21-100325-SEPA MDNS Responses-01-29-2021-V1
January 29, 2021 Job No. 1886-001-016-011
Ms. Stacey Welsh, Planning Manager
City of Federal Way
33325 8th Avenue South
Federal Way, WA 98003-6325
RE: File #17-104237-SE
SEPA MDNS Condition Responses
Woodbridge Building “B”; 3120 S 344th St, Federal Way
Dear Stacey:
On behalf of Federal Way Campus, LLC, ESM Consulting Engineers, LLC is pleased to submit
the following narrative identifying how we are addressing each of the Conditions of Approval
attached to the SEPA Mitigated Determination of Nonsignificance (MDNS) decision found in
“State Environmental Policy Act Mitigated Determination of Nonsignificance” dated October
9th, 2020.
In an effort to provide the City with clear direction on how each SEPA Condition is being
addressed, we have copied each Condition of Approval below in italics font and included a short
response as to how the Condition has or will be met and where it can be found in bold font.
1) Prior to building permit issuance, the applicant shall submit an evaluation of the facility
design by a qualified professional to ensure that the types and numbers of equipment
to be installed at the warehouse, as well as warehouse activities, are consistent or
similar to those identified in the noise report (Greenline Building “B” Development,
Federal Way Washington Environmental Noise Report, Ramboll Environ, July 2018).
This is a speculative warehouse with no tenant designated at this time. Warehouse
equipment and activities evaluation shall be deferred until the tenant improvement
phase.
2) The following measures shall be implemented during project construction with
quarterly reports submitted by the applicant to the city documenting compliance
starting from the issuance of the building permit and concluding at the issuance of a
Certificate of Occupancy:
a) All equipment shall be fitted with properly sized mufflers, and if necessary, engine
intake silencers.
b) All equipment shall be in good working order.
c) Use quieter construction equipment models if available and whenever possible use
pneumatic tools rather than diesel or gas-powered tools.
d) Place portable stationary equipment as far as possible from existing residential and
noise-sensitive commercial areas, and if necessary, place temporary barriers around
stationary equipment.
Ms. Stacey Welsh
January 29, 2021
Page 2
e) For mobile equipment, consider placement of typical fixed pure-tone backup alarms
with ambient-sensing and/or broadband backup alarms.
Comment noted.
3) A detailed review of final operating conditions shall be completed to ensure that the
noise study accurately and conservatively reflects future project operation. A report
documenting the assessment shall be submitted to the city six months after the
Certificate of Occupancy is issued.
Comment noted. The report will be submitted within 6 months of a specific tenant be
awarded a Certificate of Occupancy.
4) If the proposed use of the building includes cold storage, processing, or manufacturing,
the air quality analysis (Greenline Building “B” Development, Federal Way Washington
Air Quality Report, Ramboll Environ, June 2018) must be revised and SEPA threshold
determination revisited prior to building permit issuance, or if no building permit is
required, then prior to business license issuance.
This is a speculative warehouse with no use designated at this time. Compliance will
be determined during the future tenant improvement permit or if no permit is required,
then prior to business license issuance.
5) The following measures shall be implemented during project construction with
quarterly reports submitted by the applicant to the city documenting compliance
starting from the issuance of the building permit and concluding at issuance of the
Certificate of Occupancy:
a) Use only equipment and trucks that are maintained in optimal operational condition.
b) Require all off road equipment to be retrofit with emission reduction equipment (i.e.,
require participation in Puget Sound region Diesel Solutions by project sponsors and
contractors), including particulate matter traps and oxidation catalysts to reduce
MSATs.
c) Use biodiesel or other lower-emission fuels for vehicles and equipment.
d) Use carpooling or other trip reduction strategies for construction workers when
possible.
e) Stage construction to minimize overall transportation system congestion and delays
to reduce regional emissions of pollutants during construction.
f) Implement restrictions on construction truck idling (e.g., limit idling to a maximum of
five minutes).
g) Locate construction equipment away from sensitive receptors, such as fresh air
intakes to buildings, air conditioners, and sensitive populations.
h) Locate construction staging zones where diesel emissions won't be noticeable to
the public or near sensitive populations, such as the elderly and the young.
i) Spray exposed soil with water or other suppressant to reduce emissions of PM10
and deposition of particulate matter.
j) Pave or use gravel on staging areas and roads that would be exposed for long
periods.
k) Cover all trucks transporting materials, wet materials in trucks, or provide adequate
freeboard (space from the top of the material to the top of the truck bed), to reduce
PM10 emissions and deposition during transport.
Ms. Stacey Welsh
January 29, 2021
Page 3
l) Provide wheel washers to remove particulate matter that would otherwise be carried
off site by vehicles to decrease deposition of particulate matter on area roadways.
m) Remove particulate matter deposited on paved, public roads, sidewalks, and
bicycle and pedestrian paths to reduce mud and dust; sweep and wash streets
continuously to reduce emissions.
n) Cover dirt, gravel, and debris piles as needed to reduce dust and wind-blown debris.
o) Route and schedule construction trucks to reduce delays to traffic during peak travel
times to reduce air quality impacts caused by a reduction in traffic speeds.
Comment noted. Measures to be implemented during project construction with
quarterly reports submitted to the city documenting compliance.
6) Prior to issuance of a Certificate of Occupancy, the applicant shall construct a
northbound left-turn lane on Weyerhaeuser Way South at the southerly driveway (truck
access) to provide safer and more efficient access into the site. The northbound left
(NBL) turn lane storage shall be designed to accommodate the 95th Percentile queues
length ensuring left-turn queues will not block the through traffic lane. The
channelization plan must be reviewed and approved by the city and WSDOT.
A channelization plan regarding the left-turn lane on Weyerhaeuser Way S was
submitted to WSDOT and we received the second round of review comments on
01/11/2021. These comments are currently being addressed.
7) Prior to building permit issuance, the applicant shall install weight limit signs on
Weyerhaeuser Way South from South 320th Street to the project driveway, and South
336th Street from 20th Avenue South to Weyerhaeuser Way South.
Weight limit signs will be proposed and installed prior to building permit issuance.
8) As such, prior to the Certificate of Occupancy issuance, the applicant shall provide a
fully executed bond for 120 percent of the engineer’s estimate for design and
construction costs to upgrade the existing pavement on Weyerhaeuser Way South,
from the proposed truck entrance to South 320th Street. The bond term shall be for a
period of three years from the time of notification by the applicant of full occupancy and
use of the facility, unless a shorter term is mutually agreed to in the implementation
agreement discussed below. The applicant shall provide the engineer’s estimate. […]
In the alternative, the applicant may choose to design and construct the implicated
roadway(s) identified by the city. For the purposes of this condition, a “truck” shall mean
a vehicle rated in excess of 30,000 pounds gross weight as discussed in Chapter 8.40
FWRC. Prior to building permit issuance, the applicant and the city shall enter into an
implementation agreement to set forth the conditions by which the city will monitor the
truck trips; how the city will make its determination that the applicant has exceeded the
28 or more truck trips per week; how notice will be provided to the applicant; the cure
period for the applicant to remedy the excess truck trips described in the above
condition; when the city will call the bond or require the applicant to construct the
implicated roadways; the bond conditions; and all other requirements deemed
necessary by the city.
Comment noted.
Ms. Stacey Welsh
January 29, 2021
Page 4
9) The existing pavement on Weyerhaeuser Way South (south of the site), from the
proposed truck entrance to the SR-18 interchange must be fully reconstructed
(subgrade soils and new pavement) to accommodate the expected truck traffic load.
The applicant shall provide pavement design for city review and approval prior to
engineering plans submittal. Once the pavement design is approved by the city, the
development shall perform full depth reconstruction of the roadway segment impacted
by the truck traffic.
The pavement design is being submitted with the building permit application.
10) Prior to issuance of a certificate of occupancy, the applicant shall construct right-turn
storage for the westbound SR-18 off-ramp to mitigate for the impact to the westbound
off-ramp to the satisfaction and with approval of WSDOT.
Comment noted. Prior to issuance of a certificate of occupancy, the applicant shall
construct a right-turn storage for the westbound SR-18.
11) Cumulative traffic impacts from Warehouses A and B and the Greenline Business Park
to the SR 18 westbound ramp intersection with Weyerhaeuser Way South shall be
evaluated and mitigated in a SEPA analysis addendum, and/or revision to the
Warehouses A and B TIA. PM peak hour cumulative impacts shall be included in the
TIA analysis, or added to the concurrency review for Warehouse A, as the city finds
most consistent with its regulations. The city shall determine if WSDOT has jurisdiction
over the SR 18 intersection. If WSDOT has jurisdiction over the SR 18 intersection,
WSDOT LOS standards shall be applied to the intersection and any necessary pro-
rata mitigation for Warehouse A shall be formulated in consultation with WSDOT, as
contemplated in Conclusion of Law No. 8 of the Final Decision. If WSDOT doesn’t have
jurisdiction over the intersection, city LOS standards shall be applied and pro-rata
mitigation for Warehouse A imposed as necessary. All mitigation shall be subject to
RCW 82.02.020 and constitutional nexus/proportionality.
An updated TIA (considering traffic from potential future development including
Building A, B, and the Business Park), and a memorandum including the calculation of
the pro-rata share of the mitigation for Building B, subject to RCW 82.02.020 and
constitutional nexus/proportionality is being submitted with this building permit
application.
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
LAURA BARTENHAGEN, P.E, LEED AP
Principal
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