Attachment 3Stacey Welsh
From: 1301 mrp@gmail.com
Sent: Wednesday, October 21, 2020 2:09 PM
To: Ping Inquiry
Subject: "File No: 17-104237-SE" -- Weyerhauser
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• This campus as a whole has outstanding historic significance and therefore any changes must be compatible
to its existing design. This campus is significant not just for Washington and the Northwest —it is known
nationally and internationally as one of the finest examples of modern corporate campus design.
• The tree buffer proposed by the owner is insufficient because the entire forested parcel contributes to the
significance of the campus design. The City should require the owner to substantially reduce the size of the
proposed warehouse to preserve more of the forested land and the historic design of the campus.
• Ultimately, the historic significance of the campus warrants additional review through an Environmental
Impact Statement (EIS), which the City should require. An EIS would allow for more public comment and
require that the property owner consider alternatives that have less harmful environmental impacts.
Please reconsider....
Meredith Perlman
Stacey Welsh
From: Marj Hause <marjhause@gmail.com>
Sent: Tuesday, October 20, 2020 8:07 AM
To: Ping Inquiry
Subject: "File No: 17-104237-SE"
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Attn: Stacey Welsh
I urge you to allow more time for public comment on the development of this property. It is important we preserve the
beauty of this area as we grow and create industry. The current proposal seriously diminishes the area of forestry and
encroaches on the historic design of the campus.
Thanks, Marj Hause
Stacey Welsh
From: Richard Kennedy <richard@whovian.name>
Sent: Monday, October 19, 2020 9:31 PM
To: Ping Inquiry
Subject: Comments File No: 17-104237-SE
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Attn: Stacey Welsh
Re: Mitigated Determination of Non -Significance" (MDNS) for warehouse on the former Weyerhaeuser Campus
Comments Summary: The proposed warehouse on the former Weyerhaeuser Campus requires an Environmental
Impact Statement (EIS) due to its impact on the historic significance of the entire site.
The former Weyerhaeuser Campus as a whole has outstanding historic significance and therefore any changes must be
compatible to its existing design. This campus is known nationally and internationally as one of the finest examples of
modern corporate campus design. As such, its significance extends far beyond the State of Washington and the Pacific
Northwest.
The City of Federal Way should require the owner to substantially reduce the size of the proposed warehouse to
preserve more of the forested land and the historic design of the campus. The tree buffer proposed by the owner is
insufficient because the entire forested parcel contributes to the significance of the campus design.
Finally, the City of Federal Way should require an EIS as the historic significance of the campus warrants an additional,
thorough review. An EIS would allow for more public comment and require that the property owner consider
alternatives that have less harmful environmental and historical impacts.
-- Richard T. Kennedy, Past President
-- Des Moines Historical Society
-- PO Box 98055
-- Des Moines, WA 98198-0055
-- http://www.dmhs.org/
Stacey Welsh
From: Daniel Jost <djost.1983@gmail.com>
Sent: Friday, October 23, 2020 4:51 PM
To: Ping Inquiry; Stacey Welsh
Subject: Comments on Plans for Redeveloping Weyerhauser Campus
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To: The City of Federal Way
Re: File No. 17-104237-SE
I am writing to express my concern regarding the recent plans for the former Weyerhauser Campus. I am particularly
concerned about the Determination of Nonsignificance for the property where Woodbridge Building "B" is proposed
(File No. 17-104237-SE). I hope the city will rescind this decision. Allowing the construction of a 45-foot-tall warehouse
on this site would greatly diminish this local and national treasure.
When the American Society of Landscape Architects celebrated its 100th anniversary in 1999, Weyerhauser's Campus
was highlighted in a special issue of Landscape Architecture Magazine as one of the most significant works of landscape
architecture of the 20th century. Today, the design of the Weyerhauser Campus is taught in landscape architecture
history classes --including the one I taught as a graduate student at the University of Washington.
At Weyerhauser Campus, SWA Group and SOM created a functional work of land art. He transformed the suburban
parking lot --which is not typically an outlet for artistic expression --into a beautiful composition to experience as a driver,
pedestrian, or viewer from an adjacent property. Adjacent forested areas were sculpted and pierced with roads as part
of this composition --and tell a story about Weyerhauser's ecological goals. Seven years after completing this landscape,
Peter Walker was hired to lead Harvard University's landscape architecture program --where he was the leader of a
highly influential movement that sought to create functional and meaningful land art that served a social function. The
approach Walker brought to the Weyerhauser Campus transformed the field of landscape architecture and dominated it
for much of the next 35 years.
The current proposal leaves only a very narrow strip of trees between key paths/drives and the new warehouses. In
some places, they are proposing only one line of trees between the warehouse and key paths, drives, and lawns. And it
treats the area where Warehouse B is being proposed as an empty lot ready to be developed. This forested area where
Warehouse B is proposed is no more an empty space ready to be filled than the forested areas around the Grand Canal
at Versailles are empty. It is an essential part of this historic landscape. The narrow strips of trees proposed would not
adequately block views or buffer noise. They would destroy the entry experience intended for the site --which was about
moving through a forested area. And most importantly, Warehouse "B" as proposed would also completely throw off
the artistic balance of this masterpiece of landscape architecture. The possibility of building on part of the site was
considered under SWA Group's original plans but a much larger area of trees would have been preserved as part of the
landscape composition of the headquarters building under that plan.
The City of Federal Way should use any authority it has to prevent development on the forested areas directly adjacent
to the main headquarters structure and its artfully designed parking lots or limit that development to the area where
development was historically proposed. If development does occur, ideally, it should be development that is compatible
with reuse of the former HQ building and not warehouse from an unconnected company that may actually devalue that
site and lead to its demise in the future. The city should use any tools it can to ensure that a wider buffer is preserved
between new development and key parts of the campus --including existing lawn areas, pathways, and Weyerhauser
Road. This significant historic landscape should be treated as a part of Federal Way's and our nation's cultural heritage
and should not be diminished.
Daniel Jost, ASLA
Landscape designer, researcher, and educator
Former Writer/Editor Landscape Architecture Magazine (2008-2013)
Former Contributing Editor to Landscape Architecture Magazine (2013-2018)
Co -curator of Landscape Architecture Magazine '5 1 00th-anniversary issue.
Ph.D. Candidate at North Carolina State University
A photo showing how Walker used the forest to frame views and balance the composition. Much of the forested area to
the left would become a 4-story warehouse under the current proposal, destroying the balance of this masterpiece of
functional land art. (Image: Seattle Daily Journal of Commerce)
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The entire kidney -shaped area at Weyerhauser Campus contributes to Walker's land art composition. The shape is found
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A historic plan showing how any development might be respectfully distanced from the landscape surrounding the
former HQ building. Ideally, such development would be compatible with redevelopment of the campus itself and not a
warehouse.
L7
Stacey Welsh
From: Nancy Rottle <nrottle@uw.edu>
Sent: Friday, October 23, 2020 11:59 AM
To: Ping Inquiry
Subject: Comments on Weyerhaeuser Campus File #: 17-104237-SE
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Dear Ms. Welsh and City of Federal Way Planning,
I am writing to comment on the DNS issued for the Weyerhaeusr Campus. This site is a remarkable, exceptionally
significant example of an integrated landscape -building campus complex design. Such an example requires the
intactness and integrity of the landscape as an essential component to the historic significance of the ground -breaking
Weyerhaeuser building, which spans the meadow from forest edge to forest edge. Indeed, a deep protection of this
enbracing forest is required.
The iconic views of this integrated landscape and building duo from both 1-5 and Highway 18 are part of our South King
County heritage, appreciated for the past half -century. It is recognized not only locally, but also nationally and
internationally. Lead Project Designer Peter Walker, who is one of the profession's most heralded Landscape Architects,
has stated that he considers the Weyerhaeuser Campus one of his most successful and important projects over the span
of his long and illustrious career.
The campus should be considered for designation as a Historic Landmark, and a complete Environmental Impact
Statement should be carried out in order to fully assess and bring forward the importance of the site. Such a study
would accurately convey the impacts that inserting warehouses close to the forested edge of the meadow would cause,
and promote a more sensitive solution that would protect the integrity of this superb example of campus design.
Sincerely,
Nancy Rottle
Nancy D. Rottle, RLA, FASLA
Professor, Department of Landscape Architecture
Director, Green Futures Research and Design Lab
ScanlDesign Endowed Chair in Built Environments
Adjunct Professor, Departments of Architecture and Urban Design and Planning
College of Built Environments
Box 355734 University of Washington
Seattle, WA 98195-5734
voice 206.685.0521
http://qreenfutures.washington.edu/
http://livingshorelines.be.uw.edu/
The University of Washington acknowledges the Coast salish peoples of this land, the land which touches the shared waters of all tribes and bands within the suquamish, Tulalip,
Puyallup and Muckleshoot nations.
Stacey Welsh
From: Garrett Haynes <garrett@alpineridgeinsurance.com>
Sent: Tuesday, October 20, 2020 6:40 PM
To: Ping Inquiry
Subject: File No: 17-104237-SE
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Dear City of Federal Way,
In regards to the new warehouse that is being proposed for construction on the former Weyerhaeuser Campus, I am
requesting that the City of Federal Way take into consideration the historic significance of this property and its original
design, and that any designs for this new warehouse be compatible with the original and existing design for the
property. The removal of too many of the trees and habitat on this property would be detrimental to its design and
architecture, not to mention to the bird and animal life that abounds on it. This property is internationally known for its
building and landscape architecture and to allow it to be destroyed would be a shame. The tree buffer that is currently
proposed by the property owner is insufficient to maintain the original design for the property and should be altered so
that any new construction maintains the look and feel as it currently exists.
Also, the city of Federal Way should require an Environmental Impact Statement. This would allow for public comment
and require that the property owner consider alternatives that have less harmful environmental impacts.
Thank you,
Garrett Haynes, AIS, AINS I Principal
Alpine Ridge Insurance Agency
p: 253-833-9501
f: 800-919-1931
text: 253-461-1601
e: garrett@alpineridgeinsurance.com
www.aIpineridgeinsurance.com
See us on Yelp!
Stacey Welsh
From: Stephanie Sallaska <ssallaska@gmail.com>
Sent: Tuesday, October 20, 2020 12:14 PM
To: Ping Inquiry
Subject: File No: 17-104237-SE
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Dear Stacey Welsh at the City of Federal Way:
I moved here from Oklahoma three years ago to be near my daughter who lives close to the Weyerhauser campus. I
walk my dogs there. The trees are so towering and old, it's like we're traveling through a primeval forest. Of course,
there is the roar of 1-5 — no buffering that — but at least the trees are still there, and warehouses aren't.
There is a lot of talk about environmental impact. What about the impact on me and my daughter and my dogs? There
aren't many things special about Federal Way, but the Weyerhauser campus is ...
Stephanie Sallaska
Stacey Welsh
From: Norm Fiess <normfiess@comcast.net>
Sent: Tuesday, October 20, 2020 10:03 AM
To: Ping Inquiry
Subject: File No: 17-104237-SE
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Stacey Welch,
Please reconsider the look of the historic Weyerhaeuser Corporate Building with a row of warehouses adjacent to it with
only a small buffer of trees. As a nearby resident we have many concerns about this type of development in our
neighborhood centering around traffic and the environment however we cannot overlook the destruction of the setting
in which this beautiful building was designed and located.
Thank you,
Norm Fiess
3111 S 3491h Street
Federal Way, WA 98003
206 948-3737
Stacey Welsh
From: Nils Dickmann <nilespice@hotmail.com>
Sent: Tuesday, October 20, 2020 9:54 AM
To: Ping Inquiry
Subject: File No: 17-104237-SE
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Hi Stacey!
As a member of the Washington Trust, I've been receiving notifications regarding the proposed developments at the
former Weyerhaeuser headquarters in Federal Way. As someone who worked for Weyerhaeuser Corp on this
very campus for over 10 years it is sad to see that the City of Federal Way might allow new
development that would destroy the character of this very beautiful and unique environment. I urge
you to please listen to the requests of the Washington Trust and leave the campus as it was designed
for future generations to appreciate.
This campus as a whole has outstanding historic significance and therefore any changes must be compatible
to its existing design. This campus is significant not just for Washington and the Northwest —it is known
nationally and internationally as one of the finest examples of modern corporate campus design.
• The tree buffer proposed by the owner is insufficient because the entire forested parcel contributes to the
significance of the campus design. The City should require the owner to substantially reduce the size of the
proposed warehouse to preserve more of the forested land and the historic design of the campus.
• Ultimately, the historic significance of the campus warrants additional review through an Environmental
Impact Statement (EIS), which the City should require. An EIS would allow for more public comment and
require that the property owner consider alternatives that have less harmful environmental impacts.
To quote the founder of the Weyerhaeuser Company himself, Frederick Weyerhaeuser (1834-1914):
"This is not for us, nor for our children, but for our grandchildren."
Please protect the Weyerhaeuser Campus!
Thank you for your time and consideration,
Nils Dickmann
Stacey Welsh
From: Lynn Ferguson <lynnferguson65@comcast.net>
Sent: Tuesday, October 20, 2020 10:31 AM
To: Ping Inquiry
Subject: file No:17-101-237-SE Warehauser Campus
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Please require a full EIS before you make this decision. This example of iconic corporate design is a
regional treasure, viewed from the highway by millions. The tree buffer is not enough to protect the
integrity of the campus. Please think of future generations and our ethic of environmental
preservation and good design and preserve this campus for the future by requiring a full EIS to
assess the impacts. Lynn Ferguson lynnferguson65@comcast.net
Stacey Welsh
From: Hollis Palmer <hollispalmer@q.com>
Sent: Tuesday, October 20, 2020 12:20 PM
To: Ping Inquiry
Subject: File No: 17-104237-SE MDNS, Weyerhaeuser Headquarters
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Dear Stacey Welsh,
The City of Federal Way recently released a "Mitigated Determination of Non -Significance" (MDNS)—a decision that
would allow a small strip of trees to be kept between the proposed warehouse and the iconic former Weyerhaeuser
headquarters building which is so deeply connected to its surrounding forested landscape. I believe that this new
construction is cosmetic only and ignores the holistic and groundbreaking architectural and landscape design of the
campus.
• This campus as a whole has outstanding historic significance and therefore any changes must be compatible to its
existing design. This campus is significant not just for Washington and the Northwest —it is known nationally and
internationally as one of the finest examples of modern corporate campus design.
• The tree buffer proposed by the owner is insufficient because the entire forested parcel contributes to the
significance of the campus design. The City should require the owner to substantially reduce the size of the proposed
warehouse to preserve more of the forested land and the historic design of the campus.
• Ultimately, the historic significance of the campus warrants additional review through an Environmental Impact
Statement (EIS), which the City should require. An EIS would allow for more public comment and require that the
property owner consider alternatives that have less harmful environmental impacts.
Sincerely,
Hollis Palmer
Stacey Welsh
From: Kenna Patrick <kennajp@icloud.com>
Sent: Wednesday, October 21, 2020 9:52 AM
To: Ping Inquiry
Subject: File No: 17-104237-5E - Weyerhaeuser Campus development comments
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To Stacey Welsh and the City of Federal Way Planning Department in regard to File No: 17-104237-SE
As a professional landscape architect working in the field of environmental engineering, as well as a resident of Federal
Way, having grown up less than a mile from campus, I am so disappointed in the news that warehouse B is moving
forward through permitting. It is abundantly clear to me that this project will in fact have significant and severe adverse
impacts on the environment. Furthermore, IRG's plan will break apart, what has been for decades, one of the most
historically significant, and pristine landscapes in the south sound.
My first comment is that the determination that development of warehouse B, along with future development of the
campus, will have non -significant environmental impact is incorrect. Mitigating filled wetlands does not equate to non -
significance. Cutting down acres of habitat does not equate to non -significance. Disturbing the headwaters of Hylebos
Creek watershed does not equate to non -significance. You will be destroying an immense amount of the only remaining
habitat in a rapidly developing area, that will be in desperate need of green spaces as more people continue to move to
the south sound; and you will never be able to get this space back for animals or people. Preservation is the only answer.
I know the reality of permitting and mitigation and money, and the pressure that IRG is putting on the City, but you have
the power to stand up for what is right.
My second comment is that this landscape, designed by Peter Walker, is truly historic. We studied this landscape at the
college of built environments at the University of Washington when I was receiving my masters in landscape
architecture, but I already knew from spending my childhood here that this place was something so precious. Having this
space with all of its winding trails, sweeping views and towering trees, was part of my inspiration to become a landscape
architect. It is proven that access to expansive green spaces such as this is restorative and critical for the physical and
mental wellbeing of people living in urban and suburban environments, and no matter how many jobs these warehouses
will bring, nothing will be better for the people of Federal Way than preserving this space.
At a bare minimum, I recommend that the city require a major reduction in the size of both warehouses and parking
lots, and a major expansion of the tree buffer. It is my professional opinion that the city should not allow for the filling of
wetlands at all due to the active restoration and preservation plan in place for Hylebos Creek watershed. Ideally, this
campus as a whole would be recognized for its historic significance and preserved for future generations.
Please consider a forward thinking and environmentally aware approach in your planning, and recognize the opportunity
you have here to make Federal Way stand out.
Sincerely,
Kenna Patrick, PLA
Stacey Welsh
From: Heide Fernandez-Llamazares <heide_fll@hotmail.com>
Sent: Thursday, October 22, 2020 6:09 PM
To: Ping Inquiry
Subject: File No: 17-104237-5E --Please save and preserve the Weyerhaeuser Campus from
warehouses
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Dear Stacey Welsh and the Federal Way planning commission,
Please save and preserve the Weyerhaeuser Campus and its main building from being surrounded by warehouses. It is
such a special place -- I immediately noticed it from the 1-5 when I moved here in 2003 from Victoria, BC! I looked it up
to find out more about the building. It really is one of those rare and unique buildings whose beauty and uniqueness is
timeless and universally recognized -- on par with a Frank Lloyd Wright house or a Phillip Johnson glass house,
completely integrated and in harmony with its forest surroundings. The building and its wooded location is special and
unique, not only to Federal Way but to all of Washington. If we allow it to be surrounded by warehouses with no respect
for architecture, nature, or anything else except making money for one person, it will be a sad and irreversible fate.
There are hundreds of sites for warehouses but there are few sites that are deserving of being preserved as parkland.
The Weyerhaeuser Campus is a unique opportunity to attract a special corporate partner for Federal Way.
Save the forest. Federal Way is lucky to have Dash Point State Park and it is beloved and well -used! The Weyerhaeuser
Campus is an opportunity to add to this legacy of beautiful and significant parks, instead of building more dull corporate
parks.
The historic significance of the campus warrants additional review through an Environmental Impact Statement (EIS),
which the City should require.
If there is any way that I can help more with this process, please let me know.
File No: 17-104237-SE
Thank you,
Heide Fernandez-Llamazares
heide_fll@hotmail.com
3710 N 7th St, Tacoma, WA 98406
Stacey Welsh
From: stephanie gianarelli <sgianarelli@yahoo.com>
Sent: Wednesday, October 21, 2020 9:30 PM
To: Ping Inquiry
Subject: File No: 17-104237-SE
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Dear Stacey Welsh,
Please help protect our beautiful and historic and not able to be replaced Weyerhaeuser property! We can't let some
developer from California destroy on of our most beautiful places in Federal Way.
Please .... do something. I'm begging you.
Stephanie Gianarelli 98003-7120
Federal Way resident
Stacey Welsh
From: marianne lochner <arbor156@gmail.com>
Sent: Thursday, October 22, 2020 6:33 PM
To: Ping Inquiry
Subject: File No-17-104237-SE
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Dear Stacey Welsh,
This letter is in regard to the proposed warehouse on the former Weyerhaeuser Campus property. The campus as a
whole has outstanding historical and environmental significance and therefore any changes must be compatible with it's
existing design. The buffer proposed by the owner is insufficient because the entire forested parcel contributes to the
importance of the campus design. The city of Federal Way should require the owner to substantially reduce the size of
the proposed warehouse in order to preserve more of the forested land. An additional review through the EIS is
demanded in order to ensure the land is in compliance with environmental and historical design originally intended for
this property.
Sincerely,
Marianne Moore
Stacey Welsh
From: Carol <carol@aramburu-eustis.com>
Sent: Friday, October 23, 2020 4:53 PM
To: Ping Inquiry
Cc: Rick
Subject: FW: 17-104237-SE MDNS - Comment
Attachments: 20201023 Comment for SWC re WHSE B MDNS.pdf, 20201023 Att.A - 5-29-18 SWC
GBP&WhseA&B Comment.pdf
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The attached comment was submitted to planner Stacey Welsh as per the email below.
Carol Cohoe, Legal Assistant
Law Offices of J. Richard Aramburu, PLLC
206-625-9515
Please "REPLY ALL" to ensure that Mr. Aramburu also receives your response.
Effective February 1, 2020 we have moved to the Hoge Building:
705 Second Ave, Suite 1300, Seattle WA 98104.
From: Carol [mailto:carol@aramburu-eustis.com]
Sent: Friday, October 23, 2020 4:48 PM
To: 'Stacey.Welsh@cityoffederalway.com'
Cc: Rick (rick@aramburu-eustis.com)
Subject: 17-104237-SE MDNS - Comment
Good afternoon, Ms. Welsh, please accept this comment and attachment regarding the MDNS issued for the Warehouse
B application, File No. 17-104237-SE.
Carol Cohoe, Legal Assistant
Law Offices of J. Richard Aramburu, PLLC
Please "REPLY ALL" to ensure that Mr. Aramburu also receives your response.
Effective February 1, 2020 we have moved to the Hoge Building:
705 Second Avenue, Suite 1300
Seattle, WA 98104-1797
Telephone (206) 625-9515
Facsimile (206) 682-1376
This message may be protected by the attorney -client and/or work product
privilege. If you received this message in error please notify us and
destroy the message. Thank you.
LAW OFFICES OF Jo RIC111 ARD ARAMB,lJR,IJ PLLC
705 Second Avenue, Swine 1300
Seattle, WA 98104-1797
Telephone 206.625.9515
Facsimile 206.682.1376
October 23, 2020
Stacey Welsh
Federal Way City Hall
33325 8t" Avenue South
Federal Way, Washington 98003
www.aramburulaw.com
www.aramburu,eustis.com
Via Email:
Stacey.Welsh@
cityoffederalway.com
Re: MDNS for Woodbridge Warehouse "B" Development (File No. 17-104237-SE)
Dear Ms. Welsh:
This office represents Save Weyerhaeuser Campus (SWC), a Washington nonprofit
corporation organized and existing to protect and preserve the community and natural
values of the former Weyerhaeuser Campus and adjacent areas. SWC has been active
over the past several years in providing comment on proposals by Industrial Realty
Group (IRG) to develop three projects on the former Weyerhaeuser Campus.
On October 9, 2020, the Federal Way SEPA Responsible Official issued a Mitigated
Determination of Nonsignificance (MDNS) for the proposed Woodbridge Warehouse
"B," a 214,050 square foot general commodity warehouse with 245 parking spaces on a
16.85 acre site (hereinafter Warehouse B). The proponent is Federal Way Campus
LLC. The comment period for this proposal ends on October 23, 2020.
This letter constitutes SWC's comments on the Warehouse B proposal. In summary,
the MDNS was issued in error for two reasons. First, the City did not adequately
consider the impacts of the entirety of the IRG proposals on the former Weyerhaeuser
Campus, including Greenline Warehouse "A" (File No. 16-102948-SE) and the
Woodbridge (formerly Greenline) Business Park (File No. 17-105491) as well as
Warehouse B. These overall proposals clearly would have significant adverse impacts.
Secondly, the impacts of Warehouse B alone create a reasonable likelihood of more
than a moderate adverse impact on environmental quality. In either case, the currently
issued MDNS should be withdrawn and scoping should begin for preparation of a full
environmental impact statement.
This comment letter incorporates the comments provided by SWC on the Greenline
Business Park proposal by letter dated May 29, 2018, attached hereto (see Attachment
A) and incorporated by this reference. In that letter, SWC indicated that the Greenline
Business Park and Warehouses A and B should be consolidated for land use and
October 23, 2020
Page 2
environmental review.' The cumulative impacts of these three projects should be
considered.
STANDARDS FOR ISSUANCE OF A THRESHOLD DETERMINATION.
Under the SEPA rules the City must determine whether a proposal "is likely to have a
probable significant adverse environmental impact." WAC 197-11- 330(1)(b). A single
significant impact is enough to warrant an EIS, but also "(c) Several marginal impacts
when considered together may result in a significant adverse impact" Id. at
330(3)(c). Here there are several impacts that must be considered, including impacts on
historic resources, as outlined by letters from King County, the State of Washington
Department of Archaeology & Historic Preservation (DAHP), the Cultural Landscape
Foundation and other agencies and individuals that submitted comments to the City
regarding the Weyerhaeuser Campus. SWC has read these letters, agrees with them
and incorporates them by reference herein.
PROJECT PROPOSAL.
The application, according to the MDNS, is for a "general commodity warehouse." This
use sets a number of environmental parameters, trip generation parameters, standards
regarding release of air pollution, the need for limitation of impervious surfaces, etc. to
address expected environmental impacts. For reasons stated herein, SWC believes
that the MDNS has been issued in error.
IRG has represented, however, in its filings before the U.S. Army Corps of Engineers
(USACE) other possible uses for Warehouse B (and Warehouse A). Accordingly, the
City's decision should explicitly provide that the MDNS is issued solely for the "general
commodity warehouse" and will become null and void if there is any change in use for
the proposal. If the use of the site, or use of the building, changes from the explicit
application before the City, the permit and development process, including SEPA,
should start over with the new project information.
CUMULATIVE IMPACTS.
As noted in our May 29, 2018 letter and reinforced by Hearing Examiner and court
decisions, the environmental impacts of Warehouse A and B and Greenline Business
Park projects must be reviewed cumulatively. Comments herein supplement our 2018
letter.
The Greenline Business Park has also been under consideration for several years, in
'IRG has rebranded its projects on the former Weyerhaeuser site as the "Woodbridge" proposals.
Because SWC's prior communications and City decisions reference the "Greenline" proposal we continue
that reference.
October 23, 2020
Page 3
parallel with Warehouses A and B. Like Warehouse A, the City has had multiple and
detailed documents before it as part of the Greenline Business Park application.
In the Warehouse A MDNS the City contended that Warehouse B and the Greenline
Business Park are complex projects that may take additional time for review, thus
environmental review under SEPA could not take place at the time of the Warehouse A
application. The City's position reflects a fundamental misunderstanding of the law.
Under WAC 197-11-055, two obligations are created for local government. First, under
Subsection 1:
The SEPA process shall be integrated with agency activities at the earliest
possible time to ensure that planning and decisions reflect environmental values,
to avoid delays later in the process, and to seek to resolve potential problems.
(Emphasis supplied.) This obligates the local government to assure that SEPA
becomes a part of local decision making. Second, under Subsection 2:
(2) Timing of review of proposals. The lead agency shall prepare its threshold
determination and environmental impact statement (EIS), if required, at the
earliest possible point in the planning and decision -making process, when the
principal features of a proposal and its environmental impacts can be reasonably
identified.
(a) A proposal exists when an agency is presented with an application or
has a goal and is actively preparing to make a decision on one or more
alternative means of accomplishing that goal and the environmental
effects can be meaningfully evaluated.
(Emphasis supplied.) Under WAC 197-11-310(2):
(2) The responsible official of the lead agency shall make the threshold
determination, which shall be made as close as possible to the time an agency
has developed or is presented with a proposal (WAC 197-11-784). If the lead
agency is a GMA county/city, that agency must meet the timing requirements in
subsection (6) of this section.
(Emphasis supplied.) WAC 197-11-784 provides that: "A proposal exists at that stage in
the development of an action when an agency is presented with an application ... "
Note that with the use of the word "shall" in WAC 197-11-310(2) the requirement is
mandatory, but the City has not issued a threshold determination for the Greenline
Business Park, despite having detailed project plans and environmental reports for
more than three years. The City's failure to act violates its obligation to issue a
threshold determination "as close in time as possible to the time an agency ... is
presented with a proposal."
October 23, 2020
Page 4
The time for the City to issue a threshold determination for the Greenline Business Park
project has long since passed. The applicant long ago submitted environmental
documents and abundant detail is available for review. SEPA requires review of the
cumulative impacts of the Greenline Business Park and Warehouse A along with those
of Warehouse B. These impacts are significant, and an environmental impact statement
is required. The MDNS should be withdrawn.
TRAFFIC IMPACTS.
The City's decision relies on a traffic study prepared by TENW on March 6, 2018, IRG
Greenline Buildings A and B Federal Way, WA Transportation Impact Study, TENW
Transportation Engineering NorthWest (March 6, 2018). The court has clearly directed
the City, however, to consider the traffic impacts of the Greenline Business Park and
Warehouse A, along with other traffic impacts, in evaluating the traffic impacts of
Warehouse B. Rather than conduct the necessary analysis, however, the City imposes
a vague condition, in Mitigation Measure #11, that "cumulative traffic impacts" from
Warehouse A, Warehouse B and the Greenline Business Park on the S.R. 18
westbound ramp intersection with Weyerhaeuser Way "shall be evaluated and
mitigated" in SEPA documents. SWC believes this and other traffic -related conditions
are incomplete and inadequate, for several reasons.
1. The City has in hand, for Warehouse A, an updated traffic study showing a
continued loss of service (LOS) failure and a conflicting conclusion of no LOS failure.
Both are relevant to and need to be evaluated for Warehouse B, and the differences
reconciled in the public record, allowing for meaningful public review and comment.
The LOS failure is documented in the updated Traffic Impact Analysis for Warehouse
A, dated March 24, 2020. It concluded that the cumulative impacts of Warehouses A
and B and the Greenline Business Park will continue to cause a LOS failure (level E, in
violation of WSDOT standards) at the intersection of Weyerhaeuser Way S and SR-18.
On April 6, 2020, TENW followed up with an analysis of how the costs of mitigating the
increased traffic levels should be allocated among IRG's projects. These costs would
be minimal, though, because TENW had recommended shifting IRG's mitigation
responsibility to the driving public: it suggested that WSDOT merely re -time the traffic
signal to bring impacts below the LOS threshold.
WSDOT, on reviewing the TIA, declined to commit to changing the SR-18 light timing
and took issue with TENW's characterization of any such action as mitigation. Swires,
Mike & Maan, Sidhu, Memorandum to Ramin Pazooki & Duffy McColloch re
Woodbridge Business Park —Updated Traffic Impact Analysis, p. 2, Washington State
Department of Transportation (June 18, 2020). WSDOT said it was not requesting any
additional mitigation at this time. This leaves the LOS failure —a significant
environmental impact —unmitigated. The City should as a result be requiring an EIS for
Warehouse A.
October 23, 2020
Page 5
For reasons that are not clear in the record, however, on July 22, 2020, TENW
submitted a short "SEPA analysis addendum" to the City referring to a new, July 17,
2020 updated TIA for the three projects. In contrast to the March 24 TIA (and the
previous TIA presented to the Hearing Examiner), the "addendum" said the new TIA
concluded there would be no LOS failure at the SR-18 intersection. Remarkably, it said
the delays at the intersection after all three projects are built (47.5 seconds) will be
lower than the delays without any of the projects (53.1 seconds, as reported in previous
studies).
The new TIA obviously raises questions about its methodology and assumptions. To
our knowledge, however, it is not included in the record for Warehouse A or Warehouse
B. We do not know whether it was presented to WSDOT for review, nor whether its
assumptions are realistic, and whether it otherwise protects the State's interests.
Consideration of these impacts is required not only by SEPA, but by FWCC
19.90.120(2), which requires:
...consideration of the cumulative impacts of all development permit applications
for contiguous properties that are owned or under the control of the same
owner...
Instead of disclosing the more current (and conflicting) information, however, and
allowing meaningful public review and comment, the City relies on a 2018
transportation impact study that is now more than two and one-half years old for SEPA
analysis in an October, 2020 MDNS.
This lack of disclosure is inconsistent with SEPA and denies the public the information
needed to make meaningful comments on a project. Mitigation Measure 11 indicates
that cumulative traffic analysis could be included in the future, in a SEPA analysis
addendum or a revision to the Warehouse A and B TIA. It does not disclose or explain
the existence of conflicting and confusing studies covering the same property. The City
should withdraw the Warehouse B MDNS for this reason alone until the record is
complete and the public has had the chance to evaluate it.
2. Mitigation Measure 8 also discussed traffic volumes and impacts for travel to
and from the site, including origins or destinations north of the site. Because of the
impact of such traffic on residential and commercial areas north of the site, and
continuing congestion concerns at South 3201", including impacts from 1-5 off and on
ramps, the City should require that the applicant prohibit all trucks using the facility from
using Weyerhaeuser Way north of the site and require installation of traffic control
measures to enforce that requirement. This would include contract provisions with
customers and users of Warehouse B, prohibiting access from the north.
October 23, 2020
Page 6
The reports conducted on the campus's historic values, discussed below, find that the
curving, tree -lined roads are an important aspect of the environmental and historical
value of the campus. Mitigation Measure 8 would allow IRG to eliminate those curving
roads with ease, and with little further review of the impacts. The City believes that IRG
will balk at the costs of rebuilding these roads, but that is an untested assumption. One
can easily envision the opposite outcome: that a wide, straight thoroughfare allowing
industrial trucks to run parallel to a crowded I-5 would be well worth the cost for IRG.
Without real legal and contractual restrictions, the City is relying on an untested belief
as its only mechanism to avoid serious, adverse impacts to the quality of the
neighborhoods and the historic nature of the campus. We object strongly to the gamble
the City is engaged in, essentially pre -approving a new industrial truck route without
even a minimal evaluation of its environmental and other consequences.
3. The cumulative impacts discussed in Mitigation Measure #8 should not be
limited to impacts to S.R. 18, but consider all impacted intersections and roadways in
the City of Federal Way or other impacted areas.
IMPACTS ON HISTORIC RESOURCES.
The impacts to historic resources of the current proposal, taken individually and
cumulatively with Warehouse A and the Greenline Business Park, are significant and
require either the preparation of an environmental impact statement or significant
mitigation. The City's analysis of these impacts for Warehouse B relies on incomplete
and outdated information. The MDNS is not supported and should be withdrawn.
The historical importance of the former Weyerhaeuser corporate campus is
exceptional. This is evidenced by IRG's own consultant, Cardno, Inc., in identifying it as
a historic district eligible for listing in the National Register of Historic Places. Cardno
prepared a Built Environment Survey, a report submitted to the U.S. Army Corps of
Engineers (USACE) and the Washington Department of Archaeology and Historic
Preservation (DAHP)2. According to the Built Environment Survey, p. 6-3:
The former Weyerhaeuser Corporate Headquarters campus is an exceptional
example of built heritage that responds to its Northwest context by integrating
buildings and landscape into a synergistic whole while using materials, design,
and workmanship to reflect the corporate identity projected by the Weyerhaeuser
Company at this time in its history. The campus is also an outstanding example
of the work of landscape architect Peter Walker (SWA) and architect Edward
Charles Bassett (SOM). The former Weyerhaeuser Corporate Headquarters
campus is recommended eligible for listing in the NRHP as a historic district ...;
2 Michelle Sadlier et al., Built Environment Survey of the Former Weyerhaeuser Corporate Headquarters
Campus, Federal Way, Washington, Cardno, Inc. (July 29, 2020).
October 23, 2020
Page 7
The former Weyerhaeuser Corporate Headquarters campus, as defined below,
is a historic property so exceptional in historical and design importance that it
has achieved significance within the past 50 years.
Unfortunately, the City did not consider the Built Environment Survey in its SEPA
analysis on Warehouse B. Instead of referencing that 150+ page report, the SEPA
records reference a one -page Memorandum from Cardno to IRG, Built Environment
Survey of the Former Weyerhaeuser Corporate Headquarters Campus for Compliance
with Section 106 of the NHPA — Comments on SEPA Compliance for Woodbridge
Building B, Cardno, July 27, 2020 (Cardno SEPA Memo).
The Cardno SEPA Memo states the consultant's opinion that the impacts of
Warehouse B on the campus's historic resources are not significant under SEPA. This
reflected a similar opinion Cardno expressed in another report, on the effects of
Warehouses A and B under the National Historic Preservation Act.' Cardno has since
revised that second report, to reach the opposite conclusion:
Cardno recommends that the Woodbridge Building A and Woodbridge Building
B projects, along with their associated detention pond, will have an adverse
effect on the Weyerhaeuser Corporate Headquarters Historic District by
diminishing the integrity of the recommended contributing 50-foot buffer east of
Weyerhaeuser Road and the driving views the buffer provides.
(Emphasis provided.) Michelle Sadlier et al., Evaluation of Effects for the Proposed
Woodbridge Building A and Woodbridge Building B Projects, Federal Way,
Washington, Cardno, Inc., p. i (September 14, 2020). The City thus acted on
incomplete and outdated information in its MDNS decision on Warehouse B.
Even under Cardno's former position, however, the City's conclusions about the effects
of Warehouse B on historic values are incorrect. The applicant contends, and the City
appears to rely heavily on the idea, that the visual impacts of its industrial warehouses
are mitigated by a fifty -foot tree buffer. The tree buffer is inadequate, however, for three
reasons.
First, assessing the impacts of Warehouse B alone is not appropriate; the
impacts of Warehouse A., at least, should be included as they are adjacent to one
another and no construction has begun on Warehouse A.
Second, the site for Warehouse A and Warehouse B is a substantial wooded
area that should be included as part of the Historic District or a contributing area
thereto. We agree with the Washington Trust for Historic Preservation's position that
' Michelle Sadlier et al., Evaluation of Effects for the Proposed Woodbridge Building A and Woodbridge
Building B Projects, Federal Way, Washington, Cardno, Inc. (September 14, 2020).
October 23, 2020
Page 8
the entire wooded parcel is a contributing feature of the National Register eligible
district, not just the 50-foot buffer and driving views recommended by Cardno. The
U.S. Army Corps has not taken a position on this issue, and we expect it will be the
subject of well-informed stakeholder debate. We believe the destruction of the interior
forest stands for construction of Warehouse B would be a significant adverse
environmental impact requiring the preparation of an environmental impact statement or
significant mitigation.
And third, the minimal fifty -foot tree buffer is physically inadequate to buffer and
protect the campus's historic values, and the City's analysis has not taken into account
the expected loss of trees to windthrow and other edge effects.
Buffers must "obscure Warehouse [B] from sight," to quote the standard articulated by
the Hearing Examiner', to avoid probable significant adverse impacts to historic
resources. It is clear from the visual studies submitted to the City that Warehouse B will
be visible from the road, not "out of the way," and will cause adverse impacts. -See the
photos in Greenline Building B, Visual Impact Analysis, ESM Consulting Engineers
(August 10, 2018).
As ESM notes, the buffers around Warehouses A and B are already sparse. In addition,
50' is too narrow to protect against the inevitable loss of trees from windthrow and other
edge effects once the site is disturbed. IRG's arborist pointed out the risk of loss of
trees in Brian Gilles, Managed Forest Buffer Management Plan at the Greenline
Building B Site, Gilles Consulting (rev. June 26, 2018). On pages 5-6 he describes this
well-known phenomenon in Pacific Northwest forests:
Tree Risk Assessment must be taken seriously on this project and all of the
Campus development projects. This is due to the physiology of the trees
themselves, their growth in dense stands, the soils, and the large storms that
descend upon the region irregularly. When trees grow in a forest such as this,
they depend on the trees around them to buffer them from the wind and other
storm impacts. This results in a different physically structured tree than the same
species of the same age growing in an open setting such as a field, a park, or a
pasture.
Trees growing in a dense forest are tall and skinny. They do not have broadly
tapered bases or large buttress roots. They do not need them due to the
buffering effect of the forest as a whole. Their job is to grow tall and fast to catch
sunlight. If they do not keep up with the neighboring trees, they get shaded out
and slowly decline and die. Therefore, their internal resources are spent on
height growth.
4 Findings of Fact 13, Hearing Examiner decision.
October 23, 2020
Page 9
This is relevant and important in that, when dense forest trees are suddenly
opened to the wind and storm elements, by clearing of adjacent trees, they
are instantly vulnerable to windthrow in severe weather. This is because, as
noted above, they do not have adequate structure in their lower trunks and
buttress roots. This can be seen when driving forested lands in the northwest
and looking at wind -thrown trees at the edges of recent clear cuts.
Foresters have known this for over 100 years and have a term for it. They call
it, "New Edge." New Edge refers to the trees on the edge of a recent clear-cut.
There can be a high percentage of tree failures near the `new edge' created by
the clearing/logging of trees in a dense forest due to the growth characteristics
noted above. It can take a tree or line of trees along a newly cleared edge many
years to develop larger and roots and lower trunks to withstand large storm
loads.
Soils and saturated soils also play a huge role in tree risk assessment. The
region is known to have areas of hard pan or clay deposits below the surface.
Water can build up on top of these impenetrable layers and restrict roots from
penetrating deep. This can predispose a tree to fail if it is growing over one of
these dense layers and the soil is saturated and a storm overloads the strength
of the roots and soil.
The last comment about saturated soils is especially relevant here. The buffers most
vulnerable to windthrow are those on the windward side of the buffer (i.e., the down-
wind side of new openings). Because Federal Way's prevailing winds are from the
Southwest (especially during storms), the City should expect damage to the buffers
between Warehouses A and B and Weyerhaeuser Way S, the very buffers that are
most needed to block the driving views from the road. Compounding the problem,
IRG's documents have identified at least three wetlands in the managed forest buffer
along Weyerhaeuser Way S. Any trees growing in these wetland soils are even more
likely to come down after they lose the stands behind them. This will open even more
holes in the buffers, further increasing the visibility of the buildings.
How wide does a buffer need to be to resist windthrow and other damaging edge
effects? This was a major issue in Pacific Northwest forests in the late 90s as practices
improved to protect water bodies and fish habitat. According to experts, microclimate
effects generally extend about "one to three tree heights into forests," or roughly 100' to
600' considering all impacts. Rochelle, James A. et al., Forest Fragmentation: Wildlife
and Management Implications, p. 117, Brill (1999). On federal forest lands, scientists
used 300' as a conservative buffer to protect streams in the Northwest Forest Plan.
Washington's forest practice rules adopted stream buffers ranging from 100' (50' on
each side) to over 300' (both sides) under the 1999 Forests and Fish Agreement. The
EIS on Washington's rules used 75' as the minimum width for a riparian management
October 23, 2020
Page 10
zone (RMZ) for an "acceptable" amount of blowdown, which science suggests will still
be 15-20% of the trees. According to the EIS:
Another important aspect considered when evaluating the alternatives was
susceptibility to windthrow or blowdown. If an RMZ experiences substantial
windthrow, it may not be capable of maintaining desired functions.... The RMZs
under all alternatives are likely to experience some degree of windthrow in
localized areas. Windthrow is a normal occurrence in forests but is known to
increase along harvest unit edges after timber harvest opens formerly interior
forest trees to more direct wind effects (Harris 1989).
RMZs along streams are subject to similar increases in windthrow. Several
studies have attempted to define the relationship between riparian windthrow
and various physical and biological features such as topography, valley
morphology, aspect, slope, soil wetness, and tree type (Steinblums et al. 1984;
Harris 1989). Though these site -specific factors may increase the vulnerability of
an RMZ to wind events, no single factor has emerged as being of particular
importance on a landscape scale. However, since blowdown is generally greater
at the windward edge of a buffer, alternatives with wider RMZs would provide
more protection for riparian function.
Pollock and Kennard (1998) reanalyzed several windthrow data sets looking at
the relationship between buffer width and the likelihood of windthrow. They
reached the conclusion that buffers of less than 75 feet have a higher probability
of suffering appreciable mortality from windthrow than forests with wider buffers.
Data for blowdown within buffers from seven studies reported in Grizzel and
Wolff (1998) had a mean windthrow level of about 15 percent for 344 sites in
western Washington and Oregon with maximum windthrow levels ranging from
17 to 100 percent. Median windthrow levels were usually somewhat lower than
the mean because the data are not normally distributed with relatively few sites
having extensive blowdown. For example, the mean windthrow level for sites
reported by Andrus and Froelich (1986) was 21.5 percent while the median value
was 15.5 percent (i.e., half of the sites had less than 15.5 percent windthrow).
Windthrow levels in Southeast Alaska were found to average about 9 percent in
66-foot no -harvest RMZs over a 4 to 6 year period following harvest, and most
windthrow levels were less than 15 percent (Martin et al. 1998).... Susceptibility
to blowdown is addressed as appropriate in the effects analysis using a 75-feet
buffer width as a general guideline.
U.S. Dept. of Commerce, National Marine Fisheries Service & U.S. Dept. of the Interior,
Fish and Wildlife Service, Final Environmental Impact Statement, Chapter 4, p. 4-105.
The City needs to reevaluate its buffer requirements to factor in the predictable loss of
October 23, 2020
Page 11
10-15% of all of the significant trees plus the loss of most or all of the trees on wetland
soils. These impacts will be significant, and planting new trees will not be enough to
take their place. It will be decades before new trees provide the height, width, and depth
of crown provided by the existing forests on the Weyerhaeuser campus.
STORMWATER ANALYSIS.
As described above, the stormwater impacts of applicant's Warehouse A, Warehouse B
and Greenline Business Park should be considered together. IRG submitted its
environmental checklist on the Greenline Business Park project on October 13, 2016,
more than four years ago. That checklist described 1,067,000 square feet of new
warehouse facilities and 2,947,175 square feet of new impervious surface. A
preliminary stormwater analysis describing runoff from the site has been prepared.
In addition, the City has required a cumulative impact analysis for traffic at the
Warehouse B site in Mitigation Measure #11 that includes Warehouse A, Warehouse B
and the Greenline Business Park. No logical reason exists as to why cumulative impact
analysis for stormwater should not also be prepared, consistent with the City's
environmental analysis of cumulative impacts for traffic. The stormwater impacts of the
Greenline Business Park combine with those of Warehouse A and Warehouse B south
of the Campus and will flow south into the Hylebos Creek system. Given the Greenline
Business Park proposal is twice as large as the Warehouse A and Warehouse B
proposals together, the combined impact of all three projects to the Hylebos Basin will
unquestionably be significant. Further, the Greenline Business Park proposal was
initiated with the City more than four years ago, indicating the need to combine its
impacts with the Warehouse A and B proposals. See WAC 197-11-784.
CONCLUSION_
The MDNS on Warehouse B has been issued in error. The proposal, individually and
cumulatively with other proposals, will have probable significant adverse impacts on the
environment. The MDNS should be withdrawn, a determination of significance issued,
and scoping initiated for an environmental impact statement.
i erely
J. Richard Aramburu
J RA: cc
cc: Save Weyerhaeuser Campus
Attorneys at Law
J. Richard Aranburu 720 Third Avenue, Suite 2000
rick@aramburu-eustis.com Seattle, WA 98104
Jeffrey M. Eustis Tel 206.625.9515
eustis@aramburu.eustis.com Fax 206.682.1376
May 29, 2018
City of Federal Way
33325 8th Ave. S.
Federal Way, WA 98003
Attn: Brian Davis, Director
Department of Community Development
And Jim Harris
Planner
www.aramburu,eustis.com
Via Email:
Brian.Davis@cityoffederalway.com
Jim.Hards@cityoffederalway,com
Re: Greenline Business Park Application (File #17-105491);
Proposals for Warehouse A (#16-102947-00-UP, 16-102948-00-SE) and
Warehouse B (#17-104236-UP, 17-104237-SE).
Dear City of Federal Way:
This office represents Save Weyerhaeuser Campus, a Washington nonprofit
corporation organized and existing to protect and preserve the community and natural
values of the Weyerhaeuser Campus.
On May 14, 2018, the City of Federal Way determined that the application for the
Greenline Business Park (GBP) was complete. That proposal, made by Industrial
Realty Group of Los Angeles (IRG), includes the construction of three buildings totaling
approximately 1,068,000 square feet on a parcel of 146 acres and revisions to an
existing parking lot adding 806 parking stalls, which will involve, among other activities,
filling wetland and improving existing roads in the vicinity. On May 18, 2018, the City
issued a Notice of Master Land Use Application, initiating a fourteen day comment
period, The Notice indicates that the proposal will be reviewed under the
"Weyerhaeuser Company Pre -Annexation Concomitant and Zoning Agreement" (CA),
which places the property in the CP-1 zone created by the CA.
Previously, IRG submitted complete applications for two other construction projects also
located in the CP-1, Warehouses A and B. Warehouse A is a 225,950 square foot
warehouse building on 13.7 acres with 245 parking stalls; Warehouse B is a 217,300
June 4, 2018
Page 2
square foot warehouse building with 244 parking spaces immediately adjacent to
Warehouse A. The Warehouse A/B proposals will use a common access road and the
same stormwater detention pond. These two projects are owned by the same applicant
as for the Greenline Business Park. The City has not issued a threshold determination
under SEPA for either of IRG's Warehouse proposals.
In this letter, SWC provides comment on the rules, regulations and standards applicable
to the pending permit applications. First, any review of the business park proposal under
both current zoning and the State Environmental Policy Act (SEPA) must consider the
consolidated and cumulative impacts of all three pending proposals and cannot proceed
with separate, individual, fragmented review. Second, the existing rules and
regulations, including the CA, cannot be read to vest applications to rules and standards
adopted twenty-four years ago. In several specific areas, the City should apply current
standards and regulations adopted after Ordinance 94-219 (including the CA and its
zoning) was adopted in 1994. These issues will be addressed below.
1. THE CITY MUST CONDUCT COMBINED AND CONSOLIDATED REVIEW OF THE
THREE PENDING PROPOSALS.
1.1. SEPA REVIEW. Because of the background of this proposal, the City is
required to conduct consolidated land use and environmental review of the pending
applications, not segmenting or bifurcating review. This is based on the following.
A. ONE OWNER. The entire 426-acre Weyerhaeuser Campus was purchased
in 2016 by IRG, a California developer of warehouses and business parks.
B. THREE CURRENTLY PENDING APPLICATIONS. IRG has filed applications
for use of significant portions of the Weyerhaeuser Campus, including the GBPark,
Warehouse A and Warehouse B, which have all been deemed complete by the City.
These three applications will be referenced herein as the "IRG Applications." Each of
the applications is currently pending and no threshold determination has been issued for
any of them. Comments on the GBP are due on June 4, 2018.
C. SAME ZONE FOR ALL PARCELS. The IRG Applications are all in the CP-1
zone. That zone is ono applicable to the Weyerhaeuser Campus parcels and not to
any other properties in the city.
D. UNDER SEPA, THE THREE PENDING APPLICATIONS MUST BE
CONSIDERED IN A SINGLE ENVIRONMENTAL DOCUMENT.
The City of Federal Way has adopted by reference most of the Washington State
SEPA Rules, WAC Chapter 197-11, into Federal Way's code in FWC 14.05.020.
June 4, 2018
Page 3
Included in this adoption is WAC 197-11-060, including Subsection (b). This section
provides as follows-
(b) Proposals or parts of proposals that are related to each other closely enough
to be, in effect, a single course of action shall be evaluated in the same
environmental document. (Phased review is allowed under subsection (5).)
Proposals or parts of proposals are closely related, and they shall be discussed
in the same environmental document, if they:
(i) Cannot or will not proceed unless the other proposals (or parts of
proposals) are implemented simultaneously with them; or
(ii) Are interdependent parts of a larger proposal and depend on the larger
proposal as their justification or for their implementation.
In addition, WAC 197-11-060(c) provides as follows:
(c) (Optional) Agencies may wish to analyze "similar actions" in a single
environmental document.
(i) Proposals are similar if, when viewed with other reasonably foreseeable
actions, they have common aspects that provide a basis for evaluating their
environmental consequences together, such as common timing, types of
impacts, alternatives, or geography. This section does not require agencies or
applicants to analyze similar actions in a single environmental document or
require applicants to prepare environmental documents on proposals other than
their own.
(ii) When preparing environmental documents on similar actions, agencies
may find it useful to define the proposals in one of the following ways: (A)
Geographically, which may include actions occurring in the same general
location, such as a body of water, region, or metropolitan area; or (B) generically,
which may include actions which have relevant similarities, such as common
timing, impacts, alternatives, methods of implementation, environmental media,
or subject matter.
These provisions were considered in Indian Trail Property Owner's Ass'n v. City of
Spokane, 76 Wn.App. 430, 886 P.2d 209 (1994). There a shopping center
redevelopment and expansion were under review, including a large grocery store and
other features. However, two parts of the overall proposal were not included in the
original environmental checklist and threshold determination, a car wash and large
underground storage tanks, and were proposed for later environmental review. On a
challenge to this segmented environmental review, the Court of Appeals said as follows:
Cumulative Effects. We note at the onset that the responsible official's initial
evaluation of the underground fuel storage tanks separate from other phases of
the proposal was in error. Parts of proposals which are "related to each other
June 4, 2018
Page 4
closely enough to be, in effect, a single course of action shall be evaluated in the
same environmental document." WAC 197-11-060(3)(b). Here, a phased review
of the project was clearly inappropriate because it would serve only to avoid
discussion of cumulative impacts. WAC 197-11-060(5)(d)(ii). See also WAC 197-
11-060(3)(b). However, the error was cured when the original MDNS and DNS
were withdrawn, and the cumulative effects of the entire project considered
before a new MDNS was issued.
Redevelopment of the shopping district also included plans for a car wash. In 131
zones, a car wash requires a special permit. When addressing neighborhood
concerns about the noise impacts from the car wash, the hearing examiner
responded "there is no car wash in this application and a special permit must be
applied for before a car wash can be built in conjunction with this use". To the
extent the hearing examiner was approving separate SEPA review for the car
wash, he was in error. WAC 197-11-060(3)(b). However, the error was harmless
because the responsible official considered the impact of the car wash when
making the threshold determination and required mitigation measures for it.
76 Wn.App. at 443.
As noted above, the IRG Applications have a common owner (IRG), common
timing (all have complete pending applications), common geography (all on the
Weyerhaeuser Campus), common impacts and common zoning (CP-1, applicable only
to this property). The most significant impacts of the combined proposals affect traffic
and transportation, with significant impacts to off -site city roads and state highways
including 1-5 and SR 18. Complete and accurate traffic and transportation analysis
should include not only the three current proposals, but an accurate analysis for the
future use of the Weyerhaeuser Headquarters building (more than 300,000 square feet),
which is currently offered for lease by IRG to a single tenant. Currently, the traffic report
for Warehouse A, for example, does not include potential traffic from Warehouse B, the
GBP, or the Weyerhaeuser headquarters building. The projects, individually and
cumulatively, will also impact downstream water resources, including the Hylebos
stream, Milton's East Hylebos Ravine, Fife's Lower Hylebos Nature Park and associated
wetlands and habitat. The GBP proposal alone will total 1,441,000 square feet of
impervious surface.
Under the applicable regulations and caselaw, it would be error for the City to
conduct separate environmental review for IRG's proposals. The City should require
IRG to submit an environmental checklist that includes the cumulative impact of all three
projects. There appears to be little question that a proposal with more than 2,000,000
square feet of structure and other impervious surfaces will have a significant impact on
the environment and accordingly requires an environmental impact statement (EIS).
June 4, 2018
Page 5
1.2. LAND USE REVIEW. In addition, the three development proposals are
included within the "Corporate Park 1 " or "CP-1 " zone, which was adopted by the City in
Ordinance 94-219 as a part of the annexation of this and other nearby property in 1994.
The CP-1 zone only applies to the former Weyerhaeuser Campus. Ordinance 94-219
also reached certain "Conclusions of Law," beginning at page 4; these Conclusions
applied to the entire annexation area, including the property where the three pending
proposals are located. Conclusion B states that the property, as a whole, has "unusual
environmental features" and that the ordinance is the "means to preserve and protect
these natural features," again referencing the entire annexation area. Conclusion C
states that "any development in the corporate headquarters area is low density
characterized by large expanses of open space." The applicant contends that the 1994
CA controls development on the Weyerhaeuser Campus. While that is not entirely
correct, as pointed out below, it is apparent that the CA requires that the entire site be
considered when development proposals are made. For example, under Paragraph
14.2 of the CA, existing streets had "been constructed to meet capacity needs for on -
site development up to an additional 300,000 square feet of Corporate Office Park
development;" this provision regarding street capacity is applicable to the entire site.
The CP-1 zone found at Exhibit C to the CA also stresses that the entire site is to
be considered together in review and analysis. The CP-1 zone states its Purpose and
Objectives, saying that the properties in the zone:
...are characterized by large contiguous sites with landscape, open space
amenities, and buildings of superior quality. The property appropriate for such
uses is unique, and demands for such uses are rare. Consequently special land
use and site regulations are appropriate for such properties.
CP-1 Zone, page C-1. Subsection A states "This property is subject to its own unique
standards of review processes as set forth in the Agreement." Id. The same is true of
provisions for "Off -Street Parking" found in Exhibit C, in Section XIII at page C-18, that
although new development shall require compliance with applicable off-street parking
requirements:
the aggregate of all proposed and existing uses on the property may, subject to
the approval of the Director, be considered as a whole in establishing the
minimum number of vehicles spaces required, .. .
It is wholly inconsistent with the CP-1 zoning, and the background of the CA and
Ordinance 94-219, to separately consider individual projects when the City recognizes
that the proposals are located on a unique property. This is especially true when IRG,
the property owner, has three complete and pending applications to use substantially all
of the CP-1 zoned area. Based on the foregoing, it is apparent that since 1994 the City
has considered the Weyerhaeuser Campus unique and has adopted unique standards
June 4, 2018
Page 6
of review applicable to the entire site. Site development, by a common property owner,
must be considered as a consolidated whole for permitting purposes.
2. THE CITY IS REQUIRED TO APPLY CURRENT CODES AND STANDARDS, NOT
THOSE IN EFFECT IN 1994.
As noted above, Ordinance 94-219 is now twenty-four years old, but the
applicant for the three pending projects claims that the ordinance, and the CA, vest
these new proposals to rules, regulations and standards in effect when the ordinance
was adopted. The City should reject that proposition and apply current adopted
standards.'
The applicant seeks to apply certain provisions of the CA to its current land use
applications. Among others, the applicant asks the City to follow certain criteria in
review of its proposals, including the following provisions of the development agreement
that are contrary to codes.
1) The agreement "not to require any dedication or conveyance of the Property or
any portions thereof for public purposes ....
Paragraph 12, page 10.
2) Agreement to consider roads adequate for the addition of 300,000 square feet
of new Corporate Office Park development that might be located anywhere on
the site.
Paragraph 14.2, page 11.
3) Agreement that the property owners "shall be vested for purposes of roadway
capacity requirements and any concurrency requirements and Weyerhaeuser
shall not be required for pay for any new public streets within the Property area
or traffic mitigation fees for these streets in connection with the Additional
Development.
Paragraph 14.2, page 11, Paragraph 15, page 13.
4) Agreement that areas of the Property which are "classified as environmentally
sensitive" shall comply with the critical areas ordinance in effect in 1994, except
for special provisions found at pages C-12 to C-18.
Exhibit C to Ordinance 94-219, Section XII.
Washington law is clear that no city may establish fixed land use and
development regulations that cannot be ever modified or changed.
As described above the City should consider IRG's three pending proposals together as a single
application following evaluation of the whole proposal under SEPA.
June 4, 2018
Page 7
A) Washington Law Prohibits One Legislative Body from Binding Future
Councils.
The effect of the CA as interpreted by the applicant is that no later rules,
regulations, legislation or council action can modify the agreement; it is permanent and
never capable of modification. This concept is not consistent with Washington law for
the following reasons.
Under settled Washington law, a municipality "cannot enter into contracts binding
on future boards of commissioners." See State ex. rel. Schlarb v. Smith, 19 Wn.2d 109,
112, 141 P.2d 651 (1943). See also Miller v. City of Port Angeles, 38 Wn.App. 904
(1984) where it is recognized that a local government cannot contract away its police
power. It is recognized that this rule must be construed in the context of whether the
contract involves its legislature function or its administrative/proprietary function. This
issue was considered in some detail in AGO 2012, No. 4, which concluded as follows:
If a contract impairs the "core" legislative discretion, eliminating or substantially
reducing the discretion future bodies might exercise, the courts are likely to find
that the contract has improperly impaired the legislative authority of future
commissioners."
Moreover, the CA permits deviations from the current city standards. For example, at
Paragraphs 14.2 and 15, the CA prohibits the city from collecting impact fees for an
additional 300,000 square feet of corporate office development, an indulgence not
permitted under existing codes. Similarly, Section XII of the CP-1 zoning allowed
deviations from even the then -existing sensitive area ordinances, making it inconsistent
with those codes. Indeed, Paragraph 4.1 of the CA (page 5) specifically provides that
"to the extent Federal Way policies impose development standards conflicting with this
Agreement, this Agreement shall control." Accordingly, the CA, which is claimed to bind
all Federal Way councils forever, is ultra vires.
It is also important to note that the CA in question is different from contract
rezones or other similar legislative actions. These agreements ordinarily set forth what
will, or will not, be done on a property as a part of a rezone; in such cases, the work will
be completed as a part of the contract rezone. The CA here is not related to any project
proposed when it was executed; its sole intention is to limit the authority of the City to
take actions in the future and to allow undefined future development.
B) Washington Law Regulating Annexation Zoning Ordinances Does Not Permit
Ordinances That Last Forever.
As a city formed under the Optional Municipal Code (OMC), RCW Title 35,
Federal Way must comply with the terms of chapter 35.14 when annexing new territory.
June 4, 2018
Page 8
In particular, RCW 35A.14.330 allows an OMC city to prepare a zoning regulation to
become effective in an area to be annexed. Subsections (1) and (2) define the scope of
a potential pre -annexation zoning, while subsection (4) provides as follows:
(4) The time interval following an annexation during which the ordinance or
resolution adopting any such proposed regulation, or any part thereof, must
remain in effect before it may be amended, supplemented or modified by
subsequent ordinance or resolution adopted by the annexing city or town.
As described, this legislation allows an OMC city to establish only a "time interval"
during which the pre -annexation zoning regulation "must remain in effect." Without such
a "time interval," a local legislative authority could amend the interim zoning ordinance
at any time, as described above.
RCW 35A.14.330(4) plainly requires zoning have a "time interval" during which
the pre -annexation zoning will be binding before it may be amended or modified.
Nothing in this statute allows the local government to make permanent pre -annexation
zoning, any more than zoning adopted pursuant to the planning and zoning chapter of
the OMC, chapter 35A.63, could be made permanent.
The statute is supported by Washington caselaw regarding the permanency of
zoning, as discussed in Bishop v. Town of Houghton, 69 Wn.2d 786, 792, 420 P.2d 368
(1966):
We have no quarrel with respondents' basic theme to the effect that while zoning
implies a degree of permanency, it is not static and zoning authorities cannot
blind themselves to changing conditions. Thus, when conditions surrounding or in
relation to a zoned area have so clearly changed as to emphatically call for
revisions in zoning, the appropriate zoning authorities are under a duty to initiate
proceedings and consider the necessity of pertinent modifications of their zoning
ordinances. Otherwise, outmoded zoning regulations can become unreasonable,
and the zoning authorities' failure to suitably amend or modify their ordinances
can become arbitrary, in which event courts can and should grant appropriate
relief. 2 Metzenbaum, Zoning, 1125 (2d ed. 1955).
Land use regulations cannot be frozen in time nor be immune to new priorities,
changed circumstances, scientific study or community needs.
A zoning ordinance that can never be modified is inconsistent with the authority
granted to the City of Federal Way and is thus void.
June 4, 2018
Page 9
C) The GMA Requires Updating of Development Regulations on a Periodic
Basis; The CA Cannot be Immune from the Obligation of Continuing Review.
Federal Way is not only subject to the rules established by the OMC, but also to
the Growth Management Act, RCW chapter 36.70A (GMA). One of the obligations
imposed by the GMA under RCW 36.70A.130 is for continuing review on a periodic
basis. Under this statute each local Comprehensive Plan and the local development
regulations:
shall be subject to continuing review and evaluation by the county or city that
adopted them. Except as otherwise provided, a county or city shall take
legislative action to review and, if needed, revise its comprehensive land use
plan and development regulations to ensure the plan and regulations comply with
the requirements of this chapter according to the deadlines in subsections (4)
and (5) of this section.
(Emphasis supplied.)2 Subsection (1)(c) further states: "(c) The review and evaluation
required by this subsection shall include, but is not limited to, consideration of critical
area ordinances...." These sections requiring periodic review were imposed by the
legislature after the adoption of Federal Way's Ordinance 94-219 in 1994. The
provisions are to assure that local government regulations remain current with scientific
advancements and needs of the community. In addition, when considering amendment
of a comprehensive plan or development regulations, the City is obligated to "establish
and broadly disseminate to the public a public participation program identifying
procedures providing for early and continuous public participation in the development
and amendment of comprehensive land use plans and development regulations
implementing such plans." RCW 36.70A.140.
As it relates to critical areas, since the adoption of Ordinance 94-219 by the City,
new legislation has modified the content of critical area rules. In 1995, the Legislature
adopted RCW 36.70A.172, which requires as follows:
(1) In designating and protecting critical areas under this chapter, counties and
cities shall include the best available science in developing policies and
development regulations to protect the functions and values of critical areas. In
2 Use of the word "shall" by the legislature has a distinct meaning in Washington jurisprudence:
Moreover, "shall" when used in a statute, is presumptively imperative and creates a mandatory
duty unless a contrary legislative intent is shown. Phil. 11 v. Gregoire, 128 Wash.2d 707, 713, 911
P.2d 389 (1996); State v. Krall, 125 Wash.2d 146, 148, 881 P.2d 1040 (1994).
Goldmark v. McKenna, 172 Wn.2d 568, 575, 259 P.3d 1095, (2011).
June 4, 2018
Page 10
addition, counties and cities shall give special consideration to conservation or
protection measures necessary to preserve or enhance anadromous fisheries.
This section mandated that local governments take account of best available
information in adopting critical area regulations, including publications such as
"Wetlands in Washington State - Volume 2: Guidance for Protecting and Managing
Wetlands." See https:Hfortress.wa.gov/ecy/publications/summarypages/0506008.html.
As noted above, the applicant seeks to opt out of these provisions by reliance on
Ordinance 94-219. However, the City has recently adopted Ordinance 15-797, codified
as Chapter 19.145 of the Federal Way Code, which regulates Environmentally Critical
Areas (ECA) in the City. The purpose of this ordinance is as follows:
The purpose of this chapter is to protect the environment, human life, and
property from harm and degradation. This is to be achieved by precluding or
limiting development in areas where development poses serious or special
hazards; by preserving and protecting the quality of drinking water; and by
preserving important ecological areas such as steep slopes, streams, lakes and
wetlands. The public purposes to be achieved by this chapter include protection
of water quality, groundwater recharge, stream flow maintenance, stability of
slope areas, wildlife and fisheries habitat maintenance, protection of human life
and property and maintenance of natural stormwater storage and filter systems.
FWC 19.145.010. FWC 19.145.015 provides as follows: "Except as otherwise
established in this chapter, if a proposed development activity requires city approval,
this chapter will be implemented and enforced as part of that process." FWC
19.145.020 clarifies its application: "The provisions of this division apply throughout the
city and must be complied with regardless of any other conflicting
provisions of this
title." The provisions of this title that do not conflict with the provisions of this division
apply to the subject property. Conflicts with the CP-1 zoning are resolved in favor of the
adopted critical area ordinances.
Accordingly, the property in the CP-1 zone must be consistent with the revised
ECA ordinance; no provision of the current code exempts the CP-1 zone from its
application or allows a completely out of date code to be applied in the city.
D) The Attempt in the CA to Vest to Future Permit Activity is Inconsistent with
Washinaton Law.
In 1987, the Washington Legislature established the rules for vesting of
development applications in RCW 19.27.095 and 58.17.033. In this legislation, either a
building permit or a plat would vest when a "fully complete application" was made. As
noted in Snohomish County v. Pollution Control Hearings Board, 386 P. 3d 1064, 187
June 4, 2018
Page 11
Wash. 2d 346, 105 Wash.2d 778, 789, 719 P.2d 531 (2016): "Washington's vested
rights doctrine originated at common law, but is now statutory", citing Town of Woodway
v. Snohomish County, 180 Wn.2d 165, 173 (2014) (emphasis supplied).
The applicant here claims that it is vested to 1994 standards by virtue of the CA,
but the terms of Washington law do not allow vesting in advance of the filing of a
complete building permit or plat application. There was no complete building permit or
plat application filed when the CA was agreed to in 1994. Our courts have held that the
statutory vesting doctrine only applies when an applicant files "a completed application
for a building permit." Potala Village Kirkland, LLC v. City of Kirkland, 183 Wn.App. 191,
334 P.3d 1143 (2014). In Potala, the Court rejected the proposition that an application
for a substantial development permit would vest rights against zoning changes.
In the present case, the applicant claims the Pre -Annexation Zoning Agreement
and the CP-1 Zoning in the CA vest it to development regulations in effect at the time,
some twenty-four years ago. But, nowhere has the legislature adopted a rule that
allows pre -annexation zoning under RCW 35A.14.330 to vest development rights. The
rules established in 1987 codified the vested rights doctrine and limited its application to
building permits, plats and later (1995) development agreements. Attempts to vest
rights based on this pre -annexation zoning are not effective and any review of the
current applications should be consistent with existing land use regulations and
controls.
3. CONCLUSION.
The applicant's proposals violate basic standards for review.
First, with three complete applications on the CP-1 zoned property, Washington
law and local ordinances require that project review be consolidated. This applies not
only to review for consistency with the city codes, but also SEPA review and analysis.
An environmental checklist should be prepared that identifies and reviews the entirety of
the three pending applications. This does not present a hardship to the applicant
because it has already assembled data for its projects, all that is required is the
consolidation of this information.
Second, the city should apply current zoning, environmental and critical area
ordinances to the three applications. Consideration of the pending applications under
twenty-four year old ordinances is completely inconsistent with Washington law that
prohibits ordinances that would bind local governments forever, especially in light of the
statutory requirement to continually assure that zoning and environmental regulations
are updated to take account of the latest standards and considerations.
June 4, 2018
Page 12
Thank you for consideration of SWC's views. Please do not hesitate to contact me if
you have any questions.
Sincerely,
PA . 7
uRu EuSTi , LLP
J. Richard Arambur Uv
JRA:cc
cc: Save Weyerhaeuser Campus
Stacey Welsh
From: Stacey Welsh
Sent: Friday, October 23, 2020 4:42 PM
To: Ping Inquiry
Subject: FW: comment letter @ File NO. 17-104237-SE
Attachments: HSFW letter to city whse B Weyco.docx
From: Suzanne Vargo
Sent: Friday, October 23, 2020 4:35 PM
To: Stacey Welsh
Subject: comment letter @ File NO. 17-104237-SE
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Hello Stacey,
Please find my attached letter in regards to Warehouse B on the Weyerhaeuser Campus.
Thank you kindly.
Suzanne Vargo
October 21, 2020
Planning Department
Attn: Stacey Welsch
File No. 17-104237-SE
Dear Mr. Davis and Mr. Harris;
The Historical Society of Federal Way is grateful for our opportunity to speak on this matter. We the
board members of the Historical Society wish to oppose this application for warehouse B.
In past letters relating to both the proposed A & B warehouses, the Historical Society has expressed
their concerns regarding the historical and cultural impacts these warehouses will have to the Campus
property. Today we have learned that the Cultural Landscape Foundation (TCLCF) has enrolled the
Weyerhaeuser Campus in LANDSLIDE. A program used to educate and thereby rally support at local,
state, and national levels by calling attention to threatened and at -risk landscapes nationwide. The
Campus is regarded as a national and international icon. The Historical Society encourages the city allow
proper evaluation and assessment of the property and allow a complete and cumulative EIS study be
performed.
We highly encourage the city to work with IRG and designated the entire property and the structures
within it as an Historical District. There are one of a kind Project houses, an old firehouse as well as
remnants of occupation from the 1920's along the western shores of the lake. The architecture and
landscape were the first of its kind and have received numerous awards for excellence in these fields
respectfully. The Weyerhaeuser Campus should be placed on the King County Landmark Registration
along with the State and National eligibility for Historic and Cultural recognition.
The Campus received the Most Endangered Place nomination for 2017 (including land for the first time),
by the Washington Trust for Historic Places. Also, this year a Washington State Architectural Historian
placed the property on the National Register of Historic Places as a Determination of Eligibility. National
agencies as well as our state have determined the significance of the land and how it is associated with
the Headquarters building. Architects of Skidmore and Owings; "The Campus was intentionally
designed and executed to enhance the Northwest character of this place, disturbing as little as
possible and complementing elsewhere." (Guide to Headquarters IV- Exterior Landscaping@ Historical
Society)
The integrity of the view shed will be compromised by the removal of the buffer of trees separating the
proposed warehouses from the HQ building. The Concomitant Agreement should be upheld and no
trees should be removed as this would deter from the seamlessness of nature and the modern
architecture that currently coexisting as one. Weyerhaeuser had plans for more buildings, but these
were to be placed in an alike manner and setting of buildings like the Technology Center. This building
was unseen by drivers, (before the clearing), and was another perfect example of integrating
development with the natural environment. The integrity of the Campus was not compromised with
the Tech Center, so we know this type of development is possible and is the desire of our group.
While IRG may not think this acreage is of any value to the Headquarters, they fail to acknowledge
Stream EA, and its importance. This tributary collects head waters from the North Lake (of which there
are two) and then travels south to the swale at the end of the property, before it heads under Hwy.
18.As the city is aware this channel of water is a vital addition to the East Hylebos Creek. . According to
documents obtained from the Historical Society of Federal Way, the lands in question are indeed
historic.
GUIDE TO HEADQUARTERS:
Exterior Landscaping;
Both sides of the south meadow are stands of Douglas Fir. Established by nature without man's aid
after the original stand was harvested in the late 1800's, this forest is typical of much current forest in
the Pacific Northwest in all but high elevations. This is a description of the area proposed for A & B
warehouses.
The EIS study should be conducted with an independent agency, as the firm ESM works for both IRG and
the City of Federal Way. We believe this to be a direct conflict of interest.
Traffic impacts will be more than significant if these two warehouses are constructed. The truck travel
will exceed 400 trips, and this will increase even more with the addition of 3 more massive warehouses.
New businesses have opened up across the street along Weyerhaeuser Way S, after a very long time of
vacancy. How will IRG generated traffic impacts affect these businesses and their employees? Has this
business complex been taken into account for cumulative traffic analysis and how their volumes will
affect our daily driving? It is these traffic impacts that will dictate how citizens and employees travel to
and from the southern part of our city. When impacts are high, patrons of Federal Way businesses will
find another city to shop at. This affects not only the economy of our city but its culture.
Along with traffic comes air noise and water run off concerns. The road of Weyerhaeuser Way South
will undoubtedly be nonfunctional as Hwy. 18 is already at maximum failure according to DOT
documents. Semi -trucks will then flow into residential neighborhoods looking for a way to the Port of
Tacoma. This poses serious safety concerns to our children waiting and walking to and from the bus
stops and schools. Over a million sq. ft. of impervious surfaces placed on top of Stream EA, and
surrounding wetlands will spell disaster for the groundwater run off/ aquifer. For not only will
development cover over a million sq. ft of land, but every tree root, native species and the unique one -
of -a -kind soil fines will be removed. This process will ultimately be the end of the water source that
contributes to the East Branch of the Hylebos. No one knows of the impacts this destruction will have to
our Milton Redondo aquifer. For this reason a complete EIS must be performed.
We at the Historical Society are committed to preserving the Weyerhaeuser legacy and all the numerous
contributions they have made to our city. We would not be Federal Way without the Weyerhaeuser
Company. We urge the city to ponder the words of George Weyerhaeuser:
"Protecting the environment may determine not only whether we stay in business, but also whether we
can survive as a society." George Weyerhaeuser
Weyerhaeuser Company recognizes both the desirability and the necessity of operating its facilities
without materially impairing the qualities of the atmosphere or of the receiving waters or in a manner
damaging to the other lawful uses and users thereof. These were the principles placed on the Campus,
and it should serve as a fine example to the city of Federal Way, of how its lands can be utilized and
preserved to serve its citizens for future generations.
We ask the city to be mindful of the assets this property provides to its citizens, its environment and its
history.
Thank you for your time.
Historical Society of Federal Way
Stacey Welsh
From: Stacey Welsh
Sent: Friday, October 23, 2020 4:19 PM
To: Ping Inquiry
Subject: FW: Comments on MDNS Woodbridge B
Attachments: KingCoHPP response to MDNS Woodbridge Building B.pdf
From: Scott, Todd
Sent: Friday, October 23, 2020 4:14 PM
To: Stacey Welsh
Subject: Comments on MDNS Woodbridge B
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Good afternoon Stacey,
Please see the attached comments for this MDNS. Thank you for the opportunity to comment.
J. Todd Scott, AIA
Preservation Architect/Planner
King County Historic Preservation Program 12913 Franklin Ave East, Suite A I Seattle, WA 98102
206.477.4545 1206.861.5422 mobile I todd.scott@kingcounty.gov I www.kingcounty.gov/landmarks
My available hours are typically 9 am to 6 pm Monday — Friday
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Hello,
Attached you will find an MDNS and enclosures regarding the Woodbridge Building "B" project. Please contact
Principal Planner Stacey Welsh at 253-835-2634 or stacey.welsh@cityoffederalway.com, if you have any
comments and/or questions regarding this MDNS.
Regards,
E. Tina Piety, CAP, OM
Administrative Assistant II
1 eral Way
Community Development Department
33325 8th Avenue South
Federal Way, WA 98003-6325
Phone: 253/835-2601 Fax: 253/835-2609
www.citvoffederaIway.com
L19 King County
Department of Natural Resources & Parks
Historic Preservation Program
2913 Franklin Ave E, Suite A
Seattle, WA 98102
October 23, 2020
Stacey Welsh, Principal Planner
Planning Division, Community Development Department
City of Federal Way
Stacey.welshgcityoffederalwa.
[sent by electronic mail]
RE: Comments on MDNS for Woodbridge Building B, File No. 17-104237-SE
Ms. Welsh,
This letter is in response to the notice provided by the Federal Way Community Development
Department for comments related to the above referenced MDNS. Our office, the King County
Historic Preservation Program (HPP), currently maintains an interlocal agreement with the City
of Federal Way to provide a variety of historic preservation services whenever the City needs
them. We have not been asked to participate in the development of this MDNS or to review any
aspect of this project, but we are still provided with notices whenever a project requires review
under the State Environmental Policy Act (SEPA). These comments are a result of that
notification.
The property in question has recently been identified as a potential historic district known as the
Weyerhaeuser Corporate Headquarters Historic District. This district has been determined
eligible for the National Register of Historic Places and would also qualify as a City of Federal
Way Landmark District. This modern campus is internationally renowned for its architecture
and its landscape design, and is a nationally significant cultural landscape, perhaps the most
significant in King County. The campus may also be eligible as a National Historic Landmark,
one of only two dozen in Washington.
The current building plans have an adverse effect on this district. The SEPA checklist does not
adequately address this adverse effect and offers no guidance on how it could be mitigated.
However, there are opportunities to modify the proposed plans so that they are more compatible
with the historic, cultural, and landscape character of the site.
Consequently, our office would recommend that an Environmental Impact Statement (EIS) be
completed prior to issuance of a construction permit for this building. The EIS could offer a
variety of options to consider including relocating the building or modifying its plan to minimize
the adverse effect on this internationally significant historic district. Furthermore, an EIS would
provide the City with some additional assurance that all avenues for development of this critical
site have been considered, and potentially ease public pressure on the City on what is surely to be
a highly visible and public project.
If you have any additional questions regarding this matter, please feel free to contact me at (206)
477-4545 or todd.scottgkin _ cg ounty.gov.
Sincerely,
J. d Sc , AIA
Preservation Architect/Planner
cc: Jennifer Meisner, Historic Preservation Officer, King County
Stacey Welsh
From: Stacey Welsh
Sent: Friday, October 9, 2020 3:01 PM
To: Ping Inquiry
Subject: FW: Mitigated Determination of Nonsignificance (MDNS)
From: Schultz, Shirley <shirley.schultz@cityoftacoma.org>
Sent: Friday, October 9, 2020 2:50 PM
To: Tina Piety <Tina.Piety@cityoffederalway.com>
Subject: RE: Mitigated Determination of Nonsignificance (MDNS)
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Thank you, Tina.
I don't think that the City of Tacoma will have any comments. Have a good weekend!
Shirley Schultz, AICP
City of Tacoma I Development Services
o: 253-591-5121
c: 253-345-0879
shirley.schultz@citvoftacoma.org
www.tacomapermits.org
We work with the community to plan and permit a safe, sustainable, liable city.
Take our survey!
From: Tina Piety <Tina. Piety@ cityoffed era lway.com>
Sent: Friday, October 9, 2020 2:38 PM
To:'separegister@ecy.wa.gov' <separegister@ecy.wa.gov>; contactus@federalwayhistory.org;
'rybolt.s@portseattle.org' <rybolt.s@portseattle.org>; suzanne.l.anderson@usace.army.mil; 'rob.ryan@wa.usda.gov'
<rob.ryan@wa.usda.gov>; hubenbi@dshs.wa.gov; iford@agr.wa.gov;'reviewteam@commerce.wa.gov'
<reviewteam@commerce.wa.gov>; hgcustomerservice@wsdot.wa.gov;'mccolld@wsdot.wa.gov'
<mccolld@wsdot.wa.gov>; sepacenter@dnr.wa.gov; sepa@dahp.wa.gov; sepadesk@dfw.wa.gov;
'randy.kline@parks.wa.gov' <randy.kline@parks.wa.gov>; 'kukesc@wsdot.wa.gov' <kukesc@wsdot.wa.gov>;
'larry.fisher@dfw.wa.org' <larry.fisher@dfw.wa.org>; info@psp.wa.gov; wec@wecprotects.org;
'kelly.cooper@doh.wa.gov' <kelly.cooper@doh.wa.gov>; 'swiresm@wsdot.wa.gov' <swiresm@wsdot.wa.gov>;
'eharris@psrc.org' <eharris@psrc.org>;'sepa@pscleanair.org' <sepa@pscleanair.org>;
'brandon.reynon@puyalluptribe.com' <brandon.reynon@puyalluptribe.com>;'todd.scott@kingcounty.gov'
<todd.scott@kingcounty.gov>; 'neil.fujii@kingcounty.gov' <neil.fulii@kingcounty.gov>; 'info@edc-seaking.org'
<info@edc-seaking.org>; 'james.irish@soundtransit.org' <iames.irish@soundtransit.org>;
'perry.weinberg@soudtransit.org' <perry.weinberg@soudtransit.org>; 'jgreene@kingcounty.gov'
<i>;reene@kingcounty.gov>;'info@forterra.org' <info@forterra.org>;'jjordan@portoftacoma.com'
<iiordan@portoftacoma.com>;'tvaslet@piercetransit.org'<tvaslet@piercetransit.org>;'chase.wakefield@bp.com'
<chase.wakefield@bp.com>; 'timothy.fehr@bp.com' <timothy.fehr@bp.com>; 'keith.boyle@bp.com'
<keith.bovle@bp.com>;'aclark@co.pierce.wa.us'<aclark@co.pierce.wa.us>;'kent.hale@soundtransit.org'
<kent.hale@soundtransit.org>; 'dlathrop@desmoineswa.gov' <dlath rop@desmoineswa.gov>; 'wfwoctap@fws.gov'
<wfwoctap@fws.eov>;'sclary@mbaks.com' <sclary@mbaks.com>;'janderson@mbaks.com' <ianderson@mbaks.com>;
'sam@sampace.com' <sam@sampace.com>; Schultz, Shirley<shirley.schultz@citvoftacoma.org>; Magoon, Jana
<JMAGOON@citvoftacoma.org>; 'info@earthcorps.org' <info@earthcorps.org>; 'epa-seattle@epa.gov' <epa-
seattle@epa.gov>; 'dlein@auburnwa.gov' <dlein@auburnwa.gov>; 'assessor.info@kingcounty.gov'
<assessor.info@kinecounty.gov>; 'serviceaddresscorrec@pse.com' <serviceaddresscorrec@pse.com>;
'mike.buIzomi@soundtransit.org' <mike.bulzomi@soundtransit.org>;'char.naylor@puyalluptribe-nsn.gov'
<char.naylor@puyalluptribe-nsn.gov>; Chris Cahan<Chris.Cahan@southkingfire.org>; Rebecca Martin
<rmartin@federalwaychamber.com>; Brian Asbury <basbury@lakehaven.org>; 'jthomas@fwps.org'
<ithomas@fwps.org>; Jennifer Wojciechowski <iwoiciec@fwps.org>;'stimm@cityofmilton.net'
<stimm@cityofmilton.net>; 'bport@cityofmilton.net' <bport@cityofmilton.net>; 'karen.walter@muckleshoot.nsn.us'
<karen.walter@muckleshoot.nsn.us>;'laura.murphy@muckleshoot.nsn.us' <laura.murphy@muckleshoot.nsn.us>;
'dlewarch@suquamish.nsn.us' <dlewarch@suquamish.nsn.us>;'matthew.perkins@kingcounty.gov'
<matthew.perkins@kingcounty.gov>;'Ishimaru, Jim' <Jim.lshimaru@kingcounty.gov>
Cc: Stacey Welsh <Stacey.Welsh@cityoffederalway.com>
Subject: Mitigated Determination of Nonsignificance (MDNS)
Hello,
Attached you will find an MDNS and enclosures regarding the Woodbridge Building "B" project. Please contact
Principal Planner Stacey Welsh at 253-835-2634 or stacey.welsh@cityoffederalway.com, if you have any
comments and/or questions regarding this MDNS.
Regards,
E. Tina Piety, CAP, OM
Administrative Assistant II
.� Federal Way
Community Development Department
33325 81" Avenue South
Federal Way, WA 98003-6325
Phone: 253/835-2601 Fax: 253/835-2609
www.citvoffederalway.com
Stacey Welsh
From: Jason Ludwig <jludwig777@gmail.com>
Sent: Friday, October 23, 2020 4:16 PM
To: Ping Inquiry
Cc: Jerry Knutzen; Suzanne Vargo; Historical Society Of Federal Way; Diana Noble-Gulliford
Subject: Historical Society of Federal Way comments re: File No: 17-104237-SE
Attachments: 20.10.23 HSFW to City re Weyco vjl.docx; 20.10.23 HSFW to City re Weyco vjl.pdf
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Greetings Ms. Welsh:
Thank you for your work. Below and attached, please find a letter from the Historical Society of Federal Way regarding
the above planning matter. If you have any questions, please don't hesitate to reach out.
Warmly yours,
Jason Ludwig
Vice President, Historical Society of Federal Way
e: jludwig777@mail.com
c: 480-567-2785
October 23, 2020
Planning Department
Attn: Stacey Welsh
File No. 17-104237-SE
Greetings:
The Historical Society of Federal Way is grateful for the opportunity to comment on the above matter. Regarding the
application for warehouse B, we would like to express our staunch opposition to the proposal and remind all
stakeholders of the significant historical, cultural, and aesthetic importance of the now -threatened grounds.
The architecture and landscape present at the Weyerhaeuser Campus are considered groundbreaking and crucial to the
development of modern architectural design. The property has received numerous awards for vision and execution in its
49 years, and its relevance is not localized to Federal Way, to Washington, or even to the United States — the property is
renowned internationally and is still studied by burgeoning architects today.
Recently, the Cultural Landscape Foundation (TCLCF) enrolled the Weyerhaeuser Campus in LANDSLIDE, a program used
to rally support at local, state, and national levels for preserving threatened and at -risk landscapes nationwide. The
Campus received "Most Endangered Place" nominee status in 2017 from the Washington Trust for Historic Places. And
this year, a Washington State Architectural Historian placed the property on the National Register of Historic Places as a
Determination of Eligibility.
Heritage and preservation organizations around the world are watching Federal Way to see how we act as caretakers of
a site steeped in historical, cultural, and aesthetic significance.
The Society strongly encourages the City of Federal Way to work in concert with IRG to designate the property and the
structures thereon as an Historical District. Preservation groups, from ours to those operating with national scope,
would celebrate the City's dedication to preserving unique, significant pieces of history for future generations.
Additionally, the City would draw support from the Puyallup Tribes from whom the property, and the creek that runs
through it, are so important.
We appreciate your attention, and we hope you will make the right choice for local families, for international
recognition, and for future generations. Thank you.
Sincerely,
The Historical Society of Federal Way
October 23, 2020
Planning Department
Attn: Stacey Welsh
File No. 17-104237-SE
Greetings:
The Historical Society of Federal Way is grateful for the opportunity to comment on the above matter.
Regarding the application for warehouse B, we would like to express our staunch opposition to the
proposal and remind all stakeholders of the significant historical, cultural, and aesthetic importance of
the now -threatened grounds.
The architecture and landscape present at the Weyerhaeuser Campus are considered groundbreaking
and crucial to the development of modern architectural design. The property has received numerous
awards for vision and execution in its 49 years, and its relevance is not localized to Federal Way, to
Washington, or even to the United States — the property is renowned internationally and is still studied
by burgeoning architects today.
Recently, the Cultural Landscape Foundation (TCLCF) enrolled the Weyerhaeuser Campus in LANDSLIDE,
a program used to rally support at local, state, and national levels for preserving threatened and at -risk
landscapes nationwide. The Campus received "Most Endangered Place" nominee status in 2017 from
the Washington Trust for Historic Places. And this year, a Washington State Architectural Historian
placed the property on the National Register of Historic Places as a Determination of Eligibility.
Heritage and preservation organizations around the world are watching Federal Way to see how we act
as caretakers of a site steeped in historical, cultural, and aesthetic significance.
The Society strongly encourages the City of Federal Way to work in concert with IRG to designate the
property and the structures thereon as an Historical District. Preservation groups, from ours to those
operating with national scope, would celebrate the City's dedication to preserving unique, significant
pieces of history for future generations. Additionally, the City would draw support from the Puyallup
Tribes from whom the property, and the creek that runs through it, are so important.
We appreciate your attention, and we hope you will make the right choice for local families, for
international recognition, and for future generations. Thank you.
Sincerely,
The Historical Society of Federal Way
October 23, 2020
Planning Department
Attn: Stacey Welsh
File No. 17-104237-SE
Greetings:
The Historical Society of Federal Way is grateful for the opportunity to comment on the above matter.
Regarding the application for warehouse B, we would like to express our staunch opposition to the
proposal and remind all stakeholders of the significant historical, cultural, and aesthetic importance of
the now -threatened grounds.
The architecture and landscape present at the Weyerhaeuser Campus are considered groundbreaking
and crucial to the development of modern architectural design. The property has received numerous
awards for vision and execution in its 49 years, and its relevance is not localized to Federal Way, to
Washington, or even to the United States — the property is renowned internationally and is still studied
by burgeoning architects today.
Recently, the Cultural Landscape Foundation (TCLCF) enrolled the Weyerhaeuser Campus in LANDSLIDE,
a program used to rally support at local, state, and national levels for preserving threatened and at -risk
landscapes nationwide. The Campus received "Most Endangered Place" nominee status in 2017 from
the Washington Trust for Historic Places. And this year, a Washington State Architectural Historian
placed the property on the National Register of Historic Places as a Determination of Eligibility.
Heritage and preservation organizations around the world are watching Federal Way to see how we act
as caretakers of a site steeped in historical, cultural, and aesthetic significance.
The Society strongly encourages the City of Federal Way to work in concert with IRG to designate the
property and the structures thereon as an Historical District. Preservation groups, from ours to those
operating with national scope, would celebrate the City's dedication to preserving unique, significant
pieces of history for future generations. Additionally, the City would draw support from the Puyallup
Tribes from whom the property, and the creek that runs through it, are so important.
We appreciate your attention, and we hope you will make the right choice for local families, for
international recognition, and for future generations. Thank you.
Sincerely,
The Historical Society of Federal Way
Stacey Welsh
From: Marina Rojas <mnbrojas28@gmail.com>
Sent: Friday, October 23, 2020 2:24 PM
To: Ping Inquiry
Subject: Life, death, and opportunity at Weyerhaeuser Campus
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File No: 17-104237
Good Afternoon Stacey Welsh,
My name is Marina Rojas, and I have spent most of my life in Federal Way, Washington. I am writing to you as a
concerned citizen, pleading with my local officials to take a stand and do what is environmentally sound and historically
considerate in the case of the Warehouses currently being pushed through SEPA review at the City of Federal Way.
These proposed Warehouses would have a dire negative impact on our environment and would also detract greatly
from the beautiful PNW scenery our city has to offer, ultimately causing a loss of value that I would not doubt to have
long lasting unfortunate economic impacts as well.
The Weyerhaeuser Campus forest and meadow trails are a sanctuary to many, offering solace from the concrete
landscape of downtown Federal Way and helping to complete the dynamic environment unique to our beautiful city. I
myself have had the great honor of escaping to the trails since I was a child, making irreplaceable memories with family,
friends, and pets for the better part of the last 2 decades. In conversations with many different people in our
community, I know these meadows and trails are as important to our humans as they are to the birds and other wildlife
that make these woods their cherished homes.
In a sociopolitical climate where environmental activism has cemented a global platform, I ask you to consider how a
choice to move forward with this destruction would reflect on our city's elected and appointed leadership. It is
imperative for any modern community development to include careful consideration for how the land will be impacted.
Such established organizations as the Cultural Landscape Foundation, the United States Army Corps of Engineers, and
the Washington Department of Archaeology and Historic Preservation have contributed opinions in support of
protecting our precious resources, recognized nationally and internationally as exemplary modern corporate campus
design.
All of these factors and more further confirm the urgency for the city of Federal Way to approve only those changes
made to the campus which are compatible with the existing design. The measly tree -buffer proposed by the owner is
laughably insufficient, a performative gesture made to placate rather than actually protect the life he aspires to destroy.
An Environmental Impact Statement is not only warranted, but imperative, and the City should absolutely require it.
With the historical significance of the campus, this decision is an opportunity for Federal Way to establish itself as a
beacon of inspirational forward thinking, in turn attracting plentiful revenue from the tourists who come to our city to
marvel at the abundance of green life we have fought to preserve. Our community is ready and willing to mobilize and
amplify our voices to push to make sure these conditions are met.
Sincere regards,
Marina Rojas
Stacey Welsh
From: Jennifer Mortensen <jmortensen@preservewa.org>
Sent: Wednesday, October 21, 2020 6:30 PM
To: Ping Inquiry
Cc: Borth, Holly (DAHP); Michael Houser; lasechrist@comcast.net; Jean Parietti; Jennifer
Meisner; Todd Scott; Eugenia Woo (eugewoo@earthlink.net); Tyler Sprague
Subject: MDNS - Woodbridge Building "B" - File No: 17-104237-SE
Attachments: WA Trust - Weyerhaeuser - Building B MDNS.pdf
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Ms. Welsh,
Attached please find comments from the Washington Trust regarding the MDNS released for Woodbridge
Building "B" (File No: 17-104237-SE) at the former Weyerhaeuser Campus property.
Sincerely,
Jennifer (Jay) Mortensen I Outreach Director
she / her / hers
Washington Trust for Historic Preservation
1204 Minor Avenue I Seattle, WA 98101
206-462-2999 (d) I o: 206-624-9449 (o)
preservewa.org
WASHINGTON TRUST
W FOR HISTORIC
T PRESERVATION
October 21, 2020
Stacey Welsh, Senior Planner
plan ningocityoffederalway.com
City of Federal Way
33325 8th Avenue South
Federal Way, WA 98003
Re: MDNS -Woodbridge Building "B" (formerly Greenline warehouse "B")
Dear Ms. Welsh:
[sent via electronic mail]
The Washington Trust for Historic Preservation is writing in reference to the Mitigated
Determination of Nonsignificnce (File No: 17-104237-SE) recently released by the City of
Federal way in regards to the proposed Woodbridge Building "B"on the property now known as
Woodbridge Corporate Park, formerly the Weyerhaeuser Corporate Campus. The Washington
Trust strongly disagrees with the City's determination and continues to be concerned that the
City is not adequately recognizing and addressing the historically significant architectural and
landscape design of this campus.
As stated in the SEPA checklist, the campus has been deemed eligible for listing in the National
Register of Historic Places by the Washington State Department of Archaeology & Historic
Preservation (DAHP). The design of the former Weyerhaeuser Campus is groundbreaking in the
way it seamlessly blends the elements of architecture and landscape and in how Weyerhaeuser
carefully cultivated the 430-acre campus to showcase their company, convey a "green" corporate
image, and provide a healthy, modern lifestyle for their employees. The campus was conceived
and designed as a whole and its historic significance should be evaluated accordingly.
Regarding historic preservation, the Washington Trust disagrees with the opinions in the
memorandum provided by Cardno, the applicant's consultant, that the only eligible feature of the
historic district at the project site is the 50-foot tree buffer. Because of the holistic design of the
campus and the integration of the built and natural environments at the site, the entire wooded
parcel is a contributing feature to the eligible historic district.
As Roger Montgomery, professor of architecture at Washington University in St. Louis and later
the University of California, Berkeley, wrote in the 1972 issue of Architectural Forum about the site,
the "architecture and landscape design meld into one." He further described the headquarters
building as "an elegantly made part of the landscape itself" and situated such that it appears as
if in a "forest clearing." Weyerhaeuser's architect, Edward Charles Bassett of Skidmore, Owings &
Merrill, described the architecture and landscape as "mutually dependent" on each other and
the Weyerhaeuser Campus landscape designer, Peter Walker of Sasaki, Walker and Associates,
described his work on the project as "more forest management" than landscape design. The forest
portions of the campus are not incidental to the design of the headquarters —they are integral to
it and therefore contributing elements.
STIMSON-GREEN MANSION, 1204 MINOR AVENUE, SEATTLE, WASHINGTON 98101
T 206-624-9449 F 206-624-2410 1 preservewa.org
City of Federal Way
October 21, 2020
Page Z
In order to mitigate adverse effects to the contributing features at the project site, the Washington
Trust recommends that the City require that the applicant reduce the size of the Building "B" so
that more of the National Register eligible forested land can be retained. A 50-foot tree buffer
is insufficient for preserving the character of the historic landscape. The Washington Trust
recommends a 300- to 400-foot stand of trees be kept directly to the east of Weyerhaeuser Road at
the project site to mirror the depth of the tree stands inside (to the west of) Weyerhaeuser Road.
Ultimately, due to the exceptional historic significance of this campus and the many proposed
projects currently being processed by the City for this property, the Washington Trust reiterates
its position that the City should require the applicant to complete an Environmental Impact
Statement (EIS). An EIS would allow for more public comment and require that the property
owner consider more design alternatives that have less harmful environmental impacts.
We urge the City of Federal Way to require a more thoughtful approach to new construction on
this campus and require mitigation measures that address the real and significant impact that
Building "B" and other projects will have. Thank you for considering our request to respect the
future of the entire property and its lasting national importance to the fields of architecture and
landscape design.
Sincerely,
Jennifer Mortensen
Outreach Director
CC: Holly Borth & Michael Houser, Department of Archaeology and Historic Preservation
Lori Sechrist & Jean Parietti, Save Weyerhaeuser Campus
Jennifer Meisner & Todd Scott, King County Historic Preservation Program
Eugenia Woo & Tyler Sprague, Docomomo WEWA
Stacey Welsh
From: Drew Crooks <dwchistory@comcast.net>
Sent: Wednesday, October 21, 2020 12:02 PM
To: Ping Inquiry
Subject: Old Weyerhaeuser Campus
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Ms. Stacey Welsh,
As an historian long interested in this region's cultural heritage, I am writing in opposition to the
building of an incompatible warehouse on the Old Weyerhaeuser Campus, File No: 17-104237-SE.
The Campus, including both building and landscape, are a cultural icon and should be preserved as
much as possible. Years ago I remember visiting the Weyerhaeuser headquarters and noted the
remarkable architectural and landscape design. Don't destroy this unique historical/cultural/natural
resource!
Sincerely,
Drew Crooks
Historian
Olympia, Washington
Stacey Welsh
From: doreen@harperstudios.com
Sent: Wednesday, October 21, 2020 7:07 AM
To: Ping Inquiry
Cc: doreen@harperstudios.com
Subject: Protect Weyerhaeuser Campus historic forest
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Dear Planning Department of Federal Way,
The Weyerhaeuser Campus is a world-renknowned architectural example of great environmental design. It's imperative
that you require all necessary studies and protect it's integrity by retaining as much of the established forest as possible.
This campus as a whole has outstanding historic significance and therefore any changes must be compatible to its
existing design. This campus is significant not just for Washington and the Northwest —it is known nationally and
internationally as one of the finest examples of modern corporate campus design.
- The tree buffer proposed by the owner is insufficient because the entire forested parcel contributes to the significance
of the campus design. The City should require the owner to substantially reduce the size of the proposed warehouse to
preserve more of the forested land and the historic design of the campus.
- Ultimately, the historic significance of the campus warrants additional review through an Environmental Impact
Statement (EIS), which the City should require. An EIS would allow for more public comment and require that the
property owner consider alternatives that have less harmful environmental impacts.
Do the right thing.
Sincerely,
Doreen Harper
Des Moines, Wa resident
Stacey Welsh
From: cindy flanagan <camcalcin@hotmail.com>
Sent: Friday, October 23, 2020 4:41 PM
To: Stacey Welsh; Ping Inquiry
Cc: Brian Davis; Jay Galvin; Dan Streiffert; Barbara Petersen; Stephan Feldman; Heather
Gibson; Laura Lavington
Subject: Rainier Audubon Comment for IRG Warehouse B application FILE: 17-104237
Attachments: RAS Warehouse B MDNS COMMENT.docx
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Hello Stacey,
I have attached comments from Rainier Audubon for IRG's Warehouse B land use application File: 17-104237-SE
Please let me know if you have any problems opening the attachment.
Sincerely,
Cindy Flanagan
Rainier Audubon Board Member
Sent from Mail for Windows 10
October 22nd, 2020
Ms. Stacey Welsh
Senior Planner
City of Federal Way
P.O. Box 599
Federal Way, WA 98010
Re: Greenline Warehouse "B" File No: 17-104237-SE
Dear Ms. Welsh:
The Rainier Audubon Society is a nonprofit chapter of the Audubon Society. Our chapter boundaries
include Federal Way. The former Weyerhaeuser Headquarter Campus is identified by our chapter as an
important birding area and for forty years we have led field trips and done bird surveys to collect data
that has local and national significance: National Audubon's Christmas Bird Count which has used its
data to better understand important science including Climate Change; and Breeding Bird Atlas surveys
that are used to understand bird breeding patterns. When George Weyerhaeuser made the decision to
build the Weyerhaeuser Campus Headquarters in Federal Way, his plan was to create a campus that
reflected his business practice of including public recreating on his forested lands. Like the millions of
acres of private land Weyerhaeuser owned, he wanted to create a place for the public to recreate —a
key piece to the design concept of the campus, and we, along with millions, have been able to access
these trails for fifty years.
For the past four years, we have worked in coalition with Washington nonprofit organization Save
Weyerhaeuser Campus (SWC) who's mission is to protect and preserve the community and natural
values of the former Weyerhaeuser Campus. This comment letter incorporates comments provided by
us in Warehouse A and Greenline Business Park. We also incorporate comments provided by SWC in the
Warehouse A and Greenline Business Park proposals.
We have reviewed the Notice of Mitigated Determination of Nonsignificance (MDNS) prepared by the
City of Federal Way for Warehouse B and we ask the city to reconsider its decision and require further
review on the following topic.
Under SEPA, a single significant impact is enough to warrant an EIS. The historical significance of the
campus is being overlooked. As you know, the United States Army Corps of (USACE) is reviewing IRG's
Greenline Warehouse A and Warehouse B under one JARPA permit NWS-2017-1077. In its review, the
USACE determined that the proposed Warehouse A and B projects will cause adverse impacts to the
historical significance of the campus.1The USACE has determined the campus, not just the headquarters,
is eligible for listing on the National Register of Historical PlacesZ and thereby, has begun a Section 106
review to assess the historic district. Also in agreement with the USACE is the state's DAHP. Part of the
USACE and DAHP decision was based on the extensive historical reports that Industrial Realty Group's
consultant Cardno provided in May 2020. At a USACE coordinated meeting on October 2, 2020, that was
1 Lance Lundquist, Lance Lundquist, Cultural Resources Program Manager, Regulatory Branch, US Army Corps of
Engineers, Seattle District, October 20, 2020 Formal Letter
z Lance Lundquist USACE Cultural Resource Program Manager, email communication "Weyerhaeuser Campus
Eligibility NRHP designation"
attended by IRG, DAHP, Save Weyerhaeuser Campus, King County Historical Preservation, Washington
Trust for Historic Preservation, The Cultural Landscape Foundation, Docomomo WEWA, and others,
there was unified agreement that the Warehouse A and Warehouse B proposals would cause adverse
effects to the historical integrity of the campus, which it was agreed is clearly eligible for NRHP listing. In
fact, The Cultural Landscape Foundation's Charles Birnbaum spoke at the meeting and suggested the
campus is clearly eligible as a National Historic Landmark and he referenced an earlier letter he wrote to
the Washington Trust for Historic Preservation (see Appendix C)
It the City's technical letter review of Warehouse B, the City asks IRG for a status of the historical
reports.
17. Historic Preservation — The August 25, 2017, comment response letter for Greenline Warehouse "A"
indicated that a full survey of the Weyerhaeuser Campus was underway and would be provided to the
City upon completion. What is the status of the report?
IRG has not provided any of the Cardno historical reports it provided to the USACE in May 2020.
IRG only gives the city a one -page response stating there are no historical adverse effects (see
Appendix B). Why has IRG not provided the sufficient documentation to the city?
On October 15, 2020, IRG revised its Cardno report to reflect the decision of USACE. IRG revised
its report to cede that there are adverse effects.
The next steps at the USACE are to determine the historic boundary and contributing elements.
With this new information, including the applicant IRG's own admission of historical adverse effects for
BOTH Warehouse A and B, the City's MDNS for Warehouse B should be rescinded, a determination of
significance issued, and scoping for an environmental impact statement (EIS). Like the USACE, the city
should be gathering expert information to better understand the historic district and the adverse effects
and use this information to inform whether or not the warehouses should be built and what should be
mitigated.
Respectfully submitted,
Cindy Flanagan
Rainer Audubon Board Member
253-315-0799
camcalcin@hotmail.com
Rainier Audubon Board
President Jay Galvin gjgalvin@comcast.net
Board Laura Lavington laura.lavington@Bmail.com
Board Heather Gibson hedder_swedder@yahoo.com
Board Cindy Flanagan camcalcin@hotmail.com
Board Barbara Petersen bpbatfan@aol.com
Conservation Chair Dan Streiffert 253-796-2203 dan_streiffert@hotmail.com
Board Stephen Feldman 360-802-5211 stephanfeldman@gmail.com
APPENDIX A
EMAIL FROM LANCE LUNQUIST REGARDING FORMER WEYERHAEUSER CAMPUS NRHP ELIGIBILITY
From: Lundquist, Lance A CIV USARMY CENWS (USA) <Lance.A.Lundquist@usace.army.mil>
Sent: Wednesday, September 2, 2020 1:32 PM
To: cindy flanagan <camcalcin@hotmail.com>
Cc: McDermott, Kristin L CIV USARMY CENWS (USA) <Kristin.L.Mcdermott@usace.army.mil>; LORI A
SECHRIST <lasechrist@comcast.net>
Subject: RE: Weyerhaeuser Campus JARPA permits: request for Section 106 update
Hi Cindy,
Thank you for the update. We're still waiting for all the information to come in before initiating Section
106 consultation. We are still in the information gathering stage. If you have any information you would
like the Corps to take into consideration, please share.
The property (including the landscape) is clearly NRHP-eligible. I do not believe the owner would want to
have it nominated as a National Historic Landmark (I believe that is what you were intending below?).
We are waiting right now for an assessment of effects. Otherwise I think we will have everything
necessary to initiate consultation.
I am not aware of any other JARPA permits, separate or related to the Warehouse A & B or Greenline
Business Park permit. Kristin, are you aware of any?
Thanks,
Lance
Lance Lundquist
Cultural Resources Program Manager
Regulatory Branch
US Army Corps of Engineers, Seattle District P.O. Box 3755 Seattle WA 98124
(206) 764-6909
lance.a.lundquist@usace.army.mil
Regulatory Branch
Ms. Jean Parietti
Save Weyerhaeuser Campus
PO Box 702440245
Federal Way, WA 98063
Dear Ms. Patietti:
DEPARTMENT OF THE ARMY
CORPS OF ENGINEERS, SEATTLE DSSTWCT
P.O. BOX 3755
SEATTLE, WASHINGTON 98124-3755
October 20, 2020
Reference: NWS-2017-1077
Woodbridge Corporate
Park Brulding A & B
Adverse Effect
The U.S. Arury Corps of Engineers (Corps) Regulatory Branch has received a permit
application from Federal Way Campus, LLC associated with a commercial development project
located in Federal Way oil private land at the former Weyerhaeuser campus, at Sec 21, T21N,
R04E, Poverty Bay USGS 7.5' quadrangle, King Comity, Washington. The applicant proposes
to discharge tip to 800 cubic yards of permanent fill in 9,922 square feet (SF) of nine Category
III and IV wetlands, 17.046 SF of wetland buffer reduction, and 2951 SF of stream buffer
reduction to construct up to 439,050 SF of new building space with associated iirfrastnucture,
parking and stormwater facilities. The applicant proposes to purchase 13.53 acre points from the
King County Mitigation Reserves Program as compensatory mitigation for wetland loss.
Wetland buffers and stream buffers would be averaged by 20,720 SF of on -site wetland buffer
replacement and 3,025 SF of on -site strewn buffer replacement. The Corps is evaluating the
undertaking in compliance with Section 106 of the National Historic Preservation Act. The
Corps' permit area is defined by all areas of proposed iir-water activity, including upland areas
where work is directly associated_ integrally related- and would not occur but for the in -water
authorized activity. In evaluating the effects of the Corps' permitting actions to historic
properties, the Corps takes into consideration historic properties both within and beyond the
pewit area.
Cardno prepared three reports on the results of their cultural resources assessment of the
project area. The first report, Archaeological Resources Sia-i•et,for the Woodbridge Corporate
ParkBarildingA and Building B Projects, Federcl Way, Washirigtofr, dated March 30, 2020, is an
archaeological survey of the 32.2-acre Carps' pennit area. The second report, Built Enviromnent
Stn-i?ev of the Fanner Weyerhaeuser Corporate Headgtiarters Carrrprrs, Federal WaY,
Washington, dated July 29, 2020, is a built environment assessment of the approximately 490-
acte Weyerhaeuser campus, and includes areas outside the Corps' permit area. The final report,
-2-
Evaluation of Effects far die Proposed Woodbridge BrrildingA and Woodbridge BuildingB
Projects, Federal Wa'v, Washington, dated October 15. 2020, is a permit -specific assessment of
project effects to historic properties. lnfornation on the project is available online on the
Washington Information System for Architectural and Archaeological Records Data
(Department of Archaeology & Historic Preservation [DAHP] Project No. 2018-07-05928).
Please let us know if you need copies for your review.
Cardno found no sub -surface artifacts within the Corps' permit area. Cardno identified and
recorded three interconnected graded and partially maintained gravel roads segments within the
permit area as Site 45KI01481. The road segments are associated with a ca. 1935-1950s
residential development that was demolished between 1954 and the early 1960s, prior to the
Weyerhaeuser campus. Although the road segments are currently maintained and are used for
access. Cardno found no evidence connecting the roads to the desigxu of the Weyerhaeuser
campus. The roads appear to be simple relics of the previous housing development.
opportunistically used today. Cardno recommends 45KI01481 is not eligible for listing in the
NRHP, and the Corps agrees.
DAHP determined the main Weyerhaeuser headquarters building to be eligible for listing in
the National Register of Historic Places on October 31, 2017. but their determination did not
include the surrounding campus landscape. Cardno recommends "that the historic designed
landscape is eligible for the NRHP as a historic district at a national level of significance...
Because of the proposed historic district's exceptional historical and design significance, it is
recommended eligible at a national level of significance under Criteria Consideration G for
resources that have achieved significance within the past 50 years. Its recommended period of
significance is 1969 — 1979."
Cardno "recommends that the Woodbridge Building A and Woodbridge Building B
projects, along with thew associated detention pond, will have an adverse effect on the
Weyerhaeuser Corporate Headquarters Historic District by diminishing the integrity of the
recommended contributing 50-foot buffer east of Weyerhaeuser Road. a private road that forms
part of the recommended contributing circulation road network. The buffer's diminished
integrity in turn diminishes the integrity of the driving views that reflect the image Weyerhaeuser
Company wanted to project of itself as a forest -management company when it worked with the
original designers on the corporate campuus.-
Cardo further recotrmmends that because "the area where the projects are proposed was
earmarked for fruther expansion of the campus by the original design tearer, the recommendation
of adverse effect does not apply to the recommended non-contributing stands of trees east of the
buffer because it will not diminish the integrity of a recommended contributing element to the
campus per 36 CFR § 800.5(a)(1)." However, consulting parties, including the Washington Trust
for Historic Preservation (WTHP) and The Cultural Landscape Foundation (TCLF) recommend
-3-
the wooded area is also an important contributing elements to the district. This stand of trees is
located in the permit area and would be unavoidably destroyed by the proposed construction_
The Corps finds the Weyerhaeuser Corporate Headquarters Historic District to be an
exceptional district unambiguously eligible for listing in the National Register of Historic Places.
TCLF believes "that the corporate campus would also qualify for the more esteemed designation
of National Historic Landmark (NHL)_ of which there are currently fewer than 2,604, with
approximately 80 of those properties designated for significance in the area of landscape
architecture." The Corps permit area does not include the entire campus and as such the Corps'
determination of identification (for components that comprise the district) and effect are limited
to the Corps' permit area_ Within the Carps' permit area, the Corps agrees that the project will
have an adverse effect to the buffer and Oewshed per Cardno's recommendation, and by
destruction of the wooded area —a contributing element per the WTHP's and TCLF's
recommendations.
Based on the results presented above, the Corps has determined there would be an adverse
effect to the Weyerhaeuser Corporate Headquarters Historic District by this undertaking and
invites your comments. We will be reaching out to schedule meetings to consult on a resolution
of adverse effects. If you have any questions or need additional information, please email me at
cultu al.resourcesCausace.army.mil or call me at (206) 764-6909.
Sincerely,
Lance Lundquist
Cultural Resources Program Manager
Regulatory Branch
APPENDIX B
10:11 tf 1�m9121A
Jul 30 2020
Vr of FEME wnv
LOMMUN1i WVELUMENi
Memorandum
Date: July 27, 2020
To: Dana A. Osterl
Executive Vice President
Industrial Realty Group, LLC
11111 Santa Monica Boulevard
Suite 800
Los Angeles, CA 90025
From: Michelle Sadlier
Architectural Historian
Built Environment Survey of the Former Weyerhaeuser Corporate
RE: Headquarters Campus for Compliance with Section 106 of the NHPA —
Comments on SEPA Compllance for Woodbridge Building B
Caf-cinoy
Cardno,Inc.
801 Second Ave
Suite 1150
Seattle, WA98104
USA
Cal has completed a Built Environment Survey of the Former Weyerhaeuser Corporate
Headquarters Campus, Federal Way, Washington, July 2020 (Survey). This Survey was
prepared under Section 106 of the National Historic Preservation Act [NHPA] for submission to
the U.S. Army Corps of Engineers in connection with its permitting activity under Section 404 of
the Clean Water Act. The Survey identifies a historic district (District) on the former
Weyerhaeuser Corporate Headquarters property that is recommended eligible for listing in the
National Register of Historic Places (NRHP) under the standards of 36 CFR Section 60.4. The
Survey also identifies features that are recommended as contributing to the historical
significance of the District and those that are recommended as noncontributing. The survey is
provided solely for compliance with Section 106 of the NHPA and does not result in the listing of
the recommended NRHP-eligible District in the Ni
The Survey was not prepared for purposes of compliance with the State Environmental Policy
Act (SEPA) and does not evaluate the significance of impacts under SEPA. The purpose of this
memorandum is to provide our opinion regarding the significance of impacts to historic resources
under SEPA resulting from the proposal known as Woodbridge Building B. Note that the
definitions of terms in Section 106 of the NHPA and SEPA regulations are different. The SEPA
regulations include "historic and cultural preservation" as an element of the environment. The
definition of an "environmental impact" is an effect on the elements of the
environment. "Significant" means more than a reasonable likelihood of more than a moderate
adverse impact on environmental quality.
We have analyzed the Woodbridge Building B proposal with regard to historic resources under
SEPA. On the Building B property, the only feature identified in the Survey as contributing to the
recommended NRHP-eligible District is the 50-foot tree buffer adjacent to Weyerhaeuser Road
as it relates to the experience of a driver on Weyerhaeuser Road. The Building B site plan
shows that the project preserves a 50-foot or greater tree buffer adjacent to Weyerhaeuser
Road. Based on these factors, we conclude that the Building B proposal will not result in
significant adverse impacts to the recommended NRHP-eligible District as defined under SEPA.
Australia • Belgium • Canada • Colombia • Ecuador Germany • Indonesia -
Kenya • New Zealand • Nigeria • Papua New Guinea Peru • Philippines - Singapore
United Arab Emirates - United Kingdom • United Slates Cperations in over 100 counldes
Phone 2062690104
Fax 2062690098
www.cardno.com
APPENDIX C
June 3, 2019
Mr. Chris Moore, Executive Director
Washington Trust for Historic Preservation
1204 Minor Avenue
Seattle, WA 98101
Dear Mr. Moore,
I write on behalf of The Cultural Landscape Foundation (TCLF) to provide an assessment of the
significance of the Weyerhaeuser International Headquarters in Federal Way, Washington, as an
historic, designed landscape. As you know, TCLF is a national nen-profit organization whose mission
is to document and make visible cultural landscapes throughout the United States, and to advocate
for their informed stewardship. As such, TCLF maintalns the natlon's most comprehensive database
of cultural landscapes and their designers, and we publish guidebooks and scholarly volumes in the
field of landscape studies.' As a recognized authority on the Secretary of the Interior's Standards for
the Treatment of Historic Properties, with Guidelines for the Treatment of Cultural Landscapes,'
TCLF frequently submits testimony to municipal governments on the stewardship of cultural
landscapes, and we routinely serve as a consulting party to federal -level reviews under the National
Historic Preservation Act and the National Environmental Policy Act.
As the following will attest, TCLF wholeheartedly concurs with recent findings by the State of
Washington's Department of Archaeology and Historic Preservation that the Weyerhaeuser
headquarters would "easily qualify" for listing in the National Register of Historic Places. Moreover,
we believe that the corporate campus would also qualify for the more esteemed designation of
National Historic Landmark (NHL), of which there are currently fewer than 2,600, with
approximately 80 of those properties designated for significance in the area of landscape
architecture.
Located some 23 miles south of Seattle, the Weyerhaeuser headquarters was the product of a
ccllaboration among landscape architect Peter Walker, a partner of Sasaki, Walker and Associates,
architect Edward Charles Bassett, principal -in -charge at the San Francisco office of Skidmore,
Owings & Merrill (SOM), and George Weyerhaeuser, the president and CEO of the Weyerhaeuser
company and great-grandson of its founder. The building and the landscape were completed in
1971 and 1972, respectively. As a highly influential leader in the field of corporate landscape
design, SOM was a logical choice to develop plans for the Weyerhaeuser headquarters.3 As is well-
known, the firm's Gordon Bunshaft was first approached to undertake the design, working from his
t A partial list of publications produced under the auspices cf TCLF includes Shaping the Postwar landscape: New
Profiles from the Pioneers of American Landscape Design Project (2018); Mellon Square: Discoveringa Modern
Masterpiece (2014); Lawrence Halprin's Skyline Park (2012); Shaping the American Landscape. New Profiles from
the Pioneers ofAmerican Landscape Design Project (2009); Oesrgn with Culture: Claiming America's Landscape
Heritage (2005); Preserving Modem Landscape Architecture It: Making Postwar Landscapes Visible (2004);
Pioneers ofAmencan Landscape Design (2000); and Preserving Modem Landscape Architecture l: Proceedings
from the Wave Hill Conference (1999).
2 Formerly the coordinator of the National Park Service's Historic Landscape Initiative, TCLF's founder, president,
and CEO, Charles A. Birnbaum, FASLA, FAAR, was a co-author of the Secretary of the Interior's Standards for the
Treatment of Historic Properties, with Guidelines for the Treatment of Cultural Landscapes.
3 For an account of SOM's practice, see, e.g., from Lhe Monacelli Press (all published In 2009), Hitchcock, H,-R. SOK
Architecture of Skidmore, Owings & Merrill, 1950-19&2; Drexler, A. SOM: Architecture of Skidmore, Owings & Merrill,
19453-1973, Bush -Brown, A. SOM: Architecture of Skidmore, Owings & Merrill, 1973-1983; Mertins, 0, SOM: Architecture
of Skidmore, Owings & Merrill, 1984-1996; Frampton, K. SOM: Architecture of Skidmere, Owings & Merril, 1997-2008.
The Cultural Landscape Foundation
1711 Connedicut Avenue NW, Suite 200, Washington. CC 20009
TEL 1202 M 0553 FAX 1202 4113 0761 tclf.crg I connecting people to places
company's New York offices. But after Bunshaft's design proved too introspective and out -of -
keeping with Weyerhaeuser's Northwestern roots, the project was transferred to SOM's San
Francisco office and placed under Bassett's direction. With the addition of landscape architect Peter
Walker, based in San Francisco and raised in nearby Berkeley, the design team was well positioned
to create a corporate campus that responded to its region's particular landscape. Indeed, the result
was in many ways a reflection of George Weyerhaeuser himself, whom Walker described as "...a
forester. A simple, very direct Northwesterner.. -George wanted refinement and simplicity, but not
ostentation."
Two of the design team's early plans were put aside. One envisioned a series of clustered buildings
set amid woodlands; the other a tiered complex that descended one side of the site's central valley,
which had previously been home to scattered and subsequently derelict structures. What ultimately
emerged was a corporate campus that manifested a seamless relationship between the building
architecture and the landscape architecture. Appearing to be sculpted in place, the main
Weyerhaeuser building was set perpendicular to the valley floor, bridging the swale at its narrowest
point. The .long edifice recedes as it rises in five terraced stories that are fully draped in ribbons of ivy
that grow from planter boxes installed along the perimeter of each level. Further melding with its
environment, the building's foundation was designed to dam a small creek, creating a ten -acre lake
on the north side of the structure. The lake in turn nourishes a wet meadow of native grasses located
on the opposite side of the building at the south end of the campus. Visitors and employees arrive at
two parking lots set at the ends of the building, which are planted with formal rows of sycamores and
are terraced to correspond with at -grade entrances to the various levels of the structure.
The Weyerhaeuser complex thus brilliantly achieves the aims that Bassett described: "to find a point
where the landscaping and the bullding simply could not be separated, that they were each a
creature of the other and so dependent that they could hardly have survived alone." The "skyscraper
on its side" also allowed nearly 1,000 employees to work In an equally innovative indoor
environment. SOM's use of concrete in the design, although perhaps an odd choice for a timber
company, enabled expansive, uninterrupted interiors without permanent partitions, corridors, or
offices, the first major example in the United States of the open -office planning—burolandschaff
("office landscape") —that had taken root in Germany in the 195Os.
A roof garden was designed at the topmost level of the building by landscape architect Richard
Vignolo in 1974. Vignolo would go on to complete several projects for SOM and would also design
the landscape for Bassett's personal residence in Mill Valley, California, in 1991.' The John Shethar
Memorial Garden, by the SWA Group (as Sasaki, Walker and Associates was subsequently called)
was also added to the campus, providing a place for intimate gathering on a hillside overlooking the
lake. But the design of the Weyerhaeuser landscape extended far beyond the immediate building
complex to the 260-acre site. An evergreen forest —primarily of Douglas fir —covers more than half
the acreage, which is also interspersed with walking trails. Walker introduced drifts of alders at the
forest's edge to further enhance the visual connection between the open valley and the wooded
areas of campus. Wildflowers bloom throughout, providing seasonal variety in the evergreen -heavy
landscape.
Walker described the project as "forest management, rather than landscape design," and the
resultant interplay of voids and solids is indeed essential to the success of the overall campus, where
the work of nature and man blends seamlessly from the core of the landscape to its very edges_
Weyerhaeuser planted more than 2,500 trees at the site, restoring what had been "a cut -over forest
° A biographical profile of Vignolo, mentioning his work on the Weyerhaeuser roof garden, appears in Shaping the POSAVer
Landscape, a hardbound volume published by UVA Press in 2018, A profile of Peter Walker is also included in that
volume.
on the urban fringe, all cut up by abandoned shacks and houses." The visibility of the ensemble of
building architecture and landscape architecture from Interstate 5 was a prominent factor in the
design, so much so that a variance was obtained from the Department of Transportation to allow for
a more open highway barrier to afford better views of the complex.5
The Weyerhaeuser building won the National Honor Award from the American Institute of Architects
(AIA) in 1972, confirming that its merits as an excellent design were immediately recognized.
Moreover, the AIA bestowed its Twenty-five Year Award on the headquarters in 2001, as a building
that has "stood the test of time for 25-35 years and continues to set standards of excellence for its
architectural design and significance." The Weyerhaeuser campus has also been much studied, and
as an exemplar in the fields of architecture and landscape architecture, it has been repeatedly
published in magazines, journals, and scholarly volumes In every decade since its completion-6 Its
extensive treatment in the widely read survey by Johnson and Frankel' is especially noteworthy
because that volume gathers the premier works of Modernist landscape architecture, including the
PepsiCo World Headquarters in Purchase, New York, and the Deere and Company Headquarters in
Moline, Illinois (the latter with a landscape by Sasaki, Walker and Associates). Also featured are the
Miller House and Garden in Columbus, Indiana, and Gas Works Park In Seattle, Washington. The
former, with a landscape by Dan Kiley, was named an NHL in 2000, and the latter, designed by
Rich Haag, was listed in the National Register of Historic Places in 2013. Notably, the volume also
treats the Tanner Fountain at Harvard University in Cambridge, Massachusetts, a landscape
designed by Peter Walker.
Adding to the unquestionable prestige of the work by SOM, the Weyerhaeuser landscape Is indeed
the design of a recognized master. Peter Walker left SWA Group in 1983 and successfully partnered
with Martha Schwartz and William Johnson, among others. As Principal of PWP Landscape
Architecture, Walker's portfolio includes gardens, public parks, plazas, corporate headquarters,
university campuses, museums, memorials, and other landscapes worldwide. His significant
projects include Sea Pines Plantation in Hilton Head, Sauth Carolina; Foothill College in Los Altos
Hills, California; the Upjohn Corporation World Headquarters in Kalamazoo, Michigan; the Nasher
Sculpture Center in Dallas, Texas, and the National September 11 Memorial in New York City.
Walker has also greatly shaped the profession through his academic work and publishing. In 1976
he became the acting director of the Urban Design Program at Harvard University. He then chaired
the program in landscape architecture there from 1978 to 1981. He also served as head of the
Department of Landscape Architecture at the University of California, Berkeley. He has authored
numerous books, established Spacemaker Press, and founded Landscape Forum journal. Named a
Fellow of the American Society of Landscape Architects (ASLA) in 1975, Walker's many awards
include Harvard's Centennial Medal, the University of Virginia's Thomas Jefferson Medal, the ASLA
Design Medal, and the International Federation of Landscape Architects' Sir Geoffrey Jellicoe Gold
5 Johnson, J. and F. Frankel (1991) Modern Landscape Architecture: Redefiningthe Garden (Abbeville Press Publishers),
p. 46.
6 A partial bibliography evincing interest in the Weyerhaeuser campus from various fields of study Is as follows:
Montgomery, R. (1972) "A Building That Makes Its Own Landscape," Architectural Forum 136, no. 2.; Canty, D. (1977)
"Evaluation of an Open Office Landscape: Weyerhaeuser Co.," AIA Journal66, no. 8; "Wide Open Spaces," lndustriai
Design 19, no. 2 (1989); `Weyerhaeuser Corporate Hepdquarters," Process Architecture 85 (1989); Johnson, J. and F.
Frankel (1991) Modern Landscape Architecture: Redefiningthe Garden (Abbeville Press Publishers); 5imo, M. and P
Walker (1996) Invisible Gardens: The Search for Modernism in the American Landscape (MIT Press); Adams, N. (2007)
Skidmore, Owings & Merrill: The ExperimerttSince 1936 (Phaidon Press); Mozingo, L. (2011) Pastoral Capitalism: A
History of Suburban Corporate Landscapes (MIT Press); Birnbaum, C. and S. Craver, eds. (2018) Shaping the Postwar
Landscape (LIVA Press).
'Johnson, J. and r. Frankel (1991) Modern Landscape Architecture: Redefining the Garden (Abbeville Press Publishers),
pp. 41-51,
Medal. Walker was the first landscape architect to be awarded the Urban Land Institute's J.0
Nichols Prize for Visionaries in Urban development.
Given the widespread appreciation and recognition that the Weyerhaeuser project has received, the
stature of SOM in the field of architecture, and the illustrious career of the project's landscape
architect, it is unsurprising that the State of Washington's Department of Archaeology and Historic
Preservation determined the Weyerhaeuser headquarters eligible far listing in the National Register
of Historic Places on October 31, 2017. And indeed, the statement from state architectural historian
Michael Houser that the Weyerhaeuser campus would "easily qualify" under Criteria A and C (as a
property associated with events that have made a significant contribution to the broad patterns of
history, and one exhibiting high artistic value, representing the work of a master) clearly indicates
that the determination was entirely uncontroversial.
What is more, we believe that the Weyerhaeuser headquarters would also qualify to be designated as
an NHL because its significance under the established criteria is national in scope. Nicholas Adams,
the Mary Conover Mellon Professor Emeritus in the History of Architecture at Vassar College, has
called Weyerhaeuser "one of the finest examples of corporate architecture integrated into the
landscape from the second half of the twentieth century," And in her recent monograph, Louise
Mozingo, a professor of landscape architecture and environmental planning at the University of
California, Berkeley, writes that Weyerhaeuser was the "first corporate estate on the West Coast, and
still the only one that rivals in scale and grandeur its East Coast and Midwest counterparts..."' The
commentary of these and other authorities in their fields, and the high integrity that the campus now
exhibits, indicate to us the property's worthiness for NHL status.
There is, moreover, established precedent for including properties of this typology in the National
Register of Historic Places and among the nation's far fewer NHLs. One notes that Bell Laboratories
in Holmdel, New Jersey, a collaboration between architect Eero Saarinen and Sasaki, Walker and
Associates, was added to the National Register in 2017, with significance noted in the area of
landscape architecture. And the General Motors Technical Center, a sprawling corporate campus
that opened in 1956 in the Detroit suburb of Warren, Michigan, was added to the Register in 2000.
Designed by Saarinen and celebrated landscape architect Thomas Church, the property was
elevated to an NHL in 2014. Like the General Motors Technical Center, the Weyerhaeuser campus is
also "of exceptional value or quality in illustrating or interpreting the heritage of the United States in
history [and] architecture..." and it possesses "a high degree of integrity of location, design, setting,
materials, workmanship, feeling and association." Indeed, Weyerhaeuser's high degree of design
integrity surpasses that of Bell Laboratories and other significant corporate landscapes that have
nonetheless been recognized as worthy of preservation.
Please let me know whether TCLF may be of any further assistance. We are anxious to see the
Weyerhaeuser campus achieve a status commensurate with the cultural and historical treasure that
it is.
Sincerely,
Charles A. Birnbaum, FASLA, FAAR
President + CEO
The Cultural Landscape Foundation
S Mozingo, L. (2011) Pastoral Capitalism: A History of Suburban Corporate landscapes(MIT Press), p. 140.
Stacey Welsh
From: Melinda <melindasito@hotmail.com>
Sent: Friday, October 9, 2020 2:17 PM
To: Ping Inquiry
Subject: Re: Notice of Mitigated Determination of Nonsignificance (MDNS)
[EXTERNAL EMAIL WARNING]
This email originated from outside of the City of Federal Way and may not be trustworthy. Please use caution when
clicking links, opening attachments, or replying to requests for information. If you have any doubts about the validity of
this email please contact IT Help Desk at x2555.
Destroying what could be a beautiful preserve. All you want are apartments. People need nature.melinda sito
Sent from my iPhone
On Oct 9, 2020, at 1:S2 PM, City of Federal Way wrote:
I El
Notice of Environmental Mitigated Determinates
of Nonsignificance (MDNS)
Woodbridge Building "B" (formerly Greenline Warehouse "B")
File No: 17-104237-SE
The City of Federal Way has determined that
the following project does not have a probable
significant adverse impact on the environment,
provided the mitigation measures identified in the MDNS are met, and an
Environmental Impact Statement (EIS) is not required under RCW
43.21 C.030(2)(c). This decision was made after review of a completed
environmental checklist and other information on file with the city. This information
is available to the public by request or on the city website:
https://www.cityoffederalway.com/node/l 962.
Proposed Action: Construction of a 45-foot-tall, 214,050 square -foot general
commodity warehouse with 245 parking spaces, and associated site work,
including wetland fill, on a 16.85-acre site (parcel 6142600200), along with
improvements to the right-of-way of Weyerhaeuser Way South.
Proponent: Federal Way Campus LLC, 11100 Santa Monica Blvd, Suite 850,
Los Angeles, CA 90025
Location: 3120 South 344th Street, Federal Way, WA
Lead Agency: City of Federal Way
Mitigation Measures (Summary):
1) Prior to building permit issuance, the applicant shall submit an evaluation of the
facility design by a qualified professional to ensure that the types and numbers of
equipment to be installed at the warehouse, as well as warehouse activities, are
consistent or similar to those identified in the noise report (Greenline Building `B"
Development, Federal Way Washington Environmental Noise Report, Ramboll
Environ, July 2018).
2)The following measures shall be implemented during project construction, with
quarterly reports submitted by the applicant to the city documenting compliance
starting from the issuance of the building permit and concluding at issuance of a
Certificate of Occupancy:
a)AII equipment shall be fitted with properly sized mufflers, and if necessary,
engine intake silencers.
b)AII 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 the existing
residential and noise -sensitive commercial areas, and if necessary, place
temporary barriers around stationary equipment.
e) For mobile equipment, consider placement of typical fixed pure -tone backup
alarms with ambient -sensing and/or broadband backup alarms.
3)A detailed review of final operating conditions shall be completed to ensure that
the noise study accurately and conservatively reflects future project operation. A
report documenting the assessment shall be submitted to the city six months after
the Certificate of Occupancy is issued.
4) If the proposed use of the building includes cold storage, processing, or
manufacturing, the air quality analysis (Greenline Building `B" Development,
Federal Way Washington Air Quality Report, Ramboll Environ, June 2018) must
be revised and the SEPA threshold determination revisited prior to building permit
issuance, or if no building permit is required, then prior to business license
issuance.
5)The following measures shall be implemented during project construction, with
quarterly reports submitted by the applicant to the city documenting compliance
starting from the issuance of the building permit and concluding at issuance of the
Certificate of Occupancy:
a) Use only equipment and trucks that are maintained in optimal operational
condition.
b) Require all off road equipment to be retrofit with emission reduction equipment
(i.e., require participation in Puget Sound Region Diesel Solutions by project
sponsors and contractors), including particulate matter traps and oxidation
catalysts to reduce MSATs.
c) Use biodiesel or other lower -emission fuels for vehicles and equipment.
d) Use carpooling or other trip reduction strategies for construction workers when
possible.
e) Stage construction to minimize the overall transportation system congestion and
delays to reduce regional emissions of pollutants during construction.
f) Implement restrictions on construction truck idling (e.g., limit idling to a maximum
of five minutes).
g) Locate construction equipment away from sensitive receptors, such as fresh air
intakes to buildings, air conditioners, and sensitive populations.
h) Locate construction staging zones where diesel emissions won't be noticeable
to the public or near sensitive populations, such as the elderly and the young.
i) Spray exposed soil with water or other suppressant to reduce emissions of PM,,,
and deposition of particulate matter.
j) Pave or use gravel on staging areas and roads that would be exposed for long
periods.
k) Cover all trucks transporting material and wet materials in trucks, or provide
adequate freeboard (space from the top of the material to the top of the truck bed),
to reduce PM,,) emissions and deposition during transport.
1) 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.
6) Prior to issuance of a Certificate of Occupancy, the applicant shall construct a
northbound left -turn lane on Weyerhaeuser Way South at the southerly driveway
(truck access) to provide safer and more efficient access into the site. The
northbound left (NBL) turn lane storage shall be designed to accommodate the
95th Percentile queues length, ensuring left turn queues will not block the through
traffic lane. The channelization plan must be reviewed and approved by the city
and WSDOT.
7) Prior to building permit issuance, the applicant shall install weight limit signs on
Weyerhaeuser Way South from South 320th Street to the project driveway, and
South 336th Street from 20th Avenue South to Weyerhaeuser Way South.
8)The applicant submitted a traffic study, IRG Greenline Buildings A and B
Federal Way, WA Transportation Impact Study, TENW Transportation Engineering
NorthWest, March 6, 2018. The development is estimated to generate 954 daily
trips, with 97 trips occurring during the PM peak hour (78 passenger and 19 truck).
These trips will be served by two driveways (private loop road driveway north of
the site and truck access driveway next to SR 18) on Weyerhaeuser Way South.
According to the traffic study, all truck trips will utilize the proposed truck access
driveway on Weyerhaeuser Way South and will be traveling to and from the south
using the Weyerhaeuser Way South/SR-18 interchange. On a daily basis, 1-5
southbound congestion routinely occurs between the SR 18 and South 320th
Street interchange. In order to avoid traffic congestion and reduce travel time due
to shorter distance, truck trips with origin and destination from the north could
utilize the South 320th Street/SR-5 interchange, South 3361h Street, and
Weyerhaeuser Way South as an alternate route to the site. The traffic study has
not demonstrated how the applicant will prevent this alternative truck route (South
320th Street /SR-5 interchange, South 3361h Street, and Weyerhaeuser Way South)
to the site. Weyerhaeuser Way South from South 3201h 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, prior to the Certificate of Occupancy issuance, the applicant shall provide
a fully executed bond for 120 percent of the engineer's estimate for design and
construction costs to upgrade the existing pavement on Weyerhaeuser Way
South, from the proposed truck entrance to South 320th Street. The bond term
shall be for a period of three years from the time of notification by the applicant of
full occupancy and use of the facility, unless a shorter term is mutually agreed to in
the implementation agreement discussed below. The applicant shall provide the
engineer's estimate.
Should the truck trips generated by the project traveling north of the site (to or
from the site) exceed 28 truck trips per week as set forth in the implementation
agreement discussed below, the city will use the bond for design and construction
costs to upgrade the existing pavement on Weyerhaeuser Way South, from the
proposed truck entrance to South 320th Street, and/or from the proposed truck
entrance to SR-99 via South 336th Street, to the city's required design standards.
In the alternative, the applicant may choose to design and construct the implicated
roadway(s) identified by the city. For the purposes of this condition, a "truck" shall
mean a vehicle rated in excess of 30,000 pounds gross weight as discussed in
Chapter 8.40 FWRC.
Prior to building permit issuance, the applicant and the city shall enter into an
implementation agreement to set forth the conditions by which the city will monitor
the truck trips; how the city will make its determination that the applicant has
exceeded the 28 or more truck trips per week; how notice will be provided to the
applicant; the cure period for the applicant to remedy the excess truck trips
described in the above condition; when the city will call the bond or require the
applicant to construct the implicated roadways; the bond conditions; and all other
requirements deemed necessary by the city.
9) The existing pavement on Weyerhaeuser Way South (south of the site), from
the proposed truck entrance to the SR-18 interchange must be fully reconstructed
(subgrade soils and new pavement) to accommodate the expected truck traffic
load. The applicant shall provide pavement design for city review and approval
prior to engineering plans submittal. Once the pavement design is approved by
the city, the development shall perform full depth reconstruction of the roadway
segment impacted by the truck traffic.
10) Prior to issuance of a certificate of occupancy, the applicant shall construct
right -turn storage for the westbound SR-18 off -ramp to mitigate for the impact to
the westbound off -ramp, to the satisfaction and approval of WSDOT.
11) Cumulative traffic impacts from Warehouses A and B, and the Greenline
Business Park to the SR 18 westbound ramp intersection with Weyerhaeuser Way
South shall be evaluated and mitigated in a SEPA analysis addendum, and/or
revision to the 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, the city LOS standards shall be applied and pro-rata mitigation for
Warehouse A imposed as necessary. All mitigation shall be subject to RCW
82.02.020 and constitutional nexus/proportionality.
Further information regarding this action is available to the public upon request or
on the city website: https://www.citVoffederalwaV.com/node/1962. Contact
Principal Planner Stacey Welsh at 253-835-2634, or
stacey.welsh(a�_cityoffederalway.com. This MDNS is issued under WAC 197-11-
340(2). Comments must be submitted by 5:00 p.m. on October 23, 2020. Email
comments should be directed to planning(@cityoffederalway.com.
Unless modified by the city, this determination will become final following the
above comment deadline. Any person aggrieved of the city's final determination
may file an appeal. Anyone may appeal this determination to the Federal Way City
Clerk (33325 8t" Avenue South, Federal Way, WA 98003), no later than 5:00 p.m.
on November 13, 2020, by a written letter stating the reason for the appeal of the
determination along with the required appeal fee. You should be prepared to make
specific factual objections. All appeals shall contain a specific statement of
reasons why the decision of the responsible official is alleged to be in error.
Published in the Federal Way Mirror on October 9, 2020.
Comment Deadline
Comments must be submitted by 5:00 p.m. on October 23, 2020. Email
comments should be directed to planning(a cityoffederalway.com.
City of Federal Way 133325 8th Ave S, Federal Way, WA 98003
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Stacey Welsh
From: Charles Birnbaum <info@tclf.org>
Sent: Sunday, October 25, 2020 1:09 PM
To: Daniel Jost; Ping Inquiry; Stacey Welsh
Subject: RE: Comments on Plans for Redeveloping Weyerhauser Campus
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Dan — thanks for sending this along — Good to see where you have landed. Best, Charles
From: Daniel Jost
Sent: Friday, October 23, 2020 7:51 PM
To: Planning@cityoffederalway.com; Stacey Welsh
Subject: Comments on Plans for Redeveloping Weyerhauser Campus
To: The City of Federal Way
Re: File No. 17-104237-SE
I am writing to express my concern regarding the recent plans for the former Weyerhauser Campus. I am particularly
concerned about the Determination of Nonsignificance for the property where Woodbridge Building "B" is proposed
(File No. 17-104237-SE). I hope the city will rescind this decision. Allowing the construction of a 45-foot-tall warehouse
on this site would greatly diminish this local and national treasure.
When the American Society of Landscape Architects celebrated its 100th anniversary in 1999, Weyerhauser's Campus
was highlighted in a special issue of Landscape Architecture Magazine as one of the most significant works of landscape
architecture of the 20th century. Today, the design of the Weyerhauser Campus is taught in landscape architecture
history classes --including the one I taught as a graduate student at the University of Washington.
At Weyerhauser Campus, SWA Group and SOM created a functional work of land art. He transformed the suburban
parking lot --which is not typically an outlet for artistic expression --into a beautiful composition to experience as a driver,
pedestrian, or viewer from an adjacent property. Adjacent forested areas were sculpted and pierced with roads as part
of this composition --and tell a story about Weyerhauser's ecological goals. Seven years after completing this landscape,
Peter Walker was hired to lead Harvard University's landscape architecture program --where he was the leader of a
highly influential movement that sought to create functional and meaningful land art that served a social function. The
approach Walker brought to the Weyerhauser Campus transformed the field of landscape architecture and dominated it
for much of the next 35 years.
The current proposal leaves only a very narrow strip of trees between key paths/drives and the new warehouses. In
some places, they are proposing only one line of trees between the warehouse and key paths, drives, and lawns. And it
treats the area where Warehouse B is being proposed as an empty lot ready to be developed. This forested area where
Warehouse B is proposed is no more an empty space ready to be filled than the forested areas around the Grand Canal
at Versailles are empty. It is an essential part of this historic landscape. The narrow strips of trees proposed would not
adequately block views or buffer noise. They would destroy the entry experience intended for the site --which was about
moving through a forested area. And most importantly, Warehouse "B" as proposed would also completely throw off
the artistic balance of this masterpiece of landscape architecture. The possibility of building on part of the site was
considered under SWA Group's original plans but a much larger area of trees would have been preserved as part of the
landscape composition of the headquarters building under that plan.
The City of Federal Way should use any authority it has to prevent development on the forested areas directly adjacent
to the main headquarters structure and its artfully designed parking lots or limit that development to the area where
development was historically proposed. If development does occur, ideally, it should be development that is compatible
with reuse of the former HQ building and not warehouse from an unconnected company that may actually devalue that
site and lead to its demise in the future. The city should use any tools it can to ensure that a wider buffer is preserved
between new development and key parts of the campus --including existing lawn areas, pathways, and Weyerhauser
Road. This significant historic landscape should be treated as a part of Federal Way's and our nation's cultural heritage
and should not be diminished.
Daniel Jost, ASLA
Landscape designer, researcher, and educator
Former Writer/Editor Landscape Architecture Magazine (2008-2013)
Former Contributing Editor to Landscape Architecture Magazine (2013-2018)
Co -curator of Landscape Architecture Magazine's 100th-anniversary issue.
Ph.D. Candidate at North Carolina State University
A photo showing how Walker used the forest to frame views and balance the composition. Much of the forested area to
the left would become a 4-story warehouse under the current proposal, destroying the balance of this masterpiece of
functional land art. (Image: Seattle Daily Journal of Commerce)
ZJ;
PPF
I
Earth
The entire kidney -shaped area at Weyerhauser Campus contributes to Walker's land art composition. The shape is found
in other major works of modern landscape architecture including the Donnell Garden. (Image: TCLF)
W"er# aeuear Matter Lanaecape %r
Future �?eveopmem ^rt3arA M
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A historic plan showing how any development might be respectfully distanced from the landscape surrounding the
former HQ building. Ideally, such development would be compatible with redevelopment of the campus itself and not a
warehouse.
9
Stacey Welsh
From: vikki goodman <vikkilee10@yahoo.com>
Sent: Friday, October 23, 2020 9:42 AM
To: Ping Inquiry
Subject: Re: File No: 17-104237-SE
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I am a member of the wonderful Audubon Society and do support their very good analyses on environmental support for
all of our birds. In regards to the former Weyerhaeuser campus in Federal Way I do feel that quiet and natural places are
important for birds and for people.
The Weyerhaeuser Campus also has important historic signatures for us Washingtonians and Weyerhaeuser's founder
wanted this place as a preserve.
Birds are wonderful creatures who can sing and dance and have been here on earth for longer than us. My husband was
a logger for many years and birds are a treasure to both of us.
Please let George Weyerhaeuser rest peacefully and preserve his legacy.
Very Truly,
Vikki and John Goodman
4525 So. 280th St.
Auburn, WA 98001
253-856-0980
Stacey Welsh
From: Tina Vaslet <tvaslet@piercetransit.org>
Sent: Monday, October 12, 2020 12:07 PM
To: Stacey Welsh
Subject: RE: Mitigated Determination of Nonsignificance (MDNS)
Attachments: MDNS Packet.pdf
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Good afternoon, Stacey. Thank you for the opportunity to review this proposal. It's nice to see that pedestrian
improvements will be made with this project, especially considering the bus stop on the west side of the street (#4044)
currently has NO sidewalk. I see that there are plans to add a new shelter pad for that stop. Current ridership for that
stop doesn't warrant the placement of a shelter, but maybe this project will increase ridership enough for a shelter in
the future? It will be nice to have that option, if needed.
Kind Regards,
Tina
LTina Vaslet
Planner II — Bus Stops
Desk: 253.983.2706 1 Cell: 253.255-8521
3701 96th St. SW. Lakewood. WA 98499
Providing 40 years of service
PT20-011 Bus Stop #'s 4044 & 4051
From: Tina Piety
Sent: Friday, October 9, 2020 2:38 PM
To: 'separegister@ecy.wa.gov' ; contactus@federalwayhistory.org; 'rybolt.s@portseattle.org'
suzanne.l.anderson@usace.army.mil; 'rob.ryan@wa.usda.gov' ; hubenbj@dshs.wa.gov; jford@agr.wa.gov;
'reviewteam@commerce.wa.gov' ; hgcustomerservice@wsdot.wa.gov; 'mccolld@wsdot.wa.gov' ;
sepacenter@dnr.wa.gov; sepa@dahp.wa.gov; sepadesk@dfw.wa.gov; 'randy.kline@parks.wa.gov' ;
'kukesc@wsdot.wa.gov' ; 'larry.fisher@dfw.wa.org' ; info@psp.wa.gov; wec@wecprotects.org;
'kelly.cooper@doh.wa.gov' ; 'swiresm@wsdot.wa.gov' ; 'eharris@psrc.org' ; 'sepa@pscleanair.org' ;
'brandon.reynon@puyalluptribe.com' ; 'todd.scott@kingcounty.gov' ; 'neil.fujii@kingcounty.gov' ; 'info@edc-
seaking.org' ; 'james.irish@soundtransit.org' ; 'perry.weinberg@soudtransit.org' ; 'jgreene@kingcounty.gov' ;
'info@forterra.org' ; 'jjordan@portoftacoma.com' ; Tina Vaslet ; 'chase.wakefield@bp.com' ; 'timothy.fehr@bp.com' ;
'keith.boyle@bp.com' ; 'aclark@co.pierce.wa.us' ; 'kent.hale@soundtransit.org' ; 'dlath rop@desmoineswa.gov' ;
'wfwoctap@fws.gov' ; 'sclary@mbaks.com' ; 'janderson@mbaks.com' ; 'sam@sampace.com' ;
'shirley.schultz@ci.tacoma.wa.us' ; 'jmagoon@cityoftacoma.org' ; 'info@earthcorps.org' ; 'epa-seattle@epa.gov' ;
'dlein@auburnwa.gov' ; 'assessor.info@kingcounty.gov' ; 'serviceaddresscorrec@pse.com' ;
'mike.buIzomi@soundtransit.org' ; 'char.naylor@puyalluptribe-nsn.gov' ; Chris Cahan ; Rebecca Martin ; Brian Asbury ;
'jthomas@fwps.org' ; Jennifer Wojciechowski ; 'stimm@cityofmilton.net' ; 'bport@cityofmilton.net' ;
'karen.walter@muckleshoot.nsn.us' ; 'laura.murphy@muckleshoot.nsn.us' ; 'dlewarch@suquamish.nsn.us' ;
'matthew.perkins@kingcounty.gov' ; 'Ishimaru, Jim'
Cc: Stacey Welsh
Subject: Mitigated Determination of Nonsignificance (MDNS)
Hello,
Attached you will find an MDNS and enclosures regarding the Woodbridge Building "B" project. Please contact
Principal Planner Stacey Welsh at 253-835-2634 or stacey.welsh@cityoffederalway.com, if you have any
comments and/or questions regarding this MDNS.
Regards,
E. Tina Piety, CAP, OM
Administrative Assistant II
�MY �
Federal Way
Community Development Department
33325 81" Avenue South
Federal Way, WA 98003-6325
Phone: 253/835-2601 Fax: 253/835-2609
www.citvoffederalway.com
44k
CITY OF
Federal Way
STATE ENVIRONMENTAL POLICY ACT
MITIGATED DETERMINATION OF NONSIGNIFICANCE
(MDNS)
Woodbridge Building "B" (formerly Greenline Warehouse "B")
File No: 17-104237-SE
Description of
Proposal: Construction of a 45-foot-tall, 214,050 square -foot general commodity warehouse with
245 parking spaces and associated site work, including wetland fill, on a 16.85-acre site
(parcel 6142600200), along with improvements to the right-of-way for Weyerhaeuser
Way South.
Proponent: Federal Way Campus LLC
11100 Santa Monica Blvd, Suite 850
Los Angeles, CA 90025
Location: 3120 South 344th Street, Federal Way, WA
Lead Agency: City of Federal Way
City Staff
Contact: Principal Planner Stacey Welsh, AICP
253-835-2634, stacey.welsh(&ciiyoffederalwa.
The Responsible Official of the City of Federal Way hereby makes the following decision based upon
impacts identified in the environmental checklist, Federal Way Comprehensive Plan, Staff Evaluation for
Environmental Checklist, and other municipal policies, plans, rules, and regulations designated as a basis
for exercise of substantive authority under the Washington State Environmental Policy Act Rules pursuant
to RCW 43.31C.060.
The lead agency has determined that this proposal will not have a probable significant adverse impact on
the environment. Pursuant to WAC 197-11-350(3), the proposal has been clarified, changed, and
conditioned to include necessary mitigation measures to avoid, minimize, or compensate for probable
significant impacts. An environmental impact statement (EIS) is not required under RCW 43.21C.030(2)(c).
The necessary mitigation measures are listed below. This decision was made after review of a completed
environmental checklist (enclosed) and other information on file with the lead agency. This information is
available to the public by request or on the city website: https://www.cityoffederalway.com/node/1962.
This determination is based on the following findings and conclusions:
Mitigated Determination of Nonsignificance (MDNS) Page 1 of 8
Woodbridge Building `B" 17-104237-00-SE / Doc. I.D. 80801
FINDINGS OF FACT
1. The Woodbridge Building `B" project is for construction of a 45-foot-tall, 214,050 square -foot
general commodity warehouse with 245 parking spaces and associated site work, including wetland
fill, on a 16.85-acre site (parcel 6142600200), along with improvements to the right-of-way for
Weyerhaeuser Way South.
2. The proposal is subject to the provisions of the 1994 Weyerhaeuser Company Concomitant Pre -
Annexation Development Agreement (CZA) and zoning regulations in effect on August 23, 1994
(Federal Way City Code [FWCC]). Any procedural requirements must meet current code (Federal
Way Revised Code [FWRC]). Zoning for the subject property is Corporate Park (CP-1). Warehousing,
distribution, and corporate offices are permitted uses in the CP-I zone pursuant to CZA Exhibit C,
Section VIl, "Permitted Uses on Those Portions of the CP-I Zoned Property Lying Outside the
Managed Forest Buffer." The Federal Way Comprehensive Plan (FWCP) designation for the subject
property is Corporate Park.
The applicant submitted an air quality report prepared by Ramboll Environ, June 2018. The report
describes sources of air pollution typical of a general commodities warehouse, including emergency
generators and vehicles used by employee commuter trips and truck deliveries. The report states,
"With implementation of required measures to provide reasonable controls of dust and odors,
construction of the proposed project would not be expected to result in significant air quality
impacts." Regarding operation of the project, the report states, "The analyses described above
indicate the proposed project would be unlikely to result in any significant air quality impacts.
Consequently, no operational mitigation measures are warranted or proposed."
4. The applicant submitted a noise report prepared by Ramboll Environ, July 2018. The report
concluded, "The assessment found that operation of the proposed Project would result in acoustically
negligible increases in ambient noise at nearby residential receivers, and between no increase and
very minor increases at nearby commercial receivers. The proposed Project would be within
compliance of applicable noise limits at all nearby residential and commercial receivers." The report
lists measures to reduce the potential for high levels of noise from construction equipment or
activities. Regarding operation of the project, the report states, "Noise mitigation measures are not
warranted at this time."
The applicant submitted a traffic study, IRG Greenline Buildings A and B Federal Way, WA
Transportation Impact Study, TENW Transportation Engineering NorthWest, March 6, 2018. The
traffic study stated that all truck trips are expected to utilize the primary driveway on Weyerhaeuser
Way South, and all truck trips will be traveling to and from the south using the Weyerhaeuser Way
South/SR-18 interchange and therefore, study mitigation or improvements were not required for other
road segments. The traffic study does not however, demonstrate how the applicant will prevent trucks
entering or exiting the facility from allowing this travel. Without adequate supporting documentation/
planning, there is nothing prohibiting trucks from utilizing the South 320th Street/SR-5 interchange,
South 336th Street, and Weyerhaeuser Way South as an alternate route to the site. Based on the above,
the applicant has not demonstrated mitigation of additional truck traffic onto non -designated truck
routes, such as Weyerhaeuser Way South north of the site, including impacts to the pavement.
6. The applicant submitted a pavement analysis for Weyerhaeuser Way South, Geotechnical
Engineering Services Report Weyerhaeuser Way South, 320`h Street to SR 18 Weyerhaeuser Campus
Property Federal Way, Washington, GeoEngineers, August 29, 2017. Per the pavement analysis, the
development is expected to nearly triple the loading on the existing pavement (EASLs) along the
Mitigated Determination of Nonsignificance (MDNS) Page 2 of 8
Woodbridge Building `B" 17-104237-00-SE / Doc. I.D. 80801
truck route on Weyerhaeuser Way South. Furthermore, the pavement in the project area is
approaching the end of its useable life. The Public Works Street Division reviewed the pavement
analysis and determined that the existing pavement on Weyerhaeuser Way South along the truck
route must be fully reconstructed (subgrade soils and new pavement) to accommodate the expected
truck traffic load.
7. The SR-18 ramp terminal intersections are under Washington State Department of Transportation
(WSDOT) control and are subject to WSDOT's established standards. The traffic study prepared by
TENW for Woodbridge Building "A" (formerly Greenline Warehouse "A") was revised to address
WSDOT comments pertaining to a LOS and queuing analysis at the SR-18 ramp terminal
intersections. After the MDNS for Woodbridge Building "A" was issued, WSDOT identified and
requested mitigation for the westbound SR-18 off -ramp right -turn storage. Due to additional trips
generated by the project impacting this intersection, the 95t1i percentile queues length for the AM peak
hour would exceed the available right -turn storage. As such, WSDOT requested that the westbound
SR-18 off -ramp right -turn storage be extended from the existing 100 feet to 300 feet. A Modified
MDNS was issued for Woodbridge Building "A" to include that mitigation measure. WSDOT
confirmed in May 2019 that they reviewed the traffic study for both Warehouses "A" and `B," and
the mitigation measure was for both Warehouses "A" and `B." The mitigation measure regarding the
SR-18 off -ramp right -turn storage applies to Woodbridge Building `B."
8. In accordance with the October 29, 2019, Hearing Examiner's Request for Reconsideration Decision
for Greenline Warehouse "A," the following shall be made a SEPA mitigation measure: Cumulative
traffic impacts from Warehouses "A" and `B," and the Greenline Business Park to the SR 18
westbound ramp intersection with Weyerhaeuser Way South shall be evaluated and mitigated in a
SEPA analysis addendum and/or revision to the Warehouses "A" and `B" TIA. PM peak hour
cumulative impacts shall be included in the TIA analysis, or added to the concurrency review for
Warehouse "A," as the city finds most consistent with its regulations. The city shall determine if
WSDOT has jurisdiction over the SR 18 intersection. If WSDOT has jurisdiction over the SR 18
intersection, WSDOT LOS standards shall be applied to the intersection and any necessary pro-
rata mitigation for Warehouse "A" shall be formulated in consultation with WSDOT, as
contemplated in Conclusion of Law No. 8 of the Final Decision. If WSDOT doesn't have
jurisdiction over the intersection, the city LOS standards shall be applied, and pro-rata mitigation
for Warehouse "A" imposed as necessary. All mitigation shall be subject to RCW 82.02.020 and
constitutional nexus/proportionality.
9. The project requires review under Process III, Project Approval. The Director of Community
Development makes a written decision on the application based on the criteria listed under FWRC
19.65.100. A city staff report will be prepared for the project decision that will address additional
topic areas.
10. Cumulative Impacts Analysis —Woodbridge Building `B" is proposed on parcel 6142600200. A
separate project, Woodbridge Building "A" (formerly Greenline Warehouse "A") located on parcels
6142600005 and 6142600200, received land use approval in February 2019. The SEPA threshold
determination and land use decision were appealed. The Hearing Examiner denied the appeal and
sustained the Use Process III decision and MDNS with the addition of two conditions pertaining to
traffic and stormwater. A Request for Reconsideration was filed and the Hearing Examiner revised
the two conditions. The Hearing Examiner's decision was appealed to Superior Court. Superior Court
denied the appeals and affirmed the Hearing Examiner's Decision on June 10, 2020.
Mitigated Determination of Nonsignificance (MDNS) Page 3 of 8
Woodbridge Building `B" 17-104237-00-SE / Doc. I.D. 80801
The two projects will utilize a common driveway access off of Weyerhaeuser Way South and the
same stormwater pond located on parcel 6142600200; although, the addition of Building `B" requires
the pond to be enlarged from its size if it only served Building "A." There are no other cumulative
impacts on the Woodbridge Building `B" project. The city has not received indication from the
applicant that the two projects will be constructed simultaneously; therefore, there is no cumulative
impacts analysis regarding construction.
The city evaluated the projects for cumulative impacts and identified and analyzed those parts of the
projects that implicate such impacts in this determination. As part of the project review, the city
evaluated Building `B" with regard to FWRC 19.100.030(2). The projects share a parcel in common,
6142600200. Cumulative impact review is incorporated into many city development regulations. The
analysis of cumulative impacts for Woodbridge Building "B" is reflected throughout this determination
and the forthcoming land use decision.
Many of the project submittal documents for Woodbridge Building `B" reference Woodbridge
Building "A," in particular:
a) IRG Greenline Buildings A and B, Federal Way, WA Transportation Impact Study, TENW
Transportation Engineering NorthWest, March 6, 2018:
a. The LOS and queuing analysis for Woodbridge Building `B" included trips from
Woodbridge Building "A."
b) Critical Areas Report Files #17-104236-UP & #17-104237-SE, Greenline Building B, Federal
Way, Washington, Talasaea Consultants, Inc., revised June 26, 2018.
c) Greenline Building B Preliminary Technical Information Report, ESM Consulting Engineers
LLC, June 28, 2018.
d) Greenline Building B Visual Impact Analysis, ESM Consulting Engineers LLC, August 10, 2018.
e) Vision Analysis Greenline Building B, ESM Consulting Engineers LLC, October 9, 2018.
In addition, regarding WAC 197-11-060(3)(b), Woodbridge Building `B" can proceed without
Woodbridge Building "A" and is not reliant upon Woodbridge Building "A" taking place in order to
proceed. Woodbridge Building "B" does not depend on Woodbridge Building "A" as justification for
its implementation and the projects are not interdependent parts of a larger proposal. In other words,
Woodbridge Building `B" and Woodbridge Building "A" do not meet the WAC 197-11-060(3)(b)
threshold to require evaluation of the two projects in the same environmental document.
Another separate project, the Woodbridge Corporate Park (WCP) (formerly Greenline Business
Park), was submitted in November 2017. The WCP is proposed on other parcels within the former
Weyerhaeuser Campus. The WCP does not propose to share a common parcel, access point, or utility
facilities with Woodbridge Buildings "A" or `B." Regarding WAC 197-11-060(3)(b), Woodbridge
Buildings "A" and `B" can proceed without the WCP and are not reliant upon the WCP taking place
in order to proceed themselves. Woodbridge Buildings "A" and `B" are not interdependent parts of
the WCP and do not depend on the WCP as justification for their implementation. The WCP does not
meet the WAC 197-11-060(3)(b) threshold to require the evaluation of the other projects in the same
environmental document.
11. The "Staff Evaluation for Environmental Checklist, File No. 17-104237-SE" is hereby incorporated
by reference as though set forth in full.
Mitigated Determination of Nonsignificance (MDNS) Page 4 of 8
Woodbridge Building `B" 17-104237-00-SE / Doc. I.D. 80801
CONCLUSIONS OF LAW
Federal Way's comprehensive plan policies contained within the FWCP, serve as a basis for the exercise
of substantive SEPA authority to approve, condition, or deny proposed actions applicable to potential
adverse environmental impacts resulting from this project. The following components of the FWCP
(revised 2015) support the conditions for the development.
NEP10 The City may continue to require environmental studies by qualified professionals to assess the
impact and recommend appropriate mitigation of proposed development on environmentally critical
areas and areas that may be contaminated or development that may potentially cause contamination.
NEP86 Support state and federal air quality standards and the regulation of activities that emit air
pollutants.
NEP87 Utilize building design, construction, and technology techniques to mitigate the negative
effects of air pollution on indoor air quality for uses near sources of pollution such as Interstate-5.
NEP102 The City will evaluate potential noise impacts associated with non-residential uses and
activities located in residential areas as part of the site plan review process.
TP1.11 Develop code requirements and a designated truck route system that accommodates the needs
of the private sector and residents, and provides a balance between movement needs and quality of life.
TP1.12 Discourage the use of road facilities by vehicles carrying hazardous materials and those with
weight, size, or other characteristics that would be injurious to people and property in the City.
TP3.15 Develop access management standards to minimize the number of curb cuts on arterials to
improve pedestrian and vehicle safety.
TP3.18 Incorporate environmental factors into transportation decision -making, including attention to
human health and safety.
SEPA CONDITIONS
Based on the above policy, the following mitigation measures are required to minimize identified
potential significant adverse environmental impacts.
1) Prior to building permit issuance, the applicant shall submit an evaluation of the facility design by a
qualified professional to ensure that the types and numbers of equipment to be installed at the
warehouse, as well as warehouse activities, are consistent or similar to those identified in the noise
report (Greenline Building "B " Development, Federal Way Washington Environmental Noise Report,
Ramboll Environ, July 2018).
2) The following measures shall be implemented during project construction with quarterly reports
submitted by the applicant to the city documenting compliance starting from the issuance of the
building permit and concluding at the issuance of a Certificate of Occupancy:
a) All equipment shall be fitted with properly sized mufflers, and if necessary, engine intake silencers.
b) All equipment shall be in good working order.
c) Use quieter construction equipment models if available and whenever possible use pneumatic
tools rather than diesel or gas -powered tools.
Mitigated Determination of Nonsignificance (MDNS) Page 5 of 8
Woodbridge Building `B" 17-104237-00-SE / Doc. I.D. 80801
d) Place portable stationary equipment as far as possible from existing residential and noise -sensitive
commercial areas, and if necessary, place temporary barriers around stationary equipment.
e) For mobile equipment, consider placement of typical fixed pure -tone backup alarms with
ambient -sensing and/or broadband backup alarms.
3) A detailed review of final operating conditions shall be completed to ensure that the noise study
accurately and conservatively reflects future project operation. A report documenting the assessment
shall be submitted to the city six months after the Certificate of Occupancy is issued.
4) If the proposed use of the building includes cold storage, processing, or manufacturing, the air quality
analysis (Greenline Building "B " Development, Federal Way Washington Air Quality Report,
Ramboll Environ, June 2018) must be revised and SEPA threshold determination revisited prior to
building permit issuance, or if no building permit is required, then prior to business license issuance.
5) The following measures shall be implemented during project construction with quarterly reports
submitted by the applicant to the city documenting compliance starting from the issuance of the
building permit and concluding at issuance of the Certificate of Occupancy:
a) Use only equipment and trucks that are maintained in optimal operational condition.
b) Require all off road equipment to be retrofit with emission reduction equipment (i.e., require
participation in Puget Sound region Diesel Solutions by project sponsors and contractors),
including particulate matter traps and oxidation catalysts to reduce MSATs.
c) Use biodiesel or other lower -emission fuels for vehicles and equipment.
d) Use carpooling or other trip reduction strategies for construction workers when possible.
e) Stage construction to minimize overall transportation system congestion and delays to reduce
regional emissions of pollutants during construction.
f) Implement restrictions on construction truck idling (e.g., limit idling to a maximum of five minutes).
g) Locate construction equipment away from sensitive receptors, such as fresh air intakes to buildings,
air conditioners, and sensitive populations.
h) Locate construction staging zones where diesel emissions won't be noticeable to the public or
near sensitive populations, such as the elderly and the young.
i) Spray exposed soil with water or other suppressant to reduce emissions of PMIo and deposition of
particulate matter.
j) Pave or use gravel on staging areas and roads that would be exposed for long periods.
k) Cover all trucks transporting materials, wet materials in trucks, or provide adequate freeboard
(space from the top of the material to the top of the truck bed), to reduce PMIo emissions and
deposition during transport.
1) Provide wheel washers to remove particulate matter that would otherwise be carried off site by
vehicles to decrease deposition of particulate matter on area roadways.
m) Remove particulate matter deposited on paved, public roads, sidewalks, and bicycle and pedestrian
paths to reduce mud and dust; sweep and wash streets continuously to reduce emissions.
n) Cover dirt, gravel, and debris piles as needed to reduce dust and wind-blown debris.
o) Route and schedule construction trucks to reduce delays to traffic during peak travel times to
reduce air quality impacts caused by a reduction in traffic speeds.
Mitigated Determination of Nonsignificance (MDNS) Page 6 of 8
Woodbridge Building `B" 17-104237-00-SE / Doc. I.D. 80801
6) Prior to issuance of a Certificate of Occupancy, the applicant shall construct a northbound left -turn
lane on Weyerhaeuser Way South at the southerly driveway (truck access) to provide safer and more
efficient access into the site. The northbound left (NBL) turn lane storage shall be designed to
accommodate the 95t1i Percentile queues length ensuring left -turn queues will not block the through
traffic lane. The channelization plan must be reviewed and approved by the city and WSDOT.
7) Prior to building permit issuance, the applicant shall install weight limit signs on Weyerhaeuser Way
South from South 320' Street to the project driveway, and South 336th Street from 20th Avenue South
to Weyerhaeuser Way South.
8) The applicant submitted a traffic study, IRG Greenline Buildings A and B Federal Way, WA
Transportation Impact Study, TENW Transportation Engineering NorthWest, March 6, 2018. The
development is estimated to generate 954 daily trips with 97 trips occurring during the PM peak hour
(78 passenger and 19 truck). These trips will be served by two driveways (private loop road driveway
north of the site and truck access driveway next to SR 18) on Weyerhaeuser Way South. According to
the traffic study, all truck trips will utilize the proposed truck access driveway on Weyerhaeuser Way
South and will be traveling to and from the south using the Weyerhaeuser Way South/SR-18
interchange. On a daily basis, I-5 souhbound congestion routinely occurs between the SR 18 and
South 320th Street interchange. In order to avoid traffic congestion and reduce travel time due to the
shorter distance, truck trips with origin and destination from the north could utilize South 320th
Street/SR-5 interchange, South 336th Street, and Weyerhaeuser Way South as an alternate route to the
site. The traffic study has not demonstrated how the applicant will prevent this alternative truck route
(South 320th Street /SR-5 interchange, South 336th Street, and Weyerhaeuser Way South) to the site.
Weyerhaeuser Way South from South 320th Street and SR 18 is not a designated truck route and
therefore, the roadway cannot support heavy vehicle weights. In general, heavier vehicles cause more
damaged to the road than light vehicles. The federal government estimated that an 18-wheel truck
causes the same damage to the road as 9,600 cars. Based on the above, the applicant has not
demonstrated mitigation of additional truck traffic onto non -designated truck routes such as
Weyerhaeuser Way South north of the site, including impacts to the pavement.
As such, prior to the Certificate of Occupancy issuance, the applicant shall provide a fully executed
bond for 120 percent of the engineer's estimate for design and construction costs to upgrade the
existing pavement on Weyerhaeuser Way South, from the proposed truck entrance to South 320th
Street. The bond term shall be for a period of three years from the time of notification by the
applicant of full occupancy and use of the facility, unless a shorter term is mutually agreed to in the
implementation agreement discussed below. The applicant shall provide the engineer's estimate.
Should the truck trips generated by the project traveling north of the site (to or from the site) exceed
28 truck trips per week as set forth in the implementation agreement discussed below, the city will
use the bond for design and construction costs to upgrade the existing pavement on Weyerhaeuser
Way South, from the proposed truck entrance to South 320th Street, and/or from the proposed truck
entrance to SR-99 via South 336th Street, to the city's required design standards. In the alternative, the
applicant may choose to design and construct the implicated roadway(s) identified by the city. For the
purposes of this condition, a "truck" shall mean a vehicle rated in excess of 30,000 pounds gross
weight as discussed in Chapter 8.40 FWRC.
Prior to building permit issuance, the applicant and the city shall enter into an implementation
agreement to set forth the conditions by which the city will monitor the truck trips; how the city will
make its determination that the applicant has exceeded the 28 or more truck trips per week; how notice
Mitigated Determination of Nonsignificance (MDNS) Page 7 of 8
Woodbridge Building `B" 17-104237-00-SE / Doc. I.D. 80801
will be provided to the applicant; the cure period for the applicant to remedy the excess truck trips
described in the above condition; when the city will call the bond or require the applicant to construct
the implicated roadways; the bond conditions; and all other requirements deemed necessary by the city.
9) The existing pavement on Weyerhaeuser Way South (south of the site), from the proposed truck
entrance to the SR-18 interchange must be fully reconstructed (subgrade soils and new pavement) to
accommodate the expected truck traffic load. The applicant shall provide pavement design for city
review and approval prior to engineering plans submittal. Once the pavement design is approved by
the city, the development shall perform full depth reconstruction of the roadway segment impacted by
the truck traffic.
10) Prior to issuance of a certificate of occupancy, the applicant shall construct right -turn storage for the
westbound SR-18 off -ramp to mitigate for the impact to the westbound off -ramp to the satisfaction
and with approval of WSDOT.
11) Cumulative traffic impacts from Warehouses A and B and the Greenline Business Park to the SR
18 westbound ramp intersection with Weyerhaeuser Way South shall be evaluated and mitigated
in a SEPA analysis addendum, and/or revision to the Warehouses A and B TIA. PM peak hour
cumulative impacts shall be included in the TIA analysis, or added to the concurrency review for
Warehouse A, as the city finds most consistent with its regulations. The city shall determine if
WSDOT has jurisdiction over the SR 18 intersection. If WSDOT has jurisdiction over the SR 18
intersection, WSDOT LOS standards shall be applied to the intersection and any necessary pro-
rata mitigation for Warehouse A shall be formulated in consultation with WSDOT, as
contemplated in Conclusion of Law No. 8 of the Final Decision. If WSDOT doesn't have
jurisdiction over the intersection, city LOS standards shall be applied and pro-rata mitigation for
Warehouse A imposed as necessary. All mitigation shall be subject to RCW 82.02.020 and
constitutional nexus/proportionality.
This MDNS is issued under WAC 197-11-340(2); the lead agency will not act on this proposal for 14
days from the date of issuance. Comments must be submitted by 5:00 p.m. on October 23, 2020. Email
comments should be directed to planning@a,cityoffederalway.com.
Unless modified by the city, this determination will become final following the above comment deadline.
Any person aggrieved of the city's final determination may file an appeal. Anyone may appeal this
determination to the Federal Way City Clerk (address below), no later than 5:00 p.m. on November 13,
2020, by a written letter stating the reason for the appeal of the determination, along with the required
appeal fee. You should be prepared to make specific factual objections. All appeals shall contain a
specific statement of reasons why the decision of the responsible official is alleged to be in error.
Responsible Official: Brian Davis
Position/Title: Community Development Director
Address: 33325 8th Avenue South, Federal Way, WA 98003
Contact: 253-835-2633, brian.davis&cityoffederalwa,
Date Issued: October 9, 2020 Signature: Digitally Signed October 9. 2020, at 9: 39 AM
Mitigated Determination of Nonsignificance (MDNS) Page 8 of 8
Woodbridge Building `B" 17-104237-00-SE / Doc. I.D. 80801
40k
CITY 8F
Federal Way
Department of Community Development
STAFF EVALUATION
FOR ENVIRONMENTAL CHECKLIST
Woodbridge Building "B"
Federal Way File: 17-104237-SE
Related Files: 17-104236-UP, 17-104239-CN, & 18-102212-SM
NOTE: Technical reports and attachments referenced below may not be enclosed with all copies of this evaluation.
Documents are available for review; contact Principal Planner Stacey Welsh, Department of Community Development,
33325 81 Avenue South, Federal Way, WA 98003, 253-835-2634, or Stacey.welsh(&cityoffederalway.com. This
information is available to the public by request or on the city website: htg2s://www.ciiyoffederalwgy.com/node/1962.
I. SUMMARY OF PROPOSED ACTION
Construction of a 45-foot-tall, 214,050 square -foot general commodity warehouse with 245 parking
spaces and associated site work, including wetland fill, on a 16.85-acre site (parcel 6142600200),
along with improvements to the right-of-way for Weyerhaeuser Way South (Exhibit A).
II. GENERAL INFORMATION
Project Name: Woodbridge Building `B" (formerly Greenline Warehouse `B")
Applicant: Federal Way Campus LLC
11100 Santa Monica Blvd, Suite 850
Los Angeles, CA 90025
Phone: (310) 806-4434
Applicant's
Agent: Eric LaBrie
ESM Consulting Engineers, LLC
33400 8th Avenue South, Suite 205
Federal Way, WA 98003
Phone: (253) 838-6113
Location: 3120 South 344th Street, Federal Way, WA (Exhibit B)
Parcel: 614260-0200
Zoning: Corporate Park (CP-1)
Comp Plan
Designation: Corporate Park
Staff Evaluation for Environmental Checklist Page 1 of 11
Woodbridge Building `B" 17-104237-SE / Doc ID 80803
The following information was submitted as part of the application for review. The most recent versions
of documents are listed below, as some documents have been revised and submitted multiple times.
1. Built Environment Survey of the Former Weyerhaeuser Corporate Headquarters Campus for
Compliance with Section 106 of the NHPA — Comments on SEPA Compliance for
Woodbridge Building B, Cardno, July 27, 2020
2. Federal Way Campus, LLC Renaming of Current Land Use Projects, ESM Consulting
Engineers LLC, February 8, 2019
Vision Analysis Greenline Building B, ESM Consulting Engineers LLC, October 9, 2018
4. Resubmittal File No.'s 17-104236-UP & 17-204237-SE, Greenline Building B, ESM
Consulting Engineers LLC, August 15, 2018
5. Environmental Checklist, signed by Matt Reider, August 10, 2018
6. Greenline Building B Visual Impact Analysis, ESM Consulting Engineers LLC, August 10, 2018
7. Greenline Building `B" Development, Federal Way, Washington, Air Quality Report,
Ramboll Environ US Corporation, June 2018
8. Greenline Building `B" Development, Federal Way, Washington Environmental Noise Report,
Ramboll Environ US Corporation, July 2018
9. Technical Review Comments, ESM Consulting Engineers LLC, June 28, 2018
10. Project #TAL-1593, Tetra Tech, received June 28, 2018
11. Greenline Building B Preliminary Technical Information Report, ESM Consulting Engineers
LLC, June 28, 2018
12. Buffer Averaging Plan Wetland Exemption Exhibit Sheet W1.1, Talasaea Consultants, Inc.,
received June 28, 2018
13. Design Narrative and Process III Decisional Criteria, ESM Consulting Engineers, June 27, 2018
14. Managed Forest Buffer Management Plan At the Greenline Building B Site Weyerhaeuser
Way South, Federal Way, WA 98003, Gilles Consulting, revised June 26, 2018
15. Evaluation of Interior Trees at the Greenline Building B Site Weyerhaeuser Way South, Federal
Way, WA 98003, Gilles Consulting, revised June 26, 2018
16. Tree Data for 32 Acre Site, Weyerhaeuser Way South, Federal Way, WA, Gilles Consulting,
June 26, 2018
17. Response to Comments dated 13 December 2017, Talasaea Consultants, Inc., June 26, 2018
18. Critical Areas Report Files #17-104236-UP & File #17-104237-SE, Greenline Building B
Federal Way, Washington, Talasaea Consultants, Inc., revised June 26, 2018
19. Revised Geotechnical Engineering Services Report Proposed Greenline Building B Development,
Federal Way, Washington, GeoEngineers, June 21, 2018
20. Impervious Area Exhibit Sheet EN-02, ESM Consulting Engineers LLC, June 18, 2018
21. Design Brief, Exterior Elevations & Perspectives Sheet A1.0, by Craft Architects, June 18, 2018
22. Building Elevations Sheet Al.1, Craft Architects, June 18, 2018
Staff Evaluation for Environmental Checklist Page 2 of 11
Woodbridge Building `B" 17-104237-SE / Doc ID 80803
23. Site Plan Sheet ST-01; Existing Conditions Sheet EX-01; Legend Sheet LG-01; Preliminary
Drainage Grading and ROW Plan Sheet SD-0 1, Preliminary Landscape Plan Sheets LA-0 1;
Landscape Details and Notes Sheet LA-02; Frontage Plan Sheet LA-03Clearing and Grading
Plan Sheet GR-01; Site and Road Cross Sections Sheet GR-02; Truck Movement Study Sheets
DT-01 & DT-02, and Tree/Vegetation Retention Plan Sheet TR-01, ESM Consulting
Engineers LLC, June 18, 2018
24. IRG Greenline Buildings A and B Federal Way, WA Transportation Impact Study, TENW
Transportation Engineering NorthWest, March 6, 2018
25. Preapplication Conference Summary, City of Federal Way, September 8, 2017
26. Master Land Use Application, received September 1, 2017
27. Greenline Warehouse `B" Process III/IV Application With SEPA, ESM Consulting Engineers
LLC, September 1, 2017
28. Site Photographs, received September 1, 2017
29. Geotechnical Engineering Services Report Weyerhaeuser Way South, 320th Street to SR 18
Weyerhaeuser Campus Property Federal Way, Washington, GeoEngineers, August 29, 2017
30. Tree Counts on the Two 16-Acre Parcels..., Gilles Consulting, revised August 24, 2017
31. My Credentials, Gilles Consulting, August 23, 2017
32. Title Report Guarantee/Certificate No. 0105928-16, Chicago Title Insurance Company,
August 8, 2017
33. Water Certificate of Availability, Lakehaven Utility District, August 4, 2017
34. Sewer Certificate of Availability, Lakehaven Utility District, August 4, 2017
III. ENVIRONMENTAL CHECKLIST
The following lists the elements of the environmental checklist (Exhibit C) and a response to each:
1. Whether city staff concurs with the applicant's response to the checklist item, or
2. City staff s additional comments or clarification to each checklist item.
A. BACKGROUND
The project development application was submitted June 17, 2016, with subsequent submittals
made on September 1, 2017, September 11, 2017, and September 29, 2017. It was determined to
be a complete application on September 29, 2017. Subsequent submittals were made on June 28,
2018, July 10, 2018, August 15, 2018, September 18, 2018, October 9, 2018, February 12, 2019,
and July 30, 2020.
Following are staff s comments on the August 10, 2018, checklist (resubmitted August 15, 2018):
1. In a February 8, 2019, letter the applicant requested that the Greenline Warehouse "B" project
now be referred to as Woodbridge Building "B." They are the same project and any reference
to Greenline Warehouse "B" should be considered as a reference to Woodbridge Building "B."
2-7. Concur with the checklist.
Staff Evaluation for Environmental Checklist Page 3 of 11
Woodbridge Building `B" 17-104237-SE / Doc ID 80803
See the list above in Section II for additional environmental information that has been
prepared related to the proposal.
Concur with the checklist.
10. A building permit is required.
11. There are 245 parking spaces proposed.
12. Concur with checklist.
B. ENVIRONMENTAL ELEMENTS
1. Earth
a.-h. Potential impacts will be mitigated through compliance with the 1994 city code
requirements, KCSWDM, and BMPs. Compliance with local, state, and federal
standards will provide sufficient mitigation of potential erosion impacts. Concur with
the checklist.
2. Air
a.-b. Concur with the checklist.
C. The applicant was requested to provide information related to emissions associated with
the operation of the facility, and a detailed study by a qualified expert about the effect of
particulate matter from diesel trucks on the environment and on downwind properties.
The applicant submitted an air quality report ("Greenline Building `B" Development,
Federal Way Washington Air Quality Report," Ramboll Environ, June 2018) that
concluded, "At the time of this analysis, the exact use of the warehouse had not been
established. However it is anticipated that the warehouse will be used for general
commodities that do not require cold storage. Furthermore, the warehouse will not
include processing or manufacturing facilities. Sources of air pollution typical of a
general commodities warehouse include emergency generators and vehicles used by
employee commuter trips and truck deliveries." A condition will require the air quality
analysis to be revised and the SEPA threshold determination revisited if the proposed
use of the building includes cold storage, processing, or manufacturing.
The report also states, "With implementation of required measures to provide
reasonable controls of dust and odors, construction of the proposed project would not
be expected to result in significant air quality impacts."
Regarding air quality impacts during construction, the report states:
"The following is a list of possible mitigation measures that could be implemented
to reduce potential air quality impacts during construction of the project.
• Use only equipment and trucks that are maintained in optimal operational
condition
Staff Evaluation for Environmental Checklist Page 4 of 11
Woodbridge Building `B" 17-104237-SE / Doc ID 80803
• Require all off road equipment to be retrofit with emission reduction equipment
(i.e., require participation in Puget Sound region Diesel Solutions by project
sponsors and contractors), including particulate matter traps and oxidation
catalysts to reduce MSATs
• Use biodiesel or other lower -emission fuels for vehicles and equipment
• Use carpooling or other trip reduction strategies for construction workers when
possible
• Stage construction to minimize overall transportation system congestion and
delays to reduce regional emissions of pollutants during construction
• Implement restrictions on construction truck idling (e.g., limit idling to a
maximum of 5 minutes)
• Locate construction equipment away from sensitive receptors such as fresh air
intakes to buildings, air conditioners, and sensitive populations
• Locate construction staging zones where diesel emissions won't be noticeable
to the public or near sensitive populations such as the elderly and the young
• Spray exposed soil with water or other suppressant to reduce emissions of PMIo
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 PMIo emissions and deposition during transport
• Provide wheel washers to remove particulate matter that would otherwise be
carried off site by vehicles to decrease deposition of particulate matter on area
roadways
• Remove particulate matter deposited on paved, public roads, sidewalks, and
bicycle and pedestrian paths to reduce mud and dust; sweep and wash streets
continuously to reduce emissions
• Cover dirt, gravel, and debris piles as needed to reduce dust and wind blown
debris
• Route and schedule construction trucks to reduce delays to traffic during peak
travel times to reduce air quality impacts caused by a reduction in traffic speeds"
A condition will implement the above listed items. Regarding operation of the project,
the report states, "The analyses described above indicate the proposed project would be
unlikely to result in any significant adverse air quality impacts. Consequently, no
operational mitigation measures are warranted or proposed."
Mitigation measures related to air are contained within the MDNS conditions. Federal
Way Comprehensive Plan (FWCP) policies cited in the MDNS provide the basis and
authority for the mitigation conditions.
3. Water
a. Surface
1. Concur with the checklist.
Staff Evaluation for Environmental Checklist Page 5 of 11
Woodbridge Building `B" 17-104237-SE / Doc ID 80803
2. According to submitted project materials, 9,922 square feet of direct impact (fill) to
wetlands are proposed. Wetland DQ will not be impacted.
3-6.Concur with the checklist.
b. Ground
1-2. Concur with the checklist.
C. Water Runoff
1-3. Concur with the checklist.
d. Final review of the stormwater quality and detention will occur in conjunction with the
final engineering plan review. Compliance with local, state, and federal standards will
sufficiently mitigate stormwater impacts from the project.
4. Plants
a. Concur with the checklist.
b. Two wetlands and adjacent buffers will remain.
C. Concur with the checklist.
d. To clarify, buffer enhancement of native plants could only be allowed within averaged
buffer replacement areas based upon the application that has been submitted. A
landscape plan in accordance with the 1994 Federal Way City Code (FWCC) 22-1563 is
required for this project. In addition, compliance with the significant tree standards of
FWCC 22-1568, is required. A preliminary landscape and tree and vegetation retention
plan has been submitted in conjunction with the application. Final review and approval
of the required landscaping plan will occur as part of the building permit approval.
e. Concur with checklist.
5. Animals
a-e. Concur with the checklist.
6. Energy and Natural Resources
a. Concur with the checklist.
b. The proposal is for a 45-foot-tall building.
C. Concur with the checklist.
7. Environmental Health
a. 1-5. Concur with the checklist.
Staff Evaluation for Environmental Checklist Page 6 of 11
Woodbridge Building `B" 17-104237-SE / Doc ID 80803
b. 1-2. Concur with the checklist.
b. 3. The applicant was requested to provide a noise report prepared by a qualified expert to
verify that the noise generated by the site operation would not exceed the city's
thresholds for noise set forth in FWRC 7.10. The applicant submitted an
environmental noise report ("Greenline Building `B" Development, Federal Way
Washington Environmental Noise Report," Ramboll Environ, July 2018) that
concluded, "The assessment found that operation of the proposed Project would result
in acoustically negligible increases in ambient noise at nearby residential receivers,
and between no increase and very minor increases at nearby commercial receivers.
The proposed Project would be within compliance of applicable noise limits at all
nearby residential and commercial receivers. An evaluation of the actual facility
design, once submitted, should be completed to ensure that the types and numbers of
equipment to be installed at the warehouse, as well as warehouse activities, are
consistent or similar to those identified in this report." This shall be made a condition.
Regarding construction related noise, the report states, "The following may help to
reduce the potential for high levels of noise from construction equipment or
activities, as may be received at existing noise -sensitive land uses, and therefore
would help to reduce the potential for perceived impact:
• Require that all equipment be fitted with properly sized mufflers, and if
necessary, engine intake silencers
• Require that all equipment be in good working order
• Use quieter construction equipment models if available, and whenever possible
use pneumatic tools rather than diesel or gas -powered tools.
• Place portable stationary equipment as far as possible from existing residential
and noise -sensitive commercial areas, and if necessary, place temporary
barriers around stationary equipment.
• For mobile equipment, consider replacing typical pure -tone backup alarms with
ambient -sensing and/or broadband backup alarms."
Regarding operation of the project, the report states, "Noise mitigation measures are
not warranted at this time." Under the conclusions section it states, "A detailed
review of final operating conditions should be completed to ensure that this noise
study accurately and conservatively reflects future Project operation." Conditions
will implement the above listed items.
Mitigation measures related to noise are contained within MDNS conditions. FWCP
policies cited in the MDNS provide the basis and authority for the mitigation
conditions.
8. Land and Shoreline Use
a-g. Concur with the checklist.
h. Stream EA is also present on the property.
i-m. Concur with the checklist.
Staff Evaluation for Environmental Checklist Page 7 of 11
Woodbridge Building `B" 17-104237-SE / Doc ID 80803
9. Housing
a-c. Concur with the checklist.
10. Aesthetics
a. Concur with the checklist.
b. Additional views altered include from Weyerhaeuser Way South on the overpass over
SR-18 and from the eastbound SR-18 exit. Additional details can be found in the
August 10, 2018, Visual Impact Analysis.
c. References to "Type III" landscaping should be Type I and Type II, per the submitted
landscaping plan.
11. Light and Glare
a-d. Concur with the checklist.
12. Recreation
a-c. Concur with the checklist.
13. Historic and Cultural Preservation
a. The Washington State Department of Archaeology and Historic Preservation has
determined that the Weyerhaeuser Headquarters would qualify for listing on the
National Register of Historic Places.
b. See the memorandum prepared by Cardno.
c-d. Concur with checklist.
14. Transportation
a. Concur with the checklist.
b. Concur with the checklist.
C. Two separate questions are shown in the checklist for item "c."
Staff response to the first question: Concur with the checklist.
Staff response to the second question: Frontage improvements and right-of-way
dedication consistent with the street modification decision are required (city file no. 18-
102212-SM). Prior to engineering plans approval, WSDOT approval of the traffic
study and channelization plans shall be provided.
Staff Evaluation for Environmental Checklist Page 8 of 11
Woodbridge Building `B" 17-104237-SE / Doc ID 80803
Prior to issuance of the Certificate of Occupancy, the applicant shall construct a
northbound left -turn lane on Weyerhaeuser Way South at the southerly driveway (truck
access) to provide safer and more efficient access into the site. The northbound left -turn
(NBL) lane storage shall be designed to accommodate the 95t1i Percentile queues length,
ensuring left -turn queues will not block through traffic lane. The channelization plan
must be reviewed and approved by the city and WSDOT.
Prior to building permit issuance, the applicant shall install weight limit signs on
Weyerhaeuser Way South from South 320th Street to the project driveway, and South
336th Street from 20th Avenue South to Weyerhaeuser Way South.
The applicant submitted a traffic study, IRG Greenline Buildings A and B Federal Way,
WA Transportation Impact Study, TENW Transportation Engineering NorthWest,
March 6, 2018. The development is estimated to generate 954 daily trips with 97 trips
occurring during the PM peak hour (78 passenger and 19 truck). These trips will be
served by two driveways (private loop road driveway north of the site and truck access
driveway next to SR 18) on Weyerhaeuser Way South. According to the traffic study, all
truck trips would utilize the proposed truck access driveway on Weyerhaeuser Way
South and will be traveling to and from the south using the Weyerhaeuser Way South/
SR-18 interchange. On a daily basis, I-5 souhbound congestion routinely occurs
between the SR 18 and South 320th Street interchange. In order to avoid traffic
congestion and reduce travel time due to shorter distance, truck trips with origin and
destination from the north could utilize South 320th Street/SR-5 interchange, South 336th
Street, and Weyerhaeuser Way South as an alternate route to the site. The traffic study
has not demonstrated how the applicant will prevent this alternative truck route (South
320th Street /SR-5 interchange, South 336th Street, and Weyerhaeuser Way South) to the
site. Weyerhaeuser Way South from South 320th Street and SR 18 is not a designated
truck route and therefore, the roadway cannot support heavy vehicle weights. In general,
heavier vehicles cause more damaged to the road than light vehicles. The federal
government estimated that an 18-wheel truck causes the same damage to the road as
9,600 cars. Based on the above, the applicant has not demonstrated mitigation of
additional truck traffic onto non -designated truck routes, such as Weyerhaeuser Way
South north of the site, including impacts to the pavement.
As such, prior to the Certificate of Occupancy issuance, the applicant shall provide a
fully executed bond for 120 percent of the engineer's estimate for design and
construction costs to upgrade the existing pavement on Weyerhaeuser Way South, from
the proposed truck entrance to South 320th Street. The bond term shall be for a period
of three years from the time of notification by the applicant of full occupancy and use
of the facility, unless a shorter term is mutually agreed to in the implementation
agreement discussed below. The applicant shall provide the engineer's estimate.
Should the truck trips generated by the project traveling north of the site (to or from the
site) exceed 28 truck trips per week as set forth in the implementation agreement
discussed below, the city will use the bond for design and construction costs to upgrade
the existing pavement on Weyerhaeuser Way South, from the proposed truck entrance
to South 320th Street, and/or from the proposed truck entrance to SR-99 via South 336th
Street, to the city's required design standards. In the alternative, the applicant may
Staff Evaluation for Environmental Checklist Page 9 of 11
Woodbridge Building `B" 17-104237-SE / Doc ID 80803
choose to design and construct the implicated roadway(s) identified by the city. For the
purposes of this condition, a "truck" shall mean a vehicle rated in excess of 30,000
pounds gross weight as discussed in Chapter 8.40 FWRC.
Prior to building permit issuance, the applicant and the city shall enter into an
implementation agreement to set forth the conditions by which the city will monitor the
truck trips; how the city will make its determination that the applicant has exceeded the
28 or more truck trips per week; how notice will be provided to the applicant; the cure
period for the applicant to remedy the excess truck trips described in the above condition;
when the city will call the bond or require the applicant to construct the implicated
roadways; the bond conditions; and all other requirements deemed necessary by the city.
The existing pavement on Weyerhaeuser Way South, south of the site, from the
proposed truck entrance to the SR-18 interchange must be fully reconstructed (subgrade
soils and new pavement) to accommodate the expected truck traffic load. The applicant
shall provide pavement design for city review and approval prior to engineering plans
submittal. Once the pavement design is approved by the city, the development shall
perform full depth reconstruction of the roadway segment impacted by the truck traffic.
The SR-18 ramp terminal intersections are under Washington State Department of
Transportation (WSDOT) control and are subject to WSDOT's established standards.
The traffic study prepared by TENW for Woodbridge Building "A" (formerly Greenline
Warehouse "A") was revised to address WSDOT comments pertaining to LOS and
queuing analysis at the SR-18 ramp terminal intersections. After the MDNS for
Woodbridge Building "A" was issued, WSDOT identified and requested mitigation for
the westbound SR-18 off -ramp right -turn storage. Due to additional trips generated by
the project impacting this intersection, the 95 h Percentile queues length for the AM peak
hour would exceed the available right -turn storage. As such, WSDOT requested that the
westbound SR-18 off -ramp right -turn storage be extended from the existing 100 feet to
300 feet. A Modified MDNS was issued for Woodbridge Building "A" to include that
mitigation measure. WSDOT confirmed in May 2019 that they reviewed the traffic
study for both Warehouses "A" and `B" and the mitigation was for both Warehouses
"A" and `B." The mitigation measure regarding the SR-18 off -ramp right -turn storage
applies to the Woodbridge Building `B."
Conditions will implement the above listed items.
Mitigation measures related to traffic are contained within MDNS conditions.
FWCP policies cited in the MDNS provide the basis and authority for the mitigation
conditions.
d-e. Concur with the checklist.
g. See response in 14(c), above. In addition, in accordance with the October 29, 2019,
Hearing Examiner's Request for Reconsideration Decision for Greenline Warehouse
"A," the following shall be made a SEPA mitigation measure:
Staff Evaluation for Environmental Checklist Page 10 of 11
Woodbridge Building `B" 17-104237-SE / Doc ID 80803
Cumulative traffic impacts from Warehouses "A" and `B," and the Greenline
Business Park, to the SR 18 westbound ramp intersection with Weyerhaeuser Way
South shall be evaluated and mitigated in a SEPA analysis addendum, and/or
revision to the Warehouses "A" and `B" TIA. PM peak hour cumulative impacts
shall be included in the TIA analysis, or added to the concurrency review for
Warehouse "A" as the city finds most consistent with its regulations. The city shall
determine if WSDOT has jurisdiction over the SR 18 intersection. If WSDOT has
jurisdiction over the SR 18 intersection, WSDOT LOS standards shall be applied to
the intersection and any necessary pro-rata mitigation for Warehouse "A" shall be
formulated in consultation with WSDOT as contemplated in Conclusion of Law
No. 8 of the Final Decision. If WSDOT doesn't have jurisdiction over the
intersection, city LOS standards shall be applied and pro-rata mitigation for
Warehouse "A" imposed as necessary. All mitigation shall be subject to RCW
82.02.020 and constitutional nexus/proportionality.
15. Public Services
a-b. Concur with the checklist.
16. Utilities
a-b. Concur with the checklist.
IV. CONCLUSION
The proposal can be found to not have a probable significant adverse impact on the environment if
appropriate conditions are properly implemented pursuant to the MDNS. Conditions of the MDNS
are based upon impacts identified within the environmental checklist, project submittal documents,
and the above "Staff Evaluation for Environmental Checklist, File 17-104237-SE," and are
supported by plans, policies, and regulations formally adopted by Federal Way for the exercise of
substantive authority under SEPA to approve, condition, or deny proposed actions.
The city reserves the right to review any future revisions or alterations to the site, or to the proposal,
to determine the environmental significance or nonsignificance of the project.
Exhibit A — Reduced Scale Site Plan
Exhibit B — Vicinity Map
Exhibit C — Environmental Checklist
Prepared by: Principal Planner Stacey Welsh (253-835-2634, stacey.welshkcityoffederalway.co )
Date: October 1, 2020
Staff Evaluation for Environmental Checklist Page 11 of 11
Woodbridge Building `B" 17-104237-SE / Doc ID 80803
ADD 240' DEEP STORAGE, LEFT TURN
LANE AND CHANNELIZATION FINAL
DESIGN TO BE DETERMINED BY
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SHEET INDEX:
CIVIL PLANS
%- SHEET NO. DRAWING NO. DESCRIPTION
�- 1 ST-01 SITE PLAN
30TH AVENUE S. (PUBLIC RIGHT OF WAY) 2 EX-01 TOPOGRAPHIC SURVEY
3 LG-01 LEGEND
OFF —SITE R/W DEDICATION 4 SO-01 PRELIMINARY DRAINAGE, GRADING
AND RIGHT—OF—WAY PLAN
5 LA-01 PRELIMINARY LANDSCAPE PLAN
6 LA-02 LANDSCAPE DETAILS & NOTES
7 LA-03 FRONTAGE PLAN
8 GR-01 CLEARING & GRADING PLAN
9 GR-02 SITE & ROAD CROSS SECTIONS
10 DT-01 TRUCK MOVEMENT STUDY
11 DT-02 TRUCK MOVEMENT STUDY
12 TR-01 TREE/VEGETATION RETENTION PLAN
ARCHITECTURAL PLANS
SHEET NO. DESCRIPTION
A1.0 DESIGN BRIEF, EXTERIOR ELEVATIONS & PERSPECTIVES
A1.1 BUILDING ELEVATIONS
PROJECT STATISTICS:
SITE AREA: 738,493 S.F. (16.95 AC.)
CRITICAL AREAS, NON—EXEMPT = 53,627 S.F. (1.23 AC.)
OPEN SPACE: 0 S.F. (0 AC.)
AREA OF ON —SITE PUBLIC PURPOSE LANDS = 0 S.F.
NET SITE AREA = 684,866 S.F. (15.72 AC.)
SITE DATA:
PARCEL NO: 614260-0200
ZONING: CP-1
CONSTRUCTION: UNLIMITED
USE: WAREHOUSE AND OFFICE
WETLAND FILL AREA = 9,949 SF,
PARKING: 245 CAR STALLS (8 ADA ACCESSIBLE),
PARKING STALLS:
245 STANDARD=8.5'X18' (MIN)
AISLE WIDTH: 26' (TYP)
PROJECT CONTACTS:
CIVIL ENGINEER OWNER Z AGENT
ESM CONSULTING ENGINEERS FEDERAL WAY CAMPUS, LLC
LAURA BARTENHAGEN, PE, LEED AP TOM MESSMER
33400 8TH AVE S 8847 IMPERIAL HIGHWAY, SUITE H
SUITE #205 DOWNEY, CA 90242
FEDERAL WAY, WA 98003
(253) 838-6113
LANDSCAPE ARCHITECT
ESM CONSULTING ENGINEERS
LEANNE KUHLMAN
33400 8TH AVE S
SUITE #205
FEDERAL WAY, WA 98003
(253) 838-6113
GEOTECHNICAL ENGINEER
GEOENGINEERS
STEVE HELVEY
1101 FAWCETT AVE
SUITE #200
TACOMA, WA 98402
TYPICAL 8.5'x18' PARKING ARCHITECT
CRAFT ARCHITECTS PLLC
SCALE: 1 "=20'
CATHY
2505 3RD AVE,
SUITE #324
SEATTLE, WA 98121
(206) 720-7001
WETLAND CONSULTANTS
TALASAEA ASSOCIATES
BILL SHIELS / JENNIFER MARRIOTT
15050 BEAR CREEK RD NE
WOODINVILLE, WA 98077
(425) 861-7550
TRANSPORTATION ENGINEER
TENW
JEFF SCHRAMM
816 6TH ST S
KIRKLAND, WA 98033
(425) 250-0581
REVISIONS
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DWG. NAME ST-01
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DATE: 06/18/2018
ST-01
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EXHIBIT
CITY OF
Federal Way
Department of Community Development Services
33325 8ch Avenue South
RESUBMITTED Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
AUG 15 2018 www.cityoffederalway.com
CITY OF FEDERAL WAY
GOMMUN" DEVELOP'ME' T
SEPA ENVIRONMENTAL CHECKLIST QR.I&S .NAI_ T1I0I1T
Purpose of checklist:
Governmental agencies use this checklist to help determine whether the environmental impacts of your proposal are
significant. This information is also helpful to determine if available avoidance, minimization, or compensatory
mitigation measures will address the probable significant impacts, or if an environmental impact statement will be
prepared to further analyze the proposal.
Instructions for applicants: hjelp4
This environmental checklist asks you to describe some basic information about your proposal. Please answer each
question accurately and carefully, to the best of your knowledge. You may need to consult with an agency specialist or
private consultant for some questions. You may use "not applicable" or "does not apply" only whenyou can explain why it doer not
apply and not when the answer is unknown. You may also attach or incorporate by reference additional studies and/or reports.
Complete and accurate answers to these questions often avoid delays with the SEPA process, as well as later in the
decision -making process.
The checklist questions apply to all parts ofyourproposal, even if you plan to do them over a period of time or on different
parcels of land. Attach any additional information that will help describe your proposal or its environmental effects. The
agency to which you submit this checklist may ask you to explain your answers or provide additional information
reasonably related to determining if there may be significant adverse impact.
Instructions for Lead Agencies:
Additional information may be necessary to evaluate the existing environment, all interrelated aspects of the proposal,
and an analysis of adverse impacts. The checklist is considered the first, but not necessarily the only source of
information needed to make an adequate threshold determination. Once a threshold determination is made, the lead
agency is responsible for the completeness and accuracy of the checklist and other supporting documents.
Use of checklist for nonproject proposals: hel
For nonproject proposals (such as ordinances, regulations, plans, and programs), complete the applicable parts of
sections A and B, plus the SUPPI.I NII::NTAL Sl-li:l'',T IUlk NONPRC' 13C1' AC-FIONS 02art 17 . Please completely answer all
questions that apply and note that the words "project," "applicant," and "property or site" should be read as "proposal,"
"proponent," and "affected geographic area," respectively. The lead agency may exclude (for nonprojects) questions in
Part B (Environmental Elements) that do not contribute meaningfully to the analysis of the proposal.
Bulletin #050 — May 1, 2014 Page 1 of 14 k:\Handouts\Environmental Checklist May 2014
A. BACKGROUND hel W
1. Name of proposed project, if applicable: Iaelpj
Greenline Building "B"
2. Name of applicant: hel
Federal Way Campus, LLC
3. Address and phone number of applicant and contact person: hel
11100 Santa Monica Blvd, Suite 850
Los Angeles, CA 90025
310-261-4382
4. Date checklist prepared: hel
August 10, 2018
5. Agency requesting checklist: iel
City of Federal Way
6. Proposed timing or schedule (including phasing, if applicable): hel
Land Use Review and Approval 26 Weeks
Clear, Grade, and Underground 8 Weeks After Land Use Approval
Building Permit and Construction of Building 26 Weeks After Land Use Approval
7. Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal?
If yes, explain. VLelpj
There are no future additions to Building B. Right -of -Way dedications and improvements will occur as part
of the Building B development.
8. List any environmental information you know about that has been prepared, or will be prepared, directly related to
this proposal. VILIpI
■ Critical Areas Report for Federal Way Campus, LLC
• Managed Forest Buffer Management Plan
• Tree Evaluation Report
• Design Narrative and Building Elevations
• Geotechnical Report
• Pavement Analysis
• Level One Downstream storm drainage analysis pursuant to KCSWDM
• Preliminary Technical Information Report (TIR) addressing relevance of the 9 Core and 5 Special
Requirements of 2016 King County Surface Water Design Manual.
• Traffic Impact Analysis
• Environmental Noise Report
• Air Quality Technical Report
• Cultural Resource Analysis prepared by Tetra Tech
■ Visual Impact Analysis
9. Do you know whether applications are pending for governmental approvals of other proposals directly affecting the
property covered by your proposal? If yes, explain. gel
Section 404 U.S. Army Corps of Engineers
Bulletin #050 — May 1, 2014 Page 2 of 14 k:\Handouts\Environmental Checklist May 2014
10. List any government approvals or permits that will be needed for your proposal, if known. VLelp4
Section 404 U.S. Army Corps of Engineers, Commercial Grade & Fill City of Federal Way, SEPA Threshold
Determination, Process III Land Use Review, NPDES Construction Stormwater Discharge Permit, Land Surface
Modification Permit, Engineering Permit (EN) and Forest Practice Class -IV- General Application.
11. Give brief, complete description of your proposal, including the proposed uses and the size of the project and site.
There are several questions later in this checklist that ask you to describe certain aspects of your proposal. You do
not need to repeat those answers on this page. (Lead agencies may modify this form to include additional specific
information on project description.) VLelpj
The proposed Building "B" development is for the construction of a 214,050 square foot
Warehouse/Distribution Center located on a site of approximately 16.9 acres. In addition to the construction
of Building "B", there will be street improvements along the frontage of Weyerhaeuser Way South where
adequate Right -of -Way exists.
12. Location of the proposal. Give sufficient information for a person to understand the precise location of your
proposed project, including a street address, if any, and section, township, and range, if known. If a proposal would
occur over a range of area, provide the range or boundaries of the site(s). Provide a legal description, site plan,
vicinity map, and topographic map, if reasonably available. While you should submit any plans required by the
agency, you are not required to duplicate maps or detailed plans submitted with any permit applications related to
this checklist. iel
Future Site Address: 337XX Weyerhaeuser Way S, Federal Way, WA
Per King County Assessor's Data: 3120 S 344TH ST 98003
Located between Weyerhaeuser Way S and Weyerhaeuser Rd
NORTH LAKE ADD TO EAST TACOMA LOT 7 FEDERAL WAY BLA #17-100484-SU REC #20171103900001 SD BLA
BEING POR S 1/2 OF SE 1/416-21-4 & POR NW 1/4 & NE 1/4 & SE 1/4 & SW 1/4 21-21-4 & LOTS 1 THRU 8 BK
18 NORTH LAKE ADD TO EAST TACOMA & LOTS 8 & 10 THRU 15 & POR LOT 9 LOUISE'S NORTH LAKE TRACTS
TGW RDS ADJ
Parcel Number: 614260-0200
B. ENVIRONMENTAL ELEMENTS lielp
1. Earth
a. General description of the site RlelW
(underline/circle one): Flat, rolling, hilly, steep slopes, mountainous, other
Somewhat undulatory with a general downward slope to the east.
b. What is the steepest slope on the site (approximate percent slope)? hel
±15%
c. What general types of soils are found on the site (for example, clay, sand, gravel, peat, muck)? If you know the
classification of agricultural soils, specify them and note any agricultural land of long-term commercial
significance and whether the proposal results in removing any of these soils. VwIP4
Weathered (medium dense) glacial till and unweathered (dense to very dense) glacial till. Generally
silty sand with gravel.
d. Are there surface indications or history of unstable soils in the immediate vicinity? If so, describe. DLeI4
None
Bulletin #050 — May 1, 2014 Page 3 of 14 k:\Handouts\Environmental Checklist May 2014
e. Describe the purpose, type, total area, and approximate quantities and total affected area of any filling,
excavation, and grading proposed. Indicate source of fill. gel
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 may be imported for the building foundation. Native on -site
material will be used for general fill.
Approximate earthwork quantities:
Cut = 31,800 Cubic Yards
Fill= 55,400 Cubic Yards
Net: 23,600 Cubic Yards of Fill
Stripping=19,700 Cubic yards
Could erosion occur as a result of clearing, construction, or use? If so, generally describe. VILIPJ
Erosion could occur as a result of clearing and construction, particularly if earthwork is completed
during periods of rainfall. TESC measures will be implemented as approved by the City prior to
clearing and construction.
g. About what percent of the site will be covered with impervious surfaces after project construction (for example,
asphalt or buildings)? "el
Asphalt and building surface covers approximately 54.94% of the Building'B' site.
h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: h��
The owner will institute an erosion control plan to be used during earthwork and construction.
2. Air
a. What types of emissions to the air would result from the proposal during construction, operation, and
maintenance when the project is completed? If any, generally describe and give approximate quantities if known.
iel
Some heavy machinery exhaust and dust particulates generated primarily by construction equipment.
b. Are there any off -site sources of emissions or odor that may affect your proposal? If so, generally describe.
Zel
No
c. Proposed measures to reduce or control emissions or other impacts to air, if any: Riel.W
All construction equipment will be in proper working order and regulated for emissions by the
manufacturer and local emissions laws. Vehicles entering and leaving the site will also be regulated for
emissions by state and local emissions laws. During construction the site will be watered as necessary to
keep any dust from impacting surrounding air quality.
3. Water
a. Surface Water ael
1) Is there any surface water body on or in the immediate vicinity of the site (including year-round and
seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe type and provide names. If appropriate,
state what stream or river it flows into. hel
The following description includes both Building B and Building A project limits as they are in close
proximity to each other. Building A site is also considered in the immediate vicinity.
Bulletin #050 — May 1, 2014
Page 4 of 14 k:\Handouts\Environmental Checklist May 2014
There are no fish -bearing or perennial streams on or near the site. A man-made ephemeral ditch,
unnamed, connects Wetland EE to Wetland DR. An ephemeral stream (Stream EA) occurs in the
southeast portion of the project area. See attached Wetland report for more details. 13 on -site
wetlands occur within the project limits. Onsite Wetlands: DP (PFO), DQ (PSS), DR (PSS), DT (PSS),
DU (PSS), DW (PFO), DX (PFO), DZ (PFO), EB (PFO/PSS), EC (PFO), ED (PFO), EE (PSS), and EF (PFO).
All wetlands ultimately discharge to Hylebos Creek to the south.
2) Will the project require any work over, in, or adjacent to (within 200 feet) the described waters? If yes,
please describe and attach available plans. VLe1W
The following description includes both Building B and Building A project limits as they are in close
proximity to each other. Building A, under separate SEPA, will be constructed ahead of Building B.
Yes, work adjacent to the man-made ditch is proposed 9,949 square feet of proposed direct impacts
(fill) to wetlands DU, DW, DX, DZ, EB, ED, and EE. Indirect impacts will affect Wetlands DO, EC, and
EF. Wetlands DP, DR, and DT will not be impacted. Stream EA will not be impacted. See attached
work plans and report for more details.
3) Estimate the amount of fill and dredge material that would be placed in or removed from surface water or
wetlands and indicate the area of the site that would be affected. Indicate the source of fill material. el
The following description includes both Building B and Building A project limits as they are in close
proximity to each other. Building A, under separate SEPA, will be constructed ahead of Building B.
Total wetland fill to equal ±435 cubic yards.
Fill materials will be sourced from the project site.
The filling of these wetlands will have no long-term impacts on the surrounding hydrology. The
runoff from the Site in the post -development condition will be detained within the proposed
Stormwater pond to the south before being discharged under Highway 18. This path of water
movement will be the same in the post -development condition as from the pre -development
condition.
Wetland EE does currently drain to Wetland DR through a culvert and associated ditch that was
artificially constructed many years ago. That artificial connection between Wetlands EE and DR will
be removed in the post -development condition as previous City concerns regarding the Site's
stormwater discharges disallowed any site runoff to be conveyed to these remaining wetlands.
4) Will the proposal require surface water withdrawals or diversions? Give general description, purpose, and
approximate quantities if known. Ihel
No
5) Does the proposal he within a 100-year floodplain? If so, note the location on the site plan. hel
No
6 ) Does the proposal involve any discharges of waste materials to surface waters? If so, describe the type of
waste and anticipated volume of discharge. Raelpj
No
b. Ground Water
1) Will groundwater be withdrawn from a well for drinking water or other purposes? If so, give a general
description of the well, proposed uses, and approximate quantities withdrawn from the well. Will water be
discharged to groundwater? Give general description, purpose, and approximate quantities if known. iel
Bulletin #050 — May 1, 2014 Page 5 of 14 k:\Handouts\Environmental Checklist May 2014
No groundwater will be withdrawn from a well for drinking water or any other purpose.
2) Describe waste material that will be discharged into the ground from septic tanks or other sources, if any
(for example: domestic sewage; industrial containing the following chemicals...; agricultural; etc.). Describe
the general size of the system, the number of such systems, the number of houses to be served (if
applicable), or the number of animals or humans the system(s) are expected to serve. iel
No waste material will be discharged into the ground from septic tanks or other sources. See
subsection 3.0 for information for discharge of stormwater.
c. Water runoff (including stormwater):
1) Describe the source of runoff (including stormwater) and method of collection and disposal, if any (include
quantities, if known). Where will this water flow? Will this water flow into other waters? If so, describe.
hel
Run-off from impervious surfaces will be collected and directed into on -site stormwater detention
pond at the southern end of the site, shared with Building "A." Once detained and treated for water
quality, the storm water will be released to the downstream system, including the off -site wetlands.
2) Could waste materials enter ground or surface waters? If so, generally describe. Ihel
Not as proposed
3) Does the proposal alter or otherwise affect drainage patterns in the vicinity of the site? If so, describe.
No - discharge will occur at the natural location.
d. Proposed measures to reduce or control surface, ground, and runoff water, and drainage pattern impacts, if any:
The project contractors, users, and personnel will utilize onsite Best Management Practices. Attached
drainage plans show runoff from impervious surfaces will be directed to on site stormwater detention
pond.
4. Plants Raelpj
a. Check the types of vegetation found on the site: hel 0
X Deciduous tree: alder, maple, aspen, other
X Evergreen tree: fir, cedar, pine, other
X Shrubs
X Grass
pasture
crop or gram
orchards, vineyards, or other permanent crops
X Wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other
water plants: water lily, eelgrass, milfoil, other
other types of vegetation
b. What kind and amount of vegetation will be removed or altered? "el
Native
Native trees and shrubs will be removed during site construction. 7 of 13 on -site wetlands will be filled;
3 wetlands and adjacent buffers of native trees and shrubs will remain.
c. List threatened and endangered species known to be on or near the site. lielp
Bulletin #050 — May 1, 2014 Page 6 of 14 k:\Handouts\Environmental Checklist May 2014
No native threatened and endangered plant species observed or known to occur on or near the site.
d. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on the site, if
any. zel
Buffer enhancement of native plants will be done as needed.
e. List all noxious weeds and invasive species known to be on or near the site.
Himalayan blackberry, English ivy, English holly
5. Animals
a. List any birds and other animals which have been observed on or near the site, or are known to be on or near
the site. Examples include: iel
birds: hawk, heron, eagle, songbirds, other:
mammals: deer, bear, elk, beaver, other: rabbits, squirrels
fish: bass, salmon, trout, herring, shellfish, other: bass and perch
b. List any threatened and endangered species known to be on or near the site. DaelW
Bald Eagle nest documented ±1,500 feet east of site; none on -site.
c. Is the site part of a migration route? If so, explain. VLelpJ
The entire region is known to be part of the Pacific Flyway. The Pacific Flyway includes Alaska and the
Aleutian Islands and the Rocky Mountains and Pacific coast regions of Canada the United States and
Mexico, south to where it becomes blended with other flyways in Central and South America. However,
the site is not known to be used by migratory fowl.
d. Proposed measures to preserve or enhance wildlife, if any. VLe1W
Preservation of remaining wetlands and adjacent uplands - a corridor will be provided between
preserved wetlands and forested buffers will be provided along Weyerhaeuser Way S and Highway 18.
e. List any invasive animal species known to be on or near the site.
Bullfrog
6. Energy and Natural Resources
a. What kinds of energy (electric, natural gas, oil, wood stove, solar) will be used to meet the completed project's
energy needs? Describe whether it will be used for heating, manufacturing, etc. Ihel
Electrical energy will be the primary source of power serving the project. Natural gas maybe used to
satisfy incidental energy needs.
b. Would your project affect the potential use of solar energy by adjacent properties? If so, generally describe.
ael
No, the proposed building height will not exceed 42 feet above grade. No existing development utilizes
solar energy in proximity to which the shadow cast from the building has any effect.
c. What kinds of energy conservation features are included in the plans of this proposal? List other proposed
measures to reduce or control energy impacts, if any. iel
No plans included in the Commercial grade & Fill Permit. Energy conservation will be addressed in the
building permit documents.
Bulletin #050 — May 1, 2014
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7. Environmental Health
a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion,
spill, or hazardous waste that could occur as a result of this proposal? If so, describe. VILIPJ
None known.
1) Describe any known or possible contamination at the site from present or past uses.
None known.
2) Describe existing hazardous chemicals/conditions that might affect project development and design. This
includes underground hazardous liquid and gas transmission pipelines located within the project area and in
the vicinity.
None known.
3) Describe any toxic or hazardous chemicals that might be stored, used, or produced during the project's
development or construction, or at any time during the operating life of the project.
No toxic or hazardous chemicals are known to be stored on site.
4) Describe special emergency services that might be required.
None anticipated
5) Proposed measures to reduce or control environmental health hazards, if any.
State regulations regarding safety and the handling of hazardous materials will be followed during
the construction process. Equipment refueling areas would be located in areas where spill could be
quickly contained and where the risk of hazardous materials entering surface water is minimized.
b. Noise
1) What types of noise exist in the area which may affect your project (for example: traffic, equipment,
operation, other)? VLe1W
The primary source of noise near the project site is from vehicular traffic along Weyerhaeuser Way S
and Hwy-18. It is not anticipated to materially impact the proposed project in any way.
2) What types and levels of noise would be created by or associated with the project on a short-term or a long-
term basis (for example: traffic, construction, operation, other)? Indicate what hours noise would come
from the site. VLelo
Short-term impacts would result from the use of construction equipment during the site
development. Construction would occur during permitted construction hours and always in
compliance with the City of Federal Way noise regulations. Long-term impacts would be those
vehicular trips associated with the Building. Noise generated from the proposed Building and office
operations is not expected to impact surrounding properties.
3) Proposed measures to reduce or control noise impacts, if any: VLe1W
Construction activity will be limited to permitted construction hours and construction equipment
will not be allowed to idle for continuous periods of time, which will help mitigate the impacts of
potential construction noise.
8. Land and Shoreline Use
a. What is the current use of the site and adjacent properties? Will the proposal affect current land uses on nearby
or adjacent properties? If so, describe. iel
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The property is zoned as Corporate Park but the project site is primarily vacant with small areas used for
landscape material storage. Pedestrian trails meander through the site.
North- Proposed BUILDING A Development
East- Office
West- Corporate Park
South- Corporate Park/Highway
The proposed development may have a minor impact with respect to the additional traffic of deliveries
and employee trips.
b. Has the project site been used as working farmlands or working forest lands? If so, describe. How much
agricultural or forest land of long-term commercial significance will be converted to other uses as a result of the
proposal, if any? If resource lands have not been designated, how many acres in farmland or forest land tax
status will be converted to nonfarm or nonforest use? iel
No
1) Will the proposal affect or be affected by surrounding working farm or forest land normal business
operations, such as oversize equipment access, the application of pesticides, tilling, and harvesting? If so,
how.
No impact.
The site exists on land previously owned by Weyerhaeuser Company and used for corporate
headquarters for many years.
c. Describe any structures on the site. hel
None
d. Will any structures be demolished? If so, what? el
No
e. What is the current zoning classification of the site? liel
Corporate Park- 1(CP-1)
f. What is the current comprehensive plan designation of the site? hel
Corporate Park
g. If applicable, what is the current shoreline master program designation of the site? V1614
N/A
h. Has any part of the site been classified as a critical area by the city or county? If so, specify. Vidw
Yes, site reconnaissance conducted by Talasaea resulted in discovery of 13 wetlands on the proposed
project site. A copy of the wetland delineation report was submitted with this environmental checklist
and is available upon request.
i. Approximately how many people would reside or work in the completed project? hel
Approximately 245 people would work at the completed project
j. Approximately how many people would the completed project displace? iel
None
k. Proposed measures to avoid or reduce displacement impacts, if any. hel
N/A
Bulletin #050 — May 1, 2014 Page 9 of 14 k:\Handouts\Environmental Checklist May 2014
1. Proposed measures to ensure the proposal is compatible with existing and projected land uses and plans, if any.
hel'
The project will be developed in accordance with applicable City of Federal Way development and land
use codes and the approved Annexation and Concomitant Agreement to ensure the project is consistent
with the goals and policies of the Comprehensive Plan and applicable Development Regulations.
m. Proposed measures to ensure the proposal is compatible with nearby agricultural and forest lands of long-term
commercial significance, if any.
None proposed
9. Housing
a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low-income
housing. VLelp
N/A
b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low-income
housing. aaelW
N/A
c. Proposed measures to reduce or control housing impacts, if any. DaelW
N/A
10. Aesthetics
a. What is the tallest height of any proposed structure(s), not including antennas; what is the principal exterior
building material(s) proposed? Ihel
The tallest structure on this property will be the Building at 45 feet above adjacent grade. The principal
exterior building material will be painted concrete panel. Additional details can be found in the provided
Building Elevations or the Visual Impact Analysis dated August 10, 2018.
b. What views in the immediate vicinity would be altered or obstructed? Zel
Currently forested. Views impacted would be viewing SW from 33d PI S, viewing West from East Campus
parking lot. There is a 50' forested buffer that runs along Weyerhaeuser Way S and a 100' forested
buffer along Highway 18. A visual impact analysis is provided which shows minimal visibility of the
building behind the managed forest buffer.
c. Proposed measures to reduce or control aesthetic impacts, if any. iel
Maintain required 50' managed forest buffer along Weyerhaeuser Way S and the required 100'
managed forest buffer along State Route 18. Supplement sparse vegetation in the managed forest
buffer with Type III landscape screen planting plan as well as Type III landscape screen planting in
undisturbed areas of the project property. Type III landscape screen regulated by the City of Federal
Way provides a solid sight obscuring landscape screen. Although, it will take some time for plants to
mature and fill out the gaps, the applicant is confident that the additional planting of vegetation will
mitigate visual impacts.
Furthermore, the applicant will incorporate exterior building materials that compliment the surrounding
character as shown in the building elevations and Visual impact Analysis. The applicant has voluntarily
incorporated design elements found in FWRC 19.115, although not required by the 1994 Weyerhaeuser
Pre- Annexation and Concomitant Agreement.
11. Light and Glare
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Page 10 of 14 k:\Handouts\Environmental Checklist May 2014
a. What type of light or glare will the proposal produce? What time of day would it mainly occur? aaelpj
Parking lot lighting would occur dusk through dawn at completed project. Minimal glare would occur
from sunlight reflected off parked cars. Additionally, the headlights of traveling vehicles would occur
any time of day.
b. Could light or glare from the finished project be a safety hazard or interfere with views? hel
No
c. What existing off -site sources of light or glare may affect your proposal? hel
None
d. Proposed measures to reduce or control light and glare impacts, if any.
The managed forest buffer running adjacent to Weyerhaeuser Way S and Highway 18 along the property
would diffuse and mitigate impacts from glare sources from either side of the buffer.
12. Recreation
a. What designated and informal recreational opportunities are in the immediate vicinity? hel
Informal pedestrian hiking trails meander throughout the immediate vicinity. Please note that these
trails are located on private property and no right has been conveyed to the public for their continued
use.
b. Would the proposed project displace any existing recreational uses? If so, describe. VLe14
Yes, the informal trails will be removed through the site by the proposed development; however,
pedestrian connections will remain around the site.
c. Proposed measures to reduce or control impacts on recreation, including recreation opportunities to be
provided by the project or applicant, if any. VILIpI
A continuous sidewalk will eventually be installed along Weyerhaeuser Way S which will provide for
formal pedestrian connectivity to the north.
13. Historic and cultural preservation
a. Are there any buildings, structures, or sites, located on or near the site that are over 45 years old listed in or
eligible for listing in national, state, or local preservation registers located on or near the site? If so, specifically
describe. hel
Yes, the Weyerhaeuser Headquarters building was constructed in 1969. Pursuant to CFR 36, Chapter I,
subsection 60.4 criteria for evaluation, the Weyerhaeuser Headquarters building may be eligible.
However, the Weyerhaeuser Headquarters is not currently listed in national, state, or local preservation
registers.
b. Are there any landmarks, features, or other evidence of Indian or historic use or occupation? This may include
human burials or old cemeteries. Are there any material evidence, artifacts, or areas of cultural importance on or
near the site? Please list any professional studies conducted at the site to identify such resources. VLe1W
No known landmarks or evidence have been observed on or near the site.
c. Describe the methods used to assess the potential impacts to cultural and historic resources on or near the
project site. Examples include consultation with tribes and the department of archeology and historic
preservation, archaeological surveys, historic maps, GIS data, etc. iel
The methods used to assess the potential impacts included GIS data analysis and WISAARD GIS data
review. More information in Cultural Analysis Report prepared by Tetra Tech.
Bulletin #050 — May 1, 2014
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d. Proposed measures to avoid, minimize, or compensate for loss, changes to, and disturbance to resources. Please
include plans for the above and any permits that may be required.
If any such historic or cultural evidence is encountered during construction or installation of
improvements, work will be halted in the area and a state -approved archeologist/historian will be
engaged to investigate, evaluate and/or move or curate such resources, as appropriate.
14. Transportation
a. Identify public streets and highways serving the site or affected geographic area and describe proposed access to
the existing street system. Show on site plans, if any. VLel
The project site is primarily served by Weyerhaeuser Way S, north of Highway 18. Passenger vehicle
access off of the existing Loop Road is proposed at the southwest corner of the site. Delivery truck and
tractor trailer access is provided at the northeast corner of the site, shared with proposed Building A,
closest to the Highway 18 interchange.
b. Is the site or affected geographic area currently served by public transit? If so, generally describe. If not, what is
the approximate distance to the nearest transit stop? iel
Yes, the site is serviced by Pierce County Transit route 501 with 2 stops along the property frontage of
proposed Building A on Weyerhaeuser Way S.
c. How many additional parking spaces would the completed project or non -project proposal have? How many
would the project or proposal eliminate? hel
The proposed project will add 245 car stalls.
Will the proposal require any new or improvements to existing roads, streets, pedestrian, bicycle, or state
transportation facilities, not including driveways? If so, generally describe (indicate whether public or private).
hel
Yes, frontage improvements and right-of-way dedication consistent with the arterial/collector section G
and pavement along Weyerhaeuser Way will be upgraded to accommodate truck traffic.
d. Will the project or proposal use (or occur in the immediate vicinity of) water, rail, or air transportation? If so,
generally describe. Jbf1W
Not expected.
e. How many vehicular trips per day would be generated by the completed project or proposal? If known, indicate
when peak volumes would occur and what percentage of the volume would be trucks (such as commercial and
non -passenger vehicles). What data or transportation models were used to make these estimates? gel
It is estimated that approximately 78 new pm peak hour trips will be generated by this project.
Daily Passenger Vehicle Trips will be 763
Daily Truck Trips will be 191
Total Daily Trips (Passenger and Truck) will be 954
More information can be found in the Traffic Impact Analysis, dated March 6, 2018.
f. Will the proposal interfere with, affect, or be affected by the movement of agricultural and forest products on
roads or streets in the area? If so, generally describe.
Not expected.
g. Proposed measures to reduce or control transportation impacts, if any. help
Payment of the City's transportation impact fee is expected, which will help fund City-wide
transportation improvements. Signage and proper education will be utilized to deter trucks from going
Bulletin #050 — May 1, 2014 Page 12 of 14 k:\Handouts\Environmental Checklist May 2014
past the designated truck entrance on Weyerhaeuser Way S, heading northbound toward 320th St.
Modifications to existing northbound center left -turn lane are described in the recent TIA. Furthermore,
the City is requesting full width street frontage improvements along Weyerhaeuser Way S parallel to the
Building A and B properties.
15. Public services
a. Would the project result in an increased need for public services (for example: fire protection, police protection,
public transit, health care, schools, other)? If so, generally describe. help
The completed Building facility would result in a slight increased need for public services to include fire
protection, police protection, and health care.
b. Proposed measures to reduce or control direct impacts on public services, if any. VLOW
The increased demand will be offset by impact fees, levies, and taxes required to be paid by the
applicant as part of this development. Also the proposal has been designed in a manner that will provide
adequate access for fire, medic, and police vehicles.
16. Utilities
a. Underline/circle utilities currently available at the site: iel
electricity,natural gas, water, refuse service telephone, sanitary sewer, septic system, other
The above listed utilities are either available on -site or will be extended as necessary to serve the site.
b. Describe the utilities that are proposed for the project, the utility providing the service, and the general
construction activities on the site or in the immediate vicinity which might be needed. Tel
Lakehaven Utility District will provide water and sewer connection.
Puget Sound Energy will supply electricity and gas
Telephone: Century Link, Verizon, Comcast
Fire Protection: South King Fire & Rescue
C. SIGNATURE HELP
The above answers are true and complete to the best of my knowledge. I understand that the lead agency is relying on
them to make its decision.
1Z'111z'ff"g"
t
Signature:
Printed Name of Signee: PA44
Position and Agency/Organization: �� P L
Date Submitted: xv
Bulletin #050 — May 1, 2014 Page 13 of 14 k:\Handouts\Environmental Checklist May 2014
Stacey Welsh
From: Julie Beffa <j.e.beffa@gmail.com>
Sent: Friday, October 9, 2020 7:41 PM
To: Ping Inquiry
Subject: Re: Notice of Mitigated Determination of Nonsignificance (MDNS)
[EXTERNAL EMAIL WARNING]
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this email please contact IT Help Desk at x2555.
Very very disappointing.
So sorry you did not see the negative environmental effects that this will cause.
So shortsided of the city and truly an abrogation of your duty to protect your citizens.
Julie Beffa
On Fri, Oct 9, 2020 at 1:52 PM City of Federal Way <newsletter@cityoffederalway.com> wrote:
I Ij 1�fT�I�Pl
Notice of Environmental Mitigated Determination
of Nonsignificance (MDNS)
Woodbridge Building "B" (formerly Greenline Warehouse "B")
File No: 17-104237-SE
Project Files
J The City of Federal Way has determined that
the following project does not have a probable
significant adverse impact on the environment,
provided the mitigation measures identified in the MDNS are met, and an
Environmental Impact Statement (EIS) is not required under RCW
43.21 C.030(2)(c). This decision was made after review of a completed
environmental checklist and other information on file with the city. This information
is available to the public by request or on the city website:
https://www.citVoffederalwaV.com/node/l 962.
Proposed Action: Construction of a 45-foot-tall, 214,050 square -foot general
commodity warehouse with 245 parking spaces, and associated site work,
including wetland fill, on a 16.85-acre site (parcel 6142600200), along with
improvements to the right-of-way of Weyerhaeuser Way South.
Proponent: Federal Way Campus LLC, 11100 Santa Monica Blvd, Suite 850,
Los Angeles, CA 90025
Location: 3120 South 344th Street, Federal Way, WA
Lead Agency: City of Federal Way
Mitigation Measures (Summary):
1) Prior to building permit issuance, the applicant shall submit an evaluation of the
facility design by a qualified professional to ensure that the types and numbers of
equipment to be installed at the warehouse, as well as warehouse activities, are
consistent or similar to those identified in the noise report (Greenline Building `B"
Development, Federal Way Washington Environmental Noise Report, Ramboll
Environ, July 2018).
2) The following measures shall be implemented during project construction, with
quarterly reports submitted by the applicant to the city documenting compliance
starting from the issuance of the building permit and concluding at issuance of a
Certificate of Occupancy:
a) All equipment shall be fitted with properly sized mufflers, and if necessary,
engine intake silencers.
b) All equipment shall be in good working order.
c) Use quieter construction equipment models if available, and whenever possible,
use pneumatic tools rather than diesel or gas -powered tools.
d) Place portable stationary equipment as far as possible from the existing
residential and noise -sensitive commercial areas, and if necessary, place
temporary barriers around stationary equipment.
e) For mobile equipment, consider placement of typical fixed pure -tone backup
alarms with ambient -sensing and/or broadband backup alarms.
3) A detailed review of final operating conditions shall be completed to ensure that
the noise study accurately and conservatively reflects future project operation. A
report documenting the assessment shall be submitted to the city six months after
the Certificate of Occupancy is issued.
4) If the proposed use of the building includes cold storage, processing, or
manufacturing, the air quality analysis (Greenline Building `B" Development,
Federal Way Washington Air Quality Report, Ramboll Environ, June 2018) must
be revised and the SEPA threshold determination revisited prior to building permit
issuance, or if no building permit is required, then prior to business license
issuance.
5) The following measures shall be implemented during project construction, with
quarterly reports submitted by the applicant to the city documenting compliance
starting from the issuance of the building permit and concluding at issuance of the
Certificate of Occupancy:
a) Use only equipment and trucks that are maintained in optimal operational
condition.
b) Require all off road equipment to be retrofit with emission reduction equipment
(i.e., require participation in Puget Sound Region Diesel Solutions by project
sponsors and contractors), including particulate matter traps and oxidation
catalysts to reduce MSATs.
c) Use biodiesel or other lower -emission fuels for vehicles and equipment.
d) Use carpooling or other trip reduction strategies for construction workers when
possible.
e) Stage construction to minimize the overall transportation system congestion
and delays to reduce regional emissions of pollutants during construction.
f) Implement restrictions on construction truck idling (e.g., limit idling to a
maximum of five minutes).
g) Locate construction equipment away from sensitive receptors, such as fresh air
intakes to buildings, air conditioners, and sensitive populations.
h) Locate construction staging zones where diesel emissions won't be noticeable
to the public or near sensitive populations, such as the elderly and the young.
i) Spray exposed soil with water or other suppressant to reduce emissions of PM10
and deposition of particulate matter.
j) Pave or use gravel on staging areas and roads that would be exposed for long
periods.
k) Cover all trucks transporting material and wet materials in trucks, or provide
adequate freeboard (space from the top of the material to the top of the truck bed),
to reduce PM,o emissions and deposition during transport.
1) 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.
6) Prior to issuance of a Certificate of Occupancy, the applicant shall construct a
northbound left -turn lane on Weyerhaeuser Way South at the southerly driveway
(truck access) to provide safer and more efficient access into the site. The
northbound left (NBL) turn lane storage shall be designed to accommodate the
95th Percentile queues length, ensuring left turn queues will not block the through
traffic lane. The channelization plan must be reviewed and approved by the city
and WSDOT.
7) Prior to building permit issuance, the applicant shall install weight limit signs on
Weyerhaeuser Way South from South 320th Street to the project driveway, and
South 336th Street from 20th Avenue South to Weyerhaeuser Way South.
8) The applicant submitted a traffic study, IRG Greenline Buildings A and B
Federal Way, WA Transportation Impact Study, TENW Transportation Engineering
NorthWest, March 6, 2018. The development is estimated to generate 954 daily
trips, with 97 trips occurring during the PM peak hour (78 passenger and 19 truck).
These trips will be served by two driveways (private loop road driveway north of
the site and truck access driveway next to SR 18) on Weyerhaeuser Way South.
According to the traffic study, all truck trips will utilize the proposed truck access
driveway on Weyerhaeuser Way South and will be traveling to and from the south
using the Weyerhaeuser Way South/SR-18 interchange. On a daily basis, 1-5
southbound congestion routinely occurs between the SR 18 and South 320th
Street interchange. In order to avoid traffic congestion and reduce travel time due
to shorter distance, truck trips with origin and destination from the north could
utilize the South 320th Street/SR-5 interchange, South 336th Street, and
Weyerhaeuser Way South as an alternate route to the site. The traffic study has
not demonstrated how the applicant will prevent this alternative truck route (South
3201h Street /SR-5 interchange, South 3361h 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, prior to the Certificate of Occupancy issuance, the applicant shall provide
a fully executed bond for 120 percent of the engineer's estimate for design and
construction costs to upgrade the existing pavement on Weyerhaeuser Way
South, from the proposed truck entrance to South 3201h Street. The bond term
shall be for a period of three years from the time of notification by the applicant of
full occupancy and use of the facility, unless a shorter term is mutually agreed to in
the implementation agreement discussed below. The applicant shall provide the
engineer's estimate.
Should the truck trips generated by the project traveling north of the site (to or
from the site) exceed 28 truck trips per week as set forth in the implementation
agreement discussed below, the city will use the bond for design and construction
costs to upgrade the existing pavement on Weyerhaeuser Way South, from the
proposed truck entrance to South 3201h Street, and/or from the proposed truck
entrance to SR-99 via South 336th Street, to the city's required design standards.
In the alternative, the applicant may choose to design and construct the implicated
roadway(s) identified by the city. For the purposes of this condition, a "truck" shall
mean a vehicle rated in excess of 30,000 pounds gross weight as discussed in
Chapter 8.40 FWRC.
Prior to building permit issuance, the applicant and the city shall enter into an
implementation agreement to set forth the conditions by which the city will monitor
the truck trips; how the city will make its determination that the applicant has
exceeded the 28 or more truck trips per week; how notice will be provided to the
applicant; the cure period for the applicant to remedy the excess truck trips
described in the above condition; when the city will call the bond or require the
applicant to construct the implicated roadways; the bond conditions; and all other
requirements deemed necessary by the city.
9) The existing pavement on Weyerhaeuser Way South (south of the site), from
the proposed truck entrance to the SR-18 interchange must be fully reconstructed
(subgrade soils and new pavement) to accommodate the expected truck traffic
load. The applicant shall provide pavement design for city review and approval
prior to engineering plans submittal. Once the pavement design is approved by
the city, the development shall perform full depth reconstruction of the roadway
segment impacted by the truck traffic.
10) Prior to issuance of a certificate of occupancy, the applicant shall construct
right -turn storage for the westbound SR-18 off -ramp to mitigate for the impact to
the westbound off -ramp, to the satisfaction and approval of WSDOT.
11) Cumulative traffic impacts from Warehouses A and B, and the Greenline
Business Park to the SR 18 westbound ramp intersection with Weyerhaeuser Way
South shall be evaluated and mitigated in a SEPA analysis addendum, and/or
revision to the 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, the city LOS standards shall be applied and pro-rata mitigation for
Warehouse A imposed as necessary. All mitigation shall be subject to RCW
82.02.020 and constitutional nexus/proportionality.
Further information regarding this action is available to the public upon request or
on the city website: https://www.citVoffederalwaV.com/node/1962. Contact
Principal Planner Stacey Welsh at 253-835-2634, or
stacey.welsh(a)cityottederalway.com. This MDNS is issued under WAC 197-11-
340(2). Comments must be submitted by 5:00 p.m. on October 23, 2020. Email
comments should be directed to planning(o-)cityoffederalway.com.
Unless modified by the city, this determination will become final following the
above comment deadline. Any person aggrieved of the city's final determination
may file an appeal. Anyone may appeal this determination to the Federal Way City
Clerk (33325 8t" Avenue South, Federal Way, WA 98003), no later than 5:00 p.m.
on November 13, 2020, by a written letter stating the reason for the appeal of the
determination along with the required appeal fee. You should be prepared to make
specific factual objections. All appeals shall contain a specific statement of
reasons why the decision of the responsible official is alleged to be in error.
Published in the Federal Way Mirror on October 9, 2020.
Comment Deadline
Comments must be submitted by 5:00 p.m. on October 23, 2020. Email
comments should be directed to planning(o)cityoffederalway.com.
City of Federal Way 1 33325 8th Ave S, Federal Way, WA 98003
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Stacey Welsh
From: Noel Hagens <noelhagens@gmail.com>
Sent: Tuesday, October 20, 2020 9:08 PM
To: Ping Inquiry
Subject: the historically significant Weyerhaeuser Campus
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Stacey Welsh -
Re "File No: 17-104237-SE"
I write out of deep concern for the historically significant Weyerhaeuser Campus, which is
known not only in Washington but also nationally and even internationally for its innovative
design.
The changes that the city of Federal Way are considering are drastic on top of the
warehouses which are already under way. A thin strip of trees will not disguise the
damage to the iconic building and its lovely surroundings. The campus as a whole is
outstanding and ground breaking, and the building depends for its innovation on the
grounds near it.
Please stop this damaging development and maintain what is left of the beautiful design
which has brought fame to the city of Federal Way.
Thank you for your attention to this matter.
Noel Hagens
Stacey Welsh
From: Shannan St.Clair <shannan.st.clair@gmail.com>
Sent: Tuesday, October 20, 2020 11:15 AM
To: Ping Inquiry
Subject: Weyerhaeuser Campus - File No: 17-104237-SE
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Hello Ms. Welsh — I am writing to you regarding File No: 17-104237-SE and the proposal for another incompatible
warehouse on the former Weyerhaeuser Campus working its way through SEPA review at the City of Federal Way.
The City recently released a decision that would allow for this inappropriate new construction to move forward —
and is failing to take into account the historic significance of the campus.
The property owner has called for only a small strip of trees to be kept between the proposed warehouse and the
iconic headquarters building which is so deeply connected to its surrounding forested landscape. The City has
deemed this cosmetic measure as sufficient to avoid harm to the historic campus, but I personally disagree and
believe this solution ignores the holistic and groundbreaking architectural and landscape design of the campus.
The campus as a whole has outstanding historic significance and therefore any changes must be compatible to its
existing design. This campus is significant not just for Washington and the Northwest —it is known nationally and
internationally as one of the finest examples of modern corporate campus design.
The tree buffer proposed by the owner is insufficient because the entire forested parcel contributes to the
significance of the campus design. The City should require the owner to substantially reduce the size of the
proposed warehouse to preserve more of the forested land and the historic design of the campus.
Ultimately, the historic significance of the campus warrants additional review through an Environmental Impact
Statement (EIS), which the City should require. An EIS would allow for more public comment and require that the
property owner consider alternatives that have less harmful environmental impacts.
We; as a city, have an excellent opportunity to positively shape how Federal Way will look and feel for decades to
come. I do not want to live in a city that is a pass through warehouse depot. I do not want to live in a city that
completely overlooks the value in its natural green spaces and a site (maybe the only one) with real architectural
value; the Weyerhaeuser Campus. I understand that we need to develop and grow, but we can do that in a
thoughtful, ecologically sound, and positive way for all Federal Way citizens. Not just a warehouse developer who
doesn't have any vested interest in the long-term livability of our city.
Thank you for your time and consideration regarding this very important matter.
Appreciatively
Sharman St. Clair
2709 SW 346th Street
Federal Way, WA 98023
Stacey Welsh
From: Mary Ehlis <maryehlis@gmail.com>
Sent: Friday, October 23, 2020 1:54 PM
To: Ping Inquiry
Subject: Weyerhaeuser Campus (File No: 17-104237-SE)
Attachments: Weyerhaeuser Campus letter - Oct. 23.docx
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Attention: Stacey Welsh
Thank you for considering my concerns.
Mary Ehlis
October 23, 2020
Dear Mayor Ferrell, Federal Way City Council, Planning Commission, & Planning Department:
Why would the City of Federal Way not require an Environmental Impact Statement on the proposed
building of a warehouse on the Weyerhaeuser Campus site (File No: 17-104237-SE)? The entire Campus
was recognized in 2017 by the WA Trust for Historic Preservation as a unique historic and sensitive
environmental site that deserves a higher and better use than has been proposed so far. It is one of the
few glimpses of Federal Way from 1-5 that is truly an inspirational and beautiful vision of our community.
Maps of the Federal Way region with its many lakes show that the Weyerhaeuser Campus/North Lake
area are the head of the Hylebos waterway system. Why would we potentially damage a system that
WA State, Federal Way and other surrounding cities have spent a lot of funds and efforts to preserve?
An EIS would hopefully reveal any potential harm to an already fragile ecosystem both in the West
Hylebos system and to the Weyerhaeuser Campus property.
Anyone who has dealt with traffic in the Hwy. 18 and 1-5 corridor through Federal Way knows that it
can't handle much more. Do we really need to be adding additional truck traffic that a warehouse will
generate along with the impact to the roads? This is another issue that should be carefully reviewed.
The Weyerhaeuser Campus with its award winning building and thoughtfully landscaped grounds should
be preserved and listed on the National Landmark registry as an exceptional example of modern
corporate design. It would put the City of Federal Way in the national spotlight. This exceptional
acreage could serve for a much better and higher use than as a warehouse district. Surely, a higher
education, corporate or governmental organization can be found that would use and develop the
property in such a way that would preserve its historic and environmental features. That would truly be
of benefit to the City of Federal Way and the people who live here.
Sincerely,
Mary L. Ehlis (253-344-7795)
Stacey Welsh
From: Joann Roomes <jroomes@yahoo.com>
Sent: Monday, October 19, 2020 8:45 PM
To: Ping Inquiry
Subject: Weyerhaeuser Campus File No: 17-104237-SE
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To Whom It Concerns:
I am writing in response to the "Mitigated Determination of Non -Significance" (MDNS) and the
proposed new construction on an historic property.
See File No: 17-104237-SE
The proposed construction is inappropriate for this property.
This campus as a whole has outstanding historic significance and therefore any
changes must be compatible to its existing design. This campus is significant not just for
Washington and the Northwest —it is known nationally and internationally as one of the finest
examples of modern corporate campus design.
The tree buffer proposed by the owner is insufficient because the entire forested parcel
contributes to the significance of the campus design. The City should require the owner to
substantially reduce the size of the proposed warehouse to preserve more of the forested land
and the historic design of the campus.
Ultimately, the historic significance of the campus warrants additional review through
an Environmental Impact Statement (EIS), which the City should require. An EIS would
allow for more public comment and require that the property owner consider alternatives that
have less harmful environmental impacts.
Please reconsider.
Joann Roomes
jroomes@yahoo.com
Stacey Welsh
From: Sandy Strehlou <sstrehlou@fridayharbor.org>
Sent: Tuesday, October 20, 2020 9:42 AM
To: Ping Inquiry
Subject: Weyerhaeuser Campus
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Dear Federal Way Planning Commission:
I recently became aware of the changes proposed for what remains of the amazing
Weyerhaeuser Campus property. What a fabulous gem you have in Federal Way. Please
do not allow the proposed warehouse to
be built on the property. Contrary to the
recent determination of non -significance,
mitigated or not, the warehouse will
destroy the beautiful and historic
resource in your city. Once hacked apart
with inappropriately designed in -fill
structures, you can never go back and repair the damage.
How fortunate you are to have a recent past treasure. Cities everywhere are trying to
design beautiful park areas that all to often fall short of having enduring significance.
Federal Way residents are blessed to have the Weyerhaeuser Campus in their
community. People who live outside of Federal Way, but within the region, view the
campus as a destination. It brings visitors to your community, and with them, tourist
dollars. The building and the landscape are intrinsically important, more than just the
sum of their parts. Americans are becoming increasingly interested in recent past
I
architecture and landscape design. The original design of the site and the prominence of
the architects who created it endow international significance. You simply cannot
replicate a resource like this. It's park setting is needed in today's urban environments; a
warehouse will irrevocably diminish the tranquil character of the property. Anything
added to the site must be compatible. The proposed warehouse is anything but. You will
loose entirely the magic of this place.
Please do not sacrifice the tree buffer forest. If an industrial warehouse development is the
unfortunate highest and best use, the City should approve the project only if the owner
reduces the size of the proposed warehouse to preserve more of the forested land and
reduce the volume of traffic that would result otherwise.
I urge you to conduct further review by requiring and Environmental Impact Statement.
This is the best way to ensure that Federal Way residents, and regional visitors to the
property, can weigh-in and encourage the property owners to consider alternatives that
would not result in irreversible and harmful environmental and cultural impacts.
I am originally from California's Bay Area (now a resident of San Juan Island). Prior to
relocating to WA, I participated in a 5-year City of Oakland project to save an important
historic cultural site. It took us that amount of time to bring together community, civic
and business partners to save the site by identifying funding sources that together
would both save and rehabilitate the resource. When given the opportunity, the
residents of Oakland overwhelmingly supported the project and we found the money.
Likewise, I encourage you to step back and take the time to protect this rare and significant
resource with a plan that is less onerous. Federal Way is your town, not to be
deconstructed to fit only the wants and needs of corporate interests. There are ways to
accomplish multiple needs, but once dismantled, you will never have the important and
beautiful resource you have now. You need time to find the best path.
ra
Thank you for your consideration.
Sandy Strehlou
Friday Harbor, WA
Stacey Welsh
From: kevinpatrickw@yahoo.com
Sent: Wednesday, October 21, 2020 9:04 AM
To: Ping Inquiry
Subject: Weyerhaeuser File No: 17-104237-SE
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Dear Stacey,
I am deeply concerned that a proposal for another incompatible warehouse on the
former Weyerhaeuser Campus is working its way through SEPA review and that the City
has released a decision that would allow for this inappropriate new construction to move
forward! This is failing to take into account the historic significance of the campus.
The property owner has called for only a small strip of trees to be kept between the
proposed warehouse and the iconic headquarters building which is deeply connected to
its surrounding forested landscape. The City has deemed this cosmetic measure as
sufficient to avoid harm to the historic campus, but I say this solution ignores the
holistic and groundbreaking architectural and landscape design of the campus.
This campus as a whole has outstanding historic significance and therefore any
changes must be compatible to its existing design. This campus is significant
not just for Washington and the Northwest —it is known nationally and
internationally as one of the finest examples of modern corporate campus
design.
The tree buffer proposed by the owner is insufficient because the entire forested parcel
contributes to the significance of the campus design. The City should require the owner
to substantially reduce the size of the proposed warehouse to preserve more of the
forested land and the historic design of the campus.
Ultimately, the historic significance of the campus warrants additional review through an
Environmental Impact Statement (EIS), which the City should require. An EIS would
allow for more public comment and require that the property owner consider alternatives
that have less harmful environmental impacts.
Our family has lived near the Weyerhaeuser campus for over 35 years and we have
walked and run on the trails, enjoying the unique ambiance of the property all the while.
It is a beautiful approach to our neighborhood, and we appreciate it daily.
Sincerely, Joan and Kevin Patrick
I
Stacey Welsh
From: Justine Rojas <rojas Justine@gmail.com>
Sent: Friday, October 23, 2020 1:03 PM
To: Ping Inquiry
Subject: Weyerhaeuser Land Use Proposal
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Ms. Walsh,
I am writing you in regards to the Land Use Proposal at the Weyerhaeuser campus (File no. 17- 104237 - SE).
I moved to the Federal Way area 22 years ago with my husband and our young family. When we were getting to know
the new city we had moved to, we were pleasantly surprised to find the corporate headquarters of the Weyerhaeuser
Campus. We were impressed by the design of it's main building, but also by the surrounding forest that incorporated
native fauna and provided a safe home to local wildlife. I spent many days walking the children and our dog on their 12
miles of trails, teaching them about the native trees of Washington and the birds that migrated through our area. What
a gift and a role model this campus is to a suburban city landscape. All too often over the last 50 years, suburban areas
have been blighted with big box stores, concrete parking lots and ill designed huge warehouses that not only are an
assault on the aesthetics of cities, but also do huge damage to our environment and Rob our wildlife of a healthy
ecosystem to thrive in.
When I heard 4 years ago that Weyerhaeuser would be selling their campus headquarters I was immediately fearful it
would result in a loss of this rare and historical acreage nestled in our city, but I was hopeful the city government would
recognize the value of the architectural wonder they had in their midst. I was also heartened to hear about the
formation of the Save Weyerhaeuser Campus (SWC) group, composed of volunteers who dedicated countless hours to
protecting the integrity of the historical piece of land in Federal Way.
As I have followed the process of land use proposals and the research the SWC has conducted about the ecosystem the
campus supports and it's downstream effects on important watersheds in the area, I felt sure the city would elect to
protect the integrity of the architecture and the forest it sits gently within. Now I hear the latest proposal is only to
preserve a 50 foot buffer of forest around the Weyerhaeuser headquarters building and install a huge warehouse on the
land.
I am writing to ask that the city further consider the historical significance of the campus design, which is nationally and
internationally recognized, and request additional review through an Environmental Impact Statement (EIS). An EIS
would allow more public comment and require that the property owner consider alternatives that have less harmful
impact to the environment.
The destruction of these trails and this forest would be a huge loss To the Federal Way area. Please take every step you
can to protect it.
Thank you,
Justine Rojas
253 921 3157
Sent from my iPhone
Stacey Welsh
From: Debbie Caddell <cIc2000@comcast.net>
Sent: Tuesday, October 20, 2020 8:57 AM
To: Ping Inquiry
Subject: Weyerhaeuser
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I am a resident 3 minutes from the Weyerhaeuser campus and am deeply concerned about the potential building.
This pertains to File No: 17-104237-SE.
The campus as a whole has historic significance. It is known nationally and internationally. My boyfriend is a
contractor from Seattle. He told me this and he loves that campus.
The tree buffer proposed by the owner is not far too small. The City should require the owner to reduce the size of
the proposed warehouse in order to preserve the forested land.
Please consider additional review through an Environmental Impact Statement.
Thanks
Debbie Caddell
Stacey Welsh
From: Cathy Taylor <mcraetaylor@yahoo.com>
Sent: Wednesday, October 21, 2020 1:00 AM
To: Ping Inquiry
Subject: Weyerhauser campus
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Dear Ms. Welsh:
It's unbelievable that on this historic, lovely location, a warehouse will be built. I'm referring to file # 17-104237-SE.
Really will our only legacy be money over history? Please don't let this happen!
Respectfully,
Cathy Taylor
514 N 11th St.
Tacoma, WA. 98403
Sent from Yahoo Mail on Android
Stacey Welsh
From: Marie and Craig <crgrie123@yahoo.com>
Sent: Friday, October 23, 2020 12:20 PM
To: Ping Inquiry
Subject: Weyerhauser Campus
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PLEASE save the Campus for people and wildlife. Honor the Weyerhauser legacy and please do
NOT develop the land with warehouses and trucks which pollute the air. Runoff from heavy truck
traffic will pollute the water. Can't any stretch of land be left undeveloped??? THINK Central Park in
New YCampus has the same effect and importance as Central Park in New York.
Thank you
Marie west -Johnson
Rainier Audubon Society