Smith Brothers Technical CommentsCOMMUNITY DEVELOPMENT DEPARTMENT 33325 8th Avenue South Federal Way, WA 98003-6325
253-835-7000
www.cityoffederalway.com
Jim Ferrell, Mayor
September 15, 2021
Mr. Ben Eldridge
Barghausen Consulting Engineers
18215 72nd Avenue South
Kent, WA 98032
beldridge@barghausen.com
Re: File #21-102066-00-UP; TECHNICAL COMMENTS
Smith Brothers Farms, 34520 9th Avenue South, Federal Way
Dear Mr. Eldridge:
City staff has completed review of your Process III Master Land Use (MLU) application for the Smith Brothers
Farms Distribution Center. The proposal is for an approximately 55,000 square foot dairy product distribution
building and associated site improvements. The application was deemed complete on July 14, 2021.
TECHNICAL COMMENTS
The following comments provided by staff reviewing your project must be addressed prior to land use approval.
Please direct questions regarding any of the technical comments to the appropriate staff representative.
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 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(s) to meet the applicable requirements.
2. Site Plan – Remove the reference to the expansion on the site plan as a phasing plan has not been
proposed. A separate land use review process will 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. These would include, but not limited to, written
explanation of the timing of the expansion/phasing, elevations, site plan, and landscape plans for the
Phase 2, future expansion building.
Mr. Ben Eldridge
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3. Building Height – Please refer to the “Average Building Elevation (ABE)” and “Height of Structure”
definitions in Federal Way Revised Code (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 divided 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 the
FWRC needs to be shown, not just the four corners of the building.
4. Parking Area Design – Dimensions are not provided for the compact spaces or drive isle width where the
nine compact spaces are provided. Provide dimension to verify compliance with the city’s Parking Lot
Design Criteria handout.
5. Landscaping – This is not a complete technical code-based review of the landscape plan. 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 22 square feet of Type IV landscaping per parking
stall when 50 or more parking stalls are being provided.
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
meets this requirement as two rows of trees interspaced is required. Refer to FWRC 19.125.050(2),
Figure 4, below.
c) The landscape along the property line of the intersection at South 344th Street and 9th Avenue South
has large gaps of trees missing in the required 10-foot buffer.
d) The city understands that there is a sewer easement along the south property line. There is a list of
approved trees that Lakehaven Water & Sewer District allows within easements (enclosed). The
Mr. Ben Eldridge
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21-102066-00-UP Doc. I.D. 81617
landscape plan must be revised to include the 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.
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 the 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.
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.
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 the 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).
b. Identify materials and designs of any retaining walls visible from the right-of-way or adjacent properties.
c. Provide a detail of the proposed fence.
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 west façade includes
building modulation with a depth of ** feet deep and ** feet wide. This facade also includes a canopy
for ** percent of the façade.”
b. Identify specific methods of façade articulation and scale for each building facade pursuant to FWRC
19.115.060(3).
c. Provide pedestrian connections from both rights-of-way to the main entrance. A delineated
pedestrian connection from South 344th Street to the main entrance 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).
8. Solid Waste and Recycling - No details regarding the solid waste and recycling storage area was 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).
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 the ground mounted
and rooftop equipment, if any.
Mr. Ben Eldridge
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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 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 storage yards, service yards, loading areas, mechanical or electrical equipment, utility
installations, trash receptacles, etc.”
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.”
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 parcels is required. BLA approval is required at
the time of the issuance of building permits; buildings cannot be constructed over property lines. A BLA
is an administrative review process under FWRC 18.10. A BLA information handout is enclosed. Contact
the Permit Center at permitcenter@cityoffederalway.com or 253-835-2607 for the BLA application fee
and submittal questions.
SEPA Checklist
12. Background (7) – Include the approximate square footage of the future addition.
13. Background (11) – Include information regarding the phasing for the future addition.
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.
15. Land and Shore (8f) – The comprehensive plan designation of the site is Commercial Enterprise.
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.”
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.
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.
Mr. Ben Eldridge
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PUBLIC WORKS – TRAFFIC DIVISION
Sarady Long, 253-835-2743, sarady.long@cityoffederalway.com
Use Process III
1. Show the 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). Unless the Public Works Director approves or modifies the required improvement, the
applicant will be expected to construct street improvements consistent with the planned roadway cross-
sections as shown in Map III-4 in Chapter III of the Federal Way Comprehensive Plan (FWCP) and Capital
Improvement Program (CIP) shown as Table III-10 (FWRC 19.135.040).
• Ninth Avenue South is a Principal Collector planned as a Type “K” street, consisting of a
44-foot street with bike lane, 6-foot planter strips with street trees, 8-foot sidewalks, and
street lights in a 78-foot right-of-way. Assuming a symmetrical cross section, half street
improvements are required as measured from the street centerline. It appears the existing 39-
foot right-of-way will be adequate to accommodate the planned improvement.
• South 344th Street is a Principal Collector planned as a Type “R” street, consisting of a 40-
foot street with curb and gutter, 4-foot planter strips with street trees, 6-foot sidewalks, and
street lights in a 66-foot right-of-way. Assuming a symmetrical cross section, half street
improvements are required as measured from the street centerline.
2. At a minimum, two curb ramps at the 9th Avenue South/South 344th Street intersection will need to be
upgraded to meet the ADA. Additional mid-block curb ramps at the easterly property will be expected to
be installed as part of this project to meet the ADA.
3. The driveway width on South 344th Street is wider than the 30-foot 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 Public Works Director for consideration.
4. Adequate driveway throat length should be provided for safe and efficient traffic circulation. A 40-foot
throat length is recommended as measured from the face of curb (or edge of traveled way if no curb
exists) on the public street to the first conflicting drive aisle or parking movements that would conflict
with entering and exiting traffic.
5. Label the dimension of the driveway on the plan set.
6. Update sheet C1 of 10 to reflect the correct existing right-of-way width on 9th Avenue South. The
existing half street right-of-way is 39 feet as measured from the street center and not 30 feet as shown on
the plan.
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.
Mr. Ben Eldridge
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8. The truck circulation site plans (turning diagram) should be in the civil plans and not the architectural plans.
9. It appears the turning truck will mount the driveway curb within the internal site drive aisle; consider
modifying the driveway to accommodate a turning truck.
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).
11. Transportation 14.d – Half-street improvements to 9th Avenue South and South 344th Street are required
per code. However, the applicant may submit a modification request to modify or waive these
improvements. This section will need to be update to reflect the Public Works Director’s decision if a
modification request is submitted.
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 stormwater management, per FWRC 19.125.150.
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 six-feet below existing grade (2.5 feet above the “design”
groundwater elevation), and per the requirements of the 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.
3. A revised Technical Information Report (TIR) 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 Avenue South.
LAKEHAVEN WATER & 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.
2. As previously noted, the applicant will need to apply for either a 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.
Mr. Ben Eldridge
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SOUTH KING FIRE & 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 need to connect to the yard FDC.
2. A wall mounted FDC is acceptable if desired.
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 the revised application materials as appropriate, by electronic
submittal (Document Upload Link or https://www.cityoffederalway.com/node/4588), a letter explaining
how these comments have been addressed, and the completed “Resubmittal Information Form” (enclosed).
Please note, the original plan review fee collected at submittal of your permit covers the initial review and one
resubmittal. Commencing September 1, 2021, the city has begun charging applicants for any additional staff
time necessary to complete each review following the first resubmittal. The resubmittal fee will be collected at
the time a land use decision is issued.
If you have any questions regarding this letter please contact me at becky.chapin@cityoffederalway.com, or
253 835-2641.
Sincerely,
Becky Chapin
Senior Planner
enc: Public Comment Letter
Acceptable Landscape Trees Within Lakehaven Easements
BLA Submittal Requirements
Resubmittal Information Form
c: Kevin Peterson, Senior Engineering Plans Reviewer
Sarady Long, Senior Transportation Planning Engineer
Brian Asbury, Lakehaven Water & Sewer District
Sean Nichols, South King Fire & Rescue
Scott Hougham, KGIP, shougham@kgip.com
Dustin Highland, Smith Brothers Farms, dhighland@smithbrothersfarms.com