15-105116L N
A ILI
V�10
November 3, 2015 Jim Ferrell, Mayor
Steve Hammer
BPH Architects
19624A 76"' Avenue West
Lynnwood, WA 98036
Emailed: steveabrAiarch.com
RE- Permit #15-105116-00-AD; EXPANSION To NONCONFORMING DEVELOPMENT
St Luke's Lutheran Church, 515 S 312'1' St, Federal Way
(Parcel Nos. 082104 9157,082104 9038, 082104 9153 and 082104 9127)
The city is in receipt of your October 5, 2015, request to interpret pending amendments to Federal Way
Revised Code (FWRC) 19.30 'Nonconformance'. The request relates to the construction of new gross
floor area (GFA) on an existing nonconforming development - St. Luke's Lutheran Church, Daycare and
School. The development contains certain nonconformances, not limited to a nonconforming 30-foot
required yard. It is requested the Planning Division interpret FWRC 19.30.090(2)(a) - Exceptions, which
states:
um%f pC7 m.4tiiiat, *4_*f9&*,w.0rwwff#*#rinance s
identified in subsection (1) is not required unless th-sir r oposes to add 4,900 squarefeet of n
grossfloor area to the subject property or ten percent of the grossfloor area of the building(s) on :t.hej
"'W" FrMhrdzne_rzeriod commencin2,
time of buildingperinit issuance... " I
The subject property contains a 15,198 sq. ft. free-standing gym and a 51,118 sq. ft. church (including
childcare facilities and school classrooms) building. In October 2015, gross floor area on the subject
property totaled 66,316 sq. ft. Per FWRC 19.30.090(2)(a), the proponent may add up to 10% of the GF
of the buildings on a nonconforming development. If the gross floor area remains the same with no sqUa
footage removed, a maximum of 6,632 sq. ft. may be added as a new structure or square footage additio
The applicant proposes the constructiori of a new 21,830 sq. ft. Family Life Center at the rear of the
church building, replacing the 15,198 square -foot free-standing gym. The proponent asks: If demolishe
would the area of the previous gym structure be included in the ten percent gross floor area calculation•
all the building(s) on the subject property per FWRC 19.3 0.090(2)(a)?
In response, if demolished, the free-standing gym building is not credited towards the GFA exception
under FWRC 19.30.090(2)(a). The gym's gross floor area would not continue to exist on the subject
property once demolished. The current proposal exceeds the gross floor area addition exceptions set fort
therefore the ai.q%licant would need to c"mfsIr1 with all the develo�&ment reulations in effect at t e t me
the expansion. The 'Proposed Site Plan' submitted on October 5, 2015, r-ram-sents 43% of the gross floor
area of all buildings continuing to exist on the subject property after gym demolition. The administrative
decision request represents a major expansion of the total gross floor area, which exceeds the
nonconforming development Exception thresholds of FWRC 19.3 0.090(2)(a).
Mr. Hammer
Naveber 3 2015
Page 2
Nonconformance provisions aim to correct existing nonconformities either incrementally over time or in
some instances immediately. The intent of the nonconformance' regulation update enables legal
nonconforming developments to make minor expansions to total gross floor area without requiring
conformance with development regulations in place at the time of a new application.
Closing
If you have any questions regarding this letter, please contact me at 253-835-2644, or leil,yvilloughby-
oake @cit_voffederill a s om.
Sincerely, ,
Leila Willoughby- a -e
Associate Planner
c: Todd Zem, St. Luke's Lutheran Church, 515 S 312`h Street, Federal Way, WA 98003; Email: cl1r� hkrtl °IItt1 .si'eci vt .cir
Matt Herrera, Senior Planner
8�zI4 ;11c
Doc I.D.:71104
RECEIVED
REQuEST FOR ADMINISTRATivE DECISION
w
"Fu OCT 0 5 Z015 DEPARTMENT OF COMMUNITY DEVELOPMENT
CITY OF 0 %�—� 33325 8' Avenue South
Federal WayCITY OF FEDERAL WAY Federal Way, WA 98003-6325
253-835-2607; Fax 253-835-2609
CDS www.citvoffederalwav-corn
FILE NUDate
MBER — L
Applicant
NAME Steve Hammer PRU"RY PHONE (425) 774-4701
BUS1NESS/ORGANMTION BPH Architects ALTFJMATE PHONE
F4AU,XNG ADDRESS 19624A 76th Ave. W E-MAM steve@bpharch.com
CITY Lynnwood sTATE WA zip 98166 FAX
Property Address/Locatio -- 515 S. 312tb St.
Description of eestroride art inte retaticn of tl�e trrdin' for Face tiaart a . See attached detailed re oast
with our lip is and °ustication
List/Describe Attachmen Code
(FVMC) mrta-iron a to Nonconformin Uses DeveloDments and Lots — Cb Dter 19.30 'Nonconfomance'
3. Detailed written re uesL
letin #079 — September 10, 2015 Page 1 of I k:\14andouts\Request for Administrative Decision
In
DATE: 10/5/ 5
TO: City ofFederal Way
ATTN: Isaac Ccm|en'Planning Manager
SUBJECT: File #15-1U2298-OU-P[,Preapp|icationConference
St. Luke's Lutheran Church Master Plan
We are hereby requesting an Administrative Decision on the following revised wording for a
portion of section 19.30 'Nonconformance' as it relates to our proposed addition to St. Luke's
Lutheran Church, as identified in the above referenced Preapplication Conference.
The existing church building is 51,118 SF (including the recent classroom wing) and the existing
free-standing gym is 15,198 SF for a total of 66,316 SF for the group of buildings. So our
understanding is that under Exception (a), this would allow us to add on up to 10% of that tot
or 6631 SF in a 36 month period on the subject property.
However, our question is; what if we were to demolish the existing gym building and rebuild
it? The existing gym building is old and in poor shape, with no fire sprinklers, and not very
functional. Would the new code allow us to replace that existing square footage and still add
additional 10%, or 6631 SF? The net change would not exceed 10%, but the total size of the
addition would be 15,198 + 6631 = 21,830 SF of gross area on the subject property (within a
year period).
The wording does not specifically say 10% of net new gross floor area, but I believe that is the
intent, to minimize the increase in bulk and scale on non -conforming buildings. By tearing do
and rebuilding the existing gym building in a different configuration, we would not be increas il
the bulk and scale of the buildings on site beyond the 10% exception. E
Your decision on this issue will have a very significant impact on the design of this building, so
timing is also important. We can't move forward with the building design until we have an answer
oiii this Administrative Decision.
Steve Hammer
BPH Architects
opH Architects /9624x76th Ave,w Lynnwood' WAvoosu (425) 774'4701 www.bnhu,chzom
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