20-102489-Retaining Wall Modification-2020-10-13-V3October 13, 2020
Stacey Welsh, Principal Planner
City of Federal Way
Department of Community Development
33325 – 8th Avenue South
Federal Way, WA 98003
RE: Request for Modification of Retaining Wall Height
Pape Kenworth Northwest
Files #20-102489-UP, 20-102490-SE and 20-102492-AD
City of Federal Way, King County, Washington
Our Job No. 20833
Dear Stacey:
This modification request has been prepared in response to the review comment provided in the
Community Development, Planning Division section of the letter dated September 15, 2020 to justify the
use of retaining walls over six feet in height. Section 19.120.120 (3) (a) FWRC states that “For
commercial and multifamily lots, rockeries and retaining wall shall be a maximum of six feet in height as
measured from finished grade at the base of wall to the top of wall”. The Pape Kenworth Northwest
project is a truck maintenance facility with areas for office, showroom and parts warehouse and a
separate structure to be used as a body shop. The property also includes a storage area for trailers that
arrive on the site in association with maintenance or repair.
The topography of the site is rolling with steep slopes and sensitive areas. The project site proposed
grades are flat as required by use for truck maneuvering and access which requires the use of retaining
walls. In order to minimize disturbance to sensitive areas and maximize use of the property, retaining
walls over six feet in height will be required. All retaining walls are designed for structural stability and will
be landscaped in accordance with city standards.
The following are justifications for approval of this modification as required by the city.
a. “There are no feasible and reasonable alternatives to the clearing, grading or tree/vegetation
removal activity being proposed;”
Response: Due to rolling topography of the site with steep slopes and sensitive areas, there
is no feasible and reasonable alternative to avoid construction of retaining walls. In order to
minimize disturbance to the sensitive area buffer and provide a reasonable and functional site
layout for the intended use of this property, retaining walls over 6-foot in height are the best
alternative. Using standard 6-foot high retaining walls would require more area of clearing
and would have an adverse impact on the site layout and reasonable use of the property for
its intended use.
b. “The proposed modification will result in the same or less impacts than meeting the
standards;”
Response: The proposed modification to use retaining walls over 6-foot high will result in
less impact to the sensitive area buffer reduction and would result in a more efficient site
layout for safer traffic movement which will be in the public interest.
Stacey Welsh, Principal Planner
City of Federal Way
Department of Community Development -2- October 13, 2020
We believe that this modification should be granted for this project, since it is demonstrated that the use
of retaining walls over six feet in height would provide maximum use of the site as proposed and would
not be detrimental to public safety. Please review at your earliest convenience and please feel free to
contact me with any questions or need additional information. Thank you.
Sincerely,
Daniel K. Balmelli, P.E.
Executive Vice President
DKB/yg
20833c.007.doc
enc: As Noted
cc: Quinn Closson, Pape Group
Bart Dickson, Cobalt Development
Howard Kimura, H.G. Kimura Architect, PLLC
Ali Sadr, Barghausen Consulting Engineers, Inc.
Ben Eldridge, Barghausen Consulting Engineers, Inc.