MDNS Signed
Mitigated Determination of Nonsignificance (MDNS) Page 1 of 8
Woodbridge Building “B” 17-104237-00-SE / Doc. I.D. 80801
STATE ENVIRONMENTAL POLICY ACT
MITIGATED DETERMINATION OF NONSIGNIFICANCE
(MDNS)
Woodbridge Building “B” (formerly Greenline Warehouse “B”)
File No: 17-104237-SE
Description of
Proposal: Construction of a 45-foot-tall, 214,050 square-foot general commodity warehouse with
245 parking spaces and associated site work, including wetland fill, on a 16.85-acre site
(parcel 6142600200), along with improvements to the right-of-way for Weyerhaeuser
Way South.
Proponent: Federal Way Campus LLC
11100 Santa Monica Blvd, Suite 850
Los Angeles, CA 90025
Location: 3120 South 344th Street, Federal Way, WA
Lead Agency: City of Federal Way
City Staff
Contact: Principal Planner Stacey Welsh, AICP
253-835-2634, stacey.welsh@cityoffederalway.com
The Responsible Official of the City of Federal Way hereby makes the following decision based upon
impacts identified in the environmental checklist, Federal Way Comprehensive Plan, Staff Evaluation for
Environmental Checklist, and other municipal policies, plans, rules, and regulations designated as a basis
for exercise of substantive authority under the Washington State Environmental Policy Act Rules pursuant
to RCW 43.31C.060.
The lead agency has determined that this proposal will not have a probable significant adverse impact on
the environment. Pursuant to WAC 197-11-350(3), the proposal has been clarified, changed, and
conditioned to include necessary mitigation measures to avoid, minimize, or compensate for probable
significant impacts. An environmental impact statement (EIS) is not required under RCW 43.21C.030(2)(c).
The necessary mitigation measures are listed below. This decision was made after review of a completed
environmental checklist (enclosed) and other information on file with the lead agency. This information is
available to the public by request or on the city website: https://www.cityoffederalway.com/node/1962.
This determination is based on the following findings and conclusions:
Mitigated Determination of Nonsignificance (MDNS) Page 2 of 8
Woodbridge Building “B” 17-104237-00-SE / Doc. I.D. 80801
FINDINGS OF FACT
1. The Woodbridge Building “B” project is for construction of a 45-foot-tall, 214,050 square-foot
general commodity warehouse with 245 parking spaces and associated site work, including wetland
fill, on a 16.85-acre site (parcel 6142600200), along with improvements to the right-of-way for
Weyerhaeuser Way South.
2. The proposal is subject to the provisions of the 1994 Weyerhaeuser Company Concomitant Pre-
Annexation Development Agreement (CZA) and zoning regulations in effect on August 23, 1994
(Federal Way City Code [FWCC]). Any procedural requirements must meet current code (Federal
Way Revised Code [FWRC]). Zoning for the subject property is Corporate Park (CP-1). Warehousing,
distribution, and corporate offices are permitted uses in the CP-1 zone pursuant to CZA Exhibit C,
Section VII, “Permitted Uses on Those Portions of the CP-1 Zoned Property Lying Outside the
Managed Forest Buffer.” The Federal Way Comprehensive Plan (FWCP) designation for the subject
property is Corporate Park.
3. The applicant submitted an air quality report prepared by Ramboll Environ, June 2018. The report
describes sources of air pollution typical of a general commodities warehouse, including emergency
generators and vehicles used by employee commuter trips and truck deliveries. The report states,
“With implementation of required measures to provide reasonable controls of dust and odors,
construction of the proposed project would not be expected to result in significant air quality
impacts.” Regarding operation of the project, the report states, “The analyses described above
indicate the proposed project would be unlikely to result in any significant air quality impacts.
Consequently, no operational mitigation measures are warranted or proposed.”
4. The applicant submitted a noise report prepared by Ramboll Environ, July 2018. The report
concluded, “The assessment found that operation of the proposed Project would result in acoustically
negligible increases in ambient noise at nearby residential receivers, and between no increase and
very minor increases at nearby commercial receivers. The proposed Project would be within
compliance of applicable noise limits at all nearby residential and commercial receivers.” The report
lists measures to reduce the potential for high levels of noise from construction equipment or
activities. Regarding operation of the project, the report states, “Noise mitigation measures are not
warranted at this time.”
5. The applicant submitted a traffic study, IRG Greenline Buildings A and B Federal Way, WA
Transportation Impact Study, TENW Transportation Engineering NorthWest, March 6, 2018. The
traffic study stated that all truck trips are expected to utilize the primary driveway on Weyerhaeuser
Way South, and all truck trips will be traveling to and from the south using the Weyerhaeuser Way
South/SR-18 interchange and therefore, study mitigation or improvements were not required for other
road segments. The traffic study does not however, demonstrate how the applicant will prevent trucks
entering or exiting the facility from allowing this travel. Without adequate supporting documentation/
planning, there is nothing prohibiting trucks from utilizing the South 320th Street/SR-5 interchange,
South 336th Street, and Weyerhaeuser Way South as an alternate route to the site. Based on the above,
the applicant has not demonstrated mitigation of additional truck traffic onto non-designated truck
routes, such as Weyerhaeuser Way South north of the site, including impacts to the pavement.
6. The applicant submitted a pavement analysis for Weyerhaeuser Way South, Geotechnical
Engineering Services Report Weyerhaeuser Way South, 320th Street to SR 18 Weyerhaeuser Campus
Property Federal Way, Washington, GeoEngineers, August 29, 2017. Per the pavement analysis, the
development is expected to nearly triple the loading on the existing pavement (EASLs) along the
Mitigated Determination of Nonsignificance (MDNS) Page 3 of 8
Woodbridge Building “B” 17-104237-00-SE / Doc. I.D. 80801
truck route on Weyerhaeuser Way South. Furthermore, the pavement in the project area is
approaching the end of its useable life. The Public Works Street Division reviewed the pavement
analysis and determined that the existing pavement on Weyerhaeuser Way South along the truck
route must be fully reconstructed (subgrade soils and new pavement) to accommodate the expected
truck traffic load.
7. The SR-18 ramp terminal intersections are under Washington State Department of Transportation
(WSDOT) control and are subject to WSDOT’s established standards. The traffic study prepared by
TENW for Woodbridge Building “A” (formerly Greenline Warehouse “A”) was revised to address
WSDOT comments pertaining to a LOS and queuing analysis at the SR-18 ramp terminal
intersections. After the MDNS for Woodbridge Building “A” was issued, WSDOT identified and
requested mitigation for the westbound SR-18 off-ramp right-turn storage. Due to additional trips
generated by the project impacting this intersection, the 95th percentile queues length for the AM peak
hour would exceed the available right-turn storage. As such, WSDOT requested that the westbound
SR-18 off-ramp right-turn storage be extended from the existing 100 feet to 300 feet. A Modified
MDNS was issued for Woodbridge Building “A” to include that mitigation measure. WSDOT
confirmed in May 2019 that they reviewed the traffic study for both Warehouses “A” and “B,” and
the mitigation measure was for both Warehouses “A” and “B.” The mitigation measure regarding the
SR-18 off-ramp right-turn storage applies to Woodbridge Building “B.”
8. In accordance with the October 29, 2019, Hearing Examiner’s Request for Reconsideration Decision
for Greenline Warehouse “A,” the following shall be made a SEPA mitigation measure: Cumulative
traffic impacts from Warehouses “A” and “B,” and the Greenline Business Park to the SR 18
westbound ramp intersection with Weyerhaeuser Way South shall be evaluated and mitigated in a
SEPA analysis addendum and/or revision to the Warehouses “A” and “B” TIA. PM peak hour
cumulative impacts shall be included in the TIA analysis, or added to the concurrency review for
Warehouse “A,” as the city finds most consistent with its regulations. The city shall determine if
WSDOT has jurisdiction over the SR 18 intersection. If WSDOT has jurisdiction over the SR 18
intersection, WSDOT LOS standards shall be applied to the intersection and any necessary pro-
rata mitigation for Warehouse “A” shall be formulated in consultation with WSDOT, as
contemplated in Conclusion of Law No. 8 of the Final Decision. If WSDOT doesn’t have
jurisdiction over the intersection, the city LOS standards shall be applied, and pro-rata mitigation
for Warehouse “A” imposed as necessary. All mitigation shall be subject to RCW 82.02.020 and
constitutional nexus/proportionality.
9. The project requires review under Process III, Project Approval. The Director of Community
Development makes a written decision on the application based on the criteria listed under FWRC
19.65.100. A city staff report will be prepared for the project decision that will address additional
topic areas.
10. Cumulative Impacts Analysis –Woodbridge Building “B” is proposed on parcel 6142600200. A
separate project, Woodbridge Building “A” (formerly Greenline Warehouse “A”) located on parcels
6142600005 and 6142600200, received land use approval in February 2019. The SEPA threshold
determination and land use decision were appealed. The Hearing Examiner denied the appeal and
sustained the Use Process III decision and MDNS with the addition of two conditions pertaining to
traffic and stormwater. A Request for Reconsideration was filed and the Hearing Examiner revised
the two conditions. The Hearing Examiner’s decision was appealed to Superior Court. Superior Court
denied the appeals and affirmed the Hearing Examiner’s Decision on June 10, 2020.
Mitigated Determination of Nonsignificance (MDNS) Page 4 of 8
Woodbridge Building “B” 17-104237-00-SE / Doc. I.D. 80801
The two projects will utilize a common driveway access off of Weyerhaeuser Way South and the
same stormwater pond located on parcel 6142600200; although, the addition of Building “B” requires
the pond to be enlarged from its size if it only served Building “A.” There are no other cumulative
impacts on the Woodbridge Building “B” project. The city has not received indication from the
applicant that the two projects will be constructed simultaneously; therefore, there is no cumulative
impacts analysis regarding construction.
The city evaluated the projects for cumulative impacts and identified and analyzed those parts of the
projects that implicate such impacts in this determination. As part of the project review, the city
evaluated Building “B” with regard to FWRC 19.100.030(2). The projects share a parcel in common,
6142600200. Cumulative impact review is incorporated into many city development regulations. The
analysis of cumulative impacts for Woodbridge Building “B” is reflected throughout this determination
and the forthcoming land use decision.
Many of the project submittal documents for Woodbridge Building “B” reference Woodbridge
Building “A,” in particular:
a) IRG Greenline Buildings A and B, Federal Way, WA Transportation Impact Study, TENW
Transportation Engineering NorthWest, March 6, 2018:
a. The LOS and queuing analysis for Woodbridge Building “B” included trips from
Woodbridge Building “A.”
b) Critical Areas Report Files #17-104236-UP & #17-104237-SE, Greenline Building B, Federal
Way, Washington, Talasaea Consultants, Inc., revised June 26, 2018.
c) Greenline Building B Preliminary Technical Information Report, ESM Consulting Engineers
LLC, June 28, 2018.
d) Greenline Building B Visual Impact Analysis, ESM Consulting Engineers LLC, August 10, 2018.
e) Vision Analysis Greenline Building B, ESM Consulting Engineers LLC, October 9, 2018.
In addition, regarding WAC 197-11-060(3)(b), Woodbridge Building “B” can proceed without
Woodbridge Building “A” and is not reliant upon Woodbridge Building “A” taking place in order to
proceed. Woodbridge Building “B” does not depend on Woodbridge Building “A” as justification for
its implementation and the projects are not interdependent parts of a larger proposal. In other words,
Woodbridge Building “B” and Woodbridge Building “A” do not meet the WAC 197-11-060(3)(b)
threshold to require evaluation of the two projects in the same environmental document.
Another separate project, the Woodbridge Corporate Park (WCP) (formerly Greenline Business
Park), was submitted in November 2017. The WCP is proposed on other parcels within the former
Weyerhaeuser Campus. The WCP does not propose to share a common parcel, access point, or utility
facilities with Woodbridge Buildings “A” or “B.” Regarding WAC 197-11-060(3)(b), Woodbridge
Buildings “A” and “B” can proceed without the WCP and are not reliant upon the WCP taking place
in order to proceed themselves. Woodbridge Buildings “A” and “B” are not interdependent parts of
the WCP and do not depend on the WCP as justification for their implementation. The WCP does not
meet the WAC 197-11-060(3)(b) threshold to require the evaluation of the other projects in the same
environmental document.
11. The “Staff Evaluation for Environmental Checklist, File No. 17-104237-SE” is hereby incorporated
by reference as though set forth in full.
Mitigated Determination of Nonsignificance (MDNS) Page 5 of 8
Woodbridge Building “B” 17-104237-00-SE / Doc. I.D. 80801
CONCLUSIONS OF LAW
Federal Way’s comprehensive plan policies contained within the FWCP, serve as a basis for the exercise
of substantive SEPA authority to approve, condition, or deny proposed actions applicable to potential
adverse environmental impacts resulting from this project. The following components of the FWCP
(revised 2015) support the conditions for the development.
NEP10 The City may continue to require environmental studies by qualified professionals to assess the
impact and recommend appropriate mitigation of proposed development on environmentally critical
areas and areas that may be contaminated or development that may potentially cause contamination.
NEP86 Support state and federal air quality standards and the regulation of activities that emit air
pollutants.
NEP87 Utilize building design, construction, and technology techniques to mitigate the negative
effects of air pollution on indoor air quality for uses near sources of pollution such as Interstate-5.
NEP102 The City will evaluate potential noise impacts associated with non-residential uses and
activities located in residential areas as part of the site plan review process.
TP1.11 Develop code requirements and a designated truck route system that accommodates the needs
of the private sector and residents, and provides a balance between movement needs and quality of life.
TP1.12 Discourage the use of road facilities by vehicles carrying hazardous materials and those with
weight, size, or other characteristics that would be injurious to people and property in the City.
TP3.15 Develop access management standards to minimize the number of curb cuts on arterials to
improve pedestrian and vehicle safety.
TP3.18 Incorporate environmental factors into transportation decision-making, including attention to
human health and safety.
SEPA CONDITIONS
Based on the above policy, the following mitigation measures are required to minimize identified
potential significant adverse environmental impacts.
1) Prior to building permit issuance, the applicant shall submit an evaluation of the facility design by a
qualified professional to ensure that the types and numbers of equipment to be installed at the
warehouse, as well as warehouse activities, are consistent or similar to those identified in the noise
report (Greenline Building “B” Development, Federal Way Washington Environmental Noise Report,
Ramboll Environ, July 2018).
2) The following measures shall be implemented during project construction with quarterly reports
submitted by the applicant to the city documenting compliance starting from the issuance of the
building permit and concluding at the issuance of a Certificate of Occupancy:
a) All equipment shall be fitted with properly sized mufflers, and if necessary, engine intake silencers.
b) All equipment shall be in good working order.
c) Use quieter construction equipment models if available and whenever possible use pneumatic
tools rather than diesel or gas-powered tools.
Mitigated Determination of Nonsignificance (MDNS) Page 6 of 8
Woodbridge Building “B” 17-104237-00-SE / Doc. I.D. 80801
d) Place portable stationary equipment as far as possible from existing residential and noise-sensitive
commercial areas, and if necessary, place temporary barriers around stationary equipment.
e) For mobile equipment, consider placement of typical fixed pure-tone backup alarms with
ambient-sensing and/or broadband backup alarms.
3) A detailed review of final operating conditions shall be completed to ensure that the noise study
accurately and conservatively reflects future project operation. A report documenting the assessment
shall be submitted to the city six months after the Certificate of Occupancy is issued.
4) If the proposed use of the building includes cold storage, processing, or manufacturing, the air quality
analysis (Greenline Building “B” Development, Federal Way Washington Air Quality Report,
Ramboll Environ, June 2018) must be revised and SEPA threshold determination revisited prior to
building permit issuance, or if no building permit is required, then prior to business license issuance.
5) The following measures shall be implemented during project construction with quarterly reports
submitted by the applicant to the city documenting compliance starting from the issuance of the
building permit and concluding at issuance of the Certificate of Occupancy:
a) Use only equipment and trucks that are maintained in optimal operational condition.
b) Require all off road equipment to be retrofit with emission reduction equipment (i.e., require
participation in Puget Sound region Diesel Solutions by project sponsors and contractors),
including particulate matter traps and oxidation catalysts to reduce MSATs.
c) Use biodiesel or other lower-emission fuels for vehicles and equipment.
d) Use carpooling or other trip reduction strategies for construction workers when possible.
e) Stage construction to minimize overall transportation system congestion and delays to reduce
regional emissions of pollutants during construction.
f) Implement restrictions on construction truck idling (e.g., limit idling to a maximum of five minutes).
g) Locate construction equipment away from sensitive receptors, such as fresh air intakes to buildings,
air conditioners, and sensitive populations.
h) Locate construction staging zones where diesel emissions won't be noticeable to the public or
near sensitive populations, such as the elderly and the young.
i) Spray exposed soil with water or other suppressant to reduce emissions of PM10 and deposition of
particulate matter.
j) Pave or use gravel on staging areas and roads that would be exposed for long periods.
k) Cover all trucks transporting materials, wet materials in trucks, or provide adequate freeboard
(space from the top of the material to the top of the truck bed), to reduce PM10 emissions and
deposition during transport.
l) Provide wheel washers to remove particulate matter that would otherwise be carried off site by
vehicles to decrease deposition of particulate matter on area roadways.
m) Remove particulate matter deposited on paved, public roads, sidewalks, and bicycle and pedestrian
paths to reduce mud and dust; sweep and wash streets continuously to reduce emissions.
n) Cover dirt, gravel, and debris piles as needed to reduce dust and wind-blown debris.
o) Route and schedule construction trucks to reduce delays to traffic during peak travel times to
reduce air quality impacts caused by a reduction in traffic speeds.
Mitigated Determination of Nonsignificance (MDNS) Page 7 of 8
Woodbridge Building “B” 17-104237-00-SE / Doc. I.D. 80801
6) Prior to issuance of a Certificate of Occupancy, the applicant shall construct a northbound left-turn
lane on Weyerhaeuser Way South at the southerly driveway (truck access) to provide safer and more
efficient access into the site. The northbound left (NBL) turn lane storage shall be designed to
accommodate the 95th Percentile queues length ensuring left-turn queues will not block the through
traffic lane. The channelization plan must be reviewed and approved by the city and WSDOT.
7) Prior to building permit issuance, the applicant shall install weight limit signs on Weyerhaeuser Way
South from South 320th Street to the project driveway, and South 336th Street from 20th Avenue South
to Weyerhaeuser Way South.
8) The applicant submitted a traffic study, IRG Greenline Buildings A and B Federal Way, WA
Transportation Impact Study, TENW Transportation Engineering NorthWest, March 6, 2018. The
development is estimated to generate 954 daily trips with 97 trips occurring during the PM peak hour
(78 passenger and 19 truck). These trips will be served by two driveways (private loop road driveway
north of the site and truck access driveway next to SR 18) on Weyerhaeuser Way South. According to
the traffic study, all truck trips will utilize the proposed truck access driveway on Weyerhaeuser Way
South and will be traveling to and from the south using the Weyerhaeuser Way South/SR-18
interchange. On a daily basis, I-5 southbound congestion routinely occurs between the SR 18 and
South 320th Street interchange. In order to avoid traffic congestion and reduce travel time due to the
shorter distance, truck trips with origin and destination from the north could utilize South 320th
Street/SR-5 interchange, South 336th Street, and Weyerhaeuser Way South as an alternate route to the
site. The traffic study has not demonstrated how the applicant will prevent this alternative truck route
(South 320th Street /SR-5 interchange, South 336th Street, and Weyerhaeuser Way South) to the site.
Weyerhaeuser Way South from South 320th Street and SR 18 is not a designated truck route and
therefore, the roadway cannot support heavy vehicle weights. In general, heavier vehicles cause more
damaged to the road than light vehicles. The federal government estimated that an 18-wheel truck
causes the same damage to the road as 9,600 cars. Based on the above, the applicant has not
demonstrated mitigation of additional truck traffic onto non-designated truck routes such as
Weyerhaeuser Way South north of the site, including impacts to the pavement.
As such, prior to the Certificate of Occupancy issuance, the applicant shall provide a fully executed
bond for 120 percent of the engineer’s estimate for design and construction costs to upgrade the
existing pavement on Weyerhaeuser Way South, from the proposed truck entrance to South 320th
Street. The bond term shall be for a period of three years from the time of notification by the
applicant of full occupancy and use of the facility, unless a shorter term is mutually agreed to in the
implementation agreement discussed below. The applicant shall provide the engineer’s estimate.
Should the truck trips generated by the project traveling north of the site (to or from the site) exceed
28 truck trips per week as set forth in the implementation agreement discussed below, the city will
use the bond for design and construction costs to upgrade the existing pavement on Weyerhaeuser
Way South, from the proposed truck entrance to South 320th Street, and/or from the proposed truck
entrance to SR-99 via South 336th Street, to the city’s required design standards. In the alternative, the
applicant may choose to design and construct the implicated roadway(s) identified by the city. For the
purposes of this condition, a “truck” shall mean a vehicle rated in excess of 30,000 pounds gross
weight as discussed in Chapter 8.40 FWRC.
Prior to building permit issuance, the applicant and the city shall enter into an implementation
agreement to set forth the conditions by which the city will monitor the truck trips; how the city will
make its determination that the applicant has exceeded the 28 or more truck trips per week; how notice
Mitigated Determination of Nonsignificance (MDNS) Page 8 of 8
Woodbridge Building “B” 17-104237-00-SE / Doc. I.D. 80801
will be provided to the applicant; the cure period for the applicant to remedy the excess truck trips
described in the above condition; when the city will call the bond or require the applicant to construct
the implicated roadways; the bond conditions; and all other requirements deemed necessary by the city.
9) The existing pavement on Weyerhaeuser Way South (south of the site), from the proposed truck
entrance to the SR-18 interchange must be fully reconstructed (subgrade soils and new pavement) to
accommodate the expected truck traffic load. The applicant shall provide pavement design for city
review and approval prior to engineering plans submittal. Once the pavement design is approved by
the city, the development shall perform full depth reconstruction of the roadway segment impacted by
the truck traffic.
10) Prior to issuance of a certificate of occupancy, the applicant shall construct right-turn storage for the
westbound SR-18 off-ramp to mitigate for the impact to the westbound off-ramp to the satisfaction
and with approval of WSDOT.
11) Cumulative traffic impacts from Warehouses A and B and the Greenline Business Park to the SR
18 westbound ramp intersection with Weyerhaeuser Way South shall be evaluated and mitigated
in a SEPA analysis addendum, and/or revision to the Warehouses A and B TIA. PM peak hour
cumulative impacts shall be included in the TIA analysis, or added to the concurrency review for
Warehouse A, as the city finds most consistent with its regulations. The city shall determine if
WSDOT has jurisdiction over the SR 18 intersection. If WSDOT has jurisdiction over the SR 18
intersection, WSDOT LOS standards shall be applied to the intersection and any necessary pro-
rata mitigation for Warehouse A shall be formulated in consultation with WSDOT, as
contemplated in Conclusion of Law No. 8 of the Final Decision. If WSDOT doesn’t have
jurisdiction over the intersection, city LOS standards shall be applied and pro-rata mitigation for
Warehouse A imposed as necessary. All mitigation shall be subject to RCW 82.02.020 and
constitutional nexus/proportionality.
This MDNS is issued under WAC 197-11-340(2); the lead agency will not act on this proposal for 14
days from the date of issuance. Comments must be submitted by 5:00 p.m. on October 23, 2020. Email
comments should be directed to planning@cityoffederalway.com.
Unless modified by the city, this determination will become final following the above comment deadline.
Any person aggrieved of the city’s final determination may file an appeal. Anyone may appeal this
determination to the Federal Way City Clerk (address below), no later than 5:00 p.m. on November 13,
2020, by a written letter stating the reason for the appeal of the determination, along with the required
appeal fee. You should be prepared to make specific factual objections. All appeals shall contain a
specific statement of reasons why the decision of the responsible official is alleged to be in error.
Responsible Official: Brian Davis
Position/Title: Community Development Director
Address: 33325 8th Avenue South, Federal Way, WA 98003
Contact: 253-835-2633, brian.davis@cityoffederalway.com
Date Issued: October 9, 2020 Signature: ___Digitally Signed October 9, 2020, at 9:39 AM________