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22-100735-Project Narrative-02-16-2022-V1 February 16, 2022 Job No. 1886-001-016-011 Ms. Stacey Welsh, A.I.C.P. Principal Planner City of Federal Way 33325 8th Avenue South Federal Way, WA 98003-6325 RE: Woodbridge Building “B”, Clear and Grade EN Permit Submittal Dear Stacey: On behalf of Federal Way Campus, LLC, ESM Consulting Engineers, LLC is herein submitting this letter and application materials for an EN permit for the Woodbridge Building “B” project, to allow for early clearing and grading of the Building B site, prior to issuance of the building permit (21-100325-CO), currently under review. We have carefully reviewed the draft comments provided by the City on January 31, 2022 and are using this opportunity to address those comments that have an effect on the clearing and grading of the site as a way of verifying compliance with applicable land use decision conditions. We have listed each comment below in italic font along with our response in bold font. Community Development – Planning Division Comments 5. Civil Plans – The civil site plan is missing labels for one of the wetlands and the stream. Sheet EX-01 has been verified to include all wetland labels as well as Stream EA. 6. SWPPP – On page 4 the document states that there are no known critical areas on- site, and on page 7 it lists roads not near the project. SWPPP Page 4 has been revised to reflect the existing wetlands, and Section 2.1.2 has been revised to reflect the correct road names adjacent to the site. Public Works – Development Services Division Comments 9. Add the city’s inspection notification number (253-835-2700), and the “on call” utility locate number to the civil plan set. This information has been added to the cover sheet. 16. Per SEPA MDNS condition response letter, item 5(I) a wheel wash is required. Construction general permit SWPP plan must be revised to address this condition. Ms. Stacey Welsh February 17, 2022 Page 2 A wheel-wash detail has been added to sheet GR-06 and is referenced for the two construction entrances shown on sheets GR-02, GR-03, and GR-05. 22. Project information sheet shall be included with the following information. a. Project name b. Table of Contents c. Vicinity map d. Phone number of “On-call” utility locator. (811 or 1-800-424-5555) e. City’s Public Works Department Preconstruction/ Inspector notification phone number (253) 835-2700. f. Name and phone number of Surveyor. g. Name and phone number of Engineer. h. Name and phone number of owner/agents. i. Legal Description. This information has been shown on the cover sheet. 24. At least one plan sheet needs to show all boundary survey information that has been stamped by a professional land surveyor licensed in the state of Washington. Sheet EX-01 has been revised to include this information. 27. A clearing and grading site plan shall indicate trees to be retained with protection fencing. This information has been added on sheets GR-01 to GR-05. 28. Wetland shall be labeled with the number from the wetland inventory, or shall be labeled as (un-inventoried”, if such. Sheet EX-01 has been revised to show all wetlands on the property as un-inventoried. 29. The City’s standard approval block located in the lower right corner of all drawings. Permit number shown on top of approval block. The standard approval block and note have been added as requested. The permit number will be added as soon as it is known. 30. A Forester must be present to supervise the activities in environmentally sensitive areas and forest buffer zones. A note has been added to sheet TR-01 under the Tree Preservation Notes, to ensure the contractor will have a forester present as required. 53. Dam safety Compliance required. Detention pond is over 10-acre feet: Detention ponds and other open impoundment facilities must comply with requirements for dam safety (WAC 173-175). Under current regulations (as of February 2012), if the impoundment has a storage capacity (including both water and sediment storage volumes) greater than10 acre-feet above natural ground level and a dam height of more than 6 feet, then dam safety design and review are required by the Washington State Department of Ecology (Ecology). If the storage capacity is less Ms. Stacey Welsh February 17, 2022 Page 3 than 10 acre-feet above natural ground level, then the facility is exempt from Ecology review. If the dam height is less than 6 feet but capacity is greater than 10 acre-feet, then Ecology reviews on a case-by-case basis to determine the hazard potential downstream in the event of a failure. 13 Acre Feet – 67,165 SF, 9.5’ deep. The detention pond required live storage volume is 413,100 cubic feet (9.48 acre-feet) storing the Level 3 flow control of the 100-year storm event. The detention pond available volume is 445,090 cubic feet (10.22 acre-feet), providing an 8 percent factor of safety. The sediment storage volume is 50,150 cubic feet (1.15 acre-feet), for a total pond volume of 495,240 cubic feet (11.37 acre-feet). The maximum berm height between existing natural ground and the top of live storage is 5.7 feet, which is less than the 6 feet. Per WAC 173-175-020 Applicability (1), dated October 25, 2019: Only water that can be stored above natural ground level or which could be released by a failure of the dam is considered in assessing the storage volume. The volume of water that is stored 5.7 feet above natural ground level (elevations 376.3 to 382.0) is 346,525 cubic feet (7.96 acre-feet), which is the volume that is required to be under a maximum 10 acre-feet as to not trigger the dam safety requirement. In summary, the proposed stormwater detention pond stores less than 10 acre-feet with a 5.7 feet height berm and does not trigger the dam safety requirement. 55. The emergency overflow spillway shall be armored in conformance with KCSWDM Table 4.2.2.A. The spillway shall be armored full width, beginning at a point midway across the berm embankment and extending downstream to where emergency overflows re-enter the conveyance system (see Figure 5.1.1.B, p. 5-14). The emergency overflow spillway armor has been added in plan view and detail on sheet GR-05. City Condition #1: Future submittals related to this project shall contain the property’s most current legal description. Compliance Verification: January 2021 building permit submittal: Sheet EX-01 of the civil set has an outdated legal description. This updated description was obtained from King County Parcel Viewer: NORTH LAKE ADD TO EAST TACOMA LOT 7 FEDERAL WAY BLA #17-100484-SU REC #20171103900001 SD BLA BEING POR S 1/2 OF SE 1/4 16-21-4 & POR NW 1/4 & NE 1/4 & SE 1/4 & SW 1/4 21-21-4 & LOTS 1 THRU 8 BK 18 NORTH LAKE ADD TO EAST TACOMA & LOTS 8 & 10 THRU 15 & POR LOT 9 LOUISE'S NORTH LAKE TRACTS TGW RDS ADJ The legal description has been revised on sheet EX-01 as noted above. City Condition #9: The following amendments shall be made to the critical area report before issuance of a building permit: a. Include an analysis of wetland functions as required by Section 22-1356(b) of the 1994 FWCC. Ms. Stacey Welsh February 17, 2022 Page 4 b. If Talasaea is considering the built-condition of Building “A” to be the existing conditions for the Building “B” proposal, Sheet W1.0 of the revised report shall be revised to show the reduced buffers for Stream EA and Wetlands DT, DR and DQ to be consistent with the proposed buffers on Sheet W1.2 of the report for Woodbridge Building “A”. Currently, Sheet W1.0 shows the buffers as if Building “A” was not built. c. The applicant shall show/label on Sheet W1.1 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 that reduction occurs. Adjustments shall be made if necessary. d. The “buffer replacement for Parcel A” shown on Sheet W1.1 is not approved and shall be removed from Sheet W1.1. e. When ESA’s comments of inconsistencies between report text, figures, and the plan sheets are resolved in the submittal for Building “A”, the submittal documents for Building “B” shall be revised where necessary. Compliance Verification: January 2021 building permit submittal: The critical areas report submitted with the building permit is dated 9-1-17; the final version of the critical areas report reviewed during land use was dated 6-26-18. Land use condition of approval #9 also requires amendments to be made to the report. Once an updated report is received, peer review can proceed and comprehensive compliance verification with critical areas related land use conditions can occur. An addendum to the 2018 revised Critical Areas Report has been prepared that includes the most up-to-date discussion of the Project, in light of the approved Building A project, while addressing the additional information requested by the City. Additional discussions have been provided, as requested, including an analysis of wetland functions as required by Section 22- 1356(b) of the 1994 FWCC. Graphics that accompany the CAR have also been updated to reflect the approved Building A project as well as refining the buffer averaging proposed for thoroughness and accuracy. City Condition #11: 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. Compliance Verification: January 2021 building permit submittal: The critical areas report submitted with the building permit is dated 9-1-17; the final version of the critical areas report reviewed during land use was dated 6-26-18. Land use condition of approval #9 also requires amendments to be made to the report. Once an updated report is received, peer review can proceed and comprehensive compliance verification with critical areas related land use conditions can occur. Plan sheets have been revised to only reflect post-construction buffers where the proposed development is shown. City Condition #12: Installation of permanent signs and split rail fencing is required at the outer edge of the wetland buffers for Wetland DT and shall be completed before final inspection for the building permit. Ms. Stacey Welsh February 17, 2022 Page 5 Compliance Verification: January 2021 building permit submittal: The critical areas report submitted with the building permit is dated 9-1-17; the final version of the critical areas report reviewed during land use was dated 6-26-18. Land use condition of approval #9 also requires amendments to be made to the report. Once an updated report is received, peer review can proceed and comprehensive compliance verification with critical areas related land use conditions can occur. Permanent signs and fencing are shown along the outer perimeter, as requested. City Condition #13: The boundary between the wetland buffer 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 in perpetuity. Compliance Verification: January 2021 building permit submittal: The critical areas report submitted with the building permit is dated 9-1-17; the final version of the critical areas report reviewed during land use was dated 6-26-18. Land use condition of approval #9 also requires amendments to be made to the report. Once an updated report is received, peer review can proceed and comprehensive compliance verification with critical areas related land use conditions can occur. Signs are shown at 150-foot spacing around the critical areas to remain post-construction. City Condition #14: 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. Compliance Verification: January 2021 building permit submittal: not addressed. Final authorizations from WDFW, ECY and the USACE are included in this response. City Condition #40: The critical areas report referenced in the Preliminary TIR needs the date corrected. The reference will need to be updated in the final TIR. Compliance Verification: January 2021 building permit submittal: The TIR submitted with the building permit references an outdated version of the critical areas report. In addition, the critical areas report submitted with the building permit is dated 9-1-17; the final version of the critical areas report reviewed during land use was dated 6-26-18. Land use condition of approval #9 also requires amendments to be made to the report. The Critical Areas Report revised 6-26-18 is included with this submittal as well as a Critical Areas Report Addendum dated 2-16-22. The TIR report will be revised and submitted with the civil construction plan submittal, following this clear and grading plan submittal. The Forest Practices was submitted under separate cover (22-100345-AD). As part of this EN Permit Application, we are including electronic copies of the following materials. Hard copies can be provided if requested; however, due to the Covid-19 state of emergency, all materials will be submitted electronically. All the documents will be named according to the City’s standard naming conventions. Ms. Stacey Welsh February 17, 2022 Page 6 1. Cover letter (this letter) 2. Permit Application 3. Clearing and Grading Plans 4. SWPPP 5. Critical Areas Report 6. Critical Areas Report Addendum 7. Final Authorizations from WDF, ECY and the USACE 8. Haul Route and Traffic Control Plan 9. NPDES Permit If there are any questions or a need for further clarification, please feel free to contact me at (253) 838-6113 and we would be happy to discuss them with you. Sincerely, ESM CONSULTING ENGINEERS, LLC LAURA BARTENHAGEN, P.E., LEED AP Principal \\esm8\engr\esm-jobs\1886\001\016-0011\document\letter-009.docx