Change of UseCOMMUNITY DEVELOPMENT DEPARTMENT 33325 8th Avenue South Federal Way, WA 98003-6325
253-835-7000
www.cityoffederalway.com
Jim Ferrell, Mayor
March 8, 2021
Mr. Chase Silver
700 112th Avenue NE, Suite 203
Bellevue, WA 98004
chase@windermere.com
Re: File #21-100459-00-AD; CHANGE OF USE ANALYSIS
Highline Community College, 1615 South 325th Street, Federal Way
Dear Mr. Silver:
The city is in receipt of your February 9, 2021, submittal for a Change of Use from office to business/
vocational/trade school use. The site is zoned Community Business (BC) and contains two approximately
7,600 square foot buildings. The northern building, previously used as an office, is the subject of this Change
of Use Analysis. The request is to locate a business/vocational/trade school in the northern building. Minor
tenant improvements are proposed inside the building. No site modifications are planned.
ZONING COMPLIANCE REVIEW
Federal Way Revised Code (FWRC) 19.15.025 addresses a change of use at a developed site as follows:
“19.15.025. Zoning and use review process for new tenants – Change of use at a developed site.
The purpose of this section is to review and determine compliance with applicable zoning and
development code requirements when a new use is proposed to occupy an existing building or
site. When a land use changes from one use category in the zoning charts to another use
category, a zoning compliance review shall be performed as part of the use process review, when
required, or in conjunction with the required business registration and/or building permit review.
Each paragraph in a zoning chart is a use category. If the new use is in the same use category as
any previous legal use of the site, no zoning compliance review is required.”
The subject property is located in the BC zone. The previous use of the northern building was an office,
which is a permitted use pursuant to FWRC 19.220.010. A new business/vocational/ trade school use is
proposed to occupy the building and is a permitted use pursuant to FWRC 19.220.040, “Schools – Day care
facilities, commercial – Animal kennels.”
The existing and proposed uses are located in different zoning charts; therefore, a zoning compliance review
is required. Per FWRC 19.15.025(1), any new use shall comply with only those standards of the use zoning
charts that are directly related to the new use as determined by the director. Examples include parking, use-
specific setbacks, use-specific special regulations and notes, and nonconforming surface water quality
improvements identified in FWRC 19.30.120. Other nonconforming aspects of the site which are not made
nonconforming as a result of the change of use are not required to be brought into conformance as a result
of this subsection.
Mr. Chase Silver
Page 2 of 3
March 8, 2021
21-100459-00-AD Doc. I.D. 81173
In addition, the underlying required zoning review process for the proposed school use (Process II) is the
same review process as the existing office use (Process II). Therefore, per FWRC 19.15.025(2), no new formal
land use review process is required.
CHANGE OF USE ANALYSIS
The subject property is zoned Community Business (BC). Business/vocational/trade schools are a permitted
use pursuant to FWRC 19.220.040, “Schools – Day care facilities, commercial – Animal kennels.”
Use-Specific Regulations and Notes – No external changes to the existing building are proposed. In accordance
with FWRC 19.220.040(7), all school activities that may impact adjacent properties must take place within an
enclosed building. The submittal does not indicate outdoor activities are proposed.
Parking Requirements
The tables below describe the parking requirements for the existing and proposed uses.
Table 1. Existing Use
Gross Floor
Area (sq. ft.)
Existing
Use
Parking
Requirement
Required
Parking
7,666 Office 1/300 sq. ft. 26 spaces
Table 2. Proposed Use
Staff &
Students
Proposed Use Parking Requirement Required
Parking
Staff: 6
Students: 68
Business/vocational/trade
school
1 for each employee and 0.5
for each student
40 spaces
The submitted application and site plan indicate that 40 parking spaces on the site will be dedicated to the
school use, satisfying the parking requirement.
State Environmental Policy Act (SEPA) Environmental Review – As submitted, the proposal does not add square
footage to the building or parking spaces to the site and is therefore SEPA exempt. The proposal does not
exceed the SEPA exemptions set forth in WAC 197-11-800(3).
OTHER DEPARTMENT REQUIREMENTS
Public Works Tra ffic Division
The proposed change of use from small office to junior/community college will not generate any new PM
trips, so concurrency is not required. Please contact Senior Transportation Planning Engineer Sarady Long at
sarady.long@cityoffederalway.com if you have any questions.
Public Works Development Services Division
There are no exterior improvements and the proposed change of use does not appear to create a potential for
pollution not previously experienced. Please contact Development Services Manager Cole Elliott at
cole.elliott@cityoffederalway.com if you have any questions.
Mr. Chase Silver
Page 3 of 3
March 8, 2021
21-100459-00-AD Doc. I.D. 81173
Building Division
A tenant improvement permit has been submitted (20-105046-CO). For information regarding the building
or sign permit application process, please contact the Permit Center at permitcenter@cityoffederalway.com,
or 253-835-2607.
CONCLUSION
Pursuant to FWRC 19.15.025(1), this zoning change of use will not trigger or require upgrades to any zoning
related site improvements including, but not limited to: parking lot layout; parking stall count; landscape
buffers; building or site design; etc.
In summary, the proposed zoning change of use for this developed site is hereby approved. This letter is not
intended to identify all issues, as modifications to the building require additional building permit application
review. Also, you will need to obtain a city business license through the city’s Finance Department before
occupying the building. If you have any questions regarding this letter, please contact Interim Planning
Manager Stacey Welsh at stacey.welsh@cityoffederalway.com.
Sincerely,
Digitally Signed March 8, 2021, at 11:14 AM
Brian Davis
Community Development Director
c: Stacey Welsh, Interim Planning Manager
Cole Elliott, Development Services Manager
Sarady Long, Senior Transportation Planning Engineer