Loading...
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.