Public Comment Response Letter-04-03-2020-V1
April 1, 2020 Job No. 1352-023-019
Ms. Becky Chapin
Senior Planner
City of Federal Way
33325 8th Avenue S
Federal Way, WA 98003
RE: #19 -105072-SU, 19-105073 -SE, & 19-105074-UP
The Woodlands at Redondo Creek Preliminary Plat
Public Comments Responses
Dear Ms. Chapin:
On behalf of RMJ Holdings, LLC, ESM Consulting Engineers, LLC is providing this letter as a
formal response to the public comments we received from the City of Federal Way on February
19, 2020.
The City of Federal Way received 3 public comments regarding this project. Below is a
summary of each topic of concern from the public comments with our response. A matrix of
respondents and their topic of concern (identified based on numbers correlated with topic from
below) is provided at the end of this letter.
1. TRAFFIC, ROAD SAFETY AND SIGHT DISTANCE
Public commenters expressed concern regarding additional traffic from the proposed
development overloading S 304th Street and the surrounding neighborhood. A Traffic Impact
Analysis was prepared for this project by Traffex, dated September 28, 2019. Further, the City
ran a transportation concurrency test for the proposed project. A proposal of 68 single-family
residential lots “passed” the concurrency test, resulting in a Capacity Reserve Certificate for
the project site under file #19-104256-CN. FWRC 19.90.130 provides standards for
transportation concurrency to ensure traffic generated by the project plus existing city road
facilities meet the City’s transportation Level of Service (LOS), including applicable
intersections impacted by the development.
In addition to the proposed roads internal of the project meeting the City’s road standards, half-
street improvements will be made to 20th Avenue S and S 304th Street at the frontage of the
subject property, including a future turn lane on 304th Street. These improvements also provide
adequate sight distance from all impacted intersections, with substantial improvement to sight
distance of the 20th Avenue and 304th Street intersection. Traffic calming devices will be
provided on the roadways internal to the development to minimize opportunities for vehicles to
speed through the new road connection. Finally, this project is subject to pay Traffic Impact
Fees to the City of Federal Way at time of building permit issuance to help finance the City’s
transportation infrastructure. Refer to sheet PP-06 and PP-07 of the Preliminary Plat plan set
for more details.
Ms. Becky Chapin
April 1, 2020
Page 2
2. PEDESTRIAN ACCESS
Neighbors to the project have concern about safe pedestrian access for residents within and
surrounding the development due to a lack of sidewalks. Aligning with the City’s road
standards, this project proposes to provide sidewalks on all roads to be developed within the
project. The internal sidewalks will connect to the existing 20th Avenue S that connects to
304th, where an 8’ wide sidewalk will be provided along the S 304th Street frontage to the
subject property. Additionally, an extruded curb will be provided along the shoulder of 304th to
the existing commercial business driveway near the corner of Pacific Highway S. Refer to
sheets PP-06 and PP-07 of the Preliminary Plat plan set for more details.
3. SCHOOL CAPACITY
Prior to submitting the preliminary plat application to the City, we have been in contact with the
Federal Way School District regarding this project proposal. The District’s contacts have not
expressed concerns regarding student capacity as a result of this development. The applicant
is subject to pay School Impact Fees to school district at time of building permit issuance to
support growth within the school district.
4. WATER AND SEWER
Commenters expressed their concern regarding the lack of water pressure in the
neighborhood, with an assumption that the proposed development impacts the surrounding
water pressure. We contacted Lakehaven Utilities regarding this concern – Brian Asbury,
development engineering supervisor, stated, “Lakehaven is currently studying ‘hilltop’ areas
within our service area, to determine what (if any) improvements may be needed to existing
water systems. In these ‘hilltop’ areas, available service pressure at meters is typically around
40 psi, which is Lakehaven’s stated low-pressure figure (i.e., a goal). However, virtually all
properties in these ‘hilltop’ areas have available service pressure above what is required by
statute (e.g., 30 psi at static conditions, etc.). The study will take a couple of years before
completed, and at that time we’ll identify any needed capital improvement projects.
The development of the subject plat won’t impact system pressures at all…pressure is pressure
and is determined almost exclusively by elevation in relation to the level of water in the
supplying tank.
In response to a couple of the comments you included:
• Concurrent shower & laundry use having a noticeable impact is typically more
associated with a supply meter/line size issue, and not a pressure issue. The size
issue could simply be too small diameter of pipe or older pipe where pipe diameter has
decreased over the years due to scale build-up (this condition will also scrub off some
pressure psi).
• Source (well) water is pumped up to tanks. However, properties are served by gravity
head down from the tanks. There is no direct connection (in this area) of
properties/buildings to ‘pumped’ source water.”
A commenter also had concern for an alleged sewer treatment capacity. To this, Brian with
Lakehaven explained, “Lakehaven does not have any sewer system facility (pipe, pump
station, treatment plant, etc.) that is at or over capacity, nor do any current system capacity
levels trigger any statutory system studies &/or upgrades. Lakehaven is constantly reviewing
& upgrading the water & sewer systems as necessary under our Capital Improvement Program
projects, to meet the current & future system demands.”
Ms. Becky Chapin
April 1, 2020
Page 3
The applicant is subject to pay applicable Developer Extension and Latecomer fees associated
with extending and connecting to the Lakehaven infrastructure, in addition to any construction
and permit costs.
5. HOMELESS ENCAMPMENT
The applicant is currently working with the City staff to develop a plan that will minimize or
eliminate homeless trespassing on the subject property. This issue has been historically
ongoing throughout the City and on this project site, far before the applicant took ownership of
the site. The applicant is interested in taking appropriate measures that will help create a safer
and cleaner environment for new and existing residents surrounding the property.
The critical areas and buffers onsite will have enhanced protection from trespassers with the
installation of split rail fencing and Native Growth Protection signs around their respective
perimeters. Further, currently degraded areas on site due to the homeless encampments will
be cleared of debris and planted with native vegetation as part of the buffer enhancement and
restoration efforts of this project.
6. TREE RETENTION – NOISE AND HABITAT
A neighbor commented their concerns of additional noise to the surrounding environment and
a reduction of natural habitat due to tree removal from this project. This project proposes to
follow the City’s tree retention requirements found in FWRC 19.120.130. Trees within the
wetland, stream and their buffers will not be removed to preserve natural habitat. Tree removal
will occur within the developing area of the site, approximately 72% of the subject property.
Tree replacement will be dispersed throughout designated public purpose tracts, and
mitigation plantings will occur within the wetland buffer. Further, by providing approximately
28.7 tree units per acre, this project proposes to exceed the City’s trees retention requirements.
The subject property was evaluated by two professional ecologists – the project’s consultant
and the City’s consultant. No endangered species or their habitats were observed onsite. The
stream is a non-fish bearing stream due to a natural fish barrier. Their inventory research did
not result in any indication of endangered species on the site. The Washington State
Department of Fish and Wildlife Priority Habitat Map shows the wetland on site as a priority
habitat, as with every identified wetland in the state.
Refer to the Tree Conservation Plan, the Landscape Plan sheets included with the Preliminary
Plat plan set and the Critical Area Report and Mitigation Plans for more details.
7. NATURAL ENVIRONMENT – WETLAND, STREAM AND STEEL LAKE
Impacts to the natural environment on and around the subject property are appropriately
addressed and mitigated for by following the City of Federal Way standards found in FWRC
19.145. The applicant’s ecology consultant and the City’s third-party ecology consultant have
reviewed the site conditions and state inventory data, and applied state and local requirements
to analysis and conclusions for both existing conditions and proposed measures. Please refer
to the project’s Critical Areas Report and Mitigation Plan prepared by Sewall Wetland
Consulting.
Public Record Respondent / Commenter Parcel Number Date Concerns
Anne Etter 798280-0090 12/05/2019 1, 7
Laurie Ault-Sayan 798300-0120 01/02/2020 1, 2, 3, 4, 5, 6, 7
Ricardo Kelly 367440-0186 01/06/2020 2, 4
Ms. Becky Chapin
April 1, 2020
Page 4
If there are any questions or a need for further clarification, please feel free to contact me at
(253) 838-6113 and I would be happy to discuss them with you.
Sincerely,
ESM CONSULTING ENGINEERS, L.L.C.
SAVANNA NAGORSKI, MS
Planner/GIS Analyst
Enc: As noted
cc: Dmitriy Mayzlin (w/Enc)
Justin Lagers