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21-101125-UP-Comment Response Memo-07-26-21-V1 1 June 29, 2021 Community Development Department 33325 8th Avenue South Federal Way, WA 98003 253-835-7000 Regarding: File #21-101125-UP, 21-101126-SE Technical Review Comments Dear Review Team, Please see the following architectural (G+A), civil (Navix), landscape (TRA) and traffic (JTE) responses regarding your comments issued on 06/28/21. COMMUNITY DEVELOPMENT – PLANNING DEVISION 2. Plan Set: a. On Sheet AS1.0: 1. The parking analysis has no unit bedroom detail or commercial building square footage shown. Detail how the commercial parking requirement was determined. The preapplication Summary Letter asked for details to be provided on the number of units by bedroom to ensure code compliant parking is provided, also see FWRC 19.220.050(6). FWRC 19.220.050(6) 6. Parking spaces shall be provided as follows: Efficiency dwelling units – 1.0 per unit Studio dwelling units – 1.25 per unit One bedroom dwelling units – 1.5 per unit Dwelling units with two bedrooms or more – 2.0 per unit. G+A Response: Unit bedroom details and commercial building square footage is provided along with updated parking calculations. See AG1.0. 2. For the Podium building, the building height calculation needs additional documentation. Existing elevation calculations are not shown. Please see bulletin #151, “Height Measurement” for further instruction. Also 245.5 feet is more than 5 feet above the lowest proposed elevation of 235.5 feet.” G+A Response: Updated building height calculations have been provided using both existing and proposed grades. See AS1.0. Both methods of calculating the average grade are within 7.66’ of each other. When we use either of these average grades numbers, we can make the height limit work for the project. However, when we incorporate “the average can be no greater than five feet higher than the lowest elevation” it restricts the average grade to the lowest part of the site. This creates a hardship for the podium as the podium has been located on the area of the site with the highest slope differential. Regardless of using existing or proposed calculations the south portion of the podium (elevation E) restricts the height limit. We ask to be allowed to use one of the average grade plane calculations without being restricted by the five foot above the lowest elevation. We have used methods of scale reduction techniques to step the building back at this portion of the building, even though this is not required by FWRC. By using thoughtful design, we reduced the mass of the top floor and located a residential amenity space. We are 2 proposing glass railings to further reduce scale at this area. It appears that the ‘Height Limit” handout is designed for smaller scale buildings with a smaller footprint; that is why we would like to modify this calculation method as we need some leeway to allow for the building. See AS1.0, 1/A1.02, A1.03 and A1.04 and A1.21. 3. Additionally, per FWRC 19.220.050(3), the northwest elevation needs more of an appearance of a gabled/pitched roof. FWRC 19.220.050(3) 3. All buildings except for related parking structures up to 65 ft. in height (six stories), must be gabled with pitched roofs, unless the building is taller than 35 ft. (three stories) with a rooftop that contributes to the multifamily open space requirements. G+A Response: We have given the podium’s northwest elevation more of an appearance of a gabled roof. See 1/A1.00. b. On Sheet AS1.1, factor in the required right-of-way dedication. G+A Response: We have factored in the right-of-way dedication to the calculations. See AS1.1. c. On Sheets A2-A4, clarify what levels in the podium building will be underground and how the podium meets use zone chart FWRC 19.220.050(5). FWRC 19.220.050(5) 5. For 100 dwelling units or more on a subject property, 25 percent of parking shall be underground or on the first floor within the building footprint, except for visitor parking, which can be surface parking. G+A Response: We have clearly added the grade lines to the elevations to illustrate what levels of the podium are below grade at each elevation. There are two additional levels of parking below Level 3. See AG1.1 for stalls provided below grade or within the building footprint. In addition, see A1.00-A1.05 for podium elevations. d. On Sheet C2, the site key has no letters. Navix Response: Site keys have been updated. e. On the landscaping sheets: 4. Do the landscape buffer widths shown along 1st and 348th include landscaping in the right-of- way? If yes, the widths need to be revised to exclude this area from the measurements. TRA Response: Widths have been revised. 3 5. No parking lot landscaping details, such as the size of the islands or total amount provided, are shown. See FWRC 19.125.070(3) for further requirements. FWRC 19.125.070(3) (3) Landscape islands. Landscape islands shall be a minimum size of 64 square feet and a maximum of 305 square feet, and a minimum width of six feet at the narrowest point for islands at the end of 90-degree parking rows, three feet at the end of rows with angled parking, and eight feet in width for islands used to separate head-to-head parking stalls and shall be provided at the following locations: (a) At the end of all rows of parking; and (b) For separation buffering between loading doors or maneuvering areas and parking areas or stalls; and (c) Any remaining required landscaping shall be dispersed throughout the interior parking area in a manner to reduce visual impact of the parking lot; (d) Deciduous trees are preferred for landscape islands within interior vehicle use areas. TRA Response: Sheet L1.00 has a table, Parking Lot Island Landscape Planting, showing the total amount of parking spaces along with the square foot number of plant area required by code and how much planting area is provided. The plan shows the location of these planting lot islands in a hatch and it provides the size with a square footage number next to each island. 3. Design Guidelines – Please address the following comments: a. Provide information to demonstrate the podium building’s compliance with FWRC 19.220.050(1). FWRC 19.220.050(1) 1. All nonresidential ground floor spaces must have a minimum floor-to-ceiling height of 13 ft. and a minimum depth of 15 ft. G+A Response: A section is provided illustrating the 13’ minimum floor to ceiling height. A plan is provided to show compliance the minimum depth of 15’. See A1.20 and A1.30. b. No design guidelines narrative was submitted; one was requested in the Preapplication Summary Letter, and it is listed under the Building Elevations/Design Intent section of the Use Process III Submittal Requirements. G+A Response: A design guidelines narrative has been provided detailing design intent. c. The security program detailed in FWRC 19.115.040 is not addressed in the submittal. FWRC 19.115.040 The following is a list of general strategies that are encouraged to be addressed in a security program for new stacked multifamily dwelling units, senior housing, or special needs housing: (1) Develop written security policies and an emergency management plan, including evacuation procedures. G+A Response: 4 Emergency exit plans, signage and emergency lighting will be provided throughout the buildings and site to help residents and visitors navigate in an emergency event. Ownership will develop a written security policy. A site lighting plan is provided, see sheet SL1.1. See individual responses below. (2) Provide illumination in all areas of the building, including parking facilities and entryways to buildings, according to requirements of the Illuminating Engineering Society (IES) Lighting Handbook. G+A Response: Building and site illumination will be provided in all areas including but not limited to: entries, parking lots, trash areas, site residential amenities, pedestrian paths (3) Ensure that the lobby and the area immediately outside its doors are free of places of concealment for persons. G+A Response: The lobby and area immediately outside its doors will be free of concealment for persons. Residential gated access is also being installed to restrict access from nonresidential users to all residential zones. (4) Install large glass panels in lobby doors. G+A Response: Large storefront window systems are being used at lobby areas for high visibility. (5) Design buildings so that the elevator area is fully visible throughout the lobby. On levels other than the lobby floor, elevators should open directly to hallways, without recesses or blind corners that restrict two-way visibility. G+A Response: All elevators are designed to be fully visible and in plain sight. See A1.10 and A1.20. (6) Locate laundry rooms in a more active area of the building, adjacent to common space or the main lobby, and install large glass windows in the laundry room. G+A Response: There are no laundry rooms located in any building. Washing machines and dryers are located in each unit. (7) Keep laundry rooms and exercise rooms secure and accessible by residents. G+A Response: Washer and dryers are located in each unit. Exercise rooms will be secure and accessed by via key card or similar device. (8) Locate mailboxes and mail rooms adjacent to the main lobby of the building. G+A Response: Mailrooms are located on the ground floor in the main lobby area for all residential units. (9) Store keys in a secure location and control their distribution. G+A Response: Building management will secure and store keys and control their distribution. 5 (10) Control access into the building by locking all exterior entrances, including accessible roof openings, doors to accessible balconies and terraces, and parking garage entrances. Provide automatic door closures, as needed. G+A Response: All building entries, parking garages, roof decks and private patios will have controlled access and automatic door closures as needed. (11) Provide deadbolt locks, peepholes, and safety chains (night latches) on resident doors. G+A Response: All residential doors will have deadbolt locks, peepholes, and safety chains. (12) Install a functioning high quality video monitoring system with cameras located in the lobby, elevator, playground, and parking lot. G+A Response: Security systems will be provided in the lobby, elevator, playgrounds, and parking lot. (13) Keep plants and shrubs trimmed to provide for visibility of the building and surrounding property. G+A Response: Building management will provide regular landscape maintenance to keep plants and shrubs trimmed for visibility. (14) Trim tree branches up from the ground in order to discourage the possibility of a person hiding. G+A Response: Building management will provide regular landscape maintenance to keep plants and shrubs trimmed for visibility. (15) Make sure fences can be seen through. G+A Response: Fences will be designed so that they can be seen through. (16) Post the site and building addresses clearly. G+A Response: The site and building addresses will be clearly visible and located to per the City of Federal Way requirements. d. The podium building needs to address FWRC 19.115.050(3)(b)-(d). FWRC 19.115.050(3)(b)-(d) (3) Parking structures (includes parking floors located within commercial buildings). (b) Parking structures which are part of new development shall be architecturally consistent with exterior architectural elements of the primary structure, including rooflines, facade design, and finish materials. (c) Parking structures should incorporate methods of articulation and accessory elements, pursuant to FWRC 19.115.060(3)(b), on facades located above ground level. 6 (d) Buildings built over parking should not appear to “float” over the parking area but should be linked with ground level uses or screening. Parking at grade under a building is discouraged unless the parking area is completely enclosed within the building or wholly screened with walls and/or landscaped berms. FWRC 19.115.060(3)(b): (i) Showcase, display, recessed windows; (ii) Window openings with visible trim material, or painted detailing that resembles trim; (iii) Vertical trellis(es) in front of the wall with climbing vines or similar planting; (iv) Set the wall back and provide a landscaped or raised planter bed in front of the wall, with plant material that will obscure or screen the wall’s surface; (v) Artwork such as mosaics, murals, decorative masonry or metal patterns or grillwork, sculptures, relief, etc., over a substantial portion of the blank wall surface. (The Federal Way arts commission may be used as an advisory body at the discretion of the planning staff); (vi) Architectural features such as setbacks, indentations, overhangs, projections, articulated cornices, bays, reveals, canopies, and awnings; (vii) Material variations such as colors, brick or metal banding, or textural changes; and (viii) Landscaped public plaza(s) with space for vendor carts, concerts and other pedestrian activities. G+A Response: (b) Brick pilasters are used to connect the facade design by incorporating a consistent language and material that is being used at the podium entries and amenity areas. See A1.00-A1.04. (c) The parking structure incorporates metal screens compliant with 19.115.060(3)(b)(v). See A1.00- A1.04. (d) The parking and at grade residential amenity has been designed to give the podium a base as required by FWRC 19.115.090(q). The parking is both completely enclosed within the building and is screened with walls and perforated screens to provide visual interest. Brick pilasters are used to connect the facade design by incorporating a consistent language and material that is being used at the podium entries and amenity areas. See A1.00-A1.04. e. The commercial building needs to address FWRC 19.115.050(4)(a), as there is no entrance on 348th, the primary commercial façade. FWRC 19.115.050(4)(a) (4) Pedestrian circulation and public spaces. (a) Primary entrances to buildings, except for zero lot line townhouse development and attached dwelling units oriented around an internal courtyard, should be clearly visible or recognizable from the right-of-way. Pedestrian pathways from rights-of-way and bus stops to primary entrances, from parking lots to primary entrances, and pedestrian areas, shall be accessible and should be clearly delineated. G+A Response: A site wayfinding strategy will incorporate wayfinding monument signage to clearly locate site entries, commercial building entries, residential entries and outdoor residential amenities. See AS1.1 for locations. f. See FWRC 19.115.050(4)(b); while the majority of the site meets this guideline, there are several locations that show striped crosswalks, which need to be revised to meet this standard. FWRC 19.115.050(4)(b) (b) Pedestrian pathways and pedestrian areas should be delineated by separate paved routes using a variation in paved texture and color and protected from abutting vehicle circulation areas with landscaping. Approved methods of delineation include stone, brick or granite pavers; exposed aggregate; or stamped and colored concrete. Paint striping on asphalt as a method of delineation is not encouraged. 7 G+A Response: Pedestrian pathways and areas are delineated using variations of paved material and color. All crosswalks have been revised to reflect this requirement. See AS1.0. g. See FWRC 19.115.050(4)(d) & (e); show what is proposed in the pedestrian plazas and near the commercial building on the site plan. FWRC 19.115.050(4)(d) & (e) (d) Bicycle racks should be provided for all commercial developments. (e) Outdoor furniture, fixtures, and streetscape elements, such as lighting, freestanding signs, trellises, arbors, raised planters, benches and other forms of seating, trash receptacles, bus stops, phone booths, fencing, etc., should be incorporated into the site design. G+A Response: (d) Bicycle parking racks have been added near the commercial building. See AS1.1 for location. (e) Outdoor furniture, site lighting, benches, BBQs, children's play equipment and wayfinding signage is proposed for the various plazas and residential amenity areas. See AS1.0 and AS1.1 for amenity features. See SL1.1 for site lighting locations. h. Regarding FWRC 19.115.060(2)(a), it is clear the design uses façade modulation and landscaping in many locations and a canopy on the north side of the commercial building; please provide a narrative or other means of clearly identifying how the proposal meets the two of four requirements on all facades more than 60 feet in length. FWRC 19.115.060(2)(a) (2) Except for zero lot line townhouse development and attached dwelling units, all building facades that are both longer than 60 feet and are visible from either a right-of-way or residential use or zone shall incorporate facade treatment according to this section. Subject facades shall incorporate at least two of the four options described herein, except, however, facades that are solidly screened by Type 1 landscaping, pursuant to chapter 19.125 FWRC, outdoors, yards, and landscaping, may use facade modulation as the sole option under this section. Options used under this section shall be incorporated along the entire length of the facade, in any approved combination. Options used must meet the dimensional standards as specified herein; except, however, if more than two are used, dimensional requirements for each option will be determined on a case- by-case basis; provided, that the gross area of a pedestrian plaza may not be less than the specified minimum of 200 square feet. (a) Facade modulation. minimum depth: two feet; minimum width: 6 feet, maximum width: 60 feet. Alternative methods to shape the building, such as angled or curved facade elements, off-set planes, wing walls and terracing, will be considered, provided that the intent of this section is met. (b) Landscape screening. eight-foot-wide Type II landscape screening along the base of the facade, except Type IV may be used in place of Type II for facades that are comprised of 50 percent or more window area and around building entrances. For building facades that are located adjacent to a property line, some or all of the underlying buffer width required by chapter 19.25 FWRC, outdoors, yards, and landscaping, may be considered in meeting the landscape width requirement of this section. (c) Canopy or arcade. As a modulation option, canopies or arcades may be used only along facades that are visible from the right-of-way. Minimum length: 50 percent of the length of the facade using this option. (d) Pedestrian plaza: size of plaza: plaza square footage is equal to one percent of the gross floor area of the building, but it must be a minimum of 200 square feet. The plaza should be clearly visible and accessible from the adjacent right-of-way. G+A Response: The podium building uses a combination of all four methods. See diagram below to illustrate compliance. 8 The commercial building: north facade uses facade modulation, Type II landscape buffer. West facade uses facade modulation, canopies and pedestrian plaza (1,658 sf). South facade used façade modulation, canopies and pedestrian plaza (1,658 sf). East façade uses facade modulation and a combined length of 19' of landscape. For every 60’ of façade length the building modulates by a minimum of 2’. See AS1.0, AS1.1, A3.00, A3.01, and A3.10. The quads are broken up into two sides each 32’-6” wide with an open breezeway in between breaking up each side to less than 60’ wide thus complying. In addition, the quad buildings all use facade modulation and are not visible from the ROW except for Quad 1. The project is required to have Type II or III landscape buffers in between it and the ROW. Each quad is surrounded by a varying degrees of landscape screening. Quads 2, 3, 4, 5, 6, 7 are all adjacent to or have views of pedestrian plazas or the retention pond. If required to meet this stipulation, we ask for a departure from having to comply for each quad individually as we have designed them to have a village appeal. Canopies do not fit with the quad design as their stairways are already covered from the elements. Having to add Type II landscaping around each quad facade is not feasible due to site constraints and could become a safety concern due to an increased number of hiding places. See A2.00. A2.01 and A2.10 i. Note that the façade modulation minimum depth is 2 feet, not 1.6 feet; several locations will need to be revised to comply with this guideline. G+A Response: See façade modulation diagrams A1.10, A2.10 and A3.10. The quads are broken up into two sides each 32’-6” wide with an open breezeway in between breaking up each side to less than 60’ wide thus do not need to meet this requirement. 9 ii. Need detail for façade modulation on the commercial building’s north and south sides and the quads façades longer than 60 feet in length on the elevation sheets, similar to how it is shown for the podium building. G+A Response: See façade modulation diagrams A2.10 and A3.10. The quads are broken up into two sides each 32’-6” wide with an open breezeway in between breaking up each side to less than 60’ wide thus do not need to meet this requirement. For the commercial building for every 60’ of façade length the building modulates by a minimum of 2’. i. The podium building needs to address FWRC 19.115.080(3). FWRC 19.115.080(3) (3) Commercial and residential components may have different architectural expressions, but the facade shall exhibit a number of unifying elements to produce the effect of an integrated project. G+A Response: All buildings have been designed to express individuality while maintaining a unified campus design. There is a shared material palette used across the campus. A complimentary color palette has been selected and distributed across the buildings. Shared canopy designs and storefront window systems are also being used for both the podium and commercial building. See A1.00-A1.05, A3.00 and A3.01. j. The commercial building needs to address FWRC 19.115.090(1)(b) and (d). Also clarify how the podium building addresses FWRC 19.115.090(d). FWRC 19.115.090(1)(b) &(d) (1) Professional office (PO), neighborhood business (BN), and community business (BC). (b) Entrance facades shall front on, face, or be clearly recognizable from the right-of-way; and shall incorporate windows and other methods of articulation. (d) Ground floor entrances to retail sales or services shall incorporate plaza features or furnishings, and/or streetscape amenities, in a context-sensitive amount and combination, considering the scale of the retail use(s) and entrance(s) to the overall building or development, and the proximity and access to other existing plaza or streetscape features. G+A Response: The plaza areas provided for both the podium and commercial building are incorporating plaza features including, table and chairs, benches, site lighting, trash receptacles, paving differentiation, way finding signage in amounts that are appropriate for the sizes of the spaces they serve. See AS1.0 and AS1.1. k. To comply with FWRC 19.115.090(p), the 348th façade of the podium building needs to have a wider significant structural offset and the northwest facing façade needs to have a wider and deeper offset. FWRC 19.115.090(p) (p) Building facades that exceed 120 feet in length and are visible from an adjacent residential zone, right-of- way, public park, or recreation area shall incorporate a significant structural modulation (offset). The minimum depth of the modulation shall be approximately equal to 10 percent of the total length of the subject facade and the minimum width shall be approximately twice the minimum depth. The modulation shall be integral to the building structure from base to roofline. 10 G+A Response: 348th Street facade (north) 174' x 10% = 17.4' deep 17.4' x 2 = 34.8' wide 17.4' x 34.8' stuctural offset req'd 21'-10" x 26'-0" provided. Departure requested as width does not comply. Corner façade (northwest) 154' x 10% = 15.4' deep 15.4' x 2 = 30.8' wide 15.4' x 30.8' stuctural offset req'd 5340 sf of building area removed and 5025 sf provided as public plaza = Comply 1st Avenue South (west) 197" x 10% = 19.7 deep 19.7' x 2 = 39.4' wide 19.7 x 39.4' structural offset req'd 21'-10" x 36'-6" provided. Departure requested as width does not comply. See structural offset diagram below. Due to site constraints a departure is requested as the widths for the structural offsets do not fully comply. For 348th Street we ask for a departure of 8’-8” of the width required for this requirement. For 1st Avenue South we ask for a departure of 10” of the width of this requirement. This requirement is believed to assist in reducing mass and scale of long buildings. We have taken this into consideration and have reduced the building into (3) main segments as well as removing more of the building from the corner than is required. This has allowed the design to provide a residential plaza which will activate the streetscape and corner. The width needed to comply will affect the interior layout of the units and make them unusable. See AG1.1. 11 l. The quads need to comply with FWRC 19.115.090(q). FWRC 19.115.090(q) (q) Buildings should be designed to have a distinct base, middle and top. The base (typically the first floor) should contain the greatest number of architectural elements such as windows, materials, details, overhangs, cornice lines, and masonry belt courses. The midsection, by comparison, may be simple. (Note: single-story buildings have no middle.) The top should avoid the appearance of a flat roof and include distinctive roof shapes including but not limited to pitched, vaulted, or terraced, etc. G+A Response: (q) All buildings have been designed to have a distinct base, middle and top. Quad building 1, facing 1st Avenue South, has been revised to comply with this code section. We have added a brick base to the entry sides of the first floor. Since quads 2-8 are not facing any right-of-way we would like to depart from this requirement for these buildings. See A2.00 and A2.01. m. To comply with a component of FWRC 19.115.090(r), residential window openings need to have visible trim material, or painted detailing that resembles trim. FWRC 19.115.090(r) (r) Residential design features, including but not limited to entry porches, projecting window bays, balconies or decks, individual windows (rather than strip windows), offsets and cascading or stepped roof forms, shall be 12 incorporated into all buildings. Window openings shall have visible trim material or painted detailing that resembles trim. G+A Response: (r) The design does not incorporate window trim as this detracts from the modern aesthetic. We request to depart from this requirement. 4. Open Space – Please address the following comments: a. Provide details of the podium and quad residential balconies and patios per FWRC 19.220.050(11) if they are to be counted towards the total residential usable open space. FWRC 19.220.050(11) 11. The subject property must provide usable open space in a total amount equal to at least 150 sq. ft. per dwelling unit, and may include private spaces such as yards, patios, and balconies, as well as common areas such as playgrounds, recreation rooms, plazas, rooftop terraces, pools, active lobbies, atriums, or other areas the director deems appropriate. A minimum of 25 percent of the usable open space provided must be common open space. Private open space such as a patio, porch, balcony, or yard may be credited toward total residential usable open space, if such private open space is a minimum of 48 square feet and has a minimum dimension of six feet. G+A Response: Updated open space calculation have been provided as well as quad balcony details. The podium balconies do not comply and have been removed from this calculation. See AS1.1 and A2.10. b. What amenities will the public plazas have? G+A Response: Public plazas will have tables, chairs, trash receptacles, planters, exterior site lighting, benches, BBQs and way finding signage. See AS1.0 and AS1.1 c. In the Preapplication Summary Letter staff asked for a site plan graphic and narrative to demonstrate compliance with open space requirements. Using Sheet AS1.1 is fine if the needed open space details are added. G+A Response: Updated open space calculation have been provided. See AS1.1, A1.20, A1.21 and A2.10. 5. Rockeries/Retaining Walls – Rockeries and retaining walls must be shown on the site, landscape, and civil plans. Provide necessary details to demonstrate compliance with FWRC 19.120.120(2)-(4) and (7). FWRC 19.120.120(2)-(4) and (7) (2) For detention/retention ponds, rockeries and retaining walls shall be a maximum of six feet in height as measured from finished grade at base of wall to top of wall around the detention/retention pond. (3) For commercial and multifamily lots, rockeries and retaining walls shall be: (a) A maximum of six feet in height as measured from finished grade at base of wall to top of wall. (b) There shall be a minimum three-foot landscaped setback at the base of each rockery or retaining wall. (4) The width of the terrace between any two vertical rockeries and/or retaining walls shall be a minimum of five horizontal feet to allow for landscaping and maintenance. (7) Rockeries and retaining walls visible from a public right-of-way or adjacent property shall be composed of rock, brick, or other textured/patterned wall styles as approved by the planning and public works director. 13 Rockeries and retaining walls shall be landscaped in accordance with the applicable standards in Chapter 19.125 FWRC, Article I, Landscaping. G+A Response: All retaining walls are shown on the landscape, civil and architectural plans. The terrace widths between retaining walls are shown in the site plan and elevations for top of wall and bottom of wall are shown in the grading plan to demonstrate compliance with FWRC 19.120.120(2)-(4). The retaining walls will be composed of a textured or patterned style to comply with FWRC 19.120.120(7). See C3.00, C4.00, C4.10. 6. Tree/Vegetation Plan – Please address the following comments: a. Per FWRC 19.120.130(3), only the wetland and not the buffer can be deducted from acreage. FWRC 19.120.130(3) (3) Calculation of the total tree units required. 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. TRA Response: This has been addressed in the notes (2), where it is deducting only the wetland area and public and private streets to get the total acreage and the tree units required. b. There is a discrepancy between the number of trees in the calculation table and what is shown on the site plan as trees to be retained, please clarify. TRA Response: This discrepancy has been corrected. c. The plan needs to list the number of required tree units per FWRC 19.120.130(3) (show calculation) and address how the remaining balance will be met; the proposal is only retaining 76 tree units, when approximately twice that amount is needed between retained and planted trees. FWRC 19.120.130(3) (3) Calculation of the total tree units required. 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. TRA Response: This calculation is shown in the table, Tree Replacement Units on L1.00(2). The table shows the proposed trees times the city table for the total tree units required. 7. Forest Practices – A Forest Practices Application has not been submitted. A Forest Practices Class IV-General Application is required if more than 5,000 board feet of merchantable timber will be harvested from the property in conjunction with the development activity. The city reviews the 14 application in conjunction with SEPA review and review of associated development permits or approvals. TRA Response: There will not be more than 5,000 board feet of merchantable timber harvested from the property in conjunction with the development activity, therefore a Forest Practice Application is not required. 8. Geotechnical Report – Please address the following comments: a. The submitted report is from 2015, is unsigned, is labelled “draft,” and was prepared for a previous version of this project. G+A Response: An updated Geotechnical Report has been submitted. b. The report references the shoreline management code for critical areas (Title 15) rather than FWRC 19.145; the project is not within the shoreline jurisdiction. G+A Response: An updated Geotechnical Report has been submitted. c. The report denotes that the preparer did not review the grading plan. G+A Response: An updated Geotechnical Report has been submitted. 9. Wetland Fencing – Critical areas fencing and signage per current standards will need to be installed per FWRC 19.145.180(2) and (3)(a)(iv). FWRC 19.145.180(2)(3)(a)(iv) (2) Signs. Development proposals approved by the city shall require that the boundary between a critical area buffer and contiguous land shall be identified with permanent signs. Permanent signs shall be a city-approved type designed for high durability. Signs must be posted at an interval of one per lot or every 150 feet, whichever is less, and must be maintained by the property owner or homeowners’ association in perpetuity. The wording, number and placement of the signs may be modified by the director based on specific site conditions. (3) Fencing. Permanent fencing shall be required at the outer edge of the critical area buffer under the following circumstances: (a) As part of any development proposal for: (iv) Other development proposals, including but not limited to multifamily, mixed use, and commercial development where the director determines that such fencing is necessary to protect the functions of the critical area. G+A Response: Permanent fencing is proposed along the perimeter of the pond to ensure the wetland to the south of the pond is protected. Permanent signs will be installed along the fence. 15 10. Title Report Criteria – As a reminder, in the April 28, 2021, Notice of Complete Application Letter, an updated title report was requested as the version submitted is over five years old. G+A Response: An updated Title Report has been submitted. 11. Affordable Units – A minimum of five percent of new dwelling units must be considered affordable as defined by FWRC 19.110.010. As was noted in the Preapplication Summary Letter, the formal application must reflect the affordable housing requirement and provide details of how it will be accomplished. FWRC 19.110.010 (1) Purpose. To provide affordable housing to the citizens of Federal Way and to comply with the Growth Management Act and the county-wide planning policies for King County. (2) Affordable housing defined. “Owner-occupied affordable housing” means dwelling units that are offered for sale at a rate that is affordable to those individuals and families having incomes that are 80 percent or below the median county income. “Rental affordable housing” means dwelling units that are offered for rent at a rate that is affordable to those individuals and families having incomes that are 50 percent or below the median county income. (3) Multiple-family developments; senior citizen housing; assisted living facilities; townhouse development; zero- lot line townhouse development; mixed-use projects; and cottage housing in multifamily zones. New projects involving 25 dwelling units or more are required to provide affordable dwelling units as part of the project. At least two dwelling units or five percent of the total number of proposed units, whichever is greater, shall be affordable. Projects including affordable dwelling units may exceed the maximum allowed number of dwelling units as follows: (a) One bonus market rate unit for each affordable unit included in the project; up to 10 percent above the maximum number of dwelling units allowed in the underlying zoning district. (4) Single-family developments. New single-family developments in the RS-35, RS-15, RS-9.6, and RS-7.2 zoning districts have the option of providing affordable dwelling units as part of the project. Projects including affordable dwelling units may reduce minimum lot size as follows: (a) Those lots in a new single-family conventional subdivision or short subdivision which are proposed to contain affordable dwelling units may be reduced in area by up to 20 percent of the minimum lot size of the underlying zoning district; provided, that the overall number of dwelling units in the subdivision may not exceed 10 percent of the maximum number of units allowed in the underlying zoning district. (5) Provisions for affordable housing for cottage housing development in single-family residential zones are set forth in Chapter 19.250 FWRC. (6) Duration. An agreement in a form approved by the city must be recorded with King County department of elections and records requiring affordable dwelling units which are provided under the provisions of this section to remain as affordable housing for the life of the project. This agreement shall be a covenant running with the land, binding on the assigns, heirs and successors of the applicant. G+A Response: Development total number of units = 233 units x 5% = 11.65 or 12 affordable dwelling units required. 12 units will be offered for rent at a rate that is affordable to those individuals and families with incomes that are 50 percent or below the median county income. These 12 units will remain as affordable housing for the life of the project. See AG1.2 12. Mechanical Equipment – As noted in the Preapplication Summary Letter, 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. 16 FWRC 19.115.050(6)(b) states that site utilities, including transformers and fire standpipes, 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. FWRC 19.110.070, 19.115.050(6)(b) (1) Generally. Except as specified in subsection (2) of this section, vents, mechanical penthouses, elevator equipment and similar appurtenances that extend above the roofline must be surrounded by a solid sight- obscuring screen that meets the following criteria: (a) The screen must be integrated into the architecture of the building. (b) The screen must obscure the view of the appurtenances from adjacent streets and properties. (2) Exemptions. The following shall be exempted from the provisions of this section: (a) Rod, wire and dish antennas allowed under FWRC 19.110.060 are exempt from the requirements of this section, if the screening would interfere with the effective operation of the antenna. (b) A painted appurtenance is exempt from the requirements of this section if the director of community development determines that painting will be as effective in minimizing rooftop clutter as would a solid sight- obscuring screen. (6) Commercial service and institutional facilities. Refer to FWRC 19.125.150 and 19.125.040 for requirements related to garbage and recycling receptacles, placement and screening. (b) Site utilities shall comply with the following: (i) Building utility equipment such as electrical panels and junction boxes should be located in an interior utility room. (ii) 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. G+A Response: All rooftop mechanical equipment will be architecturally screened from view. Mechanical equipment has been located behind gabled and shed roofs. Additional screening has been added where needed. Any other such appurtenances ie. elevator machine rooms are fully enclosed within the building envelope. See 1/A1.00. 13. School Access Analysis – A school access analysis is required to be submitted to the city with the Process III review and SEPA checklist. The analysis will be routed to Federal Way Public Schools to determine whether off-site improvements are needed for safe walking routes, and/or to determine where an appropriate bus stop should be located within the development. Contact Jen Thomas with the Federal Way School District at 253-945-2071 or jthomas@fwps.org for information about the school access analysis requirements. G+A Response: We are currently coordinating this analysis with FWPS. At this time Jen Thomas is out of town. We will continue this coordination and will submit this analysis once Jen returns and we can resume our coordination. 14. Boundary Line Adjustment – The project submittal does not address the need for a Boundary Line Adjustment (BLA). A BLA is required to remove interior lot lines as buildings are proposed to be built across property lines. The BLA will need to be recorded before building permits can be issued. G+A Response: A Boundary Lot Adjustment will be recorded. 17 15. Garbage and Recycling Receptacles – The only facility shown on the site plan is at the southeast corner of the site, far away from the majority of site users. Recent emails between your firm and city staff have indicated there will be additional interior facilities. The following was noted in the Preapplication Summary Letter: 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 on the site plan. Include the square footage of each facility provided. G+A Response: The additional trash facility has been provided along with the requested square footage. See A4.00, A4.01 and A4.02. SEPA 16. Background – Review the project submittal documents and augment this section as appropriate (checklist item #A[8]). 17. Water – There is an on-site wetland. (Checklist item #3[a]). 18. Land Use –The comprehensive plan designation of the site is Community Business (checklist item #8[f]). 19. Transportation – Update as needed per Public Works requirements. 20. Other – If project materials are revised or added that necessitate an update to the SEPA checklist, please update the contents accordingly prior to resubmittal. G+A Response: Comments 16-20 have been addressed and the SEPA checklist has been resubmitted. PUBLIC WORKS - DEVELOPMENT SERVICES DIVISION 1. Submit a current title report. The report that was submitted for land use is more than five years old. G+A Response: A current title report has been submitted. 2. The previously approved Right of Way Modification Request expired in 2017. The applicant needs to either show the required street improvements on both 1st Avenue South and South 348th Street, as identified in the Preapplication Summary Letter, or submit a new written request to the PW Director to waive or modify the improvements. G+A Response: A new written request to modify the improvements has been submitted with a new Right of Way Modification Request. 3. The pollution generating impervious surfaces (PGIS) of the “bypass” areas should be provided with water quality treatment facilities, if those areas meet or exceed the thresholds for water quality treatment as outlined in the 2016 King County Surface Water Design Manual (KCSWDM). Code Sections: 18 King County Surface Water Design Manual https://kingcounty.gov/services/environment/water-and-land/stormwater/documents/surface-water-design- manual.aspx Navix Response: Additional water quality devices have been added to treat bypass area. 4. On Page 20 of the Technical Information Report (TIR), the narrative above Table 5 indicates 79,243 CF of storage is required; however, the narrative below Table 6 indicates 77,147 CF of storage is required. This discrepancy needs to be corrected. Navix Response: The narratives on page 20 of the TIR are corrected so the required volumes are consistent. 5. Sheet C2.00 (site plan): please update the site key notes to have corresponding alphabetic indicators next to them. Navix Response: Alphabetic indicators have been added to the key notes on the site plan. 6. Provide approximate top- and bottom- of wall elevations for the new wall in the stormwater pond. The applicant will likely have to pay for third-party review of the retaining wall (at the time of permit application). Navix Response: The height of the new retaining wall in the stormwater pond is labeled in the site sections to show that the wall complies with height requirements. 7. Cuts in the roadway pavement on 1st and/or 348th for utility connections may have to extend pavement restoration beyond that which is currently shown on the plans, and/or payment of mitigation fees may be due for those cuts. The restoration requirements and mitigation fee cannot be determined until such time as a city right of way permit application is submitted for those connections. Navix Response: Pavement cuts will be updated accordingly when the right of way application is submitted for the corrections. PUBLIC WORKS - SOLID WASTE & RECYCLING DIVISION 1. The roof height of the enclosure is not shown. Provide roof height dimensions on one of the side elevations for the enclosure (per FWRC 19.125.150[7][e][ii][3]): if accessed directly by a collection vehicle, whether inside or outside a structure, a 21-foot overhead clearance shall be provided.) Code Sections: (7) Space and access requirements. The following minimum space and access requirements for solid waste and recycling storage areas shall be incorporated into the design of all buildings: (e) Access for service providers to the storage space from the collection location shall meet the following requirements: (ii) For containers larger than two cubic yards and all compacted refuse containers: 19 (3) If accessed directly by a collection vehicle, whether inside or outside a structure, a 21-foot overhead clearance shall be provided. G+A Response: The roof has been removed from the structure and height is shown. See A4.00 and A4.01. 2. It is unlikely roll-out services for the recycling dumpsters will work, as they are too heavy. The smaller gate is not wide enough to allow access. (Per FWRC 19.125.150[6][b]: in all cases, gates shall be of sufficient width to allow direct, in-line access by solid waste and recycling collectors and equipment. In uses where two or more separate detachable containers [commonly referred to as dumpsters] are situated side-by-side within an enclosure, there must be a minimum of 18 feet of unobstructed access when gates are fully opened [hardware, hinges, and walls will add to total enclosure width, based on design and materials used]. Gate openings must be at least 12 feet wide when an enclosure houses a single drop box or compactor unit.) Code Sections: (6) Design guidelines – General. The following provisions shall apply to all storage area designs: (b) Enclosure and landscaping. All outdoor trash enclosures for solid waste and recycling receptacles shall be screened according to FWRC 19.125.040(4) and (5). In all cases, gates shall be of sufficient width to allow direct, in-line access by solid waste and recycling collectors and equipment. In uses where two or more separate detachable containers (commonly referred to as dumpsters) are situated side-by-side within an enclosure, there must be a minimum of 18 feet of unobstructed access when gates are fully opened (hardware, hinges, and walls will add to total enclosure width, based on design and materials used). Gate openings must be at least 12 feet wide when an enclosure houses a single drop box or compactor unit. Enclosure gates shall not include center posts that would obstruct service access. All landscaping shall be designed not to impede access to the enclosure. G+A Response: A single drop unit is shown with 12’wide gate clearance. See A4.00. 3. Size of southwest related facilities: the space requirement includes this element: (FWRC 19.125.150[7][b]: mixed-use development that contains both residential and nonresidential uses shall meet the storage space requirements shown in Table A for residential development, plus 50 percent of the requirement for nonresidential development. In mixed use developments, storage space for solid waste may be shared between residential and nonresidential uses, and designated storage space for recycling services shall also be provided.) FWRC 19.125.150(7)(b) (7) Space and access requirements. The following minimum space and access requirements for solid waste and recycling storage areas shall be incorporated into the design of all buildings: (b) Mixed-use development that contains both residential and nonresidential uses shall meet the storage space requirements shown in Table A for residential development, plus 50 percent of the requirement for nonresidential development. In mixed use developments, storage space for solid waste may be shared between residential and nonresidential uses, and designated storage space for recycling services shall also be provided. G+A Response: See AG1.1 for calculations. Also see A4.00, A4.01 and A4.02 for plans. 4. Provide plans for the collection of SW&R on each floor (per FWRC 19.125.150[7][a][ii], in addition to the requirement in subsection (7)(g) of this section, plans for stacked multifamily dwelling units shall require designated interior solid waste accumulation or storage areas on each level, including details on how solid waste is conveyed to shared storage space[s]). 20 Code Sections: (7) Space and access requirements. The following minimum space and access requirements for solid waste and recycling storage areas shall be incorporated into the design of all buildings: (a) Except as provided in subsection (7)(a)(i) of this section, for all uses, storage space for solid waste and recyclable materials containers shall be provided as shown in Table A for all new structures and for existing structures to which two or more dwelling units are added. (ii) In addition to the requirement in subsection (7)(g) of this section, plans for stacked multifamily dwelling units shall require designated interior solid waste accumulation or storage areas on each level, including details on how solid waste is conveyed to shared storage space(s). (g) The solid waste and recyclable materials storage space, access, and pick-up/service specifications required in this section, including the number and sizes of containers, shall be included on the plans submitted with the land use or building permit application for any development subject to the requirements of this section. G+A Response: See AG1.1 for storage space calculations. See A4.02 for refuse waste chute that runs vertically thru the building down to Level 3 where the storage of waste is kept. PUBLIC WORKS -TRAFFIC DIVISION 1. Per FWRC 19.135.280, there may be only one driveway for each 330 feet of lot frontage. This property does not have the 660 feet minimum street frontage on South 348th Street and 1st Avenue South to allow a second access. The applicant is required to submit a written request to the Public Works Director to modify the standard. Code Sections: (1) Access to arterials and collectors may be permitted consistent with the following table. On state highways that are not designated as limited access, the minimum spacing is 250 feet, or as shown in the following table, whichever is greater. Left turn and crossing movements through standing queues of traffic may be prohibited, as determined by the public works director. City of Federal Way Access Management Standards Access classification Median Through traffic lanes Minimum spacing (feet)** Minimum signal progression efficiency*** Crossing movements Left-turn out Left- turn in Right- turn out Right- turn in 1 Raised 6 Only at signalized intersections Only at signalized intersections 330 150 150 40% 2 Raised 4 330 330 330 150 150 30% 3 Two-way left- turn lane 4 150 150* 150* 150* 150* 20% 4 Two-way left- turn lane 2 150* 150* 150* 150* 150* 10% * Does not apply to single-family residential uses. ** Greater spacing may be required in order to minimize conflicts with queued traffic. *** If the existing efficiency is less than the standard, new traffic signals may not reduce the existing efficiency. (a) Raised medians will be required if any of the following conditions are met: (i) There are more than two through traffic lanes in each direction on the street being accessed. (ii) The street being accessed has a crash rate over 10 crashes per million vehicle miles, and currently has a two-way left-turn lane. 21 (b) Two-way left-turn lanes will be required if the street being accessed has a crash rate over 10 crashes per million vehicle miles, and currently does not have a left-turn lane. (2) Driveways that serve any use other than detached dwelling units may not be located closer than 150 feet to any street intersection or to any other driveway, whether on or off the subject property. Driveways that serve only residential use may not be located closer than 25 feet to any street intersection. (3) There may be no more than one driveway for each 330 feet of lot frontage. The city may further limit or prohibit access to or from driveways onto arterial streets. (4) Separation distances shall be measured from centerline to centerline of roadways and driveways. JTE Response: Comment acknowledged, thank you. A formal request to modify the standard would be made. 2. First Avenue South is a minor arterial street. The queuing analysis showing the 95th percentile queue length for the northbound direction for build scenario is 508 feet. The north access on 1st Avenue South shall be right-in and right-out only as it is conflicting with the queuing length. JTE Response: The north access on 1st Avenue S. is about 360 s/o of NB to WB LT stop bar. During the AM peak hour the 95% NBLT queue is noted at 119’ (4 to 5 vehicles) leaving ample space for a SB to EB resident motorist to wait in the TWLTL to enter the site. During the PM peak the NB to WB LT queue is 203’ (~8 cars) still leaving ample space for a resident to use the TWLTL; also at this time the NB through queue is 204’ (about 8 cars) that is well short of the access driveway. The users of this driveway are residents of the building thus regular users of the access. I do not believe restricting the access is necessary. The short term queueing affects numerous driveways throughout the region and is within driver expectation. 3. South access on 1st Avenue South is not conflicting with the present northbound travel queuing length. However, if in the future any conflict will arise, the city will restrict that access to right-in and right-out for safety. JTE Response: See response to item #2. Acknowledged: that if a safety item were to arise the City can restrict driveway turning movements if needed. 4. The city may restrict the west most access to left-in on South 348th Street in the future if any conflict in queuing will arise. JTE Response: I believe you are referring to the east driveway? See response to item #3. 5. First Avenue South is a Minor Arterial planned as a Type “C” street, consisting of a 72-foot street including 5-foot bike lanes with curb and gutter, 6-foot planter strips with street trees, 8-foot sidewalks, and streetlights in a 106-foot right-of-way. Assuming a symmetrical cross section, a right-of-way dedication from 3 to 8.4 feet, and half street improvements, are required as measured from the street centerline. Please show the future improvement or apply for a modification request. JTE Response: My Client indicated that this item has been discussed with the City. A formal request to modify the standard would be made. 22 6. 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. Show the driveways width and spacing dimension. Code Sections: The maximum width of driveways, excluding flaring as approved by the public works director, is as follows: (1) For driveways that serve only single-family residential uses and zero lot line townhouse developments, the maximum driveway width is the greater of 20 feet for a two or more-stall driveway, or ten feet for each parking stall, and 10 feet for a one-stall driveway. (2) For other private driveways, refer to the city of Federal Way public works development standards for requirements. (3) For driveways that serve uses other than single-family residential uses and zero lot line townhouse development, the maximum driveway width is 30 feet for a two-lane two-way driveway and 40 feet for a three- lane two-way driveway. 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. JTE Response: Thank you for the feedback, the driveways will be designed and constructed per applicable City standard. 7. The proposed area of commercial/retail space in the submitted plan (17,879 square feet) and the traffic impact analysis report (14,420 square feet) is different. Resubmit the traffic impact analysis correcting the commercial/retail space and trip generation. JTE Response: As noted earlier the Commercial/Retail Space portion of the project has refined subsequent to my March 8, 2021 report. The current plan has 18,292 sf of commercial space most of which is Amenity Space for the residents of the Apartment facility. The projected space breakdown is as follows: Stand-alone retail building / / 7,523 square feet, of which approximately 2,100 is the drive-thu tenant. The remaining 5,423 is general retail. Commercial area in the podium building / / 10,769 square feet, of which 1,380 is “Clubhouse Amenity”, 7,174 is lobby, 1,589 is fitness, and 626 is bike storage & bike workshop amenity. The Trip Generation for the Apartment Amenity space is embodied in the apartment data. 8. Pass-by rate of 10 percent for AM peak hours is used for retail. Submit the supporting documents. JTE Response: The traffic affect of the nominal 10% pass-by-factor applied is 0.9 AMPHT’s that is not significant. 9. Submit all the supporting reports and analysis files used in the traffic analysis report. JTE Response: I included the pertinent supporting documents and subsequently provided the City the Starbucks TG Report. Typically, ITE data is typically not included unless there is a specific reason to do so. 23 10. Match the land-use code according to the ITE trip generation manual 10th edition. JTE Response: My work on the project started in 2016 when the 9th Edition of the TG was in use. I inadvertently missed updating some of the LUC designations in the report text, the correct LUC’s were used in the TG table. 11. Submit all the count data for Rainier Valley Starbucks used in the report to calculate the pass-by rate. JTE Response: I have provided the City a copy of the entire Starbuck Report I have on file. This report was sent to me as a courtesy from a former employer (TP&E, Inc.) that is no longer in business. 12. The retail type is not specified. Hence, Land-Use 814 Variety Store is a more appropriate match. JTE Response: When the ITE Trip Generation 9th Edition was current LUC 826 ‘Specialty Retail’ would have been used. This LUC generated 2.71 PM peak hour trips/1,000 sf. I used Shopping Center LUC 820 that with a TG rate of 3.81 PMPT’s/1,000 sf. 13. The internal trips look high. The size of the retail in the present project is very small to apply this procedure. The procedure varies significantly, and the internal capture rate needs to be justified. JTE Response: A lot of the internal trips are due to the Coffee/Donut shop that is expected to be a hangout spot for residents of the building. I used the NCHRP 684 methodology. 14. The city has adopted a new 2021 impact fee schedule. 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]). FWRC 19.100.070[3][a]). (3) Transportation impact fee. Unless the use of an independent fee calculation has been approved, or unless a development agreement entered into pursuant to RCW 36.70B.170 provided otherwise, the fee shall be calculated and paid per the following: (a) For commercial developments, fees shall be calculated based on the impact fee schedule in effect at the time a completed building permit application is filed and paid prior to permit issuance. For a change in use for which no building permit is required, the fee shall be calculated and paid based on the impact fee schedule in effect on the date of an approved change of use. JTE Response: See full response memorandum from JTE for item #14 response. 24 SOUTH KING FIRE & RESCUE 1. Elevators are required for any building that requires emergency personnel to carry a stretcher more than two stories above the ground level. The elevator(s) shall be capable of fitting a stretcher lying flat. G+A Response: Elevators will be capable of fitting a stretcher lying flat.