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2022 08-17 Planning Commission Agenda PacketCommissioners City Staff Lawson Bronson, Chair Wayne Carlson, Vice-Chair Keith Niven, Planning Manager Tim O’Neil Hope Elder Kari Cimmer, Admin & Permit Center Supervisor Diana Noble-Gulliford Tom Medhurst 253-835-2629 Jae So Anna Patrick, Alternate www.cityoffederalway.com Vickie Chynoweth, Alternate Vacant, Alternate K:\01 - Document Review\Planning\Planning Commission Documents\2022 08 August 17\To Be Purged\2022 08-17 Planning Commission Agenda.docx City of Federal Way PLANNING COMMISSION August 17, 2022 City Hall 6:00 p.m. City Council Chambers AGENDA 1. CALL TO ORDER 2. ROLL CALL 3. APPROVAL OF MINUTES a. Planning Commission Meeting of July 20, 2022 4. PUBLIC COMMENT (NON-HEARING COMMENTS) 5. COMMISSION BUSINESS a. Public Hearing: 2022 Annual Comprehensive Plan Amendments i. Staff Presentation ii. Commission Questions iii. Public Comment iv. Commission Deliberation 6. STAFF BUSINESS a. Manager’s Report 7. NEXT MEETING a. September 7, 2022 – Regular Meeting 8. ADJOURNMENT Planning Commission meetings are held in-person. To request accommodation to attend or to provide public comment virtually, please contact Kari Cimmer at 253-835-2629 or karic@cityoffederalway.com, no later than 5:00 p.m. on Tuesday, August 16, 2022. Planning Commission Minutes Page 1 July 20, 2022 CITY OF FEDERAL WAY PLANNING COMMISSION July 20, 2022 6:00 p.m. City Hall MEETING MINUTES 1. CALL TO ORDER Chair Bronson called the meeting to order at 6:00 p.m. 2. ROLL CALL Commissioners present: Lawson Bronson, Hope Elder, Tim O’Neil, Tom Medhurst, Jae So, Anna Patrick, and Vickie Chynoweth. Diana Noble-Gulliford participated via Zoom audio. Chair Bronson excused Commissioner Carlson. City Staff present: Planning Manager Keith Niven, City Attorney Kent van Alstyne, and Admin & Permit Center Supervisor Kari Cimmer. 3. APPROVAL OF MINUTES Commissioner So moved to approve the July 6, 2022 minutes as submitted. Commissioner Elder seconded. 4. PUBLIC COMMENT None 5. COMMISSION BUSINESS Planning Manager Niven introduced and reviewed a memorandum addressing questions posed by Commissioners at the July 6, 2022 Meeting. Planning Manager Niven began a review of the Shoreline Master Program (SMP) Chapter, Policy Section, presentation. Mr. Niven noted that of the 105 Shoreline Policies to be covered tonight a great majority will simply be a “should” to “shall” verbiage change. As was requested by Commissioner So, he will spend tonight’s review time on the more substantive changes. Commissioner O’Neil had questions regarding cell towers. City Attorney van Alstyne noted stated the cell towers regulations are in our zoning code. 6. MANAGER REPORT A stakeholder virtual meeting for the South Station area will be held on Thursday, July 21 and the Planning Commissioners are invited to attend. Page 2 of 74 Planning Commission Minutes Page 2 July 20, 2022 The Ad Hoc committee members are attending a meeting on August 2 at 5:30 p.m., to do a SWAT analysis of the downtown. All Commissioners are invited to come as citizens. A reminder that the Bally’s hearing will be on August 9, 2022 City Council meeting. The 2022 Comp Plan Amendments for the Rivera property and the Traffic division will be presented at the August 17, 2022 Planning Commission meeting. 7. NEXT MEETING Planning Manager Niven announced the next meeting of the Planning Commission will be held at 6:00 p.m. on August 17, 2022, which will be a public hearing. 8. ADJOURNMENT Commissioner Medhurst moved that the meeting be adjourned; Second by Commissioner O’Neil. The meeting adjourned at 7:18 p.m. Attest: Approved by Commission: _______________________________________ __________________ Kari Cimmer, Admin & Permit Center Supervisor Date Page 3 of 74 STAFF REPORT TO THE FEDERAL WAY PLANNING COMMISSION June 7, 2022 TO: Federal Way Planning Commission FROM: Brian Davis, Community Development Director Keith Niven, AICP, CEcD, Planning Manager Natalie Kamieniecki, Associate Planner SUBJECT: 2022 Comprehensive Plan Amendments Rivera Property Site Specific Request Public Works Text Amendments MEETING DATE: August 17, 2022 I. BACKGROUND Pursuant to RCW 36.70A.130 (5)(a), the City of Federal Way must update its comprehensive plan every ten years. The deadline for the next major update is December 31, 2024. However, per Federal Way Revised Code (FWRC) 19.80.050, the city has elected to review citizen-initiated requests on an annual basis. As part of the annual review, the city may also make changes to chapters and maps of the comprehensive plan. Federal Way adopted its comprehensive plan in 1995 and updated it in December 1998, December 2000, November 2001, March 2003, July 2004, June 2005, July 2007, June 2009, October 2010, January 2011, January 2013, June 2015, January 2018, April 2019 and January 2021. The Growth Management Act (GMA, RCW 36.70A.130 [2] [a]) limits plan updates to no more than once per year, except under the following circumstances: 1. The initial adoption of a subarea plan that clarifies, supplements, or implements jurisdiction-wide comprehensive plan policies; 2. The development of an initial subarea plan for economic development located outside of the one hundred year floodplain in a county that has completed a state- funded pilot project that is based on watershed characterization and local habitat assessment; 3. The adoption or amendment of a shoreline master program; 4. The amendment of the capital facilities element of a comprehensive plan that occurs concurrently with the adoption or amendment of a county or city budget; or Page 4 of 74 Staff Report to Planning Commission Page 2 Public Hearing June 15, 2022 doc. id. 82301 5. The adoption of comprehensive plan amendments necessary to enact a planned action. Except as otherwise provided above, the governing body shall consider all proposals concurrently, so the cumulative effect of the various proposals can be ascertained. However, after appropriate public participation, a county or city may adopt amendments or revisions to its comprehensive plan that conform to this chapter whenever an emergency exists, or to resolve an appeal of a comprehensive plan filed with a growth management hearings board or with the court. II. REASON FOR PLANNING COMMISSION ACTION FWRC Chapter 19.80, “Council Rezones,” establishes a process and criteria for comprehensive plan amendments. Consistent with Process VI review, the role of the Planning Commission is as follows: 1. To review and evaluate the requests for comprehensive plan amendments; 2. To determine whether the proposed comprehensive plan amendments meet the criteria provided by FWRC.80.140, 19.80.150, and 19.75.130(3); and 3. To forward a recommendation to the City Council regarding adoption of the proposed comprehensive plan amendments. III. PROCEDURAL SUMMARY Selection Process (Prioritizing Docketed Proposals) February 7, 2022 Land Use Transportation Committee (LUTC) Meeting February 15, 2022 City Council Public Hearing Comprehensive Plan Amendment Process April 15, 2022 Issuance of Determination of Nonsignificance pursuant to the State Environmental Policy Act (SEPA) April 29, 2022 End of SEPA Comment Period May 20, 2022 End of SEPA Appeal Period May 27, 2022 Notice of Planning Commission Public Hearing (exhibit W) June 15, 2022 Public Hearing before the Planning Commission July 6, 2022 Public Hearing continuance (if needed) September 9, 2022 LUTC Meeting October 4, 2022 City Council 1st Reading Page 5 of 74 Staff Report to Planning Commission Page 3 Public Hearing June 15, 2022 doc. id. 82301 October 18, 2022 City Council 2nd Reading IV. 2022 COMPREHENSIVE PLAN AMENDMENTS This annual update includes one citizen-initiated request for amendments to comprehensive plan designations and zoning; and, Public Works Text Amendments for Non-motorized transportation improvements throughout the city and around the transit center. The Rivera site-specific request is described in Section V of this staff report, the Public Works Text Amendments are described in Section VI. V. CITIZEN-INITIATED SITE-SPECIFIC REQUEST 1. Site-Specific Request – Richard Rivera Property Request for a comprehensive plan amendment and rezone of parcel no. 052104-9204, 1.26- acre site, located at 1600 South 304th Street, from Professional Office (PO) to Community Business (BC) (exhibits I and J). Reason for the Request The applicant previously obtained project approval for an office building under permit #07- 105965-UP (expired, July 18, 2016). The applicant asserts that current and past high vacancy rates for office buildings in the city has inhibited financial institutions from approving construction loans for new professional office buildings in Federal Way. The Community Business (BC) zone affords flexibility in retail, office and residential uses. The immediate area is developed with a variety of land uses including Federal Way High School, mixed retail uses, religious assembly, vehicles service station and residential units including attached dwelling units and single-family dwelling units. In addition, there are other BC-zoned properties adjacent and in the nearby area including to the south, east and southeast of the subject property. Summary Applicant: Richard Rivera Property Owner: Richard Rivera Existing Comprehensive Plan Designation: Professional Office (PO) Existing Zoning Designation: Professional Office (PO) Requested Comprehensive Plan Designation: Community Business (BC) Parcel No. Address Size in Acres Existing Land Use 052104-9204 1600 S 304th St 1.26 acres Vacant property Page 6 of 74 Staff Report to Planning Commission Page 4 Public Hearing June 15, 2022 doc. id. 82301 Requested Zoning Designation: Community Business (BC) Surrounding Zoning & Land Use Zoning Land Use North Single-Family (RS9.6, minimum lot size 9,600 square feet) Single Family Residence South Community Business (BC) Federal Way High School, Union 76 Car wash station East Multi-Family (RM 2400) Attached dwelling units West Professional Office (PO), Community Business (BC) Office use Availability of Utilities Sanitary Sewer: Lakehaven Water and Sewer provides sewer service in this area. Sewer service is available adjacent to the property along both S 304th Street and 16th Avenue S. Future site development would require onsite sewer extension &/or sewer service connections from Lakehaven Water and Sewer District (exhibit K). Public Water: Lakehaven Water and Sewer District provides water service in this area. Existing water service is available adjacent to the property along both S 304th Street and 16th Avenue S. Future site development would require onsite water main extension &/or water service connections from Lakehaven Water and Sewer District (exhibit K). Solid Waste: Solid waste is provided by Waste Management. Availability of Public Services Police: Police protection is provided by and will continue to be provided by the City of Federal Way Police Department should development occur. A component of the Community Design Guidelines applications for development would be required to submit the Crime Prevention Through Environmental Design. Checklist. The provisions within the code section promote concepts to reduce attraction of crime. Fire/Emergency/Medical: These services are provided by South King Fire and Rescue. The South King Fire has indicated that they have no comment regarding the proposed comprehensive plan and rezone of the site from PO to BC. Page 7 of 74 Staff Report to Planning Commission Page 5 Public Hearing June 15, 2022 doc. id. 82301 Schools: This area falls within the boundaries of Federal Way School District. School impact fees for residential uses are collected at the time of building permit. Critical Areas There are no mapped or known critical areas. No geologically hazardous landslide or erosion hazard. No wetlands or fish and wildlife habitat is located on or within 225 feet of the subject property. The site is not located within a regulated aquifer recharge or wellhead protection area. The site is not located within a flood hazard area or shoreline jurisdiction. Drainage 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. Future development must meet 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. The project site lies within a Conservation 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 Enhanced Basic Water Quality Area. Water Quality Treatment shall be designed to meet the treatment criteria of the Enhanced Basic Water Quality Menu. Access This parcel has street frontage on 304th Street and 16th Avenue South. Final access and driveway location will be reviewed through future site-specific development applications. Potential Traffic Impacts This is a non-project action associated with changing the comprehensive plan designation and zoning from Professional Office (PO) to Community Business (BC). This non-project action and potential impacts to traffic are evaluated at a high level. However, should this request be approved, at the time that an application for a development permit is submitted, the Traffic Division will conduct a Transportation Concurrency Analysis, which will analyze peak hour impacts of the project to assure that there is adequate capacity to accommodate the proposed development. Supplemental mitigation may be required if the proposed project creates an impact not anticipated in the Transportation Improvement Plan (TIP). Development proposals will also be subject to a traffic impact fee to address system impacts. Site-specific analysis may also be required to address impacts outside of the evening peak hour or safety issues. VI. Public Works Comprehensive Plan Amendments The following Comprehensive plan amendments are requested by the Public Work Department for non-motorized transportation improvements: A. City Center: Page 8 of 74 Staff Report to Planning Commission Page 6 Public Hearing June 15, 2022 doc. id. 82301 Extend BPA Trail from 11th PL/13th Ave S along north side of S. 324th St to 23rd Ave S and along west side of 23rd Ave S from S. 324th to S. 320th Street (exhibit A & B). This project element is included under City’s CIP, Project #16 (exhibit M). The proposed amendment results in an 18 foot-wide multi use / shared-used path and regional trail connection to the BPA Trail (exhibit C) and consistent with the Federal Way City Center Access Project – Proposed Solution Community Outreach Summary (exhibit L). B. Federal Way Transit Center Pedestrian Connection: Construct sidewalk to preserve pedestrian access between large blocks with in City Center, specifically from Pete von Reichbaurer Way S and 21st Ave S (exhibit D). This project is included under City’s CIP, Project # 29 (exhibit N). The proposed amendment will improve and preserve non-motorized transportation safety for those accessing the Federal Way Transit Center. C. North Fork West Hylebos Trail: Construct Trail within Spring Valley along North Fork of West Hylebos Creek (exhibit E). Typical cross section in nonenvironmentally sensitive areas (Asphalt Concrete) and boardwalk within environmentally sensitive areas (exhibit F & G), respectively. This project is included under City’s CIP, Project # 42 (exhibit O). The proposed amendment will increase opportunities to connect the community with the natural environment as well as connect to Todd Beamer High School. The project would be a joint venture between Public Works Surface Water Management (SWM) and the Parks Department. D. Non-Motorized Facilities Around South Federal Way Transit Station (exhibit H): Project Description 1 S. 359th: SR 99 to SR 161: Construct sidewalk and bike lanes on both sides of the street 2 16th Avenue S: S. 359th to S. 364th Way: Construct sidewalk and bike lanes on both sides of the street 3 S. 359th and SR 161: Construct staircase and ADA accessible ramp 4 I-5 Crossing: S. 359th to 20th Avenue S: Construct non-motorized crossing 5 20th Avenue S and S. 360th: SR 161 to 32nd Avenue S: Construct sidewalk and bike lanes on both sides of the street 6 Milton Road S: SR 161 to S 369th St: Construct sidewalk and bike lanes on both sides of the street VII. Public Comments Received The following is a summary of the comments received during the notice of application and SEPA Environmental Determination. Comment letters are included as an attachment to this staff report. Rivera Property • Lives directly across from the proposed rezone. Concerns over increased traffic and crime. Development will displace families that have lived in the area for more than 40 years (exhibit P). Page 9 of 74 Staff Report to Planning Commission Page 7 Public Hearing June 15, 2022 doc. id. 82301 • Bought home with understanding that property was zoned PO for office use. BC could allow multi-family housing. Concerns with traffic and crime (exhibit Q). • Strongly oppose, could allow multi-family. Part of the “American Dream” is owning a house not living in an apartment (exhibit R). • Development of the property will result in traffic congestion and increased crime. The proposal will displace families and decrease property values (exhibit S). • Concerns about impact to the neighborhood and if an impact study has been conducted (exhibit T). • Adjacent office property currently experiences illegal activity. Proposal will increase crime and vehicle break-ins. Impacts associated with overflow parking from activities related to Federal Way High School (exhibit U). • Concerns over change in zoning that would allow multi-family housing. Proposal will have a negative effect to Federal Way High School and neighboring homes. Significantly increase traffic and crime (exhibit V). Public Works • No comments were received on the proposed text amendments for non-motorized transportation improvements. VIII. COMPLIANCE WITH FWRC 19.80.140 - FWRC 19.80.140, Factors to be Considered in a Comprehensive Plan Amendment – The city may consider, but is not limited to, the following factors when considering a proposed amendment to the comprehensive plan. (1) The effect upon the physical environment. Rivera Property There are no foreseeable or anticipated significant adverse impacts on the physical environment related to development of this property. Regardless of zoning, the city has adopted codes and regulations in place to protect the environment. There are no mapped or known critical areas on site. No mapped or known geologically hazardous landslide or erosion hazard onsite. No wetlands or fish and wildlife habitat is located on or within 225 feet of the subject property. The site is not located within a regulated aquifer recharge or wellhead protection area. The site is not located within a flood hazard area or shoreline jurisdiction. Public Works There will be no adverse or unmitigated impact on the physical environment related to development of the proposed Public Works non-motorized transportation improvements. The city has adopted environmental codes in place to protect the environment. Project specific environmental review will occur with each requested project. Planning non- motorized transportation options with an emphasis on including non-motorized routes, greater mobility options, alternatives to driving, and lowering transportation-related energy consumption is consistent with the city’s transportation state and regional policies (FWCP Chapter 3.1) and a benefit to the physical environment. Page 10 of 74 Staff Report to Planning Commission Page 8 Public Hearing June 15, 2022 doc. id. 82301 (2) The effect on open space, streams, and lakes. Rivera Property The project is currently undeveloped land. There are no mapped lakes or streams on or within close proximity to the site. Development of the site as currently zoned or as proposed will not impact open space, streams or lakes. Public Works A. City Center – Proposal to extend BPA Trail will not affect open space, streams or lakes. B. Federal Way Transit Center Pedestrian Connection – Proposed pedestrian connection is located within currently developed city blocks north of S 320th St between Pete von Reichbauer Way S and 21st Ave S. This connection will not affect open space, streams or lakes. C. North Fork West Hylebos Trail – The proposed boardwalk will require project specific environmental review and critical areas assessment. The boardwalk does diminish open space, lakes or streams. The project will enhance environmental education opportunities. D. Non-Motorized Facilities Around South Federal Way Transit Station non- motorized capital projects – Individual projects will require site specific environmental review as needed. The projects will not impact open space, lakes or streams. (3) The compatibility with and impact on adjacent land uses and surrounding neighborhoods. Rivera Property The FWRC provides development regulations to offset impacts to adjacent property through setbacks, height limitations, landscaping, tree retention, building, site design criteria; etc., for all developments. Specifically, concerns regarding height of potential multi-family structures has been received through public comment. For a site-specific comprehensive plan amendment, a declared use and development plan is not required. However, current regulations contain provisions to offset height impacts on adjacent residential or single-family residential zoned property. for example, multifamily structures within the BC zone are limited to a building height that may not exceed 30 ft. above average building elevation for the portion of the building located within 100 ft. from a single-family residential zone. The height limitation of 30 feet within 100 feet of a residential zone or single-family residential zone is echoed throughout the uses permitted in the BC zone. Public Works The Public Works text amendments for non-motorized transportation improvements are primarily comprised of completing or constructing sidewalks, improving bicycle transportation, pedestrian connectivity to the Federal Way Transit Center and other similar improvements at locations throughout the city. The proposal also includes improving access to the natural environment via the West fork Hylebos Trail and Boardwalk. These uses are compatible with the surrounding land uses and neighborhoods. Page 11 of 74 Staff Report to Planning Commission Page 9 Public Hearing June 15, 2022 doc. id. 82301 (4) The adequacy of and impact on community facilities including utilities, roads, public transportation, parks, recreation, and schools. Rivera Property All public utilities are available to the subject property. School impact fees are collected during the building permit phase if future development includes residential uses. The project site is within ¼ mile of bus transit service. Traffic mitigation will be implemented during project specific review. There are a wide variety of recreational opportunities in the city. These opportunities include Dash Point State Park (a 398-acre state park on the west side of the city, operated and maintained by Washington State Parks); Celebration Park (an 84-acre city-owned community park located approximately in the middle of the city with ballfields and walking trails); Town Square Park (a four-acre city-owned community park located in the City Center); and recreation trails in the Bonneville Power Administration right-of-way. There are also a number of other parks and open space areas scattered throughout the city. The Rivera Property is privately owned property and is not a public park, protected open space or green belt. City codes require provision of on-site open space, or a fee-in-lieu of open space, if land is developed for residential uses.This is a non-project action and there is no site-specific proposal; however, if the parcel is developed with residential uses in the future, impacts on schools would be mitigated by the payment of a school impact fees. The listed elements community facilities including utilities, roads, public transportation, parks, recreation, and schools are adequate to accommodate the proposal. Public Works The proposed amendments serve to provide viable and safe alternative access for pedestrian and other non-motorized options to travel to community facilities, travel along roadways and arrive at public transportation facilities. The west Fork Hylebos Trail will enhance parks and recreations opportunities and connect to Todd Beamer High School. The listed elements community facilities including utilities, roads, public transportation, parks, recreation, and schools are adequate to accommodate the proposal. (5) The benefit to the neighborhood, city, and region. Rivera Property The existing neighborhood pattern includes commercial, office, civic, single-family and multi-family uses. At present, vacancy rates of existing office buildings continue to climb making office developments less likely to be constructed or viable for the foreseeable future. Unsecured vacant properties that do not have established uses or the appearance of ownership are subject to trespass and illegal dumping or encampments. The BC zone allows for a mixture of uses more compatible with the surrounding development. Public Works The proposed amendments aim to maintain mobility through a safe, balanced, and integrated transportation system, enhance community health and livability through a connected system of non-motorized pedestrian, bicycle and transit ways that are part of a regional transportation network aimed at reducing dependency on individual private vehicle transportation. Page 12 of 74 Staff Report to Planning Commission Page 10 Public Hearing June 15, 2022 doc. id. 82301 (6) The quantity and location of land planned for the proposed land use type and density and the demand for such land. Rivera Property Professional Office or Office Park designation in not in demand and existing office building vacancy has significantly increased in the post pandemic work scape trends. Demand for land that is flexible and allows mixed use development with respect to commercial retail and residential uses is in demand and need to reach employment and housing goals. Public Works Not applicable for non-motorized transportation improvements identified in this report. (7) The current and projected population density in the area. Rivera Property Population growth continues to steadily increase within the City of Federal Way (FWCP 2.3, figure II-3). The proposal is a non-project action comprehensive plan amendment and does not require a site-specific proposal. If residential development or mixed use commercial residential is proposed at the site the number of units would depend on development regulations for access and stormwater infrastructure, and zoning restrictions due to height, parking, landscaping, and open space requirements. As identified in the Housing Action Plan the area in general can accommodate such development. In addition, Federal Way needs to add approximately 6,800 new units before 2040 to accommodate expected population growth and account for past underproduction. This equates to an average production of 339 units each year, a 68% increase over recent housing production trends Public Works Population within the city and region continues to grow. Diverse options for non- motorized transportation available to residence of all mobility types and needs are increasingly vital to the success of an emerging multi-modal progressive transit-oriented city. (8) The effect upon other aspects of the comprehensive plan. Rivera Property The Community Business designation encompasses two major retail/commercial areas along the SR-99 corridor, including the segment generally between South 272nd Street and South 312th Street, and the segment between South 324th Street and approximately South 339th Street. Presently, these areas are characterized by a wide range of development types and appearances, including older, single-story developments that provide excellent redevelopment opportunities (FWCP 2.7). Approval of the requested Community Business (BC) comprehensive plan designation at the subject property not affect other aspects of the comprehensive plan. Public Works Approval of the requested text amendments will not affect other aspects of the Community Plan. IX. COMPLIANCE WITH FWRC 19.80.150 - Criteria for Amending the Comprehensive Plan – The city may amend the comprehensive plan only if it finds that: Page 13 of 74 Staff Report to Planning Commission Page 11 Public Hearing June 15, 2022 doc. id. 82301 (1) The proposed amendment bears a substantial relationship to public health, safety, or welfare; Rivera Property Changing the designations from Professional Office to Community Business does have a substantial relationship to public health, or safety in that in the event the property is developed with any of the allowed uses within the BC zone there is an increased chance that the site will be occupied with relevant uses other than the dwindling office use type. It is not likely that sorely office use would be financially viable or the highest and best use of the site. With diverse use types permitted in the BC zone it is more likely the site would be developed, occupied and be productive for the overall economic growth of the city. Developed and occupied sites generally deter illegal trespass, encampments and garbage dumping. If in the future residential development were proposed at this location, the Housing Action Plan has indicated that this area having the potential to the contribution of additional residential units to meet expected population growth goals. Due to the small size of the subject property there is an increased probability that small businesses would be able to thrive at this location, potentially adding job opportunities. Public Works Please see response under Sections V (4) & V (5). (2) The proposed amendment is in the best interest of the residents of the city. Rivera Property and Public Works As detailed throughout this report, the Rivera Property proposal and the Public Works non-motorized transportation improvements text amendments are in the best interest of the residents of the city. (3) The proposed amendment is consistent with the requirements of Chapter 36.70A RCW and with the portion of the city’s adopted plan not affected by the amendments. The comprehensive plan amendments under consideration are consistent with the following goals of RCW Chapter 36.70A.020 of the Growth Management Act (GMA). The following goals are not listed in order of priority and shall be used exclusively for the purpose of guiding the development of comprehensive plans and development regulations: i. Urban growth. Encourage development in urban areas where adequate public facilities and services exist or can be provided in an efficient manner. ii. Transportation. Encourage efficient multimodal transportation systems that are based on regional priorities and coordinated with county and city comprehensive plans. iii. Housing. Plan for and accommodate housing affordable to all economic segments of the population of this state, promote a variety of residential densities and housing types, and encourage preservation of existing housing stock. iv. Economic development. Encourage economic development throughout the state Page 14 of 74 Staff Report to Planning Commission Page 12 Public Hearing June 15, 2022 doc. id. 82301 that is consistent with adopted comprehensive plans, promote economic opportunity for all citizens of this state, especially for unemployed and for disadvantaged persons, promote the retention and expansion of existing businesses and recruitment of new businesses, recognize regional differences impacting economic development opportunities, and encourage growth in areas experiencing insufficient economic growth, all within the capacities of the state's natural resources, public services, and public facilities. Rivera Property The Rivera property proximate location to Pacific Highway S and disassociated with the predominate locations of existing Office Park and Professional Office designations. The proposed BC designation would be consistent with the existing BC corridor identified in the Comprehensive Plana and is consistent with the following policies of the comprehensive plan for the Community Business Comprehensive Plan Designation: General Policies for Commercial, Office, and Commercial Enterprise The following apply to all commercial, office, and commercial enterprise designations. In some instances, specific goals and policies may follow a specific land use designation. • LUP 26 Provide for a mix of commercial and residential uses in most commercial areas • LUP 27 Use design and performance standards to integrate multi-family development into commercial developments as commercial/ residential mixed-use development. Performance standards should focus on scale, appearance, and compatibility. • LUP 29 Ensure compatibility between non-residential developments and residential zones by regulating height, scale, setbacks, and buffers Community Business • Goal LUG6 Transform Community Business areas into vital, attractive, areas with a mix of uses that appeal to pedestrians, motorists, and residents, and enhance the community’s image. Policies • LUP 39 Encourage transformation of the Pacific Highway (SR-99) Community Business corridors into quality retail/commercial mixed-use areas, designed to integrate auto, pedestrian, and transit circulation, and to improve traffic flow and safety, including access control and off-street interconnectivity between adjoining properties where feasible. Continue to utilize Community Design Guidelines to ensure quality site and building design and functional and aesthetic compatibility between uses. Integration of pedestrian amenities and open space into retail and office development should also be encouraged. • LUP 40 Encourage a range of pedestrian-oriented retail, while continuing to accommodate auto-oriented retail uses, and provide supportive uses to meet the needs of residents and employees in the area. Public Works Page 15 of 74 Staff Report to Planning Commission Page 13 Public Hearing June 15, 2022 doc. id. 82301 Public Work Department request Comprehensive Plan text amendments to include the non-motorized transportation improvements consistent with the goals and policies of the FWCP - Chapter Three, Transportation. An overarching goal of the city is safety, accessibility, and a connected multi-modal non-motorized network. • Goal 1 TG1 Maintain mobility through a safe, balanced, and integrated transportation system. • Policies TP1.1 Reduce reliance on drive alone trips by prioritizing and implementing supportive local-level transit, high occupancy vehicle (HOV), and nonmotorized improvements. • TP1.10 Coordinate with transit agencies to provide convenient non-motorized access to transit facilities. • Goal 3 TG3 Enhance community health, livability, and transportation by providing a connected system of pedestrian, bicycle, and transit ways that are integrated into a coordinated regional network. • TP3.8 Encourage non-motorized improvements that minimize the need for residents to use motorized modes by extending the existing non-motorized system and providing: 1. Access to activity centers and schools; 2. Linkage to transit, park & ride lots, and school bus networks; 3. Completion of planned pedestrian/jogging or bicycle trails; 4. Designating a network of streets that can safely and efficiently accommodate bicycles; and, 5. Extend sidewalks to all streets. • Goal 5 TG5 Develop and implement transportation systems management strategies and programs that contribute to the overall effectiveness of the multimodal transportation system. • TP5.8 Encourage the provision of a robust transportation alternative rich environment so that all members of the community, including those with transportation disadvantages, have viable travel options or alternatives. X. FWRC 19.75.130(3)(a), Recommendation by the Hearing Examiner. In this instance, through the consolidated review process of FWRC 19.15.060, the Planning Commission applies the criteria listed in FWRC 19.75.130(3)(a) instead of the Hearing Examiner. Because this application is utilizing the consolidated review process of FWRC 19.15.060, the Planning Commission will forward a recommendation to the City Council as provided under FWRC 19.80.240. After considering all of the information and comments submitted on the matter, the Planning Commission shall issue a written recommendation to the city council. The Planning Commission shall use the following criteria for quasi-judicial rezones: (3) Decisional criteria. The hearing examiner shall use the following criteria for quasi-judicial rezones: (a) The city may approve an application for a quasi-judicial nonproject rezone only if it finds that: (i) The proposed rezone is in the best interest of the residents of the city; and Page 16 of 74 Staff Report to Planning Commission Page 14 Public Hearing June 15, 2022 doc. id. 82301 Rivera Property The change in designation and zone would allow for the property to be developed as any of the listed uses in FWRC 19.220 – Community Business. The property does not contain any mapped or known critical areas and is served by urban infrastructure and services that can support the proposed designation and uses. Public Works Not applicable. (ii) The proposed rezone is appropriate because either: (A) Conditions in the immediate vicinity of the subject property have so significantly changed since the property was given its present zoning and that, under those changed conditions, a rezone is within the public interest; or (B) The rezone will correct a zone classification or zone boundary that was inappropriate when established; Rivera Property Conditions in the immediate vicinity of the subject property have significantly changed since the property was given its present zoning and since the City of Federal Way incorporated has remained undeveloped. At present, vacancy rates of existing office buildings in the city are approximately 26-30%, making office developments less likely to be constructed or viable. This is the case with the Rivera Property. The applicant previously obtained project approval for an office building under permit #07-105965-UP (expired, July 18, 2016). The applicant asserts that current and past high vacancy rates for office buildings inhibited the project to obtain funding. Unsecured vacant properties that do not have established uses or the appearance of ownership are subject to trespass and illegal dumping or encampments. The BC zone allows for a mixture of uses more compatible with the surrounding development and BC corridor identified in the Federal Way Comprehensive Plan (FWCP 2.7, II-14). Public Works Not applicable. (iii) It is consistent with the comprehensive plan; Rivera Property Not applicable as the rezone is accompanied by a comprehensive plan map amendment. Public Works Not applicable. (iv) It is consistent with all applicable provisions of the title, including those adopted by reference from the comprehensive plan; and Rivera Property The proposal to rezone the Rivera Property from PO to BC is consistent with all applicable provisions of the title, including those adopted by reference from the comprehensive plan. Page 17 of 74 Staff Report to Planning Commission Page 15 Public Hearing June 15, 2022 doc. id. 82301 Public Works Not applicable. (v) It is consistent with the public health, safety, and welfare. Rivera Property The proposal to rezone the Rivera Property from PO to BC is consistent with public health, safety and welfare. Public Works By providing additional non-motorized improvements, the city is increasing the opportunity for people to make healthy mobility choices. XI. PLANNING COMMISSION ACTION Consistent with the provisions of FWRC 19.80.240, the Planning Commission may take the following actions regarding each proposed comprehensive plan amendment and rezone request: 1 Recommend to City Council adoption of the proposed comprehensive plan amendments as proposed; 2. Recommend to City Council that the proposed comprehensive plan amendments not be adopted; 3. Forward the proposed comprehensive plan amendments to City Council without a recommendation; or 4. Recommend to the City Council that the Rivera amendment be approved and the Public Works Amendments be denied; or 5. Recommend to the City Council that the Public Works Amendments be approved and the Rivera amendment be denied; or 6. Modify the proposed comprehensive plan amendments and recommend to City Council adoption of the amendments, as modified. Exhibits • “A” City Center Extend BPA Trail (11th PL13th Ave S along north side of S. 324th St to 23rd Ave S) • “B” City Center Extend BPA Trail (west side of 23rd Ave S from S. 324th to S. 320th ST • “C” City Center S 324th ST & 23rd Ave S (Roadway Cross Section) • “D” Federal Way Transit Center Pedestrian Connection (Construct Sidewalk) • “E” North Fork West Hylebos Trail Approximate Location • “F” North Fork West Hylebos Trail (Trail Cross Section) • “G” North Fork West Hylebos Trial (Boardwalk Cross Section) • “H” Public Works Sound Transit Non-Motorized Access Project • “I” Zoning Map of Site-Specific Request #2 – Rivera • “J” Aerial Map of Site-Specific Request #2 – Rivera • “K” Lakehaven Water and Sewer Map 21-104065-UP Page 18 of 74 Staff Report to Planning Commission Page 16 Public Hearing June 15, 2022 doc. id. 82301 • “L” CCA Outreach Report Summary Fall 2019 • “M” Capital Improvements Project 16 City Center • “N” Capital Improvements Project 29 FWTC Pedestrian Access Improvements • “O” Capital Improvements Project 42 West Hylebos Trail • “P” Public Comment Steven Smith 5-1-22 • “Q” Public Comment Jim and Ramona High 4-22-22 • “R” Public Comment Harold G 4-24-22 • “S” Public Comment Loni Held 5-1-22 • “T” Public Comment Larry Menzel 5-11-22 • “U” Public Comment Kara Bee 4-27-22 • “V” Public Comment GP Ericksen 4-24-22 • “W” Notice of Planning Commission Public Hearing Page 19 of 74 Page 20 of 74 Page 21 of 74 Page 22 of 74 Page 23 of 74 Page 24 of 74 Page 25 of 74 Page 26 of 74 West Hylebos Wetlands Park Five Mile Lake Park South County Hylebos Wetlands WestHylebosCreekH y l e b o s C re e k HylebosCreekH ylebosCr eekBrook Lake Lake Geneva Fivemile Lake Trout Lake Mud Lake Milton Federal Way 19th Ave5thAve26th Ave Ct12thAveAlder St S380Th St 28th Ave SS 376Th St 23rd Ave15th Ave23rdPl S Comet St 23rdAveSS 368 t h Pl S 3 4 5 th S t32nd Ave SS 342nd St 35thWaySS lP ts131stAveSS 334th St 13th Pl SS 333rd St S 357th St 42ndAveSS 352nd St45thAveS38thAveS S 356th St S 37 5 t h S t 45thW ayS37th Ave S2 6th D r SS 371st PlForestLn MiltonRdSUnnamed 25thAveCtSS 358th St 26th Ave S19thWaySS 380th S t20thAveS33rdPlSS340thSt 51stAveSS 356th P l2ndLnS 22ndAveSS 361st Pl S 372nd Pl S 380thPl 35th Ave SS 3 4 1s t Pl 40th Ave SWeyerhaeuserRd17thAveS46th Ave SS 371st St 38th Ave SS379 t h S t S 370th St S 363rd P ldPlSS333rd St S 3 6 2 n dPl44th Ave S9thAveS18thAveS50th Ave SS 360th St S 3 58t h St 8 t h A veS S 355th PlS333rdLn S 374th St S 376th StS334thSt S 338th St S 349th St 17th Ave40th Ave SS 351st St S 332nd St 16th Ave SS 340th St S 353rd Pl 48th Ave SS 337th Ln S 368th StS364thWay S 376th Pl S378 t h St 41stAveS41stPlS3rd Pl S38th Ave SS 344th St 12thPl S S 3 4 4thWay39th Ave SS369th St 45thPlSS341 stPl6thAveS1st L nS36th Pl SS 3 4 2n d P l45thAveSVirgi niaCtS375t h P lS 340thPl Unn amedS lP ht0118th Pl SS evA ht8S lP ht432 1stAveSS 374th Pl S 348th St S 346th St S 362nd St 44th Ave SS 359th St S354thSt21st Ave S37thPlS49th Ave SS evA ht7439th Ave S4th Ave SPrivate Rd42nd Ave S30thAveS39thAv e S S 352n dLnS 343rd St 27thPl SS 347th Pl 1 1 thPlS S 347th St S 367th Pl S 338 t h S tPriv a t eRd18thPlS12thAveSS 376th St S372ndW ay S 3 5 5th St S 364th St S 366th St S 344th StPrivateRd S 365th St SW 332ndPlS 364th St34th Ave S20thAveSMiltonR d S S 349th St 28th Ave S9thAveSS 344th St Mil i t aryRdSMilitary Rd SWeyerhaeuserWaySS 37 5 t h StS 333rd St20th Ave SS 352nd St 1st Ave SPeasleyCanyonWaySS 373rd St S 356th St S 336th St 1st Wa y SS 360th St16th Ave SS 348th St 18 99 161 5 5 SF I-5SF I-5 SF Enchanted Parkway (Design Option) SF Enchanted Parkway (Design Option) SF EnchantedParkway 99 xrpa.sseccA_dezirotomnoN\sseccA_dezirotomnoN\spaM_aerA_noitatS\scoDpaM\SIG\scvS99\2 esahP ELDT 030-0081-455\gnireenignERDH-0081\stneilC\stcejorP\OSP\:U :htaP 1202/11/2 :etaDTacoma Dome Link Extension South Federal Way Figure 1 Source: WSDOT, Sound Transit, King County, Pierce County, City of Tacoma, Mapbox, OpenStreetMap N 0 ½1¼Miles PRELIMINARY DRAFT - SUBJECT TO REVISIONS Project cost $Low Med High $$ $$$ Project type Bike Only Ped Only Bike and Ped Station and alignment alternative Project Name Description Criteria Rating Key to Rating Lower Performing Higher PerformingNOYES Station access project Street/path Intersection/ crossing ProximityConnectionsMissing LinksFacility ConditionsBarriersCollision historyFacility ComfortUnderserved PopulationsY/N Y/N Y/N Y/N SF 17 Construct separated bicycle lanes $$$ SF 7 Provide pedestrian safety improvements $SF 8 Provide pedestrian safety improvements $ SF 6 Construct multiuse path through Hylebos Wetlands $$ SF 18 Construct sidewalks and bicycle lanes $$ MARCH 2021 SF 10 Complete sidewalk gaps $$ SF 13 Complete sidewalk gaps $$ SF 11 Complete sidewalk gaps $$ SF 9 Construct stair connection $ SF 16 Construct separated bicycle lanes with landscape buer $$ SF 1 Bicycle safety and signal improvements for pedestrians $$ SF 14 Complete sidewalk gaps $$ SF 15 Construct bicycle lanes and connect to Interurban Trail $$$ SF 12 Complete sidewalk gaps $$ SF 4 Bicycle safety, sidewalk and signal improvements $$ SF 5 Construct nonmotorized crossing of I-5 $$$ SF 3 Bicycle safety and signal improvements for pedestrians $ SF 2 Bicycle safety, sidewalk and signal improvements $$ Page 27 of 74 S 302ND ST 16TH AV SS 303RD STS 303RD ST 14TH AV S13TH AVS 16TH AV S16TH AV SS 304TH ST S 302ND ST PACIFIC HWY SPACIFIC HWY SS 304TH STS 304TH ST 13 T HAVSS 305TH PL First BaptistChurch Federal WayHigh School RS9.6 RM1800 RS9.6 BC RM3600 RM1800RM2400BC BC RS5.0 BC RS9.6 RS9.6RS9.6 RM3600 BCBC BC PO WetlandRating: I WetlandRating: I City of Federal Way 2022Site Specific Requestsfor Comprehensive Plan andZoning Designation Changes This map is accompanied by no warranties, and is simply a graphic representation.!Existing DesignationsComprehensive Plan: Professional Office (PO)Zoning: Professional Office (PO)!Requested DesignationsComprehensive Plan: Community Business (BC)Zoning: Community Business (BC) Rivera Pr operty Exhibit #2 Legend Site Specific Request Buildings Streets Streams (City Survey) Wetlands (1998 City Survey) Zoning Boundary* Note: An asterix (*) next to a zoning designation indicates the property isgoverned by a development agreement. R:\erike\cd\Projects\SSR Complan\2022\Maps\ssr2_2022.mxd 0 500250 Feet´ Page 28 of 74 S 302ND ST 16TH AV SS 303RD STS 303RD ST 14TH AV S13TH AVS 16TH AV S16TH AV SS 304TH ST S 302ND ST PACIFIC HWY SPACIFIC HWY SS 304TH STS 304TH ST 13 T HAVSS 305TH PL First BaptistChurch Federal WayHigh School RS9.6 RM1800 RS9.6 BC RM3600 RM1800RM2400BC BC RS5.0 BC RS9.6 RS9.6RS9.6 RM3600 BCBC BC PO WetlandRating: I WetlandRating: I City of Federal Way 2022Site Specific Requestsfor Comprehensive Plan andZoning Designation Changes 0 500250 Feet´ This map is accompanied by no warranties, and is simply a graphic representation.!Existing DesignationsComprehensive Plan: Professional Office (PO)Zoning: Professional Office (PO)!Requested DesignationsComprehensive Plan: Community Business (BC)Zoning: Community Business (BC) Rivera Pr operty Exhibit #2 Legend Site Specific Request Streams (City Survey) Wetlands (1998 City Survey) Zoning Boundary* Note: An asterix (*) next to a zoning designation indicates the property isgoverned by a development agreement. R:\erike\cd\Projects\SSR Complan\2022\Maps\ssr2_2022_aerial.mxd Page 29 of 74 8" CONC8" CONC12" CONC 0253000220 1439 0253000215 1447 0253000210 1455 0253000205 1463 0253000200 1471 0521049183 30323 0521049202 30324 0521049204 30324 2500000000 30317 0521049118 30331 0521049203 30330 0421049237 30318 0421049040 30333 0921049036 30405 0821049001 31031 12"12"12"6"8"16"8"16" 12"6"12"16"6"12"8"16"16"12"S 304TH ST 16TH AVE S15TH CT S0 10050 Feet NOTE: Lakehaven Water and Sewer District neither warrants nor guarantees the accuracy of any facility information provided. Facility locations and conditions are subject to field verification. Rivera Complan Amendment & Rezone 21-104065-UP p12/9/21 BIA Page 30 of 74 Federal Way City Center Access Project – Proposed Solution 1 Community Outreach Summary Prepared for: Community Outreach Summary May – October 2019 Proposed Solution Prepared by: Page 31 of 74 Federal Way City Center Access Project – Proposed Solution 2 Community Outreach Summary Contents Project overview ............................................................................................................................ 4 Project background ................................................................................................................... 4 Report summary ........................................................................................................................ 4 Approach ................................................................................................................................... 5 By the numbers ......................................................................................................................... 5 Key themes ............................................................................................................................... 5 Traffic congestion .................................................................................................................. 5 Interchange modification recommendations .......................................................................... 6 Local impacts ......................................................................................................................... 6 Construction and property acquisition ................................................................................... 6 Multi-modal options and safety .............................................................................................. 6 Project coordination ............................................................................................................... 6 Open space and environmental impacts ............................................................................... 6 Conclusion ................................................................................................................................. 6 Stakeholder summary ................................................................................................................... 7 Outreach methods ..................................................................................................................... 7 Tabling events ....................................................................................................................... 7 Emails .................................................................................................................................... 7 Flyer distribution .................................................................................................................... 7 Key findings ............................................................................................................................... 8 General .................................................................................................................................. 8 S 324th Street interchange solution ....................................................................................... 8 Local street improvements ..................................................................................................... 8 Stakeholder interviews .............................................................................................................. 9 Stakeholder briefings ................................................................................................................. 9 Environmental justice briefings ................................................................................................ 10 Key findings ......................................................................................................................... 10 EJ briefing summary ............................................................................................................ 11 Conclusion ............................................................................................................................... 12 Open house summary ................................................................................................................. 13 Outreach methods ................................................................................................................... 13 Direct email .......................................................................................................................... 13 Print media ........................................................................................................................... 14 Page 32 of 74 Federal Way City Center Access Project – Proposed Solution 3 Community Outreach Summary Direct mail ............................................................................................................................ 14 Flyer distribution .................................................................................................................. 15 Social media ........................................................................................................................ 15 Telephone hotline ................................................................................................................ 15 Online and in-person open house key findings ....................................................................... 15 Nonmotorized access and mobility ...................................................................................... 16 Proposed intersection controls ............................................................................................ 16 Local impacts ....................................................................................................................... 16 Next steps ................................................................................................................................... 17 APPENDICES ............................................................................................................................. 18 Appendix 1: Stakeholder outreach materials ....................................................................... 19 Appendix 2: Open house outreach materials ....................................................................... 22 Appendix 3: Online open house ......................................................................................... 28 Page 33 of 74 Federal Way City Center Access Project – Proposed Solution 4 Community Outreach Summary Project overview The City of Federal Way relaunched its City Center Access Project in 2017 to address increasing congestion in the City Center and surrounding areas. In 2018 and 2019, the City evaluated ways to reduce congestion in the City Center and make it easier for people to travel into, out of and around the City Center. The City evaluated solutions in the area of the S 320th Street corridor between SR 99 (Pacific Highway) and Military Road S with the goal of improving quality of life and economic vitality for the City Center. After evaluating improvements to local streets, the project team concluded they need to change access to the City Center from I-5 to achieve the project’s goals. The project team is now refining a proposed solution at S 324th Street, selecting an option from a wider range of possible solutions we identified earlier in the project. Community outreach and continuous traffic modeling is helping the project team fine tune a solution to present to City Council for approval in late 2019. Project background The Federal Way City Center is comprised of both the City Center Core, an urban center/regional growth center, and the City Center Frame, which is a mixed-use zone that surrounds and supports the core. Together, they complement each other to create a “downtown” area as outlined in the City’s Comprehensive Plan. The City Center is bounded by I- 5 to the east, S 312th Street to the north, 11th Place S to the south, and 13th Avenue S to the west. The project team analyzed past, current, and future traffic trends, expected needs for residents, commuters, and businesses in the area. The project team also evaluated the environmental impacts that are associated with: • Improving nonmotorized mobility access. • Increasing safety and efficiency. • Improving and enhancing transit operations. • Coordinating with other local transit projects. • Improving travel around, rather than through, the City Center core. • Improving access to and from I-5. This evaluation process is identified in the City of Federal Way 6-Year Transportation Improvement Plan (TIP) as an environmental documentation study. The City used the study to identify plans to modify access at S 320th Street and S 324th Street along I-5, and other local infrastructure improvement needs. Report summary From May to October 2019, the project team held a series of community outreach events including tabling at community festivals, hosting briefings for project neighbors, businesses and organizations serving environmental justice populations, stakeholder interviews, and an online and in-person open house. The project team incorporated the feedback gathered from these events into their evaluation of solutions to reduce congestion in the City Center. Page 34 of 74 Federal Way City Center Access Project – Proposed Solution 5 Community Outreach Summary This report summarizes the City’s community outreach efforts and feedback we received from local residents, businesses, and other key stakeholders. Approach Project team members used various outreach methods to inform the public and invite participation to help narrow down possible solutions. The project team used outreach methods to target both narrow and broad audiences, based on specific community interests, issues or known concerns. Community members communicated with the project team in-person at events, online and over the phone. By the numbers Date Attendees Open houses In-person open house Oct. 10, 2019 38 Online open house Oct. 1-14, 2019 434 Stakeholder briefings Project area businesses May 21, 2019 2 Project area neighbors May 14 & 20, 2019 35 Belmor Park Aug. 20, 2019 110 Federal Way Chamber of Commerce Oct. 8, 2019 8 Stakeholder interviews Target stakeholders July 24 - Oct 10, 2019 6 Environmental Justice (EJ) Briefings Community Connections Roundtable July 2, 2019 15 Sea Mar Community Health Centers Sept. 20, 2019 2 Build the Bridge (BTB) Oct. 1, 2019 5 Multi-Service Center (MSC) Oct. 15, 2019 40 Social media City of Federal Way Facebook Oct. 3, 2019 2,040* Sound Transit Facebook Oct. 3, 2019 32,229* Total 34,958 *Number of Facebook followers on the page Key themes • Traffic congestion • Interchange modification recommendations • Local impacts • Multimodal options and safety • Project coordination • Open space and environmental impacts Traffic congestion Residents and local business representatives shared that they are experiencing more congestion entering and leaving the City Center. Participants shared concerns about traffic backing up onto local surface streets and problems with current infrastructure. Most participants agreed that congestion in the City Center, and Federal Way, is a growing concern the City should address. Page 35 of 74 Federal Way City Center Access Project – Proposed Solution 6 Community Outreach Summary Interchange modification recommendations Most individuals did not oppose changing the S 324th Street interchange. They generally understood why the City is pursuing this option. A majority of commenters supported building roundabouts to access S 324th Street from I-5, but suggested the City educate people on how to use roundabouts safely. Most participants were unfamiliar or knew little about diverging diamond interchanges so either did not provide feedback or did not think it was a good idea. Local impacts Most participants did not oppose local improvements at S 320th and S 324th streets. However, several participants expressed concern about losing parking at the park and ride near the future Sound Transit light rail station, and potential roadway improvements near Steel Lake Park. Participants at the neighborhood briefings in May shared significant concerns about local street improvements impacting the rural neighborhood character east of I-5 at S 312th Street and 32nd Avenue S. Construction and property acquisition Several neighborhood briefing attendees shared concerns about construction, including property acquisition and project funding. Business representatives and some residents were concerned businesses will face an economic burden because already underperforming shopping centers in the area will have less business during the construction from major transit projects. Multimodal options and safety Many commenters supported the City creating pathways for people walking and biking, and better access to transit. Participants supported pedestrian bridges to separate people walking from vehicle traffic. Participants would like to see more sidewalks within the City Center on both sides of the road, and longer crosswalk times for people walking and biking across major roads. Project coordination Many participants urged the City to coordinate with other major transit projects, such as the Federal Way/Tacoma Dome Link Extension project, to reduce impact and disruption to the community. Participants were concerned building these projects at the same time could increase congestion and lead to longer commute times. Other participants expressed concern about potential impacts to their homes and the relocation process. Open space and environmental impacts Many participants feared possible solutions would compromise green space and parks and said preserving these spaces is a priority. These participants do not oppose the project so long as construction of roads remains outside of parks or recreational spaces such as golf courses. Many participants expressed concern about potential impacts to the environment, including wetlands, natural water sources, and trees. Community members encourage the City to preserve these resources. Conclusion The community members we engaged during this process generally support the modifying the S 324th Street interchange to help ease congestion into, out of, and around the City Center. Participants wanted to stay informed and understand how the City plans to implement the solution. As the project progresses into design and environmental review, the City will continue to engage the community and share information. Page 36 of 74 Federal Way City Center Access Project – Proposed Solution 7 Community Outreach Summary Stakeholder summary The City of Federal Way conducted community outreach in spring and summer 2019 to evaluate possible solutions. Our goal was to understand community sentiments about the interchange modification solutions and local roadway improvements that would change the way people enter and exit the City Center from I-5. The project team collected community feedback through the following activities: • Targeted neighborhood briefings in the project area • A briefing for City Center businesses • An in-person and online open house open to the public • Briefings to service providers targeting environmental justice communities • Interviews with stakeholders previously engaged in 2018 Outreach methods The project team announced these activities using the following methods: • Tabling events • Door-to-door outreach • Emails to project listserv Stakeholder outreach by the numbers Total Tabling event contacts 124 Emails 315 Door-to-door outreach – businesses 284 Door-to-door outreach – residences 253 Total 976 Tabling events The project team hosted information tables at two major events in Federal Way: The Red White and Blues Festival on July 4 and the Summer Sounds Music Festival on Aug. 20. The project team provided fact sheets in English, Spanish, and Korean as well as display boards featuring the proposed solutions. Visitors to the project booth won prizes by spinning a wheel and left contact information to receive project updates. Emails The project team emailed updates to community members to share the latest project information and promote outreach events. Emails included a brief description about the solutions, the evaluation criteria, public outreach recaps, and opportunities for community members to provide input. Flyer distribution On May 16 and May 17, 2019, project staff visited 273 businesses in downtown Federal Way to invite business owners or their representatives to a briefing on Tuesday, May 21, 2019. They spoke with managers and employees at businesses at the Gateway Center, The Commons Mall, the Celebration Center, Pavilion Centre, Pavilion Centre II and businesses along 23rd Avenue S, Pacific Highway, S 316th Street, and S 320th Street about the project. Page 37 of 74 Federal Way City Center Access Project – Proposed Solution 8 Community Outreach Summary Project staff gave each business invitations to the briefing. We engaged people at most businesses in conversations about the project. Many of the managers and employees were unaware of project and agreed traffic in the City Center is a growing concern. Key findings The City of Federal Way interviewed six commercial property owners and business leaders and participated in four briefings with residents and businesses from May through Oct. 2019. Most participants did not oppose the City’s proposed interchange modification at S 324th Street and agreed congestion in the City Center is growing and disruptive. General • Participants take alternate routes to avoid S 320th Street • Participants were concerned about the potential changing traffic patterns which may divert traffic into their neighborhoods • Participants were worried the solutions may increase commute times • Participants suggested more proactive communications from the City through more frequent email updates, social media event reminders or reader board signs S 324th Street interchange solution • Participants generally agreed this is a reasonable solution • Stakeholders agreed a couplet along S 320th and S 324th streets west of I-5 negatively impacts businesses Local street improvements • Participants appreciated the east to west connection created by expanding S 324th Street to Weyerhauser Way S • Participants shared concerns about potential impacts to the natural environment including the removal of trees and potential damage to pipelines • Some stakeholders were concerned that HOV lanes will not be effective and may make it harder for travelers to access businesses along S 320th Street Business groups Number of businesses The Commons 72 Pavilions Center 23 Pavilions Center II 27 Celebration Center 35 Gateway Center 21 Hwy 99 to Reichbauer Way; 316th and 320th (49), Reichbauer Way and 23rd Avenue S Ave; S 316th Street and S 320th Street (33), 23rd Ave and I5 (13) 95 Total 273 Page 38 of 74 Federal Way City Center Access Project – Proposed Solution 9 Community Outreach Summary Stakeholder interviews The project team interviewed six commercial property owners and business representatives during July, August, and October 2019. We have previously engaged with these stakeholders and followed up with them to share our proposed solution. We will consider their input as we finalize the proposed solution. These stakeholders shared their experience of heavy traffic within the City Center and agreed that solutions that will ease congestion to help people get around the area are necessary. Name Organization Interview date Audience/Property Represented Blaine Burnett The Hynes Group July 24, 2019 Belmor Park Lindy Goodling Harsch Investment Properties July 31, 2019 Celebration Centre, Pavilions Centre II, and SeaTac Village (manage only) Dana Ostenson Industrial Realty Group Aug. 12, 2019 The Greenline (Former Weyerhaeuser Campus), East Campus Tech Center Rich Schokley Federal Way Chamber of Commerce and Highline College Aug. 15, 2019 Federal Way Chamber current and future businesses and college students Daryl Reichstein Rosen Properties Aug. 15, 2019 Hillside Shopping Center, Fountain Plaza Loretta Messick MJR Development Oct. 10, 2019 Federal Way Center, Heron Building, Talon Building The majority of commercial property owners and business participants we spoke to agreed the City needs to ease congestion within the City Center. Participants also said the City needs to understand traffic impacts related to the future light rail station and temporary impacts during construction. A participant also commented the City needs to remain aware of how changes in the way people move around the city may affect residents in nearby communities by creating longer commute times, adding more traffic to residential streets, and affecting safety for people walking and biking. Half of the stakeholders suggested the City research how other nearby cities, including Seattle, Renton, and Bellevue, are addressing congestion. Participants also wanted more sidewalks, bike paths and access to public transit. Stakeholder briefings The City hosted seven business and community briefings about the City Center Access project during May, August, September, and October 2019. The City invited neighborhood leaders and property owners via email and distributed flyers door-to-door. The project team also invited Chamber of Commerce members to a briefing via the Chamber’s newsletter. About 190 community members attended the five briefings. Page 39 of 74 Federal Way City Center Access Project – Proposed Solution 10 Community Outreach Summary Business Briefing Date Location Attendees Project area businesses May 21, 2019 Federal Way City Council Chambers 2 Federal Way Chamber of Commerce Oct 8, 2019 Federal Way Chamber of Commerce 8 South King Fire and Rescue Oct 8, 2019 South King Fire and Rescue 10 Project area bankers Sep 27, 2019 Federal Way PAEC 10 Project area business owners Sep 26, 2019 Federal Way PAEC 15 Community Briefing Date Location Attendees Project area neighbors May 14 & 20, 2019 Federal Way City Council Chambers 35 Belmor Park Aug 20, 2019 Belmor Park Clubhouse 110 Total 190 Many attendees wanted the City to create better east to west connections and support a new interchange at S 324th Street. Attendees supported local improvements as long as those improvements do not make it harder for residents to get to surrounding neighborhoods. Attendees asked about how the City is funding design and construction and if funding requires voter approval. In addition, all meeting attendees encouraged the City to coordinate with Sound Transit and expressed concern about how construction could affect their homes and businesses. Although most attendees considered an interchange at S 324th Street a viable option, some were confused about the project’s purpose. Many viewed the City Center as a pathway for people to travel home and not necessarily a destination for shopping. The connection between placing an interchange at S 324th Street and reducing congestion in the City Center core did not connect for some attendees since many do not spend time in that area. A few attendees asked about ways to connect with City staff to voice future questions or concerns. Many attendees also asked for more frequent communication from the project team especially related to local street improvements and work impacting surrounding neighborhoods. Environmental justice briefings The project team conducted four environmental justice (EJ) briefings in 2019 to a total of 22 attendees. Project team members briefed attendees about the possible interchange modifications and local street improvements, collected feedback to inform the evaluation, and discussed the project timeline and opportunities for public involvement moving forward. Key findings • Concerns about displacing vulnerable community members as a result of the project. • Concerns about mobility for older adults and those living with disabilities in the City Center core. Page 40 of 74 Federal Way City Center Access Project – Proposed Solution 11 Community Outreach Summary • General support for the project and interest in the potential options for the proposed solution (e.g. diverging diamond v. roundabouts, pedestrian and bicycle improvements, etc.). • Concerns about emergency service access to the roads in the couplet alternative. • Questions and concerns about project funding and approval process. • Questions about a lack of an interchange modification at S 288th Street, especially since high levels of congestion are present in that area. • Questions and concerns about access to jobs and resources and if any aspects of the proposed solutions will negatively impact these things. • Question about the impact the construction of Sound Transit’s future light rail station and the proposed interchange modifications will have on traffic moving through the City Center EJ briefing summary The City Center Access Project team presented to four organizations and coalitions as part of its environmental justice work. Environmental Justice Briefing Date Attendees Location Korean Quarterly June 27, 2019 40 Federal Way City Hall Federal Way Community Connections Roundtable July 2, 2019 15 Federal Way Public Library Sea Mar Community Health Centers Sept. 20, 2019 2 Sea Mar Federal Way Medical Clinic Build the Bridge (BTB) Oct. 1, 2019 5 Federal Way City Hall in the Hylebos room, 2nd floor Multi-Service Center (MSC) Oct. 15, 2019 40 Multi-Service Center, Federal Way Total 102 The organizations represented at these briefings include: • CHI Franciscan • Multi-Service Center • Puget Sound Educational Service District • City of Federal Way Department of Community Development • SoCo Culture • Federal Way Library (King County Library System) • Federal Way Public Schools • Korean Women’s Association Page 41 of 74 Federal Way City Center Access Project – Proposed Solution 12 Community Outreach Summary • Urban League of Seattle Project team members presented the project purpose and need, including accommodating planned growth in the City Center, addressing more traffic delays and backups onto I-5, improving access to emergency services, and planning for long-term needs. They reviewed how they evaluated local street improvements and discussed their conclusion that the City needs to modify the interchange to reduce congestion on S 320th Street. The City Center project team explained why the City is no longer considering the S 312th Street interchange option and other interchanges. In September, the presentation included the interchange modification at S 324th Street the team identified as its proposed solution, and in October, included a walkthrough of the online open house. Visuals relating to the possible interchange modifications and bicycle and pedestrian connections under evaluation were in all briefings. All briefings concluded with the presenter discussing next steps and noting how the project team is encouraging broader community participation with an online and in-person open house. Attendees asked questions, voiced concerns, and shared comments as a full group throughout the briefings. Conclusion About 298 people gave feedback on the City’s solutions through stakeholder interviews and community and business briefings. Overall, participants do not oppose the project or the proposed solution, however some attendees expressed concern about a lack of public input. Concerns often included issues related to Sound Transit’s plans for the area and coordination with the City Center Access Project. Others voiced concerns about impact to mobility and transit access for those from vulnerable populations, such as the elderly and disabled. Many attendees and interview participants wish to receive more frequent updates from the City. Page 42 of 74 Federal Way City Center Access Project – Proposed Solution 13 Community Outreach Summary Open house summary The project team hosted an online and in-person open house in October to share the proposed solution at S 324th Street and gather public feedback on the solution and three major design questions: • Ramp configurations • Intersection controls • Nonmotorized connections The project team received 41 written comments and interacted with 452 participants. Date Channels Comments Attendees Oct. 1-14 Online open house 35 434 Oct. 10 In-person open house 10 38 Oct. 3 Social media -- 2,040* Oct. 1 Postcards -- 24,244** Sept. 20, 27 Print media circulation -- 29,167*** Total: 25 55,923 *Number of Facebook followers **Households receiving postcard ***Households receiving Federal Way Mirror Outreach methods The City used diverse tactics to reach a broad group of community members, including • Email updates • Newspaper notice • Postcards • Flyers to community gathering places • Social media • Telephone hotline Email On October 1, the project team emailed 280 members of the project’s listserv to announce the selection of the proposed solution as well as the launch of the online open house. The project listserv includes: • Briefing attendees • Community members, organizations, and business representatives who opted-in to the Project’s contact listserv • Commercial property owners and managers who participated in stakeholder interviews The email provided a brief description of the proposed solution, the dates for the online and in- person open house, and invited readers to attend both to leave final comments for consideration The study team mailed 24,244 postcards to invite the community to an in-person open house on Oct.10, 2019. Page 43 of 74 Federal Way City Center Access Project – Proposed Solution 14 Community Outreach Summary before the project team presents the final proposed solution to City Council on November 5. The email closed with the phone number for the project hotline where members of the community can call and provide feedback over the phone. Print media The City posted a legal notice in the Federal Way Mirror newspaper advertising both online and in person open houses. The notice highlighted project partners, as well as the importance of collecting input for further evaluations before presenting a final proposed solution to City Council on November 5. The newspaper ran the legal notice in physical publications on September 20 and 27. Direct mail The City mailed postcard invitations to 24,244 addresses which arrived in their mailboxes on October 1. The postcard included a brief project overview, a link to the online open house, and details about the in-person open house. The City mailed the postcard to addresses from the northern boundary of S 272nd Street south to SR 18 to ensure people who frequently use those interchanges could provide feedback. To increase the input from residents and business owners who use S 320th Street and other City Center roads, the City included addresses west to First Avenue and east to the Auburn city limits. The project team mailed postcards to addresses in the project area, including addresses west to First Avenue and east to the Auburn city limits. The Federal Way Mirror ran a public notice on Sept. 20 and 27 notifying community members of the Oct. 10 in-person open house. Page 44 of 74 Federal Way City Center Access Project – Proposed Solution 15 Community Outreach Summary Flyer distribution On October 1, we distributed flyers to 28 Federal Way community gathering places, including churches, the Federal Way Transit Center, Federal Way Senior Center, Korean Women’s Association, and nine grocery stores frequented by residents in the project area. We gave someone at each location a flyer or poster and talked with them, sharing project information, describing ways for interested community members to participate, and answering questions. We reached out to places where limited English proficient populations gather, such as ethnic grocery stores or churches offering services in non-English languages. We distributed flyers, encouraged them to attend the open house and assured those who spoke Spanish and/or Korean that interpreters would be available at the open house. The study team also posted multiple flyers at the Federal Way Transit Center near busy bus stops. Social media The City created an event on Facebook announcing the launch of the City Center Access project online open house as well as the date of the in-person open house. The posting included start and end dates and times for both and invited the public to visit and leave comments based on the information shared by the project team. Telephone hotline The City of Federal Way created a project hotline for the City Center Access project to address in a timely manner the public’s questions, comments, and concerns. The hotline is available, after callers select their language, in Spanish, Korean, and English. No exchanges occurred between callers and project team staff checking the hotline. Online open house Online and in-person open house key findings The below key themes emerged from the comments we received from the online and in- person open houses. We asked participants for their thoughts on the proposed solution, whether it addressed their previous input, their preference for intersection controls, and thoughts on nonmotorized elements of the solution. Feedback mirrored these questions closely, centering around nonmotorized access and mobility and proposed intersection modifications. Key themes include: • Improving access and mobility for people walking and biking. On October 3, the City of Federal Way posted a Facebook event advertising City Center Access open house. The online open house collected comments from Oct. 1-14, 2019. Page 45 of 74 Federal Way City Center Access Project – Proposed Solution 16 Community Outreach Summary • Proposed intersection modifications are acceptable. • Concerns about additional weave in hybrid option. • Concerns about local impacts. • Traffic congestion is a growing concern. Mobility for nonmotorized users Online participants commented they are experiencing growing congestion entering and leaving the City Center. Most participants urged the City to develop a plan to improve connections for people walking and riding bicycles. Some participants suggested adding more bike lanes or a shared use path for pedestrians and bicyclists. One participant asked the City to add sidewalks on both sides of arterial roadways leading to and from the City Center–the lack of sidewalks forces people to walk across the street illegally. Some residents expressed that bike lanes are hazardous for drivers. One participant commented that roundabouts would improve pedestrian safety. One participant expressed concern about safely getting to the Commons shopping center from Belmor Park. Proposed intersection controls Most participants supported adding roundabouts to ease congestion but asked the City to provide information about how to use roundabouts. The diverging diamond design option concerned several participants. They shared that “weaving” and “cutting across” lanes would confuse drivers and could lead to collisions. Some participants suggested coordinating traffic signals to reduce current congestion. Other participants noted concern about traffic on S 320th Street and potential road widening that may affect power towers in the area. Local impacts Several participants gave feedback about impacts to local roadways. They expressed concerns about losing parking at the park and ride near the future Sound Transit light rail station, and potential roadway improvements near Steel Lake Park. One participant shared concern that street improvements would increase traffic near a park at S 312th Street and 32nd Avenue. Another participant suggested moving the project area away from a senior living center at Belmor Park, to limit noise, traffic and access impacts to residents. Live, work, and play map Responding to an interactive map, most participants indicated they live inside the Federal Way city limits. Generally, visitors noted their workplaces along the I-5 corridor Open house attendees placed stickers on a map outlining the City of Federal Way to mark where they live (green), work (orange), and play (yellow). Open house attendees provided feedback on boards stationed around the open house. Page 46 of 74 Federal Way City Center Access Project – Proposed Solution 17 Community Outreach Summary and mostly outside the City Center. Residents also shared that they recreate along the waterfront, at parks in Federal Way, and within the City Center. Next steps The project team will review all comments and use them to help refine the proposed solution before presenting it to City Council on Nov. 5 for a vote in late 2019. Page 47 of 74 Federal Way City Center Access Project – Proposed Solution 18 Community Outreach Summary APPENDICES Page 48 of 74 Federal Way City Center Access Project – Proposed Solution 19 Community Outreach Summary Appendix 1: Stakeholder outreach materials Appendix 1.1: Flyer for neighborhood briefings on May 14 and May 20, 2019 Page 49 of 74 Federal Way City Center Access Project – Proposed Solution 20 Community Outreach Summary Appendix 1.2: Email to attendees from May neighborhood briefings. Page 50 of 74 Federal Way City Center Access Project – Proposed Solution 21 Community Outreach Summary Appendix 1.3: Flyer for Belmor Park residents advertising a City Center Access project team lead neighborhood briefing Page 51 of 74 Federal Way City Center Access Project – Proposed Solution 22 Community Outreach Summary Appendix 2: Open house outreach materials Appendix 2.1: Email to project listserv announcing launch of online open house Page 52 of 74 Federal Way City Center Access Project – Proposed Solution 23 Community Outreach Summary Appendix 2.2: Front and back view of open house postcards delivered to residences in a specified radius within the Federal Way City Center area, delivered Oct. 1. Page 53 of 74 Federal Way City Center Access Project – Proposed Solution 24 Community Outreach Summary Appendix 2.3: Open house postcard distribution map Page 54 of 74 Federal Way City Center Access Project – Proposed Solution 25 Community Outreach Summary Appendix 2.4: City of Federal Way Facebook event for City Center Access open house Page 55 of 74 Federal Way City Center Access Project – Proposed Solution 26 Community Outreach Summary Appendix 2.5: Public notice for City Center Access online and in-person open house in the Federal Way Mirror newspaper Page 56 of 74 Federal Way City Center Access Project – Proposed Solution 27 Community Outreach Summary Appendix 2.6: Flyer for City Center Access online and in-person open house given to businesses in the area to publicly display. Page 57 of 74 Federal Way City Center Access Project – Proposed Solution 28 Community Outreach Summary Appendix 3: Online open house Page 58 of 74 Page 59 of 74 Page 60 of 74 Page 61 of 74 Page 62 of 74 PLANNING COMMISSION NOTICE OF PUBLIC HEARING 2022 City of Federal Way Proposed Comprehensive Plan Amendments Rivera Property Comprehensive Plan Amendment and Rezone Public Works Comprehensive Plan Amendments for Non-Motorized Transportation Improvements (Non-Project Actions) File Number’s: 22-100262-UP; 21-104065-UP; 22-101175-SE The City of Federal Way’s Planning Commission will conduct a public hearing on Wednesday, June 15, 2022, at 6:00 p.m. in the Council Chambers (City Hall, 33325 8th Avenue South, Federal Way, WA 98063-9718). The commission will hear testimony and provide a recommendation to the City Council’s Land Use/Transportation Committee (LUTC) and City Council on a proposed comprehensive plan amendment and rezone of Rivera Property, located at 1600 S 304th Street, parcel #052104-9204, and the Public Works Non-Motorized Transportation Improvements at various locations across the city as follows: 1. File #21-104065-UP, Richard Rivera Property – Request for a comprehensive plan amendment and rezone of parcel no. 052104-9204 (1.26- acre site), located at 1600 South 304th Street, from Professional Office (PO) to Community Business (BC). 2. File #22-100262-UP, a request from the City of Federal Way Public Works for the following non-motorized transportation projects: • City Center: Extend BPA Trail from 11th PL/13th Ave S along north side of S. 324th St to 23rd Ave S and along west side of 23rd Ave S from S. 324th to S. 320th Street. See attached exhibit “A” “B” and “C” for plans and cross section. This project is included under City’s CIP (Project #16). • Federal Way Transit Center Pedestrian Connection: Construct sidewalk to preserve pedestrian access between large blocks with in City Center as shown in exhibit “D”. This project is included under City’s CIP (Project # 29). • North Fork West Hylebos Trail: Construct Trail within Spring Valley along North Fork of West Hylebos Creek as shown in Exhibit “E”. Typical cross section in nonenvironmental sensitive areas (Asphalt Concrete) and environmentally sensitive areas (Board Walk) are shown in Exhibit “F” and Exhibit “G”, respectively. This project is included under City’s CIP (Project # 42) Page 63 of 74 • Non-Motorized Facilities Around South Federal Way Transit Station adding the following non-motorized capital projects: Project Description 1 S. 359th: SR 99 to SR 161: Construct sidewalk and bike lanes on both sides of the street 2 16th Avenue S: S. 359th to S. 364th Way: Construct sidewalk and bike lanes on both sides of the street 3 S. 359th and SR 161: Construct staircase and ADA accessible ramp 4 I-5 Crossing: S. 359th to 20th Avenue S: Construct non-motorized crossing 5 20th Avenue S and S. 360th: SR 161 to 32nd Avenue S: Construct sidewalk and bike lanes on both sides of the street 6 Milton Road S: SR 161 to S 369th St: Construct sidewalk and bike lanes on both sides of the street 7 SR 161: Milton Rd to S 380th St: Construct sidewalk and bike lanes on both sides of the street 8 SR 161: S. 352nd to S.359th: Construct separated bicycle lanes with landscape buffer 9 S. 356th St: SR 99 to 1st Avenue S: Construct sidewalk and bike lanes on both sides of the street The official file is available for public review through the Community Development Department https://www.cityoffederalway.com/page/land-use-notices. A staff report will be available on Tuesday June 7, 2022. Interested persons may submit written comments to the Planning Commission prior to the hearing, present written comments to the commission during the hearing, and/or may appear at the hearing to provide verbal testimony. For additional information please contact Associate Planner Natalie Kamieniecki, 253-835-2638, or natalie.kamieniecki@cityoffederalway.com Published in the Federal Way Mirror on May 27, 2022. Page 64 of 74 Page 65 of 74 Page 66 of 74 Page 67 of 74 Page 68 of 74 Page 69 of 74 Page 70 of 74 Page 71 of 74 Page 72 of 74 Page 73 of 74 Page 74 of 74