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17-105489-Response to Technical Review Comments-12-21-2023 December 21, 2023 Job No. 1886-001-016-0016 Ms. Lisa Klein, AICP Contract Planner, City of Federal Way City of Federal Way 33325 8th Avenue S Federal Way, WA 98003-6325 RE: File Nos. 17-105489-UP & 17-105490-SE, and 21-104771-SH AHBL No. 2200534.30 Woodbridge Business Park - 327XX Weyerhaeuser Way South, Federal Way 5th TECHNICAL REVIEW COMMENTS – Response Letter Dear Ms. Klein: This letter is written on behalf of Federal Way Campus, LLC to provide detailed responses to comments received from AHBL dated August 2, 2023 and Critical Areas Addendum comments from ESA dated June 9, 2023. The following documents have been included in this resubmittal along with this letter:  Revised SEPA checklist, 12/21/2023  Critical Area Responses to Comments, 12/01/2023  Critical Area Report Addendum, 12/01/2023  Critical Area ILF Plan, 12/01/2023  Critical Area Mitigation Plans, 12/01/2023  Traffic Impact Analysis Update, 10/13/2023  Revised Parking Exhibit, 11/29/2023  Revised Preliminary TIR, 12/07/2023  Revised Process IV Plan Set, 12/14/2023  SEPA Memo, 12/18/2023  Visual Study Letter, 12/07/2023  Visual Study Report, 12/07/2023 In an effort to provide concise and direct responses, we have copied the review comments below in italics and added our responses in bold. Comments from AHBL letter dated August 2, 2023 – Lisa Klein and Stacey Welsh 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. Consistent information has been communicated throughout the plan set and associated application materials. Ms. Lisa Klein December 21, 2023 Page 2 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. Please see response below for more detail on how the project meets the code-required minimum parking. 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). Additional parking stalls have been identified in the vicinity of the existing WTC Building. As a result, the total parking supply now totals 1,975 parking spaces which exceeds the code-required minimum parking of 1,897 spaces, assuming 10 percent office space for each building (per Table 1 of the 8/2/2023 comment letter). An exhibit showing the allocation of the parking spaces between the existing WTC building and Buildings 1, 2, and 3 is included in this resubmittal. 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. The existing internal parcel lines will need to be revised after land use approval so that parcel lines do not bisect future buildings. A condition of approval can be placed on the project to require that code-required minimum parking spaces be provided on each individual lot, or a shared parking agreement can be recorded prior to issuance of building permits. 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 Ms. Lisa Klein December 21, 2023 Page 3 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 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. The plans have been revised to respect the existing loading doors at the rear and sides of the WTC building. All temporary structures will be removed during construction, and all permanent structures necessary for building operations have been respected in the revised parking layout. 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. The project now exceeds the minimum parking required. A condition of approval can be placed on the project to require that code-required minimum parking spaces be provided on each individual lot, or a shared parking agreement can be recorded prior to issuance of building permits. Ms. Lisa Klein December 21, 2023 Page 4 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 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. See revised Visual Study Letter and Report that includes final renderings similar to the View Impact Study dated March 2018. The visual study report shows the assessment process in creating the final rendering. The LiDAR tree mapping and 3D model grades inform the Solid Tree modeling imagery. Studying the building heights and the grade location helped determine if additional vegetation may be required. Any additional vegetation required to obstruct views of the building are modeled with trees with 10-15 year maturity. Final renderings demonstrate that the perspective views of the proposed Business Park from adjacent properties is obstructed due to existing and proposed vegetation. The red, dashed lines show the extents of the proposed buildings for reference. 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. Ms. Lisa Klein December 21, 2023 Page 5 This comment has been noted. 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. Low-grow, erosion control hydroseed has been provided in these areas. 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. A 5' width Type I supplemental landscape area has been added along the western parking lot perimeter at the rear of the existing WTC building. All supplemental trees and vegetation within the wetland buffer will be native mesic species. 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. All trees along the western parking lot perimeter are specified to be 10' minimum height at time of installation. Revise the Preliminary Plant Palette to indicate a range of tree heights at planting of between 6’ and 10’. The Preliminary Plant Palette has been revised to indicate a range of tree heights between 6' and 10' at the time of installation. A footnote has been added that calls out the 10' installation height for trees along the western parking lot perimeter. Ms. Lisa Klein December 21, 2023 Page 6 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. The Preliminary Plant Palette footnote for the supplemental Type I landscape area also states that the City of Federal Way may require, as a condition of approval, that the area west of the WTC building be assessed post-construction and additional supplemental plantings conditioned if needed. 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. Landscaping has been added to the blank area and this comment has been corrected. 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. The note has been corrected so that all trees in this area are 10’-tall 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. A letter requesting withdrawal of this application and a refund of any remaining fees was sent to Stacey Welsch on November 29, 2023 and a copy was uploaded to the City’s permitting website. Wetlands and Streams 10. Review and address each comment in the enclosed June 9, 2023, review letter from the City’s wetland consultant, ESA. Our wetland consultant (Wet.Land) has provided a separate response letter, dated December 1, 2023, wherein she addresses each comment from ESA in detail. A copy of this letter is included in this resubmittal. Ms. Lisa Klein December 21, 2023 Page 7 SEPA Checklist 11. On your next resubmittal, use the new State SEPA checklist dated January 2023. The updated SEPA Checklist has been used. 12. Add the revision date for the Preliminary Technical Information Report to response to A.8. The most recent revision date for the Preliminary TIR has been added. 13. Remove Shoreline Management Substantial Development Permit from response to A.10. The SSDP has been removed. 14. Add City Critical Areas Review to response A.10. City Critical Areas Review has been added. 15. Revise Section 13(c), to include the technical reports and studies completed to assess the historic and cultural resources affecting the site. The pertinent reports and studies already listed under section A.8. have been reiterated in this section. 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. The answer has been revised to be consistent with sheet CV-01 and the mitigation plans. 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 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. The on-site impervious area has been revised to be 60 acres of new, replaced, and existing areas as described on the updated plan set cover sheet. This area has been verified to match on the plans and in the storm report. Ms. Lisa Klein December 21, 2023 Page 8 The Preliminary Technical Information Report dated February 8, 2023 notes the developed drainage area is 71.48 acres, which includes both pervious and impervious areas. As shown in Table 4.1 on page 27 of the report PDF, the impervious area for the onsite drainage basins is 59.99 acres, which rounds to 60 acres. The preliminary stormwater report also goes on to discuss additional impervious areas for frontage improvements (sidewalk and pavement addition) as well as pavement reconstruction, however, those areas are outside of the proposed developed parcel. Furthermore, the SEPA requires only an approximate representation of the estimated impervious area on the project site, which may change marginally with final design plans and storm calculations. Cole Elliot – Public Works Development Services 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. Administrative Decision #23-104424-000-00 was approved on October 31, 2023, which allows trucks to travel to/from the site on Weyerhaeuser Way S. Sarady Long – Public Works Traffic Division 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. Full frontage improvements and the necessary dedication has been included on the revised plan set. ADA compliant pedestrian facilities are provided at the roundabout on Weyerhaeuser Way S and S 336th Street. 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. The plans have been revised to show proposed Section E for the pavement design on the remaining truck travel route on Weyerhaeuser Way S (S 320th St to truck entrance to Woodbridge Buildings A and B). 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. Ms. Lisa Klein December 21, 2023 Page 9 As documented in the Updated TIA, trucks are not anticipated to utilize S 336th Street from Weyerhaeuser Way S to SR 99. 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. As documented in the updated TIA, minimal queuing is anticipated from the northerly driveway on Weyerhaeuser Way S and is not anticipated to impact the future roundabout. The exact location and final design of the northern site access driveway is expected to be reviewed and determined as the design of the future City roundabout progresses. 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’. A Road Modification request to modify driveways was submitted, reviewed, and subsequently approved on May 9, 2023. See City Folder #23-100781-SM. 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. The updated TIA includes the turning path of a WB-67 truck at the S 336th Street and S 33rd Place roundabouts on Weyerhaeuser Way which shows that the turn paths can be accommodated at both. As shown, the roundabouts on Weyerhaeuser Way S can accommodate the WB-67 vehicle movements without conflicts. 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. An Administrative Decision was previously submitted and approved to utilize driveway width of 40-ft (City Folder #23-100781-SM). Please see the updated autoturn exhibits dated 9-11-2023 which show curb radii at the driveways. Additionally, updated autoturn exhibits show right turns out of all driveways with no truck paths overlapping proposed curb. 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. Street lighting has been added to sheets ST-01, ST-02, and the frontage improvement plan, sheet FR-01. Ms. Lisa Klein December 21, 2023 Page 10 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. Please see the updated TIA and plans for further detail regarding turn lane warrants and dedication. 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. A full TIA including PE stamp is included in this submittal along with this response memo. 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. The Updated TIA now separates the intersections under City of Federal Way jurisdiction from the intersections under WSDOT jurisdiction and describes the separate LOS standards for each. 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 336 th St. Furthermore, the mitigation should be verified for consistency with the TIA. The SEPA checklist has been updated to include this information. 2. Transportation 14(g) – Revise this section to include full pavement reconstruction along truck route as identified in the TIA. The SEPA checklist has been updated to include this information. 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. Sheet FR-01 has been updated to show only Section E for the whole truck travel route, including the roundabouts. Ms. Lisa Klein December 21, 2023 Page 11 ESA – Critical Areas Addendum and Supporting Documents Review Review 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. Impact calculations have been revised to the approach above with buffer averaging for indirect buffer impacts removed. The In Lieu Fee (ILF) Plan has been adjusted accordingly. See CAR addendum, revised Mitigation Plan, and revised ILF Plan for an updated assessment of critical area impacts. 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. Buffer impacts have been modified. See CAR addendum, revised Mitigation Plan, and revised ILF Plan for an updated assessment of critical area impacts. 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. See the CAR addendum for a revised discussion on buffer impacts and mitigation. 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. Noted. A utility corridor must still cross through the buffer at the location of the previous access road. The stormwater access road was shifted to collocate with the existing trail. However, note that the trail width and substrate does not meet the requirements for a maintenance access road and thus will be modified accordingly to meet the necessary standards. See the CAR addendum for a revised discussion of the utility corridor and access road. 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 Ms. Lisa Klein December 21, 2023 Page 12 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. See the CAR addendum for a revised discussion on buffer impacts and mitigation. 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. 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. Graphics were revised to more clearly reflect the critical area impacts, including buffer modifications. See the CAR addendum for a revised discussion on buffer impacts and mitigation. 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. More details of the trail restoration were previously provided in Chapter 4.1.3 of the CAR Addendum. The intent is to remove the compacted gravel base and restore these areas with soil and plantings consistent with other restoration actions proposed onsite. Note that the existing trail to be restored is the same trail, simply at multiple locations. FWRC 19.145.440 does not clearly describe this circumstance where an existing trail would be removed from within a buffer without an associated buffer modification. This action is part of the onsite mitigation. 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. Ms. Lisa Klein December 21, 2023 Page 13 Noted. See the CAR addendum for a revised discussion on buffer impacts and mitigation. 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. Noted. 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. Noted. Required permits will be acquired prior to any in-water work. 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. The In Lieu Fee (ILF) Plan has been revised to reflect the new site plan and critical area impacts. If there are any questions or a need for further clarification, please feel free to contact me at (253) 838-6113 and I would be happy to discuss them with you. Sincerely, ESM CONSULTING ENGINEERS, LLC ERIC G. LaBRIE, A.I.C.P. President \\esm8\engr\esm-jobs\1886\001\016-0016\document\letter-028.docx