20-101386-Response Letter to ESA Memo-09-11-2020-V1
Resource & Environmental Planning
15020 Bear Creek Road Northeast • Woodinville, Washington 98077 • Bus: (425)861-7550 Fax: (425)861-7549
25 August 2020 TAL-1572B
Ms. Stacey Welsh, AICP
Principal Planner, Community Development Department
City of Federal Way
33325 8th Avenue South
Federal Way, WA 98003
Via email: Stacey.welsh@cityoffederalway.com
REFERENCE: Woodbridge Building “A” – 3120 South 344th Street, Federal Way, WA
Permit #20-101386
SUBJECT: Response to ESA Comment Letter
Dear Stacey:
This letter is to respond to comments prepared by Ms. Jessica Redman at ESA dated 8 July
2020 regarding the City of Federal Way’s Conditions of Approval of the Woodbridge Building “A”
project located at 3120 South 344th Street in Federal Way. We have provided the text of each
comment or question verbatim in bold text. Our responses to each comment follow
immediately in standard font.
Review of Documents
In addition to the Response Letter, the following associated documents were reviewed by
ESA at the request of the City:
• Critical Areas Report and Buffer Averaging Plan – Greenline Building A (Talasaea,
revised February 10, 2020),
• Construction Plans for Woodbridge (formerly Greenline) Building A (ESM
Consulting Engineers, March 23, 2020),
• Landscape Plan for Woodbridge (formerly Greenline) Building A (ESM Consulting
Engineers, March 23, 2020), and
• Federal Way Parcel #2121049014 Drainage – Existing Conditions and Drainage
Study Summary (Talasaea, March 2, 2020).
Review Comments and Recommendations
Each of the Conditions of Approval reviewed by ESA has been copied below (in italics
font) followed by ESA’s review comments and /or recommendations.
Condition 4
Work is not allowed on Wetlands DP, DQ, DR, DT, Stream EA, and associated buffers, as
stream setback intrusions and improvements/land surface modifications in non-
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Resource & Environmental Planning
15020 Bear Creek Road Northeast • Woodinville, Washington 98077 • Bus: (425)861-7550 Fax: (425)861-7549
Concomitant Zoning Agreement (CZA) exempt wetland setbacks require USE Process IV
application review and approval per FWCC Sections 22-1312(c) and 22-1359(d).
ESA does not believe this condition has been met. Figures W2, W3, and W3.1 of the
Revised CAR show mitigation work in the majority of the buffers of Wetlands DP, DQ, DR,
DT, and Stream EA. Additionally, Sheet LA-04 of the Landscape Plan for Woodbridge
Building A (hereinafter referred to as the Landscape Plan) notes that portions of the
buffer of Wetland DR, near the east side of the proposed loading docks, may be
supplemented with additional vegetation if the existing vegetation does not meet the
Type 1 landscape screen. Per Condition 4, no work is allowed in these buffers, outside of
the wetland and stream buffer replacement areas (see Condition 12 below), without
obtaining further land use approval. ESA does not believe this condition has been met as
invasive species removal and mitigation plantings are proposed outside of the buffer
replacement areas. Furthermore, the storm drainage easement shown on the
Construction Plans and Landscape Plan crosses through the combined buffer of
Wetlands DT, EC, and EF, which is inconsistent with the figures in the Revised CAR.
The Project drawings, including Construction, Landscape, and Mitigation Plan sheets, have all
been revised to reflect the accurate post-development wetland buffers, Wetlands EC and EF
have been removed as these wetlands are being filled for this project, and all enhancement
plantings have been removed from within the remaining standard buffer areas. All proposed
supplemental plantings will be contained within the buffer addition areas only.
Condition 11
The following amendments shall be made to the critical area report prior to issuance of a
building permit:
(a) The amount of impact to the buffer of Stream EA is inconsistent between the text
in the Report and on Figure W1.2 in the Report. Section 7.2.3 – Stream Buffer
Averaging of the report states that 1,944 SF of the buffer area will be reduced and
2,235 SF of buffer area will be replaced. However, Figure W1.2 shows a reduction of
1,695 SF of stream buffer and a replacement of 2,359 SF. We recommend the Figure
and the Report be revised to show the correct quantities of reduction and
replacement.
ESA believes Condition 11(a) has been met. The amount of impacts to the buffer of
Stream EA (1,944 SF) is consistent in the text of the Revised CAR, as well as on
Sheet W1.2.
Comment noted. No further action necessary.
(b) According to the Buffer Averaging Plan in the Report (Sheet W1.2) only the
northwest portion of the buffer of Wetland DT is being impacted. However, several
sheets in the Site Plan show the entire wetland buffer being reduced to 50 feet. We
recommend the Report and plan sheets be revised as necessary to show the
correct buffer impact.
ESA does not believe this condition has been met. The buffers in the figures in the
Revised CAR are not consistent with those in the Construction Plans or Landscape
Plan. As mentioned above, the Construction Plans and Landscape Plan show the
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25 August 2020
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Resource & Environmental Planning
15020 Bear Creek Road Northeast • Woodinville, Washington 98077 • Bus: (425)861-7550 Fax: (425)861-7549
buffer of Wetland DT combined with the buffers of Wetlands EC and EF. No buffer
reduction or addition is apparent as shown in Figure W1.2 in the Revised CAR.
The Construction Plans and Landscape Plan have been revised to reflect no Wetland EC
or EF in the post-development condition, and the buffer of Wetland DT has been revised to
reflect the accurate post-development modified wetland buffer.
(c) The applicant shall show/label on Figure W1.2 the size of each area of buffer
reduction and replacement to demonstrate that each reduction is compensated for
at the location of the critical area where the reduction occurs. Adjustments shall be
made if necessary.
ESA believes Condition 11(c) has been met. The square footage of buffer reduction
and buffer addition for each critical area where buffer averaging is proposed (DQ,
DR, DT, and Stream EA) has been added to Sheet W1.2 in the Revised CAR to show
that buffer reduction will be adequately compensated by buffer addition.
Comment noted. No further action necessary.
Condition 12
Areas of wetland and stream buffer replacement shall be enhanced with native
vegetation, as necessary, to endure buffer function continues post-development.
Planting details shall be shown on the landscape plan submitted with the building permit.
ESA does not believe Condition 12 has been met. Figures W2.0, W3.0, and W3.1 of the
Revised CAR contain mitigation plantings in the majority of the buffers of Wetlands DP,
DQ, DR, DT, and Stream EA, that are not reflected in the Landscape Plan. No details for
wetland and stream buffer enhancements are included in the Landscape Plan as required
by Condition 12. Additionally, as described under our response to Condition 4, the
Revised CAR proposes mitigation work outside of the wetland and stream buffer
replacements areas, which would require further land use approval. Furthermore, under
Condition 12 in the Response Letter, the applicant describes invasive species clearing in
these buffers, as well as the removal of a gravel road in the existing buffer of Stream EA.
These actions would also require further land use approval under the CZA.
All enhancement plantings have been removed from within the remaining standard buffer areas
of Wetlands DP, DQ, DR, DT, and Stream EA. All proposed supplemental plantings will be
contained within the buffer addition areas. The Landscape Plan has been revised to reflect the
same supplemental plantings as identified in the Mitigation Plan to that these plans are
consistent with one another.
Condition 13
All subsequently submitted building and engineering plans shall show averaged critical
area buffers, including buffer replacement areas, and only buffers for critical areas that
will remain after development.
ESA does not believe this condition has been met. The Construction Plans clearly show
the averaged critical area buffers for Wetlands DQ and DR. The Landscape Plan only
shows the averaged buffer for Wetland DQ. Neither of the plans clearly show the
averaged buffers for Wetland DT or Stream EA. Additionally, Wetlands EC and EF, and
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25 August 2020
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Resource & Environmental Planning
15020 Bear Creek Road Northeast • Woodinville, Washington 98077 • Bus: (425)861-7550 Fax: (425)861-7549
their associated buffers, are shown on both the Construction Plans and Landscape Plan.
However, these wetlands will be filled as part of the proposal and therefore, should not
be included on either plan. Both the Construction Plan and Landscape Plan should be
revised so they are consistent and only show the buffers that will remain post-
construction.
The Construction Plans and Landscape Plan have been revised to be consistent with the
Mitigation Plan with regards to post-development buffers, as well as properly reflecting Wetland
EC and EF not being present in the post-development condition.
Condition 14
Installation of permanent signs and split rail fencing is required at the outer edge of the
wetland buffers for Wetlands DQ, DR, and DT, and shall be completed prior to final
inspection for the building permit.
ESA believes this condition has been met. Sections 7.3. and 7.4 of the Revised CAR
discuss the installation of critical areas fencing and signage, post-construction.
Additionally, the location of fencing and signage along the outer edges of Wetlands DQ,
DR, and DT is shown on Figure W1.2.
Comment noted. No further action necessary.
Condition 15
The boundary between the wetland buffers and contiguous land shall be identified with
permanent signs, which shall be a city-approved type designed for high durability. Signs
must be posted at an interval of one per every 150 feet and maintained by the property
owner.
As mentioned above, the applicant proposes the installation of critical area fencing and
signage along the outer edges of Wetlands DQ, DR, and DT. However, according to
Section 7.4 of the Revised CAR, signs will be installed every 100 feet. According to
Condition 15, as well as Federal Way Revised Code (FWRC) 19.145.180(2), signs must be
posted at an interval of every 150 feet. ESA recommends that Section 7.4 be revised to
reflect Condition 15 and FWRC requirements.
The Mitigation Plan has been revised to reflect critical area signage at intervals of 150 feet.
Condition 16
The City shall not issue any approvals to fill wetlands until all state, federal, or other
agency permits as may be required to fill the wetlands have been obtained and
verification provided to the City.
ESA understands that the applicant has already initiated the permit process. ESA agrees
that all necessary state and federal permits be provided to the City before issuance of
any local permits.
Comment noted. Copies of the Federal and State permits will be provided to the City upon
receipt.
Stacey Welsh
25 August 2020
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Resource & Environmental Planning
15020 Bear Creek Road Northeast • Woodinville, Washington 98077 • Bus: (425)861-7550 Fax: (425)861-7549
Condition 38
As stated in the King County Stormwater Design Manual (KCSWDM) Section 1.2.2.1, the
applicant shall submit a critical areas report for the offsite wetland on parcel 2121049014.
The critical areas report shall be completed as outlined in FWRC 19.145.080; reviewed by
an outside peer reviewer at the developer’s expense; and approved prior to approval of
the final TIR and prior to building permit issuance.
ESA reviewed the Federal Way Parcel #2121049014 Drainage – Existing Conditions and
Drainage Study Summary (hereinafter referred to as the Drainage Study) prepared by
Talasaea and dated March 2, 2020. The Drainage Study was submitted with the Building
Permit Application to meet Condition 38 as well as the Level 1 Downstream Analysis
required by the KCSWDM. According to the KCSWDM, the Level 1 Downstream Analysis
is composed of four tasks: 1) Define the study area; 2) Review all available information
on the study area; 3) Field inspect the study area; and 4) Describe the drainage system
and its existing and predicted drainage and water quality.
To summarize the Drainage Study, four wetlands (Wetlands CR/CS, CP, CQ, and F) and
one stream (Stream A) occur on the parcel. An additional stream (Weyerhaeuser Creek)
occurs offsite to the west. Wetlands CP and F are Category III wetlands, with a low
habitat score, and are allotted an 80-foot buffer per FWRC 19.145.420.
Wetland CR/CS and CQ are Category II wetlands. Wetland CR/CS has a high habitat score
and is allotted a 150-foot buffer; and Wetland CQ has a low habitat score and is allotted a
100-foot buffer per FWRC. However, under the 1994 Federal Way City Code (FWCC) and
the Concomitant Zoning Agreement (CZA) all wetlands are allotted a 100-foot buffer1.
Stream A is the primary drainage path on the parcel, which conveys water offsite to the
southwest through a culvert, and into Weyerhaeuser Creek. Weyerhaeuser Creek flows
into West Hylebos Creek, approximately 1.3 miles downstream. Both streams are fish-
bearing (Type F) streams and are allotted a 100-foot buffer under both FWRC 19.145.270
and the FWCC/CZA. Below are our findings and recommendation as a result of the review
of the Drainage Study as well as a June 4, 2020 site visit.
• ESA generally agrees with the boundaries of the four onsite wetlands. The
majority of flags were able to be observed during the June 4, 2020 site visit.
Stream A was also observed flowing through Wetland CR/CS.
Comment noted. No further action necessary.
• ESA also agrees with the rating and categorization of the onsite wetlands and
Stream A. However, according to the City, critical areas on the parcel are under
the jurisdiction of the FWRC and not the FWCC/CZA. Therefore, text, Table 1, and
Figure 5 of the Drainage Report should be revised to remove all references to
buffer widths under the FWCC/CZA.
Comment noted. See the revised Drainage Report.
• ESA agrees with the description of the drainage pattern on and offsite. Offsite
conditions were not observed in the field due to lack of access. However, ESA
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25 August 2020
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Resource & Environmental Planning
15020 Bear Creek Road Northeast • Woodinville, Washington 98077 • Bus: (425)861-7550 Fax: (425)861-7549
researched and reviewed available information regarding watershed hydrology
near the site, primarily the Hylebos Watershed Plan (EarthCorps, 2016). The
drainage pattern described in the Drainage Report is comparable to the drainage
pattern described and mapped in this study.
Comment noted. No further action necessary.
• Figure 6 of the Drainage Report shows the buffer of Wetland CR/CS to be 165 feet.
The figure should be revised to show the correct buffer width of 150 feet.
Comment Noted. Please see the revised Drainage Report.
• Figure 5 and Figure 6 of the Drainage Report shows a Stream X immediately
offsite to the west. Figure 6 shows Stream X to be a Type F stream with a 100-foot
buffer. However, the Drainage Report does not provide a description of Stream X
under the results of the field investigations. Based on the description of Stream A,
it appears that Stream X is likely a continuation of Stream A. ESA recommends the
report and/or figure are revised for consistency.
Comment noted. Minor revisions have been made to reflect that Stream X is likely a
continuation of Stream A.
Thank you for your comments. I hope this resolves any questions you have about the site. If
you have any questions or require additional information, please call me at (813) 846-1684.
Sincerely,
TALASAEA CONSULTANTS, INC.
Represented by:
Jennifer Marriott, PWS
Senior Wetland Ecologist/Project Manager
Attachments:
1. Revised Critical Areas Report and Buffer Averaging Plan, prepared by Talasaea
Consultants, revised 25 August 2020;
2. Revised Buffer Averaging Plan Sheets, Appendix C of the Revised CAR by Talasaea
Consultants (Item #1 above);
3. Revised Existing Conditions and Drainage Study Summary (Parcel #2121049014),
prepared by Talasaea Consultants, revised 25 August 2020.