20-102490-Landscape Modification-2020-10-13-V3October 13, 2020
Stacey Welsh, Principal Planner
City of Federal Way
Department of Community Development
33325 – 8th Avenue South
Federal Way, WA 98003
RE: Request for Modification to Landscape Standards
Pape Kenworth Northwest
Files #20-102489-UP, 20-102490-SE and 20-102492-AD
City of Federal Way, King County, Washington
Our Job No. 20833
Dear Stacey:
This modification request has been prepared in response to the review comment provided in the
Community Development, Planning Division section of the letter dated September 15, 2020 to justify not
locating trees within a portion of Type I landscape buffer that lies within an existing power line easement.
Section 19.125.050 states that 'Type I landscaping is intended to provide a solid sight barrier to totally
separate incompatible land uses. This landscaping is typically found between residential and incompatible
nonresidential land uses, such as industrial.'
The Pape Kenworth N.W. project is a truck maintenance facility with areas for office, showroom and parts
warehouse and a separate structure to be used as a body shop. An existing transmission line easement
overlaps a portion of the southern part of the property. As required by easement directives, no trees are
allowed within the easement to avoid future conflict with the power lines.
The following are justifications for approval of this modification as required by the city.
a) "The proposed modification represents a superior result than that which could be achieved by
strictly following the requirements of this title;"
Response: A 15-foot width Type I landscape buffer is required along 32nd Avenue South
due to the property to the south being residential. For all the areas outside of the
transmission line easement, additional trees are shown to supplement the required trees.
Within the easement, shrubs (Pacific Wax Myrtle) are shown. The Pacific Wax Myrtle is a
native evergreen shrub that will reach 15 to 20 feet in height at maturity, providing similar
solid screening as evergreen trees would provide.
b) "The proposed modification complies with the stated purpose of this title and any applicable
subsections of this title;"
Response: The quantity of plant material within the transmission line easement and for the
remaining portions along 32nd Avenue South meet the intent of the Type I landscape buffer,
which is to provide 100 percent screening within 3 years of installation.
c) "If the proposed modification will not violate any City of Federal Way Revised Codes or
ordinances. In particular, a modification shall not be a substitute for any zoning variance;"
Response: All proposed plant material within the Type I landscape buffer, in addition to the
plant material for the rest of the site, will meet City of Federal Way requirements for
landscape installation, plant sizes, and soil and mulch depth. No other modifications or
variances related to landscaping are proposed.
Stacey Welsh, Principal Planner
City of Federal Way
Department of Community Development -2- October13, 2020
d) "Where applicable, the proposed modification would result in an increased retention of
significant trees and/or naturally occurring vegetation on the site; and”
Response: Not applicable.
e) "The proposed modification also satisfies the criteria listed in subsection (2), (3), (4), (5), or
(6) of this section;"
Response: The width of the required landscape buffer is not proposed to be reduced or
averaged. The full 15-foot width is provided although trees will not be located in the
transmission line easement.
We believe that this modification should be granted for this project, since it is demonstrated that the use
of medium-height native evergreen shrubs, the Pacific Wax Myrtle, would provide similar solid screening
as would evergreen trees. Please review at your earliest convenience and feel free to contact me with
any questions or need additional information. Thank you.
Sincerely,
Jeff M. Varley
Senior Landscape Architect, RLA
JMV/jd
20833c.008.doc
cc: Quinn Closson, Pape Group
Bart Dickson, Cobalt Development
Howard Kimura, H.G. Kimura Architect, PLLC
Daniel K. Balmelli, Barghausen Consulting Engineers, Inc.
Ali Sadr, Barghausen Consulting Engineers, Inc.
Ben Eldridge, Barghausen Consulting Engineers, Inc.