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Pre-App Summary Letter 121019kCITY OF Federal Way Centered on Opportunity Mr. Steve Joo S J Architects 4021 262^d Place SE Issaquah, WA 98029 Re: File #19-105202-00-PC, PREAPPLICATION CONFERENCE SUMMARY Hwang Short Plat, 32604 45th Court SW, Federal Way, Parcel #873218-0230 Dear Mr. Joo: CITY HALL 33325 8th Avenue South Federal Way, WA 98003-6325 (253) 835-7000 www.cityoffederalway.com Jim Ferrell, Mayor December 10, 2019 Thank you for participating in the preapplication conference with the City of Federal Way's Development Review Committee (DRC) held December 5, 2019. We hope that the information discussed at that meeting was helpful in understanding the general requirements for your project as submitted. This letter summarizes comments given to you at the meeting by the members of the DRC. The members who reviewed your project and provided comments include staff from the city's Planning and Building Divisions, Public Works Department, and representatives from Lakehaven Water and Sewer District and South King Fire and Rescue. Some sections of the Federal Way Revised Code (FWRC) and relevant information handouts are enclosed with this letter. Please be advised, this letter does not represent all applicable codes. In preparing your formal application, please refer to the complete FWRC and other relevant codes for all additional requirements that may apply to your project. I, Leila Willoughby -Oakes, am the key contact for your project. I may be contacted at 253-835-2644, or �_: U h - nk ci �ofFederal�va .c gym. For specific technical questions about your project, please contact the appropriate DRC representative as listed below. Otherwise, any general questions about the preapplication and permitting process can be referred to me. PROJECT DESCRIPTION Applicant proposes to subdivide one parcel into two. Site composed of 1.79 acres and contains a stream, wetland, and associated critical area buffers. MAJOR ISSUES Outlined below is a summary of the major issues of your project based on the plans and information submitted for the 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 sections of this letter. i Planning Division C The site contains several environmentally critical areas; see comments below for required reports and review processes. The applicant is strongly encouraged to review all of FWRC Chapter 19.145 (Environmentally Critical Areas) in detail with regard to all provisions that could apply to the various aspects of the project. Mr. Steve Joo Page 2of10 December 10, 2019 • The city requires a third -party critical areas review to determine the extent of the wetland/wetland buffers and stream/stream buffers on proposed Lot 1 to the north. i Critical areas and critical area buffers must be set -aside in a separate tract and shall not be counted towards minimum lot areas. • All residential subdivisions are required to provide open space in the amount of 15 percent of the gross land area of the subdivision site per FWRC 18.55.060(2). All or some of the open space requirement may be satisfied by a fee -in -lieu payment at the discretion of the Parks Director. If open space is provided onsite, it shall be provided in its own tract. As with other tracts, an open space tract cannot count towards the minimum lot area of the lots. • Lakehaven Water & Sewer o Water services are provided by Tacoma Water (253-502-8247, or gwhitleyucitvoftacoma.or). • Public Works Development Services Division 1. Stormwater flow control and water quality treatment (if required), and Best Management Practices (BMP's) shall be per the requirements of the 2016 King County Surface Design Manual (KCSWDM). It's the applicant's responsibility to verify, what, if any, additional requirements may apply to the development of a new single-family home, due to the proximity of the stream and wetland. These requirements will apply at the time of permit submittal for a single-family home on the new lot. • Public Works Traffic Division 1. Transportation Concurrency Management (FWKC 19.90) — A transportation concurrency permit with the application fee of $1,721 is required for the proposed project. 2. Traffic Impact Fees _MZC 19.91) — Traffic impact fees are required and assessed at the time of the building permit. 3. Frontage Improvements (FWRC 19.135.040) — Construct street improvement and dedicate right-of-way on Hoyt Road SW. 4. Access — No direct lot access to Hoyt Road SW • Lakehaven Water & Sewer District 1. Lakehaven strongly discourages the development of a public water/well supply system within the boundaries of Lakehaven's water service boundaries. Lakehaven will provide comments to the applicable regulatory agencies reflecting this, and will also require sufficient proof that the proposed public well will not impact Lakehaven's aquifers, wells, and/or public water supply system. For additional information on this topic you may contact Lakehaven's Water Operations Manager Stan French at sfrench@lakehaven.org. • South King Fire & Rescue 1. Fire hydrants shall be within 600 feet of all points to a structure. A residential automatic fire sprinkler system shall be installed in the new building. 19-105202-00-PC Doc ID: 79799 Mr. Steve Joo Page 3 of 10 December 10, 2019 DEPARTMENT COMMENTS Outlined below are the comments made by the representatives of each department present at the preapplication conference. Each section should be read thoroughly. If you have questions, please contact the representative listed for that section. COMMUNITY DEVELOPMENT — PLANNING DIVISION Leila Willoughby -Oakes, 253-835-2644, leila.willoughby-oakes a cityoffederalway.Com 1. Short Plat Process — Pursuant to FWRC 18.30.010, short plat applications are administratively processed through the Department of Community Development. The administrative review process requires that the Director of Community Development issue a decision on the short subdivision request and confirm conformance with FWRC 18.30.110(2). Public notice of the complete short plat proposal is required per FWRC 18.30.080, and a 15-day public comment period is provided. However, no public hearing will be required unless an appeal is filed. A master land use application and short plat handout are enclosed; relevant code sections are available at the city's website at ",w.citaoffccleralway.com. 2. Land Use Review Timefirames — 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. Review 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. Per FWRC 18.05.080(1), if an applicant fails to provide additional information to the city within 180 days of being notified by mail that such information is requested, the application shall be deemed null and void and the city shall have no duty to process, review, or issue any decision with respect to such an application. Meeting Follow -Up: Upcoming code amendments include a public notice mailing for all short plats to property owners within 300-feet of the property. Please contact Senior Planner Becky Chapin at 253-835- 2641 for code update timing. Please find mailing envelope instructions enclosed with this letter. 3. Public Notice —Short plat applications and SEPA determinations require a public notice and a 15-day comment period. Within 14 days of issuing the Letter of Complete Application, a Notice of Application and Optional DNS will be published in the Federal Way Mirror, mailed to persons within 300 feet of the subject property, posted on the subject property, and placed at the city's three designated notice boards. Meeting Follow -Up: Forthcoming housekeeping code amendments include a mailing notice for short plat proposals to adjacent property owners within 300-feet of the short plat boundaries. 4. Fees —As development fees change annually (adopted each January), please contact the Permit Center at 253-835-2607, or,12ern-itcentet@ciJXaffederalwav: ,for an updated fee list prior to submitting your application. Additional utility fees, school impact fees, concurrency, and engineering plan review fees apply. 5. Lot Si.Ze — The zoning for the subject site is RS-7.2 Minimum lot size for each lot is 7, 200 square feet. As depicted, the proposed lots meet the minimum lot size requirement. Property dedicated to the city for right-of-way frontage improvements, if applicable to this project, may not be counted in lot areas (see the traffic comments). Property set aside in tracts (access, critical area, and/or open space) may also not count towards a minimum lot area under FWRC 19.05.120 "lot area" and 19.145.150(1). 19-105202-00-PC Doc ID: 79799 Mr. Steve Joo Page 4of10 December 10, 2019 All residential subdivisions are required to provide open space in the amount of 15 percent of the gross land area of the subdivision site per FWRC 18.55.060(2). If open space is provided onsite, it shall be provided in its own tract, see item #9, below. 6. Design Criteria —Short plats are subject to the subdivision design criteria of FWRC Chapter 18.55. 7. Setbacks— Future residences must conform to the following structural setback requirements of FWRC 19.200.010, "Detached Dwelling Units": front yard — 20 feet; side yard —10 feet; and rear yard —10 feet. Existing structures to be retained must conform to the structural setback requirements from newly located property lines. 8. Miscellaneous Single-FamiyResidential Regulations — a. Maximum height of structures — 30 feet above average building elevation. b. Maximum lot coverage — 60 percent. c. Required parking spaces — two per dwelling unit. Open Space — All residential subdivisions are required to provide open space in the amount of 15 percent of the gross land area of the subdivision site per FWRC 18.55.060(2). All or some of the open space requirement may be satisfied by a fee -in -lieu payment at the discretion of the Parks Director, after consideration of the city's overall park plan, quality, location, and service area of the open space that would otherwise be provided with the project. Open space fees shall be paid prior to recording the short plat. If the applicant chooses to provide onsite open space, it shall be provided in its own tract and include a combination of the following types: Open Space Category % of Gross Land Area Usable 10% minimum Conservation No maximum or minimum Buffer 2% maximum Constrained 2% maximum Per FWRC 18.55.060(5), "Open space shall be owned in common undivided interest by all property owners within the land division as members...." As with other tracts, an open space tract cannot count towards the minimum lot area of either lot. Another option related to providing the required open space on -site is to request a modification to the open space category requirements per FWRC 18.55.060(3). This request requires review and approval by the Parks Director. For example, as part of the short plat an applicant could submit a request to modify the open space category requirements to: 1) not provide the minimum of 10 percent of "usable" open space; and 2) allow the designation of the entire required 15 percent as "conservation" open space to overlay all or a portion critical area as a tract in the short plat. Meeting Follow -Up: You may provide a combination of on -site and fee -in -lieu in order to satisfy the open space code requirements. 19-105202-00-PC Doc ID: 79799 Mr. Steve Joo Page 5 of 10 December 10, 2019 10. Clearing Grading and Tree and Vegetation Retention — The short plat is subject to the provisions of FWRC 19.120, "Clearing, Grading, and Tree and Vegetation Retention." It is recommended that FWRC 19.120 be reviewed carefully in reference to the proposed short plat. A clearing and grading plan that meets FWRC 19.120.020 and FWRC 19.120.040 must be submitted with the formal short plat application, as clearing and grading work is proposed. The clearing and grading codes pursuant to FWRC 19.120, explicitly outline the following objectives for retaining native vegetation and existing mature trees on the subject property when feasible in a new development: ■ To encourage site development, including clearing, excavation, and filling, in such a manner as to minimize hazards to life, health, and property. • To promote building and site planning practices that are consistent with natural topography, soils, and vegetative features, and minimize disturbance to vegetation and soils. • To preserve and enhance the city of Federal Way's physical and aesthetic character by preventing untimely and indiscriminate removal or destruction of trees and vegetation, and preserving important landscape characteristics that define aesthetic character, such as trees, important vegetation species, and unique landforms or other natural features to the maximum extent possible. 11. Tree Density Requirements — The plat will be subject to tree density requirements of FWRC 19.120.130(1); note that 25 tree -units per acre are required for single-family zoned sites. 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. Required tree density can be composed of retained trees and replacement plantings per FWRC 19.120.130. The tree and vegetation plan must clearly show where the tree units are to be located. The formal application must indicate what trees are to be removed. In the case of the 1.25-acre site, approximately 32 tree units are required (25 x 1.25 acres = 31.25 tree units. Tree unit credits are in Table 2 of FWRC 19.120.130(2). The total number of tree units required to be provided is calculated by multiplying gross site acreage, minus any proposed public or private streets and regulated critical areas tracts. Despite this provision, trees located within critical area buffers can be credited towards satisfying the tree units per acre requirement. 12. Wetlands — Wetlands exist on and adjacent to the subject property within 225 feet. A report prepared in conformance with the Critical Areas Ordinance contained in FWRC 19.145.410 is required. The wetland and buffer must be delineated on the short plat drawing and placed in a tract in conformance with FWRC 19.145.150 and 19.145.420. Per FWRC 19.145.420(6), all lots approved in a recorded subdivision that contain wetlands and their associated buffer in a native growth protection easement or tract may be improved pursuant to easement or tract boundaries established in the plat, regardless of subsequent regulatory buffer increases or natural migration. New improvements shown on the short plat drawing within wetland buffers would not be approved as part of the short plat. A separate Use Process III application submittal and approval for wetland buffer alterations or reductions is required. The applications can be processed concurrently. FWRC 19.145.440 addresses development within wetland buffers. The applicant must demonstrate the criteria of this section are met in order to develop within wetland buffers, including making improvements 19-105202-00-PC Doc 1D: 79799 Mr. Steve Joo Page 6 of 10 December 10, 2019 to the existing driveway access off of 45th Court SW (paving and widening to meet city and South King Fire & Rescue code requirements) and work included private services if required as detailed in FWRC 19.145.440. The applicant must justify using the existing driveway for the access to the newly created lots rather than locating access in a different portion of the site outside the buffer. 13. Streams — A portion of Joe's Creek is located on the subject property. This feature must be delineated on the short plat drawing and placed in a tract in conformance with FWRC 19.145.150 and 19.145.260. The site contains documented fish habitat, which requires compliance with FWRC 19.145.260. 14. Geologically Ha.Zardous Areas — The short plat drawing shows areas with existing slopes greater than 15 percent. A professionally prepared geotechnical report is required as part of the application submittal per FWRC 19.145.250. All development activities on or within 50 feet of a geologically hazardous area as defined in FWRC 19.05.070 are subject to the Critical Areas Ordinance, see FWRC 19.145.220. All landslide hazard areas and buffers (if any) must be delineated on the short plat drawing and placed in a tract in conformance with FWRC 19.145.150 and 19.145.230. 15. Critical Ares Review — The applicant is responsible for providing critical areas reports to the city and for covering the cost of the city's consultants who may review the reports. Meeting Follow -Up: The applicant has submitted a peer review request and a 2018 report. The city is working with the applicant on a peer scope. The proposal does not include a formal delineation of northern portion of the site where the stream/wetland exists, as the prior report was prepared for an addition to the existing residence to the south on proposed Lot 1. 16. Schoollmpact Fees — School impact fees are due at the time of building permit application for new dwelling units. This fee amount is subject to change as determined annually by the Federal Way School District. 17. Sewage Disposal— The applicant must provide documentation that each lot in the subdivision will either connect to the sanitary sewer system or provide an on -site septic system. Wherever feasible, all lots in the short plat shall be connected to sanitary sewer system; see comments from the Lakehaven Water and Sewer District. If connection to the sanitary sewer system is not feasible, on -site sewage disposal may be utilized. The city does not have any code provision requiring connection to the sanitary sewer system. The design and construction of the septic system must be approved by the Public Health -Seattle & King County prior to preliminary subdivision approval. If on -site septic systems are provided, prior to short plat recording, the applicant must obtain the Public Health -Seattle & King County signature on the short plat document and provide a copy of their signed Application for Final Subdivision. 18. Approval Duration — Short plat preliminary approval expires five years from the date of approval. Engineering plans (if applicable, as the subject proposal is only two lots; site development may be reviewed under a single-family building permit) must be approved, improvements constructed, and the short plat must be recorded within the five-year time period. No less than 60 days prior to the lapse of approval, the applicant may request a two-year time extension for the short plat approval. 19. Recording — The applicant will record the short plat with the King County Division of Records and Elections subsequent to the Public Works Department approval of the submitted as -built plans. Prior to recording the short plat, all surveying, and monumentation must be complete. All other required improvements must be substantially completed as determined by the departments of community Development and Public Works. 19-105202-00-PC Doc 1 D: 79799 Mr. Steve Joo Page 7 of 10 December 10, 2019 PUBLIC WORKS — DEVELOPMENT SERVICES DIVISION Kevin Peterson, (253.835.2734, kevin.peterson tom_ cityoffederalway.com) Land Use Issues — Stormwater 1. Surface water runoff control and water quality treatment (if necessary), and other Best Management Practices (BMP's), will be required per the 2016 King County Surface Water De ign Manual (KCSWDM), and will be required at the time of permit submittal for a new single-family home on the new lot. A Level 1 downstream analysis shall also be provided in the preliminary TIR. The city has 1" = 100', five-foot contour planimetric maps in GIS format that may be used for basin analysis. 2. If infiltration is proposed, soil logs prepared by a licensed geotechnical engineer or septic designer must be provided to verify infiltration suitability. 3. If more than one acre will be disturbed during construction, a National Pollutant Discharge Elimination System (NPDES) construction stormwater permit may be required. Information regarding this permit can be obtained from the Washington State Department of Ecology at 360-407-6048, or htQ)://www.ecy.wa.govZpLc�ginins wrllstormwaterlconstructianlindex.hnn]. 4. If work is to be done below the ordinary high-water mark, a Hydraulic Project Approval (HPA) permit may be required. Information regarding this permit can be obtained from the Washington Department of Fish and Wildlife. Right -of -Way Improvements See the Traffic Division comments from Senior Transportation Planning Engineer Sarady Long for traffic related items. 2. If dedication of additional right-of-way is required to install street frontage improvements, the dedication shall be conveyed to the city through a statutory warranty deed. The dedicated area must have clear title prior to recording. Building Permit Issues 1. Prior to submitting for a building permit, refer to the Building Division checklist for the Public Works requirements for a single-family home. 2. When topographic survey information is shown on the plans, the vertical datum block shall include the phrase "DATUM: N.G.V.D.-29" or "DATUM: K.C.A.S.," on all sheets where vertical elevations are called out. 3. Temporary Erosion and Sediment Control (TESC) measures, per Appendix D of the 2016 KCSWDM, must be shown on the engineering plans. 4. The site plan shall show the location of any existing and proposed utilities in the areas affected by construction. 19-105202-00-PC Doc ID: 79799 Mr. Steve Joo Page 8of10 December 10, 2019 PUBLIC WORKS TRAFFIC DIVISION Sarady Long, 253-835-2743, sarady.long a ci offederalwa .cam Transportation Concurrency Analysis (FWRC 19.90) 1. Based on the submitted materials for two lots, the Institute of Transportation Engineers (ITE) Trip Generation - 10th Edition, land use code 210 (Detached Single Family Residential), the proposed project is estimated to generate approximately one new weekday PM peak hour trip. 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). The 2019 estimated fee for the concurrency permit application is ,$1,721 (1 - 10 trips). This fee is an estimate and based on the materials submitted for the preapplication meeting. The concurrency applicant 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 the new weekday PM peak hour trips as identified in the concurrency trip generation. 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. Transportation Impact Fees (TIF) (FWRC 19.91) 1. The current 2019 traffic impact fee is ,$3,999 per lot, plus a three percent administrative fee. The actual fee will be assessed and collected from the applicant when the building permit is issued, using the fee schedule then in effect (FWRC 19.100.070[3][c]). Prior to building permit issuance, the applicant may request to defer the payment of a transportation impact fee to the final building inspection. Refer to the defer payment of the impact fee code for process. Street Frontage Improvements (FWRC 19.135) 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 will be expected to construct improvements on the following streets to the city's planned roadway cross -sections: Hoyt Road SW is a Minor Arterial planned as a Type "K" street, consisting of a 44-foot street with curb and gutter, 6-foot planter strips with street trees, 8-foot sidewalks, and street lights in a 78-foot right-of-way. Assuming a symmetrical cross section, half street improvements and up to 19 feet of right-of-way dedication are required as measured from the street centerline. 2. 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). Information about a right-of-way modification requests are available through the Public Works Development Services Division. These modification requests have a nominal review fee currently at ,$334. 19-105202-00-PC Doc ID: 79799 Mr. Steve Joo Page 9of10 December 10, 2019 3. The proposed driveway on Hoyt Road SW will not be permitted per the recorded plat. Residential lots should not have direct access onto Hoyt Road SW, which is classified as a minor arterial. It appears a shared access is possible from the existing driveway on 45t" Court SW. LAKEHAVEN WATER AND SEWER DISTRICT Kathleen Mathena, Engineering Technician 253-946-5407, kmathena@lakehaven.org Water This property is served by Tacoma Water. Sewer Sewer Service to Proposed Lot A A Sewer Certificate of Availability issued separately by Lakehaven may be required to be submitted with any' land use and/or building permit applications (check with land use agency for requirement). The certificate is valid for one year from the date of issuance. If a certificate is needed, allow one to two working days to issue for typical processing. Option 1 — Connect to the existing sanitary sewer NIH 0894-1 located on proposed Lot B. A utility easement will be required for the private side sewer to service proposed Lot A. Option 2 — Connect to the existing eight -inch sanitary sewer main located in Hoyt Road SW.A right-of-way permit is required for work at this location. Preliminary estimated Lakehaven sewer service connection fees/charges/deposits for 2020 will be as follows: Sewer Certificate of Availability Capital Facilities Charge - Sewer Sewer Service Connection Permit Fee Right -of -Way permit (only for Option 2) Proposed 2020 cost $80.00 Proposed 2020 cost $3,988.00 + tax Proposed 2020 cost $480.00 + tax Proposed 2020 cost $980.00 *All Lakehaven fees and charges are typically reviewed and adjusted (if necessary) annually, and are subject to change without notice. Lakehaven Development Engineering related application forms, and associated standards information, can be accessed at htms:/l-,v<u<v.lakehavcn.orb,/2f14/DLi clol2ment-Engineering,. SOUTH KING FIRE AND RESCUE Sean Nichols, Fire Plans Examiner 253-946-7242, Sean.Nichols@southkingfire.org Water Supply A Cwifrcate of WaterAvailabilidy including a hydraulic fireflow model shall be requested from the water district and provided at the time of the building permit application. Emergency Access Fire apparatus access roads does not comply with the requirements of Fire Access Policy 10.006: hUp.-//soittlikingfire.org/DocumentCentei:/Home/Vte%v/Z4. 19-105202-00-PC Doc 1D: 79799 Mr. Steve Joo Page 10of10 December 10, 2019 Fire Sprinkler System Due to non-compliance with the fire department emergency access, residential fire .sprinklers are required. Meeting Follow -Up: Per Fire Marshall Chris Cahan, if the applicant installs sprinklers in the new residence, a fire access road need not comply with access requirements (i.e. not widened). Further, per Project Planner Leila Willoughby -Oakes, the above will reduce impacts to wetland buffers and ultimately permit review times, if the existing driveway is utilized and a shared access easement is established between Lots 1 and 2. CLOSING This letter reflects the information provided at the preapplication meeting and is intended to assist you in preparing plans and materials for formal application. We hope you found the comments useful to your project. We have made every effort to identify major issues to eliminate surprises during the city's review of the formal application. 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). 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, Leila Willoughby - Oakes, at Led,,L.WiUoughby-Oakesciiyoffedel-,ilway.com. We look forward to working with you. Sincerely, Leila Willoughby -Oakes Associate Planner enc: Master Land Use Application Hwang Short Plat Submittal Checklist Mailing Labels Sign Installation Certificate Concurrency Application Right of -Way Modification Bulletin South King Fire & Rescue Access Standards Lakehaven Handout c: Sarady Long, Senior Transportation Planning Engineer Kevin Peterson, Senior Engineering Plans Examiner William Golding, Planning Intern Kathleen Mathena, Lakehaven Water & Sewer District, �walhaHnCitila✓eeJmt+ra.nrn Sean Nichols, South King Fire & Rescue, sean.nichols@southkingfire.org Jongwon Woo, 32604 45th Court SW, Federal Way WA 98023, ionn on9109 a7Lmil.7om (Owner) 19-105202-00-PC Doc 1D: 79799