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23-105386-SU-Project Narrative-12-05-23 PROJECT NARRATIVE and CODE CONSISTENCY ANALYSIS for PRELIMINARY PLAT of CREEKWOOD Prepared by: Barghausen Consulting Engineers, Inc. December 4, 2023 PARCEL DATA Parcel No.: 122103-9037 Gross Site Area: ±19.86 acres STR: 12-21N-3E Existing Zoning: RS-15.0 Existing Comprehensive Plan: Single Family Medium Density Fire District: South King County Fire and Rescue School District: Federal Way District No. 210 Water District: Lakehaven Utility District Sewer District: Lakehaven Utility District Thomas Guide Page: 744 Kroll Map Page: 712 SITE DESCRIPTION The site is bordered on the north and south by single-family subdivisions, to the east by a commercial self- storage property, and to the west by vacant residential property. Primary access to the subject property is from the north via the end of 22nd Avenue SW through the adjacent plat of Lakota Ridge. The property also has a second point of access near the northeast corner where 21st Avenue SW transitions to 21st Way SW. The site is undeveloped and vacant with variable downward slopes to the south ranging from gentle to steep. The site contains two localized areas of steep slopes, three wetlands, and four streams. An existing east-west sanitary sewer main and associated easement cross the southern portion of the site. A 24-inch diameter public stormwater bypass line crosses through the middle of the site from the end of 22nd Avenue SW down to Lakota Creek. The stormwater pipe was installed by the city within a public drainage easement granted by a prior owner of the subject property in order to mitigate flooding and erosion from the adjacent storm drainage system in the Lakota Ridge plat which was the proximate cause of the steep incised ravine on the site. PROJECT DESCRIPTION / HISTORY OF PRIOR APPLICATIONS The proposed plat of Creekwood will subdivide a 19.86-acre property into 19 single family residential lots as a cluster subdivision under the provisions of FWRC 18.55.040. Access to the proposed lots will be from a new public road (Road A) to be constructed onsite. The plat will create separate tracts for landscaping, critical areas, and drainage facilities/open space. The project density is 0.96 du/ac, which is roughly half of the allowed density in the RS-15.0 zoning designation, due to the physical constraints described above. The subject property was initially evaluated for development feasibility purposes in 2014 by Core Design and GeoResources, with a site plan showing 26 residential lots. A pre-application meeting was subsequently held on July 27, 2017 for a subdivision of 20 lots using “lot-size averaging” (LSA) methodology. A preliminary plat application was subsequently submitted on August 16, 2017 and processed under File No’s 17-103948-SE and 17-103947-SU. 2 of 10 22154.005-Project Narrative-2023-12-04.docx A Notice of Complete Application was sent to the applicant on January 17, 2018, along with a list of technical review comments and request for additional information. There were a number of concerns outlined in this letter which included the following: • In order to meet LSA requirements, a number of the Lots were designed to include portions of steep slopes and other critical areas and buffers within the Lot. This concept was not supported by the city due to the obvious conflict between private land ownership and the need to protect and preserve critical areas and buffers. • Trails were proposed within the critical areas and buffers with resulting impacts due to clearing and grading activities associated primarily with a new trail connection from 22nd Avenue SW down the hillside to connect to a future east-west trail that would coincide with the existing vehicular access road maintained by Lakehaven Utility District (LUD) along the alignment of their trunk sewer line adjacent to Lakota Creek. • The site is located within the ASARCO Smelter Plume overlay. Concerns were expressed about the potential for Lead and Arsenic contamination being present on the site above MTCA levels. • Stormwater detention was proposed via an open pond in relatively close proximity to the top of the steep slopes. A variety of concerns were expressed by Public Works as well as by GeoDesign Inc., the city’s 3rd party review consultant. These included concerns for slope stability due to leakage from the storm pond along with potential failure of the pond liner. • The city expressed concerns over the design of the proposed public road crossing over the ravine above the emergent point of Drainage “Y.” These included the useful life of the proposed retaining wall being at least 50 years, and requirements for maintenance. The initial applications were partially reviewed by the city, but Application No. 17-103947-SU subsequently expired on June 14, 2019, when a gap of over six months occurred during the review process between resubmittals. A new preliminary plat application was filed on July 8, 2019, to replace the expired one. The 2019 application was substantially in conformance with the 2018 application but included responses to city comments outlined in the city’s previous Notice of Complete Application letter. The new application was given File No. 19-103218-SU. The city sent comments to the applicant on December 19, 2019, and the applicant responded with resubmittals on January 27, 2020, and October 27, 2020. The final response from the city on the above applications was sent to the applicant on May 25, 2021. While substantial progress had been made addressing many of the earlier concerns and issues raised by the city and their consultant team, there were still outstanding issues to be addressed so in November 2021, the applicant contacted Barghausen Consulting Engineers Inc. (BCE) to assist with responses to the letter of May 25, 2021. However, by the time the response was submitted to the city on April 22, 2022, the application had again expired, prompting the applicant to once again file for a new pre-application review with city staff on May 20, 2022. The pre-application meeting was held on June 16, 2022, and the project was given new File No. 22-102372-00-PC with a formal response from the city dated July 11, 2022. In 2023, BCE filed new applications for Preliminary Plat & SEPA (File Nos. 22-105973-SU & 22-105974- SE), Administrative Determination for CIP Storm Vault (approved File No. 22-105977-AD), Administrative Determination for CIP Retaining wall (approved File No. 22-105978-AD), and Modification of Right-of-Way Cross Section (approved File No. 22-105-976-SM). City comments for Preliminary Plat & SEPA (File Nos. 22-105973-SU & 22-105974-SE) were received May 9, 2023. In September 2023, the city of Federal Way completed a code revision to FWRC 18.55 pertaining to open 3 of 10 22154.005-Project Narrative-2023-12-04.docx space allocation in subdivisions. Under the old code section, the overall size of the Creekwood plat coupled with the extent of onsite critical areas imposed an active open space requirement amounting to almost 30 percent of the developable area, thereby substantially reducing the allowable density on a parcel that is already highly constrained. The new code removes this burden but cannot be implemented under the current vested application. In order to revise the project to comply with the new open space standards, the 2023 application was withdrawn and this narrative updated to accompany new preliminary plat application. The overall layout of the public road and developable lot areas are very similar to what was proposed in the applications recently withdrawn (File Nos. 22-105973-SU & 22-105974-SE). The new application specifically incorporates and responds to all of the comments in May 9, 2023 technical review letter received from the city after their review of the withdrawn applications, including comments received from the city’s third-party consultants. The previously approved CIP vault for the proposed storm drainage system as well as the previously approved road variance are both reflected in the new application. The primary changes made to the proposal in response to the May 9, 2023 comments include: • A significant reduction (roughly 20 percent) in the extent of clearing and grading of lots during the plat development phase, limiting the scope to that which is reasonably necessary to minimize import/export of soil during construction along with a corresponding reduction in the number of offsite truck trips on city roads. • Elimination of the CIP retaining wall that was previously shown to accommodate the Road A crossing over the ravine. The new design for the ravine crossing utilizes a geogrid reinforced structural fill concept discussed with the city in the spring of 2023. • All retaining walls previously shown on lots have been eliminated. • The third-party review comments from ESA and NV5 have all been addressed and incorporated into the design. • The amount of usable open space has been reduced to comply with the new standards set forth in FWRC 18.55 and consolidated in a single location. • The overall development area encompassing roads and lots has been reduced to the minimum necessary. The rest of the site and all prior open space and critical area tracts have now been combined into a single open space tract, maximizing protection of the steep slopes and critical areas. • The design of the sewer and storm drainage connections to existing facilities have been modified to substantially minimize work with critical area buffers. • The overall density was reduced by 5 percent (from 20 lots to 19 lots) as a result of all of the above changes. CLEARING AND GRADING As designed, the proposed clearing and grading will be generally limited to the level to moderately sloping areas of the site to minimize the removal of existing trees as well as to minimize the disturbance or compaction of native soils, except as needed for building purposes (road, site development and abbreviated grading for building pads for the future lots). A modification request is enclosed to allow for limited “mass grading” to establish Road A and limited lot grading. The modification request includes written justification for modification of clearing grading and tree retention standards pursuant to FWRC 19.120.050. The written request specifically addresses each criterion in FWRC 19.120.050(1)(a-d) and (2)(a-c). 4 of 10 22154.005-Project Narrative-2023-12-04.docx ROADS/ACCESS/TRAFFIC CONCURRENCY The site abuts the road stub of 22nd Avenue SW and the angle transition of 21st Avenue SW to 21st Way SW. Currently 22nd Avenue SW is a long dead-end that terminates at the site's northern boundary. The Creekwood Plan proposes to construct a new connection between 22nd Avenue SW and 21st Avenue SW. Construction of the new road will have the benefit of (1) eliminating the long dead-end in the plat to the north and (2) providing a second access for the neighborhood of close to 100 homes to the north which currently has only a single access to 21st Avenue SW at 307th Street SW. The new road connection will enable emergency vehicles to access the site and adjacent neighborhood to the north from two separate locations. Due to physical constraints of the site and the extensive critical areas and their associated buffers, Road A must cross the same ravine discussed below in the section on Critical Areas. The limits of the ravine crossing will be as close to the north property line as possible to minimize the amount of stream buffer intrusion required, and to avoid directly impacting the emergent point for “Drainage Y”. The depth of the ravine at the crossing point is such that it is not possible to utilize a traditional 2H:1V structural fill without encroaching onto the “Drainage Y” emergent point. Therefore, the applicant is proposing to construct a reinforced fill slope in Tract C for Proposed Road “A” where it crosses the existing ravine just east of the intersection with 22nd Avenue SW. Please see the enclosed Geogrid-Reinforced Slope Assessment & Global Stability Analysis letter prepared by Earth Solutions NW LLC dated October 30, 2023. CRITICAL AREAS The site contains two localized areas of steep slopes, Category III and IV wetlands, and four streams/drainages, as assessed and described in the Wetland & Fish & Wildlife Habitat Assessment and Buffer Enhancement Plan prepared by Soundview Consultants, LLC. All critical areas and their associated buffers will be preserved in one consolidated critical area tract. It is in the public interest to provide an alternative public road/emergency vehicle access to 22nd Avenue SW which is a long dead-end cul-de-sac in the adjoining plat to the north. This can be accomplished by constructing a new public road (Road A) from the existing dead-end through the Creekwood plat out to 21st Avenue SW. In order to complete this road connection, Road A must be designed to cross over the upper reaches of a ravine that lies north of an emergent stream on the proposed plat known as “Drainage Y”. The ravine is the result of erosion in the upper reaches of the north tributary to Lakota Creek drainage system primarily caused by prior flooding from an old storm pond located in the adjacent subdivision. A 24-inch bypass storm pipe was constructed within and adjacent to the tributary in or around 2005 but the ravine remained. The proposed Road A crossing has been designed to preserve “Drainage Y” in its existing condition but will require limited grading and upland fill to create a reinforced slope resulting in stream buffer intrusion subject to mitigation and a Process III review. Detailed discussion about the critical areas, buffer averaging and temporary buffer impact mitigation is provided in the Wetland & Fish & Wildlife Habitat Assessment and Buffer Enhancement Plan prepared by Soundview Consultants, LLC included with the application materials. A Process III application has been prepared to support the proposal for Road A ravine crossing, which will include imported structural fill within the road prism, limited grading, and installation of a reinforced fill slope. RETAINING WALLS One rockery, which complies with FWRC 19.120.120 is proposed in Tract A. No other retaining walls are proposed. TREE RETENTION The project demonstrates compliance with tree retention/replacement requirements of 25 tree units per 5 of 10 22154.005-Project Narrative-2023-12-04.docx acre in the preliminary plat plan set, see Sheet T-1. As proposed, tree retention exceeds the minimum retention requirement and is estimated to be 163 trees per acre with all tree retention occurring in Tract C. SCHOOL WALKING CONDITIONS We have reviewed the walk and bus routes for Federal Way Schools per their transportation program. Please see the enclosed School Walking Conditions Exhibit. 1. Elementary School students would walk to Adelaide Elementary School. 2. Junior High School students would walk to SW 304th Street at 17th Avenue SW to be bussed to Lakota Junior High School. 3. High School students would walk to SW 304th Street at Adelaide Load Zone to be bussed to Decatur High School. STORMWATER The site is located in the Lower Puget Sound Basin which is subject to Conservation Flow Control and Enhanced Basic Water Quality. Project-generated stormwater will be collected and conveyed to an underground cast-in-place stormwater detention vault in the north central area of the site (Tract B). Discharge of treated and detained stormwater will be released to the aforementioned existing 24-inch storm bypass pipe in Tract C that outlets directly to Stream Z before leaving the site. The vault will be designed per the 2021 King County Surface Water Design Manual. Although CIP vaults are typically only allowed on private projects inside the City Core, Section 4.1 of the March 2019 Public Works Development Standards (PWDS) of the City of Federal Way allow the Public Works Director to approve the use of a CIP storm vault outside the City Core. In this case there is ample justification for using a CIP vault in lieu of an open stormwater pond. The same applicant received approval for Administrative Determination for CIP Storm Vault (approved File No. 22-105977-AD); if possible, the current application would request to use the existing approval. FEDERAL WAY COMPREHENSIVE PLAN CONSISTENCY The clustered Preliminary Plat proposal as designed enables development of the subject property in a manner consistent with the underlying zoning designation and Comprehensive Plan while also preserving trees, open spaces, critical areas and habitats, and improving vehicle and pedestrian mobility between neighborhoods. The following Federal Way Comprehensive Plan Policies support the proposed development. Emphasis added by underlining where applicable. LUP 17 Encourage the development of parks and the preservation of open space in and adjacent to residential areas to provide adequate recreational opportunities and preserve the natural setting of Federal Way. LUP 18 Continue to consider special development techniques (e.g., lot size averaging, cottage housing, accessory dwelling units, townhomes, duplexes, and planned unit developments) in single-family areas provided they result in residential development consistent with the quality and character of existing neighborhoods. LUP 19 Preserve site characteristics that enhance residential development (trees, watercourses, vistas, and similar features) using site planning techniques such as clustering, planned unit developments, and lot size averaging. 6 of 10 22154.005-Project Narrative-2023-12-04.docx TP 1.14 Develop and maintain a Layered Network that provides connectivity and recognizes that not all streets provide the same quality of travel experience. Classify streets as Freeway, Principal Arterial, Minor Arterial, Principal Collector, Minor Collector, or Local Street. Ensure that the Layered Network continues to provide for all varieties of street uses including regional mobility and cross-town trips, commuting, shopping, and recreational travel, property and business access, and parking, regardless of mode. TP3.13 Acquire access paths between existing developments, cul-de-sacs, public facilities, business areas, and transit followed by trail construction to improve non-motorized circulation. Require the same for all new developments or redevelopments. TP 3.18 Incorporate environmental factors into transportation decision-making, including attention to human health and safety. TP 4.1 Integrate land use and transportation plan decisions to support the land use vision and plan. TP 4.2 Enhance traffic circulation and access with closer spacing of through streets, where feasible, and limiting the area to be served by a single access point commensurate with planned density. HP 15 As appropriate, reduce minimum lot sizes to allow construction of smaller, detached single-family houses on smaller lots. HP 16 Increase capacity and encourage greater diversity of housing types and costs for both infill and new development through various methods, such as inclusionary zoning, density bonuses, and transfer of development rights, cluster housing, cottage housing, garden housing, duplexes, and low to moderate density housing types. NEP 2 Preserve and restore ecological functions, and enhance natural beauty, by encouraging community development patterns and site planning that maintains and complements natural landforms. NEP 3 Plant suitable native trees and vegetation within degraded stream, wetlands, lake buffers, and steep slopes. NEP 6 Mitigation sequencing steps, which begin with avoiding impacts altogether by not taking certain action or parts of an action, should be applied to all projects where impacts to environmentally critical areas are proposed. NEP 7 Implement and periodically update environmentally critical area regulations consistent with Best Available Science while also taking into consideration the City’s obligation to meet urban-level densities and other requirements under the GMA. NEP 9 The City will continue to encourage utilization of the soil safety program and Model Remedies Guidance for properties impacted by the Tacoma Smelter Plume. NEP 10 The City may continue to require environmental studies by qualified professionals to assess the impact and recommend appropriate mitigation of proposed development on environmentally critical areas and areas that may be contaminated or development that may potentially cause contamination. NEP 37 Continue to enforce erosion control measures for work in or adjacent to stream or lake buffers. NEP 38 Appropriate mitigation for detrimental impacts may be required for construction work within the buffer area associated with a stream or a lake. The City will continue to work in cooperation with the Department of Fish and Wildlife through the Hydraulic Project Approval permit process, as applicable, for development proposals that involve streams and lakes. NEP 82 Encourage minimal modification of trees within environmentally critical areas and their buffers. 7 of 10 22154.005-Project Narrative-2023-12-04.docx NEP 83 Encourage preserving forested areas within tracts and Native Growth Protection Easements when subdividing land. NEP 92 Regulate new development to ensure new blocks encourage walkability and maximize connectivity and route choice. Create reasonable block lengths to encourage more walking and physical activity. NEP93 Require the continuation of the street network between adjacent development projects to promote walkability and allow easier access for emergency vehicles. NEP 105 Open space provides important wildlife habitat corridors and should be linked with other designated regional and state open space systems. NEP 106 Preserve and restore habitat connections and tree canopy to link stream corridors, geologically hazardous areas, floodplains, wetlands, and critical habitat sites into a system of habitat corridors. This provides connections for wildlife, supports biodiversity, improves water quality, reduces risks due to flooding and landslides, and supports the City’s adaptation to climate change. CODE CONSISTENCY ANALYSIS CLUSTER SUBDIVISION CRITERIA (18.55 & 18.60) FWRC 18.55.040 The innovative or beneficial overall quality of the proposed development shall be demonstrated by the following criteria: (a) The subdivision provides innovative development, otherwise not allowed, but which promotes the goals of the comprehensive plan for architectural compatibility with single-family housing on adjacent properties. Response: The site is so highly constrained with critical areas that it is imperative to use the cluster subdivision criteria to reach a reasonable lot yield for future housing units as would otherwise be anticipated under the RS-15.0 zone. The proposed reduced lot sizes promote retention of existing critical areas and non-fragmented open space where existing trees can be retained. Innovative development is a subjective term, but the innovative measures employed in this proposal include varying lot sizes and shapes as well as utilization of the site resulting in minimal impacts to wetlands, streams, steep slopes, buffers, and surrounding neighborhoods. Even with the benefit of reducing lots sizes to 7,500 SF as allowed under these criteria for a cluster subdivision, the maximum lot yield for the project will still be just under 50 percent of what would be anticipated under the RS-15.0 zoning designation. However, the lot yield would be substantially less if the cluster provisions are not utilized, further reducing the number of proposed housing units in the city. (b) The subdivision provides the required open space. (New code language per Ord 23-966, adopted September 5, 2023) Response: The required amount of usable open space is 150 square feet per lot and 50 percent of the open space must be active open space. For the 19 lots proposed, the required usable open space equates to 2,850 square feet and the active open space requirement is 1,425 square feet. The project will provide active recreation and open space in Tract B on top of the stormwater vault, as depicted on the enclosed plans (Sheet L-3). The flat and open portion of Tract B is roughly 11,640 square feet, which far exceeds the 2,850 square feet required for the project. (c) Native trees are retained in accordance with FWRC 19.120.130 et seq. (New code language per Ord 23-966, adopted September 5, 2023) 8 of 10 22154.005-Project Narrative-2023-12-04.docx Response: A significant portion of the site will be undeveloped where tree retention will be achieved in Tract C, the critical area tract. Cluster development is being utilized in order to limit disturbance of sloped areas of the site because it is the best option for development that will result in successful retention of mature tree canopy and native vegetation. (d) Cluster lots immediately adjacent to existing neighborhoods have incorporated design elements through lot size and architecture to be compatible as approved by the community development director. (New code language per Ord 23-966, adopted September 5, 2023) Response: As designed, no new lots will abut any existing residential lots on neighboring properties. The project improves neighborhood connectivity with the extension of 22nd Avenue SW out to 21st Avenue SW. Open space, drainage, and critical areas tracts comprise the entire north, west, and south boundaries. The creative clustering results in lots that will have rear yards adjacent to open space with no physical or visual relationship or impact to any existing offsite lots. The proposed Cluster Subdivision would allow lots to be reduced to 50 percent of the underlying zone, which in this case is 7,500 square feet except for lots abutting the Lakota Ridge plat to the north, which is zoned RS-9.6, which must be at least 90 percent of the underlying zoning minimum, which would be 8,640 square feet. As no proposed lots abut any adjacent property, the project as designed complies with the minimum clustered lot area of 7,500 square feet. (e) The cluster subdivision will not result in destruction or damage to natural, scenic, or historic features. Response: The applicant is not aware of any existing natural, scenic, or historic features on the site. No destruction of features is proposed. All critical areas will be retained in one critical area tract. Stream buffer intrusion associated with the road fill across the ravine will be fully mitigated following grading. Fencing will be installed at the critical area tract boundaries to prevent human intrusion into the buffer areas. Cluster development is being utilized in order to limit disturbance of sloped areas of the site because it is the best option for development that will result in successful retention of mature tree canopy and native vegetation. (f) Each dwelling unit shall meet the design standards in the FWRC community design guidelines for cluster subdivisions. Response: Future homes will comply with 19.115.120 Design for cluster residential subdivision lots as required (requirements listed below) to be reviewed at the Building Permit stage. • Garages shall be provided for all residential lots, except if the lot is in a multi-family zone. • Front entryways should be the prominent feature of the home. Attached garages should not compose more than 40 percent of the front facade of the single-family home if the garage doors are flush with the front facade or will be set back a minimum of five feet from the rest of the front facade. Detached garages should also be set back a minimum of five feet from the facade. • If garage access is provided from alleys, the front yard setback can be reduced to 15 feet. • Each dwelling unit shall be intended for owner occupancy. APPLICANT'S RESPONSE TO PREAPPLICATION MAJOR ISSUES AND PRIOR REVIEWS Preapplication Meeting Comments dated July 11, 2022. 9 of 10 22154.005-Project Narrative-2023-12-04.docx 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. Planning Division • If the proposal is designed as a cluster subdivision, then additional FWRC cluster plat requirements apply regarding design, open space, etc. Response: Please see Cluster Plat Criteria Analysis in this document. The subject property is zoned RS-15.0. A Cluster Subdivision pursuant to FWRC 18.55.040 would allow lots to be reduced to 50 percent of the underlying zone, which in this case is 7,500 square feet except for lots abutting the Lakota Ridge plat to the north, which is zoned RS-9.6, which must be at least 90 percent of the underlying zoning minimum, which would be 8,640 square feet. The project has no lots abutting any neighboring property or subdivision; therefore, the lot areas comply with the minimum area of 7,500 square feet. • Any exploratory site reconnaissance work requires prior city review and approval. Response: Site reconnaissance work has been completed with city review and approval. • Several environmentally critical areas are present on the site and must be evaluated. Response: Special reports are provided to evaluate streams and wetlands, steep slopes, and the ravine crossing. In addition, an analysis relating to the ASARCO Smelter Plume is provided with the application materials. • Mass clearing and grading of the site is not supported by FWRC. Response: The enclosed plans and application materials include a clearing limits plan and a Clearing and Grading Permit and a Forest Practices Permit so that the Use Process III or IV review can be included in the SEPA, land use review, and public hearing, which will help streamline the future Site Development Review process as well. A separate modification request is enclosed to address FWRC 19.120.050. Public Works Development Services Division • AD-Administration determination for the proposed CIP vault is required because the project is outside the City Core. Response: An administrative determination was previously approved and is enclosed for use with the current proposal. • AD-Administration determination for the CMP box culvert is required. This concept is proposed instead of a soldier pile wall crossing a ravine. Response: This no longer applies as neither a box culvert nor soldier pile wall is proposed. The ravine crossing has been redesigned to utilize a reinforced slope. • Any storm pipe run at 15 percent or above require pipe anchors (2021 Surface Water Design Manual -Pipe Anchors) • Response: Compliance with this comment is demonstrated in the preliminary plat plan set. 10 of 10 22154.005-Project Narrative-2023-12-04.docx • A new review from Wetland/Fish and Game may be required for the proposed box culvert (if excepted) the last review was in 2017. Response: A box culvert is no longer proposed. The emergent point for Drainage “Y” will remain undisturbed with the proposed design using a reinforced fill slope so additional review by WFDW is not anticipated. Public Works Traffic Division • Transportation Concurrency Management (FWRC 19.90) – A transportation concurrency permit with application fee of $5,451 (11-50 Trips) is required for the proposed project. Response: The concurrency application is enclosed with the submittal package. • Traffic Impact Fees (FWRC 19.91) - Traffic impact fees are required for single family residential dwelling units and will be assessed at building permit stage. The estimated total traffic impact fee is $156,281.37. Response: Traffic impact fees are noted. • Frontage Improvements (FWRC 19.135.040) – Construct Street frontage improvements and dedicate right-of-way (ROW) for two (2) new streets within the property. Response: The site does not have any real "frontage" to existing streets; however, the on-site streets are designed consistently with city standards. A Right-of-Way Modification was previously approved (decision enclosed) for two sections of Road A in which the standard cross section would be narrowed in order to reduce the impacts to the stream buffer and steep, erosive slopes. • Access Management (FWRC 19.135.260) – The development shall meet access management standards. Response: New residential driveways will comply with the access management standards. No driveways are proposed within 25 feet of any intersection. Building Division • A geo report shall be submitted with each building permit application. • Any retaining walls will require third party review which is additional cost to the developer. Response: Noted. Technical and SEPA comments outlined in the review letter dated May 9, 2023 for the previous application have been addressed in the new application materials, as applicable per current codes and the updated design.