FINAL ESA_Warehouse_A_BuildingPermit_ResubmittalReview_March2021
March 15, 2021
Stacey Welsh, City of Federal Way Department of Community Development
Jessica Redman
Greenline Warehouse “A” Building Permit Critical Area Review – Review of Revised Documents
At the request of the City of Federal Way (City), Environmental Science Associates (ESA) reviewed the
Response to ESA Comment Letter, submitted by Talasaea Consultants (and dated August 25, 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 was renamed the Greenline Campus, and is
currently known as the Woodbridge 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 proposed Warehouse “A” project (Project) would construct
an approximately 226,092 square foot warehouse on the site, along with associated infrastructure, parking, and
stormwater facilities. ESA previously reviewed the applicant’s Response Letter to the Conditions of Approval
(submitted by ESM Consulting Engineers and dated March 24, 2020), which was part of the Project’s
Commercial Building Permit Application. ESA’s comments and recommendations were submitted to the City in
the technical memorandum titled Greenline Warehouse “A” Building Permit Critical Area Review – Final
Version (dated July 8, 2020). In response to these comments, the Response to ESA Comment Letter (hereinafter
referred to as the Comment Response) was submitted to the City as well as several revised documents that are
also a part of this review. These include:
Critical Areas Report and Buffer Averaging Plan – Greenline Building A (Talasaea, revised August 25,
2020),
Construction Plans for Woodbridge (formerly Greenline) Building A (ESM Consulting Engineers,
August 26, 2020),
Landscape Plan for Woodbridge (formerly Greenline) Building A (ESM Consulting Engineers, August
26, 2020), and
Federal Way Parcel #2121049014 Drainage – Existing Conditions and Drainage Study Summary
(Talasaea, August 25, 2020).
Greenline Warehouse “A” Building Permit Critical Area Review – Review of Revised Documents
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Review Comments and Recommendations
The comments and recommendations below only pertain to Conditions of Approval that were not met according
to our July 8, 2020 technical memorandum. These include Conditions 4, 11(b), 12, 13, 15, and 38. All other
Conditions were previously considered fulfilled and therefore, are not part of this review. Each Conditions of
Approval that was not met during our previous review has been copied below (in italics font) followed by ESA’s
review comments and /or recommendations, based on our review of the Comment Response and revised
documents listed above.
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).
Figures W2, W3, and W3.1 in the August 2020 version of the Critical Areas Report and Buffer Averaging Plan –
Greenline Building A (hereinafter referred to as the Revised CAR) have been revised to show proposed
enhancement as occurring only in the buffer addition areas of Wetlands DP, DQ, DR, DT, and Stream EA.
Additionally, Sheet LA-04 of the August 2020 version of the Landscape Plan for Woodbridge Building A
(hereinafter referred to as the Revised Landscape Plan) notes that enhancement may occur within the Managed
Forest Buffer (MFB) or within the buffer addition areas as identified in the Revised CAR. No work is proposed in
these buffers, outside of the wetland and stream buffer addition areas, and therefore further land use approval for
this area is not necessary. The storm drainage easement shown on the Construction Plans and Landscape Plan has
also been revised to be consistent with the figures in the Revised CAR. ESA believes this condition has been met.
Condition 11
The following amendments shall be made to the critical area report prior to issuance of a building permit:
(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.
The Revised CAR buffer figures are now consistent with those in the August version of the Construction
Plans (hereinafter referred to as the Revised Construction Plan) and the Revised Landscape Plan. As
stated in the Comment Response, Wetland EC and EF and their associated buffer have been removed
from the sheets showing the post-development condition, as they will be filled. Therefore, ESA believes
this condition has been met.
Condition 12
Areas of wetland and stream buffer replacement shall be enhanced with native vegetation, as necessary, to ensure
buffer function continues post-development. Planting details shall be shown on the landscape plan submitted with
the building permit.
ESA does not believe Condition 12 has been met. Figures W2.0, W3.0, and W3.1 of the Revised CAR have been
revised to only show enhancement plantings in the buffer addition areas of Wetlands DP, DQ, DR, DT, and
Greenline Warehouse “A” Building Permit Critical Area Review – Review of Revised Documents
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Stream EA, as recommended in our July 8, 2020 review memo. However, these revisions are not reflected in the
Revised Landscape Plan. ESA recommends that details for wetland and stream buffer enhancements are included
in the Landscape Plan as required by Condition 12.
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.
The Revised Construction Plans and Revised Landscape Plan show the averaged critical area buffers for
Wetlands DP, DQ, DR, DT, and Stream EA that will remain post-construction. Additionally, the buffers for
Wetland EC and EF have been removed from the Revised Construction Plans and Revised Landscape Plan, as
they will be filled as part of the project. ESA believes this condition has been met.
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.
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. In our July 8, 2020 review memo, ESA recommended that Section 7.4 of the CAR be revised to reflect these
requirements. ESA agrees that the revisions to Section 7.4 of the Revised CAR meet our recommendations and
therefore, this Condition has been met.
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.
After review of the August version of the Federal Way Parcel #2121049014 Drainage – Existing Conditions and
Drainage Study Summary (hereinafter referred to as the Revised Drainage Study), ESA believes that the majority
of our recommendations included in our July 8, 2020 review memo have been met. For example, Figure 6 has
been revised to show the correct 150-foot buffer for Wetland CR/CS. Additionally, Figures 5 and 6 have been
revised to show the former Stream X as a continuation of Stream A flowing offsite. However, the Revised
Drainage Study continues to include language and references to buffer widths under the FWCC/CZA. As stated in
our July 8, 2020 review memo, 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. These recommendations have not been reflected in the
Revised Drainage Study, and therefore, this condition has not been met.