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LUTC PKT 03-05-2001 C/b/Council " Land UseJTransportstion CommiL~ee .,.. March 5, 2001:' . :,.' City Hall .'.' 5:30. pm ... . .... Council Chambers 2. 3. 4. MEE'I~NG AGENDA CALL TO ORDER Approval of Minutes of the January 22, 2001, Meeting PUBLIC COMMENT (3 minutes) BUSINESS FI-EMS A. Draft RFP for Downtown Market Study B. 2001 Site-Specific Comprehensive Plan Map Change Requests C. Height Code Amendment for Schools Info McClung/15 min Action Clark/30 min Action Clark/15 min FUTURE MEETING AGENDA ITEMS 25% Nonconforming Street Issues 6. AD3OURN Committee Members: Dean McColgan Jeanne Burbidge Eric Fa/son City Sta~' Kathy McClung, D/rector, Community Development Services Sandy L y/e, Administrative Assistant 253.661.4116 I:\LU-TRANS\March S, 2001 LUTC AGN.doc ~." CitY of Federal'Way ....' ', :.. ~ · · : .?, CitY COuncil :.'," :" .:' .... " ',"~ ~' · ', ,,: .. ;~ ..... ~' . .:~. ':' ..j;." 'Lan~- - Use!:~,~n~po~tion:.Com'~iffee--" ',~..% ":.~.!., , .? .~:..:.:. :..~:.. ,.. · '.=.'.~ ..". '=' ~' '=',.. .. ...... ,~=.::.'.?="<;~.' '..~..... ·-'="~ ~. . ... ..~'!~" ......': .~'.':'" ... ". ' .. _ _February.2~l";, ~..200~1' ,:,:,,,,,, '":'...... ~."'" ' · :' .:~.':' '.'"'~i~!!'::.?~'_ ?': :i':.I:, .' :.. ':" '~" '~i:,: ',:': '~ '~.'.'.ii' ?~.'~:._ -__:~' Ci~. Hali'...'.._~ _., 5:30. pm ':.'.,...~:.:, · :". :.~..,.~..'~:"i .:/~' ,~:?~. ', .: .. ,, "' ?"" ' ........ ,,.~. 'council ·Chambers, ~......, ~.~i?":" ' MEETING SUMMARY In attendance: Committee members Dean McColgan, Chair, Jeanne Burbidge, and Eric Faison; Deputy Mayor Linda Kochmar; Director of Community Development Services Kathy McClung; Public Works Director Cary Roe; City Attorney Bob Sterbank; Deputy Public Works Director Ken Miller; Street Systems Engineer Marwan Salloum; Traffic Engineer Rick Perez; Assistant Traffic Engineer Hazem El-Assar; Administrative Assistant Sandy Lyle. 1. CALL TO ORDER Chair McColgan called the meeting to order at 5:40 pm. APPROVAL OF MINUTES The minutes of the January 22, 2001, meeting was approved as presented. 3. PUBLIC COMMENT None. BUSINESS ITEMS 23r~ Avenue South Road Improvements Project (South 316th -to South 324th Streets) - 100% Design Approval/Authorization to Bid -The proposed 23~ Avenue South Road Improvements Project design has been completed and was presented to the Committee. In an effort to reduce costs and public disruption several other construction projects have been scheduled to take place at the same time. These include the City Center beautification improvements, Sound Transit improvements, Tacoma Public Utilities Water Division improvements and Lakehaven Utility District water and sewer improvements. Total estimated project costs are $9,169,900 of a total $9,905,362 budget from grants, mitigation funds, general funds and other agencies. Staff also presented an update on negotiations with Sound Transit and a draft agreement between the City and Sound Transit on division of responsibilities and legal relations during the construction of the 23r" Avenue South Improvement Project prior to the actual construction of the proposed Transit Center. The Committee m/sic recommendation of approval to the City Council at its March 6, 2001, meeting, to approve: 1. The 100% design plans for the 23r~ Avenue South Road Improvements Project 2. To authorize staff to bid the project and return to the City Council in April for permission to award the bid to the lowest bidder. 3. To authorize Interlocal Agreements with Lakehaven Utility District, Tacoma Public Utilities Water Division and with Sound Transit for the 23r~ Avenue South Road Improvements Project. Twin Lakes Neighborhood Traffic Safety Project- Residents in the vicinity of SW 314th and 27~' Avenue SW have requested the installation of speed humps in that area based upon concerns of cut-through traffic and speeding. At a neighborhood meeting residents and staff reached a consensus proposing the installation of three speed humps. Ballots were sent to residents within 600 feet of the proposed speed hump locations and a tabulation of the votes indicated that over a 50% majority of the returned ballots favored the speed humps. Linda Waits, a concerned neighborhood citizen, expressed her concerns that a stop sign might be more appropriate than speed humps but concurred that speed humps would definitely assist with the cut-through and speeding problems. FUTURE MEETINGS The next meeting will be held in Council Chambers at 5:30 pm on March 5, 2001. ADJOURN The meeting adjourned at 6:30pm. CITY OF FEDERAL WAY MEMORANDUM DATE: TO: FROM: VIA: SUBJECT: February 28, 2001 Dean McColgan, Chair Land Use and Transportation Committee Kathy McClung, Community Development Services Director David M~~nager Downtown Market Study RFP BACKGROUND Attached is a DRAFT Request for Proposals to conduct a market study for the City Center Core and Frame zoning districts. Conducting the study is the first step to determine residential and housing capacity the City can expect to see in the downtown area in the next several years. This information will be used as the basis for completing the Planned Action SEPA budgeted and planned for this year's work program. PROPOSAL The market and feasibility study will determine retail, office, lodging and residential capacity for the downtown area. It will describe the existing economic profile for the area and discuss the influence of neighboring communities. The study will also define key opportunities and barriers to attracting residential and commercial development. RECOMMENDATION No action is required by the Council on this item. The DRAFT RFP is presented for the Council's review and comment prior to advertising. APPROVAL OF COMMII-I-EE ACTION: Dean McColgan :' Jeanne Burbidge Eric FaiSOn Request for Proposals City Core and Frame Market Analysis and Economic Development Feasibility Study City of Federal Way Send Proposals to: Kathy McClung, Community Development Services Director City of Federal Way P.O. Box 9718 Federal Way, WA. 98063-9718 Submittal Date: April 6, 2001 by 5:00 p.m. I. Introduction II. III. The City of Federal Way is seeking proposals to conduct a market and feasibility study for it's City Center Core and Frame (CC-C, CC-F) zoning districts. The City Center area is conveniently located between Seattle and Tacoma on the I-5 corridor with easy access from Pacific Highway South and Highway 18. The City of Federal Way is committed to the revitalization and redevelopment of it's City Center Core and Frame. Realizing the City Center's strong economic and housing potential, the City Council has adopted a City Center Vision in the Comprehensive Plan and has allotted over 37 million in streetscape improvements for this area. Project Description The City Center Core and Frame has potential for both new development and revitalization for retail, office, lodging, and housing activity. A market study will determine the capacity the City Center can expect to see in the next 20 years. The information will be used to complete a Planned Action SEPA for the city's Core and/or Frame areas and to develop strategies for recruiting the types of businesses the city would like to have in the City Center. The study will also be used to help determine whether both the Core and Frame should be included in the Planned Action SEPA. Consultants must have experience in conducting cost-benefit and financial analyses for development projects, market analyses, visioning, and in urban planning and design. Consultants must have performed similar work for other communities and possess a strong knowledge of retail office and residential markets, consumer trends, and the ingredients for development and redevelopment successes. Teams or partners bringing multiple areas of expertise are desirable, but not required. The final work product and tasks will include a written report with components described in the scope of work below, a presentation to the council's Land Use and Transportation Committee, and consultation to the consultant selected to prepare the Planned Action SEPA once this study has been completed. Scope of Work Specific tasks and questions to be answered in the analysis for both the City Center Core and Frame will include, but not be limited to: Define the market characteristics of the subject area including a regional overview, projected employment income, and population growth. IV. · Describe the existing economic profile for the City Center Core and Frame. At a minimum this should include: land use inventory, business mix, business performance, vacancy rates, residential development, activity generators, land availability, and land price. · Describe the influence of neighboring communities and developments and the implications and opportunities for Federal Way. · Describe development influences including: growth in regional economy and Federal Way's market share, growth in City Center Core and Frame employment and population, transit center and city hall, and mixed use development. · Describe retail demand including: regional retail market conditions and shopping patterns, local retail sales trends, existing conditions and retail development projections. · Describe office and lodging demand including: regional market, local conditions, and projected demand. · Describe current and future residential demand including existing housing market forecasts for multi-family, townhouses, condominiums and senior housing, and actions necessary to facilitate projected residential growth. · Identify barriers and key opportunities that the City has to achieving the downtown development/redevelopment vision identified in the City's Comprehensive Plan. Submission Content Submissions of qualifications should include, but not necessarily be limited to the following: * A brief narrative describing your firm and the vision your company would bring to this project. · Background and qualifications of staff likely to work on this project. · Descriptions of relevant experience. · Examples of similar work performed for other urban areas and related outcomes. · Identify the individual in charge of contractual arrangements or managing contracts (i.e. project manager). · Identify proposed fees and charges for the scope of work described above. · Identify time frame and steps to complete deliverables and tasks. V. Submission Evaluation A small committee composed of public and private sector representatives will review submissions. The committee will narrow down the pool of respondents to five finalists for a final interview. Interviews are tentatively scheduled for the week of April 16th, 2001. VI. Submission Procedure Please submit (5) copies to Kathy McClung, Director of Community Development Services P.O. Box 9718, Federal Way, WA. 98063-9718. The due date is 5:00 p.m., Friday, April 6, 2001. Questions about the RFP should be directed to Kathy McClung at Kathy. McClung~ci.federal-way.wa.us or 253.661.4107 or Lori Michaelson at Lori.Michaelsonl~ci.federal-way.wa.us or 253.661.4045. CITY OF FEDERAL WAY MEMORANDUM February 28, 2001 TO: FROM: VIA: SUBJECT: Dean McColgan, Chair Land Use/Transportation Committee (LUTC) Kathy McClung, Director of Community Development Services Margaret H. Clark, AICP, Senior Planner i~ David ~~~id~ger Selection Process -- 2001 Comprehensive Plan Update A. BACKGROUND The City of Federal Way updates its comprehensive plan once per year, starting September 30~ of each year. As discussed in the attached staff report, the City received six new site-specific requests and one request to amend the text of the Comprehensive Plan in September 2001. We also have four requests from previous years that have already been through the Selection Process, and are waiting for the Transportation Model to be finalized prior to being presented to the City's Development Review Committee for review. Staff is proposing to combine the site-specific requests received in September 200 with those requests received in previous years in order to complete them all this year, and be on schedule for the 2002 Comprehensive Plan Amendment Cycle (deadline for these request is September 2001). Bo PROPOSAL 1. Following is a summary of the six-site specific requests received in September 2000: a) Site Specific Request (41 - Request from Richard Senn to change the comprehensive plan designation and zoning of 28.79 acres located north of South 320~h Street and west of 30th Avenue SW from Single Family High Density Residential and RS 7.2 (one unit per 7,200 square feet) to Multifamily and RM 3600 (one unit per 3,600 square feet). b) Site Specific Request #2 - Request from Paul Benton to change the comprehensive plan designation and zoning of 4.03 acres located north of South 312~ Street and east of 1 st Avenue South from Professional Office (PO) to Office Park (OP). c) Site Specific Request #3 - Request from John Nguyen to change the comprehensive plan designation and zoning of 0.71 acres located south of South 308t~ Street and west of 14t~ Avenue South from Professional Office (PO) to Multifamily and RM 1800 (one unit per 1,800 square feet). d) Site Specific Request #4 - Request from John Smith to change the comprehensive plan designation and zoning of 3.1 acres located east of 33ra Place South in East Campus from Single Family High Density Residential and RS 9.6 (one unit per 9,600 square feet) to Office Park (OP). e) Site Specific Request #5 - Request from Chong Nam Yi to change the comprehensive plan designation and zoning of 1.43 acres located north of South 344~h Street and west of Pacific Highway South from Business Park (BP) to Community Business (BC). 0 Site Specific Request #6 - Request from Richard Hanson to change the comprehensive plan designation and zoning of 8.16 acres located south of the proposed Silverwood Subdivision, west of 9th Avenue SW from Single Family Medium Density Residential and RS 15.0 (one unit per 15,000 square feet) to Single Family High Density Residential and RS 9.6 (one unit per 9,600 square feet). 2. Request to amend the text of the Comprehensive Plan. A request was received from Rhys Sterling on behalf of Jean Suh to change the text of the comprehensive plan to allow compatible retail and other non-residential uses in areas designated for high-density single-family and multi-family uses. C. RECOMMENDATION Staff is recommending that Site-Specific Request #1 not be considered further because it does not meet certain selection criteria as discussed in the attached staff report, and that Site-Specific Requests #2, #3, #4, #5, and #6 be analyzed further. Also, staff recommends that the text amendment to allow compatible retail and other non-residential uses in areas designated for high- density single-family and multi-family uses not be considered further because it is not consistent with the overall vision of the comprehensive plan. In addition, the code already allows for Home Occupations in residentially zoned areas. APPROVAL OF COMMITTEE ACTION: Jbanne Burbidge ' O Eric Faison K:\Comprehensive PlanX20Ol~Vlemo to LUTC on Selection Process for 030501 Mtg.doc/Last printed 02/28/2001 O1:40 PM P~e2 CITY OF FEDERAL WAY STAFF REPORT February 26, 2001 Selection Process -- 2001 Comprehensive Plan Update BACKGROUND A formal process for updating the comprehensive plan and development regulations was adopted in March 1999. This process sets up a yearly deadline of September 30 to submit applications for amendments. Pursuant to Federal Way City Code (FWCC) Section 22-523, after the deadline for accepting applications, the City Council shall hold a public hearing and select those docketed amendment requests it wishes to consider for adoption. It is the City's practice that all City business be presented to a Council Committee, in this case the Land Use/Transportation Committee, before Council deliberation. Changes and updates to the comprehensive plan can be divided into updates to chapters and requests for changes to comprehensive plan designations and zoning for specific parcels. A. Status of the Comprehensive Plan Amendments 1. The 2000 Comprehensive Plan Update The City is in the process of working on the 2000 Comprehensive Plan Amendments (requests received September 1999). These site-specific requests were presented to the Council on October 17, 2000 to determine which requests should go forward for further analysis. The next stage in the Amendment Process is review by the City of Federal Way Development Review Committee (DRC). The Development Review Committee is comprised of representatives from the City of Federal Way Planning and Building Divisions, the Public Works and Public Safety Departments, as well as the Lakehaven Utility District and Federal Way Fire Department. The DRC reviews requests to identify any significant impacts that may result from changes in comprehensive plan designation and zoning. One of the impacts normally analyzed is impact on the transportation system. The City has recently updated the Transportation Model. The Model, although built, is undergoing further analysis in order to evaluate the Year 2000 Requests. Once analysis is complete, we will present the Year 2000 Requests to the DRC for review. 2. The 2001 Comprehensive Plan Update In September 2000, the City received six new site-specific requests for changes to the comprehensive plan designation and zoning. We also received one request for changes to the text of the comprehensive plan. 3. Proposal to Combine the 2000 and 2001 Comprehensive Plan Updates Staff is proposing to combine the site-specific requests received in September 1999 and those received in September 2000 due to the following reasons: (a) The site-specific requests received in September 1999, although having completed the Selection Process, cannot move forward until further analysis of the Transportation Model has been completed. (b) The previous deadline for the Five-Year Update of the Comprehensive Plan was September 2002. A bill has been introduced to extend that date to September 2004 for King County cities. This means that as part of the 2001 Update, we can review the Site Specific Requests received in September 2000 without having to make substantive text changes to comply with the Five-Year Update requirements. (c) Due to their scope, Phase II of the Potential Annexation Area (PAA) Study, the Planned Action SEPA for the downtown, and changes to address the Endangered Species Act (ESA) will not be completed in 2001. With a pending change in deadline from September 2002 to September 2004 for the Five-Year Update, we can complete the site-specific requests submitted to date without delay. As a result, staff is bringing forward the site-specific requests received in September 2000 for the Selection Process, in order to combine them with the two sets of requests previously received (those received in September 1999 and those received in September 2000) to move them forward simultaneously through the process. The alternative would be to complete the 2000 Comprehensive Plan Amendment Process (requests received in September 1999), and then process those requests received for the 2001 Update (requests received in September 2000). By combining the 2000 and 2001 site-specific requests, we will be able to complete both updates in 2001 and be on schedule for the 2002 Comprehensive Plan Update (deadline for these requests is September 2001) during which we will incorporate those items referenced in 3(c), above. 2001 Comprehensive Plan Update -- Site-Specific Comprehensive Plan Changes 1. In September 2000, the City received the following six site-specific requests (Exhibit A Composite Map): (a) Request from Richard Senn to change the comprehensive plan designation and zoning of 28.79 acres located north of South 3202 Street and west of 30th Page 2 of 22 Avenue SW from Single Family High Density Residential and RS 7.2 (one unit per 7,200 square feet) to Multifamily and RM 3600 (one unit per3,600 square feet) (Exhibit B). (b) Request from Paul Benton to change the comprehensive plan designation and zoning of 4.03 acres located north of South 312th Street and east of 1st Avenue South from Professional Office (PO) to Office Park (OP) (Exhibit C). (c) Request from John Nguyen to change the comprehensive plan designation and zoning of 0.71 acres located south of South 308~ Street and west of 14th Avenue South from Professional Office (PO) to Multifamily and RM 1800 (one unit per 1,800 square feet) (Exhibit D). (d) Request from John Smith to change the comprehensive plan designation and zoning of 3.1 acres located east of 33rd Place South in East Campus from Single Family High Density Residential and RS 9.6 (one unit per 9,600 square feet) to Office Park (OP) (Exhibit E). (e) Request from Chong Nam Yi to change the comprehensive plan designation and zoning of 1.43 acres located north of South 344th Street and west of Pacific Highway South from Business Park (BP) to Community Business (BC) (Exhibit F). (f) Request from Richard Hanson to change the comprehensive plan designation and zoning of 8.16 acres located south of the proposed Silverwood Subdivision, west of 9~h Avenue SW from Single Family Medium Density Residential and RS 15.0 (one unit per 15,000 square feet) to Single Family High Density Residential and RS 9.6 (one unit per 9.600 square feet) (Exhibit G). The following requests were received in September 2000 and have already been through the Selection Process. (a) Request from DMB Consulting Engineers on behalf of the owners of the Goodwin Dental Clinic to change the comprehensive plan designation and zoning of 0.48 acres located north of South 288~ Street and east of Pacific Highway South from Multifamily and RM 1800 (one unit per 1,800 square feet) to Community Business and BC zoning (Exhibit H). (b) Request from Jerry Jackson on behalf of himself and others for a City of Federal Way Community Business comprehensive plan designation and BC zoning with a Development Agreement associated with annexation of 27.19 acres located north of SW 320t~ Street and east of I-5. The property presently has a King County Comprehensive Plan Designation of Commercial Outside of Office and Urban Residential (4-12 dwelling units per acre) and zoning of Office and R-4 (Residential, four units per acre) (Exhibit I). 3. Requests received in April 1999 and deferred for review based on applicants' request: Page 3 of 22 (a) (b) Request from a number of property owners to change the comprehensive plan designation and zoning of 45.85 acres located south of South 3362 Street and west of Pacific Highway South from Business Park and BP zoning to Community Business and BC zoning and Multifamily (Exhibit d). The properties located east of the wetlands and adjacent to Pacific Highway South are requested to be Community Business and the northern three parcels west of the wetlands are requested to be Multifamily Request from the Weyerhaeuser Company to change the comprehensive plan designation and zoning of 49.97 acres located south of South 336th Street and east of Pacific Highway South from Business Park and BP zoning to Multifamily and RM 3600 zoning (one unit per 3,600 square feet) (Exhibit K). C. Request For Change To Comprehensive Plan Text A request was received from Rhys Sterling on behalf of Jean Suh to change the text of the comprehensive plan as follows (Exhibit L): 1. On Page IV-4, under Residential Areas, delete the last eight words of the sentence as follows: The City of Federal Way encourages integration of high-density housing with retail and other uses, espec'.'a!!y 2. On page IV-13, under Economic Development Goals, add the following goal: EDG4 The City will encourage the integration of high-density single-family and multi-family housing with compatible retail and other non-residential USES. 3. On Page IV-14, under Economic Development Goals, add the following goal: EDP23 The City will actively permit retail and other non-residential commercial uses within existing high density single-family and multi-family residential zoned areas, subject to minimum conditions imposed under Process III to ensure such integrated uses are compatible, and public health, safety, and welfare are protected. II REASON FOR COUNCIL ACTION Pursuant to FWCC Article IX, "Process VI Review," the City Council is required to review all requests concurrently. Further, prior to adoption, the Council is required to hold a public hearing, at which time it selects those amendment requests it wishes to consider for adoption based on specific criteria outlined in Section IV of this staff report. Page 4 of 22 III PROCEDURAL SUMMARY FOR 2001 COMPREHENSIVE PLAN AMENDMENT PROCESS September 30, 2000 Deadline for Applications March 5, 2001 LUTC Meeting - A summary of all requests will be presented to the LUTC for determination of which requests should be considered during the upcoming amendment process. April 17, 2001 Public Hearing by City Council. IV DECISIONAL CRITERIA The following criteria shall be used in selecting the comprehensive plan amendments to be addressed during the upcoming cycle: Whether the same area or issue was studied during the last amendment process and conditions in the immediate vicinity have significantly changed so as to make the requested change within the public interest. 2. Whether the proposed amendment is consistent with the overall vision of the comprehensive plan. 3. Whether the proposed amendment meets existing state and local laws, including the Growth Management Act. 4. In the case of text amendments or other amendments to goals or policies, whether the request benefits the city as a whole versus a selected group. If the request meets the criteria set forth in 1-4 above, it shall be further evaluated according to the following criteria: 5. Whether the proposed amendment can be incorporated into planned or active projects. Amount of analysis necessary to reach a recommendation on the request. If a large-scale study is required, a request may have to be delayed until the following year due to workloads, staffing levels, etc. 7. Volume of requests received. A large volume of requests may necessitate that some requests be reviewed in a subsequent year. 8. Order of requests received. Based on its review of requests according to the above criteria, the Council shall determine which requests shall be further considered for adoption, and shall forward those requests to the Planning Commission for its review and recommendation. Page 5 of 22 V STAFF ANALYSIS AND RECOMMENDATION SITE SPECIFIC REQUEST #1 File Number: Parcel: Location: Size: Applicant: Agent: Owner: Request: 00-104941-00 UP 122103-9029 North of S 320~h St and west of 30~ Ave SW (Exhibit B) 28.79 acres Richard Senn Same Same Request to change the comprehensive plan designation and zoning from Single Family High Density Residential and RS 7.2 (one unit per 7,200 sq ft) to Multi-family and RM 3600 (one unit per 3.600 sq ft) Existing Comprehensive Plan: Existing Zoning: Proposed Comprehensive Plan: Proposed Zoning: Single Family High Density Residential RS 7.2 Multi-family RM 3600 DECISIONAL CRITERIA Criterion No 1 Whether the same area or issue was studied during the last amendment process and conditions in the immediate vicinity have significantly changed so as to make the requested change within the public interest. Staff Response This area was not studied during the last amendment process. This apartment complex was approved by King County as Quail Run III; a Planned Unit Development (PUD) of 166 attached units and was recorded on December 1989, prior to the City's incorporation. At that time, the King County zoning was Suburban Residential (SR). As stated in King County, Title 21 - Zoning, the intent of a PUD is to permit flexibility that will encourage a more creative approach in the development of land. Upon incorporation, the site was zoned RS 7.2 (Single Family - one unit per 7,200 square feet) by Federal Way. Apartments are a legal nonconforming use in this zone. The complex has since been renamed as Forest Village. Adjacent uses to the east and west are single family residential. To the north is vacant property owned by Collella Estates, for which there is an application in process for preliminary plat approval for 108 lots. To the south are condominiums (Quail Run Divisions I and II). Existing density is 5.77 units per acre. A zoning of RM 3.6 allows a density of approximately 12 units per acre, which could potentially allow an additional 179 units for a total of 345 units. Based on a site visit, there are steep slopes on the western portion of the site through which Joe's Creek runs. Joe's Creek discharges into the nearshore environment (Shorelines), critical habitat for the threatened Chinook Salmon species. The remaining area is developed with two-story attached units. An RM 3.6 zoning could result in doubling the density. Conditions have not changed since construction in 1989/ Page 6 of 22 1990 to make the requested change within the public interest, especially as the complex is served by one access only, 30t~ Avenue SW, which is only a half street for a portion of its length. Originally, there was a second access, SW 3192, a private road through Quail Run Phases I and II. However, this private road has been blocked by the residents of Quail Run I and II due to through traffic from Quail Run III. Criterion No 2 Whether the proposed amendment is consistent with the overall vision of the comprehensive plan. Staff Response The site has been developed as a Planned Unit Development since 1989/1990. The existing development fits in with adjacent uses. However, potentially doubling the density would not be consistent with Comprehensive Plan Goal L UG3 - Preserve and protect Federal Way's single-family neighborhoods. Criterion No 3 Whether the proposed amendment meets existing state and local laws, including the Growth Management Act. Staff Response The proposal does not conflict with any existing state or local laws, including the Growth Management Act. The area is already developed with all existing services. However, as mentioned under Criterion 1 above, there is only one access to Forest Village presently, which does not meet City code. If the request was approved, and a multi-family land use designation was granted, any future development permit would have to meet all City requirements. Criterion No 4 In the case of text amendments or other amendments to goals or policies, whether the request benefits the city as a whole versus a selected group. Staff Response This criterion does not apply to this request, since it is a site-specific request. If the request meets the criteria set forth in 1-4 above, it shall be further evaluated according to the following criteria: Please note that the response to the following Criteria 5, 6, and 7are the same for all six requests and therefore, only one analysis will be done for these three criteria. Criterion No 5 Whether the proposed amendment can be incorporated into planned or active projects Staff Response The proposed requests can be incorporated into this year's comprehensive plan update. Criterion No 6 Amount of analysis necessary to reach a recommendation on the request. If a l~rge-scale study is required, a request may have to be delayed until the following year due to workloads, staffing levels, etc. Page 7 of 22 Staff Response The analysis necessary to reach a recommendation on these requests can be done as part of the work required for the combined 2000 and 2001 Comprehensive Plan Update. Criterion No 7 Volume of requests received. A large volume of requests may necessitate that some requests be reviewed in a subsequent year Staff Response Six new requests for site-specific comprehensive plan amendments and one request for a text amendment have been received. In addition, the Council approved two requests to be considered further for the 2000 Update and there were also two requests carried over from 1999, based on requests of the applicants and the need for additional market and transportation-related information. This brings the total to ten site-specific requests and one request for a text amendment. These requests can all be processed this year. Furthermore, processing the site-specific requests concurrently will enable staff to analyze the overall impact on the transportation system and the demand for land. Criterion No 8 Order of requests received Staff Response This was the sixth site-specific request received. Staff Recommendation: That the request not go forward for further analysis because it does not meet Criteria No's 1 and 2. SITE SPECIFIC REQUEST #2 File Number: Parcel: Location: Size: Applicant: Owner: Request: 00-104926-00 UP 082104-9074, 082104-9076 & 082104-9167 North of S 312th St and east of 1st Ave S (Exhibit C) 4.03 acres Paul Benton Same Request to change the comprehensive plan designation and zoning from Professional Office (PO) to Office Park (OP) Existing Comprehensive Plan: Existing Zoning: Proposed Comprehensive Plan: Proposed Zoning: Professional Office Professional Office (PO) Office Park Office Park (OP) Page 8 of 22 DECISIONAL CRITERIA Criterion No 1 Whether the same area or issue was studied during the last amendment process and conditions in the immediate vicinity have significantly changed so as to make the requested change within the public interest. Staff Response This area was studied as part of the 1995 Comprehensive Plan Amendment process. At that time, these parcels had a comprehensive plan designation of Suburban Residential and zoning of Professional Office (PO). The applicant requested a comprehensive plan designation of Office Park to eliminate the inconsistency between PO zoning and the Suburban Residential land use designation. The City Council approved the request to designate the parcels with an Office Park Land Use designation, which at that time corresponded to the PO zoning. During the 1999 Comprehensive Plan Amendment Process, a new Comprehensive Plan designation of Professional Office was added to reflect more closely uses allowed in the Professional Office Zone. The applicant is requesting OP zoning to build senior housing. Land uses in the immediate vicinity have not significantly changed during the last five years. The adjacent use to the north is a single- family development, Parkwood Campus, which was constructed after incorporation of the City in 1990. The adjacent use to the east is also single-family. The use to the south is a multi-family complex (Greystone Meadows Apartments), and across the street to the west is a 7-11 convenience store and Papa John's Pizza on the comer with vacant land further to the north. Senior housing is allowed in the RS Single Family Residential zone and all Multi-Family zones, either of which may be more appropriate zoning for this location than an Office Park (OP) zone. Senior housing is also allowed in the Community Business (BC), City Center Core (CC-C), City Center Frame (CC-F). Office Park (OP), and Business Park (BP) zones. These commercial designations are not appropriate for this location. Criterion No 2 Whether the proposed amendment is consistent with the overall vision of the comprehensive plan. Staff Response The overall vision of the comprehensive plan is to provide an appropriate balance of services, employment, and housing. This comer was designated Professional Office to provide for small- scale office development compatible with adjacent residential neighborhoods. Designating these parcels as Office Park would not conform to this vision as the Office Park Designation allows for a mix of office and compatible manufacturing type activities with a limited amount of retail support services. Therefore, Office Park uses would not be appropriate for this location. Moreover, a Market Study prepared for the City in 2000 found that the City has enough capacity designated for different uses to accommodate the 20-year employment forecast. However, while there is adequate land for employment growth in the aggregate, several districts achieve more than 50 percent buildout. These are Neighborhood Business (BN), City Center Frame (CC-F), Corporate Park (CP-1), and Professional Office (PO). Even though the majority of uses allowed in the OP zone may not be appropriate for this location, senior housing would be compatible with surrounding uses. Page 9 of 22 Criterion No 3 Whether the proposed amendment meets existing state and local laws, including the Growth Management Act. Staff Response The proposal does not conflict with any existing state or local laws, including the Growth Management Act. However, these parcels are located within the Mirror Lake Basin, which has been experiencing flooding problems. Development of this site for any use will have to meet the requirements of the King County Water Surface Water Design Manual. Criterion No 4 In the case of text amendments or other amendments to goals or policies, whether the request benefits the city as a whole versus a selected group. Staff Response This criterion does not apply to this, since this is a site-specific request. If the request meets the criteria set forth in 1-4 above, it shall be further evaluated according to the following criteria: Please refer to responses under Site Specific Request #1 for Criteria 5, 6, and 7. Criterion No 8 Order of requests received. Staff Response This was the fifth site-specific request received. Staff Recommendation: Based on information provided by the applicant, they are requesting an OP zoning so that they can build senior housing. Senior housing is also allowed in the RS (Single Family Residential) and the RM (Multi-family zone), either of which may be more appropriate zoning for this location than an Office Park (OP) zone. Staff recommends that this request be analyzed further with the goal of allowing senior housing. SITE SPECIFIC REQUEST/t3 File Number: Parcel: Location: Size: Applicant: Owner: Request: 00-104891-00 UP 082104-9138 South of S 308th St and west of 14t~ Ave S (Exhibit D) 0.71 acres/31,050 sq ft John Nguyen Same Request to change the comprehensive plan designation and zoning of the Lake Apartments from Professional Office (PO) to Multifamily and RM 1800 (one unit per 1,800 square feet) Page 10 of 22 Existing Comprehensive Plan: Existing Zoning: Proposed Comprehensive Plan: Proposed Zoning: Professional Office Professional Office (PO) Multi-family RM 1800 (1 unit per 1,800 sq ft) DECISIONAL CRITERIA Criterion No 1 Whether the same area or issue was studied during the last amendment process and conditions in the immediate vicinity have significantly changed so as to make the requested change within the public interest. Staff Response This area was not studied during the last amendment process. The Lake Apartments, a 15-unit complex, was constructed in 1958. At the time of City incorporation in 1990, it was zoned Multifamily (RM 900) by King County. Federal Way adopted a zoning of Professional Office for this apartment complex and the two parcels to the north, Existing uses in this area include a dental office to the north, Southridge House, a senior housing complex to the east, the Lake Easter Estates Condominiums to the west and the Liberty Lake Condominiums to the south. Conditions in the immediate vicinity have not significantly changed in recent years. However, the Lake Apartments are an existing legal nonconforming use and changing the land use designation and zoning to RM - Multifamily and RM 1.8 (Multi-family, one unit per 1,800 square feet) would make the use consistent with the zoning, while not impacting surrounding uses. Criterion No 2 Whether the proposed amendment is consistent with the overall vision of the comprehensive plan. Staff Response Policy LUP23 of the Comprehensive Plan reads, "Support multiple family development with transportation and capital facilities improvements". The Lakes Apartments are located one block to the west of Pacific Highway and approximately half a block north of South 312th Street. Transportation is readily accessible as both Pacific Highway and South 3122 Street are bus routes. Criterion No 3 Whether the proposed amendment meets existing state and local laws, including the Growth Management Act. Staff Response The proposal does not conflict with any existing state or local laws. Criterion No 4 In the case of text amendments or other amendments to goals or policies, whether the request benefits the city as a whole versus a selected group. Staff Response This criterion does not apply to this request, since it is a site-specific request. Page 11 of 22 If the request meets the criteria set forth in 1-4 above, it shall be further evaluated according to the following criteria: Please refer to responses under Site Specific Request #1 for Criteria 5, 6, and 7. Criterion No 8 Order of requests received. Staff Response This was the fourth request received. Staff Recommendation That the request goes forward for further analysis. SITE SPECIFIC REQUEST #4 File Number: Parcel: Location: Size: Applicant: Agent: Owner: Request: 00-104441-00 UP 726120-0060 East of 33rd PI S in East Campus (Exhibit E) 3.1 acres John Smith Harry Horan Rachel Smith Request to change the comprehensive plan designation and zoning from Single Family High Density Residential and RS 9.6 to Office Park (OP-1) Existing Comprehensive Plan: Existing Zoning: Proposed Comprehensive Plan: Proposed Zoning: Single Family High Density Residential RS 9.6 Office Park Office Park (OP- 1) DECISIONAL CRITERIA Criterion No 1 Whether the same area or issue was studied during the last amendment process and conditions in the immediate vicinity have significantly changed so as to make the requested change within the public interest. Staff Response This area was not studied during the last amendment process. It was annexed in 1994 as part of a much larger annexation, the East Campus Annexation. Since that time, East Campus has seen a great demand for office development. The use to the north is the Slavik Gospel Church. The use to the east and south consists of office buildings under construction for Weyerhaeuser use, uses to the northwest across 33ra P1 S is residential along North Lake and uses to the southwest is part of the Weyerhaeuser Corporate headquarters. Due to all the recent office development in this area, a case can be made that conditions in the immediate vicinity have significantly changed so as to make the requested change within the public interest. Page 12 of 22 Criterion No 2 Whether the proposed amendment is consistent with the overall vision of the comprehensive plan. Staff Response The overall vision of the comprehensive plan is to provide an appropriate balance of services, employment, and housing. A Market Study prepared for the City in 2000 identifies that the finance, insurance, real estate, and services (FIRES) sector has the greatest demand for future built space. However, the Market Study also states that there may not be enough land zoned outright for residential uses to accommodate projected residential uses. Criterion No 3 Whether the proposed amendment meets existing state and local laws, including the Growth Management Act. Staff Response The request for an Office Park comprehensive land use designation and zoning is not inconsistent with existing state and local laws, including the Growth Management Act. Criterion No 4 In the case of text amendments or other amendments to goals or policies, whether the request benefits the city as a whole versus a selected group. Staff Response This criterion does not apply to this request, since it is a site-specific request. If the request meets the criteria set forth in 1-4 above, it shall be further evaluated according to the following criteria: Please refer to responses under Site Specific Request # 1 for Criteria 5, 6, and 7. Criterion No 8 Order of requests received. Staff Response This was the second request received. Staff Recommendation That the request goes forward for further analysis SITE SPECIFIC REQUEST #$ File Number: Parcel: Location: Size: Applicant: 00-104875-00 UP 202104-9121 North of S 344~h St and west of Pacific Highway S (Exhibit F) 1.43 acres Chong Nam Yi Page 13 of 22 Agent: Owner: Request: Harry Horan Yi/Roe Request to change the comprehensive plan designation and zoning from Business Park (BP) to Community Business (BC) Existing Comprehensive Plan: Existing Zoning: Proposed Comprehensive Plan: Proposed Zoning: Business Park Business Park (BP) Community Business Community Business (BC) DECISIONAL CRITERIA Criterion No 1 Whether the same area or issue was studied during the last amendment process and conditions in the immediate vicinity have significantly changed so as to make the requested change within the public interest. Staff Response This area was not studied during the last amendment process. However, in April 1999, the City received a request to change the comprehensive plan designation and zoning of 45.85 acres located just south of South 336th Street and west of Pacific Highway from Business Park to Community Business (please refer to Site Specific Request #9 and Exhibit G). In April 1999, the City also received a request to change the comprehensive plan designation and zoning of 49.97 acres located just south of South 336th Street and east of Pacific Highway from Business Park to Multi-family (please refer to Site Specific Request # 10 and Exhibit H). The two requests received in April 1999 will be processed concurrently with those requests received in September 2000, and those received in September 2001. This will allow staff to evaluate all requests concurrently to determine the impact on the Business Park-zoned land. The existing use to the north is a tow company and mobile home. To the east is Neimen Glass. To the west are industrial office buildings and to the south is storage. However, the property to the south was recently purchased by Lloyd's Trucking. Criterion No 2 Whether the proposed amendment is consistent with the overall vision of the comprehensive plan. Staff Response The overall vision of the Comprehensive Plan is to restrict commercial development to the downtown (City Center Core and Frame), to Pacific Highway South, generally between South 272na Street and South 348~ Street, and to the areas found around South 348~ Street, approximately between SR-99 and 1-5. In addition, there are a dozen nodes of Neighborhood Business located throughout the City. These nodes have traditionally provided retail and services to adjacent residential neighborhoods. The Market Study prepared for the City in 2000 identifies that the City has enough capacity designated for commercial uses to accommodate the 20-year employment forecast; therefore, there is not a demand for additional commercially zoned land. The Study also identified that there would be a demand for 11 to 13 percent of Business Park zoned land from 2000 to 2020, a 20-year planning horizon. However, in the last year since the base data for the Market Study was collected, the City has experienced increased development of BP-zoned land. Page 14 of 22 Criterion No 3 Whether the proposed amendment meets existing state and local laws, including the Growth Management Act. Staff Response The proposal does not conflict with any existing state or local laws. Criterion No 4 In the case of text amendments or other amendments to goals or policies, whether the request benefits the city as a whole versus a selected group. Staff Response This criterion does not apply to this request, since it is a site-specific request. If the request meets the criteria set forth in 1-4 above, it shall be further evaluated according to the following criteria: Please refer to responses under Site Specific Request it 1 for Criteria 5, 6, and 7. Criterion No 8 Order of requests received. Staff Response This was the third request received. Staff Recommendation That the request goes forward for further analysis. The additional analysis should analyze the location and amount of vacant buildable Business Park-zoned land in light of recent development taken in the context of Requests it9 and # 10. SITE SPECIFIC REQUEST #6 File Number: Parcel: Location: Size: Applicant: Agent: Owner: Request: 00-104224-00 UP 302104-9033 South of proposed Silverwood Subdivision, west of 9~ Ave SW (Exhibit G) 8.16 acres Richard Hanson De-En Lang, Subdivision Management Richard Hanson Request to change the comprehensive plan designation and zoning from Single Family Medium Density Residential/RS 15.0 to Single Family High Density Residential/RS 9.6 Existing Comprehensive Plan: Existing Zoning: Single Family Medium Density Residential RS 15.0 Page 15 of 22 Proposed Comprehensive Plan: Proposed Zoning: Single Family High Density Residential RS 9.6 DECISIONAL CRITERIA Criterion No 1 Whether the same area or issue was studied during the last amendment process and conditions in the immediate vicinity have significantly changed so as to make the requested change within the public interest. Staff Response This parcel was part of a larger parcel requesting a change in comprehensive plan designation and zoning of Urban Residential and RS 9.6 (Single Family, one unit per 9,600 square feet) in 1995. At that time, the Land Use Chapter of the Comprehensive Plan stated that upon availability of sewers, an increase in density might be warranted. Only a portion of the total area requesting the comprehensive plan amendment was granted the request. The area granted a change from RS 15.0 (Single Family Residential, one unit per 15,000 square feet) zoning to RS 9.6 (Single Family Residential, one unit per 9,600 square feet) zoning is now under review as the Silverwood plat. The reason that "Silverwood" was granted a change in designation was that the owners committed to the City that sewer would be extended to serve the area. With the area to the north being developed as single family lots, and sewer having been extended to the north of the Hanson property, conditions in the area have changed. However, there are still single-family development on large lots to the east and south. Property to the west is the 363~a Open Space, owned by the City of Federal Way. There is wetland located on the western portion of the site. Criterion No 2 Whether the proposed amendment is consistent with the overall vision of the comprehensive plan. Staff Response The Comprehensive Plan (page II-13) states that the Single Family Medium Density designation creates urban lots with a density range of one to three dwelling units per acre to avoid developing on or near environmentally sensitive areas. However, Federal Way Policy LUP9 states, "Designate and zone land for Federal Way's share of regionally-adopted demand forecasts for residential, commercial and industrial uses for the next 20 years." RS 9.6 zoning would allow for 4.5 units per acre, as opposed to the presently allowable density of 2.9 units per acre. The Market Study prepared for the City in 2000, identifies a shortage of land zoned outright for residential development in terms of meeting regional forecasts, based on historical development. Criterion No 3 Whether the proposed amendment meets existing state and local laws, including the Growth Management Act. Staff Response The proposal does not conflict with any existing state or local laws. In addition, GMA goals include encouraging growth in urban areas and reducing urban sprawl, which should be furthered by development of this site. Page 16 of 22 Criterion No 4 In the case of text amendments or other amendments to goals or policies, whether the request benefits the city as a whole versus a selected group. Staff Response This criterion does not apply to this request, since it is a site-specific request. If the request meets the criteria set forth in 1-4 above, it shall be further evaluated according to the following criteria: Please refer to responses under Site Specific Request # 1 for Criteria 5, 6, and 7. Criterion No 8 Order of requests received. Staff Response This was the first request received. Staff Recommendation That the request goes forward for further analysis. The following requests were received in September 2000 and have already been through the Selection Process. SITE SPECIFIC REQUEST//7 File Number: Parcel: Location: Size: Applicant: Agent: Owner: Request: CPA99-0011 332204-9109 North of 288~ St and east of Pacific Highway (Exhibit H) 0.48 acres. Thomas Goodwin and Carl Jacobson DMB Consulting Engineers Thomas Goodwin and Carl Jacobson (Goodwin Dental Clinic) To change the comprehensive plan designation and zoning from Multifamily (RM 1800 -- one unit per 1,800 square feet) to Community Business (BC) Existing Comprehensive Plan: Existing Zoning: Proposed Comprehensive Plan: Proposed Zoning: Council Determination: Multi family RM 1800 Community Business Community Business (BC) Analyze the request further based on a comprehensive plan designation and zoning of Community Business and BC Page 17 of 22 SITE SPECIFIC REQUEST #8 File Number: Parcels: Location: Size: Applicant: Agent: Owners: Request: CPA99-0014 092104-913 9; 092104-9316; 092104-9187; 092104-9140; 092104-9206; 0921049028; 092104-9310 & 092104-9318 North of SW 320~ St and east of I-5 (Exhibit I) 27.19 acres Jerry Jackson Jerry Jackson Please refer to following table Parcel No. Owner Acres 092104-9139 All-American Homes 9.15 acres 092104-9316 All-American Homes 0.33 acres 092104-9187 Larry Weigel 1.15 acres 092104~9140 Donald J. Henderson 2.28 acres 092104-9206 Arthur Henderson 0.33 acres 092104-9028 William Pmett 5.25 acres 092104~9310 Winchester Investment Corporation 4.6 acres 092104-9318 Youngyul Na 4.1 acres Total 27.19 acres To change the comprehensive plan and zoning from King County Comprehensive Plan Designation of Commercial Outside of Office and Urban Residential (4-12 dwelling units per acre) to Community Business with a Development Agreement Existing Comprehensive Plan: Existing Zoning: Proposed Comprehensive Plan: Council Determination: King County Comprehensive Plan Designation of Commercial Outside of Office and Urban Residential (4-12 dwelling units per acre) King County Office and R-4 (Residential, four units per acre) Community Business with a Development Agreement Analyze the request further based on a comprehensive plan designation and zoning of Office Park and OP. The two following requests were originally submitted in April 1999. Based on traffic-related questions, and questions pertaining to supply and demand of variously zoned land in the City, the applicants requested that work be deferred on their requests until a citywide market analysis and transportation model had been completed. The market analysis has been completed. The transportation model has been built, but is undergoing further analysis. SITE SPECIFIC REQUEST #9 File Number: Parcels: Location: Size: Agent: Applicant: Owner: CPA99-0008 202104-9069,202104-9070, 202104-9001,202104-9090, 202104-9086, 202104-9080, 202104-9072, 202104-9004, 202104-9051, & 202104-9100 South of S 336th St and west of Pacific Highway S (Exhibit d) 45.85 acres Richard Borsini on behalf of Campus Gateway Associates, Gene Merlino, and Chase WN Trust Please refer to following table Please refer to following table Page 18 of 22 Request: Number Parcel No. Owner Acres I 202104-9069 Johal Rajhinder; Kulwinder 1.15 acres 2 202104-9070 Campus Gateway Associates 16.75 acres 3 202104-9001 Gene Merlino 8.9 acres 4 202104-9090 Richard Lyons 0.2 acres 5 202104-9086 Richard Carson 4.93 acres 6 202104-9080 Ralph Jones 1.5 acres 7 202104-9072 Chase WN Trust 7.75 acres 8 202104-9004 Slisco/Knight/Dagmar 4.44 acres 9 202104-9051 Bob Wright 8.28 acres 10 202104-9100 Orville & Victoria Cohen 0.85 acres Total 45.85 acres To change the comprehensive plan designation and zoning from Business Park (BP) to Community Business (BC) for areas east of the wetlands and Multifamily and RM 2400 for the northern three parcels west of the wetlands (numbers 2, 3, and 7 in the above table) Existing Comprehensive Plan: Existing Zoning: Proposed Comprehensive Plan: Proposed Zoning: Council Determination: Business Park Business Park (BP) Community Business for the areas east of the wetlands and Multifamily for the northern three parcels west of the wetlands (numbers 2, 3, and 7 in the above table) Community Business (BC) Business for the areas east of the wetlands and Multifamily (RM 2400) for the northern three parcels west of the wetlands (numbers 2, 3, and 7 in the above table) Analyze the request further based on a comprehensive plan designation and zoning of Community Business (BC) for areas east of the wetlands and Multifamily and RM 2400 for the northern three parcels west of the wetlands (numbers 2, 3, and 7 in the above table) SITE SPECIFIC REQUEST #10 File Number: Parcels: Location: Size: Applicant: Owner: Agent: Request: CPA99-0004 212104-9003, 212194-9004, 212104-9016, 212104-9051, 212104-9063, 212104-9064, 212104-9065, 212104-9066, 212104-9067, 212104-9069, 212104-9083, & 212104-9084 South ofS 336~h St and east of Pacific Highway S (Exhibit K) 49.97 acres Wayne Rankin, Christian Faith Center The Weyerhaeuser Company G. Wayne Potter, Barghausen Consulting Engineers To change the comprehensive plan designation and zoning from Business Park (BP) to Multifamily and RM 3600 zoning (one unit per 3,600 square feet) Page 19 of 22 Parcel No. Acres 212104-9003 5 acres 212194-9004 4.91 acres 212104-9016 5 acres 212104-9051 5 acres 212104-9063 5 acres 212104-9064 4.94 acres 212104-9065 4.92 acres 2'12104-9066 4.91 acres 212104-9067 2.32 acres 212104-9069 5.01 acres 212104-9083 1.62 acres 212104-9084 1.34 acres Total 49.97 acres Existing Comprehensive Plan: Existing Zoning: Proposed Comprehensive Plan: Proposed Zoning: Council Determination: Business Park Business Park Multifamily Multifamily - RM 3600 zoning (one unit per 3,600 square feet) Analyze the request further based on a comprehensive plan designation and zoning of Multi-family and RM 3600 zoning (one unit per 3,600 square feet) REQUEST FOR TEXT AMENDMENT A request was received from Rhys Sterling on behalf of Jean Suh to change the text of the comprehensive plan as follows (Exhibit L): 1. On Page IV-4, under Residential Areas, delete the last eight words of the sentence as follows: The City of Federal Way encourages integration of high-density housing with retail and other uses, ..... ;,.lh, .~l,.~.,~ el> OO ,~n,4 ;~. tU.~ ~;~, ~ont~ 2. On page IV-13, under Economic Development Goals, add the following goal: EDG4 The City will encourage the integration of high-density single-family and multi-family housing with compatible retail and other non-residential uses. 3. On Page IV-14, under Economic Development Goals, add the following goal: EDP23 The City will actively permit retail and other non-residential commercial uses within existing high density single-family and multi-family residential zoned areas, subject to minimum conditions imposed under Process III to ensure such integrated uses are compatible, and public health, safety, and welfare are protected. Page 20 of 22 DECISIONAL CRITERIA Criterion No 1 Whether the same area or issue was studied during the last amendment process and conditions in the immediate vicinity have significantly changed so as to make the requested change within the public interest. Staff Response This issue has never been studied before. There have been no changes in the City to make the requested change to allow retail and other non-residential uses, not presently allowed, in areas designated as Single Family High Density Residential and Multi-family, in the public interest. Approving such a text amendment may allow these uses in the RS 9600, RS 7200, RS 5000, RM 3600, RM 2400, and RM 1800 zones. Criterion No 2 Whether the proposed amendment is consistent with the overall vision of the comprehensive plan. Staff Response As stated on page II-1 of the Comprehensive Plan, the Land Use Concept is the preservation and enhancement of existing residential neighborhoods; therefore, the proposed amendment is not consistent with the comprehensive plan. Criterion No 3 Whether the proposed amendment meets existing state and local laws, including the Growth Management Act. Staff Response The proposal does not conflict with any existing state or local laws, including the Growth Management Act. Criterion No 4 In the case of text amendments or other amendments to goals or policies, whether the request benefits the city as a whole versus a selected group. Staff Response This text amendment would serve to benefit only the applicant. Presently, home occupations are allowed in residential neighborhoods as long as they meet the criteria stated in the code. If the request meets the criteria set forth in 1-4 above, it shall be further evaluated according to the following criteria: Please refer to responses under Site Specific Request #1 for Criteria 5, 6, and 7. Criterion No 8 Order of requests received Staff Response This was the third request received. Page 21 of 22 Staff Recommendation: That the request not goes forward for further analysis because it does not meet Criterion No 2. V COUNCIL ACTION Pursuant to FWCC Section 22-523(D), based on its review of requests according to the criteria in Section IV of this staff report, the City Council shall determine which requests shall be further considered for adoption, and shall forward those requests to the Planning Commission for its review and recommendation. The Council's decision to consider a proposed amendment shall not constitute a decision or recommendation that the proposed amendment should be adopted, nor does it preclude later Council action to add or delete an amendment for consideration. VI LIST OF EXHIBITS Exhibit A Composite Map of Site Specific Requests Exhibit B Site Specific Request #1 Exhibit C Site Specific Request #2 Exhibit D Site Specific Request #3 Exhibit E Site Specific Request #4 Exhibit F Site Specific Request #5 Exhibit G Site Specific Request #6 Exhibit H Site Specific Request #7 Exhibit I Site Specific Request #8 Exhibit J Site Specific Request #9 Exhibit K Site Specific Request #10 Exhibit L Request for a Text Amendment l:\00cmpamn\Staff Report on Selection Process to 82100 LUTC Meeting.doc/2/28/01 1:39 PM Page 22 of 22 LU C) CO 0 Z ~0 ~' ~©,-, L ~ '~ ~- O~z ~ r-0 I I $ LU n <; 0 E 00 o ~ 0 LU 0 ~ 0 ~ ~ou BAGE._~I Ob/ I I I I I I FTTI ~q Z Z o E ~oe_ m 0 LU C-) (,'0 Z :0' 0 CD 0 .1' C~ Z d d 0 L,., I:: 0 ~ Z ~ RHYS A. STERLING, P.E., Attorney at Law JoDo P.O. Box 218 Hobart, Washington 98025-0218 (425) 432-9348 (voice message) E-mail: RhysHobart@aol.com 1495 N.W. Gilman Blvd. Suite 4-G Issaquah, Washington 98027 (425) 391-6650 (daytime) Facsimile (425) 391-6689 September 19, 2000 HAND DELIVERED Stephen Clifton, Director Community Development Services 33530 1st Way South Federal Way, Washington 98063 COM~,~L~f'!Fi"¢ ........ Re: Jean J. Suh Applications for Amendments to Comprehensive Plan and Development Regulations to Accommodate Retail and Other Commercial Uses in High Density Single-Family and Multi-Family Residential Zones Dear Mr. Clifton: I represent Jean J. Suh as the owner/resident of the single- family residence at 2011 South 330th Street, Federal Way, Washing- ton, and the owner as sole proprietor of the Korean Broadcasting Station Radio Hankook (KSUH AM 1450 Puyallup / KWYZ AM 1230 Ever- ett). Mrs. Suh respectfully submits the attached two (2) applica- tions to the City of Federal Way for its consideration in amending (a) the Comprehensive Plan and (b) the Development Regulations to generally accommodate retail and other uses in high density resi- dential areas consistent with the "vision" statement as expressed, but as yet unimplemented, under the current Comprehensive Plan. Mrs. Suh's suggested amendments initially address the location of radio broadcast stations within appropriate residential zones as one such compatible use. Please phone me at 425-391-6650 if you have any questions re- garding this matter. Thank you for your cooperation. Very truly yours, RHYS A. STERLING, P.E., Attorney at Law Jom. Enclosures cc: Jean J. Suh PAGE APPLICATION NO O~) "'/04t~0 4 -O O -- U/° Project Name MASTER LAND USE APPLICATION DEPARTMENT OF COMMUNITY DEVELOPMENT SERVICES 33530 First Way South, Federal Way, WA 98003 (253) 661-4000 - Fax (253) 661-4129 www.ci, federal-way.wa.us September 18, 2000 Date Application for Non-Site Specific Comprehensive Plan Amendment Property Address/Location Parcel Number(s) Applicant Name: Jean J. Sub Address: 2011 South 330th St. Federal Way, WA 98003 Ph°ne: (253) 815-1212 Fax:( 253) 815-1913 Email: Signature: Zoning Designatmn Agent (If Different than Applicant) Address: $>. o. ~'o ~ 218' 0 Phone: Fax: (t/2~' Signature: Comp Plan Designation Owller 'Name:Jean J. Suh Address: 2011 South 330th St. Federal Way, WA 98003 Ph°ne:(253) 815-1212 Fax: ( ) Email:253 815-1913 'roject Description Non-site specific amendment to Comprehensive Plan to implement with goals and policies the current vision statement that the City encourage integra- tion of high-density housing with retail and other uses. Uniform Building Code (UBC) Construction Type ~/~- (UBC) Occupancy Type Type of Permit Required: SEPA Checklist Notice Mailed Sign Board (Refer to Development Submittal Requirements Handout) Annexation R R __ Binding Site Plan R R R __ Boundary Line Adjustment __ Comp Plan/Rezone R R Land Surface Modification R R * Lot Line Elimination __ Pre. application Conference __ Process I (Director's Approval) ~ Process II (Site Plan Review) R* R __ Process III (Project Approval) R R R __ Process IV (Hearing Examiner's Decision) R Rx2 R __ Process V (Quasi-Judicial Rezone) ~ Process VI R R R ~ SEPA Only R R Shoreline R R * Variance R R R Conditional Use R R R Short Subdivision * R * Subdivision R R = Required DEPARTMENT OF COMMUNITY DEVELOPMENT SERVICES 33530 First Way South P.O. Box 9718 Federal Way WA 98063-9718 (253) 661-4000 - Fax (253) 661-4129 www.ci, federal-way.wa.us APPLICATION FOR COMPREHENSIVE PLAN AMENDMENT 1. SITE SPECIFIC REQUESTS a) }Vho may apply. Any person may, personally or through an agent, apply for a decision regarding property he or she owns. b) How to apply. The applicant shall file the following information with the Department of Community Development Services: 1) 2) A completed Master Land Use Application. A vicinity map showing the subject property with enough information to locate the property within the larger area. 3) A copy of the underlying plat or the King County Assessor's parcel map. 4) The following site data: a) Tax Parcel No. b) Lot Size/Acreage c) Existing Comprehensive Plan Designation d) Existing Zoning e) Requested Comprehensive Plan Designation f) Requested Zoning 5) Services. Please provide the following information regarding the availability of services: a) The site is currently served by sewer /septic (check one). Sewer Provider: b) The site is currently served by a public water system __/well __ Water Provider: c) Fire District#: d) School District#: (check one). EXHIBi /.. Comprehensive Plan Amendment Application Page ! File # 6) 7) 8) A set of stamped envelopes, and a list of the same, labeled with the name and address of all current owners of real property, as shown in the records of the county assessor for the subject property, within 300 feet of each boundary of the subject property, with the return address of the City of Federal Way, Department of Community Development Services, 33530 First Way South, P.O. Box 9718, Federal Way, WA 98063-9718. A copy of the county assessor's map identifying the properties specified in subsection 6 of this section. Any additional information or material that the Director of Community Development Services determines is reasonably necessary for a decision on the matter. 2. OTHER REQUESTS FOR COMPREHENSIVE PLAN AMENDMENTS a) Who may apply. Any person may, personally or through an agent, apply for an amendment to policies of the comprehensive plan. b) How to apply. The applicant shall file a completed Master Land Use application with the Department of Community Development Services. c) ProposedArnendment. A proposed amendment can be either conceptual or specific amendatory language. Please be as specific as possible so that your proposal can be adequately considered. If specific wording changes are proposed, this should be shown in strike ouffunderline format (please attach additional pages if necessary). The City of Federal Way encourages integration of hiqh- density_ housing with retail and other uses~ c~^~"z Section 4.1, pg. IV-4 (Residential Areas). SEE ATTACHED PAGES FOR ADDITIONAL CHANGES. d) Reference. Please reference the Element of the Comprehensive Plan (e.g., Land Use, Transportation, Housing, Capital Facilities) and page number where located. Economic Development Goals and Policies, pp. IV-12 - IV-1 4. PAG Comprehensive Plan Amendment Application Page 2 File # Add New Section to Economic Development Goals (pg. IV-13): EDG4 The City will encouraqe the inteqration of hiqh density sinqle-family and multi-family housinq with compatible retail and other non-residential uses. Add New Section to Economic Development Policies (pg. IV-14): EDP23 The City will actively permit retail and other non- residential commercial uses within existinq hiqh density sinqle-family and multi-family residential zoned areas, subject to minimum conditions imposed under Process III to ensure such inteqrated uses are compatible and public health, safety and wel- fare are protected. PAG OF SUPPORT FOR THE AMENDMENT (Please fill out for all amendments, whether site specific or otherwise) Please explain the need for the amendment (why is it being proposed). Include any data, research, or reasoning that supports the proposed amendment (please attach additional pages if necessary). Although stated as a Comprehensive Plan "vision" state- ment, no specific goals or policies h~v~ be~ adopted to actively ~mp!emen~ anR ~v~ m~h v~sio~. Home occupa- tions have historically been found compatible with other- wise residential usage. T~ere ms no sound reason to find with hiqh density single-family and multi-family housing is not likewise compatible and should thus be encouragea subject to conditions imposed by a Process III approval. FEE There is no fee for the initial application. If after a public hearing, the City Council determines that the request shall be further considered for adoption, site specific requests must be submitted for a preapplication conference with a $310 fee (non-refundable, but credited to the formal application fee). If after the preapplication conference, the applicant decides to pursue the request, the remaining portion of the comprehensive plan amendment fee of $582, plus $58 per acre will be required. In the case ora non-site specific amendment, the fee will be $582. SIGNATURE Signat? September 18, 2000 Date Jean J. Suh Print Name If you have any questions about filling out this application form or the amendment process, please contact the Department of Community Development Services at (253) 661-4000. Please be advised that an application for a comprehensive plan amendment lacking the required information will not be accepted. K:~OLD HANOOUTS~LANNI NG'~PPS~AMNDAPP.WPD REVISEO JULY 3 I, 2000 PAGE__. _OF Comprehensive Plan Amendment Application Page 3 File # CITY OF FEDERAL WAY MEMORANDUM February 28, 2001 To: FROM: VIA: SUBJECT: Dean McColgan, Chair Land Use/Transportation Committee (LUTC) Kathy McClung, Director of Community Deve.lopment Services ~r Margaret H. Clark, AICP, Senior Planner ~¢t6 David M~ger Amendments to Federal Way City Code (FWCC), Chapter Relating to Allowed Maximum Heights and other Miscellaneous Changes A. BACKGROUND Be As part of its regular review of development regulations, Staff has identified the need to amend the text of Federal Way City Code (FWCC), Section 22 to address a number of code items related to definitions of various types of schools, clarification of where various types of schools should be located, maximum allowable height of schools, and parking requirements for churches. When preparing the amendments, staff also found there was a need to modify the Use Zone Charts to ensure consistency in height requirements in the Multifamily Residential Zones. Please refer to attached Staff Report for a discussion of each issue. PROPOSAL The Planning Commission conducted a public hearing on February 21,2001. There were two requests of staff. One was to provide a definition of Gymnasium and the other was to allow Trade Schools in the City Center Frame (CC-F). The request to allow Trade Schools in the CC-F was to ensure that the Gene Juarez Beauty School, which is located in that zone, does not become non- conforming as a result of the code amendment. The intent of the staff code amendment was to allow Vocational schools in zones where office uses were allowed and to allow Trade Schools where more intensive uses were allowed. Therefore, as an alternative to allowing Trade Schools in the CC-F, Staffwould like to recommend including beauty schools in the definition of Vocational School. Therefore the definition of Business or Vocational School would be as follows: Business College or Vocational School shall mean a post-secondary institution that offers instruction in business principles and practices that will enhance one's ability to perform in a business setting, i.e., secretarial, accounting, purchasing, computers programming or usage, or training in fields such as health services, restaurant management, real estate, beautician training or other professional training or continuing education. In response to a definition for Gymnasium, the following is recommended: A gymnasium is a room or building equipped for gymnastics or sports, which must be accessory to a school facility. A gymnasium may also be used as an auditorium to hold concerts and other performing arts. C. RECOMMENDATION The Planning Commission recommends adoption of the proposed FWCC text amendments as presented by staff with the two changes described in B above. Please note that staff has recommended a change to the definition of Vocational School to address Planning Commission's concerns of the Gene Juarez School in lieu of allowing Trade Schools in the CC-F zone. APPROVAL OF COMMITTEE ACTION: L.~)ean McCol~ Jeanne Burbidge Eric Faison 152001 Code Amendments\Schools\Planning Commission\Memo to LUTC.doc/02/28/2001 11:46:18 AM Page 2 STAFF REPORT TO THE PLANNING COMMISSION Allowed Maximum Heights and Other Miscellaneous Changes Federal Way City Code (FWCC), Amendments Planning Commission Meeting of February 21, 2001 I BACKGROUND As part of its regular review of development regulations, Staff has identified the need to amend the text of Federal Way City Code (FWCC), Section 22 to address the following: 1. Modify the definition for Business or Vocational School, Trade School, and School, and clarify in which zones they would be allowed in. 2. Modify the Use Zone Charts to allow for schools in the Office Park Zone. 3. Allow for increased heights for School Gyms and other school-related structures. 4. Modify the Use Zone Charts to ensure consistency in height requirements in the Multifamily Residential Zones. 5. Modify parking requirements for churches to address the wide range of uses associated with churches. The proposed amendments have been prepared in "line-in/line-out" format, with s~ikeeuts (proposed deletions) and underline (proposed additions) indicated. II DISCUSSION OF PROPOSED CODE AMENDMENTS A. Definition for Business or Vocational School, Trade School, and School, and clarification of which zones they would be allowed in. The School District has identified a need to prepare high school students nearing graduation for jobs considered vocational, business-related, or trade in nature. Presently, the definition of School addresses only instruction in the several branches of learning and study required by the Basic Education Code of the State of Washington. Therefore, an amendment is being proposed to widen the definition of school (Exhibit A) to address the needs of the district. When the existing definitions were being reviewed, staff realized that there were inconsistencies in the existing definitions of Business College, Vocational School, and Trade School. Therefore, staff has recommended some amendments to address these inconsistencies (Exhibit A). There were also inconsistencies in which zones various types of schools could be allowed. In order to address this, the Use Zone Charts are being proposed to be changed as follows: Zone School Business School Trade School Vocational School College University SE X RS X RM X PO X BN X BC X X Add X Add X Add CC-C X X Y~-Delete X Add CC-F X X ~-Delete X Add OP X X X X BP X Y~-Delete Staff recommends that Trade Schools no longer be allowed in the City Center Core (CC-C) and City Center Frame (CC-F) zones due to their nature (Exhibit A) but that they are allowed in the Community Business (BC) zone. We also recommend that Vocational Schools be allowed in the BC, CC-C, and CC-F zones, but delete them from the BP zone. Also, that Business Schools be allowed in the BC zone. B. Modify the Use Zone Charts to allow for schools in the Office Park Zone Presently, schools are allowed in all zoning districts except Professional Office (PO), Office Park (OP), and Business Park (BP). Panther Lake Elementary School is presently located in the OP zone as a legal nonconforming use. This makes it difficult for Panther Lake to substantially expand or make substantial improvements without complying with the provisions of FWCC, Article IV, "Nonconformance." Allowing schools in the OP zone is not in conflict with any City goal or policy and would allow the continued existence of Panther Lake as a legally allowed use. C. Allow for increased heights for School Gyms and other school-related structures As part of normal review of the zoning code, staff has realized that existing provisions would not allow construction of a school gym without obtaining a variance to the height provisions of the code. In the majority of the zoning districts, the maximum height for schools is presently 30-35 feet. However, information from representatives of the Federal Way School District shows that gyms need to be taller than 30-35 feet to allow for activities. In addition, other school related structures, if built today to existing City design standards, would need to exceed 30-35 feet. Staff is therefore recommending increased heights for gyms and other school- related structures based on separation standards from adjacent residential zones and increased setbacks for increased heights. Please refer to Exhibit B--Use Zone Charts. Modify the Use Zone Charts to ensure consistency in height requirements in the Multifamily Residential Zones When the Use Zone Charts were being amended to address the recommendations for increased heights for schools, Staff realized that there were existing conflicts in the Multifamily (RM) zone relating to allowed heights of structures in the RM 1.8 zone (Multifamily -- Minimum Lot Area per unit of 1,800 square feet) when adjoining a low density zone. For example, please refer to Section 22-674 of Exhibit B. Under the Height Structure column, the allowable height is 30 feet above average building elevation, but under Special Regulations and Notes, the Planning Commission Staff Report Page 2 Height & Other Miscellaneous Amendments Ee maximum height is 15 feet. Amendments are being proposed to make these requirements consistent in each Use Zone Chart where a conflict was identified. An amendment is also being proposed for the definition of Adjoining for clarification purposes (Exhibit C). Modify parking requirements for churches to address the wide range of uses associated with churches Presently, the Use Zone Charts of the FWcc require that churches provide one parking space for every five people based on the maximum occupancy load in the principle worship area. During review of development applications for churches, Staff has determined that this may not result in an adequate number of parking spaces for a church because it has become more common for churches to have a variety of accessory uses such as day care and schools. Therefore, staff is recommending that required parking spaces be based on a Transportation Management Plan (TMP), which would allow each church to provide adequate parking based on the activities to be conducted on-site. Please refer to Exhibit B. III REASON FOR PLANNING COMMISSION ACTION FWCC Chapter 22, Zoning, Article IX, Process VIReview, establishes a process and criteria for zoning code text amendments. Consistent with Process VI review, the role of the Planning Commission is as follows: · To review and evaluate the zoning code text regarding any proposed amendments; To determine whether the proposed zoning code text amendment meets the criteria provided by FWCC Section 22-528; and, To forward a recommendation to City Council regarding adoption of the proposed zoning code text amendment. IV PROCEDURAL SUMMARY February 3,2001 February 19, 2001 February 21,2001 Determination of Nonsignificance pursuant to State Environmental Policy Act (SEPA) End of SEPA Comment Period Public Hearing in front of Planning Commission DECISIONAL CRITERIA FWCC Section 22-528 provides criteria for zoning text amendments. The following section analyzes the compliance of the proposed zoning text amendment with the criteria provided by FWCC Section 22-528. The City may amend the text of the FWCC only if it finds that: Planning Commission Staff Report Page 3 Height & Other Miscellaneous Amendments The proposed amendment is consistent with the applicable provisions of the comprehensive plan; The proposed FWCC text amendments are consistent with, and substantially implement, the following Comprehensive Plan goals and policies: LUG1 LUP 6 LUG3 LUP15 Improve the appearance and function of the built environment. Conduct regular reviews of development regulations to determine how to improve upon the development review process. Preserve and protect Federal Way's single family neighborhoods. Protect residential areas from impacts of adjacent non-residential uses. The proposed amendment bears a substantial relationship to public health, safety, or welfare; and The proposed FWCC text amendments will result in improved review processes, by providing consistency between requirements and standards, which have a direct relationship to the public health, safety, and welfare. The proposed amendment is in the best interest of the residents of the city. The proposed FWCC text amendment will improve review processes by clarifying and standardizing requirements, resulting in increased efficiency and effectiveness of City resources. VI PLANNING COMMISSION ACTION Consistent with the provisions of FWCC Section 22-539, the Planning Commission may take the following actions regarding the proposed Zoning Code text amendments: 1. Recommend to City Council adoption of the FWCC text amendments as proposed; 2. Modify the proposed FWCC text amendments and recommend to City Council adoption of the FWCC text amendments as modified; 3. Recommend to City Council that the proposed FWCC text amendments not be adopted; or, Forward the proposed FWCC text amendments to City Council without a recommendation. Planning Commission Staff Report Page 4 Height & Other Miscellaneous Amendments VII STAFF RECOMMENDATION The following motion is suggested: Move to recommend to the City Council for adoption of the proposed FWCC text amendments. (If changes occur as a result of Planning Commission deliberations add, "as amended by the Planning Commission.") VIII EXHIBITS Exhibit A- Revised Definitions of Schools Exhibit B - Use Zone Charts Proposed to be Amended Exhibit C - Revised Definition of Adjoining l:~ega-Churches~Planning CommissionXH¢ight & Othe~ Misc Changes Staff Repo..doc/Last printed 02/I 4/2001 O1:54 PM Planning Commission Staff Report Page 5 Height & Other Miscellaneous Amendments FWCC CHAPTER 22, ZONING Sec. 22.1. Definitions School definitions: Business r'..n~..~v..~o~ or Vocational School shall mean a post-secondary institution that offers instruction in business principles and practices that will enhance one's ability to perform in a business setting, i.e., secretarial, accounting, purchasing, computers programming or usage, or training in fields such as health services, restaurant management, real estate, or other professional training or continuing education. College or university shall mean a post-secondary institution for higher learning that grants associate or bachelor degrees and may also have research facilities and/or professional schools that grant master and doctoral degrees. This may also include community colleges that grant associate or bachelor degrees or certificates of completion in business or technical fields. Schools shall mean institutions of learning, excluding those offering post secondary education, offering instruction in the several branches of learning and study required by the Basic Education Code of the State of Washington to be taught in public, private and parochial schools, including those disciplines considered vocational, business-related, or trade in nature. Trade~.., ~ ....... .~.,.~,.~../';"""ti school shall mean a post-secondary institution that trains persons for qualification in specific trades or occupations, i.e., mechanics; construction trades such as carpentry, HVAC, and wiring; electronics repair and service including computers; plumbing; chefs and culinary training; upholstery; bartending; etc. EXHIBIT_ OF_ t l:k2001 Code Amendmenis~Schools~SEPA~School Definitions. DOC/Last printed 2/14/01 1:25 PM H PAG E__L ~, '~ (qo~a) Hills JuNO)ti HZIS SS~IDO~Id A~HIA~I o EXHIBIT t; PAG E_D__O F~ PAG E___~O F .t -7 PAG E_7_.OF~ H EXHIBIT /~ PA~E S'" OF~9 EXHIB ~T_~_______ PAG E__~__ 0 F ~_.2___. EXH~E~T{'? B _ PAGE IOOF~'~ PAGE ~/OF;'~ EXHIB[~T /~ $~I3Vd$ ONDtbWd H~tfkLgfl'd.L$ =lO J~HDIHI-I HDV}IHAOD £01 (qo~o) Si(liS 3ZI$ £0:1 SS~::)01~d A~HIA~d o~-~nb~r~ SNOI,LV'ICID~IH PAG E_Z_~OF_g_2__ E~,,DF~ /~ .. PAGE ~s. OF ,~'~ . PAGE PAGE t__~OF_Z2_ o N 8,-, L ~ · SH3V([S B~I fLLD fI'8,.LS :I0 .LH9I~I PAGE 2,0 ~WJIE:)f'AtLLS (qo~a) a(llS b £N0~5 HZIS £oq ~o == PAGE~OP ,~ '~ d ;2:; ,,~ PAGE. ,t ..~ ,t 7 E×HII~?~ .... /5' PAGE ~ $ OF ,,~'? ~3~Vd$ DND['SYJ ~:H'kL'9iq'~LLS :I0 .I.HOEIH ~l~(l (q3~3) ';JGIS ~tZI$ £01 PAGE :'~ OF,z'~ FWCC CHAPTER 22, ZONING Sec. 22.1. Definitions Adjoining shall mean property that touches or is directly across the street from the subject property. For the purpose of height regulations, any portion of a structure which is mere than 100 feet or more from a low density zone is not considered to be adjoining that zone. PAGE 1:~2001 Codc Amcndmcnts~SchoolsLSEPAkDcfinition of Adjoining. DOC. first pdntcd 2/14101 1:16 PM