21-102066-UP-ModReq-Land-2021-11-24-V2November 24, 2021
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 Avenue South and South 344th Street
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 modifi cation 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 sign ificant
trees or existing vegetation.
5. The proposed modification also satisfies the criteria listed in subsection (2), (3), (4), (5), or (6)
of this section.
EJ Walsh, P.E.
Director of Public Works City of Federal Way
Department of Community Development -2- November 24, 2021
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) wo uld 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
cc: Scott Hougham, KGIP
Daniel K. Balmelli, Barghausen Consulting Engineers
Daniel Casey, Barghausen Consulting Engineers