FW Mixed Use Technical Comments (002)COMMUNITY DEVELOPMENT DEPARTMENT 33325 8th Avenue South Federal Way, WA 98003-6325
253-835-7000
www.cityoffederalway.com
Jim Ferrell, Mayor
June 28, 2021
Ms. Felicity McDougall
Graves & Associates
3110 Ruston Way, Suite E
Tacoma, WA 98402
fmcdougall@gravesassoc.com
Re: File #21-101125-UP & 21-101126-SE, TECHNICAL REVIEW COMMENTS
Federal Way Mixed Use, Parcels 912940-0010, -0020, -0030, -0040, & -TR-A, Federal Way
Dear Ms. McDougall:
City departments/divisions have the following comments in response to your March 31, 2021, and April 27,
2021, submittals. Some comments provided herein are required and some are informative; while others may
be applicable during future steps of the project. Comments in this letter need to be addressed prior to
issuance of a land use application decision, or as otherwise noted. Questions regarding technical review
comments should be addressed to the referenced staff representative. The Federal Way Revised Code (FWRC) is
available online at: http://www.codepublishing.com/WA/FederalWay/.
Community Development – Planning Division
Stacey Welsh, (253) 835-2634, stacey.welsh@cityoffederalway.com
Use Process III
1. General – Technical comments made about an item on one sheet, or in a document, may necessitate
changes to other related sheets and documents. It is the applicant’s responsibility to determine any such
necessary adjustments. Please ensure consistent information is communicated throughout the plan set
and associated application materials.
2. Plan Set – Please address the following comments:
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).
2. For the podium building, the building height calculation needs additional documentation.
Existing elevation calculations are not shown. Please see Bulletin #151, “Height
Ms. Felicity McDougall
Page 2 of 7
June 28, 2021
21-101125-00-UP Doc. I.D. 81463
Measurement” for further instruction. Also 245.5 feet is more than 5 feet above the
lowest proposed elevation of 235.5 feet.
3. Additionally, per FWRC 19.220.050(3), the northwest elevation needs more of an
appearance of a gabled/pitched roof.
b. On Sheet AS1.1, factor in the required right-of-way dedication.
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).
d. On Sheet C2, the site key has no letters.
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.
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.
3. Design Guidelines – Please address the following comments:
a. Provide information to demonstrate the podium building’s compliance with FWRC 19.220.050(1).
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.
c. The security program detailed in FWRC 19.115.040 is not addressed in the submittal.
d. The podium building needs to address FWRC 19.115.050(3)(b)-(d).
e. The commercial building needs to address FWRC 19.115.050(4)(a), as there is no entrance on 348th,
the primary commercial façade.
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.
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.
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.
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.
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.
i. The podium building needs to address FWRC 19.115.080(3).
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).
Ms. Felicity McDougall
Page 3 of 7
June 28, 2021
21-101125-00-UP Doc. I.D. 81463
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.
l. The quads need to comply with FWRC 19.115.090(q).
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.
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.
b. What amenities will the public plazas have?
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.
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).
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.
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.
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.
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 application in
conjunction with SEPA review and review of associated development permits or approvals.
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.
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.
c. The report denotes that the preparer did not review the grading plan.
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).
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.
Ms. Felicity McDougall
Page 4 of 7
June 28, 2021
21-101125-00-UP Doc. I.D. 81463
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.
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.
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.
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.
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.
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.
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.
Ms. Felicity McDougall
Page 5 of 7
June 28, 2021
21-101125-00-UP Doc. I.D. 81463
Public Works – Development Services Division
Kevin Peterson, (253) 835-2734, kevin.peterson@cityoffederalway.com
1. Submit a current title report. The report that was submitted for land use is more than five years old.
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.
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).
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.
5. Sheet C2.00 (site plan): please update the site key notes to have corresponding alphabetic indicators next
to them.
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).
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.
Public Works – Solid Waste & Recycling Division
Rob Van Orsow, (253) 835-2770, rob.vanorsow@cityoffederalway.com
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.)
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.)
Ms. Felicity McDougall
Page 6 of 7
June 28, 2021
21-101125-00-UP Doc. I.D. 81463
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.)
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]).
Public Works – Traffic Division
Soma Chattopadhyay, (253) 835-2731, soma.chattopadhyay@cityoffederalway.com
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.
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.
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.
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.
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 street lights 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.
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.
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.
8. Pass-by rate of 10 percent for AM peak hours is used for retail. Submit the supporting documents.
Ms. Felicity McDougall
Page 7 of 7
June 28, 2021
21-101125-00-UP Doc. I.D. 81463
9. Submit all the supporting reports and analysis files used in the traffic analysis report.
10. Match the land-use code according to the ITE trip generation manual 10th edition.
11. Submit all the count data for Rainier Valley Starbucks used in the report to calculate the pass-by rate.
12. The retail type is not specified. Hence, Land-Use 814 Variety Store is a more appropriate match.
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.
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]).
SOUTH KING FIRE & RESCUE
Sean Nichols, 253-946-7242, sean.nichols@southkingfire.org
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.
CLOSING
Please be aware that this review does not preclude the city from requesting additional information related to
any of the topics discussed above. Please submit by electronic submittal (Document Upload Link or
https://www.cityoffederalway.com/node/4588) revised application materials as appropriate, a letter explaining
how these comments have been addressed, and the completed “Resubmittal Information Form” (enclosed).
If you have any questions regarding this letter please contact me at stacey.welsh@cityoffederalway.com, or
253 835-2634.
Sincerely,
Stacey Welsh, AICP
Principal Planner
enc: Bulletin #151 “Height Measurement”
Resubmittal Information Form
c: Kevin Peterson, Senior Engineering Plans Reviewer
Rob Van Orsow, Solid Waste/Recycling Manager
Soma Chattopadhyay, Traffic Engineer
Sean Nichols, South King Fire & Rescue
Brett Jacobsen, X Marks the Spot LLC, bjacobsen@fnw-inc.com