20-103453-Zoning questions and responses_09-11-2020 v1Redondo Heights Zoning Code
Questions, Clarifications, Responses, Answers List
Updated 9/10/2020
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Below is an ongoing list of Zoning Code Questions the applicant has had since beginning the project
and responses from individuals at the City.
The applicant recognizes no answer is final until a complete land use application is made and
approved. However hopefully this ongoing team effort will prove an efficient process for all.
Code Section References Refer to Federal Way Revised Code (FWRC) unless noted otherwise.
Average Building Elevations (ABE)
1. Subject: Average Building Elevation calculation for a site with multiple structures.
FWRC 19.05.010 “Average building elevation (ABE)” means the average of the highest and
lowest existing or proposed elevations, whichever is lowest, taken at the base of the exterior
walls of the structure, or it means five feet above the lowest of the existing or proposed
elevations, whichever is lowest. ABE is the elevation from which building height is measured.
Question 1A: We believe the portion of the above which states “or it means five feet above
the lowest of the existing or proposed elevations” means that in no case shall the ABE grade
any lower than 5’ above the lowest elevation (the lowest of proposed or existing, taken at the
base of the exterior walls of the structure).
Please confirm or correct the above interpretation
1A Doc Response: Yes, you are correct. Elevation is going to be most important for the whole
planned site, even if schematic, so that we can come up with the most accurate answer to this
question. I will want the Building Official to weigh in on this as well.
Question 1B: This is a large undeveloped site with no roads that appears to have had
significant cuts and fills creating several “holes” and “drop-offs. Creating roads and useable
and accessible building pads for this affordable multi-building housing project will require
significant regrading and hopefully, to minimize material hauling, a balanced cut and fill.
Having to measure a 30’ or 35’ building height from some of these existing deep holes will
make it impossible to develop these portions of the site. In similar situations we have been
allowed to create a grading plan for the roads and building plans that then becomes “existing
and finish grade” for purposes of height measurement of new buildings, vastly simplifying the
design (and review) process.
Would this be an acceptable approach to solving this problem?
1B Doc Response: Height will be measured by finished grade in this case, not by existing
topography.
Redondo Heights Zoning Code
Questions, Clarifications, Responses, Answers List
Updated 9/10/2020
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Lot Coverage
2 Subject: Lot coverage calculation with pervious paving.
FWRC 19.110.020 “...the area of all structures, pavement and any other impervious surface
on the subject property will be calculated as a percentage of total lot area.”
Question 2: We assume that where some form of pervious pavement is used, this pavement
would not be considered impervious and therefore would not be considered as lot coverage.
Please confirm or correct the above interpretation
2 Doc Response: Any surface that is pervious, existing or new, will be considered in
stormwater evaluation and in meeting zoning requirement. You may know that gravel is not
considered pervious in stormwater calculation. We will want to have public works determine if
a surface is pervious or impervious. Graveled areas, or portions of graveled areas (possibly
only 50% of the area) are not considered pervious.
Question 2B: To manage stormwater runoff, we are looking into green roof, which helps in
stormwater retention.
Does the City allow to use green roof in lot coverage and stormwater calculation?
2B Doc Response: No.
Question 2C: What is public works determination of what is considered pervious vs.
impervious?
2C Response: XXX
Height Limit
3 Subject: Roof Appurtenances definition
FWRC 19.110.060 “Rooftop appurtenances may exceed the applicable height limit by Max
4'-0".”
Question 3A: We find no definition of Rooftop appurtenances, so assume the following ar e
considered “rooftop appurtenances:
a. Parapets
b. railings
c. Rooftop planters
d. Roof rakes
e. elevator or stair penthouses
f. Mechanical equipment
Please confirm or correct the above interpretation
3A Doc Response: All you list are considered appurtenances. Some of my planners may
disagree with ‘planters’ being appurtenances and should be considered part of the height,
however, I consider such as appurtenances as long as they are not ‘near’ the edge of the
building or visibly seen from the ground approximately 50 feet, or across the parking lot.
Please remember that Code requires appurtenances limited to 10% of the rooftop area.
Redondo Heights Zoning Code
Questions, Clarifications, Responses, Answers List
Updated 9/10/2020
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Roof
4 Subject: multi-family building roof
FWRC 19.205.060 special regulations and notes 2 “All buildings must be gabled with pitched
roofs.”
Question 4: Enhanced State Energy codes requirements, and particularly those aimed at
minimizing infiltration increasingly make the traditional form of construction with gabled
trusses with batt insulation between the bottom cord virtually impossible. Insulation and roof
membrane and rigid insulation are now most effectively placed above the roof sheathing.
This has also led to use of roofs for green roof, often accessible adding to open space.
Obviously decks and terraces have never been required to have a “gabled roof” above them.
In fact “Rooftop terraces” are specifically encouraged in this kind of development in section
FWRC 19.205.040. We assume such rooftop terrace is not required to have a gabled roof
above it.
Considering the reality of the energy code noted above, and in an effort to create a more consistent
design approach, could structures with significant accessible terraces be allowed to waive the
requirement to add gables to those portions that are not accessible terraces?
4 Doc Response: We will have to work on this. The Code states that ‘all roofs shall be
gabled.’ This, of course, is design oriented and intended to fit with possible single family
structures and zones. The definition of ‘gabled’ can be worked to achieve some of what is
intended here. As an architect, you might come up with some design that is going to achieve
this intended visual function while providing the intended and function of green roof.
Open Space
5 Subject: open space definition and calculation
FWRC 19.05.010 “Open space” means an area of land that is valued for natural processes
and wildlife, for agricultural production, for active and passive recreation, and/or for
providing other public benefits. In certain cases, open space may refer to both outdoor and
indoor spaces that provide active or passive recreational amenities for a development’s
occupants or users.
Question 5A: We assume “areas of land ..for wildlife” would include any area of vegetation
at grade or above grade.
Please confirm or correct the above interpretation
5A Doc Response: Yes
Question 5B: We assume indoor spaces that provide active or passive recreational amenities
for a development’s occupants or users would include all areas within the Community
Building(s). These buildings will be available to all residents for variety of uses.
Please confirm or correct the above interpretation
5B Doc Response: Yes
Redondo Heights Zoning Code
Questions, Clarifications, Responses, Answers List
Updated 9/10/2020
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Open Space in Multi-family Project
6 Subject: open space definition and calculation in RM Zone multi-family projects
FWRC 19.205.040 The subject property must contain at least 400 sq. ft. per dwelling unit of
usable open space6A usable for many activities and may include common open spaces such
as plazas, recreation rooms, rooftop terraces, p-patches, pools, active lobbies, and atriums. A
minimum of 25 percent of the usable open space provided must be common open space.
Private open space such as a patio, porch, balcony, or yard may be credited toward total
residential usable open space, if such private open space is a minimum of 48 square feet and
has a minimum dimension of six feet.
Question 6A: As pea patches and yards are specifically noted as Useable Open Space in the
above, we assume “useable”, when outdoors, would include any “visually useable” softscape
and hardscape areas”
Please confirm or correct the above interpretation
Doc Response: I have to see what you have in mind here.
Doc Response (8/6/2020): Surface stormwater detention pond may be considered Usable
Open Space if the area can be accessed by walk path, bridges, etc.
At least 10 percent of this required open space must be developed and maintained with
children’s play equipment6B. If the subject property contains four or more units, this required
open space must be in one or more pieces each having a length and width of at least 25 ft. In
addition6D, if the subject property contains 20 or more units, at least 50 percent of this
required open space6C must be in one or more pieces each having a length and width of at
least 40 ft.
Question 6B and 6C: We assume that that “this required open space”, refers to the common
open space, not the total open space.
Please confirm or correct the above interpretation
Doc Response: Correct
Question 6D: We assume that a site with 130 units only needs to comply with the
requirements for 20 or more units, not both requirements for 4 or more and 20 or more.
Please confirm or correct the above interpretation
6 D Doc Response: Correct
Parking
7 Subject: reduction of the required parking numbers and parking space dimensions
FWRC 19.130.010 & 19.205040 “A decrease in the required number of parking spaces
under FWRC 19.130.020 may be permitted if a thorough parking study documents that fewer
parking spaces will be adequate to fully serve the uses.
Question 7A: The site is within one half mile of the Sound Transit Star Lake Link Station
(currently under construction) and within walking distance of many services, including a
Safeway. With nearby light rail, more walkable services will be developed and alternate transit
Redondo Heights Zoning Code
Questions, Clarifications, Responses, Answers List
Updated 9/10/2020
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modes to the station and services provided in the near future. This affordable housing project
seeks to be a Transit Oriented Development.
Based on these facts may a decrease in required parking be considered? If further study is required
please provide guidance on what should be studied.
Bulletin #042 Parking Lot Design Criteria
7A Doc Response: Reduced parking is only addressed in TOD in the City Center-Commercial
and City Center-Frame zone. Reduced parking is justified but will have to be addressed within
a separate parking study. A study from a similar situation (TOD and related reduced parking
need) has been accepted before.
Question 7B: The above stall depths and aisle widths are greater than required when the
Silver Shadows was built. Wide roads encourage cars to go fast, eliminate potential open
space and increase construction import.
Based on the desire to create more sustainable affordable housing project, may the stall depths and
aisle widths be reduced to 54’ for a double loaded 90 degree parking module?
7B Doc Response: We don’t have control over the width of pavement or parking lot dimension
requirements. Some other form of speed reduction would have to be used such as speed
bumps or decreased access between areas where no parking exists. Public Works is going to
be heavily involved in the final design of parking lots and they should be consulted on this.
Redondo Heights Zoning Code
Questions, Clarifications, Responses, Answers List
Updated 9/10/2020
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Yards/Landscape Buffer
8 Subject: yard and landscape buffer between existing and new developments
FWRC 19.205.040 Multifamily Dwelling Units: required yards: side 5 feet;
FWRC 19.125.060 (3) landscape requirements by zoning district RM. (c) type III landscape 10
feet in width shall be provided along all perimeter lot lines…”
FWRC 19.125.040 (27) “Landscaping shall not be required along interior lot lines within a
development where parking is being shared.”
Question 8: Shelter Resources owns the new construction site and the existing Silver Shadows
site to the east, and intent to make the two sites as one development. The sites will have
vehicle and pedestrian connections. The tenants of both sites will be under the same
management and share all the common use amenities, including parking. The two sites shall
be visually connected.
Based on these facts, may we consider the lot line between the two sites an interior lot line within a
development and eliminate the need of yard and landscape buffer at this location?
8 Doc Response: No landscaping will be required between the buildings. We will consider it a
separate phase of the same development.
Solid Waste Storage
9 Subject: Solid waste storage requirements
FWRC 19.125.150 (7) (a) (ii) Space and access requirements: In addition to the requirement
in subsection (7)(g) of this section, plans for stacked multifamily dwelling units shall require
designated interior solid waste accumulation or storage areas on each level, including details
on how solid waste is conveyed to shared storage space(s).
Question 9A: The proposed 2 or 3-story apartment buildings are not served by elevator.
Storage inside building on every level requires additional staff to collect and transport the solid
waste to outdoor storage enclosure to be picked up by waste management service. Adding
elevator or trash chute in this type of small low-rise building is not economical, especially for
an affordable project like this.
Based on these facts, may we eliminate the solid waste storage inside the building?
9A Doc Response: Need to review waste management plan to decide.
FWRC 19.125.150 (7) (d) (vi) The storage space(s) shall be no more than 150 feet from the
common entrance(s) to residences and/or service entrances to nonresidential buildings
Question 9B: to minimize the pickups and traffic driving thru the site, we propose to use a
compactor at a centralized location. This also helps to conserve open space on the site.
Based on these facts, will the City consider one centralized solid waste storage/collection location for
this site?
9B Doc Response: I would like to see a conceptual plan that clarifies the intent of outdoor
compactors and corrals and a waste management plan.
Redondo Heights Zoning Code
Questions, Clarifications, Responses, Answers List
Updated 9/10/2020
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Adjacent Property Zone
10 Subject: zone of the property south of this site
FWRC 19.205.040.5 Multifamily Dwelling Units: If any portion of a structure on the subject
property is within 100 ft. of a single-family residential zone, then that portion of the structure
shall not exceed 30 ft. above average building elevation and the structure shall be set back a
minimum of 20 ft. from the property line of the residential zone.
Question 10A: Properties to the South are generally zoned BC. However a narrow (about
50’ wide) strip, which appears to be for access, is zoned RS-7.2 and runs the entire 330’
length of the south property line. It is questionable if a330’ x 50 strip is really a buildable
single family lot and would seem odd to buffer it from a 3 story building on the north while a
much larger BC zoned structure could be built to the south.
Is there any possible mitigation of the requirement for only 2 story structures within 100’ of this strip?.
10A Doc Response: The best approach to this is a variance request. It should be filed at the
time of building permit intake, for Process II, administrative review. Provide draft supporting
document for review.
FWRC 19.45.015 Administrative Variance: The community development director may grant a
variance that does not exceed 25 percent of the measurable standard.
Question 10B: A request to allow 5 additional feet to construct a 35 foot tall building instead
of the 30 foot tall building allowed within a 100’ of a SF zone does not exceed 25% of the
measurable standard. (5/30 = 16%)
Please confirm or correct the above interpretation
10B Response: