Al Karam Memory Care Preap SummaryCOMMUNITY DEVELOPMENT DEPARTMENT 33325 8th Avenue South Federal Way, WA 98003-6325
253-835-7000
www.cityoffederalway.com
Jim Ferrell, Mayor
August 13, 2021
Mr. Hans Korve
DMP Engineering
726 Auburn Way North
Auburn, WA 98002
hans@dmp-inc.us
Re: File #21-102624-00-PC, PREAPPLICATION CONFERENCE SUMMARY
Al Karam Memory Care and Commercial Development, 30200 Pacific Highway South,
Federal Way, King County Parcel ID – 042104 9257
Dear Mr. Korve:
Thank you for participating in the preapplication conference with the City of Federal Way’s Development
Review Committee (DRC) held July 29, 2021. We hope that the information discussed at that meeting was
helpful in understanding the general requirements for your project as submitted.
This letter summarizes comments given to you at the meeting by the members of the DRC. The members
who reviewed your project and provided comments include staff from the city’s Planning and Building
Divisions, Public Works Department, and representatives from Lakehaven Water & Sewer District and South
King Fire & Rescue. Some sections of the Federal Way Revised Code (FWRC) and relevant information
handouts are enclosed with this letter. Please be advised, this letter does not represent all applicable codes. In
preparing your formal application, please refer to the complete FWRC and other relevant codes for all
additional requirements that may apply to your project.
I, Jim Harris, am the key contact for your project and may be contacted at jim.harris@cityoffederalway.com
or 253-835-2652. For specific technical questions about your project, please contact the appropriate DRC
representative as listed below. Otherwise, any general questions about the preapplication and permitting
process can be referred to me.
PROJECT DESCRIPTION
Four-phase commercial and senior and memory care residential development. Project includes fast food, 50
units of senior living, and a memory care unit composed of a grouping of several smaller buildings. The
fourth parcel (proposed lot 3) has not yet been determined.
MAJOR ISSUES
Outlined below is a summary of the major issues of your project based on the plans and information
submitted for the preapplication review. These issues can change due to modifications and revisions in the
plans. The major issues section is only provided as a means to highlight critical requirements or issues. Please
be sure to read the comments made by all departments in the following section of this letter.
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• Planning Division
• See the information in the Planning Division comments sections 2, 5, and 7 below regarding a
height variance.
• The site is a Geologically Hazardous Area and requires a critical area review.
• There are different zoning standards for each of the various proposed uses.
• The site is adjacent to a single-family residential zoning district, which limits the height to 30 feet
maximum for a portion of the site.
• Public Works Development Services Division
• A storm system outside the City Center Core must be above ground.
• The R-Tank system may not be viable based upon preliminary Geotechnical Report.
• Public Works Traffic Division
• Transportation Concurrency Management (FWRC 19.90) – A transportation concurrency permit with the
application fee is required for the proposed project.
• Traffic Impact Fees (FWRC 19.91) – Traffic impact fees are required for commercial and senior
residential development and will be assessed at the building permit stage.
• Transportation Impact Analysis (TIA) – A TIA prepared by a licensed engineer in Washington is
required to assess other significant project impacts and determine traffic and safety mitigation
measures not identified in the concurrency analysis. The TIA shall also include trip generation to
determine the number of trips generated by the development.
• Frontage Improvements (FWRC 19.135.040) – Construct street frontage improvements and dedicate
right-of-way along the property frontage on 16th Avenue South.
• Access Management (FWRC 19.135.260) – The development shall meet access management standards.
• Intersection Sight Distance – Submit an intersection sight distance analysis consistent with the
AASHTO standard.
DEPARTMENT COMMENTS
Outlined below are the comments made by the representatives of each department present at the preapplication
conference. Each section should be read thoroughly. If you have questions, please contact the representative
listed for that section.
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COMMUNITY DEVELOPMENT – PLANNING DIVISION
Jim Harris, 253-835-2652, jim.harrise@cityoffederalway.com
1. Zoning Designation and Use – The subject property is designated Community Business (BC); the proposed use
includes a variety of uses including senior housing and memory care (FWRC 19.220.080); general
retail/office (FWRC 19.220.010), and fast food (FWRC 19.220.020). All the proposed uses are permitted in
the BC zone, but there are many different zoning standards that apply to the various uses. The senior
housing zoning standards are discussed below, as this is your proposed first phase. Please thoroughly review
the office/retail use chart (FWRC19.220.010) and the entertainment zone use chart (FWRC19.220.020) as
each use has different development standards.
2. Land Use Application – As the project triggers SEPA per the zone chart, the project requires a Process III
Land Use Application. Process III is an administrative site plan review process conducted by city staff
with a final decision issued by the Director of Community Development.
You have inquired about a potential increase in height over the permitted maximum height of 30 feet for
that portion of the site within 100 feet of a residential zone. Further details about both administrative
variances and Hearing Examiner variances are included in sections 7 and 8 below. In summary, a Process
IV Hearing Examiner land use review, including a height variance, would be required in lieu of the
Process III application. FWRC 19.70.010 states: “If the development, use or activity that requires
approval through process II or III is part of a proposal that also requires approval through process IV,
the entire proposal will be decided upon using process IV, if the director determines that will result in
more efficient decision making.”
Typically, the director has determined in circumstances like this, where a variance is requested as a
component of the site development, that the whole project is reviewed under Process IV, in order to
make more efficient decision-making.
Under Process IV, following compliance with SEPA regulations, the Community Development Director
will issue an administrative decision on the Community Design Guideline component of the project.
Following the design decision, city staff will provide a written recommendation to the Hearing Examiner
on the site plan and in this case, a height variance. The Hearing Examiner will hold a public hearing on
the application and issue a written decision on the application within approximately two weeks following
the close of the hearing.
3. State Environmental Policy Act (SEPA) Environmental Review – The project is subject to environmental review
under the State Environmental Policy Act (SEPA), as the proposal exceeds the flexible thresholds (20,000
square-foot building) pursuant to FWRC 14.15.030(1)(c). The city may utilize the optional Determination of
Nonsignificance (DNS) method of combining the land use and SEPA notifications when environmental
checklists are thoroughly completed and environmental impacts are disclosed and evaluated. The optional
DNS process can expedite the overall land use application process. An environmental threshold
determination made by the Director of Community Development must be issued prior to the land use or
building permit approval.
4. Binding Site Plan – In general, a binding site plan is a commercial property subdivision and is regulated in
FWRC 18.20.050. A binding site plan is not required, as multiple uses and buildings are allowed on
commercial zoned property. However, if an owner wants to pursue a binding site plan, then a binding site
plan may be submitted concurrent with or following a Process III land use review. A binding site plan is
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subject to the procedural and substantive requirements in FWRC 18.20. A binding site plan typically
requires public improvements as discussed in the FWRC.
5. Land Use Review Timeframes – The Planning Division will notify the applicant of the application status
within 28 days of submittal. If the application is determined complete, staff will issue a Letter of
Complete Application. The FWRC limits the administrative review to 120 days from the date of a
complete application. The 120-day review period will stop any time the applicant has been requested by
the city to correct plans, perform required studies, or provide additional information needed to issue a
decision. The review period will begin within 14 days following submittal of requested items. Please be
advised that any request for corrections and/or additional information must be provided within 180 days
of written notification, or the land use application will expire.
6. Public Notice – Process III applications and SEPA determinations require a public notice and 15-day
comment period. Within 14 days of issuing the Letter of Complete Application, a Notice of Application
will be published in the Federal Way Mirror, mailed to persons within 300 feet of the subject property,
posted on the subject property, and other notice in accord with the FWRC.
If you opt to request a Hearing Examiner height variance, then the Process IV procedures would apply
rather than Process III procedures. Many of the procedures are similar, but an additional mailing is
required for notice of the public hearing.
7. General Zoning Regulations & Key Development Regulations for Senior/Special Needs Housing – All site
improvements must comply with the applicable FWRC development regulations. The following general
regulations will apply to the proposed senior housing element of the proposal. Please consult the
appropriate zone use charts for development standards of the other potential site uses. The subject
property is within the BC zone. Senior citizen/special needs housing is a permitted use in the BC zone
subject to regulations set forth in FWRC 19.220.080. The following is only a portion of the zoning
regulations governing the proposed uses in the BC zone. The applicant should consult the referenced use
zone chart and entire FWRC prior to submitting a Master Land Use Application.
(a) Required Yard and Lot Coverage – Required minimum yard (building) setbacks for senior citizen
housing is 20 feet front, 5 feet side, and 5 feet rear yards. The side and rear setbacks default to the
minimum required perimeter landscape buffer width (if larger than the required setback). No
maximum lot coverage applies. The buildable area will be determined by other requirements for
landscaping, parking, required yards, etc.
(b) Maximum Building Height – The height allowed for senior housing is 65 feet above average building
elevation (AABE) for the portion of the site not within 100 feet of the residential zone to the west.
The center of the right-of-way is the line where the BC and Single-Family Residential (RS) zones are
distinguished. The height limitation for proximity to RS zone starts at the center of the 16th Avenue
right-of-way. A building height handout is enclosed.
The maximum building height is 30 feet above average building elevation per FWRC 19.220.080
note 2, for that portion of the site within 100 feet of a residential zone (to the west). The 30-foot
height limit applies to the area of building within 100 feet of the residential zone to the west.
The remaining portion of the site over 100 feet from the residential zone is allowed an outright
height of 65 feet above average building elevation for the senior housing use. Read closely and apply
all notes on the applicable zoning chart FWRC 19.220.080 (enclosed).
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Per FWRC 19.110.060 “Exceptions,” rooftop appurtenances may exceed the applicable height
limitation by a maximum of four feet if the area of all appurtenances and screening does not exceed
10 percent of the total area of the building footprint. These appurtenances must be located in such a
way as to minimize view blockage.
Appurtenances that do not meet the standards of this section may be permitted if the director
determines that, based on accurate graphic representations provided by the applicant, views from
adjacent properties will not be significantly affected. A written modification request to the height
limitation is required to be submitted with the Process III application.
(c) Parking – Required minimum parking stall count is 1.0 parking space per dwelling unit for senior
housing and 0.5 stalls for each unit of special needs housing. Note 4 on FWRC 19.220.080 requires a
minimum of 25 percent of the parking to be underground or on the first floor within the building
footprint when over 100 units are proposed. Please note that tuck-under open exposed parking
generally does not meet the intent of the community design guidelines. See the enclosed code section
for dimensional requirements for parking stalls.
(d) Open Space – Under FWRC 19.220.080 (note #8), open space requirements for senior citizen housing
is a minimum of 100 square feet of common open space per unit. With your application, please
provide a site plan graphic detailing the common open space areas and include a written description
of those areas intended as common open space; identify all amenities in each of the individual open
space areas. Include on the submittal drawings the size and location of each recreation area, the
intended users, and indicate whether it is interior or exterior common open space.
Again, the other proposed uses of office/retail and fast food are subject to similar, but different standards
on each zone use chart as mentioned above. Apply the standards in those charts to the proposed land uses.
8. Height Variance – In your preapplication materials, you requested information regarding the possibility
of a height variance. FWRC 19.45.015 has an option for an administrative variance, which allows a
variance up to 25 percent of the measurable standard. If this administrative height variance is proposed,
then the administrative variance would be reviewed and considered in conjunction with the Process III
land use review.
A height variance request which exceeds 25 percent of the measurable standard requires review and
approval by the Hearing Examiner under Process IV review. If a Process IV height variance is proposed,
then the whole project review (Process III) would be reviewed under Process IV Hearing Examiner
review. Pursuant to FWRC 19.15.060, where more than one application is submitted for a given
development, and those applications are subject to different levels of process, then all of the applications
shall be subject to the highest level of process that applies to any of the individual applications, and
procedures for issuance of a letter of completeness, notice of application, notice of decision, open review
record hearing, and/or appeal hearing.
Note the height standards for office retail and fast food are significantly different from height standards
for senior housing use. An administrative height increase may be applicable for a portion of the site as
discussed in FWRC 19.220.010 and .020, that would be only applicable to portions of the site more than
100 feet from the adjacent residential zone. Pursuant to note FWRC 19.220.010(1)(b), if there is any
request or proposal to exceed the applicable 30-foot height limit, then such request would render note
(1)(b) not met, and an administrative height increase up to 55 feet would not be permissible without a
Process IV Hearing Examiner variance.
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Under either variance option summarized above, the applicant must address how the requested variance
meets the decisional criteria of FWRC 19.45.030.
FWRC 19.45.030 Criteria for grant.
“The city may grant the variance only if it finds all of the following:
(1) That the variance will not constitute a grant of special privilege inconsistent with the
limitations upon uses of other properties in the vicinity and zone in which the subject property
is located.
(2) That the variance is necessary because of special circumstances relating to the size, shape,
topography, location or surroundings of the subject property to provide it with use rights and
privileges permitted to other properties in the vicinity and zone in which the subject property
is located.
(3) That the granting of the variance will not be materially detrimental to the public welfare or
injurious to the property or improvements in the vicinity and zone in which the subject property
is located.
(4) That the special circumstances of the subject property are not the result of the actions of the
owner of the subject property.”
The applicant carries the burden of proof for convincing the director or Hearing Examiner that the
requested variance meets the decisional criteria.
There were no elevations and/or specific information submitted to the city in regard to the proposed
building height. Since no height specifications and/or elevations were submitted, we are unable to
comment further on any potential variances.
You are strongly encouraged to have a follow-up discussion and meeting with staff after the preapplication
meeting to further discuss the proposed building height when you have a preliminary design and height
calculation, as well as to discuss any potential variances as your site and building design progresses.
9. Community Design Guidelines – Review of the proposal under the city’s design guidelines, FWRC Chapter
19.115, is required for the project and will occur in conjunction with the use process review. The principal
applicable guidelines for the project are noted below. However, this does not necessarily include all
applicable guidelines, and project designers must consult the guidelines in their entirety in preparing an
application. The application must include a written narrative identifying how the proposal complies with
the applicable design guidelines, as detailed.
• FWRC 19.115.010(2) CPTED – Implement Crime Prevention through Environmental Design
(CPTED) principles to reduce opportunities for criminal activities to occur. The city’s Police
Department and Planning Division will evaluate the formal application and review for compliance
with CPTED principles. A completed CPTED checklist must be submitted with your application.
i. Natural Surveillance – Promote visibility of public spaces and areas.
ii. Access Control – Identify techniques that deter unauthorized and/or
inappropriate access.
iii. Ownership – Reduce perception of areas as ownerless.
• FWRC 19.115.050 Site Design – Refer to all sections of this chapter for site design standards. Key
sections include:
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i. (1) General criteria (d), (f), and (g)
ii. (2) Surface parking lots (a), (b), (c), and (e)
iii. (4) Pedestrian circulation and public spaces (a) and (b)
iv. (5) Landscaping
v. (6) Commercial services (a)
vi. (7) Miscellaneous (a)
• FWRC 19.115.060 Building Design – Refer to all sections of this chapter for building design standards.
Key sections include:
i. (1) General Criteria (c)
ii. (2) Building façade modulation and screening options – (a), (b), and (c)
1. All building facades are both longer than 60 feet and visible from either a right-
of-way or residential use or zone and shall incorporate facade treatment
according to this section. Subject facades shall incorporate at least two of the
four options on each façade. Options intended to break up the mass of large
buildings include: (a) façade modulation; (b) landscape screening; (c) canopy or
arcade; and (d) pedestrian plaza.
2. Building facades visible from rights-of-way should incorporate methods of
articulation and accessory elements in the overall architectural design, for
example display windows, window openings with visible trim material, vertical
trellis, artwork, decorative masonry or metal patterns or grillwork, relief,
material variations, etc.
• FWRC 19.115.070 Building and Pedestrian Orientation – Requirements of this section apply to the
project (FWRC 19.115.070[1][a]).
• FWRC 19.115.090(1) District Guidelines for the Community Business (BC) Zone – Requirements of this
section apply to the project (FWRC 19.115.090[1][a] – [f]).
10. Landscaping – Landscape requirements are contained in FWRC Chapter 19.125 “Outdoors, Yards, and
Landscaping.” Following are the key landscape requirements for the project.
a) A landscape plan prepared by a Washington State licensed landscape architect shall be submitted
with the formal application. Please follow general guidelines outlined in FWRC 19.125.040(1) through
(28) when preparing the site plan and planting schedule, especially: “(22) Screening of blank building
walls. Building walls which are uninterrupted by window, door, or other architectural feature(s) listed
in FWRC 19.115.060(3)(b), that are 240 square feet or greater in area, and not located on a property
line, shall be screened by landscaping. Such planting shall include trees, shrubs, and groundcover
appropriate for the area proposed.” And “(24) All loading areas shall be fully screened from public
right-of-way or nonindustrial/manufacturing uses with Type I landscaping.”
b) Per FWRC 19.125.060(6)(c), for properties within the BC zone, Type III landscaping a minimum of
five feet in width shall be provided along all property lines.
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Depending on the site layout chosen, if parking is located near the right-of-way, then FWRC
19.125.070(5)(a) requires that a three-foot-tall berm (or increased plantings) be installed in
perimeter landscaping buffers screening parking areas from the adjacent right-of-way.
c) Parking Lot Landscaping – Twenty-two square feet of interior lot landscaping, per parking space for
lots with more than 49 stalls, must be provided in accordance with FWRC 19.125.070, “Parking Lot
Landscaping.” Type IV parking lot landscaping is required to be installed at the ends of all rows of
parking and disbursed throughout the interior parking area. The site plan must list the specific size of
each landscape island proposed for interior parking lot landscaping in order to verify the required
calculation is provided. Landscape islands must be a minimum width of six feet between stalls and at
the ends of rows. Lighting fixtures shall not replace any required interior parking lot landscaping.
11. Tree Density Requirements – A tree and vegetation retention plan as required under FWRC 19.120.040(2)
must also be submitted with the Process III or Process IV land use application. The tree and vegetation
retention/replacement plan must be prepared by a certified arborist or certified landscape architect. The
standards require each development to maintain a minimum tree unit density. As required under FWRC
19.120.130(2), the minimum tree density in the BC zone is 20 tree units per acre. The subject property’s
density would be 21 tree units (20 tree units x 1.05 acres).
A tree unit is a value assigned to existing trees retained on the property or replacement trees. The larger
the tree, the greater value it is assigned. Required tree density can be composed of retained trees and
replacement plantings per FWRC 19.120.130. The tree and vegetation plan must clearly show where the
21 tree units are to be located. The formal landscape plan must detail information about tree unit credits
and replacement.
12. Geologically Hazardous Areas – There is a significant grade difference between 16th Avenue South and the
project site. The western portion of the site likely meets the definition of a geologically hazardous area
per FWRC 19.05.070. Provide a topographical survey of the site and geotechnical report with your
application submittal. Development activity must satisfy the requirements of FWRC 19.145,
“Environmentally Critical Areas,” and specifically meet the submittal and application requirements
pertaining to geologically hazardous areas in FWRC 19.145.220 – 19.145.250.
The city requires a third-party review of critical area reports by a city contracted consultant. All third-
party reviews must be paid for and pre-funded by the project applicant.
13. Rockeries/Retaining Walls – See FWRC 19.120.120(3)-(7) for specifics about retaining wall requirements of
height, location, landscaping, and material composition.
• For commercial lots, rockeries and retaining walls shall be a maximum of six feet in height as
measured from the finished grade at the base of the wall to the top of the wall.
14. Rooftop Mechanical Equipment – Per FWRC 19.110.070, vents and similar appurtenances that extend above
the roofline must be surrounded by a solid sight-obscuring screen that is integrated into the architecture
of the building and obscures the view of the appurtenances from adjacent streets and properties. Please
provide screening details on the elevation drawings.
15. Lighting – In addition to CPTED lighting standards, the following shall apply: lighting levels shall not spill
onto adjacent properties (FWRC 19.105.030); lighting shall be provided in all loading, storage, and
circulation areas; and lighting standards shall not reduce the amount of landscaping required for the
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project (FWRC 19.115.050). A photometric lighting plan that meets the standards of the Illuminating
Engineering Society (IES) minimum outdoor light levels will be required with the Process III application.
16. Garbage and Recycling – The new buildings/uses must provide trash and recycling facilities as described in
FWRC 19.125.040(4) and FWRC 19.125.150. The trash enclosure area may not be located within
landscape buffer areas, must be screened according to the landscape chapter, and must be architecturally
consistent with the design of the primary structure on site.
17. Affordable Housing Units – A minimum of five percent of new dwelling units must be considered
affordable as defined by FWRC 19.110.010. “Affordable Units” for rental affordable housing means dwelling
units that are offered for rent at a rate that is affordable to those individuals and families having incomes
that are 50 percent or below the median county income. The formal application must reflect the
affordable housing requirement and provide details of how it will be accomplished. Note that prior to
issuance of a certificate of occupancy for any building, an agreement in a form approved by the city
requiring affordable dwelling units to remain as affordable housing for the life of the project must be
recorded with the King County Recorder’s Office by the applicant.
18. Clearing & Grading – The applicant is required to obtain clearing and grading plan approval as a
component of the use process review. Consult FWRC 19.120.040(1) for items that are required to be
included on the plan, including the anticipated amounts of cut and fill.
19. Tacoma Smelter Plume – The subject property is located in the Tacoma Smelter Plume detect area
containing less than 20 parts per million (ppm) arsenic and lead concentration in the soil. The site is in
very close proximity to a greater than 20 ppm area. Please contact Department of Ecology’s Eva Barber,
Technical Assistance Coordinator, at eva.barber@ecy.wa.gov or 360-407-7094 regarding the Voluntary
Soil Clean-Up Program.
As the site is in the less than 20 ppm area, the city will not require soil testing. However, the city
encourages soil testing and cleanup if applicable in conjunction with site review and site development.
See the Department of Ecology’s link for more information on the Tacoma Smelter Plume:
https://apps.ecology.wa.gov/dirtalert/?lat=47.304972&lon=-122.379794&zoom=13.
20. Time Limitations – Per FWRC 19.15.100(2), the applicant must substantially complete construction for
the development activity and complete the applicable conditions listed in the decision within five years
after the final decisions. Requests for time extensions may be granted by the Director of Community
Development if criteria set forth in FWRC 19.15.110 can be met.
21. Application Fees & Submittal – Please contact the Permit Center at permitcenter@cityoffederalway.com or
253-835-2607 for updated fee schedules and for applications and permits.
PUBLIC WORKS – DEVELOPMENT SERVICES DIVISION
Cole Elliott, PE, 243-835-2730, cole.elliott@cityoffederalway.com
Land Use Issues – Stormwater
1. Surface water runoff control and water quality treatment will be required per the 2016 King County Surface
Water Design Manual (KCSWDM) and the City of Federal Way Addendum to the manual. This project meets
the requirements for a Full Drainage Review. At the time of land use site plan submittal, a preliminary
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Technical Information Report (TIR), addressing the relevance of the project to the nine core and five special
requirements of the KCSWDM will be required. A Level 1 downstream analysis shall also be provided in the
preliminary TIR. The city addendum can be found at: www.cityoffederalway.com/node/1467.
2. The project lies within a conservation flow control area; thus, the applicant must design the flow control
facility to meet this performance criteria. In addition to flow control facilities, Best Management Practices
(BMP’s) are required as outlined in the KCSWDM. The project also lies within an enhanced basic water
quality area. Water quality treatment shall be designed to meet the treatment criteria of the enhanced
basic water quality menu. The city will accept treatment systems which are listed on the Department of
Ecology’s General Use Level Designation (GULD) for the required level of water quality treatment.
3. According to geotechnical report, infiltration is not a viable stormwater treatment option.
4. Detention and water quality facilities for private commercial developments outside the City Center Core
must be above ground (i.e. open pond). Underground facilities are allowed only with approval from the
City of Federal Way Public Works Department. You ask about using an “R-tank” system based upon the
submitted Geotechnical Report; this system may not be viable.
5. Show the proposed location and dimensions of the detention and water quality facilities on the
preliminary plans.
6. If more than one acre will be disturbed during construction, a National Pollutant Discharge Elimination
System (NPDES) construction stormwater permit may be required. Information regarding this permit
can be obtained from the Washington State Department of Ecology at 360-407-6048 or
http://www.ecy.wa.gov/programs/wq/stormwater/construction/index.html.
Right-of-Way Improvements
1. See the Traffic Division comments from Soma Chattopadhyay, PE fotr traffic related items.
2. If dedication of additional right-of-way is required to install street frontage improvements, the dedication
shall be conveyed to the city through a statutory warranty deed. The dedicated area must have clear title
prior to recording.
3. All stormwater treatment and detention requirements outlined above may apply to any improvements
within the public right-of-way.
4. FWRC 19.135.280 requires that driveways serving residential uses may not be located closer than 25 feet
to any street intersection. Lots and intersections within new subdivisions or short plats must be designed
to meet this standard.
Building Permit Issues
1. Engineered plans are required for clearing, grading, road construction, and utility work. Plans must be
reviewed and approved by the city. Engineering review fees are $3,158 for the first 18 hours of review for
commercial building permits. Additional review time is charged at $175 per hour. A final TIR shall be
prepared for the project and submitted with the engineering plans. Both the TIR and the plans will
require the signature/seal of a professional engineer registered/licensed in the State of Washington.
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2. In addition to engineering approval, short plats and subdivisions are required to obtain a separate permit
for grading. Details and fees may be obtained from the Building Division.
3. The Federal Way Public Works Development Standards Manual (including standard detail drawings, standard
notes, and engineering checklists) is available to assist the applicant’s engineer in preparing the plans and
TIR on the city’s website at: www.cityoffederalway.com/node/1467.
4. Bonding is required for all street improvements and temporary erosion and sediment control measures
associated with the project. The bond amount shall be 120 percent of the estimated costs of the
improvements. An administrative fee deposit will need to accompany the bond to cover any possible
legal fees in the event the bond must be called. Upon completion of the installation of the improvements,
and final approval of the Public Works Inspector, the bond will be reduced to 30 percent of the original
amount and held for a two-year maintenance period.
5. The developer will be responsible for the maintenance of all storm drainage facilities (including the
detention and water quality facilities) and street systems during the two-year maintenance period. During
that time, the Public Works Inspector will make periodic visits to the site to ensure the developer’s
compliance with the maintenance requirements. Upon satisfactory completion of the two-year
maintenance period, the remainder of the bond will be released. Maintenance for public roads and
subdivision drainage facilities then become the responsibility of the city. Maintenance for private roads
and drainage facilities, including short plats, remain the responsibility of the individual property owners.
6. When topographic survey information is shown on the plans, the vertical datum block shall include the
phrase “DATUM: N.G.V.D.-29” or “DATUM: K.C.A.S.,” on all sheets where vertical elevations are
called out.
7. Drawings submitted for plan review shall be printed on 24″ x 36″ or 22″ x 34″ paper. Site plans shall be
drawn at a scale of 1″ = 20′, or larger. Architectural scales are not permitted on engineering plans.
8. Provide cut and fill quantities on the clearing and grading plan.
9. Temporary Erosion and Sediment Control (TESC) measures, per Appendix D of the 2016 KCSWDM,
must be shown on the engineering plans.
10. The site plan shall show the location of any existing and proposed utilities in the areas affected by
construction.
PUBLIC WORKS – TRAFFIC DIVISION
Soma Chattopadhyay, PE, soma.chattopadhyay@cityoffederalway.com
Transportation Concurrency Analysis (FWRC 19.90)
1. A concurrency permit will be required with land use application. At that time, the PW Traffic Division
will perform a concurrency analysis to determine if adequate roadway capacity exists during the weekday
PM peak period to accommodate the proposed development. Please note that supplemental
transportation analysis and concurrency mitigation may be required if the proposed project creates an
impact not anticipated in the six-year Transportation Improvement Plan (TIP). However, a Binding Site
Plan (BSP) is exempt from concurrency.
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2. The concurrency applicant fee must be paid in full at the time the concurrency permit application is
submitted with the land use application. The fee is based on the new weekday PM peak hour trips as
identified in the concurrency trip generation. The applicant has the option of having an independent
traffic engineer prepare the concurrency analysis consistent with city procedures; however, the fee
remains the same.
3. Staff is unable to determine trip generation for the proposed development using the Institute of
Transportation Engineers ITE’s Trip Generation due to the incomplete data, and more specific land uses
are required to be provided. The applicant’s traffic engineer may submit a trip generation study to
determine the number of trips generated by the proposed development. At a minimum, the trip
generation study shall include three studies for similar land use and settings. The methodology for
determining the trip generation shall be based upon the guidelines established in the most recent edition
of the ITE Trip Generation Handbook.
4. The estimated fees for the concurrency permit application are $1,801 (1 - 10 trips), $5,167 (11 - 50 trips),
$9,452 (51 – 500 trips), and $15,152 (greater than 500 trips). The fee for the concurrency application will
be based on the total new trips the development is estimated to generate. The concurrency application
fee must be paid in full at the time the concurrency permit application is submitted with the land use
application. The fee may change based on the new weekday PM peak hour trips as identified in the
concurrency trip generation. The applicant has the option of having an independent traffic engineer
prepare the concurrency analysis consistent with city procedures; however, the fee remains the same.
Transportation Impact Fees (TIF) (FWRC 19.91)
1. The proposed project is a four phased commercial and senior residential development. The uses are not
yet been determined in order to estimate the traffic impact fees. However, according to the fee schedule
for 2021, the rate for senior living is $1710/dwelling unit, assisted living nursing home is $2736/bed, fast
food restaurant is $66.66/square feet, and administrative office is $8.43/square feet. Please note, the
actual impact fee will be calculated based on the fee schedule in effect at the time a completed building
permit application is filed and paid prior to permit issuance (FWRC 19.100.070[3][a]).
Transportation Impact Analysis (TIA) (FWRC 19.135)
1. A Transportation Impact Analyses (TIA) to identify transportation impacts of development projects and
provide appropriate mitigation measures is required. The TIA shall assess additional project impacts
beyond those that were identified under the concurrency permit process conducted by the city. Mitigation
improvements necessary beyond those identified in the TIP to meet the city’s adopted level-of-service
standards shall be provided by the applicant.
2. A TIA prepared by engineer licensed in the state of Washington is required for this development project.
The engineer should contact the Traffic Division for a scoping sheet in the initial stages of their study.
The TIA should include the following analysis:
Analysis of intersections impacted by 100 trips in the weekday morning and Saturday peak hours.
Queuing analysis of access points for morning, evening, and Saturday peak hours.
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Street Frontage Improvements (FWRC 19.135)
1. Based on the available records and the submitted materials, it appears that this proposal meets the 25
percent threshold criteria for requiring street frontage improvements as identified in FWRC 19.135.030.
The applicant/owner may submit an appraisal for the subject property, or King County Assessor’s
records may be used. The Public Works Development Services Division will evaluate the submitted
appraisal data to determine if the project actually meets the city’s 25 percent threshold for requiring street
frontage improvements.
2. The applicant/owner will be expected to construct street improvements consistent with the planned
roadway cross-sections as shown in Map III-4 in Chapter III of the Federal Way Comprehensive Plan
(FWCP) and Capital Improvement Program (CIP) shown as Table III-10 (FWRC 19.135.040). Based on
the materials submitted, staff conducted a limited analysis to determine the required street improvements.
The applicant will be expected to construct improvements on the following streets to the city’s planned
roadway cross-sections:
SR-99 is a Principal Arterial planned as a Type “A” street, consisting of a 90-foot street with curb
and gutter, 6-foot planter strips with street trees, 8-foot sidewalks, and street lights in a 124-foot
right-of-way. The Pacific Highway South frontage is built to the planned cross section Type A.
Therefore, no right-of-way dedication and improvements are required.
Sixteenth Avenue South is a Minor Collector planned as a Type “R” street, consisting of a 40-foot
street with curb and gutter, 6-foot sidewalks with street trees, and streetlights in a 66-foot right-of-
way. Assuming a symmetrical cross section, a three-foot right-of-way dedication and half street
improvements are required as measured from the street centerline.
3. The applicant may be required to dedicate additional right-of-way to accommodate additional turn lane
improvements if identified in the transportation impact analysis and/or property corner radius.
4. The applicant may make a written request to the Public Works Director to modify, defer, or waive the
required street improvements (FWRC 19.135.070). Information about right-of-way modification requests
are available through the Public Works Development Services Division. These modification requests
have a nominal review fee currently at $500.00.
5. Tapers and transitions beyond the project frontage may be required as deemed necessary for safety
purposes, taper rate shall be WS^2/60, or as directed by the Public Works Director.
Access Management (FWRC 19.135)
1) Access management standards are based on roadway safety and capacity requirements. FWRC 19.135.280
provides access standards for streets based on planned roadway cross-sections. Please note that access
classifications are per Drawing 3-1A in the Public Works Development Standards.
2) WAC 468-52-040 limits access on state highways to access spacing of 250 feet with only one access per
parcel. Pacific Highway South is access class “1” where left access may be permitted every 330 feet and
left-out access is only permitted at signalized intersections (FWRC 19.135.280). The access is right-in
right-out only at Pacific Highway South.
3) Please show all neighboring driveways within 150 feet of the proposed driveway(s).
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4) Per FWRC 19.135.280, there may be only one driveway for each 330 feet of lot frontage. This property
has more than 660 feet minimum street frontage to allow a second access. Additionally, the driveway
must be located no closer than 150 feet to any street intersection or to any other driveway, whether on or
off the subject property on 16th Avenue South.
5) This property has a third access which is an access easement to the south from the adjoining commercial
strip mall. For better internal circulation, city staff encourages the applicant to provide an easement to the
south property for the proposed driveways.
6) The director may grant a modification administratively to reduce spacing standards by up to 20 percent
of the tabular values with supporting documentation (FWRC 19.135.290). Please note that these
modification requests have a nominal review fee of $500. Once the preliminary traffic queuing analysis
has been completed, the applicant’s traffic engineer may submit a written request for access modification
if desired.
7) For driveways that serve uses other than single-family residential uses and zero lot line townhouse
developments, the maximum driveway width is 30 feet for a two-lane two-way driveway and 40 feet for a
three-lane two-way driveway (FWRC 19.135.270). Driveway widths may be increased in order to provide
adequate width for vehicles that may be reasonably expected to use the driveway, as determined by the
Public Works Director.
8) With the exception of single-family residential driveways, a minimum driveway throat length of 40 feet is
required as measured from the face of the curb to the first conflicting circulation aisles or parking space.
Driveways accessing roadways with a speed limit greater than 35 mph may be required to provide a 50-
foot throat length.
9) Submit an intersection sight distance analysis for the design vehicle used at the plat access driveway with
16st Avenue South. The analysis shall be conducted in accordance to the latest AASHTO guidelines (3.5
feet object height, 3.5 feet driver’s eye height, and 14.5 feet back from the edge of the traveled way for
passenger vehicles). The analysis must bear the seal of a licensed engineer in the state of Washington. The
sight distance triangle shall be depicted on the plan set.
10) Please provide photo documentation within the appendix of the sight distance analysis. A minimum of one
photo looking to the left and one looking to the right will show the location of the viewer in accordance to
AASHTO guidelines. The site plan with plan and profile sheets should also be incorporated into the report
to provide the site distance documentation. Indicate if there are any street trees, landscaping requirements,
or any other objects existing or proposed to be within the sight distance triangle. State if the sight distance
requirements are met or not and provide any traffic safety mitigation measures.
Miscellaneous Safety Related Comments
1. The applicant must submit a Vehicle Turning Diagram to the Public Works Traffic Division. This diagram
will show how the appropriate design vehicle (such as: bus, garbage truck, and WB-62) can enter, maneuver,
and leave the site without encroaching onto opposing traffic lanes or mounting a curb.
2. Please submit the analysis showing the drive-through storage length is adequate to meet the expected
demand so that traffic will not back up in city street.
3. The application should be forwarded to King County Metro for any transit requirements.
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PUBLIC WORKS – SOLID WASTE AND RECYCLING DIVISION
Rob Van Orsow, 253-835-2770, robv@cityoffederalway.com
Solid Waste & Recycling Design Considerations
• Provide adequate space allocation for interior and exterior garbage, recycling, food waste, waste oil, yard
debris, hazardous waste, and/or biohazard collection containers. Minimum enclosure area is established
by FWRC 19.125.150(7)(a). The FWRC requires that plans allow access to containers for both occupants
and haulers.
• Basic solid waste and recycling services typically include two “dumpster” containers situated side-by-side
within a single trash enclosure. With gate doors open, 18 feet of clearance width is required; no structures
(such as gate posts) are allowed across the enclosure opening. Gate pins/holes are preferred to hold gates
closed or open (to allow service access and preserve gate hardware).
• Plan unobstructed access for service vehicles, in-line with enclosure openings. Allow appropriate paved
turning area for service vehicles, minimizing “blind spots” during ingress and egress.
• Per FWRC 19.125.150(7)(e), sites may require a larger enclosure, or multiple enclosures, to accommodate
on-site user access and/or additional waste types and containers.
• Per FWRC 19.125.150(6)(d), depending on enclosure size, surface water run-off must be managed via an
oil-water separator, while large enclosures require a roof combined with a drain to sanitary sewer. A related
Spill Prevention Plan is also required.
• Landscaping and screening requirements are established in FWRC 19.125.040(4) and (5).
COMMUNITY DEVELOPMENT – BUILDING DIVISION
Greg Kirk, 253-835-2621, greg.kirk@cityoffederalway.com
1. Building Codes. The structure will be treated as a new building permit application and must meet all current
codes, including:
• International Building Code (IBC), 2018
Washington State Amendments WAC 51-50
• International Mechanical Code (IMC), 2018
Washington State Amendments WAC 51-52
• International Fire Code (IFC), 2018
Washington State Amendments WAC 51 -54
• Uniform Plumbing Code (UPC), 2018
Washington State Amendments WAC 51-56
& WAC 51-57
• National Electric Code (NEC), 2017
• Accessibility Code (ICC/ANSI A117.1), 2009
• International Residential Code, 2018
Washington State Amendments WAC 51-51
• Washington State Energy Code, 2018 WAC 51-11
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2. Building Criteria. The following applies to the proposed structure:
• Occupancy Classification:
• Type of Construction:
• Floor Area:
• Number of Stories:
• Fire Protection:
• Wind/Seismic: Basic wind speed 85 Mph,
Exposure, 25# Snow load, Seismic Zone D-1
3. Building Permit Application Process. A completed building permit application and commercial checklist are
required. The commercial checklist will be completed by staff and provided at the time of land use
approval. Copies of application and checklist may be obtained at www.cityoffederalway.com.
Appointments are required for intake of new commercial building permit submittals. Please schedule an
intake appointment with the Permit Center staff at permitcenter@cityoffederalway.com or (253) 835-2607.
Some projects may require a third-party review or inspection. The cost to cover these fees is the
responsibility of the applicant. Any third-party fee is in addition to regular permit fees and costs.
Please note, land use approval is recommended prior to submitting the building permit application to
avoid delay in project review. If the project has not received land use approval, it may be placed on hold
until the land use review is completed.
4. Review Timing. Federal Way reviews plans on a first in, first out basis; however, there are some small
projects with inconsequential review requirements that may be reviewed out of order.
The first comment letter can be expected within five to seven weeks of the submittal date. Re-check of
plans will occur in one to three weeks after re-submittal.
Revised or resubmitted plans shall be provided in the same format, size, and amount as the originally
submitted plans. Revised/resubmitted drawings shall indicate by means of clouding or written response,
what changes have been made from the original drawings. You or your representatives will be required to
affix the city’s date stamp on each page of resubmitted plans and to collate loose plans into existing plan
sets. Plans for all involved departments will be forwarded from the Community Development Department.
5. Other Permits & Inspections. Separate permits may be required for electrical, mechanical, plumbing, fire
suppression systems, and signs. Applicants may apply for separate permits at any time prior to
commencement of construction.
When required, special inspections shall be performed by WABO approved agencies or by agencies
approved by the building official prior to permit issuance. Construction must be approved by all
reviewing departments prior to final building division inspection. All concerned departments (planning,
public works, electrical, & fire) must sign off before the Building Division can final the structure for
occupancy. Building final must be approved prior to the issuance of a Certificate of Occupancy.
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Construction projects may be required to have a pre-construction conference. If a pre-con meeting is
required, the general or representative, all subs, the architect or representative, the engineer or
representative, electrical contractor, and any other interested party, should attend this meeting. Meetings
will occur at the Building Division and will be scheduled by the inspector of record for the project.
The information provided is based on limited plans and information. The comments provided are
not intended to be a complete plan review and further comments are possible at time of building
permit plan review.
LAKEHAVEN WATER AND SEWER DISTRICT
Brian Asbury, 253-946-5407, basbury@lakehaven.org
General
• All Lakehaven development engineering related application forms, and associated standards information,
can be accessed at http://www.lakehaven.org/204/Development-Engineering.
• 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.
Water
• A Water Certificate of Availability issued separately by Lakehaven may be required to be submitted with any
land use and/or building permit application (check with the 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 2021 cost for a Water Certificate of Availability is $40.00.
• A Lakehaven Developer Extension (DE) Agreement will be required to construct new, abandon, and/or
modify existing water distribution system facilities for the proposed development, including extend-to-far-
edge(s), in accordance with long-standing Lakehaven policy. 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.
• A water service connection application submitted separately to Lakehaven is required for each new service
connection to the water distribution system, 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. Separate
water service connections/meters shall be installed for mixed uses within structures that are incompatible for
billing purposes (i.e., single-family residential, multi-family residential. and/or non-residential).
• To satisfy premise isolation requirements, the installation and satisfactory testing of an approved backflow
prevention assembly (BPA) adjacent to each domestic and irrigation service meter is required pursuant to
WAC 246-290-490 and Lakehaven standards regarding premise isolation. With low health cross-connection
hazards, either a double check valve assembly (DCVA) or a reduced pressure backflow assembly (RPBA) is
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required. For fire-protection, and presumably as a low cross-connection hazard, an aboveground double check
detector assembly (DCDA) or an aboveground reduced pressure detector assembly (RPDA) is required for
three-inch and larger fire protection service connections; for two-inch and smaller fire protection service
connections, a separate full-flow meter with an aboveground DCVA or an aboveground RPBA is typical.
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.
• 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).
• Based on the proposal submitted, preliminary estimated Lakehaven water service connection fees, charges,
and/or deposits (2021 schedule) will be as follows. Actual connection charges will be determined upon submittal
of service connection application(s) to Lakehaven. Connection charges are separate from any DE fees, charges,
and/or 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.
o Water Service/Meter Installation-Domestic & Irrigation, ⅝″ x ¾″ to 2″ size range: $484.88-$1,066.73 fee
(per meter drop-in). Actual sizes to be determined by Lakehaven based on the applicant’s estimated
maximum GPM usage rates. Also, most fire-protection, flow-detection-only meters are ⅝″ x ¾″ size.
o Capital Facilities Charge(s)-Water: $4,674.71 per Equivalent Residential Unit (ERU). Each MFR unit
equals 0.75 ERU. Actual non-residential amount(s) due will be determined by Lakehaven based on the
applicant’s estimated annual total water usage rate.
Sewer
• A Sewer Certificate of Availability issued separately by Lakehaven may be required to be submitted with any
land use and/or building permit application (check with the 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 2021 cost for a Sewer Certificate of Availability is $40.00.
• A Lakehaven Developer Extension (DE) Agreement will be required to construct new, abandon, and/or
modify the existing sanitary sewer system facilities necessary for the proposed development, including
extend-to-far-edge(s) in accordance with long-standing Lakehaven policy. 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.
• 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 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, installation of an
externally-located grease interceptor is required for all new restaurants and/or buildings with food
preparation/service establishments, size to be determined by the applicant’s engineer. Also, if applicable, see
the enclosed Lakehaven Trash/Recycling Enclosure Standards.
• The associated DE Agreement must achieve a point of either substantial completion or acceptance, as
determined by Lakehaven prior to activating any new sewer service connection(s).
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• Based on the proposal submitted, preliminary estimated Lakehaven sewer service connection fees, charges,
and/or deposits (2021 schedule) will be as follows. Actual connection charges will be determined upon submittal
of service connection application(s) to Lakehaven. Connection charges are separate from any DE fees, charges,
and/or 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.
o Sewer Service Connection Permit: $377.13 fee (per building).
o Capital Facilities Charge(s)-Sewer: $4,614.93 per ERU. Actual amount due will be determined by
Lakehaven based on the applicant’s estimated annual domestic/commercial/industrial only water usage
rate. Sewer system capacity credits are available for this property from system capacity charges previously
assessed to the property for 17.76 ERU. Please contact Lakehaven for further detail.
SOUTH KING FIRE AND RESCUE
Sean Nichols, 253-946-7242, sean.nichols@southkingfire.org
Water Supply
Fire Flow
A Certificate of Water Availability shall be requested from the water district and provided at the time of the building
permit application.
Fire Hydrants
Approximately two additional hydrants will be required for this site. Possibly additional may be required. Fire
hydrants shall be in service prior to and during the time of construction.
Emergency Access
Fire apparatus access roads shall comply with all requirements of Fire Access Policy 10.006
http://southkingfire.org/DocumentCenter/Home/View/24. Fire apparatus access roads shall be installed and
made serviceable prior to and during the time of construction. The grade for commercial property access roads
cannot exceed 12 percent.
Note
Due to the proposed occupancy, an elevator that can fit a stretcher lying flat will be required. Additional
requirements will be noted when a full or more comprehensive set of plans are submitted.
CLOSING
This letter reflects the information provided at the preapplication meeting and is intended to assist you in
preparing plans and materials for a formal application. We hope you found the comments useful to your
project. We have made every effort to identify major issues to eliminate surprises during the city’s review of
the formal application. The completion of the preapplication process in the content of this letter does not vest
any future project application. Comments in this letter are only valid for one year as per FWRC 19.40.070(4).
This is a preliminary review only and does not take the place of the full review that will follow submission of
a formal application. Comments provided in this letter are based on preapplication materials submitted.
Modifications and revisions to the project as presented for this preapplication may influence and modify
information regarding development requirements outlined above. In addition to this preapplication letter,
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please examine the complete FWRC and other relevant codes carefully. Requirements that are found in the
codes that are not addressed in this letter are still required for your project.
If you have questions about an individual comment, please contact the appropriate department representative
noted above. Any general questions can be directed towards me, the key project contact Jim Harris, at 253-
835-2652, or jim.harris@cityoffederalway.com. We look forward to working with you.
Sincerely,
Jim Harris
Senior Planner
enc: Master Land Use Application
Lakehaven Facilities Map
Process III Development Submittal Requirements Checklist
Parking Stall Dimension Handout
FWRC 19.220.010
FWRC 19.220.020
FWRC 19.220.080
Binding Site Plan Handout
Building Height Handout
GHA Handout
Variance Handout
CPTED Checklist
UP3 and UP 4 Handouts
Tree Unit Calculation Handout
Lakehaven Documents
c: Cole Elliott, Public Works Development Services Manager
Soma Chattopodhyay, Public Works Traffic Engineer
Brian Asbury Lakehaven Water & Sewer
Sean Nichols, South King Fire & Rescue
saadmohi@googlemail.com