17-105489-SEPA Memo-12-21-2023
719 2ND AVENUE, SUITE 200 | SEATTLE, WA 98104 | P 206.394.3700
TECHNICAL MEMORANDUM
DATE: December 18, 2023
TO: Coby Holley, Vice President, Asset Development Manager
Federal Way BP, LLC
11111 Santa Monica Boulevard, Suite 800, Los Angeles, CA 90025
FROM: January M. Tavel, Senior Cultural Resources Specialist, Parametrix
SUBJECT: Federal Way Woodbridge Business Park Project, Federal Way, Washington, SEPA
Compliance – Historic Resources
CC: Courtney Kaylor, Partner, McCullough Hill PLLC; Jennifer Ferris, Senior Cultural Resources
Specialist, HDR
Introduction and Purpose
Federal Way BP, LLC, proposes redevelopment of the Weyerhaeuser Technology Center property (WTC) at the
former Weyerhaeuser International Corporate Headquarters campus located in Federal Way, Washington 98001
(County Parcels 162104-9013, -9056 and -9030). The proposal is known as Federal Way Woodbridge Business
Park Project (the Project). Process IV site plan approval and associated review under the Washington State
Environmental Policy Act (SEPA) by the City of Federal Way is required. The Project may also require a United
States Army Corps of Engineers (USACE) nationwide permit under Section 404 of the Clean Water Act. As part of
the federal review process, USACE is required to comply with Section 106 of the National Historic Preservation Act
(NHPA) (16 United States Code [USC] 470) and its implementing regulations (36 Code of Federal Regulations [CFR]
Part 800). The purpose of this memorandum is to provide technical recommendations regarding the significance
of impacts to historic resources under SEPA resulting from the Project. The SEPA recommendations herein are
informed by studies conducted for Section 106 compliance. Note that the definitions of terms in Section 106 of
the NHPA and SEPA regulations are different. The SEPA regulations include “historic and cultural preservation” as
an element of the environment. The definition of an “environmental impact” is an effect on the elements of the
environment. “Significant” means more than a reasonable likelihood of more than a moderate adverse impact on
environmental quality. The proposal description, SEPA conclusion, description of historic resources, and
discussion of resources are provided below.
Proposal Description
The Project would retain the existing WTC building but would require demolition of existing features and
construction of new buildings, amenities, and associated sitework. The Project includes demolition of existing
parking lots, clearing, grading, and construction of three new commercial buildings with parking lots, access
roads, utility services, and stormwater facilities on approximately 97.67 acres, as well as associated frontage
improvements along Weyerhaeuser Way S. The project may also include construction of additional parking east of
the WTC building. If implemented construction would require some tree removal, but the approximately 50-foot
wooded buffer adjacent to the west side of Weyerhaeuser Way S would be retained. While the existing WTC
building would remain, the parking lot associated with the WTC would be reconfigured to allow for construction
of the three new buildings. As currently designed, Building 1 would be 605,195 square feet, Building 2 would be
240,675 square feet, and Building 3 would be 125,520 square feet. Building 1 would be located directly north of
the WTC, and Buildings 2 and 3 would be located directly south of the WTC. Maximum height of the buildings
would be no more than 42 feet.
TECHNICAL MEMORANDUM (CONTINUED)
Federal Way Woodbridge Business Park Project: Historic Resources
Effects Assessment, Federal Way, Washington
2 December 18, 2023
SEPA Conclusion
Given the limited area in which the Project is located and the combination of all Project activities, including
planned avoidance and minimization of impacts, the Project will not result in significant adverse impacts on
historic resources under SEPA. Avoidance and minimization measures include, but are not limited to, retention of
the WTC building, avoidance of the headquarters meadow, provision of the approximately 50-foot treed buffer
along Weyerhaeuser Way S, and retention of treed buffers between the Project and the meadow to the south
and between the Project and I-5. In addition, proposed mitigation includes rehabilitation of the WTC roof
gardens.
Description of Historic Resources
For a separate project, Cardno prepared a Built Environment Survey of the Former Weyerhaeuser Corporate
Headquarters Campus, Federal Way, Washington report in July 2020 (Built Environment Survey Report) (Sadlier et
al. 2020) to satisfy regulatory requirements for obtaining a USACE Section 404 permit. As part of that federal
review process, the USACE was required to comply with Section 106 of the NHPA )16 U.S. Code 470) and its
implementing regulations (36 CFR Part 800). The Built Environment Survey Report evaluated the Weyerhaeuser
Corporate Headquarters eligibility for listing in the National Register of Historic Places as an historic district 1,
identified the historic district boundary, identified contributing and non-contributing components of the historic
district 2, and evaluated four buildings on the campus for individual NRHP eligibility. The USACE submitted its
determination of eligibility based on these recommendations. In October 2020, the State Historic Preservation
Officer (SHPO) concurred with USACE’s determination (USACE 2020; DAHP 2020). Properties determined to be
eligible for listing in the National Register of Historic Places (NRHP-eligible) include the following (Sadlier et al.
2020).
• One historic district:
The Weyerhaeuser Corporate Headquarters Historic District (determined NRHP-eligible)
• Four individually eligible properties:
Weyerhaeuser Company Corporate Headquarters Building (determined NRHP-eligible)
Project House 1 (determined NRHP-eligible)
Project House 2 (determined NRHP-eligible)
King County Fire District 22 Fire Station (determined NRHP-eligible)
These properties are not listed in any historic property register at the local, state, or federal level. The WTC
Building, originally constructed to provide administration, research, and industrial loading dock facilities, was
determined to be a contributing component of the Weyerhaeuser Corporate Headquarters Historic District.
1 The National Park Service (NPS) defines an historic district as an historic property that “possesses a significant
concentration, linkage, or continuity of sites, buildings, structures, or objects united historically or aesthetically by plan or
physical development” and “a district derives its importance from being a unified entity, even though it is often composed
of a wide variety of resources” (NPS 1995).
2 Contributing components to an historic district are those sites, buildings, structures, or objects that support the district’s
ability to express its historic significance. These components can lack individual distinction, but together convey a visual
sense of the overall historic environment or be an arrangement of historically or functionally related properties. In addition,
“an historic district can contain buildings, structures, sites, objects, or open spaces that do not contribute to the significance
of the district” and “the number of noncontributing properties a district can contain yet still convey its sense of time and
place and historical development depends on how these properties affect the district’s integrity” (NPS 1995).
TECHNICAL MEMORANDUM (CONTINUED)
Federal Way Woodbridge Business Park Project: Historic Resources
Effects Assessment, Federal Way, Washington
3 December 18, 2023
However, modifications to the WTC building, completed in 1978, diminish its design and material significance
when evaluating under Criteria Consideration G for resources that have achieved significance within the past 50
years and was not considered individually eligible for listing in the NRHP (Sadlier et al. 2020: 6-30).
For the current Project, ICF and Parametrix have prepared a Draft Federal Way Woodbridge Business Park Project:
Historic Resources Effects Assessment, Federal Way, Washington, January 2023 (Historic Resource Effects
Assessment) (ICF and Parametrix 2023). This Historic Resource Effects Assessment was prepared under Section
106 of the National Historic Preservation Act (NHPA) for submission to the USACE in connection with its
permitting activity under Section 404 of the Clean Water Act for the Federal Way Woodbridge Business Park
Project (Project). The Historic Resource Effects Assessment describes the previously identified historic properties,
provides additional research and analysis to characterize these previously identified properties as needed, and
characterizes project effects on historic properties in the proposed area of potential effects (APE). The Historic
Resources Effects Assessment provides the justification for the proposed APE, identification of the USACE permit
area (which is the same as the proposal site), and describes the methods and approach used for field survey and
analysis, the historic context, research and field survey findings, an effects analysis that considers physical and
visual effects, and technical recommendations.
Based on the findings of both the Built Environment Survey Report and supplemental research in the Historic
Resource Effects Assessment, the following features adjacent to the WTC building are considered non-
contributing to the historic district: WTC service yard; open spaces adjacent to the WTC which were not part of
the original design; tree stands outside of contributing managed woods, model forest, and campus-wide wooded
buffers; WTC detention pond; WTC Service Road 1; WTC Service Road 2 and Extension; WTC Service Road 3; WTC
Detention Service Road; Amenity Trails and Desire Paths (WTC vicinity); and Volleyball court (Sadlier et al. 2020;
ICF and Parametrix 2023: 4-21). Contributing components of the historic district located in the project site
include: the WTC building, WTC parking lots and circulation drives, WTC landscaping, portions of the campus-wide
wooded buffer, the northern portion of the Weyerhaeuser Way S roadway, and the headquarters meadow
(Sadlier et al. 2020; ICF and Parametrix 2023: 4-5, 4-10).
While neither the Built Environment Survey Report or the Historic Resource Effects Assessment were prepared for
the purpose of compliance with SEPA and do not evaluate the significance of impacts under SEPA, their findings
support the discussion of SEPA impacts that follows.
Discussion of Impacts
Project activities would not physically impact the individually eligible properties – Weyerhaeuser Company
Corporate Headquarters Building, Project House 1, Project House 2, or King County Fire District 22 Fire Station
(ICF and Parametrix 2023: 4-31 to 4-32). As described in greater detail in the Section 106 Historic Resource Effects
Assessment, some contributing components of the Weyerhaeuser Corporate Headquarters Historic District would
be altered by the Project.
• WTC parking lots and circulation drives, and WTC landscaping would be demolished in their entirety to
accommodate construction of Buildings 1, 2, and 3. In addition to removal of two contributing
components of the historic district, this would also change the immediate setting of the adjacent retained
historic district contributing component – the WTC building.
• Four small sections of the wooded buffer along the Weyerhaeuser Way S. circulation road would be
removed for the construction of four entrances to new access roads. While the Project would not alter
the location or alignment of Weyerhaeuser Way S, the roadway would be physically impacted at four
points on the west side of its alignment through the construction of new entranceways to the access
roads of the three new commercial buildings.
TECHNICAL MEMORANDUM (CONTINUED)
Federal Way Woodbridge Business Park Project: Historic Resources
Effects Assessment, Federal Way, Washington
4 December 18, 2023
• Given there are only two current entrances to the WTC building from Weyerhaeuser Way S, the
experience of the wooded buffer while traveling on circulation roads would be altered along the northern
portion of Weyerhaeuser Way S by the introduction of the four entrances for access roads to the WTC,
and Buildings 1, 2, and 3 on the west side of Weyerhaeuser Way S.
While the Project may also include the construction of additional parking east of the WTC building, if
implemented, construction of the additional parking would require removal of trees in a wooded area that is non-
contributing to the historic district. In addition, temporary impacts from vibration, noise, fugitive dust, and traffic
from construction or operation of the Project are not expected to alter the WTC building, portions of the wooded
buffer, Weyerhaeuser Way S, or the headquarters meadow.
No views from the WTC were identified as contributing components of the historic district (Sadlier et al. 2020).
Views identified as contributing components to the historic district include views north from the headquarters
building, views south from the headquarters building, and views of the headquarters building. None of these
views would be significantly impacted by the Project.
• The proposed Project activities, located to the north–northeast of the headquarters building, would not
significantly impact the views north from the headquarters building due to distance and the intervening
managed woods area to the immediate northeast of the headquarters building and retained portions
wooded buffer along the headquarters meadow to the north of the headquarters building. The retained
wooded buffer along the headquarters meadow would continue to screen visibility of the WTC building
and screen new construction (Buildings 1, 2, and 3). In addition, the four new entranceways proposed
along Weyerhaeuser Way S would not be visible from the headquarters building due to distance and the
intervening managed woods area to the immediate northeast.
• Views south from the headquarters building would not be altered as no proposed Project activities would
occur in that area.
• Views of the headquarters building would not be altered by the Project. Views of the headquarters
building from the north include those from vantage points along Interstate 5 across the headquarters
meadow, along the eastern portion of S 336th Street, and along the headquarters pond, all of which
would not be altered by the Project. Views of the headquarters building from the south would not be
altered, because no proposed Project activities would occur in that area and activities would not be
visible to the north beyond the headquarters building, its associated parking lots, hardscaping,
landscaping, and managed woods areas.
While some Project activities would represent changes to portions of setting, design, materials, workmanship,
feeling, and association of the historic district, measures to avoid or minimize impacts to contributing
components of the Weyerhaeuser Corporate Headquarters Historic District have been planned as part of the
Project, including:
• The WTC building would be retained as part of the Project and measures would be taken to protect the
building from damage during construction.
• An approximately 50-foot tree and vegetation buffer would be retained and managed between the
easternmost limit of construction and Weyerhaeuser Way S, except for driveway locations. The wooded
buffer along the headquarters meadow would not be altered; an approximately 50-foot tree and
vegetation buffer would be retained and between the western limit of construction and the headquarters
meadow. The proposed depth of these buffers matches the tree-buffer depth adjacent to specified city or
county roads as agreed upon between Weyerhaeuser Company and the City of Federal Way in a
concomitant agreement (Weyerhaeuser Company Concomitant Pre-Annexation Zoning Agreement 1994
[CZA]). The buffer would include multiple trees that are substantially taller than the heights of the
TECHNICAL MEMORANDUM (CONTINUED)
Federal Way Woodbridge Business Park Project: Historic Resources
Effects Assessment, Federal Way, Washington
5 December 18, 2023
proposed Project elements so that these elements would not project above the buffer and buffer
management would include understory vegetation and mid-level tree planting as directed by the Project
forester intended to mature and fill in the visual gaps between the mature trees. Where the buffer would
be maintained, once mature, it would effectively screen the proposed Project elements from
Weyerhaeuser Way S. and other historic district contributing components outside the Project site. In
addition, buffer enhancement along Weyerhaeuser Way S. and the headquarters meadow will include
planting of additional trees under the guidance of the forester. A Managed Forest Buffer is also
maintained between the Project and I-5 as provided in the CZA.
• The project would include landscape enhancements to support minimization of impacts to the historic
district setting adjacent to the WTC building. These include: expanses of lawn similar to fields adjacent to
the building; additional mixed overstory landscaping along the north and south borders to more densely
screen new parking area; protection of all existing healthy treats up to grading limit and addition of trees
within buffer as directed by the project forester to retain maximum vegetation density along
Weyerhaeuser Way frontage; and large stature deciduous tree species in larger planting areas on north,
east, and south building parking area entrances. Please see the attached landscape plan (MC-EN-43).
• The Project would avoid physical alteration to the majority of the historic district’s contributing
components. This includes the two components most important to conveying the district’s historic
significance – the headquarters building and headquarters meadow – as well as other contributing
components: the headquarters parking lots, ivy on the headquarters building, headquarters pond,
managed woods inside the headquarters circulation road, hardscaping and planting on the headquarters
grounds and parking lots, Guardian Rock, flagpole, street furniture around the headquarters building
grounds and parking lots, model forest, Rhododendron Species Botanical Garden, Project House 2, views
north and south from headquarters building, and views of the headquarters building. While project
planning originally included alternation of the headquarters meadow for installation of stormwater
management, the proposal reflects revised design to avoid the meadow.
In addition, proposed mitigation under this SEPA regulatory process includes rehabilitation of the WTC roof
gardens as a measure to compensate for changes to the Weyerhaeuser Corporate Headquarters Historic District.
This would include activities to reinstall and maintain soil and plant materials in roof gardens at both the north
and south entrances. Consistent with Secretary of the Interiors Standards for the Treatment of Historic
Properties, this rehabilitation will retain the historic design and include selection of plant material that is
compatible in color and texture with the grass originally planted in these locations, as substantiated by
documentary and physical evidence (NPS 2017). In addition, plant selection will consider current best practices
for roof plantings and environmental conditions present at the site to help ensure long-term success of the
rehabilitation effort.
REFERENCES
ICF and Parametrix. 2023. Draft Federal Way Woodbridge Business Park Project: Historic Resources Effects
Assessment, Federal Way, Washington. January 2023. ICF, Seattle, Washington, and Parametrix, Seattle,
Washington. Prepared for Federal Way Campus, LLC, Los Angeles, California.
National Park Service (NPS). 1995. National Register Bulletin 15: How to Apply the National Register Criteria for
Evaluation. Available: https://www.nps.gov/subjects/nationalregister/upload/NRB-15_web508.pdf.
Accessed: October 5, 2023.
National Park Service (NPS). 2017. The Secretary of the Interior’s Standards for the Treatment of Historic
Properties with Guidelines for Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings
TECHNICAL MEMORANDUM (CONTINUED)
Federal Way Woodbridge Business Park Project: Historic Resources
Effects Assessment, Federal Way, Washington
6 December 18, 2023
(Revised). Available: https://www.nps.gov/orgs/1739/upload/treatment-guidelines-2017-part1-preservation-
rehabilitation.pdf. Accessed: November 17, 2023.
Sadlier, Michelle, Becky Strickler, and Jennifer Ferris. 2020. Built Environment Survey of the Former
Weyerhaeuser Corporate Headquarters Campus, Federal Way, Washington. July 29. Cardno, Seattle,
Washington. Prepared for Federal Way Campus, LLC, Los Angeles, California.
United States Department of the Army Corps of Engineers (USACE). 2020. Section 106 Correspondence for NWS-
2017-1077 Woodbridge Corporate Park Building A & B Adverse Effect. October 20. United States Department
of the Army Corps of Engineers, Seattle District, Seattle, WA. Letter to Washington State Department of
Archaeology and Historic Preservation, Olympia, WA.
Washington State Department of Archaeology and Historic Preservation (DAHP). 2020. Section 106
Correspondence for Greenline Business Park, Federal Way, Washington (Project 2018-07-05928). October 21.
Olympia, WA. Letter to United States Army Corps of Engineers, Seattle District, Seattle, WA.