It is understood that a future
parking modification process (as described in FWC 22-1398) may be needed should
these spaces be needed for loading, building access, or outdoor storage.
d. Section XIII of the CP-1 regulations provided in the CZA provide that existing development
and uses are deemed to comply with the minimum required number of spaces (i.e., the WTC
Building parking), but new development is required to comply with the following (emphasis
added in underlined text):
“New development shall require compliance with applicable off-street parking minimums,
except in computing off-street parking requirements, the aggregate of all proposed and
existing uses on the property may, subject to approval of the Director, be considered as a
whole in establishing the minimum number of vehicle spaces required, based on the
following:
(1) Any excess capacity in existing parking spaces lying within 800 feet of a proposed
development may be used to reduce the requirement for additional parking
development.
(2) If the occupant of a proposed use provides van or alternative service between the
proposed use and remote parking facilities, any excess parking on the entire property
may be used to reduce the requirement for additional parking development.”
Our understanding of the above requirements is that you are to provide the code-required
minimum parking spaces per building (existing spaces for WTC Building). Alternatively, if
you have an excess of parking for one building, but the overall aggregate parking quantity
meets code, you may choose to share any excess spaces among other buildings. In this
scenario, you must request the Director’s approval of the aggregate parking quantity and
demonstrate compliance with Items (1) and (2) above.
If you are unable to meet the code-minimum parking requirements per building, but
are able to meet the aggregate requirements, you may request approval and
demonstrate compliance with Section XIII.B. (1) and (2) provided above. Alternatively,
you may apply for a Variance; however, please note that it is not likely that a variance
could be approved when building sizes could be reduced to accommodate additional
parking, among other alternatives.
View Impacts / SEPA
3. The resubmittal included additional historical and cultural resources information that responds to
previous City comments. The new information has been routed to the Historic and Cultural
Resources consultant for review and comment. You will be provided comments under separate
cover from the consultant.
The Visual Impacts Exhibit you submitted dated November 3, 2022, provides additional information
but remains difficult to interpret and may be difficult for the public and hearing examiner to interpret
as well. We remind you that the burden of proof is yours to demonstrate, as you say in your
response letter, that “the Business Park buildings will be hidden by the forested buffers and existing
vegetation”. Staff recommends that you prepare a visual impact assessment similar in format to
the Visual Impact Assessment dated March 22, 2018 so that staff and the hearing examiner can
fully assess the level of screening to be provided. The assessment should clearly show building
size and scale, as well as the landscaping and tree retention proposed to mitigate for the impacts.
The original Visual Impact Assessment dated March 22, 2018, is a good example of what the City
is looking for, together with the additional viewpoints the City requested (and that you provided in
Eric LaBrie
August 2, 2023
2200534.30
Page 5 of 9
the recent resubmittal). Prepare and provide a Visual Impact Exhibit, similar to the Visual
Impact Assessment dated March 22, 2018 that demonstrates how the landscaping and tree
retention will mitigate view impacts from each of the six viewpoints depicted on the Visual
Renderings dated November 22, 2021.
Managed Forest Buffer, Landscape Plans, and Tree Retention
4. The screening of the truck bays on the north side of Building A to the future right-of-way and
properties to the north may require enhancement. The WFC Plan describes the western half of this
area as containing Forest Cover Type III. Forest Cover Type III is described in the WFC Plan as
being poorly stocked with 30 trees per acre and containing large gaps where shade tolerant
conifers, such as western red cedar, could be planted. Interplanting with a shade tolerant tree
species would improve this buffer over time and screen the truck bays from the future right-of-way.
In lieu of revising the landscape plans at this time to include the addition of shade tolerant tree
species within Forest Cover Type III, you have requested a condition of approval that the buffer be
assessed post-construction to determine where infill plantings should occur, if needed. Staff
concurs that this approach is acceptable. We may recommend a condition of approval will
require assessment of the buffer post-construction, and infill plantings provided in
conjunction with the forester’s recommendations for shade tolerant trees in this location.
5. There are concerns about the location of the storm vault northeast of Building 1 (see the Traffic
Division comments, below). No groundcover was provided over Vault 1A, however landscape
islands with groundcover, shrubs and one tree are depicted over Vault 1B. If the vault is to remain
in this location, any portions not required to be free of cover shall be landscaped with grass or other
groundcover. Provide landscape groundcover on Vault 1A.
6. FWCC Sec. 22-1564(b) requires all outside storage areas be fully screened by Type I landscaping
a minimum of 5 feet in width. According to aerial photographs and Sheet Ex-01, there is currently
an outside storage area in the rear/west side of the existing WTC Building. The plans show
reconstruction of the rear parking lot to provide all parking, however your Response to Technical
Review Comments indicate that outside storage is intended to remain. The City remains concerned
about views of the outdoor storage area from Interstate 5 once the ponds are constructed and trees
removed.
The landscape plans provide a landscape buffer around the exterior of the parking lot; however, the
landscape plans have coded the west perimeter buffer as “building façade planting”, not Type 1.
The landscape plans appear to rely upon the retained vegetation outside the parking lot perimeter
for the required Type 1 landscaping. The comment response letter indicates that 10-foot-tall trees
will be supplemented within the area to the west of the parking lot perimeter but there are no notes
on the landscape plans to that end. The preliminary plant palette indicates tree heights at planting
will be 6 feet. Staff concurs that the Type 1 landscaping will be met in the combined area of the
perimeter parking lot landscaping and the wetland buffer plantings with the addition of the proposed
trees and the planting scheme at the parking lot perimeter. Revise the landscape plans to fully
screen the rear side of the WTC Building with Type I landscaping a minimum of 5 feet in
width located on the west perimeter of the parking lot. Revise the landscape plans
specifically note that the supplemental trees planted in the area west of the parking lot
perimeter will be 10-feet tall at the time of planting. Revise the Preliminary Plant Palette to
indicate a range of tree heights at planting of between 6’ and 10’. Note that we may
recommend a condition of approval so that the area west of the WTC building can be
assessed post-construction and additional supplemental plantings provided if needed.
Eric LaBrie
August 2, 2023
2200534.30
Page 6 of 9
7. The landscape plans are blank in the area southwest of Detention Pond #5. Correct the
landscape plans to depict the intended planting scheme in the area southwest of Detention
Pond #5.
8. There are notes provided on Sheet LA-02 that need rewording/clarification. The note is specific to
a callout to an area east of Detention Pond 5. The Note reads that all trees between detention
pond #5 and Weyerhaeuser Way are 10-feet minimum in height at time of planting. The Notes
further states to refer to the Plant Legend on Sheet LA-01 (which provides 6-foot as the minimum
planting height). The note further provides that all evergreen trees at this location shall be 10 feet
in height at planting. Revise the note to correct the inconsistency by removing the last
sentence so that all trees in this area are to be 10-foot in height at planting.
Shoreline Substantial Development Permit Review Comments
9. The ordinary highwater mark (OHWM) of North Lake was field delineated in November 2022 at the
request of the City. The new delineation was surveyed, and the location was incorporated into the
figures in the Revised Critical Areas Report Addendum and Shoreline Jurisdictional Detail exhibit.
The updated survey of the OHWM shows that all proposed construction falls outside of the 200-foot
Shoreline Management Zone (SMZ); therefore, a shoreline permit is no longer required. The City
requires that you submit a letter formally withdrawing the Shoreline Substantial
Development Permit application.
Wetlands and Streams
10. Review and address each comment in the enclosed June 9, 2023, review letter from the
City’s wetland consultant, ESA.
SEPA Checklist
11. On your next resubmittal, use the new State SEPA checklist dated January 2023.
12. Add the revision date for the Preliminary Technical Information Report to response to A.8.
13. Remove Shoreline Management Substantial Development Permit from response to A.10.
14. Add City Critical Areas Review to response A.10.
15. Revise Section 13(c), to include the technical reports and studies completed to assess the
historic and cultural resources affecting the site.
Other Details
16. Question B.3.a.2 and the Revised CAR describes 8,585 SF of wetlands to be directly impacted
(filled). Sheet CV-01 describes 12,078 SF of wetland fill. Revise Sheet CV-01 to be consistent.
17. The SEPA checklist provides that 59.8 acres or 61% of the site will be covered with impervious
surface, which is reduced from the November 2021 SEPA checklist. Sheet CV-01 describes that
60.70 acres will be impervious surface, which is unchanged since the November 2021 plans. The
Preliminary Technical Report dated Feb. 8, 2023 describes 71.25 acres of impervious surface
(which is equivalent to 73% of the 97,66 acre site). You have added impervious area to the project
Eric LaBrie
August 2, 2023
2200534.30
Page 7 of 9
with the additional parking areas, but it does not appear to be fully reflected in all of the
documents/plans. Update all plans and documents to reflect the revised impervious areas.
Cole Elliot – Public Works Development Services, (253) 835-2730,
Cole.elliott@cityoffederalway.com
A Public Works Administration Decision (AD) request is needed for allowing semi-trucks to use
Weyerhaeuser Way south of the business park. Without that request we cannot identify
mitigation and/or allow semi-truck traffic south of the Business Park. The applicant can contact
Cole Elliot for more information.
Sarady Long – Public Works Traffic Division, (253) 835-2743, sarady.long@cityoffederalway.com
The Public Works traffic Division has finished its review of the submitted materials and
provides the following technical review comments. Please note, traffic related
comments/concerns by WSDOT and other agencies must be addressed and approved by the
respective agency.
Plans Comments
1. Revise plans to show street improvement and right-of-way (row) dedication along the entire
frontage that abuts the subject property on S 336th St, Weyerhaeuser Way S and at the
Weyerhaeuser Way S roundabout. Unless a street modification is granted/approved by the Public
Work Director, the plans must show the improvements and row dedication along the entire property
frontage on Weyerhaeuser Way S., S 336th St. and at the roundabout as required by code (FWCC
22-1474). ADA compliant pedestrian facilities must be provided at the roundabout.
2. Sheet FR-01 - Pavement reconstruction plan: Use one pavement design (Section E) for the whole
truck travel route on Weyerhaeuser Way S including the roundabouts. Section E pavement design
is adequate for UP review and approval. The final design will be reviewed and approved in EN
stage.
3. Verify if trucks will be utilizing S 336th St from Weyerhaeuser Way S to SR 99. Pavement
reconstruction on S 336th St may be needed if current pavement is not adequate to accommodate
the truck traffic.
4. The preferred City Center Access alternative identified a roundabout at 23rd Avenue S and
Weyerhaeuser Way S. Verify queuing from the northerly driveway will not impact the roundabout
and coordinate with the City Center Access Study team to determine the roundabout design.
5. Driveways should be constructed to commercial, industrial driveway approach standard. A street
modification will need to be submitted and approved by the PW director to utilize radius driveway
and any driveways width exceeding the maximum 30’.
6. Verify WB-67 truck can maneuver the roundabout on Weyerhaeuser Way S without mounting the
curb. As depicted, it appears the rear tire path may go over the center island curbing. Please note,
the roundabout center island curbing is not mountable.
Eric LaBrie
August 2, 2023
2200534.30
Page 8 of 9
7. The Auto Turn exhibit depicted a 40’ wide driveway with unspecify driveway radius. A street
modification will need to be submitted and approved by the PW director to utilize radius driveway
and any driveways width exceeding the maximum 30’. The AutoTurn exhibit with a 40’ wide
driveway and unspecify radius appears to show the truck rear tire path touching the driveway curb
for both maneuver in/out of the driveway. Please confirm. Furthermore, the AutoTurn exhibit did not
show the right turn out of any of the driveways.
8. Street lighting as shown on Sheet ST-01 and ST-02 is conceptual for UP and will need to be
designed and review as part of EN permit. However, the street lighting plan should be incorporated
with frontage improvement plan.
9. Southbound right turn lanes at the 2nd and 4th driveway on Weyerhaeuser Way would need to be
designed to meet all applicable standards. Additional row dedication would be needed for the turn
lane and must be depicted on the plan.
TIA Review Comments
1. Submit a full TIA with PE stamp along with TENW responses to technical review
comments. Without a full TIA, staff cannot review and verify.
2. Revise TIA to distinguish between intersections under WSDOT control and Federal
Way and the applicable LOS standard for each agency. Update the City of Federal
Way LOS standard to the correct LOS standard as identified in the Comprehensive
Plan.
SEPA Checklist – Transportation
1. Transportation 14(c) – Update this section to include right-of-way dedication along the
north property for future S 324th Street extension and frontage improvement on S 336th
St. Furthermore, the mitigation should be verified for consistency with the TIA.
2. Transportation 14(g) – Revise this section to include full pavement reconstruction
along truck route as identified in the TIA.
Pavement Analysis Report
1. Use one pavement design (Section E) for the whole truck travel route on
Weyerhaeuser Way S including the roundabouts. Section E pavement design is
adequate for UP review and approval. The final design will be reviewed and approved
in EN stage. The pavement design for the Weyerhaeuser Way South shall be in
accordance with procedure in the AASHTO Guide for Design of Pavement Structures
(1993). Once the pavement design is approved by the City, the developer shall
perform full depth pavement reconstruction on Weyerhaeuser Way South from curb to
curb.
Eric LaBrie
August 2, 2023
2200534.30
Page 9 of 9
Closing
Please be aware that this review does not preclude the City from requesting additional information related
to any of the topics discussed above. Please submit be electronic submittal (Document Upload Link or
https://www.cityoffederalway.com/node/4588) revised application materials as appropriate, a letter
explaining how these comments have been addressed, and the completed “Resubmittal Information
Form” (enclosed).
Please note the original application fees collected at submittal cover the initial review and one resubmittal
only. A resubmittal fee will be charged for each review following the first resubmittal.
Pursuant to FWRC 19.15.050, if an applicant fails to provide additional information within 180 days of
being notified that such information is requested, the application shall be deemed null and void and the
City shall have no duty to process, review, or issue any decisions with respect to such an application.
If you have any questions regarding this letter, please contact either Stacey Welsh or me (see contact
information provided above).
Sincerely,
Lisa Klein, AICP
Contract Planner for City of Federal Way
LK/lsk
Encl: Technical Review Letter from ESA dated June 9, 2023
Resubmittal Information Form
c: Keith Niven, Community Development Director
Stacey Welsh, Principal Planner, stacey.welsh@cityoffederalway.com
Cole Elliot, Development Services Manager, cole.elliott@cityoffederalway.com
Sarady Long, Senior Transportation Planning Engineer, sarady.long@cityoffederalway.com
Brian Asbury, Lakehaven Water and Sewer District, basbury@lakehaven.org
Scott Gerard, South King Fire and Rescue, scott.gerard@southkingfire.org
Coby Holley, cholley@irga.com
Q:\2020\2200534\30_PLN\Working_Files\Process IV\20230802 5th Ltr (Woodbridge Bus Pk-Tech Rev) clean 2200534.30.docx
5309 Shilshole Avenue, NW
Suite 200
Seattle, WA 98107
206.789.9658 phone
206.789.9684 fax
www.esassoc.com
memorandum
date June 9, 2023
to Stacey Welsh, City of Federal Way Department of Community Development
from Jessica Redman, PWS
subject Critical Areas Addendum and Supporting Documents Review: Woodbridge Business Park
At the request of the City of Federal Way (City), Environmental Science Associates (ESA) reviewed several
documents for the property at approximately 32901 Weyerhaeuser Way South in Federal Way, Washington. The
136-acre site is a combination of five parcels (King County Tax Parcel Numbers 1621049056, 1621049013,
1621049030, 1621049036, and 2285000010) currently owned by Federal Way Campus, LLC.
This property was originally reviewed by ESA between May and August of 2017 as part of the Tech Center
Boundary Line Adjustment project. Several site visits were conducted to evaluate wetland boundaries. Results
were reported to the City in the Existing Conditions Report – Tech Center Boundary Line Adjustment technical
memo (dated August 22, 2017) and the Review of the Letter titled “Response to Comments dated 22 August
2017” Existing Conditions Report – Tech Center Boundary Line Adjustment (letter dated August 22, 2017)
technical memo (dated October 16, 2017). Previous versions of the critical areas report and conceptual mitigation
plan (dated October 27, 2018 and April 9, 2020) were also reviewed by ESA. ESA’s most recent review of the
project includes a review of the Addendum to 9 April 2020 Critical Areas Report and Proposed Mitigation Plan
(prepared by Wet.land, LLC and dated October 10, 2021) and the Woodbridge Business Park Project In-Lieu Fee
Plan (prepared by Wet.land and dated October 10, 2021), in which the applicant proposed that all direct and
indirect wetland impacts be mitigated through the purchase of in-lieu fee credits. Findings of the most recent
review of the critical areas report (dated October 10, 2021) and the in-lieu fee plan (October 10, 2021) were
presented to the City in the Critical Areas Addendum and Supporting Documents Review: Woodbridge Business
Park technical memorandum (dated July 20, 2022). In response to ESA’s comments and recommendations in the
July 20, 2022 technical memo, the applicant has submitted the following documents that are included in this
review:
• The technical memo titled Revised Critical Areas Report Addendum (prepared by Wet.land, LLC and
dated February 9, 2023).
• The technical memo titled Response to City Comments (16 August 2022) (prepared by Wet.land, LLC and
dated February 9, 2023).
• The technical memo titled City Project Nos. - 17-105489-UP, 17-105490-SE & 21-104771-SH AHBL No.
2200534.30 Woodbridge Business Park - 327XX Weyerhaeuser Way South, Federal Way TECHNICAL
Critical Areas Addendum and Supporting Documents Review: Woodbridge Business Park
2
REVIEW COMMENTS – Response Letter (prepared by ESM Consulting Engineers and dated February
10, 2023).
• Woodbridge Business Park Plan Set (prepared by ESM Consulting Engineers and dated February 3,
2023).
• Shoreline Jurisdiction Detail from Woodbridge Business Park Plan Set.
The current application involves the construction of three new buildings that will provide approximately 961,390
square feet (SF) of new warehouse and office space. The Tech Center building will remain, and the existing
parking lot will be reconfigured to maximize space. Associated infrastructure to be constructed includes new
stormwater detention facilities, parking for cars and trucks, and maneuvering space for the anticipated truck
traffic around these buildings.
Site Background and Purpose of Review
In 1994, the Weyerhaeuser Company entered into a pre-annexation zoning agreement with the City, known as the
Concomitant Agreement, to ensure that once annexed, the Weyerhaeuser Company Campus was developed “with
maximum flexibility which will ensure optimal development, while preserving the unique natural features of the
site” (Weyerhaeuser Company Concomitant Pre- Annexation Zoning Agreement, 1994). The purpose of this
review is to determine if the proposed project is in compliance with Concomitant Agreement, Chapter 19.145
(Critical Areas) of the Federal Way Revised Code (FWRC), and Chapter 15.10 (Critical Areas in Shoreline
Management Areas) of the FWRC.
Review of Documents
ESA reviewed the documents listed above. Generally, the project has only slightly changed since ESA reviewed
the project in 2022. However, the Project Site has changed over time based on City-approved boundary line
adjustments. According to the documents, 24 wetlands and one stream (Stream AC) occur within or adjacent to
the revised site of the Business Park project (the Project). The site is also adjacent to North Lake, a shoreline of
the state. Based on the new site plan, the project will result in 8,585 SF of direct wetland impact a slight decrease
from the previous value of 8,612 SF. Seven wetlands will continue to be insufficiently buffered, and therefore are
being considered indirectly impacted due to site development encroachments, resulting in an additional 6,353 SF
of indirect wetland impact, a decrease of 1,487 SF from the previous design. The applicant proposes to purchase
20.96 credits from the ILF program to compensate for all direct and indirect impacts.
In addition to the direct and indirect wetland impacts, the project will permanently impact 36,721 F of wetland
and stream buffer through reducing the buffers for buffer averaging to construct road improvements, as well as
constructing an access road to two stormwater ponds. An additional 27,114 SF of wetland buffer will be
temporarily disturbed during the restoration of an existing trail as well as during the removal of a culvert from
Stream EA and associated buffer enhancement. To mitigate for the permanent and temporary buffer impacts, the
applicant proposes 61,354 SF of wetland buffer replacement using buffer averaging, 4,754 SF of wetland buffer
re-establishment, and 27,649 SF of wetland and stream restoration. In summary, a total of 93,757 SF of buffer
mitigation are proposed for the 63,835 SF of permanent and temporary buffer impacts.
Additionally, according to the Revised Critical Areas Report Addendum (hereinafter referred to as the Revised
Addendum), a stretch of the ordinary high water mark (OHWM) of North Lake adjacent to the project was
delineated in November 2022 at the request of the City. The new delineation was surveyed and incorporated into
the figures in the Revised Addendum. The updated survey of the OHWM shows that all proposed construction
Critical Areas Addendum and Supporting Documents Review: Woodbridge Business Park
3
falls outside of the 200-foot Shoreline Management Zone (SMZ); therefore, a shoreline permit is no longer
required.
Review Comments and Recommendations
Based on the document review for consistency with the City of Federal Way requirements and regulations, we have
the following comments and recommendations:
1. As stated in our July 20, 2022 review memo, the City continues to recommend that the standard buffer be
used to calculate the indirect impacts for Wetlands DE, GB-North, and any other wetland where a portion
of the wetland is being used as buffer, therefore resulting in indirect impacts. Using a reduced or averaged
buffer to calculate these impacts is not allowed under the FWRC. ESA recommends that indirect impacts
be recalculated using the standard buffer widths.
2. According to the Revised Addendum, the buffers for Wetlands AG, AV, DE, and GB(N) exceed the 25%
buffer reduction allowed per FWRC 19.145.440(6). Because this does not meet code requirements, this
should not be part of the proposal.
3. According to the Response to City Comments (16 August 2022), the applicant is not proposing pure buffer
reduction with enhancement; and therefore, the proposed reduced buffers do not need to meet the criteria
in FWRC 19.145.440(6) as suggested in ESA’s July 20, 2022 memo. However, due to the large amount of
buffer reduction being proposed, ESA continues to recommend that the critical areas report be revised to
include a discussion on how the proposed buffer reductions meet these requirements, to ensure a no net
loss of ecological function.
4. The proposed construction of a new access road to the stormwater ponds is not an approved development
within a buffer per FWRC 19.145.440. Because the existing road to the south is a permanent alteration to
the buffer, as defined in FWRC 19.145.440(4), this area should be used to access the proposed
stormwater pond, as it will result in less impacts to the existing buffer. Because this does not meet code
requirements, ESA recommends this not be part of the proposal.
5. The proposal for Wetland DE, shown on Sheet W1.8 does not meet the buffer averaging requirements
under FWRC 19.145.440(5)(b), which states “the buffer is increased adjacent to the higher functioning
area of habitat or more sensitive portion of the wetland and decreased adjacent to the lower functioning or
less sensitive portion.” Most of the area of buffer “give-back” is not specific to Wetland DE. In
particular, the southern portion of the “give-back” area is adding buffer to Wetlands DF, DG, and DI,
which would not provide additional buffer function to Wetland DE. The buffer impacts are concentrated
to the northern extent of Wetland DE and increased buffer to the south and west would not compensate
for the decreased buffer, or buffer impacts, to the north. Additionally, the buffer along the east side of
Wetland DE, merges with other critical areas (i.e., other wetlands and their buffers) for an estimated
buffer (protected area) of approximately 150 feet or greater. The existing buffer is already greater than
that required by FWRC and therefore, more than sufficient to protect the functions of the Category III
wetland. Additional buffer in this area would provide little to no additional buffer function. ESA
recommends the critical areas report and associated figures be revised to ensure that the buffer averaging
requirements under FWRC 19.145.440(5)(b) are met.
6. It is unclear where the buffer replacement areas are located for Wetland BR and AG. Sheet W1.9 states
that the buffer of Wetland BR will be reduced by 284 SF and replaced with 704 SF of new buffer. However,
in Viewport 6 of this plan sheet, the buffer replacement area appears to be much larger than 704 SF.
Critical Areas Addendum and Supporting Documents Review: Woodbridge Business Park
4
Additionally, Viewport 7 states that 3,432 SF of the buffer of Wetland AG will be reduced and replaced by
20,427 SF of new buffer. Buffer replacement is proposed in three separate areas including the buffer
replacement area shown for Wetland BR in Viewport 6. ESA recommends the critical areas report and
associated figures be revised to ensure that the buffer averaging requirements under FWRC
19.145.440(5)(b) are met.
7. According to the Revised Addendum, temporary buffer impacts to several wetland buffers will occur
through the restoration of an existing trail to functioning buffer. As recommended in our July 20, 2022
review memo, ESA continues to recommend that a description of the proposed restoration be included in
the critical areas report. Similar to grading, this work may be considered to be development by the City and
would need to meet the criteria under FWRC 19.145.440. The same is recommended for the restoration of
the unpaved access road to functioning buffer proposed in the buffer of Wetland AV.
8. ESA recommends that the critical areas report be revised to show how the proposed buffer averaging for
Wetlands BR and FB meet the criteria in FWRC 19.145.440.5.
9. Based on the Shoreline Jurisdiction Detail submitted with the application documents, ESA agrees that all
proposed developments are outside of the SMZ; and therefore, the project no longer requires a Shoreline
Permit.
10. ESA agrees that the proposed stormwater reconfiguration and outfall structure proposed in the buffer of
Stream AC meet the requirements of FWRC 19.145.330. ESA also agrees that the proposed mitigation
involving the removal of a culvert and habitat improvements will result in an overall lift of ecological
function. ESA recommends that any required permits from the U.S. Army Corps of Engineer and/or the
Washington Department of Fish and Wildlife be obtained before any in-water work commences.
11. According to the project’s King County In-Lieu Fee (ILF) Plan (Attachment 4 to the Revised Addendum),
a total of 20.96 credits will be purchased to mitigate for all direct and indirect wetland impacts. However,
all debits were calculated as if they were direct wetland impacts. According to Washington State
Department of Ecology guidance, an adjusted ratio (starting at 0.5:1) should be applied when calculating
debits for indirect impacts. ESA recommends the debits for direct and indirect wetland impacts be
calculated separately and the ILF Plan be revised to reflect the correct number of debits. If the total area of
direct and/or indirect impacts changes due to any of the recommended revisions above, the revised ILF
Plan should also reflect those changes.
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RESUBMITTAL INFORMATION
This completed form MUST accompany all resubmittals.
Additional or revised plans or documents for an active project will not be accepted
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https://www.cityoffederalway.com/node/4588)
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