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20-102489-Correspondence-SEPA Resubmittal-20-100968-AD-2020-06-10-V2June 10, 2020 Stacey Welsh, Principal Planner City of Federal Way Department of Community Development 33325 – 8th Avenue South Federal Way, WA 98003 RE: Response to Technical Review Comments Pape Kenworth NW – Federal Way Northeast Corner of South 320th Street and I-5 City of Federal Way, King County, Washington Our Job No. 20833 Dear Stacey: We have revised the plans and technical documents for the above -referenced project in accordance with your comment letter dated April 24, 2020. Enclosed are the following documents for your review and approval: 1. One (1) each electronic copy Resubmittal Information Form 2. One (1) each electronic copy revised Master Land Use Application 3. One (1) each electronic copy revised Architectural Plans to include Site, Floor, Elevations, Sign and Illumination Plans 4. One (1) each electronic copy revised Community Design Guideline Narrative 5. One (1) each electronic copy revised Civil Engineering and Landscape Planting Plans 6. One (1) each electronic copy revised SEPA Checklist 7. One (1) each electronic copy revised Preliminary Technical Information Report 8. One (1) each electronic copy revised Geotechnical Engineering Report 9. One (1) each electronic copy revised Trip Generation Study 10. One (1) each electronic copy revised Parking Assessment 11. One (1) each electronic copy Soundview Consultants Response to Comments letter dated May 22, 2020 12. One (1) each electronic copy Tree Retention Exhibit 13. One (1) each electronic copy revised Wetland and Fish and Wildlife Habitat Assessment and Buffer Averaging Plan 14. One (1) each electronic copy draft Forest Practices Class IV-General Application 15. One (1) each electronic copy updated Title Report Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -2- June 10, 2020 16. One (1) each electronic copy Slope Exhibit 17. One (1) each electronic copy Truck Turn Diagram 18. One (1) each electronic copy Photometric Analysis 19. One (1) each electronic copy Draft Variance Request for Driveway Width 20. One (1) each electronic copy Draft Variance Request for Retaining Wall Height The following outline provides each of your comments in italics as written, along with a narrative response describing how each comment was addressed: Community Development – Planning Division Stacey Welsh, (253) 835-2634, stacey.welsh@cityoffederalway.com 1. General – Technical comments made about an item on one sheet or in a document ma y necessitate changes to other related sheets and documents. It is the applicant’s responsibility to determine any such necessary adjustments. Please ensure consistent information is communicated throughout the plan set and associated application materials. Response: Comment acknowledged. Use Process III 2. Master Land Use Application – Please address the following comments: a. The list of parcels has the parcel ending in -9028 listed as -9208. Response: The tax parcel number on the Master Land Use Application has been corrected. b. Under the Project Description, please describe the proposal in further detail, including the size, height, and number of buildings proposed, number of parking spaces, and include other site improvement details, utility extensions, and frontage improvements. Response: Refer to SEPA Checklist description from HGKA as this will have a comprehensive project description including the details they requested. 3. Plan Set – Please address the following comments a. On the site plan and civil sheets, show the geologically hazardous area and buffer in accordance with the geotechnical report (see page 14) and the critical areas setback per Federal Way Revised Code (FWRC) 19.145.160. Response: The geologically hazardous area and buffer as well as the critical areas setback have been added to all relevant sheets. Refer to slope exhibit showing the 15-39% and >40% slopes on separate exhibit due to the extensive area of the slopes super-imposed on the site plan. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -3- June 10, 2020 b. On the civil and landscaping sheets: i. Remove the building permit number for the Tilt project from the plan sets. Response: The incorrect permit number has been removed from all sheets. ii. The area of wetland buffer reduction is 972 square feet, not 378 square feet; correct in multiple locations. Response: The revised area of wetland buffer reduction of 951 square feet and wetland buffer addition of 1,422 square feet as shown on the site plan. c. On Sheet SP-1: i. Under the Project Phasing note, it discusses an “early grading and temporary erosion control permit”; however, there is no such application at the city. Response: This note has been removed. ii. Parking stall calculations need to be rounded upwards in accordance with FWRC 19.130.040; adjust the site plan accordingly if needed. Response: Parking calculations have been rounded up. Parking count has changed and we added more passenger stalls to the site. On the site plan and report by TENW, we show both the City of Federal Way parking requirement and proposed passenger stalls based on a parking stud y by TENW for 4 similar Pape facilities. iii. Pedestrian connections between the parking stalls on the east and west sides of the site and Building A should be installed for functionality and safety purposes. The pathways should comply with FWRC 19.115.050(4)(a) and (4)(b). Response: Pedestrian connections have been made between the parking stalls on the east and west sides of the site and building A by means of a 5’ colored concrete walk with scores at 5’ oc to show change of material between the asphalt surrounding. iv. Regarding retaining walls see FWRC 19.120.120 and address the following: 1. Label the heights of the retaining walls on the site plan Response: Retaining wall heights are labeled on the site plan . 2. Provide a retaining wall detail in the submittal. Response: A typical MSE retaining wall detail is included as Figure 9 in the revised Geotechnical Engineering Report. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -4- June 10, 2020 3. Compliance with FWRC 19.120.120 needs to be demonstrated; including height, architectural details, landscaping, etc. In addition, coordinate any necessary details on the civil and landscape plan sets. Response: A modification request to exceed the maximum wall height of 6 feet has been included within this submittal. 4. Retaining walls are limited to six feet in height. The process for a modification request to that standard is detailed in FWRC 19.120.050. The modification request should accompany the project submittal. Staff will be looking for explanations from your civil and geotechnical engineers on this matter. Response: A modification request to exceed the maximum wall height of 6 feet has been included within this submittal. d. On the civil sheets: i. On Sheet C4, update the construction sequence to remove the reference to the stream and restoration and enhancement activities, as there is no stream on site and restoration and enhancement activities are not proposed as part of this project. Response: The construction sequence on sheet C4 has been revised as requested. ii. On Sheet C5, the wetland buffer addition area needs to be fenced of f like the rest of the wetland buffer. Clarify what type of fencing is proposed at the wetland buffer edge. Response: The fence has been relocated to include the wetland buffer addition area and the fence has been called as a 6-foot high chain link fence. iii. Provide a minimum of two cross sections of the site, drawn to scale, depicting the existing and proposed grade and any proposed rockeries and/or retaining walls in accordance with the Use Process III Submittal Requirements checklist. Response: Additional sections have been added to the revised civil plans. e. On the landscaping sheets: i. No landscaping is shown along the southern property line along 320 th, where five feet of Type III is required per FWRC 19.125.060(6)(a). Response: 5-foot width Type III landscaping is shown. ii. Fifteen feet of Type I landscaping is required along 32 nd. If trees are not allowed within the BPA easement, what is being done to meet or exceed the requirement, such as a wider buffer, increased use of shrubs, etc.? Due to the landscaping limitations imposed by the BPA easement, a landscaping modification needs to be requested in accordance with FWRC 19.125.100. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -5- June 10, 2020 Response: Additional landscaping is shown in the BPA easement area where trees are not allowed. These are comprised of native evergreen shrubs…Tall Oregon Grape, Pacific Wax Myrtle, and Evergreen Huckleberry. They will grow tall enough to provide screening up to 5-foot to 6-foot height iii. Ensure parking lot landscaping islands are six feet in width as required by FWRC 19.125.070(3). Response: Base site plan revised all landscaped islands to minimum 6-foot. iv. Sheet L-2 shows existing vegetation to be retained, which does not seem possible in areas where retaining walls are going to be installed, and in areas within the clearing limits shown on the civil plans, please clarify. Response: Hydroseed areas have been adjusted. v. On Sheet L-3: 1. Update the parking lot landscaping summary to be consistent with the number of parking spaces proposed on the site plan. Response: Parking lot landscaping has been updated. 2. For the cumulative total area of parking lot landscaping, the maximum amount of area that can be counted per island is 305 square feet per FWRC 19.125.070(3). It is ok to have islands larger in size tha n 305 square feet; however, only 305 square feet of any one island can count towards the cumulative total area of parking lot landscaping. Response: Acknowledged. Updated landscaping calculations have been provided within the revised landscape plans. 4. Elevations – Please address the following comment: a. Note the height of the south elevation main entrance, which appears to be taller than the rest of the building. Response: Height of south elevation is now shown. 5. Design Guidelines – Please address the following comments: a. The CPTED checklist was reviewed by Lindsey Sperry, Crime Prevention Analyst for the Federal Way Police Department, and she does not have any concerns at this time. Response: Comment acknowledged. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -6- June 10, 2020 b. Regarding the submitted design narrative: i. The narrative describes installation of fencing between six to eight feet in height. Fences over six feet in height are not permitted within the 20-foot front yard setback per FWRC 19.125.160(5). Provide a fence and gate detail so that compliance with FWRC 19.115.090(1)(f) and FWRC 19.125.120 -140 and 160 can be verified. Response: Fencing note on site plan has been called out as a black 6’ height chainlink fence. We will change the text in the narratives. See SP-4 for fencing /gate detail indicating a black chainlink fence with black powder -coated posts/caps. ii. On page 3 of the narrative, clarify content provided in Items (g) and (5) as landscaping is not proposed on the west and south sides of the site. Existing vegetation will be retained to the west. While not shown on the plans, landscaping is required on the south side. Response: Landscaping 5-foot in width will be provided on south and west sides of the site. c. Regarding façade modulation and screening options pursuant to FWRC 19.115.060(2), please review and address comments (i-iv) below. Given the intended function of the buildings, meeting FWRC 19.115.060(2) presents challenges. Options include providing a visual analysis that demonstrates that certain facades are not visible from either the right-of-way (I-5, 320th, 32nd) or a residential use or zone, if that proves to be the case. Another option is to look at the west and east facades of Building A as one building with a façade modulation built into it by the way the buildings are connected; however, the length of the façade modulation exceeds the maximum width of 60 feet (FWRC 19.115.060[2][a]). Another possibility is to provide alternate means of achieving compliance with FWRC 19.115.060(2) pursuant to FWRC 19.115.020. 1. The Building A north elevation of the office/showroom/parts building scales differently between the full-size site plan and the enlarged set. On Sheet SP- 1 the sections are almost 70 feet in length, while the same sections scaled on Sheet SP-3 are under 60 feet. Check the scales and confirm correct information is shown on the sheets. If the requirement to meet FW RC 19.115.060(2) is triggered, please address it. Response: Overall Site Plan corrected to 1”=40’ scale along with graphic scale. Building modulation provided < 60’ along north, east and west sides of building A and special consideration for south elevat ion requested as combination of Plazas, special alternate “eyebrow” design and canopy overhangs are being proposed, see revised design guidelines for descriptions. Building B, façade modulation provided as needed, with same special design element with com bination plazas and canopy proposed, see design guideline for description. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -7- June 10, 2020 2. The same situation occurs on the Building A south elevation of the office/showroom/parts building. The building length scales out at 260 feet in length, not 212 feet as listed in the design narrative. Check the scales and adjust documents as necessary. Response: See response to item 1 above. ii. Landscaping (FWRC 19.115.060[2][b]): 1. With the addition of trees (to be consistent with Type II landscaping per FWRC 19.125.050[2]), landscaping is acceptable as shown on the east elevation of the parts warehouse of Building A. Label the area as Type II on the landscaping plans. Response: The building has been flipped so the parts warehouse now faces west and the office/showroom face east toward 32nd Ave S to provide more transparency from 32nd Ave S. into the showroom with glass at the SE Corner. Type II landscape has been labeled along the west side fronting the parts warehouse, refer to the site plan and landscape plan. 2. On Building B: a. With the addition of trees (to be consistent with Type II landscaping per FWRC 19.125.050[2]), landscaping is acceptable as shown on the west elevation. Label the area as Type II on the landscaping plans. Response: Type II landscaping has been labeled on the site plan and Landscape plan for building B. b. Landscaping on the east elevation needs to have 15 feet of Type I per FWRC 19.125.060(6)(b), which supersedes FWRC 19.115.060(2)(b) for Type II. Update the design narrative and landscaping plans accordingly. Response: Design Narrative & Landscape plan has been updated to reflect this. iii. Canopy (FWRC 19.115.060[2][c]): 1. The design narrative states that there is a five-foot wide canopy proposed on the south elevation of Building A. Per FWRC 19.115.060(2)(c), the minimum width of a canopy must be six feet. Response: Building overhangs have been increased to 6’ minimum at the building entry area. Other overhangs are 15’ and 25’ deep, refer to floor Plan and Elevations. iv. Pedestrian plazas (FWRC 19.115.060[2][d]): 1. Pedestrian plazas must be visible and accessible from the adjacent right -of- way. None of the plazas proposed meet these criteria due to their locations, Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -8- June 10, 2020 lack of pedestrian paths connecting them to the right-of-way, and the fact that the site will be secured with fencing and gates. Response: Due to existing topography of the site and the need for the site to be gradually sloping to accommodate the “low-boy” trucks as previously described, we have opted to utilize building modulation option in lieu of pedestrian plazas. However, we may still retain some of the on-site pedestrian areas for the employees and attempt to utilize some as a combination of requirement to meet modulation requirements, see Modified Design Guidelines. 2. Per FWRC 19.115.070(1)(b), plazas should be located at street corners to optimize pedestrian access and use. Response: We have located pedestrian plazas for Building B at the street corners, but will still be secured due to the security fencing. Due to grades mentioned in item 1 above, we will utilize building modulation in lieu of pedestrian plazas, however will retain some of the pedestrian plazas as shown on the site plan. 3. The northernmost elevation of Building A proposes to use a pedestrian plaza located along another portion of the building. Pedestrian plazas must be near the façade for which they are serving the purpose of FWRC 19.115.060(2). Response: See item 2 above. 4. Plazas are an excellent site feature and can still provide function to site users. At least one pedestrian plaza per building will be allowed to satisfy the requirements of FWRC 19.115.060(2). Response: While we did not see the limitation of only one pedestrian plaza per building noted in the code, we may retain the plazas shown on the site plan however; they will not be used in full to satisfy FWRC 19.115.060 (2). In the Design Guideline narrative, we request permission to use the plaza along the south side of building A along with a special architectural entry with open glass for transparency and the canopy option. Modulation is not every 60’ maximum on this elevation however, we proposed modulation at entry “eyebrow” design, pedestrian plaza and canopy overhang of 6’ > 50% of elevation. 6. Outdoor Storage– Please address the following comments a. The proposal includes outdoor truck storage separate from the principal sales area. Compliance with FWRC 19.125.170 needs to be demonstrated, including updating the site, landscaping, and civil plans as necessary. Any modifications must be applied for per FWRC 19.125.170(7) as part of the Use Process III application. Response: Site has all required landscaped buffers at the north, east, south and west sides of the site. Areas designated as “outdoor storage” are intended to be trucks that will be in line for the maintenance or body shop. It is the intent of this Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -9- June 10, 2020 facility to provide enough maintenance bays to work on trucks as they come in rather than store them outside. Business model dictates stored vehicles do not provide income or proper maintenance service for their clientele. Ther efore, you will see minimal outdoor storage of parked trucks on the exterior. The front of S. 320th Street will be used for “Principal Sales Area” for new trucks. In addition, along 32nd Ave S, we have a 15’ type I landscape screen which is intended to provide a solid sight barrier due to residential use/zones to the east, across the street. Along the south side, the site is approximately 16’ higher in grade than S. 320th Street which creates a visual barrier. The north side of the site varies from 10-21’ higher than the property to the north and also serves as a visual barrier. The west side has acres of wetlands and sensitive areas that do not present any visual issues from the public as it is screened by +100’ tall evergreen trees from I -5. b. Per FWRC 19.125.170(5), the outdoor truck storage areas are to be factored in when calculating the gross floor area (gfa) of the development. The additional gfa must be counted in the required parking calculation. Response: Gross area of “outdoor storage” has been calculated and noted on the site plan for the City of Federal Way parking calculation. In addition, we show four similar Pape facilities and their passenger vehicle parking as related to square footing of the facility. The proposed 14,928 square foot outdoor truck storage area has been included in the calculation of the City of Federal Way code parking requirements. The calculated code required parking requirements are documented in the Updated Parking Assessment by TENW dated 5/14/2020. The traffic report by TENW shows the summary of 4 other Pape Facilities and how they derived at the parking ratio per square foot of building area. The project proposes using this parking study to illustrate their need for passenger parking stalls. The parking study, if accepted, will override the City of Federal Way parking requirements. c. Per FWRC 19.220.030(7), outdoor storage cannot be located in front of the main building; it is presently shown on the south side of that structure. Response: The project is oriented toward 32nd Ave South and we consider this the “front” of the main building and our primary entry is visually oriented to the SE Corner. Although we have a 15’ type I landscape screen along 32nd Avenue S., all will be oriented for our customers to enter from this street. Although the property also fronts S. 320th Street, it has no driveway access and the street is 16’ below the site, so visually not accessible to the motoring public from this street. In addition, we have removed the truck parking along the south side because of the explanation in item 6a above. Since we moved the primary truck check in canopy to the east side, we allowed room for the larger trucks to perform a circular turn to access this side of the building. See site plan. 7. Parking– Please address the following comments: a. The parking analysis does not cite the FWRC and only provides three examples of other Pape locations. For consistency, include the Lakewood, WA location in addition to the others listed, as was done in the trip generation report. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -10- June 10, 2020 Response: The Parking Assessment (dated 5/14/2020) has been updated to include data from the Lakewood, WA Pape’ Kenworth facility. Required parking per FWRC section 19.220.030 was also included in the updated parking assessment. We have included the City of Federal parking calculation which includes the building area and the area of “outdoor storage.” We have also shown the 4th Lakewood facility in the parking study as requested. Reference report by TENW and the site plan which reflects both parking calculations. b. See comment #6(b) above, and address as part of the parking analysis. Response: The GFA used to calculate the code required parking per FWRC section 19.220.030 includes the proposed 14,928 square foot outdoor truck storage area. 8. Wetlands – Review and address the enclosed April 15, 2020, memo from the city’s wetland consultant, Landau. Response: A response to comments letter has been prepared by Soundview Consultants and is included within this submittal. 9. Tree/Vegetation Retention Plan – Please address the following comments: a. On Sheet 2: i. The BPA easement needs to be factored into the site area for calculation as it is not exempt per FWRC 19.120.130(3). Response: The BPA easement disallows the grantor the ability to plant and maintain trees within its boundaries and would not be suitable for planting trees. The easement should therefore be treated as any other right-of-way that would place limitations on the planting of trees, such as public and private roads. As provided for in FWRC 19.120.130, all areas burdened by such property rights limitations should be excluded from the tree retention calculation. However, in an effort to expedite project approval, the tree plan has been revised to demonstrate adequate tree retention even if the easement area were included in the tree retention calculation. ii. The wetland report describes Wetland A as being 4.23 acres in size; ensure the tree/vegetation plan reflects the correct wetland size and adjust associated tree calculations as necessary pursuant to FWRC 19.120.130(3). Response: Wetland A is 80,689 square feet (1.85 acres) in size on the site. The wetland report has been corrected accordingly. 10. Forest Practices – A Forest Practices Class IV-General Application is required if more than 5,000 board feet of merchantable timber will be harvested from the property in conjunction with the development activity. The city will review the proposed Class IV- General Forest Practices in conjunction with the SEPA review, and review of associated development permits or approvals. Please provide either the application or a written determination by the arborist that the project will fall under the established threshold. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -11- June 10, 2020 Response: A completed draft Forest Practices Class IV-General Application has been included for city review with this submittal. 11. Geotechnical Report – The report describes proposed retaining walls of 8 to 14 feet, and on page 20, describes them as being 40 feet in height, please clarify. The report notes a deviation to be requested per FWRC 19.120.120; however, there is no such request included with the submittal. Clarify what is proposed and update materials accordingly. Response: The “Retaining Structures” section on page 20 of the revised Geotechnical Report has been clarified. 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. 12. Use Process III Decisional Criteria – Provide a narrative demonstrating how the proposal satisfies FWRC 19.65.100(2). Response: Based upon all revisions made from this letter of comments, please refer to the revised Design Guidelines that have been updated to reflect the revisions. 13. Signs – Signage is not normally reviewed as part of the UP III process; signs are reviewed and approved via permits administered by the Permit Center. If a combined sign package for adjacent property owners is being pursued per FWRC 19.140.140(5), then that does require UP III approval. If a combined sign package is not proposed, then please remove the sign detail sheets from the submittal. Response: The project requires multi-tenant signage between Pape and Kenworth Northwest and is submitted to the City for review. W e will also obtain a standard sign permit from the City during the permit phase. 14. Title Report – The submitted reports are from 2018. The UP III submittal requirements require submission of a current title report. Also, title reports not more than one year old are required as part of the submittal for a Boundary Line Adjustment (BLA); which the submittal documents indicate will be forthcoming after annexation. Response: An updated title report is enclosed. 15. Boundary Line Adjustment – The SEPA checklist indicates that a BLA will be processed to configure the seven existing lots into two or three separate lots. From what has been submitted for review, the ultimate lot configuration is unclear. Show the proposed lot reconfiguration throughout project documents s o that code compliance with multiple criteria may be verified. Response: The proposed new lot lines are shown on all relevant plans and documents. SEPA CHECKLIST 16. Environmental Information – Include the parking analysis (checklist item #A[8]). Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -12- June 10, 2020 Response: Refer to attached revised environmental Checklist, report from TENW and the site plan for City of Federal Way parking analysis including the area of outdoor storage and the parking study showing 4 similar Pape sites studied by TENW. 17. Project Description – Include details regarding the size, height, and number of buildings proposed; number of parking spaces, including other site improvement details; utility extensions; and frontage improvements (checklist item #A[11]). Response: Project Description has been revised to include the above information. 18. Land Use – Please address the following comments: a. Include the presence of the geologically hazardous area per the submitted geotechnical report (checklist item #B[8][h]). Response: A slope exhibit has been included with this submittal. b. Removing residences is considered displacement (checklist item #B[8][j]). Response: The SEPA checklist has been updated to address this comment and a copy is included with the package. c. Indicate whether high, middle, or low-income housing is being eliminated (checklist item #B[9][b]). Response: The SEPA checklist has been updated to address this comment and a copy is included with the package. 19. Historic and Cultural Preservation – There are structures on-site, please elaborate (checklist item #B[13][a]). Response: The SEPA checklist has been updated to address this comment and a copy is included with the package. 20. Transportation – Frontage improvements are part of the project (checklist item #B[14][h]). In addition, review the Public W orks Traffic comments below, and revise the SEPA checklist as necessary. Response: Frontage improvements along 32nd Avenue South shall be consistent with City of Federal Way “Type K Street”. 21. Public Services – Elaborate on the stated increased need for public services (checklist item #B[15][a]). Response: The development will require additional public services including parking, frontage, water service and stormwater. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -13- June 10, 2020 Public Works – Development Services Division Ann Dower, (253) 835-2732, ann.dower@cityoffederalway.com Engineering Plans 22. The southwest corner of the site is an acceptable pond location, provided requirements in the 2016 King County Surface Water Design Manual (KCSWDM) are met. Additional information will be necessary regarding slopes (south and west sides), soils, setbacks, discharge method and location, access, and other manual requirements to verify that the pond will function properly in that location. Response: Sections that include the proposed detention facility have been provided on the civil plans. The sections also provide additional details on the slope, access, fill requirements, etc. In addition, the “Detention Pond” section on page 32 of the r evised Geotechnical Report addresses global stability of the pond and embankments, recommended setback from the steep slope, and low permeability liner recommendations based on site soils. 23. Infiltration must occur within native soil, not within fill, as required by the KCSWDM. Further details must be provided regarding the type of infiltration system and where infiltration will occur. If this a proposed injection well situation, Department of Ecology approval will be required prior to Federal Way review. Response: Sections that include the infiltration facility have been provided on the civil plans indicating that the facility is proposed to be located within native soil. The section also provide additional details on the type of infiltration system that is being proposed. We do not believe that the proposed facility qualifies as injection well. 24. Oil control will be required for this site as outlined in the KCSWDM in Special Requirement 5. The TIR states that it is not necessary; however, no explanation was provided. The applicant must explain how the intended use, with both truck storage and repair, does not trigger this requirement. Response: Oil control has been provided and detailed on the updated civil plans. 25. FWRC 11.05.110 requires that overhead utility lines be placed underground. There are overhead utilities both along South 320th Street and along 32nd Avenue South. The applicant will need to apply for and receive approval of a variance per FWRC 11.05.080 if they do not wish to place the existing overhead utilities that are impacted by roadway improvements underground. Response: The applicant intends to place the overhead utility lines along 32nd Avenue South underground and, if needed, intends to apply for a variance for FWRC 1.05.110 at the civil plan review stage of the project to address undergrounding utilities along South 320th Street. 26. Lakehaven Water & Sewer District has indicated that a crossing of South 320 th Street may be necessary. Please inform city staff as soon as possible if trenching will occur, as overlay requirements will apply. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -14- June 10, 2020 Response: The project anticipates that a crossing of South 320th Street will be necessary and trenching is expected to occur. 27. The Overall Site Plan shows the trash enclosure as uncovered. The Source Control section of the summary indicates that it will be covered. If it is plumbed to the sanitary sewer, it will have to be covered, regardless of size. If it is plumbed to the storm sewer, an oil/water separator will be required. Response: The trash enclosure will drain to the stormwater system, which include an oil water separator. Response: Site Plan shows the trash enclosure at building B, Body Shop, is located on the west side and is now covered to assist in building modulation requirements. The trash enclosure along the West side of the Site, Southwest of Building A, is currently uncovered and is 173 sf. Refer to Civil for drainage and oil/water separator requirements. 28. Runoff from 32nd Avenue South and adjacent pollution-generating impervious surface is shown as being routed to the infiltration trenches, without treatment. Infiltration facilities do require basic level treatment, as stated in KCSWDM Exception 2 in Section 1.2.8.1.A. Response: Additional cation exchange capacity (CEC) and organic content test ing was conducted on soils in the vicinity of the proposed infiltration trenches. The tested soils met requirements for treatment. Test results have been added as Table 16 on page 32 of the revised Geotechnical Report. 29. Cross sections of the pond and the i nfiltration trenches will be required with the land use submittal. Outfalls will be reviewed in more detail. Response: Cross sections of the infiltration facility and the detention facility have been provided on the revised civil plans. 30. Show approximate locations of street trees on the site plan. Please be advised that a separately metered irrigation system will be required for the planter strip on South 320 th Street. Response: Approximate location of street trees have been shown on the revised civil engineering plans. Technical Information Report 31. The downstream analysis will require an actual in-person visit to the downstream area. Document field conditions and structures with photos. Response: The TIR has been updated to include documentation of field conditions and structures with photos. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -15- June 10, 2020 Geotechnical Report 32. Retaining walls will require geotechnical review and approval. The geotechnical report must study the possible effect of the infiltration trenches located nearby. Construction must account for any affects the infiltration trenches may have on the walls. Height requirements will be determined by the Planning Division. Response: The preliminary global stability analysis described on page 22 of the Revised Geotechnical Report was updated to show the proposed infiltration trenches and an elevated water table below the proposed infiltration trenches. 33. The engineer and geotechnical engineer must make determinations regarding slope percentages and soil stability. Please provide a plan showing areas of 15 pe rcent and greater slopes. Response: A plan showing slopes of 15 – 39 percent and 40 percent or greater is included as Figure 4 of the revised Geotechnical Report. In addition to the slope exhibit showing the steep slopes from 15-39% and 40% or greater and associated buffers per report by GeoResources, Inc., superimposed on the site plan layout. This was provided due to the dominating affect this illustration would have on the site plan. Public Works – Traffic Division Sarady Long, (253) 835-2743, sarady.long@cityoffederalway.com Plans Comments 34. Provide AASHTO pavement design for the pavement section on 32nd Avenue South. It may be necessary to provide concrete instead of asphalt for the intersection landing in order to prevent pavement distresses and rutting from downhill truck traffic. Response: Asphalt and Portland cement concrete pavement designs for 32nd Avenue South using the AASHTO 1993 method have been added on page 26 of the revised Geotechnical Report. 35. Provide channelization plans for South 320th Street and 32nd Avenue South improvements showing pavement removal, new and existing markings, signs relocation, etc. Response: Conceptual channelization plans have been provided in the updated civil plans. Detailed plans will be provided at the permitting stage. 36. The 32nd Avenue South street extension must be designed to meet AASHTO, and all applicable standards. ADA compliant pedestrian facilities must be provided for all improvements to the maximum extent feasible. Response: Comment acknowledged. A detailed design for the 32nd Avenue South extension that is ADA compliant will be provided at the permitting stage. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -16- June 10, 2020 37. The maximum driveway width is 30 feet for a two-lane two-way driveway and 40 feet for a three-lane two-way driveway. The applicant must submit a Vehicle Turning Diagram supporting the request to increase the width to 55 feet. The request would be determined on a case-by-case basis by the Public Works Director. There is a $344 fee associated with the request. Response: The site plan has been revised to include widths of 55-foot. A truck turn diagram has been included with the submission for city review. 38. Show transition at the end of the property on 32nd Avenue South between the existing pavement/gravel road and new 28-foot pavement and sidewalk. Response: This transition has been shown on the updated civil plans. 39. Frontage improvements on South 320th Street will likely be within WSDOT limited access and therefore, will require WSDOT’s channelization approval. The applicant should coordinate with WSDOT on the required plans submittal. Response: Applicant will coordinate with WSDOT on required plan submittal for frontage on South 320th Street, and later submit channelization plan for WSDOT approval. 40. The existing traffic signal at South 320th Street and 32nd Avenue South intersection will need to be modified to accommodate the required South 320 th Street and 32nd Avenue South street improvements. The signal plans must be designed by a professional engineer licensed in Washington State and submitted to the city for review and approval. Response: TENW will prepare traffic signal modification plans to be included with first permit submittal to accommodate the intersection improvements. 41. Provide a narrative regarding how the proposed gate entry will be utilized during business hours. Adequate storage length must be provided to ensure a waiting vehicle will not block through traffic on public streets. Please note, the gate must be approved by the US Postal Service, Federal Way Safety Team (Police and Fire Department), and Lakehaven Water & Sewer District. Response: During current business hours, several managers/employees will be equipped with the task to open the security gates early in the morning and close them at the end of business hours. The employee performing this task will be in their passenger car. The site plan shows 26.81’ and 27.24’ queuing on the south and north gates, respectively, from gate to edge of paved street. Project will coordinate with US Postal Service, Federal Way Police and Fire and Lakehaven Water & Sewer District for access in an emergency. 42. Provide a conceptual illumination plan. The final illumination plan shall be designed by a professional engineer and will need to be submitted as part of the engineering plan submittal. Response: A conceptual illumination plan is included with this response letter. Final illumination plans shall be included in first permit submittal. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -17- June 10, 2020 Trip Generation and Parking Assessment Review Comments 43. The trip generation study shall be based upon the guidelines established in the most recent edition of the ITE Trip Generation Handbook, and must be stamped by a professional engineer. All relevant data used in the analysis shall be included. Response: The trip generation study has been updated to reflect the current proposed building area. The traffic data collected and used to support the derived trip generation rates is included in the updated trip generation study. The study and data collection is consistent with the guidelines established in the ITE Trip Generation Handbook by collecting data on multiple days at multiple similar uses to what is proposed. 44. Per the Trip Generation Study, the project is estimated to generate 62 AM peak hour trips and 62 PM peak hour trips. These trips will likely impact the South 320 th Street and SR 5 ramp terminal intersections. The SR 5 ramp terminal intersections are under WSDOT control and therefore, are subjected to their respective established traffic guideline and LOS standard. The applicant should coordinate with WSDOT to address any potential traffic related concerns. Response: TENW will coordinate with WSDOT to address potential traffic related concerns. 45. The parking assessment should include the Lakewood local site consistent with the four sites in the trip generation study. Response: An updated Parking Assessment (dated 5/14/2020) has been prepared, and includes data collected at the Lakewood Pape’ Kenworth facility. 46. It appears that the parking ratio of stalls per 1,000 square feet is based on parking stalls provided by each site compared to the gross floor area. The analysis did not include the inventory of any available on- or off-street parking, other peaks demand, utilization rate, etc. Response: The parking ratio was derived based on the building areas and the on-site parking supply provided at the four existing similar Pape’ Kenworth facilities. Parking demand was assumed to be accommodated on-site at the four facilities studied and the availability of on-street parking was not factored into the derived parking ratio. SEPA Checklist – Transportation 47. Transportation 14(d) – Revise this section to specify frontage improvement and right -of- way dedication along South 320th Street and 32nd Avenue South. Response: Detailed information regarding proposed roadway improvements have been added to the SEPA checklist as requested. 48. Transportation 14(f) – Revise the trip generation identified in this section to be consistent with the trip generation study conducted by TENW. Per the trip generation study, the project is estimated to generate 62 pm peak trips and no data was provided for weekday Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -18- June 10, 2020 daily. With the estimated 62 pm peak hour trips, it is unlikely this project would generate 8,230 daily trips as specified. Response: The previously reported weekday daily trip generation of 8,230 daily trips was an error. Based on the current proposed building area of 79,744 square feet, the project trip generation estimate has been updated to reflect 924 weekday daily trips with 69 trips occurring during the AM peak hour and 69 trips occurring during the PM peak hour. Lakehaven Water & Sewer District Brian Asbury, (253) 946-5407, basbury@lakehaven.org 49. Regarding any water/sewer utility work in South 320th Street, it would only be sewer. If constructed per the current Wastewater Comprehensive Plan, a new gravity sewer main would extend/route from the east along the north side of South 320th Street, ideally north of any right-of-way asphalt pavement, then extend north in 32nd Avenue South to the site’s northeast corner (far edge). The applicant had previously inquired of Lakehaven regarding the possibility of extending a new sewer main directly from the south; if this route/alignment were to be approved by Lakehaven, we would anticipate no asphalt pavement excavation would be allowed to cross South 320th Street. Response: The project is proposing a new sewer main be extended to the north with full overlay of the intersection of South 320tj Street and 32nd Avenue South. 50. Lakehaven’s previous October 10, 2019, comments are still applicable, with the following task/item updates: a. Lakehaven issued Water & Sewer Certificates of Availability for the proposed project/property on February 28, 2020. Certificates are valid for one-year from the date of issuance. Response: Comment acknowledged. b. The following are the October 2019 comments previously provide by Lakehaven: Water  A Water Certificate of Availability issued separately by Lakehaven may be required to be submitted with any land use and/or building permit applications (check with land use agency for requirement). The certificate is valid for one year from the date of issuance. If a certificate is needed, allow one to two working days to issue for typical processing. The 2019 cost for a Water Certificate of Availability is $70.00. Response: Comment acknowledged.  Hydraulic model results (FF #94) indicate that Lakehaven’s standard maximum allowable system liquid velocity of 10 feet square, at no less than 20 psi, is exceeded in the existing proximate water system at a fire flow rate above 5,400 GPM. This flow figure depicts the calculated performance of the existing water distribution system under high demand conditions. Fire flow ra tes greater than available in the existing Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -19- June 10, 2020 distribution system may be accommodated through water distribution system improvements. On-site hydraulic system calculations may need to be determined during design of the on-site water distribution system improvements. Please contact Lakehaven for further details. Response: Comment acknowledged.  A Lakehaven Developer Extension (DE) Agreement will be required to construct new (on-site fire hydrant) water distribution system facilities for the proposed development. Additional detail and/or design requirements can be obtained from Lakehaven by completing and submitting a separate application to Lakehaven for either a Developer Pre-Design Meeting or a DE Agreement. Lakehaven encourages owners/developers/applicants to apply for Lakehaven processes separately to Lakehaven, and sufficiently early in the pre-design/planning phase to avoid delays in overall project development. Response: Comment acknowledged.  A water service connection application submitted separately to Lakehaven is required for each new service connection to the water distribution system, or any modification to an existing water service connection (e.g., larger meter/service, irrigation, abandonment of existing service[s], re-activation, etc.), in accordance with standards defined in Lakehaven’s current “Fees and Charges Resolution.” Non-single-family properties require separate domestic (per building typically, some exceptions allowed), irrigation (if irrigated landscaped areas are incorporated into the site development), and fire protection (if required or installed) water service connections and meters. Response: Comment acknowledged.  For water use during site construction/development, the existing water service(s) must be utilized for this purpose. Please contact Lakehaven for further details. Response: Comment acknowledged.  Protection of any existing water meters and/or service connections, or full abandonment by “removal” if future service(s) will not be needed, will be required for any on-site building demolition. Please contact Lakehaven for further information regarding this issue. Response: Comment acknowledged.  To satisfy premise isolation requirements, the installation and satisfactory testing of an approved backflow prevention assembly (BPA) adjacent to each service meter is required pursuant to Washington Administrative Code (WAC) 246-290-490 and Lakehaven standards regarding premise isolation. Because the potential cross - connection hazard(s) cannot be determined at this time, Lakehaven canno t specify the minimum required BPA device. Contact Lakehaven’s Cross-Connection Control Program Manager (Chris Zoepfl, czoepfl@lakehaven.org, 253-946-5427) for additional information on premise isolation/BPA installation and testing coordination. Response: Comment acknowledged. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -20- June 10, 2020  Typically required location(s) for any BPA is outside of a building (fire - protection typically aboveground, RPBA/RPBA devices always aboveground), and as close to the main as possible, but no further than 50 feet from the main. There are some reasons/situations for some case-by-case exceptions that are allowed by Lakehaven, most of these in Federal Way’s City Center area. Applicants may submit a modification request (include plan/sketch) to Lakehaven for non-typical location(s). Contact Lakehaven’s Cross-Connection Control Program Manager (Chris Zoepfl, czoepfl@lakehaven.org, 253-946-5427) for additional information on premise isolation/ BPA requirements, installation, and testing coordination. Response: Comment acknowledged.  The associated DE Agreement must achieve a point of either Substantial Completion or Acceptance, as determined by Lakehaven, prior to activating any new domestic or irrigation water service connection(s). Response: Comment acknowledged.  Based on the proposal submitted, preliminary estimated Lakehaven water service connection fees, charges, and/or deposits (2019 schedule) will be as follows. Actual connection charges will be determined upon submittal of service connection application(s) to Lakehaven. Charges-Payable-in-Lieu-of-Extension (CPILOE) are assessable against the property for water facilities previously constructed that provide direct benefit to the property. If a DE Agreement is required, CPILOE charges are due prior to and as a condition of scheduling the Lakehaven DE preconstruction meeting. Connection charges are separate from any DE fees/charges/deposits and are due at the time of application for service. All Lakehaven fees, charges, and deposits are typically reviewed and adjusted (if necessary) annually, and are subject to change without notice. Response: Comment acknowledged. o Water Service/Meter Installation, Main Bldg., Domestic, 1½" preliminary size: $732.70 drop-in meter fee. Actual size to be determined by Lakehaven based on the applicant’s estimated maximum domestic/commercial GPM usage rate. Response: Comment acknowledged. o Water Service/Meter Installation, Body Shop Bldg., Domestic, 1" preliminary size: $1,500.00 meter upsize deposit (upsize an existing meter). Actual size to be determined by Lakehaven based on the applicant’s estimated maximum domestic/commercial GPM usage rate. Response: Comment acknowledged. o Water Service/Meter Installation, Irrigation, 1" preliminary size: $1,500.00 meter upsize deposit (upsize an existing meter). Actual size to be determined by Lakehaven based on the applicant’s estimated maximum irrigation GPM usage rate. Response: Comment acknowledged. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -21- June 10, 2020 o Water Service/Meter Installation, Fire-Protection, ⅝" x ¾" flow-detection-only meter: $474.10 drop-in meter fee (each x2). Response: Comment acknowledged. o Capital Facilities Charge(s)-Water, preliminary estimate of 10.00 ERU: $0.00. Actual amount due to be determined by Lakehaven based on applicant’s estimated annual total water usage rate. Water system capacity credits are available for this property from system capacity charges previously assessed, paid directly to Lakehaven, and/or credited to the property for 11.64 Equivalent Residential Units (ERU). Please contact Lakehaven for further detail. Response: Comment acknowledged. o CPILOE: $11,148.63. If CPILOE paid after annexation into the City of Federal Way, add $864.02 for the city excise tax. Response: Comment acknowledged. Sewer o A Sewer Certificate of Availability issued separately by Lakehaven may be required to be submitted with any land use and/or building permit applications (check with land use agency for requirement). The certificate is valid for one year from the date of issuance. If a certificate is needed, allow one to two working days to issue for typical processing. The 2019 cost for a Sewer Certificate of Availability is $70.00. Response: Comment acknowledged. o A Lakehaven Developer Extension (DE) Agreement will be required to construct new sanitary sewer system facilities necessary for the proposed development, including extend-to-far-edge(s) in accordance with long-standing Lakehaven policy. Lakehaven’s current Wastewater System Comprehensive Plan indicates a sewer trunk extension to the property from the east; however, Lakehaven would consider, and presuming downstream analysis supported, extending a new sewer main from the south across South 320th Street. Additional detail and/or design requirements can be obtained from Lakehaven by completing and submitting a separate application to Lakehaven for either a Developer Pre- Design Meeting or a Developer Extension Agreement. Lakehaven encourages owners/developers/applicants to apply for Lakehaven processes separately to Lakehaven, and sufficiently early in the pre-design/planning phase to avoid delays in overall project development. Response: Comment acknowledged. o A separate Lakehaven Sewer Service Connection Permit is required for each new connection to the sanitary sewer system, in accordance with standards defined in Lakehaven’s current “Fees and Charges Resolution.” Minimum pipe slope for gravity sewer service connections is two percent. In addition to all Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -22- June 10, 2020 other sewer service installation standards, installation of a Type 1, 48-inch monitoring manhole is typically required on the private building sewer line, for all new or modified non-residential connections. Also, if applicable, see the enclosed Lakehaven Trash/ Recycling Enclosure Standards. Response: Comment acknowledged. o The applicant will be required to complete and submit a Sewer Use Survey (SUS). Information in the SUS will be used by Lakehaven to determine specific pretreatment requirements (if any). Response: Comment acknowledged. o Execution of a Discharge Agreement will be required, as a condition of Lakehaven issuing Sewer Service Connection Permit(s) for this site. Response: Comment acknowledged. o Based on the proposal submitted, preliminary estimated Lakehaven sewer service connection fees, charges, and/or deposits (2019 schedule) will be as follows. Actual connection charges will be determined upon submittal of service connection application(s) to Lakehaven. All Lakehaven fees, charges, and deposits are typically reviewed and adjusted (if necessary) annually, and are subject to change without notice. Response: Comment acknowledged. o Sewer Service Connection Permit: $420.23 fee (per building). Response: Comment acknowledged. o Capital Facilities Charge(s)-Sewer, preliminary estimate of 8.00 ERU: $3,978.13 per ERU. Actual amount due to be determined by Lakehaven based on applicant’s estimated annual domestic/commercial/industrial only water usage rate. Please contact Lakehaven for further detail. Response: Comment acknowledged. General o All Lakehaven development engineering related application forms and associated standards can be accessed at Lakehaven’s web pages: http://www.lakehaven.org/204/development-engineering Response: Comment acknowledged. o All comments herein are valid for one year and are based on the proposal(s) submitted and Lakehaven’s current regulations and policies. Any change to either the development proposal(s) or Lakehaven’s regulations and policies may affect the above comments accordingly. Response: Comment acknowledged. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -23- June 10, 2020 South King Fire & Rescue Sean Nichols, (253) 946-7242, sean.nichols@southkingfire.org Water Supply 51. 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. Response: Comment acknowledged. Fire Hydrants 52. 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 being obstructed by fire hose. Response: Comment acknowledged. 53. Hydrant spacing along access roads and location in relationship to buildings and sprinkler FDC shall be approved by Fire Marshal’s Office. Response: Comment acknowledged. 54. Fire hydrants shall be in service prior to and during the time of construction. Response: Comment acknowledged. Emergency Access 55. Fire apparatus access roads shall comply with all requirements of Fire Access Policy 10.006: http://southkingfire.org/DocumentCenter/Home/View/24. Response: Comment acknowledged. 56. Designated and marked fire lanes may be required for emergency access. This may be done during the plans check or prior to the building final. Requirements and marking options can be found in FWRC Title 8: http://www.codepublishing.com/WA/FederalWay/. Response: Comment acknowledged. 57. Fire apparatus access roads shall be installed and made serviceable prior to and during the time of construction. Response: Comment acknowledged. 58. 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. Response: Comment acknowledged. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -24- June 10, 2020 Vehicle Access Gates 59. All vehicle access gates shall comply with the Gate Policy (if gates are installed): http://southkingfire.org/DocumentCenter/Home/View/21. Response: Comment acknowledged. Fire Department Lock Box 60. 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. Response: Comment acknowledged. Fire Sprinkler System 61. An NFPA 13 fire sprinkler system is required in all buildings. Response: Comment acknowledged. 62. 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. Fire walls shall not be considered to separate a building to enable deletion of the required automatic fire-extinguishing system. Response: Comment acknowledged. 63. 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. Response: Comment acknowledged. Fire Alarm 64. A fire alarm system is required. Response: Comment acknowledged. 65. 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. Response: Comment acknowledged. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -25- June 10, 2020 We believe that the above responses, together with the enclosed revised plans and technical documents, address all of the comments in your letter dated April 24, 2020. Please review and approve the enclosed at your earliest convenience. If you have questions or need additional information, please do not hesitate to contact me at this office. Thank you. Sincerely, Daniel K. Balmelli, P.E. Executive Vice President DKB/yg 20833c.002.doc enc: As Noted cc: Quinn Closson, Pape Group Bart Dickson, Cobalt Development Howard Kimura, H.G. Kimura Architect, PLLC Ben Eldridge, Barghausen Consulting Engineers, Inc. Betsy Dyer, Barghausen Consulting Engineers, Inc.