17-105489-Response Letter to ESA Review Memo-04-02-2020-V13Resource & Environmental Planning
15020 Bear Creek Road Northeast • Woodinville, Washington 98077 • Bus: (425)861-7550 Fax: (425)861-7549
1 April 2020
TAL-1572C
Mr. Jim Harris, Senior Planner
City of Federal Way
Department of Community Development
33325 8th Avenue South
Federal Way, WA 98003
Via email: Jim.Harris@cityoffederalway.com
REFERENCE: Greenline Business Park Project, Federal Way, Washington
SUBJECT: Response to ESA Review Memorandum dated 30 November 2018
Dear Jim:
In response to the comments provided by Ms. Jessica Redman and Ms. Ilon Logan on 30
November 2018 (ESA) I am providing the following responses. The ESA Review Memo
addressed the Critical Areas Report and Conceptual Mitigation Plan prepared by Talasaea
Consultants, Inc. (27 October 2017) for the property located at approximately 32901
Weyerhaeuser Way South, Federal Way, Washington.
I am providing you with our responses and clarifications to the comments and recommendations
posed by ESA. To ensure accuracy, I am providing the text of their comments below in bold
text, using the same bulleted list system as found in ESA’s Memo. My responses follow
immediately in italic text.
• As documented in our previous review of the Tech Center BLA (memo dated August
22, 2017), we agree with the wetland delineation boundaries, rating forms, and rating
classifications established by Talasaea for wetlands occurring on the proposed
project site.
Comment noted.
• We generally agree with the conceptual mitigation plan and believe that the
proposed mitigation site appears to be an adequate location for wetland creation. As
the mitigation design progresses, we strongly recommend that the applicant
perform further environmental investigations (groundwater level monitoring, soil
analysis, etc.) at the proposed mitigation site to acquire the necessary data and
information to inform mitigation feasibility and design.
Comment noted. Additional investigations are anticipated, but have not been completed to
date.
Mr. Jim Harris
1 April 2020
Page 2 of 5
Resource & Environmental Planning
15020 Bear Creek Road Northeast • Woodinville, Washington 98077 • Bus: (425)861-7550 Fax: (425)861-7549
• Impacts to wetlands and wetland buffers should be minimized to the extent
possible. It appears that in several areas, impacts could be further minimized, if not
avoided, by minimal design and layout modifications while still resulting in a viable
project. These areas include the following:
o The proposed 820 SF of wetland fill in Wetland DE near the southwest corner of
Building A;
Building A (Building 1 on civil plans) is a large rectangular warehouse with limited
opportunity to modify the shape. Additionally, vehicular access completely around the
building is required. Impacts to Wetland DE have been reduced to the greatest extent
feasible for the proposed Site Plan.
o The proposed filling of Wetland CG and the intrusion into the buffers of Wetland
BA and PK, by the construction of Detention Pond 1;
The Detention Pond 1 has been sized based on existing data, assuming no possibility
of infiltration. Additional geotechnical testing will be conducted to further evaluate the
possibility of infiltration in this general area to determine if the pond can be further
reduced. At this point in time, the pond has been reduced to the greatest extent
possible. The physical geometry of the pond has been designed to reduce its footprint
as much as possible, and preserve the large conifers along Weyerhaeuser Way South
as much as feasible while minimizing impacts to critical areas.
o The proposed intrusion of the eastern edge of Detention Pond 2 into the buffer of
Wetland AV;
Only temporary construction impacts are proposed to the buffer of Wetland AV due to
grading around Detention Pond 2. These temporary disturbance areas include an
existing road with adjacent roadside ditches that will all be restored post-developed to a
forested condition.
o The proposed intrusion of the southeast corner of Detention Pond 3 into the
buffer of Wetland BR;
No direct or indirect impacts are proposed to Wetland BR or its buffer Detention Pond 3
does not extend into the buffer of Wetland BR.
o The proposed intrusion of the western edge of Detention Pond 4 into the buffer of
Wetland AH;
Wetland AH currently occurs at the base of the berm surrounding the existing
stormwater pond and is likely the result of water leaking through the berm, consistent in
formation/origins of Wetland AG. Wetland AH will only have minor temporary impacts
to its buffer resulting from regrading of the existing stormwater pond berm to expand
this facility, but will be fully restored afterwards. Wetland AH will be indirectly impacted
Mr. Jim Harris
1 April 2020
Page 3 of 5
Resource & Environmental Planning
15020 Bear Creek Road Northeast • Woodinville, Washington 98077 • Bus: (425)861-7550 Fax: (425)861-7549
as a result, but the post-development condition will be no different than the existing
condition – where the buffer includes a stormwater pond and adjacent berm.
o The proposed intrusion of the southwest corner of Building B into the buffer of
Stream AC.
Building B (Building 2 on civil plans) has been pulled back out of the stream buffer.
We recommend the current design and layout, which results in the proposed impacts to
wetlands and wetland buffers, is reevaluated for the areas described above and included
in the mitigation sequencing process.
The site plan has been revised since this comment letter was issued, with the proposed area of
development reduced from what was previously proposed. Direct wetland impacts are limited to
a few select areas where warehouse geometries are difficult to adjust or finesse around
organically shaped wetlands. Wetland impacts have been targeted to the lower quality
wetlands. Buffers have been averaged to the greatest extent possible, and indirect impacts
have been calculated where wetland fill will result in insufficiently buffered wetlands in the post-
development condition.
• The City considers grading within a wetland buffer to be development, and therefore,
the applicant needs to show that the proposed temporary buffer impacts due to site
grading meet the criteria under FWRC 19.145.440 – Development within wetland
buffers. Additionally, the applicant shall demonstrate that temporary buffer impacts
have been avoided or minimized to the extent possible, per FWRC 19.145.130.
Temporary buffer impacts should also be included on the figures in the Report.
Temporary buffer impacts are identified on the revised critical area plan sheets and have
been labeled as temporary construction impacts. These areas have been reduced to the
greatest extent possible, and are generally limited to areas near the proposed detention
ponds and where work is proposed to remove an existing trail and restore this area as
forested buffer.
• The wetland buffers on the Site Plan are inconsistent with the wetland buffers on the
figures in the Report. For example, buffers for Wetlands BA-2, PK, and BB appear
larger on the Site Plan than on Figure WI.1 in the Report. The Site Plan should be
revised to reflect the buffers presented in the Report.
Plans have been revised to be consistent on buffer widths shown.
• Sheets of the Site Plan that contain the proposed development should only show the
buffers post-development and should not include existing buffers for wetlands that
will be filled or indirectly impacted. Site Plan sheets should be revised to show post-
development buffers and an existing conditions figure should be added to the Site
Plan.
Comment noted. This revision has been made.
Mr. Jim Harris
1 April 2020
Page 4 of 5
Resource & Environmental Planning
15020 Bear Creek Road Northeast • Woodinville, Washington 98077 • Bus: (425)861-7550 Fax: (425)861-7549
• We recommend the ordinary high water mark (OHWM) of North Lake, within the project
area, be delineated in order to accurately calculate and assess proposed impacts and
activities in the shoreline.
The OHWM of North Lake was delineated in the field, as well as cross checked against
topography to ensure the most accurate reflection on the Site. The delineation was done
during a period of very high water, and so elevation data was used to correct the OHWM
location. While the OHWM would be located behind any obligate wetland species, no
wetlands that meet these parameters occur on the Site that would alter the location of the
OHWM from the clear topographic break along the northwest and west edge of the lake
where either salal begins, or where facultative or facultative wetland species occur.
• If the proposed mitigation area or any other development is within 200 feet of the
OHWM of North Lake, then shoreline review is triggered under FWRC 15.05 –
Shoreline Management. We recommend Section 6 – Regulatory Review of the Report
be revised to include all required permits.
The only work proposed within shoreline jurisdiction is enhancement plantings as part of the
mitigation effort to restore areas to a native vegetation community, and minor grading to
ensure positive drainage towards the lake. No development is proposed within the shoreline
jurisdiction. No permanent impacts to wetlands or their buffers are proposed. The Project
proposes to clean up the existing buffers and restore these areas. Native vegetation is
generally limited in these areas to young red alder and black cottonwood due to the compact
soils and range of hydrologic conditions. These areas of habitat enhancement do not affect
areas dominated by large conifers – as these stands have been specifically avoided.
Ultimately, the proposal will result in an increase in quality of critical areas and will be
consistent with the intent of the Shoreline Management Program.
• Referring to Figure WI.3 of the Report, it appears that buffer creation is proposed in
the existing buffer of Wetlands BB and BD North. This area cannot be considered as
new buffer and the Report and figures should be revised to reflect any changes.
The mitigation plan has been revised to clearly show wetland and buffer creation outside of
existing buffers.
• The areas shown as buffer creation and wetland creation areas on Figures W1.3 and
W3.1 of the Report are inconsistent. Areas of the mitigation area between the southern
end of Wetland BB and the northern end of Wetland BD North are shown as wetland
buffer creation on Figure W1.3 and shown as emergent and scrub-shrub wetland
creation, as well as buffer enhancement, on Figure W3.1. We recommend the figures
be revised to show the correct proposed mitigation actions, consistently across all
relevant Report figures.
The plan sheets have been revised for consistency to accurately reflect which areas are
wetland creation versus wetland enhancement, and then to distinguish between buffer
creation, buffer enhancement, and buffer restoration.
Mr. Jim Harris
1 April 2020
Page 5 of 5
Resource & Environmental Planning
15020 Bear Creek Road Northeast • Woodinville, Washington 98077 • Bus: (425)861-7550 Fax: (425)861-7549
• A 10-foot wide sewer easement runs through the proposed mitigation area. The sewer
was installed approximately 18 years ago along with its corresponding impact
mitigation area, which is apparently located north of the existing boat launch access.
Future application materials should show this area of previous mitigation so that it is
clear the area is not included within the current mitigation proposal.
This sewer line is shown and clearly labeled on the plans. No portion of this sewer line has
been included within this mitigation proposal. No work is proposed within the limits of this
sewer line easement.
• A portion of the buffer enhancement area on Figure W3.1 of the Report encroaches
into the existing sewer easement. This area should be removed from the mitigation
calculations. Some planting will be allowed within the terms of the easement
agreement, but this area cannot be secured in perpetuity as mitigation for the
Greenline Business Park wetland impacts.
The plans have been revised to remove any mitigation activity from within this sewer line
easement.
• Within the mitigation area, some portions of the wetland creation areas that are
closest to the sewer easement, will have less than a 25-foot buffer. The wetland
creation area should be relocated or reconfigured so that it can be adequately
buffered.
The mitigation area has been adjusted to reflect a full buffer off the sewer line easement.
While grading is being proposed near this easement as part of the wetland creation effort,
only those areas that are clearly buffered have been accounted as wetland creation. The
other areas will be buffer enhancement.
We trust that the information presented above is sufficient to address ESA’s comments
regarding Talasaea’s Critical Areas Report and Conceptual Mitigation Plan submittal for this
project. If you have any additional questions or need more information, please contact me at
(425) 861-7550.
Thank you.
Sincerely,
TALASAEA CONSULTANTS, INC.
Jennifer Marriott, PWS
Senior Wetland Ecologist/Project Manager