012 Response to ESA CommentsResource Environmental Planning
15020 Bear Creek Road Northeast Woodinville, Washington 98077 Bus: (425)861-7550 Fax: (425)861-7549
26 June 2018
TAL-1572F
Stacey Welsh, AICP
Senior Planner
City of Federal Way Department of Community Development
33325 8th Avenue South
Federal Way, Washington 98003
REFERENCE: Critical Areas Report Review
Greenline Building B, Federal Way, Washington
File #17-104236UP & #17-104237-SE
SUBJECT: Response to Comments dated 13 December 2017
Dear Stacey:
In response to ESA’s comments regarding the Critical Areas Report: Greenline Warehouse B
dated 1 September 2017, we are providing the following responses. As is typical with our
procedure for response letters, we will be providing ESA comments verbatim in bold text.
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.
The Critical Areas Report has been revised to include the descriptions of the wetlands
whose buffers are being modified.
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 is 10,092 SF and surpasses
the allowed 10,000 SF of exempt impacts.
A survey error was noted and addressed. While an error of this small magnitude would
normally not be an issue, given the sensitive nature of this Project and the impact
threshold, it became more important to address the error.
Stacey Welsh
26 June 2018
Page 2 of 3
Resource Environmental Planning
15020 Bear Creek Road Northeast Woodinville, Washington 98077 Bus: (425)861-7550 Fax: (425)861-7549
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.
That was an error on our part that has been corrected. Please see revised Sheet W1.1
for the updated reduction/replacement buffer areas. There is a net gain for both wetland
and stream buffers.
The CAR for Warehouse B does not include a planting plan.
Areas of temporary construction impacts have been removed from the Site Plan,
consistent with previous direction given for Greenline Building A, so that no planting plan
is currently required. Buffers will be modified through reductions consistent with the
Concomitant Agreement and replaced outside of the Managed Forest Buffer at a
minimum of a 1:1 ratio.
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.
The discrepancy has been corrected. No temporary construction impacts are shown on
the plans. Also, please note that the Critical Areas Report addresses wetlands, streams,
and their buffers, while the Management Plan is prepared by the Arborist. The intent
and purpose of each report differs.
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.
Sheet W1.3 was only provided within the Managed Forest Buffer Management Plan and
was an older graphic that has since been removed from Talasaea documents. There
are existing trails and gravel roads across the Site, some of which will remain in the
developed condition. Some portions of these gravel roads and trails may be restored to
a forested condition as part of the management of the Managed Forest Buffer. Please
see the Arborist Report for details. Trail restoration is not part of the Critical Areas
Review, despite the referenced graphic being produced by Talasaea Consultants.
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.
Stacey Welsh
26 June 2018
Page 3 of 3
Resource Environmental Planning
15020 Bear Creek Road Northeast Woodinville, Washington 98077 Bus: (425)861-7550 Fax: (425)861-7549
Please note that the Arborist Report was using older graphics that relayed the pertinent
information for the purposes of the tree evaluation, but that was not applicable to the
critical areas evaluation on-site.
Greenline Buildings A and B are separate projects, but it is assumed that Building B will
only ever be constructed after Building A, never before or without Building A. For that
reason, the Building A built condition is considered to be the existing condition for
Building B. The Managed Forest Buffer remains the same for both Buildings A and B.
All wetland impacts are occurring as part of Building A. Some buffer modification to off-
site critical areas (Wetland DT and Stream EA) are occurring as part of the Building A
application to accommodate the required stormwater drainage easement. These same
buffers will be modified a second time slightly to accommodate the edge of the Greenline
Building B development.
We trust that the information presented here sufficiently answers your comments pertaining to
this project. If you have additional questions or require more information, please contact Bill
Shiels or me at (425) 861-7550.
Thank you.
Sincerely,
TALASAEA CONSULTANTS, INC.
for Jennifer M. Marriott, PWS
Senior Ecologist
cc: Mr. Tom Messmer, FWC, LLC
File