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20-102489-Resubmit Response Letter-2020-10-13-V3October 13, 2020 Stacey Welsh, Principal Planner City of Federal Way Department of Community Development 33325 – 8th Avenue South Federal Way, WA 98003 RE: Response to Technical Review Comments Pape Kenworth Northwest Files #20-102489-UP, #20-102490-SE and #20-102492-AD City of Federal Way, King County, Washington Our Job No. 20833 Dear Stacey: We have revised the plans and technical documents for the above-referenced project in accordance with your comment letter dated September 15, 2020. Enclosed are the following documents for your review and approval: 1. One (1) each electronic copy Resubmittal Information Form for each application 2. One (1) each electronic copy revised Architectural Plans to include Site, Floor, Elevations, Sign and Illumination 3. One (1) each electronic copy Maximum Building Height Justification 4. One (1) each electronic copy revised Civil Engineering and Landscape Design Plans 5. One (1) each electronic copy Modification Request for Retaining Wall Height 6. One (1) each electronic copy Modification Request for Landscape Requirement 7. One (1) each electronic copy revised Community Design Guidelines Narrative 8. One (1) each electronic copy updated Forest Practice Application 9. One (1) each electronic copy revised Use Process III Decisional Criteria Narrative 10. One (1) each electronic copy revised SEPA Checklist 11. One (1) each electronic copy revised Technical Information Report 12. One (1) each electronic copy revised Geotechnical Information Report 13. One (1) each electronic copy 2020 Traffic Concurrency Review Application 14. One (1) each electronic copy updated Parking Assessment Memo 15. One (1) each electronic copy Photometric Analysis 16. One (1) each electronic copy revised Truck Turn Exhibit Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -2- October 13, 2020 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 Use Process III 1. General – Technical comments made about an item on one sheet or in a document may 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. 2. 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 FWRC 19.145.160. It is understood that there are separate exhibits in the report and provided with the project submittal; however, as has been done for the wetland and associated buffer, this information must also be shown on the site plan per FWRC 19.145.150(4). Response: Geologic hazardous areas and buffers in accordance with report (page 14) have been added to the site and civil plans. b. On the site and civil plans, correct the five-foot critical areas BSBL in the wetland reduction area to the new buffer line. Response: The BSBL has been corrected in the wetland reduction area. c. Update the area of wetland buffer reduction/addition on Sheets C13, L2, and L6. Response: The wetland buffer areas have been updated. d. On Sheet SP-1, regarding retaining walls, see FWRC 12.120.120 and address the following: 1. Explain retaining wall modifications from the requirements in FWRC 19.120.120. The process for a modification request to those requirements is detailed in FWRC 19.120.050, not a FWRC 19.45 variance request. The modification request should accompany the project resubmittal. Staff is looking for explanations from your civil and geotechnical engineers on this matter. Please explain in detail (not in general) about why it is needed. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -3- October 13, 2020 Response: A modification request letter addressing the retaining wall height has been prepared in place of the previous variance request per FWRC 19.102.050. e. On the landscaping sheets: 1. Remove the building permit number for the Tilt project from the landscape plan set. Response: Building permit number has been removed as requested. 2. No landscaping is shown along the southern property line along 320th, where five feet of Type III is required per FWRC 19.125.060(6)(a). Response: Type II landscape buffer has been added. 3. Fifteen feet of Type I landscaping is required along 32nd. Due to limitations imposed by the BPA easement, a landscaping modification needs to be requested in accordance with FWRC 19.125.100, this is not a FWRC 19.45 variance request. Response: Comment acknowledged. A landscape modification has been prepared in accordance with FWRC 19.125.100. 4. 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: Plans have been revised to indicate erosion control hydroseed to be applied over the impacted areas that coincide with the proposed grading. 5. On Sheet L-3, the parking lot landscaping calculation needs updated as more that 86 parking stalls are proposed. The summary shows that an inadequate amount of parking lot landscaping is being provided; 2,192 square feet, when 2,552 square feet are required. Please address and updated plans accordingly. Response: Sheet L3 has been updated to reflect 117 parking stalls. f. On Sheet A-2,5 1. Need to show calculations for the proposed elevations in addition to the existing elevations, see the enclosed handout. Response: Per the handout provided, new calculations for the proposed elevations have been shown. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -4- October 13, 2020 2. The main office building ABE shown is not correct, the lower number was not selected. Response: Please see updated calculations where the lower number has been selected. 3. Any building greater than 35 feet in height requires a demonstration of compliance with FWRC 19.220.030(1). Response: A Maximum Building Height Justification for the building, which is greater than 35 feet in height, has been prepared and is enclosed with this package. 3. Design Guideline – Please address the following comments: a. On page 3 of the submitted design 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: Note (g)(5) has been edited to read 5-foot landscape along the north and south property lines. Landscape along west side has been omitted due to natural vegetation being retained. b. Regarding façade modulation and screening options, 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 of both buildings. Label the areas as Type II on the landscaping plans. Response: Type II screen has been labeled on the landscape planting plan. 4. Outdoor Storage – Extensive trailer parking areas are shown on the landscaping sheets and nowhere else. This differs quite a bit from the 14,928 square foot outdoor truck area shown on the site plan. If this additional area is proposed, then it must meet outdoor storage (FWRC 19.125.170[3] & [5]) and parking lot landscaping requirements (FWRC 19.125.070). Response: Landscape plan has been updated to reflect the site plan. These are the designated areas for truck storage/parking. The display trucks for sale are limited since each truck has enormous inventory costs and Pape Kenworth Northwest typically only carries 6 to 9 trucks at a time. In terms of truck parking for maintenance, the bays are designed to house the trucks inside and the trucks in queue are made with appointments, so the business model and management minimizes having a large mass of truck on-site waiting to be serviced. 5. Parking – 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. While the parking analysis provides a new ratio for determining the amount of required parking, the analysis omits applying it to the Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -5- October 13, 2020 outdoor storage space (94672 x 1.38 / 1000 = 131 spaces, not 116, which are shown on the site plan). Other submittal documents note 111 spaces. Response: The parking calculations included in the previous May 14, 2020 parking assessment by TENW have been updated to include the square footage of outdoor truck storage areas. A revised Parking Assessment Memo dated September 30, 2020 includes the revised parking calculations. 6. Lighting Plan – FWRC 19.105.030 contains lighting regulations. 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. Provide an on-site lighting plan. Response: A preliminary illumination plan and lighting calculations is included with the resubmittal. The intent of the plan is to meet City lighting regulations. 7. Forest Practices – The submitted application is incomplete. Please provide or revised answers to items #3 (20-102492-AD, 20-102490-SE, and 20-102489-UP), #4, #8-board feet, and #9. The application is also missing all required signatures. Response: A revised application has been prepared and will be submitted for review. 8. Use Process III Decisional Criteria – Provide a narrative demonstrating how the proposal satisfies FWRC 19.65.100(2); to clarify this is different than FWRC 19.115 (design guidelines). Response: See attached Process III Decisional Criteria narrative responding to the criteria listed in FWRC 19.65.100(2). 9. Burden of Proof – In this letter, staff members have identified items that require the provision of additional information for review. During the Notice of Application comment period, the city received six public comment letters, which are enclosed. Please review and address the comments to support your project. Per FWRC 19.56.080: 19.65.080, “Burden of Proof” “The applicant has the responsibility of convincing the director that, under the provisions of this chapter, the applicant is entitled to the requested decision.” Response: Please see enclosed Decisional Criteria Narrative to address public comments received by the city. 10. Signs – The site plan shows the buildings and signs proposed on the same property, therefore, a combined sign package for adjacent property owners is not necessary per FWRC 19.140.140(5). Keep this provision in mind should a boundary line adjustment (BLA) change the circumstances from what is currently shown. Signage is not reviewed or approved as part of the land use application process but rather via permit administered by the Permit Center. Response: Comment acknowledged. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -6- October 13, 2020 11. Boundary Line Adjustment – The site plan has been revised as requested to shown the proposed lot reconfiguration. The drawing shows the seven lots reduced to two, with proposed Lot 1 containing the buildings, parking lot, and stormwater pond, and proposed Lot 2 containing everything west of the developed area, such as the wetland and buffer. Although the BLA has not been submitted, some comments will be noted here. As part of the BLA submittal, identify where there is a feasible building envelope for proposed Lot 2, as this lot appears to have minimal building potential due to critical areas and buffers. You can provide this on the BLA and/or in a separate depiction for clarity. Keep in mind that a BLA cannot produce a landlocked parcel or an unbuildable lot per FWRC 18.10.010(4) and 18.55.020 Response: The project will not combine all lots into one parcel instead of the two parcels previously indicated. SEPA 12. Background – Please address the following comments: 1. The annexation is effective; update the checklist accordingly (checklist item #A[9]). Response: The SEPA checklist has been updated to reflect the completion of the Annexation process. 2. The Forest Practices Application decision is issued by the city, not WA DNR (checklist item #A[10]). Response: The SEPA checklist has been revised per the comment above. 13. Parking – The number of proposed parking stalls is listed incorrectly in multiple locations, including under the project description and in the transportation section. Response: The checklist has been updated with consistent parking count throughout. 14. Other – If project materials are revised or added that necessitate an update to the SEPA checklist, please update the contents accordingly prior to resubmittal. Response: Comment acknowledged. Public Works – Development Services Division Ann Dower, (253) 835-2732, ann.dower@cityoffederalway.com Technical Information Report 15. The downstream analysis requires further information be provided regarding the onsite and offsite wetland. How does the offsite portion discharge and how is it conveyed under South 320th Street? Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -7- October 13, 2020 Response: After additional investigation, we believe that runoff from 32nd Avenue South most likely crosses South 320th Street to the west near the I-5 on-ramp via and existing 8-inch pipe. 16. Comingling stormwater runoff form public property with runoff from private property is not the preference of the city due to legal and responsibility issues that may arise. Detention and infiltration should be sized as shown in the TIR to include runoff from new impervious area within the right-of-way, but conveyance to those facilities will not be required. Response: Comment acknowledged. The facilities have been revised as requested. 17. Explain the runoff that is being collected from offsite, north of 32nd Avenue South, and discharged to a manhole at the north end of the improvements. How much area will discharge to this pipe? Where does this come from and to where is it being conveyed? Response: Runoff from offsite improvements will be collected by a proposed catch basin and pipe system and conveyed to the west along South 320th Street, then to the south under South 320th Street. Geotechnical Report 18. Under Stormwater Recommendations page 28, infiltration is not anticipated by this report “Based on the current site plan.” The site plan in the report does not match the site plan presented by Barghausen Engineers. Infiltration setbacks are partially addressed, but appear to be inaccurate based on review of the Slope Exhibit (Barghausen) which overlays the site plan (Barghausen) onto the Site Slopes Map (Figure 4) provided in the geotechnical report. The geotechnical engineer must specifically address how the detention pond and infiltration trenches will impact the landslide hazard areas (15 percent slopes or greater) and the steep slope hazard area (40 percent slopes or greater), as defined in the 2016 King County Surface Water Design Manual (KCSWDM) section 5.1.1 “Setbacks” and 5.2.1 “Infiltration Near Steep Slopes and Landslide Hazard Areas.” Ponds and infiltration trenches must be located 200 feet from these slopes, unless the geotechnical engineer can recommend a lesser setback. The distance from top of slope must also be addressed. Currently, the report states that this 200-foot setback should be met; therefore, the site plan cannot be approved until this issue is resolved. Response: The Geotechnical Information Report has been updated to reflect the appropriate stormwater management per the 2016 KCSWDM. Slope stability information has been prepared and is included in the updated report 19. Only B3 is in the location of the proposed infiltration trenches. Testing procedures and number of tests must meet the requirements shown in section 5.2.1 of the KCSWDM, and infiltration rates must be revised accordingly. Response: Additional testing will be performed on the site and the updated information will be provided to the city when available. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -8- October 13, 2020 Landscape Plan 20. A 2.5-inch caliper is required for street trees. Response: Caliper of street trees has been updated. 21. Call out the separate irrigation meter required for right-of-way landscaping on South 320th Street. Response: Water meter for South 320th Street is shown on the irrigation plan and also on the civil engineering plan set. Civil Plan Set 22. Please revised the “ex R/W” note on the left side of the road section for 32nd Avenue South. Indicate what will be constructed at this time and what will be done by others at a later date. Response: The note has been revised as requested. 23. Show a pond liner, as recommended in the geotechnical report on page 32. Response: Pond liner is now shown. SEPA Checklist 24. Item A-10 should include WSDOT approval of the trip generation study, channelization plan, and storm drainage. Response: The checklist has been updated to include WSDOT approvals. Modification for Driveway 25. The Truck Turn Exhibit does not provide driveway widths for 32nd Avenue South; however, measurement of the openings shows widths in excess of 50 feet. The exhibit needs to support and coordinate with the modification. Response: A driveway modification has been approved for 55-foot width for each driveway. Survey 26. A survey, stamped by a surveyor licensed in the State of Washington, must be provided. Response: A copy of the survey is included as requested. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -9- October 13, 2020 Public Works – Traffic Division Sarady Long, (253) 835-2743, sarady.long@cityoffederalway.com Trip Generation/TIA Comments 27. A TIA should be prepared to address potential traffic impacts to the neighborhood north of the site and the surrounding streets network. The project’s trips will also impact the South 320th Street and SR 5 ramp terminal intersections, which are under WSDOT control. The applicant should contact King County and WSDOT for TIA scoping to determine the limit of the analysis. Response: A TIA will be prepared to address WSDOT and King County concerns, as well as public comments received from several neighbors. TENW has contacted WSDOT and King County, provided them with the project information and trip generation, and has required their comments related to the TIA scope of work. 28. Update the trip generation memo to include truck trips percentage, trip distribution, and discussion of impacts on the roadway network north of the site. Response: The TIA for the project will include truck trip percentages, trip distribution, and a discussion of potential traffic impacts on the roadway network north of the site. Plan Comments: 29. Provide an ADA Compliance path from the proposed sidewalk on the north side of South 320th Street (Sta 3+30.41 – Begin Road improvements) to the northbound on-ramp pedestrian island. Contact WSDOT on the required plans submittal. Response: An ADA compliant path is now shown as requested. 30. Provide truck turning templates for the eastbound left turn from South 320th Street to 32nd Avenue South northbound. Verify a truck can make this turning movement without encroaching on the southbound through lane. Response: An updated truck turn exhibit is included with this package. 31. The submitted truck turning templates appear to show the stop line for both lanes of the southbound approach located further back than standard to avoid turning path overlap with right-turning vehicles entering 32nd Avenue South northbound. Given the full cut section of the north leg of the intersection, moving the stop line back would require prohibit right-turn-on-red movement. This restriction is not desirable due to poor compliance and inefficient signal operations. As such, 32nd Avenue South should be widened to accommodate the turning movements without encroaching on the southbound through lane. Response: An updated truck turn exhibit is included with this package. Stacey Welsh, Principal Planner City of Federal Way Department of Community Development -10- October 13, 2020 32. Revised the HOV lane on South 320th Street from 14 to 12 feet. Response: The HOV lane has been revised from 14-foot to 12-foot. 33. The intersection landing should be concrete to prevent pavement distresses and rutting from downhill truck traffic. Response: The intersection landing has been revised to concrete. 34. Provide a 28-foot wide paved street from approximately Sta 26+000 to the northerly property line. As shown, it appears the new pavement width is less than 20 feet Wide. Response: Pavement width is shown at 28-foot as required. 35. Show the 3/4 road improvement section and the 28-foot road section on the plan. Response: Road sections are shown on the plans as requested. 36. Channelization plans, illumination plan, traffic signal plans, and pavement design, etc. are conceptual for land use approval. Detailed plans will need to be submitted at the engineering stage. Response: Comment acknowledged. We believe that the above responses, together with the enclosed revised plans and technical documents, address all of the comments in your letter dated September 15, 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/bd 20833c.006.doc enc: As Noted cc: Quinn Closson, Pape Group Bart Dickson, Cobalt Development Group Howard Kimura, HG Kimura Architect PLLC Ben Eldridge, Barghausen Consulting Engineers Ali Sadr, Barghausen Consulting Engineers Betsy Dyer, Barghausen Consulting Engineers