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19-103625July 26, 2019 e Surveying LDC1 Engineering RECEIVED Planning JUL 2 9 2019 EJ Walsh, P.E. CITY OF FEDERAL WAY Public Works Director COMMUNITY DEVELOPMENT City of Federal Way 33325 8th Avenue South Federal Way, WA 98003 RE: Right -of -Way (ROW) Improvement Waiver Request Pacific Ridge Apartments Dear Mr. Walsh, This letter serves as a formal Right -of -Way (ROW) Improvement Waiver Request on behalf of AMCAL Multi -Housing, Inc. for the proposed Pacific Ridge Apartments, located at the 32500 block of 171h Avenue South (Parcel No. 1621049023). A pre -development meeting was held with the City of Federal Way on August 2, 2018. At this meeting, comments from the Public Works Traffic Division noted the following requirement of a new public road: "Construct east -west road along the southerly property to a Type R street. At a minimum, the improvement shall include 40' street with curb and gutter, 4' planter with street trees, 6' sidewalks and streetlights along the north side of the street. The east -west road shall extend the entire length of the property with a turnaround at the end of the street." To provide further context of the location and surrounding vicinity, the following information is provided for your consideration. Property Summary Location: 32500 block of 17th Avenue South Parcel #: 1621049023 Size: 6.53 acres (284,661 SF) Zoning: BC (Community Business) Abutting properties: North - Office/Commercial, water tower (Lakehaven Utility District) South - Light industrial, Waterbury Park Apartment Homes East - Belmor Mobile Home Park West - Office/Commercial Development Proposal Construction of 355 senior and family affordable housing units, consisting of: 284 units of senior housing 71 units of family housing Service ABOVE the Standard ph: 425.806.1869 • fx: 425.482.2893 • www.LDCcorp.com Pacific Ridge Right -of -Way Improvement Waiver Request July 26, 2019 Page 2 of 8 Vicinity Map Figure 1 - Vicinity Map ROW Improvement Modification, Deferment or Waiver Request In accordance with Chapter 19.135.030 of the Federal Way Revised Code (FWRC), right-of-way improvements are required when an applicant engages in any activity that requires a development permit. Per Chapter 19.135.070, the Public Works Director may modify, defer or waive the requirements of Chapter 19. The applicant may apply for a Right -of -Way Improvement Modification, Deferment or Waiver by making a written request to the Director of Public Work to modify, defer, or waive the requirements of FWRC Title 19, Chapter 135, "Development Improvements," for the following reasons: The improvement as required would not be harmonious with the existing street improvements, would not function properly or safely or would not be advantageous to the neighborhood or City as a whole. W C C C M 0- to v C w Service ABOVE the Standard } Pacific Ridge Right -of -Way Improvement Waiver Request July 26, 2019 Page 3 of 8 2. Unusual topographic or physical conditions preclude the construction of improvements as required. 3. Proper vertical or horizontal alignments cannot be determined because the existing streets do not have correct alignments. 4. The required improvement is part of a larger project that has been scheduled for construction in the city's adopted six -year transportation improvement program. Justification for ROW Improvement Waiver _Request The following items respond directly to FWRC Title 19, Chapter 135: 1. The improvement as required would not be harmonious with the existing street improvements, would not function property of safely or would not be advantageous to the neighborhood or City as a whole. Response: The requirement of a Type `R' street located along the southern property boundary is not harmonious or advantageous at this location. Because of the existing radius of 20th Way South, and the fact there are is an ingress/egress point serving commercial properties directly to the south of the subject property, the roadway, if proposed, would intersect with 201h Way South at a point that could create turning conflicts (see Fig. 1 above). Additionally, a public road in this location would not serve any property other than subject property. The Belmor Mobile Home Park is located directly to the east of the subject property and a public road, if proposed, would serve no immediate public purpose. There is no known timetable of when the mobile home park might redevelop, so it is unreasonable at this time to require a public road that will serve no other property other than the subject property. However, should the mobile home park property redevelop in the future, there are surrounding public roads that could adequately serve the property, including connections to S. 3241h Street to the north, 201h Way S. to the west/southwest, and S. 3301h Street to the south. See Figure 2 below for potential roadway connections within the mobile home park. al a- Service ABOVE the Standard Pacific Ridge Right -of -Way Improvement Waiver Request July 26, 2019 Page 4 of 8 Figure 2 - Potential public road connections for MHP 2. Unusual topographic or physical conditions preclude the construction of improvements as required. Response: Placing a new road on the south side of the Pacific Ridge Apartments project creates significant concerns due to topographic and physical conditions. At the pre -development meeting, it was indicated that a primary reason for wanting this road was to connect to a future road extending in the north/south direction just east of the property (depicted in the City of Federal Way Comprehensive Plan, Map 111-3). The topography in the future road location east of the site slopes as much as 1.5H to 1V. At the east end of the new roadway on the Pacific Ridge Apartments site, the improvements would terminate at an elevation approximately 10 feet above the Belmor Mobile Home Park, too high to connect to a road running north/south. Connections between the Belmor Mobile Home Park to 20th Way S would be better made to the south, replicating the existing private road, The Dunes Ct. Further, as depicted in the Comprehensive Plan, the new north/south road would meet S 324th Street approximately 130 feet east of the south access to The Commons at Federal Way Mall. The short spacing between driveways on opposite sides of S 3241h Street could create turning conflicts with left turn lane queues. W M a- v w Service ABUyt the Standard Pacific Ridge Right -of -Way Improvement Waiver Request July 26, 2019 Page 5 of 8 A report entitled Pacific Ridge, Wetland and Habitat Study and dated 9/9/18 was performed by The Watershed Company. A wetland with a 165-foot buffer was located on the Belmor Mobile Homes property. The buffer not only extends over the entire width of the road shown in the comprehensive plan, but also would affect approximately the last 45 feet of a road built on the south property line of the Pacific Ridge Apartments site. Due to the topographic constraints at the east side of the Pacific Ridge Apartments project, designing this road as required would be problematic. The physical constraints of the wetland buffer compound these issues. The road requirement was put forth with the intention of being a connector to a new north/south road, but this road would have even more significant topographical and physical constraints, as described in the above paragraphs. This connector would serve little public purpose, as the Pacific Ridge Apartments and Belmor Mobile Home Park can both connect to 201h Way S and S 3241n Street by more convenient routes. The applicant requests consideration of these constraints in the consideration of this modification request. The applicant has noted that topography and physical conditions located along the proposed roadway corridor make construction of the requested road cost prohibitive. The additional costs to develop the site with the requested road add an enormous cost burden to their high -quality residential community. In fact, our client has noted that if a public roadway was to be required, the costs of such roadway would prohibit them from developing a residential project as the costs of roadway would exceed the cost benefit of providing for housing that helps meet the needs of all residents in the community. 3. Proper vertical or horizontal alignments cannot be determined because the existing streets do not have correct alignments. Response: This location presents significant challenges (see comments and Fig. 1 above). The subject property is located along 20th Way South at a point where the radius of the road is curvilinear and potentially presents itself with turning conflicts with regards to site distance. Because of the existing radius of 20th Way South, the fact there is an intersection less than approximately 230 feet away, and there are is an ingress/egress point serving commercial properties directly to the south, the proposed roadway would intersect with 20cn Way South at a point that would create turning conflicts. The applicant requests consideration of intersection spacing requirements of FWRC 19.135.280 Separation of a intersections and driveways. 4. The required improvement is part of a larger project that has been scheduled for construction in the city's adopted six -year transportation improvement program. Response: The proposed public roadway is not part of a larger project as identified in the six- W year transportation program. to u c U O Service the Standard Pacific Ridge Right -of -Way Improvement Waiver Request July 26, 2019 Page 6 of 8 Other Considerations In addition to the required responses to the waiver request above, the applicant would also like to offer the following considerations, specifically as it relates to goals and policies of the City's Comprehensive Plan. Transportation Element TP2.3 Prioritize transportation projects considering concurrency, safety, multimodal enhancements, environmental impacts, and cost effectiveness. Response: As noted in the comments above, there are safety concerns with the location for a proposed roadway at this location along 201h Way South. In addition, there are significant cost considerations for the construction of a full public roadway along this alignment. TG3 Enhance community health, livability, and transportation by providing a connected system of pedestrian, bicycle, and transit ways that are integrated into a coordinated regional network. Response: The placement of a public roadway in this particular location does not add to the overall regional road system. Figure 2 proposes several alternatives for connections if/when the mobile home property to the east redevelops. TP3.18 Incorporate environmental factors into transportation decision -making including attention to human health and safety. Response: As noted in comments above, there are environmental factors that should be considered if a public roadway was required. Due to the radius of 20th Way South, there would be concerns regarding the placement of a new public road and left in/left out turning movements. Housing Element Overall Goal Preserve, protect, and enhance Federal Way's existing high -quality residential neighborhoods and promote a variety of opportunities to meet the housing needs of all residents of the community and region. HP16 Increase capacity and encourage greater diversity of housing types and costs for both infill and new development through various methods, such as inclusionary zoning, density bonuses, and transfer of development rights, cluster housing, cottage housing, garden housing, duplexes, and low to moderate density housing types. Response: The project proposes 355 high -quality residential units that are affordable to the community (at 60-percent of the Area Median Income). This project would serve to address this policy. C C CZ 0- w Service ABO`. the Standard Pacific Ridge Right -of -Way Improvement Waiver Request July 26, 2019 Page 7 of 8 HG5 Develop a range of affordable housing opportunities for low-income households consistent with CWPPs and the needs of the community. Response: As noted above, the proposal of 355 high -quality residential units would help lower income households and go toward helping address this policy of serving housing needs of the community. HP31 Consider delaying, deferring, or exempting affordable housing from development fees, concurrency requirements, payment from impact fees, offsite mitigation, and other development expenses that do not compromise environmental protection or public health, safety, and welfare concerns, or constitute a nuisance. Response: As mentioned in the above narrative, the requirement of a public road along the southern boundary of the subject property poses several safety and environmental concerns. These include a conflicting intersection with 20th Way South, topographic and physical conditions along the roadway corridor, and the off -site wetland located directly to the east of the subject property in -line with the proposed roadway. All of these issues combined would create costs for such a roadway that would prohibit the developer from constructing an affordable housing project as the costs of roadway would exceed the cost benefit of providing for affordable housing units. Also, it is clear that the City has created policies to allow for and promote affordable housing. Using mechanisms that lower the costs of development, as noted in HP31, would help promote affordable housing projects and ensure developments are constructed in the most cost-efficient way possible. HP38 Integrate and coordinate construction of public infrastructure with private development to minimize housing costs wherever possible or practicable. Response: As previously discussed, the costs of construction of a public roadway, along with the constraints of the site, make the project prohibitive to develop and therefore would not be in the spirit of this housing policy. C C Summary Based on the information and justifications provided above, the applicant, AMCAL Multi - Housing, Inc. believes a ROW improvement waiver request for a Type `R' roadway is c warranted. c w We appreciate your consideration this waiver request. If you should have any questions, please don't hesitate to contact me at 425-806-1869 or at cwhite@LDCcorp.com. C .T Service ABOVE the Standard Pacific Ridge Right -of -Way Improvement Waiver Request July 26, 2019 Page 8 of 8 Sincerely, LDC, INC. Cj �Ll)ctQ Clay White Director of Planning CC: Mario Turner, VP of Development, AMCAL Multi -Housing, Inc. Sarady Long, Senior Traffic Engineer Robert "Doc" Hansen, Planning Manager Encl: Pacific Ridge Boundary and Topographic Survey a Service ABOVE the Standard CITY OF Federal Way September 9, 2019 LDC, Inc Attn: Clay White 20210 142nd Ave NE Woodinville, WA 98072 CITY HALL 33325 8th Avenue South Federal Way, WA 98003-6325 (253) 835-7000 www.cityoffederalway.com Jim Ferrell, Mayor RE: Permit #19-103625-00-SM; PACIFIC RIDGE APARTMENTS, 325xx 17TH AVE S, Request to waive street improvements Dear Mr. White, This letter responds to your request to waive the required street improvements along the south side of your property, as part of the proposal for the development of Pacific Ridge Apartments. After evaluating the existing conditions, review of Federal Way Revised Code (FWRC) provisions (Sections 19.135.070 and 19.135.090) and direction provided by the City Council, the Public Works Department hereby denies your request, as noted below. FRTC Section 19.135.070 (1)_ The improvement as required would not be harmonious with existing street improvements, would not function properly or safely or would not be advantageous to the neighborhood or city as a whole. While the proposed new street would only serve this private development in the near -term, the street will eventually be extended easterly and connect to other proposed streets as shown in the Transportation section of the City's Comprehensive Plan. The future easterly extension, along with other `grid' roads in that area will be required at the time the Belmor Mobile Home Park property is redeveloped. This roadway would benefit the City and neighborhood, as it would comply with the City's Comprehensive Plan for grid roads in this neighborhood as well as serving to meet the City code -based block perimeter standards, at the time the Belmor Park property is redeveloped. (2) Unusual topographic or physical conditions preclude the construction of the improvements as required. According to the topographic map provided with your request, the ground along the proposed street alignment rises in the west -to -east direction, representing an overall slope of just over +2%, with the steepest slope being just over +7% in the eastern section of the rising grade. The ground then drops down from that high point, representing an overall slope of just under -3%. The ground is shown to continue on a downward slope on the Belmor Park property. These topographic grade changes across the length of the property do not appear to be so acute that the roadway could not physically be constructed. While the Comprehensive Plan shows this road connecting to a north -south roadway along or near the western edge of the Belmor property, that north south roadway alignment is conceptual, and could be revised as part of the Belmor Park redevelopment planning in order to accommodate this connection. Additionally, the applicant refers to the Belmor Park pond that's to the east of this proposed roadway as a wetland. This pond was constructed by the City in 1998 as a detention and water quality facility, and at this time there 19-103625-00-SM Doc. I.D. e _,1 -) has been no formal determination as to whether or not this is a wetland or other environmentally sensitive area. The topography along this roadway alignment does not appear to represent an unusual topographic condition beyond that of a `typical' roadway design through undeveloped property. (3) Proper vertical or horizontal alignments cannot be determined because the existing streets do not have correct alignments. The location of this road, where it connects to 20th Way S, is along a curve and is also less than 150-feet from a private commercial driveway on the opposite side of 20th. Alignment of a roadway along the north property line would present a greater challenge (in the vertical alignment) since the topography along that side of the property is quite a bit more dramatic than along the south side. The primary difficulty in designing the roadway along the south side will be at the intersection with 20th Way S, due to the curve noted above. Other than some potential design challenges at the intersection with 20th Way South, the horizontal and vertical alignments of this roadway do not seem to be beyond the scope of a `typical' roadway design. Therefore, one of the conditions of developing this property will be to construct the roadway along the south property line, as identified in the Traffic Division comments of the City's August 21, 2018 pre - application meeting summary letter, as follows: Construct "3/4" street improvements per City standard street section Type "R', with a 40-foot wide paved roadway, with a 4-foot planter strip, 6-foot sidewalk, and 3-foot utility strip behind sidewalk along the northern edge of the paved roadway, within a right of way of adequate width to contain the improvements. A City -standard (90-foot diameter) cul-de-sac will also be required at the eastern end of the roadway. The cul-de-sac would be temporary until such time as the road is extended to the east. The requirements and conditions of this letter will be applicable for a period of one year. If a permit is not issued within the one year time period, this waiver will be void, and a new request for modification must be submitted. Should you have any questions please do not hesitate to contact Kevin Peterson, Engineering Plans Reviewer at (253) 835-2734. 5inc7Iy, C Desiree Winkler, P.E. Deputy Public Works Director DW:KP/ss Enclosure: City Detail DWG 3-2R and 3-2Z cc: Jim Harris, Sr. Planner Sarady Long, Sr. Transportation Planning Engineer Project file (lcp) Day file 19-103625-00-SM Doc.[.D. (:IT �' OF �� Federal Way PUBLIC WORKS DEPARTMENT STREET MODIFICATION REQUEST / ACTION Project Name Pacific Ridge Apartments Permit # 18-102873-PC Location 325xx 17th Ave S Request The applicant is requesting waiver of an east -west street across the southern boundary of their property that was identified in the City's August, 2018 pre -application meeting. The applicant contends that criteria 1, 2, and 3, listed under FWRC Section 19.135.070, apply to this street alignment. Staff Analysis This street, along with a future extension into and through the Belmor Park property, is required in order to meet FWRC Section 19.135.251 — Block perimeter standards. Additionally, the location of this street alignment is consistent with Maps III-3 and 111-4 of the City's Comprehensive Plan, which show a conceptual east -west roadway near this development. The easterly extension of this street will be to-, and eventually through-, the Belmor Mobile Home Park property, connecting to other planned, east -west and north -south roadways proposed within the Belmor property at the time it redevelops. The required street section for this roadway is a Type `R' street, with a 40-foot roadway, 4-foot planter strips, and 6-foot sidewalks in a 66- foot right of way. In the pre -application summary letter, traffic division required the 40-foot roadway, with the planter strip and sidewalk along the northern edge, eliminating the planter strip and sidewalk along the southern edge. A City -standard (90-foot diameter) cul-de-sac would also be required at the eastern end. The cul-de-sac would be temporary until such time as the road is extended to the east. FWRC Section 19.135.070 (1): The improvement as required would not be harmonious with existing street improvements, would not function properly or safely or would not , be advantageous to the neighborhood or city as a whole. While the proposed new street would only serve this private development in the near -term, the street will eventually extend and connect to other proposed streets, as shown on the Comp. Plan Map, that will be required as part of the redevelopment of the Belmor Park property. These future grid roads would be beneficial to the neighborhood in general, and the City as a whole, as it would create alternative routes of travel through an area that is currently served by few through -streets, at the same time meeting City -code required block perimeter standards. (2) Unusual topographic or physical conditions preclude the construction of the improvements as required. According to the applicant -provided topographic map, the ground along the proposed street alignment rises approximately 11-feet in elevation in the first 480-feet in the west -to -east direction, representing an overall slope of just over +2%, with the steepest slope being just over +7% in the eastern 140-feet of the rising grade. The ground then drops down from that high point approximately 5-feet over the eastern 180-feet of the property, representing an overall slope of just under -3%. The ground is shown to continue on a downward slope on the Belmor property. 1:\formletters\Street Mod Requests\Street Mod Request Form - Pacific Ridge Apts.docx Scan completed form into Amanda folder These topographic grade changes across the length of the property do not appear to be so acute that the roadway could not physically be constructed. Additionally, while the Comp. Plan shows this road connecting to a north -south roadway along or near the western edge of the Belmor property, that north south roadway alignment is conceptual, and could be revised as part of the Belmor Park redevelopment planning in order to accommodate this connection. Additionally, the applicant refers to the Belmor Park pond that's to the east of this proposed roadway as a wetland; however, this pond was constructed by the City in 1998 as a detention and water quality facility, so while it likely has wetland characteristic's, because it's a manmade constructed water feature, it's unlikely it would be considered an environmentally sensitive area that would necessitate strict environmental review and permitting in order to extend roads through the Belmor property. (3) Proper vertical or horizontal alignments cannot be determined because the existing streets do not have correct alignments. The location of this road, where it connects to 20th Way S, is along a curve and is also less than 150-feet from a private commercial driveway on the opposite side of 20th. Alignment of a roadway along the north property line would present a greater challenge (in the vertical alignment) since the topography along that side of the property is quite a bit more dramatic than along the south side. The primary difficulty in designing the roadway along the south side will be at the intersection with 20th Way S, due to the curve noted above. Beyond that, the horizontal and vertical alignment is relatively straightforward. Requirements / Conditions of Approval Staff recommends denial of this request for the following reasons: 1) The roadway would benefit the City and neighborhood, mainly in the future, as it would comply with the City's Comprehensive Plan for grid roads in this neighborhood as well as helping to meet our block perimeter standards as the Belmor property redevelops in the future; 2) The topography along this roadway alignment does not appear to be beyond that of a `typical' roadway design through undeveloped property, nor does it appear that the Belmor pond would be considered an environmentally sensitive area, since it is a constructed detention/water quality pond; 3) Other than some potential design challenges at the intersection with 20th Way South, the horizontal and vertical alignments of this roadway do not seem to be beyond the scope of a `typical' roadway design. Staff Recommendation: Initial Date Approve Deny Development Services Reviewer V_OV `d 2l I k 9 ❑ Development Services Manager C.&I 2.1 `$' ❑ Traffic Division Reviewer ❑ 1r Traffic Division Manager J1 L ��'` G 7 ❑ ❑"- Deputy Director 21 ❑ Director Decision ��`_ 4131i ❑ l:\formletters\Street Mod ReqLies ts\Street Mod Request for - Pacific Ridge Apts.docr Scan completed form into Amanda folder City of Federal Way Comprehensive Plan Map III - 3 Functional Classification of Existing and Planned Streets and Highways CITY OF Federal Way Scale: 0 0.5 JAcomplan12014 Update\Transportation\Maps\Functional_Classification mxd Map Date: April 2015 City of Federal Way GIs Division 33325 8th Ave S Federal Way, WA 98003 253-B35-7000 www. cityoffede ralway, co m Transportation Element This map is intended for use as a graphical representation. i The City of Federal Way makes i Miles no warranty as to its accuracy. 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ORDER NO. 20376707-416-416 \ BENCHMARKS EFFECTIVE DATE MARCH 27. 2018 HELD CITY OF FEDERAL WAY COORDINATE VALUES MONUMENT IN CASE AT INTERSECTION OF SOUTH LOT 4 OF KING COUNTY SHORT PLAT N0. 275005, AS CITY 0� FFEDERAL WAY B.M. NO- 2167-25 BETWEEN HORIZONTAL CONTROL MONUMENTS FW 100 320TH STREET AND PACIFIC HIGHWAY SOUTH RECORDED UNDER RECORDING NO. 7606220930, •. FOUND BRASS CAP MON IN CASE WITH NO UD, AND FIN 120 AS DESCRIBED BELOW: STATE PLANE COORDINATES RECORDS OF KING COUNTY AUDITOR; E CENTERLINE OF 23RD AVE SOUTH ELEVATION = 414.271' (NGVD-29) r, 1j(1 NAD 83(91) - NORTH ZONE EXCEPT THOSE PORTIONS DEEDED TO KING COUNTY FOR ' TOP, OF MONUMENT IN CASE (NO COVER) 23RD NORTH 118491.72 THE 17TH AVENUE SOUTH EXTENSION BY RECORDING AVEr9Lr SOUTH, 60 FEET +/- SOUTH OF EAST EAST 127329133 NOS 8808240414 AND 8808300844 i FWNO i MmArMUR Vi LASE DRIVE TO SEA-TAC MALL SURVEYREFERENCES SITUATE IN THE CITY OF FEDERAL WAY, COUNTY OF KING, WITH Y BRASS DISK AND PUNCH, GOWN 0.5' STATE PLANE COORDINATES STATE OF WASHINGTON AT THE INTERSECTION OF S 325TH STREET AND (HAD 83 - NORTH ZONE) (R1) KING COUNTY RECORD OF SURVEY 17TH AVE SOUTH ELEVATION = 409.40' (NGVD-29) NORTH 117812.94 (REC NO. 2DO10129900011) EQU/PMENTaPROCEDURE$ EAST 1275687-57 (R2) FEDERAL WAY PWA SOUTH, A hURROAMAL DATUM " L� -SENT PUNNED UNIT DEVELOPMENT (REC. NOL 751009 362) SEINED PE SURVEY: SURVEY PERFORMED BY FIELD TRAVERSE NAD 83I91 WASlYHGTOH STATE COORDINATES -NORTH ZONE IN MONUMENT IN CASE AT INTERSECTION OF SCUM 320TH STREET AND PACIFIC HIGHWAY SOUTH (R3) KING COUNTY SHORT PUT NO 275005 INSTRUMENTATION: LEICA MS-50 ROBOTIC TOTAL STATION WITH DATA (REC. NO 7006220938) COLLECTOR AND LEICA GS-14 GPS MAINTAINED IN STATE PLANE COORDINATES MAD 83(91) - NORTH ZONE ADJUSTMENT TO MANUFACTURES SPECIFICATIONS AS REQUIRED BY WAC 332-130-100 NORTH 118491,72 EAST 1273293.33 PRECISION: MEETS OR EXCEEDS STATE STANDARDS WAC 332-130-090 N Z O a �mI 6p C x c n _sP a'x = to W 6 >< u u s o €<3 $n�5 Z U Foa O Q W O 5 vQ TIC Q U Z Q � 0 JOB U m a p �t Wes+ SZ ••t W.Ti \� HIhWk R: 1119•IO9V OPAW44 NAME:Pt9-ID9s-9T EE50N1t DRAFIM BY: NSr DM1IE: D6-06-19 ,ILIRA50"TIO'L• "r0 COUNTY BT-01 SHEET 1 OF 1