3-7-19 City CD Technical Review LtrCITY OF
Federal Way
Centered on Opportunity
March 7, 2019
Mr. Eric LaBrie
ESM Consulting Engineers, LLC
33400 8t" Avenue South, Suite 205
Federal Way, WA 98003
eric.labrie C@es.=iyLc_orrm
CITY HALL
33325 8th Avenue South
Federal Way, WA 98003-6325
(253) 835-7000
www. cityoffederalway. com
Jim Ferrell, Mayor
FILE
Re: Files #17 -105489 -UP & 17 -105490 -SE; TECHNICAL REVIEW COMMENTS
Woodbridge Corporate Park (aka - Greenline Business Park),
327XX Weyerhaeuser Way South, Federal Way
Dear Mr. LaBrie:
The Planning Division has the following preliminary comments in response to the Greenline Business Park
SEPA and Process IV applications. The proposal includes: construction of three new buildings totaling
approximately 1.1 million square feet; construction of approximately 1,577 vehicle parking and truck parking
stalls; approximately 18,000 square feet of wetland fill; construction of five stormwater ponds; and associated
site work and improvements.
This proposal is subject to the provisions of the 1994 Weyerhaeuser Company Concomitant Pre -Annexation
Development Agreement (CZA), and Corporate Park Zone (CP -1) zoning regulations in effect on August 23,
1994. Any procedural requirements must meet today's code, Federal Way Revised Code (FWRC) Title 19. Some
comments provided herein are required and some are informative, while others may be applicable during
future steps of the project. Comments in this letter need to be addressed prior to issuance of a SEPA
threshold determination and land use application decision, or as otherwise noted. Questions regarding
technical review comments should be addressed to the referenced staff representative.
City staff has been informed that the applicant will be submitting a revised Business Park proposal. These
comments are not a complete code based review of the proposal, and does not identify environmental
impacts resulting from the proposal. These comments should be addressed in any fsaturc submittal on the
project application.
Jim Harris — Planning Division, (253) 835-2652, lim.harrisLa)ciiyoffederalway.com
1. 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.
Use Process IV
2, Plan Set — Please address the following comments:
Mr. Eric LaBrie
Page 2of8
March 7, 2019
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.
b. Revise and amend the site data block for city reporting purposes with at least the minimum following
information:
• Under the site area, identify the size of each parcel;
is 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.
3. Parking and Parking Stall Reduclion 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 every 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 Allay 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 (ITE) concludes actual parking demand is 981 stalls.
In order for city staff to further evaluate the parking stall reduction request, please provide the following
information:
17-105489-00=UP Doc [D 17344
Mr. Eric LaBrie
Page 3 of 8
March 7, 2019
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 higher parking 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.
4. Process IV — Please provide a written response to how the proposal meets the Hearing Examiner Process
IV decisional criteria in FWRC 19.70.150(3)(a-0.
5. Butddtv{g 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 have minimal
unique or superior quality characteristics.
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 I 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.
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.
c. Identify the proposed screening methods between the truck bays on the north side of Building A to
the properties to the north.
d. Provide and delineate pedestrian connectivity the from right-of-way sidewalks to the buildings,
between buildings, and from buildings to the parking areas.
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.
f Identify retaining wall designs, materials, and architectural treatments.
17-105489-00=UP Doc ID 17344
Mr. Eric LaBrie
Page 4 of 8
March 7, 2019
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."
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.
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.
8. ManagedForest Bufer— 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).
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 III.B.2.
Eliminate all intrusions into the 50 foot MFB, except those uses specifically allowed by the CZA.
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.
9. Significant Trees —
a. Address the following comments on Sheet TR -01 and revise/provide additional information to
supplement the Gilles Evaluation of Trees as necessary:
i. The table on plan sheet TR -01 and in the Gilles report simply identifies the following:
■ 4,182 significant trees exist on site;
■ 1,736 significant trees are to be retained;
■ 41.5 percent of the significant trees will be retained; and
■ There is an average of 28.64 significant trees per acre.
There is minimal to no supporting documentation in the application materials and Gilles Report
of how the numbers above were derived and extrapolated.
17-105489-00—UP Doc ID 17344
Mr. Eric LaBrie
Page 5 of 8
March 7, 2019
If tree data is being proposed through representative sampling of trees as it appears, then you
need to provide a comprehensive table of data, and associated maps/plans, showing at a
minimum the following:
■ Size of each representative vegetation area;
■ Size of each vegetation type area;
■ Location of representative sample areas; (this is shown areas a -h on Gilles
attachment 1 vegetation map);
■ Number of significant trees in each representative sample area;
• Extrapolate (show the math) concluding how many significant trees exist in each
representative vegetation type area.
■ This data and analysis needs to be provided for each Vegetation Type and each
transect in Attachment 2 of the Gilles Report
Attachment 1 in the Gilles report---questions/comments to address:
u. Why are the two side-by-side transects (E and F) in the same vegetation type area? Why would
this be appropriate?
iii. Why are there no representative samples/ transects in the blue Wet Forest Type?
iv. If there are no transects in the Wet Forest Area, how was an average tree count per acre derived
in this vegetation type?
v. Visually, the vegetation area east of Weyerhaeuser Way seems a fairly different vegetation type
from the vegetation type west of Weyerhaeuser Way; however, in attachment A to Gilles Report,
both areas are classified as the same vegetation type (Western Red Cedar Forest). Please confirm
this vegetation type is accurate for both sides of Weyerhaeuser Way.
vi. Provide sample area/transect for areas in Western Red Cedar Forest on both sides of
Weyerhaeuser Way South. These should be separate vegetation areas.
vu. The meadow area north of 336th Street is not identified on Attachment A; however, on TR -01 it
is identified that 1,731 significant trees are existing/retained in "undisturbed vegetation" area, the
undisturbed area on TR -01 is primarily the Meadow, and the Meadow is largely void of trees.
Please explain.
viii. A separate vegetation category type must be made for the MFB areas, and identify the MFB
correctly on TR -01.
ix. Provide a detailed and easy to follow table demonstrating and concluding support for the
significant tree count and retention count as identified on TR — 01, and in the Gilles Report.
x. The Gilles Report and the general maintenance plan need to identify the name, phone number,
and email contact of the owner representative of the site in regard to the Tree Protection Fence
and tree protection measures identified on page 15 of the Gilles Report. Do not put the City of
Federal Way Code Compliance phone number and email as the contact. It is the owner's
responsibility to insure adequate protection. The owner/representative needs to have a 24-hour
phone access number posted.
b. The significant tree count and retention count must only include properties on the west side of
Weyerhaeuser Way South, and only that portion of property proposed for development on the east
side of Weyerhaeuser Way with this application. Properties should be reflective of current property
boundaries.
17-105489-00= UP Doc ID 17344
Mr. Eric LaBrie
Page 6of8
March 7, 2019
c. A separate significant tree count and analysis must occur for the portions of the property that is
being developed as part of this proposal on the east side of Weyerhaeuser Way. See the comments
above on how to prepare a tree count and analysis.
d. Brian Gilles has not provided credentials that he is a qualified Forester as required by the CZA.
Please provide these credentials, or at a minimum have a Qualified Forester prepare and certify this
tree information discussed.
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.
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 SEPA
review, and review of associated development permits or approvals,
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 SEPA checklist result
in any changed or different analysis or conclusions in the noise report?
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?
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?
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.
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.
15. Use Process IV Decisional Criteria — Provide a narrative demonstrating how the proposal satisfies FWRC
19.70.150(3)(a -fl. You should also a provide analysis and justification of the project compliance with the
requirements of the CZA.
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:
ftl).//ftp.ci!yoffeder-,tlway.com/Outbox/CD/Public°/`2OComment Greenline°/02 Buie N2 Park.
17-105489-00=UP Doc ID 17344
Mr. Eric LaBrie
Page 7 of 8
March 7, 2019
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."
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 cut/fill 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.
18. Aesthetics — A visual impact analysis of the proposed Greenhne 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 provided from Interstate -5, South 336th 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.
19. Historic Preservation — Address the October 31, 2017, comments from the Washington State Department of
Archeology and Historic Preservation (DAHP).
20. Public Works Department Comments — Comments on stormwater drainage have been previously provided
regarding the required Master Drainage Plan as required in the KCSWDM, as adopted by the city.
The Traffic Division has not provided any comments. We will forward comments on the Traffic Analysis
review when prepared.
Doc ID 17744
17-105489-00=UP
Mr. Eric LaBrie
Page 8of8
March 7, 2019
21. Agency Review and Coordination - We strongly encourage you to proactively address transportation
comments and concerns raised by WSDOT (contact Ran -in Pazooki, Local Agency & Development
Services Manager) and King County (contact Rose LeSmith, P.E., County Traffic Engineer, King County
Road Services Division).
22. Lakehaven Water and Sewer issued Certificates of Water & Sewer Availability 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 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 pre-
design/planning phase to avoid delays in overall project development.
CLOSING
Please be aware that this review does not preclude the city from requesting additional information related to
any of the topics discussed above. Please submit revised application materials as appropriate, accompanied by
the completed "Resubmittal Information Form" (enclosed). Pursuant to FWRC 19.15.050, if an applicant
fails to provide additional information to the city within 180 days of being notified that such information is
requested, the application shall be deemed null and void and the city shall have no duty to process, review, or
issue any decisions with respect to such an application.
If you have any questions regarding this letter, please contact me at jim.harris@citvoffederal ray.eon7, or 253
835-2652.
Sincerely,
a-,�
rris
Senior Planner
enc: November 30, 2018, Review Memo from ESA
Resubmittal Information Form
c: Brian Davis, Community Development Director
Robert "Doc" Hansen, Planning Manager
Stacey Welsh, Senior Planner
Kevin Peterson, Engineering Plans Reviewer
Cole Elliot, Public Works Development Services Manager
Sarady Long, Senior Transportation Planning Engineer
Brian Asbury, Lakehaven Water & Sewer District
Chris Cahan, South King Fire & Rescue
Dana 0stens on, (Imenson@IndustrialrealW roup.com
Matt Reid er, Matt. Re iderQesmcivil.com
Ramin Pazooki, WSDOT,12arookr _ w,;dllt.M.gpv
Rose LeSmith, King County Road Services, rosc.les>nith C1 kin�cVunt►�.�cw
17-105489-00=UP Doc ID 17344