21-100731-UP-Correspondence-02-24-2021-V1
12202 Pacific Avenue Suite C
Tacoma, WA 98444
Office: 253-531-4300
Fax: 253-537-6542
To: Stacey Welsh, Planner
City of Federal Way
From: Neitha Wilkey, Architect
Address: Email: neithaw@austincina.com
Date: February 25, 2021
Project: Twin Lakes Veterinary Hospital
Re: Process III Application
Application and Summary Letter Number of Pages: 6
Twin Lakes Summary Letter
Request for Waivers: (information will be submitted for site development and building permit) for:
Landscape: We have shown there is adequate room for landscape and it has been called out on the
plans. It appears the amount of landscaping required for new parking, 6 spaces, is 120 sf. Also, for
the landscape requirement between residential on the new education wing which is over 44' from the
property line. There is a solid wood fence between the residence and the existing clinic.
Site Clearing and Grading Plan: We are requesting the waiver of a site clearing and grading plan. The
area of the proposed addition is virtually flat and has mostly hard surface a small amount of the grass
yard will be removed.
Differences you will see in the plan from the predevelopment drawings.
1. At the north end of the building, there is a vault for power. The storage area was reduced in
size to allow the building to jog so as not to disturb the vault. Changing the depth of the storage
area kept the proposed building footprint as presented in the Pre-Application submittal.
2. The parking proposed in the northern buffer (part of wetland review) has been moved to the
front of the lot along 320th outside the buffer. This shows that there is enough room to
accommodate the loss of the two parking areas to building expansion and that needed for the
training facility.
Introduction Paragraph:
Site:
The Twin Lakes parcel is divided by a wetland. The 150' set back on either side of the wetland divides
the property from east to west. The wetland takes up 52% of the parcel. Parcel 217,793. `Wetland
w/setback is approximately 114,404 SF.
Most of the existing building and the residence are within the southern portion of the 150' setback. The
southern portion abuts 320th Street SW. It is not possible to access the northern portion of the site
without crossing the wetland. The northern portion backs up to the backyards of the residential
neighborhood.
12202 Pacific Avenue Suite C
Tacoma, WA 98444
Office: 253-531-4300
Fax: 253-537-6542
Twin Lakes Veterinary Process III Application Page 2 of 6
Business:
Twin Lakes addition will offer education and training to all age groups of the community for animal
handling, obedience and nutrition. Training and mentorship (shadow programs) are a precursor to
veterinary assistant programs for all young adults and for those on a non-traditional education path.
FWRC 19.05.190 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…including those disciplines considered vocational, business related or trade related. This type of
education would be considered vocation or trade related.
RCW28A.150.200 Program of Basic Education
‘persons under the age of 18’, ‘knowledge and skills necessary to meet the state-established high
school graduation requirements that allow students to have the opportunity to graduate with a
meaningful diploma that prepares them for postsecondary education, gainful employment, and
citizenship,
This training, in conjunction with other Basic Education Requirements achieved via home-schooling,
public schooling or private schooling provides the opportunity to graduate with a meaningful diploma
that prepares them for postsecondary education, gainful employment, and citizenship.
These opportunities are especially important to home school students.
Directly adjacent to the addition is an existing fenced yard for hands-on animal training.
An up-to-date computer area will allow for research of veterinary subscription sites not typically
available to students and the public.
Hours of operation: Veterinary Clinic 7-6pm. Monday through Saturday, 1 or 2 staff 24 hrs for sick
animal care
Education/Training Facility 8-10 pm Monday through Sunday.
Outside yard: Dawn to Dusk Monday through Sunday
Letter 4/6/2020 Item by Item Response:
1. It has been determined that the addition is an approved non- conforming use (letter dated
4/6/2020).
2. Non-conforming Development:
Since this project does not exceed the 25% gross floor area, existing non-conforming elements of the
site do not need to be upgraded. Only those elements of new work will be required to meet the current
codes.
3. SEPA, not required.
4. Use Process III required.
5. Land Use Timelines: Understood
12202 Pacific Avenue Suite C
Tacoma, WA 98444
Office: 253-531-4300
Fax: 253-537-6542
Twin Lakes Veterinary Process III Application Page 3 of 6
6. Public Notice. Acknowledged. Mailing label and envelopes are now handled by the Permit
Center for a small fee. A change which surfaced during Covid-19.
7. Land Use Application Submittal Requirements: Understood.
8. Effect of Use Process Decision: Understood.
9. General Zoning Regulations.
The required yards and setbacks are met for the addition.
Maximum lot coverage is 9%
Existing Building Height: 21'-6"
Addition Height: 14'-1"
Parking:
Existing Clinic: 1/300 = 12
Existing Residence = 2
Voc Education Student = 7
Voc Ed Employee = 1
Spaces Required 22, Spaces Provided 24.
10. Landscape: No changes to the existing landscape are intended. We are requesting a waiver
for providing a new landscape plan at this time due to the small amount. The amounts are shown on
the site plan.
11. Tree Retention/Replacement Requirements
No trees will be removed for this project. A note is placed on the site plan.
12. Clearing and Grading: Requesting a waiver at this time. The areas of work are essentially flat
and clearing is limited to grass and asphalt covered by pavement.
13. Community Design Guidelines - Application also attached.
13a. CPTEC – Crime Prevention FWRC 19.115.010(2). Attached.
13b. Site Design
The addition is at the back of the existing building and there are no alterations to the front of the
building. The existing entrance has a human scaled covered entry way and oversized sidewalk area.
These are set back from the sidewalk approximately 75’. Landscape is pleasant and meets Crime
Prevention standards.
12202 Pacific Avenue Suite C
Tacoma, WA 98444
Office: 253-531-4300
Fax: 253-537-6542
Twin Lakes Veterinary Process III Application Page 4 of 6
Most of the surface parking is existing. This site design adds 6 parking spaces to the east of the
business’ driveway. No changes are proposed to the building entrance area.
13c. Building Design
The addition is to the back of the existing building. The same materials and elements are proposed to
give it a cohesive appearance. The roof is flat with a parapet similar to the rest of the back of the
building. The site is flat. Modulation: No new wall lengths are greater than 60’.
The residential property to the north is 483' away and is shielded by trees growing in the wetland buffer
area.
13d. Institutional Uses
(1) The overall look of the site doesn't change. It is a well maintained property.
(2) The proposed parking works well within the limitations of the site. For the time being Access
Management has requested that the easterly driveway remain closed. Between that and the extend
of the wetlands buffer a looped aisle is not feasible.
(3) There are no facades that exceed 120 feet in length.
(4) Roof design. The new roof is subordinate to the existing pitched roof elements. The addition uses
an architectural parapet that blends materials and modulates height between the existing flat roof and
the pitched roof elements of the front of the building.
14. Lighting: Bollard style lighting will be added along sidewalk from new parking. No extra lighting
is being added.
(5) Alternative Methods: The addition is at the back of the building marginally visible from the main
road. It is 135' from the south property line.
15. Mechanical Equipment: We will be using curb mounted screening. See detail on drawings.
16. Garbage and Recycling Receptacles: between existing and new addition in an alcove.
Verification of sizes with Waste Management indicate there is sufficient space and the access has not
changed.
17. Wetlands - See, Biologist report. The existing wetland boundary covers about 115,500 sf in
the center of this parcel. Which is over half of the parcel right in the middle making the part of the parcel
to the north of the wetland boundary in accessible.
FWRC 19.145.440(4): We are asking that the director allow 446 sf of new hard surface within the
wetland boundary adjacent to the existing building and addition. We propose replacing this amount
along the south eastern edge of the buffer. See Biologist's report.
18. Outside Agency Permits. Understood.
19. Application Fees & Submittal. Understood.
12202 Pacific Avenue Suite C
Tacoma, WA 98444
Office: 253-531-4300
Fax: 253-537-6542
Twin Lakes Veterinary Process III Application Page 5 of 6
Public Woks Traffic Division
1. Understood
2. Concurrency Permit: Attached
3. Understood
Transportation Impact Fees
1. Understood
2. Understood.
3. Understood.
Street Frontage Improvements
1. Value of Improvements
Assessed Value is $908,800, does not include land. Twenty-five percent is $227,200. The proposed
development is for 1,100 s.f. addition to the building. Our estimating guide suggests a build out cost
for offices (1 story) of 194.59 per s.f. for a total of $214,049. This totals $214,049 which is less than
25%. This does not include the value of the land because the parcel is greater than 100,000 sf.
The developable area due to wetlands buffers is 22,305 sf. If the land value for this 22,305 sf was
added the project would be even less 23.5%.
HOWEVER a request for a waiver of improvements has been submitted.
2. Required Street Improvements.
The current layout of 320th does not meet the Type I street. We are making a written request to waive
the improvements at this time as it is not consistent with the properties on either side of 1060 SW
320th Street between 7th Avenue SW and 23 Avenue SW. And on either side of these streets, there
is no landscape strip at all.
3. Applicant has made a written request to defer improvements.
4. Understood.
Access Management
1. No changes to existing access proposed.
2. No changes to existing 39' wide driveway proposed.
3. Easterly driveway access will remain closed, sidewalk will be replaced as needed.
Fire, pre-application comments, 1/29/20 letter.
Fire Flow: Certificate provided, 2,500 available.
Fire Hydrants: Existing fire hydrants meet requirements.
12202 Pacific Avenue Suite C
Tacoma, WA 98444
Office: 253-531-4300
Fax: 253-537-6542
Twin Lakes Veterinary Process III Application Page 6 of 6
Emergency Access: Apparatus Access is sufficient. Vehicle may travel in 124' and reach all sides of
the building in less than 150'.
Fire Department Lock Box: Will be added.
Fire Alarm: The addition will have a fire alarm system.
33325 8th Avenue South Federal Way, WA 98003-6325 253-835-7000 www.cityoffederalway.com Jim Ferrell, Mayor
April 6, 2020
Ms. Neitha Wilkey
AustinCina Architects
12202 Pacific Highway South, Suite C
Tacoma, WA 98444
neithaw@austincina.com
Re: File #19-105945-PC, REVISED PREAPPLICATION CONFERENCE SUMMARY
Twin Lakes Veterinary Hospital/Training Center, 1060 SW 320th Street, Federal Way
Dear Ms. Wilkey:
This letter consists of revised Planning Division and a portion of Public Works Traffic comments, based on
the proposed use of the building addition as a school. All other comments from the previous January 29,
2020, letter remain in effect. For technical questions about your project, please contact the appropriate DRC
representative as listed below. Otherwise, any general questions can be referred to me.
PROJECT DESCRIPTION
The proposal is to add 1,100 square feet to an existing building for use as an educational training facility. The
project is proposed at 1060 SW 320th Street, on King County tax parcel 072104-9202.
MAJOR ISSUES
Outlined below is a summary of the major issues of your project based on the plans and information
submitted for preapplication review. These issues can change due to modifications and revisions in the plans. The major issues section is only provided as a means to highlight critical requirements or issues. Please be
sure to read the comments made by all departments in the following section of this letter. Planning Division (revised section)
• The project requires a Process III land use application.
• A wetland report and buffer determination are required.
DEPARTMENT COMMENTS
Outlined below are the comments made by the representatives of each department. Each section should be
read thoroughly. If you have questions, please contact the representative listed for that section.
Ms. Neitha Wilkey
Page 2 of 8 April 6, 2020
19-105945-PC Doc ID 80327
COMMUNITY DEVELOPMENT – PLANNING DIVISION (ENTIRE SECTION REVISED)
Stacey Welsh, 253-835-2634, stacey.welsh@cityoffederalway.com
1. Zoning Designation and Use – The subject property is designated Single Family Residential (RS 7.2). The
current use on the site as a veterinary hospital is not permitted, and is considered a nonconforming use. FWRC 19.30.080(1) and 19.30.180 prohibit expansions of nonconforming uses. The proposed additional
use is an educational training facility (school), which is a permitted use in the RS 7.2 zone as listed within
and subject to the regulations set forth in the Use Zone Chart of FWRC 19.200.090. Per FWRC 19.05.190:
“Schools” means 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.
The proposed new use is not considered an expansion of a nonconforming use because it is a
conforming use being added to the site.
2. Nonconforming Development – Per FWRC 19.30.090(1), all nonconforming aspects of a development must be brought into conformance if an applicant proposes to add to the subject property either 2,500 square feet
of new gross floor area or more, or 25 percent of the gross floor area or more of the building(s) on the
subject property, whichever is less, within any consecutive 36-month time period commencing at the time of building permit issuance.
According to the King County Assessor, there are two building on site, the vet clinic which is 3,576 square feet in size and the residence which is 960 square feet in size. The calculation of 25% of the gross
floor area of the buildings on the subject property is (3576+960=4536*.25=1,134 square feet). The proposed building addition is 1,100 square feet, which is less than 25% of the gross floor area of the
buildings on the subject property; therefore, as currently proposed, this requirement is not triggered.
3. State Environmental Policy Act (SEPA) – Pursuant to FWRC 14.15.030(1) and WAC 197-11-800(1), the
project is not subject to environmental review under the State Environmental Policy Act (SEPA).
4. Land Use Application – Per FWRC 19.15.030(4), where an improvement/addition that houses a new and
different use is added to an existing developed site, the new improvement/addition shall be processed under the use process indicated by the applicable use zone chart. Per the use zone chart, FWRC 19.200.090 (Schools), Use Process III is required for the project. Process III is a review process
conducted by city staff with a final decision issued by the Community Development Director. The Process III decision criteria are contained in FWRC 19.65.100(2).
5. Land Use Review Timeframes – The Planning Division will notify the applicant of the application status within 28 days of submittal. If the application is determined complete, staff will issue a Letter of
Complete Application. The FWRC limits the administrative review to 120 days from the date of a complete application. The 120-day review period will stop any time the applicant has been requested by
the city to correct plans, perform required studies, or provide additional information needed to issue a
decision. The review period will begin within 14 days following submittal of requested items. Please be advised that any request for corrections and/or additional information must be provided within 180 days
of written notification, or the land use application will expire.
Ms. Neitha Wilkey
Page 3 of 8 April 6, 2020
19-105945-PC Doc ID 80327
6. Public Notice – Process III applications require a public notice and comment period. Within 14 days of
issuing the Letter of Complete Application, a Notice of Application will be published in the Federal Way Mirror, posted on the subject property, placed at the city’s three designated notice boards, and mailed to property owners within 300 feet of the subject property.
7. Land Use Application Submittal Requirements – Please refer to the enclosed Bulletin #001, “Submittal Requirements for Use Process III or IV,” to determine what materials must be submitted with the land
use application.
8. Effect of Use Process Decision – In accordance with FWRC 19.15.100(2), “Lapse of Approval - Generally,”
the applicant must substantially complete construction for the development activity, use of land, or other actions approved; and complete the applicable conditions listed in the Use Process decision within five
years after the final decision of the city on the matter, or the decision becomes void. Provisions for extension of time are contained within FWRC 19.15.110, “Lapse of Approval – Time Extension.”
9. General Zoning Regulations – The use zone chart of FWRC 19.200.090 (enclosed) provides regulations for
the proposed use. The applicant should consult the referenced use zone chart prior to submitting a Master Land Use Application to verify all site components and proposed uses will comply with city code.
The following is only a portion of the zoning regulations governing the proposed use in the RS zone:
Schools (FWRC 19.200.090)
Required Yards, Lot Coverage, Building Height, Parking – Required yards, lot coverage, building height,
and parking are:
i. Front/side/rear setback – 20'/20'/20'
ii. Maximum lot coverage – 75%
iii. Maximum building height – 30 feet above average building elevation (AABE)
iv. Parking – The use zone chart only identifies parking requirements for elementary, middle, and
high schools. The use zone chart for schools in the Community Business (BC) zone (FWRC 19.220.040) includes an appropriate parking requirement that can be applied here, namely,
business/vocational/trade school: one space for each employee and a 0.5 space for each student.
v. See Special Regulations and Notes #4, #7, and #12:
a. #4. Hours of operation and maximum number of attendees may be limited by the city to
reduce impacts on nearby residential uses.
b. #7. All activities pertaining to schools, such as auto-repair or other uses that may impact adjacent properties, must take place within an enclosed building.
c. #12. This use must comply with the requirements of the State Department of Social and Health Services, and/or the State Superintendent of Public Instruction.
i. The applicant must provide documentation addressing this requirement with the land use
application submittal.
10. Landscaping – Landscape requirements are contained in FWRC Chapter 19.125 “Outdoors, Yards, and
Landscaping.” Following are the key landscape requirements for the project.
(a) A landscape plan prepared by a Washington State licensed landscape architect shall be submitted
with the formal application. Please follow general guidelines outlined in FWRC 19.125.040(1) through
(28) when preparing the site plan and planting schedule.
Ms. Neitha Wilkey
Page 4 of 8 April 6, 2020
19-105945-PC Doc ID 80327
(b) Per FWRC 19.125.060(2), for properties within the RS zone:
i. Type III landscaping 10 feet in width shall be provided along all property lines of nonresidential uses.
(c) Parking Lot Landscaping – Twenty square feet of interior lot landscaping per parking stall is required
per FWRC 19.125.070(2)(a)(i)(A). Additional parking lot landscaping requirements are contained within FWRC 19.125.070.
11. Tree Retention/Replacement Requirements – A tree and vegetation retention plan as required under FWRC 19.120.040(2) must be submitted with the Process III application. The tree and vegetation retention/
replacement plan must be prepared by a certified arborist or certified landscape architect. The standards require each development to maintain a minimum tree unit density. Per FWRC 19.120.130(3), the total number of tree units required to be provided by a regulated activity shall be calculated by multiplying gross
site acreage, minus any proposed public or private streets and regulated critical areas (excluding buffers) determined by Federal Way to be undesirable for tree planting (e.g., certain wildlife habitat and wetlands),
by the required tree density (in tree units per acre) set forth in Table 19.120.130(1). The result of the
calculation will be the total number of tree units required for the activity. If the calculation results in a fractional quantity, it shall be rounded up to the next higher whole number. As required under FWRC
19.120.130(2), the minimum tree density in SF zones is 25 tree units per acre. A tree unit is a value assigned to existing trees retained on the property, or replacement trees. The larger the tree, the greater value it is assigned. The formal landscape plan must detail information about tree unit credits and replacement.
• If the applicant does not plan on removing any trees, then that can be documented with a
note placed on the site plan and landscaping plan, along with a note regarding the site’s compliance with the 25 tree units/acre requirement.
12. Clearing & Grading – The applicant is required to obtain a clearing and grading plan approval as a component of the Process III approval. Consult FWRC 19.120.040(1) for items that are required to be included on the plan, including the anticipated amounts of cut and fill. Clearing and grading plans are
reviewed and approved in conjunction with the land development permit associated with the proposed development. Approval and notice to proceed shall be required prior to commencing clearing and
grading activities on the site. Reference FWRC 19.120.060(2).
13. Community Design Guidelines – Review of the proposal under the city’s design guidelines, Chapter 19.115
FWRC, is required for the project and will occur in conjunction with the use process review. The principal applicable guidelines for the project are noted below. However, this does not necessarily include all applicable guidelines, and project designers must consult the guidelines in their entirety in preparing an
application. The application must include a written narrative identifying how the proposal complies with the applicable design guidelines as detailed.
(a) FWRC 19.115.010(2), CPTED – Implement Crime Prevention through Environmental Design
(CPTED) principles to reduce opportunities for criminal activities to occur. The city’s Police Department and Planning Division will evaluate the formal application and review for compliance with CPTED principles. A completed CPTED checklist must be submitted with your application.
i. Natural Surveillance – Promote visibility of public spaces and areas.
ii. Access Control – Identify techniques that deter unauthorized access and/or inappropriate
access.
iii. Ownership – Reduce perception of areas as ownerless.
Ms. Neitha Wilkey
Page 5 of 8 April 6, 2020
19-105945-PC Doc ID 80327
(b) FWRC 19.115.050, Site Design – Refer to all sections of this chapter for design standards. Key sections include:
i. (1) General criteria (d)-(g)
ii. (2) Surface parking lots (a)-(c)
iii. (4) Pedestrian circulation and public spaces (e)-(f)
iv. (5) Landscaping
v. (6) Commercial service (a)-(b)
vi. (7) Miscellaneous site elements (a)
(c) FWRC 19.115.060, Building Design – Refer to all sections of this chapter for design standards. Note that the requirements of this section apply to all sides of the buildings. Key sections include:
i. (2) Façade modulation (a)-(d); the eastern building façade is both longer than 60 feet and visible
from a right-of-way or residential use and/or zone, and therefore, must incorporate a minimum of two out of four design options intended to break up the mass of large buildings. Options
include façade modulation, landscape screening, canopy or arcade, and pedestrian plaza.
ii. (3) Building articulation and scale (b)
iii. (4) Methods to reduce building massing (a)-(b); residential zone is located on property to the north.
(d) FWRC 19.115.100, Institutional uses, see (1)-(7)
14. Lighting – FWRC 19.105.030 contains lighting regulations. The applicant shall select, place, and direct
light sources both directable and nondirectable so that glare produced by any light source, to the maximum extent possible, does not extend to adjacent properties or to the right-of-way. A lighting plan
will be required with the land use submittal for the portion of the site where work is proposed.
15. Mechanical Equipment – FWRC 19.110.070 requires vents, mechanical, and elevator equipment, and similar
appurtenances that extend above the roofline, to be architecturally screened from public view, with a
corresponding elevation detail provided with the formal application.
FWRC 19.115.050(6)(b) states that site utilities, including transformers, fire standpipes, and engineered
retention ponds (except biofiltration swales) should not be the dominant element of the front landscape
area. When these must be located in a front yard, they shall be either undergrounded or screened by walls
and/or Type I landscaping, and shall not obstruct views of tenant common spaces, public open spaces,
monument signs, and/or driveways.
16. Garbage and Recycling Receptacles – FWRC 19.125.150 requires that storage areas for garbage and recycling receptacles be required for each project. The formal application must note the specific size and location
of each facility. Locations for the recycling and garbage facilities must be depicted on the formal site plan. Include the square footage of each facility provided, and depict routes of travel for staff and service
providers, including vertical clearance and turning radius of each.
17. Wetlands – There is a wetland on the property, located to the north of the previously developed area. The
building addition is planned on the north side of the existing building in an area of lawn located closer
towards the wetland than the existing building is now. As a result, the wetland boundary, rating, and buffer need to be determined to ascertain if the building in the proposed location can be permitted. The
critical areas report review will determine the areas on-site that are subject to regulations addressing
development within wetland buffers (see FWRC 19.145.410-440).
Ms. Neitha Wilkey
Page 6 of 8 April 6, 2020
19-105945-PC Doc ID 80327
The applicant is responsible for obtaining a critical areas report prepared by a qualified professional that
delineates and rates the wetland and submitting for city review. The report may be peer reviewed at the
applicant’s cost per FWRC 19.145.080(3). As the property is already developed, the following code
sections were reviewed; however, they are of limited utility as they address existing development
consisting of previously approved areas that are paved, and the building addition is proposed in an area
of existing lawn.
• FWRC 19.145.110(5), Critical Areas Exemption. Development within the footprint of existing paved
surfaces that were previously approved.
• FWRC 19.145.440(4), Permanently Altered Buffer. The director may provide written approval for a buffer reduction when existing conditions are such that portions of the required buffer exist in a permanently
altered state (e.g., roadways, paved parking lots, and permanent structures) and do not provide any buffer function. The buffer may be reduced up to the area where the altered conditions exist.
18. Outside Agency Permits – It is the applicant’s responsibility to identify and obtain all required state, federal, or other agency permits as may be required.
19. Application Fees & Submittal – Please contact the Permit Center at permitcenter@cityoffederalway.com, or 253-835-2607, for updated fee schedule information for applications and permits.
PUBLIC WORKS TRAFFIC DIVISION (SECTION PARTIALLY REVISED, SEE UNDERLINED TEXT)
Sarady Long, 253-835-2743, sarady.long@cityoffederalway.com
Transportation Concurrency Analysis (FWRC 19.90)
1. Based on the submitted materials for an 1,100 square feet addition to the existing veterinary clinic
building using the Institute of Transportation Engineers (ITE) Trip Generation - 10th Edition, land use
code 640 (Animal Hospital), the proposed project is estimated to generate approximately five new weekday PM peak hour trips.
2. A concurrency permit is required for this development project. The PW Traffic Division will perform a concurrency analysis to determine if adequate roadway capacity exists during the weekday PM peak
period to accommodate the proposed development. Please note that supplemental transportation analysis and concurrency mitigation may be required if the proposed project creates an impact not anticipated in the six-year Transportation Improvement Plan (TIP).
3. The estimated fee for the concurrency permit application is $1,773 (1 – 10 trips). This fee is an estimate and based on the materials submitted for the preapplication meeting. The concurrency application fee must be
paid in full at the time the concurrency permit application is submitted with the land use application. The fee may change based on any changes in the estimated weekday PM peak hour trips as identified in the
concurrency application. The applicant has the option of having an independent traffic engineer prepare
the concurrency analysis consistent with city procedures; however, the fee remains the same.
Ms. Neitha Wilkey
Page 7 of 8 April 6, 2020
19-105945-PC Doc ID 80327
Transportation Impact Fees (TIF) (FWRC 19.91)
1. Based on the submitted materials for 1,100 square feet of animal hospital, the estimated traffic impact fee is $18,660. Please note, the actual impact fee will be calculated based on the fee schedule in effect at the time
a completed building permit application is filed and paid prior to permit issuance (FWRC 19.100.070 3[a]).
2. The applicant may prepare and submit to the director an independent fee calculation for the development
activity. The documentation submitted shall be prepared by a licensed traffic engineer and shall show the basis upon which the independent fee calculation was made using procedures consistent with those
established in the Trip Generation Handbook, current edition, by the institute of Transportation Engineers.
3. The applicant submitting an independent fee calculation requires payment to the City of Federal Way a
fee to cover the cost of reviewing the independent fee calculation. The fee required by the city for
conducting the review of the independent fee calculation shall be charged on an hourly rate as adopted by the City Council at the time of the submittal.
Street Frontage Improvements (FWRC 19.135)
1. Based on the available records and the submitted materials, it appears that this proposal meets the 25
percent threshold criteria for requiring street frontage improvements as identified in the FWRC 19.135.030. The applicant/owner may submit an appraisal for the subject property, or King County
Assessor’s records may be used. The Public Works Development Services Division will evaluate the submitted appraisal data to determine if the project actually meets the city’s 25 percent threshold for requiring street frontage improvements.
2. The applicant/owner will be expected to construct street improvements consistent with the planned roadway cross-sections as shown in Map III-4 in Chapter III of the Federal Way Comprehensive Plan (FWCP)
and Capital Improvement Program (CIP) shown as Table III-10 (FWRC 19.135.040). Based on the materials submitted, staff conducted a limited analysis to determine the required street improvements. The
applicant would be expected to construct improvements on the following streets to the city’s planned
roadway cross-sections:
South 320th Street is a Principal Arterial planned as a Type “I” street, consisting of a 58-foot street with curb and gutter, 6-foot planter strips with street trees, 8-foot sidewalks, and street
lights in a 92-foot right-of-way. South 320th Street is improved with five lanes, including vertical curb gutter, sidewalks, streetlights, etc., on both sides of the street. However, these improvements may not meet current standards. As such, the applicant shall upgrade the
street frontage on South 320th Street to meet current standards.
3. The applicant may make a written request to the Public Works Director to modify, defer, or waive the
required street improvements (FWRC 19.135.070). These modification requests currently have a review fee of $344.
4. Tapers and transitions beyond the project frontage may be required as deemed necessary for safety purposes. The taper rate shall be WS2/60, or as directed by the Public Works Director.
Ms. Neitha Wilkey
Page 8 of 8 April 6, 2020
19-105945-PC Doc ID 80327
Access Management (FWRC 19.135)
1. Access management standards are based on roadway safety and capacity requirements. FWRC 19.135.280 provides access standards for streets based on planned roadway cross-sections. Please note that access
classifications are per Drawing 3-1A in the Public Works Development Standards.
2. For driveways that serve uses other than single-family residential uses and zero lot line townhouse developments, the maximum driveway width is 30 feet for a two-lane two-way driveway and 40 feet for a
three-lane two-way driveway (FWRC 19.135.270). Driveway widths may be increased in order to provide adequate width for vehicles that may be reasonably expected to use the driveway, as determined by the
Public Works Director.
3. The existing easterly driveway shall remain closed and must be improved to provide a continuous sidewalk.
CLOSING
All other comments from the previous January 29, 2020, letter remain in effect. The completion of the
preapplication process in the content of this letter does not vest any future project application. Comments in
this letter are only valid for one year as per FWRC 19.40.070(4). As you know, this is a preliminary review
only and does not take the place of the full review that will follow submission of a formal application.
Comments provided in this letter are based on preapplication materials submitted.
Modifications and revisions to the project as presented for this preapplication may influence and modify
information regarding development requirements outlined above. In addition to this preapplication letter,
please examine the complete FWRC and other relevant codes carefully. Requirements that are found in the
codes that are not addressed in this letter are still required for your project.
If you have questions about an individual comment, please contact the appropriate department representative
noted above. Any general questions can be directed towards me (the key project contact) at 253-835-2634, or
stacey.welsh@cityofederalway.com.
Sincerely,
Stacey Welsh, AICP
Principal Planner
(REVISED)
enc: Bulletin 001 “Process III or IV Submittal Requirements” c: Scott Sproul, Building Official
Bulletin 003 “Master Land Use Application” Kevin Peterson, Senior Engineering Plans Reviewer
Bulletin 002 “Mailing Labels” Sarady Long, Senior Transportation Planning Engineer
Bulletin 021 “CPTED Checklist Instructions” Brian Asbury, Lakehaven Water & Sewer District
Bulletin 022 “CPTED Checklist” Sean Nichols, South King Fire & Rescue
FWRC 19.200.090 Michael Mizimoto, mp.mizumoto@comcast.net
COMMUNITY DEVELOPMENT DEPARTMENT 33325 8th Avenue South Federal Way, WA 98003-6325 253-835-7000 www.cityoffederalway.com
Jim Ferrell, Mayor
Ms. Neitha Wilkey November 18, 2020 AustinCina Architects
12202 Pacific Highway South, Suite C
Tacoma, WA 98444 neithaw@austincina.com
Re: File #20-104038-PC, REVIEW OF CRITICAL AREAS REPORT Twin Lakes Veterinary Hospital/Training Center, 1060 SW 320th Street, Federal Way
Dear Ms. Wilkey:
On October 19, 2020, the City of Federal Way received your request for review of the October 12, 2020, Critical
Areas Study for Twin Lakes Veterinary Hospital, prepared by Altmann Oliver Associates, LLC. The city has reviewed the report, which details the presence of Wetland A, a Category III wetland with a 150-foot buffer. The wetland buffer extends southward into the developed portion of the property.
The report concludes that:
“The proposed project cannot be accomplished using standard buffer reduction or buffer averaging provisions. It appears the only way the project could be accomplished is by using the
existing development within wetland buffer provision of FWRC 19.145.440(4), which states that ‘The director may provide written approval for a buffer reduction when existing conditions are such that portions of the required buffer exist in a permanently altered state (e.g., roadways, paved parking lots, and permanent structures)
and do not provide any buffer function. The buffer may be reduced up to the area where the altered conditions exist.’”
The following information was provided on page 6 of the April 6, 2020, revised preapplication summary
letter from the city to the applicant:
“As the property is already developed, the following code sections were reviewed; however, they
are of limited utility as they address existing development consisting of previously approved areas that are paved, and the building addition is proposed in an area of existing lawn.
• FWRC 19.145.110(5), Critical Areas Exemption. Development within the footprint of existing paved surfaces that were previously approved.
• FWRC 19.145.440(4), Permanently Altered Buffer. The director may provide written
approval for a buffer reduction when existing conditions are such that portions of the required buffer exist in a permanently altered state (e.g., roadways, paved parking lots, and permanent structures) and do not provide any buffer function. The buffer may be reduced
up to the area where the altered conditions exist.”
The October 2020 wetland report also states that:
“The proposed project consists of a small addition to the existing veterinary hospital. As part of the project, 1,036 s.f. of new structure would be created within the buffer and 864 s.f. of additional
parking would be created. All the impacted buffer areas currently consist of existing asphalt,
Ms. Neitha Wilkey
Page 2 of 2
November 18, 2020
20-104038-00-AD Doc. I.D. 80951
concrete pavers, or lawn adjacent existing parking areas and no native vegetation would be
removed as part of the project. None of the impacted buffer areas currently provide any significant functional benefit to the wetland and no direct wetland impacts are proposed.”
Per Federal Way Revised Code (FWRC) 19.145.440(4), the benchmark is not whether a buffer area provides a significant functional benefit. FWRC 19.145.440(4) allows for a permanently altered buffer when existing
conditions are such that portions of the required buffer exist in a permanently altered state (e.g., roadways, paved parking lots, and permanent structures) and do not provide any buffer function.
Portions of the buffer area would qualify for a permanently altered buffer per the standards in the code. A lawn may not provide a significant functional benefit as a buffer, but it does provide some benefit and can be altered to provide more buffer function since it is not in a permanently altered state, such as a paved surface
or occupied by a permanent structure.
Figure 2 of the October 2020 wetland report also shows a proposed parking area, which was not included with the preapplication submittal. This proposed parking is shown north of the building addition, beyond the fenced lawn area and even further into the wetland buffer.
As a result, revisions to the proposal are necessary to proceed further. Different options include:
• Be within the footprint of existing paved surfaces that were previously approved (FWRC 19.145.110[5], Critical Areas Exemption).
• Explore other configurations or buildable locations for the addition, or consider a stand-alone
building entirely outside of the standard or permanently altered buffer (this would not include the lawn area).
A street modification request has not been submitted. The preapplication summary letters from earlier this year included requirements from other city departments and outside agencies. Has your client determined if
the requirements from Public Works, Building, South King Fire & Rescue, and Lakehaven Water & Sewer
District are workable?
The Department of Community Development is implementing safety protocols and modifying our services. As a result, our doors will remain closed for in-person business. Staff will be able to serve customers electronically by email (permitcenter@cityoffederalway.com), by phone (253-835-2607), or by electronic submittal (Document Upload
Link or https://www.cityoffederalway.com/node/4588). This practice is intended to help protect our citizens, customers, and staff from potential exposure to the virus. We thank you for your understanding in this matter.
Should you have any questions about this letter, please contact me at stacey.welsh@cityoffederalway.com, or 253-835-2634.
Sincerely,
Stacey Welsh, AICP Planning Manager
c: Michael Mizimoto, mp.mizumoto@comcast.net