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ESA Memomemorandum Stacey Welsh, City of Federal Way Department of Community Development At the request of the City of Federal Way (City), Environmental Science Associates (ESA) reviewed the Critical Areas Report Greenline Warehouse B(dated September 1, 207) prepared by Talasaea Consultants Inc. for the property at approximately 33663 Weyerhaeuser Way in Federal Way, Washington. The site is part of the former Weyerhaeuser Campus property which has recently been renamed the Greenline Campus. The 13.1-acre site is a combination of two parcels (King County Tax Parcel Numbers 6142590005 and 6142600200) currently owned by Federal Way Campus, LLC. The Greenline Warehouse B project (Project) is proposing to build a 214,050 square foot (SF) building, with associated infrastructure and parking, directly south of the proposed Warehouse A. ESApreviously reviewed development application materials for this site in October 2016 for development by Preferred Freezer Services, LLC and again in June 2017 for development by Federal Way Campus, LLC and the proposed Greenline Warehouse A. Site visits by ESA biologists were conducted in August 2016 and May 2017. The results of the Preferred Freezer and Warehouse A reviews were reported to the City in the Critical Areas Report and Conceptual Mitigation Plan Review: Preferred Freezer Services LLC (ESA memo dated October 5, 2016) and the Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Warehouse(ESA memo dated June 21, 2017) technical memorandums. ESA also reviewed wetland determinations throughout the Greenline Campus and existing conditions reports for the Greenline Headquarters and Greenline Tech Center Boundary Line Adjustment (BLA) projects. ESA biologists conducted four site visits for the BLA projects which occurred in May, June, and August, 2017. Results of the wetland verifications for the Headquarters and Tech Center BLA project were presented to the City in the Existing Conditions Report – Greenline Headquarters Boundary Line Adjustment Review technical memo (ESA memo dated August 18th, 2017) and the Existing Conditions Report – Tech Center Boundary Line Adjustment technical memo (ESA memo dated August 22nd, 2017). Site Background and Purpose of Review In 1994, the Weyerhaeuser Company entered into a pre-annexation zoning agreement with the City, known as the Concomitant Agreement, to ensure that once annexed, the Weyerhaeuser Company Campus was developed “with maximum flexibility which will insure optimal development, while preserving the unique natural features of the site” (Weyerhaeuser Company Concomitant Pre- Annexation Zoning Agreement, 1994). The Concomitant Agreement has detailed zoning provisions for the property and states that any portions of the property classified as environmentally sensitive, including wetlands, are under the jurisdiction of, and shall comply with, Article XIV (Environmentally Sensitive Areas) of the 1994 Federal Way Code (FWC). The purpose of this review is to determine if the proposed project is in compliance with Concomitant Agreement and Chapter 22, Article XIV of the 1994 FWC. Review of Documents ESA reviewed the Critical Areas Report – Greenline Warehouse B (dated September 1, 2017 and hereinafter referred to as the CAR) and the Greenline Warehouse B Site Plan prepared by ESM Consulting Engineers (also dated September 1, 2017). According to the documents, two wetlands (Wetlands EC and EF) occur within the site of the Warehouse B project (the Project). Eleven other wetlands and one stream (Stream EA) occur adjacent to the Project’s site. The Project proposes to fill both Wetlands EC and EF. Due to the proximity of the proposed Warehouse A to the proposed Warehouse B, all wetlands, streams, and impacts were described in the Critical Areas Report and Buffer Management Plan – Greenline Warehouse A (hereinafter referred to as the Management Plan), and therefore, that document is also a part of this review. According to the Management Plan, the construction of Warehouse A and B will result in a total of 9,922 square feet (SF) of direct wetland impacts (including Wetlands EC and EF). According to the Concomitant Agreement, “development affecting wetlands which are individually smaller than 2,500 square feet and/or cumulatively smaller than 10,000 square feet in size in any 20-acre section of property” is exempt from sensitive areas regulations. Therefore, the proposed impacts to wetlands are considered exempt by the City and no mitigation is required. The buffers of three additional wetlands (Wetlands DT, DR, and DQ) will be reduced a total of 10,124 SF. To compensate, the Management Plan proposes to replace 19,625 SF of buffer for a net gain of 9,411 SF. Approximately 1,944 SF of the buffer of Stream EA will also be reduced, and replaced with 2,235 SF of additional stream buffer. Impacts from construction will also result in2,648 SF of temporary buffer impacts to the buffers of Wetland DQ and DR. Review Comments and Recommendations Based on the review of documents for consistency with the City of Federal Way requirements and regulations, we have the following comments and recommendations: The Critical Areas Report – Greenline Warehouse B document does not meet the requirements stated in Section 22-1356 (b) of the 1994 Federal Way Code and does not include wetland descriptions or an analysis of wetland functions. It includes impacts and mitigation over plan sheets (Sheet 1.1), but does not include a description of the impacts and mitigation in the report. It is unclear why the size of three wetlands (Wetlands DQ, DX, and DZ) are different between the Management Plan and the previously reviewed Critical Areas Report and Conceptual Mitigation Plan: Greenline Warehouse A(see Table 1 in both documents). During our June 2017 review and associated site visit, ESA agreed with the wetland delineation boundaries. Using the originally reported sizes in critical areas report, the total proposed fill to is10,092 SF and surpasses the allowed 10,000 SF of exempt impacts. Sheet W1.1 of the CAR proposes 4,427 SF of buffer reduction, but only proposed 3,286 SF of buffer replacement. The amount of replacement should be equal or greater to the amount of reduction. The CAR for Warehouse B does not include a planting plan. It is unclear what the temporary construction impacts to the buffers of Wetlands DQ and DR include. To meet code requirements, the application materials should show how the proposed temporary impacts meet the criteria for land surface modifications within setback areas under Section 22-1359(d) of the 1994 Federal Way Code. Furthermore, the application materials propose different amounts of temporary impacts. The CAR proposes 5,874 SF of temporary impacts and the Management Plan proposed 22,494 SF of temporary impacts. It is unclear what the trail restoration area (Area F) is on Sheet W1.3 of the Management Plan. No trail is mentioned in the report text or shown on any associated figure. Proposed buffer reductions and replacements for Warehouse A and Warehouse B should be presented on one figure so that they can be compared and confirmed. A portion of the buffer replacement area on the Management Plan figure (Sheet W1.2) appears to overlap with the proposed buffer reduction area on the figure (Sheet W1.1) in the Warehouse B CAR.