17-104237-Built Environment Survey-07-30-2020-V1
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Cardno, Inc.
801 Second Ave
Suite 1150 Seattle, WA 98104
USA
Phone 206 269 0104
Fax 206 269 0098
www.cardno.com
Memorandum
Date: July 27, 2020
To: Dana A. Ostenson
Executive Vice President
Industrial Realty Group, LLC
11111 Santa Monica Boulevard
Suite 800
Los Angeles, CA 90025
From: Michelle Sadlier
Architectural Historian
RE:
Built Environment Survey of the Former Weyerhaeuser Corporate
Headquarters Campus for Compliance with Section 106 of the NHPA –
Comments on SEPA Compliance for Woodbridge Building B
Cardno has completed a Built Environment Survey of the Former Weyerhaeuser Corporate
Headquarters Campus, Federal Way, Washington, July 2020 (Survey). This Survey was
prepared under Section 106 of the National Historic Preservation Act (NHPA) for submission to
the U.S. Army Corps of Engineers in connection with its permitting activity under Section 404 of
the Clean Water Act. The Survey identifies a historic district (District) on the former
Weyerhaeuser Corporate Headquarters property that is recommended eligible for listing in the
National Register of Historic Places (NRHP) under the standards of 36 CFR Section 60.4. The
Survey also identifies features that are recommended as contributing to the historical
significance of the District and those that are recommended as noncontributing. The survey is
provided solely for compliance with Section 106 of the NHPA and does not result in the listing of
the recommended NRHP-eligible District in the NRHP.
The Survey was not prepared for purposes of compliance with the State Environmental Policy
Act (SEPA) and does not evaluate the significance of impacts under SEPA. The purpose of this
memorandum is to provide our opinion regarding the significance of impacts to historic resources
under SEPA resulting from the proposal known as Woodbridge Building B. Note that the
definitions of terms in Section 106 of the NHPA and SEPA regulations are different. The SEPA
regulations include “historic and cultural preservation” as an element of the environment. The
definition of an “environmental impact” is an effect on the elements of the
environment. “Significant” means more than a reasonable likelihood of more than a moderate
adverse impact on environmental quality.
We have analyzed the Woodbridge Building B proposal with regard to historic resources under
SEPA. On the Building B property, the only feature identified in the Survey as contributing to the
recommended NRHP-eligible District is the 50-foot tree buffer adjacent to Weyerhaeuser Road
as it relates to the experience of a driver on Weyerhaeuser Road. The Building B site plan
shows that the project preserves a 50-foot or greater tree buffer adjacent to Weyerhaeuser
Road. Based on these factors, we conclude that the Building B proposal will not result in
significant adverse impacts to the recommended NRHP-eligible District as defined under SEPA.