Signed Change of Use AnalysisCOMMUNITY DEVELOPMENT DEPARTMENT 33325 8th Avenue South Federal Way, WA 98003-6325
253-835-7000
www.cityoffederalway.com
Jim Ferrell, Mayor
April 12, 2021
Tzzy Wong
12181 “C” Street
Tacoma, WA 98444
tzzywong@aol.com
Re: Folder #21-100917-AD; ZONING COMPLIANCE REVIEW – CHANGE OF USE
Drive Through Coffee; 1045 South 320th Street, Federal Way
Dear Tzzy Wong:
The city is in receipt of your request for a Change of Use Analysis at the above-mentioned property on parcel
150050-0010. The subject property consists of an existing 3,765 square foot office building permitted and
constructed prior to the City of Federal Way incorporation. The change of use is to locate a new 131 square
foot coffee stand utilizing the existing drive-thru. The use is proposed within a portion of the existing
building and includes interior renovations.
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 City Center Frame (CC-F) zone. The building was permitted and
constructed under King County prior to the city’s incorporation. The previous use of the space was office use.
Per FWRC 19.230.010, office is a permitted use in the CC-F zone. A new (fast food restaurant) is proposed to
occupy a portion of the building and is a permitted use pursuant to FWRC Chapter 19.230.030.
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-
Tzzy Wong
Page 2 of 3
April 12, 2021
21-100917-AD Doc ID 81246
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.
In addition, the underlying required zoning review process for the proposed fast food restaurant 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 located in the CC-F zone. A fast food restaurant is proposed to occupy the site and is
a permitted use pursuant to FWRC Chapter 19.230.030, “Entertainment, etc.”
Upon review of the submitted application documents, the development is consistent with the special notes
and regulations for a fast food restaurant use within the CC-F zone.
Setbacks – There are no required minimum setbacks for the proposed use. The location of the existing drive-
thru and structure are currently nonconforming per FWRC 19.230.030. The change of use does not make the
site more nonconforming.
Parking Requirements – The submitted site plan shows 19 parking spaces. Per FWRC 19.230.030, one space is
required for each 80 square feet of gross floor area for a fast food restaurant use. Per FWRC 19.230.010, one
space is required for each 300 square feet of gross floor area for office space. Therefore, the proposal requires
two parking spaces and the existing use requires 13 spaces. The existing parking exceeds the minimum
parking required for the existing office space and proposed fast food restaurant.
Nonconforming Development – The change of use and tenant improvement (TI) as proposed does not trigger any
nonconformance review or site upgrades as the proposal does not exceed the thresholds of FWRC
19.30.090(1)(a).
State Environmental Policy Act (SEPA) Environmental Review – As submitted, the proposal does not add square
footage to the building and is therefore SEPA exempt. The proposal does not exceed the SEPA exemptions
set forth in WAC 197-11-800(3).
OTHER DEPARTMENT REQUIREMENTS
Building Division
Any tenant improvement/addition, or a sign permit, related to this building will require submittal of a
building permit application to the Permit Center. For information regarding the building permit application
process, please contact the Permit Center at 253-835-2607, or permitcenter@cityoffederalway.com.
Public Works Development Services Division
The proposed increase in impervious surface does not trigger site improvements. Please contact
Development Services Manager Cole Elliott at cole.elliott@cityoffederalway.com if you have any questions.
Tzzy Wong
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April 12, 2021
21-100917-AD Doc ID 81246
Public Works Traffic Division
There are no traffic concerns for the change of use. However, future permit applications for this site may be
subjected to concurrency and traffic impact fees if the Traffic Division determines the change of use
generates net new trips. Please contact Senior Transportation Planning Engineer Sarady Long at
sarady.long@cityoffederalway.com if you have any questions.
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 will 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. Should you have any questions about this decision, please contact Associate
Planner Chaney Skadsen at (253) 569-1772, or chaney.skadsen@cityoffederalway.com.
Sincerely,
Digitally Signed April 12, 2021, at 10:56 AM
Brian Davis
Community Development Director
c: Chaney Skadsen, Associate Planner
Sarady Long, Senior Transportation Planning Engineer
Cole Elliott, Development Services Manager