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20210319 Ltr (Woodbridge Bus Pk-Tech Rev) 2200534.30Civil Engineers Structural Engineers Landscape Architects Community Planners Land Surveyors Neighbors TACOMA 2215 North 30th Street Suite 300 Tacoma, WA 98403-3350 253.383.2422 TEL www.ahbl.com March 19, 2021 Eric LaBrie ESM Consulting Engineers, LLC 33400 8th Avenue South, Suite 205 Federal Way, WA 98003 Eric.labrie@esmcivil.com RE: City Project No. 17-105489-UP and 17-105490-SE Technical Review Comments Woodbridge Business Park (aka Greenline Business Park) 327xx Weyerhaeuser Way South, Federal Way AHBL No. 2200534.30 Dear Mr. LaBrie: The City received a resubmittal of plans and documents associated with the Process IV and SEPA review of the above project on April 9, 2020. The City has the following comments in response to the resubmittal. The proposal has been modified to include the construction of three new buildings totaling 971,390 square feet, construction of approximately 1,551 vehicle and truck parking spaces, construction of five stormwater ponds, and associated site work and improvements. Approximately 12,070 square feet of wetlands would be directly impacted, and seven wetlands would be insufficiently buffered, causing 7,849 square feet of indirect impacts. Additional grading impacts to wetland buffers are proposed. The proposal includes a mitigation plan for wetland and buffer impacts. You have also applied for a Boundary Line Adjustment (BLA). The City has provided separate comment letters for the review of the east and west BLA application and those are both currently on hold. The proposal is subject to the provisions of the 1994 Weyerhaeuser Company Concomitant Pre-Annexation Development Agreement (CZA), and Corporate Park Zone (CP-1) zoning regulations in effect on August 23, 1994. Critical areas are to be reviewed under the current critical areas regulations. Drainage for new development shall be designed to comply with current Federal Way drainage requirements. The land use procedural requirements must meet today’s code, Federal Way Revised Code (FWRC) Title 19. Some comments provided herein are required to be addressed and some are informative, while others may be applicable during future steps of the project. Comments in this letter need to be addressed prior to issuance of a SEPA threshold determination and land use application decision, or as otherwise noted. Questions regarding technical review comments should be addressed to the referenced staff representative. Lisa Klein – Contract Planner, (253) 651-7907, lklein@ahbl.com Jim Harris – Planning Division, (253) 835-2652, jim.harris@cityoffederalway.com 1. Technical comments made about an item on one sheet may necessitate changes to other sheets and related documents, and it is the applicant’s responsibility to determine any such necessary adjustments. Please ensure consistent information is communicated throughout the plan set and associated application materials. 2.See the separate City technical review letters pertaining to the proposed BLA. Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 2 of 15 Parking Analysis Off-street parking shall comply with the 1994 zoning code as modified by the provisions of Section XIII of the CP-1 regulations. Required parking is one parking space per 300 square feet of gross floor area (GFA) for office, and one for every 1,0000 square feet of GFA for warehouse. No floor plan has been submitted, so the exact breakdown of office and warehouse space has not been determined, however, if we were to assume that 10 percent of each building is office space, the provided number of parking spaces does not meet the minimum requirements. As an alternative to meeting the code minimum parking requirements, a Parking Analysis was prepared by Transportation Engineering Northwest dated March 10, 2020. The following comments pertain to review of the onsite parking and the TENW Parking Analysis. 3. The Site Plan and Parking Analysis do not provide the number of parking spaces per building, just an aggregate number. Section XIII of the CP-1 regulations provided in the CZA provide that: “the aggregate of all proposed and existing uses on the property may, subject to approval of the Director, be considered as a whole in establishing the minimum number of vehicle spaces required, based on the following: 1. Any excess capacity in existing parking spaces lying within 800 feet of a proposed development may be used to reduce the requirement for additional parking development. 2. If the occupant of a proposed use provides van or alternative service between the proposed use and remote parking facilities, any excess parking on the entire property may be used to reduce the requirement for additional parking development.” Either provide a breakdown of parking per building demonstrating that each building meets the required number of parking spaces or provide a response for the Director’s consideration to the CZA provisions listed above. 4. The TENW Parking Analysis provides a parking calculation that is based on the Warehouse LUC 150. A calculation for office space associated with the warehouse use was not provided and the office space use may increase the parking requirement. Provide the office space calculation per the ITE Parking Generation Manual or explain why the office space calculation is not provided (for example, if office space is presumed to be an accessory use to the warehouse use). 5. The Traffic Impact Analysis (TIA) used a different LUC than the Parking Analysis (LUC 130 – Industrial Park). Either modify the technical documents for consistency or clarify why the Parking Analysis and TIA would use different LUCs. 6. As requested in the City’s comment letter dated March 7, 2019, if the proposal is not meeting City code requirements for parking, the Parking Analysis shall provide comparisons to other existing similar uses with similar land use characteristics in the Greater Puget Sound region. 7. The size provided for the existing WTC building on the site plan (Sheet CV-01) is 239,354 square feet. The size of the WTC building provided in the Parking Analysis is 450,000 square feet. The size of the WTC building provided by the King County Assessor is 468,457 square feet. Clarify which building size is correct for the WTC building and correct the plans and Parking Analysis accordingly. Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 3 of 15 Plan Statistics 8. The Cover Sheet of the Plan Set (Sheet CV-01) depicts the site area as 136 acres. Sheet SD-01 provides the site area as 145.99 acres. Clarify which statistic is correct and modify the plans and documents as needed to correct the discrepancy. 9. There are discrepancies in the impervious surface numbers provided for the project area. The Architectural site plan provides 60.7 acres of impervious, Sheet SK-01 provides 45.79 acres of impervious surface, and the SEPA checklist identifies 61.02 acres of impervious surface (45 percent of 135.61-acre site). Clarify which statistic is correct and modify the plans and documents as needed to correct the discrepancy. 10. Section III of the CP-1 regulations states, “The aggregate impervious surface coverage by all permitted uses, primary and accessory, shall not exceed 70 percent of the total CP-1 zoned property.” The “Impervious Area Exhibit” prepared by ESM, September 9, 2017, shows the existing impervious coverage in the CP-1 zone is 8.6 percent and the construction of the proposed project would increase it to 24.1 percent. We believe that the exhibit is now outdated based on recent project changes. Revise/update the exhibit to match the current proposal. Managed Forest Buffer, Landscape Plans, and Tree Retention Section III.B of the Exhibit C of the CZA states that a continuous Managed Forest Buffer (MFB) shall be provided around the entire perimeter of the CP-1 property. On November 18, 2018, the City issued Interpretation #18-01 (18-105277-UP) that describes the location and depth of the MFB on the CP-1 zoned property. Washington Forestry Consultants, Inc. prepared a Forest Management/Maintenance Plan dated March 23, 2020 (the WFC Plan) which was submitted together with qualifications information on the preparer. The WFC Plan describes the location and vegetation types and quantities for each of the MFB areas. In general, the WFC plan is acceptable, however the site plan revisions described herein will require revisions. 11. The CZA states a “Managed Forest Buffer shall be provided around the entire perimeter of the CP-1 property.” The CP-1 perimeter extends to the northeastern parcel along the North Lake shoreline (Lot F on EX-01), which is the lot currently proposed to contain a stormwater pond and wetland mitigation area, and where a Managed Forest Buffer (MFB) is not provided. The east boundary of the northeastern parcel is adjacent to single-family zoned land (including the adjacent access road, which is zoned single-family). The property zoned for single-family is currently owned by Washington Department of Natural Resources and used for a boat launch and public access for fishing, which is an incompatible use to the CP-1 zone. The CZA provides that a 50-foot MFB is to be provided adjacent to incompatible use. Provide a 50-foot MFB on the east boundary of the northeastern parcel. Update the Forest Management/Maintenance Plan to include this area. 12. Section III.B.4 of the CZA describes that widening of rights of way “shall not require relocation of any boundaries of the required Buffer for developed lots” (emphasis added). Section VIII.A.8 of the CZA describes that only perpendicular access roads are permitted in the MFB. The northern 25-foot MFB shall be located outside of the 106-foot Development Reservation area that is to be dedicated for right of way. Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 4 of 15 13. The screening of the truck bays on the north side of Building A to the future right of way and properties to the north requires enhancement. The WFC Plan describes the western half of this area as containing Forest Cover Type III. Forest Cover Type III is described in the WFC Plan as being poorly stocked with 30 trees per acre and containing large gaps where shade tolerant conifers such as western redcedar could be planted. Interplanting with a shade tolerant tree species would improve this buffer over time and screen the truck bays from the future right-of-way. The landscape plans shall be revised to include the addition of shade tolerant tree species within Forest Cover Type III located within the northern 25-foot MFB that infill the existing trees. Per Section XI.A.3 of the CZA, the selection and installation of plant material in the MFB shall be the responsibility of the Forester. A letter approving the landscape plans for this specific area shall be provided by WFC. 14. The Tree Retention Plan Sheet TR-01 is not consistent with the grading plans SD-01 and SD-02, the Visual Impact Exhibit, or the landscape plans. It depicts no tree retention adjacent to Weyerhaeuser Way South between the road and new buildings. The Grading Plans, however, depict that a large portion of the landscape buffer in this area will not be graded, which would allow for tree retention. The grading plans also depict greater potential for tree retention around the south and west sides of Buildings 2 and 3 and stormwater ponds 4 and 5 than shown on Sheet TR-01. The Visual Impact Exhibit also depicts the retention of the mature vegetation in these areas. The landscape plans depict new plantings in these areas to supplement the native vegetation. Per Section XI.A.1 of the CZA, all portions of the property not used for buildings, future buildings, parking, storage, or accessory uses, and proposed landscaping areas shall be retained in a “native” or predeveloped state. Revise Sheet TR-01 to match the grading plans, landscape plans, and Visual Impact Exhibit. All plans need to be consistent. Site Plan 15. Provide all easements to be retained and new easements proposed on the site plan sheets to determine any potential conflicts. 16. Sheet EX-01 depicts a small dashed line setback from the north and eastern perimeter of Parcel F. Identify the purpose of the line. Visual Impact Exhibit 17. The following modifications to the Visual Impact Exhibit are required: a. Update the exhibit to reflect the current site plan. Revise the building references in the exhibit to correlate with the site plan for ease of reference (i.e., number designations instead of letters). b. Provide additional view locations as depicted below in Figure 1 depicting the change in view resulting from tree removal and the site development. Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 5 of 15 Figure 1 - View Impact Exhibit - Additional View Locations Building Elevations and Design Brief The site and building design are required to comply with the CZA, and, where indicated, the FWCC. The specific CZA and FWCC design requirements affecting development of the property are stated below in “a – d” followed by staff technical comments as to how they apply to the Woodbridge Business Park: a. “The property is unique in terms of its development capacity and natural features. Weyerhaeuser desires to develop its Property with maximum flexibility which will insure optimal development, while preserving the unique natural features of the site.” b. “CP-1 properties are characterized by large contiguous sites with landscape, open space amenities, and buildings of superior quality. The property appropriate for such uses is unique and demands for such uses are rare. Consequently, special land use and site regulations are appropriate.” Staff Analysis: The CZA’s meaning and intent to “preserve the unique natural features of the site,” as described in “a,” is critical in understanding how the CP-1 properties are to be developed. Understanding the intent of “a” is assisted by the additional characterizations of the site provided in “b,” i.e., the unique natural features to be preserved are the unique “landscape and open space amenities.” The CZA intent is to preserve the meadow, a unique landscape Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 6 of 15 feature that provides an open space amenity. Also to be preserved is the Managed Forest Buffer and the forest/native vegetation located outside of the development footprint (described below in (d.A.1)), which form the landscape. The preservation of these areas will allow for “optimal development” of the site. Provision “b” further describes the existing condition of the CP-1 properties as containing buildings (such as the headquarters building and WTC building) that are of superior quality. It acknowledges that the site is unique and deserves “special land use and site regulations.” The special regulations include regulations that require new buildings be of superior quality and that the development preserve the unique natural features. How the intent of the CZA is specifically applied to the proposal is provided below. c. Section X General Development Conditions: “Provisions of the FWC relating to façade measurement, modulation, distance between structures, or materials, other than those specified herein, shall not apply to this zone.” Staff Analysis: This provision is clear that prescriptive building design requirements typically found in design standards do not apply. Removal of specific design standards requires reliance upon the existing buildings and landscape for guidance in determining the intent of superior building design. d. Section VI.B requires that proposed landscaping comply with Section XI (Landscaping). Section XI provides specific modifications to Chapter 22, Article XVII (Landscaping) that are applicable in the CP-1 zoning district, including: o A.1 “All portions of the property not used for buildings, future buildings, parking, storage or accessory uses, and proposed landscape areas shall be retained in a “native” or predeveloped state. Alterations to existing landscaping shall match or be compatible with existing vegetation.” o A.2 “Alterations to existing landscaping in connection with new development shall match or be compatible with existing vegetation. Extensions of, or duplication of existing plant material in connection with future development is preferred.” Staff Analysis: These provisions clearly intend for the existing vegetation to be retained to the greatest extent possible, and, when required to be removed for future buildings, parking, storage or accessory uses, the replacement plantings shall match or be compatible with existing vegetation. 18. Based on the CZA requirements and the staff analysis described above, we have the following comments on the building and site design: a. As previously commented by the City, the site and building design, as viewed from the high-profile public street roundabout, do not represent “buildings of superior quality” or an “altered site that matches existing vegetation.” We understand you have reduced the size of Building 2 and pulled it away from the public right-of-way; however, the concerns remain that at this prominent location, the combination of the proposed tree removal for the storm pond, proposed plantings, and the building aesthetics do not meet the CZA requirements. The following would improve the building and landscaping Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 7 of 15 aesthetics at this location and better comply with the CZA. The city is open to alternatives that provide an equivalent or superior approach to site and building design: i. Construction of storm pond #5 and its maintenance access road requires removal of mature vegetation and limits the planting of replacement vegetation that would otherwise screen the building. Relocation of the storm pond maintenance access road to a location that extends from the parking lot instead of Weyerhaeuser Way would allow the existing trees in that location to remain and new trees to be planted along this prominent frontage for additional screening. Relocate the pond maintenance access road to minimize tree removal. Provide additional trees between Weyerhaeuser Way and the stormwater pond for building screening. ii. The landscape plans provide new evergreen tree plantings between the street frontage and storm pond #5; however, the landscape plans do not indicate tree sizes. The City will require that the trees at this location be at least 10 feet in height at the time of planting. Add this note to the landscape plans. iii. The southeast corner of Building 2 marks the entry point to the new campus and this corner is not architecturally emphasized. Consider mimicking the building corner treatments provided at the main building entry at the northeast corner and/or the entry at the southwest corner or provide other architectural building elements that enhance building design at this high-profile location. b. As provided above, the meadow is a “unique natural feature of the site that is to be preserved.” In order for the meadow to be preserved/retained in its native/predeveloped state, the City will require the meadow be protected from development through the recording of a conservation easement. This will be a condition of approval. c. The City is concerned about view impacts from Interstate 5 as a result of the pond and building construction. If view impacts are not adequately mitigated, the City may determine that a SEPA Determination of Significance is appropriate and an EIS will be required. The following comments provide our analysis of the impacts and potential opportunities to mitigate the impacts. Additional analysis will likely be required following plan changes and receipt of the updated View Impact Analysis to evaluate if the impacts are adequately mitigated. i. The Visual Impact Exhibit demonstrates that Buildings 2 and 3 will be visible from Interstate 5, impacting the view of the site across the meadow, a “unique natural feature of the site” that, per the CZA, shall be preserved (see staff interpretation above). The retention of the existing trees between the meadow and the buildings provides some screening of the building, however the screening is limited. The existing vegetation that is to remain at this location is narrow in width (particularly at the south end) in the existing condition, and these trees are largely deciduous trees, which will result in significantly less screening during the fall and winter than what is depicted on the Visual Impact Exhibit. Additionally, the height of Building 2 will clearly exceed the height of the retained trees as viewed from Interstate 5. Additional screening is required. One option could be to plant additional evergreen trees of a type that will exceed the height of the building at maturity. If this option is selected, WFC (the forester) shall recommend a suitable tree type for this location that will grow quickly and that Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 8 of 15 will eventually exceed the building height. The new trees shall be no less than 10 feet in height at the time of planting. The City is open to considering other options at this location. The selected screening shall be depicted on the revised View Impact Analysis. ii. Storm Pond #3 is partially located within the northern portion of the meadow and in an area where the adjacent managed forest buffer is also meadow (i.e. has no trees in its natural predeveloped condition). Construction of Storm Pond #3 will therefore impact the meadow, which is not acceptable as described above, and will require removal of trees that could otherwise provide screening of the rear elevation of Building 3 as viewed from Interstate 5. Storm Pond #3 shall be relocated (potentially placed in an underground facility) so as not to impact the meadow or screening of Building 3 as viewed from Interstate 5. Alternatively, you may propose relocation of the above ground pond in a manner that demonstrate that view impacts will be mitigated. iii. Storm Pond #2 is located between the 100-foot-wide Managed Forest Buffer adjacent to Interstate 5 and the palustrine-forested and scrub-shrub wetlands located adjacent to the rear side of the existing WTC building. The rear side of the WTC building contains a storage yard and loading area that is not visible from Interstate 5 today and the rear and south building elevations have deteriorated and have no modulation or architectural elements that are required for buildings of superior quality that will be visible from a public right of way. Construction of Pond #2 will require removal of a 145 – 170-foot-wide swath of mature trees and native vegetation that will open the view of the south and rear elevations of the existing WTC building. The remaining vegetation will be the 100-foot wide Managed Forest Buffer (which is partially meadow grass and transitions to forest to the north) and the sparsely vegetated wetlands and wetland buffers. The following menu of potential options for screening and mitigating view impacts caused by Storm Pond #2 shall be considered and depicted on the View Impact Analysis for additional review. Alternatively, you may propose relocation or redesign of the pond in a manner that demonstrates that view impacts will be mitigated. Provide additional plantings in the Managed Forest Buffer. The forester shall provide recommendations for the additional plantings that retain the integrity of the “native” or predeveloped conditions” of the MFB and are planted so as to provide additional screening. New plantings shall be evergreen trees that are at least 10 feet in height at the time of planting. Provide additional screening of the rear side of the WTC building by augmenting the wetland buffer plantings with additional evergreen trees that are at least 10 feet in height at the time of planting. Provide documentation that the additional plantings have been approved by the wetland biologist. Provide additional landscape screening within the reconfigured rear parking/storage area of the existing WTC building. The screening would need to be of a depth and type that provides effective screening. Modify the rear and south elevation of the existing WTC building to provide architectural treatments that are complementary to the new buildings and represent “superior quality.” Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 9 of 15 Relocate or redesign Storm Pond #2 to retain the trees in this area. In lieu of an open pond, consider an underground facility in the parking areas. d. The overall design of the buildings is not representative of the CZA requirement that the buildings be of superior quality. The existing campus and the headquarters and WTC buildings provide guidance as to what was intended by “superior quality.” Additionally, when multiple buildings are provided on the same site, they should create a unified, campus-like development (a current code requirement but a common prerequisite for a site with multiple buildings). The existing headquarters and visible sides of the WTC buildings are relatively timeless in their design (i.e. not trendy), with strong horizontal and rectangular lines and a significant amount of glazing. The proposed building design, however, is not complementary to, or reminiscent of the existing buildings. The mountain-themed paint scheme serves to break up the façade but does not correlate to the existing buildings or legacy of the site, which is more about trees and timber than mountain views. Staff recommends elimination of the mountain paint scheme, expansion of the vertical wood panels and incorporation of additional windows to improve the building’s quality of design, and to provide a more complementary design to the existing buildings and a design that is representative of the legacy of the campus and of superior quality. Wetlands and Streams 19. Review and address each comment in the enclosed January 25, 2021, review letter from the City’s wetland consultant, ESA. 20. Add the North Lake 200-foot Shoreline Management Zone to the plans, including the area where improvements are planned to Weyerhaeuser Way (near Wetland BL) and, if required, submit for a Shoreline Substantial Development Permit. See the ESA letter, comment #10, for more details. SEPA Checklist 21. The revised SEPA checklist does not reflect all of the plan changes and additional environmental information that has been prepared or updated. Update the SEPA Checklist to reflect the updates and revisions made to the project. In particular, the following is noted as needing to be updated: a. Update the environmental information listed in A.8 to reflect revised/updated studies and newly completed studies. b. See the ESA comment letter on the review of the Talasaea Critical Areas Report and Proposed Mitigation Plan dated April 9, 2020. Update the SEPA Checklist in accordance to any updates/revisions made to the Critical Areas Report. In particular, if a shoreline permit is required, update the list of government approvals provided in A.10. c. Include the wetland impacts and mitigation proposal in the project description in A.11. d. Update the wetlands information provided in B.3 and B.8.h to match the updated Critical Areas Report and Mitigation Plan dated April 9, 2020, or as updated based on ESA comments. The statistics provided appear out of date. Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 10 of 15 e. Update B.7 to address the existing pipelines (see Technical Review memo from the Public Works Department dated November 3, 2020). f. Update B.10.b and B.10.c to address altered views from Interstate 5 and how the view impacts will be mitigated. g. Are measures proposed to control light and glare impacts? Amend section B.11 to address proposed light and glare mitigation measures. h. Provide further clarification of what is meant by your intent to reconfigure onsite trails in Section B.12. Which trails will be removed, and which will be reconfigured to avoid dead-ends? Your comment response letter dated April 2, 2020, indicates that many of the trails throughout the property will be retained in accordance with the CZA purpose statement (your Comment 5). Please clarify. i. Update section B.13. Include a description of the Cardno Cultural Resources Study dated March 16, 2018 and address the findings. 22. The Cardno Report did not include information regarding correspondence with DAHP or the Tribes. Your letter responding to public comments indicates in Item 4 that the report will be submitted to DAHP. Did you provide a copy of the report to DAHP for their comment? If so, provide copies of all correspondence and/or comments that were received following DAHP’s review of the Cardno report. Kevin Peterson – Public Works Development Services, (253) 835-2734, Kevin.peterson@cityoffederalway.com Prior to Land Use approval, the applicant shall address the following Technical Review comments: Use Process 23. Provide a breakdown of impervious surfaces on the site plan cover sheet: total impervious area for the entire project, total new impervious area (as defined in the King County Surface Water Design Manual - KCSWDM), and total replaced impervious area. 24. Based on the Boundary Line Adjustment (BLA) currently under review for this project, it appears that Pond 1 is isolated on a separate parcel, without adequate space to locate a building, and therefore cannot be allowed as it does not create a ‘buildable lot’, as defined in FWRC Section 19.105.010. In addition, it appears that the current proposed BLA property lines may either cross through or are very close to Ponds 2 and 3. These ponds shall be located completely within property boundaries and meet property line setbacks as required in the design criteria of the KCSWDM. Clearly show the proposed new property lines that are delineated on the BLA(s) currently under review with the City. 25. Pond 5: Access to this pond shall be provided on-site, no access allowed from either S 336th St or Weyerhaeuser Way S. 26. It is difficult to see what, if any, Solid Waste & Recycling amenities are being provided. Show and/or otherwise indicate on the plans where the SW&R facilities are located and provide some basic design details on the enclosures. Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 11 of 15 27. Street trees shall be 2.5-inch caliper, per City standards. Technical Information Report (TIR) 28. Based on the information provided, it appears the project is under the threshold for Large Project Drainage Review and is now subject to Full Drainage Review requirements of the 2016 KCSWDM. 29. There appear to be essentially 2 primary threshold discharge locations – 1 to the south and into the Weyerhaeuser Pond and 1 to the east into North Lake, which eventually discharges into the Weyerhaeuser Pond. In the Existing condition, approximately 24 acres of the site discharges to North Lake, yet in the Developed condition, it appears only 13.14 acres are discharging to North Lake, with the remainder discharging to the Weyerhaeuser pond. The requirement is to maintain, as closely as possible, the hydrology to each discharge location so as not to create adverse impacts by increasing or decreasing flows to one basin or the other. 30. The report indicates that an additional 3.43 AC-FT of live storage from this project is being directed to the Weyerhaeuser Pond on the old headquarters building site: a. Provide an estimated depth of water that will be added across the existing pond (i.e., x.xx-feet +/- depth of water added across the existing pond surface; existing WS Elev=xxx.xx’, New WS Elevation=xxx.xx’). b. Provide a copy of the approved and/or as-built plans for the 2004 headworks modification to the Weyerhaeuser Pond. 31. Pond 2, as currently designed, has a detention capacity greater than 10 acre-feet with an impounding berm over 6-feet in height. As such, this detention pond will need to comply with the State Department of Ecology regulations and review process for dam safety (KCSWDM Section 5.1.1, WAC 173-175) – this should be identified in the TIR. 32. The WWHM analysis for Pond 5 shows it to FAIL. The analysis needs to indicate the facility to PASS, and the pond shall be designed and analyzed to meet the PASS condition. Otherwise, provide a narrative in the TIR that provides an explanation of the Pond 5 analysis FAIL condition. 33. From the November 2017 pre-application meeting summary letter: ‘…the site is near an identified Sphagnum Bog (Core Requirement 6.1.4 of the KCSWDM). The applicant’s engineer shall demonstrate in their storm water technical analysis if and/or how the project does (or does not) impact this bog, and the means of providing water quality treatment to meet the Sphagnum Bog treatment criteria if storm water runoff affects the bog.’ Based on the topographic mapping provided, it appears that some portion of the site, at the NE corner, does discharge into the Bog, including a portion that is being developed with parking and drive aisles. Please provide the analysis as requested from the pre-application meeting summary. 34. The TIR must also examine the Hylebos Executive Proposed Basin Study and the projects impacts upon the East Hylebos recommendations and the Basin Wide recommendations. The TIR shall include a section that provides an analysis of the project and how it meets the requirements of - and/or does not further impact - drainage-related issues that are identified in the study. Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 12 of 15 SEPA 35. According to the plans and survey provided, as well as project materials reviewed by the City in the immediate vicinity of this site (and unrelated to this project), there is a buried, 14-inch Olympic oil pipeline that runs through the west side of the project site. There may also be a buried gas main that extends south through the northeast portion of the site. These 2 pipelines shall be disclosed/identified under section B.7.a.2 of the SEPA checklist, with proposed measures to protect these pipelines under section B.7.a.5 of the checklist. Sarady Long – Public Works Traffic Division, (253) 835-2743, sarady.long@cityoffederalway.com The Public Works traffic Division has finished its review of the submitted materials. The following technical review items must be address. Please note, these comments did not include comments from WSDOT. Traffic related comments/concerns by WSDOT must be addressed and approved by WSDOT. Plans Comments 36. The submitted plans depicted the correct Type K street section and right-of-way dedication for S 336th St and Weyerhaeuser Way S. However, the plans did not show street improvement and potential right-of-way dedication at the S 336th St and Weyerhaeuser Way S roundabout. ADA compliant pedestrian facilities must be provided at the roundabout. Unless a street modification is approved by the Public Work Director, the submitted plans must show improvement at the roundabout. 37. Provide a truck turning diagram to ensure the roundabouts on Weyerhaeuser Way S can accommodate the expected trucks. 38. Pavement design and upgrade may be necessary on Weyerhaeuser Way S and S 336th St in order to accommodate the expected truck traffic generate by the proposal. The applicant must perform pavement evaluation demonstrating that the standard pavement section for a Type “K” street is adequate to handle the expected traffic load generating by the proposal. 39. The proposed northerly driveway must meet separation distance from the future S 324th St and Weyerhaeuser Way S intersection. Please coordinate with the City Center Access Study team to determine the future intersection and S 324th St alignment. 40. Submit a Vehicle Turning Diagram to the Public Works Traffic Division showing how the appropriate design vehicle can enter, maneuver, and leave the site without encroaching onto opposing traffic lanes or mounting a curb. Please note, the maximum driveway width is 30 feet for a two-lane two-way driveway and 40 feet for a three-lane two-way driveway (FWRC 19.135.270). Driveway widths may be increased or modified to radius driveways in order to provide adequate width for vehicles that may be reasonably expected to use the driveway, as determined by the Public Works Director. 41. Show conceptual street lighting along the property frontage on S 336th St and Weyerhaeuser Way S on the plans. Details design is not required at this time. Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 13 of 15 42. The depicted 25’wide manage forest buffer should not be within the proposed 106’ development reservation (right-of-way) for future S 324th St extension. TIA Review Comments 43. Page 3 – The TIA identified the project buildout in 2022. However, the concurrency application identified 2023 buildout. Please address this discrepancy. 44. Table 1 Page 7: Revise Weyerhaeuser Way S from S 320th St. to S 336th St classification to a Minor Arterial instead of a Principal Collector. The remaining portion from S 336th St (Roundabout) to SR 18 is classified as a Minor Arterial. 45. Page 7 – Transit Service: Add King County Metro Route 181 on S 320th St approximately ¼ mile north of the site. Coordinate with Pierce Transit for any on site transit related improvements requirement. 46. The TIA need to clarify or provide narrative on how the proposed ITE LUC 130 (Industrial Park) is applicable to the development. From a technical perspective, the City concurs with using the Transportation Institute Engineer (ITE) Trip Generation Manual 10th Edition LUC 130 (Industrial Park) to estimate the trip generation for the development. Since the actual tenant(s) is still unknown, Industrial Park land use consisted of manufacturing, service, and warehouse facilities is appropriate. Please note, additional analysis may be required if the trips generated by the actual uses exceed the trips identified in the traffic report. 47. The TIA appears to utilize the same truck trip percentage for all analysis periods. Clarify if the truck trip percentage from ITE Trip Generation Manual is specifically for all analysis periods (weekday, AM, PM, and Saturday). If not, the TIA should address how the proposed 15 percent truck trips would be applicable to all analysis periods. 48. The proposed 2 percent annual traffic growth rate is acceptable. 49. The proposed pipeline trips from surrounding developments such is acceptable. However, the TIA should provide a separate figure or spreadsheet of these trips for tracking purposes. 50. Page 14 – Project Trip Distribution and Assignment: Provide clarifications on the AM, weekday, and Saturday trip distribution. The narrative of the project trip distribution and assignment appears to indicate that the AM, weekday, and Saturday project trips distribution is generated and provided by the City. The Emme model plot provided by the City is based on PM only with no distinction between car or truck trips. 51. The adopted City Center LOS is based on average V/C and not individual V/C ratio of each intersection. Provide narrative to clarify why other intersections in the City Center were not included. 52. The report identified all site access locations would operate at LOS D or better with v/c less than 1.0. Provide right turn lane warrant analysis for truck access and storage pocket at driveway with the highest volume. 53. The AM and PM LOS analysis for S 320th St and 32nd Ave S is showing cycle length of 173 seconds. The cycle length should not exceed 160 seconds. Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 14 of 15 54. Show critical movement for Stop controlled intersections. For example, Weyerhaeuser Way S and S 323rd St is showing 0.00 v/c ration but the NBT and SBT has 0.10 v/c ratio. 55. The trip assignment in Figure 6 through 8 depicted truck trips utilizing non truck routes and traveling through residential neighborhood. Revise the truck trip assignment at intersection 5, 7, 9, 10 and 12 and recalculate the LOS for AM, PM, and Saturday. For example, intersection #9 in Figure 6 depicted 5 truck trips west of the S 336th St and Weyerhaeuser Way roundabout, which has been designated no truck except for local deliveries. Also, intersection #7 (32nd Ave S & S 323rd St) has 18 truck trips going through the office complex roundabout. These truck trips should be reassigned to intersection #6 (S 320th St & Weyerhaeuser Way S). 56. Intersection #2 (25th Ave S & S 320th St) – Change pm+pt to D.P+P. 57. Intersection #5 (32nd Ave S & S 320th St) – Change EBL and WBL from pm+pt to D.P+P. 58. Intersection #6 (Weyerhaeuser Way S & S 320th St) – Change WBL from pm+pt to D.P+P. 59. Table 6 on page 16 (Future 2022 Weekday Peak Hour Level of Service Summary): Some of the study intersection does not match with Figure 10-13. For example, intersection #6 in Table 6 depicted as Pacific Highway S / S 336th St. Update Table 6 to match Figure 10-13. 60. Weyerhaeuser Way Assessment – The City concurs that the 2022 future with project is expected to meet the minimum street design standards for a Type K street. 61. Traffic impact fee for commercial developments, fees shall be calculated based on the impact fee schedule in effect at the time a completed building permit application is filed and paid prior to permit issuance. 62. The City has determined that the S 320th St. / SR 5 and Weyerhaeuser Way S / SR 18 ramps intersections are located within WSDOT limited access. As such, WSDOT has jurisdiction over these intersection and its respective LOS standards shall apply. Any LOS failure and mitigation measures must be reviewed and approved by WSDOT. 63. Forward update TIA to WSDOT for technical review comments. SEPA Checklist - Transportation 64. Transportation 14(c) – Revise this section to including right-of-way dedication of 106’ for future S 324th St extension. CLOSING Please be aware that this review does not preclude the City from requesting additional information related to any of the topics discussed above. Please submit revised application materials as appropriate, accompanied by the completed “Resubmittal Information Form” (enclosed). Pursuant to FWRC 19.15.050, if an applicant fails to provide additional information within 180 days of being notified that such information is requested, the application shall be deemed null and void and the City shall have no duty to process, review, or issue any decisions with respect to such an application. Eric LaBrie March 19, 2021 City Project No. 17-105489-UP and 17-105490-SE Page 15 of 15 If you have any questions regarding this letter, please contact either Jim Harris or me (see contact information provided above). Sincerely, Lisa Klein, AICP Contract Planner for the City of Federal Way LK/ enc: Technical Review Letter from ESA dated January 25, 2020 Resubmittal Information Form c: Brian Davis, Community Development Director Stacey Welsh, Planning Manager Jim Harris, Senior Planner, Jim.Harris@cityoffederalway.com Kevin Peterson, Senior Engineering Plans Reviewer, Kevin.Peterson@cityoffederalway.com Cole Elliot, Public Works Development Services Manager Sarady Long, Senior Transportation Planning Engineer, Sarady.Long@cityoffederalway.com Brian Asbury, Lakehaven Water and Sewer District, basbury@lakehaven.org Sean Nichols, South King Fire and Rescue, sean.nichols@southkingfire.org Dana Ostenson, dostenson@industrialrealtygroup.com Q:\2020\2200534\WORDPROC\Letters\20210319 Ltr (Woodbridge Bus Pk-Tech Rev) 2200534.30.docx January 25, 2021 Jim Harris, City of Federal Way Department of Community Development Jessica Redman and Ilon Logan Critical Areas Report and Proposed Mitigation Plan Review: Woodbridge Business Park At the request of the City of Federal Way (City), Environmental Science Associates (ESA) reviewed the Critical Areas Report and Proposed Mitigation Plan – Woodbridge Business Park (dated April 9, 2020) prepared by Talasaea Consultants Inc. for the property at approximately 32901 Weyerhaeuser Way South in Federal Way, Washington. The 136-acre site is a combination of five parcels (King County Tax Parcel Numbers 1621049056, 1621049013, 1621049030, 1621049036, and 2285000010) currently owned by Federal Way Campus, LLC. This property was originally reviewed by ESA between May and August of 2017 as part of the Tech Center Boundary Line Adjustment project. Several site visits were conducted to evaluate wetland boundaries. Results were reported to the City in the Existing Conditions Report – Tech Center Boundary Line Adjustment technical memo (dated August 22, 2017) and the Review of the Letter titled “Response to Comments dated 22 August 2017” Existing Conditions Report – Tech Center Boundary Line Adjustment (letter dated August 22, 2017) technical memo (dated October 16, 2017). A previous version of the critical areas report and conceptual mitigation plan (dated October 27, 2018) was also reviewed by ESA in 2018. This previous review was under the former name of the project, “Greenline Business Park” and included a sixth parcel (King County Tax Parcel Number 7978200520). Findings were presented to the City in the Critical Areas Report and Conceptual Mitigation Plan Review: Greenline Business Park – FINAL technical memorandum (dated November 30, 2018). In response to ESA’s comments and recommendations in the November 30, 2018 technical memo, Talasaea revised the critical areas report to its current April 9, 2020 version and submitted a Response to ESA Review Memorandum dated 30 November 2018 technical memo (dated April 1, 2020). The April 1, 2020 memo, as well as the latest version of the Woodbridge Business Park plan sheets (prepared by ESM Consulting Engineers and dated March 31, 2020) are also part of this review. The current application involves the construction of three new buildings that will provide approximately 961,390 square feet (SF) of new warehouse and office space. The Tech Center building will remain and the existing parking lot will be reconfigured to maximize space. Associated infrastructure to be constructed includes five new stormwater detention facilities, parking for cars and trucks, and maneuvering space f or the anticipated truck traffic around these buildings. Critical Areas Report and Proposed Mitigation Plan Review: Woodbridge Business Park 2 Site Background and Purpose of Review In 1994, the Weyerhaeuser Company entered into a pre-annexation zoning agreement with the City, known as the Concomitant Agreement, to ensure that once annexed, the Weyerhaeuser Company Campus was developed “with maximum flexibility which will insure optimal development, while preserving the unique natural features of the site” (Weyerhaeuser Company Concomitant Pre- Annexation Zoning Agreement, 1994). The purpose of this review is to determine if the proposed project is in compliance with Concomitant Agreement, Chapter 19.145 (Critical Areas) of the Federal Way Revised Code (FWRC), and Chapter 15.10 (Critical Areas in Shoreline Management Areas) of the FWRC. Review of Documents ESA reviewed the Critical Areas Report and Proposed Mitigation Plan – Woodbridge Business Park (dated April 9, 2020 and hereinafter referred to as the Revised Report), the Response to ESA Review Memorandum dated 30 November 2018 technical memo (dated April 1, 2020 and hereinafter referred to as the Comment Response), and the Woodbridge Business Park Site Plan prepared by ESM Consulting Engineers (dated March 31, 2020 and hereinafter referred to as the Site Plan). According to the documents, 48 wetlands and one stream occur within the site of the Business Park project (the Project). The site is also adjacent to North Lake, a shoreline of the state. Construction of the three buildings, stormwater facilities, and parking areas would directly impact 12,070 SF (0.28 acre) of wetlands. Seven wetlands would be insufficiently buffered, and therefore are being considered indirectly impacted due to site development encroachments, resulting in an additional 7,840 SF (0.18 acre) of impact. An additional 3,024 SF (0.07 acres) of permanent buffer impacts and 29,819 SF (0.68 acre) of temporary construction impacts are anticipated for the construction of detention ponds and associated access roads. No work will occur within the ordinary high water of the stream and no permanent impacts are proposed to the stream buffer. Additionally, the Revised Report states that no development activities are proposed on or adjacent to North Lake. The Revised Report describes two mitigation alternatives for direct and indirect wetland impacts. Under Option 1, the total 19,910 SF (0.46 acre) of direct and indirect wetland impacts would be mitigated for through 38,901 SF (0.89 acre) of wetland creation and 2,021 SF (0.05 acre) of wetland enhancement. In addition, 80,225 SF (1.84 acre) of wetland buffer would be created; 13,296 SF (0.31 acre) of buffer would be restored; and 7,204 SF (0.17 acre) of wetland buffer would be restored around the area of wetland creation. Wetland mitigation will meet ratios provided in FWRC 19.145.430(5) and will occur onsite in the vicinity of North Lake. Under Option 2, if deemed preferred by State and Federal regulatory agencies, the Applicant would purchase credits from the King County In-Lieu Fee (ILF) program as mitigation for wetland impacts. If Option 2 is chosen, Option 1 would not be enacted and all required documentation for the use of an ILF program (analysis of mitigation alternatives, credit-debit analysis, etc.) would be provided at a later date in an ILF Use Plan. In either Option 1 or 2, the total 32,843 SF (0.75 acre) of permanent and temporary wetland buffer impacts as a result of the construction of the detention ponds would be mitigated for onsite. Proposed onsite buffer mitigation includes the creation of 27,113 SF (0.62 acre) of wetland buffer, restoration of 29,819 SF (0.68 acre) of wetland buffer, and replacement of 3,184 SF (0.07 acre) of wetland buffer. Review Comments and Recommendations Based on the document review for consistency with the City of Federal Way requirements and regulations, we have the following comments and recommendations: Critical Areas Report and Proposed Mitigation Plan Review: Woodbridge Business Park 3 1. We agree with the wetland delineation boundaries, rating forms, and rating classifications established by Talasaea for wetlands occurring on the proposed project site. 2. We generally agree with the conceptual mitigation plan and believe that the proposed mitigation site appears to be an adequate location for wetland creation. As the mitigation design progresses, we continue to strongly recommend that the applicant perform further environmental investigations (groundwater level monitoring, soil analysis, etc.) at the proposed mitigation site to acquire the necessary data and information to inform mitigation feasibility and design. 3. We agree that 38,901 SF or wetland creation is adequate for 19,901 SF of direct and indirect wetland impacts based on the guidance in Ecology’s Wetland Mitigation in Washington State – Part 1: Agency Policies and Guidance (2006) and FWRC 19.145.430(5). However, we recommend the applicant increase the proposed area of wetland creation by 5 to 10 percent of the total mitigation area (approximately 2,000-4,000 SF) to account for the risk of failure, uncertainties, and the temporal loss of original wetland functions and area, ensuring that the mitigation to impact ratios are successfully met. 4. The previous version of the critical areas report and conceptual mitigation plan (dated October 27, 2018) described 63 wetlands within the Project site. The Revised Report only discusses 48 wetlands within the Project site. ESA understands that six wetlands (Wetlands CB, CD, BE, BF, BK, and BL) are located on the parcel that was removed from the project (King County Tax Parcel Number 7978200520); and therefore, should not be included in the Revised Report. However, the Revised Report does not account for nine wetlands that were previously reported as occurring on the project site, and confirmed by ESA in the field. It is our recommendation that the Revised Report be corrected to include Wetlands CE, FA, KG, KH, KI, KJ, KK, KL, and KM or provide details on why they were omitted. 5. In our November 30, 2018 review memo we recommended several areas of the design be reevaluated to minimize impacts to wetlands and wetland buffers. We agree that Talasaea has sufficiently reduced direct impacts to wetlands to the greatest extent feasible for the proposed development, as presented in the Comment Response. 6. As stated in our November 30, 2018 review memo, the City considers grading within a wetland buffer to be development, and therefore, simply restoring the buffer post-construction does not meet FWRC requirements. The applicant needs to show that the proposed temporary buffer impacts due to site grading meet the criteria under FWRC 19.145.440 – Development within wetland buffers, including requirements for buffer averaging and/or buffer reduction if proposed. ESA recommends that the Revised Report be amended to include a clear description of how the Project meets these criteria. 7. As stated in our November 30, 2018 review memo, the wetland buffers on the Site Plan are inconsistent with the wetland buffers on the figures in the Revised Report. For example, buffers for Wetlands BA-2, PK, and BB appear larger on the Site Plan than on Figure WI.1 in the Report. ESA continues to recommend the Site Plan be revised to reflect the buffers presented in the Report. 8. As stated in our November 30, 2018 review memo, sheets of the Site Plan that contain the proposed development should only show the buffers post-development and should not include existing buffers for wetlands that will be filled or indirectly impacted. It was recommended the Site Plan be revised to show post- development buffers and an existing conditions figure be added to the Site Plan. Site Plan sheets ST-01, ST- Critical Areas Report and Proposed Mitigation Plan Review: Woodbridge Business Park 4 02, ST-03, GR-01, GR-02, and GR-03 continue to show wetlands and wetland buffers that will be impacted as a result of the Project. ESA continues to recommend the Site Plan be revised to only show post- development buffers on these pages. ESA considers the topographic survey sheets (Sheets EX-01, EX-02, and EX-03) to sufficiently represent existing conditions. 9. According to the Comment Response, the ordinary high water mark (OHWM) of North Lake was flagged in the field. However, no methodology or date of fieldwork is provided in the Revised Report. ESA recommends that this information be added to the report. 10. ESA recommends that the line representing the 200-foot Shoreline Management Zone be added to all relevant figures in the Revised Report to ensure that the only work in this area will be the installation of enhancement plantings and minor grading, which according to the Revised Report, would not trigger a shoreline development permit. Currently, according to Sheet ST-03 of the Site Plan, it appears that road improvements are proposed in the vicinity of Wetland BL, within the 200-foot Shoreline Management Zone. Additionally, because the proposed mitigation area is within the Shoreline Management Zone, we recommend that the Section 6 – Regulatory Review of the Revised Report be amended to include justification of why a shoreline development permit would not be required. 11. According to the Mitigation Grading Plan (Sheet W2.0) of the Revised Report, an existing upland swale in the proposed mitigation area will be graded to a similar elevation as portions of the proposed wetland creation area. Wetland-suitable plants are also proposed to be installed in this area per the planting plan (Sheet W3.1). According to Sheet W1.3, this area is considered to be wetland buffer restoration. However, the proposed grading and planting is consistent with wetland creation. ESA recommends that this area be revisited to ensure that wetland buffer is successfully restored here, and the created wetland is adequately buffered, as proposed. 12. ESA agrees that the 10-foot wide sewer easement been added to existing figures sheets of the Site Plan (Sheets EX-01, EX-02, and EX-03). However, the easement has not been included on the project sheets of the Site Plan (Sheets ST-01, ST-02, and ST-03). Additionally, the easement is not labeled on the figures in the Revised Report. ESA recommends that the sewer easement is labeled an included on all sheets of the Site Plan as well as in Plan Legend on all sheets in the Revised Report. 13. ESA agrees that the mitigation plan in the Revised Report clearly shows the wetland creation and buffer creation areas outside of existing buffers as recommended in our November 30, 2018 memo. 14. ESA agrees that the plans have been adequately revised to remove any mitigation from the sewer easement as originally recommended in the November 30, 2018 memo. Bulletin #129 – September 24, 2018 Page 1 of 1 k:\Handouts\Resubmittal Information RESUBMITTAL INFORMATION This completed form MUST accompany all resubmittals. Additional or revised plans or documents for an active project will not be accepted unless accompanied by this completed form. Changes to drawings must be clouded. Applicants will be required to affix the city’s date stamp on each page of resubmitted plans and to collate loose plans into existing plan sets. You are encouraged to contact the Permit Center prior to submitting if you are not sure about the number of copies required. Project Number: ___ ___ - ___ ___ ___ ___ ___ ___ - ___ ___ - ___ ___ Project Name: _______________________________________________ ____ Project Address: _ _____________________________________________________ Project Contact: ________________________________________________________ Phone: _________________________ Email ________________________________ RESUBMITTED ITEMS: # of Copies DETAILED Description of Item Resubmittal Requested by: _______________________ Letter Dated: _____/_____/_____ (Staff Member) OFFICE USE ONLY RESUB #: _______ Distribution Date:___________ By:___________ Dept/Div Name # Description Building Planning PW Fire Other DEPARTMENT OF COMMUNITY DEVELOPMENT 33325 8th Avenue South Federal Way, WA 98003-6325 253-835-2607; Fax 253-835-2609 www.cityoffederalway.com