21-102066-UP-Modification Request for Landscape Buffer-11-24-2021-V1
EJ Walsh, P.E.
Director of Public Works
City of Federal Way
Department of Community Development
33325 – 8th Avenue South
Federal Way, WA 98003
RE: Modification Request to Public Works Development Standards for Landscape
Buffer
Smith Brother’s Farms – Federal Way
Southeast Corner of 9th Ave. S and S. 344th St.
City of Federal Way, King County, Washington
Our Job No. 21537
Dear Mr. Walsh:
This modification request has been prepared in response to the review comment provided in the Public
Works – Planning Division section of the letter dated September 10th, 2021, to justify a modification of the
landscape buffers along the perimeter of the project site. This modification would allow for perimeter
landscape strips to be less than the standard 10 feet from the property line, and additional landscaping will
be provided in the reduced areas to provide a harmonious landscape.
The requested modification would be consistent with the requirements specified under FWRC
19.125.100 Modification Options.
The following are justifications for approval of this modification request.
1. The proposed modification represents a superior result than that which could be achieved by strictly following the
requirements of this title
Response: Additional planting within the modified landscape buffer can be accommodated to
achieve a superior result.
2. The proposed modification complies with the stated purpose of this title and any applicable subsections of this title
Response: The additional plating within the modified landscape buffer would achieve a more
aesthetically pleasing landscape strip. Additional landscape averaging can be accommodated
in sections of the project where there are minimal improvements proposed.
3. If the proposed modification will not violate any city of Federal Way Revised Codes or ordinances. In
particular, a modification shall not be a substitute for any zoning variance.
Response: The proposed modification will not violate any supporting codes or ordinances as
required by the City. Additional landscape improvements within the modified areas shall adhere
to all city requirements.
4. Where applicable, the proposed modification would result in an increased retention of significant trees and/or naturally
occurring vegetation on the site
Response: Since the project site has been cleared of natural vegetation previously, the
proposed landscape design does not have significant impact on the retention of significant
trees or existing vegetation.
5. The proposed modification also satisfies the criteria listed in subsection (2), (3), (4), (5), or (6) of this
section.
Response: Subsection (2) is satisfied by the responses provided above. Subsection (3) requires
the proposed landscape area to incorporate a combination of additional plant materials, a berm 3-feet in
height, and architectural elements of appropriate scale, all of which can be supplied within the proposed
modification area as required. Subsection (4) would not be violated as the proposed modification would
improve the landscape sections to improve overall community landscape and would not create any
scenic view obstructions. Subsection (5) states that perimeter landscape strips may be averaged, up to
50 percent of the width requirement. The proposed modification would be asking for a 25 percent width
reduction at specific areas to accommodate proposed improvements. Subsection (6) requirements can
be met with landscape buffer averaging throughout the project perimeter. See attached Landscape
Modification Plan for more details.
We believe that this modification request should be granted for this project, since it is demonstrated that
the modified landscape improvements would improve the composition of the public corridor. Please review
at your earliest convenience and please feel free to contact me with any questions or need additional
information. Thank you.
Sincerely,
Benjamin H. Eldridge, P.E.
Senior Project Engineer
enc: As Noted
cc: Scott Hougham, KGIP
James Carleton, Nelson
Ben Eldridge, Barghausen Consulting Engineers, Inc.
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1 SCALE: 1"=30'AREA OF LANDSCAPE MODIFICATIONIN ALL LANDSCAPE AREAS IN WHICH RETAINING WALLS NECESSITATE LANDSCAPE BUFFERWIDTH OF LESS THAN 10', 3' TOPSOIL BERM IS SPECIFIED AND DENSITY OF SHRUB PLANTINGHAS BEEN INCREASED BY AT LEAST 50% (132 ADDITIONAL SHRUBS). SEE COMPLETELANDSCAPE SET FOR DETAILS. AREAS SHOWN IN PLAN ABOVE WITHIN BROAD DASHED LINE.