19-103818 (2)4CITY OF
s�. Federal Way
Centered on Opportunity
September 18, 2019
Mr. Adam Paul
AP Consulting Engineers PLLC
PO Box 162
Auburn, WA 98071
aep1u1@-apconstltingmgjncers.co
CITY HALL
33325 8th Avenue South
Federal Way, WA 98003-6325
(253) 835-7000
www.cityoffederalway.com
Jim Ferrell, Mayor
FILE
Re: File #19-103818-00-UP; USE PROCESS I "DIRECTOR'S APPROVAL"
Nelson Brush Removal/Security Fence, 34010 Pacific Highway South, Federal Way
Dear Mr. Paul:
The City of Federal Way's Community Development Department received your land use application on
August 8, 2019. The subject property is a vacant lot located at 34010 Pacific Highway South, Federal Way,
WA 98003 (parcel 202104-9080), This letter describes the project background, application decision,
conditions of site plan approval, review findings, conclusions, and procedural information resulting from the
Use Process I review of the application.
BACKGROUND
The applicant proposes to remove brush from the site and debris from the homeless encampment, remove
eight trees, and install an eight -foot tallvinylcoated chain -link security fence with a 24-foot wide gate on the
north side of the property for fire department access.
DECISION
The City of Federal Way's Community Development Department has completed the Use Process I
administrative review and hereby conditionally approves limited clearing on the subject property and
exempts the clearing plan approval requirements of Federal Way Revised Code (FWRC) 19.120.020 for
underbrush clearing on the subject property, and conditionally approves construction of the security fence
with associated removal of identified trees based on the conditions, findings, and conclusions noted below.
CONDITIONS OF SITE PLAN APPROVAL
1. The project is subject to a final planning inspection. To schedule the inspection, please contact Planning
Intern Will Golding at 253-835-2622.
2. The chain -link security fence shall be constructed to the proposed eight feet in height. Approval for fence
construction does not sanction any use of the enclosed vacant property. The fence will be considered
temporary in regards to any proposed future development of this property, as this fence impacts the
Mr. Adam Paul
Page 2 of 4
September 18, 2019
explicit intentions to facilitate pedestrian connectivity and pedestrian grid of future site development
identified in the Federal Way Village Master Plan.
3. Nothing may be stored inside the fence enclosure; the property must remain vacant unless an additional
land use permit, application is submitted to and approved by the City of Federal Way.
4. Landscaping in front of the fence will not be required and is discouraged in order to provide increased
visibility of the property in accordance with FWRC 19.115.010, crime prevention through environmental
design (CPTED).
5. This approval allows clearing brush and tree branches from approximately six inches above ground to a
height of approximately seven feet above ground. No coniferous trees more than 12 feet tall, or 3-inch
caliper deciduous trees (measured at 4.5 feet above ground level) may be removed other than those
identified for removal to construct the security fence. This work may be conducted with hand tools and
hand equipment; mini excavator or similar; and brush hog or similar.
6. Ground disturbance, grading, or land filling; access road construction; on -site vegetation piling; and on -
site burning are not allowed unless authorized through a separate development permit.
7. Clearing, grading, and tree removal on the subject property exceeding the scope of this proposal shall
constitute a zoning violation under FWRC 19.05.340. The purpose of this proposal is to removal a
limited number of trees to install a security fence in response to deter concerns arising from homeless
encampments.
FINDINGS
■ The subject property is zoned Community Business (BC). Pursuant to FWRC Title 19 "Zoning and
Development Code," 19.220 "Community Business (BC)," the property lies within the city approved
Federal Way Village Master Plan.
■ Proposed tree removal and security fence installation is not subject to review under the State Environmental
Policy Act (SEPA) as the scope of the proposed work will not impact environmentally critical areas or
associated buffers.
The subject property is located within a 10-year Wellhead Protection Zone for aquifer recharge. The
applicant is not required to submit a hazardous materials inventory checklist as the proposal will keep the
land vacant of any use other than the installation of a temporary chain -link security fence, leading to the
determination that no hazardous materials pose a risk on site at this time.
* FWRC 19.120.030(7) exempts clearing of underbrush from permit and code requirements contained in
FWRC 19.120.020 for, "Actions which must be undertaken immediately, or within a time too short to
allow for compliance with the requirements of this article, to avoid an imminent threat to public health or
safety; to prevent an imminent danger to public or private property; or to prevent an imminent threat of
serious environmental degradation." Based on information known to city and South King Fire & Rescue
staff confirming incidents of public threats and misdemeanor activity by trespassers encamped or hiding
on the property, this criterion is met.
19-103818-00-UP Doc. I.D. 79627
Mr. Adam Paul
Page 3 of 4
September 18, 2019
■ The proposal has been reviewed for consistency with all applicable zoning regulations, including FWRC
19.30, "Nonconformance"; FWRC 19.125, "Outdoors, Yards, and Landscaping"; and FWRC 19.115,
"Community Design Guidelines."
■ The security fence proposal includes a 20-foot front yard setback. Pursuant to FWRC 19.115.090(fl,
chain -link fences visible from the public right-of-way, and not screened by Type I landscaping shall utilize
vinyl -coated mesh, powder -coated poles, dark color(s), and architectural element(s), such as pole caps
and/or decorative grid pattern.
■ Pursuant to FWRC 19.125.170(3)(b), a minimum six -foot -high solid screening fence, wall, or other
appropriate architectural screening, surrounded by five feet of Type I landscaping, or a combination of
architectural and landscape features, is required by code around the outside area. The director has the
ability to determine that the required screening is not necessary, and after reviewing the site plan and
surrounding properties determined that the required five feet of type I landscape screening is not
conducive to the intent of FWRC 19.115.010, crime prevention through environmental design (CPTED),
mainly the intent to increase natural surveillance.
• Total tree units existing on site are 210. After removal of eight identified trees, the property will have 192
total tree units remaining to fulfill FWRC 19.120.130, tree and vegetation retention standards, of 20 tree
units/acre in BC zones, exceeding to the required 30 tree units on the 1.48-acre property.
■ The proposal is found to be consistent with the Federal Way Comprehensive Plan, all applicable provisions of
the FWRC; and upholds the public health, safety, and welfare of the Federal Way community.
CONCLUSIONS
The proposal has been reviewed for compliance with the FWRC, pertinent zoning regulations, and other
applicable city regulations. Based on the findings and conclusions of this review, conditional approval of the
project is recommended. This decision shall not waive compliance with future City of Federal Way codes,
regulations, and policies relating to this decision. The approval of the installation of the security fence in no
way allows for the use of this land as it will retain vacant.land use status. If the use of this property is sought
to be developed in any way, a new Master Land Use Application will need to be applied for with the City of
Federal Way's Permit Center and reviewed for compliance before a future decision is issued.
PROCEDURAL INFORMATION
The date of the decision is September 18, 2019. Pursuant to FWRC 19.55.050, any person who received
notice of the administrative decision may appeal in the form of a letter delivered to the Department of
Community Development Services (33325 8th Avenue South, Federal Way, WA 98003-9718) on or before
October 3, 2019. An appeal letter must contain a clear reference to the matter being appealed and a
statement of the alleged errors in the director's decision, including the identification of specific disputed
findings and conclusions made by the director. Please be aware that work on the project may not begin until
the end of the appeal period, other than the above referenced brush clearing and homeless encampment
debris removal.
19-103818-00-UP
Doc. LD. 79627
Mr. Adam Paul
Page 4 of 4
September 18, 2019
Since you are the only party of record you may waive your right to appeal this decision. Waiver of the right to
appeal does not affect the effective date of this decision. The city must receive this waiver in writing. If you
choose to waive your right to appeal, you could begin work on the proposal when the city receives your letter
waiving your right to appeal. This decision shall not waive compliance with future City of Federal Way codes,
policies, and standards relating to this development.
If you have any questions regarding this decision, please contact me at ' hare. oldie ci offederalway.com,
or 253-835-2622.
Sincerely4(
UV
William Golding
Planning Intern
enc: Approved Site Plan
19-103818-00-UP Doc. LD. 79627
CITY OF
Federal Way
Centered or, Opportunity
January 29, 2020
Mr. Curtis Nelson
627 East Francis Avenue
Spokane, WA 99720
curt a wtirbinc.com
CITY HALL
33325 8th Avenue South
Federal Way, WA 98003-6325
(253) 835-7000
www.cityoffederalway.com
FILE
Re: File #19-103818-00-UP; NOTICE OF VIOLATION FOR USE PROCESS I APPROVAL
Nelson Security Fence, 34010 Pacific Highway South, Federal Way, WA
Dear Mr. Nelson:
Jim Ferrell, Mayor
The City of Federal Way's Community Development Department provided land use approval on September
19, 2019, for the construction of a security fence on a vacant lot located at 34010 Pacific Highway South,
Federal Way, WA 98003 (parcel 202104-9080). This letter is to inform you of the city's recent knowledge of
violations on the property and requests you take corrective action to address the concerns listed below. This
letter presents background information on the conditional land use approval, observations made by city
employees, notice of land use approval and code violations, and a conclusion stating the course of action
moving forward.
BACKGROUND
On September 19, 2019, the city approved a proposal to remove brush and debris from a homeless
encampment, including removing eight trees, in order to install an eight -foot tall vinyl coated chain -link
security fence with a 24-foot wide gate on the north side of the property for fire department access.
Conditions of the land use approval decision are listed below:
CONDITIONS OF LAND USE APPROVAL
The project is subject to a final planning inspection. To schedule the inspection, please contact me at
253-835-2622, or Williarn.gol ' ci otFederalwv.com.
2. The chain -link security fence shall be constructed to the proposed eight feet in height. Approval for fence
construction does not sanction any use of the enclosed vacant property. The fence will be considered
temporary in regards to any proposed future development of this property, as this fence impacts the
explicit intentions to facilitate pedestrian connectivity and pedestrian grid of future site development
identified in the Federal Way Village Master Plan.
3. Nothing may be stored inside the fence enclosure; the property must remain vacant unless an additional
land use permit application is submitted to and approved by the City of Federal Way.
Mr. Curtis Nelson
Page 2 of 3
January 29, 2020
4. Landscaping in front of the fence will not be required and is discouraged in order to provide increased
visibility of the property in accordance with Fedv- d Way Revised Code TWRC) 19-115.010, crime
prevention through environmental design (CPTED).
5. This approval allows clearing brush and tree branches from approximately six inches above ground to a
height of approximately seven feet above ground. No coniferous trees more than 12 feet tall, or 3-inch
caliper deciduous trees (measured at 4.5 feet above ground level) may be removed other than those
identified for removal to construct the security fence. This work may be conducted with hand tools and
hand equipment; mini excavator or similar; and brush hog or similar.
6. Ground disturbance, grading, or land filling; access road construction; on -site vegetation piling; and on -
site burning are not allowed unless authorized through a separate development permit.
7. Clearing, grading, and tree removal on the subject property exceeding the scope of this approved
proposal shall constitute a zoning violation under FWRC 19.05.340. As indicated within conditions of the
approved land use, the proposal is to remove a limited number of trees (eight) to install a security fence
in response to concerns arising from homeless encampments.
CITY OBSERVATIONS
On January 23, 2020, a city employee observed unauthorized activities and development at 34010 Pacific
Highway South, Federal Way, WA 98003. Two recreational vehicles were observed to be parked within the
recently built security fence area. The two vehicles were parked in front of the access gate to the property and
block the designated access to the property for emergency vehicles. The vehicles were parked on an
unpermitted gravel parking pad development.
NOTICE OF VIOLATIONS
Based on January 23, 2020 observation, numerous concerns exist on this property that violating the conditions
of land use approval and multiple sections within the FWRC. The observed violations are listed below:
■ Condition 1 above was violated as no request for final inspection was ever received by city staff after the
land use approval was provided and the subsequent construction of the security fence.
• Condition 2 above was violated as the vacant parcel is currently being utilized for vehicle storage, which
is an unpermitted use and also violates conditions of the Federal Way Village Master Plan.
• Condition 3 above was violated as two recreational vehicles were observed to be stored in the property,
as well as no additional land use permits have been received from the property owner to utilize the vacant
property for any development purposes.
• Condition 6 above was violated as unauthorized ground disturbance has occurred as a result of the
construction of a gravel parking pad without any permit applications received by the city.
• The subject property is located within a 10-year Wellhead Protection Zone for aquifer recharge. The
unauthorized construction of a gravel parking pad and subsequent parking of vehicles in this space now
introduces the risk of hazardous materials entering into this protected aquifer recharge area and violates
FWRC 19.145.470, as well as requirements for parking surfaces to avoid this problem within FWRC
19.130.100(4).
19-103818-00-UP Doc I.D. 80086
Mr. Curtis Nelson
Page 3 of 3
January 29, 2020
■ The unauthorized construction of a gravel parking pad violates FWRC 19.130-210(1) as gravel is an
inferior surface material compared to the surface material of the right -of --way providing direct vehicle
access to the unauthorized parking area.
• The unauthorized parking of vehicles in the current location violates multiple codes, including FWRC
19.135.110 and 13.31.030(n), as these vehicles obstruct easement to the property, including emergency/
fire services. Continued emergency access easement obstruction can lead to a $150.00 per day fine, per
FWRC 8.55.030, which the property owner will be responsible to pay per FWRC 8.55.110.
CONCLUSIONS
Based on the observed violations, the city requests you remove the vehicles from this vacant property and not
park vehicles within the security fenced area moving forward. You will have 14 days to comply with this
request. In the event of failing to comply with this request, the city will issue a Notice of Violation (NOV]
which can lead to daily fines until all vehicles are removed from the property. Check with city staff regarding
obtaining final project inspection and the construction of a gravel parking pad. If you have any questions
regarding this letter, contact me at %viihmngnldin citvoffedetalxvay.com, or 253-835-2622.
Sincerely, `
William Golding
Planning Intern
4��
c: Angie Villalovos, Code Compliance Officer
Robert `Doc" Hansen, Planning Manager
19-103818-00-UP
Doc. I.D. 80086
R EEV s r)
FEB 14 2020
Community l)evOiOpn7en$
City of Federal Way Dep�irtrnent February 7, 2020
William Golding
Planning Intern
33325 8 h Ave. South
Federal Way, WA 98003-6325
RE: Response to your letter dated January 29, 2020, regarding
WIRB INC- 34010 Pacific Highway South, Federal Way, WA
Dear William Golding:
I am in receipt of your letter dated January 29, 2020, accusing me of being in violation of your conditions
of land use.
First, I would like to point out that I have taken the initiative and the expense of cleaning up the property
you accuse me of violating by removing dangerous and toxic debris left behind by the increasing
homelessness epidemic that plagues the City of Federal Way and endangers its residents and businesses.
This clean up personally cost me over $25,000, and I received no help or even a thank you from you or
anyone from the City of Federal Way, even though I have been a member of your business community for
nearly 30 years.
Second, it is disappointing to me that you cannot follow-through on your commitment to finalize the zoning
for this property, which was supposed to be done by January of 2020, but you have the resources to drive
by so that you can write me up for violations that are not warranted. I have addressed my response to this
preposterousness below:
Condition 1: You accuse me of violating a request for final inspection, however, why would I request a
final inspection when the fence is not considered complete? There are final touches and sections that
require additional attention that are still being worked on. When this work is complete and to our
satisfaction, you will be notified for a final inspection at that time. There is no indicated timeline or
required timeframe under which I am obligated to request an inspection. An inspection is required at the
completion of the project. Therefore, there is no violation.
Conditions 2 and 3: You accuse me of storing two recreational vehicles in this fenced off space. These
vehicles have been moved to the other side of the fence, which I own, to temporarily make room for
equipment and personnel who are still conducting work in and around the property. To have to move these
vehicles around the restrictive and tight -spaced parking lot several times a day is not practical for business
or labor costs and there is no other open space to utilize while work is being conducted. Therefore, since I
own the property, I am temporarily utilizing it to streamline the work effort and the work area. These
vehicles are not permanently parked there, they are not creating any hazard, they are not in anyone's way of
business or pedestrians, and they pose no danger to anyone or anything. Therefore, there is no violation.
Condition 6: You accuse me of unauthorized ground disturbance. I don't know who you sent out to make
these observations but they are incorrect and negligent in their accusation. There is NO ground disturbance
and NO parking pad. The change of dirt color in this area is left from the residue of the gravel that had to
be brought in as a requirement for building a fence that was level, aesthetically pleasing, and that would
improve the view from the road and the surrounding businesses. We had a quality fence built and made
sure it was constructed in a way that would deter vandalism and illegal trespassing. This required gravel in
some areas. The "pad" is some of the gravel that was left over and simply spread out over the dirt. There
is NO parking pad. And, fer your reference, this fencing cost over $45,000 to date and is a significant
improvement to the visual aspect of this area of Federal Way. Any visible ground disturbance is the result
of the toxic cleanup. Would you have preferred that we left all the feces, garbage and dangerous drug
paraphernalia throughout the area? Once again, I will point out, there is no violation on our part.
Page 2 of 2
City of Federal Way
William Golding, Planning Intern
February 7, 2020
You state that the area within the fencing is located within a 10-year Wellhead Protection Zone for aquifer
recharge and you accuse that we are now posing a danger to it. Again, I'd like to ask you: what about all
the homeless camps that existed on this land for the last 10 years that you did nothing about? This land was
occupied by vagrants that left human and animal feces everywhere, drug paraphernalia, and many other
dangerous toxins and refuse that we took the time and spent the money to remove and clean up properly,
which only adds value to the property, the entire area, and the City of Federal Way. The City of Federal
Way never addressed the dangers to the Wellhead Protection Zone until now, even though the way the City
left it created more of a threat not just to the so-called Wellhead Protection Zone, but also to the general
public, the surrounding businesses, and even the homeless people themselves. How is this double standard,
or newly created standard, a fair assessment on my business and activities?
I have worked hard to comply with the guidelines and restrictions set forth by the City of Federal Way. I
own a respectable business and own more than one property in this city. I am an advocate for the city and I
have done what I can to contribute to the clean-up and improvement to my property and adjacent
properties. I contribute to Federal Way's tax base and I expect to be treated fairly and professionally.
However, I do not appreciate the tone and approach you take toward businesses like mine that are working
hard, on your behalf and in the city's favor, to improve Federal Way. You should be working
collaboratively with business owners like me, as a supportive and enabling advocate, instead of working
against me, creating roadblocks to progression. If there is some concern you perceive may exist, why don't
you talk to me, as a tax paying business owner, about how we can work together to make things right, or at
least so you can understand what is going on, before you send out such a damning communication?
I will assume these issues are satisfactorily addressed and your accusations of violations is removed
immediately.
In addition, I would like to take this opportunity to suggest that your mayor and Economic Development
Department review how the City Planning Department works with businesses in your community. This has
been an ongoing difficult and disappointing experience to say the least. You have made owning property
and conducting business in Federal Way a difficult and disappointing task, and there doesn't appear to be
any effort to improve it in the near future.
I hope you will not use this response as any further excuse to delay the zone change that you committed to
having done last month.
Zis
elson
President and CEO
Western International Recovery Bureau
CC: Tim Johnson, Economic Development Director
Jim Ferrell, Mayor
Angie Villalovos, Code Compliance Officer
Robert Hansen, Planning Manager
I—)
.0':41k
CITY OF 1Q :t�ftmvwO
Federal Way
APPLICATION No(S) 1 `
RECEIVED MASTER LAND USE APPLICATION
DEPARTMENT OF COh1MUNrry DEVE:I.OPMENT
33325 8"' Avenue South
AUG 0 8 2019 Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
CITY OF FEDERAL WAY www.rityoffederalway.eom
GOMMUNn-Y DEVELOPMENT
10391.9-60^ li/ P Date (F l!
Project Name Nelson Brush Removal/ Security Fence
Property Address/Location 339XX Pacific I lighway South, Federal Way, WA
Parcel Number(s) 2021049080
Project Description Remove brush from site and debris from homeless encampment. Remove trees to install a secur
fence animate for Fire Department access.
PLEASE PRINT
Type of Permit Required
Annexation
Binding Site Plan
Boundary Line Adjustment
Comp Plan/Rezone
_ Land Surface Modification
Lot Line Elimination
Preapplication Conference
Process I (Director's Approval)
Process Il (Re Plan Review)
Process III (Project Approval)
Process IV (Hearing F,xamiuer's Decision)
Process V (Quasi -Judicial Rezone)
_ Process V I
SEPA w/Project
SLPA Only
_ Shoreline: Variance/Conditional Use
Short Subdivision
_ Subdivision
Variance: Commercial/Residential
Required Information
BC -Community Business Zoning Designation
BC Comprehensive Plan Designation
0 Value of Existing Improvements
- Value of Proposed Improvements
International Building Code (113C):
Occupancy l ype
-_ —Construction Type
Applicant
Nance: AP Consulting Engineers PLLC
Address'PC) Pox 162
City/State: Auburn, WA
Zip: 98071
Phone: 253-737-4173
Fax:
Email: APC' APCon fit in rs.cons
Signature:
(L*n
Agent (ifdili'crcnl IhA Applicant)
Name:
Address:
City/State:
Zip:
Phone:
Fax:
Email:
Signature:
Owner
Name: Curtis Nelson
Address: 627 East Francis Avenue
City/Slate:: Spokane, WA
Zip: 9L770
Phone: 509-995-5965
Fax:
Email: curt: il-1 linc,c i �7
Signature:
Bulletin #003 — January 1, 2011 Page 1 01, 1 01landouls\Master Land Use Application
A PORTION OF THE N.E. 1/4 OF THE N.E. 1/4 OF SECTION 20, TOWNSHIP 21 NORTH, RANGE 04 EAST,;W.M.
. -
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1 MASTER SITE PLAN
1'� 9G.ALEMS 4-3-0T
NOTES
1, As pe FUCC 22-1564M.. a minim= or 25% or U1 p1enL male la le -111 6e drought w1l L
2. 7Fn IanC.Fdpa plallr pill men •Jp p`nlmum raver a of W12 "a :AcL ar parking
lot Ur.WeAP1"Q Waal n^ rlra rovoJ ng cefculptlan. JW" Pnop M%o PAIlr7e? Lot
Spam.'% n oqw— rtl pv -tot • 25212 ..*aM raCl-
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GROUND FLOOR FIRSTFLOOR
SECOND &
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BUILDING
BUILDING-
BUILDING�V4,W��SF
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RETAIL ANCIiO
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p
12a0m 9c
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PAFKIIhG
12,000 SF
COrahERCIAL
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RE9IDENTAL
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3
12,300 BF
12AGO Z;;
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'fti—,AIL
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24jLoo 5F
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-
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I 4p00 6F
Zc-TAIL
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RETAIL
V 300 9F= is
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COhP
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H
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RESTADRAM
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V 300 SFa 100
U
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i 5,100 SF
5,1o0 SF
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7
TOTAL
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SECOND FLOOR
F
FIRSTFLOOR
RESIDENTIAL
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PARKING
NO.OF
NO. OF
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FLOORS
UNITS
TYPE
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D
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IST
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2ND
TYPE Hi-B
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