Staff Evaluation
Staff Evaluation for Environmental Checklist Page 1 of 11
Woodbridge Building “B” 17-104237-SE / Doc ID 80803
Department of Community Development
STAFF EVALUATION
FOR ENVIRONMENTAL CHECKLIST
Woodbridge Building “B”
Federal Way File: 17-104237-SE
Related Files: 17-104236-UP, 17-104239-CN, & 18-102212-SM
NOTE: Technical reports and attachments referenced below may not be enclosed with all copies of this evaluation.
Documents are available for review; contact Principal Planner Stacey Welsh, Department of Community Development,
33325 8th Avenue South, Federal Way, WA 98003, 253-835-2634, or stacey.welsh@cityoffederalway.com. This
information is available to the public by request or on the city website: https://www.cityoffederalway.com/node/1962.
I. SUMMARY OF PROPOSED ACTION
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 (Exhibit A).
II. GENERAL INFORMATION
Project Name: Woodbridge Building “B” (formerly Greenline Warehouse “B”)
Applicant: Federal Way Campus LLC
11100 Santa Monica Blvd, Suite 850
Los Angeles, CA 90025
Phone: (310) 806-4434
Applicant’s
Agent: Eric LaBrie
ESM Consulting Engineers, LLC
33400 8th Avenue South, Suite 205
Federal Way, WA 98003
Phone: (253) 838-6113
Location: 3120 South 344th Street, Federal Way, WA (Exhibit B)
Parcel: 614260-0200
Zoning: Corporate Park (CP-1)
Comp Plan
Designation: Corporate Park
Staff Evaluation for Environmental Checklist Page 2 of 11
Woodbridge Building “B” 17-104237-SE / Doc ID 80803
The following information was submitted as part of the application for review. The most recent versions
of documents are listed below, as some documents have been revised and submitted multiple times.
1. 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, July 27, 2020
2. Federal Way Campus, LLC Renaming of Current Land Use Projects, ESM Consulting
Engineers LLC, February 8, 2019
3. Vision Analysis Greenline Building B, ESM Consulting Engineers LLC, October 9, 2018
4. Resubmittal File No.’s 17-104236-UP & 17-204237-SE, Greenline Building B, ESM
Consulting Engineers LLC, August 15, 2018
5. Environmental Checklist, signed by Matt Reider, August 10, 2018
6. Greenline Building B Visual Impact Analysis, ESM Consulting Engineers LLC, August 10, 2018
7. Greenline Building “B” Development, Federal Way, Washington, Air Quality Report,
Ramboll Environ US Corporation, June 2018
8. Greenline Building “B” Development, Federal Way, Washington Environmental Noise Report,
Ramboll Environ US Corporation, July 2018
9. Technical Review Comments, ESM Consulting Engineers LLC, June 28, 2018
10. Project #TAL-1593, Tetra Tech, received June 28, 2018
11. Greenline Building B Preliminary Technical Information Report, ESM Consulting Engineers
LLC, June 28, 2018
12. Buffer Averaging Plan Wetland Exemption Exhibit Sheet W1.1, Talasaea Consultants, Inc.,
received June 28, 2018
13. Design Narrative and Process III Decisional Criteria, ESM Consulting Engineers, June 27, 2018
14. Managed Forest Buffer Management Plan At the Greenline Building B Site Weyerhaeuser
Way South, Federal Way, WA 98003, Gilles Consulting, revised June 26, 2018
15. Evaluation of Interior Trees at the Greenline Building B Site Weyerhaeuser Way South, Federal
Way, WA 98003, Gilles Consulting, revised June 26, 2018
16. Tree Data for 32 Acre Site, Weyerhaeuser Way South, Federal Way, WA, Gilles Consulting,
June 26, 2018
17. Response to Comments dated 13 December 2017, Talasaea Consultants, Inc., June 26, 2018
18. Critical Areas Report Files #17-104236-UP & File #17-104237-SE, Greenline Building B
Federal Way, Washington, Talasaea Consultants, Inc., revised June 26, 2018
19. Revised Geotechnical Engineering Services Report Proposed Greenline Building B Development,
Federal Way, Washington, GeoEngineers, June 21, 2018
20. Impervious Area Exhibit Sheet EN-02, ESM Consulting Engineers LLC, June 18, 2018
21. Design Brief, Exterior Elevations & Perspectives Sheet A1.0, by Craft Architects, June 18, 2018
22. Building Elevations Sheet A1.1, Craft Architects, June 18, 2018
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Woodbridge Building “B” 17-104237-SE / Doc ID 80803
23. Site Plan Sheet ST-01; Existing Conditions Sheet EX-01; Legend Sheet LG-01; Preliminary
Drainage Grading and ROW Plan Sheet SD-01, Preliminary Landscape Plan Sheets LA-01;
Landscape Details and Notes Sheet LA-02; Frontage Plan Sheet LA-03Clearing and Grading
Plan Sheet GR-01; Site and Road Cross Sections Sheet GR-02; Truck Movement Study Sheets
DT-01 & DT-02, and Tree/Vegetation Retention Plan Sheet TR-01, ESM Consulting
Engineers LLC, June 18, 2018
24. IRG Greenline Buildings A and B Federal Way, WA Transportation Impact Study, TENW
Transportation Engineering NorthWest, March 6, 2018
25. Preapplication Conference Summary, City of Federal Way, September 8, 2017
26. Master Land Use Application, received September 1, 2017
27. Greenline Warehouse “B” Process III/IV Application With SEPA, ESM Consulting Engineers
LLC, September 1, 2017
28. Site Photographs, received September 1, 2017
29. Geotechnical Engineering Services Report Weyerhaeuser Way South, 320th Street to SR 18
Weyerhaeuser Campus Property Federal Way, Washington, GeoEngineers, August 29, 2017
30. Tree Counts on the Two 16-Acre Parcels…, Gilles Consulting, revised August 24, 2017
31. My Credentials, Gilles Consulting, August 23, 2017
32. Title Report Guarantee/Certificate No. 0105928-16, Chicago Title Insurance Company,
August 8, 2017
33. Water Certificate of Availability, Lakehaven Utility District, August 4, 2017
34. Sewer Certificate of Availability, Lakehaven Utility District, August 4, 2017
III. ENVIRONMENTAL CHECKLIST
The following lists the elements of the environmental checklist (Exhibit C) and a response to each:
1. Whether city staff concurs with the applicant’s response to the checklist item, or
2. City staff’s additional comments or clarification to each checklist item.
A. BACKGROUND
The project development application was submitted June 17, 2016, with subsequent submittals
made on September 1, 2017, September 11, 2017, and September 29, 2017. It was determined to
be a complete application on September 29, 2017. Subsequent submittals were made on June 28,
2018, July 10, 2018, August 15, 2018, September 18, 2018, October 9, 2018, February 12, 2019,
and July 30, 2020.
Following are staff’s comments on the August 10, 2018, checklist (resubmitted August 15, 2018):
1. In a February 8, 2019, letter the applicant requested that the Greenline Warehouse "B" project
now be referred to as Woodbridge Building "B." They are the same project and any reference
to Greenline Warehouse "B" should be considered as a reference to Woodbridge Building "B."
2-7. Concur with the checklist.
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Woodbridge Building “B” 17-104237-SE / Doc ID 80803
8. See the list above in Section II for additional environmental information that has been
prepared related to the proposal.
9. Concur with the checklist.
10. A building permit is required.
11. There are 245 parking spaces proposed.
12. Concur with checklist.
B. ENVIRONMENTAL ELEMENTS
1. Earth
a.-h. Potential impacts will be mitigated through compliance with the 1994 city code
requirements, KCSWDM, and BMPs. Compliance with local, state, and federal
standards will provide sufficient mitigation of potential erosion impacts. Concur with
the checklist.
2. Air
a.-b. Concur with the checklist.
c. The applicant was requested to provide information related to emissions associated with
the operation of the facility, and a detailed study by a qualified expert about the effect of
particulate matter from diesel trucks on the environment and on downwind properties.
The applicant submitted an air quality report (“Greenline Building “B” Development,
Federal Way Washington Air Quality Report,” Ramboll Environ, June 2018) that
concluded, “At the time of this analysis, the exact use of the warehouse had not been
established. However it is anticipated that the warehouse will be used for general
commodities that do not require cold storage. Furthermore, the warehouse will not
include processing or manufacturing facilities. Sources of air pollution typical of a
general commodities warehouse include emergency generators and vehicles used by
employee commuter trips and truck deliveries.” A condition will require the air quality
analysis to be revised and the SEPA threshold determination revisited if the proposed
use of the building includes cold storage, processing, or manufacturing.
The report also 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 air quality impacts during construction, the report states:
“The following is a list of possible mitigation measures that could be implemented
to reduce potential air quality impacts during construction of the project.
• Use only equipment and trucks that are maintained in optimal operational
condition
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Woodbridge Building “B” 17-104237-SE / Doc ID 80803
• 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
• Use biodiesel or other lower-emission fuels for vehicles and equipment
• Use carpooling or other trip reduction strategies for construction workers when
possible
• Stage construction to minimize overall transportation system congestion and
delays to reduce regional emissions of pollutants during construction
• Implement restrictions on construction truck idling (e.g., limit idling to a
maximum of 5 minutes)
• Locate construction equipment away from sensitive receptors such as fresh air
intakes to buildings, air conditioners, and sensitive populations
• 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
• Spray exposed soil with water or other suppressant to reduce emissions of PM10
and deposition of particulate matter
• Pave or use gravel on staging areas and roads that would be exposed for long periods
• 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
• 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
• 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
• Cover dirt, gravel, and debris piles as needed to reduce dust and wind blown
debris
• 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”
A condition will implement the above listed items. Regarding operation of the project,
the report states, “The analyses described above indicate the proposed project would be
unlikely to result in any significant adverse air quality impacts. Consequently, no
operational mitigation measures are warranted or proposed.”
Mitigation measures related to air are contained within the MDNS conditions. Federal
Way Comprehensive Plan (FWCP) policies cited in the MDNS provide the basis and
authority for the mitigation conditions.
3. Water
a. Surface
1. Concur with the checklist.
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Woodbridge Building “B” 17-104237-SE / Doc ID 80803
2. According to submitted project materials, 9,922 square feet of direct impact (fill) to
wetlands are proposed. Wetland DQ will not be impacted.
3-6. Concur with the checklist.
b. Ground
1-2. Concur with the checklist.
c. Water Runoff
1-3. Concur with the checklist.
d. Final review of the stormwater quality and detention will occur in conjunction with the
final engineering plan review. Compliance with local, state, and federal standards will
sufficiently mitigate stormwater impacts from the project.
4. Plants
a. Concur with the checklist.
b. Two wetlands and adjacent buffers will remain.
c. Concur with the checklist.
d. To clarify, buffer enhancement of native plants could only be allowed within averaged
buffer replacement areas based upon the application that has been submitted. A
landscape plan in accordance with the 1994 Federal Way City Code (FWCC) 22-1563 is
required for this project. In addition, compliance with the significant tree standards of
FWCC 22-1568, is required. A preliminary landscape and tree and vegetation retention
plan has been submitted in conjunction with the application. Final review and approval
of the required landscaping plan will occur as part of the building permit approval.
e. Concur with checklist.
5. Animals
a-e. Concur with the checklist.
6. Energy and Natural Resources
a. Concur with the checklist.
b. The proposal is for a 45-foot-tall building.
c. Concur with the checklist.
7. Environmental Health
a. 1-5. Concur with the checklist.
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Woodbridge Building “B” 17-104237-SE / Doc ID 80803
b. 1-2. Concur with the checklist.
b. 3. The applicant was requested to provide a noise report prepared by a qualified expert to
verify that the noise generated by the site operation would not exceed the city’s
thresholds for noise set forth in FWRC 7.10. The applicant submitted an
environmental noise report (“Greenline Building “B” Development, Federal Way
Washington Environmental Noise Report,” Ramboll Environ, July 2018) that
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. An evaluation of the actual facility
design, once submitted, should be completed 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 this report.” This shall be made a condition.
Regarding construction related noise, the report states, “The following may help to
reduce the potential for high levels of noise from construction equipment or
activities, as may be received at existing noise-sensitive land uses, and therefore
would help to reduce the potential for perceived impact:
• Require that all equipment be fitted with properly sized mufflers, and if
necessary, engine intake silencers
• Require that all equipment be in good working order
• Use quieter construction equipment models if available, and whenever possible
use pneumatic tools rather than diesel or gas-powered tools.
• 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.
• For mobile equipment, consider replacing typical pure-tone backup alarms with
ambient-sensing and/or broadband backup alarms.”
Regarding operation of the project, the report states, “Noise mitigation measures are
not warranted at this time.” Under the conclusions section it states, “A detailed
review of final operating conditions should be completed to ensure that this noise
study accurately and conservatively reflects future Project operation.” Conditions
will implement the above listed items.
Mitigation measures related to noise are contained within MDNS conditions. FWCP
policies cited in the MDNS provide the basis and authority for the mitigation
conditions.
8. Land and Shoreline Use
a-g. Concur with the checklist.
h. Stream EA is also present on the property.
i-m. Concur with the checklist.
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Woodbridge Building “B” 17-104237-SE / Doc ID 80803
9. Housing
a-c. Concur with the checklist.
10. Aesthetics
a. Concur with the checklist.
b. Additional views altered include from Weyerhaeuser Way South on the overpass over
SR-18 and from the eastbound SR-18 exit. Additional details can be found in the
August 10, 2018, Visual Impact Analysis.
c. References to “Type III” landscaping should be Type I and Type II, per the submitted
landscaping plan.
11. Light and Glare
a-d. Concur with the checklist.
12. Recreation
a-c. Concur with the checklist.
13. Historic and Cultural Preservation
a. The Washington State Department of Archaeology and Historic Preservation has
determined that the Weyerhaeuser Headquarters would qualify for listing on the
National Register of Historic Places.
b. See the memorandum prepared by Cardno.
c-d. Concur with checklist.
14. Transportation
a. Concur with the checklist.
b. Concur with the checklist.
c. Two separate questions are shown in the checklist for item “c.”
Staff response to the first question: Concur with the checklist.
Staff response to the second question: Frontage improvements and right-of-way
dedication consistent with the street modification decision are required (city file no. 18-
102212-SM). Prior to engineering plans approval, WSDOT approval of the traffic
study and channelization plans shall be provided.
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Woodbridge Building “B” 17-104237-SE / Doc ID 80803
Prior to issuance of the 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-turn
(NBL) lane storage shall be designed to accommodate the 95th Percentile queues length,
ensuring left-turn queues will not block through traffic lane. The channelization plan
must be reviewed and approved by the city and WSDOT.
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.
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 would 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 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
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Woodbridge Building “B” 17-104237-SE / Doc ID 80803
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 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.
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.
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 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 was for both Warehouses
“A” and “B.” The mitigation measure regarding the SR-18 off-ramp right-turn storage
applies to the Woodbridge Building “B.”
Conditions will implement the above listed items.
Mitigation measures related to traffic are contained within MDNS conditions.
FWCP policies cited in the MDNS provide the basis and authority for the mitigation
conditions.
d-e. Concur with the checklist.
g. See response in 14(c), above. In addition, 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:
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Woodbridge Building “B” 17-104237-SE / Doc ID 80803
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.
15. Public Services
a-b. Concur with the checklist.
16. Utilities
a-b. Concur with the checklist.
IV. CONCLUSION
The proposal can be found to not have a probable significant adverse impact on the environment if
appropriate conditions are properly implemented pursuant to the MDNS. Conditions of the MDNS
are based upon impacts identified within the environmental checklist, project submittal documents,
and the above “Staff Evaluation for Environmental Checklist, File 17-104237-SE,” and are
supported by plans, policies, and regulations formally adopted by Federal Way for the exercise of
substantive authority under SEPA to approve, condition, or deny proposed actions.
The city reserves the right to review any future revisions or alterations to the site, or to the proposal,
to determine the environmental significance or nonsignificance of the project.
Exhibit A – Reduced Scale Site Plan
Exhibit B – Vicinity Map
Exhibit C – Environmental Checklist
Prepared by: Principal Planner Stacey Welsh (253-835-2634, stacey.welsh@cityoffederalway.com)
Date: October 1, 2020