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011 CA Report CRITICAL AREAS REPORT GREENLINE BUILDING B FEDERAL WAY, WASHINGTON FILES #17-104236-UP & 17-104237-SE Prepared For: FEDERAL WAY CAMPUS, LLC Los Angeles, California Prepared By: TALASAEA CONSULTANTS, INC. Woodinville, Washington 1 September 2017 (Revised 26 June 2018) Critical Areas Report Greenline Building B Federal Way, Washington Files #17-104236-UP & 17-104237-SE Prepared For: Tom Messmer, Vice President Federal Way Campus, LLC 11100 Santa Monica Boulevard, Suite 850 Los Angeles, California 90025 Prepared By: Talasaea Consultants, Inc. 150250 Bear Creek Road NE Woodinville, Washington 98077 (425) 861-7550 1 September 2017 (Revised 26 June 2018) Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page i EXECUTIVE SUMMARY PROJECT NAME: Greenline Building B APPLICANT: Tom Messmer, Vice President, Federal Way Campus, LLC (FWC) LOCATION: The Project Site is located in Federal Way, Washington on King County Parcel Number 614260-0200. The coordinates for the center of the Project Site are 47.297199, -122.294056. The Project Site is 14.3 acres in size. The Public Land Survey System location of the Project Site is Section 21, Township 21 North, Range 4 East, Willamette Meridian. PROJECT STAFF: Bill Shiels, Principal; Ann Olsen, RLA, Senior Project Manager; Jennifer Marriott, PWS, Senior Ecologist; David Teesdale, PWS, Senior Ecologist; Richard Tveten, Senior Ecologist; and Kristen Numata, Ecologist FIELD SURVEY: Site evaluations and wetland delineations were performed between December 2015 and present. CAVEAT: This report assumes that construction of Greenline Building A (Files #16-102947-UP & 16-102947-SE) is complete and that the Building A built-condition is the baseline existing condition for Greenline Building B. This report assumes that the wetlands proposed to be impacted as part of Building A have been impacted, and thus are no longer present in this existing condition scenario. DETERMINATION: Wetlands DT and DP occur within the Managed Forest Buffer, as well as Stream EA. Wetlands EC and EF previously occurred within the Site but were identified for impact as part of the Greenline Building A project, and as such, are not shown on the provided graphics for Building B. All existing wetlands require a 100-foot setback per the 1994 Federal Way City Code (FWCC). Stream EA requires a 50-foot setback as a minor stream per the 1994 FWCC. HYDROLOGY: Hydrology for the Project Site wetlands is supported, for the most part, by seasonal precipitation and interception of surface water flow, as well as groundwater to a lesser extent. SOILS: The NRCS maps one type of soil in the entirety of the Project Site, Alderwood gravelly sandy loam, 0 to 8 percent slopes. The National Technical Committee on Hydric Soils does not include Alderwood gravelly sandy loam as a hydric soil. VEGETATION: The majority of the Project Site is a Douglas fir forest with an understory dominated by salal. Other typical species present within the uplands include salmonberry, vine maple, and other native shrub and herbaceous species. Several non-native species of tree are present along the gravel access roads, clearly planted at some point in the past. Typical vegetation within the wetlands includes salmonberry, red alder, and several species of willow though areas of minimal to no vegetation present. PROPOSED PROJECT: FWC, LLC is proposing to develop a general commodity building that will be approximately 214,050 square feet with associated infrastructure and parking. A stormwater quality control and detention pond are located to the south and is an expansion of the Greenline Building A facility. Limited commercial vehicle ingress and egress access will be off Weyerhaeuser Way S near the interchange ramps for Highway 18, while additional vehicular access will be provided off Weyerhaeuser Loop Road. A 100-foot wide Managed Forest Buffer (MFB) along Weyerhaeuser Way S, expanded to 100-feet along Highway 18, will be maintained Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page ii consistent with the arborist-prepared management plan, as required by the Concomitant Agreement with the City ASSESSMENT OF DEVELOPMENT IMPACTS: The proposed site plan has been designed to minimize impacts to critical areas to the greatest extent practicable while meeting the criteria for development of a viable project and conforming to the City of Federal Way standards and zoning. Construction of the proposed development and stormwater pond will not impact any critical areas that have not already been addressed through the Greenline Building A application. Minor modifications to the proposed buffer reduction plan for Wetland DT and Stream EA are anticipated to accommodate the Site. PROPOSED COMPENSATION: No mitigation is proposed to compensate for wetland impacts as the wetland impacts are exempt from City of Federal Way regulations per the Concomitant Agreement. Buffer averaging will occur on the Project Site through buffer replacement, enhancement, and restoration per the Concomitant Agreement. Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page iii TABLE OF CONTENTS Executive Summary ......................................................................................................... i Table of Contents ............................................................................................................ iii List of Figures, Tables and Appendices .......................................................................... v Chapter 1. Introduction ................................................................................................ 1 1.1 Purpose of Report ............................................................................... 1 1.2 Statement of Accuracy ........................................................................ 1 1.3 Qualifications ....................................................................................... 1 Chapter 2. General Property Description and land use ............................................... 2 2.1 Project Site Location ........................................................................... 2 2.1.1 Project Site Description ....................................................................... 2 Chapter 3. Methodology .............................................................................................. 2 3.1 Background Data Reviewed ................................................................ 3 3.2 Field Investigation ............................................................................... 3 Chapter 4. Results ....................................................................................................... 4 4.1 Analysis of Existing Information ........................................................... 4 4.1.1 USGS Quadrangle Map ...................................................................... 4 4.1.2 National Wetland Inventory Map ......................................................... 4 4.1.3 Natural Resources Conservation Service Map .................................... 4 4.1.4 King County GIS Database ................................................................. 4 4.2 Analysis of Existing Conditions ............................................................ 4 4.3 Wetland DP ......................................................................................... 5 4.4 Wetland DT ......................................................................................... 5 4.5 Stream EA ........................................................................................... 6 4.6 Wildlife Surveys and Habitat Assessments ......................................... 6 4.6.1 Listed Species - Salmonids ................................................................. 6 4.6.2 Listed Species - Bald Eagles ............................................................... 7 Chapter 5. Regulatory Review ..................................................................................... 7 5.1 Federal and State Regulations ............................................................ 7 5.2 City of Federal Way Permitting Approach............................................ 8 5.2.1 Wetlands ............................................................................................. 9 5.2.2 Streams ............................................................................................... 9 Chapter 6. Proposed Project ....................................................................................... 9 6.1 Proposed Project ................................................................................. 9 6.2 Stormwater Treatment ......................................................................... 9 Chapter 7. Assessment of Development Impacts ........................................................ 9 7.1 Wetland and Buffer Impact Analysis .................................................. 10 7.1.1 Wetland Impacts ................................................................................ 10 7.1.2 Wetland Buffer Impact Analysis ......................................................... 10 7.1.3 Buffer Averaging ................................................................................ 10 7.1.4 Land Surface Modifications within the Setback (buffer) Areas .......... 10 7.2 Stream Impact Analysis ..................................................................... 12 7.2.1 Stream Impacts ................................................................................. 12 7.2.2 Stream Buffer Analysis ...................................................................... 12 Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page iv 7.2.3 Buffer Averaging ................................................................................ 12 Chapter 8. Summary ................................................................................................. 12 Chapter 9. References .............................................................................................. 14 LIST OF FIGURES Figure 1. Vicinity Map and Driving Directions Figure 2. Site Aerial and Parcel Map Figure 3. USFWS National Wetlands Inventory Map Figure 4. NRCS Soils Map Figure 5. Historical Aerial (1957) Map Note: all figures are located at the end of the report before the appendices. APPENDICES Appendix A: Buffer Averaging Plan Sheets Sheet W1.0 Existing Conditions Plan Sheet W1.1 Proposed Site Plan, Impacts & Mitigation Overview Plan Sheet W1.2 Buffer Modification Overview Plan Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 1 CHAPTER 1. INTRODUCTION 1.1 Purpose of Report This report is the result of a critical areas study for the Federal Way Campus, LLC (FWC, LLC) property proposed for the development of Greenline Building B (referred to hereinafter as the “Project Site” or “Site”). The Site is located in Federal Way, Washington (Figure 1). The Project Site is comprised of King County Parcel Number 6142600200 (Figure 2). The Applicant is planning to develop an approximately 214,050 square foot building with limited office space and associated infrastructure. This report has been prepared to comply with the requirements of the 1994 Federal Way City Code (FW CC) Article XIV. Environmentally Sensitive Areas, Division 7. Regulated Wetlands, Sections 22-1356-1359, and the Concomitant Agreement. This report will provide and describe the following information:  General property description;  Methodology for critical areas investigation;  Results of critical areas background review and field investigation;  Existing site conditions;  Regulatory review;  Proposed Project; and  Assessment of Development Impacts. This report assumes that construction of Greenline Building A (Files #16-102947-UP & 16-102947-SE) is complete and that the Building A built-condition is the baseline existing condition for Greenline Building B. This report assumes that the wetlands proposed to be impacted as part of Building A have been impacted, and thus are no longer present in this existing condition scenario. 1.2 Statement of Accuracy Stream and wetland characterizations and ratings were conducted by trained professionals at Talasaea Consultants, Inc., and adhered to the protocols, guidelines, and generally accepted industry standards available at the time the work was performed. The conclusions in this report are based on the results of analyses performed by Talasaea Consultants and represent our best professional judgment. To that extent and within the limitation of project scope and budget, we believe the information provided herein is accurate and true to the best of our knowledge. Talasaea does not warrant any assumptions or conclusions not expressly made in this report, or based on information or analyses other than what is included herein. 1.3 Qualifications Field investigations and evaluations were conducted by Talasaea staff including: Bill Shiels, Principal; Jennifer Marriott, PWS, Senior Ecologist; David R. Teesdale, PWS, Senior Wetland Ecologist; Richard Tveten, Senior Ecologist; and Kristen Numata, Ecologist. Bill Shiels has a Bachelor’s Degree in Biology from Central Washington University and a Master’s Degree in Biological Oceanography from the University of Alaska. He has over 40 years of experience in wetland delineations and mitigations. Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 2 Jennifer Marriott has a Bachelor’s Degree and a Master’s Degree in Biology from University of Central Florida, and a second Master’s Degree in Soil and Environmental Science from the University of Florida. She has over 13 years of experience in wetland delineations and environmental permitting. David Teesdale has a Bachelor’s Degree in Biology from Grinnell College, Iowa, and a Master’s Degree in Ecology from Illinois State University. He has 20 years of experience in wetland delineations and biological evaluations. Richard Tveten has a Bachelor of Science and Master of Science in Biology from Western Washington University with a focus on terrestrial ecology and fire ecology, respectively. Richard has worked for the public and private sectors for 20 years in wetlands, water quality, and forest management. Kristen Numata has Bachelor’s Degrees in Biology and Environmental Science from Santa Clara University. Buffer mitigation design was prepared by Ann Olsen, RLA. Ann has over 24 years of experience in designing critical area mitigation plans CHAPTER 2. GENERAL PROPERTY DESCRIPTION AND LAND USE 2.1 Project Site Location The Project Site is comprised of King County Parcel Number 614260-0200 currently owned by the Applicant, FWC, LLC (Figure 2). The coordinates for the center of the Project Site are 47.297199, -122.294056. The Project Site is 14.3 acres in size. The Public Land Survey System location of the Project Site is Section 21, Township 21 North, Range 4 East, Willamette Meridian. 2.1.1 Project Site Description The topography of the Site is gently sloping downhill from the west to the east and north to south. The Site is bound to the north by the Greenline Building A Project, by Weyerhaeuser Way South to the east, by Weyerhaeuser Road to the west, and Highway 18 to the south. The on-ramp to Highway 18 abuts the south property line of the Project Site. The Site is currently undeveloped except for existing service roads and a passive recreational trail system. CHAPTER 3. METHODOLOGY The critical areas analysis of the Site involved a two -part effort. The first part consisted of a preliminary assessment of the Site and the immediate surrounding area using published environmental information. This information includes: 1) Wetland and soils information from resource agencies; 2) Critical Areas information from King County and the City of Federal Way; 3) Orthophotography and LIDAR imagery; and, 4) Relevant studies completed or ongoing in the vicinity of the Site. The second part consisted of site investigations where direct observations and measurements of existing environmental conditions were made. Observations included plant communities, soils, hydrology, and stream conditions. This information was used to help characterize the site and define the limits of critical areas onsite and offsite for regulatory purposes (see Section 3.2 – Field Investigation below). Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 3 3.1 Background Data Reviewed Background information from the following sources was reviewed prior to field investigations:  US Fish and W ildlife Service (USFWS), Wetlands Online Mapper (National Wetlands Inventory) (U.S. Fish and Wildlife Service 2017) (www.wetlandsfws.er.usgs.gov/wtlnds/launch.html);  Natural Resources Conservation Service (NRCS), Web Soil Survey (NRCS 2017)(www.websoilsurvey.nrcs.usda.gov/app/);  NRCS, National Hydric Soils List by State (NRCS 2016) (www.soils.usda.gov/use/hydric/lists/state.html);  King County GIS Database (King County 2016);  Orthophotography from USDA’s National Agricultural Imagery Program (NAIP 2016), Earth Explorer (USGS), and Google Earth.  Washington Department of Fish and Wildlife (WDFW) Priority Habitat and Species (PHS) Mapper;  Salmonscape (WDFW) (http://wdfw.wa.gov/mapping/salmonscape);  StreamNet (The Pacific States Marine Fisheries Commission)(http://www.streamnet.org/data/interactive-maps-and-gis-data/)  USFWS listed species data; and  National Marine Fisheries Service (NMFS). 3.2 Field Investigation Talasaea Consultants originally evaluated the Project Site as part of a larger effort for FWC, LLC beginning in December 2015. Wetlands have been periodically evaluated for accuracy since their initial delineations in December 2015 through the present. Our wetland delineation utilized the routine approach described in the Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountain, Valleys, and Coast Regions (U.S. Army Corps of Engineers 2010). Ordinary high water marks (OHWM) were established based on the DOE guidance document Determining the Ordinary High Water Mark for Shoreline Management Act Compliance in Washington State (DOE Publication #16-06-029, March 2010). Plant species were identified according to the taxonomy of Hitchcock and Cronquist (Hitchcock, et al. 1969). Taxonomic names were updated and plant wetland status was assigned according to North American Digital Flora: National Wetland Plant List, Version 2.4.0 (Lichvar, et al. 2012). Wetland classes were determined with the U.S. Fish and Wildlife Service’s system of wetland classification (Cowardin, et al. 1979). Vegetation was considered hydrophytic if greater than 50% of the dominant plant species had a wetland indicator status of facultative or wetter (i.e., facultative, facultative wetland, or obligate wetland). Wetland hydrology was determined based on the presence of hydrologic indicators listed in the Corps’ Regional Supplement. These indicators are separated into Primary Indicators and Secondary Indicators. To confirm the presence of wetland hydrology, one Primary Indicator or two Secondary Indicators must be demonstrated. Indicators of Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 4 wetland hydrology may include, but are not necessarily limited to: drainage patterns, drift lines, sediment deposition, watermarks, stream gauge data and flood pr edictions, historical records, visual observation of saturated soils, and visual observation of inundation. Soils on the site were considered hydric if one or more of the hydric soil indicators listed in the Corps Regional Supplement were present. Indicators include presence of organic soils, reduced, depleted, or gleyed soils, or redoximorphic features in association with reduced soils. An evaluation of patterns of vegetation, soil, and hydrology was made along the interface of wetland and upland. Wetland boundary points were then determined from this information and marked with wire flags or surveyors tape. Data forms prepared by Talasaea for representative locations in both upland and wetland locations are included within the Critical Areas Report and Buffer Averaging Plan for Greenline Building A, dated 2 March 2018. These data forms document the vegetation, soils, and hydrology information that aided in the wetland boundary determination. CHAPTER 4. RESULTS This section describes the results of our in-house research and field investigations. For the purpose of this report, the term “vicinity” describes an area within 300 feet of the Site. 4.1 Analysis of Existing Information The following sources provided information on site conditions based on data compiled from resource agencies and local government. 4.1.1 USGS Quadrangle Map The Project Site occurs on the Poverty Bay quadrangle. The quad map indicates North Lake occurs north of the Site with Weyerhaeuser Pond well west of the Site. No other wetland or stream features are indicated on this map. 4.1.2 National Wetland Inventory Map The National Wetland Inventory (NWI) maps no wetlands on or adjacent to the Project Site (Figure 3). 4.1.3 Natural Resources Conservation Service Map The NRCS maps one type of soil in the entirety of the Project Site, Alderwood gravelly sandy loam, 0 to 8 percent slopes (Figure 4). The National Technical Committee on Hydric Soils does not include Alderwood gravelly sandy loam as a hydric soil. 4.1.4 King County GIS Database King County does not map any critical areas on or adjacent to the Project Site. In the broad vicinity of the site, both North Lake and Weyerhaeuser Pond are mapped as wetland units. One wetland unit is mapped to the south of the Project Site, but is separated from the Project Site by Highway 18. 4.2 Analysis of Existing Conditions The Site is located adjacent to the Greenline Building A project (Sheet 1.0, Appendix A). All of the wetlands located on or adjacent to the Site were reviewed and evaluated Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 5 as part of the Greenline Building A project, and are detailed within the Critical Areas Report and Buffer Averaging Plan for Greenline Building A, dated 2 March 2018. The field work for these two projects was conducted concurrently, and thus much of the data overlaps. The Project Site was undeveloped on the 1957 aerial image, though a series of parallel roads crossed the Site (Figure 5). Parcels and roads were laid out in a standard grid pattern. The now vacated rights-of-way have long since been removed or abandoned, based on a review of historic aerial imagery. Figure 5 reflects the locations of the currently delineated wetlands relative to the 1957 aerial imagery, which shows the presence of the old rights-of-way and structures present at that time. Much of this area is underlain by glacial till. This dense material frequently possesses inclusions consistent with redoximorphic features except they lack the diffuse boundaries characteristic of active wetland hydrology. This material is also very difficult to dig through for complete soil profiling. In addition, a number of non-native species of trees occur along the existing gravel roads. Talasaea Consultants performed an initial delineation of Project Site wetlands in January 2016. We subsequently re-delineated the wetlands in April of 2016. Thirteen (13) wetlands occurred across the combined sites for Greenline Buildings A and B. Of those wetlands, nine (9) were proposed to be impacted as part of the construction of Building A, including Wetlands EC and EF, which are located within the current Greenline Building B Project Site. Wetlands DP and DT and Stream EA will remain within the Managed Forest Buffer that occurs adjacent to the Greenline Building B Site. 4.3 Wetland DP Wetland DP is a 300 square-foot palustrine forested wetland located in the southeast corner of the site between a gravel pedestrian path and Highway 18 adjacent to the Highway 18 right-of-way (ROW). This depressional wetland is dominated by red alder (Alnus rubra). Wetland DP is seasonally flooded, and has hydrology supported by precipitation and overland flow. Most of the wetland was ponded with 6 inches of water at the time of site investigations so thorough evaluations of soils were problematic. Soils were assumed hydric within the wetland due to the presence of wetland hydrology and hydrophytic vegetation. 4.4 Wetland DT Wetland DT is a 2,430 square-foot palustrine scrub-shrub wetland located to the south of Wetlands EB along a maintained service road. This depressional wetland is located along the eastern edge of the Project Site. Vegetation within the wetland consists of vine maple (Acer circinatum), salmonberry, and reed canarygrass (Phalaris arundinacea). Most of the wetland was under at least 12 inches of water at the time of site investigations so thorough evaluations of the soils were problematic. Soils within the unit, where a soil pit could be dug, are a 10YR 2/2 and were assumed hydric within the wetland due to the presence of wetland hydrology and hydrophytic vegetation. Wetland DT is seasonally flooded, and is supported hydrologically by precipitation and overland flow. Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 6 4.5 Stream EA Stream EA is located in the southeast corner of the Site and flows south under the access road and under Highway 18. The stream is intermittent and is supported hydrologically by precipitation and surface water flows from the surrounding uplands. Areas immediately surrounding the stream are dominated by red alder and Himalayan blackberry (Rubus armeniacus). 4.6 Wildlife Surveys and Habitat Assessments The Project Site was evaluated for wildlife and habitats concurrently with delineation efforts and observations of additional wildlife were recorded during all field visits since December 2015. The general habitat on the Project Site is a blend of small depressional wetlands, third-growth Douglas fir forest with a patchy salal/sword fern understory, and a mixed deciduous forest with a primarily salmonberry understory. No unique habitats occur onsite. General wildlife observations during fieldwork included:  Birds: American Robin, Pacific Wren, Canada Goose, Chickadee, Ruby- crowned Kinglet, Red-winged Blackbird, Pileated Woodpecker, Bufflehead, Mallard, American Widgeon, American Crow, American Coot, Pied-billed Grebe, Rufous Hummingbird;  Mammals: mountain beaver (burrows), rabbit, deer, coyote;  Amphibians: bullfrogs. Multiple site visits since the initial wetland delineations have added to the list of species identified as occurring on the Project Site, as well as expanding our timeframe over which we have evaluated this Site. No listed species occur on the Project Site. A bald eagle nest is mapped on the Washington Priority Habitat and Species database as occurring approximately 1,350 feet east of the Project Site. One non-fish-bearing stream occurs within the Project Site. North Lake occurs approximately 1,200 feet north of the Project Site on the opposite side of Weyerhaeuser Way South. 4.6.1 Listed Species - Salmonids While no habitat occurs on or adjacent to the Project Site for salmonids, listed species evaluated for these effects include the listed salmon species (Chinook salmon, steelhead, bull trout) to address the potential for downstream water quality impacts. A bald eagle nest is mapped on the Washington Priority Habitat and Species database as occurring approximately 1,350 feet east of the Project Site, and is discussed in detail below. Salmonids have not been observed in any of the streams, North Lake, or Weyerhaeuser Pond within the greater FWC, LLC property. Neither SalmonScape nor StreamNet map any salmonid species as occurring within North Lake, though the lake is noted as being stocked by the Washington Department of Fish and Wildlife with rainbow trout . The outlet for North Lake is also not mapped with salmon -presence, neither modeled nor actually present. Mapping of salmonids stops south of the Federal Way Campus property, well south of Highway 18. The apparent hindrances restricting salmonid migration into this area appear to be several not-fish-accessible culverts downstream outside of the FWC, LLC property. There is also a long stretch of pipe (roughly 1,600 linear feet) from the Weyerhaeuser pond, under the former Weyerhaeuser headquarters building, to its outlet just north of Highway 18, that is likely problematic for fish passage. Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 7 The potential for federally or state listed species occurring within either of the Sites is very low. There are no streams located on the Project Site within which salmonids could occur. No impacts within the ordinary high water mark for any stream or lake is proposed as part of this project. All stormwater will be treated prior to discharge and conveyance off-site. 4.6.2 Listed Species - Bald Eagles A bald eagle nest is mapped on the Washington Priority Habitat and Species database as occurring approximately 1,350 feet east of the Site. The location of this nest was field verified, though its use status was not. No eagles were observed in or near the nest at the time of survey through the winter of 2015 to summer 2017. The nest occurs on a large tree within a large wetland/upland complex located east of an office park, and is visible from the edge of the adjacent commercial office park. The nest occurs across Weyerhaeuser Way South from the Project Site, and on the opposite side of the office park from the Project Site. Bald eagles were removed from the federal endangered species list in 2007, and no longer are protected under the Endangered Species Act. Ho wever, bald eagles continue to be protected under the Bald and Golden Eagle Protection Act and the Migratory Bird Treaty Act. These Acts prohibit the “taking” of a bald eagle through direct or indirect actions that may disturb the birds enough to disrupt their breeding, foraging, or nesting behaviors. The existing office park and Weyerhaeuser Way South have been in place for many years, and occur between the Project Site and the mapped nest. Bald eagles are unlikely to be disturbed by Project Site given the regular use of existing facilities around the existing nest. No bald eagle nests occur within the Project Site. No foraging habitat occurs within the Project Site – both sites are too densely vegetated. Eagles are most likely to forage in and around North Lake or Weyerhaeuser Pond, or potentially within the open field areas located in the broad area. Bald eagles rarely hunt within densely wooded environments. It is possible eagles may use trees within the Site for roosting. However, given the number of large trees within the area, it is incredibly unlikely that the removal of the trees for this project will negatively affect the bald eagle. This project may affect but is not likely to adversely affect listed species. Lastly, coordination for federally listed species occurred through the US Army Corps of Engineers during the application process for NWP-2016-433, and the Project was determined to have no effect on listed species. Because the Project Sites are adjacent to each other, it is likely the Building B project will have the same no effects determination. CHAPTER 5. REGULATORY REVIEW 5.1 Federal and State Regulations Wetland impacts on the Project Site are subject to applicable State and Federal regulations. Wetland impacts are regulated on the Federal level by Sections 404 and 401 of the Clean Water Act. The US Army Corps of Engineers (Corps) is responsible for administering compliance with Section 404 via the issuance of Nationwide or Individual Permits for any fill or dredging activities within wetlands. Any project that is Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 8 subject to Section 404 permitting is also subject to requirements of Section 401 of the Clean Water Act (CWA), administered by the Department of Ecology (DOE). Because direct wetland impacts are proposed on the Project Site, the project would be required to comply with all Section 404 and 401 permitting requirements prior to any construction-related activities that would affect “waters of the US.” A permit application will be submitted to the Corps to address the proposed critical area impacts for Greenline Building B in conjunction with Greenline Building A. 5.2 City of Federal Way Permitting Approach The Weyerhaeuser Company entered into a pre-annexation zoning agreement with the City of Federal Way in 1994. This Concomitant Agreement transferred to the new property owners, FWC, LLC, upon their purchase of the property during the winter of 2015-2016. Through this purchase, the Concomitant Agreement and guidelines identified therein are applicable to the Greenline Building A project, including the specific language of the Concomitant Agreement with regard to wetlands, as well as the 1994 FWCC for Environmentally Sensitive Areas, Article XIV, Sections 22 -1221 through Sections 22-1369, particularly Sections 22-1357, 22-1358, 22-1359. While we have evaluated the Site using both the 1994 FWCC, as well as the current Federal Way City Code (FWCC), we will be using the 1994 FWCC to evaluate the potential impacts of this project to the onsite wetlands , so as to remain consistent with the existing Concomitant Agreement. This was confirmed by Brian Wilson (the former City of Federal Way Chief of Staff) via email to Jack McCullough (the Applicant’s land use attorney) on 6 June 2016. We feel that using the 1994 FWCC to evaluate critical area impacts still uses the best available science and will not provide lesser protections to those critical areas present compared to what is required at the Federal level. The Concomitant Agreement outlines exemptions from the 1994 FWCC, specifically exemptions from “the provisions of Section 22, Article XIV of the FWCC and requirements of this Agreement” including: 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 this property (Page C-16 of the Concomitant Agreement, Section XII.H.3). The 20-acre section of the property associated with the Greenline Building A application was previously identified as part of the Greenline Building A application. All wetlands potentially affected by this proposed project were previously addressed through the Greenline Building A application. Wetlands EC and EF were insufficiently buffered from the Greenline Building A site plan, and thus were included within the 10,000 square feet of wetlands to be impacted that were exempt from City of Federal Way regulations. Wetlands EC and EF will be filled as part of this proposed development, but since impacts to these wetlands were already addressed through the Greenline Building A project, no additional justification or compensation is provided within this current Greenline Building B application. As with all of the wetlands included within the 10,000 square feet of wetland impacts exempt from City regulations for Greenline Buildings A and B, these wetlands will be permitted, and mitigated for accordingly, through the Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 9 Corps and DOE permitting process. A copy of the issued permit will be provided to the City upon receipt by the Applicant. 5.2.1 Wetlands All wetlands under the 1994 FWCC have 100-foot standard buffers (Article XIV, Division 7, Section 22-1357). Buffer width reduction of up to 50% is allowable through buffer averaging with a minimum buffer width of 50 feet, as outlined in the Concomitant Agreement (Section XII.G.1). 5.2.2 Streams Stream EA is classified as a non-fish-bearing (minor) stream within Federal Way, which requires a standard 50-foot buffer according to 1994 FWCC (Article XIV, Division 5, Section 22-1306). Buffer width reduction is allowable through buffer averaging with a minimum buffer width of 25 feet, as outlined in the Concomitant Agreement (Section XII.F.1). This buffer is larger than what would be required under the current FW CC. This is an artificial feature that was constructed at some point after 2000. This stream shows poor substrate development, and is comprised mostly of leaf litter. The slopes of the channel were constructed as this feature is located at the toe of the slope from the utility easement that traverses this portion of the Project Site. CHAPTER 6. PROPOSED PROJECT 6.1 Proposed Project FWC, LLC is proposing to develop a general commodity building on 14.3 acres of CP- 01 zoned land (Sheet W1.1, Appendix A). The proposed building will be approximately 214,050 sf with associated infrastructure and parking. A stormwater quality control and detention pond will be constructed as an expansion to the Greenline Building A stormwater pond. Limited commercial vehicle ingress and egress access will be off Weyerhaeuser Way S with additional vehicular access points along Weyerhaeuser Loop Road. A 100-foot wide Managed Forest Buffer (MFB) along Weyerhaeuser Way S and along Highway 18 will be maintained consistent with the arborist-prepared management plan, as required by the Concomitant Agreement with the City. 6.2 Stormwater Treatment A stormwater quality control and detention pond is proposed south of the Site to address stormwater treatment and detention needs for the Project. Stormwater will be collected from the Site and conveyed to the stormwater facility with treated stormwater conveyed east to connect to the same outfall where the area drainage previously discharged under Highway 18. The stormwater facilities will be designed to meet current DOE Water Quality Standards. CHAPTER 7. ASSESSMENT OF DEVELOPMENT IMPACTS The proposed site plan has been designed to minimize impacts to critical areas to the greatest extent practicable while meeting the criteria for development of a viable project and conforming to the City of Federal Way standards and zoning. In attempting to avoid wetland impacts on this site, several different configurations were evaluated to find the best fit for the project needs. No other wetlands or streams occur within or adjacent to the Site that will be impacted that were not already addressed as part of Greenline Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 10 Building A. A buffer modification overview plan for that addresses cumulative Greenline Building A and B impacts is presented on Sheet W1.2 of Appendix A. 7.1 Wetland and Buffer Impact Analysis 7.1.1 Wetland Impacts Construction of this project will not impact any additional wetlands beyond those already addressed through the Greenline Building A application. While Wetlands EC and EF occur within the Site, these wetlands were included as wetland impact through the Greenline Building A project because they were insufficiently buffered in the post- development condition. While no mitigation is required to offset wetland impacts through the City of Federal Way, mitigation for these impacts will be addressed through Corps and DOE permitting. 7.1.2 Wetland Buffer Impact Analysis For permitting with the City of Federal Way, buffers will be applied consistent with the 1994 FWCC, which prescribes a standard 100-foot setback to all wetlands (Article XIV, Division 7, Section 22-1357). The 1994 FWCC uses the term “setback” rather than the currently accepted term “buffer”. This is different from building setbacks, which can be required in addition to standard wetland buffers. This buffer width will only be applied to wetlands remaining in the post-development condition. 7.1.3 Buffer Averaging Buffer averaging is allowed through the Concomitant Agreement as long as a minimum 50-foot buffer is retained (Section XII.G.1). Minor modifications to the buffer averaging proposed for Wetland DT through the Greenline Building A project are outlined below. No modifications to the Wetland DP buffers are required. Buffers for Wetland DT will be reduced to less than the standard 100-foot, but no less than 50-feet, to accommodate the proposed development. The reduced buffer areas will be replaced immediately adjacent to the existing buffers such that the total buffer areas in the post-development condition will be no less than the pre-development buffer areas. The averaged buffer replacement area will be located outside of the MFB as required by the City. 7.1.4 Land Surface Modifications within the Setback (buffer) Areas While development affecting wetlands is exempt from the regulations of the 1994 FWCC, disturbances to buffers of the non-impacted wetlands should follow the regulations outlined within the 1994 FWCC. In addition to the buffer averaging allowed through the Concomitant Agreement, Section 22-1359, Article XIV of the 1994 FWCC allows for land surface modifications within the setback areas from regulated wetlands. However, no restrictions are outlined within this Section beyond the following from subsection (d). These criteria (1 through 6) are reiterated below, followed by a response explaining how the proposed improvements are consistent with each criterion. 1. It will not adversely affect water quality. The clearing and grading work for site construction is not likely to adversely affect water quality. The potential affected wetland buffers have been reduced through buffer averaging so that minimum buffer widths are maintained and that the total area of wetland buffer will not be reduced . No toxic materials will be placed in the buffers as part of this work. Any fill associated with the grading will Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 11 be cut from other portions of the site or will be clean imported fill. Temporary erosion and sediment control (TESC) measures, such as silt fencing at the clearing and grading limits, will be installed pursuant to the TESC plan prepared by the civil engineer, which will protect the buffers and wetlands from construction site runoff. 2. It will not destroy nor damage a significant habitat area. The clearing and grading work is not likely to destroy or damage significant habitat area. There are no significant habitat areas within the Project Site. The Project Site currently supports third-growth coniferous forests that are not unique to this area. The Managed Forest Buffer adjacent to the Site will be enhanced in the post-development condition, thereby increasing the Site’s habitat value. 3. It will not adversely affect drainage or stormwater retention capabilities. The clearing and grading work is not likely to adversely affect the drainage or stormwater retention capabilities of the wetlands or buffers that occur adjacent to the Site. The proposed project will not result in any impediments or significant changes to the existing drainage patterns within the remaining wetlands or the buffers, and the existing surface drainage patterns will be maintained. A complete stormwater system is designed for the project that will handle all stormwater retention and detention. 4. It will not lead to unstable earth conditions nor create erosion hazards. The clearing and grading work is not likely to lead to unstable earth conditions or erosion hazards. Proper erosion and sediment control measures and best management practices will be implemented during all construction activities. The topography on the Project Site is generally gently sloping, though it will be graded relatively level to ensure proper grades for the large building and associated parking for both cars and large trucks. All disturbed soil areas will be temporarily stabilized with either three (3) inches of mulch or hydroseed approved by the TESC plan. 5. It will not be materially detrimental to any other property in the area of the subject property nor to the city as a whole, including the loss of significant open space or scenic vista. The clearing and grading work will not be materially detrimental to any other property in the area of the Project Site nor to the City as a whole. While this Site and some adjacent areas are currently undeveloped, the Site and adjacent parcels are zoned Corporate Park Zone (CP-01) per the Concomitant Agreement. This zoning allows for corporate offices, production and light assembly of goods, and warehousing and distribution, among others, which is consistent with the proposed building. The Project Site is located within a larger general area that contains some residential developments, especially along North Lake, as well as office parks. While the project will result in the loss of the existing coniferous forest on the interior of the Site, the project will maintain the Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 12 required 50-foot MFB along Weyerhaeuser Way S, adjusted to 100 feet along Highway 18, resulting in retained open space and habitat . 6. It is necessary for reasonable development of the subject property. The proposed project is a large building that requires a large rectangular footprint. This greatly limits the design flexibility during site development. The required truck access to the building and associated parking facilities have been integrated into the design as efficiently as possible taking into account critical areas and the required MFB. 7.2 Stream Impact Analysis 7.2.1 Stream Impacts No impacts to Stream EA are proposed with this project. 7.2.2 Stream Buffer Analysis For permitting with the City of Federal Way, buffers will be applied consistent with the 1994 FWCC, which prescribes a standard 50-foot setback to all minor streams (Article XIV, Division 5, Section 22-1306). The 1994 FWCC uses the term “setback” rather than the currently accepted term “buffer.” This is different from building setbacks, which can be required in addition to standard wetland buffers. 7.2.3 Buffer Averaging Buffer width reduction is allowable through buffer averaging with a minimum buffe r width of 25 feet, as outlined in the Concomitant Agreement (Section XII.F.1). Buffer averaging is proposed for Stream EA to compensate for lost buffer due to site development encroachments. The Stream EA buffer will be reduced to less than the standard 50-foot, but no less than 25-feet, to accommodate the proposed development. The reduced buffer will be replaced immediately adjacent to the existing buffers such that the total buffer area in the post-development condition will be no less than the pre- development buffer area. The averaged buffer replacement area will be located outside of the MFB as required by the City. CHAPTER 8. SUMMARY The Greenline Building B Site is a 14.3acre assemblage of CP-01 zoned land that occurs on one (1) parcel located in the City of Federal Way in King County, Washington. Existing gravel access roads, trails for passive recreation, and a utility easement are present onsite. Two (2) wetlands, Wetlands EC and EF, occur within the Site that were previously identified for impact as part of the Greenline Building A project. Wetlands DP and DT and Stream EA will remain within the Managed Forest Buffer that occurs adjacent to the Greenline Building B Site. All wetlands identified require a 100-foot setback per the 1994 FWCC. Stream EA requires a 50-foot setback as a minor stream per the 1994 FWCC. FWC, LLC is proposing to develop a general commodity building that will be approximately 214,050 square feet with associated infrastructure and parking. A stormwater quality control and detention pond are located to the south and is an Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 13 expansion of the Greenline Building A facility. Limited commercial vehicle ingress and egress access will be off Weyerhaeuser Way S near the interchange ramps for Highway 18, while additional vehicular access will be provided off Weyerhaeuser Loop Road . A 100-foot wide Managed Forest Buffer (MFB) along Weyerhaeuser Way S and Highway 18 will be maintained consistent with the arborist-prepared management plan, as required by the Concomitant Agreement with the City. Construction of the proposed development and stormwater pond will not impact any critical areas that have not already been addressed through the Greenline Building A application. Minor modifications to the proposed buffer reduction plan for Wetland DT and Stream EA are anticipated to accommodate the Site. Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Page 14 CHAPTER 9. REFERENCES Cowardin, L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of Wetlands and Deepwater Habitats of the United States. U.S. Fish and Wildlife Service, Department of the Interior. FWSOBS-70/31. Environmental Laboratory. 1987. Corps of Engineers Wetlands Delineation Manual. Technical Report Y-87-1, US Army Engineer Waterways Experiment Station, Vicksburg, Miss. Hitchcock, C.L., and A. Cronquist. 1973. Flora of the Pacific Northwest. University of Washington Press. 730 pp. Hruby, T. Washington State Wetland Rating System for Western Washington - Revised. Olympia, WA: Washington State Department of Ecology Publication #04- 06-025, 2008. Hruby, T. 2014. Washington State Wetland Rating System for Western Washington. 2014 Update. Washington State Department of Ecology Publication # 14-06-029. Lichvar, R.W. The National Wetland Plant List. ERDC/CRREL TR-12-11, Hanover, NH: U.S. Army Corps of Engineers, Cold Regions Research and Engineering Laboratory, 2012. Iowa State University. 1995. Hydric Soils of Washington State. U.S. Department of Agriculture, Natural Resources Conservation Service. December 5. Munsell Color. 1988. Munsell Soil Color Charts. Kollmorgen Instruments Corp., Baltimore, Maryland. Soil Survey Staff, Natural Resources Conservation Service, United States Department of Agriculture. Web Soil Survey. Available online at http://websoilsurvey.nrcs.usda.gov/. Accessed [April 2016]. U.S. Army Corps of Engineers. 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Western Mountains, Valleys, and Coast Region. Wetland Regulatory Assistance Program. ERDC/EL TR-10-3 U.S. Fish and Wildlife Service. 1989. National Wetlands Inventory Map, Poverty Bay Quadrangle. Washington State Department of Ecology. March 1997. Washington State Wetland Identification and Delineation Manual. Washington State Department of Ecology. Water Quality Assessment and 303(d) List. 2016. www.ecy.wa.gov/programs/wq/303d (accessed 2017). Washington State Department of Fish and Wildlife [Map Online], Olympia (WA): SalmonScape [February 24, 2017]. URL: <http//wdfw.wa.gov/mapping/salmonscape/index.html> Washington State Department of Fish and Wildlife. 2012. Priority Habitats and Species Database [online], Olympia, WA. [accessed February 2017]. <www.wdfw.wa.gov/mapping/phs/> Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx FIGURES FIGURES Figure 1. Vicinity Map and Driving Directions Figure 2. Site Aerial and Parcel Map Figure 3. USFWS National Wetlands Inventory Map Figure 4. NRCS Soils Map Figure 5. Historical Aerial (1957) Map Greenline Building B Critical Areas Report June 2018 Copyright © 2018 Talasaea Consultants, Inc. 1572F Greenline Building B CA Report.V2.docx Appendix A APPENDIX A BUFER AVERAGING PLAN SHEETS Sheet W1.0 Existing Conditions Plan Sheet W1.1 Proposed Site Plan, Impacts & Mitigation Overview Plan Sheet W1.2 Buffer Modification Overview Plan