Historic review ends abruptly

After eight months of biweekly meetings to hammer out federal mitigation for Industrial Realty Group’s Woodbridge A/B warehouse projects, the U.S. Army Corps of Engineers abruptly ended the process July 27, 2021, saying it has no jurisdiction to require IRG to obtain permits.

That means an easement to protect the façade of the headquarters building, view easements to protect the north and south meadows, and more robust landscape buffers to protect some campus views are no longer in play at the federal level on these two warehouses.

Those measures were negotiated by IRG and the state Department of Archaeology and Historic Preservation (DAHP) as part of the federal process known as Section 106. It’s a process that kicks in when a developer needs a federal permit to fill wetlands on a site. The Section 106 process considers negative impacts to historic resources of a development site and ways to avoid, minimize or mitigate those impacts.

In February, IRG requested that the Corps conduct an Approved Jurisdictional Determination for the Warehouse A/B sites. Based on a change in wetlands regulations during the previous administration, the Corps determined in July 2021 that “there are no water[s] of the U.S. within the review area,” which means a Corps permit isn’t required, according to correspondence from Lance Lundquist, Cultural Resources Program Manager for the USACE’s Seattle District.

A Section 106 review is anticipated for the Woodbridge Business Park, the three-warehouse development on the north end of the campus, which encompasses more significant wetlands.

IRG mitigation offer covers key areas of campus, but no guaranteed public access

At the Feb. 12, 2021, Section 106 meeting, Federal Way Campus (IRG) representatives presented their proposed plan to mitigate construction of 1.4 million square feet of warehouses on the historic Weyerhaeuser Campus. (Read the mitigation proposal here.)

The proposals cover general concepts, and IRG proposed for the details to be ironed out with the state Department of Archaeology and Historic Preservation after a memorandum of agreement is signed. However, it’s typical for the U.S. Army Corps is to have the details worked out with input from the consulting parties, before the agreement is signed, so the process is “transparent and open,” explained Lance Lundquist, the cultural resources program manager for the Corps’ Seattle District office, who is overseeing the mitigation discussions.

Most of IRG’s mitigation is proposed to offset construction of Warehouses A and B, neighboring the former headquarters building. The proposal includes an easement to preserve the exterior of the HQ building, protection of the south meadow viewshed, and creation of a 50-foot buffer along the loop or ring road across from the former headquarters building in an effort to screen the warehouses from view.

Trails, meadows and wooded areas would be managed for employees working on the campus, but no public access is guaranteed. IRG points out that the 1994 zoning agreement for the campus allows public access at the owner’s discretion, and IRG would take into account tenant desires and safety concerns.

In addition, mitigation is proposed for three warehouses on the north part of the campus. (That project, Woodbridge Business Park, totals more than 970,000 square feet and is currently under review by the city and the Corps of Engineers in separate permit processes.) The proposed mitigation is protection of the north meadow viewshed and a “voluntary forested buffer of 50 feet or greater” on the west (Interstate 5) side of the development, between the buildings and the meadow.

IRG’s mitigation does not mention protection of the Rhododendron Species Botanical Garden or the Pacific Bonsai Museum, which both sit on leased land on the campus, or conservation of the 54-acre North Lake shoreline, for which $4 million in grant money has been banked toward a potential purchase. Although IRG offered to sell the property with many conditions in 2019, one of its consultants sent an email to the Section 106 consulting parties on Feb. 11 saying the property is no longer for sale.

In addition, IRG values all of its proposed easements at $91.3 million; it only paid $70.5 million for the campus and has five warehouse projects that experts say will make a significant profit.

Read the official minutes of all the Section 106 meetings in the column at right, and learn more about the Section 106 below, and here.


 IRG asked to bring mitigation ideas

The historic significance of the former Weyerhaeuser campus is well established, and it’s been determined that warehouse development will cause adverse effects to the campus — so it’s time for Industrial Realty Group to bring forward “appropriate mitigation possibilities,” the state’s highest historic preservation official said.

The comments from Allyson Brooks, executive director of the state Department of Archaeology and Historic Preservation (DAHP) and the State Historic Preservation Officer (SHPO), came both at the January 29, 2021, U.S. Army Corps of Engineers Section 106 historic/cultural review meeting and in email correspondence afterward.

“I think we need to start actual negotiations,” Brooks said in a February 2 email to the consulting parties who meet biweekly to discuss ways to avoid, minimize or mitigation the planned warehouse development on the campus. The current conversation involves Warehouses A and B, totaling more than 400,000 square feet, on the southeast corner of the campus, neighboring the former Weyerhaeuser headquarters building.

Brooks is a key player in the Section 106 mitigation negotiations because she and the Army Corps are the legal signers to the mitigation agreement.

“I am very aware of everyone's viewpoints but the Section 106 process does not mandate a consensus preservation outcome,” Brooks wrote. “All parties need to start focusing on appropriate mitigation possibilities … we heard Dana [Ostensen] from IRG stating he is considering mitigation proposals.  It would be helpful to have these in writing from IRG in time for the next meeting.”

Brooks said her agency has “certain mitigation options we would like to see and would also like have mitigation options other than a [site] redesign from other parties so we can start having additional discussions and a resolution towards completing the MOA [Memorandum of Agreement]. “

During the January 29 meeting, Brooks noted her agency’s interest in preserving the main building and its views, the Pacific Bonsai Museum, the Rhododendron Species Botanical Garden, and campus trails. Focusing on a redesign of the A/B property, as some have advocated, might mean a lost opportunity to preserve other areas, she said.

Ostensen pointed out how much money IRG has been spending the maintain the campus since purchasing it in 2016 for $70.5 million. The headquarters building is not expected to be a profit center, he said. “They ask everyone to be aware that in order to preserve the campus and the building, they need an profitable engine,” and plan to limit development to the original master plan locations — proposed by a group of nationally/internationally known architects — would  not provide that, according to the official meeting minutes.

There was also discussion about the possibility of combining mitigation negotiations for the Warehouse A/B site and for the three warehouses planned on the north end of the campus around the existing Technology Center. The Corps is reviewing separate permits — one for the A/B site and one for the three warehouses on the north.

The minutes show that Betsy Merritt, deputy general counsel for the National Trust for Historic Preservation, said it is important to look at the campus holistically, considering cumulative effects from overall development, and that she would like to discuss both permits together. In agreement were Brooks and Charles Birnbaum, president and CEO of The Cultural Landscape Foundation.

The next Section 106 meeting is Friday, February 12.

Read the official minutes of all the Section 106 meetings in the column at right, and learn more about the Section 106 below, and here.


What should I know about Section 106?

IRG needs a permit from the U.S. Army Corps of Engineers to fill wetlands on the Warehouse A/B site in the southeast corner of the campus, and a separate permit to fill wetlands on the Greenline Business Park site on the north end of the campus.

As a result, the Corps must determine how to avoid, minimize or mitigate adverse effects to the historic campus caused by the issuance of its permit for the development.

The process, called Section 106, involves regular meetings of official consulting parties to discuss options. The goal is coming up with mitigation that is both meaningful and reasonable, as explained by Lance Lundquist, cultural resources program manager, regulatory branch, for the Seattle District of the Corps of Engineers. Lundquist is leading the biweekly mitigation discussions for the Warehouse A/B site; the separate Section 106 for the Greenline Business Park has not begun.

Save Weyerhaeuser Campus is an official participant in the discussions, along with the Washington Trust for Historic Preservation, the National Trust for Historic Preservation, The Cultural Landscape Foundation, the state Department of Archaeology and Historic Preservation (DAHP), King County Historic Preservation, SoCoCulture, SWA Group (landscape architecture and urban design), Skidmore, Owings & Merrill (SOM, the original architects of the campus), and of course Federal Way Campus (IRG). At the January 15 meeting, legendary landscape architect Peter Walker, who designed the campus landscape, also participated. Read more.

Learn more about the Section 106 process.