Technical Comment Letter COMMUNITY DEVELOPMENT DEPARTMENT
33325 8th Avenue South
Federal Way, WA 98003-6325
253-835-7000
www.cityoffederalway.com
Jim Ferrell, Mayor
Mancong Lin March 22, 2022
Bumgardner Architects
2111 3rd Avenue
Seattle, WA 98121
mancongl@bumgardner.biz
Re: File #20-104351-00-UP & 20-104353-SE; TECHNICAL REVIEW COMMENTS
Redondo Heights TOD (Site C), 27614 Pacific Hwy South, Federal Way
Dear Ms. Lin:
The Community Development Department is in receipt of your November 24, 2021, Process III and State
Environmental Policy Act (SEPA) Master Land Use (MLU) application. City staff have the following preliminary
comments in response to the Redondo Heights TOD (Site C) Process III application. The proposal is for a
new mixed-use development of 72 residential units with food bank on street level, office building,
underground and at grade parking, and site improvements. Pursuant to Federal Way Revised Code (FWRC)
19.15.045, the application was deemed complete on December 21, 2021.
TECHNICAL COMMENTS
The following comments provided by staff reviewing your project must be addressed prior to issuance of a
land use Process III application decision, or as otherwise noted. Questions regarding technical review
comments should be addressed to the referenced staff representative.
Community Development – Planning Division
Becky Chapin, 253- 835-2641, becky.chapin@cityoffederalway.com
1. Technical comments made about an item on one sheet may necessitate changes to other related sheets and
related documents, and it is the applicant’s responsibility to determine any such necessary adjustments.
Please ensure consistent information is communicated throughout the plan set and associated application
materials. Revisions to address the comments below may result in further additional comments and may
require further plan revision to meet applicable requirements.
2. Retaining Wall – Sheet L. 1501 of the landscape plan depicts a retaining wall along Pacific Hwy South. It is
hard to tell if that is within the right-of-way or on private property. If on private property, provide sections
and details of proposed retaining walls that indicate material, and overall height. Refer to FWRC
19.120.120, retaining walls shall be set back a minimum of three feet from adjacent public rights-of-way
and include a minimum of three feet of landscaped setback at the base. Per FWRC 19.120.120(6), if
private agreements are reached with utility companies and written documentation is provided to the city,
and a minimum three-foot wide planting buffer can be established and maintained to screen the wall from
view, retaining walls can be located to the back of the right-of-way as determined by the community
development services and public works directors.
Ms. Mancong Lin
Page 2 of 4
March 22, 2022
21-104847-00-UP Doc. I.D. 81965
3. Smoking Area – If smoking is prohibited within the units, designated smoking areas shall be provided for
the proposed development. The smoking area shall not be visible from the public rights-of-way and must
be clearly depicted on the site plan.
4. BLA Required – A boundary line adjustment (BLA) to consolidate multiple parcels and/or remove
interior lot lines is required. Prior to issuing building permits, a BLA must reconfigure the existing lot
lines, or remove the lot lines. The BLA application must be submitted, approved, and recorded prior to
the issuance of any building permits.
5. School Access Analysis – A school access analysis is required to be submitted to the city with the Process III
application. The analysis will be routed to Federal Way Public Schools to determine whether off-site
improvements are needed for safe walking routes, and/or to determine where an appropriate bus stop
should be located within the development. Contact Jen Thomas with the Federal Way School District at
253-945-2071 or jthomas@fwps.org for information about the school access analysis requirements.
6. Affordable Units – A minimum of five percent of new dwelling units must be considered affordable as
defined by FWRC 19.110.010. A covenant or other document with form and content to be approved by
the City Attorney regarding affordable housing must be recorded prior to occupancy of any buildings
Public Works – Development Services Division
Cole Elliott, 253-835-2730, cole.elliott@cityoffederalway.com
Kevin Peterson, Senior Engineering Plans Reviewer, provided comments below. Kevin no longer works for
the City; any comments can be directed to Cole Elliott.
1. Given the scope of the project: 72 residential units, a 3,000 SF office, and 6,500 SF food bank, the solid
waste and recycling (SWR) facility appears to be extremely inadequate. Refer to FWRC Section
19.125.150 for the SWR enclosure requirements. The applicant should provide some additional details on
the plans that show the SWR area, and provide a narrative as to how all users will access the enclosure
area as well as how the waste management company will collect the trash and recycling;
2. On the civil plans, provide the following areas:
a. Total site area
b. Total NEW impervious area
c. Total existing impervious area to be replaced
d. Total NEW + Replaced impervious area
Public Works – Traffic Division
Soma Chattopadhyay, 253-835-2731, soma.chattopadhyay@cityoffederalway.com
1. The Super market tip generation is different from Food Bank. Food Bank will not generate any internal
capture and will have less pass by trip than Super market. Super market peak hours and trip generations
are different than Food bank. Please clarify how these two land use types are considered similar nature.
2. Please note that the city calculates traffic impact fee which depends on land-use and trip generation. ITE
does not have trip generation for Food Bank. City will be using the same land-use which the applicant is
submitting. Hence it may result in higher fees as a Super market compared to Food Bank.
Ms. Mancong Lin
Page 3 of 4
March 22, 2022
21-104847-00-UP Doc. I.D. 81965
3. A minimum driveway throat length of 40 feet is required as measured from the face of curb to the first
conflicting drive or parking aisle. (Public Works Development Standards - 3.2.14 A Driveways- General
10). Adequate throat length is required to accommodate 95th percentile queue length. Please show that
the proposed south driveway has at least 40 ft. throat length.
The following comments regarding the parking assessment prepared by TENW, Inc. were provided via email
on February 18, 2022.
4. It appears the selected many sites are multifamily housing without retail use. Also parking studies are very
old. It is staff understanding that the proposed project is a mixed-use development and as such the
selected study sites should be similar use in term of retail use, housing units, transit service (daily and
hourly headway) within ¼ mile, available amenities, monthly rental, parking charge, etc.
5. The parking data should be collected for at least two days duration in order to account for any
abnormally. Furthermore, the count should be collected outside of the holidays travel period to better
reflect realistic parking demand.
6. Provide document how the peak period weekday between 8 p.m. – 9 p.m. and weekend peak period
between 6:00 a.m. – 5:00 a.m. were selected for the study sites and also identify if weekday or weekend is
the peak period for multifamily housing. Per ITE Parking Manual, the peak period parking demand for
Multifamily Housing (LUC 221) is between 10:00 p.m. to 5:00 a.m. and according to Urban Land institute
7PM to 5PM. In order to capture each site peak demand, the counts of number of parked vehicles
should be conducted once per hours over that period. All count data used to generate the report should
be included in the back.
7. Provide average rate and 85th percentile rate for the study sites. Parking demand for the development
should be calculated at the 85th percentile.
8. Parking inventory for each selected site should identify parking spaces allocated for visitors, office staff,
handicapped, truck loading/unload parking spaces. These spaces should not be included in the total
available tenant parking spaces.
9. Provide available off-site/on-street parking capacity for each site and identify how many are utilized for
each site. The analysis should also identify any potential available off-street parking for the proposed
development.
10. ITE parking data is based on the 85th percentile demand whereas the sampled sites utilized the average of
peak period.
11. Parking requirements for multifamily comparison from nearby jurisdictions should not be included in the
parking analysis. The four comparable sites are adequate to establish reasonable parking demand for the
development. Furthermore, Seattle, Issaquah, Mill Creek, Mukilteo and Lynwood would not be
comparable to Federal Way in term of transit services, employment density, etc.
Ms. Mancong Lin
Page 4 of 4
March 22, 2022
21-104847-00-UP Doc. I.D. 81965
Federal Way Police – Crime Prevention
Lindsey Sperry, 253-835-6707, lindsey.sperry@cityoffederalway.com
1. The Police Department is always concerned about adequate parking, especially when there will be a
daycare and food bank at the location. Although ‘parking studies’ often show what an adequate number
of stalls is, we are finding that most of these complexes are not even close to having the actual amount of
parking necessary for residents. Our concern is the lack of parking will increase illegal parking issues at
the park and ride and neighboring businesses.
2. Verify if this complex will have security camera’s around the property. We would suggest that they do.
We would also like to see more plans for the security of the parking garage.
3. The Police Department will need to coordinate codes or key card access to the buildings in case of
emergency’s (similar to the access Fire is provided).
CLOSING
Please be aware that this review does not preclude the city from requesting additional information related to
any of the topics discussed above. Please submit the revised application materials as appropriate, by electronic
submittal (Document Upload Link or https://www.cityoffederalway.com/node/4588), a letter explaining
how these comments have been addressed, and the completed “Resubmittal Information Form” (enclosed).
Individual documents or materials may be submitted to me or the appropriate reviewer for further discussion
purposes, but these email submittals are not considered resubmittals.
Please note, the original plan review fee collected at submittal of your permit covers the initial review and one
resubmittal. The city has begun charging applicants for any additional staff time necessary to complete each
review following the first resubmittal.
Pursuant to FWRC 19.15.050, if an applicant fails to provide additional information to the city within 180
days of being notified that such information is requested, the application shall be deemed null and void and
the city shall have no duty to process, review, or issue any decisions with respect to such an application.
If you have any questions regarding this letter, please contact me at becky.chapin@cityoffederalway.com, or
253-835-2641.
Sincerely,
Becky Chapin
Senior Planner
enc: Bulletin 129 ‘Resubmittal Information’
c: Cole Elliott, Development Services Manager
Soma Chattopadhyay, Traffic Engineer
Lindsey Sperry, Crime Analyst & Prevention Specialist
Len Brannen, Shelter Resources, lenb@shelterresourcesinc.com
Mark Simpson, Bumgardner Architects, marks@bumgardner.biz