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