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19-102629FILE CITY OF 0 L,,S %�W�Fe ra Way Centered on Opportunity July 15, 2019 Mr. John Everett ESM Consulting Engineers LLC 33400 8th Avenue South, Suite 205 Federal Way, WA 98003 iohn.everett@esmn MLcox Re: File #19-102629-00-PC, PREAPPLICATION CONFERENCE SUMMARY Saghalie at Twin Lakes Subdivision, 34220 21st Avenue SW, Federal Way Dear Mr. Everett: CITY HALL 33325 8th Avenue South Federal Way, WA 98003-6325 (253) 835-7000 www cityoffederalway. com Jim Ferrell, Mayor Thank you for participating in the preapplication conference with the City of Federal Way's Development Review Committee (DRC} held June 20, 2019. We hope that the information discussed at that meeting was helpful in understanding the general requirements for your project as submitted. This letter surnm a izes comments given to you at the meeting by the members of the DRC. The members who reviewed your project and provided comments include staff from the city's Planning and Building Divisions, Public Works Deparrment, and representatives from Lakehaven Water and Sewer District and South King Fire and Rescue. Some sections of the Federal Wray Revised Code (FWRC) and relevant information handouts are enclosed with this letter. Please be advised, this letter does not represent all applicable codes. In preparing your formal application, please refer to the complete FWRC and other relevant codes for all additional requirements that may apply to your project. I, Natalie Kzmieniecki am the key contact for your project; I may be contacted at 253-835-2638, or natalie.kan ieniecki ci Toffederalwa .coFor specific technical questions about your project, please contact the appropriate DRC representative as listed below. Otherwise, any general questions about the preapplication and permitting process can be referred to your key contact. PROJECT DESCRIPTION The proposal is to subdivide approximately 7.6 acres into about 26 single-family lots. The west half of the site is improved with the Twin Lakes Park and Ride facility. MAJOR ISSUES Outlined below is a summary of the major issues of your project based on the plans and information submitted for preapplication review. These issues can change due to modifications and revisions in the plans. The major issues section is only provided as a means to highlight critical requirements or issues. Please be sure to read the comments made by all departments in the following section of this letter. Mr. John Everett Page 2of15 July 15, 2019 • Planning Division 1. A boundary line adjustment (SLA), or other legal segregation, is required between parcels 242103- 9048 and 242103-9008 to isolate the park and ride area from the proposed subdivision. • Public Works Development Services Division 1. There is a known off -site, downstream stormwater conveyance restriction. The applicant may choose to fix the conveyance restriction, OR provide a Level 3 Flow Control pond on -site. e Public Works Traffic Division 1. Tran*or1;a1kn Coneunency Management (FE RC 19.90) — A transportation concurrency permit with the application fee of $4,938.00 is requited for the proposed project. 2. Trafc Impact Fees (FWRC 19.91) — Traffic impact fees are required for each residential dwelling unit, to be assessed at building permit issuance. 3. Frontage Improvements (FW,RC 19.133.040) — Construct street improvements and dedicate right -of --way along SW 344th Street and 19s' Avenue SW. 4. Internal Road— Internal roads shall be a Type W street. DEPARTMENT COMMENTS Outlined below are the comments made by the representatives of each department present at the preapplication conference. Each section should be read thoroughly. If you have questions, please contact the representative listed for that section. COMMUNITY DEVELOPMENT — PLANNING DIVISION Natalie Kamieniecki, 253-835-2638, natalie.k-amienjecld@cityoffederalway.com 1. Zonin,g Designation and Density — The site is zoned RS7.2 (Single -Family Medium -Density Residential, one unit/7200 square feet.). Lots in the RS7.2 zone must be a minimum lot size of 7200 square feet unless otherwise allowed under the FWRC. Please refer to FWRC 18.55.040 for cluster plat regulations and FWRC 19.100.010(2) for affordable housing regulations for lot size reduction options. 2. Review Pmcess — A subdivision of ten or more lots and/or tracts requires a review and public hearing on the preliminary plat application by the city's Hearing Examiner. In summary, following application submittal, the city will review the application for completeness and technical comments. The first procedural decision point is the State Environmental Policy Aa (SEPA) review and determination. Following conclusion of the SEPA review, city staff will present the staff report and recommendation on the preliminary plat to the Hearing Examiner, who then makes the final decision on the preliminary plat application. The Hearing Examiner's written decision on the preliminary plat is based on the applicant satisfying criteria pursuant to FWRC 18.35.170(3). The decision of the Hearing Examiner may be appealed pursuant to FWRC 18.35.210. After the final decision on the preliminary plat, engineering plans must be submitted and reviewed by the city's Public Works Department. Following review and approval of engineering plans, construction of plat infrastructure may begin_ Substantial completion of plat improvements is required prior to final plat review and decision by the City Council as described below. Doc ID: 79244 19-102629-00-PC r—) iMr. John Everett Page 3 of 15 July 15, 2019 A preliminary plat informational bulletin and Master Land Use application are enclosed. The application must be prepared in accordance with the submittal requirements listed in the enclosed informational bulletin and in accord with FWRC standards. 3. State Environmental Policy Act (SEPA) — The proposed subdivision is not categorically exempt from environmental review pursuant to Wlasbington Administrative Code (WAC) 197-11-800 and is subject to a threshold determination. A completed environmental checklist must be submitted with the Master Land Use application. A thoroughly completed checklist that gives comprehensive answers to each item will expedite the review process. The public, government agencies, and tribes will be invited to comment on the checklist during a 14-day comment period. An environmental threshold determination made by the director must be rendered prior to public hearing on the preliminary plat application. 4. Application/Review Fees — Contact staff at the Permit Center (, rrrlltcenter@cityaffederalway.corn, or 253- 835-2607) to inquire about application fees in place at the time of application submittal. Also, any third party reviews by city consultants for review and assistance with wetland consultations must be pre -funded and paid by the applicant. 5. Environmentally Critical Areas —The application must include the appropriate critical area studies pursuant to the standards of FWRC 19.145.080, and necessary permitting applications related to each critical area feature as they are applicable to the preliminary plat. Wetlands — Wetlands are indicated on the property. The presence or absence of wetlands must be verified by a qualified professional. The wetlands and buffers on site must be classified per the city's wetland rating system in FWRC 19.145.420. A wetland delineation, classification, and associated wetland report prepared by a qualified wetland biologist in accordance with FWRC Chapter 19.145, Article IV must be provided. 6. Public Notice — The preliminary plat and SEPA review require a notice of application. The applicant will be responsible for supplying a map and list of all properties within 300 feet of the subject property. Three sets of stamped mailing envelopes for each property owner with the department's return address must accompany the map and list. The city's GIS Department provides this service for a nominal fee (less the postage and envelopes). Please see the enclosed bulletin for further information. The applicant will also be required to pay for and post city supplied large notice boards at the appropriate times. 7. Design Criteria and Improvements — Subdivisions are subject to the subdivision design and improvements criteria set forth in FWRC Chapters 18.55 and 18.60, respectively. It is the responsibility of the applicant to identify how the proposed subdivision meets applicable design and improvements criteria and is therefore, entitled to the land division. 8. Buildable Lands Calmlation — Please provide the following information in tabular form on the site plan: Doc ID: 79244 19-102629-00-PC Mr. John Everett Page 4 of 15 July 15, 2019 Information for Buildable Lands Calculation (Please provide this information in tabular form on the site plan.) Category #Acres Gross Land Area — Acreage of the site prior to any dedications or set -asides. GiticalAreas—Acreage precluded from development due to wetlands and buffers; streams and buffers; regulated lakes and buffers; shoreline setbacks; flood hazard areas; erosion hazard areas; and landslide hazard areas. Rights -of -Way — Acreage dedicated for public rights -of -way (e.g. street widening). Do not include private access easements and private roadways internal to multi -family and/or senior housing, commercial, or industrial complexes. Public Purpose — Acreage of site to be used for retention/detention/drainage facilities; open space and parks, or other on -site public facilities. Do not include public utilities easements or landscaping. Net Land Area — Gross land area minus critical areas, rights -of -way, and public purpose. 9. Lot Cluster Plat Regulations — 1118.55.040 Cluster subdivision. (1) Purpose. The term "cluster subdivision" applies to both long and short subdivisions. The purpose of cluster subdivisions is to provide design flexibility, sensitivity to the surrounding environment, and innovation consistent with the site and the comprehensive plan; promote compatibility with housing on adjacent properties through lot size and design; promote affordable housing; promote reduction of impervious surface; promote usable open space; and promote the retention of native vegetation. (2) Standards. (a) The gross land area available for cluster subdivisions must be a minimum of two acres. (b) Lots created in a cluster subdivision may be reduced in size below the minimum required in FWRC Title 19, up to one-half of the size of the underlying zoning requirement, but in no case smaller than 5,000 square feet, per lot; provided, that minimum setback requirements are met. This provision cannot be used together with FWRC 19.110.010(4)(a) (affordable housing bonus). (c) When the cluster subdivision abuts a single-family zoned neighborhood, the lots in the proposed development immediately adjacent shall be no less than the neighboring lot size, or the underlying zoning minimum lot size minus 10 percent, whichever is smaller. (d) Refer to FWRC 19.120.110 for additional development standards for sites with slopes of 15 percent or greater. (e) Open space. (i) Open space created through cluster subdivisions shall be protected from further subdivision or development by covenants filed and recorded with the final plat of the subdivision. (ii) Any subdivision created by this section must provide all open space on -site and it must be all usable except up to five percent can be buffer. (iii) All usable open space must be readily identifiable with the development and easily accessible by the residents. Usable open space should be the central focus and an amenity for the project. 19-102629-00-PC Doc ID: 79244 Mr. John Everett Page 5of15 July 15, 2019 (3) Approval criteria. The innovative or beneficial overall quality of the proposed development shall be demonstrated by the following criteria: (a) The subdivision provides innovative development, otherwise not allowed, but which promotes the goals of the comprehensive plan for architectural compatibility with single-family housing on adjacent properties. (b) The subdivision results in 15 percent common open space of which at least 10 percent of the gross land area must be usable on -site open space, which is identified with the development and easily accessible to residents. (c) Native tree retention in accordance with FWRC 19.120.130 et seq. (d) Cluster lots immediately adjacent to existing neighborhoods have incorporated design elements through lot size and architecture to be compatible as approved by the community development services director. (e) The cluster subdivision will not result in destruction or damage to natural, scenic, or historic features. (� Each dwelling unit shall meet the design standards in the FWRC community design guidelines for cluster subdivisions." 19.115.120 Design for cluster residential subdivision lots. (1) Garages shall be provided for all residential lots except if the lot is in a multifamily zone. (2) Front entryways should be the prominent feature of the home. Attached garages should not compose more than 40 percent of the front facade of the single-family home if the garage doors are flush with the front facade, or will be set back a minimum of five feet from the rest of the front facade. Detached garages should also be set back a minimum of five feet from the facade. (3) If garage access is provided from alleys, the front yard setback can be reduced to 15 feet. (4) Each dwelling unit shall be intended for owner occupancy" 10. Affordable Housing Re gulations — Pursuant to FWRC 19.100.010(2), new single-family developments in the RS-7.2 zoning district have the option of providing affordable dwelling units as part of the project. Projects including affordable dwelling units may reduce minimum lot size as follows: "Those lots in a new single-family conventional subdivision or short subdivision which are proposed to contain affordable dwelling units may be reduced in area by up to 20 percent of the minimum lot size of the underlying zoning district; provided, that the overall number of dwelling units in the subdivision may not exceed 10 percent of the maximum number of units allowed in the underlying zoning district." 11. Miscellaneous Residential Regulations — a) Maximum height of structures — 30 feet above average building elevation. b) Setbacks for structures are a minimum of 20-feet front yard and 5-feet side and rear. c) Corner lot side yard for that portion of the lot not adjacent to the primary vehicular access is 10 feet. d) Maximum lot coverage — 60 percent. e) Required parking spaces — minimum of two per dwelling unit. f) Driveway and/or parking pad may not be closer than five feet to any side property line. 19-102629-00-PC Doc ID: 79244 Mr. John Everett Page 6 of 15 July 15, 2019 12. Open Space — All residential subdivisions are required to provide open space in the amount of 15 percent of the gross land area of the subdivision site per FWRC 18.55.060(2). A minimum 10 percent of the open space is required to be usable open space, i.e. appropriate for active recreation areas. Additionally, any onsite open space must be set aside in a tract and owned in common, undivided interest by all property owners within the subdivision. All or some of the open space requirement may be satisfied by a fee -in - lieu payment at the discretion of the city's Parks Director, after consideration of the city's overall park plan, quality, location, and service area of the open space that would otherwise be provided with the project. The fee -in -lieu of open space is calculated on 15 percent of the most recent assessed land value of the property. If the fee -in -lieu option is chosen, a written request to Parks Director, John Hutton, is required. A copy of this request is a required component of the preliminary plat application. Usable open space design size and location options, along with provisions for access, improvements, ownership, and maintenance, will be reviewed in conjunction with review of the preliminary plat. Critical areas and buffers, conservation tracts, slopes, storm pond tracts, etc. do not qualify as usable open space. For a cluster plat, all open space must be on site, and a minimum of 10 percent of the open space shall be usable and integral to the development. We encourage you to consult the Bicycle and Pedestrian Plan and implement the trail plan as a component of the open space for the proposed subdivision. Trail improvements would qualify as usable open space. 13. Landscaping Around Pond — A minimum width of three to five feet of landscaping strip for pond screening is required between the pond and roadway per FWRC 19.115.050. 14. Tree Retention/Replacement—The city's tree standards require each development/redevelopment to maintain a tree unit density. The minimum tree density requirements for RS zones are 25 tree units per acre. The required density for the subject property will be determined by multiplying the gross site acreage, minus streets and critical areas, by 25. A tree retention plan detailing how the subject property will meet tree unit density requirements shall be submitted with the preliminary plat application. Items required to be included in the plan are itemized in FWRC 19.120.040(2)(a) through (e). The table below identifies tree unit values for retained and replacement trees. FWRC 19.120.130-2 — Tree Unit Credits Retained Trees Tree Unit Credit Existing Tree 1" to 6" d.b.h. 1.0 Existing Tree > 6" to 12" d.b.h. 1.5 Existing Tree > 12" to 18" d.b.h. 2.0 Existing Tree > 18" to 24" d.b.h. 2.5 Existing Tree > 24" d.b.h. 3.0 Replacement Trees Replacement Tree - Small (Mature canopy area < 450 SF) .50 Replacement Tree - Medium (Mature canopy area 450 to 1,250 SF) 1.0 Replacement Tree - Large (Mature canopy area > 1,250 SF) 1.5 19-102629-00-PC Doc ID: 79244 Mr. John Everett Page 7of15 July 15, 2019 15. Clearing & Grading — With the preliminary plat application, a clearing and grading plan addressing items listed in FWRC 19.120.040(1)(a) through 0) is requit-ed. Prior to beginning clearing and grading activities, all critical areas and buffers, and trees/vegetation that are to be preserved within and adjacent to the construction area, shall be clearly marked and protected per guidelines prescribed within FWRC 19.120.160. Any retaining walls and rockeries can be a maximum of six feet in height and must comply with standards in FWRC 19.120.120. Preliminary designs for retainv:Fg walls shall be submitted with the preliminary plat application, and include cross sections and visual depictions of retaining walls. Pursuant to FWRC Chapter 19.120 Article IV, "Forest Practices Regulations," a Class IV General Forest Practices application may be required for timber harvest associated with the development of the site. If required, a completed forest practice application must be submitted with the preliminary plat application. This permit must be issued as either,part of the preliminary plat or prior to any timber harvest onsite. 16. SchoolAc-essAnalbj*—Pursuant to FWRC 18.55.070, pedestrian and bicycle access should be provided for established or planned safe school routes, bikeways, trails, transit stops, and general circulation. Please provide an analysis of access routes for schools serving this proposed preliminary plat. Off -site construction may be required in order to provide safe school access routes. Contact Jennifer Wojciechowski at 253-945-2071, or iiE9jcie@,f�vns^org. for information about the school access analysis requirements and assignment information. 17. School Impact Fees — School impact mitigation fees are to be paid at the time of an individual single-family building permit. 18. Exploratory Site Retvnnausance Work — Please provide city staff written notice before any site reconnaissance work occurs. If any geotechnical exploration, boring work, or any work in critical areas is to occur, this activity must be approved by city staff prior to this work as identified in FWRC 19.145.120(2). 19. Approval Duration — Per FWRC 18.35.220, preliminary plat approval shall expire five years from the date of the hearing examiner approval, unless the applicant requests an extension as provided in FWRC 18.05.090. 20. Final Plat — The final plat fee, in effect at the time of the final plat application, and items identified in FWRC 18.40.020 are required to process the final plat. Substantial completion of the plat infrastructure must occur prior to submittal and processing of the final plat application. The city allows bonding of only minor improvements. The City Council will take action on the plat and upon approval; the applicant will record the final plat drawing with the King County Recorder's Office. 21. Remrdsng — Following substantial completion} of subdivision improvements and City Council review of the final plat, the applicant will record the plat with the King County Recorder's Office The applicant is responsible for the plat recording fees. prior to recording the plat, all surveying, and monumentation must be completed. In addition, all other required improvements must be substantially completed as determined by the departments of Community Development and Public Works. Doc ID: 79244 19-102629-00-PC Mr. John Everett Page 8 of 15 July 15, 2019 PUBLIC WORKS — DEVELOPMENT SERVICES DIVISION Kevin Peterson, 253-835-2734, kevin.peterson@cityoffederaiway.com Land Use Issues — Stormwater 1. Surface water runoff control and water quality treatment will be required per the 2416 King County Surface Water Derign.MaNtal (KCSWDM). This project meets the requirements for a Full Drainage Review. At the time of preliminary plat subrrnittal, a preliminary Technical Information Report (TIR), addressing the relevance of the project to the nine core and five special requirements of the KCSWDM will be required. A Level 1 downstream analysis shall also be provided in the preliminary TIR. 2. The project lies within a Conservation Flow Control area. However, due to the downstream conveyance issue noted under the Major Issues section above, the applicant can choose to either Fix the conveyance problem, or provide a Level 3 flow control pond for the project. In addition to flow control facilities, Best Management Practices (BMP's) are required as outlined in the KCSWDM. The project also lies within an Enhanced Basic Water Quality Area. Water quality treatment shall be designed to meet the treatment criteria of the Enhanced Basic Water Quality Menu. Beside those water quality treatment systems identified in the KCSWDM, the city will also accept those systems that have been approved for Enhanced Basic Treatment under the Washington State Department of Ecology (WADOE) General Use Level Designation (GULD) criteria. 3. If infiltration is proposed, soil logs prepared by a licensed geotechnical engineer or septic designer must be provided to verify infiltration suitability. 4. Detention and water quality treatment facilities for subdivisions are required to be above ground (i.e. an open pond), within a separate storm drainage tract, and dedicated to the city for future maintenance. Detention and water quality facilities may be within the same tract. Underground facilities are allowed only with approval from the City of Federal Way Stormwater Management Division. A written request for the use of underground facilities shall be submitted prior to-, or at the time of-, preliminary plat submission. 5. Show the proposed location and dimensions of the detention and water quality facilities on the preliminary plans. If more than one acre will be disturbed during construction, a National Pollutant Discharge Elimination System (NPDES) construction stormwater permit may be required. Information regarding this permit can be obtained from the Washington State Department of Ecology at 360-407-6048, or h www.e ova. ov ro ams w stormwater canstructi n ixudex.htnl. Right -of -Way Improvements See the Traffic Division comments from Senior Transportation Planning Engineer Sarady Long, for traffic related items. 2. Dedication of right-of-way is required to be conveyed to the city through a statutory warranty deed. The dedicated area must have clear title prior to recording. All stormwater treatment and detention requirements outlined above may apply to any improvements within the public right-of-way. Doc ID: 79244 19-102629-00-PC Mr. John Everett Page 9of15 July 15, 2019 4. FWRC 19.135.280 requires that driveways serving residential uses may not be located closer than 25 feet to any street intersection. Lots and intersections within new subdivisions or short plats must be designed to meet this standard. Engineering (El) Permit Issues 1. Engineered plans are required for clearing, grading, road construction, and utility work. Plans must be reviewed and approved by the city. Engineering review fees (2019) are $3,004.00 for the first 18 hours of review for plats, and $167.00 per hour for additional review time. A final TIR shall be prepared for the project and submitted with the engineering plans. Both the TIR and the plans will require the signature/ seal of a professional engineer registered/licensed in the State of Washington. 2. In addition to engineering approval, projects that will be filling or grading in the area of the future building pads are required to obtain a separate grading permit from the Building Division. 3. To assist the applicant's engineer in preparing the plans and TIR, the Federal Way Public Works Development Standards Manual (including standard detail drawings, standard notes, and engineering checklists) is available on the city's website at btW://www.cityoffederxnh dex.2spx?nid=171. 4. Bonding is required for all street improvements and temporary erosion and sediment control measures associated with the project. The bond amount shall be 120 percent of the estimated costs of the improvements. An administrative fee deposit will need to accompany the bond to cover any possible legal fees in the event the bond must be called. Upon completion of the installation of the improvements, and final approval of the Public Works Inspector, the bond will be reduced to,30 percent of the original amount and held for a two-year maintenance period. 5. The developer will be responsible for the maintenance of all storm drainage facilities (including the detention and water quality facilities) and street systems during the two-year maintenance period. During that time, the Public Works Inspector will make periodic visits to the site to ensure the developer's compliance with the maintenance requirements. Upon satisfactory completion of the two-year maintenance period, the remainder of the bond will be released. Maintenance for public roads and subdivision drainage facilities then become the responsibility of the city. Maintenance for private roads and drainage facilities, including short plats, remain the responsibility of the individual property owners. 6. When topographic survey information is shown on the plans, the vertical datum block shall include the phrase "DATUM: N.G.V.D.-29" or "DATUM: K.C.A.S.," on all sheets where vertical elevations are noted. 7. Drawings submitted for plan review shall be printed on 24" x 36" or 22" x 34" paper. Site plans shall be drawn at a scale of 1" = 20', or larger. Architectural scales are not permitted on engineering plans. 8. Provide cut and fill quantities on the clearing and grading plan. 9. Temporary Erosion and Sediment Control (TESC) measures, per Appendix D of the 2016 KCSWDM, must be shown on the engineering plans. 10. The site plan shall show the location of any existing and proposed utilities in the areas affected by construction. Doc ID: 79244 19-102629-00-PC O Mr. John Everett Page 10 of 15 July 15, 2019 PUBLIC WORKS — DEVELOPMENT SERVICES DIVISION Sarady Long, 253-835-2743, sarady.long@cityoffederalway.com Transportation Concurrency Analysis (FWRC 19.90) 1. Based on the submitted materials for 26 single-family detached housing lots, the Institute of Transportation Engineers (ITE) Trip Generation - 8th Edition, land use code 210 (Single Family Detached Housing), the proposed project is estimated to generate approximately 26 new weekday PM peak hour trips and 245 daily trips. 2. A concurrency permit is required for this development project. The PW Traffic Division will perform a concurrency analysis to determine if adequate roadway capacity exists during the weekday PM peak period to accommodate the proposed development. Please note that supplemental transportation analysis and concurrency mitigation may be required if the proposed project creates an impact not anticipated in the six -year Transportation Improvement Plan (TIP). 3. The estimated fee for the concurrency permit application is $4,938.00 (11 — 50 trips). This fee is an estimate and based on the materials submitted for the preapplication meeting. The concurrency applicant fee must be paid in full at the time the concurrency permit application is submitted with the land use application. The fee may change based on the new weekday PM peak hour trips as identified in the concurrency trip generation. The applicant has the option of having an independent traffic engineer prepare the concurrency analysis consistent with city procedures; however, the fee remains the same. Transportation Impact Fees (TIF) (FWRC 19.91) Based on the submitted materials for 26 single-family lots, the estimate traffic impact fee is $107,094 ($4,119 per dwelling unit). The total amount of the impact fees will be assessed and collected from the applicant when the building permit is issued, using the fee schedule then in effect. The applicant may request, at any time prior to building issuance, to defer the payment of the impact fee to final building inspection. If this option is selected, a covenant, prepared by the city to enforce payment of the deferred fees, will be recorded at the applicant's expense on each lot. Please, refer to defer payment of impact fee code for process. Street Frontage Improvements (FWRC 19.135) The applicant/owner will be expected to construct street improvements consistent with the planned roadway cross -sections as shown in Map III-4 in Chapter III of the Federal Way Comprehensive Plan (FWCP) and Capital Improvement Program (CIP) shown as Table III-10 (FWRC 19.135.040). Based on the materials submitted, staff conducted a limited analysis to determine the required street improvements. The applicant will be expected to construct improvements on the following streets to the city's planned roadway cross -sections: ■ SW 344LI, Street shall be Type "K" local street, consisting of a 44-foot street with curb and gutter, 6-foot planter strips with street trees, 8-foot sidewalks, and street lights in a 78-foot right-of-way. Assuming a symmetrical cross section, 3/4 street improvements are required. It appears there is adequate right-of-way to accommodate the required road improvements. 19-102629-00-PC Doc ID: 79244 O Mr. John Everett Page 11 of 15 July 15, 2019 ■ The comprehensive plan Map III-3 depicts a three -lane north -south minor collector road (19th Avenue SW) extending from the existing stub -out south of SW 342nd Street to SW 344th Street. The applicant would be expected to construct 19th Avenue SW Street to a Type "S" local street, consisting of a 36-foot street with curb and gutter, 4-foot planter strips with street trees, 5-foot sidewalks, and street lights in a 60-foot right-of-way. ■ The internal road (SW 343 Street) serving lots 15 through 22 shall be a Type "W" street, consisting of a 28-foot street with curb and gutter, 4-foot planter strips with street trees, 5-foot sidewalks, and street lights in a 52-foot right-of-way with a temporary turn -around. SW 343=d Street should conceptually align with the existing stub -out to the east. 2. The applicant may make a written request to the Public Works Director to modify, defer, or waive the required street improvements (FWRC 19.135.070). Information about right-of-way modification requests is available through the Public Works Development Services Division. These modification requests have a nominal review fee currently at $334. 3. Tapers and transitions beyond the project frontage may be required as deemed necessary for safety purposes. The taper rate shall be WS2/60, or as directed by the Public Works Director. Access Management (FWRC 19.135) 1. All lots shall be accessed by a public street right-of-way (FWRC 18.55.020). In certain cases, lots may be accessed by an ingress/egress and utilities easement or alley, subject to the requirements established in the city of Federal Way Public Works Development Standards. Residential lots should not have direct lot access onto SW 344d' Street. 2. Driveways serving a single family dwelling unit abutting two streets should be at least 25 feet from the beginning of the street radius. 3. No street, or combination of streets, shall function as a cul-de-sac longer than 600 feet (FWRC 18.55.010). 4. Block perimeters shall be no longer than 1,320 feet for non -motorized trips, and 2,640 feet for streets (FWRC 18.55.010 and FWCP Policy TP4.2). PUBLIC WORKS — SOLID WASTE AND RECYCLING DIVISION Rob Van Orsow, 253-835-2770, robv@cityoffederalway.com Solid Waste & Recycling Design Considerations • Adequate space allocation is required for interior and exterior garbage, recycling, food waste, waste oil, yard debris, hazardous waste, or biohazard collection containers. Minimum recycling space allocation is established by FWRC 19.125.150. 19-102629-00-PC Doc ID: 79244 Mr. John Everett Page 12of15 July 15, 2019 • For basic solid waste and recycling needs within a single enclosure, clear interior dimensions measuring 10 feet deep by 20 feet across are recommended, along with a two -door swing -open or roll -open gate that spans the front width of the enclosure. When gate doors are opened, no structure or hardware should remain above grade across the enclosure opening. Gate pins/holes are preferred for holding gates in closed and open positions to ease service access and maximize the life of gate hardware. a Sites may require a larger enclosure, or multiple enclosures, to accommodate on -site user access and/or additional waste types and containers. • Plan for user access to interior waste and recycling storage areas/containers, and to exterior containers screened by enclosure(s). • Plan for unobstructed, safe enclosure ingress and egress for service vehicles, directly in line with enclosure openings. Allow appropriate turning radii for service vehicles, and minimize potential "blind spots" during ingress and egress. • Consider landscaping, setbacks, and screening requirements (based on FWRC 19.125.040[4] & [5]). • Note that larger -scale commercial or multi -unit housing developments may see long-term savings from the use of on -site waste compaction equipment. Planning for this equipment may require larger enclosure dimensions, defined overhead clearances, consideration of power utility access, and drainage management. • Mixed -use developments may also benefit from on -site waste compaction equipment. Additional mixed - use development considerations include: o Designated chutes and/or internal facility maintenance areas or services for tenants; o Moving waste and recycling streams from interior units to collection areas; and o Access by business tenants and/or residents to exterior waste and recycling areas. Help with many design parameters related to service access is available via the city's contracted solid waste services provider, Waste Management. Contact Senior Route Manager John Davis at 206-786-4530 (cell). LAKEHAVEN WATER AND SEWER DISTRICT Brian Asbury, 253-946-5407, BAsbury@lakehaven Water • Lakehaven issued a Water Certificate of Availability for the proposed project/property on June 9, 2019. The certificate is valid for one-year from the date of issuance. • Fire flow at no less than 20 psi available within the existing water distribution system is (and will be within the new onsite/subdivision system) a minimum of 1,000 GPM (approximate) for two hours or more. This flow figure represents Lakehaven's adopted minimum level of service goals for residential areas regarding performance of the existing water distribution system under high demand conditions. If 19-102629-00-PC Doc ID: 79244 Mr. John Everett Page 13 of 15 July 15, 2019 more precise available, and/or estimated onsite fire flow figures are required or desired, the applicant can request Lakehaven perform a system hydraulic model analysis (separate from, or concurrent with, an application for availability). The 2019 cost for a system hydraulic model analysis is ,$230.00. A Lakehaven Developer Extension (DE) Agreement will be required to construct new and water distribution system facilities for the proposed development, including extend -to -far -edge (east -central) in accordance with long-standing Lakehaven policy. Additional detail and/or design requirements can be obtained from Lakehaven by completing and submitting a separate application to Lakehaven for either a Developer Pre -Design Meeting or a DE Agreement. Lakehaven encourages owners, developers, and 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. + The associated DE Agreement must achieve a point of either Substantial Completion or Acceptance, as determined by Lakehaven, prior to activating any new domestic or irrigation water service connection(s). Based on the proposal submitted, preliminary estimated Lakehaven water service connection fees, charges, and/or deposits (2019 schedule) will be as follows. Actual connection charges will be determined upon submittal of service connection application(s) to Lakehaven. Connection charges are separate from any DE fees, charges, and/or deposits and are due at the time of application for service. All Lakehaven fees, charges, and deposits are typically reviewed and adjusted (if necessary) annually, and are subject to change without notice. o Water Service/Meter Installation, 1" preliminary size: ;$306.43 drop -in meter fee, per lot. Actual size(s) to be determined by Lakehaven based on UPC plumbing fixture count. o Capital Facilities Charge(s)-Water: ,$4,242.12 per Equivalent Residential Unit (ERU). Sewer • Lakehaven issued a Sewer Certificate of Availability for the proposed project/property on June 9, 2019. The certificate is valid for one-year from the date of issuance. A Lakehaven Developer Extension (DE) Agreement will be required to construct new sanitary sewer system facilities necessary for the proposed development, including extend -to -far -edge (east central) in accordance with long-standing Lakehaven policy. A new, separate parallel "service" main is recommended in 191h Avenue SW, to avoid deep sewer service connections to sewer trunk in the right-of-way area. Minimum horizontal separation between the new "service" main and other underground utilities (including existing sewer system trunk) is three -feet; however, five -feet or more is preferred by Lakehaven. Terminus depth of the easterly sewer system extension should be a minimum of 10-feet. Additional detail and/or design requirements can be obtained from Lakehaven by completing and submitting a separate application to Lakehaven for either a Developer Pre -Design Meeting or a Developer Extension Agreement. Lakehaven encourages owners, developers, and 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. ■ The associated DE Agreement must achieve a point of either Substantial Completion or Acceptance, as determined by Lakehaven, prior to activating any new sewer service connection(s). • Based on the proposal submitted, preliminary estimated Lakehaven sewer service connection fees, charges, and/or deposits (2019 schedule) will be as follows. Actual connection charges will be determined upon submittal of service connection application(s) to Lakehaven. Charges -Payable -in -Lieu -of -Extension Doc ID: 79244 19-102629-00-PC Mr. John Everett Page 14 of 15 July 15, 2019 (CPILOE) is assessable against the property for sewer facilities previously constructed that provide direct benefit to the property. Monthly CPILOE amount adjustments expired in 2010, and the CPILOE amount indicated below is due until/unless paid in full. If a DE Agreement is required, CPILOE (full amount) are due prior to and as a condition of scheduling the Lakehaven preconstruction meeting. Connection charges are separate from any DE fees, charges, and deposits and are due at the time of application for service. tall Lakehaven fees, charges, and deposits are typically reviewed and adjusted (if necessary) annually, and are subject to change without notice. o Sewer Service Connection Permit: $420.23, per lot. o Capital Facilities Charge(s)-Sewer: $3,978.13 per Equivalent Residential Unit (ERU). o CPIL.OE (191h/2P1 SW Sewer Trunk): $171,653.34. General All Lakehaven Development Engineering related application forms, and associated standards information, can be accessed at Lakehaven's Development Engineering web pages (h tvww.lakehaven.o 2Q4 Devel ment e ■ All comments herein are valid for one (1) year and are based on the proposal(s) submitted and Lakehaven's current regulations and policies. Any change to either the development proposal(s) or Lakehaven's regulations and policies may affect the above comments accordingly. SOUTH KING FIRE AND RESCUE Sean Nichols, 253-946-7242, sean.nichols@southkingf"ire.org Water Supply A Certificate of WlaterAvailability including a hydraulic fire flow model* shall be requested from the water district and provided at the time of building permit application. *Ahydraulic fire Bow modelis required for single family residences that exceed 3600 square feet, including garages and covered areas. Fare Hydmnir This project will require at least one additional fire hydrant within the subdivision. Every building lot shall have a fire hydrant within 350 feet All measurements shall be made as vehicular travel distance. A fire hydrant is required either on Lot 22 or Lot 3/4 to meet the distance requirements. Fire hydrants shall be in service prior to and during construction. Emergency Access Fire apparatus access roads shall comply with all requirements of Fire Access Policy 10.006: h soutlikin fimor DocumentCen Home View 24. Doc ID: 79244 19-102629-00-PC Mr. John Everett Page 15 of 15 July 15, 2019 Fire Sprinkler System Determination of requirements for residential fire sprinklers, if any, are made at the time of the building permit application. CLOSING This letter reflects the information provided at the preapplication meeting and is intended to assist you in preparing plans and materials for formal application. We hope you found the comments useful to your project. We have made every effort to identify major issues to eliminate surprises during the city's review of the formal application. The completion of the preapplication process in the content of this letter does not vest any future project application. Comments in this letter are only valid for one year as per FWRC 19.40.070(4). This is a preliminary review only and does not take the place of the full review that will follow submission of a formal application. Comments provided in this letter are based on preapplication materials submitted. Modifications and revisions to the project as presented for this preapplication may influence and modify information regarding development requirements outlined above. In addition to this preapplication letter, please examine the complete FWRC and other relevant codes carefully. Requirements that are found in the codes that are not addressed in this letter are still required for your project. If you have questions about an individual comment, please contact the appropriate department representative noted above. Any general questions can be directed towards me, the key project contact, Natalie Kamierniecki, at 253-835-2638, or natae.kan-iertiecki(@.citvofiFederaiNvay.com. We look forward to working with you. Sincerely, Natalie Kamieniecki Associate Planner enc: Master Land Use Application, Bulletin #3 Preliminary Plat Application Checklist#37 SEPA Checklist, Bulletin #4 c Kevin Peterson, Development Services Sarady Long, Traffic Division Sean Nichols, King County Fire and Rescue Brian Ashbury, Lakehaven Water and Sewer District RJM 19-102629-00-PC Doc ID: 79244 2421039048 34210 SW 344TH —67-0530006Ow 142 67 5300070 1822 1 1895450390 Lakeliaven WATER & SEWFR DISTRICT 38002 0 1931f 7503800280 —7 g750 800250 f 1924 750380027 904 1920 5038002 0 .7503800290 1710 1926 4" DI 8" 7503800300 —� 1927 750 8003400032, 750193310 9055{38 2;J1I 2421039008 34220 •`' 9" DI QD 1.5" PVC 18 "' 179 1895 1 189F781T .95450 1763 2421039018 34408 89545 310 18 54503 0 173 1745 18 545031 1723. 2421039051 1605 1921 1921 1 1921(*90191 10130 Q5 10140 1895450280 4403 34425 54 50 9 1715 —.E 10160 4 �1895450270 3 409 j00 34433 NOTE: Lakehaven Water and sewer Saghalie at Twin Lakes Subdivision rM District neither warrants nor guarantees 19-102629-PC the accuracy of any facility information 0 100 200 provided. Facility locations and conditions are subject to field verification. 6/13/2019 BIA Feet 1. 2. 3. 4. 5. 6. 7. CITY OF Federal Way June 20, 2019 9:00 a.m. NAME Natalie Kamieniecki Associate Planner ��-►✓, Lcr�-cis Pre -application Conference Sign in Sheet COMMUNITY DEVELOPMENT REVIEW COMMITTEE City Hall Hylebos Room 8. Blf C s 9. 10.1 11. 12. Project Name: Saghalie Preliminary Plat . . . - 1- r I St ♦ ___ File Number: 19-102629-PC DEPARTMENT L D1yISI0N Community Development Ac,g h6r0es, LLc_ TELEPHONE NuMBER/EMAIL 253-835-2638 natalie.kamieniecki@cityoffederalway. com -Np - 55& 7 cJN� •-s C:rnP�rrr ,vssfc�vrna .. ?pG-2°l`1-1-7-7-7 t✓LL pM,4r: @Atja;cAn UtRl 5,`Lk01M LP RAYE*j wft-Ze— 253— —5* 7 "3—%1&-'V 1 �vt_biv. A0AN4 el ?�-3 _ 0�S - 2io�-t l CID- WT\ -Z,s3> r3 3 s -fir 1� eSM (sNVpr%& �nlb�nk a Inn. eJ¢✓e�• �Clr� c_'�n, 2,s3 825Y-l�la"3 bIr-t,rilgat�`�jrj ��y'na�,,�s �C(xG r>�1a . �a��rs �► ��iul .cam em O N S U L,T I N G E N G I_N E E R 5 tic May 31, 2019 Mr. Robert "Doc" Hansen Planning Manager Department of Community Development City of Federal Way 33325 81h Avenue S Federal Way, WA 98003 RE: Request for Pre -Application Conference Saghalie at Twin Lakes Dear Mr. Hansen: Job No. 1352-024-019 RECEIVED JUN 0 3 2019 CITY OF FEDERAL WAY COMMUNfTY DEVELOPMENT Please accept this letter and accompanying information as our request for a pre -application conference with the City of Federal Way for a potential subdivision of approximately 6.79 acres of vacant property located just east of the WSDOT Twin Lakes Park-n-Ride northeast of the intersection of SW 344th Street and 181h Avenue SW. The following is a general project narrative describing the proposed project concept as well as questions in bolditalics related to the various design elements: Zoning and out Desi n Surrounding uses are as follows: • North: Single -Family Residential ■ South: Single -Family Residential • East: vacant Single -Family Residential West: Transit parking The subject site is zoned RS7.2. The proposed lot layout is intended to meet all underlying zoning and lot dimension requirements, lot coverage, building setbacks and impervious surface maximums. Lot size averaging is utilized in this propose layout . Gc� �'1�t.11V Q. Please confirm conditions ifany to allow lot size averaging. The proposed internal street network depicted creates a 19th Ave SW connection thru to future SW 344th St along with future road connection to the east. Q.• Does the proposed intemal road network appear to comply W#7 FWRC 18.55.010 (3)? Q. Please confirm road connection to the east is, in fact required. 33400 Bth Ave S. Ste 205 Tel (253) 838 6113 Everett (425) 297 9900 Civil Engineering Land Planning Federal Way WA 99003 Fax (253) 838 7104 Toll Free (800) 345 5694 Land Surveying Landscape Architecture www esmcivil corn 3D Laser Scanning GIS Mr. Robert "Doc" Han May 31, 2019 Page 2 Retaining walls may be proposed to help create level building sites. Q Please confirm the restrictions on retaining wall height and any exceptions Q. Are there limitations on the height of graded slopes? (assuming geotechnical engineering approved design) Q. Please confirm building setback requirements for comer lots Critical Areas No critical areas are mapped or observed on the subject property as confirmed during review of adjacent "Pena Plat" to the south. Q.• Does the City have any additional information related to critical areas in this location? Street Network and Frontage Improvements Q.• Please confirm the ROW width requirements for the proposed street network including SW 344h .St Please confirm the frontage improvement requirements for SW 344m Street Traffic Peak -hour traffic volumes generated by the proposed project are expected to exceed 20 trips. Q. Does the required tiafiic concurrency permit application address all necessary scope for traffic impact/safety analysis, or will a separate study be required? Q• Are there any known LOS or other traffic safety deficiencies pertinent to the project location? Utilities Water and sanitary sewer services provided by Lakehaven Water and Sewer District are assumed to be available in the adjacent right-of-ways to the property. It is anticipated that these existing water and sewer facilities will provide adequate capacity for development proposed on site. Q.• Please comment on the probable connection points and any noted capacity or pressure concerns relative to serving the subject site. Stormwater The project proposes to locate a stormwater facility at the location depicted and discharge to the adjacent open conveyance flowing north toward SW 341 st St. It is assumed that the existing WSDOT stormwater facility downstream is sized to provide bypass or future overflow conveyance from upstream properties. Q.• Does the City ha ve any information or concem about the existing open ditch conveyance? Q. Please confirm that WSDOT facility is suitable/sized for receiving upstream stormwater from this project Was proper consideration made for future upstream development? ESM Mr. Robert "Doc" Hanz May31,2019 Page 3 Q. What are the anficipated stormwater standards for the proposed project given its location? Are the any known conveyance deficiencies? Q. Please confirm pond access and landscape buffer requirements (if any) Q.• What would the Citjls concerns be regarding potential enlargement of existing WSDOTpond adjacent to Me west? Open Space The applicant prefers to meet open space requirements via payment in lieu. Q.• Please confirm the approval process and liming expectations for fee -in -lieu requests? Q.• Can both recreation and passive open space requirements be met via fee in lieu if allowed? Tree Retention Q. Can the trees located in the critical areas orbuffer be counted towards tree retention? Q.• Please confirm that tree inventory may be conducted via representative sampling. Pre -Application.. Conference Submittal The following items are included in this submittal: Project Narrative (this letter); Master Land Use Application; Conceptual Site Plan Drawing (7 copies); Submittal fee of $571.00; We understand that these materials constitute a complete submittal and ask that the City schedule Pre -Application Conference at your next available date. Please contact me upon your receipt and review of this information to confirm the date and time. Thank you for your attention to this project and we look forward to working with the City. Very truly yours, ESM CONSULTI ENGINEERS, LLC. IN EVERETT Planning Director Enc: As Noted CC: Dmitriy Mayzlin Ikesm8lengrlesm-iobsO 352WT01 Mocumentlletter-001.dou CITY OF FEDERAL WAY COMMUNITY DEVELOPMENT DEPARTMENT DEVELOPMENT REVIEW COMMITTEE TRANSMITTAL DATE: June 4, 2019 TO: Cole Elliott, Development Services Manager Greg Kirk, Building Plans Examiner Rick Perez, City Traffic Engineer Brian Asbury, Lakehaven Water & Sewer District Chris Cahan, South King Fire & Rescue Jennifer Wojciechowski, Federal Way School District .�;MOB. A7k.-,1,Pk. XPiarheATraan&t)rMLVA\ &\ST,b41\V0ZiV1lsi % FROM: Natalie Kamieniecki, Associate Planner FOR DRC MTG. ON: June 13, 2019 - Internal June 20, 2019, 9:00am - with applicant FILE NUMBER(s): 19-102629-PC RELATED FILE NOS.: None PROTECT NAME: SAGHALIE AT TWIN LAKES SUBDIVISION PROJECT ADDRESS: 34220 21ST AVE SW ZONING DISTRICT: RS 7.2 PROJECT DESCRIPTION: Proposal to subdivide approximately 7.6 acres into approximately 26 single family lots. LAND USE PERMITS: TBD PROJECT CONTACT: JOHN EVERETT ESM CONSULTING ENGINEERS LLC MATERIALS SUBMITTED: Master Application Project Narrative Vicinity Map Preliminary Site Plan ctiry OF Federal Way Centered on Opportunity June 5, 2019 Mr. John Everett ESM Consulting Engineers LLC 33400 8th Avenue South, Suite 205 Federal Way, WA 98003 CITY HALL 33325 8th Avenue South Federal Way, WA 98003-6325 (253) 835-7000 wwwcityoffederalway. com FILE Re: File #19-102629-PC; PREAPPLICATION CONFERENCE NOTICE Saghalie at Twin Lakes Subdivision, 34220 21st Avenue SW, Federal Way Dear Mr. Everett: Jim Ferrell, Mayor The Community Development Department is in receipt of your preapplication conference request. The application has been routed to members of the Development Review Committee and a meeting with the project applicant has been scheduled as follows: 9:00 a.m. — Thursday, June 20, 2019 Hylebos Conference Room Federal Way City Hall, 2nd Floor 33325 8th Avenue South Federal Way, WA 98003 We look forward to meeting with you. Please coordinate directly with anyone else you would like to attend the meeting as this will be the only notice sent by the department. If you have any questions regarding the meeting, please contact me at nat�lie kamieniecki ecityoffederalway.com. or 253-835-2638. Sincerely, F Natalie Kamieniecki Associate Planner Doc. I.D. 79245 19-I02629-00-PC l RECEIVED MASTER LAND USE APPLICATION DEPARTMENT OF COMMUNITY DEVELOPMENT J U N 0 3 2-019 33325 81h Avenue South CITY OF Federal Way, WA 98003-6325 FederalWay MM' -NI D V AL WA'( 253-835-2607; Fax 253-835-2609 car����i� �1=Vf~LOPtti,4�P�T LL'�V�1'.4it�'pl�l'dl:rellLL'i1L.1:C1111 APPLICATION NO(S) U 2 r Date Project Name Property Address/Location 19000 Block Of SW 344th Street Parcel Number(s) Portion Of 242103-9008 Project Description-Subdivision±7.6 ac. 91 B 2 r ± PLEASE PRINT Type of Permit Required Annexation Binding Site Plan Boundary Line Adjustment Comp Plan/Rezone Land Surface Modification Lot Line Elimination X Preapplication Conference Process I (Director's Approval) Process II (Site Plan Review) Process III (Project Approval) Process IV (Hearing Examiner's Decision) Process V (Quasi -Judicial Rezone) Process VI SEPA w/Project SEPA Only Shoreline: Variance/Conditional Use Short Subdivision Subdivision Variance: Commercial/Residential Required Information RS-7.2 Zoning Designation HDR Comprehensive Plan Designation $0 Value of Existing Improvements Unknown Value of Proposed Improvements International Building Code (IBC): Unknown Occupancy Type Unknown Construction Type Applicant Name: RMMJJ HHo dd� L.Lc Address: 9675 4VIM Street, Suite 105 City/State: Mercer Island, WA Zip: 98040 Phone: 206-294-1777 Fax: Email: dmitriy@americanclassichomes.com Signature; 7__ Agent (if di%rent than Applicant) Name: ESM Consulting Engineers Address:33400 8th Ave S, #205 City/State: Federal Way, WA Zip: 98003 Phone: 253-838-6113 Fax: Email: john.everett@esmcivil.com Signature: Owner Name: WSDOT c/o Eva Betts Address: City/State: Zip: Phone: 360-705-6944 Fax: Email: BettsE@wsdot.wa.gov Signature: Bulletin #003 —January 1, 2011 Page 1 of 1 k:\Handouts\Master Land Use Application Legend Storm Drainage Line Stormwater Pipe Water Main Sewer - Gravity Easement9103210123 10 P ;7 2Si1 �Ai1f1�0@l0 ti+ 2 J nlrosoelto I _ f I E iF f ':�q09 — N i _n 115 VQAtMACaE PENA SHORT PLAT II U21 W BOIB j Site Details Parcel: East Portion of 242103-9008 , Address: Twin Lakes Park and Ride, E::.:. City: Federal Way Zip Code: 96023 JUdedlction: City of Federal Way Size: 6.79 AC f 295,XXX SF Current Use: Vacant (Single -Family) RS7.2 Zoning Min Lot Size: 7,200 SF L.1 tezlwBs2� Max Lot Coverage: 60% AWE. T Max Height: 30' Min Building Setbacks: 2e31W�1 Front: 20' Interior Sides: 5' 1 Corner Sides: 10' Rear: 5' Road Standards Local Street y Right-of-way: 56' I! Pavement: 32' Planting Strip: 4' Sidewalks: 5' c 2 {•``F Fr- -- ,lD WT Obc Y v1 N �- 1921049018 ML Zo 19 j f. gZ• Tuvrl-AW0Cw1:, !� V rt RD-ST EXTENSION CENTERLINE. �s STu6 Fog f Cowasc7(c,J ? ll 1 Borr�lOa� T • t �V .ie1q 41 w+ww� MM7NH i d c m E m � r �0 5c10 J �pZ 3 m'10 N W ¢ o 0S 0 go �W o Z$0¢m r�E Y NC W „Ud1, rA w Z L Z E m w U c W 16ECM W o0 m� r aT 1 la p = 7 W V f0 N V N r 7 O^ D R E C � I HD W 0. aU �p