Pape Findings
Pape Kenworth Northwest 20-102489-00-UP / Doc. I.D. 81408
Findings for Project Approval Page 1 of 15
EXHIBIT A
FINDINGS FOR PROJECT APPROVAL
Federal Way Revised Code (FWRC) Chapter 19.65, “Process III Project Approval”
& FWRC 19.145.440(5), “Buffer Averaging”
PAPE KENWORTH NORTHWEST
File #20-102489-UP
The Director of Community Development hereby makes the following findings according to content
requirements of the Process III written decision as outlined in Federal Way Revised Code (FWRC) 19.65.100(4)
and FWRC 19.145.440(5). These findings are based on the review of city documents, recommendations from
the city’s wetland consultant, Landau, and items submitted by the applicant received July 20, 2020, and
resubmittals received October 15, 2020, December 8, 2020, and January 28, 2021.
1. Proposal – Pape Kenworth Northwest proposes the construction of a 64,077 square-foot truck maintenance
building with areas for office, showroom, and parts warehouse; a 15,667 square-foot maintenance body shop
building; 117 vehicle parking stalls; outdoor storage area for trucks and trailers on-site in association with
maintenance/repairs to the truck cab; and associated site improvements, including utility extensions and
frontage improvements along 32nd Avenue South and the north side of South 320th Street. Existing
residential structures are to be removed. Site development includes wetland buffer averaging.
2. Site Condition – The site is approximately 20 acres, comprised of parcels 092104-9028, -9139, -9140, -9160, -
9187, -9206, & -9316, which were annexed into the city in 2020, and are located at the northeast corner of
I-5 and South 320th Street. Portions of the site contain steep slopes and it is heavily vegetated in the
western portion with a Category III wetland with an 80-foot buffer. The property has been vacated and any
remaining residential structures are to be removed. The property located to the north is vacant, Interstate 5
is to the west, South 320th Street is to the south with commercial development beyond, and a largely
unimproved 32nd Avenue South is located to the east with residential development beyond. A major feature
of the site is the BPA transmission towers and power lines that cut across the property.
3. Boundary Line Adjustment – The subject property consists of seven parcels. The application materials indicate
a boundary line adjustment (BLA) will be pursued to reduce the number of lots. Many zoning and building
code requirements are associated with the location of property lines. A condition of approval will require
the BLA to be recorded before the issuance of a building permit.
4. Zoning and Comprehensive Plan – Zoning for the subject site is Community Business (BC). Truck sales,
service, and repair is a permitted use in the BC zone subject to the provisions of FWRC 19.220.030,
“Vehicle and equipment sales, service, repair, rental – Self-service storage facilities.” The Federal Way
Comprehensive Plan (FWCP) designation for the subject site is Community Business.
5. Review Process – The project requires review under Process III, Project Approval. Also, the subject property
contains an on-site wetland and associated buffer. To accommodate retaining walls due to the slope on the
property wetland buffer averaging is proposed. According to FWRC 19.145.440(5), “Buffer Averaging,” the
city reviews and decides upon buffer averaging using Process III. The Community Development Director
makes a written decision on the application based on criteria listed under FWRC 19.145.440(5)(a-d) and
19.65.100. Appeals of the director’s decision are conducted by the city’s Hearing Examiner.
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6. State Environmental Policy Act (SEPA) – The proposed improvements exceed categorical exemption levels according
to Washington Administrative Code (WAC) 197-11-800. The city issued a Mitigated Determination of Nonsignificance
(MDNS) on April 30, 2021 (city file 20-102490-SE). The threshold determination comment period ended May 14,
2021, and the appeal period ended June 4, 2021.
7. Public Notice – According to Process III regulations, a Notice of Application (NOA) was published in the
Federal Way Mirror, posted on the subject property, posted on the city website, and mailed to the persons
receiving the property tax statements for all property within 300 feet of each boundary of the subject
property on August 21, 2020. According to SEPA regulations, a notice of the MDNS was published in
the Federal Way Mirror, posted on the subject property, posted on the city website, mailed to all owners of
real property as shown in the records of the county assessor located within 300 feet of the site, emailed to
agencies, and sent to people who provided comments in response to the NOA, on April 30, 2021.
8. Public Comments – Six comment letters were received on the application; the comments relate to roads,
traffic, and access. Three comment letters were received on the MDNS; the comments relate to
transportation, WSDOT’s culvert replacement, and environmental impacts. Many of these topics are
addressed below in subsequent sections of this report.
The city has carefully and thoroughly considered each of the comments received as part of the city’s
review of the application. All of these comments will be included within the administrative record for this
proposal and will accompany the application throughout the city’s project review process. A copy of the
decision will be mailed to all interested parties.
9. Bulk & Dimensional Requirements – The proposed buildings are subject to the following required yards, lot
coverage, height, and parking standards outlined in FWRC Use Zone Chart 19.220.030.
Required Yards – Are 20 feet in the front; 0 feet on the sides; and 0 feet on the rear. Outdoor parking and
service areas may not be closer than 10 feet to any property line (Note #4). Except for principal sales
lots, outdoor storage areas shall be located to the rear and/or side(s) of the principally permitted structure
(Note #7). As shown on the site plan, all setbacks are satisfied.
Per Note #6, “auto body repair and/or painting may be permitted only if building layout and design
mitigates impact of dust, fumes, noise, glare, odor, or any other discharge on neighboring uses and natural
systems; protects neighboring uses and natural systems from accidental spillage, leakage, or discharge of
hazardous material and pollutants; and all operations, service, painting and repair must be conducted
within enclosed buildings.” Building layout and site design include setbacks, landscaping, stormwater
treatment, and architectural treatments designed to mitigate the items noted above. In addition, a
condition of approval shall be applied regarding service, painting, and repair.
Lot Coverage – None required, the buildable area is determined by other site development requirements.
Height – The maximum height allowed for this use in the BC zone is 30 feet above average building
elevation (AABE) when located within 100 feet of a residential zone (located on parcels to the east of 32nd
Avenue South); otherwise, 35-55 feet AABE. If approved by the director the height of a structure may
exceed 35 feet AABE to a maximum of 55 feet AABE if all of the criteria in FWRC 19.220.030(1)(a)-(d)
are met.
Building A is over 100 feet away from a residential zone. The applicant provided a written request
documenting compliance with FWRC 19.220.030(1)(a)-(d) for Building A to exceed the 35-foot maximum
height limit to be 44 feet in height at its tallest point. The request is approved.
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A portion of Building B is within 100 feet of a residential zone; therefore, that portion of Building B cannot
exceed 30 feet AABE. The submitted elevation drawing shows a portion of Building B at 33 feet in height
within 100 feet of a residential zone. That portion of the building has a flat roof, and per FWRC 19.05.080,
the “height of structure” means the vertical distance measured from the average building elevation around
the building segment to the highest point of a flat roof. The building permit plan set will need to reflect a
code-compliant building; this shall be made a condition of approval.
Parking – According to FWRC 19.220.030, one parking space for each 300 square feet of gross floor area
(gfa) is required. Additionally, per FWRC 19.125.170(5), the outdoor truck storage areas are to be factored
in when calculating the gfa of the development. The additional gfa must be counted in the required
parking calculation. The amount of required parking by code is 336 spaces (64,077 + 15,667 + 20,944 =
100,688/300 = 336).
The number of parking spaces required by code may be reduced when a parking study is provided
following FWRC 19.130.080(2). The applicant submitted a parking study requesting a reduction to provide
117 spaces. Based on the September 30, 2020, Pape Kenworth Northwest Updated Parking Assessment,
prepared by TENW, the proposed 117 parking stalls are based on parking provided at four existing Pape
facilities, including two in Washington State. An average parking ratio of 1.16 parking stalls/1,000 square
feet was derived. According to this assessment the proposal would need 117 spaces (100,688 x 1.16 =
116,798/1,000 = 117). Parking space calculations are rounded upwards per FWRC 19.130.040. The staff
has reviewed the parking assessment and concurs that a parking reduction is acceptable and the site will be
required to provide 117 spaces.
10. Landscaping – Per FWRC 19.125.060(6), Type I landscaping 15 feet in width shall be provided along the
perimeter of the property abutting a residential zoning district. This applies to the property line along 32nd
Avenue South. Additionally, Type III landscaping five feet in width shall be provided along all other
property lines. The western portion of the property is heavily vegetated and existing vegetation will be
retained to satisfy the perimeter landscaping requirement in that area. The submitted landscaping plan
demonstrates compliance with these requirements.
According to FWRC 19.125.100(1)(c), due to special circumstances of the site that involve compliance
with special easements, the applicant submitted a landscape modification request. A portion of the
property south of Building A is encumbered with a Bonneville Power Administration (BPA) easement.
Permitted vegetation within this power line easement is limited and trees are not allowed. As a result, the
request is to not provide trees within the portion of the Type 1 landscaping area along the eastern property
line within the BPA easement.
The applicant provided a narrative to demonstrate compliance with the modification criteria in FWRC
19.125.100(2). The modification proposes that within the easement, shrubs will be used; Pacific Wax
Myrtle is a native evergreen shrub that can reach 15 to 20 feet in height at maturity, providing a similar
solid screening as evergreen trees would provide. The landscaping modification is granted.
Interior parking lot landscaping in the amount of 22 square feet per parking stall is required per FWRC
19.125.070(2)(a)(i)(B). For the 117 parking stalls provided, 3,608 square feet of landscaping is required (117
x 22 = 2,574). The applicant proposed 2,824 square feet of interior parking lot landscaping, exceeding the
minimum requirement as detailed on the site plan.
Per FWRC 19.125.040(24) “All loading areas shall be fully screened from public right-of-way or
nonindustrial/manufacturing uses with Type I landscaping.” The elevation drawing and site plan show
truck bays on the west and east sides of Building A and north and south sides of Building B. Native
vegetation is being retained along the western portion of the site. Screening with Type I landscaping is
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planned to be provided along the eastern property line. The elevation of the site above South 320th Street
to the south of the site, and the distance of Building B from the nonindustrial/manufacturing uses to the
north and location of Building A precludes the need for further Type I screening for this purpose.
11. Tree Retention/Replacement – According to FWRC 19.120.130, compliance with the city’s tree density
requirements in the BC zone (20 tree units per acre) requires 400 tree units on the subject property’s 20
acres. For reference, the property will be permitted to deduct acreage for the wetland and right-of-way
dedication, which will require less than 400 tree units for the property. The applicant submitted the
required tree retention plan and proposes to remove trees in conjunction with the site development while
retaining the western portion of the property intact, including more than 400 tree units remaining on site.
Additionally, replacement plantings of tree units will be installed in conjunction with the required
landscaping exceeding the minimum required tree units. This requirement is satisfied.
12. Forest Practices – A Forest Practices Class IV-General Application is required, as more than 5,000 board
feet of merchantable timber will be harvested from the property in conjunction with the development
activity. Per FWRC 19.120.200(1)(a), “A Class IV – General application shall be approved based on an
approved clearing and grading plan and tree and vegetation retention plan and prior to conducting forest
practices on the project site.” A Forest Practices Application has been submitted.
13. Tacoma Smelter Plume – The former Asarco copper smelter in Tacoma caused widespread soil
contamination with lead and arsenic in parts of King, Pierce, Kitsap, and Thurston counties. This 1,000
square mile area is known as the Tacoma Smelter Plume. The state cleanup level for arsenic is 20 parts
per million (ppm). According to the Department of Ecology mapping checked in 2021, the subject
property is located in the Tacoma Smelter Plume detect area containing under 20 ppm predicted arsenic
concentration; therefore, testing of site soils is not applicable.
14. Wetland & Buffer Averaging – The site contains a Category III wetland with a habitat score of five, which
requires an 80-foot buffer per FWRC 19.145.420(2). No streams or other fish and wildlife habitat
conservation areas were observed on the subject property. In addition, a five-foot building setback is
required from the edge of the buffer per FWRC 19.145.160. The applicant submitted a Revised Wetland
and Fish & Wildlife Habitat Assessment & Wetland Averaging Plan, prepared by Soundview Consultants
(SVC), May 22, 2020. A review of the original report occurred before the submittal of the Use Process III
application, under city file 19-105322-AD, to establish the wetland rating and buffer. The original buffer
averaging plan was reviewed under file 20-100968-AD.
The city’s wetland consultant, Landau, peer-reviewed the above-mentioned report as well as reports
prepared under the prior two Administrative Decision (AD) reviews noted above. Landau agreed with
the wetland rating and buffer width. Landau prepared a technical memorandum on August 21, 2020, in
which they concluded that “the May 2020 technical memorandum satisfies the criteria for critical areas
reports provided in FWRC 19.145.080 and 19.145.410(2), and the criteria for wetland buffer averaging
provided in FWRC 19.145.440(5).”
To accommodate site development given the site constraints including the BPA easement and topography,
the applicant proposes an intrusion within the wetland buffer to construct retaining walls. According to
FWRC 19.145.440(5), “Buffer Averaging,” the director has determined the proposed wetland buffer
averaging request meets the criteria contained in FWRC 19.145.440(5), as analyzed below:
a) The total area of the buffer after averaging is equal to the area required without averaging;
Response: A total of 951 square feet of buffer area will be reduced near the northwest portion of the
site, and a total of 1,422 square feet of buffer area will be added to a portion of the buffer area south
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of the area proposed for reduction. The proposed wetland buffer averaging will result in a net gain in
the wetland buffer area of 471 square feet. Criteria satisfied.
b) The buffer is increased adjacent to the higher functioning area of habitat or more sensitive
portion of the wetland and decreased adjacent to the lower functioning or less sensitive portion;
Response: The buffer is increased adjacent to the higher functioning area of habitat with native vegetation
and lack of human-caused disturbance, and decreased adjacent to the lower functioning area with
invasive vegetation and fill material. Criteria satisfied.
c) The buffer at its narrowest point is not reduced to less than 75 percent of the required width; and
Response: The proposed buffer at its narrowest point is 68 feet, which is more than 75 percent (60 feet)
of the required standard buffer width of 80 feet. Criteria satisfied.
d) Unless authorized in writing by a consenting neighboring property owner, the averaging will
remain on the subject property.
Response: The proposed buffer averaging will remain on the subject property. Criteria satisfied.
Per FWRC 19.145.170 and 19.145.180(2) and (3)(c), a notice on the title, critical area fencing, and signage
are required. The proposed site security fencing should suffice in-lieu of critical areas fencing to keep site
users of the developed portion of the property away from critical areas and their buffers. These items
shall be made conditions of approval.
15. Geologically Hazardous Areas –The applicant submitted a geotechnical report prepared by GeoResources,
LLC, October 8, 2020. The western portion of the property contains an erosion hazard area.
GeoResources documented the erosion hazard area and noted that it can be mitigated by installing
conventional construction best management practices (BMPs) before starting construction. Per FWRC
19.145.240(1), erosion hazard areas do not contain standard buffers. There are criteria within FWRC
19.145.240(3) for proposed improvements within an erosion hazard area. The geotechnical report did not
indicate any compliance concerns with FWRC 19.145.240(3).
GeoResources documented a landslide hazard area in the western portion of the site; slopes steeper than
40 percent with 10 feet or more of vertical relief. GeoResources conducted a slope stability analysis and
concluded that “Based on the results of our slope stability analyses, the existing slope conditions meet or
exceed the minimum factors of safety required by the City of Federal Way.” Per FWRC 19.145.230,
landslide hazard areas have a standard buffer of 50 feet. The buffer and setback may be reduced or
improvements may be located in a landslide hazard area when a qualified professional demonstrates to
the director’s satisfaction that the improvements will not lead to or create any increased slide hazard, or
be at risk of damage by the landslide hazard. GeoResources concluded that:
“Based on our review of the provided preliminary site plan, we understand that no structures
are currently proposed within 50 feet of the top of this steep slope. However, the base of the
proposed detention pond embankment is approximately 20 to 30 feet from the top of the
steep slope. We evaluated the global stability of the existing and proposed site conditions
along cross section A-A’, as described above, where the distance between the proposed
detention pond and steep slope is narrowest. Based on our stability analyses, it is our opinion
that the proposed detention pond will not create an increased slide hazard and therefore the
standard 50 foot buffer required by the City of Federal Way can be reduced per FWRC
19.145.230(4). We recommend the buffer be reduced to 15 feet to correspond to the
required IBC setback as described below,”
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Additionally,
“Based on our stability analyses, it is our opinion that the proposed detention pond will not
adversely impact the nearby steep slope/ landslide hazard area or be adversely affected by
the proximity to the nearby steep slope/ landslide hazard area, provided the reduced buffer
from the hazard area described above is preserved and maintained.”
The site plan and civil sheets submitted with the building permit will need to show the five-foot
geologically hazardous area (GHA) critical areas setback per FWRC 19.145.160. This information must
be shown on the plans per FWRC 19.145.150(4). This is in addition to the 15-foot GHA buffer. In
addition, a portion of the security fence is proposed within the geologically hazardous area, and the 15-
foot buffer and will need to be moved to be outside of these areas. Fences are permitted within the five-
foot critical areas setback per FWRC 19.145.160(3). A portion of the stormwater pond and surrounding
area will also need to be adjusted to be outside the 15-foot GHA buffer and the additional five-foot
GHA critical areas setback. These items will be conditions of approval.
The landslide hazard area buffer reduction is approved. According to FWRC 19.145.250(2), the following
shall also be made conditions of approval:
• The recommendations of the geotechnical report shall be followed.
• A geotechnical engineer or engineering geologist shall be present on-site during all
development activities within the erosion and landslide hazard areas to establish proper
methods, techniques, and adherence to plan drawings.
• Trees, shrubs, and groundcover are retained except where necessary for approved
development activities on the subject property.
• Before building permit issuance, provide a letter by the geotechnical engineer or engineering
geologist stating that they have reviewed the project plan drawings and in their opinion, the
plans and specifications meet the intent of the geotechnical report.
16. Clearing & Grading – Grading of the site includes approximately 69,000 cubic yards of cut and 93,000
cubic yards of fill. Site development will be required to follow the recommendations provided in the
October 8, 2020, geotechnical report, prepared by GeoEngineers. Clearing/grading activities will also be
reviewed for consistency with applicable standards outlined in Chapter 19.120 FWRC as part of
construction permitting.
17. Retaining Walls & Fencing – The proposed grading and drainage plan and October 8, 2020, geotechnical
report, prepared by GeoEngineers, include details of retaining walls, which are subject to FWRC
19.120.120. According to the geotechnical report;
“Retaining walls are proposed to support fills along the western and northwest portion of the
project area and provide up to 41 feet of grade separation. Per the FWRC 19.120.120, walls for
commercial developments are limited to six feet in height, and rockeries and retaining walls
visible from a public right-of-way shall be composed of rock, brick, or other textured/patterned
wall styles as approved by the City. We understand you are requesting a deviation to construct
retaining walls up to about 14 feet in height. The proposed configuration provides up to 41 feet
of grade separation and consists of three tiered walls with individual maximum heights of 10 to
14 feet that are horizontally separated by terraces sloping at up to 3H:1V.”
To accommodate the site development, existing steep slopes in the area, and to minimize impacts to the
Category III wetland buffer, retaining walls are proposed. The grading plan shows a maximum height of
nine feet, while the geotechnical report discussed 10-14 feet; the final design will be reviewed at the time
of the building permit. The applicant provided a request for modification per FWRC Chapter 19.120.050.
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The modification request notes that the site has steep slopes and sensitive areas. The project site
proposed grades are flat as required for truck maneuvering and access, which requires the use of retaining
walls. To minimize disturbance to sensitive areas and maximize the use of the property, retaining walls
over six feet in height are needed. Using standard six-foot-high retaining walls will require more area of
clearing and impact to the sensitive area buffer. The proposed modification to use retaining walls over six
feet high will result in fewer impacts than meeting the standard, per FWRC 19.120.050(1)(b).
According to FWRC 19.120.050, “Modifications,” the director has determined the proposed modification
request meets the criteria contained in FWRC 19.120.050(1)(b) and is approved.
The entire developed portion of the property is proposed to be enclosed with a six-foot security fence
with gates located at the two site driveways following FWRC 19.125.160(5).
18. Community Design Guidelines – As detailed below, the project embodies site and building design principles
consistent with the requirements of the Community Design Guidelines (FWRC Chapter 19.115).
a. Crime Prevention Through Environmental Design (CPTED)
i. A completed CPTED checklist was submitted and reviewed by the Federal Way Police
Department. There were no concerns or comments on the proposal.
ii. The proposal meets many of the CPTED guidelines, such as having no blind corners in
pathways and the parking lot areas, both building entrances are visible from the street, entrances
are identified, the entire developed portion of the site will be enclosed with a chain-link security
fence with gated access, and incorporation of lighting throughout the site.
b. Site Design – FWRC 19.115.050
i. Pedestrian areas and amenities are incorporated in the overall site design; overall design continuity
is achieved through the use of similar elements throughout the project; and access control is
provided by fencing the entire developed portion of the site.
ii. Required landscaping is provided, the parking aisles have loop access, and driveways are visible
from the right-of-way.
iii. Primary entrances to buildings are visible or recognizable from the right-of-way. Pedestrian
pathways from rights-of-way to primary entrances, from parking lots to primary entrances, and
pedestrian areas, are accessible and delineated.
iv. Pedestrian pathways and pedestrian areas shall be delineated by separate paved routes using a
variation in paved texture and color and protected from abutting vehicle circulation areas with
landscaping. Approved methods of delineation include: stone, brick, or granite pavers; exposed
aggregate; or stamped and colored concrete. Paint striping on asphalt as a method of delineation
is not encouraged. A condition of approval shall ensure this is completed on-site.
v. Bike racks, on-site furniture, and trash receptacles will be located adjacent to the buildings or at
the building entry plaza areas.
vi. All outdoor trash enclosure areas will be accessible and screened appropriately.
vii. According to the application materials, the location of transformers is still to be determined. A
condition approval shall require that site utilities, including transformers and fire standpipes, shall
not be the dominant element of the front landscape area. When these must be located in the
front yard, they shall be either undergrounded or screened by walls and/or Type I landscaping,
and shall not obstruct views of tenant common spaces, public open spaces, monument signs,
and/or driveways.
viii. Lights are placed to illuminate portions of the site via building and pole lights, directing sharp
cut-off lights toward to interior of the site to mitigate light spillage offsite.
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c. Building Design – FWRC 19.115.060
i. Buildings A and B each use a combination of required façade modulation, landscape screening,
canopy, and pedestrian plaza.
ii. Buildings will have window openings with metal trim, architectural overhangs/projections/
canopies/awnings, material variations such as cmu brick veneer, metal siding texture, and metal
color banding around the building to break up facades and massing, as well as landscaped plazas.
d. Building and Pedestrian Orientation – FWRC 19.115.070
i. Both building entrances are orientated to the right-of-way and incorporate plazas.
ii. While the pedestrian plazas do not meet all of the criteria due to their locations, lack of
pedestrian paths connecting them to the right-of-way, and the fact that the site will be secured
with fencing and gates, they are still valued as a site amenity and provide a function to employees
and customers.
iii. The two buildings are not linked by a pedestrian path due to distance, site grades, and desire by
the owner to not encourage pedestrian traffic within a high vehicular use site with large trucks.
e. District Guidelines – FWRC 19.115.090(1)(a)-(f)
i. Surface parking is located behind and to the side of the building. No parking is adjacent to the
right-of-way.
ii. Entrance facades face the right-of-way and incorporate transparent glass windows and other
methods of articulation.
iii. Plazas with appropriate amenities are located at both building entrances.
iv. The entire developed portion of the site is proposed to be fenced. The submittal indicates
compliance with fence design standards.
19. Outdoor Activities – The project includes outdoor storage of truck trailers associated with the repair/
maintenance of the trucks. This area is shown on the site plan near the west side of Building A. This does
not involve the area near the southern property line proposed for outdoor display of vehicles for sale or
lease. Outdoor storage on a commercial property must comply with FWRC 19.125.170.
a. The outdoor storage areas:
i. Comply with required buffers for the primary use and required yards adjoining the residential use
or zone.
ii. Are screened by Building A and Type 1 perimeter landscaping along 32nd Avenue South, and
grade change and distance to South 320th Street.
iii. The six-foot height limitation is not necessary as the proposed location should render items not visually
obtrusive and are not anticipated to detract from the aesthetic quality of the overall development.
iv. Location is not anticipated to inhibit safe vehicular and pedestrian movement to, from, and on
the subject property.
v. Have been used in calculating the gross floor area of the development and has been factored into
the amount of required parking and associated parking analysis.
vi. Will be located in an improved area of the site.
20. Rooftop Mechanical Equipment –Per FWRC 19.110.070, rooftop mechanical equipment and similar
appurtenances that extend above the roofline are required to be surrounded by a solid sight-obscuring
screen that is integrated into the architecture of the building and obscures the view of the appurtenances
from adjacent streets and properties. A condition of approval shall require this to be shown on the
building permit plan set.
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21. Garbage/Recycling – Design and space requirements meet the criteria outlined in FWRC 19.125.150. The
garbage and recycling facilities are not visible from abutting residential properties or rights-of-way and are
screened by enclosures and landscaping.
22. Lighting – The proposal includes outdoor lighting. Per FWRC 19.105.030(3), “The applicant shall select,
place and direct light sources both directable and nondirectable so that glare produced by any light
source, to the maximum extent possible, does not extend to adjacent properties or to the right-of-way.”
The applicant submitted a lighting plan. The proposed maximum off-site light spill level is 4.5 horizontal
footcandles (fc). For reference, an average fc rating for an active building entrance is two fc. Considering
the projected lighting levels and distance to adjacent uses, glare problems are not anticipated.
23. Additional Permitting – Additional permitting, such as engineering review and building permits, are required for
site development. An engineering permit has been submitted (city file 21-101029-EN). It is the applicant’s
responsibility to identify and obtain all required state, federal, or other agency permits as may be required.
24. Transportation Concurrency– As a component of the Use Process III application, projects undergo
transportation concurrency analysis according to the state’s Growth Management Act (GMA); goals and
policies of the FWCP; and FWRC Chapter 19.90, “Transportation Concurrency Management.” The city’s
Traffic Division reviewed the concurrency application and determined all intersections impacted by one
or more weekday evening peak hour trips will meet the city’s Level of Service standards with
programmed improvements. A Capacity Reserve Certificate was issued on February 3, 2021, for the
development of 80,000 square feet of new truck sales, maintenance, office, and body shop repair
facilities. The number of new PM peak hour vehicle trips generated by the project is 69.
25. Transportation Impact Fee – A transportation impact fee is required and will be calculated based on the fee
schedule in effect at the time a building permit application is filed and must be paid before permit
issuance, per FWRC 19.100.070.
26. Access – The applicant has provided vehicular/pedestrian access and circulation consistent with the goals
and policies for transportation, as outlined in Chapter 3 of the FWCP. The subject property is served by
two vehicle access points via the extension of 32nd Avenue South.
27. Transportation Impact Analysis (TIA) – The applicant submitted a traffic study, Pape’ Kenworth Northwest -
Federal Way, WA Transportation Impact Study, TENW Transportation Engineering NorthWest, December
2, 2020, and updated January 22, 2021. The traffic study was completed to address on-site access and off-
site intersections outside of the city limits. Per the TIA, the project is estimated to generate 924 new
weekday daily trips (208 truck trips), 69 AM peak hour trips (13 truck trips), and 69 PM peak hour trips
(12 truck trips). The trip distribution in the TIA identified that the project trips will impact the I-5/South
320th Street ramp terminal intersection, 32nd Avenue South/South 316th Street, and Military Road South/
South 316th Street. These intersections were identified for further analysis by the Washington State
Department of Transportation (WSDOT) and King County.
Washington State Department of Transportation (WSDOT): The I-5 and South 320th Street ramp terminal
intersections are under WSDOT control and are subject to WSDOT’s established standards. WSDOT
requested further analysis at the ramp terminal to document existing and future operations with the
development project. However, no mitigation was requested at this time.
King County: The project trips will impact two intersections (32nd Avenue South/South 316th Street and
Military Road South/South 316th Street.), which are under King County jurisdiction. However, these two
intersections do not meet the King County Code (KCC) 14.80 “Intersection Standards” thresholds of 30-
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peak hour and 20 percent of the peak hour trips and operating at a level of service (LOS) worse than
“E.” Therefore, King County does not expect any significant adverse traffic impacts to these two
intersections and no mitigation was requested.
Thirty-Second Avenue South will be improved to the City of Federal Way standards from South 320th
Street to the north property boundary. The traffic signal at South 320th Street/32nd Avenue South will be
modified to accommodate the new north leg of the intersection and also to provide safe access to the
site. The new 32nd Avenue South road extension will connect to the existing section of 32nd Avenue
South in King County. With the new road connection, less than five project trips are expected to utilize
the new road extension during the AM and PM peak hours. However, the existing trips from the
neighborhood may be re-routed to the new road connection. King County recommended that
neighborhood traffic calming measures be considered.
To minimize neighborhood impacts north of the site and discourage any potential cut-through traffic
resulting from the new road connection, concurrent with engineering plan submittal to the City of
Federal Way, the applicant shall coordinate with King County to design and implement neighborhood
traffic calming devices. Before issuance of a Certificate of Occupancy, the agreed-upon traffic calming
devices shall be constructed per King County standards (SEPA mitigation measure).
28. Street Improvements – The applicant/owner will be expected to construct street improvements consistent
with the planned roadway cross-sections as shown in Map III-4 in Chapter III of the FWCP and Capital
Improvement Program (CIP) shown as Table III-10 (FWRC 19.135.040). The applicant is expected to
construct improvements on the following streets to the city’s planned roadway cross-sections:
Thirty-Second Avenue South is a Principal Collector planned as a Type “K” street, consisting of a
44-foot street with curb and gutter, 6-foot planter with street trees, 8-foot sidewalks, and street lights
in a 78-foot right-of-way. Assuming a symmetrical cross-section, the applicant will be expected to
construct ¾ street improvements for approximately 300 feet north from South 320th Street and taper
to a 28-foot wide paved street with curb and gutter, 6-foot planter strips, and 8-foot sidewalk along
the remainder of the property frontage. To accommodate the improvements, an additional 39-foot
right-of-way dedication is required as measured from the street centerline. Please note, the existing
traffic signal will need to be modified to accommodate the required street improvement.
To accommodate the expected truck traffic, 32nd Avenue South must be designed
and constructed to meet the expected truck traffic load using the site. The final
review of the pavement design and truck turning path will occur in conjunction with
the final engineering plan review.
South 320th Street is a Principal Arterial planned as a Type “A” street, consisting of a 90-foot street
with curb and gutter, 6-foot planter strips with street trees, 8-foot sidewalks, and street lights in a
124-foot right-of-way. Assuming a symmetrical cross-section, half street improvements are
required as measured from the street centerline along the entire property frontage. Please note,
WSDOT approval is required for channelization impacting the state's limited access.
The applicant submitted and received approval from the Deputy Public Works Director for a right-of-
way modification request to increase driveway widths to 55 feet (file #20-102997-SM).
Truck trips generated by the project are expected to utilize the traffic signal as primary access. The
submitted truck turning templates depict trucks performing right-turn and left-turn maneuvers that would
encroach onto the opposing lane of travel even with the stop line for both lanes of the southbound
approach located further back than the standard. Given the full cut section of the north leg of the
intersection, moving the stop line back would require prohibiting the right-turn-on-red movement. This
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restriction is not desirable due to poor compliance and inefficient signal operations. The applicant has not
demonstrated the expected trucks, such as WB 40 and/or WB 67, can utilize the site safely without
encroaching into opposing traffic lanes or mounting a curb.
Before issuance of a Certificate of Occupancy, the applicant shall design and construct the South 320th
Street/32nd Avenue South intersection to accommodate the new north leg of the intersection. The
intersection shall be designed to ensure the appropriate design vehicle, such as WB40 and/or WB67, can
access the site without encroaching into opposing traffic lanes or mounting a curb. Furthermore, the
eastbound left-turn lane storage on South 320th Street shall be extended from approximately 150 feet to
225 feet to ensure left-turn queues will not block the through traffic lane. The intersection improvement
plans (traffic signal plan, channelization plan, etc.) shall be designed to meet all applicable standards and
must be reviewed and approved by the city before construction (SEPA mitigation measure).
The development is estimated to generate 924 new weekday daily trips (208 truck trips), 69 AM peak hour
trips (13 truck trips), and 69 PM peak hour trips (12 truck trips). The truck trips will be served by the
primary access via the 32nd Avenue South and South 320th Street intersection. As part of the project
development, 32nd Avenue South will be improved to a Type “K” street standard. The applicant shall
evaluate the Type “K” street pavement standards and redesign the pavement if necessary to accommodate
the expected truck traffic load using the site. The pavement design must be submitted with engineering
plans for review and approval (SEPA mitigation measure).
29. Transportation Agency Comments –WSDOT and King County Road Services Division (RSD) provided
comments to the city, which are detailed above under the Transportation Impact Analysis Section. RSD
also provided the following comment:
“To minimize impacts to the neighborhood north of the proposed development, King
County RSD recommends that all truck trips be required to access South 320th Street to/
from the south via 32nd Avenue South. We recommend that the developer be required to
provide on-site signing in combination with employee education to prohibit any truck traffic
to/from the north along 32nd Avenue South.”
Conditions of approval shall require the developer to provide on-site signage and employee education to
prohibit any truck traffic to/from the north along 32nd Avenue South.
30. Stormwater – The development will be required to meet all standards outlined in the 2016 King County
Surface Water Design Manual (KCSWDM) and the City of Federal Way addendum to that manual. A
Technical Information Report (Barghausen Engineers, October 12, 2020), which included a geotechnical
report (GeoResources, May 28, 2020), has been accepted by the city for land use approval. To meet
conservation flow control requirements, a detention pond and infiltration trenches are proposed.
Enhanced basic water quality requirements are to be met through a proprietary facility, such as a Modular
Wetland, for stormwater flowing through the detention facility. Water flowing into the infiltration
trenches will be pretreated and then pass through native soils that are expected to meet requirements for
groundwater protection. The Technical Information Report and engineering plans must be further
reviewed and approved by the Public Works Department before issuance of a building permit.
31. Water and Sewer – Lakehaven Water & Sewer District is the water and sewer, service provider. Lakehaven
issued certificates of water and sewer availability on February 28, 2020; certificates are valid for one year
from the date of issuance. Updated certificates will need to be submitted with the building permit. The
applicant will need to submit applications to Lakehaven for water and sewer service connections and
developer extension agreements.
32. South King Fire & Rescue – South King Fire & Rescue reviewed the application and has the following
comments, listed here as information and to be addressed at the building permit stage.
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a. A Certificate of Water Availability, including a hydraulic fire flow model, shall be requested from the
water district and provided at the time of the building permit application.
b. Fire hydrants shall be within 100 feet of fire department connections (FDCs) and shall be on the same
side of the road to prevent roads from being obstructed by a fire hose. Hydrant spacing along access
roads and location in relationship to buildings and sprinkler FDC shall be approved by Fire Marshal’s
Office. Fire hydrants shall be in service before and during the time of construction.
c. Fire apparatus access roads shall comply with all requirements of Fire Access Policy 10.006:
http://southkingfire.org/DocumentCenter/Home/View/24. Designated and marked fire lanes may be
required for emergency access. This may be done during the plans check process, or before the building
permit final. Requirements and marking options can be found in FWRC Title 8 at:
http://www.codepublishing.com/wa/federalway/. Fire apparatus access roads shall be installed and
made serviceable before and during the time of construction.
d. Stormwater detention vaults shall be rated for outrigger loading if they are near the building where a
ladder truck could set up during fire department operations.
e. All vehicle access gates shall comply with the Gate Policy:
http://southkingfire.org/DocumentCenter/Home/View/21.
f. A recessed fire department “Knox” brand key box shall be installed on the building near the front
entrance. Location(s) will be approved by the plan reviewer or Deputy Fire Marshal onsite.
g. An NFPA 13 fire sprinkler system is required in all buildings. An automatic fire sprinkler system shall be
installed in all occupancies where the total floor area included within the surrounding exterior walls on all
floor levels, including basements, exceeds 5,000 square feet. Firewalls shall not be considered to separate
a building to enable deletion of the required automatic fire-extinguishing system. The system demand
pressure (to the source) required in a hydraulically designed automatic fire sprinkler system shall be at
least 10 percent less than the correlative water supply curve pressure.
h. A fire alarm system is required. City code requires an automatic fire detection system in all buildings
exceeding 3,000 square feet gross floor area. The fire alarm system is required to monitor the sprinkler
system, including water flow. Provide full notification as required by NFPA 72. Complete coverage
smoke detection is not required for this project. This fire detection system shall be monitored by an
approved central and/or remote station.
33. Director’s Decision Criteria – The Director of Community Development makes a written decision on the
application based on the criteria listed under FWRC 19.65.100(2):
a. The proposal is consistent with the comprehensive plan;
i. The FWCP designation for the subject property is Community Business. The FWCP contains
the following goals and policies:
o LUG 6: 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.
The proposed business will add to the mix of uses in the BC zone available to motorists
and residents. New commercial development in that location will enhance the
community’s image.
o 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.
The proposed business accommodates auto-oriented retail use and provides a
supportive use to meet the needs of residents and businesses in the area.
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b. The proposal is consistent with all applicable provisions of the FWRC;
i. As conditioned, the proposal is consistent with the applicable zoning regulations as detailed in
this report.
c. The proposal is consistent with the public health, safety, and welfare;
i. The Community Development, Police, and Public Works Departments, along with Lakehaven
Water & Sewer District and South King Fire & Rescue, have reviewed the project for conformance
with codes designed to protect the public health, safety, and welfare. Additional details will be
reviewed at the building/engineering permit stage. The applicant’s submittal also notes that “By
removing the existing single family homes currently on-site, it will result in the removal of
vagrancy, drug use and crime that appeared to be present on-site prior to the annexation.”
d. The streets and utilities in the area of the subject property are adequate to serve the
anticipated demand from the proposal;
i. See the Transportation, Water & Sewer, Stormwater, and Conditions of Approval related
sections of this report.
e. The proposed access to the subject property is at the optimal location and configuration; and
i. Access to the site will be provided via two driveways located on 32nd Avenue South, which connects
to South 320th Street. The site has proximity to the regional road network, including Interstate 5.
Also, see the Transportation-related and Conditions of Approval sections of this report.
f. Traffic safety impacts for all modes of transportation, both on and off site, are adequately
mitigated.
i. See the Transportation-related and Conditions of Approval sections of this report.
g. It is consistent with the site design standards set forth for all zoning districts in FWRC 19.115.050;
i. See the Community Design Guidelines section of this report.
h. It is consistent with applicable supplemental guidelines set forth in FWRC 19.115.090; and
i. See the Community Design Guidelines section of this report.
i. For development applications for remodeling or expansion of an existing development, it is
consistent with those provisions of Chapter 19.115 FWRC, Community Design Guidelines,
identified by the director as being applicable.
i. This provision is not applicable as the project does not include remodeling or expansion of
existing development.
34. Conditions of Approval – The following conditions of approval are attached to the Process III decision:
1) Before issuance of any building permit the Boundary Line Adjustment shall be recorded.
2) All service, painting, and repair shall be conducted within enclosed buildings.
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3) The building permit plan set shall include revisions to the portion of Building B that is within 100
feet of a residential zone, which cannot exceed 30 feet AABE.
4) Before issuance of a Certificate of Occupancy, the security fence shown on the site plan shall be
installed. Critical areas signage shall be installed every 150 feet following FWRC 19.145.180(2).
5) Before issuance of a Certificate of Occupancy, a copy of the recorded notice on title shall be
submitted following FWRC 19.145.170.
6) The site plan and civil sheets submitted with the building permit shall show the five-foot geologically
hazardous area (GHA) critical areas setback. This is in addition to the 15-foot GHA buffer.
7) The site plan and civil sheets submitted with the building permit shall address the following: the
portion of the security fence proposed within the GHA and the 15-foot buffer shall be moved to be
outside of those areas. A portion of the stormwater pond and surrounding area shall also be adjusted
to be outside the 15-foot buffer and the 5-foot critical areas setback.
8) The recommendations of the geotechnical report shall be followed.
9) A geotechnical engineer or engineering geologist shall be present on-site during all development
activities within the erosion and landslide hazard areas to establish proper methods, techniques, and
adherence to plan drawings.
10) Trees, shrubs, and groundcover shall be retained except where necessary for approved development
activities on the subject property.
11) Before building permit issuance, the owner shall provide a letter by the geotechnical engineer or
engineering geologist stating that they have reviewed the project plan drawings and in their opinion,
the plans and specifications meet the intent of the geotechnical report.
12) Pedestrian pathways and pedestrian areas shall be delineated by separate paved routes using a
variation in paved texture and color. Approved methods of delineation include: stone, brick, or
granite pavers; exposed aggregate; or stamped and colored concrete. Paint striping on asphalt as a
method of delineation is not encouraged. These items shall be shown on the building permit plan set
and completed on-site before issuance of a Certificate of Occupancy.
13) Site utilities including transformers and fire standpipes shall not be the dominant element of the
front landscape area. If these must be located in the front yard, they shall be either undergrounded or
screened by walls and/or Type I landscaping, and shall not obstruct views of tenant common spaces,
public open spaces, monument signs, and/or driveways. These items shall be shown on the building
permit plan set and completed on-site before issuance of a Certificate of Occupancy.
14) The building permit plan set shall show that rooftop mechanical equipment and similar appurtenances
that extend above the roofline are surrounded by a solid sight-obscuring screen that is integrated into
the architecture of the building and obscures the view of the appurtenances from adjacent streets and
properties.
15) Before issuance of a Certificate of Occupancy, on-site signage shall be installed to prohibit any truck
traffic to/from the north along 32nd Avenue South.
16) Before issuance of a Certificate of Occupancy, the owner shall provide a narrative detailing the
planned employee education to prohibit any truck traffic to/from the north along 32nd Avenue South.
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17) Before issuance of a Certificate of Occupancy, the applicant shall design and construct the South
320th Street/32nd Avenue South intersection to accommodate the new north leg of the intersection.
The intersection shall be designed to ensure the appropriate design vehicle, such as WB40 and/or
WB67, can access the site without encroaching into opposing traffic lanes or mounting a curb.
Furthermore, the eastbound left-turn lane storage on South 320th Street shall be extended from
approximately 150 feet to 225 feet to ensure left-turn queues will not block the through traffic lane.
The intersection improvement plans (traffic signal plan, channelization plan, etc.) shall be designed to
meet all applicable standards and must be reviewed and approved by the city before construction
(SEPA mitigation measure).
18) The applicant shall evaluate the Type “K” pavement street standards and redesign the pavement on
32nd Avenue South to accommodate the expected truck traffic load using the site. The pavement design
must be submitted with the engineering plans for review and approval (SEPA mitigation measure).
19) The applicant shall coordinate with King County to design and implement neighborhood traffic
calming devices. Before issuance of a Certificate of Occupancy, the agreed-upon traffic calming
devices shall be constructed per King County standards (SEPA mitigation measure).
CONCLUSION – As conditioned, the proposed site plan and buffer averaging application have been
determined to be consistent with the FWCP; with all applicable provisions of the FWRC; and with the public
health, safety, and welfare. As conditioned, the streets and utilities in the area of the subject property are
adequate to serve the anticipated demand from the proposal, and the proposed access to the subject property
is at the optimal location and configuration for access. The proposed development is consistent with the
decisional criteria required under FWRC Chapter 19.65, “Process III, Project Approval” and FWRC
19.145.440(5), “Buffer Averaging.”
The proposed site plan and application enclosures have been reviewed for compliance with the FWCP,
pertinent zoning regulations, and all other applicable city regulations. Final construction drawings will be
reviewed for compliance with specific regulations, conditions of approval, and other applicable city
requirements. This decision shall not waive compliance with future City of Federal Way codes, policies, and
standards relating to this development.
Prepared by: Principal Planner Stacey Welsh Date: June 4, 2021