Landmark Review CommentsCOMMUNITY DEVELOPMENT DEPARTMENT 33325 8th Avenue South Federal Way, WA 98003-6325
253-835-7000
www.cityoffederalway.com
Jim Ferrell, Mayor
July 13, 2020
Mr. David Ratliff
Landmark LLC
10900 NE 8th Street, Suite 1200
Bellevue, WA 98004
david.ratliff@devcowa.com
Re: Files #20-100896-UP & 20-100898-SE; COMBINED TECHNICAL REVIEW COMMENTS
Landmark Apartments at Celebration Park, 330XX 15th Avenue South, Federal Way
Dear Mr. Ratliff:
The Community Development Department is in receipt of your February 28, 2020, Process III and State
Environmental Policy Act (SEPA) Master Land Use (MLU) application. The Planning Division has the following
preliminary comments in response to the Landmark Apartments at Celebration Park SEPA and Process III
applications. The proposal includes: construction of three new multi-family – mixed use buildings with 231
affordable rate housing units; 479 parking stalls; a future daycare building; associated site work; and street and
utility improvements on vacant property. Pursuant to Federal Way Revised Code (FWRC) 19.15.045, the
application was deemed complete on March 27, 2020.
Comments in this letter must be addressed prior to issuance of a SEPA threshold determination and land use
Process III application decision, or as otherwise noted. Questions regarding technical review comments
should be addressed to the referenced staff representative.
City staff and other departments have conducted a technical review of the proposal of the SEPA and Use
Process III application. The following represents the combined technical review comments from the
Community Development Department, Public Works Development Services and Traffic Divisions, PARC’s,
Public Safety, Federal Way Public Schools, South King Fire & Rescue, and Lakehaven Water & Sewer District.
Community Development – Planning Division
Jim Harris, jim.harris@cityoffederalway.com
The following Planning Division comments need to be addressed prior to the SEPA threshold determination
and Process III land use application decision, or as otherwise noted. The FWRC is available online. Questions
regarding the Planning Division technical review comments should be addressed to Jim Harris at
jim.harris@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.
Mr. David Ratliff
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2. Site Data Block Required – For required city reporting purposes, provide a site data block on site plan sheet
12 and/or on requested architectural site plan with at least the minimum following information:
• Identify the size of each parcel;
• Total site area;
• Identify proposed building total footprint area;
• Identify square footage of all proposed building areas including, commercial area private,
commercial area public, and multi-family area (square footage);
• List the and number of floors of each existing and proposed building;
• Identify the proposed height of each building;
• Include the impervious area (identify both paved areas, building area, and total);
• Include the stormwater area square footage; (if using above ground surface area);
• Identify area for public right-of-way dedication (square footage);
• Net land area (total site area minus right-of-way dedication);
• Identify size of critical area, wetlands, and buffer on-site; and
• List parking stalls count (surface stalls and under building parking stalls).
3. Building Height – The building height, including the Average Building Elevation (ABE) data as defined in
FWRC 19.05.010(A), needs to be shown on the site plan and elevations for each building face. The
building height shown on the elevation sheets needs additional ABE information as identified in the
FWRC. Average of both existing and proposed grade as specified in FWRC needs to be shown.
Once the ABE is determined, then the ABE needs to be shown on the elevation sheets. Show the
building height of each building elevation, measuring from the ABE to the mid point of sloped roofs.
“ ‘Average building elevation (ABE)’ means the average of the highest and lowest existing or
proposed elevations, whichever is lowest, taken at the base of the exterior walls of the
structure, or it means five feet above the lowest of the existing or proposed elevations,
whichever is lowest. ABE is the elevation from which building height is measured.
“ ‘Height of structure’ means the vertical distance measured from the average building
elevation around the building segment to the highest point of a flat roof or to the deck line
of a mansard roof, or to the mid-point between eave and ridge of the highest principal roof
of a gable, hip, gambrel, or similar sloped roof. For single-family residential structures where
the total area of dormers exceeds 35 percent of the total area of the underlying sloped roof,
height will be measured to the ridge of the highest principal gable.”
4. Ground Floor Commercial, Office Use –
a. Per FWRC 19.220.050 note 1, identify the first-floor ceiling height. Identify the depth of the ground
floor commercial per FWRC 19.220.050 note 1.
b. Please clarify on the site plan, and provide a brief written mixed use narrative, of how the proposed
ground floor commercial areas meet FWRC 19.220.050 note 4, the minimum commercial frontage
requirements.
Mr. David Ratliff
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c. Provide an architectural site plan with dimensions clearly showing these commercial areas. Clearly
identify how the numeric requirements of note 4 are met, and identify which ground floor areas are
proposed for private ground floor amenity areas for residents only and those areas which are
available for general public office and commercial uses. The plans and project narrative do not clearly
distinguish which ground floor areas are private leasing office, private recreation area, and public
commercial areas. City staff has been generous in allowing a portion of the private ground floor
amenity areas to be counted to fulfil a portion of the ground floor commercial; however, the ground
floor commercial areas need to be primarily for commercial/office use available to the public.
5. Community Design Guideline Review - Building and Site Design –
a. Provide a written narrative stating how each façade individually meets the dimensional guidelines of
the façade modulation and screening guidelines in FWRC 19.115.060(2), incorporating at least two of
the four treatments (or something better), including modulation, landscape screening, pedestrian
plaza, and canopies. For example, the east façade should be described as: “The east façade includes
building modulation with a depth of ** feet deep and ** feet wide. This facade also includes a canopy
for ** percent of the façade.”
Provide a narrative of how each facade identified below complies with modulation and screening
standards for each of the following building facades:
Building A: North façade (all); east façade (all); west façade (portion adjacent to 13th
Place South); and south façade (the approximately 80-foot easterly portion of building).
Building B: East and west facades (all); north and south facades (minimum of first 60 feet
of each façade).
Building C: East façade (all); north façade (approximately easterly most 80 feet); south
façade (approximately easterly most 80 feet); west façade is not applicable.
Building D: North and east facades.
b. Identify specific methods of façade articulation and scale for all building facades pursuant to FWRC
19.115.060(3).
c. The primary long uninterrupted rooflines on buildings should incorporate significant steps or height
variations to break up these long interrupted horizontal roofline planes per FWRC 19.115.060(1) and
19.115.060(4).
d. The floating decks/balconies must be revised to eliminate the appearance of floating per FWRC
19.115.080(1). The design guidelines encourage upper story setbacks, rather than upper story bump
outs as proposed.
e. What is the proposed building setback from the property line (right-of-way line) of the upper floor
balconies on the north elevation of Building A?
f. Identify variations of materials, color texture, etc. to emphasize the base of all buildings. Submit a
digital color rendering of the development with details of building exterior architectural elements.
g. Show amenities for any proposed pedestrian plazas as required in FWRC 19.115.050(6).
h. Is the ground floor of the east elevation of Building A at street sidewalk level? The east elevation
plan for Building A appears to show the first floor not at sidewalk level. Please clarify.
i. Provide details of the facades of the ground floor commercial areas per FWRC 19.115.080.
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j. Ground floor commercial is encouraged along the whole east façade of building A.
k. Is there large venting of all below building parking proposed or required? What is the appearance of
this venting if applicable?
l. Provide details of the design of the ground floor north and south elevations of Building B. The
ground floor parking on Building B, which runs the full length of Building B, needs to be modified to
address FWRC 19.115.050(3). In general, the landscape along the south façade of Building B may
provide some visual relief, but the north elevation of Building B does not meet the design guidelines
for parking structures. This north side ground level façade will need significant treatment to meet the
minimum design guidelines requirements.
m. The trash and recycling area enclosure adjacent to 13th Place South needs to be relocated to a less
visible area away from the public right-of-way per FWRC 19.115.050(6).
n. Provide conceptual elevations of Building D which meet design guidelines in order to gain Process
III approval for this portion of the development.
o. Provide strong pedestrian connections in logical and usable locations. A delineated pedestrian
connection from a centralized and logical building entrance area of Building B to the play area and
amenities area must be provided and identified with a variation in material, color, and texture per
FWRC 19.115.050(6) and 19.115.070.
p. Provide a strong east – west pedestrian connection through the site from 13th Place South to 15th
Avenue South.
q. It is unclear if there is an outdoor pedestrian walkway from the westerly portion of Building C to the
13th Place South public right-of-way. Please clarify.
r. Provide pedestrian connections/delineated routes to trash/recycling areas.
s. Provide delineated pedestrian connections across parking areas and drive aisles connecting sidewalks,
with separate material, pattern, and texture, not paint, per FWRC 19.115.050(4).
t. Elaborate and provide a graphic of the hot water heating solar panels identified in the SEPA checklist.
I suggest having your architect contact me to discuss these comments and discuss potential solutions
prior to re-submitting a full written response and revised preliminary plans.
6. Tree Units – The proposed development plans include removal of all trees and vegetation on the
developing portion of the property. No existing trees are proposed for preservation on the portion of the
site being developed under this application. Removal of all trees and vegetation is contrary to the
objectives of the FWRC clearing and grading regulations under FWRC Chapter 19.120 Article II and
Article III. Pursuant to FWRC 19.120.080 and 19.120.130(1), provide a written request and justification
for removal of all trees and vegetation as proposed, as the proposed clearing and grading does not
attempt to “minimize removal of existing trees and minimize the disturbance or compaction of native
soils….” The FWRC policies encourage retention of existing trees and vegetation in good health to the
maximum extent possible in all developments.
A complete code-based review of the proposed tree unit count and compliance is not being conducted at
this time. This final code review typically occurs with the final landscape plan review during the building
permit review. However, we offer the following comments that should be addressed at this time in regard
to the tree unit requirements in FWRC 19.120.130. Please address each of the following comments:
Mr. David Ratliff
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a. Sheet L1.3 tree sample areas table is not necessary and should be removed. This tree sample
evaluation count is not applicable under current FWRC requirements.
b. A portion of parcel -9034 is not proposed for development, but is viable for future development.
There is no indication on any of the plans or submitted documents that this undeveloped area is
intended as a permanent tree and vegetation preservation area; and therefore, this area not currently
proposed for development should be eliminated from the tree unit area calculations.
c. The tree unit table on sheet L1.3 needs to be revised to include:
Gross land area being developed.
Subtract area of right-of-way dedication.
Equals net developable area.
Multiply net developable area by 20 tree units acre (FWRC 19.120.130), and this results
in the quantity of tree units required on the developed portion of the site.
d. Provide a table on the landscape plan, showing the above calculations, and the proposed tree unit
calculations. All trees retained and planted on the developed portion of the site count for tree units,
except trees in the public right-of-way.
7. Landscape Plan – A complete code-based review of the landscape plan is not being conducted at this time.
The following comments are intended to identify major comments that will need to be addressed prior to
the decision on the Process III application.
a. If any proposed building, or portion of a building, does not provide building frontage commercial/
office space, then that portion of the building must provide a minimum five-foot-wide type III
landscape strip along the property line. This will apply to a portion of the east façade of Building A as
currently proposed.
b. On sheet L 3.1, landscaping is proposed along most of the east façade of Building A. Is this commercial
space along this east façade?
c. It appears there are utilities or vaults, or similar proposed, within the required perimeter five-foot
landscape area that need to be relocated outside the landscape area at the following locations: south
of Building B adjacent to 15th Avenue South; and at the far southwest corner of the site.
d. Notes regarding open space on sheet L1.0 need to be revised to meet current FWRC. See the open
space discussion below for further information.
e. The trash/recycle area on the east side of 13th Place South needs to be relocated outside the five-foot
perimeter landscape area. Also see the design comments above regarding location of the trash area.
f. All perimeter landscape areas need to be a minimum width of five feet, free of retaining walls, and
free of parking overhangs. Retaining walls cannot reduce the width of landscape areas below five feet
in perimeter area. Please verify all perimeter landscape area widths, especially along the south
property line, west side.
g. What are two unidentified squares north and west of play area A on sheet L1.1?
h. Provide a minimum five-foot Type III landscape area between the Amazon lockers and right-of-way line.
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i. Provide dimensions on landscape plans.
j. To improve plan clarity, change/clarify the fence symbols and/or line weight of the proposed fences
on the landscape plans.
This is not a complete technical code-based review of the landscape plans. This review is intended to
address major items on the landscape plan, and to identify spatial requirements for landscape perimeter
areas and parking lot landscaping areas in general. Final landscape review occurs with building permit
application review. However, the comments above need to be addressed in order to evaluate the Process
III site plan application.
8. Forest Practices – A Forest Practices Class IV-General Application is required if more than 5,000 board feet of
merchantable timber will be harvested from the property in conjunction with the development activity.
Please provide data from a qualified source regarding the amount of merchantable timber to be harvested. If
applicable, a forest practices permit needs to be disclosed and identified on the SEPA checklist. A forest
practice permit needs to be submitted and approved in conjunction with development permits or approvals.
9. BLA Required – As the buildings and parking areas extend over several parcel lines, a boundary line adjustment
(BLA) to consolidate multiple parcels is required. Timing of the BLA will need to be considered and evaluated
with other factors of the development, such as, but not limited to:
• At time of issuance of individual building permits, buildings cannot be constructed over property lines.
• Right-of-way dedication for 13th Place South needs to be considered and discussed with Public
Works staff regarding the timing of dedication.
• As the subject property has two different zoning designation, city staff will not support creation of
lots with split zoning designations.
A boundary line adjustment is an administrative review process under FWRC 18.10. A BLA information
handout is enclosed. Contact the Permit Center at permitcenter@cityoffederalway.com for the BLA
application fee.
10. Subject Property Segregation – The subject property will be segregated by a public roadway and public right-
of-way dedication of 13th Place South. The right-of-way dedication will result in some of the FWRC
required improvements and amenities for a multi-family development being located on non-contiguous
properties. Eventually, this could result in a portion of the property being sold and the property could
become nonconforming in regard to FWRC requirements.
Please propose a solution that prevents a portion of the property from being sold and resulting in
nonconforming development. One possible solution is to record a document approved by the City
Attorney that prevents a portion of the development from being sold or ownership transferred.
11. Future Phase – The proposed future Building D phase is unclear in the SEPA and Process III application
materials. The preliminary site plan and SEPA checklist state the Building D daycare as a future phase,
but the site plan shows parking and driving area improvements for the daycare, and development of a
“pad” for a future daycare building.
Development of the site plan as proposed shows the pad for future daycare and associated parking and
driving area for the daycare being developed with the “first” phase. However, the daycare use and
building appears to be the proposed future phase.
Mr. David Ratliff
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City staff cannot support development of the future phase as proposed since the future development area
includes the shared driving aisle and parking area for Building C and future Building D. The building and
parking area for the future daycare phase is zoned Office Park (OP), and OP zoning does not allow
multi-family use as has been previously discussed. As currently proposed, parking for the multi-family will
occur on OP zoned property, and the OP property will not have an established approved use.
Hypothetical future development of the OP parcel with a future phase, while not evaluating the whole
proposal for SEPA impacts and FWRC compliance, is not supported by city staff. In summary,
developing the infrastructure, parking, and driving aisles for the future phase without further evaluation
of the whole future phase does not meet the intent of the Process III site plan review.
Another factor supporting the city staff position on the phasing is that the multi-family portion of the
proposal (Building C) cannot function and meet applicable requirements such as parking, vehicular
access, and circulation, without developing the vehicular access on the adjoining (future phase) OP
parcel. Therefore, land use review and approval of at least the southern portion of the OP zoned parcel
and proposed Building D is necessary, since the development of at least a portion of the OP parcel is
integral and necessary for development of the proposed apartment Building C.
The proposed action and application could be modified to meet applicable FWRC requirements and gain
city staff support of the phasing if the daycare is proposed as part of the current Process III land use and
SEPA review. The daycare could still be slated for future construction. The SEPA checklist would need to
be revised to address this action. Transportation concurrency would need to be prepared in accord with
Public Works requirements. The Process III application would need to address this daycare proposal and
parking compliance, including, but not limited to, execution of reciprocal access and parking if applicable.
A preliminary site plan and preliminary elevations of the future daycare will need to be submitted to
include this phase in the pending Process III application and Community Design Guideline review
element of the proposal. The Process III decision would be valid for five years per FWRC 19.15.100. If
plans, design, and/or use for the future daycare phase change within the five-year approval duration, a
modification to the site plan and elevations for future development could potentially be processed in
accord with FWRC 19.15.090. Alternatively, a new land use application in accord with the FWRC could
be submitted in lieu of the future phase D daycare building, during or after the five-year validity of the
Process III decision, or should the proposed land use of phase D be modified or revised.
12. West Trash/Recycle Area – The west trash recycle area is proposed on OP zoned property and this cannot
be approved. The trash area is necessary for the multi-family development, which is not permitted in OP.
Relocate the trash/recycle area to the BC property.
13. SEPA Checklist – The submitted SEPA checklist needs to be revised/updated to address each of the
following comments:
A 7. Clarify the phasing of the daycare.
A 10. A forest practice permit maybe required.
A 11. Clarify the phasing.
A 12. Clarify; further expand the specific project location. Add “located in the City of Federal Way,
King County, WA,” as this checklist will eventually be reviewed and seen by agencies and other parties
throughout Washington State.
A 5. Clarify that the northwestern most property will not be developed, and provide a wildlife habitat
statement. Clarify; is this portion to remain as undeveloped habitat in perpetuity or until developed in
the future etc.
Mr. David Ratliff
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B 7. Clarify and expand about possible contamination of the former auto junkyard. The junkyard parcel
is not included and evaluated in the 2006 Enco Site Assessment. Identify site testing requirements for
lead and arsenic from the Assarco Plume.
B 8. Please note, the comprehensive plan designations of the parcels should be consistent with the
current zoning. The referenced comprehensive plan designations on the checklist are likely incorrect;
however, the current comprehensive plan map on the city’s website also appears to be incorrect.
B13. Reference the human body buried at the site identified in the submitted Enco Site Assessment.
What is the plan and mitigation if a body is found?
B15. Provide an estimate of the number of school children expected upon completion of construction
and occupancy.
14. Regulated Wetlands –
a. The 60-foot wetland buffer shown on the site plan on the west side of the site is not approved. The
wetland on the far west side of the site is shown with a 60-foot wetland buffer. This wetland buffer
width is discussed in a July 16, 2018, Habitat Technologies letter review to the city, and the Habitat
Technologies Letter report identifies the wetland as a Category III wetland rating, with 17 points for
total function and includes a total of 4 habitat points.
City staff concurred with the Habitat Technologies Report and wetland rating in an August 10, 2018,
letter to Habitat Technologies. However, the City Council amended the city’s critical area regulations
on July 2, 2019, and the wetland buffer widths were changed. Under the current FWRC, the
minimum buffer width of a Category III wetland is 80 feet. Your wetland consultant will need to
update their Wetland Z analysis report and provide the wetland buffer rating, classification, habitat
score, etc., per the FWRC currently in effect. Upon an initial glance at the current FWRC 19.145.420,
a Category III wetland with 4 habitat points has an 80-foot wetland buffer.
The site plan will need to be revised to keep all improvements and land surface modifications outside
of the wetland buffer.
b. The wetland consultant and civil engineer shall address how the development and hardening of the
majority of the subject property will affect the hydrology of Wetland Z. Measures shall be implemented
to not adversely impact the hydrology and functions of Wetland Z.
15. Open Space –
a. Sheet L1.0 has the wrong standard for usable open space, and the calculation and plan sheet need to
be revised to meet FWRC 19.220.050, note 11. In summary, 34,650 square feet of usable open space
is required for the proposed 231 units, not 23,100 as identified on L1.0. Revise table on L1.0 and
specifications accordingly to meet the minimum FWRC requirements.
b. What are dimensions of the balconies for individual units? FWRC 19.220.050 note 11 has minimum
dimensional requirements for open space and balconies, etc.
c. What are the two unidentified squares north and west of play area A on sheet L1.1?
d. To meet the purposes of Process III review, usable recreation area should be provided on both sides
of 13th Place South.
e. What outdoor recreational opportunities are provided on-site for residents aged 13 – 18 years old?
Plan sheet L1.1 specifies outdoor usable recreation areas for children aged 2 – 12, but nothing is
shown for ages 13 – 18.
Mr. David Ratliff
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16. Smoking Area – A designated smoking area is required for both the east and west sides of the proposed
development. The smoking area shall not be visible from the public rights-of-way, and not adjacent to the
wetland buffer.
17. Parking Stall Count and Parking Analysis – City staff concurs with the FWRC total parking stall count
requirement of 478 stalls, based on the proposed unit type, for the 231 units, plus 3,733 square feet of
ground floor commercial, plus 10,171square feet of future daycare as proposed. Plan sheet page 12
identifies 478 parking stalls are provided in surface and structured parking.
The following comments must be addressed:
a. A parking layout and preliminary design for structured parking was not submitted with the
application. As the project review progresses, at a minimum a conceptual stall layout must be provided
for structured parking that meets at a minimum, the stall counts proposed for each structure.
A parking analysis for the proposal was prepared February 20, 2020by TENW.
The last sentence of the parking analysis under conclusion states: “Therefore, the analysis of parking
demand for the proposed Landmark Apartments project concluded the proposed supply of 479 stalls would exceed
forecasted demand, provide adequate surplus of on-site parking during peak periods, and a reduction of FWRC
19.130.080(2) is justified.”
b. Why does the TENW parking analysis justify a reduction in parking, when the proposed site plan
shows the parking stall count proposed meets the minimum FWRC count requirement?
c. City staff does not concur with the evaluation of the TENW parking analysis, as the Parking
Demand Study Table uses data from as far back as 2002, and the most current data on the table is
2013. Data needs to be updated. This data is also questionable for comparison purposes, without
providing and comparing unit/bedroom mix data of the compared facilities.
d. City staff does not concur with the analysis in the Puget Sound Properties Unit Composition Table in
the TENW analysis. This table needs to be revised to include at a minimum the three Devco
properties built within the City of Federal Way, and the development just outside Federal Way City
limits as comparable. This will provide more local geographical comparable analysis.
e. City staff in the Police Department (see the enclosed June 18, 2020, Sperry email) have raised
significant concerns about parking demand and off-site overflow parking problems at all three existing
Devco properties constructed in the City of Federal Way. If the last sentence in the first paragraph of
page five of the TENW report is referring to the three Devco properties in Federal Way, then city
staff does not concur with this statement by TENW which says: “These existing residential properties
all have similar bedroom mixes, market characteristics, and do not generate off-site parking demand.”
As requested above, provide an analysis of these three projects in Federal Way as compared.
f. Identify any measures proposed to assure any peak parking periods will not result in off-site overflow
parking in nearby areas such as: Celebration Park; Federal Way Public Schools adjacent properties;
and other nearby commercial sites.
g. Identify how the parking stalls are assigned to tenants. Are parking stall(s) included in the monthly
rental cost of each unit, or are parking stalls an additional cost for each unit?
h. Note, changes to the site plan, unit count, unit mix, and commercial area sizes may occur from
addressing city code requirements and the parking stall count and design will need to be adjusted
accordingly.
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18. Parking Area Design – Dimensions are not provided on site plans for the parking stalls and drive aisle
widths. City standard for ninety-degree parking stalls is 18 feet depth, and 25.5-foot-wide two-way drive
aisles. It appears the proposed parking stalls and drive aisle widths total approximately five to eight feet
below the city standard. Increase the stall depth/drive aisle width, etc. A two-foot parking overhang may
be allowed in certain applications, but if the parking overhangs into the required perimeter landscape
areas or pedestrian pathways, then the required perimeter landscape area or walkway width needs to be
seven feet minimum width.
19. Environmental Site Assessment Soils Contamination &Assarco Plume Soils Testing – A July 12, 2006,
Environmental Site Assessment by EnCo Environmental was submitted with the application. The EnCo
report does not address all of the parcels (Appendix A, Figure 2). One parcel not evaluated is parcel
172104-9034, which was the former auto junkyard. The site assessment indicates portions of the site were
previously an airplane hangar and airstrip, auto repair, auto junkyard, etc. The report also indicates the
likelihood of the following on on near the site: human body (page 9); soil contamination with petroleum
(page 12); clandestine drug labs (page 19); rusty metal drums; and homeless camps.
Please address each of the following comments:
a. Provide further information on the potential soils’ contamination and remediation process on parcel
9034 and any other applicable parcels. This is contained as a recommendation on page 26 of the report.
b. The date of the EnCo report is approximately 14 years old. Is there an update to this report?
c. What is the process and proposed action if human remains are encountered as identified on page 9 of
the report.
d. Provide information on how the recommendations on page 26 of the EnCo report and/or the
recommendations of an updated environmental report will be implemented.
e. Provide a soils’ testing report regarding lead and arsenic contamination from the Tacamoa Asarco
Smelter Plume. No information was submitted with the application regarding lead and arsenic levels
at the site. Follow the latest Department of Ecology Guidelines for the Tacoma Plume testing. See
the city’s May 6, 2019, preapplication letter for further information regarding this subject. This initial
testing and evaluation needs to be done prior to the issuance of a SEPA threshold determination.
20. School Access Analysis – The school access analysis will need to be updated and revised to meet both
Federal Way Public Works Depatrtment comments and Federal Way Public Schools standards. Safe
walking areas for school children getting to and from school bus stops is required as part of the health,
safety, and welfare criteria of Process III review.
21. Affordable Units – 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 as required
by FWRC 19.110.010.
22. Rooftop and Ground Mounted Equipment – The submittal does not provide detail on the location and
screening for ground mounted and rooftop mechanical equipment. Identify both ground mounted and
rooftop equipment.
a. For rooftop mechanical equipment, per FWRC 19.110.170, vents, mechanical penthouses, elevator
equipment, and similar appurtenances that extend above the roofline must be surrounded by a solid
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sight-obscuring screen that meets the following criteria: (a) the screen must be integrated into the
architecture of the building; and (b) the screen must obscure the view of the appurtenances from
adjacent streets and properties.
b. For ground mounted equipment, per FWRC 19.125.050, Type I landscaping is intended to provide a
solid sight barrier to totally separate incompatible land uses. This landscaping is typically found “…
around outdoor storage yards, service yards, loading areas, mechanical or electrical equipment, utility
installations, trash receptacles, etc.”
At the Devco Uptown Apartments, ground mounted HVAC units were not addressed during the site
plan review and became an issue during construction. HVAC units shall not be placed in front of
ground floor commercial like Uptown.
23. Retaining Walls – Retaining walls must meet FWRC 19.125.160(6) and 19.120.120. Please address the
following comments and revise plans accordingly.
a. Provide a written response of how the proposed retaining walls along the southwesterly property
edge meet each of the standards in FWRC 19.105.160(6)(a-c).
b. Some of the walls proposed along the southwestern property line and west property line do not
include a required minimum three-foot landscaped setback as required in FWRC 19.120.120(3)(b).
c. Identify materials and designs of any retaining walls visible from the right-of-way or adjacent properties.
24. Geotechnical Report – The geotechnical report indicates there are no geologically hazardous areas on the
site, and the site is suitable for development. No further action on this item.
25. Use Process III Decisional Criteria – Provide a narrative demonstrating how the proposal satisfies FWRC
19.70.150(3)(a-f).
26. Notice of Application Status - See the June 11, 2020, correspondence to David Ratliff regarding the status of
the Notice of Application.
27. Contact Waste Management and provide city staff an email or other written correspondence from Waste
Management staff that the size and location of the proposed trash enclosure area is acceptable.
Waste Management’s contact is:
Dian L. Young Waste Management
Commercial Route Manage 701 2nd Street NW
South Sound – WM Auburn, WA 98001
dyoung15@wm.com 253-804-6815 office / 253-455-0355 cell
Public Works – Development Services Division
Kevin Peterson, kevin.peterson@cityoffederalway.com
Public Works Development Services has reviewed the materials submitted for the referenced project and
finds the application complete. The following technical review comments will need to be addressed prior to
land use approval, and/or final SEPA determination:
Mr. David Ratliff
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SEPA Issue
1) Section A.10 – It appears the applicant will need to prepare and record a Boundary Line Adjustment
(BLA) to eliminate and/or rearrange the existing lot lines. This should be identified in the checklist.
Land Use Issues
1) Vertical datum shall be NGVD-29 per city requirements.
2) The plans show two parallel storm drain “mains” in 13th Place South, with both mains eventually
discharging to the detention vault to the east. Typically, there is a single main conveyance system along
one side of the road, with inlets and crossings at certain intervals based on road grade. The engineer
needs to provide an explanation for the reason behind the parallel systems.
3) All Solid Waste and Recycling (SWR) enclosures shall conform to FWRC 19.125.150, which includes
guidelines for floor area, access, drainage, and cover (as necessary).
4) Current plans show one SWR enclosure near the “future” Building D, away from the new multi-family
building, which doesn’t appear to lend itself to be within a reasonable walking distance for the residents
of Building C. The applicant should re-evaluate the site to determine a more reasonable location.
5) The cover sheet shall include the following: total existing parcel area; total parcel area after right-of-way
dedication; total impervious area of new development on-site (exclude public street improvement areas);
and total area to be dedicated for right-of-way.
6) Provide separate plan sheets that show the proposed detention vaults and outlet control structures.
Include a minimum of two cross-sections through each vault, cut at 90-degrees to each other, with at
least one section showing the outlet control structure. Each plan and section view shall be “to-scale.”
7) Sheet GP-01 shows a small amount of grading within the wetland buffer adjacent to the west of the site.
Unless otherwise approved by the city’s planning division, be advised that all grading needs to stay
outside of the buffer.
8) The landscape plan indicates low-growing shrubs within the planter strips between the public road and
sidewalk. Per city development standards, this area shall be planted with sod.
9) Street trees shall be chosen from the city’s street tree list (City Detail 3-48). Tree species depends on the
width of the planter strip (either four or six feet), and shall be 2.5-inches caliper.
10) Plans show some improvements on city parks property, north of the site (the driveway extended west of
13th Place, in alignment with South 330th), including parts of retaining walls. While an easement (5837598)
and recorded documents 930507200 and 9709020181 are shown along this alignment, it’s unclear to what
extent the full intended uses of these recorded documents are for. The applicant will need to provide
proof that the easements are still in effect, and that they are allowed to use this/these easements on parks
property, and if the improvements are allowed as shown. Easement recording. number 5837598 is not
listed in the title report. The applicant will need to verify the easement, recording number, and provide a
copy of the easement document to the city.
Mr. David Ratliff
Page 13 of 19
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11) The engineer will need to confirm, and provide the analysis, that hydrology to the wetlands to the west of
site is maintained in the developed condition, as it is in the current, undeveloped condition. The applicant
will also need confirmation from a certified wetland biologist that the hydrology is, or will be, maintained
in the developed condition.
Final Engineering
The following comments are intended for information only at this time, but will need to be addressed
during the final engineering plan design:
1) At the time of building permit submittal, the public street improvement plans (13th Place South, 15th
Avenue South, and South 330th Street) can be included with the building permit plan sets; however, the
street improvement plans shall be on their own plan and profile sheets, separate from the other site
improvement plans.
2) A final street lighting plan shall be submitted with the final engineering plans. The streetlight plan shall
incorporate all standards and specifications of the City of Federal Way.
3) Final vault design (structural) shall incorporate the loading requirements of South King Fire and Rescue
(SKFR) Guideline #10.006 for fire apparatus with outriggers. The vault structural design will be reviewed
by the city’s third-party reviewer, with all review expenses paid by the owner/applicant.
Public Works – Traffic Division
Sarady Long, sarady.long@cityoffederalway.com
The Public Works Traffic Division has finished its review of the submitted materials and provides the
following technical review comments:
Plans Comments
1. The civil plans must depict the correct frontage improvement and right-of-way dedication along the
subject property on 13th Place South, South 330th Street, 15th Avenue South, and South 332nd Street.
2. The subject property frontage on South 332nd Street must be improved to a Type “R” street. At a
minimum, the improvement shall consist of 40 feet paved road, 4-foot planter strips with street trees, 6-
foot sidewalk, street lights, and 3-foot utility strip, all within the public right-of-way. Furthermore, the
intersection radius must be designed to accommodate a school bus.
3. The depicted Type “R” improvement on 13th Place South is not correct. Thirteenth Place South shall be
constructed to a Type “M” street, consisting of a 36-foot street, 6-foot planter strips with street trees, 8-
foot sidewalks, and street lights in a 70-foot right-of-way.
4. A mini-roundabout should be installed at the 13th Place South and South 330th Street intersection for
traffic control. The applicant may explore other alternative options of traffic control for this intersection.
Mr. David Ratliff
Page 14 of 19
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5. It appears part of the driveway next to Building D is located on parks property. Provide documentation
from the Parks Department permitting this use.
6. Consolidate pedestrian crossing on 13th Place South between the two sites (Building C on the west side
and recreational center on the east side) to one central and direct location. The internal pedestrian
walkway should be designed to guide pedestrians to this crosswalk. In addition, a rectangular Rapid
Flashing Beacon (RRFB) shall be installed at the crossing to promote pedestrian safety crossing the street.
7. The proposed development will likely generate significant pedestrians to and from Celebration Park. As
such, the applicant shall provide a pedestrian connection on the west side of 13th Place South from South
330th Street to Celebration Park Road. This connection will provide a safe pedestrian path from the
development to the park.
8. Submit a Vehicle Turning Diagram for the South 330th Street/13th Place South and South 332nd Street/15th
Avenue South intersection. This diagram will show how the appropriate design vehicle, such as school
bus, can maneuver the site without encroaching onto opposing traffic lanes or mounting a curb.
Coordinate with the Federal Way School District on the appropriate school bus template.
9. Show the conceptual street lighting along the property frontage on 13th Place South, South 330th Street,
South 332nd Street, and 15th Avenue South. A details design is not required at this time.
10. According to FWRC 19.135.280, there may be only one driveway for each 330 feet of lot frontage. This
property does not have the 660 feet minimum street frontage to allow a second access on 13th Place
South. Furthermore, driveways must be located no closer than 150 feet to any street intersection, or to
any other driveway, whether on or off the subject property. As such, one of the driveways on 13th Place
South must be closed. The applicant may submit a street/driveway modification request to the Public
Works Director.
11. For driveways that serve uses other than single-family residential uses and zero lot line townhouse
developments, the maximum driveway width is 30 feet for a two-lane two-way driveway and 40 feet for a
three-lane two-way driveway (FWRC 19.135.270). Driveway widths may be increased in order to provide
adequate width for vehicles that may be reasonably expected to use the driveway, as determined by the
Public Works Director.
12. Verify the intersection sight distance at all driveways on 13th Place South in meeting AASHTO, and
depict on the civil plan. The new 13th Place South road extension must be designed to meet all applicable
AASHTO sight distance requirements.
TIA Review Comments
1. The project description in the TIA does not match the description in the Process III application or the
concurrency permit application. Please verify and revise accordingly.
2. The build-out year in the TIA is not consistent with the concurrency application build-out year. Please
revise the build-out year in the TIA to 2021, consistent with concurrency application.
Mr. David Ratliff
Page 15 of 19
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3. The Transportation Engineer (ITE) Trip Generation Manual 10th Edition LUC 820 (Shopping Center) may
be used for the proposed 4,165 square feet retail portion, but staff does not support using the 34 percent
pass-by rate. Additionally, the proposed 50 percent reduction in PM trips for the day care center is not
supportive by staff without supporting documentation.
4. The proposed three percent annual traffic growth rate to the existing counts to estimate the horizon year
volume is acceptable.
5. The 2019 traffic counts depicted about 575 vehicles utilize the park road during the PM peak period.
With the construction of 13th Place South road extension, some of the through traffic (no park related
traffic) will be expected to be diverted to 13th Place South. The future turning movement estimates by
TENW should provide the best engineering estimate of the percentage diversion. Furthermore, South
332nd Street extension from 13th Place South to SR 99 will likely alter the surrounding trip, and therefore,
should be incorporate into the trip diversion.
6. Page 10 – Site Access and Circulation: The sight distance analysis identified meets the City of Federal Way design
entering sight distance requirements. Verify if the sight distance meets AASHTO intersection sight
requirement and not entering sight distance. Attach all applicable calculations to the back of the traffic report.
7. Page 10 – Site Access and Circulation: Depict the intersection sight distance triangle on the plan and attach as
a figure.
8. The TIA should also address the safe pedestrian crossing on 13th Place South. A consolidated crossing
with RRFB and onsite walkways guiding pedestrian to the RRFB crossing should be provided to increase
pedestrian safety.
9. The adopted level of service (LOS) is a volume/capacity ratio less than 1.20 for signalized (except in City
Center, where the standard is an area average of 1.10), or a volume/capacity ratio of less than 1.00 for
unsignalized intersections. Levels of service are defined by the 2000 edition of the Highway Capacity
Manual (HCM). Provide the HCM 2000 printout instead of the HCM 2010.
10. Peak hour factors for signalized intersections for exiting conditions may use either actual existing PHF’s
by approach, or use the peak 15-minute period for the entire intersection and multiply those volumes by
four. For future year analysis, a default PHF of 0.95 for the entire intersection may be used, or if the
existing intersection PHF based on total entering volume is higher than 0.95, the exiting value may be
used. For unsignalized intersections, existing approach PHF’s shall be used.
11. Page 16 – On-Site Parking Supply: Parking will be reviewed and approved by the Planning Division.
12. Page 16 – Project Mitigation Measures: Traffic impact fee will be assessed at the time of the building permit
submittal. The proposed reduction of 50 percent of the traffic impact fee for the day care proposal is not
support by staff. The applicant must provide supporting documentation, such as trip generation study, to
the city for review.
13. Figure 8 on page 14 depicts 2023 Project PM Peak Hour Traffic Volumes, but the spreadsheet in the
back of the report specifies 2021. Please clarify.
Mr. David Ratliff
Page 16 of 19
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SEPA Checklist – Transportation
1. The project description in Section 11 of the SEPA checklist does not match the description in the TIA.
Verify which one is the correct project scope and revise accordingly.
2. Update the Transportation section 14(d) to include street improvement and right-of-way dedication on
South 332nd Street.
Federal Way Police
Lindsey Sperry, lindsey.sperry@cityoffederalway.com
Please address all Police Department comments in Lindsey Sperry’s June 18, 2020, and June 23, 2020, emails
(enclosed).
Federal Way PARC’s
Jason Gerwin, jason.gerwin@cityoffederalway.com
Contact Jason Gerwin regarding questions regarding adjacent city property.
South King Fire and Rescue
Sean Nichols, sean.nichols@southkingfire.org
Water Supply
Fire Flow
A Certificate of Water Availability, including a hydraulic fire flow model, shall be requested from the water district and
provided at the time of the building permit application.
Fire Hydrants
Fire hydrants shall be within 100 feet of fire department connections (FDC’s) and shall be on the same side of the
road to prevent roads from being obstructed by fire hoses.
*Hydrant spacing along access roads and location in relationship to buildings and sprinkler FDC
shall be approved by Fire Marshal’s Office
Fire hydrants shall be in service prior to and during the time of construction.
Emergency Access
Fire apparatus access roads shall comply with all requirements of Fire Access Policy 10.006:
http://southkingfire.org/DocumentCenter/Home/View/24.
Designated and marked fire lanes may be required for emergency access. This may be done during the plans
check or prior to the building final. Requirements and marking options can be found in Title 10 of the Des Moines
Municipal Code: http://www.codepublishing.com/WA?DesMoines/
Fire apparatus access roads shall be installed and made serviceable prior to and during the time of construction.
Mr. David Ratliff
Page 17 of 19
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Storm water detention vaults shall be rated for outrigger loading.
Vehicle Access Gates
All vehicle access gates shall comply with the Gate Policy (if gates are installed):
http://southkingfire.org/DocumentCenter/Home/View/21
Fire Department Lock Box
A recessed fire department “Knox” brand key box shall be installed on each of the buildings near the front
entrance. Location(s) will be approved by the plan reviewer or Deputy Fire Marshal onsite.
Fire Sprinkler System
An NFPA 13 fire sprinkler system is required in all buildings.
An automatic fire sprinkler system shall be installed in all occupancies where the total floor area included within
the surrounding exterior walls on all floor levels, including basements, exceeds 5,000 square feet. Fire walls shall
not be considered to separate a building to enable deletion of the required automatic fire-extinguishing system.
The system demand pressure (to the source) required in a hydraulically designed automatic fire sprinkler system
shall be at least 10 percent less than the correlative water supply curve pressure.
Standpipe
A Class 1 Standpipe is required.
A Class I standpipe system is required in buildings where the floor level of the highest story is located more than
30 feet above the lowest level of the fire department vehicle access.
Buildings four or more stories in height shall be provided with not less than one standpipe for use during
construction. Such standpipes shall be installed when the progress of construction is not more than 40 feet
(12 192mm) in height above the lowest level of fire department access. Such standpipe shall be provided with
fire department hose connections at accessible locations adjacent to usable stairs. Such standpipes shall be
extended as construction progresses to within one floor of the highest point of construction having secured
decking or flooring.
Elevator
The elevator(s) shall be sized to accommodate an ambulance stretcher.
Where elevators are provided in buildings four or more stories above grade plane, at least one elevator shall
be provided for fire department emergency access to all floors. The elevator car shall be of such a size and
arrangement to accommodate a 24-inch by 84-inch ambulance stretcher in the horizontal position.
Fire Alarm
A fire alarm system is required.
City code requires an automatic fire detection system in all buildings exceeding 3,000 square feet gross floor area.
The fire alarm system is required to monitor the sprinkler system, including water flow. Provide full notification
as required by NFPA 72. Complete coverage smoke detection is not required for this project. This fire detection system shall
be monitored by an approved central and/or remote station.
Mr. David Ratliff
Page 18 of 19
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Emergency Responder Radio Coverage
All buildings shall have approved radio coverage for emergency responders within the building based upon
the existing coverage levels of the public safety communication system at the exterior of the building.
(http://southkingfire.org/DocumentCenter/View/279)
Fire Suppression System
If any retail space includes a restaurant, an approved fire suppression system is required for all type 1 kitchen hoods.
Roof Access:
Stairway access to the roof shall be provided in the building with a roof slope less than 33.3 percent (2015 IFC 504.3).
Smoke Control
If a height increase is obtained by using IBC 504.4.1, a smoke control system shall be installed in accordance with
IBC/IFC 909. Ensure the smoke control conceptual plan is submitted at the same time as the garage plans are
submitted for review as smoke control review may have an impact on the building design.
Federal Way Public Schools
Sally Mclean, smclean@fwps.org
Please address all FWPS comments in the April 18, 2020, and July 1,2020, emails from FWPS (enclosed).
Lakehaven Water and Sewer
Brian Asbury, basbury@lakehaven.org
Regarding the city’s application completeness review for the subject application/project, the applicant has
completed and submitted to Lakehaven an application for Certificate(s) of Availability, and Lakehaven issued
those certificates on May 24, 2019. However, no other application has been submitted to Lakehaven that is
necessary to be able to determine the applicant’s specific requirements for connection to Lakehaven’s water
and/or sewer systems to serve the subject property. As previously noted, the applicant will need to submit an
application for either a Developer Pre-Design Meeting or Developer Extension Agreement for Lakehaven to
formally commence the water and/or sewer plan review process. Lakehaven encourages owners, developers,
and/or applicants to apply for Lakehaven processes separately to Lakehaven, and sufficiently early in the pre-
design/planning phase to avoid delays in overall project development.
CLOSING
Please be aware that this review does not preclude the city from requesting additional information related to
any of the topics discussed above, or any other elements of the proposal. Please submit revised application
materials as appropriate, accompanied by the completed “Resubmittal Information Form” (enclosed).
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.
All materials for resubmittal need to be submitted electronically thru the city’s on-line permit center portal on
the city’s website at Document Upload Link, or https://www.cityoffederalway.com/node/4588.
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.
Mr. David Ratliff
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If you have any questions regarding this letter, please contact me at jim.harris@cityoffederalway.com.
Sincerely,
enc: Resubmittal Information Form
BLA Handout
Building Height Handout 151
Lindsey Sperry Email 6/23/20, Includes String to 6/18/20 Email
Sally McLean FWPS, Email 4/18/20
Jen Thomas, FWPS, Email 7/1/20
c: Robert “Doc” Hansen, Planning Manager
Kevin Peterson, Engineering Plans Reviewer
Cole Elliot, Public Works Development Services Manager
Rick Perez, City Traffic Engineer
Sarady Long, Senior Transportation Planning Engineer
Lindsey Sperry, Federal Way Police
Jason Gerwin, Federal Way PARC’s
Sean Nichols, South King Fire and Rescue
Brian Asbury, Lakehaven Water & Sewer District
Sally McClean, Federal Way Public Schools, smclean@fwps.org
Jen Thomas, Federal Way Public Schools, jthomas@fwps.org
Garrett Wise, Blueline, g.wise@thebluelinegroup.com
Jake Drake, Blueline, j.drake@thebluelinegroup.com
Stephen Sullivan, stephen.sullivan@heartlandwa.com