ESA_Warehouse_A_BuildingPermit_Review_2020_0708_Final
July 8, 2020
Stacey Welsh, City of Federal Way Department of Community Development
Jessica Redman
Greenline Warehouse “A” Building Permit Critical Area Review – Final Version
At the request of the City of Federal Way (City), Environmental Science Associates (ESA) reviewed the
Response Letter to the Conditions of Approval, submitted by ESM Consulting Engineers (and dated March 24,
2020) and related reference documents for the property at approximately 33663 Weyerhaeuser Way in Federal
Way, Washington. The site is part of the former Weyerhaeuser Campus property which has recently been
renamed the Greenline Campus. The proposed Warehouse “A” is a 15.6-acre site that is a combination of
portions of two parcels (King County Tax Parcel Numbers 6142600005 and 6142600200) currently owned by
Federal Way Campus, LLC. The Response Letter to the Conditions of Approval (hereinafter referred to as the
Response Letter) was submitted to the City as part of the Commercial Building Permit Application for the
construction of an approximately 226,092 square foot warehouse on the site, along with associated infrastructure,
parking, and stormwater facilities. The Response Letter details how the applicant has addressed each of the
Conditions of Approval attached to the City’s Process III Project Approval dated February 4, 2019. The purpose
of this memo is to review the Response Letter and associated documentation for consistency with the Conditions
of Approval and applicable code. Per the City’s request, ESA’s review is limited to conditions regarding critical
areas, specifically Conditions of Approval 4, 11 through 16, and 38.
This property was first reviewed by ESA in October 2016 during a previous application for development by
Preferred Freezer Services, LLC. ESA’s review of the Preferred Freezer application was reported to the City in
the Critical Areas Report and Conceptual Mitigation Plan Review: Preferred Freezer Services LLC technical
memorandum (dated October 5, 2016). In March 2017, the Preferred Freezer land use application was amended to
instead develop a one-story general commodity warehouse known as Warehouse A. ESA again reviewed the
property under the Warehouse A application, which included wetland creation to mitigate for impacts to
wetlands. ESA presented findings to the City in the Critical Areas Report and Conceptual Mitigation Plan
Review: Greenline Warehouse technical memo (dated June 21, 2017). Site visits were performed for each of these
reviews. In March 2018, the application was revised again to include a buffer averaging plan instead of a
mitigation plan. ESA presented findings of this review in the technical memo titled Critical Areas Report and
Conceptual Mitigation Plan Review: Greenline Warehouse A Resubmittal (dated April 3, 2018). Review
comments and recommendations included in the April 3, 2018 memo were not addressed before the approval and
instead are included under the Conditions of Approval.
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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- 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.
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.
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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.
(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 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.
(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.
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.
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 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
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Construction Plan and Landscape Plan should be revised so they are consistent and only show the buffers that
will remain post-construction.
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.
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.
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.
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.
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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.
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.
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 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.
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.
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.
1 For additional information on the CZA, a pre-annexation zoning agreement with the City, please refer to ESA’s June 5, 2017 and April 3,
2018 review memos.