17-105489-Technical Review Comments Response Letter-04-02-2020-V13April 2, 2020
Mr. Jim Harris
Senior Planner
City of Federal Way
33325 8th Avenue S
Federal Way, WA 98003-6325
�
Job No. 1886-001-016-0016
Re: Files #17 -105489 -UP & 17 -105490 -SE
TECHNICAL REVIEW COMMENTS - RESPONSES
Woodbridge Corporate Park (aka - Greenline Business Park)
327XX Weyerhaeuser Way South, Federal Way
Dear Mr. Harris:
On behalf of Federal Way Campus, LLC, ESM Consulting Engineers is pleased to provide
the City of Federal Way with updated and revised application materials for the
Woodbridge Business Park proposal. The application materials are in response to the
Technical Review Comments letter dated March 7, 2019. For ease of review, we have
followed the same format and numbering of each comment in your letter and have included
our responses in Bold.
Jim Harris — Planning Division
Technical comments made about an item on one sheet may necessitate changes to
other related sheets and related documents, and it is the applicant's responsibility to
determine any such necessary adjustments. Please ensure consistent information is
communicated throughout the plan set and associated application materials.
This comment has been noted. The plans and associated application materials have
been reviewed for consistency.
Use Process IV
2. Plan Set—Please address the following comments:
a. The "Site Data" section of the site plan on Sheet ST -01 lists several parcels
as part of the project. The parcels on the plan sheets are not current to the
parcel configuration and legal descriptions following recording of the
Lakefront Boundary Line Adjustment (BLA, city file 18 -100123 -SU). Please
revise accordingly.
33400 8th Ave. S. Ste 205 Tel (253) 838 6113 Everett (425) 297 9900 Civil Engineering Land Planning
Federal Way, WA 98003 Fax (253) 838 7104 www,esmcivii.com Land Surveying Landscape Architecture
3D Laser Scanning GIS
Mr. Jim Harris
April 2, 2020
Page 2
The parcel lines have been updated and now reflect the most recently
recorded Boundary Line Adjustment. Another Boundary Line Adjustment
was submitted on March 12, 2020 that is intended to reflect the ultimate
configuration of the Business Park.
b. Revise and amend the site data block for city reporting purposes with at /east
the minimum following Information:
•
Under the site area, identify the size of each parcel,
•
Include the existing building area;
•
List the size of each existing and proposed building;
•
Identify the proposed building height;
•
List the existing and proposed uses of each buildings;
•
Include the total building square footage;
•
Include the impervious area (identify both paved area, building area,
and total);
•
Include the stormwater area square footage;
•
Included the Managed Forest Buffer Area square footage;
•
Included the wetland and buffer area square footage;
•
Included the existing parking stall count,
•
Included the code required and proposed parking stall count,
•
Included the area of public dedication (square footage) and purpose;
and
•
Included the landscape area square footage.
A full parcel information table has been updated and added to sheet CV -01.
Please note that some data requested extends across existing parcel lines.
When this is the case, overall areas are provided for the total site.
3. Parking and Parking Stall Reduction Request -
Off-street parking shall comply with the 1994 zoning code as modified by the
provisions of Section XIII of the CP -1 regulations. Required parking is one parking
space per 300 square feet of gross floor area (gfa) for office, and one for e very 1, 000
square feet of gfa for warehouse. No floor plan has been submitted, so the exact
breakdown of office and warehouse space has not been determined
In summary, based on the November 10, 2017, ESM Parking Analysis memo, the
applicant is requesting a reduction of 819 parking stalls from the minimum count
required by the Federal Way City Code (FWCC).
The ESM memo summarizes:
o Code requires 2,396 stalls (2,395,550 SF warehouse).
o Site plan provides 1, 577 stalls (1, 466 car stalls & 111 trailer stalls).
o Parking stall count reduction request of 819 stalls (2,396 - 1,577 = 819).
o ESM memo (l TE) concludes actual parking demand is 981 stalls.
In order for city staff to further evaluate the parking stall reduction request, please
provide the fol%wing information:
Mr. Jim Harris
April 2, 2020
Page 3
Identify the existing uses and square footage of the existing Tech Center building and
anticipated uses of the Tech Center building. City staff understands that a portion of
the building is used as an office. Office use has a higherparking rate than warehouse
use.
Pursuant to FWCC Section 22-1398, a decrease in the required number of parking
spaces under Section 22-1377 may be permitted if a thorough parking study
documents that fewer parking spaces will be adequate to fully serve the uses.
Provide a thorough parking study prepared by a licensed PE in the transportation
field addressing the parking count reduction request. The parking study shall address
all existing and anticipated uses of all building area and shall also include
comparisons to other exiting similar uses with similar land use characteristics in the
Greater Puget Sound region.
Pursuant to FWCC Section 22-1397, a parking stall count reduction would be
considered (and decided) as part of the land use review process based on the criteria
in FWCC Section 22-1398.
A parking analysis has been prepared by TENw "Parking Analysis for the
Woodbridge Business Park- Federal Way, WA TENW Project No. 5219" dated March
10, 2020, and is included with this submittal.
4. Process IV— Please provide a written response to how the proposal meets the
Hearing Examiner Process l V decisional criteria in FWRC 19.70.150(3)(a -f).
See ESM's separate response letter attached with this submittal "Technical Review
Comments - Response to Comments #4 & 15", dated April 1, 2020.
5. Building and Site Design — In general, the existing parking area layout (including
ample landscape areas and open space on the west side of the Tech Center, and
vast landscape area east of the Tech Center building) generally meets the CZA
Exhibit C purpose statement as the existing development is characterized by large
contiguous sites with landscape, open space amenities, and buildings of superior
quality.
In general, the proposed Business Park site plan, buildings, and parking layout is
short of meeting the CZA objective of a superior quality, as the proposed site plan
layout and parking areas ha ve minimal unique or superior quality characteristics.
We understand the purpose statement within the CZA; therefore, we have designed
the proposed project to exceed the prescriptive requirements of the CZA zone.
Please note that construction of the Tech Center and its surrounding improvements
occurred under different regulations and under King County jurisdiction, prior to
approval of the CZA.
The revised building and site design have been prepared to exceed the minimum
prescriptive requirements of the CZA and comply with the Recitals and Purpose
statements by preserving unique natural features of the site (e.g. the meadows lying
north and south of the Headquarters building, the bonsai garden, the rhododendron
Mr. Jim Harris
April 2, 2020
Page 4
garden, the lakefront properties and many of the trails throughout the property), while
maximizing development flexibility.
a. The site and building design at the southeast corner of proposed Building B
needs to be addressed. From this high profile corner at the large high visibility
public street roundabout, looking toward the site from the public roadway the
linear appearance is proposed as: a large geometric shaped stormwater
pond,- storm pond vehicle maintenance access; then a six foot tall retaining
wall (unidentified finish materials); then a drive aisle and parking stalls above
the wall; and then a 42 foot tall building corner. Address how this site and
building design are superior quality design; as noted as one of the site
objectives identified in the Section l of the CP -1 regulations (Exhibit C to
CZA). This corner is a very high aesthetic value signature area of the
campus. Please reconsider and revise the plans to incorporate and
implement superior quality design in this location, as well as all areas of the
site.
We are unaware of any areas of the campus being identified as "signature
area(s)" and have found no additional regulations pertaining to buildings
proposed in this location. Regardless, Building B (now labeled as Building 2)
has been reduced in size and pulled away from the roundabout, thereby
reducing its overall presence at this intersection. The stormwater pond has
also been pulled back, leaving a significant area, approximately 100 feet in
depth, which will be landscaped heavily with trees and taller vegetation to
screen this building. The stormwater ponds throughout the development are
designed to be curvilinear and located below the existing ground surface so
that they are not visible from the adjacent public roadways.
b. Implement screening of all truck areas, wing walls, or comparable and/or
dense landscape or other architectural screening between the Building A
truck bays and Weyerhaeuser Way.
The Building 1 loading docks are screened from Weyerhaeuser Way S by
approximately 50' of vegetation. This includes at least 30' of existing, mature
vegetation which will be supplemented with additional plantings and
approximately 20' of new plantings. Refer to Sheet LA -01 for details. The
truck areas for Buildings 2 and 3 are located in an internal courtyard and are
therefore screened from Weyerhaeuser Way S.
C. Identify the proposed screening methods between the truck bays on the north
side of Building A to the properties to the north.
A 106' -wide swath of land containing mature vegetation, which also includes
a 25' -wide Managed Forest Buffer, is proposed to remain undisturbed along
the northern boundary of the site. Retention of this vegetation, along with
placement of the building substantially below the existing grades to the north
will screen the truck bays from the properties to the north. No further
screening is necessary between these compatible uses. See sheet ST -01,
ST -02, and ST -03.
Mr. Jim Harris
April 2, 2020
Page 5
d. Provide and delineate pedestrian connectivity the from right-of-way sidewalks
to the buildings, between buildings, and from buildings to the parking areas.
Pedestrian connectivity from the sidewalks in the right-of-way to the
buildings, between buildings, and from buildings to the parking areas has
been added to the plan set and can be found on sheets ST -01 and ST -02.
e. FWCC Section 22-1564(u) requires building walls which are uninterrupted by
a window, door, or other architectural feature; that are 240 square feet or
greater in area; and not located on a property line, to be screened by
landscaping. Identify how this code requirement is being met.
Please note that the architectural treatment proposed on all proposed
building walls meets the City's design guidelines and are the same
architectural features proposed and approved for the Building A project (File
#16 -102947 -UP).
Identify retaining wall designs, materials, and architectural treatments.
The project currently proposes CMU block walls for the retaining walls. No
specific architectural treatments are proposed. If a specific treatment or
material is required, please identify.
6. Rooftop and Ground Mounted Equipment— The submittal does not provide detail on
the location and screening for ground mounted and rooftop mechanical equipment.
Will rooftop equipment be fully or partially screened and with what type of material?
a. For rooftop mechanical equipment, per FWCC Section 22-960(a), vents,
mechanical penthouses, elevator equipment, and similar appurtenances that
extend above the roofline must be surrounded by a solid sight -obscuring
screen that meets the following criteria: (a) the screen must be integrated into
the architecture of the building'. and (b) the screen must obscure the view of
the appurtenances from adjacent streets and properties.
b. For ground mounted equipment, per FWCC Section 22-1565(a)(1), Type I
landscaping is intended to provide a solid sight barrier to totally separate
incompatible land uses. This landscaping is typically found ".. around
outdoor storage yards, service yards, loading areas, mechanical or electrical
equipment, utility installations, trash receptacles, etc."
Rooftop and ground mounted equipment cannot accurately be located at this
preliminary design stage; however, al! equipment will be adequately screened per
FWCC.
7. Wetlands and streams — Please address the following comments:
a. Review and address each comment in the enclosed November 30, 2018,
review letter from the city's wetland consultant, ESA.
Mr. Jim Harris
April 2, 2020
Page 6
A separate response letter, "Response to ESA Review Memorandum dated
30 November 2018" by Talasaea Consultants, Inc, dated April 1, 2020, has
been attached with this resubmittal.
b. Please confirm that the project applicant has opted to comply with and
process this application under the current FWRC critical area regulations,
rather than the critical area and wetland and stream regulations contained in
the 1994 FWCC, and additional wetland regulations contained within the CZA.
The applicant has opted to comply with and process the application under the
current FWRC.
8. Managed Forest Buffer— Please address the following comments:
a. Show the Managed Forest Buffer (MFB) on the north end of the CP -1
property per the November 8, 2018, City of Federal Way MFB Interpretation
(city file 18 -105277 -UP).
The 25' -wide MFB along the site's northern perimeter of the CP -1 zone is
shown on the revised plans.
b. Include and identify the 50 -foot wide MFB along all lengths and both sides of
Weyerhaeuser Way South, and on the north side of South 336th Street as
required in CZA Exhibit C Section Ill. B.2. Eliminate all intrusions into the 50 -
foot MFB, except those uses specifically al/owed by the CZA.
This comment does not appear to be consistent with the CZA or the
November 8, 2018 MFB Interpretation issued by the City since the internal
public roads do not form the "perimeter of the CP -1 property." For further
clarification, please refer to Exhibit B, Zoning Designations of the CZA for a
depiction of the perimeter of the CP -1 zone. This document does not depict
the internal portions of public roads as forming the perimeter of the CP -1
zone. The only location where the perimeter of the CP -1 zoned property
abuts a city or county roadway is along that segment of Weyerhaeuser Way
South, adjacent to the OP -1 zone in the southeast corner of the CP -1 zoned
property. This portion of Weyerhaeuser Way South was accurately depicted
with a 50' -wide MFB on the Building A and Building B application materials
previously submitted.
C. Provide a General Maintenance Plan for the MFB by a Qualified Forester and
identify who will be the required ongoing Qualified Forester per the CZA.
The applicant has engaged Mr. Galen Wright with Washington Forestry
Consultants (WFC) to act as the project's Forester, replacing Gilles Tree
Consulting. Please see the enclosed CV, Company Profile and "Forest
Management/Maintenance Plan", dated March 23, 2020.
9. Significant Trees —
The CZA prohibits the City from requiring an applicant to locate and identify
significant trees on the CP -1 property; therefore, this information has been removed
Mr. Jim Harris
April 2, 2020
Page 7
from the revised application materials. Significant Tree estimates have been
provided on sheet LA -01 based on site-specific information obtained by WFC and
Gilles Tree Consulting.
Please refer to Exhibit C, Section II. A. (Applicability), which states: `The provisions
of this section apply to all property designated Corporate Park (CP -1) Zone on
Exhibit B-1 of this Agreement. This property shall be subject to its own unique
standards of re view processes asset forth in the Agreement if the pro visions of the
CP Zone conflict with other provisions of City code, the CP Zone provisions shall
prevail. After the date of the attached Agreement, any changes in City codes
referenced in this Agreement shall not be deemed to modify the provisions of this
Zone unless approved hereinafter. "(Emp. added)
Exhibit C, Section XI. A. 3. (Landscaping) states: "Selection and installation of plant
material in all forested areas shall be the responsibility of the designated Forester
Provisions of the FWC related to selection and spacing of plant material and
identification of significant trees shallnotapp/yin the CP -1 zone. "(Emp. added)
10. Landscape Plan —A code -based review of the landscape plan is not being conducted
at this time as the site plan is being modified.
This comment has been noted.
11. Forest Practices — A Forest Practices Class IV -General Application is required, as
more than 5, 000 board feet of merchantable timber will be harvested from the
property in conjunction with the development activity. The city will review the
proposed Class IV -General Forest Practices in conjunction with SERA review, and
review of associated development permits or approvals.
This comment has been noted.
12. Noise Report— An April 2018 Environmental Noise Report by Ramboll was submitted
with the application. At this time, city staff requests the following comments be
addressed in regard to the Nose Report.
a. On page 11 of the noise report, an assumed building height of 30 feet was
used for the Noise Prediction Model. Will an actual building height of 42 feet
as identified in the SERA checklist result in any changed or different analysis
or conclusions in the noise report?
The heights of the three new buildings were updated to 45 feet in the CadnaA
noise model. This is referenced on Page 11 of the updated "Environmental
Noise Report" by Ramboll US Corporation, dated March 2020.
b. The noise report does not address the proposed removal of
approximately 2,446 significant trees from the site as identified in the
Gilles Tree Report. Will the removal of approximately 2,446 significant
trees from the site result in any changed or different analysis or
conclusions in the noise report? How does implementation/retention of
the MFB affect site noise?
Mr. Jim Harris
April 2, 2020
Page 8
Obstructions such as existing trees were not included in the CadnaA noise
model. Therefore, estimated sound levels received at the closest sensitive
receivers are considered conservative. Having a buffer of trees around the
project site would allow for some noise reduction at nearby sensitive
receivers. This is referenced on Page 11 of the updated "Environmental
Noise Report" by Ramboll US Corporation, dated March 2020.
C. The noise report does not specifically address the open water lake east of the
proposed development and how potential noise could be impacted by the
open water environment. Please address if the presence of the existing open
water lake environment will result in any changed or different analysis or
conclusions in the noise report?
The North Lake was modeled as hard, or acoustically "reflective", increasing
noise transmission across this surface. Therefore, estimated sound levels at
nearby sensitive receivers are considered conservative. This is referenced on
Page 11 of the updated "Environmental Noise Report" by Ramboll US
Corporation, dated March 2020.
13. Geotechnical Reports — A code -based review of the geotechnical report is not being
conducted at this time as there are no known geologically hazardous areas on the
site.
This comment has been noted.
14 Drainage Plan and Downstream Analysis and Potential Off -Site Improvements —
All required off-site drainage analysis, improvements, and mitigation needs to be
evaluated concurrent with this review. No information on off-site impacts and
mitigation has been provided. Any potential off-site improvements may be
required to be evaluated for SEPA compliance and FWCC based review for
potential impacts to downstream critical areas and associated procedural
requirements.
The preliminary technical information report has been revised to show a reduced
site plan, with new impervious area below 50 acres, such as to no longer trigger the
Master Drainage Plan requirement. Off-site impacts are not anticipated; therefore,
no mitigation is proposed.
15. Use Process IV Decisional Criteria — Provide a narrative demonstrating how the
proposal satisfies FWRC 19.70.150(3)(a-0). You should also a provide analysis and
justification of the project compliance with the requirements of the CZA.
A separate response letter has been prepared to address this comment, "Technical
Review Comments - Response to Comment #4 & 15" and has been attached to this
resubmittal.
16. Burden of Proof— In this letter, staff members have identified items that require
additional information to be submitted for city review. During the Notice of Application
comment period, the city received a number of public comments. Please review and
address the comments to support your project, which can be opened in Outlook here:
Mr. Jim Harris
April 2, 2020
Page 9
ftp://ftp.cityoffederalway.corn/Ourbox/CD/Public%2OComment Greenline%2013usi
ness%20Park.
FWRC 19.70. 120, Burden of Proof
"The applicant has the responsibility of persuading the hearing examiner by a
preponderance of the evidence that, under the provisions of this chapter, the
applicant is entitled to the requested decision as specified in FWRC 19.70. 120. "
Public comments have been reviewed and addressed in a separate letter, "Response
to Public Comments", dated April 1, 2020 attached with this submittal.
SEPA Checklist — Please revise and update the SEPA checklist to address the following
comments:
17. Environmental Documents — The submitted checklist lists needs to be
revised/updated to address each of the following comments:
A. 10. Building permits.
B. 1.e, Identify cudfill quantities on the property on the east side of
Weyerhaeuser Way.
B. 2. Reference the Air Quality Analysis submitted with the application; and
findings and mitigation measures proposed; etc.
B. 3. Reference appropriate wetland delineations and evaluations prepared for the
site.
B. 3. Reference the Wetland Mitigation and Wetland Creation Plan prepared for
the site.
B 3. Reference the Master Drainage Plan, or other drainage plan as
appropriate, for the site in accord with the King County Surface Water Design
Manual (KCSWDM) and City of Federal Way standards.
B. 7 Identify any contaminants from the Tacoma Assarco Smelter Plume.
B. 7 Reference the noise report prepared and submitted for the proposal and
proposed mitigation.
B. 8 Reference the adjacent public boat launch, fishing, and recreational
access on North Lake.
B. 8. Checklist identifies the existing tech center as office, and the parking
analysis identifies it as warehouse. Please rectify.
B. 8. Identify if any portion of the proposal is within 200 feet of the OHWM of
North Lake.
B. 11. Any measures proposed to control light and glare impacts?
B. 13 Reference the name, date, author, and summary of the Cultural
Resources Archival Study prepared for the site.
B. 13. Reference the name, date, author, and summary of the Transportation
Impact Analysis prepared for the site. Identify mitigation proposed.
Environmental documents have been updated to reflect the above comments.
18. Aesthetics — A visual impact analysis of the proposed Greenline Business Park
development is requested to determine its cumulative impact on public views of the
three proposed warehouses. Views of a three-dimensional computer model,
combining the existing site conditions and the proposed development, shall be
Mr. Jim Harris
April 2, 2020
Page 10
provided from Interstate -5, South 3361h Street, and Weyerhaeuser Way South, from
various points along each route. It is requested that a three-dimensional laser
scanning visual impact analysis be used to capture and display the density of existing
and retained on-site vegetation from any point in the area, to accurately allow
determination of the aesthetic impact from the development, and to determine
mitigation measures if any are needed.
Architectural renderings of the views of the proposed development were previously
submitted from the three public roadways surrounding the project. Additionally, a
design brief with exterior elevations and perspectives, by Nelson, has been included
with this resubmittal.
As previously stated by the Applicant, three-dimensional laser scanning is not the
appropriate tool to provide an accurate visual impact analysis of a forested site. If
additional views are necessary, please identify exactly how many are required and
note the exact location and direction for each additional view to be provided.
19. Historic Preservation — Address the October 31, 2017, comments from the
Washington State Department of Archeology and Historic Preservation (DAHP).
This comment will be addressed in a separate report that is currently being prepared
by Cardno. Once complete, this report will be submitted to the City and DAHP.
20. Public Works Department Comments — Comments on stormwater drainage have
been pre viously pro vided regarding the required Master Drainage Plan as required in
the KCSWDM, as adopted by the city.
The proposed project site plan has been reduced and now includes less than 50
acres of new impervious area, and thus no longer triggers the Master Drainage Plan
requirement.
The Traffic Division has not provided any comments. We will forward comments on
the Traffic Analysis review when prepared.
This comment has been noted.
21. Agency Review and Coordination - We strongly encourage you to proactively
address transportation comments and concerns raised by WSDOT (contact Ramin
Pazooki, Local Agency & Development Services Manager) and King County (contact
Rose LeSmith, P.E., County Traffic Engineer, King County Road Services Division).
This comment has been noted and the applicant's team is currently coordinating with
WSDOT. Upon receipt of WSDOT's comments and direction, we will also reach out
to King County.
22. Lakehaven Water and Sewer issued Certificates of Water & SewerAvailability for the
proposed application/project on August 4, 2017 Updates of these certificates will
need to be provided to the city. No other application has been submitted to
Lakehaven that is necessary to be able to more specifically determine the applicant's
requirements for connection to Lakehaven's water and/or sewer systems to serve the
subject property. As previously noted, the applicant will need to submit an application
for either a Developer Pre -Design Meeting or Developer Extension Agreement for
Mr. Jim Harris
April 2, 2020
Page 11
Lakehaven to formally commence the water and/or sewer plan review process.
Lakehaven encourages owners, developers, and applicants to apply for Lakehaven
processes separately to Lakehaven, and sufficiently early in the predesign/planning
phase to a void delays in o vera// project de velopment.
Updated certificates of water and sewer availability were obtained on 12/31/19 and
are included in this resubmittal.
Thank you for your comments and your attention to this project. Should you have any further
questions or would like clarification on any information, we can be available to meet with City
staff on short notice. Feel free to contact me at any time at 253-838-6113 or at
Eric.Labrie@esmcivil.com.
Sincerely,
ESM CONSULTING ENGINEERS, LLC
�
ERIC G. LaBRIE, A.I.C.P.
President
cc: Dana Ostenson, Federal Way Campus, LLC
Courtney Kaylor, McCullough Hill Leary, PS
Enc: As Noted
\\esm8\engr\esm-jobs\1886\001 \016-0016\document\1etter-006.docx