HomeMy WebLinkAboutPlanning 2013-03-28 COMPLETE AGENDA PACKETCity of Tukwila
Department of Communk, Development
Jim Haggerton, Mayor
Jack Pace, Director
CHAIR, TIIOMAS MCLEOD; VICE-CHAIR, LOUISE STRANDER; COMMISSIONERS, BROOKE
ALFORD, MIKE HANSEN, SHARON MANN, CASSANDRA HUNTER AND MIGUEL MAESTAS
BOARD OF ARCHITECTURAL REVIEW
PUBLIC HEARING
MARCH 28, 2012 - 6:30 PM
TUKWILA CITY HALL COUNCIL CHAMBERS
1. Call to Order
Attendance
Adoption of 02/28/13 Worksession minutes
BOARD OF ARCHITECTURAL REVIEW
IV. CASE NUMBER: L12-046
APPLICANT: Bob Fadden on behalf of Wayne Jones
REQUEST: Public Hearing Design Review to consider the construction of a
17,000 square foot commercial structure with associated parking on
2.35 acres within a Commercial/Light Industrial District of the City
of Tukwila. The building will be devoted to warehouse and office
use.
LOCATION: 4501 S. 134th Place
V. Director's Report
VI. Adjourn
6300 Southcen er Boulevard, Suite #100 • Tukwila, Washington 98188 • Phone 206-4 - 670 • Fax 206-431-3665
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City of Tukwila
Planning Commission
Planning Commission (PC) Worksession Minutes
Date: February 28, 2013
Time: 6:30 PM
Location: City Hall Council Chambers
Present: Thomas McLeod, Chair; Louise Strander, Vice - Chair; Commissioners, Mike Hansen, Brooke
Alford, Cassandra Hunter, Sharon Mann and Miguel Maestes
Staff: Nora Gierloff, Deputy DCD Director and Rebecca Fox, Senior Planner
Chair McLeod opened the worksession at 6:35 PM.
Minutes:
A welcome was extended to Miguel Maestes, the new PC Member.
Staff introduced guest speaker Anne Fritzel from the Growth Management Services section of the Department
of Commerce. She gave a presentation about the relationship between the history of the Growth Management
Act (GMA), the requirements of the multi- county planning policies and the goals and policies in local
comprehensive plans. She also spoke about consistency between local development regulations and the
comprehensive plan and how the goals were achieved through review of individual projects.
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PC Hearing Minutes
February 28, 2013
Ms. Fox summarized the work plan for the GMA- required 2015 comprehensive plan update that had been
presented to CAP on 2/25/13. She discussed the elements proposed for review as 2013 annual amendments:
Shoreline narrative, Utilities, Transportation, Capital Facilities, Natural Environment and possibly
Community Image. The focus of these updates will be changes needed to meet new state requirements,
correction of out of date information, and incorporation of direction from the Strategic Plan as well as editing
and formatting for greater readability and ease of use online. In 2013, public participation will be provided
through open houses, hearings, mailings and information provided through the web site and articles in the
Hazelnut and Tukwila Reporter. The remaining elements will be reviewed in 2014, with work completed
prior to the June 30, 2015 deadline.
There was discussion about the need for additional work sessions for briefmg on the comprehensive plan
elements and staff agreed to propose dates and determine the one that worked for the greatest number of
commissioners.
Chair McLeod asked if there was interest in changing the standard meeting time from 6:30 to either 6 or 7
PM. There was not a consensus on a different time so the meeting start will remain at 6:30.
Ms. Gierloff gave a presentation about the regional Growing Transit Communities project. It is a planning
effort aimed at making the best use of the current investments in transit infrastructure and is funded by a $5
million dollar grant from the US Department of Housing and Urban Development. The emphasis is on
making sure that the transportation benefits are shared equitably and that intensified, transit oriented
development is promoted within a half mile radius of stations.
Staff provided an update on the environmental review of the Southcenter Plan which includes analysis of a
higher intensity option in the Regional Center and TOD districts for Council review.
Action Items:
• Staff to provide a copy of Ms. Fritzel's presentation, information about the planning short course in
Fife, link to the MRSC web site, and a link to the comprehensive plan memo and schedule presented
to CAP.
• Staff will provide possible work session dates and schedule one that works for the greatest number of
commissioners.
Adjourned: 8:25 PM
Submitted By: Nora Gierloff, Deputy DCD Director
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Notification:
City of Tukwila
Jim Haggertoti, Mayor
Department of Community Development Jack Pace, Director
Staff Report
To the Board of Architectural Review
Prepared March 8, 2013
On February 21, 2013, Notice of Application was distributed to tenants and
property owners within 500 feet of the subject property. The Notice of Application
was also posted on site. On March 15, 2013, a Notice of Public Hearing was
disturbed to all property owners and tenants within 500 feet and the notice was
published in the Seattle Times.
File Number: L12 -046 (Design Review)
Associated Permits: L06 -086 (Design Review) E06 -023 (SEPA) L07 -044 (Special Permission from the
Director) and L08 -056 (Major Modification to an approved Design Review
Application).
Applicant Bob Fadden on behalf of Wayne Jones
Request:
Construction of a 17,000 square foot commercial structure with associated parking
on 2.35 acres within a Commercial /Light Industrial District of the City. The
building will be devoted to warehouse and office use. A large parking area for
construction equipment will be located in the rear of the building.
Location: 4501 S. 134th Place
Comprehensive Plan
Designation: Commercial /Light Industrial (C /LI)
Zoning District: Commercial /Light Industrial (C /LI)
SEPA
Determination: Mitigated Determination of Non - Significance issued June 14,
2007. An addendum to the MDNS was adopted on November 7, 2008.
Staff: Brandon J. Miles, Senior Planner
Recommendation: Approval with conditions
6300 Sozithcenter Boulevard Suite #100 • Tukwila, Washington 98188 • Phone 206 - 431 -3670 • Fax 206 - 431 -3665 3
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Attachments:
A. Applicant's Response to Design Review Criteria
B. Revised Plans (Site Plan, Landscaping Plan, Floor Plans, and Elevations)
BACKGROUND
On July 3, 2007, the City issued a Notice of Decision approving the construction of a two story light
industrial /office building at 4501 S. 134th Place South. The Notice of Decision reflected the decision
made by the BAR at their June 2007 meeting. The approved building was proposed to have a total square
footage of 17,000 square feet. Parking for the proposed building was to be located in front of the
building; a large parking area for construction equipment was proposed to be installed in the rear of the
building.
On September 26, 2008, the City received a request from the applicant to modify the approved design
review plans. The applicant proposed to add a third story on the building. The third story will add
approximately 6,000 square feet of new building space. The major modification to the project was
approved by the BAR at its December 2007 Regular Meeting.
TMC 18.60.070 (E) specifies that a design review approval shall expire if construction is not commenced
within three years of approval. Thus, the December 2008 BAR approval for the 4501 Building expired in
December of 2011. In order to proceed with the project, the applicant must submit and have approved a
new design review application.
Existing Development
The site is largely undeveloped land. The applicant did install some of the required parking, which was
approved in 2008.
It appears that in the past this site had been used as a location for fill. The applicant's geotechnical report
(Cornerstone Geotechnical Engineering Report, received by the City on December 11, 2006) indicated a
significant amount of fill and other materials at a depth of approximately 10 -12 feet. The site also
contains deposits of kiln ash which is a heavy metal and is considered a toxic substance by the
Washington State Department of Ecology. It appears that the kiln ash migrated onto the site from an
adjacent parcel.
The east portion of the property contains a very steep slope (excess of 40 percent). This slope is highly
vegetated with mature trees and landscaping.
Along the eastern edge of the property is a portion of Southgate Stream. The stream is in the right of way
for S. 134th Place.
The site has a very odd shape. The front portion of the property is narrow, approximately 97 feet wide.
The property widens towards the middle and rear of the property.
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Topography:
The site has a mix of topography. As noted, the west portion of the property contains a steep slope in
excess of 40 percent. No construction activity is proposed on this slope. After the toe of the slope the
property generally has a slope of 5 percent. Near S. 134th Place, the slope of the property is generally
from 15 -17 percent with a down slope towards S. 134th Place South.
Property slope increase from S. 134th Place.
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Vegetation:
As noted, the site is undeveloped. Mature landscaping is located on the steep slope on the western portion
of the property. Outside of this area, the vegetation consists mainly of shrubs and blackberries. Several
medium sized trees are located along S. 134th Place S. These trees are within the buffer area for the
stream.
As part of the Special Permission application approved by the City in 2007, the applicant installed
vegetation within the buffer of the adjacent type 2 stream.
Stream Located in Front of Property.
Findings- Decision Criteria - Design Review
The project is subject to the design review criteria laid out in Tukwila Municipal Code (TMC) 18.60.050
(B).
In the following discussion, the TMC Design Guidelines are shown below in bold, followed by staff's
comments. The applicant's response to the design criteria is included as Attachment A.
1. Relationship of Structure to Site
A. The site should be planned to accomplish a desirable transition with streetscape and to
provide for adequate landscaping and pedestrian movement.
The applicant is proposing to construct a Light Industrial building within the C /LI district of the City.
Vehicular and pedestrian access to the City will be via a private access road. The access road is on an
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adjacent parcel and the applicant has obtained an easement to utilize the tract.
A five foot paved pedestrian access will extend from S. 134th Place S to the entrance of the building.
The first 60 feet of the site will be utilized as an enhancement for the stream buffer located in the front of
the property. The applicant has completed this enhancement and now within his required monitoring
period.
Stream Buffer Enhancement Area
Parking for the proposed building will be located in the front of the building. Perimeter and parking
landscaping will be provided in the front portion of the site. Pedestrian connections are not proposed to
the surrounding properties. An eight foot tall fence will be constructed to separate the applicant's
property from the two neighboring properties. The fence does not meet setbacks. A condition has been
placed to address this situation.
B. Parking and service areas should be located, designed, and screened to moderate the visual
impact of large paved areas.
The front portion of the property will be utilized for parking. The parking will be screened from S. 134»'
Place by the 60 foot wetland enhancement area.
A large service area is proposed in the rear of the building. The proposed use for this area is to store
contractor equipment (trucks, heavy machines, etc). The building has been positioned to screen the
service area from S. 134th Place. The storage area does border Macadam Road South. Macadam Road
South is at a significantly higher elevation than the applicant's project. As noted, a large downward slope
extends east of Macadam Road South towards the applicant's property. This slope area contains a
significant number of mature trees which will be retained as part of this project.
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C. The height and scale of each building should be considered in relation to the site.
The C /LI allows a maximum height of 45 feet. The proposed building will have a high point of
approximately 32.5 feet. The building will have a street facade of approximately 140 feet. However the
visibility of the facade is minimized by the vegetation in the 60 foot stream buffer. The surrounding
buildings have a street facade ranging from 120 to 175 feet. The surrounding buildings range in height
from 25 to 30 feet in height.
The proposed building may appear taller than the building to the north, but that is because the finish floor
elevation of the building to the north is ten feet lower that the applicant's property.
2. Relationship of Structure and Site to Adjoining Areas
A. Harmony on texture, lines, and masses is encouraged
The applicant's building will utilize varying elevations and color. The east elevation for the building
includes varying elevations to provide vertical modulation. No vertical modulation is proposed along the
west elevation or the south elevation. Minor vertical elevation is proposed along the north elevation.
Windows are used on all elevations to provide horizontal modulation.
A cornice is provided along the roofline of the entire building. The cornice provides more horizontal
modulation for the building.
The building is being developed to provide two separate suite areas. Each suite area would include its
own main entrance on the east elevation. The entrances will be recessed back with the 2nd floor extending
over the entry doors. This provides a small entry feature for the building.
The main building material is colored concrete. CMU brick is used in the front of the building.
Landscaping is provided directly adjacent to the east elevation of the building. Once mature, this
landscaping will visually break up the mass of the front facade of the building.
When the Normed Building was constructed several years ago the City received complaints from the
residential neighbors along Macadam Road that the glare from the building's roof was disturbing. The
homes along Macadam Road look down upon the commercial /light industrial buildings in the valley.
Glare from the proposed 4501 Building may not be an issue given that there is a significant amount of
vegetation on the hillside that separates the proposed building from the existing homes. However, a
condition has been added.
B. Appropriate landscape transition to adjoining properties should be provided
Upon completion, the landscaping along the north and south property lines will comply with the City's
landscaping requirements.
No additional perimeter landscaping will be required on the west property line because this area contains
mature landscaping. TMC 18.52 requires 12.5 feet of landscaping along the front property line.
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However, since the front portion of the property will contain a 60 foot enhanced stream buffer additional
perimeter landscaping is not needed.
C. Public buildings and structures should be consistent with the established neighborhood
character.
Not applicable as the applicant's building is not public.
D. Compatibility of vehicular pedestrian circulation patterns and loading facilities in terms of
safety, efficiency and convenience should be encouraged.
As noted, access to the site will be via a shared access drive. Access to the parking area is from two curb
cuts, one located right off of the access drive and the other when the access drive makes a 90 degree turn.
The access drive extends to the rear of the building to provide access to the rear storage area. Most of the
parking is isolated from the main access drive. This separation reduces conflicts between users of the
parking lot and through traffic on the access drive. Some conflict may exist of users of the parking stalls
directly next to the access road. These users would have to back up onto the access drive in order to
maneuver on the site. A fire -turn around is provided in the rear of the building. Parking and service areas
have been separated from each other.
E. Compatibility of on -site vehicular circulation with street circulation should be encouraged.
The project will utilize an existing access drive and no new access points are proposed along S. 134th
Place.
3. Landscaping and Site Treatment
A. Where existing topographic patterns contribute to beauty and utility of a development, they
should be recognized, preserved and enhanced.
A significant number of trees will be retained on site after completion of this project. The trees located in
the rear of the property along the steep slope will remain and provide an excellent screen for the single
family homes along Macadam Road S. The applicant has proposed to retain several trees located along S.
134th Place South, which are located within the buffer area.
There are several trees located off -site directly to the north of the applicant's property. These trees are not
going to be removed; however, the grading activity on the site could damage the root system of these
trees. Planning staff has provided a condition to address this concern.
B. Grades of walks, parking spaces, terraces and other paved areas should promote safety and
provide an inviting and stable appearance.
The site will utilize differing paving materials to differentiate between the pedestrian walkway and drive
paths. Additionally, the pedestrian walkway will be slightly higher than the drive path.
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C. Landscaping treatment should enhance architectural features, strengthen vistas and
important axis, and provide shade.
Building perimeter landscaping is provided along the front of the building. When mature this landscaping
will break up the facade of the front portion of the building. The access drive is lined with trees which
provide a site entry feature.
D. In locations where plants will be susceptible to injury by pedestrian or motor traffic,
mitigation steps should be taken.
The applicant has proposed curbs around all landscaped areas to prevent damage to plantings from
automobiles.
E. Where building sites limit planting, the placement of trees or shrubs in paved areas is
encouraged.
Landscaped areas have been provided within the parking areas. The landscaped areas comply with the
City's requirements for landscaping within parking areas. Landscaped areas will also be provided near
the main entrances to the building.
F. Screening of service yards, and other places that tend to be unsightly, should be
accomplished by the use of walls, fencing, planting or combination.
The service yard for the site will be located behind the building and thus not visible from S. 134th Place.
The topography and trees on the site will screen the service yard from Macadam Road S.
The dumpster will be located along the north property line and will be enclosed with tilt up concrete
walls.
G. In areas where general planting will not prosper, other materials such as fences, walls, and
paving of wood, brick, stone, or gravel may be used.
This provision is not applicable to this project. The applicant has noted in the narrative, "Gravel will be
used in areas where parking overhang will cause planting to be ineffective ". However, the landscaping
plans make no such indications on where these areas are. The City requires that ground cover achieve 90
percent coverage within three years of planting.
H. Exterior lighting, when used, should enhance the building design and the adjoining
landscape. Lighting standards and fixtures should be of a design and size compatible with
the building and adjacent area. Lighting should be shielded, and restrained in design.
Excessive brightness and brilliant colors should be avoided.
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4. Building Design
A. Architectural style is not restricted; evaluation of a project should be based on quality of its
design and relationship to its surroundings.
The proposed building is approximately 17,000 square feet in size. The building is two stories and is
being built to house two tenants. Large service doors are provided in the front and rear of the site.
The materials for the building are concrete and CMU brick. However, the use of the CMU brick is very
limited and will only be used as an accent in the front of the building.
The building has a degree of vertical modulation on the east (front) and north (side) elevation. Windows
are used to provide a small amount of horizontal modulation on all elevations.
A cornice is proposed around the entire roof line.
B. Buildings should be appropriate scale and in harmony with permanent neighboring
developments.
The surrounding buildings are light industrial in nature. The surrounding buildings have an average
height of 29 feet and have street facades ranging in length between 120 and 175 feet. The applicant's
proposed building will be approximately 32.5 feet tall and will have a street facade of 140 feet.
C. Building components such as windows, doors, eaves, and parapets should have good
proportions and relationship to one another. Building components and ancillary parts shall
be consistent with the anticipated life of the structure.
The proposed building will mainly be constructed with colored concrete. A small amount of CMU will
be used in the front partition of the building. Windows have been placed in aluminum sash. A cornice
has been placed around the top of the parapet. Exterior doors will have a metallic color.
D. Colors should be harmonious, with bright or brilliant colors used for accent.
The building will utilize earth tone colors. The front portion of the building will feature three colors, dark
brown is used to create symmetry and two different tan colors are used to provide horizontal modulation.
The other sides of the building will only feature the two tan colors.
The applicant has not included colors for the proposed dumpster enclosure.
E. Mechanical equipment or other utility hardware on roof, ground or buildings should be
screened from view.
The mechanical equipment will be screened by the parapet on the roof. The equipment will not be visible
from S. 134th Place, since S. 134th Place South is at a down angle from the building. During winter
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months, when the trees on the steep slopes are dormant, the mechanical equipment may be visible from
Macadam Road S.
F. Exterior lighting should be part of the architectural concept. Fixtures, standards, and all
exposed accessories should be harmonious with building design.
The applicant has noted that lighting will be provided on the building, within the service area, and within
the parking area. The applicant has proposed "designer flood lights" that will be installed on the building.
The applicant has also proposed "ecolume decolume" parking lot lights. These lights will have a square
fixture.
G. Monotony of design in single or multiple buildings should be avoided. Variety of detail,
form and siting should be used to provide visual interest.
The project proposes both vertical and horizontal modulation. There is only one building proposed, so
monotony of design of multiple buildings is not a concern.
5. Miscellaneous Structures and Street Furniture
A. Miscellaneous structures and street furniture should be designed to be part of the
architectural concept of design and landscape. Materials should be compatible with
buildings, scale should be appropriate, colors should be in harmony with buildings and
surroundings, and proportions should be to scale.
The rear portion of the site will be utilized as contractor storage yard. The applicant has proposed to
construct a chain link fence around this portion of the property. The fence ranges in size from six feet
along Macadam Road South to eight feet along the north and south property lines. A gate will be
provided along the access road to restrict access to the rear portion of the property. The site map (sheet
Al) notes that the fence will be dark green on the north and south property line. However, no such note is
provided for the portion of the fence along Macadam Road South.
TMC 18.52.040 (F) requires that any fence be placed on the interior side of any required landscaping.
The landscaping plan (sheet L1) shows that this requirement will be met on the north property line, but
not on the south property line.
The City's Parking requirements also require that bicycle parking be provided for the proposed use. No
bicycle parking is shown on the site plan.
B. Lighting in connection with miscellaneous structures and street furniture should meet the
guidelines applicable to the site, landscape and buildings.
No street furniture will be provided with this project.
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DESIGN REVIEW CONCLUSIONS
Design Review Guidelines
Relationship of Structure to Site:
The proposed development has been designed to meet the functional requirements for this type of land use
while being responsive to the special characteristics of the site. The building is proportion to the property
size. The new building will meet all required setbacks.
Typically, the City encourages that parking be located in the rear of a site. However, given the odd shape
of this property, the uses for the front portion of the property are very limited and thus using this area for
parking is appropriate.
Relationship of Structure and Site to Adjoining Areas:
The proposed building's form and scale is in keeping with the existing development in the area. The
buildings height and form is consistent with other development in the area.
Landscape and Site Treatment:
The applicant will install landscaping that meets the City's landscaping requirements within the
Commercial /Light Industrial Zone. The applicant will install a significant amount of perimeter
landscaping and interior landscaping. All landscaped areas will have automatic irrigation and the
applicant will be required to maintain the landscaping for the life of the project (TMC 8.28.180).
Building Design:
The proposed building is of comparable scale with buildings in the neighborhood and has been painted
with colors that will make it harmonious with adjacent buildings and the hillside behind the building. The
design is appropriate for the light industrial nature of the area.
Miscellaneous Structure and Street Furniture:
Given that the rear portion of the site will be utilized for storage it is appropriate to secure the area with
fencing. However, the fence needs to comply with the requirement to place the fence on the interior side
of the required landscaping. Parameters should also be placed to ensure that the fences do not hinder the
ability to maintain the landscaped areas. This can be accomplished by placing gates along the fence line.
The fence along Macadam Road should also be dark green.
Bicycle parking is required for the proposed building, but is not shown on the site plan.
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Design Review Recommendation
Staff recommends approval of the 4501 Building application with the following conditions:
General
1. The site map shall be updated to show the location of bicycle parking for the site. Per
figure 18 -7 of Title 18 the site is required to have two bicycle parking stalls. The Director
shall approve the location and design of the parking stalls. However, the Director shall not
approve a design which will require the removal of any landscaping approved by the Board
of Architectural Review.
2. The fence along the south property line shall be placed within the interior of the five foot
landscape strip.
3. In order to maintain the north and south landscaped strip, a gate shall be added on the north
fence and the south fence.
4. The chain -link fence along Macadam Road South shall be dark green.
5. Barbwire shall not be used on the chain -link fence along Macadam Road South.
6. The concrete walls for the dumpster enclosure shall be painted to match the color of the
primary building. The proposed black chain -link fence with wood slats shall be replaced
by green chain -link fence (same fencing material as the perimeter fence) with wood slats.
7. The roof shall utilize non -glare finishes and colors.
Landscaping
1. At the time of construction, tree protection fences shall be placed around the trees on the
neighboring north property. The fences shall be placed one foot for every inch in height.
No grading activity shall occur within these protected areas.
2. All landscaped areas shall have groundcover placement and species selection which allows
for 90 percent coverage within three years.
3. All final details of the landscaping plan, including plant species and spacing, shall be
approved by the City's Urban Environmentalist prior to issuance of the building permit for
the project.
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LANCE MUELLER & ASSOCIATES
A "II" IS C V" A V b
Memorandum
Date: 4 -22 -07 amended 3 -19 -2013
To: Brandon Miles
CC: Wayne Jones
From: IE3ob Fadden— Lance Mueller & Associates
Attachment A
Job No. 12 -108
Re: 4501 Building — Project Consistency Narrative Memo
Brandon,
Thanks for your memo of 4 -7 -07 expressing some concerns about the building design. I have
reviewed them with Wayne Jones and studied them in detail and prepared updated drawings that
reflect concurrence with the design guidelines of the TMC section 18.60.050A and Chapter 18.30 of
the Zoning Code.
The document package submitted for Design Review contains a significant amount of information
in the Design Narrative attached, as to how the project as submitted complies with TMC section
18.60.050A. In addition to topographic information, a site survey showing adjoining buildings,
environmental exhibits, and a discussion of the neighborhood characteristic, contains a
photographic exhibit that allows everyone to become familiar with the site.
Some of the comments you provided are very general and others are more project specific. The
general comment will be addressed first and the specific comments second.
In discussing the feedback with Wayne Jones, the owner, he points out that the surrounding
properties are all developed and the buildings are "middle aged ". This is very significant since it
establishes what will happen in the future in terms of redevelopment and further development.
This sub area of Tukwila though zoned C /LI is actually dominated by light industrial uses. The uses
adjacent to this 4501 property are distribution, service, and manufacturing with undeveloped
property in this area, other than the 4501 property, located well south of this site and currently
occupied by single family residences. The undeveloped area is significantly encumbered by stream
buffers, sloping topography, inadequate storm drainage, and an unimproved street system.
Commercial activities currently do not exist in this area. Since 134th PI. S. is on a secondary street
with no significant traffic flow, and the area is already developed, commercial activities most likely
will not occur. The chance of the street being improved and a traffic flow brought to a level that
would support commercial uses is minimal and further reduced by the open drainage ditch along
the west side which is considered a stream.
130 Lakeside Ave. • Suite 250 • Seattle, WA • 98122 • (206) 325 -2553 • Fax (206) 328 -0554
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The probability of the 4501 property being used commercially simply doesn't exist. The pan handle
shape of the property, the fact that the area that will support a building over 300 feet away from the
street, and the 50 foot stream buffer in the front yard prevents the building being used for a
commercial use.
The ownership of the surrounding properties is either institutional investors, individual business
owners, or private investors. What this means is the property uses are stable and the chance of
the redevelopment of properties into higher and better uses is unlikely, unless the ownership is
consolidated and a large corporate user comes along it is not realistic. If that happened all existing
uses would be removed and the building demolished.
This is significant because any new facility should be similar to adjacent buildings as intended by
TM section 18.60.050A. Care should taken to be sure that the new facility blends with its
neighbors and doesn't make them appear as second class neighbors.
Mr. Jones position is since the existing uses in the sub area are light industrial, the long term uses
on adjoining properties are light industrial. He plans to use the building and grounds himself in a
light industrial manor that it is appropriate to construct his building as a light industrial building and
it should not have an appearance of a commercial building.
We bring this point to your attention because many of your design comments are appropriate for a
commercial building that the public can regularly access and a building that is adjacent to
commercial uses. Light industrial buildings do not require this level of design treatment because
they serve functions that are different than commercial building.
Impersonal appearance at many areas of an industrial building is appropriate since these areas are
functional in nature, not normally a pedestrian area or publicly in view. Treatment of those areas
has no general benefit and is a waste of a citizen's money.
The areas at that are appropriate for design treatments at light industrial building are those visible
from the public street or from adjacent uses which are not similar. These areas because of other
provisions of the code have buffer landscaping that screen the building facade.
Below I have cut and pasted in your comments. The changes in building design that have been
made are noted and referenced by sheet number. Where changes have not been made we have
stated why they are not needed. We think you will concur with us once you have the opportunity to
study the materials already submitted.
• Incorporate some type of modulation into the design of the building. The modulation should
include:
The only area that modulation and design treatment are appropriate is at the east
facade.
The west face of the 4501 building is completely screened from Macadam Road by
existing buffer planting and not visible from any of the adjacent buildings.
The south walls of the light industrial warehouses to the north have blank unarticulated
surfaces with no windows. This wall is set back from the lot line ten feet. The code
required landscaping has disappeared and the city has not required it to be replaced. If
130 Lakeside Ave. • Suite 250 • Seattle, WA • 98122 • (206) 325 -2553 • Fax (206) 328 -0554
16
the landscaping was in place it would buffer the blank wall areas that are over 300 feet
long.
The warehouse to the south of this site adjacent to the storage area is elevated above
the 4501 building. This building has no windows to the north and no view of the
storage area. Adjacent to the buildings to the south is ten feet of mature landscaping
which screens the view of the warehouse to the south.
Also south of the site is an old house that serves as an office. The lower floor has no
windows and no view of the storage yard in back of the 4501 building to the north.
The view from the second floor windows toward the 4501 building of the building to
the north is screened by landscaping. The drawing as resubmitted provides and
architectural treatment on the upper part of the 4501 wall surface, surface articulation,
a variation in height and a change in color.
1. Wall plane projections and recess. The original design as submitted has a recess at the
office area. A section has been added to clarify this. This recess also provides
protection from weather at the office entries. In addition modulation has been added
at the east elevation. The central part of facade, where the office area is located, has
been brought forward by lapping the panels.
2. Texture Change. The building surface at the south has sufficient texture. It is created
by the rustication (reveals) in the wall surfaces. These reveals tie into the painting
patterns, the window elements, and other architectural features.
3. Material Change. The design as previously submitted used an alternate material at the
entry area for design relief. The revised design at the front entry area provides a CMU
wainscot at the building base as part of the building transition to the ground and as
additional visual texture. The treatment is provided at the entry area where it can be
enjoyed by visitors.
• Roof Design
1. Variation in the roof design should be used to add interest to and reduce the scale of the
building. See revised elevations shown on sheet A-3. Additional parapet height is
added at the projected plane of the office area.
2. A cornice with a distinct treatment should be used around the parapet. The building
already has a cornice element at the top of the wall. An additional step has been added
to the feature which is illustrated the section shown on sheet A-3.
• Materials and colors
1. The proposed colors are generally acceptable.
2. The front and sides of the building should utilize or at least have the appearance of at least
two building materials such as brick; sandstone or other native stone; and tinted, textured, or
concrete masonry units. The design treatment in this setting is appropriate at the east
(front facade). This treatment is shown on the revised elevations.
Treatment on the west side adjacent to the service doors and storage yard is appropriate
because of the existing buffer blocks any view of this area from offsite.
130 Lakeside Ave. • Suite 250 • Seattle, WA • 98122 • (206) 325-2553 • Fax (206) 328.0554
17
The north facade of the building is not visible from the street or from the property at
the north. The base landscaping adjacent to the wall provided will mature and buffer
the wall in the future. Windows in the upper area of the wall have been provided
where the wall might be visible above the adjacent building from a distance. The
treatment wall exceeds the design standard of the neighbors wall and is appropriate
based on the TMC.
The south wall of the building elevations has been modified to add additional treatment
in the area visible form the property to the south. This includes the addition of
fenestration, surface articulation, changes in color, and vertical modulation. In addition
at the lot line there is buffer landscaping to screen the building base and over 10 feet of
landscaping, which includes mature trees on the neighboring property that visually
buffers the 4501 building to the south.
• Entry
1. The two entries to the building need to be more pronounced. Entryway design elements and
variations should give the orientation and add character to the building. Suggestions include
the use of canopies, overhangs, recesses /projections, arcades, peaked roof forms, arches,
outdoor patios, or particular architectural details. See revised drawings and sections. The
building is not a commercial building that generally accepts the public. The entries are
clearly visible from the parking area directly in front of the building and as part of the
overall facade The entry area is part of the overall design and can be identified from
134TH Pl. S. Each entry will be signed separately which will identify the individual
user. Currently the building has only one tenant, Lakeridge Development
Other Items:
1. Clarify the design and materials of the proposed trash enclosure. Chain link fence is not
appropriate. Many projects are using split face CMU walls with a metal gate. The color of the
enclosure should be consistent with the colors of the primary building. Please also clarify the
square footage of the trash enclosure and how much space is being reserved for recycling
collection space. City Code requires that equal space be provided for recycling. See revised
drawing sheets A -1.
2. Please provide additional information on the storage area located in the rear of the site. Will
vehicles be washed on the site. The yard behind the building is for storage of
construction material and equipment. No service, repair, or vehicle washing is
proposed within the storage area.
If you have any questions or further concerns please feel free to contact me.
Bob
130 Lakeside Ave. • Suite 250 • Seattle, WA • 98122 • (206) 325 -2553 • Fax (206) 328 -0554
18
JOB: 4501 BUILDING
Applicant Responses:
10. Construction of a light industrial warehouse building for use as office, storage,
equipment maintenance. The maintenance area will be at the south end and be
about 2,500 s.f. The building will be a partial 2 -story building of 17,000 s.f. gross
area with a second floor of 2,999 s.f. The major part of the building will be used by
the building owner for office and storage. The area behind the building will be
used for equipment and material storage. These materials and equipment are
used by the owner in his construction business. Part of the yard is proposed to be
paved with crushed rock since tracked equipment will be parked on it occasionally.
The building will be a Type VB sprinklered construction with a non structural slab
on grade and tilt up concrete exterior walls. The roof system will be a Class B built
over rigid insulation on a wood /steel hybrid structure. The building is currently
proposed with un- separated B, S -1, and F1 uses.
19
JOB: 4501 BUILDING
Applicant Responses:
B. ENVIRONMENTAL ELEMENTS
1. Site was graded and rockeries installed under previous permit. The western part
of the site is gravel covered and is overgrown with weeds and brush and slopes
gently east, east of the rockery. West of the rockery it slopes up to McAdam
Road. The eastern part of the site consists of finger of land (pan handle) that
slopes towards 134th PI. So. Part of this area is gravel, part grass, and some is
covered with Alder and Evergreens. Along the north lot line the site slopes sharply
to meet grade of neighboring property. Details can be found on existing conditions
drawing.
20
Project Consistency Narrative
4501 BUILDING
Relationship of Structure to Site
a. The site should be planned to accomplish a desirable transition with
the streetscape and to provide for adequate landscaping and
pedestrian movement.
Response:
The property to be developed is located between two streets, Macadam
Road on the west and S 134th Place on the east. Previously the site,
except the west which is a steeply sloped, was graded and used as a
storage area. At the east there is a drainage channel next to S. 134th PI.
which is considered a class III stream from which development will be set
back 50 feet.
The proposed design utilizes natural features at the east and the west as
transition to the existing street. At the west the existing mature site
obscuring vegetation provides a buffer that averages 100 feet, which
results in an excellent transition to the residential zoning west of Macadam
Road.
S. 134th PI. on the east is about 20 feet lower than the proposed building
and 10 feet lower than the east end of the parking area. Adjacent to the
street is a 50 foot stream buffer. Within the buffer there are existing trees
which screen the upland part of the site from the street. After the buffer
planting is installed, the planting will almost obscure the view of all but the
upper portion of the building facade.
The combination of new and existing planting and the topographic feature
of the site provide an excellent transition between the streetscape and the
site.
The site is accessed from S 134th Place which has no current sidewalks
along either side of the street. As a result there are no pedestrian routes in
the area in the public way.
The development however, to insure safe access, provides a 5 ft. wide
pedestrian concrete sidewalk along the edge of the private entry drive to
the public way.
21
Project Consistency Narrative
4501 BUILDING
Page Two
b. Parking and service areas should be located, designed and screened
to moderate the visual impact of large paved areas.
Response:
The proposed development locates the building in the middle of the site in
the only area of the site which can be reasonably developed with a
structure. This location utilizes the existing topography and current grading
to develop a facility that generally separates parking from service and
storage area.
The site design as designed has a 50 foot planted buffer along its eastern
boundary and a natural buffer along it west boundary that obscures views
from off site. Along the north border of the site is an existing industrial park
and at the south side is a commercial development.
The adjoining property to the north is an industrial park. Along the eastern
portion of the north lot line of the park is existing landscaping and mature
trees. At the western section is an existing building wall of about 30 feet in
height that has no landscaping next to the wall and no windows.
The neighboring property to the south has two buildings on it. The western
building is a warehouse. Its north wall has no windows and roof level is
about 35 feet above existing grade of the 4501 Building site. The second
building to the east is a house used as an office with storage in the
basement. Windows in the facade will look to the north toward the
proposed building.
The building as designed and located on the site has an entry area for
offices in the middle which will be visible once you enter the shared
driveway. To the north of the entry, on the east facade, screened from the
street and separated from parking, is first a drive in door and then a dock
height door. The dock high door is placed at the most northerly location to
take advantage of the existing topography and screen from the adjoining
industrial parking with landscaping.
The general parking area for the building is located between the front of the
building and the street. Handicap parking and convenience parking is
located at the building entry. The site as currently shown provides
landscaping along the perimeter of the parking areas and landscape
islands at the ends of parking rows. As such, its design moderates the
visual impact of the paved area.
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Project Consistency Narrative
4501 BUILDING
Page Three
Located on the west side of the building are several service doors that
open toward the service yard to the west of the building. The locations of
the adjoining building, the existing topography and landscaping makes the
area to the west of the proposed building a good location for the service,
storage and loading areas because it is obscured from view from the
streets and have little impact on neighboring uses.
c. The height and scale of each building should be considered in
relation to its site.
Response:
The surrounding properties are currently developed with industrial
buildings. These buildings are generally tilt up concrete, some with
windows, with a smooth painted finish which are about 25 to 35 feet in
height. The finish floor elevations above the street vary depending on the
individual lot.
The finish floor building to the north of the this property, which is about 30
feet high, is about ten feet lower then the proposed 4501 building and the
building directly south whose finish floor is about 2 feet higher is about 25
feet in height. The building to the east in front of the site is about 28 feet
high. Both the building to the east and the buildings to the north have a
street facades that range between 120 and 175 feet.
The proposed building has an average height of about 29 feet and a street
facing facade of 140 feet. This makes the scale and height of the
purposed development have an appropriate scale to the surrounding
buildings and site.
2. Relationship of Structure and Site to Adjoining Area
a. Harmony in texture, line and masses is encouraged.
Response:
The surrounding building facades are generally horizontal and about 30
feet in height. The building finishes are smooth painted concrete and have
little architectural treatments except windows.
The public facade proposed building design is harmonious with the mass,
line and textures of surrounding buildings.
23
Project Consistency Narrative
4501 BUILDING
Page Four
b. Appropriate landscape transition to adjoining properties should be
provided.
Response:
The proposed development has landscape transitions at all adjoining
properties where appropriate. The transitions to neighboring properties and
the streets meet the design intent of code.
The details of the transitions are as follows;
The transitions provided at the streets are extensive and meet or exceed
ordinance requirements as well. At the eastern street a 50 foot planted
buffer is provided and at the western street an existing planted buffer
averaging 100 feet is in place.
The proposed design provides a landscape transition at the north lot line to
the neighboring industrial park. This transition along the eastern part of
that boundary consists of five feet of required planting that supplement the
existing :neighboring trees and additional landscaping in front of the
parking. At the western part of the boundary, 5 feet of planting is provided
next to the lot line north of the security fencing. Currently, north of this lot
line, no code required landscaping remains against the blank building
facade.
At the south lot line three different conditions occur. The first one occurs
at the pan handle east of the building in which the general parking area is
located along the entry drive. At this location the design proposes a
minimum of five feet of side yard landscaping behind the keystone wall in
front of the parking area and planting south of the keystone wall between
the wall land the walk.
The second and third conditions occur where the two existing buildings are
located on the neighboring lot to the south. The two existing buildings are
located about 25 feet south of the lot line. South of the 4501 Building lot
line is a landscape bed that averages 12 feet and ranges in width between
10 and 15 feet in which is planted mature trees. This area serves as a
landscape transition for both properties even though it is not located on the
lot.
The finish floor location of the two buildings to the south differs. The
westerly building is located above a 8 foot rockery 25 feet south of the lot
line. At the base of the rockery is 10 to 15 feet of planting. Increasing the
planting area along this area would not improve the transition between
properties.
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Project Consistency Narrative
4501 BUILDING
Page Five
As part of this application the Owner is requesting a landscape design
modification to allow the required landscaping along this lot line to be
placed in one of the other open areas of the site. He feels that the existing
landscape transition at this lot line is appropriate.
c. Public buildings and structures should be consistent with the
established neighborhood character.
Response: This is a private building and is consistent with the neighboring
buildings
d. Compatibility of vehicular and pedestrian circulation patterns and
loading facilities in terms of safety, efficiency and convenience
should be encouraged.
Response:
The site design separates parking and service areas from each other. In
limited areas, service vehicle circulation areas overlap parking circulation
areas. At no location will a vehicle parked at a loading dock obstruct
vehicle circulation areas.
e. Compatibility of on -site vehicular circulation with street circulation
should be encouraged.
Response:
Site access is provided to this property through an existing shared drive
which will be improved and widened as part of this development. This
access to the public street makes the circulation compatible with the
existing street.
All vehicle circulation for this development will occur on private property or
over a private easement on adjacent property. The common access drive
will be used for general ingress and egress as currently occurring.
Maneuvering on the easement will occur at two parking stalls at the east .
side of the building where they will back out on to the easement. This
easement dead -ends about 100 feet to the south and serves parking on
those adjacent sites which already use the easement for maneuvering.
The development of this site doesn't disrupt the current circulation patterns
and improves access and has been designed to be compatible with the
existing private circulation.
25
Project Consistency Narrative
4501 BUILDING
Page Six
3. Landscape and Site Treatment
a. Where existing topographic patterns contribute to beauty and utility
of a development, they should be recognized, preserved and
enhanced.
Response:
The proposed design utilizes the existing vegetation, significant trees and
the topography to the maximum extent feasible to screen and buffer the
site and preserve wooded areas. The new plantings were provided to
enhance the existing vegetation and improve the overall development.
b. Grades of walks, parking spaces, terraces and other paved areas
should promote safety and provide an inviting and stable appearance.
Response:
Grades on site are designed to allow for easy movement by pedestrians
and vehicles. Differing paving materials are provided at vehicle area and
pedestrian pathways to designate access routes to the building entry from
parking areas and the street. The boomed concrete walkways with the
adjacent landscaping will provide an inviting, stable, and safe pathway from
the street to the site.
c. Landscape treatment should enhance architectural features,
strengthen vistas.and important axis, and provide shade.
Response:
The landscape design as proposed allows the building entry to be viewed
from the private drive and focuses your attention on the entry as you
approach.
d. In locations where plants will be susceptible to injury by pedestrian or
motor traffic, mitigating steps should be taken,
Response:
Curbs are provided around all landscaped areas to prevent intrusion of
vehicles. Parking stall curbs or wheel stops will be provided 18 to 24
inches into the parking stall to prevent damage to planting.
e. Where building sites limit planting, the placement of trees or shrubs
in paved areas is encouraged.
Response:
The design as shown provides landscape islands within the parking area in
which shrubs and trees are provided. At the service area doors, adjacent
to the building where paving is provided, trees and shrubs are planted at
the property perimeter to visually buffer this area.
26
Project Consistency Narrative
4501 BUILDING
Page Seven
f. Screening of service yards and other places, which tend to be
unsightly, should be accomplished by the use of walls, fencing,
planting or combinations of these. Screening should be effective in
winter and summer.
Response:
The storage area east of the service doors is screened from view from
offsite area by a combination of existing evergreens, new evergreens,
existing buildings, the new building, and site obscuring fencing. Some
deciduous planting is provided within those areas for variation and will not
diminish the effectiveness of the screening in the winter.
g. In areas where general planting will not prosper, other materials such
as fences, walls, and paving of wood, brick, stone or gravel may be
used.
Response:
Gravel will be used in areas where parking overhang will cause planting to be
ineffective.
h. Exterior lighting, when used, should enhance the building design and the
adjoining landscape. Lighting standards and fixtures should be of a
design and size compatible with the building and adjacent area. Lighting
should be shielded, and restrained in design. Excessive brightness and
brilliant colors should be avoided.
Response:
The photometrics of all light fixtures will be selected to limit light effects to
the site and provide 1 fc. (noon light) at the edge of the adjoining property.
Light fixtures will be color corrected metal halide so the color will be white
and the fixture efficient.
Current light design for the site calls for four types of fixtures. These have
been selected based on there location. Along the south edge of the
parking lot two 30 foot high 250 watts shoe box pole lights are provided.
These fixtures will light the parking lot and the pedestrian path to the
building.
At the building entry two 75 watt recessed down lights will be installed in
the soffitt to light the entry alcove to make it warm and inviting. In the two
landscaped islands at each end of the parking in front of the office are two
75 watt pole mounted pedestrian walkway lights that will provide lighting for
the parking area and make this area feel secure. These are located so that
they will provide surface lighting at each adjacent drive in doors.
27
Project Consistency Narrative
4501 BUILDING
Page Eight
At the west and south side of the building shoe box fixtures are provided,
mounted on arms attached to the building to provide security lighting. The
fixture on the west arm is 250 watt and the one on the south is 75 watt to
minimize the effect on the adjacent property.
Overall the lighting design will enhance the site and blend effectively with
surrounding uses.
4. Building Design
a. Architectural style is not restricted; evaluation of a project should be
based on quality of design and relationship to surroundings.
Response:
The purposed building design exceeds the design quality of the buildings in
front of it and next to it and is of equal or better quality of other buildings in
the area. See photo exhibit.
b. Buildings should be to appropriate scale and be in harmony with
permanent neighboring developments.
Response:
The proposed building is of comparable scale with buildings in the
neighborhood and has been painted with colors that will make it
harmonious with the adjacent buildings.
c. Building components, such as windows, doors, eaves, and parapets,
should have good proportions and relationship to one another.
Building components and ancillary parts shall be consistent with
anticipated life of the structure.
Response:
The exterior building materials have been selected for endurance and easy
maintenance. The wall areas are painted concrete, windows are set in an
aluminum sash, parapets are capped with colored metal flashings, and
exterior doors are painted metal. Doors and window sizes have been
selected based on the use of the building and are proportionate to the
scale of the building. A parapet has been provided to create the vertical
height needed for a balanced design.
d. Colors should be harmonious, with bright or brilliant colors used only
for accent.
Response:
The colors as selected are natural tones that are from one family of colors.
These colors blend together to create a soft appearance while the accent
color provides enough contrast so that signage can be placed in that area
and be visible but in keeping with the color family used on the building.
28
Project Consistency Narrative
4501 BUILDING
Page Nine
e. Mechanical equipment or other utility hardware on roof, ground or
buildings should be screened from view.
Response:
The building design provides for a parapet on the north, south and east
side (front).
The roof surface behind the parapet slopes to the west, which enables the
north and south parapet to step and create a more interesting facade. The
height of the parapet is sufficient to block the view of any small mechanical
unit which would be installed on the roof from the public street that is lower
and some distance away.
f. Exterior lighting should be part of the architectural concept. Fixtures,
standards and all exposed accessories should be harmonious with
building design.
Response:
Exterior lighting has been selected and placed to compliment the building
and site design and provide visual focus on the building entry area at night.
g. Monotony of design in single or multiple building projects should be
avoided. Variety of detail, form and fitting should be used to provide
visual interest.
Response:
The street facade provides visual interest through the use of glazing,
recessed entries, landscaping, changes in color, and articulation of the
building surface. The design has detailing, form and balance appropriate
for a warehouse building in an industrial area.
5. Miscellaneous Structures and Street Furniture
a. Miscellaneous structures and street furniture should be designed to
be part of the architectural concept of design and landscape.
Materials should be compatible with buildings, scale should be
appropriate, colors should be in .harmony with •buildings and
surroundings, and proportions should be to scale.
Response:
The building has no street frontage that can be developed because of the
drainage channel and the wetland buffer. At this time no miscellaneous
structures or street furniture is proposed.
b. Lighting in. connection with miscellaneous structures and street furniture
should meet the guidelines applicable to site, landscape and buildings.
Response:
No lighting is proposed at this time.
29
Project Consistency Narrative
4501 BUILDING
Page Ten
Consistency with adopted plans and regulations (TMC 18.100.030)
6. Demonstrate the manner in which the proposal is consistent with, carries
out and helps implement applicable state laws and the regulations, policies,
objectives and goals 'of the City of Tukwila Comprehensive Plan, the City of
Tukwila's Development Regulations and other official laws, policies and
objectives of the City of Tukwila.
Response:
Comprehensive Plan — The development is designated under the Comprehensive
Plan as C /LI. The purpose of this plan designation is to provide area that can
be used by commercial and light industrial uses that will be compatible with
other similar uses. The goal of the comprehensive plan for this area is to
provide employment and revitalize existing properties. The proposal to
construct this facility meets the goals of the plan for four reasons.
1. The use is allowed under the under laying zoning district.
2. The project will be owner occupied and as such brings a new business into
the community which provides employment.
3. This development will result in additional tax income for the City
4. As a result of the development of this facility, a property that is in a
degraded state will be restored to state that will improve the neighborhood,
and relate to the surrounding land uses.
Development Regulations — The development regulations for this property are
listed in Chapter 18.30 of the Zoning Code and Title 18, the critical areas
ordinance (TMC 18.06. - -), in Title 18, and in the Design Criteria Industrial
Properties (TMC 18.60.050A). The project, as presented, is designed. to
comply with those regulations, design standards, and the design intent of those
regulations.
WAC Regulations — The property is subject to WAC Chapter 51 and as illustrated
complies with the intent of those regulations.
Other Laws, Policies, and Regulations — The project has been through the
preapplication process with the City. As part of that process, the City provided
the applicant with a comprehensive listing of all of the development
regulations, mitigation measure that might be required, policies, and design
objectives. The proposed project has been designed to comply with those
regulation, policies, mitigation measure, laws, Title 18, and ordinances
provided.
Project Consistency Narrative.doc
(LMA #08 -114)
30
attachment b
site plan
project statistics
index to the drawings
legal description
general notes
project description
deferred submittal list
W
N
4501 BUILDING
S. 134th STREET
TUKWILA, WASHINGTON
SHEET - 3 -19 -13
EAST ELEVATION
WEST ELEVATION
SOUTH ELEVATION
NORTH ELEVATION
WtST ELEVATION
landscape plan
NORTH
SCALE: 1" = 30°
4501 BUILDING - MITIGATION Plan
NE 1/4 OF SEC. 15, TWP. 23 N, RGE. 4 E, W.M.
TAX PARCEL ID NO.: 261320 -0045
VICINITY MAP
NOT TO tCALE
SURVEY BY:
W
01
W
0)
SCALE= 1" 1°
PLANTING AND STAKING DETAIL
4501 BUILDING - I1lIITI TION P
NE 1/4 OF SEC. 15, TWP. 23 N, RGE. 4 E, W.M.
TAX PARCEL ID NO.: 261320 -0045
SPLIT RAIL FENCE DETAIL
SILT FENCE DETAIL
SUFFER GRASS SEEDING
EXISTING WOODY DEBRIS
IN STREAM CHANNEL
STREAM SIGN DETAIL
PLANT SCHEDULE
ON-SITE STREAM CHANNEL
DEN PARCEL ID NO.: 2613n-0045
FEFFEEF 'OF Of;
POEFF PEEP-
W
BENCHMARK
AoRAAG r EGRESS EAGRAAA
LEGAL DESCripTIONS