17-105489-Response to Public Comments-04-02-2020-V13
April 2, 2020 Job No. 1886-001-016-0016
Mr. Jim Harris
Senior Planner
City of Federal Way
33325 8th Avenue S
Federal Way, WA 98003-6325
RE: File Nos. 17-105489-00-UP & 17-105490-00-SE
TECHNICAL REVIEW COMMENTS –COMMENT #16
RESPONSE TO PUBLIC COMMENTS
Woodbridge Business Park - 327XX Weyerhaeuser Way South, Federal Way
Dear Mr. Harris:
This letter is written on behalf of Federal Way Campus, LLC to provide a detailed response to
public comments submitted to City of Federal Way regarding the Process IV Land Use
Application for Woodbridge Business Park. The response was requested by City of Federal
Way in the Technical Review Comments letter dated March 7, 2019. For ease of review, we
have grouped the public comments by topic and included our responses in bold font below.
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:
ftp://ftp.cityoffederalway.corn/Ourbox/CD/Public%20Comment _Greenline%20Busi
ness%20Park.
1. Increased traffic
Undoubtedly, the proposed project will add traffic on Weyerhaeuser Way S and the
surrounding street system, primarily leading to Highway 18 and Interstate 5. To help
mitigate this additional traffic the project is proposing to widen Weyerhaeuser Way S
and S 336th Street to meet the City’s Street Section K and pay traffic mitigation fees as
required by the City. Furthermore, an application for traffic concurrency was submitted
to the City on November 11, 2019 and is currently under review.
2. Noise to be created by the proposed buildings
The “Environmental Noise Report” prepared by Ramboll US Corporation, dated March
2020, measured the existing sound levels for the site and an assessment based on the
proposed development was performed. The assessment was based on significant
expected equipment anticipated during hours of operation and included truck traffic for
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April 2, 2020
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loading and unloading of products. The model found the proposed project would result
in negligible increases in ambient noise.
3. Air quality changes caused by traffic increase
Ramboll US Corporation completed an “Air Quality Technical Report”, dated March
2020. The report includes the current air quality conditions and explains the potential
impacts during construction. Construction could temporarily change localized air
quality but is unlikely to result in any significant adverse air quality impacts. Air quality
in relation to the increase in daily trips caused by the project would not likely cause or
contribute to any significant traffic-related air quality impacts.
4. Historic preservation of the Weyerhaeuser campus
The project is not registered under the National Register of Historic Places. The
applicant has commissioned Cardno to compete a historic review of the Campus and
details will be included in the report when it is complete. We anticipate this report will
be submitted to the City and DAHP in the near future.
5. Environmental review should be consolidated and an EIS required
Comments requested that the environmental review for Woodbridge Business Park be
consolidated with the other two projects adjacent (Woodbridge Building A and
Woodbridge Building B). However, separate applications for the three projects have
been submitted and the approval of one application does not impact the progress of
the other projects. Moreover, there have been no significant adverse environmental
impacts that cannot be mitigated which makes the assertion of an EIS inappropriate.
6. Tree Report
Concerns regarding the originally submitted tree report, methodology used, and the
qualifications of the arborist to uphold the Concomitant Zoning Agreement were raised.
Since our receipt of the public comments, the applicant has engaged Mr. Galen Wright
with Washington Forestry Consultants to act as the project’s Forester, replacing Gilles
Tree Consulting. A new tree retention plan has been completed “Revised Tree and
Vegetation Retention Plan”, dated February 18, 2020 by Washington Forestry
Consultants, Inc.
7. Water quality
The “Preliminary Technical Information Report” by ESM Consulting Engineers, LLC,
dated March 31, 2020 describes the project’s stormwater conveyance system and
mitigation for the stormwater runoff. The proposed development will comply with Level
2 Flow Control, Basic and Enhanced Water Quality Treatment per the SWDM.
The proposed onsite stormwater conveyance system will collect and convey runoff
from the developed project site to the stormwater drainage system in the Right-of-Way
(ROW) of S 336th Street and Weyerhaeuser Way S. The developed project site will
drain to the south and east boundaries of the site, discharging to the Weyerhaeuser
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April 2, 2020
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Pond and North Lake respectively, which are the natural discharge locations for the
site. All stormwater discharges will be treated prior to being discharged.
8. Damage of wetlands
The “Critical Areas Report and Conceptual Mitigation Plan” by Talasaea Consultants,
Inc., dated October 27, 2017, delineates the extent of impacts to the wetlands.
Construction of the proposed development would directly impact (fill) 0.31 acres of
wetlands for the buildings, parking, and stormwater facilities. Four wetlands will be
insufficiently buffered resulting in an additional 0.11 acre of wetland being considered
indirect wetland impacts due to site development encroachments. Wetland impacts
will be mitigated through a multi-part mitigation plan which can be found within the
report mentioned above. All impacts are allowed under the CZA.
9. Loss of habitat and greenspace
Pursuant to the CZA, up to 70% of the entire CP-1 zone may be developed with
impervious surfaces and no other lot coverage restrictions shall apply (Section III A.).
The project is proposing to maintain the open meadow area, the Managed Forest
Buffers, Critical Areas and their buffers, trails and other habitats and greenspace.
Additionally, the “Critical Areas Report and Conceptual Mitigation Plan” prepared by
Talasaea Consultants, Inc., dated October 27, 2017 found that no unique habitats
occur on site.
10. Loss of wildlife
The “Critical Areas Report and Conceptual Mitigation Plan” by Talasaea Consultants,
Inc., dated October 27, 2017, includes an assessment of wildlife found at the site. The
study found no listed species on the project site.
Salmonids were a recurring concern in the comments, but as stated in the Critical
Areas report no habitats for salmonids occur on or immediately adjacent to the project
site. There are no fish-bearing streams or lakes located on the project site. Salmonids
do occur in North Lake and downstream in the Hylebos Creek, but all stormwater
charged from the site will be treated to meet water quality standards prior to being
discharged into downstream water bodies.
11. Size of the forest buffers
There are concerns over the size of forest buffers surrounding the project. Section III.B
of the CZA states, “A continuous Managed Forest Buffer shall be provided around the
entire perimeter of the CP-1 property.” The depth of the MFB is 50 feet where the
perimeter abuts a city road and 100 feet where the perimeter abuts a state highway. A
25-foot buffer is shown along the northern boundary with the OP-1 zone and a 100-
foot buffer is shown along Interstate 5. These two boundaries are the only portion of
the perimeter of the CP-1 zone within the project site.
12. Compatibility of use with adjacent land
The proposal is subject to the provisions of the 1994 Weyerhaeuser Company
Concomitant Pre-Annexation Development Agreement (CZA) and zoning regulations
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April 2, 2020
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in effect on August 23, 1994 (FWCC). Zoning for the subject property is Corporate Park
(CP-1). Warehousing and distribution; and corporate offices are permitted uses in the
CP-1 zone pursuant to CZA Exhibit C, Section VII, “Permitted Uses on Those Portions
of the CP-1 Zoned Property Lying Outside the Managed Forest Buffer.” The CZA
states that warehousing and distribution are allowed uses and are therefore, by
definition, considered to be compatible with adjacent land.
If you have any questions, please feel free to contact me at 253-838-6113, and I look forward
to your response.
Sincerely,
ESM CONSULTING ENGINEERS, LLC
ERIC G. LaBRIE, A.I.C.P.
President
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