21-102066-UP-Response Letter-2021-11-24-V2 (1)November 24, 2021
Becky Chaplin
Senior Planner
City of Federal Way
Community Development Department
33325 – 8th Avenue South
Federal Way, WA 98003
RE: Responses to Comments – Consolidated Correction Letter
Smith Brothers
City of Federal Way File #21-102066-00-UP
Our Job No. 21537
We have revised the plans and technical documents for the above-referenced project in accordance with
your comment letter dated September 15, 2021. Enclosed are the following plans and documents for your
review and approval:
1. One (1) electronic copy Resubmittal Form
2. One (1) electronic copy revised SEPA Environmental Checklist
3. One (1) electronic copy revised Civil Engineering Design Plans
4. One (1) electronic copy revised Landscape Planting Plan
5. One (1) electronic copy revised Architectural Site Plan
6. One (1) electronic copy revised Technical Information Report
7. One (1) electronic copy revised SWPPP
8. One (1) electric copy of Modification Request to Public Works D evelopment Standards
for Driveway Width (to be submitted under separate permit)
9. One (1) electric copy of Modification Request to Public Works D evelopment Standards
for Frontage Improvements (to be submitted under separate permit)
10. One (1) electric copy of Modification Request to Public Works D evelopment Standards
for Retaining Wall Height (to be submitted under separate permit)
11. One (1) electric copy of Modification Request to Public Works D evelopment Standards
for Landscape Buffer (to be submitted under separate permit)
12. One (1) electronic copy Sketch ABE Calculations
13. One (1) electronic copy Ultrablock Materials Brochure
The following outline provides each of your comments in italics, along with a narrative response
describing how each comment was addressed:
Community Development – Planning Division
Becky Chapin, 253-835-2641, becky.chapin@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
Becky Chaplin
Senior Planner
City of Federal Way
Community Development Department -2- November 24, 2021
to determine any such necessary adjustments. Please ensure consistent information is
communicated throughout the plan set and associated application materials. The resubmitted
Architectural Site Plan, Civil Plans, and Landscape Plan depict different building square
footage. Please correct prior to resubmitting. Note, revisions to address the comments below
may result in further additional comments and may require further plan revision to meet
applicable requirements
Response: The building square footage of 45,300 square feet has been shown and is
consistent throughout all submitted documents.
2. Site Plan – Remove reference to the expansion on the site plan as a phasing plan has not
been proposed. A separate land use review process wi ll be required for the additional 10, 000
square feet. Alternatively, if you wish to include a phasing plan as part of the current Process
III review, additional plans and details of the expansion would be required. Including, but not
limited to, written explanation of timing of expansion/phasing, elevations, site plan, and
landscape plans for Phase 2, future expansion building.
Response: The reference to expansion has been removed from all plan sets and the full
building footprint has been shown.
3. Building Height –Please refer to the “Average Building Elevation (ABE)” and “Height of
Structure” definition in FWRC 19.05.010 and FWRC 19.05.080. The ABE is calculated for
each building façade of the structure, then add each façade ABE together and divide d by the
number of facades for the final ABE datum. For example, a four-sided building ABE
calculation would be A+B+C+D / 4 = ABE. Average of both existing and proposed grade of
each facade as specified in FWRC needs to be shown, not just the four corners of the
building.
Response: See Sketch ABE calculations sheet with notes have been provided with this
submittal.
4. Parking Area Design – Dimensions are not provided for the compact spaces or drive isle
width where the 9 compact spaces are provided. Provide dimension to verify compliance with
the city’s Parking Lot Design Criteria handout.
Response: Dimensions to compact spaces and drive aisles have been added to the site
plan.
5. Landscaping – This is not a complete technical code-based review of the landscape plans.
This review is intended to address major items on the landscape plan, and to identify spatial
requirements for landscape perimeter areas and parking lot landscaping areas in general.
Final landscape review occurs with the building permit application review. However, the
comments below need to be addressed in order to evaluate the Process III site plan
application.
a) The parking lot landscaping calculation is not provided. Refer to FWRC 19.125.070,
“Parking Lot Landscaping,” the development must provide twenty-two square feet of
Becky Chaplin
Senior Planner
City of Federal Way
Community Development Department -3- November 24, 2021
Type IV landscaping per parking stall when 50 or more parking stalls are being
provided.
Response: Parking lot landscaping calculations and areas of individual parking lot
landscape areas have been added to sheet L-1.
b) The Type II perimeter landscaping shall be evergreen or a combination of
approximately 60 percent evergreen and 40 percent deciduous trees, with an
allowable five percent variance, interspersed as depicted below, with large shrubs
and groundcover. It does not appear the perimeter landscaping meet s this
requirement as two rows of trees interspaced is required. Refer to FWRC
19.125.050(2), Figure 4, below.
Response: All perimeter landscaping has been revised as noted. The
evergreen/deciduous tree ratio have been added to sheet L-1.
c) The landscape along the property line of the intersection at S 344th St and 9th Ave S
has large gaps of trees missing in the required 10-ft buffer.
Response: Additional trees and shrubs have been added in this area.
d) The city understands that there is a sewer easement along the south property line.
However, there is a list of approved trees that Lakehaven Water & Sewer District
allow within easement, enclosed. The landscape plan must be revised to include t he
acceptable landscape trees along the south property line. Other shallow root tree
species may be planted, but will need to be reviewed and approved by Lakehaven.
Response: Perimeter landscaping in area of the Lakehaven Water and Sewer
District easement has been revised to include and deciduous tree species selected
from Lakehaven Water & Sewer District’s approved list.
e) Perimeter landscape areas need to be free of retaining walls. Retaining walls cannot
reduce the width of landscape areas below the required width along perimeter area.
Please verify all perimeter landscape area widths are at least 10 feet, excluding
retaining walls. Increases in the landscape buffer width may be necessary to
accommodate the retaining walls.
Response: See attached Modification Request to Public Works Development
Standards for Landscape Buffer.
f) If for some reason the site cannot meet perimeter landscape requirements, whether
that is due to sight-distance and/or utilities, a landscaping modification needs to be
requested in accordance with FWRC 19.125.100.
Response: See attached Modification Request to Public Works Development
Standards for Landscape Buffer.
Becky Chaplin
Senior Planner
City of Federal Way
Community Development Department -4- November 24, 2021
6. Retaining Walls and Fencing – Retaining walls and fences must meet FWRC 19.125.160(5-6)
and 19.120.120. Please address the following comments and revise plans accordingly.
a) Provide a written response of how the proposed retaining walls meet each of the
standards in FWRC 19.125.160(6)(a-c).
Response: Terra Associates Inc. is preparing a wall detail which will be in cluded in
the civil construction package for site development and any other relevant
construction permits. See Modification Request to Public Works Development
Standards for Retaining Wall Height for more details.
b) Identify materials and designs of any retaining walls visible from the right-of-way or
adjacent properties.
Response: For the retaining wall along 9th Ave. S., a textured concrete block, with
Ultrablock quarry stone finish is being proposed. A cut sheet has been included
within this submittal.
c) Provide a detail of the proposed fence.
Response: Fencing details added to sheet C7 of the civil set.
7. Community Design Guidelines – Building and Site Design –
a) Provide a written narrative stating how each façade individually meets the
dimensional guidelines of the façade modulation and screening guidelines in FWRC
19.115.060(2), incorporating at least two of the four treatments (or something better),
including modulation, landscape screening, pedestrian plaza, and canopies. For
example, the west façade should be described as: “The wes t façade includes
building modulation with a depth of ** feet deep and ** feet wide. This facade also
includes a canopy for ** percent of the façade.”
Response: Building’s west and north façades are subject under FWRC
19.115.060(2) to trigger modulation and screening options. East and south façade
are not subject to this section.
The west façade includes:
(2)(a): building modulation with a depth of 2 inches deep, varying color and varying
width between 6 feet and 60 feet. This façade also includes a diagonal office corner
feature of 24 feet wide. Office also has lowered parapet height in comparison with
warehouse. See attached color rendering on sheet EX3-0.
(2)(d): pedestrian plaza area more than 900 square feet, more than 1 percent of the
building footprint. The plaza has direct access from the adja cent right-of-way and
parking lot.
Becky Chaplin
Senior Planner
City of Federal Way
Community Development Department -5- November 24, 2021
The north façade includes:
(2)(a): building modulation with a depth of 2 inches deep, varying color and varying
width between 6 feet and 60 feet. This façade also includes a diagonal office corner
feature of 24 feet wide. Office also has lowered parapet height in comparison with
warehouse. See attached color rendering on sheet EX3-0.
(2)(d): pedestrian plaza area more than 900 square feet, more than 1 percent of the
building footprint. The plaza has direct access from th e adjacent right-of-way and
parking lot.
b) Identify specific methods of façade articulation and scale for each building facades
pursuant to FWRC 19.115.060(3).
Response: Building’s west and north facades fits the criteria under FWRC
19.115.060(3), for being visible from a right-of-way.
The west façade includes:
(3)(b)(ii) Window openings with visible trim material; full wall height window panels for
office corner;
(3)(b)(iv) Building is set back from property line, and has TYPE II landscaping along
the property line to provide visual screen for the wall.
(3)(b)(vi) Architectural features such as vertical reveals on warehouse walls, diagonal
angled exterior building wall, also parapet height transitions between warehouse and
office, and lastly coping trim above office.
(3)(b)(vii) Material variations of color changes, metal coping at parapet.
(3)(b)(viii) Public Plaza of more than 900 square feet for potential public activities.
The north façade includes:
(3)(b)(ii) Window openings with visible trim material; full wall height window panels for
office corner;
(3)(b)(iv) Building is set back from property line, and has TYPE II landscaping along
the property line to provide visual screen for the wall.
(3)(b)(vi) Architectural features such as vertical reveals on warehouse walls, diagonal
angled exterior building wall, metal canopy above office entrance, also parapet height
transitions between warehouse and office, and lastly coping trim a bove office.
(3)(b)(vii) Material variations of color changes, metal coping at parapet.
(3)(b)(viii) Public Plaza of more than 900 square feet for potential public activities.
Becky Chaplin
Senior Planner
City of Federal Way
Community Development Department -6- November 24, 2021
c) Provide pedestrian connections from both rights-of-way to the main entrance. A
delineated pedestrian connection from South 344th Street to the main e ntrance must
be provided and identified with a variation in material, color, and texture per FWRC
19.115.050(4) and 19.115.090(2). It appears that the pedestrian connection from 9th
Avenue South to the main entrance is a stripped crosswalk. Please revise to meet
requirements of FWRC 19.115.050(4).
Response: Pedestrian connections provided from both rights-of-way to the main
entrance. A delineated pedestrian connection from South 344th Street to the main
entrance has been provided and identified with stamped and light gray colored
concrete per FWRC 19.115.050(4) and 19.115.090(2).
8. Solid Waste and Recycling - No details regarding the solid waste and recycling storage area
were provided. Provide an elevation drawing of the enclosure. Solid waste and recycling
storage area design shall be consistent with the architectural design of the primary
structure(s) on the site, FWRC 19.125.150(6).
Response: Weather protection is provided utilizing fully enclosed and locked waste
compactors, located adjacent to the building. No drains are proposed for this area. The
containers for recycling, garbage, and other source-separated solid waste materials will be
provided with clearly visible signs. Additional details regarding the enclosed trash and
recycling receptacles provided on the Architectural Site Plan and sheet C6 of the civil set.
9. Rooftop and Ground Mounted Equipment – The submittal does not provide detail on the
location and screening for ground mounted and rooftop mechanical equipment. Identify both
ground mounted and rooftop equipment, if any.
Response: Rooftop mounted HVAC equipment will be design-build, screening will be
provided by either building parapets or screen walls designed with the equipment. See
screening section detail 4 on sheet A4-0, for illustration of probable location of RTU and
parapet. Ground mounted transformer pad identified on site plan , near side entrance at west
side.
a) For rooftop mechanical equipment, per FWRC 19.110.170, 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; and (b) the screen must obscure the view of the appurtenanc es from
adjacent streets and properties.
Response: See exhibit EX5-0 screening section for illustration of RTU being fully
screened by solid parapet. The screen obscures the view of appurtenances from
adjacent streets and properties.
b) For ground mounted equipment, per FWRC 19.125.050, Type I landscaping is
intended to provide a solid sight barrier to totally separate incompatible land uses.
This landscaping is typically found “… around outdoor stora ge yards, service yards,
loading areas, mechanical or electrical equipment, utility installations, trash
receptacles, etc.
Becky Chaplin
Senior Planner
City of Federal Way
Community Development Department -7- November 24, 2021
Response: No ground mounted HVAC equipment is proposed. Building will utilize
rooftop units. Evergreen screening is proposed at the loading areas adjacent to the
public right of way. See sheets L-1 and L-2 for more details.
10. Burden of Proof – In this letter, staff members have identified items that require the provision
of additional information for review. During the Notice of Application comment period, the city
received one public comment letter, which is enclosed. Please review and address the
comments to support your project. Per FWRC 19.65.080:
19.65.080, “Burden of Proof”
“The applicant has the responsibility of convincing the director that, under the provisions of
this chapter, the applicant is entitled to the requested decision.”
Response: This response is intended to address the questions laid out by the Federal Way
Public Schools Business Services letter.
• What are the sizes of the trucks to be used in the distribution process?
Response: The largest expected trucks are anticipated to be 73.5-feet in overall
length. In addition, delivery trucks are approximately 8-feet in width and 20-feet long.
• How many trucks are expected to move in and out of the facility each day?
Response: Approximately 12-15 larger trucks are expected during hours of
operation. Approximately 40 delivery trucks are expected per day.
• What times of the day will the trucks be mostly moving in and out of the facility?
Response: Larger trucks are received between the hours of 7 AM and 3 PM.
Delivery trucks will leave the facility at 5 AM and return by 3 PM, spread out amongst
those hours. The distribution should have minimal effect on school drop off and pick
up hours.
11. Boundary Line Adjustment – As the building and parking areas extend over the internal
parcel line, a boundary line adjustment (BLA) to consolidate the two parc els is required. BLA
approval is required at time of issuance of building permi ts, buildings cannot be constructed
over property lines. A boundary line adjustment is an administrative review process under
FWRC 18.10. A BLA information handout is enclosed. Contact the Permit Center at
permitcenter@cityoffederalway.com for the BLA application fee and submittal questions.
Response: A boundary line adjustment application is being prepared and will submitted to
the City of Federal Way for review under separate cover.
SEPA Checklist
12. Background (7) – Include approximate square footage of future addition.
Response: The reference to the future building addition has been removed.
Becky Chaplin
Senior Planner
City of Federal Way
Community Development Department -8- November 24, 2021
13. Background (11) – Include information regarding phasing for the future addition.
Response: The reference to the future building addition has been removed.
14. Environmental Health (7b2) – Provide more details regarding the long-term impacts. Include
the type of vehicles coming and going to the site and hours of operation.
Response: Approximate times of operations and types of vehicles have been added to the
response.
15. Land and Shore (8f) – The comprehensive plan designation of the site is Commercial
Enterprise.
Response: Revised accordingly.
16. Land and Shore (8h) – The site is located within a five-year wellhead protection zone and
wellhead protection regulations apply pursuant to FWRC Chapter 19.145, “Environmentally
Critical Areas.”
Response: Acknowledged, this section has been revised accordingly.
17. Transportation (14c) – The number of proposed parking stalls is listed incorrectly based on
the proposed site plan. The parking count must include all on-site parking, including truck,
box truck, and van parking.
Response: Section has been revised to be consistent with the proposed site plan.
18. Other – If project materials are revised or added that necessitate an update to the SEPA
checklist, please update the contents accordingly prior to resubmittal.
Response: Comment acknowledged. The SEPA checklist has been revised to be consistent
with all project documents.
PUBLIC WORKS – TRAFFIC DIVISION
Sarady Long, 253-835-2743, sarady.long@cityoffederalway.com
Use Process III
1. Show frontage improvements along the property frontage on 9th Avenue South and South
344th Street. These streets are improved with vertical curb gutter, sidewalks, streetlights,
etc., but the improvements do not meet the current street standards. The applicant may
submit a written request to the Public Works Director to modify, defer, or waive the required
street improvements (FWRC 19.135.070). Unles s the Public Works Director approved or
modified the required improvement, the applicant would 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).
Becky Chaplin
Senior Planner
City of Federal Way
Community Development Department -9- November 24, 2021
• 9th Avenue South Principal Collector planned as a Type “K ” street, consisting of 44’
street with bike lane, 6’ planter strips with street trees, 8’ sidewalks, and street lights in a
78’ right- of-way (ROW). Assuming a symmetrical cross section, half street improvements
are required as measured from the street centerline. It appears the existing 39’ right-of-
way would be adequate to accommodate planned improvement.
• South 344th Street is a Principal Collector planned as a Type “R” street, consisting of 40’
street with curb and gutter, 4’ planter strips with street trees, 6’ sidewalks, and street
lights in a 66’ right-of-way (ROW). Assuming a symmetrical cross section, half street
improvements are required as measured from the street centerline
Response: See Modification Request to Public Works Development Standards for
Frontage Improvements for the formal request to exclude frontage improvements from
the project requirements.
2. At a minimum, two curb ramps at 9th Avenue South/ South 344th Street intersection would
need to be upgraded to meet ADA. Additional mid-block curb ramps at the easterly property
would be expected to be installed as part of this project to meet ADA.
Response: Two curb ramps are proposed at the northeast and southeast corners at the
intersection of 9th Ave. S. and S. 344th St. The upgrade of the curb ramp at the southeast
corner eliminates the need of any mid-block ramps to the east as the sidewalk ends near the
eastern boundary of the project site.
3. The driveway width on South 344th Street is wider than the 30’ maximum allowable for a two-
lane 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. However, a modification must be submitted to the Pub lic Works Director for
consideration.
Response: See Modification Request to Public Works Development Standards for Driveway
Width for the formal request to increase standard driveway width for truck access.
4. Adequate driveway throat length should be provided for safe and efficient traffic circulation. A
40’ throat length is recommended as measured from the face of curb (or edge of traveled way
if no curb exists) on the public str eet to the first conflicting drive aisle or parking movements
that would conflict with entering and exiting traffic.
Response: A 40-foot throat length has been provided.
5. Label dimension of driveway on the plan set.
Response: Driveways have been labelled accordingly.
6. Update sheet C1 of 10 to reflect the correct existing r ight-of-way width on 9th Avenue South.
The existing half street right-of-way is 39’ as measured from street center and not 30’ as
shown on the plan.
Becky Chaplin
Senior Planner
City of Federal Way
Community Development Department -10- November 24, 2021
Response: The existing right-of-way has been revised and shown correctly throughout the
plan set.
7. The truck circulation site plan depicted trucks traffic will not utilize 9th Avenue South or South
344th Street west of the driveway. Give that the development is consistent with the
surrounding businesses, pavement evaluation is not necessary.
Response: Acknowledged, no further action required.
8. The truck circulation site plans (turning diagram) should be in the Civil Plans and not in the
architectural Plans.
Response: The truck circulation site plan has been moved to the Civil Plan set.
9. It appears the turning truck will mount the driveway curb within the internal site drive aisle;
consider modifying the driveway to accommodate the turning truck.
Response: The access has been modified to accommodate truck turning without mounting
the curb.
SEPA Checklist:
10. Transportation - 14.a: Update this section to specify truck traffic will utilize the driveway on
South 344th Street as the primary access to Pacific Highway South (SR 99).
Response: This section has been updated accordingly.
11. Transportation – 14.d: Half-street improvements to 9th Avenue South and S 344th Street are
required per code. However, the applicant may submit a modification request to modify or
waive these improvements. This section will nee d to be update to reflect the Public Works
Director’s decision if a modification request is submitted.
Response: See Modification Request to Public Works Development Standards for Frontage
Improvements for the formal request to exclude frontage improvements from requirements.
PUBLIC WORKS – DEVELOPMENT SERVICES DIVISION
Kevin Peterson, 253-835-2734, kevin.peterson@cityoffederalway.com
1. The applicant shall provide additional details for their Solid Waste and Recycling (SWR)
facilities, including storm water management, per FWRC Section 19.125.150;
Response: SWR facilities to be fully enclosed and sealed within container. Additional details
added to Architectural Site Plan and sheet C6 of the civil plan set.
2. According to the geotechnical report, groundwater was noted at 8.5 feet below finish grade
(TP #5 – page 7 of the pdf file), and it was concluded that this should be used in design
considerations. With the bottom of the infiltration trench designed at 6-feet below existing
grade (2.5 feet above the ‘design’ groundwater elevation), and per the requirements of the
Becky Chaplin
Senior Planner
City of Federal Way
Community Development Department -11- November 24, 2021
2016 King County Surface Water Design Manual (KCSWDM), Section 5.2.1, a groundwater
mounding analysis shall be performed to ensure the infiltration facility will perform as
designed;
Response: To clarify, groundwater monitoring indicates that the seasonal high-water table is
approximately 8.5 feet below the existing grade (elevation 248). The bottom of the infiltration
trench (see Sheet C8 for more details) is located approximately 6-feet below the proposed
finished grade (elevation 253). The geotechnical report created by Terra Associates, Inc.
reiterates the separation being at least 5-feet in section 4.7 Infiltration Feasibility of the before
mentioned report. A mounding analysis is currently being completed and will be submitted
under a separate cover.
3. A revised Technical Information Report is required that addresses the facility sizing for the
detention and water quality facilities, due to the added parking area (not included in original
submittal) along 9th Ave S.
Response: The revised Technical Information Report has been included as part of this
submittal.
LAKEHAVEN WATER AND SEWER DISTRICT
Brian Asbury, 253-946-5407, BAsbury@lakehaven.org
1. Regarding the city’s completeness review for the subject application/project, the applicant
has completed and submitted to Lakehaven an application for Certificates of Availability, and
Lakehaven issued these Certificates on May 24, 2021. However, no other application has
been submitted to Lakehaven that is necessary to be able to determine the applicant’s
specific requirements for connection to Lakehaven’s water and/or sewer systems to serve the
subject property. As previously noted, applicant will need to submit an application for either
Developer Pre-Design Meeting or Developer Extension Agreement for Lakehaven to formally
commence the water (and sewer) plan review process. Lakehaven encourages
owners/developers/applicants to apply for Lakehaven processes separately to Lakehaven,
and sufficiently early in the pre-design/planning phase to avoid delays in overall project
development.
Response: A draft Developer Extension Agreement has been submitted to LWSD for review.
SOUTH KING FIRE AND RESCUE
Sean Nichols, 253-946-7242, sean.nichols@southkingfire.org
1. The hydrant nearest the FDC, needs to be moved across the drive aisle so Fire doesn’t block
the road with hose if they needed to connect to the yard FDC.
Response: The proposed fire hydrant has been moved to within the planter across the drive
aisle.
Becky Chaplin
Senior Planner
City of Federal Way
Community Development Department -12- November 24, 2021
2. A wall mounted FDC is acceptable if desired.
Response: Wall mounted FDC is proposed on Utility Plan, see sheet C9.
We believe that the above responses, together with the enclosed revised plans and technical doc uments,
address all of the comments in your letter dated September 15, 2021. Please review and approve the
enclosed at your earliest convenience. If you have questions or need additional information, please do not
hesitate to contact me at this office. Thank you.
Sincerely,
Ben Eldridge, P.E.
Senior Project Engineer
JT/
21537c.001.doc
enc: As Noted
cc: Scott Hougham, KGIP
Daniel K. Balmelli, Barghausen Consulting Engineers
Daniel Casey, Barghausen Consulting Engineers