21-104309-Comment Response Letter-04-12-2023-V2
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Process IV Land Use Review Comments Response
Plans Examiner: Stacey Welsh (Planning)
Phone: 253-835-2634
253-835-2746
Permit Number: 21-104309-UP
21-104370-SE
Project Name: Midway Samoan Assembly of
God Church
Contact Person: Jamie Trenda Project Number: 20-046
Date: April 11, 2023 Phone: 425-885-4300
Per your Technical Review Comments dated February 10, 2022:
1. General – Technical comments made about an item on one sheet, or in a document,
may necessitate changes to other related sheets and documents. 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.
R: Noted. Supporting documents have been reviewed and updated to reflect
design changes.
2. Plan Set – Please address the following comments:
a. Buildable Lands information was submitted on the Use Process submittal
requirements checklist and on the civil plans. Per the Use Process submittal
requirements checklist, this information needs to be in tabular form on the site
plan. Make sure to address the right-of-way dedication and critical areas. Below
grade stormwater systems do not count as public purpose area.
R: Buildable Lands information has been added to the site plan. See Arch
sheet A1.10.
b. Label the wetland on the site and civil plans.
R: Wetland has been labeled on all Architectural and Civil Plans. See Arch
sheet A1.10 for revisions.
c. Correct the street name on the plans.
R: Street name has been corrected to Military Road South. See Arch sheet
A1.10 for revision.
d. On the landscaping sheets:
i. While the tree/vegetation retention plan shows trees proposed for
removal, it provides no calculations. As was requested in the Pre-
Application Summary Letter, the formal landscape plan must detail
information about tree unit credits and replacement. See FWRC
19.120.130(1)-(4).
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R: Tree unit credit and replacement information has been added to
sheet L1.0.
ii. Need to add required perimeter landscaping along the southern property
line, up to the wetland buffer (beyond the fenced stopping point used
now).
R: Perimeter landscaping along south property line has been
extended up to wetland buffer as requested on sheet L1.1.
iii. Landscaping in the right-of-way should not be factored into the calculation
for the total landscape area provided.
R: Landscaping in R.O.W. has been removed from calculation for
landscape area provided on sheet L1.0.
iv. 30 parking spaces are proposed on-site; update the parking lot
landscaping calculations.
R: Parking lot landscape calculations on sheet L1.0 have been
updated to reflect 30 parking spaces.
v. Landscaping must meet FWRC 19.125.070(3), or apply for a modification
per FWRC 19.125.100. Modifications can be submitted as part of a
project resubmittal.
R: Parking lot islands meet minimum and maximum area
requirements and 6’ minimum width requirement for end islands. No
modifications are proposed.
vi. For the perimeter landscaping along the street, trees to be planted in the
public right-of-way do not count as trees for Type III landscaping. Per
FWRC 19.125.050(3)(b), Type III landscaping shall be a mixture of
evergreen and deciduous trees interspersed with large shrubs and
groundcover.
R: Trees have been added outside the R.O.W. to meet Type III
landscape requirement.
vii. Reconsider the use of elm trees in small parking lot landscape islands
due to their size at maturity and susceptibility to disease. Also see FWRC
19.125.085(1)(i).
R: Elm trees have been replaced with Shademaster Honey locust,
see Planting Plan sheet L1.1 and Plant Schedule on sheet L2.1.
viii. Reconsider use or placement of ornamental grasses in parking lot
landscaping islands and near the site driveway due to the potential for
visibility issues over time.
R: The proposed grasses in the parking lot islands and along the
site driveway, Pennisetum alopecuroides ‘Hameln’, are fairly small.
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Nevertheless, we have replaced them with a smaller variety,
Pennisetum alopecuroides ‘Burgundy Bunny’.
3. Design Guidelines – Please address the following comments:
a. Regarding FWRC 19.115.060(2), all building facades are both longer than 60
feet and are visible from either a right-of-way or residential use or zone, and are
therefore required to meet the standard. From the submittal it appears the north
side is using, façade modulation, canopy/arcade, and pedestrian plaza. The
west side is using façade modulation and needs one more method as the
pedestrian plaza is located on the north side of the building; the east side is
using façade modulation and a design guidelines departure would need to be
requested for the east side of the building to use canopy as one of the methods
since that side is not visible from the right-of-way per FWRC 19.115.060(2)(c). A
design guidelines departure may be needed for the south side to use canopy,
depending on the width and length of the canopies. Additionally, one more
method is needed for the south side.
Design guideline departures are addressed in FWRC 19.115.020 and can be
submitted as part of a project resubmittal. Alternatively, see FWRC
19.115.100(5), which allows for use of alternative methods to organize and
shape the structural elements of a building and provide facade treatment
pursuant to FWRC 19.115.060(2) and/or FWRC 19.115.100(3). If this section is
utilized please address all the criteria.
R: See the revised project narrative at section addressing FWRC
19.115.060(2). Response has been updated to address all building facades
with design guideline departure requested for west side, to allow use of
the canopy/ arcade option.
b. Are the canopies on the west and south sides of the building within the required
setback? See FWRC 19.125.160(4) if needed.
R: Canopies proposed are all within the building setback.
c. Plans show that the pedestrian plaza has bike racks but no other amenities. Per
FWRC 19.115.050(1)(b), pedestrian amenities include but are not limited to
outdoor benches, tables and other furniture; also see FWRC 19.115.050(4)(e).
R: The proposed plaza layout has been added to plan set, see sheet A2.11
for enlarged plans. The project narrative has also been updated to include
this information.
d. Per FWRC 19.115.050(4)(b), the pedestrian pathways and pedestrian areas
should be delineated by using a variation in paved texture and color. Approved
methods of delineation include: stone, brick or granite pavers; exposed
aggregate; or stamped and colored concrete.
R: As seen on sheets A1.10, A2.10, & A2.11 the proposed plaza area will
have stamped concrete and the walkways will be made of exposed
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aggregate concrete. Paving referenced in keynotes 3, 4, 13 on sheet A1.10.
The project narrative has also been updated to include this information.
e. Per FWRC 19.125.040(22), confirm that any areas of 240 square feet either do
not exist or are screened per this code.
R: There is only one section of blank wall that exceeds 240 square feet, on
the south façade. The entire south façade is screened by Type II
landscaping.
f. Per FWRC 19.115.100(3), the north and south building facades exceed 120 feet
in length and are visible from an adjacent residential zone or right-of-way and
need to incorporate a significant structural modulation (offset). The proposal
needs to comply with the guideline or request a departure per FWRC
19.115.020.
Alternatively, see FWRC 19.115.100(5), which allows for use of alternative
methods to organize and shape the structural elements of a building and provide
facade treatment pursuant to FWRC 19.115.060(2) and/or FWRC
19.115.100(3). If this section is utilized please address all the criteria.
R: See the revised project narrative at section addressing FWRC
19.115.100(3) and 19.115.100(5).
4. Parking – For the parking request, the criteria in FWRC 19.130.080(1) do not relate to a
request to reduce the number of required parking spaces. Please provide a response to
the criteria in FWRC 19.130.090 instead. Provide documentation from Church of Christ
related to using the site for parking/shuttle purposes.
R: Design narrative has been updated to respond to the criteria in FWRC
19.130.090, requesting a modification to the parking area location.
5. Critical Areas – Please address the following comments:
a. The project scope includes work within the wetland for demolition of a structure
and the sewer line installation. Pursuant to FWRC 19.145.430 “Development
within wetlands,” this requires Use Process IV approval. This aspect of the
project was not included within the submitted project narrative, Master Land Use
Application, or SEPA checklist. Since this aspect of the project was not included
with the public Notice of Application, the public notice will need to be redone.
The timing of the notice will be determined after the resubmittal is reviewed.
R: The project narrative and SEPA checklist have been updated to specify
demolition of existing structure and sewer line installation within wetland.
b. Please see the enclosed memo from the city’s peer review consultant, ESA, and
address their comments as part of your resubmittal to the city.
R: Please see attached revised “Wetland Delineation” and “Wetland and
Stream Suffer Mitigation Plan”
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SEPA
6. Background – Review the project submittal documents and augment this section as
appropriate (checklist item #A[8]).
R: Section A.8 has been reviewed and updated.
7. Earth – Reconcile clear/grade quantities with information contained in the civil plan set.
(checklist item #B[1][e]).
R: Section B.1.e has been updated to match the latest Civil plan set.
8. Water – Ensure all critical areas impacts are adequately addressed. (checklist item
#B[3]).
R: Section B.3 has been reviewed and updated to reflect the latest plans.
9. Land and Shoreline Use – Revise response to describe the wetland, not wetlands and
note the on-site stream buffer. (checklist item #B[8][h]).
R: Section B.8.h has been updated.
10. Transportation – Trip information does not match what is contained in the TIA.
(checklist item #B[14][f]).
R: Section B.14.f has been updated to match the TIA.
11. Other – If project materials are revised or added that necessitate an update to the
SEPA checklist, please update the contents accordingly prior to resubmittal.
R: Contents have been updated accordingly.
Public Works – Development Services Division
Sam Basmeh, 253-835-2746
1. Surface water runoff control and water quality treatment will be required per the 2021
King County Surface Water Design Manual (KCSWDM) and the City of Federal Way
Addendum to the manual. This project meets the requirements for a Full Drainage
Review.
R: Noted.
2. The project lies within a Conservation Flow Control Area; thus, the applicant must
design the flow control facility to meet this performance criteria. In addition to flow
control facilities, Best Management Practices (BMPs) 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.
R: See “Preliminary Drainage TIR”.
3. In addition to the KCSWDM, our initial review suggests that FWRC Section 19.30.120,
“Nonconforming Water Quality Improvements” applies to this site. Therefore, water
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quality treatment will be required for the entire site, including new and existing pollution
generating impervious surfaces. Treatment options must be selected from the
Enhanced Basic Water Quality Menu provided in the KCSWDM.
R: See “Preliminary Drainage TIR”.
4. A Surface and Stormwater Utility System Development Charge is required. System
development charges (SDCs) are one-time fees that will be paid at the time of
development and are intended to recover a share of the cost of system capacity
needed to serve growth. The SDC is based on the amount of new impervious surfaces
added for any development project. For calculating the SDC for commercial and multi-
family development, impervious surface is expressed as an Equivalent Service Unit: 1
ESU = 3,200 square feet (SF) of impervious surface added. The current 2021 fee is
$981 per each ESU.
R: Noted.
5. Although the Wetland Delineation Report does provide a soils analysis with sample
logs located within the wetland and the associated buffer, and states - the remainder of
the subject property is upland. The soil in non-hydric, two-chroma matrix gravelly
sandy loam, with no redox features in the soil profile. The water table is not present at
24-inches from the surface. A portion of the upland area is covered by lawn grasses
previously planted. A separate Soils Report is required to prove the feasibility of the
proposed infiltration trench and pervious HMA parking lot.
R: Soils report for area of site to be developed was provided with initial
submittal. No infiltration proposed on site as it is not feasible.
6. Detention and water quality facilities for private commercial developments outside the
City Center Core must be above ground (i.e. open pond). For short plats, the detention
and water quality facilities shall be within a separate tract, that will be owned and
maintained by the owners of the platted lots. Underground facilities are allowed only
with approval from the City of Federal Way Public Works Department.
Response: Please see proposed detention options. Drainage pond only feasible
if allowed within wetland buffer. Otherwise, underground facility is needed.
Please provide preferred direction.
7. Show the proposed location and dimensions of the detention pond and water quality
facilities on the civil plans.
R: Please review detention options submitted & provide preferred direction.
8. Since more than one acre will be disturbed during construction, a National Pollutant
Discharge Elimination System (NPDES) construction storm water permit may be
required. Information regarding this permit can be obtained from the Washington State
Department of Ecology at
http://www.ecy.wa.gov/programs/wq/stormwater/construction/index.html or by calling
360-407-6048.
R: Noted.
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9. Per provided civil plans some of the work proposed will be done below the ordinary
high-water mark, a Hydraulic Project Approval (HPA) permit may be required.
Information regarding this permit can be obtained from the Washington Department of
Fish and Wildlife.
R: Noted.
10. All stormwater treatment and detention requirements outlined above may apply to any
improvements within the public right-of-way.
R: Noted.
11. Provide engineering detail plans for required frontage improvements per Modification
Letter Approval; 15 foot right of way dedication, curb & gutter, 3 foot planter strip, 6 foot
sidewalk and 3 foot utility strip.
R: Noted.
12. Dedication of right-of-way was required to install street frontage improvements; the
dedication shall be conveyed to the City through a statutory warranty deed after the
Boundary Line Adjustment is approved. The dedicated area must have clear title prior
to recording. Please see attached Statutory Warranty Deed Work Sheet.
R: Noted.
13. 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. Please see the attached Bond
Quantity Work Sheet.
R: Noted.
14. The Topographic Survey sheet provide shows the vertical datum used was NAVD88
and it used one monument. The city requires that 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 called out and survey must tie in two monuments.
R: See revised Survey.
15. A Right-of Way permit is required for frontage improvements and the driveway
connection. Please provide engineered site plans for the frontage improvements, a
Traffic Control Plan in accordance with WSDOT and MUTCD, Certificate of Insurance
(COI), bid or estimate, and a City prepared Performance and Maintenance Bond; see
the COFW ROW permit application page 1 for further details.
R: Noted.
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Public Works – Traffic Division
Soma Chattopadhyay, 253-835-2731
1. Provide a detail sheet demonstrating that garbage truck maneuvering inside the
parking lot is feasible.
R: Garbage truck maneuvering inside the parking lot has been added to the set.
See Arch sheet A2.12.
Community Development – Building Division
Greg Kirk, 253-835-2621
1. Demolition permits are required for all the buildings.
R: Noted.
Lakehaven Water & Sewer District
Brian Asbury, 253-946-5407
1. There is a fair amount of changes that will be needed for the onsite water
main/system/hydrant work, see enclosure for notable mark-ups. For sewer, they are
showing a new sewer service line through the wetland buffer and into wetland itself; if
the City approves this it will presumably be limited to dry-month construction/installation
and a future O&M plan will be required (primarily to describe what happens if/when
they need to get into the buffer/wetland in the future in wet months for sewer service
line O&M). LWSD will likely have additional requirements/comments regarding the
existing water service connections & proposed new water service connection, but those
are relatively minor to the overall project & should not ultimately conflict with any other
utilities/requirements for this site.
R: Noted.
South King Fire & Rescue
Sean Nichols, 253-946-7242
2. No comments on the submittal; contact if you have any fire related questions.
R: Noted.
Due to the comments concerning the Wetland Report and discussions with the City, we
have revised the site plan to increase the width of the wetland buffer. All of the supporting
documents have been updated to reflect this change. The changes made in relation tot eh
increased buffer have ben labeled Delta 2.
I trust that the above responses will be sufficient to complete the review of this project.
Should there be further questions or clarifications needed please do not hesitate to contact
me directly at 425-885-4300 or via email at jamie@magellanarchitects.com.
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Sincerely,
Jamie Trenda
Sr. Project Manager
Magellan Architects