HomeMy WebLinkAboutPlanning 2018-12-13 Item 3 - Staff Report - Justice Center Conditional Use and Design Review (Public Safety Plan)Requests:
Allan Ekberg,
Staff Report to the Board of Architectural Review
Prepared December 5, 2018
Conditional Use Permit and Design Review approval of the Tukwila
Justice Center and accessory public recreation use in the north parking
lot
Hearing Date: December 13, 2018
Notification:
yoI
On October 10, 2018, a notice of application was issued and mailed to all
property owners and tenants within 500 feet of the subject property and
posted on site. A notice of application was sent to all potentially
interested agencies on October 31, 2018. A notice of hearing was sent to
all agencies and property owners and residents within 500 feet and
posted on site on November 5, 2018. On November 7, 2018, the Seattle
Times and City of Tukwila Legal Notice section included the notice of the
public hearing.
File Number: L18-0088 and L18-0096
Applicant: Rachel Bianchi for the City of Tukwila
Owner: City of Tukwila
Associated Permits: SEPA
Special Permission
Building, mechanical, electrical and sign permits
Proposed Address:
Parcel Numbers:
15001 Tukwila International Boulevard
0041000515; 004100514; 0041000480; 0041000494; 0041000513;
0041000516; 0041000517; 0041000335; 0041000330
Current addresses 14835, 14845, 15001-15029 Tukwila International Boulevard; 3415 S 150th
Street; 15006-15045 Military Road S.
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Comprehensive
Plan/ Zoning
Designation: Regional Commercial (RC)
Sepa Determination: Determination of Non -Significance issued on November 29, 2018.
Staff: Moira Bradshaw
Attachments:
A. Vicinity Map
B. Zoning Map
C. Applicant's response to Conditional Use Permit Criteria
D. Plans - Civil, Site, Landscape, Elevations, Furnishings
E. Site Lighting Calculations Plan
F. City of SeaTac SEPA comments
G. AM/PM Trip Generation Analysis Justice Center (Fehr & Pers 11/26/18)
H. Applicant's response to Design Review criteria
I. Roof top mechanical study from Tukwila International Boulevard
J. Lighting Fixture images
K. Site Plan showing location of recommended conditions
REPORT ORGANIZATION
Following a project description and site information, the report is divided into two sections: section
one is for analysis of the conditional use permit and section two is analysis of the design review
request. In each of these sections, the proposal is compared to the specific criteria for approval.
Conclusions follow each section.
The Consolidation of Permit Applications section in the Permit Application Types and Procedures
Chapter of the Zoning Code (TMC 18.104.030) allows for permit applications related to a single project
to be bundled together in a consolidated hearing and approval procedure. The procedures for the
highest numbered land use decision related to the project are used. A conditional use permit is a Type
3 land use decision made by the Hearing Examiner. Design review is a Type 4 decision made by the
Board of Architectural Review. The Conditional Use Permit and Design Review requests will both be
decided by the Board of Architectural Review in an open record public hearing on December 13, 2018.
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FINDINGS
VICINITY/SITE INFORMATION
Project Description
The proposal is to build approximately 48,000 square feet of municipal office building that will
house the Police Department, Municipal Court, Emergency Operations organization and public
conference rooms as well as needed site improvements for circulation, parking, storage and
landscaping. The north parcel is a stand-alone parking lot that will provide parking for the public
and possibly auxiliary uses such as public recreation and farmers markets.
The 3.9-acre site is comprised of nine existing parcels in two separate blocks separated by S.
150th Street. The building, along with the associated site improvements of parking, fencing,
landscaping and utilities, are proposed in the north half of the block bounded by Tukwila
International Boulevard, S. 150th Street, Military Road and S. 152nd Street.
A public parking lot and an area for potential future auxiliary public uses is located on an "L"
shaped site to the north of S. 150th Street. The applicant indicates that when the public parking
lot is not in use for the Justice Center, it could be used for other public activities such as a
farmer's market and 3 on 3 youth basketball tournaments. A Farmers Market is a permitted use
as retail sales of food, public recreation is allowed as a conditional use in the RC zone.
Subject Property and the Surrounding Land Uses
Figure 1 Vicinity Map - looking north from above SR 518
The properties straddle S. 150th Street along the west edge of Tukwila International Boulevard.
Surrounding the north property is Church by the Side of the Road, Olympus Printing, El
Matador apartments, China Pavilion restaurant and a convenience store.
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The south parcel has a fast food restaurant along its southern edge and a bank is south of the
restaurant. Other uses in the vicinity include auto -oriented uses, a school, public facilities for
sewer and water districts, residential and commercial services and retail.
The preexisting uses of the property consist of a former motel, restaurants, food markets,
commercial services, adult entertainment and one house.
The boundary between the Cities of SeaTac and Tukwila follows the east edge of the Military
Road S. right of way. A Zoning Map of the area is Attachment B.
Section 1: Conditional Use Permit Criteria
The Land Use Table (Figure 18-6 Land Uses Allowed by District) lists "Fire & Police Stations"
and "Parking areas, for municipal uses and police stations" as conditional uses in Regional
Commercial (RC) districts.
The proposed project must comply with criteria detailed in the Conditional Use Permit Chapter
of the Tukwila Municipal Code (TMC 18.64.050).
The applicant's response to the conditional use permit criteria is Attachment C to this staff
report. Staff makes the following findings using the Code's conditional use permit criteria (TMC
18.64.050) listed in italics:
1. The proposed use will not be materially detrimental to the public welfare or injurious to the
property or improvements in the vicinity.
The Emergency Operations Center is currently located at Fire Station 51 in the Southcenter
neighborhood, the other uses currently exist in the City of Tukwila at 6200 Southcenter
Boulevard. The proposal is to move those uses and consolidate them at this new site. The
current location for the Police and Court operations is along the Southcenter Boulevard
corridor where they coexist with offices and commercial services adjacent to low and medium
density residential.
The new location for these civic uses is more intensively developed with commercial service
and retail uses. The long-term future for the area is to incorporate higher density residential
mixed with retail and commercial uses as the site is close to the Tukwila International
Boulevard Station.
Fire Station #47 previously provided emergency response from 3215 S. 152 Street but recently
closed. Fire Station #54 is at 4237 S. 144th Street.
The applicant has said that other uses could be programmed for the north parcel such as a
farmer's market, and 3 on 3 basketball. The impacts associated with the predominately office
nature of the use includes peak am and pm traffic. There will also be emergency response by
police vehicles and the transportation of suspected and convicted criminals to jail or to Court.
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Two "sally ports," which are secure passages for the movement of prisoners, are included in
the proposed use. The current design shows one sally port adjacent to holding cells in the
Police section of the building and the second one adjacent to the Courtroom. The sally ports
are enclosed with a ten -foot -high opaque fence and automatic gates. (Sheet A5.4, Attachment
D) The parking area for staff is encircled with a six -foot -high perimeter fence along the north,
west and south property edges of the south parcel and has automated sliding gates over the
driveway entrances. Two -foot tall concrete walls are proposed along the east and north edges
of the building. (Sheet L8.02)
New frontage improvements are proposed along S. 150th Street that extend beyond the
frontage of the proposed development. The northwest corner of the intersection of S. 150th
Street and Tukwila international Boulevard will be improved with curb, gutter, sidewalk, storm
drainage as part of this project. Historic access and parking for the business will shift from in
front of the building (between the sidewalk and the building front) to on -street.
Figure 2 NW corner S. 150th Street and Tukwila International Boulevard
The applicant states that the City has been working with the surrounding businesses to
coordinate development of the project. The applicant acknowledges that "the business'
existing garbage /recycling area will need to be accommodated and relocated. The City and its
design team will work with the business to find a new location forgarbage/recycling, either in
their parking lot north of the restaurant or on the City's north lot. Similarly, the city and its
design team will work with them on parking/access modifications to ensure they can continue
to operate during and after Justice Center development and frontage improvements. These
issues have not been resolved at this time."
2. The proposed use shall meet or exceed the same standards for parking, landscaping yards and
other development regulations that are required in the district it will occupy.
Parking
A parking standard for police stations is not listed in the Off-street Parking Regulation Chapter
City's Zoning Code; therefore, a Type 2 decision by the Director of Community Development is
required. Per the Uses Not Specified section (TMC 18.56.100,) the parking standard shall be
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based upon the requirements of the most comparable use specified in the Code. The Director
issued a Determination that 148 stalls is the minimum number required for the police station
and municipal offices. The bicycle parking requirement is four. The proposal exceeds that
minimum standards. A total of 105 stalls for employees are proposed on the south lot; a total of
100 stalls are proposed for the general public on the north lot.
The International Building Code states that "accessible parking must be located on the
shortest accessible route of travel and wherever practical must not cross lanes of vehicular
traffic. Where crossing traffic lanes is necessary, the route shall be designated and marked as a
crosswalk." Accessible parking is provided in both lots, the staff and the public lot, as well as in
S. 150t" Street and the City's Building Official and determined that the proposal meets Code.
Height and Setbacks
In addition to minimum off-street parking requirements, minimum structure setbacks and
height maximums of 3 stories or 35 feet are specified for the RC zone. The north parcel has no
structures. On the south parcel, the ten -foot tall sally port fences and the building are subject
to the setback standards. The structures meet the setback requirements except for the canopy
over the public entrance on the Tukwila international Boulevard frontage. Staff is
recommending approval of a waiver of the front yard setback. Waivers are allowed for
pedestrian oriented amenities and is subject to a Board of Architectural Review decision.
(Sheets L1.01 & A5.1, Attachment D)
The tallest portion of the building is 33 feet. Fences up to six feet and walls up to four feet are
exempt from the yard setbacks. (Yard Regulations TMC 18.50.070)
Landscape
The Landscape Chapter of the Zoning Code (TMC 18.52) was updated in 2017. Standards exist
for:
■ Landscape perimeter depths and plant palette;
■ Parking lot landscaping standards, including amount of landscaping, landscaping
location, and plant palette;
■ Streetscape landscaping;
■ Ground level mechanical and recycling/trash screening;
■ Significant tree retention;
■ Plant material requirements; and
■ Soil preparation.
Landscape perimeter depths and plant palette
10-foot deep Type 1 perimeter front yard landscaping is proposed along all street fronts
including Military Road S., S. 150th Street and TIB. The standard calls for a mix of deciduous
and evergreen trees but the proposal shows only deciduous. (Sheet L5.11, Attachment D)
Six feet deep, Type II side yard landscaping is required along the south property line on the
south parcel and the at four locations on the north parcel. The standard calls for a mix of
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deciduous and evergreen trees but the proposal sometime includes no trees and in others only
includes deciduous.
Figure 3 Side yards on north parcel
Parking Lot Landscaping standards
Trees must be evenly distributed; landscape islands must be a minimum of 6 feet by 100
square feet in area and protected from damage by cars; landscape islands must be used every
10 parking stalls and at the end of every row of parking. A minimum of 20 square feet of
landscaping per stall is required. The Landscape Architect calculates that the minimum
square footage is met.
There is an even distribution of trees in the two lots and the landscape islands meet the
minimum dimensions. On the north parcel, there is a row of 14 stalls that does not have
parking at either end and there is not a landscape island after 10 stalls. A second row of 15
stalls adjacent to the back of the China Pavilion is also not broken up by a landscape island.
On the south parcel, there three rows of more than 10 stalls.
Streetscape Landscaping
Minimum separation from utilities, driveways, transformers, curbs, must be provided.
Ground level mechanical and garbage
Ground level mechanical equipment and garbage storage areas shall be screed with evergreen
plant materials and or fences or masonry walls. Sheet L1.01 on Attachment D shows that on
the south parcel there is an emergency back up generator and an electrical vault in the
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northwest corner of the Court's sally port. The electrical vault (El) is adjacent to S. 150th Street
and the back-up emergency generator (E3) is prominently located with minimal screening.
Significant Trees
Significant trees located within any required landscape area that is not a safety hazard shall be
retained and protected during construction. Although a complete survey of the site is not
included, there are two significant oaks behind the sidewalk on TIB that are not incorporated
into the landscape plan.
Plant materials
Native species or species with low water requirements that are adapted to the Pacific
Northwest are required with numerical species maximums. The species diversity maximum for
trees is exceeded for Hazelnuts.
Soil materials
Structural soils are not noted but is a requirement that must be used to a depth of 36 inches
with minimum soil volumes of 750 cubic feet per tree.
Supplemental Development Standards
Lighting capable of providing adequate illumination for security and safety that is in scale with
the height and use of the associated structure is required. Any illumination must be directed
away from adjoining properties and streets. (Light Standards, TMC 18.50.170)
A lighting site plan (Sheet ES1.1, Attachment D) and a Site Lighting Calculations Plan
(Attachment E) have been provided.
96 square feet of recycling storage space is required, and the outdoor collection point may not
be in a required setback or landscape area. In addition, the collection point many not be
located so that hauling trucks obstruct pedestrian or vehicle traffic on or off site. (Recycling
Storage space for non-residential uses, TMC 18.50.185.) The Code further specifies that the
collection point must have an opaque wall or fence of sufficient size and height to provide
complete screening and that the architectural design is consistent with the design of the
primary structure. (Design of Collection points for garbage and recycling containers TMC
18.50.190)
The site plan shows an adequately sized space on the site plan along the southwest corner of
the building and has indicated that the design of the enclosure will use the same metal
cladding to be used on the building. Height of the enclosure hasn't been provided.
3. The proposed use shall be compatible generally with the surrounding land uses.
The surrounding area is characterized by low scale small businesses; gas stations, fast food,
community uses, such as a school and church; and housing. The purpose of the RC zone, in
which the Justice Center will locate, is to provide for an area of high intensity regional uses
such as commercial services, offices, lodging, entertainment and retail activities along a
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regional transportation corridor. The proposed municipal functions of the proposal are the
similar in character to some of the other uses allowed in the zone. Other high intensity uses
permitted outright include bus stations, automotive services, fraternal organizations, light
manufacturing uses, bowling alleys, and night clubs. The unique aspects of the police station
can be compatible given the high intensity uses also allowed in the zone and the nature of the
transportation system that is adjacent to the site.
4. The proposed use shall be in keeping with the goals and policies of the Comprehensive Land
Use Policy Plan.
The Comprehensive Plan's goal statement for the Tukwila International Boulevard District is to
be a complete neighborhood with a thriving multicultural, residential, and business
community with vibrant places to live, work, shop and play. That the District is a safe and
walkable destination with an authentic main street character that connects to other
destinations.
The land use goals further state that the aspiration is for the corridor to transform into a place.
A place that one travels to rather than through. The narrative and policies highlight the desire
for a more walkable people place rather than an auto -oriented place.
The Economic Development Chapter Policy 2.1.6 says, "Leverage capital improvement funds to
encourage in -fill, land assembly, redevelopment and land conversion for family -wage jobs, but
only if concurrent with substantial private actions."
The Tukwila International Boulevard Policy 8.6.1 says, "Establish a more walkable and
connected street network through the TIB district by investing in public sidewalks and
requiring private redevelopment projects to organize site plan elements to allow for through
connections."
The Comprehensive Plan's Capital Facilities chapter requires adequate public facilities to serve
the growth in households and jobs in the City. The Tukwila Comprehensive Plan adopts service
standards and meeting those standards requires adequate space for public safety, planning for
emergencies and emergency preparedness, and hearings and decisions on violations of local
laws.
5. All measures shall be taken to minimize the possible adverse impacts which (sic) the proposed
use may have on the area in which it is located.
The City of SeaTac, during SEPA review, requested additional traffic information on the project
after reviewing the number of daily trips anticipated for the project. (Attachment F) A more
detailed AM and PM peak trip analysis was done that found that PM peak trips will be less than
the number of trips generated by the current development of the sites. AM peak trips will be
increased by 75% because of the office nature of the proposed use. (Attachment G)
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In addition, the proposed facility is in a block that is bordered by north south minor and
principal arterials, Military Road S. and Tukwila International Boulevard respectively. Within a
block and a half from the site are S. 154th/and Southcenter Boulevard - east west minor
arterials and State Route 518 access.
Parking supply exceeds the minimum required number of parking stalls so that motorists who
are accessing the Center do not become a nuisance. The north parking lot will only reach
capacity during days when there is an arraignment or a hearing. Perimeter fencing is included
on the south parcel to ensure that the police vehicles, City staff, prisoner transportation are
adequately secure. Operationally, the City has harmoniously coexisted adjacent to a
residential neighborhood at the current location along Southcenter Boulevard.
Conclusions
1. The proposed project will change the overall character of the site and its structures. The
proposed development will generally be the same scale of the surrounding development but
will have significantly more controlled vehicular access, landscaping and pedestrian
improvements. The proposed Justice Center parking areas are similar in scale to other parking
lots in the area.
2. The applicant has indicated they will resolve impacts to the two businesses at the northwest
corner of the intersection of S. 150th Street and Tukwila International Boulevard.
3. The proposed uses will not be materially detrimental to the public welfare or injurious to the
property or improvements in the vicinity. Noise associated with the Justice Center, that is
emergency response sirens, is exempt from the noise regulations, and has historically existing
in the area with Fire Station 47.
4. Operational management and protocols for scheduling uses in the north parking lot will
prevent any adverse impacts of multiple uses on the lot. Parking will be the primary use to
support the function of public parking for the Justice Center.
5. Noise from basketball tournaments or other recreation related uses would be limited to day
time use due to the lack of sports nighttime lighting.
6. The Landscape Plan shows that modifications would need to be approved or the plans revised
because some Code requirements are not met. Those standards are reviewed under the
design review application per the Request for Landscape Modifications criteria of the
Landscape Chapter (TMC 18.52.100) and the Tukwila International Boulevard Design Manual.
7. The proposed police station, municipal court, office use, public meeting space and outdoor
recreation space will be compatible with the surrounding land uses. Traffic from the uses can
be accommodated within the existing transportation network. An analysis of the difference in
trips generated by the proposed use and the existing uses shows that P.M. peak trips are less
with this facility. AM peak trips increase because of the office character of the use.
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8. The project will provide sidewalks where none currently exist on S. 150th Street and mid -block
on the south parcel thereby breaking -up the large blocks in the area and providing pedestrian
pass throughs. The new landscaping will support the low impact storm water goals of the City
and improve the visual environment and air quality.
9. The proposed use will not conflict with the goals and policies of the Comprehensive Plan.
Recommendation
The conditional use permit recommendation is combined with the design review recommendation
and conditions located at the end of Section 2.
Section 2: Design Review Criteria
This project is subject to Board of Architectural (BAR) design approval under the Regional
Commercial Design Review Section of the Tukwila Municipal Code (TMC 18.24.070.) The project
is subject to design criteria included in Tukwila International Boulevard Design Manual, which
is available on the city's website at http://www.tukwilawa.gov/dcd/apps/TUKWILA
INTERNATIONAL BOULEVARD Design Manual.pdf. For the applicant's response to the criteria,
see Attachment H.
The Manual is organized into four sections; covering Site Design, Building Design, Landscape
Design and Signs. Within each section are a number of subject areas, covering such issues as
pedestrian circulation, architectural relationships, planting design and sign placement. For
each subject area there are one or more Design Criteria that are general in nature. The Design
Criteria explain requirements for development proposals. They are the decision criteria by
which the Board of Architectural Review will decide whether to approve, condition or deny a
project. The Design Guidelines, which augment each Design Criterion, provide guidance to the
project applicant, to City Staff and to the BAR in determining whether the project meets each
Design Criterion.
. SITE DESIGN
A. Site Design Concept
The proposal is to orient the building to Tukwila International Boulevard and the accessory
uses of parking and storage to the west portion of the site fronting on Military and S. 150th
street. One driveway access onto Military Road S. and two driveways along the south side of S.
150th Street and one driveway access along the north side of S. 150th Street are proposed.
The existing Tukwila International Boulevard. streetscape improvements are proposed for
replacement, including the existing trees, walls, and sidewalks on the south and north parcels.
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B. Relationship to Street Front
The guideline recommends that a distinctive street edge be designed in order to create an
interesting pedestrian environment. The regulations require a 20-foot setback along Tukwila
International Boulevard, ten feet along S. 150th Street. These requirements can be waived if
they are approved as part of the overall design approval and pedestrian oriented space is
provided. Per the Tukwila International Boulevard Design Manual, pedestrian oriented space is
defined as "an area between a building and a public street that promotes visual and pedestrian
access onto the site and that provides pedestrian -oriented amenities and landscaping that
enhances the public's use of the space. A pedestrian oriented space is encouraged to have
landscaping or built in planters; site furniture, artwork or amenities such as pedestrian
weather protection or other enclosure such as an arcade." The applicant requests a waiver of
the standard setback for the proposed canopy. The canopy is 20 feet tall, placed over the
public building entrance, and extends ten feet from the building wall towards the public
sidewalk on Tukwila International Boulevard.
The guidelines go on to stipulate that all sidewalks in the neighborhood be a minimum of eight
feet wide and on TIB be 12 feet wide and that this depth include public landscaping. All the
frontages comply with the required minimum of eight feet of sidewalk including landscape
area.
C. Street Corners
The south parcel, the building site, has two corners - Military Road S. and S. 150th Street and
Tukwila International Boulevard and S. 150th Street. The intent of the guideline is to improve
access to buildings located on corner lots and increase prominence of buildings on street
corner.
The proposal places the building against Tukwila International Boulevard with the auxiliary
uses of parking and storage along the west half of the site. Transparent windows and the
public entrance face Tukwila International Boulevard with primarily blank walls and opaque
fencing on the S. 150th street front. In lieu of placing the building within 15 feet of the corner, a
walkway to the building entrance is proposed and at least 200 square feet of additional
landscaping is created per the guideline.
D. Continuity of site with adjacent sites
This criterion addresses continuity in building setback, structural massing, location of
circulation elements and landscaping to visually and functionally be compatible with adjoining
properties.
Sidewalks improvements will encircle the south block and include an additional east west
sidewalk, mid -block, creating continuity and improving circulation in the area.
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Through block sidewalks are also proposed on the north site to establish a future pattern that
will improve accessibility for the area.
On the south parcel, there are three adjacent buildings. Key Bank and Taco Time are
approximately 30 to 35 feet setback from Tukwila International Boulevard. The most adjacent
building, Taco Time, is an auto -oriented use. It does not provide an appropriate building edge
or mass to emulate. The proposed setback to TIB is more in keeping with the development
goals for this area. The design direction in terms of massing is for higher, more dense
developments as this location is within 1/2 mile of the Tukwila International Boulevard Station
and can support transit -oriented developments.
E. Shared Facilities
On the north parcel, curb cuts are shown between the site and the properties containing
Church by the Side of the Road and the China Pavilion. Bollards and parking stalls however are
shown preventing vehicular access between the properties.
F. Site Design for Safety
The guidelines suggest the following ways to improve site safety: Limiting the number of
locations where pedestrians might encounter vehicles and if their paths must cross provide
adequate site distance.
The south parcel has three driveways and the north parcel has one driveway. Other than staff,
all building visitors must use on -street parking or the north parcel. S. 150th Street is being
improved with a cross walk and street frontage improvements.
The City's Building Official has confirmed that the proposed accessible public parking in S.
150th Street meets the Building Code location criterion.
The driveway to the north parcel has 15 feet of additional concrete on both sides of the
driveway apron. Staff believes this will facilitate and encourage the public to use these paved
areas for mid -block crossings. The applicant explains that the pavement ensures sight
distance visibility for pedestrians using the sidewalk and drivers using the driveway; however,
similar treatments are not proposed adjacent to the three other proposed driveways.
Groundcover and low shrubs are as effective as pavement, support the City's low impact
development goals, and would be more of a deterrent for illegal mid -block crossing.
Motorists currently park and drive through and along the front of the Stop/Buy corner store
and China Pavilion, utilizing the paved area behind the TIB sidewalk and the front door to the
business. The frontage improvements on the north edge of the S. 150th Street will include a
new sidewalk along the southern edge of the building. The plans do not show how vehicles will
be prevented from traveling over the sidewalk from the north, as they currently do.
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The building is being designed so that minimal site surveillance will occur from inside the
building. Opaque windows and screens are being used in office areas. Observation of outdoor
on -site activities by building occupants will be minimal or not occur but will be possible by
passersby.
A 6-foot-high perimeter fence protects the Police, Court and EOC employees as well as Police
equipment. 10-foot-high sally -port fences enclose the transfer areas for suspected criminals.
Lighting fixtures and lighting levels provide a minimum of .2-foot candles per the Tukwila
International Boulevard Design Manual. The City's Crime Prevention Officer suggests an
increase to .8 with an average of 1.0 for areas where criminal activity could occur such as in the
northwest corner of the new public parking lot on the north parcel.
G. Siting and screening of service areas
The garbage and recycling area is located to the south side of the building away from the
adjacent streets. The applicant has indicated that it will be screened with the reddish
insulated metal material used on the building. An elevation showing the height of the
structure has not been submitted.
Mechanical equipment is located on the roof and may be visible from adjacent streets.
Attachment I is a study of rooftop mechanical visibility from Tukwila International Boulevard.
The other streets have not been analyzed. Mechanical systems are visible from the east side of
Tukwila International Boulevard.
H. Natural Features and Sensitive Areas
There are slight topography changes as evident in the cross sections, the land is generally
sloping down from north to south. (Attachment D) There are two significant oak trees behind
the Tukwila International Boulevard sidewalk on the north parcel. There are no other sensitive
features.
Along the Tukwila International Boulevard parking lot frontage, the proposal is to increase the
width of the sidewalk to 12 feet and the curb side landscaping to 5 feet. (Sheet C8.01,
Attachment D) Modifying the width of the sidewalk and landscaping would maintain continuity
with the adjacent sites and potentially allow preservation and incorporation of the significant
trees.
. Surface Stormwater detention facilities
Bioretention areas arranged in the parking lots and in areas adjacent to the building and
underground detention vaults are proposed for the site.
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. Pedestrian circulation
Sidewalks are provided to both the staff and public entries.
New frontage improvements are proposed along S. 150t" Street and will also be installed along
Military Road S. The existing frontage improvements along Tukwila International Boulevard
will be modified.
Through block sidewalks are proposed as part of the design in addition to the frontage
improvements. The south parcel will have a 6-foot-wide sidewalk along the south property line
adjacent to the Taco Time, thereby breaking up that block. The north parcel will have two
sidewalks that will begin breaking up that block into more walkable segments.
K. Pedestrian Amenities
The northeast corner of the south parcel will have a widened landscape area with light poles of
varying heights from 15 to 28 feet. (Attachment J) Banners may be attached to the light poles
to add color and graphic interest. Banners are allowed on city owned poles per the Permits
section, Exceptions - Sign Permits Not Required. (TMC 19.12.030)
On the Tukwila International Boulevard frontage on the south parcel, 240 linear feet of two -
foot -high concrete walls are aligned along the edge of the right of way and are broken up into
11 sections. The street side of the walls are landscaped but the building side are not, thereby
allowing access for seating. 39 benches are arrayed between the walls and the building.
Four, 10-foot-long by two -foot -high walls are also located between the accessible on -street
parking stalls and the public sidewalk on S.150t" Street.
Four u-shaped bike racks are located street side of one of the walls in front of the public entry.
See Sheet A 5.4, Attachment D fora detail of the bench.
. Vehicular Circulation
This criterion is to evaluate a proposal so that conflicts between pedestrians and vehicles is
minimized. The south parcel is shown with three access driveways - two from S. 150th Street
and one from Military Road S. and the north parcel with one from S. 150th Street. The applicant
states that the second driveway on S. 150th Street makes sense because a back-up area is
needed for entering or existing the sally port. The asphalt back-up area is proximate to the
street. Current access to the City Hall campus, where Police and Court is located, utilize two
for ingress and egress and one for ingress.
M. Parking
Required parking is divided between the building site and a separate site on the north side of S.
150t" Street. A special permission decision was made to determine the parking standard for the
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municipal facility using a combination of the office standard of 3 stall per 1,000 usable square
feet and 1 stall per 100 square feet of assembly area. The proposed design provides more
parking than the minimum requires.
II. BUILDING DESIGN
A. Architectural Concepts
All structures are located on the south parcel. The building is designed with shared facilities in
the center of the building and the public and private entries located at opposite ends of this
central axis. The municipal court function is in the north end of the building, emergency
operations in the center, and the police function to the south. The southern portion of the
building is a larger mass with two stories while the northern portion of the building is the
smaller scale with one story. The public oriented entrance hallway runs the length of the east
facade and is the visible portion of the facility to pedestrians.
B. Architectural Relationships
The most significant structure in the vicinity is the Tukwila International Boulevard Station
(TIBS,) which is a multi -modal transit station for light rail and Metro buses. The station has a
modern design of glass and metal with a signature asymmetrical cantilevered roofline. The
other new development three blocks to the north, Tukwila Village, includes several one-story
structures combined with 4 and 5 story structures with structured parking. As redevelopment
along the boulevard continues, the architectural relationships will get more established and
architectural context will become more important. This public facility will continue the
establishment of a modern context for future development in the neighborhood.
C. Building Elements, Details and Materials
Five exterior building materials predominate: metal wall panels, concrete panels, storefront
glazing in aluminum frames and two types of metal screens, one flat and one curvy. The use of
sienna red colored metal cladding and metal screens will reinforce the massing of the
structure. (Sheets A 5.1- A 5.3, Attachment D)
The perforated rain screens shield the building occupants and the rooftop mechanical
equipment. The applicant has indicated that the perforated screens will be designed with an
image. The details on what and how the image will be displayed in not known at this time.
The applicant indicates that the lines on the building show where the metal clad panels and
rainscreens attach to each other. That design detail will be a minimal gap of 3/4 inch. The
connection between the perforated screens on the second floor and the metal cladding below
are seamless with no modulation.
The elevations indicate that rain down spouts will be part of the architectural detailing of the
building.
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The criterion asks for distinctive building corners at street intersections using special
architectural elements and detailing and pedestrian -oriented features where possible. The
building is setback 100 feet from the S. 150th and Tukwila International Boulevard corner. The
guideline suggests seven ways of taking advantage of a corner location. The design employs
pedestrian light fixtures (Attachment J) arrayed in two arcs in the corner. A pattern of porous
pavement and concrete and landscaping fills in the corner setback and extends along the
Tukwila International Boulevard frontage.
On the south parcel, along the south property line, a retaining wall, which ranges in height
from two to three feet, is proposed. It will be topped by the perimeter fence and the sally port
fence. The wall and fence structure will be setback to meet the minimum setback.
Attachment D includes elevations of the fencing.
A small unobtrusive wall mounted fixture is proposed around the exit doors. (Attachment J)
D. Pedestrian -Oriented Features
The building site is bordered on three sides by public streets. 257 feet of the building wall is
placed adjacent to Tukwila International Boulevard with 179 feet of transparent glass.
Transparent windows along Tukwila International Boulevard, also wrap around the northeast
corner. The entry canopy over the public entry, the 39 benches, the 206 feet of 2-foot-tall walls,
and bicycle racks adjacent to the public sidewalk provide pedestrian oriented features along
that Tukwila International Boulevard street front.
The 68-foot-long north facade of blank walls and opaque sally port fencing along S. 150th street
create a negative visual impact. The structures are setback from 25 feet for the sally port fence
and 75 feet for building's corner.
The guideline for this criterion stipulates that building facades that face public streets must
incorporate one or more specific measures:
■ transparent windows over at least half the length;
■ sculptural, mosaic or bas relief artwork along at least half the length of the
ground floor; or
■ pedestrian oriented space located adjacent or connected to the sidewalk.
Specifically, at least 500 square feet of pedestrian space for every 100 linear feet of blank
building wall; or other methods that meet the intent.
To quality as a Pedestrian Oriented Space, an area must have:
■ Visual and pedestrian access into the site from the public right of way,
■ Paved walking surfaces of either concrete or approved unit paving,
■ On -site or building mounted lighting providing at least .2-foot candle on the
ground, AND
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• At least 2 feet of seating area or one individual seat per 60 square feet of open
space.
Landscaping is proposed to screen the blank facade and create pedestrian amenity and
interest. The corner is visually and physically accessible to pedestrians from the street, there
are paved surfaces of acceptable material, the foot candle is not known for the full area; There
is approximately 6,500 square feet of space in the corner, which requires 216 linear feet of
seating. The two -foot -high walls and the 39, two -foot -wide wood and metal benches exceeds
the linear foot requirement. The criterion is not met because the foot candle minimum is not
known.
E. Mechanical Equipment
The elevations show roof -mounted mechanical equipment that should be screened so that
none are visible from surrounding public streets. The visibility study (Attachment I) shows that
there is partial visibility from TIB and visibility from the other streets is not known. The
required backup generator and electrical transformer are sited so they could be visible from S.
150th Street.
III. LANDSCAPE DESIGN
A. Landscape Design
The intent of this criterion is to ensure the private landscaping reinforces, complements and
enhances public streetscape improvements.
Requirements for the sites include ten feet of Type I Light Perimeter front yard screening. Type
I is defined as a mix of deciduous and evergreen trees, a shrub every seven linear feet and
groundcover. Front yards are on Military, S. 150th and Tukwila International Boulevard.
Six feet of Type II Moderate side yard landscaping and 0 rear yard. Type II requires evergreen
and deciduous trees and the shrubs standard is increased to one every four linear feet. The
southern property line between the Justice Center and Taco Time is a side yard. The property
lines perpendicular to S. 150th and Tukwila International Boulevard are the side yards on the
north parcel.
Trees proposed on frontages are Sawleaf Zelkova, American Yellowwood, Persian Parrotia,
Patmore Ash, Tulip Tree, Duraheat River Birch, none of which are evergreen. The applicant
proposes removing the existing street trees along Tukwila International Boulevard and
planting the Sawleaf Zelkova that has small pointed leaves.
Bioretention is incorporated into the landscape plan. (Attachment D) Landscape islands,
which are all at least six feet in width and 100 square feet in area, are used between parallel
parking stalls thereby providing a continuous planting strip.
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Figure 4 South parcel TIB frontage
Figure 5 North parcel FIB frontage
There is public landscaping along the curb line and behind the sidewalk. The existing Tukwila
International Boulevard improvements (shown above) are an 8-foot-wide sidewalk with a 4
foot by 4-foot planting bed for the street trees, which are maples along Tukwila International
Boulevard.
The proposed Tukwila International Boulevard cross section on the north lot is a 5-foot planter,
12-foot sidewalk and 4-foot landscaping behind the sidewalk. Along S. 150th Street, the cross
section varies with a 6-foot-wide planting area and 7-foot-wide sidewalk to the east of the
driveway and a 4-foot planting area and 6-foot sidewalk to the west of the sidewalk.
On the south parcel, the planting area along Tukwila International Boulevard is 9.1-foot-deep
and a ten -foot -wide sidewalk; on S. 150th Street, adjacent to the accessible on -street parking
stalls, the sidewalk is 11.5 feet wide. West of these stalls, the planting area is four feet wide
and six feet of sidewalk width. The Military Road S. street improvements are being designed by
the City of SeaTac and include a bike lane, curb, planting area and eight -foot sidewalk.
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B. Planting Design
All the tree species are deciduous. The shrubs are a combination of evergreen and perennial.
The Landscape Chapter (TMC 18.52.060) stipulates that there must be a diversity of tree and
shrubs. The proposed 43 Hazelnut trees is more than 20% of the species proposed on site.
The landscape plan and planting schedule do not meet all the minimum standards; however,
the Landscape Chapter (TMC 18.52.100) allows modifications to the requirements subject to
compliance with specific criteria:
1. The modification or revision does not reduce the landscaping to the point that activities
on the site become a nuisance to neighbors; and
2. The modification or revision does not diminish the quality of the site landscape as a
whole; and
3. One or more of the following are met:
The modification or revision:
a) more effectively screens parking areas and blank building walls: or
b) enables significant trees or existing built features to be retained; or
c) is used to reduce the number of driveways and curb cuts and allow joint use of
parking facilities between neighboring businesses; or
d) is used to incorporate pedestrian or transit facilities; or
e) is for properties in the NCC or RC districts along Tukwila International Boulevard
where the buildings are brought out to the street edge and a primary entrance
from the front sidewalk as well as from off-street parking areas is provided; or
f) is to incorporate alternative forms of landscaping such as landscape planters,
rooftop gardens, green roof, terraced planters or green walks;
g) or the modification is to incorporate a community garden
The side yard landscaping on the north and south parcels do not meet the perimeter
landscaping standards but the modifications do not reduce the landscaping to the point where
the site activities would become a nuisance to neighbors and the modification does not
diminish the quality of the site landscaping. The modifications can be supported because
sidewalks are being added to connect adjacent sites.
Some of the shrubs may get as tall as 5-6 feet. Rosmarinus officinalis and salal, can grow 3-6
feet tall, forming thickets (good bird habitat) in shade or partial shade. The applicant states
that all shrubs will be kept below 30 inches. In some locations the shrub choices are
appropriate. The southern perimeter should have shrubs and a mixture of evergreen and
deciduous trees per the standard.
The Cornus stolinifera, Arctic fire dogwood, and Cornus sericea, Kelsey dogwood, both dwarf
varieties, must be trimmed annually or semiannually for its valuable winter, bright red stems to
be displayed.
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IV. Signage
A. Signage Concept
The applicant shows one wall sign on the TUKWILA INTERNATIONAL BOULEVARD facade. The
architect states that raised metallic lettering on a simple background will be used that
contrasts with the red -colored metal wall panel. Lighting at night is also proposed although
not shown (Attachment D)
One sign is allowed on a wall with an entrance. Per the Pedestrian Oriented Building Mounted
Signs section of the Sign Code (TMC 19.20.050 F (4),) the facade that does not have an entrance
may be permitted a reduced size sign (50% of the size allowed for a facade with an entrance).
At the time of permitting, all signage will be reviewed for compliance with the Sign Code,
including size requirements.
B. Sign Placement
The graphics show one sign about eight feet from grade on a blank section of wall on the east
facade that is located just to the north of the customer entrance.
C. Sign Design
The Design Manual stipulates that high -quality material and finishes must be used for signage
and backlit plastic signs are discouraged. The sign appears to be individual channel letters.
CONCLUSIONS
. Site Design
A. Site Design Concept. Both the north and the south parcels support the function of the site. A
distinctive street edge on the south parcel is created using fencing and landscaping along
Military Road S. and S. 150th Street and a building edge along Tukwila International Boulevard.
Landscaping is the edge material for the north lot, which fronts on Tukwila International
Boulevard and S.150th Street.
B. Relationship to Street Front. The improvements will upgrade the visual appearance in the
neighborhood and include public street improvements. The required 20-foot setback along
Tukwila International Boulevard can be waived for the canopy over the entrance as it is a
welcome public amenity and meets the criterion.
Other than along Tukwila International Boulevard, the design employs landscaping to create a
consistent edge to the street and add visual interest.
The public entry along Tukwila International Boulevard ensures that public access is visible
and accessible to pedestrians and drivers from along Tukwila International Boulevard. The
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staff entry that opens into the site's parking lot is securely fenced and is unlikely to cause any
public confusion. The building frontage along S. 150th Street is sufficiently minimized and
scaled compared to the Tukwila International Boulevard facade that the public will be visually
drawn to the Tukwila International Boulevard edge to find the building entry.
C. Street Corners. Additional paving, lighting and landscaping at the corner of Tukwila
International Boulevard and S. 150th Street is intended to add visual interest to the streetscape.
The significant setback from the corner is mitigated with a widened sidewalk and at least 200
square feet of landscaping that includes trees, shrubs and groundcover per the criterion.
D. Continuity of Site with Adjacent Sites. Physical connections are promoted with the proposed
improvements. A visually continuous building line along Military Road S., S. 150th Street, and
Tukwila International Boulevard are not viable given the relatively small size of the buildings
and the amount of land that parking consumes on the sites. However, the proposed
sidewalks provide physical connections between sites and along public streets.
Similar improvements are occurring along and through the north parcel.
E. Shared Facilities. On the north parcel, two driveway connections: one into the Church by the
Side of the Road and east to the building that houses the China Pavilion and the Stop Buy
Corner store parking lot, promote efficient use of resources that may be shared in the future.
Bollards and parking stalls are currently shown blocking those connecting driveways.
F. Site Design for Safety. A conflict between motorists and pedestrians could occur where the
sidewalk improvement along the south side of the Stop & Buy /China Pavilion property is
proposed. It should be designed to protect pedestrians from motorists that use that site.
Using landscaping rather than pavement adjacent to the north parcel's driveway would
provide adequate site distance and more distinctly direct pedestrian along a safer path to the
building.
This criterion says, "Design and site structures to maximize site surveillance opportunities from
buildings and public streets." The building is not designed to provide surveillance
opportunities. Windows are designed to be above eye level; and opaque glass and metal
window screens are proposed. The clear glass along the ground floor of the Tukwila
International Boulevard facade opens onto an internal corridor that has limited
employee/public eyes; however, the public areas of the site are visible from the street where
users will be able to rely on passersby and cameras.
The site furnishings are of durable high -quality materials. The applicant states that, "The wood
seats use new wood that is superior to traditional wood in terms of durability."
The street crossing that will be necessary is designed as a zebra crosswalk, which is a more
visible graphic than the standard crosswalk design of two parallel lines.
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G. Siting and Screening of Service Areas. The central south location of the trash/recycling
collection area minimizes its visual and aural impacts.
H. Natural Features and Sensitive Areas. The criterion identifies the importance of preserving
features that are assets to the community. Incorporation of the most significant natural
feature, the two significant oaks has not been proposed when they are located along the
perimeter of the site and adjacent to a parking lot
I. Surface Water Detention Facilities. The use of biofiltration and porous materials minimizes
storm loads on local streams and provides natural surface water treatment.
J. Pedestrian Circulation. The site supports the movement of the public between properties and
within the property to the building entries. Transit is readily accessible to the building through
public frontage and crossing improvements in the area.
K. Pedestrian Amenities. The covered entrance and site furnishings provide pedestrian amenities
for the public. A separate and secure area outdoor gathering area facing west is provided for
the staff. Adequate seating is being provided along TIB for site users as well as passersby.
Access between the site boundaries is barrier free. A trash receptacle has been chosen but not
yet sited. The purpose of the criterion is for consideration be given to weather in designing
pedestrian amenities thereby improving access for those not arriving by car, be beneficial for
safety reasons and contribute to pedestrian comfort and convenience. To increase the utility
of the bike racks, they should be moved under the canopy, so they may be protected from the
weather, to not interfere with the public movement along the sidewalk, and not be too far from
the entrance to be comfortably safe for most bike owners.
. Vehicular Circulation. Safety and convenience are part of the design program for motorists and
pedestrians.
M. Parking. The impact of the parking areas along the street fronts is mitigated through
landscaping of the perimeter and placing the parking onto two separate sites. The perimeter
fence is setback behind the perimeter landscaping.
II. Building Design
A. Architectural Concepts. The building is designed along a central axis that has two opposing
entrances, a public entrance and a staff entrance. Both sides of the building have a consistent
architectural character. Within the building the separation of the criminal versus judicial
functions occurs and will likely be transmitted through signage. The emergency operations
function has a much smaller public presence and therefore does not need the visibility like the
other two functions.
B. Architectural Relationships. The size of the structure is like other traditional neighborhood
commercial buildings such as the grocery store and strip retail developments in the corridor.
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The scale of the structure will bridge the difference between the smaller auto oriented uses
and the higher density residential mixed uses that are envisioned for the neighborhood. The
building provides a positive precedent for future design within the corridor.
C. Building Elements, Details, and Materials. High performance concrete (materials will be
provided at BAR public hearing) that is setback 100 feet from the corner provides a distinctive
material at the northernmost edge of the building. However, the use of layers of Landscaping,
hardscape and a storm water treatment depression highlight the corner. The light fixtures
arrayed in two arcs of graduated heights through this space provide additional lighting, and
the potential for banners, thereby providing visual interest.
The small windows eight feet above grade on the ground floor of the north and south facades
are architectural details that allow some light but also a feeling of safety for the building's
occupants. Additional physical and emotional support for the occupants is provided by
covering windows in office areas that overlook public areas with a metal screen. Although
there is no surveillance from the building's occupants to the outdoor areas of the site, the
screen over the building's windows will be designed with a decorative pattern in order to
provide an interesting facade.
The metal walls and perforated screening will complement each other and provide a greater
sense of mass and harmony in the design. The proposed materials of metal and concrete
complement each other and are durable materials and should provide ease of maintenance
and longevity to the building.
Functional Lighting of the building emergency exits is provided. The light fixture submitted will
be stylistically compatible and provide functional lighting for emergency exits.
D. Pedestrian -Oriented Features. The lack of any windows below eight feet on the 166-foot-long
south facade is ameliorated by the fencing and enclosure for the trash/recycling as well as the
five -foot -deep perimeter landscaping and fencing.
E. Mechanical Equipment. The setback of the mechanical equipment and the screens do not
sufficiently screen the equipment from public sidewalks. The ground mounted generator and
electrical transformer are visible from S. 150th Street and just 18 inches of depth on the north
side is provided in the landscape area to screen the generator.
III. Landscape Design
A. Landscape Design. Generally, the landscape plan will be an enhancement of the area. The
aesthetic value of mature vegetation is not being accomplished with the removal of the two
oaks that are thriving between the back of the Tukwila International Boulevard sidewalk and
the proposed parking lot. The proposed sidewalk width of 12' can be maintained at 8', which
matches the existing width on either side of the proposal. The 12' is not needed for a parking
lot. The existing Tukwila International Boulevard streetscape design will not be reinforced
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with this new planting plan that should be modified to use a species that is more
complementary of the existing street tree.
The buffering and screening requirement for Type II landscaping is a valuable function that is
not met in several locations. The southern perimeter landscape of primarily groundcover and
trees and yet this side is functional in site design with minimal architectural detailing on the
building. The side yard landscaping on the north parcel has an edge with just one species of
shrub. The width here may not be enough for deciduous trees because of the adjacent building
that sits along the property line; however, columnar evergreen and deciduous varieties should
be used.
As noted earlier, landscaping should be used rather than hardscape adjacent to the driveway
to the north lot in order to discourage pedestrians from crossing mid -block on S. 150th Street
and achieve the aesthetic and functional goals that landscaping provides.
Landscaping requirements for the ends of the parking rows on the north parcel and landscape
islands every 10 stalls negatively impacts the flexibility desired for the site. The intent of north
parcel is to use the space for auxiliary activities. The central planting along between the rows
that don't meet the Code compensates for the missing islands.
B. Planting Design. The plant materials in general reinforce the landscape design concept and are
appropriate to their locations in terms of hardiness and growth characteristics. The
maintenance program advocated for the shrubs and the use of deciduous trees will not
sufficiently screen the north or south facades. An evergreen rather than the deciduous
hazelnut should be selected for screening the blank walls on S. 150th Street and along the
southern perimeter. The screening and buffering requirements are not met with the location of
the back-up emergency generator and electrical box that is in a visible and in a proximate
location to S. 150th Street. The plant palette must also be modified to reduce the number of
Hazelnuts as it exceeds the plant diversity maximum.
IV. Signage
Signage Concept, Placement & Design. The proposed sign is integrated with the architectural
concept in scale, materials and placement. The location of the sign on the east building wall
will be a positive detail and complement the architecture of the building in its design and
placement. The one sign, however, will likely be inadequate as it does not orient to where
many customers will be parking and originate. Inadequate directional signage is provided for a
project that straddles a street. In addition, the minimal pedestrian -oriented character of the S.
150th facade would be aided by signage. The guidelines also recommend that signage
prominently display the building number and consideration be given to both day and night
time viewing. Ambient lighting from the building may not be sufficient for readability of the
wall sign.
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V. Setback and Landscape modifications
With compliance with conditions listed below the proposal meets the modification criteria. The
landscape modifications will not be reduced to the point that the site activities become a
nuisance to neighbors and will not diminish the quality of the landscape for the site as a whole.
The proposed modifications will be used to incorporate pedestrian facilities and is appropriate
because the building will be brought out to the street edge. A primary entrance from a front
sidewalk is provided from Tukwila International Boulevard.
RECOMMENDATION
Staff recommends adoption of the Findings and Conclusions and approval of the Conditional Use
Permit and Design Review applications with the following waivers and conditions:
Waiver approvals for:
1. Front yard setback for the canopy that extends 10 feet into the front yard over the public
entrance;
2. Landscape islands at the ends of each row of parking;
3. Landscape islands every 10 stalls; and
4. Type I front yard evergreen plant specification.
Conditions, which are indicated on a site plan with corresponding numbers, (Attachment K) are to be
approved administratively prior to issuance of the building permit:
1. Utilize plants rather than hardscape adjacent to the driveway onto the north parcel.
2. Add a barrier, such as a curb or bollards, along the north edge of the new sidewalk being
installed on the north side of S. 150th Street.
3. Provide a minimum of .2-foot candle along the north facade of the building.
4. Provide a final design for graphic on metal screens and wrap the design around the corners of
the perforated screen.
5. Provide a screen that is compatible with building materials for the trash and recycling
enclosure. If necessary, screen the roof top mechanical and ground mounted systems from
public streets.
6. Move bike racks to under the canopy and closer to entrance.
7. Modify the paving plan to incorporate the existing significant oak trees into the landscape plan,
if feasible.
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8. Modify the Plant Palette by:
a) adding evergreen tree species to be used along the blank north building facade,
in the south perimeter landscaping and in the Type II side yard landscaping on the
north parcel;
b) substituting a tree species for Tukwila International Boulevard that more closely
mimics the character of the existing street tree;
c) meeting the tree species diversity standard and reducing the number of
hazelnuts.
9. Provide night time illumination for the proposed wall sign in keeping with the architecture of
the site and provide additional signage that orients to the public on S. 150th Street.
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