17-105489-Comment Response Letter-11-12-2021-V1
November 11, 2021 Job No. 1886-001-016-0016
Ms. Lisa Klein, AICP
Contract Planner, City of Federal Way
City of Federal Way
33325 8th Avenue S
Federal Way, WA 98003-6325
RE: File Nos. 17-105489-UP & 17-105490-SE
TECHNICAL REVIEW COMMENTS
Woodbridge Business Park - 327XX Weyerhaeuser Way South, Federal Way
AHBL No. 2200534.30
Dear Ms. Klein:
This letter is written on behalf of Federal Way Campus, LLC to provide detailed responses to
comments received from AHBL dated March 19, 2021, technical review comments received
from Kevin Peterson at City of Federal Way dated March 22, 2021, and Critical Areas Report
comments from ESA dated January 25, 2021. In an effort to provide concise and direct
responses, we have copied the review comments below in italics and added our responses in
bold.
Comments from AHBL in letter dated March 19, 2021
1. Technical comments made about an item on one sheet may necessitate changes to other
sheets and related documents, and it is the applicant’s responsibility to determine any such
necessary adjustments. Please ensure consistent information is communicated
throughout the plan set and associated application materials.
This comment has been noted and the re-submittal has been verified to ensure it is
consistent throughout all documents.
2. See the separate City technical review letters pertaining to the proposed BLA.
This comment has been noted. The prior BLA applications (File Nos. 20-10116 and 20-
103511) have been withdrawn. We anticipate a condition of approval of this Process IV
application will be to process a BLA concurrent with building permits to align property lines
with the final configuration of the development.
Ms. Lisa Klein
November 11, 2021
Page 2
Parking Analysis
Off-street parking shall comply with the 1994 zoning code as modified by the provisions of
Section XIII of the CP-1 regulations. Required parking is one parking space per 300 square
feet of gross floor area (GFA) for office, and one for every 1,0000 square feet of GFA for
warehouse. No floor plan has been submitted, so the exact breakdown of office and
warehouse space has not been determined, however, if we were to assume that 10 percent
of each building is office space, the provided number of parking spaces does not meet the
minimum requirements. As an alternative to meeting the code minimum parking requirements,
a Parking Analysis was prepared by Transportation Engineering Northwest dated March 10,
2020. The following comments pertain to review of the onsite parking and the TENW Parking
Analysis.
3. The Site Plan and Parking Analysis do not provide the number of parking spaces per
building, just an aggregate number. Section XIII of the CP-1 regulations provided in
the CZA provide that:
“the aggregate of all proposed and existing uses on the property may, subject to
approval of the Director, be considered as a whole in establishing the minimum number
of vehicle spaces required, based on the following:
1. Any excess capacity in existing parking spaces lying within 800 feet of a
proposed development may be used to reduce the requirement for additional
parking development.
2. If the occupant of a proposed use provides van or alternative service between
the proposed use and remote parking facilities, any excess parking on the
entire property may be used to reduce the requirement for additional parking
development.”
Either provide a breakdown of parking per building demonstrating that each building
meets the required number of parking spaces or provide a response for the Director’s
consideration to the CZA provisions listed above.
Please see the Woodbridge Business Park Parking Analysis prepared by TENW and
dated September 1, 2021, included with the resubmittal.
4. The TENW Parking Analysis provides a parking calculation that is based on the
Warehouse LUC 150. A calculation for office space associated with the warehouse use
was not provided and the office space use may increase the parking requirement.
Provide the office space calculation per the ITE Parking Generation Manual or explain
why the office space calculation is not provided (for example, if office space is
presumed to be an accessory use to the warehouse use).
The updated Parking Analysis, dated September 1, 2021, is based on LUC 130
Industrial Park which is consistent with the land use used in the Traffic Impact Analysis
(TIA). A separate office space calculation was not provided because the office space
is an accessory use to the industrial park use.
5. The Traffic Impact Analysis (TIA) used a different LUC than the Parking Analysis (LUC
130 – Industrial Park). Either modify the technical documents for consistency or clarify
why the Parking Analysis and TIA would use different LUCs.
Ms. Lisa Klein
November 11, 2021
Page 3
The updated Parking Analysis, dated September 1, 2021, is based on LUC 130
Industrial Park which is consistent with the land use used in the Traffic Impact Analysis
(TIA).
6. As requested in the City’s comment letter dated March 7, 2019, if the proposal is not
meeting City code requirements for parking, the Parking Analysis shall provide
comparisons to other existing similar uses with similar land use characteristics in the
Greater Puget Sound region.
A specific user of the project has not been identified. As such, a comparison to existing
similar uses is not possible. It is recommended that the City impose a condition
requiring the building permit application plan set to include a section with a parking
analysis that demonstrates compliance with the required parking ratios. This is
consistent with the City’s approach on other project approvals, including Woodbridge
Building B (Process III Project Approval Finding 8 and Condition of Approval 3).
7. The size provided for the existing WTC building on the site plan (Sheet CV-01) is
239,354 square feet. The size of the WTC building provided in the Parking Analysis is
450,000 square feet. The size of the WTC building provided by the King County
Assessor is 468,457 square feet. Clarify which building size is correct for the WTC
building and correct the plans and Parking Analysis accordingly.
All areas noted are correct. The area noted on Sheet CV-01 is the footprint of the
WTC, which is a multi-story building. The area used in the parking analysis is based
on a BOMA survey, which established the leasable area within the building (451,460
sf). We have included the Assessor’s information on Sheet CV-01.
Plan Statistics
8. The Cover Sheet of the Plan Set (Sheet CV-01) depicts the site area as 136 acres.
Sheet SD-01 provides the site area as 145.99 acres. Clarify which statistic is correct
and modify the plans and documents as needed to correct the discrepancy.
The project has been reduced to a total gross site area of 97.66 acres.
9. There are discrepancies in the impervious surface numbers provided for the project
area. The Architectural site plan provides 60.7 acres of impervious, Sheet SK-01
provides 45.79 acres of impervious surface, and the SEPA checklist identifies 61.02
acres of impervious surface (45 percent of 135.61-acre site). Clarify which statistic is
correct and modify the plans and documents as needed to correct the discrepancy.
The discrepancies have been resolved. The total impervious area (replaced, existing
and new) is 63.91 acres.
10. Section III of the CP-1 regulations states, “The aggregate impervious surface coverage
by all permitted uses, primary and accessory, shall not exceed 70 percent of the total
CP-1 zoned property.” The “Impervious Area Exhibit” prepared by ESM, September 9,
2017, shows the existing impervious coverage in the CP-1 zone is 8.6 percent and the
construction of the proposed project would increase it to 24.1 percent. We believe that
the exhibit is now outdated based on recent project changes. Revise/update the exhibit
to match the current proposal.
Ms. Lisa Klein
November 11, 2021
Page 4
The Impervious Area Exhibit has been updated to match the revised project and now
reflects an aggregate impervious surface coverage of 22.4% of the CP-1 zoned
property.
Managed Forest Buffer, Landscape Plans, and Tree Retention
Section III.B of the Exhibit C of the CZA states that a continuous Managed Forest Buffer (MFB)
shall be provided around the entire perimeter of the CP-1 property. On November 18, 2018, the
City issued Interpretation #18-01 (18-105277-UP) that describes the location and depth of the
MFB on the CP-1 zoned property. Washington Forestry Consultants, Inc. prepared a Forest
Management/Maintenance Plan dated March 23, 2020 (the WFC Plan) which was submitted
together with qualifications information on the preparer. The WFC Plan describes the location
and vegetation types and quantities for each of the MFB areas. In general, the WFC plan is
acceptable, however the site plan revisions described herein will require revisions.
11. The CZA states a “Managed Forest Buffer shall be provided around the entire
perimeter of the CP-1 property.” The CP-1 perimeter extends to the northeastern
parcel along the North Lake shoreline (Lot F on EX-01), which is the lot currently
proposed to contain a stormwater pond and wetland mitigation area, and where a
Managed Forest Buffer (MFB) is not provided. The east boundary of the northeastern
parcel is adjacent to single-family zoned land (including the adjacent access road,
which is zoned single-family). The property zoned for single-family is currently owned
by Washington Department of Natural Resources and used for a boat launch and
public access for fishing, which is an incompatible use to the CP-1 zone. The CZA
provides that a 50-foot MFB is to be provided adjacent to incompatible use. Provide a
50-foot MFB on the east boundary of the northeastern parcel. Update the Forest
Management/Maintenance Plan to include this area.
A 50’ width Managed Forest Buffer has been added the east boundary of the northeast
parcel, which is no longer part of this project.
12. Section III.B.4 of the CZA describes that widening of rights of way “shall not require
relocation of any boundaries of the required Buffer for developed lots” (emphasis
added). Section VIII.A.8 of the CZA describes that only perpendicular access roads
are permitted in the MFB. The northern 25-foot MFB shall be located outside of the
106-foot Development Reservation area that is to be dedicated for right of way.
We respectfully remind the reviewer that the City previously addressed this issue in
Interpretation #18-01. In Interpretation #18-01, the City stated:
Ms. Lisa Klein
November 11, 2021
Page 5
This interpretation is final and binding. The 25-foot MFB is to be located on the land
reserved for future right-of-way.
We also remind the City that the extension of S 324th Street is not necessary to mitigate
project impacts and future dedication cannot be required without compensation.
Compensation, in the form of TIF credit, is required for any future right-of-way
dedication. The applicant submitted an application for TIF credit on 9/11/18 and
respectfully requests a decision be issued.
13. The screening of the truck bays on the north side of Building A to the future right of way
and properties to the north requires enhancements. The WFC Plan describes the
western half of this area as containing Forest Cover Type III. Forest Cover Type III is
described in the WFC Plan as being poorly stock with 30 trees per acre and containing
large gaps where shade tolerant conifers such as western red cedar could be planted.
Interplanting with a shade tolerant tree species would improve this buffer over time and
scree the truck bays from the future right-of-way. The landscape plans shall be revised
to include the addition of shade tolerant tree species within Forest Cover Type III
located within the northern 25-foot MFB that infill the existing trees. Per Section XI.A.3
of the CZA, the selection and installation of plant material in the MFB shall be the
responsibility of the Forester. A letter approving the landscape plans for this specific
area shall be provided by WFC.
If the 106’-wide buffer is not adequate to screen the truck bays of Building 1, the
project Forester will specify planting of shade tolerant tree species. No additional
MFB is required as explained in Comment #12 above.
14. The Tree Retention Plan Sheet TR-01 is not consistent with the grading plans SD-01
and SD-02, the Visual Impact Exhibit, or the landscape plans. It depicts no tree
retention adjacent to Weyerhaeuser Way South between the road and new buildings.
The Grading Plans, however, depict that a large portion of the landscape buffer in this
area will not be graded, which would allow for tree retention. The grading plans also
depict greater potential for tree retention around the south and west sides of Buildings
2 and 3 and stormwater ponds 4 and 5 than shown on Sheet TR-01. The Visual Impact
Exhibit also depicts the retention of the mature vegetation in these areas. The
landscape plans depict new plantings in these areas to supplement the native
vegetation. Per Section XI.A.1 of the CZA, all portions of the property not used for
Ms. Lisa Klein
November 11, 2021
Page 6
buildings, future buildings, parking, storage, or accessory uses, and proposed
landscaping areas shall be retained in a “native” or predeveloped state. Revise Sheet
TR-01 to match the grading plans, landscape plans, and Visual Impact Exhibit. All
plans need to be consistent.
The plans have been updated to reflect retention of native vegetation and
supplemental planting in areas that are not being graded for the project.
Site Plan
15. Provide all easements to be retained and new easements proposed on the site plan
sheets to determine any potential conflicts.
The easements have been added to the site plan sheets.
16. Sheet EX-01 depicts a small, dashed line setback from the north and eastern perimeter
of Parcel F. Identify the purpose of the line.
The setback has been identified on this sheet as the Managed Forest Buffer.
Visual Impact Exhibit
17. The following modifications to the Visual Impact Exhibit are required:
a. Update the exhibit to reflect the current site plan. Revise the building
references in the exhibit to correlate with the site plan for ease of reference
(i.e., number designations instead of letters).
b. Provide additional view locations as depicted below in Figure 1 depicting the
change in view resulting from tree removal and the site development.
The visual impact exhibits have been updated to reflect the current site plan including
the tree buffer along the meadow, the ponds, and wetland locations. Additional visual
impact exhibits have been provided as requested.
Building Elevations and Design Brief
The site and building design are required to comply with the CZA, and, where indicated, the
FWCC. The specific CZA and FWCC design requirements affecting development of the
property are stated below in “a – d” followed by staff technical comments as to how they apply
to the Woodbridge Business Park:
a. “The property is unique in terms of its development capacity and natural features.
Weyerhaeuser desires to develop its property with maximum flexibility which
will ensure optimal development, while preserving the unique natural features
of the site.”
b. “CP-1 properties are characterized by large contiguous sites with landscape, open
space amenities, and buildings of superior quality. The property appropriate for
such uses is unique and demands for such uses are rare. Consequently, special
land use and site regulations are appropriate.”
Ms. Lisa Klein
November 11, 2021
Page 7
Staff Analysis: The CZA’s meaning and intent to “preserve the unique natural features of the
site,” as described in “a,” is critical in understanding how the CP-1 properties are to be
developed. Understanding the intent of “a” is assisted by the additional characterizations of the
site provided in “b,” i.e., the unique natural features to be preserved are the unique “landscape
and open space amenities.” The CZA intent is to preserve the meadow, a unique landscape
feature that provides an open space amenity. Also, to be preserved is the Managed Forest
Buffer and the forest/native vegetation located outside of the development footprint (described
below in (d.A.1)), which form the landscape. The preservation of these areas will allow for
“optimal development” of the site.
Provision “b” further describes the existing condition of the CP-1 properties as containing
buildings (such as the headquarters building and WTC building) that are of superior quality. It
acknowledges that the site is unique and deserves “special land use and site regulations.” The
special regulations include regulations that require new buildings be of superior quality and
that the development preserve the unique natural features. How the intent of the CZA is
specifically applied to the proposal is provided below.
c. Section X General Development Conditions: “Provisions of the FWC relating
to façade measurement, modulation, distance between structures, or
materials, other than those specified herein, shall not apply to this zone.”
Staff Analysis: This provision is clear that prescriptive building design requirements typically
found in design standards do not apply. Removal of specific design standards requires reliance
upon the existing buildings and landscape for guidance in determining the intent of superior
building design.
d. Section VI.B requires that proposed landscaping comply with Section XI
(Landscaping). Section XI provides specific modifications to Chapter 22, Article
XVII (Landscaping) that are applicable in the CP-1 zoning district, including:
o A.1 “All portions of the property not used for buildings, future buildings,
parking, storage or accessory uses, and proposed landscape areas
shall be retained in a “native” or predeveloped state. Alterations to
existing landscaping shall match or be compatible with existing
vegetation.”
o A.2 “Alterations to existing landscaping in connection with new
development shall match or be compatible with existing vegetation.
Extensions of, or duplication of existing plant material in connection with
future development is preferred.”
Staff Analysis: These provisions clearly intend for the existing vegetation to be retained to the
greatest extent possible, and, when required to be removed for future buildings, parking,
storage or accessory uses, the replacement plantings shall match or be compatible with
existing vegetation.
Provision “a” identified by staff is part of Recital C in the CZA. Provision “b” identified by staff
is part of “Section I. Purpose and Objectives” in Exhibit C of the CZA. We respectfully remind
the City that, in response to a motion filed by both the applicant and the City, the City’s Hearing
Examiner previously ruled that the Recitals and purpose statements are not regulatory. The
Examiner ruled: “CZA recitals do not serve as development restrictions on the property” and
“Zoning district purpose clauses do not serve as development restrictions on the project site.”
Please see page 8 of the Ruling on Motion for Partial Dismissal included with this submittal.
Ms. Lisa Klein
November 11, 2021
Page 8
18. Based on the CZA requirements and the staff analysis described above, we have the
following comments on the building and site design:
a. As previously commented by the City, the site and building design, as viewed from
the high-profile public street roundabout, do not represent “buildings of superior
quality” or an “altered site that matches existing vegetation.” We understand you
have reduced the size of Building 2 and pulled it away from the public right-of-way;
however, the concerns remain that at this prominent location, the combination of
the proposed tree removal for the storm pond, proposed plantings, and the building
aesthetics do not meet the CZA requirements. The following would improve the
building and landscaping aesthetics at this location and better comply with the
CZA. The city is open to alternatives that provide an equivalent or superior
approach to site and building design
i. Construction of storm pond #5 and its maintenance access road
requires removal of mature vegetation and limits the planting of
replacement vegetation that would otherwise screen the building.
Relocation of the storm pond maintenance access road to a location
that extends from the parking lot instead of Weyerhaeuser Way would
allow the existing trees in that location to remain and new trees to be
planted along this prominent frontage for additional screening.
Relocate the pond maintenance access road to minimize tree removal.
Provide additional trees between Weyerhaeuser Way and the
stormwater pond for building screening.
The plans have been updated to move the pond access road and include
additional plantings in this location.
ii. The landscape plans provide new evergreen tree plantings between the
street frontage and storm pond #5; however, the landscape plans do not
indicate tree sizes. The City will require that the trees at this location be
at least 10 feet in height at the time of planting. Add this note to the
landscape plans.
The plan note for this area has been revised to include the requirement that all
trees between Detention Pond #5 and Weyerhaeuser Way are 10’ minimum
height at the time of planting.
iii. The southeast corner of Building 2 marks the entry point to the new
campus and this corner is not architecturally emphasized. Consider
mimicking the building corner treatments provided at the main building
entry at the northeast corner and/or the entry at the southwest corner
or provide other architectural building elements that enhance building
design at this high-profile location.
The SE corner of Building 2 does include the architectural entry feature as
indicated in the design brief elevations. The east wall of Building 2 including
the SE and NE corners will mimic the west elevation as noted on Sheet A1.0.
b. As provided above, the meadow is a “unique natural feature of the site that is
to be preserved.” In order for the meadow to be preserved/retained in its
native/predeveloped state, the City will require the meadow be protected from
Ms. Lisa Klein
November 11, 2021
Page 9
development through the recording of a conservation easement. This will be a
condition of approval.
The CZA prohibits the City from imposing this condition. Specifically, Section
13 of the Development Agreement states (emphasis added):
c. The City is concerned about view impacts from Interstate 5 as a result of the
pond and building construction. If view impacts are not adequately mitigated,
the City may determine that a SEPA Determination of Significance is
appropriate and an EIS will be required. The following comments provide our
analysis of the impacts and potential opportunities to mitigate the impacts.
Additional analysis will likely be required following plan changes and receipt of
the updated View Impact Analysis to evaluate if the impacts are adequately
mitigated.
A minimum 50-foot-wide tree buffer will be maintained along the edge of the
meadow to buffer the view from Interstate 5. The Forester will review all project
buffers at the time of construction and require additional plantings to further
mitigate any view impacts.
i. The Visual Impact Exhibit demonstrates that Buildings 2 and 3 will be
visible from Interstate 5, impacting the view of the site across the
meadow, a “unique natural feature of the site” that, per the CZA, shall
be preserved (see staff interpretation above). The retention of the
existing trees between the meadow and the buildings provides some
screening of the building, however the screening is limited. The existing
vegetation that is to remain at this location is narrow in width
(particularly at the south end) in the existing condition, and these trees
are largely deciduous trees, which will result in significantly less
screening during the fall and winter than what is depicted on the Visual
Impact Exhibit. Additionally, the height of Building 2 will clearly exceed
the height of the retained trees as viewed from Interstate 5. Additional
screening is required. One option could be to plant additional evergreen
trees of a type that will exceed the height of the building at maturity. If
this option is selected, WFC (the forester) shall recommend a suitable
tree type for this location that will grow quickly and that will eventually
exceed the building height. The new trees shall be no less than 10 feet
Ms. Lisa Klein
November 11, 2021
Page 10
in height at the time of planting. The City is open to considering other
options at this location. The selected screening shall be depicted on
the revised View Impact Analysis.
Additional evergreen planting will be provided between the existing meadow
and the proposed development if necessary.
ii. Storm Pond #3 is partially located within the northern portion of the
meadow and in an area where the adjacent managed forest buffer is
also meadow (i.e., has no trees in its natural predeveloped condition).
Construction of Storm Pond #3 will therefore impact the meadow,
which is not acceptable as described above, and will require removal
of trees that could otherwise provide screening of the rear elevation of
Building 3 as viewed from Interstate 5. Storm Pond #3 shall be
relocated (potentially placed in an underground facility) so as not to
impact the meadow or screening of Building 3 as viewed from Interstate
5. Alternatively, you may propose relocation of the above ground pond
in a manner that demonstrate that view impacts will be mitigated.
See response to comment 18.b above and note that the pond has been
relocated to maintain a 50-foot buffer along the meadow.
iii. Storm Pond #2 is located between the 100-foot-wide Managed Forest
Buffer adjacent to Interstate 5 and the palustrine-forested and scrub-
shrub wetlands located adjacent to the rear side of the existing WTC
building. The rear side of the WTC building contains a storage yard and
loading area that is not visible from Interstate 5 today and the rear and
south building elevations have deteriorated and have no modulation or
architectural elements that are required for buildings of superior quality
that will be visible from a public right of way.
Construction of Pond #2 will require removal of a 145 – 170-foot-wide
swath of mature trees and native vegetation that will open the view of
the south and rear elevations of the existing WTC building. The
remaining vegetation will be the 100-foot wide Managed Forest Buffer
(which is partially meadow grass and transitions to forest to the north)
and the sparsely vegetated wetlands and wetland buffers. The
following menu of potential options for screening and mitigating view
impacts caused by Storm Pond #2 shall be considered and depicted
on the View Impact Analysis for additional review. Alternatively, you
may propose relocation or redesign of the pond in a manner that
demonstrates that view impacts will be mitigated.
Provide additional plantings in the Managed Forest Buffer. The
forester shall provide recommendations for the additional
plantings that retain the integrity of the “native” or predeveloped
conditions” of the MFB and are planted so as to provide
additional screening. New plantings shall be evergreen trees
that are at least 10 feet in height at the time of planting.
Provide additional screening of the rear side of the WTC
building by augmenting the wetland buffer plantings with
additional evergreen trees that are at least 10 feet in height at
Ms. Lisa Klein
November 11, 2021
Page 11
the time of planting. Provide documentation that the additional
plantings have been approved by the wetland biologist.
Provide additional landscape screening within the reconfigured
rear parking/storage area of the existing WTC building. The
screening would need to be of a depth and type that provides
effective screening.
Modify the rear and south elevation of the existing WTC
building to provide architectural treatments that are
complementary to the new buildings and represent “superior
quality.”
Relocate or redesign Storm Pond #2 to retain the trees in this
area. In lieu of an open pond, consider an underground facility
in the parking areas.
The proposed ponds have been relocated to reduce the impact and removal of
existing screening and vegetation. The revised plans result in a minimum 50-
foot-wide tree buffer along the meadow, which will be maintained, and
supplemental plantings added to reduce the visual impacts from Interstate 5.
d. The overall design of the buildings is not representative of the CZA
requirement that the buildings be of superior quality. The existing campus and
the headquarters and WTC buildings provide guidance as to what was
intended by “superior quality.” Additionally, when multiple buildings are
provided on the same site, they should create a unified, campus-like
development (a current code requirement but a common prerequisite for a site
with multiple buildings). The existing headquarters and visible sides of the
WTC buildings are relatively timeless in their design (i.e., not trendy), with
strong horizontal and rectangular lines and a significant amount of glazing.
The proposed building design, however, is not complementary to, or
reminiscent of the existing buildings. The mountain-themed paint scheme
serves to break up the façade but does not correlate to the existing buildings
or legacy of the site, which is more about trees and timber than mountain
views. Staff recommends elimination of the mountain paint scheme,
expansion of the vertical wood panels and incorporation of additional windows
to improve the building’s quality of design, and to provide a more
complementary design to the existing buildings and a design that is
representative of the legacy of the campus and of superior quality.
See response to comment #17. The design intent matches what has been
previously approved for Woodbridge, Buildings A & B, which was found to meet
the requirements of the CZA.
Wetlands and Streams
19. Review and address each comment in the enclosed January 25, 2021, review letter
from the City’s wetland consultant, ESA.
Please see the separate letter prepared by Wet.Land, dated October 10, 2021 for
responses to all of the comments provided by the City’s wetland consultant.
Ms. Lisa Klein
November 11, 2021
Page 12
20. Add the North Lake 200-foot Shoreline Management Zone to the plans, including the
area where improvements are planned to Weyerhaeuser Way (near Wetland BL) and,
if required, submit for a Shoreline Substantial Development Permit. See the ESA letter,
comment #10, for more details.
The 200-foot Shoreline Management Zone has been added to the plans, resulting in a
very small portion of the proposed improvements to Weyerhaeuser Way S being
located within the Shoreline Management Zone. A Shoreline Substantial Development
Permit will be submitted to cover these roadway improvements under separate cover.
SEPA Checklist
21. The revised SEPA checklist does not reflect all of the plan changes and additional
environmental information that has been prepared or updated. Update the SEPA
Checklist to reflect the updates and revisions made to the project. In particular, the
following is noted as needing to be updated:
a. Update the environmental information listed in A.8 to reflect revised/updated
studies and newly completed studies.
b. See the ESA comment letter on the review of the Talasaea Critical Areas
Report and Proposed Mitigation Plan dated April 9, 2020. Update the SEPA
Checklist in accordance to any updates/revisions made to the Critical Areas
Report. In particular, if a shoreline permit is required, update the list of
government approvals provided in A.10.
c. Include the wetland impacts and mitigation proposal in the project description
in A.11.
d. Update the wetlands information provided in B.3 and B.8.h to match the
updated Critical Areas Report and Mitigation Plan dated April 9, 2020, or as
updated based on ESA comments. The statistics provided appear out of date.
e. Update B.7 to address the existing pipelines (see Technical Review memo
from the Public Works Department dated November 3, 2020).
f. Update B.10.b and B.10.c to address altered views from Interstate 5 and how
the view impacts will be mitigated.
g. Are measures proposed to control light and glare impacts? Amend section
B.11 to address proposed light and glare mitigation measures.
h. Provide further clarification of what is meant by your intent to reconfigure onsite
trails in Section B.12. Which trails will be removed, and which will be reconfigured
to avoid dead-ends? Your comment response letter dated April 2, 2020, indicates
that many of the trails throughout the property will be retained in accordance with
the CZA purpose statement (your Comment 5). Please clarify.
i. Update section B.13. Include a description of the Cardno Cultural Resources
Study dated March 16, 2018 and address the findings.
The SEPA checklist has been updated to reflect all the plan changes and additional
environmental information that has been prepared. The updated checklist is attached
with this resubmittal.
22. The Cardno Report did not include information regarding correspondence with DAHP or
the Tribes. Your letter responding to public comments indicates in Item 4 that the report
will be submitted to DAHP. Did you provide a copy of the report to DAHP for their
comment? If so, provide copies of all correspondence and/or comments that were received
following DAHP’s review of the Cardno report.
Ms. Lisa Klein
November 11, 2021
Page 13
Cardno completed a reconnaissance-level survey within the entire former
Weyerhaeuser Corporate Headquarters campus. The reconnaissance-level survey
evaluated the historical significance and National Register eligibility of the campus.
Michael Houser and Holly Borth of the DAHP discussed the historic district with Cardno
via video conference on April 10, 2020 and during an on-site visit on June 24, 2020.
The DAHP correspondence that concurred that the Weyerhaeuser Corporate
Headquarters Historic District was eligible for listing in the NRHP at the national level
of significance on October 21, 2020 is included with this resubmittal.
Comments from Kevin Peterson – Public Works Development Services,
(253) 835-2734, Kevin.peterson@cityoffederalway.com
Prior to Land Use approval, the applicant shall address the following Technical Review
comments:
Use Process
23. Provide a breakdown of impervious surfaces on the site plan cover sheet: total impervious
area for the entire project, total new impervious area (as defined in the King County Surface
Water Design Manual - KCSWDM), and total replaced impervious area.
The breakdown has been added on the site plan cover sheet.
24. Based on the Boundary Line Adjustment (BLA) currently under review for this project, it
appears that Pond 1 is isolated on a separate parcel, without adequate space to locate a
building, and therefore cannot be allowed as it does not create a ‘buildable lot’, as defined
in FWRC Section 19.105.010. In addition, it appears that the current proposed BLA
property lines may either cross through or are very close to Ponds 2 and 3. These ponds
shall be located completely within property boundaries and meet property line setbacks as
required in the design criteria of the KCSWDM. Clearly show the proposed new property
lines that are delineated on the BLA(s) currently under review with the City.
The prior BLA applications (File Nos. 20-10116 and 20-103511) have been withdrawn.
We anticipate a condition of approval of this Process IV application will be to process a
BLA concurrent with building permits to align property lines with the final configuration of
the development.
25. Pond 5: Access to this pond shall be provided on-site, no access allowed from either
S 336th St or Weyerhaeuser Way S.
Access to Pond 5 has been provided from within the site.
26. It is difficult to see what, if any, Solid Waste & Recycling amenities are being provided.
Show and/or otherwise indicate on the plans where the SW&R facilities are located and
provide some basic design details on the enclosures.
There are large trash enclosures located at each building. These will be utilized for
Solid Waste and recycling. The typical design can be found on Sheet A1.0. Additional
waste and recycling area’s will be provided within the buildings as part of future tenant
improvements.
Ms. Lisa Klein
November 11, 2021
Page 14
27. Street trees shall be 2.5-inch caliper, per City standards.
Street trees are specified in the Plant Legend as 2.5-inch caliper, as required per City
standards.
Technical Information Report (TIR)
28. Based on the information provided, it appears the project is under the threshold for Large
Project Drainage Review and is now subject to Full Drainage Review requirements of the
2016 KCSWDM.
This comment has been noted, Full Drainage Review is now specified in the Project
Overview of the TIR.
29. There appear to be essentially 2 primary threshold discharge locations – 1 to the south and
into the Weyerhaeuser Pond and 1 to the east into North Lake, which eventually
discharges into the Weyerhaeuser Pond. In the Existing condition, approximately 24 acres
of the site discharges to North Lake, yet in the Developed condition, it appears only 13.14
acres are discharging to North Lake, with the remainder discharging to the Weyerhaeuser
Pond. The requirement is to maintain, as closely as possible, the hydrology to each
discharge location so as not to create adverse impacts by increasing or decreasing flows
to one basin or the other.
The existing 24-acre basin will change shape from existing to developed conditions, but
the overall area of the basin tributary to North Lake will remain generally the same. As
shown on the Developed Basin Map in Appendix A of the TIR, there is an area of
approximately 4.7 acres that was originally part of the 24-acre basin that will now drain to
the Weyerhaeuser Pond. To make up for this difference an area of 3.0 acres was added
to Basin 1, leaving 1.7 acres of difference between the original 24-acre basin and the
proposed 22.3-acre basin. To bring the system back into balance, up to an additional 1.7
acres of building roof will be reallocated from Basin 2 to Basin 1 during final design (based
on the currently proposed site layout) to maintain the 24-acre basin total that drains to
North Lake.
30. The report indicates that an additional 3.43 AC-FT of live storage from this project is
being directed to the Weyerhaeuser Pond on the old headquarters building site:
a. Provide an estimated depth of water that will be added across the existing pond
(i.e., x.xx-feet +/- depth of water added across the existing pond surface;
existing WS Elev=xxx.xx’, New WS Elevation=xxx.xx’).
The TIR narrative and calculations have been revised to send 3.68 acre-feet of live
detention volume to the Weyerhaeuser Pond which has a mean water surface area of 8.07
acres. The increase in ponding depth of the Weyerhaeuser Pond during the 100-year
storm event (conservatively not taking into account the slope of the shore at the waterline)
would be approximately 0.46-feet (5.5-inches) across the existing pond surface. The
increase in water elevation is from 356.5 to 356.96.
This increase in volume and associated ponding depth is acceptable because it is less
than the design capacity of the previous adjustment.
Ms. Lisa Klein
November 11, 2021
Page 15
b. Provide a copy of the approved and/or as-built plans for the 2004 headworks
modification to the Weyerhaeuser Pond.
A copy of the plans has been included with this submittal. These plans were printed from
AutoCAD to PDF, but ESM does not currently have the official approved plans (dated July
13, 2004) or as-built plans. We do have additional project documentation available if
needed, including City project number 04-101908, the storm drainage report, as well as
communication correspondence during construction.
31. Pond 2, as currently designed, has a detention capacity greater than 10 acre-feet with an
impounding berm over 6-feet in height. As such, this detention pond will need to comply
with the State Department of Ecology regulations and review process for dam safety
(KCSWDM Section 5.1.1, WAC 173-175) – this should be identified in the TIR.
The Pond 2 detention storage volume has been reduced to 9.32 acre-feet to fit the revised
project and is now below the threshold necessitating dam safety review and compliance.
32. The WWHM analysis for Pond 5 shows it to FAIL. The analysis needs to indicate the
facility to PASS, and the pond shall be designed and analyzed to meet the PASS
condition. Otherwise, provide a narrative in the TIR that provides an explanation of the
Pond 5 analysis FAIL condition.
Pond 5 has been revised to show a Pass condition in the WWHM output with a modeled
volume of 5.40 acre-feet. Pond 5 detention volume was then reduced to 1.72 acre-feet to
send 3.68 acre-feet downstream to Weyerhaeuser Pond and the Pond 5 control structure
was revised to attenuate the intermediate flows generated from the split detention volume.
33. From the November 2017 pre-application meeting summary letter: ‘...the site is near
an identified Sphagnum Bog (Core Requirement 6.1.4 of the KCSWDM). The
applicant’s engineer shall demonstrate in their storm water technical analysis if and/or
how the project does (or does not) impact this bog, and the means of providing water
quality treatment to meet the Sphagnum Bog treatment criteria if storm water runoff
affects the bog.’ Based on the topographic mapping provided, it appears that some
portion of the site, at the NE corner, does discharge into the Bog, including a portion
that is being developed with parking and drive aisles. Please provide the analysis as
requested from the pre-application meeting summary.
Figure 1.2 has been updated to show the drainage basin outline that goes to the identified
Sphagnum bog. The developed site has been designed such as to direct all proposed
impervious areas to detention and water quality treatment facilities. Specifically, the
pollution generating impervious area at the NW corner has been designed to discharge to
Pond 2.
34. The TIR must also examine the Hylebos Executive Proposed Basin Study and the projects
impacts upon the East Hylebos recommendations and the Basin Wide recommendations.
The TIR shall include a section that provides an analysis of the project and how it meets
the requirements of - and/or does not further impact - drainage-related issues that are
identified in the study.
A memorandum has been added to the TIR (Appendix C) that addresses this comment.
Ms. Lisa Klein
November 11, 2021
Page 16
SEPA
35. According to the plans and survey provided, as well as project materials reviewed by
the City in the immediate vicinity of this site (and unrelated to this project), there is a
buried, 14-inch Olympic oil pipeline that runs through the west side of the project site.
There may also be a buried gas main that extends south through the northeast portion
of the site. These 2 pipelines shall be disclosed/identified under section B.7.a.2 of the
SEPA checklist, with proposed measures to protect these pipelines under section
B.7.a.5 of the checklist.
The SEPA Checklist has been updated to reflect these 2 pipelines running through the
project site.
Comments from Sarady Long – Public Works Traffic Division,
(253) 835-2743, sarady.long@cityoffederalway.com
The Public Works traffic Division has finished its review of the submitted materials. The
following technical review items must be address. Please note, these comments did not include
comments from WSDOT. Traffic related comments/concerns by WSDOT must be addressed
and approved by WSDOT.
Plans Comments
36. The submitted plans depicted the correct Type K street section and right-of-way
dedication for S 336th St and Weyerhaeuser Way S. However, the plans did not show
street improvement and potential right-of-way dedication at the S 336th St and
Weyerhaeuser Way S roundabout. ADA compliant pedestrian facilities must be
provided at the roundabout. Unless a street modification is approved by the Public
Work Director, the submitted plans must show improvement at the roundabout.
No dedication is necessary for the roundabout at S 336th St and Weyerhaeuser Way
S, and ADA compliant pedestrian ramps have been added to the plan set. Street
improvements tie into existing prior to the S 336th Street Roundabout. Additional details
of these designs will be provided during the construction document review process at
a later date.
37. Provide a truck turning diagram to ensure the roundabouts on Weyerhaeuser Way S
can accommodate the expected trucks.
Truck traffic is anticipated to enter/exit the site from the north; therefore, no new truck
traffic is anticipated to utilize these roundabouts. In the rare case that a truck exits the
site to the south, we have verified the adequacy of the roundabouts and confirmed they
can handle a WB-67 truck.
38. Pavement design and upgrade may be necessary on Weyerhaeuser Way S and S
336th St in order to accommodate the expected truck traffic generate by the proposal.
The applicant must perform pavement evaluation demonstrating that the standard
pavement section for a Type “K” street is adequate to handle the expected traffic load
generating by the proposal.
Ms. Lisa Klein
November 11, 2021
Page 17
Please refer to the GeoEngineers Pavement Analysis report dated August 16, 2021
included with this resubmittal.
39. The proposed northerly driveway must meet separation distance from the future S
324th St and Weyerhaeuser Way S intersection. Please coordinate with the City
Center Access Study team to determine the future intersection and S 324th St
alignment.
The applicant is coordinating with the City Center Access Study team. The future
alignment of S 324th Street and its intersection with Weyerhaeuser Way S have not
been approved. The northerly driveway meets separation distances with the current
design of this future intersection. The City may not delay or condition the Project based
on a future, as yet undetermined condition that is not caused by the Project.
40. Submit a Vehicle Turning Diagram to the Public Works Traffic Division showing how
the appropriate design vehicle can enter, maneuver, and leave the site without
encroaching onto opposing traffic lanes or mounting a curb. Please note, the maximum
driveway width is 30 feet for a two-lane two-way driveway and 40 feet for a three-lane
two-way driveway (FWRC 19.135.270). Driveway widths may be increased or modified
to radius driveways in order to provide adequate width for vehicles that may be
reasonably expected to use the driveway, as determined by the Public Works Director.
TENW has provided a separate AutoTurn memo that concludes our analysis for trucks
entering/exiting the site. All driveways are able to accommodate a WB-67 truck.
41. Show conceptual street lighting along the property frontage on S 336th St and
Weyerhaeuser Way S on the plans. Details design is not required at this time.
Preliminary pavement marking & illumination has been included in the submittal plan
documents. Additional details of these designs will be provided during the construction
document review process at a later date.
42. The depicted 25’wide manage forest buffer should not be within the proposed 106’
development reservation (right-of-way) for future S 324th St extension.
See response to Comment #12.
TIA Review Comments
43. Page 3 – The TIA identified the project buildout in 2022. However, the concurrency
application identified 2023 buildout. Please address this discrepancy.
The buildout year has been updated to 2023 in the Woodbridge Business Park Updated
TIA dated September 3, 2021.
44. Table 1 Page 7: Revise Weyerhaeuser Way S from S 320th St. to S 336th St classification
to a Minor Arterial instead of a Principal Collector. The remaining portion from S 336th St
(Roundabout) to SR 18 is classified as a Minor Arterial.
This comment has been addressed in the Woodbridge Business Park Updated TIA
dated September 3, 2021.
Ms. Lisa Klein
November 11, 2021
Page 18
45. Page 7 – Transit Service: Add King County Metro Route 181 on S 320th St
approximately 1/4 mile north of the site. Coordinate with Pierce Transit for any on site
transit related improvements requirement.
This comment has been addressed in the Woodbridge Business Park Updated TIA
dated September 3, 2021.
46. The TIA need to clarify or provide narrative on how the proposed ITE LUC 130 (Industrial
Park) is applicable to the development. From a technical perspective, the City concurs
with using the Transportation Institute Engineer (ITE) Trip Generation Manual 10th Edition
LUC 130 (Industrial Park) to estimate the trip generation for the development. Since the
actual tenant(s) is still unknown, Industrial Park land use consisted of manufacturing,
service, and warehouse facilities is appropriate. Please note, additional analysis may be
required if the trips generated by the actual uses exceed the trips identified in the traffic
report.
The Woodbridge Business Park Updated TIA dated September 3, 2021 includes
language regarding the use of ITE LUC 130 (Industrial Park) given the uncertainty about
the future tenant of the proposed project.
47. The TIA appears to utilize the same truck trip percentage for all analysis periods. Clarify
if the truck trip percentage from ITE Trip Generation Manual is specifically for all
analysis periods (weekday, AM, PM, and Saturday). If not, the TIA should address how
the proposed 15 percent truck trips would be applicable to all analysis periods.
The Woodbridge Business Park Updated TIA dated September 3, 2021 includes an
updated trip generation estimate for trucks based on truck trip rates documented in the
ITE Trip Generation Manual 10th Edition Supplement dated February 2020.
48. The proposed 2 percent annual traffic growth rate is acceptable.
Comment noted.
49. The proposed pipeline trips from surrounding developments such is acceptable.
However, the TIA should provide a separate figure or spreadsheet of these trips for
tracking purposes.
Comment noted. The Woodbridge Business Park Updated TIA dated September 3,
2021 includes a separate figure showing the pipeline project trip assignment.
50. Page 14 – Project Trip Distribution and Assignment: Provide clarifications on the AM,
weekday, and Saturday trip distribution. The narrative of the project trip distribution and
assignment appears to indicate that the AM, weekday, and Saturday project trips
distribution is generated and provided by the City. The Emme model plot provided by the
City is based on PM only with no distinction between car or truck trips.
The Woodbridge Business Park Updated TIA dated September 3, 2021 includes
additional language about how the City’s Emme model plot was used to distribute
project trips during the analysis periods.
Ms. Lisa Klein
November 11, 2021
Page 19
51. The adopted City Center LOS is based on average V/C and not individual V/C ratio of
each intersection. Provide narrative to clarify why other intersections in the City Center
were not included.
The Woodbridge Business Park Updated TIA dated September 3, 2021 includes
additional language regarding the analysis at City Center intersections.
52. The report identified all site access locations would operate at LOS D or better with v/c
less than 1.0. Provide right turn lane warrant analysis for truck access and storage
pocket at driveway with the highest volume.
The Woodbridge Business Park Updated TIA dated September 3, 2021 includes right
turn lane warrant analysis.
53. The AM and PM LOS analysis for S 320th St and 32nd Ave S is showing cycle length
of 173 seconds. The cycle length should not exceed 160 seconds.
The Woodbridge Business Park Updated TIA dated September 3, 2021 addresses this
comment.
54. Show critical movement for Stop controlled intersections. For example, Weyerhaeuser
Way S and S 323rd St is showing 0.00 v/c ration, but the NBT and SBT has 0.10 v/c ratio.
The Woodbridge Business Park Updated TIA dated September 3, 2021 addresses this
comment.
55. The trip assignment in Figure 6 through 8 depicted truck trips utilizing non truck routes and
traveling through residential neighborhood. Revise the truck trip assignment at intersection
5, 7, 9, 10 and 12 and recalculate the LOS for AM, PM, and Saturday. For example,
intersection #9 in Figure 6 depicted 5 truck trips west of the S 336th St and Weyerhaeuser
Way roundabout, which has been designated no truck except for local deliveries. Also,
intersection #7 (32nd Ave S & S 323rd St) has 18 truck trips going through the office
complex roundabout. These truck trips should be reassigned to intersection #6 (S 320th St
& Weyerhaeuser Way S).
The Woodbridge Business Park Updated TIA dated September 3, 2021 includes a
revised truck trip assignment. Few, if any, truck trips are anticipated to travel to/from
the west of the site on S 336th Street for local deliveries.
Currently Weyerhaeuser Way restricts trucks greater than 30,000 pounds (gross
vehicle weight) except for local deliveries.
Some truck traffic in the updated TIA was assigned to/from the south on Weyerhaeuser
Way based on existing travel patterns and future travel patterns estimated in the local
traffic model. This provides a reasonable evaluation of traffic impacts on Weyerhaeuser
Way to the south since some smaller trucks (less than 30,000 gross vehicle weight) are
anticipated to be generated by the Business Park.
Ms. Lisa Klein
November 11, 2021
Page 20
To ensure that trucks generated by the Business Park that greater than 30,000 gross
vehicle weight do not use Weyerhaeuser Way to/from the south, a condition may be
placed on the project to limit or restrict truck use, similar to the conditions placed on the
Building A project.
56. Intersection #2 (25th Ave S & S 320th St) – Change pm+pt to D.P+P.
The Woodbridge Business Park Updated TIA dated September 3, 2021 addresses this
comment.
57. Intersection #5 (32nd Ave S & S 320th St) – Change EBL and WBL from pm+pt to D.P+P.
The Woodbridge Business Park Updated TIA dated September 3, 2021 addresses this
comment.
58. Intersection #6 (Weyerhaeuser Way S & S 320th St) – Change WBL from pm+pt to D.P+P.
The Woodbridge Business Park Updated TIA dated September 3, 2021 addresses this
comment.
59. Table 6 on page 16 (Future 2022 Weekday Peak Hour Level of Service Summary):
Some of the study intersection does not match with Figure 10-13. For example,
intersection #6 in Table 6 depicted as Pacific Highway S / S 336th St. Update Table 6
to match Figure 10-13.
The Woodbridge Business Park Updated TIA dated September 3, 2021 addresses this
comment.
60. Weyerhaeuser Way Assessment – The City concurs that the 2022 future with project is
expected to meet the minimum street design standards for a Type K street.
Comment noted.
61. Traffic impact fee for commercial developments, fees shall be calculated based on the
impact fee schedule in effect at the time a completed building permit application is filed
and paid prior to permit issuance.
See response to comment #12 regarding TIF credit.
62. The City has determined that the S 320th St. / SR 5 and Weyerhaeuser Way S / SR 18
ramps intersections are located within WSDOT limited access. As such, WSDOT has
jurisdiction over these intersection and its respective LOS standards shall apply. Any LOS
failure and mitigation measures must be reviewed and approved by WSDOT.
Comment noted.
63. Forward update TIA to WSDOT for technical review comments.
The Woodbridge Business Park Updated TIA dated September 3, 2021 has been
forwarded to WSDOT for review.
Ms. Lisa Klein
November 11, 2021
Page 21
SEPA Checklist – Transportation
64. Transportation 14(c) – Revise this section to including right-of-way dedication of 106’
for future S 324th St extension.
Comment noted. Please note the response to comment #12 regarding TIF credit.
Comment in letter from Kevin Peterson – Sr. Engineering Plans Reviewer dated March 22,
2021
The owner is required to set aside a tract of land along the North boundary/Northwest corner of the
property in order to accommodate the planned roadway known as the South 324th St Extension
(also known as the City Center Access Project). The tract boundary(ies) should follow the limits of
the proposed roadway alignment as it affects the IRG property, as depicted on the IRG Preliminary
Road Design Plan Draft and which was presented in the March 1, 2021 Federal Way City Center
Access Project – Presentation to IRG – Design Meeting PowerPoint presentation. The tract shall be
set aside by way of the City’s Tract ‘X’ agreement, which is not considered a subdivision of land.
The project has set aside a 106’-wide area to accommodate the City’s future extension of S
324th St. This can be accommodated as a separate tract once the final design of this roadway,
including its intersection with Weyerhaeuser Way S are approved.
Comments from Jessica Redman and Ilon Logan for the Critical Areas Report and Proposed
Mitigation Plan Review Comments and Recommendations dated January 25, 2021
Please see the attached Response to City Comments letter by Wet.land, dated October 10,
2021.
If there are any questions or a need for further clarification, please feel free to contact me at
(253) 838-6113 and I would be happy to discuss them with you.
Sincerely,
ESM CONSULTING ENGINEERS, LLC
ERIC G. LaBRIE, A.I.C.P.
President
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