UP I DecisionCOMMUNITY DEVELOPMENT DEPARTMENT
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-7000
www.cityoffederalway.com
Jim Ferrell, Mayor
Mr. Lucas Johnson November 19, 2021
AHBL
225 N. 30th Street, Suite 300
Tacoma, WA 98403
ljohnson@ahbl.com
Re: File #21-102929-UP; PROCESS I “DIRECTOR’S APPROVAL”
Federal Way High School Pre-Apprenticeship Space, 30611 16th Avenue South, Federal Way
Dear Mr. Johnson:
The Community Development Department has completed review of your Use Process I Master Land Use
application for the Federal Way High School Pre-Apprenticeship Space (CTE Yard) at Federal Way High
School. The Process I application is hereby approved per the findings and conclusions noted below.
FINDINGS OF FACT
1. The applicant proposes to complete exterior improvements at Federal Way High School, including
converting an existing lawn area to a pre-apprenticeship program yard, including a 20’ tall, 52’ x 24’ (1,248
square feet) pole barn structure without walls, gravel surfacing, fencing, and outdoor classroom seating.
No changes to existing parking or removal of required landscaping are proposed.
2. The zoning for the property at 30611 16th Avenue South (parcel 082104-9001) is Community Business
(BC). A school is an allowed use in the BC zone per Federal Way Revised Code (FWRC) 19.220.040,
“Schools – Day care facilities, commercial – Animal kennels.”
3. According to FWRC 14.15.030(1), the project is exempt from environmental review under the State
Environmental Policy Act (SEPA), as the proposal does not exceed the flexible thresholds.
4. Per FWRC 19.15.030(1) minor improvements and modifications to a site that are exempt from SEPA
shall be processed using Process I as follows:
“(1) Minor improvements, modifications and additions. Minor improvements, modifications
and additions to a site such as parking lot and landscape area modifications and improvements,
and/or additions to an existing developed site that are exempt from SEPA shall be processed
using process I, provided the improvements and/or additions do not exceed either of the
following thresholds: (a) Twenty-five percent of the gross floor area of the existing use; or
(b) Two thousand square feet of new gross floor area.”
5. The location of the pole barn is proposed more than 20’ from any property line, is 20’ in height, and
there is no maximum lot coverage for this use, all in compliance with the bulk and dimensional standards
in FWRC 19.220.040.
Mr. Lucas Johnson
Page 2 of 5
November 19, 2021
21-102929-UP Doc. I.D. 81859
6. The 2014 city staff report for the high school replacement project noted, “1,600 students and 120
employees will require a minimum of 280 parking spaces. The applicant has proposed 610 total parking
spaces and therefore exceeds the minimum.” According to that report, there is an adequate amount of
existing parking spaces to accommodate the current proposal.
7. Per FWRC 19.220.040 Special Regulation and Note #7 all activities pertaining to schools, such as auto
repair or other uses that may impact adjacent properties, must take place within an enclosed building. The
proposed structure will not have walls; however, the area is centrally located within the school grounds
and not near any property line.
8. Given the proposed development location, code required site perimeter and parking lot landscaping are
not affected. Removal of existing lawn does not trigger any landscaping code based replanting
requirements.
9. The proposal includes removal of 6 trees. Per FWRC 19.120.130(2) the 38.2 acre site is required to
provide 20 tree units per acre (38.2 x 20=764 units). According to the submittal there are 779 tree units
on site.
10. There are no known critical areas in the area proposed for development.
11. Per FWRC 19.115.030, applications for expansion of existing developments shall meet only those
provisions of the design guidelines chapter that are determined by the Director to be reasonably related
and applicable to the area of expansion.
12. The applicant submitted a Crime Prevention through Environmental Design (CPTED) checklist. The
design narrative states, “The materials for the project will be selected to match the existing materials
palette on FWHS. Access into the CTE Yard will be through two vehicle gates and two pedestrian gates.
All gates will be locked and monitored by the existing FHWS security networks (cameras and locks).”
Upon review, gate details differ throughout the plan set; sheets show either none or only two.
13. Per FWRC 19.115.090(1)(f), chain-link fences visible from public rights-of-way or adjacent properties,
and not screened by Type I landscaping as defined by FWRC Chapter 19.125, shall utilize vinyl-coated
mesh, powder-coated poles, dark color(s), and architectural element(s) such as pole caps and/or
decorative grid pattern. According to the project narrative, “The CTE Yard will be enclosed by 6’ high
metal picket fence on all sides. The fence will be square picket-style fence, to match existing school
fencing, approximately 4” picket spacing, painted black.”
14. Per FWRC 19.115.100(4), roof design shall utilize forms and materials that avoid the general appearance
of a “flat” roof. Rooflines with an integral and obvious architectural pitch are an approved method to
meet this guideline. According to the submittal, the structure will have a metal, shed-style roof (a low-
slope roof sloping in one direction).
15. According to the project narrative, “Existing site lighting provides sufficient illumination for circulation
and general safety. Additional lighting will be provided within the canopy work area to support the
teaching activities…The project area is centrally located on the FWHS campus and as such would not
result in lighting spilling into adjacent properties. The lighting provided in the canopy area will be
sufficient for teaching activities and would remain on during non-school hours for added security. Light
fixtures in the canopy area will be selected with cut-off shields, to provide down lighting.” The proposal
is in compliance with the lighting regulations in FWRC 19.105.030.
Mr. Lucas Johnson
Page 3 of 5
November 19, 2021
21-102929-UP Doc. I.D. 81859
16. FWRC 19.125.150 requires that storage areas for garbage and recycling receptacles be provided for each
project. The 2014 city staff report for the high school replacement project noted, “garbage and recycling
space is provided within the screened service area along the north building elevation. Space requirements
of 2 sf per 1,000 sf of gross floor area are exceeded.” This was for a 235,885 square foot building.
Subsequently, the solid waste receptacles code was revised in 2017. For more than 200,001 square feet of
non-residential development, based on the gross floor area of all structures on the lot, the required
minimum area for shared storage space is 500 square feet. As a result, existing on-site receptacles are
adequate.
17. Per FWRC 19.15.100(1), the applicant must substantially complete construction for the development
activity, use of land, or other actions approved; and complete the applicable conditions listed in the
Process I decision within one year after the final decision of the city on the matter, or the decision
becomes void.
18. The Building Official reviewed the submittal and found the following that shall be addressed at time of
permitting:
a. No accessible path between the main school building and pole building is provided.
b. Explain how gravel surfacing meets accessibility for students in/under this building.
c. There is no plan showing how students will exit the area or how the new fencing affects the
existing school for egress.
d. How is the seating constructed and how does it provide accommodations for accessibility?
e. A drinking fountain shall be provided.
19. Public Works Development Services reviewed the submittal and found the following that shall be
addressed at time of permitting:
a. The provided civil plans, Sheet C4.0, Storm Drainage and Utility Plan, proposes a new pole
barn building to be built over an existing 12” PVC storm pipe. Either relocate the existing
12” drainage pipe or relocate the pole barn structure.
b. Change permit no. 16-105024-00-CO to the current permit number on “C” and “L” sheets.
20. The Public Works Traffic Division reviewed the submittal. A Capacity Reserve Certificate was issued on
November 17, 2021. The number of new PM peak hour vehicle trips generated by the project is 1. Per
FWRC 19.91 traffic impact fees are required and will be assessed at the building permit stage. The impact
fee will be calculated based on the fee schedule in effect at the time a completed building permit
application is filed and paid before permit issuance per FWRC 19.100.070(3)(a).
21. Lakehaven Water and Sewer District (LWSD), the water and sewer service purveyor for the site, reviewed
the submittal and noted the following that shall be addressed at time of permitting:
a. The seat walls shown on the site plan cannot be installed over LWSD water main or within
easement limits.
b. A Lakehaven Developer Extension Agreement will be required to construct new, abandon,
and/or modify existing water distribution system facilities for the proposed development.
Mr. Lucas Johnson
Page 4 of 5
November 19, 2021
21-102929-UP Doc. I.D. 81859
22. South King Fire & Rescue reviewed the submittal and stated that a voice evacuation system shall be
extended from the school fire alarm to this barn since it will be used as an E type occupancy. A separate
permit is required.
CONCLUSIONS OF LAW
1. The proposed improvements are not exempt from use process review as they do not meet criteria set
forth in FWRC 19.15.020, “Exceptions.”
2. Process I “Director’s Decision” is the appropriate Master Land Use application as minor improvements
and modifications to an existing developed site are proposed that do not exceed thresholds set forth in
FWRC 19.15.030(1).
3. The proposed improvements comply with zoning regulations set forth in Use Zone Chart FWRC
19.220.040, including required yards, lot coverage, height, and parking.
4. The proposed improvements meet Process I purpose criteria set forth in FWRC 19.55.020, including
compliance with applicable provisions of FWRC Title 19, “Zoning and Development Code,” and health,
safety, and welfare standards.
APPEALS
The effective date of this decision per FWRC 19.05.360 is November 22, 2021. Pursuant to FWRC
19.55.050, the applicant, any person who submitted written comments or information, any person who has
specifically requested a copy of the decision, or the city may appeal this decision to the Federal Way Hearing
Examiner by December 6, 2021. Any appeal must be in the form of a letter delivered to the Community
Development Department with the established fee. The notice of appeal must contain a statement identifying
the decision being appealed, along with a copy of the decision; a statement of the alleged errors in the
director’s decision (including identification of specific factual findings and conclusions of the director
disputed by the person filing the appeal); and the appellant’s name, street address, email address, telephone
number, fax number, and any other information to facilitate communications with the appellant.
CLOSING
This land use decision does not waive compliance with future City of Federal Way codes, policies, and
standards relating to this development. This Process I approval does not constitute approval of a building
permit. If you have any questions regarding this decision, please contact Principal Planner Stacey Welsh at
253-835-2634, or stacey.welsh@cityoffederalway.com.
Sincerely,
Brian Davis
Community Development Director
Mr. Lucas Johnson
Page 5 of 5
November 19, 2021
21-102929-UP Doc. I.D. 81859
enc: Approved Site Plan
c: Stacey Welsh, Principal Planner
Scott Sproul, Building Official
Sam Basmeh, Development Services Reviewer
Sarady Long, Senior Transportation Planning Engineer
Kathy Mathena, Lakehaven Water & Sewer District
Sean Nichols, South King Fire & Rescue
Mike Benzien, Federal Way Public Schools, mbenzien@fwps.org