Woodbidge B Exhibit A - Findings for Project Approval
Exhibit A – Findings for Project Approval Page 1 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
Exhibit A
Findings for Project Approval
Federal Way Revised Code (FWRC) Chapter 19.65, “Process III Project Approval”
Woodbridge Building “B” Project, File #17-104236-UP
The Director of Community Development hereby makes the following findings according to content
requirements of the Process III written decision as outlined in Federal Way Revised Code (FWRC)
19.65.100(4). These findings are based on a review of city documents and items submitted by the applicant
and received September 1, 2017, September 11, 2017, September 29, 2017, June 28, 2018, July 10, 2018,
August 15, 2018, September 18, 2018, October 9, 2018, February 12, 2019, and July 30, 2020.
For reference: FWRC=Federal Way Revised Code (current code); FWCC=Federal Way City Code
(1994 code); CZA=Concomitant Zoning Agreement; and CZA Exhibit C=CP-1 regulations.
1. Proposal – The proposal is Woodbridge Building “B” (formerly Greenline Warehouse “B”),
construction of a 45-foot-tall, 214,050 square-foot general commodity warehouse with 245 1 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. Since the original
submittal, a Boundary Line Adjustment (BLA) was recorded (city file 17-101484-SU), altering the lot
lines of the subject property. Future submittals related to this project must contain the most current
legal description. This will be made a condition of approval.
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. Zoning and Comprehensive Plan Designation –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 the 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 according to CZA Exhibit C, Section VII, “Permitted Uses on Those Portions of the
CP-1 Zoned Property Lying Outside the Managed Forest Buffer.” The CZA states that warehousing
and distribution are allowed, subject to Process IV, Hearing Examiner review (FWRC Chapter 19.70)
when such a facility is within 200 feet of a single-family zone or use. The subject property is not
within 200 feet of a single-family zone or use. The Federal Way Comprehensive Plan (FWCP)
designation for the subject property is Corporate Park.
1 The submitted site plan (Sheet ST-01) prepared by ESM, June 18, 2018 (resubmitted June 28, 2018), states “Parking: 245 car
stalls (8 ADA accessible)”; however, the drawing shows 244 total parking spaces.
Exhibit A – Findings for Project Approval Page 2 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
The proposal was reviewed as a general commodity warehouse with an associated office. A future
change in the type of use and/or occupancy shall require review for compliance with applicable
requirements, and to determine any impacts, including revisiting the SEPA threshold determination
and Use Process III decision, as needed. This will be made a condition of approval.
3. Site Plan Review Process – 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.
4. State Environmental Policy Act (SEPA) – The proposed improvements exceed categorical exemption
levels according to Washington Administrative Code (WAC) 197-11-800. The city issued a Mitigated
Determination of Nonsignificance (MDNS) on October 9, 2020 (city file 17-104237-SE). The
threshold determination comment period ended October 23, 2020, and the appeal period ended
November 13, 2020. The city received comments during the public comment period on the MDNS.
The city considered all comments received. A SEPA appeal was filed on November 12, 2020. The
SEPA appeal hearing will occur after the issuance of this Use Process III decision and the expiration
of its associated appeal period.
5. Public Notice – According to Process III regulations, a Notice of Application (NOA) was published in the
Federal Way Mirror, posted on the subject property, posted on each of the official notification boards of
the city and public libraries located within the city, and mailed to the persons receiving the property tax
statements for all property within 300 feet of each boundary of the subject property on October 13, 2017.
Approximately 51 written comments were received on the application. According to SEPA regulations, a
notice of the MDNS was published in the Federal Way Mirror, posted on the subject property, mailed to
all owners of real property as shown in the records of the county assessor located within 300 feet of the
site, emailed to agencies, and sent to people who provided comments in response to the NOA, on October
9, 2020. Approximately 40 written comments were received on the MDNS.
6. Public Comments – Approximately 51 written comments were received on the application. The comments
generally relate to alleged environmental impacts, traffic, zoning, design, process, infrastructure &
utilities, pollution, noise, odor, economic impacts, public health & safety, quality of life, property values,
neighborhood character, historic preservation, and green space. Approximately 40 written comments were
received on the MDNS. The MDNS comments generally relate to alleged environmental impacts,
transportation, stormwater, wetlands, tree removal, noise, economics, quality of life, historic preservation,
green space, and that any changes must be compatible with the existing design of the campus. Several
MDNS comments also discuss the separate Woodbridge Building “A” (formerly Greenline Warehouse
“A”) and Woodbridge Corporate Park (formerly Greenline Business Park) projects currently under review
by the city. Concerning these separate projects, the comments received by the city variously assert that
cumulative SEPA review and/or an Environmental Impact Statement (EIS) are required.
The city has carefully and thoroughly considered each of the comments received as part of the city’s
review of the application. All of these comments will be included within the administrative record for
this proposal and will accompany the application throughout the city’s project review process.
The city also provides the following response concerning the comments requesting a master plan,
cumulative SEPA review, and/or an EIS for the project. A master plan was not proposed or otherwise
requested by the applicants, and no applicable statutory or local code provision allows the city to
unilaterally require the preparation of a master plan. The applicants have also elected to submit separate
complete application submittals for projects on the former Weyerhaeuser Campus, which the city is
Exhibit A – Findings for Project Approval Page 3 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
required by law to process. (Also, see the finding below regarding “cumulative impacts analysis.”)
And unless there are significant adverse environmental impacts that cannot be mitigated, a SEPA
Determination of Significance requiring preparation of an EIS is inappropriate. The city’s SEPA
Responsible Official has determined that this standard has not been met concerning the project. Finally,
the city is generally prohibited from requiring an applicant to provide mitigation of a project to an extent
that exceeds the project’s anticipated impacts. The city accordingly cannot require the Woodbridge
Building “B” project to mitigate an impact that it does not cause or otherwise contribute to.
7. Bulk & Dimensional Requirements – Per Section III.B of the CP-1 regulations, no building setbacks
are specified in the CP-1 zone except for the continuous Managed Forest Buffer (MFB), which states
that a continuous MFB shall be provided around the entire perimeter of the CP-1 property. Please see
section 9, Managed Forest Buffer (MFB), below for further information regarding the MFB.
Section III of the CP-1 regulations states that “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 applicant submitted an “Impervious Area Exhibit,” prepared by ESM, June 18, 2018, which
shows the existing impervious coverage in the CP-1 zone is 11.6 percent and the construction of the
proposed project would increase it to 15.7 percent (the proposed increase in the impervious area also
includes Woodbridge Building “A”).
Per Section IX of the CP-1 regulations, the maximum building height is six stories. The tallest
proposed component of the project is the building at 45 feet in height, which is less than six stories.
8. Parking Requirements – 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 the office and one for every 1,000 square feet of gfa for the
warehouse. No floor plan has been submitted, so the exact breakdown of office and warehouse space
has not been determined. As an example, if 10 percent of the building is an office, then required
parking would be: for the office (21,405/300 = 72) and the warehouse (192,645/1000 = 193), for a
total of 265 parking spaces. For reference, the site plan depicts 244 parking spaces. A condition of
approval will require the building permit application plan set to include a section with a parking
analysis that demonstrates compliance with the required parking ratios.
9. Managed Forest Buffer (MFB) – Section III.B of the CP-1 regulations states, “A continuous Managed
Forest Buffer shall be provided around the entire perimeter of the CP-1 property.” The depth of the
setback is 50 feet where the perimeter abuts a city road and 100 feet where abutting a state highway.
A 50-foot buffer is shown along Weyerhaeuser Way, which is the perimeter of the CP-1 property in
that area. A 100-foot buffer is shown along State Route 18 (SR-18), which is the perimeter of the CP-
1 property in that area.
Planned activities in the MFB include managed forest, a 10-foot wide pedestrian path, fencing, a
driveway, and signage, which are allowed according to CZA Exhibit C, Section VIII, “Uses on Those
Portions of the Property Lying Within the Managed Forest Buffer.”
Per CZA Exhibit C, Section X.B.2, within the MFB natural materials are preferred for fencing.
Fencing is required around wetland buffers. Also, stormwater conveyance infrastructure is planned
within the MFB west of Stream EA. Such activity is permitted within the MFB per CZA Exhibit C,
Section VIII.D.2, which allows minor grading or filling associated with permitted uses within
forested areas not requiring review or approval under Section XII (“Environmentally Sensitive
Areas”). Per the CZA, the activity must be supervised by the Forester.
Exhibit A – Findings for Project Approval Page 4 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
Per Section IV.B of the CP-1 Zoning Regulations, the property owner shall designate a qualified
Forester and prepare a General Maintenance Plan (GMP). The property owner has designated Brian
Gilles of Gilles Consulting as the Forester and a GMP has been submitted for review. The Managed
Forest Buffer Management Plan at the Greenline Building B Site, June 26, 2018, is approved with the
following condition:
• Work is not allowed within Wetlands DP, DT, Stream EA, and associated buffers, as
stream setback intrusions and improvements/land surface modifications in non-CZA
exempt wetland setbacks require Use Process IV application review and approval per
FWCC Sections 22-1312(c) and 22-1359(d).
10. Landscaping –Section XI of the CP-1 regulations states that “The provisions of this section shall
modify the application of Chapter 22, Article XVII (Landscaping), of the FWC[C] in the CP-1 zone.”
This modification language states in part, “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 pre-developed state.” The preliminary landscape plan (Sheet LA-01) shows portions of the
property outside of areas for buildings, future buildings, parking, storage or accessory uses, and
proposed landscaping areas to be retained in a “native” or pre-developed state.
Per FWCC Section 22-1564(w), “All loading areas shall be fully screened from public right of way or
non-industrial/manufacturing uses with Type I landscaping.” The project contains a loading area on
the east side of the building facing Weyerhaeuser Way. The preliminary landscape plan (Sheet LA-01)
shows that there is existing vegetation to remain inside and outside of the MFB, along with
supplemental planting if necessary to screen the loading area from Weyerhaeuser Way. There are notes
on Sheet LA-02 that reference Type I and Type II landscaping for additional, supplemental, and
replanting purposes. A condition of approval will require installation of all additional, supplemental,
and replanted Type I and II landscaping, as indicated on Sheet LA-01 and LA-02, before the building's
final inspection.
Section XI.D of the CP-1 regulations states, “New parking areas shall comply with minimum
standards of the FWC[C]; except that selection and distribution of plant material conforming to
existing development shall be preferred.” Per FWCC Section 22-1567(b)(1)(a)(ii), interior parking lot
landscaping is required at the rate of 22 square feet of Type IV landscaping per parking stall, when 50
or more parking stalls are provided. As 244 parking stalls are provided, 5,368 square feet of parking
lot landscaping is required (244 x 22 = 5,368). Plan Sheet LA-01 2 shows 6,501 square feet of
proposed parking lot landscaping. If the number of parking spaces increases such that the required
parking lot landscaping exceeds the 6,501 square feet shown, then additional parking lot landscaping
will be required.
FWCC Section 22-1567(c) contains requirements for the location and size of parking lot landscape
islands. Sheet LA-01 of the plan set shows that all parking lot landscape islands meet the criteria.
2 The submitted preliminary landscape plan (Sheet LA-02) states 252 parking stalls are proposed and that the total square feet of
interior parking lot landscaping proposed equals 11,209 total square feet and 7,701 square feet if only counting 350 square feet
for areas larger than 350 square feet. FWCC Section 22-1567(c) limits the size of parking lot landscape islands to a maximum of
305 square feet, not 350 square feet. The site plan drawing shows 244 parking stalls are being provided, not 252 stalls, which
requires 5,368 square feet of parking lot landscaping (244 x 22 = 5,368). On Sheet LA-01, 6,501 square feet of parking lot
landscaping is shown, counting only 305 square feet for areas larger than 305 square feet.
Exhibit A – Findings for Project Approval Page 5 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
FWCC Section 22-1567(e)(1) requires parking areas adjacent to the public right-of-way to incorporate
berms at least three feet in height within perimeter landscape areas, or through other means as listed
in the code section, to reduce the visual impact of parking areas and screen automobiles. Plan Sheet
LA-01 shows that the 50-foot wide MFB, along with other existing vegetation that will remain, will
substitute for the berm to screen parking areas near Weyerhaeuser Way.
Section XI.A.3 of the CZA states, “Selection and installation of plant material in all forested areas
shall be the responsibility of the designated Forester.” In the MFB Management Plan, the Forester has
identified a recommended plant palette. On landscaping plan set Sheet LA-02, it lists species to be
used within the MFB. The following species are listed on Sheet LA-02 and are not listed in the MFB
recommended plant palette: Wild Ginger, Wood Fern, and White Flower Rhodie. A condition of
approval will require that these species be removed from the landscaping plan submitted with the
building permit.
11. Tree Retention/Replacement – According to FWCC Section 22-1568, the development must retain or
replace 25 percent of the existing significant trees on site. According to the submittal, the Building
“B” property contains approximately 607 significant trees. The parcel will retain significant trees in
the MFB and other areas proposed to remain undisturbed. Plan set Sheet TR-01 (Tree Retention Plan)
shows that approximately 29 percent of the significant trees on the Building “B” site will be retained.
This requirement is satisfied. A condition of approval will require all significant trees to be retained
within the MFB and within areas planned to remain undisturbed according to the submitted plan set
(Sheets TR-01 & GR-01) to the maximum extent feasible.
12. Forest Practices – A Forest Practices Class IV-General Application is required as more than 5,000
board feet of merchantable timber will be harvested from the property in conjunction with the
development activity. Per FWRC 19.120.200(1)(a), “A Class IV – General Application shall be
approved based on an approved clearing and grading plan and tree and vegetation retention plan and
prior to conducting forest practices on the project site.” A condition of approval will require the
applicant to obtain Forest Practices approval before the issuance of the building permit.
13. Critical Areas – Section 12 of the CZA addresses environmentally sensitive areas. The project site
contains wetlands and a stream. The applicant submitted a critical areas report prepared by Talasaea,
which has subsequently been revised and submitted for review. The most recent version is “Critical
Areas Report Greenline Building B,” revised June 26, 2018. In the report, the consultant notes that the
revised report assumes that the construction of Greenline Building “A” is complete and therefore, the
built condition of Building A is the baseline condition. This baseline consists of Stream EA with an
averaged buffer, Wetland DT with an averaged buffer, and Wetland DP with a regular buffer.
For Woodbridge Building “B,” the applicant plans to make minor revisions to the Stream EA averaged
buffer and Wetland DT averaged buffer from the baseline condition of built Greenline Building “A.”
The report was sent to the city’s consultant, ESA, for a peer review. Throughout the review, ESA
completed site visits and reviewed relevant documents. In their April 1, 2019, memorandum, they state
the following comments and recommendations, some of which the city will incorporate into conditions
of approval as appropriate:
“After review of these documents, ESA has the following comments and recommendations
regarding the revised submittal documents:
Exhibit A – Findings for Project Approval Page 6 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
• “The Revised Report includes wetland descriptions of the wetlands onsite as recommended
by ESA, however, the Revised Report does not include an analysis of wetland functions as
required by Section 22-1356(b) of the 1994 Federal Way Code.
• “If Talasaea is considering the built-condition of Building A to be the existing conditions
for the Building B proposal, Sheet W1.0 of the Revised Report should be revised to show
the reduced buffers for Stream EA and Wetlands DT, DR, and DQ to be consistent with the
proposed buffers on Sheet W1.2 of the CAR for Greenline Building A. Currently Sheet
W1.0 shows the buffers as if Building A was not built.
• “If Talasaea is considering the built-condition of Building A to be the existing condition for
the Building B proposal, Sheet EX-01 should not show wetlands impacted by the
construction of Building A. This sheet should also be revised to show the reduced buffers
mentioned in the bullet above and the footprint of the Building A proposal.
• “Plan sheets that show the proposed development should show the buffers post-
development, including averaged wetland and stream buffer. Currently the plan sheets do
not show the averaged wetland buffers for Stream EA and Wetland DT.
• “It is unclear why an area of wetland buffer replacement for Building A is located south of
the road between Buildings A and B. This area of buffer addition was not included on
documents we reviewed for Building A.
• “According to the Response Letter, “Some buffer modification to offsite critical areas
(Wetland DT and Stream EA) are occurring as part of the Building A application to
accommodate the required stormwater drainage easement. These same buffers will be
modified a second time to accommodate the edge of the Greenline Building B development.
“ESA recommends that if buffers are modified for the Building A application they remain
modified and protected in perpetuity. Buffers should not be modified a second time to
accommodate the Building B development. We recommend that buffer modifications
proposed in the application for Building A be established so they reflect the buffers that
will ultimately be needed for Building B as well.
• “As mentioned above, ESA has not received a response to comments and recommendations
submitted in the review memo for Building A (dated April 3, 2018). Many of these
comments were on inconsistencies between report text, figures, and the plan sheets. We
recommend that once these inconsistencies are resolved in the submittal for Building A, the
submittal documents for Building B are also revised where necessary.”
Some of the above consultant recommendations from ESA will be made conditions of approval. The
CZA allows buffer averaging with limitations, and the applicant is proposing buffer averaging as
detailed above. For reference, CZA Sections XII.F and XII.G address wetland and stream setback
(buffer) averaging. The proposed Stream EA buffer averaging involves three locations where the
buffer is reduced to no less than 25 feet and two locations where the buffer is to be replaced. The area
to be averaged does not extend beyond the boundaries of the site plan. The proposed Wetland DT
buffer averaging involves one location where the buffer is reduced to no less than 50 feet and two
locations where the buffer is to be replaced. The areas to be averaged do not extend beyond the
boundaries of the site plan.
Exhibit A – Findings for Project Approval Page 7 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
For clarity, in addition to the required revisions to the critical areas report detailed above, the applicant,
as a condition of approval, shall show/label on Sheet W1.1 the size of each area of buffer reduction and
replacement to demonstrate that each reduction is compensated for at the location of the critical area
where that reduction occurs. Adjustments shall be made if necessary. As a condition of approval, areas
of wetland and stream buffer replacement shall be enhanced with native vegetation, as necessary, to
ensure buffer function continues post-development.
On Sheet W1.1 there is an area labeled as “buffer replacement for Parcel A,” which is located near
the driveway entrance off of Weyerhaeuser Way and has the proposed pedestrian trail within it. This
buffer replacement area was not shown in materials submitted for the Woodbridge Building “A”
project. Woodbridge Building “A” is a separate project. The CZA does not allow for buffer averaging
to extend beyond the boundaries of the site plan. This area is also separated from wetlands located on
Parcel A by a driveway; averaged buffer areas must be in proximity to their wetland. The “buffer
replacement for Parcel A” shown on Sheet W1.1 is not approved and as a condition of approval shall
be removed from Sheet W1.1. In several locations within the critical areas report it is stated that
replacement buffer area will be located outside of the MFB as required by the city. It is fine to have
some averaged buffer area within the MFB; the original concern was the placement of all buffer
replacement areas within the MFB or making the entire MFB a buffer replacement area.
CZA Section 12.H.3 states, “H. Exemption. The following shall be exempt from the provisions of
Section 22, Article XIV of the FWC and requirements of this Agreement: 3. Development affecting
wetlands which are individually smaller than 2,500 square feet and/or cumulatively smaller than
10,000 square feet in size in any 20-acre section of this property;” For clarity, the “property”
referenced in the CZA citation is all property subject to the CZA, not an individual development site.
Future projects need to allocate their entire site area into one or more 20-acre sections. Wetlands DP
and DT are non-exempt and subject to applicable provisions of the CZA and FWCC.
Per FWCC Section 22-1270, “The city may require other construction techniques, conditions and
restrictions on development in order to minimize adverse impacts on steep slopes, wells, streams,
regulated lakes or regulated wetlands.” To protect the function of the wetlands, a condition of
approval will require permanent fencing at the outer edge of the wetland buffer for Wetland DT.
Fencing around Wetland DP’s buffer is not appropriate as it is located within the buffer of Stream
EA. The boundary between the wetland buffer and contiguous land shall be identified with permanent
signs. Permanent signs shall be a city-approved type designed for high durability. Signs must be
posted at an interval of one per every 150 feet and maintained by the property owner in perpetuity.
Public Works has a standard detail for the wetland sign. The wetland sign must meet the standard
detail required by Public Works.
While wetland impacts are exempt from city mitigation requirements as permissible in the CZA, the
Talasaea report describes federal and state regulations as follows: “Wetland impacts on the Project
Site are subject to applicable State and Federal regulations. Wetland impacts are regulated on the
Federal level by Sections 404 and 401 of the Clean Water Act. The US Army Corps of Engineers
(Corps) is responsible for administering compliance with Section 404 via the issuance of Nationwide
or Individual Permits for any fill or dredging activities within wetlands. Any project that is subject to
Section 404 permitting is also subject to requirements of Section 401 of the Clean Water Act (CWA),
administered by the Department of Ecology (DOE). Because direct wetland impacts are proposed on
the Project Site, the project would be required to comply with all Section 404 and 401 permitting
requirements prior to any construction-related activities that would affect ‘waters of the US.’ A
permit application will be submitted to the Corps to address the proposed critical area impacts for
Greenline Building B in conjunction with Greenline Building A.”
Exhibit A – Findings for Project Approval Page 8 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
In January 2018, the city conducted a preapplication meeting for construction of Corps-required
compensatory mitigation at an off-site location on parcel 152104-9178, for wetland impacts
associated with Greenline Buildings A & B. As was stated in the September 8, 2017, Preapplication
Conference Summary for the Greenline Warehouse “B” project, “In addition, the city will not issue
any approvals to fill wetlands until all state, federal, or other agency permits as may be required to fill
the wetlands have been obtained and verification provided to the city.” In recognition of FWCC
Section 22-1224, this will be made a condition of approval.
14. Tacoma Smelter Plume – The former Asarco copper smelter in Tacoma caused widespread soil
contamination with lead and arsenic in parts of King, Pierce, Kitsap, and Thurston counties. This
1,000 square mile area is known as the Tacoma Smelter Plume. The state cleanup level for arsenic is
20 parts per million (ppm). According to the Department of Ecology mapping checked in 2019, the
subject property is located in the Tacoma Smelter Plume detect area containing under 20 ppm arsenic;
therefore, testing of site soils is not applicable.
15. Clearing & Grading – There is an approximately 34-foot elevation change across the property, from
the northwest to the southeast. The preliminary cut/fill analysis is 19,700 cubic yards (stripping),
31,800 cubic yards (cut), 55,400 cubic yards (fill), and 23,600 cubic yards (net fill). According to the
SEPA checklist, “Cuts in the west and fills in the east will be completed to create a level development
pad. A small portion of structural fill material will be imported for the building foundation. Native on-
site material will be used for general fill.” The applicant submitted a geotechnical report, “Revised
Geotechnical Engineering Services Report, Proposed Greenline Building B Development Federal
Way, Washington,” on June 21, 2018, prepared by GeoEngineers. The report states, “The finish floor
elevation for the structure is planned to range from Elevation 393 feet in the southeast to 396.4 feet in
the northwest. Cuts and fills will be required to create the building pad. Soil cuts are planned through
most of the building pad and appear typically less than 5 feet. One exception is in the northwest corner
where cuts up to about 12 feet will be required in the proposed parking area. The greatest fill thickness
(approximately 7 feet) is required in the southeast corner of the building footprint. We understand that
a 2H:1V (horizontal:vertical) cut slope will be used to establish planned grade along the northwest
boundary. A 6- to13-foot high retaining wall is planned for the east and southeast margin of the site.
We understand that the wall type has not been determined.” Land surface modification activities will
be reviewed for consistency with applicable standards outlined in FWCC Division 7 and Chapter
19.120 FWRC as part of construction permitting.
16. Design Guidelines – Section X of the CP-1 regulations states that “Provisions of the FWC[C] relating
to façade measurement, modulation, distance between structures, or materials, other than those
specified herein, shall not apply to this zone.” The FWCC states that one of the purposes of site plan
review is, “To encourage proposals that embody good design principles that will result in high quality
development on the Subject property.” The city adopted non-residential community design guidelines
in 1996, after the effective date of the CZA. In the September 8, 2017, Preapplication Summary
Letter for the Greenline Warehouse “B” project, the applicant was encouraged to meet the city’s
design guidelines to complement the other buildings in the area.
On Sheet A1.0 of the plan set, the architect provides a design narrative:
“This design has been envisioned with a clear mindset of the surrounding landscape and
regional materials. Sourcing materials and design elements from the Pacific Northwest
aesthetic allows this warehouse building to blend in with the surrounding character of
Federal Way. Located on a well-known site, we have included timber accents and artistic
Exhibit A – Findings for Project Approval Page 9 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
reveal patterns to emphasize the history and character of the area. Entry nodes, visible to
the public streets, are comprised of large expanses of glass, glue laminated timber framing,
façade modulation, large canopies and arcades. Building signage will be provided with
non-traditional methods including regional materials and forms, strong composition with
the building design and unique signage elements. Altogether, the proposed approach to the
building is of superior design quality and deep appreciation for the character and history of
the chosen site and the region.”
Sheet A1.0 explains the incorporation of a selection of current FWRC design guidelines (FWRC
Chapter 19.115), including façade modulation; use of a canopy and arcade at the building entries;
recessed windows and panels; artistic reveal patterns; paint scheme; indentations; overhangs;
emphasizing the building entrances with transparent glass; timber beams; and large overhangs.
FWCC Section 22-1564(u) requires building walls that are uninterrupted by a window, door, or other
architectural feature, that are 240 square feet or greater in area, and not located on a property line, to
be screened by landscaping. On Sheet A1.0, the architect states that “no blank walls exist on the
elevations with an uninterrupted area greater than 240 s.f. A combination of vertical banding,
mountain reveal patterns, varying window shapes, trellis features and main entry design demonstrates
compliance with FWCC 22-1564(u).” Sheet A1.1 states, “applicant acknowledges in final building
permit elevations no blank wall surface greater than 240 s.f. will be proposed.”
17. Rooftop Mechanical Equipment –The submittal does not provide detail on the location and screening
for rooftop and ground-mounted mechanical equipment. A condition of approval will require the
building permit submittal to address these items:
a. For rooftop mechanical equipment, per FWCC Section 22-960(a), vents, mechanical penthouses,
elevator equipment, and similar appurtenances that extend above the roofline must be surrounded
by a solid sight-obscuring screen that meets the following criteria: (a) the screen must be
integrated into the architecture of the building; and (b) the screen must obscure the view of the
appurtenances from adjacent streets and properties.
b. For ground-mounted mechanical equipment, per FWCC Section 22-1565(a)(1), Type I landscaping
is intended to provide a solid sight barrier to totally separate incompatible land uses. This
landscaping is typically found around mechanical or electrical equipment and utility installations.
18. Garbage/Recycling – FWCC Section 22-949 provides requirements for the garbage receptacle and
dumpster placement and screening. The project will have two interior recycling collection areas
within the building and a recycling dumpster enclosure across from the truck court. A solid waste
enclosure is also proposed across from the truck court. The enclosures will not be located within a
required yard or buffer area. The enclosures are proposed to have concrete tilt-up panels with metal
deck-clad gate doors, with all metals painted. Per FWCC Section 22-1564(d), “All trash enclosures
shall be screened from abutting properties and/or public rights of way by a 100 percent sight-
obscuring fence or wall and appropriate landscape screen.” Per FWCC Section 22-1564(b), “All
outside storage areas shall be fully screened by Type I landscaping a minimum of five feet in width,
as described in section 22-1565(a), unless determined by the community development review
committee (CDRC) that such screening is not necessary because stored materials are not visually
obtrusive.” Sheet LA-01 shows existing vegetation to be retained adjacent to the enclosure area, but
no verification if it meets or exceeds Type I landscaping. A condition of approval will require the
building permit landscaping plan to provide Type I landscaping a minimum of five feet in width on
the north and south sides of the combined enclosure area.
Exhibit A – Findings for Project Approval Page 10 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
Regarding sizing of facilities, referencing June 18, 2018, “Sheet No. A1.0,” the proponent
acknowledges that the code requires the provision of a minimum of 643 square feet in area for
recycling storage space. “Solid waste” includes both garbage and recycling. The code sets minimums
for recycling space, but in practice, space set aside for garbage storage typically more than doubles
the minimums set for recycling alone.
In addition to one exterior recycling enclosure, the applicant states they are providing two interior
recycling collection areas of 242 square feet each. Setting aside designated space is the first step, and
as a condition of approval, plans must demonstrate: 1) how occupant use of these designated areas
will integrate with service access; and 2) how the storage and collection of other garbage generated
on-site comply with FWCC Section 22-949(e)(1), which states the recycling storage area and garbage
storage area shall be adjacent to each other.
As noted above, while a total area of 644 square feet has been designated for recycling receptacles,
this only satisfies the minimum required area for storage space for recyclables. The smaller area
designated for garbage storage (approximately 160 square feet) does not conform with the first clause
of FWCC Section 22-949, which states, “storage areas for garbage and recyclables shall be required
to be incorporated into the design.” In practice, garbage storage space typically more than doubles the
designated space for storage of recyclables. As such, the garbage enclosure may be inadequate for the
proposed building due to its size. Plans do not appear to accommodate a realistic level of service for a
site occupant. Therefore, as a condition of approval, plans must demonstrate that the garbage and
recycling storage needs have been incorporated into the design and planned for in ways that will serve
occupants over time.
For purposes of general guidance, if the applicant’s design objective is to minimize the area
designated for solid waste storage, consider designing to accommodate waste compaction equipment.
The current enclosure design is incompatible with the use of large-scale compaction equipment,
which may be the most economical long-term management option for a facility this large. For these
reasons, the plans could designate interior access point(s) leading to the loading dock area where
compaction equipment would be stationed. Based on facility size, a tenant may require more than one
compactor (one for garbage and one for recyclables) so the design could show how it would
accommodate two compactors adjacent to each other. Another form of compaction is balers (typically
used for compacting waste cardboard). Accommodations for compaction equipment could be
specified within the interior recycling storage space areas. Planning for this equipment would require
a reconfigured enclosure design. The two exterior enclosures can be eliminated if plans are revised to
indicate placement and access to adequate compaction equipment. To further accommodate
compaction equipment, revised plans should factor in overhead clearances, power access, drainage
management, and similar site needs.
19. Lighting – The proposal will include outdoor lighting. Per FWCC Section 22-954(c), “The applicant
shall select, place and direct light sources both directable and nondirectable so that glare produced by
any light source, to the maximum extent possible, does not extend to adjacent properties or to the
right-of-way.” A condition of approval will require the submittal of a lighting plan before the issuance
of a building permit for verification that this code criterion will be met.
20. Open Space – Section 13 of the CZA states:
“The Property has significant open space currently used for running, walking, kite flying
and other recreational activities. These uses may continue at Weyerhaeuser's discretion.
The City agrees not to require any dedication or conveyance of the Property or any
Exhibit A – Findings for Project Approval Page 11 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
portion for public purposes, provided, that in connection with any new development
applications within 200 feet of State shorelines, the City may require public trails, water
access or open space as may be required by adopted City codes.”
The parcel involved with this development proposal contains trails. According to the applicant’s
submittal, the trails will be removed from the site by the proposed development. The subject property
is not within 200 feet of state shorelines; therefore, the city cannot require the applicant to provide
public trails.
21. Noise – 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 outlined
in FWRC 7.10. The applicant submitted an environmental noise report (Greenline Building “B”
Development, Federal Way Washington Environmental Noise Report, July 2018, by Ramboll
Environ) 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 of approval (a
SEPA mitigation measure).
Regarding construction-related noise, the report states, “The following may help to reduce to 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 the 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 of approval will implement the above-listed items (SEPA
mitigation measures).
22. Air Quality – 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 downwind properties. The applicant submitted an
air quality report (Greenline Building “B” Development, Federal Way Washington Air Quality
Report, June 2018, by Ramboll Environ) 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
Exhibit A – Findings for Project Approval Page 12 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
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 of approval (a SEPA mitigation measure) 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.
• “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.”
Exhibit A – Findings for Project Approval Page 13 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
A condition of approval will implement the above-listed items (a SEPA mitigation measure).
Regarding the 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.”
23. Historic and Cultural Preservation –As part of the April 5, 2018, technical comment letter for
Woodbridge Building “B,” the applicant was requested to provide the cultural resource analysis that
was completed by Tetra Tech for Parcel B as part of the Woodbridge Building “A” project. For
clarification, Parcel B is the Woodbridge Building “B” site. The report applicable to the Woodbridge
Building “B” site is “Project #TAL-1593,” by Tetra Tech, undated. The applicant provided the report
to the city on behalf of Building “B” on June 28, 2018. This report was previously sent to the
Washington State Department of Archaeology & Historic Preservation (DAHP) as detailed below:
The applicant submitted reports regarding archaeological resources in the project area for the
Woodbridge Building “A” project (“Project #TAL-1593”, by Tetra Tech, undated & Project #TAL-
1572F”, by Tetra Tech, undated). These materials were sent to DAHP by the city.
DAHP provided an April 24, 2017, letter to the city in response stating, “We concur with the findings
of the two Tetra Tech reports regarding archaeological resources in the project area of potential effect
(APE) for the first and revised project areas. While addressing archaeological resources in the two
project areas, the reviewed materials are not responsive to our recommendations to conduct a
comprehensive survey and inventory of the former Weyerhaeuser headquarters campus. As clearly
stated in our letter, we request and recommend that the campus be surveyed and recorded by
professionals with expertise in architectural history as well as cultural resources to document historic
and cultural resources on the entire campus.”
The letter further states, “As a clarification, DAHP’s recommendation is not a request for listing of the
Weyerhaeuser building or associated resources in the National Register of Historic Places. Rather, we
are recommending that the property be surveyed and inventoried in order to document the historical
and architectural significance of the site for future planning purposes. A National Register listing is an
honorary recognition that follows a defined nomination process; whereas a survey and inventory of
cultural and historic resources is a planning tool and database for informed design-making.”
The August 25, 2017, comment response letter from the applicant for Woodbridge Building “A”
indicated that a full survey of the Weyerhaeuser Campus was underway. The full survey may be
forthcoming, but the information the city has received does not indicate any historic resources on the
site. In the applicant’s June 28, 2018, comment response letter for Building “B” they stated, “The
report is still underway. So far there is nothing on the Building B site that is of historical significance.”
The city also received an October 31, 2017, letter from the Washington State Department of
Archaeology and Historic Preservation (DAHP). The letter was in response to a citizen requesting a
“Determination of Eligibility” for the National Register for the headquarters building and its
landscape. The DAHP letter stated, “While not yet 50 years old the Weyerhaeuser Headquarters
would easily qualify for listing on the National Register of Historic Places (under criteria A & C) as a
ground breaking design that has been studied by generations of architects, architectural historians,
landscape architects and historians.” Further, “Specific details as to the boundaries of a listing would
need to be defined after further study but most likely includes the full 260 acres as initially developed
by Sasaki, Waller & Associates.” Also, “We would welcome a National Register application for the
building anytime. However keep in mind that per federal regulations, National Register listing
requires owner consent.”
Exhibit A – Findings for Project Approval Page 14 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
On July 30, 2020, the applicant submitted a memorandum prepared by Cardno entitled: “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” in which they
conclude:
“We have analyzed the Woodbridge Building B proposal with regard to historic resources under
SEPA. On the Building B property, the only feature identified in the Survey as contributing to
the recommended NRHP-eligible District is the 50-foot tree buffer adjacent to Weyerhaeuser
Road as it relates to the experience of a driver on Weyerhaeuser Road. The Building B site plan
shows that the project preserves a 50-foot or greater tree buffer adjacent to Weyerhaeuser Road.
Based on these factors, we conclude that the Building B proposal will not result in significant
adverse impacts to the recommended NRHP-eligible District as defined under SEPA.”
The city evaluated the Cardno conclusion of no significant adverse impacts in its SEPA determination
and determined it was correct.
The NHPA Section 106 process is a separate, federal regulatory procedure independent of the city’s
local project permit review framework. The Section 106 process is not within the city’s control, and it
contains standards that are different from those implicated in this Process III decision. The city
acknowledges that the outcome of the NHPA Section 106 process may result in mitigation measures
(either mandatory and/or voluntary) that are separate from and in addition to any requirements
imposed through the city’s review of the applicant’s proposal.
24. Additional Permitting – Additional permitting, such as engineering review and a building permit, are
required for site development; none of which have been applied for at this time. It is the applicant’s
responsibility to identify and obtain all required state, federal, or other agency permits.
25. Transportation – As a component of the Use Process III application, projects undergo traffic
concurrency analysis according to the state Growth Management Act (GMA); goals and policies of the
FWCP; and Chapter 19.90 FWRC, “Transportation Concurrency Management.” A Capacity Reserve
Certificate was issued in November 2017. The number of new PM peak hour vehicle trips generated by
that project was 78. A transportation impact fee is required and will be calculated based on the fee
schedule in effect at the time a building permit application is filed and must be paid before permit
issuance. A traffic study was submitted for review, IRG Greenline Buildings A and B Federal Way, WA
Transportation Impact Study, TENW Transportation Engineering NorthWest, March 6, 2018. Additional
transportation-related matters are addressed in the sections below.
26. Right-of-Way Modification – The Deputy Public Works Director issued a right-of-way modification
for Greenline Warehouse “A” outlining required frontage improvements for both Warehouse “A” and
Warehouse “B,” with timing and bonding requirements (city file #18-102212-SM). See the enclosed
June 22, 2018, decision document. The building permit site plan shall reflect the requirements
outlined in this letter; this shall be made a condition of approval. Construction plans shall be included
in the building permit submittal for review and approval.
27. Northbound Left-Turn Lane – Before the 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-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. This shall be made a condition of approval (a SEPA mitigation measure).
Exhibit A – Findings for Project Approval Page 15 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
28. Trucks – The traffic study stated that all truck trips are expected to utilize the primary driveway on
Weyerhaeuser Way South. It is expected that 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/I-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.
i. Before 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 (a SEPA mitigation measure).
ii. 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. Daily, I-5 southbound congestion routinely occurs between SR 18
and the South 320th Street interchange. To avoid traffic congestion and reduce travel time due to a
shorter distance, truck trips with origin and destination from the north could utilize South 320th
Street/I-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 /I-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 damage 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, before a certificate of occupancy is issued, 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 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 outlined 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 this condition, a “truck” shall mean a vehicle rated more
than 30,000 pounds gross weight as discussed in Chapter 8.40 FWRC.
Exhibit A – Findings for Project Approval Page 16 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
Before 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.
29. WSDOT –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 about 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 Warehouse “A” and
“B” and the mitigation was for both Warehouse “A” and “B.” The mitigation measure regarding the
SR-18 off-ramp right turn storage applies to the Woodbridge Building “B.” Before the issuance of a
certificate of occupancy, the applicant shall construct right-turn storage for the westbound SR-18 off-
ramp to mitigate the impact to the westbound off-ramp to the satisfaction and with approval of
WSDOT (a SEPA mitigation measure). Before engineering plans approval, WSDOT approval of the
traffic study and channelization plans shall be provided. This shall be made a condition of approval.
Also, per the October 29, 2019, Hearing Examiner’s Request for Reconsideration Decision for Greenline
Warehouse “A,” the following SEPA mitigation measure shall be made a condition of approval:
“Cumulative traffic impacts from Warehouse 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 Warehouse 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.”
Both the imposition and adequacy of this condition were subsequently upheld in the King County
Superior Court’s June 10, 2020, Order Denying Land Use Petitions in Consolidated Case No. 19-2-
30502—9 KNT.
The Hearing Examiner’s condition has since been satisfied. After consultation with WSDOT, the city
confirmed by a December 19, 2019, memorandum that the SR 18 westbound ramp intersection with
Weyerhaeuser Way South is located within WSDOT limited access; that WSDOT has jurisdiction
over the intersection; and that WSDOT’s LOS standards shall apply in the manner and to the extent
provided by state law.
Exhibit A – Findings for Project Approval Page 17 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
On July 22, 2020, the applicant’s transportation consultant, TENW, provided a technical
memorandum containing a SEPA analysis addendum to the Warehouse “A” and “B” TIA that
addressed the Hearing Examiner’s condition. The TENW memorandum acknowledged that WSDOT
has established a LOS D standard for the SR 18 westbound ramp intersection with Weyerhaeuser
Way South. TENW proceeded to conduct, and document, a cumulative traffic impacts analysis for
Warehouse A, Warehouse B, and the Business Park encompassing trip generation, trip distribution
and assignment, and future traffic volumes. The TENW analysis determined that the SR 18
westbound ramp intersection with Weyerhaeuser Way South is anticipated to operate at acceptable
(i.e., LOS D or better) levels with or without the three proposed projects, and therefore that no
additional mitigation or pro-rata share allocation is required to satisfy the Examiner’s condition.
TENW’s July 22, 2020, addendum was evaluated by the city. On August 18, 2020, the city’s Traffic
Engineer determined that the addendum met the requirements of the Hearing Examiner’s condition
and that no additional mitigation was necessary for the SR-18 westbound ramp intersection with
Weyerhaeuser Way South. The Community Development Department documented this conclusion in
a Conditions Compliance Verification memorandum on September 11, 2020.
30. Pavement – A pavement analysis for Weyerhaeuser Way South was performed by GeoEngineers
(“Geotechnical Engineering Services Report Weyerhaeuser Way South, 320th Street to SR 18
Weyerhaeuser Campus Property Federal Way, Washington,” August 29, 2017). Per the pavement
analysis, the development is expected to nearly triple the loading on the existing pavement (EASLs)
along the truck route on Weyerhaeuser Way South. Furthermore, the pavement in the project area is
approaching the end of its useable life. The Street Division has reviewed the pavement analysis and
determined that 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 before 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. This shall be made a condition of approval (a SEPA mitigation measure).
31. Transit –The project proposes to relocate the existing crosswalk and affiliated bus stops. Due to bus
stop and crosswalk relocation, the project will install new foundations, relocate existing benches and
signs, and provide new shelters. Details on the relocated bus stops and transit-related improvements
will need to be shown on the engineering submittal, which shall be made a condition of approval.
32. Stormwater – The project will be required to meet the requirements of the 2016 King County Surface
Water Design Manual (KCSWDM) and the City of Federal Way Addendum to that manual.
Conservation flow control and enhanced basic water quality requirements apply. This is considered a
high-use site requiring oil control per Special Requirement #5 in the KCSWDM. Best Management
Practices must be implemented to augment flow control. Flow control and water quality requirements
may apply to required public right-of-way improvements. Based on a review of the submitted
documents, the following shall be made conditions of approval:
a) The Right-of-Way Modification decision issued on June 22, 2018, includes improvements to
Weyerhaeuser Way South. As a part of building permit approval, water quality treatment and
flow control shall be provided for the public right-of-way as outlined in the regulations in place at
the time a building permit application is received.
Exhibit A – Findings for Project Approval Page 18 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
b) The applicant states that this project drains to an offsite wetland on parcel #2121049014;
however, no detail has been provided concerning the wetland. Therefore KCSWDM Chapters
3.3.5 through 3.3.7 may apply. If the amount of impervious surface area proposed by the project
is greater than or equal to 10 percent of the 100-year water surface area of a closed depression,
then a point of compliance analysis must be done to verify that the water surface levels are not
increasing for the return frequencies at which flooding occurs, up to and including the 100-year
frequency. The applicant has not provided a comparison of the proposed impervious surface area
to the surface area of the wetland or closed depression, nor have they provided a minor floodplain
analysis to establish an assumed base flood elevation. Conservation Flow Control (Level 2) must
therefore be considered a minimum standard, and the applicant will be required to provide
additional flow control if the site’s impervious area meets or exceeds the 10 percent threshold, or
a flooding problem will be created or exacerbated. The applicant shall provide necessary
documentation and mitigation before building permit issuance.
c) As stated in the KCSWDM section 1.2.2.1, the applicant shall submit a critical areas report for
the offsite wetland on parcel #2121049014. The critical areas report shall be completed as
outlined in FWRC 19.145.080, reviewed by an outside peer reviewer at the developer’s expense,
and approved before approval of the final TIR and before building permit issuance.
d) Before building permit approval, WSDOT approval of the project’s impacts on storm drainage
conveyance within WSDOT right-of-way shall be provided.
e) Before building permit issuance, a downstream analysis for the four acres that drain to the
southwest must be provided.
f) Low Impact Development measures, as required by the KCSWDM, must be implemented to
provide flow control mitigation for both frontage improvements and onsite improvements.
g) The critical areas report referenced in the Preliminary TIR needs the date corrected. The reference
will need to be updated in the final TIR.
h) Also, per the Hearing Examiner’s October 29, 2019, Request for Reconsideration Decision for
Greenline Warehouse “A,” the following shall be made a condition of approval:
i. The applicant shall supplement its stormwater plan to demonstrate compliance and
consistency with the Executive Proposed Basin Plan Hylebos Creek and Lower
Puget Sound (King County Surface Water Management, 1991).
This condition has since been satisfied. The applicant’s consultant, ESM Consulting Engineers,
LLC, provided a preliminary technical memorandum on February 7, 2020. In response to city
staff review comments, ESM submitted a revised version of the technical memorandum on April
22, 2020. The revised ESM memorandum supplemented the applicant’s original stormwater plan
to demonstrate compliance and consistency with the 1991 Hylebos Basin Plan. Each of the
potentially applicable basinwide and East Hylebos-specific recommendations identified in the
1991 Hylebos Basin Plan were specifically addressed in the memorandum. ESM’s technical
memorandum was evaluated by the city. On July 22, 2020, the city’s Development Services
Manager determined that the analysis contained in the ESM memorandum met the requirements
of the Hearing Examiner’s condition and directed that the memorandum be incorporated into the
Final TIR for the proposal. The Community Development Department documented this
conclusion in a Conditions Compliance Verification memorandum on September 11, 2020.
33. Water/Sewer – Lakehaven Water & Sewer District is the water and sewer service provider.
Lakehaven issued certificates of water and sewer availability in August 2017; certificates are valid for
Exhibit A – Findings for Project Approval Page 19 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
one-year from the date of issuance. Before issuance of a building permit, updated certificates of water
and sewer availability shall be submitted. This shall be made a condition of approval.
Per Lakehaven, the water and sewer system facilities indicated on the resubmittal plan set are generally
consistent with previous Lakehaven system design/layout comments. No other application has been
submitted to Lakehaven that is necessary to be able to determine the applicant’s specific requirements
for connection to Lakehaven’s water and/or sewer systems to serve the subject property. The applicant
will need to apply for either a Developer Pre-Design Meeting or Developer Extension Agreement for
Lakehaven to formally commence the water and/or sewer plan review process. Lakehaven encourages
owners/developers/applicants to apply for Lakehaven processes separately to Lakehaven, and
sufficiently early in the pre-design/planning phase to avoid delays in overall project development.
34. South King Fire & Rescue – South King Fire & Rescue (SKF&R) reviewed the application and has the
following comments, listed here as information and to be addressed at the building permit submittal.
• The required fire flow for this project is 3,000 or 4,000 gallons per minute depending on the type
of construction. A Certificate of Water Availability, including a hydraulic fire flow model, shall
be requested from the water district and provided at the time of building permit application.
• This project will require at least four fire hydrants in approved locations. Additional fire hydrants
may be needed to meet minimum spacing requirements of 525 or 600 feet between each hydrant
depending on the type of construction.
• Existing fire hydrants on adjacent properties shall not be considered unless fire apparatus access roads
extending between properties and easements are established to prevent obstructions of such roads.
• Hydrant spacing along access roads and location in relationship to buildings and sprinkler FDC shall
be approved by the Fire Marshal’s Office.
• Fire hydrants shall be in service before and during the time of construction.
• Fire apparatus access roads shall comply with all requirements of Fire Access Policy 10.006.
• The site plan did not provide detail to verify the following requirements:
o Angles of approach, departure, and minimum ground clearance.
• Designated and marked fire lanes may be required for emergency access. This may be done during
the plans check or before the building final. Requirements and marking options can be found in Title
8 of the FWRC.
• Fire apparatus access roads shall be installed and made serviceable before and during the time of
construction.
• All vehicle access gates, if any, shall comply with the SKF&R Gate Policy.
• A recessed fire department “Knox” brand key box shall be installed on the building near the front
entrance. Location(s) will be approved by the plan reviewer or Deputy Fire Marshal onsite.
• An NFPA 13 fire sprinkler system is required.
• An automatic fire sprinkler system shall be installed in all occupancies where the total floor area
included within the surrounding exterior walls on all floor levels, including basements, exceeds 5,000
square feet. Firewalls shall not be considered to separate a building to enable deletion of the required
automatic fire-extinguishing system.
Exhibit A – Findings for Project Approval Page 20 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
• The system demand pressure (to the source) required in a hydraulically designed automatic fire
sprinkler system shall be at least 10 percent less than the correlative water supply curve pressure.
• A fire alarm system is required.
• City code requires an automatic fire detection system in all buildings exceeding 3,000 square feet
gross floor area. The fire alarm system is required to monitor the sprinkler system, including water
flow. Provide full notification as required by NFPA 72. Complete coverage smoke detection is not
required for this project. This fire detection system shall be monitored by an approved central and/or
remote station.
• All buildings shall have approved radio coverage for emergency responders within the building
based upon the existing coverage levels of the public safety communication system at the exterior of
the building.
• The building shall be designed for High Piled Combustible Storage per chapter 32 of the 2015 IFC.
This code offers options for fire protection based on the intended use of the building. Some options
will limit the commodity and height of storage in the warehouse.
35. 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 (Cause No. HEX 18-003; 19-001). 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. Subsequently, the two conditions have been incorporated into the Woodbridge
Building “B” decision and have been satisfied as noted above.
The two projects will utilize common driveway access off of Weyerhaeuser Way 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.”
With respect to the potential cumulative impact on public views, the city required the applicant to
provide a visual impact analysis of Woodbridge Building “B” to identify any cumulative impacts on
public views from development of the two buildings (A and B). The August 10, 2018, analysis
prepared by ESM Consulting Engineers concludes that the building will only be minimally visible
through a screen of trees from the viewpoints studied. A second October 9, 2018, analysis prepared
by ESM Consulting Engineers was done to study additional viewpoints and concluded that the
proposed buildings would not be visible from the additional points studied.
At this time, the Woodbridge Corporate Park (WCP) land use application is still under review. A
visual impact analysis was submitted for the WCP. The city has provided technical comments,
including requiring modifications and supplemental view impact analysis, and is continuing to work
with the applicant on the matter.
The city took the cumulative visual impacts analyses for Woodbridge Buildings “A” and “B,” as well
as the visual impact analysis for the WCP, into account in reviewing Building “B.” Based upon the
Exhibit A – Findings for Project Approval Page 21 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
visual studies submitted and all other pertinent information, the city has determined that, as approved
and conditioned herein, Building “B” will not create any significant adverse environmental impacts to
public views.
There are no other common elements between the Woodbridge Building “B” project and the
Building “A” and/or WCP proposals. The city has not received indication from the applicant that the
two projects will be constructed simultaneously; therefore, there are no cumulative impacts
anticipated from the construction process itself.
The city was guided by the Hearing Examiner’s original decision and his reconsideration decision in
Cause No. HEX 18-003; 19-001 in performing the analysis of its cumulative impact for this decision
and the corollary SEPA review. The city thoroughly evaluated the projects for any cumulative impacts
in making this determination. As part of the project review, the city evaluated Building “B” with
regard to FWRC 19.100.030(2) and SEPA’s cumulative impacts requirement. The projects share a
parcel in common, 6142600200. As the Hearing Examiner acknowledged, cumulative impact review is
effectively incorporated into and implemented through various overlapping city development
regulations. The analysis of cumulative impacts for Woodbridge Building “B” is reflected throughout
this decision and the corollary SEPA review.
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.
i. 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 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
to proceed themselves. Woodbridge Buildings “A” and “B” are not interdependent parts of the WCP
Exhibit A – Findings for Project Approval Page 22 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
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.
Although the city has not, except where indicated, evaluated the Woodbridge Building “A,” Building
“B,” and WCP proposals in a single environmental document under WAC 197-11-060(3)(b), the
potential for cumulative impacts was a predominant focus of the city’s project review under both the
FWRC and SEPA. The city performed a thorough, comprehensive cumulative impacts analysis
consistent with the previous decisions of both the Hearing Examiner and the Superior Court. Except
as indicated in this decision and/or the October 9, 2020, MDNS, no such cumulative impacts were
identified. Based upon this analysis, the city is confident that no gaps in information or necessary
mitigation exist.
36. Director’s Decision Criteria – The Director of Community Development makes a written decision on
the application based on the criteria listed under FWRC 19.65.100(2)(a):
a. The proposal is consistent with the comprehensive plan;
i. The Federal Way Comprehensive Plan (FWCP) designation for the subject property is
Corporate Park. The FWCP (revised 2015) contains the following goals and policies:
o LUG8: Create office and corporate park development that is known regionally, nationally,
and internationally for its design and function.
According to the applicant, “Craft Architects has considered the natural surroundings
and existing built structures on the Federal Way Campus, LLC property. In their
design, Craft Architects has, included timber accents and artistic reveal patterns to
emphasize the history and character of the area. Entry nodes, visible to the public
streets, are comprised of large expanses of glass, glue laminated timber framing,
façade modulation, large canopies and arcades.”
For clarification, regarding the building’s entry node, the loop road is a private road,
not a public street.
o LUG9: Work collaboratively to evaluate and realize the potential of the (former)
Weyerhaeuser properties in East Campus.
The former Weyerhaeuser properties in East Campus are privately owned. According
to the applicant, “East Campus has been developed. This process III application to
develop Building ‘B’ is a collaboration of City approved code and the property
owner’s plans to revitalize this area of Federal Way through development as
permitted by the Concomitant Agreement.”
o LUP 49: In the East Campus Corporate Park area, encourage quality development that
will complement existing uses and take advantage of good access to I-5, Highway 18, and
future light rail as well as proximity to the City Center.
According to the applicant, “Building ‘B’ shares the same quality of development as
the building located in the East Campus. Furthermore, the proposed access to Building
‘B’ takes advantage of its proximity to Highway 18. Pedestrian vehicles may travel
east or west on Weyerhaeuser Way S. and may access future light rail stations.”
o NEP10: The City may continue to require environmental studies by qualified professionals
to assess the impact and recommend appropriate mitigation of proposed development on
Exhibit A – Findings for Project Approval Page 23 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
environmentally critical areas and areas that may be contaminated or development that
may potentially cause contamination.
See the “Critical Areas,” “Air Quality,” and “Noise” sections of this report.
o NEP86: Support state and federal air quality standards and the regulation of activities that
emit air pollutants.
See the “Air Quality” section of this report.
o 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.
See the “Air Quality” section of this report.
o 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.
See the “Noise” section of this report.
b. The proposal is consistent with all applicable provisions of the FWRC;
i. As conditioned, the proposal is consistent with applicable zoning regulations in effect on
August 23, 1994 (FWCC), and procedural requirements of the current code (FWRC), as
detailed in this report.
c. The proposal is consistent with the public health, safety, and welfare;
i. The Community Development and Public Works Departments, along with Lakehaven Water
& Sewer District and South King Fire & Rescue, have reviewed the project for conformance
with codes designed to protect public health, safety, and welfare. Additional details will be
reviewed at the building/engineering permit stage.
d. The streets and utilities in the area of the subject property are adequate to serve the
anticipated demand from the proposal;
i. See the “Transportation,” “Water & Sewer,” “Stormwater,” and “Conditions of Approval”
related sections of this report.
e. The proposed access to the subject property is at the optimal location and configuration; and
i. Access to the site will be provided via Weyerhaeuser Way and a loop road (private road). See
the “Transportation” and “Conditions of Approval” sections of this report.
f. Traffic safety impacts for all modes of transportation, both on and off site, are adequately
mitigated.
i. See the “Transportation” and “Conditions of Approval” sections of this report.
37. Conditions of Approval – The following conditions of approval are attached to the Process III decision:
1. Future submittals related to this project shall contain the property’s most current legal description.
Exhibit A – Findings for Project Approval Page 24 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
2. The proposal was reviewed as a general commodity warehouse with an associated office. A
future change in the type of use and/or occupancy shall require review for compliance with
applicable requirements and to determine any impacts, including revisiting the SEPA threshold
determination and Use Process III decision, as needed.
3. The building permit application plan set shall include a section with a parking analysis that
demonstrates compliance with required parking ratios.
4. Work is not allowed within Wetlands DP, DT, Stream EA, and associated buffers, as stream
setback intrusions and improvements/land surface modifications in non-CZA exempt wetland
setbacks require Use Process IV application review and approval per FWCC Sections 22-1312(c)
and 22-1359(d).
5. Before building final inspection, all additional, supplemental, and replanted Type I and II
landscaping, as indicated on the Use Process III preliminary landscaping plan (Sheets LA-01 and
LA-02), shall be installed.
6. In the landscaping plan submitted with the building permit, the following species listed on Sheet
LA-02 in the MFB recommended plant palette: Wild Ginger, Wood Fern, and White Flower
Rhodie, shall be removed.
7. All significant trees shall be retained within the MFB and within areas planned to remain
undisturbed as indicated on the Use Process III tree/vegetation retention plan and clearing and
grading plan (Sheets TR-01 & GR-01) to the maximum extent feasible.
8. The applicant shall obtain Forest Practices approval before the issuance of a building permit.
9. The following amendments shall be made to the critical area report before issuance of a
building permit:
a) Include an analysis of wetland functions as required by Section 22-1356(b) of the 1994 FWCC.
b) If Talasaea is considering the built-condition of Building “A” to be the existing conditions for
the Building “B” proposal, Sheet W1.0 of the revised report shall be revised to show the
reduced buffers for Stream EA and Wetlands DT, DR, and DQ to be consistent with the
proposed buffers on Sheet W1.2 of the report for Woodbridge Building “A.” Currently, Sheet
W1.0 shows the buffers as if Building “A” was not built.
c) The applicant shall show/label on Sheet W1.1 the size of each area of buffer reduction and
replacement to demonstrate that each reduction is compensated for at the location of the
critical area where that reduction occurs. Adjustments shall be made if necessary.
d) The “buffer replacement for Parcel A” shown on Sheet W1.1 is not approved and shall be
removed from Sheet W1.1.
e) When ESA’s comments on inconsistencies between report text, figures, and the plan sheets
are resolved in the submittal for Building “A,” the submittal documents for Building “B”
shall be revised where necessary.
10. Plan sheets that show the proposed development shall show the buffers post-development,
including the averaged wetland and stream buffers.
Exhibit A – Findings for Project Approval Page 25 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
11. Areas of wetland and stream buffer replacement shall be enhanced with native vegetation, as
necessary, to ensure buffer function continues post-development. Planting details shall be shown
on the landscape plan submitted with the building permit.
12. Installation of permanent signs and split rail fencing is required at the outer edge of the wetland
buffers for Wetland DT and shall be completed before final inspection for the building permit.
13. The boundary between the wetland buffer and contiguous land shall be identified with permanent
signs, which shall be a city-approved type designed for high durability. Signs must be posted at
an interval of one per every 150 feet and maintained by the property owner in perpetuity.
14. The city shall not issue any approvals to fill wetlands until all state, federal, or other agency permits
as may be required to fill the wetlands have been obtained and verification provided to the city.
15. The building permit submittal shall address the following:
a) Rooftop mechanical equipment, including vents, mechanical penthouses, elevator equipment,
and similar appurtenances that extend above the roofline must be surrounded by a solid sight-
obscuring screen that meets the following criteria: (a) the screen must be integrated into the
architecture of the building; and (b) the screen must obscure the view of the appurtenances
from adjacent streets and properties.
b) Type I landscaping is required around ground-level mechanical and electrical equipment and
utility installations unless precluded for safety and access reasons.
16. The building permit landscaping plan shall provide Type I landscaping a minimum of five feet in
width on the north and south sides of the combined trash/recycling enclosure area.
17. Before building permit issuance, plans shall demonstrate: 1) how occupant use of the designated
garbage/recycling areas will integrate with service access; and 2) how the storage and collection
of other garbage generated on-site complies with FWCC Section 22-949(e)(1), which states the
recycling storage area and garbage storage area shall be adjacent to each other.
18. Before building permit issuance, plans shall demonstrate that the garbage and recycling storage
needs have been incorporated into the design and planned for in ways that will serve occupants
over time.
19. Before issuance of a building permit, a lighting plan shall be submitted for verification of
compliance with FWCC Section 22-954(c).
20. Before 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, a SEPA mitigation measure).
21. 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 a certificate of occupancy (SEPA
mitigation measures):
Exhibit A – Findings for Project Approval Page 26 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
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.
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 the placement of typical fixed pure-tone backup alarms with
ambient-sensing and/or broadband backup alarms.
22. 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 prepared by a qualified professional shall be submitted to the city six months after the
certificate of occupancy is issued (a SEPA mitigation measure).
23. 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 the SEPA threshold determination
revisited before the building permit issuance, or if no building permit is required, then before
business license issuance (a SEPA mitigation measure).
24. 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
(SEPA mitigation measures):
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 another suppressant to reduce emissions of PM10 and
deposition of particulate matter.
j) Pave or use gravel on staging areas and roads that will 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.
Exhibit A – Findings for Project Approval Page 27 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
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.
25. Before 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 to the site. The northbound left 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 (a SEPA mitigation measure).
26. Before 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 (a SEPA mitigation measure).
27. 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 994 daily trips consisting of 795 passenger vehicle trips and
199 truck trips. 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. 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.
Daily I-5 southbound congestion routinely occurs between SR-18 and the South 320th Street
interchange. To avoid traffic congestion and reduce travel time due to a shorter distance, truck
trips with origin and destination from the north could utilize the South 320th Street/I-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/I-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 damage 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, before 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 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 outlined in the implementation agreement discussed below, the
city will use the bond for design and construction costs to upgrade the existing pavement on
Exhibit A – Findings for Project Approval Page 28 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
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 this condition, a “truck” shall mean a vehicle rated more
than 30,000 pounds gross weight as discussed in Chapter 8.40 FWRC.
Before 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 (a SEPA mitigation measure).
28. Before engineering plans approval, WSDOT approval of the traffic study and channelization
plans shall be provided.
29. 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 the pavement design
for city review and approval before 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 (a SEPA mitigation measure).
30. Before issuance of a certificate of occupancy, the applicant shall construct right-turn storage for
the westbound SR-18 off-ramp to mitigate the impact to the westbound off-ramp to the satisfaction
and with approval of WSDOT (a SEPA mitigation measure).
31. Cumulative traffic impacts from Warehouse 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 Warehouse 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 (a SEPA mitigation measure).
32. Details on the relocated bus stops and transit-related improvements shall be shown on the
engineering submittal.
33. A Right-of-Way Modification was issued on June 22, 2018, outlining required frontage
improvements for both Warehouse A and Warehouse B, with timing and bonding requirements.
The building permit site plan shall reflect the requirements outlined in this letter. Construction
plans shall be included in the building permit submittal for review and approval.
Exhibit A – Findings for Project Approval Page 29 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
34. The Right-of-Way Modification issued on June 22, 2018, includes improvements to
Weyerhaeuser Way South. As a part of building permit approval, water quality treatment and
flow control shall be provided for the public right-of-way as outlined in the regulations in place at
the time a building permit application is received.
35. The applicant states that this project drains to an offsite wetland on parcel 2121049014; however,
no detail has been provided concerning the wetland. Therefore KCSWDM Chapters 3.3.5 through
3.3.7 may apply. If the amount of impervious surface area proposed by the project is greater than
or equal to 10 percent of the 100-year water surface area of a closed depression, then a point of
compliance analysis must be done to verify that the water surface levels are not increasing for the
return frequencies at which flooding occurs, up to and including the 100-year frequency. The
applicant has not provided a comparison of the proposed impervious surface area to the surface
area of the wetland or closed depression, nor have they provided a minor floodplain analysis to
establish an assumed base flood elevation. Conservation Flow Control (Level 2) must therefore
be considered a minimum standard, and the applicant will be required to provide additional flow
control if the site’s impervious area meets or exceeds the 10 percent threshold, or a flooding
problem will be created or exacerbated. The applicant shall provide necessary documentation and
mitigation before building permit issuance.
36. As stated in the KCSWDM Section 1.2.2.1, the applicant shall submit a critical areas report for
the offsite wetland on parcel 2121049014. The critical areas report shall be completed as outlined
in FWRC 19.145.080; reviewed by an outside peer reviewer at the developer’s expense; and
approved before approval of the final TIR and before building permit issuance.
37. Before building permit approval, WSDOT approval of the project’s impacts on storm drainage
conveyance within the WSDOT right-of-way shall be provided.
38. Before building permit issuance, a downstream analysis for the four acres that drain to the
southwest must be provided.
39. Low Impact Development measures, as required by the KCSWDM, must be implemented to
provide flow control mitigation for both frontage improvements and onsite improvements.
40. The critical areas report referenced in the Preliminary TIR needs the date corrected. The reference
will need to be updated in the final TIR.
41. The applicant shall supplement its stormwater plan to demonstrate compliance and consistency
with the Executive Proposed Basin Plan Hylebos Creek and Lower Puget Sound (King County
Surface Water Management, 1991).
42. Before issuance of a building permit, updated certificates of water and sewer availability shall
be submitted.
CONCLUSION
As conditioned, the proposed site plan application has been determined to be consistent with the FWCP;
with all applicable provisions of the FWCC and FWRC; and with public health, safety, and welfare. The
streets and utilities in the area of the subject property are adequate to serve the anticipated demand from
Exhibit A – Findings for Project Approval Page 30 of 30
Woodbridge Building “B” Project 17-104236-00-UP / Doc. I.D. 81257
the proposal, and the proposed access to the subject property is at the optimal location and configuration
for access. The proposed development is consistent with Process III, Project Approval, decisional criteria
required under Chapter 19.65 FWRC.
The proposed site plan and application attachments have been reviewed for compliance with the FWCP,
pertinent zoning regulations, and all other applicable city regulations. Final construction drawings will be
reviewed for compliance with specific regulations, conditions of approval, and other applicable city
requirements. This decision shall not waive compliance with future City of Federal Way codes, policies,
and standards relating to this development.
Prepared by: Stacey Welsh, Principal Planner Date: June 24, 2021