22-102123-UP-Pre app summary letter-05-09-2022,ACITY OF
�L Federal Way
April 20, 2022
Kris Stamon
McGranahan Architects
2111 Pacific Avenue Suite 100
Tacoma, WA 98402
Kris.stamon()a,mcuanahan.com
33325 8ch Avenue
South
Federal Way, WA 98003-6325
253-835-7000
www.eityof'federal way. com
Jim Ferrell, Mayor
Re: File #22-101129-00-PC, PREAPPLICATION CONFERENCE SUMMARY
Federal Way Memorial Field Renovation - 1300 South 308" Street, Federal Way
King County Parcel number 082104 9001
Dear Mr. Stamon:
Thank you for participating in the preapplication conference with the City of Federal Way's Development
Review Committee (DRC) held April 7, 2022. We hope that the information discussed at that meeting
was helpful in understanding the general requirements for your project as submitted.
This letter summarizes comments given to you at the meeting by the members of the DRC. The members
who reviewed your project and provided comments include staff from the City's Planning and Building
Divisions, Public Works Department, and representatives from Lakehaven Water and Sewer District and
South King Fire and Rescue. Some sections of the Federal Way Revised Code (FWRC) and relevant
information handouts are enclosed with this letter. Please be advised, this letter does not represent all
applicable codes. In preparing your formal application, please refer to the complete FWRC and other
relevant codes for all additional requirements that may apply to your project.
The key contact for your project is me, Jim Harris, 253-835-2652, iim.harris@cityoffederalway.com. For
specific technical questions about your project, please contact the appropriate DRC representative as
listed below. Otherwise, any general questions about the preapplication and permitting process can be
referred to your key contact.
PROJECT DESCRIPTION
Renovations and upgrades to existing Memorial Stadium. Consists of new construction of grandstands
and support buildings; T.I. in existing building for team rooms; maintenance to track and field surfacing;
upgrade to existing south parking lot.
MAJOR ISSUES
Outlined below is a summary of the major issues of your project based on the plans and information
submitted for preapplication review. These issues can change due to modifications and revisions in the
plans. The major issues section is only provided as a means to highlight critical requirements or issues.
Please be sure to read the comments made by all departments in the following section of this letter.
Kris Stamon
April 20, 2022
Page 2
• Planning Division
1. Proposed 100-foot tall light poles exceed 55-foot tall maximum height limit for this zone and land
use.
2. SEPA and Process III land use review required.
3. Community Design Guideline review required in conjunction with Process III review.
• Public Works Traffic Division
• Transportation Concurrency Management (FWRC 19.90) — A Transportation concurrency
permit with application fee of estimated $9,972 (51 - 500 Trips).
• Transportation Impact Analysis (TIA) — A trip generation study prepared by a licensed
engineer in Washington is required to determine the number of trips generated by the
development.
• Traffic Impact Fees (FWRC 19.91) - Traffic impact fees payment will be assessed at building
permit submittal.
• Frontage Improvements (FWRC 19.135.040) — It appears the proposal will not exceed the 25%
threshold for frontage improvement.
• Access Management (FWRC 19.135.260) — The development shall meet access management
standards.
DEPARTMENT COMMENTS
Outlined below are the comments made by the representatives of each department present at the
preapplication conference. Each section should be read thoroughly. If you have questions, please contact
the representative listed for that section.
COMMUNITY DEVELOPMENT — PLANNING DIVISION
Jim Harris, 253-835-2652, jim.harris(ti,,citl/offedei-alway.com
1. Zoning Designation and Use —The subject property is zoned Community Business (BC). The
proposed use of a school is permitted in the BC zone subject to regulations outlined in FWRC
19.220.040.
2. State Environmental Policy Act (SEPA) — According to information submitted with the pre -
application materials, Federal Way Public Schools is going to act as the SEPA Lead Agency. Please
provide notice of all SEPA process and actions to the City of Federal Way Community Development
Department.
3. Land Use Application — The proposed stadium and field construction requires Use Process III, which
is an administrative land use review process conducted by city staff with a final decision issued by
the Community Development Director. The Process III decision criteria are contained in FWRC
19.65.100(2).
You have inquired about a potential increase in height over the permitted maximum height of 55-feet
in regard to the field light poles. Further details about both administrative variance and Hearing
Examiner variance are included in section 9 below. In summary, if a requested variance exceeds the
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administrative variance threshold discussed in section 9 below, a Process IV Hearing Examiner Land
Use review including a height variance would be required in lieu of the Process III application.
FWRC 19.70.010 states: If the development, use or activity that requires approval through process II
or III is part of a proposal that also requires approval through process IV, the entire proposal will be
decided upon using process IV, if the director determines that will result in more efficient decision
making.
Typically, the Director has determined in circumstances like this, where a variance is requested as a
component of the site development, then the whole project is reviewed under Process IV, in order to
make more efficient decision -making.
Under Process IV, following compliance with SEPA regulations, the Community Development
Director will issue an administrative decision on the Community Design Guideline component of the
project per FWRC 19.70.010. Following the design decision, City staff will provide a written
recommendation to the Hearing Examiner on the site plan and in this case a height variance. The
Hearing Examiner will hold a public hearing on the application, and issue a written decision on the
application within approximately two weeks following close of the hearing.
4. Land Use Review Timeframes — The Planning Division will notify the applicant of the application
status within 28 days of submittal. If the application is determined complete, staff will issue a Letter
of Complete Application. The FWRC limits the administrative review to 120 days from the date of a
complete application. The 120-day review period will stop any time the applicant has been requested
by the city to correct plans, perform required studies, or provide additional information needed to
issue a decision. The review period will begin within 14 days following submittal of requested items.
Please be advised that any City request for corrections and/or additional information must be
provided within 180 days of written notification, or the land use application will expire.
5. Public Notice — Process III applications require a public notice and comment periods. Within 14 days
of issuing the Letter of Complete Application, a Notice of Application (NOA) will be published in the
Federal Way Mirror, posted on the subject property, and distributed as required by FWRC 19.65.070.
The applicant will be required to post city supplied notice boards at the appropriate times. City staff
will prepare the 300-foot mailing.
Land Use Process III Application Fees & Submittal — Refer to the enclosed, "Submittal Requirements
for Use Process III or IV," to determine what materials must be submitted with the land use
application. All project submittals must be submitted electronically. Please visit the city's website to
request a document upload link for submittal: www.cityoffederalway.com/node/4588. Please contact
the Permit Center at permitcenter(r cityoffederalway.com or 253-835-2607 for updated fee schedules
for applications and permits, or for help with the submittal process.
7. Effect of Use Process Decision — In accordance with FWRC 19.15.100(2), "Lapse of Approval -
Generally," the applicant must substantially complete construction for the development activity, use
of land, or other actions approved; and complete the applicable conditions listed in the Use Process
decision within five years after the final decision of the city on the matter, or the decision becomes
void. Provisions for extension of time are contained within FWRC 19.15.110, "Lapse of Approval —
Time Extension."
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8. Key Development Regulations — The use zone chart of FWRC 19.220.040 (enclosed) provides
regulations for the proposed use. The applicant should consult the referenced use zone chart before
submitting a Master Land Use Application to verify all site components and proposed uses will
comply with city code. The following is only a portion of the zoning regulations governing the
proposed use in the BC zone:
School Use (FWRC 19.220.040)
Required Yards, Lot Coverage, Building and Structure Height, Parking:
i. Minimum Front/Side/Rear Setbacks — 20'/0'/0'
ii. Maximum Lot Coverage — None; the buildable area will be determined by other site
development requirements, i.e., required buffers, parking lot landscaping, surface water
facilities, etc.
iii. Maximum Building and Structure Height —Height is 35-55 feet above average building
elevation (AABE); also see special regulations and notes #1-3 from the use zone chart
(FWRC 19.220.040):
1. Building height may not exceed 30 feet AABE when located within 100 feet of a residential
zone. (The proposal is over 100 feet away from residential zones.)
2. Except for gyms, if approved by the Director of Community Development, the height of a
structure may exceed 35 feet above average building elevation (AABE) to a maximum of
55 feet AABE, if all of the following criteria are met:
a. The additional height is necessary to accommodate the structural, equipment, or
operational needs of the use conducted in the building, and/or all ground floor
spaces have a minimum floor -to -ceiling height of 13 feet and a minimum depth of
15 feet;
b. Height complies with note 1;
c. Height over 35 feet is set back from nonresidential zones by one foot for each
one foot of height over 35 feet; and
d. Rooflines are designed to avoid a predominantly flat and featureless
appearance through variations in roof height, forms, angles, and materials.
3 For any structure, including gyms, an increase in height above 35 feet shall not block views
designated by the comprehensive plan.
The application must include a written narrative how each of the special notes in the zoning use
chart have been met and/or addressed.
iv. Parking — The application will must include a parking analysis to support and justify the quantity
of parking stalls provided and available for the stadium use. FWRC 19.220.040 requires one
parking space for each employee and 1 for every 10 students in the school use zone chart. The
school use and school parking demand is likely not a good indicator of parking demand for the
stadium use, but since the stadium use is allowed as an accessory use to the school, the parking
stall count will have to meet the requirement for the primary school use. Again, City staff will
need to document how the proposed parking is adequate for the stadium use.
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The city staff report for the fairly recent Federal Way High School rebuild and replacement project
noted, "1,600 students and 120 employees will require a minimum of 280 parking spaces. The
applicant has proposed 610 total parking spaces and therefore exceeds the minimum."
Height Variance — During the pre -application conference meeting, the applicant identified that the
proposal includes 100-foot-tall light poles for the field lighting. FWRC 19.45.015 has an option for an
administrative variance, which allows a variance up to 25 percent of the measurable standard (55-foot
height limit, would be eligible for a potential 13-foot administrative height variance). If this
administrative height variance is proposed, then the administrative variance would be reviewed and
considered in conjunction with the Process III land use review.
A height variance request which exceeds 25 percent of the measurable standard requires review and
approval by the Hearing Examiner under Process IV Hearing Examiner public hearing review and
decision.
Under either variance option summarized above, the applicant must address how any requested
variance meets the decisional criteria of FWRC 19.45.030.
FWRC 19..45.030 Criteria
The city may grant the variance only if it finds all of the following:
(1) That the variance will not constitute a grant of special privilege inconsistent with the limitations
upon uses of other properties in the vicinity and zone in which the subject property is located.
(2) That the variance is necessary because of special circumstances relating to the size, shape,
topography, location or surroundings of the subject property to provide it with use rights and
privileges permitted to other properties in the vicinity and zone in which the subject property is
located.
(3) That the granting of the variance will not be materially detrimental to the public welfare or
injurious to the property or improvements in the vicinity and zone in which the subject property is
located.
(4) That the special circumstances of the subject property are not the result of the actions of the
owner of the subject property.
The applicant carries the burden of proof for convincing the Director or Hearing Examiner that the
requested variance meets the decisional criteria.
All other options must be considered and evaluated prior to a variance request. Compliance with the
FWRC standards should be pursued. Any variance application must provide technical support and
justification for said variance.
There were no elevations and/or specific information submitted to the City in regard to the proposed
light pole height. Under any scenario, with any variance request, the application must include an
analysis of why the 55-foot maximum building height cannot be met for lights. This analysis shall
evaluate the effectiveness of lights that are 55 feet tall, and identify why they are not technically
feasible. Since no technical lighting information was submitted, City staff is unable to comment
further on any potential variances.
You are strongly encouraged to have a follow-up discussion and meeting with staff after the
preapplication meeting to further discuss any potential variances as the site design and facility design
progresses.
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10. Non -conforming Development - As proposed, the building floor area expansion / new stadium
bleachers and building construction triggers all nonconforming aspects of a development to be
brought into conformance with the zoning and development code regulations per FWRC
19.30.090(1)(a) since the proposed expansion exceeds the size thresholds. The nonconforming
aspects that require compliance and upgrade include;
■ Perimeter landscape buffers;
Interior parking lot landscaping;
• South parking lot surfacing material.
Each of these development improvement requirements are discussed individually further below.
IL South Parking Lot Upgrade — The surfacing and design of the south parking lot is required to be
upgraded to a paved condition, per FWRC 19.130.210 and 19.30.090(1)(a). The parking lot area must
include a minimum of 22 square feet of interior parking lot landscaping for each parking stall per
FWRC 19.125.070.
12. Landscaping/Tree Retention —Show any trees to be removed on the site plan, any proposed
landscaping, and document the project/site compliance with the tree retention and replacement
standards in FWRC 19.120.130(2).
13. Landscaping — The land use application must include a preliminary landscape plan, prepared by a
licensed landscape architect, in accordance with the landscape requirements contained in FWRC
Chapter 19.125, "Outdoors, Yards, and Landscaping." Following are the key landscape requirements
for the project:
(a) Perimeter Landscape Buffers — Type III perimeter landscape buffer a minimum of five feet in
width is required along the south property line per FWRC 19.125.060(6)(a). It appears this area
south of the south parking lot likely needs some minor supplementing of landscape materials in
order to meet the Type III landscape standard.
Along the west perimeter property line, a minimum 15-foot-wide Type I solid screen landscape
buffer is required per FWRC 19.125.060(6)(b) abutting a residential zoning district. It also
appears the existing west side perimeter Type I landscape buffer will require supplementing to
meet the Type I solid screen requirement.
Type I and Type III landscaping types are described in FWRC 19.125.050.
(b) Interior Parking Lot Landscaping —Per FWRC 19.125.070, Type IV landscaping shall be
provided within surface parking areas as follows: required interior lot landscaping. Landscape
areas shall be provided at the following rate within paved areas: institutional developments shall
provide the following: 22 square feet of interior lot landscaping per parking stall when 50 or more
parking stalls are being provided. In addition, per FWRC 19.125.070(6), vehicular overhang into
any landscaping area shall not exceed two feet.
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(c) Rockeries, Retaining Walls, and Fencing — Rockeries, retaining walls, and any proposed fencing
must be shown on the site, landscape, and civil plans. Per FWRC 19.120.120, the height of
rockeries and retaining walls associated with development is limited to six feet. Retaining walls
and rockeries shall be set back a minimum of three feet from adjacent public rights -of -way, and
where retaining walls are terraced; there shall be a minimum five feet distance between terraces
to accommodate landscaping and its maintenance. Walls that are visible from the public right-of-
way or adjacent property shall be composed of brick, rock, or other textured/patterned styles as
approved by the planning and public works directors.
(d) Modification — Per FWRC 19.125.100, any proposed landscape modifications will be reviewed
and decided upon in conjunction with the Process III application. A request for a landscape
modification must include a written narrative of how the proposal meets the applicable
modification criteria.
14. Clearing & Grading — Show details for clearing and grading on the site plan or an additional plan
sheet. Preliminary clearing and grading plans are reviewed in conjunction with the land use review
process associated with the proposed development.
15. Critical Areas — None known on the area proposed for development.
16. Community Design Guidelines —A review of the proposal under the city's design guidelines, Chapter
19.115 FWRC, is required for the project and will occur in conjunction with the land use process
review. The principal applicable design guidelines for the project are noted below. However, this does
not necessarily include all applicable guidelines, and project designers must consult the guidelines in
their entirety in preparing an application. The application must include a written narrative identifying
how the proposal complies with the applicable design guidelines, as detailed.
a. FWRC 19.115.010(2), CPTED — Implement Crime Prevention through Environmental Design
(CPTED) principles to reduce opportunities for criminal activities. The city's Police Department
and Planning Division will evaluate the formal application and review for compliance with
CPTED principles. A completed CPTED checklist must be submitted with your application.
i. Natural Surveillance — Promote visibility of public spaces and areas.
ii. Access Control — Identify techniques that deter unauthorized access and/or inappropriate
access.
iii. Ownership — Reduce the perception of areas as ownerless.
b. FWRC 19.115.050, Site Design — Key sections include: subsections 1, 2, 4, 6 and 7.
c. FWRC 19.115.060 (2) Fagade modulation and screening options. There are facades that are both
longer than 60 feet and visible from a right-of-way or residential use and/or zone, and must
incorporate a minimum of two out of four design options intended to break up the mass of large
buildings. These design options include faoade modulation, landscape screening, canopy or arcade,
and pedestrian plaza. Options used must meet the dimensional standards as specified, but if more
than two are used, dimensional requirements for each option may be modified. The stadium is a
unique building, but that does not exclude the design from meeting the intent of the guidelines. We
can further discuss ideas on how to find the stadium design is compliant with the guidelines.
d. FWRC 19.115.060 (3) Building articulation and scale (a)-(b); (a) applies to facades visible from
rights -of -way and other public areas.
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e. FWRC 19.115.090(1), District guidelines — See (1)(f):
i. If utilized, chain -link fences visible from public rights -of -way or adjacent properties,
and not screened by Type I landscaping as defined by Chapter 19.125 FWRC, shall utilize
vinyl -coated mesh, powder -coated poles, dark color(s), and architectural element(s) such as
pole caps and/or decorative grid pattern.
f. FWRC 19.115.100, Institutional Uses — See (4):
i. Roof design shall utilize forms and materials that avoid the general appearance of a
"flat" roof. Rooflines with an integral and obvious architectural pitch are an approved method
to meet this guideline. Alternative distinctive roof forms, such as varied and multiple stepped
rooflines, architectural parapets, articulated cornices and fascias, arches, eyebrows, and
similar methods will be considered by the director; provided, that the roof design minimizes
uninterrupted horizontal planes and results in architectural and visual appeal.
17. Lighting — FWRC 19.105.030 contains lighting regulations. The applicant shall select, place, and
direct light sources both directable and nondirectable so that glare produced by any light source, to
the maximum extent possible, does not extend to adjacent properties or the right-of-way. Note any
site lighting on the site plan.
18. Mechanical Equipment — FWRC 19.110.070 requires vents, mechanical and elevator equipment, and
similar appurtenances that extend above the roofline to be architecturally screened from public view,
with a corresponding elevation detail provided with the formal application.
19. Garbage and Recycling Receptacles — FWRC 19.125.150 requires that storage areas for garbage and
recycling receptacles be provided for each project. The city staff report for the recent high school
replacement project noted, "garbage and recycling space is provided within the screened service area
along the north building elevation. Space requirements of 2 sf per 1,000 sf of gross floor area are
exceeded." This was for a 235,885 square foot building. Subsequently, the solid waste receptacles
code was revised in 2017. For more than 200,001 square feet of non-residential development, based
on the gross floor area of all structures on the lot, the required minimum area for shared storage space
is 500 square feet. As a result, there should be adequate receptacles existing onsite. During the
meeting, it was discussed that the current proposal will use the existing garbage/recycling facility on
site.
20. Application Fees & Submittal — Please contact the Permit Center at
permitcenter(g),cityoffederalway.com, or 253-835-2607, for updated fee schedule information for the
applications and permits.
Please note, the original application fee collected at submittal of the land use application covers the
initial review and one resubmittal only. The City will be charging applicants for any additional staff
time necessary to complete each review following the first resubmittal.
The building permit process is separate from land use review and is subject to fees, procedures, and
review timeframes. Process III land use approval is recommended prior to submitting the building
permit application to avoid delay in project review. If this is not feasible, please provide details on
timing needs. No clearing, grading, or demolition may occur on site in advance of the land use
approval; building or grading permit; demolition permits; or other approval process as required by the
City.
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PUBLIC WORKS DEVELOPMENT SERVICES DIVISION (Sam Basmeh, 253-835-2746,
s amir.basmeh@cityoffederalway.com)
Land Use Issues — Stormwater
Surface water runoff control and water quality treatment will be required per the 2021 King County
Surface Water Design Manual (KCSWDM) and the City of Federal Way Addendum to the manual.
This project meets the requirements for a Full Drainage Review. At the time of land use site plan
submittal, a preliminary Technical Information Report (TIR), addressing the relevance of the project
to the nine core and five special requirements of the KCSWDM will be required. A Level 1
downstream analysis shall also be provided in the preliminary TIR. The City Addendum can be
found at the following website: www.cityoffederalway.com/tiode/1467,
2. The project lies within a Flood Problem flow control area; thus, the applicant must design the flow
control facility to meet this performance criteria. In addition to flow control facilities, Best
Management Practices (BMP's) are required as outlined in the KCSWDM. The project also lies
within an Enhanced Basic Water Quality Area. Water Quality Treatment shall be designed to meet
the treatment criteria of the Enhanced Basic Water Quality Menu. The City will accept treatment
systems which are listed on the Department of Ecology's General Use Level Designation (GULD)
for the required level of water quality treatment.
In addition to the 2021 KCSWDM, our initial review suggests that FWRC Section 19.30.120,
"Nonconforming Water Quality Improvements" applies to this site. Specifically, the following items
are applicable:
a) Redevelopment which involves the creation or addition of impervious surfaces having an area of
2,000 square feet or more;
b) Redevelopment which involves the construction or replacement of a building footprint or other
structure having a surface area of 2,000 square feet or more, or which involves the expansion of
a building footprint or other structure by 2,000 square feet of surface area or more;
c) Redevelopment which involves the repair or replacement of 2,000 square feet or more of an
impervious surface, when such redevelopment is not part of a routine maintenance activity;
d) Redevelopment which involves the collection and/or concentration of surface and/or stormwater
runoff from a drainage area of 2,000 square feet or more;
e) Redevelopment which contains or directly discharges to a floodplain, stream, lake, wetland, or
closed depression, groundwater recharge area, or other water quality sensitive area determined
by the Public Works Director, based on a written map, policy, water quality monitoring data or
plan in existence or implemented by the Director prior to submission of a redevelopment
application which is determined to trigger application of this subsection, or based on information
developed during review of a particular redevelopment application;
f) Redevelopment, other than normal maintenance or other than the tenant improvements, but
including any increase in gross floor area, in any one consecutive 12-month period which
exceeds 50 percent of the assessed or appraised value (whichever is greater) of the structure or
improvement being redeveloped. The applicant may provide an appraisal of the improvement.
The appraisal must be from a source acceptable to the City. The Director may require the
applicant to provide an appraisal from a second source acceptable to the City if the assessed
valuation appears to be inaccurate or inappropriate. If more than one appraisal is provided by the
applicant or required by the City, the greater of the two amounts shall be used. For purposes of
this determining value under this section, improvements required pursuant to FWRC Sections
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19.30.090 (nonconforming development), 19.30.110 (street/sidewalk improvements), 19.30.120
(nonconforming water quality improvements) and 19.135.030 (street/sidewalk improvements)
shall not be counted towards the 50 percent threshold which would trigger application of this
subsection.
Therefore, water quality treatment will be required for the entire site, including new and existing
pollution generating impervious surfaces. Treatment options must be selected from the Enhanced
Basic Water Quality Menu provided in the KCSWDM.
4. Show the proposed location and dimensions of the detention and water quality facilities on the civil
plans.
5. Since more than one acre will be disturbed during construction, a National Pollutant Discharge
Elimination System (NPDES) construction storm water permit will be required. Information regarding
this permit can be obtained from the Washington State Department of Ecology at
httr).://www.cev.m,a.ov/,orograirLs/wq/storinwater/construction/index.html or by calling 360-407-6048.
6. If work is to be done below the ordinary high-water mark, a Hydraulic Project Approval (HPA) permit
may be required. Information regarding this permit can be obtained from the Washington Department of
Fish and Wildlife.
EN Permit Issues
7. Engineered plans are required for clearing, grading, road construction, and utility work. Plans must be
reviewed and approved by the City. Engineering review fees currently are $3,325.00 for the first 18 hours
of review for Commercial building permits and full subdivision EN permits. Short plats are charged
$2,216.00 for the first 12 hours of review. Additional review time is charged at $184.00 per hour. A final
TIR shall be prepared for the project and submitted with the engineering plans. Both the TIR and the
plans will require the signature/seal of a professional engineer registered/licensed in the State of
Washington.
8. The Federal Way Public Works Development Standards Manual (including standard detail drawings,
standard notes, and engineering checklists) is available on the City's website at:
www.gityoffederalway=m/node/1467 to assist the applicant's engineer in preparing the plans and TIR.
9. Bonding is required for all street improvements and temporary erosion and sediment control measures
associated with the project. The bond amount shall be 120 percent of the estimated costs of the
improvements. An administrative fee deposit will need to accompany the bond to cover any possible legal
fees in the event the bond must be called. Upon completion of the installation of the improvements, and
final approval of the Public Works Inspector, the bond will be reduced to 30 percent of the original
amount and held for a two-year maintenance period.
10. The developer will be responsible for the maintenance of all storm drainage facilities (including the
detention and water quality facilities) and street systems during the two-year maintenance period. During
that time, the Public Works Inspector will make periodic visits to the site to ensure the developer's
compliance with the maintenance requirements. Upon satisfactory completion of the two-year
maintenance period, the remainder of the bond will be released.
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11. When topographic survey information is shown on the plans, the vertical datum block shall include
the phrase "DATUM: N.G.V.D.-29" or "DATUM: K.C.A.S.," on all sheets where vertical elevations
are called out.
12. Temporary Erosion and Sediment -control (TESC) measures, per Appendix D of the 2021 KCSWDM,
just be shown on the engineering plans.
13. As of Jan 1 2022, A Surface and Stormwater Utility System Development Charge is required.
System development charges (SDCs) are one-time fees that will be paid at the time of development
and are intended to recover a share of the cost of system capacity needed to serve growth. The SDC
is based on the amount of new impervious surfaces added for any development project so depending
on the final impervious length of the new access road, we can calculate the initial SDC. They are
expressed as one ESU per 3200 square feet of new impervious which amounts to $1,035.00 per ESU.
Questions from applicant prior of pre -application conference regarding Storm Water:
7,a) The City of Federal Way Addendum to the King County Surface Water Design Manual (KCSWDM)
references the 2016 version of the manual, but a 2021 version exists. Which manual governs the project?
The City of Federal Way follows the 2021 KCSWDM and the City of Federal Way Addendum to
the manual.
7,b) Based on our research, we understand that the site is located in a Flood Problem Flow Control Area
(Level 3 flow control) and that Enhanced Basic water quality treatment is required.
Can you please confirm the flow control and water quality requirements for the project?
Yes, this project lies within a Flood Problem flow control area; thus, the applicant must
design the flow control facility to meet this performance criteria. The project also lies within an Enhanced
Basic Water Quality Area. Water Quality Treatment shall be designed to meet the treatment criteria of the
Enhanced Basic Water Quality Menu. The City will accept treatment systems which are listed on the
Department of Ecology's General Use Level Designation (GULD) for the required level of water quality
treatment.
7,c) The KCSWDM has limited options for BMPs that can be used to achieve Enhanced Basic Water
Quality. What BMPs does the City of Federal Way allow, including proprietary BMPs?
Any approved method that is in the 2021 KCSWDM and you can use the DOE manual as well.
7,d) Bioretention cells were used for the Federal Way HS project. Is bioretention still an acceptable BMP
for meeting the treatment requirements?
Yes, or you can use different methods that are in the 2021 KCSWDM.
7,e) A bioretention cell is located south of the existing gravel parking lot, providing treatment for that
surface.
7,f) Is it acceptable to continue using the bioretention facility for treatment of the parking lot, even if the
parking lot is surfaced with asphalt?
Please make sure the existing bioretention complies with the new 2021 KCSWDM it may be
required to upgrade to comply with the 2021 KCSWDM.
7,g) The current plan for the athletic field is to perform a replacement of the surface wear layer which
includes the synthetic grass turf and synthetic running surface. The existing subgrade features will remain
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in place; including the elastic layer (3.5" porous asphalt), aggregate base, and drainage system. The
design team understands that this work meets the definition of "maintenance" in the KCSWDM.
Does the City have the same understanding?
As presented to the city, no work will be done to the existing underdrain system. Then, proposed
work will be classified as "maintenance".
7,h) The Technical Information Report for the Federal Way HS project (prepared by Springline Design,
LLC) indicates that the existing detention pond has additional capacity for approximately 0.94 acres of
impervious surface. Is it acceptable for this project to use this additional capacity?
Must provide a new Technical Information Report, (TIR) and run the model KCRTS to make sure
the existing pond will meet the new standards from 2021 KCSWDM. Model should be for the entire
property and no just proposal work area. Also, the school used approximately 0.17 Acres for the
Apprenticeship Yard Project.
7,i) Does the City have record of any past projects that may have already used some of this capacity?
Yes, the Apprenticeship Yard Project, Permit No. 21-10293 1 -00-EN, will use approximately 0.17
Acres.
7,j) This project is considering expanding the existing detention pond as a way to meet flow control
requirements. For example, removal of the berm between the two cells and/or excavating at the north end
to create additional storage. Is this approach generally acceptable to the City? Note that the existing pond
was designed under the 2009 KCSWDM, but the flow control criteria from this manual appears to be the
same as the current manual.
Please run the model to verify it does follow the 2021 KCSWDM. Any changes must be shown
on plans and TIR when the flow control may be adjusted to meet requirements. Must show live storage
and the dead storage of proposal new detention pond work.
PUBLIC WORKS TRAFFIC DIVISION
Sarady Long, 253-835-2743, Sarady.long@cityoffederalway.com
Transportation Concurrency Analysis (FWRC 19.90)
1. Staff is unable to determine trip generation for the proposed development using the Institute of
Transportation Engineers ITE's Trip Generation. Therefore, the applicant must submit a trip
generation study to determine the number of trips generated by the proposed development. At a
minimum, the trip generation study shall include three (3) studies for similar land use and settings.
The methodology for determining the trip generation shall be based upon the guidelines established in
the most recent edition of the ITE Trip Generation Handbook.
Based on the submitted materials to upgrade and increase capacity of the existing stadium by 760
seats, using the trip generation study prepared by TENW of 0.20 PM trip per seat, the proposed
project is estimated to generate approximately 152 new weekday PM peak hour trips.
2. A concurrency permit is required for this development project. The PW Traffic Division will perform
concurrency analysis to determine if adequate roadway capacity exists during the weekday PM peak
period to accommodate the proposed development. Please note that supplemental transportation
analysis and concurrency mitigation may be required if the proposed project creates an impact not
anticipated in the six -year Transportation Improvement Plan (TIP).
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The estimated fee for the concurrency permit application is $9,972 (51 - 500 PM Trips). This fee is an
estimate and the actual application fee will be determined after the trip generation study is submitted
and approved by staff. The concurrency application fee must be paid in full at the time the
concurrency permit application is submitted with land use application. The fee may change based on
any changes in the estimated weekday PM peak hour trips as identified in the concurrency
application. The applicant has the option of having an independent traffic engineer prepare the
concurrency analysis consistent with City procedures; however, the fee remains the same.
Transportation Impact Fees (TIF) (FWRC 19.91)
1. The impact fee will be calculated using the data from trip generation study. The impact fee will be
assessed at the time a completed building permit application is filed and must be paid prior to permit
issuance.
Street Frontage Improvements (FWRC 19.135)
1. Based on the available records and the submitted materials, it appears that this proposal will not meets
the 25 percent threshold criteria for requiring street frontage improvements as identified in the FWRC
19.135.030. However, it appears the school parking stalls on 16t" Avenue South are located within
the public rights -of -way. This issue would need to be addressed as part of this project or other
agreement to be approved by the City.
Design Criteria (FWRC 18.55) and Access Management (FWRC 19.135)
1. Per FWRC 19.135.280, driveways must be located no closer than 150' to any street intersection or
any other driveway, whether on or off the subject property. The city may further limit or prohibit
access to or from driveway onto public streets as deems appropriate for safety. The project does not
appear to meet this requirement. The applicant must provide supporting documentation that a share
access is not supportive by the adjacent property owner.
2. Driveway that serve uses other than single-family residential uses and zero lot line townhouse
developments, the maximum driveway width is 30 feet for a two-lane two-way driveway and 40 feet
for a three -lane two-way driveway (FWRC 19.135.270). Driveway widths may be increased in order
to provide adequate width for vehicles that may be reasonably expected to use the driveway, as
determined by the Public Works Director.
3. Minimum throat length for non -single-family driveways shall be 40 feet minimum, 50 feet desirable.
Throat length is measured from the face of curb (or edge of traveled way if no curb exists) on the
public street to the first conflicting drive aisle or parking movements that would conflict with entering
and exiting traffic.
PUBLIC WORKS — SOLID WASTE AND RECYCLING DIVISION
Rob Van Orsow, 253-835-2770, robv@cityoffederalway.com
Solid Waste & Recycling Design Considerations
Adequate space allocation for interior and exterior garbage, recycling, food waste, waste oil, yard
debris, hazardous waste, and/or biohazard collection containers. Minimum enclosure area is
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established by FWRC 19.125.150 (7)(a). FWRC requires that plans allow access to containers for
both occupants and haulers.
• Basic solid waste and recycling services typically include two `dumpster' containers situated
side -by -side within a single trash enclosure. With gate doors open, 18 feet of clearance width is
required; no structures (such as gate posts) are allowed across the enclosure opening. Gate
pins/holes are preferred to hold gates closed or open (to allow service access and preserve gate
hardware).
• Plan unobstructed access for service vehicles, in -line with enclosure openings. Allow appropriate
paved turning area for service vehicles, minimizing `blind spots' during ingress and egress.
■ Per FWRC 19.125.150 (7)(e), sites may require a larger enclosure, or multiple enclosures, to
accommodate on -site user access and/or additional waste types and containers
• Per FWRC 19.125.150 (6)(d), depending on enclosure size, surface water run-off must be
managed via an oil -water separator, while large enclosures require a roof combined with a drain
to sanitary sewer. A related Spill Prevention Plan is also required.
• Landscaping and screening requirements are established in FWRC 19.125.040 (4) and (5).
COMMUNITY DEVELOPMENT — BUILDING DIVISION
Greg Kirk, 253-835-2621, greg.kirk@cityoffederalway.com
Building Codes. The structure will be treated as a new building permit application and must meet all
current codes including:
• International Building Code (IBC), 2018
Washington State Amendments WAC 51-50
* International Mechanical Code (IMC), 2018
Washington State Amendments WAC 51-52
• Uniform Plumbing Code (UPC), 2018
Washington State Amendments WAC 51-56 & WAC 51-57
• International Fire Code (IFC), 2018
Washington State Amendments WAC 51 -54
• National Electric Code (NEC), 2020
• Accessibility Code (ICC/ANSI Al 17.1), 2009
• International Residential Code, 2018
Washington State Amendments WAC 51-51
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■ Washington State Energy Code, 2018 WAC 51-11
2. Building Criteria. The following applies to the proposed structure:
• Occupancy Classification: A-5, M, A-3
■ Type of Construction: IIB and VB
• Floor Area: Not known at this time
■ Number of Stories: one
• Fire Protection: Non-combustible construction
• Wind/Seismic: Basic wind speed 85 Mph, Exposure, 25# Snow load, Seismic Zone D-1
3. Building Permit Application Process. A completed building permit application and commercial
checklist are required. The commercial checklist will be filled out by staff and provided at the time of
Land Use Approval. Copies of application and checklist may be obtained on our web site at
www.cityoffederalway.com.
Submittal of the building permit is by electronic submittal only. Please use this link
htlps://www.cilyoffederatwU.com/node/4588 to request a link to upload your submittal documents. If
you have questions about this process, please contact the permit center at 253-835-2607 or
ElectronicSubmittal a7cit offederalwa .com. Please note, the application fee collected at initial
submittal of the permit application covers the initial review and one resubmittal only. The City will be
charging applicants for any additional staff time necessary to complete each review following the first
resubmittal.
Some projects may require a third -party review or inspection. The cost to cover these fees is the
responsibility of the applicant. Any third -party fee is in addition to regular permit fees and costs.
Please note, Land Use Approval is recommended prior to submitting the building permit application
to avoid delay in project review. If the project has not received Land Use Approval, it may be placed
on hold until Land Use review is completed.
4. Review Timing. Federal Way reviews plans on a first in, first out basis; however, there are some
small projects with inconsequential review requirements that may be reviewed out of order.
The first comment letter can be expected within 5-7 weeks of submittal date. Re -check of plans will
occur in one to three weeks after re -submittal.
Revised or resubmitted plans shall be provided in the same format, size, and amount as the originally
submitted plans. Revised/resubmitted drawings shall indicate, by means of clouding or written
response, what changes have been made from the original drawings. Plans for all involved
departments will be forwarded from the Community Development Department to all review staff.
Please use this link https://www.cityoffederalway.com/node/4588 to request a link to upload your
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resubmittal documents. If you have questions about this process, please contact the permit center at
253-835-2607 or ElectronicSubmittal(a)cit offederalwa .com.
5. Other Permits & Inspections. Separate permits may be required for electrical, mechanical,
plumbing, fire suppression systems, and signs. Applicants may apply for separate permits at any time
prior to commencement of construction.
When required, special inspections shall be performed by WABO approved agencies or by agencies
approved by the building official prior to permit issuance. Construction must be approved by all
reviewing departments prior to final building division inspection.
All concerned departments (Planning, Public Works, Electrical, & Fire) must sign off before the
Building Department can final the structure for occupancy. Building final must be approved prior to
the issuance of a Certificate of Occupancy.
Construction projects may be required to have a pre -construction conference. If a pre -con meeting is
required, the general or representative, all subs, the architect or representative, the engineer or
representative, electrical contractor, and any other interested party, should attend this meeting.
Meetings will occur at the Building Department and will be scheduled by the inspector of record for
the project.
6. Site -Specific Requirements.
• Due to wind loads this project will be sent out for third party structural review
• Project must meet all accessibility requirements in IBC Chapter 11 and ICC/ANSI Al 17.1
■ This project must meet all exiting requirements in 113C Chapter 10
■ No storage is allowed under the bleachers without providing fire sprinklers
The information provided is based on limited plans and information. The comments provided are
not intended to be a complete plan review and further comments are possible at time of building
permit plan review.
LAKEHAVEN WATER AND SEWER DISTRICT
Brian Asbury, 253-946-5407, BAsbury@Iakehaven.org
Lakehaven's comments below, regarding the proposed renovations and upgrades to Memorial Stadium on
the western portion of parcel 0821049001. Let me know if there's any questions or if additional
information is needed.
GFNF.R A T .
All Lakehaven Development Engineering related application forms, and associated standards
information, can be accessed at Lakehaven's Development Engineering web pages
(http://www.lakehaven.orZ/204/Development-Engincering).
All comments herein are valid for one (1) year and are based on the proposal(s) submitted and
Lakehaven's current regulations and policies. Any change to either the development proposal(s) or
Lakehaven's regulations and policies may affect the above comments accordingly.
W ATF.R
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• Lakehaven issued a Water Certificate of Availability for the proposed project/property on 4/l /22;
Certificate is valid for one-year from date of issuance.
• A Lakehaven Developer Extension (DE) Agreement will be required to construct new water distribution
system facilities for the proposed development. Additional detail and/or design requirements can be
obtained from Lakehaven by completing & submitting a separate application to Lakehaven for either a
Developer Pre -Design Meeting or a DE Agreement. Lakehaven encourages
owners/developers/applicants to apply for Lakehaven processes separately to Lakehaven, and sufficiently
early in the pre-design/planning phase to avoid delays in overall project development.
• A water service connection application submitted separately to Lakehaven is required for each new
service connection to the water distribution system, or any modification to an existing water service
connection (e.g., larger meter/service, irrigation, abandonment of existing service(s), re -activation, etc.),
in accordance with standards defined in Lakehaven's current `Fees and Charges Resolution'. Non -
single -family properties require separate domestic (per building, typically, some exceptions allowed),
irrigation (if irrigated landscaped areas are incorporated into the site development &/or property has a
sewer service connection), and fire protection (if required or installed) water service connections &
meters.
• The associated DE Agreement must achieve a point of either Substantial Completion or Acceptance, as
determined by Lakehaven, prior to activating any new domestic or irrigation water service connection(s).
9F.WF.R
Lakehaven issued a Sewer Certificate of Availability for the proposed project/property on 4/1/22;
Certificate is valid for one-year from date of issuance.
A separate Lakehaven Sewer Service Connection Permit is required for each new connection to the
sanitary sewer system or any modification (disconnect, re -align, abandon, etc.) to an existing sewer
service connection, in accordance with standards defined in Lakehaven's current `Fees and Charges
Resolution'. Minimum pipe slope for gravity sewer service connections is 2%. In addition to all other
sewer service installation standards, installation of a Type 1, 48" monitoring manhole is typically
required on the private building sewer line, for all new or modified non-residential connections. Also,
installation of an externally -located grease interceptor is required for all new restaurants &/or buildings
with food preparation/service establishments, size to be determined by applicant's engineer & approved
by Lakehaven. Also, if applicable, see attached Lakehaven Trash/Recycling Enclosure Standards.
SOUTH KING FIRE AND RESCUE
Sean Nichols, 253-946-7242, Sean.Nichols@southkingfire.org
Water Supply:
Fire Flow:
A Certificate of Water Availability shall be requested from the water district and provided at the time
of building permit application.
Fire Hydrants:
Fire hydrants shall be in service prior to and during the time of construction.
Emergency Access:
Fire apparatus access roads shall comply with all requirements of Fire Access Policy 10.006
http://southkingfire.oMMocumentCenter/HomeNiew/24
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Fire apparatus access roads shall be installed and made serviceable prior to and during the time of
construction.
General Comment:
The area under the bleachers are not allowed any storage unless the space is reduced to under 1000
sf. If area under bleachers is used, and exceeds 1000 sf, fire sprinklers ARE required underneath.
CLOSING
This letter reflects the information provided at the preapplication meeting and is intended to assist you in
preparing plans and materials for formal application. We hope you found the comments useful to your
project. We have made every effort to identify major issues to eliminate surprises during the City's
review of the formal application. The completion of the preapplication process in the content of this letter
does not vest any future project application. Comments in this letter are only valid for one year as per
FWRC 19.40.070(4).
As you know, this is a preliminary review only and does not take the place of the full review that will
follow submission of a formal application. Comments provided in this letter are based on preapplication
materials submitted.
Modifications and revisions to the project as presented for this preapplication may influence and modify
information regarding development requirements outlined above. In addition to this preapplication letter,
please examine the complete FWRC and other relevant codes carefully. Requirements that are found in
the codes that are not addressed in this letter are still required for your project.
If you have questions about an individual comment, please contact the appropriate department
representative noted above. Any general questions can be directed towards me, the key project contact,
Jim Harris, at 253-835-2652, orjim.harris@cityoffederalway.com We look forward to working with you.
Sincerely,
Jim Harris
Senior Planner
enc: Process III Submittal Checklist
Lakehaven Facility Handout
Lakehaven Trash Enclosure Information
c: Tim Ausink, Federal Way Public Schools, tausink@fwps.org
Sam Basmeh, Federal Way Public Works Development Services Division
Sarady Long, Federal Way Public Works Traffic Division
Sean Nichols, South King Fire and Rescue
Brian Asbury, Lakehaven Sewer and Water
22-101129-00-PC
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