21-104847-Site C_Response LU correction1_2022-04-01
April 1, 2022
Becky Chapin
City of Federal Way
Community Development Department
33325 8th Avenue South
Federal Way, WA 98003-6325
Re: Redondo Height TOD (Site C) – 27614 Pacific Highway South, Federal Way
Subject: File #20-104351-00-UP & 20-104353-SE; TECHNICAL REVIEW COMMENTS
Ms. Chapin,
I am writing to respond to the Technical Review Comments, dated March 22, 2022 as indicated below.
Community Development – Planning Division
Becky Chapin, (253) 835-2641, becky.chapin@cityoffederalway.com
1. Technical comments made about an item on one sheet may necessitate changes to other related sheets
and related documents, and 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. Revisions to address the comments below may result in further
additional comments and may require further plan revision to meet applicable requirements.
Applicant Response
Acknowledged.
2. Retaining Wall – Sheet L. 1501 of the landscape plan depicts a retaining wall along Pacific Hwy South. It is
hard to tell if that is within the right-of-way or on private property. If on private property, provide
sections and details of proposed retaining walls that indicate material, and overall height. Refer to FWRC
19.120.120, retaining walls shall be set back a minimum of three feet from adjacent public rights-of-way
and include a minimum of three feet of landscaped setback at the base. Per FWRC 19.120.120(6), if
private agreements are reached with utility companies and written documentation is provided to the city,
and a minimum three-foot wide planting buffer can be established and maintained to screen the wall
from view, retaining walls can be located to the back of the right-of-way as determined by the community
development services and public works directors.
Applicant Response
Acknowledged. Applicant intends to reach agreements with private utility companies to construct
wall within existing easements. Written documentation shall be provided to the city. As shown on
Detail 13 Sheet L1504c, a minimum 3’ wide landscape planter is proposed between the back of
sidewalk and face of wall. Per FWRC 19.120.120(6), Applicant will request proposed wall be
located at back of right-of-way pending approval by community development services and public
works directors.
Redondo Heights TOD – Responses to Technical Review Comments
Page 2 of 5
3. Smoking Area – If smoking is prohibited within the units, designated smoking areas shall be provided
for the proposed development. The smoking area shall not be visible from the public rights-of-way
and must be clearly depicted on the site plan.
Applicant Response
Smoking is prohibited within the units and buildings. A designated smoking area is depicted on
the site plan. See L1501c.
4. BLA Required – A boundary line adjustment (BLA) to consolidate multiple parcels and/or remove
interior lot lines is required. Prior to issuing building permits, a BLA must reconfigure the existing
lot lines, or remove the lot lines. The BLA application must be submitted, approved, and recorded
prior to the issuance of any building permits.
Applicant Response
Acknowledged. BLA process is underway. Applicant understands no building permit will be
issued until the BLA is submitted, approved, and recorded.
5. School Access Analysis – A school access analysis is required to be submitted to the city with the
Process III application. 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.
Applicant Response
A school access analysis has been completed for the proximate elementary school within less than
1 mile of the project. All other public school access would continue as currently provided via the
existing school bus stop within the transit lane on SR 99 that serves the Silver Shadows Apartment
complex.
6. Affordable Units – A covenant or other document with form and content to be approved by the City
Attorney regarding affordable housing must be recorded prior to occupancy of any buildings as required
by FWRC 19.110.010.
Applicant Response
Acknowledged. Documentation is underway. Applicant understands it must be recorded prior to
Occupancy of any building.
Public Works – Development Services Division
Kevin Peterson, kevin.peterson@cityoffederalway.com
1. Given the scope of the project: 72 residential units, a 3,000 SF office, and 6,500 SF food bank, the
solid waste and recycling (SWR) facility appears to be extremely inadequate. Refer to FWRC Section
19.125.150 for the SWR enclosure requirements. The applicant should provide some additional
details on the plans that show the SWR area, and provide a narrative as to how all users will access
the enclosure area as well as how the waste management company will collect the trash and recycling;
Applicant Response
Building 4 residential floors all have and a storage room for recycle storage (X25) and a trash
chute (see room x22 on A2 series sheets) which deposits solid waste in the Solid Waste and
Redondo Heights TOD – Responses to Technical Review Comments
Page 3 of 5
recycle (SWR) storage area located on the below grade P1 parking level (see sheet A-2-P1). The
Solid Waste and Recycle storage room includes a compactor for garbage, compacted solid waste
containers, recycle containers, and food waste container. The total storage area exceeds FWRC
19.125.150 requirements. See sheet A0-2.1-4 for proposed waste/recycle storage area
summary.
On collection days, management staff move the containers from the P1 parking level with a
motorized tug to the staging/pickup area, located east of building 4, on Site B. See site plan
C1.0c. Enclosure and screening are provided per FWRC 19.125.150. See revised L1501c for
screening and A4-2.2 for enclosure details.
Solid waste from Building 5 Office is stored within Building 5 and also taken to the above
Staging/pick up area for pick-up.
Building 4 Retail (Food Bank) Food Waste is stored in the Food Bank cooler and sent back to the
distribution center on the Food Bank owned Delivery Trucks for composting at the two farms
owned by the food bank. Recycling is stored inside the Food Bank an also taken back to the
distribution center on Food Bank owned delivery trucks. Due to Food Bank re-use processes,
garbage is very limited, however a covered area adjacent to the truck load (see sheet L1501c)
has room for 3 EA CY containers that, if needed, will be moved to the hatched staging area south
of the load dock on for the food bank delivery truck to pick up.
Site B waste/recycle storage is under a separate permit (with site A).
2. On the civil plans, provide the following areas:
a. Total site area
b. Total NEW impervious area
c. Total existing impervious area to be replaced
d. Total NEW + Replaced impervious area
Applicant Response
See revised sheet C1.00c for added total site areas and noted impervious areas under “Project
Information.”
Public Works – Traffic Division
Soma Chattopadhyay, soma.chattopadhyay@cityoffederalway.com
1. The Super market tip generation is different from Food Bank. Food Bank will not generate any
internal capture and will have less pass by trip than Super market. Super market peak hours and trip
generations are different than Food bank. Please clarify how these two land use types are considered
similar nature.
Applicant Response
The Limited Scope TIA has been updated to provide documentation of the differences between a
typical supermarket use and the proposed food bank. The analysis is considered highly conservative
as the foodbank would typical generate limited PM peak hour trips given its limited operating hours.
2. Please note that the city calculates traffic impact fee which depends on land-use and trip
generation. ITE does not have trip generation for Food Bank. City will be using the same land-use
which the applicant is submitting. Hence it may result in higher fees as a Super market compared
Redondo Heights TOD – Responses to Technical Review Comments
Page 4 of 5
to Food Bank.
Applicant Response
The Limited Scope TIA has been updated to provide documentation of the differences between a
typical supermarket use and the proposed food bank. The analysis is considered highly conservative
as the foodbank would typical generate limited PM peak hour trips given its limited operating hours.
Payment of impact fees are not due until a building permit is issued. Further documentation to support
the actual trip generation of proposed foodbank use will be provided by applicant.
3. A minimum driveway throat length of 40 feet is required as measured from the face of curb to the
first conflicting drive or parking aisle. (Public Works Development Standards - 3.2.14 A
Driveways- General 10). Adequate throat length is required to accommodate 95th percentile queue
length. Please show that the proposed south driveway has at least 40 ft. throat length.
Applicant Response
The revised site plan provides minimum 40 feet driveway throat per Public Work standards.
See dimensions on revised site plans C1.0c.
The following comments regarding the parking assessment prepared by TENW, Inc. were provided via
email on February 18, 2022.
1. It appears the selected many sites are multifamily housing without retail use. Also parking studies are
very old. It is staff understanding that the proposed project is a mixed-use development and as such
the selected study sites should be similar use in term of retail use, housing units, transit service (daily
and hourly headway) within ¼ mile, available amenities, monthly rental, parking charge, etc.
2. The parking data should be collected for at least two days duration in order to account for any
abnormally. Furthermore, the count should be collected outside of the holidays travel period to
better reflect realistic parking demand.
3. Provide document how the peak period weekday between 8 p.m. – 9 p.m. and weekend peak period
between 6:00 a.m. – 5:00 a.m. were selected for the study sites and also identify if weekday or
weekend is the peak period for multifamily housing. Per ITE Parking Manual, the peak period
parking demand for Multifamily Housing (LUC 221) is between 10:00 p.m. to 5:00 a.m. and
according to Urban Land institute 7PM to 5PM. In order to capture each site peak demand, the
counts of number of parked vehicles should be conducted once per hours over that period. All count
data used to generate the report should be included in the back.
4. Provide average rate and 85th percentile rate for the study sites. Parking demand for the
development should be calculated at the 85th percentile.
5. Parking inventory for each selected site should identify parking spaces allocated for visitors, office
staff, handicapped, truck loading/unload parking spaces. These spaces should not be included in
the total available tenant parking spaces.
6. Provide available off-site/on-street parking capacity for each site and identify how many are
utilized for each site. The analysis should also identify any potential available off-street parking for
the proposed development.
7. ITE parking data is based on the 85th percentile demand whereas the sampled sites utilized the
average of peak period.
Redondo Heights TOD – Responses to Technical Review Comments
Page 5 of 5
8. Parking requirements for multifamily comparison from nearby jurisdictions should not be included
in the parking analysis. The four comparable sites are adequate to establish reasonable parking
demand for the development. Furthermore, Seattle, Issaquah, Mill Creek, Mukilteo and Lynwood
would not be comparable to Federal Way in term of transit services, employment density, etc.
Applicant Response
See attached responses from TENW.
Federal Way Police – Crime Prevention
Lindsey Sperry, lindsey.sperry@cityoffederalway.com
Preliminary Technical
1. The Police Department is always concerned about adequate parking, especially when there will be a
daycare and food bank at the location. Although ‘parking studies’ often show what an adequate
number of stalls is, we are finding that most of these complexes are not even close to having the
actual amount of parking necessary for residents. Our concern is the lack of parking will increase
illegal parking issues at the park and ride and neighboring businesses.
Applicant Response
Extensive analysis and thought have been given to this important subject. Per parking study
provided by TENW, the parking stalls provided are more than sufficient for this development.
Please see Parking Study, dated 3/23/2022.
2. Verify if this complex will have security camera’s around the property. We would suggest that
they do. We would also like to see more plans for the security of the parking garage.
Applicant Response
Acknowledged. Security cameras will be provided around the development, including parking
garage.
3. The Police Department will need to coordinate codes or key card access to the buildings in
case of emergency’s (similar to the access Fire is provided).
Applicant Response
Acknowledged. Police Department access key and access to each building will be provided.
Please contact me with any questions or comments.
Sincerely,
Mancong Lin, AIA
Cc: Len Brannen, SRI
Mark Simpson, Bumgardner
Tom Jones, KPFF
Alex Shkerich, Communita Atelier
Michael Read, TENW
Kevin Peterson, FW Public Works
Soma Chattopadhyay, FW Traffic
Lindsey Sperry, FW Police
MEMORANDUM
Public Works Department
DATE: 1/25/2022
TO: Becky Chapin
FROM: Soma Chattopadhyay, Traffic Engineer
SUBJECT: Redondo Heights TOD Site A PARKING ASSESSMENT - (21-104847)
27454 Pacific Highway S
The Public Works Traffic Division has completed the review of the parking assessment prepared by
TENW, Inc. submittal and provides the following technical comments:
1. It appears the selected many sites are multifamily housing without retail use. Also parking
studies are very old. It is staff understanding that the proposed project is a mixed-use
development and as such the selected study sites should be similar use in term of retail use,
housing units, transit service (daily and hourly headway) within ¼ mile, available amenities,
monthly rental, parking charge, etc.
TENW RESPONSE: CONSISTENT WITH ITE PRACTICE, PARKING STUDIES OF INDIVIDUAL USES
WERE INCLUDED OF LOCAL STUDIES. THESE STUDIES CONCLUDE A HIGHER PARKING DEMAND
THAN THE CURRENT EDITION OF ITE RATES WHEN LIGHT RAIL WILL BE AVAILALBLE, AND AS
SUCH, ARE CONSERVATIVE TO DEMONSTRATE ADEQUATE SUPPLY ON-SITE.
2. The parking data should be collected for at least two days duration in order to account for any
abnormally. Furthermore, the count should be collected outside of the holidays travel period to
better reflect realistic parking demand.
TENW RESPONSE: CONSISTENT WITH ITE PRACTICE, PARKING STUDIES OF LOCAL SITES WERE
PERFORMED ON TWO WEEKNIGHTS AND A WEEKEND.
3. Provide document how the peak period weekday between 8 p.m. – 9 p.m. and weekend peak
period between 6:00 a.m. – 5:00 a.m. were selected for the study sites and also identify if
weekday or weekend is the peak period for multifamily housing. Per ITE Parking Manual, the
peak period parking demand for Multifamily Housing (LUC 221) is between 10:00 p.m. to 5:00
a.m. and according to Urban Land institute 7PM to 5PM. In order to capture each site peak
demand, the counts of number of parked vehicles should be conducted once per hours over that
period. All count data used to generate the report should be included in the back.
TENW RESPONSE: ADDITIONAL DOCUMENTATION IS INCLUDED IN THE PARKING STUDY ON
MULTIPLE PERIODS TENW SURVEYED TO DETERMINE PEAK PERIODS OCCURING IN THE EVENING
(AFTER 8PM). THE 2 SURVEYS CITED BY ITE IN PARKING GENERAL MANUAL ARE TOO SMALL OF
A SAMPLE TO DRAW ANY CONCLUSIONS AND NOT CONSISTENT WITH SHARED PARKING DATA
PUBLISHED BY THE ULI.
4. Provide average rate and 85th percentile rate for the study sites. Parking demand for the
development should be calculated at the 85th percentile.
TENW RESPONSE: CONSISTENT WITH ITE PRACTICE, NO FURTHER ADJUSTMENTS TO THE
AVERAGE RATE DEVELOPED ARE REQUIRED. FURTHERMORE, OUR SURVEYS ARE ADJUSTED
HIGHER THAN OBSERVED RATES TO ACCOUNT FOR OCCUPANCY AND GARAGE STALLS THAT
COULD NOT BE OBSERVED.
5. Parking inventory for each selected site should identify parking spaces allocated for visitors,
office staff, handicapped, truck loading/unload parking spaces. These spaces should not be
included in the total available tenant parking spaces.
TENW RESPONSE: ALL SURVEYED STALLS WERE RESIDENT/GUEST ONLY CONSISTENT WITH ITE.
6. Provide available off-site/on-street parking capacity for each site and identify how many are
utilized for each site. The analysis should also identify any potential available off-street parking
for the proposed development.
TENW RESPONSE: ADDITIONAL DATA ON AVAILABLE OFFSITE/STREET PARKING AND TRANSIT
SERVICES ARE INCLUDED.
7. ITE parking data is based on the 85th percentile demand whereas the sampled sites utilized the
average of peak period.
TENW RESPONSE: SEE RESPONSE TO COMMENT 4 ABOVE.
8. Parking requirements for multifamily comparison from nearby jurisdictions should not be
included in the parking analysis. The four comparable sites are adequate to establish reasonable
parking demand for the development. Furthermore, Seattle, Issaquah, Mill Creek, Mukilteo and
Lynwood would not be comparable to Federal Way in term of transit services, employment
density, etc.
TENW RESPONSE: SEVERAL OF OUR PREVIOUS SITES HAVE BEEN EXCLUDED FROM THE LOCAL
DATA TO REPRESENT CONSISTENT LAND USE MIX, DENSITY, AND TRANSIT SERVICES.