21-102066-UP-Modification Request for Retaining Wall-11-24-2021-V1
Stacey Welsh, Principal Planner
City of Federal Way
Department of Community Development
33325 – 8th Avenue South
Federal Way, WA 98003
RE: Request for Variance to Public Works Development Standards for Retaining Wall Height
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 Stacey:
This variance request has been prepared in response to the review comment provided in the Community
Development, Planning Division section of the letter dated September 10th, 2021, to justify the use of
retaining wall 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 Smith Brother’s Farms project is a warehouse distribution facility with areas for
traditional offices and associated truck loading. The property also includes a storage area for trailers that
arrive on site.
The topography of the site relatively steep, with large existing stockpiles creating unique earthwork
challenges. The project site proposed grades are as flat as required to accommodate truck maneuvering
and access which requires the use of retaining walls. To minimize disturbance to surrounding areas and to
maximize use of the property, a retaining wall over six feet in height will be required along 9th Avenue South.
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 variance as required by the city.
a. “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.”
Response: Granting this variance will not constitute a grant of special privilege inconsistent
with the limitations upon uses of other properties. Retaining walls over six feet high have been
allowed in other properties in the vicinity and zone in which the subject property is located.
b. “That the variance is necessary because of special circumstances relating to the size, shape,
topography, location, or surrounding 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.”
Response: The variance is necessary due to the steep slopes of the site and stockpiles leftover
from a previous owner. To provide a functional site layout for truck storage and maneuvering,
retaining walls over six feet in height will be required. This is consistent with rights and
privileges permitted to other properties in the vicinity and zone in which the subject property is
located.
c. “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.”
Response: Granting this 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 because these retaining walls will be constructed in accordance with city standards
and designed specifically for the proposed conditions.
d. “That the special circumstances of the subject property are not the result of the actions of the
owner or the subject property.”
Response: The need for retaining walls over six feet is not the result of the actions of the owner
of this development and is based on the existing topography and use of the property allowed
under subject property zoning.
We believe that this variance 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,
Benjamin H. Eldridge, P.E.
Senior Project Engineer
enc: As Noted
cc: Scott Hougham, KGIP
James Carleton, Nelson
Ben Eldridge, Barghausen Consulting Engineers, Inc.
Daniel Casey, Barghausen Consulting Engineers, Inc.